=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #318
—December 30, 1992—
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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THE YEAR IN REVIEW: TOXICS, PART 1
Continuing the review of 1992 highlights we began last week:
Non-Cancer Health Effects
For two decades, the chemical industry and the federal government
kept the American people focused narrowly on cancer risks from
chemical exposures. Meanwhile, largely unnoticed by science or
medicine, many chemicals have been affecting the human immune
system, reproductive system, and nervous system.
Only a handful of chemicals have been proven to cause cancer in
humans. Many more have been shown to cause cancer in laboratory
animals, but an army of scientists now makes a good living by
arguing that animal tests don’t tell us much about humans. While
this debate rages, thunderous quantities of industrial poisons
continue to spew into the environment. The environmental movement
and the public have allowed the chemical industry and their
friends in government to define the terms of the discussion. The
result has been two decades of focus on cancer and not much else.
Cancer is important, of course, but so are other health problems
caused by chemicals.
During 1992, non-cancer threats from chemicals began to get the
attention they deserve. For example, SCIENCE magazine, official
voice of the American Association for the Advancement of Science,
said April 3 (pg. 28),
IN THE 1980S, HUMAN IMMUNE SYSTEMS WERE FIRST FACED WITH THE
BLATANT DESTRUCTIVE POWER OF AIDS. NOW IN THE 1990S, HUMANS–AND
IMMUNOLOGISTS–ARE ENCOUNTERING DRAMATIC INCREASES IN YET ANOTHER
DISTURBING, THOUGH FAR MORE SUBTLE PROBLEM: ENVIRONMENTAL
POLLUTANTS ARE HAVING A DELETERIOUS EFFECT ON IMMUNE SYSTEMS.
INDEED, EVERYWHERE THESE DAYS DOCTORS ARE SEEING INCREASINGLY
SEVERE CASES OF IMMUNE-RELATED DISEASES.
A 1992 report by the National Research Council (NRC), titled,
ENVIRONMENTAL NEUROTOXICITY, said, “There is convincing evidence
that chemicals in the environment can alter the function of the
nervous system.” The report suggested that chemical exposures may
be responsible for some degenerative brain disorders such as
Parkinson’s disease, Alzheimer’s disease, and Lou Gehrig’s
disease (amyotrophic lateral sclerosis).
NRC said there are 70,000 chemicals now in commercial use and
less than 10% of these have ever been tested at all for toxic
effects on the nervous system and “only a handful have been
evaluated thoroughly.”[1]
Risk Assessment
As the focus of concern shifted away from cancer, critics of risk
assessment became more vocal. Risk assessment is a technique that
first came into use during the Carter administration, then was
promoted with a vengeance during the Reagan/Bush years. Risk
assessment is now the main intellectual prop that allows
industries to continue dumping billions of pounds of industrial
poisons into public air and water supplies. When anyone objects,
the poisoners trot out a risk assessment produced by some
high-priced consultant, showing that the risk of giving anyone
cancer is less than one-in-a-million. EPA has blessed this as the
official technique for showing that industrial poisons rarely, if
ever, cause significant harm. In the desperate latter days of the
Bush administration, William Reilly, chief of EPA, even went so
far as to suggest that ALL EPA policy should be based on risk
assessment.
To expose the swindle inherent in all risk assessments, one
merely needs to point out that little or nothing is known about
the effects of chemicals on the immune system, the reproductive
system, and the nervous system. When little or nothing is known,
it is obviously impossible to show that any particular chemical
exposure is safe. Under such circumstances, the only dose known
to be safe is zero. Since there will never be enough research to
discover the ill effects of all INDIVIDUAL chemicals now in use,
much less COMBINATIONS of all chemicals now in use, risk
assessment is, AND ALWAYS WILL BE, a sham and a deception.
Scientists like Tom Webster at Queens College in New York and
Mary O’Brien at University of Montana in Billings, and lawyer
Paul Merrell of Alder-Hill Associates in Tidewater, Oregon, have
published devastating critiques of risk assessment.
The National Research Council’s study of neurotoxins jolted the
political system into a new awareness of risk assessment. Senator
Edward M. Kennedy (D-Mass.), sponsor of a bill called the “Safety
of Pesticides and Food Act,” greeted the NRC report saying, “This
report makes clear how little we know about the health
consequences of the thousands of toxic chemicals that permeate
our high-tech society. The most ominous finding is that current
risk assessment methods are not sensitive enough to detect real
and avoidable risks lurking in our environment.”
If 1992 is any indication, risk assessors in 1993 will find
themselves on the defensive.
Incineration
Throughout the 1970s and 1980s, evidence accumulated that all
landfills leak and that there is no affordable way to build a
safe landfill. (You might build a long-lived landfill inside a
huge 12″-thick titanium box welded shut, but no one could afford
it.)
As an alternative, industry and its acolytes in government
decided to build thousands of hazardous waste incinerators. To
show that these were safe, EPA developed an elaborate “trial
burn” system. Incinerator operators pick representative wastes
that are supposedly harder to destroy than the other wastes that
would be routinely burned. These harder-to-destroy wastes are
called POHCs (principal organic hazardous constituents). During
the trial burn, POHCs in nearly pure form are fed into the
incinerator and what comes out the smoke stack is compared to
what was fed into the furnace. A simple calculation then reveals
the “destruction and removal efficiency” (DRE) of the machine.
EPA established regulations REQUIRING 99.99% DRE FOR ALL WASTES
FED INTO HAZARDOUS WASTE INCINERATORS and they told everyone who
would listen that 99.99% DRE of the POHCs proved beyond any doubt
that 99.99% DRE would be achieved for all wastes fed into the
furnace.
In late 1992, this was all revealed as a fraud and a ruse.
Greenpeace chemist Pat Costner unearthed two EPA studies,
conducted in 1984 and 1985, showing that no incinerators could
meet the established regulations. Any chemical present in the
waste stream at a concentration below 1000 parts per million
(ppm) cannot be destroyed with 99.99% DRE. Since thousands of
incinerators had been sold to the public by industry and by EPA
as “safe” specifically to destroy dangerous wastes present in
concentrations lower than 1000 ppm, it became clear that this was
a public health scandal of considerable proportions.
In response to the public flap, on September 22, 1992, EPA’s
director of the office of solid waste, Sylvia Lowrance, wrote a
memo to all 10 regional EPA offices, suggesting ways to avoid
acting upon the discrepancy between the requirements of the law
and the actual operating characteristics of hazardous waste
incinerators. It seems clear that, according to EPA’s
regulations, all hazardous waste incinerators should be shut down
because the regulations say, “the DRE performance standard
applies to each waste feed burned.” Since no incinerators can
meet the 99.99% requirement for all wastes burned, no incinerator
meets EPA regulations. Ms. Lowrance’s memo seemed to be aimed at
showing EPA staff how to evade the requirements of the law–a
kind of guidance EPA officials are not supposed to give.
On December 22, in a letter to the EPA inspector general John
Martin, EPA employee William Sanjour formally charged Sylvia
Lowrance with violations of law.[2] The inspector general is now
required to conduct an investigation.
Our hat is off to Mr. Sanjour for his fortitude and persistence.
Let us hope the new administration recognizes what an asset he is
to the EPA. Many of the suggestions in his 1992 report, WHY EPA
IS LIKE IT IS AND WHAT CAN BE DONE ABOUT IT, could make any
government agency work better.[3]
Lead in Children
The federal Centers for Disease Control in 1992 officially
reduced the amount of lead that is considered “acceptable” in
children’s blood, from 25 micrograms per deciliter to 10
micrograms per deciliter.
As the year wound down, a spate of studies began appearing in
medical journals indicating that even 10 micrograms per deciliter
is associated with permanent loss of IQ. The NEW ENGLAND JOURNAL
OF MEDICINE reported October 29 (pgs. 1279 and 1308) that low
levels of lead in young children don’t merely “delay
neurobehavioral or motor development” but actually produce
“deficits in intelligence.” At least three studies of children
exposed to lead before the age of 4 have now shown that the
damage is measurable during school years, ages seven to 10. One
study of well-to-do children in Boston showed that each increase
of 10 micrograms of lead per deciliter of blood at age 2
produced a six-point decrease in IQ at age 10. This held true in
the range 0 to 25 micrograms per deciliter, which means that a
child with 25 micrograms of lead in his or her blood at age 2
would lose 15 IQ points compared to what his or her IQ would
otherwise have been. Such a decrease might not debilitate a
person who started with a 125 IQ, but it would devastate a person
at the lower end of the normal range of intelligence. A person
pushed from a 90 to a 75 IQ would face a lifetime of serious
learning disabilities and expensive remedial help.
Late in 1992, the Bush administration responded by issuing rules
requiring all children on Medicaid to be screened for lead.
However, the new rules allowed states to continue using outmoded
screening techniques that cannot detect lead below 25 micrograms
per deciliter, no doubt intended as a kinder, gentler way of
continuing to ignore this menacing problem.[4]
Happy new year!
–Peter Montague, Ph.D.
===============
[1] Philip J. Landrigan, ENVIRONMENTAL NEUROTOXICOLOGY
(Washington, D.C.: National Academy Press, 1992), pg. 2.
[2] We covered this story in greater detail in RHWN #280 and
#312. William Sanjour’s 8-page letter to the inspector general is
available from us for $4.00.
[4] N.Y. TIMES September 13, 1992, pg. A1.
Descriptor terms: cancer; carcinogens; health; exposure;
studies; testing; nas-nrc; immune system damage; risk assessment;
hazardous materials; immune system; reproductive system;
reproductive hazards; landfilling; hazardous waste incineration;
waste treatment technologies; waste disposal technologies; lead;
cdc;