Date: Sun, 11 Sep 2005 23:54:13 -0400
To: Linda D Dykema
Subject: Commentary on MDCH PEI Dioxin Exposure
Please include this email with the comments compiled on the subject report.
TO: Dr. Linda Dykema, Toxicology and Response Section, at 1-800-648-6942.
FROM: Bill Egerer, Midland Matters
DATE: Sept.11, 2005
RE: Comments on MDCH “Pilot Exposure Investigation Report dated July 8th, 2005
The PEI report and process producing it documents and verifies serious failings in MDCH’s regulatory and communication responsibilities for Michigan residents. The entire PEI process; from its inception, design, conduct, communications and final reporting, verify that resident groups concerns with MDCH’s lack of sound science is no longer anecdotal, but a systemic issue within this agency’s entire operation. Immediate and extensive oversight of this agency’s conduct is needed to protect the public from their continued “witch hunt” approach to handling public health and public policy matters. Left unchecked, this agency appears driven to conduct actions of ungrounded fear mongering, divorce itself from cooperating with local health officials and mostly significantly, a blatant disregard and refusal to rely on peer reviewed scientific method (sound science) in their conduct.
The MDCH Mission, Vision and Goals document its purpose and focus on resident needs, specifically ….“effective strategies that are culturally responsive and competent, customer-driven, and community-based, which leads to quality health outcomes.
The conduct of MDCH on this entire PEI process was not scientifically competent; was not customer-driven and certainly was not community-based. Without the trust of the very people MDCH is suppose to serve, the question of “capacity to carry out their charter” must be asked.
NOT SCIENTIFICALLY COMPETENT
From beginning to end, MDCH violates the very protocols of the study it created.
In just one example: Individual results cannot be SIMPLY READ. They must consider a long list of other factors to be of any meaning.
TAKEN DIRECTLY FROM THE STUDY COMMENTS: Conclusions regarding the source of an elevated blood level can only be determined after careful analysis of a number of factors; e.g. age, body weight, recent weight loss, occupation, lifestyle, lipid levels, smoking and diet, particularly consumption of local fish. Only after these considerations along with a careful analysis of possible exposure pathways can conclusions regarding possible exposure sources be reliably made. This level of evaluation is beyond the scope of this study from both a design and statistical analysis perspective.
Both in the study responses to comments and in real life, MDCH is vague to "missing in action" on this topic. MDCH says tested residents should take their results to their own physicians and did NOT incorporate any venue for having the results explained to them by experts. This is formula begging for misunderstandings. How can personal tests be conducted on a human involved with such a volatile subject matter as a "toxin" and MDCH just “throws out” the information without adequate support?!?
The MDCH arrogance reached an apex during the protocol commentary stage when it was asked to include the resumes and credentials of its researchers in the study documents. MDCH’s response: NO!
I’m a layperson, but could not locate a scientist who found the PEI “study” worthy of any merit in its flawed design, communications and ultimate reporting with deliberate exclusions of other pertinent information. If MDCH is satisfied, or even pleased with the competence of their own work, then they should subject it to the rigors of the scientific communities and allow them to evaluate its scientific worthiness and credibility.
From the perspective of resident groups formed to have a voice independent from the organized environmentalist groups, MDCH is responsive only to environmental activists and their sympathetic media. Anyone even modestly engaged in the Saginaw Valley dioxin issue knows it easily creates attention, varied opinions, emotions and volatile questions whenever a new development occurs. Seldom is there solid consensus on any development. And yet, MDCH proceeds with issuing individual results to study participants with little to no explanation of how to interpret the results. They manage to “stroke” the media into a frenzy of reporting false interpretations, fail to initially consult with local health officials and basically leaves the community situation to feaster without any expertise to intervene. Not until Dow’s Dr. Carson published a full page “Understanding Dioxin Concentrations in Blood” explanation in local newspapers was the disastrous communications situation put to rest.
During the past 18 months, I’ve grown accustom to expect these “environmental activists” type behaviors from MDCH. Its consistent with how they issue fish warnings without notice or involvement of local designated health officials. The PEI release of information appeared deliberate by MDCH in trying to cause fear in the communities and jump to public policy conclusions.
NOT COMMUNITY BASED
MDCH rigidly maintains a Lansing based operation and disregards trying to coordinate or involve the local health officials from Saginaw and Midland. These officials are not provided advance notice on health advisories and were not engaged prior to the MDCH release of individual’s scores on the PEI study. Its nearly impossible to believe this is some type of oversight, since MDCH seems to have no difficulty in reaching media sources that are sympathetic to cover and publish their messages of fear, concern and directives. Any legitimate regulatory agency that had sincere interest in the local regions people getting an advisory, would certainly work directly with that locals health professionals. MDCH has heard this resident complaint before and chooses to “go it alone” so they are not held accountable.
The original PEI design, protocol, communications and reporting should have had serious and active engagement of local community health professionals. The degree of any involvement was too little, too late and that was the MDCH plan. MDCH does not operate with a “Community Based” agenda.
As a lifetime Michigan resident, taxpayer and property owner in the Saginaw Valley area, I register my protest and objection to MDCH’s handling of the entire PEI process. My experiences with MDCH activities during the past 2 years shows they threaten my property ownership value, my livelihood and my quality of life. Many residents did not trust MDCH in early 2004 and this PEI report, issued July 2005, further erodes this lack of confidence.
I will request my elected officials become engaged to provide investigation, oversight and accountability for any further MDCH actions related to this report.
Bill Egerer, Founder