THE INVISIBLE VICTIMS OF DIOXIN IN ONTARIO

The following is one of the 4,000 records provided to the Fact-Finding Panel on Herbicide 2,4,5-T. It is on-line and can be accessed by googling "Welcome to Ontario 2,4,5-T Records Online".



March 24, 1980

Dear Sir:

I am writing to you because of my concern over the decision of the Ontario Government to lift the ban on spraying underbrush in the cottage areas with 245T or dioxin. The Ontario Hydro is apparently preparing to spray in the Chandos Lake area near Apsley.

My father bought property on Chandos Lake in 1924 and we have used the cottage on this land ever since. In 1949 I spent two months in the summer there with our two young children in order to escape the heat of a tiny city Apartment. The Ontario Hydro had cut through our maple sugar bush just 40 feet behind the cottage without any permission a few years previously. During this summer of 1949 the raspberry bushes came up in profusion on the hydro cut in many areas. We picked and ate raspberries for several weeks and even froze some. I learned later that the hydro had sprayed the hydro cut with 245T that Spring or previous Fall. Many people were furious as they noticed the drop in bird population. I had become pregnant in August that Summer and in October had a miscarriage. I knew not why. I had had two previous full term pregnancies and produced two very healthy babies. I became pregnant several months later and at eight months a badly deformed baby was stillborn. It was not until a few years later when I heard on a C.B.C. Farm Broadcast that the spraying of 245T was banned from highly populated areas because of birth defects that I realized why I had had this traumatic experience. Neither my husband nor I have ever smoked or drank and I had never taken drugs or anti-nausea pills of any kind during any of my pregnancies. We were living in Windsor, Ont. at the time and a stillborn death there would not be linked with the Chandos Lake area.

I went through six years of hell until my third child was born strong and healthy, but I was still fearful of having another pregnancy. As a further follow-up to this, my daughter who loved to pick and eat berries with me, has never had a proper menstrual cycle and cannot have her own children. She has had many examinations to determine the cause of this but the Doctors cannot find any reason whatsoever. In every other way she is physically and mentally exceptional having excelled in sports as well as scholastically. The son of one of our cottage neighbours lives in a wheel chair because of a spinal injury he was born with. His mother was with me for a week that same summer. His grandmother has since died of leukemia. Now I know that the "experts" will say there is no scientific proof that 245T is responsible for what I went through, but I have heard of many law suits being won on less evidence. Maybe I should have brought suit against the Hydro years ago, but I could not have faced this experience.

I do hope you can bring pressure to bear on the Ontario Government and Ontario Hydro to forbid the spraying in any area of our country. Hopefully this letter will further the case against spraying 245T. After all people take their children, as I did, to the country in the summer to avoid pollution. And for what? Surely the cottagers should be allowed the peace of mind when in the bush to feel confident that their children and grandchildren can eat the wild straweberries, raspberries, and blackberries etc. that come up so quickly after a clearing is made.

I think we should encourage the young people to do the underbrushing on the hydro cuts as we have been doing behind our cottage ever since. The hydro can come in and cut large branches of trees that pose a danger to the wires but under no circumstances should they be allowed to do any spraying at all not even by the so called "controlled" spraying by experts.

Sincerely



Birth defects, reproductive problems and spina bifida are all recognized consequences of exposure to 2,3,7,8 TCDD (dioxin). The Ontario Ministry of Natural Resources, Ministry of Transport and Ontario Hydro all were concerned with the health of their (male) workers applying these herbicides. I wonder how many wives and families were damaged by exposure to clothing etc. worn by these same workers. None of this whether in Vietnam, Canada or the U.S. had to happen. Corporate greed and stupidity enabled by morally bankrupt governments protecting corporate interests led to this disaster.

SCIENCE, POLITICS & MONEY. THE LAST TWO USUALLY TRIUMPH OVER THE FIRST

I have been going through a website which purports to be "Welcome to Ontario 2,4,5-T Records Online". Firstly I see nowhere near the 4,000 plus records that supposedly were made available to the Facy-Finding Panel in their Report released in June 2013 in the Ontario legislature. Secondly the opening page lists all the exceptions and deletions in records that occurred allegedly under the Freedom of Information and Protection of Privacy Act as well as under the Copyright Act. Personally I give those allegedly legal reasons very little credibility because my experience and others with FOI is that it is legislation, only in name, to assist citizens to access government data. Finally as indicated, the opening page also indicates numerous records have been blanked out or deleted as allegedly being "Not Relevant". Indeed many of the listed records are simply blank pages. Obviously very unimpressive.

To date I have downloaded about a dozen of what appeared to be the most interesting records. Lots more to go. One is a letter dated February 14, 1966. It simply is a Memo to "All Area Managers, Central Region" asking for their pesticide requirements for the upcoming 1966 season. It is under the subject Forestery- Brush and Weed Control chemicals. The first two chemicals are Brushkill, 2, 4-D & 2,4,5-T mixed followed by Brushkill, 2,4,5-T (For Resistant Brush). It is my understanding that Brushkill is one of the brand names for Uniroyal Chemical's products produced here in Elmira, Ontario. The other name is Brushbane .

There are three records I've seen to date which indicate a strong counteroffensive to honest efforts to determine human health effects caused by Agent Orange, 2,4,5-T and Dioxin (2,3,7,8 TCDD). The first is a December 22, 1969 letter to Dr. Lee A. DuBridge, Science Adviser to the President (U.S.). It is critiquing a Report titled "Teratogenic Evaluation of 2,4,5-T" and clearly this multipage critique written by Glenn Klingman, President of the Weed Science Society of America, is self-serving. Just as clearly this Weed Science Society of America is some kind of chemical industry lobby group. Mr. Klingman has cc' d the following chemical manufacturers namely Diamond Shamrock, Dow Chemical, Hercules, Hooker Chemical and Monsanto.

There is also a letter dated February 26, 1970 from a Donald Grant, Director of Medical Services presumably for Ontario Hydro. He has sent it to Mr. J.E.F. Winter, Chief Forester of Ontario Hydro. This letter references a number of newspaper articles from both Canada and the U.S. warning of the health hazards of 2,4,5-T. Mr. Grant quite brusqely sweeps aside those public concerns as he states "The herbicide spray program for brush and weed control within Ontario Hydro should be continued without fear of harmful effects to our employees or the public.".

The third letter dated February 23, 1972 is from Dow Chemical of Canada, Sarnia Ontario. It is written by a Mr. Wiffen and sent to a Mr. J. VanRees presumably also of Dow Chemical. It is advising Mr. VanRees regarding his presentation to Ontario Hydro about 2,4,5-T and Dioxin! Two sentences many pages later state "...of the fact that there is a growing preponderance of scientific evidence and regulatory opinion attesting to the safety of 2,4,5-T to health and the environment." This is followed by "...discussion of 2,4,5-T and estimates of hazard from registered uses of the commercial herbicide quickly turns to the conjectural aspects about 2,3,7,8 tetrachlorodibenzodioxin (TCDD)."

Tomorrow's posting will show other records indicating the opposite of what these three persons were trying to get across to decision makers and some of those with vested interests in keeping 2,4,5-T on the market.

THE ONTARIO FACT-FINDING PANEL DISCUSS INTERPRETATION ISSUES IN HEALTH STUDIES

Epidemiological or health studies of human beings exposed to a particular chemical or physical irritant of some nature are extremely unlikely not to have some major issues. These include having a large enough group of people to make a statistically valid comparison. They include having a group of individuals exposed to the item of concern, such as TCDD, and then being able to compare their health to a relatively equal group of individuals who have not been exposed. By a relatively equal group we mean of similar age, similar genetic background , similar diet, similar overall health originally etc..

Other issues in this study would include the impossibility of having perfect knowledge. How many of us can remember an exposure say to an on the job solvent that occurred twenty-five years ago? Yes if you collapsed at the time due to an acute exposure you probably would remember. Otherwise not. How many of us have been exposed to a chemical and not even known it? This exposure could be via air, food or water. Therefore determining who is in the control group allegedly not having been exposed to the chemical of concern is a difficulty.

The Panel discuss at length problems with exposure assessment. "Even the most comprehensive and high-quality epidemiological studies typically have monitoring information on exposure for only a few points in time for some of the study population, which must be used to represent the exposure history of the entire population. Thus for most of the timeframe covered by any epidemiological study, exposures must be estimated or extrapolated, from a relatively small amount of monitoring data...". Thus exposure misclassification can lead to either false negative conclusions or to false positive conclusions regarding associations between TCDD and health.

The Panel then states "Clearly, exposure misclassification can and probably does have a powerful effect in nearly all observational epidemiology studies. What's more, it typically drives relative risk estimates towards the null.". Also disease misclassification can and does occur. Current medical records are considered for example a much better indication of cancer presence than death certificates listing the cause of death.

Confounding is a huge issue which can only be somewhat mitigated in these studies. Obesity and smoking for example are risk factors for many diseases. Suggesting that a persons' cancer is caused by exposure to a single large exposure to TCDD may not reflect a lifetime of smaller exposures to TCDD through foods and inhalation. Similarily suggesting that exposure to TCDD through annual road spraying wasn't large enough to cause their cancer probably is ignoring their previous exposures to TCDD by eating fish downstream of Uniroyal Chemical or even through exposure from spraying of nearby Ontario Hydro power lines. To date I have seen no suggestion that this study has considered multiple exposures to 2,3,7,8 TCDD and or 2,4,5-T from many other known sources in our environment. In other words it is not accurate to separate out Ontario government causes of TCDD exposure and suggest that they haven't added to citizens toxic burden.

Another well recognized confounding variable is known as the "healthy worker effect". In essence the Panel are focusing on workers exposed to 2,4,5-T and TCDD and comparing them to the general population. However the forestry and Hydro workers as a group are probably healthier (at least initially) than the general population in order for them to be working full time. Also the general population includes the very elderly who are more likely to have serious other health issues.

The Fact-Finding Panel concluded that as much as possible the studies they reviewed all considered possible limitations of epidemiological studies. While that is mildly comforting that is all it is. While I'm not suggesting any flaws specific to the Panel's work, I am suggesting that the whole field of risk assessment is fraught with information difficulties, assumptions and extrapolations. Perhaps the mathematical models and calculations are the best we've got. Perhaps the best we've got is significantly underestimating the effects of Ontario's poisoning of the environment. Perhaps not. It was still incredibly stupid for an incredibly long length of time.

THRESHOLD VERSUS NON-THRESHOLD CARCINOGENS

"A non-threshold carcinogen is usually genotoxic and is presumed to have no safe dose. A threshold model is based on the assumption that developing cancer requires a minimum level of exposure (the threshold), below which no cancer will develop."

In 2006 the U.S. EPA asked the National Research Council (NRC), part of the National Academy of Sciences (NAS), to review the 2003 version of the U.S. EPA assessment of the health effects of TCDD and related compounds. While they agreed with the EPA's findings on a number of matters they did however find "...that the EPA's decision to use only the non-threshold model for extrapolation was not adequately supported and recommended that U.S. EPA use both threshold and non-threshold models to extrapolate risks at lower levels.".

There have been studies and assessments by Health Canada, the Canadian Council of Ministers of the Environment (CCME) and numerous other studies by individual scientists over the decades. Most of the results have been supportive while some studies have been less supportive of particular findings. For example some studies show a clear association of TCDD with diabetes, others less so. One study strongly stated that their review indicated that "...results were consistent for an association with defective brain development in infants.". Also some studies believe that there is a strong association between ischemic heart disease and TCDD and a weaker association between TCDD and all cardiovascular disease.

The loopholes for both government and industry to avoid accountability for their culpabilty in the pain, sufferring and death of hundreds of thousands to millions of Canadians are immense. These studies are at the population level not the level of the individual. Therefore for an individual to sue for damages for the pain and sufferring or loss of a loved one, especially in Canadian courts, is almost hopeless. An example would be an individual exposed by highway spraying by the Ontario Ministry of Transport through the 50s, 60s and 70s. To find out for example half way through the trial that the individual involved also was exposed to TCDD by a parent living beside Uniroyal Chemical in the 40s and 50s would be a confounding variable. Which exposure (or both) did the damage?

Again while I am still reading this report by the Fact-Finding Panel, to date I find it very disturbing. The Panel have indeed found evidence of gross negligence by our political authorities while carefully not using those words or terminology. They have indicated the current scientific understanding regarding TCDD (especially 2,3,7,8 TCDD) and it is horrific. Again their language is much more nuetral and put in medically correct terms. My confidence in the basic commonsense and integrity of our political leaders past and present continues to plummet.

MERRY CHRISTMAS & A HAPPY NEW YEAR

VARIOUS SCIENTIFIC STUDIES OF 2,3,7,8 TCDD (DIOXIN)

Many national and international agencies and institutes have studied the health effects of exposure to 2,4,5-T and 2,3,7,8 TCDD. Also individual scientists have also performed reviews of the scientific literature. Unsurprisingly there is not 100% agreement on each and every health effect, threshold level, and final outcome of exposures. This is due to differences in human response to simialr exposures as well as confounding factors such as prior unknown exposures, different lifestyles, genetic background and overall prior level of health. Studies include both experimental animal studies with controlled doses and then extrapolations to humans as well as epidemiological studies looking at past human exposures. There have been world wide a number of catastrophes and exposures with the whole gamut of minor to horrific health effects following.

The literature reviewed by the Fact-Finding Panel in Ontario indicated a number of possible diseases caused by exposure to 2,4,5-T and 2,3,7,8 TCDD,. In total they include cancer, heart disease, neurological conditions, reproductive and immunological conditions, endocrine function and skin conditions. Some of these better known reports and studies include

IARC (International Agency for Research on Cancer) Three studies in 1977, 1987 and 1997. The first was inconclusive, the second linked chlorophenoxy herbicides, including 2,4,5-T, to soft tissue sarcoma, non-Hodgkin lymphoma and Hodgkin disease. The 1997 study stated that 2,3,7,7 TCDD was carcinogenic to humans and caused excesses for non-Hodgkin lymphoma, lung cancer and all cancers combined.

WHO (World Health Organization) in 2003 examined chlorophenoxy herbicides found in drinking water. They found evidence of associations with miscarriages and birth defects in some but not all studies. They also found limited evidence of an association with non-Hodgkin lymphoma.

IOM (Institute of Medicine) is part of the well respected U.S. National Academy of Sciences (NAS). In 2012 in studying Agent Orange and Dioxins they found sufficient evidence of soft tissue sarcoma including heart, non-Hodgkin lymphoma and leukemia. They also determined there was sufficient evidence to include Type 2 diabetes and spina bifida as effects. There was only limited evidence of heart disease and hypertension being caused by Agent Orange and dioxins.

NTP (U.S. National Toxicology Program) In a 2011 study they determined that TCDD was a known human carcinogen and caused excesses of non-Hodgkin lymphoma, lung cancer and in fact all cancers combined.

It is essentially impossible to categorically prove beyond any doubt, ahead of time, that exposure to certain chemicals will sicken and kill human beings. What we should always be aware of is the purpose of insecticides, herbicides and fungicides. That purpose is to kill other life forms. In the history of the human species on this planet, there is a terrible irony in our willingness, for profit, to kill other species that allegedly harm mankind; while cheerfully sacrificing a certain number of our own species. For profit.

ONTARIO'S "WEEDLESS" TOWN, ELMIRA

How many Elmira and Woolwich residents recall those ads in the 60's extolling the virtues of mass spraying throughout Elmira, Ontario? How many Elmira residents have died prematurely as a result after sufferring various ailments including cancers? Esther Thur of Elmira and the Elmira Environmental Hazards Team attributed her multiple bouts of cancer to Uniroyal Chemical.

The Fact-Finding Panel on Herbicide 2,4,5-T have stated that in 1978 Ontario municipalities used 90,000 kg. of Agent Orange, half of which was 2,4,5-T (ie. 45,000kg). The combined use of 2,4,5-T by the MNR, MOT and Ontario Hydro that year was half of that or 23,000kg. The Panel did not allegedly have data to show if those numbers were representative of the entire 1950-1979 era for either total useage or proportional useage between the province and municipalities. Regardless in one year alone (1978) Ontario municipal and provincial governments doused nearly 70,000 kilograms (150,000 pounds) of 2,4,5-T on unsuspecting Ontarians.

The Panel also claim that they do not know which manufacturer or suppliers provided Ontario with 2,4,5-T. As we manufactured it right here in Elmira, Ontario I've got one candidate in mind. The Panel bless their pointed little heads at least have indicated that they are satisfied that the 2,4,5-T used in Ontario did indeed contain the same Dioxin contaminant as that purchased by the U.S. military for use in Vietnam. That again was purchased both in the U.S. as well as from Uniroyal Chemical in Elmira, Ontario.

The Panel have also indicated clearly that while there were standards, policies, practices and guidelines regarding the spraying of pesticides at the time, they (the Panel) "could not determine the extent to which they were followed or enforced". Stories by survivors indicate that students were on the ground holding balloons allowing Ministry of Natural Resources pilots to spray from the air, thus soaking the students as well. That hardly bodes well for ground spraying procedures to be any more professional or careful.

The Panel discuss the difference between Threshold and Non-Threshold (one hit model) levels or risks. Essentially the Non-Threshold hypothesis states that zero risk is only possible with zero exposure. This theory feels that exposed populations are at risk at any level of exposure to carcinogens particularily genotoxic ones which damage DNA. The Panel state that historically the Threshold approach has not been used to estimate risks from carcinogen exposure
"...but more recent advances in risk assessment science have led the scientific community to discuss integrating the Threshold and Non-Threshold models for the risk assessment of carcinogens.".

Clearly uncertainty abounds. I wonder when the last human being is left whether the long deceased scientific community will have the data they require to unequivocally state that Dioxins are lethal eventually to everybody.