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No other federal environmental legislation forbids disposal of mater- 
ials based upon the mere presence of carcinogens, mutagens, and tera- 
togens. Freshwater and marine water quality criteria are defined in 
terms of unreasonable risk. None of the carcinogens, mutagens, and 
teratogens for which water quality criteria have been set are known 
to be present in the New York Bight at concentrations even approach- 
ing accepted lifetime risk levels as established by EPA. 
Many Careinopenaiamicagenebana teratogens occur naturally in the 
environment. In fact, chemicals which are essential to life at one 
concentration may be carcinogenic or teratogenic at other concentra- 
tions (e.g., selenium and vitamin A, respectively). Information on 
the vast majority of carcinogens, mutagens, and teratogens is rare, 
and for many of these chemicals no analytical procedures exist. 
Thus, this proposed prohibition is inappropriate and technically 
insupportable. At the London Dumping Convention meeting in 1981, the 
inclusion of carcinogens, mutagens, and teratogens as prohibited 
materials was proposed to be included in Annex I. The proposal was 
rejected specifically because of the inadequacy of technical 
information that could be interpreted in any meaningful regulatory 
manner. 
To prohibit the ocean disposal of a waste due solely to the presence 
of an objectionable constituent, regardless of concentration, 
expected dilution, or potential effects, as proposed in the draft 
Amendment, is arbitrary and technically unsupportable. 
