No Subject

[slester@essential.org]

To:     Dioxin Activists
        Can You Sign On??
        The More the Better
 
Thursday, August 8, 1996 is the deadline for comments on the EPA's 
proposed standards and guidelines for medical waste incinerators. If your 
group wants  to sign on to these comments, please phone, fax or e-mail 
CCHW by 6 p.m. e.d.t.  Wednesday, August 7. Okay? We can make final 
versions available for you to get to interested press people on Thursday.
 
 
The Air  and Radiation Docket and Information Center
Docket No. A-91-61
The U.S. Environmental Protection Agency 
401 M. Street, SW
Washington, DC 20460
 
An Obsolete Solution to A Clear and Present Danger 
xx Groups Comment On Proposed Standards and Guidelines for Medical Waste 
Incinerators
 
We, the undersigned xx groups, call upon the United States Environmental 
Protection Agency to acknowledge and act upon its own findings on the 
health effects of dioxin when issuing new source performance standards 
and emission guidelines for new and existing medical waste incinerators. 
The agency has insufficient emissions data upon which to base "Maximum 
Achievable Control Technology" (MACT) standards, but ample, peer-reviewed 
data regarding the health implications of air emissions from medical 
waste incinerators is readily available. To assure that the EPA 
recognizes its own conclusions that "the margin of exposure between 
background levels and levels where effects are detectable in humans in 
terms of TEQs is considerably smaller than previously estimated," we 
reiterate some of EPA's key comments from its 1994 draft health 
assessment on dioxin. 
 
In the draft health assessment the EPA finds that:
 
        At current exposure levels, the dioxin-related cancer risk is 
between 1 in 1,000 and 1 in 10,000. This risk level is 100 to 1000 times 
higher than the "acceptable" risk level of one in a million. This risk 
estimate makes dioxin the most threatening cancer causing chemical for 
the general population.
 
        Dioxin related health problems other than cancer may have even 
more impact on public health than the cancer-causing effects of dioxin.
 
        Some health effects of dioxin (suppression of the immune system, 
reduced testosterone levels, reduced glucose tolerance) were found to 
occur "at or near levels to which people in the general population are 
exposed." 
 
        The major route of human exposure is through ingestion of a wide 
variety of common foods containing small amounts of dioxin. This has 
resulted in widespread exposure of the general public. Dioxin has been 
found in very high levels in human breast milk, which lies at the top of 
the human food chain.
        Medical waste incineration accounts for 53% of total known dioxin 
emissions to the air.  
 
The American Hospital Association (AHA)  has challenged the last of these 
findings, arguing that the EPA estimate of 6,700 medical incinerators is 
too high. The proposed standards and guidelines on medical waste 
incinerators accept the AHA count and are based on 2,400 incinerators. 
But this argument over the number of smokestacks clouds the fundamental 
issue: Dioxin is not a potential environmental health problem. It is a 
clear and present danger. The goal of proposed standards and guidelines 
should  not be reduction of dioxin emissions but the elimination of 
dioxin exposure.
 
The proposed standards and guidelines promise a best case scenario of 4.8 
grams TEQ per year of dioxin emissions from MWIs. But this "best case" 
will still force the American people to eat 480 times the virtually safe 
dose of dioxin from medical waste incinerators.
 
In its 1994 dioxin health assessment EPA estimates that a "virtually 
safe" dose is .5 picograms per day for a 150 pound adult.  If you 
multiply that safe dose by the population of the United States, the safe 
total dioxin allotment is 125 million picograms per day or .05 grams per 
year.  This US EPA safe dose estimate for total exposure from all sources 
is almost 100 times lower than the proposed best case scenario just for 
medical waste incinerators.
 
In its 1994 draft health assessment on dioxin, the EPA estimated that 
there were 6,700 medical waste incinerators that produced 53% of dioxin 
emissions to the air. Based on AHA challenges to that estimate, the 
proposed standards and guidelines assume that there are 2400 MWIs, 36% of 
the EPA total. Based on that conservative assumption, the estimate of the 
percentage of total dioxin emissions from MWIs drops from 53% to 19%. 
Based on a 19% share of total emissions,  the safe dioxin allotment for 
all medical waste incineration would be .01 grams per year. The proposed 
standards and guidelines offer as a best case scenario, a level of dioxin 
emissions of 4.8 grams - 480 times the EPA safe dose. 
 
How can the US EPA justify the creation of a new rule on medical waste 
incinerators that would keep adding dioxin to the existing body burden of 
the American people? Why is the government proposing that the medical 
industry invest millions in incineration, an obsolete and deadly 
technology, when cleaner, safer, and less costly alternatives to 
incineration are available?
 
We call on the EPA to issue a final rule that recognizes the agency's own 
alarming findings about the health effects of dioxin exposure. We call on 
the EPA to issue a final rule that uses health-based standards to ensure 
the protection of the health of the American people. We call on the EPA 
to recognize that real environmental protection cannot be found in wet or 
dry smokestack scrubbers. We call on the EPA to recognize that 
incineration emissions cannot be scrubbed enough to protect the health of 
the American people . 
 
Group Names

Citizens Clearinghouse for Hazardous Waste
P.O. Box 6806
Falls Church, VA 22040
(703) 237-2249
e-mail:  cchw@essential.org