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ARCC Letter to David Obey November 30, 2000
Representative
David Obey Dear Representative Obey: The Alliance for Responsible Use of Chlorine Chemistry (ARCC), a coalition of major US labor unions and corporations, requests your assistance on a matter of urgent concern to US national and international interests - EPA's draft Dioxin Reassessment. EPA released the first draft of its Dioxin Reassessment in 1994. At that time, EPA used an open review process that allowed many public sector stakeholders and independent scientists to review the entire draft (2,000 + pages), including the health and exposure sections. As a result of this lengthy and open public review, key 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, now exceeding 3,000 pages. Despite the inclusion of new information and substantially revised chapters, EPA has asked for public review of only three chapters out of 38 revised chapters. Even more disturbing, in the July 2000 peer review meeting, only two chapters were reviewed and public speakers were allowed only five minutes to make a comment. On November 1-2, the EPA's SAB met but was tasked with reviewing only three of the 38 chapters of the new document. The chapters not reviewed by SAB contain over 300 new scientific studies that form the basis of many of EPA's draft conclusions. The reassessment is generating intense scientific controversy, and 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 (New York Times, May 18, 2000). 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 US ATSDR's minimal risk level of 1 pg/kgbw/d, issued in 1999. It should also be noted that the European Commission's level is comparable to US ATSDR and WHO levels. 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, trade, employment, manufacturing, construction, transportation and US government agency budgets - the EPA should extend the review period and ensure 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 this calendar year. In 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 now decides to provide more time and opportunity 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. Representative Obey, we ask that you support efforts to require EPA to provide more time for a full and open process of review, especially a review of the full document by the SAB, in order to address basic issues raised by the draft report. We understand that the Department of Agriculture has already commissioned the National Academy of Sciences (NAS) to fully review the dioxin issue due to the potential impact on public perception of the safety of the US food supply. The NAS review process will require adequate time for completion. We have recently written to Vice President Gore and Senator Lieberman on this issue (with copies to the EPA Administrator and the Secretaries of Agriculture, Commerce, Defense, Energy, Health and Human Services and Transportation, and to USTR). The American people, workers, stakeholder industries and scientists who want more time for a thorough review should have it. Please, urge the Administration and EPA to support extending this review process by several months. Sincerely, John J. Barry C.T. Howlett
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