Superfund and public health policies: an ATSDR response.

We read with interest the article "Public Health Policies Regarding Hazardous Waste Sites and Cigarette Smoking: An Argument by Analogy" by Legator and Strawn (p. 8). The article raises a number of important points regarding the characterization of health risks presented by hazardous waste sites. In particular, the article argues that government policies and public health practice pertaining to hazardous waste sites should somehow be developed and pursued in ways analogous to how public health agencies have reacted to the health, hazard of cigarette smoking. For reasons described in this letter, we differ with Legator and Strawn's arguments on two counts: 1) they are misinformed about how federal agencies are dealing with the health threats posed by hazardous waste sites, and 2) their proposed analogy between cigarette smoking and hazardous waste sites strikes us as being inadequate. Turning first to the authors' attempt to develop an analogy between cigarette smoking and hazardous waste sites, it is not at all obvious to us that such a comparison can be made. We agree with Legator and Strawn that cigarette smoke contains a complex mixture of toxic substances , and acknowledge, based on our agency's experience, that some toxic waste sites release complex mixtures of substances into the environment. However, it is not true that exposure scenarios between cigarette smoking and hazardous waste sites are comparable. For example, unlike cigarette smoke, hazardous waste sites contaminate multiple environmental media in addition to air (1). Further, the degree of exposure can be vastly different, depending on such factors as proximity to hazardous waste sites, routes of exposure, and lifestyle, including smoking behaviors. We also have difficulty in comparing the situation of cigarette smoking to hazardous waste sites because of the disparity in scientific knowledge. Considerable investment has been made in studying the toxicology of cigarette smoke constituents and the epidemiology of health consequences of smoking. In contrast, as pointed out by the National Research Council (2), there are an inadequate number of epidemiologic (and we would add toxicologic, as well) investigations pertaining to the health effects of hazardous wastes. Given the disparity in scientific data, how can meaningful comparisons between cigarette smoking and hazardous waste sites be made-especially if such comparisons, as argued by Legator and Strawn, are to be forged into public health policies? Legator and Strawn's central thesis seems to be "The role of the public health agencies should be to identify those …