If you have been following the story about “Deceit and Denial: The Deadly Politics of Industrial Pollution”, by Gerald Markowitz and David Rosner, you will be interested in a new resource that is a great adjunct to the book. And, if you haven’t been following the story, you can get caught up by reading about it here, here, and best of all, here.
Markowitz and Rosner have accumulated numerous powerful critics in publishing the book. As the authors have become drawn into vinyl chloride litigation against various chemical manufacturers, they have undergone attacks on their professional standards, ethics and integrity, as a way of discrediting their value as expert witnesses.
They are now replying to these attacks, by creating the web site deceitanddenial.org. A primary role for this web site is to provide to historians and other researchers (and bloggers!) with links to the documentation they’ve cited in their book:
Because one of the key accusations is that we inadequately and inaccurately documented our statements in Deceit and Denial, we will be posting on this site the documents we used in our footnotes for the scholarly community to evaluate.
In the meantime, they also provide a link to the Environmental Working Group’s Chemical Industry Archives, an excellent resource of chemical industry documents brought to light through discovery during lawsuits and FOIA requests. These are very important resources for viewing the dark history of occupational and environmental health in the U.S. as seen through the eyes of the chemical industry.
For me, it was worth seeing Markowitz’s and Rosner’s site just for the 309 page timeline of vinyl chloride history.
I’m taking today off from mercury, because I need the time to digest the wealth of material available (see here, here, here, here and here, if you’re game to read ahead).
I’ve also found some great sources of information on Resources for the Future, a think tank in the best sense of the word. RFF has a very digestible news summary of mercury regulation and legislation. It also provides a comparison of the different multipollutant regulatory and legislative proposals here.
The House of Representatives Resource Committee (RC) report on mercury leaves a trail of talking points like bread crumbs, in an attempt to lead the reader to this conclusion:
There has been no credible evidence of harm to pregnant women or their unborn children from regular consumption of fish. (page 3 of RC’s report)
However, it’s a trail that leads away, not towards enlightenment about mercury risks.
A large part of the RC’s complaint has to do with the EPA’s Reference Dose (RfD) for methylmercury. The RfD has been used to develop the fish advisory for methylmercury. It is also the benchmark used to evaluate the blood-mercury data collected during the NHANES survey. It is one of the reasons that there is such concern about health risks potentially associated with mercury emissions from power plants. The RfD for methyl mercury is based on a blood mercury level of 58 ug/L, which is the lower 95% confidence interval on an estimated dose that doubles the prevalence of young children with scores on a test of intellectual development that would fall into the clinically subnormal range. The EPA applied a 10-fold uncertainty factor to this value to obtain the RfD. So, the RfD for methylmercury is intended to protect intellectual development of children.
The complaints that the RC makes about the RfD are: 1) it is the most restrictive protective level in the world; 2) it is based on results from a single test of children that is not sensitive enough to discern effects from mercury alone; 3) the study subjects were also exposed to very high levels of toxic organic compounds like DDT and PCBs that mimic mercury’s effects and can make them worse; 4) the study is also not reflective of U.S. fish consumption (page 3 of RC’s report).
A little bit of conceptual ground clearing is needed before we deconstruct these factoids. As has been discussed on this blog, the RfD is defined as an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily exposure to the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime. The RfD is viewed as a useful reference point for gauging the potential for adverse effects at other levels of exposure.
Important qualifiers to keep in mind in thinking about the RfD are: 1) doses at the RfD (or less) are not likely to be associated with any health risks. They are likely to be protective of human health and of little regulatory concern; 2) in contrast, as the level and frequency of exposures exceeding the RfD increase, the probability of adverse effects being observed in a human population also increases; 3) the conclusion that all doses below the RfD are acceptable and that all doses in excess of the RfD are unacceptable cannot be categorically stated.
With this in mind, on to the factoids:
“It is the most restrictive protective level in the world”
An inane argument to be brought up in support of the RC’s “no credible evidence” thesis. Whether or not the RfD is restrictive isn’t terribly pertinent. Whether or not it is scientifically robust is pertinent. We discuss that point in just a moment, but it is important to note that the National Academy of Sciences (NAS) report on methylmercury endorsed the EPA’s RfD value.
“It is based on results from a single test of children that is not sensitive enough to discern effects from mercury alone”
A statement that exposes a wealth of ignorance about how studies are used to evaluate human health risks from chemical exposure. The RfD is developed from the one critical study that is well conducted and identifies the most sensitive end point of toxicity. This one study is selected from the weight of evidence for adverse effects for a chemical. Prior selecting the critical study, the accumulated studies are reviewed to make sure that the chemical in question is associated with specific adverse effects (hazard identification) and that there is evidence of a relationship between levels of exposure and frequency and/or severity of adverse effects (dose-response assessment). The NAS report says:
Chronic, low-dose prenatal MeHg exposure from maternal consumption of fish has been associated with more subtle end points of neurotoxicity in children. Those end points include poor performance on neurobehavioral tests, particularly on tests of attention, fine-motor function, language, visual-spatial abilities (e.g., drawing), and verbal memory. Of three large epidemiological studies, two studies — one conducted in the Faroe Islands and one in New Zealand — found such associations, but those effects were not seen in a major study conducted in the Seychelles islands. (Page 4, Executive Summary)
Each of these three large epidemiological studies was judged by NAS to be well designed and carefully conducted, and each examined prenatal methylmercury exposures within the range of the general U.S. population exposures. In the Faroe Islands and New Zealand studies, methylmercury exposure was associated with poor neurodevelopmental outcomes, but no relation with outcome was seen in the Seychelles study.
The NAS considered that the differences in findings between the Faroe and the Seychelles studies might be explained by differences in the study designs and in the characteristics of the study populations. These differences included the ways methylmercury exposure was measured (in umbilical-cord blood versus maternal hair), the types of neurological and psychological testing performed on children, the ages of testing between the two studies (7 years versus 5.5 years of age), and the patterns of methylmercury exposure between the two study settings. Those differences in study characteristics did not explain the differences in the findings, when the New Zealand study was included in the analysis. The New Zealand study used a research design similar to the Seychelles study. The patterns of exposure to methylmercury observed in the New Zealand study were similar to the Seychelles study. However, the New Zealand study reported associations of neurodevelopmental effects with methylmercury exposure that were similar to those found in the Faroe Islands. The NAS report goes on to say:
The committee concludes that there do not appear to be any serious flaws in the design and conduct of the Seychelles, Faroe Islands, and New Zealand studies that would preclude their use in a risk assessment. However, because there is a large body of scientific evidence showing adverse neurodevelopmental effects, including well-designed epidemiological studies, the committee concludes that an RfD should not be derived from a study, such as the Seychelles study, that did not observe any associations with MeHg.
In comparing the studies that observed effects, the strengths of the New Zealand study include an ethnically mixed population and the use of end points that are more valid for predicting school performance. The advantages of the Faroe Islands study over the New Zealand study include a larger study population, the use of two measures of exposure (i.e., hair and umbilical-cord blood), extensive peer review in the epidemiological literature, and re-analysis in response to questions raised by panelists at a 1998 NIEHS workshop and by this committee in the course of its deliberations. (Page 6 of the Executive Summary)
At the end of the day, the NAS committee concluded that the Faroe Islands study was the most appropriate study for deriving the RfD. The reasons for selecting it directly rebut the RC’s contention that “just one study” was considered (as if it is a weak reed), and an insufficiently powerful study at that. A misleading statement that appears to have been skillfully crafted.
“The study subjects were also exposed to very high levels of toxic organic compounds like DDT and PCBs that mimic mercury’s effects and can make them worse”
This appears to be an attempt to discredit the Faroe Island researchers by alleging that they failed to account for confounding factors in evaluating relationships between neurodevelopmental effects and methylmercury exposure. That wasn’t the case, however, as addressed by the NAS report:
The Faroe Islands population was also exposed to relatively high levels of polychlorinated biphenyls (PCBs). However, on the basis of an analysis of the data, the committee concluded that the adverse effects found in the Faroe Islands study, including those seen in the Boston Naming Test, were not attributable to PCB exposure and that PCB exposure did not invalidate the use of the Faroe Islands study as the basis of risk assessment for MeHg. (Page 6 of the Executive Summary)
A side point brought up by the RC’s factoid: people are not exposed to chemicals in isolation. The RfD for methylmercury, by itself, does not account for the potential for neurodevelopmental effects from multiple chemicals, such as PCBs, chlorinated pesticides (including DDT), dioxins and furans, and brominated fire retardants, and by itself, may not necessarily be protective, if there is also exposure to those other substances. Tools exist for addressing such cumulative risks – but that is a topic for another day.
“The study is also not reflective of U.S. fish consumption”
Putting aside the fact the NAS report stated that each epidemiological study examined prenatal methylmercury exposures within the range of the general U.S. population exposures, this assertion (it doesn’t really even rise to the level of factoid) belies a very narrow view of the world, or even the U.S. Fish consumers such as low-income or minority subsistence fishermen, Native Americans or hard-core recreational anglers may have typical consumption rates that are substantially higher than most Americans. While I haven’t yet done the analysis on this one yet (will I have to fact-check all of the RC’s stuff??), neither has the RC staff. These studies probably aren’t reflective of fish consumption for white upper-middle class professionals in Washington, D.C., but then again, Rep. Pombo’s aides just may need to get out a little more often.
There’s more stuff to deconstruct, but we all probably need a break. There will be more, later.
Such people are not total hacks -- that is to say, while they may be Satan's emissaries on earth, they do take professional pride in their own work, and add filigrees and flourishes partly to increase effectiveness but also, I believe, out of pure love of craft. For example, there is some obvious merit to the author's accusations against the sugar barons -- among others, that they had hooked up with pure-food types not out of altruism but as a way to fight Splenda's increasing share of the sweetener market. This is the spoonful of sucralose, so to speak, that helps work down the public's gullet a larger message: that people who oppose synthetic foods on whatever grounds are anti-technology "chemicalphobes."
Organizations such as this are not about arguing a case, but adding strands to a narrative. Facts may be used as part of the grapeshot, but they are by no means the only or even most important part of the armamature. Painting an investigation of questionable scientific assertions as an inquisition on the order of Galileo's, for example, lifts the issue out of the debating chamber and into the realm of dreams. You certainly don't want to side with inquisitors or chemicalphobes. Now eat this chlorinated sugar.
The reference to Galileo and the Inquisition is a column by Steven Milloy about Bjorn Lomborg, the “skeptical environmentalist”, who has been criticized by numerous scientists over the evidence and reasoning he uses to support his views that concerns about global warming have been overblown. But, as Alicublog says, it’s not about careful reasoning, but simply manufacturing narrative.
The two cultures are alive and kicking, when you can read an essay about fat written by an academic, without a word about the health consequences. Laura Kipnis’s essay on fat, femininity and feminism made the point that
“[w]omen here may pant, ‘I'm doing it for myself’ while strapped to their treadmills, but the fact is that the beauty culture is a heterosexual institution, and to the extent that women participate in its rituals, they, too, are propping up a heterosexual society and its norms.”
However, at a time when the words “obesity” and “epidemic” can be found in the same sentence, it is specious to attribute all efforts by women to improve their fitness and nutrition as enslavement to the beauty culture. Some may understand that a certain amount of lean body mass is better for you than fat.
In the documentary “Supersize Me”, Morgan Spurlock subsists on meals entirely from McDonalds for a month. Amidst the substantial gain in weight, skyrocketing cholesterol level, and neurobehavioral symptoms including headaches, mood swings, symptoms of addiction, and depressed libido, his doctors begin to observe clinically detectable adverse effects to his liver function. Food (not just food contaminants) as toxic exposure. Ick.
Obesity is becoming recognized as an environmental health problem with long-term consequences. The increasing incidence of type II diabetes in children parallels the rising prevalence of obesity. Other disorders associated with obesity include hypertension, hypercholesterolemia, heart disease, asthma, emotional health concerns (such as depression and low self-esteem), and orthopedic disorders. The environmental determinants of obesity include the built environment which does not encourage physical activity (urban bike paths really suck where I live), and an abundance of more readily available poor nutritional choices; socioeconomic factors result in the environmental causes of obesity disproportionately affecting minority and low-income families.
I’m not quite as ready as Michael Jacobson to conclude that advertising, pricing, packaging, and availability all encourage Americans to eat more food. But it makes sense that selling more food, and particularly selling more processed food, makes for better shareholder value for the food industry. It is in that light that you need to interpret messages such as this one, “snack foods don’t fatten kids”, a news report by Steven Milloy, citing a recent Harvard University study. The study says that, too. . . actually, what it really says is this:
Our results suggest that although snack foods may have low nutritional value, they were not an important independent determinant of weight gain among children and adolescents.
So, snack foods aren’t bad for your kid, if he or she is also getting their five to nine servings of fruits and vegetables along with their 30 minutes of exercise per day. However, the causes of obesity are multifactorial (those words “independent determinant” in the conclusion speak volumes). In other words, if they eat snack foods along with poor diet and inactivity, your kids are going to get fat; the Harvard study suggests that overweight parents may be associated with overweight kids.
Aside from Steven Milloy citing one study, why are government diet and exercise guidelines encouraging people to eat less highly processed foods with unhealthful fat, added sugar and too much salt, if snack foods are so benign?
I’ve wandered a bit off topic, but at a time when lifestyle related disorders and illnesses are helping to bankrupt people, maybe our focus on obesity needs to be on the health rather than beauty aspects.
Bob Whitson (Howling at a Waning Moon) has been actively following the saga of Clear Skies legislation as it makes its way through Congress. It seems to be struggling. The bill enabling Clear Skies has been delayed in committee, amended heavily (to the point that a utility lobbyist characterized it as considerably to the left of the original proposal), and the Bush Administration’s unwillingness to act on carbon dioxide emissions could derail the legislation.
Here’s an idea of the growing sense of desperation among the sponsors of Clear Skies: Sen. James Inhofe, chairman of the Senate Environment and Public Works Committee, where the Clear Skies bill currently resides, has directed two national organizations that oppose Clear Skies to turn over their financial and tax records to the Senate.
The two groups are the State and Territorial Air Pollution Program Administrators (STAPPA), which represents 48 state air pollution control agencies, and the Association of Local Air Pollution Control Officials (ALAPCO), which represents more than 165 local agencies. The STAPPA/ALAPCO web site can be found here. The request for financial records comes on the heels of testimony from these groups, which stated that Clear Skies “fails on every one of our associations' core principals," was "far too lenient" on polluters and would undermine "states' abilities to protect air quality."
After the testimony, in a letter with follow-up questions, Inhofe included a request for financial statements, membership lists and tax returns for the last six years for both groups. Reportedly, the Senate committee asked for the information because of long-standing concerns about the decision-making process of the state air pollution group, and was pursuing those questions as part of its oversight responsibility.
The majority staff director for the committee, Andrew Wheeler, said the request for the groups' documents did not stem from their criticism of the legislation. He said the panel wanted to determine whether the groups represented only regulators' views or whether they also were subsidized by outside interests, including environmentalists or foundations. The funding, Wheeler said, "goes to who they're speaking for."
"It has nothing to do with 'Clear Skies,' " says Mr. Wheeler. "If we wanted to intimidate them, we would have done it before they testified, not after."
Intimidation and the U.S. Senate are two concepts that wouldn’t seem to go together. But these are different times. Nice organizations you got here. Be a shame if something happened to them, know what I mean? MyDD eloquently expresses the outrage about the intimidation part.
The story can also be found in the LA Times. Revere over at Effect Measure also beat me to the punch on this story.
As noted in Effect Measure and in this blog, that august scientific group, being the leading Republican members of the Resources Committee of the House of Representatives has prepared a report concluding that the risks of mercury pollution have been overstated. Not a surprising conclusion when you consider the source, which might actually be the right-wing, funded by Exxon-Mobil think tank, Frontiers of Freedom.
While the report isn’t terribly useful for informing the debate about the mercury emissions from power plants or mercury risks (c’mon, did you really think it was there for any reason other than an excuse for a press release), I’ve put it to use as a platform for deconstructing some of the right’s talking points about mercury.
I’ve been wanting to write about the EPA’s Reference Dose for methyl mercury for sometime now, and this provides the perfect opportunity. But that post is taking awhile to prepare; because unlike some people, I’m trying to frame the issues transparently and in a manner that readers might find useful. So, in the meantime, let’s look at one of the factoids, instead.
The Resources Committee report (which I’ll call the RC report herein) poses the question, “others wonder whether the overall increase in global mercury emissions and deposition mean that Americans will be exposed to higher concentrations of methylmercury in fish.” In answering that question, it offers “recently published and ongoing scientific research can provide some insight to this question”. One of those pieces of research is this study published in Environmental Health Perspectives (referred to here as the EHP paper), which the RC report characterizes as follows, with a quote from the study:
Concentrations of mercury, lead and persistent organic pollutants in the umbilical cord blood of Inuit infants born in Nunavik, Quebec decreased between 1994 and 2001.
“Inuit inhabitants of Nunavik consume great quantities of marine food and are therefore exposed to high doses of food chain contaminants. …We analyzed 251 cord blood samples collected from 1994 through 2001 for polychlorinated biphenyls (PCBs), dichlorodiphenyl trichloroethane (DDT), dichlorodiphenyl dichloroethylene (DDE), hexachlorobenzene (HCB), chlordanes, lead and mercury. Using an exponential model, we found strongly significant decreasing trend for PCBs (7.9% per year, p <0.001), DDE (9.1% per year, p < 0.001), DDT (8.2% per year, p< 0.001), and HCB (6.6% per year, p < 0.01). No significant trends were detected for chlordanes. A significant reduction of lead and mercury concentrations was found [i.e., by more than 8% decrease per year], ...”
The quote appears to have been lifted from the abstract of the EHP paper. Those who bother to read further into the paper will find the authors’s opinions about why the trends in mercury, lead and chlorinated hydrocarbon compounds looked like this.
The chlorinated hydrocarbon trends (i.e. PCBs and the pesticides) were explained by the restrictions in the use of the substances since the 1970s, though the authors suggest that some foodchain exposures could still occur from global cycling and long-range transport of these substances. They also note the changes in the Inuit diet as a possible factor in exposure reduction to chlorinated hydrocarbon compounds:
The eating habits of Inuit populations have changed enormously during the last 50 years. Since market-bought food has been introduced in their diet, added carbohydrates, junk food, pork, chicken, milk products, and other "foreign" food items have become increasingly popular, especially among adolescents and young adults. . . . Market food usually has a lower trophic level than does traditional Inuit food and is consequently less contaminated by POPs. This is reflected by the much lower mean concentrations of PCBs and chlorinated pesticides detected in cord blood samples from populations whose diet is almost exclusively composed of market-bought food, such as those in southern Québec. . . . However, although a gradual switch from traditional food to market food would result in a decrease in blood concentrations of food chain contaminants, it seems unlikely that dietary modifications would be of such magnitude that they alone would cause an annual decrease of 5-10% in the body burden of contaminants.
Ellipses have been added only to remove the citations in the original EHP paper. The authors also comment that:
The generalized downward tendency of OC concentrations observed in wildlife and human tissues throughout the world strongly suggests that the environmental contaminant burden is steadily declining and that this tendency can be observed in all levels of the food chain. We believe that most of the decrease of OC concentrations observed in this study can be attributed to descending concentrations in the traditional food items of the Inuit diet.
This seems to offer some explanations for the declining trend in chlorinated hydrocarbon compounds (PCBs, DDT, DDE, chlordane and HCB). What’s the story with lead?
We’re told that biomagnification does not play an important role in lead exposure. Lead shot used in hunting is considered to be a more important source of exposure. A recent ban in lead shot, coupled with an information campaign, are considered to be the reasons for the decline in lead exposures.
The RC report authors don’t explain what any of this has to do with mercury exposure, possibly because they may not have read through the entire EHP paper.
What do the EHP authors really say about mercury exposures?
Because no data on mercury temporal trends in arctic wildlife since 1994 are available, it is hazardous to speculate on the cause of the variations observed in this study. In contrast to OCs*, our results for mercury do not support an exponential decrease. The concentrations were constant across the years, except for markedly lower levels in 1998 and 2000. When we used n-3 fatty acids in cord blood as a surrogate of maternal fish consumption, we observed a slight decrease that was not statistically significant and was not related to the mercury concentration. We also searched for relation between mercury concentration and the numbers of beluga caught in each village between 1996 and 2001, but no relation was found (Department of Fisheries and Oceans 2002). A thorough dietary survey would be necessary in order to elucidate the cause of the variation observed. Other studies with longer follow-up would clarify whether the lower levels observed in 1998 and 2002 were due to chance or were signs of a new temporal trend of mercury.
*OC – organochlorine compounds – PCBs, DDT, DDE, chlordane and HCB; synonym for chlorinated hydrocarbon compounds.
This was a very interesting study that provided some deeper insights on persistent organic pollutant (POP) exposures. It also seems to provide some indication of the effectiveness of precautionary measures, such as restricting PCB and chlorinated pesticide use, reducing use of lead shot and lead health education measures. However, it appears that with the exception of a couple of years, there is no declining trend in mercury concentrations; and at this time, the most that can be said is that the trends in mercury exposures and their underlying explanations, are inconclusive. It is scarcely the definitive scientific statement to help the readers of the RC report judge “whether the overall increase in global mercury emissions and deposition mean that Americans will be exposed to higher concentrations of methylmercury in fish.”
So, what’s the deal here? Is this simply an example of sloppy scholarship? A lack of awareness (or concern) that anyone was going to do any fact checking? In the end, it doesn’t really matter that the report is really a 33 page, turgidly written op-ed piece, with footnotes. On the heels of this report are stories in a hundred different newspapers titled “Mercury Risks Overstated, House Panel Says”. Mission accomplished. But it does a deep disservice to anyone really trying to understand mercury issues.
This week, the Washington Post reports the results of a recent survey showing that area residents spend far longer getting to work and find themselves in daily traffic jams three times as often as commuters elsewhere. The median commute time to work is 30 minutes each way. However,
[i]n spite of increasingly long and frustrating commutes, the survey found that Washingtonians remain addicted to their cars. Three in four area commuters drive to work alone. Carpooling is no more prevalent here than it is elsewhere in the country. Metro is widely admired but largely bypassed, a boutique transportation system that serves a hard-core constituency but is viewed by most commuters as inconvenient.
Though the DC transportation system borders on collapse, according to local officials, people seem determine to continue to rely on their cars.
Government officials said they have all but given up on attempts to do anything extraordinary to solve area transportation problems. Instead, they are trying to broaden commuting options for people by experimenting with such proposals as allowing drivers without passengers to pay to use carpool lanes. But they said there was little they can do if people continue to live farther and farther from their jobs.
Beyond the impact to quality of life and the threat to energy security, there may be an environmental health cost from over-reliance on automobiles.
The air quality impacts principally associated with motor vehicles are emissions of hazardous air pollutants and reactive organic compounds. The hazardous air pollutants include known and probable human carcinogens (benzene, formaldehyde, 1,3-butadiene, diesel exhaust particulates) and respiratory irritants (formaldehyde, acetaldehyde and acrolein). More resources on HAPs from mobile sources can be found here. The reactive organic compounds along with oxides of nitrogen and ultraviolet light result in the formation of the respiratory irritant ozone.
The numerous epidemiological studies provide conflicting evidence about human cancer risks associated with the carcinogens emitted from motor vehicle emissions. An example of one study showing an association between childhood leukemia and traffic density is here; an example of one study finding no association is here.
There may be a question as to whether or not to worry about cancer risks from car and truck exhaust, but what is clearer is the linkage between vehicle emissions and ozone, and ozone and respiratory health. According to an EPA fact sheet, inhaling low levels of ozone can cause acute respiratory problems, aggravate asthma significantly reduce lung capacity, produce inflammation of lung tissue, lead to hospital admissions and emergency room visits (10 to 20 percent of all summertime respiratory-related hospital visits in the northeastern U.S. are associated with ozone exposures), and impair the body's immune system defenses, making people more susceptible to respiratory illnesses, including bronchitis and pneumonia. Up to 40 percent of the U.S. population may be at an increased respiratory risk from ozone (with a nod to Brooklyn Dodger for pointing me to the Yale and Johns Hopkins study). Many of the drivers, who live far from where the emissions are highest, don’t have to bear the costs associated with these problems.
The counties around Washington D.C. are non-attainment for ozone, meaning that concentrations of ozone in air are higher than the National Ambient Air Quality Standards. Emissions from the vehicles are a big part of that problem. With the transportation system nearing collapse, meaning more traffic jams, more time spent idling and more emissions, ozone impacts could be expected to worsen.
Driving less would help. A 1996 study published in Journal of the American Medical Association reported on traffic reduction strategies implemented in Atlanta during the Summer Olympics and the resulting health outcomes. The conclusion from the study was that efforts to reduce downtown traffic congestion in Atlanta during the Olympic Games resulted in decreased traffic density, a corresponding reduction in ozone and significantly lower rates of childhood asthma events. The Metro might be inconvenient, but so is asthma.
The latest in automotive systems: The Bad Boy, a ten-foot-tall $225,000 3.5-ton personal vehicle twice the size of a Hummer. It’s equipped with infrared cameras that peer through darkness. The flat-nosed cab can be bulletproofed. The dash can include a satellite phone, a two-way radio and a global-positioning system all alongside DVD, MP3 and CD players and a flip-out LCD screen. For $750,000, buyers can get the fully loaded "NBC" version that can overpressure the cab to provide protection from fallout, or biological and chemical weapons.
The one weak spot, other than a demonstration of extreme avarice, is the 6.9 miles per gallon mileage. That is offset by the 58 gallon diesel tank, which gives the Bad Boy a 400 mile cruising radius. Bushmaster 25 mm cannon not yet available as an option.
Mercury Rising – The House of Representatives Mercury Report
The House Resources Committee has issued a report today making the claim that the risks from mercury in the environment have been overstated, and that fears about mercury exposure are causing more harm by scaring people away from eating fish.
The report, written by aides to the majority Republican members of the committee, also asserted that there is no link scientifically between mercury emissions from coal-fired power plants and mercury levels in fish.
I’m reading through it and will have more of an analysis later. A copy can be downloaded here.
Reported in today’s Globe and Mail is a study published this week in Environmental Science and Technology that concludes household dust is a principal source of human exposure to polybrominated diphenyl ether (PBDE) fire retardants.
As noted previously here, concerns are growing about the human health risks from PBDE exposures.
In a sense, what is different about Libby, Montana is the White House suppressing EPA’s actions to alert the general public about the asbestos hazards in vermiculite. Otherwise, it is simply another story about a company trying to cover up unpleasant news about some public or occupational health and safety hazard it has created, a scene that has become depressingly familiar these days.
The good news is that the hazards associated with asbestos, and the means for controlling them, are well understood. A lot of information is available that can be used in managing your risks from asbestos exposure. The Libby, Montana story has alerted us to the potential for exposure to tremolite in vermiculite products. Other than that, the story remains pretty much the same – asbestos is potentially present in a wide range of products and materials in the home and workplace, and there are several occupations and parts of the country associated with an increased health risk from exposure to asbestos.
From EPA’s asbestos web site, there is a fact sheet with some interesting tidbits. For example, there have been common misunderstandings about EPA’s 1989 bans on asbestos-containing materials (ACM) and products or uses. In 1991 the U.S. Fifth Circuit Court of Appeals vacated much of the so-called "Asbestos Ban and Phaseout" rule and remanded it to the EPA. Thus, much of the original 1989 EPA ban on the U.S. manufacturing, importation, processing, or distribution in commerce of many asbestos-containing product categories was set aside and did not take effect. Six asbestos-containing product categories are still subject to the 1989 asbestos ban. However, EPA has no existing bans on most other asbestos-containing products or uses. The lists of product classes banned or still in commerce are presented in GETF’s report (see below).
EPA states that it does not track the manufacture, processing, or distribution in commerce of asbestos-containing products, and recommends that it would be prudent for a consumer or other buyer to inquire as to the presence of asbestos in particular products. Possible sources of that information would include inquiring of the dealer/supplier or manufacturer, refer to the product's "Material Safety Data Sheet" (MSDS), or consider having the material tested by a qualified laboratory for the presence of asbestos (as if people just “know” how to collect a bulk sample, submit it for laboratory analysis, select a qualified laboratory or interpret the results).
In other respects, EPA’s asbestos web site has a trove of information. The gem is a recent report published by the Global Environment and Technology Forum. There was a sense of hysteria about ACM in buildings in the 1980s, leading to premature and unwarranted abatement projects, which by the 1990s turned to complacency, resulting in some laxity in management programs. Based on interviews and meetings with various stakeholders, the GETF report found that:
The quality of work performed by people conducting response actions and managing asbestos in buildings may have declined during the past decade. This fact may not be universal across the country, or consistent by the types of facilities involved. Reasons expressed included less frequent enforcement of existing regulations; quality of training for asbestos workers, consultants, and regulatory personnel; misunderstanding of existing regulations; lack of independent oversight of projects in some states; and, conflicts among federal and state regulations.
The dilemma with asbestos is this: while it’s a known human carcinogen, the effects from exposure are delayed for many years. The magnitude of the risk with low environmental exposure levels is not known, and can only be calculated hypothetically. ACM that is not friable and in good condition has relatively little potential for human exposure. Proper techniques for managing ACM can reduce the risk of exposure. However, the costs of asbestos inspections, management, and control activities provide little tangible reward, since the outcome associated with effective management of ACM is – nothing (i.e. noone gets sick), and the outcome associated with failing to manage ACM properly isn’t discernable for decades, if at all. There’s a regulatory framework for asbestos, but it is seen as confusing, inconsistent and possibly a barrier to innovative solutions for managing asbestos. It isn’t readily apparent how effectively the regulations are being enforced.
So, as mentioned previously, we’re probably on our own. This means investing your hard-won time and money to deal with an issue that, in certain ways, is really the responsibility of someone else (government, building owner, facility manager, employer). More on this later.
Via Chris Mooney, I’ve been introduced to the Center for Progressive Regulation, a non-profit research and educational organization that “supports regulatory action to protect health, safety, and the environment, and rejects the conservative view that government’s only function is to increase the economic efficiency of private markets.”
CPR recently published a book presenting a new progressive agenda for public health and the environment. CPR argues that the need for such an initiative is plain – since 9-11, environmental problems have largely faded from public view, and in the shadows, regulated industries and their allies on the political right have been systematically dismantling the occupational and environmental health and safety regulatory framework that has grown up over the past 30 years. In arguing for creating a sense of urgency in addressing health and safety problems, CPR states that: [t]he warning signs are in plain evidence: an epidemic of asthma among children, unacceptably high levels of mercury in the blood of women of childbearing age, lead in household water supplies, outbreaks of cryptosporidium and other pathogens in drinking water, bizarre weather changes, mounting levels of pesticides in the natural environment, smog in all our major cities, and cars and workplaces that are still unsafe.
A brief introduction to the principles articulated by CPR can be found in a white paper available from their web site. It issues a needed rallying cry, and a series of key recommendations for re-energizing environmental protection at a time when it is not politically sexy. I don’t agree with all of the points that they have made (a topic for another day), but overall, CPR is a resource well worth checking in to.
By now, you should have heard about indictments issued by against W.R. Grace & Co. with regard to asbestos exposures of residents of Libby, Montana. The company and seven current and former executives have been indicted for environmental compliance violations along with conspiracy to cover up what happened in Libby. The indictment alleges that in the late 1970s the executives obtained knowledge of the toxic nature of tremolite asbestos in vermiculite mined at Libby through internal epidemiological, medical and toxicological studies, as well as through product testing. Despite legal requirements under the Toxic Substances Control Act to turn over to EPA the information they possessed, W.R. Grace and its officials failed to do so on numerous occasions. Grace and the officials deny the charges.
The EPA was prompted to act in 1999 after a report about the health crisis in the Seattle Post-Intelligencer by Andrew Schneider. In August of 2003, a federal court directed W.R. Grace to reimburse the EPA $54 million dollars for investigation and cleanup costs under Superfund. Grace is contesting the decision.
Because of the long latency period, the disease burden associated with asbestos will be with us for many years to come. A recent report in MMWR on occupationally-related pneumoconiosis mortality reported that most causes were trending downward, except for asbestosis, where the age-adjusted mortality nationally has increased from 0.54 in a million in 1968 to 6.88 in a million in 2000. The stats for this and other occupational lung diseases can be found at NIOSH’s Occupational Respiratory Disease Surveillance site, here. I used the web engine to check on mesothelioma incidence, the other scourge associated with asbestos exposure. Trend incidence for meso isn’t provided, because of changes in the ICD (International Classification of Diseases) classification, but the age-adjusted mortality is 11.63 in a million. It’s reasonable to assume that the mesothelioma trend mirrors asbestosis.
The product manufactured by Grace in Libby was the insulation Zonolite. Up to 35 million homes in the United States may be insulated with Zonolite. The EPA was set in 2002 to issue a public health emergency notice to the American public about potential hazards of asbestos in insulation and how to manage them. But in January 2003, the White House, through Office of Management and Budget squelched EPA’s proposal. The story broken in the St. Louis Post-Dispatch (by Andrew Schneider again) is posted here.
I guess it’s official. We’re on our own. Under the current administration, we can count on the government agencies to not only be constrained in managing health risks, but to also actively prevented in limiting information that would allow us to make our own risk management decisions. There is ample information available on asbestos to allow us to be more active participants in managing our risks – which I’ll talk about more tomorrow (promise – I’ll also finish up on mercury, too). I’m sure we all have better things to do with our time, but taking reasonable steps to protect one’s health is an imperative, especially with this bankruptcy thing looming.
Posting will be very light for a few days while I work off some backlog. Normal traffic will return next week. In the mean time, take a look at the archives and check in to the links on the blogroll.
Recall last month that the Bush Administration was rebuffing efforts by the District of Columbia to place restrictions on hazardous materials transportation. The D.C. Council this week approved a 90-day ban on shipments of hazardous materials through the nation's capital, becoming the first jurisdiction in the nation to restrict shipments in response to the threat of terrorism. Council members who approved the ban said reassurances from federal officials were not enough to safeguard residents.
The legislation enacting the temporary ban does not require congressional review, though the council is also considering a bill for a permanent ban on hazmat shipments. That permanent ban would be subject to review by Congress.
Rail giant CSX Corp., which owns and operates the major freight line that runs through the city, passing within four blocks of the U.S. Capitol, is bound to object. Federal officials opposed D.C.’s action, saying that they have pushed CSX to voluntarily reroute dangerous materials.
The legislation bans the most dangerous classes of hazmat, including certain explosives, flammable and toxic gases. It also requires rail and trucking firms carrying other hazardous materials to obtain permits from the city's Transportation Department. Ban advocates say they expect about 5 to 10 percent of rail shipments to fall under the prohibition. Approximately 8,500 hazmat rail cars go through D.C. each year. Only a fraction of those would fall under the ban.
The U.S. Department of Homeland Security and the U.S. Department of Transportation have both said that federal and industry officials have taken safety measures that go beyond the D.C. ban but declined to say what material is being rerouted. Of course, one of those proposed measures included removing hazardous material placards from commercial transportation carriers. This would ostensibly eliminate the potential for terrorists to identify hazardous materials shipments as potential weapons, as well as make it virtually impossible for first responders to protect the public in the event of a release, and increase health and safety risks to those same first responders. Great idea, no?
No. With thinking like that, it is no wonder that municipalities are considering banning hazmat shipments through their jurisdictions. Though D.C.’s law probably would not withstand federal court challenge, CSX is not considering a legal challenge right now. Right now, publicity would only feed a national debate about the rights of communities to restrict the flow of hazardous materials, in a political climate where Congress and the administration have had little incentive to regulate rail transport. Spread the word.
The EPA’s Office of Inspector General issued a report yesterday stating that the agency ignored scientific evidence and its own guidelines in order to develop mercury emission limits that would be consistent with the Bush administration's free-market approaches to controlling pollutants from power plants. Note that the press release was distributed on Friday – the traditional day for burying unpleasant news.
The key finding of the OIG’s report was, “[e]vidence indicates that EPA senior management instructed EPA staff to develop a Maximum Achievable Control Technology (MACT) standard for mercury that would result in national emissions of 34 tons annually, instead of basing the standard on an unbiased determination of what the top performing units were achieving in practice.”
The 34-tons-per-year target was based on the amount of mercury reductions expected to be achieved from implementation of nitrogen oxide (NOx) and sulfur dioxide (SO2 ) controls, rather than from implementation of control technologies specifically for mercury. According to EPA officials, 34 tons represents the most realistic and achievable standard for utilities.
However, MACT standards typically require all facilities to achieve emissions reductions achieved by the top performing 12 percent of facilities in the nation. The OIG stated that the 34 ton/year standard understated the average amount of mercury emissions reductions achieved by the top performing 12 percent of utilities – which is just about saying that the proposed standard doesn’t comply with the Clean Air Act.
The OIG also called into question the cost benefit of the desired cap-and-trade approach to emissions limitations compared with the MACT, and questioned the ability for the proposal to address mercury hot spots. In other words, a facility could achieve the standard by buying emissions credits, which would reduce overall mercury emissions and long-range transport, but still result in significant exposures to residents living near the facility. Finally, the OIG found that the rulemaking did not comply with certain Agency and Executive Order requirements, including not fully analyzing the cost-benefit of regulatory alternatives and not fully assessing the rule’s impact on children’s health.
The part of the story that was most interesting starts on page 13 of the report:
EPA documents and an analysis of the process used to compute the MACT floor support EPA staff’s statements that the MACT floor computations were developed to produce the desired national emissions of 34 tons per year. Documentation that we reviewed indicated that EPA conducted at least three Integrated Planning Model (IPM) runs in order to reach the pre-determined target for national mercury emissions of 34 tons. The initial IPM run to try to reach the 34-tons target yielded a national emission of 29 tons (i.e., the IPM model indicated that mercury could be reduced from 48 tons to 29 tons). After changing the proposed MACT emission limits, a second IPM model yielded a national emission of 27 tons. While we were provided summary information about these two IPM model runs, they were not included in the EPA rulemaking docket.
An Agency source indicated that these results were not acceptable to senior management because they were not close enough to the 34-tons target.
Shorter version: pick the target, then back the analysis into it.
Not taking enough consideration of the impact on children’s health is disturbing, because reducing mercury emissions is almost entirely about childrens’ health. Agency officials argued that reductions in emissions will reduce atmospheric mercury, would in turn result in less deposition, lower mercury levels in fish, and ultimately reductions in human exposure to mercury, though a detailed analysis of the risk reduction had not been done for the proposed rule. However, they hoped to have a more detailed assessment for the final rule. They further explained that the Notice of Data Availability issued in December 2004 proposed a process for quantifying the proposed rule’s impact on mercury deposition and the resulting bioaccumulation in the environment. So they proposed an emission limit without knowing if it would achieve any meaningful public health goals?
No topical blogging tonight because I got home from work too late and my brain hurts. In the meantime, please check in to some highlights from Blogtopia that I have encountered in my travels.
Pathogen Alert says “[w]e monitor 14,516 news sources worldwide, read 37 medical print publications and communicate with dozens of scientists so you get the whole truth.” True to the name, they publish short news items on microbiological hazards. This blog is supported by a internet publisher, Urgent eBooks (“publishers of eBooks that matter to your future”). They offer one book on the avian influenza H5N1 virus strain that could pose a pandemic risk, and are looking for topics for other books. I also encourage you to check in to Effect Measure, which monitors this issue regularly. Pathogen Alert appears to be a private-sector version of Environmental Health News.
W. David Stephenson’s blog on homeland security emphasizes “empowering the public, creative use of technology, win-win private/public collaborations yielding security and economic benefits and protecting civil liberties.” A tall order, but you can’t fault a writer who posts on the topic of teen sex and homeland security, as a way of introducing the concept of networking behavior and smart mobs. Scrolling down a little further, I found a post on “Company Commander”, a blog started up by junior officers in the army where they can swap advice and information about how to do their jobs – for circumstances where “the book” doesn’t provide adequate guidance, such as dealing with the day-to-day realities in Iraq. By the way, if you want to read a great blog on Iraq, I suggest “My War” by Colby Buzzell, an enlisted man with a Stryker brigade in Mosul. Anyway, Company Commander represents an approach to learning that is decentralized, collaborative, non-hierarchical and iterative, run by the people responsible for getting the job done. Stephenson feels the same approach is needed for homeland security. It could also benefit environmental health as well.
David Pollard also advocates the bottom-up, grass-roots approach to problem solving, for addressing the ecological/economic morass that threatens us with collapse. His “Values Statement” presents a values-based definition of well-being, a vision for community and a call to help develop a plan of action – which as yet is not formed, but left as encouragement for us to collaborate and add to it. Always a worthwhile read, if at times, intellectually overwhelming.
That will have to hold you for now. Regular posting should resume tomorrow.
Harvard Study on Personal Bankruptcy and Medical Expenses
Everyone and his brother have posted on this topic today, so I won’t add (too much) to the flood of words. However, as a service only to the readers of Impact Analysis, here is a link to the actual article online and in pdf.
Beyond the usual factoids that half of personal bankruptcies are related to medical expenses and that most of the bankrupt individuals were insured, you also find that a quarter of the bankruptcies involved cardiovascular diseases, percent; trauma/orthopedic/back problems by nearly one-third; and cancer, diabetes, pulmonary, or mental disorders and childbirth-related and congenital disorders by about 10 percent each.
Debtors’ out-of-pocket medical costs were often below levels that are commonly labeled catastrophic (so, these people were sucked dry by fairly ordinary medical conditions). Having private insurance sometimes made things worse, with debtors going deeper in the hole when their insurance was cancelled. The human face of medical bankruptcy, shown briefly in the paper, was heart-rending:
Debtors’ narratives painted a picture of families arriving at the bankruptcy courthouse emotionally and financially exhausted, hoping to stop the collection calls, save their homes, and stabilize their economic circumstances. Many of the debtors detailed ongoing problems with access to care. Some expressed fear that their medical care providers would refuse to continue their care, and a few recounted actual experiences of this kind. Several had used credit cards to charge medical bills they had no hope of paying.
The co-occurrence of medical and job problems was a common theme. For instance, one debtor underwent lung surgery and suffered a heart attack. Both hospitalizations were covered by his employer-based insurance, but he was unable to return to his physically demanding job. He found new employment but was denied coverage because of his preexisting conditions, which required costly ongoing care. Similarly, a teacher who suffered a heart attack was unable to return to work for many months, and hence her coverage lapsed. A hospital wrote off her $20,000 debt, but she was nonetheless bankrupted by doctors’ bills and the cost of medications.
A second common theme was sounded by parents of premature infants or chronically ill children; many took time off from work or incurred large bills for home care while they were at their jobs.
Finally, many of the insured debtors blamed high copayments and deductibles for their financial ruin. For example, a man insured through his employer (a large national firm) suffered a broken leg and torn knee ligaments. He incurred $13,000 in out-of-pocket costs for copayments, deductibles, and uncovered services—much of it for physical therapy.
Heart disease, cancer, stroke, lower respiratory tract disease, and diabetes accounted for more than two-thirds of the deaths in the U.S. in 2001 (the last year with statistics readily available), according to the CDC. Other stricken with these conditions live on to see their financial resources drained away to cover medical expenses. Not all of these conditions are preventable, but many are. For those readers who are smokers, drinkers to excess, who don’t eat properly or exercise, if the risk of death or disability isn’t threatening, maybe the risk of bankruptcy is.
From Prometheus, we hear about an interesting development: many of the neocons in Washington who promoted war with Iraq are now going green. An article in Slate says that, “James Woolsey, the former director of the Central Intelligence Agency and staunch backer of the Iraq war, now drives a 58-miles-per-gallon Toyota Prius and has two more hybrid vehicles on order. Frank Gaffney, the president of the Center for Security Policy and another neocon who championed the war, has been speaking regularly in Washington about fuel efficiency and plant-based bio-fuels.”
Woolsey and Gaffney, both members of the hawkish Project for a New American Century, look at going green from a geopolitical perspective. They have begun to see that the flow of oil dollars to countries potentially hostile to us as a threat to our national interests. They view reducing oil imports as a “national security imperative”.
Many will view this with mixed emotions. It is promising that those who speak to decision-makers are starting to come around. But was it necessary to go through the tragedy of war in Iraq for their epiphanies? It seems that anyone with half a brain could have seen that war isn’t the way to provide energy security. Some of the threats to our energy supply will be tougher to take on than Iraq.
Maybe we can start the debate again about fuel efficiency standards for SUVs. Perhaps next we can even get the neocons concerned about the threats to human capital and intellectual resources from exposures to environmentaltoxicants.
The American Public Health Association (APHA) in 2004 issued a policy statement calling for action to be taken to prevent human exposure to polybrominated diphenyl ethers (PBDEs) used as flame retardants. In urging proactive steps to reduce exposure, the APHA states that PBDE compounds are widely used, chemically similar to PCBs, environmentally persistent, rapidly bioaccumulating in human tissue including breast milk, and function as developmental neurotoxicants in studies with laboratory animals.
It notes that the European Union and several states in the U.S. are instituting phase-outs of PBDE use, and that alternatives to PBDEs for fire safety include product redesign to eliminate the need for added chemicals; use of naturally flame retardant materials like wool and leather or plastics containing sulfur; and use of alternatives such as red phosphorus, ammonium polyphosphate and aluminum trihydroxide.
The APHA resolution calls for fixing a date for phasing out use of PBDEs; federal and state action to alleviate the short-term economic impacts from the phase-out and to sponsor research in alternatives to PBDEs; labeling for products that contain PBDEs; regulating disposal of PBDEs or discharges to surface water; and increasing environmental monitoring for PBDEs, including biomonitoring of body burden.
All of the APHA policy statements for 2004 can be found here.
From my Greenclips mailing list, I found out that the U.S. Green Building Council’s Technical and Scientific Advisory Committee (TSAC) has released for public comment a draft of its long-awaited report on polyvinyl chloride (PVC). A more detailed summary of this report can be found here. The TSAC’s PVC web site is here. The report was commissioned to determine “the availability and quality of the evidence as a basis for a reasoned decision about the inclusion of a PVC-related credit in the LEED Rating System”. The report’s central finding is that “the available evidence does not support a conclusion that PVC is consistently worse than alternative materials on a life-cycle environmental and health basis.” The report also discusses data gaps and subject areas which, “if information became available, could alter the results of the analysis.” The “PVC-related credit” would provide a credit towards LEED certification of a building that does not use PVC materials.
LEED (Leadership in Energy and Environmental Design) certification identifies building projects that demonstrate a commitment to sustainability by meeting specified performance standards. LEED certification establishes recognition in the green building sector, contributes to a growing green building knowledge base, and qualifies projects for a growing array of state and local government incentives.
PVC and comparable building materials were analyzed using lifecycle analysis (LCA) coupled with health risk assessment. The Task Group also created a database of nearly 2,500 relevant reports, papers, and other source materials, many submitted by various stakeholders, to assess the “availability and quality of the evidence”. In addition to the conclusion that a PVC-related credit was not appropriate in LEED rating, the report also stated that credits should be based on life-cycle impact categories rather than specific material types (a weakness of LEED certification that I have heard about elsewhere).
Some might view the USGBC report as a clean bill of health for PVC (I can see the wingnuttery now, if they bothered to pay attention to such things). While they clearly came to a different conclusion than CHEJ regarding PVC, the USGBC report says only that PVC was not a worse performer environmentally compared with other building materials. CHEJ looked at a wider range of uses for PVC, such as packaging, which has a different product lifecycle. USGBC’s methodology clearly was more robust, though. It would be interesting to see how PVC would fare when all of its uses were analyzed using LCA/risk assessment. It should be noted that the report states, “occupational cancer risks are far from negligible in relation to health risks to the general population, and should be considered more widely as part of comprehensive life-cycle methodologies”. It is the mark of a good risk assessment to note this finding, because it identifies the concern that the risks associated with PVC (and other building materials for that matter) are borne disproportionately by workers. As CHEJ also notes, poor communities also pay the risk price for our consumer choices. Whether we’re buying PVC siding or head lettuce, it’s something we pay scant attention to.
