### Polychlorinated Biphenyls (PCBs); Reassessment of Use Authorizations Docket ID: EPA-HQ-OPPT-2009-0757

Comments By Ann C. Casey

The opinions I expressed here are exclusively my own personal opinions and do not necessarily reflect the opinion of my employer, any past agency or employer, peers, or professional affiliates I have.

## Background & Expertise
• I am a graduate ofthe College of St. Rose Albany with a BA in Sociology and a BS in Biology. • For the past 22 years I have work on the analysis, R&D and monitoring of PCBs. • I have co-authored 8 peer reviewed publications on PCB and given several oral presentation on PCBs. • I have developed several extraction and analysis techniques for PCB congeners and Aroclors.• I am a parent of4 children 1 -13yr old and 8 year old Triplets. • I would like to commend The USEPAfor issuing an ANPRM forthe use and distribution in commerce ofcertain classes of PCBs and PCB items and certain other areas ofthe PCB regulations underthe Toxic Substances Control Act (TSCA).

• The Reassessment is 

### long overdue

• Please note this will be a long and difficult taskto complete

## History

• Our history is a greatteacher ifwe are willing to listen and hearall sides. • The first research project I worked on in 1987 was the reassessment of Love Canal ten years afterthe news broke that people, families, children, were living, going to school, playing on toxicwaste.

## Love Canal Yesterday and Today

### Home Grown Environmental Activist

• Lois Gibbs became an environmental activist in 1978 when she discovered that her Niagara Falls, New York, neighborhood of Love Canal, was built on awaste dump containing toxic substances. • Her 7-year-old son, Jon, became ill in June 1978. In August, a state of emergencywas declared in the family's south-end neighborhood, Love Canal. That October, Jon died of kidney disease, which atoxicologist said was caused by exposure to poisonous chemical waste.

## Reassessment of PCB 

## & TSCA
• 30 plus years of research

• LaboratoryAnalysis/Technology Improvements

• Understanding the Chemistry of PCB

• Were are the PCB today?

• Who is in contactwith PCB? • Is 50PPM a reasonable level?

## Research

• Much ofthe research is telling us people 

### (women and children) should not be exposed at any level of PCBs.



### • Cancer is notthe only end pointwhen assessing effects of PCBs



### • Ingestion of PCBs 

### is notthe onlyway of exposure; Inhalation and dermal exposure are also routes.

## LaboratoryAnalysis Technology Improvements • The range in which we can measure PCBs has improved greatly. • At the time ofthe 50PPM level itwas know that all labs could detect and id PCBs as Aroclors • PCB can now be detected as Aroclors and or Congeners at PPT ranges • Lab studies have shown effects on rat at environmental relevant levels.

## Understanding the Chemistry of PCB • This is still a problem.

• Many people do not understand PCBs

• These are a complicated class of chemicals • PCBs are volatile, they are soluble in water, they are absorbed by animals and human and they are great mimics

## Were are the PCB today?

• They are all overthe world.

• They are in water, soil, food, meat/fish, milk, air and humans. • PCB levels have gone down with the enforcement and the use ofTSCA • But the are in many products that are still in use today at levels that only continue the problem

## Who is in contactwith PCB?

• We all are every day • Is it the levels ofthe 1960-1970's no but only because of regulations like TSCA • The very population we want to keep safe our children and women ofchild bearing year are still in contact due to products used 30 years ago.

## Is 50PPM a reasonable level?

• In my opinion NO it was a starting point 30 years ago. • This level should be incrementally stepped down. • I feel afairtargetwould be 10PPM.

• Many ofthe products needed 30yrs ago are at the end ofthe product life.• No products or uses should be removed or exclude from TSCA. • Ifanything more record keeping and accountability should be added.

• Economics are important but if we fail to protect ourwater, food, air, and children then WE FAIL TO EXIST