For example, regarding sanitary and phyto-sanitary SPS measures, both sides have simplified approval and clearance procedures.
In the EU this specially helps the value-added agri-food sector while in Japan the manufacturing and services sectors benefit. The adoption by Japan of around European Protected Geographical Indications has been a major step forward. In the first place, they include a clause safeguarding the compliance with the Paris Agreement on Climate , creating a precedent that aspires to set a standard for future trade agreements.
Secondly, they attach great importance to data protection. In fact, the matter of safe data flows is considered the Data Movement Agreement or a third major agreement in its own right. Abe has taken the lead on world-wide data governance by putting on the agenda of the G20 summit in Osaka the commitment to work towards a regime built on Data Free Flow with Trust DFFT principle aiming at what he calls the Society 5.
The effect of their adoption could be called a positive upheaval where the exposure to liberalised trade is used as an opportunity to revamp primary and secondary sectors as well as to modernise the tertiary one by adapting to the new challenges. Akeda noted the difference between the Japanese approach at the negotiating table, more business-oriented and flexible compared with the more people-oriented and normative European style. Japan clearly pursues the improvement of economic efficiency through FTAs and one aspect that took longer in the negotiations were the European prescriptions such as those on adopting more international industrial standards ISO.
This lack of international standardisation has been one of the NTBs that protected Japanese Small and Medium Enterprises SME that cater to a captive domestic market without the need to internationalise. In fact, SME productivity has been long under scrutiny. To force them to open up to the global market and embrace opportunities brought by the digital economy is part of the strategy of the third arrow. SMEs are predominantly responsible for agriculture, textile, apparel and leather products in the goods trade, and for information, communication, real-estate activities, construction, wholesale and retail in the services trade.
Energy, auto, computer and electronics manufacturing as well as financial and insurance services rely on bigger corporations. Employees holding positions that are subject to the State Personnel Act. The State Personnel Manual governs the policies and procedures applicable to these positions.
In rare cases, e. The University of North Carolina at Greensboro. Submit Search. Toggle navigation Toggle search iSpartan Email. In addition, in order, to answer this question one would have to assume that the data generated in the control areas are representative of the conditions in the general Niagara Falls area.
At this point we certainly don't know that to be a fact. Heath August 21, Page 9 Love Canal area. That element is the data generated on the adverse health effects that have already resulted from living at Love Canal. It is the conclusion of both the State of New York and Dr. Beverly Paigen that an increased incidence of adverse birth outcomes resulted from residing in the Love Canal community.
In addition, Dr. Paigen1s work also suggests that other forms of health impairment i. The available health effects data has been criticized for various scientific inadequacies. The environmental data we have been asked to review is, in my judgment, flawed in a variety of respects as well.
Consequently, the best judgment that can be made about the risk to human health from residing in Love Canal would be a judgment based on both the evidence we have from environmental monitoring and from health effects testing. Even if we were able to accurately predict the adverse health consequence of exposure to all the chemicals in the various environmental media, we would be hard pressed to determine whether the reported level of chemical contamination is accurate or is predictive of future conditions.
With regard to the current situation, it is unclear from the data presentation what margin of error exists for the reported levels of chemical contamination. Further analyses would have to be provided in order for anyone to feel confident in judging the true magnitude of current contamination reported within the declaration area. Concerning future patterns of contamination, it is my belief that, based on the data before us, we are unable to predict with any accuracy what the future will be.
Disruption of the clay cap as noted above might lead to far greater contamination of the-declaration area. Suggestions voiced at the workshop that the area designated by EPA as Area 11 might become a park or a public playground indicate that the integrity of the clay cap in that area might be at far greater risk than merely from erosion, subsidance and lack of maintenance.
Any activity that would have people 'using the canal site as a playground or park would most surely jeopardize the integrity of the clay cap. Moreover, even Dr. Deegan noted that for certain environmental media, contamination within the declaration area far exceeded that in the control area.
Most notably Dr. Deegan spoke about the contamination of sewer lines and sediments. While Dr. Deegan alluded to the fact that EPA had just announced plans for the cleanup of the sewer lines and sediments, it should be remembered that this announcement of cleanup is not new.
Under the pevious Administration, the Regional Administrator for Region II announced a program that was also going to clean up the sewer lines. Heath August 21, Page 10 program was not undertaken. Consequently, one should not assume that the promise of cleanup programs means that cleanup will occur. Finally, on this same point it should be noted that while Dr.
Deegan stated that the barrier drain system was operating as designed and "the material was moving back faster than it had ever moved out," there is no documentation for such a statement in the materials presented to us.
This is a significant point because previous reports about the functioning of the barrier drain system were less optimistic about its working success. The third question posed was "Were sufficient samples taken and analyzed to determine the extent of contamination"by particularly hazardous materials and to be able to assess the potential threat to human health? In my judgment, insufficient discussion took place about this question.
Differences of opinion were voiced as to the potential threat posed by dioxin exposure, but the direct intent of the question i. I agree with those who expressed concern over the high levels of dioxin in soil samples taken in the Love Canal declaration area. As one participant noted, it certainly is difficult to explain to the' public that parts per billion levels in soil are an insignificant risk when the Commissioner of Health of the State of New York has warned people against eating fish contaminated with parts per trillion of the same chemical.
Obviously, the exposure that may result from eating fish contaminated with dioxin as opposed to living in an area with dioxin-contaminated soil is not the same.
However, it should be remembered that young children, for example, often play in soil and very young children may in fact ingest soil. The last question posed to the consultants was "Based on available data, can you conclude that the area is not habitable? Heath August 21, Page 11 question in the negative.
The conclusion that most likely would be drawn fcom that response is that the respondant believes that the declaration area should be rehabitated. I certainly do not believe that the evidence we were asked to consider allows one to conclude that the Love Canal declaration area is a safe place to live.
I strongly believe that CDC and the Department of Health and Human Services would be making a grave error if they concluded from a review of this data that the Love Canal declaration area was safe to live in, and that individuals should be encouraged to relocate there.
At best, our judgment must be that the data base presented to us, taken alone, is insufficient to reach a conclusion on habitability that would be scientifically supportable.
If forced to offer a more definitive opinion, then one would have to say that no one should be encouraged to relocate in the Love Canal area based on what we know today. I recognize that a number of families in the declaration area have chosen to stay rather than to move out.
That is clearly their choice to make. I believe we have a responsibility as scientists to -- as best as we can -- explain the significance of the data that have' been gathered, and to be honest and straightforward about the numerous uncertainties that exist. If these individuals continue to choose to stay, that is their right. Providing such advice is clearly different from actively supporting a conclusion that the declaration area should be reinhabited. I hope- these comments will be useful to CDC in making a recommendation to SPA regarding the meaning of the environmental assessment data.
At the workshop you stated that the final report that will be prepared by the Department of Health and Human Services for EPA will have our letters to you attached as appendicies.
I believe it is essential that our comments be included because I want to be sure that the views of all consultants are clearly and accurately presented.
As I indicated at the meeting, I would be happy to participate in another meeting if that would be useful to CDC. Again, thank you for the opportunity to participate in the workshop and to serve as an expert consultant to CDC on this matter.
Heath, jr. This is the report requested from my service as a consultant to Center for Diseases Control following the meeting on- the above subject held in Atlanta, Georgia on August I hope that the submission of this report satisfactorily completes my consultant assignment.
Sincerely, Robert L. Many of the pollutants monitored including heavy metals, polynuclear aromatics, halogenated aliphatics, acrolein, acrylonitrile, benzene, toluene, xylenes, and polychorinated biphenyls; represent the broad range of chemical pollutants typically found in the urban industrial environment.
Without in any way minimizing the undesirability of their presence in the air and water consumed by humans, it is concluded that these "typical" pollutants are not adequate indicators of the possible hazards of Love Canal dumping on the habitability of adjacent residential areas.
According to data furnished by the' company to the New York State Health Department, at least 21, tons of such wastes were duaped into Love Canal during this period. Hooker Chemical Company pioneered during and immediately after World War II in the production of a large variety of chlorinated aromat-ic compounds including 2,4,5-trichlorophenol and chlorobenzenes; benzotrichloride and other chlorinated toluenes; photo-chlorination of benzene to produce lindane and other isomers of hexachlorocyclohexane; and the highly reactive hexachlorocyclopentadiane for Diels-Alder diene syntheses of the insecticides aldrin, chlordane, heptachlor, endosulfan, and mirex.
The toxic chemicals selected as suitable indicators for this evalua- tion are shown in Table 1 together with available data on TLV values for human industrial exposures to contaminated air and ADI values for contamina- ted drinking water.
In the subsequent Tables , the available analyses for the maximum detected concentrations of these indicatorNchesical pollutautsin various environmental situations, i. These have been transported by leaching in large amounts through the storm sewer system with the worst pollution being found in Area 4 to the North.
However, the large ppm quantities of the several pollutants found throughout the- adjacent areas suggests a rather massive movement of the sub-surface soils throughout the entire storm sewer system.
We understand that EPA will undertake to clean up the storm sewer contamination and that capping of the Love Canal area and the provision of a leachate treatment facility should substantially decrease the movement of the toxic pollutants through the storm sewer system. The data for soil contamination Table 3 shows evidence of migration of dichlorobenzene to Area 2. Further analytical data for other hazardous pollutaifcs in the "declaration zone" would appear desirable.
Water; The sump water Table 4 and shallow well data Table 5 if representative and reliable appear to indicate substantial ground water pollution only in the Love Canal Area This is essentially what would be expected because of the relatively deep burial ca 30 feet of the 21, tons of pollutants.
The deep well data is essentially negative for the key chemical pollutants in all sites. Rather large amounts of dichloro-and trichlorobenzenes and 7«-hexachlorocyclohexane in storm sewer water of Area 2 and lesser amounts in Areas 4 and 8 also demonstrate the spread of the pollutants from Love Canal into the "declaration area" through water.
Thus additional and regular monitoring of storm and sanitary sewer water for che presence of the key pollutants is highly desirable. Air; The air sampling data from Living Areas Table 7 is difficult to interpret because of the small number of key pollutants monitored. The data are almost entirely restricted to dichlorobenzenesandchlorotaluenes that are among the most volatile of the key pollutants.
The presence of these in Living Areas, hoxrever, is greater at maximum values in the "declaration areas" 2, 3, 4, 6, 8; than recorded in Area These maximum values especially for dichlorobenzenes are 4. These substantially increased values must be significant and air monitoring in Living Areas for other volatile key pollutants especially hexachlorocyclopentadiene and hexachlorobutadiane should be made to confirm air movement.
Migration of these substances will undoubtedly be decreased by the remedial construction undertaken but cannot be discounted as a long tana source of contamination of the "declaration area" by highly toxic and relatively non-volatible pollutants. Q-2 Do the levels measured represent concentrations that could cause acute or chronic adverse health effects in people living in the Love Canal beyond what might be expected under usual residential conditions in the Niagara Falls area?
A'-2 It is impossible to answer this question in the-negative. The presence of at least 21, tons of hazardous pollutants in the Love Canal and the evidence summarized in A-l that detectable amounts of these are to be found in the adjacent Areas 2, 3, 4, 6, 8 suggests that people living in these areas will be exposed to trace chemical insults from a variety of highly toxic chemical pollutants for generations. All-of these chemicals are suspect carcinogens.
The epidemio- logical studies of birth defects, abortions, and chromosomal aberra- tions made in the Love Canal and adjacent areas, while subject to disputations, are significantly disturbing to demand a strongly conservative attitude about promoting the exposure of thousands of persons, especially young children to these trace chemical pollutants over a lifetime.
Comparisons of environmental health standards for air quality i. ADI values; with maximum air pollution levels and water contaminations recorded for the Love Canal area, are somewhat reassuring. The maximum detected levels for most of the key pollutants for which the data are available are very substantially less than accepted standards.
The use of 8-hour TLV's for air pollutants for evaluation of the hour lifetime exposures that are found in the declaration areas is also very misleading.
For lifetime exposures the spectrum of sensitivity of the exposed population including the very young and the aged is much wider than that of an occupationally exposed population.
All of chese condi- tions suggest the need for a safety factor of at least for the very hazardous chemicals concerned, that should be superimposed upon any considerations of TLV values. Q-3 Were sufficient samples taken and analyzed to determine the extent of contamination by particularly hazardous material as to be able to assess their potential threat to human health?
A-3 Although a large number of samples were taken and analyzed and the values obtained seem to be reliable within the present state of the art, sampling and analysis wera not rigorous enough to describe adequately the human health threat from the highly toxic key pollutants of Love Canal.
More effort should be expended on routine and regular sampling for the other key pollutants such as lindane, hexachlorobenzene, pentachlorophenol, pentachloronitrobenzene and the more volatiledi-,tri-, tetra-chlorobeazenes and phenols, and chlorinated toluenes.
Q-4 Based on available data, can you conclude that the area is not habitable? A-4 In the writer's opinion the immediate Love Canal Area 11 should be completely barred to human access. Suggestions that it become a "park area" are irresponsible. It is much more difficult to assess the habitability of the "declaration areas" especially Areas 2, 3, 4, 6, 8 adjacent to Love Canal.
Additional monitoring data is important to determine the effects of the remedial capping and barrier construction instituted in the Love Canal and to fill the voids in the analysis of key pollutants as indicated above. The writer does not believe that it would be responsible to advise inhabitants that the area is totally safe. Certainly he would not want to expose himself, his family or his friends to these hazards of chemical pollution through lifetime residence there.
There is in addition a measurable hazard in lifetime exposre to the polluted atmosphere of the city of Niagara Falls itself. J ppb 0. Suspect carcinogen. Narang, A. Richards, K. Aldous, P. O'Keefe, R. Smith, D.
Hilker, 1. Bash, J. Stack, D. August 17, -2 area cannot be rehabilitated. With the exception of the dozen or so obviously contaminated houses, I'd go as far as having no objection to the other houses in the area being reoccupied. When the summarized EPA sampling data are available, I'd like to see them. Thanks for giving me the opportunity to offer advice. Sincerely, Samuel Milham, Jr. MKS ii. KOX E PAKX,. August 18, Clark W.
Heath: Given the heterogeneity of the group who reviewed the EPA monitoring data, it is clear that there will not be a consensus concerning what these data mean relative to a health risk to the residents of the Love Canal area. I think it is quite clear that the analytical data was generated in as scientifi- cally a rigorous manner as is possible.
All of the analytical chemists present at the meeting were of that- opinion, including Stephen Kim of the New York State Department of Health. The validity of these analytical data is also suggested by their general concordance with the data generated earlier by the New York Department of Health. Some of the panel members had difficulty evaluating the EPA analytical data in the form in which they were presented.
I had less difficulty in that regard, primarily because I had spent considerable time comparing the data from the various sampling regions of the declaration area with the control data. It is my opinion that, with the exception of the canal area itself including some ring one houses , the analytical data do not indicate that residents of the declaration area are exposed to levels of chemicals by way of air, water or soil which are, in a practical sense, different than exposure, by those same routes, of people living in the control areas.
It is also highly unlikely since they are,, in general, much lower than allowable concentrations in the industrial work environment, that persons in the control areas are experiencing any significant health risk from exposure to the levels of various chemicals detected in the EPA monitoring.
It can be argued that persons in the declaration area are exposed to toxic chemicals, as a result of their presence in the Love Canal, which were not monitored for fay the New York Department of Health-or EPA. However, I do not believe that argument has any merit in a practical sense. The EPA monitoring examined for compounds of known and unknown toxicity which they knew had been disposed of in the Love Canal. Unquestionably, there are compounds in the Love Canal which were not examined for in the EPA monitoring and for which there is no toxicology data base.
However, unless these compounds posses considerable volatility, the persons in the declaration area are not likely to be exposed to them. In addition, the human health monitoring or the animal studies which have been done on site have not yet produced any evidence of adverse health effects or the potential for adverse health effects in residents of the declaration area. I repeat that it can, and has been, argued that persons living in the declaration area may be exposed to chemicals which have not yet been identified in the monitoring program.
It is further argued that these chemicals may have an adverse health effect. My answer to this is that there comes a time when we must stop delaying decisions relative to the health risks to persons in the declaration area based on unknown and improbable eventualities. I believe the time for decision making in this regard has come. Based on the analytical data, the results of human health monitoring and on-site animal studies it is my opinion that no practical health risk exists for persons living in the declaration area excluding the immediate area of the canal and ring one houses.
The finding of low birth weight children in the "wet" vs. I do not find these data at all convincing. First of all, the numbers are small. Secondly, there is no evidence that there was movement of chemicals from the canal into these areas.
Finally, the fact that the incidence of low birth weight babies of families living in ring one and ring two houses was not significantly different from control incidences suggest the effect seen in the "wet" area is either a spurious result or unrelated to living in close proximity to Love Canal.
With those general comments as a background, let me direct some remarks to the specific questions you posed in your letter of August 6. Question 1 As I indicated above, the raw data from the EPA analytical monitoring does not suggest that the compounds which were monitored for were in higher concentrations in the declaration as compared to the control areas of Niagara Falls excluding some ring one houses and the immediate area of the cana1.
Question 2 Again, as noted above, the analytical data currently available do not indicate that persons living in the declaration area are exposed qualitatively or quantitatively to chemicals which are, in a practical sense, different from the exposure of people living in control areas of Niagara Falls. Question 3 In my opinion, sufficient sampling for known substances of high toxicity have been performed. Page Three August 18, of sufficient amounts of these substances in areas outside of some ring one houses and the immediate canal area, which pose a health risk to people living in these areas.
In my opinion, people living outside of the ring one houses are not exposed to levels of the chemicals present in the Love Canal which pose any significant health risk. Further, the lack of significant migration of chemicals from the canal excluding some ring one houses and storm sewers adjacent to the canal in the 30 plus years of the presence of significant amounts of chemicals in the canal does not suggest the possibility of future exposure of persons living in the declaration area from chemicals present in the immediate area of the canal.
The fact that additional safeguards against migration of chemicals from the canal by various routes, including storm sewers, have been put in place, adds additional assurance that significant migration is highly unlikely in the future. Sincerely, Robert A. Neal President RAN.
Beverly Paigsn Summary The consultanCs to CDC were asked to evaluate a subset of the data obtained by EPA's environmental chemical testing program and to answer the following quas tions: 1. Are the concentrations of chemicals significantly higher than other areas of Niagara Falls? Could these concentrations cause adverse health effects?
Were enough samples taken of very toxic chemicals such as dioxin to be able to assess its health threat? Is the area habitable? The data had several problems in the presentation of material and in the adequacy of measurements.
Putting these aside, I believe it was possible to judge that organic chemicals were higher in Love Canal study area the entire Love Canal neighborhood excluding Rings 1 and 2 than in other areas of.
Niagara Falls. Organic chemicals were higher in storm sewers, in scream sediments, in sumps, in soil, and in home air. The data are not adequate to permit an answer to questions 2 and 4 regarding health and habitability for reasons discussed below. In answer to question 3, there were insufficient samples taken to adequately evaluate whether dioxin levels constitute a health threat in the study area even though the small number of samples had surprisingly high levels of dioxin.
Finally, additional analyses of data would be helpful in determining the extent of contamination at Love Canal and these are listed. Adequacy of data A. Problems for the consultants in reviewing data The data were difficult to evaluate because of the siassive amount of data, the short time to review, the lack of statistical treatment, the inability to read some tables and maps, and the lack of sufficient summary tables and paragraphs.
Although I can appreciate the difficulties in assembling and reproducing such large amounts of data, I am not comfortable as a scientist in answering questions concerning public health based on data I cannot read pp , , data with obvious errors maps on pp show stream sediment samples taken where there is no stream , unexplained symbols on maps and tables, and little aggregation of data or statistical analysis i.
There was r. The EPA program was designed Co test for preferential migration p 8 , yet there was no data analysis concerning that hypothesis. The separation into areas had some rationale, but there is no discussion of this nor analysis by area.
The picture was further confused when Mr. Deegan of EPA, at the August 13 meeting of consultants, stated that, in his opinion, the data demonstrated no evidence of chemical contamination beyond Ring 1 except for storm sewers and stream sediments.
When a consultant asked Mr. Deegan about the soil data on p 41, Deegan replied that table was "no longer operative. Deegan claimed that the differences were "not statistically significant. Problems with using the data base to answer questions concerning health and habitability The original plan was to couple the environmental testing programs with a health study. Had that plan been carried out, the two studies taken together could have been used to answer questions of health and habitability.
As it stands, the current data base is not appropriate to answer such questions for the following reasons: 1. Love Canal has over chemicals present and only a'subset were measured. Little or nothing is known about the toxicology of a large percentage of the chemicals present because they are waste products or process intermediates for a fuller discussion see Rail et al.
Little is known about the synergism or antagonism that might exist in such a complex mixture of chemicals. Even for those chemicals that were measured and for which toxicological data exist, most studies are based on workers or experimental animals.
Almost nothing is known concerning the concentrations of chemicals that would be safe for the jhuaar. First, if the levels of one particular chemical were high enough, one could state it was unsafe. Second, if one particular area showed no evidence of chemical contamination, then one could tentatively conclude the area was safe if the sampling was adequate and if the subset of chemicals measured are an adequate reflection of the whole set.
The results of the quality control program are described on pp and following. Several points were made by EPA. The "meaning of trace is obscured by the variance in minimal detection limits among laboratories" p Trace from one lab could be 30 times -higher than trace from another lab i.
Some laboratories performed much better than others ranging from 33 percent. These two facts lad to a cautionary statement that "users or Love Canal data should be aware of differences in detection limits The magnitude of the testing program "literally over-whelmed the national capacity for low level chemical analysis" p Thus many samples were held too long and this fact becomes important for volatiles and semivolatiles. For water many samples arrived with poorly fitted or leaking Teflon cap liners p Water samples were held too long.
Soil samples were held too long and the effect of holding was stated not to be a problem between weeks but "losses in the first few weeks are indeterminable at this time" p For air holding time was not given in the summary data. Deegan referred the consultants to the full data base in Atlanta, but we could not find holding time there either.
Holding time for volatiles in air is quite critical. Some chemical measurements were not to be trusted, i.
Reproducibility and. I 2 would like to see a more conventional analysis of reproducibility. Tentative conclusions based on the data The data base is not adequate to answer questions of health and habitability but there are several questions that can be answered or could havebeen answered by an environmental monitoring program.
The conclusions are only tentative given the problems with presentation of material and quality of data base discussed under I above. Is the Love Canal area contaminated? Only the drinking water appears to be the same as the rest of Niagara Falls and that is based on very limited data. EPA did not give any statistical analysis of the data so I examined the data for organic chemicals and simply asked whether each organic chemical was more frequently found in Love 'Canal samples than in control samples.
I then used a simple statistical test, the sign test which has relatively low power, to ask the probability that, for example, out of 13 separate tests, Love Canal was higher than control 13 out of 13 times. This is not a sophisticated analysis; it would be possible to use other tests that involve a combination of probabilities such as Fischer or Wallis. In addition, a strong argument could be made for combining the chemicals into groups such-as all trichlorophenols or all BHC or all organics.
For storm sewer sediments, there were 21 Love Canal area samples and 1 control and 14 organic chemicals gave positive readings. For storm sewer water, there were 9 Love Canal samples and 1 control and 13 organic chemicals were detected? In the sanitary sewers, only 1 Love Canal water sample was taken no control samples. Twelve organic chemicals were " found at levels comparable to or higher than storm sewer water p The stream sediments in Love Canal were contaminated but the stream water did not show evidence of contamination.
There were 4 Love Canal samples and 5 control samples. For the sediments, 12 out of 12 chemicals were higher in Love Canal; in the stream water only 2 organic chemicals were detected toluene and heptochior and Love Canal was lower than control. In Che soils, chere were Love Canal samples and 8 concrol samples p All 12 concrol samples were 0. In drinking wacer, Chere were 31 Love Canal samples and 5 concrol samples.
A CoCal of 7 organic chemicals were detecced; Love Canal samples were higher in 3 and concrol samples were higher in 4. Thus chere was no apparenc difference in Love Canal and concrol, a result chac is noc surprising since Che same municipal wacer is supplied Co boch areas. The daCa given for shallow aquifer wells and deep aquifer wells was noC sufficienc Co perraic an evaluacion. There were over Love Canal samples of outdoor air p 72 and over 80 Love Canal samples of basemenC air p For living area air, Chere were over Love Canal samples and 30 conCrols p AfCer eliminacing benzene and Coluene based on information in Che qualicy conCrol seccion; 11 ouc of 12 organic chemicals were higher in Love Canal homes Chan in conCrol homes.
The exception is? In conclusion, che daca show chac Love Canal is clearly higher in organic chemical conCaminaCion Chan che conCrol area in sconn sewer, sCream sediments, sumps, soils, and living area air. No determination could be made for sanicary sewers, basexant air, or oucside air since no concrol data exist.
Drinking waster was che same for boch Love Canal and control and indeed coines from Che same municipal source. Surface water, surprisingly, did not show any evidence of contamination although the sediments did. Perhaps this is because organic chamicals would Cend co scay in sediments or be released inCo air, buC would noC be dissolved in waCer.
How far has Che conCaminaCion occurred? UnforCunaCely, no analysis by area was given. The areas of parcicular concern are 5 and 1 which are che excreme edges of the neighborhood and where the greatest percentage of current residents are located.
Both areas 1 and 5 have a few houses on swales or streams and these appear to be giving quantifiable levels of chemicals. I would like Co see an analysis with and without those houses. Sy what routes did contamination occur? No analyses were presented that would permit such a determination, but it may be possible. Several homes in the area have flooding in the yard from storm sewers.
Are the soils, air, or sumps higher in such homes? Is there any correlation between positive readings in soil and air or sumps in the home?
D- Has remedial work resulted in a reduction in contamination? Deegan stated that back flushing of chemicals from the soil was occurring to a greater extent than expected. This is an important finding and I would like to see the data. I would also like to see a comparison of homes done by both New York State and Love'Canal to compare soil, air, and sumps. Is there correspondence between the geochemical evidence of contamination and the adverse health effects?
The adverse reproductive outcomes found by New York State should be compared to the geochemical data. Questions posed by CDC - -. A- Are the concentrations of chemicals, significantly higher than in other areas of Niagara Falls? As discussed above, the answer is yes.
Due to the limitations of the data base discussed above, I do not believe this question can be answered. Only 4 soil samples in the study area were tested for dioxin and all 4 were negative. This is an insufficient number of samples. Eleven storm sewer sediment samples were taken and all had dioxin levels.
As discussed above, I do not believe this particular data base permits an answer to that question. Any of these situations could lead to periodic exposures much higher than those detected by the EPA monitoring programs.
Further Analyses The following information would be useful in a further evaluation of the data base. Holding time for air. Evaluation by area. All positive readings for organic chemicals on a map by media and with various media combined. List of organic chemicals not likely to be found in consumer products.
Map of control sites and other dumps in Niagara Falls. Statistical evaluation of data. Readable tables of data for air. Correlation of chemical data with adverse reproductive outcomes.
Readable figures for daily variation in air readings. Final questions The most striking thing about the EPA monitoring program was the high percentage of negative findings and the low levels of chemicals found compared to New York data. Tne question that comes to me is whether exposure at Love Canal is periodic in nature and whether the health impact may occur by transitory exposure to higher levels than those found by EPA.
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