prepared a third draft in April 2008, which was also posted to its Web site. The 2008 draft no longer contained the health data that had been included in the previous draft.


In response to CDC’s request, in April 2008 IOM appointed a committee of 11 experts in toxicology, risk assessment, risk communication, exposure assessment, public health, biostatistics, and epidemiology to conduct this study. In addition to reviewing the 2007 and 2008 report drafts, the National Academies was asked to respond to whether comments on the drafts from reviewers and the Offices of the Director of ATSDR and CCEHIP were adequately addressed. CDC requested that the National Academies produce a letter report for public dissemination within 4 months. The present letter report fulfills that request. The IOM committee had the following materials available to it:

  • The letter from the IJC with the original request to ATSDR (IJC 2001; see Appendix B).

  • The three report drafts (ATSDR 2004, ATSDR 2007, ATSDR 2008a).

  • The internal and external reviewers’ comments (ATSDR 2008b).

  • Other supporting documentation provided by CDC and ATSDR (Appendix C).

The committee met twice. At its first meeting in May 2008 in Washington DC, an open session was held at which CDC officials presented the charge to the committee. The open session included an open-microphone period, but no other interested parties asked to address the committee.


This letter report presents background information on the ATSDR report drafts and a detailed evaluation. In summary, the committee identified substantial limitations in the 2007 draft. It noted changes in the 2008 draft report, but important limitations remain. The committee’s conclusions are presented here verbatim from the conclusions section of the letter report. The body of the letter report elaborates on the support for those conclusions, with examples. On the basis of its evaluation, the committee offers the following conclusions with respect to its specific tasks:

  1. Evaluate the appropriateness of the datasets used and the scientific quality of the data analysis and presentation, and the conclusions drawn from the draft July 2007 report.

    No justification or support was provided for the selection of the datasets used in the 2007 draft, the data analysis and presentation were insufficient, and key conclusions were either not clearly stated or overstated and were presented in a manner that was not supported by the data summarized in the document.

The committee considered the summary of the ATSDR health evaluations (e.g., Public Health Assessments, Health Consultations) in the 2007 draft report to be partly responsive to the IJC request “to provide the Commission information on public health assessments that it has conducted on hazardous waste sites located within any of the 33 United States AOCs.” However, the 2007 draft did not provide suitable information on current contaminant concentrations and potential health effects in the AOCs. Although the datasets used contain valid information and are potentially useful for certain purposes, other potentially useful datasets were not considered, and no justification or support is provided for the selection of the datasets used in the report draft. The appropriateness of that use cannot be fully evaluated in the absence of a clear statement of the task undertaken in the draft report, and the approach to that task, that provide the rationale for investigating particular adverse health outcomes and particular contaminants. With respect to data analysis and presentation, only descriptive data analyses were presented in the report draft, and the presentation lacked sufficient interpretation or synthesis. No statistical



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