=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #378
—February 24, 1994—
News and resources for environmental justice.
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TODAY’S TOXICS POLICIES ARE “ETHICALLY
UNACCEPTABLE,” SAYS GREAT LAKES COMMISSION
The long-awaited 7th biennial report of the International Joint
Commission (IJC) was issued last week. The IJC is a government
body with responsibility for maintaining and restoring
environmental quality in the Great Lakes. Past IJC reports have
recommended policies that, taken together, define an entirely new
approach to the problem of persistent toxic substances.
The 7th IJC report once again calls for:
** phase-out (“sunsetting”) of all persistent toxic substances
from the Great Lakes ecosystem;
** a ban on the manufacture and use of chlorine;
** an end to reliance on risk assessment;
** a ban on solid waste incineration;
** a reversal of the policy that assumes chemicals are innocent
until proven guilty;
** adoption of the principle of precautionary action (which says:
wherever it is acknowledged that a practice could cause harm,
even without conclusive scientific proof that it does cause harm,
the practice should be prevented and eliminated);
** An end to chemical-by-chemical regulation, substituting an
approach that eliminates whole classes of chemicals by
“strategically preventing the formation of the persistent toxic
substance in the first place.”
The IJC defines toxic substances as 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.” The IJC defines a PERSISTENT
toxic substance as one with a half-life in any medium (air,
water, soil, sediment, or living things) greater than 8 weeks, or
one that bioaccumulates in the tissue of living organisms. The
half-life of a substance is the time it takes for half of the
substance to degrade, go away or disappear.
The 1978 Great Lakes Water Quality Agreement, signed by the
federal governments of the U.S. and Canada, insists that, “The
discharge of toxic substances in toxic amounts be prohibited and
the discharge of any or all persistent toxic substances be
virtually eliminated.” In its SIXTH BIENNIAL REPORT in 1992 the
IJC said, “This statement is the cornerstone of the Agreement.”
The 7th IJC report says that “conventional scientific concepts of
dose-response and acceptable ‘risk’ can no longer be defined as
‘good’ scientific and management bases for defining acceptable
levels of pollution. They are outmoded and inappropriate ways of
thinking about persistent toxics,” the report says.
“The production and release of [persistent toxic] substances into
the environment must, therefore, be considered contrary to the
[1978 Water Quality] Agreement legally, unsupportable
ecologically, and dangerous to health generally. Above all, they
are ethically and morally unacceptable,” the report says. It
goes on to stress the need for a zero discharge policy for
persistent toxic substances: “The limits of allowable quantities
of these substances entering the environment must be effectively
zero, and the primary means to achieve zero should be the
prevention of their production, use and release, rather than
their subsequent removal.”
The IJC was created in 1909 by the governments of Canada and the
U.S. to oversee the Boundary Waters Treaty, which guides Great
Lakes-related behavior of the two nations. Starting in 1912, and
again in 1945 and 1964 the IJC was asked by the two governments
to report on water quality of the lakes. The studies revealed
progressive deterioration. In 1972 and again in 1978 the two
nations signed Water Quality Agreements aimed specifically at
improving water quality in the lakes. The goal of the 1978
Agreement was broad: “to restore and maintain the chemical,
physical and biological integrity of the waters of the Great
Lakes Basin Ecosystem.” It is up to the IJC to manage and monitor
efforts to achieve the goals of the 1978 Agreement. In 1981, the
IJC began issuing a report every two years, describing the
condition of the lakes in relation to the goals of the 1978
Agreement.
The new (7th) report says, “The theme of this report is that the
time has arrived for a major shift in the way decision-making
takes place for the Great Lakes ecosystem. In particular,
society must adopt a clear and comprehensive action plan to
virtually eliminate persistent toxic substances that are
threatening human health and the future of the Great Lakes
ecosystem.”
Early in the report, the IJC asks what might happen if people
refuse to control persistent toxic substances? Here is a long,
verbatim quotation from the report:
“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 [in the womb] 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 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 [in the womb]?
“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,” the IJC
said.
The new report puts risk assessment into perspective: “Risk
assessment is useful in decision-making, especially in setting
action priorities, but is not directly relevant to the basic
virtual elimination commitment. The Commission does not accept
the argument that the elimination of persistent toxic substances
should be subject to a risk-benefit calculation, as that is not
the approach of the [1978 Great Lakes Water Quality] Agreement,”
the report says.
Users and producers of persistent toxic substances had told the
Commission that phase-out of toxic substances would cause job
loss outweighing any long-term health benefits. They said
risk-benefit analysis showed that virtual elimination of
persistent toxic substances would not pay. The Commission
rejected that argument explicitly, saying, “to continue resisting
a strategy that changes our production and consumption habits and
moves away from reliance on persistent toxic substances, will be
disastrous in the long term from all perspectives.”
The Commission called upon industry representatives to stop
denying toxics problems and to focus on solutions:
“Representatives of industry, when presented with evidence of
ecosystem health concerns about substances used in commerce,
should react by embracing open dialogue, data sharing and fact
finding, to resolve rather than deny, concerns and effect an
orderly and timely transition to those solutions,” the IJC says.
The Commission called for an end to incineration anywhere in
North America that could affect the Great Lakes: “A growing
number of incinerators operate within the Great Lakes region,
contributing significantly to the load of contaminants,
especially from the low-temperature incineration of industrial,
commercial and household refuse containing plastics and solvents,
coated papers and many other products,” the report says. “Any
strategy towards virtual elimination and zero discharge of
persistent toxic substances must address the significant inputs
from incineration,” the report says. “The Commission urges the
stringent regulation of existing facilities throughout North
America, taking into account the need to ensure the zero
discharge of persistent toxic substances from those stacks to the
Great Lakes.”
The report calls upon “Governments, industry and labour [to]
begin devising plans to cope with economic and social dislocation
that may occur as a result of sunsetting persistent toxic
substances.” It calls upon “Labour unions [to] include in their
negotiations the issue of transition to a sustainable economy
without persistent toxic substances.” And it calls upon citizens
to get involved: “Citizens should constantly ask political,
social and industrial leaders about the effects of the use and
discharge of pollutants on this and future generations,” the
report says, noting that “The patience of many citizens seems to
be near a breaking point.”
“Maintaining a healthy society means more than failing to
discover disease,” the report says.
GET: International Joint Commission, SEVENTH BIENNIAL REPORT ON
GREAT LAKES WATER QUALITY (Washington, DC and Ottawa, Ontario:
International Joint Commission, 1994), 58 pages, available free
from the International Joint Commission, 1250 23rd Street, N.W.,
Suite 100, Washington, DC 20440; telephone: (202) 736-9000.
                
                
                
                
    
–Peter Montague, Ph.D.
Descriptor terms: international joint commission; ijc; waler
quality; water pollution; treaties; cn; canada; u.s.; regulation;
toxic substances; toxics; sunsetting; chlorine; incineration;
bans; zero discharge; reverse onus; precautionary principle;
principle of precautionary action; persistence defined;