Re: Prions not destroyed by incineration?

["Ralph Ryder" <ralph@tcpub.demon.co.uk>]

-----Original Message-----
From: Mike Ewall <catalyst@envirolink.org>
To: Multiple recipients of list DIOXIN-L <dioxin-l@essential.org>
Date: 26 January 1999 09:26
Subject: Prions not destroyed by incineration?

Hello List
I'm never sure if I should post things like the following on the
dioxin-list.
Perhaps we should have 'an associated odds and sods list.
I apologise to those you who aren't interested and suggest you hit the
delete.

The following is a piece taken from the forthcoming community guide  "The
Reality of Iniceration' a joint Communities Against Toxics and NEWs
publication which should be coming out sometime around May/June. (hopefully)
It contains by presentations by Prof Lacy and Dr Vyvyan Howard at a
conference 'BSE Incineration and You' held at Wrexham, North Wales in March
1998.

Copyright © R Ryder, Communities Against Toxics



Newspaper editors, obviously greatly concerned about the monetary aspect of
BSE made sure the British public had no shortage of information about the
financial cost to the government, the beef industry and the country’s
farmers.
 Later they became slightly more interested in what, to those of us not
bitten by the monitary, materialistic bug, is ultimately of more importance.
The fact it’s quite possible within the next couple of decades millions of
Briton’s could be facing a devastating, incurable, disease.
 In the words of consultant neuropathologist Dr. Helen Grant:
 “We are all now part of a huge, uncontrolled transmission experiment whose
outcome, whose awfulness we cannot yet judge or comprehend.”(1)
 Current evidence shows the blame for this can be laid squarly at the feet
of the last Conservative Government’s and their money crazed, capitalist
obsession of putting business interests above all else.
 Their the lack of action has already cost 27 lives through
Creutzfeldt-Jacob’s Disease (CJD), caused a number of farmers to commit
suicide, cost thousands of jobs in the meat trade, and an estimated £4
billion in lost exports by the year 2000.
 Before the 1979 election, documents show that the Thatcher government liked
new arrangements in which:
 “Because of the present economic climate, the beef industry should itself
determine how best to produce a high-quality product.”
 The government agreed to the introduction of weaker regulations allowing
industrialists’ to make major decisions on feed produce. As a result the
manufactures of cattle feed introduced BSE into the human food chain by
adding diseased sheep carcasses into the feed process, then in order to
reduce costs, they lowered the process temperature allowing the
prion/infectivity to survive.
 The ensuing human deaths and financial fiasco are a result and once again
we are witness to the foolhardiness of allowing industry to monitor itself.
 “I think now we remember again that that sort of crazy, free trade,
language reaps a very strange harvest,” said Prof. Tim Lang (Centre of Food
Policy, Thames Valley University).
 For fifteen months after it became clear that animal feed containing brains
from BSE infected cattle was connected with the deaths of other cattle - the
government allowed food producers to continue using the ground-up brains and
spinal cords of infected animals in food for human consumption. These
sections, described by MP Dennis Skinner (referring to BSE free cattle meat
being sent abroad), as “the scragg ends”, were OK for the British consumer.
These were in all probability used for the cheaper burgers, sausages,
pasties and pies eaten mainly by the poorer sections of British society.
 Failing once again to observe the ‘Precautionary Principle’, the government
allowed this practice to continue for this period maintaining there was no
proven scientific link between BSE and Creutzfeld Jakob’s disease.
 This was a nonsense born of political and economic necessity. The truth is
that similar strains of the BSE type diseases are transmitted from one
species to another 7 times out of 10 in laboratory experiments. (2)
 Documents obtained by the BSE inquiry currently underway revealed a
reluctance by the ministry, then headed by Gillian Shephard, to undermine
the Thatcher Governments de-regulation policy.
 The ministry overrode the advice of government appointed experts who
recommended the creation of a permanent advisory committee on feedstuffs.
Nicholas Soames, then the junior Agriculture Minister with responsibility
for food safety, told the commons at the end of 1993 that the government had
decided that excising committees could advise adequently on feedstuffs. In a
letter to Baroness Cumberlege, a junior Health Minister, Soames wrote:
 “The main thing that worries me is that if we set up the proposed committee
it is almost bound to recommend tightening regulations or other forms of
controls.”(3) Hardly the words of a responsible government official
concerned about public health.
 So, in order to avoid placing restrictions on industry, the ministers
ignored the advice of their own appointed experts with devastating
consequences.
 Scientists have proved that ‘Mad Cow’disease has caused Creutzfeldt-Jakob
disease. The final confirmation comes after years of uncertaincy and will
bolster calls for compensation for victims’ families.”
 David Churchill, whose son Stephen was the first and youngest victim of the
new variant of CJD said at the time of the confirmation. “If they come out
and say it is definately BSE it’s a dreadful result because it means that
whoever mismanaged the food chain killed our son.”(4)
Some farmers have said that the manufacturers of the animal feed containing
diseased remains didn’t declare the true contents of the feed, so it is
unfair to lay the burden of blame at the farmers’ doorstep.
 If this is really what they think then why haven’t we seen farmers at least
attempting to sue the animal food producers for their lost cattle?  Surely
this is worth trying under the 1993 legislation on the ‘Duty of Care’ on
waste that was set in place to protect the public at large from the
irresponsible actions of others, including manufacturers? The feed was
produced after all from a waste product, infected sheep.
 What about the farmers who for more than a year knowingly sold infected
beef for human consumption after the government refused to pay them full
compensation for infected animals? As a consequence, it’s quite likely that
hundreds of thousands of infected, and potentially infected cattle, went
into the human food chain. Were these farmers not guilty of violating some
form of Duty of Care to the people who ate their produce?
 Dr. Stephen Dealler, (Consultant Microbiologist, Burnley General Hospital)
has studied BSE since 1988. He believes that when those first early cases of
vCJD developed and people died, there were only about 10 reported cases of
infected cattle. A ratio of one to one.
 Dr. Dealler, believes it is possible as many as 10 million people could be
affected, while Professor Richard Lacey, (Microbiologist, Leeds University)
accused by some farmers of being responsible for the BSE scare ‘single
handed,’ believes: “the worst case scenario is that half the population
could be vulnerable.” A mind boggling 28 million people.
 There have now been 27 deaths from vCJD. It is estimated that at one time
the British public were consuming an average of 250,000 BSE infected cattle
a year. The government admits the diseased brains were still being fed to
cattle more than seven years after the practice was banned.
 John Pattison, one time chief adviser to the government on BSE has spoken
of an epidemic: “on the scale of Aids.”
 One would think that such a statement would have alarm bells ringing in the
corridors of power, but no! The reaction of many MPs, besides Soames and
Shephard, showed  incredible apathy and highlighted just how out of touch
with reality these ‘ivory towers’ representatives are. Tory MP Paul Marland,
(West Gloucestershire) was urging the Secretary of State for Health to:
 “...do nothing at all”, because according to him, “...such health scares
and food scares have occurred before.”
 Dame Elaine Kellett-Bowman (Lancaster) was saying:
 “No one should stir up unnecessary panic where panic is not required.”
 Statements like this, and the one by the now disgraced Neil Hamilton
(Tatton), who accused the media of being:
 “Alarmist and running a scare campaign - seeking sensationalism...” make
one wonder just who is suffering from brain disease and who the ‘mad’ cows
really are.
 Many farmers accuse Prof. Richard Lacy of scaremongering over the number of
expected victims. They base these accusations on the time span since BSE was
first discovered and the small number of victims todate. The fact is that
the brain damage found in these younger victims was a different kind of CJD
(called vCJD) than that found in patients with other forms of the disease.
Ten years is comparable with the incubation times of other spongiform
encephalopathies.

Who Pays The Fiddler
 The claims by the government that its had taken the advice of ‘specialists’
about the danger of a transfer from cattle to humans is disputed by many of
the scientists working in the field of BSE research.
 “If you wanted someone to tell you that BSE wasn’t a risk you could find
someone, if you wanted somebody to tell you that BSE was going to go away,
you could find someone. If you wanted somebody who was going to tell you
just what you wanted to hear, you could find one of those as well,” said Dr.
Dealler. “...and that’s what has happened to these major committees.”
 Professor Lacey also believes that government has been selective in their
choice of experts:
 “They identify the people whose views are concordant with their policy.
They wanted to hear advice that supported little action,” he said.
 What can only be described as the apathetic, in some cases even cavalier
attitude of Tory ministers toward BSE and public health has seen an
appalling lack of genuine research being conducted in the 12 years since the
first case was reported.
 The public became very concerned about the effects the infected meat might
have on the ‘burger consuming” youngster of Britain. In an attempt to pacify
them, the ministry called together its experts for discussions. The
statement issued by the Minister of Health, Stephen Dorrel, after a weekend
of talks with the members of the Spongiform Encephalopathy Advisory
Committee (SEAC), had concluded that:
 “...infants and children are not likely to be more susceptible to BSE than
adults.”
 This did little to convince the general public, many of whom were aware
that young children are still developing many of the body’s natural defence
systems and consequently are more susceptible to infectious diseases.
 The validity of Dorrel’s statement was made even more doubtful when an
extremely worried looking Professor Jeffrey Almond, a member of the 13
strong SEAC, talked to the press about the pressure being exerted on him and
his colleagues by ministers over the weekend in question stating:
 “...to try to come to some rational decision when the scientific data is
very scant has been very difficult.”
 “Surely to ask scientists to come to a conclusion on such an important
issue as child safety without sufficient information is not only
unscientific, it is totally irresponsible”, said a spokeman for CATs. “Not
only does it put tremendous pressure on the scientists concerned, it
conveniently shifts the burden of responsibility away from the government
officials who can now proclaim: “We took the advice of the experts at that
time,”

Mechanism & Entry
 There is still no understanding of the mechanism of BSE, or indeed the
route of entry into the human body. Laboratory experiments on animals have
shown that the prions can be inhaled or enter the body through the eye.(5)
 Professor Gareth Jones (Cambridge University) said: “It is the same time
bomb as asbestos.”
 There is a mounting body of opinion that if hundreds of thousands of tons
of carcasses and waste are incinerated the agent that leads to BSE and vCJD
will enter the atmosphere.
 “A huge problem is that the material they have ground down is not small
enough be effectively incinerated. Tests on mice and rats have shown the
germ can be absorbed through the eye.” said Prof Jones.
 “The germ is a protein and it is logical that it could enter the body in
various ways including via the lungs.
 We don’t know whether a microgramme or a ton of the germ is enough to
trigger the disease.”(5)
 Some scientists are unsure as to whether the disease is actually infectious
because BSE doesn’t meet the criteria of Cox Postulates, the method of
determining whether a disease is infectious or not. Cox Postulates means the
agent can be taken from an infected animal - transferred to a culture tray -
cultured - transferred to another animal, and the animal then develops the
disease. BSE has not been cultured in the laboratory.
 Why after more than a decade since the first cases were recorded, do
scientists know so little about this terrible disease? Most of the research
has centered around sheep scrappie and very little has actually been
conducted on the BSE prion itself.
 In an attempt to eradicate BSE, the government has called eight million
cattle to be slaughtered over the next five years. They are still searching
for a long-term, safe way of disposing of the huge numbers of bovine
carcasses piling up. There is currently 260, 000 tonnes of suspect material
stored in 12 warehouses around the country.costing the British taxpayer
£7million a year. This figure is expected to rise by another 65,000 tonnes
this year. There have even been discussions about whether to charter massive
refrigeration ships in which to store the overflow.
 Incineration has continually been put forward by government officials and
engineers as “a tried and proven technology” to deal with the mountains of
animal waste. SEAC recommended that bovine waste could be incinerated in
power stations, cement kilns and incinerators. Disturbingly, they refused to
place copies of the minutes of an important  meeting in the public domain on
the grounds that this would not be in the public interest.
 Later revelations demonstrated that within a few months of issuing this
advice the Government had possession of data that showed this recommendation
was seriously flawed.
 The Environment Agency (EA) and Government departments, including the DTI
and MAFF deliberately, (and probably unlawfully), withheld critical
information from local authorities on the dangers of incinerating BSE
infected waste. This claim, made in 1997 by the Public Interest Consultants
(PIC), was a reaction to a story in the Observer “Strands of BSE survive
1500 C test”[6]
 PIC claimed that local authorities have been forced to make critical
decisions over proposals for new animal waste incineration plants without
access to vital information the EA and Government departments had in their
possession for months.
 Roger Lilley of PICs told CATs at the time: “We have been asking for this
information over the last six months only to receive persistent brush-offs
from the Agency [7][8].
 PICs advised a number of local communities threatened with incinerator
applications about the risk of burning of bovine waste that could possibly
be infected with BSE in the face of the misinformation fed to their local
authorities by Government departments on this issue.[9]
 Confidence in the pollution control authorities reached such a low ebb that
local authorities such as Northamptonshire County Council have continued to
refuse planning permission for incinerators on the basis of strong
suspicions about the environmental effects.[10] These suspicions have now
been vindicated. Roger Lilley said:
 “...the credibility of the Environment Agency as a public watchdog is yet
again on the line. There is an urgent need for an investigation to uncover
who was responsible for the suppression of this vital data. Furthermore,
this saga has demonstrated that planning authorities and the public are
unable to rely upon the E A to protect their interests. The current gulf
between planning and pollution control must be narrowed and brought back
under democratic control.”
 Richard Lacey, professor of medical microbiology at Leeds University
believes the decision not to publish the data was political:
 “The infective agent had already been shown to be incredibly resistant at
high temperatures.” he said. “Anyone who says this process will definitely
destroy the infectivity is really very silly. We don’t know. The members of
the advisory committee are there to give the Government reassuring advice.
They are either ignorant of the facts or just puppets.”
 Science’s only known way of testing that material is infection-free is to
inject it into an animal’s brain and see if the disease develops over the
animal’s life span. In the best analysis with calves this  would take five
years to achieve.
 Very disconcerting for communities threatened with applications for, or
living near excising cattle incinerators, is the knowledge that according to
research data in the hands of the Government and the EA, even temperatures
as high as 1,500 degrees centigrade have failed to destroy prions. Trials,
carried out in test rigs at two of Britain’s Power stations have amazed
scientists by showing that strands of material directly related to the prion
remained. With the current test programme it would take at least two years
to establish whether the material still posed a threat to health.
 The EA admitted that it had identified strands of amino acids, the building
blocks for protein, in the ash of cattle burning incinerators, but claimed
it had been impossible to identify whether they were from prions. The Agency
said these were being classified as ‘infective’ for the purpose of risk
assessment.
 This news poises grave doubts as to whether incineration is really a safe
method of dealing with infected carcasses - or whether it simply provides a
very efficient method of spreading the prion far and wide.
 “Killing prions is not just a question of temperature alone and it is very
expensive to test if they are still present,” says Dr. Richard Bruce, boss
of the Hartington Group of Consultants. [10]
 One would thinkl this would potentially throw a spanner into the Government
’s disposal programme. But no! They still plan to dispose of all cattle over
30 months old by incineration.
 Around 1,000 carcasses a week are currently being disposed of at 10 small
incinerators around the country. Company’s are falling over themselves to
get in on the ‘incineration’ act.
 Although experts and regulatory officials are telling people living near
existing and proposed incinerators; “strict regulations will protect them”,
emissions tests performed by the Environment Agency, which gives licenses to
the operators of the incinerators, do not cover prions.
 The government had at one time asked Power stations to burn cow parts. They
believed this would provide the cheapest method of disposal. However,
National Power, Scottish Power and Powergen all conducted trials to burn
carcasses and expressed concerns about handling and burning possibly
infected materials. They were worried about the effects of cattle meal and
bone on their expensive equipment and the concerns about risks to health
from their staff and local residents.
 Powergen, which has burned cattle at a 1 MW test rig at its Ratcliffe
station, seems the most likely to apply for a licence to burn cattle and was
reported to be buying a materials handling system for bone meal and tallow
for its Ferrybridge C power station. But, like the other power companies, it
must still gain approval from the E A  to burn cattle waste. [11]
 Powergen refused to confirm or deny reports that it is/was seeking
indemnities to cover it against any damage caused to its boilers by calcium
deposits and any effects the emissions might have on its employees and local
residents.
 “There are still many questions to be answered,” says Powergen.

ReChem
 The only large commercial incinerator operator with a licence to burn cows
is the ReChem hazardous waste facility at Pontypool, South Wales. Mike
Averill, head of waste management at ReChem has accused the government of
letting power stations avoid European emissions regulations to burn cattle.
 His plant however, has not escaped criticism on this issue. “It’s worrying
that  a plant surrounded by heavy chemical contamination, proven to come
from its operations, can be deemed worthy of a licence to burn highly
infectious animal material and nuclear waste. If the chemicals can get out
and contaminate the area so badly, what the hell is there to say the
infective agent cannot get out through the same way?” said a member of a
local CATs campaigning group.
 In the meantime despite the evidence of living prions the government is
increasing the country’s capacity for incineration by funding the expansion
of existing incinerators.
 In most cases these existing incinerators are far from ‘state of the art’
facilities and can be seen simply as glorified tin sheds or ‘backyard
barbecues’(12). Most have no pollution abatement equipment with ash, soot
and dust being scattered around neighboring properties.
 Work has been funded by MAFF to investigate the use of giant microwave
ovens to dispose of whole cattle carcasses and Essex-based BRC Environmental
Services hope to obtain funding from MAFF to build a £250,000 test unit
capable of taking whole carcasses.
 “Techniques such as microwaving, chemical and microbiological treatment are
very feasible and far less polluting,” says Roger Lilley. “We have been
calling for the use of microwave induced pyrolysis for treating clinical
waste for some time.”(11)
 To date, microwave pyrolysis seems to be the only reliable (?) method of
killing off prions. In addition, it is the only alternative to incineration
being considered for MAFF funding. Other proposals are in the pipeline and
MAFF is appealing to industry and the Institute of Mechanical Engineers to
offer ways round the problem.
 “The worrying thing about going to engineers for advice is they are not
toxicologists. They always say that incineration is a proven method to
dispose of all waste, although the evidence it’s not is quite overwhelming,”
said Ralph Ryder. “Perhaps they should be told it’s in their remit to
consider the toxicity of the materials involved; whether they would be
content for their family to live next door to a plant burning BSE infected
materials; and if they would be happy to let their children play outdoors
among the steam plume as it grounds,” he concluded.

ToxCat
A number of people have contacted Communities Against Toxics expressing
their fears about the lack of information available on BSE and incineration.
The conference report in this edition of ToxCat took place in March in
Wrexham North Wales when delegates heard eminent speakers highlighting the
appalling lack of knowledge about the prion, its infectivity, its means of
entry into the human body, and its so called ‘safe’ disposal by
incineration. Disturbingly Jeff Rooker, the Food Safety Manager (I wonder
where his department have been for the last decade?) said in July ...”
contracts to burn the huge mounds of carcasses and then send them as ash for
burial were expected soon.”

STOP PRESS - 17th JULY!
White corpuscles are now being removed from blood to be used for transfusion
because of the danger of introducing vCJD.


BSE References
[1] Interview Dr. Helen Grant by James Erlich quoted in The Tory Record, An
Assessment The Commission For Assessing The Conservative Record. ISBN
1-897766029-7
[2] James Erlich. BSE (Mad Cow Disease) The Tory Record, An Assessment The
Commission For Assessing The Conservative Record. ISBN 1-897766029-7
[3] Michael Hornsby, The Times. Saturday March 21, 1998
[4]Reports in The Sunday Times (28 September 1997)
[5]Geoffrey Lakeman & Oonagh Blackman. Daily Mirror Oct 9th 1997
[6] Strands of BSE Survive 1500C test. Observer 27/4/97 by Michael Paduano
[7]Letter from PIC Partner Alan Watson 2.10.1996 to the Environment Agency
Bristol Head Office asking for any information of which the Environment
Agency were aware on the issue of incineration as a method of destroying
prions.
[8] Letter from Dr. Stuart Stearn of the Environment Agency dated 7.2.1997
to Alan Watson (chasing replies to letters in October): “Thank you for your
enquiry which I understand was received on 21 January by E-mail in which you
asked about monitoring data relating to the destruction of prions by
incineration and combustion. “Whether or not a prion is infective for BSE is
believed by some experts to be a function of their shape or stereo
chemistry. We do not know of any data which directly compares the
effectiveness of this function before or after incineration. However a
number of studies have examined the effect of high temperature on
infectivity and one such by Dr. David Taylor, published in the Journal of
General Virology, December 1994, on the effects of dry heat on infectivity
of BSE. These all conclude that high temperatures are very effective in
reducing infectivity. I hope this is helpful.”
[9] Letter of 6.11.1996 from S Thomas, Environmental Health Officer of
Carmarthenshire County Council to Alan Watson: “I can confirm that officers
from this department have carried out a considerable amount of research in
respect to this matter and they are led to believe via sources in MAFF that
German research has showed that the prion is totally inactivated at
temperatures of 133 C 3 bar pressure for 20 minutes.”
[10] Planning permission for an incinerator at Guilsborough, Northants to be
operated by Time Right was refused on 15.4.1996.
[11] Professional Engineer  6/11/97
[12] Dr. Dick Van Steenis, Speaking about a cattle incinerator at a public
inquiry in Wrexham, 23rd April 1998.

Copyright © Ralph Ryder, Communities Against Toxics




The following presentations are taken from the conference ‘BSE, Incineration
and You,’ held at St. Christopher’s School Hall, Wrexham, North Wales on
March 14th 1998. Organised by local campaigners and concerned organisations,
more than 200 people heard a number of eminent speakers on some of the
problems associated with incineration including, emissions, monitoring,
legislation and regulations. Professor Richard Lacey, Microbiologist, (Leeds
University) spoke of the serious doubts about the technology of incineration
as a safe method to dispose of the BSE infected carcasses. Dr. Vyvyan
Howard, (Senior Lecturer, Liverpool Universities Foetal and Infant
Toxico-Pathology Unit) spoke of the effects of chemical by-products of
incinerator on the developing foetus and human health. Alan Watson Public
Information Consultants, (PIC) told of the general situation with modern and
past incinerators. Ralph Ryder (Coordinator Communities Against Toxics)
spoke of the inefficiency of the regulatory bodies set in place to protect
public health. Solicitor Ms. Giselle Bakkenist (Leigh Day & Co.,
Manchester), told how the law can be used to protect communities and how
individuals can take action against dirty industry. This ToxCat features the
talks of Professor Richard Lacey and Dr. Vyvyan Howard.


Professor Richard Lacey

“I think first I had better tell you what BSE stands for” said Professor
Richard Lacey: “Blame Someone Else.”

 I’ve been asked to tell you my background: I started off with a degree at
Cambridge University in biochemistry where I did medicine, I briefly
specialised in pediatrics and babies. Then I went back to my hobby at the
time, which still is one, which is growing things. I started growing
bacteria and went into microbiology.
 I have been in Leeds for about fifteen years. During this time I started
off with the interest in drugs and anti-biotics based in human medicine and
also in veterinary medicine. Then for four years, believe it or not, in the
late 1980s I advised the last government. True! They didn’t take any notice
though.
 Then in the mid 1980s the infections in food started to rise. At this time
we were controlling most other infectious diseases - even HIV wasn’t taking
off as it might have done. TB was on the run and the vaccinations against
measles etc., were working, but food poisoning was on the increase. As I
have knowledge of veterinary and human medicine this was clearly an interest
for us.
 We started off looking at salmonella and listeria. The good news for me was
that the number of listeria cases has dropped and I think we should take
some of the credit for that.
 Early on in 1988 I actually believed the government line on BSE. I thought
it was all sheep scrappie and thought it was no danger to us. But the more I
looked into it the more worried I became. I am getting even more worried,
particularly from the point of view of incineration.
 I think if you take any industrial process near a society or near
agriculture, we should demand the following before we actually use it: we
should first of all know what exact temperatures and times are needed to
destroy the infectious agent. Both temperature and time are important.
 For example If you take bacteria that are easily killed by heat, take
salmonella. You can either kill salmonella with 5 seconds at 70 degrees
centigrade, or 5 minutes at 60 degrees or 50 minutes at 50 degrees. So the
higher the temperature you get, the less time is needed. We should also have
a margin of safety, for example with pasteurising milk. We could have 70
degrees but in fact we have 72 degrees to make absolutely certain we get up
to 70 degrees.
 Then we should have a situation of satisfactory control in practice and
monitoring, and we should have research that shows us what temperatures and
times are needed.
 Now - previous speakers have very elegantly described chaotic shambles with
incinerators and dangers. But with BSE it’s one worse because we haven’t got
the basic knowledge. We don’t actually know what temperatures or times are
needed to kill it.
 You might very well ask why, in 1998, 12 years on from when the first case
of BSE was identified, why is it that no research has been done that
identifies which temperature and for how long, gets rid of the infectious
agent, and why hasn’t that research been done? Why hasn’t any useful
research been done? It’s very important as without that information how can
we possibly do anything but speculate about safety?
 The nearest experiments that have been done are in the United States,
mainly in New York, taking not BSE but sheep scrappie. In fact BSE tends to
be tougher then sheep scrappie, it’s different.
 But what they did in America, (this was published 10 years ago) they show
that if you heat sheep scappie infectivity to 360 degrees centigrade, for
one hour, the infectivity survives. We haven’t got an end product, we don’t
know how to get rid of it. We also don’t know the exact chemical structure.
We don’t know the nature of the material, the chemical - the actual
chemistry. We know it is an infection because it’s capable of passing
between animals by experiments and so on, but we don’t know exactly what it
is. There might be a very strange type of carbon in it or something that
makes it very durable. We just don’t know. So we haven’t even got the
beginning of an assessment. We can’t do a risk assessment.
 The Environment Agency is extraordinary. As one of the previous speakers
showed it is propaganda, pure and simple. It’s talking about ‘risk analysis.
’ We can’t do risk analysis because we haven’t got the information -in the
same way we cannot actually say what the danger to the human population
already is because we can’t work it out.
 Now there is obviously a prima facie straight forward danger, if the
material is spread from an incineration to the environment, and those of you
who are farmers, I’m concerned about your livelihoods, because, if the
incinerator taking BSE material is placed near farmland - there is
absolutely no reason why the infectivity won’t get on the grass and get into
animals.
 We know the infection can survive for many years in grass and in soil -
this was demonstrated in Iceland in the 1940s with sheep scrappie. They had
a high incidence of disease in their flocks and they slaughtered them all
and replaced them with lambs from a scrappie free area - New Zealand. Within
3 or 4 years the disease had returned. Therefore it must have been picked up
from the environment. This is published data, I’ve re-published it. This is
well known scientifically.
 Now to come back to the Environment Agency’s claims: They say that the risk
to the human population is less than one in a billion per year. They have no
idea about that. They’re premise of this risk is completely flawed. Their
talking of an infectious dose that might come up of being one gram. Now one
gram of microorganism is a huge number, it’s billions and billions and
billions. It cannot possibly be one gram. One gram of the pure infection, if
put into food, could well be enough to destroy half the population of this
country. It’s ridiculously too high to claim that is the infectious dose.
But probably more worrying is the claim that it’s based on. If we are
exposed to the infection agent that is like eating it. They’re comparing the
route of inhalation like eating.
 Now we know in general that it’s much easier for micro-organism to get into
the body from the lungs than it is from eating. The lining of the gut is
pretty tough. It’s only the occasional accident for example with a cut
somewhere, for the bacteria to get in from the gut. But the lungs are very,
very easy to get infection in.
 I’ll give you a few examples: Legionnaires disease, you just need a few
bacteria in a particle of water. TB, Influenza. All sorts of infections are
very easy to get into the lungs.
 Unfortunately, no research has been done on this route. Again, believe it
or not, there’s no research been done on looking at the potential of these
diseases,  TSEs [Transmissible Spongiform Encephalopathies] as they are
called as a group, to get into the lung. But what we do know is that they
can spread animal to animal. If you had an infected sheep, with a sheep
definitely not an ineffective source, and put them in the same pen, then the
infection can spread. That’s then called horizontal transfer.
 Therefore you can see that the criteria I’ve outlined about the basis for
safety cannot be met. We don’t know what heat is needed, we think that the
pupil can breathe it in, and that’s assuming the incinerator works well.
 Then you’ve got the problem of what happens to the ash? Where does that go?
There are very few plans put forward to it, because we know that the
incinerator will not destroy the agent, it has been found in ash from sorted
sheep. Where does the ash go? Presumably to landfill sites?
 Now I think what I’ve told you should say to you ‘you do not want to have
an incinerator near a population or farm animals because of this risk.’ It
would be absolutely tragic if we got rid of BSE at farm level and we were to
re-introduced it with animals coming from somewhere else.
 So! What are we going to do with the mounting mountains of unwanted meat
and bone meal? It’s going to be very difficult.
 At the moment a lot of dead animals are going into landfill sites all over
the country. I was met by three knackermen yesterday who pointed that about
a million animals on farms which die, are being put into great collecting
ditches and then gradually filled up, some of which contain hundreds of dead
animals. This practice is not allowed in other European countries and they
estimated to me that about a million animals a year - I’m not saying it’s
round here, this is particularly in Scotland, are suffering a fate like
this. That is not satisfactory, in the same way that where you are going to
put the ash is not satisfactory either. It can’t go to landfill sites -
indeed, the European Union funding of our BSE problem requires incineration,
and that is beyond our control. Infected carcasses have to be incinerated.
 So what I would like to see is these sites identified with great care and
discussion, preferably in uninhabited parts of the country, preferably in
offshore islands. It’s going to cost more money. We do not want the
haphazard, random, promotion of incinerators for the convenience of the
people who operate them, or for using existing facilities which aren’t up to
the job. The reason for the proposal near here is because it’s already there
and it’s the cheapest option. We have got to take this much more seriously.
Instead of going for the cheapest option, you’ve got go for the best option
for everyone.
 The alternative, the other thing that can be done, is burning under the
ground. It is possible to drill holes into rocks and use high pressure heat
and destroy the agent like that. That probably, as far as the environment
goes, would be the best option, but again it is going to cost money.
 Now unfortunately [with] most planning application like the one facing you,
the Department of the Environment and Governments authorities are trying to
tell you the that the safety issues aren’t relevant, but I assure you they
are.
 I want to suggest to you finally that the onus is on the authorities to
show that the system is safe. It’s not on you to show it’s dangerous. You
want to attack them that they have to show it’s safe. All they will do is
say: “Well we’ve asked the experts, we’ve asked Spongiform Encephalopathy
Advisory Committee who tell us it’s safe.” That is what the Environment
Agency say, but the members of that committee don’t understand what’s going
on, and they cannot prove it’s safe. So if you take that line and ask them
to prove its safe, then you will win the case if you want to fight this
application, so I wish you all the best.

Thank you.


Dr. Vyvyan Howard, Senior Lecturer at Liverpool University’s Fetal and
Toxico-Pathology Unit.

 “I first got involved when there was a proposal for a waste to energy
incinerator on the Wirral. At that time I was astounded to realise that I
knew very little, as a qualified medical man, about the health effects of
some of the processes that are going on around us. Since then I’ve learnt a
lot and indeed we have had a great deal of support from our local
councillors in opposing and rejecting several incinerator applications on
the Wirral, which for clinical and municipal wastes remains an incinerator
free zone. So your councillors, if they are suitably informed can be great
allies and I hope that’s one of the results of today’s meeting.
 These results represent real life. You are told that the incinerator that
is going to go up in your town is going to be run to government’s standards
and there are going to be no problems.
 This was the Royal Bournemouth Hospital clinical waste incinerator, the
public inquiry for which I gave evidence. (Fig 1) This is hydrogen chloride
gas, 3.6 milligrams per cubic metre, a very low level, and the second level
was 1.5 again a very low level, this was during commissioning. Then there
was a 3 month gap. The next measurement 498, five times over the limit,
could have been going on for 3 months, one of the precusers of dioxins. This
is reality, incinerators don’t work to specification all the time, we all
know that. Because effluents are not measured continuously you can be
exposed to high levels of pollutants for periods of time without realising
it. So if you accept one of these plants into your midst, be aware that it
won’t work to specification. I think this is a very important message which
the other speakers have all talked about.
 Now there are a number of things going on with human health patterns which
are worrying. We don’t know the answers to why their changing but I think we
are all probably aware, for example, of the fact that for breast cancer in
the 1960s there was a 1 in 20 chance of women developing it, now it’s 1 in
11. In some parts of the United States it’s 1 in 7. In fact the general
lifetime risk of getting cancer in the 1950s was 1 in 4, it’s now below 1 in
3. In fact last month it was announced in the press that cancer had
overtaken coronary artery disease as  the biggest killer in our society
currently.
 Testicular tumours in young men have more than doubled in that period;
brain tumours have been increasing at 2% per annum for the 20 years, that’s
a 40%  increase in primary brain tumours; in pediatric tumours there’s a
massive increase in non-Hodgkins lymphoma. Now we don’t know why this is
happening, but all we can say is in that sort of time scale for these
changes in human health must be happening because of our environment or the
way we live.
 I just want to do a little bit about chemistry because this is rather
important for what I’m going to tell you about health effects. Sodium
Chloride, common salt, we can’t live without it. Life evolved in a solution
of it, the sea. Three percent of the earth crust is made of it. In fact, all
the chlorine on the planet has been tied up, as salt, until about a 100
years ago. And then by a process of electrolysis, and Runcorn was one of the
first plants, we started to split it into sodium, (to make caustic soda for
many chemical processes) and chlorine gas. This chlorine gas, the chemical
industry has to do something with because you can’t let it into the
environment. It’s highly poisonous. So a whole industry has grown up. What
shall we do with chlorine gas, this by-product? The solution has been
largely to tie it to carbon. The carbon comes from the oil industry and the
coal industry. Our bodies are made of carbon. There are many organochlorine
compounds, over 11,000 on sale commercially; solvents, paints, wall
coverings, medicines, pesticides, you name it. PVC, you can’t go more than a
couple of inches without finding Polyvinyl Chloride. This forms a large part
of our throw-away society.
 If these organochlorine compounds become involved with a combustion
process, then new compounds are formed. Of these the dioxins are the most
widely trumpeted, but I must tell you there are many many thousands of
different compounds produced by combustion. The toxicology of the majority
we know absolutely nothing about, literally nothing.
 So! Forty million tons of chlorine gas produced per year on the planet.
Thirty five per cent of that goes towards making PVC and a lot of that ends
up in incinerators.
 Why should we be worried about organochlorines? Well, there are a number of
reasons why we should. Firstly, they are completely alien to life. You and
I, everyone sitting here, have no naturally occurring carbon chlorine
compounds in our bodies. Any that are there have been produced actually by
anthropogenic activity. They persist for many years decades or even
centuries. They accumulate in living tissue, most of them are fat loving,
that means that they bio-accumulate and bio-concentrate. Now many are toxic,
some are designed to be, pesticides for example. This is really what I
wanted to concentrate on. The fact that at the time when you are forming
yourself in your mother’s womb is when you get the highest dose. This is
because your mother passes them on to you across the placenta and then
subsequently in the breast milk. They have a number of affects which
probably don’t affect adults too much, but can affect the foetus.
 Organochlorine compounds get literally everywhere. This was the result of
study by Rick Lear at Liverpool University. (Fig 2 & 3) He took fish from
the Irish Sea and the Mersey Basin and looked for organochlorine compounds
in them. This was about 8 years ago. These are a couple of Dab that were
caught off Walny island, each spike is a organochlorine compound, so there
are PBCs there - there are pesticides. You can see a lot of the peaks there
were not actually even identified.
 This is part of our food chain. We are at the top of the food chain. Things
concentrate up the food chain. So there have been studies showing that if
you take the concentration of dioxin in water, say in the Great Lakes, and
you follow it up through the food chain, from the plants to the fish, to the
things that feed on fish, you can find a concentration say in a Herring Gull
25 million times higher than it would be in the water.
 So with these compounds, the basic message is when you make them they don’t
go away just because you put them in an incinerator. The incinerator is
actually a method of dispersing waste, you change its chemical composition
into ash and gas and particulates. You’ve got exactly the same mass of waste
that you started off with. You just happen to have dispersed a lot of it.
Once you have dispersed it don’t think it’s gone away, it’s going to come
back to you in your food chain.
 What has been the most abundant source of dioxin pollution? It has been
municipal and clinical waste incinerators. (showing slide) This is from the
United States study which has been the biggest ever made on dioxin
production. You can see that these two top things here (logarithmic scale)
are municipal waste incinerators and clinical waste incinerators. They have
probably given rise so far to between 50% and 80% of the dioxin that have
been deposited on the land and in the water courses.
 But now of course they’re being improved. It’s new incinerators. They have
lots of new and complicated devices which - as I have just demonstrated in
one from Bournemouth don’t always work. Even if they do work, these things
are still producing toxic substances, albeit at lower levels than before.
 Where have we got to now with respect to human health? This is the position
we seem to be in. Mr. Average has about 9 parts per trillion in the body.
Per trillion means per thousand million parts, not a lot. However, at this
level there is experimental evidence that enzymes systems can be switch on
and that in some animals you can get enhanced viral susceptibility.
 Now already the Coalite plant has been mentioned. The families living off
the milk on the contaminated farms had about 45 parts per trillion. They
were quite badly affected, and the people working in the plant, the guys
actually manufacturing some of the organochlorine compounds who we have
studied, also had some raised levels.
 By looking at some of the things you can see basically the effects that
dioxin-like substances can have. They can disrupt endocrine systems and
affect brain development. There’s quite a lot of evidence of learning
difficulties associated with exposure to these substances, and they can
surpress the immune system. On top of this we know they are cancer inducing
agents, but this is a relatively weak effect. The really worrying effect is
on the next generation.
 I have done some studies on the Coalite workers and we have shown that they
have lower than average testosterone levels, that’s the male sex hormone,
and they also have lowered than average immunoglobulin M levels. That’s an
antibody which helps you to fight infections.
 But that’s actually just reproducing data which has been shown around the
world in other studies. These are dioxin levels in foetuses that we have
studied in Liverpool (showing slide) and you can see that as early as 26
weeks the mother is already passing levels at 1ppt or 2 ppt. So you get
exposed to these very early on in life.
 Then the child is born, and hopefully the mother starts to breast feed. Why
not? It’s a very human activity. (showing slide) If the yellow bar on the
graph is the amount of dioxin the mothers get in a day, the magenta bar is
the amount the baby gets. Well, it doesn’t look as if there is an awful lot
of difference, but if you divide that amount by the weight of the mother or
the baby you then see the problem is that during the first 6 to 9 months of
your life, that’s when you really get the highest concentration of these
substances, and that is when you are still actually in the process of
developing a number of systems in your body.
 There have been recent studies in Holland which I will tell you a little
bit about.
 Firstly, what is the tolerable daily intake of dioxins?
 Well! the World Health Organisation  tells you it’s 10 picograms per
kilogram of body weight a day (pg/kg/day) (TC: reduced to 6 pg/kg/day in
June). Now, a picogram is a millionth of a millionth of a gram, 10pg/kg/day
means the average 70 kilogram adult could consume 700 picogram of this stuff
a day and would be OK.
 The Dutch Health Council has just recommended a 10 fold decrease in that
level to 1pg/kg/day and they also estimate that already the average Dutch
adult is taking 2 pg/kg/day.
 So, what the Dutch Health Council is saying is actually to protect new born
babies we need to decrease this tolerable daily intake to 1 pg/kg/day. But
we know that the average member of the population is 100% over that and the
average intake of the UK resident is now 3 pg/kg/day
 So the message there is we are going to have to turn the clock back, we are
going to have to be reducing and removing sources of these compounds to the
environment. It’s not good enough to just say: “Well this plant is only
going to produce a tiny little bit more which is not going to have any
effect. No! The evidence that this Dutch Government Council report was based
on is the following paper in Environmental Health Perspective showing that a
group of mothers with high levels of dioxin in their breast milk compared to
a group of mothers with low dioxin in their breast milk. The ones with the
high level actually affected their offspring thyroxin level measurably in a
dose related response.
 So we have hormone disruption at current levels of body burden in a
proportion of the population.
 Other recent findings:
Professor Hoosmans in Groningen has performed a study where they’ve done a
sort of IQ test for newly born children, again relating it to amounts of
dioxin in the mothers’ breast milk. They found that the higher exposed
babies actually performed less well in this “neonatal neurological
optimality test”. They don’t know whether it’s a permanent effect, but it is
measurable at this young age.
 Professor Weissglas Kuperus in the University of Rotterdam has done a
similar study looking at immuno-suppression. She finds indices of
immuno-suppression in babies related to the mothers’ loading in her breast
milk of dioxin-like substances.
 So these three reports are part of the basis for the Dutch Health Council
to recommend to the Dutch Government a 10 fold decrease in exposure for
acceptable daily intake.
 This is really the problem. If you look at any one individual it is usually
impossible to say there is anything wrong with them because they fall within
the normal range. What we are looking at with this sort of pollutant is
‘population shifts’. We are probably shifting the whole of the population by
some small amount. That means that nearly everybody falls within the normal
range.
 It is therefore very difficult to actually nail these things, particularly
when we know we’re dealing with a massive mixture. It’s estimated that we
all now have between 300 & 500 chemical residues in our bodies which would
not have been there 50 years ago, simply because they were not being made
then.
 Actually trying to sort out what that mixture is doing toxicologically is
almost impossible.
 Lets take something we can all relate to like IQ. This is a purely
theoretical example.
 If we shifted the whole population 5 points to the left so that the average
IQ becomes 95. What actually would we have done to society?
 What we would have done is to halve the number of people with an IQ over
130, and doubled the number of people with an IQ of under 70. Now I think
all of us can imagine what that would do for society - it would be a
disaster. But we have to start asking ourselves questions like; what happens
if you shift it 0.1 of a per cent? Or what happens if you make society an
0.2 of a percent more susceptible to infection? What is the effect on our
economy? These are the sort of questions that we’re having to start to ask
ourselves.
 They are only measurable on a population basis, but it’s this background
level of pollution we have which is probably affecting the developing child
the most, which is extremely insidious and indeed very worrying.
 If we look at the time scale over which this has happened it tends to fit
together because the first generation to be exposed to these sort of
substances postnatally was my generation, the post war baby boom. And then
the 1950s saw the first generation who were appreciably exposed in the womb.
By the time we get to the 1970s that cohort is becoming of child bearing age
and actually a lot of the graphs for showing testicular tumours; increased
incidence of cancer of the testes and other hormonally related conditions in
populations, show they really start to lift off at that time.
 I just want to finish by saying one other thing. What I’ve described to you
here is the sort of global risk from having these machines, now there are
local risks as well. Alan Watson mentioned that having an incinerator in
Bolton was equivalent to everybody driving 1,000 miles a year. Now that
brings with it particulates and we inhale particulates. There are a lot of
studies going on at the minute which are showing that particulate
inhalation, particularly of the very small particulates, is related to
increased mortality. There is a six city study being performed in the States
which shows a 15% difference in the mortality rates related to particulate
loading in the atmosphere. The Americans are now attributing 3% of all
deaths in their country, that’s 60,000 deaths a year, due to particulate
inhalation. I’m organising a big meeting in London in July on particulates
and their toxicity. I think this is something you have to consider. The
particles, the small bits and pieces that come out of these incinerator
below 100 nanometres, that’s a 10th of a 1000th of a millimeter. There’s no
filtration system that can stop them coming out. But we know from the
research that is going to be presented at this July meeting, that the ones
that do the most damage are the ultra-fine particulates.
 So there are local concerns as well as these global ones that I’ve talked
about. They are all avoidable by simply taking a sensible and sustainable
attitude to waste management.
                         Thank you very much.

© Ralph Ryder CATs

If anyone is interested there is a part two to this feature. but I think
that is enough for now.

wishing you good health

Ralph Ryder