More Testing Issues - Using the Wrong Research

this page under review

Yesterday we at last received a reply from the Department of Health (DoH) regarding not-so-recent inquiries we had made into the estimates for tolerable daily intake (TDI) of antimony reported on the Community Information website; the ‘safe’ daily amount. 

We sent this information and our questions to a DoH Officer familiar with Costerfield in August. We waited three weeks for a reply. The message that we eventually received advised us that the officer was going on holidays for two weeks and would get back to us then (!)… That’s more than two weeks ago.

Yesterday we eventually received the patronising reply transcribed below.

Just in time, too! Testing starts Monday, 6 October 2014.

We are far from satisfied by this wholly inadequate response and so will take up the issue again here.

So to clarify, while this reply is ostensibly from the Department of Health, it is in fact a reply from Golder Associates, but we’ve become used to speaking to people other than the Department of Health about Health Issues by now.

We can only assume that the Department’s officer isn’t familiar with the TDI calculation himself, so he called in the all-purpose consultants for advice...

From, ahem, the DoH, then:

Please forgive the delay in getting back to you
I have been in contact with John Frangos from Golders and please find below his response

1.        Intake Calculation

Intake can be expressed in two ways; as a unit body weight dose or as a mass per person.  
The WHO (page 9) description is of a drinking water concentration.  
The intake is different.  
Below you will find a step by step explanation of the difference.
Calculation of a Drinking Water Guideline

Where:

Item	Units	Description
DWG	micrograms per litre (µg/L)	Drinking water guideline expressed as a concentration in water.  This is not an intake however the calculation is based on an intake.
Safe intake or tolerable daily intake	micrograms per kilogram bodyweight	This is a lifetime average daily dose that should not cause adverse health effects within the general population.
Body weight	kilograms	Mass of an individual.  For standard setting purposes the WHO use 60 kilograms as they are interested in global average bodyweight of adults.  In Australia we use 70 kilograms given that the average body weight of an Australian is closer to 80 kg than 60 kg.
Proportion TDI to DWG	Proportion	This is the proportion of the TDI allocated to drinking water.  The TDI is for all sources of exposure.  For this reason only a proportion is allocated to Drinking Water.

For antimony the WHO Drinking Water Guideline is calculated as follows:
                                                     

 

= 18 µg/L (rounded to 20)

 

Calculation of a daily intake per unit body weight:
Intake = mass of compound (milligram or microgram per day) ÷ bodyweight (kg)
Example:  The antimony TDI is 6 micrograms per kilogram (µg/kg).  

Calculation of a daily intake per person:
Intake (person) = mass of compound (milligram or microgram per day) x body weight of person.
Example:  If we assume the bodyweight of an adult is 70 kilograms then the TDI can be expressed as
6 µg/kg x 70 = 420 µg per 70 kilogram adult per day  

***

Now our questions actually relate to the applicability of the WHO’s Antimony in Drinking Water guidelines that we became familiar with earlier. We know that Golder Associates, DSDBI and now DoH, are employing this document to inform the “next phase of testing”. The above reply, and the rapid response we received from DSDBI this morning confirm this. And it underlies the information given to the Costerfield Community on the DoH website.

According to the recent Community Antimony Fact Sheet on the Department of Health website:

The World Health Organization has calculated a safe level of antimony that a person can take into the body every day over a lifetime. This value has been determined from studies in animals with conservative safety factors applied to protect human health. This acceptable daily intake is 6 micrograms/kg body weight/day.

An adult weighing 70kg can take into their body 420 micrograms of antimony per day without effect. A one year old child weighing 10kg can take into their body 60 micrograms of antimony per day without effect.

The World Health Organization’s Antimony in Drinking Water has this to say about the estimation of a total daily intake of 6 micrograms per kilogram per day. We are familiar with this document from other discussions. You’ll recognise the paragraph at the end…

The most common source of antimony in drinking-water appears to be dissolution from metal plumbing and fittings. The form of antimony in drinking-water is a key determinant of its toxicity, and it would appear that antimony leached from antimony-containing materials would be in the form of the antimony(V) oxo-anion, which is the less toxic form. It is therefore critical that the study selected for guideline derivation be a drinking-water study.

[Emphasis added.]

The suggested NOAEL (Lynch et al., 1999) in the subchronic drinking-water study in rats conducted by Poon et al. (1998) was 6.0 mg/kg of body weight per day based on decreased body weight gain and reduced food and water intake. A TDI of 6 μg/kg of body weight can be determined by applying an uncertainty factor of 1000 (100 for intra- and interspecies variation and 10 for the use of a subchronic study). A guideline value of 20 μg/litre (rounded figure) can be derived from this TDI by assuming a 60-kg adult drinking 2 litres of water per day and allocating 10% of the TDI to drinking-water. It should be noted that this value could be highly conservative because of the nature of the end-points and the large uncertainty factor; further data could result in a lower uncertainty factor.

[Emphasis added to indicate the “conservative safety factors applied to protect human health” noted by the DoH.]

There are adequate analytical methods for antimony in drinking-water with detection limits below the guideline value. As the most common source of antimony in drinking-water appears to be dissolution from metal plumbing and fittings, control of antimony from such sources would be by product control. At one time, antimony was suggested as a possible replacement for lead in solders, but there is no evidence that this has occurred. Antimony is not removed from water by conventional treatment processes (EUREAU, 1994). Control would therefore be by source selection or dilution.

The possibility of co-exposure of consumers to arsenic and antimony in drinking-water would necessitate an assessment of the local geological conditions on a case-by-case basis. If both elements were found to be present, case-specific risk evaluations for possible additivity and synergistic effects would need to be performed.

The WHO then, bases its TDI on the assumption of exposure to antimony(V) oxo-anion, which is most commonly sourced “from metal plumbing and fittings”. Earlier in the WHO document (p. 8) it is stated that:

In general antimony(III) is more toxic than antimony(V), and the inorganic compounds are more toxic than the organic compounds (Stemmer, 1976) with stibin (SbH3), a lipophilic gas, being most toxic (by inhalation).

Now one would assume that, given that antimony(III) is more toxic than antimony(V) as per page 1 of Antimony in Drinking Water:

Soluble pentavalent antimony (antimony(V)) compounds (sodium stibogluconate, stibosamine) are used as specific therapeutics against different forms of leishmaniasis and are physiologically tolerated more than trivalent antimony (antimony(III)) compounds (Winship, 1987).

and since we are not dealing with the leaching of antimony(V) from plumbing and fittings, then the Department’s estimate of 6 micrograms per kg of body weight per day would very much appear to be an over-estimate of the TDI for antimony(III).

The critical antimony species involved at Costerfield are cationic (positive) ions of inorganic compounds derived from the ore body components. They are definitely not the anionic (negative) antimony oxo species the WHO used to determine its guidelines. Our expert advice tells us that these antimony cations are not only more soluble (in water), they are more mobile through the soil profile, [this runs counter to the nebulous Sim/Priestly report on this point] and as a consequence are far more toxic to mammalian species.

The WHO data related to organic forms of antimony (and any derived data based on organic antimony forms of "lesser" toxicity), has absolutely no applicability to the Costerfield scenario. A very pertinent fact that it seems DoH, DSDBI and Golder are simply choosing to ignore .

(There is also absolutely no doubt whatsoever that arsenic (As) species do occur along with antimony at Costerfield [and there are a number of other cationic inorganic species present at concern levels, too]. Given these major pathways of toxicity, cumulative exposures MUST be considered for all toxic species present. It is an absolutely essential requirement that ALL of the major toxic cationic species be so determined, collectively. )    

It is our understanding that the only directly applicable antimony toxicity data is that published by

US ATSDR and US EPA which is clearly far more pertinent to Costerfield, and, it should be noted, far more damning of the actual situation in light of the actual concentrations of metals in the soil and water in Costerfield.

You see, the Community has already undertaken testing of its own. Long before the Regulators or their hired consultants arrived on the scene. We had to. It took from March until May for the DoH and DSDBI to even front the Costerfield Community to announce a “rapid assessment” was beginning. We still laugh at the irony.

It’s all well and good referring to a drinking water study when it’s the drinking water system that’s under examination – note this WHO document comes from a collection of Sanitation documents. And the World Health Organization cautions against making this very mistake by stating: “It is therefore critical that the study selected for guideline derivation be a drinking-water study” …. because its own guidelines are for antimony(V).

But that is simply not the case in Costerfield. This is not a drinking water study. Here we are looking at contamination of the people of Costerfield and their water tanks by environmental antimony, much of which would be the “more toxic” inorganic antimony and antimony(III) compounds.

The report into Costerfield by Professors Priestly and Sims for the DoH notes at page 21:

The soil bioavailability studies of Flynn et al (2003) and Gal et al (2007) although limited to studies of leaching and/or ecotoxicology, but not mammalian toxicity, suggested that Sb mobility and bioavailabilty from contaminated soils is extremely limited, so this is unlikely to be a major contributor to absorption in the Costerfield region. [Emphasis added.]

They are also very careful to avoid giving a TDI for antimony. This from their report’s terms of reference (p. 23):

Is there evidence of modelling or kinetic studies that have used intake to estimate a urinary antimony level? If not, can a urinary Sb threshold be derived from intake (in the order of TDI) calculations?

While some of the published papers have estimated intakes and compared them with putative health-based guidelines, no studies were identified that calculated a urinary excretion profile based on these intakes. In fact, some papers (Gebel, 1998, a, b) noted a poor correlation between soil or airborne antimony concentrations and measured urinary outputs.

Nevertheless the authors of the information being provided to Costerfield residents saw fit to declare a TDI. Except they are using the wrong form of antimony!

We'll say that again: the Department of Health is providing residents of Costerfield with misinformation regarding the safe levels of antimony they may ingest because it is using for its terms of reference the incorrect form of antimony - antimony(V) - and thus the wrong guidelines.

Unfortunately we are coming to expect misinformation by now.

The experts brought in by the Department think that “Sb mobility and bioavailability of contaminated soils is extremely limited, so this is unlikely to be a major contributor to absorption in the Costerfield region”. And unlike the Department of Health and the Golder Associates testers - who have “estimated intakes and compared them with putative health-based guidelines” – they aren’t prepared to put a safe threshold “in the order of a TDI” on the safe levels of antimony ingestion.

Yet the Community Antimony Fact Sheet provides Costerfield residents with what it deems to be a safe amount of antimony for ingestion – 420 micrograms/day.

Why does the government website contain potentially dangerous misinformation for the people of Costerfield? 

Is it because to admit that the antimony that needs to be tested for is of the type found in industrial processes would confirm the mine as a source... and that the regulators haven't done their jobs...?

What is the Department of Health’s

– or the DSDBI's or whoever is looking after Health this week –

response to the above observations?

A little summary:

• ·        The antimony in the water tanks isn’t going to be from the plumbing. Or fittings.
• ·        And it’s “unlikely” to be from the soils according to Profs. Priestly and Sim.
• ·        And particulate monitoring ceased at Costerfield on 13 February, 2006.
• ·        And the 2007 EPA SEPP AQM recommends that attention be paid to the possible entry of    heavy metals “such as antimony” in drinking water tanks near mines.
• ·        In 2013/4 two vents were installed at the mine to deal with its expanded operations into the Cuffley Lode; 3m vents that exhaust at up to 12/ms into the Costerfield atmosphere.
• ·        And high antimony levels were taken from people at a distance from the mine.
• ·        And particulates are not detected in these pieces of junk.
• ·        And particulates can be concentrated further from their source because of uplift.

 What do YOU think caused the high antimony readings in and around Costerfield?

We’ll ask the question we asked the other day again here - we are still to receive a reply:

How much material – antimony, arsenic, respirable silica, blasting detritus “including CO₂, CO, SO₂, NO_X and ammonia gases (NH₄)” - does EPA/DSDBI estimate has been emitted by the mine via its vents over the past eight years?  

***

According to the Commonwealth Government’s Department of Environment’s “National Pollution Inventory” antimony emissions in Australia fell from 16,000 kg in 2008/9 to 7,700 kg in 2012/13.

Do these figure need to be revised?

Stage 2 Golder Issues

We commit to making any response from the Government available on the blog immediately.

And we do so in order to encourage open disclosure and a responsible and accountable Government and its regulatory authorities.

Golder are only testing for 8 metals? When how many can be tested for? SHOULD BE TESTED FOR. 

The Costerfield Community itself has undertaken testing for 32 elements!

Entrenching scientific uncertainty in the process again... still...

Here is our latest email to those responsible for this debacle.

Dear Kylie,

I am deeply concerned with DSDBI’s email which has been sent out  to allegedly "inform” residents of the Golder “Stage Two Work” at Costerfield.

A suite of ‘eight undisclosed elements’ is neither sufficient nor appropriate to assess the many and varied risks that exist for the Costerfield and Heathcote communities from both past and present operations of the Costerfield mine.

Whilst I realise this mine consistently uses a “short” list of elements for its own commercial reasons, it is simply not good enough for the government contracted consultants hired by the primary Regulator to also be using a similar list!

This “short list” does not include other “heavy metals” known to exist at concern levels in soil and water in the vicinity of the mine and its dust-deposition and waste water disposal areas.

   

Any new soil testing program must also include vanadium levels across this region as the US ATSDR has a Chronic Inhalation Level for Vanadium of 0.0001 mg/m³ and values around the mine have often been measured at levels of 120 mg/kg level (1.2 million times the inhalation level maximum).

Then there are the titanium levels problems which are often in the region of 4,000+ mg/kg; ATSDR has an Inhalation Level of 0.00008 mg/m³ (50 million times the inhalation level maximum).

[red text: these are erroneous figures. Inhalation figures cannot be calculated from soil figures quite so neatly.]

No speciation work has been undertaken to date for these two elements to establish what form they exist in but they certainly require urgent investigation; it is crucially noteworthy that the Golder Phase Two work will not cover these elements since it is limited to only eight elements!

Whilst the mine has provided superficial data for only two months regarding the content of dust moving offsite, e.g., (antimony, arsenic and silicon), there are many other dangerous elements known to exist in this ore stream.

Despite all of the historical data for mercury use on this site to recover gold, Golder have not even bothered to include this Internationally controlled highly toxic element in their work. This failure by Golder is of particular concern since random surface tests on an historical tailings dump outside the mine site has shown average mercury readings of 10 mg/kg – and children presently play on this particular dump!

US ATSDR has a Chronic Inhalation Level for mercury of 0.0002 mg/m³ (Neurological damage).  10 mg/kg mercury converts to 82 mg/m³ in the air or enough mercury to take 27,347 m³ of air to the ATSDR limit of 0.0002 mg/m³, (which would cover 1.36 Ha to a height of 2 meters). 

It is a pity that the DSDBI chosen consultant did not have the data from the first part of the project to pick up on this issue.

Arsenic Pentoxide (the major form of arsenic found at the mine), is now on the PAN International list of Hazardous Pesticides (CAS number 1303-28-2); is Golder now going to include this issue, as a consequence?

Next  there are the issues with Lead Nitrate, used as a flocculant on site (“production additive” in mine speak) which is a Class 6 Toxic, Class 5.1 Oxidising Agent, soluble in water, is categorised as ‘probably carcinogenic to humans’ by the IARC. Consequently, it must be handled and stored with the appropriate safety precautions to prevent inhalation, ingestion and skin contact. Due to its hazardous nature, the limited applications of Lead(II) Nitrate are under constant scrutiny. Lead Nitrate is suspected of causing neurological impairment in children and may cause harm to an unborn child, and a possible risk of causing infertility; 

Next, Sodium Dibutyl Dithiophosphate, an organophosphate of similar toxicity to many globally banned pesticides, Class 8 Dangerous Goods, Hazchem 2R – decomposes to sodium hydroxide or hydrogen sulphide, pH of 13; Endocrine Inhibitor.

If the Golder scope of work had been circulated outside of the agencies which have all had a hand in the ‘regulatory failures’ at this mine, then you would have undoubtedly ended up with a scope of work that was ‘much better informed’, particularly from overseas experience with this type of mine and the suite of toxic substances that can be expected in these ore bodies and historical tailings piles.

I was pleased to see that John Mitas has today, finally, clearly articulated  “risk evaluation for possible additivity and synergistic effects”. I look forward to a full disclosure of Golders proposed methodology to carry out this evaluation.

The usual starting point for this type of evaluation is to carry out the basic hazard index (Nordberg et al) work that is routine even in the Third World these days, but for some reason was not carried out in the first part of the Golder work.

We have just completed XRF retesting many of the Costerfield samples previously collected and have compared these results with ICP-MS data with very high correlation demonstrated between these two analytical procedures.

There are in fact 32 elements of interest in the soils and tailings dumps around the extremity of the operational mine and Golder is only going to test for 8!

In short, it is neither acceptable nor scientifically robust, for the base suite of eight elements the mine tests for, to be adopted as the sole basis for the so called "independent study”!

If you don’t look, then you certainly won’t find these problem areas.  But then, by following this myopic undertaking you can’t then be said to be held accountable for what really exists as substances at concern levels existing in this environment! 

Such a move by Golder and the various supporting government departments would not be excusable for any ensuing pending legal actions resulting from confirmation of these broader and highly predictable contaminants impacting residents, tourists, animals or the environment.   

I therefore respectfully suggest that the Golder scope of work be expanded to include the full suite of potentially toxic elements  – this will actually save money for the Government because the standard 17 elements by ICP-Ms (and cold vapour AAS for the mercury) will not have to be ‘trimmed’ down manually to just the chosen 8 elements and Golder can save labour by just publishing the laboratory results as supplied by the Laboratory.

Kylie, I look forward to your prompt response to these critical issues.

I am in the city tomorrow if you want to discuss this face to face.

Regards

Andrew Helps

Managing Director   Hg Recoveries Pty Ltd  ACN 144 752 885

Level 13, 350 Collins Street Melbourne Vic 3000

A member of the UNEP Global Mercury Partnership

Partnership Areas: Mercury in Gold Mining,

Mercury Air Transport and Fate, Mercury in Products,

Mercury Waste Management, Mercury Supply and Storage

Heavy Metal Specialists

Face-to-face with Andrew would be good; upfront, honest and forthright communication with the Costerfield Community via the email forum would be even better. We have led the way, have we not?

We commit to making any response from the Government available on the blog immediately.

And we do so in order to encourage open disclosure and a responsible and accountable government and its regulatory authorities.

 

100km/h Winds in Costerfield

(Important Update: At the bottom of this page we asked the Departments concerned a very important question.

To their credit they were rapid in their response and replied as follows:

I can confirm that we are aware of the WHO recommendation highlighted in your email.
 
“The possibility of co-exposure of consumers to arsenic and antimony in drinking water would necessitate an assessment of the local geological conditions on a case-by case basis. If both elements were found to be present, case-specific risk evaluations for possible additivity and synergistic effects would need to be performed”
 
I can confirm that the Golder work program developed in consultation with DSDBI, DoH, EPA and DEPI  includes assessment of local geological conditions, and assessment of arsenic in water.  I also can confirm that we are testing 8 metals in water, soil, air, sheep and eggs.   These include arsenic and antimony.  This data is being collected to assess the cumulative risk to residents.  That is the risk posed by the metals in combination with the other metals.  As recommended by the WHO this will include risk evaluation for possible additivity and synergistic effects. *

(*Edit 20 August 2015: these synergistic/additive results are still to be provided to the community)
 
We welcome this open exchange of information and hope that it bodes well for future, further inclusion of the Costerfield Community in the health issues that surround their beautiful town.

Nevertheless, some serious issues are still posed by the other material we present on this page - and indeed by the response from the Department; we deal with these issues here and here - therefore we have left it here to keep the very important unanswered questions posed, and to accommodate further information that will be forthcoming soon. And so...)


We’ve seen this document before:

From the Mandalay ERC Minutes, 21 November, 2007:

6 Quarterly Environmental Monitoring Report

6.2 Air Quality & Dust

DISCUSSION

Visible dust from the mine

[Local resident] B** asked what about the possibility of uplift dust over one location to a more distant location.

Colin Burns [AGD] stated that this can happen with respirable dust but not with deposited dust which is relatively course.

B** stated that dust from the mine is visible when he has walked down to the mine on several occasions.

Colin Burns stated that dust seen by B** is suspended dust and much finer than deposited dust. Suspended dust can be at a higher concentration further from the source but this is not the case with deposited dust.

And we saw this quote in the same piece:

Department of Health Senior Medical Adviser Dr Danny Csutoros in the McIvor Times on 13 August, 2014:

"We had a couple of samples that didn't make sense - a couple of people who were way out of the area with high antimony."

 Oh, and this from the 2003 Workplan for Underground Mining 4200/5380:

Mine exhaust air will be discharged from at least one ventilation rise into the atmosphere. Exhaust air will contain particulates in the form of dust, blasting products, including CO₂, CO, SO₂, NO_X and ammonia gases (NH₄). The key contaminants in terms of potential effects on downwind air quality are considered to be CO, NO₂ and dust.

***

Winds were wild around Costerfield earlier this week... gusts of a hundred-plus kilometres an hour... and sometimes, like earlier this week, at around 7pm, too - change of shift at the mine; that's when the mine blasts prior to the start of the next shift, because the mine itself is clear of workers. It's not the first time the wind has blown fiercely in Costerfield over the past decade...

We also know that particulate monitoring ceased in Costerfield on 13 February, 2006. Until "permanently installed sophisticated real time air quality monitoring" was re-instated in June of this year as part of the 'whole of government' dust suppression strategy.

This bodgied up monitoring equipment had previously told them they didn't have to...

Industry groups have been telling the regulators about these shortcomings since at least 2007 according to this article from Waste Management and Environment Magazine from 6 September of that year. 

Questions that need to be answered by the regulators... DSDBI, EPA, DoH... 

How far do dust, PM10, PM2.5, blasting compounds and respirable silica travel when they leave the Cuffley Vent's 3m diameter exhaust at 43.2 km/h and meet a 100km/h wind? 

Or the Augusta Portal? Just asking... ;)

That kind of event could carry dust and particulate matter onto properties a fair old distance from the mine, one would assume… “way out of the area”, in fact.

At what distance from the mine are Golder Associates testing for the presence of antimony? 

(You won't find mention of Costerfield or Mandalay Resources in their list of Projects on that site, but it is interesting to note that they have provided full time site supervision during construction of the:

• engineered fill

• dual clay liners and leachate detection layer

• HDPE geomembrane liner and cushion layer

• leachate drainage aggregate and leachate collection pipework.

for a Waste Cell in Dublin, South Australia. In 2010. Dual clay liners AND an HDPE liner. Wow! Never thought I'd say that... South Australia, eh?)

Are they also testing for arsenic in Costerfield... and beyond? 

We've asked this next question previously, but it's a good one so we'll ask it again.

How much material – dust, antimony, arsenic, respirable silica, blasting detritus “including CO₂, CO, SO₂, NO_X and ammonia gases (NH₄)” - does EPA/DSDBI estimate has been emitted by the mine via its vents over the past eight years?  

How far has it been blown? What other materials are Golder testing for?

The WHO 2004 background report into antimony in drinking water reads at page 10:

The possibility of co-exposure of consumers to arsenic and antimony in drinking water would necessitate an assessment of the local geological conditions on a case-by-case basis. If both elements were found to be present, case-specific risk evaluations for possible additivity and synergistic effects would need to be performed.

Is this is being done? DSDBI could neither confirm nor deny such testing was planned. Why not? This is a Health issue. What's a mining regulator doing dealing with it?

A simple straight question has been asked of the regulators by email:  

Are Golder testing for synergistic and additive effects of arsenic and antimony? 

A simple straight answer is required.

And it is a very important answer that needs to be provided before the "next phase of testing" commences on MONDAY 6 OCTOBER, 2014 in a compromised and incomplete manner. 

Arsenic was tested for back in 1998 when the Department of Human Services used to do its own testing on behalf of the people of Victoria...

As stated above, the highlighted question above was answered very quickly by the Department concerned. We thank them for their prompt and forthright reply.

Edit: 20 August 2015 - We still await the synergistic data.