=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #110
—January 2, 1989—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
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WILLIAM REILLY WILL HEAD U.S. EPA.
President-elect George Bush has named William Reilly to head the
U.S. Environmental Protection Agency (EPA). What can we expect
from Mr. Reilly?
For about 20 years, Mr. Reilly has directed the Conservation
Foundation in Washington, DC. In 1987, the Foundation published a
614-page blueprint for environmental protection, called STATE OF
THE ENVIRONMENT, A VIEW TOWARD THE NINETIES. Everyone should read
at least three chapters: 3: “Toxic and hazardous pollutants,” 7:
“America’s waste: managing for risk reduction,” and 8: “Toxics in
the air: reassessing the regulatory framework.” The book is much
stronger and more coherent than anything the EPA has ever
published. Therefore, at the very least, you will be able to
confront local EPA officials by reading passages from this book
at public hearings, prefacing your remarks with, “Here’s what
your leader has to say on this subject.”
If we can believe his book, Mr. Reilly will make a difference in
at least three areas at EPA: (1) he will make more intelligent
and restrained use of risk assessment; (2) he will emphasize the
need for reliable information about wastes and their
consequences; and (3) he will give greater emphasis to waste
reduction.
Mr. Reilly’s book says, “The best way to make sense out of the
complex components and paths of waste streams is to examine the
different kinds and degrees of risk and damage they create.” (pg.
419). In principal, we agree. However we have all had “risk
assessment” used against us by industry and its supporters in
government. They focus the discussion on one aspect of “hazard,”
usually the potential to cause cancer in humans. They simply
don’t discuss any other health consequences, and they ignore
non-human species entirely. Then they use a mathematical model to
show how the chemical will move through the environment. (The
mathematical model itself may be based on guesswork but it often
seems convincing to local officials because its results are spit
out by a computer.) They use these results to show that, based on
one or two studies of mice or guinea pigs, the amount of chemical
likely to reach the “average” person will only cause “acceptable”
numbers of cancers. What is the “average” person? A completely
healthy, well-to-do white male in the prime of life. What is an
“acceptable” number of cancers? Industry and its supporters in
government assume they have the “right” to kill one person in a
million each year by exposure to each chemical for which a risk
assessment is being done. (Where they got this “right” they never
say.)
But risk assessment doesn’t have to be carried out in this crude
way. Mr. Reilly’s book seems to indicate he’d do it differently.
Risk assessment asks two questions: First, what is the inherent
hazard of the chemical? And, second, how can humans and other
creatures become exposed to it?
Mr. Reilly’s book recognizes that both hazard assessment and
exposure assessment are exceedingly complex. Hazard assessment is
complex because so little is known about the effects of most
chemicals. “The science of risk assessment is relatively
undeveloped. The National Research Council concluded in a 1984
report that fewer than 2 percent of the chemicals currently used
for commercial purposes have been tested sufficiently for a
complete health hazard assessment to be made. Adequate
information to support even a partial hazard assessment is
available for only 14 percent of the chemicals; for 70 percent,
no information is available. Moreover, these percentages refer
only to human health hazards. In general, environmental hazards
are even less well understood….” (pg. 425)
Additional complexities include these: Some chemicals degrade
into other, more toxic chemicals. For example, in the
environment, trichloroethylene (TCE) may be transformed into
vinyl chloride or 1,2dichloroethylene, substances that are 2.5
and 5 times more potent than the original solvent. (pg. 422)
A single source of waste can endanger humans and, by a different
route, wildlife, and can create an aesthetic nuisance with
serious economic consequences (making beaches unfit for swimming,
for example). Thus, there may be multiple risks from one chemical
discharge.
Mr. Reilly discusses the difficulties in assessing exposure to
chemicals, too:
The pathways of movement through the environment may be
exceedingly complex and indirect. Air pollution may fall to the
ground and become water pollution, eventually making its way to
the oceans. Furthermore, it is difficult to assess the
sensitivity of the people and the environment that will be
exposed. A person’s health, age, and exposure to other chemicals
(besides the one being assessed) will affect that person’s
sensitivity to a chemical. For example, a person with asthma
responds differently to air pollution than a person without
asthma. A child may absorb more lead than an adult because
children have a higher metabolic rate and are more active, and
because some children eat dirt. (pgs. 421-422)
Mr. Reilly emphasizes the need for reliable information about
wastes: “The first priority is to get more information about what
wastes are entering the environment, how they are entering, and
in what quantities…. [such information] is useful to…
governments in planning for emergencies, [and] in setting
priorities for regulatory action….” (pg. 454)
Mr. Reilly also thinks we need new information on health effects
of chemicals. He says, “Much attention has been focused on
cancer, and the ability to assess the risk from carcinogens has
increased considerably in the past 10 years. Comparable progress
needs to be made in improving methods to assess other types of
health and environmental effects. After all, exposure to some
chemicals can affect people’s reproductive, immune, and nervous
systems and can cause other problems as well.” (pg. 455) Mr.
Reilly’s book also indicates the importance of pollution
prevention. He says, “By contrast, the most effective, as well as
most economical, way to reduce the risks associated with wastes
in many cases is to reduce the amount that is generated and
released to the environment.” (pg. 410)
Mr. Reilly’s book lists seven reasons why industry may want to
reduce its production of wastes. Notice that strategies of the
grass roots environmental movement play a key role in several of
Mr. Reilly’s 7 reasons:
1) higher cost of managing waste;
2) financial liability from lawsuits;
3) difficulties in siting new waste management facilities;
4) difficulties getting permits for existing waste management
facilities;
5) difficulties cleaning up existing facilities;
6) shortages of liability insurance;
7) public concern about toxics.
Don’t get us wrong. You will need to remain vigilant and
aggressive in dealing with William Reilly’s EPA. But George Bush
certainly could have done a lot worse.
Get: William Reilly and others, STATE OF THE ENVIRONMENT: A VIEW
TOWARD THE NINETIES (Washington, DC: Conservation Foundation
[1250 24th St., NW, Wash., DC 20037; phone: (202) 293-4800],
1987; $19.95 per copy.
–Peter Montague, Ph.D.
Descriptor terms: epa; william reilly; waste reduction;
pollution prevention; waste avoidance; waste minimization;
conservation foundation; risk assessment;