http://groups.yahoo.com/group/aspartameNM/message/1176
Isn't it time we regulated chemicals?
Tim Montague, Environmental Research Foundation: Murray 2005.06.25

From: "Gary Greenberg" <gngreenberg@gmail.com>
To: <Occ-Env-Med-L@MC.DUKE.EDU>
Subject: RACHEL: Isn't It Time We Regulated Chemicals?
Date: Saturday, June 25, 2005 2:04 AM

---------------- Information from the mail header -------------------
Sender: Occupational & Environmental Medicine
for Clinicians & Public Health Professionals <Occ-Env-Med-L@MC.DUKE.EDU>
Poster: Gary Greenberg <gngreenberg@GMAIL.COM>
Subject: RACHEL: Isn't It Time We Regulated Chemicals?
---------------------------------------------------------------------

(Moderator note: ERF is an advocacy organization, routinely alarmed
about potential new claims of environmental health dangers. Their
well-written editorials are presented to the oem-l forum in an effort
to provoke intellectual discussion, not as an endorsed point of view.
For contrast, see the newsletters posted from ACSH. -G)

^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
RACHEL'S ENVIRONMENT & HEALTH NEWS  June 23, 2005
#820 http://www.rachel.org

^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^

ISN'T IT TIME WE REGULATED CHEMICALS?

By Tim Montague*

If you read almost any newspaper these days, you learn the following
kinds of information:

** Many plastic toys contain chemicals that can interfere with the
sexual development of laboratory animals and are now thought capable
of doing the same in baby boys.[1]

** Most of the rivers and streams in the U.S. are contaminated with
low levels of chemicals that can change the sexual orientation of fish
and can interfere with reproduction in animals that feed on fish.[2]

** Dozens of toxic chemicals have recently been measured in household
dust, indicating that common consumer products are contaminating our
homes with toxicants.[3]

You might ask yourself, isn't the government regulating dangerous
chemicals? Unfortunately, the answer is No, not in any effective way.

About 1700 new chemicals are put into commercial use each year, almost
entirely untested for their effects on humans and the natural
world.[4]

After a chemical causes enough harm for someone to take notice, then
the government conducts a numerical risk assessment (aka, quantitative
risk assessment) on an individual chemical. The point of a numerical
risk assessment is to learn how much of a chemical is "safe" to eat,
drink, and breathe. Then the government may try to regulate releases
of that chemical. But fewer than 1% of all chemicals are currently
regulated. (See Rachel's #815.)

A scientist at the University of Oregon has described why numerical
risk assessment doesn't work, and has suggested other ways we could
control chemical hazards.[5]   Dr. Joe Thornton -- a biologist --
explains that numerical risk assessment is a fundamentally
inappropriate way to control persistent pollutants (such as heavy
metals and chemicals containing chlorine) for two reasons:

1) It assumes that we can learn all the ways that every individual
chemical can cause harm in humans and in the natural environment --
but there aren't enough scientists in the world to do this.

2) Many industrial chemicals tend to stick around for a long time and
move from place to place in ways that are impossible to predict, so
often we don't even know what we're looking for.

Thornton proposes we adopt four new ways of regulating chemicals --
zero discharge, clean production, reverse onus, and phasing out entire
classes of persistent chemicals -- because the old way (regulating one
chemical at a time at the end of the discharge pipe) simply doesn't
work.

Risk assessment assumes that damage is local, short-lived, and
predictable. But organisms and the environment are complex,
interconnected, and only partly understood (to put it mildly).
Therefore, we cannot predict cause-and-effect in any reliable way. In
the face of these insurmountable difficulties, we can take a
precautionary stance: when we have good reason to suspect harm, yet we
have scientific uncertainty, we can err on the side of caution. Faced
with choices, we can give the benefit of the doubt to public health
and to nature.

Thornton's four principles begin to clarify how the precautionary
principal can work in the real world. These principles are:

ZERO DISCHARGE -- Persistent and bioaccumulative toxicants are
incompatible with ecological processes, and no amount of their release
into the environment is acceptable.[6]

CLEAN PRODUCTION -- We can consider alternative technologies up front
and avoid the use of known toxicants in manufacturing. Finding
alternatives rather than approving pollutants becomes the focus.[7]
For example, in dry cleaning, we can replace perchloroethylene (perc)
with CO2 and water-based methods.

REVERSE ONUS -- Apply the same logic used in drug safety: give
manufacturers the responsibility to show that a product is reasonably
safe for use before it can be released into the environment. This
shifts the burden of proof from society to the chemical companies to
provide information about their products, to monitor for harmful
effects and to come clean about their findings.

EMPHASIS ON LARGE CLASSES OF CHEMICALS -- Faced with the
impossibilities of measuring the impacts of individual chemicals,
simply phase out entire classes of compounds that are clearly
problematic. PCBs, CFCs and lead compounds are all examples of classes
of chemicals that have been phased out because of their hazards.[5]

Thornton gives six reasons why the current risk paradigm is so flawed:

1. ACCUMULATION OF PERSISTENT POLLUTANTS

Risk-based approaches assume that nature and living things can absorb
and assimilate synthetic chemicals, breaking them down and digesting
them. This may be true for sewage, oil, and other naturally occurring
substances. But persistent organic pollutants (POPs) like pesticides,
solvents, refrigerants, etc. often resist natural breakdown and can
persist for years, decades or centuries. (See Rachel's #284, #505,
#611.)

Many POPs and metallic pollutants are fat-soluble and thus
bioaccumulate as they move up the food chain. Top predators like
humans, bears, and big fish can accumulate chemical concentrations
that are tens of millions of times greater than typical environmental
levels.

Persistence and bioaccumulation mean that even very small discharges
of synthetic chemicals can build up to dangerous levels in our bodies
over time. The general public's average body burden for some of the
best studied pollutants is already at or near the range at which
health impacts have been found in laboratory animals.[5] To avoid this
problem, we can declare that there is no level of acceptable discharge
for chemicals that persist or magnify in the food chain -- in other
words, we can adopt a zero-discharge policy.

2. CUMULATIVE GLOBAL POLLUTION

Numerical risk assessment oversimplifies the real world and considers
environmental risks to be local in time and space. Once a chemical
disperses beyond some horizon, it is assumed to do no further harm. So
industry is encouraged to dot the landscape with sources of pollution
that collectively begin to overwhelm the biosphere but which are
individually within acceptable limits. As a result the entire planet
has become polluted.

3. TOXICOLOGICAL COMPLEXITY

The science of numerical risk assessment is based on the premise that
we can calculate a chemical's impact on the health of living things.
Risk assessors do this by measuring the toxicity of individual
chemicals on individual species -- usually rats, mice and other small
mammals. There are at least 70,000 synthetic chemicals being used in
commerce today (up from 40,000 in 1991). Risk assessment considers the
toxicity of an individual pollutant acting alone -- when in reality
each chemical is acting in concert with a myriad of other chemicals in
the environment.

This poses a huge problem -- studying multiple chemical exposures is
very costly and time-consuming. It would require 33 million
experiments just to learn something about the effects of 25 different
chemicals on a single species over a short period of time (13 weeks).
A similar study of just 1% of the 70,000 chemicals in commerce would
require 10E210 experiments (that is, 10 with 210 zeroes behind it).
Trillions upon trillions upon trillions of experiments -- you can see
that science as we know it is not prepared to tackle this problem. On
the other hand, the risk-assessment solution is easy: Just ignore
multiple chemical exposures.

4. INADEQUATE DATA

Industry's capacity for inventing new chemicals has overwhelmed the
regulatory system's ability to study their potential harms. The
chemical industry is introducing at least 1700 new chemicals into
commerce each year.[4] The U.S. National Toxicology Program conducts
assessments on just 10 to 20 substances per year. At this rate we are
falling at least 90 years behind in our knowledge each year that
passes. A study by the National Research Council in 1997 concluded
that we lack even minimal toxicity information for 70% of the most
worrisome chemicals -- those that are manufactured in high volume and
are already suspected of harming the environment.

The risk-assessment solution: If you don't have data on the toxicity
of a substance, assume the risk is ZERO. Just ignore the problem.
Here, reverse onus plays an important role in putting the burden of
proof on industry to collect and reveal data on new chemicals prior to
their general release or manufacture.

5. FORMATION OF CHEMICAL MIXTURES AND BYPRODUCTS

The nature of industrial chemistry is messy. When you mix chemicals
under diverse industrial circumstances you inevitably produce new and
unexpected byproducts. Joe Thornton gives three examples of how we are
flying blind:

a) Paper manufacturing. The effluent from pulp mills contain over 300
organochlorine byproducts; including dioxins, furans, phenols,
benzenes, thiophenes, methyl-sulfones, methanes, ethanes, acids and
PCBs. We have only identified 3 to 10% of the organically bound
chlorine in pulp effluent. In other words, we are 90-97% ignorant of
what is coming out of the pipe.

b) Incineration. Incinerator emissions are estimated to contain over
1,000 products of incomplete combustion (complete combustion would
reduce the fuel to carbon dioxide and water). Yet we have identified
only 40-60% of these chemical effluents.

c) Pesticide manufacture. Byproducts account for almost 20% of DDT
manufacture by weight. Many of these byproducts have never even been
identified.

We don't know the names, structures or toxicity of many of the
chemical byproducts formed in industrial processes. Even though we
phased out purposeful manufacture of PCBs they -- and dioxins, an
unwanted byproduct -- are still being introduced into the environment
as side-effects of chlorine chemistry. To prevent global contamination
with dioxin, we would need to phase out the whole class of
organochlorines.

6. POLLUTION CONTROL AND DISPOSAL

End-of-pipe pollution control and disposal technologies do little to
prevent global environmental contamination. If you manufacture a
substance that breaks down slowly and tends to accumulate in living
things, it will eventually spread throughout the living world.
Scrubbers, filters, precipitators, incinerators, and landfills are all
just ways of temporarily moving a substance from one location or form
to another (a shell-game). In the end, everything that persists will
disperse into the air, water, land and living things and people will
be affected. Landfills leak, incinerators generate toxic ash and gas,
and even the best pollution controls are never 100% effective.

Thornton helps us realize that we are foolish to try to control
chemicals with the end-of-the-pipe risk-assessment approach. Instead,
we can use the precautionary principle and acknowledge that:

a) Some chemicals don't belong in the environment (zero discharge) and
are best regulated away as entire classes of compounds;

b) With the right combination of carrots and sticks as motivation,
industry can find clean technologies (clean production); and

c) The burden of proof (aka "reverse onus") can be placed on the
industries that want to introduce new chemicals -- to show that they
have done their best to understand the consequences of their actions
-- thus motivating them to innovate and develop clean technologies.
No data? No market.

==========

* Tim Montague is Associate Director of Environmental Research
Foundation. He holds an M.S. degree in ecology from University of
Wisconsin-Madison and lives in Chicago.

[1] http://www.gsenet.org/library/11gsn/2005/gs050530.4.html

[2] See http://www.gsenet.org/library/11gsn/2005/gs050530.7.html and
http://www.gsenet.org/library/11gsn/2005/gs050420.13.html and
http://www.gsenet.org/library/11gsn/2003/gs030108.7.html and
http://www.gsenet.org/library/11gsn/2004/gs040302.13.html
http://www.gsenet.org/library/11gsn/2002/gs020730.7.html

[3] http://www.gsenet.org/library/11gsn/2003/gs030108.7.html

[4] See http://www.whitehouse.gov/omb/budget/fy2004/pma/newchemicals.xls
and http://archive.gao.gov/t2pbat3/151661.pdf

[5] Joe Thornton, "Beyond Risk: An Ecological Paradigm to Prevent
Global Chemical Pollution" INTERNATIONAL JOURNAL OF OCCUPATIONAL AND
ENVIRONMENTAL HEALTH Vol. 6 (2000) pgs. 318-330. Available at
http://www.rachel.org/library/getfile.cfm?ID=536 And see Rachel's
#704, which reviews Thornton's book, Pandora's Poison.

[6] International Joint Commission. FIFTH BIENNIAL REPORT ON GREAT
LAKES WATER QUALITY. Windsor, ON, Canada, 1990. Available here:
http://www.ijc.org/php/publications/pdf/ID603.pdf

[7] Mary O'Brien, MAKING BETTER ENVIRONMENTAL DECISIONS; AN ALTERNATIVE TO
RISK ASSESSMENT (Cambridge, Mass.: MIT Press, 2000).  ISBN: 0262650533

^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^

RACHEL'S ENVIRONMENT & HEALTH NEWS
Environmental Research Foundation
P.O. Box 160
New Brunswick, N.J.  08903
Fax (732) 791-4603; E-mail: erf@rachel.org

SUBSCRIPTIONS

Subscriptions are free. To subscribe, send E-mail to
listserv@lists.rachel.org with the words
SUBSCRIBE RACHEL-NEWS YOUR FULL NAME in the message.

SPANISH EDITION

The Rachel newsletter is also available in Spanish; to learn how to
subscribe in Spanish, send the word AYUDA in an E-mail message to
info@rachel.org.

BACK ISSUES IN ENGLISH AND SPANISH

All back issues are on the web at: http://www.rachel.org in text and
PDF formats.

COPYRIGHT NOTICE

Permission to reprint Rachel's is hereby granted to everyone, though
we ask that you not change the contents and we ask that you provide
proper attribution.

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.

Some of this material may be copyrighted by others. We believe we are
making "fair use" of the material under Title 17, but if you choose to
use it for your own purposes, you will need to consider "fair use" in
your own case.  --Peter Montague, editor

^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^

Gary N. Greenberg, MD MPH    Sysop / Moderator Occ-Env-Med-L MailList
GNGreenberg@gmail.com                       http://occhealthnews.net

Recent change (4/05): Only mail addressed to
OCC-ENV-MED-L@MC.DUKE.EDU will be broadcast to the forum. Please update your
addressbooks.
*************************************************************

Rich Murray, MA  Room For All  rmforall@comcast.net  505-501-2298
1943 Otowi Road    Santa Fe, New Mexico 87505   USA
http://groups.yahoo.com/group/aspartameNM/messages
group with 185 members, 1,177 posts in a public, searchable archive

http://groups.yahoo.com/group/aspartameNM/message/1165
short review: research on aspartame (methanol, formaldehyde, formic acid)
toxicity: Murray 2005.06.23 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1071
research on aspartame (methanol, formaldehyde, formic acid) toxicity: Murray
2004.04.29 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1143
methanol (formaldehyde, formic acid) disposition: Bouchard M et al, full
plain text, 2001: substantial sources are degradation of fruit pectins,
liquors, aspartame, smoke: Murray 2005.04.02 rmforall

Fully 11% of aspartame is methanol--  1,120 mg aspartame  in 2 L diet soda,
almost six 12-oz cans,  gives 123 mg methanol (wood alcohol).   If 30% of
the methanol is turned into formaldehyde, the amount of formaldehyde is 18
times the USA EPA limit for daily formaldehyde in drinking water, 2 mg in 2
L water.

http://groups.yahoo.com/group/aspartameNM/message/1164
artificial sweetener sales soar, stevia and tagatose available: Murray
2005.03.31 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1152
reply to Ferne Hudson, Tate & Lyle PLC, re Splenda (sucralose) policy:
Murray 2005.02.08 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1122
UN FAO & WHO approve Steviol glycosides as sweetener June 2004,
imports to UK no longer blocked: Martini: Murray 2004.10.17 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1084
26 stevia safety abstracts since 1993: aspartame vs stevia debate on
alt.support.diabetes, George Schmidt, OD: Murray 2004.05.25 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1131
genotoxicity of aspartame in human lymphocytes 2004.07.29 full plain text,
Rencuzogullari E et al, Cukurova University, Adana, Turkey 2004 Aug: Murray
2004.11.06 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1088
Murray, full plain text & critique: chronic aspartame in rats affects
memory, brain cholinergic receptors, and brain chemistry, Christian B,
McConnaughey M et al, 2004 May: 2004.06.05 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1067
eyelid contact dermatitis by formaldehyde from aspartame, AM Hill & DV
Belsito, Nov 2003: Murray 2004.03.30 rmforall

http://groups.yahoo.com/group/aspartameNM/message/1155
continuing aspartame debate in British Medical Journal, John Biffra, Bob
Dowling, Nick Finer, Ian J Gordon: Murray 2005.02.09 rmforall
*************************************************************