What's New: Archives

May 19, 2005 - Revisions to "Dioxin Serum Levels"

Greater attention is now being given to dioxin blood serum levels in residents residing along the Tittabawassee River.  Some of the information that has been reported is incorrect and possibly misleading.

DioxinSpin.com is being expanded to include more information on this extremely important topic.

April 18, 2005 - Dioxin Newsletters

The "Framework" for a proposed agreement between The Dow Chemical Company and the DEQ requires that the company send each of the Priority 1 property owners a "dioxin communication package".

DioxinSpin.com has obtained a copy of Dow's initial proposal which is based on supplying a copy of the various dioxin pamphlets developed by various MI and US regulatory agencies.

While this information is valuable in providing general information on dioxins, the proposal does not provide a complete picture of the potential impact on human health from dioxin exposure in the Midland area.

DioxinSpin.com will be mailing Dioxin Newsletters to the Priority 1 property owners in order to provide additional information on dioxin topics that might be of interest to persons that reside on dioxin contaminated properties.  The first Newsletter was mailed the week of April 11, 2005.

The Newsletters will also be available on this website.  Readers that find the information to be of value are welcome to distribute copies to other interested persons or at dioxin information meetings.

More information and copies of the Newsletters can be found via the "Dioxin Newsletters" button on the left side of the page.

March 16, 2005 - "Flawed Science"

The importance of "sound science" in helping to resolve the various issues associated with dioxin contamination in Dow's Midland plant, in Midland and in the Saginaw Valley can not be emphasized enough.  In the November, 2004 issue of Community Update, the company said:

"Dow strongly believes that the only way to find real solutions to this situation is by knowing the facts."  "We continue to welcome your feedback and comments as we work thought this issue.  Thank you for your ongoing interest and support."   "Your input is essential. We want to hear from you."

Based on Dow's desire for factual information, DioxinSpin has been revised to include a new section – "FLAWED SCIENCE". (See link on left side of page)

The section will provide an analysis of potential mistakes and oversights that might be present in the company's various studies on the effects of dioxin exposure on human health.  Each "analysis" will focus on a single concept and will generally be no more than 4 to 5 pages in length.  Hopefully, "Flawed Science" will be an "easy read" for the reader with a non-technical background.

DioxinSpin welcomes comments and criticism from not only the company but also from any reader with an interest in dioxin contamination issues.

March 10, 2005 - Furans in the river

The Dow Chemical Web site has posted information as to the potential impact of furans from the very early chlorine cells on the present day levels of dioxins/furans being found in the Tittabawassee River.  The information suggests that the company may have lost a great deal of its dioxin-related "expertise" and knowledge of the Midland operations.

DioxinSpin has provided an analysis and comments of the company's chlorine cell information including specific dioxin "expertise" and historical items that the company's writers may not have been aware of. 

Link to :   "Forgotten Science - Forgotten History"  

February 17, 2005 - "Framework" For A Proposed Agreement

In January, 2005, the Michigan DEQ and The Dow Chemical Company agreed to a "Framework For An Agreement" to resolve many of the issues associated with dioxin contamination of Midland area soils and the floodplain of the Tittabawassee River.  The "Framework" was negotiated without public comment.

1.   The "Framework" is based on an incorrect assumption that dioxin contamination of Midland was the result of emissions from a single source : the company's incinerator complex.  Modeling of dioxin levels in the neighborhoods selected for reduction of dioxin exposure indicates that the Wexford Avenue neighborhood may have been contaminated by at least two sources of emissions.  If the modeling is correct, then the "Olde Towne" portion of Midland was also affected by the two sources.  To date, "Olde Towne" has been sampled at only one location to determine dioxin levels.  The "Framework" does not require any additional sampling of Midland area soils until 2006, at the earliest.

2.   The "Framework" established the March, 2004 flooding as a criteria for activities to reduce the potential for dioxin exposure being experienced by Tittabawassee River residents.  However, the record flood of September, 1986 (crest = 33.94 ft) was more extensive than the March, 2004 flood (crest = 27.45 ft).  The 1986 flood inundated an area approximately seven (7) times greater than that flooded in 2004. 

On the basis of the 2004 flood, the "Framework" identified 140 riverside properties as Priority 1 locations entitled to some degree of residential cleanup and other dioxin exposure reduction activities.  The number of residences entitled to dioxin cleanup based on the 1986 flooding is not known at this time.

October 5, 2004 - New Zealand TCDD Body Burden Study

In September, 2004, the New Zealand Ministry of Health released the results of a study that correlated TCDD body burden levels with TCDD soil levels for 24 long term residents that lived in proximity to a 2,4,5-T plant owned and operated by Ivon Watkins-Dow from 1960 to 1987.  The plant  also produced trichlorophenol (and TCDD) from 1969 to 1987.   The plant is now part of Dow AgroSciences.  A summary of the findings of the study and estimates of TCDD body burden levels in some MIdland, MI and Tittabawassee River residents is provided

More information is available via "Dioxin Body Burdens" on the left hand side of the page.

August 3, 2004 - Dow Mortality Studies Are Once Again Available On Dow Website

The mortality studies that Dow Chemical offered as evidence that there is no convincing evidence of links between specific cancers and potential dioxin exposure are once again available on a Dow web site.  A link to the site is as follows:
         
http://www.dom.com/facilities/namerica/michigan/dioxin/scientific/health.htm

Many thanks to those readers that might have sent an e-mail to Dow asking for the new web location of the studies.  Rumors have been circulating that the Midland Daily News was considering a story about why Dow removed these "critical" reports from the internet. 

In a community, such as Midland, with a large population of researchers that routinely practice a free exchange of scientific information, removal of the studies would have raised questions about the validity of the studies.  Although sometimes flawed, these studies are still a vital part of Dow's overall dioxin strategy.  The risk of losing support of the scientific members of the community by no longer allowing easy access to the studies may have caused Dow to rethink their removal.

Dow has yet (as of Feb. 17, 2005) to post the most recent updates of the mortality of its dioxin exposed workers : KM Bodner, et al, Cancer risk for chemical workers exposed to 2,3,7,8-tetrachlorodibenzo-p-dioxin, Occup. Env. Med. 2003: 60:672-675 and the unpublished JM Ramlow, et al, Ten-Year Update of a Cohort Study of Workers with Potential Exposure to Higher Chlorinated Dioxins, 1997. 

Bodner, 2003 is available in DioxinSpin.com "Mortality Studies A".  DioxinSpin.com has a hard copy of Ramlow, 1997.  If Dow does not add this study to its web site in the near future, perhaps DioxinSpin.com will – provided that Dow gives permission.

It's a credit to Dow that the first study that is listed is the NIOSH, Fingerhut, 1991 study that clearly shows several linkages between dioxin exposure and elevated mortality from certain cancers.  This study evaluated the mortality of 5,100 dioxin-exposed chemical workers from 12 different companies.  Dow's 2,200 dioxin employees were part of the study cohort.  The NIOSH study is an excellent example of an objective and comprehensive epidemiology study and well worth the reading.

DioxinSpin.com has questioned the data, methodology and the conclusions of some of the Dow studies.  Specific comments can be found in the sections (see left side of page) with "Mortality" was part of the title.

July 9, 2004 - Midland Dioxin Levels In Prior Years; Mortality of Midland Plant Workers

It is well recognized that the Midland community has very high levels of dioxins – much higher that the typical Michigan or US community.

Mathematical modeling of dioxin levels for the years when Dow's chemical waste incinerators and tar burners were in operation indicates that maximum dioxins levels in the community may have been more than 12 times higher than those measured in 1996 – max 3,690 ppt-TEQ vs. 289 ppt-TEQ.

Modeling of dioxin levels at Dow's Midland plant indicates that maximum levels were more than 25 times higher than the average dioxin levels measured in 1996 by the DEQ – max 83,903 ppt-TEQ vs. 3,255 ppt-TEQ.

Modeling using dioxin levels found in 1996 at a potentially undisturbed location, inside the Midland plant fenceline, suggests that maximum dioxin levels could have been more than 200 times greater than the average levels found in 1996 – max 656,340 ppt-TEQ vs. 3,255 ppt-TEQ.

More information on dioxin levels in prior years can be found in the "Dioxin Levels" section or via this direct link:  Link to Dioxin Levels in Prior Years

Although information on the impact of wide-spread dioxin exposure to Midland plant employees is very limited, there are some Dow studies that suggest that the Midland plant location has a significant elevation in both very rare cancers and mesothelioma, a cancer normally associated with asbestos exposure.  The NIOSH, 1991 study indicates a possible linkage between deaths from the very rare cancers and dioxin exposure.

More information on the mortality of Midland plant workers can be found in the "Dioxin Toxicity" section or via this direct link:  Link to Midland Worker Mortality

June 10, 2004 - Mortality Statistics

There seems to be some confusion on that part of some Midland and river residents as to why, if dioxin exposure is so harmful, there has not been a cancer "epidemic".   Without such an epidemic, the risk of dioxin exposure must be significantly overrated.  This opinion may be shared by many Midland and river residents.

There is a very fine line between a "statistically significant" elevation of cancer mortality and "no causal relationship".  Assuming that there are 5000 long term residents along the river, the difference between these two widely different findings is approximately 34 additional deaths spread over 45 years spread over more than 20 miles of river — hardly epidemic proportions.

Dioxin exposure does cause an elevated mortality from cancer.  However, the additional (and un-necessary deaths) occur over the course of many years.  These additional deaths may be noticeable only to an epidemiologist — and to the deceased and their families.

For more information, go to Mortality Statistics

May 21, 2004 - Overview of Dow's Incinerators and Tar Burners

An overview of the past Midland plant chemical waste incinerators and tar burners from the 1930's to the present has been assembled.  The overview also provides information on waste tar incineration in Dow's powerhouses during the 1060's.    Link to Incineration Overview

May 13, 2004 - Information on Two Chemical Waste Ponds Reclaimed as Building Sites - Possible Chemical Exposure to Employees (Aerial Photographs Available)

A 1949 aerial photograph of Dow's Midland Plant indicated the presence of two chemical waste ponds that had been filled-in during 1949 to the early 1950's and reclaimed for use as sites for several manufacturing plants, warehouses and office buildings.  Link to Waste Ponds

May 9, 2005 - Correction to Comments on Dow's Scope of Work on Tittabawassee River

The MDEQ has informed me that, due to system improvements,  Dow is no longer allowed to turn off the Revetment Groundwater Interceptor System (RGIS) when the river is overflowing the sheet piling that separates the collection tile from the river.

The March 25, 2004 (pg 7) comments to the MDEQ on Dow's proposed Scope of Work for the Tittabawassee River contained out-of-date information.  The original  comments are available below on this page.

May 6, 2005 -  Mortality Studies "C" Added

Dow carried out two mortality studies on more than 35,000 employees that worked in the Midland and Bay City sites.  These studies examined worker mortality from 1940 to 1982 and from 1940 to 1994.

 Although the studies were not dioxin-specific, the data indicates that general chemical exposure can result in increased mortality, especially from certain specific cancers.  Cancer mortality for hourly employees increased with duration of employment and hourly workers with more than 20 years of employment demonstrated statistically significant elevations of several cancer categories.  The 1940 to 1982 study failed to include approximately 6,250 employees that worked in Dow's Bay City Magnesium Foundry even though the foundry workers clearly met the cohort criteria.

The 1940 to 1994 study provided details on the elevated mortality of the foundry workers.  Due to the large number of changes made to the study cohort, the study can not be considered as an update of the 1940-1982 study.

DioxinSpin.com commentary is presented that shows that the 1940-1994 study was based on questionable methodologies that may have invalidated the conclusion that worker health is better than the national average.

April 16, 2004 - Mortality Studies "B"  Added

Dow has stated that the Dow workers (n = 2,092) that were included in the NIOSH, 1991 mortality study of dioxin exposed chemical workers had lower overall mortality and total cancer mortality than did the 3,080 workers that worked for the other eleven companies in the study.  However, an examination of data indicates that Dow employees had higher mortalities in eight (8) cancer categories while the other companies' employees had higher mortalities in only five (5) cancer categories. DioxinSpin.com analysis provides a side-by-side comparison of cancer mortalities of the Dow employees and the non-Dow employees.

This website section also contains a side-by-side comparison of the mortality of Dow employees as determined by one NIOSH and six Dow epidemiology studies.  The "clustering" of elevated mortalities for certain cancers is especially noticeable.

April 13, 2004 - Chloracne Incident Added

Chloroacne is a skin condition that is normally associated with exposure to high levels of chlorinated aromatic compounds, such as dioxins and furans.  TCDD is recognized as the chemical that causes the greatest chloro-agenic response in humans.

Prior to the startup of Dow's new 2,4,5-trichlorophenol plant in 1963, the incidence of chloroacne in the Chlorophenol production plants was very low with only 1-3 cases per year being observed. 

Dow's new 2,4,5-trichlorophenol process produced significantly higher levels of TCDD than did the old process.  Thirty five (35) new chloroacne cases were reported in the first year of production.  Dow shutdown the new plant for approximately one year to decontaminate equipment and to install approximately $5 million of new equipment to remove the high amounts of TCDD in the product. 

The new plant continued to struggle with high levels of chloroacne for the entire operating life of the plant.  In 1970, a record high 90 chloroacne cases were experienced. 

Despite the fact that Dow continued to claim that TCDD exposure only resulted in a mild skin condition, it is believed that once a worker was diagnosed with chloroacne, the employee was assigned a job in a non-TCDD plant.

Dow has never fully released the full details of the chloroacne "incident".  The website summary is based on information contained in several Dow reports and on the author's personal experience.

April 13 - Mortality Studies "A" Amended

In 2002, Dow updated the mortality of its 2,100+ employees that had been exposed to dioxins.  The Bodner, et al, 2002 study examined the mortality of these workers from 1940 to 1994. 

The update failed to clarify vague areas in several previous Dow studies and failed to provide an update on mortality from "Rare Cancers of Other and Unspecified Sites", a category that several Dow studies found to be significantly elevated for the dioxin cohort and for the Midland plant in general.

This section contains a copy of the Bodner, 2002 study plus DioxinSpin.com comments on the study.

As part of the RCRA operating permit for Dow's hazardous waste facilities at the Midland site, Dow was required to submit a proposed Remedial Investigation Scope of Work (SOW) for Midland Area Soils and for the Tittabawassee River and its Floodplain contaminated with dioxins, furans and other toxic compounds.  Dow submitted the required SOW to the MDEQ on August 11, 2003.

When Dow failed to agree to the changes being requested by the MDEQ, the company was issued a Notice of Deficiency on December 12, 2003.  Failure to respond to the Notice of Deficiency could have resulted in a withdrawal of the operating permits.

On February 17, 2004, Dow submitted a revised Scope of Work and the MDEQ is currently reviewing the SOW.

Upon careful review, I believe that the SOW has several deficiencies.

Midland Area Soils

1.  The number of locations to be sampled is far below the number of sampled locations required for a 95% confidence level that all areas of high dioxin contamination have been found.

2.  The proposed sampling will only determine the dioxin levels in the first 1" to 3" of top soil.  Earlier sampling in Emerson Park indicated that dioxin levels continued to increase with greater depths.  Samples taken 15" below ground had TCDD-TEQ levels that were 4X the levels found in the first 1" of soil.

3.  The Midland neighborhoods that were to be sampled were based on dioxin contamination patterns resulting from the 703/830 Bldg. incinerators.  The proposed sampling plan did not take into account the dioxin patterns resulting from chemical waste incineration in the three on-site powerhouses.

These three deficiencies were summarized in a March 19,2004 letter that was sent to both Dow and the MDEQ.

A full copy of the letter can be read by selecting the link below:

Tittabawassee River Sediments

This portion of the SOW had the following deficiencies:

1.  The number of locations that were sampled is far below the number of sampled locations required for a 95% confidence level that all areas of high dioxin contamination have been found.

2.   A number of floodplain locations had dioxin levels that increased with greater depth.  More sampling at greater depths is needed to better define the extent of dioxin contamination at all levels in the floodplain.

3.   The proposed clay and topsoil barrier may be washed away during springtime flooding.  Penetration of the barrier may not be noticeable and dioxin exposure may occur, as well as dioxin re-distribution.  A clay-plastic liner-clay-topsoil barrier was recommended.

4.   The MDEQ's comments about the need to determine if the release of hazardous pollutants were still occurring were supported.  Information as to the historic operation of the chemical waste ponds and leakage of organic compounds from the ponds into the river was provided.

These deficiencies were detailed in the March 25, 2004 letter that was sent to both the MDEQ and to Dow.

A full copy of the letter can be read by selecting the link below:

Correction: Information was provided on pg 7 that the revetment collection system is turned off when the river flooded over the sheet piling. This information is no longer correct.  Improvements have been made to the collection system and the collection system is no longer allowed to be turned off under any circumstances.

Community Advisory Panel

In 2004, the MDEQ established a Community Advisory Panel as a mechanism to solicit input on various issues in managing the dioxin contamination that exists in the rivers, floodplain and City of Midland. 

Information was provided to Mr. Vince Castellanos, a member of the CAP, on the impact of soil-related dioxins on daily dioxin intake, dioxin body burdens and resulting health risks.

The information contains estimates of Daily Dioxin Intakes for both children and adults that are exposed to varying levels of dioxins found in the Midland Area soils and floodplain soils.  Estimates of Dioxin Body Burdens are provided, as well as, cancer death rates from epidemiology studies that correlated dioxin body burden levels with cancer mortality.

A full copy of the letter sent to Mr. Castellanos with this information can be read by selecting the link below:

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