December 5, 2009 

The issue of environmental protection provides us a common vision that allows us to develop synergies from different backgrounds, to ensure a clean and safe environment for all life forms. There are strong correlations between health and the environment to which the quality of life can be assured and protected. It is against this background that our professional attention has been drawn to the findings of a recent investigative report by an Inter-Agency Investigative Committee referred to as “the committee” in this report on water pollution by Firestone Natural Rubber Company’s  activities.

Most recently, an investigative committee was requested by the Liberian government to look into potential pollution by Firestone around Kparnyah Town, Margibi County, Liberia. The findings 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 emanating from 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 we carefully reviewed the final report submitted by the committee, we believe three major components of the report were less than adequate.

1.      The terms of reference and parameters sampled

2.      The water sampling protocols, and  

3.      The recommendations from the committee based on the results of the samples.

Firstly, the terms of reference and the parameters given to Earthtime Inc., the company hired to conduct 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 report indicates 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 “Standard Methods” in this report).  However, based on the sampling strategy, methodology, and test results presented in the report, the report draws more questions than answers. Thirdly, the committee’s recommendations were less than adequate to address continued pollution prevention at Kparnyah Town.  

Our professional observations of the report was based on a collective knowledge of over fifty years working in the fields of environmental assessment, remediation, restoration, and health and safety exposure analysis. 

Below are the following observations:

1)            How did the investigative committee arrive at the 14 parameters given to Earthtime Inc.?  An adage in sampling states that “one only finds what one tests for.”  Could the committee have recommended running a battery of tests to determine ALL possible potential contaminants in the water? Did the committee request Firestone to submit a chemical inventory list and accompanying Material Safety Data Sheets (MSDS), to determine if other toxic substances were or are currently used at their facilities? The report did not give any detail regarding the rationale for these parameters, or how the committee reached the terms of reference.

 2)            What prompted the analysis of orthophosphate? Orthophosphate (the lone contaminant of concern per the study), in industrial use, is a corrosion inhibitor typically added to finished drinking water in low concentrations at treatment plants (<3 mg/L) to treat the water for lead or copper found in the distribution pipes.  Orthophosphate is also used in some instances when there is difficulty in balancing pH in highly acidic solutions.  Additionally, orthophosphate forms are produced by natural processes, but man-made sources include: partially treated and untreated sewage or waste water, runoff from agricultural sites, and application of fertilizers.

Could the high level of Orthophosphate be an indication of highly acidic discharge? This would contradict the (pH) test results in the report suggesting the discharge was not acidic. Could the elevated Orthophosphate levels be attributed partially or untreated waste water, runoff from other sources, or could it be attributed to the sample handling and testing methods, indicating false positive results? Accordingly, Standard Methods SM1060B (Table 1060: I) recommends that Orthophosphate samples must be filtered immediately upon collection and analyzed within 48 hours, thereafter. The sampling methodology presented in the report did not indicate that these procedures were followed.

3)                According to Standard Methods SM1060B, samples must be preserved at a temperature of 4° Celsius (39.2⁰ F) and not 40° Celsius (104⁰ F) as documented in the report. This alone, with no qualifier on the samples may allow the analysis to be lower than the MCL (Minimum Contamination 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 samples are duplicate samples labeled differently and sent to the laboratory. Both the QA/QC and properly labeled samples should have the same results; otherwise, the lab results are questionable.  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 another standard industry practice that guarantees proper handling and transfer of the samples from the collection point, ensuring the integrity of the collected samples, to the designated qualified laboratory. Furthermore, documentation from the receiving laboratory was not disclosed in the report, 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 Firestone would have considered the following: 

 1.                 A complete review of Firestone's natural rubber process; review of the list of 

                    chemicals, material safety data sheets (MSDS) of chemicals that are used in their operational process. 

                    A Full review of their treatment plant operations, its chemicals used in the treatment process, daily and 

                   monthly peak flow rates. From this review, develop a sampling regiment and establish comprehensive list 

                   of chemical/physical parameters (organic, inorganic, volatile organic compounds, etc) to target for laboratory analysis. 

                   This will provide the rationale for selecting the chemicals to be targeted.

 2.               Develop an Implementation Work Plan to address sampling procedures, test methods, 

                    sampling frequencies, health and safety requirements for personnel collecting the samples, define the 

                    data quality objectives, leading to the site-specific data use and planning. This plan defines and establishes the quality 

                     assurance objectives; defining the criteria for sampling and evaluations analysis. 

 3.                In the absence of Environmental Protection Agency of Liberia (EPAL) Regulatory standards, establish baseline or 

                     background concentrations of all analysis by collecting series of samples from locations up-gradient of the secondary treatment pond. 

                     This way, the results of samples collected from the creeks could be evaluated against site-specific conditions in lieu of 

                      comparing the results to World Health Organization (WHO) or Liberia's Class I, II, or III water quality standards.

4.                 In addition to the sample locations selected, collect samples at the influent into the secondary pond from the treatment

                     plant to know the concentrations of wastewater entering the pond, than compare it to the effluent concentration.

5.                   Collect a series of samples from all engineered/scientifically established locations over a period of time at specific 

                       intervals (i.e. monthly or quarterly), to obtain sufficient data to assess the environmental impact of Firestone’s operation

                      on the creeks. One sampling event is not sufficient to draw a reasonable conclusion in a study of this kind.

6.                   Consider sediment samples as certain organic and inorganic particulates may settle in river beds. Once settled, 

                       it may be an ongoing source of pollutants to the water body or trigger the potential for groundwater contamination or harm 

                       living organism in the river. 

 7.                    Avoid placement of samples in a cooler with temperature at 40 degrees Celsius (104 degree F). SM1060B recommends 

                        that all samples must be preserved at a temperature of 4 degrees (39.20 F) Celsius, not at 40 degrees.

 8.                    Avoid collecting samples during a rainfall event as shown in the photographs. This may contribute to dilution of the 

                        samples (as units are pulled from the streams) and may raise questions about the integrity of data collected, especially 

                       with non-storm water sampling activities. It is important that containers used to pull samples prevent foreign bodies 

                       from mixing with the samples.

9.            Take sample of the confluence and the Farmington River where these stream flow.  According to the report, only the creeks were contaminated, but these creeks flow into the Farmington River. What is the status of the water quality at Farmington River?

10.         Taking organism survey between three segments of water would provide valuable information regarding the impact of 

              the Firestone operations on Ninpu Creek.  This survey should include the segment of water upstream of the discharge point, 

              the segment immediately adjacent to discharge and down toward the confluence of Vah Creek and then the Vah Creek 

               upstream of the confluence with the Ninpu Creek. Can these segments support life? 

 The committee’s recommendations also do little to correct the pollution issue or provide appropriate relief for the residents 

  of Kparnyah town or the environment. Furthermore, the full cost of the investigation should be deferred to the guilty party, and

  should not be at the expense of the Liberian people.  The report recommends that Firestone and Kparnyah should work to solve their 

   problems but makes no mention of enforcing the environmental laws of Liberia which calls for a fine of $50,000.00 plus the cost 

   of returning the environment to its original state (as much as is practical).  

 As such, we recommend the following:

1. Firestone should IMMEDIATELY stop discharging into water bodies pending a new investigation conducted by a qualified third party. This time, fully delineate the vertical and horizontal extent of ANY contamination.

2. The residents in the affected communities should be privileged to medical care to ensure their safety, and henceforth, be placed under IMMEDIATE medical surveillance. Who ever is found guilty of contaminating the river shall bear the cost pending a thorough investigation. This requires free periodic clinical visits for a time determined by a qualified medical personnel, until the risk of chronic health effects are mitigated and/or eliminated.

3. Domestic water should be IMMEDIATELY provided to the affected residents, and whoever is found guilty of contaminating the water supply shall bear the cost pending a thorough investigation.

4. Both Firestone and the Government of Liberia should provide an independent third party to conduct a thorough investigation; and also conduct studies on suggested remedial methods, and anyone found guilty of contaminating the river shall bear the cost, pending a thorough investigation.

5. A complete monitoring regime should be constituted based on site specifics that should be established by the Environmental Protection Agency of Liberia; providing a continuous data on established sample media (i.e. monitoring wells, soil, and surface water) – said monitoring should be conducted by a qualified environmental specialist for a period until the significant threat is established to have been eliminated.

6. Access to contaminated water bodies should be restricted until remediation exercises are completed.

7. The residents of Kparnyah Town claimed three (3) lives have been lost as a result of drinking contaminated water. This allegation needs to be thoroughly investigated to establish validity of claims.

In view of the above comments, we suggest that President Ellen Johnson-Sirleaf revisits the report by the government’s committee and reconstitute another team that is capable, and possesses the technical skills to perform a thorough investigation. We further suggest that the President and the government fund the new committee adequately to conduct this investigation (cost subsequently deferred to guilty party).

Africa Environmental Watch, in collaboration with Members of the Liberian Society of Environment, Health, and Safety Professionals (LSEHSP) believe that pollution impacts the health of people and life forms everywhere in Liberia, and should therefore, claim our utmost attention.

We believe that the environment (planet), the people (social) and the economy (prosperity) are all critical to the pursuit of Liberia’s Poverty Reduction Strategy objectives.

Thank you,

AFRICA ENVIRONMENTAL WATCH

MORRIS KOFFA – EXECUTIVE DIRECTOR

Liberian Society of Environment, Health, and Safety Professionals (LSEHSP)

LENUS PERKINS, BSCE, CQM. – INTERIM CHAIRMAN

PHILIP B. SUAH, Jr. MBA, EHS – MEMBER

MORRIS KOFFA, MS, ELP, CFPM – MEMBER

ANTHONY S. NAH, JR. MS, CHSP, CIAQM, HEM, EMS - MEMBER

B.K. ROBERTSON, Ph.D. --MEMBER