[Dioxin-l] more on EPA's proposed 300 ppt dioxin standard for sludge

[Tony Tweedale]

I received the below in reply to a querry about the safety of this proposed
standard for dioxins in sludge. Late it came to me that this is obviously
deliberate attempt  by EPA Admin. Browner to enshrine yet another lax
dioxin standard before releasing as final their Dioxin Reassessment, w/ its
TDI (estim. safe dose) of 0.01 pg.kg/d (for a ligfetime cancer risk of
10E-6, or one/million).  This TDI, we all realize, is 100 to 1,000 times
more stringent than other proposed and existing ones around the
world--plenty of reason for EPA to hold the RA and finaliize as many
orders-of-magnitude too weak dioxin limits as it can get away with.  The
Med Waste Incinerator rule, other incinerator rules, the P&P "Cluster" rule
are all examples of orders of maginutide lax dioxin standards finalized
since the '94 External Review Draft Dioxin Reassessment.  This speaks to me
of infered yet clear economic corporate power and of their money in the
Clinton Admin.

The below goes well beyond my reply to the querry I received, in which I
used the exposure asumptions (eg child's hand-to-mouth behavior) of ATSDR's
current Interim dioxin soil exposure Min. Risk Levels (MRL's, used for
initial screening of contaminated sites, for further action), but
substituted the EPA draft TDI for cancer risk (0.01 pg/kg/d) for ATSDR's
laughably-poorly justified TDI of 1 pg/kg/d.  For ATSDR, back-calculating
from this TDI leads to an action level of 1 ppb (1,000 ppt) dioxin in soil;
using EPA's draft TDI (but same exposure assumptions) it leads to 10 ppt.
Yet EPA wants to set a limit in sludge of 300 ppt!  More pin-head politics
trumping science and public health's prevention principle.

Of course, you can't really assume that exposure to food grown in
dioxinated sludge is identical to exposure from playing in dioxinated soil.
Yet my initial thought is that more dioxin would be tranferred to you in
the sludge->food exposure scenario.  Please make your explicit thoughts
known to EPA (see below, the sludge comment ends 22 Feb., but also let the
Admin. know that we know she is squelching and playing GOd w/ public health
(the Reassessment) and that we will hold her accountable, a/w/a whoever
else is doing so).
---


Date: Sat, 08 Jan 2000 13:54:17 -0500
From: "Caroline G. Snyder" <cgsnyder@post.harvard.edu>
To: ttweed@wildrockies.org
Subject: [Fwd: EPA's proposed 300 ppt dioxin standard for sludge]

--
Caroline G. Snyder   cgsnyder@post.harvard.edu
Date: Thu, 06 Jan 2000 12:17:50 -0500
From: "Caroline G. Snyder" <cgsnyder@post.harvard.edu>
To: Tom Irwin <tirwin@clf.org>
Subject: EPA's proposed 300 ppt dioxin standard for sludge

In 1992, the Wisconsin Department of Health (WDOH) did a human cancer
risk assessment for dioxin TEQ in agricultural soils.  Using realistic
and conservative assumptions, WDOH concluded that dioxin levels of 1.2
ppt in agricultural soil ( other than grazing pastures) and 0.19 ppt in
soil of grazing pastures is protective of human health.  Current
Wisconsin sludge regulations specify a 0.5 ppt soil limit for pastures
and a 1.2 ppt dioxin limit in other agricultural soil.

On December 23, EPA's Office of Water proposed a limit of 300 ppt of
dioxin TEQ for sludge that is land applied.

EPA's risk assessment addresses only the human cancer risks;  it ignores
the many other serious health risks from dioxin, especially to children,
and it does not address the dioxin risks to live stock or wildlife.  The
risk assessment appears to use unrealistic and non-conservative
assumptions very similar to those that were used for the Round One risk
assessment that led to the 503's ( Cf. Harrison et al, Case for
Caution).

For example, EPA's Office of Water uses deterministic point estimates
for input variables, ignores synergistic effect on all levels,
exaggerates dilution factors, underestimates erosion and dust exposure,
underestimates surface water impact, greatly underestimates the
consumption of beef and diary products produced on sludged pastures and
underestimates the amount of soil/sludge ingested by grazing animals.
Five singificant exposure pathways that impact human health, live stock,
or wildlife,  are not addressed because of insufficient data.  Much of
the recent dioxin literature appears to have been ignored.

We urge you to write to EPA's Office of Water objecting to this proposed
rule which will futher endanger human health, agricultural soil, live
stock and the environment from land application of sludge.  Such high
levels of a potent, persistent, and bioaccumulative poison  should not
be spread deliberately on our land.

The deadline for comments in midnight, February 22..

Mail:  Part 503 Sewage Sludge Use of Disposal Rule; Docket Number
W-99-18, Comment Clerk
       Water Docket MC-4101
       US Environmental Protection Agency
       401 M Street, SW
       Washington, DC 20046

For up-to-date information on dioxin's adverse
health effects and for policy recommendations, see CCHW's recent repport
at  www. essential org/cchw/campaign/policy.html

Caroline Snyder, President    Citizens for a Future New Hampshire
--
Caroline G. Snyder   cgsnyder@post.harvard.edu

Tony Tweedale

Causality is a concept not subject to empirical demonstration. -David Hume
(1711-'76)

Temperate but endangered planet.  Enjoys weather, northern lights,
continental drift.  Seeks caring relationship with intelligent life form.
      -Friends of the Earth