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Toxic Exposures of Children in N.J. The Role of Risk Assessment Peter Montague, Ph.D. ([email protected] ) Unless otherwise noted, all the data (and all the citations to page numbers) are from: Final Report of the New Jersey Comparative Risk Project (Trenton, N.J.: N.J. Department of Environmental Protection, July, 2003), available at

1,3-Butadiene Acrolein Benzene Cadmium Carbon monoxide Chromium Dioxin

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Page 1: 1,3-Butadiene Acrolein Benzene Cadmium Carbon monoxide Chromium Dioxin

Toxic Exposures of Children in N.J.The Role of Risk Assessment Peter Montague, Ph.D. ([email protected])

Unless otherwise noted, all the data (and all the citations to page numbers) are from:

Final Report of the New Jersey Comparative Risk Project (Trenton, N.J.: N.J. Department of

Environmental Protection, July, 2003), available at

http://www.state.nj.us/dep/dsr/njcrp/

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1,3-BUTADIENE

“Butadiene is classified as a known human carcinogen.”

“Essentially the entire state is exposed to ambient levels” that average 0.07 µg/m3, which carries a lifetime cancer risk of 1 in 48,000 (about 2.3 cancers per year). (pg. 717)

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ACROLEIN

“Can affect respiratory function, particularly in children.”

“Children are more susceptible to a potential increase in infections after exposure... ”

“Exposures in [New Jersey] urban areas can be 20 times the reference concentration established by EPA [which is 0.02 µg/m3]...” (pg. 726)

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BENZENE

“The average benzene concentration statewide was estimated to be 3.3 µg/m3.”

“Benzene is classified as a known human carcinogen.”

In 1990, estimated concentrations of benzene in NJ air ranged from 1 to 342 times the one-in-a-million lifetime cancer risk level. (pgs. 753-754)

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CADMIUM

“Recent data indicate that adverse health effects from cadmium exposure may develop in about 1% of the adult general population at an average daily intake of 30 µg over a life-span. In high-risk groups [not defined] the percentage will be even higher (up to 5%).”

“Background levels to which the [N.J.] population is exposed (including food, air, and drinking water pathways) are estimated at 30-50 µg per day.” (pg. 760)

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CARBON MONOXIDE

The recommended EPA 8-hour average is 9 ppm.

“Annual averages in New Jersey [outdoors] are in the 1-2 ppm range.” (pg. 768)

“Households with gas appliances may be exposed to concentrations up to 15 times greater than ambient outdoor levels.” (pg. 768)

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CARBON MONOXIDE (cont’d)

“There is a lack of comprehensive data on the levels of CO [carbon monoxide] in indoor environments. There is a possibility that significant populations are exposed to concentrations greater than 9 ppm...” (pg. 766)

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CHROMIUM

Ambient air concentrations in NJ are estimated to result in a lifetime cancer risk of 1.7 per 100,000 people.” (This would result in about 2 cancers per year.)

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DIOXIN

“Dioxin is generally distributed and the exposure is considered uniform for all citizens of New Jersey.” (pg. 791)

“The current re-evaluation of dioxin risks... notes that the current exposures may be in the range to observe health impacts.” (pg. 791)

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DBPs

Disinfection by-products (DBPs) are a diverse group of chemicals, only about half of which by weight have been chemically characterized, formed by the reaction of chlorine... during water treatment.

DBPs may be expected to cause 40 to 350 bladder cancers per year in NJ., 2 neural tube defects, and 200 miscarriages. (pg. 803)

Several studies have shown a correlation between drinking chlorinated water and colorectal cancer. Associations with brain and kidney cancers have been reported. (pg. 803)

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ENDOCRINE DISRUPTERS (EDs)

“Pregnant women and young children through all developmental stages are especially sensitive. Nursing young of mothers previously exposed to elevated levels of ED chemicals are likely to have high levels in adipose [fatty] tissue[s] that become mobilized at lactation.” [pgs. 804-805]

IMPORTANT NOTE: Breast feeding is still the best way to nourish an infant.

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ENDOCRINE DISRUPTERS (EDs) (cont’d)

“Individuals exposed during sensitive stages of development may experience permanent developmental deficits whose degree may range from mild to severe.”

“Virtually everyone has been exposed to some degree.” (pg. 806)

“While recognition of the potential for ED effects is increasing, many substances with potential ED effects continue to be released into the environment and levels of population exposure may increase as background levels in the environment increase.” (p. 806)

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FORMALDEHYDE

“Formaldehyde affects lung function and raises the susceptibility toward infection.... Related to its effects on lung function, formaldehyde may be an important contributor to the onset of asthma.” (pg. 810)

Formaldehyde is considered a probable human carcinogen by the US EPA. (pg. 810)

“Formaldehyde is a pervasive pollutant, therefore all New Jersey citizens are exposed.” (pg. 810)

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LEAD

The “action level” for toxic lead is 10 µg/dL, which is 625 times the natural background level.*

19% of white children have blood lead > 5 µg/dL28% of Hispanic children have blood lead > 5 µg/dL46.8% of black children have blood lead > 5 µg/dL=====26% of children ages 1-6 have blood lead > 5 µg/dL

5 µg/dL is 300 times the natural background level of lead in blood** A. Russell Flegal and Donald R. Smith, “Lead Levels in Preindustrial Humans,” New England Journal of Medicine Vol. 326 (May 7, 1992), pgs. 1293-1294.

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LEAD (cont’d)

In a study of 4,853 children, math and reading test scores declined with blood-lead levels as low as 2.5 µg/deciliter.*

[However,] “There are persuasive reasons to believe that cognitive dysfunction may not be the most important effect of lead, and that we may be entering a fifth stage of understanding of lead’s effects, in which lead is recognized to adversely affect social behavior,” meaning attention deficits, aggression, delinquency, and violent crime.*

*Herbert Needleman, “Lead Poisoning,” Annual Reviews of Medicine Vol. 55 (2004), pgs. 209-222.

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MERCURY

An estimated 92% of NJ children are exposed to methyl mercury in the womb. (pg. 867)

“For women of child bearing age/pregnant women in NJ, 10-21% are estimated to be exposed above the RfD [reference dose] intended to be protective against neurologic developmental effects of the fetus in utero.

This corresponds to approximately 11,000 to 24,000 infants per year in N.J.” (pg. 867)

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MTBE (Methyl Tertiary Butyl Ether)

Has been added to gasoline since 1979 to replace toxic lead.

EPA has set a “reference concentration” for chronic inhalation exposure of 0.83 ppb. (pg. 877)

In an air monitoring program in Camden, MTBE was found in 29 out of 31 samples (94%) with a mean concentration of 1.29 ppb which is roughly twice (1.8 times) the EPA reference concentration. (pg. 877)

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NICKEL

“Because of the ubiquitous nature of nickel and its use in everyday household items and consumer products, the statewide population is exposed on a daily basis.” (pg. 884)

“Chronic (long-term) respiratory effects such as asthma and an increased risk of chronic respiratory tract infections in humans have been associated with exposure to nickel” (pg. 882)

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NITROGEN OXIDES (NOx): "The total population of New Jersey is exposed to significant levels of NO2." (pg. 896)

"Children are susceptible to NOx and its effects on immune systems. Asthmatics are also susceptible to low level exposures." (pg. 897)

The federal standard for NO2 is an annual average of 0.053 ppm; NJ has its own standard -- an annual average of 0.05.

"...some individual studies suggest effects in children as low as 0.015 ppm [one-third of the allowable average in N.J.]. The most noticeable and reproduced impacts observed at low levels are the susceptibility to respiratory disease (such as cold and flu symptoms." (pg. 897)

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NITROGEN OXIDES (NOx) (cont’d)

"For the general population, the average concentration of NO2 is less that 0.02 ppm suggesting that there is a slight chance that children may have challenged immune systems."

"The potential effects on children's immune systems are most noticeable in the frequency and severity of childhood colds and flu. The symptoms of runny nose, sore throat, difficulty sleeping and exhaustion are not life threatening but certainly troubling to the children and their families. It is not clear if early susceptibility to these diseases has long lasting effects with respect to adult health conditions." (pg. 897)

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OZONE: “The entire population of the state has been potentially exposed to ozone concentrations above the 8-hour standard.” (pg. 909)

“Children are most at risk from exposure to ozone because they are active outside, playing and exercising, during the summertime when ozone levels are at their highest.” (pg. 909)

“Exposure to ozone can also increase susceptibility to respiratory infections.” (pg. 908)

“Thousands of studies of ozone exposure indicate that there is no minimum threshold for triggering respiratory responses and a significant proportion of hospital visits can be associated with exposure to elevated ozone levels.” (pg. 912)

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FINE PARTICLES (SOOT) – PM 2.5

“Fine and ultrafine particles can be inhaled deep into the lungs, where they can deliver toxic constituents to the lung tissue and blood stream in addition to being lodged in lung tissue and interfering with lung function.” (pg. 915)

“It appears that particulate exposure causes an inflammatory response which may damage the body’s defense mechanisms. Cardiovascular effects from particulate exposure include an increase in coagulation of the blood due to the release of certain molecules in the body. There is also some evidence that lead[s] researchers to believe that particles can move from the lung tissue to other target sites which cause[s] effects at other locations.” (pg. 916)

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FINE PARTICLES (cont’d) – PM 2.5

Since 1999, NJ DEP has measured fine particles at 18 locations.

In the year 2000, EPA’s allowable annual average for fine particles (15 µg/m3) was exceeded at 8 locations (44%). (pg. 917)

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FINE PARTICLES (cont’d)- PM 2.5

According to the N.J. Comparative Risk Project, for each 10 µg/m3 increase in the 3-month average for PM 2.5 [fine particles], there is a corresponding increase of:

4% for deaths from all causes6% for cardiopulmonary deaths8% for lung cancer deaths. (pg. 918)*

* Citing C. Arden Pope and others, “Lung Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine Particulate Air Pollution,” Journal of the American Medical Association (JAMA), Vol. 287, No. 9 (March 6, 2002), pgs. 1132-1141.

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FINE PARTICLES (cont’d)

“Abt Associates, Inc. was commissioned by the US EPA... to analyze data and develop equations which estimate premature mortality [death] due to outdoor levels [of fine particles]...

This [effort] assumes that the [federal fine particle standard] is protective of human health.... Application of the equations derived by Abt Associates, Inc., results in an estimate of approximately 500 to 1000 premature deaths per year in NJ due to PM 2.5 [fine particles].” (pg. 919)

That’s one to three funerals each day, 365 days a year.

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FINE PARTICLES (cont’d)

“Inhalation can aggravate existing respiratory and cardiovascular disease, damage lung tissue, and interfere with lung function.” (pg. 923)

“Groups most widely affected include young children, asthmatics, the elderly, smokers, and individuals with chronic lung or cardiovascular disease....

“Children and adolescents may be at increased risk because they have higher respiration rates.” (pg. 923)

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PESTICIDES IN FOOD

“There are no crops grown or food consumed that can be guaranteed completely pesticide free...” (pg. 928)

“There are no current NJ data available that can be used for quantification of actual exposure to pesticide residues fromfood grown in NJ.” (pg. 929)

“Over 9000 commodity/pesticide active ingredient combinations currently have tolerances [numerical limits on allowable residues] and will need [risk] assessment.” [pg. 932)

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PESTICIDES IN FOOD (cont’d)

"It is difficult to actually quantify the exposure level to the over 300 different pesticides used on foods.... The conclusion is that while there is much data available, there are great gaps in what is required before a valid assessment can be performed on the impacts from the presence of the myriad of pesticides." (pg. 929)

"Infants and children have higher susceptibility to pesticide residues due to their stage of immature development and their increase in risk from pesticide exposure. Exposure to even trace levels of POPs [persistent organic pollutants] at crucial times in fetal or infant development can disrupt or damage human hormone, reproductive, neurological, or immune systems." (pg. 929)

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PESTICIDES IN FOOD (cont’d)

"Of 316 pesticides with food tolerances [numerical limits on allowable residues on foods], only 163 (52%) of them are routinely analyzed under FDA's [regulatory program]. Pesticide metabolites and breakdown products, significant or toxic inert ingredients need to be analyzed but we do not have estimates of these. No risk estimates can be done because this basic data are [sic] not available." (pg. 931)

"Most of the NJ state population and population of the subgroups are effected [sic]." (pg. 931)

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PESTICIDES IN FOOD (cont’d)

"All New Jersey citizens are exposed to pesticides in the food that they eat. Monitoring of food products shows that 40% of grain samples, 55% of fruits and 30% of vegetables test positive for at least some level of pesticide residues. In a few cases, these detections show concentrations of pesticides over established safety limits. There is evidence that children are more susceptible to pesticide toxicity because of rapid growth during development and the higher body burden that results when children intake levels are similar to adults." (934)

NJ DEP RISK SUMMARY: "A large population is exposed to possible pesticide contamination, but the levels of exposures are generally low and within established safety limits." (pg. 934)

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PESTICIDES INDOORS

"...80% to 90% of the exposure to pesticides occurs through the indoor environment." (pg. 936)

"Many of the extremely persistent pesticides have not been in use for over a decade, yet they may still be detected in indoor air." (pg. 936)

"Many studies show widespread presence of pesticide residues in homes." (pg. 936)

"Pesticide exposure by ingestion of dust by small children (under six years old) may be of greater importance than the respiratory exposure to pesticides." (pg. 937)

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PESTICIDES INDOORS (cont’d)

"[In a 1986-1988 EPA study of 32 pesticides]... Thirty commonly used household pesticides were found in house dust and yard soil…. Residues of many pesticides were found in and around the home even when there was no known use of them on the premises." (pg. 937)

"Older homes (e.g., built in the 1930-40s) were found to have high levels of indoor pesticides. Homes built in the 1960s show second highest levels." (pg. 938)

"EPA among others has serious concerns about the chronic impacts of low doses especially on the endocrine system and reproduction, the neurological and immune systems, cognitive and behavioral systems such as learning, and memory." (pg. 942)

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PESTICIDES OUTDOORS

There are approximately 600 unique pesticidal chemicals ("active ingredients“) in use outdoors in NJ. These are used on residential lawns, turf, home and outdoor gardens, parks, camp-sites, playgrounds, driveways, roads and rights-of-way, and golf courses. (pg. 946)

"Significant amounts of outdoor pesticides enter the indoor environment through track-in. This results in higher levels in indoor dust than outdoor soil concentration levels." (pg. 950)

"Low levels of long-lived or persistent pesticides are present in the atmosphere throughout the year. These pesticides have been found wherever they are studied. Some of these pesticides have the ability to bioaccumulate in humans and in the food chain." (pg. 947)

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PESTICIDES OUTDOORS (cont’d)

"Most pesticides have not been fully evaluated with respect to endocrine disruption. EPA tests and criteria are still being developed and have been criticized as being deficient in the ability to define and assess lose dose effects of pesticides on the immune system and neurological structure." (pgs. 949-950)

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PESTICIDES IN WATER

Total annual outdoor pesticide use in N.J.: 2,365,845 pounds(or 5 ounces for every resident of the state)

"There are more than 600 pesticides in use in New Jersey... They are designed to be toxic to target species, and in most cases create risk to humans as well." (pg. 954)

"There are only 26 federal [standards] for pesticides in drinking water supplies" and eight of these are for pesticides no longer legal for use in New Jersey. (pg. 958)

US Geological Survey (USGS) reported in 1999 that every water sample collected from 50 streams in NJ and Long Island (NY) contained at least one pesticide. (pg. 962)

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PCBs (polychlorinated biphenyls)

PCBs are a group of 209 polychlorinated biphenyl congeners produced as mixtures... for various uses, such as fire retardants, hydraulic fluids, insulating materials in transformers and capacitors, and open-ended applications (e.g., plasticizers, surface coatings, inks, adhesives, pesticide extenders, paints, and microencapsulation of dyes for carbonless duplicating paper)." (pg. 974)

"Among the effects of various of the PCB congeners are neurodevelopmental retardation, decreased thyroxine levels, reproductive dysfunction, immune system suppression, carcinogenesis, and enzyme induction." (pg. 974)

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PCBs (polychlorinated biphenyls) (cont’d)

"The likely effects of PCBs... include breast cancer, non-Hodgkins lymphomas, liver and gall bladder cancers, pancreatic cancer, decreased circulating thyroid hormone, and prenatal effects that affect postnatal neurodevelopment."

"Breast feeding transfers organochlorines from mother to infant (as much as 20-25% of prenatal maternal body burden) and results in an organochlorine intake in the range of 50-fold higher than adults on a body weight basis." (pg. 976)

IMPORTANT NOTE: Breast feeding is still the healthiest and best way to nourish an infant.

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PCBs (polychlorinated biphenyls) (cont’d)

"As many as 2000 to 2500 cases of cancer per year may be attributable to PCBs in New Jersey. This is approximately one-third to one-half of the total incidence of breast, pancreatic and non-Hodgkins lymphatic malignancies in the state. There are however significant uncertainties in these estimates. There is also evidence that pre- and post-natal exposures to PCBs may have adverse effects on neurological development." (pg. 982)

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PAHs (polycyclic aromatic hydrocarbons)

Polycyclic aromatic hydrocarbons (PAHs) are chemical compounds... that result from incomplete burning of organic material such as cigarettes, wood, food, and fossil fuels. PAHs are found nearly everywhere in the environment, both naturally and as a result of human activities. There are thousands of PAHs; of particular concern are those that cause cancers, including skin, bladder, lung, and possibly the gastrointestinal tract." (pg. 993)

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PAHs (polycyclic aromatic hydrocarbons) (cont’d)

"All New Jersey residents have been and will continue to be exposed to PAHs, however, the degree of exposure from these sources can vary greatly from region to region, with higher levels in urban areas... Children and adolescents may be at increased risk due to higher rates of metabolism." (pg. 993)

"There are insufficient exposure data available to quantify the number of illnesses in New Jersey." (pg. 993)

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RADIUM IN WATER: Radium (Ra) is a naturally-occurring radioactive element…. (pg. 1005)

"Bone sarcoma [cancer] increases have been reported in relationship to radium in drinking water in studies in Canada, Illinois, and Iowa. Because of these findings, and unknowns regarding actual tap water concentrations in many well water sites, elevated radium in some New Jersey drinking water sources is rated as an important health/public health issue for the state." (pg. 1013)

"Radium passes through mother's milk to the feeding infant; it also crosses the placenta during pregnancy, and is retained in fetal bones." (pg. 1005)

IMPORTANT NOTE: Breast feeding is still the best way to nourish an infant.

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RADIUM IN WATER (cont’d)

"Radium content of fish and game could be important in some populations with high consumption." (pg. 1012)

"In some areas of the state more than 50% of drinking water wells exceed health based standards." (pg. 1013)

However, NJ DEP assumes, without stating the basis of the assumption, that the vast majority of water from these wells is treated or diluted down to levels that meet federal “health-based” standards, and that, therefore, only 100,000 to 300,000 citizens are regularly drinking water containing radium that exceeds federal drinking water standards. (pg. 1008)

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RADON IN AIR AND WATER

Radon is a radioactive gas found in both air and water in many parts of New Jersey.

Consequences of average radon exposure:"Total number of lung cancers per year in NJ is 1426. Total number of stomach cancers per year in NJ is 10." (pg. 1018)

"The total number of lung cancers resulting from radon exposure may be as high as 1700 per year." (pg. 1021)

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STS (Second-hand Tobacco Smoke)

"Over 4000 chemicals including 40 known or suspected human carcinogens have been identified in cigarette smoke.” (pg. 1024)

Health effects in N.J. attributable to STS exposures:

Otitis media (middle ear infections) (14,000-32,000 cases/yr)

Asthma exacerbation (8,000-20,000 cases/yr)

Bronchitis and pneumonia (3,000-6,000 cases/yr)

New asthma cases (160-520 cases/yr)

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STS health effects in N.J (cont’d)

Ischemic heart disease (700-1240 deaths/yr) (average: 970)

Low birth weight (194-372 cases/yr)

Lung cancer (60-80 deaths/yr) (average: 70)

Sudden infant death syndrome (SIDS) (38-54 deaths/yr) (average: 46)

Lower Respiratory Tract Illness (LRI) in children up to 18 months (2-4 deaths/yr) (average: 3)

Total estimated STS deaths/yr: 1089 (pgs. 1025-1027)

"STS exposure occurs among all populations and ecosystems throughout New Jersey." (pg. 1025)

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STS (second-hand Tobacco Smoke) (cont’d)

"Children's lungs are even more susceptible to harmful effects from STS than those of adults. In infants and young children up to three years old, exposure to STS causes an approximate doubling of the incidence of pneumonia, bronchitis and bronchiolitis [a form of pneumonia]. There is also strong evidence of increased middle ear effusions [escape of fluid], reduced lung function, and reduced lung growth.” (pg. 1025)

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SOx (sulfur oxides)

Sulfur oxides (SOx) are by-products of the combustion of sulfur-containing fuels -- coal and to a lesser extent liquid petroleum fuels.

"There is an average exposure that all New Jersey citizens face, and there are some areas of the state that face elevated concentrations [Camden, Gloucester, Morris and Union counties, and probably Essex though there is no SOx monitor in Essex.] (pg. 1033)

“Therefore, we can assume that the children in the urban counties have a slight but increased chance of both respiratory illness and for greater susceptibility to colds and flu symptoms." (pg. 1034)

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UV (ultraviolet radiation from the sun)

"UV exposure is known to be associated with various skin cancers, accelerated skin aging, cataract and other eye diseases, and may reduce a person's ability to resist infectious diseases." (pg. 1038)

"A number of studies suggest that UV exposures at environmental levels suppress immune responses in both rodents and man. In rodents this immune suppression results in enhanced susceptibility to certain infectious diseases with skin involvement and some systemic infections. In humans, pigmentation appears to provide little protection against UV-induced immune suppression." (pg. 1041)

"There is no question that the risk is increasing." (pg. 1042)

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VOCs (volatile organic compounds) - carcinogenic

The New Jersey Comparative Risk projected studied 5 carcinogenic VOCs and found that they are present statewide at low levels. The average concentrations (in µg/m3) for 4 of the 5 are given (pgs. 1048-1049) as: acetaldehyde (1.21)acrylonitrile (0.007)hydrazine (0.00015)ethylene oxide (0.012)

The total estimated cancers resulting from exposures to these 5 is one cancer every three years. (pg. 1050)

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VOCs (volatile organic compounds) – non-carcinogenic

State-wide average outdoor exposures include:

Toluene (3.8 µg/m3)Xylene (2.9 µg/m3)Methanol (1 µg/m3)

And these indoor exposures:

M- and o-xylene (21 to 29 µg/m3)Toluene (60-62 µg/m3)

In addition, Xylene and Toluene "are often detected in drinking water" at levels below current regulatory limits. (pg. 1055)

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• 1,3-Butadiene• Acrolein• Benzene• Cadmium• Carbon monoxide• Chromium• Dioxin• Disinfection by-products in H2O

– perhaps 600 chemicals, including:

– trihalomethanes– chloroform– bromodichloromethane– haloacetic acids– haloaldehydes– haloketones– haloacetonitriles– chloropicrin

– cyanogen– chloride– Chlorophenols

• Endocrine disrupters unknown number (80-100?)

• Electromagnetic fields• Fine particles

– metals– sulfates– nitrates– acidity– ozone– peroxides– aldehydes– free radicals

• Formaldehyde• Lead• Mercury

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• MTBE• Nickel• NOx - Nitrogen oxides• Ozone• Pesticides in food

– 316 legal chemicals• Pesticides - Indoors• Pesticides - Outdoors

– 600 chemicals in 9000 forms• Pesticides - water• Polychlorinated biphenyls

(PCBs)– 209 chemicals, not all

present• Polycyclic aromatic

hydrocarbons (PAHs)– More than 100 different

chemicals

• Radium in drinking water• Radon• Second-hand tobacco

smoke– 4000 chemicals

• SOx - Sulfur oxides• Ultraviolet radiation• Volatile organic compounds -

carcinogenic– acetaldenyde– Acrylonitrile– hydrizine– ethylene oxide

• Volatile organic compounds - non-carcinogenic– Toluene– Xylene (M- and o-)– Methanol

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Conclusion:** The children of New Jersey are exposed to several thousand toxic materials on a daily basis.

** Most of these individual toxic materials are very poorly understood. Determining the effects of exposure to mixtures of chemicals is not possible due to limitations of science.

** There is widespread agreement that children are more susceptible to harm than adults.

** More than 99% of these exposures are perfectly legal and fall within established numerical limits (to the extent that any such limits exist).

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Conclusion (cont’d)

** Despite the absence of data about the consequences of exposures, risk assessments have been used to assure the public that most of these exposures are harmless or that the risks are “acceptable.”

** Based on risk assessments, government agencies claim to have established “safe” levels and “health-based standards” but the scientific justification for using such terms is weak or non-existent.

** There is no sense of urgency about these problems because the risks have been “assessed” and declared “acceptable” by government authorities.

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Conclusion (cont’d)

THEREFORE: the risk-based approach --

(a) provides a false sense of security to parents and a false mantle of “sound science” for government regulators;

(b) puts the burden of proof of harm on the victims of exposures – it is up to YOU to show you are being harmed by a particular exposure before prevention can be considered;

(c) excludes the public from debating the wisdom of initiating a different approach (prevention, precautionary action);

(d) allows government to claim that it is protecting public health adequately and that a truly preventive, precautionary approach is not needed or is already being used.