An Open Letter to EPA Ombudsman Robert Martin

Editor’s note:  This letter, coauthored by Science Committee members, was published at the Science Committee’s web page but not in the local newspaper.  As this letter suggests, the Science Committee, early on, tried every avenue, bent every ear, tested every official it could find respecting EPA’s scientific missteps in that agency’s push for a greatly expanded Coeur d’Alene Basin Superfund site.

group sit.jpg

(PHOTO CREDIT:  Zona Desconocida)

To:  Robert Martin
U.S. Environmental
Protection Agency

From: Science Committee
of the Shoshone Natural
Resources Coalition

April 27, 2001
Shoshone County, Idaho  

Dear Mr. Martin,
On behalf of the people of Shoshone County, Idaho, the Science Committee of the Shoshone Natural Resources Coalition begs to draw your attention to the following facts:

The EPA’s Progress Report for Cleanup in the Coeur d’Alene River Basin has just been published.   This document claims that human health represents the top priority in the EPA’s plan for environmental remediation of our area.  Childhood lead exposure is the main focus of this would-be remediation.

Yet, there is no credible nor uncontroverted scientific evidence that child lead poisoning is a problem in our area.

Local physicians do not see childhood lead poisoning cases.

A modern and fully equipped hospital in neighboring Kootenai County has no special programs, wards, nor physician training for child lead poisoning — and they have no caseload for lead as such.     

The EPA’s imputation of a child lead problem in our area is the product of a mining-area environmental stereotype and a virtually self-contained computer simulation model, called the Integrated Environmental Uptake Biokinetic (or IEUBK) model.

The IEUBK offers a faulty and unreliable simulation approach to the estimation of the proportion of children above the agency’s 10 micrograms per deciliter blood lead standard.

The IEUBK model has been criticized in the scientific literature on both statisticaland empirical2 grounds regarding its ability to predict the frequency of children at the high end of the blood lead distribution.

Inputs to the model were not developed by means of rigorous environmental sampling and have been subject to what miners call “high grading” by the sampling methods actually employed — including their use of the -80 sieve.

The model is subject to gross variations in output predictions or estimates depending upon discretionary and a priori input parameters.

Key scientific concepts are misused and misunderstood in the EPA’s science for this

No part of the EPA’s science takes into consideration the negative health effects of the EPA’s actual and potential economic and social impacts on this area.4

The model’s alternative estimations for various communities in our area were validated (and thus putatively confirmed) against case-finding and catch-as-catch-can survey data that have no scientific standing for use as sources of population frequency estimates.5

Moreover, the catch-as-catch-can survey data employed in purported validations of IEUBK model’s estimations were not frequencies of unduplicated persons but instead frequencies per total observations — approximately 100 multiple observations among the 524 total observations were illegitimately employed in analyses and descriptive population projections.

A much more satisfactory and direct approach to estimating the frequency of high blood lead levels is available by means of a rigorously conducted survey of blood lead levels — yet the EPA has consistently eschewed this more direct approach in favor of its self-contained and essentially untestable IEUBK model.

Moreover, on April 12, 2001 the SNRC Science Committee engaged a panel of EPA scientists in a Science Summit in order to offer our critical observations on their approach to child blood lead estimation in our area and to hear their responses.  This event generated a number of telling and disconcerting comments from EPA scientists, including:

We were informed that the published triggering standard for human health action (namely, 5% or more of the children in a population at or above 10 micrograms of lead per deciliter of blood) was not in fact salient to the EPA’s decision making process in this area — despite that standard’s repeated assertion in the EPA’s draft Human Health Risk Assessment.

We were informed that the EPA’s remediation of blood lead risk was aimed at “future generations” of our area’s children, though no explanation has been offered as to how future generations of children may be more at risk than the present generation — about whom, we repeat, no credible evidence has been offered suggesting exceedance of the EPA’s stated “5%+ at 10µg/dL+” standard.

According to our reading of the just-released EPA Progress Report, our systematic critique of EPA science relating to (a) sampling and data collection, (b) bioavailability, and (c) population estimates has played no part in the ineluctable and single-minded development of the EPA’s action plan for our area.

Based on these and other facts, we request that you use your powers as EPA Ombudsman to:

Explore the controverted science claims our own investigation has brought to light

and explore with us the prospect of empanelling a neutral and authoritative scientific body (following the model used at Aspen’s Smuggler Mine area) that would make a binding scientific assessment of the state of childhood health in our area.

Thank you for your attention to this matter.

Respectfully submitted by the Science Committee of the Shoshone Natural Resources Coalition,

Robin Stanley, Chair
Fred Brackebusch
Bill Calhoun
Lee Haynes
Robert Hopper
Ivan Linscott
Ron Roizen


1 Carroll RJ, Galindo CD, “Measurement error, biases, and the validation of complex models for blood lead levels in children,” Environ Health Perspect 106 Suppl 6:1535-9, (Dec) 1998.

2 Biesiada M, Hubicki L, “Blood lead levels in children: epidemiology vs. simulations,” Eur J Epidemiol 15(5):485-91, (May) 1999.

3 See Fred Brackebusch’s presentation to the SNRC Science Summit.

4 See Bill Calhoun’s presentation to the SNRC Science Summit.

5 See Ron Roizen’s presentation to the SNRC Science Summit.



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