RACHEL'S ENVIRONMENT & HEALTH WEEKLY #471
. . ---December 7, 1995---
. . HEADLINES:
. . THE FOUR HORSEMEN -- PART 1
. . ==========
. . Environmental Research Foundation
. . P.O. Box 5036, Annapolis, MD 21403
. . Fax (410) 263-8944; Internet: erf@rachel.clark.net
. .

There are dozens or hundreds of small environmental problems, but there are only four really big ones that we know of today. If we could solve these four, we might lick more than 90% of the world's known environmental threats. The four are:

(1) burning of fossil fuels (coal, oil, and natural gas), leading to global warming and the creation of killer air pollution (fine particles; see REHW #440, #373);

(2) use of chlorine as an industrial feedstock, leading to destruction of the earth's ozone shield and the widespread poisoning of humans and wildlife by reproductive toxins and hormone-mimicking, gender-bending chemicals, plus widespread damage to the immune systems and nervous systems of humans and other species by a host of solvents, pesticides, and other chlorinated industrial compounds;

(3) the mining and distribution of uranium and its byproducts, leading to an unsolvable problem of long-lived radioactive waste, and an ever-growing likelihood of enormous violence--acts of terrorism causing 100,000 or more deaths in one instant;

(4) so-called "development" that degrades and diminishes biodiversity, leading to major, irreversible loss of species, destabilizing all life. These are the four horsemen[1] of the environment, and as 1995 slouches to a close, all four are upon us. This week we'll discuss the first two.

Fossil Fuels and Global Warming

** The world's scientific community this year acknowledged that global warming has begun and that humans are an important cause.[2] Later this month, the United Nations Intergovernmental Panel on Climate Change (IPCC) is expected to release its new 2000-page report, which circulated in draft form this summer. (Copies of the final report will be available from Sandra Vaughn-Cook at the U.S. Global Change Research Program in Washington, D.C.; phone (202) 651-8250.) As CHEMICAL & ENGINEERING NEWS (C&EN) describes it, the IPCC final report says:

** Average air temperature of the earth has increased somewhere between 0.5 and 1.0 degrees Fahrenheit since 1880; during the same period, the level of the world's oceans has risen 3.9 to 9.8 inches; glaciers are melting, especially glaciers in the southern hemisphere where some have disappeared completely during the past 20 years; moreover, the shrinking of glaciers has accelerated in recent years. Coral reefs are blanching (turning white) and some are dying because of unusually high ocean temperatures. And if this year's trend continues, 1995 will stack up as the hottest year since record-keeping began in this country in 1860.

"There is also a general consensus that higher temperatures projected for the next century will cause more frequent and intense heat waves, wide-scale ecological disruptions, a decline of agricultural production in the tropics and subtropics, and continued acceleration of sea-level rise," reports CHEMICAL & ENGINEERING NEWS.

In sum, there is now a scientific consensus that global warming is occurring, and that its future effects will be significant; "wide-scale ecological disruptions" are going to be uncomfortable and expensive. What's agreed-upon is bad. But what's being discussed credibly is catastrophic. CHEMICAL & ENGINEERING NEWS --a publication of the American Chemical Society, not known for wild-eyed environmentalism --discusses the possible disintegration of the Antarctic ice pack.[3] If the ice pack should slide into the ocean, the oceans would rise 74 meters (240 feet) in short order. Coastal cities would drown, and vast areas of agricultural land would disappear.

As we go to press, Congress is haggling over budget cuts --ranging from 25% to 41% --that will greatly diminish the U.S.'s ability to conduct scientific studies of global warming, perhaps on the theory that no news is good news --or perhaps because the oil and coal corporations pumped $1.2 million dollars into Congressional re-election war chests in the first 6 months of 1995, according to the Center for Responsive Politics in Washington, D.C.

During 1995, bad news continued to accumulate about the ill effects of chlorinated chemicals on wildlife and humans, and on global ecosystems such as the earth's protective ozone layer. Unfortunately, corporate producers and users of such chemicals seem incapable of restraining themselves; therefore with help from their indentured government they continue to resist the obvious need for a phase-out of chlorine as an industrial feedstock.

Example: propiconazole. "Modern" farmers use this chlorinated compound as a fungicide (i.e., it kills fungus). It is a member of a class of chemicals called imidazole derivatives. One of the characteristics of imidazole derivatives is that, in mammals, they suppress the production of certain sex hormones.[4] This effect is so powerful that some imidazole derivatives have been considered for use as male contraceptives in humans because they sterilize men.[5]

In wildlife, propiconazole greatly enhances the toxic action of organophosphate pesticides such as malathion, chlorpyrifos, and diazinon. In birds (partridge, Japanese quail, house sparrows, and tree sparrows, among others) and in honey bees, the presence of propiconazole increases the potency of organophosphate pesticides six-fold to 18-fold.[6] Because birds and honey bees move from place to place, they can encounter organophosphate pesticides in one locale and imidazole-derivative fungicides in a different locale. Even though no government "standards" may have been violated at either locale, the combined effects on the birds and the bees may be lethal. (This is one reason why "risk assessments" give false and misleading assurances of "safety" for individual chemicals, because they can never take into consideration the combined effects of multiple chemicals. See REHW #470.)

In Norway, researchers suspected that propiconazole might disrupt the natural balance of microscopic organisms in a stream that received runoff from propiconazole-treated fields. Under experimental conditions, they showed that propiconazole at 5 parts per billion (ppb) completely eliminated algae from a stream. Algae provide the first link at the bottom of the food chain.[7]

U.S. EPA [Environmental Protection Agency] considers propiconazole a "Class C" carcinogen, in other words a "possible" carcinogen in humans, based on limited data from laboratory experiments on animals.[8]

One might think that --knowing facts such as these --rational people would be working hard to phase out such potent endocrine-disrupting, carcinogenic poisons. But one would be wrong. In June, 1995, Ciba-Geigy, the Swiss chemical giant operating from an office in Greensboro, North Carolina, sought permission from EPA to leave propiconazole residues on oats at 100 ppb. Mmmmm, good. Ciba-Geigy also has a request pending before EPA to allow propiconazole residues at the level of 1500 ppb on "stone fruit" crops --peaches, apricots, plums, and prunes. On November 15 of this year, EPA proposed a new pesticide rule that would legalize propiconazole residues on mint leaves and stems, and on mushrooms. In other words, the use of this poison is expanding, not declining. Some would consider this clear evidence that government is incapable of acting in the public interest. Others would conclude from the same evidence that corporations are inherently incapable of acting in the public interest and the government they have bought and refashioned in their own image is merely aping their amoral behavior. Either way, chances for discussing a phaseout of chlorinated chemicals seem more remote than they did just a year ago.

The optimistic view is that the Montreal Protocol--the international treaty designed to get DuPont's deadly CFCs off the market by this year --will allow the ozone hole to heal itself within 50 to 100 years. This view assumes 100 percent compliance with the Montreal Protocol.

But in September, reliable sources indicated that an enormous "black market" in CFCs has appeared. According to Ozone Action, an advocacy group in Washington, D.C., up to 22,000 tons (44 million pounds) of black market CFCs are entering the U.S. each year as people resist investing in CFC-free equipment. Furthermore, the black market isn't the only loophole in the law. "The real crime is what's legal," says John Passacantando, executive director of Ozone Action. "The U.S. Environmental Protection Agency is preparing to celebrate Ozone Layer Awareness Week, and assures us that December 31, 1995 is the last day CFCs can be manufactured in the U.S. Taking into account two Clean Air Act provisions which allow production after 1995, U.S. companies may still produce 60,000 tons of CFCs [per year], which is almost 75 percent of 1993 production levels. That's a long way from the public perception of what a ban means," Passacantando says.[10] As we go to press, Congress is debating whether to thumb its nose at the Montreal Protocol by repealing the sections of the Clean Air Act that ban domestic sales of CFCs. (Foreign sales of CFCs by U.S. corporations will remain legal in any case.)

[Next week: The other two horsemen.]

--Peter Montague ===============

[2] Bette Hileman, "Climate Observations Substantiate Global Warming Models," C&EN [CHEMICAL & ENGINEERING NEWS] Vol. 73, No. 48 (November 27, 1995), pgs. 18-23.

[3] "Higher temperatures in Antarctica have led to disintegration of some ice shelves," C&EN [CHEMICAL & ENGINEERING NEWS] Vol. 73, No. 48 (November 27, 1995), pg. 20.

[4] Allan Pont and others, "Ketoconazole Blocks Testosterone Synthesis," ARCHIVES OF INTERNAL MEDICINE Vol. 142 (November 1982), pgs. 2137-2140.

[5] Gerald A. LeBlanc, "Are Environmental Sentinels Signaling?" ENVIRONMENTAL HEALTH PERSPECTIVES Vol. 103, Number 10 (October 1995), pgs. 888-890.

[6] Gail Johnston and others, "Interactive Effects Between EBI Fungicides (Prochloraz, Propiconazole and Penconazole) and OP Insecticides (Dimethoate, Chlorpyrifos, Diazinon and Malathion) in the Hybrid Red-Legged Partridge," ENVIRONMENTAL TOXICOLOGY AND CHEMISTRY Vol. 13, No. 4 (1994), pgs. 615-620.

[7] Karl Jan Aanes and Torleif Baekken, "Acute and long-term effects of propiconazole on freshwater invertebrate communities and periphyton in experimental streams," NORWEGIAN JOURNAL OF AGRICULTURAL SCIENCE Volume unknown (1994, Supplement 13), pgs. 179-193.

[8] FEDERAL REGISTER Vol. 60, No. 220 (November 15, 1995), pgs. 57375-57377. Available on-line from wais.access.gpo.gov.

[9] Dan Lubin and Elsa H. Jensen, "Effects of clouds and stratospheric ozone depletion on ultraviolet radiation trends," NATURE Vol. 377 No. 6551 (October 26, 1995), pgs. 710-713; and see Sasha Madronich, "The radiation equation," NATURE Vol. 377 No. 6551 (October 26, 1995), pgs. 682-683.

[10] Matthew L. Wald, "Smuggling of Polluting Chemicals is Described," NEW YORK TIMES September 17, 1995, pg. 30. And see Julie Edelson Halpert, "Freon Smugglers Find Big Market," NEW YORK TIMES April 30, 1995, pgs. 1, 31. And see Associated Press, "A Black Market in Coolants," NEW YORK TIMES October 26, 1994, pg. A22.

Descriptor terms: fossil fuels; coal; oil; natural gas; global warming; energy; chlorine; chlorinated hydrocarbons; solvents; pesticides; chlorofluorocarbons; cfcs; ozone depletion; uranium; plutonium; nuclear weapons; nuclear war; terrorism; proliferation; development; loss of biodiversity; loss of species; un; ipcc; oceans; glaciers; coral reefs; agriculture; food; agricultural productivity; heatl drought; propiconazole; fungicides; money in politics; campaign finance; congress; imidazole derivatives; wildlife; carcinogens; sterilants; contraceptives; ciba-geigy; endocrine disruptors; endocrine system; ultraviolet radiation;

          
.                    ---November 30, 1995---                    .
.                          HEADLINES:                           .
.                     MAKING GOOD DECISIONS                     .
.                          ==========                           .
.               Environmental Research Foundation               .
.              P.O. Box 5036, Annapolis, MD  21403              .
.      Fax (410) 263-8944; Internet: erf@rachel.clark.net       .
.                          ==========                           .
.  

MAKING GOOD DECISIONS

Risk assessment is one way of making decisions, but it is not the only way, and it is not the best way.[1] Furthermore, risk assessment as usually practiced is unethical.

Risk assessment has been described by the National Academy of Sciences (NAS) as a four-step process.[2]

STEP 1: HAZARD IDENTIFICATION. This step is supposed to estimate chemical damage from acute (single dose), subchronic (a few doses), or chronic exposures for each possible toxic endpoint. Toxic "endpoints" include cancer, damage to organs (liver, kidney, heart, etc.), developmental disorders, damage to the immune system, central nervous system, reproductive system, and genes. Because organisms (whether hamsters or people) react differently at different stages of development, particularly while in the womb, dozens of "endpoints" must be considered. In actual practice, most endpoints are simply ignored.

STEP 2: DOSE-RESPONSE ASSESSMENT. Dose-response assessment means determining what damage, and to which bodily systems, will occur as the dose of a chemical increases. Most people are familiar with the concept of dose-response; think of the effects from drinking one, two, or three glasses of wine. In general, greater dose leads to greater effect. Usually assessing dose-response for a chemical requires estimating ("extrapolating") from data about laboratory animals, who have been given high doses, to effects in humans who typically receive low doses from environmental exposures. There are many different ways of "extrapolating" from high-dose animal data down to low-dose human estimates.

STEP 3: EXPOSURE ASSESSMENT. Exposure assessment tries, or should try, to determine how much of a chemical is absorbed from all sources. Example: if the chemical is a pesticide, exposures might occur through food, water, air, and perhaps even skin, through home and occupational uses. (In practice, many sources of exposure are usually ignored.)

STEP 4: RISK CHARACTERIZATION. Ideally, risk characterization takes information from hazard assessment, dose-response assessment, and exposure assessment, then adds information about the characteristics of the affected population --How old are they? Are they generally malnourished? Overweight? --and combines it all together to determine an estimate of hazard (called "risk"). (In practice, the characteristics of a particular population are usually ignored and averages are used instead.) Hazard (called "risk") is expressed as a probability of a particular kind of harm to a specified group of people during a stated period of time. For example, a typical estimate of "risk" might be expressed this way: a particular group of people is expected to endure one additional cancer for every 100,000 people, over and above the normal risk of cancer, as a result of chronic exposure to some toxic chemical in their drinking water during their lifetimes of 70 years.

Despite the NAS's idealistic description of risk assessment, the process is deeply flawed and subject to abuse.

** RISK ASSESSMENT IS INHERENTLY MISLEADING: In actual fact there are no agreed-upon ways for assessing nervous system damage, immune system damage, or damage to the genes.[3] Furthermore, science has no way to evaluate the effects of exposure to several chemicals simultaneously. Because everyone in the real world is exposed to multiple chemicals simultaneously, risk assessment is never describing the real world, yet almost always PRETENDS to describe the real world. Risk assessment pretends to determine "safe" levels of exposure to poisons, but in fact it cannot do any such thing. Therefore, risk assessment provides false assurances of safety while allowing damage to occur. It is therefore inherently misleading.

** RELIANCE ON RISK ASSESSMENT HARMS DEMOCRACY: Because risk assessment is a mathematical technique, most people cannot understand, or participate in, risk assessments. Therefore, reliance on risk assessment for decision-making harms democracy because most people are excluded from the process.

** A BETTER WAY OF MAKING DECISIONS IS AVAILABLE: To assure that all viewpoints are brought to the table, we should not rely on risk assessment for decision-making. Instead, we could employ a decision-making technique that was described in the National Environmental Policy Act (NEPA) of 1969, a federal law. NEPA requires that, before certain decisions can be made, all reasonable alternatives must be examined. If this approach is taken, then the public can get involved in describing and discussing all reasonable alternatives. In such a process, all viewpoints can be aired. Cultural values, historical perspectives, and local concerns can all be brought into the decision, along with issues of technology, costs, and benefits. People can look at all the alternatives and can decide which one they prefer. The process of thinking about alternatives is healthy for a community --it helps people visualize the future that they want for themselves and their children. Risk assessment suppresses such discussions.

** NO RISK IS ACCEPTABLE IF IT IS AVOIDABLE: When people are examining a full range of alternatives, they have an opportunity to apply the principle that, "No risk is acceptable if it is avoidable." However, when people are merely doing a risk assessment, this principle cannot come into play. A risk assessment never reaches the conclusion that a risk is avoidable because risk assessment NEVER asks whether a particular risk can be avoided. That is simply not a question that risk assessment asks.

An example will show the difference between these two approaches (risk assessment vs. examining all the alternatives): In some communities, a decision has been made (often without any public input) to burn solid waste. This decision has then been justified by a risk assessment. A risk assessor is called in to show that the incinerator will "only" harm one in a million people living nearby. Because the harm is so "small," the incinerator is deemed "acceptable."

This is a typical use of risk assessment, to justify a decision that was made by lawyers, financial analysts, bankers, corporate officials, and elected officials. Often, such a decision is announced after the fact, and then a risk assessment is completed to "prove" to the public that such a decision is "acceptable."

Another way of approaching an incinerator would be to step back and ask, "What is the problem we are trying to solve here?" One answer is "the problem of solid waste" or perhaps even "use and disposal of items that are not biodegradable."

Then the question becomes, what are the different ways of solving such a problem? Here the public will have a great deal to say, and the search for an answer can be a model of democracy. For some portion of solid waste, recycling and reuse are obvious alternatives to incineration. Separating out the toxic materials, and landfilling the remainder, is another alternative. Some communities have even banned certain kinds of consumer products because they are so difficult to get rid of without creating dangers. Batteries that contain mercury are one example; certain plastics are another example. Obviously there are many alternatives to examine, including some alternatives that involve asking people to consider changing their own behavior.

Once the various alternatives have been described, then risk assessment could be applied to each alternative, as one part of a decision-making process.

** RISK ASSESSMENT FAILS TO EVALUATE BENEFITS: Another advantage of "examining all the alternatives," compared to risk assessment is this: Risk assessment does not examine benefits, but "examining all the alternatives" does. Naturally, when people make a choice, they want to balance the disadvantages AND the advantages, the costs AND the benefits. Risk assessment merely assesses the costs (the "risks") of one proposal and asks whether those costs are "acceptable" or not. But people in the real world don't just want to know whether the "costs" are acceptable --they also want to know whether the "benefits" are sufficiently desirable. Assessing all the alternatives will allow people to discuss benefits as well as costs.

** RISK ASSESSMENT OF ONE OR A FEW CHOICES IS UNETHICAL: The environment is being harmed and needs to be protected. Therefore, ethical considerations require us to try to harm the environment as little as possible. Risk assessment does not ask the question, "What is the least harm we can do?" Instead, risk assessment asks, "Will the damage we are going to do be acceptable?" To provide an ethical framework for decision-making, we need to ask, "Which alternative will bring sufficient benefits AND minimize damage to the earth?" If a decision has not been made by examining all available alternatives and then selecting the least-damaging alternative, the decision is not an ethical one. Risk assessment as commonly practiced is unethical because it excludes discussion of reasonable alternatives, including least-damaging alternatives.

In sum, in the recent past, risk assessment has often been used to impose bad decisions on people-of-color communities, on indigenous people, and on communities that lack political power. Even when risk assessment is used for legitimate purposes, it falls short as a decision-making technique because it does not consider benefits or alternatives; it only evaluates "risks" and furthermore it only evaluates some of the "risks." Finally, it can never evaluate the hazards of multiple exposures.

The main decision-making tool that we should rely on is "looking at all the available alternatives" and having a full public discussion of the costs AND THE BENEFITS of those alternatives. This approach can engage the community in discussion of what is desirable and what is important, not merely what is an "acceptable risk." In an open, democratic decision-making process, risk assessment might play some role in helping people evaluate a full range of alternatives, but it should certainly never be the only decision-making technique, and it should never be applied to a single choice or to a narrow range of choices.

Unless we search for least-damaging alternatives, our decisions cannot be ethical ones. A decision made by examining the risks of a single alternative, or of a narrow range of alternatives, can never be an ethical decision. Protecting the environment requires us to examine all the alternatives in an open, democratic process, examine all the costs and all the benefits, and then choose the least-damaging alternative.

--Peter Montague =============== [1] Thanks to Tom Goldtooth of the Indigenous Environmental Network (IEN), and to Paul Connett of St. Lawrence University, who expanded our thinking about risk assessment. Credit for the main ideas in this discussion of decision-making belongs to Mary O'Brien, who nevertheless bears no responsibility for the way those ideas are presented here.

[2] National Research Council, RISK ASSESSMENT IN THE FEDERAL GOVERNMENT: MANAGING THE PROCESS (Washington, D.C.: National Academy Press, 1983).

[3] See Anna Fan, Robert Howd, and Brian Davis, "Risk Assessment of Environmental Chemicals," ANNUAL REVIEW OF PHARMACOLOGY AND TOXICOLOGY Vol. 35 (1995), pgs. 341-368.

Descriptor terms: risk assessment; decision making; hazard assessment; chemicals; toxicity; immune system; nervous system; genes; endrocrine system; reproductive system; developmental damage; toxicity; ethics; cancer; carcinogens;

Back issues available by E-mail; to get instructions, send . . E-mail to INFO@rachel.clark.net with the single word INFO . . in the message; back issues also available via ftp from . . ftp.std.com/periodicals/rachel and from gopher.std.com. . . Permission to repost, reprint or quote is hereby granted. . . Subscribe: send E-mail to rachel-weekly-request@world.std.com . . with the single word SUBSCRIBE in the message. It's free. . =================================================================

WEEKLY NEWS UPDATES