It’s bad enough that lead is making headlines everywhere, but now a new group of chemicals is showing up in drinking water across the country – in Portsmouth, NH, Hoosick falls, NY, Scottsdale, AZ, Colorado Springs, CO, Decatur, AL, Bucks County, PA, Cape Cod, MA to name a few places. These chemicals are called perfluorinated compounds, or PFCs and they first generated headlines in the 1990s when they contaminated the drinking water for 70,000 people of Parkersburg, WV where a DuPont plant made teflon and related products for decades. Exposure to these chemicals is linked to developmental delays in children, decreased fertility, increased cholesterol, changes in the immune system, and cancer (prostate, kidney and testicular).
PFCs are quickly becoming the “hot” chemical to look for in drinking water as it seems to be showing up everywhere including places such as the Pease International Tradeport Business and Industrial Center in Portsmouth, NH. In the summer of 2014, the City of Portsmouth reported that two unusual chemicals were found in all three wells that serve the business center as well as the NH Air National Guard Base on the site of the old Pease Air Force Base. The concentration of one of these chemicals – perfluorooctanesulfonic acid (PFOS) – exceeded the USEPA Provisional Health Advisory (PHA) causing the city to immediately shut down the well. PFOS and perfluorooctanoic acid (PFOA) are part of the class of chemicals known as perfluorinated compounds, and they are starting to show up in drinking water wells throughout the country.
PFCs are common in many consumer products, including teflon pans, fabric protectors, pizza boxes and ski wax and it is used to make carpets, clothing, fabrics for furniture. They are also used to fight fires and in a number of industrial processes. At the Pease Air Force Base in Portsmouth, the water became contaminated when firefighters practiced putting out fires on abandoned portions of the airbase using firefighting foams that contained PFCs.
PFOA and PFOS contamination in drinking water is thought to stem from two main sources: factories that formerly manufactured or used the chemicals, and locations, including military bases, where they were used in firefighting foams. According to the EPA, both PFOA and PFOS are found at very low levels in the blood of the general population across the U.S.
Although no one lives at the Tradeport Center, more than 10,000 people work there and there are two day care centers. The people who use the daycare centers immediately formed a Facebook page called “Testing for Pease” and began asking for blood testing for the children. Soon more than 500 adults and children had their blood tested for PFCs and many had levels that were higher than the general population. More blood testing is now underway as the community struggles to make sense of the results and what it means for their future. The health effects of PFCs are not well understood but studies in communities with similar exposures found associations with kidney cancer and testicular cancer. Other concerns includes high cholesterol, immune damage and possible reproductive effects.
In May of this year, the EPA finalized its Health Advisory for PFOA and PFOS lowing its advisory value from 400 and 200 respectively to 70 parts per trillion (ppt) for both compounds combined. This level was based on a lifetime exposure to total PFCs. This change followed criticism from researchers at the Harvard University School of Public Health that the original PHA was not adequately protective of the public. This health advisory is based on long term exposure to PFOA and PFOS in drinking water.
CHEJ has prepared fact sheets on the toxicity of these chemicals and on the how to interpret blood levels. Both were prepared as part of our work with the local residents in Portsmouth, NH.
Don’t hesitate to contact us if you have any questions about PFCs including how to interpret test results.
Tag: EPA
Last week, we asked you on Twitter, Facebook, and through an e-mail to add your voice to an important discussion: what do you want to see from the next EPA administration? The results are in!
- Focus on environmental justice: 58 votes
- More direct efforts to make impactful resolutions: 32 votes
- Responsive leadership: 27 votes
- Transparent decision making: 26 votes
103 people participated in the survey. As you can see, some people put more than one answer– we should expect a lot from the EPA!
The most popular choice was a focus on environmental justice, with about 40% of the vote. It’s clear that the participants in this poll aren’t happy with the approach the EPA is taking towards environmental justice. The next EPA administration must adopt an mode of operation that protects everyone, especially those who need it most.
We’ve seen environmental injustice exemplified in Flint, where the EPA stayed silent, failing the people there who need clean water. It’s time for a new EPA to speak up. As this infographic from The Nation shows, “environmental racism is nothing new.”
More direct efforts to make impactful resolutions, responsive leadership, and transparent decision making all came in at about 20%. All of these qualities are the next EPA administrator must have, and that current administrator Gina McCarthy has often failed to exhibit.
With elections looming, it’s time for politicians– and for all of us– to know what we need from the new EPA for it to be effective in protecting our environment and the people in it. Let’s hold our candidates responsible for their power of appointing the new EPA administrator.
Categories
Funds, cleanups fewer
By Brendan Lyons of the Times Union. The usefulness of the EPA in cleaning up Superfund sites, a creation which often gets credited to Lois Gibbs and is a label for toxic waste removal as a government and corporate responsibility, is severely unfunded. Here’s a look at some of those repercussions.
The 2002 chemical release would haunt the tiny village near Rochester for years. The accidental discharge at the Diaz Chemical plant showered contaminants on the residential neighborhood surrounding the facility, blanketing homes and playgrounds with potentially toxic substances.
A few months later, the U.S. Environmental Protection Agency, which would declare the plant a federal Superfund site, took over responsibility for relocating the occupants of eight homes who fled and refused to return to their residences. It took another nine years for the EPA to settle on a plan to fully clean up the site. Two weeks ago, workers finally began relocating a public water line that runs through the abandoned factory site in Orleans County.
“Anytime you have a time lag like we experienced, it’s always frustrating,” said John W. Kenney Jr., who was mayor of the village of Holley for 10 years beginning in 2006, and a village trustee for three years before that.
A 75-year-old who has lived in the village for more than 50 years, Kenney said it was frustrating that it took so long for the EPA to mobilize its cleanup plan and arrange for the eventual sale of the abandoned residences, which the EPA last week said is “being worked on in preparation to have the eight homes placed back on the real estate market.”
For the embattled EPA, the arguably slow response times to many environmental disasters — some of which cost hundreds of millions of dollars to clean up — may be tied to dwindling funding rather than a lack of urgency.
A trust fund that was set up when President Jimmy Carter signed the 1980 law establishing the federal Superfund program began to run short of cash in the 1990s. The decline came after Congress — and also President George W. Bush during his two terms — repeatedly declined to support renewing a federal tax previously imposed on petroleum and chemical companies, which are often blamed for the nation’s worst environmental disasters.
The “polluter pays” tax, as it’s sometimes called, expired in 1995 and was never restored despite urgings to Congress from every U.S. president since Carter — except the most recent Bush.
Without the money, many Democratic lawmakers say the EPA has been hobbled and fallen behind in its mission to clean up the nation’s most severely polluted sites. In a report to Congress last year, the U.S. Government Accountability Office said that in 2013 roughly 39 million people — 13 percent of the U.S. population — lived within three miles of a federal Superfund site. The report said more than a third of those living near the sites were either under the age of 18 or were 65 years or older. The EPA’s Region 2, which includes New York, had the largest number of people — 10 million, or about one-third of the region’s population — living within a three-mile radius of a federal Superfund site.
Thanks to Brendan Lyons and the Times Union for sharing this story with us.
If you’d like to read the original article, click here.
I don’t know if you noticed, but over the past week and a half, we at CHEJ have been repeatedly asking you, and by extension, your friends, your family, your colleagues, and everyone else you know to call in to the White House and ask for the EPA to ‘Get Out of The Way!’ I’m sure if you’ve called, whether it was once, or every day like myself, you discovered that it was the easiest and most polite call exchange with a government agency that you’ve ever had in your entire life. From my perspective at least, the phone call went something like this:
“Hi, this is the White House Comment Line. All our lines are busy right now, but if you’d like to stay on the line, someone will accept your call and record a quick comment….”
…Music plays while I’m put on hold for less than ten seconds…
Which is kind of boring and bureaucratic-sounding, right? Until a sweet old lady answers your call and sincerely listens to whatever it is you’re trying to say!
“Hello?”
“Hi! My name is Zoe Hall and I am a citizen of St. Louis calling on behalf of the citizens of Bridgeton, Missouri. I think the EPA needs to get out of the way and push for the FUSRAP to pass so the Army Corps of Engineers can clean up the West Lake Landfill. I would also like the president to see what he can do about relocation for the citizens within a mile of the landfill. This is a really pressing issue and I hope you see to it the president finds out how concerned I am.”
Eventually, by the last Tuesday of our push for calls, the conversation ended like this:
“Sure sweetie, are you referring to HR-4100?”
Which is the House of Representatives bill 4100 pushing for FURSAP. The instant recognition of the exact issue we are pushing for indicates that the White House Comment Line has gotten such an influx of calls concerning West Lake that they have to have a code for it to easily identify and tally up all of our voices united in our outrage. This is a huge deal –– this list of codes and top concerns of the nation gets forwarded to the White House Staff in order to keep our president updated on the issues we as his constituents are focused on. That means our president has in his possession a lengthy list of people’s names and outcries for change. What he does next is out of our hands, but at least, now aware of our concern, he is accountable for whatever that may be! In itself, I consider this a victory.
Whether or not you participated in the call in, everyone can learn from the power this provided to the citizens at West Lake and anyone who wants to organize a simple, empowering action that is not only easy to do (it takes five minutes!) but is also one that gets results. Remain persistent and focused, keep your goals clear, and use the power given to we the people to raise your voice as loud as possible, so that one of the most powerful people in the world might hear.
I’d be outraged. This is a real life situation. It took eight years for water results to be analyzed and reviewed by the federal public health agency for a small Pennsylvania community. They concluded that drinking water was not safe to drink; and that the agency has no information about water contaminates from 2011 through 2016.
Is it safe now? Although samples were taken over the eight-year period, no one knows. The federal health scientists have never seen those results. Even if they did, it might take another eight years to get the results — that would be 2024.
This is terrible . . . right? Unfortunately, it actually gets worse. The state health scientists said that same water was safe to drink, as did the federal Environmental Protection Agency (EPA) after reviewing the same sample results. . . . yet the water was poisoned. It is unknown how many people mixed baby formula or bathed their young children in this toxic water.
I looked into why now, in May, 2016, did the federal Agency on Toxic Substance Disease Registry (ATSDR) release a report concluding the water was unsafe to drink. I found a recent news story that announced that the victim’s lawsuit against the polluter was recently settled in court. This settlement, in Dimock, Pennsylvania against Cabot Oil & Gas was the only change in the situation. Although I could be wrong, my conclusion was that the agency decided not to get involved in the messy trial of a multinational corporation. Instead, allowed a community to be poisoned. If that’s true, then I have no confidence nor hope that the American people are protected by their own public health government agency. In fact, it reaffirms for me that our public health protections are controlled by polluters and their lawyers.
Families, young children, and women of childbearing age drank toxic water with false assurances of safety from the very agencies charged to protect them. What is the public supposed to do? Whom can they trust? Why can’t our health authorities act in the best interest of public health of the American people who pay for their services through our tax dollars?
For the past thirty five years, I’ve watched the criteria for health assessments go from the preponderance of evidence (collection of all relevant studies, their quality, sources and conclusions) to obscure abstract mathematical assessments. In the past five years, it’s gotten worse. When results are undeniably harmful to public health, even using this abstract model, the results are held from the public, with agencies utilizing “draft” as reasons for not releasing reports to the public. All this time, health professionals know people are being exposed to unnecessary, and in some cases, avoidable health risks. You need not look any further than what is still happening in Flint, Michigan with their drinking water to understand this problem.
The jury’s verdict on water contamination in Dimock may have broad implications for the broader debate about the environmental risks of the shale drilling rush nationwide. Although the case did not center on claims that the fracking process (as opposed to drilling, well casing failures, spills or other problems) had directly caused the water contamination, most of the gas wells that the plaintiffs focused their attention on were aimed at the Marcellus shale gas formation.
Kassie Siegel, director of the Center for Biological Diversity’s Climate Law Institute, commented, “This is a huge victory for the people of Dimock, but it’s also a sharp rebuke to the Obama administration for failing to fully investigate threats posed by fracking and dangerous drilling to water supplies in Pennsylvania and across the country. Because of the EPA’s disturbing history of delay and denial, it took a federal jury to set the record straight about the natural gas industry’s toxic threat to our water.”
America, what in the world are we going to do? I’d love to hear ideas because I don’t feel safe nor should you. Send any comment you might have to me at infor@chej.org.
Categories
TSCA Reform: Is It Enough?
On Tuesday in a vote of 403-12 the U.S. House of Representatives passed a bill to update the Toxic Substances Control Act of 1976 (TSCA). The Frank R. Lautenberg Chemical Safety for the 21st Century Act, named after a former democratic senator from New Jersey who dedicated much of his life to TSCA reform, is a “compromise bill” designed to appease industry and environmental groups alike. The bill is also a compromise between the House and the Senate who came up with separate TSCA reform bills and were forced to combine them. The Senate’s vote is still pending, and will likely happen in the next few weeks. White House correspondents have said President Obama supports the bill and will sign it into law pending its passing in the Senate.
The original TSCA was meant as a way for EPA to evaluate the toxicity of chemicals and regulate them if they posed a threat to human or environmental health. However, TSCA is full of holes and red tape that have actually made it more difficult for EPA to regulate chemicals. The 1976 TSCA does not require industry to get safety approval before beginning the sale of a product and only allows EPA a certain amount of time to evaluate the product. Additionally, a counterintuitive measure of TSCA required EPA to provide proof of potential harm for a chemical before beginning to evaluate the harmfulness of the chemical. Worst of all, the original TSCA legislation required the EPA to consider the cost of enforcing regulations when evaluating chemicals. These restrictions meant that EPA could not or did not take sufficient regulatory action, and when it did, courts used TSCA to overturn their rules (including the asbestos regulations). Consequently, only about 200 chemicals have been evaluated since TSCA first passed, while the New York Times estimates about 64,000 chemicals are currently left unregulated.
The current TSCA reform bill aims to address the problems in the 1976 law. It requires EPA to test chemicals regularly, working on 20 chemical reviews at one time. It also ensures that EPA focus on chemicals that are more likely to harm vulnerable populations (children, workers, pregnant women, low income communities) and chemicals that could easily pollute drinking water. EPA will evaluate what it perceives as the most dangerous chemicals first, but industry can pay to have their chemicals evaluated out of order (useful if they want to begin selling new products). Industry will also contribute $25 million total each year to help fund the EPA evaluations. The rest of the funding will come from federal allocation of the budget. Finally, the TSCA reform bill also includes a requirement to find ways to reduce animal testing and a requirement to evaluate chemicals linked to cancer clusters (see Trevor’s Law).
However, despite the numerous improvements to TSCA, the reform bill is also somewhat problematic. The section that most concerns environmental activists and other critics explains that EPA regulations will preempt those set by states. While any state regulations enacted on or before April 22 will be upheld, EPA regulations will apply to chemicals evaluated after April 22nd. Proponents of the bill argue that this section addresses the patchwork of enforcement by state and that it will improve interstate commerce. However, this could mean that states with traditionally strict chemical safety measures like California could see their regulations watered down. States are permitted to request waivers from EPA, but EPA takes full responsibility for the nationwide evaluation of chemicals, even blocking states from continuing to evaluate chemicals the EPA is researching. This statute gives EPA an enormous amount of power, even allowing EPA to control our exposure levels. Even now EPA allows for higher exposure levels of some chemicals than do states. Are we sure we’re ready to trust them so completely? Federal safeguards such as those preventing chemical exposure should be a minimum, not a maximum. Or as Senator Bernie Sanders (D-VT) said when asked about the bill, “[F]ederal chemical regulations should be a floor, not a ceiling.” EPA should set the standards, but states should be free to make them more stringent in order to better protect the health of their residents.
I suspect that many of you watched in amazement as President Barack Obama drank a sip of tap water while visiting Flint, MI earlier this month and told everyone that it’s OK. Sorry, Mr. President, but all’s not well in Flint. This publicity stunt is a slap in the face to so many people. Not only have thousands of people including young children and infants already been exposed to toxic levels of lead and other contaminants that will affect their health for years, but thousands of people in Flint are still drinking and using contaminated water.
Dr. Marc Edwards, a professor of engineering at Virginia Tech who has done an enormous amount of water testing in Flint released the latest testing results in April several weeks before Obama’s visit. These results showed lower levels of lead in the water, but lead levels were still above the action level set by Obama’s EPA. In a press release, Edwards stated that “People have to continue using bottled water and filters until further notice.” Furthermore, no one is testing the water for volatile organic compounds like trihalomethanes (THM), contaminants that result from adding chlorine to kill bacteria. Early in the Flint crisis, THMs and bacteria levels were found to be high, but once elevated lead was found in the water, testing for THMs and bacteria stopped.
Be clear, Obama’s publicity stunt was not about public health. It was not about good science or testing results that show that the water is safe to drink. Instead, it was about reassuring the public that all is well in Flint and that the government has everything under control. It was about avoiding taking responsibility and not holding those at the highest levels of government accountable for the mistakes that led to the disaster in Flint. It was about controlling the media and trying to convince the media to move on to the next hot button issue. If this succeeds, then we can expect to see more Flints in the future, because we will not have learned anything from this public health disaster.
While the situation in Flint, Michigan has deservedly garnered much of the American public’s attention, it is important to recognize that it is just one example of many minority and low-income communities around the country that are living in a toxic environment. Rural North Carolina is another community that has seen its leaders fail to protect the most disadvantaged citizens, in this case, from the toxic pollution associated with the many hog farms in the region. African American and Native American communities in this region have been dealing with the toxic conditions for decades, since North Carolina saw a boom in the number of concentrated animal feeding operations, commonly known as CAFOs, in the 1980s and 1990s.
These feeding operations, that allow hog farmers to produce thousands of hogs for slaughter on a single farm, also produce millions of tons of waste, pathogens, antibiotic-resistant bacteria, and debilitating odors that damage the health and well-being of the minority families that overwhelmingly makeup the neighborhoods that surround them. As an example of how impactful these CAFOs can be, one 80,000-head facility produced 1.5 times the amount of waste generated by the City of Philadelphia in a single year. Yet, these hog producers lack all of the chemical and mechanical filtration systems that are required to treat human sewage. Instead, waste from these operations end up in unlined and untreated lagoons that leach into groundwater and can even rupture and spill their contents into surrounding landscapes and waterways. In addition, the noxious odors that are generated by CAFOs have also been found to cause respiratory problems, eye irritation, and even high blood pressure among individuals living nearby.
Because the development of this type of farming happened so fast in North Carolina, lawmakers have failed to keep up in implementing the necessary policies and regulations to protect the health of its citizens and environment. Particularly troubling is that despite the fact that CAFOs result in localized health problems, state and local health agencies do not have any authority in regulating them. Instead, natural resource agencies, whose mission is not to protect human health, are left with the responsibility.
While some progress has been made in recent years to improve technology, nearby residents are still struggling with horrible living conditions. This has resulted in a recent complaint filed by the University of North Carolina and Earthjustice in 2014 with the state’s Environmental Protection Agency. The complaint was filed under Title VI of the Civil Rights Act, which says that recipients of federal funds must prevent harm to communities or individuals based on race. Negotiations between community groups and regulators fell apart when regulators invited pork industry representatives to participate in negotiations. This left many community members with the impression that state leaders cared less about the health of its disadvantaged citizens, and instead was looking out for the interests of the pork industry. And much like the U.S. EPA failed to act in order to protect the citizens of Flint, they have also yet to intervene and do an investigation to improve the situation in North Carolina and other regions plagued by the negative effects of CAFOs.
This is just one of many examples of environmental injustice that shows us that if there is pollution generated from industry, or in this case, from the production of our food, it is overwhelmingly impacting the most disadvantaged in our society. We need to make the connection between the atrocities that are occurring in Flint, with the similar injustices that are experienced in North Carolina and all across the country and we need to call on our leaders to do a better job of promoting clean and healthy communities for all its citizens.
To learn more about the effects of hog farming, check out this paper by Environmental Health Perspectives
Categories
I’ve Got Your Back, Really?
I can’t believe that President Obama drank a sip of water from Flint. It was a slap in the face to so many people. His own agency was responsible for not raising the alarms when EPA received data that said the water was poisoned. Obama has done a number of extraordinary things while in office. Yes, I voted for him and yes, I’d likely do it again. I’m stunned. What in the world could Obama have been thinking when he drank that water? Of course there is no way his water was toxic from chemicals, viruses or bacteria let alone lead. Further dismissing the crisis, he said he likely eat lead paint chips as a child. Really? That dismissal brings no comfort to the parents of lead poisoned children who will never reach their birth potential and are sick. I can’t help but wonder if Gina McCarthy orchestrated that news event.
Obama’s person in charge, Gina McCarthy, EPA Administrator has ignored literally all but one division of EPA’s programs and responsibility including drinking water. The one exception since she was confirmed in July 2013 is climate change. Remember the January 2014 West Virginia Elk River spill that poisoned the drinking water of 300,000 people. Drinking water in schools, hospitals, family homes with pregnant women and small children were exposed to toxic chemicals resulting in serious health impacts. The company responsible had not been inspected by EPA since 1991. You would think that McCarthy’s EPA would monitor the site after the spill but they didn’t. Seven months later, in June 2014, another spill from the same company occurred from a sump pump malfunction into the same Elk River.
Then in February 2014 there was the Dan River coal ash spill that poisoned the river from Virginia to North Carolina. For a week a pipe poured arsenic and other heavy metals 140,000 tons of toxic waste and wastewater directly into the river. Ash was found on the bottom of the river for 70 miles and as much as 5 feet deep in places.
Today, the question of what to do with coal ash wastes is still a problem especially for low income communities. EPA is behind the proposal to dump it in garbage landfills in mostly low wealth, rural, communities of color. Gina McCarthy supports this proposal but the US Commission on Civil Rights is investigating the fairness of the plan.
The Colorado Animas River spill was solely the fault of EPA’s lack of careful attention. It was EPA that accidentally released an estimate of three million gallons of waste water into the river in August 2015. This river supplies drinking water to area residents. EPA authorities knew about the risk through a June 2014 work order that read “Conditions may exist that could result in a blowout of the blockages and cause a release of large volumes of contaminated mine waters and sediment from inside the mine, which contain concentrated heavy metals” and through a May 2015 action plan for the mine that also noted “the potential for a blowout.” People living along the Animas and San Juan rivers were advised to have their water tested before using it for cooking, drinking, or bathing. The spill also caused major problems for farmers and ranchers who rely on the rivers for their livelihoods.
The next crisis is likely in St Louis, MO. An underground fire from one old dump site is creeping towards the adjunct radioactive site. When the fire reaches the radioactive materials the state’s Attorney General’s experts say there could be a Chernobyl like event. This possible crisis can be taken care and avoided but McCarthy is not acting. Saying you are sorry and accepting the resignation of staff is not how to run an agency.
McCarthy has hurt so many innocent American people and the reputation of the agency is questionable. I don’t know if EPA can ever recover. Her advice to the President should have been, say you’re sorry, don’t act like me, an incompetent leader and declare the situation what it is a disaster. Then bring in the troops to change the pipes so everyone can be sure their water is safe.
The fiasco in Flint, MI has forced an important change in EPA’s recommended protocols for testing lead in drinking water. In a memo to state health and water administrators issued February 29, 2016, the US EPA reversed its prior recommendations on how to sample drinking water targeted for lead testing. The new protocols are as follows:
- Do not remove or clean faucet aerators prior to collecting samples
- Do not pre-flush prior to sampling
- Use wide mouth sample bottles to allow water flow to enter at a rate similar to what consumers might use when pouring a glass of water to drink
In the past, EPA‘s advice was to pre-clean the aerator, flush pipes prior to sampling, and open the tap slowly and sample at low flow. Using these guidelines results in less particulate lead getting into the sample and thus finding lower lead concentrations in the water. Removing or cleaning an aerator prior to testing masks the added contribution of lead at the tap that results from the lead in the aerator. Flushing the pipe prior to sampling eliminates the lead that has built up overnight or since the last time the faucet was used. Pouring the water slowly, whether by using a narrow container or by just opening the tap slowly, also reduces particulate lead that gets into the water by not disturbing lead present in the pipe as much as a normal flush would. These inaccurate procedures were called to task by Dr. Marc Edwards from Virginia Tech University who found high levels of lead in the drinking water in Flint, MI.
Despite the fact that this is not what people typically do when they pour a glass of water from the sink to drink, these are the sampling procedures that EPA has been advocating for years and what water companies have been using for years to measure lead in drinking water. By using these procedures, water companies everywhere, not just in Flint, are not accurately measuring the lead concentration in drinking water, and they are potentially missing a significant portion of the lead actually in the drinking water systems. Doing this provides a false sense of security that seriously endangers public health.
Although EPA has issued these new guidelines, there’s no guarantee that water companies around the country have switched to the new sampling procedures. If you’re concerned about the lead levels in your water, find out what sampling procedures are being used because it makes a huge difference. While we can thank the public attention given to the disaster in Flint for this critically important change, now we need to make sure that testing agencies across the country follow this new protocol. Contact CHEJ at info@chej.org to obtain a copy of this important memo.