Jon Sumby
The mistake in this part of the Gunns IIS may lead readers to a wrong conclusion about the ability of dioxin to accumulate through the food chain. Gunns want to assure the community that, ‘Seals do not readily assimilate dioxins from their food and do not biomagnify dioxins’, and that the seals living on Tenth Island face no threat from the pulp mill waste disposal, but do these mistakes really give credible support to their claim? This is a ‘draft IIS’ and the mistake about ‘marine bird’ versus ‘marine mammal’ is only the first I have found in one part of one section of 7500 pages. How many other errors or omissions are in this IIS? These errors damage the integrity and credibility of the pulp mill IIS. I suggest that the RPDC, in it’s infinite wisdom, send the draft IIS back to Gunns and tell them to do it again and to do it right, without these misleading errors.
THE Gunns IIS, Section 4.3.4, ‘Potential for bioaccumulation of dioxins by seals’, starts out by saying:
‘Direct evidence for lack of biomagnification of dioxins through trophic levels of a food web has recently been provided by Wan et al. (2005). In an investigation of a food web in Bohai Bay (15)…’ (V10_A23, p.24)
Then in the footnote it is written: (15) Bohai Bay is an enclosed inner sea in north China…The study analysed 9 dioxins, 11 furans and 12 PCBs in samples of phytoplankton/seston, zooplankton, 3 invertebrate species, 6 fish species and one marine mammal.
However, if you read the paper by Wan et al., they actually write:
‘The present study analyzed nine PCDDs [dioxins], eleven PCDF [furan] isomers… in samples of phytoplankton/seston, zooplankton, three invertebrate species, six fish species, and one marine bird’
…Oops.
Birds are not mammals. They descend from the reptiles, so the bird in the study (a herring gull) is more closely related to a crocodile than a seal. This section of the IIS is about supporting the claim that: ‘Seals do not readily assimilate dioxins from their food and do not biomagnify dioxins.’ By the error of writing ‘marine mammal’ instead of ‘marine bird’, the casual reader may make the mistake of assuming that the paper by Wan et al. is talking about a seal. Different animals have different abilities to remove dioxins from their bodies; vertebrate animals don’t excrete some of the most toxic dioxins. There is a world of difference between a bird and a seal. There is a lot of research that shows that seals accumulate dioxins; from the harp seal to the Weddell seal, but the Gunns IIS is talking about research involving a seagull and seems to apply it to the Tenth Island seals.
The other problem I have about this section is the Gunns IIS seems to ignore the first sentence in the paper by Wan et al.: ‘Many investigations have highlighted the bioaccumulation of dioxins in animals, but little is known about the trophodynamics of dioxins in the food web.’
The paper by Wan et al. examines how dioxins move through the different levels of the food chain, which is a very complex area. The Gunns IIS says, ‘Direct evidence for lack of biomagnification of dioxins through trophic levels of a food web has recently been provided by Wan et al.’. This is a bit of a blanket statement, if you read the paper by Wan et al., it shows that of the 9 dioxins and 11 furans they track, only few of these 20 chemicals examined showed a reduction in concentration in the food chain, what is called ‘trophic dilution’. Overall, the total concentrations of dioxins increased, as Wan et al., note: ‘ …the total PCDD/F [dioxin and furan] concentrations ranged from 7.6 (wolfish (Obontamblyopus rubicundus)) to 36 pg/g wet weight (herring gull (Larus argentatus)).’ [The Wan et. al. paper is available at: www.environ.pku.edu.cn/personal/professor/geography/hujianying/hjy/environment/download/Wan%20DXN%20Foodweb.pdf]
The mistake in this part of the Gunns IIS may lead readers to a wrong conclusion about the ability of dioxin to accumulate through the food chain. Gunns want to assure the community that, ‘Seals do not readily assimilate dioxins from their food and do not biomagnify dioxins’, and that the seals living on Tenth Island face no threat from the pulp mill waste disposal, but do these mistakes really give credible support to their claim? This is a ‘draft IIS’ and the mistake about ‘marine bird’ versus ‘marine mammal’ is only the first I have found in one part of one section of 7500 pages. How many other errors or omissions are in this IIS? These errors damage the integrity and credibility of the pulp mill IIS. I suggest that the RPDC, in it’s infinite wisdom, send the draft IIS back to Gunns and tell them to do it again and to do it right, without these misleading errors.
If you believe there are no other errors or omissions in the Gunns IIS, pigs (and seals) might fly.
