United States
Environmental Protection
Office of Public Awareness
Washington DC 20460
     t f
     V /


  In this issue EPA Journal
   examines the myriad ways
in which chemicals affect our
lives and describes how the in-
dustry has become a major
force in the economy.
  Administrator Douglas M.
Costle discusses the "chemical
revolution" of the past three
decades and explains EPA's
current activities in regulating
some aspects of the industry.
Two of the  major laws EPA has
for dealing with toxic chemicals
are the Toxic Substances Con-
trol Act and the Federal In-
secticide, Fungicide and
Rodonticide Act.
  In an interview, Steven
Jeilinek, EPA Assistant Ad-
ministrator for Toxic Sub-
stances, analyzes the Toxic
Substances Act  and describes
how it is helping government
gather information on chem-
icals while safeguarding indus-
try trade secrets.
  The magazine also has an
article in which Jeilinek reviews
the significance of proposed
new amendments to the Fed-
eral  Insecticide, Fungicide and
Rodenticide Act.
  Dr. David P. Rail, Director
of the National Institute of
Environmental Health Sciences,
in another interview details the
mission of his agency and how
its research complements the
work of others in dealing  with
health-related questions in-
volving chemicals. A report by
tne Conservation Foundation
describes the need for more
toxicologists and the career
opportunities for men and
women in this exciting and
expanding field.
   Other articles deal with at-
sea incineration of toxic sub-
stances; the aftermath of an
explosion in Seveso, Italy, and
other incidents involving toxics,
the effort to curb chemicals in
drinking water, and plans for a
major conference on urban
environmental problems. D

                             United States
                             Environmental Protection
                             Office of
                             Public Awareness (A-107)
                             Washington, D.C. 20460
                         &EPA JOURNAL
                              Volume 4
                              Number 8
                              September 1978
                             Douglas M. Costle, Administrator
                             Joan Martin Nicholson, Director, Office of Public Awareness
                             Charles D. Pierce, Editor
                             Truman Temple, Associate Editor
                             John Heritage, Chris Perham, Assistant Editors
                             L'Tanya White, Staff Support
EPA's Purpose: To formulate
and implement actions which
lead to a compatible balance
between human activities and
the ability of natural systems to
support and nurture life
Dealing with the
Chemical Revolution
An analysis by Douglas M.
Costle of the benefits and dan-
gers of the boom in chemicals.

Toxic Substances
An interview with Steven
Jellinek, Assistant Administrator
for Toxic Substances.

Major American
Toxics Disasters   8
A review by John Heritage of
damages in this country caused
by some dangerous chemicals

An Environmental
The Seveso Case
An account by Marion Parks of
the aftermath of an explosion in
a chemical factory in Italy.

Seagoing Furnace
Destroys Toxics  16
Burning at sea is one approach
being used to get rid of harmful


Nation 30
The Challenges
in Environmental
Health   18
An interview with Dr. David P.
Rail, Director, National Institute
of Environmental Health

A report on the need for scien-
tists trained in dealing with
toxic substance problems.

Sharing Environmental
with Japan
An article by Kirk Maconaughey
on a meeting of U.S. and
Japanese officials scheduled
for this month.

Curbing Chemicals in
Drinking Water 26
An explanation by Victor J.
Kimm of why EPA wants stricter
drinking water regulations.
                                                          News Briefs  38
Ocean Dumping
off New York
A report by Peter W. Anderson
on the disposal of municipal
sludge and toxic and other in-
dustrial wastes in Region 2.

Urban Conference
EPA and two other Federal agen-
cies and three private groups
will hold a conference on urban
life in Washington next April.

Congress Expedites
Pesticide Program
New amendments to the Federal
Pesticide Law are expected to
improve registration procedures.

Response Team
A report on EPA's new group
set up to cope with environ-
mental emergencies that require
special clean-up skills

Region 8 Report 40
                             Front cover: EPA inspector in
                             protective face mask checking
                             pesticide received at Port of
                             Newark, N. J.
                             Inside cover:  Children of Seveso
                             show effects  of dioxin exposure.
                             Head of child at rear is covered
                             with a stocking while being
                             treated for chloracne, a skin  ail-
                             ment that is a reaction to the
                             toxic chemical. See P. 11
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                             the Office of Management and
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                             Photo credits: Dan McCoy*, Boyd
                             Norton", Hope Alexander", Bill
                             Strode", Marion Parks,
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                             Mason Co.Inc., Stern/Black Star,
                             Wisconsin Department of
                             Natural Resources

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Environmentally Speaking
       Dealing with
      the Chemical
         By Douglas M. Costle,
  U.S. Environmental Protection
     We've undergone in 30 years a chemical revolution in
     this country. In a sense, our society has become a
chemical addict. The U.S. chemical industry has sales of
over $112 billion a year.
  Practically everything we touch during a day has in turn
been touched by man-made chemicals.
  The chemicals we use have brought us tremendous
benefits, but some of them pose serious problems as well.
One of our difficulties in trying to deal with hazardous
chemicals, however, is that we don't know as much as we'd
like to know about their impact on health.
  Anybody knows that carbon tetrachloride is dangerous
when people are exposed to relatively large doses. But it's
much less clear what happens when they're exposed to
small amounts over a long period of time. PCB's are among
a number of substances that we have learned are harmful—
and learning that only after long years of use. DDT is an-
other one, and so is asbestos, and so is vinyl chloride.
  The point I want to make doesn't have to do with the fact
that we've now identified several dangerous pollutants.

 It has to do with the virtual certainty that we're going to face
 more grim surprises in the years ahead.
   EPA is now in the process of making an inventory of all
 the chemicals produced in commercial volume in this
 country, or imported for use here. When we started on this
 project last year we were estimating there would be 30,000
 chemicals on that list. We're now betting the figure will be
 closer to 70,000. And we know there are another three to
 four million chemicals in various stages of research and
 development, although only a small fraction of these are
 likely ever to get into commerce.
   I'm confident that the vast majority of these chemicals
 will be shown to be harmless, when used properly. But with
 so many chemicals involved, the odds are strong that some
 whose effects aren't yet known will turn out to be
   PCB's symbolize the complex nature of the pollution
 problem. Once chemicals like these are in the environment,
 they can be incredibly difficult to get out.
   Proposals have been made, for example, to dredge PCB's
 out of river beds, but this would involve many problems.
   The expense is one major obstacle. New York State
 thought about dredging 40 miles of Hudson River bed, but
 hjgs estimated that a  full-scale effort could cost as much as
 $200 million.
   Even if that kind of money could be found, there would
 still be other tough questions to be  dealt with. For one
 thing, something would have to be  done with the huge
 amounts of riverbed spoil. Not many mayors would leap at
 the chance to bring vast quantities of contaminated spoil
 into their towns or cities.
   Assuming the disposal  problem can be resolved, there's
 still the question of environmental damage to the river bed.
 For numerous waterways, this could be an especially seri-
 ous concern. So we're going to have to deal with the after-
 effects of such contamination as best we can.
   Our current problems with these toxic chemicals are part
 of a phase we're going through on the way to a totally new
 kind of approach.
   It's a catch-up phase, and like any such phase it's painful.
 We're dealing with problems that have developed over dec-
 ades. That means we've been forced to come up with after-
 the-fact solutions that are sometimes very complicated,
 sometimes very costly, and sometimes not as effective as
 we would like.
   As a Nation, we are beginning to recognize the short-
 comings of after-the-fact action. Congress recognized this
 when it passed the Toxic Substances Control Act, or TSCA,
 in 1976.
   With TSCA, we're no longer going to have to wait until
 the chemicals are in the water, or in the air, or in the
 ground, before we try to control them. For new chemicals,
 we're going to be able to get testing done before commerical
 manufacturing starts, and decide at that stage whether
 controls are necessary.
   Unfortunately, this is not going to be a quick or painless
process. A great many tough decisions are going to have to
be made.
   In the case of PCB's, some of the tough decisions have
already been made. EPA has proposed that they no longer be
manufactured, processed, sold or used except as part of a
totally enclosed system. That means the discharge of this
substance into the environment is eventually going to be
cut to virtually nothing.
   As for many other chemicals to be regulated, we're going
to have to act on many of them with less than complete,
decisive scientific information. And we know that we're
sometimes going to face heavy pressure to go slow.
   I don't intend to foot-drag if there is evidence that a
chemical poses a clear threat to the health of the American
people. I have always believed that public health is far too
serious  a concern to take chances with. I think we should be
rational and reasonable, but we must also be firm and
think ahead.
   There's no way we can calculate the cost of future harm
represented by the pollution that's now in the environment.
But we know it's potentially enormous. PCB's again provide
an example. All manufacturing of PCB's has stopped.
Nevertheless, we estimate that there are about 750 million
pounds  still in use; another 300 million pounds in landfills
and dumps (most of it uncontrolled); and 150 million
pounds  simply loose in the environment.
   There is no doubt at all that more PCB's will be turning
up in the environment, and they have a half-life of more
than 100 years.
   We don't know yet what the effects will be in people
exposed over most of their lives to some toxic chemicals.
   The short-term effects of some of these chemicals are
well known. We know that exposure to the pesticide DBCP
injures human reproductive systems, and we know that
Kepone causes nerve damage. It is less clear exactly what
the chronic effects of these and other chemicals are. What
is clear, however, is that some do cause chronic diseases,
such as  cancer.
   I mentioned at the outset that we've launched a chemical
revolution in this country. In truth we don't know yet what
the sure consequences of that revolution are going to be.
   Reducing health and other costs related to pollution is the
major benefit we realize from pollution-control programs.
Other kinds of benefits—harder to "cost out"—are equally
   How much is it worth to field workers to know that the
pesticides they deal with are not going to be deleterious to
their health over a long period of time? To the city worker
to see a clear sky? What would a child pay to be able to
swim in streams that once had been too polluted to permit
it? What is the value of knowing that our water is safe to
  We cannot put a dollar-and-cents figure on these benefits.
Moreover, economists don't know how to "model" the
quality of life. Yet most Americans believe that such bene-
fits are real, and they are demanding a clean and healthy
environment. We have no alternative but to do our best to
help them achieve it. D

       An interview with
          Steven Jellinek
Assistant Administrator
  for  Toxic Substances
                             Can you describe how
                             the U.S. compares with
                             other industrialized
                             countries in controlling
                             toxic substances?
                             In the case of legislation to
                             control toxic substances, the
                             U.S. is ahead of most of the
                             industrialized world. A number
                             of other countries have toxics-
                             related legislation in place—
                             Japan, Switzerland, Canada,
                             and Sweden. And others are
                             now actively considering tox-
                             ics-related laws—the United
                             Kingdom, France, and Ger-
                             many, in particular. Also, the
                             European Common Market is
                             considering a proposal for
                             common review of new chemi-
                             cal substances. With respect to
                             specifics of  developing testing
                             requirements and initiating
                             review of new chemical sub-
                             stances, though, we are ahead
                             of other nations.
 So the short answer is
 that we're out front in
Japan, Switzerland, Canada,
and Sweden had toxic laws be-
fore we did. But many aspects
of the Toxic Substance Control
Act (TSCA) and our plans for
implementation go beyond
those currently in place or con-
templated by the other coun-
tries. In general, we have much
more powerful and far-reach-
ing authority under TSCA.

 Is TSCA going to  be a
 handicap to the U.S. in
 international  trade?
I don't think so. It certainly is
the only major law that EPA
administers that has the poten-
tial for any significant effect on
international trade. The auto-
mobile emission control por-
tions of the Clean Air Act also
have a potential  impact on
international trade, but some of
our foreign trading partners
seem to be doing better than
American manufacturers in
meeting provisions of that law.
With toxics, of course, we ere
dealing with chemical products
that as a whole involve tens of
billions of dollars annually in
international trade. The law re-
quires us to treat importers the
same as domestic manufac-
turers, and that means requir-
ing the same types of controls,
information, testing, and so
forth. All these requirements
must be the same for foreign
manufacturers as for domestic
manufacturers. Because of this,
the international community is
very  interested in TSCA, and
that's why we will continue to
meet both with representatives
of individual countries and with
delegations from groups of
countries. They are very inter-
ested in  making sure that, in-
ternationally speaking, efforts
to control toxic substances are
consistent and basically har-
monious. That's why our first
contacts with the international
community  have focused on
ways to  harmonize approaches
to testing chemicals and to
assure that tests are done

Will all these require-
ments  be viewed as help-
ing  to  fuel inflation and
raise costs for
There's no question  that there
are various ways of implement-
ing TSCA that would make it
more expensive for chemical
companies to do business than
if the Act did not exist. But the
chemical industry represents
an extremely healthy and profit-
able  sector of the American
economy, and I believe that any
of the costs we wouid conceiv-
ably  impose under TSCA would
be absolutely minuscule com-
pared to the industry's sales,
assets, and profits. Further-
more, I don't think we're talking
about any kind of major eco-
nomic impact from TSCA im-
plementation. And the benefits
that we jvould realize from
these economic impacts—ben-
efits to the Nation's public
health and environment stem-
ming from the wise control of
toxic substances—would far
exceed any adverse economic

You pointed out in a re-
cent speech that there
are 14 other major Fed-
eral laws concerning
some aspect of toxic sub-
stances, in addition to
TSCA. How does TSCA
make a  major contribu-
tion to  solving our prob-
TSCA provides EPA with sev-
eral unusual authorities that
don't exist under any other
Federal toxics-related law. The
other statutes generally are of
two types: those that concern
wastes or by-products of manu-
facturing, such as the toxics-
related provisions of the Air
Act, the Water Act, the Ocean
Dumping Act, and so forth, and
those that deal with special
categories of toxic chemicals
and involve licensing or regis-
tering those products, such as
pesticide or drug registration
laws. There's also the Occupa-
tional Safety and Health Act,
which in part focuses specifi-
cally on worker exposure prob-
lems.  However, TSCA is very
broad and very comprehensive.
It deals with chemicals and
products, per se, throughout
the life cycle of the chemicals
—through manufacturing, dis-
tribution, use, and disposal. So
it encompasses the entire spec-
trum of interest that one might
have in toxic chemicals.
  It also  provides EPA and the
Federal Government with some
very important new  authorities.
In enacting TSCA, Congress
recognized that there must be
a way for the Government to
gather various kinds of vital
information on chemicals. One
of the things that we knew most
about chemicals  was that we
didn't know enough. For exam-
ple, we didn't know which
chemicals were being manu-
factured, what volumes were
being manufactured, and what
health and environmental ef-
fects they caused. We kept
getting hit with "chemical-of-
the-week" or "chemical-of-the-
month" scares, and we were
unable to anticipate these prob-
lems. TSCA has two important
provisions to help solve this
problem.  One gives us the
authority to gather basic chem-
ical-related information so  we
can make more informed deci-
sions. Section 8 is the informa-
tion-reporting and record-keep-
ing part of TSCA that gives EPA
the authority to collect all kinds
of information from industry on
chemical production, use, ex-
posure, by-products, impurities,
and so forth. The section 4
testing provisions of the Act
give EPA the authority to re-
quire that industry actually
perform tests on  chemicals  in
order to develop health and
environmental effects informa-
tion that may  not have existed
at all or, if it did,  was not avail-
able to the Federal Govern-
ment. With that kind of infor-
mation, not only will EPA be
better informed about chemical
risks, and therefore better able
to control what appears to be
the most unreasonable risks,
but other agencies such as the
Occupational  Safety and Health
Administration will be better
informed about the kinds of
chemicals that workers deal
with. Right now OSHA doesn't
have the authority to require
testing or require certain kinds
of information from manufac-
turers. Often, OSHA doesn't
know what actually is being
produced by a given chemical
company. We'll be able to help
OSHA do its job better by col-
lecting information that they
can use. The information that
we get on health  and environ-
mental effects through the use
of TSCA will be useful to the
EPA air and water programs,
too. If a problem  is so pervasive
that it cannot be  controlled
effectively through any other
Act, then the  law says that
TSCA ought to be brought in to
do the controlling. That is one
of the new and different things
about TSCA.
   Another unusual feature of
TSCA gives EPA  the authority,
under section 5, to review
notices from manufacturers of
their intent to put new chemi-
cals on the market. Based on the
results of this review, we can
take action to stop or limit the
introduction of new  chemicals
if we think they will  cause un-
reasonable risks to health or
the environment. Beginning
early next year, every new
chemical will be subjected to
this premanufacture notifica-
tion requirement. EPA will  have
90 days, extendable to 1 80
days, to read the notice and
decide whether to take action.
If we decide not to take action,
the chemical goes on the
   TSCA's premanufacture re-
view authority is different from
the pesticides law in that it's
broadly applicable to all new
chemicals. Pesticides are regis-
tered for very specific uses as
chemical products that are in-
tended to be poisons and there-
fore require  special  attention.
With TSCA,  every new chemi-
cal is considered a potential
problem, and the premanufac-
turing notification process
gives EPA a  chance to identify
and stop those that have the
greatest potential to create

Does the Act authorize
you to select priorities
for which toxics you're
going  after, and  why?
There are all kinds of priorities.
Institutionally, we feel that we
have to give  priority  in these
first few years to establishing
the Act's basic testing, infor-
mation-gathering, and preman-
ufacturing notification func-
tions so that we can  provide
the basis for a long-term, effec-
tive control program. It takes a
long time to  build a case
against chemicals. You must
have information available, you
have to know how to use that
information, and how to de-
velop it into  a risk assessment
that identifies what the prob-
lems are and demonstrates that
the problems are greater than
the benefits. So we have a long
pipeline to fill, and we recog-
nize that we  have to  start filling
it with adequate risk assess-
ments and information right
from the beginning.  By law, of
course, we have a statutory
deadline to get the premanu-
facturing notication  program
going, and we are giving prior-
ity to that.
   In addition, we are identify-
ing high-priority chemicals for
early regulatory action. The Act
encourages us to give high pri-
ority to those chemicals that
cause cancer, birth defects, or
gene mutations. We're trying to
identify those chemicals,  based
on existing information, that
are highly toxic, whose health
effects are indisputable, and
that are widely used and, there-
fore, widely  exposed to people
and the environment. We are
placing  highest priority for
early regulatory action on
chemicals that have high ex-
posure,  are highly toxic, and
for which the case is relatively
well made. We don't want to
wait two to three years before
regulating our first chemical.
Right now, we're looking at
substances like asbestos, ben-
zene, and some of the other
known human carcinogens and
highly toxic chemicals.

What about radioactive
wastes? Is that out of
TSCA's jurisdiction
TSCA excludes certain sub-
stances that  fall within the
scope of other laws. Radio-
active materials that are regu-
lated by the Nuclear Regulatory
Commission are excluded for
purposes of this Act, for exam-
ple, as are drugs and food addi-
tives, which  already are regu-
lated by the Food and Drug
Administration. Congress  didn't
want us to duplicate other reg-
ulatory programs, so they  spe-
cifically prevented us from
dealing with them under TSCA.

Are all toxics
I  can't give you a simple answer
to that.  By definition, all pesti-
cides are poisonous to some-
thing. Their purpose is to kill
insects, weeds, microorgan-
isms, and so forth. Not all
chemicals are poisonous,  but
any chemical in any amount
may be a poison, in the sense
that it may have a deleterious
effect on the organism it's inter-
acting with. There's no defini-
tion of a "toxic substance" in
the Act.

I assume in your work
you are going to find that
some toxic substances
are in fact poisonous and
require appropriate
deliberation to protect
human health and the
Yes, of course. We're going to
look at individual chemical
substances and then decide
under what conditions the
chemical is exposed to people
and the environment. Then we'll
try to determine whether those
conditions are dangerous or
pose unreasonable risk; if  so,
they will have to be controlled.

How do toxic substances
differ from pesticides?
TSCA excludes pesticides,
which EPA regulates under the
Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA).
With pesticides, we have a reg-
istration program in the truest
sense. You cannot legally put a
pesticide on  the market without
getting EPA approval, or regis-
tration, and you cannot change
the use of a pesticide without
EPA approval. There arc a num-
ber of other things you  cannot
do with pesticides without get-
ting EPA approval. TSCA, on
the other hand, is wide open.
By that I mean it requires EPA
to use its own discretion to
identify and  control problems
as they become known. FIFRA
puts the burden on the  manu-
facturer, who has to say: "Here,
I want to use this pesticide.
Approve or disapprove it."
TSCA is much more flexible
and puts a completely different
type of burden on industry and
EPA. Other than that, there are
a tremendous number of sim-
ilarities between TSCA and
FIFRA when  it comes to inves-
tigating the health and environ-
mental risks  of chemical sub-
stances. But under TSCA, we're
looking for other chemical prod-
ucts in the industrial process,
in consumer products,  and in
intermediate chemical busi-
nesses; we've got to find toxic
chemicals, to identify them,
and to make sure we're working
on the most  important  ones.
How many chemicals
must EPA deal with under
the TSCA?
Our rough estimate is that
70,000 chemical substances
are in commerce in the United
States. About 111,000 chem-
icals have been reported to us
on forms by the entire chemical
industry as part of the initial
chemical inventory under
TSCA. Many of those compa-
nies, of course, produce the
same chemicals, so there is a
lot of duplication in that figure.
We are processing those forms
and will shake out the dupli-
cates, so the final number will
be much lower than 111,000.
It may even be  lower than

Could  you give us  a
thumbnail description of
how  the Act will enable
you to handle this
enormous number of
Chances are very good that
most of the estimated 70,000
chemical substances are not
toxic, at least in the ways they
are normally used and exposed
to people and the environment.
Probably 80 or 90 percent of
them are not toxic in the sense
that they don't present unrea-
sonable risks to human health
and the  environment. Also, we
expect that most of the 70,000
are manufactured in small quan-
tities. And we think that rela-
tively few of them—maybe 10
to 20  percent—are manufac
tured  in significant quantities,
meaning over 100 tons or so.
We will know more about this
when  the chemical inventory is
completed later this  year, be-
cause we've asked for produc-
tion information.
   We have to identify the high-
volume, high-toxicity chemicals
and focus our efforts on those
that appear to pose the biggest
problems to the most people.
!f we had all the staff in the
world, theoretically we could
investigate every one of  those
70,000  substances even if only
five tons of a chemical were
manufactured once every other
year for some special,  com-
pletely enclosed use in a reac-
tion vessel in some small fac-
tory in Peoria.  But realistically,
we can't waste our time on that.
The job, as Congress recog-
nized, is to find out which chem-
ical substances are the impor-
tant ones, and to determine
how they affect human health
and the environment.

I  assume you'll use com-
puters extensively in the
inventory work?
Yes, we will. The inventory it-
self is being put in a computer
system so we can easily retrieve
the information as it's needed.
Much of what industry has re-
ported for the inventory is con-
fidential, meaning that it in-
volves trade-secret information.
Consequently, we are setting up
two separate computer systems.
One will only handle confiden-
tial business information, and
keep it physically separate from
the other system so we can
maintain the requested con-
fidentiality. Then there will be a
public file of all the information
that is not confidential, and it
will be available to anyone who
needs to use it. That file will
include aggregations of some of
the confidential data that can-
not be identified by any individ-
ual company, but we fully ex-
pect that enough information
will be available for analysis to
understand the nature of the
chemical industry and the prob-
lems TSCA was enacted to

What safeguards are
being taken to protect the
trade secrets?
Over the past several months,
an internal EPA task force has
developed a very thorough set
of security procedures to ensure
that this information is handled
carefully, and that it is not dis-
closed inadvertently. In the
unlikelihood that some trade
secret is willfully disclosed in
an unauthorized manner, the
Act itself provides some fairly
stiff criminal  penalties, which
EPA employees and others au-
thorized to use the information
are subject to.
 Can you describe how a
 fully implemented TSCA
 might have prevented
 such past toxics-related
 disasters as those invol-
 ving DBCP, PBB's and
 The Act gives EPA the power to
 identify problems before they
 develop, particularly with new
 chemicals. We will have certain
 information on a chemical in
 front of us before it goes on the
 market. We'll be able to decide
 at that point whether it's going
.to be a problem. So if we saw
 a sterility  problem in animal
 tests—as  in the case of DBCP,
 for example—we could have
 flagged that for more attention
 and have gotten ahead of the
 problem before many people
 and the environment were
 exposed to the chemical.
   I should mention, however,
 that our ability to identify prob-
 lems beforehand will only be as
 good and as thorough as the
 competence of our staff. Thus
 far, the Agency, the Adminis-
 tration, and Congress have been
 very sympathetic toward our
 staffing needs, and we expect
 to be increasing our staff in the
 months and years ahead. I've
 been encouraged with the excel-
 lent quality of people we've
 been able  to attract to the pro-
 gram so far. And in addition to
 EPA's own efforts under TSCA,
 of course, industry knows that
 we will be looking over its
 shoulder.  Not only that, but
 we're going to be between in-
 dustry and the market place.
 I think these factors will have
 their own  impact on the way
 industry makes decisions on
 chemicals. Industry will try to
 identify and avoid potential
 problems  ahead of time. So
 TSCA will have some indirect
 influence  that we hope will help
 prevent many kinds of problems
 that have  occurred in the past.
   My understanding of the PBB
 catastrophe in Michigan is that
 it largely  involved a tragic hu-
 man error. A highly dangerous
 chemical  was accidentally
 mixed with cattle feed. As ter-
 rible as this was, I  doubt
 whether EPA or TSCA could
 have done much at the time, or

          Continued on page 23
                                                                                                         EPA JOURNAL

The Team Leaders
Four Deputy Assistant Admin-
istrators help Steven Jellinek
run EPA's program to regulate
toxic substances and pesticides.
They are responsible for a na-
tional effort involving 1,282
employees and $86.1 million a

Marilyn  C. Bracken
Deputy Assistant Administrator
for Program Integration and
Responsible for integrating the
Agencv 's toxic substances ac-
tivities, coordinating inter-
agency toxic substances strate-
gies, and for establishing and
operating toxic substances
information programs and poli-
cies. Directs the activities of
the Program Integration Divi-
sion, the Chemical Information
Division, the Monitoring Di-
vision  and the Office of Industry
Assistance. Dr. Bracken has
also served as Associate De-
partment Head, Environmental
Chemistryand Biology, and
Department Head, Energy and
Environmental Information
Systems, at the MITRE Cor-
poration. She was Director of
the Division of Scientific
Coordination, Bureau of Bio-
medical Science, U.S. Con-
sumer Product Safety Com-
mission; was involved in
developing data-base manage-
ment systems at the Office of
Information Systems, U.S.
Department of Agriculture, and
was an information systems
anaiystatthe National Agricul-
tural Library. Dr. Bracken was
also a chemist at the National
Bureau of Standards and
Melpar, Inc.
John P. DeKany
Deputy Assistant Administrator
for Chemical Control.
Responsible for the planning.
evaluation, and operation of the
regulatory control program
under the Toxic Substances
Control Act (TSCA). This in-
cludes identifying and initiating
needed actions to regulate
chemical substances and mix-
tures; performing, or insuring
the performance of, scientific,
economic, and technological
assessments in support of such
actions; holding informal hear-
ings on proposed regulations;
developing rules for
controlling chemicais;
receiving premanufacturing
notices for new chemicals,
reviewing such notices, and
determining the need for any
control action. DeKany also
supervises the Premanufactur-
ing  Review Division and the
Control Action Division in the
Office of Toxic Substances.
Prior to this job, DeKany was
Director of the Emission Con-
trol Technology Division in
EPA's Mobile Source Air Pol-
lution Control Program. DeKany
was responsible for the de-
velopment of regulations, test
procedures, and technology
assessments for the Agency's
motor vehicle and aircraft
emission standards setting.
Previously he worked in what
is now the Office of Research
and Development's Industrial
Environmental Research Lab-
oratory in Research Triangle
Park,  N.C. DeKany also has
fourteen years' experience in
nucfear engineering. He was a
manager of marketing strategy
for Westinghouse, a venture
analyst for Gulf Oil Corporation,
and a nuclear project engineer
for the U.S. Atomic Energy
Commission and Argonne
National Laboratory.
Edwin L. Johnson
Deputy Assistant Administrator
for Pesticide Programs.
Responsible for managing and
directing the pesticide activities
of the Agency. Included is the
development of strategic plans
to control the adverse effects of
pesticides and to establish
policies and regulations which
will lead to more judicious and
pesticide use. Johnson's office
has responsibility for standards
governing the certification of
pesticide applicators; the regis-
tration of all pesticide products
under the Federal Insecticide,
Fungicide, and Rodenticide
Act (FIFRA); establishing tol-
erance levels for pesticide
residues in food and feed;
monitoring pesticide residues
in plants, animals, and the en-
vironment;  reviewing requests
for emergency pesticide uses
and special local needs; de-
termining research and moni-
toring needs and requirements,
and reviewing environmental
impact statements concerning
pesticide use. Johnson has
previously served as Associate
Deputy Assistant Administrator
for Pesticide Programs, Director
of Operations and Strategic
Studies for Pesticide Programs
in the Office of Water and
Hazardous Materials, and Spe-
cial Assistant in the former
Office of Categorical Programs.
Johnson was a program and
management analyst, an engi-
neer systems analyst, and then
Chief of the Systems Analysis
and Economics Branch at the
former Federal Water Quality
Administration. At the U.S.
Public Health Service, he was
an engineer and project director
and then Chief Economist for
Comprehensive Planning and
Warren R. Muir
Deputy Assistant Administrator
for Testing and Evaluation.
Responsible for planning and
operation of the program to
identify and evaluate the haz-
ards that chemical substances
and mixtures may pose to
health and the environment.
This includes developing cri-
teria for assessing pertinent
scientific data, establishing and
carrying out policies and pro-
cedures for required testing
under TSCA, developing and
evaluating test procedures and
guidelines, selecting chemicals
to be tested, and conducting
risk assessments in support of
regulatory action on existing
chemicals and as assistance in
judging hazards of new chem-
icals. Previously, Dr. Muir was
Senior Staff Member for En-
vironmental Health at the
President's Council on Environ-
mental Quality (CEQ). His
personal responsibilities in
program development at CEQ
included toxic substances and
environmental health, occupa-
tional health, pesticides and
integrated pest management,
regulation of chemicals, en-
vironmental effects research,
environmental health condi-
tions, and chemical substance
information. Program develop-
ment by his staff concerned
monitoring, the analysis of
environmental conditions and
trends, information systems,
environmental indicators, and
the design of UPGRADE, a com-
puterized system to analyze and
display environmental data.


        By John Heritage
   Back in 1971, a little girl named Andrea
     Piatt became mysteriously ill in her
Missouri home. She was hospitalized im-
mediately, suffering bladder pain, diarrhea,
bloody urine and  headaches.
  tt took more than three years for scien-
tists to find the culprit. Andrea had unknow-
ingly been exposed to a highly toxic chemi-
cal, TCDD, adioxin. The poison was a by-
product in the making of hexachlorophene,
an antiseptic.
   The TCDD  that sickened Andrea was so
potent that  it killed hundreds of birds,
dozens of pet  dogs and cats,  many rodents
and even the flies where the chemical had
been sprayed. Mo re than 60 horses also died.
   Andrea's tragedy is an example of why
the Toxic Substances Control Act was en-
acted. With this new legislation, which
went into effect in 1977, Congress acted to
head off similar incidents in  the future.
Here is the rest of Andrea's story and some
other disasters that the new  law was
designed to prevent.

   Andrea liked to play in the big barn and
horse arena on a farm near Moscow Mills,
Mo. Then on May 21, 1971, a truck drove
up and sprayed the earthen arena floor with
about 2,000 gallons of what  Andrea's
mother and her business partner were told
was salvaged  motor oil, to keep dust from
blowing around. Three days later, the birds
began to die.
   By the time Andrea was hospitalized and
hundreds of animals were dead, everyone
involved suspected that something in the
waste oil  had caused the epidemic. But no
one knew what.
   The answer even eluded scientists at
the Center for Disease Control in Atlanta.
Finally, a lexicologist who had read about
TCDD in  Germany proposed  that soil from
the horse arena be tested for it. The test
confirmed the poison's presence.
   The TCDD  was traced to a tank of waste
liquids at a  chemical plant 350 miles from
the farm. The  plant was making hexoachloro-
phene, and  TCOD was one of the leftovers.

John Heritage is an A ssistant Editor of
EPA Journal.



        (Po^chlc-i-wittd Btphenyw          s
 A toxic*nvlfonmeorol contominonr requiring
            <~nd disposal if. accordance with
, , 	ji ftoteaion Agency Requlortom
 40 CFR 761- "Or DispcwH nfo -notion contoct
       ther^otestas. eP.A. Office,
 In case of c,cidem or spil' coll toll free the U.S.
   Coosr Guord Nationc Response Center.
 Also ConfcxJ
 Tel. No.
Barrels of PCB wastes carry these labels at  .i temporary holding  site  until they can
hi; transferred  to ii licensed PCB disposal site.
  The plant owners had contracted with a
chemical distributor to get rid of the
wastes. Under subcontract, a truckload of
the contaminated liquids had been hauled
to a storage yard in St. Louis, and the truck
later sprayed the TCDD-tainted wastes on
the horse arena where Andrea played.
  The TCDD trail showed the conse-
quences of ignorance and lack of effective
regulation. When an industrial waste with
dangerous TCDD got into circulation,
death and illness were the result.

Children also were involved in another
more recent episode. Back in 1972 the U.S.
Department of Commerce set mandatory
                              flameproofing standards for children's
                              nightgowns and pajamas. A fire retardant
                              chemical called Tris appeared to be an
                              economical and convenient answer to the
                              rules. Soon it was being applied to about
                              half the children's sleepwear sold in the
                                 At the time it seemed that one hazard of
                              childhood had  been lessened, because in
                              1973-74, the first year flame-proofing was
                              mandatory, children's burns and deaths
                              from clothing fires showed a decline.
                                 But then another problem surfaced.
                              EPA-funded research at Columbia Umver-

sity showed that Tris had the potential to
cause mutations or changes in cells. In late
1975, EPA reported the results. By Feb-
ruary, 1977, National Cancer Institute data
showed that Tris was a highly  potent
cancer-causing agent in test animals. Other
research showed the chemical could be
absorbed through  the skin.
   In April, 1977, the Consumer Product
Safety Commission halted the production
and sale of Tris-treated clothing. Based on
available data, it was estimated that 300
out of every million male children wearing
Tris-treated pajamas for 12 years would
develop cancer.
   The dream of an easy answer had dis-
appeared. In the effort to protect children
from fire, millions had been exposed to a
cancer risk. The threat hadn't been checked
before the first safety rules were issued. By
the time health action came, Tris-treated
nightwear had been used from coast to
coast. It was yet another demonstration
that the public needed the protection of the
new toxics law designed to help detect
carcinogens before they found their way
into the marketplace.

Workers were the victims in still another
toxics incident. This time, the workers be-
latedly learned something was wrong, but
damage already had been done.
   The story broke on network  television in
late July, 1977. More than a dozen workers
at the Occidental Chemical Company in
Lathrop, California, had become sterile or
had very low sperm counts. A soil fumigant
known as DBCP was believed to be the
cause. The chemical was widely used to
protect crops from root-destroying round-
   In less than two weeks, production of
DBCP in the U.S. was halted voluntarily
and California banned its production, sale,
or use.
   Moving with unusual speed, the Federal
Occupational Safety and Health Adminis-
tration completed  the complex steps to set
an emergency standard on DBCP to sharply
restrict the levels of the chemical to which
plant workers could be exposed.
   EPA suspended and announced  its in-
tent to cancel DBCP use on 19 crops with
edible roots, and set special handling rules
for other DBCP uses. The Food and Drug
Administration said it would monitor farm
produce headed for market to  check the
chemical's residues.
   Although Government, industry and la-
bor had moved quickly once the national
publicity focused on the problem, warning
signals actually had been flashing for 1 6
years. Ina 1961 study commissioned by
industry, DBCP was identified as damaging
to laboratory  animals. At the lowest level
of exposure studied, breathing DBCP
vapors was found  to harm the  liver, kidneys
and various tissues including sperm cells.
The report was published in a professional
  As early as 1973, National Cancer In-
stitute studies had identified DBCP as a
cause of cancer in animals. In March, 1976,
an employee at the Lathrop plant, Ted
Bricker, was told by a doctor that he had
an abnormal sperm count. The diagnosis
contributed to worker and union concern
about possible hazards at the plant.
  The long lag in controlling DBCP  had
many reasons. Facts were known but not
forcefully communicated. Industry's rec-
ordkeeping had been spotty. The occupa-
tional health establishment seemed  to be
preoccupied with other ailments. And of
course TSCA, with  its new requirements to
fill in the  gaps left in other toxics laws, was
not yet in existence.

A toxic substance can do far more than
harm workers in a chemical plant, or con-
taminate children's pajamas. It can taint
the whole environment—the rivers, the
land, the sea, wildlife, humans. The case
of PCB's shows how this could occur.
  Spring is usually a time of increased
activity along the Hudson River in New
York. The fishermen turn out to tap the
river's wealth.
Samples of dirt taken from  tho bank of
the Sheboygan River showed the site to
be a source of PCB contamination to the
watershed. At one time hydraulic fluids
containing 12 percent PCB's  were
deposited  here  and the  chemical has
since been leaching from  the  soil.
  But since February, 1976, the Hudson
has been different. Both sport and commer-
cial fishing have been banned on much of
the  river by the Commissioner of the State
Department of Environmental Conserva-
  The river has become contaminated by a
class of toxic chemicals called polychlori-
nated biphenyls, or PCB's. Worse, despite
corrective action by the main polluter,
General Electric Co., the Hudson probably
will be tainted for years.
  One eel was found to have 559  parts per
million of the chemical. The level  was so
high that an adult who ate a 7-ounce por-
tion would get 50 percent of his iifetime
"allowance" of PCB's in a single serving.
Said one long-time Hudson River fisher-
man, "Shopping in  a fish market these days
is like picking your  way through a  mine-
  The concern about PCB's was under-
standable. In 1968  in Japan, a machine
leak of the chemical into rice oil caused a
tragic poisoning. The 1,500 victims of
yusho, or oil disease, suffered skin lesions.
swollen limbs, and  eye and liver problems.
The accident called wide attention to the
danger from PCB's.
  Over a period of 30 years some 230 tons
of PCB's had built up in Hudson River sedi-
ments, mostly from two GE plants that had
discharged PCB's with waste water. It
would cost as much as $200 million to
dredge the contaminated bottom,  accord-
ing to one estimate.
  The worst of the buildup was in a 40-
mile stretch of the river, but the chemical
was reaching far from the Hudson. By
1972, the  PCB's had been found in every
major river system  in the U.S. Prized coho
salmon in  Lake Michigan were tainted. The
substance was found in some of Ohio's
milk supply. PCB's were accidentally
sprayed on 800,000 pounds of tuna meal in
a Puerto Rican warehouse fire when two
electric transformers burst.
  Like its  distant relative, DDT, the chem-
ical was everywhere. It was estimated that
51 percent of the people in the U.S. had
some PCB's in their bodies. Meanwhile,
research was implicating the compound
in cancer and birth  defects. Among other
results, high PCB doses killed laboratory
test animals.
  Because the PCB's are chemically
stable, fire resistant, and don't conduct
electricity, they had been widely used in
electrical equipment for many years.  Other
PCB-aided products included adhesives,
paints, insulating tape, printing inks and
plastic. Some 450 million pounds of the
PCB's had built up  in nature and in often-
leaky  landfills and dumps, according to
  EPA has proposed an end to the manu-
facture, processing, sale or use of PCB's
except as part of a totally enclosed system.

                        Employees of the  Wisconsin Department of Natural
                        Sheboygan River, warning  anglers  to  avoid eating  fish
                                 Resources posl si.            -mle sln-trM ot ihe
                                     because they coriUitn hicjh levels of PCB's.
But the compound remains in lakes, rivers,
dumps, fish and people. It is a memorial  to
nearly half a century of ignorance about
the hazards of one industrial compound.
   What were the reasons for these various
toxics episodes? How could the United
States, with a long history of public pro-
tection, allow them to happen?
   The trouble reaches back to the years
after World War II, when an explosive
growth in U.S. chemicals began. The trend
promised to boost the Nation's living
standards, though with a little-noticed
   By the 1 970's, the chemical revolution
had transformed America, in everything
from soap to skyscrapers. As many as
70,000 chemical substances were in the
marketplace. Sales in the industry were
more than $112billionin1977.
   But in the birth of the chemical age, a
big question was overlooked. !t was the
possible danger to the public's health,
especially from chronic disease. Only a
few thousand compounds had been ade-
quately tested for chronic health and en-
vironmental effects. Little was known about
the long-term risks of existing chemicals
being marketed, let alone new ones not yet
in commercial production.
   Unwittingly, the Nation itself had be-
come a laboratory. People were being
tested, not the chemicals. The doses could
be heavy from products, wastes, and
   Few Americans had any idea until re-
cently that they were living so dangerously.
They didn't know that when they did or-
dinary things such as eating, drinking and
breathing, they could be laying their lives
on the line, playing a game of chemical
   It  took endangered children, contami-
nated fish, dying horses and other incidents
to alert the public to the long-term risks
some chemicals pose.
  The new toxics law gives EPA strong
authorities. Tests may be required on po-
tentially harmful chemicals. Manufacturers
must notify EPA of planned production of
new compounds for the marketplace. The
EPA Administrator can take action de-
signed to keep a new chemical off the
market. The Administrator has the author-
ity to control existing  substances as well.
  The philosophy of preventive action is
now functioning to protect the public from
exposure to toxic substances. Although the
law is no guarantee against human care-
lessness or willful neglect of safety meas-
ures, it does set up many new precautions
and imposes major penalties against viola-
tors. While it is too early to gauge its
effects precisely, observers agree that the
Toxic Substances Control Act has given
Federal officials a weapon that promises to
greatly reduce the likelihood that com-
pounds like TCDD, Tris and DBCP can
reach the consumer in the future. D

       By Marion Parks
       ore than two years ago in
       Seveso. Italy, an explosion
   in a small factory producing
   trichlorophenol for export to
   the United States brought in
   its aftermath all the kinds of
   costs and consequences that
   environmentalists have antici
   pated and sought to forestall
   through timely and appropriate
   regulation. The Seveso case has
   shown through a tragic disaster
   why we need to protect the
   health of people and the en
   vironment from accident or
   misuse in the management of
   toxic substances, under the
   conditions of massive chemical
   production of our times It
   shows as well the enormous
   costs to the public and the
   burdens and losses for the "
   dustry that can ensue when
   such protective regulations f-ui
   Marion Parks is vice president
   of the Rachel Carson Trust
   for the Living Environment, Inc

or are lacking. The story is still
far from ended and the toll of
its costs on society will continue
for a long time into the future
  The explosion on July 10,
1 976. at the ICMESA chemical
plant in Seveso, some 1 2
miles north of Milan, showered
a populated area of more than
six square miles with a fallout
of trichlorophenol, ethanol,
caustic soda, and tetrachloro-
dibenzo-para-dioxin (TCDD), a
substance characterized  by the
President's Science Advisory
Committee Panel on Herbicides
as "extraordinarily toxic." No
other agent, indeed, has yet
been discovered to be more
toxic. In research as small a dose
as 0.0006 milligrams of TCDD
per kilogram of body weight
killed one-half of the female
guinea pigs to which it was fed.
Its effects vary with different
antmal species that have  been
tested, but only slightly.
  11 has been established that
TCDD is teratogenic; i.e. it
causes birth defects in develop-
ing animals and may be lethal
to the fetus or cause abortion.
It tends to cling or bond with
particles of dust, silt, or organic
matter and may be ingested or
inhaled  It has poisoned humans
and large animals such as horses
through skin contact. Extensive
records of sickness due to con-
tact with TCDD show that its
most conspicuous symptoms a re
chloracne, a severe skin disease
that  is very resistant to treat-
ment, and in some cases
hirsutism, an unnatural and dis-
figuring growth of hair over the
forehead and sides of the face,
as well as serious liver and
kidney ailments. Many other
symptoms occur, including
persisting debility and psycho-
neurotic reactions. Whether
TCDD is cumulative in living
tissues has not been determined
but is under investigation in
several research studies. Some
research in Germany and
France has indicated that it
may be carcinogenic, i.e., a
cause of cancer. This has not
been confirmed.
  There is no antidote that can
reverse or modify the effects
of TCDD. The tetra-dioxin mole-
cule  itself is nearly indestruc-
tible. Its biodegradation in
soil takes place very slowly
To some extent the process may
be stimulated or aided by sun-
light; when the TCDD becomes
embedded deeply into soil
cracks and crevices, this action
has little effect. TCDD is in-
soluble in water but can be
transported mechanically by
water and lodges and persists
in silt. It can be removed from
various surfaces with  solvent
or diesel oil, but is not quanti-
tatively diminished or  altered in
its action. Therefore it remains
unchanged in the washing agent
and containers, which are then
permanently contaminated and
can induce chloracne in
  Tetra-dioxin can be disinte-
grated and consumed by heat,
but only at sustained tempera-
tures above 2500°F,  much
above the capacity of any
ordinary incinerator. Application
of heat at lower temperatures
seems to intensify its reaction.
According to some analysts
it may have the potential of
multiplying its own quantity
under certain conditions of
  It is possible to synthesize
TCDD in pure form for research
purposes, but no refinement of
the manufacturing process has
succeeded in eliminating its
occurrence as a contaminant
in trichlorophenol and related
compounds. These include
phenoxy-acetic acid herbicides
such as 2,4,5-T; hexachloro-
phene, a bacteriocide used in
deodorants and germicidal
soaps; and pentachlorophenol,
used as a wood preservative.
In most current production of
these compounds, TCDD con-
tamination is kept at levels
below 0.1 part per million.
The products are used in agri-
culture, forestry, cosmetics,
and in hospitals (surgical soaps,
for example), on the theory that
at a very low level the presence
of TCDD  does not constitute
a threat to human health, al-
though there is disagreement
among scientists regarding this
theory and its interpretation.
    The trichlorophenol products
    are synthesized from the
basic material ethylene, a re-
finery by-product. The manu-
facturing process requires
several steps in several types of
chemical plants, which may be
located in a single complex
or widely separated from each
other. The ICMESA chemical
plant of Seveso is owned by the
Givaudan corporation, a sub-
sidiary of the giant Hoffman La
Roche pharmaceutical company
based in Switzerland. ICMESA's
production, according to com-
pany spokesmen, was limited to
trichlorophenol, all of which
was shipped to the Givaudan
plant in Clifton, New Jersey, for
conversion into hexachloro-
   The ICMESA instalfation is
relatively old, a small establish-
ment, employing about 1 57
workers, a Swiss manager  and
engineer, and an Italian chemical
engineer. It is situated in an en-
clave of former farmland which
is in the process of suburban
conversion. The area around it
is not an industrial zone but
typically suburban, with large,
substantial business centers in
the towns or communes of
Seveso, Cesano Maderno,
Meda, and Desio, which all
blend into each other. In a
mixed pattern on the fringes of
each one there are houses with
garden plots large  enough to
grow a few fruit trees and
vegetables and to keep
chickens, rabbits, and a type of
small Asian goat which has been
popular in the area; two- to
four-story apartment  buildings;
and scattered throughout the
four communes a multitude of
small and medium artisan
shops, with some 25,000 em-
ployees. The shops produce fur-
niture, mostly for export to
Switzerland and other European
  The heavily traveled modern
freeway running  northward
from Milan to the Swiss
frontier skirts the east side  of
the ICMESA plant. The housing
development, which was hardest
hit by the chemical fallout, is
situated between the freeway
and the factory. About a mile-
and-a-half to the west of
ICMESA is the Seveso City
Hall, a large dark stone and
brick building.  Between it and
the factory lies a street of rather
large homes with tree-filled
grounds, and opposite them the
stretch of land and large build-
ings owned by the Seminary of
St. Augustine, and between
there and the factory a few
blocks of mingled shops and
  The local health and labor
authorities did not know what
was produced at ICMESA. They
did not know where the product
was shipped or in what
quantities, whether toxic
wastes were generated, or what
disposal was made of them. No
information on that score is
available now. A few years
before the accident, the
Seminary sued the company
because some of their cows
                                                                                                             EPA JOURNAL

                            DWEIO  nssoiuro
                               01  ACCESSO
 Barbed wire fences cordon off some of the most badly contaminated areas of the town.
were poisoned by water from
the Seveso river, which runs
near ICMESA, but did not ob-
tain a judgment. The factory
Workers' Council had requested
information through the local
authorities about the chemicals
they handled in order to deter-
mine occupational hazard two
years before the explosion, but
a reply from the company was
still pending.
  Italy has no government
agency for environmental over-
sight. Its laws regulating indus-
trial pollution are old and bear
little pertinent relation to con-
ditions of modern petrochemical
operations. The almost unlimited
expansionofthisindustry, under
few restrictions and lax  inspec-
tion policies, has been en-
couraged in order to gain its
input into the weak national
economy. As an outcome of
the Seveso disaster a govern-
ment census of industry
throughout the country has
been urged and demands for
regulation under new laws and
more enforcement of such
regulations as exist, have been
voiced in Parliament.
  On Saturday, July 10,  1976,
at noontime, the runaway ex-
plosion took place in the
ICMESA reactor, as a crew of
six or eight workers were
shutting down the plant for
the week-end. In a split second
the chemicals in the 2,000-litre
tank roared up with a force that
the control valve failed to con-
tain, and shot out through the
vent opening to the outside of
the building in a rolling greyish-
white cloud. It later was esti-
mated to contain some 500 kilo-
grams of sodium hydroxide
methanol and tetrachloro-
benzine, the basic components
of trichlorophenol. By official
estimate two to three kilograms
of TCDD were suspended in this
mass. Some observers believe
it may have been much more. At
the lowest estimate, considering
the extraordinary toxicity and
persistence of the tetra-dioxin,
it was a staggering amount. The
manager of ICMESA said that
1,000 kilos of trichlorophenol
and perhaps some TCDD re-
mained in the reactor Volun-
teers were trying to clean it out.
One worker developed severe
    Similar, indeed practically
    identical, accidents have
happened in the production of
trichlorophenol over a stretch
of years since 1 948, twice in
chemical  plants in the United
States, twice in Germany, once
in England, once in Holland. In
each instance workers and
others in contact either with
them or something in the plant
have suffered chloracne and
other sickness requiring medical
care for prolonged periods.
Contamination of the buildings
and equipment with the tetra-
dioxin was ineradicable to a
degree requiring demolition
(under extreme precautions)
and the rubble was put under
cement and buried or dumped
at sea. In every instance, prior
to the explosion at Seveso, the
poison was contained within
the factory. The injury and
sickness of workers, their
treatment and compensation.
dismantling of equipment,
demolition of buildings, and
disposal of the rubble all were
internal matters for owners,
managers, and company
physicians. The reports of the
latter, published in some
scientific journals in England
and Germany, were of prime
importance to the Italian health
officers in identifying, con-
firming, and coping with the
Seveso disaster.
  In Seveso for the first time,
such an accident became a
public affair, a regional disaster.
No health officials were pre-
pared for  it. The body of refer-
ence information they needed
was extensive but not codified,
readily accessible or definitive.
The more they learned from it.
the more  appalled they became.
Responsible officials nonetheless
had to take the terrible risks of
decision in that nightmare
situation with no firm prece-
dents to guide them and under
enormous pressures to find a
quick fix and avoid public panic
On July 30, twenty days after
the explosion, the Minister
of Health, in defending the
government for not having
acted faster than it had, said
that "no similar accident has
occurred  before in the world,"
adding that it was not possible
yet to decide the best way to
decontaminate. That decision,
in fact, has not been fully
settled on up to this time.

  A momentary wailing
whistle accompanied the es-
cape of the chemical cloud out
of ICMESA and a stench filled
the air. The day was fair with
almost no wind. The vaporous
mass settled to the ground,
bounced upward, descended
again, and vanished. Its load
of sticky vapor and fine white
crystals settled visibly on vege-
tation and walls and drifted
invisibly far beyond the ap-
parent area of its fall ICMESA
offered the first map of the area
contaminated.  It ran in the shape
of a triangle with the apex at
ICMESA, south and eastward
from the factory. The first
estimate was 1  2 hectares or
268 acres  Day by day, for
many weeks afterward, the zone
of impact was to be extended
by new discoveries of the pres-
ence of TCDD.  As of now, a
plot of some 1 50 acres has been
sealed off from any access, and
is deemed unusable for at least
1 0 years, perhaps longer.
  People for the most part
were indoors at their noonday
meals when the explosion
occurred, but a few little child-
ren were playing outside. Some
of them ran to the cloud,
laughing, with arms out-
stretched. It  looked to them like
snowflakes. Those children are
still sick, disfigured with stub-
born chloracne over faces and
arms, destined to years more of
treatment and eventual plastic
surgery. Many adults became
nauseated and  had headaches
after the cloud  came down. But
they were accustomed to the
occasional noisome emissions
from ICMESA  They ignored
this latest one and waited for
the effects to pass

     01 Sunday afternoon, two
     •epresentatives of the man-
agement of ICMESA sought out
the health officer and the
Mayors of Seveso and Meda.
They said the people should be
warned not to eat fruit, vege-
tables, poultry, or rabbits from
their yards. Samples of soil and
vegetation from around
ICMESA were  collected and
sent to the company laboratory
in Dubendorf, Switzerland, for
analysis  Flowers and leaves
touched by the fallout were
beginning to wilt. There was
evident damage to crops in
the path of the cloud. On  Mon-
day and Tuesday some adults
reported illness and children
were suffering with body rash.
Domestic animals were sicken-
ing. On Tuesday they began to
die. The veterinarians found
hundreds of wild birds, seem-
ingiy including a whole flock
of swallows, dead on the
ground. Wherever they went,
they encountered dead field
mice and moles.
  Friday, July 1 6, the workers
closed down ICMESA. At 6:30
that evening the management
told the health authorities that
the emission "was toxic." The
acting health officer stated that
the people should be evacuated
from the contaminated zone.
Twelve children were hospital-
ized. The Mayor ordered the
preventive destruction of the
vegetation and the animals in
the zone, the carcasses to be
doctors noted that the lesions
were of a type not encountered
before. On Tuesday, July 20,
ten days after the explosion,
it was confirmed both for the
health authorities and the pub-
lic, that the poison they were
dealing with was TCDD. The
following day 444 people
were evacuated from their
homes and housed in a large
hotel complex about ten kilo-
meters away, near Milan.
Eighty children were sent to
summer camp at Lake Como.
  Physicians and scientists
began to mobilize. Health and
public authorities held meetings
daily. From some quarters a
demand was raised to burn
everything to the ground. A
military contingent arrived with
armored trucks and flame-
throwers and remained on call
for weeks, to the intense alarm
Worker clad in protective garb is cleaning dioxin residues from
a homo insido thn affected area in Seveso.
picked up by truck squads from
ICMESA and held there. At
five o'clock the next morning,
ICMESA sent trucks with spray
equipment around to douse the
vegetation with lime. The
workers refused to go back to
the factory. The Mayor ordered
it closed and on July 1 8 a judge
ordered its sequestration. The
only other factory in the immedi-
ate area, a plant which made
children's clothes and employed
about 80 women workers,  was
ordered closed. Fourteen
children were now hospitalized
with rash and skin lesions. The
of some of the scientists and
health officers. Burning was
held in abeyance while other
possibilities were studied. It
was proposed to remove a layer
of soil to the depth necessary to
remove  the tetra-dioxin pene-
tration and spray the earth taken
away with a layer of plastic.
  Two American military of-
ficers, believed attached to
NATO, appeared, took soil
samples, and went away mys-
teriously. The memory of U.S.
military  use of herbicides in
Vietnam intruded frequently,
and was like a stage ghost
every little while stalking
through the scene. Insistent
demands were made on the
public authorities to summon
the Vietnamese doctor Thon
That Thun as a consultant.
His advice, electronically trans-
mitted to the press, was to
watch for the protection of the
natural defenses of the body
organism in exposed people,
apply antibiotics, immuno-
stimulants, and prescribe Vita-
min C. His advice regarding de-
contamination was picturesque
if not practical: wash everything
down with white Marseilles
soap. This was no stranger than
another scientist's proposal to
put olive oil on everything. There
was logic in both suggestions, as
TCDD, like other organochlorine
chemical formulations, is lipo-
philic, or fat-attracted.

    The problem always re-
    mained, with any proposal,
of disposing finally of the TCDD
however it might be removed
from the soil, house walls and
roofs, school interiors, wherever
it was encountered. It was soon
shown that the seriously con-
taminated zone was much larger
than first estimated, and beyond
it a still greater area was de-
signated as a "zone of caution".
The final estimate of the amount
of soil into which TCDD had
penetrated and lodged, by
depth and area, was 99,000
metric tons. Removal  in the
foreseeable future was an im-
possibility. Burning was perhaps
the worst of all proposals,
since some of the TCDD, re-
leased from where it lodged
but not destroyed, could be
distributed more widely than
ever in smoke and ash and
carried into the soil somewhere
else by rain.
  A serious study was made of
constructing,  probably close to
the ICMESA site, a special in-
cinerator capable of consuming
TCDD by subjecting it to the
necessary high temperature.
Public fear and resistance to
this idea led to citizen protest
demonstrations. For the
present, the scheme remains in
abeyance. Some people, how-
ever, looking at what has be-
come not only a national prob-
lem of Italy but a world problem
— the safe disposal  of chemical
wastes—have thought of put-

ting up such an incinerator on
a part of the wasted and ruined
ground of Seveso as a point of
disposal for toxic chemical
wastes from all Italy and pos-
sibly a larger area.
  On July 23, ten days after the
explosion, a heavy rain fell on
the Seveso region. Many fears
were expressed that the run-
off would carry the poison
into the underground water
basin (most of the area is
supplied by wells) and the
river system emptying into the
Po. These fears have neither
been borne out in experience
nor entirely allayed. The soil
of the contaminated area is
largely clay; it tends to crack
when dry but is not very porous.
It is thought that most of the
tetra-dioxin was washed into
these crevices and for the most
part  remains there. This would
account for much of the high
concentrations and persistence
of the poison and the ultimate
decision to seal off such a large
part  of it  against any occupancy
or use—for ten years or longer
as may turn out.
  The Givaudan company
spokesmen in Switzerland told
the press shortly after the ex-
plosion that the company was
financially able to pay the
costs of rehabilitating the con-
taminated area and would take
charge and do so, but this pro-
posal was rejected by the gov-
ernment  of Lombardy Prov-
ince  and the local authorities.
Givaudan hired the  British
chemical engineering firm of
Cremer and Warner as con-
sultants and they conducted
tests on the ground in Seveso.
  In  the last week of July, 1976,
and early August, the formu-
lation of lawsuits against
ICMESA  and Givaudan was be-
gun by the Lombardy Regional
government, the labor  union,
and other entities. The technical
director of ICMESA was placed
under arrest charged with
"culpability of causing a disas-
ter and harmful disregard of the
misfortunes caused by his ac-
tions." His release was later
obtained but the scope and
duration  of litigation stemming
from the Seveso case will un-
doubtedly be costly and trying
for all concerned for years to
  The number of families
evacuated from the poisoned
zone continued to rise until
some 750 individuals were
housed in the Residencia
Leonardo da Vinci. By October
the evacuees, angry and desper-
ate at the uncertainty of their
situation, one day went out and
stormed the barricades, de-
manding the right to reoccupy
their homes. They were per-
suaded to return to the Residen-
cia. in the next weeks people
began agitating for permission
to go into the Seveso cemetery
to clean the graves in prepa-
ration for All Souls' Day, Novem-
ber 2. The area around the
cemetery had been declared a
military zone and the army
maintained a vehicle park near-
by. The people were permitted
to enter and did so provided
with materials for washing and
polishing the large flat slabs
of marble with which most
graves in Italian cemeteries
are covered. Nearly all of those
who performed this task suf-
fered skin rashes afterward and
some complained of respira-
tory discomfort.

A     great effort was made by
     the authorities to clean the
schools so that the children
could enter them again. The
walls were vacuumed and
washed with detergents, always
by a work force wearing pro-
tective clothing, gloves and us-
ually masks. After the schools
reopened some 200 children
developed skin rash. Some of
their teachers believe that they
have more respiratory ailments
and colds than in past years,
but this cannot be counted as
an epidemiological statistic.
   The knowledge that TCDD is
a potent teratogen fell on the
doctors and the public with
enormous impact soon after its
presence in the poisonous cloud
from ICMESA was confirmed.
In addition to emergency clinics
where more than 10,000 people
were examined and given blood
and  urine tests, a special
maternity clinic was established
both for counseling and for
therapeutic abortion, which the
Italian Supreme Court recently
declared to be legal in some
circumstances. Twenty-seven
abortions were performed and
the fetal material was sent to
a German university for examin-
ation by a team of Italian and
German specialists. No confir-
mation of birth defects was
derived from this study. A very
stormy period of religious and
political controversy arose over
the abortion question and the
clinic was closed. Some women
of the region, who believed they
had been too dangerously ex-
posed to TCDD to risk bearing
a child that might be deformed.
went to other countries for
abortions in order to avoid the
agitation and controversy sur-
rounding this issue at home.
   It is unlikely that any reliable
or extensive epidemiological
studies of birth defects have
been made in any country. In
the United States as in Italy,
very little data have been kept
or compiled in this regard over
past years with which new data,
for example, relating to a mass
exposure to a toxic chemical
that is teratogenic. can be com-
pared. Continuing research is
required and the Seveso case
will be a stimulus in that direc-
  Innumerable meetings of
health officials, toxicologists,
physicians, and public adminis-
tration officers were held in
Seveso, Milan, and Rome over
the Seveso case. Many foreign
specialists were called to Italy
on consultation. An Italian team
of scientists and administrators
came to the United States and
met with Americans in special
sessions at the Department of
State and the National  Academy
of Sciences. No one could really
help very much beyond ex-
changing the hard information.
There is no antidote for tetra-
dioxin poisoning, they had to
agree. There is no technological
magic with which to counteract
or repair the damage done in
Seveso to the big physical area
touched by the cloud and its
drift, and to the segment of
human society whose lives were
disrupted and certainly in some
cases brought to irreparable
  It was only too natural, in the
charged state of political ten-
sions and economic strain under
which Italy has lived for some
years now, to accuse public
officials of ineptitude or poor
performance. In a moment of
passion, an angry citizen shot
one of the health officials of
the Seveso area in the legs. As
a matter of fact, the Italian
scientific community mobilized
rapidly and the doctors worked
selflessly in a day-and-night
effort to cope with the emer-
gency. A pharmacological in-
stitute equipped with the
expensive, sophisticated instru-
mentation for the technique of
gas chromatography and mass
spectrometry. which are re-
quired for the detection and
quantification of TCDD, already
existed in Milan under highly
competent specialists. They
were in the Seveso action from
the beginning.
  As the full significance of
what had happened began to be
appreciated, the government
declared Seveso a disaster
area, provided assistance funds,
and named a special national
commission to deal with the
problem, under the Ministry of
Health. In Seveso, the unfolding
situation with all its shocks and
complexities involved the four
Communal administrations, the
Province of Milan, and the Re-
gional Giunta  of Lombardy.
Their ability to get together and
steer a relatively straight and
basically safe  course through
the emergency was something
of a marvel. An interesting
thing  about it  in retrospect is
that despite disagreements or
conflicting opinions, or ques-
tions of lines of authority, no
dictatorial figure seems to have
been brought to the surface by
the difficulties encountered.
Perhaps this was because, in
the presence of a massive
poisoning of the earth with a
chemical so dangerous as
TCDD, the alternatives were
very limited, and everybody
had to come back to exactly
what had been done, whether
he wished to or not.

    Not everyone is satisfied that
    enough has been done. Lax-
ness in sealing off and guarding
the contaminated zones can be
charged. Many will disagree
with the recent official estimate
of 67 proven cases of chloracne,
ascribing the hundreds of
other incidents of severe skin
irritation to burns from the
sodium and methanol content
of the fallout.  Some people
believe that the epidemiological
surveys of the general area
have been deliberately incom-

         Continued on page 35


                                  • himnnys nt thr: stern of the Vulcanus mark the location of the incinerator, which destroys toxic
                                     is by burning them at extremely high temperatures.
     When the U.S. Air Force
     began casting about eight
years ago for a way to dispose
of its surplus stock of Herbicide
Orange, the defoliant used in
Vietnam,  it ran into unexpected
  Herbicide Orange has been
under heavy criticism from sci-
entists who warned that the
dioxin contaminant in the mix-
ture caused birth defects in lab-
oratory animals. The Defense
Department had ordered the
herbicide withdrawn from use
in 1970 and the Air Force found
itself stuck with about 2.3 mil-
lion gallons of it. (Herbicide
Orange was a half-and-half
mixture of 2, 4-D and 2, 4, 5-T.
The latter was banned for a
number of uses years ago, and
the dioxin was a contaminant
from the  process used to
manufacture it.)
  One proposal to bury the
herbicide in Utah ran afoul of
former Governor Calvin L.
Hampton, who asked Federal
officials to drop the idea. His
administration earlier had tried
to show that Army nerve gas
killed some 6,400 sheep in
Utah in 1968, and State offi-
cials were understandably
leery of the new toxic. Another
plan called for diluting Herbi-
cide Orange and selling it to
South American farmers at cut-
rate prices, an idea that en-
countered objections by the
State Department. The Air
Force also met resistance with
a draft environmental impact
statement proposing to incin-
erate the  stocks on land in
Illinois  and Texas. Opponents
said this was technically un-
sound, environmentally danger-
ous and expensive, and the plan
was abandoned.
  Still another major alterna-
tive the Air Force pursued, at
EPA's insistence,  was reproc-
essing the herbicide to remove
the dioxin by means of special
coconut shell charcoal filters.
This was tried on a pilot scale
in Mississippi, and the experi-
ment was successful, but it
created a new problem: There
was no known way to destroy
the contaminated charcoal.
   In the meantime, however, a
relatively new technology for
managing toxic substances had
been gathering impetus in Eu-
rope. German and Dutch engi-
neers since 1969 have been
using at-sea incineration to
destroy organochlorine wastes.
(The release  of such com-
pounds to the environment is
undesirable because they are
very persistent and can enter
the food chain. Even small
quantities of  some types are
acutely toxic.)
  The technique employed by
Europeans to manage such
wastes involved specially
equipped ships that burned the
material at high temperatures
in the North Sea. The first of
these vessels was the Matthias
I, a small tanker of about 1,000
metric tons that had been fitted
with an incinerator and was
used by a German firm for half

a dozen years. A larger tanker
of 3,500 tons, the Matthias II,
was modified in the same way
and is still in service. Then in
1975 the Matthias III, a much
bigger tanker of 19,300 tons
was modified in a Germany
shipyard to perform similar
work. Matthias III was designed
to carry 1 5,000 tons of  liquid
waste in its tanks plus several
thousand 55-gallon drums on
its main deck. However, this
ship did not perform satisfac-
torily, and rather than invest
any further in modifications,
the company decided to take it
out of commission.
   But in the meantime the idea
of at-sea-incineration already
was being examined seriously
by several specialists in EPA as
a way of disposing of hazardous
toxics like Herbicide Orange.
These men included John P.
Lehman, Director of the Hazard-
ous Waste Management Divi-
sion; Russell Wyer, who had
been Specially appointed by
Kenneth Biglane, Director of
the Oil and Special Materials
Control  Division, to study the
technology; and Ronald A.
Venezia, EPA project officer for
environmental assessment of
organochlorine waste incinera-
tion, Office of Research and
   The ultimate answer to the
problem turned out to be the
M/T (for Motor Transport)
Vulcanus, a Dutch-owned ves-
sel that had been converted
from a cargo ship to a chemica!
tanker fitted with two large in-
cinerators at the stern. Unlike
Matthias I and II, the Vulcanus
was big enough to operate
worldwide. Twin diesels gave
her cruising speeds up to 13
knots and  she met the require-
ments of the Intergovernmental
Maritime Consultative Organ-
ization (IMCO) and the U.S.
Coast Guard for transport of
dangerous cargo by tanker.
   Operated by Ocean Combus-
tion Service, the Vulcanus had
many safety features, including
a double hull with 15 tanks in-
side the inner hull to carry the
waste liquid.  During normal
operation the tanks could  be
discharged only through the
incinerator feed system.
   The Vulcanus had been in-
cinerating wastes from Euro-
pean countries since 1972 and
had acquired considerable op-
erating experience. In late 1974
EPA issued a research permit
for incineration at sea of  4,200
metric tons of organochlorine
wastes from the Shell Chemical
Company's plant at Deer Park,
Tex. The wastes had been gen-
erated during the plant's pro-
duction  of vinyl chloride and
other  industrial products.
   The burn, conducted in the
Gulf of Mexico about 150 miles
from land, was monitored by
two research vessels for pos-
sible pollution of surrounding
monitored waters and also by a
specially equipped EPA aircraft
to measure air emissions
   EPA granted  permission for
incineration of another shipload
a month later with some correc-
tions in  monitoring, and in De-
cember  issued a third permit for
incinerating another 8,400 tons
of wastes.
   Based on these tests, the
Agency  determined that the
process did not result in any
significant adverse impact on
the environment, although some
modifications in the ship and its
operations were required.
Measurements of emissions
from the incinerator stacks
showed that more than 99.9
percent  of the wastes had been
oxidized, that is, destroyed, by
the intense heat.
   Observers found no measur-
able increases in concentra-
tions of  trace metals or organo-
chlorides in the surrounding
sea or in marine life, and no
adverse effects on migratory
   EPA determined that at-sea
incineration was a viable alter-
native to other means of dispo-
sal. When it was found that the
disposal of contaminated char-
coal canisters was not possible,
the go-ahead was given for us-
ing at-sea incineration to des-
troy the  Air Force stocks of the
Herbicide Orange. Two-thirds
of the Air Force stockpile was
stored at Johnston Island, a
lonely and remote speck in the
Pacific some 850 miles south-
west of Hawaii.  The other third
arrived there on the Vulcanus
July 11 last year from storage
in Mississippi.
   One of the most important
features of the ship was the
very high temperatures that
could be generated in the incin-
erators. The U.S. permit for
destruction of Herbicide Orange
called for a minimum operating
temperature of 1,250 degrees
Celsius (about 2,280
degrees Fahrenheit). But as
matters turned out, the temper-
ature during the burn actually
approached 1,500 Celsius
(2,732 Fahrenheit), hot enough
to melt steel, and more impor-
tant, also hot enough to destroy
the toxic materials. In fact
Herbicide Orange burned so
well that operators had to throt-
tle back on the flow to keep the
heat from  destroying the
   Along with the cargo, the ship
carried a special portable lab-
oratory on her deck just for-
ward of the bridge where spe-
cialists could study samples
and monitor instruments. Ela-
borate precautions were taken
to assure the safety of the crew
as well as of the surrounding
environment. In addition to nor-
mal equipment, for example,
all personnel within the inciner-
ator area had gas masks avail-
able for instant use and those
exposed to high temperatures
wore fire-fighter entry suits.
Pesticide gas respirators, port-
able monitors, Scott air packs
and even portable emergency
eye baths were on hand. No
workers were allowed to enter
the incinerator area without
wearing disposable protective
clothing, and upon leaving they
had to throw the clothing into
a barrel, take a shower, and
don fresh  coveralls. Contents
of the barrel were routinely
   Fortunately, emergency
equipment was never needed.
In three separate burns about
1,000 miles southwest of
Hawaii in July and August last
year, the Air Force supplies of
Herbicide  Orange were care-
fully incinerated without
   Instruments measured com-
bustion  effluent, and the crew
took wipe  samples of selected
areas on the ship to confirm that
no traces of the herbicides
found their way into living
areas. In a mop-up operation,
each of the tanks that had
stored the herbicide was rinsed
with diesel oil which was then
   In its official report to EPA
on the operation, TRW, Inc.,
which performed monitoring,
sampling and analysis to assure
compliance with the EPA per-
mit, declared, "Destruction and
combustion efficiencies meas-
ured during the Research and
Special  Permit burns met or ex-
ceeded  requirements. All other
conditions of the permits re-
lated to at-sea incineration
operations  were met, including
adherence to a comprehensive
safety plan."
  The significance of the John-
ston Island project, however,
extended far beyond destruc-
tion of the 10,400 metric tons
of Herbicide Orange. According
to Lehman, some 30 to 40 mil-
lion metric tons of toxic waste
are produced annually in the
United States, and the volume
is steadily increasing.
  At the same time, disposal
has become more difficult be-
cause of increasingly stringent
controls in the new Resource
Conservation and Recovery Act
to protect the environment.
  Long-term storage of these
wastes in above-ground tanks is
unsatisfactory in many cases
because of the potential for
leaks, accidental ignition,
and spills from natural disasters
such as earthquakes.
  So the at-sea incineration
offers another approach to dis-
posal of these potentially dan-
gerous by-products. Although
only about half of the annual
output of hazardous waste is
organic and amenable to in-
cineration, the experiments
demonstrate that under appro-
priate safeguards, at-sea incin-
eration can be managed safely.
As an indication of growing
interest by both government
and industry in this relatively
new procedure, the U.S. Mari-
time Administration has com-
missioned a cost study by Glo-
bal  Marine, (builders of the
Glomar  Explorer), of ship con-
version  for future incinerator
vessels. It is believed there are
enough  wastes to support the
operation of four such ships
under the U.S. flag. If true, then
an infant industry in safe, sea-
borne waste disposal appears to
be in the making. D

in  Environ-
An Interview With
Dr. David  P. Rail,
Director, National Insti-
tute of Environmental
Health Sciences
Could you explain briefly
the mission of NIEHS and
how it differs from other
organizations, such as
EPA, the National Cancer
Institute, and so on?
Let me point out first that we are
part of the National Institutes of
Health and I think that's the key
to understanding how our mis-
sion is different from the more
regulatory-oriented agencies
like EPA, or FDA, or OSHA, or
NIOSH. We try to understand in
basic biomedical terms how
environmental chemicals act to
produce their damage to human
health. We are basically inter-
ested in mechanisms. Now I
know that some people think
that studies on mechanisms are
ivory-tower and basically irrele-
vant to the urgent needs of
regulatory agencies. But it
seems to me they are the neces-
sary backup for effective, well-
balanced regulatory action.
  Stephen J. Gould, a brilliant
Harvard scientist, discussed
some years ago the fact that
scientists are reluctant to deal
with data, even though the data
seem very solid and reliable, if
they don't understand the basic
mechanism that appears to be
producing the data. He cited as
an example the fact that for
decades it's been known that
the West Coast of Africa and
the East Coast of South Amer-
ica fit almost perfectly, like a
jigsaw puzzle  cut-out.  But sci-
entists refused to accept this fit
because they couldn't under-
stand how these two continents
could have belonged to each
other at one time when they are
now over a thousand miles
apart. When the theory of plate
tectonics came along, the theory
that continents are on  shifting,
floating plates and can move
and bump against each other
and come apart, all of a sudden
everybody said those data are
nifty. Let's believe them. But
what the scientists needed was
the mechanism, the understand-
ing of why the data were there
in the first place. That is what I
call the comforting dogma—
that scientists like to be able to
understand what's going on
above and beyond just getting
  Mechanism studies have an-
other great importance to regu-
latory agencies. For instance,
they provide the basis for devel-
oping rational, short-term tests
for toxicity. One of the prob-
lems in regulating for human
health protection is that our
standard toxicity tests take lit-
erally years, are extremely
expensive in terms of dollars
and scarce professional staff,
and frankly are still at a pretty
crude stage. What we hope to
do with our mechanism data is
to be able to develop much more
precise, meaningful tests for
chemicals for predicting human
toxicity in much shorter time
frames. In addition to this basic
research, which is really the
essence of NIEHS, we do short-
term research. We are inter-
ested in pragmatic problems.
We have a large study under-
way on the toxicity of asbestos
ingested orally, which grew out
of the Reserve Mining Com-
pany's Lake Superior case. We
are supporting an excellent epi-
demiological study at Harvard
University on air pollution
levels and human health. We
feel that an imaginative mixture
of the basic mechanistic re-
search and relevant real-time
research, (meaning directly
relevant to PBB's and similar
problems) is the most effective
way to make the Institute strong
and exciting.
   We are different from the
other agencies also because we
deal with the entire spectrum of
environmental problems,
whether they be in the air, the
water, or the workplace, or
whether they be a result of a
mixture of a therapeutic medi-
cine and an environmental pol-
lutant. So our mandate is broad:
to look at all  aspects of those
chemicals that can come in con-
tact with people and might dam-
age human health. In addition
to chemicals we have small
programs on non-ionizing radi-
ation research, (i.e., microwave
effects) which I think will be
increasingly important in the
future, and on the harmful
 effects of  noise.
   Our current budget is around
 $65 million. We haveabout 366
full-time employees, and with
the part-time and post-doctoral
students, and so on, over 500
people work at our Institute
every day.
How many mice and rats
does your lab keep on
hand for tests?
About 20,000 in our current
excellent animal rooms. We are
building a new facility across
the street on a portion of 500
acres of land the Research
Triangle Foundation gave to the
U.S. Government that could
have up to 1 20,000 mice or
rats. When those quarters are
finished—they should be ready
in  1980—we are hopeful that
this will let us expand our pro-
gram significantly. Our new
building is on an artificial lake
which we will begin to fill in a
month or so,  and there is a
lovely site across the lake from
our building in the pine trees
that's reserved for the Environ-
mental Protection Agency.

You mentioned two
studies—oral asbestos,
and the noise study. Are
either of these being done
in cooperation with  EPA?
We work closely with EPA on
the noise, but there is no direct
collaboration. I am pleased that
EPA is contributing to the cost
of  the oral asbestos experi-
ments, and I think it is another
example of how we do work
very closely with the regulatory
agencies on matters of urgent
regulatory need. That study was
designed by an interagency
group with NIEHS, EPA,  FDA
and other scientists.

At one time in your career
you were very active in
the National Cancer Insti-
tute in the use of chemo-
therapy to meet the can-
cer challenge. Why  did
you change course and
take the environmental
Well,  I hope it was a well
thought-out philosophical
change in course. As I began to
look at the toxicity of anti-
cancer agents I began to be
concerned about how to pre-
dict for toxicity. Not for one or
ten or a hundred patients, but
hundreds of thousands to mil-
lions of people, and it seemed
to me that a totally unsolved
problem at that time, which was
close to ten years ago, was the
concept of population toxicity:
 I 8

An artist's rendition
Park, N.C.
of the National Institute of  Environmental HenHh Science building  under construe)              h  Triangle
 What about the danger of a
 chemical to which many if not
 most people in the country are
 exposed?  How do you predict
 or project  the toxicity to this
 enormous spectrum of well
 people, ill  people, males, fe-
 males, young, old, those on good
 diets, those on bad diets? And
 this concept of population tox-
 icity began to intrigue me, and
 that is really what led rne down
 to North Carolina and the Na-
 tional Institute of Environmental
 Health Sciences.

 With  enactment of the
 Toxic Substances  Control
 Act we have discovered
 there is a woeful shortage
 of toxicologists. Can you
 explain why that is and
 the NIEHS role in helping
 train new ones?
 The Office of Management and
 Budget decided in the mid-
 19 60's that we were training
 too many biomedical scientists
          and I happen to think there was
          some truth in that judgment.
          Unfortunately they did not look
          at some of the smaller special-
          ties within the biomedical sci-
          ences and as they cut back all
          training programs they also cut
          back our training program for
          environmental toxicologists,
          epidemiologists, and patholo-
          gists. In fact in 1975, our train-
          ing budget had fallen from
          about $5 million a year to $1.7
          million, and we were literally
          being phased out. I was very
          concerned about this. The sci-
          entists  at EPA were very con-
          cerned about it, and with help
          from the Administration, Con-
          gress put an extra $3.5
          million in our 1976 budget and
          we are now atabouta $5to $5.5
million a year level for training
toxicologists and scientists in
other fields. This will help. The
Conservation  Foundation, with
support from EPA  and NIEHS,
held a meeting to look at toxi-
cology and toxicology training.
They project a need for an addi-
tional 1,000 toxicologists over
the next three or four years with
modest  continued  support after
that time. Our training budget
for the next fiscal year has not
been authorized or appropri-
ated, but we are hopeful we will
be able to train even more toxi-
cologists in the future. The
shortage is very real and very
dramatic, and its continuation
can have nothing but dire conse-
quences for the Federal regula-
tory program as well as for
industry, which increasingly
wants to ensure that the chemi-
cals it produces are safe.
We understand that
NIEHS was instrumental
in funding work by a
physician, Dr. Philip S.
Guzelian, at the Medical
College of Virginia to
help remove Kepone
from the bodies of
workers at Hopewell
during the Kepone crisis.
Can you describe that and
comment on your  organi-
zation's ability to meet
future crises of this kind?
This was really very exciting.
We were, of course, aware of
the Kepone problem and I got
a phone call from Dr. Guzelian,
who said, "You know, I have
most of the Kepone patients on
my service at the Medical Col-
lege of Virginia." Dr. Guzelian
had been trained as a physician,
an internist, and a pharmacolo-

gist, and he said, "We Think
this would be an unparalleled
opportunity to look at the phar-
macokinetics, the fate and dis-
tribution and excretion of this
chemical in these twenty or
thirty people and try to see if
we can develop mechanisms to
help them rid their bodies of
Kepone." We were able to get
a sole-source contract for Dr.
Guzelian to get his work started.
This was truly sole-source,
since he had all the patients
that were ill of this particular
disease. We got that funded
within two or three months,
which is probably a record. He
then applied for a standard NIH
research grant through us and
that was funded, and he now
has a long-term project sup-
ported by our grants mechanism
to look not only at Kepone but
the possibility of eliminating
other agents.
  His project was successful.
He  discovered, which had not
been known before, that a sig-
nificant amount of the Kepone
appears to be excreted in the
bile, or at least somewhere in
the gastrointestinal tract and
that if you administer a binding
agent, called cholestyramine,
this agent can bind the Kepone,
prevent it from being re-
absorbed into the body, and you
can increase the excretion about
seven-fold. He has done this in
a double-blind study and not
only do the chemical  levels of
the Kepone go down in the
bodies of the patients, but their
symptoms are going away.
They are becoming less sick.
This, to me, is one of the great
success stories of well-applied
basic research in the environ-
mental field.
Assuming that we might
have another Kepone-type
crisis in the future, do
you have a mechanism
within your organization
to give a quick grant to an
institute for research?
A quick contract under certain
circumstances. The contracting
procedure is now very complex
and, as a matter of fact, if  you
cannot fulfill the narrow defini-
tion of sole-source, it becomes
very difficult to rapidly fund
people doing research of high
urgency in a critical area of
environmental health. And I
think we should look for new
means to develop the rapid
support mechanism.

Do you think it would be
useful for the government
contracting procedures
be  modified so that
agencies like yours can
grant money to re-
searchers rapidly?
I think it would be wonderful if
there could be a mechanism
whereby the various agencies
involved in  environmental
health, such as NIEHS, EPA,
and some of the others could
have access to a small contin-
gency fund each year which
could be used very rapidly to
explore situations where there
are real human health problems
and it is important to move rap-
idly to study and solve them,
such as Kepone, PCB's, and
the PBB problem in Michigan.

On that subject,  are you
comfortable with the  laws
now in place to control
environmental  hazards,
or  do you believe there
should be amendments or
new laws?
I think now we are really in
pretty good shape. The Toxic
Substances Control Act is really
a landmark law. It is extraordi-
narily complex, as I am sure
everybody at EPA understands.
I guess I am conservative
enough to suggest that I would
like to see how implementation
of the Act works before we rec-
ommend any drastic changes.
If you took back over the last
ten years, the growth of the
ability of the government  to
regulate toxic chemicals,  other
than food additives and drugs,
has gone from about zero to
potentially close to one-hun-
dred percent, This is a dramatic
accomplishment and I  think
having bitten off this large
mouthful, we probably ought to
try to digest  it and see how it
works before we talk about new

The Act will require
much  more testing of
toxics in laboratories, but
industry often has ques-
tioned the validity of
comparing results of tests
on mice to the cancer
hazards of a chemical to
humans. Can  you com-
ment  on this?
Well I am very concerned about
that argument for basically two
reasons. The first is almost a
moral issue. If you don't test
chemicals in laboratory animal
situations you have no choice
but literally to test them on the
human population, to make the
people exposed to the chemi-
cals "guinea pigs," which
means you have to have (if a
chemical is toxic) a full round
of human diseases, and pos-
sibly, death  and/or disability,
before we know that chemical
is toxic and can take appropri-
ate regulatory action. It seems
to me modern society cannot,
will  not, and should not accept
using society itself as the test
animal. The  alternative is to use
laboratory animal tests to pre-
dict the toxicity and then take
regulatory action on the basis
                                                            Dr. Philip S.  Guzelian of the
                                                            Medical  College  of  Virginia,
                                                            who has  done  extensive  re-
                                                            search in toxicology, developed
                                                            ,1 method for  treating  Kepone
of that prediction. I think the
evidence is increasing that
laboratory animals predict very
well—not perfectly,  but then
nothing in biology is perfect—
for toxicities in the human pop-
ulation. It has only been recent-
ly that we have begun to take a
hard fook at the results of lab-
oratory animal tests and the
results when the human popu-
lation is inadvertently exposed
to the same chemicals. Fortu-
nately the latter doesn't happen
that often. We are finding that
the  results are surprisingly
  The International Associa-
tion for Research on  Cancer at
Lyons, France, has now looked
at close to 400 chemicals for
carcinogenicity. With roughly
half of them, they feel,  there is
evidence at the animal  level for
carcinogenicity, but with most
of those there is absolutely  no
information one way or the
other as to whether these chem-
icals are carcinogenic in peo-
ple. On the other  hand, for 26
of them there is clear evidence
that the chemicals are carcino-
genic in humans. Now six of
those are unknown chemicals
from  industrial processes, and
in each of those industrial
processes laboratory animals
have identified carcinogenic
components. So that for those
six, there is a good relationship
between animals  and humans.
For 1 6, there is also a clear
positive effect in  laboratory ani-
mals, and a clear positive effect
in people. There are four left
where there is reasonably good
evidence at the human level.
For two of these, arsenic and
benzene, there is beginning
evidence at the animal level
that arsenic may be a co-carcin-
ogen and there are two studies
with benzene, as yet unpub-
lished, that show it probably is
a carcinogen in animals. The
other two are chemicals which
simply have not been tested in
animals yet. So that suggests
there is really very good con-
cordance between laboratory
animals and human results. I
think we can begin to put more
confidence in animal tests.

Can you explain the
Ames Test for the general
The Ames test uses bacteria
which have been genetically
engineered to be very sensitive
to mutations. Mutations are a
way of descrjbing what hap-
pens to the  DNA, which is the
way life reproduces itself with
fidelity. A mutation occurs
when that process is messed
up. The reproduction  from
mother-cells to daughter-cells
is no longer proper. There is a
change, and that change is
mutation. Most  scientists now
believe that most cancers have
an origin in a mutation in a cell
in the body somewhere, due
either to chemicals or to ioniz-
ing radiation, or to ultraviolet
radiation. That is the so-called
initiating event  in the cancer
process.  It  is likely that other
things may have to happen for
that to develop  into a clinical
tumor or cancer. The initiating
event is the disturbance of the
DNA in trying to send informa-
tion from one cell to the next,
and that is  called a mutation.
These bacteria have been de-
signed so that they pick up in
a very simple way these

Is the Ames test chiefly
useful to  your laboratory
as a quick screening  or
has it broader value than
I think the Ames test will have
enormous value. We use it  all
the time. There  are problems
with it right now, which I don't
think are well appreciated. The
problem is  there is no one Ames
test. The specifications of the
test, which strain of bacteria,
details of the nutrient broth,
details of adding the micro-
somal mixture are still flexible
and are still being studied. It is
going to be very useful, but we
need to begin to apply quality
control procedures to the Ames
test to standardize it in one of
three or four or five forms and
then begin to do this very care-
ful comparison between the
results using chemicals in the
standardized Ames test as well
as in laboratory animals, and
from what we know, in people.
A good example of what 1 am
talking about is the fact that
initially the Ames test was neg-
ative with respect to saccharin.
As you adjusted the conditions
of the tests, made changes, you
showed that under certain cir-
cumstances saccharin  could
become positive in that particu-
lar Ames test. So I think with
the Ames test and a number of
the other  very promising assays,
like sister-chromatid exchange,
and some of the others, we
need to standardize them. We
need to do the testing  of the
test to see how predictive it is.
I think it  has a great future.

Is NIEHS now doing tests
on saccharin, and if so,
does it appear now that it
is the impurities  in  the
saccharin that are the
No, 1 don't think we are. A lot of
other laboratories are.  It is still
intensively being studied and
the saccharin story  is fascinat-
ing. The so-called Canadian
study really was not addressed
to whether saccharin caused
cancer in the bladder of rats.
That had  really been well estab-
lished in  two or three previous
studies. The problem it ad-
dressed was the fact that there
was at that time, and probably
still is, a contaminant in saccha-
rin, orthotoluene sulfanomide,
which many people thought
was the carcinogen. The Cana-
dians spent most of their efforts
trying to  determine whether
the contaminant was a carcino-
gen. The  importance of their
study was that the contaminant
clearly was not a carcinogen,
in a well-designed,  well-con-
trolled test. This immediately
validated the  two previous
positive American studies for
saccharin. The Canadians also
threw in another group of ani-
mals given saccharin that in
fact absolutely duplicated the
two previous  American studies.
There are still probably other
contaminants in saccharin and
they are being intensively
studied, and I must say today I
don't know whether one of
these contaminants is the
mutagen-carcinogen, or
whether it is saccharin itself.
Do you think it would be
useful to merge the var-
ious environmentaHy re-
lated agencies such as
yours, EPA, and the en-
vironmental functions of
others, such as the Food
and Drug Administration,
or are they more effective
as separate independent
1 think you can make good argu-
ments one way or the other. I
have been impressed as I have
lived within the bureaucracy
that there is importance and
strength to diversity. Each of
the agencies really has a unique
mission and  needs the opportu-
nity to focus on that  mission.
Whereas  FDA is concerned
about drugs and food additives,
EPA is concerned about air pol-
lutants and water pollutants,
pesticides and toxic substances
and, although many of the
techniques and the methodol-
ogies are different, there needs
to be a focus on the particular
chemicals of concern. I think
the diverse organization allows
for strength in focusing on par-
ticular concerns. At the same
time, I feel there needs to be
much stronger coordination
and information exchange be-
tween the relevant agencies,
and this has moved a long way
in the last six or seven years.
Within HEW we have the Com-
mittee to Coordinate Toxicol-
ogy and Related Programs,
which has had EPA representa-
tives on it since Day One, The
Interagency Regulatory Liaison
Group is now functioning very
effectively. So I think I would
recommend diversity but with
effective coordination of the
various agencies.
Recently you expressed
some concern over the
amount of cadmium in the
environment and its effect
on humans. Do  you think
we need an EPA standard
on this and a  curb on its
use by the Defense De-
partment and others?
i think it's a little early to pro-
pose a standard. I think we still
need better information on
emission sources.  We need
better information on the trac-
ing of cadmium through the
environment and how it ulti-
mately gets to human beings.
I think we need that information
fairly urgently and I don't think
we are quite at the stage where
we know how to control cad-
mium. We need the information
dealing with how it moves from
its production and use through
the environment to people be-
fore we can find those critical
areas in that flow of cadmium
that can be controlled.

In what way is cadmium
hazardous to humans?
There is some evidence that it
may cause cancer of the pros-
tate. It does damage the kid-
neys and it is implicated in
causing hypertension. With
hypertension being one of the
major killers today, it could
have enormous importance,  but
I don't think we know quite
enough about it to talk about
standards. I  think we need to
learn quite a bit more about its
effect on people and how it
reaches them.

What do you  see as the
greatest challenge in en-
vironmental health  in the
next  decade?
I think it is what I talked about
earlier. Developing and validat-
ing a series of efficient tests
using laboratory animals or
laboratory systems so that in
a reasonable length of time, and
with a reasonable amount of
money we can look at a new
chemical and suggest that it
will likely be safe when it is put
into the environment by what-
ever commercial process is
used. I think that is the urgent
need—to develop predictive
tools for chemical toxicity. [ ]

This interview was conducted
by Truman Temple, Associate
Editor of EPA Journal.


More Toxi-
   Environmental health legis-
   lation, particularly the
Toxic Substances Control Act,
has created major new de-
mands for lexicologists. How
many are there at present? How
many are needed? Is there a
gap between need and supply?
   To find out the answers, the
Conservation Foundation  or-
ganized a workshop with repre-
sentatives from the chemical
industry, environmental organi-
zations, Federal and State
agencies, academic institu-
tions, and the press. Results of
their discussions were pub-
lished last April in a report,
"Training Scientists for Future
Toxic Substance Problems."
Sponsors of the workshop were
EPA, the National Institute of
Environmental Health Sciences
(NIEHS), the Chemical Industry
Institute of Toxicology, and the
   According to the report, it's
estimated that about  5,000
professionals now work in the
field of toxicology. There is an
immediate need for about
1,000 additional professionals,
of whom 500 would be senior
professionals with doctoral or
postdoctoral training in toxi-
cology. Some consider these
projections too conservative.
But in any case, they suggest
the magnitude of the problem.
   One thousand additional tox-
icologists may not appear to be
a very large figure, but it repre-
sents about 20 percent of the
present professional work
force. In addition, there is a
continuing need for new men
and women to replace those
who leave each year because
of retirement, career changes,
and so on. It's estimated that
this replacement need is about
200 professionals each year, or
half that number of  senior
   NIEHS is the major institu-
tion through which training
grants are made in toxicology
and other environmental  health
sciences. The number of pre-
doctoral and postdoctoral
NIEHS grants (including  re-
newals) declined from 409 dur-
ing Fiscal Year 1971 to 194
during 1976. The 1977 figure
is 331. Predoctoral training
requires an average of about
three years to complete (three
to four years after a bachelor's
degree or two to three years
after a master's degree);  post-
doctoral training takes an aver-
age of about two years. So the
1971  level of trainee support
through NIEHS, if continued,
would produce about 1 50 new
senior professionals per year
orabout 135 peryearforthe
1977  figure.
   "Such statistics confirm that
current training programs are
inadequate to cope  with the
anticipated bulge in demand,"
the report declared. "This
shortfall is a serious national
problem that deserves  prompt,
high-priority attention, both by
infusion of adequate training
funds and by a variety of  other
strategies. . . ."
   The problem of expanding
toxicology training  programs,
while critical, is strictly limited,
both in size and time. The re-
port warned that it would be
unfortunate to set up training
programs that ignore the lim-
ited nature of the need and
produce an excessive number
of highly trained specialists, a
situation that occurred in train-
ing aerospace engineers in the
   "There is a very large price
to pay for not giving priority to
funding of toxicology training:
that price is mistaken decisions
by government and industry
about the marketing and use of
chemicals," the report empha-
sized. "Decisions on environ-
mental contaminants, toxic
chemicals, and other environ-
mental health issues will be
made regardless of the level of
knowledge and professional
skill brought to bear on them,
because, through legislation,
the public demands it. If train-
ing is inadequate in quality—
or if insufficient numbers of
trained toxicologists are avail-
able—the price for society can
be enormous. Not only are
poorly conceived and adminis-
tered chemical testing pro-
grams expensive, but the cost
may also be measured in lives
or jobs unnecessarily lost."

Conferees at the workshop
agreed that recruitment of out-
standing trainees is essential
in meeting the need for good
toxicologists. The challenges
and rewards of a career in en-
vironmental toxicology may
not be known or appreciated by
the public. Recruitment of
trainees also appears to have
suffered from widespread ad-
verse publicity involving the
reliability of test results in a
few situations. Steady funding
is critical both for trainee sup-
port and for continuity in devel-
oping competent and respected
training centers, they noted.

Professional Challenges
The study of environmental
contamination problems—
whether the effects of chemi-
cals on animals or people or the
movement of contaminants into
the human food chain—offers
intellectual and professional
challenges, the report declared.
   "Toxicology also has a
strong moral appeal as a career
with clear potential for social
benefit in its concern with pre-
vention of disease and dis-
ability. And toxicologists have
the opportunity to see their
work used in the social judg-
ments applied to toxic chemical
questions—for instance, risk/
benefit analyses and other
kinds  of decision making,"
the report stated.
   From a purely practical view-
point, toxicology was high-
lighted as an attractive career
because TSCA and other new
laws have created many pro-
fessional opportunities.
   The conferees suggested
that toxicologists have the
opportunity to spread a  sense
of excitement about the pro-
fession, directed toward other
professions, undergraduate,
graduate and high school stu-
dents. While this could  over-
stimulate interest and lead to
over-expansion if carried too
far, the need for new toxicol-
ogists is great enough to war-
rant a  major effort, the report
   Professional societies have
a real  opportunity to increase
public awareness of toxicology
as a profession, and they
should consider holding meet-
ings with chemists, pharma-
cologists, and other associa-
         Contmued on page 37
                                                                            EPA JOURNAL

Controlling Toxic
Continued from page 6
could do much in the future, to
prevent such'errors, per se.
The possible exception to this
is that TSCA gives us the au-
thority to require special label-
ing of toxic chemical contain-
ers transported or otherwise
used in commerce. We now are
developing a labeling provision
under TSCA. If such a provision
had been in place at the time,
the Michigan PBB tragedy
might have been prevented.
   Kepone, of course, involved
willful violation of existing law.
TSCA will enable us to identify
those areas where Kepone-like
substances are being produced;
we will be able to alert regional
and State officials that a danger-
ous chemical is being produced
at a given site, and that they
may want to do some monitor-
ing to see if any of it is escap-
ing into the environment, so in
that sense, TSCA will help. But
neither TSCA nor any other law
can be effective in the case of
willful violations.

Are you comfortable  with
TSCA, or are there some
improvements or amend-
ments you would like to
Well, I think we need to have a
little more experience working
with the Act before we start
talking about amendments. But
when we have some experience
under our belt and learn that
some parts of the Act may not
operate the way we think  Con-
gress intended, we certainly
will approach Congress about
amending it; it's just too  early
to do so now, however.

Is it fair to characterize
TSCA as a law that
covers some of the loop-
holes in the other laws,
plus gives us a broader
Yes, that's a good way  of  put-
ting it. It's both an umbrella
and a gap filler. It covers a
whole series of other laws, and
at the same time fills in the gaps
among them.
What about "turf" prob-
lems with other agencies?
Since some other agencies
also regulate toxics, do
you foresee jurisdic-
tional disputes?
There are a couple of things that
can be said on this subject. One,
of course, is that the other
chemical regulatory agencies—
OSHA, FDA, and the Consumer
Product Safety Commission—
have joined EPA as members of
the  Interagency Regulatory Liai-
son Group. The very reason for
this group's existence is to
avoid turf problems, and to take
advantage of common knowl-
edge and develop consistent
approaches to dealing with
chemicals. Considerable effort
is going into this group to help
us work together more effec-
tively. I think this has been very
  The other thing is that Con-
gress recognized that there are
potential overlaps among TSCA
and toxics-related  portions of
other statutes, and that these
overlaps should be avoided. So
section 9 of TSCA  requires us
to defer to other agencies or to
other laws, if deferral repre-
sents the best way  to deal with
the problem. We can't just move
in and poach on someone else's
territory. We are obligated to
assess the problem and then to
decide whether the most effec-
tive solution  is through TSCA
or some other law. Congress
was sensitive to that, and pro-
vided a  mechanism within
TSCA for avoiding problems of
this kind.
Getting back to  some of
the international aspects
of toxic substances con-
trol, is there a mecha-
nism within TSCA to
handle chemicals im-
ported from other
Yes. As I mentioned earlier,
importers are treated the same
under TCSA as domestic manu-
facturers. This is why there is
so much international interest
in TSCA. Any regulation that
we promulgate for the U.S.
market applies to foreign
importers, as well.

If I am a Japanese ex-
porter and I'm bringing
in a  boat-load of arsenic,
what will U.S. Customs
officials at the dock do?
Assuming that we had decided
to regulate arsenic, they would
be on the lookout for arsenic
shipments. EPA's own enforce-
ment people would too. If Japa-
nese  or any other foreign manu-
facturers develop some new
chemical, we will have arrange-
ments with customs and our
own enforcement people to  as-
sure that the chemical is not
introduced without proper noti-
fication under TSCA section 5.

Is there any way to con-
trol  our exports of toxics
to protect other
Congress decided that it
wouldn't give us the authority
to prevent the export of chem-
icals that we think are too dan-
gerous to be used in the United
States. The only way we can
deal with that is if the actual
production of that chemical for
export purposes poses such a
risk that the chemical should be
banned within the U.S. How-
ever, TSCA directs us to notify
foreign countries if chemicals
we have acted against are being
exported. Congress decided
that it's not appropriate for EPA
to tell a foreign country that it
should not use a chemical, but
it is entirely appropriate that
we tell them what we think the
problems are with the chemical,
and let them make up their own
minds. The pesticide law is very
similar to the toxics law in this
respect, I might add.

TSCA has some very
powerful penalties, in-
cluding up to $25,000 a
day  and a year in prison
for some violations. Is
there any way to  assure
the small chemical com-
pany official that he or
she won't be put in leg
irons for some minor in-
fraction under TSCA?
I can't speak directly for the
Assistant Administrator for
Enforcement, but I think we will
take a common-sense approach
to enforcing the Act—one that
is firm but also recognizes that
there may be unique situations
that don't require as stiff or
stringent approaches as others.
That characterizes EPA's en-
forcement program generally
—-tough but realistic, sensitive
to special concerns.

The public is hearing so
many stories these days
about everything  causing
cancer—like the recent
story  on fried hamburgers
as carcinogens. Is there a
danger they may not be-
lieve us any longer? Are
you worried about
whether the public will
stop supporting the effort
to control toxic
This is a real problem, and a
real concern to me personally.
There are a couple of aspects to
it. One is that it appears the
public wants to make  its own
risk-benefit decisions in situa-
tions where individuals have
personal  control—such as
smoking, using saccharin, or
even eating hamburgers. EPA,
though, is concerned about  in-
voluntary  exposure to chemical
risks that are unreasonable. The
public has generally shown that
it doesn't want to be exposed
to risks it doesn't necessarily
benefit from or have any direct
control over. There's a big dif-
ference between exposure to a
naturally-occurring risk, such as
aflatoxin, and exposure to risks
that do not occur naturally and
are introduced by human
activity. By definition, one has
to live with some naturally oc-
curring risks.  D
This interview was conducted
by Leighton Price, OP A Asso-
ciate Director for Toxic Sub-
stances; Charles Pierce,
Editor, and Truman  Temple,
Associate Editor, of EPA

with Japan
By Kirk D Maconaughey
 Ihe U.S. Government will
 ' host the Third Annual Joint
Planning and Coordination
Committee Meeting this month
with Japan, a country that led
the world in enacting broad
toxic substances control legis-
lation. Deputy Administrator
Barbara Blum assisted by Alice
B. Popkin, Associate Adminis-
trator for International Activ-
ities will be the U.S. Chairman
at the September 11-13  meet-
ing, which will be held at the
Department of State. Blum led
the delegation at last year's
meeting which was held in
Tokyo. Hisanari Yamada, Di-
rector General of Japan's
Environment Agency, will lead
his country's delegation.
   Although formal cooperation
in environmental matters dates
back to August 5, 1975, when
the bilateral environmental
agreement was signed, the
United States and Japan have
enjoyed a much longer history
of working together. Consider-
ing our close political and eco-
nomic ties with Japan, and the
fact that we face many common
environmental  problems, it is
not surprising that cooperation
in this and related areas  dates
back many years.
   In 1964, for example,  the
two countries established the
US-Japan Cooperation Program
in Natural Resources.  It was
from this program that the
Environmental Agreement

Kirk Mnconaughey is the U.S.
Executive Secretary for the US-
Japan Environmental Agree-
ment and is n member of the
Office of International
emerged. Informal cooperation
on environmental topics also
has been pursued at other
levels. In 1971, Russell Train,
at that time Chairman of the
Council on Environmental
Quality, met with Japanese
officials to discuss ways in
which the two countries could
broaden the scope of their
environmental cooperation. In
the context of these discus-
sions, regularly scheduled,
high-level meetings were ar-
ranged for the purpose of
exchanging technical informa-
tion. With the establishment of
the bilateral agreement, these
meetings have been expanded
and are now called the Joint
Planning and Coordination
Committee Meeting. The pur-
pose of the Joint Committee
Meeting is to discuss major
environmental policy issues
relevant to both nations, to
coordinate and to review activi-
ties under the Agreement, and
to make necessary recommen-
dations to the two governments
to implement  the Agreement.
   The US-Japan Agreement is
one of nine bilateral environ-
mental agreements in which
EPA participates. These envi-
ronmental agreements  are in
turn part of much broader
science and technology agree-
ments between the United
States and other nations. Under
the broad science and technol-
ogy agreement between the
United States and Japan, there
are nine separate agreements,
the Environmental Agreement
being one of the most active.

Economic Power
Japan has been called the
world's most rapidly changing
society. Although somewhat
small in terms of land mass,
there can be no mistaking
Japan's importance  in the world
economy. Over the past quarter
of a century, the country has
successfully mounted an indus-
trial and development campaign
which has made her the world's
third largest economic power.
This same tremendous indus-
trial  and technological surge
which has resulted in Japan's
recent prosperity also accounts
in part for her environmental
   To begin dealing  with these
concerns Japan established its
Environment Agency (EA) in
1 971. EA has the task of setting
and  implementing the country's
   Sewage Treatment

   Management of Bottom
   Sediments Containing
   Toxic Pollutants

   Identification and Control
   of Toxic Substances
   Air Pollution Related

   Photochemical Air Pollution
   Stationary Source Air
   Pollution Control Technology

   Automobile Pollution Control

   Solid Waste Management

   Health Effects of Pollutants
                                 Technology for Closed
                                 Systemization of Industrial
                                 Waste Liquid Treatment
 U.S. Chairman
 Frank Middleton
 MERL-Cincinnati, Ohio

 Dr. A. F. Bartsch
 ERL-Corvallis, Oregon
 Dr. Marilyn Bracken
 Office of Toxic Substances
 Washington, D. C.

 Dr. Herbert Wiser
 ORD-Washington, D. C.

 Dr. A. P. Altshuller

 Richard Stern
 Dr. F. Gordon Hueter

 Dr. Eugene Berkau
 MERL-Cincinnati, Ohio
national environmental policies.
In addition to these respon-
sibilities, EA administers na-
tional programs in the areas of
nature and park conservation.
Over the past seven years, EA
has worked diligently to im-
prove japan's environmental
quality.'Major programs have
been enacted to improve pollu-
tion controls in both air and
water. A significant percentage
of Japan's pollution abatement
technology is directed towards
four major categories: desulfur-
ization, dust collection, indus-
trial wastewater treatment, and
sewage treatment equipment.
Great strides have been made
in reducing pollution levels of
sulfur oxides and nitrogen ox-
  In 1976 the Organization for
Economic Cooperation and
Development (OECD) com-
pleted a survey on the environ-
mental policies of Japan. In its
report OECD stated that Japan
has established a successful
environmental program. Im-
pressive pollution/abatement
programs have been  success-
fully introduced and  pollution
trends  have been reversed. In
such areas as air quality and
toxic chemicals, the  OECD con-
cluded that environmental
quality has greatly improved.

Information on Toxics
Much useful information has
been exchanged at the US-
Japan Joint Meetings in the
past three years. It was in these
sessions that we learned first-
hand of Japan's experiences in
controlling PCB's under its new
Chemical Substances Control
Law. At the second meeting,
the two countries discussed
respective experiences in deal-
ing with and implementing na-
tional toxic substances control
  In addition to policy level
discussions each of the individ-
ual  projects under the Agree-
ment is reviewed during the
meeting. EPA, the State De-
partment, and the President's
Council on  Environmental Qual-
ity (CEQ) are the principal U.S.
agencies that participate. EPA
has primary responsibility for
managing ten projects. (See
         Continued on page 33

Environmental Almanac: September 1978
A Glimpse of the Natural World We Help Protect
   Farmers in the mountainous
   areas of Kenya in equa-
torial Africa are now busy
harvesting  as many flowers as
they can from the pyrethrum
plant, a member of the chrysan-
themum family sometimes re-
ferred to as the "death daisy"
because of its effectiveness
as an insecticide.
   At present there is a short-
age of pyrethrum because there
have been  unusually heavy
rains in Kenya, the main pro-
ducer. Kenya normally has two
rainy seasons, a  short one in
May and June and a long wet
   As a result the thousands of
farmers who grow this flower
on small plots are trying to
harvest as  many of the blooms
as possible before the arrival
of winter.
   After being picked, the
flowers are dried in the sun.
A flower extract  is then shipped
to the United States and other
countries.  The powder ob-
tained from the dried flower
 heads provides the potent
   Another factor contributing
to the current world shortage
 of natural pyrethrum is that the
 prices of coffee, tea, corn, and
 other crops raised in Kenya
 have gone up more swiftly than
 the government-controlled
price for this natural insecti-
cide. However, pyrethrum is
still one of Kenya's main agri-
cultural export crops.
   In addition to the approxi-
mately 85,000 farmers in
Kenya who raise pyrethrum,
there are farmers in Tanzania,
Rwanda,  Zaire, New Guinea,
Ecuador, Brazil, and Japan who
grow this flower. But Kenya
has dominated the world
   Pyrethrins, the bug-killing
substance obtained from the
flower, are practically non-toxic
to warm-blooded animals but
have a very rapid "knock-
down" effect on many insects.
   The pyrethrins break down
quickly when exposed to light
and their effect is fleeting.
They can be stabilized, how-
ever, and their effect intensi-
fied (synergized) by the addi-
tion of piperonyl butoxide and
other compounds.
   Although  the flower is often
grown  for its decorative value
in the United States and many
other countries, the plant will
produce  satisfactory amounts
of the  insecticidal substance
only if grown under certain
   Effective generation of the
pest-killing chemical is only
assured if the plant is grown in
a nearly  continuous Spring-like
climate with no frost and with
nearly equal day and night
intervals, conditions found in
the uplands of Kenya.
  Attempts made to grow
pyrethrum as a commercial
crop in Colorado and other
locations in the United States
have been generally aban-
doned. In addition to the
exacting climatic conditions
required to grow pyrethrum
for its pesticidal uses, the high
cost of the labor needed to
pick the flowers just at the
right time has also discouraged
attempts to grow it in the
United States.
   The commercial use of pyre-
thrum is believed to have origi-
nated in Persia. The fame of
these peculiar flowers spread
after someone noticed dead
insects surrounding flowers
which had been discarded
after they withered.
   The pyrethrum insect pow-
der was first imported into this
country in 1 860, according to
a book "Pyrethrum, the Natural
Insecticide," edited by John E.
   This work contains an evalua-
tion of pyrethrum by Emil M.
Mrak, a noted scientist. Mrak
said that pyrethrum is one of the
earliest insecticides and "con-
trols certain insects as effec-
tively and more safely than
most of the currently used
synthetic organic insecticides.
There is no evidence of harm
to humans, domestic animals,
or wildlife, when used as
  The shortage of natural
pyrethrum has helped to stimu-
late interest in the pyrethroids,
man-made imitations of this
natural pesticide. Last summer
EPA gave emergency  permis-
sion to 14 States to allow cotton
farmers to use five experimental
insecticides, including three
new pyrethroids, to help com-
bat serious outbreaks of de-
structive caterpillars.
  Approximately 4,000 of the
35,000 pesticides registered
with EPA contain pyrethrum or
synthetic pyrethroids.
  Hopes that the natural  pyre-
thrum could replace many
dangerous pesticides have  not
been fully realized because of
growing problems, cost and
efficacy factors. At-
tempts to fully duplicate this
natural product  have not been
  Scientists have reported that
pyrethrum is so complicated a
substance that it has evaded
complete analysis. They  have
noted that its very complexity
may be responsible for the in-
ability of insects to develop
resistance to it.—C.D.P.  fl

in Drinking
By Victor J. Kimm
   Are organic chemicals in
     the Nation's drinking
water a cancer risk or not?
EPA says they are. The water-
works industry generally says
such dangers are unproven.
  EPA set off the debate last
February when it proposed
regulations to start limiting the
amount of organic chemicals in
drinking water. The controls
would initially apply to public
water systems serving over
75,000 people. The waterworks
industry has generally opposed
the standards.
  The cancer risk question is
the critical one for EPA. Under
the Safe Drinking Water Act,
the Agency must set standards
if there is such a health danger.
The objective is to reduce the
risks to the extent feasible.
   In proposing the standards,
EPA is convinced the risks are
there. The Agency feels that
organic chemicals in drinking
water pose a big enough health
problem to justify action under
the law. EPA realizes though
that details of the proposed
rules may be modified based on
public comments.
   The health basis for the pro-
posed EPA standards is sup-
ported by Federal agencies
experienced in dealing with
environmental carcinogens.
The agencies include the
National Cancer Institute, the
National Institute of Environ-
mental Health Sciences, and the
Food and Drug Administration.
The approach EPA is taking in
the drinking water proposal has
evolved as these and other
health-oriented agencies have
wrestled with the problems of
regulating human exposure to
   Several important scientific
conclusions about the nature of
cancer have played a role in
this evolution. First, there is
the simple fact that exposure to
chemicals can cause cancer.
The first evidence of chemical
carcinogenesis in humans dates
back to 1 775, when Percival
Pott noted that there were high
rates of scrotal cancer in men
who had been exposed to soot
as chimney sweeps. During the
20th century, a number of in-
dustrial chemicals, such as
benzidine, asbestos, and vinyl
chloride, have been shown to
produce cancer in workers
exposed to high levels, in
addition, it is generally agreed
that cigarette smoking and
excessive exposure to sunlight
can cause lung and skin cancer,
   Second, there is significant
evidence that environmental
rather than genetic factors are
causing a significant amount of
human cancer. A classic epi-
demiological study was done
of Japanese immigrants to the
United States and their de-
scendants. Japan has high
rates of stomach cancer and
low rates of colon cancer, com-
pared to the U.S. When the
Japanese immigrated to the
U.S., their rates of stomach
cancer fell and their rates of
colon cancer increased. Among
their children, the difference
was even more marked: closer
to the U.S. pattern and further
from the Japanese pattern.
   Something about the U.S.
diet,  lifestyle, or environment
produces lower rates of stom-
ach cancer and higher rates of
colon cancer than Japan. We
don't know what these causa live
factors are but we can presume
that it is something in the en-
vironment. (The term "environ-
ment" here refers to everything
humans are exposed to, includ-
ing such things as cigarette
smoking, food, and sunlight, as

Victor J. Kimm is EPA's Deputy
A ssistant A dministrator for
Drinking Water.
                                                                                                      EPA JOURNAL

well as the results of environ-
mental pollution in the usual
   Third, scientists have devel-
oped methods for testing sus-
pected carcinogens in labora-
tory animals. This approach
seemed necessary. Studies of
cancer patients have been able
to identify only a small number
of human carcinogens. Also,
our society doesn't allow inten-
tional testing of humans with
suspected carcinogens. So
some method was needed to
test the thousands of existing
chemicals as well as the new
ones that are constantly  being
   Although the differences
between humans and rats and
mice introduce uncertainty in
the use of animal data, the test
results have been well con-
firmed: of the known human
carcinogens, all but a few also
cause tumors in laboratory ani-
mals. These tests have been
criticized for using doses much
higher than those actually en-
countered by people. The high
doses are necessary to produce
a response in enough of the
animals so that conclusions
can be reached without requir-
ing thousands of animals to be
tested. Additionally, the size
of the dose is less important
than its effect: if the result is
cancer and not simply an over-
burdening of the animals' sys-
tems, there is reason for  con-
cern. In view of the conclusion
discussed below that even very
small doses of carcinogens
carry some risk, the animal
tests at high doses are valid
for indicating the presence of
a cancer risk and the relative
potency of the chemical  tested.
   In the case of organic  con-
taminants in drinking water,
there is also a series of human
epidemiological studies  that
have attempted to relate high
human cancer rates to indica-
tors of such contamination.
This research has generally
shown such  a relationship.
Such studies are difficult to
interpret because other factors
are also likely to be present in
the large cities that have high
levels of organics in their water.
However, the fact that the re-
search does show a relationship
reinforces the concern about
organic chemicals in drinking
 water, especially since some of
 the organics cause cancer in
 animal tests.
    Finally, and perhaps the most
 controversial, is the conclusion
 by the mainstream of scientific
 thought that there is no safe
 level for a carcinogen and that
 any exposure, no matter how
 small, will result in some risk of
 cancer. The reason for this con-
 clusion is that cancer seems to
 be the result of a small number
 of discrete events in the struc-
 ture of a single cell which trans-
 forms it into a cancer cell that
 can evade the body's defenses
 and grow in an uncontrolled
 way, ultimately producing
 death. We understand very
 little about how a chemical car-
 cinogen interacts with a cell's
 DNA to transform it, but it is
 believed that any case of chem-
 ical carcinogenesis is the result
 of a single molecule (or a small
 number of them) interacting
 with a single cell. It follows
 that exposure to a small amount
 of a carcinogen produces some
 small risk of cancer.
   The "no safe level" conclu-
 sion has important conse-
 quences. It means that expo-
 sures of large numbers of
 people even to very low levels
 of carcinogens are still a matter
 of concern, even if the risk to
 any particular individual ap-
 pears negligible. For example,
 if everyone in the U.S. had a
 one-in-100,000 chance of get-
 ting cancer as a result of such
 an exposure, certainly a very
 small risk, that would still mean
 2,200 or so additional cases of
 cancer nationwide. It also
 means that the animal tests are
 valid bases for inferring human
 risk even with the very high
 doses which must be used in
 those tests for technical rea-
 sons. Although the environmen-
 tal exposures are usually orders
 of magnitude lower than those
 used in the animal tests, the
 number of people exposed is
 orders of magnitude higher.
   It should be noted that there
 are reputable scientists who do
 not accept the "no safe level"
 conclusion. However, in the
 disagreement, which isn't likely
to be resolved in the foreseeable
 future, the preponderance of
 scientific opinion does accept
 it. So the regulatory agencies
 have found it prudent, as a
 matter of public policy, to take
 a conservative position and
 adopt the "no safe level"
   Since exposure to any
 amount of a carcinogen carries
 some risk, regulatory decisions
 cannot be based on determina-
 tion of a safe level. But in many
 cases, complete elimination of
 the chemical from the environ-
 ment is not feasible or has costs
 that society would be unwilling
 to pay. EPA and other regula-
 tory agencies have therefore
 adopted the policy of mini-
 mizing any human exposure to
 carcinogens, provided the costs
 are reasonable. This is the ra-
 tionale that has guided the
 development of the proposed
 regulations to limit organic con-
 taminants in drinking water.
   EPA believes that the costs
 of the proposed regulations are
 quite reasonable. While a com-
 plete discussion of costs would
 exceed the space available here,
the bottom line is that, in a
 city that would have to install
granular activated carbon treat-
 ment, the average family's
water bill would probably in-
crease by about $10-520 per
   EPA's evaluation of the
 health risk has been endorsed
 by the Director of the National
 Cancer Institute, Dr. Arthur C.
 Upton. In a  letter to EPA Admin-
 istrator Douglas M. Costle, Dr.
 Upton stated:

 "/ have reviewed the health
basis of EPA's proposed regu-
 lations for control of organic
 contaminants in drinking water.
 ... Briefly, we support the
judgement that these chemicals
present a potential risk of can-
 cer that should be reduced to
 the extent feasible.

A /though it is not possible at
 this time to quantify the actual
hazard from exposure to chemi-
cally contaminated drinking
water or to determine the con-
tribution to national cancer
rates from drinking water, sev-
eral conclusions can be drawn
from the current thought on
cancer cause and prevention:

   1. Chemicals which have
   been shown to cause cancers
   in animal studies are com-
   monly found in drinking
   water in small amounts.
   2. Some known human carci-
   nogens have been found in
   drinking water.

   3. Exposure to even very
   small amounts of carcino-
   genic chemicals poses some
   risk and repeated exposure
   amplifies the risk.

   4. Cancers induced by expo-
   sure to small amounts of
   chemicals may not be mani-
   fested for 20 or more years
   and thus are difficult to relate
   to a single specific cause.

   5. Some portion of the popu-
   lation that is exposed is at a
   greater risk because of other
   contributing factors such as
   prior disease states, expo-
   sure to other chemicals, or
   genetic susceptibility.

In addition, a number of epide-
miological studies have been
conducted which show a pat-
tern of statistical association
between elevated cancer risk
rates and surrogates for organic
contaminants in drinking water.
While such studies are far from
conclusive, when taken together
with the toxicological data from
animal testing, they constitute a
further basis for public health

While we do not have [f/?e]  ex-
pertise to reach judgement on
the feasibility of the treatment
that would be required by the
proposed regulations, we do
believe that the potential risk
justifies action and would en-
courage you to reduce the
amounts of chemicals in drink-
ing water to the extent that is
consistent with reasonably
available means..."

   To summarize, we know that
a great deal of human cancer is
caused by unknown factors in
the environment. We also know
that certain chemicals that
cause cancer in animals are
found in low levels in air, food,
and drinking water. These
chemicals, and others that have
not yet been tested, contribute
to the total incidence of cancer,
although the magnitude of the
impact of each is unknown.
Thus EPA believes that it
should take the first step toward
removing such chemicals from
the Nation's drinking water. D

Dumping off
New York
By  Peter W.
    Disposal of municipal sew-
      age sludge, industrial
wastes, and dredged materials
in ocean waters off New York
is a regional issue of intense
public interest and concern. The
majority of these activities, past
and present, in the U.S. occur
at dump sites managed by Re-
gion 2 in the New York Bight,
an 11,000 square  mile ocean
area off the Eastern coastline
extending from  Cape May, N.J.,
to Montauk Point, N.Y.
  The honorary title of "Big
Dumper" given to us by our
friends stems from the fact that
in 1977, for example, about 80
percent by volume of all dump-
ing of sewage sludge, acid
wastes, construction debris,
and chemical wastes in the
United States took place at four
EPA-designated ocean dump
sites in the Bight. When indus-
trial  dumping activities at a site
off the north coast of Puerto
Rico (also in Region 2) are in-
cluded, this figure increases to
91 percent.
  This volume of  municipal and
industrial wastes being dumped
in the Bight, and scientific evi-
dence that the sewage sludge
and dredged material are  ad-
versely impacting the marine
environment, has  resulted in
"high public visibility," for the
problem. Scientific investiga-
tion, mainly by the National
Oceanic and Atmospheric Ad-
ministration,  has documented
several adverse environmental
impacts at the sludge and
dredged material  sites.
   These include elevated con-
centrations of heavy metals,
organic matter, and bacteria in
the water and bottom sediments
with attendant threat of bio-

Dr. Peter Anderson is  chief of
Region 2's Marine Protection
accumulation in the food chain.
Reduced catches of bony fish in
high-carbon sediment areas
also have been noted. Extensive
areas have been closed to shell-
fishing. Nutrient enrichment  has
resulted in increased phyto-
plankton productivity. Fin rot,
exoskeleton erosion, and gill
clogging have occurred in cer-
tain types of marine life—and
sediments have been found in
the vicinity of the dump sites
devoid of normal bottom-
dwelling marine life.
   Ocean dumping is by no
means the only waste in the
Bight. Pollutants from the
Hudson-Raritan estuarine sys-
tem, including raw sewage,
inadequately treated municipal
and industrial effluents, agricul-
tural and urban runoff, com-
bined storm-sewer discharges.
and oil spills far outweigh ocean
dumping in terms of total
pollutant loading. Thus, it is
difficult to ascribe these adverse
impacts entirely to ocean dump-
ing; however, it is a significant
component in some instances.
   Most environmental inci-
dents in the New York Bight  are
attributed to ocean dumping.
For example, reports of sewage
sludge (the popular "sludge
monster") on the beaches of
Long Island and New Jersey are
common, although unsubstan-
tiated, every spring and
summer. The washup of "float-
ables"—wood, plastic, tar-
grease balls, paper, and similar
debris—on Long Island beaches
and an extensive kill of bottom-
dwelling, fish and shellfish off
the New Jersey coast in the
summer of 1976 were attrib-
uted to ocean dumping in most
early press reports. However,
subsequent evaluation of tech-
nical information found that
these two incidents were
brought  on by atypical atmos-
pheric and hydrologic conditions
aggravated by pollutants, pri-
marily from inland sources.
Ocean dumping was at most a
minor contributing factor.
   Recognizing the magnitude
of environmental problems in
the Bight and its responsibili-
ties under several Federal
statutes, particularly the Marine
Protection, Research, and
Sanctuaries Act, Region 2 has
carried out an ocean monitoring
program involving several
Federal, State, and local agen-
cies. This is designed to collect
and evaluate reliable environ-
mental information, to support
enforcement actions, and to
determine the overall status of
the marine environment. An
effective program also was
developed under the Region's
permit program to require
technically feasible, environ-
mentally acceptable, and
economically reasonable alter-
natives to ocean dumping.
   Implementation of the Act
in April 1973 spurred indus-
trial ocean dumpers in the
Region to construct land-based
treatment facilities or to carry
out other environmentally
acceptable alternatives for
handling their wastes. Of the
roughly 150  industrial ocean
dumpers in 1973, only eight
remain. During 1977, these
eight dumped almost  1.5 mil-
lion wet tons of aqueous wastes.
Typical wastes include water
solutions of inorganic salts with
trace amounts of organic
compounds, liquid wastes from
the manufacture of non-persis-
tent organophosphate pesti-
cides, acid wastes from the
manufacture of titanium dioxide
and fluorocarbons, and residual
wastes from the manufacture
of Pharmaceuticals.
   Five of the eight waste
dumpers have agreed to stop
ocean dumping on or before
April, 1981.  The remaining
three have promised to bring
their wastes  into compliance
with EPA's restrictive ocean
dumping criteria by 1981 and
to investigate innovative treat-
ment technology. An addi-
tional eight industrial  waste
sources in Puerto Rico are
under firm compliance sched-
ules to cease ocean dumping
by 1981.
   Ocean dumping of municipal
wastes has a less favorable
record. It became clear shortly
after passage of the Act that
the construction of new and
improved publicly-owned
wastewater treatment facilities,
scheduled for completion be-
tween  1 977 and 1 983, would
increase by 250 percent the
amount of sludge generated by
municipalities that practice
ocean dumping in the Bight.
In 1977, these sources dumped
almost 4.5 million wet tons;
 by 1981, the time set by law to
_stop the ocean dumping of
 harmful sewage sludge, these
 same sludge generators will be
 dumping an estimated 11.1
 million wet tons.
   The problem of handling, in
 an environmentally acceptable
 manner, not only the present
 volume of sludge, but also the
 projected increases due to up-
 graded treatment, is only now
 being  resolved. In 1974, in con-
 junction with the  States of New
 Jersey and New York, the Re-
 gion funded a study by the Inter-
 state Sanitation Commission to
 determine feasible and environ-
 mentally acceptable alternative
 disposal methods for sewage
 sludge in a metropolitan area. In
 mid-1976, after evaluating the
 results of this study, the Region
 concluded that acceptable land-
 based alternatives such as com-
 posting, incineration, and
 pyrolysis were available. How-
 ever, it also was recognized that
 the major municipal dumpers in
 the metropolitan area could not
 implement an alternative dispo-
 sal method before the end of
 1981, and even then only if no
 institutional or legal problems
 hindered implementation.
   Thus, since August 1976, all
 permits for the ocean dumping
 of sewage sludge have  included
 a strict compliance schedule to
 cease  ocean dumping on or be-
 fore December 31, 1981. (It
 should be noted that the Act
 was amended on  November 4,
 1977 to include this 1981
 phase-out date for the disposal
 of sewage sludges, which un-
 reasonably degrade the marine
 environment.) These schedules
 include milestones for the pre-
 paration of facility plans and
 environmental assessments on
 the selected alternative(s), pub-
 lic hearings, preparation of
 plans end specifications, and
 initiation and completion of
   All  permittees  are given the
 opportunity to comply with this
 permit condition  using  Con-
 struction Grant funds, and most
 have chosen this path.
   All  of the alternate disposal
 options available to sludge
 dumpers have substantial en-
 vironmental impacts associated

with them. Metropolitan area
sewage sludge contains ele-
ments that are environmental
problems in themselves, such as
human pathogens (viruses,
fungal  spores, parasitic cysts,
and bacteria), heavy metals
(cadmium, rrjercury, chromium,
etc.), and organohalogens
(pesticides, PCB's, etc.).
   Aerobic composting, which is
being considered by many
sludge dumpers as an alterna-
tive, is a beneficial use (recycl-
ing) of the sludge. This process
reduces the health risks from
bacteria and viruses, reduces
odor problems, and dilutes the
metal and toxic organics con-
tent. However, the risks from
other pathogens (fungal spores,
parasitic cysts) are not con-
trolled, nor is the threat of bio-
accumulation of heavy metals
and toxic organics through the
agricultural use of the com-
posted material. Of additional
concern are the potential envi-
ronmental problems associated
with percolation of nutrients,
heavy metals, and toxic or-
ganics into adjacent streams
and groundwater aquifers.
These  concerns are particularly
keen in Long Island and south-
ern New Jersey, which depend
on groundwater for potable
water supplies. Thus, the use of
composted sludges is being
limited by State and Federal
action  to non-agricultural uses
in accord with specific applica-
tion rates.
   The other option actively be-
ing considered is incineration.
While pathogens and some
toxic organics are destroyed,
sewage sludge incineration re-
sults in waste gases, particu-
lates, and a sterile ash that re-
tains most of the heavy metals
originally present. The dis-
charge of particulates, odors,
volatile toxic organics, airborne
metals (cadmium, mercury, and
lead), and other waste gases
could cause air pollution prob-
   Facility plans developed by
the 55 remaining sludge dump-
ers, out of the roughly 250
plants  in1 973, are be ing sub-
mitted to the public for review.
The decision point on which
alternative disposal method to
implement is at hand. It won't
be an easy choice. D
     ''Current N.Y. Sludge Site
       -:N.Y. Acid Site
     A N.Y. Construction Debris Site

             • "106" Site
 DuPont Site
    Sludge Site
                                             '  •
                                        '  :     A
                                      Wi i
                            Region 2
                                  Puerto Rico
                                  Ind. Waste Site

Around  the  Nation
Environmental Town
Meeting Set
Region 1 and the Maine
Audubon Society will co-
sponsor an environmental
town meeting in that State
on October 12, William R.
Adams, Jr., Regional Ad-
ministrator and Henry War-
ren, Commissioner of the
Maine  Department of En-
vironmental Protection,
will answer citizens' ques-
tions about the impact of
Federal and State environ-
mental  programs on Maine
residents. Specific discus-
sion topics will include
environmental taws dealing
with clean water and air,
toxic substances, and solid
waste.  The town meeting
wilt be  heftt in the Main
Lounge of the Moulton
Union,  Bowdoin College,
Brunswick, Me. from 7:30
to 10 p.m. A similar meet-
ing was held in Rhode
Island earlier this year as
part of  a series being spon-
sored by the  Regional

Secretary Named
Brendan J. Whittaker, a
44-year old forester and
Episcopal  priest, has been
named  Vermont's Secre-
tary of  Environmental Con-
servation by Governor
Richard A. Snelling.  Whit-
taker had been serving as
the State's energy director,
and was previously Direc
tor of Information and
Education for the State
Agency for Environmental
Sole Source
EPA has designated the
Long Island aquifer as the
sole water supply source
for  Nassau and Suffolk
Counties in New  York
State, in response to a peti-
tion filed by the Environ-
mental Defense Fund in
January, 1975. Under the
Safe Drinking Water Act of
1 974 any future project in
the  two counties that in-
volves Federal assistance
(through a grant, loan guar-
antee, contract, or other-
wise) will be subject to re-
view by EPA for potential
impact on the groundwater
system. In making his deci-
sion Administrator Douglas
M. Costle noted that the
aquifers are the principal
source of drinking water
for approximately 2.5 mil-
lion people; that there is no
economically feasible al-
ternative to replace the
groundwater system; that
the  system could become
contaminated through its
recharge zone, and that
contamination of the aqui-
fer would pose a significant
public health problem.
Eckardt C. Beck,  Regional
Administrator, called the
designation "an important
additional safeguard for
protecting the health of
Long Island residents."
Beck added, "EPA will
now carefully examine Fed-
erally-assisted projects to
ensure that the high water
quality of Long Island's
natural underground reser-
voir is preserved."
Water Pollution Jail
Sentence Issued
U.S. District Court Judge
Edward R. Becker recently
sentenced Manfred De-
Rewal of Pennsylvania to
a six-month jail sentence
for dumping poisonous
chemicals into the Dela-
ware River in violation of
the Federal Clean Water
Act. DeRewal,  who has
owned or been associated
with waste disposal com-
panies in Pennsylvania,
New Jersey and North
Carolina, was also fined
$20,000 and placed on
four and one-half years
probation. He has been
cited for more  than 100
State pollution violations
over the past 1 3 years. Fol-
lowing a detailed investiga-
tion by the U.S. Attorney's
office and Region 3's En-
forcement Division, De-
Rewal pleaded guilty to
five counts of violating
Federal pollution laws in
March,1977. DeRewal and
three accomplices had
rented a warehouse near
the Delaware River in Phil-
adelphia where they stored
over 730,000 gallons of
waste solicited from vari-
ous companies. The wastes
were poured into  a storm
sewer through a manhole
in the warehouse, and into
the Delaware River near
Philadelphia's  Torresdale
drinking water plant. Re-
gional Administrator Jack
J. Schramm said, "The
sentencing serves notice
on all persons involved in
illegal dumping practices
that the Federal Govern-
ment will not tolerate any-
one who risks the lives of
others by illegally dis-
charging dangerous chem-
icals into our waterways."

Pennsylvania Gets
Permit Authority
The Pennsylvania Depart-
ment of Environmental Re-
sources has been  given the
authority to administer the
National Pollutant Dis-
charge Elimination System
permit program in that
State. Pennsylvania is the
fourth State in Region 3 to
be given that authority and
only the West Virginia pro-
gram remains under Re-
gional administration.

Research Funding Set
Through the Chesapeake
Bay Program, Region  3 will
be awarding approximately
$9 million in Federal grants
to State agencies, citizen
groups, and research  in-
stitutions to study environ-
mental problems of the
 Leaded Gas Violator
 A Miami, Fla., service sta-
 tion operator has paid
 $8,300 in fines for putting
 leaded gasoline into ve-
 hicles marked "unleaded
 gasoline only." The com-
 pany, Alpine Enterprises,
 Inc., signed a consent
 agreement with Region 4
 about the penalty. The firm
 had been observed intro-
 ducing leaded fuel into
 three cars. It also was
 charged with mislabeling
 dispensing pumps and fail-
 ing to equip pumps with
 the proper size nozzles.

 Forest Industries
 Air pollution controls are
 being installed at three
 major forest industries in
 Region 4 before their  facil-
 ities switch from burning
 oil to coal. The Westvaco
 Corporation in Charleston,
 S.C., expects to complete
 conversion by the end of
 1979. Continental Forest
 Industries in Savannah,
 Ga., and Weyerhaeuser
 Company in Plymouth,
 N.C. should have com-
 pleted the change-over by
 mid-1981. Pollution from
these coal-fired boilers, it
is believed, will be less
than present emissions
from oil-fired units. There
should be no delay in com-
pliance with air pollution
regulations because con
trols will be installed be-
fore the conversion is

Chemical Disposal
EPA has approved a chem-
ical waste landfill near
Livingston, Ala., for the
disposal of polychlorinated
biphenyls (PCB's), a chem-
ical compound toxic to
aquatic life and harmful to
humans. The landfill, in
east-central Alabama, is
operated by Waste Man-
agement, Inc.
Agencies Cooperate
Region 5 has reached an
agreement with the Food
and Drug Administration
to have water samples ana-
lyzed for pollution at the
FDA laboratory in Minne-
apolis, Minn. The innova-
tive agreement was ar-
ranged under a cooperative
program announced last
year by EPA, FDA, the Con-
sumer Product Safety
Commission, and the Oc-
cupational Safety and
Health Administration to
share resources. Acting
Regional Administrator
Valdas V. Adamkus said
the agreement will cut
down on duplication of lab-
oratory facilities by the two
agencies for the Minneap-
olis area. "Not only will
this agreement increase our
field monitoring capacity,
but it is expected to save
about $25,000,"  he added.

Cleaning A Lake
EPA is funding half the cost
of a $2.6 million project to
clean up Lake Lansing, a
435-acre lake in Ingham
County, Mich. Funds from
the  Agency's Clean Lakes
Program are being matched
by local sources. The proj-
ect will attempt to restore
the  recreational potential
of the lake through hy-
draulic dredging, which
will remove aquatic vege-
tation and sediments that
clog the lake. The  project
will be used to evaluate
hydraulic dredging and
determine the impact it
would have on similar

PCB's Discovered in
Scientists at EPA's Cen-
tral  Regional Laboratory in
Chicago have found levels
of polychlorinated bi-
phenyls (PCB's) as high
as 1 3 parts per million in
samples of Nu-Earth, a fer-
tilizer made from sludge
processed by the Metro-
politan Sanitary District of
Greater Chicago. This  level
exceeds the  recommended
limit of 10 parts per million
set by the Food and Drug
Administration  for the pro-
tection of human health.
Nine other chemicals clas-
sified  as polynuclear aro-
matic hydrocarbons were
also found in the sludge.
Some polynuclear hydro-
carbons are believed to
cause cancer. Composted
sludge has been distributed
free of charge in the Chi-
cago area by the Sanitary
District for 5 years.
set up at the Robert S. Kerr
Environmental Research
Laboratory in  Ada, Okla.
The wastewater treatment
facility construction grant
program, part of EPA's
Office of Water and Waste
Management, and the
Agency's Office of Re-
search and Development
will combine  their efforts
to encourage  and acceler-
ate use of land application
systems, in response to the
1977 amendments to the
Clean Water Act and the
policy on land treatment
processes adopted by Ad-
ministrator Douglas M.
Costle. The Ada Lab has
already been  involved in
research related to land
treatment processes and
protection of  groundwater.
Land application is espe-
cially advantageous for
smaller communities where
land prices are compara-
tively low and the costs of
sophisticated treatment
systems are prohibitive.
enforcement activities, and
stressed the Region's com-
mitment to carrying out the
regulations. State environ-
mental agency staff mem-
bers also participated in
the meetings. In addition to
the PCB regulations, the
Regional Office employees
discussed with the utilities
the future regulation of
coal ash disposal.
Land Treatment
Systems To  Be
With the encouragement of
Regional Administrator
Adlene Harrison, a coop-
erative effort to stimulate
use of land treatment sys-
tems for cleaning up muni-
cipal wastewater will be
Utility Companies
The Air and Hazardous Ma-
terials Division recently
held a series of one-day
meetings with representa-
tives of utility companies
concerning the  regulations
for handling polychlori-
nated biphenyls (PCB's)
under the Resource Con-
servation and Recovery
Act. The  regulations con-
tain provisions  covering
recordkeeping,  marking,
and storage. The meetings,
held in Lincoln, Neb., Jef-
ferson City, Mo., and Bet-
tendorf, Iowa, explained
EPA's responsibilities un-
der the new regulations as
well. Morethan 135 people
attended the meetings,
where EPA staff set out
inspection procedures and
Noise Control
Institute Set
The region is cosponsoring
the second annual Noise
Control Institute with the
Colorado Department of
Health, the University of
Colorado, the Community
Noise Control Association,
and the City of Boulder En-
vironmental  Protection
Office. The institute, which
will be held atthe Univer-
sity of Colorado in Boulder,
October 9-13, will be at-
tended by noise control
specialists from across
the country.  Sessions will
cover all aspects important
to the operation of a suc-
cessful community noise .
control program including
training in the use of noise
measurement tools, the
physiological and psycho-
logical effects of noise, and
issuing summonses to
noise violators. This year's
institute will put special
emphasis on land-use plan-
ning for noise control, in-
cluding information on
criteria development; deal-
ing with noise from traffic,
airport/aircraft, railroads
and industry; and review-
ing plans for proposed
development. Academic
credit is available for peo-
ple who attend the full five
days. Special two- and
three-day sessions  also are
available. A program bro-
chure is available from the
Bureau of Conferences and
Institutes, 217 Academy,
970 Aurora Ave., Boulder,
Colo. 80302, Attn.: Second
Annual Noise Control
Water Quality
Management Planned
The Pima County, Ariz.,
Association of Govern-
ments' plan for areawide
water quality management
for the Mt. Lemmon area
points out new solutions to
eliminate discharges to a
local creek. Sabino Creek
is the only free-flowing
stream in the area and is
used heavily for recreation.
Under the plan, prepared
under section 208 of the
Clean Water Act, the cen-
tral collection and treat-
ment systems in the area,
which were functioning
poorly, will be abandoned
in favor of individual treat-
ment systems, which will
cost less and be more re-
liable. All discharges into
the creek will be eliminated
under the current plan.

Minority Contracting
Region 9 has awarded a
contract to Homitz, Allen
and Associates of Oakland,
Cal. to improve participa-
tion of minority architec-
tural and engineering firms
in the EPA construction
grants program. The con-
tractor acts as a "commu-
nicator" with minority
firms; informing them of
available jobs, explaining
regulations for contracting
with EPA, and presenting
seminars on organization
skills. The contract has sig-
nificantly increased minor-
ity participation in Agency
Boat Noise Studied
Last summer Region 10
helped the Washington
State  Department of Ecol-
ogy gather information that
will be used in the develop-
ment of noise regulations
for powerboats. EPA and
the State noise personnel
set up buoys just off the
Seattle shore of Lake
Washington and invited
powerboat dealers and dis-
tributors to run their boats
through a course that al-
lowed sound-level meas-
urements to be taken off-
shore. The regulations
being developed are in-
tended to reduce intrusive
boat noise that bothers
residents of beach houses,
and other people on the
shores of Washington's
lakes, rivers, and marine

Disposal Sites
Region 10 has recently ap-
proved two State-licensed
waste disposal facilities.
The facilities,  located  in
Arlington, Ore., and Grand
View, Idaho, may now
accept discarded electrical
equipment, soil, and other
debris contaminated with
polychlorinated biphenyis
(PCB's). Both disposal
sites are commercially
operated. Each will be sub-
ject to permits that contain
eight pages of rigorous
technical and operational
requirements to ensure
that the PCB's in the con-
taminated waste never
enter the surrounding
environment. D
    SEPTEMBER 1978

A    major conference on the ur-
     ban environment has been
scheduled for April, 1979, by
three Federal agencies and
several urban, labor and
environmental groups. The
goal is to gain a consensus on
how to improve the quality of
life in the Nation's depressed
urban areas.
   "What we are trying to do
is get a definition of 'urban
envrronmentalism,' " said
EPA's Deputy Administrator,
Barbara Blum, in a press con-
ference announcing the April
plans. This is a "very new con-
cept," she added, and if it is
going to work, the definition
for it has to come from the
people who live in the cities,
based on their priorites.
  Another conference aim,
Blum said, is to forge "sort of
an unholy alliance." It isn't
unholy, but would have been
thought so a few years ago,
she explained.  It would include
"the people in the inner city,
the environmentalists, the
minorities, the labor unions."
Such a coalition would "help
us in our fight to preserve the
inner cities."
   Blum predicted that the con-
ference participants will in-
clude ". . . housewife groups
. .  . butterfly groups . . .
neighborhood groups . . .
everyone who wants to par-
ticipate in the city."
   The announcement of the
conference was made jointly
by Blum; Jay Janis, Undersec-
retary of the  Department of
Housing and Urban Develop-
ment (HUD); James Joseph,
Undersecretary of the Depart-
ment of the Interior (DOI), and
by representatives of private
co-sponsoring groups. They
included Vernon Jordan of the
National Urban League, Frank
Wallick of the Urban Environ-
ment Conference and Founda-
tion, and Neil Goldstein of the
Sierra Club.
   The fact that the three
Federal agencies are helping
fund the conference with a
joint  $11 5,000 grant is an
acknowledgement that the
Federal  Government can't do
the job alone, Blum said. "The
keystone of the Administra-
tion's urban policy is the forg-
ing of a new partnership among
the various levels of govern-
ment, the private sector and
Major  Urban  Conference
Deputy Administrator Barbara Blum shared the announcement of an urban environmental conference
with Vernon Jordan  (loft), of the National Urban League and Jack Watson (right) Assistant to the
    !'ir>nt for Intergovernmental Affairs.
the voluntary and neighborhood
organizations," she said.
"Urban environmentalism
must become a key factor in
this new partnership."
   The environment is impor-
tant in the Administration's
urban policy, Presidential
Assistant Jack Watson added.
"When we talk about urban
policy, we are not just talking
about roads and houses. We
are not just talking about jobs.
We are talking about the qual-
ity of  life in cities where peo-
ple live. . . ." He  called the
participation of three Federal
agencies in the urban environ-
mental press conference "a
harbinger of some very, very
positive things to come." Wat-
son is Assistant to the Presi-
dent for Intergovernmental
   Jordan, President of the
National Urban League, ex-
plained the common grounds
for action  in the urban environ-
ment. "With the advancement
of technology and the subse-
quent urban sprawl, the urban
areas  have borne  the brunt of
air and water pollution, auto-
dominated transportation,  re-
stricted housing opportunity
and deteriorated neighbor-
   Now, he said, the damages.
compounded by unemploy-
ment and energy shortages,
demand a common effort by
environmental and urban re-
form forces. The aim, he said,
must be "a meaningful attack
on the environmental problems
that now plague the American
  Jordan added that "there
may be situations where blacks
and whites violently disagree,
but if the air isn't pure, it may
not make any difference. That
is one thing that is very diffi-
cult to separate on the basis
of race."
   In a speech to the Sierra
Club last May, Blum also made
a strong case for urban en-
vironmentalism. "The flight to
the suburbs is binding inner
city and suburban people to-
gether in ways that the sub-
urban escapees did not antici-
pate. The air, water, and noise
may be most lethal downtown,
but increasingly the metropoli-
tan environment is one con-
tinuous airshed, watershed and
noise basin."
   "It's time to recognize that
there is no place to hide,"
Blum added. "It's time for all
urban residents, inner-city and
suburban, to acknowledge that
they share a common destiny.
And it's time for the environ-
mental movement to forge a
new urban vision and make a
sustained commitment to
create a healthy urban environ-
  The conference will be a key
in shaping such a vision and
launching a joint effort to
achieve it.  Conference objec-
tives include identifying a
national agenda to advance
cooperation among labor,
environmental and community
groups, melding the socio-
economic environment  more
closely with the physical en-
vironment; identifying racial
and economic factors camou-
flaged as environmental mat-
ters; and discussing technical
subjects such as pollution con-
trol, transportation, land use
and drinking water quality.
  Goldstein, NationalConserva-
tion Representative of the
Sierra Club, supported the
need for an urban environ-
ment vision. "The Sierra
Club," he said, "well known
for its leadership in wilderness
preservation, is determined to
be a leading force for improv-
ing America's cities as  well."
  Goldstein said  he believed
his  group could aid cities by
"better focusing our urban
environment efforts, forging
coalitions with other organiza-
tions, and calling upon  a vast
reservoir of volunteer talent.
. .  ." These steps needn't de-
tract from  "our current efforts
in other areas. . .  ." he added.

   Also supporting the vision
 of a better urban environment
 was HUD Undersecretary Jam's.
 "It is clear, for example, that
 quality housing requires qual-
 ity surroundings, such as clean
 air and water standards. It is
 clear that resources spent
 wisely for the environment
 are dollars spent wisely for
 housing. And it is also clear
 that dollars misspent for social
 programs are dollars misspent
 for the environment."
   Janis argued for "a sound
 balance between our environ-
 mental and urban needs in
 order to achieve the most good
 for the greatest number."
   Unde'rsecretary Joseph of
 the DOI said the urban environ-
 mental conference "can pro-
 vide a valuable springboard in
 bringing  together these diverse
 groups and assist in the estab-
 lishment of a national grass
 roots network...."
   "There is an assumption in
 some places," he added, "that
 the concerns with ecology and
 equality are antithetical, that
 one movement focuses on eco-
 nomic justice, while the other
 is concerned  not so much with
 power but with pollution. . . ."
   But Joseph believed that
 many who were raised in
 ghettos and barrios are now
 convinced that a clean environ-
 ment, "must go hand in hand
 with our  other efforts to build
 a society which is healthy,
 humane and just."
   Wallick, Chair of the Board
 of the Urban Environment Con-
ference, also saw a change in
 consciousness. "The environ-
 mental awareness of 1970—
 Earth Day—has given the
whole country a feeling that
we have to do something about
the environment," he said.
 "And the environment is not
restricted to the outdoor en-
vironment. It is a part of our
lives; it is a part of the work
   Wallick commended the
Administration for its aid for
the environmental conference
scheduled for April. "I think
the fact that the Administra-
tion is willing to give us some
sort of national visibility is
very much a feather in their
hat, and I hope we can make
it successful." D
with Japan
Continued from page 24
   CEQ has responsibility for
 the 1 Hh project, which is en-
 titled, "Environmental Impact
 Assessments." At the Second
 Joint Planning and Coordina-
 tion Committee Meeting, the
 U.S. proposed that five new
 areas be added to the Agree-
 ment: water conservation and
 flow reduction, non-point
 source control and water quality
 management, measurement of
 by-product coke oven emission
 control technology, manage-
 ment and disposal of radioac-
 tive wastes, and environmental
 economics and incentives for
 pollution control. It is hoped
 that useful exchanges of infor-
 mation will soon begin in each
 of these areas.
   The participants in each of
 the eleven established projects
 meet on a regular basis. The
 sessions are held in Japan one
 year and in the United States
 the next. It is from these tech-
 nical meetings that the real
 fruits of this cooperation are
 realized, for they provide each
 country with first-hand informa-
 tion on how each nation deals
 with common environmental
 problems. Visits to field facili-
 ties are also arranged during
the sessions to provide partici-
pants with an opportunity to see
technical innovations and mod-
 ifications in pollution control
 equipment. For example, a team
 representing EPA's Kepone
 Mitigation Feasibility Task
 Force, the Management of Bot-
tom Sediments Containing
Toxic Pollutants project, and
 members of the U.S. Army
 Corps of Engineers recently
returned from a visit to Japan
where they met with representa-
tives of several industrial firms.
   This EPA-sponsored team
 observed newly-developed
 dredging technology and ad-
 vanced techniques for handling
contaminated sediments and
sludges. From this visit and
further discussions, it is highly
probable that this Japanese
technology will be useful in
aiding the United States in
handling its in-place toxic pol-
lutant problems and refining
its technology. To date, the
Japanese technology has been
used effectively on sludge and
sediments contaminated by
mercury, copper,  zinc, cad-
mium, lead, chromium and
PCB's. Subsequent investiga-
tions are underway to deter-
mine whether this technology
can aid  in  any future clean-up
of Kepone in the James River,
  The two countries have also
worked together in the area of
radioactive waste disposal. For
example, this past June Japan
sent a scientist to participate  in
EPA's low-level radioactive
waste recovery dive program.
This team  surveyed and con-
ducted tests in a radioactive
waste dump site located approx-
imately 200 miles off the
Maryland/Delaware coast. The
Japanese participant from
Japan's  Atomic Energy and Re-
search Institute not only took
part in the analysis and survey
segment of the program but also
participated in several of the
scheduled dives.

Sharing Expertise
Still another benefit  derived
from our bilateral cooperation
is the exchange of technical
experts. Over a dozen qualified
Japanese research scientists
have visited our laboratories
and facilities. These scientists
have stayed in the United States
for as long as one year, and
have performed valuable work
for EPA  and for their own na-
tional programs.  Individual
areas of study are agreed upon
prior to their arrival. Detailed
reports are written for both
nations once the assignments
have been  completed. Over the
years, Japanese scientists have
visited our laboratories in North
Carolina, Ohio, New Jersey,
Oregon, and Nevada. The bene-
fits derived from this exchange
program come not only in the
completion of the agreed upon
scope of work, but also in the
development of lasting profes-
sional and personal
   While EPA does not send
researchers to Japan for such
extended periods, we do send
fact-finding teams to gain valu-
able information on a variety of
industrial pollution control
topics. Teams have visited
Japan recently to gain informa-
tion in the areas of flue gas de-
sulfurization and noise pollu-
tion control. A team is tenta-
tively scheduled to conduct a
survey of Japan's pollution
control practices in the iron and
steel industry.
   Several officials from Japan's
Environment Agency have
visited EPA's headquarters to
become familiar with our na-
tional policies and to observe
how environmental matters are
handled at the national level. In
addition, EPA receives approx-
imately 2,000 Japanese visi-
tors each year. Their interests
range from such topics as the
preparation of environmental
impact statements to the role
public interest groups play in
setting national environmental
   These are some of the num-
erous ways in which Japan and
the United States have been
cooperating  in the environ-
mental area  in recent years.
The basic culture of the Jap-
anese lays great stress on har-
mony between man and nature,
and we have much to learn
from this philosophy. In sim-
ilar fashion,  as Japan has
moved into a world role as a
highly industrialized country.
she has profited by studying
our legislation and technology
in the field of pollution control
and abatement.  The U. S.-
Japan Agreement augurs well
for a continuation of the use-
ful exchange of environmental
information between the two
nations. D

Program ^
   Both EPA and farmers
     "should be particularly
optimistic about the future of
our pesticide program" as a
result of recent amendments to
the Federal Pesticide law,
Steven D. Jellinek, Assistant
Administrator for Toxic Sub-
stances, has declared.
   A  House and Senate Confer-
ence Committee at press time
had approved a number of
amendments to the Federal
Insecticide, Fungicide, and
Rodenticide Act (FIFRA).
Jellinek, in an address to the
Southern Commodity Producers
Conference in Birmingham,
Alabama July 27, said there
were several aspects to the
amendments that merited
• Conditional registration per-
mitting EPA to register products
similar to old chemicals or
providing new uses of them;
• A "generic standards" ap-
proach allowing EPA to make
broad decisions for an  entire
group of products containing
the same ingredient;
• A diminished requirement for
reviews on the efficacy of
• A liberalized approach to uses
of a pesticide that are not in
literal accord with the printed
label on the product.
  Jellinek, who spoke at the
invitation of the Alabama Farm
Bureau Federation, said that the
"conditional registration"
amendment "will greatly im-
prove our ability to register
products that are similar to or
are actually new uses of old
chemicals." He said it was
"very frustrating" to have to
turn down numerous applica-
tions because of a double stand-
ard that allows continued use of
products already registered but
requires a full complement of
registration data before  iden-
tical new products can be reg-
istered. Jellinek added that
EPA planned to issue regula-
tions ior conditional registra-
tion within the new few months,
and begin issuing such registra-
tions immediately thereafter.
   The generic standards ap-
proach to re-registration of
existing pesticides will make
possible a more streamlined
procedure rather than the pre-
sent practice  of regulatory deci-
sions on a product-by-product
   With respect to efficacy re-
views, Jellinek explained that
under the amendments EPA will
depend more and more on farm-
ers for information on how pes-
ticides are actually performing
under field conditions. "We will
look to the Department of Agri-
culture and the land-grant uni-
versity system for feedback on
efficacy," he  declared, "rather
than relying on data from the
registrants that becomes rapid-
ly outdated owing to regional
and climatic variations and
changing degrees of pest
   On the final point, the Assist-
ant Administrator said the
amendments provide a new
definition of "use inconsistent
with the label." It makes clear
that certain practices, which
may not be in strict or literal
accord with the printed label,
are nonetheless legally con-
sistent with label directions.
   "Specifically," he said,
"farmers and other pesticide
applicators will be able to use
less than the specified label
dosage, to treat for a pest not
listed on the label, to mix pesti-
cides and fertilizers, and to
employ responsible methods of
application not specified on
the label.
   "We expect that these
changes will introduce a wel-
come measure of common
sense to pesticide use enforce-
ment, which incidentally under
the new legislation will become
even more of a State respon-
sibility than it is now."
   The agreement by House-
Senate conferees on the FIFRA
amendments was reached in
July after eight months of nego-
tiations. Still awaiting action at
press time was approval by the
full House and Senate and the
President's signature before the
amendments could become law.
   Jellinek told the Commodity
Producers Conference that a
fundamental dilemma is re-
flected in FIFRA:
   "First, pesticides are among
the riskiest chemicals used in
our society.
   "And second, pesticides are
necessary for modern agricul-
tural productivity and
   In essence, he said, the  Fed-
eral pesticide law "requires
EPA to balance the risks of pes-
ticides exposure to humans and
the environment against the
benefits of pesticide use to
society and the economy. On
one hand, we must protect
society from the risks of using
pesticides. On the other we
must assure  that American agri-
culture has, and wil! continue to
have, the necessary pest-control
tools to  meet the Nation's—
and to an ever-increasing ex-
tent, the world's—needs for
food and fiber.
   "I assure you that this task is
neither simple nor easy. The
pressures that prevail upon us
are enormous," he added.
   Pesticide use has been in-
creasing rapidly since the mid-
1 960's.  Jellinek pointed out
that about 35,000 pesticides
are now registered for use in the
United States. The U.S. market
for pesticides in 1976 was $2.4
billion and by 1984 is expected
to grow to $3.3 billion. Produc-
tion of pesticides in the United
States grew from one billion
pounds in 1966 to 1.4 billion
in 1976, with more than half the
total used by agriculture. The
figures indicate that the in-
crease is likely to continue, he
said, along with chance of wide-
spread human and environmen-
tal exposure to dangerous
chemical pesticides.
  At the same time, agriculture
is a more highly competitive
endeavor than ever before, he
declared, with farmers expected
to produce more food and fiber
at lower prices to the consumer
while maintaining profit levels
that enable their businesses to
survive. "That isn't easy, either,
and we know it," Jellinek said.
   He cited a number of recent
decisions by EPA on various
pesticides to illustrate that "we
have not—as some of our cri-
tics have charged—stuck to  a
predetermined, knee-jerk pat-
tern of decision-making that
favors any particular
   The Assistant Administrator
conceded that the Office of Pes-
ticide Programs has a number of
deficiencies to overcome and is
working hard to do so. "And we
need to do a better job of con-
veying the message," he said,
"that we are neither weak-
kneed apologists for the pesti-
cide industry nor rampant cru-
saders against the use of every
pesticide on the market today
—because we are not."
   In summarizing the complex
decisions on certain pesticides
in recent times, he emphasized
that in each case the science
was examined, costs and bene-
fits carefully and objectively
evaluated, alternatives ex-
plored, and as fair a decision
as possible was rendered.
   Modern agriculture, he con-
cluded, "is one of America's
most promising economic ad-
vantages in a time when our
country needs economic advan-
tages perhaps more than ever
before. I am convinced that we
can continue to strengthen this
advantage while at the same
time prevent the adverse human
health and  environmental im-
pacts that sometimes accom-
pany agricultural progress." D

A listing of recent Agency pub-
lications and other items of use
to people interested in the
 General  Publications
Pollution: A Common Concern
(June 1978)
In this 8-panel pamphlet ten
prominent black leaders explain
how cleaning up the environ-
ment can play a part in efforts
to improve the quality of life for
black and other Americans.
Those included in the pamphlet
are Benjamin Hooks, Coretta
Scott King, Vernon Jordan,
Richard Hatcher, Parren
 Mitchell, Dorothy Height, M.
Carl Holman, Dr. Carlton Good-
lett, Bayard Rustin, and Eddie
N. Williams. Copies of the
pamphlet are available from
 Printing Management (PM-
215), EPA, Washington, D.C.

 Bicycle Strategies to Reduce
Air Pollution (1978)
 This 20-page booklet explains
 ways in which bicycles fit into
 plans to clean up air pollution.
 It gives an outline for bicycle
 program plans, points out ad-
 vantages of bicycles over other
 forms of transportation, and
 lists bicycle coordinators to
 contact in various regions of the
 country for more  information.
 Copies of the booklet are avail-
 able from Nina Rowe,
 (AW-445), EPA, Washington,

 Federal  Register
 Copies of Federal Register
notices are  available at a cost
of 20 cents per page. Write
 Office of the Federal Register,
 National Archives and Records
 Service,  Washington, D.C.

 Water Pollution
 EPA amends guidelines for ore
 mining and dressing point
 source category effective;
 7/11/78. Pp.29771-778, in
 the July  11 issue.

 EPA establishes a maximum
 permissible level for oxamyl
 residues on apples; effective
 7/12/78 P. 29946, July 12
Clean Water Act
EPA publishes a list of four
conventional pollutants. Pp.
32857-859, July 28 issue.

Toxic Substances
EPA requests public comment
on Chemical Use List: Com-
ments by 9/22/78, Pp. 3222-
251, July 25 issue.

Coming Events

EPA and Federal Design
EPA's Office of Public Aware-
ness will explain the history
and significance of changes in
that Office and how the
changes are reflected in both
management and graphics
design at the Fourth Federal
Design Assembly this month.
  More than 800 Government
officials are expected at the
sessions September 21 and 22
in the Pension Building, F  and
G Streets between 4th and 5th
Streets N.W. Administrator
Douglas M. Costle, Deputy
Administrator Barbara Blum,
and William Drayton, Jr.,
Assistant Administrator for
Planning and Management, are
among EPA officials invited to
the  meeting.
  Joan  M.  Nicholson, Director
of the Office of Public Aware-
ness, will outline the measures
that are being taken to improve
EPA's communication with
various segments of the public.
She will describe the reorgan-
ization of OPA and how that
relates to the Agency's graph-
ics  program in reaching vari-
ous constituency groups.  Ivan
Chermayeff, design consultant,
also has been invited to
  The Assembly is sponsored
by the National Endowment for
the Arts and is aimed at pro-
viding a better understanding of
the design process and how to
integrate it  into Federal deci-
sion-making and  policy. In
addition to  Agency officials,
participants will include Mem-
bers of Congress, representa-
tives of  State agencies, profes-
sional design societies, and
industry. Q
 An Environmental
 The Seveso Case
 Continued from page 15
 plete. It is evident that a power-
 ful impulse exists to put a good
 face on the matter, concentrate
 on the final decision to fence
 off the zone that simply cannot
 be handled in any other way,
 and dampen down public con-
 cern over any other sequels to
 the disaster.
   A particular effort was made
 to get people out of the Resi-
 dencia Leonardo da Vinci and
 back in their homes, as the
 evacuation was certainly the
 most traumatic and conspicuous
 social consequence of the ac-
 cident.  Of 140 families evac-
 uated, 1 20 have now been
 returned to  their homes. Their
 houses were decontaminated
 by removing the tile roofs,
 vacuuming and scrubbing the
 walls with detergent and solvent
 and clearing the grounds
 around them. New roofs, ap-
 pliances, and furnishings have
 been provided.  Only limited
 use can be made of the land
 around them. The area still
 looks desolate.  But the houses
 were treasured as many of the
 owners built them with their
 own labor.
   In the fall of 1977, the re-
 maining problems and the long-
 term management of the con-
 taminated area were turned
 over from the Lombardy Re-
 gion to a new commission
- which has established offices
 in the Augustinian  Seminary
 in Seveso. Its tasks will be to
 supervise medical monitoring,
 continuing land decontamina-
 tion studies and work, and
 maintenance of vigilance over
 the closed area. Eventually they
 will have to deal with the dis-
 posal of all of the contaminated
 waste. The ICMESA factory
 will have to be demolished. Its
 rubble will be added to the
 other TCDD-contaminated ma-
 terial which is held within
 the closed zone. This consists
 of mounds of plastic bags filled
 with the vegetation collected
 from the whole contaminated
 area; thousands of items of
 protective clothing, coveralls
 (changed daily), gloves, masks,
head coverings, boots, worn by
the cleanup squads, to which
more is being added as any
work goes on; plus the roof
tiles and the furnishings taken
from the vacated houses;
together with the carcasses of
35,000 animals that died or
were slaughtered, preserved in
metal containers stacked up
row on row; and also the trucks,
tools and other equipment
contaminated by use in the
poisoned area.  The costs of all
this has amounted to billions of
lire already, with a great  deal
more still to be  required, by some
means, from public funds. T'
   The Hoffman-La Roche
   Company faces damages
   of up to $50 million for
   the contamination of
   Seveso, according to
   a company official.
      Adolf Jann, chairman
   of the Swiss chemical
   company,  told a news
   conference recently that
   La Roche had bought
   properties in the worst-
   hit areas from the former
   inhabitants, and all other
   families had now been
   allowed to return.
      Jann said a final
   decision on the company's
   liabilities was expected
   soon, but he did not
   expect total damages to
   exceed $50 million. He
   added that three boys
   from Seveso were still
   suffering from a serious
   form of acne

                              Environmental response tnam mnmhnr wears a •         r.h<;mical protective garment
                              while trying to close off a leaking tank truck during a simulated environmental disaster.
    The television news may one
    evening picture a figure
clothed in protective suit with
self-contained air supply entering
a sewer or approaching a tank
car. This is not an astronaut or
the man from SWAT. It's some-
one from EPA, a member of a
new group set up to improve the
Agency's ability to cope with
environmental emergencies.
   The Environmental  Response
Team will have a core staff of
six with new skills required by
provisions of the Clean Water
Act. Now that the initial list of
hazardous substances has been
issued under the Act, EPA will
have new responsibilities for
protecting public health and
the environment from chemical
spills into waterways.
   But the team's charge will be
more  comprehensive than just
responding to spills. It encom-
passes, for example, averting
contamination of public water
supplies, aiding in the disposal
of solid and  hazardous wastes.
Federal  disaster assistance,
and preventing the release of
toxic air pollutants. The team
will permit EPA to provide
around-the-clock support to the
Regional offices with personnel
whose sole responsibility is to
respond to environmental
  Establishment of the Re-
sponse Team comes at a time
when EPA is becoming increas-
ingly concerned with environ-
mental emergencies. The des-
ignation of hazardous sub-
stances under the Clean Water
Act, the task set by the Toxic
Substances Control Act, and
the emphasis on hazardous
wastes in the Resource Con-
servation and  Recovery Act all
signal greater responsibilities
in the area of environmental
  Reflecting this new concern,
EPA Administrator Douglas M.
Costle in October 1977 re-
quested the Office of Planning
and Management to study the
Agency's capabilities in pre-
venting and responding to
environmental emergencies.
Paul Elston, Deputy Assistant
Administrator for Resource
Management,  set up an emer-
gency response task force to
analyze the Agency's activities.
In December the work of the
task force expanded when the
Interagency Toxic Substances
Strategy Committee was estab-
lished and EPA was designated
the lead agency for developing
an interagency plan to deal with
chemical crises.
  Staffing of the Response
Team is just getting underway.
All are likely to be already em-
ployed by EPA as emergency
response experts or other spe-
cialists. The membership will
probably include chemists, toxi-
cologists, biologists, sanitary
engineers, and a specialist in
waste disposal techniques such
as incineration and landfilling.
   Since the work will be physi-
cally demanding and require
considerable travel, team mem-
bers will be subjected to rigor-
ous physical examinations
before they  are selected and
will have periodic examinations
to ensure that they have not
been affected by exposure to
low levels of toxic chemicals.
When not responding to envi-
ronmental emergencies, they
will conduct training sessions
for EPA and State employees,
developing  contingency plans,
and prepare operating manuals
and other technical documents.
   To  ensure that the regula-
tions for responding to chemical
crises are appropriate and fea-
sible,  the Emergency Response
Task Force held a meeting re-
cently at EPA Headquarters in
Washington, D.C. to consider
suggestions from various or-
ganizations. The meeting was
chaired by Office of Public
Awareness Director Joan Mar-
tin Nicholson and included rep-
resentatives from trade asso-
ciations, labor organizations,
chemical firms, and environ-
mental groups. They stressed
the need for cooperation, coor-
dination, and public  informa-
tion both before and  after an
emergency situation  occurs.
   According to Kenneth Big-
lane, Director of the  Oil and
Special Materials Control Divi-
sion, the team will function as
a special unit in his Division.
Although its location has not
been selected, it is likely to be
started in the heavily indus-
trialized areas of the eastern
United States. In general, re-
quests for the team will come
from the Regional Administra-
tor's Emergency Coordinator
once he has concluded that the
Region needs assistance. The
team will be particularly valu-
able when more than one Re-
gion is involved. An  incident on
the Ohio River, for example,
could involve Regions 3, 4,
and 5.
   On the scene, the  Emer-
gency Response Team will be
more than a "Band-Aid" opera-
tion, according to Ken Biglane.
Taking as an example a chem-
ical spill into a stream on a
Friday evening, Biglane says.
"The  Response Team will pro-

vide immediate assistance to
the Regional On-Scene Coordi-
nator monitoring the chemicals,
predicting when they will pass,
providing emergency water
treatment technology or arrang-
ing to have water trucked in.
The team will come up with
solutions, techniques, and
measures to minimize the im-
mediate threat, giving other
EPA program offices time to
marshal their resources."
   The Emergency Response
Team concept has its origin in
Section 311 of the 1972 Water
Act, which called for prepara-
tion of a National Contingency
Plan to handle spills of oil and
hazardous substances when the
spiller is not taking proper
cleanup actions.
   The plan, published in 1973
by the Council on Environmen-
tal Quality, coordinates  Federal
cleanup efforts. Responsibility
for on-scene coordination rests
with EPA for spills into inland
waters, while the  Coast Guard
in the Department of Transpor-
tation is responsible for spills
in coastal waters and the Great
   EPA draws its on-scene coor-
dinators from the 56 emergency
response specialists in the Re-
gional Offices. They are trained
in disciplines such as biology,
chemistry, engineering,  and
oceanography and are experi-
enced in cleaning up and re-
moving spills or mitigating
their environmental effects.
They also view and inspect the
spill control and countermeas-
ure plans that facilities handling
oil and hazardous materials
must prepare. EPA is involved
in about 3,000 spills a year, but
only 50 require an on-scene
coordinator to take over the
cleanup operation.
  EPA's emergency response
has not been confined to oil
spills, however. Although the
list of hazardous substances
was not designated until March
1978, EPA responded to such
spills in the interest of public
welfare. For example, EPA pro-
vided an on-scene coordinator
in October 1973 when 1 5 rail-
road cars derailed near Rush,
Ky., spilling acrylonitrile into
a nearby creek, and in Septem-
ber 1974 when 260 gallons  of
PCB's were spilled in the
Duwamish Waterway in
Washington State.
   The Response Team will also
provide EPA with new skills in
situations like that at the Ken-
tucky acrylonitrile case, where
the choice had to be made
between permitting the spilled
acrylonitrile to continue to burn
or to try to put the fire out.
Local officials decided to ex-
tinguish the fire although they
were uncertain about the air
pollutants resulting from open
   One member of the team will
be an expert in this area, al-
though predicting combustion
products under the highly vari-
able conditions of open burning
is tremendously complicated.
   The Response Team is likely
to be less hardware-oriented
than the Coast Guard's strike
forces, although it will have
some special mobile equipment.
The team will be responsible
for running the Environmental
Emergency Response Unit, now
operated by the Industrial En-
vironmental Research Labora-
tory in Edison, N.J. The unit is a
trailer mainly intended to re-
move chemicals by carbon ad-
sorption, but it uses a series of
physical and chemical proc-
esses in a versatile system suit-
able for on-site removal and
treatment of both chemicals
and oil.
   The team will also have
compact laboratory and moni-
toring equipment that can be
transported to the scene of an
emergency. Other special mo-
bile equipment will be added to
the Response Team's arsenal in
the future. Among them are a
special mobile incinerator now
being designed by the Office of
Research and Development and
the Dynactor, a reaction cham-
ber in which chemicals are
diffused into  small particles so
that they can  be treated very
   Eventually, Biglane plans to
have teams in Edison, Cincin-
nati, and on the West Coast.
With these teams, Biglane says,
"We hope to bolster State and
local programs for disaster as-
sistance. After all, the local
communities  are the ones on
the receiving  end of all environ-
mental catastrophies. They
need help. These teams are
programmed to provide that
help through  EPA's Regional
Offices." D
 Wanted: More
 Continued from page 22

 tions of scientists in health-
 related areas. These societies
 should also consider scholar-
 ship programs, prizes, awards,
 and other activities that might
 increase awareness of toxicol-
 ogy as a profession, conferees

 The Role of Institutions
 "The absence of a Federal Civil
 Service job  category entitled
 'toxicologist' is a severe imped-
 iment to effective recruitment of
 outstanding toxicologists into
 the regulatory agencies, since
 the entire existing Federal ap-
 paratus for advertising and hir-
 ing, as welt as for career ad-
 vancement, is based on the
 existence of a carefully defined
 Civil Service professional lad-
 der," the report noted. Without
 this job category, if a Federal
 agency needs to hire a toxicolo-
 gist it must fill a  job category
 called "biologist" or "pharma-
 cologist/toxicologist," and the
 qualifications most central to
 toxicology cannot be taken into
 account and rewarded ade-
 quately. For example, if a GS-13
 biochemist acquires additional
 skills in toxicology, there may
 not be a job category into which
 he or she can be  promoted that
 recognizes them. Yet it is this
 kind of retraining that is badly
 needed to meet the demand for
 toxicologists, the report noted.
   "We strongly recommend
 that the Civil Service establish
 a career category and promo-
 tional ladder for 'toxicologist,' "
 the report said. "Toxicology  is
 a profession; the establishment
 of a career ladder will aid the
 Federal Government in the re-
 cruitment and retention of qual-
 ified professionals. The Society
 of Toxicology, we believe,
 should address this issue, as
 should the officials in the Fed-
 eral  Government whose depart-
ments and agencies must recruit
 and retain highly qualified

The report added that there are
many opportunities for industry
to recruit trainees in toxicology.
Some companies have pro-
grams for training technicians
 and junior scientists, and these
 programs could be expanded,
 perhaps in cooperation with
 local universities. Industry also
 might explore cooperative pro-
 grams with universities, such as
 joint staff appointments which
 would involve the appointee
 more fully in the industry and
 the university.
   Industry is routinely asked to
 expand its support of university
programs in toxicology, and
 some have argued that industry
 has a principal responsibility
 for this training, since chem-
 icals are manufactured and
 marketed by industry, and
 roughly one-third of the pool of
 trained toxicologists finti em-
 ployment in industry, according
 to conferees. The consensus
 was that industry can and
 should contribute to training
 toxicologists at universities.
 They noted the training of toxi-
 cologists at universities is in
 large measure a public
   "At the same time, the rate
of development of industrial
research centers is staggering,"
the report declared. It is esti-
mated there was a 70 to 100
percent increase in industrial
toxicology facilities from 1975
to 1977, and that there will be a
further 100 percent increase
during the next few years.
   "There are not enough well-
trained people to go around,
and the hiring of toxicologists
from one institution to another
has already reached 'robbing
Peter to pay Paul' proportions,"
the report stated. "Clearly, in-
dustry has a major stake in
expanding the  supply of trained
professionals just to meet its
own needs. Greater financial
support  of toxicology training
programs by corporations
would both serve the national
interest and contribute to meet-
ing the need for toxicologists
which many industrial toxico-
logy laboratories already feel
acutely." D

Copies of the full report on
which this article is based may
be obtained from the Conserva-
tion Foundation, 1717 Massa-
chusetts Ave.,  N.W.,
Washington, D.C. 20036.

EPA Studies
Birth  Mishaps
In Oregon Town
                      News Briefs
EPA  is  probing  the  cause of  10 miscarriages
between 1973 and  1977 among  eight women in
a small Oregon  town to determine if the
mishaps were caused by herbicide spraying
in nearby forests.   "We're uncertain  at this
point whether herbicides are responsible for
the  miscarriages,"  said EPA  Administrator
Douglas M. Costle recently.  "But one  of the
herbicides in question, namely 2,4,5-?, has
caused  birth defects and stillbirths  among
laboratory animals  such as mice, rats,  hamsters
and  birds.  Another of the brush killers, Silvex,
is being studied  by EPA for  the same  reasons."
Also, Costle added, the Oregon women  have
stated  that the times of their miscarriages
correlate closely with the times of herbicide
treatments in the forests.
Blum  Testifies
On Inflation
EPA Tightens
Limit  For
Fuel Evaporation
"EPA's  regulations  are not  a major contributor
to inflation, although we acknowledge  our
responsibility to  seek least-cost approaches to
reaching environmental goals,"  EPA Deputy
Administrator Barbara Blum  recently told  a
House Subcommittee.   Although EPA's regulatory
actions  have an  impact on the Consumer Price
Index  (CPI), Blum  said, "any conceivable
modification of  current regulations would not
substantially alter the nation's underlying
inflation rate."   Environmental cleanup results
in a number of positive and anti-inflationary
effects  such as  fewer illnesses, fewer lost
work days, and lower medical bills, Blum told
the Subcommittee on Economic Stability of the
Committee on Banking, Finance and Urban Affairs.

EPA Administrator  Douglas M.  Costle recently
announced a tougher standard for the reduction
of evaporative emissions for gas-fueled cars
and light trucks,  starting  with the 1981  model
year.   The new standard will reduce nationwide
hydrocarbon emissions from  all mobile  sources
by as much as 10 percent in 1985, and  25  percent
by 1990.   It will  replace the standard which
began with the 1978  models.   Evaporative  emissions
are the  hydrocarbon molecules in gasoline vapors
that escape from cars and trucks in addition to
emissions in the exhaust.
States Served by EPA Regions
Region 1 (Boston)
Connecticut, Maine.
Massachusetts, New
Hampshire, Rhode Island

Region 2 (New York
New Jersey, New York,
Puerto Rico, Virgin
Region 3
Delaware, Maryland
Pennsylvania, Virginia,
West Virginia, District
of Columbia

Region 4 (Atlanta)
Alabama, Georgia,
Florida, Mississippi,
North Carolina, South
Carolina, Tennessee.
Region 5 (Chicago)
Illinois, Indiana, Ohio,
Michigan, Wisconsin,

Region 6 (Dallas)
Arkansas, Louisiana,
Oklahoma, Texas. New
Region 7 (Kansas
Iowa, Kansas, Missouri,

Region 8 (Denver)
Colorado. Utah,
Wyoming, Montana,
North Dakota, South
Region 9 (San
Arizona, California,
Nevada, Hawaii

Region 10 (Seattle)
Alaska, Idaho. Oregon.

Lewis Hughes
He has been appointed Deputy
Associate Administrator, Office
of Internaiional Activities.
  Dr. Hughes previously
served as Acting Chief of the
Institutional Operations Office
of the National Aeronautics and
Space Administration, Ames
Research Center, Moffett Field,
Calif. From 1972-78 he was
Chief of the Health and Safety
Office at Ames Research Cen-
ter where he worked closely
with members of the European
Space Agency and other for-
eign organizations using the
  Dr. Hughes was  Radiological
Safety Officer at the University
of California in Berkeley 1965-
72 where he also lectured in
the  School of Public Health on
radiation safety measures. He
was a health physicist at Law-
rence Livermore Laboratory
1956-65. Earlier he served in
the  U.S. Army Field Artillery
with the rank of 1st Lieutenant.
  He received the NASA Ex-
ceptional Service Award in
1976 and the NASA Group
Achievement Award in 1 977.
  He received an A.B. degree
from West Virginia State Col-
lege in 1951, an M.S. from
West Virginia University in
1958, and a Ph.D. from the
University of California, Berke-
ley, in 1972. Dr. Hughes is
author of 34 scientific reports
and manuals.
Guanita Reiter
The Special Assistant to Region
6 Administrator Adlene Harri-
son recently won the Barbara B.
Tennant Award from Federally
Employed Women (FEW), an
organization dedicated to win-
ning equal opportunity for
working women. Reiter won the
award for her efforts in han-
dling the International  Women's
Year National Conference in
Houston, Tex. She was respon-
sible for registering over
23,000 participants at the Con-
ference. She also won  the EPA
Bronze Medal for excellence in
the Federal Women's  Program
in June, 1977.
Joseph Padgett
The Director of the Strategies
and Air Standards Division at
Research Triangle Park, N.C.
was recently elected to a 3-year
term on the Air Pollution Con-
trol Association's Board of
Directors. Padgett began his
professional career in  1948
with Westinghouse Corporation
as a design engineer. Since
then he has worked for a num-
ber of private companies in
various engineering and mana-
gerial positions, including the
USI Technical Center,  Parsons
Corporation, and the Atlantic
Richfield Corporation until
1 970, when he began working
for the United States Postal
Service. In 1971 he joined EPA
as Chief of the Systems Anal-
ysis Staff in the Office of Air
Programs and assumed his
present Directorship in 1972.
Padgett received his B.E. De-
gree in Mechanical Engineering
from the Johns Hopkins Univer-
sity in 1948 and an M.S. in the
same field from the California
Institute of Technology in
1951. He is a registered Pro-
fessional Engineer in the State
of Ohio and holds several
Lam K. Lim
He has been cited by President
Carter for initiating and imple-
menting the EPA Value Engi-
neering Program as part of the
Construction Grants regulations
at a savings to the government
of S75 million. Lim is a sani-
tary engineer with the  Muni-
cipal Technology Branch, Muni-
cipal Construction Division.
He heads an independent team
of design engineers who review
proposed construction projects
for unnecessarily high costs
and suggest cheaper alternative
methods of completing the
project. Although voluntary at
first, Value Engineering analysis
is now required of all projects
costing  $10 million or more
which seek grants. Lim also
received the EPA Bronze Medal
for his services in June 1977.
James A. Chamblee
He has been cited by President
Carter for outstanding accom-
plishments as Chief of the Pri-
orities and Needs Assessment
Section, Water and Waste Man-
agement Program. In a recent
letter the President specifically
thanked him for his money-
saving efforts in reducing gov-
ernment forms. Chamblee, who
is responsible for conducting
the 'State Facility Needs Sur-
vey', redesigned the Survey
questionnaire from its old 37-
page length down to just one
page, saving the government an
estimated $1.2 million in re-
lated processing costs. He also
was cited by Administrator
Douglas M. Costle for  his ac-
complishments in carrying out
the Survey itself. He was pre-
viously awarded the EPA
Bronze Medal in June 1977,
and in December of that year
received  a $2,300 cash award
as a Special Achievement
Award for Special Service.
Sarah T. Kadec
She has been appointed Assist-
ant Director for Information
Services at the Executive Office
of the President, reporting to
Richard Harden, Director of
   Mrs. Kadec has served as
Chief of the Library Services
Branch at EPA Headquarters
since May, 1971. In  1975 she
was awarded the EPA Silver
Medal for Superior Service. The
previous year she received  a
commendation from the Admin-
istrator for helping to establish
the Federal Energy Administra-
tion's National Energy Informa-
tion Center.
   Mrs. Kadec received an A.B.
degree in 1952 from Madison
College and a Master's degree
in library science in 1961 from
the Carnegie Institute of Tech-
nology. She has been involved in
library and information systems
work for a number of Washing-
ton-area industries and agen-
cies and taught at the Univer-
sity of Maryland and Catholic
University library schools.  In
1969-70 she served as a con-
sultant to the Center for Scien-
tific and Technological Informa-
tion in Tel-Aviv.


The  Rocky
By Alan  Merson
Every Region contains, in some
measure, what Region 8 epito-
mizes: areas of clean air, clean
water and land largely un-
spoiled by man. While EPA's
foremost priority must, of
course, be protection of the
public health. Region 8 must
necessarily  interpret that goal
in the context of a prevention
  The factor driving that strat-
egy more than any other is the
rapid economic growth over-
taking the six States of Region
8, but largely concentrated in
the  energy-rich inter-mountain
region, where a majority of the
Nation's energy resources for
the  next hundred years will
probably be found. The clash
between Region 8's still rela-
tively undeveloped land mass
and the rapidly accelerating
pace of energy development is
producing, in some areas, a
dramatic discord which can
only reach a crescendo in com-
ing  years.
  Virtually  every major issue
confronted by our Regional
Office is an outgrowth of this
clash. Exploding population
growth in Denver, Salt Lake
City, Billings, Casper, and
Grand Junction all represent
variations of this theme in addi-
tion to the smaller, more obvi-
ous, energy  boom towns, such
as Craig, Colorado, and Rock
Springs and Gillette, Wyoming.
  It seems appropriate, there-
fore, to depart from the format
of previous  Regional Office
narratives in order to illustrate
in anecdotal fashion the work-
ing  out of this theme. This is
not  to say that Region 8 ne-
glects EPA's more traditional
environmental clean-up func-
tions. Our Enforcement Divi-
sion, for example, recently
secured a settlement with a
major steel mill in Colorado,
which will result in probably the
cleanest coke oven emissions
in the Nation. We maintain an
active permit enforcement pro-
gram against major polluters of
the  numerous streams rising
within our region, although it is
mo re likely to be concerned with
mining than manufacturing
activities. We have active
solid waste, radiation and
noise programs which, al-
though short on resources,
have been long on innova-
tion and creativity. We have
had an extensive involve-
ment in pesticides,
and are currently admin-
istering one of the few EPA-run
pesticide certification programs
in the Nation. We have a special
concern with toxic substances
in the Denver area.
Still and all. Region 8 remains
basically clean. How to keep it
clean is our greatest challenge.
Let us examine four cases, be-
gining with the City of Denver
  Once famous for pristine  air,
Denver has witnessed a grad-
ual worsening of air quality
over the past decade until it
now ranks as the second dirti-
est metropolitan area in the
Nation. For many years, efforts
to improve Denver's air quality
met with  little interest or com-
mitment on the part of the pub-
lic. Last fall and earlier this
year, however, Denverites ex-
perienced a growing number of
increasingly serious air pollution
alerts.  Public opinion surveys
indicated that air quality was
the single most disturbing issue
to residents of the Denver area.
Last November the Regional
Office detailed 1 5 of our em-
ployees to a Denver Air Task
Force to work exclusively on
Denver's air crisis, first to mo-
bilize the 43,000 Federal em-
ployees of the Denver area to
end their  reliance on single
occupancy vehicles, and, sec-
ond, as Federal efforts in such
example-setting became visible,
to assist the private sector in
doing likewise.
  This strategy, developed
with State and local officials
and with our sister Federal
agencies, was commended by
President Carter during his
visit to Denver on Sun Day last
May. The President pledged
his personal support for Den-
ver's clean air campaign and
asked that EPA and the  Federal
Regional  Counsel coordinate
an aggressive Federal effort  to
support local initiatives. The
President catalogued some  $42
million that will ultimately be
made available for the Denver
air project, including money for
transit-related construction,
free off-peak hours bus service,
electric car demonstrations, an
inspection and maintenance
awareness campaign, meas-
ures to prevent tampering with
emission controls, and a direc-
tive to our Regional Office to
report to him on a monthly
basis on the progress of this
   Another regional issue of
major importance is closely
linked with the Denver air qual-
ity picture and is an excellent
example of the interrelation-
ship between air, water, and
land use. The Foothills Project
is a proposed water treatment
plant, dam, reservoir, and tun-
nel system designed to nearly
double the Denver Water De-
partment's treatment capacity.
Since some public  lands are
involved in the project area, an
environmental impact state-
ment (EIS) was prepared. It fell
to this regional office to review
that statement under the Na
tional  Environmental Policy
Act and section 309 of the
Clean Air Act.
  After extensive review, Re-
gion 8 concluded that the im-
pacts of the project were sub-
stantial and that alternatives to
the project had not been ade-
quately considered.
  On that basis, we referred
the matter to the President's
Council on Environmental
Quality. CEO agreed with our
assessment and recommended
that right of way permits be
denied by the Federal agencies
managing the lands in the
project area. The permits were
nevertheless issued.

   Region 8 was then asked to
advise the Army Corps of Engi-
neers as to the propriety of
granting a dredge and fill per-
mit for the proposed dam under
Section 404 of the Clean Water
Act. The Region conducted two
lengthy public hearings pri-
marily to determine whether in
fact less environmentally dam-
aging alternatives to the pro-
posed dam had been adequately
investigated. Concluding that
they had not, the Region recom-
mended against issuance of the
permit, leaving it now for the
Corps to decide that issue. In
response to considerable Con-
gressional interest, the Corps
has agreed to undertake an
exhaustive analysis of alterna-
tives before rendering its deci-
sion. This in itself goes a long
way toward meeting the Re-
gion's concerns.
   Whatever the outcome,  the
link is established. Water avail-
ability helps shape growth pat-
terns  which in turn largely
determine the quality of air in
the region.
   That same link exists in
wastewater treatment, a fact
which has led us to the prepara-
tion of an "overview" environ-
mental impact statement to
examine the cumulative im-
pacts of funding ten waste-
water treatment projects in the
Denver metro area.
   Funding of additional waste-
water treatment capacity sup-
ports  growth. Growth without
commensurate air quality con-
trols will result in continued air
pollution problems in the Den-
ver region. In the framework of
the EIS and of the 208 planning
process, we developed policies
which will guide our future
funding of treatment works,
   The philosophy behind the
overview EIS assumes that
Federal expenditures  in many
of our urban areas shape
growth. Here, as in 208 and
State Implementation Plan
revisions, Region 8 is working
to insure that Federal  managers
carefully evaluate the impacts
of these expenditures as they
affect environmental  quality
and to do so in cooperation
with other agencies whose pro-
grams may cross-cut one
   Yet another example of the
responsibility placed upon our
Region to perform its function
of safeguarding environmental
quality in areas of rapid devel-
opment is the coal-fired power
plants at Colstrip, Montana.
Two plants there now generate
some 700 megawatts of elec-
tricity. Construction of two
additional units which would
each generate an additional
700 megawatts has been
   Approximately twenty miles
from Colstrip lies the Northern
Cheyenne Indian Reservation,
an area of Class I air quality
under the Prevention of Sig-
nificant Deterioration policy.
Montana Power Company, rep-
resenting a consortium of
utilities, app ltd In pre-con-
struction pern-it^ under this
policy, which is, ot course, de-
signed to protect the quality of
air already  cleaner than that
required by the National Am-
bient Air Quality Standards.
   Extensive analysis of data
generated by computer mocfei-
ing and actual meteorological
data led us to conclude that
Colstrip Units 3 and 4, if built
as planned, would violate al-
lowable increments of sulfur
pollution on the reservation.  In
the three-year period analyzed,
violations would have occurred
on at least 19 days. Congres-
sional changes in the Clean Air
Act of 1977 allow one such
violation. We thus had to deny
the permits in the face of over-
whelming local support for the
plants as well as a strong re-
gional and national  interest in
generating additional power.
   The final outcome of the Col-
strip issue is not clear at this
time. There is the possibility of
further administrative action as
well as litigation, but it does
serve, again, as an example of
the energy vs. environment
dilemma Region  8 constantly
   The bottom line in this Re-
gion 8 report must, of course,
be the competence, courage.,
and dedication of Region 8 em-
ployees in performing tasks of
inestimable value for this coun-
try in the face of  something
less than total acceptance of
our role by much of the public.
And therein  probably lies our
Region's greatest challenge in
the coming months and years:
building a broad-based con-
stituency for the  values we
seek to serve, f
This is the plains country EPA
has been seeking to protect
near Colstrip, Mont.

Back cover: One of New York
City's sludge-dumping vessels
carries waste from sewage
treatment plants into the At-
lantic Ocean for disposal.

                                                                                                            V  ft
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                                           United States
                                           Environmental Protection
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