October 12, 2005, Ms Zoe Kelman, a chemical engineer with the Site Remediation
Program and a participant on the Chromium Workgroup submitted a memo to
Commissioner Bradley Campbell outlining her independent review, "A
Counter - Argument to the New Jersey Chromium Workgroup's Recommendations
”. Upon Commissioner Campbell’s request, the Chromium Workgroup
chair coordinated responses to the memo. Not every point was commented
upon, as there were time constraints.
of the criticisms of the chromium workgroup raised in this memo seem to
represent criticism of the risk based paradigm in general. The chromium
clean up criteria are based on the current risk based paradigm and not
on a precautionary paradigm, although the two are not necessarily mutually
exclusive. It is the tool that both the federal and state government uses
for determining “acceptable” risk. Other paradigms have been
addressed in recent years and include the precautionary approach. The
European Commission stresses the need for "reliable scientific data
and logical reasoning" when adopting the precautionary approach.
Before "triggering" the use of the principle, it recommends
a thorough evaluation of scientific evidence. The analysis must also include
an assessment of the uncertainties in the scientific data. It stresses
the wide range of actions that may be taken under the principle, including
no action at all. The precautionary principle should not be used in an
arbitrary way but is itself based on a thorough review and interpretation
of scientific evidence.
of the various approaches to manage risk is valid. However, it is beyond
the purview of this work group to change the paradigm.
to Commissioner Campbell criticizing the Chromium Workgroup Report
with responses from the Workgroup Chair
to Chromium Workgroup - Home