Lisa Mackenzie
From:
Ursula Edgington <
>
Sent:
Tuesday, 3 July 2018 12:48 p.m.
To:
submissions
Subject:
Submission
Categories:
Green category
Risk assessment methodology  
 
This is a very important opportunity to review and make sure that the new assessment system includes 
corrections of some fundamental problems of the significant and dangerous weaknesses of the current risk 
assessment system  
 
This draft is founded on the philosophy of cost-benefit analysis. But applying a cost-benefit analysis 
approach only to issues which concern the environment and human health is unfair, unethical & risky. There 
is current research which points out the gaps in the science about the potential harm to public health & our 
environment of aerial poison operations.  
 
Hence the EPA must broaden their risk assessments of hazardous substances like Brodifacoum & 1080 
poisons to include things that might highlight the wider issues. 
These issues can by explored by the following: 
  epidemiological studies into health issues/spikes in health issues in areas where aerial poison has 
occurred.  
* actively interview local residents who are down wind from the operations to ask about health impacts, 
impacts on bush, bird life, insect life, pasture, estuary, coastal life, etc. 
* to conduct extensive risk assessments of the impacts of 1080 dust and mist 
* to conduct regular & extensive risk assessments of the impacts of 1080 on deep groundwater at p/p/trillion
* to review and evaluate their operational procedures to ensure that there are no conflicts of interest 
 
Risk assessments must not be motivated by the 'chase to economic benefits', at the serious cost to human 
and ecosystem health. 
 
There is an underlying assumption that these use of these substances 'will go ahead', regardless of the 
potential gaps & potential harm to health and that assumption needs to be broken down. 
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The public health aspects of operational risk assessments should not be carried out operators (contractors) 
who have been tasked to do the poisoning, because of an obvious conflict of interests, they will naturally not 
want to find anything which might stall the project. Instead, the public health aspects of a risk assessment 
must be done by someone completely independent with no interest in whether the operations go ahead or 
not. 
 
 
* also see info https://oehha.ca.gov/proposition-65/chemicals/sodium-fluoroacetate 
 
--  
Ursula Edgington BA (Hons) PGDipCet MA PhD  
Tertiary Teacher, Freelance Researcher & Writer 
Mobile +
 
 
 
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