http://infoarchive.net/sgroup/BIOFUEL/37783/
#798 -- The Chemical Wars, Part 1, August 19, 2004
http://infoarchive.net/sgroup/BIOFUEL/38111/
#799 -- The Chemical Wars, Part 2, September 02, 2004
------
http://www.rachel.org/bulletin/index.cfm?issue_ID=2471
#800 -- The Chemical Wars, Part 3, September 16, 2004
by Peter Montague
[Continuing: We have been describing the philosophy of environmental
regulation in the U.S. Basically, it is a "prove harm" system --
anything goes until someone can "line up the dead bodies" and prove
that significant harm is occurring. When that happens, which is rare,
then a multi-year, or multi-decade, battle begins in which
underfunded and understaffed government regulators bargain with a
phalanx of corporate lawyers and scientists-for-hire. Eventually they
hammer out a compromise between public health and corporate purposes.
The compromise becomes an enforceable regulation --until one
corporation or another decides to mount a challenge and the dance
begins anew.
The "prove harm" system rests on three assumptions: (1) Humans can
determine the "assimilative capacity" of every population of humans
and animals and every ecosystem on Earth -- the capacity to absorb
damage without suffering permanent, serious harm. (2) Once the
"assimilative capacity" of a river, or a population of humans or
birds, has been determined, we will set regulatory controls to keep
the harm within "acceptable" limits; and (3) We already know which
substances and activities are harmful or, in the case of activities
we never suspected were harmful, we will we warned of possible
dangers by traumatic but sublethal shocks.
Obviously the system really hinges on assumption #1 -- that we can
determine the "assimilative capacity" of an ecosystem, or of a
population of polar bears or humans. For this purpose, a special
technique has been developed called "risk assessment." Risk
assessment is the linchpin of the "prove harm" regulatory system, and
the main intellectual armor of industrial polluters. But this emperor
is wearing no clothes. Let's take a look.]
Of course there's nothing wrong with trying to assess risks. We all
do it every day. But there's an important difference between our own
personal risk assessments and corporate/governmental risk assessments.
When we assess risk in our own lives, (a) we examine risks that we
ourselves are willing to take; (b) we compare our options; and (c) we
use all available information; and (d) we weigh not only the risks we
face but also the benefits. For example, we might ask ourselves, "Can
I just dash across this street in the middle of the block, or, given
the shoes I'm wearing and the arthritis in my left knee, should I
walk to the corner and cross with the light? Is saving a minute or
two worth the risk of being hit by a truck?" We compare risks and
benefits, we assess our alternatives, we consider all the available
information, and we weigh the risks we ourselves are willing to take.
In contrast, corporate risk assessors almost always (a) assess the
dangers of a single pre-determined option, and (b) assess dangers
that they intend to impose on others, usually without their informed
consent; and (c) examine only the scientifically-proven evidence,
ignoring other kinds of information such as historical precedents,
worker knowledge, and community preferences; and (d) ignore the
benefits (or lack of them) to those who will be enduring the dangers.
Basically, the main use of corporate/governmental risk assessment is
to establish how much damage corporations and governments can get
away with and to label that damage "acceptable."[1]
Typical questions that corporate/governmental risk assessments answer
would include, How much dioxin can aluminum smelters discharge into
the Columbia River basin without thinning the Bald Eagle population
to extinction? How many trout can families along Lake Michigan eat
each month before their children's IQs are diminished 5 points? How
much benzene can we maintain in the air of this factory without
killing more than 1 in every 10,000 workers? Will this urban trash
incinerator kill no more than one in each million citizens who
breathe its fumes?
Risk assessment serves corporate purposes because it involves large
quantities of scientific data, all of it subject to limitations and
uncertainties that can be disputed forever without resolution. Where
data are lacking or disputed, assumptions and judgments must be
substituted for facts. The National Academy of Sciences put it
politely when it said, "Risk assessment techniques are highly
speculative, and almost all rely on multiple assumptions of fact --
some of which are entirely untestable."[2] In 1983 the National
Academy identified at least 50 points during the course of a cancer
risk assessment where choices had to be made on the basis of
professional judgment, not science.[3] Corporate scientists-for-hire
can select and manipulate the data and choose particular assumptions
(often silently), allowing them to reach almost any conclusion they
set out to reach yet still package it as "science" even though the
conclusion is based on judgment and is not in any way reproducible.[4]
Risk assessment provides corporations other major benefits as well.
Because risks are expressed mathematically (the probability of x
occurring during y years of exposure to chemical z), troublesome
questions of right and wrong cannot arise, and most of the public is
left out of the process. Thus risk assessment gives corporate goals a
patina of "sound science," prevents ethical considerations from
muddying the debate, and keeps the affected citizens locked out of
the discussion.
Risk assessment now guides all environmental management, not merely
the control of chemicals. Before cutting new roads into a national
forest, the government completes a risk assessment to decide how many
roads would decimate the bear population. Ocean fisheries are managed
by risk assessment to determine the "maximum sustainable yield" of
fish. Risk assessment determines allowable drug residues in beef,
allowable pesticide residues in food, allowable withdrawals of water
from rivers and aquifers, allowable contamination of drinking water,
limits on the discharge of particulates and toxic chemicals from
coal-fired power plants, auto emission limits, livestock grazing
allotments on arid lands, allowable harvests of endangered species,
fishing and hunting quotas, workplace exposure limits, radiation
limits in medical settings, cleanup standards for contaminated sites,
and on and on.
Risk assessment is so fundamental to the "growth and rapid
innovation" culture that the technique is now taught at most large
colleges and universities. There are several scholarly journals
devoted to it. Many books have been written on the subject, including
several by the National Academy of Sciences. The federal government
sponsors research to elaborate and refine risk assessment techniques,
and it trains risk assessors in places like Mexico and the Ukraine,
intending to "harmonize" the response to corporate harms world-wide.
Risk assessment research institutes at places like Harvard are
generously funded by important corporate risk-makers like Monsanto
and Dow, and the work of these institutes is injected directly into
federal "risk policy." Professional societies of risk assessors meet
each year in resort locations to swap war stories and share their
latest techniques. Assessing risks has become a major industry unto
itself. It is no exaggeration to say that the modern industrial
system with its culture of "rapid innovation at any cost" could not
maintain its present course without risk assessors to run
interference.
In the last decade, however, risk assessment has come under withering
criticism from at least a dozen perspectives:
1) Because of genetic makeup, individuals differ markedly in their
susceptibility to poisons. Some people are far more sensitive than
others. For example, some people cough and wheeze when they walk down
the detergent aisle at the grocery store; others don't. Furthermore,
many people suffer from chronic conditions (asthma, diabetes, etc.),
so risk assessments cannot reasonably assume, as they typically do,
that only healthy young adults are exposed.
2) Risk assessors try to account for human variability by applying a
"safety factor" of 10 to their numerical estimate of risk. But such a
number has little to do with science. Safety factors are often little
more than guesses. Why not a factor of 11 or 17 instead of 10? Even
calling it a "safety" factor is misleading because who can say it
offers safety?
3) Risk assessments of chemicals are conducted on single chemicals,
but in the real world we are all exposed to mixtures of chemicals day
in and day out. Furthermore, many studies have now shown that
harmless amounts of individual chemicals, in combination, can add up
to a harmful dose.[5] The health effects of mixtures are far too
complex for science to sort out, yet mixtures are what we encounter
in our daily lives, so testing single chemicals is misleading and
often beside the point. Corporate scientists-for-hire may pretend
that, with sufficient testing, the problem of mixtures can be
mastered. But when asked where the resources will come from to test
all possible combinations of even 1000 chemicals, they grow silent.
There are 41 billion possible combinations of 1000 chemicals taken in
groups of 4. Even if we could test a million combinations a year,
which we can't, it would take 41,000 years to complete such a battery
of tests.
4) Some chemicals are only biologically active during a brief period
of time (a "window of vulnerability") in the development of an
organism, so toxicity must be tested during those exact
times.[6,7,8,9,10] Chemicals tested during other times will appear to
be less potent or even inert.
5) In the case of some hormone-disrupting chemicals, low doses can
cause greater endocrine disruption than high doses. More than 100
studies have now confirmed that this phenomenon is real.[11] This
seems to happen because the hormone system is active at low doses but
becomes overwhelmed and stops responding at higher doses.
Traditionally, chemicals have been tested at the highest doses that
laboratory animals could tolerate, but now we know that high-dose
tests may miss important toxic effects that only occur at low doses.
Many of the high-dose tests that have been completed to date (and
upon which federal regulations are based) are of very limited value
from a public health perspective and need to be re-done at much lower
doses.
6) We now know that cells respond differently to chemicals, depending
on their prior history of exposure.[12,13] In addition, whole
organisms (mice, humans) exhibit similar behavior: response to a
chemical is strongly conditioned by prior exposure. For example, a
person who smokes a cigarette for the first time reacts with
lightheadedness and perhaps nausea but a habituated smoker develops a
craving for cigarette smoke and feels sick without it. Furthermore,
after a heavy smoker quits smoking, he or she will be "sensitized" to
second-hand smoke thereafter, reacting to it much more powerfully
than a person who has never smoked. Thus individual history of
exposure to a chemical can dramatically affect response. This
important phenomenon is not taken into account in the toxicity tests
that underlie chemical risk assessments.
7) It has now been established that cells respond differently to
pulsed exposures to some chemicals, compared to continuous exposures.
Thus a pattern of repeated exposures interrupted by regular intervals
of non-exposure elicits a different response compared to cells
continuously exposed.[14,15] "For example, when animals respond to
gonadotropin-releasing hormone, the pulse frequency of stimulation is
more important than the average level of the hormone."[14]
8) Medical understanding of the role of inflammation in disease is
now changing substantially. Inflammation is a sign that the immune
system has been incited, and animals (or humans) with inflammation
react differently to chemical exposures than animals without
inflammation.[16]
9) We now know that many dose-response relationships are not linear.
Indeed, the shape of dose-response curves is the subject of an
extensive body of contentious literature, yet risk assessors continue
to rely most often on the simplifying assumption of linearity. This
simplifying assumption makes many risk assessments possible but it
may also make them wrong.
10) Thousands of potentially important biochemical reactions are
ignored during risk assessments. Current federal protocols for
examining the tissues of experimental animals were developed before
the advent of biochemistry and molecular biology. After animals are
dosed and then killed for tissue analysis, their organs are examined
visually for gross damage, but microscopic examination of the organs
is not typically required -- much less the sophisticated analyses
made possible by modern biochemistry and molecular biology. Animal
testing is decades behind current biology, and will likely remain so
for economic reasons. Thorough examination of dosed animals would be
far more expensive than the simple examinations that are standard
today (and which already cost in the range of $20,000 to $100,000 per
test).
Even when animal tissues are examined under a microscope, not all
tissue types are examined. All organs are composed of various types
of cells, and each type would need to be examined to claim that a
thorough investigation had been conducted, but this is not done.
Thus thousands of distinct biochemical mechanisms are not examined,
because no one requires them to be (to keep costs down). Cognition,
behavior, fertility, disease resistance, male reproduction, chronic
neurotoxicity, immune alteration and hormone function (critical to
hundreds of biochemical systems) are all ignored in typical risk
assessments.[17]
In sum, thousands of potential injuries are missed by typical gross
visual (and occasional microscopic) examinations in animal toxicity
tests.
11) The vulnerable period of development is not tested. With rare
exceptions, the period of greatest vulnerability (corresponding to
the human period of life from conception through age 18) is not
tested in laboratory animals. Adult animals are tested. In addition,
effects on second and third generations are not typically looked for.
12) The commercial forms of chemicals tested in the laboratory may
bear little resemblance to chemicals of the same name found in
environmental food chains. Depending on source of exposure, pathway
through the food chain, and weathering effects, chemicals measured in
humans or other animals can have distinctly different characteristics
from "pure" commercial forms of chemicals, meaning that many risk
assessments are conducted on chemical species that are not
encountered in the real world.[18]
It must be obvious that these shortcomings of risk assessment cannot
be remedied because there simply aren't enough laboratories and
enough money to take into account all the sources of variability
listed above.
And if corporations and government agencies cannot systematically
take these biological phenomena into account, they should acknowledge
that their risk assessments are hardly more than window dressing,
having little to do with reproducible science, intended mainly to
mollify an apprehensive public.
[To be continued.]
============
Reprinted with permission from: Peter Montague, "The Chemical Wars,"
New Solutions Vol. 14, No. 1 (2003), pgs. 19-41.
[1] Mary O'Brien, Making Better Environmental Decisions; An
Alternative to Risk Assessment (Cambridge, Mass.: MIT Press, 2000;
ISBN 0-262-65053-3).
[2] Quoted in Anthony B. Miller and others, Environmental
Epidemiology, Volume 1: Public Health and Hazardous Wastes
(Washington, DC: National Academy of Sciences, 1991), pg. 45.
[3] United States General Accounting Office, Chemical Risk
Assessment; Selected Federal Agencies' Procedures, Assumptions, and
Policies [GAO-01-810] (Washington, D.C.: United States General
Accounting Office, August, 2001), pg. 31.
[4] A major study of risk assessment was conducted by 11 European
governments during the period 1988-1990, and published by the
Commission of the European Communities under the title Benchmark
Exercise in Major Hazard Analysis in 1991. The 11 governments
(Netherlands; Greece; Great Britain; Denmark; Italy; Germany; France;
Belgium; Spain; Finland; and Luxembourg) established teams of their
best scientists and engineers and set them to work on a single
problem: analyzing the accident hazards of a small ammonia storage
plant. Private companies like Rohm & Haas, Solvay, Battelle, and Fiat
contributed experts as well. The results were stunning: the 11 teams
varied in their assessment of the hazards by a factor of 25,000.
Analyzing the hazards of a single, small plant handling only one
chemical, these world-class "risk experts" reached wildly different
conclusions. For example, the individual risk at the "refrigerated
storage site" was calculated by one group of experts to be
one-in-400, but by another group of experts to be one-in-10-million.
(Figure 3.5, pg. 58 of the Benchmark study.) See Commission of the
European Communities, Benchmark Exercise on Major Hazard Analysis. 3
Volumes. (Luxembourg, Luxembourg: Commission of the European
Communities, 1991).
[5] David O. Carpenter, Kathleen Arcaro, and David C. Spink,
"Understanding the Human Health Effects of Chemical Mixtures,"
Environmental Health Perspectives Vol. 110 Supplement 1 (February,
2002) pgs. 25-42.
[6] Beverly S. Rubin, Mary K. Murray, David A. Damassa, Joan C. King,
and Ana M. Soto, "Perinatal Exposure to Low Doses of Bisphenol A
Affects Body Weight, Patterns of Estrous Cyclicity, and Plasma LH
Levels," Environmental Health Perspectives Vol. 109, No. 7 (July
2001), pgs. 675-680.
[7] K.S. Landreth, "Critical windows in development of the rodent
immune system," Human and Experimental Toxicology Vol. 21, Nos. 9-10
(Sep-Oct, 2002), pgs.493-498;
[8] M.C. Garofolo, F.J. Seidler, M.M. Cousins, C.A. Tate, D. Oiao,
and T.A. Slotkin, "Developmental toxicity of terbutaline: Critical
periods for sex-selective effects on macromolecules and DNA synthesis
in rat brain, heart, and liver," Brain Research Bulletin Vol. 59, No.
4 (Jan. 15, 2003), pgs. 319-329;
[9] T.A. Lindsley and L.J. Rising, "Morphologic and neurotoxic
effects of ethanol vary with timing of exposure in vitro," Alcohol
Vol. 28, No. 3 (Nov., 2002), pgs. 197-203;
[10] M.R. van den Heuvel and R.J. Ellis, "Timing of exposure to a
pulp and paper effluent influences the manifestation of reproductive
effects in rainbow trout," Environmental Toxicology and Chemistry
Vol. 21, No. 11 (Nov., 2002), pgs. 2338-2347.
[11] Erik Baatrup and Mette Junge, "Antiandrogenic Pesticides Disrupt
Sexual Characteristics in the Adult Male Guppy (Poecilia
reticulata)," Environmental Health Perspectives Vol. 109, No. 10
(October 2001), pgs. 1063-1070.
[12] Nicholas T. Ingolia and Andrew W. Murray, "History Matters,"
Science Vol. 297 (Aug. 9, 2002), pgs. 948-949.
[13] Upinder S. Bhalla, P.T. Ram, and R. Iyengar, "MAP Kinase
Phosphatase As a Locus of Flexibility in a Mitogen-Activated Protein
Kinase Signaling Network," Science Vol. 297 (Aug. 9, 2002), pgs.
1018-1023.
[14] M.S. Berrill, S. Bertram, B. Pauli, D. Coulson, M. Kolohon, and
D. Ostrander, "Comparative sensitivity of amphibian tadpoles to
single and pulsed exposures of the forest-use insecticide
fenitrothion," Environmental Toxicology and Chemistry, Vol. 14, No. 6
(1995), pgs. 1011-1018;
[15] R.B. Naddy, K.A. Johnson, and S.J. Klaine, "Response of Daphnia
magna to pulsed exposures of chlorpyrifos," Environmental Toxicology
and Chemistry Vol. 19, No. 2 (2000), pgs. 423-431.
[16] P.E. Ganey and R.A. Roth, "Concurrent inflammation as a
determinant of susceptibility to toxicity from xenobiotic agents,"
Toxicology Vol. 169, No. 3 (Dec 28, 2001), pgs. 195-208.
[17] U.S. Environmental Protection Agency, Health Effects Test
Guidelines; OPPTS 870.4100 Chronic Toxicity [EPA 712-C-98-210]
(Washington, D.C.: U.S. Environmental Protection Agency, 1998.)
[18] S.L. Schantz, J.J. Widholm, and D.C. Rice, "Effects of PCB
Exposure on Neuropsychological Function in Children," Environmental
Health Perspectives Vol. 111, No. 3 (March 2003), pgs. 357-376.
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