UPHE response to UDOH’s updated Stericycle report

Oct. 14, 2015

Utah Physicians for a Healthy Environment appreciates the interest that the Utah Department of Health (UDOH) has taken in Stericycle’s impact on public health. We reviewed their study and conclusions and offer a critique of both.


We know the devastating consequences of human exposure to potent industrial toxins like heavy metals–mercury, lead, cadmium and radioactive isotopes–dioxins and furans, and polycyclic aromatic hydrocarbons. Every year for more than 25 years, the Stericycle incinerator has been releasing from a relatively short stack, tons of these compounds, some of the most toxic compounds known to man, right into the heart of the most heavily populated part of the state. Many of these compounds do not degrade, but steadily accumulate in ever increasing amounts into the local environment and beyond, steadily increasing human exposure. For UDOH to issue a report that basically says no harm to the community has been done defies logic as well as science. The scientific evidence that incinerators like Stericycle cause serious harm is as undeniable as the evidence that smoking causes cancer.

UDOH has assessed the health risks of Stericycle using only a narrow lens of badly outdated toxicology risk assessment (TRA) techniques and a “statistical review.” TRA methodology is historically entrenched, almost always results in favorable review for polluting industries, and UDOH staff available to address these issues are in fact toxicologists, not physicians. TRA is a method developed for engineering evaluations of pollution sources, but it is very inadequate and often inaccurate in assessing the biological complexities of human health. TRAs have almost always concluded that incinerators are safe while strong epidemiological data shows the opposite. We liken this approach to attempting to judge how critically injured a trauma patient is by focusing on a chest x-ray, and ignoring their bleeding sites, blood pressure, heart rate, breathing, and state of consciousness.

The medical community has increasingly parted ways with toxicologists regarding the health consequences of environmental and chemical toxins. For 400 years the foundation of toxicology has been the concept of “the dose makes the poison,” which is a presumption that health effects are related to dose, and that a dose can be found for virtually all chemicals where no effect is found. As reassuring as that thought may be, it no longer holds up to scientific scrutiny.

Medical scientists are now pointing out three important contradictions to this pillar of toxicology. The greatest public health threat of chemicals lies in fetal exposure where dose is less important than the timing, i.e. does the exposure occur during a critical window of embryonic development? A dose of a toxic chemical required to create a certain disease maybe 100,000 times smaller if the exposure occurs during fetal development as opposed to during puberty. The second contradiction is the idea that the smaller the dose, the less effect. Medicine is now discovering that for some toxic chemicals that relationship is not linear, and the clinical effect can actually increase as the chemical concentration decreases.

Third, it is now well established that for many toxins, there is no safe level of exposure, extremely low concentrations can have proven and profound health consequences. There are thousands of medical studies that show toxic chemicals can cause epigenetic changes, that alter gene expression and proteins inside cells, tissues and organs even at minute concentrations. If these epigenetic changes occur in the germline, multiple generations can be impacted by a single exposure. This latter point is important because it suggests that the consequence of EDC exposures can go beyond an individual or a generation. Not all the victims of Stericycle’s emissions have been born yet.  Even if there is no further exposure and despite efforts to clean the environment, the consequences will continue for many decades.

UDOH’s analysis ignores the massive amount of recent and relevant medical research available. Because of that their study cannot be considered a medical assessment.

Critique of the “Statistical Review”

UDOH did a statistical review or “cancer cluster study” (despite their unwillingness to use that term) of the population near Stericycle compared to the rest of Utah’s population. Relying only on a statistical analysis is doomed to failure in small cluster studies like this. Either the number of people included has to be very large, or the environmental exposure has to be really deadly. Epidemiologists sum up cluster studies this way: “If we detect a problem, you know you have a true catastrophe.” Indeed UDOH’s own report states, “Cluster investigations rarely result in important discoveries of causality.” Of 428 cancer cluster studies done nationally in the last 22 years, only 13% yielded statistical confirmation that a cluster existed, and only one revealed a definite cause (1).

Does that mean toxic exposures don’t cause cancer, or other serious diseases? No, but it does illustrate the limitation of evaluating cancer clusters only through a wide statistical lens. It’s like a surgeon trying to remove cancer cells using binoculars rather than a microscope. This should have been more widely acknowledged by UDOH in its messaging to the public so that the study is not given authority or an interpretation that is not warranted.

With these inherent problems in the study, the fact that UDOH still found a higher incidence of lung, colon, anal, bone and joint cancer, cutaneous melanoma, breast, and prostate cancer among Stericycle’s neighbors compared to the rest of the state, especially for the later study periods, is significant. This follows the pattern that would be expected if the incinerator was a contributing factor, because most solid cancers take decades to develop after a triggering exposure. Any statistical bump in cancer that might be due to the incinerator would not be expected to reach its peak for another ten to twenty years, even after Stericycle is gone.

UDOH makes this statement, “However, it is unlikely that elevated cancer rates in the study area can be attributed to environmental contaminants, as these cancer types are most often associated with behavioral and genetic factors and are frequently preventable. Residents are encouraged to make healthy life choices, such as smoking cessation, maintaining a healthy diet and weight, avoiding excessive sun exposure, and getting enough physical exercise.” Why would UDOH infer the residents near Stericycle engage in higher risk personal behavior than other residents of the state when in fact UDOH’s own study found the exact opposite? For UDOH to take this nonsensical direction makes it seem like it is bending over backwards to exonerate environmental factors.

Furthermore, there was no indication from the report that the statistical review controlled for this lower incidence of risky behavior, which would be expected to lower the cancer rates. If so, that increases further the significance of the higher rates of cancer in the study population.

In fact, the most common cancers found, breast and prostate cancers, have been shown to be connected to environmental contaminants. Hormone sensitive cancers like breast and prostate cancers are on the rise nationally. A report published two weeks ago on endocrine disrupting chemicals (EDC) by the Endocrine Society, the international society of endocrinologists, stated that it is more necessary than ever to minimize further exposures. The report makes this statement, “Among the EDC’s with the strongest association to impaired mammary development..and susceptibility to tumors, are dioxins.” Early life exposure leads to delayed pubertal breast tissue development in female rodents and in girls. Dioxins have also demonstrated effects on later life lactation and breast and ovarian cancer risk.

Dioxins are some of the best characterized endocrine disruptors of the male reproductive system. The developing prostate has been shown to be sensitive to minute doses of estrogens, which suggests that altered morphogenesis may predispose the prostate to cancer. Furthermore, there is early research evidence showing a connection between air pollution and both breast and prostate cancer (2,3,4,5).

There is even early evidence of an environmental connection to colon cancer because numerous studies show a strong relationship between inflammatory bowel disease and air pollution, which increases a person’s chance of colon cancer about 600% (6,7,8,9).

Itemized critique of TRAs in general and this one in particular.

1. TRAs using dispersion modeling are not accurate in predicting ground level concentrations of pollutants. For example, modeling almost never takes into account secondary particulates or dioxins formed as the products of combustion rise up the stack. The majority of dioxins released from incinerators are not formed in the furnace, but rather in exhaust gases, as they cool after leaving the furnace (10). As far we can tell, this was not taken into account in UDOH’s modeling.

2. UDOH’s rosy conclusions contradict the only actual measurements of dioxins in people’s homes, i.e. the attics of nearby residents, which showed levels of dioxins as high as 17 times what would be considered the upper limit of acceptability in an industrial area, with concentrations inversely proportional to the distance from Stericycle.

3. Typically TRAs involve estimating the risk to health of only a small fraction of the hundreds of different pollutants emitted by incinerators. UDOH’s study only addressed nine of them, and primarily only dioxins. The illogical assumption is made that if emitted substances are not assessed, which is the overwhelming number of toxic pollutants, then they have zero risk. One study found that the amounts of unknown, but likely dangerous, organohalogen compounds formed by waste incineration are higher by orders of magnitude than the amount of dioxins.

4. TRAs assume that all pollutants have thresholds below which they are safe. Doctors who specialize in hormone and endocrine diseases have officially contradicted this claim (this will be addressed in more detail later in this report). The science is very clear this is not the case. Many pollutants, including dioxins, many heavy metals and radioactive particulates–exactly what comes out of Stericycle’s smoke stack– do not have “safe” thresholds and some may even be more dangerous at lower concentrations. Many studies published in the peer-reviewed literature document that EDCs can act in the nanomolar to micromolar range, and some show activity at picomolar levels (11).  It is worth emphasizing that a whistle blower employee testified that Stericycle incinerated radioactive material, in gross violation of their permit, and this TRA did not address this issue in anyway.

5. This particular TRA assumed that only air emissions and nearby soil concentrations need to be considered. Air emissions may be only the tip of the iceberg. Bioaccumulation in food was not part of the analysis. Most food today is contaminated with dioxins, but predominantly from past incinerator emissions. 93% of human dioxin exposure comes from meat and dairy products despite the fact that 96% of dioxins originated as air emissions. Soil samples and air concentration modeling are poor surrogates of human exposure and not very revealing about what health risks are present.

It has been estimated that 20 to 60% of 2,3,7,8-TCDD in the air is in the vapor phase.  The lower chlorinated and some of the most toxic dioxins may vaporize from soil or water surfaces and be transported long distances in the atmosphere, even around the globe (12). Focusing on local soil concentrations simply does not represent the extent of Stericycle’s spread of dioxins. Given that, the best UDOH’s evaluation could say is that dioxins are proven toxins, but they are unable to assess the health consequences of dioxins attributable to Stericycle.

Through biological processes many toxic substances accumulate in organisms, concentrate in certain tissues of those organisms, and increase in concentration as they move up the food chain. Humans are at the top of the food chain and because our capacity to break down dioxins is very limited, concentrations in our bodies usually increase over time. Lipophilic toxins like dioxins will concentrate especially in human breast milk. Nursing infants consume 10 to 20 times as much dioxin as the average adult. Six months of breast feeding will transfer 20% of a mother’s lifetime accumulation of chemicals like dioxins to the nursing child. Soil sampling will reveal nothing about dioxin and other organochlorine chemical concentrations in breast milk. If Stericycle’s emissions are not safe for nursing infants then the facility is not safe. So a fair question to raise is why did UDOH make no effort to examine breast milk in nearby residents?

6. Exposure to dioxins from an incinerator are not just limited to inhalation or from surrounding soil. The volume of dioxin and heavy metals released in ash can be much greater than stack emissions. One study found that only 1.7% of an incinerator’s dioxin releases went up the stack, with the vast majority released in ash and slag, which can re-enter the Wasatch Front ecosystem putting everyone at risk (13). Stack pollution controls only increase dioxins in this part of waste stream. The ash will be sent to a landfill, but all landfills eventually leak (according to the EPA), and are otherwise buffeted by wind, rain, ice, snow and erosion, slowly releasing the toxins back into the environment affecting populations far beyond North Salt Lake.

7. Build up in the environment faster than biodegradation can occur and is not factored in. In the case of most heavy metals–they are not combustible, do not degrade and cannot be destroyed. Dioxins only degrade over several decades. Concentrations of these toxins in the local environment will steadily increase over time.

8. TRAs focus on diseases like cancer, but almost completely ignore other health outcomes related to dioxins and other industrial toxins, like neurotoxicity, abnormal sexual development, birth defects, reproductive disorders for males and females, altered sex ratios of newborns, immunosuppression, behavioral disorders, diabetes, obesity, thyroid, cardiovascular and fatty liver diseases.  Toxins in Stericycle’s waste stream have been definitively shown to negatively impact genetic and epigenetic integrity, sperm counts and viability, which can influence the health of subsequent generations. In fact just one high dose of pre-natal dioxin exposure in animals has been shown to reduce female fertility and increase the rate of preterm births for three subsequent generations. Animals exposed a second time showed the same problem lasting for four generations (14).

TRAs do not and cannot assess this consequence because the manifestations may not appear for decades into the future. However, just because a risk cannot be quantified doesn’t mean that it is doesn’t exist and shouldn’t be factored into public policy.

9. Typical TRAs assume that the hazard posed by each individual compound tested out of context and in isolation can predict the hazard of the entire complex mixtures of chemicals, ignoring the cumulative risk and the likelihood of synergistic impacts.  To UDOH’s credit, this TRA did make an attempt, albeit a meager one, to evaluate multiple toxins, in this case, nine of them. This apparently is based on an EPA assumption from 1989. All lot has changed since then. Hundreds of other halogenated organic compounds are released by incinerators that have been studied less thoroughly than dioxins. For example PCBs and hexachlorobenzene (HCB) fall into the category of Persistent Organic Pollutants (POPs) and endocrine disruptors. Many of these compounds are thought to have dioxin-like toxicity.

Studies specific to PCBs and HCB show a wide variety of adverse health outcomes with increased exposure, including markedly increased rates of childhood obesity, shorter stature, impaired fetal growth, decreased birth wt. and size and markedly higher rates of obesity in adults, and abnormal sex chromosomes (15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25). Intrauterine exposure to HCB and PCBs significantly increases the likelihood of developing asthma in childhood and adolescence, most likely by impairing normal development of the immune system (26).

It would be extremely naive and a gross oversimplification, leading to a significant underestimation of toxicity, to believe that there are only nine toxins of concern in Stericycle’s stack emissions and waste stream.

Moreover, UDOH simply added up the hazard quotient for individual toxins to calculate a cumulative hazard quotient. Complex biologic processes are seldom explained by simple arithmetic. Some of those toxins can behave synergistically, making the adverse end result much greater than just adding up their hazard quotients.

10. Making judgements about health risk based on modeled annual average atmospheric concentrations of individual pollutants, including HAPs, ignores short term spikes that carry health consequences independent of annual averages, especially in the case of fetal exposures as per mentioned in point #8. Furthermore, making judgements based on annual averages ignores the burden of year to year accumulation of many persistent organic pollutants, like dioxins, and heavy metals.

11. North Salt Lake and South Davis County residents are also additionally exposed to the emissions of the refineries and traffic from the freeway corridors. This TRA is unable to make any conclusions regarding the health threats of this rather unique, complex exposure circumstance for the residents of Foxboro, which common sense suggests makes them more at risk than almost any other large neighborhood on the Wasatch Front.

12. Declaring that Stericycle has had no significant health impact on nearby residents by virtue of this TRA assumes that we have a comprehensive understanding of the complexity of biological processes and chemical toxicity when in reality there are vast information gaps. Lack of knowledge cannot be equated with safety, it can only be equated with lack of knowledge. That is all the more appropriate when there is ample research that contradicts the conclusions drawn from this TRA.

13. UDOH’s study stated that “Prior to 2003, chronic exposure would have been unlikely as the land was largely undeveloped.” That assumes that before 2003, no one was exposed to Stericycle, and yet we know full well that Stericycle’s emissions reach many miles up and down the Wasatch Front. Any study limited to impacts in the immediate area of the incinerator will not address the far reach of Stericycle’s emissions. Dioxins and other toxic pollutants can travel far distances away from the source. For example, dioxins in the breast milk of Inuit Native Americans in Northern Canada have been traced to incinerators in the US hundreds of miles away (27, 28).

14. Finally, TRAs like this one ignore the extra vulnerability of the15-20% of the adult population that is uniquely and probably genetically much more sensitive to chemical insults.

The TRA and Statistical Review Contradict the Medical Research

As alluded to above, UDOH’s conclusions contradict the bulk of medical research on the toxicity of incinerator emissions. Hundreds of worldwide studies have confirmed that living near an incinerator, or having your body “contaminated” with “incinerator” toxins originating miles away, statistically increases your chance of many types of serious diseases, including, but not limited to cancer. A comprehensive review of the literature up to 2008 is available here:

One such example illustrates the contradiction. A study from Italy published two years ago evaluated populations surrounding eight municipal incinerators (medical waste incinerator emissions are even more toxic), a much larger sample size than UDOH’s study. The researchers demonstrated a 30% increase in pre-term births among pregnant women most exposed to incinerator emissions (29). The authors concluded, “Maternal exposure to incinerator emissions, even at very low levels, was associated with preterm delivery.”

Stericycle’s past operative permit allowed it to emit a combined 9.51 tons every year of the most toxic substances known to man. That is as much as a full sized oil refinery or coal fired power plant. No one would dare suggest that an oil refinery’s emissions are not a health hazard. But because those emissions are released from a much shorter stack than an oil refinery, the impact on local health is greater. Moreover, we know that Stericycle has been citied for exceeding their permit limits, and that these figures do not represent uncounted bypass emissions, which for substances like dioxins may have been greater than the “authorized” emissions.

The most useful part of UDOH’s study could have been the look at adverse pregnancy outcomes and neonatal mortality in North Salt Lake, Woods Crosss, and West Bountiful. But because the control group was the rest of the state of Utah, with over 80% of Utahns living along the Wasatch Front and being exposed to much of the same environmental threats as Stericycle’s neighbors, it is very possible that meaningful differences would not be found.

UDOH’s report on lead in Stericycle’s emission acknowledges that there is no safe level of exposure to lead. Mercury is an even more intense neurotoxin, perhaps as much as 1,000 times more neurotoxic. Yet in describing Stericycle’s health risks, the report makes no reference to Stericycle having been permitted to release 60 lbs of mercury and 130 lbs of lead into the atmosphere of surrounding neighborhoods every year.

Over 20 years that’s 1200 lbs. of mercury and 2,600 lbs of lead, all from a relatively short smoke stack, which is less likely to disperse emissions. Because both of these toxic heavy metals are never destroyed, those emissions steadily accumulate in every conceivable way into the immediate environment exposing fetuses and children to an ever increasing amount of neurotoxins, despite everyone acknowledging that no amount of exposure is safe. Through modeling of Stericycle’s lead emissions, UDOH has declared that virtually none of the children living near Stericyce should have elevated blood levels of lead.

Furthermore, recent studies have shown that even blood lead levels not historically thought to be elevated are associated with impaired cognition. In fact, the corollary to the acknowledgement that there is no safe level of lead exposure, is the fact that every bit of lead exposure will cause impairment of cognitive abilities. Recent research has established this correlation: for every 0.19 ug/dl of lead actually measured in an adolescent’s blood, there was a loss of one IQ point. In this study the average lead level was 1.71 ug/dl (30). This means that the average person tested lost more than 8 IQ points due to lead exposure at levels far less than are historically considered toxic.

The “modeled” blood level lead from UDOH’s report yielded a value of 1.03 ug/dL, which is significantly lower than the actual measured average found in the afore mentioned study of “unexposed” adolescents. The reference or presumed “acceptable” level currently being used by the CDC and referred to in this report, 5.0 ug/dL, would be associated with an astonishing IQ loss of over 25 points. How is that acceptable? The accuracy of UDOH’s modeled values are certainly called into question, but even if they were accurate, they would still be associated with an IQ loss of 5 points. How would even that be considered acceptable? And how would that yield UDOH’s statement that, “it is unlikely that outdoor environmental lead exposures in the incinerator area will not  result in adverse health effects in children?” What could have been meaningful, but what was not done, would have been actual measurements of lead in the blood of Foxboro children and mothers, compared to national levels.

Utah has higher levels of autism than any other state in the union, other than New Jersey. With one in every 32 Utah boys being diagnosed with autism, the autism epidemic should be considered a public health emergency. The causes of autism are likely multiple, but seem to be a combination of genetic predisposition and various environmental exposures. One of the most well established of those environmental exposures is heavy metals. Studies of children living near sources of heavy metal pollution show higher rates of autism and special needs requirements (31, 32). While Stericycle isn’t the only source of heavy metal exposure in North Salt Lake, it is a completely unnecessary one.

That being the case, it would seem like UDOH should be weighing in on every possible source of heavy metals near Utah’s population base, and tracking heavy metal exposure of its pregnancy mothers by actual measurement, not calculated, modeled values. In this context, UDOH’s dismissal of any health consequence to Stericycle’s heavy metal emissions seems particularly myopic, if not negligent.

Dioxins can trigger health effects at extremely low concentrations. Indeed, there is no known level below which dioxins are known to be harmless, though everyone has some dioxin their body.  As mentioned above, dioxins have been linked to cancer, neurotoxicity, abnormal sexual development, birth defects, reproductive disorders for males and females, altered sex ratios of newborns, immunosuppression, behavioral disorders, diabetes, obesity, thyroid, cardiovascular and fatty liver diseases. Dioxin exposures are typically measured in picograms (one picogram is one trillionth of a gram) per day. At this level of concentration, even detection is difficult. Even short term exposure to these endocrine disruptors at the wrong time of development can have a lifelong effect. Because the changes occur at the molecular level, they are not evident until later in life.

The primary standard by which UDOH has judged the toxic potential of Stericycle’s emissions to the nearby residents is an RSL (regional screening level), offered by the EPA . The report acknowledges that RSLs do not indicate a health effect level or even a cleanup standard. They only offer a comparison to other sites and communities. And later in the same paragraph the report does exactly what the report acknowledged can’t be done, in making a statement that values of RSL below a certain level present a cancer risk so small that further investigation is not considered meaningful. UDOH’s report states “This emission standard and modeled exposure eliminates the need for cancer risk assessment for inhalation of dioxins past 2014.” This statement is at odds with the known chronological course of the development of most solid cancers, which usually only become manifest decades after they are triggered.

UDOH’s report goes on to state that the RSLs for dioxins were developed from inhalation reference concentrations established by the California EPA in the year 2000. That in turn was established on the basis of a 1978 study of long-term dietary exposure to dioxins in rats. The report then goes on to acknowledge essentially the weakness and limitations of the 1978 study in extrapolation to human health risks, and then admits this very limited data base is the basis upon which the UDOH report draws its conclusions. In other words, UDOH’s conclusions are derived from a single study in rats from almost 40 yrs ago, and that study assumed a linear relationship between dose of exposure and affect which we now know is no longer valid.

UDOH’s Section on Adverse Birth Outcomes (ABO)

UPHE disagrees with UDOH’s downplaying of environmental risk factors for adverse birth outcomes. UDOH categorizes as “medical risk factors” diabetes, gestational diabetes, pregnancy induced hypertension, eclampsia, and toxemia, while ignoring the research that shows environmental influences on these same pregnancy risks. Regarding environmental risk factors UDOH states, “hazardous pollution, indicate[s] increase risk, although there is some disagreement” and an “inability of studies to demonstrate conclusive findings,” and, “The low amount of ABO risk that can be attributed to air pollution exposure, compared to intrinsic, extrinsic, and medical risk factors suggests that these environmental risk factors are not likely to be very important to the overall community health with respect to ABO rates.” UDOH cites 45 references in support of these statements, but with only two published since 2011. UDOH appears to have cherry picked the research, failed to include the most current studies, and ignored the expanding microbiologic and histologic research showing placental and fetal damage from air pollution.

On UPHE’s website are 184 references, many of them published since 2011, showing an impact of air pollution on pregnancy outcomes and complications, placental blood flow and architecture, chromosomal integrity, and fetal development (33). Typical of this body of research are studies that show higher air pollution exposure associated with 30-80% increase in pregnancy complications. See the section below for international medical organizations that are equally concerned about environmental risks to pregnancy.

UDOH concludes that three study periods showing either higher rates of low birth weight syndrome (LBW) or premature births were most likely the result of random variation. We see no basis for UDOH to draw that conclusion rather than simply acknowledging the higher rates in the study population, as would be consistent with the bulk of medical research.

Multiple Medical and Environmental Organizations Warn
of Incinerator Hazards and Low Dose Toxin Exposure

“The emissions from incinerator processes are extremely toxic. Some of the emissions are carcinogenic. We know, scientifically, that there is no safe threshold below which we can allow such emissions. We must use every reasonable instrument to eliminate altogether.”
— U.K. Environment Minister Michael Meacher to a House of Lords Inquiry, 1999

“POPs (persistent organic pollutants) have been linked to numerous adverse effects in humans and animals. Those include cancer, central nervous system damage, reproductive disorders and immune system disruptions. They are, in fact, lethal.”
— EPA Administrator Christie Whitman, 2001

The extraordinary vulnerability of the first three months of embryonic development makes Stericycle’s emissions a public health urgency. This type of risk was specifically addressed by a recent joint public statement by the American College of Obstetricians and Gynecologists and the American Society for Reproductive Medicine. The position statement included this:

“Reducing exposure to toxic environmental agents is a critical area of intervention for obstetricians, gynecologists, and other reproductive health care professionals. Patient exposure to toxic environmental chemicals and other stressors is ubiquitous, and preconception and prenatal exposure to toxic environmental agents can have a profound and lasting effect on reproductive health across the life course. Prenatal exposure to certain chemicals has been documented to increase the risk of cancer in childhood…[we] join leading scientists and other clinical practitioners in calling for timely action to identify and reduce exposure to toxic environmental agents while addressing the consequences of such exposure” (34).

A 2009 statement, strengthened and updated in 2015, by the Endocrine Society, the largest organization of internal medicine physicians that specialize in endocrine and hormonal diseases, made this statement regarding endocrine disruptors that include toxic compounds like dioxins and other components of Stericycle’s emissions and their potential harm to fetal development:

“Even infinitesimally low levels of exposure indeed, any level of exposure at all, may cause endocrine or reproductive abnormalities, particularly if exposure occurs during a critical developmental window. Surprisingly, low doses may even exert more potent effects than higher doses” (35).

A recent report and press release from the International Federation of Gynecology and Obstetrics (FIGO), including doctors from 125 countries, and from the American College of Obstetricians and Gynecologists, American Society for Reproductive Medicine, International Federation of Gynecology and Obstetrics, Royal College of Obstetricians and Gynaecologists, Society of Obstetricians and Gynaecologists of Canada, had this to say:

“We are drowning our world in untested and unsafe chemicals and the price we are paying in terms of our reproductive health is of serious concern….Miscarriage and still birth, impaired fetal growth, congenital malformations, impaired or reduced neurodevelopment and cognitive function, and an increase in cancer, attention problems, ADHD behaviors, and, hyperactivity are among the list of poor health outcomes linked to chemicals such as pesticides, air pollutants, plastics, solvents, and more.”

A recent review by 12 of the most knowledgeable researchers on endocrine disruption
concluded that, “Whether low doses of EDCs influence certain human disorders is no longer conjecture, because epidemiological studies show that environmental exposures to EDCs are associated with human diseases and disabilities,” and that, “For every chemical that we looked at that we could find a low-dose cutoff, if it had been studied at low doses it had an effect at low doses” (36).

Finally, a report published in the most prestigious medical journal in the world, The New England Journal of Medicine, regarding the toxicity of volatilized compounds from oil made this statement illustrating the risk from small exposure to toxic agents.

“Mutagenic effects theoretically can result from a single molecular DNA alteration. Regulatory prudence has led to the use of “one-hit models” for mutagenic end points, particularly cancer, in which every molecule of a carcinogen is presumed to pose a risk.” And, “Pregnant women should particularly avoid dermal contact with oil and should avoid areas with visible oil contamination or odors” (37). This illustrates the exquisite sensitivity that the developing fetus has to toxic agents at extremely small doses.

The mainstream medical community recognizes that indeed, the integrity of intrauterine development is at risk from exposure to the toxic components of Stericycle’s emissions.


Incinerators, especially medical waste incinerators, have been shown by ample medical research to represent significant health hazards to both the communities where they are located and to the public at large. UDOH’s study does nothing to change or contradict that prevailing science. Traditional toxicology risk assessments are losing credibility to a massive body of medical research that shows toxins, even in small amounts, are having a profound impact on public health. We encourage UDOH to base its future analyses of the health hazards of pollution sources on a predominance of medical science rather than traditional toxicology.



1. Goodman, M. et al. Cancer clusters in the USA: What do the last twenty years of state and federal investigations tell us? Crit Rev Toxicol. 2012 Jul; 42(6): 474–490.
Published online 2012 Apr 21. doi: 10.3109/10408444.2012.675315
PMCID: PMC3408895

2. Parent ME, Goldberg MS, Crouse DL, Ross NA, Chen H, Valois MF, Liautaud A. Traffic- related air pollution and prostate cancer risk: a case-control study in Montreal, Canada. Occup Environ Med. 2013 Mar 26. [Epub ahead of print]

3. Crouse DL, Goldberg MS, Ross NA, Chen H, Labrèche F 2010. Postmenopausal Breast Cancer Is Associated with Exposure to Traffic-Related Air Pollution in Montreal, Canada: A Case–Control Study. Environ Health Perspect 118:1578-1583. doi:10.1289/ehp.1002221

4. Parent ME, Goldberg MS, Crouse DL, Ross NA, Chen H, Valois MF, Liautaud A. Traffic- related air pollution and prostate cancer risk: a case-control study in Montreal, Canada. Occup Environ Med. 2013 Mar 26. [Epub ahead of print]

5. Hu H, Dailey AB, Kan H, Xu X. The effect of atmospheric particulate matter on survival of breast cancer among US females. Breast Cancer Res Treat. 2013 Apr 17. [Epub ahead of print]

6. Beamish LA, Osornio-Vargas AR, Wine E. Air pollution: An environmental factor contributing to intestinal disease. J Crohns Colitis. 2011 Aug;5(4):279-86. doi: 10.1016/j.crohns. 2011.02.017. Epub 2011 Mar 23.

7. Kaplan GG, Hubbard J, Korzenik J, Sands BE, Panaccione R, Ghosh S, Wheeler AJ, Villeneuve PJ. The inflammatory bowel diseases and ambient air pollution: a novel association. Am J Gastroenterol. 2010 Nov;105(11):2412-9. doi: 10.1038/ajg.2010.252. Epub 2010 Jun 29.

8. Ananthakrishnan AN, McGinley EL, Binion DG, Saeian K. Ambient air pollution correlates with hospitalizations for inflammatory bowel disease: an ecologic analysis. Inflamm Bowel Dis. 2011 May;17(5):1138-45. doi: 10.1002/ibd.21455. Epub 2010 Aug 30.

9. Kish L, Hotte N, Kaplan GG, Vincent R, Tso R, et al. (2013) Environmental Particulate Matter Induces Murine Intestinal Inflammatory Responses and Alters the Gut Microbiome. PLoS ONE 8(4): e62220. doi:10.1371/journal.pone.0062220

10. Taylor and Lenoir, 2001; Lemieux, et al., 2001; Blumenstock, et al., 2000; USEPA, 2000c; U.S. Department of Energy 2000; USEPA, 1999a; Fangmark, et al., 1994; and Altwicker, et al., 1992.

11. Vandenberg L, et al. Hormones and Endocrine-Disrupting Chemicals: Low-Dose Effects and Nonmonotonic Dose Responses. Endocr Rev. 2012 Jun; 33(3): 378–455. Published online 2012 Mar 14. doi: 10.1210/er.2011-1050 PMCID: PMC3365860

12. http://www.atsdr.cdc.gov/toxprofiles/tp104-c1-b.pdf

13. Giugliano, M., Cernuschi, S., Grosso, M., Miglio, R., Aloigi, E., “PCDD/F Mass Balance in the Flue Gas Cleaning Units of a MSW Incineration Plant,” Chemosphere, vol. 46, pp. 1321-1328, 2002.

14. Bruner-Tran, KL and KG Osteen. 2010. Developmental exposure to TCDD reduces fertility and negatively affects pregnancy outcomes across multiple generations. Reproductive Toxicology http://dx.doi.org/10.1016/j.reprotox.2010.10.003

15. 3. Govarts E, Nieuwenhuijsen M, Schoeters G, Ballester F, Bloemen K, de Boer M, et al. 2011. Prenatal Exposure to Polychlorinated Biphenyls (PCB) and Dichlorodiphenyldichloroethylene (DDE) and Birth Weight: A Meta-analysis within 12 European Birth Cohorts. Environ Health Perspect :-. http://dx.doi.org/10.1289/ehp.1103767

16. Maria-Jose Lopez-Espinosa M, Murcia, M, Iñiguez C, et al. Prenatal Exposure to Organochlorine Compounds and Birth Size. Pediatrics, online. (doi: 10.1542/peds.2010-1951)

17. Valvi D, Mendez MA, Martinez D, Grimalt JO, Torrent M, Sunyer J, et al. 2011. Prenatal Concentrations of PCBs, DDE, DDT and Overweight in Children: A Prospective Birth Cohort Study. Environ Health Perspect :-. http://dx.doi.org/10.1289/ehp.1103862

18. Airaksinen R, Rantakokko P, Eriksson J, et al Association Between Type 2 Diabetes and Exposure to Persistent Organic Pollutants. Diabetes Care, Published online before print August 4, 2011, doi: 10.2337/dc10-2303

19. Burns J, Williams P, Sergeyev O, et al. Serum Dioxins and Polychlorinated Biphenyls Are Associated With Growth Among Russian Boys. Pediatrics 2011; 127: e59-e68.

20. Goncharov, A, M Pavuk, HR Foushee and DO Carpenter. 2010. Blood pressure in relation to concentrations of pcb congeners and chlorinated pesticides. Environmental Health Perspectives http://dx.doi.org/10.1289/ehp.1002830.

21. Burns JS, Williams PL, Sergeyev O, Korrick SA, Lee MM, Revich B, et al. 2011. Serum Concentrations of Organochlorine Pesticides and Growth among Russian Boys. Environ Health Perspect :-. http://dx.doi.org/10.1289/ehp.1103743

22. Rauch SA, Braun JM, Barr DB, Calafat AM, Khoury J, Montesano MA, et al. 2012. Associations of Prenatal Exposure to Organophosphate Pesticide Metabolites with Gestational Age and Birthweight. Environ Health Perspect :-. http://dx.doi.org/10.1289/ehp.1104615

23. Valvi, D, MA Mendez, D Martinez, JO Grimalt, M Torrent, J Sunyer and M Vrijheid. 2011. Prenatal concentrations of PCBs, DDE, DDT and overweight in children: A prospective birth cohort study.  Environmental Health Perspectives http://dx.doi.org/10.1289/ehp.1103862.

24. Roos V, Rönn M, Salihovic S, Lind L, Bavel BV, Kullberg J, Johansson L, Ahlström H, Lind PM.Circulating Levels of Persistent Organic Pollutants in Relation to Visceral and Subcutaneous Adipose Tissue by Abdominal MRI. Obesity (Silver Spring). 2012 May 4. doi: 10.1038/oby.2012.123. [Epub ahead of print]

25. Wu H, Bertrand KA, Choi AL, Hu FB, Laden F, Grandjean P, Sun Q. Persistent Organic Pollutants and Type 2 Diabetes: A Prospective Analysis in the Nurses’ Health Study and Meta-analysis. Environ Health Perspect (): .doi:10.1289/ehp.1205248

26. 14. Hansen S, M Strøm, SF Olsen, E Maslova, P Rantakokko, H Kiviranta, D Rytter, BH Bech, LV Hansen, and TI Halldorsson. 2013. Maternal concentrations of persistent organochlorine pollutants and the risk of asthma in offspring: Results from a prospective cohort with 20 years of follow-up. Environmental Health Perspectives. http://dx.doi.org/10.1289/ehp.1206397.

27. Final report to the North American Commission for Environmental Cooperation (Flushing, NY. Centre for the Biology Natural Systems, Queens College, CUNY, 2000).

28. Raloff FJ. Even Nunavut get plenty of dioxin. Science News 2000;158:230

29. Candela S, Ranzi A, Bonvicini L, Baldacchini F, Marzaroli P, Evangelista A, Luberto F, Carretta E, Angelini P, Sterrantino AF, Broccoli S, Cordioli M, Ancona C, Forastiere F. Air pollution from incinerators and reproductive outcomes: a multisite study. Epidemiology. 2013 Nov;24(6):863-70. doi: 10.1097/EDE.0b013e3182a712f1.

30. Lucchini, RG, S Zoni, S Guazzetti, E Bontempi, S Micheletti, K Broberg, G Parrinello and DR Smith. 2012. Inverse association of intellectual function with very low blood lead but not with manganese exposure in Italian adolescents.

31. Andrea L. Roberts, Kristen Lyall, Jaime E. Hart, Francine Laden, Allan C. Just, Jennifer F. Bobb, Karestan C. Koenen, Alberto Ascherio, and Marc G. Weisskopf. Perinatal Air Pollutant Exposures and Autism Spectrum Disorder in the Children of Nurses’ Health Study II Participants. Environmental Health Perspectives, 2013 DOI: 10.1289/ehp.1206187

32. Palmer, R.F., et al., Proximity to point sources of environmental mercury release as a predictor of autism prevalence. Health & Place (2008), doi:10.1016/j.healthplace.2008.02.001.

33. http://uphe.org/air-pollution-health/birth-outcomes/

34. http://www.acog.org/Resources_And_Publications/Committee_Opinions/ Committee_on_Health_Care_for_Underserved_Women/ Exposure_to_T oxic_Environmental_Agents

35. https://www.endocrine.org/endocrine-press/scientific-statements

36. Vandenberg L, et al. Hormones and Endocrine-Disrupting Chemicals: Low-Dose Effects and Nonmonotonic Dose Responses. Endocr Rev. 2012 Jun; 33(3): 378–455. Published online 2012 Mar 14. doi: 10.1210/er.2011-1050 PMCID: PMC3365860

37. Goldstein B, Osofsky H, Lichtveld M. The Gulf Oil Spill N Engl J Med 2011; 364:1334-1348April 7, 2011

Comments are closed