By Dennis Mitchell
As an old aquatic toxicologist, I wanted to hear Dr. Willie Soon, independent scientist, as the keynote speaker at the 23rd Annual Florida/Alabama Technical Conference in Pensacola June 8th. As a long time attendee of this conference, I expected solid information and was not disappointed. The event is a cooperative effort of two chapters of the Air & Waste Management Association and, as usual, was attended by a mix of industry, academics, and senior regulatory folks from both states, and consulting professionals. This is a conference so popular that registration had to be closed off several days before the event. Although the subject matter of this conference is mostly of the applied nature and of wide scope, this year had some special attention to the mercury issues as they affect both federal criterion and with Florida, in particular, the onerous total maximum daily limit (TMDL) for mercury.
Mercury expertise is the reason that Dr. Soon was invited as the keynote speaker, as he has been on a relentless ten year quest to evaluate the data relating to mercury and its toxic organic forms.
Armed with a collection of documented data sources covering an exhaustive analytical review of the world’s published and unpublished data about environmental mercury, he painted a clear picture of the EPA’s foggy choices for reliance on questionable data to construct the new Utility MACT rules. The EPA position has created a quagmire of wobbly science that the FL-DEP is forced to work through, establishing the state’s TMDL’s. Further, the data used by EPA for consumption of methyl mercury in fish created doubt in many attendees’ mind that the truth has been stretched beyond believability for political purposes in the U.S.
The issue of methyl mercury as a neurotoxin has never been in doubt, but Dr. Soon made a strong point (interestingly enough, just as the FL-DEP did in their May 24th 2012 draft report) that the connection between total mercury in the water column has no correlation to the toxic methyl mercury converted by natural biological means and then accumulating in some fish. This is a point that EPA seems to casually skip over in their apparent rush to frighten people away from eating fish. Some in the audience suggested that the mercury panic is likely just a flank attack on coal use and CO2 is the real target. I, for one, could easily believe that point.
Dr. Soon discussed the (infamous) Faroe Island study, that seems to be the foundation of EPA’s curious position, and that study failed to pass even a whiff of sober content. This seemingly severely flawed study is limited primarily to consumers of pilot whale meat that was grossly contaminated with PCB’s-not exactly what your local grocery chain sells daily for the fish catch-of-the-day. It’s also not what your average angler brings home to cook, but EPA seems able to avoid those realities in their policy decisions.
This irrelevant study of contaminated whale meat seems to be the primary basis for EPA demanding virtually unachievable low levels of mercury that potentially could be converted to methyl mercury in fish consumption. Dr. Soon seems to imply that the earth has a lot to say about this process, but EPA declares they know more than Mother Nature. In fact, common foods such a barbeque sauce and soft drinks consistently have many times the total mercury than the irrationally low environmental limits the EPA demands.
In glaring contrast, the CDC sets safe limits on mercury far above the EPA targets. Dr. Soon’s rhetorical question was “What does EPA know suddenly that the CDC has not learned after many years of study and analysis including the NHANES program?”
It seems that suspect science and poor policy tend to go hand in hand with over reaching regulatory power. I’m sure the Florida DEP has plenty of horsepower to work on this issue without heavy handed federal threats. They could do a more scientific and productive job if left to their own devices.
The EPA doesn’t even allow the Florida legislature to pass environmental laws. To preserve some scientific sanity, the FDEP continues to valiantly fight (a mostly losing battle) to keep the Numeric Nutrient science at the fore.
The reality is that in the U.S., industrial sources are not the major contributor of environmental mercury. It seems the ocean evades more mercury, by far, than any other source. Also, recent re-evaluations of volcanic contribution of mercury are several times higher than assumed by the earlier works EPA stubbornly clings to, in spite of the evidence available.
States like Florida are particularly subject to high mercury from ocean evasion both from general proximity, but also a salt transport process that enhances the near shore deposition. Perhaps this too - escaped the EPA?
A lot of facts tend to escape the EPA. To their credit, the FDEP tries to make some of these points; points arrogantly ignored by EPA.
Even with the most stringent constraints on waste mercury, the amount of methyl mercury that will end up in edible fish will not likely change because of the constantly available amounts from natural mercury sequestration. Remember, the amount of mercury in the water column has NO CORRELATION to the methyl mercury found in fish.
Dr. Soon elaborated on the overwhelming data that mercury, as a dynamic presence in the environment, has not changed in millions of years. Conversion to methyl mercury, especially in the presence of selenium, has been a factor in evolutionary survival for eons. It may not be intuitive, but having either much higher or much lower levels of total mercury in the environment would not likely change the levels of methyl mercury in fish because the biology is in charge. The DNA that deals with mercury is clever and persistent. And if it weren’t effective for any given species, extinction would have occurred long, long ago.
Furthermore, the levels of methyl mercury have never posed a real health issue to U.S.; not even to pregnant women. The real and present danger lays in the mythology about mercury in fish. This mythology has been pounded into the public’s perception thereby contributing to people not eating enough fish and missing the marvelous benefits of this food source.
The overwhelming conclusion of a 17 year Rochester University Seychelle Island study of a population that eats fish (not contaminated whale meat) regularly defied the myth. Methyl mercury in human tissue cannot be correlated to any deleterious conditions in that population as had been sighted in government studies. Yet, EPA persists with the illusion.
Although there are well documented cases of direct ( and illegal dumping)pollution of methyl mercury toxicity, and also OSHA type accidents, the most telling point of the day was the lack of any documentation for methyl mercury from fish consumption correlating to consumption of methyl mercury from natural conversion functions. EPA’s Lisa Jackson has claimed as many as 17,000 lives will be saved in the US from the new restrictions on mercury. Yet a room of 120+ scientists, engineers, and regulators could not point to a single scientific source for any documented history of death by environmentally created methyl mercury!
How does an agency claim to save lives of people who aren’t dying from methyl mercury in the first place? As Dr. Soon pointed out, it’s incompetence at best and political motivation at worst. The modeling assumptions by EPA create press releases and regulations based on mythology.
In a somber tone, Dr. Soon asked the right question… “How many people will be or already have been harmed by the EPA’s panic message to blindly avoid consuming reasonable amounts of cheap and nutritious food such as fish?” I wonder why EPA is more interested in saving the avatars of their theoretical models than living breathing human beings. According to this learned, principled, talented scientist, EPA’s hypothetical female for their modeling would be someone who ate nearly a pound of fish per day for 70 straight years. Beam me up, Scotty…please!
Dennis Mitchell is certified as a Qualified Environmental Professional (QEP) by the Institute of Professional Environmental Practice (IPEP) and is presently the chair of Ethics Committee for IPEP. He was a recipient of the Lifetime Honorary Award from the International Air & Waste Management Association in 2001. He was chair of the Climate Change Panel at the 104th International a&WMA Conference. He has been a member of Louisiana Society of CPA’s since 1985 and retired from Troy University where he taught both in both science and accounting.