The US Environmental Protection Agency (EPA) recently published a document titled, “Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments”.  This document is being described as part of the agency’s dioxin reassessment.  EPA struggled for over twenty years to create a final document addressing dioxin exposure disease risk.  Now that such a document has been published, EPA is misinterpreting the document so as to please corporate interests.

In the above named document EPA sets forth a non-carcinogenic effects oral reference dose for dioxin.  The oral reference dose is 0.7 picograms dioxin TEQ/kg bw/day.  Per capita dioxin exposure at current levels of food supply contamination is estimated to be approximately 0.6 picograms dioxin TEQ /kg bw/day.  EPA takes the position that the food supply is safe.  This position can not be defended with logic.  Those who consume animal fats receive dioxin  exposure in excess of the oral reference dose.  Exposure in excess of the oral reference dose means that significant disease risk is imposed.  The food supply is not safe.  EPA is responsible for protecting the environment and the public health.  EPA is responsible for warning the American public concerning the presence of unsafe levels of dioxin in the animal fat portion of the food supply.  Failure to provide this warning results in avoidable harm to public health.  EPA’s behavior is unethical and should be corrected.

I have sought to discuss the unreasonableness of this position with the Acting Director of the Office of Research and Development, Lek Kadeli.  Mr. Kadeli has not responded.

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