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ARCC
Letter to Vice President Albert Gore
September 22, 2000 Vice President
Albert Gore, Jr. Dear Vice President Gore: The Alliance for Responsible Use of Chlorine Chemistry (ARCC), a coalition of major U.S. labor unions and corporations, requests your assistance on a matter of urgent concern to U.S. national and international interests -- EPA's draft Dioxin Reassessment. When EPA released the first draft of its Dioxin Reassessment in 1994, numerous public sector stakeholders and independent scientists reviewed the entire 2,000-plus-page draft, including both the health and exposure sections. As a result of this lengthy, open public review, significant portions of the draft were determined to be deeply flawed and were rejected by EPA's Science Advisory Board (SAB). EPA was directed to address the concerns of the SAB in its next draft. In June, EPA released its latest draft of the reassessment. The draft now exceeds 3,000 pages. Despite the inclusion of new and substantially revised chapters, EPA has asked for public review of only two sections. The updated health effects and exposure chapters will not be open for public review and comment at all. Only two sections will receive limited public scrutiny; for example, the July peer review meeting on these two sections included only five minutes of oral comment. The reassessment is already generating intense scientific controversy and concern. It appears to be more sensational and politically-charged than the previous draft. It has been called "an embarrassment to science" by a distinguished past member of the SAB, and this reaction is supported by other past SAB members (see New York Times, May 18, 2000). Currently, the World Health Organization's "tolerable daily intake" (TDI) of dioxin is 1 -- 4 picograms per kilogram of bodyweight per day (pg/kgbw/d). The WHO level is comparable to the U.S. ATSDR's minimal risk level of 1 pg/kgbw/d, issued in 1999. Yet, EPA's draft reassessment could yield an exposure risk level thousands of times lower. Without question, the implications of EPA's draft are potentially explosive. As a matter of common sense -- given the implications for public health, agriculture, international trade, employment, manufacturing, construction, transportation and U.S. government agency budgets -- the EPA should extend the review period and make sure that the process of review is as open, comprehensive and robust as possible. However, EPA appears determined to finalize the reassessment before the end of the calendar year. During 1994, EPA provided multiple opportunities for public comment on the entirety of the draft, and sought written and oral comments in public meetings held throughout the country. Unless EPA provides more time and opportunities for external input, the current draft made will not be scrutinized as it was in 1994. The National Research Council / National Academy of Sciences recently criticized EPA for attempting to make science policy without adequate external input. In this case, given the public health and economic implications of the draft, more time for external comment should be provided. Mr. Vice President, we ask the Administration to require EPA to provide more time for a full and open process of review in order to address basic issues raised by the draft report. The American people, workers, stakeholder industries and scientists who want more time for a thorough review should have it. We urge the Administration and EPA to support extending this review process by several months. Sincerely,
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