=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #235
—May 29, 1991—
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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WHAT ‘TOXICS USE REDUCTION’ IS NOT.
Global pollution by toxic chemicals is increasing. Chemical
contamination now contributes to the following kinds of problems:
global warming, ozone depletion, acid rain, rising cancer rates,
increasing asthma, the widespread poisoning of children by lead,
escalating rates of Parkinson’s disease and of Lou Gehrig’s
disease, growing infertility among American men and women in
their prime reproductive years, the contamination of breast milk,
a new disease called “multiple chemical sensitivity,” and more.
Yet current approaches to regulation do not incorporate ways of
dealing with the continued spread of chemicals worldwide. As we
saw last week, two researchers at Oak Ridge National Laboratory
(ORNL) recently published a brief catalog of global pollutants
and, using EPA (U.S. Environmental Protection Agency) methods for
assessing cancer risk, they concluded that the “background”
cancer risk from just 11 chemicals is one-in-a-thousand, which is
about 1000 times more risk than EPA would usually allow any
individual polluter to create. (ENVIRONMENTAL SCIENCE &
TECHNOLOGY Vol. 25 [May, 1991], pgs. 814-819.) Here is the heart
of the problem: by focusing only on controlling risks to the
“most exposed individual,” EPA has allowed thousands of small
polluters to dump chemicals into the environment; together these
small sources add up to a big hazard, yet none of them
individually presents a large enough hazard for EPA to officially
notice.
To prevent pollutants from spreading everywhere on earth, we must
prevent the introduction of dangerous pollutants into all media:
air, water, and soil. To do this, we must either use fewer
dangerous chemicals, or we must destroy them before they are
released into the environment. In the case of metals, which can
never be destroyed, we must use less of them. In the case of
toxic organic chemicals, such as dry cleaning fluid
(tetrachloroethylene, also known as perchloroethylene, or perc),
we can either use less of it or we must destroy it after we use
it, before it gets away from us. An organic chemical is
considered “destroyed” when it is broken down into its elements.
(There are only 92 naturally-occurring elements and everything on
Earth is made up of combinations of these 92 building blocks. It
is worth noting that some of the building blocks themselves are
toxic, so these will need to be used in strict moderation, or not
at all, if we are to avoid poisoning the earth. Thallium,
mercury, and cadmium fall into this category. Elemental chlorine
probably belongs in this category as well–see RHWN #225.)
Any organic molecule that can be put together can also be taken
apart–“destroyed”–for a price. That’s the hitch. After a
chemical like perc has cleaned someone’s clothes a few times, it
is dirty and not very useful. It is ready for discard. Now would
be the time to “destroy” it. EPA’s solution to this problem is to
burn it in an incinerator. Unfortunately, as the ORNL researchers
noted “…emissions from incinerator stacks tend to release
pollutants directly into the atmosphere.” In fact, incinerators
release unburned chemicals directly via the stack but also via
leaks and spills during transport and handling. Moreover, once
chemicals are in an incinerator’s combustion chamber, they can
recombine into new chemicals (called PICS–products of incomplete
combustion) which can be more toxic, more long-lived, and all
together more dangerous than the chemicals the incinerator was
supposed to destroy. Incineration is good at limiting a
polluter’s liability, but it is not a solution to chemical
contamination–it is part of the problem.
There are other ways to destroy organic molecules besides
incineration, but they are generally not used because they are
expensive. Furthermore, even if we could afford to use more
efficient machines for destroying organic molecules, routine
spills and leaks during normal handling of large quantities of
chemicals would poison the planet sooner or later, so reducing
the use of organic chemicals (at least those that are toxic, or
are persistent in the environment, or that enter food chains)
seems the only real solution. This is what is generally meant by
pollution prevention, or toxics use reduction (TUR). What exactly
is toxics use reduction? Let us try to say what it is not. (1)
Toxics use reduction is not reducing the concentration of toxics.
If you have one pound of toxins mixed with one pound of water and
you add another pound of water, you have cut the concentration of
toxins, but you have done nothing to protect the environment. It
is the total quantity of toxins entering the environment that is
important, not the concentration. So toxics use reducion will
seek to reduce the total mass (amount) of toxins entering the
environment, regardless of concentration. (We note that EPA
permits issued to polluters describe the allowable levels of
pollution as a particular concentration. This reflects the EPA’s
desire to protect the most exposed individual not the general
environment. These permits are a key part of the EPA approach
that has allowed the global pollution problem to get entirely out
of hand.)
(2) Toxics use reduction is not EPA’s recentlyannounced
Industrial Toxics Project (ITP). In January, 1991, EPA chief
Reilly announced with great fanfare a voluntary “pollution
prevention” program. Reilly asked 600 industrial polluters to
voluntarily reduce their emissions of 17 toxic chemicals by 33%
by 1992 and by 50% by 1995.
This sounds good on paper. However, industry will measure and
report its own progress. EPA will not check on the accuracy of
the data. Industry reports its emissions of these chemicals each
year under the law known as SARA Title III (specifically the part
that calls for the Toxics Release Inventory, or TRI). Reporting
is known to be inaccurate. In fact, when the Chemical
Manufacturers Association asked EPA to allow TRI-reported
emission reductions to be applied as a “pollution credit” under
the new Clean Air Act, EPA refused, saying that the Clean Air Act
was a regulatory program that needs better data than a strictly
voluntary program could provide. It seems apparent that Mr.
Reilly’s ITP will allow industry to claim great progress toward
pollution prevention, progress that George Bush will no doubt
take credit for during his next election bid. Meanwhile, EPA
admits that the data will be flakey, not of suitable quality to
form the basis of a regulatory program. This is the lesson we can
learn from William Reilly: effective pollution prevention will
not be voluntary and it will require careful bookkeeping by
proper authorities. One good way to achieve this would be to levy
a tax on each pound of pollution, which would put Internal
Revenue Service (IRS) into the business of measuring pollution so
it could collect the tax. Self-reporting by industry might work,
with IRS doing spot checks, if corporate officers could be
penalized for lying about emissions as they might for lying about
income.
(3) Toxics use reduction is not risk reduction. EPA has managed
to define most environmental problems in terms of “risk
assessment”–a mathematical procedure based on so many half-baked
assumptions that it allows an accomplished risk assessor to reach
any conclusion he or she sets out to reach. (See RHWN #194, #195, #204.) Since EPA now defines “pollution”
largely in terms of risks as revealed through risk assessments, it seems only logical
that the agency will soon start to define “pollution prevention”
in terms of reduced risks as revealed by risk assessments. No
doubt when Mr. Bush’s election campaign is in full swing, EPA
will announce that its voluntary emissions-reduction program has
achieved a giant reduction in the risks to which the public is
subjected, and this will be declared a major victory for
pollution prevention. EPA will not have made a single measurement
of an actual decline in the amount of any dangerous chemical
entering the environment (which is the only true measure of
toxics use reduction)–but Mr. Bush will nevertheless declare
himself the pollution prevention President. The Bush-Reilly
toxics use reduction plan has the important advantage that it
will not interfere one whit with the continued poisoning of the
planet for profit.
–Peter Montague, Ph.D.
Descriptor terms: global environmental problems; toxic
substances; diseases; ozone depletion; global warming; cancers;
reproductive disorders; breast milk; mcs; ornl; oak ridge
national laboratory; epa; risk assessment; air pollution; water
pollution; pollution prevention; cleaning fluids; thallium;
mercury; cadmium; chlorine; organic chemicals; perc; pics;
incineration; tri; sara; bush administration; regulation;
monitoring; voluntary emissions-reduction program;