Scott MacDonald

Senior Policy Analyst

Office of Research

University of California

1111 Franklin Street, 11th Floor

Oakland, California 95607-5200

 

Dear Mr. MacDonald:

 

The California Environmental Protection Agency (Cal/EPA) is seeking your assistance under our Interagency Management Agreement (IMA) dated June 15, 1998, as amended October 29, 1998.   Cal/EPA is requesting expert advice and recommendations on the toxicity of chromate.  Subsequent to receiving this advice, Cal/EPA’s Office of Environmental Health Hazard Assessment will develop documentation identifying a numerical public health goal for chromium-six in drinking water and submit it for peer review as part of this request.

 

The complexity of the toxicology and potential human health issues related to chrome-six (hexavalent chrome, typically as chromate) necessitates that we seek the expertise of the academic and scientific community to help us better understand the issues and develop a drinking water goal that is protective of public health.  There has been recent and intense public and media interest in chromate in groundwater.  On October 24, 2000, members of the State Legislature held a public hearing on this subject in Burbank.   We can expect this interest to continue and will extend to this letter and the nature of our request.

 

As background, under State law, the California Department of Health Services (DHS) is responsible for promulgating primary standards, or maximum contaminant levels (MCLs) for contaminants in drinking water.  In establishing an MCL, DHS must consider the public health goal (PHG) adopted by the Office of Environmental Health Hazard Assessment (OEHHA), while also taking into account the technical feasibility and cost of treatment to achieve a level as close to the PHG as practicable.  The PHG adopted by OEHHA is based solely on health effects and is the numerical value for the concentration of a contaminant in drinking water that is without significant risk, or provides an adequate margin of safety.   In developing a public health goal, it is essential that we use the best available science and interpretation of that science.  Therefore, we request that the Office of the President of the University of California convene a Chromate Toxicity Review Committee and appoint a Chair of the Committee to assist us with some of the scientific and technical issues of chromate toxicity.

 

We suggest that the Chromate Toxicity Review Committee consist of a sufficient number of members to provide expertise in the following areas: toxicology of metals, rodent pathology, rodent cancer bioassays, epidemiology, human physiology, pharmacokinetics, and risk assessment methodology.  As per our IMA, we are providing you a list of names of potential committee members to assist you in your search.  These candidates have not been contacted as to their willingness or availability to serve on the committee.  A factor that would affect availability is participation in one public meeting in the spring, the specific date and location of which is to be determined by the Chair.  Under our IMA, the Office of the President is not limited to this list in its selection of candidates.   However, the President of the University of California, under California Statute (Health and Safety Code 57004 Sec. (2)(b)) must recommend this group of scientists for purposes of conducting the external scientific peer review of the scientific basis of our proposed rules.

 

For the Chair of the Committee, we ask that you give consideration to Professor Jerold Last at the University of California at Davis.  In 1998, Prof. Last demonstrated exemplary leadership in managing a contract with the State of California to assess the potential health and environmental impacts of the gasoline additive methyl tertiary-butyl ether (MTBE).  A comprehensive report was completed within budget and on schedule.  In early 1999, Prof. Last was successful in getting the authors of each chapter of the report to participate in lively public hearings in northern and southern California.  Cal/EPA was extremely appreciative of the manner in which Prof.  Last coordinated the efforts of the authors in producing the report and participating in the public hearings.  Cal/EPA and the California Health and Human Services Agency would appreciate the leadership and direction of Prof. Last as Chair of the Chromate Toxicity Review Committee.

 

Please contact me as soon as you have identified the Chair so that we can finalize an agreement.   I can be reached at (916) 324-7584 or by electronic mail at “bvance@calepa.ca.gov”.

 

 

                                                                        Sincerely,

 

 

 

 

                                                                        William A. Vance, Ph.D.

                                                                        Assistant Secretary

 

Enclosures

 

cc:  Joan Denton, Ph.D., Director, OEHHA

       Diana Bonta, R.N., Dr.P.H., Director, DHS