[CPEO-MEF] CPEO comments on EPA's Perchlorate Determination

[Lenny Siegel <lsiegel@cpeo.org>]

For a formatted PDF version of this letter, go to
http://www.cpeo.org/pubs/CPEOperchloratecomments.pdf



CENTER FOR PUBLIC ENVIRONMENTAL OVERSIGHT


November 24, 2008

US Environmental Protection Agency
Office of Water Docket (Mail Code:  2822T)
1200 Pennsylvania Avenue, NW
Washington, DC  20460

Ref: Docket EPA-HQ-OW-2008-068

Dear Sirs/Mmes:

In the October 10, 2008 Federal Register EPA made a preliminary 
determination that not enough people in the United States are exposed to 
significant levels of perchlorate in public drinking water systems to 
merit the issuance a national primary drinking water regulation. This is 
one of the most disappointing and convoluted EPA documents that I have 
ever reviewed.

To reach that conclusion, it proposes to specify a health reference 
level of 15 parts per billion (ppb) based on its current reference dose 
of .7 micrograms per kilogram per day and a calculation of dietary 
sources of perchlorate other than drinking water. As other commenters 
have explained, EPA has failed to recognize that this health reference 
level exposes young children to levels of perchlorate above the 
reference dose.

More important, though it draws upon the work of the Centers for Disease 
Control to profile perchlorate exposures in the population, it dismisses 
one of its key findings: In 2006 Blount et al found that women with low 
iodide levels (over a third of the female population) experience 
decreased thyroid functions at low perchlorate exposures characteristic 
of much of the U.S. population. That effect could seriously impair the 
development of fetuses carried by such women.

But EPA states that Blount did not establish a causal relationship. That 
is, other factors - such as exposure to nitrates or thiocyanate, might 
be influencing thyroid function. It wrote, "It is also not known whether 
the association between perchlorate and thyroid hormone levels is causal 
or mediated by some other correlate of both."

That is, EPA recognizes that there is a major threat to public health, 
but it refuses to take action because there is a chance that the 
association between perchlorate and decreased thyroid function might be 
caused by another. unknown chemical compound. Yet EPA promises no action 
to track down and investigate that mysterious cause. This is 
unconscionable!

This reminds me of O.J. Simpson's criminal defense. He insisted that 
some third party or parties killed his wife and Ronald Goldman, but he 
showed little interest in finding the unknown perpetrators.

If EPA were serious about protecting the health of America's children, 
it would move forward with plans to develop a legal standard for 
perchlorate in drinking water. In the course of that effort, it should 
consider how other contaminants might contribute to the problem.

Finally, over the past decade, our understanding of the perchlorate 
threat has changed. Large sources of perchlorate pollution, associated 
with rocket-fuel production and other industrial activity, remain. 
However, it appears that perchlorate exposure is widespread at low 
levels also because of natural, agricultural, and incidental sources. To 
develop a public health strategy that addresses such exposures, we need 
a drinking water standard that requires the sampling of our water 
supplies at the low levels found to be a potential problem by the 
Centers for Disease Control. Even if it turns out that other factors - 
such as low iodine consumption - play a key role in the manifestation of 
thyroid dysfunction, such sampling is essential to protect the health of 
our children for decades to come.

Sincerely,

(submitted electronically)

Lenny Siegel
Executive Director




's co
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Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org



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