lane county February 20, 1985 HP 44750-12 The Honorable Thomas P. O'Neill, Jr., Speaker United States House of Representatives Capitol Building Hashington, DC 20515 Dear Speaker O'Neill: Citizens in Lane County, Oregon have presented the Board of County Commissioners with infonnation regarding the United States Environmental Protection Agency. On that basis, it appears that since 1979, the EPA has acted to suppress and delay the validity and test results of a major human health study covering a 1,600-souare-mile area of western Oregon. Recently obtained documents from the study suggest the possibility of a public health emergency in western Oregon. Documents recently obtained under the Freedom of Infonnation Act demonstrate that EPA has been aware since 1980 that this study showed dioxin in over 60 percent of deer and elk tissue samples taken from forests in western Oregon, where an abnonmal increase of birth defonnities and reproductive problems in elk herds had been reported. Worse, dioxin was also identified in human mothers? milk samples and numerous domestic water sanples taken fron the sane area. The history of just one of EPA's sanpling sites is revealing. In 1979, EPA researchers reported to Lane County that dioxin was found at levels of 17-20 parts per trillion (ppt) in a residential water supply, and EPA's contract epidaniologist advised the family that the water was unsafe. The family had been drinking the water for seven years, during which time they suffered chronic respiratory and gastrointestinal ailments, two miscarriages and a child born with defective lungs and liver and learning disabilities. The husband sdasequently died of heart disease at age 38. This water supply was sampled again in 1979, but because of an alleged "mixup" with samples fran Dow Chemical, was reportedly not analyzed until 1983, and found negative. In August, 1984, EPA researchers again collected samples from this site. In December, EPA reported finding dioxin levels in five out of these six sanples, at levels frun 10 to SD ppt. Despite EPA's emphatic position in the cancellation proceeding that no safe level of dioxin can be demonstrated, and deSpite the warning in 1979 that 17-20 pot of dioxin in this water rendered it unsafe to drink, nevertheless, EPA announced in December 1984 that up to 50 presented no health hazard. The last known application of or silvex in the vicinity of this par- ticular site occurred in 1976, yet the dioxin levels have apparently increased between 1979 and 1984. This is perhaps explained by additional documents obtained under FOIA, reporting (in 1980) that ?dioxin contamination of pesti- cides and the environnent is increasing", referring to a list of some COURTHOUSE PUBLIC SERVICE 125 EAST 81H AVENUE ClRitaL?N ter to The Honorable Thomas P. O'Neill, Jr., age 2 HP 44750?12 20 pesticides other than and silvex "that may contain dioxins, based on an analysis reflecting 50th the manufacturing processes and chemical structure of those pesticides." study, known as the Alsea Study, correlated human involuntary abortions with the time, location and dosage of herbicide spraying in a 1,600?square?mile area representative of spray patterns in coastal forests from Washington to northern CaiifOrnia, triggering EPA's energency suspension of forestry and rights-of?way uses of and silvex in 1979. The study was vehemently attacked by ng Chgmigal and other industry advocates, who challenged its lack of any evidence of dioxin exposure in the study population. For four years, while industry proclaimed the study invalid in the scientific, medical and popular media, administrators and legal counsel? apparently _grdered the scientists who conducted the study not to publish it or to dafe?d it; publicly in any manner. During this fine, it is alleged that_?PA suppressed-- and in some cases misreported--results of laboratory analyses demonstrating widespread dioxin contanination in the study area mothers' milk, domestic water supplies, wildlife and in tissues of a baby born without a brain. At the very time the emergenty suspension of and silvex was announced, EPA was delaying evidence of dioxin exposure that confinmed the validity of the Alsea Study. (EPA's "scientific" explanation fer reporting that no dioxin was found in most of these sanples is that the samples ?may have been contaninated" with dioxin in the testing laboratory.) After fbur years of fruitless attenpts to obtain EPA test results, Oregon residents in August 1983, finally obtained results of some dioxin analyses directly fron the testing laboratory. The analyses showed alarming levels of dioxin in a range of samples. Although these results were reported to EPA in 1980, the agency failed to warn residents of the presence of dioxin, and elected not to release the infonnation in response to FOIA and discovery requests. After the testing laboratory released its results, EPA defused the resulting publicity by announcing that the laboratory analyses--completed and reported to EPA in 1980-?erroneously included samples from Dow Chemical CompagyLs_Midlangg Michigan facility; EPA has yet to provide satifactory evidence that such a mixup actually occurred. The EPA's Alsea Study is significant because it is the only major study of dioxin contanination from use of herbicides (as opposed to manufacture or dumping) documenting human?exposure to dioxin associated with human health impacts. Furthenmore, the similarities of topography, climate and herbicide use patterns in Vietnam and Oregon rain forests make the Alsea Study especially significant to the Vietnan veterans' case against Agent Orange. He have learned that an internal investigation was ordered and supervised by EPA Acting Administrator Lee Thomas. The appear to suggest that EPA may have misled the Oregon federal court and, further, that EPA failed to infonn either the public or the sanple donors of its test results (a pattern repeated in Hemlock, Michigan; Hempstead, New York; Arkansas, Missouri, Louisiana and elsehwere). Shortly after the Oregon dioxin tests were revealed in 1983, EPA and Dow agreed to cancel all registrations fer and silvex. ter to The Honorable Thomas P. O'Neill, Jr., age 3 HP 44750?12 The best evidence awailable suggests that western Oregon residents continue to be exposed to increasing levels of dioxin in their water, soil and food, asso- ciated with abnonnal increases in birth defects, involuntary abortions, cancers and reproductive disorders. Because of EPA's unc00perative and suspect behavior, we ask you to initiate a vigorous and thorough investigation of EPA's conduct of the Alsea Study and the cancellation proceedings and to authorize an independent study of dioxin exposure and human health in the Oregon coast range. We further ask that the study be subject to a citizen review board, with full public disclosure at all stages of design and execution. For the entire duration of this study, we ask Congress to order a moratorium on the use in the coast range of all pesticides potentially capable of containing or breaking down into TCDD or structurally related compounds. Sincerely, Peter DeFazio, Chair Lane County Board of Commissioners PD:cb 96 3-RisK, 99+- U1 LIST OF ATTACHMENTS December 22, 1984: The U.S. Environmental Protection Agency reports results of 1984 sampling from the same Five Rivers, Oregon, water supply where dioxin was found in 1979, says' less than one part per billion of dioxin is not a hazard. February 14, 1983: Dioxin sampling results from Missouri were withheld from E.P.A.'s Dioxin experts, who charged that E.P.A.'s one-part?per?billion dioxin "safety" level was "extremely hazardous." It is important to note that this standard was for soil contamination at Times Beach, not for human drinking water supplies or for food. March 28, 1979: In announcing its emergency sus- pension of forestry registrations for two dioxin- contaminated herbicides, E.P.A. discloses results of? Dow Chemical Company's three-generation study, says it found multigenerational reproductive effects from dioxin exposure at a chronic dose of one part per trillion in the diet per day. March 6, 1984: An E.P.A. document received under the Freedom of Information Act says that one out of six human adipose tissue samples from the Five Rivers area was positive at 12 parts per trillion of dioxin. No records have been provided of where, when, or from whom these samples were collected. January 13, 1982: A 1977 E.P.A. report was received under discovery in Merrell v. Block in response to a request for documents relating to E.P.A. human health studies in the area of the Siuslaw National Forest. Six human fat samples were positiVe at TCDD levels ranging from 4 to 64 ppt, a range similar to levels later found in Vietnam War veterans' fat samples. E.P.A. has provided no other information about these Oregon samples. Laboratory reports on TCDD analyses of Oregon deer and elk fat introduced into E.P.A.'s 2,4,5-1? cancel? lation proceedings show 50 per cent to 77.8 per cent of samples positive for TCDD at levels up to 68 parts per trillion. .January 17, 1985: A 1979 E.P.A. document was re- ceived under the Freedom of Information Act which states that the rationale for E.P.A.'s study of TCDD residues in Oregon and Washington deer and elk was that the Oregon elk herd had "an excess" of reproduc- tive problems, including stillborns and birth de- formities. Several pages are excerpted from the same June 24, 1983 final E.P.A. report. All results were reported separately to E.P.A. during 1979 and 1980. The terim reports were obtained under FOIA during 1983 and 1984. The final report was recently received. pp. 1-6: Table II human milk samples collected from the Pacific Northwest, including western Oregon. Most of the positive samples were confirmed by other laboratories; E.P.A. subsequently concluded that the samples were negative because they ?may have been contaminated" in the laboratory. pp. 7?8: Table includes samples collected from the 1,600-square-mi1e study area surrounding Alsea in January, 1979. Preliminary, positive results of both these and the mothers' milk samples had been reported to E.P.A. by the time of its emergency suspens ion of 2,4,5?t registrations. Most of the positive results were confirmed by another laboratory, but again E.P.A. concluded that with the exception of one Lane County sample -- the samples were negative be? cause they "may have been contaminated" in the laboratory. Dr. Eldon Savage, E.P.A. contract epi- demiologist at Colorado State University, advised the donor of the reported positive sample that the house- hold water supply was unsafe to drink with levels of 17?20 parts per trillion TCDD. (This is the same site that was again positive in the 1984 sampling.) pp. 9-10: Table VII samples were collected in summer and fall of 1979 as part of the Alsea study. Most samples were from the Five Rivers area, within the Alsea study area. These results were reported to E.P.A. in 1980, but-were not released to the public despite repeated attempts to obtain them through Congressional petitions, Freedom of? Information Act requests, and discovery in Me-rrell v. Block. After this table (alone) was released by the Nebraska lab? 10 ll 12 oratory in August, 1983, EJKA. announced that the high?level sediment and sludge samples were not from Oregon, but were instead from Dow Chemical's Midland, Michigan manufacturing facility. Despite FOIA administrative proceedings and a lawsuit, Elke. has still not provided evidence supporting this an? nouncement. The low levels of dioxin in the newts are significant because the animals were collected from the same water supply found positive for dioxin in Table and again in 1984. The low levels of dioxin found in the products of conception (sample No. are significant because that sample was from a full?term baby born without a brain. E.P.A. later announced that both these samples were negative for dioxin. Not included on Table VII are results of domestic water samples taken at the same time, re- porting dioxin levels in the water supply of a prop- erty where three women have suffered a total of seven miscarriages and two men have died of cancer. later reported this sample as negative also. December'12, 1980: Oregon state officials reject a study proposed by theILS. Centers for Disease Con- trol examining possible relationships between herbi- cide spraying and the incidence of neural tube birth defects. That category of birth defects includes anencephaly, the type of birth defect suffered by the baby positive for TCDD in its tissues in Table VII. Centers for Disease Control statistics on neural tube birth defects in Lane, Lincoln, Benton and Polk coun- ties, showing significant increase in particular birth defects during 1970-78. These findings prompt- ed the CJLC. proposed study rejected by the state of Oregon. An overview of the local medical community's concerns about the unusual incidence of neural tube birth defects in Lincoln and Benton counties is reproduced from The Medical Tribune series. Fall, 1984: Under FOIA request, EJLA. provides unpublished draft report, circa spring 1983, by Drs. Jack Griffith and Robert Duncan, the scientists who headed the Alsea study for EJKAH They note that they had been constrained by'Tika.administrators and legal counsel not to discuss their work in any 12 public forum," and describe the circumstances compel- ling them to prepare an accurate report because the E.P.A. Alsea study findings "have been seriously misrepresented to both the public and the scientific communities by proponents of the chemicals . . 13 April 4, 1980: E.P.A. document received in fall, 1984. Dr. Griffith writes to tOp civil service mana- ger of E.P.A. pesticide program, expressing concern that E.P.A. restraints on study scientists, prevent?" ing them from defending their work against industry ?attacks, have allowed industry views to_prevai1 even within E.P.A.. Dr. Griffith points out that Hie Alsea study report released by E.P.A. was ?severely edited" in particular of all background informa? tion -- and reviews the reasons why the original, unedited report is valid. He emphasizes the signifi- cance of the study, which ?would provide us with the only opportunity for a viable human link between and possible adverse health effects." 11+ September 11, 1983: E.P.A. Office of General Counsel memo reviews agency responses to FOIA and discovery requests for results of Oregon dioxin analyses, con? cludes that did not fully respond to Merrell's discovery requests and that the government made certain statements in its pleadings which were apparently incorrect.? 15 Fall, 1984: E..P.A. releases a 1980 budget justifica? tion report from the head of Pesticide Programs to a Garter Administration appointee. Summarizing dioxin programs at E.P.A. in 1980, the document refers to a list of 20 pesticides other than and silvex "that may contain dioxins." (A FOIA request for this list is outstanding.) .The report notes that the E.P.A. pesticide program's ?dioxin monitoring re- quirements and responsibilities are increasing because dioxin contamination of pesticides and the environment are also increasing," and expresses con? cern about other substances which are structurally or toxicologically similar to dioxins. Jer The attached NCAP "History of is a pretty good summary chrOnology through March 1981. Adding some pieces that are missing from it, and events that have happened since, you can fill in some gaps: 1979 Agent Orange veterans class action suit filed against Dow et al February: preliminary analytical results from some Alsea area samples and NW'mothers' milk are reported with many positive for dioxin, just before emergency suspension announced. August Second round of Alsea area (Five Rivers) samples collected (continuing through January '80) 1980 August?December: analytical results of second round of Alsea area samples reported, with many positives, in particular tissues from a baby born without a brain in the study area containing 3 dioxin. 1981 March: The same month EPA and Dow go into negotiations to settle the 2, 4, 5-T case, Dow settles a massive suit brought ten years before by residents of Globe, Arizona exposed to by the Forest Service, acknowledging that the outcome of the case could affect the Agent Orange vets' case. May?July An EPA Region report on dioxins is edited drastically by headquarters staff in D.C. (Hernandez) at Dow's request. Dow specifically asks that references to Alsea and Agent Orange be altered or deleted. April?December: Paul Merrell sues Forest Service, BLM, EPA, EPA refuses to answer discovery requests for records and results of Alsea/Five Rivers study. 1982 continue closed-door negotiations, EPA joins Dow in successfully oppgs ing an NCAP motion to refer questions of scientific fact the Alsea Study) to a committee of the National AEEdemy of Sciences. Merrell continues unsuccessfully -- to obtain Alsea/Five Rivers Study documents under Freedom of Information Act (request filed in 1981). 1983 April: U.S. District Court rules in favor of Merrell, banning herbicide spraying in Alsea Study area until federal agencies complete safety studies and make them public. Publication of A Bitter Fog: Herbicides and Human Rights. EPA Acting Administrator John Hernandez resigns following congressional inquiry into his 1981 1983 (cont.) 1984 1985 July: August: Chronology continued editing of Region dioxin report (see above). Mike Axline, of 0 law professor representing Merrell on appeal, obtains results (Table VII) of some 1979 Alsea/Five Rivers samples directly from the analytical laboratory. High levels of dioxin (5800 ppt) in sludge and sediment, low levels in wildlife and baby born without brain. Table VII introduced in court hearing (NCAP case) triggering national publicity. EPA defuses media attention by announcing the high level samples were not from Oregon, quietly acknowledging three days later that the samples had not been decoded yet. Ten days later, EPA announces the high level samples are from Dow Chemical Company's Midland, Mich._plant. September-October: EPA prepares internal investigation to August: November: December: February: "explain" what happened to Alsea/Five Rivers Study; EPA and Dow agree to end negotiations on and cancel all registrations -- according to the "grapevine" within EPA, this was the direct result of Table VII being released. EPA returns to Five Rivers, collects sediment samples from a single site, the only water supply previously tested which is no longer used for drinking. Mike Axline files Freedom of Information Act suit against EPA (van Strum v. Ruckelshaus) on request for documents relating to Alsea/Five Rivers Study, lists over 25 categories of documents EPA has failed to provide. 2 EPA announces 5 out of 6 August 84 samples positive for dioxin at levels "up to 50 parts per trillion." EPA releases "Five Rivers Update" report, showing up to 78 dioxin at August '84 site. Judge weinstein denies Agent Orange vets' claims against the government, finding no evidence of "adverse human reproductive effects associated with exposure to phenoxy herbicides." Tests tint Cl?itll?i at EUGENE Tests done tor the Environmental Protection Agency shomr dioain contamination in the Five Rivers area southwest oi Corvallis but otiicials and environmentalists are at odds over whether the level is sale. Samples were taken in August to determine whether herbicide spraying had contaminated rivers and streams in the area with the potentially cancer-causing chemical. EPA spokesman Bob Jacobson told KVAL-TV 1n Ett- gene that results by the Centers for Disease Control in Atlanta show dioxin levels up to 50 parts per trillion. Renate Kimbrough. a toaicologist at the CDC. told the television station the levels lottnd by the testing are not considered dangerous. . "We lound that anything below one part per billion would riot give people a sullicient dose its cause ?We found that anything below one part. per billion would not give people a sufficient dose (to cause harm).' hannl." she said. But Five Rivers resident Paul Merreii says a Uni- versity of Oregon molecular biologist lound that as little as one part per trillion could cause long-term genetic damage. . Men-ell says the EPA commissioned the late George Streisinger to evaluate a Dow Chemical Co. study of dioxin. "Ills (Streisinger'sl conclusion was that he found genetic defects over several generations at the lowest amount tested. one part per trillion." Mcrrell said. "George calculated that ii there was to be no eiiect the concentration would have to be in the parts per quadril- lion range." Merreil says he does not consider water from the, streams in the Five Rivers area sale to drink. although they are used as drinking water sources. He says the so- called""saie" levels are set arbitrarily. and he charges that political pressures play a role in setting levels. Merrell's wile. Carol Van Strum. author ol a book about the herbicide controversy. told KVAL on Friday mine Rivers A researcher ?found genetic de- fects over several generations at the lowest amount tested, one part per trillion.? Nomi-twins?? that "they [the EPA) have known thewaier had dioxin in it for a long time. They knew that dioxin was rte-sent in wildlife in this area since 1974. but they've never taken any action on it." Jacobson said the EPA will decide in a less weeks whether anv action is needed. Section it'd". Dmmboe 22. 1964 Eagle pitch at 18 earns Aoki victory; details in Sports VOL. 133 NO. 38.261 Lavelle accused of withholding NORTHWEST FINAL MONDAY. FEBRUARY 14. 1983 ll 54 PAGES data on dioxin Agency officials level further charges of pro-industry bias By GREGORY GORDON \il. ASHINGTON tl'Pll Several ol the Envi- ronmental Protection Agency's top dioxin ea- perts uere denied access lot months to sampling results lrom Missouri sites contaminated WITH the highly toitit chemical. agency ollittals said Su'da} At the same time. it was learned that a lot- mer thiel ol scientific support in an hazard- ous waste enforcement section has been given little to do lor the past Sit months One source said he has spent much at the time "reading newspapers The ullicial. Lamar Miller, had disagree- ments with ousted assistant EPA administrator R:ta Latelle over the handling 0! negotiations itli pritate companies ltorn which the gavern- meni sought cleanup damages. sources said position was that we made our he5t oller to parties. and it lhet turned ll down. wed sue them." one source said "Rita's was that we made our best alter. and it - they didn't lilte it. why. she?d change her oller. this had a phi-osophy that failing to get a settle- ment was a la lure." Three ollicials told United Press Inter- national that Lat elle. who was tired last Mori- day by President Reagan. restricted access at most men-titers of a spetial working group on chlorinated to the Missouri dioitin data The sources said such data was routinely prouded in the past to the entire group. whith includes a cross-section ol some of the agency's top scientists. engineers and health eeperts. The Missouri sites. including the entire town of Times Beach. Mo. and a re5idential area in the St Louis suburb at Imperial. have become one o! the most pressing problems lor the em- battled agency. under lire lrom several congres- sional committees. EPA otlicials. who asked to remain anony- mous. expressed concern that some experts were shut out of the inlormation stream at a time when agency experts needed all inlorniation possible even unconfirmed sampling results to help them prtipust cleanup actions and determine the danger to citizens. The group had no role in setting the agency's controversial action plan tnat would leave dioitio levels in Missouri soils a: pan per billion. a level the group has in the past consult-red eit- tremely hazardous. one group member said It uas disclosed last tail that Lovelle's stall considered a cleanup level as high as IUtl parts per billion. or to IOUJIUU times higher than the level lolluwtng the cleanup at Love Canal. Latelle. lacing set-era] investigations. has been sharply criticized by lawmakers. tnl'll?on- mental groups and EPA employees for being too cozy with industry and agreetng to inadequate cleanup actions. Speaking publicly lor the lirst time since her llring Saturday. Lauelle denied in an interview that the dioxm group had been provided less than lull access to sampling data, I "That's preposterous." she said "We had our cancer assessment experts in. I had so many experts in on Missouri . .. that's preposterous I had every expert that knew anything about di- oxins in raised in that case. it was so monumen. oil and continues to be She said hundreds of samples taken in recent months were not provid- ed to the group because they "hadn't been total- ly collected One member of the dioxin Working group said Lat-'elle "just didn't want anybody here at headquarters to know about the data" taken by EPA's Kansas City regional oftice Another said top EPA officials "pist haven?t used the working group like they should." The source noted that most members of the group were not invited to a dioitin meeting in Septem- ber. when data was presented that began to reveal the mounting dimensions at the problem at Missouri horse arenas and in Imperial "They wanted to hold the data back." the ollinal said "They didn't want it leaked Forecast: cloudy; high, 55; low, 40; report on Page A2 25 CENTS i in": i i 4?31)? . ?To" Decision and Emergency Order SuSpending Registrations for the Forest, Rights-of-way. and Pasture Uses of Acid L2, 4, I . INTRODUCTION During the past ten months, the Agency has been gathering information about through its Rebuttable Presumption Against Registration process in Order to decide whether registration of this pesticide should be continued1 43 FR 17116, April 21, 1978). This review was prompted by studies showing that and/or its dioxin contaminant. caused reproductive and oncogenic effects in test animals. During the public'debate initiated by the RPAR, the Agency received reports that wOmen living in the vicinity of Alsea, Oregon, had miscarriages shortly after was Sprayed in the forest areas where they reside. The Agency investigated the circumstances surrounding these reported Current methods for manufacturing 2. 4 5- -T pro- duce TCDD as a by- product of the manufacturing process- Although 2 4, 5- -T manufacturers attempt to remove this contaminant, TCDD cannot be completely removed. An EPA contract laboratory has measured the TCDD content in 16 recently produced commercial samples of technical grade from five different manufacturers. The contractor reported that the TCDD content in these samples ranged from not detectable to of detection: 0.01 ppm) [excluding higher values that the contractor reported as doubtful]. Therefore. because TCDD is present as a low?level contaminant in commercial samples of 2,4 S-T, references in" this document to or the "pesticide product" mean that is contaminated with TCDD. -1- LCPULI. NU LCL?bUa=ll?b vI-l 0-3? I mice. Courtney and Moore reported that TCD had no effect on fetal weight or embryonic mortality at 0.5 ug/kg in CD rats, and Sparschu et al. reported no effect at 0.03 ug/kg in Sprague-Dawley rats. Dow Chemical Company, a registrant. has recently completed a study of the effects of TCDD on repro- duction in Sprague-Dawley rats exposed to low dose-levels of this chemical for three generations. The registrant concluded that "impairment of reproduction was clearly evident among rats ingesting 0.01 or 0.1 ug per day. Significant decreases were observed in fertility, litter size, gestation survival, post-natal survival, and postnatal body weight." In addition, exposure to 0.001 ug per day, the lowest level tested in this /p T- VA //;tudy. resulted in statistically significant increases in the percentage of pups dead at birth and/or dying before the end of three weeks of life in some generations.- Dow Chemical Company has claimed that the of this study are "trade segret" or "cquiggngigl." An injunction issued on April 4, 1978, in the case of Egg Chemical 22; v. Sostlg, Civil Action No. 76-10087, U.S. District Court for the Eastern District of Michigan .Northern Division), arguably precludes EPA from dis- closing the data from this study at the present time. Although the relevant provisions of FIFRA have since been amended to allow disclosure of data such as this (see, FIFRA Sections-1qcm and the injunc- tion has not yet been modified. EPA intends to request the Court to modify the injunction. but until this has been done the Agency will not publicly disclose the data from the study. The summary presented in the text of this Order does not, in EPA's opinion, constitute disclosure of the allegedly ?trade secret" data submitted by Dow and would not cause any harm to Dow's legitimate competitive interests. The data from the study may be made available to any party in a suSpension or cancellation proceeding under an appropriate protective arrangement. -26.. Althouoh the experimental protocols and strains differ for the several studies cited, in each case TCDD significantly increased the incidence of resorbed embryos or stillborn animals relative to the rate observed in control animals not exposed to TCDD. The regular occurrence of embryonic death in studies by different inveStigators in primates and in different rodent strains indicates that exposure to TCDD during mammalian gestation may result in the death of the embryos and related maternal reproductive failure. {ii} gkeletal Anomalies Skeletal defects appear in six studies involving four different mouse strains. Courtney and Moore report the following incidences of cleft palate in the indicated strains exposed to 3 ug/kg TCDD: 71% in litters of mice, compared to none in the controls; 22% in litters of mice compared to none (0/23) in the controls; and 30% (3/10) for CD-1 mice, compared to none in the controls. Neubert and Dillmann, also using 3 ug reported 29% (7/24) of the viable litters had fetuses with cleft palate for NMRI mice compared to 6% (10/160) of the control litters. Smith et al. reported cleft palate in 713 (10/14) of CF-1 mouse litters at 3 ug/kg, compared to none (0/34) in the controls. -27- . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY DME?Harch 6, 1984 Research Triangle Park, N. C. 27711 . ?1555* Analysis for 2378-TCDD in Human Adipose Tissue Samples Associated with the Five Rivers, Oregon Study (EMSL-RTP I.D. No. 2) rho" Robert Harless, Research Chemist LA Advanced Analysis Techniques Branch, (MD-67) 7? Dr. Norbert Jawarska, Director .Environmental Research Laboratory - Duluth and HQ Liaison for National Dioxin Study Eight extracts of human adipose tissue were received 3/2/84 from the ECL located in Bay St. Louis, Mississippi. The extracts were subjected to a previously described HRGC-HRMS method of analysis for quantitative determination of 237B-TCDD and TCDD isomers. A 25m SP-2340 fused silica capillary column was used for the analytical determinations. Analytical results generated for the extracts are shown in Table 1. Evaluation of pertinent data indicates: 2373-TCDD was detected in one extract (maybe QA sample?). TCDD isomers were not detected in any of the extracts. Method efficiency was adequate. With one exception (D-697), the extracts were relatively free of chlorinated contamination. Small sample size and 5 ng 13C12-TCDD fortification level prohibits achieving to 10 minimum limits of detection for D-697 extract. Trace level amounts of PCBs and other chlorinated contamination were detected in this extract. However, the contamination does not interfere with analysis for 2378-TCDD. In order to achievi 1 to 10 minimum limits of detection for a 0.1 gram sample, the 3C12- TCDD fortification level should be no more than 0.1 to 0.5 ng. All D-697 extract was used for analysis. However, 20 to 40 percent of each of the other extracts is stored for reference. Please call me if you have any questions. Attachment cc: A. Dupuy D. HcDaniels H. Dellarco J. Clements R. Lewis Fo~11704fitu Table 1 Analytical Results for 237B-TCDD in Human Adipose Tissue (Five Rivers Oregon Study) 2378-TCDD Sample 13C12-TCDD Method Efficiency Detected and Sample Weight Fortification 2 Recovery of Hinimum Limit (grams) Level (n5) 1 of Detection (ppt) D-685 10 5 98 ND (0.8) 0-686 10 5 77 ND (0.8) D-687 10 5 96 ND (1.0) D-688 10 5 94 ND (1.0) 0-697 0.088 5 96 ND (53.0) 0-698 1.43 5 90 ND (4.3) 0-699 10 5 80 ND (0.7) 0-700 10 5 92 12 (0.9) part per trillion. ND - not detected at specified detection limit. NOTE - None of the other 21-TCDD isomers were detected in these extracts at equivalent detection limits. 1 . THE UNIVERSITY OF NEBRASKA-LINCOLN NEBRASKA 66539 I . I -ho U'September 29, 1977 Ms. Pat Office of Pesticide Program NH 568 U. S. Environmental Protection Agency Washington, D. C. 20$60 Dear Pat: Enclosed is a report of.our analysis for TCDD in samples coded G?l7 through 6-60. The report contains the sample identity, the weight of sample taken for work?up, the concentration of TCDD. and the detectinn limit. Thrre are a few cozzents I would like to make on these results. 1. All data-?concentration of TCDD, detection limit, and percent recoverv~? were obtained by The conditions used for both the CC and the MS have been previously renortcd (see my letter cf August 11, 1977) except for the following. We injected the extract with the column at 250?. This temperature was held for four minutes and then increased to 305? at a rate of 25? per minute and held there for seven minutes. The retention time was 5 minutes. We made this change to decrease the ?tailing" of the TCDD peak, to separation of TCDD and the various PCB's, and to purgethe calunn of higher boiling contaminants. 2. Most of the samples were hiehlg contaminated with PCB's and DDS. This was especially true for the human adipose extracts. In fact, after complECing the normal clean?up and analyzing three ex:racts,we found we were unable to obtain low detecrion limits because of the high concentration of the contaminants. Therefore, the alumina liquid chromatography step was repeated, and the majority of the interferences were removed. The percent recoveries could be better, but the additional sample handling had a definite effect:- introduced in the work-up. re fear samples of supermarket gee! at and three samples of Nebraska soil. No unusual concentrations of PCB or DDE were found. Accordingly, the contaminants were present initially. We estimate that the amounts of PCB were 100 to 1000 times greater than normal in some of the extracts following the prescribed clean~up.' To check whether the contaminants were present initially in the sarsle or were RECEIVED F:tr?ic3 7.) . THE or NEBRASKA-LINCOLN 1-H: or: Nam-ensue. OMAHA THE umvensn?v ow meant-sum MEDICAL CENTER i r15 Oct . -27 September 29, 197? @ii 3. We found low detection limits for all the analyses except three (average detection limits excluding these three was 6 1:3 parts per trillion). 0?22 showed a large PCB interference at m/e 322. The percentrecoveryon was very low (52), and the amount of sample for 6?24 was limited. The analyses are a classic example of the detection limit exceeding the sensi? tivity of the method. Our analyses could have been done at a level lower than 1 part pen?tillionlconsidering sensitivity only. However, the detection limit was raised because of two factors: (1) the concentration of native TCDD in our spike was sufficient to detect, and (ii) a PCB interference at m/e 322 was found in most cases which ?tailed?-into the region for the exact mass of native,TCDD. 4. Please note that results for samples 6?40 and 6?49 are not reported. Various instrumental problems occurred during these runs. They will be run again along with our next batch of samples. . I 5. Sample which we reported as a positive, was worked?up again, but no internal standard could be detected. We think we forgot to spike the extract. Therefore, this sample will be analyzed once again. I hope these results are acceptable to you. Please advise us on any additional {:work that should be done with these samples. I would recommend that we repeat the analysis with those samples which showed positive. Finally, we are in need of more samples as well as additional internal standard. I would appreciate it if you would arrange a shipment in the very near future. Sincerely yours; Michael L. Gross Associate Professor HLG:sac Enclosures cc Dr. Tung Sun Dr. P. A. Lyon Mr. Dave Hilker . . Mr. Stan Wojinski Mr. Richard Reising Document provided under discbvery to plaintiff in'Merrell v. Block, et a1., USDC Oregon Civil No. delendants January 13, 1982 supplemental response to second and third requests for production, page 3, document 14.] The documenE is apparently responsive to a request for documents_relat1ng to past; 1 current, or proposed study, investigation, or.1nquiry into alleges, suspected, or confirmed human health effects associated with the use of pesticides in the area of the Siuslaw National rorest, Oregon. [plaintiff's August 31, 1981 second request for production 01 docu? ments, page - 2, SAMPLE SAMPLE ID DESCRIPTION 17 Human Adipose 18 Human Adipose 19 Human Adipose 20 Human Adipose 21 Human Adipose 22 Human Adipose 23 Human Adipose 24 Human Adipose 25 - Human Adipose 26 Human Adipose 27 Human Adipose 28 Human Adipose 29 Human Liver 30 Human Liver 31 Human Liver 32 Human Liver 33 Human Liver 34 Human Liver 35 Human Liver 36 Human Liver 37 Human Adipose 38 Human Liver 39 Human Adipose 40 Human Adipose REPORT GAS RESOLUTION MASS SPECTROMETRY ANALYSIS WEIGHT TAKEN NOON OHIO .1280 .7851 .8344 .2253 .6309 .3597 .9082 .7275 .5791 .4527 .6724 .1945 .2531 .8124 .6131 .2248 .2896 .0702 .2360 .6546 .4564 .4527 .8805 .6639 0F TCDD IN HUMAN SAMPLES PERCENT REcovnur CONCENTRATION 16.92-9122 DETECTION 11 3 30 DIN-1U LJ L-JKOMJ EOFHIENLE Low percent recovery Large PCB contaminat at m/e 322 Low percent recovery Malfunction Chromatography/High Resolution Mass Speclrometry An SAMPLE SAMPLE ID 0 DESCRIPTION 41 Human Adipose 42 Human Liver 43 Human Adipose 44 I Human Adipose 45 Human Liver 46 Human Adipose 47 Human Adipose 48 Human Liver 49 Human Liver 50 Human Liver 51 Human Adipose 52 Human Adipose 53' Human Adipose 54 Human Adipose 55 Human Adipose 56 Human Liver 57 Human Adipose 58 Human Adipose 59 Human Adipose 60 Human Adipose HEIGHT TAKEN 5.5058 3.5538 5.4404 5.6241 2.9099 3.1839 3.3663 4.3566 4.3083 3.2096 2.3975 6.0590 4 5.3701 9.4785 9.1319 2.6606 7.1199 8.2333 _a.7a15 9.7420 PERCENT RECOVERY CONCENTRATION (pptr??Suhmitted By: alysis of TCDD in Human Samples DETECTION LlpIT(nQ;gl_ ??pg?ENTs mm U?l Malfunction NOON Michael L. Gross Department of Chemistry University of Nebraska Lincoln, NE 68588 September 29, 1977 Acession 9 Title of Project: DMP Deer and Elk Study Status of Project: in progress Location of Sampling: Oregon and Washington Herbicide Use: forest Sample Media: deer and elk adipose tissue Range of Limit of Detection: RTP: 0. - 6.0 WSU: 8. 8 - 34.0 Average Limit of Detection: RTP: 2.7 WSU: 14.8 a of Samples Collected: deer: 6 elk 9 a of Samples Analyzed: 15 of Samples Suspected Positive: deer: 3 of 6, 50.0% elk: 7 of 9, 77.8% Comments: It is important to note that four samples were analyzed below 50% recovery of the 37Cl TCDD standard and therefore require re?extraction and re-analysis according to standard DMP procedures. These samples are WA-D-B, and wA-s-7. Nevertheless, the data indicate the presence of 2.3.7.8 TCDD residues in both deer and elk. Also it is important to note that RTP reported the presence of other minor isomers in addition to the major 2.3.7.8 TCDD isomer (based on the DMP analytical criteria). The result of this study indicates that additional sampling may be useful in providing more information about the extent of dioxin contamination associated with the use of and silvex in this geographic area. Dani Research Triangle Park div State University Tox icant Adipose Analysis ppu?cl Native 'ran 11:13:) Two TCDD 37c1. Sample. Center TCDD Added RTP Detected Recovery DctecEE? c-1cction {c1 Recover? Sample I to Sample I (ppt}(C} L1m1t {ppt)(c) (ppt) Lim1t (ppt) deer on-n-s 124(?) 12 2 ?89 1(9? 31 i 21 46 deer wn-Ddeer 126 no 4 34 up 34 29 deer Control deer HA-D-4 128 ND 3 36 NA deer 02-0-6 129(deer 130 7 4 31 6(9) no 24 33 Method Blank105 elk wn-E~2 132?9? 9 2 67 NA elk 03-5-elk 134(deer Control 21 135??, 34 6 so 10?:02 elk on-E?9 137(8) 5 3 100+ 12?9? no a 98 elk HA-E-S 133 12 3 57 13(9) no 19 43 elk 139?9) 4 1 87 14(9) an 10 84 Standard 14 140 21 2 100+ 15 12 11 76 Solution?b} wk?n~4 141?e? 21 2 76 16?9? 21 '11 70 411k 142 no 4 36 17?91 ND 25 32 to] If) (9) ND: 11A: N8: nethod Blank: extraction procedure using solvent only. Standard Solution: a standard solution containing ppt: parts per trillion corrected for recovery 1055 two other isomers in addition to 2, 3, 7, 8? tetrachloroigibenzo-p-dioxlfn the major isomer?uere observed HSU analyses reported here are the average of two runs evidence of PCB contamination in sample Not Detected not analyzed by HSU due to limited amount of sample Sample wt. for all samples was 59. 3 37Gb TCDD addition to each sample is 5 nanograms (n9) except Control Sample -10 which contained 1.33 ng. ?in 514, (A 0 4? [35) ?$3st ?3 HEALTH I CTS LnnoriATL-Hv ?4 RESEARCH l?r'iF'lK 27TH DATE: December l7, l979 SUBJECT: Results of Capillary Column Analyses Performed on Extracts of Deer and Elk Adipose Tissue for Residues FROM: Robert Harless 241%?? HERL, ETD, ACB (MD-69) TD: Mike Dellarco, Dioxin Project Manager Special Pesticide Review Division Office of Toxic Substances 40l Street, SM US EPA Washington, DC 20460 THRU: Dr. R. G. Lewis, Chief Analytical Chemistry Branch MD-69) HERL, ETD Per your request, these samples were not analyzed until the most high priority samples. "Vertac", etc. were analyzed. This shipment of sample extracts was received from the EPA Pesticide Monitoring Laboratory, Bay-St. Louis, Mississippi, 9-6?79, and was assigned the identification number The sample extracts were subjected to a previously described capillary column multiple ion monitoring method of analysis for residues utilizing a Varian 3llA mass spectrometer interfaced with an SE-30 NCOT glass capillary column. The criteria utilized for confirmation of were: 1. Capillary column retention time of 2.3.7.8-TCDD. 2. Co-injeccion of sample fortified with37Cl-TCDD and 2.3.7.8- TCDD standard. 3. Molecular ion chlorine isotope ratio (m/e'szo and m/e 322). 4. Capillary column simultaneous multiple ion monitor- ing response (m/e 320, m/e 322, and m/e 328) for TCDDresponse greater than 2.5 mm noise level. \lThe capi11ary co1umn retention time of 2.3.7.8-TCDD was 15 min- utes :_15 seconds. The MS mass reso1ution (8,500) was sufficient to reso1ve TCDD from contamination. The masses monitored during these ana1yses were: 1. m/e 318.9793 PFK reference 2. m/e 319.8965 TCDD 3. m/e 321.8935 TCDD 4. m/e 327.8847 37c1-Tcoo Resu1ts The resu1ts are shown in Tab1e 1. The recovery of 3YC1-TCDD was be1ow 50% for specific samp1e extracts. Therefore, the resu1ts shou1d not be reported. _These specific samp1es shou1d be subjected to anaTytica] c1ean-up and ana1ysis again to confirm the reported resuTts. TCDD isomers (3) were detected in RTP-124, 129, 132, 134, 135, 137, 139, and 141. The isomer having exact retention time as 2.3.7.8- TCDD was the major isomer detected (high concentration). No prob1ems were encountered in these ana1yses. Summer! 2.3.7.8-TCDD and two (2) TCDD isomers were detected in deer and e1k adipose tissue samp1es. CC: Dr. Wi11iam Durham, Director Env1ronmenta1 Toxico1ogy Division Dr. Nancy wi1son, Chief Chem1ca1 Characterization Section (MD-69) TABLE ACB #l08 ANALYTICAL RESULTS FOR 2.3.7.8-TCDD RESIDUES Sample 37 TCDD TCDD Sample Height Fortification Detection Detected ID Level (n9) 1 Recovery Limit (gpt[* {opt} Comments 5 5 89 2 -l2 Deer Adipose RlP-l27 Elk Adipose RIP-135 - 5 1.100100not detected parts per trillion corrected for recoveny 105585 0-5954. 7 Wisgne ewe-e UFEVGEQ -m-v-wpr - v: ?In. Dayton. Ohio 45431 November 29. 1979 Mr. H. T. Hollaway . U.S. Environmental Protection Agency - Office of Toxic Substances 1 I Special Pesticide Review Div. Hall #2 gg-l 1921 Jefferson Davis Highway, Rm. 728 Ema-new-..? Nee/i Arlington, Virginia 22202 Dear Mr. Hollaway: Attached is a table showing the results of analyses of the remaining samples in the batch of l7 which we have been analyzing. Results for the first nine samples were reported in our recent Quarterly Report. We are proceeding as rapidly as possible with the MS-3D modifications to permit isomer-specific TCDD determina- tions, and will provide you with a status report on those develop- ments in the near future. Sincerely, Wig?r Thomas O. Tiernan, Professor of Chemistry and Director of the Brehm Laboratory Attachment TABLE 1 . . . RESULTS OF GC-HIGH RESOLUTION ns ANALYSES OF SAMPLE PROVIDED BY EPA . . FOR (TCDD) BY WRIGHT STATE UNIVERSITY Run Run 2 EPA Native TCDD Detected Native TCDD Detected Average Average Sample (parts-per-trillion) (parts-per?trillion) TCDD M.D.C. m/e 320 m/e 322 Average m/e 320 m/e 322 Average __jpp?l_ _1ppgl_ Recoverg HSU-HSU-PCB contamination of sample is evident. b. This sample was supposedly spiked with only 1.33 ng total The indicated recovery however indicates a possible error in spiking. QUANTITATICH 0F LEVELS OF IR EPA FURNISHED EXTRACTS OF BIOLOGICAL MATERIALS EPA Cooperative Agreement No. Submitted by Brehm Laboratory Wright State University Dayton. Ohio 45435 Thomas 0. Tiernan, Joseph G. Solch. Garrett VanNess. Michael L. Taylor, and Thomas Mazer Quarterly Report September 23. 1979 Submitted to'- William T. Hollaway Coordinator --Dioxin Implementation Plan U.S. Environmental Protection Agency 'Office of Toxic Substances Special Pesticide Review Division (TS-791) Mall #2 192l Jefferson Davis Highway. Rm. 728 Arlington. Virginia 22202 .45 I. INTRODUCTION Analyses of EPA-furnished extracts of deer and elk adipose for tetra- chlorodibenzo-p-dioxin content were accomplished by Wright State University during the third quarter of the program being conducted under EPA Coopera- tive Agreement No. Results of these analyses are reported herein and other pertinent topics are discussed. II. EXPERIMENTAL PROCEDURES The experimental procedures applied for the analyses reported herein are essentially the same as those described previously in the Quarterly Report of March 23, l979. RESULTS AND CONCLUSION The results of analyses of nine extracts of deer and elk adipose are listed in Table 1. Since these extracts were based on five gram samples, whereas the Coonerative Agreement specified that ten gram samples would be extracted by EPA. it was not possible to achieve the specified detection sensitivity for TCDD. However, the minimum.detectable TCDD levels in most of the samples are quite reasonable. being 13 parts-per-trillion (ppt) or less for five of the nine samples. In all cases where higher detection limits were imposed. the recoveries. based on the internal standard. were extremely poor. It is noteworthy that recoveries were less than 50% for four of the nine samples, and were in the acceptable range for only three samples. This suggests that the EPA extraction and cleanup methodology is not really adequate for these types of samples. and that improvements are desirable. Three of the nine samples analyzed exhibited very large /0 6 -apparent biphenyl (PCB) interferences. and the recoveries for these samples were the lowest observed in this set. as shown in Table 1. IV. PROJECT STATUS AHD PLANS In order to be consistent with the Cooperative Agreement schedule. Hright State would have been required to analyze twenty-one (2l) sample . extracts during the present third quarter reporting period. As noted in the previous Quarterly Report submitted to EPA. Wright State analyzed nine (9) samples in excess of the requirements during the previous quarter, which reduces the nonnal sample analysis load (30 samples/quarter) to twenty- one (21). as just mentioned. However. EPA supplied Wright State with only seventeen (l7) sample extracts during the present reporting period, and these were not received until September 20, 1979, only three days before the end of the third quarter of the Cooperative Agreement. In view of this 1 late shipment of samples, it was not possible to complete analyses of all seventeen (l7) extracts prior to the end of the reporting period. Analyses of nine of the seventeen were completed and are reported herein. as noted above. It must be emphasized that EPA has not provided Wright State with the numbers of samples specified in the Cooperative Agreement for the present quarter. and that the sample shipment which was made was not timely. It is urged that attempts be made to rectify this situation in the coming quarter. and that the appropriate number of samples be shipped as soon as possible. wright State should receive a minimum of thirty-four samples from EPA for analyses during the fourth quarter (prior to December 23. 1979) in order to satisfy the projected schedule. During this reporting period. authorization was received from EPA (letter of September 13. 1979 from w. T. Holloway) to accomplish an internal budget-transfer of funds for the Cooperative Agreement. Accord- ingly. $8000 was transferred from the equipment line to the supply line of expenditures for the Agreement. as authorized. Also during this reporting period, Dr. T. 0. Tiernan attended the National Meeting of the American Chemical Society in Washington. 0.0., where he participated in a Symposium on the Chemistry of Chlorinated Dibenzodioxins and Dibenzofurans. Dr. Tiernan also visited Hr. Hollaway and Mr. DeLarco, at their EPA offices during this trip. to discuss the status of the Copperative Agreement and future plans. In the course of these discussions, Dr. Tiernan reviewed some recent data obtained by Wright State. relevant to the detection of TCDD in combustion samples. Preliminary data showing separation and determination of TCDD isomers using capillary- column gas chromatography in conjunction with low-resolution mass spectro? metry were presented by Dr. Tiernan. and the detection of TCDD in fireplace soot by Wright State was noted. Dr. Tiernan further emphasized the desir- ability of proceeding with the proposed modifications to our Mass Spectrometer to incorporate capillary-column EC, in view of these findings and the reports by Dow Chemical of T000 in combustion samples. 12 EPA Sample No. (deer adipose) HSU-Z (deer adipose) wsu-aa' (deer adipose) HSU-4 (deer adipose) NSU-S (deer adipose) usu-sa' Run 1 Native TCDD Detected m/e 320 m/e 322 Average 30 14 14 (deer adipose) USU-7 (deer adipose) HSU-B (e1k adipose) HSU-9 (eik adiposeRESULTS OF GC-HIGH RESOLUTION MS ANALYSES 0F EPA-SUPPLIED SAMPLE EXTRACTS BY WRIGHT STATE UNIVERSITY TABLE 1 Run 2 Native TCDD Detected 46 14 16 65 a. PCB contamination of sampies is evident. Ell. 21' 13 14 70 m/e 320 m/e 322 Average 34 14 15 68 Average Native TCDD 31 14 14 68 Average Minimum Detectabie Average Concentration 3 Recoverx UNITED STATES ENVIRONMENTAL PROTECTION AGENCY b? DATE: September 6, 1979 Decoding of Sample Extracts Shipped to and Univ. of Nebraska for TCDD Analysis on 9/5/79 Aubry E. Dupuy, Jr., Chemist FROM: . . . . Pestic1des Monitoring Laboratory Michael Dellarco OBJECT: TO: I. Samples Shipped to RTP uh mple Shipment Sample Sample Fortification Level Number Description Wt.(g) _?ppt native TCDD) Region deer adipose OR-D-S 5 5 5 - 5 RTP-126 5 - 5 Control deer adipose 5 7 5 Region deer adipose Method blank 5 - 5 RTP-132 Region elk adipose WA-E-Z 4 - 4 RTP-133 - 5 - 5 RTP-134 5 - 5 Control deer adipose 5 21 1.33 Region elk adipose 5 - 5 0R-EOR-E-B 5 - 5 Standard solution 5 14 5 Region elk adipose 5 - 5 RIP-142 5 - 5 FROM TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY September 21. 1979 In I 'r Decoding of Sample Extracts Shipped to Wright {a State University for TCDD Analysis on 9/19/79 - 1 l' I Aubry E. Dupuy, Jr., Chemist M?s/4, i 4. [978- 1/ Pesticides Monitoring Laboratory iin Michael Dellarco Please refer to the memo decoding the RIP shipment that I sent to you on September 6, 1979. The RIP equivalent numbers (split samples) are as follows: Sample Shipment Number Shipment Number Equivalent (Wright State Univ.) (RTP) WSU-Z RTP-IZS WSU-B RIP-126 USU-5 RTP-129 USU-6 USU-7 RTP-131 RTP-133 RTP-135 RTP-136 USU-13 RTP-139 USU-16 RTP-141 RIP-142 Due to limited sample material, samples (deer adipose and sample RTP-132 (elk adipose WA-E-Z) was sent to only. cc: Dr. Han Tai, Manager Pesticides Monitoring Laboratory ?20-6 (Rn. 3-76) I I 15 Rationale and Study Design for Proposed TCDD Analysis of Region Elk and Deer Adipose Tissue samples. 1. Reasons why such a study is needed: A. Because of so many variables, mother's milk TCDD levels alone do not provide much valuable information about TCDD in the environment. Utilizing human subjects presents great diversity in terms of diet, mobility in the environment, medication. and exposure history. Because of the nature of the TCDD molecule, it should be more concentrated in adipose tissue than elsewhere. Milk with its butterfat content would thus not be an unreasonable sample type, but adipose tissue would be much better. The difficulties of obtaining adipose biopsies from a selected population of humans are obvious. A TCDD monitoring study of carefully selected samples of elk and deer will provide the following advantages: Elk and deer live in discrete forest areas all of their lives. The herds are closely monitored by professional wildlife biologists. Exposure information from past spraying histories of the areas can be obtained. This localized nature of the herds enhances research design. Elk and deer are browsers and grazers, eating only vegetation from the forest areas they inhabit. Their diet thus reflects their environment (in terms of residues of any environmental contaminants) far more accurately than does a typical diet of an ?exposed" human. Elk and deer are consumed by large numbers of people. Knowledge of possible contaminants in these animals is thus of public health importance. In California, State agencies have interpreted the precautions on the label to apply to both deer (California does not have appreciable elk poPulations) and livestock. The state thus opposes spraying 2 weeks prior to and during the deer season. Elk and deer herds in Region coastal forests often consist of sufficient quantities of older animals to allow for sampling them preferentially as indicators of any bioaccumulation in an 'exposed? environment over a several year timeframe. As explained later, several of our elk samples are from animals in the 10 to 13 year age class. B. were labeled as to: species, date sampled. sex. age, site and date of kill, name, address and telephone of donating hunter, name, address and telephone of biologist making the collection, and miscellaneous comments by the sampling officer. They were then frozen and taken to a central site where they were then picked up by EPA Region X. Labels were made of paper and affixed to the bottles with strong twine. Colecting dates were as follow: Oregon deer, 11-5-77; Oregon elk, 12-3-77; Washington deer, 10-22 and 10-23?77; and Washington elk, 10-31?77 through 11-21-77. At present, the samples are stored frozen at the EPA Region Laboratory in Seattle. They are labelled and sealed since their collection, and can be shipped at once whenever a suitable analytical laboratory can be found and utilized. Sample data are as follow: Oregon elk totalled 15. All of these animals were taken from the Coos Bay to Rosenburg area. Specifically, all of the animals came from the Millacoma and Coos River drainages, stretching across predominantly Weyerhaeuser land eastward from the vicinity of Allegany. The elk herd is monitored closely by game biologists. and has been experiencing an excess of reproductive problems, including stillborns and teratisms during recent years. Ages range from 2 to 13 years (mean: 7.5 years). Mean size of fat sample is 43.5 grams. All are female, because only cows are sacrificed and studied from this herd annually by the game biologists. Oregon deer totalled 10. All were taken from hunters at check stations in the Tillamook area. Age ranged from 1.5 to 5.0 years (mean: 2.8 years]. Mean size of fat sample is 58.8 grams. Seven males and three females were sampled. Washington deer totalled 9. They were taken in the general area stretching from Aberdeen toward the Pacific Coast. Mean sample size was 22.3 grams. Ages ranged from 0.5 to 5 years (mean: 1.9 years). Seven males and two females were sampled. Region began this study in the Fall of 1977 as a corollary to the mother's milk sampling study for TCDD, for reasons already outlined at the beginning of this paper. We have informed OSPR of this effort since its inception and have requested assistance numerous times in the analysis of the samples for TCDD. chiefly through Mr. Raising of OSPR. We have received no response whatsoever from DSPR. Fina1 Report for Cooperative Agreement No. CR-806847. "U1tratrace Ana1ysis of Tetrach1orodibenzodioxin (TCDD) in Environmenta1 Samp1es" by the University of Nebraska-Lincoln and the U.S. Environmenta] Protection Agency. June 24, 1983 BZ E?u Val U??hl? 3331i .., I :1 r! . 20 gable II. Analysis of Extracts of Human Milk for TCDD: Real Samples. Sample Sample Conc Det Isotope Data Txpe Spike (Ppt) limit Recoverg_ Ratio Report 1?11 45 1-11 45 65 1-11 70 1?11 75 1?11 70 1?11 55 1?11 2-II 55 1-II 45 1?11 45 . 45 2-II 4o 3?x 50 1-11 45 1-II 30 1-11 50 1?11 45 1-11 50 1-11 55 1-11 60 1-.82 3-XI 7D 2-IB MILK 10 - MMG-1 MILK 10 ND MMG-I MILK 10 ND MILK 10 ND MILK 10 ND MMG-4 MILK 1o 12 MMG-S MILK 10 ND MILK 10 ND MMG-7 MILK 10 ND MILK 10 ND MMG-9 MILK 10 ND . 10 ND MMG-11 MILK 10 ND MILK 10 11 MILK 2.5 10 MILK 10 ND MMG-14 MILK 10 ND MMG-15 MILK 10 ND MMG-Is MILK 10 2.5 MMG-Is MILK 2.5 ND MILK 10 MILK 10 ND MILK 1n MILK 10 MMG-20 MILK 10 MILK 1o MILK 10 MMG-23 MILK 10 MILK 10 MILK lD MMG-27 MILK 10 MILK 1o MMG-29 MILK 10 MILK 10 MMG-31 MILK 10 MMG-32 MILK 10 . MILK - MMG-33 MILK 1o MMG-34 MILK 10 HMS-34 MILK . MILK 1o MMG-35 MILK 10 ND MILK 10 ND MILK 10 11 MILK 3.5 MILK 2.5 MMG-39 MILK 2.5 ND MILK - 2.5 I Ho Lu) I 70 2-IB MMG-42 MMG-42 MMG-43 MMG-44 MMG-46 MMG-47 MMG-48 MMG-49 MMG-50 MMG-50 MMG-50 MMG-52 MMG-52 MMG-53 MMG-54 MMG-SS MMG-SS MMG-56 MMG-57 MMG-SB HMS-59 MMG-59 MMG-59 MMG-59 MMG-60 MMG-62 MMG-63 MMG-64 MMG-65 MMG-66 MMG-67 MMG-SB MMG-69 MMG-69 HMS-70. MMG-72 MMG-72 MMG-73 MMG-74 MMG-75 MMG-76 MMG-77 MMG-77 MMG-7B MMG-79 MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK wam4-II 2-IB 2-IB Z-IVA 2-IVA 2-IVA 2-IVA 3-K 2-IVA 3-K 2-IVA HMS-B3 Mme-34 ENG-85 MMG-BS MMs?as MMG-87 MMG-BB MMG-BQ HMS-90 MMG-91 MMG-92 MMG-93 MMG-93 MMG-94 HMS-97 HMS-101 HMS-103 HHS-108 MMG-104 Mus-105 MMG-106 MMG-IOE MMG-106 HMS-108- MEG-110 HMS-110 MEG-111 HMS-112 ENG-112 HMS-113 HMS-113 HMS-114 HMS-114 ENG-115 MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK MILK GOOD ocacnMD.ND .5...80 ,..85 .84 .83 .81 .81 2-IVA 2-IVA 3?x 3-x 2-IVA 3-VIA 3-VIA 3-VIA 3-VIA 3-VIB 3-VIA 3-VIB 3-VIA 34VI8 3-VIA 3-VIA 3-VIA 3-VIA 3-VIA 3-VIB 3-VIA 3-VIA 3-VIA 3-VIA 3-VIB 3-VIIA 3-VIIA 3-VIIA 3-VIIB 3-VIIA 3-VIIB 3-VIIA 3-VIIB- 3-VIIA 3-VIIA 3-VIIB 3-VIIA MMG-116 MILK 2.5 ND 1 45 3-VIIA MMG-117 MILK 2.5 ND .7 40 MMG-118 MILK 2.5 1.4 .6 40 MMG-118 MILK ND 1 - Mme-119 MILK 2.5 ND .7 40 3-VIIA MMG-120 MILK 2.5 3.3 .6 45 MILK 2.4 .3 I .80 3-VII8 MILK 2.5 ND .6 50 MMG-122 MILK 2.5 ND 1.1 35 3-VIIA MILK 2.5 ND .9 55 3-VIIA MMG-124 MILK 2.5 ND 1 55 MMG-125 MILK 2.5 .89 .5 60 . 3-VIIA MMG-125 MILK .50 .2 .94 MMG-125 MILK 1.5 .8 .75 3-VIIB MILK 2.0 .5 .69 MILK .6 .1 .84 MILK 235 1.3 .6 50 MILK 2.5 ND .7 60 MILK 2.5 ND .8 60 MMG-129 MILK 2.5 2.9 .7 70 MILK 3.6 .3 .79 MMG-130 MILK 2.5 ND .4 55 MMG-131 MILK 2.5 ND .5 65 MILK ND .5 - MMG-132 MILK 2.5 ND .4 70 MMG-132 MILK ND 1 MMG-133 MILK 2.5 ND .7 60 MILK 2.5 ND .5 70 MMG-135 MILK 2.5 ND .7 60 MMG-136 MILK 2.5 ND .6 65 MMG-137 MILK 2.5 .6 .6 85 - MMG-137 MILK ND 1 3-IXB MMG-138 MILK 2.5 ND .9 70 3-IXA MMG-139 MILK 2.5 ND .9 85 . 3-IXA MMG-140 MILK 2.5 ND 1 65 MMG-141 MILK 2.5 ND 1 85 3-IXA MMG-142 MILK 2.5 ND 1 45 3-IXA MMG-143 MILK 2.5 ND 1 90 . 3-IXA MILK 2.5 1.0 .8 75 MILK 1.0 .4 .73 3-IXB MMG-14s MILK 2.5 ND 1 85 MILK 2.5 .7 .7 90 3-IXA MMG-146 MILK ND .5 - 3?Ix8 MILK 2.5 1.2 1 85 MILK 1.3 .6 .81 3?Ix8 MILK 2.5 IND .B 70 3-IXA MMG-149 2.5 ND .7 100 3-IXA MMG?lso MILK 2.5 ND 1 65 3-I MMG-151 MILK 2.5 3 2 40 4?1 MMG?lsz MILK 2.5 130 20 45 4-1 MILK 2.5 48 6 55 4-1 MMG-154 MILK 2.5 ND 1 60 4-1 MILK 2.5 4 2 50 4-1 MMG-156 MILK 2.5 12 6 60 4-1 mas-157 HMS-158 ans-159 Huh-Lu 60 50 60 huh-sh . 25 gable Analysis of Water and Sediment for TCDD (Alsea, Oregon Study Phase Sample Sample Conc Det Isotope Data N3. Type Spik (223) limit Recovegy Ratio .Report I .067 .02 75 2-IVB .027 .005 65 3-Iv .76 .04 85 .092 .01 '90 .023 .009 45 3-IV .067 .03 80 .041 .03 50 ND .008 55 - .061 ..040 .03 65 ND .007 55 ND .04 60 2-IVB .070 .3-3-Iv SEDIMENT 1.9 .2 .78 3-V UN-16 SEDIMENT 5.9 3 105 3-I UN-16 SEDIMENT ND 1.5 3-v UN-16 SEDIMENT ND .7 - SEDIMENT 19 9 80 3-1 UN-17 SEDIMENT 2.3 .5 .83 3?v UN-18 SEDIMENT ND 11 60 UN-19 WATER .061 .03 70 3-II WATER ND .02 120 3-II WATER ND .04 70 3-II UN-22 WATER .083 .02 90 3-II UN-23 WATER .065 .03 60 WATER 0081 ".005 60 WATER ND .05 80 UN-253 WATER .11 .04 60 UN-25 WATER .011 .009 50 3-IV WATER .081 .06 45 UN-26 WATER ND .004 55 WATER ND .07 45 UN-28 WATER ND .07 40 UN-29 WATER ND .08 40 3?11 WATER .17 .03 70 UN-31 WATER ND .08 45 UN-32 SEDIMENT ND 9 70 3-I UN-32 SEDIMENT ND .4 65 3?Iv UN-33 SEDIMENT ND 4 85 SEDIMENT ND 4 90 WATER WATER WATER WATER WATER WATER WATER WATER WATER WATER WATER WATER WATER WATER 11 WATER 12 WATER UN 13 SEDIMENT SEDIMENT SEDIMENT SEDIMENT SEDIMENT a?aa?gs?ssaa I I no. I Egg ND 14 35 SEDIMENT 2.5 3-1 SEDIMENT 2.5 22 5 35 SEDIMENT 2.5 ND 13 70 3?1 SEDIMENT 2.5 ND 9 75 3?1 SEDIMENT 2.5 38 4 35 3-1 SEDIMENT 11.1 .7 .80 3-v SEDIMENT 2.5 21 3 55 3-I SEDIMENT 2.5 34 16 35 SEDIMENT 11.7 1.6 .63. 3-v SEDIMENT 2.5 20 12 25 3-1 SEDIMENT 4.4 .5 .83 3-v SEDIMENT 2.5 ND 1.8 20 3?111 SEDIMENT 2.5 1.3 .4 60 SEDIMENT 2.5 ND 12 60 SEDIMENT 2.5 ND .9 45 SEDIMENT 2.5 3.6 1.2 50 SEDIMENT 3.6 .4 .86 3?v SEDIMENT 2.5 4.4 1.4 40 SEDIMENT 5.8 .6 .78 3?v SEDIMENT 2.5 ND .9 60 SEDIMENT 2.5 ND .8 60 WATER 2.5 ND .03 65 9 WATER 2.5 ND .06 80 9 WATER 2.5 ND .07 55 9 WATER 2.5 .08 .03 100 9 WATER 2.5 ND .10 75 9 SEDIMENT 2SEDIMENT 2.5 24 13 55 9 SEDIHENT 2.5 7 3 70 9 SEDIMENT 2SEDIMENT 2.5 7 4 35 9 SEDIMENT 2.5 7 2 50 9 SEDIMENT 2.5 5 2 45 9 SEDIMENT 2.5 ND 2 55 9 SEDIMENT 2.5 9 4 80 9 SEDIMENT 2.5 58 5 75 9 ??11 05:; H- 31 Epeble VII. Analysis of TCDD in Biological and Environmental Samples ("Alsea, Oregon Phase II Project"). Sample LDBLANK UN BLANK 166 167 168 169 170 171 172 173 185 185 186 187A 533353333333 187A 5 5 555555355535 188A BLANK BLANK 188A 353 UN 188A .191199 33533333 Sample Type SEDIMENT SEDIMENT SEDIMENT SEDIMENT SEDIMENT SEDIMENT SEDIMENT SEDIMENT SEDIMENT SEDIMENT SEDIMENT SLUDGE SOLVENT SOLVENT SLUDGE SLUDGE SLUDGE SLUDGE SLUDGE SLUDGE WATER WATER WATER FILTER WATER FILTER CAT LIVER PRODUCTS OF CONCEPTION PRODUCTS OF CONCEPTION PRODUCTS OF CONCEPTION SOLVENT CHARCOAL PRODUCTS OF CONCEPTION PRODUCTS OF CONCEPTION MOUSE SHREW MOUSE MOUSE MOUSE MOUSE MOUSE SHREW SHREW SHREW SHREW Conc Isotope Spike (ppt) limit Recovery Ratio 2.05 ND 19 30 2.05 120 15 40 3 2.1.63 - - 680 2.1..78 5800 .79 .25 2..39 1.85 ND 15 50 2.05 ND 19 50 Extracted only. Analyzed elsewhere. 2.0 3 2 50 10.0 ND 12 50 10.0 ND 12 20 .- 1 Extracted only. Analyzed elsewhereExtracted only.' Analyzed elsewhere2.45 ND 3 55 Extracted only. Analyzed elsewhere. 2.5 ND 8 30 2.Data Report 10-IV 10-V 10-IV 10-V 10-IV 10-V 10-V 10-V 10-IV 10-IV 10-V 10-V 10-V 10-V 10-V 10-V 10-V 10-VI 10-II 10-II 12-1 10-11 10-II 12-1 10?1 10-1 12-11 10-1 10-1 10?1_- 12-11 10-1 10-1 10?1 gm: UN UN UN BLANK BLANK BLANK 199 199 200 201 202 202 203 001 002 003 203 204 BLANK BLANK BLANK UN UN 204 204 SHREW SHREW BIRD HOUSE BIRD BIRD MOUSE SOLVENT SOLVENT SOLVENT MOUSE NEWTS SOLVENT SOLVENT SOLVENT NEWTS NEWTS Ext NH I Extracted 2.5 2.4 2.4 2 5 Extracted onlyted only. ND onlyAnalyzed elsewhere. 3 30 Analyzed elsewherenalyzed elsewhere. 10-1 10-1 10-1 12-I 12-1 /0 I453 I'?niita'. -. . Regional AgriculturaigForoet WeeklyPage; 'h Price: :0 Cents Look (it ?highly PARC By CLAUDE f?uirimi Fir-u SALEM, lu'c "he Posti- cirie nautical Itesc'lrch if'hliCi has rejected a "retrospective type of study" of the prslir'itle piuhlcm in waste! counties of ?region as outlined in a report made by the US. Center to" Disease Control. Atlanta. Ga in a (?h-tiige of direction. PARC d-?cided to study a proposal in be made by Oregon State University on the effect of the [maticide 2.- "Jun highly exrmsed peo-l? pie in Eastern Oregon and the Willamette Vallty." That proposal is due at the next meeting of the gown. Jan. 30. at which time they will also consider a report of pesticide studies made by Dr. James Googin of the Univer- sity of Orcson Health Sciences Center. Portland. Maria (lillam. F'uiene. of the Norlliwrst Coalit'on for M- tr-rnatIvr-a to t?cstir-dcs. sug- gested PARC study "the rise and distribution of the bse of chemicals in Oregon.? . The ?action .came after a morning of technical discus- sion on pesticides by a group of is scientists last Thursday at the Oregon Department of Agriculture. under direction of Bill Kosesan. administrator of the department plant division and chairman of PARC. - Warren of the De- partrneut of Elwironincnial Quality. mode the original mo- tion. He said he did so "after iookin? at all the data in the CDC report" and 1with the hope something could be going from the center before the summer applications of pesticides. Edmunds. epidemiolo- gist With the disease control center'at Atlanta. said the SALEM. OREGON 'k FRIDAY. DECEMBER 12. I980 pesticide study be outlined would require 31001100 in fund- ing from the state of Oregon. He. said the CDC is not a fund- ing group. the U.S. Environ- mental Protection A go 37 would not contribute, but the LLS. Forest Service could have some funds. Edmunds esti- mated total cost of the pro- study at $132.00". said birth defects among children born in Ore- gon runs lower than the na- tional average but two coun- ties have defects significantly - higher than the U.S. average. pilot study by the Atlanta CDC was done in Lincoln. lien- ton and Polk counties on use of 2.t-D in primarily forested areas. Based on the ?rcnon rate of central nervous sys- tem birth defects from the Birth Defects Monitoring Pro- -nram data. it was estimated 264 cases could be located and interviewed in Western Ore- goo. Specifically. the study de- sign rejected by PARC was retrospectin a case-control study. personal interviews would be conducted of 26-1 central ner- vous system cases and 2M controls to evaluate various maternal and paternal risk factors. With adequate staff. the work could have been completed in nine to 18 months. The report states that a re- liable. lmblased estimate of . exposure to 2.4-D- would be . needed for both cases and con- trols. Because birth defects are rare events. it would be difficult to obtain enough oases for a study With sufficient statistical power. other than in a retrospective study. Edmunds said the CDC re- port is "only an outline of an approach to the problem." During the discussion. he said the proposed further study has some advantages but there may be more disadvantages and them is no need to make a study for the sake of a study. Mike Newton. professor of forest ecology at OSU, eon- 'm "that the CDC pilot may hypo-'3" thesis blaming in coastal county birth defect problems is erroneous. He said use of 2.1D is a national problem and in many farming areas the use is much greater than in the timberod coastal community. He cited widespread roadside need and brush use of Eat-D and other herbicirirs. Newton qtmiinncd the incidence of coastal do~ is extraordinary and said birth defects in the region may be due to other causes such as high phosphate levels in suits and excessive rules of mercury and copri'r in water -'5uppiies at thu- coast. He said a study of residents in urban areas at the coast -- well removed from timber showed that 17 percent of the population had high residues of 2.4-0 in tin-1r Urine. study. if it is positive. 1would show but Urey would be subject to other vari- able causes than herbicides. We don?t imow what causes de- fects. There is only a 50 per- cent chance of picking up herbicide effects With a study." said Newton. He said there is a 10.000404 safety factor in herbicide ap- plications. "Drugs. alcohol. etc.. show birth defects in users. such confounding fac- tors are large and will confuse the study." Newton continued. Gillam said "lots of citizens merit; proposed . . . shifts. Study emphasis are angry" about 2.4-0 appli- cations and warned that "soon- er or later you must look at. use of herbicides." James Witt. agricultural Ex- tension spemalist 1n chemis- try. OSU. proposed looking at positive controls for birth de- fects due to 2.4-D. Virgil Freed. head of the agricultural chemistry depart- ment at OSU. called for a stu of possible defects among husbands and. Wives who have used pesticides on family farms in Morrow and Umaiilla counties. for many continuous years. Dr. Stringham. family phy- sician in Lincoln County. sug- gested both fathers and moth- ers should be studies for birth defects. The Pesticide Analytical lic- search Center consists of rcp- resentatives from the state de- partments of Agriculture. Health Division. Environmen- tal Quality. Forestry and Fish 8.- Game. One member from the public at large is appoint- ed by the ?governor. Volume 53, illuuiznr . ,7891?07'71272633?3?? (.0 [37:19.0 3'34 Defoe: ?nancephaly 45 Hydrocephaly 65 Sgina Bifida 55 C38 :35 Calf: 11.1 325 P1late 329 'lStul? 375 tectal Acresia 393 :enal Agenesis 450 .eduction Deformity 483 0335 626 Eirzhs in BDMP 30:1:ored significant increases Benton $4144 .0 . (357 CD .591?? gin-3?11 Oregon, 1970-1978 _Coun Lincoln ?u Benton. Polk No. N02. No Cases Rate Cases ?{Rate Cases 2 15.3 9i 9.11.0 -- r. 303.3 1,307 9,123 1,051 1002 1002 anencephaiy (observed 8, expect Total CNS (observed 23, expecte Lane ?,hydrocepha1y (observed 16, expe cleft lip (observed-23, expecte reduction deformity (observed 16, expected 7.3) n. 4 I v4.1.3? Total Lincoln, Benton, Polk, Lane Lane Cou?ties No. No. Cases Rate Cases Race 12 4.6 23 6.2 l? 6.18.6 79 21.2 23 8.9 28 7.5 33 12.8* 41 1110.4 31 8.3 25,860 37,341 89% ed .05 16.68) .05 cted 9.9) .05 11.6) a .01 .33 a f1-4y15:: 70-77 All Oregon No155 8.9 8.1 174,659 7,903,544 652 33 Volume 24 Number I6 INTERNATIONAL MEDICAL NEWS Aunml 3. 1983 Herbicide DIspuIe Ignites Tranquil Oregon County av ROI-I well known II have In New Yotk In; the county . loud the Iot- THE summon It Lincoln oI TimeI Beach in the but?: in em the Count Range. A major concern County. Otegon menu to tepreIent Lincoln County II heady taken on nI- iuhigheI- ~Ihnn- -nurtnIl me of neuntl- -Iube the mhetype of bucolic I my- tionII IigniI'IcIInce and hes national IneneephIIy uni! hy- ged coutline of whitewuhed tube beyondthe thebmden of Ihil among newborn Ic- petched on above the Pucil'tc Ocean. ?e??llphic Inca. cord-n3 to the Centerl fut DiIeuc Control which crashes union the rock below; The Iptuytng only have caused II num- in InulI towns with gulleties. gift shops. her of health problem. for the people I both deleI'II diviIion eonIbIncI seafood tesuutants. nnd'I IIid- back liIe- neutnl tube net1h: lofty backdyop 0? 1h; foreshcou. "Iii-1 1? 1? ?lth VOUI In eted Paci?c Coast Range. containing II #:qu . 351?. ?1:1 tIcI. Totals noted both Iew hidden where people raise 1? 1 County and neurby Benton County. where nuns and livestock and want to be Iett gang ?holy 91$ . th .ty. many people on the coast and In the Count alone. Elf-1111:3111 I. 11hr ?.1111? Range no lot then medIcII cute 'Ihe Ii;- .. . . . Mi 'limwi?I?? "l?nrl . ?it1 . 29I- both]: The eoItItIItuuctIthouIIndI of mum? "is I three I13 we per 4.3 . each yeIIt. It element of its econonnc 11.145}: ii? one I4 I one). weII- ntoItIIn- . one one CNS. not othetwne Industry. The create the 3-3-13; - . . lull-I1. Illti't: unc- IZI II pet. thud InIin of the economy. logging. .. . 1.. County lumber. Ind other wood ptoductI. . hIIthI ??wIIh no can below .1er 41.. Behind healthful lunatic. however. 111113 Inothet Lincoln County. I'ertodtt: Iptuytnuo oI over the to remove broth in the rote-II created I ?urry of ageinII. the govem- ment and timber computiel. Although not 1974). I2 cane? 4 me not I met. Ieven ?1 Inlet. one ence- Ieven otIIeI CNS. not otIIenvIIe tot-I. 40 on page See Herbicide, Birth Defect Tie In Oregon County from page i cases (ZHJ rate per births). as a whole tor the saute peri- od: anenecphaly 4.2 per I0.tlt)tl..bir1hs; spina bit'ida. 5.8 rate; hydrocephaly. 4.5 rate; enceph?alocele. l.2 rate; total U.S.. Ill.? rate per ?Mill. "The local rates are high for whatever reason. says Larry lalnionds. a DC epi- demiologist in the birth detects division. ?You have two cases ol? ancncephaly in Benton l'or I982. l'orettample. One case in any area is? expected; two are not." 'Ihese statistics ?rst attracted the atten- tion nt CDC three years ago because tiiost counties With high rates are in the east . like Appalachia. 'llien. "here comes this lun- ny little county in the west." said Mr. lid- monds. The agency sent him to the state capital of Salem in September. I980. to a meeting of representatives from state tor- estry. agriculture. and health agencies. and doctors and consumers. DC 's after: to conduct a pilot study to assess the elfeet of herbicide spraying on the population. All those represented de- cided against. doing the study. however. because critics could easily tear it down. Pan of the probletn is that it is dill'icolt to do such a study. Esisting'spraying ree- ords make it hard to conl'inn that people Who say they have been sprayed were actu- ally esptued. Although residents them- ?fly-?1 ?will? gl'fl i All? il rigidly ?a ?'th a 1.1% .11 ?my, 1f?: ?Ml-ill 1 J: ?111 1113' 1:11:11? $11111 3113'! 11; 11W?cac1i il?la'li ?pail Lag-i? ulfli _ii Will? .. 1- 1" Ia?l ll?l?l? .. fie-MIL? in}: .1ll.? Ch ?1 (111111} $11111? fall! ".Jlfl.1h;l ll' . Hilly: gill: i I jfli dill?: 1 .Irf? in? up? ll'plr?h If?: 1' - .EHI - 111.1311. ling-4' :E?nr E52: l; ?1 ?31?th I 1 ""11 Helicopter completes spraylng pass over etaar-eut Oregon selves think the problem has eased. Mr. Edmonds points-out that the CNS total tor I982 was four cases. The only year that was higher?with Iive-cases??was I970. There has also been a higlter-than-nor- mal rate of miscarriages in the areas of heaviest spraying in Lincoln County and adjacent Benton County. findings which caused the Environmental Protection Agency to ban the use nationally of 2.4.5- and Silvett on forest lands in I979. llut these herbicides can still he applied to agri- 1cultural land and home gardens. Questions about the elt?ects of spraying on the health of Coast Range residents-? especially in the tensile Five Rivers area. in the heart ol?tlte timber-rich Stuslaw Na- tional Forestmled District Court Judge Robert ltellont in April to Issue an Injunction prohibiting the US. Forest Ser- vrce and U.S. llureau of Land Manage- ment from spraying herbicides and pestl- cides within 25 miles of Siuslaw bound- aries until the two agencies research the health elteets of herbicide use the area. The herbicides atl'ected are Roundup. l?tcloram. and Krentlc. Al- thouglt lilted his own ban a month later. the restriction was reinstated by the 9th Circuit Court ol Appeals in San Francisco in May. Because the court tenta-. lively scheduled hearings on these appeals 1i in September. the ruling means spraying this summer not take place coiripnnics were not allected. however. Int-t the As with other controversies involving 'heihicttles over the years. the lines of bat- tle have been drawn between the "big" (various agencies of the Iederal govern- them. and large timber companies. who say need to spray herbicides to protect their economic interests and rid the forests of hrush to assure the growth of market- alile trees) and the "little" (residents of the areas neat to. or in the middle of. land to be sprayed who worry that their water and their bodies will be adversely allaclesl by the spraying). In the niiddle??sometitncs taking sides. soniettmeanut?are the doctors ol Lincoln County. to whom the people of the area turn when they think they have been math sielt by the spraying. lJrs. hack and Renee Stringham. bath Mle In lamily practice in the county sltwa I975. have been the most igueal in their questions about the cheats ol lterbluld! spraying. don' I want herbicides banned altogether." says Dr. Chat-It I just want to stop the wholesale use and abuse of them. The Stringhams hadn' I heard of harbi- cntes when they started their practice. In the summer of I977. a group protesting the spraying oi herbicides on timber company land in the north part of the county were sprayed. All 20 came to the lor help in treating their symp- toms. headaches and nausea. Next issue. The stringhalu ml questions, Jr? e9? Herbicide Spraying in Oregon. . lino-a! lineal? Count). 0re.. on the Paci?c coast. a controversy boil: over the health fem efaert'al herbicide spraying. b) the 0.5 Forest Sen-ice andn'mber companies. the hat mm?: repair-red. While the chemicals remove forest brush. Opponents argue hey may aiso be responsible for a Mgher-than-norma} rate neural tube defects? aperia?y anerrephah and hydrocephaly?amang m'bontr there over the past dec- de. In 1977. FF: hurt and Renee Srr" ghanr were alerted When they treated 20 wars who had been sprayed dur- ?Ig a protest: headache and nausea were expert in the side effects of spraying. ?e canplainrs. av Row LOVELL mime To help these patients. I disc-owned I knew nothing. and Int no one knew very much [about herbi- cities]? recalls Dr. Renee Stringham. ?In hmofdoingresearetheeman To ?nd out rmre about the possible health hazards of herbicides. the Stn'ngh- ams attended a conference in June. I979 at the University of Oregon School of Medi- cine in Portland. There they heard experts on the subject like Dr. Samuel Epstein. professor of occupational and environ- mental medicine at the University of [Hi- nois School of Public Health. citing the possible dangers of herbicide-use. One the second day. forester-s and farmers talked; ab-out their need for herbicrdes. "We left with the feeling that these: things could be dang-create." said Dr. Chuck Stringham. "The mfaenee also; just isolated people in the hinterlands vor- rying about what no one else know." 3 The Stringhams heeame more persistent ticed. for example. that of the 300 babies they delivered dunng their ?rst four years in Lincoln County. seven had major neu- anencephalics. one. encephalocele. and one had a porenceplulic cyst. called the CDC to see if this rate was high and the person I talked to asked'il'l was-near Benton our-1t}. which he called ooeoffourhot spots for aneneephal) in the countn." Sulld Dr. Renee Stringham. Benton County is the nest to the east and includes mayor portions ofthe Siuslau National Forest. The also noticed that one out ofthree pregnan- cies of panents they treated ended 31th man-ems miscarriage Ald'iough they had no hard evidence that these miscar- tinge-s were caused by herbicides. this dis- emery increased their questions in the 0(1980. the Stringhams proposed that the Lincoln County Medical Secret} an minati'se petition to get a treasure on the hall-or in the November. cide spraying over watersheds and limit ivolunuu'il} expired Tl: medical soci- ety members attending the regular" meeting impassedatootioninfavcrol'me taxing the petition seven is two. aft-o unetslaterceaSannday number: who had not mended the ?rst Earring ha! Edi-added another one ice the . follouing Honda} to reconsiderdie ear-la: roar Two miepnentnt experts from Cali- Rania one}: presaa' on herbi- cides hear.? the net vote. The dam felt they tended thetr out rmgedforDr sanel- I'n c: the local rel-pom- cable channel to Ind: on: [It's-cram and frat: mutual sexier) math-en. ?mime: ?rst of setter} 5pm of the Inma- trve-mone Bod. Staph-:5 caste-argued leave-l) for the erasure shad: Ia: ti:- nJ-tub-e defects' dueebydroarphalics. two 6m that November. The hanassment they suffered during the campaign. alcmg with meneedsoftheirtlueehoysandDr. Renee Stringharn's recent bout with breast can- rtive now. Dr. Chuck Stringharn is still treating lid his wife involved in the ?rst place. In- worrien from the Five Rivers area. All have similar problems. according to Dr. Stringham; ?suspicious utenne bleeding. menstrual irregularity. and abdominal Other doctors in the county takeissu: with the Stringhams or anyone comment-i; herbicides and illness Dr. Denald Firin- nearer the heavily sprayed areas the: where the Stringinms live. since 1958. Dr. my" patiean complaining nl' herbicide- related illness during that time. ?My pne- tiee doesn?t include many ofth: hill adds. ?Herbicides have a short hie. Much of this [controversy] comes from a dioxin craze. Truly dioxin is. without a m. one ofthe roost patent chemicals in Iheworld. maximum iscul} anim- [arn'ry that has been pert} well elirninmd. Heu of the people complaining [base tnents that are] eeartphely compatible Dr. Forinash does taut think there he enmgh data to say that huh-ides ms: medical problems. ?Calm rs advised." continued. ?Bin. as yet. and: the ca- Cmn'rn-ee' on MS page (5 [?res-day. August I1. l983' . . . And Views On The Threat of Con-genital Defects ann'nued from preceding page eeptjon of dioxin. there is not hard evi- dence that this is a real problem If there was a great danger from herbicides. we wouldn't be wondering about it. we would thou about it." Another physician is not so sure. Dr. Peter J. Cookson is a palhOIOngI who has practiced in Newport for [0 years. lho-ugh not actively invoked in the herbi- ddeissueononesndeortheother. Dr. Cooks-on says he began to wonder about he relationship betteen spraying and health two years ago when he had two cases of aneneephalie infants. ?In m} experience. in all my years of training at the University of Medical School. I had not seen an} arsen- aephalic cases." he sud talked to my innit-tors and aslt? when the} had last seen one?among the 1GB deliseries per year at the hospital The; hadn?t seen an}. The; remarked. ?that's a lot to see in such . I small. podunli place.? Since that time. Dr Cents-on has not seen an} more cases "But the) haven't hen spraying since then. either." he add- ed The county health of?cer. Dr Ethan Wilson. thinks the public reaction to graying has had another consequence. ?At the state level; there has been a deci- sion to minimize spasm; because of the kit spots and local reaction." be said. "Things are slowing dean. Cornpanies [which are still allot-ed to sen} 1 have had I) be more covert in Ming their [darts because ofthe tandem. helicop- I: ?Std for mgoztw 3pm . ago. and a large pn-e of logging equip- n?eu aas set a?'re in line. it two different Fanfd'rcCoas: RangeIThereis-also nact more public Dr Wilsonsaiddie romeasesinthe curt-it} he exposure that caused nausea. x'd r-Jmnma.? pram The Que-atoms disap- p?e. th. nut day uneasy about mg-tem: efforts of herb-rides." be lit! rust don't hat-e the data. It's a of ab: roe-It sham up It: . yea-s -- f. Aq-q .. p, The coumy iaelf is also much more aware of boa to handle herbicide-related poblerns than most nual governments. few years. the Lincoln and Benton county health of?cers in 198! worked out a plan. with help from an Oregon State scientist. to respond when peOple call to mplun of ilkless and link that illness to herbicide-s The :aller rs asked for details on when and ssh-ere the incident han'ened If the illness has been trolmged. the Palm de- partment holiness blood and urine samples lid semis them for analysis to the Oregon Department ongneulnn'e. The health de- partment also examples ofl'oliage mud dumge'wthe agrieulnn'e de- partment Last year there was little it:- spmse.mdmg toGnil Sue-r. environ- mental health pogram mg: for Lin- coln Crust}. "The sex '5 with: stay.? said Ms. Slater ?The di?erenee is the ml of sensing It's at enmal-pohunl-eeo- mjc- issue "nus celebrated irndent oe- ean-red a May It the: a League hm Finland on a school pining ?eld'm Toledo. just east of Newport. That night and the next day 12 boys and nine parents had come down headaches. intestinal cramps. and vomiting The health depart- ment was asked to intestigate and dis-cov- ered that the school dismet had sprayed the ?eld with NS 610 herbmde on May 5. - In the intervening period. four other effects It had been raining intermittently until May II. a amny?day The sun appar- ently caused the had reaction then. A delay- in reporting the incident also caused a de- la; in making blood and unne tesu. "1f it?smore that-148m. there isnoehanee' of getting Signi?cant levels to do Signi?? cant tests." said Dr. Wilson. Continued on page 30 ?Us View Spraying Calvinuedfrtun page his problem has always plagued physi- cians trying to prove herbicrde poisoning elsewhere. People wait to go to the doctor beyond the time when complete data can be obtained. thus lessening the chance to grove their illness is herbicide-related. ?Beyond 24 to 48 hours. the chance of getting anything measurable is pretty neg- ligible." said Ms. Stater. The matter of herbicide spraying?for both defenders practice and oppo- ofiP?will doubtless go on as long as there are forests and people living near Item. Concludes pathologist Dl". Cookson: ?My opinion is the cases [ofdeforrned ba- bies] showed up after a yet of intense spraying. They disappearai after spraying stopped. Anyone can argue that this was not caused by the spraying lcan't prove i. If they start spraying again. we'll see fanny-looking babies again. live do, I'm then you drink the water." Herbicide Watcher A Bitter Fug. ?19"de Von Smart Sierra Club Books. San Francisco. 288 pp . rs A reasonable book about a controversial and often unrea- sonable subject. the use of herbicides tn forestry and agnculture. and the conse- quences for the people exposed. Carol Von lives on a small farm in the middle ofthe Siuslau- National For- in the Coast Range of Oregon. After Iri'children were accidentally sprayed and got sick in I977. she began to investigate the effects of herbicides on her neighbors and others living in the area. She dis-cov- ered other sicknesses. as well as a pattern of miscarriages and deformed babies that maid be linked to the spraying. In the eyes of the government bumm- erars with whom she spoke. however. there was no say spraying could escr cause health problems. To them. she writes. "pmson-s are innocent until prosen guilty." She usages on to present a revien of berbicrde use elsewhere?for example. Agent Change in Vietnam. and 2.4.5-T tn Globe. Aria Habooltdetails medical evi- dence the porno-cots ofbetbicaies always say is lacking but never research them- selves ln?eedJi'tisaspectmakesthebook useful to mystic-lam who encounter ocea- sivonal pmenu who cu'rtplain of illness possibly linked to herbicides A Bitter Fogis an mgr) book. but it is nelsbrill'mthewa} similarbontshave been in the past. It is a Bell-Britten protec- tile aimed at penetrating the nail of ind-J: ference other-bind: admcates. in closing. 30th uhich mil} domes its just powers from the consent of the gas- ermd carnal dens It: 'eplropl the opportu- nity to Infant: their dis'Tetioe to et- ercise the: control oser potenaal lethal poisons Tbepe?ple hast-arenas! du'} to . exercise their rights More is at stale than mm of Jenna-ac} Against the deaf} politeness-n decorum: pom-ans. only an . infmned. can; pubbc can defend the greatest pf! ofaIJ?lit'e resell Ros Wednesday. September I4. Citizens Iley' In Oregon Pesticide Fight? Rim Liivou. Tm; Two MMUII victories for herbicide opponents in Oregon in recent years were won out by doctors but by private in- dividuals using medical evidence gathered hugely on their own. Honnie llill lives near Alsea. Oregon. - Just over the Benton County line lrom Lin- coln County. In I97H. this high school En- glish teacher with a long-standing Interest in science chanced upon the research find? ings ol James Allen. a University of Wis- consin selentist. about the increases in spontaneous abortions among rhesus mon- keys esposed to down. "When I read that." she said in a Interview. ?it helped explain the miscar- riagc sullered In [975. lly that time I had taught in Alsea live years and heard rum- blings liimi limiter students about itilsctir- riages they had had. She contacted them ltir inliirttiation about how [or along in pregnancy they had been and then got medical verification. Third of Three Ports From I973 to I977 there had been 34 miscarriages in the Msea area. most clus- tered in I970 and l977.livoyearsol'lieavy spraying. Over 70% occurred in the spring. roughly coinciding with the spray period. "It seemed very curious-that the only variable in our lives here-?the seasonal occurrences?was the use of her- bicrdes tn the spring." she said. As olten happens when sermon is di- rectly involved in the herbicide issue. Bonnie Ilill's search to gain more Inlorma- tton took on an element ol a crusade. 'l he day she venlied the iitiscamages. she con- tac?ted the government agencies and pri- vate companies who spray in the area for data on the location and amounts of herbi- cide used. A Flurry cl tfobltelty She used data from the U.S. Environ- mental Protection Agency llzl?A) on spraying patterns and potential spray sites. and itiolertal limit the of Forestry. the U.S. Forest Serwce. and the USS. Ilureau of Land Managetticiit' (BLM) on IierbiCide application. to pre- pare pinpointing the location and dates ol spraying and the location of the homes ol the women who had miscarried. She did this lor each year Iroin to I977. Alter she had prepared all her documen- t'mitmard mt [mgr .IJ . .- H1 ?eJa? it! If." ?ll; ?25 'ili'lljy ?if, m; up.? "1 l' ?hit" .. ?lil ?it ill"? ?t-tlth? Jill?. I s?hl' ll'k .-, Jen . .. ?flv'7l' El}: 7 I it: ?P?Jlf??t 1till?! '?ih Wit I reuercher Bonnle NIH and keep lookout on cruli near that home. typical at those used locally tor water. Dunner] Data Gathering by Citizens Began Pesticide Case ('onrurirrd from rarer 9 ration. Mrs. Ilrll wrote a letter to EPA. the. other agencies concerned. and newspapers in Portland. Eugene. and Corvallis. stating her thesis that the spraying and Ilse miscar- riages were connected. 'l?hme letters brought television camera crews to her door and a great deal of pati- 'l was not aware ut the eatent ol' the controversy until that tone." she contin- ued. "The word miscarriage caused the in- terest. although I was opposed to anything sensational. was yes! interested in the el- teet these substances have on the environ- ment." Some weeks alter her letter to EPA. the agency sent two scientists to meet will! Mrs. Hill and two ul? the other women who had miscarried. That August. another team arrived to interview the women and get them to tilt out questionnaires. The learn drew a water sample the lulluw- tog January. lung alter the last spraying. The area is crisscrossed by a nuorher- ol? streams lruitr which all residents regularly draw their water. EPA ?ludy Contained This material [later to he called Al sea It was then sent to It! physierans around the country l'ur review. 'I'lrcse reviewers even- tually said that there was noconclusrve ev- idence to support the contention that lrerhi- cide's caused the miscarriages. In the ureantone. lzl'A pressed ahead witlr its larger Alsea II study ot Lotto square nnles ltorn Lincoln (?in on the north to Florence to the south and inland 35 miles. On March I. I919. helore the Spraying season hegarmhe agency an- nounced its conclusions: The alairttun rate ol was higher Ill this study areatliao Ill either ol two other areas used lot comparison. 0 There was a seasonal luur-inoittlt cycle ol abortions with a peak ul June in the study area. 0 There was a cross-correla- tion lietween the spontaneous irr- des and the pattern ul 2.4.5-1' use. Attire satire tone. lzl'A liantied must use ot 2.4.5-1' and nationwide. over strong ohiectrons from the truest prialucts and Dow (?henircal ('oinparty. The hair cattle because the agency satd'vrt had signrticaut evidence linking the nos- eai?rrages in Alsea to the use til the chenil- cals 'l he l?irrest Servtce and the clieirocal curiipanres have been trying to overturn the hair ever since. so l'ar with no success. is ?r As ltonnre Ilill savored her victory. l?aul Merrell's held against herhiurlc spraying .In the nearby l?rve Rivers area had not yet lrcguir Acting its his own attoriicy Mr suit to strip the spraying or April Iarlureol the 5 Depart- rocrtt id lulcrrot and ?Us to implement the procedural oi the National liirvrrornireiital l'olrr'y Act ol l?ttitt. In a January hearing. the court upheld Meiicll's argument that law reourres agencies to carry out their own sctcutilo inquiry Irtto salcly ol lierlir crdes. rather asserting that lzl'A regis- ot a ctierriical tor pesticide Use is adequate posit ot salety. Mt "'lltc [tulilts' has been alerted Itial's greatest-thing People have started looking 'lo tlls?. the court was the turning point. the lie- grniiuig ol the end. 'llieie's a lot til work tell to do trot we're user the top." SPONTANEOUS AND In March 1979, the Environmental Protection Agency (EPA) suspended and Silvex use on forest, rights-of-way, and rangeland because of accumulated evidence of animal toxicity data and epidemiological data which showed that human exposure to these chemicals may result in cancer, increased susceptibility to disease through suppression of .41. f! I the immune response, and adverse reproductive effects (1). Among the epidemiological evidence was a reported relationship between the timing and level of spraying and increased frequency of spontaneous abortions in the coastal forest area of Oregon i, -was a court challenge of?t'heE suspension deu..=iun The EPA a - I - - .. decision was upheld and?; cancellation process was be'gun'_ in ?edmig?tkajiyggj??' i?i?gg .-. - I ~it'asu?1ingtor' 13.0 Because the matter has _be_en in litigation almost continuallysince-the suspension, the researchers primarily responsible for the spontaneous abortion study (including the, authors of this report) were constrained by the requests of EPA adm environmental contamination w1th d1ox1n (7), the f1nd1ngs of a recent conference 1n Ho Chi Minh City, concerning the effects of herbicide spraying during the Vietnam War (8) the accumulation of other epidemiological evidence and the possibility that EPA is #1..ij negotiating a settlement of the domestic isue with the Dow Chemical Company i. (11) mek?e; it imperative that the Oregon experience be publicly placed in the proper . I . perspective. This is necessary because the ?ndings of increased spontaneous abortions zmong women i_n areas of 2,4,5- use with the 19311}, related to 02.1w? ?kW/2.2! Rig-jg; 1- 11?: -1 u? attest? . - .. -. ceases?m? s43: Emit 77%? a Hie ?7,2ng ?9?qu . a . MW I 4? hrs- '61 ?9,9 "Ti?frail. ?as then submitted to interested members of the seientmc communm, provinces-1L: of coniinuedJL?J-Lgse The investigation of abortions ir-iu'nn Oregon originated in connection with the 2,4,5-1? RPAR issued by the EPA in April 1978. The RPAR summarized the evidence that 2,4,5-1? and its contaminant (TCDD) caused fetotoitic and carcinogenic effects in laboratory animals (12). A H- .. The herbicide is classified as moderately toxic with an acute oral (rat) at 500 mg (acid (14). however, the toxicity of has not been of?princi" .7: public health'concern, but rather the effects of its contaminant recommendations made to EPA by the Advisory Committee on 2, 4, 5? the dioxin contaminant must be held to less than 0.1 parts per million (ppm) during the - manufacturing process had been demonstrated to be embr yotoxic in birds (15) -- and to be teratogenic in mammals (16,17,18). There was also the suspicion that exposure to 2, 4 and its TCDD contaminant was related to the occurrence of birth defects and stillbirths in humans (19, 20 However, the conclusion of various study groups was that reproductive abnormalities reported among laboratory animals were associated with 2,4,5? exposures containing 30 or more of TCDD, and that the use of restricted to M?w-no more than 0.1 TCDD (before dilution) should present no hazard to human health (22). 714,91) .3 Field studies of fish and mammals have provided evidence both supporting and contradicting claims of TCDD accumulation in higher animals. An evaluation of biota in .. . 1. ., the area used by USAF for training bomber crews in application of military defoliants 'showed little accumulation of TQDD in fish living in the streams of the area. The area received approximately 1000 lb.?acre During the peak year of "application the 2,4,5-1" contained about 2-10 Mice in the area accumulated liver tissue. burdens of several hundred parts per trillion (pptl when measured at the end of the spray program, and the sandy soil had accumulated residues up to 700 ppt. These animals 1-- 1 a ?owcu?l/ ww .g?emonstrated no pathological changes (23). Msubsequent studies of the 1355;.- . -. had entered certain food chains (insects, mosquito fish, sunfish, snakes, and birds), (25). it was recommended that ?shing in the area be restricted to prevent human consumption of fish until all traces of the TCDD disappeared (24). Because phenoxy herbicides are applied to control noxious vegetation, the species of animals most likely to be critically exposed are the herbivores and those exposed directly 6-904 hr Hm?i? M77363 and 'residues in eart, liver, muscle, stomach content and feces/ 10.53pm}, operations. For exa p13, deer whose habitat had been treated with in-other organs such as brain, blood, kidney, lung, nodes, ash-onus- .. .24- - - as well as blood and urine. Peak' residues ranged from 6.0 to 191.6 g/kg Cows milk samples from 2,4,5?T?treated areas of Oklahoma, Arkansas, and Missouri .were found to be negative for TCDD with detection limits on the order of 1 (26). TCDD in-beef fat was undetectable in two series of animals which had grazed on treated pastures in Oklahoma, Texas, and Missouri. in a third group of seven animals confined in a sprayed pasture, three samples were positive at the detection limit of 3-4 (27). TCDD has been found in several beef cattle maintained in Hui-d experiment on fields which had. received 1,2,3, or 4 pounds of 2,4,5?T,?acre. Average TODD in fat was 20.3 in the 4 lb/acre group, but there were only three samples, one of which was extremely high. At 3 lb/acre, the average was 12.3 ppt, again derived from some high.- valuesaqdv many negatives (28). . - TODD residues are strongly bound to soil sediments and migrate through water run? off .(lt?oung et a1, 1978). ?tpdies of TCDD bicaccumulation in aquatic biological samples in the drainage areas of an Agent Orange storage area have shown an approximate first- order decrease in residue levels with distance from the origin of the contamination (Young et al, 1979). 1'zu:C Thus, we see that women who have recently conceived could be exposed to TCDD through accumulated residues in fish and animals, through direct exposure during spraying 3; operations, and through TCDD movement and accumulation in the sediment associated with the surface water drinking soumes which are very common in the coastal region. In a re5ponse to the RPAR request for public comments, eight women in the environs of Alsea, Oregon reported suffering 13 spontaneous abortionsduring the period of 1972-1977. They felt they were unduly exposed to 2,4,5-1" by the frequent W: Mforest Spraying. In response to the inquiry of the Oregon women, EPA :commissioned Colorado State University researchers to survey the women and ascertain as Amu uch information as possible on 2, 4, 5-1? exposure and subsequent abortions. The survey I. 11 data were subsequently reviewed by ten experts in the fields of obstetrics, gynecoloc?v, 5 epidemiology, biostatistics, reproductive endocrinology, and perinatal medicine. end?? a ?Jill?? concluded that although a causal relationship between forest herbicide use and 4.. . -- reproductive wastage had not been emonstrated, there was a high numerical incidence of March to June abortions (nine . 13) and that the spontaneous abortions appeared to: I: follow a seasonal pattern (2). Further, a report from the Yarram District, New Zealand}; on the relationship of 2, 4, 5?2? usage and birth defects stressed the importan [girlie of the temporal relationship of spraying and conception (13). Subsequentlv,z to investigate spontaneous abortions in Oregon in relation to timing and level of usage in the coastal forest arca. - . - . The tpsea design was a descriptive epid1?1 1?.1iolg cstudy, suitable for comparing (m c1 bd?t? 5' wMiCUt-ttrtu K5 4/4 64:41:01?: an area exposed to 2, 4:17;: (t a study area) and a- .. . it! ram-Ila d? 2, 4 (the control area). Thejstudy area represented about 1,500 square miles of Oregon i vW' forested Coastal Range. It included the western half of Benton County, a small western .. portion of Lane County, and nearly all of Lincoln County. The study area is predominately rural in nature with an estimated 48,000 persons based on the 1970 census. The control 1, . area was all of inalheur County in eastern Oregon (estimated population of 25, 000), a rural @Mwa. .11 Mia. . 131.111.2411qu Lava-2L 35 7M-WLO 'a I Q. at 0 have been the site of usage for the selected observation period area known)? of 1972?1971. t'hile topologically different, the two areas were similar in two vital areas, eg., the economic viability of the communities, and the medical management of spontaneous abortions among physicians practicing in both communities. Specifically, the two areas 'ivere similar in mean family income, pe cent of families below poverty level, median agei?of female population, birthrate, fertility rate, fertility ratio, infant death rate, and the number of physicians, and hospital beds per capita. Although the study area is a forested coastal region while the control area is a dry, arid region there is no .n-o evidence that such geographical differences are important to spontaneous abortion . .- 0! . co 011' experience. was, When community characteristics are similar, other factors, such as viruses,'_ .11.. 'a infections, lifestyle (including drug use) and poor maternal health are expected to play N- equal roles in both the study and comparison communities as causes of spon aneous ,5 abortion??v?ferencei in spontaneous abortion experience may then be]re_lated to a . 7M1 .. 64"?th ?1 ?1):ch ?raw-Ff 5:120?? .3. If within boundaries of the study area and its absence from the control area. .. -. fiel study of spontaneous abortions represents a formidable task, ,s-i-Je-it is not .Lum'imgcc?tbl only to agree upon an acceptable definitio?pjt?a epidemiology (sf?em o?QA-tb Was is poorly understood (30,29). This is.-true in part because the diagnosis and reporting of spontaneous abortions is a complex problem. Any abortion taking place prior o! to the first missed menstrual period will almost surely: no unnoticed. If an abortion occurs during the fourth to seventh week of gestation it can easilv go unreported and be clinically uncon?. med since women are unlikely to seek medical care that? early. From the eighth week of gestation forward, fetal losses begin to come to the attention of the physician, but reporting to vital statistics registries is not generally required until about toga 11 m7 a, ?@0461? seawtwj? (Put i I 5 Put? ACLHE?Lui?gcfe Paw/'67 20 completed weeks of gestation (30). ammormomo . p? (11-669) (30515476972 hf . 5 5 1::sf? . ?Etii;=" f2.? Deputy Assistant Administrator'wl-r-Office of. Pesticide Programs i?j? I .T I i Env1r0nment41?aProtect1on Agency . . Ir? .X I 1* 115-- 31' 1" b' $317.45.? 4g; Hashingt on' 204602 I 1. - . ream-11.11.: . ev? -- 0851-..- . had some disturbing news yesterday and I thought I share it with. T?i? g: "you: since _it concerns HED support for DGC and the 2. 4, 5- hearings. Bob Duncan-was infonned by BBC staff that although DGC was 100 percent .giejg?f; - in in; support_ of the Alsea study there were continuous and frequent scatological comments from HED staff about the Alsea study, and a- reluctance to provide requested support. The DGC staff did not elaborate E"on exactly who the complainers were, and frankly, that's not important.,.; i? 55 Hhat does matter is whether or not the attitude of the staff is refleIctive' :33333 of Peter McGrath' 5 and/or your thinking. .1I . have also been told on different occasions by different people that I Steve Jellinek is not happy with the study nor with the Colorado project' 5- conduct of the effort. This is quite bothersome, since the project had only six weeks to go into the field, conduct the study, and draft an initial report. The time frame was mandated by EPA and the project I conformed accordingly. Anyone who knows anything about field studies must know that to devel op a study protocol, transport staff. hundreds of miles, conduct a major study, analyze the data. and generate a respectable, even good report in such a- short time is nothing short of 519,}; - phenomenal. Sue Sherman has also been quoted as saying you don't want 1 "another Alsea study" of "soft" data. If this is true. I'm really - ta. __discouraged, since Bob Duncan and I have-said.since.the beginning of this effort that the Alsea data are not soft. In terms of numbers of SA's per pregnancy, the Alsea numbers'are unbelievably reflective of - other studies conducted throughout the years in other communities and . referenced in the literature. There is also no doubt that the medical management of SA's in both the study and comparison connmnities is very similar both in treatment and in hospitalization practices; we - - reported what is taking place regarding the hospitalization of and we did not underr report or over report in either area. Upon review of the hospital records by a University of Miami physician (with a specialty in maternal and child health), Bob Duncan and myself, there is no - doubt that the use coded hospital record face sheets actually reflect what was determined by the physician of record to be the diagnosis of the patient. I A private. independent. international university An aqua! opponunity/af?rmative action empioyrr I .. -. - u- - . . . ?e .so??turatslva, . .. . no question but that the cyclic nature tear?? a. . . nature of the data between the Ms: .. . .. 2.4.5-T. . . magmas} use? 1.2-. . Ei?i??r?l?q study, hasbeen knocked.by_the best of experts and ggag?yg: found_to have little in the way of redeeming value.- But I would . - the criticism there are two salient facts ?Kar'ae; regarding the'Alsea study; i.e.i,none of the detractors have actually . ., ;r thegfact of significant differences among the and control'populations with other than a rehash of the data gathered by fact; when one looks at all_the critical reviews. ?i?f one-begins tofsee that they center about four major criticisms: l) study andjcontrol'populations are not similar; 2) medical treatment obstetrics cases is dissimilar in the study and control groups; f;l-3) the hospital generated data are "soft" because: the data were i, abstracted by different persons; did not accurately reflect all place in the study and control areas; did not include significant ?99. and completed a better designed study; and none ied?that_the abstraction process was done so by theuColorado project staff people and the hospital .n-9 ?wa?the?data?jsfgenuine and?reflective of what is found in the literature tontrolfcommunities;is statistically associated with the time x: 3 . . a- . input; did not adjust for the large numbers of tourists u-F-'coming into the study area yearly and giving birth or having abortions; ?iffa: we used inappropriate statistics to support an already decided EPA position; and 4) spray data in the Alsea basin area did not accurately reflect the spray data figures used in the entire Alsea study area. I will not bore you with individual responses to each of these criticisms, suffice it to say, that we have reliable data to refute each one, and will do so during the hearing.. I would however, like to review the following points: the Alsea report as released was a severely edited version of the original paper prepared a by The editing at the request-of the project support team removed a major portion of the introduction, purpose of the study. and background data on the animal studies that theoretically lead to -- . the?development of the Alsea study. In fact,_the paper was edited to fit'into?the official EPAtPcogranI Support Document, and should never have been submitted for public comment or review without the appropriate - background information. - I understood when developing the study that we were involving ourselves in a very difficult endeavor, i.e. spontaneous abortions would be particularly difficult to measure due to the scarcity and incompleteness of any data. However, such data if it could be generated. would provide us with the only opportunity for a viable human link between and possible adverse health effects. - I 2.. 33$? ??f'Agg ou no dou-t Areca11, rI had serious reservations about finding anyth1ng,1 page,? re1ationship between the study and contro1 groups ,1 since destriptive. epidemioTogic studies are genera11y not sensitive enough sma11 differences among study groups. Quite frank1y, - .5 the use fof hospita1ized cases made this determination possib1e because of, 3? the? ?hard" data _nature of the infonnation.-j If we had inc1uded other data 1:1 sources, ?weg1ike1y wou1d have masked the significant, but sma11, differences "I-n between the two .3 "Add?! ,2 :5 we}; . i?gm HMuch has been said about other factors being responsib1e for the increased acumen-g numbers of 5 in the study area. I pointed out consistent1y, and from it's: the?beginning, that given two 1ike communities (and in the medica1 manage- nent of SA's, the popu1ation at risk to pregnancy and thus abortions, and their rura1 and economic nature, the study and comparison communities are .7 much a1ike) factors inf1uencing 5 mus-t be assumed to be the same '1 i. recurring factors that are known to negative1y inf1uence feta1 we1fare 13,5uch as very young or advanced materna1 age; previous abortions; poor socio- 1' $1 economic status; pro1onged time to conception; impaired materna1 hea1th; i11egitimate pregnancies; pe1vic patho1ogy; anatomic defects of the generat- 7? 37. ive tract, et a1, and to aff ect a11 chi1d bearing popu1ations equa11y, unti1 1 11111 my I .Efl. - I ?7 shown A1though not a great dea1 is known about the epidemio1ogy of 5 this much can be said: the successfu1 deve1opment of the fetus is without doubt -- f?significant1y re1ated to factors which inf1uence the intra- uterine environ-I =1 ment, such as TCCD. Since one must assume (supported by the 1iterature) that genera11yt the onset of 5 in one community wou1d not be significant1y different from another without an identified fetotoxic variab1e inf1uencing the outcome, one must a1so assume that when the variab1e and an increased number of SA's are statistica11y associated, there is a distinct 1ike1ihood of a causative re1ationship. It has been my position from the beginning - that the A1sea study, upon appropriate data ana1ysis, ref1ected this approach and that, if in fact detractors fe1t that other causes might-be responsib1e for the p1ace-time re1ationships we are seeing between spray and abortion, then it wou1d most proper1y be their p1ace to provide data to support their hypotheses. To date this_has not been doneThe critica1 point in this entire episode is that peop1e rea11y know 1itt1e about the cause of 5 and apparent1y 1ess about the nature of epidemio1- ogjc studies. Consistent1y throughout this exercise over _the past year, reviews of the A1sea study' have ref1ected an intense interest in eva1uating the A1sea study as if it were designed to provide cause-effect re1ationships. This simp1y is not the case. The study was descriptive in nature, with what I wou1d consider to be-a specia1 wrink1e on my part, a com arison community. I knew that any differences found wou1d be quite sma1l; and had we not used a comparison community we wou1d have recognized no difference. in the number of SA's in the A1sea popu1ation when compared to other reported popu1ations. This approach is unique to descriptive studies. -ev-r rift-HF" hm ., ""133 1~ Es g?e?'s if? ,1 . 4,433 . . 5:35;; Etc-Mid": Aa?'higim 9.95 1y..adt?was quite?1npossib1e to use theistandard case? ?controT approach since -e?hir?a114thi d- _bearing women conceiving and de1ivering in the study area were_ 33- at risk- -toW exposure to use of the comparison community perhaps_ 23.. ,_caused Some confusion on the part of different reviewers, but the study ~is sti1 on1y a search of hospita1 records and a descriptive rendition .. of what is found on those records. The purpose of any findings wou1d be -- . 3Hto ca11 attention to interesting facets of the data. and to generate. . ?~5355iiqcomment3 discuss1on and additiona1 studies required Ito support or reject the f1ndings. L. ..1 manianghi?? It is obvious to me at 1east as an epidemio1ogist, why Dow and others - - have not presented new work to support their position. what we found is i j: scientifica11y supportab1e, and they know it. Rather than undertake - 1 study, which for them wou1d have been simp1e to do in the past 3??5 year, they have chosen to attack the study pub1ica11y and poTitica11y.- stress the cause- -effect concept when it c1ear1y is not a study of that i? ?nature, and cast enough doubt about the re1iabi1ity and va1idity of the - 1 35:? ?i data that EPA wou1d be forced or coerced into repudiating the resu1ts.- must say, that the actions of DEC a10ng the way have tended to support . :41 .this effort. The study report (taken out of context from the 2, 4 5. Program Support Document) was submitted for review and criticism without ..1 - the banefit of expTanation and/or supporting documentation, and frank1y, . it was right1y denounced by members of the scientific community (however 1; so1icited or biased). In fact, the study did exact1y what we hoped it . . . wou1d do. It provided us with usefu] infonnation on the number of 5 in the study and comparison communities, and enab1ed us to determine . that a significant re1ationship existed between 2, 4, 5- usage and the increased number of 5 in the study community. I don know frankTy, that you cou1d ask more of a study. Sure1y there was some sToppy work, both on the part of the contractor, and of the Washington staff but the study design was snund, the data were good, and the resu1ts refiective of what is happening in the study and controT communities. In one Tast aside, I feeT constrained to point out that everyone associated with the deve1opment of the A15ea study has been restrained from speaking against the negative comments on the study and on the capabiTity and veracity of those invo1ved in its deve1opment, conduct and interpretation by USE. This is quite unfortunate and a1though it may be much better for our defense in the hearing, I be1ieve it may be causing much of the _;egat1ve thought and non- support express_ed by HED staff to DGC. Sincere1y, JG/bt Gri Professor Dept. of Epidemio1ogy PubTic HeaTth 1 University of Miami Schooi of Medicine 15655 s.w. 127th Ave. Miami, F1 33177 (305) 251-9823 rr' - uric. . o. jzg?il Hannah-'3, 06c: .W 9/1 /e3 . MEMORANDUM SUBJECT: Merrell v. Block and the Five Rivers Investigation Stanley H. Abramson Associate General Counsel Pesticides a Toxic Substances Division Gerald H. Yamada Deputy General Counsel Jud; Wheeler of my staff has looked at files in our possession regarding the case of Merrell v. Block to determine whether the question of the Five Rivers investigation was part of the court proceedings. This issue is of particular concern because of a letter from Michael Gross to Linda Fentiman dated September 22. 1981, which transmitted the results of some of thei Five Rivers' sample analyses (Attachment A). It is clear from the pleadings in the Merrell litigation that Paul Merrell made repeated efforts through the court to obtain the results of the Five Rivers' analyses in addition to similar efforts under FOIA. The following are examples of his efforts and the government's_response. 4/15/81 - Complaint Herrell referenced the camplaints regarding Forest Service spraying in 1979 and follow-up study and stated that ?(n10 results of that course of study were ever made public.? The F01 request and the Agency response (6/23/81) were part of I the court record. Exhibit 12-1 . I I?m? I 12?2 -2- 8/31/81 - Plaintiff's Second Request for Production Item (1-7) requested '(alny and all agency records . . . pertaining or relating to any past, current, or proposed study, investigation, or inquiry into alleged. suspected. or confirmed human health effects associated with the use of pesticides in the area of the Siuslaw National Forest. . . 10/23/81 EPA Defendants' Response to Plaintiffs' First Request for Admissions Under Rule 36 Item 2?10 contains an admission that by mid-August, 1979 ?a health study was commenced in an attempt to ascertain if there was an association between residency in the Five Rivers Valley and exposure to certain pesticides." Item 2-11 admits information about samples taken for chemical analyses and transported to Bay St. Louis and states '(d)efendants deny that all of these samples were to have been analyzed for residues of 2.4?0, picloram, silvex and cioxin (sic). Defendants deny that because of analytical priorities set up by U.S.E.P.A.'s Special Pesticide Review Division. no chemical analyses were ever.performed.' Item 2-17 admits that '(d)efendant Edwin L. Johnson has claimed that the document listed in Enclosure A to Exhibit 2 are . . all of the documents in our filed (sic) concerning the studies done in the Five Rivers areas and any complaints specific to that area." In Item 2?18 defendants deny that ?documents referred.to in Enclosure A to Exhibit 2 do not give any results of 'studies done in the Five. Rivers area? or of any investigations into 'any complaints Specific to that area" because these documents do include some preliminary a . 2, H- -3- results of the studies and investigations involved.??f EnCiosure A of Exnibit 2 is EPA's 6/23/81 response to Herrell?s F01 Request No. 213. MS. Wheeler did not see any 'preliminary_ results" in these documents, except for Bill Wheeler's autopsy report on the two headed kitten which contained no chemical analysis. 12/4/81 Memorandum in Support of Plaintiff's Motion to Compel Production Herrell referenced his second request for production under the heading The Five Rivers Health Study" and requests the court to compel production based on EPA's admission that there was a health study. He tied in the Five Rivers ?study? with the NEPA requirement for the EIS to address adverse impacts. 12/17/81 - EPA Response to Second and Third Requests for Production Makes no reference to Five Rivers investigation. 12/23/81 - Plaintiff Paul E. Herrell's_Motion for Summary Judgment Describes the complaints to EPA made in the spring of 1979 regarding Forest Service spraying. Paragraph 53 specifically references Motion to Compel Production and Five Rivers Health study. . 1/25/82 - Plaintiff Paul E. Herrell?s Reply Brief in Support of Motion to Compel Production - In paragraph 15 Herrell states that the type of information requested by plaintiff. including the Five Rivers Health Study, - is unqualifiedly required to be disclosed. In paragraph 35, - under the heading 'What about the Five Rivers Health Study? he states that he 'has been unable to identify a single document 12-3 3 - loll. 12-4 -4- among those provided or listed as withheld . . . which deal with the Five Rivers Health Study. Is the agency contending there are no more documents relating to this study. even after they have refused to admit that no chemical analyses were ever performed? response to plaintiff's first request for admissions. October 23, 1981, page 4/26/82 Plaintiff Paul Merrell's Motion to Amend Complaint Paragraph 9 refers to FOIA No. 213 (the Five Rivers request) and claims key documents were arbitrarily withheld without explanation. Paragraph 15 is a claim that Merrell is entitled by law to access to the documents sought in the FOIA request. Merrell seeks expedited processing of the FOIA requests and an injunction against withholding the documents. 6/9/82 - Memorandum in Opposition to Plaintiff's Motion to Amend Complaint and transmittal letter from Thomas Lee (Assistant U.S.-Attorney) to Linda Fentiman (EPA. OGC) The transmittal letter to Linda Fentiman states 'a copy of your Memorandum as filed. is enclosed" (underscoring added). The memorandum 2) states '?kfehdants Anne M. Gorsuch and EPA have fully responded to plaintiff's requests (for production). and have released to him all non-privileged documents in EPA's files which are responsive to his discovery requests. . . . In regard to an issue raised concerning whether Merrell's appeal of the partial denial of his FOIA requests (unrelated to Five Rivers). at p.4 the memorandum indicates his appeal is being treated as a new FOIA request and '(a)gency files will be searched to determine 4 ul'au .. -0 I01. 12-5 -5- if there are any new documents which fall within the terms (of the FOIA requests). The memorandum argued there was no relation? ship between Merrell's FOIA requests and Merrell's allegations in the original e, defendants stated '(pllaintiff never asked for the documents sought under FOIA as part of his numerous discovery requests. . . Merrell had argued the Five Rivers information was necessary for a proper analysis of adverse effects under NEPA. On 4/30/82 the court denied Merrell's motion to amend his complaint as to the FOIA argument. - Merrell's FOIA #213 asked for, inter alia, '(a)ll documents T3 the possession of the USEPA. . . which EPA . . . can reasonably identify as having knowledge or records pertaining to the 'Lincoln County Study. . . concerned with phenoxy herbicides, principally . . He also requested '(a)ny and all records pertaining to terms and results of c00peration among the Siuslaw National Forest. the Institute of Rural and Environmental Health (U. of Colorado). the 0.5. Environmental Protection Agency. or any other agencies or persons involved in the review and monitoring of the Siuslaw National Forest's fall 1979 pesticide program. . . In paragraph 9. he requested '(alny and all records pertaining to any other investigations, reports. or complaints of human health problems in the area of Five Rivers, Oregon (at any time) in which involvement of.pesticides was or is known, suspected. or claimed by any person.? Paragraph 10 requested any communications relating to human health problems in the Five Rivers area and paragraph 11 requested PIHS reports for 1981 relating to pesticide use in the Five Rivers area. 8/10/82 - Memorandum in Support of Plaintiff Paul E. Herrell's Motion for Reconsideration of Magistrate's Order by District Judge This relates to denial of Herrell's motion to amend his complaint to include FOIA arguments. In a footnote on p. 6.. Merrell stated '(w)hile plaintiffs' administrative appeals did 12 produce some further documents (re IBT) . . . many documents were again withheld without explanation. The request for documents relating to the Five Rivers Health Study has once again (as in discovery) simply been ignored.? 1/27/83 - Plaintiff Merrell's Summary Judgment Supplemental Memorandum On p. 5 Merrell states discussion of the results of this (1979 human health) study appear anywhere in the record of this case." At p. 8 he argues that the Five Rivers Health Study must be completed and the results analyzed. It appears from the above cited documents in the court- records that the Office of General Counsel was cognizant of, and in certain instances, developed. statements which would indicate that the results of the Five Rivers analyses were not available. In light of the September 22, 1981 letter from Gross to Fentiman, it would appear that OGC did not properly respond to Merrell's claims. It is known that Ms. Fentiman, both as a matter of philosphy and practicality, interpreted the discovery requests in the narrowest possible light. Sihce EPA records referred to "Five Rivers? and not the 'Siuslaw National it would appear that certain agency records where, therefore, not turned over to Merrell. In light of the repeated references to Five Rivers in Herrell's pleadings, hindsight would indicate this interpretation of Merrell's discovery request may have been unduly . 3v: restrictee. 12-7 -7- I recommend that appropriate language be included in the 'Conlon? report on Five Rivers to indicate that OGC did not fully respond to Herrell's discovery request and that the government made certain statements in its pleadings which were apparently incorrect. Attachment contains suggested wording for the 'Conlon" report regarding the issues addressed herein. Attachments EPA is a defendent in the case of Herrell v. Block, which involves a challenge under NEPA to the Forest Service herbicide spray program in the Siuslaw National Forest. As part of that litigation. the plaintiff. Paul Herrell. requested that EPA produce. through the discovery procedure. documents relating to a study or investigation of human health effects associated with the use of pesticides in the area of the Siuslaw National Forest. In several places in the pleadings. Hr. Herrell reiterated his request and also referenced his FOIA request (FOIA No. 213) regarding a study of human health effects related to pesticide use in the Five Rivers area. The discovery requests 1HLL2 were interpreted narrowly by the Office of General Counsel and. or as a result. certain documents relating to the results of the Five Rivers analyses of which the Office of General COunsel apparently was aware were not produced in response to Mr. Herrell' discovery requests. These documents were also not produceg? in to Mr. Merrell's FOIA request. Further. statements were made in the government's pleadings which would indicate that no further information was available beyond that _turned over to Mr. Herrell in response to his FOIA request. 12-8 . MEMORANDUM SUBJECT: Pesticides and the Dioxin Honitorinq Program TC: Steven Jellinek -s:istant Administrator For Posticides and Toxic Substances In responss to vcur reques we h~"e prepare? a status retort on an? rioxin I.onitorinc Program. From its furry ?*qinning, the mission of the Dioxin ?onitor'nc roqra MP) :1s to r?r.ve1op the -na.lvtical no thodcl coy "otnct :cri.ns in tho "arts per tr5.llion level. an? then follow +hnt .tvelopment with environmental monitoring studios r.csignce ro ?to :mount of euro-z-?ioxin ?ound in ?r.n rn? the as a result o? the 2395 of a 1% have :c?invsd this initial coal, with a number of stu?ios still in progress. Tho rcsults of many of these will to used in the be ?a nos. :rpcr?ix #1 lists some of these stueics which ore funded trrouch our rooparntivs agree mont with Wright State L'ni. ors1_ty 9r.? tho Univnrsity of ?obraska at a cost of $700 Vt also rocniv: support from the Toxicont Fna1.ys is C:nter. Cay Gt. Louis, PS cn? the Health Effects Pesoarch Laboratorv Trinnclo Ptrk, KC. Cur cooperative cc rcemonts rn? our in-houso support Fr: to and this fiscal ycar. tr 'ced some of un ortainty lities. ?t this moment, we arr nanooing a *unzn 1.c1ccso su t'dy, -?tsnoting to initiate a phcnoxv rnanol study 0? rmulatod 2.4.5-T and silvox procucts. and considering a study of ilvnx use in orchards. The human adipose tissue samples have been collected by the Survey and Analysis Division (SAD), but the funds for this stony will come from our current progrnn. The phenoxy phenol study has still to be cesiqnod. it may to ccn?ucted ry SAP at the Gulf South Research Institute, New Orleans. LA. He could no the silvex orchard stu?y but only at the of one of our current rrojects ?150, we do not ?ave nnouoh fnn?s to participate in *bu rhrnox' phenol. study. (D Fun?ing hav to our noni+nr5ng rosrons Dicxin Ccnt.mint ticn cf ?es in ?1 es and tfe Environnent We are also concerned with the presence of dioxins in other pesticides: RED identified 20 nesticices that may cents in dioxins. based on an analysis reflecting both the manufacturing {recesses and chemical structure 5 .ose nesticides. vs e111 establish nrier' tie for these suspect chemie ?1 on the basis of potential _or exposure and on tne basis of how nucb Suspect nesticice is used cac.. year. The DHP uoul? confirm the presence of dicxi ns in tnese pes ticides, a fact which would lend to nproprinte envi.ronmente1 monitoring studies in order to document the exposure - ssceieted with the uses of th. se ehemicn ls which contain dioxin. 1 this time, however, we do not have any funding for this import- responsibilit?. In the past, we have con?u ted dioxin analyses for recion .al offices {at no entree to them) in support of tneir r-ntorcenent activities veal: .nq with use and those dealing with rastrdous waste sites. The requests we receive for iicxin analysis in westc sites continue to increase. In tuis ins tree, we are concerned with the very high levels of ?ioxin we Inve 5 end in our of waste senples collected at Love Canal. NY, Jacksonville. ER. and Verona, 20. "e be lievc there exists a real potential for contanination of people end the envir nnent near these sites v.1cr will recuirr dioxin :nelyses 1n tr? narrs per trillion level. *5 we are to surport this activity in future, we will rcc? nd?itionnl fun?s not rarely to resnond to these ruquests but also to were leteretory inrrovercnt: -t our facilities to ensure the safe of these can nee rous and toxic In sedition to these needs for dioxin analyses a; we feel that some hing has to be done about the presence of chlorinated ritence-n-eioxins and ctlori nated dihenzof ure ns created during combustion. Cur experience with analyses of combustion product shows that these ?in?s of are complex because of the affinity of dioxins to perticuln tes, a. fact that makes the extraction nroces ses dilficult and tine-eons ,uminq. Th.se analyses are elso cemnlen because the iffersnt dioxin isomers that nay be nvneent in .-.- scmele must be sepnreted from each other. Turt terror-. in orter to ninpoint combustion plant which nay be generating Fioxins, it is necessary to analyze a large number of sennles to show that dioxins nre being emitted from the stack into the environment. it the same tine it is necessary to analyze these plant con?iticns which influence the production of these toxic -. 1L. -3- As you are aware, dioxins have been detected at a resource recovery plant at Hempstead, Long Island. In August the Office of Solid Waste and OPP will do an in-depth study of this plant to determine whether or not dioxins are created during the Operation of the incinerator and, if they are, whether or not those dioxins reach the atmosphere. Region is telling us that a similar problem may exist with a similar plant near Chicago. In that case, plant emissions are said to have killed the horses of a man who has also come down with chloracne. Region is investigating all these allegations. At this time, dioxins are only one of several suSpected causes for these adverse effects, but Region has requested that we perform dioxin analyses af er they rule out other possible causes. Unless we receive additional funding, we will not be able to honor their request for dioxin analysis. It also appears that PCB incinera- tors may.be responsible for the creation of dioxins and dibenzofurans. Strengthening EPA's Dioxin Monitoring Program A. EPA Funding of Dioxin Program ?is in the Agency' 5 best. interest to continue to fund the dioxin monitoring program to the point that it could make a positive? contribution in the identification and analysis of dioxins in pesti- cides, hazardous waste sites, and incinerators. These analyses are o.plex and may be hazardous. As such, they certainly are beyond the scope of most contractors. I believe that this in-house program could do the work cheaper and better than any outside contractor. In $5 B. light of this fact, I recommend that this program receive about million for a period of five years. OPP Current Dioxin Funding Requirements The Office of Pesticide Programs needs a minimum of $875, 000 to maintain an effective dioxin monitoring program* during fiscal years 1981 and 1982: PURPOSE TOTAL RPAR Hearing Support $175,000 $175,000 Methods Development 250,000 $250,000 500,000 Laboratory Equipment 100.000 100.000 200,000 TOTAL $525,000 $350,000 $875,000 it Appendix $2 liscs all those Studies which are either underway*gr scheduled to be completed sometime during this year or so. Projection will be done at a later date. i? To conclude CPP's dioxin monitoring requirements and responsibilities are increasing because dioxin contamination of pesticides and the environment is also increasing. It seems that we will have to establish levels of tolerable exposure for people end the nnVironnent from products which nither contain dioxins or substances like dibensofurens which are structurally similar to dioxins. In this context we need to develop standards for tve higher-level dioxin ccmrounds like the hexa?, herte-, end octe? ?icsins because some of these isomers are carcinogenic. We need to refine our analytical netho?olocy for Oibnnsofurens because these substances are related to dioxins and H"ey nay -0. be contaminants to some restici?os, though we ?now virtually :11 1 nothing a: ut this subject yet. we estimate that $500,009 would suffice to suprort tre development of methods for ?ioxin isomers and dibnntofursn analyses ?urinq and ?oreovor, sediticnnl l: oratory eouirment will be necessary to speed up the analysis of dioxin samples. inprox metely $90,000 will be needed . i to buy intermediate instruments uch as licuid chronetoornnh and a capillary column ges nhrometoqrenh i. order to ioprove the quality of analysis for ?ioxin enc ?ibenzogurnn sanoles. toother will be necessary in order to buy glossvern ens safety equipment for Bay St. Louis Laboratory. Finally, +rerc?s need to work closely with the Survey and Rnolysis Division {fit} 0? FPII one rte Eiorin Berk Crown (which res OPP, FPII, end CRD centers) to cotermine: the feasibility of neetins our needs within Lhe present funding constraints projected by the end bonnet and fb) the requirements that can be satisfied by :ar {versus using internal OPP capabilities). Tn nssenev, 'e expect to refine our requirements eve further one regetiote prioritias based on huocet restrictions. Edwin L. Johnson Deputy Assistant ??ministretor for Pestici?e Attachment cc: Division Directors H. Conlon D. Loncmirc Chlosta Z. ?ellianatos A. Ponner H. 31. Yet: tdz?-ln-RO .upuszL amcru mo ncu?umu .Hri. - on+ b?rsw p4 ucqu4 n4 uurpmmucuue4 an Too: moau.. rm cman mo :um a .w?mw 4mnr.u:tu HM Tcpuou ?cpuc mam nu: Ernuawp m0 m::L4+c Lm vauUm mma numb .cr cowumcucd Ilamoan?uu umm Capone? EcnerLb . 4%Hun u. coHuoam?c How ma? mu .omuu use we 4umr whSmOLxm c? uu4.4uc:lm an wanna >0Au moow can"; Hun? .u mmonu mmsuuon Muuhamcwlou can mmuUrLuxulcr o? ommL4 ?may cmumuUHU. .Quuv mo cucumunu ax? pom bun 4pc Ut4nUa1u. munc?mm ouv?u .UouhannL unauw CUFF 4H .cz communuunnuhunuu ?zu?uwach .hbr\duLL hp mouh?mcrou nuacu our mcaaumm m1b . .mHHU?thw ~O4HunthJuHHuw map ?nu? MHJO .Uhf mxu c.+4 m0 occ ccnw.r .430 uucv mum?wmc at Lzuhn wn?nwmuccu m. I. . mczpo>rw .nmuu uc ?nonunm nxu Lumz kuusmqou $szn av .CL LOwumLUlelnuuchh uwcumowmv hv:;u uccn I?l- m- 0:4 maaEmP acuvucwmm. Ha c:L.0-T. .4:on .2 .r .44 nur:wnm umwwu; bf occm cco? mom>acuu 04n. 0E .w?mn?u mmouwwn cm nuuv mo mmuwuu cdnucou Op tuuou amen wpuL buhpn unapom mo co?Uah an? Cw unmaLuMOL (cu. mw.m?m: .OL nuJu.u owor?um may warm (1 fl umwn?umux mxu ?w uLoan use Du nuanwuuccu ?My: Lu?rL nunw unannou?w nc?munuu Wvuum Junk .xuor czu muuau?uu nu ummho cu muom. LL Tums mam:an 30m a b?uu .>m3uovu2 bubon?u nun Saws: mom05p44 m0 co?uumamnu muons mm?h untuumc: bim4u.w u.hULcuu mo 4Lcunsw L.. .g4L Cahown H4 '0 .m>excou m.Cume ?0.3 mcsum nzo?pmuu 0+ umHHEwm .02 u_:u s2ur. >u2uo. coocuo v.1- snug; Hugucnuom UcwuLaduur uw .oucvaOLEH mo CL Haw: maowunp cw mnt>m . Duct or+ mu smog c>mr muuomuo Uaxcu .unob m0 unaosn c3ocx w: muuncw?mucou am?? a :mu ax m?m?wnn ?wank .Cwmcuumwa m0 hu?muobaca cLu um avaad mo?dh ?oum uw>wmuou coma aha; mmHnEum hunnp m" .03 n.anH?~ wwsuu wanna; aamccum .ha:o Emu Emu. umxu .2th? .3. can Eoum Luau ?non mnu 0? km rHa?an hmr+2 mw m?z? %msvu inn ?u wu .uoucb Cw numb no nan .uanEUUqunhuc. ancu unmu van Amannu .anmhmuu ma- we +h.um um cmuar uwc comm mp?: new? we huc.3+ ch .ucocmcuu wc coupnc>un .qum3 m0 mca. S. .02 c. mu mutuaunww. mu.. vl . . ouunIIALbOQc 02 ?a n.nmm?sou .o?srmnun cc 30c mm %Upuq w.u out) cm h?uum on? Lu?3 uEanouu manna ouom .cowuuo CH n.0uu warp Eonm ocuvmn?ou pkg: .m HaunuELoun>cu cuaawaa2 tar ?uCcEamom .pCpm3 msowuc2 QHLE L0: hr; >1num he uho?m wH .02 Ilhcsum H4 mnnxa - .wc>ao>u? rum nobw? can ?mm (can dn on >kum?4x0Hmun .huoumnonma vacuum um mwmhawc . xulhrmaou on umcc mm .umm n? Luv? ?0 "mm? uu cbaquOI 05+ :3oru abmn m.0hm?lca? oru cu sum uw-uu Lunch no new nHuEwcm ?oum coxmu oijdm mom ITJ .WQ. D: In ?4 mucwumcm Elm.?.m m?u ou unououcH m0 .l LJ I udy Region II r?ques --rccr551cn 11 Those are from t?9 are: around 6, Leo: Island ?nor- an incinerator burning Hunicipa] vastn is sand to b0 Eioxins int the atn.osnbern. Coho: ffv?ir ?ot Likely to ?avg an Trro?iato T-rro* on ?native: Rncion ion lo. 4 Some 1? :amrles (watvr and sediment) ?awn ?leccfad in ccnnec tic-n with a? incident in the Region. T?osn :.re scrorhzled ior analysis in July. "on .ntcni VI ?0 "achnical Crave Fosticiie inrlnois Reavc for accooaicn F0. 22 3 number of other testici?cs in :n?ition ?o ?of :ilvnx noul? possibl; contain =nd other ?icy1rc. 1":0 brann ccllocto?. from rito rt? bur-1""- urn-1m? (so-callc? P=rn Site mkich are t.?cucht to co tain dioxins. ?nrion need: to know or rot Ricxins are in?en? yroeent Eofcrp precan?ing vitb This is "+h9 other Verona" case. :.1arge container of was a. hn2vily contaminated by was ?old by Ehc company 1:0: hang y=rrs. Two analysis. Tre compan" -o initiate a in toxificPt tion process which will lend to a?dit ional samples. Pasta Exposure analyses (Region four 5333135 fro scheduled for rnalyzis. LLborztorv nfl-J-cs .grnp to. 27 Two samples vill ho "~od ?y July. STUDIEI COHPLIJID Appendix '2 Dionin Monitoring Reguirenenta in 9 atates I Type [Application I Data Source I Honitoringl Sa-pie I Start I Completion I Geographic I Expected I I I I Type I Site I Date Date I are. Use I Hu-an I Silven reniduea I Human Monitoring I Ambient I MK I I 1977 Nationwide I I euponura I in human urine I Network I Study I I I I I PD-I I Human I Silver reaiduea I Boiia Monitoring I Ambient I I NR I 1977 I Nationwide I Erna I expo-ura I in agricultural I Network I Study will Innvironlentail TCP teaiduea in I Boila Honitoring I Ambient I I UK I 1977 I laboratory I HPAR Ifata I environmental I Network I Study I I I I analyaia I PDmus-r I run Market none: I Special I m: I NR I 1977 I Nationwide I eupoaure I residuea in food I study I study I I I I I Human I I Hu-an Monitoring I Ambient I I I 1977 I Varioua I RPAR I expo-are I reaiduea in hu-anl Network I study I I I I hot apots I I I urine lIu-an 2.1.54! I Soiln Honitoring Ambient I NR I 1977 I Various I expoaure I reaiduea on rica,l Hetuorl I Study I I I I hot spot. I I I corn. and sugarcane aoilariceland 2.4.54! Air Monitoring I Ambient I MK I m: I 1977 I Varioua I arm I Sampling I reaiduea in air I Netvork I Study I I I I hot spot! I rn I Type I Application I Data Source I Monitoringl Sample I Start I Completion I Geographic I Expected I I I I Type I Sire I Date I Date I Area I Use I Seawater. I foreat areaa nearI NED . I Speciai' I 20 I 11/78 I van I Alaska. I I water, I Alana. Oregon I Dioain Monitoring Study I I I Oregon I Hearing I uiidiile I I Program I I I I I I Support I I I Contract laba Environ- I leaiduea in soil I "an I Special I 23 I 5/79 I 3/00 I Hiaconlln I man I Dental fate I I Diorin Monitoring I Study I I I I I Hearing -I I I Pl?quaDrinking hunter and eedilaentI . - I Special I 39 I 1/79 I 3/80 I All?l. I I water land areal-e near I Di'oain Monitoring I Study I I I I Oregon I Hearing I Oregon I Program I I I I I I Support I Mus-an IVietnaI I Veterana I Special I 40 I 6/79 I 2/91. I Nationwide I I adipoae Iveterane I Achiniatration I Study I I I I Hearing I Hunt 59312? I Hus-an niih Iliu-ana realding I I Ambient II 103 I "/77 I 4/81; I Cali!ornia,l I Inear loraata I Regional Officea I Special I I I Completedl Oregon. I Hearing I I I Contract laba I Study I I I I HuhingtonJ Support Ill-5h I names Ana-n1 ea- I Cattle grating onl sun/op" Ambient 5 6! I 4/79 5/90 I Kanlal, I am: I [Insure I paeturelnnd I Regional Critical I Special I I I I Missouri. I "eating I road-dietaryl I Contract I Study I I I I Oklaho-a, Support Water, aedi-I Edible (lab in I mp Special I 'n 1/79 I mum-n. I up? I bent. I ricaiand area. I Contract laba I Study I I I I I Hearing I aealile I I SlbloPli I I I I I I Support I lnviron- I Deer and ell I Region 3 I Special I 25 I 10/78 I 5/8: I Dream". I I Dental late -I grazing on I I Study I I I I ?aalnington I Hearing I I treated foraatSupport 0/ I TYPO I I Data Source I Sample I Start I Coupletlon I Geographic I I I I I Type I Site I Date I Date I Area I Use I Sea nu I Catfish In con- I Contract laba Special I so 3/79 I 5/60 I Hints-Inn? I Dietary I Hneasent va. I I. Study I I I I Arkansas I Ilearln? STUDIES I Elpolure I cattlah SUPPOH I I treated ricelandaI Pathological I FTP I Special I 40 I 1/80 I 5/80 I Laboratory I I "pa-sure I atudy o! 11:00 In I Dioxin Honltoring I Study I I I I Analysis I "eating .I I laboratory I Progral - I.. I I I I of Sun-plea I 1" I I limiters Ila-an I Pathological I RIP I SpecIal I I I 5/30 I I I tI'llmiaura I atudy of row in I Dloxln monitoring I Study I I I I analysis I "eating I I pregnant atonlteya I PrograSanplea I Support I I and off- -a?rln9 Che-[cal I Analyala for rcnol I Speclal I I I I Spot checkal I Milly!? I content In Ionnell SPA laboratory I Study I I 6/80 I 9/81. I 0! Inhaler-?Che-loll I Analyala for TCIDI I Special I I I I South-rice I I Analyala I content In lrbon I EPA Laboratory I Study I 40 I 12/79 I 5/arena I Support I Hui-an I Preaence of I I Speclal I I I I laboratol'l' I I adipoae I realduea I SAID I Study I St- I 4/80 I 5/36 I AMIYSII I I tlaaue Samplea I Support I Ilulan I uaera I lit. Sinal I Special I 56 I 10/93 I I I I adipoaa I far- vorkera I nedlcal Center I Study I I I I I ranqtl??d I "ear-II?! I tlaaue I In ranqeland Support I I Iran Sea life I Crayllah. catflahl Univ. of Nabraaka I Special I 20 I I 3/81 I Louialana I I Dietary I Iedibla, aeafoo-dII I Study expoaure Spray drift I Foreat. I Unlv. of ?ebraaka I Special I 40 I 80/3? I 3/81 I Southueat I I ot-ny. rice I um I Study I I I I US Hearing I I i'lelda and rangeSupport Dioaln I Dioain caabuatlonl Univ. of Hebraaha I Special I 40 I 10/90 I 3/81 I I . I co-buatlon I producta I I Study I I I I I Hearing . SumDietary I Apple 5 prune I I Special I I I I I I axpoaura I orchard. near I Univ. of Hebraaka I Study I 50 I Ill/ll. I 3/3! I 05 I "eating I I treated areal Support I Type I Application I Data Source I Sample I Start I Conpletion I Geographic I Expected I I I I Type sue I Date Date I hrea Um: I worker I TCP TCDO oer-all Contractor and/or I Special I 6/80 I 1/81 I Cooling I RPAR I expoaure I and lphalation I IPA Laboratory I Study I I I I tavern, I Hearing I atudy I affecta paper I Support I I workers I II I deter-inedl I I sills. tan-I I I cooling towerneries. andl I 0 Pulp pap" I I I I I uachlne I nuolrs ahopa I tanneries machine ahopa Chemical I Reaiduea of I Contractor and I Special I To be I 6/80 I 1/81 I Samples IIOI I I Analysia I in leather iron I EPA Laboratory Study I determinedI I I leather I I I from tanneries I I I I I tanneriea I I Che-lcal I Residues of I Contractor and I Special I To be I 6/80 I I Samples Iron I RPAR I ?nely-la I 1cm in paper I an Laboratory Study I determiner-II I pulp and I pn?zn I I Pulp and Piper MllChe-ical I Analysis for TCDDI EPA Laboratory I Special I To be I 9/80 I 4/81 I Spot checha I RPAR I Analyaia I content in I I Study I deter-inedI I I of nanuiac- I Hearing I I hesachlorophene I I I I I I turers I Support I lnvironRPAR I Iental fate I Sugarcane fields I Univ. of Hebraaha Special I 25 I 10/8b I 7/81 I Southwest I Hearing I I near treated I I Study I I I I vs I Support I I areas Dloain I Presence of I Univ of Nebraaha I Special I 200 I 1/81 I I Laboratory I Methods I Combustion I dloxina in I ?right State Univ-I Study I I I I Analysis I develop- I I combustion Sample: I went I Iprodurtl Tech Grade I Preaence of I St. Louis I Special I Sto I 1/81 I HI I Nationwide I Methods I I dloaina in I Univ. of Nebraska I Study I I I I I developwent I aanufacturing wright State Univ.I I. (4) run. CC: '2 Dioxins from Resource Recovery and Waste Combustion . To emphasize the importance of analytic accuracy and quality control in the sampling work OSW is planning to conduct on this subject. Don Barnes. Walt Kovelick and I will meet with Ple'nn/Dietrich to discuss the "stakes" for both the OTS and OSW programs. Following that, Barnes will prepare a memorandum recommending no further sampling for dioxins without an approved (by CDWG) Agency protocol for sampling from incineration and resouce recovery facilities. If necessary, you will approach Chris Beck. . For the August 6 TSPC meeting, the need for $1.5 million to support the dioxin combustion study will be discussed. This money will be in addition to the HOD-500.000 required for Hempstead. Reinforcement of Role of Chlorinated Dioxin Work Group . Don Barnes will proceed to finalize the memorandum from you to the Regional Administrators describing both the availability ?of the DMP for analytic work and the requirement for accurate sampling protocols (acceptable to the DMP) prior to taking samples. The issue of regional participation in funding such efforts will be raised. . A potential TSPC discussion item is the allocation by program offices to the Regional programs of sufficient funds to pay a share of the dioxin study design and analysis costs. Analyses would be coordinated through the DMP. Don Barnes Marty Helper _Paul Lapsley Toby Clark