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July 8, 1999
PVC AND THE BREASTS OF MOTHERS
Wow! Last week the Science and Environmental Health Network (SEHN) brought us THE PRECAUTIONARY PRINCIPLE IN ACTION: A HANDBOOK, and this week they bring us a full-length book just published by Island Press: PROTECTING PUBLIC HEALTH & THE ENVIRONMENT: IMPLEMENTING THE PRECAUTIONARY PRINCIPLE.[1] (To order the book from Island Press, telephone 1-800-828-1302 -- well worth the $30 price.)
Carolyn Raffensperger, the North Dakota dynamo who powers SEHN, seems to be everywhere at once. Last week she traveled to the White House, invited to make a presentation about the precautionary principle. We take this as further evidence that American industry is in a panic over this new way of making environmental decisions. Perhaps they are hoping Al Gore can coopt and "cool out" these precautionary upstarts and get things back onto the risk assessment track where they belong. We suspect Mr. Gore -- who talks a good game but whose actions have proven him an untrustworthy friend of the environment -- will do his best to give chemical corporations what they want.
SEHN's new book-length anthology will satisfy anyone who wants to know the history of the precautionary principle, where it fits into environmental law, how it has developed in Europe, and how the principle can be applied in many different settings. SEHN's book is deep and rewarding, at once philosophical and factual, a thoroughly satisfying volume.
Best of all, there is a special reward at the end of the book -- a wonderful little essay by Sandra Steingraber, our favorite environmental writer. Here, with permission from Island Press, is that essay verbatim:
Why the Precautionary Principle? A Meditation on Polyvinyl Chloride (PVC) and the Breasts of Mothers
by Sandra Steingraber[2]
Those of you who know me know that when I talk on these topics I usually speak out of two identities: biologist and cancer activist. My diagnosis with bladder cancer at age 20 makes more urgent my scientific research. Conversely, my Ph.D. in ecology informs my understanding of how and why I became a cancer patient in the first place: bladder cancer is considered a quintessential environmental disease. Links between environment and public health became the topic of my third book, LIVING DOWNSTREAM, but since I have been given the task of speaking about the effect of toxic materials on future generations, I'm going to speak out of another one of my identities -- that of a mother.
I'm a very new mother. I gave birth in September 1998 to my daughter and first child. So, I'm going to speak very intimately and in the present tense. You know it's a very powerful thing for a person with a cancer history to have a child. It's a very long commitment for those of us unaccustomed to looking far into the future. My daughter's name is Faith.
I'm also learning what all parents must learn, which is a new kind of love. It's a love that's more than an emotion or a feeling. It's a deep physical craving like hunger or thirst. It's the realization that you would lay down your life for this eight-pound person without a second thought. You would pick up arms for them. You would empty your bank account. It's love without boundaries and were this kind of love directed at another adult, it would be considered totally inappropriate. A kind of fatal attraction. Maybe, when directed at babies, we should call this "natal attraction."
I say this to remind us all what is at stake. If we would die or kill for our children, wouldn't we do anything within our power to keep toxics out of their food supply? Especially if we knew, in fact, there were alternatives to these toxics?
Of all human food, breast milk is now the most contaminated. Because it is one rung up on the food chain higher than the foods we adults eat, the trace amounts of toxic residues carried into mothers' bodies become even more concentrated in the milk their breasts produce. To be specific, it's about 10 to 100 times more contaminated with dioxins than the next highest level of stuff on the human food chain, which are animal-derived fats in dairy, meat, eggs, and fish. This is why a breast-fed infant receives its so-called "safe" lifetime limit of dioxin in the first six months of drinking breast milk. Study after study also shows that the concentration of carcinogens in human breast milk declines steadily as nursing continues. Thus the protective effect of breast feeding on the mother appears to be a direct result of downloading a lifelong burden of carcinogens from her breasts into the tiny body of her infant.
When it comes to the production, use, and disposal of PVC [polyvinyl chloride plastic], the breasts of breast-feeding mothers are the tailpipe. Representatives from the vinyl industry emphasize how common a material PVC is, and they are correct. It is found in medical products, toys, food packaging, and vinyl siding. What they don't say is that sooner or later all of these products are tossed into the trash, and here in New England, we tend to shovel our trash into incinerators. Incinerators are de facto laboratories for dioxin manufacture, and PVC is the main ingredient in this process. The dioxin created by the burning of PVC drifts from the stacks of these incinerators, attaches to dust particles in the atmosphere, and eventually sifts down to Earth as either dry deposition or in rain drops. This deposition then coats crops and other plants, which are eaten by cows, chickens, and hogs. Or, alternatively, it's rained into rivers and lakes and insinuates itself into the flesh of fish. As a breast-feeding mother, I take these molecules into my body and distill them in my breast tissue. This is done through a process through which fat globules from throughout my whole body are mobilized and carried into the breast lobes, where, under the direction of a pituitary hormone called prolactin, they are made into human milk. Then, under the direction of another pituitary hormone called oxytocin, this milk springs from the grape-like lobes and flows down long tubules into the nipple, which is a kind of sieve, and into the back of the throat of the breast-feeding infant. My daughter.
So, this, then, is the connection. This milk, my milk, contains dioxins from old vinyl siding, discarded window blinds, junked toys, and used I.V. bags. Plastic parts of buildings that were burned down accidentally are also housed in my breasts. These are indisputable facts. They are facts that we scientists are not arguing about. What we do spend a lot of time debating is what exactly are the health effects on the generation of children that my daughter belongs to. We don't know with certainty because these kids have not reached the age at which a lot of diseases possibly linked to dioxin exposure would manifest themselves. Unlike mice and rats, we have long generational times. We do know with certainty that childhood cancers are on the rise, and indeed they are rising faster than adult cancers. We don't have any official explanation for that yet.
Let me tell you something else I've learned about breast feeding. It's an ecstatic experience. The same hormone (oxytocin) that allows milk to flow from the back of the chest wall into the nipple also controls female orgasm. This so-called let-down reflex makes the breast feel very warm and full and fizzy, as if it were a shaken-up Coke bottle. That's not unpleasant. Moreover, the mouths of infants -- their gums, tongues, and palates -- are perfectly designed to receive this milk. A newborn's mouth and a woman's nipple are like partners in a tango. The most expensive breast pump -- and I have a $500 one -- can only extract about half of the volume that a newborn baby can because such machines cannot possibly imitate the intimate and exquisite tonguing, sucking, and gumming motion that infants use to extract milk from the nipple, which is not unpleasant either.
Through this ecstatic dance, the breast-fed infant receives not just calories, but antibodies. Indeed the immune system is developed through the process of breast feeding, which is why breast-fed infants have fewer bouts of infectious diseases than bottle-fed babies. In fact, the milk produced in the first few days after birth is almost all immunological in function. This early milk is not white at all but clear and sticky and is called colostrum. Then, from colostrum you move to what's called transitional milk, which is very fatty and looks like liquid butter. Presumably then, transitional milk is even more contaminated than mature milk, which comes in at about two weeks post-partum. Interestingly, breast milk is so completely digested that the feces of breast-fed babies doesn't even smell bad. It has the odor of warm yogurt and the color of French mustard. By contrast, the excretions of babies fed on formula are notoriously unpleasant.
What is the price for the many benefits of breast milk? We don't yet know. However, one recent Dutch study found that schoolchildren who were breast fed as babies had three times the level of PCBs in their blood as compared to children who had been exclusively formula fed. PCBs are probably carcinogens. Why should there be any price for breast feeding? It should be a zero-risk activity.
If there was ever a need to invoke the Precautionary Principle -- the idea that we must protect human life from possible toxic danger well in advance of scientific proof about that danger -- it is here, deep inside the chest walls of nursing mothers where capillaries carry fat globules into the milk-producing lobes of the mammary gland. Not only do we know little about the long-term health effects of dioxin and PCB exposure in newborns, we haven't even identified all the thousands of constituent elements in breast milk that these contaminants might act on. For example, in 1997 researchers described 130 different sugars unique to human milk. Called oligosaccharides, these sugars are not digested but function instead to protect the infant from infection by binding tightly to intestinal pathogens. Additionally, they appear to serve as a source of sialic acid, which is essential to brain development.
Most recently, Swedish researchers discovered powerful anti-cancer proteins in breast milk. Activated by stomach acids, they appear to enhance cell suicide in defective cells, which is one way our own bodies protect us from developing cancer.[3]
So, this is my conclusion. Breast feeding is a sacred act. It is a holy thing. To talk about breast feeding versus bottle feeding, to weigh the known risks of infectious diseases against the possible risks of childhood or adult cancers is an obscene argument. Those of us who are advocates for women and children and those of us who are parents of any kind need to become advocates for uncontaminated breast milk. A woman's body is the first environment. If there are toxic materials from PVC in the breasts of women, then it becomes our moral imperative to solve the problem. If alternatives to PVC exist, then it becomes morally imperative that we embrace the alternatives and make them a reality.
THE USES OF SCIENTIFIC UNCERTAINTY
A revolution is occurring in the way science is used in environmental regulation. Like most revolutions, this one is causing some pain and some disruption, and of course it is being opposed viciously by those who profit from the present system. But the revolution is occurring nevertheless, and the ultimate outcome seems assured. When the revolution is complete, it will be a great day for public health and for the environment.
Scientists often define "scientific certainty" as "being 95% sure that cause and effect have been correctly identified." It is exceedingly rare for a large group of scientists to be 95% certain about anything, especially about anything as complex as an environmental problem. When you're talking about living systems, great scientific uncertainty is the norm. Even in the case of an ultra-well-studied chemical like dioxin, scientific uncertainty far outweighs firm knowledge of cause and effect.
How is scientific uncertainty currently treated in environmental protection? For 50 years it has been used permissively. It has been used to postpone actions that would protect public health. The classic case is the introduction of tetraethyl lead into gasoline. When chemical and automobile corporations announced they were starting to put highly-toxic tetraethyl lead into gasoline in 1922, numerous public health officials thought it was a dangerous idea and they urged delay and careful study. But the corporations argued that there was no scientific agreement about the threat; in the absence of convincing evidence of widespread harm (which had not yet occurred, so couldn't be documented), they insisted they had the right to proceed. Basically, they argued, "Until you can line up the dead bodies, we can do whatever we want." On that basis, the corporations pressed ahead heedlessly with the new toxic technology, thus setting the standard for corporate behavior over the next 50 years. The consequences of that particular decision are now a matter of record -- tens of millions of Americans suffered brain damage, their IQs permanently diminished by exposure to lead dust.
Because we have allowed scientific uncertainty to postpone controls on dangerous activities, we now have hazardous levels of mercury in most of the nation's fresh-water fish; the Earth's ozone shield has been dangerously depleted; global warming is upon us, with attendant droughts, fires, floods, hurricanes, tornadoes and typhoons; the ocean's major fisheries are in serious decline; the normal sex ratio of male-to-female babies has been changed in numerous industrialized countries, and human sperm counts have declined 50% in 50 years; immune system disorders like asthma and diabetes are steeply rising; many of the world's coral reefs are dying; cancers of the brain, the lymph system, the blood system and the testicles are increasing; cancer in children is escalating; many species have gone extinct.... This list of contemporary calamities could be readily extended.
But now people are waking up. They are waking up to the fact that scientific uncertainty should be cause for caution, not for plunging ahead recklessly. When flying blind, if you are not sure whether that shape looming just ahead is a cloud or a mountain, slow down. A stitch in time saves nine. If you aren't sure what you're doing, you should proceed slowly and carefully, or perhaps not at all. Better safe than sorry. That is the philosophy of precaution.
In truth, the principle of precautionary action has seemed a bit abstract, until now. It has seemed like a fine philosophy, but how would it work in actual practice? Now a new handbook from the Science and Environmental Health Network (SEHN) fleshes out this important philosophy of environmental protection, describing how it can work at the local level.[1]
The United States is already under obligation to operate by the precautionary principle. The federal government signed and ratified the Rio Declaration from the 1992 United Nations Conference on Environment and Development. The Rio Declaration says, "In order to protect the environment, the precautionary approach shall be widely applied by States [meaning nations--P.M.] according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation." Therefore, it is not a matter of WHETHER the U.S. will abide by the precautionary principle, but HOW.
The precautionary principle is now embedded in numerous international treaties and conventions: the Second North Sea Declaration; the Bergen Declaration on Sustainable Development; the Ministerial Declaration of the Second World Climate Conference; the Maastricht Treaty on the European Union; the Helsinki Convention on the Protection and Use of Transboundary Watercourses and International Lakes; and others.
Thus the stage is set. All that remains is for organizers and activists to press the precautionary principle into service at the local and state levels. The new guidebook from SEHN shows us how.
The precautionary principle says that decision-makers have a general duty to take preventive action to avoid harm before scientific certainty has been established.
The test for knowing when to apply the precautionary principle is the combination of threat of harm and scientific uncertainty. Some people would say that the threatened harm must be serious or irreversible, but others point out that this does not allow for the cumulative effects of relatively small insults.
Instead of asking how much damage or harm we will tolerate (which is the approach taken by risk assessment), the precautionary principle asks how to reduce or eliminate hazards, and it considers all possible means for achieving that goal, including scrapping the proposed activity. (Of course, alternatives to a hazardous activity must be scrutinized as carefully as the hazardous activity itself.)
The precautionary principle shifts the burden of proof. Proponents of an activity should prove that their activity will not cause undue harm to human health or the ecosystem. Those who have the power and resources to act to prevent harm have a responsibility to do so. That responsibility has 2 parts: financial liability for anything that goes wrong. [A performance bond posted up front (common in the construction industry) is the best way to handle this. The second part of responsibility is a duty to monitor, understand, investigate, inform and act. Ignorance and uncertainty are no longer excuses for postponing actions to prevent harm.
The steps in taking precautionary action are not complicated:
1. Describe and understand the problem or threat. How big is it? How far could it extend in space and time? Are there indirect impacts (for example, after the product is thrown away)? How serious could the effects be? Similar questions are raised whenever an environmental impact statement is written in response to the National Environmental Policy Act (NEPA), so there is not much new here.
2. Describe what is known and what is not known. There are many kinds of uncertainty (which the SEHN HANDBOOK does an excellent job of describing). Are we dealing with something that is unknowable, or about which we are totally ignorant? (If so, this is a good reason not to proceed.) What would it take to reduce the uncertainties? (Some uncertainties can be reduced and some cannot.) The SEHN HANDBOOK provides a good guide for understanding uncertainties: "Environmental and public health advocates have to ask difficult questions of industry and regulators to expose the depths of our ignorance. Once this lack of knowledge has been exposed, the notion of needlessly exposing humans and the environment to hazards without information on their effects seems irrational, and precaution seems logical."
3. Identify alternatives to the activity or product. First restate the problem to describe the purpose of the activity. A development provides housing; a solvent provides degreasing; a pesticide provides pest management. Now examine all of the alternative ways of fulfilling the purpose, to find the one that minimizes damage to people and to the environment.
4. Determine a course of action. How much precaution seems called for? Stop the proposed activity? Demand alternatives? Demand modifications to reduce bad impacts? Demand that a performance bond be posted up front?
5. Monitor. Those undertaking the activity should bear the cost of monitoring, but it should be conducted by an independent party (when possible). The monitoring information might warrant additional actions, or different actions.
The HANDBOOK then compares precaution to the way decisions are made now -- by risk assessment. Risk assessment does not fare well in the comparison.
The HANDBOOK ends with a section called "Answering the critics." Critics of the precautionary approach say things like, "It is not based on sound science" and, "This is emotional and irrational" and, "This will halt development and send us back to the stone age," and, "We comply with regulations so we are already practicing precaution." The HANDBOOK patiently provides reasoned responses to each of these dumb statements and several others as well.
The precautionary principle has American industry scared to death. Precautionary action immediately makes sense to people. Everyone can understand the wisdom of, "Do unto others as you would have others do unto you" and, "Better safe than sorry." The precautionary principle combines scientific validity with ethical force. No wonder corporations (and their handmaidens in government) consider it a threat to business as usual. It IS a threat to business as usual.
Industry's best hope is to adopt the language of precaution with great fanfare, while pressing ahead with the same old risk-based projects and programs, hoping no one will notice. To this end, the Harvard Center for Risk Analysis, a chemical industry think tank, held a conference last month to develop strategies for countering the precautionary principle. Participants openly scoffed at precaution. One participant described how his mother used to make him wear a sweater whenever he went outside, even though he lived in southern California. That pathetic little anecdote drew a loud, nervous laugh from the assembled throng, as if it had scored big points against the wisdom of precaution.
Participants had paid good money to attend the Harvard seminar, hoping to learn how to shore up the sagging fortunes of risk assessment. But even Big Heads from Harvard cannot salvage a bad idea whose time has gone. All risk assessments are fiction, shot through with assumptions, guesstimates, judgments, and biases -- all disguised disingenuously as "good science." The only thing that allows risk assessors to hold their heads up in public is that most people don't have the faintest idea what risk assessors do for a living or the consequences their work entails.
The principle of precautionary action, on the other hand, embodies all aspects of science -- including uncertainty -- in an ethical procedure aimed at ELIMINATING risks (something no risk assessment has ever aimed to do).
In the long run, the ethical way will prevail.
--Peter Montague
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