3. Please provide al correspondence between ESR and Dr Jeff Fowles and ESR and Tox-Logic
regarding both the 2020 or 2022 reports.
1 September 2020
From: Tox-Logic <[email address]>
Sent: Tuesday, 1 September 2020 11:34 am
To:
Peter Cressey
Subject:
Re: Methamphetamine again
Very good points about the blinding. I shall re-read all of her work and this wil be a
crucial aspect of the context of the reassessment, so i’m happy to discuss on phone
about it.
Regards
Jeff
Sent from my iPhone
On Aug 31, 2020, at 12:49 PM, Peter Cressey wrote:
Hi Jeff
I’m not overly impressed by any of the graphs, but the reporting of plausible symptoms
in the ‘opportunistic case studies’, that resolved when people moved is interesting. I
think there are issues around blinding (did people report symptoms before they knew
the property was meth contaminated) and the objectivity of the symptoms. However,
this study may be as good as it gets, considering the potential ethical issues with a ful y
blinded study. I think the study could be categorised as ‘suggestive evidence of adverse
health effects from tertiary exposure to meth contamination levels close to the current
NZ remediation standard’ or something like that.
Cheers
Peter
From: Tox-Logic
Sent: Tuesday, 1 September 2020 3:43 a.m.
To: Peter Cressey
Subject: Re: Methamphetamine again
Hi Peter,
I had the same feeling about the recent Wright paper. I just can’t get over that regression
line. It seems like a single extreme outlier data point determines everything that’s
concluded from it. But stil the general relationship is plausible.
Jeff
Sent from my iPhone
On Aug 27, 2020, at 8:16 PM, Tox-Logic
<[email address]> wrote:
kind regards
Jeff
Sent from my iPhone
Withheld under
Section 9(2)(a) of the
Official Information Act 1982
On Aug 27, 2020, at 7:48 PM, Peter Cressey <
> wrote:
Hi Jeff
Sorry, I got this email when I was sick at home. I have attached the papers I have from
Jackie Wright’s work. I just looked up the 2020 paper – I doesn’t look totally compelling,
but it also contains information that adds to the overal picture.
Kind regards
Peter
From: Tox-Logic
<[email address]>
Sent: Friday, 21 August 2020 3:15 p.m.
To: Peter Cressey
>
Subject: Re: Methamphetamine again
Hi Peter,
I see there is a 2020 paper in Toxics by Jackie Wright on MA exposure and health effects
from 3rd hand MA exposure. I’m not sure how their Figure 1 was deemed scientifical y
sound given that the entire slope is based on a single outlier value, but such is the
nature of publications these days.
However it is useful context and wil need to be included in the new analysis.
Jeff
Sent from my iPhone
On Aug 19, 2020, at 9:02 PM, Peter Cressey
<[email address]> wrote:
Very reasonable compared to what ESR charges for my time!
From: Tox-Logic
<[email address]>
Sent: Thursday, 20 August 2020 3:28 p.m.
Withheld under
To: Peter Cressey <
>
Section 9(2)(a) of the
Subject: Re: Methamphetamine again
Official Information Act 1982
The hours look fine, but my
these days.
If that blows a hole in the budget feel free to scale my hours back.
Withheld under Section 9(2)(b)(i ) of the
Official Information Act 1982
Regards
Jeff
Sent from my iPhone
On Aug 19, 2020, at 6:20 PM, Peter Cressey
wrote:
Thanks Jeff. Do the hours and chargeout rate look okay?
From talking to the latest HUD incumbent it just didn’t seem as though our original
proposal was going to meet her needs. The current limit is a level that properties are to
be remediated to, but it has been interpreted as a limit above which remediation is
required. I think they are looking for some science to define a situation where
remediation is vital, as opposed to desirable. Forensic use a level of 30 mcg/100 cm2 to
indicate likely manufacturing and Gluckman suggested 15 mcg/cm2 – I am wondering
whether a relatively minor relaxation of the conservativism in either the model or the
reference dose might get use nearer to one of those values. In any cases, it would be a
good opportunity to update the science and pick apart the inputs.
Peter
From: Tox-Logic
<[email address]>
Sent: Thursday, 20 August 2020 1:03 p.m.
Withheld under
To: Peter Cressey
>
Section 9(2)(a) of the
Subject: Re: Methamphetamine again
Official Information Act 1982
Hi Peter,
Thanks for this and yes I’m interested as before. Interesting timing from HUD. I suppose
the variables to be examined would include those that we started considering last year,
but it seems the proposal does not call for a stochastic assessment per se.
But please consider me available and interested in any event.
Regards from another climate disaster...!
Jeff
Withheld under
Sent from my iPhone
Section 9(2)(a) of the
Official Information Act 1982
On Aug 19, 2020, at 4:11 PM, Peter Cressey <
> wrote:
Hi Jeff
I hope all is wel in sunny California.
Ministry of housing and urban development (HUD) have reactivated their interest in the
methamphetamine issue. Their preference seems to be for a guidance document rather
than a hard regulatory approach, which I think is sensible. We had some discussions
yesterday with HUD and our forensic people who are expert on methamphetamine
residues. HUD are looking for scientific advice and we identified two pieces of work that
should provide support.
The attached is my take on what they want on the human health side. The pricing at the
end of the document is just what we had in our original proposal.
So:
Are you interested in being involved?
Do the hours look appropriate for the work described? (given that the description is
fairly thin!)
Is the chargeout rate stil appropriate?
I’m not sure that there is going to be a lot of new data, but I think some of the
conservatism in the inputs to the risk assessment can, at least, be acknowledged.
It would be great if you could let me know about this by the beginning of next week.
Best wishes
Peter
Peter Cressey
Science Leader
Institute of Environmental Science and Research Limited (ESR)
Christchurch Science Centre: 27 Creyke Road, Ilam, Christchurch 8041
PO Box 29181, Christchurch 8540, New Zealand
Withheld under
DDI:
/ T:
/ EXTN:
Section 9(2)(a) of the
E:
Official Information Act 1982
www.esr.cri.nz
The information contained in this message and/or attachments from ESR is intended
solely for the addressee and may contain confidential and/or privileged material. If you
are not the intended recipient, any review, disclosure, copying, distribution or any action
taken or omitted to be taken in reliance on it is prohibited by ESR. If you have received
this message in error, please notify the sender immediately.
23 October 2020
From: Tox-Logic <[email address]>
Sent: Friday, 23 October 2020 10:56 am
To:
Peter Cressey
Subject:
Re: GMC meth testing ESR 000592
Hi Peter - that’s good news. And thank you for the attachment on the exposure variables
we looked at last year. Did you see Wrights 2020 paper on inhalation route? Seems to
suggest 20% addition to exposure from volatilized MA, but i haven’t gone through it in
detail yet.
j
Sent from my iPhone
On Oct 22, 2020, at 2:49 PM, Peter Cressey wrote:
Hi Jeff
I think we are all go here – should sign the contract early next week.
I have inserted the exposure model analysis we did previously into a prototype report
and adapted to the current situation (attached). I don’t think we have much wriggle
room on that side.
For the RfD review, do you have the Chapman paper? I only have the summary in the
Salocks report. It may be worth considering the data as either continuous (average
weight gain) or dichotomous (proportion of participants who lost weight), to see what
the slope of the dose-response curve looks like. Just a thought.
I am working through the Wright paper at the moment. The reported symptoms are
plausible, although a lot of them would also be plausible for people stressed by living in
a known meth contaminated dwel ing. I don’t see anything in the paper to suggest a
biological gradient (more severe or more frequent symptoms in more contaminated
properties), so it is likely that the evidence could best be described as ‘suggestive’.
Kind regards
Peter
From: Tox-Logic
Sent: Wednesday, 7 October 2020 3:29 p.m.
To: Peter Cressey
Subject: Re: GMC meth testing ESR 000592
Hi Peter,
That sounds great. Seems like the first part is basical y continuation of the work we
started last year so we could team up to finish that off. I’m happy to critical y dig into
the RfD details. If you don’t mind critical y reviewing Jackie Wright.
Jeff
Sent from my iPhone
Withheld under
Section 9(2)(a) of the
Official Information Act 1982
On Oct 6, 2020, at 4:00 PM, Peter Cressey <
>
wrote:
Hi Jeff
I have just been talking to Vanessa James at HUD. We wil adjust the
milestone dates to give a report date of about 23 November. We wil
make ‘our best efforts’ to deliver sooner, but won’t commit.
I see three aspects to what we are going to do:
*
Dissecting the exposure model to see how much room for
movement there might be there. I think we have done a lot of
this, but wil need to repackage.
*
Dissecting the RfD. This is likely to be a critical review of the
factors used to derive the Salocks RfD
*
Review of the recent literature. This is likely to focus strongly on
Jackie Wrights work and a critical appraisal of what can be
concluded from it
I’m happy to divide this up any way that you are comfortable with.
Would it suit you to have a Teams meeting sometime in the next couple
of days to discuss? Let me know a time and I’ll arrange the meeting.
Cheers
Peter
From: Tox-Logic <[email address]>
Sent: Tuesday, 6 October 2020 8:33 a.m.
To: Peter Cressey
>
Subject: Re: GMC meth testing ESR 000592
Hi Peter,
I would not be able to commit to delivering before mid November. But
15-20 Nov could be done.
Dividing up the work - happy to discuss by phone if you’re available
later?
Regards
Jeff
Sent from my iPhone
On Oct 5, 2020, at 11:27 AM, Peter Cressey
> wrote:
Withheld under
Section 9(2)(a) of the
Hi Jeff
Official Information Act 1982
Can you indicate what timeframe would work for you.
Also, have a think about how you would like to divide
up the work.
Thanks
Peter
From: Tox-Logic <[email address]>
Sent: Monday, 5 October 2020 4:16 p.m.
Withheld under
To: Peter Cressey <
>
Section 9(2)(a) of the
Subject: Re: GMC meth testing ESR 000592
Official Information Act 1982
Hi Peter,
Ditto from me on timeframe....
Regards
Jeff
Sent from my iPhone
26 November 2020
From: Jeff Fowles
Sent: Thursday, 26 November 2020 8:55 pm
To:
Peter Cressey
Subject:
Re: MA RfD re-evaluation draft
Hi Peter,
I’m happy to hear it fits in and it looks overal like a thorough treatment of the various
topics - my hats off to you on the other sections.
I’m comfortable with the conclusions as written although maybe it would be good to
chat about how the 1.5 vs 15 issue is conveyed among ourselves so that we are both on
the same page about the practical implications for remediation, etc.
Best and thanks for the col aboration!
Jeff
Sent from my iPhone
On Nov 25, 2020, at 7:42 PM, Peter Cressey wrote:
Hi Jeff
I think this is a very fine piece of work. Wel done!
I have integrated it into the overall document and written a conclusion, based
around HUDs risk management questions. The conclusion makes some fairly firm
conclusions, which you wil need to be comfortable with. Can you have a look
over the conclusion/exec summary and edit as you see fit.
Thanks for a great job.
Peter
From: Jeff Fowles
Sent: Thursday, 26 November 2020 1:04 p.m.
To: Peter Cressey
Subject: MA RfD re-evaluation draft
Hi Peter,
Attached is my draft input on the RfD reconsiderations. Its possible more could be
put in surrounding ECHA's AF guidance as a stronger basis, and I may be adding
to that as we go forward.
Please let me know if you have any questions or comments that I can address.
Best regards
Jeff
The information contained in this message and/or attachments from ESR is
intended solely for the addressee and may contain confidential and/or
privileged material. If you are not the intended recipient, any review,
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This email has been filtered by SMX. For more information visit smxemail.com
22 December 2020
From: Peter Cressey
Sent: Tuesday, 22 December 2020 11:22 am
To:
'Jeff Fowles'
Subject:
RE: Leo's review of the meth report
Hi Jeff
Not a problem.
Best wishes to you and June for a wonderful Xmas and New Year.
Peter
From: Jeff Fowles <[email address]>
Sent: Tuesday, 22 December 2020 10:35 a.m.
Withheld under
To: Peter Cressey <
>
Section 9(2)(a) of the
Subject: Re: Leo's review of the meth report
Official Information Act 1982
Hi Peter,
I’m sorry to be unresponsive but just learned that my incoming email was not working
for this account and have fixed it. In the future for me the
.com should
be the one used for me, I wil be phasing out this hotmail account.
Again apologies for seeming to ignore your emails!
Regards
Jeff
Withheld under
From: Peter Cressey
>
Section 9(2)(a) of the
Sent: Sunday, December 13, 2020 12:08 PM
Official Information Act 1982
To: Jeff Fowles <[email address]>; Jeff Fowles <
>
Subject: Leo's review of the meth report
Hi Jeff
I said to Vanessa that we would respond to the reviewers’ comments this morning. I
have addressed all the comments related to the review of the literature (al of Barry
Borman’s comments and half of Leo Schep’s). I have drafted the fol owing response to
Leo’s comments about the Chapman study, but was hoping for your input:’
“Dr Schep has commented on the use of the Chapman study on previous occasions
and is on record as saying “It has problems, but I can see why they used that paper and I
wouldn't criticise them for that, because it is difficult to try to establish a dose that is of
concern.” (RNZ interview, 2018).
Dr Schep comments in his current review that “Weight loss linked to this drug is not a
harmful effect”. However, in toxicological studies a weight loss or even a decrease in
weight gain is viewed as an adverse effect and in many cases may be the only adverse
effect characterised.
Dr Schep further comments on the uncontrol ed dietary intakes of the study
participants. While this is not an ideal aspect of the study, the study did involve real
human beings and, as such, control ing all background factors is often not possible. The
fact that reduced weight gain was monotonically associated with methamphetamine
dose under the double-blinded protocol argues against an uncontrol ed aspect of the
study as the basis for the weight loss reported.”
Does this look okay? Is there more you would like to add?
Thanks
Peter
Peter Cressey
Science Leader
Institute of Environmental Science and Research Limited (ESR)
Christchurch Science Centre: 27 Creyke Road, Ilam, Christchurch 8041
PO Box 29181, Christchurch 8540, New Zealand
DDI:
/ T:
/ EXTN:
E:
Withheld under
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Official Information Act 1982
The information contained in this message and/or attachments from ESR is intended
solely for the addressee and may contain confidential and/or privileged material. If you
are not the intended recipient, any review, disclosure, copying, distribution or any action
taken or omitted to be taken in reliance on it is prohibited by ESR. If you have received
this message in error, please notify the sender immediately.
This email has been filtered by SMX. For more information visit smxemail.com
14 January 2021
From: Peter Cressey
Sent: Thursday, 14 January 2021 11:28 am
To:
'Jeff Fowles'
Subject:
FW: Peer review query: methamphetamine contamination
Attachments: FW20045 HUD_meth-evidence DRAFT 14 Dec 2020 JES 1_1_2021.docx
Hi Jeff
Happy New Year. Hope you had a good break and are feeling rested and relaxed.
Attached is the final peer review comments on the meth report – from John Snawder.
Most of this comments relate to preferences in wording. The only substantive comment
relates to the UF for LOAEL to NOAEL extrapolation. My initial reaction is that the issues
he raises are covered by the UF for database uncertainties, but I think you are the best
person to comment on this.
Cheers
Peter
16 January 2021
Withheld under
From: Jeff Fowles <
>
Section 9(2)(a) of the
Sent: Saturday, 16 January 2021 5:25 am
Official Information Act 1982
To:
Peter Cressey
Subject:
Re: FW: Peer review query: methamphetamine contamination
Hi Peter,
I have considered the reviewer's comments regarding the RfD. He points to the gap in
robust dose-response data in the low dose range as a source of justification for
uncertainty factor of 10 for LOAEL to NOAEL. Yet, as you indicated, this is one area
where UF's overlap to a certain degree, and the somewhat vague UF for database
uncertainties would seem to have relevance in this case. It goes without saying really
that a 10x factor would "be more protective", but the question is actual y whether a 3x
factor is sufficiently protective. It seems that distinguishing appropriateness of 3 vs 10
(in this instance) is somewhat subjective. Animal data do seem to be honing in on
scarcely measurable, reversible neurological effects threshold at around 0.1 mg/kg
under conditions of stress. As the reviewer points out, ultimately it boils down to the
degree of risk one is prepared to accommodate. My preference is to remain with the 3x
given what we currently know.
Regards
Jeff
22 January 2021
From: Jeff Fowles
>
Sent: Friday, 22 January 2021 3:25 pm
To:
Peter Cressey
Subject:
peer review
Peter
Thanks for copying me in. I ful y back your view on the moving goalpost of the peer
review.
regards
Jeff
Sent from my iPhone
25 January 2021
From: Peter Cressey
Sent: Monday, 25 January 2021 9:34 am
To:
'Jeff Fowles'
Subject:
FW: Comments on final report
Attachments: FW20045 HUD_meth-evidence FINAL January 2021 VJ comments.pdf;
FW20045
HUD_meth-evidence FINAL 25 January 2021.docx
Hi Jeff
I have gone through the HUD comments. I have tried to do what their CSA suggests and
found it to be more difficult than I thought. My initial idea was to include al peer review
comments and responses as an appendix, but some of the reviewer comments don’t
really lend themselves to such a format. I have tried to add a brief precis of John
Snawder’s substantive comment and your response (section 2.4, highlighted in yel ow).
Can you have a look at this and see what you think.
Thanks
Peter
26 January 2021
From: Peter Cressey
Sent: Tuesday, 26 January 2021 9:01 am
To:
Vanessa James
Cc:
Jeff Fowles; Michel e Wil iamson
Subject:
RE: Comments on final report
Attachments: FW20045 HUD_meth-evidence FINAL 25 January 2021.pdf; HUD
comments and ESR
responses Jan 2021.docx
Hi Vanessa
Please find attached the finalised methamphetamine report, amended in response to
your review comments and the comment from your CSA. Also find attached a list of
your review comments and an indication of how we have responded to them. A synopsis
of John Snawder’s major comment and our response has been included in section 2.4.
Thank you for highlighting our inconsistency in presenting the age range of the Young
and Turner study.
This has now been fixed.
Good luck with the further work in this area that this report supports.
Kind regards
Peter
26 January 2021
Withheld under
From: Jeff Fowles <
>
Section 9(2)(a) of the
Sent: Tuesday, 26 January 2021 5:44 am
Official Information Act 1982
To:
Peter Cressey
Subject:
Re: FW: Comments on final report
Fol ow Up Flag:
Fol ow up
Flag Status: Completed
Hi Peter,
I appreciate and am grateful for the work you are doing to satisfy the peer review
process. Your proposed wording fairly describes the issue raised by the reviewer.
Perhaps consider including that the practical implication of the reviewer suggestion
would be a 3x lowering of the proposed RfD to 5 ug/kg/d. Just to make it clear to the
reader.
Best regards
Jeff
Withheld under
Section 9(2)(a) of the
Official Information Act 1982
On Sun, Jan 24, 2021 at 12:40 PM Peter Cressey <
> wrote:
Hi Jeff
I have gone through the HUD comments. I have tried to do what their CSA suggests and
found it to be more difficult than I thought. My initial idea was to include al peer review
comments and responses as an appendix, but some of the reviewer comments don’t
really lend themselves to such a format. I have tried to add a brief precis of John
Snawder’s substantive comment and your response (section 2.4, highlighted in yel ow).
Can you have a look at this and see what you think.
Thanks
Peter
25 July 2022
From: Peter Cressey
Sent: Monday, 25 July 2022 11:44 am
To:
'Jeff Fowles'
Subject:
Methamphetamine again
Hi Jeff
MHUD have commissioned us to do another smal piece of work, to answer two
questions:
1.
Does ESR recommend that 15 µg/100cm2 is also appropriate as a target level for
remediation to achieve for premises which test above this level? Please explain the
reasons for your conclusion.
2.
If ESR recommends that 15 µg/100cm2 is not an appropriate target level for
remediation to achieve under question (1), what level do you think is the highest
acceptable target level?
Please explain the reasons for your conclusion.
I have looked at this from three approaches:
*
Is there a precedent for differential trigger and target concentrations?
*
Is there a risk basis for differential trigger and target concentrations?
*
Is there likely to be a risk-benefit driver for differential trigger and target
concentrations?
The more I thought about this, the more I decided that 15 µg/100cm2 should be the sole
limit – the rework of the RfD indicates no appreciable risk below this concentration.
However, I would really appreciate discussing this with you and possibly enlisting you as
a peer reviewer (the report wil be very short). So you have any time in the next couple of
days?
Cheers
Peter
Peter Cressey
Science Leader
Institute of Environmental Science and Research Limited (ESR)
Christchurch Science Centre: 27 Creyke Road, Ilam, Christchurch 8041
PO Box 29181, Christchurch 8540, New Zealand
DDI:
/ T:
/ EXTN:
E:
Withheld under
www.esr.cri.nz
Section 9(2)(a) of the
Official Information Act 1982
27 July 2022
From: Peter Cressey
Sent: Wednesday, 27 July 2022 7:33 am
To:
'Jeff Fowles'
Subject:
RE: Methamphetamine again
Thanks Jeff. In the end I felt as though the issues were almost philosophical, rather than
scientific, so I really appreciate your input.
From: Jeff Fowles
>
Withheld under
Sent: Wednesday, 27 July 2022 3:51 a.m.
Section 9(2)(a) of the
To: Peter Cressey <
>
Official Information Act 1982
Subject: Re: Methamphetamine again
Hi Peter,
This is really wel written, and I only had a couple of typos and 1 or 2 questions for your
consideration.
From my perspective, risk assessments all fall somewhere on the spectrum of data-
driven and data-gap-driven, and this RA is somewhere in the middle with ample animal
data, but scarce control ed human data and also not much in terms of biomonitoring or
epi data of the low doses in those living in remediated vs non-remediated homes. But
those data gaps are not going to be fil ed any time soon, if ever. This document
articulates the issues very nicely and I believe should serve HUD's needs.
Regards
Jeff
On Mon, Jul 25, 2022 at 2:23 PM Peter Cressey <
> wrote:
Thanks Jeff. Its fairly short and is based on reasoning as much as on scientific material.
Il arrange the report number while you are reviewing.
Kind regards and many thanks
Peter
From: Jeff Fowles <
>
Sent: Monday, 25 July 2022 5:20 p.m.
To: Peter Cressey
Subject: Re: Methamphetamine again
Hi Peter,
Thanks for the invitation to review this. I believe I do have time to review this. Feel free to
send it across in whatever stage and I l spend some time on it. It s been a wee while
since I looked at the recent literature so I would need to update but that shouldn t be
onerous I wouldn t think.
Regards
Jeff
Withheld under
Sent from my iPhone
Section 9(2)(a) of the
Official Information Act 1982
On Jul 24, 2022, at 4:49 PM, Peter Cressey <
> wrote:
Hi Jeff
MHUD have commissioned us to do another smal piece of work, to answer two
questions:
1. Does ESR recommend that 15 g/100cm2 is also appropriate as a target level
for remediation to achieve for premises which test above this level? Please
explain the reasons for your conclusion.
2. If ESR recommends that 15 g/100cm2 is not an appropriate target level for
remediation to achieve under question (1), what level do you think is the
highest acceptable target level? Please explain the reasons for your conclusion.
I have looked at this from three approaches:
*
Is there a precedent for differential trigger and target concentrations?
*
Is there a risk basis for differential trigger and target concentrations?
*
Is there likely to be a risk-benefit driver for differential trigger and target
concentrations?
The more I thought about this, the more I decided that 15 g/100cm2 should be the
sole limit the rework of the RfD indicates no appreciable risk below this
concentration.
However, I would really appreciate discussing this with you and possibly enlisting you
as a peer reviewer (the report wil be very short). So you have any time in the next
couple of days?
Cheers
Peter
Peter Cressey
Science Leader
Institute of Environmental Science and Research Limited (ESR)
Christchurch Science Centre: 27 Creyke Road, Ilam, Christchurch 8041
PO Box 29181, Christchurch 8540, New Zealand
DDI:
/ T:
/ EXTN:
Withheld under
E:
Section 9(2)(a) of the
www.esr.cri.nz
Official Information Act 1982
The information contained in this message and/or attachments from ESR is intended
solely for the addressee and may contain confidential and/or privileged material. If you
are not the intended recipient, any review, disclosure, copying, distribution or any
action taken or omitted to be taken in reliance on it is prohibited by ESR. If you have
received this message in error, please notify the sender immediately.
This email has been filtered by SMX. For more information visit smxemail.com
The information contained in this message and/or attachments from ESR is intended
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