Owens Corning, a Guelph-based fibreglass manufacturer, has applied for a special exempt from the province that would allow it to emit hexavalent chromium at a higher level than what will be allowed under new provincial standards taking effect in July (Learn more here).
Inhaled hexavalent chromium is recognized as a human carcinogen with established links to lung cancer (source).
Wellington Water Watchers is concerned about the potential impact this issue will have on local streams, rivers and groundwater due to the fallout from these emissions. The following comments are suggested to us from concerned citizens. Please feel free to use a modified version of the comments for submission to the Environmental Bill of Rights.
The deadline to submit comments is Monday, February 1st, 2016.SUBMIT COMMENTS
Note: You do not have to be a Guelph resident to submit your comments.
*image source: Wikimedia Commons (2007) Photo of potassium chromate
I strongly object to the approval of Owens Corning (OC) Site Specific Standard for the following reasons:
Most health information available regarding hexavalent chromium Cr(VI) comes from occupational exposures and experimental animals. Consequently, information regarding exposure to pregnant women and children is extremely limited. Cr(VI) has been associated with adverse effects on development and reproduction and safe Cr(VI) concentrations of exposure for pregnant women and children has not been pinpointed. Furthermore, the synergistic effects of Cr(VI) along with other toxins Owens Corning emits, such as toluene, has not been studied. As a result of this lack of scientific research, we should not be involuntarily exposed to this slew of chemicals at these concentrations.
Based on the modelling the exposure to Cr(VI), concentrations are within 0.001mg/m3 (as a maximum) at City of Guelph Water Services. This is 10 times above the Ministry cancer risk benchmark. This estimated risk is only considered negligible by some regulatory bodies but not ALL regulatory bodies.
In order to protect the health of the public, the following should be considered:
Higher standards of compliance should be enforced as a result of the close proximity in which the OC is located to other non-industrial places of employment, as well as residential and recreational neighborhoods. Higher standards of compliance should include for example an automatic sampler installed on the OC’s stacks sampling randomly throughout the year to monitor whether or not the OC is meeting the standards.
It is my understanding that OC will require an executable spill contingency and prevention plan, reviewed and approved by the MOECC. However to protect the public there also needs to be a mitigation plan for air quality exceedances. In addition, it is imperative that there be a reliable warning system installed if there are any malfunctions in equipment resulting in increased Cr(VI) concentrations. Monitoring at a specific frequency will not address these concerns. Staff at City of Guelph Water Services must be informed immediately if OC exceeds their concentrations.
Finally, the allowable Cr(VI) concentrations that Water Services employees are exposed to should not exceed those that residential neighborhoods are exposed to. Water Services is a place of employment, and the exposure levels allowed must meet occupational health and safety standards. However, the employees of Water Services are not fibreglass employees and did not choose careers working in these conditions. Water Services staff should be considered under the residential concentration standards and not under the same occupational exposure concentrations as OC employees.
The World Health Organization, the Centre for Disease Control, the US Environmental Protection Agency, the Agency for Toxic Substance and Disease Registry in the US, the Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health, and countless other organizations have come to the same scientific conclusion — hexavalent chromium is carcinogenic and hazardous to human health.
There have been extensive and comprehensive studies all over the world that demonstrate that hexavalent chromium is carcinogenic and has serious, negative (and sometimes fatal) impact on people:
-Chronic inhalation exposure to chromium (VI) in humans results in effects on the respiratory tract, with perforations and ulcerations of the septum, bronchitis, decreased pulmonary function, pneumonia, asthma, and nasal itching and soreness reported.
-Chronic human exposure to high levels of chromium (VI) by inhalation or oral exposure may produce effects on the liver, kidney, gastrointestinal and immune systems, and possibly the blood.
-Dermal exposure to chromium (VI) may cause contact dermatitis, sensitivity, and ulceration of the skin.
To grant Owens Corning a site-specific standard for hexavalent chromium is reprehensible and has the potential to endanger the residents of Guelph for generations.
We, in no way, support Owens Corning receiving a site-specific standard for hexavalent chromium.