California bureaucrats consider lowering detection limit for purposes of reporting for perchlorate

This is my response to the State Water Resources Control Board regarding their proposal for lowered detection limit for purposes of reporting for perchlorate. (see the previous post for SWRCB’s announcement).

 

The California State Water Resources Control Board (SWRCB) seems to appreciate the Precautionary Principle, which says, “When an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.”

In 1825, one of Britain’s most respected publications, the Quarterly Review wanted something quite similar to the Precautionary Principle invoked over railroads. Unless someone took action, locomotives would careen through the countryside at speeds “twice as fast as stagecoaches.” It was potentially dangerous.

According to experts of the day, locomotives threatened harm to the environment and human health. Some physicians predicted that the incredibly high speeds (nearly 20 miles per hour) could cause psychological harm; people would suffer mental anguish from objects entering and leaving their fields of vision too rapidly. Others predicted that passing trains would cause pregnant mares to spontaneously abort. The Review beseeched, “We trust that Parliament will, in all railways it may sanction, limit the speed to eight or nine miles an hour.”

As we know, the world heeded these foresighted experts invoking precautionary measures, and as a result, no mode of transport exceeds eight or nine miles an hour today. Well no, the world didn’t embrace that, but such is the thinking of the SWRCB with regard to perchlorate, Chromium-6, and other chemicals.

In its background material on perchlorate, the SWRCB conflates its use with toxicity, omits that it occurs naturally in nature and is a byproduct of chlorination, and it disregards “dose makes the poison.”

The SWRCB tells the reader that “Perchlorate and its salts are used in solid propellant for rockets, missiles, and fireworks, and elsewhere (e.g., production of matches, flares, pyrotechnics, ordnance, and explosives).”  The information ominously adds, “Their use can lead to releases of perchlorate into the environment.”

Perhaps it was meant to simplify, but the information is incomplete. It neglects to mention that perchlorate occurs naturally in the environment, and, in certain desert areas, in concentrations higher than those quoted as being found in California. Perchlorate is also a byproduct of water treatment disinfection with sodium hypochlorite.

SWRCB’s information page does note that “Perchlorate’s interference with iodide uptake by the thyroid gland can decrease production of thyroid hormone, which is needed for prenatal and postnatal growth and development, as well as for normal metabolism and mental function in the adult.” It is exactly for this reason why perchlorate was used to treat hyperthyroidism due to Graves disease and to treat thyroid gland disorders resulting from the accumulation of excess iodine. SWRCB neglects to point out the high dosages needed for these affects. As the American Council on Science and Health (ACSH) pointed out, “Clinical use of perchlorate in treating disease involves doses up to 400 milligrams on a daily basis, a level which is thousands of times greater than potential environmental exposures.”

It is this disregard of even the most basic toxicology that is disturbing.

Every compound no matter how dangerous, has a level at which it is benign; and every compound, no matter how benign, has a level at which it is toxic. Or as Paracelsus (1493-1541) put it, “All substances are poisons; there is none which is not a poison. The right dose differentiates a poison and a remedy.” Take two aspirin for a headache and it has a therapeutic effect. Take two grains of an aspirin tablet, nothing happens. Take two pounds of aspirin for a headache and the headache will be gone, along with the person who took it.

Dose determines risk. In a peer-reviewed paper on perchlorate, the ACSH emphasized, “it is imperative that this cornerstone principle of toxicology be included in any assessment of perchlorate. Mere detection of a chemical in the environment cannot be equated with increased risk, but must be evaluated in terms of the hazard, dose-response, and human exposure, all steps in the characterization of health risk.” This, the SWRCB has neglected to do. It relies on the new technology to detect lower perchlorate levels without justifying the need using the above criteria.

The Dose-Response of the body is of utmost importance. As Frank Schnell, board-certified, PhD toxicologist (retired) explains Dose-Response,

“Most biological effects, whether adverse or not, are the consequence of a cascade of biochemical reactions initiated when chemical agents (referred to by pharmacologists and toxicologists generically as “effectors,” “agonists” or “ligands”) bind to effect-specific macromolecular receptors usually distributed on cell surfaces. It is of supreme indifference to the receptor whether the chemical binding to it is of natural, synthetic, endogenous, or exogenous origin. As long as the ligand fits into the receptor’s active site, the former will produce the effect mediated by that receptor.

“This receptor-mediated mechanism of action accounts for the existence of thresholds of effect and for the S-shaped Dose-Response (D-R) Curve that typically results when the strength of the effect (from zero- to 100%-response) is plotted on the ordinate (y-axis) against the logarithm of the dose on the abscissa (x-axis).”

Figure 1 Dose-Response Sigmoid Curve

Now, here’s the kicker, Schnell writes that

“A sub-threshold concentration of the effector will not activate enough receptors to produce in the cell a significant effect. (If this were not the case, the effective regulation of normal metabolic processes would not be possible.)” (emphasis added)

A review of existing research, not innuendo and ill-informed supposition, reveals SWRCB has overstated a need for increased monitoring.

In its discussion of health effects of perchlorates, the Agency for Toxic Substances and Disease Registry (ATSDR) noted:

“In a study of the general population, Li et al. (2001) examined the prevalence of thyroid diseases in Nevada Counties with respect to perchlorate in drinking water. The cohort consisted of all users of the Nevada Medicaid program during the period of January 1, 1997 to December 31, 1998. Disease prevalence in residents from Clark County (Las Vegas), whose drinking water had 4–24 ? g/L of perchlorate (0.0001–0.0007 mg perchlorate/kg/day), were compared with those from another urban area of similar size (Reno, Washoe County), but with no perchlorate in the water, and also with those from all other counties, also with no perchlorate exposure…. Analysis of the data showed no statistically significant period-prevalence rate difference between Clark County and Washoe County. For acquired hypothyroidism, the prevalence was lower in Clark County than in other counties (opposite to what would be expected).”

However, the SWCRB backgrounder worries that infants may be less tolerant of perchlorate exposure: “Perchlorate’s interference with iodide uptake by the thyroid gland can decrease production of thyroid hormone, which is needed for prenatal and postnatal growth and development, as well as for normal metabolism and mental function in the adult.”

Again, in its discussion of health effects of perchlorates, the Agency for Toxic Substances and Disease Registry (ATSDR) found nothing rising to the level of needing more monitoring or regulation on perchlorate:

“Several developmental studies of perchlorate in humans have focused on the evaluation of neonatal thyroid parameters. Lamm and Doemland (1999) examined rates of congenital hypothyroidism in seven counties of Nevada and California with perchlorate contamination in the drinking water (4–16 ?g/L [ppb]) (0.0001–0.0005 mg/kg/day). The investigators analyzed data from the neonatal screening programs of the two states for any increased incidence of congenital hypothyroidism in those counties. The rates for the California births were adjusted for Hispanic ethnicity, which was known to be a risk factor for congenital hypothyroidism. During 1996 and 1997, nearly 700,000 newborns were screened. The risk ratio in the seven counties was 1.0 (95% confidence interval [CI] 0.9–1.2) (249 cases observed/243 expected). The risk ratios for the individual counties relative to statewide expected rates ranged from 0.6 to 1.1. While the results showed no increase in rates of congenital hypothyroidism, it is known that congenital hypothyroidism is caused by developmental events that are not suspected of being affected by perchlorate exposure.

“Kelsh et al. (2003) also found no relationship between congenital hypothyroidism and exposure to perchlorate through the drinking water in a study of newborns (n=15,348) whose mothers resided in the community of Redlands, California, during the period 1983 through 1997 and who were screened by the California Newborn Screening Program. Perchlorate was detected in the water system serving the community at a concentration of up to 9 ?g/L (mean, <1 ?g/L).”

“Crump et al. (2000) conducted a study of school-age children from three cities with different concentrations of perchlorate in drinking water in northern Chile. The city with the highest perchlorate concentration was Taltal, 100–120 ?g perchlorate/L (ppb), water from the city of Chañaral had 5–7 ?g/L, and perchlorate was not detected in water from the city of Antofagasta. The study comprised 162 children 6–8 years of age, of which 127 had resided continuously in their respective city since conception. The children underwent examination of the thyroid gland and a blood sample was taken for analysis of TSH, T4, FTI, T3, and antiperoxidase antibody. After adjusting for sex, age, and urinary iodide excretion, the children from Taltal and Chañaral had slightly lower TSH levels than children from Antofagasta (opposite to expected), but the differences were not statistically significant.”

SWRCB’s cherry-picking of information may be charitably viewed as providing a worst-case scenario. While that may be the intent, SWRCB’s background information is rendered biased rather than useful or informative. It is pearl-clutching designed to scare people and thus allow the SWRCB to further ratchet down the already unreasonable EPA maximum contaminant level (MCL) of six parts per billion (6 ppb) in drinking water to something so low as to be ludicrous. The NOAEL for perchlorate  translates to a Drinking Water Equivalent Level (DWEL) of 24.5 ppb.

The ignorance and laziness of our public officials to accept the word of activists, such as the Environmental Working Group, over pragmatic scientists hurts people. When we require people to spend money on the wrong priorities, that money is not available for things that could truly save lives. As Schnell told me in an email, “In real life, excess conservatism doesn’t just waste money; it also costs lives… i.e., the ones that could have been saved had the wasted money been spent more wisely.”

And this is real money. The Mercatus Center at George Mason University, puts the amount of money lost since 1980 due to added regulation at $4 trillion; a drag of 25 percent on our gross domestic product (GDP). “If regulation had been held constant at levels observed in 1980, the US economy would have been about 25 percent larger than it actually was as of 2012….This amounts to a loss of approximately $13,000 per capita, a significant amount of money for most American workers.”

Of course, economics alone should not guide us in decision making. But as Bjorn Lomborg reminds us, “[I]gnoring costs doesn’t make difficult choices disappear; it makes them less clear.”

It is disturbing to find the SWRCB more responsive to the environmental lobby than to the scientific communities. SWRCB provides conjecture without any data to support the need for lowered MCL.  As such the legitimate needs of Californians are subsumed by rhetoric. California’s citizens are ill-served if they are made poorer and not safer with ill-considered regulations, abandoning any pretense of scientific objectivity and embracing the paranoid the Precautionary Principle of scaremongering activist environmental NGOs. SWRCB relies on supposition, pearl-clutching, and innuendo rather than science with its messy research. One can only conclude that SWRCB has abandoned basic science for basic fear-mongering.

 

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An Open Letter to California’s State Water Resources Control Board (Draft)

I received this in an email on June 16, 2017 and I’ve been mulling it over since then.

This is a message from the State Water Resources Control Board.

You are receiving this email because you have requested notification from the State Water Resources Control Board, Division of Drinking Water (DDW) regarding important updates on drinking water regulations.  DDW has completed a review of the perchlorate maximum contaminant level (MCL).  DDW will present the findings of the review and recommend investigation of a lowered detection limit for purposes of reporting, or DLR, at the July 5, 2017 Board Meeting in Sacramento.  If the Water Board agrees with the staff recommendation, and directs an investigation into lowering the DLR, the public will have another opportunity to comment on any proposed changes to the regulations during the rulemaking process, which is subject to a 45-day comment period under the Administrative Procedures Act.

The attached document is a summary of the findings and recommendations.  If you would like to make any comments regarding the summary or recommendation, then please submit your comments by June 29 to either:

ddwregunit@waterboards.ca.gov
or
Division of Drinking Water
Attn: David Pimentel
State Water Resources Control Board
1001 I Street, 17th Floor
Sacramento, CA   95814

Opportunity for comment may also be made available during the July 5 Board Hearing.  Additional information regarding the perchlorate MCL, Board Meeting procedures, and the specific time and location of the Board Meeting will be posted soon on DDW’s perchlorate website:

http://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/Perchlorate.shtml

Below is my draft response. I welcome your thoughts regarding it.

Re: Perchlorate

The California State Water Resources Control Board (SWRCB) seems toappreciate the Precautionary Principle.

The 1998 Wingspread Statement on the Precautionary Principle says, “When an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.”

In 1825, one of Britain’s most respected publications, the Quarterly Review wanted something quite similar to the Precautionary Principle invoked over railroads. Locomotives could careen through the countryside at speeds “twice as fast as stagecoaches.” It was potentially dangerous.

According to experts of the day, locomotives threatened harm to the environment and human health. Some physicians predicted that the incredibly high speeds (nearly 20 miles per hour) could cause psychological harm; people would suffer mental anguish from objects entering and leaving their fields of vision too rapidly. Others predicted that passing trains would cause pregnant mares to spontaneously abort. The Review beseeched, “We trust that Parliament will, in all railways it may sanction, limit the speed to eight or nine miles an hour.”

As we know, the world heeded these foresighted experts invoking precautionary measures, and as a result, no mode of transport exceeds eight or nine miles an hour today. Well no, the world didn’t embrace that, but such thinking appears to animate SWRCB with regard to perchlorate, Chromium-6, and other chemicals.

In its background material, the SWRCB disregards basic toxicology: every compound no matter how dangerous, has a level at which it is benign; and every compound, no matter how benign, has a level at which it is toxic. Or as Paracelsus (1493- 1541) put it, “All substances are poisons; there is none which is not a poison. The right dose differentiates a poison and a remedy.” Take two aspirin for a headache and it has a therapeutic effect. Take two grains of an aspirin tablet, nothing happens. Take two pounds of aspirin for a headache and the headache will be gone, along with the person who took it.

Thus, the Dose-Response of the body is of utmost importance. As Frank Schnell, board-certified, PhD toxicologist (retired) explains Dose-Response, “Most biological effects, whether adverse or not, are the consequence of a cascade of biochemical reactions initiated when chemical agents (referred to by pharmacologists and toxicologists generically as “effectors,” “agonists” or “ligands”) bind to effect-specific macromolecular receptors usually distributed on cell surfaces. It is of supreme indifference to the receptor whether the chemical binding to it is of natural, synthetic, endogenous, or exogenous origin. As long as the ligand fits into the receptor’s active site, the former will produce the effect mediated by that receptor.

“This receptor-mediated mechanism of action accounts for the existence of thresholds of effect and for the S-shaped Dose-Response (D-R) Curve that typically results when the strength of the effect (from zero- to 100%-response) is plotted on the ordinate (y-axis) against the logarithm of the dose on the abscissa (x-axis).”

Now, Schnell points out the kicker: “A sub-threshold concentration of the effector will not activate enough receptors to produce in the cell a significant effect. (If this were not the case, the effective regulation of normal metabolic processes would not be possible.)”  (emphasis mine)

SWRCB’s omissions and cherry-picking of information may be charitably viewed as providing a worst-case scenario. While that may be the intent, SWRCB’s background information is rendered biased rather than useful or informative. It evokes emotions to designed scare people and thus allow the SWRCB to further ratchet down the ultra-conservative EPA maximum contaminant level (MCL) of six parts per billion (6 ppb) in drinking water to something so low as to be ludicrous.

The ignorance and  laziness of our public officials to apparently accept the word of activists over pragmatic scientists hurts people rather than making them safer. When we require people to spend money on the wrong priorities, that money is not available for things that could truly save lives. As Schnell told me in an email, “In real life, excess conservatism doesn’t just waste money; it also costs lives.. i.e., the ones that could have been saved had the wasted money been spent more wisely.”

And this is real money. The Mercatus Center at George Mason University, puts the amount of money lost since 1980 due to added regulation at $4 trillion; a drag of 25 percent on our gross domestic product (GDP). “If regulation had been held constant at levels observed in 1980, the US economy would have been about 25 percent larger than it actually was as of 2012….This amounts to a loss of approximately $13,000 per capita, a significant amount of money for most American workers.”

Of course, economics alone should not guide us in decision making. But as Bjorn Lomborg reminds us, “[I]gnoring costs doesn’t make difficult choices disappear; it makes them less clear.”

It is disturbing to find the SWRCB more responsive to the environmental lobby than to the scientific communities. As such the legitimate needs of Californians are subsumed by rhetoric. California’s citizens are ill-served if they are made poorer and not safer with ill-considered regulations, abandoning any pretense of scientific objectivity and embracing the paranoid the Precautionary Principle of scaremongering activist environmental NGOs.

 

 

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Don’t Drink Yellow Tap Water

California, chemaphobia, and the ‘Erin Brockovich chemical’ (Chromium-6)

Chromium 6 found in elementary school’s drinking water

On March 11, 2016, Coyote Valley Elementary School near Middletown, California (north of San Francisco), started handing out bottled water following reports that the Hidden Valley Lake municipal water supply had levels of chromium-6 higher than were allowed by the state division of drinking water. As a result the school turned off its drinking fountains and handed out bottled water.

How much higher? Three parts per billion (ppb) higher. In California, 10 parts per billion of chromium-6 is the Maximum Contaminant Level (MCL) for drinking water. Their water tested at 13 ppb. (The regulations are found in California’s Drinking Water Law Book.) One billion is a lot. One billion drops of water (at five ml per drop) is enough to fill more than two Olympic-sized swimming pools.

“Logistically, its been a nightmare,” Coyote Valley Principal Shane Lee is quoted saying in the Lake County Record-Bee, “I’m looking forward to turning our faucets back on.”

The Record-Bee article goes on to say, “Chromium-6, also known as hexavalent chromium, is a highly toxic heavy metal and a known carcinogen made famous by law clerk Erin Brockovich…”

Here is what is correct about the above sentence:

  • Chromium-6 is also known as hexavalent chromium, or CR(VI)
  • It is a known carcinogen when inhaled in high concentrations over long periods of time.
  • It was made famous by Erin Brockovich, a law clerk for the legal firm of Masry & Vittitoe.

Chromium, the stuff of bumper coatings, is an odorless and tasteless metallic element. It is found naturally in rocks, plants, soil and volcanic dust, and animals. The most common forms of chromium that occur in natural waters in the environment are trivalent chromium (CR(III) or chromium-3) and hexavalent chromium (also referred to as CR(VI) or chromium-6). Chromium-6 occurs naturally in the environment from the erosion of natural chromium deposits. It can also be produced by industrial processes. (Source: Chromium in Drinking Water, EPA.gov)

Chromium, the stuff of bumper coatings, is an odorless and tasteless metallic element. It is found naturally in rocks, plants, soil and volcanic dust, and animals. The most common forms of chromium that occur in natural waters in the environment are trivalent chromium (CR(III) or chromium-3) and hexavalent chromium (also referred to as CR(VI) or chromium-6). Chromium-6 occurs naturally in the environment from the erosion of natural chromium deposits. It can also be produced by industrial processes. — Source: Chromium in Drinking Water, EPA.gov

Welcome to Cheomphobifornia

Welcome to California, home of chemophobia and flawed risk assessment. Photo by the author.

Welcome to California, home of chemophobia and flawed risk assessment. Photo of a Starbucks Proposition 65 warning by the author.

To say California “errs on the side of caution” would be putting too fine a point on things. California, home of Proposition 65, is chemophobic.

As I wrote on this blog previously, “In 1986, we Californians passed Proposition 65, ‘The Safe Drinking Water and Toxic Enforcement Act,’ and Prop 65 is the reason you see signs everywhere, including Starbucks, saying, ‘Warning! Detectable amounts of chemicals known to the State of California to cause cancer, birth defects, or other reproductive harm may be found in or around this facility.’” As a side note, you won’t find these signs at the smaller coffee houses. It’s not that they don’t have the same chemicals warned of in the signs; they are not worth suing–not deep enough pockets.

California’s 10 parts per billion–ppb (10 µg/L) maximum contaminant level (MCL) for chromium-6 became effective on July 1, 2014. Up until that time, the school’s water supply had been considered safe (note: at 13 ppb, nearly one-tenth of the federal standard, it still is very safe). The community’s well, on which the school relies, provided water significantly below California’s pre-2014 super-cautious 50 ppb (50 µg/L) MCL for chromium-6. This is 1/10 of the very cautious federal limit set by the Environmental Protection Agency of 100 ppb (100 µg/L) for total chromium.

For added irony, the bottled water the school handed out needed to meet the federal standard only of 100 ppb. The bottled water could have have more chromium-6 than the water fountains had. You can’t make this stuff up.

Chromium-6: The Legacy of Erin Brockovich

By Alison Cassidy [CC BY-SA 4.0 (http://creativecommons.org/licenses/by-sa/4.0)], via Wikimedia Commons

By Alison Cassidy [CC BY-SA 4.0 (http://creativecommons.org/licenses/by-sa/4.0)], via Wikimedia Commons

By now everyone know the story of the “busty” “gutsy” legal assistant Erin Brockovich, who, in 1993, gathered 600 prospective plaintiffs from the tiny tumbleweed of a desert town of Hinkley, California to sue the electrodes off the evil corporation of Pacific, Gas, and Electric (PG&E) for leaching chromium-6 (hexavalent chromium) into Hinkley’s groundwater supply. In 2000, it was made into a movie starring Julia Roberts as “busty” “gutsy” Erin Brockovich.

What the movie doesn’t mention is that according to Quackwatch, “In December 1987, PG&E determined that 10 domestic wells serving 14 families contained chromium at levels only slightly above the U.S. Department of Evironmental Protection’s drinking water standard. In response, PG&E provided bottled drinking water and offered a free medical evaluation to these families.”

In the movie, “Everybody and everything from the chickens to frogs to people were purportedly keeling over with illnesses including breast cancer, chronic nosebleeds(1), Hodgkin’s disease (lymphoma), lung cancer(2), brain stem cancer, stress, chronic fatigue, miscarriages, chronic rashes, gastrointestinal cancer, Crohn’s disease, spinal deterioration, kidney tumours, ‘intestines eaten away,’ and other things unlisted because that’s as fast as I could write in a dark theatre,” according to investigative reporter Michael Fumento. Brockovich decides that chromium-6 must be the culprit because PG&E had the deepest pockets.

The law firm’s team persuaded the jury that chromium-6 leached into the groundwater by PG&E had afflicted Hinkley’s population with this plague of diseases and won a record (at the time) $333,000,000.

That PG&E had leached chromium-6 into Hinkley’s groundwater supply is true; that chromium-6 caused all those afflictions is not.

“Stupid nonsense dressed up to look like complicated science is still just stupid nonsense.” – Frank Schnell, Board Certified PhD in Toxicology

According to the American Council on Science and Health (ACSH), “The problem is this: there is no way that hexavalent chromium was responsible for the cluster of health problems in Hinkley. And there is ample, peer-reviewed scientific evidence backing that conclusion.”

“[The movie, Erin Brockovich] encouraged exactly the wrong way to think about data, elevating individuals’ medical histories to the level of proof and distorting the notion of risk….The first question to ask is whether residents of Hinkley really did have more sickness than people living elsewhere.”

Yet the movie plays up what looks like science. “While it is easy to see that the sex and violence in movies are fantasies,” Gina Kolata wrote in the New York Times, “it is hard for any but scientists to discern when science in movies crosses the line from verity to hyperbole and indoctrination.” That is, it’s hard for us non-science types to distinguish the pepper from the fly shit. Hollywood hides the difference by suspending our disbelief for the purpose of telling a tale. Consider the scene where Brockovich visits Hinkley and is offered tea made with well water. She leaves the cup untouched and the camera dwells on the cup leaving the audience with foreboding; it’s contaminated with chromium-6. The truth is rather more prosaic and not nearly as dramatic: the chemical makeup of the tea will change CR(VI) to the nutrient CR(III).

According to scientists, “[T]he movie encouraged exactly the wrong way to think about data, elevating individuals’ medical histories to the level of proof and distorting the notion of risk….The first question to ask is whether residents of Hinkley really did have more sickness than people living elsewhere,” Kolata wrote.

“The problem is this: there is no way that hexavalent chromium was responsible for the cluster of health problems in Hinkley. And there is ample, peer-reviewed scientific evidence backing that conclusion.”

A 2003 study by Paustenbach, Finley, Mowat, and Kerger. says, “available information clearly indicates that Cr(VI) [chromium-6] ingested in tap water at concentrations below 2 mg/L is rapidly reduced to Cr(III) [chromium-3]” and that “Cr(VI) [chromium-6] in water up to 10 mg/L (ppm) does not overwhelm the reductive capacity of the stomach and blood.” In fact, chromium-3, as ACSH notes, “is an essential dietary nutrient required for normal glucose, protein, and fat metabolism, and is found in fresh vegetables, fruit, meat, beef, grain, and yeast.”

The Paustenbach study notes: “Because Cr(VI) [chromium-6] in water appears yellow at approximately 1-2 mg/L [1-2 parts per million], the studies represent conditions beyond the worst-case scenario for voluntary human exposure.”

“Because Cr(VI) [chromium-6] in water appears yellow at approximately 1-2 mg/L [1-2 parts per million], the studies represent conditions beyond the worst-case scenario for voluntary human exposure.” — Human health risk and exposure assessment of chromium (VI) in tap water

Mything Safety Hazards

Where did California get its 10 ppb limit?

Frankly, it looks like California’s political bureaucrats in the state’s Water Resources Board just pulled the number out of their collective asses. I have heard that the water board’s staff suggested 25 ppb for chromium-6, one half the WHO’s 50 ppb.

There’s scant evidence for us to be concerned with chromium 6 as a carcinogen in our drinking water. There’s no good evidence to backstop California’s Maximum Contaminant Limit (MCL) of 10 ppb for chromium 6 in drinking water. As noted before, the U.S. EPA sets the limit for all types of chromium at 100 ppb, and the uber-cautious United Nations World Health Organization (WHO) sets the limit at 50 ppb for chromium-6. From what I’ve seen, it looks like the European Union uses the WHO 50 ppb limit, which is still five times higher than California’s new MCL.

“Many states compete with the USEPA, and each other, to see who can be the most conservative. ” Frank Schnell, a Board Certified PhD in Toxicology told me in a phone interview.(3) He said even though the EPA’s MCL has a built in safety factor of 100, some states strive to be more conservative than the EPA, which sounds reasonable. “In reality, however, once you’re safe, having a limit 10 times lower does not make you 10 times safer. It just means you are unnecessarily alarming your citizens and wasting their money.”

He offered the analogy of standing at the Grand Canyon. “If you’re standing near the rim of the Grand Canyon admiring the view, you’re probably safe. Nevertheless, as improbable as it is, it’s not entirely impossible that a very strong gust of wind might blow you over the edge. To make sure that you were safe, even under very windy conditions, you could step back ten paces or so–that’s what regulators call a ‘safety factor.’ But, to imagine that stepping back 100 paces, or even a mile, would make you even more safe under implausible conditions (a tornado?) would be not only misguided, but counterproductive, as well, because then you couldn’t see the Grand Canyon, at all.”

“Chromium carcinogenicity via the oral route is more a matter of fiction than science,” Dr. Schnell told me in an email exchange. “Unfortunately, the non-scientists who saw the 2000 movie Erin Brokovich went away thinking they had seen a documentary rather than an entertaining fictionalization of a legal drama in which the scientific facts played no part.” There is a scene in the movie where Julia Roberts avoids the tea made for her and the camera focuses on it several times, making the point that it is contaminated with the dreaded chromium-6. “The fact is that, when consumed in contaminated water or beverages, Cr(VI) [chromium-6] is reduced to the required nutrient Cr(III) [chromium-3] which is essential for sugar & fat metabolism.”(emphasis in the original)

“Mice are not little men,” we should not ban a chemical “at the drop of a rat.” –Dr. E. Whelan, Founder, ACSH

As I noted, there is scant evidence, but there is some, suggesting that chromium-6 can be ingested in amounts so high that they overwhelm the stomach’s acids and affect the stomach and intestines. In one paper, the population of Liaoning Province, China, drank well water contaminated with chromium-6 from a ferrochromium factory in the province. The high levels of chromium-6 turned the water yellow. The “poor” data (the researchers agree the data are messy and haphazard) have been manipulated three ways from Sunday. At present, the statistical reviews conclude that the results are “consistent with” increased exposure. In another study, “F344/N rats and B6C3F1 mice were administered sodium dichromate dihydrate, a hexavalent chromium compound, in drinking water for 2 years.” (EPA Draft, 2010) The 2010 EPA draft cites the “NTP Technical Report on the Toxicity Studies of Sodium Dichromate Dihydrate (CAS No. 7789-12-0) Administered in Drinking Water to Male and Female F344/N Rats and B6C3F1 Mice and Male BALB/c and am3-C57BL/6 Mice.” Catchy, huh? Wonder why it wasn’t a New York Times bestseller? Rats and mice received concentrations of 6.25 62.5, 125, 250, 500, or 1,000 milligrams (mg) of sodium dichromate dihydrate per liter (L) of water. At the highest dosage of 1,000 mg/L the rats had “ulceration, hyperplasia, and metaplasia of the forestomach and histiocytic infiltration of the small intestine.” They conclude that “Exposure to sodium dichromate dihydrate caused hyperplasia and ulceration of the stomach in rats and an anemia and lesions of the small intestine in rats and mice.”

Which brings me back to another study, “Human health risk and exposure assessment of chromium (VI) in tap water,” Paustenbach’s 2003 study’s conclusion: “Based on a physiologically based pharmacokinetic model for chromium derived from published studies, coupled with the dose reconstruction studies presented in this article, the available information clearly indicates that (1) Cr(VI) ingested in tap water at concentrations below 2 mg/L is rapidly reduced to Cr(III), and (2) even trace amounts of Cr(VI) are not systemically circulated. This assessment indicates that exposure to Cr(VI) in tap water via all plausible routes of exposure, at concentrations well in excess of the current U.S. Environmental Protection Agency (EPA) maximum contaminant level of 100 microg/L (ppb), and perhaps those as high as several parts per million, should not pose an acute or chronic health hazard to humans.” (Emphasis mine)

Recall that Chromium-6 in water appears yellow at approximately 1-2 mg/L. Would you drink water the color of fluorescent urine?

It’s really that simple. If chromium-6 worries you, don’t drink yellow tap water.

If chromium-6 worries you, don’t drink yellow tap water.

The Bottom Line: Chemaphobia Costs You more than money

Biased reports get dressed up in sciency jargon all the time. They are as Schnell told me, “designed to make your head hurt, so that you won’t hear that soft little voice of common sense in the back of your head whispering ‘this is all bullshit, isn’t it?.’..Stupid nonsense dressed up to look like complicated science is still just stupid nonsense.”

Studies conducted with agendas to prove a chemical is harmful, rather than determine facts, harm the science of toxicology. “More importantly,” Dr. Schnell points out, “they harm the very people they were designed to protect by diverting limited resources from the solution of real problems to the promotion of make-believe ones.”

Why does being “too safe” matter to you or me?

Two reasons:

  1. This type of excessive caution costs you and me time–in that it takes more time at work to pay for the testing for contaminants and, if necessary, upgrading of water treatment facilities (I work in water treatment; everything costs dearly.) You pay in the form of higher taxes, utility rates, and prices. Costs get passed on down to the consumer. “Ok but…,” I hear you saying, “This doesn’t matter if it makes me safer.”
  2. Aye, there’s the rub. This type of excessive caution does not make you safer. Not even an itty-bitty bit.

The Unbearable Lightness of Wallet

The ignorance and laziness of public officials to accept the word of activists over pragmatic scientists costs you money (which is in fact, time). And this is real money. The Mercatus Center at George Mason University, puts the amount of money lost since 1980 due to added regulation at $4 trillion; a drag of 25 percent on our gross domestic product (GDP). “If regulation had been held constant at levels observed in 1980, the US economy would have been about 25 percent larger than it actually was as of 2012….This amounts to a loss of approximately $13,000 per capita, a significant amount of money for most American workers.”

Of course, economics alone should not guide us in decision making. But as Bjorn Lomborg reminds us, “[I]gnoring costs doesn’t make difficult choices disappear; it makes them less clear.”

When we spend money on the wrong priorities, that money is not available for things that could truly save lives. As Schnell told me, “In real life, excess conservatism doesn’t just waste money; it also costs lives.. i.e., the ones that could have been saved had the wasted money been spent more wisely.”

“[I]gnoring costs doesn’t make difficult choices disappear; it makes them less clear.” – Bjorn Lomborg

 

Footnotes

1. Dr. Schnell told me, “High concentrations of airborne Cr(VI) are sufficiently caustic to corrode the septum of the noses of unprotected workers occupationally exposed over extended periods of time. Hence, the fictional reference in one scene of the movie to PG&E workers having to wear masks to prevent nosebleeds.”

2. Chromium 6 “compounds have been found to cause lung cancer specifically in industry workers who, via inhalation over long periods of time, are exposed to levels in air up to 1,000 times higher than those found in the environment,” wrote the American Council on Science and Health. (emphasis in original)

3. August 26, 2016. Frank Schnell is a retired toxicologist for the Agency for Toxic Substances and Disease Registry (ATSDR), which is part of the Center for Disease Control (CDC), in Atlanta, Georgia. and is a member of the American Council on Science and Health Scientific Advisory Panel.

References

Ames, Bruce N., M Profet, and Lois Swirsky Gold, Proceedings of the National Academy of Sciences, Vol. 87, pp. 7777-7781, October 1990, Medical Sciences, “Dietary pesticides (99.99% all natural)”

Ames, Bruce and Lois Swirsky Gold. 2005. “Risk, Cancer and Manmade Chemicals.” Spiked. http://www.spiked-online.com/newsite/article/1514#.Vy0E72Yva2A.

Bentley Coffey, Patrick McLaughlin, Pietro Peretto. 2016. “The Cumulative Cost of Regulations | Mercatus.” http://mercatus.org/publication/cumulative-cost-regulations.

International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use. 2011. “Impurities: Guideline for Residual Solvents Q3C(R5).” International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use. http://www.ich.org/fileadmin/Public_Web_Site/ICH_Products/Guidelines/Quality/Q3C/Step4/Q3C_R5_Step4.pdf

Jaroff, Leon. 2003. “Erin Brockovich’s Junk Science.” Time. http://content.time.com/time/health/article/0,8599,464386,00.html.

Kerger, B D, R O Richter, S M Chute, D G Dodge, S K Overman, J Liang, B L Finley, and D J Paustenbach. “Refined Exposure Assessment for Ingestion of Tapwater Contaminated with Hexavalent Chromium: Consideration of Exogenous and Endogenous Reducing Agents.” Journal of Exposure Analysis and Environmental Epidemiology 6 (2): 163–79. http://www.ncbi.nlm.nih.gov/pubmed/8792295.

Kolata, Gina. “REFLECTIONS; A Hit Movie Is Rated ‘F’ In Science.” New York Times. http://www.nytimes.com/2000/04/11/health/reflections-a-hit-movie-is-rated-f-in-science.html.

Paustenbach DJ, Finley BL, Mowat FS, Kerger BD. 2003. “Human Health Risk and Exposure Assessment of Chromium (VI) in Tap Water. – PubMed – NCBI.” J Toxicol Environ Health A. . https://www.ncbi.nlm.nih.gov/pubmed/12851114.

Schnell, Frank. 2016. “How Natural Variations Became Environmental Crises: The Numbers Racket.” American Council on Science and Health. http://acsh.org/news/2016/02/15/how-natural-variations-became-environmental-crises/.

Schnell, Frank. 2016. “How Natural Variations Became Environmental Crises: The Word Game.” American Council on Science and Health. http://acsh.org/news/2016/02/16/how-natural-variations-became-environmental-crises-the-word-game/.

Smith, Allan H. 2008. “Hexavalent Chromium, Yellow Water, and Cancer A Convoluted Saga.” Journal of Epidemiology 19 (1): 24–26. doi:10.1097/EDE.0b013e31815c40dc.

Schwarz, Ph.D., and Joe. 2004. “Erin Brockovich Story Largely Fiction.” http://www.quackwatch.org/01QuackeryRelatedTopics/brockovich.html.

U.S. Environmental Protection Agency. 2015. “Chromium in Drinking Water.” https://www.epa.gov/dwstandardsregulations/chromium-drinking-water#self.

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