Introduction
Deliberately Skewed Damage Assessment
Obscuring the Real Issues in Sediment Cleanup
Inaccurate Use of Monitoring Data
Economic Study Manipulation
Manipulation of Health Statistics
Misdirected Cancer Research - The GE Study

Scientists Critique the GE Study
Political Use of Junk Science
Links to More GE Information
Journal Abstract of the GE Cancer Study

click here  for more Lahey cartoons on the Fox River and Green Bay cleanup

Introduction

The Fox River polluters are fond of calling for "Sound Science" as an answer to all environmental concerns raised, but they frequently don’t use it themselves. Instead, they give the appearance of using science to defend their positions or to attack government regulatory decisions, while skewing information to their benefit. They often demand more studies, as a delay tactic, while their money stays safely invested in profit-making ventures. This tactic has worked well here for 30 years, from the time the Wisconsin DNR started investigating PCB pollution in the Fox River in 1971.

The following are recent examples of industry manipulation of science on the Fox River:

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Deliberately Skewed Damage Assessment

In November 2000, the DNR and Fort James Corporation announced they had reached a $7 million settlement as compensation and restoration for PCB damages to the Fox River and Green Bay. This settlement was based in large part on a scientific assessment performed by a consulting firm chosen by the Fox River Group of paper companies (see Thompson Defends Fox River Polluters). Recently, this assessment was challenged by the Science and Technical Advisory Committee (STAC) for the Fox River/Green Bay Remedial Action Plan. The STAC submitted detailed comments to the DNR stating that the consultant’s assessment was based on seriously flawed science. A quote from the STAC letter:

Obscuring the Real Issues in Sediment Cleanup

The Fox River Group used another consulting firm to write "scientific reports" to deliberately mislead the public about the significance of the PCB dredging demonstration projects. They focus attention on the day to day (transitory) surface concentrations before and after dredging to claim that little benefit was seen, when the truly important benefit is mass removal of large quantities of PCBs, to prevent future releases permanently. The surface residue immediately after dredging is relatively insignificant compared to the total mass removed. As an example, here’s a quote from the Fox River Group’s webpage : 

Inaccurate Use of Monitoring Data

The Fox River Group, and General Electric in New York, deliberately cite sediment monitoring data before dredging projects are complete to make dishonest claims that dredging made the sediments more polluted. As we all know, serious errors were made (deliberately) at both Deposit N and Site 56/57 dredging demos, which left both sites exposed over the winter before they could be completed. This allowed the companies to take samples after the first dredging season and claim that dredging made the PCB concentrations worse. As an example, here’s a quote from the Fox River Group’s webpage: 

Economic Study Manipulation

The Fox River Group convinced the DNR to use a well-known industry consulting firm, Triangle Economics Research (TER), to assess the economic damage caused by PCBs. TER has a long history of serving corporate interests all across the country. TER’s own webpage cites more than 50 Natural Resource Damage Assessments where they’ve helped polluters limit their liabilities, by using the most conservative economic methods possible. TER recently merged with Blasland, Bouck and Lee (BBL), another consulting firm which has worked for several years directly as technical consultant and advocate for several of the Fox River Group member companies. BBL also works for General Electric and many other PCB polluters across the country. They specialize in contaminated sediment problems.

Not surprisingly, TER and the Fox River Group have been critical of the economic methods used by the U.S. Fish And Wildlife Service, because the Service calculated much higher (truer) damages --- and the Fox River Group has deliberately misled the public about the economic methods used by the Service.  (see the Fox River Group webpage.)

The Fox River Group and Wisconsin DNR claim the Service used a method called "Contingent Valuation" which uses in-depth surveys of the public to determine their "willingness to pay" for lost services. The Fox River Group and Wisconsin DNR claim that a recent Nobel Laureate, Daniel McFadden, says that "Contingent Valuation" is a flawed method because of the potential for bias in the results. However, David Allen, the local Fox River project manager for the U.S. Fish and Wildlife Service, said the Service actually used an updated, improved version of Contingent Valuation called "Conjoint Analysis" which greatly reduces the potential for bias in the results. TER’s own lead economist, William Desvousges, uses Conjoint Analysis and has written numerous journal articles praising this method. 

The Fox River Group and the Wisconsin DNR also claim that a federal court has ruled that Contingent Valuation is not a valid method, based on a pollution case in Montrose, California. However, according to Mr. Allen, a judge did dismiss a case a few years ago, brought by the National Oceanic and Atmospheric Administration (NOAA) against a chemical company there; however, the judge ruled that the chemical injuries to wildlife were not proven. He did not reject the economic methods, but because the economic calculations were based on the wildlife injuries which were rejected, the economic methods were irrelevant. NOAA appealed to a higher court which reversed the lower court and ruled that the injuries were proven; however, this judge forced the parties into settlement negotiations. The case was settled without any ruling on the economic methods.

During preparations however, NOAA assembled a blue-ribbon panel of economists, including two Nobel Laureates (not McFadden), who concluded that Contingent Valuation is a valid technique for purposes of Natural Resource Damage Assessments, so long as a set of standards they detailed were used to prevent bias in the results. (Their conclusions are printed in the 1993 Federal Register, Vol. 58, pgs 4601-4614.) In another federal case, Ohio v. Interior, the court ruled that Contingent Valuation is valid. Economics methods are evolving each year, and anti-bias techniques are included in Conjoint Analysis, which is the reason U.S. Fish and Wildlife Service felt comfortable using this method. 

It’s important to note, however, that the Service used the lower-bound estimates of damages, which many citizens believe are too conservative and undervalue our economic losses due to PCBs. (see Economic Damages) This makes it doubly ironic that the Fox River Group’s PR campaign has succeeded in convincing many people that the Service’s estimates are outlandishly high.

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Manipulation of Health Statistics

In January 1999, Appleton Paper Company captured headlines (see Green Bay News Chronicle, 1/21/99) with the claim that cancer rates were lower in the Fox River Valley than the rest of the state; and implied that the data showed that PCBs had no impact on cancer rates and were therefore not a health concern. They based their claim on a review of a 1996 cancer mortality map of Wisconsin, which gave death rates per county. This public relations  message was flawed in a number of ways:

• It can be misleading to look at a map of cancer rates in Northeast Wisconsin, to compare our region with other areas, because so many factors must be weeded out to detect a true cancer-causing effect. Many people move in and out of the area, some neighborhoods are dominated by older citizens, some areas are low-income or high-income, etc. Many people don’t eat local fish, come in contact with the water or sediment, or breathe concentrated PCB vapors near the water or sediment. A true epidemiological study is needed of only those people with PCB exposures, especially through fish-eating. Those people studied need to provide blood and tissue samples to confirm the levels of their PCB exposure before results could be considered valid.

• If Appleton Paper had looked more closely they would have found that we have increased rates of Breast Cancer in Green Bay.   The state health department found these cancer clusters in only 3 zip codes in Wisconsin, and two are on the northeast side of Green Bay (zip codes 54311 and 54301) both located near and downwind from the last 7 miles of the Fox River, where more than 90% of the river's PCBs are concentrated.  Airborne PCBs tend to be the lightweight types of PCBs which behave strongly as estrogens (hormones), and increased estrogen levels have been linked to increased rates of breast cancer in national and international studies. This needs to be investigated.

• Overall cancer rates have increased dramatically in the U.S. over the last 50 years. Now, each of us has a 1 in 3 chance of developing cancer. This makes it difficult to detect increased rates of cancer from one cause. We need a full-scale epidemiological study before local effects can be linked to PCBs. Such studies have not been done in Northeast Wisconsin. People are sick or dying of cancer all around us, but on an individual level it’s very difficult to claim a single cause. 

• The Valley is heavily industrial and all of us are exposed to thousands of chemicals in our homes and workplaces, so it’s difficult to sort out all the confounding variables to determine a true effect. Results also have to be adjusted to take into account age, level of chemical exposure, bad diet, smoking, and drinking habits, and other chemical exposures. 

• Many cancers take a long time to develop, perhaps 20 or 30 years after exposure to the chemical. This lag time can complicate studies. (On the Fox River, fishing has been restored only about 20 years --- until the late 1970s the river was too polluted to support many sport fish.) It’s also possible that the children of fish-eaters may be at more risk of cancer, due to chemically triggered PCB effects during development of the baby in the womb. Such an effect may not appear for decades, long after exposure occurred.

• Cancer is only one of MANY serious health risks due to PCBs. Perhaps the most disturbing health problems are the developmental, immune and nervous system changes caused in children of PCB-contaminated mothers. It’s wrong to focus only on cancer due to PCBs.

• PCBs are only linked to certain kinds of cancer, not all kinds of cancer. Therefore, an overall map of all cancers in entire counties could miss true clusters of increased cancers of one type.

Misdirected Cancer Research --- The GE Study

The Fox Valley paper industries hailed a major study released in 1999 by General Electric (GE) of more than 7,000 of its workers because it supposedly shows that PCBs do not cause cancer. However, the study was seriously flawed and its results misrepresented.

• The study was based primarily on inhaled PCBs. Inhaled PCBs or PCBs absorbed through the skin tend to be the lighter weight types of PCBs (out of 209 possible) with fewer chlorine atoms attached --- not the highly-chlorinated versions more strongly associated with cancer. Airborne PCBs are more likely to produce nervous system damage or other health problems, with cancer a lesser risk, so the researchers were looking for the wrong types of health problems. This is important because the more carcinogenic forms of PCBs tend to accumulate in fish, ducks and other animal-based foods selectively, while the lighter PCBs go airborne. Those who eat fish from the Fox River and Green Bay need a cancer study which specifically examines fish-eaters' cancer rates. (We haven't found a single study of this type, which is disturbing after all these years.)

• The study actually showed some increases in 3 of the 6 types of cancer investigated (according to the Agency for Toxic Substances and Disease Registry, see below), but the company downplayed these results.

• GE paid a chemical-industry-funded research group to hire private detectives to find every GE employee who worked at or near the PCB plants in Hudson Falls and Fort Edward in New York state, which creates a potential selection bias affecting which people they chose to find [ie: those without cancer?] (Source: Hudson Sloop Clearwater )

• Many of the people in the study worked at GE less than a year. The researchers only required a work history at GE of at least 90 days.

• The study did not account for the lag time (latency) which can occur between the time of PCB exposure and the development of cancer. The lag time can often be 20 or 30 years after exposure.

• The study included thousands of people who never came into physical contact with PCBs. If every worker who did come in contact with PCBs died of cancer, the mortality would not have been "statistically significant" because their numbers would have been swamped-out by the large number of non-exposed people in the study. 

(Source:  Hudson Sloop Clearwater )

• The study did not look at the incidence of cancer, just mortality. Every single former GE employee could have been battling cancer for twenty years with no impact on this GE-funded study, because GE didn’t count cancer sufferers or survivors, only the dead. 

• The study did not look at long-term health effects in workers' children, which may be significant. 

Scientists Critique the GE Study

Scientists are highly critical of the "no cancer from PCB" claims being made as a result of the GE study. For example: 

"Most of the workers didn't work in areas where PCBs were used, and those who did were there on average only a couple of years," said James Cogliano, PhD, Chief of the Quantitative Risk Methods Group for the EPA. "Some classified as exposed had PCB blood levels in the low range of background levels in the general public. Others were classified as highly exposed if they worked with PCBs for only a short time. Those kinds of things can dilute results, and create enormous potential for uncertainty." 

Michael Thun, MD, Vice President of Epidemiology and Surveillance Research for the American Cancer Society, said, "The bad news is PCB exposures were not well characterized, the study was too small to detect small risks for uncommon cancers, and the results may not be relevant to PCB exposure through food. Also there was a borderline association with colorectal cancer in women. That needs a closer look."

Officials from the Agency for Toxic Substances and Disease Registry say the study does not support the company's claims that PCBs do not hurt people because it suffers from exposure misclassification (by including individuals who worked at the plants but had little to no exposure to PCBs), failure to account for the latency period between exposure and appearance of cancer, and other biases. PCB levels were actually measured in only 200 of the over 7,000 people in the study. "Nevertheless, the study did find excesses in three of the six cancers of interest," the ATSDR officials noted in a published letter criticizing the study. (Source: Clean-up GE) 

"It's noteworthy that the GE-funded study is the only one of the major occupational PCB exposure studies that did not find some statistically significant elevation of incidence of cancer," says Dr. David Carpenter of the Albany School of Public Health. "Every international group of experts that has been asked to look at the issue has concluded that they are proven to cause cancer in animals and are probable carcinogens in humans." Carpenter adds that there can be no absolute proof that PCBs (or any other chemical for that matter) cause cancer because there's no way to control for other exposures. "There's just no doubt that PCBs are carcinogenic in the minds of any independent scientist. It's only people with close ties to industries that have conflicts of interest that would make such preposterous claims. It's very akin to the smoking, cancer and tobacco industry story. To have a corporation like General Electric deny that animal research, including research done by their own laboratories proving PCBs cause cancer in rats, is relevant to whether PCBs cause cancer in humans is ludicrous. Our whole system of study of disease is based on animal research. Unfortunately the public has become confused because of the message that GE and other industries have put out." (Source: Clean-up GE)  For more information, see PCBs and Cancer Effects

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Political Use of Junk Science

GE is facing billions of dollars in clean-up costs at multiple PCB-contaminated Superfund sites around the country, such as the Hudson and Housatonic Rivers in the Northeast. They may also face numerous private lawsuits over PCB health damages in former workers and customers. GE has a vested interest in whether PCBs cause cancer. (See links to GE's actions on the Hudson and Housatonic Rivers.)

The GE cancer study had a purpose. "They want to cause public confusion, and make the argument appear to seem scientifically complicated, because they know that oftentimes the public will tune out as soon as it gets complicated," says Judith Enck, policy advisor to New York Attorney General Elliott Spitzer. (Source: Clean-up GE) 

The study is also used to wear down third party support for the cleanup. The claim that PCB's don't cause cancer was brought out in April when GE officials led by NBC president and GE vice chairman Robert Wright met privately with New York City Council members to lobby against a council bill endorsing the dredging project. GE's Albany lobbyist, James McMahon sat in on the meeting, along with his brother Thomas, the City Council's former finance director and a lobbyist with the Chamber of Commerce. (Source: Clean-up GE) 

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Links to More GE Information 

• For more discussion of the GE study, see Appleton Post Crescent article from 3/11/99, and an 9/25/00 article in the Poughkeepsie Journal in New York. 

• The Hudson Clearwater Sloop also chronicles inaccuracies in other GE claims. 

• A U.S. EPA response to a GE letter on the Housatonic River gives more examples of GE’s inaccurate claims. 

Journal Abstract of the GE Cancer Study

Renate D. Kimbrough, MD, Martha L. Doemland, PhD, Maurice E. LeVois, PhD. Mortality in Male and Female Capacitor Workers Exposed to Polychlorinated Biphenyls. JOEM 41:3 (March 1999), pp 161-171

"A mortality study was conducted in workers with at least 90 days' exposure to polychlorinated biphenyls (PCBs) between 1946 and 1977. Vital status was established for 98.7% of the 7075 workers studied. In hourly male workers, the mortality from all cancers was significantly below expected (standardized mortality ratio [SMR] = 81; 95% confidence interval [CI], = 68 to 97) and comparable to expected (SMR = 110; 95% CI, 93 to 129) in hourly female workers. No significant elevations in mortality for any site-specific cause were found in the hourly cohort. All-cancer mortality was significantly below expected in salaried males (SMR = 69; 95% CI, 52 to 90) and comparable to expected in salaried females (SMR = 75; 95% CI, 45 to 118). No significant elevations were seen in the most highly exposed workers, nor did SMRs increase with length of cumulative employment and latency. None of the previously reported specific excesses in cancer mortality were seen. This is the largest cohort of male and female workers exposed to PCBs. The lack of any significant elevations in the site-specific cancer mortality of the production workers adds important information about human health effects of PCBs."