702 H Street, NW, Suite 300, Washington, DC 20001
Tel: 202-462-1177 • Fax: 202-462-4507
1-800-326-0959 • www.greenpeaceusa.org
January 23, 2012
The Honorable Lisa P. Jackson, Administrator
U.S. Environmental Protection Agency
1200 Ariel Rios Building
Washington, DC 20460
Dear Administrator Jackson:
Thank you for your renewed attention to the EPA’s dioxin reassessment. We applaud
the scientific rigor of the Agency and your own efforts to bring this twenty-five year
process to closure. Unfortunately once again moneyed special interests, such as the
chemical industry lobby (American Chemistry Council), shamelessly pursue even further
delays.
The American Chemistry Council apparently didn’t read President Obama’s March 9,
2009 memorandum to federal agencies that signaled the standard for scientific integrity
in this administration:
“Science and the scientific process must inform and guide decisions of my
Administration on a wide range of issues, including improvement of public
health, protection of the environment, increased efficiency in the use of energy
and other resources, mitigation of the threat of climate change, and protection of
national security.
“The public must be able to trust the science and scientific process informing
public policy decisions. Political officials should not suppress or alter scientific
or technological findings and conclusions. If scientific and technological
information is developed and used by the Federal Government, it should
ordinarily be made available to the public….”
With regard to the scientific integrity of the chemical industry lobby we are reminded of
the December 13, 1995 testimony of Admiral Elmo Zumwalt, commander of U.S. naval
forces in Vietnam, before the House Science Committee. Zumwalt was the only nongovernmental, non-industry witness allowed to testify. Zumwalt said the "company
docs" who were hired to testify on behalf of the chemical sector use “voodoo science”
reminiscent of the claims made to deny Vietnam War veterans eligibility for health
benefits from exposure to the dioxin containing defoliant Agent Orange. Zumwalt
ordered the use of Agent Orange in Vietnam. In 1988 Zumwalt’s son died from what
they both believed was exposure to the defoliant.
While it was neither acceptable nor surprising that the administration of George W.
Bush failed to complete a dioxin reassessment initiated by his father’s EPA, there was a
moment in time even then when it looked promising. On June 2, 2001 the Washington
Post reported:
“An expert scientific panel formally urged the Environmental Protection Agency
yesterday to release a study that has been in the works for more than a decade
and concludes that consumption of animal fat and dairy products containing
traces of dioxin can cause cancer in humans.
“The study's conclusion that chlorinated dioxin is an air pollutant that should be
more tightly regulated could have serious long-term economic consequences for
a wide variety of industries, including producers of milk, beef, poultry, and
chemical and paper products. The EPA's issuance of a final report could result in
federal and state regulations costly to those industries.
“EPA scientists and officials have said they are confident of the findings, which
they began circulating last June, and are urging EPA Administrator Christine
Todd Whitman to issue it in final form this summer. But the study is politically
charged and has drawn opposition from industry groups and Capitol Hill
Republicans.
“A spokesman for Whitman said yesterday that a final decision will be put off
until other agencies, including the Agriculture Department, the Food and Drug
Administration and the Justice Department, have an opportunity to review the
study.”
In an August 2, 2001 letter to EPA Administrator Christine Todd Whitman, over forty
members of Congress said:
“The American people have already waited a long time–more than ten years–for
the completion and release of the Dioxin Reassessment. EPA has been studying
the sources and health effects of dioxin for nearly 20 years, and this report is the
most comprehensive health risk assessment ever prepared by the agency.
“The Dioxin Reassessment finds that dioxin causes a wide array of adverse
health effects. The risk of cancer from dioxin exposure may exceed one in 1000
for the general population—a level a thousand times higher than the risk level of
one in a million that is generally considered acceptable for cancer. The risk is
higher for workers and others with higher levels of exposure. Dioxin also causes
numerous non-cancer health problems, including reproductive, immunological,
developmental, and endocrine system effects…
“By signing the Stockholm Convention on Persistent Organic Pollutants this
spring, the Administration officially recognized that dioxin is hazardous. Parties
to the treaty are committed to a number of significant steps to eliminate or reduce
the production, use and release of 12 persistent organic pollutants (POPs),
including dioxin. While recognizing that it will be a challenge to completely
eliminate dioxin, since it is a by-product of industrial activities, the treaty calls for
its “continuing minimization and where feasible, ultimate elimination. Given U.S.
2
support for the POPs treaty, it is imperative that we move ahead with the Dioxin
Reassessment, which will provide a basis for domestic policies on dioxin.”
As a result of these inexcusable delays we certainly do not take your efforts today for
granted. In fact we are reminded of a similar time during the Clinton administration when
we thought the conclusion of the dioxin reassessment was at hand. Below is an excerpt
from the testimony of Greenpeace Research Coordinator, Joseph Thornton, before the
EPA Science Advisory Board on May 15, 1995. (In 2007 President Bush awarded Mr.
Thornton the Presidential Early Career Award for Scientists and Engineers for his work
in evolutionary biology.)
“Until the release of the 1994 reassessment, the history of EPA's science on
dioxin was stained by political tampering. When EPA last tried to reassess the
hazards of dioxin, in 1987, it was clear to all that the process was driven by a
political agenda for deregulation, although the document that emerged
masqueraded as science or, even worse, so-called ‘science-policy.’ Only after
the SAB rejected that reassessment did EPA withdraw its proposal to downgrade
its estimate of dioxin's toxicity. After that, the record shows that the paper
and chemical Industries redoubled their lobbying effort to persuade EPA and the
Bush White House to revise the dioxin hazard assessment once again. When the
agency responded by announcing the reassessment in 1991, we expected that
this project, like the one before it, would be designed to yield a predetermined
outcome in the interest of polluting industries.
“It is thus with great surprise and sincerity that we congratulate the scientists in
EPA for their integrity in the preparation of the documents released in September.
EPA built in accountability and transparency by involving external authors and
expert review panels, publishing parts of the reassessment in scientific journals
prior to government publication, and holding public hearings on the document.
“EPA thus raised the public's expectations tremendously. This document has
garnered worldwide attention and has catalyzed recognition of the long-term
health impacts of large-scale dioxin pollution. It has created a flurry of activity to
eliminate dioxin sources among grassroots communities in this country, many of
whom feel EPA has told them the truth for the first time. The world is eagerly
awaiting EPA's final commitment to the vision contained in the draft
reassessment.
“As we expected, however, the draft reassessment provoked an aggressive
counter-offensive by dioxin-producing industries. Much of this effort, supported
by tremendous financial resources, you will see before you in the next two days.
Now the ball is in the SAB's court: the panel must help to clarify the scientific
basis of the message, but it must not shy from or cloud the truth. If at this point
the SAB allows or forces EPA to retreat in the face of political pressure, it will do
tremendous damage to the credibility not just of EPA but of scientists in our
society in general. If EPA retreats now from its position, everyone will know that
3
the agency started to tell the truth, but powerful political interests ultimately
silenced this voice, all under the guise of ‘scientific review.’ The public's trust in
the integrity of science, currently at an all-time low, will erode further.
“Ultimately, the greatest cost will be the health of future generations. The
reassessment and its review are not your average government toxicology project.
At stake are issues that pertain to the integrity of the human species -- and many
others, as well -- on a global basis. At stake is our ability to produce children
who can develop normally and live full and healthy lives in a world in which other
species are also healthy; you are on this panel as leading scientists, but we
hope you will not forget your roles as parents, grandparents, and guardians of
the planet. To its credit, EPA has assumed a leadership role in the dioxin debate.
We thank you for showing courage, clarity and integrity as you address these
profound issues.”
As you know, on August 29, 2011, the EPA announced its plan for the completion of the
dioxin reassessment. EPA committed to completing the non-cancer portion of the
reanalysis and posting it to the IRIS database by the end of January 2012 and to then
complete the cancer portion of the reanalysis “as quickly as possible.” EPA stated that
once the Agency completes both the non-cancer and cancer portions of the reanalysis,
the reassessment would be considered final.
The American public has a right to know about the health consequences of exposure to
dioxin, and EPA needs to take steps to protect American families from this unnecessary
harmful class of chemicals.
We urge you to adhere to your stated schedule of finalizing the non-cancer portion of
the dioxin reanalysis by the end of January 2012 and to finalize the cancer portion as
quickly as possible thereafter.
Thank you for your attention to this matter, and for your commitment to protecting
America’s health and environment.
Sincerely,
Rick Hind
Legislative Director
Greenpeace
cc:
Cass Sunstein, Administrator, Office of Information and Regulatory Affairs
Nancy Sutley, Chair, White House Council on Environmental Quality (CEQ)
Paul Anastas, Assistant Administrator, Office of Research and Development,
EPA Rebecca Clark, Acting Director, National Center for Environmental Assessment
4