2008 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Wed, 31 Dec 2008 09:37:21 -0800 (PST)
Reply: cpeo-military
Subject: [CPEO-MEF] PERCHLORATE: EPA's Office of the Inspector General calls for cumulative risk assessment
 
On December 30, 2008 U. S. EPA's Office of the Inspector General (OIG) released its External Review Draft of its "Scientific Analysis of Perchlorate" report. The 213-page 2.5 MB PDF file may be downloaded from http://www.epa.gov/oig/reports/2009/20081230-2008-0010.pdf. OIG is taking comments through March 10, 2009.

Thus far I have only read the cover letter, but the letter makes it clear that the Analysis' authors find fault in the single-chemical risk assessment approach that EPA, as well as the National Academy of Sciences, have taken to develop acceptable risk levels for perchlorate exposure. OIG calls for a cumulative risk assessment that would consider other compounds that stress the thyroid's ability to uptake iodide, such as thiocyanate, nitrate, and the lack of iodide.

This appears to be an appropriate response to the critique I wrote about what I call EPA's "O.J." draft decision not to develop a drinking water standard for perchlorate. I excerpt my November 24, 2008 letter below:

"... 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."

Lenny


--


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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