Statement on Phase-out of Cyanazine

7/29/2019 Statement on Phase-out of Cyanazine

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Environmental Working Group

Executive Summary

The tap water of abou t 1 million Californians, most ly in the San Joaqu in Valley, is contam i-

nated with a long-banned pesticide that is one of the most potent carcinogens known ,

according to an Environm ental Working Group (EWG) analysis of state d ata. Yet

Californias current dr inking water standards for the compou nd allow exposu re to 100

times the safe adu lt dose and almost 300 times the safe dose for infants and children.

EWGs computer-assisted analysis of water u tility test results for DBCP in finished water

leaving treatment plants found that DBCP contaminates tap w ater in 38 water systems in

nine counties. Fresno, Riverside, Clovis, Lodi and Madera are the largest communities with

serious contamination p roblems (Table 1).

In all 38 of these comm un ities, the tap water delivered to hom es, schools and businesses

contains levels of DBCP well above the levels considered safe by the state for other cancer-

causing comp ound s -- the so-called negligible, or one in one million, risk level. In 31 com-

mu nities, average DBCP contam ination levels for 1996 throu gh 1998 were from 10 to 200

times the amou nt associated w ith a negligible risk of cancer (Spath 1988).

DBCP is a potent carcinogen and perhap s the most pow erful testicular toxin ever mad e.

The pesticide causes genetic mutations an d cancer in every species of animal on wh ich it

has been tested , in both sexes and by all routes of exposure -- ingestion, contact with the

skin, and inhalation. It is classified as a p robable hu man carcinogen by the U.S. Environ-

men tal Protection Agency, and the World Health Organization classifies it as having

sufficient eviden ce of carcinogenicity. Accord ing to Un iversity of California researchers,

DBCP can abolish testicular function in test animals that are administered just a single

dose of the compoun d (Reed et a l. 1987).

Infants and children at highest risk

The current legal limit for DBCP in California tap w ater does not protect infants and chil-

dren. For example, the risk assessments used by the state to establish safe exposure limits

do not acknowledge that bottle-fed babies drink seven times m ore water relative to their

size than ad ults. EWG corrected the states risk estimates to account for infants wh o d rink

contam inated tap water m ixed in their formula and also bathe in DBCP-tainted w ater. We

found that the curren t legal contam ination limit, or MCL, allows 285 times more DBCP in

tap w ater than w ould norm ally be considered safe for infants.

EWG California Policy Memorandum

Contact:

Bill Walker (415) 561-6698

Zev Ross (415) 561-6699

EWG California P.O Box 29201, The Presidio San Francisco, CA 94129 (415) 561-6698 Fax (415) 561-6696

[email protected] www.ewg.org

November 1999

Tap Water in 38 Central Calif. Cities Tainted With Banned Pesticide --Some Bottle-Fed Infants May Exceed Safe Dose Before Age 1

W O R K I N G G R O U PT M

E N V I R O N M E N T A L


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Environmental Working Group2

SOURCE: Environmental Working Group, from water suppliers test results, 1996-98

Based on cur rent levels of contamination, all of which are legal, EWG estimates that in 19

California communities including Fresno, Riverside, Clovis, Madera and Lodi, the average

bottle-fed infant wh o d rinks formula reconstituted with tap water receives a lifetimes dose

of DBCP by his or her first birthd ay (Table 2). By the time these children are one year old ,

their cancer risk from DBCP exceeds the one in one m illion level of risk generally deem edacceptable by state and federal regu lators. In 11 comm un ities these bottle-fed infants re-

ceive a lifetime dose in the first six mon ths of life.

Twenty years after it was ban ned , DBCP is still found in the tap wa ter of at least 1 million

Californians at levels that p resent a h igh d egree of risk. Because it takes 140 years for

DBCP to comp letely degrad e un der average groun dw ater conditions in California, for all

practical pu rposes DBCP will remain in the d rinking water of these comm un ities un til

action is taken to clean it up or bring alternative w ater sup plies to the affected areas.

Table 1: Thirty-eight California comunities where DBCP levels exceed cancer risk standards.

Avg. DBCP Multiple of Multiple of Population Conc (ppb) Safe Adult Safe Child

Water System City Served 1996-98 Dose Dose

Carri l l o W ater Sy stem Sh after 5 0 0 .4 3 4 2 1 7 6 2 0Su n W or ld In tern ati o n al In c .-Co m Cen ter Bak ersf i el d 2 5 0 0 .1 9 4 9 7 2 7 7Tu l c o W ater Co m p an y V i sal i a 7 2 0 0 .1 8 4 9 2 2 6 3

U C Sh after Researc h Stati o n Sh after 2 6 0 .1 8 1 9 1 2 5 9M alaga Co u n ty W ater D i str i c t Fresn o 1 ,0 0 0 0 .1 6 6 8 3 2 3 7M ad era-C i ty M ad era 3 5 ,5 1 5 0 .1 3 8 6 9 1 9 7Ex eter C i ty o f Ex eter 8 ,1 3 1 0 .1 1 6 5 8 1 6 6Par l i er C i ty o f Par l i er 1 0 ,0 0 0 0 .1 1 3 5 7 1 6 1Lin d say C i ty o f Li n d say 8 ,9 7 0 0 .0 9 1 4 6 1 3 0Bak m an W ater C o m p an y Fresn o 8 ,5 0 0 0 .0 8 8 4 4 1 2 6Lo d i C i ty o f Lo d i 5 3 ,9 0 3 0 .0 8 4 4 2 1 2 0C l o v i s C i ty o f C l o v i s 7 0 ,5 3 5 0 .0 7 4 3 7 1 0 6LSID - To n y v i l l e Li n d say 4 0 0 0 .0 7 1 3 6 1 0 1Cu tl er PU D Cu tl er 4 ,0 0 0 0 .0 5 8 2 9 8 3Riv ersid e C i ty o f Ri v ersi d e 2 4 5 ,0 0 0 0 .0 5 7 2 9 8 1C i ty o f San ger San ger 1 7 ,3 8 0 0 .0 5 5 2 8 7 9D elh i CW D D elh i 3 ,2 8 0 0 .0 4 8 2 4 6 9Fresn o C i ty o f Fresn o 3 9 0 ,3 5 0 0 .0 4 5 2 3 6 4Reed ley C i ty o f Reed ley 2 1 ,0 0 0 0 .0 4 3 2 2 6 1

W asc o C i ty o f W asc o 1 3 ,7 7 4 0 .0 3 7 1 9 5 3D elan o G ro w er ' s G rap e Pro d u c ts D elan o 4 3 0 .0 3 3 1 7 4 7Ear l im art PU D Ear l im art 6 ,5 0 0 0 .0 3 0 1 5 4 3Ceres C i ty o f Ceres 3 0 ,0 3 8 0 .0 2 8 1 4 4 0Rip o n C i ty o f Rip o n 8 ,2 0 0 0 .0 2 5 1 3 3 6V i sal i a - Cal i fo rn ia W ater Serv i c e San Jo se 8 2 ,3 0 0 0 .0 2 5 1 3 3 6K in gsb u rg C i ty o f K in gsb u rg 8 ,3 3 5 0 .0 2 3 1 2 3 3Iv an h o e Pu b l i c U ti l i ty D i st Iv an h o e 5 ,0 0 0 0 .0 2 3 1 2 3 3C i ty o f H u gh so n H u gh so n 3 ,3 8 1 0 .0 2 2 1 1 3 1D elan o C i ty o f D elan o 2 9 ,9 4 4 0 .0 2 0 1 0 2 9V au gh n W C In c Bak ersf i el d 1 1 ,9 0 6 0 .0 2 0 1 0 2 9M o d esto C i ty o f M o d esto 1 8 0 ,3 2 0 0 .0 2 0 1 0 2 9Cal i fo rn ia W ater Serv i c e - Sel m a San Jo se 1 6 ,2 5 0 0 .0 1 6 8 2 3Lam o n t PU D Lam o n t 1 2 ,6 9 0 0 .0 1 5 8 2 1Tu lare C i ty o f Tu lare 3 9 ,8 0 0 0 .0 1 2 6 1 7D in u b a C i ty o f D in u b a 1 4 ,1 9 2 0 .0 1 0 5 1 4

Caru th ers Co m m Serv D ist Caru th ers 1 ,6 6 0 0 .0 0 5 3 7C i ty o f M o d esto D e H i l l c rest M o d esto 8 0 5 0 .0 0 4 2 6O ro si Pu b l i c U ti l i ty D i str i c t O ro si 5 ,4 8 6 0 .0 0 4 2 6

Total 1,343,343

Average 0.069 34 98


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Environmental Working Group3

State health standards for DBCP are incredibly weak. They do virtually nothing to protect

Californians, but instead , legalize unsafe levels of exposu re to the pesticide. They allow

100 times m ore DBCP in tap w ater than is generally considered a safe level of exposure to

carcinogens, and nearly 300 time the generally recognized safe level when state estimates

are corrected to accura tely reflect infant exposure v ia tap water and bathing.

Table 2: Formula-fed children in 19 communities get a lifetime dose of DBCP by age one

Age of child atone in a million

Po ulation cancer riskWater System City Served (months old)

C arr i l l o W ater Sy stem Sh after 5 0 1 .0Su n W orl d In tern ati o n al In c .-C o m Cen ter Bak ersfi e l d 2 5 0 2 .2Tu l c o W ater C o m p an y V i sal i a 7 2 0 2 .3U C Sh after Researc h Stati o n Sh after 2 6 2 .3M alaga C o u n ty W ater D i str i c t Fresn o 1 ,0 0 0 2 .5M ad era-C i ty M ad era 3 5 ,5 1 5 3 .0Ex eter C i ty o f Ex eter 8 ,1 3 1 3 .6Par l i er C i ty o f Par l i er 1 0 ,0 0 0 3 .7Lin d say C i ty o f Li n d say 8 ,9 7 0 4 .8Bak m an W ater C o m p an y Fresn o 8 ,5 0 0 5 .0Lo d i C i ty o f Lo d i 5 3 ,9 0 3 5 .3C l o v i s C i ty o f C l o v i s 7 0 ,5 3 5 6 .2LSID - To n y v i l l e Li n d say 4 0 0 6 .5

C u tl er PU D C u tl er 4 ,0 0 0 8 .1Ri v ersi d e C i ty o f Ri v ersi d e 2 4 5 ,0 0 0 8 .3C i ty o f San ger San ger 1 7 ,3 8 0 8 .7D elh i C W D D el h i 3 ,2 8 0 1 0 . 2Fresn o C i ty o f Fresn o 3 9 0 ,3 5 0 1 0 . 9Reed l ey C i ty o f Reed l ey 2 1 ,0 0 0 1 1 . 4W asc o C i ty o f W asc o 1 3 ,7 7 4 1 4 . 0D elan o G ro w er ' s G rap e Pro d u c ts D el an o 4 3 1 6 . 0Ear l im art PU D Ear l im ar t 6 ,5 0 0 1 8 . 6C eres C i ty o f C eres 3 0 ,0 3 8 2 0 . 3Rip o n C i ty o f Rip o n 8 ,2 0 0 2 2 . 8V i sal i a - C al i fo rn i a W ater Serv i c e San Jo se 8 2 ,3 0 0 2 3 . 2K in gsb u rg C i ty o f K i n gsb u rg 8 ,3 3 5 2 6 . 2Iv an h o e Pu b l i c U ti l i ty D i st Iv an h o e 5 ,0 0 0 2 5 . 6C i ty o f H u gh so n H u gh so n 3 ,3 8 1 2 7 . 0D elan o C i ty o f D el an o 2 9 ,9 4 4 3 0 . 6V au gh n W C In c Bak ersfi e l d 1 1 ,9 0 6 3 0 . 1M o d esto C i ty o f M o d esto 1 8 0 ,3 2 0 3 0 . 8C al i fo rn i a W ater Serv i c e - Selm a San Jo se 1 6 ,2 5 0 3 9 . 8Lam o n t PU D Lam o n t 1 2 ,6 9 0 4 5 . 0Tu lare C i ty o f Tu lare 3 9 ,8 0 0 5 6 . 2D in u b a C i ty o f D in u b a 1 4 ,1 9 2 6 8 . 1C aru th ers C o m m Serv D i st C aru th ers 1 ,6 6 0 1 9 7 . 6C i ty o f M o d esto D e H i l l c rest M o d esto 8 0 5 2 2 2 . 9O ro si Pu b l i c U ti l i ty D i str i c t O ro si 5 ,4 8 6 2 8 2 . 9

Total 1,349,634

Average 34SOURCE: Environmental Working Group, from water suppliers test results, 1996-98


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Recommendations

The state mu st set a legal contam ination limit, or MCL, for DBCP that reflects a safe level

of exposure. EWG recommend s an MCL of 0.001 parts per billion (ppb).

But this alone will not solve the problem. People in the affected commu nities deserve clean

tap water, as it w as before the actions of the p esticide indu stry and state regulators com-bined to pollute it with DBCP. To achieve that goal EWG recomm end s:

The state mu st immediately provide fun ds to the affected communities to either treat

water w ith advanced carbon and pollutant separation techniqu es to remove DBCP from

finished tap water, or obtain new sou rces of dr inking water that a re not contaminated w ith

any amoun t of DBCP.

The state should take legal action against the m anu facturers of DBCP to recoup all costs

associated with cleanup, securing alternative water sources and m onitoring for all comm u-

nities with an y amou nt of DBCP in their tap w ater.

The manufacturers should also be forced to compensate all prop erty owners served by

water systems contam inated w ith DBCP for any decrease in p roperty values associated

with DBCP contamination dr inking water.

Manu facturers should also pay all costs incurred by ind ividuals with p rivate wells to

clean u p, filter or redu ce DBCP contamination or to obtain a new clean supp ly of drinking

water.

Failures by the state

Two actions by the State of California prod uced this weak h ealth stand ard for DBCP in tap

water. The first was the d ecision that the cost of cleaning u p the w ater d id not justify the

health protections that it wou ld provide to the people who d rink and bath e in it. The

second is the fact that infants and children are ignored in the p rocess of setting a safe expo-

sure level.

Docum ents from the California Departm ent of Health Services show that th e state never

seriously considered setting an enforceable limit for DBCP contam ination at a point tha t

wou ld p rovide the n ormal level of health p rotection for the pu blic that is typically app lied

to poten t cancer causing substances. DHS risk assessments from the late 1980s show that

the lowest level considered (and u ltimately rejected) as a m aximu m contam inant limit wasfifty times higher than wh at the DHS described at tha t time as the level that wou ld nor-

mally be considered a safe dose the one in one m illion cancer risk level (Spath 1988).

Part of the reason that DHS never seriously considered a truly safe health stand ard for

DBCP is that DBCP is such a poten t pesticide that it is not p ossible to detect an amoun t

small enough to be safe. Any d etection carries risks that are above the trad itional one in

one m illion negligible risk level.

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The safe level calculated by DH S, 0.002 parts p er billion, is five times smaller th an the

lowest detectable amou nt, 0.010 ppb. Even so, the state could have provided a much

greater safety margin for the pu blic by setting the safe level at the limit of detection. Regu-

lators rejected th is option because in their jud gment the ad ditional pu blic health protec-

tions were not worth the mon ey.

This illustrates a major breakdown in environmental law and regulation. Und er cur rentpolicy, both the health risks and the full cost of cleanup are should ered by the p ublic, even

though the public is the only truly innocent party in the process. The manufacturer w ho

prod uced it, farmers who u sed it and state regulators wh o licensed it can all walk aw ay

from the problem. Only the people who had nothing d o to with it are faced with the pros-

pect of drinking and bathing in contaminated water, or p aying tens of millions of dollars to

clean it up. Notably, the comm un ities drinking contaminated w ater were never given the

option to decide whether they wanted to spend the money to clean up their tap water.

No protections for infants and children

The most glaring error in th e risk assessment u sed by the state to set the current MCL forDBCP is the assump tion that an ind ividu al consum es a constant am ount of water over a

lifetime, when m easured in m illigrams of water p er kilograms of body w eight. This as-

sum ption is severely out of step with contemp orary risk assessment techniques, and greatly

off target in terms of what infants and children really dr ink. By using this assumption,

DHS assumes a water consump tion level for infants tha t is less than wh at 99 percent of all

bottle fed babies actua lly drink. Put anoth er way, DHS fails to protect 99 percent of all

bottle fed babies d rinking formula mad e with tap water from DBCP du ring the critical first

four m onth s of life.

By using these outdated assump tions, DHS overlooks the fact that m any children get a

lifetime dose of DBCP in their first years of life. Using infant tap water consump tion data

repor ted by the U.S. Departm ent of Agriculture for 1994 throu gh 1996, EWG estima tes that

in 19 California commu nities, an average bottle fed baby dr inking formula reconstituted

with tap w ater will get a lifetime d oes of DBCP by his or her first birthd ay. In 11 towns,

bottle fed babies will get a lifetime d ose of DBCP by six mon ths of age.

DBCP is a potent carcinogen and perhap s the most p owerful testicular toxin ever mad e.

The pesticide causes genetic mutations an d cancer in every species of animal on wh ich it

has been tested, in both sexes and by all routes of exposure (ingestion, dermal contact, and

inhalation). It is classified as a p robable hu man carcinogen by the U.S. EPA, and is consid -

ered to have sufficient evidence of carcinogenicity by the World H ealth Organ ization.Accord ing th e University of California researchers, DBCP can abolish testicular fun ction

in test anim als adm inistered just a single dose of the comp ound (Reed et al. 1987).

Dangers during crucial developmental periods

Boys run serious risk of reproductive damage if DBCP exposure occurs during critical

periods of development: in utero, du ring infancy, and again dur ing pu berty. Everyone

exposed is at risk from the carcinogen ic effects of the comp ound , but children are generally

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recognized as being more susceptible than ad ults to poten t carcinogens like DBCP. Child-

hood cancer rates have r isen stead ily over the past 30 years, and exposure to cancer causing

environmenta l contaminants like DBCP is now considered by man y experts to be part of

the cause of this increase.

After correcting the DHS risk estimates to include DBCP exposure via tap water used to

reconstitute infant formula du ring the first four m onths of life, EWG estimates that currentsafeguard s allow 285 times m ore DBCP in tap water than wou ld normally be considered

safe by the state of California. But even this estimate does not includ e any ad justm ent for

the increased vulnerability of infants and children to carcinogens.

A recent review of proposed revisions to the federal cancer risk assessment guidelines by

scientists at the University of California, pu blished in the National Institu tes of Health,

Environmental H ealth Perspectives, characterized the flaws in the cur rent cancer risk

assessment m ethods this way:

Risk assessment m ethods for carcinogens have not considered the timing of doses of car-

cinogens during a hu man lifetime. Models used to estimate dose and response do not

consider the age at wh ich d oses are applied. A given dose of a carcinogen counts the same

at 70 years of age as it does at five. Because there is considerable evidence that d oses re-

ceived earlier in life are more likely to result in d evelopm ent of cancer than d oses received

late in life, this approach w ould be expected to underestimate risks of doses received d ur-

ing childhood .

There is no evidence to suggest that exposure standards based on assum ptions about ad ult

toxicity, suscept ibility, and exposure will adequately protect infants and children. Quite the

contrary, there is sufficient eviden ce for some agents to believe they m ay not . The p roposed

carcinogen risk assessment guidelines shou ld incorporate langu age that will provide in-fants and children w ith need ed p rotection (Buffler and Kyle 1999).

The DHS risk assessment assumes that a dose of DBCP consum ed at one mon th of age

presents the same risk as a dose at age 60. It also assumes that relative to their size, infants

and children , even bottle fed babies, are exposed to the sam e amou nt of DBCP as adu lts.

Both of these assum ptions are wrong, and both und ermine what little protection the cur-

rent MCL provides to the p ublic.

References

Buffler, Patricia A. and Am y D. Kyle. 1999. Carcinogen risk assessmen t guidelines and children. Environ-menta l Health Persp ectives. 107(6). P. A 286.

Reed et a l. 1987, Health Risk Assessment of 1,2, dibrom o-3-chloroprop ane (DBCP) in California Drinking

Water, Dep artm ent of Environ menta l Toxicology, University of Californ ia, Davis. State of California Contract

number 84-84571.

Spath, Dave. 1988. MCL for Dibromochlorop ropan e (DBCP). Memo to Peter A. Rogers, Chief, Public Water

Supp ly Branch, California Departm ent of Health Services. October 19, 1988.

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Documents

Statement on Phase-out of Cyanazine