apha's dioxin reassemnt public commnets (old..)

[cmcr@ism.net (Cold Mountain, Cold Rivers)]

                                       American Public Health Association
                                       1015 15th Street, NW | Ste. 300 |
Washington, DC 20005 |
                                       202-789-5600


January 11, 1995

 To:
                             Technical Information Staff (8601)
                             Office of Health and Environmental Assessment
                             U.S. Environmental Protection Agency
                             401 M Street, SW
                             Washington, DC 20460

 Re:
                             Dioxin Health Assessment Comments

 APHA Contact:
                             Eric Juzenas (202) 789-5600


        Note: Format of comments has been altered from original to comply
with HTML format.


               Comments of the American Public Health Association

The American Public Health Association supports the conclusions of the U.S.
Environmental
Protec tion Agency's draft documents, "Health Assessment Document for
2,3,7,8-Tetrachlorodibenzo-p -dioxin (TCDD) and Related Compounds" and
"Estimating
Exposure to Dioxin-like Compounds". In the face of scientific uncertainty,
although less than
existed in the past, EPA's conclusions appear adequately protective of
human health and the
health of other species.

In supporting EPA, APHA notes the high toxicity of chlorinated dioxins,
dibenzofurans and
biphenyls. As a result of expanded research in the last decade, the wide
spectrum of health
consequences now believed related to dioxins include cancers, reproductive
and developmental
effects, immune deficiency, endocrine disruption including diabetes
mellitus, altered
testosterone and thyroid hormone levels, neurological damage including
cognitive and behavioral
alterations in offspring of dioxin-exposed mothers, liver damage, elevation
of blood lipids which
constitute risk factors for cardiovascular disease, and skin damage.

APHA also notes the extreme persistence of these compounds in the
environment and within the
human body, and that levels of dioxins and related compounds in humans in
industrialized
countries are at or near levels where health consequences might be
expected. APHA is very
concerned that nursing infants in particular are ingesting quantities of
these substances that are
far in excess of acceptable amounts, and that infants may be far more
sensitive to the toxic
effects of these compounds.

Contamination of the food supply (including meat, milk, fish, and mother's
milk) with dioxins is
a serious public health concern.

APHA urges the EPA and other governmental agencies to use the results of
the dioxin
reassessment project to:

· Decrease the new production of dioxins and dioxin-like compounds at the
source through
pollution prevention and strict controls on emissions;

· Aim for as close to a zero emission standard as possible, since there is
little to no apparent
margin of safety;

· Expand efforts to monitor the human population for body burdens of
dioxins, particularly
high-risk populations such as nursing infants, veterans and immigrants
potentially ex posed in
Vietnam, and dioxin-exposed workers;

· Step up efforts to monitor the environment, especially the food supply,
for dioxins and related
compounds; and

· Continue to increase efforts to understand the public health consequences
of dioxin exposure,
particularly among high-risk populations, through further clinical,
toxicological and
epidemiologic studies.

APHA further urges continued public input on the reassessment documents and
policy decisions
arising from the conclusions.


Tony Tweedale              || "I'm not going to get involved in any
Bx 7941                    ||   of that peer-reviewed mumbo-jumbo."
Missoula, Montana 59807    ||      -Rep. John Doo<-->little (R-CA)
406-542-1709, fax 728-0867 ---------------------------------------
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