12/27/12 Letter to Suzanne Wells, US EPA Concerning POPs Exposure Minimization Education on Akwesasne Reserve and in Town of Massena


Suzanne Wells
Superfund Program
US Environmental Protection Agency
Transmitted by electronic mail

Dear Ms. Wells,

The Environmental Protection Agency (EPA) has a broad mandate to
protect the environment and public health.  I believe that this
mandate includes making full use of scientific knowledge to minimize
the harm that will result from contamination of the environment with
man-made chemicals.  Populations, which reside in the vicinity of POPs
contaminated sites, have received respiratory exposures to site
specific contaminants as a result of evaporation from the sites.  Oral
exposures have occurred whenever local fish and wildlife were
consumed.  These exposures have taken place in addition to exposures
received as a result of the presence of POPs in all animal fats
available in the mainstream food supply, including those animal fats
found in meats, dairy products, eggs and fish.  Consumption of
mainstream food supply animal fats is a major source of exposure for
the populations referred to above.  Exposure minimization is key to
minimizing harm.  Accomplishing exposure minimization requires
providing people with warnings of major exposure routes.  Providing
such warnings makes possible exposure avoidance behavioral changes.

I am interested in creating an educational outreach for the
populations at the Akwesasne Reserve and in the Town of Massena that
provides residents with a warning of the
POPs exposure health hazard constituted by contamination of mainstream
food supply animal fat foods, including:  meats, eggs, fish and dairy
products available in
supermarkets.  This education is important due to a history of site
related exposures to POPS.  I have spoken with leaders in both
Akwesasne and the Town of Massena and it is clear that there is little
or no public awareness of this health hazard.  People are aware of the
PCB contamination that exists in St. Lawrence River, Grasse River and
Raquette River fish, but they are completely in the dark regarding
mainstream food supply contamination.  Making mainstream food supply
contamination known to these populations is a key step in minimizing
the POPs exposures received in the St. Lawrence River Valley.  I am
hopeful that widespread awareness of this health hazard will lead to
new consumption patterns that exclude hotdogs, hamburgers, bologna,
butter, lard, and other foods high in animal fats.

I believe that EPA is one of the governmental entities most suited to
providing populations that reside in the vicinity of POPs contaminated
sites with a warning of the POPs exposure health hazard constituted by
mainstream food supply contamination.  I would like to enter into a
dialogue with EPA for the purpose of creating an educational outreach
within the agency designed to provide this warning.

I have provided a copy of my proposal for educational outreach below.
Please review the proposal as a preliminary to entering into the
proposed dialogue.

joyous in Nature,

Donald L. Hassig


Proposal for Minimizing Harm to Human Health Resultant from Persistent
Organic Pollutants Contamination of the Environment:  Focus on


Exposure minimization is a key paradigm of public health protection.
The Akwesasne Reserve located along the St. Lawrence River at the
mouths of the Grasse, Raquette and St. Regis rivers is a place of
above average exposures to persistent organic pollutants (POPs).  This
exposure has resulted from the contamination of the region with PCBs,
which were used and disposed of at the ALCOA West facility, the former
Reynolds Metals facility and the former GM Powertrain facility.  The
region has received additional inputs of POPs as a result of being
located downstream and downwind from the Great Lakes Basin.
Considering the excess exposure that has occurred here, POPs  exposure
minimization is merited.  Two important strategies of exposure
minimization are:  (1) contaminant removal and (2) educational
outreach on exposure minimization, which involves making known the
existence of the POPs exposure health hazard constituted by
contamination of all animal fats, including both fats present in local
wild caught fish and wildlife as well as fats present in the meats,
fish, dairy products and eggs available in the mainstream food supply.

This project proposal is for the establishment of an educational
outreach on the subject of POPs exposure minimization on the Akwesasne
Reserve and in the Town of Massena.  The educational outreach would
implement strategies, including:  (1) door to door visits for the
purpose of distributing literature and speaking directly with
residents; (2) development of a website based upon the website
akwesasnehealth.wordpress.com; (3) presentations to community groups;
and (4) dialogue with the health professionals of the project area.

Contamination of the Global Environment

During the past 100 years the manufacture and use of certain
halogenated hydrocarbons has gradually led to the contamination of the
global environment.  These substances are highly resistant to natural
break-down processes.  They are also soluble in fats.  Because of
these two characteristics, POPs accumulate to the highest levels in
organisms at the top of food chains.  Many species of organisms have
body burdens of POPs.  Consumption of animal fats is the major
exposure route for this group of anthropogenic chemicals.

All peoples of the Earth bear body burdens of POPs, but those who
consume relatively large quantities of animal fats have the greatest
accumulation of POPs in their fat tissues.  First Nations peoples with
diets composed largely of fish and wildlife have received particularly
heavy POPs exposures.

POPs are not evenly distributed throughout the world.  These
substances evaporate at elevated temperatures and condense out of cold
air to redeposit onto the surface of the planet.  The boreal and
arctic ecosystems are reservoirs of POPs.  The sediments of the Great
Lakes are another vast POPs reservoir.  The outdoor air of the Great
Lakes region contains elevated concentrations of POPs.  Those First
Nations peoples living in the Great Lakes region and downwind from the
Great Lakes on the St. Lawrence River receive significant respiratory
POPs exposures in addition to the POPs exposures  resultant from
consumption of fish and wildlife produced in these ecosystems.

Excess Exposures of the People of Akwesasne

The people of Akwesasne, a Mohawk reserve located on the St. Lawrence
River East of Massena, New York, have a long history of consuming fish
from the St. Lawrence River.  Akwesasne is not only downwind from
Great Lakes POPs.  It is downwind also from nearby POPs contaminated
waste disposal sites on the ALCOA West property, the former Reynolds
Metals property and the former GM Powertrain site.  All three
properties contain areas that were classified as Superfund sites.
Major remedial activities have taken place at these sites, but
remediation was conducted many years after disposal activities
contaminated soils and sediments.  Large quantities of PCBs remain on
the former GM Powertrain site.  All sites were sources of PCB releases
to the outdoor atmosphere leading to respiratory exposures for
decades.  Thus the people of Akwesasne have received oral and
respiratory exposures to POPs that are far in excess of the average
exposure of residents of North America.

Damages to Human Health

The scientific research literature of POPs exposure impacts on human
health is vast and rapidly growing.  Scientific knowledge now supports
the conclusion that POPs exposure at current levels of food supply
contamination imposes a significant quantity of disease risk upon the
average consumer of animal based foods.  Damages to health associated
with POPs exposure include:  cancer, type 2 diabetes, cardiovascular
disease, immune system dysfunction, impairment of sexual function,
autoimmune diseases, impairment of cognitive function and obesity.

Akwesasne residents experience high rates of type 2 diabetes,
cardiovascular disease and cancer.  Epidemiological studies have
demonstrated a connection between PCB exposure and elevated incidence
of type 2 diabetes and cardiovascular disease at Akwesasne.  Anecdotal
evidence supports the conclusion that cancer incidence is far above
average in this place where so much exposure to POPs has occurred for
so very many years.

Minimization of Harm to Human Health

A groundbreaking public health policy document titled, “Persistent
Organic Pollutants:  Impact on Child Health” was published in 2010 by
the World Health Organization.  This report recommends that health
arena leaders take action to minimize the exposure that children
receive to POPs.

POPs exposure minimization can be accomplished via a number of
strategies.  The strategies involving action to reduce the presence of
POPs in the environment and food supply include:  banning the
production and use of POPs such as brominated flame retardants,
clean-up of POPs contaminated sites and establishing a prohibition
against the use of animal fats in the feeding of food animals.  POPs
exposure minimization can also be accomplished by implementing
strategies that motivate exposure avoidance behaviors.  Principal
among these strategies is POPs exposure minimization education.  Such
education involves providing the general public with a clearly set
forth warning describing the POPs health hazard and recommending
limited animal fat consumption.

“Persistent Organic Pollutants:  Impact on Child Health”, World Health
Organization, 2010


Restricting consumption of all animal fats is highlighted as a
priority strategy for POPs exposure minimization.  Simona Surdu, PhD
is the report’s major author.  David O. Carpenter, MD, Director of the
SUNY Albany Institute for Health and the Environment is a contributing
author.  The WHO recently designated the Institute for Health and the
Environment as one of its world-wide centers.

“Children are more sensitive than adults to almost all dangerous
substances, and that particularly is true for persistent organic
pollutants (POPs).  Prenatal and early life exposure to POPs results
in reduced cognitive function, suppressed immune system function and
altered development of the reproductive system as well as increased
risk of development of other diseases, such as cancer, later in
life.”-David O. Carpenter, MD

Multiple exposure to POPs and resultant unquantified total damages to
health are addressed in the 2010 WHO policy document.  Use of
precaution is advised in the face of incomplete yet substantial
knowledge of serious damages to health resulting from POPs exposure.
Concerns involving gestational, lactational, childhood and adolescent
exposures are raised.  This is the first time that a governmental
public health entity has provided leadership on the use of scientific
knowledge to minimize the harm that will result from global POPs
contamination.   Focus on action to minimize exposure makes this a
highly important public health protection document.

The National Center for Environmental Health and the Agency for Toxic
Substances and Disease Registry of the Centers for Disease Control and
Prevention have begun a process for developing educational pieces on
the subject of POPs exposure minimization.  Early documents in this
vein include a piece intended for education of physicians on the
subject of PCB exposure health effects and another physician education
piece on the subject of dioxin exposure health effects.  These
documents would be utilized in educational outreach to physicians
practicing within the project area.


During the course of the past 100 years the global environment has
become heavily polluted with a large number of man-made chemicals,
many of which persist in the environment and accumulate to the highest
levels at the top of food chains.  POPs are a major part of global
contamination.  Human beings are heavily impacted by POPs exposures:
cancers, type 2 diabetes, heart disease, obesity, ADHD, reduced
cognitive function, impaired immune system function  and altered
reproductive function.  The time is upon us for cooperative efforts by
governmental public health entities and non-government environmental
health organizations to conduct educational outreach programs focusing
on POPs exposure minimization.  Such educational outreach is a crucial
part of the overall effort to minimize the harm that will result from
POPs contamination of our world.

Donald L. Hassig, Director
Cancer Action NY
Cancer Action News Network
P O Box 340
Colton, NY USA 13625


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