#704: MODERN ENVIRONMENTAL PROTECTION--PART 1

[Guest guest]

rachel@... on 07/27/2000 01:58:26 PM

Please respond to rachel@...

rachel-weekly@...

cc: (bcc: Decelie/CHASE)

Subject: #704: MODERN ENVIRONMENTAL PROTECTION--PART 1

=======================Electronic Edition========================

.. .

.. RACHEL'S ENVIRONMENT & HEALTH WEEKLY #704 .

.. ---July 21, 2000--- .

.. HEADLINES: .

.. MODERN ENVIRONMENTAL PROTECTION--PART 1 .

.. ========== .

.. Environmental Research Foundation .

.. P.O. Box 5036, polis, MD 21403 .

.. Fax (410) 263-8944; E-mail: erf@... .

.. ========== .

.. All back issues are available by E-mail: send E-mail to .

.. info@... with the single word HELP in the message. .

.. Back issues are also available from http://www.rachel.org. .

.. To start your own free subscription, send E-mail to .

.. listserv@... with the words .

.. SUBSCRIBE RACHEL-WEEKLY YOUR NAME in the message. .

.. The newsletter is now also available in Spanish; .

.. to learn how to subscribe, send the word AYUDA in an .

.. E-mail message to info@.... .

=================================================================

MODERN ENVIRONMENTAL PROTECTION--PART 1

Two extraordinary books have just been published by MIT Press.

Together, they describe a fundamentally new approach to

environmental protection. This week we begin reviewing Joe

Thornton's PANDORA'S POISON.[1] Soon we will review

O'Brien's MAKING BETTER ENVIRONMENTAL DECISIONS.[2] In these two

books, we see the best environmental thinking of the past 15

years really coming together. This is what we've all been waiting

for -- a new system for environmental protection that can unite

the various strands of the environmental community behind a few

shared goals and a common agenda. This IS powerful reason for

hope.

Using chlorinated chemicals as a case study,PANDORA'S POISON

reveals how (and why) the current system of environmental

protection has failed so miserably. To replace this failed

system, Thornton describes a fundamentally new approach.

Thornton is a scientist, a molecular biologist, and the bulk of

his book describes in detail the extensive damage that

chlorinated chemicals have already done to humans and wildlife.

Thornton shows that in just 60 years, the petrochemical industry

has contaminated every living thing on earth with novel

toxicants, some of which disrupt life's fundamental processes at

levels measured in parts per trillion (a proportion equivalent to

one drop in a train of tank cars 10 miles long). Introduction of

organochlorine chemicals by Dow, Monsanto, DuPont and others was

an unprecedented act of hubris combined with a studied ignorance

as to consequences. And of course it was all perfectly legal,

licensed and overseen by the world's most vigilant regulatory

agencies. How could this happen? Thornton tells us how.

The chemical industry now produces an astonishing 40 million tons

of elemental chlorine each year, which it then combines into

11,000 different chlorinated chemical products, plus thousands of

other unintended chlorinated byproducts, virtually all of which

are toxic and all of which eventually make their way into the

environment, where, for the most part, nature has no efficient

means for decomposing them. Most of these toxicants interfere

with the fundamental processes of living things. As a result,

" Every species on earth -- including humans -- is now exposed to

organochlorines that can reduce sperm counts, disrupt female

reproductive cycles, cause endometriosis, induce spontaneous

abortion, alter sexual behavior, cause birth defects, impair the

development and function of the brain, reduce cognitive ability,

interfere with the controlled development and growth of body

tissues, cause cancer, and compromise immunity. If we stopped all

further pollution today, these compounds would remain in the

environment, the food web, our tissues and those of future

generations for centuries, " says Thornton, summarizing the

findings of more than a thousand scientific studies.(pg. 6)

Thornton makes it clear that the decision to add chlorine to

industrial organic chemicals was one of the most profound errors

that humans have ever made. He argues cogently that most

chlorinated chemicals should be phased out over the next several

decades, and we should adopt a new system of environmental

protection that would prevent such errors in the future.

Thornton is an excellent writer, so his book is easy to read, but

the book is also an intellectual tour de force, synthesizing

scientific information from toxicology, epidemiology, ecology,

molecular biology, and environmental and industrial chemistry.

But Thornton does not stop there; in the final chapters he delves

into history, ethics, and the philosophy of science to describe

and explain the system of environmental protection that allowed

the global organochlorine disaster to unfold. He labels the

current, failed system the " risk paradigm " and he proposes a

fundamentally new system for environmental protection, which he

calls the " ecological paradigm. "

As Thornton says, " A paradigm is a total way of seeing the world,

a lens that determines how we collect and interpret data, draw

conclusions from them, and determine what kind of response, if

any, is appropriate. " (pg. 7)

The " risk paradigm " tells regulators which problems are

important, and how to handle them. Unfortunately, it is an

entirely inadequate tool for managing chlorinated chemicals and

other persistent or bioaccumulative pollutants like mercury,

lead, asbestos, and biologically active radioactive elements such

as plutonium.

The risk paradigm tries to manage pollution one chemical at a

time by allowing chemical discharges so long as they don't exceed

a numerical standard of " acceptable " contamination. This approach

assumes that ecosystems have an " assimilative capacity, " a

certain ability to absorb and decompose chemicals without harm,

and it assumes that humans can learn what that assimilative

capacity is. The risk paradigm also assumes that organisms, such

as humans or birds, can accommodate some degree of chemical

exposure with no or negligible adverse effects, so long as

exposure remains below the " threshold " at which toxic effects

become significant.

The " risk paradigm " aims to set " acceptable exposures, " chemical

by chemical. The " risk paradigm " uses quantitative risk

assessment to establish " acceptable " exposures and regulators

then set discharge limits, chemical by chemical, intending to

make sure that " acceptable " exposure limits are never exceeded.

Industry then applies end-of-pipe control devices (filters,

scrubbers, etc.) to capture pollutants and move them to a

different place. That is how the current system of environmental

protection was designed, and that is how it operates today.

Obviously, it places great faith in science to discover how

nature works and to predict and understand harm in individual

organisms and in complex ecosystems -- a faith that is misplaced

because science is simply not up to the task.

The " ecological paradigm " is entirely different. As Thornton

says, " First and foremost the Ecological Paradigm recognizes the

limits of science: toxicology, epidemiology and ecology provide

important clues about nature but can never completely predict or

diagnose the impacts of individual chemicals on natural

systems. " (pg. 10) The proper response to this inevitable

scientific uncertainty is to avoid practices that have the

potential to cause severe damage, even in cases in which we do

not have scientific proof of harm. This is the precautionary

principle, familiar to RACHEL'S readers. (See REHW #586.)

However, Thornton points out, the precautionary principle does

not tell us what kind of action to take. So we need to supplement

the precautionary principle with three additional principles:

zero discharge, clean production, and reverse onus. Together,

these ideas constitute a new " ecological paradigm " for protecting

the environment.

Zero discharge means we must eliminate rather than allow the

release of substances that persist or bioaccumulate (because they

remain in the environment, available to cause trouble). Their

persistence tells us that nature does not have means for handling

them.

Clean production emphasizes the redesign of products and

processes so they don't use or create toxic chemicals -- avoiding

trouble before it occurs. The point of clean production is to

seek out, and adopt, the least harmful alternatives.

Reverse onus is a new way of evaluating chemicals. Using the

principle of reverse onus, the burden of proof, which now rests

with society to prove that a chemical will cause harm, is shifted

to those who want to produce or use a novel chemical. Such people

must demonstrate in advance that their actions are not likely to

pose a significant hazard. Chemicals currently in use that cannot

meet this criterion will be phased out in favor of less damaging

alternatives.

In the " risk paradigm, " a lack of data about a chemical is taken

as evidence of safety, so untested chemicals are allowed to be

used without restriction. The result is the current permissive,

laissez faire system in which anything goes until someone can

prove to a scientific certainty that significant damage has

occurred.

In contrast, the " ecological paradigm " amounts to " a program of

continued reductions in the production and use of all synthetic

[human-created] substances, with priority given to chemical

classes that are known to persist, or bioaccumulate, or cause

severe or fundamental disruptions of biological processes. " (pg.

11) As Thornton says, " By reversing the onus in environmental

regulation, the Ecological Paradigm simply applies the standard

that society now uses for pharmaceuticals -- demonstrate safety

and necessity before a drug is licensed for introduction into

patients' bodies -- to chemicals that will enter our bodies

through the environment. Reversing the burden of proof would also

set straight the twisted ethics of the current system, in which

we mistakenly grant chemicals the presumption of innocence--a

right that was created for people--while humans and other species

are subject to a large-scale, multigenerational experiment of

exposure to untested and potentially toxic chemicals. " (pg. 11)

Four Reasons Why the Risk Paradigm Has Failed

Reason#1: The risk paradigm only comes into play late in the

process of creating pollution. Under the risk paradigm, chemicals

are produced and used without any restrictions. However, just

before the chemicals are about to be discharged into the

environment, they are captured, treated and " disposed of " in a

landfill, incinerator or other device.

As Thornton points out, this end-of-pipe approach fails for four

reasons:

a) When the product itself contains poisons, pollution control

devices are useless. He gives the examples of pesticides sprayed

on a field, paint stripper sold to a handyman, and PVC [polyvinyl

chloride] pipe installed in a building that may one day burn

down, creating significant amounts of dioxin. In none of these

examples will end-of-pipe pollution control devices help.

Pollution control devices -- filters and scrubbers -- merely

shift contaminants from one place to another -- from the water to

the land, or from the land to the air (then back to the land

somewhere else). Eventually, captured pollutants always make

their way into the environment.

c) Control technologies deteriorate and break down just as all

mechanical systems must. Therefore, they don't always work as

well as they were designed to work and they release contaminants

increasingly as time passes.

d) Pollution control devices are only designed to capture a

certain proportion of the pollutants being created; beyond that,

control becomes prohibitively expensive, so a certain small

proportion of pollution always escapes. As total production

grows, the amount that escapes must grow too.

Reason #2: The concepts of assimilative capacity and acceptable

discharge -- the centerpieces of the risk paradigm -- don't work

for chemicals that persist or bioaccumulate. Chemicals that do

not break down rapidly in nature will build up in living things,

contaminating food webs. Natural systems have no " assimilative

capacity " for such chemicals and there can be no " acceptable "

discharges of such chemicals.

Reason #3: Risk assessment, another central tool of the risk

paradigm, doesn't work for systems as complicated as living

organisms in ecosystems because (a) most of the crucial

information about individual chemicals is missing; ( our

measuring techniques are crude, so we can never be sure that a

contaminant level we believe is " harmless " is actually harmless;

© we are largely ignorant about how organisms function in

ecosystems so we cannot predict what will happen when we

introduce toxicants into such systems, especially when we

introduce multiple toxicants simultaneously, which is almost

always the case in the real world; (d) finally, there are genuine

surprises -- risk assessors may look for certain suspected

effects, find none, and declare a chemical harmless but the

chemical may turn out to cause an effect they did not

investigate, or an effect they never dreamed of.

Reason #4: Risk assessment was designed to deal with

well-defined, local, short-term hazards. But preventing major

local damage does not prevent the slow accumulation of global

damage, which is the cumulative result of millions of

technological decisions. " The local focus of the risk-based

system is intrinsically at odds with the problem of global

accumulation. " (pg. 342) The problem of global accumulation is

what we're dealing with in the case of chlorinated chemicals

(like DDT), lead, mercury, and plutonium.

Finally, Thornton points out that, " Once global injury occurs,

the current system's methods for dealing with damage also break

down. The scope of this kind of damage -- large scale impairment

of the health of human and wildlife populations, contamination of

the entire food web -- is so vast that it can never be cleaned up

or repaired. The inability to trace causality to individual

actors means that victims cannot be compensated or individual

perpetrators held legally responsible. Most important, this

system, which requires a demonstration of a causal link before

action can be taken to eliminate the cause of a problem, cannot

even stop the damage it is doing when it finally becomes obvious;

the limits of epidemiology and the lack of local, determinate

causality mean that this requirement will never be satisfied.

Current institutions become paralyzed by their own unrealistic

standards of proof. " (pgs. 342-343)

[More next time.]

===============

[1] Joe Thornton, PANDORA'S POISON; CHLORINE, HEALTH, AND A NEW

ENVIRONMENTAL STRATEGY (Cambridge, Mass.: MIT Press, 2000). ISBN:

0262201240.

[2] O'Brien, MAKING BETTER ENVIRONMENTAL DECISIONS; AN

ALTERNATIVE TO RISK ASSESSMENT (Cambridge, Mass.: MIT Press,

2000). ISBN: 0262650533.

################################################################

NOTICE

In accordance with Title 17 U.S.C. Section 107 this material is

distributed without profit to those who have expressed a prior

interest in receiving it for research and educational purposes.

Environmental Research Foundation provides this electronic

version of RACHEL'S ENVIRONMENT & HEALTH WEEKLY free of charge

even though it costs the 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 tax-deductible contribution to: Environmental Research

Foundation, P.O. Box 5036, polis, MD 21403-7036. Please do

not send credit card information via E-mail. For further

information about making tax-deductible contributions to E.R.F.

by credit card please phone us toll free at 1-888-2RACHEL, or at

(410) 263-1584, or fax us at (410) 263-8944.

-- Montague, Editor

################################################################