Environmental Justice | Why living in USA is increasingly hazardous to health
Moderator’s Note: One of the hallmarks of neoliberalism is the
dismantling of the so-called regulatory state. Abolishing rules that protect
health and the environment is one of the targets of neoliberal deregulation.
There are some states where the threats posed to public health and the
environment by pollution and toxins are by far greater. Texas and West Virginia
come to mind as places where recent industrial accidents illustrate how
deregulation creates an even more hazardous set of conditions that increase
risk for all communities and especially the most vulnerable (typically,
low-income or people of color).
On January 10, at a West Virginia tank farm owned by a corporation known
as Freedom
Industries, a 48,000-gallon tank began leaking 4-Methylcyclohexane
Methanol, or MCHM, a compound used to wash coal of impurities. The leak spilled
into the Elk River upstream from Charlestown, W.Wa and has so far left 300,000
people without safe drinking water supplies.
As I monitored this incident, it turned out that the chemical MCHM
has never been thoroughly studied and we actually know very little about
its toxicity. While the Environmental
Protection Agency’s classification system lists MCHM on the Tier II
reporting form, reserved for “hazardous” materials under the Toxic Substances
Control Act (TSCA). However, the state
agencies in West Virginia did not have a plan for emergency response in the
event of an accident and the public was not even informed that the chemicals
were stored at this faculty, within yards of the drinking supply for hundreds
of thousands.
There are roughly 75,000 hazardous chemicals used by industrial and
manufacturing processes in the USA today. Serious scientific study of the
health and environmental effects of these substances is pathetically lacking: Less
than 1 percent of these agents have been thoroughly studied. In other word,
we are ignorant of the toxic environment we are being forced to live in under
neoliberal capitalism.
For this reason, I am posting an insightful critical analysis of our
“toxic ignorance” prepared by twp reputable scientists who are experts in
toxicology and epidemiology. The report by Estabrook and Tickner was originally
released in 2012 and it reveals that instead of being over-regulated,
industries are largely unregulated and there is very little enforcement of weak
laws. The principal legislation that local governments and citizens should be
able to rely on – Toxic Control, Substances Act – is woefully dated and
inadequate. Regardless of the statutory limits, there is little money invested
in hiring the inspectors we need to monitor these hazardous substances and the
industries that produce or utilize them.
I wish to acknowledge and thank the Massachusetts Precautionary
Principle Project for making this report available for free distribution. For
more information on environmental risks and the precautionary principle, please
visit the Sustainable Production
home page.
Facing Our
Toxic Ignorance
Tom Estabrook, Ph.D. and Joel Tickner, Sc.D.
Our dilemma is like that of a plane hurtling through
the fog without a map or instruments.
Colburn, et al., Our Stolen Future (1996)
Most people believe that government agencies are protecting their health
and environment from the effects of toxic chemicals. They believe that somebody
is testing these chemicals for adverse effects before they come on the market and
regularly thereafter. Nothing could be farther from the truth.
Recent studies of our level of knowledge of chemicals’ toxicity and
impacts on public health and the environment demonstrate that we know very
little about most industrial chemicals and pesticides in commercial use today.
We are flying blind. Despite our lack of information about these substances,
every day government agencies and others make decisions permitting their use
and release into the workplace and environment based on the belief of an
acceptable risk and a minimal impact. We are generally deciding that these
substances are innocent until proven guilty.
There are at least 75,000 chemicals in commerce today. Roughly 1,000 new
chemicals are put on the market each year. Almost none of the 75,000 chemicals
have been adequately analyzed for their full impact on the environment and
human health, and most have not even received basic toxicological testing.
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Ignorance of Complex Chemical Mixtures
We are ignorant of the real world of complex mixtures of chemicals. We
tend to think in linear terms; we look for direct cause and effect relations
between exposures to single chemicals and single diseases. This atomized
thinking ignores the complex interactions of multiple chemicals and is incapable
of predicting real world health outcomes. Current health research generally
includes laboratory tests involving animals that typically consider the effects
of exposure to only one chemical substance at a time. This is because
scientists frame hypotheses (questions asked) in ways that are feasible to
answer with the time and resources available. But unlike the animals used in
the laboratory, humans are exposed by many routes to multiple chemicals (and
other compounding stressors), at work, home, in the womb, and elsewhere.
Scientific studies have found that exposure to multiple chemicals can
have additive or synergistic effects in humans, and a few recent studies have
begun to assess these combined effects. Studies have indicated that
combinations of chemicals – for example the plasticizer diethyl hexyl phthalate
widely used in vinyl products combined with other common toxicants (e.g., the
solvent trichloroethylene or the pesticide heptachlor) – are much more
powerful, and potentially damaging, than single chemicals alone (1). Long-term
exposure to multiple chemicals can have cumulative effects and may affect the
susceptibility of humans to diseases in ways that are not well-understood. In
addition, virtually nothing is known about the cumulative impacts of chemicals
combined with other stressors such as diet, poverty, physical stress, etc.
Using current methods, laboratory tests for additive, synergistic, and
cumulative effects, however, are impractical because of the high costs in time
and money that would be required. Testing just one dose of just the top 1,000
high volume chemicals in three-way combinations would require 166 million
different experiments. Testing all the three-way combinations would take over
180 years to complete, if each experiment took one hour to conduct and 100
laboratories worked non-stop (2).
Lack of Testing
Not only are current scientific methods not well-suited to studying the
safety of combinations of chemicals, the chemical-by-chemical testing we do
perform is woefully inadequate in relation to the real world. Most chemicals in
commerce have not been lab tested. Nor have they been the focus of an
epidemiological study to look for evidence of harmful effects in humans. How
many of the 75,000 chemicals in commerce have actually been tested for their
toxicity?
The Environmental Defense Fund (now called Environmental Defense)
analyzed a sample of 100 chemicals out of a total number of 3,000 high
production volume (HPV) chemicals (chemicals that are produced in quantities of
1 million pounds or more per year). The 1997 EDF report (3) found the
following:
• For 71% of the HPV chemicals we do not have in
the public record even the simplest health and safety facts. This means that
only 29% of high-volume chemicals had basic health hazard screening data, as
established by the Organization for Economic Cooperation and Development. The
OECD’s basic health screening data, or Screening Information Data Set or SIDS,
consists of the following required tests: acute toxicity; chronic toxicity;
developmental and reproductive toxicity; mutagenicity; ecotoxicity; and
environmental fate. The 71% figure from 1997 indicated virtually no improvement
over a 1984 National Research Council study of a sample of 100 of the 3,000 HPV
chemicals, where 78% of the chemicals lacked even “minimal toxicity
information.”
• Of the sampled chemicals known to be released
into the environment — the Toxic Release Inventory chemicals — 51% are not even
minimally screened for health hazards. This means that even for chemicals which
have at least one recognized health hazard, we generally don’t know if they
have other health hazards because they have not been adequately screened.
• Carcinogenicity tests are missing for 63% of
HPV chemicals.
• Reproductive toxicity tests are missing for 53%
of HPV chemicals.
• Neurotoxicity tests are missing for 67% of HPV
chemicals.
• Immune system toxicity tests are missing for
86% of HPV chemicals.
• Studies for assessing impacts on children have
not been done for more than 90% of HPV chemicals.
• 58% of the sampled HPV chemicals have not been
tested for any form of chronic toxicity.
The Chemical Manufacturers Association (CMA), now called the American
Chemistry Council, the main chemical industry trade association, acting on a
challenge from EDF to conduct its own screening tests and make them available
to the public, analyzed the same sample of HPV chemicals. The CMA found that
47% of the same 100 chemicals had a full screening set. While more optimistic
than EDF’s finding of 29%, this figure still confirms that less than half of
chemicals have even the minimum screening tests (see 4). Thus even the chemical
industry admits that it is flying blind.
The EPA analyzed a much larger sample (2,863) from the 3,000 HPV
chemicals. They found that only 7% had a full screening set, while 43% lacked
even basic screening data (4).
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| Available toxicity studies by type of health risk |
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| Number of Available Toxicity Screening Tests for HPV Chemicals |
It is important to note that all three studies looked only at screening
level data, which is just the minimum data set that government agencies around
the world suggest that we should have on chemical toxicity. Even less is known
about actual human exposures or toxicity beyond the basic screening tests.
While EPA has urged U.S. chemical companies to carry out these tests,
EPA’s testing program, like the OECD SIDS international testing program, has
thus far been voluntary. This program, called the HPV Challenge, encourages industry
to develop the minimum SIDS data for the approximately 3,000 HPV chemicals by
the year 2004. While industry balked at such an ambitious timeline (stating
that they needed to do an assessment of which data is needed for each
chemical), EPA has threatened the issuance of testing rules under the Toxic
Substances Control Act if industry does not comply. At any rate, EPA is only
beginning to determine what it will do once it collects these data.
Because of the general lack of toxicity testing, it is impossible for
the public to know what health threats these high-use chemicals might pose or
whether they are under control. It is not surprising that we are unable to test
the toxicity of 75,000 chemicals, or even those chemicals most widely used in
commerce. The task is overwhelming. But this task is minute in comparison to
the job of assessing the toxicity of chemical combinations.
Toxicity testing of pesticides, like testing for chemicals used in
manufacturing and commerce, is seriously lacking. Adequate toxicological data
are available for only about 17%, or 100 out of 600, active pesticide
ingredients (5). Data are often lacking on reproductive and developmental
toxicity of pesticide ingredients. The registration process focuses on
individual chemicals and has tended to ignore the health and ecological effects
of combinations of chemicals, although the Food Quality Protection Act of 1996
discussed a margin of safety required for anticipated or known multiple
chemical exposures which act through similar mechanisms.
Testing Methods: The Limits of Environmental Health Research
Environmental health research attempts to estimate the toxicity and
health impacts of different substances. Research about the toxicity of chronic
hazards is based on human studies, animal studies, and in some cases, studies
on isolated cells or tissues. Studies of cells in the laboratory, in-vitro
studies, are not described further here, but can provide useful early
information to spark precautionary action as they are inexpensive and quick.
For example, if a chemical is estrogenic in the test tube - an easy test to
complete - it may be prudent to restrict its use.
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Human Studies
Human evidence is the preferred choice in providing information about
toxicity because it looks at actual patterns of exposure and observed effects
on people. The field of epidemiology focuses on the factors – including
chemical exposures – that contribute to diseases in various groups of people.
Epidemiologists identify an exposed group of people, another group that was not
exposed, and compare their rates of illness. After taking additional factors
(such as family history or smoking) into account, these studies can provide
evidence that a chemical exposure increases the risk of disease.
Doing epidemiological studies, however, involves several major problems:
• Getting long-term information about an
individual’s exposures and medical history is very difficult and the data are
often unreliable. For example, following a large group of children throughout
their lives to search for evidence of disease from a prenatal or infant
exposure is obviously a very slow and costly process. Often the best
epidemiological information comes from studies of hazardous chemicals in the
workplace, where records are sometimes available. But these conditions may not
be directly relevant to understanding risks in the general environment. In
addition, occupational health studies have often focused on healthy adult
males, and there is less known about the hazards for woman. Workplace health
studies are even less useful for understanding children’s health risks.
• Studies based on workplace exposures don’t
always translate well to home and community settings because of different
levels and duration of exposures. Workplace exposures are generally higher,
while the range of health effects studied may be narrower than one would wish,
to understand the entire community (6).
Field environmental health research also has numerous potential sources
of error, including:
• Uncertainty. Uncertainty exists about: the
pathways and levels of exposure; the mechanisms by which exposure leads to
disease (this information is needed so that the appropriate statistical models
can be used); the diagnosis of the disease being studied and about other
stressors that may contribute to the disease (confounding factors).
• Too small a sample size. Field studies are
often limited by economic or logistical reasons to relatively small samples of
the population. This means the study may not have the statistical “power” to
detect an effect even if it does exist. To reach a conclusion with confidence
that the results are not due simply to chance, you need a large enough
population size (7).
Often inconclusive results from epidemiologic studies are mistakenly
interpreted as evidence that a chemical is safe. This is a common confusion
about the meaning of “negative results”. One should always ask: “Do the results
reflect a lack of evidence that an effect exists, or instead do they represent
evidence that an effect does not exist?” In the former case, the study is
inconclusive and one cannot say whether the exposure is hazardous or not. In
the latter case, which is much less common for all the reasons noted above, the
study actually does suggest that the exposure does not cause the disease being
studied.
Eminent biologist John Cairns Jr. has described this problem as “absence
of certainty is not synonymous with absence of risk.” He states: “while high
uncertainty may obscure both the probability of a risk and the magnitude of
harm, uncertainty does not eliminate risk. Unrecognized risks are still risks;
uncertain risks are still risks; and denied risks are still risks (8).”
Animal Studies
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Scientists and decision-makers most often rely on laboratory tests on live
animals (called in vivo tests) to determine human risks. Such tests can be
completed relatively quickly and in controlled circumstances. Animal tests can
be used to predict potential human effects by making two important
extrapolations:
• Extrapolating from high dose to low dose
exposures. In in-vivo tests, higher doses are generally given to animals than
humans would normally receive. By making as much as 50% of the exposed animals
ill, rather than giving low doses to large samples of test animals, scientists
reduce costs and time needed to conduct studies.
• Extrapolating from test animals to humans.
Scientists use models based on the dose-response relationship to extrapolate
the responses (such as tumors) from test animals to humans. In general, as the
exposure (the amount of a substance in your immediate environment) increases,
dose (the amount of a substance you actually absorb into your system)
increases. The dose-response relationship does not accurately describe the
health impacts of highly toxic chemicals like endocrine disrupting substances
such as PCBs, dioxins, bisphenol-a and a wide range of pesticides (9).
These two extrapolations from animal studies create several important
problems:
• Thresholds. Extrapolating from high doses to
low doses has fueled a major debate about whether there are thresholds below
which there are no harmful effects from a substance. Many scientists believe
that effects like cancer and some developmental effects have no threshold, ie.,
there is no “safe” level of exposure. Many dose-response models assume
thresholds, known as no observed effect levels (NOELs); above these levels one
should avoid exposure, while below it is believed there is no reason to suspect
harm. For substances without thresholds, we must assume that any exposure might
be harmful.
• Animal differences. Extrapolating from test
animals to humans is problematic because of a wide range of differences between
test animals and humans, including body weight and size, life span, and
metabolism. Until we better understand the causes of cancer and other diseases,
it is very difficult to account for the differences between animals and humans.
Even among test animals, responses to chemicals vary (6). It is generally
assumed, however, that effects observed in laboratory animals are relevant to
humans unless demonstrated otherwise. Nonetheless, industry and government are
placing a greater emphasis on demonstrating that the “mechanisms of action”,
the biological pathway by which a chemical causes disease, are comparable in
test animals and humans. This will place an added burden on government agencies
and citizens to “prove” harm before action takes place.
Why Environmental Health Research is Limited
Environmental health research is limited in determining the effect of a
broad range of industrial toxicants on the general human population for the
following reasons:
1. There are too many chemicals in commercial use.
Science cannot keep up with the introduction of 1,000 new substances to the
market each year and the 70,000 plus chemicals in commerce. New chemicals that
have come on the market since 1980 represent less than 1% by volume of all
chemicals on the market today.
2. Environmental health research fails to account
for multiple and variable exposures. Health research depends on laboratory
tests on animals, in which only one or two variables at a time are tested.
Humans, on the other hand, are subject to multiple pathways of exposure and to
many chemicals, some at work, some at home, some outside from air and water.
Exposures to multiple chemicals can have interactive and cumulative effects. To
a certain degree toxicological tests are able to assess the combined effects of
exposure to multiple chemicals, but these tests are expensive and would take
too much time to conduct.
3. Environmental health research is narrowly
focused on the cancer paradigm. Normally, we test a single chemical for its
ability to cause cancer or acute effects. Although it is widely understood that
there are other types of toxic insult to living organisms (such as damage to an
organism’s hormone system, toxicity to an organism’s development,
neurotoxicity, or damage to ecosystems), there are few established ways for
testing how or if a chemical causes these disruptions (7).
By focusing largely on the cancer paradigm, environmental health
research tends to miss the long-term reproductive or developmental toxicity of
low-dose human exposures, which may affect human development from the fetal
stage through the reproductive years. Environmental health research is only
beginning to help us understand the importance of timing of exposures (e.g., in
the womb) but even these effects are difficult to follow in humans because
exposure in the womb may not result in health effects until several decades
later (9).
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The cancer paradigm also looks for signs of disease as a result of toxic
exposures, whereas many chemicals, such as endocrine disrupting chemicals, can
damage people without making them outwardly sick. PCBs, for instance, can
diminish a person’s short-term memory or attention span. While it is widely
recognized that there are other hazards, we have few settled methods for
testing how, or even whether, a chemical causes other types of toxicity. Our
narrow focus on the cancer paradigm is relevant both to toxicological and
epidemiological testing and critical to why we are ignorant about health
effects of chemical exposure. The cancer paradigm prevents us from looking for
other effects and potential root causes. Fortunately, studies on neurotoxicity
and reproductive toxicity are beginning to take us beyond the cancer paradigm
to look at other effects and potential causes (7).
4. Environmental health research misses the wide
differences in individual reactions. These differences may be due to gender,
age, genetic variations in affected groups of people, and differences in
socio-economic status. It also generally fails to account for susceptible
sub-populations, children, the fetus, the elderly, and the ill.
The limits and potential errors inherent in environmental health
research — which generally relies on mathematical techniques for one or two
chemicals — all point to the fact that we can rarely statistically draw a
direct causal connection between specific health and environmental impacts and
real chemical exposures in the environment, especially in an environment with
complex chemical mixtures. In order to protect people from hazardous exposures,
we cannot wait for high levels of statistical significance before taking action.
Regulatory Tools That Keep Us Ignorant
Lack of basic toxicity testing of chemicals greatly contributes to our
ignorance about chemical toxicity and health effects. But lack of toxicity
testing is not the only problem. Other factors contribute to our ignorance of
health and environmental hazards of commercial chemicals (see 10):
• Government regulations focus on single
chemicals and effects on single media rather than chemical mixtures and
exposures through multiple pathways such as air, water, and food. Environmental
health research, with its basic practice of toxicity testing, is currently
limited to assessing each chemical by itself rather than assessing complex
mixtures of chemicals, as they are found in reality. Current regulations
reinforce the limits of environmental health research by focusing on single
chemicals while ignoring their additive and interactive effects.
• Government regulations focus on one source of
exposure rather than cumulative exposures. Current laws and regulations encourage
regulators to consider only one avenue of exposure at a time rather than
cumulative exposures from air, water, food, and other sources. Exposure from
any single source may be tolerable, while the total from all sources may be
unsafe. While government agencies are beginning to look more closely at
cumulative effects, greater consideration is not likely to occur for some time.
• Trade secrets regulations. Provisions in laws
keep citizens in the dark on chemical components of many industrial and consumer
products.
• Shift of burden of proof from industry to
government. The current industrial chemical testing system has failed to
adequately test even the most commonly used chemicals for basic health effects.
This failure has shifted to government the burden of demonstrating that
existing chemicals will pose an unreasonable risk. In testing food (for
pesticide residues) and other consumer products, the government simply does not
have money or staff to do adequate testing.
• Toxic Release Inventory (TRI) is applied too
narrowly. Created by the Emergency Planning and Community Right to Know Act,
the Toxic Release Inventory requires manufacturers to let the public know about
chemicals transferred or released to the environment. The TRI currently considers
only releases during manufacturing, while ignoring the intentional release of
chemicals from or through products, such as pesticides, detergents, and
plastics.
• Loopholes in Federal environmental laws.
Loopholes, particularly in the Toxic Substances Control Act (TSCA), rob the EPA
of its ability to take action on problematic chemicals.
The Failure of TSCA
The Toxic Substances Control Act is responsible for the failure to
assure safety for the thousands of chemicals used and released into the environment.
TSCA created authority for EPA to require chemical testing and set controls
(including bans) as necessary. TSCA has failed to uphold chemical safety
largely because its legal structure is self-defeating and because EPA has
failed to carry out the law’s provisions, although the agency’s enforcement has
improved in recent years. There are two major problems with the law itself
(11):
• The law fails to require companies to test
chemicals that are in use. TSCA Section 4 states that EPA can issue “test rules”
(rules for toxicity testing), but it places the agency in an impossible
situation: EPA must have toxicity data before it can require toxicity data.
That is, before EPA can issue a “test rule” on a chemical, it must first
demonstrate the following conditions: either (1) that the chemical may pose an “unreasonable
risk”or (2) both that is produced in major amounts AND that “substantial”
exposures are happening in quantitative terms (either number of people exposed
or amount of material released) or that “significant” exposures are happening
in qualitative terms (a case-by-case analysis of the effects of exposure). Thus
information on releases, exposures, and toxicity is necessary in order to prove
“substantial” and “significant,” though the “may” burden could allow the agency
to be more aggressive if it chose to be so. EPA must also demonstrate that
existing data are insufficient and that testing is necessary before it can
issue a “test rule.” The result of these loopholes is that corporations successfully
challenge EPA in court, restricting EPA’s ability to issue test rules. Indeed,
EPA issued “testing actions” for only 263 chemicals over a 20 year period, when
20,000 new chemicals came onto the market.
• EPA must prove “unreasonable risk” to health or
the environment, in order to take action to restrict a chemical in commerce,
which undermines the agency’s authority. TSCA Section 6 gives EPA the general
authority to control any chemical that will pose “unreasonable risk of injury
to health or the environment.” This authority can range from a labeling
requirement to an outright ban. Of course, the need to prove “unreasonable risk”
undercuts the agency’s position because, in reality, EPA does not have the
resources to provide enough information to prove “unreasonable risk” in court
when challenged by corporate power. In 20 years of TSCA, EPA took action under
Section 6 against only five chemicals or chemical classes. In one clear case,
EPA attempted to ban asbestos after studying its well-known effects for 10
years. When challenged by industry, a court in Louisiana found that EPA had not
demonstrated a “significant risk”.
This flawed law seriously undermines the government’s ability to ensure
effective testing of chemicals already in use, or to restrict use of injurious
or deadly chemicals.
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Image credit: earthtimes |
Acting on Toxic Ignorance: The Need for the Precautionary Principle
Lack of basic testing and flaws in the government’s ability to regulate
chemical use and testing show that government agencies must do much more to
protect workers, the public, and the environment. Left to itself, industry will
not conduct even basic toxicity testing. This leaves a near impossible task up
to government.
In order to counteract our toxic ignorance we need to learn more while
taking action now, based on what we already know. But we need more than just
better information. While toxicological testing and information on human
exposure to chemicals are necessary, we also need a new approach to chemical
regulation that is based on the notion of precaution and prevention.
In Our Stolen Future, Colburn,
Myers, and Dumanoski propose the following actions to resolve the monumental
problem of tracking and testing 75,000 plus chemicals and their combinations
(10):
• Reduce the number of chemicals. This entails
significantly reducing not only the number of chemicals on the market, but also
the number of chemicals used in products. Products should be made simpler.
• Make only chemicals which are detectable, have
a well-defined content, and whose degradation in the environment is well
understood. Make and market only chemicals that can be readily detected in the
real world with current technology. Restrict production to only products that
have a completely defined chemical makeup and stop production of products
containing unpredictable mixtures of chemicals. Do not produce a chemical
unless we know well how it degrades in the environment.
• Shift the burden of proof of safety onto
chemical manufacturers. Our current approach assumes that chemicals are
innocent until proven guilty, which is completely wrong.
• Redefine risk assessment. The tool of risk
assessment is now used to keep questionable compounds on the market until they
are proven guilty. It should be redefined as a means of keeping untested
chemicals off the market and eliminating the most worrisome ones in a timely
fashion.
Understanding the impossibility of calculating risks for all of the
chemicals in commence, countries such as Sweden and Denmark have initiated bold
proposals to address chemicals based on their inherent characteristics. For
example, the Swedes have proposed phasing out over the next 20 years chemicals
that are persistent or bioaccumulative, are carcinogenic, reproductive
toxicants, neurotoxicants, or developmental toxicants. Further both Denmark and
Sweden understand that a way to reduce the hazards of chemicals is by reducing
exposure. In this regard, they are focusing on implementing a goal of zero
chemical emissions by 2025.
All actions to resolve our problem of tracking and testing chemicals
should be guided by applying the Precautionary Principle. Implementing the
Precautionary Principle means:
• Taking action in the face of uncertainty
• Shifting burdens onto those who create risks
• Considering alternatives to potentially harmful
activities
• Using democratic decision-making processes that
include those who might be affected
We must use precaution, based on what we do know, don’t know, and can
know, to confront our ignorance about the toxicity and health effects of 75,000
chemicals. While testing should continue, we cannot rely on it to provide
conclusive evidence about a chemical’s guilt or innocence. Because we have so
few testing resources and there are so many chemicals, we can never hope to get
ahead of the testing curve. Precaution is the only meaningful course of action.
References
1. M. Narotsky et.al. 1995. “Non-additive developmental toxicity in
mixtures of trichloroethylene, di(2-ethylhexyl) phthalate and heptachlor in a 5x5x5
design,” Fundamental and Applied Toxicology, 27: 203-216; E.J. Ritter et.al.
1987. “Teratogenicity of di(2-ethylhexyl) phthalate, 2-ethylhexanol,
2-ethylhexanoic acid, and valproic acid, and poetntiation by caffeine,”
Teratology, 35: 41-46.
2. Peter Montague. 1996. “Dangers of chemical combinations.” Rachel’s
Environmental Health Weekly, #498, June 13.
3. Environmental Defense Fund. 1997. Toxic Ignorance: The Continuing
Absence of Basic Health Testing for Top-Selling Chemicals in the United States.
4. U.S. Environmental Protection Agency. 1998. Chemical Hazard Data
Availability Study: What do we really know about the safety of high production
volume chemicals.
5. D.D. Weisenburger. 1993. “Human health effects of agrichemical use,”
Human Pathology, 24(6), pp. 571-576.
6. Daniel Fiorino. 1995. Making Environmental Policy. Berkeley:
University of California Press.
7. Katherine Barrett and Carolyn Raffensperger. 1999. “Precautionary
science,” in Carolyn Raffensperger and Joel Tickner (eds.). Protecting Public
Health and the Environment: Implementing the Precautionary Principle.
Washington, DC: Island Press. p. 111.
8. John Cairns, Jr. 1999. Absence of Certainty is not Synonymous with
Absence of Risk. Environmental Health Perspectives 107(2), pp. A56-57.
9. Greater Boston Physicians for Social Responsibility and Massachusetts
Public Interest Research Group. 1996. Generations at Risk: How Environmental
Toxins May Affect Reproductive Health in Massachusetts. Cambridge, MA.
10. Theo Colburn, Dianne Dumanoski, and John P. Myers. 1996. Our Stolen
Future. New York: Plume-Penguin, p. 207.
11. Peter Montague. 1997. “The Toxic Substances Control Act,” Rachel’s
Environment and Health Weekly, #564, Sept. 18.
Massachusetts Precautionary Principle Partners Contact Information
Clean Water Fund
36 Bromfield Street #204
Boston, MA 02108
Tel. 617-338-8131 Fax 617-338-6449
Email: bostoncwa@cleanwater.org
Lowell Center for Sustainable Production
University of Massachusetts Lowell
One University Avenue
Lowell, MA 01854
Tel. 978-934-2981 Fax 978-452-5711
Email: joel_tickner@uml.edu
Massachusetts Breast Cancer Coalition
51 Diauto Drive, Suite B
Randolph, MA 02368
Tel. 413-586-7395 (Sharon Koshar)
Email: koshar@javanet.com
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