Feedback on experiences with ATSDR

[joelf@cape.com (Joel Feigenbaum)]

[NOTE: Joel refers to an attached document at the end -- it's too
long to attach here, please contact Joel directly if you would like a
copy. -jg]

To Doris Bradshaw:

This is in response to your request for information about ATSDR's role in
promoting public health. Please use the following in any way you find
appropriate.

We have been on the ATSDR CAP from its inception seven years ago. Our goal
is to have comprehensive health studies performed around the Otis/Camp
Edwards Super Fund site. Of particular concern are large elevations of
several types of cancer, particularly lung cancer in women, around the
site. Here are some of the problems we have encountered:

1. ATSDR performed a symptoms and disease prevalence study containing too
few subjects to give significant results. In spite of our advice, ATSDR
chose a control population in a town known to have severe environmental
problems and high rates of cancers of the blood and lymphatic systems. Our
criticism of the results of that study are attached.

2. In 1995, ATSDR refused to include a critical area, Hatchville, in its
study, although we believe there is a great likelihood of toxic exposure in
Hatchville. In 1997, with the discovery of a dangerous ethylene dibromide
plume in Hatchville, we again requested a study of Hatchville. In 1999,
with the discovery of four more plumes flowing from the Base to Hatchville,
we have once again demanded a comprehensive health study of Hatchville

3. ATSDR has not responded to our requests to perform an epidemiological
cancer study in the area of Hatchville. Instead, ATSDR decided to undertake
a dose reconstruction study of the Hatchville area (although experts argued
that this would be futile). We have had no news of this in almost two
years.

4. ATSRD arbitrarily, and undemocratically decides which potential exposure
sites are permissible for study as "part of the Superfund site." Clearly,
if we are to study causes of female lung cancer, we must study all air
exposures, both on and off the site. However, under orders from the Air
Force representative to the CAP, Colonel Barbara Larcom, ATSDR has refused
to discuss the problem of ground level aircraft exhaust proximate to
residential areas. The hypocrisy of this prohibition is evident, since we
are permitted to discuss air quality impacts of Army National Guard
artillery training. Similarly, we were not permitted to discuss exposures
from PAVE PAWS, an Air Force radar installation.

ATSDR obtains all of its funding for operations on the Cape from the Air
Force. ATSDR openly consults with the Air Force at meetings when the Air
Force objects to discussion of certain issues.

5. After one of the elementary schools (serving off base children from
Bourne) on the base was shut down because of pesticide contamination, we
requested that ATSDR primarily study the health of children who had
recently attended, or were still attending schools on the base. In spite of
repeated assertions to the contrary, ATSDR insisted on believing that we
wanted the study to center on health outcomes of people who attended the
schools during the 1970's. ATSDR wasted countless hours tediously informing
us about an unsuccessful sampling study to find such former students. ATSDR
wasted so much time that CAP members simply decided not to press the issue.

6. ATSDR calls off meetings unilaterally, some times for six months.

7. At our request, ATSDR provided funds for Mass. Department of Public
Health to compute cancer incidence data by census tract. ATSDR  maintained
the right to peer review the study before release. ATSDR missed a serious
error in interpreting the results of certain population estimates. The
effect of this error was to underestimate cancer rates near the Base. When
this error was pointed out on the telephone to ATSDR by one of us, the
Agency at first denied that there was an error, and then canceled two
scheduled CAP meetings in a row (summer 1995). After six years, the census
tract computations have still not been correctly performed.

8. The Cape Cod CAP--some times called "Super-CAP"--is unique in several
respects. Through a fortunate conjunction of activists, State officials,
and Air Force Major McCabe, who preceded Col. Larcom and the need for the
Air Force to establish credibility after a period of terribly botching the
groundwater clean-up effort, the CAP was provided expert advisors of its
own choosing, who sit at the table with us, give advice, and perform
original research. Additionally, representatives of the county health
agency, the Mass. Department of Public Health, EPA and the Mass. Dep't of
Environmental Protection are all CAP members. A professional transcription
agency provides complete, accurate minutes of all meetings.

In short, this body has the ability to martial significant resources and
has broken the model of paternalistic control typical of ATSDR run
operations. However, under new Air Force dominance, ATSDR is seeking to put
the genie of effective public participation back into the bottle. Its goal,
quite simply is to see that nothing useful happens.

Please find the attached document containing our comments on the July 1996
"Health Study Of Communities Surrounding Otis Air National Guard Base/ Camp
Edwards Falmouth, Massachusetts" Final Report by ATSDR. If you cannot open
it, please let me know.


Sincerely,

Joel Feigenbaum, Ph.D.
Richard Hugus

Joel Feigenbaum
ph: (508) 833-0144
24 Pond View Drive
E. Sandwich MA 02537