Critique of Toxicology Reports carried out by
Professors Daly & Braitberg

By Isla MacGregor

Editor’s note: The full text of the Critique, with an explanation of the deficiencies in each patient's assessments by Professors Daly and Braitberg is at www.lead.org.au/mr/THMTT_Critique_Of_Toxicology_Reports%20.pdf

The following is a revised version of the original summary.

Professors Frank Daly and George Braitberg based their assessments on ten patients from information provided by the Department of Health and Human Services (DHHS) from previous investigations, medical reports, data, test results and files. The conclusions in their reports, based on the information provided, show numerous errors of fact and incorrect assumptions:

• Conclusions drawn were made from incomplete, flawed and deficient DHHS and EPA investigations
• Assumptions on possible diagnosis were made without patient consultations or examinations
• Assumptions on possible diagnosis were made without access to up- to-date medication lists, accurate medical reports, documentation, correct data and specialist/ diagnostic test results
• Incorrect attribution and analysis of data
• Conflicting findings between Professor Daly's and Professor Braitberg’s Reports.

Other than problems described in our patient-specific analysis of the reports there are general examples in the reports that point to inconsistencies and flawed analysis:

• Professors Daly and Braitberg did not adequately assess the commonality and the patterns of symptoms in the patients. For example, most patients have experienced sudden-onset and severe dental problems in the past two years, yet this is not discussed in any depth except for patient C, where smoking is suggested as a cause for poor dentition. All patients have experienced abnormal hair loss, concurrent with dental problems and musculoskeletal problems, regardless of age. Had Professors Daly and Braitberg conducted patient examinations, the pattern of the symptoms, which is what caused Dr Ernst to notify the DHHS, would have been clearly apparent, and could have assisted with their assessments.Professor Daly states in relation to patients A, B, C, F, G and H that “The presence of multiple symptoms in multiple organ systems without any associated objective medical signs or pathological abnormalities suggests a functional somatic disorder, which occurs in up to 4% of the population”. Professor Braitberg states that “the first step is to overcome the currently held belief that the residents have been poisoned by heavy metals. However, belief, no matter how strong; where there is no evidence, does not serve the best interests of these patients.” This diagnosis is given in the absence of any comprehensive objective clinical medical or psychological assessment or reports based on patient consultations, examinations and test results.
• Although no thallium testing was done by the EPA or DHHS, Prof Daly's comments on Page 25, on the effects of thallium poisoning, refer only to effects of severe poisoning, not to long term low level exposure, which can in fact result in gradual loss of hair.
• Prof Braitberg on Page 43 incorrectly states that “None of the patients have had skin biopsies”. Three patients have had excisions of lumps and these were tested for cancer. Although testing was requested for heavy metals on these biopsies, this testing was not done.

In Prof Braitberg's Executive Summary he states “while there is some evidence of low level soil concentration elevation of some metals,” and in Professor Daly's Summary he also states “Rosebery has demonstrated elevated levels of several metals”. This is incorrect considering that properties had some very high levels, including a soil lead level of 4,590mg/kg - up to 15 times the Health Investigation Level (HILs); an arsenic level of 646mg/kg - up to 6 times the HIL's. These levels are not just 'elevated' - they are very high.

The information provided to the toxicologists from the DHHS on data from the EPA investigations did not include critical information needed for a thorough toxicological assessment:

• No biological or environmental tests were conducted by the DHHS or the EPA for thallium or any radioactive elements
• No roof cavity dust testing was conducted by the EPA, and dust monitoring/sampling was either not done or incomplete
• Arsine gas testing was inadequate and conclusions drawn erroneous.
• The instruments used for Hydrogen Sulphide testing had insufficient resolution
• The Toxic Heavy Metals Taskforce Tasmania Critique of the EPA investigation including: sampling methodologies, data interpretation and presentation and conclusions drawn were not assessed

Because of the failures in the EPA investigation and failure of the DHHS to provide accurate information, Professors Daly and Braitberg were unable to address the major issue of potential exposure pathways for dust and gas and instead focused on those for water and soil.

The Department of Health and Professors Daly and Braitberg have failed to adequately take into account the importance of complex mixtures of toxic substances at even low levels and their effects on human health. In the context of discussion on low level exposure synergism, Profs Daly and Braitberg cite the US Agency for Toxic Substances and Disease Registry (ATSDR) Interaction profiles for: arsenic, cadmium, chromium and lead; and lead manganese, zinc and copper, from 2004. There is no referencing to more recent relevant research from the US National Institute of Environmental Health Sciences (NIES) and the National Toxicology Program. In a recent article in Environmental Health Perspectives, Linda Birnbaum, Director of NIES and NTP states:

“There are several recent examples of how research supported by the NIEHS is leading to a paradigm shift in understanding how environmental toxicants – even at very low-level exposures – can have significant consequences including dysfunction and disease”.

The conclusions from a recent survey in the US on lead exposure and kidney disease have shown “ increasing epidemiologic evidence indicating an adverse effect of low-level environmental lead exposure.” Blood Lead Level and Kidney Function in US Adolescents from the Third National Health and Nutrition Examination Survey by Jeffrey J. Fadrowski, MD, MHS; Ana Navas-Acien, MD, PhD; Maria Tellez-Plaza, MD, MPH; Eliseo Guallar, MD, DrPH; Virginia M. Weaver, MD, MPH; Susan L. Furth, MD, PhD Arch Intern Med. 2010;170(1):75-82. 

A new study published in the ejournal evisa on 23-2-10 by Chris Newcombe, Andrea Raab, Paul N. Williams, Claire Deacon, Parvez I. Haris, Andrew A. Meharg, Jörg Feldmann: Accumulation or production of arsenobetaine in humans? J. Environ. Monit., 2010, outlines important research on inorganic sources of arsenobetaine and metabolism of arsenic by the human body. 

Can humans metabolize arsenic compounds to arsenobetaine?, by W. Goessler, C. Schlagenhaufen, D. Kuehnelt, H. Greschonig, K. J. Irgolic,Appl. Organomet. Chem., 1997, 11, 327–335.  adds to this body of research and in relation to potential exposure pathways for Rosebery residents there is a need for further investigations.

The provision of comprehensive specialist assessments and data along with consultations and examinations of patients is essential for toxicological assessment relating to long term low-level exposure to complex mixtures of heavy metals. In summary, due to the serious deficiencies in the documentation provided to Professor Daly and Professor Braitberg by the Department of Health and lack of patient examinations, we are unable to accept the findings in Professor Daly and Professor Braitberg's Reports.