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Dow Wild Game study: just the facts, no spin

Click on a link in the image below to view the Entrix studies results as graphs & raw data without the Dow spin. The Squirrel, Turkey, and Deer links are specific the Dow WG study and include graphs of the Total TEQ levels of ALL the   samples.  This information was gleaned from the 321 page Dow Final report which intentionally presents the results in a manner that most people would never understand.   The Humans, Fish, Birds, Soil, and Sediment links offer additional information about activities related the the contamination   including reviews of the Dow WG data by the EPA's Dr. J. Milton Clark  and GES's Dr. Hector Galbraith.

bulletClick here for official Final report: MDCH Dioxins in Wild Game Taken from the Tittabawassee River Floodplain South of Midland, Midland and Saginaw Counties, Michigan EPA ID# MID980994354  Final Report April 29, 2005.  Report is officially peer reviewed and backed by the Federal Government ATSDR.
bulletClick here for official State of Michigan T.River Flood Plain Wild Game Consumption Advisory. The Michigan Department of Community Health has issued an advisory against eating wild turkey meat or deer liver and urge consumers to limit consumption of venison and squirrel harvested in or near at least 22 miles of the floodplain along the Tittabawassee River. Although dozens of advisories exist for fish tainted with toxic chemicals, it is only the second time the state has issued such a warning for terrestrial animals.
bulletClick here for official MDEQ Analysis of Wild Game Study. Levels of dioxin in the wild game harvested in the floodplain downstream of Midland are higher than levels found in game harvested from a location upstream of Midland (2 to 120 times higher). Typically, the highest concentrations were seen in the samples collected near Imerman Memorial Park.
bulletEPA: "Unacceptable, elevated cancer risk's to public health to frequent consumers of fish"
bulletGES: The studies design results "in an underestimation of the contaminant concentrations to which wildlife would be exposed and, hence, the magnitude of the risks incurred."

vvvv Click on the links in the image below for details of the study. vvvv

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bulletClick here to listen to more of the Dr. Linda Birnbaum (EPA)  presentation: "Dioxin, are we at risk?".   You are hearing a clip from the video when this page is opened.
bulletEPA memo (7/30/04) to the MDEQ indicates the results of the Dow/Entrix Wild Game study in the Tittabawassee River Flood plain are much more serious than the Dow Press release indicates.  The EPA goes on to state that they may need "to become engaged in the dioxin contamination problem and to re-enforce existing risks to public health and wildlife".  A summary of the memo was published today in the Midland Daily News.  Conclusions:
bulletThe contamination has similar characteristics regarding levels of risk and area affected as the Kalamazoo and Fox Rivers, which are currently a focus of the US EPA remediation plans.
bulletIt is clear than a persistent, un-addressed dioxin problem exists.
bulletUnacceptable, elevated cancer risk's to public health to frequent consumers of fish.
bulletPotential health risks to persons consuming game.
bulletDioxin contamination of game indicate contamination of the terrestrial food chain
bulletUnacceptable, serious aquatic ecological risks to fish, fish eating birds, and mammals.
bulletStrong consideration should be given to removal of dioxin contaminated  sediments and flood plain soil.
bulletThere is particular concern regarding distortions of risk information which are causing inaccurate risk messages to the public.
bulletClick here to read the EPA 7/30/04 memo.
bulletGES memo (7/16/04) to the MDEQ indicates the results of the Dow/Entrix Wild Game study in the Tittabawassee River Flood plain confirms findings of MDEQ/GES 2003 T.River Aquatic Ecological Risk Assesement.  Conclusions:
bulletReview of the Entrix (2004) report has shown that the data contained therein support one of the major conclusions of the Michigan DEQ terrestrial ecological risk assessment (GES, 2004), that is that biota and food chains on the Tittabawassee River downriver of Midland are contaminated by PCDDs and PCDFs. A reasonable conclusion from this is that predators and scavengers at the tops of these food chains are likely to be even more exposed to these contaminants than the deer, squirrels, and turkeys sampled in the Entrix (2004) study.
bulletHowever, the Entrix (2004) study was designed to generate data for an evaluation of risk to human health, rather than to ecological receptors. Because of this, design elements in the Entrix (2004) study, though perhaps appropriate for a human health risk analysis, result in an underestimation of the contaminant concentrations to which wildlife would be exposed and, hence, the magnitude of the risks incurred. These design elements comprise:
bulletThe sampling was confined to organisms which, because of their diets, are unlikely to bioaccumulate PCDDs and PCDFs to the extent that other organisms would.
bulletThe carcass handling procedures resulted in a likely underestimation of the magnitudes of the PCDD/PCDF whole-body burdens to which predators and scavengers may be exposed.
bulletThe sample spatial distribution almost certainly results in an underestimation of the PCDD/PCDF body burdens of turkeys in the lower sections of the floodplain, and, hence, in the potential exposures to their predators and scavengers.
bulletClick here to read the entire July 2004 memo
bulletTittabawassee River Aquatic Ecological Risk Assessment Slide Show
bulletTittabawassee River Aquatic Ecological Risk Assesement Final Report (pdf)
bulletClick here to review the Dow/Entrix 321 page report which contains the actual data.  We welcome anyone to review the data and provide corrections to those presented on this site.  Dow lawyers should love this as they will be able to bill Dow for another 1000 hours or so.  And you can bet if they find a mistake, they will not reveal it until we are in trial.
bulletClick here to review the Dow Public Relations spin summary of the study which contains all the speculation, statistical manipulation, and other types of misinformation.  The conclusions are especially entertaining.   According to Dow, If you intend to eat any wildlife from the floodplain, the game is safe to eat.  We say just make sure you get an "Average" specimen.  When you review the data it will be evident that many specimens exceed the average by orders of magnitue.  How lucky do you feel? 

"OK, with a great deal of reading and some perseverance one need not be a rocket scientist to get to the substance of the Dow Wild game study. Substance being the operative word! Able to spin their abysmal findings and get their desired headlines and slant, Dow’s press release in no way reflects the high levels of dioxin found in these floodplain animals. Dow apparently diluted and or averaged the numbers south of Midland taking their "sound science" spin to new levels. The hard data which appeared later on Dow’s website confirms that dioxin in the floodplain soils is available to individual game animals at very high levels in many cases. Some of these animals are very young and many were found to have numbers that exceed 100ppt TEQ. The national standard is less than .5 ppt. Headlines and news stories accomplished what Dow wanted ----to convince the public that these game animals were no more harmful than supermarket chicken. Nothing could be further from the truth. It’s not rocket science take a look at the data yourself. " 

"Dow’s wild game study was spin, not " sound science" and in fact is tantamount to a lie. There is no excuse and no ethical justification for this corporate misdeed. If Dow wants people to trust that they are committed to "sound science" and " working with the community", they need to stop twisting, distorting, lying and omitting information. "

"One other major distortion? Dow’s Wild game Study contrary to their press releases in November and this month, was not approved by DEQ. Resolution to this issue will never come to fruition so long as Dow’s misinformation campaign and manipulation of the facts go unchallenged by those agencies and officials, state and local, charged with protecting the health and welfare of the people. "    [Excerpts from the Lone Tree Council/Trw Dioxin Update News letter of 7/27/04]


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