CDC/ATSDR Issues Revised Great Lakes Report for Public Comment

**Background materials included below**

WHO: Dr. Henry Falk, Director, Coordinating Center for Environmental Health and Injury Prevention, Centers for Disease Control and Prevention (CDC)

WHY: On Wednesday, the Agency for Toxic Substances and Disease Registry (ATSDR) issued a revised report on what is known about environmental contaminants and human health in 26 Great Lakes "Areas of Concern." This report responds to a request from the International Joint Commission (IJC) to define the threat to human health from critical pollutants found in the Great Lakes basin. The report analyzes many sources of data on environmental exposures and on human health in the Great Lakes basin.

Key conclusions of the revised report include: 1) available environmental health data provide a useful but only a partial picture of the burden of chemical exposures people in the region face; 2) current health and environmental data collection cannot define the threat to human health from critical pollutants in the Great Lakes region; and 3) need for additional data collection and analysis to permit scientists, decision makers, and members of the public to define the threat to human health from pollutants in the Great Lakes basin.

The report is available on the Internet at http://www.atsdr.cdc.gov/greatlakes. The report is open for public comment for 60 days.

WHEN: Wednesday, April 30, 2008

Noon, ET

Brief remarks followed by Q&A

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TRANSCRIPT

A transcript of this media availability will be available following the briefing at the CDC web site at http://www.cdc.gov/od/oc/media.

Selected Information on Chemical Releases within Great Lakes Counties Containing Areas of Concern (AOC)

A report by the Agency for Toxic Substances and Disease Registry,

US Department of Health and Human Services

Press Briefing Packet

PUBLICATION EMBARGO UNTIL

Noon ET

WEDNESDAY, APRIL 30, 2008

Preface

Public Health Implications of the Great Lakes Areas of Concern

Howard Frumkin, M.D., Dr.P.H., Director

National Center for Environmental Health

and

Agency for Toxic Substances and Disease Registry

The Great Lakes form one of the world's principal freshwater seas, and one of North America's most spectacular and beautiful natural features. For the millions of people who live near the Great Lakes, and the millions more who visit them, the lakes, the watersheds that feed them, and the surrounding land are a source of inspiration and sustenance.

But careless practices over many years have resulted in contamination of the Great Lakes ecosystem. Countless chemical products and byproducts of modern life--solvents, metals, pesticides, persistent organic pollutants, and more--have found their way into the air, water, land, and biota, and even into people's bodies. Substantial cleanup has already been accomplished, and more is underway. We are only beginning to understand the consequences of this contamination.

For almost a century, since the 1909 enactment of the Boundary Waters Treaty, the International Joint Commission (IJC) has helped the U.S. and Canadian governments manage the lake and river systems along the border. An important expression of that commitment was the Great Lakes Water Quality Agreement (GLWQA), first signed in 1972. The GLWQA commits the United States and Canada to restoring and maintaining the chemical, physical, and biological integrity of the Great Lakes basin ecosystem, and explicitly recognizes the importance of protecting human health as part of this task.

The Agency for Toxic Substances and Disease Registry (ATSDR) has been committed to protecting public health from chemical contamination since its formation more than 20 years ago. In 2001, the IJC asked ATSDR for "assistance in evaluating the public health implications of environmental contamination in Great Lakes Areas of Concern." (Areas of Concern are ecologically degraded places in the region.) This report is the response to that request.

In assembling this report, ATSDR scientists surveyed many sources of data on environmental exposures and human health. Ultimately, four kinds of environmental data were included in the report. While each of these draws on a large, sophisticated data base, each has important limitations. Together, these environmental data provide only a partial picture of the burden of chemical exposures people in the region face. Moreover, available health data cannot be clearly linked to the environmental data. As a result, it is impossible to draw firm conclusions about the threat to human health from critical pollutants across the Great Lakes basin.

The major conclusion of this report is that we need better data to allow us to assess threats to human health. Even as we work to prevent pollution, and clean up the residua of past emissions -- much-needed efforts that are well underway -- we need to advance our understanding of the health consequences of chemical exposures. Better data are an essential first step.

The preparation of this report

An early draft of this report became public in 2007, before ATSDR had not finished reviewing and finalizing it. That draft raised scientific concerns, which are described at http://www.atsdr.cdc.gov/grtlakes/pdfs/Scientific_Concerns.pdf. Accordingly, ATSDR held up release of the report, and set about correcting the deficiencies.

While this is a routine procedure to assure scientific quality, it was misinterpreted by some as suppression of science. Several important points became clear.

First, good science matters. The 2007 draft was not ready to be released because it did not clearly assemble, analyze, and present the available data. Such a document could lead to incorrect conclusions. Second, good communication matters. It is important to make methods, data, and conclusions clear to all readers of a report. Third, people care passionately about the environment, about health, and about the links between the two. All of us -- at our Agency, across the Great Lakes region, across the nation -- believe in wholesome, healthy, environments, and believe that accurate, timely information will help us get there. That shared concern is a precious resource.

This report aims to be accurate, informative, and useful to health professionals, decision-makers, and the public. It confirms that the Great Lakes basin is contaminated with toxic chemicals, that we lack sufficient information about human exposure to these chemicals, that we are therefore unable to draw solid conclusions about their health impact across the region, and that we need better information. I am proud that our Agency -- together with many partners in government, academia, civil society, and the private sector -- is taking steps to fill data gaps and improve our understanding, from our Great Lakes Human Health Effects Research Program (http://www.atsdr.cdc.gov/grtlakes/program-overview.html) to our Biomonitoring program (http://www.cdc.gov/biomonitoring/).

This report is an important step on the journey toward understanding the public health implications of environmental contamination in the Great Lakes basin. We need to work hard to build that understanding. More importantly, we need to apply that understanding, by taking effective action to protect people now and in the future, and to sustain a healthy ecosystem.

Acknowledgments

Thanks to the many contributors, reviewers, and partners who helped produce this report. Above all, thanks to the many members of the NCEH/ATSDR staff who came together over recent months to check data quality, explain methods, strengthen data analyses, upgrade GIS maps, clarify writing, and otherwise do what had to be done to produce a high-quality report. Their hard work, dedication, and professionalism made all the difference.

Executive Summary

Background: This report responds to a request from the International Joint Commission (IJC), the binational organization that works to implement the Great Lakes Water Quality Agreement (GLWQA) between the U.S. and Canada. The GLWQA calls for the two nations to define "the threat to human health from critical pollutants" found in the Great Lakes basin.

This report: The geographic focus of this report is a set of 26 "Areas of Concern" (AOCs) along Great Lakes streams, rivers, and lakes. These AOCs are defined under the Agreement as ecologically degraded geographic areas requiring remediation. In response to the IJC request, this report summarizes previously-published public health assessment products and chemical release information for the 26 U.S. AOCs and 54 counties that are in close geographic proximity to those AOCs. Much of the available data pertain to counties, and not to AOCs. Some AOCs occupy small parts of a single county, while others may reach across more than one county. The data come from publicly available data sets provided by ATSDR and the U.S. EPA.

The pollutants: The GLWQA defines "critical pollutants" as substances that persist in the environment, bioaccumulate in fish and wildlife, and are toxic to humans and animals. There are 12 categories of critical pollutants. This report emphasizes the critical pollutants (within the constraints imposed by using existing data) but also presents information on other pollutants, when such information is available and relevant.

Environmental data: This report compiles and presents previously collected environmental data from four sources:

These data are presented in three ways: in text, in tables, and in Geographic Information System-based (GIS) maps created by ATSDR for each of the 26 U.S. AOCs.

Health Data: To be useful for assessing potential health effects related to AOCs, health data should have the following characteristics:

Except as noted in the context of ATSDR health assessment products, no currently available health data meet these needs; thus this report does not include other health data. ATSDR remains committed to improving the availability and relevance of data linking health and environment over time.

Conclusions: This report yields five principal conclusions.

First, there is evidence of environmental pollution in the Great Lakes region, including both past and ongoing releases. Of more than 140 hazardous waste sites located in AOC counties and evaluated by ATSDR, 86 were identified as having a potential human health impact, including 2 classified as "urgent public health hazards," 47 as "public health hazards," and 37 as "indeterminate public health hazards." Many but not all of these sites have been remediated. The TRI and NPDES data reveal ongoing releases of pollutants in or near almost every AOC. Beneficial use impairments exist across much of the region.

Second, the available information on environmental pollution in the Great Lakes region is limited and incomplete. Data sources such as TRI exclude important sources of pollutants. Other sources and pathways of exposure -- in food, in air, in drinking water, in consumer products, in workplaces -- are not captured by available databases.

Third, the available information on environmental pollution provides little insight on people's exposure to pollutants. TRI data on chemicals used and emitted, and NPDES data on chemicals discharged into water, do not indicate whether these chemicals reach people and enter their bodies. ATSDR assessments of hazardous waste sites do include analysis of exposure pathways, but do not include data on how much exposure actually occurs.

Fourth, available health data are not well matched to the exposure data and therefore cannot be used to help assess whether the environmental exposures have adverse health consequences. Much more and better health data will be needed to provide useful information on health outcomes of greatest interest, such as neurobehavioral, endocrine, reproductive, and immune function.

Fifth, for all these reasons, it is currently impossible at this time to define "the threat to human health from critical pollutants" found in the Great Lakes basin -- the inquiry that motivated this report. This query remains keenly important in view of evidence of contamination in many areas of the Great Lakes basin, and this report serves to highlight the pressing need for better data, properly collected, organized, and analyzed, to help define threats to human health and optimal strategies for protecting health.

Recommendations: These conclusions support the need for additional data collection and analysis to permit scientists, decision makers, and members of the public to define the threat to human health from pollutants in the Great Lakes basin. Needed activities include:

Conclusions and Recommendations

7.1 Conclusions

The IJC requested ATSDR assistance in "evaluating the public health implications of environmental contamination in Great Lakes AOCs by providing information on ATSDR's public health assessment products of hazardous waste sites within these AOCs." This report extends the scope of that request by providing information on other sources of environmental contamination in the region, and from sources near but not in the AOCs.

This report summarizes the environmental information about the 26 US AOCs and the associated 54 AOC counties in the Great Lakes region. For the first time this report consolidates the findings from the ATSDR site specific public health assessment products for 150 sites in the Great Lakes region and summarizes publicly available environmental information for the 54 AOC counties. For each site addressed in this report it describes the site and addresses the current status of environmental clean up efforts at the site.

Additionally chapters 2-6 provide data from ATSDR public health site assessment products that identify sites within the Great Lakes AOCs with ongoing problems and the current status of remediation efforts.

The ATSDR site data show documented, possible, or unknown contaminant exposures in 150 sites in the 54 AOC counties. Of these, at the time of this report 81 sites no longer present a continuing source of contaminant exposure as verified by ATSDR, USEPA, or state agencies. The remaining 69 sites are in various stages of site characterization or remediation, or remediation is not planned.

The TRI and NPDES data refer to releases in 54 "AOC counties," counties impacted by the presence of degraded ecosystems. These data show ongoing releases of critical pollutants, and other chemicals, across the Great lakes region.

Fish-tissue monitoring has documented contaminant levels above health-based values, resulting in advisories to limit fish or wildlife consumption in all 26 AOCs, with the exception of Presque Isle Bay in Pennsylvania. In some cases fish advisories are specific to locations within an AOC and result from chemical releases into the AOC, but in many instances fish advisories are regional in scale. Eight of the AOCs listed restrictions on drinking water consumption or problems with odor or taste. Specific reasons were not always available. In one instance (Grand Calumet) chemical substances in treated drinking water was cited as a reason for the listing of this impairment. The publications and public health research findings from the ATSDR Great Lakes Research Program presented in Appendix 3 document important health outcomes among persons living in the Great Lakes Basin from consumption of fish and game contaminated with persistent organic chemicals from chemical releases related to the AOCs. It is worth noting that from 1992 to the present, the Great Lakes Research Program has supported approximately $32 million in extramural research in the Great Lakes. This represents a tangible commitment on the part of ATSDR to public health in the region.

Taken together, these bodies of knowledge provide a scientific basis for justifying future hypothesis - driven research studies capable of providing answers to important public health issues of concern in the Great Lakes Basin.

The questions that motivated this report are important. They matter to members of the public who live in the Great Lakes region, to health care providers, and to public officials. In view of evidence of contamination in many areas of the Great Lakes basin, efforts to move toward answers, in scientifically rigorous, accurate ways, are well justified. However, this report reveals considerable limitations in the ability to answer these questions.

A range of health effects may be associated with toxic exposures. At high exposure levels, these health effects may be obvious. At lower exposure levels, health effects may be more difficult to quantify and to attribute to chemicals, especially when other factors also contribute to risk, or when the health effect occurs long after the exposure. Examples include some of the most widely discussed effects of chemical exposures: cancer, reproductive abnormalities, endocrine disruption, neurobehavioral dysfunction, and developmental abnormalities.

Health data are not routinely collected on most of these outcomes. Available health data, such as vital statistics and hospital discharge data, are collected for other purposes, and address health outcomes generally not related to chemical exposures. Even health data of interest, such as those from cancer registries, are collected on different spatial and temporal scales than available environmental data, and the data bases do not link with each other. Accordingly, the available health data do not help elucidate the effects of exposure to environmental pollutants.

Given the limitations of currently available environmental and health data, the threat to human health from critical pollutants found in the Great Lakes basin cannot be clarified. This report serves to highlight the pressing need for better data, properly collected, organized, and analyzed, to help define threats to human health and optimal strategies for protecting health.

Data are available only for certain sources of environmental contamination, and under certain conditions. TRI data do not reflect the totality of toxic releases, since small firms, firms from certain industry sectors, and other categories of emitters, are exempted from reporting. The NPDES captures direct emissions to surface waters from industrial, municipal, and other "point sources," but it includes no information on non-point source water pollutants. ATSDR health assessment products are based on available site-specific sampling data and may not fully characterize every exposure pathway or contaminant. These data, taken together, do not include exposures from pesticide applications, from mobile sources, or from indoor sources. In short, the available data provide a very partial picture of contaminants in the environment.

The available data do not indicate whether people are actually exposed. For exposure to occur, there needs to be a completed pathway from a source to people's bodies. Discharge of a pollutant into a stream (as indicated in NPDES) does not mean that people are exposed to that pollutant, or if so, how much. Use of a chemical in a factory, as reported in TRI, does not mean that people are exposed to the chemical, or if so, to what extent.

Consider the reported releases of lead and lead compounds (2,200,000 pounds) in the Maumee River AOC; lead and lead compounds (430,000 pounds), mercury and mercury compounds (14,000 pounds), and PCBs (1,200,000 pounds) in the Rouge River AOC; and dioxin and dioxin-like compounds in the Saginaw River and Bay AOC, all primarily released to land. These releases represented disposal in Resource Conservation and Recovery Act (RCRA) Subtitle C landfills, which are authorized to accept hazardous waste for disposal and operate under very stringent guidelines. Although these RCRA-land filled releases may serve as reservoirs of these chemicals, they should not be contributing to human exposure.

To be useful for assessing potential health effects related to chemical exposures in AOCs, health data should be biologically associated with relevant exposures and be well-matched to the environmental data in space and time. In addition, data should be available that can clarify the role of other non-environmental risk factors. For example, if a chemical is suspected of contributing to premature births, other risk factors for premature birth should be known and taken into account. Ideally, these data should be available on the individual level, and not at the population level, for proper data analysis. Very little routinely collected and available health data meets these tests.

7.2 Recommendations

Understanding environmental conditions in the Great Lakes region and protecting residents from possible health effects is a priority for ATSDR and CDC. Community members in the Great Lakes region deserve accurate information provided in a timely manner. ATSDR and CDC have a number of programs that serve these aims: ATSDR conducts a range of activities at hazardous waste sites to protect the public from exposure to hazardous chemicals. Between January 2001 and February 2008 in the 8 Great Lakes states ATSDR has worked at 528 sites and this work has resulted in 756 documents.

Although there are extensive ongoing activities, this report supports the need for additional data collection and analysis to permit scientists, decision makers, and members of the public to define the threat to human health from pollutants in the Great Lakes basin.

ATSDR strongly supports the need for data collection and research to help elucidate the links between chemical contamination and health effects, in the Great Lakes region and elsewhere. Existing efforts at ATSDR and CDC, such as the Environmental Public Health Tracking program (http://www.cdc.gov/nceh/tracking/) and the Great Lakes Human Health Effects Research Program (http://www.atsdr.cdc.gov/grtlakes/program-overview.html), represent important steps toward those goals. This report suggests that further such efforts are well justified.

Improving the Science in the Draft Report: Selected Information on Chemical Releases within Great Lakes Counties Containing Areas of Concern (AOC)

Since its formation more than 20 years ago, the Agency for Toxic Substances and Disease Registry (ATSDR) has been committed to the protection of public health from chemical contamination. In 2001, the International Joint Commission (IJC) asked ATSDR for "assistance in evaluating the public health implications of environmental contamination in Great Lakes Areas of Concern."(1) In response to that request, ATSDR developed a report entitled "Selected Information on Chemical Releases within Great Lakes Counties Containing Areas of Concern (AOC)"(2)

An in-process draft of this report became public in 2007, before ATSDR had finished reviewing and finalizing it. That draft raised scientific concerns. These concerns are described at http://www.atsdr.cdc.gov/grtlakes/pdfs/Scientific_Concerns.pdf. Accordingly, ATSDR delayed release of the report and set about correcting the deficiencies. This statement summarizes actions taken to assure the scientific quality of the current (April 2008) draft.

Whether people in the Great Lakes region are exposed to environmental contaminants in ways that could affect their health is an important question. The answer depends on a solid science base with accurate environmental data, knowledge of whether and how people are exposed to environmental contaminants, accurate health outcome data, appropriate data analysis, and conclusions supported by the data. The exposure data and the health data must correspond in geographic location and in time. For readers to assess the science accurately, the process of collecting, analyzing, and interpreting information must be clear and transparent.

From the perspective of ATSDR senior scientists, the July 2007 draft report suffered from serious deficiencies in many of those areas. An inter-divisional ATSDR workgroup, with help from the National Center for Environmental Health/ATSDR Office of the Director (OD), have worked to remedy the deficiencies. Below is a short summary of the major concerns and how they were addressed in the current (April 2008) draft:

Scientific methods: The methodology for the July 2007 and previous working drafts was unclear. Readers of the drafts could not identify key processes the authors used to analyze the data and draw conclusions, particularly relating to the use of county health data.

In the April 2008 draft, this problem was addressed as follows:

Environmental data: Multiple improvements were made in the environmental data presented in the April 2008 report relative to earlier drafts.

Exposure information: The information summarized in the 2007 draft and other previous working drafts of this report did not indicate whether, when, and how people might have been exposed to environmental contaminants. In Chapter 7, the April 2008 draft report acknowledges these gaps and recommends additional scientific work to address them.

Health data: The 2007 draft based its conclusions in part on preexisting health data collected for other purposes. Specifically, included in the 2007 draft were county-level data compiled by the Association of State and Territorial Health Officials, the National Association of County and City Health Officials, and the Public Health Foundation, with support from the Health Resources and Services Administration (HRSA) http://www.phf.org/CHSI-notes.pdf. Although those health data are useful for many purposes, several considerations mitigated against their inclusion in the April 2008 draft report:

In response to the above concerns, the health data have been removed from the April 2008 report -- again, they are available on the Web at the address noted above. Chapters 1 and 7 provide a general discussion of the reasons why available environmental data are not generally linked to health data in this report.

Scientific review: Several rounds of peer and expert review of 2007 and 2004 working drafts of the report were conducted. Yet, many important reviewer comments were not adequately addressed, especially related to concerns about including the health data. For this report, responses to all peer review and stakeholder review comments were considered. Changes to the 2008 report summarized in this statement represent steps forward in addressing peer and expert reviewer comments.

Conclusions: Some conclusions of the 2007 and other previous working drafts overreached available data. For example, the 2007 report contained statements such as "[the study] would tend to underestimate patterns of contamination as well as potential health effects to vulnerable populations," that concluded or implied health effects from environmental contamination even while other statements in the drafts admitted an inability to estimate health effects. Chapter 7 of the 2008 draft better matched conclusions with the available data.

Recommendations: The 2007 and other previous working drafts of this report generally lacked recommendations for public health science and practice. The 2008 report uses its updated knowledge of environmental contamination in the Great Lakes region to make additional recommendations.

Summary: Understanding environmental conditions in the Great Lakes region and protecting residents from possible health effects is a priority for CDC and ATSDR. Community members in the Great Lakes region deserve accurate information provided in a timely manner. The decision to take additional time to improve the draft report in order to ensure its scientific quality was necessary.

For more than 20 years, CDC and ATSDR consistently have provided the people living in the Great Lakes states with up-to-date information to help protect them from exposures to toxic chemicals. In the eight Great Lakes states -- between January 2001 and February 2008 -- ATSDR has developed and supported 756 documents pertaining to 528 sites and both ATSDR and NCEH have many ongoing scientific and programmatic activities. CDC and ATSDR are committed to providing useful and scientifically sound information that will help decision-makers protect the public health and the environment.

1. The USEPA defines a Great Lakes Area of Concern as "a severely degraded geographic area within the Great Lakes." See http://www.great-lakes.net/envt/pollution/aoc.html#overview.

2. Previous drafts were titled Public Health Implications of the Great Lakes Areas of Concern (AOC)

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SOURCE Centers for Disease Control and Prevention