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EPA Proposes Assessing Cancer and Other Health Risks with Only 3 of Over 800 Toxaphene Chemicals



    EPA Region 4 is responding to the September 26, 2005, Office of Inspector General (OIG) Ombudsman Report, “Appropriate Testing and Timely Reporting Are Needed at the Hercules 009 Landfill Superfund Site, Brunswick, Georgia”. The OIG found the method used to analyze and quantify toxaphene was inappropriate and either under quantified or failed to identify toxaphene present in the sample.  The inappropriate method quantified toxaphene from the 8- and 9- chlorine toxaphene compounds that are not present after toxaphene enters the environment and dechlorinates to the 6- and 7- chorine toxaphene compounds that are environmentally persistent and plentiful in Brunswick.  Through a journal article, the EPA is proposing to change cancer and non-cancer risk assessments to considering only 3 of the 800+ chemicals in toxaphene, containing 8 or 9 chlorine molecules, and ignoring all the others.  


    Toxaphene is a mixture of chemicals, patent-protected by Hercules, that included, “Any polychloro camphene containing from about 40 to about 75% of chlorine …,”  — i.e., any camphene compounds with between 3 and 10 chlorine molecules attached — and identified these chemicals as the toxic ingredients of the invention. 

In 1990, the EPA, Georgia EPD, and Hercules chemists met with others and agreed to change how toxaphene was analyzed, quantified, and defined.  The three chemists were called the "Toxaphene Task Force" (TTF).  In 1993 the TTF changed how toxaphene was quantified in Brunswick, where toxaphene was manufactured from 1948 to 1980.  The OIG used laboratory analysis chromatograms to demonstrate how the EPA and GA-EPD manipulated data produced by the TTF method.

    The EPA is now in the process of responding to the OIG.  The March 21, 2006, EPA letter to the OIG said the journal article would be key to their response, and also mentions Hercules pressuring the European Union, Brussels, to change their report, "Investigation into the Monitoring, Analysis and Toxicity of Toxaphene in Marine Foodstuffs" (MATT).  The OIG relied extensively upon the MATT study.  EPA anticipates a final response to the OIG around June 22, 2006.

 Issues of Concern About the EPA’s Article

 The EPA’s article raises a number of issues about which citizens of Glynn County should be concerned:

 1. The EPA proposes limiting toxaphene toxicological assessments to only 3 chemicals, with 8 or 9 chlorine molecules, that are rare (or missing) once toxaphene enters the environment, out of the over 800 in the mixture.   The EPA, using the Toxaphene Task Force method (TTF), quantifies toxaphene by looking at these same 8- and 9- chlorine toxaphene chemicals.  The EPA's focus on these toxaphene chemicals could be an effort not to retest areas tested by the TTF method at Brunswick’s six sites, two of which are Superfund Sites.  The OIG did find a lot of toxaphene chemicals with 6 or 7 chlorine molecules in water, soil, and fish in Brunswick.

 2.  The EPA’s article claims that since the Inuit of northern Canada don't have high breast cancer rates, therefore toxaphene does not cause breast cancer.  This claim ignores transgenerational effects and delays caused by time to move north through the atmosphere, bioaccumulate in animals, and then in people.  Not all toxaphene chemicals move through the air the same, and some come to the ground before others due to temperature, rain, and other factors.   Also, the toxaphene released in Brunswick, Georgia, was toxaphene and toxaphene manufacturing wastes that was dumped directly into our estuary and several landfills around town.  Still, the EPA has made an interesting argument for comparing the Inuit breast cancer rate (the EPA’s background population) with breast cancer rates in Brunswick. 

 3.   The EPA’s article mixes atmospherically transported toxaphene fish data from far northern regions with Brunswick’s dumped toxaphene and toxaphene manufacturing waste fish data, which have far different ratios of toxaphene chemicals and different toxicological properties.

 4.  The EPA’s article promotes toxaphene chemicals that bioaccumulate as the only ones important to toxicology and ignores toxaphene metabolites produced by the liver as the body tries to remove the poison.  These metabolites are suspected to be potential endocrine disrupters (act like hormones in the body).  The toxicology of toxaphene is very poorly understood, and even less in known about the cancer and non-cancer effects of the metabolites.




 The EPA, Georgia Environmental Protection Division, and Hercules Inc. were caught "hiding the poison" by the OIG.  Now, through a journal article, the EPA seeks to change the way toxaphene risks are assessed by measuring toxaphene compounds that are either not found in environmental samples, or only in extremely small amounts.  The other 800 chemicals in the toxaphene mixture, many of which are found in very large amounts in Brunswick’s environment and toxicologically not well understood, pose unacceptable risks to human health and the environment and must be considered when assessing risk.


The EPA response to the Inspector General’s report on the Hercules 009 Site uses Terry Creek Site (above) data, but none from the Hercules 009 Site.



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