May 30, 2018 Part 3 (Go here for Part 1 and Part 2)

Protecting the environment is a game of numbers.

The state’s new Cleaner Air Oregon program will soon decide such things as how much toxic air pollution each industry should be allowed to emit. It will also decide how much toxic pollution people can inhale harming their health.

Unfortunately, Cleaner Air Oregon is about to dial-in a number that protects industry more than people. This number has been skewed to provide more protection for white people than African-Americans.

Photographs by SARAH CLARK

This map shows the three locations of DEQ air monitoring stations, plus the location of a ridge above the AmeriTies creosote plant where a residential neighborhood is located. The plant site is marked with a yellow line.

THE DALLES, ORE. -- About 15 years ago, a creosote plant in Columbus, Miss., closed down after residents filed lawsuit after lawsuit against the plant’s operator, Kerr-McGee Chemical Corp., claiming their health had been damaged by its toxic air pollution. Eventually, Kerr-McGee and its successor companies paid $62.5 million to settle those claims.

Similarly, residents of The Dalles have been complaining about health problems they say are linked to air pollution from a creosote plant in their town. The plant, operated by a company called AmeriTies West, treats raw logs with the potent pesticide creosote to make railroad ties. AmeriTies denies that its plant emits enough pollution to harm anyone.

This month, a federal health agency known as the Agency for Toxic Substances and Disease Registry (ATSDR), was asked by local health authorities to assess the situation, released a report that supported the company’s denials. It did not find that the plant’s foul odors are dangerous.

“Most substances in the outdoor air that cause odors are not at levels that can harm health,” ATSDR said in a Health Consultation Letter released at a public meeting on May 8 at Columbia Gorge Community College. It prepared the report in partnership with the Oregon Health Authority.

ATSDR acknowledged that exposure to naphthalene, the primary air pollutant in The Dalles, poses a small cancer risk, a finding that is not in dispute. But many residents say their own personal health histories make them incredulous about another ATSDR finding: Exposure to naphthalene “did not pose chronic non‐cancer public health risks.”

ATSDR said those conclusions were based on air pollution data collected in The Dalles by the Oregon Department of Environmental Quality (DEQ) showing that air pollution in the city of 15,000 people does not exceed a “minimal risk level” that ATSDR considers safe. ATSDR established this level in 1995.

DEQ collected the data during July, August and September of 2016, which are among the windiest months of the year in The Dalles, according to the National Weather Service. A person who works in The Dalles said the odors often smell stronger “on windless summer days as well as windless inversion days in the winter.” This person works for an employer who has not authorized workers to speak to the news media and asked to remain anonymous

In addition, the medical professional said, the smell seems to be strongest in a residential neighborhood located on a bluff above the creosote plant, but DEQ placed no monitoring stations anywhere near that location.

“I see a lot of children in our community with asthma,” the medical professional continued. “Asthma is a respiratory disorder that is exacerbated by exposure to ‘triggers.’ On days when one can smell the odor, it can act as a trigger. I don't have enough data to make further correlation between health risks and naphthalene. In order to do this, we would need to sample levels in these children. Some studies have done this by testing the urinary concentrations of naphthalene metabolites in exposed subjects. Others have tested the water, dust and soil.  I cannot make any correlation or assign causality or even assess the true health impact for people in The Dalles without this data and neither could the ATSDR.”

Kristina Conkright, a member of The Dalles Air Coalition, discusses laboratory test results and the health impacts of creosote on her family. After living in The Dalles, Ore. for three years, Conkright moved her family out of town to escape breathing naphthalene and other toxics associated with pollution emitted by a creosote plant. 

ASTDR says elevated levels of naphthalene in the air can cause cancer as well as a wide array of non-cancer conditions including asthma, neurological problems, and skin rashes. But it said that naphthalene levels were not high enough to cause those health effects in The Dalles.

People can identify the presence of naphthalene in air pollution if they smell mothballs. Naphthalene, the active ingredient in mothballs, is one of dozens of chemicals known as polycyclic aromatic hydrocarbons (PAHs) that are mixed in with the creosote fumes.

“The total exposure is the real danger and the naphthalene is an index chemical,” said Dr. James Dahlgren, a noted California toxicologist.

ATSDR did not perform any health tests or conduct interviews with any members of the public in the preparation of its report. But Rachel Najjar, a former resident of The Dalles, said ATSDR should have conducted a much more rigorous inquiry before drawing any conclusions at all about the safety of the city’s air.


“This study was a calculation of risk based on faulty data,” said Najjar, who recently moved to Hood River in an effort to find healthier air for her family. “Of course, they aren't going to test people or do a study, they know that what they would find will be horrific.”
-- Rachel Najjar


“This study was a calculation of risk based on faulty data,” said Najjar, who recently moved to Hood River in an effort to find healthier air for her family. “Of course, they aren't going to test people or do a study, they know that what they would find will be horrific.”

Dr. Austin Wendel, the ATSDR medical officer who wrote the report for The Dalles, deflected media questions when it was released at a public meeting sponsored by the Oregon Health Authority two weeks ago in The Dalles. He seemed to twitch nervously while referring questions to officials in the agency’s main headquarters in Atlanta.

ATSDR issued a statement acknowledging that its review of naphthalene's health effects did not determine the overall safety of breathing the air in The Dalles. The agency said it has not determined how much creosote pollution is safe to breathe.

"ATSDR has not established Minimal Risk Levels (MRLs) for creosote. MRLs are an estimate of the daily human exposure to a substance (noncarcinogenic) that is likely to be without an appreciable harmful health effect over a specified duration of exposure," the ATSDR statement said.

"MRLs for creosote cannot be determined because available data are insufficient for acute, intermediate, and chronic exposures for eating or breathing creosote. In addition, creosote is extremely complex in its chemical composition and can vary, thereby further complicating the development of MRLs."

Meanwhile, OHA spokesman Jonathan Modie defended the report.

“The report is not intended to be a definitive assessment of health risks in The Dalles,” he said. “The ATSDR report did not say the health of people in the community had not been compromised. It did acknowledge that while there is no apparent public health hazard from the specific (chemicals) evaluated at the concentrations detected, ATSDR was not able to make conclusions about cumulative non-cancer health risks from inhaling” these chemicals.

“The amount of available data upon which our analysis is based may not be satisfactory to some community members, but it does shed light on certain short- and long-term health risks the community faces, and gives us a starting point for working with our partner agencies, such as DEQ, so we can find solutions that may help reduce people’s exposure even more.”



ATSDR has faced withering criticism for alleged flaws in its work since its inception in 1983. In 1991, for example, an expert panel evaluated 15 ATSDR public health assessments that it had conducted in communities with Superfund sites and found they “were seriously deficient.” A later evaluation found that ATSDR was “still having some problems in data or analysis.”

The low point came in 2008, when the agency was shredded by a congressional committee for failing to sound the alarm about formaldehyde that contaminated trailers provided to victims of Hurricanes Katrina and Rita.

As a result, tens of thousands of families lived in trailers with elevated levels of formaldehyde “for at least one year longer than necessary,” the US House Subcommittee for Science and Technology said in “Toxic Trailers,” a blistering report issued in September 2008.

Rep. Brad Miller, a Democrat from North Carolina, told the New York Times that ATSDR’s culture is “to do quick and dirty studies and to be too willing to say there are no public health consequences. People should be able to count on the government to tell them the truth.”

In testimony to the subcommittee, Dr. Howard Frumkin, ATSDR’s administrator at the time, acknowledged that its report on the trailers was “incomplete and perhaps misleading” and said that it had been withdrawn.

“Formaldehyde is classified as reasonably anticipated to be a human carcinogen,” he said. “As such, there is no recognized safe level of exposure. Thus any level of exposure to formaldehyde may pose a cancer risk regardless of duration. Failure to communicate this issue is possibly misleading and a threat to public health."

Dr. Frumkin said that ATSDR was “taking steps to prevent similar situations in the future.”

And yet criticism about ATSDR’s work continues to roll in.

In 2010, the US General Accounting Office, the investigative arm of Congress, found that ATSDR for many years had been conducting haphazard health evaluations that relied on “poor quality data” as well as inferior methodologies and study design.

And in 2011, with Frumkin still at the helm, ATSDR was forced to withdraw another report which had determined that children in an East Chicago, Ind., neighborhood were not at risk of getting lead poisoning from a lead- and arsenic-contaminated Superfund site located nearby.

“Breathing the air, drinking tap water or playing in soil in neighborhoods near the USS Lead Site is not expected to harm people’s health,” ATSDR said in the East Chicago public health assessment, a wording that reverberated seven years later in the report on The Dalles.

ATSDR later was forced to withdraw the East Chicago report after more than 1,000 residents, including 600 children, had to be evacuated because of high lead levels found in their blood.



AmeriTies West in The Dalles, Ore., a wood treatment plant that uses creosote to preserve wood railroad ties, processes up to 1.2 million ties a year. Residential uses of creosote have been banned by the EPA since the 1980's due to cancer risks. Creosote is still allowed in the treatment of railroad ties and utility poles. 


ASTDR’s report on The Dalles failed to mention what appears to be relevant information in two studies that the agency published over the last 10 years on the health effects of naphthalene.

One of the reports is a 2009 ATSDR document entitled “Toxicological Profile of Creosote.” In it, ATSDR cites research conducted in Columbus, Miss., by a group of toxicologists led by Dr. Dahlgren, then a professor of occupational medicine at the UCLA School of Medicine.

Dr. Dahlgren’s study, Exposure assessment of residents living near a wood treatment plant, says that if you can smell naphthalene in the air, and are also suffering from symptoms typically associated with creosote exposure -- such as skin rashes, neurological dysfunction or breathing problems -- you should consider the air to be “dangerous,” he told Cascadia Times in an interview last week.

His study said people can smell naphthalene at concentrations as low as 0.437 micrograms per cubic meter in the air. DEQ in 2017 found naphthalene levels in The Dalles of up to 2.48 micrograms per cubic meter, or almost 6 times greater.

“The presence of a detectable odor of naphthalene associated with symptoms would indicate that significant airborne exposure to the creosote vapor is occurring,” said Dr. Dahlgren’s study, which was published in 2003 in the peer-reviewed journal Environmental Research.

ATSDR’s report said that low-level environmental exposure to wood processing waste chemicals in Columbus “had significantly more adverse health effects than unexposed controls matched for gender and age; these health effects included cancer as well as respiratory, skin and neurological problems.”


It noted that the prevalence among exposed people of mucous membrane irritation, skin rashes, cancer and neurological symptoms such as irritability, lightheadedness and extreme fatigue “was significantly greater.”


It noted that the prevalence among exposed people of mucous membrane irritation, skin rashes, cancer and neurological symptoms such as irritability, lightheadedness and extreme fatigue “was significantly greater.”

This chart compares the federal Agency for Toxic Substances and Disease Registry’s response to naphthalene pollution in The Dalles with its response to naphthalene pollution in Columbus. At left on the top line  it shows a computer modeled estimation of the maximum naphthalene levels in Columbus between 1950 and 1999 – as reported in a study by a group of toxicologists led by Dr. James Dahlgren. At right on the top row it shows the maximum naphthalene level ever measured in The Dalles, which was reported by AmeriTies in a study it conducted in 2011 and 2012. The chart also shows that people in Columbus were surveyed for health problems, while people in The Dalles were not.

Residents of The Dalles have reported that they too have suffered from these symptoms.

Dr. Dahlgren said his study built a database of naphthalene emissions in Columbus going back 50 years, based on historical production data. The researchers developed computer software that used this data to calculate naphthalene levels in Columbus’ air from 1950 to 1999.

A comparison of the computer-generated air pollution data from Columbus with actual air monitoring data from The Dalles shows that naphthalene levels in The Dalles during 2017 were 35 times higher than they were at their peak during those 50 years in Columbus.

But in its report dismissing any relationship between pollution and non-cancer health risks in The Dalles, ATSDR did not mention that it found a correlation between even lower levels of naphthalene in Columbus with health problems. It simply pointed out that pollution levels in The Dalles were below a predetermined “minimal risk level (MRL)” which it defined as the concentration at which naphthalene begins to pose “adverse” health risks to anyone who breathes it for a full a year

As we saw, ATSDR developed the safety level for naphthalene exposure in 1995. The US Environmental Protection Agency developed a similar safety level for naphthalene in 1998. But Dr. Dahlgren said these safety levels are “outdated” and have been superseded by more current research.


ATSDR also appears to have overlooked findings in a 2014 “Public Health Assessment” that reviewed the health effects of naphthalene pollution on African-Americans, which as a group are known to be more vulnerable to naphthalene pollution than other people.

Doctors have known since the 1950s that African-Americans typically possess a genetic trait known as glucose-6-phosphate dehydrogenase deficiency (G6PDD). People with this trait who inhale naphthalene are unable to eliminate it before it does damage. As a result, they can suffer from a unique array of health problems, including cataracts and hemolytic anemia, a condition that potentially can lead to “severe and fatal complications,” according to the National Institutes of Health.

“Naphthalene released into the air while the creosote treatment process was occurring posed a risk for respiratory irritation,” ATSDR said in the Public Health Assessment. “African-American children appear to be uniquely susceptible to acute exposure effects.”

EPA has long been concerned about health problems caused by exposure to naphthalene in African-American people. In a 1998 toxicological profile of naphthalene, EPA saidthis genetic trait “is particularly common among African and Mediterranean races.”

About 140 people who identify as African-American live in The Dalles, according to the U.S. Census Bureau’s population estimates for 2017, which were released last week.

ATSDR’s report on The Dalles failed to mention naphthalene potential health effects of the city’s African-American children. It did not interview any African-American people in The Dalles who might have suffered from these symptoms.

However, Cascadia Times was able to contact the mother of four African-American children who have been exposed most of their lives to naphthalene pollution in The Dalles. This mom said her children have suffered health conditions that resemble G6PDD-like symptoms she’s seen reported in medical literature.


ATSDR’s failure to evaluate these impacts in its report on The Dalles appears to run counter to the agency’s stated policy of working to “decrease environmental health hazards for vulnerable populations (children and elderly).” Both DEQ and OHA have adopted similar environmental justice policies.

ATSDR’s failure to evaluate these impacts in its report on The Dalles appears to run counter to the agency’s stated policy of working to “decrease environmental health hazards for vulnerable populations (children and elderly).” Both DEQ and OHA have adopted similar environmental justice policies.


Sunshine Mill Winery in The Dalles, Ore., lies just on the other side of the overpass from the AmeriTies West facility, where railroad ties treated with creosote off-gas in the yard while awaiting transport. The winery holds events in their outdoor amphitheater including movie nights in the summer. 



DEQ and OHA are launching a new program -- Cleaner Air Oregon -- aimed at regulating industrial air pollutants like naphthalene based on a scientific assessment of health impacts.

Under Cleaner Air Oregon’s draft rules, the program will rely on a dosage that the EPA determined to be safe: 3.0 micrograms per cubic meter as projected over a lifetime. This number is slightly lower than ATSDR's 3.7 micrograms per cubic meter "minimal risk level," or MRL, as measured over one year. These safety levels are just above the 2.4 micrograms per cubic meter concentration of naphthalene that DEQ detected in The Dalles’ air.

But is EPA’s so-called safe number protective enough? Dr. Dahlgren’s study, which was cited in the 2009 ATSDR paper, says no. He says the EPA's number is almost seven times higher than the dose of naphthalene that people can smell and possibly make them sick. If Oregon wanted to to be more precautionary, it could choose an equally legitimate lower number, such as the state of New Jersey’s health benchmark of 0.029 micrograms per cubic meter. The EPA’s number is 100 times higher than New Jersey's.

Nevertheless, Cleaner Air Oregon intends to use EPA’s old and outdated number as its “toxicity reference value,” which will help it determine “if action needs to be taken” to reduce health risks caused by air polluted by naphthalene, said Keith Johnson, manager of Cleaner Air Oregon.

Significantly, by relying on EPA’s number, Cleaner Air Oregon would allow AmeriTies to continue polluting just as it has been doing without facing any new restrictions. But if it adopted Dr. Dahlgren’s number, or even New Jersey's benchmark, AmeriTies might be forced to significantly reduce its emissions.

The people who would suffer the most under DEQ’s rule could be those who are most vulnerable to naphthalene pollution, such as African-Americans. Although the rule would apply to any place statewide where an industry emits naphthalene, naphthalene pollution is not a widespread problem in Oregon. For example, naphthalene levels in The Dalles are about 10 times higher than in Portland, according to DEQ modeling data published in 2011.

“The overhaul that was supposed to help the people of Oregon, ended up putting our health in even more danger,” Najjar said. “I tried to warn people. Everyone loves to believe that agencies are there to help us, so they don’t have to get invested. Truth is they are there to keep people complacent to the truth.”

Paul Koberstein