Definitions: ... "junk science" is the
term that corporate defenders apply
to any research, no matter how rigorous,
that justifies regulations to protect
the environment and public health.
The opposing term, "sound science,"
is used in reference to any research,
no matter how flawed, that can be
used to challenge, defeat, or reverse
environmental and public health
protection. ( Trust Us, We're Experts,
ISBN 1-58542-139-1, p. 222-223). Click here
for another review of the book.
The "Sound Science" mantra is alive and well in the Saginaw Valley. Anyone
with an interest in the local Dow dioxin contamination needs to take a few moments to
reflect upon the history of the phrase and those who use it. As predicted, the words of "sound
science" are being uttered by the usual suspects: Dow Chemical and it's
supporters. So how does one identify possible deceptive information when they
hear it? Simply listen for the red flag phrases of "sound science" ,
"good science", "junk science", or "poor science". Be
especially leery if spoken by Dow representatives, local public health officials,
conservative legislators (and their political supporters). Use of these
phrases by the average citizen may be benign as most have no knowledge of the corporate
sponsored misinformation campaign behind it.
What do the promoters of "sound science" hope to gain? There is no
simple answer, you will have to read all the information below to form an opinion of your
own. The short answer is paralysis by analysis, i.e. the ability to
talk and do nothing at the public's expense. In TRW's opinion, the solution is THE PRECAUTIONARY PRINCIPLE, click here for details
Below are links to extensive research pertaining to the shadowy world of "sound
03/05/12 "Sound Science" debunked.
The significance of EPA’s
recent release of the non-cancer portion of the dioxin reassessment cannot
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this cadre of apologists insisted on using the EPA’s outdated (1980’s) soil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
·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
·The vulnerability of children, women, infants or the
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
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.
02/03/11 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
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
Garabrant challenged on links to Junk
Science in court
From the Madison Record:
An epidemiologist testifying for 3M in a Madison County benzene trial
told jurors Thursday that studies indicate that benzene does not cause
the type of cancer at issue in plaintiff Veto Kleinaitis's case.
Dr. David Garabrant, an epidemiologist from the University of Michigan
at Ann Arbor, testified Thursday morning that there is no link between
benzene exposures and developing mantle cell lymphoma (MCL) or other
Non-Hodgkin's lymphomas (NHL). ....
Plaintiff's attorney William Kohlburn spent much of the early part of
his cross examination of Garabrant attacking his work for other chemical
producers and defendants.
"So, lately a great deal of the money you make testifying that things
don't hurt people comes from the companies that make those things?"
Kohlburn asked. ...
Kohlburn questioned Garabrant at length about his studies of Dioxin
that were funded by Dow Chemical Company ....
"How do you feel about offering testimony on behalf of a company that
was studying people while exposing them to bad things?" the plaintiff's
attorney asked. ...
Months after releasing documents that show that the University of
Michigan allowed Dow Chemical to preview publications about its dioxin
exposure study, the university has so far refused to release any
communications between Dow and the university researchers being paid to
carry out the study.
Because the university is publicly funded, such
communications fall under the Freedom of Information Act and legally
must be turned over upon request, but after five months the university
has failed to answer such a request — despite having cashed a check to
reimburse the expense involved in fulfilling the request more than 10
Since 2003 U of M has received at least $15 million dollars to carry
out a study that involves exposure to the chemical dioxin among
residents of the Saginaw River watershed. Dioxin is a highly toxic and
cancer causing byproduct of chemical manufacturing and Dow Chemical’s
operations at its Midland facility are the source of dioxin
contamination in the watershed.
Dioxin has contaminated the floodplain of the Tittabawassee and
Saginaw Rivers and the plume of contamination stretches into Lake
Huron’s Saginaw Bay.
In 2003, residents of the contaminated floodplain filed a class
action suit against Dow Chemical seeking medical monitoring and property
damages. That same year Dow commissioned a study by the University of
Michigan School of Public Health to examine whether there is a
relationship between levels of dioxin in soil and household dust and
levels of dioxin in people‘s blood.
The study did not involve many samples from the area known to be most
contaminated with dioxin, and it found only a small relationship between
soil and blood dioxin levels. In public presentations about the study
results, however, lead researcher Dr. David Garabrant insisted that the
study had found no relationship between blood and soil levels.
The dioxin exposure study got a great deal of publicity in the
greater Saginaw area, and though it was not a study of the health
effects of dioxin exposure, in public events and in news coverage it was
frequently portrayed as scientific evidence that area residents need not
fear the contamination.
Both the state Department of Environmental Quality (now the Dept. of
Natural Resources and Environment) and the U.S. Environmental Protection
Agency found it necessary to commission and present critiques of the
Among the shortfalls identified in these publicly funded reviews was
that the study didn’t give adequate attention to groups that could be at
special risk, such as children who have greater exposure to soils or
people who eat fish from the contaminated watershed. The government
reports also pointed out that the study did not sample heavily in the
most contaminated areas. Despite these limitations chemical industry
groups have lobbied to have the study be used by government agencies
involved in regulating dioxin and cleaning it up.
The study authors have insisted that Dow’s sponsorship of their work
had no affect on it.
In a Dec. 3, 2009 e-mail exchange with Michigan Messenger Garabrant
insisted that Dow received no preferential treatment by researchers.
“Our research contract does not require us to share our presentations
with Dow or anyone else. Dow, MDEQ, and everyone else are welcome to sit
in the audience at any public presentation we make,” he said. “We do not
provide our materials to any stakeholder preferentially, including MDEQ
and Dow. They will get the presentations when all other stakeholders get
them – when they are posted to the web.”
However, a copy of the contract between U-M and Dow, obtained by
Michigan Messenger through a FOIA request last fall, shows that Dow was
allowed to preview all communications about the study.
Sponsor recognizes that under University policy, the University
must be free to publish results of University Project and agrees
that researchers engaged in Project shall be permitted to present at
symposia, national, or regional professional meetings, and to
publish in journals, theses or dissertations, or otherwise of their
own choosing, methods and results of Project, provided however that
Sponsor shall have been furnished copies of any proposed publication
or presentation at least one month in advance of the submission of
such proposed publication or presentation to a journal, editor, or
other third party.
In an effort to understand what this provision of the contract meant
for the study and public presentations about the study, Michigan
Messenger in October filed a FOIA request asked for copies of
correspondence between U of M and Dow about the presentation and
promotion of the study.
U of M’s FOIA office identified the records in November, and cashed a
$240 dollar check to cover the labor costs of sorting the files and
preparing the response, but more than 10 weeks later still has not
produced the documents.
These documents are important to ascertain what influence Dow may
have exerted over the study’s methods and results, and over the way
those results are communicated to the public, because experts say
corporate funded research is far more likely to support the vested
interests of that funder than independently funded studies.
Social psychologist Carol Tavris earned her Phd from the University
of Michigan in 1971 and wrote about the dangers of the corporate funding
of research in her recent book with Elliot Aronson, “Mistakes Were Made
(But Not By ME).”
Tavris said that when the firewall between industry and research is
breached there is corruption and sometimes the funded scientist isn’t
even aware that he or she has become corrupted.
“Fundamentally what happens is that if I accept money to do research
from a company with a vested interest in the outcome of my research I
will continue to think of myself as unbiased, but the fact is that I am
biased in terms of interpreting data in a way that benefits my funder or
else I won’t get more funding.”
“As universities in their quest for money began breaking down what
was once a massive firewall between research and industry they began to
lose track of how funding blinds them,” she said.
Tavris said that comparing the results of studies funded
independently and those funded by industry shows a consistent and
undeniable bias toward the interests of the corporations that funded the
In her book she describes one case in which two investigators
“selected 161 studies all published in the same six year span, of the
possible risks to human health of four chemicals. Of those funded by
industry, only 14 percent found harmful effects on health; of those
funded independently, fully 60 percent found harmful effects.”
In another case:
“A researcher examined more than 100 controlled clinical trials
designed to determine effectiveness of a new medication over older ones.
Of those favoring the traditional drug, 13 percent had been funded by
drug companies and 87 percent by nonprofit institutions.”
Tavris said that Dow’s requirement that it preview presentations
about the dioxin exposure study compromises the project.
“If you are going to accept money from any funder with a vested
interest the rules have to be clear and ruthless. There needs to me a
firewall between funder and the vested interest.”
Even without such a preview provision, she said, where there is
corporate funding, “the researcher will be bending over backwards to get
the results they want.”
Tavris also pointed out that there is a history of corporate funding
compromising research at the University of Michigan, even when it
involved far lower amounts of money — and Dow was even involved in at
least one previous scandal.
In 2001, FOIA requests by the Louisville Courier-Journal revealed a
very close relationship between CSX railroad and the University of
Michigan researchers that it had hired to study whether exposure to
chlorinated solvents had caused brain damage in CSX workers.
The newspaper reported that CSX and Dow Chemical had paid more than
$170,000 for research that concluded that there was no link between the
workers solvent exposure and their diagnosed brain damage. It also
reported that while carrying out the study two of the researchers had
worked as paid expert witnesses for law firms representing the railroad
in the lawsuits filed by workers.
According to a June 26, 2001 Associated Press account of the scandal,
the CSX and Dow Chemical-funded study “was conducted without consent
from the workers, using data from medical tests they underwent at the
university years before, not knowing those tests would become research
The University insisted that corporate sponsorship has had no impact
on the study and an investigation by the U-M Institutional Review Board
cleared lead author Dr. James
Albers and his colleague Dr. Stanley Berent of any wrongdoing in October
Two years later federal investigators found that the University had
failed to follow correct protocol when it allowed doctors to access
medical records without permission.
According to a March 10, 2003 AP report the U.S. Department of Health
and Human Services Office of Human Research Protection ordered the
University to submit a correction action plan and to respond to other
Both Albers and Berent are still listed as faculty on the website of
the U of M School of Public Health.
Dr. David Garabrant, the lead investigator for the U of M Dioxin
Expose Study was also one of the researchers in the CSX sponsored
For the last six years,
University of Michigan research funded by
Dow Chemical has figured prominently in public discussions over what to
do about the dioxin contamination caused by the company in the Saginaw River
watershed. Federal and state environmental agencies have warned that U-M’s
Dioxin Exposure Study has failed to answer crucial questions and that
its results are being misinterpreted.
Despite this, U-M’s lead researcher on the project — a man some
environmental health scientists say should not be seen as objective because
of his track record of working for industry interests — is actively
insisting his study should shape regulatory action on dioxin.
David Garabrant, professor emeritus and founding director of U-M School
of Public Health’s
Risk Science Center, is the lead researcher on U-M’s Dioxin Exposure
Study which was funded with $15 million from Dow.
confidential EPA memo leaked to the media in the summer of 2007,
the agency was more blunt, naming the university’s Dioxin Exposure Study as
one of several Dow actions intended to impede cleanup.
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.
“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
“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.”
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
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.”
Click hereto view the confidential EPA memo detailing Dow's deceptive tactics
accidentally released to the Lone Tree Council as part of a FOIA request.
See 12/7/07 Detroit Free
Press story for an interpretation. Note: there have been two
breaking stories in the last 24 hours, the
whistle blower lawsuit
filed yesterday about Dow submitting flawed data to the MDEQ is unrelated to the
leaked EPA memo above. However they both share a common theme: a sneaky and
unscrupulous Dow Chemical The Detroit Free Press reports (a few snippets)
EPA found state failed to stand up to chemical giant
With the state's complicity, Dow Chemical Co. has delayed cleanup
and misled the public about the dangers of dioxin it dumped decades
ago into rivers downstream of its Midland plant, Environmental
Protection Agency officials charged in a confidential August
The memo, obtained by the Free Press, also said Dow impeded state
efforts to force a cleanup, concealed data and studies, tried to
keep documents confidential that should have been made public and
insisted on negotiating cleanup details with Gov. Jennifer
Granholm's office, rather than staff of the state Department of
Environmental Quality. ...
The situation has left people living along the
Tittabawassee and Saginaw rivers frustrated. Their yards
and homes are contaminated with dioxin that continues to
wash onto their land during flooding. ...
Separately from the EPA memo, a high-ranking Dow
employee, whose job was to oversee validation of test
results of soil samples tested for dioxin along the
river, filed a lawsuit in Saginaw County last month
claiming tests by Dow contractors were so flawed that
the laboratory doing the validation rejected them and
then quit, saying it didn't want to continue validation
work for Dow. ...
A revealing memo
The EPA memo accidentally was released within recent
weeks to the Lone Tree Council, an environmental group,
under a Freedom of Information Act request. ...
The memo said that Dow, unlike most companies, has
insisted on direct negotiations with the governor and
with Chester of the DEQ.
The EPA memo also said:
• Dow had done unapproved
studies and collected data without telling regulators.
The DEQ fined the firm $70,000 in January 2006 over
• Political figures, including legislators, have been
involved on Dow's behalf, trying to soften standards in
the company's favor.
• Dow tried to make dioxin seem less toxic. The EPA
issued a press release last month rebuking Dow for
statements downplaying the extremely high sample found
in the Saginaw River.
• Dow used a dispute process to make documents
confidential that should not be. The memo itself is one
of those documents. ...
• Under a
grant from Dow and pursuant to an unpublished contract
with Dow, the University of Michigan has conducting a
study of dioxin exposure in the Saginaw Bay watershed.
EPA does not consider the study to be particularly
relevant to the corrective action in this matter and
believes the study was initiated at the request of Dow
in order to downplay the risks of exposure to dioxin
Getting to the truth
In her suit, whistleblower Denney
the independent laboratory double-checking the dioxin results told
her in November 2006 that the data from Dow's contractor was badly
Denney told her bosses. A week later, they ordered her to stop
doing any work relating to the data validation.
The lab rejected
the data in a letter Dec. 5, 2006, saying it couldn't validate it.
On Dec. 8, the lab sent Dow a letter terminating its contract,
citing a breakdown in procedures. Denney's suit said Dow submitted
the bad data to the DEQ in February.
"She's been shut out," said Victor Mastromarco Jr., Denney's
Click hereto view the whistle blowers suit document
6/4/06 Dow's Paustenbach "scientist for hire" a fraud, T.River studies
"In a real-life epilogue to "Erin Brockovich," a peer-reviewed
medical journal will retract a fraudulent article written and placed by a
science-for-hire consulting firm whose CEO sits on a key federal toxics panel.
The retraction follows a six- month internal review by the journal, prompted by
an Environmental Working Group (EWG) investigation" ... "It is abundantly clear
that CDC's contractor, ChemRisk, does not have the necessary scientific or
ethical integrity to engender public trust," EWG's Wiles wrote to CDC Director
Julie Gerberding in March. "It is also clear that ChemRisk founder and president
Dennis Paustenbach has been directly involved in the firm's unethical behavior."
Click here to view entire
article, source: www.ascribe.org.
Why should we be concerned? Dow's "Sound Science" has Paustenbach
fingerprints all over them
Paustenbach is involved with a number of firms contracted by Dow for their
manipulated studies. "There is a whole industry that
exists to convince regulators that exposures aren't dangerous in order to get
companies off the hook and Paustenbach and (his former firm) Exponent are
middle of that industry." ," says David Michaels, an environmental research
professor at George Washington University who served as assistant secretary for
Environment, Safety and Health at the U.S. Department of Energy from 1998
through January 2001. Incidentally, when a Newark Star-Ledger's
investigator asked a former Clinton Administration environmental official about
Paustenbach, he replied: "Ah, Dr. Evil."
Dennis Paustenbach for hire, current and former affiliated companies
(that we know of):
Pausenbach not mentioned, but
this is the type of company that hired him:
The Board of Ethics (the “Board”) pursuant to the authority
contained in LSA-R.S. 42:1141, conducted a private investigation
concerning information that William Kucharski, Secretary of the
Louisiana Department of Environmental Quality, may have violated
Section 1111C(2)(d) of the Louisiana Code of Governmental Ethics (LSA-R.S.
42:1101 et seq.) (the “Code”) by sharing in income received by his
wife, Lynn Kucharski, as salary for services performed for McLaren/Hart
Environmental Engineering Corporation (“McLaren/Hart”), at a time
when that corporation had substantial economic interests which Mr.
Kucharski could affect by the performance of his official
Originally proposed in the 2002 CACO,
Paustenbachs proposed "Probabilistic Risk Assessment" methods resurfaces in
of Work for the Tittabawassee River floodplain. The EPA stated
such methods are not allowed in it's 2006 letter of "Critical
Paustenbach is a member of the EPA's Science
Advisory Board and participates in the EPA's
Dioxin Reassessment Review. Much to the Chemical industries
delight, his "contributions" have assisted in delaying the agencies final
report by almost 15 years.
The Environmental Working Group
put together an excellent expose on the matter, below are the tactics used by
Paustenbach to fraudulently submit "sound science" papers to unsuspecting
Failure to disclose who wrote the manuscript.
Failure to disclose that the study was funded by PG&E.
Falsely stating in the published paper that stomach
cancer rates weren't available for the province.
Basing analysis on the level of contamination detected in
the wells in 1965, knowing that by the end of that year the picture of
contamination in the wells had dramatically changed.
Ignoring useful data that were readily available.
Misrepresenting the study design in several ways to make
it seem stronger.
Failing to disclose key facts about the data presented.
Simultaneous submission to two journals.
The bottom line: The next time you hear Dow supporter utter "Sound
Science", think of Dr. Evil
WHO bars Dow from participating in setting global protection standards
"The WHO and other public health agencies risk their
scientific credibility and may be compromising public health by
partnering with ILSI,"
"the institute 'has a demonstrated history of putting
the interests of its exclusively corporate membership ahead of science
and health concerns, and that ILSI's special status with the WHO provides a
back door to influence WHO activities.'
Canadians contesting the false principle of "Sound Science", what about US?
The Canadian Environmental Protection Act
calls on the government to use
in its risk management of toxins, but the principle has not been used.
"As the federal government comes under
criticism for failing to properly regulate toxins and carcinogens in
consumer products and the environment, the Standing Committee on
Environment heard last week that government departments have relied on a
faulty approach of using "sound
science" to determine the risks associated with toxins." ... "Sound
science, if you read any of the literature on it, was a term created
by industry, deliberately, to interject uncertainty, to interject doubt
into decision-making. So the fact that we have sound science in our
federal documentation suggests that we're really lining ourselves up
with the kind of language the industry uses, deliberately, to undermine
"Much of the modern conservative agenda on science is embodied in the
enigmatic phrase "sound science," a term used with increasing frequency these
days despite its apparent lack of a clear, agreed-upon definition. In one sense,
"sound science" simply means "good science." Indeed, when unwitting
liberals and journalists have been caught using the phrase - which happens quite
frequently - it appears to have been with this meaning in mind. ... Conservatives, too,
want people to hear "good science" when they say "sound
science." But there are reasons for thinking they actually mean something more by the
term. ... In this sense, "sound science" seems to mean requiring a high
burden of proof before taking government action to protect public health and the
environment (not really a scientific position at all). ... U.S. House of
Representatives, chaired by Utah Republican Chris Cannon, notes that "environmental
laws should be made with great caution and demand a high degree of scientific
certainty" - once again, a policy statement rather than one having to do strictly
with science. " Chris Mooney, www.gadflyer.com
"Junkman" Steven Milloy has made a career of lobbying for
polluting industries, heading corporate front groups to deny environmental concerns, and
ridiculing individual environmentalists on behalf of corporate interests. In the world
according to Milloy, any scientific study that does not support the world view where all
chemicals are safe is "junk science", all environmentalists are alarmist, and
pollution and second hand smoke are harmless. The labels fly fast and furious, regardless
of where the scientific mainstream falls on an issue and regardless of what point we are
at in the scientific discovery process."
"[Environmental Working Groups (EWG) Web site, August 16, 1998] [T]his
"sound science" coalition is supported by hundreds of corporations, including
3M, Amoco, Chevron, Dow Chemical, Exxon, General Motors, Occidental Petroleum, Philip
Morris, Proctor & Gamble and W.R. Grace. Its objective is to act as a speakers bureau
to deliver the corporate message that environmental public policy is not currently based
on "sound science," and to counter excessive regulations that are based on what
it considers "junk" science. ODywers PR Services reports that TASSC
is "leading the charge against what it views as the unholy alliance between
environmentalists and the media" (Feb. 1996). "
Media susceptible to Sound Science spin
Fair and balanced reporting?
Other than for the headline,
today's local news coverage of Granholms possible veto of HB4617, the story
is entirely one sided with no input from the homeowners and the rest of the
state that want the bill vetoed. Recently (12/8, see
story below), the local newspaper published an article about toxins in
the Great Lakes and edited out a key paragraph about the human health effects of
dioxin and other compounds. This pattern was repeated on a local radio
station which aired two interviews this morning. The first segment was
with an individual from Midland representing those few which favor Dow Chemical,
the second was with Lone Tree Councils Terry Miller, representing the rest of
us. The radio host was all warm and gushy with the Dow guy and
virtually attacked Terry. Click on the links below to listen to the Lone
Tree radio broadcasts:
Don't kid yourself - toxins persist in the Great Lakes.
All but one paragraph of this report was printed on front page (not
on-line) by the local newspaper.
Below is the section the left out:
"(The board cites) compelling
evidence that contaminants we've known about for decades -- PCBs,
dioxin and mercury -- are causing increased disease, reduced IQs and
other serious health problems in humans," said Mike Magner, a
researcher with the center. "On top of that, they warn that a host
of other chemicals -- flame retardants, plastics additives and even
cosmetics and health-care products -- may be compounding those
"Monsanto has in fact submitted false information to EPA which
directly resulted in weakened regulations under RCRA and FIFRA since these
regulations do not take into account tetrachlorinated dioxin contamination in trig, tetra,
and pentachlorophenols, as well as 2,4-dichlorophenol and its phenoxy acetate (2,3-D, a
currently used herbicide). In addition, Monsanto's failure to report dioxin contamination
of the disinfectant in Lysol has prevented any ban or other alleviation of human exposures
to dioxins in this product. "
"The Monsanto human health studies have been submitted to EPA by
Monsanto as part of public comments on proposed dioxin rules and Agency-wide dioxin health
studies are continually relied upon by all offices of EPA to conclude that dioxins have
not caused cancer or other health effects (other than chloracne) in humans. Thus,
dioxin has been given a lesser carcinogenic potential ranking, which continues to be the
basis of less stringent regulations and lesser degrees of environmental controls. The
Monsanto studies in question also have been a key basis for denying compensation to
Vietnam Veterans exposed to Agent Orange and their children suffering birth defects from
such parental exposures."