[This article, with some of the footnotes removed, appeared in The Workbook [Southwest Research and Information Center, P.O. Box 4524, Albuquerque, NM 87106] Vol. 19, No. 2 (Summer, 1994), pgs. 86-90.]
Medical science has made impressive gains against acute disease this century, but during the past 20 years it has become obvious that chronic disease represents a much more difficult challenge. Throughout the industrialized world, many chronic diseases are steadily increasing. There is substantial and growing evidence that these increases are linked to widespread low-level chemical contamination of the environment. An aggressive new environmental movement has come into being to confront these human problems. Here is a brief, incomplete catalog:
This list is not exhaustive but indicates a sea of troubles rising, much of it linked to chemical contamination.
The grass-roots movement for environmental justice, which has come into being to confront these problems, has had many local victories. But its most far-reaching accomplishment has been to force a change in the way we think about controlling chemical contamination -- from managing pollution to preventing pollution. This is a very fundamental shift. Major polluters and their acolytes in government are now giving lip service to "pollution prevention" but almost no one in the U.S. has yet put it into practice to any significant degree. What is most important is that the new approach has been spelled out and is now available as a standard against which to measure any claims of pollution prevention.
As the American Chemical Society noted in 1993, [13] there are two basic philosophies of chemical regulation: for 20 years the U.S. has been using a permissive chemical-by-chemical approach, which assumes all chemicals are innocent until proven guilty, and which demands rigorous scientific proof of harm before regulation can occur. We call this the "prove harm" philosophy of chemical regulation. This philosophy assumes that every ecosystem and every species has some "assimilative capacity," some capacity to absorb harm without suffering irreversible damage. This philosophy assumes further that (a) scientists can discover the assimilative capacity of every ecosystem and every species ("risk assessment" is the technique that is supposed to accomplish this); that (b) regulators can and will then establish effective limits on the cumulative harmful activities so as to avoid irreversible damage; and that (c) we already know which substances are harmful and which are not; or, in the case of substances that we never suspected are harmful, we will be warned of their possible dangers by traumatic but sub-lethal shocks that alert us to the danger before it is too late. Recent history indicates clearly that all three of these assumptions are simply wrong.
Happily, an alternative philosophy of chemical regulation has developed in recent years in Europe and in some obscure corners of the U.S. government. These changes have been driven by growing citizen demands at the local level, world-wide.
The new philosophy -- which we call clean technology and others call clean production or industrial ecology -- has been articulated most succinctly in 2 reports from the International Joint Commission (IJC), the U.S.-and-Canadian governmental body in charge of water quality for the Great Lakes.
In its sixth (1992) and seventh (1994) biennial reports, the IJC has described and advocated a pollution-prevention approach commensurate with the size and nature of the problem. [14]
Basically, the clean technology approach regulates whole classes of chemicals instead of one chemical at a time. Given that some 60,000 chemicals are now produced in commercial quantities, with 500 to 1000 new ones introduced into commerce each year, regulating classes of chemicals is simpler and more manageable than the chemical-by-chemical one-at-a-time approach.
The IJC now recommends defining a class of chemicals called "persistent toxic substances," which should then be eliminated because they cannot be managed safely.
The IJC recommends that a persistent toxic substance be defined as any toxic chemical that bioaccumulates (accumulates in food chains), or any toxic chemical that has a half-life greater than eight weeks in any medium (water, air, sediment, soil, or living things). (The half-life is the time it takes for half of any substance to degrade and disappear once it has been released into the environment.) Toxic substances with either of these characteristics should be eliminated, the IJC says. [15]
The IJC takes its definition of a toxic substance from the 1978 Great Lakes Water Quality Agreement, which has been adopted by the federal government of the U.S. and Canada:
A toxic substance is anything that can "cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological or reproductive malfunctions or physical deformities in any organism, or its offspring, or which can become poisonous after concentrating in the food chain or in combination with other substances."
A substance bioaccumulates if its concentration increases as it moves through the food chain. For example, DDT may be found at one ppm (part per million) in fish and at 10 ppm in fish- eating birds. Thus DDT bioaccumulates. The IJC says any toxic substance that bioaccumulates should be eliminated.
A substance is defined as persistent if it has a half-life greater than 8 weeks in any medium (air, water, soil, sediment, or living things). As noted above, the "half life" of a substance is the time it takes for half of it to degrade and disappear. For example, DDT has a "half-life" of about 59 years in temperate climates; if a pound of DDT is released into soil today, half of it will still exist 59 years from now. After 10 half-lives only a small fraction of the original amount exists (1/1024), so 10 half-lives is the rule of thumb for how long a substance remains in the environment. By this measure, DDT remains in the environment for 590 years after it has been released. The IJC recommends that any persistent toxic substance be eliminated.
The IJC recommends that the U.S. and Canada adopt the principle of precautionary action. The precautionary principle says that, to avoid irreparable harm to the environment and to human health, precautionary action should be taken wherever it is acknowledged that a practice (or substance) could cause harm, even without conclusive scientific proof that it has caused harm or does cause harm, the practice (or emissions of the substance) should be prevented and eliminated. [16]
The IJC recommends that the U.S. and Canada adopt a "weight of the evidence" approach, not waiting for scientific certainty to be established but taking action to protect against toxics as soon as the "weight of the evidence" indicates the need for action. [17]
In recommending a "weight of the evidence" approach and in recommending the elimination of all persistent toxic substances, the IJC has turned away from risk assessment and numerical standards. [18] Today risk assessment and numerical standards form the backbone of the U.S. regulatory philosophy for controlling toxic substances. Numerical standards supposedly reflect the "assimilative capacity" of ecosystems, and humans. Risk assessment is the technique employed to establish numerical standards.
The principle of "reverse onus" says that chemicals should be considered guilty until proven innocent, not the other way around. Accordingly, the proponents of a chemical's production and use should bear responsibility for proving that a substance is not harmful to the environment or human health. Under the present system, society at large bears that responsibility and regulatory action cannot be taken until specific, widespread harm has been conclusively demonstrated and rigorously documented. The IJC says, "This principle [of reverse onus] should, in the Commission's view, be adopted for all human-made chemicals shown or reasonably suspected to be persistent and toxic, including those already manufactured or otherwise in commerce." [19]
In sum, the IJC said in 1992, "It is clear to us that persistent toxic substances have caused widespread injury to the environment and to human health. As a society we can no longer afford to tolerate their presence in our environment and in our bodies.... Hence, if a chemical or group of chemicals is persistent, toxic and bioaccumulative, we should immediately begin a process to eliminate it. Since it seems impossible to eliminate discharges of these chemicals through other means, a policy of banning or sunsetting their manufacture, distribution, storage, use and disposal appears to be the only alternative." [20] The IJC defines "sunsetting" as "a comprehensive process to restrict, phase out, and eventually ban the manufacture, generation, use and disposal of a persistent toxic substance." [21]
The IJC said, "Such a strategy should recognize that all persistent toxic substances are dangerous to the environment, deleterious to the human condition, and can no longer be tolerated in the ecosystem, whether or not unassailable scientific proof of acute or chronic damage is universally accepted.... Therefore the focus must be on preventing the generation of persistent toxic substances in the first place, rather than trying to control their use, release, and disposal after they are produced." [22]
Implementing the new philosophy of chemical control will
not be easy. Thanks to so-called "free trade" laws,
corporations are rapidly gaining new powers and new freedoms to
do as they please, to move anywhere where labor is cheap and
pollution laws are lax. Governments and democratic institutions
at all levels are being weakened. Nevertheless, for reasons
given earlier, the survival of the human species is now in
doubt; therefore we have no choice but to meet the challenge by
developing a world-wide grass-roots movement for environmental
justice, to confront the poisoners everywhere, to force them to
adopt a real pollution prevention philosophy backed by real
pollution prevention programs. I have no illusions that it will
be easy, but I also have no doubt that humanity is up to the
challenge.
                                                                    
--Peter Montague
We do not know what all of the effects of human exposure will be over many years. Future research will clarify whether low- level and long-term exposures, repeated exposures, or isolated short-term exposures at sensitive stages of fetal development are most critical. For the Commission, however, there is sufficient evidence now to infer a real risk of serious impacts in humans. Increasingly, human data support this conclusion.
The questions then become: what--if any--risks of injury are we as individuals and as a society willing to accept? How long can we afford to wait before we act? Why take any risks of having such potentially devastating results? In this vein, the Commission poses a number of other specific but very fundamental questions:
The implications of any of the above questions being answered in the affirmative are overwhelming. The implications of all of the above questions being answered in the affirmative are catastrophic, in terms of human suffering and the potential liability for that suffering and attendant health costs. Mounting evidence points to the latter possibility. Surely, there can be no more compelling self interest to force us to come to grips with this problem than the spectre of damaging the integrity of our own species and its entire environment.
Source of this quotation: International Joint Commission, Seventh Biennial Report on Great Lakes Water Quality (Washington, DC and Ottawa, Ontario: International Joint Commission, 1994), pg. 5. This report is available free from the International Joint Commission, 1250 23rd Street, N.W., Suite 100, Washington, DC 20440; telephone: (202) 736-9000.
[1] See Barry A. Miller and others, editors, Cancer Statistics
Review 1973-1989 [National Institutes of Health Publication No.
92-2789] (Bethesda, Md.: National Cancer Institute, 1992). And:
Devra Lee Davis and Joel Schwartz, "Trends in Cancer Mortality:
US White Males and Females, 1968-83," The Lancet Vol. I (March
19, 1988), pgs. 633-636. And: Devra Lee Davis, David Hoel, John
Fox, and Alan Lopez, "International Trends in Cancer Mortality
in France, West Germany, Italy, Japan, England and Wales, and
the USA," The Lancet Vol 366, No. 8713 (August 25, 1990), pgs.
474- 481. And: Devra Lee Davis and David Hoel, editors, Trends
in Cancer Mortality in Industrial Countries (New York: New York
Academy of Sciences, 1990). For a discussion, see Tim
Beardsley, "A War Not Won--Trends in Cancer Epidemiology,"
Scientific American Vol. 270 (January 1994), pgs. 130-138. And,
finally, see Devra Davis and others, "Decreasing Cardiovascular
Disease and Increasing Cancer Among Whites in the United States
From 1973 Through 1987," Journal of the American Medical
Association Vol. 271 (February 9, 1994), pgs. 431-437.
[2] Larry D. Edmonds and Levy M. James, "Temporal Trends in the
Prevalence of Congenital Malformations at Birth Based on the
Birth Defects Monitoring Program, United States, 1979-1987,"
MMWR [Morbidity and Mortality Weekly Report] CDC [Centers For
Disease Control] Surveillance Summaries Vol. 39 No. SS-4
(December, 1990), pgs. 19-23. Increasing birth defects in male
genitalia are discussed in A. Giwercman and N.E. Skakkebaek,
"The human testis--an organ at risk?" International Journal of
Andrology Vol. 15 (1992), pgs. 373-175. And see: Richard M.
Sharpe and Niels E. Skakkebaek, "Are oestrogens involved in
falling sperm counts and disorders of the male reproductive
tract?" The Lancet Vol. 341 (May 29, 1993), pgs. 1392-1395.
[3] Increasing infertility among Americans in their prime
reproductive years is discussed in Appendix A, "Reproductive
Dysfunction in the Population," pgs. 341-346, in Office of
Technology Assessment, Reproductive Health Hazards in the
Workplace [OTA-BA-266] (Washington, D.C.: U.S. Government
Printing Office, December, 1985).
[4] Elisabeth Carlsen and others, "Evidence for decreasing
quality of semen during past 50 years," British Medical Journal
Vol. 305 (1992), pgs. 609-613. And see: Richard M. Sharpe and
Niels E. Skakkebaek, "Are oestrogens involved in falling sperm
counts and disorders of the male reproductive tract?" The Lancet
Vol. 341 (May 29, 1993), pgs. 1392-1395; R. M. Sharpe,
"Declining sperm counts in men --is there an endocrine cause?"
Journal of Endocrinology, Vol. 136 (1993), pgs. 357-360;
Constance Holdren, "The Hazards of Estrogens," Science Vol. 260
(May 28, 1993), pgs. 1238-1239; "Estrogenic Chemicals May Lower
Sperm Counts," C&EN [Chemical & Engineering News] Vol. 71 No. 23
(June 7, 1993), pg. 28.
[5] Increases in ectopic pregnancies are documented in MMWR
[Morbidity and Mortality Weekly Report] CDC Surveillance
Summaries Vol. 39 No. SS-4 (December, 1990), pgs. 9-19.
[6] Bette Hileman, "Environmental Estrogens Linked to
Reproductive Abnormalities, Cancer," C&EN [Chemical &
Engineering News] Vol. 72 No. 5 (January 31, 1994), pgs. 19-23.
David E. Larson, editor, Mayo Clinic Family Health Book (N.Y.:
William Morrow, 1990), pgs. 1101-1102. Sherry E. Rier and
others, "Endometriosis in Rhesus Monkeys (Macaca mulatta)
Following Chronic Exposure to
2,3,7,8-Tetrachlorodibenzo-P-dioxin," Fundamental and Applied
Toxicology Vol. 21 (1993), pgs. 433-441.
[7] Increases in Parkinson's disease and in amyotrophic lateral
sclerosis (ALS, or Lou Gehrig's disease) are documented in
Office of Technology Assessment, Neurotoxicity; Identifying and
Controlling Poisons of the Nervous System [OTA-BA-436]
(Washington, D.C.: U.S. Government Printing Office, April,
1990); see, for example, Figures 2-2 and 2-3 on pg. 55.
[8] Increases in multiple myeloma are discussed in Jack Cuzick,
Ramon Velez, and Richard Doll, "International Variations and
Temporal Trends in Mortality from Multiple Myeloma,"
International Journal of Cancer Vol. 32 (1983), pgs. 13-19,
which was updated in Jack Cuzick, "International Time Trends for
Multiple Myeloma," in Devra Lee Davis and David Hoel, editors,
Trends in Cancer Mortality in Industrial Countries (New York:
New York Academy of Sciences, 1990), pgs. 205-214. Increases in
septicemia are documented in MMWR [Morbidity and Mortality
Weekly Report] Vol. 39 No. 2 (January 19, 1990), pg. 31-34.
[9] A. Sonia Buist and William M. Vollmer, "Reflections on the
Rise in Asthma Morbidity and Mortality," Journal of The American
Medical Association October 3, 1990, pgs. 1719-1720. And: Peter
J. Gergen and others, "National Survey of the Prevalence of
Asthma Among Children in the United States, 1976 to 1980,"
Pediatrics Vol. 81 (1988), pgs. 1-7. And: Kevin B. Weiss and
Diana K. Wagener, "Changing Patterns of Asthma Mortality,"
Journal of The American Medical Association Vol. 264 (1990),
pgs. 1683-1687. And Richard Evans III and others, "National
Trends in the Morbidity and Mortality of Asthma in the U.S.,"
Chest Vol. 91 No. 6 (June 1987) Supplement, pgs. 65S-74S.
[10] See Board on Environmental Studies and Toxicology,
National Research Council, Multiple Chemical Sensitivities
(Washington, D.C.: National Academy Press, 1992). Multiple
chemical sensitivity--an adverse reaction to low levels of many
different chemicals with symptoms that range from sniffles to
coma--afflicts 10% to 15% of the American public, and appears to
be increasing, says Bette Hileman, "Multiple Chemical
Sensitivity," C&EN [Chemical & Engineering News] Vol. 69 No. 29
(July 22, 1991), pg. 34. Hileman says, "The lack of a clear
definition or diagnostic test for MCS [multiple chemical
sensitivity] makes it very difficult to estimate its prevalence.
However there is much indirect evidence that the number of
people diagnosed with MCS is increasing." This emerging disease
has been subject of two excellent book-length studies: In 1990
the New Jersey Department of Health published a report by
Nicholas Ashford and Claudia Miller, Chemical Sensitivity, which
is distributed by National Center for Environmental Health
Strategies (NCEHS), 1100 Rural Ave., Voorhees, NJ 08043; phone
(609) 429-5358. $17.00. See also Nicholas Ashford and Claudia
Miller, Chemical Exposures: Low Levels And High Stakes (New
York: Van Nostrand Reinhold, 1990).
[11] "Studies conducted in New York state have estimated that
50,000 to 70,000 workers die each year from chronic occupational
diseases resulting from past exposures to toxic substances,"
writes Philip Landrigan of Mount Sinai School of Medicine in New
York City. "Included are lung cancers and mesothelioma [cancer
of the lining of the chest cavity] from asbestos exposure;
bladder cancer among dye workers; leukemia and lymphoma in
workers exposed to benzene and ionizing radiation; chronic
bronchitis in workers exposed to dusts; disorders of the nervous
system (including possibly dementia, Parkinson's disease, and
motoneuron disease [Lou Gehrig's disease]) in workers exposed to
pesticides, solvents, and certain other neurotoxins; renal
[kidney] failure in workers exposed to lead; and cardiovascular
disease in workers exposed to carbon monoxide and carbon
disulfide." See Philip J. Landrigan, "Commentary: Environmental
Disease--A Preventable Epidemic," American Journal of Public
Health Vol. 82 (July 1992), pgs. 941-943.
[12] Committee on Environmental Health, American Academy of
Pediatrics, "Lead Poisoning: From Screening to Primary
Prevention," Pediatrics Vol. 92 (July 1993), pgs. 176-183.
[13] Bette Hileman, "Concerns Broaden over Chlorine and
Chlorinated Hydrocarbons," C&EN [Chemical & Engineering News]
Vol. 71, No. 16 (April 19, 1993), pg. 20.
[14] International Joint Commission, Sixth Biennial Report
Under the Great Lakes Water Quality Agreement of 1978 To The
Governments of the United States and Canada and the State and
Provincial Governments of the Great Lakes Basin (Washington,
D.C., and Ottawa, Ontario, 1992) and International Joint
Commission, Seventh Biennial Report Under the Great Lakes Water
Quality Agreement of 1978 To The Governments of the United
States and Canada and the State and Provincial Governments of
the Great Lakes Basin (Washington, D.C., and Ottawa, Ontario,
1994). Both
reports are indispensable reading and are available free from
International Joint Commission, 1250 23rd Street, N.W., Suite
100, Washington, DC 20440; telephone: (202) 736-9000.
[15] International Joint Commission, Sixth Biennial Report
(cited above), pgs. 4, 57.
[16] The principle of precautionary action did not originate
with the IJC. The Ministerial Declaration of the Second
International Conference on the Protection of the North Sea,
held in London November 24-25, 1987, contains the following
language: "[We agree to] accept the principle of safeguarding
the marine ecosystem of the North Sea by reducing polluting
emissions of substances that are persistent, toxic, and liable
to bioaccumulate at source by the best available technology and
other appropriate measures. This applies especially where there
is reason to assume that certain damage or harmful effects on
the living resources of the sea are likely to be caused by such
substances, even where there is no scientific evidence to prove
a causal link between emissions and effects ('the principle of
precautionary action');"
The United Nations Environment Program (UNEP) Governing
Council on May 25, 1989, adopted Decision 15/27 urging all
governments to adopt "the 'principle of precautionary action' as
the basis of their policy with regard to the prevention and
elimination of marine pollution." Part of the rationale given
was "that waiting for scientific proof regarding the impact of
pollutants discharged into the marine environment may result in
irreparable damage to the marine environment and in human
suffering."
[17] International Joint Commission, Sixth Biennial Report
(cited above), pgs. 22-23.
[18] International Joint Commission, Seventh Biennial Report
(cited above), pg. 28.
[19] International Joint Commission, Seventh Biennial Report
(cited above), pg. 9.
[20] International Joint Commission, Sixth Biennial Report
(cited above), pg. 4.
[21] International Joint Commission, Sixth Biennial Report
(cited above), pg. 25.
[22] International Joint Commission, Sixth Biennial Report
(cited above), pgs. 5, 25.