RE: Safe Drinking Water Act

["Bove, Frank" <fjb0@ATSDHS2.EM.CDC.GOV>]

First off, I would like to apologize if you have already received my reply 
to the Chlorine Chemistry Council spokesperson's statement below.  I am not 
sure my initial e-mail got out because I received a warning that it was not 
sent to the multiple list.  So, here goes!
=================================================================

The federal register of 7/29/94 40CFR Parts 141 and 142 has the text of the
D/DBP reg-neg panel's position on regulating the use of chlorine,
chloramines and chlorine dioxide for disinfection purposes.  I urge all to
look through the document even though it is very long.  In it, there are
summaries of the evidence of the carcinogenic effects and teratogenic
effects of DBP (e.g., chloroform and bromodichloromethane) from
epidemiologic studies of HUMANS as well as from animal studies.

Starting with the animal data, the document states: "Several chronic animal
studies confirmed the carcinogenicity of chloroform.  Chloroform induced
hepatocellular carcinomas in mice when administered by gavage in corn oil.
 Chloroform also induced renal adenomas and adenocarcinomas in male rats
regardless of the carrier vehicle (oil or drinking water) employed."
 "Evidence of the carcinogenicity of bromodichloromethane (BDCM) has been
confirmed by a NTP (1987) chronic animal study.  BDCM caused statistically
significant increases in kidney tumors in male mice, the liver in female
mice, and the kidney and large intestine in male and female rats."  Animal
studies have also implicated the chlorination disinfection byproducts
dichloroacetic acid (DCA) and trichloroacetic acid (TCA) as teratogens: "DCA 

appears to induce both reproductive and developmental toxicity.
 Malformation of the cardiovascular system has been observed in rats....
Several studies show that TCA can produce developmental malformations
in...rats, particularly in the cardiovascular system."  The document states
that both TCA and DCA have been shown to be carcinogenic in animal studies.
 (Recent animal studies conducted by EPA, that are not reported in this
document, have implicated the haloacetic acids, particularly the bromoacetic 

acids but also the chloroacetic acids, as causing neural tube defects, i.e., 

the serious central nervous system defects: spina bifida and anencephaly. )

Moving along to the human evidence (the document has a lot more on the
animal evidence so I do urge any one interested to get the document ),  the
document cites  numerous studies that have found associations between
chlorinated drinking water and  bladder cancer and rectal cancer.  A recent
study mentioned in the document also found an association with pancreatic
cancer.  A meta-analysis of these studies estimated that approximately
10,000 additional cases of cancer (bladder or rectal) per year can be
attributed to chlorinated water and its by-products.   It is true that there 

was not unanimity among reg-neg panel members as to the level of
carcinogenic risk to humans posed by chlorinated drinking water containing
levels of disinfection by-products that one would normally encounter at
present in drinking water systems using surface water sources.  A few panel
members claimed that the risk is low compared to the risk of not
disinfecting the water.  Of course, no one on the panel proposed NOT
disinfecting drinking water.  The issue is how to do it safely.  So in
response to the statement below by the chlorine industry spokesperson, there 

is clear evidence of carcinogenic risk to humans from chlorination
disinfection by-products, although there is some uncertainty as to how many
cancer cases are due to these by-products.  As for developmental effects in
humans, only two studies have been completed so far that investigate the
effects of chloroform and other trihalomethanes on birth outcomes.  A study
performed in Iowa found an association between chloroform and BDCM and
small-for-gestational-age (i.e., a low birth weight given the infant's
gestational age).  A study conducted in New Jersey (by myself and my NJDOH
collaborators) found associations between total trihalomethanes (virtually
all chloroform and to a lesser extent BDCM) and neural tube defects, cleft
lip and cleft palate, and major heart defects, as well as
small-for-gestational age.  (The study was published in the American Journal 

of Epidemiology,  1995, May 1, Vol. 141, pages 850-62.)   So, the reason
that the evidence for chlorination disinfection by-products'  teratogenicity 

in humans is not "obvious" is because we are only just now beginning to do
the research in humans!

It is possible right now for water utilities that utilize surface water
sources and that disinfect with chlorine to meet the reg-neg's 80ppb
standard for total trihalomethanes (down from the current 100ppb standard).
  Many water companies in New Jersey that use surface water sources and that 

chlorinate their supplies have been under 80ppb for total trihalomethanes
for a number of years now.  The eventual standard of 40ppb should also be
attainable RIGHT NOW by most water companies.  (Again, some water companies
in NJ can meet this standard too, RIGHT NOW.)     And, of course, there are
alternatives to chlorination that must be explored.  The choice certainly is 

not between cancer and cholera, or  between increased risks to the
immune-compromised and birth defects!    The choice is between maintaining
the status quo (which certainly is cost-effective for the chlorine industry
but not for the rest of us!)  and minimizing (or eliminating) cancers and
birth defects (and possibly other health effects that have not been
adequately studied in humans) due to chlorination disinfection by-products
while at the same time preventing water-borne infectious diseases.

Frank Bove
FJB0@ATSDHS2.EM.CDC.GOV    (404) 639-6203

Mailing address:  ATSDR/DHS/ESB,  Mailstop E-31, 1600 Clifton, Atlanta GA
30333

 ----------
From: dioxin-l
To: Multiple recipients of list
Subject: Safe Drinking Water Act
Date: Wednesday, April 24, 1996 11:04PM


Let's take a look at exactly what CCC has asked for in consideration of the
Safe Drinking Water Act (SDWA).

The SDWA already proposes the use of cost-benefit testing, which is a good
thing.  Inexplicably, it exempts the place where it is most needed--in the
area of disinfectant/disinfection by-products (D/DBP).  We've asked that the
cost benefit test be extended to include D/DBP.

The D/DBP rule derived from a negotiated regulation (reg-neg).  The chlorine
industry was not a part of that negotiation.  In the intervening time since
the reg-neg we have discovered quite a bit about chlorform, the major D/DBP.
 Even EPA admits that its assessments probably overestimate the risk of
chloroform given what we now know about its pharmacokinetics.  At the same
time, EPA notes that it has almost no information about by-products of
alternative purification processes, and research is needed.

The Congressional Budget Office estimates the cost-per-life-saved associated
with the D/DBP rule to be between $800,000 and $19 billion.  The reason for
these incredibly broad limits is because of the uncertainty of any harm
caused by chlorinating water.  Since it's been done for nearly 100 years, if
chlorinated water was a clear and present danger, shouldn't the evidence be
obvious and not in the just-barely-detectable-by-science range?

There is risk to people with compromised immune systems from many
microorganisms, not just cryptosporidium.  The latter microbe is 
particularly
tough, but the best system for eliminating it seems to be ultrafiltration.
 It's expensive, but effective.  For other, non-cyst-forming
microorganisms--by far the day-to-day risk--chlorine remains the 
disinfectant
of choice.  It has allowed us to provide safe water all over the country at
reasonable cost.  Switching out of it for unknown risk, small or no benefit
but known higher cost is not reasonable without formally asking the 
question.
 Incidentally, that higher cost falls diproportionately on the smaller water
districts, and can be many times what safe water currently costs.

We often hear about the situation in Peru in 1991, when authorities
misinterpreted the US EPA's advice on D/DBP to mean that they should
eliminate the chlorine in the water.  This was clearly an error, and
obviously carried no intent to harm by either party.  However, a cholera
epidemic ensued.  What this experiment teaches us is that water purification
is necessary.

I have found that when people are reluctant to submit a product or idea to
cost-benefit testing it is because they know that it will show up poorly.
 That's my sense here, and it explains the violent objections by activist
lobbyists to what should be obvious.

Bill Carroll
Chlorine Chemistry Council