Jonathan Campbell, Health Consultant
Natural Therapies for Chronic Illness & Health Maintenance

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The ATSDR is in the process of officially downgrading the toxicity of dioxin, by upgrading the maximum tolerable dose to 1 picogram/kg/day. The EPA's dose limit, published in the 1994 Draft Dioxin Reassessment, is 0.006 picogram/kg/day.

The new rule, called the "Minimal Risk Level" is specified on page 216 of the Draft Toxicological Profile for Chlorinated Dibenzo-p-Dioxins, available from ATSDR, pub 099-5363.

Public comment is due by Feb 17, 1998, to be sent to: Agency for Toxic Substances and Disease Registry Division of Toxicology, Mail Stop E-29, 1600 Clifton Rd. NE, Atlanta, GA 30333

Also send comments to David Satcher, Administrator ATSDR (spelled out, as above) 1600 Clifton Road NE Atlanta, GA 30333

We need to mount both a scientific and political (popular) campaign to stop this effort, which I believe may have industrial roots (though they may just be stupid or arrogant). They have either accepted the cancer risk of 1 in 1000 to 1 in 10,000 [see Dying From Dioxin, page 74] for 70 years exposure, or they have re-calculated cancer risk to a lower value through some obfuscation (the document is very difficult to read to actually get any information from it).

We are in the middle of a cancer epidemic. One out of 2 American men, and one out of 3 American women, will contract cancer in their lifetimes. The rise in background and food levels of dioxin is a likely source of the epidemic. Especially significant is the dramatic rise of prostate cancer in men, which is hormone-related. There is an epidemic of Attention Deficit Disorder, which is correlated with PCB and dioxin exposure during gestation and lactation. There is an epidemic of endometriosis, correlated with dioxin exposure: over 5 million women have it. It was all but unknown at the turn of the century.

The point here is that at current BACKGROUND levels of dioxin we are seeing health effects. At the levels ATSDR recommends as Minimum Risk Level (1 pg/kg/day), it would be acceptable for an adult human to have 1.7 million picograms TEQ for a seventy year lifetime, or 25,000 pg/kg (25 ng/kg) body weight. The EPA previously calculated that the lowest level of dioxin to have caused harm in humans (that we know of) is 14ng/kg body weight. That means that the majority of the population will be way over the dioxin causation limit.

Please send letters to ATSDR calling on them to ratify the EPA limit, based on good science, of .006 pg/kg/day, or to set it to ZERO because many or most of us are near or at the "limit" for harm. (Some scientist even challenge this "limit". Each picogram of dioxin contains 1.88 BILLION molecules of dioxin, each of which is capable of disrupting a cell.)

Please take this note and re-post it or your own anywhere you think you might be able to convince others to send in critical comments.

Thanks

Sample Letter to ATSDR

Jonathan Campbell
1 Minot Ave., Littleton, MA 01460
Phone: 978-263-6754>

Agency for Toxic Substances and Disease Registry
Division of Toxicology
Toxicology Research Branch
1600 Clifton Road, E-29
Atlanta, GA 30333

Subject: ATSDR Update of Toxicological Profile for Chlorinated Dibenzo-p-Dioxins

Greetings,

Recently your office issued a document entitled Toxicological Profile for Chlorinated Dibenzo-p Dioxins, Update, Draft for Public Comment. This letter is to comment on this update and provide you data for your serious consideration.

I want to first say that I am greatly appreciative that in this document you have cited perhaps the largest amount of dioxin-related information available anywhere publicly.

However, that said, I am most concerned with, and I object to, your proposed Minimal Risk Level (MRL) for TCDD-equivalent of 1 pg/kg/day, specified on page 216 of the document in question. I do not understand how your agency, having reviewed the same cancer and non-cancer data as the Environmental Protection Agency, can come up with an MRL which is 200 times as large as the "maximum acceptable dose" published by the EPA in the 1994 Dioxin Reassessment.

1. In particular, simple mathematics shows that your MRL is clearly not protective of human health. First, the EPA has calculated that the lowest body burden level known to cause harm in humans is 14 ng/kg. Using the ATSDR’s proposed MRL of 1 pg/kg/day, a person exposed for 70 years, assuming no elimination, would accumulate levels of over 25 ng/kg average in some parts of the body. Since the mechanism for elimination of dioxin, especially at these lower concentrations, is extremely slow and varies by type of cells, we can only assume that nearly the full concentration will exist in some parts of the body for a large percentage of the population. This variation in dioxin body burden is confirmed in the autopsy results published in your proposed Toxicological Profile. General exposures at this MRL will expose a very large proportion of the population to dioxin-induced cancer and other dioxin-related diseases and afflictions.

2. "Background" dioxin exposure by a large proportion of the U.S. population to levels at the proposed MRL are already probably causing a nationwide health crisis. The consumption of dioxin-contaminated meat and dairy products in the U.S. has exposed the majority of U.S. residents to levels of dioxin of approximately 70-100 picograms of dioxin TEQ per day. Today, one out of every two men, and one out of every three women in the U.S. will contract cancer in their lifetimes. The cancers seeing the largest increases are those that are related to endocrine dysfunction, such as pancreatic, prostate, breast, ovarian, and cervical. Dioxin is the most powerful endocrine disrupter known, and has the steepest cancer dose-response curve of any organic chemical known. We must assume that dioxin exposure is likely partially responsible for the dramatic increase in cancer during the last 20 years.

In addition, millions of U.S. women suffer from endometriosis, an affliction all but unknown at the beginning of this century. Endometriosis is a dysplasic affliction: it is caused by the reproduction of the wrong type of tissue (endometrium) on the walls of the fallopian tubes. This in turn is caused by an improper or disrupted genetic message reaching the cell – the same kind of disruption that dioxin and dioxin-like chemicals are known to cause.

There are many other diseases and afflictions linked to or correlated with exposure to dioxins or PCBs. Attention Deficit Disorder, diabetes, chronic fatigue syndrome, rare nervous and blood disorders have been so linked.

Agencies of the U.S. government such as ATSDR must provide MRL standards that reduce chronic dioxin exposure below current "background" levels, to prevent even higher body burdens than exist today. Such action will prompt action by consumers and food advocacy groups to reduce contaminated meat and dairy intake, and encourage changes in industry and government to reduce dioxin production.

There is, in fact, no MRL that is protective against health effects of dioxin exposure. Each picogram of TCDD contains 1.88 billion molecules, each of which is capable of disrupting the normal actions of a cell, in ways that are undetectable by our immune system. There is just no way to know whether disrupted cells will suddenly divide uncontrollably, causing cancer, or reproduce the wrong kind of cell (dysplasia), or disrupt nerve messages, or cause an improper immune response.

The ATSDR should specify an MRL of ZERO for dioxin. At the very least, the ATSDR must affirm the lower "acceptable" dioxin dose published in the EPA Dioxin Reassessment of .006 pg/kg/day.

Sincerely,
Jonathan Campbell
February 3, 1998