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Dioxin '97 Presentation by USEPA Policy Analyst, Dwain Winters (fwd)
This is a summary, done by Pat Costner of Greenpeace, of an EPA
presentation at Dioxin'97.
Following are various points from Dwain's overheads and presentation.
I could not reproduce it in this format, however, Dwain presented a
final diagram showing that, among the kinds of sources of PCDD/Fs and
PCBs [reservoir sources, unknown sources, and known sources], the
on-going focus of risk management is known sources. [This could be
interpreted to mean that USEPA may well think that the major sources
are identified and that further efforts toward source
identification/quantification are not necessary..] It is also
interesting to note that Dwain groups USEPA's new approach, margin of
safety, with the precautionary principle as risk management paradigms
with no acceptable increment of risk. Based on Tom Webster's
explanation of margin of safety, this is not actually the case.
The key point in Dwain's presentation was the question he posed:
How will USEPA judge small increments in exposure against the
background exposure when that background is increasing or decreasing?
And the key phrase is "when that background is increasing or
decreasing".
From the presentations by Farland and Cleverly, it is
certain that USEPA is contending that background exposures are
decreasing rapidly: whatever USEPA and industry has done to
reduce dioxin releases is working well, so no new, stronger measures
are needed.
This probable USEPA perspective must be viewed in conjunction with
the presentation by Germany's Furst. He reported that,
although Germany has achieved it's goal of reducing PCDD/F (TEQ)
intake to 1 pg/kg bw/day, the intake of breastfeeding infants
is still almost 70 pg/kg bw/day. Following his session, I asked if
he or any of his colleagues had estimated an adult daily intake that
would result in intakes for breasfeeding infants of 1 pg/kg bw/day.
He smiled and said no, he had not made such calculations but that
such an intake would be "very, very low."
Dwain Winters, USEPA policy analyst, Presentation at Dioxin '97,
International Dioxin Symposium, Indianapolis, Indiana, Aug. 24-29,
1997.
Characteristics of Dioxin Policy
· Maturing scientific and technical base
· Established risk management programs
· Cross media problem
· Multitude of stakeholders
Cross Media Policy Issues
· General Population Exposure
· Special Population Exposure
· Cancer & non-cancer effects
General Population Exposure
* Atypical for Background Risk
Level of risk
Cross media origin
* How should we judge risk significance
Risk management paradigms
Risk Management Paradigms
No acceptable increment of risk
- Margin of safety
- Precautionary Principle
An Acceptable Level of Risk
- De Minimis Risk
Risk-Benefit Balancing
- TSCA
- RIA
Technology-Based Rulemaking (most dioxin regulation in US is based
on this approach, which is technology-based, not risk- or
economic-based)
- MACT [maximum achievable control technology]
- Effluent guidelines
Special Population
- Equity-based concerns
- Tied to decisions on general population
- Requires information on local scale
How to judge small increments against background (when background is
increasing or decreasing)
Cancer and non-cancer risks
- Cancer - probabilistic (chose point when risk is no longer of concern)
- Non-cancer - deterministic (presence or absence of thresholds)
Reassessment
- Talks about non-cancer effects in probabilistic terms?
Targeting future actions
Emission-based targeting
Risk-based targeting
Where to target - emissions or risk?
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Pat Costner
P.O. Box 548, or 512 CR 2663
Eureka Springs, Arkansas 72632 USA
ph: 501-253-8440
fx: 501-253-5540
em: pat.costner@dialb.greenpeace.org
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~