July 29, 2014 **EPA regulation of vapor exposure of Trichloroethylene in the workplace: a public**  **perspective.** As a member of the general public and a concerned citizen, I was very encouraged by the workshop here to day. What I witnessed was a testament to the productivity and insight , which occurs when the EPA works alongside private industry to both advance science and protect the public health. We all know it has taken over thirty years for the EPA to overcome industry, their lobbyist and their allies on Capitol Hill to finally set in place meaningful regulation of trichloroethylene (TCE) and rightfully designate it as a human carcinogen. It was refreshing to see the many different alternatives and processes for degreasing operations t hat are now available to responsible members of the bus iness community and to know the EPA also worked hand in hand with many of these companies to assist them in their efforts to shed their TCE dependence. It was most reassuring to finally see the EPA fun ction as it was intended too by its founders. Unfortunately, this example was more an exception than the norm, through no fault of the
EPA. While I am encouraged by what I saw today, I do realize there remain staunch opponents backed by irresponsibl e members of our business community who continually seek opportunities to derail the EPA from its mission to protect the public health and environment. I would like to address once such example and how this relates to current EPA efforts to weed TCE from t he market place. On January 13 th 2013, Senator Crapo sponsored two bill s (S. 50, Ref

. 1 and S. 53 , Ref

. 2 ) charging the U.S. EPA with the task of protecting children and communities f romharmful chemicals by researching cancer clusters to identify their relation to toxic exposures. The bill s also recognized the adverse effects of toxic exposures upon children as a national concern . On the surface this is a most noble cause and is to be commended.
Ho wever, there are troubling contrad ictions in this Senator’s public statements and
his confidence in the EPA. Take for example , a June 25 th letter signed by the very same Senator Crapo (Ref. 3 ). In this letter, the Senator accused EPA Deputy Director, Dr.
B arone, with “cherry picking” studies that would favor stricter regulation of TCE. Ironically, the study the Senator referred to in his statement (Johnson et. al. 2003) was part of the EPA ’s IRIS process and was previously reviewed by the EPA Scientific Adv isory B oard (SAB) with no meaningful concerns raised to its credibility. Or usefulness. The Senator then launched a n unwarranted direct personal attack upon Dr. Barone, the Deputy Director , by calling into question his academic and professional integrity. The Senator went so far as to suggest the Deputy Director’s position was acquired by fraudulent means and demanded a formal accounting of how Dr. Barone secured his current position as Deputy Director of EPA’s Office of Chemical Safety and Pollution Preve ntion. According to Senator Cra po and his fellow signatories on the letter, Senators Vitter and Inhofe, the National Academy of Science was the authority to follow when conducting “appropriate chemical risk assessments” and not the EPA. In fact accordin g to the letter, the EPA has a history of “poor management of the scientific process.” As a concerned citizen, I find the January 2013 bill s sponsored by Senator Crapo and the June 25 th letter cosigned by Senator Crap t o EPA Assistant Administrator Jon es, to be both contradictory and troubling . It seems to me, that our public leaders strive to appearas if their goal is to protect our health and advance science for the public good, but when the agency mandated by our Congress moves to protect the public good, a s udden schizophrenia manifested itself. In this alternate reality, the EPA suddenly transforms from the guardians of the environment and public health into a n inept, inefficient and unscientific organization incapable of rendering any meaningful d ecisions. If the EPA is indeed so inept and untrustworthy as described in Senator Crapo’s letter, then why entrust them to execute the mission described in S. 50 and S. 53 ? Protecting the public health is something all Americans want and desire. Dela ying meaningful regulation , oversight and research into the adverse health affects of toxic chemicals and their exposures only benefits the pockets of polluters and industry. I fully expect that any action on the part of the EPA to protect the public healt h regarding TCE exposures including vapor intrusion and inhalation in the workplace to be counter ed by a move towards the National Academy by Senators Vitter, Inhofe and Crapo . This counter will most likely be in the form of a review of EPA’s work by a committee of the Academy prior to implementi ng any of EPA’s recommendations for regulation. The National Academy of Science is no stranger to this process and as mentioned earlier, appears to be polluters, and their allies , preferred venue for r eview of EPA’s
proce dures and work. Our issue at Camp Lejeune was also subjected to t he whims of the Academy. Our brush with the Academy occurred in 2009 , when the National Research Council (NRC) published a review of literature surrounding the pollutants at Camp Lejeune , which included TCE . The NRC committee found scientific evidence to support an association between our exposures at th e base and disease to be limited

. Shortly afterwards, we uncovered a n undisclosed $600,000 (Ref. 4 ) contract between theAcademies had ent ered and Department of Defense to serve as a consultant and defend their findings at Camp Lejeune . The contract was negotiated and signed months before the report for Camp Lejeune was finalized. The contract was later dissolved by the
Aca demies after news of its existence was revealed in th e media. We also discovered an undisclosed conflict of interest concerning the peer review coordinator overseeing the finalization of the committee’s report on Camp Lejeune

. The peer review coordinator

was Dr. George Rusch, who was a thirty plus year Honeywell Ltd. employee. Following the release of the Camp Lejeune report by the NRC, we became aware that Dr. Rusch failed to address concerns of at least one of the peer reviewers cr itical of the NRC’s findings on Camp Lejeune. Why was an employee from a company tied to TCE pollution allowed to serve as the peer review coordinator fo r a report focusing primarily on people’s health effects form exposure to the same chemical? Dr . Rusch’s work has been prai sed and utilize d by lobbyist from the Halogenated Solvents Industry Alliance to challenge EPA findings (Ref. 5 )

. Yet this man was chosen by the National Academies to be an objective peer review coordinator for their Camp Lejeune report in 2009?
Fortu nately for us, The NRC’s 2009 report on Camp Lejeune has been largely discredited and replaced by respectable science , including r ecently released studies by the Agency for Toxic Substances and Disease Registry (ATSDR)

. The ATSDR found link s in advers e health outcomes for both the children born at Camp Lejeune and the Marines/ Na vy service personnel who served and worked aboard the base. TCE was heavily used at Camp Lejeune as a degreaser resulting in inhalation and dermal exposures

. TCE is a primary co ntaminant in the base’s soil, air and groundwater. In addition to our exposures in drinking water aboard the base, many menand women service personnel were exposed inhalation hazards resulting from vapor intrusion emanating from massive underground plumes of TCE aboard the base, open air vats of the chemical used for degreasing engine parts , and the base wide use of TCE as a degreaser to clean personal weapons. The EPA has a mission to protect the public health.
The EPA will continue to be severely limited in their ability to protect our health and the environment so long as we allow industry, their well

- funded lobbyist, and their political allies on Capitol Hill to continue to interfere in the scientific process with the intent of delaying any meaningful r egulation for the sake of profit. The issue of TCE as a carcinogen dragged on for decades. Thankfully, in 2011, the EPA rightfully recognized TCE as a carcinogen. In 1932 (Ref. 6 ) and again in 1952 (Ref. 7) , two curious articles appeared in the Journal of the American Medical Association regarding the industri al use of TCE . I will close with the observations written in 1932 by Dr. Carey P McCord: “Any manufacturer contemplating the use of trichloroethylene may find in it many desirable qualities . Too, in the absence of closed systems of operation, he may find in this solvent the source of disaster for exposed workmen.” Michael Partain 968 N. Heron Circle Winter Haven Fl., 33884 850

- 339

- 0828 strashni2002@yahoo.com