On May 21, 2020, subscribers to the State Water Resources Control Board listserver received a message from the State Water Resources Control Board:
This is a message from the State Water Resources Control Board.
The State Water Resources Control Board (State Water Board) will accept written comments on the draft Order Denying Petitions for Reconsideration by Bloomingcamp Water System of enforcement actions taken by Stanislaus County as local primacy agency under the California Safe Drinking Water Act.
The State Water Board’s draft order is attached to this email and is also available for review at: http://www.waterboards.ca.gov/public_notices/comments/index.shtml
Comments must be received by noon on June 22, 2020.
More information is available in the attached notice.
Ever since receiving this message, I have been detecting the faint whiff of bullshit and boot polish. I’m wrestling with responding to the California State Water Control Board. Their treatment of Bloomingcamp Ranch, a food stand on CA-120 outside of Modesto has been thuggish. (See short video here: https://www.modbee.com/news/business/agriculture/article229379199.html) Bloomingcamp’s water system, which serves, according to state records, “6 residents, 4 employees, and 25 or more customers at least 60 days out of the year,” has tested above the U.S. Environmental Protection Agency (EPA) limit on nitrate/nitrite in the water (They had 23.9 and the limit is 10). The Modesto Bee article says the State is concerned for public health reasons, “Darrin Polhemus, deputy director of the state board, said the state is vigilant about nitrates because they can cause harm to infants with limited exposure. Nitrates are a cause of ‘blue baby’ disease by interfering with the process of carrying oxygen in the bloodstream.”
The assertion that nitrates “can cause harm to infants with limited exposure” is speculative. One of the papers I read called it a transformation from a plausible hypothesis to “sacrosanct dogma.” After going through several scientific papers (which I will cite in another post), I’m getting the feeling that the EPA, and both the county of Stanislaus and the state of California, pulled the nitrate/nitrite numbers out of their asses, or more precisely, some bovine asses, hence the whiff of bullshit.
I am working on a response to the “draft Order Denying Petitions for Reconsideration” and I thought that I would share with you my journey to the science. Science, as I wrote here before, is Latin for “knowledge.” It is an evolutionary process and as long as one is will to have one’s own ideas attacked, poked, prodded, scrutinized, and ridiculed, anyone can participated. Science is not a monolithic structure run by scientists; it is the scrum of ideas, where the most adaptable to the evidence eventually win.
So, I think the authorities are completely wrong (yes they have “the rules” on their side). I invite you to do some research and prove me wrong.
California’s Division of Drinking Water of the State Water Resources Control Board wishes to change the Detection Limits for Purposes of Reporting (DLRs) for perchlorate from .004 (4 ?g/l ) to 0.002 (2 ?g/l) .
Here is their announcement:
The Division of Drinking Water (DDW), at a July 5, 2017 public hearing, presented to the State Water Board its findings and recommendations related to DDW’s review of the perchlorate maximum contaminant level (MCL). DDW’s recommendations (see the Perchlorate Review Public Document) were to first establish a lower detection limit for purposes of reporting (DLR) to gather additional occurrence data, and then revise the MCL, if the new data support development of a new standard.
The State Water Board approved DDW’s proposal to investigate, develop, and propose revisions to the perchlorate DLR (see Resolution 2017-0041). DDW is proposing to lower the DLR for perchlorate. Information on the current status of the regulation can be found on the perchlorate regulation webpage.
Further on they note: The current DLR of 4 ?g/l limits DDW’s ability to determine perchlorate in wells at lower concentrations.
Below is my rebuttal to their desire to lower the DLRs for perchlorate from 4 ?g/l to 2 ?g/l.
Division of Drinking Water
State Water Resources Control Board
1001 I Street, 17th Floor
Sacramento, CA 95814
Re: Perchlorate SBDDW-20-001
It’s clear to me the California
State Water Resources Control Board (SWRCB) cares very much about providing
clean drinking water to the most vulnerable consumers of water, children.
It is also mandated to do so by
California Water Code Section 106.3(a) which states:
It is hereby declared to be the established policy of the state that every human being has the right to safe, clean, affordable, and accessible water adequate for human consumption, cooking, and sanitary purposes.
106.3(b) then says all state agencies are to use this mandate where other state
policies are to be considered.
relevant state agencies, including the department, the state board, and the
State Department of Public Health, shall consider this state policy when
revising, adopting, or establishing policies, regulations, and grant criteria
when those policies, regulations, and criteria are pertinent to the uses of
water described in this section.
section does not expand any obligation of the state to provide water or to
require the expenditure of additional resources to develop water infrastructure
beyond the obligations that may exist pursuant to subdivision (b).
section shall not apply to water supplies for new development.
implementation of this section shall not infringe on the rights or
responsibilities of any public water system.
In preparing the proposed
regulations, the SWRCB determined the proposed regulations are consistent with
this statewide policy. Even though the proposed regulations may result in
increased costs to those that are served by PWS (public water systems), it is
the SWRCB’s decision that potential cost is outweighed by the benefits of
knowing the potential human exposure to perchlorate in drinking water supplies
and whether treatment may be needed, and in having an adequate data set to
evaluate the technological and economic feasibility of lowering the perchlorate
MCL (Maximum Contaminant Level).
As a water master for a tiny
rural water company that serves less than 50 households, I too want to provide
safe, clean drinking water to my customers, who, are also my friends and
neighbors. Clean drinking water is my job and my passion. And, in addition to
providing safe drinking water, I am required, by law, to assure that it is as
affordable as I can make it. My friends and neighbors pay the highest rates for
water in our county, in large part because regulations do not scale down well.
So, our key questions for every test, and every tests MCL, ought to be “Is this
test necessary, at what dose does this become a poison, and is this an
The SWRCB information page states
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.
In early 2007, 28-year-old Jennifer
Strange, a mother of 3, was found dead Friday in her suburban Rancho Cordova
home hours after taking part in the “Hold Your Wee for a Wii” contest in which
KDND 107.9 promised a Nintendo Wii video game system to the person who could
drink the most water without urinating. The coroner’s autopsy determined that
Ms. Strange had died of water intoxication after drinking nearly two gallons of
water. Water intoxication is also known as water poisoning,
hyperhydration, overhydration, or water
Water is considered non-toxic.
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.”
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
What is interesting is 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
A review of existing research shows 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)
“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
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
SWRCB’s selection 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 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
It is disturbing to find SWRCB providing a hypothesis without
any data to support it. The people who depend on us for clean and safe drinking
water are ill-served if they are made poorer and not safer with ill-considered
regulations. If this new MCL is adopted one can
only conclude that SWRCB has abandoned basic science for basic fear-mongering.
Hello, ideas. Welcome to the Hunger Games! May the odds be ever in your favor.
Science is under attack. Not breaking news, we can see for ourselves that it is. Right? You have heard, “We don’t have time. The science is settled. We must act now!” yes? If it’s settled, what is it and how does it get ‘settled’?
Photo by Markus Spiske on Pexels.com
So when we say the “science is settled” what do we mean by ‘science’? Perhaps science is a field of study? After all, we want girls to find careers in STEM (Science, Technology, Engineering, Mathematics). It is not, but that may be why science is perceived as a sector, a field, rather than what it partly is: a suite of methods for teasing out how everything around us—and within us—works. So rather than being a field of study, science is a way to study?
Science is not “a field of study”; it’s a suite of methods for studying nature. No scientist that I know is “unconcerned with perfection,” but they realize it’s practically unattainable while trying to achieve it. If facts are wrong, they are not facts; interps may be wrong.
Science really is knowledge: How it is obtained and verified. The word ‘Science‘ comes from the Latin word scientia, meaning ‘knowledge.’ So if we say ‘science is under attack,’ that would mean ‘knowledge‘ is under attack. And it is. Knowledge is constantly under attack, and it’s being attacked for the best of intentions: to protect people from being hurt.
His book is an apologia for free—no holds barred—speech, and against those who want to prevent such speech from hurting people.
“A liberal society stands on the proposition that we should all take seriously the idea that we might be wrong. That means we must place no one, including ourselves, beyond the reach of criticism (no final say); it means that we must allow people to err, even where the error offends and upsets, as it often will. But we also are not supposed to claim we have knowledge except where belief is checked by no one in particular (no personal authority).”
— Kindly Inquisitors: The New Attacks on Free Thought, Expanded Edition by Jonathan Rauch http://a.co/j7cmF6C
Rauch argues that “liberal science”—his term for the process of “What do we know, and how do we know it?”—is at stake if free speech is curtailed, often by well-meaning people. “No social principle in the world is more foolish and dangerous than the rapidly rising notion that hurtful words and ideas are a form of violence or torture (e.g., “harassment”),” Rauch says, “and that their perpetrators should be treated accordingly. That notion leads to the criminalization of criticism and the empowerment of authorities to regulate it. The new sensitivity is the old authoritarianism in disguise, and it is just as noxious.” (emphasis is mine)
While free speech is crucial and the threats to it (fundamentalism, egalitarianism, and humanitarianism) are crucial to liberal science, and would not work without the ability to offend, it was Rauch’s discussion of liberal science itself that I found most intriguing.
Knowledge is a product, like the metals we mine and the cars we build. To be more specific, our knowledge is a set of statements which we are satisfied are true—which have been validated, truth tested, in some satisfactory way….
Liberal science is a big and complicated thing. No one could begin to describe it fully. However, with nullius in verba (take no one’s word) and “order without authority” we have the underpinnings of liberal science.
Bertrand Russell once said that “order without authority” might be taken as the motto both of political liberalism and of science. If you had to pick a three-word motto to define the liberal idea, “order without authority” would be pretty good.
Kindly Inquisitors: The New Attacks on Free Thought, Expanded Edition by Jonathan Rauch http://a.co/4BiExtr
Who gets to choose what is knowledge? The answer is literally everyone. The competition to stay alive, though, is between ideas, not people.
Like evolutionary ecologies, liberal systems are centerless and self–regulating and allow no higher appeal than that of each to each in an open-ended, competitive public process (a game)….In biological evolution, no outcome is fixed or final—nor is it in capitalism, democracy, [or] science. There is always another trade, another election, another hypothesis….No matter who you are, you must conduct your business in the currency of dollars, votes, or criticism—no special fiat, no personal authority….
Kindly Inquisitors: The New Attacks on Free Thought, Expanded Edition by Jonathan Rauch http://a.co/6XYJ3ee
No one gets a pass. “Who you are doesn’t count; the rules apply to everybody, regardless of identity….no matter how stupid and grubby-minded the critic.” If you want your ideas to be encoded in the current book of knowledge, you must submit them for review.
[The] name of the game is to make knowledge and score credit for it, and you get credit only when your conclusions are checked out by others. Others must be able to rely on your conclusions, confirm your results, trace your logic, get hold of your data. So the game of science forces you to build bridges. You must persuade.
Kindly Inquisitors: The New Attacks on Free Thought, Expanded Edition by Jonathan Rauch http://a.co/9SJgG3s
So we find that the science never is “settled.” Our knowledge of the world outside and of ourselves shifts, adapts, and evolves as ideas gain or lose credence by how well those ideas perform against all contenders. Welcome to the games, Ideas. May the odds be ever in your favor.
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