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MODERN ENVIRONMENTAL PROTECTION--PT. 4
A recent report from the British Royal Society confirms that some common industrial chemicals, released into the environment, can interfere with hormones in living things with devastating effect.[1] Such chemicals are "cause for grave concern," the report says. The Royal Society is the United Kingdom's national academy of sciences, founded in 1660.
In humans and other animals, hormones act as chemical messengers that control much of life. The system of control by hormones is known as the "endocrine system." A recent report from U.S. Environmental Protection Agency (EPA)[2] described the endocrine system this way: "An endocrine system is found in nearly all animals, including mammals, non-mammalian vertebrates (e.g., fish, amphibians, reptiles, and birds), and invertebrates (e.g., snails, lobsters, insects, and other species). The endocrine system consists of glands and the hormones they produce that guide the development, growth, reproduction, and behavior of human beings and animals.... Disruption of this complex system can occur in various ways. For example, some chemicals may mimic a natural hormone, 'fooling' the body into over-responding to the stimulus or responding at inappropriate times. Other chemicals may block the effects of a hormone in parts of the body normally sensitive to it."[2]
Substances that interfere with the endocrine system are called "endocrine disrupting chemicals" or EDCs. The Royal Society's report says that we should take EDCs seriously because there is irrefutable evidence that some EDCs have had devastating effects on wildlife, and the endocrine system of humans is similar to that of wildlife. The report gives two examples of EDCs harming wildlife.
1. Tributyl tin (TBT) is a highly toxic form of the familiar metal, tin. TBT was introduced in the mid-1960s in marine anti-fouling paints, to prevent growth of crustaceans (e.g., barnacles) on the bottoms of ships. By 1970, biologists studying the English coast reported female shell fish (dog whelks) growing male sex organs. Soon after, biologists studying the Connecticut coast found female snails growing penises. By 1981, this condition -- known as imposex -- was traced to pollution from boats and ships. Laboratory experiments confirmed that TBT could indeed cause female molluscs to develop male sex organs.
The imposex effects of tributyl tin have now been reported worldwide -- in the UK, New Zealand, Japan, and Alaska. Over 100 species of molluscs have been adversely affected by tributyl tin and in some cases imposex has led to population declines and even extinction of species. The Royal Society draws important lessons from the TBT story:
"The example of the 'TBT story' shows that the effects of TBT were completely unexpected and unpredicted, despite legislation governing new chemicals; nobody foresaw that TBT would cause endocrine disruption in molluscs." The Society says, "...[T]he effects were first discovered by accident by field biologists. This suggests that, until our understanding of how, and what, chemicals cause endocrine disruption improves very considerably, it is likely that other unexpected cases of endocrine disruption in wildlife will become apparent. This example also highlights the difficulty of predicting what effects a chemical will have in the wider environment where it may mix with other chemicals, get degraded, or come into contact with a variety of species of animals and plants," the Royal Society says.
2. The Royal Society then recounts the discovery that some fish in all UK rivers and streams are now intersex -- having characteristics of both males and females. The story began nearly 20 ye ars ago with the chance discovery that 5% of the roach (a species of fish) living in two sewage lagoons were "grossly intersex." A nationwide survey revealed that all sewage effluents had the ability to feminize fish.
Eventually, scientists learned that the problem originated with individual humans discharging natural estrogens and the synthetic estrogens found in contraceptive pills directly into sewage. The Royal Society notes that estrogens were present in sewage effluent at "extremely low concentrations (parts per trillion)" -- but these extremely low levels were sufficient to feminize male fish. The Royal Society goes on: "Studies on wild populations of freshwater fish have shown that intersex fish are present in most rivers. In some of the poorer quality rivers, which receive large inputs of effluents from STWs [sewage treatment works], all of the male fish were intersex to varying degrees. Interestingly, the rivers containing the most severely affected fish also received significant inputs of industrial effluent, and hence it has not been possible to completely exclude a contribution from industrial chemicals in at least some cases of intersexuality in fish.... It is likely that many chemicals in the environment, possibly interacting with one another, cause this condition in fish," the Royal Society says.
The Royal Society then discusses regulations to control EDCs: "To date, essentially all research on EDCs has been driven by effects (or purported effects) many of which have caused public concern and made sensationalist stories in the media. Thus, for example, the possible decrease in [human] sperm counts was very influential in highlighting the human issues, while intersex fish helped to highlight the wildlife aspects of the EDC issue. This is an extremely slow (and costly) way of going about things; when an effect is observed, research is then carried out to determine the cause. Because our understanding of the environment is very incomplete, there will always be a role for approaching many issues in this way. However, it would be more logical to start with a chemical, and make an assessment of what effects, if any, it will induce. This is the aim of toxicity testing," the Royal Society says.
However, the Society identifies problems with the chemical-by-chemical approach: "The problem with starting with the chemical is that there are over 80,000 man-made (let alone natural) chemicals in everyday use. In turn, these will degrade in the environment to even more chemicals. Our knowledge of degradation processes (in the environment, but also within humans and wildlife) is often very poor...."
Then, in a key phrase, the Society says, "In order to develop policy and legislation to protect humans and the environment from EDCs it is first necessary to determine the risk of harm to human health and the environment." The Royal Society then suggests what is needed to complete risk assessments:
(a) Identify chemicals that have endocrine-disrupting properties. Because current tests cannot reliably identify endocrine-disrupting chemicals, new tests must be developed.
(b) With new tests in hand, we must then test each individual chemical AND "interaction between chemicals that do not have endocrine disruptive effects individually, but might in combination." Testing combinations of chemicals is essential, the Society says, because, "In reality, humans are exposed not to a single endocrine disrupter but to a 'cocktail' of such chemicals, and the possibility that such chemicals have additive or reinforcing effects (e.g. combination of an oestrogenic with an anti-androgenic compound) has to be considered seriously."
(c) Next we must examine the length of time these chemicals are in the environment, the Society says.
(d) Next we must analyze the breakdown byproducts of these chemicals, the Society says.
(e) Next we must determine the levels of exposure of humans and wildlife to these chemicals, the Society says;
(f) And finally we must determine the levels at which these chemicals are likely to cause adverse effects, the Society says.
So there you have it. A perfectly rational solution to the problem of EDCs, based on the very best science. Who could argue against such a program?
But wait. While this testing is going on, all the same chemicals will be spewed into the environment because the current philosophy of "environmental protection" says chemicals can't be controlled before risk assessments have been completed. Under this assumption, just how long will it be before we can protect ourselves and wildlife from EDCs?
To estimate the time involved, let's examine what it would take to test combinations of chemicals to see if, together, they cause endocrine disruption. There are documented instances of chemicals behaving in precisely this fashion [REHW #384 ], so the Royal Society has identified an important goal. Suppose we wanted to test just 10% of commercial chemicals, or 8000 chemicals, in combinations of three. How many combination of three chemicals can you make out of 8000 chemicals? The answer is 85 billion. Let's assume we could test one million different combinations each year -- surely a preposterous overestimate of human scientific capacity. It would then take 85,000 years to complete the tests. In other words, the Royal Society's rational program based on the very best science will NEVER protect wildlife, humans or the environment from damage.
It looks to us as if the U.S. EPA's Endocrine Disruptor Screening Program (EDSP) is cut from similar cloth: developing new tests to examine 15,000 chemicals, to discern EDCs from non-EDCs, then requiring risk assessments on each of the individual EDCs.[2] Even though the EPA program seems ambitious, it leaves out far more than it includes, e.g., EPA says there are 50 important hormones in humans, but the EDSP is only testing three of the 50.[2] The EDSP is ignoring byproducts and breakdown products of the 15,000 chemicals. Furthermore, the EDSP is ignoring combinations of chemicals. This EPA program will employ an army of scientists for a decade -- and probably far longer. It will generate "an immense amount of data" but "the difficulty will be in interpreting these data," the Royal Society points out. The chemical manufacturers will have one interpretation of the data and public health specialists will have a different interpretation. Ultimately, they will resolve their differences in court. Who will have the advantage in this contest? If EPA ever successfully bans more than 2 or 3 chemicals in the next 30 years based on this program, we will be very surprised.
There is a glimmer of hope in the Royal Society's report. After reviewing conflicting evidence linking EDCs to testicular cancer, abnormal penises, breast cancer and other human diseases, the Society says, "Despite the uncertainty, it is prudent to minimise exposure of humans, especially pregnant woman, to EDCs." Precautionary action.
How would precautionary action work? It would begin by shifting the burden of proof onto the purveyors of chemicals. As Joe Thornton has suggested (REHW #704), chemical manufacturers should be given several years in which to make a reasonable demonstration of no hazard for each of their chemicals (including its associated byproducts and breakdown products), to show that each is neither persistent nor bioaccumulative, nor carcinogenic, nor mutagenic, nor disruptive of intracellular signalling (by hormones, neurotransmitters, growth factors, cytokines, and so on), nor toxic at low doses to development, reproduction, immunity, or neurological function. Testing should occur on multiple generations of sensitive species of animals, unless testing on less than whole animals can give equivalently useful and reliable results. These are the sorts of tests required of new medical drugs.
Any chemical not passing these tests would be automatically phased out from commercial use within a decade or so. Displaced workers would be offered funds for retraining.
The Royal Society's report -- though clearly not intending to -- eloquently shows that the current appproach to environmental protection cannot protect anyone or anything except the chemical industry. We must adopt a modern precautionary approach.
MODERN ENVIRONMENTAL PROTECTION--Part 3
Once in a while a really important new idea comes along -- or an old idea gets applied in important new ways. Mary O'Brien's proposal for "alternatives assessment" instead of "risk assessment" falls into this category -- innovative and important. No doubt I'm biased because our organization hired O'Brien so she could find the time to write a book on this subject. The book has just been published by MIT Press.[1] O'Brien's basic idea is astonishingly simple but also delightfully subversive of the status quo. Her idea is that we should all take a CONSUMER REPORTS approach to decision-making. Just as the well-known consumer magazine examines a range of available options before recommending a particular toaster or TV, all decision-makers (public AND private) should examine a full range of options before committing to a new project or new technology. The least-damaging option should be chosen. In other words, we should look before we leap.
O'Brien's approach makes such good sense that you might think all decision-makers would be using it already. But that's not how decisions are made in the industrialized world. Instead of examining a full range of alternatives, decision-makers generally decide what they want to do, then they hire a risk assessor to convince everyone that the damage they are about to do is "acceptable." By the time damage becomes apparent, they're hauling loot to the bank. At that point, stopping them is almost impossible. The cumulative result of this "risk-based decision-making" is a severely degraded and stressed global ecosystem. To put it bluntly, the global ecosystem is being shredded by people who are building roads, filling wetlands, logging forests, damming rivers, vacuuming fish from the oceans, overgrazing grasslands, depleting topsoil, wasting and polluting water, and dumping persistent chlorinated chemicals, toxic metals, greenhouse gases, and nitrogen into the environment on a massive scale. Each of these damaging activities is justified and deemed to be "acceptable" on the basis of a risk assessment.
Sometimes risk assessments are very formal, filling 1000 pages or more with mathematical formulas and technical data. On the other hand, most risk assessments are so informal that you might not even recognize them as risk assessments -- they may consist of a mere sentence or two. Examples: "Silt runoff will be kept within acceptable limits by the use of hay-bale barriers, so our construction project on the edge of the Bay will kill very few fish." Or "Naturally-occurring chemicals in food cause more cancers than this pesticide will cause, so it would be silly and a waste of money to worry about the presence of this pesticide in your cornflakes."
Risk assessment is the most powerful intellectual tool that the poisoners and destroyers of the planet have ever invented. It is their battering ram AND their camouflage. It provides "cover" for just about any damaging activity that anyone might want to undertake. Risk assessment is used to justify exposing workers to toxic chemicals and radiation; to justify clearcutting and other harmful practices in irreplaceable forests; to justify automobile emissions and the resulting killer smogs; to justify allowing silt and topsoil to escape into rivers and streams; to justify cleanup standards for radioactive contamination and for chemical dumps, accidents and spills; to justify dams; to justify suburban growth and encroachment onto farmlands; to justify fishing and hunting quotas; to justify contaminating our food with pesticide residues and other additives; to justify destroying habitat needed by endangered species; to justify "acceptable levels" of industrial toxicants in ourl drinking water; to justify new road construction in roadless areas... and on and on. In a nutshell, for any particular activity, risk assessment asks (a) how much damage will be caused, (b) to what degree will humans and non-humans be "exposed" to the damage, and (c) will the local consequences be "acceptable"? Naturally, what is "acceptable" is a political judgment. If you ask the owner of a chemical factory how much money should be spent to prevent cancer in a worker, you'll get one answer. If you ask the same question of the worker, you'll get a different answer. What is deemed "acceptable" is a matter of raw political power. Thus risk assessment is not a "scientific" exercise -- it is a highly political mixture of prejudices, biases, guesses, estimates, some scientific facts, and many ethical judgments -- all masquerading as "objective" science.
Even the question, "How much damage will be caused?" is a political question. The answer depends upon how hard you are willing to look, what kinds of damage you are willing to consider, and how much scientific ignorance you are willing to acknowledge. The truth is, scientists can never figure out whether pesticides on a child's cornflakes (for example) are "safe" or "insignificant" because (a) there are dozens or hundreds of adverse effects to consider, and -- if history is any guide -- new ones will be discovered tomorrow; (b) the pesticide effects will be added on top of whatever other stresses the child may be experiencing (medical drugs, auto exhaust, paint fumes, second-hand cigarette smoke, divorced parents, chronic ailments, excessive ultraviolet radiation from the sun because of a depleted ozone layer, and so on); (c) children (like all organisms) have differing abilities to cope, and a unique history of exposure to hazards; and (d) all organisms, like all ecosystems, are simply too complex for science to understand sufficiently to allow reliable prediction of effects.
In reality, risk assessments simply omit all these complexities -- which is to say, they ignore the real world and thus are a special brand of science fiction. Scientists (or journalists) who assert that exposures to industrial chemicals are "harmless" or "insignificant" are participating in a fraud because they are pretending to know things that cannot be known. When a risk assessor's work is used to expose people to unnecessary hazards without their consent, it crosses the line and becomes grossly immoral.
Risk assessment always asks the wrong question: it asks how much damage is safe instead of asking how little damage is possible. Furthermore, risk assessment conveniently never asks, "Is the proposed activity needed?" It never asks, "Is the proposed activity ethical?" It never asks, "What will be the cumulative impact of this activity combined with all the other damaging activities to which humans and non-humans are exposed at this location?" And risk assessment never, ever asks, "Are there less damaging ways to accomplish the same purpose?" On the other hand, all these questions are central to an "alternatives assessment." Thus alternatives assessment is wonderfully subversive because it asks fundamental questions about "business as usual." Risk assessment, on the other hand, simply greases the skids for "business as usual."
Starting about 1975, industrialists hoped that risk assessment would become the permanent key to imposing harmful decisions on an unwilling public -- and for a couple of decades it seemed to be working. Corporate risk assessors -- and a phalanx of third-rate journalists transformed into highly-paid "risk communicators" -- like to dress up in white lab coats and hang stethoscopes around their necks, then accuse their critics of being "irrational" devotees of "bad science." Monsanto, Dow Chemical and other major polluters have spent hundreds of millions of dollars promoting the idea that risk assessment is the very definition of "good science." Harvard University houses a polluter-funded "center" for risk assessment, which pumps out an endless stream of shameless propaganda aimed at convincing the American public that we all need to make more decisions based on risk assessment, because risk-based decisions are "unbiased," "impartial," "neutral," "rational," and based on "sound science."[2] Sound familiar? The NEW YORK TIMES maintains at least one staffer who writes almost nothing but risk-based propaganda on behalf of polluting industries.[4] In this, he joins a long list of distinguished corporate toadies like John Stossel, Gregg Easterbrook, Elizabeth Whelan, and Michael Fumento.
U.S. Supreme Court justice Stephen Breyer went the next step in his book, BREAKING THE VICIOUS CIRCLE , subtitled, "Toward Effective Risk Regulation."[3] Judge Breyer suggested that we set up a "small centralized administrative group, charged with a rationalizing mission" within the federal government, with the power to impose their risk-based decisions the public, democracy be damned. Like religious fanatics, this risk assessment crowd wants us to believe that they have found the truth and the way -- the only way. But really all they've found is a new way to justify shredding the biosphere to make money. It's just a one more scam to provide cover for traditional destructive behavior. In her book, Mary O'Brien devotes sections to Why business loves risk assessment, Why government agencies use risk assessment, and Why many scientists live with risk assessment even though they know risk assessment isn't mainly a scientific activity -- it is mainly a political weapon wielded by the powerful to have their way with the rest of us.
O'Brien's book is filled with provocative ideas. For example, our government -- and many others, like the Harvard risk assessors[2] -- recommend "comparative risk assessment" to rank environmental problems from important to unimportant. The rationale is that we don't have enough money to solve all our problems, so we should spend our scarce dollars on the most important. O'Brien challenges that thinking: "It is noteworthy that comparative-risk-assessment processes rank environmental problems. It would be just as logical to rank which behaviors are causing the greatest environmental problems, or who is causing the greatest environmental problems, or which social arrangements allow or encourage people to cause environmental problems. By focusing on environmental problems rather than on problematic behaviors, problematic people, or problematic social arrangements, the comparative-risk-assessment group can pretend that the problems just 'happened' and that no identifiable individuals or businesses caused them." (pg. 121)
O'Brien suggests that, in a democracy, all businesses and government agencies should be required to explore, on paper, and in understandable language, their options for causing the least possible environmental damage. She says, "All potentially environmentally degrading activities, public or private, should be subject to public scrutiny of alternatives. The public deserves to know that those who pollute, extract, consume, emit, incinerate, or abandon are aware of their technological options for minimizing disturbance of the environment."(pg. 122) But of course this won't happen any time soon because, as O'Brien says, "If you wanted to get approval to undertake a particular hazardous activity, would you want people asking big questions about the activity? Would you want people to think that the hazards or the potential risks were unnecessary? Alternatives assessment threatens the status quo. Alternatives assessment can make social change seem both desirable and possible."(pg. 136)
Is risk assessment 100% bad? Not necessarily. In a thorough analysis of a full range of alternatives, risk assessment might play a role. It is risk assessment of only one or a few options that O'Brien wants to eliminate.
Please urge your local library and bookstore to order MAKING BETTER ENVIRONMENTAL DECISIONS from MIT Press.[1] Starting this fall, Mary O'Brien will be available to give a talk, debate a risk assessor, lecture at your local university, or consult with your citizen group or your government, to help discover how "alternatives assessment" can improve decisions in your area of interest. She can be reached by E-mail: mob@darkwing.uoregon.edu. --Peter Montague
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