Comments on the Connecticut Siting Council Draft

Proceeding 754 Comments on the Connecticut Siting Council Draft Best Management Practices (BMPs), dated Sept. 28 , 2006

Comments of Dr. Gary Ginsberg, Toxicologist, Connecticut Department of Public Health

January 3, 2007

I am Gary Ginsberg, a toxicologist at the Connecticut Department of Public Health, a position I have held for the past eleven years. My daily activities involve assessing the health risks from a wide variety of chemical, biological and radiological risks and in so doing assist in the setting of standards or providing advice to the public. I am also adjunct faculty at Yale University School of Public Health and at the University of Connecticut School of Community Medicine where I am an Assistant Clinical Professor. In 2006 I completed service on a National Academy of Science panel on biomonitoring and was selected to brief Congress on the findings of our report. Since then I have been selected for another NAS panel, this one on evaluating USEPA’s risk assessment methods. This panel began in November, 2006 and will report to Congress in 2008. I have published in a variety of areas including carcinogenesis, health risks to children, genetic polymorphisms, and the health risks from perchlorate. My experience with power lines and magnetic fields stems from the department’s involvement with the issue over the past 15 years and my more direct involvement with it over the past five years. During this time I have reviewed the literature, contacted a number of researchers in the area of EMF toxicology and epidemiology, helped update the department’s EMF fact sheet, and have provided testimony to the CSC on a number of occasions.

Overview of DPH Position

Today’s statement relates to a BMPs draft that CTDPH has already commented on (10/20/06 submission to Proceeding 754). The Department has read the recent testimony of others on this matter (Gradient Corp., Dr. Repacholi, Dr. Bailey, CL&P/UI). This has not changed our position that the BMP document is inadequate as currently drafted. We note that childhood leukemia predominantly occurs as acute lymphocytic leukemia (ALL) and that this disease occurs to a greater extent in industrialized countries such as the United States than in developing countries (Kim, et al., 2006; Stiller and Parkin, 1996). While there is no explanation for this phenomenon, the obvious concern is that some aspect of our technological society, such as the electrical power grid, could contribute to the risk to children. When this general concern is added to the evidence that has accumulated over the past several decades of a statistical association between transmission lines and childhood ALL, the Department believes a careful course of prudent avoidance is warranted. We note that this association has become stronger in recent years with the application of meta-analysis to the various EMF/childhood leukemia studies (Ahlboom, et al., 2000; Greenland, et al., 2000; Wartenberg, 2001a). As the demands for electricity increase in the northeast and as land suitable for building new housing and schools continues to shrink, there is a potential for increasing numbers of children to become exposed to elevated levels of EMF in Connecticut. The Department believes that a carefully constructed BMP can avoid much of this exposure and minimize the potential risks to children.

However, the current BMP draft fails to provide this roadmap for prudent avoidance. Instead it emphasizes a 100 mG ROW target that is inappropriate for residences, schools, day care centers, playgrounds or other locations where children may live or spend substantial amounts of time. While DPH does not disagree with the selection of a general 100 mG target as a general engineering goal, we feel that the draft BMPs’ emphasis on this value is misleading and overshadows the equally important goal of reducing MF to the greatest extent possible where children are involved. The draft document spends the first several pages building up to and justifying the 100 mG target, describing in some detail the methodology that arrived at this value. Not until a very brief paragraph on Page 4 does the BMP document describe the goal of “reducing MF exposure to the greatest extent possible” where children are involved. Further, that goal is stated only as “the Council will examine the feasibility” for such reductions. Then the document spells out its Best Management Practices (Section IV) and in so doing ignores the goal of “reducing exposure to the greatest extent possible” but rather focuses singly on the 100 mG target (see Page 4, middle of 4th paragraph).

We take exception to the draft BMP statement: “The actions by the legislature and the recommendations by the DPH announce a clear state policy to protect children from risk, whether that risk is substantiated by the weight of scientific evidence or not.” (Page 4, end of first paragraph). The Department has supported its recommendations with scientific discussion which has been fully referenced and takes into account the weight of evidence analyses provided by other scientific and policy bodies on this matter. This sentence should be amended such that the second clause should read: “….., since children can be more vulnerable to carcinogens, in general, and the evidence for an association between MF and human disease is mostly with respect to childhood leukemia.”

The Department wishes to emphasize that the epidemiological association between proximity to power lines and childhood leukemia has existed for nearly 30 years and that after much research, that link has not gone away, but if anything, has become stronger. The possibility that bias or confounding have created this association is diminished when considering that the dozens of studies included in recent meta-analyses are unlikely to all be biased in a similar manner or direction (Wartenberg, 2001b). We are left with a consistent statistical association that is unlikely to be due to chance or bias but for which causality has been doubted on the grounds that animal testing is not supportive.

In fact, in spite of much animal and cell culture test data, there are no experimental studies which rule out the possibility that MF causes leukemia. The Department recognizes the difficulty in proving a negative. However, the current laboratory evidence is far from strong or unified against a causal association. Given the repeated epidemiological association to childhood leukemia, there is a burden to show that new lines will not increase childhood risk of cancer before such lines are sited. Statements from federal and international bodies that MF is a possible human carcinogen and that prudent avoidance measures are needed are not very reassuring (IARC, 2002; NIEHS, 1999/2002). If the scientific evidence cannot document safety, as is currently the case, then these lines need to be sited in a manner that minimizes children’s exposures.

Animal studies do not come close to demonstrating the safety of MF from transmission lines. The negative NTP study which was cited by Gradient Corp. as the key data for deriving a ROW mG target, is not of direct relevance to the association between EMF and childhood leukemia. Further, it cannot be construed to represent the body of laboratory evidence on this subject. The Department’s previous testimony (May 31, 2006) highlighted the interpretative limitations of the NTP study (see summary points below). Further, the laboratory test data can hardly be described as uniformly negative with respect to MF and biological effects, with some of the positive and reproducible findings related to cancer mechanism. For example, laboratory generated fields have induced DNA damage (Lai and Singh, 2004; Ivancsits, et al., 2003a; Ivancsits, et al., 2003b; Wahab, et al., 2006; Mairs, et al., 2007), have had promotional effects consistent with the action of well-known tumor promotors (Chen, et al., 2000; Trosko, 2000; Nikolova, et al., 2005), and have magnified the genetic effects of other carcinogens (Mairs, et al., 2007; Cho and Chung, 2003). Field experiments in which animals were exposed to real world MF from power lines show evidence of a link to blood abnormalities and cancer. A study using household dogs as sentinels of EMF exposure found a statistical increase in leukemia with MF exposure with an odds ratio of 6.8 when comparing dogs in the highest and lowest categories of exposure (Reif, et al., 1995). Dogs who spent more than 25% of their time outdoors were at greater risk. Another field experiment involved mice caged outdoors underneath a 220 kV at an average exposure of 80 mG (Svendenstal, et al., 1999). The EMF group of mice were exposed for up to 32 days under summertime conditions, while control groups of mice were exposed to the same outdoor elements but at 200 to 500 meters from the line where measurements were well below 1 mG. This study found a number of blood abnormalities in the growing mice including lower numbers of lymphocytes and a more immature pattern of red blood cells (greater ratio of polychromatic to normal red cells). These changes were interpreted to be consistent with the kinds of pre-leukemic effects caused by ionizing radiation (Svendenstal, et al., 1999). Another finding was an increase in DNA damage in the brains of the EMF exposed animals relative to the controls (Svendenstal, et al., 1999). This finding is consistent with a number of laboratory studies involving EMF-induced DNA damage (e.g., Lai and Singh, 2004). One additional note is that the concern over EMF-induced effects on the secretion of melatonin and subsequent anti-cancer effects unclear but may be less of a concern than previously believed (Kato, et al., 1994; Burch, et al., 2000; Touitou, et al., 2006).

In summary, the laboratory and field animal evidence indicates that EMF effects on mammalian systems are quite possible and that some of these effects are consistent with cancer causation. While in some cases the positive findings are counterbalanced by negative (no effects) studies, overall, the animal/cell culture database is not one that we can celebrate as showing “all clear” and no need for safety precautions. This is especially the case given the difficulties in conducting relevant MF tests in the laboratory as elaborated below and in our previous testimony. The area of EMF-induced effects in animals and cell culture is very active and in fact researchers are planning to use new proteomic and gene expression techniques to better study the effects of EMF (Wang, 2006).

While doubt has been cast on the causality of MF and childhood leukemia, there are no credible competing theories to explain the epidemiological association. For example, some have suggested that contact currents due to household plumbing receiving current from improperly grounded household sources or from the home’s proximity to high voltage transmission lines, would explain the observed associations (Kavet and Zaffanella, 2002; Peck and Kavet, 2005). However, there has been very little documentation of the potential exposures and no experimental or epidemiological evidence of toxicity or leukemic effect. This theory remains a research hypothesis (Peck and Kavet, 2005).

Additional Reasons for Decreased Weight on the NTP Study Used By Gradient Corp to Define a Draft BMP Target Level of 100 mG The Department reiterates previous testimony regarding the manner in which the draft BMP document relies too heavily on the NTP rat study. We would like to take this opportunity to emphasize a key point: that the NTP study design did not test the vulnerable life stages at risk for childhood leukemia. Emerging evidence on childhood leukemia documents a multi-step process in which the first genetic event occurs in the womb and a second event occurs shortly after birth. This double modification of DNA leads to a spike in ALL in children at age 3, a spike which is characteristic of industrialized societies but not developing countries (Kim, et al., 2006). Thus ALL occurs because of genetic damage that is related in some way to our modern industrialized society and this occurs during two critically vulnerable early life stages. MF could theoretically act on either one or both of these stages in a residential setting. In contrast, the NTP rat bioassay began exposure when the rats were young adults – there was no exposure during a critical window of developmental vulnerability for leukemia or other cancers. Therefore, the NTP study was not a test of whether EMF could produce the animal equivalent of childhood leukemia and so was not directly relevant to the question of EMF causality of human cancer. In fact, it is not surprising that the NTP study yielded negative results given the lack of evidence for adult cancer in humans from EMF. For a test in animals to be relevant to the development of childhood leukemia, it would need to involve pre-natal and early post-natal exposures and be conducted in animals known to be sensitive to leukemia induction. One study of MF exposure in an animal leukemia test system has been reported (Harris, et al., 1998). However, that transgenic mouse system has no obvious relevance to childhood leukemia (different genetic defect involved) and that study did not expose animals until they were beyond the vulnerability windows. A transgene mouse model of childhood leukemia is under development (Kim, et al., 2006); this system may offer the best chance for laboratory testing of risk factors for human childhood leukemia.

As stated in previous testimony by DPH, there are other reasons why it is misguided to use the NTP study as the primary basis for calculating an EMF ROW target:  Human evidence of an effect is usually more influential than animal evidence in human health risk assessment. This should be the case for EMF as well given the potential importance of the epidemiological association and the interpretative difficulties of the animal tests.  It is difficult to reproduce human exposure to EMF in a laboratory setting given the mixture of wave forms and strengths that occur from the combination of household appliances, household wiring, and anything contributed from external transmission lines. It is unlikely that any laboratory studies have captured this mixture of exposures, certainly not the NTP study which administered linearly polarized, pure sine wave 60 Hz exposures (NTP, 1999). Further, the orientation of the field relative to the animals and to natural background magnetic fields can have a distinct effect on the outcome of the test (Blackman, et al., 1996). This makes it difficult to relate laboratory testing to human risk.  While laboratory studies have not yielded a clear mechanistic basis for EMF- induced carcinogenesis, there have been numerous studies showing reproducible effects of EMF on cells or test animals. These effects include DNA damage (e.g., Svedenstal, et al., 1999; Lai and Singh, 2004, Ivancsits, et al., 2003a), and promotional effects on cells in culture (Chen, et al. 2000; Trosko, 2000; Nikolova, et al., 2005). Some of these effects occurred at EMF exposures as low as 40 mG. Further, field studies of animals exposed under power lines (mice) or in residential settings (dogs) have EMF-induced effects and associations consistent with a human cancer risk (Reif, et al., 1995; Svendenstal, et al., 1999).  Animal testing does not always prove cause and effect for carcinogens that we know are active in humans. Classic examples are arsenic, and for many years chromium and cigarette smoke.

DPH Recommendations for Improvements in the Draft BMPs

In 1989 Granger Morgan stated that it is hard to justify spending more than “a few thousand dollars” per person exposed to mitigate MF exposure (OTA, 1989). This implies that he believed that a modest investment of several thousand dollars per person can be justified. Since then the epidemiological association has been strengthened while the animal/cell culture evidence remains uncertain. The Department believes that the need for investing in mitigative action is at least as compelling now, if not more so, than in 1989. Therefore, low cost options need to be used to limit MF exposure to the maximum extent feasible so as to avoid substantial numbers of children becoming exposed to fields that are substantially above background. In cases where this may occur, risk communication is needed. The Department’s specific recommendations for a re-draft of the BMPs are to:

1) Increase the focus on achieving reductions in childhood exposure to MF to the maximum extent feasible. The Department does not intend this to mean unlimited expenditure of money and resources. Rather, a plan such as developed in California should be considered; this plan involves low cost solutions (primarily split phasing) such that mitigation involves manageable costs (no more than 4% of the total project). To achieve this, the BMPs need to clearly state the health concern, and consistently use prudent avoidance language to address the uncertain but potentially increasing childhood leukemia risk in Connecticut. 2) Continue using a general 100 mG engineering-based (not risk-based) screening target but: a) make sure the BMP language is clear that this does not apply to land uses potentially involving children; b) do not associate this target with the analysis performed by Gradient Corp given the incompleteness of that analysis as described above; c) acknowledge that it is an engineering-based and not a risk- based BMP. 3) Include a risk communication aspect to the BMP that provides notification to property owners and residents along the transmission line where the edge of the ROW exceeds 10 mG. The risk communication would be in the form of a fact sheet that summarizes: a) the status of the project; b) that states that elevated MFs are possible at the edge of the ROW at this location; c) that states what is known and what is uncertain about MF exposures and risks; d) that instructs the resident/property owner about getting more detailed information on MF strength in other parts of the property and house; e) and that lists prudent avoidance techniques the individual can take at low or no cost. The utility involved should commit to providing the more detailed MF measurements and modeling on a property-by-property basis as needed. 4) Land use planning in areas where the edge of the ROW is > 10 mG: the risk communication BMP should include notice to local government and land owners informing them of the potential issues of development that is too close to the ROW.

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