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THE TOXIC SUBSTANCES CONTROL ACT
Twenty-one years ago, Congress passed the Toxic Substances Control Act (TSCA, pronounced toska). As the name of the law implies, the purpose of TSCA is to control toxic substances. But of course, before you can control toxic substances, you must know which chemicals are toxic. This requires testing. According to U.S. Environmental Protection Agency (EPA), as of October, 1996, there were 75,857 chemical substances in commercial use.[1,pg.20] The question is, how many have been tested for toxicity?
In principle, all of them should have been tested by now. TSCA says, "It is the policy of the United States that... adequate data should be developed with respect to the effect of chemical substances and mixtures on health and the environment and that the development of such data should be the responsibility of those who manufacture and those who process such chemical substances and mixtures." [15 U.S.C. paragraph 2601(b)] [1,pgs.23-24]
Now a new report from the Environmental Defense Fund (EDF) scores the chemical industry's and EPA's progress toward the goals of TSCA.[1] EDF concludes that "the policy is largely defunct."[1,pg.24] EDF says, "[F]or most of the important chemicals in American commerce, the simplest safety facts still cannot be found. This report documents that, today, even the most basic toxicity testing results cannot be found in the public record for nearly 75% of the top-volume chemicals in commercial use."[1,pg.7]
EDF revisited a question that was first asked in 1984 by the National Research Council (NRC) of the National Academy of Sciences. In 1984 the NRC studied a random sample of 100 chemicals chosen to fairly represent the roughly 3000 chemicals produced each year in quantities exceeding one million pounds. The NRC concluded in 1984 that 78% of these chemicals lacked even "minimal toxicity information."[2] Now in 1997, EDF has asked the same question, to see if the chemical industry and EPA have made progress since 1984. EDF reports that, today, 71% of the chemicals examined lack minimal toxicity information.
EDF drew its random sample of 100 chemicals from a list of 486 chemicals that are BOTH high production (greater than one million pounds per year, of which there are 2971 chemicals) and that ALSO have been identified as subjects of regulatory attention under major environmental laws.[3] (EDF excluded food additives, tobacco products, drugs, and pesticides because TSCA excludes these chemicals.) These criteria would bias EDF's sample to include chemicals that have at least been minimally tested since a completely untested chemical is unlikely to have been the focus of regulatory attention. Thus the EDF study very likely overstates the availability of toxicity information about high-volume chemicals.
What constitutes minimal toxicity screening information? EDF used a set of criteria developed by the Organisation for Economic Cooperation and Development (OECD), an international organization made up of the world's 19 wealthiest countries, including the U.S. In 1990, with extensive participation by industry, the OECD defined criteria for minimal toxicity screening information for a chemical. (U.S. EPA, on the other hand, has never defined minimal toxicity screening information.) OECD defined minimal toxicity information to include:
** Acute toxicity
** Repeated dose toxicity
** Genetic toxicity (tested in a test tube)
** Genetic toxicity (tested in laboratory animals)
** Reproductive toxicity
** Developmental toxicity/teratogenicity
The OECD also included two additional categories of information in its list of minimum requirements: environmental fate and pathways through the environment; and ecotoxicology.[4] EDF ignored these environmental criteria and limited its study to human health effects. Thus the EDF study, again, very likely overstates the availability of minimum toxicity information.
It is important to note, as EDF says, that the minimal OECD screening information for human health does not include sufficient information to conduct a comprehensive health risk assessment. The data that EDF used to judge the availability of information is minimal PRELIMINARY SCREENING information aimed at answering the question: is this chemical likely to pose a hazard to human health? Here is the EDF scorecard:
** Carcinogenicity tests are missing for 63% of high-volume chemicals.
** Reproductive toxicity is missing for 53% of high-volume chemicals.
** Neurotoxicity tests are missing for 67% of high-volume chemicals.
** Immune system toxicity tests are not available for 86% of high-volume chemicals.
** Studies for evaluating impacts on children (such as postnatal performance and neurotoxicity) have not been done for more than 90% of high-priority chemicals.
** More than half (58%) of the sampled high-priority chemicals have not been tested for any form of chronic toxicity.
No doubt, smaller-production-quantity chemicals are even less fully tested that the chemicals EDF studied.
Obviously, TSCA has failed. Who is at fault here? The basic problem lies in TSCA itself --another well-intentioned but unsuccessful attempt to 'regulate' corporate behavior. Congress passed TSCA with input from industry and from the environmental community (EDF included), then EPA set TSCA regulations after taking input from the same parties. EDF now acknowledges that TSCA "work[s] poorly in practice" and was "doomed from the start."[1,pg.25]
TSCA has three main sections aimed at gathering toxicity information and protecting public health and the environment:
** Section 4 empowers U.S. Environmental Protection Agency (EPA) to require companies to test chemicals that are currently in use;
** Section 5 requires companies to submit pre-manufacturing notifications (PMNs) to EPA 90 days before a new chemical enters commercial markets;
** Section 6 gives EPA the authority to control any chemical that presents an "unreasonable risk of injury to health or the environment." [15 U.S.C. Section 2605(a)] Control can include anything from a labeling requirement to an outright ban.
Let's look at how each section of the law actually works:
TSCA Section 4 says EPA can issue "test rules" (requirements for toxicity testing) but it puts the agency in a catch-22 position: the agency must have data in order to require data. Before EPA can issue a "test rule (i.e., ask for testing) on a specific chemical, the agency must first show either (1) that the chemical may present an 'unreasonable risk' or (2) both that it is produced in major quantities AND that either 'substantial' exposures are occurring in quantitative terms (either numbers of people being exposed, or pounds of material being released) or that 'significant' exposures are occurring in qualitative terms (a case-by-case evaluation of the impact of exposures). Obviously, 'substantial' exposures cannot be proven if quantitative information on releases of the chemical or exposures to the chemical is lacking. And 'significant' exposures cannot be proven without information on the chemical's toxicity. In addition, before issuing a 'test rule,' EPA must also show that existing data are insufficient and that testing is 'necessary.' In court, chemical corporations trip up EPA on all these points.[1,pgs.26,30-31,note 26] EPA has developed "testing actions" for only 263 chemicals over the last 20 years, a period during which at least 20,000 new chemicals have come into use.
TSCA section 5 requires that EPA receive "premanufacture notification" (PMN) 90 days before a new chemical goes onto the market. EPA then has 45 days in which to challenge the manufacturer to provide more test data. However, the law does not require that any toxicity data accompany the original PMN --data are optional --so EPA usually has no scientific basis on which to demand additional data. More than half of all PMNs are submitted without any toxicity data.
The contents of a PMN are not binding and thus there is no incentive for a manufacturer to insure that its original submission is accurate or reliable. Once EPA has finished its review of a PMN, the manufacturer need not limit uses or production levels to those described in the PMN. Manufacturers are even allowed to revise PMNs while EPA is reviewing them. When learning that EPA was considering controls on a chemical, manufacturers have gone back and revised the exposure estimates for a chemical, to avoid EPA action. They also have revised PMNs to show lower releases than previously estimated and they have added claims that the chemicals will be used in zero-discharge systems.
TSCA section 6 gives EPA sweeping powers to control chemicals. Under TSCA section 6, EPA has the authority to control any chemical that poses an "unreasonable risk of injury to health or the environment." But of course proving an "unreasonable risk" in a court of law is a challenge that the government is usually not up to. Compared to EPA, even a mid-sized corporation has many more lawyers and much more money to spend defending its 'right' to expose the public to toxins. In 20 years, EPA has taken Section 6 actions against only 5 chemicals or classes of chemicals. These include dioxin waste disposal; hexavalent chromium use in cooling towers; ending the manufacture of PCBs (a regulation required in the text of TSCA itself); metal fluids; and lead paint disclosures.
In sum: sections 4, 5, and 6 --the meat and bones of TSCA --simply do not work. The law is a failure.
Within chemical corporations, the absence of toxicity data is taken to be proof of safety. For example, the Chemical Manufacturers Association said in 1996, "Generally speaking, the philosophy of risk-based... management of chemicals... allows for the continued safe use of chemicals.... Through [this] approach, we can ensure that chemicals are used safely." But there are no data to back up such a junk science claim.
Meanwhile, between 1987 and 1992, production of basic chemicals in the U.S. increased 18%, a growth rate of 3.3% each year.
Having shown conclusively that regulation of the chemical industry hasn't worked, what is EDF's solution to this large and growing problem? More regulation. EDF favors expanding the "right to know" provisions of federal law to give citizens more information about the poisons that industry is dumping into communities day after day.
This little report from EDF is first-class work. Unfortunately, the authors of the report seem unable to imagine anything beyond the failed strategies of the last 20 years. They seem to be saying, "What we've specialized in for 20 years hasn't worked. It was doomed from the start. So now we must redouble our efforts to try to get Congress and EPA to give us more of the same." Very mysterious thinking.
--Peter Montague
WHY IS EPA IGNORING MONSANTO?
U.S. Environmental Protection Agency (EPA) on August 15 ordered a grass-roots citizens' group in Missouri to turn over all of its records to the agency within five days or face penalties of $25,000 per day until the records are produced. Steve Taylor, leader of the Times Beach Action Group (TBAG) in Ballwin, Missouri, and a frequent critic of EPA, says he and the group have no intention of complying with EPA's order.
In demanding the information from TBAG, EPA's Michael J. Sanderson cited Section 3007 of the federal Resource Conservation and Recovery Act (RCRA), which empowers EPA to gather information from the files of toxic dumpers and major polluters.[1] This is the first time the law has been turned against citizen activists trying to protect the environment.
By invoking the law, EPA is threatening to destroy the Times Beach Action Group; TBAG is so small that even one day's fine of $25,000 would bankrupt the organization. EPA's threat represents a new twist on the phenomenon known as SLAPP suits.
SLAPP suits are Strategic Lawsuits Against Public Participation.[2] They are an increasingly popular tactic being used by polluters in the U.S. to intimidate and silence citizens who voice concerns about destruction of the natural environment. The parties that bring SLAPP suits rarely win, but they tie up outspoken citizens in expensive and frightening litigation for years, thus deflecting effort and attention away from whatever the citizens had been speaking out about.
In a letter dated August 15 and delivered by Federal Express, EPA's Region VII office in Kansas City, Kansas gave TBAG five days in which to turn over copies of all its records related to toxic dump sites in Missouri and Illinois.[1] TBAG was formed in 1993 to oppose the incineration of contaminated soils excavated from the town of Times Beach, Missouri --a town so contaminated with dioxins and pesticides that federal officials evacuated all the citizens from the town in 1983.
The town of Times Beach was contaminated in 1971 by a waste oil dealer named Russell Bliss. Bliss picked up toxic wastes from Missouri chemical firms, mixed them with oil, and dumped them into the environment. Starting in May and June of 1971, Bliss sprayed toxic waste oil onto roads and horse arenas in eastern Missouri, ostensibly to suppress dust. Some of the oil was contaminated with the phenoxy herbicide 2,4,5-T and the 2,4,5-T was, itself, contaminated with dioxin. Three days after the initial spraying, birds began dying.[3] "There literally were bushel baskets full of those dead wild birds, " said Dr. Patrick E. Phillips, a veterinarian with the Missouri Division of Health.[4] Then horses began to get sick. Of 62 horses affected, 48 died. Dogs, cats, chickens, and rats died as well. Two children were affected, one with a severe kidney disorder, and were hospitalized for a time; they eventually recovered, though one lost half her body weight in the ordeal. The children's illnesses brought federal investigators to the scene from the Centers for Disease Control (CDC) in Atlanta. The CDC analyzed soil samples at the affected stables and found 30 ppm (parts per million) of dioxin; 5000 ppm of 2,4,5-T, and 1350 to 1590 ppm of PCBs.[5] CDC took great pains to identify the source of the 2,4,5-T and the dioxin (they decided it was a hexachlorobenzene germicide plant in Verona, Missouri owned by Syntex Agribusiness, though leased to another firm) but the source of the PCBs was never identified. PCBs were produced from 1929 to 1976 by Monsanto, a St. Louis, Missouri, chemical giant. It is clear that EPA was interested in the source of the PCBs because in 1972 EPA's W.L. Banks was corresponding with W.B. Papageorge at Monsanto Research Labs about PCB samples taken from "the oil storage tank" at Russell Bliss's Waste Oil Disposal Company.[6] EPA even sent some of the Bliss samples to Monsanto. Officials have never identified Monsanto as the source of any of Bliss's PCBs.
CDC and EPA widened their investigation throughout the 1970s. Meanwhile, Bliss continued to dump toxic oil at sites throughout eastern Missouri. By 1975, CDC recommended that people be evacuated from the homes in Imperial, Missouri, a place more contaminated than Times Beach, but EPA ignored CDC's recommendation.[7]
By 1983, EPA had identified at least 100 sites thought to be contaminated by dioxin. Mysteriously, the agency refused to release the names of the sites.[7] According to the NEW YORK TIMES, in 1983 only 21 of the 100 sites had been sampled and the Missouri DNR seemed to be dragging its feet. The TIMES quoted Fred A. Lafser, then director of the Missouri DNR, saying, "The feeling is, why go look for more problems when we do not have the staff to solve what we know about?"[7]
In a 1990 agreement with EPA, Syntex Agribusiness agreed to take sole responsibility for the cleanup of 27 toxic dump sites in eastern Missouri, including Times Beach. In 1992 EPA decided to incinerate 10,000 bags of contaminated soil from those sites. When the plan was announced, citizens became alarmed that the incinerator would be putting dioxin and other toxins into the air, but EPA conducted a risk assessment to show that the operation would be "safe."[8] The Times Beach Action Group (TBAG) formed in 1993 to oppose the incinerator.
As the incinerator project became a reality, TBAG became convinced that EPA and Missouri DNR had identified neither all of Bliss's contaminated sites in eastern Missouri nor the major chemicals at each site. Specifically, EPA and DNR seemed to be systematically ignoring PCBs. TBAG conducted its own investigation of toxic dumps in Missouri and Illinois, gathering thousands of pages of documents from state and federal sources --all of it public information --including transcripts of hearings, court trials and depositions, correspondence, interviews, affidavits, and articles from technical journals. Based on this information, TBAG's director, Steve Taylor has accused federal and state officials of misfeasance, malfeasance, nonfeasance, incompetence, corruption and dishonesty. Furthermore, a talented investigative reporter, C.D. Stelzer, writing for an alternative weekly newspaper, THE RIVERFRONT TIMES, has done some investigating of his own and has corroborated, and extended TBAG's charges. Other environmental groups, including the Gateway Green Alliance, have amplified the accusations against government officials.
In sum, TBAG's information has been a constant embarrassment to EPA and to the Missouri state Department of Natural Resources because their documentary evidence is so compelling. This is the information EPA is demanding to see. Steve Taylor's response is: "EPA should do its own research." He says he has tried to interest EPA in TBAG's information in the past but the agency has never even bothered to answer his letters. Now they are demanding all his files.
During 1996 and 1997, as the Times Beach incinerator project progressed, Taylor and TBAG--
** showed that EPA's own internal documents admitted that the incinerator could not destroy dioxin with the efficiency required by law (99.9999% destruction and removal efficiency). [See REHW #280, #312.]
** showed that "chain of custody" had been broken for samples taken from the incinerator. Chain of custody is a strict, legal paper trail that shows who took what samples when, to assure that samples have not been falsified or tampered with;
** revealed that the laboratory analyzing the samples for the Times Beach incinerator was 50% owned by the incinerator company --a clear conflict of interest;[9] naturally, this makes the broken chain of custody even more suspicious.
** revealed that EPA and the federal Centers for Disease Control (CDC) knew about the contamination throughout eastern Missouri in 1974 but waited nine years before taking any action to protect the public. C.D. Stelzer caught EPA officials in outright lies when they claimed they knew nothing about dioxin contamination in Missouri until "after 1980."[10]
** revealed that the risk assessment for the Times Beach incinerator did not consider PCBs or other priority pollutants that were in the soil to be burned (a clear violation of federal law) and that many EPA sampling records from many of the 27 sites were missing from the agency's files;[11]
** revealed that EPA and Missouri DNR have refused to consider abundant evidence indicating that some of the PCBs in eastern Missouri came from one obvious source: Monsanto.[10] Syntex Agribusiness has, so far, borne the burden of the incomplete cleanup alone.
Now the TIMES BEACH incinerator has done its work and has been dismantled. However, new sites contaminated by Russell Bliss continue to be discovered, and TBAG says still more will be found. Furthermore, against all the evidence, EPA and DNR continue to exclude Monsanto from their investigations of Russell Bliss's illegal dumping. Consider these facts: ** In a sworn deposition April 21, 1977, Russell Bliss himself said he picked up wastes from Monsanto.
** In a memo dated September 26, 1980, James H. Long, an official of Missouri DNR, identified Monsanto as one of the company's known to use Russell Bliss for hauling chemical wastes.
** On October 30, 1980, officials of the Missouri DNR and the Missouri attorney general's office interviewed Scott Rollins, one of Russell Bliss's truck drivers who was at the time serving a term in the state penitentiary. Rollins said he recalled very clearly picking up wastes from Monsanto.
** In an interview January 5, 1981, Judy Piatt --owner of one of the horse farms where animals died from Bliss's oil --said she had followed Bliss's trucks in 1972 and had personally watched them pick up wastes from a Monsanto plant and then illegally dump them by the roadside.
** February 9, 1983, Russell Bliss himself testified before a hearing of the Missouri Hazardous Waste Management Commission that he had a contract with Monsanto to haul away chemical wastes.
** Based on evidence presented at trial, a judge in Cole County, Missouri, November 30, 1984, concluded that Russell Bliss had dumped hazardous wastes, including PCBs, in Dittmer, Missouri and that "the only known source" of one of the chemicals (bromophenyl chlorophenyl ether) was Monsanto.
Monsanto has denied ever having given Bliss any waste containing dioxin or PCBs. So far, officials of U.S. EPA are taking Monsanto at its word and, instead of investigating the chemical giant, are investigating and harassing the citizens who have brought these documented facts to light.
--Peter Montague
THE CAUSES OF LYMPH CANCERS
Non-Hodgkin's lymphoma (NHL) is a group of cancers that arise in the white blood cells. NHL is increasing rapidly in the U.S. and elsewhere in the industrialized world. In the year 1950, 5.9 Americans per 100,000 were diagnosed with non-Hodgkin's lymphoma. In 1985, the incidence (occurrence) rate of this disease had risen to 13.1 per 100,000.[1] By 1991, the incidence rate had reached 15.1 per 100,000 and was still climbing.[2]
Between 1973 and 1991, the incidence of non-Hodgkin's lymphoma increased at the rate of 3.3% per year, making it the third fastest-growing cancer (after prostate cancer, growing at 3.9% per year, and melanoma of the skin, also growing at 3.9% per year).[2] In recent years, AIDS patients have contributed to the increase in NHL, but a steady rise in the incidence of this disease was apparent long before the AIDS epidemic. Together the known "risk factors" for NHL --including immune-suppressing drugs, rare immune-system diseases, and AIDS, explain only a small proportion of NHL cases.
About 50,900 new cases of NHL were diagnosed in the U.S. in 1995 and about 22,700 deaths from NHL were reported that year.[3] NHL is a serious disease; half the people diagnosed with it are dead within five years. The causes of NHL are not understood, but the following factors have been implicated in many studies:
** Phenoxy herbicides, especially 2,4,5-T (the herbicide now banned in the U.S.) and 2,4-D, the most popular chemical killer of dandelions and crabgrass in lawns.[4] More than a dozen studies now indicate that exposure to these herbicides increases the likelihood of getting NHL.
** Viruses. The roles of viruses "appears to be minor," say Paul Scherr and Nancy Mueller, who are experts in the viral causes of cancer. However, the Epstein Barr virus (EBV) seems to be implicated in some way in many cases of non-Hodgkin's lymphoma, although the virus BY ITSELF does not seem to cause the disease.[1,5]
** People with compromised immune systems and/or autoimmune diseases have a substantially increased likelihood of getting NHL. This is a consistent thread running throughout NHL research: the NHL family of cancers tends to strike people whose immune systems are degraded for one reason or another. This was first discovered among people who had had organ transplants. The body's immune system naturally tries to reject foreign organs. To allow a foreign kidney or liver to be accepted, doctors devised medications to suppress the immune system. In some instances, suppressing the immune system gave rise to NHL. Since that time, researchers have documented many different ways in which suppressed or malfunctioning immune systems allow NHL to develop.
In the authoritative reference book, CANCER EPIDEMIOLOGY AND PREVENTION, Paul Scherr and Linda Mueller conclude[1] that there are two clear threads visible in NHL research:
1. People whose immune systems are continually challenged (for example, by medications or by autoimmune diseases such as rheumatoid arthritis, or by other factors) seem to lose control of latent cancer-causing infections that may be caused by viruses such as the Epstein Barr virus.
2. "Another group who appears to be at increased risk are individuals with occupational exposures to chemicals," say Scherr and Mueller. They continue, "There is mounting evidence implicating phenoxy herbicide exposures, although the evidence is still not conclusive."[1]
Scherr and Mueller do not say so, but there is also evidence that the likelihood of NHL is increased by exposure to DDT, the well-known organochlorine pesticide.[6] In addition, recent evidence suggests that another class of pesticides --the organophosphates such as malathion and parathion --can cause NHL.[7] Thus organochlorines, organophosphates, and phenoxy herbicides are now all implicated in the mushrooming problem of NHL.
Most recently, provocative new research indicates that PCBs, too, can cause non-Hodgkin's lymphoma. From 1929 until just recently, PCBs were used in electrical equipment as fire retardants. They were also used in plastics, preservatives, varnishes, waxes, and carbonless carbon paper.
The connection between PCBs and NHL was first suggested in 1996 by the Swedish researcher, Lennart Hardell.[8] Hardell studied a small group (28 individuals) with NHL and compared them to a control group of 17 surgical patients in the same Swedish hospital who did not have cancer. Hardell took tissue samples from both groups and analyzed them for DDT and its breakdown product, DDE; dioxins; hexachlorobenzene (HCB); and PCBs. The tissue concentrations of both groups were the same for DDT, DDE, HCB and dioxins. However, when it came to PCBs, the group with NHL has significantly[9] more PCBs in their tissues than the control group did.
This finding is biologically plausible because PCBs are known to suppress the immune system of animals and humans. Hardell concluded his research report in 1996 saying, "Immunological impairments have been shown after exposure to PCBs. Since immunosuppression is an established risk factor for NHL, our results are of interest in the etiology [causation] of NHL but need to be confirmed in larger studies."
Now a larger study by the National Cancer Institute (NCI) has confirmed Hardell's results.[10] NCI researchers set out to explore whether people with NHL had more than their fair share of DDT in their tissues. They examined blood that had been taken from nearly 26,000 healthy individuals in 1974 --a prospective study known as the Campaign Against Cancer and Stroke [or CLUE I] being conducted at Johns Hopkins University in Baltimore. Within the large group, they identified 74 individuals who had eventually contracted NHL, and they matched them against 147 controls who did not have NHL.
The NCI researchers did not find any connection between DDT and NHL but, quite unexpectedly, they found a 4.5-fold increase in non-Hodgkin's lymphomas among people who had 1050 parts per billion (ppb) of PCBs in the fat globules of their blood, compared to people who had only 250 to 650 ppb PCBs. The study found a clear dose-response relationship between PCBs in the blood and the likelihood of having NHL.
Furthermore, this NCI study provided additional evidence of the role of the Epstein Barr virus in NHL. Individually, PCBs and EBV each increased the likelihood of NHL. However, together, the presence of BOTH Epstein Barr virus AND elevated PCBs in individuals had a synergistic effect, combining to produce a 22-fold increase in the likelihood of NHL.
The solution to this problem has two parts. One part involves the use of pesticides. Organochlorines, organophosphates, and phenoxy herbicides all increase the dangers of NHL. In the case of these chemicals, it is not too late to make sensible, precautionary decisions. In our homes, our public buildings, our schools, and our businesses we could avoid these products like the plague. Alternative ways of dealing with pests are well-known. If pesticides are needed at all, they are needed only in emergencies.
The second part of the problem is PCBs. Some 3.4 billion pounds of PCBs were distributed into the environment --all of them manufactured or licensed for manufacture by one corporation, Monsanto of St. Louis, Missouri.[11]
The whereabouts of 30 percent of all PCBs (roughly a billion pounds) remains unknown. Another 30 percent resides in landfills, in storage, or in the sediments of lakes, rivers, and estuaries. Some 30 percent to 60 percent remains in use. The characteristics of PCBs (their stability and their solubility in fat) tend to move them into the oceans as time passes. There they decimate wildlife. It is estimated that only one percent of all PCBs have, so far, reached the oceans.
Without major efforts to locate, capture, and destroy the one-to-two billion pounds of PCBs that are "out there," future generations will continue to be poisoned by PCBs, at great social and individual cost.
Recently, we hear a drum beat of public relations from Monsanto, claiming that it has turned over a new leaf and is now committed to behaving in a civilized fashion. If this is so, Monsanto could demonstrate its awakening by leading a global effort to locate and destroy PCBs, cleansing the planet (to the extent possible) of this brain-damaging, immune-suppressing, cancer-causing substance. Has anyone seen a sign of serious intentions from St. Louis?
--Peter Montague
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