"Recently I attended a public meeting as part of the process of revising numeric criteria for 41 carcinogens and other toxicants that bioaccumulate in fish consumed by humans.
"The [state environmental agency] and the EPA [U.S. Environmental Protection Agency] would be satisfied if we could derive the concentration in water of each contaminant that would result in a risk level not greater than one-in-a-million to humans consuming fish, and then sanctify that number in administrative rule.
"It occurred to me that we are missing the point. We are in essence granting rights to chemicals, and chemical dischargers, and denying them to people. The human population is not granted, for example, a guarantee that there will not be more than an additional one in 10,000 cancers in the population due to exposure to all xenobiotics [toxic chemicals made by humans]. But chemical dischargers are given a guarantee for each chemical of a defined allowable risk level they can impose on the human population.
"We seem to have it backwards. Instead of defining a societally acceptable risk to humans from ingesting contaminants, and then apportioning allowable risk to each contaminant and discharger, we grant each chemical a risk level, and do not even make the effort of calculating the cumulative risk of all chemicals to humans. If the latter is impossible, it is an argument for zero discharge industries.
"Very few at the meeting were even aware that we were not talking one-in-a-million risk level in any case, but 41-in-a-million, considering all 41 contaminants in question.
"As well, industry argued for separating estuarine from marine criteria, which would grant each chemical a two-in-a-million risk level. Why not get really ridiculous and do it by fish species --one-in-a-million risk level to humans from consuming each of the following: cod, flounder, bass... [Furthermore,] the allowable contaminant level we grant each chemical is not 'global.' As I understand it, the EPA would allow an additional risk level for these chemicals from meat consumption, for example.
"Other obvious flaws in our risk assessment are that: we in [our state] and in many other states do not even regulate most of the 126 EPA priority pollutants, let alone the 70,000 chemicals in use by industry;
"It is probable that in some cases we are using insensitive endpoints, for example widespread immune system damage may occur at lower contaminant concentrations than those which produce significant numbers of cancers;
"We ignore synergism [increased toxicity caused by multiplier effects when two or more chemicals interact];
"We aren't necessarily taking into account sensitive human sub-populations (immune depressed, or fetuses).
"What bothers me is the mismatch between the two ends of the risk spectrum. At one end we have the guaranteed risk level granted to chemicals of between one-in-100,000 and one-in-10-million; at the other end we seem to have real increases in human health deterioration, breast and testicular cancer, ADHD [attention deficit hyperactivity disorder], and reduced sperm production, of tens of percents. How do we get from one-in-a-million to tens of percents, and which end of the spectrum should we offer a guaranteed risk level?...
"Another thought: industry, in criticizing our methodology for developing new and possibly more stringent criteria, piled one difficult-to-address concern after another on us. Of course if industry were footing the bill for the studies necessary to address these concerns, perhaps they wouldn't have been as vocal. Reverse onus..."
This state official --who obviously might lose his/her job if we revealed his/her name (which, if you think about it, speaks sad volumes about free speech in America) --was commenting on the ethical dilemma of every risk assessor, which is this: assessing risks is a natural and inevitable step for humans to take (we all do a risk assessment before we dash across the street hoping to avoid getting hit by a car). But risk assessment is now embedded in our environmental laws at the federal and state levels in a way that guarantees that the "rights" of industrial poisoners will be protected by the apparatus of the state while citizens will be first disempowered and then physically harmed by the risk assessors' work. Risk assessors are now in the position of the conductors and engineers who kept the trains running on time to the death camps in Nazi Germany to minimize discomfort to their passengers --they are just doing a job, honorably and to the best of their ability, but the final result of every professional risk assessor's work is the destruction of the natural environment, one decision at a time, and the relentless spread of sickness throughout the human and wildlife populations.
The only way to restore an ethical basis to risk assessment is to embed it in a very different framework for decision-making. Right now risk assessment is used to answer the following sort of question: "How much of these 41 carcinogens can we give industry the 'right' to dump into public waters without killing an unacceptable number of citizens?" Anyone who helps the state answer such an immoral question is essentially keeping the death camp trains running on time. An ethical decision-making process would ask a very different question: How can society's resources be employed to minimize the use of chemicals known or suspected of causing harm to humans and the environment? Within a decision-making framework set up to answer THAT public policy question, risk assessors could honorably use their skills, talents, and knowledge to help society examine various alternatives. Until then, risk assessment will continue to be a raw political tool of the industrial powers-that-be, a means for 'managing' (manipulating) the anger, fear, and frustration of a citizenry that knows it is being poisoned.
The raw political nature of formal risk assessment is being demonstrated now in California, where Governor Pete Wilson's administration has ordered state risk assessors to destroy research data and internal records that fail to reflect the state's final policy decisions on pesticides, toxic wastes, and industrial-plant emissions. A memo issued by the California Environmental Protection Agency's Office of Environmental Health Hazard Assessment asks employees to cull files to ensure that they contain only materials that reflect management findings.
"Please dispose of all documents... [electronic-mail] messages and other communications prepared during the course of policy formulation which contain other policy proposals not adopted or reflected in the final decision," Charles Shulock, the office's chief deputy director, wrote on April 19, 1996. The memo was obtained by the WALL STREET JOURNAL.[1]
Mr. Shulock's memo argues that the new "records retention policy" will protect sensitive "pre-decisional" deliberations and will thus promote "robust internal discussions." But the state's scientific staff sees it differently: "It's ridiculous and isn't sincere. If they are concerned about free flow [of information], they would not conceive of shredding very important scientific evaluations," says Kristen Haynie, a spokesperson for the California Association of Professional Scientists, a labor union.
One of California's nationally-known pesticide risk assessors, Robert Howd,[2] said, "The state has hired us and pays us as experts to exercise scientific judgment. Controlling the right of scientists to decide what will be useful later would attack our professionalism, our honor and the scientific process itself."
What Mr. Howd seems not to recognize is that the formal risk assessment process, as it is typically practiced for decision-making in the U.S. today, is not about honor or professionalism or science. Baldly put, it is about making political decisions, the aim of which MUST BE to accommodate the industrial polluters who provide the mountains of cash necessary for politicians to gain re-election and retain their power. If one-in-a-million, or 41-in-a-million, or several percent of, citizens are hurt in the process, so be it. (Until we get full public financing of elections --to get the corrupting power of private money out of our elections --this political dynamic will continue to dominate decision-making, and risk assessment will only be able to be conducted within this framework.)
Case in point: Robert Holtzer, a medical doctor and biochemist, says he was told to ignore evidence that pesticides are causing cancer and asthma among residents of Lompoc, California. Dr. Holtzer says preliminary research by his agency suggested a higher-than-normal incidence of lung and bronchial cancers, and an increase in respiratory illnesses, among residents of Lompoc Valley. He says further study is needed. "Despite the fact that this looks like something, I was told to ignore it --don't study it, don't talk about it," says Holtzer, who retired recently from the California EPA's Office of Environmental Health Hazard Assessment.[3]
Dr. Holtzer says, and his former supervisor confirms, that his office was formally ordered to stop studying diseases in Lompoc. For years, residents of Lompoc have been complaining that pesticides sprayed on nearby fields of lettuce, broccoli and flowers have been making them sick with flu-like symptoms.
In June Dr. Holtzer's former supervisor, David Siegel, wrote a draft report on the Lompoc situation in which he concluded that the data "did not provide findings of increased illness in the Lompoc area." Dr. Holtzer and two of his colleagues who collected the data in Lompoc --epidemiologist Richard Ames and toxicologist Joy Ann Wisniewski --refused to sign their names to Mr. Siegel's draft report. "We asked that our names not be associated with the report," Dr. Holtzer said. Drs. Ames and Wisniewski wouldn't comment for the record, thus silently speaking volumes about the limits of free speech in late 20th century America.
The manipulation of risk assessments in California for political purposes is not unique or even unusual. Risk assessment, when it is embedded within a decision-making process specifically aimed at determining how much damage is 'acceptable' and specifically NOT aimed at finding least-harmful solutions, is by its very nature a clandestine political manipulation of the citizenry. What's unusual in California is that the unethical political manipulation is so obvious and so well documented that even the WALL STREET JOURNAL finds it noteworthy.
--Peter Montague
HEADLINES:
SOCIAL HEALTH
Julian Simon, a professor of business at University of Maryland, is the leading savant of the good news industry; his 694-page book, THE STATE OF HUMANITY, claims to show that everything is getting better all the time, worldwide, and he predicts that everything will continue to get better "indefinitely." (See REHW #485 and #503.) Simon accomplishes this by ignoring most of the world's serious environmental problems because, he says, they are all surrounded by "major scientific controversy."[1] (A similar claim can be made about any problem you want to name, because scientists can always be found who --for a fee --will create a controversy. For example, today it is possible to enjoy a lucrative career claiming that cigarettes may not cause lung cancer, thus creating the appearance of controversy where none exists.) Simon says acid rain, global warming, depletion of the ozone layer, and loss of species are all so controversial that they must be ignored because we just don't know who's right. By this means, Simon manages to conclude that all trends are positive throughout the world.
John Tierney, a "good news" writer for the NEW YORK TIMES who never allows his conclusions to be constrained by mere facts, promotes Julian Simon's views and simply dismisses anyone who suggests that perhaps not all trends are positive. ("We think the world is getting worse because our bodies are deteriorating," says Tierney --as if individual aging explained declining fish populations in the world's oceans, tattered safety nets for workers throughout the industrialized world, or rising teenage suicides worldwide.) Tierney ridicules anyone who is concerned about present trends. He says, for example, "As the rest of the world becomes as rich as America, people everywhere will have the luxury of fretting about the problems that consume us. As more of their babies survive, they'll focus on endangered species of beetles."[2]
A new book by Paul and Anne Ehrlich analyzes the good news industry and shows that it is undermining public confidence in science and reason.[3] We will review it at a later time, but our readers should know it exists now because the good news industry is hard at work deflecting attention away from environmental and social problems by claiming that such problems have been solved, or never existed in the first place. The Ehrlichs have provided a careful analysis of the good news industry (which they call "brownlash journalism") and have provided mainstream scientific critiques of its optimistic conclusions.
In RACHEL'S #516, we examined ways of measuring progress. The standard way of measuring it, called Gross Domestic Product or GDP, measures the total amount of money that changes hands during a year's time. GDP is constantly increasing, and most journalists and politicians treat GDP as a good measure of human welfare. Since GDP is constantly increasing, all of us must be better off each year (at least on average), or so the argument goes.
However, as we saw in #516 there are several good reasons for believing that GDP is NOT a sound measure of well being. An alternative measure, called the Genuine Progress Indicator, or GPI, modifies GDP by adding in money transactions that GDP treats as zero (the value of peoples' voluntary work for neighborhood associations, churches and other charities, for example).[4] GPI modifies GDP further by SUBTRACTING costs of crime, social dissolution (divorce, for example) and ecological damage, which GDP treats either as zero or as positive values even though they clearly have a negative impact on human welfare.
GPI is not a perfect measure of human well being, but the values that it uses to modify GDP are more reasonable than the zero values that GDP uses; furthermore, treating the costs of crime and social breakdown as negative, instead of positive, is certainly reasonable. Figure 1 shows that per capita GDP has risen steadily since 1950. However, the figure also shows that GPI has steadily declined since about 1970. This figure reveals that there is something fundamentally wrong with the analysis provided by the good news industry. Julian Simon, John Tierney and their ilk pretend that all trends are upward, but GPI shows that this is not so. When reasonable measures of progress are taken, it becomes apparent why many people believe things are getting worse. By many measures, things ARE getting worse.
In addition to GPI, there is another national measure of well being. It is called the Index of Social Health, published each year by researchers at Fordham University's Graduate Center in Tarrytown, New York. For the past 11 years, Marc Miringoff and his colleagues at Fordham have been gathering data on 16 measures of well being. The data go back to 1970 and are current through 1993.
The Fordham index accounts for well being during different stages of life. For children, it reports infant mortality, child abuse, and poverty. For youth, it reports teenage suicides, drug use, and the high-school dropout rate. For adults, it reports unemployment, average weekly earnings, and health insurance coverage among those under age 65. For those 65 and over, it reports poverty, and out-of-pocket health-care costs. For people of all ages, it reports homicides; alcohol-related highway deaths; food stamp coverage; access to affordable housing; and the gap between rich and poor.[5]
These measures are not taken against some absolute standard, such as zero poverty or 100% health insurance coverage. They are taken against the best that the U.S. has achieved in each category since 1970.[6,pg.464] Taking the best that the U.S. has achieved in each category, a Model Year is created. Each year's performance is then expressed as a proportion of the Model Year. Finally, all 16 measures are combined into a single numerical index.
Figure 2 shows total GDP steadily rising and the Fordham Index of Social Health steadily declining. Since 1970, America's social health (represented by the 16 measures) has declined from 73.8 out of a possible 100 in 1970 to 40.6 in 1993, a fall of more than 45%. During this time, 11 measures declined and 5 rose. The gains were seen in infant mortality; drug abuse; high-school dropouts; poverty among those over 65; and food-stamp coverage. The social indicators that worsened over the same period were children in poverty; child abuse; teen suicide; unemployment; average weekly wages; health insurance coverage; out-of-pocket health costs for those over 65; homicide; alcohol-related highway deaths; housing; and the gap between rich and poor.
In 1993, the most recent year for which data are available, the Fordham Index declined 2 points from 1992, down to 40.6 out of a possible 100. In 1993, six of the indicators --children in poverty; child abuse; health insurance coverage; average weekly earnings; out-of-pocket health costs for those over 65; and the gap between rich and poor --reached their worst recorded levels.
We believe it is very important to begin to measure progress and social health at the state and local levels.[7] If we use false measures, like GDP, or no measures at all, we can be duped and misled by the good news industry, which makes its living selling optimistic pap. If things are not going well, we need to know it so we can make efforts to improve. Whether we are discussing environment, economy, or the social fabric that holds communities together, we need to measure what's good and what's bad so that we can tell whether public policies are doing what we all need them to do. Measuring progress and social health --particularly at the local level --will allow us to think constructively and spend our money wisely.
[In future, we would like to report on municipal, county, regional or state efforts to measure well being or progress. If readers know of such work going on now, we would appreciate it if they would send us the name and phone number of someone involved, so we could call to learn more. Phone us toll-free: 1-888-2RACHEL.]
--Peter Montague (National Writers Union, UAW Local 1981/AFL-CIO)
FIGURE 2
FORDHAM INDEX OF SOCIAL HEALTH
AND GDP, 1970-1993
Index of Total Gross Social Health Domestic Product (defined in text) (in billions of 1987 $)
100 -- + 5000 80 -- + Total Gross 4000 . Domestic . - -- * + Product 60 -- * 3000 40 -- 2000
Fordham Indicator of Social Health . 20 -- 1000
. 1970 1975 1980 1985 1990 1995 . . Year . ......................................................... Figure 2. Fordham Index of Social Health vs. Total Gross Domestic Product, 1970-1993. Units of GDP are billions of 1987 dollars. The plus signs (+) represent GDP, the asterisks (*) represent the index of social health. Basically this chart shows that, by 16 measures combined, the "social health" of Americans has declined about 45% during the past 20 years. Adapted from Marc L. Miringoff, 1995 INDEX OF SOCIAL HEALTH; MONITORING THE SOCIAL WELL BEING OF THE NATION (Tarrytown, N.Y.: Institute for Innovation in Social Policy, Fordham Graduate Center, 1995). Rounding errors are inevitable when a graphic is displayed using text characters, as we have done here, because it is impossible to place data points precisely.
Descriptor terms: good news industry; julian simon; john tierney; paul ehrlich; anne ehrlich; quality of life indicators; measuring well being; measuring welfare; genuine progress indicator; gpi; gross national product; gnp; gross domestic product; gdp; national accounts; growth; index of social health; fordham university; marc miringoff; poverty; health care; infant mortality; suicide; homicide; food stamps; housing;
NOTICE Environmental Research Foundation provides this electronic version of RACHEL'S ENVIRONMENT & HEALTH WEEKLY free of charge even though it costs our organization considerable time and money to produce it. We would like to continue to provide this service free. You could help by making a tax-deductible contribution (anything you can afford, whether $5.00 or $500.00). Please send your contribution to: Environmental Research Foundation, P.O. Box 5036, Annapolis, MD 21403-7036. --Peter Montague, Editor . .
