=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #154
—November 7, 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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HOW TO ACHIEVE POLLUTION CONTROL? ZERO DISCHARGE VS. ‘PROVE HARM’.
What are the goals of the grass roots movement for environmental
justice? Surely one goal is pollution control. How can we get
there?
There are two fundamental philosophies of pollution control:
total containment vs. partial abatement. We have written before
about total containment (see RHWN #106); it is the principle of
no dumping, or zero discharge, which says, “All peaceable people
(that excludes criminals) are entitled to hold themselves and
their property free from coercion, intrusion, and fraud, provided
they secure the identical right for each other. This definition
of human rights clearly prohibits people who own property from
letting it intrude on anyone else’s body or property, which
includes the common air and water… It is not the obligation of
other humans to prove that the dumping would be lethal or even a
hazard at all. There is just no right to let your property
intrude on others, and you’d better consider that before you make
it or buy it.” Zero discharge is allowed; anything more than zero
will draw a penalty.
The alternative, which we call “prove harm abatement,” is what
the U.S. has been trying for the past 30 years. This philosophy
allows polluters to dump into common air and water until someone
can prove harm; after harm is proven, then “appropriate” controls
may be required to restrict emissions to “acceptable” levels. Why
doesn’t this system work?
1) This system rests upon the assumption that we humans know what
we are doing. It assumes that we can decide on a rational basis
how much of each chemical the earth can endure. Then we are
supposed to devise controls that will allow just the right amount
of chemicals into the environment, and no more.
There is something ominous about these assumptions. They lack
humility. Who really believes we humans know what we are doing?
Who believes we understand the environment well enough to
determine how much of each chemical is “safe” and how much is
“unsafe.” Who knew just 20 years ago that emitting CFCs
[chlorofluorocarbons] into the atmosphere would destroy the
planet’s ozone shield and allow dangerous levels of ultraviolet
light to flood the surface of the earth? Who knew that nitrogen
and sulphur released from power plants in the midwest would
devastate crops, forests and lakes throughout the eastern U.S.,
Canada and Europe by acid rain?
Even if we knew how much of a chemical we could safely release
into the environment, who believes we can devise controls that
will achieve the desired goal? When you eat swordfish, you are
risking brain damage from mercury contamination. Mercury enters
the oceans (and then the swordfish) from many sources-from coal
combustion, from the manufacture of paper, from solid waste
incinerators, and from mercury mining, to mention only a few
sources. What level of restrictions on which industrial processes
will reduce mercury emissions sufficiently to make it once again
safe to eat swordfish? It is an incredibly complex question.
There are too many ways that pollutants get into the environment
for society to be able to develop numerical controls on each
substance produced by each human activity. There are too many to
measure, too many to comprehend, too many to fix, if each is to
be separately examined and subjected to a uniquely appropriate
control.
2) There are thousands of ways pollutants can directly harm
humans; because experiments on animals are expensive to carry
out, we usually only test chemicals for gross signs of harm, such
as cancer, but there are many more subtle kinds of harm we should
be concerned about: reproductive disorders (stillbirths, birth
defects, low birth weight), developmental disorders (reduced
learning ability, for example), and sublethal effects like
headaches, sinus problems, rashes, blurred vision, unsteadiness,
kidney problems, and so forth. Medical science knows little or
nothing about these sublethal effects of most chemicals. With
60,000 chemicals now in use and 500 to 1000 new ones coming into
use each year, there are simply too many chemicals to be tested
for subtle damage, so we only test for the most obvious effects
(if we test at all).
The “prove harm” philosophy reduces the most obvious damage from
the obvious poisons but it fails to take action against unknown
ones until some new unforseen consequence becomes obvious. The
“prove harm” philosophy is concerned with what are only the most
visible fringes of the problem. 3) Even when compelling
scientific evidence of harm comes to light, there is still a
decades-long struggle to curb pollution. Lead is an example.
People have known for 2000 years that lead is a dangerous poison,
yet we allowed the automobile industry to emit millions of tons
of lead each year into our air. It took four decades to bring it
under control. Lead in paint reveals the same problem: doctors
knew for two decades that children in urban ghettoes were eating
lead paint and damaging their central nervous systems before
Congress acted to restrict lead in paint. Even after Congress
acted, the problem continued, and continues to this day.
4) Even when you can prove harm, this is not sufficient to
guarantee that a chemical will be controlled. It is now
fashionable for industry and government to open up a new debate
on how much harm is acceptable. Is it acceptable to kill one in
10,000 people exposed to benzene or may we only kill one in a
million? As odd as it may sound in our Constitutional democracy,
this is a real debate today. Under William Reilly, the EPA (U.S.
Environmental Protection Agency) has selected one-in-10,000
whereas his predecessor had selected one-in-a-million.
5) Harm that is known to be occurring, but is not visible in
reports of vital statistics, is labeled insignificant or
inconsequential. For example, the Department of Energy estimated
that the Chernobyl nuclear power plant explosion would kill
28,000 people by giving them cancer but they dismissed this as
“negligible” compared to the natural cancer rate.
After the Natural Resources Defense Council (NRDC) published its
estimate that the pesticide Alar on apples was causing 5,000
cancer deaths each year in the U.S., the winner of the American
Chemical Society’s coveted Priestley medal, George Pimintel,
ridiculed NRDC’s “hysteria,” saying 5000 cancers is “a barely
noticeable perturbation” of the nation’s cancer statistics. (C&EN
May 1, 1989, pg. 53.)
6) After harm is proven, and the need for restriction is accepted
by government agencies, additional progress toward stricter
control can be delayed by any well-funded industry that carries
out additional research; each new study becomes an opportunity to
open up a debate on whether to relax existing pollution controls.
7) The “prove harm” rule guarantees that we will have many
victims of pollution. Until we have victims-or evidence of
serious environmental disruption, like loss of the ozone shield,
loss of oyster beds from sewage, loss of the striped bass
population from PCBs-we do not have a compelling case for
restricting emissions.
8) Under the “prove harm” philosophy, the development of controls
is dependent upon risk assessments and mathematical models. Since
risk assessments and mathematical models are matters of art more
than they are matters of science, reliance upon these tools for
setting controls is guaranteed to lead to endless debate among
high-paid consultants, but little satisfactory control of
chemicals. Furthermore, ordinary people are left out of the
debate, which undermines democracy itself.
9) Prove harm strategies and item-by-item pollution control are
subject to dispute arising out of differences in emphasis, in
understanding, or even in aesthetics. When we decide it’s OK to
dump “some” chemicals into the environment, “some” is difficult
to describe, arbitrary to establish, and always subject to
question. “None” is not. That is why we should now move to a
“zero discharge” philosophy of pollution control.
–Peter Montague, Ph.D.
Descriptor terms: zero discharge; risk assessment; health
effects; lead paint; gasoline; chernobyl; nrdc; alar; george
pimintel; global environmental problems;