WARNING: This site deals only with the corporate corruption of science, and makes no inference about the motives or activities of individuals involved.
    There are many reasons why individuals become embroiled in corporate corruption activities - from political zealotry to over-enthusiastic activism; from gullibility to greed.
    Please read the OVERVIEW carefully, and make up your own mind.

OPINION ONLY

In 1989 George Carlo established Health & Environmental Sciences (HES) with a fellow Agent-Orange/tobacco denier Maurice LeVois — a mathematics teacher who set up shop as a statistician and epidemiologist. LeVois was to base himself in San Francisco and run HES-West, while Carlo remained in Washington DC and ran HES-East.

However, the formal arrangement with LeVois didn't last long (informal support lasted much longer) LaVois struck up a semi-partnership if Max Layard in California and Carlo took control of HES himself. He also extended his range of clients and began creating non-profits and subsidiaries for a number of industries and science-for-sale projects under Health and Environmental Sciences Group (HESG) banner.

LeVois and Carlo had many contacts with the tobacco industry

• Their primary contact was through Philip Morris via Tom Borelli who ran the domestic disinformation operations called cynically "Science & Technology". (Borelli is now a partner with Steven Milloy [TASSC, Fox News, and Junk Science web site fame].
  
• Carlo also worked briefly for RJ Reynolds via Tom Griscom, their Vice President of PR on the Premier cigarette project.
• The Tobacco Institute also employed his services, and he became listed on a widely-circulated list of "Full-time ETS Consultants" and part of their "Scientific Witness Team". These scientists were paid industry mouthpieces who would appear as 'independent' witnesses in local ordinance or State Assembly hearings to oppose smoking bans.
• Carlo also formed a partnership and friendships with an even-more-devious pair: Jim Tozzi and Thorne Auchter, who ran almost as many non-profit corporate front groups as Carlo himself. Their main operation was Federal Focus Inc., but they often billed through Multinational Business Services (MBS), or the Institute for Regulatory Policy (IRP). Tozzi, Auchter and Carlo also worked for the chemical and pharmacuetical industries.

In the period (say 1989 to 1999),Carlo also developed a close relationship with John D Graham who ran the Harvard School of Public Health's Risk Assessment Center. Graham and his associates later privatised the Center and established it as a private 'Risk Management' corporation under the name "Harvard Center for Risk Analysis (HRCA)"

The HCRA's propaganda services were offered to large corporations and industry groups who funded the organization. Both Carlo and Graham then contracted through Ketchum Public Relations to run a quick ($2 million) literature-analysis project for the Cellular Telephone Industry Association (CTIA) under the name Special Advisory Group (SAG) which later evolved into Wireless Technology Research, Ltd.(WTR)

This cell phone material is dealt with in Parts 3 and 5.

Some key documents

• Return to Part 1 — Early years; Dow Chemicals, Agent Orange, etc.

1989 May 31: Tobacco Institute document: "Status of Identification, Recruitment and Training of Academic Scientists for ETS-related Matters." This had been prepared for the May 31 Communications committeee meeting.
[The Communications committeee consisted of the PR operatives and lobbyists for five of the cigarette companies]

This document (which was developed primarily as a speech) outlines the elaborate procedures that they followed when recruiting corrupt or corruptable academic scientists.

1. Review of Assignment and Authority from April 7 Executive Commitee meeting.

• 12 - 15 Academic Scientists on ETS to publish in the scientific literature, testify before Congress and major regulatory agencies. Participate in scientific conferences.
• Aircraft ventilation expert to buttress cabin air quality activity
  [The airline cabin crews were lobbying for smoking bans on domestic flights.]
• Budget authority — $1.05 million for the balance of 1989

2. Institute staff is handling overall coordination.

• Clausen Ely of Covington & Burling [tobacco lawyers] is coordining day-to-day identification and recruitement activity.

3. Progress to date ETS Scientists.

• Efforts to identify began last fall.
• Covington [& Burling] retained an expert witness search firm, Weinberg & Associates.
• Myron Weinberg developed a list of 17 candidates
• Recruitment procedures [See actual document]

• Since mid-April Weinberg and Ely have reviewed the resumes and published paper of the 17 candidates identified last fall and have made initial contact with about half of them;

• In the next week or so, Ely, Weinberg and a new recruiter/trainer, George Carlo, should complete conference calls with these five candidates to ascertain their views on the literature.
• In Addition, Tom Borelli of PM [top Philip Morris misinformation specialist] suggested two candidates from the faculty of the New York Medical College ([Prof. Joseph M] Wu and [Lawrence M] Wexler).
• Ely has contacted both. Both have reviewed the ETS literature. Conference calls indicate that their views of the literature are consistent with the industry's.
• Ely and Carlo are scheduled to meet them (Wu and Wexler) on June 23rd at Philip Morris' office in Manhattan.
• Ely and Carlo also hope to meet with the other NYC-area prospects (Godfrey and Gutterplan) on the 22nd.
• Meanwhile, Weinberg has developed a second list of 12 candidates and their published papers for our review. And the process will continue until we reach our goal.

1989 Jun 15: Sam Chilcote, the President of the Tobacco Institute, used a later version of the above document as his speech notes to the tobacco company CEOs who constituted the "Executive committeee". He has added a few handnotes.
[Worth checking both]

Denying the obvious...

A later, widely-circulated e-mail from George Carlo defending himself against claims that he was "hired by Philip Morris to declare tobacco smoke safe" states: "This is one of the more outrageous rumors that seems to persist on the Internet about my previous work. I have been a very vocal and outspoken opponent of cigarette smoking and tobacco in general for over thirty years — in both my professional presentations and my publications." [It would be difficult to imagine a more damaging revelation about Carlo's role in helping the tobacco industry than the one above... despite his continual denials.]

1989 June 16: /E Philip Morris completely restructured their fight-back operations. They merged the Corporate Affairs and Science & Technology divisions to create Corporate Scientific Affairs under top lawyer Steve Parrish, and they shifted many of their key executives around.

    This restructuring also resulted in the employment of Newman Partnership Ltd, to "cut-out" direct contact with scientists offering to do dubious research, and also the establishment of an internal ETS Management committeee (EMC) which would supervise all fake science and misinformation activities. The members of this committee included both Tom Borelli and Fred Newman, and it produced this report on how they should handle the growing problems of second-hand smoke (ETS).

George Carlo clearly had access to this primary ETS planning document also since, in his proposals, he was able to echo their own requirements.

Draft ETS plan   Notes on changed responsibilities

1989 June 16: The Newman Partnership Ltd. (NPL) was run by 'Larry' [Lloyd] and Fred Newman and their wives as a PR/scientific communications firm.
[Fred Newman was the inhouse legal counsel for Philip Morris, and it is not clear whether Philip Morris knew he had a share of the company with his brother Lloyd].

    From mid 1989, NPL had a contract with Philip Morris to run a program of "scientific communications" in support of the Science & Technology (S&T) division of Corporate Scientific Affairs (run by Tom Borelli). S&T handled scientific issues [The production of misinformation and countering of science.] and NPL provided a cut-out service designed to keep the guns-for-hire operators at arm's length in case anyone ran into legal problems.

1989 Aug 5: In parallel to the changes at Philip Morris, the Tobacco Institute has contracted Larry Holcomb who ran the science-for-sale operation Holcomb Environmental Services, to reorganise their Scientific Witness Team (SWT) of supposedly 'independent' scientists, to make them more effective.

    Holcomb came up with the strategy of allocating 'subcategories' of potential problems to pairs of scientists (one to act as a backup). They would be required to publish and speak on these subjects, and thus create a perception of expertise, and would then be available to respond rapidly to any adverse health claims appearing in the scientific literature or popular press.

This document says that in their sub-categories, they are paid to provide the following services:

1. Review of past and present literature.
2. Fast review of new data.
3. Fast access to new information.
4. Attendance at science sessions on the subject.
5. Taking part in the science and/or scientific societies treating these subjects.
6. Coordinating and sharing information with other scientists identified in their subcategory.

Maurice LeVois and George Carlo:

• Cervical Cancer / Cancers other than lung cancer.
• Epidemiology: Methodology and Statistics

[See document for the others]

1989 Aug 9: /E A later update EMC document, reported, under the heading of

Public Relations
Identified the Newman Partnership, a public relations firm specializing in scientific issues/controversies, to execute the ETS program. The group focuses on scientists as well as the science media to influence the views of the general media.

Identification of a science communications consultant, the Newman Partnership, which would undertake a scientists' lobbying program to get scientists to reevaluate their views on ETS.

1989 Aug 10: Maurice LeVois as "President" writes to disinformation executive Tom Borelli at Philip Morris. He is writing from San Francisco on Health & Environmental Science Corporation letterhead on behalf of himself and Carlo.

Dear Dr Borelli [... they are not yet on firstname terms]
I would like to follow up our recent discussion about ways to test the hypothesis that scientists are systematically misinformed about ETS. What follows is a brief recap of the basic concepts we discussed, and a request for approval to develop a research protocol to test these ideas.

    I think that there is ample reason to believe that the information, attitudes, and beliefs of scientists are not entirely informed by an objective reading of the scientific literature with regard to ETS. Part of this problem stems from a tendency (not unique to scientists) for scientists to read only information that is consistent with their preexisting views, and to disregard information that challenges their views.

[He now jumps from his pretense at scientific inquiry, to scientific lobbying and public relations without taking a breath.]

Changing the way scientists select and review the ETS literature will be difficult, and success will depend upon our ability to develop a properly focused approach to communicating with them.
[So the idea is to 'change' scientists' views, not discover their bias.]

    One useful step towards the goal of fostering greater scientific objectivity in the ETS debate [a common euphemism in the industry for promoting a pro-smoking viewpoint] that we discussed earlier is to obtain objective evidence that an information bias exists. This evidence alone could encourage some scientists to reevaluate their ETS position. Scientifically rigorous survey research could provide such evidence.
['Scientifically rigorous' depends here on the rigor of the scientist — and the whole purpose of hiring Carlo and LeVois is to ensure that someone claiming to be 'independent' collected it — not the tobacco companies.]

I. Information Survey
To test the hypothesis about systematic ETS misinformation, I propose that we develop a questionnaire and conduct a survey that presents information to a sample of scientists in the form a specific questions about ETS. Topics that the National Research Council has identified as being poorly understood, or lacking adequate data, could serve as the primary topic pool for the survey.
['topic pool' refers to other pollutants being compared - such as dioxins, radon, Alar, etc]

    If a significant number of scientists respond as if there were good data to support conclusions [that ETS and the other topic pool substances are harmful] then this should be interpreted as objective evidence of bias."
[So by carefully selecting disputable topics for the survey, they would guarantee to find evidence of so-called "bias" against a topic that almost no one disputed as potentially dangerous.]



II Focus Group Research
Since the survey discussed above is intended to provide objective evidence of an information bias we already have reason to believe exists, a parallel effort could proceed to identify an effective intervention to overcome this bias.
[In parallel with the so-called rigorous science — they would run a series of misinformation campaigns targeting selected groups indentified by their focus groups.]

    As you, know, George Carlo and I would like to conduct research for PM along the lines outlined above. We propose developing a detailed research protocol for the survey portion of this work, and I believe that it would be wise to work closely with PM at this stage in order to focus our research on areas of greatest value to the client.

    George has already mentioned that we would request a $7500 advance payment that would be billed against by us during the start up phase of this project.

1989 Aug 11: Larry Holcomb's Scientific Witness Team (Aug 5) proposal to the Tobacco Institute must have been acted upon almost immediately. Only a few days later this memo circulated within the Tobacco Institute.

The Institute currently has a team of nine scientific consultants (the so-called "second team" ) who provide expert testimony before state and local legislative and regulatory bodies, attend and report on scientific meetings, and prepare "quick and dirty" critiques of scientific reports and letters-to-editors of general and scientific publications. The nine are:

1. Larry Holcomb
2. Joe Pedelty
3. Walt Decker
4. Barry Seabrook
5. Larry Halfen
6. Jack Peterson
7. David Weeks
8. George Carlo
9. Maurice LaVois

Larry Holcomb coordinates the activities and "continuing education" of this group. Carlo and LaVois, relative newcomers to the team, have not yet been used as witnesses but will be available for next year's legislative season. Peterson and Weeks, famous for their "Truth Squad" media tours, now only rarely appear as witnesses for TI.

1989 Aug 22: Sam Chilcote writes to members of the Tobacco Institute's Executive committeee.

Per your request at our August 17 meeting, I am enclosing a list of scientists who currently consult with the industry on ETS and indoor air quality issues. As counsel advised, please treat this information with utmost discretion.

    We now have a total of 37 consultant scientists. Of these, 14 are affiliated with or are faculty members at academic institutions. The remaining scientists, each of whom has solid credentials, consult on a full-time basis.

• Academics ("first team")
• Full time ETS Consultants ("second team")
• Full-time consultants on IAQ ("third team")

1989 Aug 30: Tom Osdene, the Vice President at the head of the Philip Morris Research Center in Richmond, has received a complete list of tobacco industry consultants from the Tobacco Institute. He travels extensively in Europe and is an experienced recruiter of "scientific friends".
[In later court cases he regularly pleaded the Fifth Amendment about his recruitment activities.]

He appears here to be checking US potential contributers to the McGill University ETS Conference to ensure that he haa copies of their documentation.

    Osdene uses the headings "BUS" (Business?); "BIB" (Bibliography) and "BIO" (Biography) and also corrects spelling and initials. He is also preparing computerised WHTCOATS.TXT (WhiteCoats text) which was completed on September 5 1989 and another file labled COATS.TXT the day before.

See also the Results of this conference.

1989 Sep 13: Newman Partnership Ltd (NPL) sends a draft plan for discussion to the EMC committeee of Philip Morris, It identifies its own role as "scientific public relations counsel" and sets a monthly fee of $117,000 for a sixteen month period.

    They have employed the notorious John Scanlon as Senior Counsel and Management Supervisor.

1989 Oct 6: The Newman Partnership has had a meeting with Philip Morris's EMC committeee about

Science Communications - "Launch" Projects.
Based on our meeting today, we have redefined our Science Communication projects

• Challenge study : NAS study for Surgeon General's Report to be done by LeVois ($25,000) with the Goal:
  1. Show cumulative bias over long term
  2. Determine extent of the willingness to reconsider NAS conclusions
  3. Attempt to identify possible effective intervention communication to reduce bias.
  [ie.The NAS (National Association of Science) had published a study which supported the EPA's decision that passive smoking was harmful. This was also in agreement with the Surgeon-General's annual smoking report.
        LeVois was to challenge the NAS Study by finding evidence of bias among the contributors. ]
  
  
• Survey "XYZ Substances": to be done by George Carlo ($70,000) with the Goal:
  1. Expose ETS prejudice
  2. Show ETS as not a major issue
  [This is the "Bias Study" of 1000 scientists from 5 different scientific disciplines. It is a phone survey to compare their opinions of ETS with three (XYZ) other substances (dioxin, radon, alar)]
  
  
• Survey : "Minimum standards for research acceptability" to be done by Carlo ($60,000) with the Goal:
  1. Expose shortcomings in EPA and other studies
  2. Invalidate EPA methodology
  [This was the "Health Scientist Survey" which also appears to be a preliminary concept for what later became the London Principles and Good Epidemiological Practices.(GEP)]

1989 Oct 17: Tom Borelli has returned this NPL memo to Larry Newman following their meeting with George Carlo and his assistant Patricia Doseberg. He writes across the top:

"Larry, Please review and correct. I have talked today with Carlo, Coughlin, Cherney and Moby

    Clarify the planned science opinion studies and initiate development of the protocols.
[JR Coughlin of Kraft-General Foods was also doing a bias study for coffee makers;
Arlene Cherney and S Moby were on NPL staff.

• Minimum Criteria of Acceptability for Scientific Studies
  The study should reflect opinion, by scientific specialties, of criteria for deciding the appropriate degree/linkage of a relationship between an environmental factor and a disease.
  [This project is to be a causation-criterea study designed to create a 'purist' outcome. (Setting up restrictive rules for when a scientist could say "Disease A was caused by B.") ]
• Purpose of the study:
  1. Impact on the EPA Risk Assessment Advisory Report.
  2. Publication in reputable scientific/medical journals so as to establish these criteria in the minds of scientists as being widely accepted and appropriate.
  3. Publication in general news media
  [To be of use to the tobacco industry it requires critical press attacking the EPA and NAS statements that smoking 'caused' lung-cancer, etc., and publication of the new rules in reputable scientific/medical journals.]
• It will consider weaknesses in the National Academy of Science (NAS) study, the Surgeon General's Report, and influential studies like that of Hirayama,
  [The Japanese Hirayama study was very large and convincing. It was used by both the NAS and the Surgeon-General's advisory board as hard evidence that ETS harmed non-smokers.]
• Baseline Review of NAS Study on ETS to determine "What It Really Meant" by interviewing members of the original study group, and creating a 'proper interpretation'.
  [They obviously thought that it would be possible to convince some of the scientists involved in the NAS study to equivocate, and express 'scientific reservation' about absolute conclusions. This equivocation could then be promoted as 'doubt' or even 'recanting'.]
• Study on the Source of Scientist Bias (in two parts)
  1. What scientists think the NAS study said, and what it "really said."
     [This aimed to expoit any equivocation by the NAS study principles, in comparison with the statements of those questioned in the phone survey.]
  2. What influences Scientists in terms of bias.
     [What happens when they know the main topic is cigarette smoke?]
  
  
  
• XYZ Study
  1. Test perceptions of the degree of risk of ETS and of two other substances (dioxin?, Alar?, other?) on the bias of scientific evidence :
     1. Without revealing the name of the substances
     2. And then when the substances are identified
     [The use of false comparisons (acute vs chronic: universal vs probable) can then be exploited as evidence of bias. The vague life-time risk of a range of smoking-related diseases is being compared to mutagenic and debilitating conditions like dioxin poisoning of children.]
  2. Purpose: To determine if scientists/physicians display a prejudice against substances when identified versus "blind" analysis based on evidence only).
  3. Deadline: Prior to the release date of the EPA's ETS Risk Assessment report

Carlo's attempt at rebuttal

In his later widely-circulated memo, Carlo characterised this study as "independent science" done out of the goodness of his heart: This study was done specifically to look at how the public perceived the relative risks of dioxin, radon and second hand tobacco smoke.     The conclusion was that the public perception was that all three risks were of comparable concern. Shortly thereafter, the EPA classified second hand smoke as a probable human carcinogen — which I publicly supported. Carlo is being more than a little disingenuous here. The study was funded by Philip Morris, but then circulated to the press through his silent-partner Thorne Auchter's front organization, the Institute for Regulatory Policy (IRP) with no mention of tobacco funding. It was then widely promoted by the tobacco industry as proof that doctors and research scientists (especially those at the EPA) were 'biased' against the tobacco industry. The XYZ Study was published in a 1992 edition of the Environment International as "The Health Scientists Survey: Identifying Consensus on Assessing Human Health Risk. It acknowledges only that it was conducted between 1990 and 1992 with the assistance of the IRP. There is no mention of Philip Morris, or Newman Partnership.

1989 Oct 27: Internal Tobacco Institute memo with "a preliminary agenda for the Scientific Witness Team (SWT) meeting, Sessions will take place at the Sheraton-Carlton."

Carlo is to speak on his designated sub-category of Cervical Cancer.

1989 Oct 31: Larry Newman of The Newman Partnership is at the Society for Risk Assessment Conference in San Francico. He memos Tom Borelli, Nelson Beane and Tom Osdene at Philip Morris.

    He is reporting on the paper being presented by EPA's principle ETS investigators, Kenneth Brown (KB) and Douglas Crawford-Brown (DCB), and is clearly out of his depth in scientific terms.

    However as a lobbyist and PR man, he is also collecting scuttlebutt — and recording comments that might be useful to the tobacco industry. He has tape recorded both the conference sessions and some private conversations. He describes the two EPA investigators who have been looking into whether cigarette smoke might have some sort of a synergistic reaction with radon gas (present in US granite areas) as does asbestos:

KB is a prototypic "absent minded professor". He dresses in sweater and tie and bumbles through his presentations, thinking aloud as he goes. He is the ideal person to have on the witness stand if you want to "take him apart."

    DCB looks like a prototypic nerd until he opens his mouth. He is brilliant on his feet. I think this man could be "acquired" and should be pursued for that possibility.

In private conversation with me during a break in the workshop, DCB said he has lots of questions about his ETS work. "Something is going on with ETS and radon but I can't say what with great confidence."

    About his mathematical model on ETS components for EPA he said, "I have no confidence because there are so many (carcinogenic) components. What do I look at — my 10 favorites on Tuesday." The EPA is pushing him [to finish the ETS work] so they can go before the SAB, but he says he won't go because they will "take him apart".

    He doesn't believe EPA can use his materials (or intends to) as a basis for regulatory/political action. He promised to send me a draft of his entire work of which ETS/Radon is a part.

EPA staff reviewed a draft document setting standards for publication (and acceptance?) of research. They were out of copies before I got one, but I called Tom Borelli and George Carlo and gave them the following name and address [of the] American Industrial Health Council.

1989 Nov 3 - 4:       McGill University ETS Symposium.

    Carlo is not included on the speakers list despite having helped with the recruitment and vetting of many participants. It may well be that he was seen as one of the organisers, rather than as a participant — of that he was doing witness work for the TI's SWT — or was working for some other industry at the time.

    This was Philip Morris International's closed-conference of about 80 international tobacco scientists. They were in-house scientist trusted scientific consultants from the US/Canada and Europe, and the newly recruited 'Asian WhiteCoats' attended their first tobacco conference. They were all in Canada at Philip Morris and Tobacco Institute's expense.

    Probably another 30-50 staff and organisers also attended and a few from industry-funded think-tanks. It was a massive and expensive undertaking run by Andrew Whist at PMI Corporate Affairs.

    The aim of the seminar was to develop a 'consensus' among the commissioned consultants and in-house scientific staff about ETS and exchange views about how the EPA and other agency science could be countered. The 'consensus views' could then be promoted as those of a genuine conference, and proof of doubt in the scientific community that passive smoking was a health problem.

    This 'proof' was was accumulated in the vetted conference speeches, which were then improved, selected and collated into the conference proceedings which were to be publish and distribute as a large booklet by the Institute for International Health & Development (IIHD) run by Paul Dietrich.
    The booklet was translated into multiple languages and circulated around the world to be used as a university textbook in many countries. [See other material on McGill]

[The IIHD was actually a Philip Morris front organization with United Nations NGO and US State Department links.]

1989 Nov 7: A week after the McGill conference Carlo was speaking on his "Cervical Cancer" designated sub-category at the Tobacco Institute's ETS Indoor Air Quality Conference. Most speakers on this list were members of the Holcomb (Aug 5 1989) Science Witness Team or known Tobacco contractors.

    This appears to be a trail session with some SWT members test-lecturing on their designated subjects.

1989 Nov 20: George Carlo and the Health and Environmental Sciences Group, staff have prepared the full Draft Protocols for the Newman Partnership Ltd, of Columbia, South Carolina. [The home address of Larry Newman] to hand on to Philip Morris.

    Carlo's preamble lists reasons why Philip Morris should secretly fund both his 'Bias study' and the 'Health Scientist Survey'. He spells the obvious in transparent tobacco industry terms. Such pseudo-research was needed to counter....

• The Japanese Hirayama study of lung-cancer among the wives of Japanese smokers, which had established that ETS (passive smoking) was a substantial risk factor in human lung-cancer among non-smokers.
• The same conclusion had been supported by the 1986 review of the ETS-lung cancer literature conducted by the National Academy of Sciences (NAS)
• And, in a few months (in early 1990), the US Environmental Protection Agency (EPA) was expected to release a series of quantitative risk assessments regarding ETS (passive smoking) and disease which may lead to national regulations restricting smoking in public places.

• Executive summary;
• Part 1 on the pseudo scientific research and its rationale,
• Part 2 which is a PR plan to promote the pre-ordained conclusions
• Appendicies

Executive Summary:
Specifically, three qualitative studies and one quantitative study of bias are described in this document. The three qualitative studies are interrelated and provide the basis for testing specific hypotheses regarding bias in the fourth study.

    Although the studies build upon one another, each study is unique and it is anticipated that each will be published or otherwise disseminated independently as well as in combination.

1. Minimum Standards Study — this study will identify good scientific practice standards [est. cost $131,350]
2. NAS Study Review and Interpretation — to establish what interpretation the members of the NAS panel made. [est. $28,000]
3. Scientist and Physician Opinions About the NAS Study and ETS — this study will determine what scientist and physician opinions are regarding ETS.[est. $89,000]
4. Quantitative Study of Bias — this study will test the hypothesis that knowledge of the identity of the substance being evaluated creates a bias in interpreting the potential impact on human health [est. $90,000]

Would-be peer reviewers of the protocol (e.g. University of Michigan survey research professionals) should instead be hired to develop and implement the aspects of the studies considered to be most open to public criticism (e.g. development of interview instruments, development of sampling strategies).

[ Interpretation: They would peer-review the design protocols — not the actual research — and then still claim that the research has been 'peer reviewed'.]

"When these studies are approved and "underway" , there might also be the opportunity to provide Dr Kenneth Brown, the EPA risk assessment contractor, with a briefing, prior to his submitting his final version to EPA.

    Such a briefing with Dr Brown would both present an opportunity to influence his final version by providing him with new and relevant data, and alert him to the degree of sophistication applied to critiques of his work. This type of proactive peer review, or peer review with new data is highly unusual but effective. Knowledge that such intense scrutiny is being applied might cause him to think twice."

Publication in Scientific Journals:" Non-peer review journals such as American Scientist and the various state medical society journals usually accept for publication well written and interesting papers, but may require a local interest angle.

    Both the peer review and non peer review journals routinely accept Letters to the Editor, and opportunities for this type of publication should also be sought. With respect to the most timely avenue to publication, letters to the editor and publication in The Lancet or a similar weekly medical or scientific news journal would be recommended."

Strategy.
"While much of the data to be generated in these studies have long term value and potential use, timing is of the essence in addressing the EPA risk assessments. Acceptance of the results by the scientific community will be gained both through rigorous briefing of key science groups and by publication in a peer reviewed journal. However, scientific publication should be viewed as a longer term goal since scientific peer review is time consuming and scientific journal publication backlogs are usually substantial.

    [T]he overall strategy should involve recognition that the studies being done are intended to make a contribution to the literature and the science of assessing environmental health risks. This pertains especially to the minimum standards study and the quantitative study of bias. The value of these studies goes beyond the ETS issue as far as the science is concerned, and posturing these studies as broader than ETS is recommended.
[Rather than peer-review 'in advance', he recommends hiring a University of Michigan survey research group to avoid public criticism.]

    In this way, scientific rigor is enhanced. This will also integrate into the process third parties who are likely to be viewed as objective by the general public and the scientific and public policy communities. Hopefully this will also enhance the publication of the results.

Dissemination of Results.
The results of these studies will be immediately useful in providing a science based critique of: the NAS review, the Surgeon General's opinion on ETS, and the forthcoming EPA risk assessments regarding ETS.

    Based on these application purposes, there are a number of dissemination possibilities. In-person conferences, with the opportunity to present and discuss data tables and interpretations is most advisable, and likely to be most effective.

Finally, dissemination of these results to the general public should involve background media briefings, interviews and perhaps a video, perhaps in documentary format, describing the results of these studies in the context of the overall ETS health effects issue.

Cost estimates for different aspects:

• Phase I                   $ 14,400
• Phase II                 $ 116,950        
• NAS Study Review  $ 28,000
• Opinion Survey       $ 89,000
• Study of Bias         $ 90,000

1989 Dec: /E The Tobacco Institute (TI) has circulated this list of available 'consultants' who are willing to give testimony at ordinance hearings, or before State assemblies, promoting the tobacco industry's line.
[It is important to realize that 'consultant' here means a scientist or academic paid to support the industry's position. They do not 'consult' in the normal meaning of the term, as in "providing genuine expert advice".]

    Basically there are four categories of consultants, with lists of names. Every one of them is a well known long-term tobacco industry friend and "passive smoke denier". The memo says that the...

• TI consults with 37 ETS and IAQ scientists: 14 are members of university or medical school faculties; 23 are professional consultants; 11 are exclusively expert on IAQ.
• Scientific disciplines include chemistry, toxicology, biochemistry, statistics, medicine, environmental science, biostatistics and industrial hygiene.

• Academics: 14 academic scientists from institutions including the University of California; New York University Medical Center; Columbia University; University of South Carolina; University of Alabama; University of Maryland; Medical College of Virginia; Pace University; West Virginia University; Stillman College; New York Medical College; and George Washington University.
  
  
• ETS Consultants: George Carlo; Walter Decker; Thomas Golojuch; Gio Gori; Larry Halfen; Larry Holcomb; Alan Katzenstein; Maurice LeVois; Joe Pedelty; Jack Peterson; Barry Seabrook;.and David Weeks.
  
  
• IAQ Consultants: Peter Binnie; Bill Butler; John Drake; Jolanda Janczewski; D. Johnson; Gray Robertson; Jeff Seckler; Elia Sterling; Nancy Stone; Simon Turner; and Jon Yereb.
  [IAQ Consultants are executives of a few indoor air testing companies who were paid to fake their findings to reduce the detected levels of smoke. They also travelled around the country promoting the fear of "sick building syndrome" which they said was caused by bacteria and viruses in air-conditioning systems — so blaming poor maintenance and the need for greater air-exchange rates.]

"Kinds of things they do"

• Testify on federal, state and local smoking restriction and indoor air quality bills and regulations — explaining complex scientific information in straightforward lay terms.
• Appear on television and radio talk shows — often in debate formats — in areas where smoking restriction activity is underway.
• Assist the industry in responding to media reports by preparing critiques of adverse research.
• Help reassure allies that they are on solid scientific ground

• John Fox and Dennis Vaughn, two contracted labor lawyers
• Lewis Solomon, Dean of the UCLA Graduate School of Education (who attacks workplace smoking problems associated with productivity and absenteeism)

1989 Dec 6: Tom Borelli and Amy Millman circulate a memo within Philip Morris.

The EPA's Risk Assessment has been delayed and they have time to develop a new day-by-day strategy.

• Dec 11 - Lobbyists Mannett Phelps will have an EPA action plan ready.
  
  
• Dec 15 - The McGill University ETS Conference proceedings will be available for review.(The McGill Conference report must be distributed to scientists and policy makers.)
  [Paul Dietrich of the Institute for International Health & Development had the job of publishing and distributing the procedings as booklets.]
  
  
• Jan 10 - first opportunity to leak the EPA document to the press.
  [They already had a confidential copy of the EPA's Draft Risk Assessment, but they needed to have some event to provide cover for the leak. Lisa Barrera had the inside connections within the EPA.]
  
  
• Feb 15 - The EPA's Scientific Advisory Board will begin its review of the EPA's Risk Assessment.
  [The SAB was reasonably independent — although the industry had a couple of their tame scientists on it.]
  
  
• Feb 19 - 21 Toxicology Forum
  [This was run by Coca-Cola executive Alex Malspina who also ran the ILSI. They believe that he is subject to PM/Kraft 'influence' if it comes in a brown bag. This forum gives them an opportunity to release scientific denial documents already prepared.]

Another strategy we should pursue is to try and get a sympathetic scientist appointed to the health effects panel. New scientists are chosen each time an SAB panel is convened.

    We can use the McGill findings, and the information we have received that the group preparing the risk assessment was unable to establish a synergistic relationship between radon and ETS, nor were they able to prove a significant dose response. TI will undoubtedly respond to media inquiries but we should consider using the Newman Partnership creatively.

    We need evidence that the scientists conducting research into, or reviewing the science of ETS, are less objective than they would be if they were dealing with another substance.
[A clear reference to the potential use of Carlo's "Bias study".]

1989 Dec 20: RJ Reynolds have prepared a comprehensive plan of action "Environmental Tobacco Smoke - Recommended Industry Program"

    It incorporates the Philip Morris and Tobacco Institute plans along with many suggestions for Reynold's own scientific corruption activities. Carlo is mentioned as part of the Tobacco Institute Scientific Witness Team

1989 Dec 31: /E In 1989 Carlo received two Philip Morris payments ($70,000 + $60,000) for his papers proving that epidemiology is wrong, and that anti-tobacco scientists are biased and so produce distorted results.

    Two different HES staff 'researchers', Kelly Sund and Rebecca Steffens, are listed as co-authors on the paper. Kelly G Sund's name is on the draft, and Rebecca Steffens [later Jenrow] appears on the final document.

    Kelly Sund was a faithful employee who acted as a travelling companion, general factorum and the only employed co-researcher to Carlo until now. She is never listed as having any biomedical qualifications, although she was also co-author on the dioxin-spill study of the Melbourne (Australia) water supply in this year.

Maurice LeVois also managed to take $25,000 from Philip Morris for similar work at the same time. He had already begun to work out of San Francisco with another Californian shonk and tobacco lackey called Max Layard, but he is still on record as running "HES-West".

1990: Carlo's Health and Environmental Sciences Group, Washington, DC published a report Industry Task Force on 2,4-D Research Data. Backgrounder on the uses of 2,4-D.

Phenoxy herbicides include 2,4-D, 2,4,5-T (banned for all uses in the United States in 1978), 2-methyl-4-chlorophenoxyacetic acid, and other related compounds.

2,4-D is one of the most commonly used broadleaf herbicides in North America. It is widely used in agriculture on crops such as wheat, corn, oats, rye, barley, sugar cane, and sorghum. It is also used on range and pastureland, in forestry, on rights-of-way, and on lawns and other turf, such as golf courses.

1990: Tobacco Institute's Confidential notes on Public Smoking Hearings:

Consultants:
Who they are. How long have they been working for TI. What they do.

Background

• TI consults with 37 ETS and IAQ scientists: 14 are members of university or medical school faculties; 23 are professional consultants; 11 are exclusively expert on IAQ.
• Scientific disciplines include chemistry, toxicology, biochemistry, statistics, medicine, environmental science, biostatistics and industrial hygiene.

Who:

• Academics: 14 academic scientists from institutions including the University of California; New York University Medical Center; Columbia University; University of South Carolina; University of.Alabama; University of Maryland; Medical College of Virginia; Pace University; West Virginia University; Stillman College; New York Medical College; and George Washington University.
• ETS Consultants: George Carlo; Walter Decker; Thomas Golojuch; Gio Gori; Larry Halfen; Larry Holcomb; Alan Katzenstein; Maurice Levois; Joe Pedelty; Jack Peterson; Barry Seabrook; and David Weeks.
• IAQ Consultants : Peter Binnie; Bill Butler; John Drake; Jolanda Janczewski; D Johnson; Gray Robertson; Jeff Seckler; Elia Sterling; Nancy Stone; Simon Turner; and Jon Yereb.

• How we use them
  • Prepare and deliver testimony.
  • Conduct briefings with legislators; regulators; lobbyists; and coalition allies.
  • Conduct two ETS and one IAQ media tours per month.
  • Conduct empirical IAQ research.
  • Monitor scientific developments on ETS and IAQ.
  • Prepare articles for publication.
  • Submit letters to editors of scientific and general-audience publications.
  • Attend and report on scientific conferences.
• Kinds of things they do:
  • Testify on federal, state and local smoking restriction and indoor air quality bills and regulations — explaining complex scientific information in straightforward lay terms.
  • Appear on television and radio talk shows — often in debate formats — in areas where smoking restriction activity is underway.
  • Assist the industry in responding to media reports by preparing critiques of adverse research.
  • Help reassure allies that they are on solid scientific ground.

1990 Feb: - Mar The American Paper Institute and the Chlorine Institute were organising to challenge the early EPA findings that dioxins were extraordinarily dangerous.
[Note: These ideas rested substantial on the research done by Dow Chemical's own Dr Richard Kociba in 1978]

    They therefore hired a consulting firm, ChemRisk, to set up a 'independent' "Pathology Working Group" to review the Kociba work.
[ChemRisks was actually a division of McLaren/Hart and run by the well-known science lobbyist, Dennis Paustenbach.]

• Dr Robert A Squire — from Johns Hopkins Uni [a later Carlo associate] supervised the project.
  [His name isn't on the published report]
• Dr Denis Paustenbach — the science lobbyist/President at ChemRisk. He later sifted to Exponent Inc.
• Russell E Keenan — ex-EPA, then with ChemRisk. He is now with Integral Consulting working for the Maine Pulp & Paper Assn.
• Richard J Wenning — ChemRisk, later sediment rehabilitation specialist [Now at ENVIRON]
• Alan H Parsons — a junior toxicologist at ChemRisk

"All of the Agency's analyses are now out of date in light of the significant new evidence showing that the risks of dioxin has been overstated."

Actual report Criticism

See also PubMed and

1990 Feb 8: Larry Holcomb of Holcomb Environmental Services , who is organising the 'independent' Scientific Witness Teams (SWT) for the Tobacco Institute (giving evidence for the company during lawsuits, or at government hearings) is reporting to to his TI controller Kay Thomas about the first year of operations:

For the last 4 months of 1989 (when the program first began) it has cost approx. $42,050 divided up as follows:

• Cervical cancer and cancers other than Lung Cancer, $21,800;
  [This was the subcategory allocated to Carlo and LeVois]
• Cardiovascular $9125
  [Decker and Halfen];
• Biomarkers, $2775
  [Decker];
• Epidemiology, Statistics/ Methodology $2100;
  [Also allocated to Carlo and LeVois]
• Risk Assessment, $6250.
  [Holcomb and Pedelty]

The funds have been distributed amongst five experts; [George] Carlo, [Walter] Decker, [Larry] Halfen, [Maurice] Levois and [Joe] Pedelty .

When we started, I asked Jack Peterson to indicate on his billings, any special subcategory for which he was billing. I telephoned him recently and he said he didn't believe he had billed for anything special.

1990 Feb 19: -21 The annual Winter Toxicology Forum (run by the ILSI but not by the usual Alex Malaspina) was held at Lowes L'Enfant Plaza Hotel in Washington
[Lowes is the hotel chain owned by Lorillard, The Toxicology Forum was a dubious operation which ran an alternate series of conferences to that of the Society of Toxicology. Most of the shonkly scientists were prominent in both organizations. ].

    George Carlo wasn't at this conference. However his partner Maurice LeVois was... and it was loaded with tobacco scientists:

• Maurice LaVois, Ph.D., HES-WEST
  #4 Emborcodero Center Suite 2000 San Francisco, CA
  [Note that LeVois is still using the Health & Envtronmental Sciences business name]
• Maxwell Layard, Ph.D. President Layard & Associates ,2242 San Antonia Avenue Alamda, CA
  [This is LeVois's new partner]
• Dr Ian Munro, Director, Canadian Center for Toxicology, 645 Gordon Street Guelph,Ontario Canada
  [A later Carlo partner]

1990 Mar 7: The Chlorine Institute ran a Plant Operations Seminar in Houston. The paper, "Scientific Research on the Health Effects of Dioxins in the Environment: A Review and Summary of the Issues" by George L. Carlo, Chairman, Health & Environmental Sciences Corporation is made available as part of the proceedings of that seminar (but not separately).

    The paper says it was "prepared with the assistance of Health and Environment Sciences Group and Ketchum Public Relations personnel."

[ Ketchum Public Relations was the scientific lobbying firm later credited with finding Carlo as the head of research for the Cellular Telephone Industry Association]

    The paper industry's newsletter, the "Alkine Paper Advocate", put excerpts from Carlo's lecture up on the web. In these excerpts Carlo had claimed:

Many scientists now believe that low level exposure to dioxins does not represent a serious public health hazard.

    While some studies purport to show an association between exposure to dioxins and cancer in human, those studies are widely criticized and not widely accepted by the scientific community.

and

1990 Apr 4: Newman Parnership Ltd (NPL) has sent a new proposal to Tom Borelli at Philip Morris: "Variations on Varela".

Tobacco didn't fund the study,
      Tobacco didn't write the story.
            Sometimes truth just won't be denied

When the Carlo study on bias is completed, Varela could be incorporated into plans for PR.

1990 May: Nufarm Australia:
Australian Greenpeace revealed that Nufarm Chemicals [Herbicide manufacturers owned indirectly since 1982 by Dow] was discharging illegal levels of chlorinated phenols and high levels of dioxins and furans into the sewerage system at Werribee in the Melbourne water catchment area.

    The local EPA had been warned by their own staff about dioxin discharges from Nufarm as early as 1978. The effluent was being discharged illegally from the plant into an open drain behind the factory, and water flowing from the drain into the Cherry Creek/Lake System.

    In December 1978 the Victorian government EPA's principle Water Quality Officer wrote in regard to unlicensed discharges from Nufarm into the creek:-

"A by-product of 2,4,5-T manufacture, dioxin or TCDD (2,3,7,8-tetrachlorodibenzo-p-dioxin), has received considerable publicity recently because it causes serious acne and has been linked with cancer and birth deformities. I would suggest that the analyst be contacted to ascertain if the samples were analysed for dioxin." (EPA Memorandum 28/12/1978)

    "I anticipate... that a licence application for such discharges would be refused by the Authority (or MMBW [Metro Water Board]) because of the obvious threat to aquatic life and wildlife, and the possible health risk to humans."

1990 May: The EPA circulated to its Scientific Advisory Board [SAB] and other interested parties the review draft of a report on passive smoking [ETS] entitled "Health Effects of Passive Smoking: Assessment of Lung Cancer in Adults and Respiratory Disorders in Children.".

    At the same time, letters were exchanged between the Tobacco Institute and Republican Congressman Thomas J Bliley [R-Va who was known as "Mr Tobacco" — a "tireless champion for the tobacco industry"]. These were later leaked and exposed the tobacco industry's involvement in an attempt to force Dr David Burns out of the EPA's SAB [Scientific Advisory Board] on ETS after he had been invited to become a member.

    The tobacco industry and Rep Bliley claimed that Burns was 'biased' and one senior tobacco executive labled him a "squeaky-clean ignorami (sic) well known for his militant anti-smoking beliefs."

The exposure of the Bliley correspondence resulted in a furore, and had the result of seeing Burns reappointed along with a couple of other independent scientists who were also not under the industry's control.
[The Washington Legal Foundation also objected to the SAB process]


It was a major crisis for the industry at a critical time, and they were forced to lay low. One Philip Morris executive was furious at the botched outcome:

Regardless of the ultimate "findings" of the group, confirmation of the "science" alone will have devastating effects on a worldwide basis.

    The industry, as such,, has no credibility and no forum, for fairness. The "'lobbying" against Dr Burns is viewed by the media, the EPA, etc., as yet another tactic typical of the industry and has been characterized as desperate. The lack of knowledgeable, credible "white coats" [undercover secret supporting scientists] willing to speak for the industry is particularly debilitating.

    A combination of Parrish/Borelli and any credible scientists who will enter the fray under any terms (background, not for attribution, etc.) are perceived to:be the best, if not the only, communicators with any chance.to achieve any semblance of balance to the story

[Clearly most of their 'witnesses' and regular 'consultants' were not prepared to take a public position after the Bliley leak, so PM had to fall back on the two spokesman/executives.]

• Steve Parrish make a presentation and/or write a bylined article which would be fed to any media outlet that would run it.
• Dr Edward J Burger, Jr, Director of the Institute for Health Policy Analysis, and a professor at Georgtown would be asked to make a public protest as an independent scientist.
• Peter Huber of the Manhattan Institute (the originator of the "junk-science' phrase) would possibly "write an op-ed linking ETS to pathological science" targeted at the Washington Post.

• ... add the bias pitch to all editorial board briefings and meetings with journalists.
• write a op-ed piece for them and act as an independent spokesman in a planned attack on the EPA's reformed Scientific Advisory Board.

5. Publication of Carlo op-ed and coalition development (in the works)
   [He is also to help in the creation of an anti-EPA coalition (recruiting other industry groups).]
6. Media training for Borelli, Carlo, et al. tenatively scheduled for November 8 & 9, Washington
   [Philip Morris had irregular media training sessions organized through PR firm Burson-Marsteller].

1990 May 7: Nufarm Australia:
Greenpeace activists arrived at the Nufarm chemical company, taking control of the plant's effluent discharge into the sewer, and creating a news event which the EPA could no longer ignore.

The [EPA's] analysis results were released on May the 10th 1990 [and] the EPA tests found furans (2,3,7,8-TCDF) and other toxic polychlorinated dioxins.

    Dr Brian Robinson, Chairperson of the EPA, said that as there are no safe levels for dioxins and furans,

"they should not be entering the sewerage system at all. They are dangerous in the sense that they can cause harm to the environment in even very small levels...Our major concern is that these materials bioaccumulate. Why take the risk if we don't have to?"

Production of 2,4-D at Nufarm was halted and the company required to conduct an environmental audit, the first of its kind in Australia. [Source: The Age, May 1990]

    The discharge sample was tested by National Analytical Laboratories and found to contain 1.4 parts per billion [or 143 parts per trillion] of the furan 2,3,7,8-TCDF. As a comparison, 0.038 parts per trillion in water is enough to start killing fish. (Mehrle PM. et al. 1988)

    Nufarm's effluent also contained chlorophenols, a group of chemicals that are the precursors for the manufacture of 2,4-D. Several different types of these chemicals were found, including dichlorophenol and trichlorophenol. The Greenpeace samples contained up to 5,000 parts per million of these substances, 100 times Nufarm's allowed limit as set in their old Trade Waste Agreement (NAL Report, Greenpeace, April 1990).

1990 May 31: The Washington Post surprised the world with the headline, "Scientists Temper Views on Cancer-Causing Potential of Dioxin."

    The story, by Malcolm Gladwell, said,

"Dioxin — the chemical that forced the evacuation of Love Canal, sparked a wave of lawsuits over Agent Orange and became notorious as the most potent carcinogen ever tested — may be far less dangerous than previously imagined, according to new scientific evidence."
[This followed the ChemRisk revision of Dow's earlier Kociba study]

    "Enough experts have joined the revisionist chorus that some scientists consider a softening of the government's stance toward the chemical inevitable."

1990 June: Nufarm Australia:
Following the public clamour about a dioxin spill into the water supply of Melbourne, Australia, Carlo's HES team were asked to study the health risks. They wrote in one abstract:

During June and July 1990, surface soil samples were taken in the Melbourne metropolitan area and analysed for phenolic compounds, chlorinated herbicides, polychlorinated dibenzo-para-dioxins (PCDDs) and polychlorinated furans (PCDFs).
[It doesn't say who was skilled enough to perform these tests, because the Victorian water experts clearly weren't.]

    A surface soil sample from a Werribee Farm Treatment Complex paddock, where cattle graze on land that is used for filtration of sewage, was also taken and analysed. No phenolic compounds or chlorinated herbicides were detected at the parts per billion detection limits in any of the samples.
[Parts-per-billion limits are no longer considered to be refined enough for endocrine and similar suspect mutagenic measurements. They now need parts-per-trillion.]

    PCDDs and PCDFs were detected in both industrial and nonindustrial sectors of the Melbourne metropolitan area, as well as in effluent from Nufarm Limited, an agricultural chemicals manufacturer in Laverton North, in similar concentrations (toxic equivalents in the parts per trillion range). These concentrations were consistent with background levels identified in other major urban areas.

    There was no evidence of the Nufarm effluent fingerprint in any of the background soil samples analysed. The fingerprint profile of the sample taken from Werribee Farm, although showing traces of the Nufarm effluent fingerprint, was clearly distinct from that effluent fingerprint and consistent with the fingerprint identified in the background soils. The impact of the Nufarm effluent on the area, therefore, was considered insignificant.
[This claim to be able to perform a 'fingerprint profile' is rather dubious when the work is being conducted by an epidemiologist, his secretary and a lawyer.

1990 June: The EPA released two draft reports into the public domain
                  • "Health Effects of Passive Smoking"
                  • "ETS: a Guide to Workplace Smoking Policies"
The EPA's Risk Assessment on Passive Smoking (ETS) claimed that about 3,800 non-smokers died each year from tobacco-caused lung-cancer and other health problems.

    The Tobacco Institute and the cigarette companies were preparing an all-out blitz on the top newspapers in the USA (initially 30 — later top 75) to counter the EPA claims. The plan was to run a series of editorial board briefings utilizing Tobacco Institute, Philip Morris and RJ Reynolds lobbyists.

    They hired Carlo's partner, Maurice LeVois to provide scientific back-up to their claims. He was promoted to newspaper editors as an independent expert who could show they why the EPA was wrong.
[LeVois had no biomedical qualifications whatsoever].

    They also listed national columnists who they consider "fair" or "favourable" to their cause who were to get special material, and the Institute's scientific consultants had distributed op-eds to their local newspapers, incorporating Philip Morris's McGill University closed conference reports and other material. Through commissioned letters-to-the-editor and other materials, they were attacking the EPA's science, and bolstering their claim that the EPA was politicized and biased against the tobacco industry.

    This package of documents includes the

• plan of attack on editorial boards,
• lists of the major newspapers
• the allocation of lobbyists,
• sample letters to be sent
• a long C/V of Maurice LeVois.

We also stand ready to present this scientific evidence to the media. To that end, we would be happy to meet with you and your editorial board to discuss these issues. At your convenience, Maurice LeVois, Ph.D.,an expert in epidemiology and risk assessment, and I would like meet and cover these issues.

    Dr.LeVois' expertise has been called on by the American Red Cross, the Centers for Disease Control, the Veteran's Administration and others (copy of curriculum vitae enclosed). The Tobacco Institute calls on his expertise in his capacity as a consultant.

    I will telephone you later this week to determine your interest, and, I hope, to set up a meeting time.

1990 June: A Tobacco Institute has also circulated this Issues Paper to its Regional and State Divisions. It provides the offical industry line on dozens of topics, including those dealing with "Tight Building Syndrome", "Sick Building Syndrome" and Indoor Air Quality (IAQ) issues

    It also lists full-time consultants who are available to help the various State lobbyists fight any attempts at public smoking bans. They have two categories of consultant:

Environmental Tobacco Smoke (ETS)

• Lawrence Halfen — Environmental Consultations Inc, Grand Rapids, MI
• Larry Holcomb — Holcomb Scientific Services, Olivet MI
• Walter J Decker — WJ Decker Toxicology Services, El Paso TX
• George Carlo — Washington DC
• Maurice LeVois — San Francisco, CA
• David Weeks — Boise ID
• Jack Peterson — Peterson Associate, Brookfield WI
• Joe Pedelty — Holcomb Environmental Services

[Every one on this list is a well-known, long-term science lobbyist for the tobacco industry. These were all considered 'safe' scientists for the State or Regional Directors to contract as witnesses, etc. at Local Ordinance or State Assembly hearings.]

Scientific Witness Teams on Indoor Air Quality

• Gray Robertson — Healthy Buildings International (HBI), Farifax VA
• Simon Turner — (as above)
• Jeff Seckler — (as above)
• Peter Binnie — (as above)
• Jolanda Janczewski — Consoliated Safety Services, Oakton VA
• Nancy Stone — (as above)
• Jon Yereb — (as above)

[Both of these companies was engaged in commercial indoor air quality analysis under a scheme where they were paid by the TI to discount smoke as a source of building problems. They were also available as legislative witnesses and for media tours, to discount smoke as an environmental health issue. ]

1990 Aug: The EPA decided to launch a criminal investigation of Monsanto following evidence that the Monsanto [dioxin - Agent Orange] studies were fraudulently done and that if the studies had been done correctly, they would have shown the connection between dioxin and cancer in humans. This accusation received considerable press attention.

EPA memo of July 1994.

[The action was also inexplicably dropped in 1992, and Dr Cate Jenkins, the whistleblower was repremanded for making the accusations. This was later reversed after many court cases.]

See also the simultaneous publication of the ChemRisk Report of Dioxin - Related Issues by Russell E. Keenan, PhD, to the Arkansas Pollution Control and Ecology Commission

1990 Oct: / E Nufarm Australia:
Around this date the "Assessment of dioxin-related health risks for the Melbourne metropolitan area" by George L Carlo, Kelly G Sund, James Baller. was sent to the Victorian state government.
[Only published later in June 1993 in the Australian Journal of Public Health.]

Abstract: A community health risk assessment was conducted during 1990 in Melbourne for polychlorinated dibenzo-para-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs) released in Laverton North by Nufarm Limited, an agricultural chemicals manufacturer.

    This risk assessment incorporated current scientific knowledge into hazard identification, dose-response assessment, exposure assessment and risk characterisation sections, according to the four-step framework used by the United States Environmental Protection Agency.

    The hazard identification showed that health effects are unlikely to result from general population exposures to PCDDs and PCDFs. The dose-response assessment supported a safety-factor approach for PCDD and PCDF risk assessment. The exposure assessment incorporated exaggerated assumptions to estimate both total daily exposure (203 pg total toxic equivalents of PCDDs and PCDFs, or 2.9 pg/kg body weight) and daily exposure attributable to Nufarm (56.4 pg, or 0.80 pg/kg body weight) under a worst-case scenario. The risk characterisation section found that exposures under 20 pg/kg body weight per day should not induce the aryl hydrocarbon hydroxylase system, which appears to be the starting point for PCDD and PCDF toxicity.

    We concluded that the general population exposure to PCDDs and PCDFs in Melbourne was within the range of acceptable daily intakes used by European and Canadian governments and the World Health Organization, as well as within the range of acceptable daily intakes derived using current scientific knowledge.

See Australian scene  

1990 Oct 9: Carlo and his Health and Environmental Sciences Group present a preview of the Philip Morris "Health Scientist Survey" at the New Orleans Annual Meeting of the Society for Risk Analysis. It is now called "Potential value judgement influences among scientists asked to evaluate the hazards of dioxin, radon and ETS


[This preview must have been considered less than satisfactory by Philip Morris, since the actual release of the studies was delayed for a year. Carlo claims that work on this and the "Bias Study" was done on it in 1990 and 1991 — which is a remarkably long time for a couple of telephone surveys.

    Of course, when the Banbury Conference (below) blew up, they may have decided that Carlo's name as an 'independent scientist' was not a credible concept to sell to the media.]

1990 Oct 22: - 24: Banbury Center Conference
The Banbury Center Conference on dioxins was held over these three days at Cold Stream Harbour. It had been organised by the Chlorine Institute to discuss the EPA's use of Kociba and other research in their risk-characterisation. Independent scientists were not invited, and there were only a few from the EPA, despite it being organised as a joint industry/EPA project..

    In The Dioxin Wars, author Robert Allen (from Sunday Times, UK investigative team) says

The Chlorine Institute then stood back and let Banbury officials organise the meeting and select the participants, requesting only that their consultant Michael Gallo attend as an observer for the Institute.

    The meeting, which was held in October 1990, was attended by 38 dioxin specialists. There was no general consensus among the scientists who disagreed on many points. Some felt that the latest data on dioxin merited a fresh assessment by the EPA and even suggested that the agency had over-estimated the risks from exposure. Ellen Silbergeld, a toxicologist at the University of Maryland, rejected this notion.

    Confident that it could present the conference in a favourable light for industry, the Chlorine Institute employed a public relations company, Edelman Medical Communications to prepare a press pack.

    The package contained a press release from the Chlorine Institute, statements from three scientists, and a background paper by George Carlo who had also attended the meeting as another observer for the Institute.

The press release had been carefully drafted and dioxin had been carefully detoxified. The Institute announced that a consensus had been reached on several key issues, specifically that a threshold level for dioxin existed, below which these chemicals posed no general risk to human health.

    Carlo, in his paper, announced that the meeting had 'reinforced the notion that dioxin is much less toxic to humans than originally thought'.

In 1990 the Chlorine Institute, a chlorine industry trade group with members such as Dow Chemical, Du Pont, Georgia-Pacific, International Paper, and Exxon Chemical Co, organised a conference of dioxin scientists at the Banbury Center.

    Also in attendance was George Carlo, consultant to the Institute. The Institute hired Edelman Medical Communications to publicise any conference outcome that was to the Institute's advantage.

    Following the conference, Edelman sent out a press packet with a background paper put together by Carlo, Edelman and the Institute, claiming that the conference had reached a consensus that dioxin was "much less toxic to humans than originally believed."

    This outraged some of the scientists present who had not reached this conclusion and who felt that they had been manipulated by the Chlorine Institute (Roberts 1991a).

    According to the magazine Chemistry and Industry, the Institute was merely coordinating a "public outreach program" to "capitalise [sic] on the outcome" of the conference. (Quoted in Montague 1991b)

Indeed the industry was able to use the supposed Banbury conference consensus together with the rat tumour re-count to get some States in the US to loosen dioxin standards for discharge of wastes into waterways, below those set by the EPA (Bailey WSJ 1992)
. [They were technically able to do this if they could support their choice of standards scientifically.]

"Flap Erupts Over Dioxin Meeting"

When the Chlorine Institute, an industry trade group, approached Banbury director Jan Witkowski early last year about holding a dioxin meeting; he had no inkling it would turn out differently from the 15 or so other meetings the center runs each year, some of which are also sponsored by industry.

    The Chlorine Institute lined up Robert Scheuplein of the FDA to run the meeting. He then asked Michael Gallo, a toxicologist at the Robert Wood Johnson Medical School in New Jersey, and Cornelius A. van der Heijden, a regulatory official in the Netherlands, to chair the meeting with him. From then on, the Chlorine Institute studiously kept itself out of the picture, say both Witkowski and the meeting organizers.

    The three organizers picked all participants, with one exception: George Carlo, who was invited as an observer for the Institute at its request. Carlo, an epidemiologist and lawyer who heads the Health and Environmental Sciences Group in Washington, DC, is a regular consultant to the Institute.

... with a background paper written by Carlo that none of the organizers or participants had seen — which claimed among other things that the Banbury meeting "reinforced the notion that dioxin is much less toxic to humans than originally thought."

Events then took a bizarre twist when Carlo, who received a copy of Silbergold's letter, called Witkowski [Banbury Center head] to say he had not written the paper after all and had no idea how his name ended up on it.

    Carlo has since launched a massive telephone campaign — calling the participants and this reporter repeatedly — to clear his name. Carlo concedes that he did work with Edelman and the Chlorine Institute in developing the paper but asserts, nonetheless, that "No one has the right to put someone's name on a document."

    Nancy Turett, senior vice president at Edelman, admits to putting Carlo's name on the paper — she says because he was so extensively involved in drafting it. " "The end product is very much a reflection of what Dr Carlo thought should be in it,"" says Turett.

1990 Nov: 8-9: Tobacco: George Carlo is receiving media training through Burson-Marsteller in preparation for him acting as as independent scientific critic of the EPA's Scientific Advisory Board Risk Assessment of ETS (see above, May 1990)

[The Banbury Conference story hadn't broken in the general media at this time]

1990 Nov 10: Tobacco: Philip Morris's Washington strategy meetings with Steve Parrish, Tom Borelli, Amy Millman, Vic Han (misspelled Hahn), Robert Pages and George Carlo. It was a planning meeting to attack the EPA's Risk Assessment. It also lists as attendees:

• Barracuda - Possibly a code name for an adviser to PM - maybe a creative executive from Leo Burnett advertising.
• Herbolberbol - Clearly a nickname. This is probably Bob Herbolsheimer of lobbyist Mannett Phelps, Rothnber & Phillips.
• Burson - It was ccd to Gary Auxier, the Washington strategist of Burson-Marsteller,.
• Shooks - generic for unnamed Shook Hardy & Bacon lawyers.

1990 Nov 30: [Source EPA June 1994 memo] Another Malcolm Gladwell article in The Washington Post, "Greenpeace Digs Deep Into Dioxin Debate"

Greenpeace issued a detailed 44 page critique of the Monsanto studies by Joe Thornton entitled "Science for Sale" which repeated [Dr Cate] Jenkins' [of the EPA] allegations and added several more, followed by a petition to EPA to investigate the [Monsanto dioxin] studies, and held a well publicized press conference.

    The Washington Post reported that: "The EPA said yesterday it is looking into Greenpeace's charges."

---

1991 Jan 24: A comprehensive study of US chemical workers exposed to dioxin in the course of their work at least 20 years earlier was published in the New England Journal of Medicine. The 13 year study was carried out by Marilyn Fingerhut and her colleagues at the National Institute for Occupational Health and Safety on over 5000 men who worked at 12 different factories between 1942 and 1984.

    It found that the workers had a 15% higher death rate from cancer than the US average. Those exposed to low levels of dioxin (about 90 times background levels) had no statistically significant increase in cancers, whilst those exposed to high levels (about 500 times background levels) were 50% more likely to die of cancer (Roberts 1991b, p. 625).

[The editorial in the NEJM said about dioxins that "The hypothesis that low exposures are entirely safe for humans is distinctly less tenable now than before." ]There are three different and highly diverging reports of the same NEJM article:

• New York Times story by Warren Leary — "High Dioxin Levels Linked to Cancer."
• Wall Street Journal article — "U.S. Study Suggests Exposure to Dioxin for Long Periods Can Boost Cancer Risk."
• Washington Post story by Malcolm Gladwell — "Extensive Study Finds Reduced Dioxin Danger."
  
  A later commentary says:

  Gladwell says he chose not to quote the scientist who wrote the editorial because he didn't know whether the author's views represented a scientific consensus. Instead, he quoted George Carlo, whom he identified as "one of the nation's leading dioxin experts."
  
      At the time, Carlo had not published a paper on dioxin in a peer-reviewed journal, a publication that only publishes papers reviewed by scientists in the same field.
  
      More important, Carlo is a specialist in risk assessment and management whose clients then included the Chlorine Institute, a trade group, and Dow Chemical — both affected by dioxin regulations. Gladwell did not cite Carlo's industry connections. No one else was quoted.

1991 Jan 17: & 30 The Agent Orange Act of 1991 passed the House (412—0) on the 29th and the Senate (99—0) on the 30th. This put the National Academy of Sciences (NAS) in control.

1991 Jan 23: Four CEOs of paper companies as representatives of the American Paper Institute visited EPA Administrator William Reilly. They later wrote thanking him:

'We were also encouraged by what we perceived as your willingness to have the agency move expeditiously to re-examine the potency of dioxin and chloroform in light of the important new information that has been submitted with respect to those chemicals,' [truncated]

    [There was now a] 'prevailing view that low-level dioxin exposures do not pose a serious health threat' [and] 'despite this new reality, EPA has taken no tangible or timely steps to revisit its health criteria for dioxin, and has even failed to temper the agency's zeal in acting on the worst risk estimates... '.

1991 Jan 29: Banbury Center Conference fiasco
Ellen S Ebert of ChemRisk has written to Robert K Sells of Bob Sells PR Associates in Little Rock Arkansas on behalf of Dr Keenan of ChemRisk.

[This is the Dr Keenan who organised the Kociba study re-evaluation — thus creating the misleading impression that dioxin was not so dangerous. See the abstract of the re-evaluation article, now commonly ridiculed.

    Elbert writes "... at Dr Keenan's request I am enclosing the following materials pertaining to the Banbury Conference" [Oct 22-24 1990]

• Carlo Report
  [At this time Carlo was with SUNY at Buffalo School of Medicine, and simultaneously chairman of the HES Group, Washington DC.]
• [Linda] Birnbaum Memorandum [EPA]
• Summary by [C.A] van der Heijden [Nat. Inst. of Public Health and Environmental Hygiene in Netherlands]
• Summary by [Robert] Scheuplein [of FDA]
• Summary by [Michael A] Gallo [Robert Wood Johnson Med School, NJ]
• Chlorine Institute Press Release (Draft)
  [Prepared Nov 1 1990 by George Carlo for The Chlorine Institute.]

• Carlo's public-release report questions the value of using animal studies to assess human risk from dioxin exposure and says "scientific evidence strongly suggests that dioxin at very low levels does not constitute a significant health risk to humans.
  
  
• Carlo's Chlorine Institute report, "Biological Basis for Risk Assessment of Dioxins and Related Compounds."
  [Page 1 of this report is missing] It apparently dealt with establishing that dioxins have a non-linear response, because it concludes that there are safe levels of exposure.

  During the conference, it was noted that no one presented a scientifically sound rationale for use of the linearized models for accurately estimating cancer risks for dioxin.
  
      There was support among the scientists for the Margin of Safety (MOS) approach to assessing dioxin's risk which is consistent with the concept of a practical threshold for adverse effects.
  
  [It discounts the original Kociba findings and says] "that the incidence of liver tumors in that study is less than reported originally in 1978, when today's pathologiy classification standards are applied.

• Dr Vernon Houk of the CDC expressed a desire to revisit the dioxin risk assessment position held by that agency.
  
  Dr Scheuplein of the FDA noted that his agency would also consider a change in position based on the new data.
  
  Dr Farland of the EPA was less committal.
  
  
• Report from Linda Birnbaum of the FDA [Note page 2 is missing] She sums up the situation at this time as:

  "Dioxin clearly has the potential to cause serious health effects. However, exposures, except in the few accidental poisoning episodes, have been low. As long as exposures do not increase, dioxin should not pose a health threat.

• The other three reports were not found in this file.[Not from the tobacco industry]

1991 Feb 22: Banbury Center Conference fiasco
Science magazine publishes "Flap Erupts Over Dioxin Meeting," an article about the Banbury Conference fiasco. It expressed the outrage of Ellen Silbergeld at the misrepresentation of her views and those of others at the conference. The article discussed the...

"furor that erupted in early February when participants learned that a public relations firm hired by the Chlorine Institute, which helped pay for the conference, was circulating a "consensus" summary of the meeting"

The three organisers picked all participants, with one exception — George Carlo — who was invited as an observer for the Institute at its request. Carlo, an epidemiologist and lawyer who heads the HES Group in Washington DC, is a regular consultant to the Institute.

    None of the participants Science spoke with, nor even meeting co-organiser [Michael] Gallo, knew Carlo was there as the Institute's observer.

    They also assumed that Edelman [the PR Company] was representing the Banbury Center, not the Chlorine Institute.

See later pages in this package of documents:

See the actual Science article with no applause.

1991 March 1: Lawyer James Baller, George Carlo, and his secretary Kelly Sund have jointly written. "The Agency for Toxic Substances and Disease Registry — A Growing Power in the Hazardous Waste Arena."

    This is a detailed history of ATSDR (The Superfund agency) with a so-called 'critical examination of its activities'. However Carlo and Baller were also collaborating with the ATSDR in preparing promotional material distributed via the Washington Legal Foundation (WLF).

1991 Mar 12: An op-ed, "Thumbs on the scales of Risk?" by George Carlo and Kelly Sund, is published by the Washington Times. The op-ed's byline claims that Sund [Carlo's secretary] "specialises in risk assessment."

    It then quotes Beveridge & Diamond's top lobbyist for the chemical industry (ex-EPA director) William Ruckelshaus on the need for risk assessment to be "based on scientific evidence and consensus only". [presumably, he also favours motherhood and apple pie.] These views are apparently supported by Berkeley biochemist, TASSC advisory board member and tobacco industry friend, Professor Bruce Ames — who is also credited as an "authority on risk assessment."

    The slant of the op-ed is to attack the EPA on its classification of ETS and other harmful substances like dioxins and some pesticides, by suggesting that these assessments are politically motivated.

[Note, however, that no one now seriously contends that "Alar... radon...dioxin" are not all genuine reasons for concern. However the corporate scientific lobbyists claimed that these were all examples of failed doomsaying predictions. They were trotted out to support corporate claims that scientific bias and "fear generated by worst-case risk-assessment" were the real problems. Of course, over-zealous activists also provided the corporation lobbyists with some good arguments.]

    This Carlo/HES op-ed in the Washington Times is a thinly veiled attack on the EPA's ETS Science Advisory Board, and it conforms to the requirements set out in the Philip Morris plan of November 10th. Carlo wrote about his Bias study:

A recent survey by our firm illustrates how "a value-laden process'' can warp sound, objective science.

    We asked 1,461 US scientists questions regarding the health hazards of three substances associated with current environmental health issues: environmental dioxin, environmental radon and environmental tobacco smoke. The purpose was to describe the interaction between science and preconceived judgments that affect policy.

    For dioxin and radon, knowing the name of the substance made little difference in perceptions of risks when respondents were read a series of facts. Yet with environmental tobacco smoke, simply telling them the name of the substance produced radical swings in their assessment of risk.

    According to OMB, there have been overestimates of the risks of dioxin to humans in the environment by as much as 5,000 times or more, which may have cost the public billions of dollars in direct and indirect expenditures.
[Here we have an epidemiologist quoting the White House Office of Management and Budget as an authority on the possible health risks of dioxins!]

    Dr Vernon Houk, the director of Environmental Health for the Centers for Disease Control, has said, "The general public thinks these risk estimates are based on real science, but that simply isn't true."

The American public deserves better than to have to wait 25 years, watching billions of dollars of public and private money expended and significant portions of American agriculture and business destroyed.

    The risks to our society must be assessed, regulated and communicated. Most of us want to save the planet, the children, the dolphins. Few of us know how. But members of the scientific community are developing new methods incorporating real-world assumptions, and that is a good start.

    We can fix the risk assessment problem. It's up to science — good science, unbiased science — to establish a real-world standard and the real-world studies to meet that standard. It is up to responsible journalists to report accurately, clearly, without bias or hysteria. And it is up to the public to demand and to the government to implement, not merely study, regulatory risk assessment reform.

1991 March 22: Banbury Center Conference fiasco
The American Legislative Exchange Council (ALEC) newsletter says that experts were now discounting the dangers of dioxins because of a new epidemiological study of chemical industry workers.

[ALEC was totally funded by manufacturing companies as a way to get access to compliant State and Federal politicians]

Remarked Dr George Carlo, chairman of the Health & Environmental Sciences Group and one of the nation's leading dioxin experts,

"This is very reassuring. Here we have the group of people who have been exposed to higher levels of dioxin than perhaps anyone in the world, followed for a longer period of time than any other study, and it is not bearing out the cancer risk hypothesis. If we were going to see something, we would see it here in spades. And we haven't.

Given the exorbitant costs of dioxin control regulations, state legislators would be well advised to review their own stale standards and modify them accordingly.

1991 Mar 26: Burson Marsteller has set up a press briefing to counter the release of the EPA ETS Risk Assessment categorising second-hand smoke as a Class A carcinogen. They have sent this draft press release to Philip Morris for approval.

    Two old lags who had long worked for the tobacco industry, Paul Switzer of Stanford University and Joseph Fleiss of Columbia University, were to present their conclusions about the poor quality of the EPA's work. They were prepared to say:

"That the scientific evidence is conflicting and does not support such conclusions."

Because of the hostility to any views, no matter how authoritative, which contradict anti-tobacco sentiment, the two eminent scientists are prepared to speak only on the condition that they not be publicly identified.

In Addition: Dr George Carlo is prepared to detail the results of a study conducted by his firm that indicates such personal bias against tobacco in the scientific community that the nature of the attacks becomes immediately understandable and any results highly questionable.

The scientific presentations will be buttressed by Steve Parrish, General Counsel of Philip Morris, who will describe the scientific and medi,a environment which has produced the attacks - outlining significant tobacco industry mistakes in dealing with it - will acknowledge the current social climate against smoking and will describe work by his company which points toward solutions.

This presentation will be made only to media columnists willing to agree to protect the identities of the two aforementioned scientists [Switzer and Fleiss] starting with Peter Huber, Warren Brooks and Fred Barnes.
• Huber was the 'junk-science' consultant at the Manhattan Institute who wrote a column in The American Spectator
• Brooks and Barnes were far right-wing columnists and tobacco industry supporters.

    If those columns could be obtained, and that is by no means certain, then other media opportunities may suggest themselves, but otherwise the prognosis for media support or even balance must be regarded as bleak.

1991 Apr: - May Philip Morris made a number of payment to Thorne Auchter for services related to the EPA and OSHA. [Auchter was also a silent partner in George Carlo's science for sale operation Health and Environmental Sciences (HES)]

• Apr — $ 1,728.37 + $1,668.20 + $4,756.80 + 1,931.50
• May — $1,460.50

• Jan — $4,435.00 + $ 86.95 expenses
• Mar — $5,600.00 + $67.40 exp
• Apr — $5,600.00 + $67.40 exp
        — $8,840.00 + $65.65 exp
• May — $8,840.00 + $65.65 exp
• June — $13,019.00 + $36.00
        — $6,320.00 +$150.20 exp
• Aug — $12,707.50 + $182.16 exp
• Oct — $6,671.50 + $175.93 exp

[These appear to be monthly consultancy time-charges. They are each coupled with what appears to be Washington-to-Dulles two-way cab charges.

    They are probably expense claims for Carlo's travels to talk to the media ( Philip Morris would have set up his schedule and paid the airfares direct.)]

See page 8  

1991 May: ('spring') Environmental Claims Journal [insurance industry] publishes a paper by Carlo, "New Science in Risk Assessments." It is another attempt to extract the maximum from of the 'Health Scientists Survey' to attack the EPA:

In a 1990 survey of over 1,400 American public health scientists from government, industry and academia, more than 90 percent of the respondents indicated that they believe public health funds in the US are being misdirected by the government.

1991 May: At a conference sponsored by Syntex (the company largely responsible for polluting Times Beach), Vernon Houk was interviewed by a reporter with the St Louis Post Dispatch as saying that he had made a mistake in urging the federal government to evacuate Times Beach, and that "many scientists now believe dioxin isn't as bad as we thought." He was then quoted in a front-page New York Times article by Keith Schneider.

    It later transpired that Houk's CDC proposal for relaxing dioxin standards was copied word-for-word from reports given to him by the paper industry. [Waste Not, 1991] [Keith Schneider attributed to some 'expert' his own made-up statement that exposure to dioxin was "no more harmful than a week of sunbathing". Twenty major newspapers then paraphrased the NY Times article, an used Schneider's fictitious statement to lambast scientists for sowing panic.]

1991 May: Three years before he retired through the revolving door, Dr Vernon Houk, Director of the Center for Environmental Health and Injury Control, back-tracked and announced that he believed dioxin was only "a weak carcinogen'. Houk had been the authority behind the Times Beach scare.

Houk's statements formed the "news hook" that allowed [Malcolm Gladwell of] the New York Times to climb on board with its own page-one story August 15, 1991: "U.S. Officials Say Dangers of Dioxin Were Exaggerated."

    With the Post, the Times, Houk and Reilly all speaking with one voice, the "detoxify dioxin" campaign was clearly succeeding.

1991 May 15: Payments made to the chemical industry's defence witnesses by Syntex, IPC and Nepacco in Times Beach dioxin cases.

    This comes from the evidence of Dr Gerson Smoger, the lawyer of a large number of Times Beach dioxin victims
[Carlo has occasionally claimed that he worked FOR the Times Beach VICTIMS]

1991 May 28: Tobacco lawyers Shook Hardy & Bacon are billing Tom Borelli at Philip Morris for work done quite independent of their work for the Tobacco Institute. They are charging PM $1,753.33 for reading and giving legal clearance on...

... an ETS manuscript, ETS Fact Sheets, and the Carlo paper.

1991 June 6: Carlo's OTA/dioxin associate Michael Gough is the keynote speaker at a Washington luncheon mounted by the National Chamber Foundation (the lobby arm of the US Chambers of Commerce) on "Dioxins and the Risk Assessment Process."

Philip Morris's representative [Mayada Logue] comments.

Michael Gough from the Office of Technology Assessment (OTA), the research arm of Congress, will be talking about dioxin and the risk assessment process.

    Gough was later quoted in a newspaper article [Washington Times 15 Apr 91 - "EPA to rule on risk of Secondhand Smoke"] as saying: "I am not convinced that (secondhand tobacco smoke) is responsible for anything more than an increased occurrence of colds in children".

1991 June 20: The New England Journal of Medicine (NEJM) has published a letter from George Carlo, Kelly Sund, et al (HESG) which appears to take a contrary position to JC Bailar III on "Dioxins and mortality from cancer" It makes the claim that

Respiratory cancer is excessively difficult to link to dioxin because the researchers are unable to control for cigarette smoking and occupational exposure to other substances.

1991 Jul: /E Philip Morris is compiling a two-part book to attack the EPA's Risk Assessment of ETS,

The purpose of Part I of this book is to provide a clear, concise picture of the science on ETS and the EPA's risk assessment process.

    Part II provides an overview of the status of indoor air quality research and the role of ventilation in addressing the true causes of the problem, often wrongly attributed to ETS.

The Health and Environmental Sciences Group, an independent scientific consulting firm, conducted a survey of 1,461 US scientists to determine whether there were preconceptions among scientists on risks related to certain substances undergoing risk assessments by EPA. (See Appendix          ).
[Leaving space for the Appendix number, when it was finally written.]

• Half the scientists were given brief descriptions of the available scientific data on three substances, identified only as x,y and z.
• Half of the scientists were given the same brief descriptions; however, the substances were identified: dioxin, radon and ETS.

Based on the information, the scientists were asked to estimate the degree of environmental hazard and perceived health risk posed by the substances.

(This entire section will be held until publication of Carlo survey)

1991 July 31: Maureen Jablinske, Research Associate with Carlo's Health & Environmental Sciences Group, has written to Tom Borelli at Philip Morris, sending him risk tables and saying:

Here are additional tables which include example of relative risks less than 2.0, deemed insignificant from a public health perspective.

    George would like to discuss this and other relevant matters with you in the near future.

1991 Aug 15: Banbury Center Conference fiasco
The New York Times quoted both the CDC's Vernon Houk and the EPA Director Reilly — both of whom believed chemical industry lobbying claims that the scientists had reached a consensus agreement on dioxins at the Banbury Center meeting.

    The editorial and two front page stories all downplayed the hazard of dioxins:

One article headlined 'U.S. Officials Say Dangers of Dioxin Were Exaggerated' stated that "Exposure to the chemical, once thought to be much more hazardous than chain smoking, is now considered by some experts to be no more risky than spending a week sunbathing."

    The other article called for relaxation of "the current strict and costly standards" for dioxin.

1991 Sep 21-22: The International Congress on Dioxin was held at Chapel Hill, North Carolina

1991 Sep 23: Banbury Center Conference follow-up
The International Congress on Dioxin, held at Chapel Hill, North Carolina became the subject of an expose of the lack of intelligent balance exhibited by National Public Radio.

[NPR's] Morning Edition host Bob Edwards announced that scientists were gathering in North Carolina to discuss recent studies suggesting that "the dangers of dioxin may be overrated."

    NPR science reporter Richard Harris led off with interviews with two government scientists, Michael Gough of Congress's Office of Technology Assessment and Linda Birnbaum from the Environmental Protection Agency. Both suggested that new studies might lower estimates of dioxin's danger; Gough was quoted saying that the risk of cancer from dioxin "may be zero."
[He later claimed you could eat a plateful of breakfast cereal soaked with dioxin instead of milk!]

    These remarks were countered by those of public interest activists: Ellen Silbergeld, a toxicologist identified as working for the Environmental Defence Fund, and Paul Connett, an "anti-incinerator activist."
[Incinerators also produce dioxins.]

    Harris also cited an unnamed federal official [Vernon Houk] who had ordered the dioxin-related evacuation of Times Beach, Mo., who now says the evacuation was unnecessary.

In April 1993 FAIR published a critical report of the NPR's treatment of this event under the title "An NPR Report on Dioxin: How "Neutral" Experts Can Slant a Story, by Charlotte Ryan.     She wrote about her four-month investigation into the reporting standards of National Public Radio (especially All Things Considered and Morning Edition) which had found that NPR tended to assume that government sources were neutral and that statistics-spouting scientists were objective, both dangerous assumptions in a field as politically polarized as environmental science. Consider, for example, an NPR report on the debate regarding dioxin regulation.     These remarks [Gough, Birnham and Houk] were countered by those of public interest activists: Ellen Silbergeld, a toxicologist identified as working for the Environmental Defense Fund, and Paul Connett, an "anti-incinerator activist." The last source quoted was George Carlo, identified by NPR as "a consultant for government and industry." Carlo claimed that activists were politicizing scientific research by charging bias when new research results ran counter to their activist agenda. The EXTRA article iwas directed mostly at attacking the National Public Radio's lack of checking and basic research. What's Wrong With This Coverage?     At first blush, NPR's report has the aura of fair play. Two apparently neutral sources, government scientists, set the stage, explaining the significance of the issue. Counter opinions by activists were then cited, with a final wrap-up from an independent consultant.     Beneath the apparent "balance," however, the story was tilted toward corporate interests. The segment's lead, "Recent studies suggest the dangers of dioxin may be overrated," is straight from the chemical and paper industries' public relations campaign.     NPR framed the government scientists it cited as neutral experts, pinning their story to the claim by the Office of Technology Assessment's Michael Gough that new scientific data calls into question the toxicity of dioxin. Reconsideration of dioxin standards by the EPA, however, was based principally on industry-funded studies, one of which was written by Gough himself while on sabbatical from his government job.     And according to an investigation by Jeff Bailey in the Wall Street Journal (2/20/92), the EPA's [Linda 'Sheila'] Birnbaum was influenced by a Chlorine Institute conference to urge EPA to consider the possibility that there is a "safe dose" of dioxin. (Birnbaum, according to the Journal report, has since altered her opinion.)     The unnamed federal official who regretted the evacuation of Times Beach was Dr Vernon Houk, whose work with the US. Public Health Service has been criticised by Congress, the National Academy of Science and others. In the fall of 1992, In These Times (9/25/92) reported that Houk "admitted copying virtually verbatim from paper industry documents in proposing relaxed standards for dioxin."     The NPR report portrayed these scientists as objective experts, while activists were presented as the only partisan players. However, though Michael Gough now works for government, his research was previously funded by the paper industry. George Carlo, whom NPR described only as a consultant, was identified by the Wall Street Journal as a $150/hour employee of the chemical industry's Chlorine Institute. By contrast, NPR did not mention that "anti-incinerator activist" Connett is also a scientist, with a Ph.D. in chemistry.     Nor did the report acknowledge recent studies stressing dioxin's toxicity published in leading medical journals like the New England Journal of Medicine and the Journal of the American Medical Association.     While appearing to reflect diversity of opinion, NPR's report on dioxin fell prey to what the Journal's Bailey described as a "well-financed public relations campaign by the paper and chlorine industries." Buying into mainstream journalistic assumptions about scientific objectivity and government neutrality, NPR did not help its listeners understand how federal government regulation and environmental research have been politicised."     (Source: EXTRA! April/May '93)

1991 Oct 21: John Graham at the Harvard Center for Risk Analysis [which is not a part of the University or the School of Public Health] has written to David Greenberg at Philip Morris promoting his organization and seeking a donation.

    He wants a face-to-face meeting "to learn more about the risk-related challenges that you face" and $25,000 for each of the following two years to "help the Center expand its public policy activities." He boasts that:

The Center has been launched primarily with gifts from the following corporations: the Amoco Company, Bethlehem Steel Corporation, British Petroleum, Chevron Corporation, The Coca Cola Company, Dow Chemical Company, Eastman Kodak Company, Exxon Corporation, General Electric Corporation, General Motors, lnland Steel Industries, Merck & Company; Mobil Oil Corporation, the Monsanto Company; Pepsico Incorporated, Rohm and Haas Company, Texaco, Union Carbide Corporation, and Westinghouse Corporation.

    Government support has also been provided by the Centers for Disease Control, the US Department of Transportation, and the National Science Foundation. The Center is now booking to a broader base of industrial sources to supply critical funding for the ycars ahead

Public Citizen
A later Public Citizen expose on John D Graham and the HCRA says: Graham's letter to [Philip Morris] noted that the Center had "major projects underway in carcinogen classification, risk assessment, public health priorities, and the use (and misuse) of risk numbers in environmental legislation."

1991 Oct 28: Philip Morris USA now has a detailed plan for attacking the EPA and OSHA and other regulators. It allocates specific tasks to its main disinformation executives:

• TB = Tom Borelli who runs Scientific Issues/S&T in the USA
• HGA = Helmut Gaisch (who runs the Scientific Issues/S&T in Europe)
• JB = James Bowling, special assistant to the CEO
• MP = Mary Pottoroff, major project manager
• RP = Robert Page, manager Scientific Issues
• ML = Mayada Logue, assistant Scientific Issues
• SCP = Steve Parrish, Vice President, Corporate Scientific Affairs
• TI = Tobacco Institute
• CORP.AFF = PM International Corporate Affairs under Andrew Whist

Establish a coalition of business groups and others to reform the risk assessment orocess of the federal government
— Executive Order
— White House office of Science and Technology
— )oin the White House committeee on Environmental issues
— Publication/presentation of risk assessment papers ; Carlo Studies

1991 Oct 29: Robert Page of Philip Morris is commenting to his superior Steve Parrish on the begging letter from John Graham (Oct 21)

My reaction: I think that a meeting should be arranged with Graham when he calls [David] Greenberg [PM Washington] and that you should try to attend. It doesn't hurt to talk to the guy — he says: "It is important for me to learn more about the risk-related challenges.that you (PM) face."

    Why not take him up on the offer? Sure, he's after $ to help support his Center, but whether or not PM decides to contribute, it's more important to meet him and perhaps get 'looped in' better with his activities.

    From all that Mayada [Logue] has learned, he is a key player in all this risk analysis stuff that's currently going on in the government. (Depending on the 'vibes' you guys get when you meet Graham, I would also be in favor of PM becoming a contributor to the Center.)

1991 Nov: The Journal of Toxicology and Environmental Health published the Dow Chemical re-evaluation of Richard Kociba's original findings that dioxins were producing cancer in female rats. [The Squires/Chemrisk study]

The chronic bioassay of [dioxins] reported in 1978 by Kociba et al. has been considered to be the primary evidence supporting its carcinogenicity, and is the basis for most dioxin regulations in North America and Western Europe.

    Because the histopathological criteria for proliferative lesions in the rat liver have changed significantly since 1978, a reevaluation of the liver slides was conducted recently by an independent panel of pathologists. Using current National Toxicology Program criteria, their study showed, in contrast to the original findings, that about two-thirds fewer tumors were present in the livers of female Sprague-Dawley rats.

    These results indicate that the carcinogenic risk to humans from exposure to 2,3,7,8-TCDD is at least 16-fold lower than previous estimates derived from the Kociba et al. (1978) bioassay.

1991 Nov 6: The Nufarm dioxin spill: Greenpeace in Australia published "Media lies and the new McCarthyism" The organization was under attack for its 'scare-mongering' about the dangers of the Antarctic ozone hole. Also:

The present cause cèlébre of the green-bashers is NuFarm, a Melbourne-based chemical company forced to close temporarily and submit to Australia's first environmental audit, at a cost to it of $5-6 million, following a spectacular Greenpeace action in 1990.

    Greenpeace had discovered dioxins and furans in the company's discharges into Melbourne's sewer system, with the possibility these could find their way into the food chain via meat from animals raised at the Werribee sewerage farm.

    The company had been warned previously over its waste-dumping practices, and is now facing revocation of its licence to discharge chemical waste into the sewers because of its refusal to sign an agreement with Melbourne Water. Unless it signs the agreement or finds another method of waste disposal, it could be forced to close by early 1992.

    The 1990 [Victorian government] audit eventually found that the company was not discharging dangerous levels of dioxins or furans, a finding that Greenpeace disputes, claiming there is scientific disagreement. Some scientists now say that dioxin is less dangerous to humans than previously thought, a dramatic departure from the previous acceptance that it is one of the most toxic chemicals known.

    As a result of the Nufarm episode, the group has been widely accused of using the tactic of the big lie. Whether or not Greenpeace was right in all details of its claims against Nufarm, the real big liars of our time are those who seek to conceal and underestimate the extent of the environmental and social problems facing our planet.

1991 Dec: [Carlo claim]

As Chairman of Health & Environmental Science Group, Carlo headed a pesticide industry task force to evaluate the relationship between pesticides and cancer.

In December 1991. an independent scientific review panel was convened hy Drs. Ian Munro and George Carlo to evaluate critically the methodology and findings of a study by Hayes et al. (1991). "This independent peer review was supported hy the Industry Task Force II on 2,4-D Research Data.

[Warning: This is a very large file]

1991 Dec: The HES team has completed the ['Bias Study') "Health Scientists Survey: Identifying Consensus on Assessing Human Health Risk" for Philip Morris. The HES group consists of George Carlo, Sydney D Pettygrove, Kelly Sund, Maureen Jablinske, and Nora L Lee. They have come to the pre-ordained conclusion that:

1. Weight of evidence approach is preferred
2. Corroboration between animal studies and human studies important in identifying public health risk
3. Decisions about human health risk based solely on animal models are suspect
4. Strong belief that the public does not understand public health risk information
5. Strong belief that public health dollars in the United States are not targeted properly to reduce environmental health risks

Ackowledgment — This survey was conducted during 1990 and 1991 with the support of the Institute for Regulatory Policy.[Thorne Auchter's think-tank]

Institute for Regulatory Policy

The Federal Focus, Inc operation was owned and operated by two of Carlo's closest friends: Thorne Auchter and Jim Tozzi. It was financed by Philip Morris and some chemical companies as a non-profit 'policy and educational institute' which could be used for multiple lobbying purposes: it eventually had a half-dozen subsidiaries known collectively as 'Federal Focus Institutes'.     Tozzi and Auchter also ran Multinational Business Services (MBS), a lobbyshop which specialised in influence at the White House via the Office of Management and Budget (OMB). This was essentially a partnership between two old Republican lags, and Carlo and this pair appears to have shared a large deep-sea game fishing boat moored in Florida. We know from evidence given under oath at Carlo's divorce that he had a secret partnership in HES with Auchter.     Philip Morris funded the establishment by MBS of the Institute for Regulatory Policy sometime in late 1991 [It cost them $880,000]. From that point on Jim Tozzi generally ran the Federal Focus operations and Auchter ran the Institute for Regulatory Policy and some other think-tanks/policy operations. [George Carlo's "Bias Study' project was released and published under the Institute for Regulatory Policy (IRP) name. The IRP also had Market Strategies conduct a nationwide survey of public attitudes to 'sound science' to help APCO and Philip Morris in the development of TASSC.]     Auchter was appointed in 1992 to President Bush's "Risk Assessment and Management Commission". He also specialised in junket partnerships with the State Governors Association and 'Mayoral mandate' organizations — which provided access to bribable administrators likely to control the introduction of public smoking bans.     The IRP first appears in the tobacco archives in a list of participants at a White House meeting with Vice President Dan Quayle on December 17 1991. The other participants were all corporate lobbyists involved in promoting 'tort reform' collectively under the Citizens for Civil Justice Reform (CCJR) banner. This same group also created CURE (Coalition for Uniform Risk Estimation) which was run by Thorne Auchter and Wayne Valis with the assistance of VP Dan Quayle — in parallel with the Qualyle-Valis Council on Competitiveness. See more on MBS and IRP Payment details

1991 Dec: This is a tobacco industry power-point lecture slides for Carlo's Health Scientist Survey. The slides show some data which is contrary to some of their later claims (they 'adjusted' some of the figures):

Note that: 63.7% of the expert scientific respondents agreed that a Risk Ratio of 1.3 in animal studies could be interpreted as demonstrating "Probably Health Risk"

    Only 11.4% thought it showed "No Health Risk."

1991 Dec: Tobacco lawyers Shook Hardy & Bacon report on Carlo's Health Scientist study:

A recent survey of human health scientists reportedly suggests that many scientists feel that federal funds spent for reducing environmental health risks are improperly targeted.

    The December 1991 survey was conducted by Dr George Carlo, chairman of the Health and Environmental Sciences Group, a Washington-based scientific consulting firm specializing in regulatory issues, and was commissioned by the Institute for Regulatory Policy, a regulatory reform group headed by former OSHA chief Thome Auchter.

    Given to 1,292 health professionals in epidemiology, toxicology, medicine and other disciplines, the survey reportedly suggested that 81 percent of the respondents believe that "public health dollars for reduction of environmental health risks in the UlS. are improperly targeted." Eighty-seven percent of the respondents reportedly found it impossible to calculate human cancer deaths based solely on animal data.

Philip Morris Corporate Scientific Affairs This is a large pile of documents and receipts from the Philip Morris group in early 1992. It is worth downloading, simply to get an idea of the range of nefarious activities this one tobacco company was involved in. It includes:

• Structural diagrams of the Corporate Scientific Affairs division and staff of the (This is after the Nov 1989 restructure. It is now under the control of lawyer Stephen C Parrish (who was also PM's Special Counsel).
• Also see $300,000 check to be paid to Covington & Burling (June/Aug 1991) as a supplementary grant for the Asian ETS Consultants Program [Whitecoats recruitment] followed by another $10,000 for some EPA work
  • C&B was laundering payments of $440,111 to the Asian WhiteCoats for the first half of 1991 (with $71k for C&B's expenses, etc) and were currently carrying nearly half-a-million dollars owed by the tobacco industry. The overall budget for the project had been originally been set at $1.1 million for the recruitment of 12 to 15 WhiteCoats. It had since expanded.
• PM Corporate Scientific Affairs contract with Burson Marsteller (PR). B-M's billing rates (for different states) extended from $350 per hour down to $50 per hour, with most client service work in the $200 p.h. range. They were paid roughly $40,000 (+ expenses) per month by this division of Philip Morris.
• Barrera Associates: Lisa Barrera's EPA surveillance operation is also contracted here, with monthly payments of $20k. She had insider contacts in the agency who leaked information.
• Articles of Association and Bylaws for the Center for Indoor Air Research (CIAR). Philip Morris had instigated this scientific front organization and C&B had prepared the incorporation documents. Philip Morris had put in $3.1 million, RJ Reynolds $2.2 m, and Lorillard $0.6 m
• The Business Council on the Reduction of Paperwork, a corporate front for continued attacks on the regulating agencies (which changed its name regularly), was to receive a "Grant-in-aid' of $300,000 from Philip Morris.
• Federal Focus Inc. (run by Carlo's partners/friends Jim Tozzi and Thorne Auchter) was also to receive a "Grant-in-aid" of $300,000. These two payment were handled by Amy Millman and made in two checks to be hand delivered. [Federal Focus would normally have been paid via MBS direct.]

Also attached to the pile are the accounting details of the Corporate Scientific Affairs division which is divided into two — Switzerland's FTR Science & Technology (S&T) covering Europe, and America's PM USA S&T covering the US domestic lobbying. [aka Scientific Issues]

• Paperwork on a dispute about the accounting allocation of $8.7 million in costs from PM's European (FTR) Science & Technology division in Neuchatel, Switzerland: 63% is to be allocated to Corporate Scientific Affairs (the US disinformation division).
  
      The job description of this Swiss FTR unit was now:

  • Providing strategic input on proactive measures regarding ETS and IAQ;
  • providing Corporate Affairs personnel with scientific support with respect to ETS and IAQ issues;
  • providing advisory and spokesperson services regarding ETS and IAQ in contacts with scientists, journalists, politicians and various institutions;
  • acting as a liaison between Corporate Affairs personnel and Covington & Burling regarding the consultants program [WhiteCoats];
  • monitoring the scientific literature regarding ETS;
  • providing Corporate Affairs personnel with scientific support regarding specific issues such as health warnings, regulatory issues and the efforts of various third-party institutions, and;
  • advising senior management on matters relating to ETS and IAQ.

• Tom Borelli (S&T in the USA) has an accounting for his own division which includes budgets and expenditure deals under the headings:
  • Staff expenses
  • Seminars and Workshops
  • Scientist consultants (Rylander, Tso)
  • Contributions (National Journalism Center)
  • Consultants (all propaganda producers)

    • Hines & Quinn $100,000 (Setting up a journalist network)
    • Burson Marsteller - $0.5 m (PR)
    • K Cleveland $25,000 [This is syndicated columnist Kathleen Parker who publicised their claims that passive smoking had no effect on children.]
    • George Carlo $25,000 (HES operations)

1992 Jan 21: Transcript of Legislative Assembly of Ontario, Standing Committeee on Social Development, hearings on the Waste Management Act, 1992 George Carlo's appearance was as a witness at the request of the St Lawrence Cement Co. of Mississauga.

Dr George Carlo is here. Dr Carlo is chairman of the Health and Environmental Scientists [sic] group in Washington, DC.
[Note: 'chairman' of the 'scientists group']

    He is here as an independent adviser. He is chairman of the scientific advisory board reviewing use of waste fuels in cement kilns in the United States, particularly the health and safety aspects associated with that.
[Again, the misleading inference that his evidence is as an 'independent' head of a review board.']

    Dr Carlo can answer any questions and would be available at any time to the committeee.

1992 Jan 23: Tom Borelli is flying to Washington to meet with Richard T Hines to discuss their work in support of Philip Morris's ETS projects.
[Hines & Quinn — also associated with the Southern Confederacy and the CIA.
      They ran an op-ed writing bureau and had links to the (unfettered free-market) National Journalism Center — and were attempting to set up a similar operation in Eastern Europe with Philip Morris money, via the Atlas Network.]

    Borelli's trip was cancelled due to weather. But he met with Burson-Marsteller and Joseph Wu on the 28th.
[Wu was the tame scientist from NY Medical College who Carlo hd helped recruit in 1989]

This document (Page 161) records that the budget for...

Borelli's Science & Technology division of PM (via Borelli) also:

• Gives $25,000 to the National Journalism Center.
• Gives $25,000 to Joseph Wu's New York Medical College.
• Employs Hines & Quinn as consultants for $100,000.
• Employs "Carlo" as a consultant for $25,000.
  [This would be a Carlo consultation fee, not HES project work.]

See page 161

1992 Jan 24: The Philip Morris/APCO controlled EPA Watch newsletter has a leaked preview of Carlo's "Health Scientists Survey".
[Environmental International, the journal which published it, only received their copy of the paper March 13.]

Survey says scientists feel US funds for reducing health risk misdirected.

Most human health scientists say that federal funds spent for reducing environmental health risks are improperly targeted, according to a new survey condiicted by an independent science group. The findings suggest the need for overhauling the way the federal government makes environmental risk decisions, its sponsors say.

    Some scientists warn, however, that the survey questions were asked in isolation, and did not reflect "real world" or case study scenarios.
[A very clever attempt at being seen as an even-handed commentator.]

    The December 1991 survey was conducted by Dr George Carlo, chairman of the Health & Environmental Sciences Group, a Washington-based scientific consulting firm specializing in regulatory issues, and was commissioned by the Institute for Regulatory Policy (IRP), a regulatory reform group headed by former Occupational Safety & Health Administration chief Thorne Auchter

    In the survey, 1292 health professionals in the field of epidemiology, toxicology, medicine and other disciplines were interviewed.

    Sources associated with the project say they plan to present the findings to EPA's Science Advisory Board staff, and share the survey results with members of Congress.

    Key findings of the survey show that

• 81% of the respondents believe that "public health dollars for reduction of environmental health risks in the US are improperly targeted."
• 87% responded that it is impossible to calculate human cancer deaths based solely on animal data, with
• the data from the survey "supporting a better method for assessing environmental health hazards, a 'weight of evidence' approach that takes all plausible human and animal data into account,"
• according to documents accompanying the survey, IRP sources say the survey shows the need to
  • make risk assessment as objective as possible;
  • make the results of risk assessments more understandable and
  • establish more effective prioritization of limited, governmental resources
  .

EPA Watch & Institute for Regulatory Policy (IRP)

Note that EPA Watch was edited by Bonner Cohen and part-written by Steve Milloy, the future junk-science director of TASSC and the web site.     The newsletter was secretly funded by Philip Morris via a think-tank front group called the American Policy Center run by Tom DeWeese. A few months later Burson-Marsteller's Tom Humber suggested to Philip Morris's Ellen Merlo that they revise their public relations program before the OSHA rule making on workplace smoking, and the release of the EPA's Risk Assessment in order to... "Discredit the EPA report on ETS specifically and the EPA generally" Among his many suggestions [including "Sue the Bastards"] he suggests: EPA Watch We should specifically discuss the potential for EPA Watch as a part of media and other efforts. I have previously discussed with Tom Borelli several ideas for expanding the impact of EPA Watch and the reputation of Bonner Cohen as an expert on EPA matters. The Institute for Regulatory Policy     [This was started] specifically to address the panoply of problems in the risk assessment and regulatory process identified by OMB in August 1990. IRP is an existing mechanism that currently is in the best position to assemble and mobilize a wide variety of business groups, corporations, local governments and other parties concerned about, or victimized by, EPA excesses.     Burson-Marsteller has worked with IRP, and its Director, former OSHA Administrator Thorne Auchter, since its inception, and has several clients who are among IRP's key supporters. [It is a tribute to Philip Morris's strict compartmentalization that Humber doesn't appear to know that the IRP was a Philip Morris creation. He just sees it as yet another astroturf that it is available for use by any corporation with the inclination to give it a generous grant. However he knew about the EPA Watch and Cohen-Milloy connections through APCO. He was helping them set up a Euro-TASSC operation.]

1992 Jan 28: Philip Morris's "Procurements & Payments" file for the Scientific Affairs (See last pages) lists Carlo as being paid $25,000.

[This would be for Carlo's personal consultancy ('witness') work. The Bias Study and the Health Scientist Survey would have been paid separately]

1992 Feb: Consumers Research reported a speech by Vernon Houk where he claimed that the residents of Times Beach had been evacuated needlessly:

In summary, with the exception of chloracne... there are no convincing data for the association of dioxin exposure in humans, with early mortality, adverse reproductive outcomes, or chronic diseases of the liver or of the immune, cardiovascular, or neurologic systems.

    The overall cancer question is not settled, but if dioxin is a human carcinogen, it is, in my view, a weak one that is associated only with high-dose exposures. [Consumer's Research magazine was run on the side by the same group who ran the National Journalism Center — and it was editorially available to any company which gave the NJC a healthy grant.]

1992 Feb: The Risk Analysis journal publishes Carlo's "Bias Study" under the title. "The Interplay of Science, Values and Experiences Among Scientist Asked to Evaluate the Hazards of Dioxin, Radon and ETS"

    This study becomes widely cited by tobacco friendly scientists. But it is ignored by mainstream scientists, and seen as a thinly veiled attack on the European 'precautionary principle" — an approach generally applied only when it is difficult to accurately quantify the risk associated with certain actions/pollutants.

To investigate the extent to which personal values and experiences among scientists might affect their assessment of risks from dioxin, radon, and environmental tobacco smoke (ETS), we conducted an experiment through a telephone survey of 1461 epidemiologists, toxicologists, physicians, and general scientists. Each participant was read a vignette designed to reflect the mainstream scientific thinking on one of the three substances. For half of the participants (group A) the substance was named. For the other half (group B), the substance was not named but was identified only as Substance X, Y, or Z.

    Knowing the name of the substance had little effect on the scientists' evaluation of dioxin, although those who knew the substance to be dioxin were more likely to rate the substance as a serious environmental health hazard (51% vs. 42%, p= 0.062).

    For radon, those who knew the substance by name were significantly more likely to consider it an environmental health hazard than were those who knew it as substance Z (91% vs. 78%, p<0.001).

    Participants who knew they were being asked about ETS rather than substance X were significantly more likely to consider the substance an environmental health hazard (88% vs. 66%, p<0.001), to consider the substance a serious environmental health hazard (70% vs. 33%, p<0.001), to believe that background exposure required public health intervention (85% vs. 41%,p<0.001), and to believe that above-background exposure required public health intervention (90% vs. 74%, p<0.001).

    These findings suggest that values and experiences may be influencing health risk assessments for these substances, and indicate the need for more study of this phenomenon.

In so far as the evidence to be reviewed comprises epidemiologic data and statistical analysis of that data, it requires evaluation, inference and judgment. Thus, opinions as to the inferences etc. to be drawn from epidemiologic data differ from scientist to scientist.

    Human nature being what it is, there is inevitably a degree of subjectivity involved and considerations of "social" or "political" correctness influence such deliberations.

1992 Feb 7: Philip Morris is circulating a memo about the "Health Science Survey on Risk Assessment." It is portrayed as proving that the public over-reacts to environmental health threats, and that Federal funds in the area of regulation and research are being misallocated. The executives are told that:

The attached survey of 1292 epidemiologists, toxicologists, clinicians and other health professionals was conducted by Dr George Carlo, chairman of the Health & Environmental Sciences Group (HES).

    HES is a consulting firm located in Washington, D.C. which specializes in regulatory issues. The survey entitled "Identifying Consensus on Assessing Human Health Risk" was commissioned by the Institute for Regulatory Policy (IRP). IRP is a regulatory reform group lead by Thorne Auchter, former head of the Occupational Safety & Health Administration.

1992 Feb 7: The Wall Street Journal revealed that the Georgia-Pacific Company (a paper company later owned by Koch Industries) was forced to compensate two residents downstream of their mill $4.2 million over dioxin residues.
[The Koch Brothers through various family foundations were, and still are, the major funders of various libertarian think-tanks and policy institutes supporting the chemical industry over the dioxin war.]

    Another 159 lawsuits has been filed against the company — which was not insured. Dioxins were also produced by incinerators and by cement kilns which had taken to using hazardous waste (mainly old tires) as a fuel,

    [Also from another source which doesn't mention the Koch family]

Georgia-Pacific Co.— a major paper producer — recently lost two dioxin lawsuits in which juries awarded $4.2 million to residents living downstream of its paper mill on the Leaf River in New Augusta, Mississippi.

    Georgia-Pacific has been named in 159 additional lawsuits filed by 8209 plaintiffs who claim they suffered emotional harm after eating fish contaminated with dioxins from the Georogia Pacific Plant, [and the] insurance carriers say their policites don't cover damages in lawsuits like these.
[ George Carlo had become a consultant to the trade association representing the cement kiln and incinerator industry.]

1992 Feb 22: Executive Order on Regulatory Risk Assessment:Jim Boland (Assistant to the CEO/Chairman of Philip Morris) to Craig Fuller (head of PM's domestic disinformation activities and ex-Chief of Staff in White House) who is in charge of getting the White House to issue an Executive Order to block the EPA from establishing its ETS Risk Assessment.

[Carlo's friend Thorne] Auchter believes that the Executive Order is on a fast track and that it will block EPA issuance of ETS risk assessment.

    I am dubious since OMB [White House Office of Management & Budget] would be required to reject EPA's risk assessment without cover of previously delineated standards. Nevertheless, it is crucial that we resolve these questions ASAP, and finalize our plan.

    Late Friday I learned that EPA may be embarking on a strategy to finalize the risk assessment before the Administration decides on actions resulting from 90 day moratorium/review — EPA may seek final risk assessment as earlv as April 1.
[A Presidential order had already blocked the EPA from issuing its Risk Assessment by creating a 90 day moritorium on its activities.]

    As a result, I would suggest:

1. It is premature to make copies of plan available (Auchter is even concerned about his name being on an ETS plan).
2. It is important that you participate as much as you can in our discussion on Executive Order/Adtninistration policy on Monday, 2/24 at 1:00pm.

I know it will be difficult by telephone, but it will give us the benefit of your thoughtt's — it is crucial that we finalize our plan by the end of'this week 2/28, if not sooner. (I am attachimg, another copy of the current proposed Executive Order for your convenience, and will fax materials which I expect from Auchter-Tozzi on Monday morning..

1992 Mar: Cantox, under the leadership of Dr Ian Munro prepares a very comprehensive report on likely contaminants of indoor air for the OSHA, US Department of Labor. They look at...

... 10 classes of biological agents, 230 chemicals, subdivided into 17 chemical classes, and 13 classes of physical agents.

    These agents are emitted by numerous sources which mainly comprise building materials and equipment (including furniture and HVAC systems), outdoor sources, and biological entities (e.g. humans and.plants). Sources related to normal (baseline) human activities (excluding smoking) also were identified and included mostly cleaning and renovation aetivities/materials.

    Allergenic and pathogenic agents identified in the indoor environment are comprised mainly of fungi, virues and bacteria.. In line with this observation, a variety of bacterial and/or viral strains have been found to be responsible for the adverse health effects freqaently reported by building occupants.

    Furthermore, the evidence available in the scientific literature associating HVAC systems, and more specificafly air conditioning systems, with SBS [Sick Building Syndrome] indicates that these biological agents, may represent a major cause.of complaints.

    Major sources of emissions were identified as being mostly related to building materials (eg. renovations/painting) and equipment (eg. photocopiers)

    Finally, in the case of SBS, there are actually no sound scientific criteria to understand, explain, or estimate the causes and effects related to: this event. Recent theories suggest that SBS may be considered the outcome of a multifactorial exposure comprising: physical, biological, and chemical as well as psychosocial factors. The interrelation between these components is still poorly understoodd and thus no predictive model is currently available.

It. should be noted that the present report has purposely not discussed the contribution of environmental tobacco smoke to the indoor environment since this is an issue that has been extensively studied in numerous other reports. Instead, the report has concentrated on. the identification of potential health effects associated with sources of indoor air contaminants (IACs) in office environments other than tobacco smoke.
[In other words, Cantox prepared a report without discussing the contribution to ETS — the single most important factor — because it is a disputable issue (according to the tobacco companies).

They have a very strange view of 'science'.]

1992 Mar 13: Carlo's "The Health Scientist Survey (Identifying consensus on assessing human health risk)." is finally sent to the Environmental International journal under the IRP name.

1992 Apr: Carlo is on the list of consultants for Philip Morris for a fee of $15,000 per month.

    This appears to be a retainer payment, rather than for any specific commissions — and it would have been for his media tours and witness statements (He was available for a set days a month).

    The same document shows that his friends Jim Tozzi and Thorne Auchter are retained at $70,000 a month.

1992 May:: The defence of the 2,4-D herbicide. George Carlo and Ian Munro, now seasoned firefighters in defence of dioxins, were trotted out once again to fight a growing firestorm over the less dangerous of this group of herbicides [Also a component in Agent Orange].

History: Beginning in 1988 the Environmental Protection Agency's... ... Office of Pesticide Programs (OPP) classified 2,4-D as a Group D oncogen (not classifiable as to human carcinogenicity) because existing data are inadequate to assess the carcinogenic potential of 2,4-D. [In other words... not enough research had been done.]     Accidental human poisoning with 2,4-D, which resulted in severe neurotoxicity, has been reported; adequate neurotoxicity studies are not available. While published data indicate that 2,4-D may be teratogenic, an acceptable rat teratology study is negative; a study in rabbits is needed. 1991 Sep 4: The Journal of the National Cancer Institute published the Hayes study... ... suggesting links between lawn-care uses of the herbicide 2,4-D and malignant lymphoma in dogs. This study raised predictable concerns among lawn applicators and home owners.     In response to these concerns, the Industry Task Force on 2,4-D Research Data commissioned an independent panel of scientists to review the study and its conclusions. After careful review, the panel found that due to limitations in design, the study's data did not support an association between 2,4-D and malignant canine lymphoma. 1991 Dec:, An independent scientific review panel was convened by     Drs. Ian Munro and George Carlo ... to evaluate critically the methodology and findings of the study by Hayes et al. entitled, "Case-control study of canine malignant lymphoma: Positive association with dog owner's use of 2,4- dichlorophenoxyacetic acid herbicides."     [Source May 1992 Cornell University publication "Industry Task Force Report on 2,4-D (Dacamine, Weed-B-Gon)" with funding from the Northeastern IPM Center. (??)]     This document reveals that the members of the Carlo-Munro 'independent scientific review panel' were: Philip Cole, Department of Epidemiology at the University of Alabama at Birmingham. who also worked for Dow Chemicals and the tobacco industry and was a Carlo associate. [Be aware that there are at least three Dr Philip Coles working in these research areas.] Anthony Miller, Department of Preventative Medicine and Biostatistics, University of Toronto. [probably the AS Miller who worked with Carlo at HES on tobacco projects.] Keith Solomon, University of Guelph and also the Canadian Centre for Toxicology; who also supported the tobacco and chemical industries and worked with Carlo on a number of occasions. He was an associate of Munro at the Centre for Toxicology [On 16th March 1997 a K Solomon was quoted in a Toronto Star article in support of the tobacco companies saying that "gun-shot wounds were more of a problem than second-hand smoke". Duh!] Robert A Squire, Division of Comparative Medicine, Johns Hopkins Uni. [Squires also worked for Carlo's HES, the tobacco industry, and for Elizabeth Whelan's ACSH chemical industry astroturf. He had 'supervised' Dow's Kociba dioxin re-evaluation project which supposedly gave dioxins the green light. ] 1992 May: An executive of DowElanco [A subsdiduary of Dow Chemicals] explains in a speech to a group of applicators that his company had asked George Carlo and Ian Munro to jointly convene the study group to publish "a definitive statment on the dangers of dioxin in this home-use herbicide" because of its potential threat to dogs. As expected, their chemical received the green light... However, we need your support as well. Specifically, the support we need is your continued safe use of the product. There are so many different formulations that it's difficult to generalize about the safety precautions needed.     So the message I'd leave with you today is that both my company and the Task Force are committeed to 2,4-D and to the total phenoxy business. We are committeed to managing our operations successfully in an issues intensive environment. Through our work with the Task Force, we bring to bear the resources needed to manage tomorrow's issues for ourselves and our customers. [The EPA was not satisified and requested further studies (by a differernt group) with rodents tested at higher dose levels. These studies were only completed in 1995 (and showed eye complications), and later studies revealed an increase in lymph sarcomas.]     The original study report     Industry's promotion speech to industrial users 1992 May: Journal of the American College of Toxicology carries a major article by Ian Munro, George Carlo and their teams from CanTox and Health & Environmental Sciences Group (Kelly Sund, Maureen Jablinske, Nora Lee): "A Comprehensive, Integrated Review and Evaluation of the Scientific Evidence Related to the Safety of the Herbicide, 2,4-D"     The DowElanco name was absent now. This study acknowledges only the support of "the Industry Task Force II on 2,4-D Research Data" and concluded that the herbicide was safe to use around the home: This evidence is supported by a large body of negative studies on genotoxicity, which taken together with the metabolic studies, clearly indicates that 2,4-D is highly unlikely to be a genotoxic carcinogen.     Furthermore, 2,4-D has no known hormonal activity and does not induce proliferative changes in any tissue or organ, indicating that it does not possess any of the characteristics of non-genotoxic animal carcinogens. Thus the available mechanistic studies provide no plausible basis for a hypothesis of carcinogenicity.     In this review, data relating to potential neurotoxicity, immunotoxicity and reproductive toxicity also were evaluated. There is no evidence that 2,4-D adversely affects the immune system and neurotoxic and reproductive effects only have been associated with high toxic doses that would not be encountered by 2,4-D users. ['Safe', of course, is a relative term, and this study carries an implied comparison with 2,4,5-T — which, is itself, an admission of the dangers of dioxins in the herbicides. What is most interesting here, is that this report had been peer reviewed for the Journal by a panel which consisted essentially of the same group of scientists that Carlo recruited in the following year to run his Special Advisory Group (SAG) for the cellular telephone industry. It throws doubt on the whole peer review process when both the investigation team and the peer-reviewers are so closely associated.] Sir Richard Doll of Oxford Uni — famous for his tobacco research, but also a secret consultant to Monsanto and lobbied on their behalf over Agent Orange. John Doull of Kansas State Uni — who worked also for both the tobacco and cellphone industries. He also did herbicide/dioxin research, both independently and with Carlo, Paustenback, Gough, and John D Graham. Saxon Graham of SUNY, Buffalo/Roswell Park — Carlo's old mentor and associate. Genuine researcher on tobacco problems since 1967, now retired. Raymond Greenberg of Emory University — coauthor of the Fontham ETS study with Elizabeth Fontham, Patricia A Buffler and Anna Wu-Williams; also breast cancer research. Greenberg also did studies for paper manufacturers. Gary Williams of the American Health Foundation — assistant to Ernst Wynder who was Carlo's friend and associate in the Nocebo project. Another similar report was produced in 1995 by a different team, and a draft of this article was sent to RJ Reynolds for some reason.

1992 Jul: This month's Environmental International journal carries the Carlo/Philip Morris "The Health Scientist Survey: Identifying Consensus on Assessing Human Health Risk" They had received the paper only on Mar 13 of that year. The abstract describes the methodology as:

The participants were asked questions concerning the relative usefulness and importance of specific types of data in defining health risk and were also asked to evaluate short vignettes describing various data profiles. Finally, participants were asked if they agreed or disagreed with a series of statements regarding public health policy, risk assessment, and risk managemen[:

The survey was conducted during 1990 and 1991 with the support of the Institute for Regulatory Policy.

1992 July 22: Executive Order on Regulatory Risk Assessment: Carlo's associate (later secret partner) Thorne Auchter is selected as a member of the President's Commission on Risk Assessment and Management at the White House which has been given some oversight over the EPA, FDA and OSHA regulatory standards and requirements (along with the OMB and OIRA). Another tobacco lobbyist and a lobbying lawyer for the nuclear waste industry are also selected.

    The aim of this corporate-friendly commission is to lobby President Bush to sign an Executive Order requiring the regulatory agencies to all do both a formal 'Risk Analysis' and a cost-benefit study before making any new rules governing poisoning or polluting substances. After the hammering of the Reagan Administration, George Bush was reluctant to be seen as a friend of the polluters.

[These Executive Orders mandate that federal agencies must wait to impose rules until universally accepted estimates of the cause and effecta of the hazard to be regulated are known... a near-impossible task.

    Regulators often know that a substance or product is dangerous long before they can measure the exact magnitude of the harm... or the full extent of the exposure... or even the exact mechanism by which a substance acts on the human body or environment and how that differs from their test animals.

    In Europe, this public safety-first process was formalized as the "precautionary principle" but in the USA it was inverted in favor of the corporations.]

1992 July 31: Tom Borelli at Philip Morris is using a power-point presentation with material based on Carlo's Bias Study. [He also mentions Michael Gough as an 'independent' authority!],

    Borelli tells his audience that the study's

Hypothesis: is that the use of the term ['ETS'] causes people to look at the science differently; [They believed] ETS was "bad" no matter what the science said.

• Available animal inhalation studies [were] ignored.
  [How do you do a passive smoking study on mice? You'd need tens of thousands of mice housed in a smoke-filled casino to get even a few extra deaths in their 18 month lifespans.]
• 31 Epidemiological Studies Considered,
• 24 Report No Statitically Increased Risk
• Yale University Study [The Varela Study]
  • Largest Completed study [on passive smoking] in the US,
  • [Which found] "No statistically Significant Increased Risk in Workplace, to Spouse at Home, Social Setting."

1992 Aug: /E Executive Order on Regulatory Risk Assessment: The July Monthly report of Government Affairs division of Philip Morris reveals that Thorne Auchter's Institute for Regulatory Policy (IRP) had also been behind another survey:

With regard to environmental tobacco issues, the Washington Relations Office continued its work with Corporate Affairs and PM USA to urge the Administration to issue an executive order that would establish procedures to enforce the application of sound scientific principles on all federal risk assessments.

    In support of those efforts, Market Strategies, on behalf of The Institute for Regulatory Policy, conducted a nationwide survey which demonstrated overwhelming public support for basing environmental regulations on sound science (88%) as well as public concern that if regulations are driven by media or political concerns rather than science, American taxpayers can be hurt by such regulations (83%).

Nevertheless, it appears that the EPA and the environmental groups have succeeded in blocking an executive order until after the election.

    Although the Administration's deferral of an executive order was a significant setback, we will continue our aggressive efforts to require the application of sound science to the ETS risk assessment. Our focus must now be on the Energy and Commerce committeee's requested investigations.

    It is essential that the scope of such investigations examine the bias which permeates the EPA's process on ETS, including the risk assessment.

See supplementary budget explanation

1992 Aug 3: THE tobacco lawyer-lobby firm, Shook Hardy & Bacon, have the full details of the Health Scientist Survey in their newsletter on passive smoking.

1992 Aug 7: The Office of Criminal Investigations at the EPA announced tht it had closed its investigation into the Cate Jenkins charge that Monsanto had produced fraudulent studies on the safety of dioxins. They claimed that the time delay had stretched beyond the statute of limitations, and that the studies hadn't been relied on by the EPA anyway.

    On July 20 1994 another internal EPA memo [William Sanjour to his supervisor David Bussard] detailed the charge that this inverstigation and the closure itself were fraudulent:

'One gets the impression, on reviewing the record, that as soon as the criminal investigation began, a whole bunch of wet blankets were thrown over it,' Sanjour told Bussard, noting that the investigation centred on criminal fraud.

    'In August 1992, EPA quietly closed the criminal investigation without ever determining or even attempting to determine if the Monsanto studies were valid or invalid, let alone fraudulent.'

1992 Aug 12: John D Graham had asked Rick Guardia at Kraft General Foods (the Philip Morris food subsidiary) to help him raise $25 million for his Harvard Center for Risk Analysis.(HCRA)

    The letter has also been ccd to the main tobacco staff, Tom Borelli, Mayada Logue (who had set up the initial contact with Graham), Bob McVicar who ran the KGF Foundation (which would launder payments as grants) and Jim Serafino, the head of "Scientific Affairs" [Issues management] for KGF.
[Carlo is intmately involved in later times with Graham and the HCRA]

1992 Aug 21: Executive Order on Regulatory Risk Assessment: A memo to Betsy Annese, (the head of Government and Public Relations at RJ Reynolds Tobacco) by lobbyist Matt Swetonic. Swetonic is both introducing and promoting Carlo, who is seeking funding for a project to force through an Executive Order.

    Until now, Carlo's tobacco work had been for the Tobacco Institute and Philip Morris, but now he is widening his catchment area to include RJ Reynolds.

    Swetonic was famously the front-man for Johns Manville (the asbestos company) and also an external PR for Dow Chemicals (Agent Orange) working through E Bruce Harrison [EBH — at this time a subsidiary of Hill & Knowlton]. He wrote to Annese.

As we have already discussed, yesterday I met in Washington with George Carlo, head of the Health & Environmental Sciences Group, a DC-based health sciences consulting firm.

    I have known Carlo since 1983, when he was part of my "flying circus" of Dow scientists touring the country talking about the Agent Orange issue. As recently as three or four years ago, he had a working relationship with EBH doing joint projects for various chemical industry clients. In short, we know Carlo very well and, as a result, he was quite open and. candid in the meeting.

    The [Carlo] study you sent me from Risk Analysis was funded through the Institute for Regulatory Policy which, as you know, has been the lead group trying to pressure the White House to release the Executive Order on risk assessment reform.

    According to Carlo, EPA was so concerned about the implications of the study that he was called to a meeting at the agency to explain "what the hell I was up to."

Regarding the Risk Analysis study, since, as I relayed to you previously, Carlo is unwilling to speak out directly in support of ETS, his "handlers" at the "primary funding organization" [Philip Morris] did little to publicize it when it was published in March. Carlo believes, and I tend to agree, that it is probably too late to make much of a splash with it now. But there is something else he believes can be done.

    Carlo was personally involved in a number of meetings at the White House on the Executive Order and he believes, as does Ward Hubbell, that the primary reason the Order was never issued was because it would have been perceived as a caving-in to industry at the expense of the public health.

[The Executive Order Swetonic speaks about is one that was designed to impose endless analytical requirements on government agencies before they could regulate on any potentially dangerous substance. Clearly, Carlo was now tied into some sort of partnership arrangement with Thorne Auchter at the IRP.

N Ward Hubble was a lobbyist-asscociate of Swetonic at EBH who fronted for RJ Reynolds via the National Environmental Development Association (NEDA) while Swetonic once ran the more widely tobacco-funded coalition known as the Total Indoor Environment Quality (TIEQ) organization. EBH, the NEDA and TIEQ all shared the same phone number. ]


    According to Carlo, Boyden Gray "screamed" (his word not mine) at them at one meeting that they had blown the whole thing by their heavy-handed corporate lobbying tactics and that he couldn't afford to hand the Democrats one more issue to beat President Bush over the head with in an election year.

[ C Boyden Gray was an heir of the RJ Reynolds tobacco fortune, and also White House counsel to Presidents Reagan and Bush During the Clinton Administration he ran the think-tank Citizens for a Sound Economy (now FreedomWorks) which supported the tobacco industry in exchange for generous funding, and since its inception, he also chaired the Executive Board of both the Harvard Center for Risk Analysis]

Carlo's idea for resurrecting the Executive Order is to create a groundswell of support among scientists for massive changes in the way regulatory agencies assess risk. He believes this would enable the White House to issue the Order, not because industry wants it, but because the scientific community believes it to be necessary.

There were actually two studies published as part of the IRP effort to demonstrate to the White House that the scientific community had little faith in the way regulatory agencies were assessing risk.

    The second, a copy of which is enclosed, asked a ton of questions to scientists regarding what types of evidence they would consider important in assessing risk. A number of the questions relate directly to the ETS situation, although none address it by name.

    The second study, in particular, received some favorable publicity in the environmental trade press around the beginning of this year.

1992 Sept: The International Journal of Toxicology published "Comprehensive, Integrated Review and Evaluation of the Scientific Evidence Relating to the Safety of the Herbicide 2,4-D" by George Carlo, Ian Munro and the joint HES and Cantox staff. The two companies are now working closely together.

1992 Sep 25: The Times reported that Dr Vernon Houk from the US Public Health Service, had been criticised by Congress, the National Academy of Science, and others.

    He was the "unnamed federal official" who had ordered the dioxin-related evacuation of Times Beach, Mo., and who later maintained the company-inspired line that the evacuation was unnecessary.

[Houk] admitted copying virtually verbatim from Dow Chemical documents in proposing relaxed standards for dioxin.

1992 Dec: Kelly Sund is George Carlo's stand-in on the agenda of speakers for the Risk Communications Specialty Group, at the Annual Conference of the Society of Risk Analysis held in San Diego.

1993-95: Carlo began to create a myriad of nonprofits and pseudo-science panels and societies in the early-to-mid 1990s. We have no exact foundation dates for most of these.

The Carlo Institute
This appeared to be his core non-profit for many years (founded before 1995), but it was later discarded in favour of the Science and Public Policy Institute.
The Carlo Institute for Public Health Policy
This is one of the more interesting and least known (it appears to be distinct from the Carlo Institute). It is listed as a client by Nancy Rose & Associates, Marketing & Public Relations consultants in Virginia under the heading of "Nonprofit and Public Affairs Organizations".
Science and Public Policy Institute (SIPPI)
Carlo also established the Science and Public Policy Institute (SPPI) in 1989 in Washington, D.C.. The mission of SPPI is to provide guidance to government agencies and the public on complex issues where science can be applied to assist in making informed public health, public policy and individual health protection decisions. Two addresses have been given at various times — one at the George Washington University, and the other at the address of his brownstone office also used by HES and WTR. The puff-piece says: SPPI has provided guidance on a myriad of issues including occupational health hazards, environmental and ecological damage, Agent Orange, abandoned hazardous waste sites, anti-viral treatments, food safety, smoking cessation, indoor air quality standards, silicone breast implants, electromagnetic field exposures, clinical research criteria, and nanotechnology. Note that it also mentions that the name Science and Public Policy Institute [like Health and Environmental Sciences] has been used by other organizations. Despite the 1989 foundation claim, it appears to have surfaced in 1994. SPPI is not affiliated with any of those entities and does not necessarily endorse their positions. [One is a climate denial org. in Virginia]

1993: The Chlorine Institute on behalf of the chemical industry began a $5 million public relations campaign with the release of a report entitled "Scientific Principles for Evaluating the Potential for Adverse Effects from Chlorinated Organic Chemicals in the Environment."

    This new report, was written by Carlo's business associate Ian Munro via his Canadian consulting firm CanTox, and it argues that concerns about organochlorines are overstated, and must be addressed within the current regulatory framework — one chemical at a time (there are hundreds of dioxin-producing chemical processes).

1993: The Nufarm dioxin spill: Nufarm [The Australian company with the 1990 dioxin problem in Melbourne — see Part 1] was a subsidiary of Fernz Pty Ltd. a New Zealand company [itself a subsidiary of Dow] which also owns Pharma Pacific and Pharma Pacific Management Pty Ltd. George Carlo was listed as Technical Director for all these companies and Carlo was sent on media and scientific conference tours by Pharma Pacific.

    An approach made in 1998 to Pharma Pacific Management for them to provide a "dioxin expert to present at a risk conference" revealed that Dr Carlo was still being offered around the world at this stage as a keynote conference speaker by the Pharma Group (They paid the airfare but not the lecture fee). He was then being touted by Pharma as an expert on 'Risk Assessment'. [They didn't say who's risk!

In 2010, Pharma Pacific and NuFarm Ltd were now both listed at 103-105 Pipe Road Laverton, Victoria in Australia.

    In this year Pharma Pacific also incorporated in Phoenix, AZ using vague terms like "Manufacturing Services"]

1993: The Nufarm dioxin spill: (Following the Nufarm dioxin spill in Melbourne water supply) the Australian Journal of Public Health publishes: Background soil concentrations of phenolic compounds, chlorinated herbicides, PCDDs and PCDFs in the Melbourne metropolitan area. by George Carlo, Kelly Sund, RL Crouch & BC Senefelder.

1993 Jan: /E Executive Order on Regulatory Risk Assessment: Tom Borelli's report on "New Project" for Philip Morris lists:

While the ETS budget was originally set-up to address only that issue, part of the funds went to establish groups (IRP) and resources (EPA Watch) that have a broader impact for PM.

    All of these consultants have been very effective in addressing the ETS issue for PM and could assist PM in other regulatory matters. Tozzi/Auchter, have excellent government contacts which makes them a valuable resource for the Washington office.
[Carlo also worked with them on the Executive Order]


Auchter — Last year, PM contributed [$] 880k (600k from Steve [Parrish], 280k from Craig [Fuller]) to establish the Institute for Regulatory Policy (IRP) as a vehicle for the executive order on risk assessment. Although the executive order did not make it, IRP is now a viable organization that can address various regulatory issues.

    IRP has established a coalition representing the interests of a broad array of industries and trade associations. Additionally, IRP has established a relationship with many state and local governments throughout the US. The coalition could address a number of regulatory issues of interest to PM in 1993.

    Since we have already made a sizable investment in establishing IRP, it would make sense to keep it going (at some level) for future issues.

1993 Apr 12: Jim Tozzi and Thorne Auchter (possibly with George Carlo) established a Center for Epidemiological Studies as a subsection of their highly profitable/non-profit Federal Focus. Inc which was their major health-related lobbyshop. Tozzi wrote to Philip Morris offering services:

As we previously discussed, EPA is placing an increasingly greater emphasis on epidemiological studies as a basis for its risk assessment and rulemakings. To address this need, we have established the Center for Epidemiological Studies as part of Federal Focus, a 501(c)(3) corporation.

    The Center is staffed by several fulitime epidemiologists who are supported by a number of internationally known epidemiologists on a contractual basis. The Center staff will play an increasingly greater role in the ETS risk assessment.

1993 Apr 22: With the Washington Legal Foundation (WLF) [A corporate funded anti-regulatory think-tank and legal advice center] George Carlo and James Baller jointly write:

• "Counsel Advisory" for: "Business Exposed To New Liability With Upcoming Health Assessments of Superfund Sites" which...

  ...provides a timely, provocative alert to the business community of the need to comment on the Agency for Toxic Substances and Disease Registry's pending health assessments of waste sites.

  
  
• Publish with Barry L Johnson, Assistant US Surgeon General and Assistant Administrator of the Agency for Toxic Substances and Disease Registry (ATSDR) "What You Need to Know About the ATSDR's Role In the Superfund Decision-Making Process."
  
  
  
• Run a luncheon seminar with Johnson. this year (date uncertain) through the Washington Legal Foundation on "How to Minimize Superfund Liability by Successfully Handling the ATSDR Health Assessment Process."

1993 May: (On the EPA classifications of dioxins.) Mark Shannon, (associate director in Washington of Ketchum Public Relations) began for Dow Chemicals...

... a blitz, which started in May and covered at least 30 cities, [and] was designed to undercut the press coverage that the EPA report was expected to receive when it was released in September.

    "Basically what we're trying to do is assure that industry's voice is heard by people who make policy decisions both here and around the country," Shannon said.

[This must have been an extension of the famous "flying circus" refered to by Matt Swetonic in a memo to RJ Reynolds]

The CMA is also providing about $200,000 to finance a scientific review panel to provide comments to EPA about the quality of its dioxin reassessment. The panel is co-chaired by John A. Moore, an EPA acting deputy administrator during the Reagan Administration who is now the president of the Institute for Evaluating Health Risks, a Washington think tank.

1993 June: The Nufarm dioxin spill: Two of Carlo's 1990 Melbourne water-quality/dioxin papers were published in the Australian Journal of Public Health. Both listed as research associates, Kelly Sund and James Baller.

• Assessment of dioxin-related health risks for the Melbourne metropolitan area [See listing in 1990]
• Sund appears to have no biomedical degree and worked for him at HES as his private secretary and general factorum.
• James Baller was his contract lawyer who later did work for him on a cellphone radiation panel when he ran the cellphone operation (WTR).
  
  These three "independent" experts found no cause for the Melbourne citizen's alarm, and Carlo told the Australian media that adverse health effects are unlikely to result from general population exposures to PCDDs and PCDFs. This was reported in the newspapers as clearing the Melbourne Water Supply of any suspicion of contamination.
  
      At this time Nufarm was a subsidiary of Fernz Pty Ltd. a New Zealand company which owns Pharma Pacific and Pharma Pacific Management Pty Ltd. George Carlo was, at this time, listed as Technical Director for all these companies and Carlo was sent on media and scientific conference tours by Pharma Pacific.
  [An approach made in 1998 to Pharma Pacific Management for them to provide a "dioxin expert to present at a risk conference" revealed that Dr Carlo was still being offered by them as a keynote conference speaker.
  
      He was then being touted by Pharma as an expert on 'Risk Assessment'. They didn't say who's risk! Pharma Pacific and NuFarm Ltd are now both listed at 103-105 Pipe Road Laverton, Victoria in Australia. In 2010 Pharma Pacific also incorporated in Phoenix, AZ using vague terms like "Manufacturing Services"]

The second paper carried the title:

"Background soil concentrations of phenolic compounds, chlorinated herbicides, PCDDs and PCDFs in the Melbourne metropolitan area" by Kelly G. Sund, George L. Carlo, Richard L. Crouch and Brian C. Senefelder
Abstract: During June and July 1990, surface soil samples were taken in the Melbourne metropolitan area and analysed for phenolic compounds, chlorinated herbicides, polychlorinated dibenzo-para-dioxins (PCDDs) and polychlorinated furans (PCDFs). A surface soil sample from a Werribee Farm Treatment Complex paddock, where cattle graze on land that is used for filtration of sewage, was also taken and analysed.

    No phenolic compounds or chlorinated herbicides were detected at the parts per billion detection limits in any of the samples. PCDDs and PCDFs were detected in both industrial and nonindustrial sectors of the Melbourne metropolitan area, as well as in effluent from Nufarm Limited, an agricultural chemicals manufacturer in Laverton North, in similar concentrations (toxic equivalents in the parts per trillion range). These concentrations were consistent with background levels identified in other major urban areas. There was no evidence of the Nufarm effluent fingerprint in any of the background soil samples analysed. The fingerprint profile of the sample taken from Werribee Farm, although showing traces of the Nufarm effluent fingerprint, was clearly distinct from that effluent fingerprint and consistent with the fingerprint identified in the background soils.

    The impact of the Nufarm effluent on the area, therefore, was considered insignificant.

---

1993 June: Carlo study in the Journal of Occupational Medicine "Reduced mortality among workers at a rubber plant."
[Larry Newman of NPL was PR for Bridgestone Tires]

We conducted a retrospective cohort study of mortality among current and former male employees of a modern tire manufacturing plant in Texas. Vital status was ascertained for more than 99% of the cohort of 2306 workers. Standardized mortality ratio analyses were completed based on 102 deaths. No significant excess for any disease-specific cause of death was identified, and significant deficits in all-cause mortality and deficits in cancer mortality were observed for both white and nonwhite men. The analyses were consistent in indicating that this work force has experienced no excessive disease-specific mortality

---

1993 June 8: "Evaluation of the Origin, Emissions and Controls of Organic and Metal Compounds from Cement Kilns Co-fired with Hazardous Wastes." A report by the "Process Technology Workgroup" of the industry (Cement Kiln Recycling Coalition) which has been sent to the EPA.

This report has been peer reviewed and approved by the' following members of the Scientific Advisory Board on Cement Kiln Recycling:

• George L. Carlo, Ph.D., M.S., J.D., SAB Chairman
  (Health & Environmental Sciences Group, Ltd., Washington, D.C.)
• Russell Keenan, Ph.D.,
  (ChemRisk, Inc., Portland, Maine)
• Harold Imbus, M.D., Sc.D.,
  (Health and Hygiene, Inc., Greensboro, North Carolina)

Technical assistance was provided by

• Drs. Michael P.Heap and Warren D. Owens, Reaction Engineering International, Salt Lake City, Utah,
• Maureen Jablinske, Health & Environmental Sciences Group, Ltd., Washington, D.C., and
• James Baller, Esq., Baller Harnmett, Washington, D.C., Special Counsel to the SAB.

[Russel J Keenan was a member of Dow's Kociba-study re-evaluation group along with Dennis J Paustenbach. The rest were Carlo staff or associates.]

---

1993 July 9: Science magazine reported that Carlo's associate, Ian Munro of Cantox had also been employed by the Chlorine Institute. Cantox had produced reports which argue that the dangers of chlorine compounds (ie dioxins) have been exaggerated.

---

1993 July 12 - 16: The Toxicology Forum is held in Aspen, Colorado. Speakers on Herbicide problems include:

• Evaluation of epidemiology studies and perspectives on weight of evidence — George L. Carlo,
• Exposure and toxicity of 2,4-D — Ian C. Munro, CanTox, Canada

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Washington Legal Foundation (WLF)

"Free enterprise advocates with public interest know-how". It's mission: "promoting free enterprise principles; limited government property rights; and reform of the civil and criminal justice system." [and] "shaping public policy through aggressive litigation and advocacy". "The Washington Legal Foundation (WLF) established its Legal Studies Division to develop substantive, credible materials designed to legitimise WLF's free enterprise agenda in courtrooms, and with policy-makers and the media. These audiences have long been subjected to, and influenced by, the ideas of special interest activists and government bureaucrats hostile to economic liberties and limited government. WLF's Legal Studies Division counters their pernicious influence." [Source: old WLF website]

---

1993 Aug 6: The Washington Legal Foundation published a couple of Carlo 'Legal Backgrounder' papers on Environmental Regulation. The joint authors are:

• Dr Barry L. Johnson. Assistant U.S. Surgeon General and Assistant Administrator of ATSDR [Agency for Toxic Substances and Disease Registry],
• James Baller, a senior principal of the Washington, DC law firm of Baller Hammett, P.C., [Carlo's friend and associate on Melbourne dioxin study]
• Dr George L. Carlo, an epidemiologist and Chairman of the Washington, D.C.-based Health and Environmental Sciences Group, Ltd.

These 'Legal Backgrounders' are available for sale to WLF members to help them mount a court defense. Topic: Environmental Regulation.

What You Need To Know About ATSDR'S Role In The Superfund Decision-Making Process (4 pages)... [which] discusses the expanding importance of the ATSDR in the Superfund decision making process.

    The paper also urges greater involvement by industry with ATSDR could create important new opportunities to influence EPA's decisions for those who can understand ATSDR's procedures and multi-disciplinary thought processes and participate effectively in the health-assessment process on a site-by-site basis.

On Apr 22 they also published another WLF paper on "Business Exposed To New Liability With UpComing Health Assessment of Superfund Sites" which

Provides a timely, provocative alert to the business community of the need to comment on the ATSDR's pending health assessment of waste sites.

And they also provided a commentary to the Congressional hearing on the same subject.
Another similar paper by the same authors is listed in the WLF books as: "How to Minimize Superfund Liability by Successfully Handling the ATSDR Health Assessment Process."

---

1993 Nov: TASSC: The Clinton Administration was planning to raise the Environmental Protection Agency (EPA) to cabinet-level status. This scared the hell out of the big corporations and the tobacco industry.

    They needed a way to counter the EPA's claim to scientific rigor, so Philip Morris, via their private PR firm, APCO, funded a supposed 'grassroots watchdog" organisation called The Advancement for Sound Science Coalition (TASSC) which had only one purpose; to attack the 'junk-science' used by regulators such as the EPA. It purported to be a grass-roots organization of concerned scientists.

    They hired ex New Mexico Governor Garrey Curruthers to be President and founder, and to conduct media tours promoting the tobacco industry's sound-science/junk-science message. The [then unknown] Steve Milloy acted as the behind-the-scenes media contract for TASSC and then became its director after Curruthers retired.

    With a lot of expensive promotion, Curruthers early media tours were highly successful (see two of many examples of news stories).

• Nov 28 1993 Denver Post published their 'scoop': "Here's how science might be used to keep science honest.

  The stated mission of the nonprofit corporation is to use its own scientific panel to "inform public officials, the media, and the general public about the consequences of inappropriate science," focusing on current examples of "unsound government research used to guide policy decisions." Compliance with environmental regulations cost the nation an incredible $115 billion in 1991 alone"

• Jan 2 1994 The Tampa Tribune published Slogans no substitute for sound science. [Syndicted from LA Daily News]

  Among TASSC's goals: to Inform the general public about the consequences of inappropriate science by focusing attention of current examples of unsound government research used to guide policy decisions; to establish an educational out-reach program; and to offer resources to ensure that sound scientific principles are applied.
  
      Unfortunately, such skeptics as Bruce Ames, Lois Gold, Dixy Lee Ray and the late Aaron Wildavsky don't get attention with the same ease as star-studded environmental groups and enterprises like Greenpeace and the Walden Project.

  The LA Daily News columnist Michelle Malkin who used her columns to attack Greenpeace and other activists, either through gullibility or self-interest, suggested that readers sign up for a free membership to TASSC.
  [Obviously, from her numerous later favourable columns on the subject, 'Mickey Malkin' became a card-carrying TASSC member herself! The following year she was also working on favourable tobacco stories with the Competitive Enterprise Institute (CEI) and publishing pro-tobacco and anti-EPA op-eds in the Washington Times.]

This document has an attached TASSC supporters' list (as of Jan 18 1995) which carries the names of

• seemingly gullible scientists who thought membership of such a non-profit might earn them speaking engagements at Florida conferences during winter.
• PR/lobbying executives from some of the major polluting companies.
• businessmen who didn't like environmentalism, and believed most of the climate and environmental science was concocted propaganda,
• numerous academics and scientists who worked indiscriminately for the polluting industries, provided they were well compenstated

This last group included some of the more obvious paid lackeys of the tobacco industry: Bruce Ames, Joseph Bast, George Carlo, Bernard Cohen, Geraldine Cox, James Enstrom, James Fyock, Harvey Gold, Ronald Gots, Paul Grant, Alan Hedge, Gary Huber, Peter Huber, Thomas Jukes, Patrick Michaels, Henry Miller, Alan Moghissi, Donald Stedman, Richard Stroup, Thomas Wyrick.

---

1993 Dec 21: Tom Hockaday and Katie Dold of APCO reported to Philip Morris about the "International Press Briefing on The Advancement of Sound Science Coalition (TASSC) which had had acceptances from 24 journalist.

    APCO and Philip Morris were in the early stages of planning ways to extend the role of TASSC, and so gain control of the 'sound science' debate in Europe.

    In the USA, TASSC had been successful beyond their wildest dreams. It had begun leading attacks on the 'junk-science" it said was behind the regulation of second-hand smoke, cellular telephone and EMF concerns, nuclear waste disposal, food processing, and global warming. TASSC had quickly been accepted by the media as the 'scientific authority' in labeling good and bad science, simply by claiming to be a grassroots society of 'concerned scientists.

    The exclusive funding of Philip Morris was now being replaced and expanded by grants from other companies and other industries; the 'junk-science' message had almost universal appeal among corporate poisoners and polluters.

    A questionairre sent to prospective members asking them to indicate their "junk-science" concerns, is quite revealing since it illustrates the primary concerns of the funding organizations:

Asbestos	Cellular Telephones	Chlorine in pulp/paper (dioxin)
CFCs (ozone)	Clean Air Act	Clean Water Act
Dioxins	EMFs	Endangered Species Act
Tobacco Smoke (ETS)	Fiberglass	GM products/food
Household Hazardous Waste	Other Biotech issues	Irradiation
Pesticides/food safety	Radon	Superfund
Wetlands	Waste Disposal Issues

[Carlo would have been involved in providing science-services on about half of these junk-science concerns. So it is not surprising to find him on the Scientific Advisory Board of TASSC.]

TASSC itself was a copy of Elizabeth Whelan's American Council for Science & Health (ACSH) which had successfully established itself (with chemical industry funding) as the arbiter of what was good and bad regulatory science for pesticide residues, food additives/preservatives, etc..

    ACSH had scored over the health-activists by running a campaign to ridicule their exaggerated claims about the danger of Alar on apples. This counter-measure appealed to conservatives in both of the main political parties, and quickly won Whelan the support of pesticides and food additive companies. [She had previously worked for the Chemical Manufacturer's Association (CMA) and its American Industrial Health Council (AIHC) which lobby for the companies in the area of health and the environment science. Her partner, Frederick Stare worked mainly for the food processing industry, and helped tobacco on the side (Carl Seltzer).]

    However, the tobacco industry couldn't use ACSH because Whelan had gained her 'public-health-advocate' notoriety by attacking smoking and the tobacco industry as the principle cause of cancers (partly exonerating occupational chemical exposures). This forced Philip Morris to create its own 'junk-science' astroturf.

[Note that George Carlo was enlisted as a member of the TASSC's Science Advisory Board, but he was not on the Science Advisory Board of ACSH. Most of the other science-for-sale entrepreneurs tended to sign up to support both operations.]

Katie Dold (ex APCO) became administrator of TASSC, and when Curruthers left Steve Milloy shifted out from the back-room and proclaimed himself the newly elected "Executive Director". At about the same time they created the "junkscience.com" web pages — and Murdoch's Fox News gave Milloy a regular TV spot.

    Milloy also ran the "Issues Watch" crisis monitoring service for the tobacco industry. The control of the whole operation later passed from Philip Morris to RJ Reynolds when documents were leaked exposing the role of PM in the organization and funding of TASSC.

First memo Follow-up memo

---

George Louis Carlo

• Part 1 — Dioxins, Love Canal, Three Mile Island, Agent Orange etc. • Part 2 — Tobacco industry, GEP and miscellaneous chemical industry projects. • Part 3 — Cellphone EMF problems: the CTIA and SAG/WTR • Part 4 — Later tobacco and other — immunology, vaccination, breast implants. • Part 5 — Later problems with cellphone EMF research and the demise of the WTR. • Part 6 — EMF scaremongering and various cellphone 'protection' businesses.

CONTRIBUTORS:LR13 JJHS hrh2