Dear Mr Pruitt, I see you have finally taken an interest in the environment. What with your recent decree to give yourself the last word on waterways sidestepping the input of those know-nothing environmental scientists, to your ardent interest in Superfund sites inserting yourself as the final decider on any site costing more than $50 Million to cleanup. Your focus on water and Superfund reminds me of our relatively local Superfund, the Housatonic River in Pittsfield, MA.

There’s a mess with a hefty price tag. As I am sure you are aware, there is some haggling about how best to remove all those PCBs left behind by General Electric; the roughly $613 million cleanup based on earlier EPA directives, or… the bargain basement cleanup suggested by GE, as reported in the Berkshire Eagle earlier this year. And you could be the final decider on this! So, let’s talk about those PCBs. (The chemical that one could argue has fueled a generation of toxicologists* along with the Superfund and Hazardous cleanup industry #thankyouGEandMonsanto.)

PCBs are the quintessential example of chemical recklessness and like DDT, are a legacy pollutant. As another turn-of-the century industry darling these unregulated chemicals eventually contaminated just above every region of the planet. Even seven miles down, deep sea dwellers are contaminated with PCBs.

PCB factoryGeneral Electric brought good things to life with PCB-loaded transformers and capacitors (they are not the only ones, there was Westinghouse and Aerovox Corp. and others). In a thirty-year period, up until the 1970s, GE’s New York manufacturing plant dumped over a million pounds of PCBs into the mighty Hudson making it one of the largest Superfund Sites in the nation. And that was just one factory. Basically, wherever industry lit up our lives there are PCBs. And then there were all the landfills and dumps where those products met the end of the useful lives.

PCBs weren’t just long-lived, versatile, heat resistant chemicals – turns out they are toxic as well. Put the chlorine here and it’s toxic to the brain, move it over there and they are like their more toxic cousin, dioxin, causing reproductive failure and developmental problems. But back in the 1930s and 40s, no one really had a clue about how toxic (well, actually, they did – workers showed signs of toxicity – but workers really didn’t stand much of a chance in those days), or well-traveled PCBs were, until Soren Jenson, over in Sweden, was looking to measure DDT exposure, and found that PCBs had made their way into his wife and kids as well. Imagine his surprise.

PCB congeners
PCBs, a chemical only a toxicologist could love

Now we all carry some within us. It is fascinating to imagine the journeys of these stubborn chemicals: created in Monsanto’s Anniston, Alabama factory (one of their two production sites), shipped up to General Electric’s place in Troy, slipping through a factory drain, eventually picked up by a beauty of a striped bass or maybe a little minnow living and dying in the Hudson – recycling it’s toxic load for decades before some of those PCB molecules eventually made their way into our bodies, perhaps passed from mother to child. Others accumulated in the bodies of a sleek mink feeding at the water’s edge. Unfortunately for the mink, their exquisite sensitivity to PCB toxicity may have led to local extinctions.

Monsanto fretted over its role in this global contaminant back in the 60s. They worried about lawsuits, and health effects, and their public image…but rather than discontinue the product effectively admitting guilt, they persisted (so to speak) – producing PCBs until 1977.  Perhaps they saw the writing…two years later EPA banned manufacturing, phased out their use, and tightened controls on PCB waste.

That we are still talking about them four decades later, as a result of decisions made by an industry that put profits over human and environmental health – attests to the relevance of your agency. Yes, our generation and our parents and grandparents benefited by the technologies enabled by PCBs. But when train-loads of PCBs ceased making their way into our homes, schools and factories, the lights didn’t go out. In fact, these industries grew. Perhaps, had Monsanto and General Electric had the benefit of some federal oversight – pushing them to create a great product that was safe for humans and the environment they wouldn’t be spending billions to clean up their mess today. (A pittance for them, but better spent on innovation and testing rather than cleanup and legal.) I realize this is easy to say now, with nearly a century’s worth of strategies to better understand the chemicals we use and produce. But it’s not irrelevant.

We live in an industrial age chemical world, and there is no going back. You are now in the unique role to ensure that a generation or two down the road, industry won’t be spending trillions on cleanup and legal bills (to fight cleanup) and Americans won’t be wondering why we chose to favor industry over our own health and the health of our rivers, forests and wildlife.

So, now that you have personally inserted yourself into the decision about how best to clean up our Housatonic (because it is all of ours, along with the Hudson, and New Bedford Harbor and Fox River and all the other PCB polluted gems around this country) rather than pass the responsibility for our toxic transgressions onto yet another generation, I hope you consider more than just the bottom line and what’s best for the polluter. Please consider what’s best for all of us.

If you could get this done before you are fired, that would be great. Who knows who may come next! Also, if there is anything I can do to help, please let me know.  Thank you.

*I am one of those toxicologists who, for a while, made a living off of PCBs.