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 of the 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 of 4 children 1 -13yr old and

8 year old Triplets.

• I would like to commend The USEPA for

issuing an ANPRM for the use and

distribution in commerce of certain classes

of PCBs and PCB items and certain other

areas of the PCB regulations under the

Toxic Substances Control Act (TSCA).

• The Reassessment is long over due

• Please note this will be a long and difficult

task to complete
History

• Our history is a great teacher if we are

willing to listen and hear all sides.

• The first research project I worked on in

1987 was the reassessment of Love Canal

ten years after the news broke that people,

families, children, were living, going to

school, playing on toxic waste.
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 a waste dump containing toxic

substances.

• Her 7-year-old son, Jon, became ill in

June 1978. In August, a state of

emergency was declared in the family's

south-end neighborhood, Love Canal.

That October, Jon died of kidney

disease, which a toxicologist said was

caused by exposure to poisonous

chemical waste.
Reassessment of PCB &TSCA

• 30 plus years of research

• Laboratory Analysis/ Technology

Improvements

• Understanding the Chemistry of PCB

• Were are the PCB today?

• Who is in contact with PCB?

• Is 50PPM a reasonable level?
Research

• Much of the research is telling us people

(women and children) should not be

exposed at any level of PCBs.

• Cancer is not the only end point when

assessing effects of PCBs

• Ingestion of PCBs is not the only way of

exposure; Inhalation and dermal exposure

are also routes.
Laboratory Analysis

Technology Improvements

• The range in which we can measure PCBs

has improved greatly.

• At the time of the 50PPM level it was 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 over the world.

• They are in water, soil, food, meat/fish,

milk, air and humans.

• PCB levels have gone down with the

enforcement and the use of TSCA

• But the are in many products that are still

in use today at levels that only continue

the problem
Who is in contact with PCB?

• We all are every day

• Is it the levels of the 1960-1970's no but

only because of regulations like TSCA

• The very population we want to keep safe

our children and women of child 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 a fair target would be 10PPM.

• Many of the products needed 30yrs ago

are at the end of the product life.
• No products or uses should be removed or

exclude from TSCA.

• If anything more record keeping and

accountability should be added.

• Economics are important but if we fail to

protect our water, food, air, and children

then

WE FAIL TO EXIST