=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #393
—June 9, 1994—
News and resources for environmental justice.
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Risk Assessment — Part 1:
THE EMPEROR’S SCIENTIFIC NEW CLOTHES
A scientist who made himself wealthy by conducting risk
assessments for industrial clients has now published a paperback
book on the theory of risk assessment. CALCULATED RISKS, by
Joseph V. Rodricks of Environ Corporation, is the best book we
have yet seen on the theory of risk assessment — lucidly
written, and evenhanded so far as it goes. [1] If you want to
understand the theory of risk assessment from the viewpoint of
a successful risk assessor, this is the book for you.
Unfortunately, since the theory of risk assessment is quite
different from the practice of risk assessment, Rodricks’s
book is little more than an enthusiastic description of the
emperor’s scientific new clothes.
In loving detail, Rodricks’s book describes all the theoretical
steps in a risk assessment. What the book does not discuss are:
(1) the insurmountable limits of science in determining chemical
hazards;
(2) the environmental justice problems that government officials
create when they use risk assessment to prioritize environmental
problems; and
(3) the widespread destruction of the environment that is
occurring because of our single-minded reliance on risk
assessment;
(4) other, better approaches to establishing “safety” and to
deciding environmental priorities, besides risk assessment.
This week and next, we will discuss these 4 points.
The limits of science: Risk assessors are usually working with
information that ranges from slim to none, and this will always
be the case because the chemical industry invents new chemicals
much faster than the government can test all their various
negative effects. Rodricks acknowledges that our ignorance is
vast: “Toxicologists know a great deal about a few chemicals, a
little about many, and next to nothing about most,” he says [pg.
146].
As Rodricks’s book illustrates, the government often doesn’t
even know what toxic effects to test for. For example,
Rodricks’s book is as thorough and up-to-date as he could make
it in 1992 (when the hardback edition first appeared), and yet
it does not even mention chemicals that damage the endocrine
system. The endocrine system, in wildlife and humans, is a
complex set of bodily organs and tissues whose activities are
coordinated by chemical messengers called hormones, which
control growth, development and behavior. Bears hibernate
because of chemical signals from the endocrine system, and women
menstruate under control of their endocrine systems. In the
past decade, evidence has accumulated that several dozen
pesticides and other industrial chemicals mimic, or interfere
with, hormones and thus disrupt the endocrine system. In both
wildlife and humans, it is the reproductive system of unborn
offspring that is most prone to disruption by hormone-like
pollutants.
For 20 years, risk assessors like Rodricks — well-meaning
people inside and outside of government — have given the green
light to exposing people and wildlife to thousands of chemical
compounds without understanding that some chemicals mimic, or
interfere with, hormones. The very best risk assessments gave
the answer “No problem” when in fact there were significant
problems.
This is an insurmountable shortcoming of all risk assessments.
If there are effects from chemicals that scientists have not
suspected and studied, those effects will be ignored in a risk
assessment. Furthermore, because it costs roughly $400,000 to
$1,000,000 to study a chemical even crudely, major harm must be
demonstrated before study commences. Therefore, the risk-
assessment method of setting “safe” standards always requires
that harm must be done to wildlife and humans before study
begins.
Rodricks — like every other person who makes a living
conducting risk assessments — is not deterred by the absence of
information about chemical effects. When good data are not
available, risk assessments are put together from “science
policy choices” (a fancy name for informed guesses),
assumptions, and speculation.
This is a key point. Rodricks [pg. 187] says, for example, that
in most cases the relationship between dose and response at low
levels of exposure is not known. (In other words, nobody knows
how sick your child will get from eating small amounts of
several poisons every day.) There are usually several
“scientifically plausible models” that could describe the
dose-response relationship, Rodricks says, and “scientists
cannot be sure which is correct.” Moreover, the different
models “yield sometimes substantially different pictures of the
risk for the same exposure,” he says. And, “If a risk
assessment is to be completed, a science policy choice (the
phrase used by the NRC [National Research Council]) must be made
about the model to be used…. SEVERAL SIMILAR CHOICES HAVING
TO DO WITH OTHER UNCERTAINTIES ARE NEEDED TO COMPLETE MOST RISK
ASSESSMENTS,” Rodricks says [emphasis added]. In other words,
guesswork is central to every risk assessment.
Interestingly, Rodricks does not elaborate on the “several
similar choices” that go into every risk assessment–perhaps
because to do so would reveal that risk assessment is not the
scientific enterprise it appears to be, but is in fact largely a
political exercise. Rodricks does say that, “To base risk
assessment and risk management decisions upon such uncertain
scientific knowledge is bad public policy” [pg. 227].
Unfortunately, his answer is not to reduce our reliance upon
risk assessment but to do more studies, as if more studies will
eliminate all the important uncertainties in our scientific
knowledge of the effects of chemicals on humans and ecosystems.
Dream on. (See RHWN #377.)
From the viewpoint of someone eager to dump exotic new chemicals
into the ecosystem, this is the real beauty of risk assessment:
no matter how flimsy the base of information, every risk
assessment still gives the same satisfyingly numerical answer.
Furthermore, the answer you get is completely dependent upon the
“science policy choices” that you made, yet the final result
appears to be entirely objective and impartial. A political
choice swaddled in scientific trappings. This emperor is really
a snappy dresser!
Back to our recently-discovered ignorance about hormone
disrupting chemicals. In testimony before Congress last
October, Richard Wiles of the Environmental Working Group in
Washington, D.C., showed that we now put 220 million pounds of
endocrine-disrupting pesticidal chemicals directly onto and into
our food supply each year. [2] The pesticide found most often on
fruits and vegetables is endosulfan and it is an
endocrine-disrupter. Analysis of data from the Food and Drug
Administration’s (FDA) routine food monitoring program revealed
endosulfan on 21 out of 22 samples (95%) of fruits and
vegetables heavily consumed by infants and children, Wiles
testified.
At the same hearing, Dr. Earl Gray, a section chief in U.S.
EPA’s Health Effects Research Laboratory, reported his latest
findings on a fungicide called Vinclozolin — a pesticide
currently in use with EPA’s approval. [3] “Vinclozolin, when
administered to a pregnant rat, demasculinizes the male fetuses
in a manner identical to the anti-androgenic drug flutamide and
in effect these effects are so obvious that all of the males
look like females at birth,” Dr. Gray testified. He went on to
say, “In the rats in vivo [in other words, in studies of living
animals] this chemical blocks development of the fetal male rat
reproductive system so that they have undescended testes, they
develop a vaginal pouch like a female, the penis fails to
develop normally, and they retain nipples which male rats do not
normally do.”
Congressman Henry Waxman (D-Ca.) asked Gray, “Do you think that
Vinclozolin could have the same kinds of hormonal effects on
humans?” Gray answered, “I think that is quite possible, and
likely.”
Earlier in the hearing, Dr. Theo Colborn, an expert on
endocrine-disrupting chemicals, made the point that a single
dose of some chemicals can disturb a baby’s normal sexual
development. She said, “Nor is it comforting for a woman to
realize that it takes only one very low dose, it is called a
hit, of an endocrine-disrupting chemical during one of the many
critical stages of embryonic development during her pregnancy to
change the course of sexual development of her baby.” [4]
So long as we use risk assessment as our chief guide for
allowing chemical exposures, we can expect an unending series of
unpleasant surprises as today’s “safe” dose is discovered
tomorrow to be unsafe.
Joe Rodricks makes a clear distinction in his book between risk
assessment and risk management. First you assess the risk, then
government acts to protect the public, he says. Oh, this
emperor is really looking natty! How does this work in the real
world?
At the hearing last October, Congressman Waxman asked EPA’s Dr.
Lynn Goldman how long it would take before Vinclozolin would be
removed from the American food supply. Note the rich fudge of
risk assessor’s language in Dr. Goldman’s response:
“Well, the decision could involve a number of considerations.
What we are going to be concerned about is the issue of not only
the inherent risk of the pesticide, but also the science that
tells us about the exposures that might be expected given the
various uses that are allowed under the label, and so that there
could be a variety of actions that are taken ranging from, as
you suggested, perhaps not even allowing the registration to
only allowing the registration on certain uses that are safe, to
allowing all of the uses that are currently allowed if we are
very certain that we have no exposures that would cause harm to
those who might come in contact with it, so the decision–this
piece of information is one piece of the scientific data that
needs to be examined to make a good decision about this
compound, but obviously a very important piece.” [5]
How could EPA ever determine “uses that are safe?” How could
EPA ever become “very certain” that “we have no exposures that
could cause harm?” Science simply can never provide such
assurances. So EPA will rely on–what else?–risk assessment.
How can we really be sure that no humans or wildlife will be
harmed by Vinclozolin? There’s only one way: Don’t use any
Vinclozolin. Pollution prevention.
===============
[1] Joseph V. Rodricks, CALCULATED RISKS (New York: Cambridge
University Press, 1992; paperback edition, 1994).
[3] Gray testimony in HEALTH EFFECTS…, cited in note 2 above,
pgs. 123-126.
[4] Colborn testimony in HEALTH EFFECTS…, cited in note 2
above, pg. 38.
[5] Goldman testimony in HEALTH EFFECTS…, cited in note 2
above, pg. 127.