READING THE FACT- FINDING PANEL'S REPORT ON HERBICIDE 2,4,5-T

Following are some of my concerns regarding the 2,4,5-T Report. The Panel concluded that TCDD (Dioxin) had only indirect carcinogenic effects and a general lack of mutagenicity. Hence "...the threshold model was appropriate for application to 2,4,5-T and its contaminants.". They also claim that "...a tolerable intake could be established for TCDD on the basis of the assumption that there is a threshold for all effects, including cancer...".

"The re-creation of exposure events that occurred decades ago is rife with unknowns and uncertainties. As such, many decisions were made along the way that influenced the outcome of the assessment.". Finally "Each of the decisions and input variables contain some element of variability and uncertainty, which can effect the final results and conclusions.". Well isn't that just dandy. Basically on page four the Panel are advising readers that the whole process is no more than educated guesswork, at best. At worst it is scientific mumbo jumbo hiding the provincial government's culpability in the poisoning of Ontario citizens. Then at the end of the same paragraph they have the brass to suggest however that due to allegedly using assumptions that overestimate risk, that their assessment errs on the side of safety. There is an old joke about when you ASSUME you make an ASS out of U and ME.

The first poor assumption in the report (pg. 5) deals with contaminated clothing of the employees applying the herbicide. "Exposure to contaminated clothing was possible for several receptor groups, but because the panel thought it to be less likely and less easily quantifiable it was not included in the mathematical modelling.". Wow! I find that mind boggling!

Also on page 5, "Although the panel assessed and documented the evolution of pesticide use standards and regulations in Ontario, it could not determine the extent to which practices intended to protect the general public or to protect workers involved in pesticide handling, mixing, loading and application were practiced, monitored or enforced.'. Again that is another vital piece of information missing from the equation.

Page 6 informs us of the only slightly hypocritical and uninformed knowledge level as early as 1954. " herbicides are known to be non-toxic to man and animals but operators should minimize breathing in the mist, or having it contact their faces.". So which is it? Non-toxic or dangerous enough you shouldn't even get it on your skin?

We are also informed that other provincial government departments used 2,4,5-T but the MNR, Min. of Transport and Ontario Hydro used the most. Allegedly, according to the Panel, private and municipal use was much greater than that of the province of Ontario. I find that rather strange as the Panel claim that they did not study or evaluate anything but provincial use so how did they determine that private (farmers) and municipal use was far in excess of provincial use?

Page seven has a ridiculous paragraph claiming that "None of the bystander exposures to 2,4,5-T for Ontario Hydro, MNR and MTO exceeded the benchmark level." Unfortunately the very same paragraph suggests otherwise. It appears as if the Panel's Report is playing with words and being intentionally obtuse.

The report while admitting some occupational exposure above safety standards is very carefully doing its' best to minimize admitting any possible exposure of bystanders or the general population. Even when they admit to exposure levels above the manmade calculations based upon assumptions; they still only state that people's health "could" be affected.

Once again I see politics doing its' best to use science and scientific limitations to avoid responsibility towards citizens. The fact is that our governments authorized distributing toxic substances including Dioxins throughout Ontario and now they are trying to avoid responsibility for so doing. To date my opinion is that this Report is a classic government attempt to avoid blame that rests squarely on their shoulders. Spending billions of dollars on health care is just dandy but that does not justify our provincial government weasel wording and stickhandling their way out of greater responsibilty towards their citizens.