STATEMENT of ETHICS and
PCB Contamination in the Hudson Valley: A victimless crime?
A colloquium to present the most current research on the
human health effects of PCBs.
Held February 7, 2001, SUNY School of Public Health, Rensselaer, NY,
Sponsored by Hudson River Sloop Clearwater and
Physicians for Social Responsibility
The Hudson River is the nation's largest non-government Superfund
toxic waste site. 190 miles of the federally-designated American Heritage
River are contaminated with polychlorinated biphenyls (PCBs)
discharged during the industrial manufacturing processes of the General
PCBs have long been classified as a probable human carcinogen. All
commercial PCB mixtures have been shown to cause tumors in
laboratory animals. The prepoderance of responsible scientific
investigation strongly suggests that PCBs also cause endocrine system
disruption by mimicking hormones, notably estrogen, and have been
linked to a number of developmental effects including low birth weight,
decreased IQ, and subnormal performance on standardized tests. PCBs
may also cause liver, reproductive system, and thyroid damage.
Since 1977, virtually no concerted, significant research has been
conducted on human beings who live, play, and work along the banks of
the Hudson River. Fish, birds, turtles, mammals, benthic organisms,
plankton, bulk water, and sediment have been tirelessly and thoroughly
analyzed, but the effects of PCBs on human beings in the Hudson Valley
have been largely ignored.
Today we take one small step to rectify that oversight, by assuming that
people living in the Hudson Valley are vulnerable to the same PCB-
induced diseases as have been documented elsewhere, and by
acknowledging the fact that research conducted on laboratory animals
has proven to be predictive of results found in humans following
Today, as we listen to a small but representative sample of the work
being done on PCB exposure in humans we take a cognitive step, in the
absence of site-specific data, to recognize that a convincing majority of
research inquiries have identified PCBs as a significant human health
We acknowledge that thousands of human beings have been
experiencing direct long-term exposure to PCBs through fish
consumption, through eating other foods, through inhalation, and
through dermal absorption.
PCBs do not appear to break down in the environment. They weather --
losing some of their chlorine content -- but have not been identified in a
post-PCB molecular state. Hence, the polluter's insistence that
is healing itself" can only refer to the continual dispersion and
distribution of PCBs downstream. This is unacceptable by any moral
standard. It is clear that the only course of action that will be protective
of public health is the physical removal of PCBs from exposure pathways.
On December 12, 2000, twenty-three years after PCBs were banned, the
U.S. Environmental Protection Agency has at last issued a draft of a
proposed plan to physically remove PCBs and other contaminants from
targeted "hotspots" in the upper Hudson River.
This statement will become a part of the EPA public record docket
concerning the Hudson River Superfund site.
II. Scientific Research. (A brief sampling of PCB literature.)
"New evidence is especially worrisome because it underscores the
exquisite sensitivity of the developing nervous system to chemical
perturbations that result in functional abnormalities."
The Erice Statement,
1995, signed by 18 doctors and research scientists.
...one would predict that these PCBs would be related to impaired
performance on those NBAS [neonatal behavioral assessment scale]
associated with fish consumption; namely Habituation, Autonomic, and
Reflex clusters of the NBAS. Excepting the Relex cluster, these
predictions were confirmed. Results revealed significant linear
relationships between the most heavily chlorinated PCBs and
performance impairments on the Habituation and Autonomicclusters of
the NBAS at 25-48 h[ours] after birth. Additionally, higher prenatal
PCB exposure was associated with a nonspecific performance
impairment on the NBAS as evidenced by a significantly greater
proportion of NBAS scales in which poor performance was exhibited ..
in the most highly exposed neonates.
Stewart, Reihman, et. al.
Neurotoxicology and Teratology 22 (2000) 21-29
Mulutiple regression analyses identified significant [menstrual] cycle
length reductions with consumption of more than one fish meal per
month (1.11 days) and moderate/high estimated PCB index (-1.03
days). Women who consumed contaminated fish for 7 years or more
also had shorter cycles (-0.63 days).
Mendola, Buck, et. al.
American Journal of Epidemiology 1997; 146:955-60.
... an increase in the risk of a low birth weight was observed at a CB-
153 [2,2',4,4',5,5'-hexachlorobiphenyl] concentration of 300 and 400
ng/g lipid weight, respectively...
Rylander, Str"mberg, et. al.
American Journal of Epidemiology 1998; 147:493-502.
We demonstrated three different direct mechanisms whereby PCBs are
neurotoxic in rats... Thus, PCBs have a variety of mechanisms of
primary neurotoxicity, and neurotoxicity is a characteristic of ortho-
substituted, non-dioxin-like congeners as well as some coplanar
Carpenter, Stoner, et. al.
Human Health and Ecosystem Effects, 1996.
Human health studies discussed in this study indicate that 1)
reproductive function may be disrupted by exposure to PCBs; 2)
neurobehavioral and developmental deficits occur in newborns and
continue through school-aged children who had in-utero exposure to
PCBs; 3) other systemic effects (e.g., self-reported liver disease and
diabetes, and effects on the thyroid and immune systems) are associated
with elevated serum levels of PCBs; and 4) increased cancer risks, e.g.,
non-Hodgkin's lymphoma, are associated with PCB exposures.
Barry Johnson et al
Public Health Implications of Exposure to Polychlorinated Biphenyls
Prenatal exposure to polychlorinated biphenyls (PCBs) has been
associated with a lower IQ in childhood......We conclude that PCBs
selectively impair the process of LTP [long-term potentiation] in CA1
neurons of the hippocampus.
William D. Niemi et al
Experimental Neurology 151, 26-34 (1998)
Responses not mediated through the AhR are presented and emphasize
large data gaps. Dissimilar analytical reports emphasize that selection
of analytes is not consistent. Collectively, these data confirm that AhR-
focused objectives unintentionally created the impression that
nonplanar PCBs have little if any potential for hazards to humans and
wildlife. Near steady-state exposure of healthy adults are probably of
minor consequence except for emerging correlations with non-
Hodgkin's lymphoma; however, pulses of exposure to more labile
mixtures may contribute to developmental effects without leaving a
Larry G. Hansen
Environmental Health Perspectives 106:1, 1998
In a study of caudate nucleus obtained post mortem from patients with
Parkinson's disease, there were significantly higher concentrations of
the organochlorine insecticide dieldrin and the PCB congener 153 in
the PD tissue. DDE, PCB congener 180, and total PCBs (matched with
a commercial preparation) also tended to be higher in Parkinson's
F. M. Corrigan et al
Experimental Neurology 150, 339-342 (1998)
In our Dutch study, higher levels of PCBs and dioxins in human milk
were significantly related to a reduced neonatal neurological
optimality score and to a higher incidence of hypotonia. Long-term
implications of PCB and dioxin exposure to later school performance
have been found. At 11 years of age the most highly prenatally exposed
children were three times as likely to be behind in reading
Corine Koopman-Esseboom et al
Letter to the editor, Developmental Medicine and Child Neurology 39,
Polychlorinated biphenyls may be passed to a child through mother's
Polychlorinated biphenyls can affect the reproductive system of adults.
Polychlorinated biphenyls are PROBABLE CARCINOGENS in human
Many scientists believe there is no safe level of exposure to a
Hazardous Substance Fact Sheet, New Jersey Department of Health and
Among the angler couples in this study who were attempting
pregnancy, 42% of women and 68% of men of reproductive age
reported ever having eaten Lake Ontario fish despite state advisories
warning women of reproductive age not to eat any fish from Lake
Ontario...fish consumption advisories for Lake Ontario have been
issued in New York State since 1976, yet only 49.9% of Great Lakes
sport fish consumers were aware of health advisories."
Buck et al, Epidemiology 11, 2000
[Note: Buck et al revealed that women trying to conceive take longer to
become pregnant if they have a history of consuming PCB-contaminated
fish caught in Lake Ontario. Lake Ontario fish have on average lower
levels of PCBs than Hudson River fish.]
Guo et al, in The Lancet, revisited the children born to mothers exposed
to PCBs in rice wine, an event that occurred in Taiwan, 1979. There were
significant impacts on sperm quality among the boys born to the
exposed women, with decreases in motility, increases in abnormally-
formed sperm, and decreases in sperm strength.
While little is known about the effects of Hudson River PCBs upon
human beings, there is an ample body of evidence to suggest that the
residents of the Hudson River Valley may have been suffering from a
number of effects caused by that exposure. These effects range from the
profound, e.g. cancer, to the subtle, e.g. reduced IQ.
The failure of "institutional controls," such as fish consumption
advisories, to prevent fish ingestion is due in part to the fact that anglers
fishing in tidal waters, such as the Hudson River from New York to Troy,
are not required to purchase a fishing license, and hence bypass the
most effective route of advisory dissemination. Furthermore, based on
evidence gathered during the administering of Clearwater's Angler
Survey (1992), we have learned that many of the populations ingesting
Hudson River fish are from immigrant and disadvantaged communities.
NYS DEC and DOH found in 1998 that in many cases there are language
barriers and insular cultural patterns that inhibit the dissemination of fish
If, as the evidence suggests, these communities are facing a potential for
reduced human potentiation, our region may be facing a perpetuation of
the social stratification that keeps new immigrant groups locked into a
cycle of poverty and dependence, and barred from entry into mainstream
There have been no studies of cancer or any other health effect
attributable to PCBs among people living along the Hudson River. Our
region may have been grappling with elevated levels of cancer incidence
for decades. The tumor registry maintained by NYS DOH is not readily
accessible. Studies of cancer mortality among capacitor workers have
ignored cancer incidence, despite demonstrating higher levels of cancer-
related mortality in women.
There is clearly a strong need for epidemiological studies among various
populations in the Hudson Valley to dispel the doubts and uncertainties
that cloud the Hudson River PCB issue.
We, the undersigned, have become aware of the potential for human
health impacts on the population of the Hudson River Valley.
We express our disappointment over failures to adequately monitor
public health in the immediate vicinity of the nation's largest non-
government toxic waste site.
We further express our strongest disappointment at the polluter's
efforts to confuse and misinform the public with a saturation campaign of
paid advertising. We assert that public policy should be based upon
facts, not economic hegemony.
We deplore the role of the polluter in diverting attention from the
need for a firm commitment to public health in the Hudson River
Superfund site area.
We remind our elected officials and agency appointees of the
precautionary principle, an ethos held by responsible scientists around
the world, by the terms of which a civil society must respond proactively
to strongly suggestive evidence even in the absence of absolute
We urge, in the strongest terms possible, that funding for thorough,
comprehensive, and objective epidemiological studies be allocated
immediately, and that those studies be set in motion at the earliest date
In support of the Statement of Ethics and Action, Rensselaer, NY,
February 7, 2001
Kathleen Arcaro, University at Albany School of Public Health
Jean Boyce, Social Action Committee / Unitarian Universalist
Frank Carbone Jr., Pres.- Concerned Citizens Around Stewart Airport (CCASA)
David Carpenter, University at Albany School of Public Health
Ken Dufty, President, Concerned Citizens for the Environment
Jennifer Feyerherm, Sierra Club Great Lakes Program
Dave Gibbs, Housatonic River Initiative
Anne Golden, Mount Sinai School of Medicine
Tim Gray, Housatonic River Initiative
Natalie Hawley, Rensselaer County Greens
Robert Henrickson, Nassau Union of Concerned Citizens
Judith Herkimer, Housatonic Environmental Action League, Inc. (HEAL)
Sharon Herr, UNCAGED
Michael Kane, NYSDEC
Pam Lever, UNCAGED
Julie Linehan, NYS DEC Hudson River Estuary Program
Robert M. Hardy
Alex Matthiesen, Riverkeeper
Craig Michaels, Riverkeeper
Dana Mitchell, Unitarian Universalists of the Catskills Congregation
Megan Motigue, NYS DEC Hudson River Estuary Program
Susan Murphy, HRSC, Ulster County Friends of Clearwater
Jeremy Ogonya, SPH SUNY Albany
Michelle Przedwiecki, Questar III New Visions
Julia Ravenscroft, Research Foundation, University at Albany
Larry Robertson, University of Kentucky Medical Center
George Robinson, Department of Biological Science, University at Albany
Carol Smith, Kingston Hospital
Steve Stanne, NYS Department of Environmental Conservation
Fred Stein, Hudson River Action Committee
Margaret Stein, Rensselaer County EMC
Kelly Travers-Main, UNCAGED
John Vena, Social and Preventive Medicine, SUNY-Buffalo