Are you a new visitor to this site? Click on the Home Link on the left for background information
In 2007   1,600,000 ppt dioxin found in the Saginaw River and 100,000 ppt in the Tittabawassee River, that's over 17,000 / 1,000 times higher than the States safe level of 90 ppt for direct contact in residential areas.
WB01727_.gif (697 bytes) Click here to watch The Long Shadow video  Take a Tour

WB01727_.gif (697 bytes)
04/19/13  Spring Flood on the Tittabawassee

Significant Tittabawassee River flooding this spring but nothing like in 1986
                                                Flood Stage  Flood Crest

24 33.94 (9/13/1986)

Current National Weather Service FLOOD WARNING For Monday, Apr 22, 6:17am


Pictures from around the Tittabawassee flood plain Thursday 4/18/13

State Street       
River Road        
Imerman Park    

Click here for current Tittabawassee River data from the USGS

And for those that might be concerned, yes the dioxin is being redistributed once again.  It's still there.

WB01727_.gif (697 bytes)
09/09/12  Minimizing the Harm That Will Result from the Dioxin Contamination of the Environment of the Saginaw Bay Watershed

During the course of my work as the Director of Cancer Action NY, I became aware of the dioxin contamination of the Tittabawassee River. I decided to join into the effort to minimize the harm that will result from the presence of dioxins and other industrial toxicants in the environment of the Saginaw Bay watershed. A considerable number of Midland County residents have been exposed to dioxin, which was released to the air and waters of the Tittabawassee River by the Dow Chemical Company facility located in the City of Midland. These exposures have increased the risk of developing dioxin exposure related damages to health amongst that population. The most effective way to minimize the harm that results from past dioxin exposures is to minimize current and ongoing exposures to dioxins and other POPs. Educational outreach is a key strategy for accomplishing exposure minimization.

In June 2012, I gave a brief presentation on the subject of persistent organic pollutants (POPs) exposure minimization education during the public forum portion of the Midland County Board of Commissioners meeting. Having thus initiated a dialogue on the subject, I sought the opportunity to make a full presentation to the Board of Commissioners. Mark Bone, Chair of the Board of Commissioners invited me to make the full presentation. I will be making an agenda presentation on the subject of POPs exposure minimization education to the Midland County Board of Commissioners at its October 9th, 2012 meeting. The meeting begins at 9:00 AM and takes place in the first floor meeting room of the Midland County Government Building. The presentation will be based upon a PowerPoint presentation that was developed jointly by Cancer Action NY with the assistance of Debra Kraus, a prominent member of the Agent Orange Working Group.

The contamination of the global food supply with persistent organic pollutants (POPs) began in the early 1900s. Monsanto Corporation began manufacturing and distributing PCBs in the 1930s. DDT use became widespread in the 20th century. Use of 2,4,5-T, which contained a large quantity of dioxin byproduct, occurred extensively throughout the United States, Canada and New Zealand during the mid-1900s. Brominated flame retardants have been used heavily during the course of the later half of the 20th century. The feeding of waste animal fat to food animals has greatly multiplied the quantities of POPs in the mainstream food supply. It is only in organic livestock production that a prohibition against this dangerous feeding practice exists. Plastics production has increased rapidly during the past 60 years. Disposal of waste plastics via open waste burning and incineration has created and released into the outdoor atmosphere vast quantities of dioxins and PCBs. As a result of these careless and heavy uses of man-made chemical substances, the animal fat portion of the food supply has come to contain dangerous levels of total POPs. This health damaging degree of POPs contamination of environment and food supply has existed since as early as the 1960s.

POPs contamination has existed for a sufficient period of time for a large number of people to become sick. Those people residing in the vicinity of POPs contaminated sites: the GM Powertrain Superfund Site located in St. Lawrence County, New York State on the St. Lawrence River West of Akwesasne, the Tittabawassee River-Saginaw River Superfund Site in MIdland County and Bay County in the state of Michigan, the most heavily contaminated portion of the Hudson River Superfund Site in the Town of Fort Edward in Washington County, New York State, and the American War dioxin hotspots at Bien Hoa, Da Nang and Phu Cat in Vietnam have received some of the heaviest exposures to POPs due to the fact that they have breathed POPs that evaporate from these sites in addition to having eaten POPs when consuming local fish and wildlife. These exposures took place in addition to exposures received via consumption of mainstream food supply items containing background levels of POPs. Several of these populations have been the object of extensive epidemiological studies. Accidental poisoning incidents have occurred during the past 100 years, which resulted in the sickening of large numbers of people. These populations have also been studied. The volume of scientific literature describing serious damages to health resulting from POPs exposure has grown large. Consensus now exists in the scientific research community that current levels of POPs exposure for the general population are of such magnitude that minimization of exposure is warranted.

The world's governmental public health entities: World Health Organization (WHO), United States (US) Centers for Disease Control and Prevention (CDCP), US Food and Drug Administration (FDA), US Environmental Protection Agency (EPA), Health Canada, and the European Commission's Directorate General for Health and Consumers have failed to warn the general public of the avoidable POPs exposure health hazard. This failure has taken place due to the nearly total control that is exerted by corporations over the world's governments. Obsessive interest in profit making has caused the corporate powers to turn a deaf ear to calls from activists and scientists for provision of such a warning.

In 2010, the WHO published, "Persistent Organic Pollutants: Impact on Child Health". This public health policy guidance document calls for a worldwide effort to minimize children's exposure to POPs. Cancer Action NY has advocated for publication of a POPs health hazard advisory by the WHO, the Directorate General for Health and Consumers, the US FDA, and Health Canada since 2010. No governmental public health entity has yet published any such document.

In collaboration with Cancer Action NY, the CDCP has recently begun to create two documents, one on dioxins and another on PCBs. According to Dr. Michael Hatcher, in the CDCP's Agency for Toxic Substance and Disease Registry (ATSDR), these documents will present the message that current levels of dioxin and PCB exposure are harming Americans who consume average quantities of animal fats. These documents are intended for use in the education of physicians. Upon completion of these educational pieces, ATSDR plans to produce spin-off documents intended for use educating the general public. This is a slow way of providing a warning of a major avoidable disease hazard. It is clear that corporate pressures are limiting the ability of the CDCP to take action.

Scientists and activists are not controlled by corporations. In the US, we enjoy freedom of speech and are committed to exercising that freedom for the benefit of the general public. Cancer Action NY has published a POPs Health Hazard Advisory and placed this educational document on the internet at the URL which follows.

Cancer Action NY continues to advocate for action by governmental public health entities around the world to warn the populations that they serve about the POPs exposure health hazard. Thus far our greatest success has been with the Albany County Public Health Department. The website of the Albany County Public Health Department now presents a dioxin exposure reduction educational message. In April of 2011, the St. Lawrence County Legislature considered a POPs exposure minimization education resolution that would have established a POPs exposure minimization education project within the St. Lawrence County Public Health Department. That resolution was not adopted. Nonetheless, we are making steady progress toward the day when POPs exposure minimization education will be provided by the St. Lawrence County Public Health Department.

My presentation for the Midland County Board of Commissioners is given in advocacy for the adoption of a resolution that would establish a POPs exposure minimization educational outreach within the Midland County Public Health Department. I have discussed POPs exposure minimization education with Michael Krecek, Director of the Midland County Public Health Department. Mr. Krecek has taken the position that the 2010 WHO report calling for governmental action to minimize children’s POPs exposure is well founded in the scientific literature. I believe that POPs exposure minimization education will soon be part of the work of the Midland County Public Health Department. Learning to avoid the POPs exposures entailed in consumption of the animal fat foods available in the mainstream food supply will confer a great amount of public health protective benefits in Midland County.

Donald L. Hassig, Director Cancer Action NY Cancer Action News Network
P O Box 340
Colton, NY USA 13625

WB01727_.gif (697 bytes)
06/01/12  State approves City of Midland dioxin cleanup plan, nothing for river residents

Excerpts from Michigan Radio article

After years of back-and-forth between residents, regulators and Dow Chemical, a massive clean-up of contaminated soil in Midland is getting under way.

The state approved the cleanup plan today. It calls for soil testing on 1,400 properties. Officials are looking for dioxins. Those are byproducts of chemical manufacturing. The toxins have been linked to health problems, including cancer. ...

"After all the meetings I've attended over the years and everything, and being asked why's this taking so long and everything, it's nice to be able to tell somebody the actual clean-up is really being done," said Jim Sygo, deputy director of the Department of Environmental Quality.  ....

Environmental groups say they think the number should be lower, and take into account health risks other than cancer.  ...

“If you know the history of the city of Midland, and how political this has been, and how much push-back there has been from city fathers, from the business community, from the Chamber of Commerce, from Dow Chemical, over decades, I think only then can you truly appreciate…this is significant progress for that community,” said Michelle Hurd Riddick of the Lone Tree Council. ...

Click here to view the full Michigan Radio article

TRW note:  While this may be "progress" for the City of Midland, it does absolutely nothing for the families living downstream of Midland alongDow Midland plant in the moonlight
The 22  miles of the dioxin contaminated Tittabawassee River and its flood plain.  The cleanup plan for everyone else has been stalled for years as Dow and the Chamber of
Commerce manipulate the EPA to do it's bidding.




WB01727_.gif (697 bytes)
03/05/12  "Sound Science" debunked.

Science Prevails


The significance of EPA’s recent release of the non-cancer portion of the dioxin reassessment cannot be overstated.


In 2005 many Dow Chemical apologists across the region and in Lansing insisted that the Michigan Department of Environmental Quality abandon the use of 90 ppt for dioxin in soil for residential contact. Hoping to improve the outlook on Dow’s pervasive contamination as well as to undermine MDEQ’s regulatory authority this cadre of apologists insisted on using the EPA’s outdated (1980’s) soil contact criteria of 1,000 ppt for dioxin in soil.


These apologists also cited, misused and incorrectly portrayed the Centers for Disease Control (ATSDR) use of 1,000 ppt because it was convenient for them to do so.


In public meetings and press releases alike the Dow Chemical apologists demanded " sound science” even as they attempted to legislate the use of EPA’s outdated science. They attempted to legislate the use of every Dow funded study while legislating the elimination of MDEQ’s authority overseeing corrective action. There was nothing these apologists would not do or skew to accommodate Dow’s agenda. Their idea of sound science was whatever Dow Chemical told them or whatever outcomes were divined in any one of the many studies funded by Dow. There was no room for independent scientists or public health advocates. No room or considerations for vulnerable populations


Dow apologists, supporters and dioxin deniers ignored the following:


· A plethora of current science on dioxin toxicity


· 1998 EPA directive (OSWER) allowing a state’s more stringent contact criteria be used in place of EPA’s 1,000 ppt


· 2006 Agency for Toxic Substances and Disease Registry letter from the agencies director, Dr. Peter Frumkin:


….we understand that certain Michigan state legislators have been referring to our Action Level in proposed legislation to modify the state cleanup for dioxins in soil. This is an example of how our guidelines have been applied in ways that we did not intend.”


· The algorithm used by MDCH/MDEQ to arrive at the 90 ppt


· The fact that no other community or state in the nation was using any number even close to 1, 000 ppt e.g., Florida 7.0 ppt, Oregon 3.6 ppt, Iowa 14 ppt


· EPA’s support for Michigan’s 90 ppt


· The evolving science on the toxicity of dioxin at lower exposure rates

· The vulnerability of children, women, infants or the developing fetus



Hell bent on doing Dow’s bidding, Dow Chemical became the only conduit of information for these apologists. They refused to hear any truth, argument or science not stamped with the Dow seal of approval.


Two weeks ago, on February 17th EPA released the non-cancer portion of the dioxin reassessment. For the first time ever the agency established a reference dose for dioxin of .7pc/kg/day. This number is important because it speaks to the toxicity of dioxin at low levels. When the science is distilled a soil concentration of about 49 ppt for dioxin in soils is extrapolated.


Michigan’s public servants take serious their commitment to public health and the protection of people and natural resources in this state. MDEQ’s use of 90 ppt was correct and appropriate. But because of political interference by Dow and their apologist the states’ protective number was supplanted by a politically expedient and outdated number.


The disservice foisted on the taxpayers and the people of the Saginaw Bay Watershed is surpassed only by the injustice done to property owners, families and children impacted daily because they happen to live on dioxin contaminated property.


So who embraced outdated science, politics and Dow’s agenda?


Senator Roger Kahn

Senator John Moolenaar

Senator Mike Gotchka

Governor Jennifer Granholm

Public Sector Consultants

Representative Ken Horn

Senator Tony Stamas

Local Chambers of Commerce

City of Midland

Congressman Dave Camp


(The elected officials and community leaders who sat silent and let it happen have to take some blame too)


Supplanting the state’s more protective number with a 1,000 ppt denied many residents the opportunity for interim response activities over the past several years. It has resulted in lengthy delays and wasted taxpayers’ dollars, undermined the importance of legitimate science in policy decisions and placed the polluter’s agenda ahead of public health protection.


Corporate driven politics, whose primacy is embraced by these elected officials, is anathema to the work of the people and the transparency needed for communities be engaged. The regulatory timidity that ensues when these legislators attack good public servants who rely on legitimate science further hinders public engagement. It is an affront to democracy.


The activities of the aforementioned individuals are not abstractions and their efforts to undermine public health are real. Much works remains to be done. EPA needs to speak loudly and clearly about the toxicity of dioxin and the unique contamination issues that confront this Michigan watershed awash in dioxin.


MDEQ’s 90 ppt was not junk science. Their science has been vindicated and EPA’s recent release speaks to the ever-increasing base of knowledge on the toxicity of dioxin.


Senators Kahn and Moolenaar, perhaps two of the most outspoken proponents of outdated science will hopefully embrace the recent release by EPA with as much veracity as was exhibited in their in 2005 press conference demanding MDEQ use the outdated 1,000 ppt.



Michelle Hurd Riddick
Lone Tree Council
cell 989-327-0854

WB01727_.gif (697 bytes)
02/20/12  EPA praised for release of noncancer Dioxin Reassessment.

Rep. Markey commends EPA action
 The State Column | Monday, February 20, 2012

Congressman Edward J. Markey (D-Mass.), top Democrat on the Natural Resources Committee and senior member of the Energy and Commerce Committee, today praised the Environmental Protection Agency (EPA) announcement that the non-cancer health assessment of dioxin has been finalized after two decades of delays. Dioxin is the name given to a group of toxic chemicals that are released as a byproduct of industrial processes and have the ability to accumulate in the food chain and remain in the environment for years. Exposure to dioxin causes a wide range of health impacts and has been associated with delays in motor skills and neurodevelopment in children, as well as impacts on hormones that regulate growth, metabolism and reproduction. Dioxin also has been classified as a human carcinogen by the World Health Organization and the National Toxicology Program. The American Chemistry Council, whose member companies could be impacted by any limits on dioxin releases into the environment, had pressured the EPA to delay release of the reassessment and recommended unnecessary additional reviews.

“Today, the Environmental Protection Agency has taken a major step toward protecting the public from dioxin by shining light on some of the health impacts this dangerous chemical has on the public,” said Rep. Markey. “By releasing this important part of the scientific assessment, we can begin to develop a cohesive plan to safeguard American families from dioxin exposure. It is also time for industry groups and chemical companies to stop their efforts to block completion of this important public health document. I urge EPA to continue this progress forward by moving quickly to finalize the cancer portion of the dioxin assessment as well as its cleanup goals for soil at waste sites containing dioxin.”

The EPA completed its first health assessment of dioxin in 1985, finding that the cancer risk to humans from dioxin exposure is by far the highest defined for any man-made chemical. This finding was challenged by the industries whose operations would be affected by any limits on dioxin releases into the environment. EPA subsequently began a review of the health impacts of dioxins that has been in process for more than 20 years. The Agency split the assessment into two portions covering the non-cancer impacts and cancer impacts and today released the non-cancer portion of the assessment with a commitment to release of the cancer portion “as expeditiously as possible.”

The EPA’s most recent Toxicity Release Inventory (TRI) indicates that dioxin releases rose by 18 percent from 2009 to 2010. Dioxin air releases alone increased ten percent during this time period.

According to the Centers for Disease Control, dioxins are present in the blood of 95 percent of Americans. Dioxin has also been found in breast milk and in blood samples taken from newborns. Because of the persistence of dioxin, it has been targeted for international phase-out by a treaty signed by 170 nations across the world.

Read more:

WB01727_.gif (697 bytes)
02/17/12  EPA releases noncancer Dioxin Reassessment.

The following from the EPA's Dioxin website February 17, 2012 update

On February 17, 2012, EPA finalized its final Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments, Volume 1.  This document provides hazard identification and dose-response information on 2,3,7,8- tetrachlorodibenzo-p-dioxin (TCDD) and the most up-to-date analysis of non-cancer health effects from TCDD exposure. The report also include an oral reference dose (RfD) and a detailed and transparent description of the underlying data and analyses.

EPA’s Science Plan for Activities Related to Dioxins in the Environment

EPA announced the release of the final Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments, Volume 1, in a February 17, 2012, Press Release. This document provides hazard identification and dose-response information on 2,3,7,8- tetrachlorodibenzo-p-dioxin (TCDD) and the most up-to-date analysis of non-cancer health effects from TCDD exposure. The report also include a reference dose (RfD) and a detailed and transparent description of the underlying data and analyses. EPA will complete Reanalysis, Volume 2, containing the full dioxin cancer assessment, as expeditiously as possible. In Volume 2, EPA will complete the evaluation of the available cancer mode-of-action data, and will augment the cancer dose-response modeling, including justification of the approaches used for dose response modeling of the cancer endpoints, and an associated quantitative uncertainty analysis.


bulletVolume 1 (noncancer) of the Reanalysis contains some descriptive cancer information. The cancer information in Volume 1 should not be used for regulatory or risk management decision-making.
bulletVolumes 1 and 2 of the Reanalysis will supersede the 2003 draft dioxin Reassessment.
bulletThe 2003 draft dioxin Reassessment includes a disclaimer that the document should not be cited or quoted. As such, information in this draft document should not be used for regulatory or risk management decision-making.

2,3,7,8-Tetrachlorodibenzo-p-dixoin (TCDD) Support Documents

You will need Adobe Reader to view some of the files on this page. See EPA's PDF page to learn more.

bulletEPA's Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments, Volume 1 (PDF) (2012) (344 pp, 3.8M)
This document comprises the first of two EPA reports (U.S. EPA's Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments Volumes 1 and 2 [Reanalysis Volumes 1 and 2]) that, together, will respond to the recommendations and comments on 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) dose-response assessment included in the 2006 NAS report, Health Risks from Dioxin and Related Compounds: Evaluation of the EPA Reassessment. This document, Reanalysis Volume 1, includes (1) a systematic evaluation of the peer-reviewed epidemiologic studies and rodent bioassays relevant to TCDD dose-response analysis; (2) dose-response analyses using a TCDD physiologically based pharmacokinetic model that simulates TCDD blood concentrations following oral intake; and (3) an oral reference dose (RfD) for TCDD.
bullet Appendices for Toxicological Review of 2,3,7,8-Tetrachlorodibenzo-p-dixoin (TCDD) (PDF) (1521 pp, 13.5M) (Appendices only)
bulletSupporting Reference: Recommended Toxicity Equivalence Factors (TEFs) for Human Health Risk Assessments of 2,3,7,8-Tetrachlorodibenzo-p-dioxin and Dioxin-Like Compounds (December 2010)
bullet 2,3,7,8-Tetrachlorodibenzo-p-dixoin (TCDD) IRIS Assessment Summary (2012)
bullet EPA's Dioxin Website

WB01727_.gif (697 bytes)
02/16/12  Dow to clean Midland dioxin tainted homes or offer relocation, nothing for the Tittabawassee River Residents

When I first heard this news, I was actually sick to my stomach for all the residents who live downstream on the Tittabawassee River and floodplain. The contamination there is much higher, and some of those residents have pulled their hair out for the last decade trying to get someone, anyone, Dow, the courts, MDEQ, MDCH, or EPA to buy out their properties so they could leave their contaminated homes.

EPA's solution is for Dow to do some landscaping. It's sickening.

I don't buy that Dow is willing to buy these Midland properties out of the goodness of their hearts. Notice they are only willing to buy lots adjacent to their plant, in industrial/commercially zoned areas. The area they are willing to address in Midland does not even cover the entire contaminated area, and at a clean-up number (250) far higher than the State of Michigan Residential Direct Contact Criteria of 90 ppt TEQ or the EPA's interim safe level of 72 ppt TEQ .

Residential Direct Contact Criteria. Hazardous substances can cause developmental effects. Residential and commercial direct contact criteria are protective of both prenatal and postnatal exposure. The state of Michigan has set a level of 90 ppt TEQ RDCC for dioxin. The value of 90 ppt TEQ is also the states soil cleanup criteria for residential soils. If a hazardous substance poses a carcinogenic risk to humans, the cleanup criteria derived for cancer risk under this section (part 201) shall be the 95% upper bound on the calculated risk of 1 additional cancer above the background cancer rate per 100,000 individuals. MDEQ sampling in the Tittabawassee flood plain have detected dioxin levels 100 times higher than the states RDCC.

Article from the Sacramento Bee: Dow agrees to clean dioxin-tainted properties

WB01727_.gif (697 bytes)
02/01/12  EPA fails to meet Dioxin Reassessment deadline again after 27 years of Dow's influence

Lone Tree Council

P.O. 1251, Bay City, Michigan 48706

(Fighting for environmental justice since 1978)

February 1, 2012

For Immediate Release


Contact: Michelle Hurd Riddick - Lone Tree Council 989-327-0854

Terry Miller - Lone Tree Council Chair 989-450-8097

Tracey Easthope MPH - Ecology Center 734-369-9268


Toxic Dioxin – Public Health Advocates, Environmentalists Condemn Failure to Release Dioxin Health Report


Michigan Left in the Dark about Dioxin’s Toxicity as EPA’s Voice Remains Silent


Advocates Urge EPA to Immediately Release Dioxin Health Report, Decry 27 Years of Delays Due to Dow Chemical’s Influence


(Mid Michigan) For twenty-seven years dioxin impacted communities, like Saginaw, Bay City and Midland have waited for EPA to articulate the science findings on the toxicity of dioxin. Today, Lone Tree Council and the Ecology Center denounce the US Environmental Protection Agency’s failure to once again release their report on the non-cancer impacts of dioxin. In August of 2011 EPA committed to a January 31st deadline.


The failure to finalize any portion of the report represents a political, moral and ethical failure. Dioxin has become the textbook example of how industry can successfully delay science-based progress on toxic chemicals in this country.


“Since the mid 1980’s when the Reagan administration permitted Dow Chemical to rewrite the EPA report on dioxin, administration after administration in the White House has cowed to this company and their lobbyists”, said Michelle Hurd Riddick of the Lone Tree Council. “Public health is being sacrificed, our water resources disregarded and science is being ignored once again in an effort to placate the moneyed interest. It is indefensible that this administration capitulated to industry, reaffirming the belief of most Americans that corporations have greater influence and more control and rights than people”, says Hurd Riddick.


In recent months, consistent with history, the chemical industry has been working behind closed doors to conceal hide and distort the truth about the dangers of dioxin. At the same time, Vietnam Veterans, breast cancer advocates, public health organizations, and environmental justice leaders have stood shoulder to shoulder and urged EPA to do what’s right for the health of American children and families. Over the past three weeks a broad coalition of organizations have written to EPA.


Cancer, diabetes, infertility, learning disabilities and other chronic diseases linked to dioxin exposure are extremely costly to American taxpayers in terms of health, quality of life and regional economic development. EPA missed yet another deadline to release their report on dioxin, one of the most toxic chemicals on the planet.


Tracey Easthope MPH, "Finalizing this study matters to people in Michigan. We are home to one of the largest dioxin contamination sites in the country. People have been living with this chemical in their bodies, in their food supply, and in their homes for decades.”

“This report is a great example of why people are so angry and frustrated by the influence of powerful interests that trample the public interest. How is it possible for industry to delay the release of a report for 27 years? How can a system become this dysfunctional”? said Ms Easthope of the Ann Arbor based Ecology Center.



According to EPA, dioxin releases increased by 18% from 2009-2010 nationally. Dioxin air releases increased by 10%. Dioxin’s effects on the immune system of the developing organism appear to be among the most sensitive endpoints studied.



Terry Miller, Lone Tree Council chairman is calling on the administration to support EPA’s scientific findings and release the non-cancer portion of the report as promised. “The failure of EPA to publicly affirm their science, to find their voice on the toxicity of dioxin, is an abysmal failure of public health policy “, said Miller.” How many more years will Dow Chemical and industry lobbyists be permitted to frame the issue and science on dioxin”?



Joining the Dow Chemical lobby, in anticipation of the release by EPA, the corporate agriculture industry circled their wagons, creating the Food Industry Dioxin Working Group (FIDWG) to lobby against the EPA release. The FIWG member organizations:


American Farm Bureau Federation
American Feed Industry Association
American Frozen Food Institute
American Meat Institute
Corn Refiners Association
International Dairy Foods Association
National Chicken Council
National Grain & Feed Association
National Meat Association
National Milk Producers Federation
National Oilseed Processors Association
National Pork Producers Council
National Renderers Association
National Turkey Federation
Pet Food Institute
United Egg Producers


Timeline of current EPA activities, courtesy of CHEJ, can be found at

WB01727_.gif (697 bytes)
01/15/12  Lisa Jackson, do not delay the EPA's Dioxin Reassessment

Lone Tree Council
P.O. 1251, Bay City, Michigan 48706

(Fighting for environmental justice since 1978)

January 12, 2012

The Honorable Lisa P. Jackson
U.S. Environmental Protection Agency
1200 Ariel Rios Building
Washington, DC 20460

Dear EPA Administrator Jackson:

Thank you for your ongoing attention to dioxin. The Dioxin Reassessment document isextremely important to the health of the American people and we applaud your efforts to bringthis long delayed process to closure.

We are writing to strongly urge you to finalize the non-cancer dioxin IRIS assessment by the end of January, and expeditiously release the cancer dioxin IRIS assessment as you have pledged todo. It is of paramount importance to communities like ours that are highly contaminated withdioxins from Dow Chemical’s world headquarters in Midland Michigan.

In May of 2009 you personally assured us in a much appreciated phone conversation that the release of the dioxin reassessment was a priority for you. We are hopeful that this New Year will see this come to fruition. As you know, thousands of acres of flood plain and 52 miles of river are highly contaminated with Dow’s dioxin. Game, fish and soil advisories abound in the region. EPA says Dow Chemical is the primary contributor of dioxin to Lake Huron. It was 10 years ago this month that the public was informed of the high levels of dioxin found at the confluence of the Saginaw and Tittabawassee Rivers. Thirty plus years since high levels of dioxin were found inWalleye in the river. Generations of children, families, and low income, migrant and subsistence fishers have been poisoned. It is time release the dioxin reassessment.

Since 1985, efforts by EPA to assess the risks of dioxin have been delayed time and time again. Scientists at EPA have long concluded dioxin and dioxin-like compounds are highly toxic, but a strong coalition of industries responsible for generating dioxins as a by-product of production and disposal have successfully stalled the completion of this health assessment report. As EPA has continued to work on the Dioxin Reassessment, people in communities across the country are continuing to be exposed to this highly toxic chemical. We are very concerned that industry is attempting to stall the release of this important report yet again. EPA, Region V, has documented in detail the recalcitrance of Dow Chemical in dealing with their dioxin contamination in mid- Michigan. Is it Lone Tree Council’s position, that the American Chemical Council’s call for further delay of the dioxin reassessment is part and parcel with Dow Chemical’s efforts to delay a good cleanup and obfuscate the toxicity of dioxin.

On August 29, 2011, EPA announced its final plan for completing the Dioxin Reassessment.  EPA committed to completing the non-cancer portion of the reanalysis and posting it to the IRIS database by the end of January 2012 and to then complete the cancer portion of the reanalysis “as quickly as possible.” EPA stated that once the Agency completes both the non-cancer and cancer portions of the Reanalysis, the Dioxin Reassessment would be considered final.

We are extremely dismayed that the American Chemistry Council (ACC) and other industry trade associations are once again pressuring EPA to further delay the release of this important document. We believe the American public has a right to know about the health consequences of exposure to dioxin, and EPA needs to take steps to protect American families from this unnecessary harmful class of chemicals.

We urge you to meet your schedule of finalizing the non-cancer portion of the dioxin reanalysis by the end of this January and to finalize the cancer portion as quickly as possible thereafter as you have pledged.

Thank you for your attention to this matter, and for your commitment to protecting America’s

health and environment.


Michelle Hurd Riddick
Lone Tree Council
2421 Kipling
Saginaw, MI 48602

Cass Sunstein, Administrator, Office of Information and Regulatory Affair
Nancy Sutley, Chair, White House Council on Environmental Quality (CEQ)
Paul Anastas, Assistant Administrator, Office of Research and Development, EPA
Rebecca Clark, Acting Director, National Center for Environmental Assessment,
Terry Miller, Chair, Lone Tree Council
Tracey Easthope MPH, Ecology Center Ann Arbor, MI
Cyndi Roper, Michigan Clean Water Action
Chris Kolb, Michigan Environmental Council
Kathy Henry, Tittabawassee River Watch
Pat Bradt, Zilwaukee Twp (Saginaw River dredge slurry pit)

Click here for PDF copy of letter

Click here for a history of the Dioxin Reassessment

WB01727_.gif (697 bytes)
12/21/11  Watch video of Community Advisory Group December 12, 2011 Meeting

Click here to view a video of the December 12, 2011 Community Advisory Group in action.  Lone Tree Council will be taping the monthly meetings and posting on the League of Women VotersŪ of the Flint Area web site.  You will need Adobe Flash Player to view.

The Saginaw-Tittabawassee Rivers Contamination Community Advisory Group is open to the public and meets at 6 p.m on the third Monday of the month at Saginaw Valley State University Regional Education Center, 7400 Bay Road.

If you have questions or need special accommodations at the meeting contact:

Patricia Krause

You may also call Region 5 toll-free at 800-621-8431, 9:30 a.m. to 5:30 p.m., weekdays. More information is at .

WB01727_.gif (697 bytes)
11/06/11  EPA and Dow sign agreement to start sediment clean up by Dow Midland Plant

November 2011

EPA and Dow Chemical Co. signed a legal agreement on November 2, 2011 requiring Dow to clean up sediment in Segment 1, a three-mile stretch of the Tittabawassee River next to Dow’s Midland Plant. There are six Sediment Management Areas or SMAs identified within Segment 1 where chemical pollutants are targeted for cleanup. Most of the pollution in Segment 1 is from chlorobenzenes and other chemicals rather than dioxin. A form of the contamination, dense non-aqueous phase liquid (DNAPL), a heavy liquid made up of materials that do not mix with water and sinks to the bottom of the river, is targeted for cleanup in three of the SMAs. EPA selected its plan after carefully considering public comments. EPA’s cleanup plan for each is as follows.

SMA 1 – Place a clean cap over contaminated sediment to isolate and stabilize the sediment. SMAs 2 and 3 – Remove and treat DNAPL, isolate contaminated sediment with sheet pile and a cap, and capture water within the sediment and treat it. SMAs 4 and 5 – Place a clean cap over contaminated sediment. SMA 6 – Dredge and dispose of sediment contaminated by ethyl parathion; remove and treat DNAPL; isolate remaining contaminated sediment with sheet pile and a cap; and capture water within the sediment and treat it. Materials will be treated and disposed at approved locations, sites will be monitored during and after the cleanup and the cleanup systems will operate and be maintained.

Related Documents at

EPA Proposed Cleanup Plan for Polluted River Section
• Enforcement Action Memorandum w/Responsiveness Summary as Attachment C
• Administrative Settlement Agreement and Order on Consent for Segment 1

"Patti Krause" <>

WB01727_.gif (697 bytes)
10/19/11  Garabrant due bonus from Dow?

EPA, MDEQ won't use U-M dioxin study in decision making

30 percent of homeowners along Tittabawassee River declined EPA's early dioxin cleanup

Regardless of the EPA's stance on the U of M study, the constant onslaught of misinformation by Garabrant has evidently had it's desired effect on the local populace.


WB01727_.gif (697 bytes)
09/09/11  State extends public comment period on Dow pollution permit to 9/23/11

The public comment period for the proposed reissuance of NPDES Permit No. MI0000868 to the Dow Chemical Company for the Dow Chemical Company, Michigan Operations, Midland Plant Site has been extended through Friday, September 23, 2011. The public notice documents, including the draft permit, are available via the Internet at  - click on ‘Permits on Public Notice’. If you have any questions regarding this Public Notice, please contact me at  or by telephone at 517-241-7503.

Tarek Buckmaster
Lakes Erie and Huron Permits Unit
Permits Section, Water Resources Division
Michigan Department of Environmental Quality
517-241-7503 Fax: 517-241-8133

WB01727_.gif (697 bytes)
09/09/11  Alliance for the Great Lakes comments on Dow pollution permit

Sample Comment and conclusion:

Click here for all the details of the Alliances comments, 17 pages of things you should be concerned about

Click here for instrucions on how to submit your own comments and to link to all the related documents.

WB01727_.gif (697 bytes)
08/29/11  EPA to split cancer assessment from non-cancer assessment

EPA Announces Schedule for Dioxin Assessment

Release date: 08/29/2011

Contact Information: Latisha Petteway (News Media Only), , 202-564-3191, 202-564-4355

WASHINGTON - The US Environmental Protection Agency (EPA) announced today that it plans to complete the non-cancer portion of EPA’s Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments, and post the final non-cancer assessment to the Integrated Risk Information System (IRIS) by the end of January 2012. After completing the non-cancer portion, EPA will finalize the cancer portion of the dioxin reanalysis as quickly as possible.

The decision to split the dioxin assessment into two portions, one being the cancer assessment and the other being the non-cancer assessment, follows the release by the Science Advisory Board (SAB) of its final review report of EPA’s Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments on August 26, 2011. This reanalysis report responded to the recommendations and comments included in the National Academy of Sciences' (NAS) 2006 review of EPA's 2003 draft dioxin assessment.

The SAB report indicates that EPA selected the most appropriate scientific studies to support the non-cancer health assessment and the oral reference dose derived in the draft assessment. The SAB also commended EPA for a clear and logical reanalysis document that responded to many of the recommendations offered previously by the NAS. Specifically, the SAB acknowledged that the process the agency used to identify, review and evaluate the scientific literature was both comprehensive and rigorous, and the SAB report noted that "the criteria for study selection have been clearly articulated, well justified, and applied in a scientifically sound manner."

Dioxins are toxic chemicals that share a similar chemical structure and act through a similar mechanism. While dioxin levels in the environment have been declining since the early seventies, dioxins remain a concern because they will continue to enter the food chain through releases from soils and sediments, and they have been the subject of a number of federal and state regulations and cleanup actions.

More information on dioxin:

More information on IRIS:

More information on the SAB Report:

WB01727_.gif (697 bytes)
08/24/11  State to permit Dow to increase toxin discharge into TR to pay off CAG members

The state is about to grant Dow a permit to reduce the water quality in Tittabawassee River and Saginaw Bay by allowing it to increase the levels of toxins discharged.

"The Department proposes that the applicant’s Antidegradation Demonstration, based on information required by Subrule (4) of R323.1098, shows that lowering of water quality is necessary to support the identified important social and economic development in the area."

In other words, more pollution is necessary so that Dow can provide grants to some of it's supporters on the CAG (see 8/4/11 story below):

bulletCharlie Curtis, Saginaw Basin Land Conservancy
bulletMike Kelly, Conservation Fund Watershed Initiative Network (WIN)
bulletWilliam Weber, Saginaw, Bay City, Midland Economic Development Corporation
bullet Annette Rummel,  Great Lakes Bay Regional Alliance

Conflict of interest?  We think so.  Show up and the next CAG meeting and let them know what you think, the CAG meetings are held at 6 PM on the 3rd Monday of the month at SVSU.  Perhaps this bunch of Dow cronies should remove themselves from the CAG?

We wonder what the River residents would think if they even knew this was going on.  It will be going into their backyards, and they haven't been notified of the change in discharge. A public comment notice is hidden on the DEQ website (below), but shouldn't the residents be notified considering it is their backyard?  A local TV news station ran a spot last night of a Chamber of Commerce (aka Great Lakes Bay Regional Alliance) spokes person claiming they want to improve the beaches and water quality of the Saginaw Bay near Bay City to boost tourism?  Curious statement as they evidently support flushing more of the Dow crap into the same river that feeds into the Saginaw Bay and it's beaches.

A public comment period on the proposed permit closes on 9/6/11. You can submit comments online or by mail.  Click here for details on how to submit and to link to all the related documents.

Click here to see what is currently being flushed into the Tittabawassee River and Saginaw Bay, it's not just dioxin

WB01727_.gif (697 bytes)
08/04/11  EPA: End the pro Dow Community Advisory Group bias

Administrator Susan Hedman
Region V EPA
Chicago, Illinois
Dear Administrator Hedman:
I would like to introduce myself. My name is Carol Chisholm and I live on the Dow contaminated flood plains of the Tittabawassee River. In fact according to the state, the plains behind my home are some of the most contaminated property along the river. For the past ten year I have been involved in the Tittabawassee River Watch and Lone Tree Council efforts to address Dow’s horrific contamination of our beautiful river. Was looking forward to meeting with you and am sorry you had to cancel our meeting in Chicago on June 1st.
I purchased my home in 1995 because of the beautiful area. May of 2000 I purchased the lot next with plans of building a new home. In late 2001 it was made public that the Tittabawassee River and its flood plain were contaminated with dioxin. Since the announcement I have been involved with the dioxin contamination issue.
Frankly, I am exhausted with EPA and Dow Chemical. So much talking has gone on and so little progress has been made in the past decade and I have little hope for the future. In an attempt to present the concerns and problems plaguing the resident of Saginaw, I submitted my name and was placed on the CAG. I cannot believe the CAG the EPA assembled; could Dow be any happier?
It is undeniable that most members have an affiliation with and bias for Dow. Their affiliation with Dow creates a conflict of interest that will interfere with their ability to be objective. I requested that the members of the CAG divulge any association they have with Dow. The idea of complete disclosure was shot down every time I made the request and EPA did nothing to make the CAG transparent but then again why would EPA? Most members of the CAG have attended a yearlong leadership school established by the local chamber of commerce in Saginaw, Bay City and Midland. Do you have any idea how much the Chamber of Commerce has worked against cleanup and on behalf of Dow? Did you know or does EPA even care that the person chairing this chamber of commerce leadership group is Dow Chemical’s local legal counsel.
Under the process EPA set up for picking members of the CAG, the head of the Chamber of Commerce would not allow Kathy Henry a seat on the CAG. Dow’s most vocal supporter at the Chamber of Commerce denies someone who has been involved for years and is knowledgeable a seat on the CAG. Way to go! (Should have anticipated the direction of the CAG given our first meeting was in the Boardroom of the Chamber of Commerce.)
You must also look at those on the CAG who have Dow Chemical on their boards or take money from Dow. The conflicts are unreal.
The CAG was to be representative of the polluted community. Saginaw and Bay City are blue-collar communities. The majority of the CAG members have four-year degrees including 4 attorneys. That is not representative of the area. Most of us were skeptical about EPA taking over this site and with good reason. Even if a few of us stayed on the CAG the pro Dow bias and conflict was still dominant.
Never has there been such poor public attendance at meetings since EPA took over. I bet Dow is celebrating. EPA denied relocation to residents and gave Dow the community group it always wanted. Would like to know how else member of the public are expected to communicate with EPA other than the CAG?
I will be putting my energy in the coming months to work with other people and parties interested in cleanup. Below is some information on your EPA CAG.
Carol Chisholm
Saginaw Twp
Region V EPA Established Community Advisory Group for Dow Chemical’s Dioxin Contamination of the Tittabawassee River, Saginaw River and Saginaw Bay.
Jan MccQuire Director of the Midland Area Community Foundation:
bullet GLB Leadership graduate
bullet Mary Draves, Dow’s current PR person on dioxin sits on the board of the Midland Community Foundation.
bullet Dow Chemical and Dow Foundation philanthropy to the Midland Foundation is well known.
bullet Jan’s husband is the CEO of the Dow Garden’s in Midland.
Bill Weber- Sergeant Stone Dock
bullet Member of Dow Chemical’s CAP in Midland
bullet Accepted money from Dow Chemical for the DMDF on the Saginaw River
bullet Dow has voiced interest in using the dredge site
Bob Wiese Thomas Twp Supervisor
bullet Thomas Twp is home to Hemlock Semi Conductor, major employer and joint ventures of Dow Chemical and Dow Corning; billions of dollars of investment in Mr Wiese township.
Rachel Larimore Chippewa Nature Center (CNC)
bullet CNC is member of Chamber of Commerce
bullet Millions of dollars, including initial start up money from Dow Foundation and Dow Chemical
bullet CNC works with the Dow funded MSU eco study on dioxin and wildlife
bullet CNC Board of Directors dominated by Dow employees/retirees

Mike Kelly
Conservation Fund Watershed Initiative Network (WIN)
bullet Sits on Dow’s CAP in Midland
bullet Graduate GLB Leadership School
bullet WIN heavily funded by Dow Chemical (millions)
bullet WIN’s genesis joint venture of Dow and Conservation Fund
bullet Dow Chemical Garret Geer and Jeff Martin sit on WIN’s board.
bullet With the initial leadership of The Dow Chemical Company and ongoing facilitation from The Conservation Fund, WIN has brought people and resources together to balance environmental, economic, social, recreational, and historic priorities, and to leverage ideas and resources toward a common goal—the greater good of future generations
Annette Rummel CEO Great Lakes Bay Visitors Bureau
bullet Chamber of Commerce board of directors
bullet Graduate of GLB leadership school.
bullet Dow sits on Ms Rummel’s board of directors
bullet Ms Rummel’s Administrative Assistant takes minutes for the CAG
Wendy Kanar Attorney with Cline Close & Dyer and
bullet Graduate GLB Leadership School
bullet Law firm represents Great Lakes Bay Regional Alliance (Chambers of Commerce )
July Lincoln Saginaw Attorney
bullet Graduate GLB Leadership School
Laura Ogar Bay City Environmental director
bullet Graduate GLB Leadership School
Mike Espinosa Financial Planner
bullet Graduate of GLB Hispanic Leadership graduate (established with assistance of Dow Chemical’s Jeff Martin)

Drummond Black attorney and former mayor of Midland
bullet Graduate GLB Leadership School
bullet Intervened in 2002 illegal consent order with Dow Chemical releasing Dow from significant liability down river
bullet Supported eliminating facility designation for properties contaminated with dioxin
bullet Proponent and advocate for EPA’s outdated 1,000 ppt
bullet Orchestrated 2004 Midland town hall meeting villainizing MDEQ’s efforts to address dioxin in Midland
bullet Law firm identifies Dow Chemical, several Dow foundations and Dow Kokam as clients

Len Heinzman
President Freeland Lions club
bullet Dow sits on Lions board
bullet Lions club members sold dioxin my ass hats in 2005
bullet Dow is a huge sponsor Walleye Festival
bullet Supported lifting facility designation
bullet Supports use of EPA’s 1000 ppt
Paul Vasold Tittabawassee Twp Trustee
bullet Dow funds Walleye festival in the Twp
bullet Supported lifting facility designation
bullet Use of EPA’s 1,000 ppt
bullet Twp resisted MDEQ efforts at advisory signage for fish and soil
Deb Huntley Dean of School of Science and Engineering SVSU
bullet Two academic chairs funded by Dow.
bullet SVSU in many partnerships with Dow Chemical
bullet Dow funds many projects in School of Science.
Ryan Jankoska Consumers Energy Lineman
Matt DeHues Professor Delta College
Joel Tanner retired teacher
Dave Meyer river resident attorney Smith Bovil
bullet Served on various committees for the Chamber of Commerce

Charlie Curtiss Saginaw Basin Land Conservancy

bullet Funding from Dow Chemical

WB01727_.gif (697 bytes)
08/03/11  New dioxin cancer risk study of women in Seveso Italy supports report of Breast Cancer increase in Midland and Tittabawassee River area?

 "Dioxin Exposure and Cancer Risk in the Seveso Women’s Health Study", a recent peer reviewed paper published by the National Institute of Public Health, provides an update on it's  study of 800+ women exposed to the highest levels of dioxin in a human population on July 10, 1976, during a chemical plant explosion in Seveso, Italy" 

"Individual serum TCDD is significantly positively related with all cancer incidence in the SWHS cohort, more than 30 years later. This all-female study adds to the epidemiologic evidence that TCDD is a multi-site carcinogen. "

The study seems to reinforce the conclusion of another peer reviewed study published in April 2011 (see TRW Current News 4/2/11) which identified higher breast cancer rates in women living in the city of Midland and in the vicinity of the Tittabawassee River:

"These findings suggest that increased breast cancer incidences are spatially associated with soil dioxin contamination. Aging is a substantial factor in the development of breast cancer. Findings can be used for heightened surveillance and education, as well as formulating new study hypotheses for further research."




WB01727_.gif (697 bytes)
07/30/11  Dow faces $2.5 million fine for violating waste regulations

Dow Chemical faces a $2.5-million fine for conditions at its Midland plant, where inspectors found violations of air, water and waste regulations between 2005 and early 2007.

WB01727_.gif (697 bytes)
07/22/11  Henry v Dow having impact on other toxic tort cases

bullet Lawyers rush to cite Henry v. Dow
bullet Kirkland wields Wal-Mart v. Dukes ruling to knock out Dow Chemical toxic tort class
bullet Judge blocks class action suit against Dow Chemical
bullet Dioxin lawsuit plaintiffs intend to proceed with case, or cases

WB01727_.gif (697 bytes)
07/19/11  Judge  Borrello rules against class certification of Dow dioxin contamination lawsuit
From the Saginaw News:

bulletBorrello cites Wal-Mart discrimination case as reason for his decision
bulletDow happy
bulletResidents not

WB01727_.gif (697 bytes)
07/13/11  EPA/Dow "Early Action" Progress?

Legal Agreement Signed for Early Action at Small Island in the Tittabawassee River

EPA and Dow Chemical Co. signed a legal agreement July 8, 2011, requiring Dow to take early action to limit contaminated sediment from moving downstream from a small island in the Tittabawassee River, known as Island MM. EPA's selected action to control dioxin movement from the island is to remove contaminated sediment, at a minimum that is located above the water surface. The remaining island sediment and nearby underwater areas will be capped. The cap will be designed to let the island restore itself naturally. The work will remove highly contaminated sediment and stop it from moving downstream. Based on public comment, EPA modified its proposed remedy to include a contingency that allows EPA to adjust the amount of sediment removed and the areas capped, based on studies of current conditions. EPA's responses to public comments can be found in the Responsiveness Summary, which is Appendix C to the below document called the Enforcement Action Memorandum.

Related links and documents:
EPA Proposes Cleanup Action for Small Island
Enforcement Action Memorandum, July 2011
Administrative Settlement Agreement and Order on Consent for Removal Action, July 2011
WB01727_.gif (697 bytes)
06/20/11  U.S. Fish and Wildlife Service critical of MSU dioxin wildlife study results

Snippets from the Saginaw News:

Lisa Williams, a U.S. Fish and Wildlife Service contaminants specialist, noted the MSU study did not look at several animal species that live in the river, such as fish and mollusks. ...
“There may be more species that are more sensitive (to dioxin),” she said. ...
The wildlife study looked at animal reproduction, Williams said, but did not study immune function, visual acuity and cardiac malfunction, all known issues caused by dioxin....
Comparing different habitats may also cause complications, she said. ...

Click here for details

WB01727_.gif (697 bytes)
06/09/11  Dow dioxin lawsuit back in court

Retired Saginaw County Judge Leopold Borrello ordered both parties in Henry V. Dow Chemical to issue a draft order due by June 27. The order requires each party to submit proposed findings, facts and a conclusion to whether the case should have class action status.

Borrello said he will adopt one of those orders within the week he receives them.

WB01727_.gif (697 bytes)
06/05/11  New Interim exposure control measures: move your garden.

In a heavily redacted internal email obtained under the FOIA, the EPA stated:

 "This site is potentially one of the largest corrective action projects in the country. Significant hazardous chemical (including dioxin) contamination has been identified in Midland, MI, the Tittabawassee and Saginaw watershed and extends over 50 river miles into Saginaw Bay of Lake Huron." 

The March 2010 email was one of many obtained via a recent Freedom of Information Act (FOIA) request by the Lone Tree Council.

And his is how they intend to handle it for 260 EU-Exposure Units (properties) after 8+ years of testing, research, and Dow's influence.  The rest of the areas 1000's of properties are not addressed. you are own your own:

bullet EPA/Dow Administrative Settlement Agreement and AOC on implementation of interim exposure control measures signed 5/26/11
bulletConclusions: 11
bulleti. Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances ...
bulletii. High levels of hazardous substances or pollutants...may result in the spread of dioxin contamination to other locations within the floodplain, as well as to off-site and downstream locations.
bulletiii. ...frequent flooding also enhances the threat of continuing contamination of EU sites surfaces with dioxin from up-stream locations, again leading to direct contact threats.
bulletWork to be performed: VIII.16.a page 13
bulleti. A control barrier of gravel, stone, wood chips, or soil shall be placed over exposed soil, paths, and walkways....
bulletii. Fire pits and recreational areas shall be relocated or a control barrier shall be placed over exposed soils around those areas
bulletiii. Garden beds shall be relocated out of the site or shall be raised to limit flooding.
bullet EPA Enforcement Action Memorandum (Memo page 1-35, public comments and EPA's response pages 36-62)
bulletProposed removal action activities: Section V.A.1 page 10 of 17
bulletEligibility criteria: Section V.A.2 page 11 of 17
bulletAppendix A & B: maps of contamination and activity areas
bulletAppendix D:  Public Comments and EPA's response;  pages 36-62
bullet Michigan Messenger article: EPA approves landscaping as dioxin solution

WB01727_.gif (697 bytes)
05/27/11  Dow dioxin lawsuit back in court

Judge Borrello is expected to issue a supplemental opinion to clarify his 2010 class-action ruling at 10 AM on June 9 in Saginaw County's Circuit Court.

WB01727_.gif (697 bytes)
05/22/11  LTC public comments on Island MM

Four years after the discovery of high concentrations of dioxins and furans on an island in Tittabawassee River, EPA is taking comments on proposals from Dow Chemical on how to proceed. The goal is protect public health by stopping the migration of these sediments from the island. The river has experienced three floods in the last four years and has been eroding before our eyes.


Pictures of Island MM taken 5/15/11



The island was never posted with soil contact advisories--- Dow resisted the whole sign posting thing for a long time-- and got away with it. Plans are to initiate one of three options sometime in August.

Visit for additional details:

WB01727_.gif (697 bytes)
05/19/11  Dow Dioxin class action update

After a lengthy absence from the court, Saginaw Circuit Court Judge Leopold Borrello has returned. There was a hearing today with the judge, who once again refused Dow's request to start over with respect to the typicality and adequacy of the case. The Michigan Supreme Court had asked the circuit court for better clarification of those issues back in August of 2009.
Judge Borrello indicated that he would issue an order clarifying his opinion of the issues within the next two weeks.

WB01727_.gif (697 bytes)
05/05/11  EPA to test for new dioxin contamination after Tittabawassee flood

From the Michigan Messenger:
The U.S. Environmental Protection Agency plans to begin sampling Saginaw Township’s
West Michigan Park next week to determine how much dioxin was deposited in the Tittabawassee
 floodplain during recent flooding.

WB01727_.gif (697 bytes)
05/01/11  When does cleanup begin?

West Michigan Park after 2009 cleanup       West Michigan Park after 2011 flood


WB01727_.gif (697 bytes)
04/29/11  EPA seeks public comment on proposed Tittabawassee River island clean-up

bulletEPA outlines dioxin clean-up plan for Tittabawassee River region. Does the plan go far enough?
bullet EPA proposed plan
bulletEPA comments  

WB01727_.gif (697 bytes)
04/28/11  Tittabawassee River reaches flood stage; natures way of saying don't eat the fish?

Due to recent heavy rain the Tittabawassee went over it's official 24 foot flood stage this morning and is expected to continue to rise. 

Imerman park and it's boat launch are closed due to the flood just as we suspect will occur with other parks in the area.

When the flood waters recede, residents and visitors to the Freeland Walleye Festival and the Great Lakes Bay Area need to take precautions to avoid contact will the dioxin contaminated soil which will be re-distributed over the rivers floodplain. 

MDCH Warnings:, people should take precautions when entering the flood plain: "There are some common sense steps you can take to limit your exposure to the dioxins found in the flood plain. If you have been playing or working in soil that could be contaminated, wash your skin to remove any dirt. Thorough hand washing is especially important before eating. Children playing outside should be prevented from putting toys or other dirty objects in their mouths. Clean fill dirt can be added over contaminated dirt in gardens, on lawns, and in play areas if dioxin contamination is known or suspected. However, if the area is flooded after clean fill is added, the surface soil could be re-contaminated. Care should be taken not to disturb the layer of clean soil covering the contaminated soil. Because they may be especially sensitive to dioxins, children should not play in soil or sediment that is known to contain elevated levels of dioxins.

Click here for information and images of past floods on the Tittabawassee River, this is almost an annual occurrence.

Get real-time Tittabawassee River level data from the USGS, click here

WB01727_.gif (697 bytes)
04/20/11  EPA comments on relocation of residents in dioxin contamination areas

EPA brought in a spokesperson to their monthly CAG meeting Monday, to address some Tittabawassee River residents request for relocation out of Dow's dioxin Alternative Superfund Site. The levels of widespread contamination are extraordinarily high here, and a pathway of exposure in humans has been documented by the EPA and the Michigan Department of Community Health.

"U.S. EPA also has significant concerns with human health risks associated with dioxin exposure through the food chain pathway, especially for at-risk populations such as pregnant women, children, subsistence hunters and fishers, and Native Americans. For example, a recent Michigan Department of Community Health study has identified potentially at-risk segments of the Saginaw Bay watershed population which consume a significant amount of highly contaminated fish. Of particular note, issues of environmental justice and fair treatment may be relevant with regard to some of these populations. Given the significant risks associated with exposure to dioxins, furans and other possible hazardous constituents throughout the Saginaw Bay watershed, Dow’s failure to address such risks in the revised RIWPs is problematic."

These results suggest that living on contaminated
 soil in the Tittabawassee River flood plain, eating eggs
 from chickens kept there, and eating local-caught fish
are sources of DLC contamination in the residents serum"

EPA stated that in permanent relocations, the site must pose an immediate risk to human health with no ready cleanup available, she said.

In the Great Lakes Bay Region, she said, "contaminated sediments have been dealt with both through dredging and capping."


EPA seeks public comment for dioxin contaminated Island in the Tittabawassee
Click on the picture on the left and take a look at a newly discovered contaminated island in the river.  We're wondering how many residents think the contamination has been dealt with, and feel safe in their homes because of it. Other than Riverside Boulevard, we are unaware of any other effective remediation efforts. The Regional Administrator at the time was fired by EPA for ordering that cleanup effort, by the way.

Here is EPA's guideline criteria for consideration in relocating a neighborhood. The Tittabawassee River floodplain passes with flying colors.

Decide for yourself.

WB01727_.gif (697 bytes)
04/11/11  Congress asks EPA for timeline on Dioxin Reassessment Report

For Immediate Release                                 Contact: Giselle Barry 202-225-2836
April 11, 2011                                                       

Markey Leads Call on EPA to Speed Up Action on Dioxin

Calls for release of long-overdue health assessment of toxic chemical

WASHINGTON, D.C. – Representative Edward J. Markey (D-Mass.) along with 72 members of Congress today sent a letter to Environmental Protection Agency (EPA) Administrator Lisa Jackson requesting the finalization and release of the long delayed health assessment of dioxin. Dioxin is the name given to a group of toxic chemicals that are released as a byproduct of industrial processes and have the ability to accumulate in the food chain and remain in the environment for years. Exposure to dioxin causes a wide range of health impacts and has been associated with delays in motor skills and neurodevelopment in children, as well as impacts on hormones that regulate growth, metabolism and reproduction. Dioxin has also been classified as a human carcinogen. According to the Centers for Disease Control dioxins are present in the blood of 95 percent of Americans.

“Almost 40 years ago we called a code red on Agent Orange and dioxin. Despite worldwide agreement about the toxicity of these chemicals and their persistence in the environment, EPA still has yet to release its findings on how dangerous these chemicals are to public health,” said Rep. Markey. “This much-needed assessment should not languish at the EPA as long as this dangerous chemical lasts in our food chain. The EPA should release its report without further delay.”   
“American children and families are already being exposed to unsafe levels of dioxin, and therefore, the EPA should finalize and release their long-delayed study on dioxin as soon as possible,” said Lois Gibbs, Executive Director of the Center for Health, Environment & Justice.  “Finalizing the EPA's dioxin report is essential for a strong, coordinated state, federal and industry effort directed at protecting Americans from this unnecessary toxic chemical.”

The EPA completed its first health assessment of dioxin in 1985, finding that the cancer risk to humans from dioxin exposure is by far the highest defined for any man-made chemical. This finding was challenged by the industries whose operations would be affected by any limits on dioxin releases into the environment. EPA subsequently began a review of the health impacts of dioxins that has been in process for more than 20 years. During this time both the World Health Organization and the National Toxicology Program have classified dioxin as a human carcinogen. 

The most toxic form of dioxin, a compound known as TCDD, was made notable as the contaminant of Agent Orange and released in high volume during the industrial explosion in Italy known as the Seveso disaster. Dioxins were also behind the evacuations that occurred in Love Canal, New York and Times Beach, Missouri.

According to the EPA, over 90 percent of human exposure to dioxin occurs through the diet. Dioxin has also been found in breast milk and in blood samples taken from newborns. Because of the persistence of dioxin, it has been targeted for international phase-out by a treaty signed by 170 nations across the world.

The letter to Administrator Jackson can be found HERE.

A fact sheet on dioxin can be found HERE.


WB01727_.gif (697 bytes)
04/02/11  Women living along Tittabawassee may have higher risk of breast cancer from dioxin contamination

Three recent stores from the Saginaw News concerning a new disease cluster report by the Natural Resources Defense Council and the National Disease Clusters Alliance  based on new data including a peer reviewed 2009 study of a link between local dioxin contamination and breast cancer.

bulletStudy: Dioxin causes increase in breast cancer rates in Great Lakes Bay Region
bulletWomen living along Tittabawassee, Saginaw rivers may have higher risk of breast cancer from dioxin contamination
bulletMedical officer: Tittabawassee, Saginaw river residents should get screenings, be healthy to decrease breast cancer risk

The following related 2008 peer review study was not mentioned

Spatial variations in the incidence of breast cancer and potential risks associated with soil dioxin contamination in Midland, Saginaw, and Bay Counties, Michigan, USA

Dajun Dai and Tonny J Oyana Environmental Health 2008, 7:49doi:10.1186/1476-069X-7-49 Published: 21 October 2008

 (provisional) Background High levels of dioxins in soil and higher-than-average body burdens of dioxins in local residents have been found in the city of Midland and the Tittabawassee River floodplain in Michigan. The objective of this study is threefold: (1) to evaluate dioxin levels in soils; (2) to evaluate the spatial variations in breast cancer incidence in Midland, Saginaw, and Bay Counties in Michigan; (3) to evaluate whether breast cancer rates are spatially associated with the dioxin contamination areas.
We acquired 532 published soil dioxin data samples collected from 1995 to 2003 and data pertaining to female breast cancer cases (n = 4,604) at ZIP code level in Midland, Saginaw, and Bay Counties for years 1985 through 2002. Descriptive statistics and self-organizing map algorithm were used to evaluate dioxin levels in soils. Geographic information systems techniques, the Kulldorff's spatial and space-time scan statistics, and genetic algorithms were used to explore the variation in the incidence of breast cancer in space and space-time. Odds ratio and their corresponding 95% confidence intervals, with adjustment for age, were used to investigate a spatial association between breast cancer incidence and soil dioxin contamination.

High levels of dioxin in soils were observed in the city of Midland and the Tittabawassee River 100-year floodplain. After adjusting for age, we observed high breast cancer incidence rates and detected the presence of spatial clusters in the city of Midland, the confluence area of the Tittabawassee, and Saginaw Rivers. After accounting for spatiotemporal variations, we observed a spatial cluster of breast cancer incidence in Midland between 1985 and 1993. The odds ratio further suggests a statistically significant (alpha = 0.05) increased breast cancer rate as women get older, and a higher disease burden in Midland and the surrounding areas in close proximity to the dioxin contaminated areas.

These findings suggest that increased breast cancer incidences are spatially associated with soil dioxin contamination. Aging is a substantial factor in the development of breast cancer. Findings can be used for heightened surveillance and education, as well as formulating new study hypotheses for further research.

Click here to view Environmental Health website posting of this study and peer review comments

Click here to view complete study

WB01727_.gif (697 bytes)
03/24/11  Dow Dioxin Politics - Business as usual

Former Gov. Jennifer Granholm named to Dow Chemical board of directors.  Serving on the board, which meets six times per year, will be a paid position for Granholm. According to the 2010 Dow Chemical proxy statement, members on the board of directors made between $150,000 and $200,000.

In case anyone has forgotten, below are snippets from a press release after her meeting with local residents at the Greenpoint Nature center September 3, 2002:

bullet"the state should do more to answer their concerns and to provide more transparency in state government when dealing with environmental contamination that poses health risks.
bullet“There is a definite lack of governmental accountability here,”
bullet“When I am Governor, my administration will operate differently. We will inform residents quickly regarding any health threats, and there will be a code of conduct for state government to follow in these situations.”
bullet“Residents of the contaminated areas are suspicious of the state’s commitment to protecting them..."
bulletGranholm said the environmental policies of state government the last 12 years have wrongly assumed that protecting public health and the environment is incompatible with job creation
bullet “I reject the assumption of the current management of the DEQ that leveling with the public about dioxin and other pollution problems is somehow bad for business"
bulletA plan to phase out the use and release of the most dangerous chemicals, including dioxins, in Michigan

What really a happened?  Below are snippets from the Lone Tree Councils analysis of the situation:

bulletShe abandoned Lake Huron when she failed to support MDEQ efforts to implement measures to stop the migration of dioxin-contaminated sediments to Saginaw Bay
bulletShe abandoned science and the truth when she refused to allow her scientists to respond Dow Chemical on one particularly gross misrepresentation on the risks and toxicity of dioxin.
bulletShe abandoned the public health commitment to the families living on contaminated property and to fish consumers in mid Michigan– Sitting by idly while the agencies fought with Dow to fund and place fish and soil advisory signs.
bulletShe told her DEQ staff they would share the stage with Dow Chemical at all public meetings and vet all presentations with Dow in advance of the meetings.
bulletShe interjected her office into the fight over the placement of slurry walls in the Zilwaukee dredge site. Instead of listening to science and MDEQ, she used a report by Dow’s contractors to make up her mind. There would be no slurry wall and no ground water permits.
bulletIn 2007 she signed the state’s first ever directive on Environmental Justice but she never found the strength or voice to defend the right of people to consume uncontaminated fish. Oblivious to the people in this region eating those fish to supplement their food budget, the governor was curiously silent.

Add to the above the lack of transparency created by 3 closed door sessions with Dow in 2004, 2007, and 2008.   Each time she made the decision to exclude the most important state holders; the local residents who live in the contamination 24x7.

bulletJune 2004; Granholm initiates the first closed door negotiation with Dow that drag on for over 6 months resulting in the flawed Framework document.
bulletOctober 2007: Granholm ok's States participation in another closed door negotiation with Dow & EPA lasting 4 months before the EPA walked away.
bulletDecember 2008: Granhlom ok's States participation in another closed door negotiation Dow and the EPA.  The outcome takes the Super Fund option off the table and substitutes the Super fund alternative site (SAS) which even the EPA stated: There is no need for this mid-stream switch from an existing, clean up process under a workable, enforceable RCRA corrective action permit to an unnecessary, potentially detrimental SAS approach that could lead to time delays and less extensive and less protective clean up"

WB01727_.gif (697 bytes)
03/8/11  EPA responds with analysis of recent UMDES update: still junk science?

In a letter dated 2/28/2011 the EPA has responded to a request by TRW and other organizations to review the most recent update of David Garabrants "University of Michigan Dioxin Exposure Study"

Evidently their opinion of the study has not changed, a snippet from the letter states:

"The EPA has read the updated UMDES summary report. While some new findings have been identified by the UMDES, they do not change the primary conclusions of EPA's 2009 review of the study. We do not see a need to update or revise the EPA review report . The UMDES remains one of the largest studies of its kind, with a design that is well suited to identify patterns of dioxin, furan and PCB levels in the blood of adults . The study estimates the distributions of dioxin concentrations in blood, soil and dust in the Midland and Tittabawasee River regions. However, EPA maintains that the study is limited since it did not adequately include subpopulations likely to have larger exposures. For example, the study did not include children, who generally have higher exposures to contaminants due to activities that increase their contact with and ingestion of soils and dusts. Additionally, the study did not sufficiently focus on individuals living on properties with highly contaminated soils or those consuming large amounts of local fish or game. Such a focus would have been informative to area decision makers."

Click here to view the entire EPA 2/28 response.  Click here to see original letter sent to EPA Administrator Lisa Jackson requesting a response.  See previous 2/3/11 and 1/30/11 entries below for additional details.    The media jumped all over the UMDES update misinformation blitz back in January, we wonder if they will give the same attention to the EPA's latest response?

WB01727_.gif (697 bytes)
03/3/11  Reminder; EPA accepting comments on dioxin cleanup interim plan until March 13 2011

Comments on the proposed plan may be submitted to Community Involvement Coordinator Patricia Krause by e-mail at , by fax at (312) 697-2568 or online at

See 1/10/11 and 1/21/11 entries below for additional background info
WB01727_.gif (697 bytes)
03/3/11  More on the EPA CAG or Dow's CAG? You decide

From  the Clean Water Shed Campaign

"This week Tittabawassee River Watch posted commentary on their web site about the makeup of the EPA’s established Community Advisory Group or CAG. Dots were connected illuminating the connection CAG members have to Dow Chemical and the Chamber of Commerce. It’s just a fact, even if it’s uncomfortable for some." ...

Click here for details

WB01727_.gif (697 bytes)
02/27/11  EPA CAG or Dow's CAG? You decide


The formation of the EPA Community Advisory group or CAG was initiated, as part of the Agreement Of Consent signed between Dow and EPA. It is the third invention of the public process in 8 years. Since 2002 Tittabawassee River Watch have remained actively engaged in the public process through its many reinvention's but never have we been so terribly disappointed in a public process.


Last fall Tittabawassee River Watch member Carol Chisholm resigned from the CAG.  Just before leaving, Carol asked the members of the CAG to identify their affiliations with Dow Chemical. Carol’s request was not unreasonable. The CAG and EPA have an obligation to identify to the public any and all affiliations, monetary or otherwise with Dow, particularly within the context of the organizations which CAG members identified on their application to sit on the CAG. The CAG has to be legitimate to be successful. Right?


 A short Google search is revealing


 A CAG member’s affiliation or relationship with Dow Chemical could be in the form of taking money from the company, as CAG member Mike Kelly’s Watershed Initiative Network has over the years. Or the affiliation could be sitting on one of Dow’s boards, as CAG member, Bill Weber does with the Dow CAP in Midland, or perhaps it’s flipped around and a Dow Chemical employee sits on a CAG members board; like Dow’s Mary Draves who sits on CAG member Jan McQuire’s (Midland Foundation) board, or Dow’s Jeff Martin who sits on Annette Rummel’s Board at the Great Lakes Bay Visitors Bureau, or Dow’s Garret Geer who sits on CAG member Len Heinzman’s Freeland Lions Club board (the creators of the Dioxin My Ass hats in 2004) and donates big bucks to the Freeland Walleye Festival.


 Ties that bind and follow the money


In writing the history of community involvement on this site we would be remiss to ignore the pivotal role of the Chamber of Commerce as advocate and apologist for Dow Chemical, as well as the organizations willingness to initiate and interject politics instead of science into this cleanup.


The Chamber has rejected every bit of science on dioxin unless Dow Chemical funded the science. The Chamber lobbied legislators, the governor and the business community to remove or slash public health measures intended to protect people from dioxin. The Chamber’s support for the arcane and outdated 1,000 ppt for dioxin in soil instead of the more scientifically defensible state number of 90 ppt is legend.  The Chamber supported lifting the “facility”  (HB 4716) designation off contaminated properties on the river, which would have hamstrung the state’s ability to initiate cleanup and past costs for testing on to the taxpayers. Both of these anti- public health positions supported by Dow and the  Chamber  were also supported by  CAG members Len Heinzman, Paul Vasold (Tittabawassee Twp Trustee) and Drummond Black (former Mayor of Midland).   


 CAG member Mayor Black also intervened in Lansing Circuit court in support of the 2002 illegal consent order, which would have released Dow from liability on the Tittabawassee River.


In 2007 EPA released a lengthy document outlining Dow Chemical’s outrageous and ongoing delay tactics, manipulation of science and political interference. Of course the Chamber of Commerce was livid. How dare the EPA release a document to the public critical of Dow Chemical?  Wasting little time the Chamber of Commerce filed a complaint with the Office of Inspector General at the EPA. The Chamber didn’t prevail but the organization surely flexed their muscle in defense of Dow Chemical. 


To the best of our knowledge the Chamber has never invited any regulatory agency to their membership meetings to discuss the dioxin contamination, agency studies or the science of dioxin. But the Chamber has frequently invited Dr Garabrant to present his findings from the Dow funded UM dioxin study.


In 2008 the Chamber of Commerce was lobbying the governor and the legislature to have the MDEQ removed from negotiations with Dow Chemical at the same time that Dow was lobbying EPA in Washington DC to take over. Dow and the Chamber prevailed ultimately derailing years of work.


The Chamber supported the construction and placement of the dioxin Slurry Pit in Zilwaukee Twp whose biggest proponent was CAG member Bill Weber from Sargeant Stone Dock. Dow Chemical contributed significant money to the dredge site, which was constructed in the backyards of families along the Saginaw River.



Truth is there is little difference between Dow Chemical and the Chamber of Commerce when it comes to Dow’s dioxin contamination. Dow’s agenda is the Chambers agenda. It remains relevant when looking at the makeup of the CAG.


A few years back the local chambers merged in the Tri-Cities creating the Great Lakes Bay Regional Alliance. This collaboration has put a number of business and community leaders through the Chambers leadership/ambassador training, including a number of the people on the CAG: Annette Rummel (also a Board member of the GLBRA), Laura Ogar, Mike Kelly, Drummond Black, Mike Espinoza, Jan McQuire, Wendy Kanar (Law firms represents the GLRBA) Judy Lincoln and most recently, Dan Soza.


CAG member Dave Meyer, one of four attorneys on the CAG (Lincoln, Kanar, Black and Meyer) comments on his firms web page about his committee work with the Chamber of Commerce.


CAG members Dr. Deborah Huntley, Dean of the School of Science at SVSU and Charlie Curtiss President of the Saginaw Bay Land Conservancy are also recipients of Dow’s corporate sponsorship.



 The CAG is not in anyway reflective of the entire community. The vast majority of folks on the CAG operate day to day in the same circles as business and politics.


How could EPA be so inept as to allow this to happen? Admittedly there have been resignations from the CAG .  But even if everyone were still in place, Dow Chemical and the Chamber would be the dominant voice of the CAG. Dow Chemical is the polluter and responsible party. How they came to have so much representation in the only public process offered is something that EPA needs to answer.  

WB01727_.gif (697 bytes)
02/26/11  In memory of Howard Steinmetz, former Tittabawassee River resident

Howard's widow Barbara, informed TRW that The Saginaw News refused to print Howard's obituary as written because of language it contained, referring to Dow Chemical's dioxin contamination of the Tittabawassee River.  Out of the sense of decency and compassion for her loss, we are more than happy to post it on The Tittabawassee River Watch.

Howard J. Steinmetz born in the Bronx, NY. He a greeted each day with “Hello World” and at age 78, on 11/27/2010, said “so long world.” His family moved to Detroit, and after he was married, to Saginaw. Howard owned The Host Companies. He was known for his slogans especially one that appeared on his calendar each of the more than 35 years he was in business, "Where in the World is Howard Steinmetz" In 2009 Howard was inducted into the Michigan Promotional Professional’s Hall of Fame, for excellence and creativity in the advertising specialties industry. Howard’s tranquil life was altered forever when a few years ago, the MDEQ informed him that the idyllic land on which he built his dream house, along the banks of the Tittabawassee River, had been contaminated by the disposal of Dioxin by Dow Chemical Co. located 17 miles upstream. The family’s health was in jeopardy. Howard developed two cancers. In 2005, not wanting further exposure to Dioxin, moved to Boulder Co. While enduring Cancer treatments, was enriched by the ancestral journey he took into the world of Genealogy, family research. Howard widened the horizon of his fellow Genealogists, beyond recording data alone. He took and encouraged others to flesh out the pedigree charts by telling the stories of individuals. In his own words, “they were more than names and dates carved on tombstones" “Rather than simply tracing who begat whom; study the time and circumstances; Weave the strands of information, add in the family legends and tales and make a whole cloth of them.”

He was an active member of both the Michigan and Colorado Genealogical Society, writers, and senior groups in both Saginaw and Boulder. Howard loved his life and his family. His congenial manner, endeared him to a wide variety of people. He never let an opportunity pass, without asking people to tell him their story and they did; He was honored last fall, with the 2010 Spirit Award by the Genealogical Society of Colorado.

Howard will be remembered as a punster, a lover of words, his quick and jovial wit, a humorist, lover of history, passion for story telling. He endured the deteriorating affects of the cancer and cardiac condition with courage, and a jovial undaunted spirit., both at the University of Michigan and the University of Colorado clinics.

Howard is survived by his wife, Barbara, daughters, Julie Shaffer (Bruce) of Boulder, Monica Sageman (Brad) of Evanston, Il. Grandchildren Sierra, Zane, and Maya Shaffer; Asia and Isaac Sageman, Eden Tansman Predeceased by 10 mo, also a cancer victim, daughter, Ivy (Willy Tansman) of Teaneck, NJ.

Donations can be made to: U of M Cancer Center Ann Arbor, Mi, C U Cancer Center Aurora Co.
WB01727_.gif (697 bytes)
02/03/11  Dow and U-M Garabrant team up to interfere with EPA public health measures

Lone Tree Council

 P.O. 1251, Bay City, Michigan 48706

  (Fighting for environmental justice since 1978)


FOR IMMEDIATE RELEASE            CONTACT: Michelle Hurd Riddick 799-3313

                                                                                       Cell- 989-327-0854

Feb 3, 2011                                                                Terry Miller (989) 686-6386

                                                                                         Cell: 989-450-8097

                                                                                   Carol Chisholm: 989- 790-4836



Environmentalists and river residents have requested that the EPA and national public health officials review the latest release by Dr David Garabrant of the University of Michigan Dioxin Exposure Study (UMDES) to determine whether it is an accurate and appropriate public health message to the community.


Local environmentalists including Lone Tree Council, Tittabawassee River Watch joined the Ann Arbor-based Ecology Center and Dr. Ted Schettler MD MPH in criticism of a Dow funded dioxin study.

Last week, a team of University of Michigan researchers issued a “revised final” report on a long-running dioxin exposure study conducted on area residents.  Results of the controversial study funded by Dow Chemical were first released in 2006.  This new revised final study presents no additional data, but purports to have refined its analysis to come to the conclusion that local sources of dioxin exposure like fish and soil are not currently contributing to dioxin levels in area residents. 

This ‘conclusion’ is drawn from a new statistical analysis of blood drawn from Saginaw and Midland residents in 2004 and 2005 under the direction of Dr. David Garabrant of the University of Michigan.  But river residents and environmentalists are suspicious of its timed release. So are others:


“The new report is clearly intended to influence public opinion,” said Dr. Ted Schettler, science director for Science and Environmental Health Network.   In recent media reports Dr. Schettler said that the report is “outside the scientific norm” because it does not fully explain how it reanalyzed the data to come up with the new conclusions. He too calls upon EPA to review the findings and the message.


The distribution of 117,000 of the unsolicited brochures comes on the heels of an EPA public comment period on efforts to minimize dioxin exposure for residents living in the most contaminated areas of the Tittabawassee and Saginaw flood plains.  For many residents and the environmental community the timing and content of the new report is not coincidental.


“It is so obvious that Dr. Garabrant is doing Dow’s bidding,” said Tittabawassee River Watch member and river resident Carol Chisholm. “The original study has been controversial from its beginning, criticized by both Michigan regulators and the EPA and now just as EPA is trying to educate people and make their property safer, Dr Garabrant releases the Dow funded study that says dioxin in not a problem?”


Residents and activists point out that no new information has been made available on the UMDES web site. Activists also point out that Dr. Garabrant didn’t inform the EPA, MDCH or MDNRE of this new analysis for comments.  He also did not go through the formal peer review process appropriate for scientific reports. State and federal regulators reportedly had no knowledge of the planned release of the report or distribution to the community.


“This appears much like a political campaign,” noted Terry Miller, Lone Tree Council chairman.  “It is clear that Dow is attempting to leverage the good name of the University of Michigan to give plausibility to those who would dismiss the health threat posed by dioxin and EPA’s effort to protect at-risk residents.”


Environmentalists suggest that the Dow-paid study is another variation on what Dow has historically done to avoid responsibility for a cleanup at this site.


“Usually they use the halls of power -- a call to the governor or a strong lobbying effort to rein in regulators,” said Lone Tree Council member, Michelle Hurd Riddick. “It certainly worked with the state and it worked at EPA Region V, when former Administrator Gade used CERCLA authority to compel cleanup of properties on Riverside drive. This year’s tactic, building on Dow’s decades old mantra that dioxin is not toxic, has Dow and Dr. Garabrant releasing some new and improved findings to undercut EPA’s ongoing efforts to implement public health interventions by suggesting dioxin is no problem.”


 EPA has granted TRW and Lone Tree Council a thirty-day extension on the public comment period. Lone Tree Council and river residents have also sought the technical help of Dr. Peter defur to respond to both the interim response efforts by EPA and the recent release by Dr Garabrant. 



Click here for letter to Administrator Jackson or go to: 

WB01727_.gif (697 bytes)
01/30/11  Garabrant claims dioxin of no concern to residents

David Garabrant, a known "industry aligning expert", recently released a update to his 2004 dioxin exposure study.   From what we understand, this is not a new study, just a new statistical manipulation of old data he collected in 2004.  Garabrant claimed impartiality in the original $15,000,0000 Dow Chemical funded study however not everyone agrees.  Below are comments about his "impartiality" as  published in an article by the Michigan Messenger in 2009:

Observers challenge Garabrant’s impartiality

“He is using the good name of U of M and his status as a medical doctor to remove responsibility from Dow,” said Terry Miller, chairman of the Lone Tree Council.

Miller is not alone in criticizing Garabrant for the way he carries out corporate-funded research.

A 2007 International Journal of Occupational and Environmental Health article titled Industry Influence on Occupational and Environmental Public Health by James Huff — now associate director for Chemical Carcinogenesis at the Office of Risk Assessment Research at the National Institute of Environmental Health Sciences — named Garabrant as an example of an “industry-aligning expert.”

“Academic credentials often are used to shield industry views and to create the illusion of objectivity,” Huff wrote. “In fact, a person’s professional address or organization does not reflect his or her public health philosophy, nor does the institution necessarily reflect a purity of pursuit.

“Industry often forms institutes to contradict or cloud damaging findings. One alarming result is that public health officials increasingly accede to or are coerced by industry persuasion.”

Dr. David Egilman, associate professor of community health at Brown University, has written extensively on how corporations fund science as part of a strategy to avoid liability for harms associated with their products.

In an article titled “Maximizing Profit and Endangering Health: Corporate Strategies to Avoid Litigation and Regulation” published in the International Journal of Occupational and Environmental Health he wrote:

In order to reach potential jurors, who are unlikely to read scientific publications, corporations have developed programs to restrict and coordinate the flow of health information to the media. H & K’s asbestos media strategy relied on securing interviews of and placing bylined articles by experts “sympathetic to the company’s point of view.” H & K consultants referred to this as “capturing ‘share of mind’” on the national level.

In an interview, Egilman said that he was familiar Garabrant’s work, not on dioxin but on asbestos.

“He got paid to do these asbestos studies that I critiqued. Those studies were used to deprive workers of compensation for their illnesses. Companies paid for a result that helped in presenting evidence to juries that their asbestos brakes never hurt anybody.”

Garabrant told Michigan Messenger that he was unaware that he’d been named an “industry-aligning expert” and confirmed that he had served as an expert witness for Ford on the question of whether automobile brake shoes cause mesothelioma. 

After the release of the initial study in 2006 a confidential EPA memo critical of Dow and the Garabrant study stated

The results of the study are consistent with current EPA/MDEQ understanding, and will not have any significant effect on corrective action activities. However, public presentations of the preliminary results have emphasized how little effect living on contaminated soils has on an individual’s dioxin blood level. This emphasis has resulted in numerous media stories, an understanding by some members of the public, that remediation of dioxin contamination is unnecessary.

A September 2009 EPA memo critical of the Garabrant study stated:

For risk-based decision-making, EPA’s focus is typically on highly exposed and/or sensitive subpopulations, in addition to the general population. The UMDES did not target such subpopulations and coverage of groups of interest for risk-based decision-making is limited. Thus, the lack of emphasis on sampling of subpopulations likely to be most affected -- such as people living on properties with very high soil levels and people consuming large amounts of possibly contaminated fish and game -- is a significant drawback.

From what we understand, Garabrant sent over 117,000 fliers last week the homes of Michigan residents touting his new, and possibly flawed data which once again downplay the contamination.

In a flurry of press activity late last week, many media outlets published Garabrant new claims, click here for the Detroit Free Press version

WB01727_.gif (697 bytes)
01/21/11  Lone Tree Council comments to EPA Dow Contamination interim action plan


January 19th 2011

Comments of the Lone Tree Council

 Good Evening. My name is Michelle Hurd Riddick I ‘am with the Bay City based Lone Tree Council. We appreciate the opportunity to comment tonight on Dow Chemical’s Task 1.4 Engineering Evaluation for Early Response Actions to Address Potential Acute or Near Term Exposure Risks.

Residents and interested parties are often at a disadvantage to understand technical documents so EPA efforts tonight to explain them in more detail are much appreciated. 

Tonight I would like to make a few comments and only a few suggestions.  Last week, after meeting with Tittabawassee River residents, Lone Tree Council again retained the services of Dr. Peter deFur to assist us in navigating and commenting in detail on the technical aspects of this document.  Our additional comments are forthcoming.

It would be comical if not such serious business that these activities are called Early Response Actions. This contamination is decade’s olds. Dow Chemical is rewriting a plan and embarking on a project that they first undertook in January of 2005.--- but never completed.  There is nothing early about these response activities.  They are late if anything and long overdue. I think it is safe to say that Dow did not make a best effort 6 years ago—had they done so, had the company kept their many commitments both verbal and contractual we would be light years ahead of the game.  We are looking for assurances and strong enforcement language from EPA that this will be the last time these particular interim response actions will be resurrected and re-introduced as some new plan to the community.


We call upon EPA to strengthen the Early Response Actions by offering the option of relocation to those most vulnerable--- Families with young children in particular, and those with women of childbearing age who are planning a family. In addition we request that if there are infants and children living on contaminated property that a more detailed investigation into their exposures be evaluated:

 ·         Is mom breast feeding?

·         Is there dust blowing from adjacent farm fields?

·         Is there a pet or activity responsible for tracking soils into the house?

·         Does this child visit other properties, parks or day care that are contaminated?

·         Is this child immune compromised?

·         Is the family eating fish or wild game?


Included in our comments is a link to a video of Dr Linda Birnbaum being interviewed on the impacts of dioxin? Her comments on the toxicity of these chemicals and the impact on susceptible and vulnerable populations are compelling. 

There are also residents who wish to be removed from this ongoing nightmare that by all indications has no end in sight. Some of them are sick. We are asking EPA to give them a fair hearing on the issue of relocation with clearly articulated criteria for refusing their request.

There is a huge sand bar building up in the dredge spoils site.  MDNRE staff in Bay City has voiced concern about exposures for residents from the prevailing westerly winds that are blowing dredged particles directly toward homes along the river.  We suggest EPA no longer take hands off approach on Saginaw River properties/home exposure and on the morass that is the DMDF.  Early Response efforts must be modified to include at a minimum an expedited evaluation of their exposures, potential and real time.

 Lastly, we would like to see the Early Response efforts to include contracting an independent ombudsman to trouble shoot issues residents may have with EPA, Dow or their contractors.  

We thank EPA for the opportunity to comment. As we further review materials, more detailed comments to strengthen this document will be forthcoming.


Michelle Hurd Riddick

Lone Tree Council

WB01727_.gif (697 bytes)
01/10/11  EPA updates Dow Contamination web site with interim action plan info

EPA working with MDNRE is proposing an interim action plan to limit human exposure to dioxin and furan contamination in areas along the Tittabawassee River floodplain. EPA recommends placing a physical barrier such as ground cover over soils to limit contact, or raising land use features such as gardens and recreation areas out of the floodplain. The plan proposes short-term measures, until long-term solutions are implemented for floodplain soil.

EPA is seeking public comment on the plan and on the supporting technical document called an Engineering Evaluation/Cost Analysis (EE/CA).

The public will have a chance to comment on the plan at a public meeting scheduled for Wednesday, January 19, 6:30 p.m. at Saginaw Valley State University , Curtiss Hall, Seminar Room D-G, 7400 Bay Road, Saginaw.

EPA and MDNRE representatives will also be available to talk to residents at informal sessions:

bulletTuesday, January 18, 5-8 pm at the Freeland Sportszone, 5690 Midland Road, Freeland
bulletWednesday, January 19, 1-4 pm at the Thomas Township Library, 8207 Shields Drive, Saginaw

WB01727_.gif (697 bytes)
01/09/11  EPA want's comments on plan for floodplain soil

An EPA ad on page 8 of the Sunday edition of the local "news paper" states they are accepting public comments on their proposed Interim Acton Plan for High-Use Floodplain soil.

According to the ad, the "recommended plan includes placing a barrier such as ground cover over bare floodplain soil to limit human contact, or moving or raising land-use features such as gardens and recreation areas out of the floodplain."

The ad states a fact sheet is available on the EPA Dow Chemical contamination site; however as of this morning there is nothing posted.

The public comment period is open from January 12 - Feb 11, 2011.  A public meeting will be held January 19, 2011 at SVSU's Curtis Hall, Seminar Rooms D-G at 6:30 pm.

Ground cover?  Is not this the same stuff that washes away in every flood?  Is this what Dow's $5,860,000 lobbyist dollars bought in 2010?


WB01727_.gif (697 bytes)
01/08/11  EPA testing of local drinking water complete
Click here for map of sampling area

EPA has completed its water sampling from the drinking water systems for Midland, Saginaw and Bay City. Sampling was done in response to some community concerns that U.S. Army Corps of Engineers navigational dredging in the Saginaw River might stir up contaminants that could move downstream and affect drinking water. EPA took baseline samples in 2009 while no dredging was occurring, and again in 2010 while the Corps of Engineer’s dredging was underway. EPA tested for a wide range of chemicals including dioxins, furans, volatile organics, semi-volatile organics PCBs, pesticides and metals. A comparison of the baseline sampling results to the sampling results for when dredging was underway do not show a difference in water quality as a result of dredging. The results from both years were below EPA and Michigan DNRE’s standards for drinking water safety.

bulletMore than 180 compounds were analyzed for in each sample. Most compounds were not detected in any sample.
bulletSample results were compared to the U.S. EPA National Primary Drinking Water Regulations Maximum Contaminant Levels (MCLs) established under the Safe Drinking Water Act. No contaminants were detected at concentrations exceeding the MCLs.
bulletA variety of other organic and inorganic contaminants were detected in all samples at low levels. Because MCLs are not established for all contaminants, sample results also were compared to Michigan's Part 201 Residential and Commercial 1 Drinking Water Criteria (Part 201 Criteria). Although the Part 201 Criteria are applicable to groundwater, these benchmarks were evaluated. None of these detected compounds exceeded the Part 201 Criteria.

Full report (256 pages, 8mb pdf)

WB01727_.gif (697 bytes)
01/06/11  EPA publishes recommended Toxicity Equivalence Factors for humans

Published in today's Federal Register:

According to the EPA's web site:
 "This document describes EPA's updated approach for evaluating the human health risks from exposures to environmental media containing dioxin-like compounds. It recommends the use of consensus TEF values for 2,3,7,8-tetrachlorodibenzo-p-dioxin and dioxin-like compounds, which were published in 2005 by the World Health Organization, and adopted by EPA in 2008 for ecological risk assessments."

Recommended Toxicity Equivalence Factors (TEFs) for Human Health Risk Assessments of 2,3,7,8-Tetrachlorodibenzo-p-dioxin and Dioxin-Like Compounds


When whole mixture data or data on a sufficiently similar mixture are not available for DLC exposures, the EPA recommends use of the consensus mammalian TEF values from van den Berg et al. (2006) in the assessment of human health risks posed by exposures to mixtures of TCDD and DLCs (see Table 2), using TCDD as the index chemical. EPA Program Offices and Regions have historically used TEF values in their risk assessments; this document recommends the 2005 WHO consensus TEFs, but does not address specific risk assessment applications of TEFs. Further, while ideally a full quantitative uncertainty analysis is desirable, currently available ReP data that could be used to characterize the distributions of the TEFs are not suitable for use in simulation procedures that are typically undertaken. Because limitations in both the underlying ReP data and in the ability to statistically analyze them preclude conduct of a full quantitative uncertainty analysis of the TEQs, the EPA recommends that conduct of a sensitivity analysis be considered when using TEFs in major risk assessments, as determined by EPA Program Offices or Regions. In conducting a TEF-based risk assessment the EPA suggests addressing the key risk characterization recommendations that have been discussed in this document and are summarized in Table 5. The EPA will update all of these recommendations in the future based on the evaluation of new toxicity data for the DLCs, updates to the ReP database including statistical summaries of RePs for individual DLCs, and the results of new consensus processes undertaken to update the TEF approach.

Table 5

1) Apply the TEF methodology to situations where exposures are predominantly to mixtures of dioxins, furans, and PCBs, and the goal of the assessment is to analyze the human health risks posed by the mixture.

2) Identify the fraction of the TEQ attributable to TCDD, each DLC, and to each chemical class, i.e., the PCDDs, PCDFs, and dioxin-like PCBs. Alternatively, the analysis of chemical classes could examine separately the contributions from 2,3,7,8-TCDD alone, all dioxin congeners, and the dioxin-like compounds (PCBs and PCDFs) to the TEQ.

3) When it is deemed appropriate to apply TEFs to a multiroute exposure as an interim approach, identify the fractional contributions of oral, dermal, and inhalation route exposures to the predicted TEQ. Within each route of exposure, identify the fractional contribution of each congener to the predicted TEQ and identify the fraction of the TEQ associated with each chemical class.

4) Address the implications of the identified fractional contributions to the TEQ for the risk assessment being conducted, in particular, their impacts on the overall confidence in the analytic results.

5) Include occurrence or exposure data, if available, for the following compounds as part of a qualitative risk characterization:

    1. PCB 37
    2. Polybrominated dibenzo-p-dioxins and polybrominated dibenzofurans
    3. Mixed halogenated dibenzo-p-dioxins and mixed halogenated dibenzofurans
    4. Hexachlorobenzene
    5. Polychlorinated naphthalenes and polybrominated naphthalenes
    6. Polybrominated biphenyls
    7. 6) For major risk assessments as determined by EPA Program Offices or Regions, EPA recommends the conduct of a sensitivity analysis be considered to characterize the impact of TEF variability on the TEQ.
    8. • For the TEQU and TEQL estimates that are generated, identify the fraction of the TEQ attributable to TCDD, each DLC and each chemical class.
    9. Identify the TEFi values that are most influential to changing the TEQ estimate.

Click here for Full text of report

WB01727_.gif (697 bytes)
This page contains updates from the current quarter.  To see all the past postings back to
 October 2002, go to the Archives.  Additional history is available on our
 newspaper article page with articles back to January 2002.
WB01727_.gif (697 bytes)

hit counter for myspace
Locations of visitors to this page

WB01727_.gif (697 bytes)

Up  Back to the top  Next Page >>>  Site Map