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Joint Technical Observation Statement
By
Africa Environmental Watch (AEW) and the Liberian Society of Environment, Health and Safety Professionals (LSEHSP)OnThe Inter-Agency Investigative Committee ReportOn Water Pollution by Firestone Natural Rubber Company
The issue of environmental protection provides us a common vision, one that allows us todevelop synergies from different backgrounds to ensure a clean and safe environment for all lifeforms. There are strong correlations between health and the environment to which the qualityof life can be assured and protected. It is against this background that our professional attentionhas been drawn to the findings of a recent investigative report by an Inter-Agency InvestigativeCommittee (referred to as “the committee” in this report) on water pollution by FirestoneNatural Rubber Company’s (referred to as “Firestone” in this report) activities.Most recently, an investigative committee was requested by the Liberian government to lookinto potential pollution by Firestone around Kparnyah Town, Margibi County, Liberia. Thefindings of the committee’s final report to President Ellen Johnson-Sirleaf, dated October 13,2009, stated that Ninpu creek is being polluted by the high level of orthophosphate emanatingfrom the discharge of Firestone’s waste water treatment facility. .The Africa Environmental Watch (AEW), in collaboration with the Liberian Society of Environment, Health, and Safety Professionals (LSEHSP) want to thank the government of Liberia and the investigative committee for their work on the Firestone story. However, as wecarefully reviewed the final report submitted by the committee, we believe three majorcomponents of the report were less than adequate.1.
 
The terms of reference and parameters sampled2.
 
The water sampling protocols, and3.
 
The recommendations from the committee based on the results of the samples.
 
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Firstly, the terms of reference and the parameters given to Earthtime Inc., the company hired toconduct the water quality study, was limited in scope for the nature of the investigation.Secondly, our review determined that Earthtime Inc.’s Final Report entitled
“Water Quality Survey and Analysis for Ninpu and Vah Creeks-Firestone (Harbel, Liberia)”, dated September 2009
, was not thorough and comprehensive enough to draw a scientific conclusion. The reportindicates that all tests performed were conducted in accordance with the
“Standard Methods for the Examination of water and wastewater”, 21st Edition, 2005
(referred to as “StandardMethods” in this report). However, based on the sampling strategy, methodology, and testresults presented in the report, the report draws more questions than answers. Thirdly, thecommittee’s recommendations were less than adequate to address continued pollutionprevention at Kparnyah Town.Our professional observations of the report were based on a collective knowledge of over fiftyyears working in the fields of environmental assessment, remediation, restoration, and healthand safety exposure analysis. Below are the following observations:1) How did the investigative committee arrive at the 14 parameters given to EarthtimeInc.? An adage in sampling states that “one only finds what one tests for.” Could thecommittee have recommended running a battery of tests to determine
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possible potentialcontaminants in the water? Did the committee request Firestone to submit a chemical inventorylist and accompanying Material Safety Data Sheets (MSDS) to determine if other toxicsubstances were or are currently used at their facilities? The report did not give any detailregarding the rationale for these parameters or how the committee reached the terms of reference.2) What prompted the analysis of orthophosphate? Orthophosphate (the lonecontaminant of concern per the study), in industrial use, is a corrosion inhibitor typically addedto finished drinking water in low concentrations at treatment plants (<3 mg/L) to treat the waterfor lead or copper found in the distribution pipes. Orthophosphate is also used in someinstances when there is difficulty in balancing pH in highly acidic solutions. Additionally,orthophosphate forms are produced by natural processes, but man-made sources include:
 
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partially treated and untreated sewage or waste water, runoff from agricultural sites, andapplication of fertilizers.Could the high level of Orthophosphate be an indication of highly acidic discharge? This wouldcontradict the (pH) test results in the report suggesting the discharge was not acidic. Could theelevated Orthophosphate levels be attributed partially or untreated waste water, runoff fromother sources or could it be attributed to the sample handling and testing methods, indicatingfalse positive results? Accordingly, Standard Methods SM1060B (Table 1060: I) recommendsthat Orthophosphate samples must be filtered immediately upon collection and analyzed within48 hours thereafter. The sampling methodology presented in the report did not indicate thatthese procedures were followed.3) According to Standard Methods SM1060B, samples must be preserved at a temperatureof 4° Celsius (39.2
0
 
F) and not 40° Celsius (104
0
F) as documented in the report. This alone, withno qualifier on the samples may allow the analysis to be lower than the MCL (MinimumContamination Levels).4) In the report, there was no mention of quality assurance or quality control (QA/QC)samples sent to the laboratory for testing, which is a standard industry practice. QA/QC samplesare duplicate samples labeled differently and sent to the laboratory. Both the QA/QC andproperly labeled samples should have the same results; otherwise, the lab results arequestionable. This validates the quality, consistency, and accuracy of the lab work.5) The report was not clear regarding chain of custody process. Chain of custody is anotherstandard industry practice that guarantees proper handling and transfer of the samples from thecollection point, ensuring the integrity of the collected samples, to the designated qualifiedlaboratory. Furthermore, documentation from the receiving laboratory was not disclosed in thereport, which would verify the quality and integrity of the samples were intact upon receipt.We believe that a thorough and more comprehensive Water Quality Study (WQS) at Firestonewould have considered the following:1. A complete review of Firestone's natural rubber process; review of the list of 
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