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04/19/13 Spring Flood on the Tittabawassee
Significant Tittabawassee River flooding this spring but nothing like in
Flood Stage Flood Crest
Current National Weather Service FLOOD WARNING For Monday, Apr 22, 6:17am
FLOOD WARNING CONTINUES FOR TITTABAWASSEE RIVER AT MIDLAND.. * FROM NOW UNTIL
FURTHER NOTICE. * AT 3 AM FRIDAY THE STAGE IS 26.2 FEET AND RISING. * FLOOD
STAGE IS 24.0 FEET. * MODERATE FLOODING IS OCCURRING AND MAJOR FLOODING IS
FORECAST. * FORECAST IS TO CREST AROUND 28.3 FEET AFTER MIDNIGHT TONIGHT.
Pictures from around the Tittabawassee flood plain Thursday 4/18/13
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.
09/09/12 Minimizing the Harm That Will
Result from the Dioxin Contamination of the Environment of the Saginaw Bay
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
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
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
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. ...
The significance of EPA’s
recent release of the non-cancer portion of the dioxin reassessment cannot be
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
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
·EPA’s support for Michigan’s 90 ppt
·The evolving science on the toxicity of dioxin at lower exposure
·The vulnerability of children, women, infants or the developing
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
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.
02/20/12 EPA praised for release of noncancer Dioxin
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
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.
EPA’s Science Plan for Activities Related to Dioxins in the
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
Volume 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.
Volumes 1 and 2 of the Reanalysis will supersede the 2003 draft dioxin
The 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
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.
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.
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 .
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.
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
Terry Miller - Lone Tree Council Chair
Tracey Easthope MPH - Ecology Center
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
(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
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
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
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
“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
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
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
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
Saginaw, MI 48602
Cass Sunstein, Administrator, Office of Information and
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)
11/06/11 EPA and Dow sign agreement to
start sediment clean up by Dow Midland Plant
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.
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.
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.
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
email@example.com or by telephone at 517-241-7503.
Lakes Erie and Huron Permits Unit
Permits Section, Water Resources Division
Michigan Department of Environmental Quality
517-241-7503 Fax: 517-241-8133 firstname.lastname@example.org
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
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.
"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
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?
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
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.
08/04/11 EPA: End the pro Dow Community
Advisory Group bias
Administrator Susan Hedman
Region V EPA
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.
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?
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.
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
must also look at those on the CAG who have Dow Chemical on their
boards or take money from Dow. The conflicts are unreal.
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.
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?
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.
Region V EPA EstablishedCommunity Advisory Group for Dow Chemical’s Dioxin Contamination
of the Tittabawassee River, Saginaw River and Saginaw Bay.
Director of the Midland Area Community Foundation:
Draves, Dow’s current PR person on dioxin sits on the board of the
Midland Community Foundation.
Chemical and Dow Foundation philanthropy to the Midland Foundation
is well known.
husband is the CEO of the Dow Garden’s in Midland.
Conservation Fund Watershed Initiative Network (WIN)
on Dow’s CAP in Midland
Graduate GLB Leadership School
heavily funded by Dow Chemical (millions)
genesis joint venture of Dow and Conservation Fund
Chemical Garret Geer and Jeff Martin sit on WIN’s board.
With the initial leadership of
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
CEO Great Lakes Bay Visitors Bureau
Chamber of Commerce board of directors
Graduate of GLB leadership school.
sits on Ms Rummel’s board of directors
Rummel’s Administrative Assistant takes minutes for the CAG
"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
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
"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
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.
Legal Agreement Signed for Early Action at Small Island in the Tittabawassee
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.
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. ...
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.
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."
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:
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.
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
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.
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.
05/05/11 EPA to test for new dioxin
contamination after Tittabawassee flood
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.
park and it's boat launch are closed due to the flood just as we suspect
will occur with other parks in the area.
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
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.
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,
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."
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."
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.
Markey Leads Call on EPA to Speed Up Action on Dioxin
Calls for release of long-overdue health assessment of toxic
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
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 foundHERE.
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. Methods
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
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
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
release after her meeting with local residents at the Greenpoint Nature
center September 3, 2002:
"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.
“There is a definite lack of governmental accountability here,”
“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.”
“Residents of the contaminated areas are suspicious of the state’s
commitment to protecting them..."
Granholm 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
“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"
A plan to phase out the use and release of the most dangerous chemicals,
including dioxins, in Michigan
She abandoned Lake Huron when she failed to support MDEQ efforts to
implement measures to stop the migration of dioxin-contaminated sediments to
She 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.
She 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
She 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
She 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.
In 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
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
December 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:
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"
03/8/11 EPA responds with analysis of
recent UMDES update: still junk science?
Evidently their opinion of the study has not changed, a snippet from the
"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.
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?
03/3/11 Reminder; EPA accepting comments
on dioxin cleanup interim plan until March 13 2011
"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."
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.
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
Google search is revealing
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 JanMcQuire’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.
that bind and follow the money
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.
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).
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.
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
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
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.
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.
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.
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.
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.
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.
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.
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
02/03/11 Dow and U-M Garabrant team up to interfere with EPA public health measures
Lone Tree Council
1251, Bay City, Michigan 48706
(Fighting for environmental justice since
FOR IMMEDIATE RELEASE CONTACT:
Michelle Hurd Riddick 799-3313
Terry Miller (989) 686-6386
Chisholm: 989- 790-4836
DOW CHEMICAL AND
DR DAVID GARABRANT TEAM UP FOR LATEST EFFORT TO INTERFERE WITH EPA PUBLIC
and river residents have requested that the
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
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.
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.
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?”
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.
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
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
Dr. Peter defur
to respond to both the interim response efforts by EPA and the recent
release by Dr Garabrant.
01/30/11 Garabrant claims dioxin of no
concern to residents
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:
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.
not alone in criticizing
Garabrant for the way he
carries out corporate-funded
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.
often forms institutes to
contradict or cloud damaging
findings. One alarming
result is that public health
accede to or are coerced by
David Egilman, associate
professor of community
Brown University, has
written extensively on how
corporations fund science as
part of a strategy to avoid
liability for harms
associated with their
article titled “Maximizing
Profit and Endangering
Health: Corporate Strategies
to Avoid Litigation and
Regulation” published in the
International Journal of
Environmental Health he
order to reach potential
jurors, who are unlikely
to read scientific
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
interview, Egilman said that
he was familiar Garabrant’s
work, not on dioxin but on
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.”
told Michigan Messenger that
he was unaware that he’d
been named an
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
results of the study are
consistent with current
EPA/MDEQ understanding, and
will not have any
significant effect on
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
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
In a flurry of press activity late last week,
many media outlets published Garabrant new claims, click here for the
Detroit Free Press version
01/21/11 Lone Tree Council comments to EPA
Dow Contamination interim action plan
AOC CERCLA DOCKET No. V-W-10-C-942
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.
interested parties are often at a disadvantage to understand technical
documents so EPA efforts tonight to explain them in more detail are much
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
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
· Is mom
· Is there dust blowing from adjacent farm fields?
· Is there a pet or activity responsible for tracking soils into the
· Does this child visit other properties, parks or day care that are
· 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.
Lone Tree Council
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
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:
Tuesday, January 18, 5-8 pm at the Freeland
Sportszone, 5690 Midland Road, Freeland
Wednesday, January 19, 1-4 pm at the Thomas
Township Library, 8207 Shields Drive, Saginaw
01/09/11 EPA want's comments on plan for
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."
01/08/11 EPA testing of local drinking
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.
More than 180 compounds were analyzed for in
each sample. Most compounds were not detected in any sample.
Sample 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.
A 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.
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
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
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
5) Include occurrence or exposure data, if available, for the
following compounds as part of a qualitative risk characterization:
and polybrominated dibenzofurans
Mixed halogenated dibenzo-
and mixed halogenated dibenzofurans
Polychlorinated naphthalenes and polybrominated naphthalenes
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.
• For the TEQ
and TEQL estimates
that are generated, identify the fraction of the TEQ
attributable to TCDD, each DLC and each chemical class.
Identify the TEF
values that are most influential to changing the
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