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Re: More or Less Dioxin???



  cc by email to Mr. Cray: Please read the last paragraph.
  
  Alan Watson wrote:
  
  > So presumably we can now expect you apply these standards to 
  > what looked suspiciously like 'an offhand and casual remark' 
  > from you about the Greenpeace "Dioxin Factories Expose,"`?  
  > (And this really must extend to more than a request for the 
  > field notes)
  
  First, understand that my doubts about the DFE report are based on
  experience with industry and having conducted tests in and around these
  facilities.  In addition, the language of the DFE report is not
  congruant with regards to units, nor does it try to be specific on the
  type of risk posed (actual numbers that mean anything).  A statement
  that some-odd ppb of dioxins were found is MEANINGLESS in the context
  of toxicity.  The type and quantity of specific dioxins and furans,
  along with the eventual fate of the compounds, tell the story.  
  
  So at least half of my critique will NOT be based on someone else's
  research, it will be based on an audit of said data gathering provided
  enough information is provided to make an audit.  It COULD be that they
  have spoken completely truthful, and may have actually understated the
  problem.  But based on what I know of the industry, dioxins and furans,
  and the structure of this report, I sincerely doubt it.  And I mean
  sincerely in the truest sense of the word.  The other half of my
  critique will be based on data gathered by university or government
  researchers, NOT INDUSTRY.  But if I can't break down the original
  data, and comments from other research will be short of a true
  comparison - since that data is much more specific than that in the DFE
  report.
  
  Second, if you want to play by the rules (and as you should know) when
  either a government agency in its quest for research or data, or an
  industry in its proof of compliance, each MUST SUPPLY the field data,
  chain of custody, proof of calibration, a quality assurance plan, and
  the full lab analysis as received from the contract lab.  Especially
  for dioxin data when the final results are measured in nanograms and
  picograms.
  
  As someone who has been an auditor for the USEPA and industry, I rely
  on these notes not only for the validity of the data, but also to see
  the actual results.  And another note for activists: no less than one
  out of ten times I have found errors in the translation from the lab
  data to the final report, either through simple math errors to just
  plain incompetence.  The DFE report as published on the Greenpeace
  website does not summarize the original data as most groups would be
  required to do in a compliance or research position.  No matter which
  contract lab you go to IN THE ENTIRE WORLD, every competent one will
  break out the individual dioxin and furan compounds as listed under the
  International guidelines for establishing a TEQ mass in their summary
  of the analysis.
  
  I don't see this.  All I am asking is for those in Greenpeace to adhere
  to the same standards as anybody else.  In Mr. Cray's response, which
  directed me towards lab data in the USEPA docket on a related issue, I
  don't even know yet if we are talking about the same analyses in the
  DFE.
  
  For Mr. Cray, are the data in the docket the same data used in this
  report?  If not, the request still stands.  If it is, could you please
  be specific as to where to find it so I don't go too far out of my way.
    Thanks.
  
  Sam McClintock
  scmcclintock@ipass.net