Final Comments To ATSDR Concerning ORRHES

To: Ms. La Freta Dalton
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry

Cc: ORRHES and ATSDR Staff

Following the June, 2001 meeting of ORRHES I have several concerns specific to this meeting and of a more general nature.

The four most important general concerns with the activities of ORRHES over the last seven months are listed below.

1) The lack of meaningful communication with the community is a major shortcoming. There should be at least one hour of structured dialog with the public at each meeting at a convenient time. A moderator could facilitate this by interrupting people that were restating previous concerns, and for new issues directing question to ATSDR staff, ORRHES members, or taking other appropriate actions.

2) Failure to include DOE/ORO as a non-voting member of ORRHES is totally unacceptable to me. The statement that DOE has not responded to specific individuals truthfully (assuming this is true) should not exclude their participation in this evaluation of ORR. This indicates to me that ATSDR is more concerned with placating special interests than achieving their stated objective which requires a meaningful dialog with DOE---the major source of data and funding for the project. My own experience as a community member requesting information from DOE/ORO was totally satisfactory. I received information (that I was never able to obtain from the contractor) from ORO in less than a month. In a public forum where communications and trust are essential, failure to include DOE/ORO speaks for itself. Failure to include DOE/ORO in a civil dialog can never lead to a "meeting of the minds" on issues that are of great importance to the future of ORR and the surrounding communities.

3) A considerable amount of time was spent by several Subcommittee members drafting a recommendation concerning the need for and content of a ORRHES web site ( see www.csm.ornl.gov/~frome/orrhes/ for details) . For an organization that is suppose to be able to communicate effectively the lack of ability to develop and maintain a useful web site for ORRHES is beyond my comprehension. Thanks to Al Brooks a temporary web site has been provided, but this is far short of what is needed to meet the needs of the Subcommittee and community.

4) The time required for the many work group meetings and preparation for the Subcommittee meetings is also a major problem. If my time was being spent in positive and constructive ways I would not be so concerned (the web site being just one example of wasted time on something that should have been handled up-front by ATSDR)

I also have two specific concerns related to the June 11-12, 2001 meeting.

1) Much of the material presented by Dr Hoffman on Monday, June 11 was totally inappropriate for ORRHES at this time. The ATSDR Public Health Assessments as described at atsdr1.atsdr.cdc.gov/HAC/PHA/foreword.htm clearly describes the first step in the PHA process...

"Exposure: As the first step in the evaluation, ATSDR scientists review environmental data to see how much contamination is at a site, where it is, and how people might come into contact with it."

Dr Hoffman did not explain his methods for addressing the above issue for I-131, but focused on relative risk models and probability of causation to hypothetical individuals that may have been exposed to I-131. The material should have been presented at a PHA work group meeting and the problem of technical content and relevancy to the PHA process could have been resolved. I am sure that many Subcommittee members did not have the technical background to understand much of his presentation.

The presentation by Peipins and Berger on Tuesday morning was well done and understandable to the Subcommittee. At the very least this should have preceded the Monday afternoon session.

2) On Tuesday, June 12, a recommendation was brought before the Subcommittee concerning a one day "team building" meeting. About 15 minutes was spent discussing when the meeting might take place before a recommendation was made to have the meeting. After the recommendation was made to have the meeting I requested an opportunity to discuss the motion and this request was refused by the chair. I have spent many hours listening to other Subcommittee members discuss and repeat the same position, and find this failure to allow me to speak once on this issue before a vote was taken totally unacceptable. This topic was discussed in detail at a COWG meeting, but was never discussed by the entire Subcommittee in any detail. The concerns I raised at the COWG meeting were never addressed by ATSDR staff or discussed by ORRHES.

For these and related personal reasons I do not feel that I can ask my family and my employer to allow me the time that is required to be an effective member of ORRHES and, therefore, request that you accept my resignation.

I enjoyed meeting and working with many members of ORRHES and ATSDR staff and hope you will be successful in your efforts to deal with the public health concerns associated with the ORR.

Ed Frome

P.S. I will be glad to follow the activities that are described on the OFFICIAL ORRHES web site, and if there are items on the agenda for a work group meeting that involve statistics or epidemiology I will try to participate in these discussions. However, I strongly recommend that you obtain the independent advise of a statistician at ATSDR or CDC on the somewhat complex and controversial statistical issues that seem to be of concern to the Subcommittee. For an Online Introduction to Statistics click here- see Item 6

  • Last Modified July 23 2001
  • Person responsible for page ( E. L. Frome)
  • Back To My ORRHES Web Page

    F179940