Our Greatest Accomplishment:
Grass-Roots Action Has Forced a Major Shift in Thinking
[This article, with some of the footnotes removed, appeared in
The Workbook [Southwest Research and Information Center, P.O.
Box 4524, Albuquerque, NM 87106] Vol. 19, No. 2 (Summer, 1994),
pgs. 86-90.]
Medical science has made impressive gains against acute
disease this century, but during the past 20 years it has become
obvious that chronic disease represents a much more difficult
challenge. Throughout the industrialized world, many chronic
diseases are steadily increasing. There is substantial and
growing evidence that these increases are linked to widespread
low-level chemical contamination of the environment. An
aggressive new environmental movement has come into being to
confront these human problems. Here is a brief, incomplete
catalog:
been increasing for 50 years, and continues to increase today;
particularly steep increases have occurred among cancers of the
testicles and prostate, the female breast, the brain, and the
kidney but the incidence of 10 other kinds of cancer has
relentlessly risen for five decades. [1]
heart defects, defects of the male genitalia, and facial clefts
— is rising. [2]
are having trouble reproducing; [3] this may be due in part to a
50% decline in sperm count that has been documented among men
worldwide over the past 50 years, a decline that is apparently
continuing. [4]
increasing; the number of ectopic pregnancies is rising, [5] as is
the prevalence of endometriosis, a painful disease associated
with the menstrual cycle, which now afflicts 5 million American
women. In 1960, breast cancer struck one in 20 women; today, it
strikes one in 9. [6]
[Lou Gehrig’s disease] and Parkinson’s disease — are increasing.
Some public health leaders suspect chemical contamination is the
cause. [7]
myeloma, and septicemia). [8]
system, such as asthma and diabetes, is steadily increasing. [9]
sensitivity” — a disease characterized by extreme sensitivity
to low levels of various chemicals, sometimes including odors
from new carpets, perfumes, and the fragrances in commercial
products such as waxes and detergents. Symptoms range in
severity from an itchy rash to coma. [10]
estimated 60,000 workers each year. [11] In addition to these
preventable deaths, workplace conditions cause an estimated
350,000 new cases of serious illness among workers each year,
according to Philip J. Landrigan, chairman of the department of
community medicine at the Mount Sinai School of Medicine in New
York.
given year somewhere between 2 and 4 million American children
(and approximately 400,000 fetuses) have sufficient lead in
their blood to diminish their IQ, reduce their physical stature,
damage their hearing, decrease their hand-eye coordination and
impair their ability to pay attention in school. [12] This
damage is thought to be permanent. Lead is a soft, gray toxic
metal that has been mined from the earth and formed into useful
items for 5000 years. Its toxicity to miners and workers was
well established among ancient Greeks and Romans long before the
birth of Christ.
This list is not exhaustive but indicates a sea of troubles
rising, much of it linked to chemical contamination.
The grass-roots movement for environmental justice, which
has come into being to confront these problems, has had many
local victories. But its most far-reaching accomplishment has
been to force a change in the way we think about controlling
chemical contamination — from managing pollution to preventing
pollution. This is a very fundamental shift. Major polluters
and their acolytes in government are now giving lip service to
“pollution prevention” but almost no one in the U.S. has yet put
it into practice to any significant degree. What is most
important is that the new approach has been spelled out and is
now available as a standard against which to measure any claims
of pollution prevention.
As the American Chemical Society noted in 1993, [13] there
are two basic philosophies of chemical regulation: for 20 years
the U.S. has been using a permissive chemical-by-chemical
approach, which assumes all chemicals are innocent until proven
guilty, and which demands rigorous scientific proof of harm
before regulation can occur. We call this the “prove harm”
philosophy of chemical regulation. This philosophy assumes that
every ecosystem and every species has some “assimilative
capacity,” some capacity to absorb harm without suffering
irreversible damage. This philosophy assumes further that (a)
scientists can discover the assimilative capacity of every
ecosystem and every species (“risk assessment” is the technique
that is supposed to accomplish this); that (b) regulators can
and will then establish effective limits on the cumulative
harmful activities so as to avoid irreversible damage; and that
(c) we already know which substances are harmful and which are
not; or, in the case of substances that we never suspected are
harmful, we will be warned of their possible dangers by
traumatic but sub-lethal shocks that alert us to the danger
before it is too late. Recent history indicates clearly that
all three of these assumptions are simply wrong.
Happily, an alternative philosophy of chemical regulation
has developed in recent years in Europe and in some obscure
corners of the U.S. government. These changes have been driven
by growing citizen demands at the local level, world-wide.
The new philosophy — which we call clean technology and
others call clean production or industrial ecology — has been
articulated most succinctly in 2 reports from the International
Joint Commission (IJC), the U.S.-and-Canadian governmental body
in charge of water quality for the Great Lakes.
In its sixth (1992) and seventh (1994) biennial reports,
the IJC has described and advocated a pollution-prevention
approach commensurate with the size and nature of the
problem. [14]
Basically, the clean technology approach regulates whole
classes of chemicals instead of one chemical at a time. Given
that some 60,000 chemicals are now produced in commercial
quantities, with 500 to 1000 new ones introduced into commerce
each year, regulating classes of chemicals is simpler and more
manageable than the chemical-by-chemical one-at-a-time approach.
Eliminate Persistent Toxic Substances
The IJC now recommends defining a class of chemicals called
“persistent toxic substances,” which should then be eliminated
because they cannot be managed safely.
The IJC recommends that a persistent toxic substance be
defined as any toxic chemical that bioaccumulates (accumulates
in food chains), or any toxic chemical that has a half-life
greater than eight weeks in any medium (water, air, sediment,
soil, or living things). (The half-life is the time it takes
for half of any substance to degrade and disappear once it has
been released into the environment.) Toxic substances with
either of these characteristics should be eliminated, the IJC
says. [15]
The IJC takes its definition of a toxic substance from the
1978 Great Lakes Water Quality Agreement, which has been adopted
by the federal government of the U.S. and Canada:
A toxic substance is anything that can “cause death,
disease, behavioral abnormalities, cancer, genetic mutations,
physiological or reproductive malfunctions or physical
deformities in any organism, or its offspring, or which can
become poisonous after concentrating in the food chain or in
combination with other substances.”
A substance bioaccumulates if its concentration increases
as it moves through the food chain. For example, DDT may be
found at one ppm (part per million) in fish and at 10 ppm in
fish- eating birds. Thus DDT bioaccumulates. The IJC says any
toxic substance that bioaccumulates should be eliminated.
A substance is defined as persistent if it has a half-life
greater than 8 weeks in any medium (air, water, soil, sediment,
or living things). As noted above, the “half life” of a
substance is the time it takes for half of it to degrade and
disappear. For example, DDT has a “half-life” of about 59 years
in temperate climates; if a pound of DDT is released into soil
today, half of it will still exist 59 years from now. After 10
half-lives only a small fraction of the original amount exists
(1/1024), so 10 half-lives is the rule of thumb for how long a
substance remains in the environment. By this measure, DDT
remains in the environment for 590 years after it has been
released. The IJC recommends that any persistent toxic
substance be eliminated.
Adopt The Principle of Precautionary Action
The IJC recommends that the U.S. and Canada adopt the
principle of precautionary action. The precautionary principle
says that, to avoid irreparable harm to the environment and to
human health, precautionary action should be taken wherever it
is acknowledged that a practice (or substance) could cause harm,
even without conclusive scientific proof that it has caused harm
or does cause harm, the practice (or emissions of the substance)
should be prevented and eliminated. [16]
Adopt A Weight-of-the-Evidence Approach
The IJC recommends that the U.S. and Canada adopt a “weight
of the evidence” approach, not waiting for scientific certainty
to be established but taking action to protect against toxics as
soon as the “weight of the evidence” indicates the need for
action. [17]
End Reliance on Risk Assessment and Numerical Standards
In recommending a “weight of the evidence” approach and in
recommending the elimination of all persistent toxic substances,
the IJC has turned away from risk assessment and numerical
standards. [18] Today risk assessment and numerical standards
form the backbone of the U.S. regulatory philosophy for
controlling toxic substances. Numerical standards supposedly
reflect the “assimilative capacity” of ecosystems, and humans.
Risk assessment is the technique employed to establish numerical
standards.
Adopt the Principle of Reverse Onus
The principle of “reverse onus” says that chemicals should
be considered guilty until proven innocent, not the other way
around. Accordingly, the proponents of a chemical’s production
and use should bear responsibility for proving that a substance
is not harmful to the environment or human health. Under the
present system, society at large bears that responsibility and
regulatory action cannot be taken until specific, widespread
harm has been conclusively demonstrated and rigorously
documented. The IJC says, “This principle [of reverse onus]
should, in the Commission’s view, be adopted for all human-made
chemicals shown or reasonably suspected to be persistent and
toxic, including those already manufactured or otherwise in
commerce.” [19]
In sum, the IJC said in 1992, “It is clear to us that
persistent toxic substances have caused widespread injury to the
environment and to human health. As a society we can no longer
afford to tolerate their presence in our environment and in our
bodies…. Hence, if a chemical or group of chemicals is
persistent, toxic and bioaccumulative, we should immediately
begin a process to eliminate it. Since it seems impossible to
eliminate discharges of these chemicals through other means, a
policy of banning or sunsetting their manufacture, distribution,
storage, use and disposal appears to be the only
alternative.” [20] The IJC defines “sunsetting” as “a
comprehensive process to restrict, phase out, and eventually ban
the manufacture, generation, use and disposal of a persistent
toxic substance.” [21]
The IJC said, “Such a strategy should recognize that all
persistent toxic substances are dangerous to the environment,
deleterious to the human condition, and can no longer be
tolerated in the ecosystem, whether or not unassailable
scientific proof of acute or chronic damage is universally
accepted…. Therefore the focus must be on preventing the
generation of persistent toxic substances in the first place,
rather than trying to control their use, release, and disposal
after they are produced.” [22]
Implementing the new philosophy of chemical control will
not be easy. Thanks to so-called “free trade” laws,
corporations are rapidly gaining new powers and new freedoms to
do as they please, to move anywhere where labor is cheap and
pollution laws are lax. Governments and democratic institutions
at all levels are being weakened. Nevertheless, for reasons
given earlier, the survival of the human species is now in
doubt; therefore we have no choice but to meet the challenge by
developing a world-wide grass-roots movement for environmental
justice, to confront the poisoners everywhere, to force them to
adopt a real pollution prevention philosophy backed by real
pollution prevention programs. I have no illusions that it will
be easy, but I also have no doubt that humanity is up to the
challenge.
                                                                    
–Peter Montague
END OF ARTICLE
SIDEBAR
We do not know what all of the effects of human
exposure will be over many years. Future research
will clarify whether low- level and long-term
exposures, repeated exposures, or isolated
short-term exposures at sensitive stages of fetal
development are most critical. For the Commission,
however, there is sufficient evidence now to infer
a real risk of serious impacts in humans.
Increasingly, human data support this conclusion.
IMPLICATIONS OF INACTION
The questions then become: what–if any–risks
of injury are we as individuals and as a society
willing to accept? How long can we afford to wait
before we act? Why take any risks of having such
potentially devastating results? In this vein, the
Commission poses a number of other specific but
very fundamental questions:
startling decrease in sperm count and the alarming
increase in the incidence of male genital tract
disorders are in fact caused in part as a result of
in utero exposure to elevated levels of
environmental estrogens?
epidemic in breast cancer is a result in part of
the great numbers and quantities of estrogen-like
compounds that have been and are being released
into the environment?
performance and increasing incidence of problem
behaviour [sic] in school children are not functions
of the educational system? What if they are the
result of exposure to developmental toxicants that
have been and are being released into the
children’s and parents’ environment, or to which
they have been exposed in utero?
The implications of any of the above questions
being answered in the affirmative are
overwhelming. The implications of all of the above
questions being answered in the affirmative are
catastrophic, in terms of human suffering and the
potential liability for that suffering and
attendant health costs. Mounting evidence points to
the latter possibility. Surely, there can be no
more compelling self interest to force us to come
to grips with this problem than the spectre of
damaging the integrity of our own species and its
entire environment.
Source of this quotation: International Joint
Commission, Seventh Biennial Report on Great Lakes
Water Quality (Washington, DC and Ottawa, Ontario:
International Joint Commission, 1994), pg. 5. This
report is available free from the International
Joint Commission, 1250 23rd Street, N.W., Suite
100, Washington, DC 20440; telephone: (202)
736-9000.
End Notes
[15] International Joint Commission, Sixth Biennial Report
(cited above), pgs. 4, 57.
The United Nations Environment Program (UNEP) Governing
Council on May 25, 1989, adopted Decision 15/27 urging all
governments to adopt “the ‘principle of precautionary action’ as
the basis of their policy with regard to the prevention and
elimination of marine pollution.” Part of the rationale given
was “that waiting for scientific proof regarding the impact of
pollutants discharged into the marine environment may result in
irreparable damage to the marine environment and in human
suffering.”
[17] International Joint Commission, Sixth Biennial Report
(cited above), pgs. 22-23.
[18] International Joint Commission, Seventh Biennial Report
(cited above), pg. 28.
[19] International Joint Commission, Seventh Biennial Report
(cited above), pg. 9.
[20] International Joint Commission, Sixth Biennial Report
(cited above), pg. 4.
[21] International Joint Commission, Sixth Biennial Report
(cited above), pg. 25.
[22] International Joint Commission, Sixth Biennial Report
(cited above), pgs. 5, 25.