In a message dated 4/7/2005
4:24:24 P.M. Pacific Standard Time, [email protected] writes:
The health department strongly believes in open and transparent
sharing with the public as a means to promote and protect public health.
I have read Ms. Weintraub's reponse to you carefully. She simply
you that we do act to prevent health threats where necessary. An
is when we post a warning on a beach. While you do have the
right to say
anything you wish, it was neither helpful nor fair for you to
her message in the way you did.
Rajiv Bhatia, MD, MPH.
Director, Occupational & Environmental Health,
San Francisco Department of Public Health
To w;hich we responded:
It may or may not be helpful, but it certainly is accurate to
"characterize (June's) message in the way that (I) did".
June said: "As you know, Lake Merced
is designated an emergency water supply, and as such, swimming and
other full body contact uses are prohibited. Because there are no
bacteria standards for recreational boating and fishing uses of this
body of water, there is not a compliance issue in this case
It is a fundamental rule of syllogistic logic that If A then B, If B
then C, A is true, then C is true. June said, If emergency supply
of drinking water then no swimming, if no swimming then no standards,
if no standards then no compliance issue.
June is incorrect that there are no standards for infrequent contact
recreational use in fresh water bodies. I have sent June the EPA
standards for that class of uses. I believe that it is adopted
PUC policy to meet or exceed all EPA standards, as well as the state
issued regulations. I'm disappointed that I am the one who needs
to find this stuff on the web. I'm also disappointed that I have
had to turn to the San Diego Department of Environmental Health to find
resources describing fresh water specifications and minimum standards
for water quality monitors.
June also said: "If there is
evidence that the coliform levels do present a health threat to these
boating and fishing users, we can consider taking action to prohibit
Coliform levels periodically present a health issue in recreational
waters all over the state. Where that is the case monitoring
programs are established that provide for adequate protection of the
recreational public. Notices are posted, and beaches are
cleared. We don't, however, prohibit swimming at places like
Mission Bay in San Diego just because a quarantine is periodically
required. June's suggestion is completely insensitive both to
standard monitoring approaches and to the great importance of
protecting Lake Merced as a recreational resource. For many inner
city youth this is the closest they are ever going to get to outdoor
boating and fishing opportunities. To willingly discard those
opportunities rather than develop an appropriate monitor is in my view
What June did not say is, Yes, let's get together and work out a
practical and effective monitoring program for Lake Merced.
Instead, she did say, "We do not
believe that instituting a monitoring program in the absence of a
regulatory standard for that body of water will improve protection of
the public health."
It seems to me that before I raised the alarm we had no health threats
at Lake Merced. Certainly the PUC didn't think so, as they waited
more than three months to release a report that E-coli levels in South
Lake had reached 985 MPN. Their response was to suggest a
monitoring program that would be conducted every two months, with
reports delayed a further 30 days, no matter what condition had been
observed at the lake, and with no provision for public notice other
than sending me a copy of the report. They made this proposal
after measuring the high levels of E-coli and before releasing the
report, a sequence that does little to engender public
confidence. However, it seems clear to me that if I'd just shut
up and go away, quit rattling the City's chain, we wouldn't have any
health problems, at least none that we recognized.
Well, there is a regulatory standard, and there is the need for a
monitoring program, and fortunately the PUC agrees with both of those
conclusions without the support of the Public Health Department.
I think that's also a shame.
Friends of Lake Merced