Why Tasmania needs a Science Reform Commission 4

The questions surrounding the Rosebery science – why Tasmania needs a Science Reform Commission.

Dr Roger Drew from Toxicos Pty Ltd is an advisor for the Rosebery Technical Advisory Group (TAG). The TAG advises the Rosebery Community Reference Group. But, who is paying for Dr Drew’s services?

In a recent Media Release Dr Chrissie Pickin said “Although there is evidence of elevated levels of metals, notably lead, in some samples this is not being translated into a health risk for residents.”

Clearly questions about science should not be something that should only be left to the courts to decide. Community concerns about corporate/government funded science are legitimate. Not all scientific controversies have the benefit of a firm like Slater and Gordon backing independent research as some Rosebery residents currently have. In a relatively small country like Australia, scientists frequently have to be drawn on from overseas as expert witnesses in legal disputes.

Established scientific organisations in Australia are far too imbedded in the corporate sector as are some individual scientists. One only needs to look at how far behind the NHMRC is compared to the US, the EU and the WHO when it comes to banning and regulation of chemicals that are known carcinogens and endocrine disruptors.

Toxicos, for instance, consulted for Gunns Limited and provided several reports including a Human Health Risk Assessment.

Dr Andrew Wadsley produced a Review of the Gunns Draft Integrated Impact Statement which outlined some serious errors in the IIS:

A Review of the Calculation of the Concentration of Dioxin Sorbed to Bed Sediment in Gunns’ Draft Integrated Impact Statement

Dr Andrew W. Wadsley
Australian Risk Audit
[email protected]
May 2007

Abstract

A review was undertaken of the calculation of dioxin sorbed to bed sediment in Gunns’s draft Integrated Impact Statement. This review found that calculation errors, failure to include background dioxin concentrations, and failure to use the permitted maximum limit of dioxin in the pulp mill effluent, results in an under-estimation of dioxin concentrations by a factor of 1,390 in the Human Health Risk Assessment and by a factor of 90 in the Marine Impact Assessment.

2 Introduction

The major part of the assessment of risk to marine fauna and human health relating to pollutants in the effluent outfall of Gunns Limited (Gunns) proposed pulp mill [2] is based upon work carried out by Toxicos Pty Ltd (Toxicos). A key component of this assessment is the calculation of the concentration of dioxin sorbed to bed sediment in the vicinity of the outfall (located 3 km offshore near Five Mill Bluff, northern Tasmania).

The relevant reports issued by Toxicos are:
• Human Health Risk Assessment, July 2006 [3];
• Potential Impact on Nearby Seal Colonies, July 2006 [4];
• Erratum, 15th September 2006 [5];
• Marine Impact Assessment, January 2007 [6];
• Expert witness statement of Dr Roger Drew, January 2007 [7].

An erratum to the July 2006 reports was issued by Toxicos in September 2006. This Erratum corrected an error in dioxin concentration in the effluent which had been assumed to be 0.074 pg TEQ/L; this was changed to 3.376 pg TEQ/L based on a calculation by Jaakko Poyry [8]. Because of this change, none of the calculated impacts of dioxin as presented in the July 2006 reports by Toxicos should be used. The revised impacts are presented in the Erratum. It must be noted that the minimalist presentation of the figures in the Erratum makes it very difficult to relate the revised impacts to the original reports.

8 Conclusion

This review found that calculation errors, use of inappropriate parameter values, failure to include background dioxin concentrations, and failure to use the permitted maximum limit of dioxin in the pulp mill effluent, results in an underestimation of dioxin concentrations by a factor of 1,390 in the Human Health Risk Assessment and by a factor of 90 in the Marine Impact Assessment. The impacts of these errors are far reaching and invalidate all of the quantitative ecotoxicological analyses prepared for assessment under the Tasmanian Pulp Mill Assessment Act 2007 and for assessment of the pulp mill project under the Australian Environment Protection and Biodiversity Conservation Act 1999.

In an article by Charles Waterhouse from The Sunday Tasmanian on 24 September 2006 were excerpts from a leaked DPIPWE draft review of Toxicos’ assessment on impacts on marine life from the proposed Gunns Pulp Mill.

The draft states:

‘Toxicos fails to conclude or describe the risk to seals of bioaccumulating dioxins from exposure to pulp mill effluent. Evidence exists that the effect of exposure is significant, “therefore the Toxicos implication is misleading and their conclusion false”. Toxicos states that dioxins are not significantly bioaccumulated by fish. This statement is profoundly inaccurate, misleading and directly contradictory to references cited by Toxicos and Toxicos statements. The method used to determine the risk of bioaccumulation in fish is inappropriate. The assessment using effluent concentration by Toxicos is invalid and misleading and all conclusions based on this information are unsubstantiated. Toxicos demonstrates a complete lack of understanding of the meaning of biomagnification.’

There will be no independent science conducted in Tasmania unless a Science Reform Commission is established. This Commission needs to be established as a matter of urgency if public and environmental health in Tasmania is to be protected and the precautionary principle adequately adhered to.