Friday, January 24, 2020


TAG - Technical Advisory Group

We were presented with a 40 minute Webinar (web based seminar) last evening. Despite my critical comments here beforehand, in fact the Webinar was very informative. It did start off however very clearly advising that polluters have two options. Option 1 is to remediate the contamination to the legislated numerical standards and criteria. Option 2 is to conduct a Risk Assessment and then to "manage" the excess risk. The gentleman presenting the webinar was very clear that Option 2 was more "cost effective". Cost effective in plain English means cheaper. He also advised that there were some liabilities with Option 2 namely ongoing monitoring and maintenance of any engineered methods used to "manage" the risk. Also he had the good graces to advise that past stigmas around owning contaminated sites have dissipated dramatically.

The webinar also referenced the Risk Paradigm. This is three intertwined circles representing Contaminants in one circle, Receptors in another and Exposure Pathway in the third. Where these three circles all overlap is supposed to be the amount or extent of Risk. In fact this Paradigm makes it very clear to me that polluters (and sometimes their regulators) have golden opportunities to fudge the entire process. They can artificially reduce the number and extent of contaminants by arbitrary screening methods. They can increase the Method Detection Limits (MDL) higher than the provincial/federal criteria and standards in order to miss huge numbers of toxic chemical exceedances. They can use unsatisfactory sampling methods such as shovels versus core samplers which miss much of the fines during creek bed sampling. The fines are where the hydrophobic compounds such as DDT, Dioxins, PCBs etc. are normally found. As far as Receptors go it is child's play to ignore higher up the food chain receptors of highly contaminated fish and benthic organisms. By simply not testing tissues of higher predators there will be no scientific evidence of further bio-accumulation of toxins from the creek. Similarly Exposure Pathways can also be fudged mercilessly. All three of these circles need to be investigated and researched by independent and unbiased parties. Simply allowing the polluter to hire his longtime, highly paid consultants with a huge conflict of interest is ridiculous.

It boils down to trust and confidence. If one has had thirty years of being ignored, lied to and deceived both in person and in report after report produced by parties working on behalf of the polluter then you will receive absolute crap. That is the reality and exactly what has happened in Elmira, Ontario. It continues in the supporting documents being produced for this Risk Assessment and will continue in the Risk Assessment itself. I believe that it is possible for an unbiased but knowledgeable party without self-interest involved to produce a relatively good Risk Assessment. Those are not the circumstances regarding the Uniroyal/Lanxess Site Specific Risk Assessment.

Further details on other matters from last evening's TAG meeting will be presented here tomorrow.

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