Frederick Street signNightmare on Frederick Street Continues ....

For Immediate Release
February 17, 1999

***************************************************************** The Sierra Club of Canada requested that Dr. Rosalie Bertell and Roger Dixon of the International Institute of Concern for Public Health (IICPH) prepare a response to the media release issued by CANTOX Inc.

What follows is the response from the IICPH. However, both the IICPH and the Sierra Club of Canada, are more than willing to have an open debate on CANTOX Inc.'s findings, with CANTOX Inc. and the N.S. Medical Officer Jeff Scott, at anytime and in any media format. ******************************************************************

IICPH Responds To CANTOX

CANTOX PRESS RELEASE: Cantox rejects the conclusion of the IICPH review on the Frederick Street Risk Assessment, and we stand by the findings of the Frederick Street Assessment and the interpretation presented in our report of August, 1998. We disagree with the IICPH statement that the methodologies applied by Cantox are "inadequate and insufficient". We followed internationally accepted methods designed to assess contaminated sites.

IICPH RESPONSE: CANTOX APPEARS TO BE USING A METHODOLOGY DESIGNED TO DETERMINE LIABILITY RATHER THAN HUMAN HEALTH HAZARD. THIS IS OBVIOUS IN THEIR ELIMINATION OF PAST EXPOSURES FROM THE SITE AND THE POTENTIALLY CUMULATIVE HEALTH DAMAGE FROM PAST ACTIVITIES. MOREOVER, THEIR CONSTANT APPEAL TO "BACKGROUND" EXPOSURES HAS TO DO WITH LIABILITY RATHER THAN HEALTH HARM. BACKGROUND MAY NOT BE HARMLESS. IT APPEARS TO BE USED TO SHOW THAT THE SITE, ALTHOUGH IT MAY BE HARMFUL, MAY ALSO BE LIKE OTHERS IN CANADA. THIS IS IRREVELANT WHEN DETERMINING LOCAL HEALTH DAMAGE BUT IMPORTANT IF THE FOCUS IS LIABILITY.

CANTOX PRESS RELEASE: Cantox scientists are experts in the methodologies used in risk assessments. We are the largest 4risk assessment firm in Canada, and we have conducted these types of assessments longer than any other firm in Canada. Over the past decade we have conducted several hundred large-scale detailed quantitative risk assessments of potential risks to human health and ecological receptors from exposures to chemicals from a variety of sources. We have evaluated some of the largest and most contaminated properties in Canada ( such as the former U.S. Naval base in Argentia, Newfoundland), and we are widely recognized as leaders in this field.

IICPH RESPONSE: PLEASE PROVIDE A LIST OF THE CONTAMINATED SITE WHICH WERE ASSESSED BY CANTOX, AND THE RECOMMENDATIONS WHICH CANTOX MADE FOR EACH. WAS ANY SITE FOUND TO BE A HUMAN HEALTH HAZARD?

CANTOX PRESS RELEASE: The IICPH review is not a "peer review" of the Frederick Street assessment, because this group is not recognized in the field of risk assessment. As such, many of the comments made result from a lack of understanding of the science of risk assessment and toxicology. IICPH RESPONSE: DR. BERTELL HAS A PH.D. IN MATHEMATICS, WITH A SPECIALTY IN PROBABILITY AND MEASURE THEORY. THIS IS PRECISELY THE DISCIPLINE REQUIRED TO HANDLE RISK ASSESSMENT. ROGER DIXON HAS AN M.P.H DEGREE AS WELL AS ACCREDITATION IN INDUSTRIAL HYGIENE. THIS IS EQUIVALENT TO TOXICOLOGY FOR EVALUATING THIS SITE ASSESSMENT. DR. BERTELL HAS THIRTY YEARS EXPERIENCE WITH BIOMEDICAL/POLLUTION PROBLEMS AND HAS BEEN RECOGNIZED WITH NUMEROUS NATIONAL AND INTERNATIONAL AWARDS AND HONORARY DEGREES FOR HER WORK. ROGER DIXON HAS HAD EXTENSIVE EXPERIENCE OVER TWENTY THREE YEARS. HE HAS BEEN EMPLOYED BY HEALTH CANADA, ENVIRONMENT CANADA, THE GOVERNMENTS OF ONTARIO AND ALBERTA, AS WELL AS MANY OTHER AGENCIES. ROGER IS ALSO AN ENGINEER WITH EXTENSIVE EXPERIENCE IN HAZARDOUS PROCESS OPERATIONS, INCLUDING COKE OVENS. ROGER DID THE FIRST STUDY IN ONTARIO ON COKE OVEN WORKER EXPOSURES.

CANTOX PRESS RELEASE: We disagree with IICPH statement that there were insufficient data to draw conclusions. Cantox was asked to conduct a study using existing information. It is our professional opinion that the data available at the time of the assessment were adequate to provide a preliminary indication of potential health risks associated with current chemical concentration on Frederick Street, and area. The assessment considered and clearly stated the data limitations in the overall interpretation of potential risks. In light of these limitations, several recommendations were made in the Frederic Street assessment report related tot he need for further collection of data. We expect that these recommendations will be followed through on, as we view them as being very important.

IICPH RESPONSE: THE DATA LIMITATIONS AND PRELIMINARY NATURE OF THE RECOMMENDATIONS WERE NOT ADEQUATELY REFLECTED IN THE STRONG ASSURANCES WHICH CANTOX GAVE TO THE PUBLIC THAT THERE WAS NO RISK TO THEIR HEALTH.

CANTOX PRESS RELEASE: The IICPH report criticises the amount of time spent on the assessment. We had 17 scientific staff working on the project for a total of approximately 600 hours, which is equal to about 75 person days of time.

IICPH RESPONSE: THE REPORT DOES NOT REFLECT THAT LEVEL OF COMMITMENT TO THE WORK.

CANTOX PRESS RELEASE: The IICPH report ignores the fact that Cantox made a series of very important recommendations in the risk assessment report, which we feel are critical to further the understanding of the coke ovens site and its potential impact on nearby residents.

IICPH RESPONSE: CANTOX FAILED TO GIVE CAUTIONS THE PRODOMINANT PLACE WHICH THEY DESERVE IN ITS REPORT. THE GENERAL PUBLIC PERCEPTION AND OFFICIAL INTERPRETATION OF THE REPORT IS THAT THE SITE DOES NOT NOT POSE ANY "SHORT TERM" THREAT TO HUMAN HEALTH. MOST IMPORTANT TERMS IN THE REPORT REMAIN UNDEFINED. FOR EXAMPLE, RISK OF WHAT?, HOW LONG IS "SHORT TERM", WHY SHOULD THE PUBLIC NOT BE CONCERNED FOR THE "LONG TERM"?

CANTOX PRESS RELEASE: The IICPH report ignores the fact that the assessment conducted by Cantox was highly conservative, or protective of health. For example, we assumed that people lived on Frederick Street for 70 years, never leaving the site except for a 2 week vacation one time a year. This means that we assumed that no one left the area, even to go to work or to do errands such as grocery shopping over a 70 year period. The IICPH ignores the blood and hair analysis for lead and arsenic, which was conducted on almost all residents. These data are critical to the conclusions of the Cantox report, and clearly indicate that exposure of the residents to arsenic and lead are not elevated, and are the same as any normal, healthy population elsewhere in the world.

IICPH RESPONSE: CANTOX ASSUMED THAT THE 70 YEARS OF RESIDENCE WERE ALL EXACTLY LIKE THE "STUDY" YEAR. IT TOOK NO NOTICE OF THE ACTUAL CONDITIONS OF THE SITE OVER THE PAST OR THE RISK POSED BY FUTURE CLEANUP ACTIVITIES AT THE SITE.

CANTOX PRESS RELEASE: The IICPH report criticizes the way Cantox has applied soil quality guidelines and /or criteria, and they imply that we have no understanding of these values. We are recognized experts in developing soil quality guidelines and we were not "confused" about how they should be applied. The "blanket statement" made by the IICPH that soil quality guidelines established in 1997 cannot be regarded as protective of human health is completely incorrect, and clearly indicates their lack of understanding on how these values are derived.

IICPH RESPONSE: IF CANTOX IS FULLY CONSCIOUS OF THE DERIVATION OF SOIL GUIDELINES THEN THEY SHOULD EVEN BE MORE CONFUSED FOR SUCH STATEMENTS AS: "IF THE EXPOSURES ARE BELOW THE GUIDELINES, THEN WE KNOW THAT THERE IS NO HARM TO HUMAN HEALTH".

CANTOX PRESS RELEASE: The IICPH reports suggests that we neglected to evaluate certain chemicals, or that certain important data were missing. We reviewed each of these instances carefully, these suggestions are unfounded.

IICPH RESPONSE: WE WERE SPECIFIC ON THESE CLAIMS. A GENERAL SELF-EXONORATION IS UNACCEPTABLE.

CANTOX PRESS RELEASE: The IICPH report makes several incorrect statements. Two examples of errors are as follows: The IICPH report is incorrect in stating that there were only 4 backyard soil samples analysed. There were 7.

IICPH RESPONSE: THIS IS ALSO AN INADEQUATE SAMPLE.

CANTOX PRESS RELEASE: The IICPH states that no soil samples were analysed for Polycyclic Aromatic Hydrocarbons(PAH'S). In fact, several soil samples were analysed for these compounds.

IICPH RESPONSE: CANTOX SHOULD PRESENT THE RESULTS OF SUCH ANALYSIS IF THEY EXIST.

CANTOX PRESS RELEASE: Cantox stands by the findings of the Frederick Street Assessment and the interpretation presented in our report of August, 1998. Cantox is a science based consulting firm specializing in providing expert advice to a wide range of clients on toxicology issues related to human health, the environment and regulatory affairs. There are over 50 highly qualified professionals with expertise in diverse areas of human and aquatic toxicology, environmental fate and modelling, human health and environmental risk assessment and risk communication. Cantox scientists are knowledgeable, and experienced in the methodologies use in risk assessments. Cantox has provided expert advice to numerous international committees and organizations including the World Health Organization, FEMA, the International Agency for Research on Cancer, the U.S. National Academy of Sciences, the U.S. National Toxicology Program, and the Natural Sciences and Engineering Research Council.

IICPH RESPONSE: COULD CANTOX PLEASE SUBMIT A STATEMENT FROM ONE OF ITS TOXICOLOGISTS (UNDER HIS OR HER OWN NAME) OFFERING AN OPINION ON THE HEALTH HAZARDS WHICH HAVE BEEN EXPERIENCED BY THE FREDERICK STREET RESIDENTS IN THE PAST AND THOSE WHICH CAN BE EXPECTED DURING A CLEAN UP OPERATION.

For further information call:

INTERNATIONAL INSTITUTE of CONCERN for PUBLIC HEALTH (IICPH)
Rosalie Bertell, Ph. D., GNSH
President, ACS (1998-2000), President IICPH (1984+)
710-264 Queens Quay West, Toronto ON M5J 1B5 CANADA
Tel: 1-416-260-0575,
Fax: 1-416-260-3404,
Email: IICPH@compuserv.com

CANTOX Inc.
Christine Moore, Vice-President - Eastern Region
Cantox Environmental Inc., Telephone: 902-429-0278

Sierra Club of Canada
Elizabeth May, Executive Director, Sierra Club of Canada
1.613.241.4611
Bradford Duplisea, Toxics Coordinator
Sierra Club of Canada
1.613.241.4611 ****************************************************

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