#285: Business as Usual: Lost In the Ozone

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #285
---May 13, 1992---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com

========================Original Source========================

The ozone hole over the south pole this past winter grew to be four times as large as the United States, the biggest it has ever been. Since 1970, the south-pole ozone hole has opened up each year between August and December, then closed up again as sunlight created a new supply of ozone, leaving Earth's entire ozone supply slightly more diminished each passing year.

The source of the problem is industrial chemicals (CFCs, halons and others containing chlorine and bromine), which waft upward into the sky where they break into smaller molecules. These smaller molecules remain in the stratosphere, nine to 18 miles above the earth, until they encounter frozen clouds. Frozen clouds break down the small molecules further, releasing pure chlorine and bromine which then begin to devour nearby ozone molecules that ordinarily protect Earth from deadly ultraviolet radiation, which is constantly streaming in from the sun. According to NASA [National Aeronautics and Space Administration] a one-percent reduction in the ozone shield produces a 2% increase in ultraviolet radiation on the ground.[1]

In early February this year, NASA announced that conditions were ripe for development of a huge ozone hole over the NORTH pole for the first time. In the northernmost region of the stratosphere, NASA scientists had measured chlorine monoxide levels higher than previously seen anywhere in the stratosphere. When chlorine monoxide encounters a frozen cloud, chlorine is released and ozone destruction begins immediately. At a hastily-called press conference February 3rd NASA scientists said this spring the north pole ozone hole might get big enough to cover most of Canada, northern New England, and northern Europe. This would place large human populations beneath an ozone hole for the first time. NASA said in February ozone losses up to 30% might occur this spring over Toronto and Boston. This would be a significant reduction indeed. Environment Canada, the Canadian equivalent of EPA (U.S. Environmental Protection Agency) immediately recommended that children under 18 be kept indoors throughout the spring. But within a week, this alarming and unrealistic recommendation had changed into "normal prudence should be used," whatever that might mean.

Fortunately, almost immediately after NASA's announcement, a warming trend melted the frozen clouds over the arctic and this year's ozone-depletion-season ended after ozone loss of only 10%. NASA called the 10% loss "quite significant" but said it should not be called a "hole." Ozone loss inside the south-pole ozone hole each year now routinely reaches 50% or more but relatively few humans are affected.

NASA says it now knows that ozone destruction depends on two main factors: the total amount of chlorine and bromine atoms in the stratosphere, and the length of the cold season when stratospheric temperatures dip below -78 Centigrade (-108 Fahrenheit), forming frozen clouds that release chlorine and bromine.

As soon as the cold season ends, pure chlorine and bromine change back into a less-destructive form, and sunlight proceeds to create a new batch of ozone at the rate of 350,000 tons per day, partially replenishing Earth's acutely depleted supply. But nature produces the same amount of new ozone each year whereas humans destroy MORE of the Earth's ozone each year, so Earth's total (average) ozone supply is being diminished, allowing slightly more ultraviolet light to reach Earth's surface each year.

Therefore the ozone problem has two parts: large short-term "holes" that can allow large amounts of ultraviolat light to strike the earth during spring and early summer (August-December over the south pole, February-June over the north). And the long-term depletion of ozone, producing smaller increases of ultraviolet light over much larger areas year-round.

Despite the reprieve from NASA's worst fears about a northern ozone hole, 1992 was not a good year for Earth's ozone shield:

** During January, February, and March, NASA's TOMS [Total Ozone Monitoring Spectrometer] satellite measured average ozone over the northern hemisphere lower than any previous year in the satellite's 13-year history.

** Over the north pole, ozone normally reaches a peak during late winter, but this year the late-winter peak was 10 to 15% lower than any peak previously measured.

**The threat of a northern "hole" will be with us for several decades. In 1991/92, frozen clouds in the north lasted only 39 days, saving us from a severe ozone hole over populous regions. But the average winter has 68 days of frozen clouds. In a cold year, frozen clouds can last considerably longer; for example, in 1988/89 frozen clouds lasted 79 days. Thus NASA says it expects large ozone holes over northern latitudes during many years in the next two decades.

** One major source of the problem, chlorine monoxide (derived from CFCs and a few other chemicals like carbon tetrachloride), is increasing in the stratosphere at about 5% per year, NASA said in April.

** Even if the Montreal ozone treaty of 1987 and its June, 1990, amendments are accepted world-wide, it will be 80 years before Earth's ozone returns to normal.

The bad news of 1992 followed close on the heels of a series of unwelcome revelations in late 1991.

Daniel Albritton, directory of the Aeronomy Laboratory for NOAA [National Oceanic and Atmospheric Administration] testified before Congress November 15, 1991, giving a litany of trouble:[2]

(a) During the period 1970 through the mid-'80s, ozone depletion got worse one year then better the next; every other year brought some relief. But in the late '80s through today, the situation has steadily worsened every year. Scientists are not sure why the pattern has changed, but it apparently has, Albritton said.

(b) In the 1970-1991 period total ozone depletion over northern mid-latitudes (where the U.S. population resides) ozone depletion occurred at the rate of 2.7 percent per decade. But during the later part of this period, 1979-1991, ozone depletion accelerated to 4.7% per decade. Thus total ozone destruction is accelerating. Albritton's picture of accelerating ozone loss was confirmed by new analyses announced in SCIENCE magazine April 17.[3]

(c) In the 1970s and early '80s, ozone loss was restricted to winter time. However in recent years, ozone depletion has also been observed during summer. Over northern mid-latitudes during the period 1979-1991, summer ozone losses averaged 3.3%

NASA doesn't talk much about what ozone depletion means. For one thing, information is scarce. This scarcity did not occur by chance. Of all the money spent worrying about the ozone hole(s) during the past 20 years, less than 1% has been spent measuring effects of ultraviolet light on living things like plankton, peas, polar bears, and people. Over 99% of the money has been spent outfitting airplanes with special equipment, building satellites with special eyes for seeing ozone, and so forth.

As a result, effects of modest ozone loss are poorly understood. However, effects of severe ozone loss were studied in 1975 by the National Academy of Sciences (NAS) as part of an effort to understand the consequences of nuclear war. The Arms Control and Disarmament Agency in 1978 used the NAS study to assess effects of nuclear conflict. According to the Agency, a 50% reduction in Earth's ozone shield over mid-latitudes "would cause blistering after one hour of exposure. This leads to the conclusion that outside daytime work in the northern hemisphere would require complete covering by protective clothing.... It would be very difficult to grow many (if any) food crops, and livestock would have to graze at dusk, if there were any grass to eat." [Quoted in reference 4.]

Besides severe blistering, ultraviolet light harms the immune systems of humans and animals (regardless of skin pigmentation); reduces crop yields; reduces the growth of phytoplankton (which form the basis of all oceanic food chains); and causes eye cataracts in humans and animals, leading to blindness.

Ozone losses less than 50% might cause blindness in domestic animals, thus disrupting agriculture in much of Asia which depends heavily on beasts of burden. Other complex, far-reaching negative effects are thought possible.

The Institute for Energy and Environmental Research (IEER), a private organization, has developed a practical plan for rapid phase-out of all ozone-destroying chemicals,[4] but the Bush administration has shown no real interest. After the NASA press conference in February, Mr. Bush speeded up the U.S. timetable for phasing out ozone-killing chemicals, but only by one year. In Washington, it's business as usual.

--Peter Montague, Ph.D.

===============

[1] "Press Briefing; End of Mission Statement; Second Airborne Arctic Stratospheric Expedition AASE-II." Washington, DC: National Aeronautics and Space Administration, April 30, 1992. The increased ultraviolat radiation may not all reach the ground because other pollution (for example, urban smog) may absorb it, but where the air is clear, a 1% reduction of stratospheric ozone will cause a 2% increase in ultraviolet on the ground, NASA says.

[2] Daniel L. Albritton, Director, Aeronomy Laboratory [in Boulder, Colorado], National Oceanic and Atmospheric Adminstration, U.S. Department of Commerce, "Testimony... before the Committee on Commerce, Science and Transportation, United States Senate, November 15, 1991."

[3] Richard Stolarski and others. "Measured Trends in Stratospheric Ozone." SCIENCE Vol. 256 (April 17, 1992), pgs. [342-349.]342-349.

[4] Arjun Makhijani, Kevin Gurney and Annie Makhijani, SAVING OUR SKINS; THE CAUSES AND CONSEQUENCES OF OZONE LAYER DEPLETION AND POLICIES FOR ITS RESTORATION AND PROTECTION. Takoma Park, MD: Institute for Energy and Environmental Research [6935 Laurel Ave., Takoma Park, MD 20912; phone (301) [270-3029],] February, 1992. $10.00 and worth it.

Descriptor terms: ozone; nasa; south pole; ozone hole; ozone depletion; nas; ieer;

#287: The Breakdown of Morality

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #287
---May 27, 1992---
News and resources for environmental justice.
------ 
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com =======================Original Source========================

While he was in California recently, playing golf and eating caviar, Vice-President Dan Quayle announced that the cause of the recent riot in Los Angeles was a breakdown in morality among residents of south-central L.A.

Mr. Quayle did not mention it, but it is apparent that an even more pronounced breakdown in morality occurred among the nation's leaders during the previous 15 years as they encouraged white-collar criminals to raid the public treasury and thumb their noses at government regulations.

A Case in Point: Crooks in High Places

The largest hazardous waste incinerator in the world--called WTI--is currently being built in East Liverpool, Ohio. Local citizens have been fighting the facility for 12 years. They say it is located in a place that is simply not safe or even sensible. The huge furnace is being built right on the edge of the Ohio River, which provides drinking water to many thousands of people. The site is in the 100-year flood plain and is underlain by two high-quality aquifers (sources of potable water). The site has previously been contaminated with 200,000 gallons of toxic chemicals which are presently being cleaned up as construction of the huge new pollution-source proceeds. The incinerator sits in a valley where thermal inversion conditions occur frequently; a thermal inversion is a warm layer of air that hangs over a cooler layer, thus putting a "lid" on the sky, allowing a buildup of pollutants which would otherwise drift away. The 150-foot WTI smoke stack sits below a bluff, on top of which lie an elementary school and a business college about 1100 feet from the stack as the crow flies. Homes lie 400 feet from the stack.

WTI is licensed to burn 176,000 tons of hazardous waste each year. Legally it can emit 9400 pounds of lead, 2560 pounds of mercury, 199,600 pounds of sulfur dioxide, and 157,400 pounds of fine particles each year. Because it is licensed to burn pesticides, solvents, and leftover chemical weapons (Agent orange from Vietnam), it is a certainty that WTI will create and emit substantial quantities of dioxins and furans.

WTI sits on land owned by a government unit called the Columbiana County Port Authority, which was created by the Ohio legislature in 1977. In 1979 the Port Authority leased land to WTI BEFORE THE PORT AUTHORITY EVEN OWNED ANY LAND. The Ohio Department of Transportation then bought land for the Port Authority using $4 million of Ohio taxpayers' funds explicitly earmarked "to enhance the use of Ohio's rivers." WTI will discharge liquid wastes into the river but will not use the river in any other way; it is explicitly forbidden from transporting wastes on the river. How WTI will "enhance Ohio's rivers" is known only to highly-placed political tricksters. This is merely one among many irregularities Ohio governor George Voinevitch and his cronies have been willing to overlook on behalf of WTI.[1]

Federal officials are likewise playing fast and loose on WTI's behalf. When WTI sought a permit from U.S. EPA (Environmental Protection Agency), the application for the permit was signed only by WTI and not by the land owner, the Port Authority. This behavior was just plain illegal.

The nation's hazardous waste law is called RCRA [Resource Conservation and Recovery Act] and the RCRA regulations published in the Federal Register May 19, 1980 explicity say that a "facility" includes "all contiguous land." Thus the "owner" of a "facility" explicitly includes the owner of the land.[2]

The preamble to the May 19, 1980 regulations explicitly spelled out WHY owners were required to sign a RCRA permit application: 

Some Facility Owners Have Historically Been Absentees, Knowing And Perhaps Caring Little About The Operation Of The Facility On Their Property. The Agency Believes That Congress Intended That This Should Change And That They Should Know And Understand That They Are Assuming Joint Responsibility For Compliance With These Regulations When They Lease Their Land To A Hazardous Waste Facility. Therefore, To Ensure Their Knowledge, The Agency Will Require Owners To Co-Sign The Permit Application And Any Final Permit For The Facility.

Despite these regulations, in 1983 EPA Region 5 in Chicago accepted a RCRA-permit application signed by WTI alone without the Columbiana County Port Authority and subsequently issued a RCRA permit to WTI alone, a clear violation of EPA's own regulations.

Late last year, with local activists from three states nipping at its heels, Region 5 EPA tried to cover its tracks. EPA regional administrator Valdus Adamkus wrote to Senator John D. Rockefeller IV of West Virginia on December 2, 1991:

"It is true that the property upon which the facility sits is owned by the Columbiana County Port Authority," Adamkus wrote. "It is also true that the Agency was aware of that fact at the time the permit was issued, and that the permit was issued solely to WTI. In 1983 the Agency did not make the distinction between property owners and facility owners." Mr. Adamkus's letter to Sen. Rockefeller continues: "Since 1983, the Agency has changed its policy. It now issues permits to property owners and facility operators as co-permittees."

It is evident that there was no such policy before 1983 and no change of policy in 1983. When challenged to produce the earlier policy, Mr. Adamkus's staff could not.[3]

Having been caught in a violation of law, which Mr. Adamkus tried to cover up with a lie, EPA's next step was to break the law again by adding the Columbiana County Port Authority to the WTI RCRA permit even though the Port Authority has never applied to EPA to be put on the permit. EPA has no authority to issue a hazardous waste permit to someone who does not apply for one.[4] In fact, the Port Authority has appealed EPA's decision, demanding that its name be removed from the WTI permit. It seems the Port Authority (a public body) does not want its name on a RCRA permit since it has no legal mandate to become a hazardous waste permit-holder.

A most unusual situation. Or is it? The San Francisco office of EPA (Region 9) faced a similar situation recently. Here EPA and the State of California had issued a permit to a cement kiln to burn hazardous waste. When the permit was up for renewal, local environmentalists pointed out that the landowner had never signed the permit application and refused to do so. EPA Region 9 refused to allow the RCRA permit to be renewed on grounds that the law requires the landowner to co-sign the permit application.[5] In making its decision, Region 9 explicitly stated that EPA does not have the authority to waive its own rules, which is precisely what Region 5 is doing in the WTI case. According to the logic of this precedent, Region 5 should revoke WTI's permit because the land owner (the Port Authority) refuses to apply to become a party to the permit.

It seems clear that, in the case of WTI, EPA Region 5 broke the law, lied about it, then broke the law again trying to cover its tracks.

What could cause high ranking career civil servants and government attorneys to risk their careers, their pensions and perhaps their freedom for the benefit of WTI? We can only speculate, but we believe the answer lies in knowing the background of WTI.

WTI was initially a consortium of investors put together by Jackson Stephens who operates Stephens, Inc., in Little Rock, Arkansas, one of the largest investment banks outside of Wall Street, according to the WALL STREET JOURNAL. Mr. Stephens's personal fortunate is estimated to be $1.7 billion.[6] He was a classmate of Jimmy Carter at the Naval Academy and was a heavy supporter of Carter in 1976 and 1980. Stephens profited tremendously by Carter's changes in natural gas policy. Because of Stephens, the Bank of Credit and Commerce International (known in the banking trade as the Bank of Crooks and Criminals) got a foothold in the American banking industry. The WALL STREET JOURNAL says it was Stephens who "suggested to BCCI in the late 1970s that it try to take over what is now Washington, DC's, biggest bank company, First American Bankshares, Inc." In the 1980s, Stephens became a benefactor of the Republican party and a member of George Bush's financial committee. Stephens's wife, Mary Anne, served as Arkansas co-chair of the Bush for President Committee. Stephens himself donated $100,000 to Team 100, a GOP group that collected funds for the campaign. In May, 1991, Stephens, Inc. donated another $100,000 to the Bush dinner committee, according to the WALL STREET JOURNAL (12/6/91). Last year Vice-President Quayle flew to Augusta, Georgia on a military jet at a cost to the taxpayers of $27,000. His purpose: a game of golf with Jackson Stephens.[7]

When Republican Governor George Voinevitch and EPA Region 5 administrator Val Adamkus, a Bush appointee, evade the rules to let WTI get away with murder, they signal a breakdown in morality that only the likes of Mr. Quayle could fail to notice.

--Peter Montague, Ph.D., and William Sanjour

===============

[1] These irregularities are spelled out in an 11-page memorandum April 30, 1992, by Ashley Schannauer, an attorney with the City of Pittsburgh, Penna., Law Department.

[2] See FEDERAL REGISTER, May 19, 1980; the regulations begin on pg. 33036; the definition appears on pg. 33074.

[3] Personal communication with Cleveland PLAIN DEALER reporter T.C. Brown May 14, 1992.

[4] EPA Region 5 claims that there are two precedents for issuing a RCRA permit to someone who has never applied for one: a case involving Ford Motor Co., and one involving Olin Corp. However, in these cases, both Ford and Olin signed the permit application, then tried to keep their names off the permit. EPA wouldn't let them do it. Columbiana County Port Authority refuses to sign the permit application, so the Ford and Olin cases aren't the same at all. See IN THE MATTER OF: FORD MOTOR COMPANY and IN THE MATTER OF: MICHIGAN DISPOSAL, INC. AND FORD MOTOR COMPANY, RCRA APPEAL NO. 90-9 AND 90-9A, October 9, 1991 and IN THE MATTER OF: OLIN CORPORATION, BADGER ARMY AMMUNITION PLANT, RCRA APPEAL NO. 88-18.

[5] John Chandler, "Waste Plant Is Threatened With Closure," LOS ANGELES TIMES, March 20, 1992, p.B3.

[6] Christopher Knowlton, "Of Bibles, Bonds and Billions," FORTUNE Feb. 12, 1990, pg. 112.

[7] Jim Dwyer, "Quayle and His Golf Outings: Putting One Over on the Taxpayers," ATLANTA CONSTITUTION April 15, 1992. Thanks to Jan Caves of Fortson, Georgia, for this.

Descriptor terms: dan quayle; riots; wti; east liverpool; incinerator; columbiana county port authority; rcra; jackson stephens;

#284: A Breakthrough in Control of Toxics, PCBs (dioxin)

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #284
---May 6, 1992---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com =================================Original Source========================

An important breakthrough in control of toxics occurred during April. The International Joint Commission (IJC), a government body with responsibility for environmental quality of the Great Lakes, made far-reaching official recommendations which, for the first time, embody a truly modern approach to the identification and control of toxic chemicals. It appears to be a real first step toward a sustainable world. In a nutshell, the IJC now recommends[1] that the U.S. and Canada:

a) Ban incineration in certain areas near the Great Lakes; 

b) Phase out the use of chlorine in manufacturing; 

c) Adopt a "weight of the evidence" approach, not waiting for scientific certainty to be established but taking action to protect against toxics as soon as the "weight of the evidence" indicates the need for action. 

d) Define many chemicals as "persistent toxic substances" and then ELIMINATE them because recent history tells us persistent toxics cannot be safely managed.

Although the first two recommendations--ban incineration and phase out chlorine--are the most startling, it is really the last two recommendations that constitute a radical departure from the past.

In recommending a "weight of the evidence" approach and in recommending the elimination of all persistent toxic substances, the IJC has turned its back on risk assessment and numerical standards. Today risk assessment and numerical standards form the backbone of the U.S. regulatory system for controlling toxic substances. The IJC says the traditional regulatory system has failed and must be abandoned.

In their joint 1978 Water Quality Agreement, the U.S. and Canada defined a "toxic substance" as "a substance which can cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological or reproductive malfunctions or physical deformities in any organism or its offspring, or which can become poisonous after concentration in the food chain or in combination with other substances."

The IJC now recommends defining a class of chemicals called "persistent toxic substances," which should then be ELIMINATED because they cannot be managed safely.

The IJC recommends that a persistent toxic substance be defined as any toxic chemical that bioaccumulates, or any toxic chemical that has a half-life greater than eight weeks in any medium (water, air, sediment, soil, or living things). Substances with either of these characteristics should be ELIMINATED, the IJC says.

The "half life" of a substance is the time it takes for half of it to disappear. For example, DDT has a "half-life" of about 20 years in soil; if a pound of DDT is released into soil today, half of it will still exist 20 years from now. The IJC recommends that any toxic substance with a half-life greater than 8 weeks be considered too dangerous to be released and should be ELIMINATED.

A substance bioaccumulates if its concentration increases as it moves through the food chain. For example, DDT may be found at one ppm (part per million) in fish and at 10 ppm in fish-eating birds. Thus DDT bioaccumulates. The IJC says any toxic substance that bioaccumulates should be ELIMINATED.

What is the IJC?

The IJC was created in 1909 by the governments of Canada and the U.S. to oversee the Boundary Waters Treaty, which guides Great Lakes-related behavior of the two nations. Starting in 1912, and again in 1945 and 1964 the IJC was asked by the two governments to report on water quality of the lakes. The studies revealed progressive deterioration. In 1972 and again in 1978 the two nations signed Water Quality Agreements aimed specifically at improving water quality in the lakes. The goal of the 1978 Agreement was broad: "to restore and maintain the chemical, physical and biological integrity of the waters of the Great Lakes Basin Ecosystem." It is up to the IJC to manage and monitor efforts to achieve the goals of the 1978 Agreement. In 1981, the IJC began issuing a report every two years, describing the condition of the lakes in relation to the goals of the 1978 Agreement. The 6th biennial report from the IJC, released in April, 1992, contains these far-reaching recommendations.

U.S. EPA (Environmental Protection Agency) and its Canadian counterpart, Environment Canada, must respond to the IJC recommendations within six months. In the past, many IJC recommendations have been adopted by the governments of the U.S. and Canada because IJC recommendations are typically buttressed by many studies and much data. That is the case with the present recommendations.

Regarding the Great Lakes environment, the IJC report says, "The principal problem is the presence and impact of persistent toxic substances on all sectors of the ecosystem." The report says the old way of protecting ourselves against these toxic materials has failed: "...the Commission concludes that attempts to regulate persistent toxic substances have not resulted in an efficient or successful set of programs." The IJC report says, "Surely it is time to ask whether we really want to MANAGE persistent toxic substances after they have been produced, or whether we want to ELIMINATE and PREVENT their existence in the ecosystem in the first place."

The report goes on, "It is clear to us that persistent toxic substances have caused widespread injury to the environment and to human health. As a society we can no longer afford to tolerate their presence in our environment and in our bodies.... Hence, if a chemical or group of chemicals is persistent, toxic and bioaccumulative, we should immediately begin a process to eliminate it. Since it seems impossible to eliminate discharges of these chemicals through other means, a policy of banning or sunsetting their manufacture, distribution, storage, use and disposal appears to be the only alternative." The IJC defines "sunsetting" as "a comprehensive process to restrict, phase out, and eventually ban the manufacture, generation, use and disposal of a persistent toxic substance."

The IJC says, "Such a strategy should recognize that all persistent toxic substances are dangerous to the environment, deleterious to the human condition, and can no longer be tolerated in the ecosystem, whether or not unassailable scientific proof of acute or chronic damage is universally accepted.... Therefore the focus must be on preventing the generation of persistent toxic substances in the first place, rather than trying to control their use, release, and disposal after they are produced."

This is a very important point. The IJC is urging adoption of a "weight of the evidence" approach to controlling toxics, not waiting until absolute scientific proof is available because by then it may be too late. On this point the IJC says:

The Commission Recognizes That Scientific Data Are Open To Interpretation And That, Notwithstanding The Confirmed Cause-And-Effect Link In Some Cases, Unequivocal Conclusions May Be Difficult To Reach In Others, Especially If Individual Studies Are Considered In Isolation. With Low Contaminant Concentrations, Subtle Effects And Potentially Confounding Factors, Unequivocal Evidence Of Injury To Humans By Persistent Toxic Substances May Be Difficult Or Impossible To Obtain.

Critics Have Attempted To Find Flaws With Individual Studies In Order To Discredit Findings And Conclusions About Persistent Toxic Substances. While Limitations To Study Design May Exist, This Does Not Necessarily Invalidate The Findings And Conclusions When Considered In A Weight-Of-The-Evidence Context. At Some Point The Emerging Mass Of Data And Information Must Be Accepted As Sufficient To Prompt... Action Against Environmental Contaminants.

There is abundant evidence that wildlife in the Great Lakes are being harmed by persistent chemicals, the IJC says. But "Most troubling of all is the experts' conclusion that humans are being affected as well. Indeed, they estimate that levels of some of these chemicals measured in the human population are in the same range, and in some cases even greater, than those found in adversely affected wildlife populations."

The IJC report points to evidence that fish, birds, and mammals around the Great Lakes are suffering from thyroid dysfunction, decreased fertility, decreased hatching success, gross birth defects, metabolic abnormalities, behavioral abnormalities, demasculinization/feminization, defeminization/masculinization, and compromised immune systems. (See RHWN #146, #263, #264.)

The report attributes these diseases and abnormal conditions to persistent toxic substances like lead, mercury, DDT, PCBs, PAHs [polycyclic aromatic hydrocarbons] and a broad spectrum of persistent chlorinated hydrocarbons such as hexachlorobenzene, pentachlorophenol, furans, and dioxins.

The 1978 Water Quality Agreement adopted "zero discharge" language as a philosophy, but now the IJC seems bent on turning it into a workable program. The Commission says "Zero discharge does not mean less than detectable. It also does not mean the use of controls based on best available technology, best management practices, or similar means of treatment that continue to allow the release of residual chemicals." Zero means zero, and ZERO DISCHARGE means ELIMINATION.

--Peter Montague, Ph.D.

===============

[1] The recommendation to ban incineration was included in the International Joint Commission's report, AIR QUALITY IN THE DETROIT-WINDSOR/PORT HURON-SARNIA REGION (Ottawa, Canada, and Washington, DC: International Joint Commission, February, [1992).] All other recommendations that we discuss appear in the IJC's SIXTH BIENNIAL REPORT ON GREAT LAKES WATER QUALITY (Ottawa, Canada, and Washington, DC: International Joint Commission, April, 1992). Both reports are available free from the IJC office at 1250 23rd St., NW, Suite 100, Washington, DC 20440. Telephone: (202) 736-9000. In Canada, phone (519) 256-7821.

Descriptor terms: ijc; great lakes; canada; persistant toxic substances; regulations; sunsetting; water quality agreement; bans; zero discharge; us; health; epa; environment canada;