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MODERN ENVIRONMENTAL PROTECTION--PART 2
Is it merely by coincidence that the NEW YORK TIMES chose the birthday of the United States -- July 4th -- to discuss the metaphors that scientists are now using to describe the destruction of the global ecosystem?
What is the best metaphor to help us understand the accelerating disappearance of animal and plant life and indigenous people world-wide, including the U.S. where one-third of all animals and all plants are now at risk of extinction and where the destruction of indigenous people exceeded 90% some time ago?
** Is the best metaphor the airplane losing rivets? Many rivets can pop out without having any effect on the airworthiness of the plane, but eventually the loss of one-too-many rivets will cause a crash.
** Or is it more appropriate to compare the global ecosystem to a rich, diverse tapestry, a metaphor used by Carlos Davidson, a conservation biologist at the University of California (Davis) in an interview with TIMES staff writer William K. Stevens. "The function and beauty of the tapestry is slightly diminished with the removal of each thread. If too many threads are pulled -- especially if they are pulled from the same area -- the tapestry will begin to look worn and may tear locally." In this metaphor, there is no "crash," but rather a "continuum of degradation" from "a world rich in biodiversity to a threadbare remnant with fewer species, fewer natural places, less beauty, and reduced ecosystem services." According to this metaphor, any crashes that may occur (such as the collaps e of a fishery) are relatively rare and local.
** But, says Stevens, even the tapestry metaphor seems "incomplete" because "if the human impact on the rest of nature is as pervasive and encompassing as many scientists say," then humans are not just fraying the tapestry they are re-weaving it in entirely new patterns which are "markedly simpler, duller, and less functional than the original."
The main impact of humans is to simplify the Earth and simplification itself leads to the danger of collapse, according to G. David Tilman and Kevin S. McCann, both of whom recently published articles on biodiversity in the British journal NATURE.[2,3] Only during the past 10 years have scientists been able to show that diversity is important to the stability of ecosystems. David Tilman told William K. Stevens, "We're simplifying the world on a mass scale, an unprecedented scale."
Tilman points out that we now know for sure that simplified ecosystems are subject to collapse, and we see the tapestry metaphor beginning to converge with the rivet metaphor. It is diversity that allows an ecosystem to survive during times of stress, such as drought. Because of diversity, drought will not kill every part of an ecosystem, so there is something remaining from which to rebuild. A grossly simplified ecosystem may not be able to rebuild, and desert conditions (for example) may become the norm. (An estimated 35% of the world's land is now threatened by the advance of deserts.[4]) From a human viewpoint, simple ecosystems can be very productive (farmer's fields of corn, for example), but they are fragile and subject to collapse (for example, the Irish potato famine of 1845-1851 killed a million people). Thus even "local" collapse can be exceedingly painful for those involved.
Humans are altering the face of the earth in three major ways, according to Jane Lubchenco, former president of the American Association for the Advancement of Science: (a) transforming the land and the sea, through land clearing, forestry, grazing, urbanization, mining, trawling, dredging, and so on -- all the activities we call mis-label "development;" (b) adding or removing species and genetically distinct populations via habitat alteration or loss, hunting, fishing, and introductions and invasions of species; and (c) altering the major biogeochemical cycles, of carbon, nitrogen, water, and synthetic chemicals....
Probably the easiest of all these problems to solve is the industrial contamination of the globe with exotic, dangerous chemicals. Jane Lubchenco describes the problem this way: "Novel chemical compounds -- ranging from chlorofluorocarbons to persistent organic compounds such as DDT and PCBs -- are being synthesized and released. Only a few of the thousand or so new chemicals released each year are monitored; the biological effects of most are unknown, especially synergistic interactions of different compounds, and interference with developmental and hormonal systems." Note that all of Lubchenco's examples are chlorinated compounds -- ozone-destroying chlorofluorocarbons (CFCs), DDT and PCBs. These are good choices because chlorinated compounds tend to be toxic, long-lived, and incompatible with ecosystems. Phasing out chlorine on a strict schedule -- the way the world is trying to phase out CFCs through the Montreal Protocol -- would be a rational step that humans could take to reduce the destruction of the Earth.
The Chlorine Chemistry Council -- the association of corporations that make and sell chlorinated chemicals -- argues that the world should continue to regulate chlorinated chemicals one-by-one using risk assessments, the regulatory status quo. They have one main reason for advocating this position: they know it can never lead to any significant curtailment of the chlorinated chemical industry.
The only rational, protective policy would be to phase out all chlorinated chemicals as a class. All of them. If any were to be retained, they would be exempted from phase-out on a case-by-case basis. In other words, the burden of proof should be shifted from the public onto the chlorine-using polluters: they should have to show that their wares are not causing, or going to cause, significant harm.
In other words -- as Joe Thornton says in his excellent new book, PANDORA'S POISON [6] -- before a substance can be introduced into commerce, the manufacturer should have to show that the substance and its associated by-products and breakdown products are neither persistent nor bioaccumulative and that they are not carcinogenic, mutagenic, disruptive of intracellular signaling (by hormones, neurotransmitters, growth factors, cytokines, and so on), or toxic at low doses to development, reproduction, immunity, or neurological function. Very few organochlorines could pass such a test. Thus, this would be entirely too great a burden for the chlorinated chemical industry to bear, and they know it. So they favor a continuation of the entirely ineffective present regulatory system based on risk assessments chemical by chemical, one at a time.
As Joe Thornton points out, there are seven reasons why chemical-by-chemical regulation of chlorinated chemicals has failed:
1) There are 11,000 chlorinated compounds created intentionally and thousands more created unintentionally. Furthermore, new chemicals are brought on the market much faster than toxicologists can evaluate their hazards. As of the early 1990s, EPA [U.S. Environmental Protection Agency] had established effluent guidelines for 128 chemicals, had prepared health assessments on fewer than 100 chemicals, and had issued air emission standards for fewer than 10 chemicals. This is the result of 30 years of intense effort. EPA's scientific reassessment of the hazards of just one organochlorine chemical -- dioxin -- has been underway since 1991 and is still in draft form. Even if EPA were to assign vast new resources to the task of evaluating the hazards of chlorinated chemicals, it would take many, many centuries to complete the task.
2) Organochlorines are formed as complex mixtures of thousands of compounds, and the great majority of chlorinated by-products remain unidentified and unknown. I t is not possible to assess and control on a chemical-by-chemical basis compounds that have not been identified.
3) Even if our goal were to eliminate only the most persistent, bioaccumulative and toxic organochlorines, the only practical way to accomplish this would be to phase out all of them because chlorine chemistry cannot be practiced without creating large quantities of persistent, bioaccumulative and toxic by-products. As Thornton points out, the continuing production of thousands of tons of PCBs each year -- decades after the intentional manufacture of PCBs was outlawed -- shows the failure of chemical-by-chemical regulation. Dioxin is in the same class -- almost all chlorinated products and processes create dioxin somewhere along the way -- so to avoid the production of this most toxic of all chlorinated compounds, all chlorine chemistry must be phased out.
4) The limits of toxicology and epidemiology make the chemical-by-chemical approach unsuitable for protecting health and ecosystems. Organochlorines occur in complex mixtures, so toxicologists and epidemiologists will never be able to sort out which chemical is causing which health effects because, as Thornton says, "the fact is that groups of these compounds are always responsible." "In contrast, a focus on the technologies that cause organochlorine pollution eliminates the formation of these mixtures, immediately dispensing with the problems of unidentified compounds and synergistic effects," Thornton points out.
5) The fifth reason is economic: as society phases out one organochlorine (for example, DDT), the chlorine industry creates a market for another chlorinated product and thus maintains -- or accelerates -- its program of global destruction. What the world needs is a reduction in the total burden of chlorinated chemicals, not just a reduction in one or two or 10 specific compounds. Chemical-by-chemical regulation can never give the planet respite from the chlorine scourge.
6) It makes no sense to presume that the thousands of untested organochlorines are benign, given that virtually every chlorinated compound ever tested causes one or more toxic effects. Chlorination almost always increases the toxicity and the bioaccumulation of organic chemicals. It is therefore logical and consistent with existing knowledge to presume that all chlorinated compounds are hazardous unless specific information suggests otherwise.
7) The last reason for treating organochlorines as a class is ethical. Chemical-by-chemical regulation assumes each chemical is innocent until proven guilty. This places the burden of proof on the public to prove that each chemical is harmful. As Thornton says (pg. 353), the result is a vast, poorly documented program of chemical experimentation on the public, "in which the ecosystem and our bodies are contaminated by novel chemicals, the effects of which are not well known, but are likely to be harmful." People have a right not to be experimented on without informed consent; no one has ever had the opportunity to grant or deny their consent before being exposed to the organochlorine burden that now contaminates us all." Joe Thornton is too generous to say so, but the chlorophiles -- the lovers of chlorine chemistry -- are imperceptibly different from the Nazis of the Third Reich in their willingness to allow monstrous experiments upon hapless, captive victims, world-wide.
--Peter Montague
MODERN ENVIRONMENTAL PROTECTION--PART 1
Two extraordinary books have just been published by MIT Press. Together, they describe a fundamentally new approach to environmental protection. This week we begin reviewing Joe Thornton's PANDORA'S POISON.[1] Soon we will review Mary O'Brien's MAKING BETTER ENVIRONMENTAL DECISIONS.[2] In these two books, we see the best environmental thinking of the past 15 years really coming together. This is what we've all been waiting for -- a new system for environmental protection that can unite the various strands of the environmental community behind a few shared goals and a common agenda. This IS powerful reason for hope.
Using chlorinated chemicals as a case study,PANDORA'S POISON reveals how (and why) the current system of environmental protection has failed so miserably. To replace this failed system, Thornton describes a fundamentally new approach.
Thornton is a scientist, a molecular biologist, and the bulk of his book describes in detail the extensive damage that chlorinated chemicals have already done to humans and wildlife. Thornton shows that in just 60 years, the petrochemical industry has contaminated every living thing on earth with novel toxicants, some of which disrupt life's fundamental processes at levels measured in parts per trillion (a proportion equivalent to one drop in a train of tank cars 10 miles long). Introduction of organochlorine chemicals by Dow, Monsanto, DuPont and others was an unprecedented act of hubris combined with a studied ignorance as to consequences. And of course it was all perfectly legal, licensed and overseen by the world's most vigilant regulatory agencies. How could this happen? Thornton tells us how.
The chemical industry now produces an astonishing 40 million tons of elemental chlorine each year, which it then combines into 11,000 different chlorinated chemical products, plus thousands of other unintended chlorinated byproducts, virtually all of which are toxic and all of which eventually make their way into the environment, where, for the most part, nature has no efficient means for decomposing them. Most of these toxicants interfere with the fundamental processes of living things. As a result, "Every species on earth -- including humans -- is now exposed to organochlorines that can reduce sperm counts, disrupt female reproductive cycles, cause endometriosis, induce spontaneous abortion, alter sexual behavior, cause birth defects, impair the development and function of the brain, reduce cognitive ability, interfere with the controlled development and growth of body tissues, cause cancer, and compromise immunity. If we stopped all further pollution today, these compounds would remain in the environment, the food web, our tissues and those of future generations for centuries," says Thornton, summarizing the findings of more than a thousand scientific studies.(pg. 6)
Thornton makes it clear that the decision to add chlorine to industrial organic chemicals was one of the most profound errors that humans have ever made. He argues cogently that most chlorinated chemicals should be phased out over the next several decades, and we should adopt a new system of environmental protection that would prevent such errors in the future.
Thornton is an excellent writer, so his book is easy to read, but the book is also an intellectual tour de force, synthesizing scientific information from toxicology, epidemiology, ecology, molecular biology, and environmental and industrial chemistry. But Thornton does not stop there; in the final chapters he delves into history, ethics, and the philosophy of science to describe and explain the system of environmental protection that allowed the global organochlorine disaster to unfold. He labels the current, failed system the "risk paradigm" and he proposes a fundamentally new system for environmental protection, which he calls the "ecological paradigm."
As Thornton says, "A paradigm is a total way of seeing the world, a lens that determines how we collect and interpret data, draw conclusions from them, and determine what kind of response, if any, is appropriate."(pg. 7)
The "risk paradigm" tells regulators which problems are important, and how to handle them. Unfortunately, it is an entirely inadequate tool for managing chlorinated chemicals and other persistent or bioaccumulative pollutants like mercury, lead, asbestos, and biologically active radioactive elements such as plutonium.
The risk paradigm tries to manage pollution one chemical at a time by allowing chemical discharges so long as they don't exceed a numerical standard of "acceptable" contamination. This approach assumes that ecosystems have an "assimilative capacity," a certain ability to absorb and decompose chemicals without harm, and it assumes that humans can learn what that assimilative capacity is. The risk paradigm also assumes that organisms, such as humans or birds, can accommodate some degree of chemical exposure with no or negligible adverse effects, so long as exposure remains below the "threshold" at which toxic effects become significant.
The "risk paradigm" aims to set "acceptable exposures," chemical by chemical. The "risk paradigm" uses quantitative risk assessment to establish "acceptable" exposures and regulators then set discharge limits, chemical by chemical, intending to make sure that "acceptable" exposure limits are never exceeded. Industry then applies end-of-pipe control devices (filters, scrubbers, etc.) to capture pollutants and move them to a different place. That is how the current system of environmental protection was designed, and that is how it operates today. Obviously, it places great faith in science to discover how nature works and to predict and understand harm in individual organisms and in complex ecosystems -- a faith that is misplaced because science is simply not up to the task.
The "ecological paradigm" is entirely different. As Thornton says, "First and foremost the Ecological Paradigm recognizes the limits of science: toxicology, epidemiology and ecology provide important clues about nature but can never completely predict or diagnose the impacts of individual chemicals on natural systems."(pg. 10) The proper response to this inevitable scientific uncertainty is to avoid practices that have the potential to cause severe damage, even in cases in which we do not have scientific proof of harm. This is the precautionary principle, familiar to RACHEL'S readers. (See REHW #586.) However, Thornton points out, the precautionary principle does not tell us what kind of action to take. So we need to supplement the precautionary principle with three additional principles: zero discharge, clean production, and reverse onus. Together, these ideas constitute a new "ecological paradigm" for protecting the environment.
Zero discharge means we must eliminate rather than allow the release of substances that persist or bioaccumulate (because they remain in the environment, available to cause trouble). Their persistence tells us that nature does not have means for handling them.
Clean production emphasizes the redesign of products and processes so they don't use or create toxic chemicals -- avoiding trouble before it occurs. The point of clean production is to seek out, and adopt, the least harmful alternatives.
Reverse onus is a new way of evaluating chemicals. Using the principle of reverse onus, the burden of proof, which now rests with society to prove that a chemical will cause harm, is shifted to those who want to produce or use a novel chemical. Such people must demonstrate in advance that their actions are not likely to pose a significant hazard. Chemicals currently in use that cannot meet this criterion will be phased out in favor of less damaging alternatives.
In the "risk paradigm," a lack of data about a chemical is taken as evidence of safety, so untested chemicals are allowed to be used without restriction. The result is the current permissive, laissez faire system in which anything goes until someone can prove to a scientific certainty that significant damage has occurred.
In contrast, the "ecological paradigm" amounts to "a program of continued reductions in the production and use of all synthetic [human-created] substances, with priority given to chemical classes that are known to persist, or bioaccumulate, or cause severe or fundamental disruptions of biological processes."(pg. 11) As Thornton says, "By reversing the onus in environmental regulation, the Ecological Paradigm simply applies the standard that society now uses for pharmaceuticals -- demonstrate safety and necessity before a drug is licensed for introduction into patients' bodies -- to chemicals that will enter our bodies through the environment. Reversing the burden of proof would also set straight the twisted ethics of the current system, in which we mistakenly grant chemicals the presumption of innocence--a right that was created for people--while humans and other species are subject to a large-scale, multigenerational experiment of exposure to untested and potentially toxic chemicals."(pg. 11)
Four Reasons Why the Risk Paradigm Has Failed
Reason#1: The risk paradigm only comes into play late in the process of creating pollution. Under the risk paradigm, chemicals are produced and used without any restrictions. However, just before the chemicals are about to be discharged into the environment, they are captured, treated and "disposed of" in a landfill, incinerator or other device.
As Thornton points out, this end-of-pipe approach fails for four reasons:
a) When the product itself contains poisons, pollution control devices are useless. He gives the examples of pesticides sprayed on a field, paint stripper sold to a handyman, and PVC [polyvinyl chloride] pipe installed in a building that may one day burn down, creating significant amounts of dioxin. In none of these examples will end-of-pipe pollution control devices help.
b) Pollution control devices -- filters and scrubbers -- merely shift contaminants from one place to another -- from the water to the land, or from the land to the air (then back to the land somewhere else). Eventually, captured pollutants always make their way into the environment.
c) Control technologies deteriorate and break down just as all mechanical systems must. Therefore, they don't always work as well as they were designed to work and they release contaminants increasingly as time passes.
d) Pollution control devices are only designed to capture a certain proportion of the pollutants being created; beyond that, control becomes prohibitively expensive, so a certain small proportion of pollution always escapes. As total production grows, the amount that escapes must grow too.
Reason #2: The concepts of assimilative capacity and acceptable discharge -- the centerpieces of the risk paradigm -- don't work for chemicals that persist or bioaccumulate. Chemicals that do not break down rapidly in nature will build up in living things, contaminating food webs. Natural systems have no "assimilative capacity" for such chemicals and there can be no "acceptable" discharges of such chemicals.
Reason #3: Risk assessment, another central tool of the risk paradigm, doesn't work for systems as complicated as living organisms in ecosystems because (a) most of the crucial information about individual chemicals is missing; (b) our measuring techniques are crude, so we can never be sure that a contaminant level we believe is "harmless" is actually harmless; (c) we are largely ignorant about how organisms function in ecosystems so we cannot predict what will happen when we introduce toxicants into such systems, especially when we introduce multiple toxicants simultaneously, which is almost always the case in the real world; (d) finally, there are genuine surprises -- risk assessors may look for certain suspected effects, find none, and declare a chemical harmless but the chemical may turn out to cause an effect they did not investigate, or an effect they never dreamed of.
Reason #4: Risk assessment was designed to deal with well-defined, local, short-term hazards. But preventing major local damage does not prevent the slow accumulation of global damage, which is the cumulative result of millions of technological decisions. "The local focus of the risk-based system is intrinsically at odds with the problem of global accumulation."(pg. 342) The problem of global accumulation is what we're dealing with in the case of chlorinated chemicals (like DDT), lead, mercury, and plutonium.
Finally, Thornton points out that, "Once global injury occurs, the current system's methods for dealing with damage also break down. The scope of this kind of damage -- large scale impairment of the health of human and wildlife populations, contamination of the entire food web -- is so vast that it can never be cleaned up or repaired. The inability to trace causality to individual actors means that victims cannot be compensated or individual perpetrators held legally responsible. Most important, this system, which requires a demonstration of a causal link before action can be taken to eliminate the cause of a problem, cannot even stop the damage it is doing when it finally becomes obvious; the limits of epidemiology and the lack of local, determinate causality mean that this requirement will never be satisfied. Current institutions become paralyzed by their own unrealistic standards of proof."
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