NEWS ON TOXICS AND DEFECTS LEAKING SOLVENT TANK IN THE SILICON VALLEY CAUSES TRIPLING OF BIRTH DEFECTS reported in the last newsletter on the study of birth defects in Woburn, Massachusetts caused by solvents in the drinking water from a toxic waste dump. Another case of solvent produced birth defects involving ground water contam? ination has developed in the Silicon Valley. A leaking storage tank of the Fairchild Camera Company released the solvent TCA (1,1,1 trichloroethane) into the ground water. Families using the wells contaminated with TCA experienced a doubling of miscarriages and a three time increase in birth defects. _1.oso. Birth defects General populahon I Moments-mint? at" a! San Jose Los Panes '_9.059. Show horn an.? luck-dad pfn'gtuncrs boom dunno I900 and 19m Heart defects were particularly noted. aboratory studies show that heart efects are produced in animal an exposed to TCA during pregnancy. or a copy of the findings of the .ifornia study, you would want to te the address below and request, egnancy Outcomes in Santa Clara ty, 1980?1982, Summaries of Two emiological Studies'? Calif. Dept. of Health Services 2151 Berkeley Way erkeley, California 94704 San Francisco Examiner, Jan. Z7, 1985 The Silicon Valley Toxics Coalition is a citizens group working on the issue and also on right to know ordinances: 361 Willow, Suite 3, San Jose, California, 95110. SPERMICIDE MAY CAUSE BIRTH DEFECTS In January, a federal court judge ruled that the widely used spermicide contraceptive Ortho-Gynol Contraceptive Jelly caused a birth defect in a 3 year old girl, and ordered a $5.1 million settlement. Experts testified that the gel damaged the sperm without killing it. Washington Post, Jan. 24, 1985 THE NATIONAL NETWORK PETITIONS THE PESTICIDE TEMIK We have been busy. On December 20, 1984, the National Network petitioned the outgoing administrator of E.P.A., William RUckelshaus for an emergency public health action to remove the pesticide Temik (aldicarb) from the market while it was being tested. This Union Carbide pesticide is the most acutely toxic poison ever register? ed by E.P.A., and has leached into the ground Water in numerous states- The laboratory studies indicate that Temik, like some other chemicals of the same family, will bioaccumulate in the brain of the fetus to levels higher than that of the mother animals, and cause noticeable changes in brain chemistry. The Environmental Protection Agency maintains that pesticide in the brain of the fetus is a harmless thing, and poses no health problem. For copies of the petition and the reply we received back, drOp us a note. The State of Rhode Island has banned the use of Temik, and Wisconsin is in the process of doing the same. The manufacturer has agreed to voluntarily suSpend sales on Long Island. THE NRDC PETITION ON FARM ANTIBIOTICS In the September 6, 1984, issue of the New England Journal of Medicine, a clear case of salmonella poisoning with an antibiotic resistant strain of 18 people in three states was linked to farm use of antibiotics to fatten farm animals. Scientists for many years have been concerned that the farm use of antibio? tics commonly used in medicine for human disease might lead to antibiotic resistant bacteria. This resistant bacteria could cause illnesses in people that would be very difficult to treat. The National Network signed onto a petition developed by the Natural Res? ources Defense Council in November 1984, to Margaret Heckler, Secretary of the Department of Health and Human Services. The petition asked for a ban on the use of penicillin and tetracyclines in animal feeds. THE SALTY REMARKS OF RACHEL CARSON IN SILENT SPRING, 1962 "The 'control of nature' is a phrase conceived in arrogance, born of the Neanderthal age of biology and philoso- phy, when it was supposed that nature exists for the convenience of man. The concepts and practicies of applied entomology for the most part date from that Stone Age of science. It is our alarming misfortune that so primitive a science has armed itself with the most modern and terrible weapons, and that in turning them against the insects it has also turned them against the earth." National Network To Prevent Birth Defects Mail Address: Box 15309, Southeast Station, Washington, D.C. 200 Office Address: 530 - 7th St. S.E., Telephone: (202) 543~5450 There may be some legislation on the subject in the future, and we will keep you in touch. You may want to drop a short note to Secretary Heckler, asking her to ban penicillin and tetracyclines in animal feeds. Secretary Margaret Heckler U.S. Department of Health and Human Services Hubert Humphrey Building, Rm. 200 Independence Ave. s.w. Washington, D.C. 20201 BHOPAL, INDIA REVISITED nited Nations officials, who interview- ed the cloth merchants in Bhopal who had distributed shrouds for the dead, have a much higher estimate of the numbers who died. Based upon the num? ber of shrouds sold, they estimate that between seven and ten thousand people lost their lives because of the MIC gas leak at the Union Carbide plant. One question that comes to mind is why the American press_stopped counting at 2,000 dead? How To Join State and Local Groups 5 Individuals 5 National Headquarters of National Groups ,Sf For larger donations that; heed to be tax'deductgp write your check to the: Health and Energy I?sqf and send to same addrES Washington, D.C. 20003 Suits forgdamages against Superfund? WASHINGTON (UPI) -- Two congressmen today introduced a bill to allow people injured by haz- ardous wastes to sue for damages and to recover medical costs and some lost wages from the EPA's Sits-billion Superfund. The bill. introduced by Reps. Edward J. Markey. D-Mass.. and James J. Florio. D-NJ., would per? mit federal suits against owners and operators of dumps and against transporters of toxic wastes if people are harmed by substances being treated. stored or buried. Current law permits spending or Superfund money only for cleaning up hazardous waste sites and to compensate for some prop- erty loss involving damage to nat- ural resources "The problem of hazardous substance contamination affects more than just property." Markey Dow agrees to let U.S. test soil at its plant for dioxin. Page C3. said. ?Hazardous substances hurt people. people who through not fault of their own come into con- tact with these dangerous sub- stances. ?People are made ill. ren- dered unable to work. in some cases they may even die, but they cannot receive a penny under Su- perfund." he said. Markey said victims of hazard- ous waste contamination at Times Beach. Mo., and at Love Canal near Niagara Falls. N.Y., would be eligible for aid ?if they can show continued exposure beyond the passage of this legislation." He predicted Congress would 30. SUPIHSUIT A2 SUPERSUIT FRO. A 1 approve the bill ?by the end of this year." Markey said "unknown num- bers of victims" could be helped by this bill" adding that in Wo- burn, Mass. "families have exper- an hiah int-i- would ?provide the business com munity an incentive for industry to come forward with better ways to dispose of toxic wastes.? "We want to induce industry to get off the philosophy that says land-based disposal of hazardous wastes is good.? he said. The bill would extend the fund to cover claims by those injured trimaran": substances Fees SHOE 191%wa 5? [If L523 431:352: 1-. Water consumption threat cited at conference on Great Lakes KALAMAZOO (UPI) Water consumption by neighboring states and provinces poses a far greater threat to the future of the Great Lakes than diversion to Western states. participants at a water diversion con- ference were told. The ?ve Great Lakes Huron. Ontario, Michigan, Erie and Superior form the world?s largest inland waterway. Frank Kudrna, chairman of the Great Lakes Com- mission. said Thursday a recently released study by a U.S-Canadian research organization found consump- tion of lake water would increase from the 4,900 cubic feet per second in 1975 to 37,000 cubic feet per second in 2035. That rate would draw down the level of the lakes sufficiently to threaten navigation and production of electrical power. Kudrna said. resulting in a "net eco- nomic loss well in excess of $200 million annually" to the region. . The consumption problem is so great. Kudrna said. that careful management is necessary just to have enough water for the Great Lakes states and Canadian provinces. Other speakers at the two-day conference. spon- sored by Western Michigan University. discussed the high costs of diverting water and the need for states and provinces bordering the lakes to plan for preserva- tion of that resource. David Harrison. director of the Northeast-Midwest Institute. an organization funded by foundations in 18 member states. said there is a danger the upper Mid- west could become so preoccupied with preventing di- version that development of a proper management plan could take a back seat. ?There is no question water will play a dominant role in shaping the economic growth of the region in the year 2000 and beyond." he said. We must pro- tect it with the pride and care we would use if it was oil.? Harrison. once an aide to former Michigan Gov. William G. Milliken, said Great Lakes states should begin pressuring the federal government to spend more money for preservation and purification of the lakes. Several congressmen from states represented in the Northeast-Midwest Institute have been upset with Reagan administration officials. Harrison said, be cause the president's "cabinet secretaries don?t seem to realize the Great Lakes are a special resource." The need for a special management plan to govern the use of Great Lakes water was emphasized by Har- vey Banks. a California engineer who directed a million federal study into the possible diverson of wa- ter from rivers in Missouri and Arkansas into neighbor- ing Plains states. That study found diversion to be too expensive. he said. making any large-scale diversion plan impracti- cal until the latter part of the next century. it then. Seven of 11 freed in Ala. incident l?n o?t'nf\ R?an?T?f??l nf pnnriar. Mich- and Worrie Dow chief denies dioxin health threat in Midland MIDLAND (UPI) Dow Chemical Co. President Paul F. Oreffice. in his first public comment on the dioxin controversy. denies dioxin contamination is responsible for health problems in the Midland area. in a letter to Dow?s 144.000 stockholders re- leased by the company Thursday. Oreffice said. "First and foremost. there is no health problem in Midland. Oreffice cited recent Environmental Pro- tection Agency data indicating that Midland County cancer death rates for both men and women are not significantly different from those of the U.S. population as a whole. and they haven't been for the past 30 years. ?It is alleged that health problems are trace- able to the existence of dioxin compounds in the Midland environment. Those allegations are false." Oreffice said. Of the dioxin amounts found in water sam- ples from the Tlttabawasee River. Orefi?ice told stockholders: ?Our Midland plant takes in, uses. treats and discharges about 9 billion gallons of water per year. The amount of dioxin contaminants the EPA claim to have found (50 parts per quadril- lion) in that 9 billion gallons is less than 20 drops per year." Meanwhile. the Detroit Free Press reported today that a state permit issued to Dow allowed the firm to increase by 17 times its discharge of four suspected cancer-causing chemicals into the Tittabawassee. - The state Department of Natural Resources and the Michigan Water Resources Commis- ?slon. in approving a new wastewater discharge permit for Dow, accepted such a move as a permissible health risk. the Free Press said. Dow says it has not increased its discharge and does not plan to. The state says it has. for the first time. set specific limits on toxic water pollutants. Howev- er. environmentalists counter that the state should not allow any company the authority to increase its discharge of suspected carcino~ gens. . The chemicals involved are carbon tetra- chloride. chloroform. tetrachloroethyiene and 2.4.6-trichlorophenol. All four. allegedly used at Dow's Midland plant. have been linked to can- cer in laboratory animals and suspected in hu- mans. The 1982 permit authorized Dow to dis- charge more than 81.000 pounds of the four chemicals a year. When Dow applied for the permit. it reported discharging 4.800 pounds a year. Tittabawassee fish ruled unsafe FISH. from Page 1A diluted by then and that only fish caught in the Tittabawassee should be avoided. Adamltus said several forms of dioxin were found in Dow?s ef?uent and in caged fish placed in the river belbw the plant's wastewater outlet. "This included the most toxic form of the. compound 2.3.7.8-tetracholoro-di- benzo-p-dioxin." he said. The study. which began in 1981. showed the highly toxic form of dioxin at levels of 50 parts per quadrillion in the? effluent, and at levels of 100 parts per. trillion in whole fish. The US. Food and Drug Adminstra- tion has established 50 parts per trillion as the danger" level of dioxin in edible portions of fish. Because the EPA study was done on whole fish not fillets - its results are not directly comparable to FDA standards. said Adamkus. ADAMKUS TOLD a news confer- ence there was ?great concern" over the accumulative effect that dioxin might be having on the environment. ?It's going to become the ticking bomb for human beings if it is accumu- lated over years and years." he said; ?We?re trying to prevent this type of tragedy in a decade or two." Complete results of the EPA study will not be ready until summer. The study was undertaken. Adam- kus said. to establish the source of dioxin contamination in the river and to help Michigan of?cials in developing a revised wastewater discharge permit forniw. Dow is temporarily operating under-a permit that expired in 1979. Officials at the Michigan Depart- mentiof Natural Resources said last week the results of the EPA study. which is only 25 percent complete. may serve as the basis of a lawsuit against Dow to stop dioxin pollution of the Zittabawassee. BAY PORT (UPI) The federal Food and Drug Adminstration has gathered 150 pounds of fish from Saginaw Bay to test for dioxin con- tamination. and commercial fisher- men in this Thumb community said Thursday they?re delighted. Several commercial fishermen said they are confident the tests will reas- sure customers that Saginaw Bay fish . are safe to eat. An FDA inspector gathered 150 pounds of carp. suckers and catfish Wednesday for an analysis expected DOW SPOKESMAN Al Wolf said the company would not comment on the EPA findings until it had studied the report. "We have not received a copy of the report. so we're not familiar with those findings." Wolf said. Dow has not permitted environmen- tal authorities to enter the plant for testing. A company spokeswoman. Lisa Swank. recently confirmed that Dow had rejected EPA requests for access to the plant?s grounds. She said the com- had we rated in off-premises ests on its eff uent. She said access to a holding pond on the plant site "exceeds their legal au- thority and exceeds their needs for the objective of regulating." ADAMKUS SAID the EPA is anx- ious to review further information on effluent from Dow. which provided the EPA with its own data on effluent content. Adamkus said the report cited only 90 pecent of what was in the effluent and that the remaining 10 percent was ?crucial.? The EPA sued Dow in January for more i' 'prmation about its operations. Bay fishermen welcome EPA dioxin tests to be completed tumor to six weeks. said Alan fleeting. director of the agency?s Detroit district. The FDA took the samples after newspaper reports that dioxin levels in some fish taken from Saginaw Bay exceeded FDA limits of 50 parts per trillion. Although some samples showed dioxin levels in carp up to 94 parts per officials have said those levels-occurred in whole fish and not in fillets. on which FDA guidelines re based. The Clean Water Act requires waste- water dischargers to use the ?best available technology" that is ?economi- cally achievable" by July 1. 1987. The agency said that to establish this. details must be obtained about the wastes produced by each of the plant's processes. before any pollutants are diluted. DIOXIN Is a highly poisonous. thetic waste by-product created during production of herbicides and pesticides. It has caused cancer and birth defects in test animals. but its long-term effects on humans are unclear. Dow has maintained that dioxin comes from many sources. including combustion at coal-burning power plants and from automobiles. But a 1981 EPA report concluded that Dow "has extensively contaminat- ed their facility with (dioxin) and has been the primary contributor to con- tamination of the Tittabawassee and Saginaw rivers and Lake Huron." The conclusions were ordered stricken from the final report by EPA headquarters in Washington. according to Autmkus. 94/193 0 Fl" Consumers who have read recent news stories about dioxin contamination in ?sh probably would like to know how much contamination is really dangerous. Well. you can take your pick: The Food and Drug Administration says a dioxin level of 50 parts per trillion in fish is safe. Two years ago. the FDA said 100 parts per trillion was a safe level. But the state of New York says that regular consumption of fish containing more than 10 parts per trillion of dioxin is dangerous. The Province of Ontario says its safety level is 20 parts per trillion. And scientists at the federal Environmental Pro- tection Agency suggest that even one part per trillion is unsafe if an individual insists on a 'no-risk' exposure. None of these conflicting safety standards is based on human studies because dioxin's long-tenn effects in humans are unknown. But this contami- nant of pesticides causes cancer. birth defects, and death in animals at extraordinarily low concentra- tions. and scientists are worried about human expo- sure. THE CREATION of safety standards that predate understanding of human effects is a well-known phenomenon at such agencies as the FDA. which has standards for several poorly understood contami- nants in fish. including PCB. PBB. mercury, and DDT. The bewildered consumer of fish might wonder how agencies arrive at exposure levels of safety and danger in such circumstances and how different agencies can arrive at different conclusions about what is safe. Estimates of the safety and risk for these contam- inants are much shakier than. for example. the risk estimates associated with smoking. The estimate that a two-pack-a-day smoker runs a 15 to 25 times greater risk of lung cancer than a nonsmoker is based on actual observation of cancer and death rates among smokers and nonsmokers. 0n the other hand. the risk estimates for dioxin. PCBs. and other toxins are based on animal studies. statistical projections and best guesses. The esti- mates may take into account not only scientific factors but also economic and practical consider- ations that may differ from agency to agency. For example. the. FDA calculated human health dangers from dioxin in a fairly straightforward manner. Agency scientists took the dose of dioxin that showed no effect on rats. and translated it on a pound-for-pound basis to a human dose. Then they diluted that dose several times to provide an added margin of safety. Using fish consumption levels in the U.S.. they suggested an upper safety limit of 100 parts per A safe dioxin level for fish? trillion for dioxin in fish. In July 1981. citing ?continuing concern" for population groups that ate large quantities of highly-contaminated fish. the FDA dropped the suggested limit to 50 parts per trillion. The agency also recommended that resi- dents of areas with dioxin contamination of 25 to 50 parts per trillion should eat fish no more than once or twice a month. EPA CALCULATIONS began with the same rat studies that the FDA used. But EPA extrapolations to humans were based on a much more elaborate mathematical model. Using this model. EPA re- searchers calculated the cancer risk for a person who eats a half pound of dioxin-contaminated fish every week over a lifetime. If that fish were contaminated with 100 parts per trillion of dioxin. the cancer risk would be 1 in 100. the EPA report concluded. If the dioxin level were 10 parts per trillion. the risk would be I in 1.000. And a person who wanted to limit the cancer risk to in a million would be restricted to less than two pounds of dioxin-contaminated fish in an entire lifetime even if the fish had only one part per trillion of dioxin. A major caveat: the EPA formula errs on the side of safety. Because their study was designed to find all possible risk. the researchers can be sure that the cancer risks of dioxin are no greater than their report concludes: but the risks could be much smaller. 50. for example. while the risk of eating fish with 100 parts per trillion of dioxin is almost certainly no greater than one in 100. it might be much less. ON THE other hand. EPA scientists argue that the FDA model is flawed because it assumes that. below a certain level. dioxin has no effect on animal or human health. But EPA researchers insist that cancer-causing agents such as dioxin - are net absolutely safe at any level. Even minuscule doses will produce an effect in some portion of a popula- tion. if the population tested is large enough. they argue. Until we know the true effects on humans of dioxin. PCB. PBB. DDT. mercury. and other chemi- cals. current standards are the best scientists can do. And they are intended only as guidelines. What they mean is that each of us must decide. individually. how much fresh water fish. and what kinds. to eat. .- .- . ?wa- Dow accused of landfill use violation Booth Ilene Service MIDLAND State environ- mental officials say the Dow Chemical Co. was aware its hazard- ous waste landfill near Midland was leaking. but did not immediately stop dumping there as required by law. In a related development, Attor- ney General Frank J. Kelley called a meeting'of top state and federal environmental officals today to as- sess the extent of Michigan?s dioxin problem. Officials invited include U.S. Rep. Donald Albosta. D-Mich., who has proposed creating a com- mittee to monitor progress made in research on dioxin contamination near the Dow plant. Dow Chemical managers alleg- edly knew about the seepage prob- lems for at least two days and possibly as much as three weeks prior to reporting it. according to a spokesman for the Michigan De- partment of Natural Resources. The company could face civil penalties of up to $10,000 for each day it violated the permit. said John Shauver, chief of the DNR's hazardous wastes litigation section. "We believe the duration (of the problem) was much longer than Dow reported. They had notice long before they reported it, and they continued to use the landfill after they found out." Shauver said. Dow officials could not be reached for comment. The attorney general has or- dered Dow to stop dumping wastes into the landfill until the company can guarantee safe operation. The state learned of the prob- lem March 23. when Dow reported that contaminated water had leaked into the ?clean zone." an area of sand underneath the land- fill. Company employees periodical- ly test water from the ?clean zone" to make sure the clay liner has kept the contamination from seeping into the groundwater. But a pipe that pumped contaminants out of the landfill leaked some of the liq- uid into the clean zone. Dow now is flushing out the sand with water. so that it once again will be a reliable indicator of potential leaks. Until then. the land- fill will remain closed. said John Bohunsky. a DNR hazardous waste expert. The company is required to test water from the clean zone and report the results to the DNR. The last clean samples were report- ed to the DNR Feb. 28. In Dow Chemical furor EPA plans new dioxin study Continued from Page 1A The state Public Health Depart? ment plans to study the possible link between dioxin and reportedly high rates of cancer and birth defects in Midland County. Hernandez pledged ?to pull togeth- er whatever resources are needed" for the study, after meeting yesterday with Michigan of?cials in the office of Rep. Donald Albosta, a St. Charles Democrat whose district includes Dow?s Midland facilities. Also present were Dr. Howard Tanner, director of the DNR, and Rosemary Freeman, a Washington representative of Gov. James Blanchard. ALBOSTA SAID the study could cost over $1 million in its first year, though an aide said later that ?we might be able to do it for as little as $500,000.? At the meeting, a source said, Tan- ner told Hernandez that the project might cost $3 million altogether, including $2,011,000 for tests of fish in Saginaw Bay and its tributaries and $985,000 for tests of soil and air in the Midland area. Albosta said federal and state of?- cials would meet within two weeks to develop a plan for the study and he hopes for ?some de?nitive results? within a year. ,?The important thing is to develop a base of accurate scientific data that tells us the extent of the problem and what type of a cleanup, if any, may be needed,? he said. After the closed-door meeting, Her- nandez said in an interview, ?It is clear we have to move quickly to respond to concerns of people in Michigan and to restore their confidence in the integ- rity of the OFFICIALS IN the regional office in Chicago have accused Hernandez of exerting pres- sure on them to delete parts of a 1981 dioxin report that blamed Dow for much of the dioxin pollution in the Lake Huron and Saginaw Bay areas. EPA report in ?81 urged fishing ban in Great Lakes WASHINGTON (UPI) EPA officials urged in a 1981 draft re- port that fishing in the Great Lakes be banned because of dioxin con- tamination. but the federal govern- ment did little to discourage fish- ing, agency officials say. Regional Environmental Pro- tection Agency officials in Chicago recommended in the report in the spring of 1981 that Great Lakes fishing be stopped because the po- tential cancer risks were too high. sources said. But scientists at the agency's headquarters along with former assistant administrator John Tod- hunter eliminated the reference. agreeing that the decision should be left to the Food and Drug Ad- ministration. the sources said. Agency officials sharply criti- cized the resulting FDA standard that concludes there is negligible health risk to people who eat a weekly meal of fish contaminated with dioxin at levels of 25 parts per trillion or less. and minimal risk to those who eat fish once a week at levels under 50 parts per trillion. EPA scientists projected. in a 1981 assessment. that those people face a cancer risk ranging from i in 100 to 1 in 1.000 from ingestion of the chemical, minute amounts of which have caused cancer in labo- ratory animals. ONE OFFICIAL familiar with the assessment termed the project- ed risks ?incredibly high.? although acknowledging lt was not quite as high as the health threat faced by people exposed to dioxin in parts of Missouri. The 1981 EPA assessment. a copy of which was obtained by United Press International. was prepared by Donald Barnes and Paul Brown. co-chairmen of EPA's Chlorinated Dioxins Working Group. It noted the FDA "has informal- ly pointed to 100 parts per trillion as a ?level of concern'? a level that would pose a cancer risk of 1 in 100. Sanford Miller. director of the FDA's Bureau of Foods. acknowl- edged that the FDA eventually de- cided dioxin levels of 50 parts per trillion or higher were too danger- ous for human consumption lev- els still higher than those recom- mended by EPA scientists. Miller questioned the validity of risk assessments. noting they 8.. REPORT - A2 1 ?slum-n cue. uni; dqi limit? ?ll it) sisters 3m mg ?tiOii n?wm em: new :nniinnri?v REPORT COHTIIUID FROM A1 were extrapolations from findings of dioxin's effects on animals. but said he would generally not quarrel with EPA's calculations model. "That's a very high level of risk. no question about it." he said of the l-in-loo to range. MILLER STRESSED that the federal government has no author- ity to ban fishing in state waters. but he said the FDA has banned fish sale in interstate commerce of Special Sections in today?s home delivered Flint Journal. HAMADY KESSEL INSERTS: MEIJER PERRY DRUG Circulation Dept 767-0670 Advertising Dept 767-0660 fish are taken from contaminated as. He said the FDA has urged gov- ernors of Michigan and other states bordering the Great Lakes to ban fishing in areas where dioxin levels of 50 parts per trillion or higher are detected. Both commercial and game fishing. particularly species that feed on the bottom where dioxin collects in sediment. has been halt- ed by state governments in a num- ber of areas because fish ?were found to have a high level of dioxin for some time." he said. FLINT 200 - 3001 200 E. hm 51nd Flint. Michigan 433502 Published Daily and Sunday telephone 767% I983 Booth Second clan postage F?nl. Mach. Delivered by carrier per delivery $7.75 per mouth. 01! mm and where no carrier is available. $87.00 per year. $45.25 lot in MI, 523.00 hr three months. 57.75 per month. By mail oumde Michigan. 38.25 per mm. Sunday delivery only, $5.00 per M. 87 mod to military I, $8793 per your. All mail payable in advent-ice. Guard Omen in Grand Rapids O. Box 2168 ah Hm Of?ces Washington 5% 1750 Penniytvoma NAN . Suite 1320 Lemma 1501 Bank of tau-no balding Amino omen Sou?rhlleld, 437 One Non?land Drive Bldg. 3 . H.900 Wu! Eight Mile Road New York Len-W Air-nu! Chicago 221 H. 51nd Atlanta .0540 Poi-en Ferry Road. NW. Los Angelo} . Wilil'wl Blvd. 1 San Frwiuo 703 Mel Sir-d Penman-r. il undelivered. pious- md ion-n 3579 In The Flint Journal. 200 Fiul sir-d. Flint. Mi. ?8502. I . I Where did It! I WhereYou look ter I You look 20 I A size 10 . . . I No sagging I Unbelievablc GRANI SF In Celebr: Trent Receh Wt: Control pollution? . no? . Ml econnm'~ -;vneratu~a arr and water pullo- Wastea. rn't'L?pnltunnl ll' :tlent-a and disease. ilnd mme un? ~.lte t-unyumer product:. A nf emplm men! 'he neulth. safety and 'll s?mt'e their mceptmn mu ner-n tor he- .nu .lnl?t?hpn?SlVE. and mr too much and delt- t-rtng mo little. No one mould be deluded ?nto that personnel .tt EPA ?Ill mite these problems. The mom that u'htle =1-mger lurks everywhere. at no- where very great. Potlutton :n the hr. the water and tn the enttron- ment generally increases dtseuse risks. Including cancer Yet rarely et er are the risks enough to uncntute an emergency For ex- eyen nt Love Funul. expo ?re In 2111:: slew of ha?tfduuh ?uh- some: would be ea-ttmateu .n reuse .tletlme cancer inCtdEnt?E or. perhapsl percent I DO NOT MEAN to counter;- '?tue concerns. but rather to pro- a rough of the proo- COMMENTARY faced. Life styles. tncludang ~mo-t1ng nouns 'and met. have 'a ?turn greater effect on dtsease ones. Including cancer. than cur- rent '1 at most regutalton tnltes place r. t'rts'ts atmosphere where decr- muyt he made Immedtalett. M'nnut .tdequate tnye'stt- -atlnn These problem; not ms- ;kot'dr the Indus-[not ~ortety of our ;r.:nucml..lren will present the mm of f't??lts and glye rue to 41-: name concerns. The haste elements of a ?Olutmn be None 15 early ac- but no can emerge thnout adore?:- .nl: them. one first step and by far 'he most Important Is :1 'ton of goals. It ts to make the ethronrnenl DYISIIDE or reduce enwronmental 1'le :0 zero. Stattng unrealistic goals. such as all discharges the moon's waterways by 1955. Is -a rumor source of current problem? It encourages the ortentatton. ~nort-term Mes to longvterm prob- lems and controntatton. smce eon. are dtssattshed "all a loaf and see no :totnt tn steps toward on on reachable gonl. Just what does seetety deitre? How much are we to up :0 enhance enytronrnental qualny? Survey data Show that the vast matortty of the puhttc ?up. ports environmental goals. but not. presumably. at the cost of a large reductton In standards The publtc needs to be better tntormed about what would he gamed by each proposal and what It would cost. 0A second Step ts to away from and confronta- non more generally (use: rcuutre tmmedlate actton wmle perma- nent problems: requlre planntn: .mo EPA mut-l det'e'inD an agenda and pursue 't veg-trougly Let?s clarify goals -r not-mt Ulorlt A Hep u- to unprote- the -- of dell lat-Ir. A. - ?f'la: my vnlle..e-e. and urgunttel?; ?tnlr to the th:tl [tn-re .tlntus?t no - ?wr . ;rrenl henlth Enl Hint-l1 all- llte n.tt'tre of tutu untrn for Then how awn that - :nn-t rw rutmntet: H- utwuer 'Il'ln? am! the? tin hum Hold :?ntll llr? Inar. t?nnt?l'p For actentut: tznn' the regulatory proves-y and ~hun Its rnuen-and-tumblo .tt- mmphere The resulttne reeutn- mm are often and antr. tt-rmett. and mentors-v: :hle Iltey nre t'mtlt and l-anl thetr goals. pot-tam till-M 'tl.t..-tton ut ?nib. ulbett 'Mth J'll The them- ~el=e< run he analyzed and deer- ~tn madc- truth a ytew to when uncertatnttes mil he re- mtyetl The haste ol EPA t?nn ne Improved utthnut .mpructahle Increase: tn resources ur t't?ldl' IThe luurth step t4 tmproynd tmplemenrotton The problem 2-0 large and regulatory procedures 50 that the EPA cannot o-w-mhly protect the whole enytrun- 51?.nt moot Lulu} new .?hen?ltcan are Introduced each year. to 'he tn common use, H31 the HM reeulnte more than run or three dozen new chemtcalr: 1 ?Pat \?unregulatnn mecnamam~ are needed for standards and Before the at EPA comp-antea- relted on auton- Honduras set ny Indu?trtes and proteysmnul awn-tattoos. The cnr~ ,mrntu consctence plus the of and ?lawn: promoted ?xtder-oread l? 'yoluntar'. ?tandurdg. EPA ENFORCEMENT of HS ?mourns 1.4 hampered by the small numher of Its tnspectors and by burdensome court procedures Sub- economtc Incentives for 19' enforcement. where catastro- phe ts. not threatened. could tn't- pmye enforcement There are EPA success stones Fur example. chlorobenztlate was regulated by EPA In a proceedtne 'hdl woe ulttmatety to all This poses an:- mm. to workers, but l5 lnl- to rttrus growers Rather than some hold mote trite nanntne the \L-hihlanl'E. EPA caretully oe- lmed the uses where chlorobenzr tale no.5 no use exen there. and specufted how worker?s- were to be protected The lesson :5 that faring an to a prohlem. carefully reytewtng the evidence and .ttl pame~ rm nroduce good solu- tions. eyen to difltcult problems Lilli! Live is I prof-5:0! ol' economics and public policy a! Cam-gt. Dalton lame-4911's gradual. animal of 7h. Post i i m? Dioxins: Suspected, 3, 12 but unconvicted, killer . By Hugh 31?ch manufacturing plants were not the only ll Nun StarrWr-ttu source of dioxins. which was generally us- - . stoned; they are also produced by many Dioxins rank high as the moat poisonous combustion processes. of more than four million chemical com? . I ?l pounds kno?nmman. THE DOW STUDY was the compa~ . There are approximately 75 dioxins. ny's response to state and lederal charges They cause birth defects and cancer in that Dow's herbicide-manufacturing plant . laboratory animals particularly rats. in Midland had contaminated the nearby and scientists intuitively suspect them of Titubawaasee River with dioxins. being hazardous to humans. However. he- According to Dr. Aust. the Dow scientiL cause of their extreme toxicity. no scientif- ic investi atiun which supported the report . ically controlled human experiments can commsn the respect of environmental be humanely conducted to document the scientists. The report cited the following suspicion. sources for dioxins: the opera- 1' "The best we can do_" any: biochemist tion of gasoline and diesel engines. rigsret Steven D. Amt, mm, dinner nf smoking and ?replaces. refuse incinerators. Michigan State University?s Center for chemical-tar burners. fossil-fueled power Toxicology. "is study diox- plants. automobile muf?ers and charcoal- in accidents to humans. suc as the one in brmled steaks. Seveso. ltaly. in l976.? As Robert R. Bomb. research director of The more lethal of the dioxin com- Dow's Midland Division. put it at the time pounds are the tetra-chloro~dibenzo-diox- "19 made public: "We WW ins Several are present think dreams have been With us since the as byproducts produced in the advent 0f ?fe- manufacture of the 2.4.5-1? herbicide used BUMB CQNTENDED that the inves- AgentOrange. tigation had 'completely exonerated the . company's Waste-discharge system design- i THE MOST LETHAL a tetra- ed to prevent dioxins from map-n: from i or sans-Two. the plant . . which has the appearance of small. clear. The fear dim-Ins damn; . needleliie it is present in Agent mm mm experiments on animals and Orange. A dose uf this dioxin weighing from the complaints of Vietnam war serv- one-hillionth of an animal?s body weight is tcemen. . suf?cienttoltill it. do not know the complete mech- . in a loo-pound human. this would be antsm milCUlDKYui' Aust..who i8 the equivalent to two-millionths of an 315? 0? the 0mm stances Control Commission. Autopsies on . The US. Army used Agent Orange dur- experimental animals inn?ed With TCDD ing the Vietnam war to strip away leaves 5h? the" '5 a_ 9'09?" "l FD Which and vegetation from the enemy's hiding the TCDD "Eddy bmd" ll? "913m" ?h 3 places. In the process. many soldiers from ?1rd thde . both sides came into contact with Agent . to Aust. "mm? range Orange. The Department of Defense ended widely Wale" tolerance to the a; the defoliant in Vietnam in are sensitive and some are relatively resist- 1970. Since then, many former semcernen ?The guinea 50" example. is who fought. in that war have complained of sensitive.? he 333?!- "The ?It ll 198! sensi- a wide of il edl assOCi ted with Aged? armada alleg y. a "The key questions is: Where does man . [it into the high range of variables? In I, WAS THE KILLER dioxin In. Aliment most of the studies on these kinds of com I Orange 2.3.7.3-TCDD pounds. man appears to be like the rat. As yet. scientists have not been able to ?The chances of people being immune to prove or disprove the association. it are very rare." The ?rst concentrated study at dioxins BEFORE AN animal dies of TCDIJ in the United States bertan shout to years poisoning. continues Dr. Aust. it experi- ?180 ?he? ??1?le 0? ?56039!" blo? ences a ?terrific" loss in weight. "lt?s call? chemist Dr. Allan Poland investigated ed the wanting They refuse to their effects on animals. About the same eat; and even if they are fed. they do not time. Dow Chemical Co. began studies nf thrive." the toxicological effects of TCDD. Related Also. the thymus gland. which processes studies on the dioxin family of Compounds cells used by the animal?s immunological also went on at the National institutes of system, dries up. and the animal develops Health during this period. skin sores. I Dioxin research moved forward stanifi- The long~term view. says Dr.. Aust. is cantly in 1973 following 3 Dow Chemical that TCDD contamination "promotes" Co. study which found that herhicide- cancer. . ., ?l Eli-:1" Ilia- a? . furTheuD and tha hyatermtomiea 1n the we en. 1 can sit 0188611?! ?anywhere. Lass of toe n?d finger nail: and hair 10$? regulgr occurrences af rashes and boil like eruptsond elieve toxro ambatancea produce 319118? aymptoms.fot the moqt part. Becauae of our individual gepotic makeup anq phys1ca1:,gh ?f the weakest argaa are attacked differently; as thejb dy atlemptn tb ?1d 1taelf of the foreihn material., The ouncera.? tumor?. kidney removals, spleen apekationa. enlarged livers and -neart cond1t1ona are all too common. Host reaidents that move 'away the area hav; a general Health a. t; .r .I ..- e+a?w. Two specified areas were selected In the area in an adultiOhul attempt to show-what health problems are occurring. Out of a total'of 127 hbmea. the'reaidenta are known in 50, Of those b0 homes. the lieted ailments have been noted ou?the accompanying chart. A 5" Tho 53mg procedure waegfoliowed on Sangrtugc Dr1ve.z strret 1n the vlg?hge totaling 19 namea ?lth {l?fgasceutg or: {311111 1 95 known{gag-3.351? -: .., 3:13:93. 739?s, far-M; 1:2 . a. ':The analyt30a1 data by tho various atate agencie33'the ;'ug ,Lgi material ro'r manna, ma?gdditiomxl,? . I I gag! research material and tho,pea1th recorda_nnd ailments oi the - 3.2 - area residents reveal my investigation to the present datEi? -ut-H .-.- - .July 1 1979 . 33..?19. 1 -p?5 ??359, @33- 'a?t a 4: 3?1-2-7212: .5 :22: 1' 1.. A uni-E :5 - 3 J. 15:" - in a I >131'?i??fztixfz s? 5 Egg-ff?" 3; 2' r: ?ii? Iiv?I-iltma?; 1th?32a'in121Jay: 5 aha-3.33al-v 3. Eu.? .i ?v 9.. - .- 151%?) To whom it may concern: I 1231*." L3 RE ?313. 30 THEIR ISL-11113 has been in the DCWE every day lat elv. uhy are chemicals btzried up to I mist) Heep on the mo following pieces of pro1;- 'and members 01 the families always sicld? West of the nest of the East 01 East of the Northwest of tiection 14, 13 North, Zienge 2 ereper Township3 ?1 100 1. Shepherd no.1 'Jc?t? H32) 1.7- v: (D :3 13., :31" .1?lnnd County, N13 hi{.a11. Commencing 20 role East of South corner, ?keno Hort 3 #0 rod-, T?3ence Last 30 r0331 thence South 40 rods, therce Nest 20 rode to place of ?eri?ninn (five ac:es) Section 10, ?orth, Range 2 We Jasper Township Ld?an Cou1*1;y, Iiciiren. (4280 Shepherd Rd. 1 would Sign this but it miqht cost me my wwm? -1 .. C-J job. Dozer operatcr=-1ho isonld know of this night be able to give YOU more in1ot-metioh, include: Kenneth Lhellev, Norm 1nne1,Nue.e Gushin. Jim Hard~ Luther Carter ui=l PHOTO Part of crowd hearing Times Beach buy-out details Hitch develops in buy-out of contaminated town EUREKA. Mo. (UPI) Offi- cials said Saturday a buy-out of dioxin-contaminated Times Beach might be delayed by a dispute be- tween the state and federal govern- ments over which level of govern- ment would then own the property. However. an administrator of the Federal Emergency Manage- ment Agency tried to reassure 400 people. who gathered at the Eureka Junior High School. to hear plans for the largest government buy-out ever for environmental reasons. "Think positive thoughts," said regional FEMA administrator Pat- rick Breheny. ?Don't think nega- tive thoughts. We'll get this thing worked out." Breheny told Times Beach resi- dents the government wants to of- fer them a ?fair market value" based on the worth of their proper- ty before ?ood waters from the Meramec River inundated the town in early December. He added that the Environmen- tal Protection Agency. within days. was to make its recommendations for cleaning up dioxin contamina- tion at Times Beach. where the deadly chemical was sprayed on streets in the 19705 to control dust The town is one of 27 known dioxin sites in Missouri. summer but he is uncertain when the purchases would be completed. FEMA will offer to buy the property of all Times Beach resi- dents who want to move. Breheny said. Breheny said that in addition to selling their Times Beach property to the government. each family could receive up to $15,000 in relo- cation assistance. OThe Superfund law is ?devel- oping" regulations to deal with dis- posal of dioxin. The Clean Air Act is assessing potential problems with airborne dioxin. OThe Toxic Substances Control Act establishes further rules for control of dioxin. In addition. the Food and Drug Administration has set limitations on dioxin levels in Great Lakes fish. THE CLEANUP of contaminat- ed sites is costly, perhaps prohibi- tively so. So far. the average cost of cleanup of a site ranges from $5 million to $35 million. Estimates range from $200 bil- lion to $250 billion to clean up known hazardous waste sites in the United States. The Superfund has allocated only $1.5 billion for this purpose. In water supplies. there may be no way to- clean up dioxin con- taminants. "Dioxin does not degrade in groundwater. where it is cold and there is no sunlight." Epstein said. "There are 35 gallons of aquifers and of these. it is estimat- ed that 1 percent are already con- laminated.? Epstein recommended banning dioxin in all its forms. placing an extremely high user tax on any company that makes substances of which dioxin is a contaminant or byproduct and placing ?the strictest of controls" on any dioxin disposal. One proposal is to place dioxin contaminants in underground con. crete containers for at least 100 years until technology can find a way to deal with them. The buy-out plan requires state approval. Gov. Christopher 5. Bond has said he will sign this week a bill approved by the Legislature to allo- cate Missouri?s 10 percent share - $3.3 million of the $33 million . federal purchase. The appropriation measure stip- ulates the state will own the Times Beach property only if all residents sell. A few townspeople say they want to stay. and legislators fear their presence might leave Missou- ri open to health-related suits from the dioxin contamination. ?It?s a problem. but not an insur- mountable problem." Breheny said. "l'm not ascribing any bad motives to the state. He said if the agreement with the state were worked out immedi- ately. FEMA could start offering to buy Times Beach homes by mid- D4 SUNDAY. MAY 1.1983 - THE FLINT JOURNAL FDA chief won?t be prosecuted f6r making on Uncle? time (UPI) The Justice Department says it will not prosecute the Food and Drug Ad- rriinistration chief for accepting speech lees while on government business. ?But it says his actions showed "insensitivity" to appearances. FDA Commissioner Arthur Hull Hayes has been under investigation since Feb. 9 by the Health and Hu- man Services Departments inspec- general for gifts he allegedly ac- cepted from trade. corporate and cat groups and for alleged mis- his government car. it a letter to the inspector gen- . Office. Frederick Motz. .- 'c?dtiorney for Maryland. said he intend to prosecute Hayes. . Ihougn two of the speech tees arguably.? be unlawful. ording to Metzs I ?Miter the cluded 82.250 in spe?'tCh 1885. ?ging. travel on corporate . ft and smoked chicken. . i; said of eight allegations ex- ed. in two caries ?his conduct Ebe deemed to constitute the ?uranium Arthur Hull Hayes receipt of unlawful gratuities as well as unlawful supplementation of his government salary." in both cases. Hayes was on gov- ernment business. the letter said. FDA rules allow Hayes to deliver personal Speeches as long as they do not create a conflict of interest. The two disputed occasions Dune-nun? wear: A $250 lee Hayes received for two speeches delivered Jan. 1982. to a joint meeting of the Col- lege of Physicians and the Greater Philadelphia Committee for Medi- cal-Pharmaceutical Sciences 0A $500 gift for a May 29. 1982. commencement speech at vania State University. which Hayes later returned. "Despite the fact that Dr. Hayes' acceptance of the honoraria in question may arguably be unlaw- ful. i do not believe that criminal prosecution is warranted." Motz wrote. Motz said the fees were "mod- est." There is no indication the money was paid to in?uence Hayes? actions. and although Hayes' con- duct is "troublesome." he probably did not knowingly and wilfully vio- late the law. Motz said. But he added. ?It appears to me that Dr. Hayes has shown an insen- sitivity to the principle that govern- ment employees must scrupulo ly avoid the appearance of my ety in their dealings with th lic." Residue of Ch emicals in Meat Leads to Debate on Hazards By MARIAN BURROS toxic chemicals may be present in this country's meat supply, according to the Food and Drug Administration. But how much of a danger this presents to humans is debatable. in part because only 60 residues are monitored by the Government and in part becameoi di- verging opinions on the possible haz- ards. Someoithechemicalsinquestionan fed to or injected into animals to stimu- late growth and prevent disease. and some are ingested accidentally. Many scientists. as well as environ- mental and consumer groups. content! that residues of these chemicals accu- mulate in humans and can evenmally cause serious illnesses. Others, how- ever. including a number of of?cials for the Government's regulatory agencies. saythatthere isnohardscienti?cevi- dencethatanyonehas beenhannedby them. Precisely which residues can be . found in any particular piece of meat. however. is not clear because the United States Department of Agricul- ture monitors so few of them. It does . not. for example. check for residues of such hazardous chemicals as ethylene .- bisdithiocarbamate (EBDC). hirazoll- done or polybrominated biphenyl (PBB). which are suspected of causing cancer orbirthdetects. Nor does it test for dioxin. a contami- nant of the herbicides 2.4.5.-T and Sil- vex. Dioxin is not among them because. the department says. the cost of testing for it -- 81.000 to 81.500 a sample -- is prohibitive. However, the Agriculture Depart- ment has begun a surveillance program Continuation Page 9. Column INSIDE US. Plans Inquiry on Barbie The Justice Department said it would study charges that the American Gov- ernment helped the Gestapo official ?ee to Bolivia after the war. Page 4. GM. Reopens a Plant Nearly 2.000 workers regained their jobs as a General Motors plant in Framingham. Mass. resumed pro- duction. Page 8. Armand New York ..12 Editorials" Arotmd the Nation. 8 Education "'17 18 Mound the World.. 5 Obituaries 21 Art .-..22 Op-Ed .27 Books ..23 Science Times .17-20 Business Day.. .3946 Style 2.8 .23 Television .21 Crossword .23 Theaters .22 ..23 Washington Talk. .10 Day by Day 13 Weather. News Summary and index. Page 2 Classi?ed Ads mam Exchange. Page 41 Chemicals in Nation ?3 Supplies of Meat Lead to a Debate on Possible Hazards Continued Front Page I in conjunrtion with the Food and Drug Administration of several Missouri farms where livestock may have been exposed to dioxin. So for their tests on two animals have not turned up any dioxin residues. Traces of dies in did turn up in several earlier (?mvenunent-sponmred studios of cattle in four Middle Western and Southwestern Staten. hoovever. In one of those studies. conducted in 1978 for the Environmental Protection Agency. traces of dioxin were found in a total of four of 68 cattle from Texas. Oklahoma. Missouri and Kansas that had grazed on range land sprayed with 2.4.5.1. The fat in those four animals contained between 20 and 63 parts per trillion. Doses of dioxin ?5 low as 1.5 per trillion have caused birth de- in the of monkeys. Dmpite a call from the General Ac- counting Offlce in 1979 for more exten- sive sampling for chemical residues in meat. a request from the Caner Admin? istration for more funds in 1930 and an appropriation from Congress that our to conduct more tests. the Agri ture Department under the Reagan Admitt- istration has chosen to spend the money elsewhere. Approximately 20.000 daem- lcal residue samples have been taken for each of the last four years from the 4.4 billion animals that are slaughtered yearly under Federal inspection. Residues Above Tolerances While the Food and Drug Administra? tion says that 'here may be residues from 500 or 600 chemicals in meat. the . General Accountinf Office has said 143 chemicals are like to leave ralduu above the tolerance levels set by the Government. Of those. 42 are suspected of causing cancer. 20 are suspected of causing birth defects. and six. are sus- pected of causing mutations. Lack of funds and effective testin methods are the reasons some critics the Agriculture Department believe that the possible lurards from these chemicals pose an increasingly serious threat to this country's meat supply. In 1932. {7.000 residue samples 3.000 less than lheprevious year?were taken. The budget for such tests was less than $3 million. the same as It has 1979. Testif rig before Congress at a 1N0 budget tearing. Dr. Donald Hallstatt. the administrator of the Agriculture Department's Food Safety and Inspec- tion Service. said that to increase mati- roring to 20 times the present rate would cost an estimated an million. ?This option appears unrealistic when viewed against our present budg- et." Dr. liottston said. ?but may turn out to be cost effective when viewed from the total Governmentwide budget for cotrtroillng toxic substances and the Government and private costs associ- ated with a contamination lrtciden Money blurted Elsewhere in 190 Congress appropriated $1.5 million for the residue testing program. but the was not used for that pur- pose. inst . the Agriculture rt- ment diverted the money to an - use of animal drugs, to improvement of the department's lama-Fency res system after acclden chem] cori- umination and to the department's timing methods. Today Dr. Houston prefers educa farmers to testing their livestock try. ?Elf we can do a better job of educat- ing them we mightbeable tnfurtbarre- duce residue testing." be said in a re- cent interview. Critics of the depart- ment say that teaching farmers bow to prevent contamination of livestock with chemical residues at illegal levels is useful but that without hicreaaed moni- toring the education program is mean- lngleea. Scientists have argued for over the effects of toxic chemlca 3. On one sldaare umwbo cite labontoryatud- cancer and birth defects in annuals. that humans do not react in the same way to toxic substances: in fact. they contend brooms may even be more smitlve than the laboratory animals. ?they also cite epidemiological evi- dence that brunaua suffer illnesses and diseases to time hand In labo- ratory arrimals when espmed to the some chemicals such as diorrtn and gy?bmminated blpherryl. as A 1970 General Accotu'tt port entitled "Problems in the Marketing of Raw Meat and Pottitry Containing Potentially Handful Red- dues" stated that "there Is on We carcinogen." 0am. some of them hi the Govern- ment's regulatory agertcles and unity of them In the meat industry. argue that there is no proof that the acctunulatlon of chemical residues In the body is harmful. and that became a substance camconcerinanlmalsdoes not mean It will camecancerinhumam?'hey say there is no scientifically sound evi- dence linking Ingestion of the chemicals Office re- found in the meat supply with disease. Beside. argue. if there were no tolerance leve for such tlcides as DDT and both which have been'baruted but are still widespread in the environment. there would be much less meat available for the public. Tolerance for Residues The Environmental Protection Agen- cy. which has jurisdiction over pesti- cides. and the Food and Drug Adminis- tration, which is responsible for the safety of drugs. have set tolerance levels for some chemical residues in meat and poultry. These levels are indi- cated by maximum amounts In parts per million of a toxic chemical that is rmitted in food. The tolerance level or P33 in meat is 0.3 parts per million. to Albert Meyerbolf. an at- 'torney with the National Resources De- fame Council. a public-interest law firm specializing in environmental cases. data on which to base these toler? ances. particularly for suspected car- . ?is often lrradequate and sketchy." According to the General Accounting Office. tolerance levels are sometimes established not because It has been scienti?cally determined that the levels are safe. but became there is no cer- tainty that the substance causes cancer. or became the residues of the substance are unavoidable since they are persist. like DDT. Dr. John Spaulding. director of the residue evaluation and planning divi- sion of the Food Safety and inspection Service. disagrees. "Data on safety tolerances." hesaid. "are quite exhaus. live. They are mutually upgraded." Some of the chemicals legally used in animals are drugs that make them grow more rapidly; some are drugs ad- ministered to combat certain diseases. waof thebestknownof thmeare the penicillin and tetracycline. There is scientific evidence that the in- creased preaeocd of these antibiotics in meat diminishes their effectiveness in human. who can build up a resistance totbem. Chemicalstotroducedinl-?eed Other chemicals sometimes found in meat are introduced accidentally. Ani- mals may pick up environmental con- taminants from the water they drink and from foraging or grating. The 2.4.5- T. In which dioxin Is found. ls used to kill undesirable vegetation on range lands. Occasionally. chemicals are inad- vertently added to animal feedfThal is how the wides read contamination of many food debt with PBR in Michi- gan in 1973 an the P88 was acci- dentally to feed for dairy cows. Thousands of farm animals either died or had to be destroyed. and many Michigan farm familes with P38 in their systems experienced serious medical problems such as damage to their bodies' immune systems. because PBB Is ubiquitous. farm ant. mals continue to die. and in a 1970 study by a Mount Sinai Medical School team, an estimated 97 percent of state's resi- dents had the chemical ln their bodies. Toxic chemicals have become more alent since theend of World War ll. of critics of the Department of Agri? culture say the department?s chemical residuemonitoring rogram has not kept up with the prob em. Cami Tucker Foreman was an Assist- ant Secrets of Agriculture from 1077 to use. Her utlas included supervision of the residue-monitoring program. She says the agency's effort to murmur harmful residum has never been good and is getting worse. "There is a good chance that the American public consumes meat with vlolative levels of can: attic and teratogenic chemical rust ues with some regularity." Mrs. Foreman said last August In Congressional testimony. In a recent Interview. she explained that the residue program is not de- signed to keep unsafe meat from reach- ing the public. "It merely monitors the Incidence of violations and tries to pre- vent recurrences." she contended. With the exception of some new and quicker tests for checking residues. Mrs. Foreman said. ?nothing has hap- have always made the assumption that we were missing a good part of the she sat . Changing List of Chemicals Accordl to Dr. the de- partment sages the residues moni- tored each year. A scientific group from the Agriculture Department, the Envi- ronmental Protection Agency and the Food and Dru Administration deter- mines which it: micals will be morti- lured based on such criteria as the rela- tive toxicity of the chemical and previ- (ll-B history of violations. Dr. Spaulding admits that the sam- pling sluts small. but hesaid. "It ismt critical when you are just sampling to see what Is ing on in the population." He said ter. "If you add up the violation rate for all species. the total is 8.2 percent." Both Mrs. Foreman and Rodney Leonard, who was in charge of the Agri- rulture Department's inspection serv- ice from 190? to [088. as well assume of- ?cials in the department. disagree: "They need much more intensive sam- ing." Mr. Leonard said. "so they where the most severe problems are." One problem frequently cited to the timing of residue tests: they are per- formed when the animal is slaughtered. However. by the time test mulls for most chemicals are evaluated. the meat has passed into and most likely has already been cortsumed. The exception is a test for antibiotics: it can be evaluated within l8 hours. l?Aidan Is morehe . than: for anima '3 tot origin. soifharm residues start .a checkcannotbemadetoseelfother animals from thesamesource alsocon- lain illegal levels of the chemical. But Dr. says the quick test for antibiotic residues. which was irrati- tuted in 1979. and the Reagan tration?s emphasis on educating time who raise livestock and poultry have dons. The incidence of illegal sulfa resi- dues in swinedropped from mild. percent between 1971 and 198:. he so . On the other hand. the new measures have had no a reciable effect on the illegal levels sulfa residue in very young calves. according to Joseph Set- tepani of the F.D.A.'s Bureau of Veteri- nary Medicine. "The levels of sulfa in calves sent to slaughter is extraordi- The permissible level Is one-tenth of a rt per million. he said. "and we are hiding 100 parts. In a sense. however. the overall statistics are meaningless. according to the General Accounting Office. became the Agriculture Department's practice of changing the list of residues it sam- plu each year. The department also changes the number of each species of animal tested and has now changed its department recently Instituted a joint residue testing program with the pounry industry. In exchange for the in- duct '8 assumption of rcepomtblily to test or residues before slaughter, the department has agreed not to issue a press release when accidental contami- nation occurs. as it used to do. Such in- dustry-generated data are not Included in the department's residue violation figures. Dr. Spaulding desc?bes the program as "cooperative." Mrs. Foreman calls It "collusion." - Efforts by the Food and Drug Admin- istration, Which is responsible for the safety and efficacy of animal drugs. to ban some of the drugs that present'seri- hazards to humans have met with Since 1077 the F.D.A. has tried to ban two drugs commonly used to stimulate animal growth?penicillin and tetracy- cline because most agree that their use makes bacteria in humans resistant to the drugs. A report on antibiotic-resistant salmonella in The New England Journal of Medicine last summer no the theory. But Congress pla a moratorium on the ban while further studies are being con- ducted. Another Proposed Ban For the last to years the F.D.A. has been to ban another class of ant. mal- promoters. nitrofurans. are potmtcarcinogena. The Agriculture Department does not monitor nltrohlran residues because there are no tests for them. After the F.D.A.'s last attempt for a ban. five years :30. a United States District Court 1 go Instructed the agency to re- study the problem. It is now considered likely that the agency will follow the lead of many other countries and ban the use of nitmfurans before the end of theyear. The Environmental Protection Agency is proposing another chemical. toxaphene. be came It causes liver problems and may be a carcinogen. The one use that would still be permitted is as a dip to prevent scabies in cattle. Even if the Government expanded its residue-sampling program an on liltely prospect in the current Adminis- tration critics contend that the most important problem of residues would still not be addressed: assessing the hazards of the chemicals and their metabolites. which are the components of the dremlcals that remain after they breakdown. According to Joseph Rodriclrs. for- mer F.D.A. deaut associate commis- sioner for heal a fairs and now a pit vale consultant on toxic substances. ?one of the big problems with animal drugs Is that even when the Govern ment is monitoring the drugs, it is not monitoring the metabolites." Dr. Lester Crawford. director of F.D.A.'s Bureau of Veterinary Medi- cine. says the situation is ?pretty scary" became the metabolites "may do awful things: we know so little about them." Mrs. Foreman said. "With residues the Government makes the assumption that amount of meat each year will be contaminated. They don't make a pro tense of preventing meat from going on with residues in It.? - Benefit Of the dOUbt Adminstration gives chemicals edge in questions of cancer causes By FELICITY EARRING-ER The Poet WASHINGTON Since President Rea- gan took office. federal regulators repeat- edly have refused to tighten restrictions on known cancercausing substances In the air. water. work places and dumping grounds of America. Many of these decisions are prelimi- nary. But the Reagan regulators have de- nied almost all requests for immediate ac- tion. and have let existing proposals for ac- tion linger while they review the evidence. In effect. the administration has given chemicals the benefit of the doubt. AMONG RECENT decisions about chemicals Identified as carcinogenic. or cancer-causing. by the Health and Human Services Department's National Toxicol- ogy Program: OThe Environmental Protection Agen- cy (EPA) refused to give priority status to regulation of formaldehyde as a toxic sub- stance. instead the agency has allocated $283,000 for a research information clearinghouse and a workshop of scientific experts. industry officials challenge the as- sertion that formaldehyde Is a human car- cinogen. About 28 million people living near chemical plants are exposed to low doses of it. The EPA Is developing emission standards on organic chemicals. including formaldehyde. .The Occupational Safety and Health Administration (OSHA) also refused a re- quwt for emergency regulation of formal- dehyde. to which 1.3 million workers are exposed. The Consumer Product Safety Commission did vote to ban urea formal- dehyde foam insulation. 0 OSHA rejected petitions for emergen. cy standards limiting exposure to the gaso- line additive ethylene dlbromide and the pesticide and sterllant ethylene oxide. A U.S. District Court judge this month or- dered the agency to produce an emergen- cy ethylene oxide standard: OSHA is ap? pealing. An ethylene dtbromlde standard is being developed. 0 OSHA ended preliminary work under way to develop standards for nickel and and cadmium. according to an agency offi- cial. The agency also is revising its overall policy on carcinogen regulation. . OThe Food and Drug Administration proposed a new "constituents policy." which was developed during the Carter ad- ministration. allowing tiny amounts of can- cer-causing chemicals to be added to food. drug and cosmetics If they are an integral "Mostly. the (adminis- tration) is looking for a way not to act. . . Tony Robbins American Public Health Association I part of a substance which has not proved carcinogenic. Under this policy. the FDA has approved for use In cosmetics and drugs four dyes containing traces of car? cinogens. A free society are at ii- berty to take certain dates. The regulator has to have a sense of what the society wants in terms of restrictiom and fit the scientific evidence Into the equation." said Arthur Upton. tamer director of the Na- tional Cancer institute. "What worries me is the present administration seems to he going beyond a wholesome and reasonable reassessment of the evidence." "Some people want to take a knee-Jerk reaction. We want to be protective of the public health. but we don't want to fool the public and take an action just for the sake of saying 'i took an action.? said John Todhunter. an EPA assistant administra? r. EPA did ban the carcinogenic pesticide toxaphene. although allowing use of exist- Ing stoclui. Todhunter said the agency had kept more than 80 chemicals off the mar- ket under the screening program. Over the past decade. legislators. regu- lators and scientists have moved away from the rigid attitude exemplified by the 1958 Delaney Amendment to the Food. Drug and Cosmetic Act. which banned out- right carcinogens in food additives. Recent government decisions have sharply accelerated the trend against new carcinogen controls. experts say. There are sharp disagreements on the wisdom of this policy. Ronald A. Lang. executive director of the American Industrial Health Council. which supported by chemical manufac- turers. said he applauds the decision to.re- view what he described as the question- able scientific basis for some rules and proposals imued In the Carter administra- tion's closing days. Lang also said he sup- ports efforts lihe those of EPA administra- tor Anne M. Gorsuch to require more peer review of scienti?c studies. But Tony Robbins, head of the Ameri- can Public Henith Association. and former head of the government's National insti- tute for Occupational Safety and Health. disagrees. ?Mostly. the (administration) Ls looking for a way not to act." he said We should accept a situation In which a small - part of the time the tests proving carcino- genicity are wrong. . . to eliminate the situ- ations in which people are not protected because a test showing no hazard was wrong." THE LATE 19705. the heads of the FDA. OSHA. the EPA and the CPSC ap- pointed a staff to develop a concensus on some of these issues. in [979. the group proposed the first government-wide can- cer policy. The proposal has not been revoked. but the White House Office of Science and Technology Policy has assembled a group of government scientists and regulators to prepare new guidelines for carcinogen re- search and regulation. Among other things. they are putting new emphasis on "risk amessrnent." a hybrid of statistics and science designed to show how many people are exposed to a chemical and whether exposure is likely to cause can- cer. - . Univ MIDLAND. From Al nam war that brought controversy. Today. it involves Midlund's envi- ronmt-nt and the company's political The Tittelmwamee. after it ?ows past Dow's huge flagship factory. is poisoned with enough dioxin to matte its ?sh inedible. according to state health of?cials. Medical date show that suit-tomes sarcoma. a rare cancer. appears here at rate: higher than are lound nationally. [bites of birth defects. for unexplained rea- sons. have exceeded state and na- tional levels. There is dispute over the quality of Midland's air and wa- ter. Toxic waste dumps lenlt and the state ordered Dow to shot down a major burial site earlier this month. These have become issues of con- .tcntiou in Michigan and the nation. but much of it in not new to this til- fluontly serene city of 36.0th north- .eastof Detroit. Napalm bombs made Dow a target of ?erce Vietnam war protests. its potent Agent Orange herbicide. also used in Vietnam. hus embroiled Dow and other chemical firms in multimillion-dollar damage suit: by veterans. For all that might lurk in the air. the soil and the water of Midland County. this town is a paradoxically inviting place. More per square acre then mt places. [ta own and a gleaming cen- ter for the arts. Solid and an imitating library. Writeis' work- hhtipo. a nature center. endless tennis courts and Money. Happy workers. Midland also is the quintessential company town. dominated by a Dow that brought wealth. philanthropy and good tim. Scientists do not raise their voices outside the plant ates The city council and school board are dominated by Dow em- ployee. The few citizens who ques- Lion Dow policies feel isolated and LhIL-umnod. 'This is good midmtern com- munity,? said John A. Pale-n. editor of the Midland Daily News. ?It is unusually educated. with a lot of Phil's. lawyers and brain surgeons. But it is not like a university com- munity with different disciplines. This is not a hotbed of humanistic studies. The attitude here is that .Icience and technology constitute a kind of truth and no lmve it.? Midland's ease stein directly from the presence at Dow. located here by Herbert Dow in the late 18905 and kept here by his suc- tensors no they built his dream into a - hard-charging. global of inestimalile quer and in?uence with 57.000 employee [7.000 lit-r0) and ?0.6 billion in sale: in 1082. Don: was third in the in prof- sixth largest in sale: In wet. it {has opt-ration: in 29 Cttultll?icn'. with 112 plants. Company executive: today have antizlnr l" tln- in- l' t'l'l itll_V I I . Lornec Under aruuntl lturc. 'l'ln j. liutvL feat-rut titula- tion the target of It virtual liuly war that seeks to Ila theology of bottom-lino on the American polit- ical process. Dow political action committees contribute more to campaigns than any other chemical ?rm: 3312.000 to candidates in the 1952 congressional elections. 5304.000 to ?tame. Senate and presidential candidates in 19:10. Cause and eltect may be debatable. but llUUI'a have swung open for [low in Washington. President Paul P. Oret'lice. who once likened US. economic and re- gulatory policies to of a ho- nam republic. helped the Reagan White House chaise on Environ- mental Protection Agency chief. Dow lobbyists ?nd eager ears for their regulatory ideas at the EPA. One of its Washington eta-rativcs regularly wined and dined llita M. EPA's deposed toxic-waste cleanup overseer. Belore he resigned nntler pres- sure. EPA deputy administrator John W. Hernandez .lr. allowed Dow to censor critical portions from an EPA study til the putwcy ul Dow- produced dioxin. Another Dow man' was allowed to derail an intertmtion- al system for testing: new chemicals. Both issues are under investigation. To the utter mystilication of its top executives. the company new land: itself depicted as parinh for these and other excursions into the world of regulation and - The company has just hired Hill tit Knowlton lnc.. the world's lliguest public relations ?rm. to help it deal with a deteriorating image. Robert W. Lundeen. Dow?s board chairman and a company man for 37 years. put it this way in a recent interview: ?We're not unaware of the public perceptions . . . and we know Dow doesn't get too many hero badges .. . . We are regarded as . . . . [But] we are just not going to back off on being active. effective advocates in areas where we have a right to be.? Rep. Donald J. Alboeta lD-Miclt). who was elected the area's congruen- man in 1973 without Dow?s support. takes a dim view of his biggest cor- porate wnstitoant?s style. don't think they perceive that they are part of the problem." he said. Dow executives warmed to Al- bosta after he was elected. He ta? vorsd giving the company more time to meet an air Inillution-control deadline. fearing jull-?l would be lost othenvise. But when he voted for the federal ?Superfund." requiring indus- try to pay for dump cleanup. and Vult?tl some til the Reagan budget-cutting propul- ala. Albumin was back out of lavor. AS a result of recent discoveries of dioxin llL?l't? clat-~ where to the country. tln- ls phoning a [mint r- vet-w ll. l. .3 inch: [or [it chemical production. is widely thought to be one of the most potent cancer-causing agents mode by innit. But little is known with certainty about its effect on human health. Much of the EPA review work will be done here to detennme if, as Dow maintains. all is salubrious. or if the ?rm's primaries have created a massive public health threat. Dow Pruitlent Oret'lice and other com- pany of?cials insist that dioxin is benign and has no harmful impact on human health. A Dow study. much debated and reiected by many scientists. asserts that dioxin is a product of combustion and is found wherever men uses ?re. But recently surfaced Dow inter- nal documents suggest that company have been concerned for years abtnn the potential lumrds of dioxin. One 1967 memo detailed the GOO MORHI WHILE YOU YOUR MONE IF IT WAS INSURED MARKET FREE MUG 0 INVEST Just 1?0 EARN Mt MARKET nArt GET A FREE SEE Ft COMPLE ft' 01 AND HEOEWING APPLIGZ FOB MERIT POSITI The Maryland-Notional Capitol Port ur is presently receiving nppl-cot to Merit System Board The Boord conipoicd at three members in tho held a! kl Nye-1:? o! Ii.c Board on.- comma: ?f STATEMENT OF DOW CHEMICAL U.S.A. Presented to the Department of Health Services Workshop February 19, 1982 AND THE Subcommittee on Commerce, Transportation and Tourism Committee on Energy and Commerce U.S. House of Representatives March 31, 1982 My name is Bryant Fischback. I am Manager of Environmental Services for the Western Division of Dow Chemical U.S.A. I am speaking on behalf of my Company. This testimony shall in large part be addressing the "Discussion Paper: State Action to Reduce Land Disposal of Toxic Wastes? prepared by The Interagency Task Force for Reduction of Land Disposal of Toxic Wastes. While the major focus shall be on specific issues and problems, let me first present an overview of Dow's overall philosophy and policy for waste management, followed by some general conn1nsions as they nelate to the reduction of land disposal of hazardous wastes. The general Dow philosophy and policy for waste management is that land disposal is considered as an alternative only after certain stringent requirements are met and then only as a last alternative. It is our published policy that 1. Recycling or reuse of materials be given first con? sideration prior to classification and disposal as waste. 2. Wastes are treated or neutralized whenever practical to produce nonhazardous material. 3. If recycling or treatment is not acceptable or justifi- able, then incineration should be the primary method of treat- ment for burnable wastes, especially for liquid wastes. It is only after these three alternatives are considered and ruled out that land disposal is considered as an alternative. We feel that incineration represents the best available method of managing many by-product streams and wastes. The following are our general conclusions as they relate to the reduction of land disposal of hazardous wastes in California. 1. We support the general policy of land disposal restric- tions being addressed by the Department of Health Services today. I would like to emphasize, however, that the basis for this strategy must be predicated on the condition that alternate technology facilities must be in place,.permitted. and operating before land disposal restrictions are imposed. We do not support the concept of unilateral bans. 2. It would seem that the timetable proposed.ieLunrealistic in light of current difficulties in the permitting of new facilities. Recognize, for.instance, that there are no rotary kiln incinerators currently in operation in the state. We believe, rather than providing a timetable at this time, the permitting system should be upgraded and land disposal restrictions should be predicated on the permitting and opera- tion of new alternate di5posal facilities. 3. Increased diSposal costs will be incurred when alternate technology facilities are in place and we consider this to be appropriate. However, it should be borne in mind that these increased costs like any other costs of doing business, will ultimately be paid for by the.consumer. 4. The choice of environmentally satisfactory?alternate technologies should be governed strictly by business considera- 'tions in the private sector. No attempt to mandate a particular type of technology should be made by the state. 5. We agree basically with using the concept of the criteria of toxicity, persistence in the environment, ability to bio' accumulate, and mobility in a land-disposal environment to determine when restrictions on the land disposal of wastes are justified. However, the definition of the criteria should be objectively based on good science, recognizing the simplic- ity or complexity as well as the volume of the waste being considered for disposal. For example, incinerator ash may require a minimum amount of testing as the hazard has been reduced. It is our belief that many hazardous materials can be disposed of in properly designed, operated, and-maintained land disposal facilities. It is also our belief that the degree of hazard should be used to support the degree of con? cern. This may require the consideration of narrow classes, if not of individual compounds for land disposal restrictions. Now let me address some of the specific issues as they relate to the "Discussion Paper". While the issues presented here are by no means a complete listing of our concerns and are only meant to serve as examples, they will point up a need to further define the criteria based on good science, as the determinations are made as to which wastes should be restricted from land disposal. Our remarks will address the categories as outlined in the "Discussion Paper". BIPHENYLS We support the concept that high temperature incineration is an appropriate method of destruction for It should be realized that there is not sugficient alternate technolOgy capacity available for solids, such as dirt, containing low levels of PCB's outside of TSCA approved landfillso CYANIDE COMPOUNDS Our position is that as a mintmum, polymers containing cyanide groups should be excluded from disposal restrictions. For example, materials such as ABS plastic, nitrile rubber, latexes, and acrylic carpet are suitable for land diSposal because the cyanide moeity_is bound.an? unavailable. STRONG ACIDS We have surface impoundments at our Pittsburg, California manufacturing-site which are maintained at pH's which are greater than 8. We occasionally neutralize a strong acid, such as hydrochloric acid, at less than.pH 1 in these impoundmentso Since neutralization in situ dccurs rapidly, there is little ?potential for mobilizing othen toxic.wastes in this-environment. Additionally, current regUlations do.not permit theimixing of incompatible wastes; thus, gooh management.practices based on sufficient testing, preclude the need for new regulations. Land disposal alternatives such asjthis, are appropriate and should be exempted.? HALOGENATED ORGANICS It is our position that restricting land disposal of this category by a broadbrush, generic approach is inappropriate: We have done significant work on these materials which shows that many' do not fit the criteria of toxicity, persistence, bioaccumulation, or mobility outlined in the "Discussion Paper?. Let me illustrate with just three among many examples. i 1. Plastics such as polyvinyl chloride and polymers such as chloroprene and other chlorine?containing latexes which have been demonstrated to be essentially non?toxic, are Suitable for landfill disposal. I 2. Dow manufactures several halogenated heterocyclic organic compounds, particularly those derived from.pyridinew We have carried out significant work to identify areas of uncertainty. Evidence to date shows that these products, their intermediates, .and their by?products, in general, have moderate to low orders of acute toxicity. We are continuing to study their persistence in the environment. However? neither persistence in vivo nor bioaccumulation in laboratory animals seems to be an issue as even the most highly?chlorinated ones are metabOlized,and eliminated in a matter of hours. Persistence in the environ? ment alone, may not be sufficient cause to place restrictions .on materials from land disposa 3. Here is an example where the criterion of mobility in a land disposal environment has to be carefully?. evaluated It would appear from a paper entitled ?Clay- soils permeability and hazardous waste. storage", published in August, 1981 in the Journal of the Water Pollution Control Federation (Vol' 53, No. 8, pp. 1347- -54) by professors Green, Lee, and Jones atl the University of Texas, that permeability of liquids through clay soils is surprisingly most closely related to the inverse of the log of the.octanol?wate ?partition-coefficient and some- what directly pr0portional to the dielectric constant of the liquid. Thus, they determined that water.was the.most permeable liquid studied to all three types of clay studied.: Water was usually an order of magnitude more permeable than we1.e acetone, methanol, -glycer.ine, trichloroethylene, xylene, benzene, and carbon tetrachloride, the othe- solvents studied;. Benzene, trichloroethylene and xylene were the least permeable. However, {it was observed that. solvent breakthrough occurred in the cases of carbon tetrachloride, benzene, and to a lesser extent, xylene.. This' was attributed to clay- shrinkage with subsequ.ent .cracking. Interestingly, trichlo-roethy.lene did not show break- .through with any of the clays tested The authors conclude that wastes. such as benzene, xylene, or carbon tetrachloride might best be co?disposed with a higher dielectric and, preferably miscible liquid. Certainly this study.indicates that halogenated organic liquids, as a class, do not consis? tantly show increased mobility characteristics when disposed of into clay soils. EXTREMELY HAZARDOUS WASTES We submit that rather than outright prohibition of these materials that suitable determinations should be made con- cerning the land disposal of them based on concentrations, physical form, and quantity. Furthermore, there seems to be an inconsistency in the prohibition inferred in this category versus the concentrat-ion limits provided in ot?her categories, e. g. ,beryllium, cyanide salts, mercury. We support the concept of de minimus levels based on evaluation of the criteria cited previously. Soils containing low con? centrations of these materials may not be amenable to any alternative disposal method. VOLATILE ORGANIC COMPOUNDS We consider the vapor pressure limit of 0.1 mm Hg to be unreasonably low. For example, propylene glycol, which has a vapor pressure greater than that allowable is approved by the Food and Drug Administration as a food additive. We can use it in ice.cream, but cannot dispose of it in the lando Migration through evaporation wOuld not be a factor with materials'of such low volatility, Finally, a general consideration.which relates to all classes of waste being considered here should be addressed before final regulations restricting land disposal are adopted. The physical form of the waste should be considered, Such things as contaminated soils, contaminated sludges, solid, semi~solid still bottom residues and other nOn?burnable materials may be best or only managed by land ,disposala? In summary, then, Dow Chemical firmly believes that upgrading the permitting system in California is the key to -success for this program, Additionally, we believe that innin- eration should be the primary method of treatment burnable ..wastes which cannot_be viably recycled, reused, or treated, ;Additionally, We strongly support the proposal ofitbe Chemical Industry Conncil of California that a scientific task force from the CIC meet with a scientific task force from.the Depart- ment of Health Services to address and resOlve thetissues and problems raised in these worksh0ps and in pending?legislationv We agree with the CIC position that good regulatory management must be based on good science that works: 0 The Toxic Waste Incinerator would be located in lronbound on Lister Ave. 0 Millions of gallons of toxic chemicals would be brought to lronbound Atrom other parts of New Jersey and from other states 0 Only 1% of the toxic wastes would be from Newark 0 Many of the chemicals cause cancer 0 Some of the chemicals cause health problems for people in very small quantities and in very low concentrations 0 Even It there are no problems with the incinerator, some of the chemi? cals will get into our air . 0 Potential problems with the incinerator can be caused by not follow- ing all rules and regulations regarding satety The Attorney filed a $26 million lawsuit against the companies that would own the incinerator for pollution problems at the Kin Buc land?" I in March 1979 the N. J. Dept. of Environmental protection denied an application by the same companies for a hazardous waste landfill because "the reliability of the applicant to properly operate a land based hazardous waste facility has not been records of the Solid Waste Administration indicate that on Oct. 28,1978 chemical waste was disposed at the Parklands sanitary landfill facility in violation of the conditions oi its registration. This incident raises questions as to the reliability of SCA Services or its subsidiaries to operate this facility.? a The North Carolina State Health Director conducted an investigation into SCA's background and found that the company ?has not demonstrated a consistent record of operating other waste facilities in accordance with sound management practices and in substantial compliance with Federal and State laws and regulations." 0 On Aug 28 1978. a judge in Illinois found that SCAMS is. .dii ll there was a public nuisance 5 years ago. a toxic waste incinerator Jersey had an accident. 6 people were killed and toxic chemicals were thrown into the air 0 Numerous other investigations are going on now or have occurred i, with regard to these companies including: in min 1 5 ?4sz )i'Wii .J. Hazardous Waste Task Force 0 r? 30 cm/ 0 ,9 NJ. Attorney General State Police i All W6, Congress Luxjx il- 01p r? 713 - Ur cyst-i LMVZ6 (63:3:?00 . Illa; N- . MWWQ waaounD Incineration Proposal What do they plan to do? SCA. in partnership with Scientific Inc.. want to bring thousands of gallons of toxic chemicals. each day. to the lronbound section of Newark. They would then try to destroy the chemicals in an incinerator. This is supposed to solve the problem of toxic waste disposal for the chemical industry. . Who are these companies? SCA is a multi-million dollar waste disposal corporate conglomerate empire. They have had their facilities closed down by court orders in other parts of the country. They have been caught time and time again disposing of toxic waste chemicals in an unsafe. illegal manner. They have been caught bribing government officials and are now under an indictment in Georgia for monopolistic practices. They are growing like a cancer through the acquistion of other companies. Scientific lnc. has a similar record. although they are a smaller company. Together. the two companies were responsible for the cancerous mess at Kin Buc in Edison. Both companies. and their joint venture - Earthline. which would own and operate the proposed incinerator. are currently trying to defend themselves against a $26 million lawsuit. filed against them by the US. Attorney's office for the devastation at Kin Buc. Where it be? This toxic incinerator will be located in the center of one of the most densely populated areas in the world. Specifically. Newark. Anaccident at the site would effect the neighboring cities of Elizabeth. Jersey City. Bayonne. Kearny. Staten Island and New York City. The chemicals will travel in trucks on the highways that lead to Newark: the N.J. Turnpike. Routes 1 9. 22, 21. l-78. l-280. l-95. Trucks will pass through all the cities towns located along these routes. Accidents during transport are certain; the only questions are how frequently they will happen and how serious each will be. The effects on the health a safety of truckers. firefighters. commuters and residents from one (or more) of these accidents are unknown. What are the chemicals they will handle, and what are their effects? biphenyls) are known to have extremely hazardous health environmental effects. even at very low levels of concentration. The dangers include: tumors. skin lesions. reproductive failures. swelling of joints and skin rash. The manufacture of the chemicals has been banned since 1977. but they are still in use. Dioxin three ounces distributed in drinking water can kill 1.000.000 people. One millionth of a gram can kill a rabbit. It causes cancer and birth defects, liver and kidney damage. 1. 2, dichloroethane causes liver and kidney damage. circulatory and respiratory failure and cancer. Other chlorinated hydrocarbons have similar effects. These are only a few of the identified chemicals that SCA would truck, store and handle. There are hundreds of others. Who will protect us? We don't have an answer, but we have more questions. Who protected the peOple near Love Canal? Who protected those near Kin Buc, where it took a $250,000 private law suit to get the facility closed? Who protected the peOple in Elizabeth who protested against the conditions at Chemical Control for years before it finally exploded? Are there workable evacuation plans for the communities involved? Do the firemen have sufficient training to handle all the types of accidents where toxic wastes are involved or will we be told that they'll just have to let the toxic fire burn itself out? Can anyone handle an accident where the chemicals are unknown? You probably have more. What has happened in the past? In 1979, there were 16,000 accidents involving trucks carrying hazardous materials. Another 1.200 accidents occured involving trains. These numbers are dramatically higher than those of 10 years ago. In 1980. Chemical Control another toxic waste facility. a few miles from the proposed SCA site, blew up. Many people were injured. others will get cancer in the years to come. Workers were killed in an explosion at Rollins Chemicals, another toxic waste site in New Jersey. The groundwater in many areas of New Jersey has been polluted with toxic chemical wastes. is the SCAproposal environmentally sound? No! If the chemicals are actually burned. the residues .. including by-products and unburned chemicals will be deposited in our air. No combustion process is ever complete. Even a small percentage of unburned toxic chemicals (thousands of pounds) can cause profound environmental damage. Since a profit making corporation, the incentive will be to do whatever costs less. it is cheaper to burn the chemicals at a lower temperature than to spend moey on expensive oil required to actually destroy them. i Past experience (a few incidents are mentioned above out of the vast number that have occured) shows that companies do try to dispose of chemicals for the least amount of money. It also shows that monitoring of environmental damage is minimal and often corrupt. What are the alternatives? _No matter which alternative is used. facilities cannot be located in the most densely populated areas of our country. Decentralization to smaller facilities can reduce the impact on any one community and eliminate the ?out of sight, out of mind" approach. Moreover. the further each ton of toxic wastes travels. the higher the frequency of transport accidents. The larger the concentration of these chemicals in one site. the larger the damage to people. property ?tdtheenvironment when an on-site accident occurs. - Greater Newark Bay Coalition Against Toxic Wastes 95 Fleming Ave. Newark. N.J. 07105 tel. 344-7210 or 354-1811 Alternatives Many promising alternative technologies for toxic waste disposal exist, including: encapsulation in clay, molten salt pyrolysis. calcination. chlorolysis, wet air oxidation, microwave discharge and dozens more. Some of these can be tailored to specific waste streams, often they can be performed at, the site where the wastes are produced, eliminating the need for transporting the dangerous chemicals. Each year, there are more than 16,000 transportation accidents involving hazardous chemicals. But, they?re not used? Instead of using many of these alternatives, both the chemical and hazardous waste disposal industries have chosen cheaper methods. These have included: dumping the toxic mess on the ground; pouring it into our rivers, streams and lakes; piling it up in barrells; illegally hauling it to municipal and other landfills designed only for ordinary garbage; dumping it on highways during rainstorms; legally dumping it into our sewer systems while calling it "detoxification"; and releasing it into our air supply in ill-thought- out incineration schemes. The methods used, resulting in the devastation of a Love Canal, Kin Buc or Chemical Control, were each, in their time, praised by both the industry and the ?regulatory(sic) agencies for being the ?state of the art" in technology. State of the Art The problem is the lack of both honest scientific endeavor and concern for human life. Instead, we have painted with murky chemicals, images of our citizens suffering agonizing deaths from cancer, and horror stories that should have remained in. the movies - not our daily lives. Concerns of the industry Money is needed to implement the alternatives, to make toxic waste disposal safer. Instead of spending this money, the chemical industry strives for higher and higher profits; dividends for their stockholders; interest payments to the banks; corporate officers' escalating salaries, bonuses, stock options, outlandish severance pay ?perks"; and bribes. . In addition, huge sums are spent on advertising, buying other companies, building fancy corporate headquarters and paying lawyers and accountants to find tax loopholes. Research and development funds are allocated for finding new product lines (of questionable safety or need and generating more chemical wastes) instead of being Spent on finding ways to clean up the cancerous mess they've already made. Workers, Consumers and Residents When New Jersey's other toxic waste incinerator (owned by Rollins) exploded in 1977, six workers were killed and many others injured, while residents of the area had 45,000 gallons of PCB's dumped into their air. In addition, we have been ?given" cancerous consumer products like red dye asbestos hair dryers, Triss (a carcinogen used in children's clothing) and countless others. The harm inflicted on workers, consumers and residents of the areas surrounding these industries (a good part of New Jersey), springs from the same fact - the chemical industry's mad dash for higher and higher profits using backward and essentially unregulated technologies and manufacturing processes. Maybe the alternative we need is an alternative to the chemical industry, as it is currently owned and operated and an alternative to the government agencies that bend to its will. Fact0?heet At Sea Incineration Corp. What do they plan to do? At Sea plans to build a $75 million tank farm. storage facility and terminal to unload trucks and load boats with highly toxic chemical wastes. A ?eet of ships transport the chemicals 100 miles off the Jersey Shore supposedly to be burned at sea. Who is behind this proposal? We?re not sure, but it certainly is a lot of money to be invested. Two individuals are listed as their of?cers. One, Donald Henry, worked on the Glomar expedition, which tried and failed to raise a Russian nuclear submarine from the bottom of the ocean. The other, Irwin Solomon, has spent his career in the ?eld ofinsurance. An unlikely pair to be responsible for the safe handling of millions of pounds of dangerous toxic chemicals. Some of us guess that the large chemical corporations are the primary ?nancial backers for this enterprise. Where will it be? These toxic tanks will be located in the center of one of the most densely populated areas in the world. Speci?cally, Port Newark, one of the busiest in the world. An accident at the site would effect the neighboring cities of Newark, Elizabeth, Jersey City, Bayonne, Kearny, Staten Island and New York City. The chemicals will travel in trucks on the highways that lead to Newark: the NJ Turnpike, Routes 1 9, 22, 21, I-78, 1280. I-95. Hundreds oftrucks, daily, will pass through all the cities towns located along these routes. Accidents during transport are certain; the only questions are how frequently they will happen and how serious each will be. The effects on the health safety of truckers, fire?ghters. commuters and residents from one (or more) of these accidents are unknown. What are the chemicals At Sea will handle, and what are their effects? biphenyls) are known to have extremely hazardous health environmental effects, even at low levels of concentration. The dangers include: tumors, skin lesions, reproductive failures, swelling of joints and skin rash. The manufacture of the chemicals has been banned since 1977, but they are still in use. Dioxin Three ounces distributed in drinking water can kill 1,000,000 people. One millionth of a gram can kill a rabbit. It causes cancer and birth defects, liver and kidney damage. I, 2 dichloroethane cause liver and kidney damage, circulatory and respiratory failure and cancer. Other chlorinated hydrocarbons have similar effects. These are only a few of the identi?ed chemicals that At Sea would truck, ship and store. There are many others. Who will protect us? We don?t have an answer but we have more questions. Are there workable evacuation plans for every municipality that the toxic wastes will be transported through? Do ?remen have suf?cient training to handle all the types of accidents where toxic wastes are involved? Can anyone handle an accident where the chemicals are unknown? You probably have more. What has happened in the past? In 1979, there were 16,000 accidents involving trucks carrying hazardous materials. Another 1,200 accidents occured involving trains. These numbers are dramatically higher than those of 10 years ago. In 1980, Chemical Control another toxic waste facility, a few miles from the proposed At Sea site, blew up. Many people were injured, others will get cancer in the years to come. Workers were killed in an explosion at Rollins Chemicals, another toxic waste site in New Jersey. The groundwater in many areas of New Jersey has been polluted with toxic chemical wastes. Is the At Sea proposal environmentally sound? No! At Sea means at sea dumping. If the chemicals are actually burned, the residues including by-products and unburned chemicals will be deposited in the ocean. No combustion process is ever complete. Even a small percentage of unburned toxic chemicals (thousands or millions of pounds) can cause profound environmental damage. Since At Sea is a pro?t making corporation, the incentive will be to do whatever costs less. It is cheaper to dump all the chemicals in the ocean than to spend money on expensive oil required to actually burn them. Past experience (a few incidents are mentioned above out of the vast number that have occured) shows that companies do try to dispose of chemicals for the least amount of money. It also shows that monitoring of environmental damage is minimal and often corrupt. What are the alternatives? No matter which alternative is used, facilities cannot be located in the most densely populated areas of our country. Decentralization to smaller facilities can reduce the impact on any one community and eliminate the "out of sight, out of mind" approach. Moreover, the further each ton of toxic wastes travels, the higher the frequency of transport accidents. The larger the concentration of these chemicals in one site, the larger the damage to people, property and the environment when an on-site accident occurs. Who we are? The Greater Newark Bay Coalition Against Toxic Wastes includes: Coalition for a United Elizabeth NJ Committee for Occupational Safety Health Ironbound Health Project; N.J. Public Interest Research Group (NJPIRG): NJ. Toxics Project; Rutgers Law School Environmental Law Council: The Ironbound Grouszssex County Safe Energy Alternatives (SEA) Alliance: Rutgers Law School Land Use Planning Service. We've been working together for the last year to research and let people know about the proposed At Sea facility and the dangers for the peOple (especially working people who live near the proposed site) of Northern New Jersey. Greater Newark Bay Coalition Against Toxic Wastes 95 Fleming Ave. Newark, N.J. 07105 tel. 3-44-7210 or 354-1811 LABOR DONATE