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Letter from US Congress written by Dennis Kucinich on Jan 15 2010, to Lisa P Jackson, US EPA, regarding mercury as a source of pollution through dental amalgam fillings. In this letter Kucinich tells the EPA that based on testimony from experts given to the Domestic Policy Subcommittee:
- âEPA has underestimated amount of mercury pollution that dental amalgams accounts for, thereby rendering the problem a lower priority than it would otherwise be.â
- Estimated mercury emissions data came from one test at a single crematory 10 years ago, based on that data the estimate was 0.3 tons.
- Based on 2.9 grams mercury per cremated person (average based on number of amalgam fillings) a better estimate is 3.3 tons, eleven times the level accounted for by EPA.
- EPA is required by Clean Air Act to monitor emissions of mercury.
- Congress requests EPA reevaluate and update mercury emissions from crematories, a devise a plan and timeline to address the problem in a timely fashion.
2. EPA-response- to-CONGRESS-Kucinich
Letter from Arvin Ganesan, response from US EPA to US Congress.
a. EPA recognizes that pollution from all sources of mercury is a serious concern to human health and the environment.
b. Mercury is well-documented as a toxic, environmentally persistent substance that demonstrates the ability for bioaccumulation and atmospheric transportation on a local, regional, and global scale.
c. There is evidence that âŚ âserious health impacts from low-level exposure to mercuryâ
e. No state regulations on sale or distribution of dental amalgam. Knowledge of mercury in fillings may drive future declines in use; however the expense of non-mercury fillings can affect patientsâ preference for amalgam.
f. EPA acknowledges that mercury from amalgam is a source of controllable pollution; that mercury is released into the environment through cremation of bodies containing dental amalgam.
g. Worksheet from EPA in 2005 estimated that US emissions from crematoria to be 3,000 kilograms (6,613 lbs)
h. No federal or state regulations restrict mercury emissions from crematoria.
i. EPA intends to update mercury emissions, but âdoes not intend to regulate human crematoria at this time.â
j. EPA has concluded that human crematories were not solid waste incinerators; therefore it was not appropriate to regulate them under Clean Air Act Section 129.
k. If in the future EPA concludes that crematoria should be regulated other Clean Air Act Authorities could be used.
3. mercury concentrations [spike] in emissions
Mercury in Crematoria Using Flourescence Spectrometry â September 2010 study,: Corns, Dexter and Stockwell, P S Analytical, UK
a. Mercury emissions from crematoria are almost entirely due to the presence of amalgam fillings in the cadaver.
b. Leads to âsignificant variation in the concentration of mercury emitted during each cremation.â
c. Testing was performed over the course of 4 separate cremations.
d. Mercury emissions in study had variance (ug/m-3 = micrograms per cubic meter) cremation #1 had 25.8 ug/m-3, #2 had 47.5 ug/m-3, #3 had 282.0 ug/m-3 and #4 had 1094.5 ug m-3 (THIS IS IMPORTANT, COMPARE TO ACTION SHEETS BELOW. These levels exceed the exposure levels by alarmingly high concentrations.)
e. Mercury is released in a spike about 40 minutes into the cremation, during the heating up process, as mercury reaches the temperature threshold at which it vaporizes.
f. Mercury released during a short period of time. (not gradually over time)
ATSDR (Agency for Toxic Substances and Disease Registry) Suggested Action Levels for Indoor Mercury Vapors in Homes, and FACT SHEET
a. Primary route for entry is inhalation.
b. When heated, mercury becomes a colorless, odorless gas.
c. Methylmercury and Mercury vapors are more harmful than others, because mercury in these forms reaches the brain.
d. Can cause permanently damage the brain, kidneys and nervous systems.
e. Sensitive populations are those with developing nervous systems, including young children (under six) and the developing fetuses of pregnant women.
f. Action level is indoor air concentration which should prompt consideration of the need to implement a personal response by public health and environmental officials.
g. Indoor Air Concentration must be less than 1.0 ug/m3 for residential occupancy after a spill. (NIOSH)
h. OSHA has set limits of 0.1 mg/c3 organic mercury (milligrams per cubic meter) and 0.05 mg/c3 mercury vapors for 8 hr shifts and 40 hr work weeks.
i. 10 ug/m3 requires residents be isolated from exposure (ATSDR)
j. Pregnant women should consult physicians about mercury exposure
WIKI Page for Mercury Poisoning
OSHA Guidelines for Mercury Vapor
1. Effects on Humans:
â˘ Mercury vapor can cause effects in the:
â˘ central and peripheral nervous systems,
â˘ lungs, kidneys, skin and eyes in humans.
â˘ It is also mutagenic and affects the immune system
â˘ [Hathaway et al. 1991; Clayton and Clayton 1981; Rom 1992].
â˘ Acute exposure to high concentrations of mercury vapor causes severe respiratory damage,
â˘ chronic exposure to lower levels is primarily associated with:
â˘ central nervous system damage
â˘ [Hathaway et al. 1991].
â˘ Chronic exposure to mercury is also associated with behavioral changes and alterations in peripheral nervous system [ACGIH 1991]. Pulmonary effects of mercury vapor inhalation include diffuse interstitial pneumonitis with profuse fibrinous exudation [Gosselin 1984]. Glomerular dysfunction and proteinuria have been observed mercury exposed workers [ACGIH 1991]. Chronic mercury exposure can cause discoloration of the cornea and lens, eyelid tremor and, rarely, disturbances of vision and extraocular muscles [Grant 1986]. Delayed hypersensitivity reactions have been reported in individuals exposed to mercury vapor [Clayton and Clayton 1981]. Mercury vapor is reported to be mutagenic in humans, causing aneuploidy in lymphocytes of exposed workers [Hathaway et al. 1991].
* Signs and symptoms of exposure â˘ Acute exposure: chills, nausea, general malaise, tightness in the chest, chest pains, dyspnea, cough, stomatitis, gingivitis, salivation, and diarrhea [ACGIH 1991; Hathaway et al. 1991].
â˘ Chronic exposure: Chronic exposure to mercury may result in weakness, fatigue, anorexia, weight loss, and disturbance of gastrointestinal function. A tremor may develop beginning with the fingers, eyelids, and lips which may progress to generalized trembling of the entire body and violent chronic spasms of the extremities. Parallel with development of the tremors, behavioral and personality changes may develop including increased excitability, memory loss, insomnia, and depression. The skin may exhibit abnormal blushing, dermographia, excessive sweating and irregular macular rashes. Severe salivation and gingivitis is also characteristic of chronic toxicity [Hathaway et al. 1991; Gosselin 1984].
â˘ Another manifestation of chronic mercury exposure is characterized by apathy, anorexia, flush, fever, a nephrotic syndrome with albuminuria and generalized edema, diaphoresis, photophobia, insomnia and a pruritic and sometimes painful scaling or peeling of the skin of the hands and feet with bullous lesions [Gosselin 1984].
John Reindl, Mercury Emissions from Crematoria (Reindl testified before the Domestic Policy Subcommittee referred to in the letter from Kucinich. The document referred to here is from his work in 2005. This is the data he shared during the portion of his testimony that dealt specifically on crematory emissions.
â˘ Main source of mercury in crematory emissions from dental amalgams
â˘ Cremation is third largest source of air emissions from (amalgam) products, 2436 kg a year in 2005
â˘ Fate of emissions global
â˘ Emissions mainly metallic vapor
â˘ Control methodologies
â˘ Removal of teeth before cremation , Stack controls: Co-flow filters, solid-bed filters, traditional gas scrubbing, honeycomb catalytic absorbers
â˘ Barriers to control methodologies:
â˘ Lack of recognition of need to control â˘ For removing of teeth: cultural values for handling of corpse
â˘ Costs and physical challenges of stack controls
â˘ Industry tradition â only one crematorium in US has stack controls
â˘ Information needs: more data on amount of mercury per cremation, more expertise among researchers, regulators
7. Scientific Explanation for the Tri-State Incident
McCracken Poston, A scientific explanation for the events at Tri-State Crematory
a. Theory of an external, environmental cause claimed not only the literal sanity and judgment of Ray-Brent Marsch, but also the health and ultimately the life itself of his father, Tommy Ray Marsch.
b. Suspect element is mercury
c. Ray-Brent Marsch cremated the first two-thirds of the bodies sent to him, the crematory was in somewhat of a functioning order, and there was obvious heavy particulate matter on the interior of the small crematory building due to inadequate ventilation and a breached stovepipe from the retort to the exterior.
d. Ray-Brent complained to his wife of headaches and seemingly minor body aches, and suffered from chronic insomnia. (symptoms of mercury toxicity)
e. Hair sample was taken two years after crematory discoveries and exposure to suspected mercury vapors had ended.
i. Hair sampled showed classic signature of mercury poisoning
ii. Alarmingly high levels of heavy metals
iii. Mineral transport impairment
iv. Dr Boyd Haley, University of Kentucky Scientist has signed affidavit supporting Postonâs theory.
f. Failure was on the part of the governmental regulatory process in US and in the State of Georgia.
g. Little or no guidelines exist regarding proper ventilation or placement of crematories.
h. Case is over, no appeals for Marsch, paper written as an explanation for the loved ones & the curious.
More about Mercury Here:
Ban Mercury Working group Mercury Exposure: The Worldâs Toxic Time Bomb
a. Human health is compromised by significantly smaller concentrations than ever imagined.
b. WHO concluded that âa safe level of mercury exposure âŚ has never been established.â
c. Less than 1/50th of a teaspoon mercury per 20-acre lake surface is enough to make fish in it unsafe for human consumption.
d. Methylmercury crosses blood-brain barrier
e. Mercury persists in the environment and can be tracked indoors on clothes and shoes, re-exposing residents in enclosed buildings continually.
9. Texas Study Mercury-Autism Link
University of Texas âEnvironmental mercury release, special education rates, and autism disorder: and ecological study of Texasâ
a. Concluded that for every 1000 lbs of environmentally released mercury, there was a 43% increase in the rate of special ed services, 61% increase in the rate of autism. (mercury has long been suspected as the main culprit in the dramatic rise in autism rates)
10. toxic_emission_from _crematories[env.intl]
Environment International âToxic Emissions from Crematories: A reviewâ
a. Crematories have been identified as sources of various environmental pollutants, being polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/Fs), and mercury those raising most concern.
b. The pollutants emitted by the combustion of organic matter with presence of other trace elements are: combustion gases (NOx, CO, SO2, PMâŚ.), heavy metals, and polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/Fs), among other persistent organic pollutants. Heavy metals and PCDD/Fs, stand ut because of their toxicity and capacity for bioaccumulation, which means potential risks for human health. Because of their toxicological properties, together with their persistence capacity, PCDD/Fs were listed by the Stockholm Convention on Persistent Organic Pollutants of 2001 as one of the âdirty dozenâ pollutants whose levels should be significantly reduced.
c. As a result of the US Cremation Associationâs meeting with the US EPA in November 1991, it became known that the original regulations proposed for crematories were based on no actual test data. Dental amalgams are unstable at cremation temperatures (650â700 Â°C), âŚ the free mercury metal is highly volatile.
d. Concluded that threw was an increased risk of lethal congenital anomaly (specifically spina bifida and heart defects) in relation to proximity to incinerators, and an increased risk of stillbirth and anencephalus in relation to proximity to crematoriums.
11. Characterizing the Emissions from Crematoria
Environmental Science Technology âCharacterizing the Emissions of Polychlorinated Dibenzo-p-dioxins and Dibenzofurans from Crematories and Their Impacts to the Surrounding Environmentâ
a. Two crematories in Taiwan were tested, one with no emissions controls, the other with a bag filter.
b. The one with a bag filter removed 55.1% of the dioxins/furans, but both crematories still emitted significant amount of both compounds.
c. Determined that crematories with a low stack and no pollution controls are more of a threat to the community, but even after filtration, dioxin and furan levels are still at concentration levels well above âsafeâ levels
d. US EPA has reported that there appears to be no âsafeâ level for dioxin exposure, and the levels of dioxin and dioxin-like chemicals found in the general U.S. population were âat or near levels associated with adverse health effects:
e. Stacks on tested crematories were 5 m (16.4â) and 6 m (19.7â)
PENN State/University of Wyoming Study: âThe impact of crematory operations on adjacent residential valuesâ
a. Study of residential house sales in Rawlins, Wyoming, was conducted to estimate the impact of an environmental shock from a new point source upon adjacent residential property values.
b. Data spans 27 months of house sales: 7 months before, and 20 months after the startup of crematory operations. Data based on actual home sales.
c. Studied both direction and wind patterns, determined downwind to be an important factor in study as it applies to atmospheric pollutants.
d. Rawlins City Planner issued a building permit to the subject mortuary to install a 40 ton, two-chamber, natural gas-fired Millennium II crematory in a vehicle storage garage adjacent to the mortuary building.
e. Controversy remains as to whether this Planner was authorized to issue a permit for this expanded, nonconforming use of an existing funeral home facility in an area zoned for residences.
f. Citizens began complaining to City and State authorities about the crematory with its glaring, all-night illumination, noise and â most notable â noxious odor, which permeated residentsâ houses, making them feel ill and âdevaluingâ (Morton, 2005) their properties.
g. Wyoming Department of Environmental Quality ordered an emissions test and determined that the crematory had emissions comparable to its state permit request with several notable exceptions: annual ambient cadmium and dioxin/furan concentrations at the crematory property boundary exceeded National (and Wyoming) Air Quality Standards, by approximately 205% and 2200%, respectively (URS, 2006). Hydrogen chloride concentrations at this boundary exceeded the one-hour US Environmental Protection Agencyâs âremediation goalâ by 797%, with sulfur oxide, nitrogen oxide, chromium, and mercury concentrations being from 43 to 74% of the Agencyâs National Standard or remediation goal. Cadmium, chromium, dioxin/furans, hydrogen chloride and mercury are toxins for which any positive concentration may have human health impacts. (Wexler, 2005).
What harm could one little crematory cause??
The industryâs data is mainly a mix of marketing materials and a few select tests on new crematories as they were being installed.