This letter was addressed to Dr. Rebekah Gee of the Louisiana Department of Health and Dr. Donna Williams of Louisiana Cancer Prevention and Control Programs. It was sent to L’OBSERVATEUR for publication.

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On behalf of the Concerned Citizens of St. John Parish, we write to express serious concerns about the planned LSU/Tumor Registry project in St. John Parish. We have consulted with our scientist allies, and we are deeply concerned about the project’s purpose, design, methods, and procedures.

The Governor apparently commissioned this project as a response to disturbing findings from a recent health study by the University Network for Human Rights (UNHR). The study found an unusually high prevalence of cancer and other chloroprene-associated health conditions among residents living near the Denka/DuPont plant, as well as a clear association between proximity to the plant and prevalence of illness.

Although the Governor’s office and Tumor Registry refer to their project as a “study,” all information suggests that the project is not, in fact, a “study”—which would pose a question and then seek to answer the question—but, rather, an attempt to assure the completeness of Tumor Registry data. At a town hall meeting hosted by the Governor’s office in St. John Parish, we were told that the purpose of the project is to “address concerns about the Tumor Registry not having information about all incidents of cancer in the community” (Parish President Natalie Robottom) and to “confirm what we see in the Tumor Registry, which is an excellent resource” (Policy Advisor Nick Albares).

Dr. Gee told us, “What I want to do is help you have more confidence in the Tumor Registry, so the goal of this is for you to be able to—if we’re going to use [the Tumor Registry] to say we believe the risk is not elevated, I want you to have confidence that that is a robust registry and that every case that you are aware of is in the registry and that we understand the same problem together.” Referring to the recent UNHR health study, Dr. Williams told us, “This study was done that came up with a lot of cancer in this community that maybe isn’t reflected in the Tumor Registry. So what we can do is we can confirm that every case of cancer reported in St. John is in the Tumor Registry.”

According to these statements, the purpose of the LSU/Tumor Registry project is to confirm and/or improve the completeness of Tumor Registry data—not to answer pressing questions about how emissions from the Denka/DuPont plant might be affecting the health of our community. The project appears to be based on an erroneous assumption that community members’ fundamental concern is the completeness of Tumor Registry data. However, our fundamental concern is the impact of emissions from Denka/DuPont on our health and well-being. In its current form, the project does not address this concern.

The question that this project must answer is: What are the health consequences of exposure to emissions from the Denka/DuPont plant?

To answer this question, the project’s design, methods, and procedures must be modified as follows:

• Any role, participation, or presence of Denka or the Ramboll Group in this project is unacceptable. We will not accept, under any circumstances, the presence of Denka or Ramboll Group representatives on the oversight committee or their involvement in this project in any capacity. Any scientists involved in this project must be objective and unbiased. Ramboll Group consultants hired by Denka have a financial interest in the outcome of this project, and it is therefore impossible for them to be objective and unbiased.
• The project must include a statistical power analysis. It would be unethical to undertake a project that lacks the statistical power to find an association between chloroprene exposure and cancer levels where such an association exists. This project must be designed so that any association between exposure and cancer levels could be detected, even a modest association. If a project without the requisite statistical power were undertaken, the probability of a false negative result would be extremely high.
• In its current form, the project replicates key aspects of the UNHR study—for example, LSU students will survey households within a 2.5-kilometer radius of Denka/DuPont. However, to provide us with adequate information about health outcomes in the survey area and their potential link to plant emissions, the project must replicate several additional aspects of the UNHR study:
  • The project must measure residents’ exposure to chloroprene in order to enable a comparison of chloroprene exposure with cancer levels. The UNHR study included a spatial analysis method—using distance from the Denka/DuPont plant as a proxy for exposure—but there are a number of other methods that could be used to estimate exposure as well. The LSU/Tumor Registry project purports to follow up on the UNHR study, but any project that does not include measurement of our exposure to chloroprene is not a study that follows up on the UNHR study.
  • The project must collect and provide information about all cancer diagnoses reported by residents, not just cancer diagnoses from the past 10 years.
  • The project must collect and provide information about all chloroprene-associated health conditions, not just cancer.
  • In addition to providing health data that has been verified with medical records, the project must also provide self-reported health data regardless of whether or not it has been verified with medical records. This is because we have legitimate basis for concern that some medical records of cancer diagnoses in our community might not exist (due to, e.g., hospital shutdowns, loss of medical records in the wake of Hurricane Katrina, etc.).

Finally, we would like to note that our community faces—by far—the highest risk in the country of developing cancer from air pollution due to chloroprene emissions from the Denka facility, according to the EPA’s 2011 and 2014 National Air Toxics Assessments. This information should be more than enough to compel action by state authorities to ensure Denka’s compliance with EPA emissions guidelines. Instead, nearly four years after the EPA first released information about our cancer risk from chloroprene exposure, Denka continues to emit chloroprene at levels that far exceed EPA guidelines. Louisiana state authorities must take immediate action to ensure Denka’s compliance with EPA guidelines.

We look forward to hearing from you about how you plan to address these concerns.

 

Robert Taylor                                                     Mary Hampton

Executive Director                                             President

Concerned Citizens of St. John Parish