Our Greatest Accomplishment:
Grass-Roots Action Has Forced a Major Shift in Thinking

[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:

  • The incidence (occurrence) of many kinds of cancer has been increasing for 50 years, and continues to increase today; particularly steep increases have occurred among cancers of the testicles and prostate, the female breast, the brain, and the kidney but the incidence of 10 other kinds of cancer has relentlessly risen for five decades. [1]

  • The incidence of certain birth defects -- among them, heart defects, defects of the male genitalia, and facial clefts -- is rising. [2]

  • Increasingly, couples in their prime reproductive years are having trouble reproducing; [3] this may be due in part to a 50% decline in sperm count that has been documented among men worldwide over the past 50 years, a decline that is apparently continuing. [4]

  • Certain female reproductive disorders are also increasing; the number of ectopic pregnancies is rising, [5] as is the prevalence of endometriosis, a painful disease associated with the menstrual cycle, which now afflicts 5 million American women. In 1960, breast cancer struck one in 20 women; today, it strikes one in 9. [6]

  • Certain disorders of the central nervous system -- ALS [Lou Gehrig's disease] and Parkinson's disease -- are increasing. Some public health leaders suspect chemical contamination is the cause. [7]

  • Certain blood disorders are increasing (e.g., multiple myeloma, and septicemia). [8]

  • The prevalence of some well-known diseases of the immune system, such as asthma and diabetes, is steadily increasing. [9]

  • A new disease has emerged called "multiple chemical sensitivity" -- a disease characterized by extreme sensitivity to low levels of various chemicals, sometimes including odors from new carpets, perfumes, and the fragrances in commercial products such as waxes and detergents. Symptoms range in severity from an itchy rash to coma. [10]

  • Today in the U.S., occupational disease kills an estimated 60,000 workers each year. [11] In addition to these preventable deaths, workplace conditions cause an estimated 350,000 new cases of serious illness among workers each year, according to Philip J. Landrigan, chairman of the department of community medicine at the Mount Sinai School of Medicine in New York.

  • The American Academy of Pediatrics estimates that, in any given year somewhere between 2 and 4 million American children (and approximately 400,000 fetuses) have sufficient lead in their blood to diminish their IQ, reduce their physical stature, damage their hearing, decrease their hand-eye coordination and impair their ability to pay attention in school. [12] This damage is thought to be permanent. Lead is a soft, gray toxic metal that has been mined from the earth and formed into useful items for 5000 years. Its toxicity to miners and workers was well established among ancient Greeks and Romans long before the birth of Christ.

    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.

    Eliminate Persistent Toxic Substances

    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.

    Adopt The Principle of Precautionary Action

    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]

    Adopt A Weight-of-the-Evidence Approach

    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]

    End Reliance on Risk Assessment and Numerical Standards

    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.

    Adopt the Principle of Reverse Onus

    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:

  • What if, as current research suggests, the startling decrease in sperm count and the alarming increase in the incidence of male genital tract disorders are in fact caused in part as a result of in utero exposure to elevated levels of environmental estrogens?

  • What if, as current research suggests, the epidemic in breast cancer is a result in part of the great numbers and quantities of estrogen-like compounds that have been and are being released into the environment?

  • What if the documented declining learning performance and increasing incidence of problem behaviour [sic] in school children are not functions of the educational system? What if they are the result of exposure to developmental toxicants that have been and are being released into the children's and parents' environment, or to which they have been exposed in utero?

    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.

    End Notes

    [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.