Last year we posted a notice of the highest measurement of dioxin ever recorded by the EPA. The reading was from the Tittabawassee River in Michigan, downstream from Dow Chemical's headquarters in Midland and on its way to Lake Huron (see map below). Michigan state safe levels are set at 90 ppt. The EPA standard is 1000 ppt. A hot spot reading on the river clocked in at 1.6 million ppt. Last week, the Bush Administration forced out a senior EPA official who was pushing Dow to clean it up.
I'd noticed the story last year of the EPA measurements in a news link on-line. It spurred this alternative sponsor at the blog. A month or so after that, I got a letter from a former student, an engineering graduate. He wrote to tell me of his experiences in the working world and how remarkable he found it that our classroom discussions on engineering ethics had been played out in just his first year on the job. As it happens, he works for an environmental testing firm that had been hired by Dow to provide independent testing of a dioxin hot spot in Michigan.
The ethical scenario he found himself bound up in was about this idea of "independent testing." Apparently, though he couldn't go into great detail in his note and though he didn't know I'd been following the same story, his firm had been sort of caught between Dow Chemical and the EPA. His job was (quoting him) "to characterize the soil samples using a number of small tests to determine the soil type, etc. and to photograph the cores before they were sampled." He found himself "rushing to complete the process under the supervision of both an EPA and a Dow representative, who wanted to take them to an internal Dow lab as quickly as possible." He also noted that he found it odd that "Dow was running scientific tests for on soil samples for release to the EPA which, if certain levels were detected, would lead to liability and enormous cleanup costs."
Given all of this, I was not surprised to read a little later that Dow claimed that the dioxin hot spot was not as damaging as was being reported.
Likewise, I was not surprised but still taken aback when the news broke last week that a senior EPA official had been fired by the Bush Administration for pursuing the case too thoroughly. The Chicago Tribune and The Washington Post both reported that Mary Gade had been fired:
[F]ollowing months of internal bickering over Mary Gade's interactions with Dow, the administration forced her to quit as head of the U.S. Environmental Protection Agency's Midwest office, based in Chicago.
Gade told the Tribune she resigned after two aides to national EPA administrator Stephen Johnson took away her powers as regional administrator and told her to quit or be fired by June 1.
And here is the more interesting part (quoting the Tribune again):
Gade, appointed by President Bush as regional EPA administrator in September 2006, invoked emergency powers last summer to order the company to remove three hotspots of dioxin near its Midland headquarters.
She demanded more dredging in November, when it was revealed that dioxin levels along a park in Saginaw were 1.6 million parts per trillion, the highest amount ever found in the U.S.
Dow then sought to cut a deal on a more comprehensive cleanup. But Gade ended the negotiations in January, saying Dow was refusing to take action necessary to protect public health and wildlife. Dow responded by appealing to officials in Washington, according to heavily redacted letters the Tribune obtained under the Freedom of Information Act.
As the Post noted: "[Dow] has commissioned research showing that soil containing dioxin 'is not a contributor in any meaningful way to levels of contaminants in people's bodies. Both on human health and environmental side, there's not an imminent public health threat.'"
"There is all of this mystique about dioxin," said John Musser, a Dow spokesman. "Just because it's there doesn't mean there is an imminent health threat." (Tribune)
And just because it isn't an imminent health threat doesn't mean it isn't a health threat. Despite Dow's claim, dioxin is a known human carcinogen, listed in the September 2000 draft of the U.S. EPA's Health Assessment document on dioxin (see here). It is a manufacturing byproduct of chlorinated chemicals. It came to the Tittabawassee in part after the production of Agent Orange in the 1960s, along with other chlorinated products. Dioxins were also at the root of problems at Love Canal in the 1970s.
Poisoning from dioxins (it's a class of different chemicals, not "a" chemical) "can cause organ disease, an increased risk of cancer and heart attacks, a suppressed immune system, hormonal imbalances, diabetes, menstrual problems, increased hair growth, weight loss, and, most obviously, the facial cysts known as chloracne." The effects of poisoning became publicly evident in an explicit way a few years ago. The quote I just used is from a Slate.com article written to explain what happened to Ukrainian presidential candidate Viktor Yushchenko, whom many will recall was intentionally poisoned and who, after the incident, appeared with the startling and tell-tale chloracne.
This is a blog and I think I'm supposed to offer my final take, which is this: It's perhaps too obvious to dwell on the moral speciousness of a company spokesman downplaying health effects or the role administrative ideology has played in allowing public health concerns to come under question. Those are easy ones to get up in arms about. The ethical issues also go beyond that and then become less specific. They are much larger than just "doing the right thing" or "following the law." I see this as also being about what kind of science one should do, what kinds of tests need to be done, and who decides.
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It came to the Tittabawassee in part after the production of Agent Orange in the 1960s, along with other chlorinated products. Dioxins were also at the root of problems at Love Canal in the 1970s.