I haven’t been able to give the blog much attention recently, which is a shame because a lot is going on that’s worth writing about. For now, you’ll have to make do with the blogroll, but in the meantime, check out this article by Chris Mooney. Remember how Sen. Inhofe’s committee was probably getting its mercury talking points from a think tank funded by Exxon-Mobil? Here’s more of that story.
Kevin Drum makes all of the properly progressive noises about this story in Pacific Views:
Remember yesterday I posted about potential conflicts of interest when pharmaceutical studies in medical journals are sponsored by pharmaceutical companies? You will be unsurprised to know that the same thing is true of chemical studies sponsored by chemical companies.
But, at least for this magpie, the crux of the story is in these paragraphs:
In an interview yesterday, [study co-author Frederick] vom Saal, a reproductive biologist at University of Missouri, Columbia, said there is now an "overwhelming weight of evidence" that the plastics compound is harmful.
"This is a snowball running down a hill, where the evidence is accumulating at a faster and faster rate," vom Saal said. "You can't open a scientific journal related to sex hormones and not read an article that would just floor you about this chemical. ... The chemical industry's position that this is a weak chemical has been proven totally false. This is a phenomenally potent chemical as a sex hormone."
In their study, vom Saal and Hughes suggest an explanation for conflicting results of studies: 100 percent of the 11 funded by chemical companies found no risk, while 90 percent of the 104 government-funded, nonindustry studies reported harmful effects. [emphasis added in original]
What a coincidence, huh?
Of course, the industry mouthpieces have the usual answer:
Steven Hentges, executive director of the polycarbonate business unit of the American Plastics Council, said yesterday that the new report lists numbers of studies and pieces of data without analyzing them to determine their strengths or weaknesses and relevance to human beings.
"The sum of weak evidence does not make strong evidence," Hentges said. "If you look at all the evidence together, it supports our conclusion that BPA is not a risk to human health at the very low levels people are exposed to. This paper does not change that conclusion. It has an opinion, not a scientific conclusion."
Just like all those papers saying that global warming exists are just expressing an opinion, we imagine.
So what we have here is another scientific 'controversy' that isn't. The reason that the plastics manufacturers can assert that there's a doubt about the dangers of BPA is that they've funded scientific studies to 'prove' the conclusion they want: that BPA is not dangerous. The fact that almost all of the non-corporate studies found just the opposite speaks very loudly, we think.
The origin of this story is a paper to be published in Environmental Health Perspectives. The main points by the authors were: 1) the risk assessment for bisphenol A is well overdue for updating to incorporate the large number of studies completed in the past couple of years; 2) human exposure is widespread; 3) evidence is accumulating that bisphenol A modulates hormonal responses (i.e. is an “endocrine disruptor”); hormonally active chemicals are a concern because they might increase the risk of adverse developmental and neurobehavioral health effects; 4) there are differing interpretations of the weight of evidence for identifying the potential health hazards from bisphenol A (which is only one of the steps in assessing human health risks) and the summation developed from an industry-funded effort is lacking in transparency and inclusiveness.
vom Saal and Hughes appear to make a persuasive case that the study conducted by the Harvard Center for Risk Analysis (HCRA) and funded by the American Plastics Council (APC), which concluded that evidence for low-dose effects of bisphenol A is weak, had a fairly narrow charge and didn’t examine the full weight of evidence, particularly more recent studies. However, to give the devil (or his representative, the APC) his due, counting up the numbers of studies that reported biologically significant effects does not equate to an assessment of human health risks. This is a fallacy along the lines of the “P-value fallacy” articulated by Dr. Steven Goodman, which discusses the importance of statistical significance in laboratory studies. Dr. Goodman makes the point that the term “statistically significant” means that enough data have been collected to establish that a difference is likely to exist, but it does not mean that the difference is necessarily important within the context of human health. That determination requires the application of risk assessment.
Sadly, this is another one of these “industry bad/environmentalist good” oppressive dichotomies that is a distraction and a hindrance to clear thinking. It makes for good narrative and good drama, but ultimately is an impediment to progress in addressing human exposures to toxic chemicals. And it’s what passes so often these days for discourse about environmental health in the mainstream media. Years ago, we tried to do better. “Understanding Risk: Informing Decisions in a Democratic Society” published in 1996 by the National Academy of Sciences (NAS) tried to establish a non-adversarial process for sharing health risk information and opinion that addressed the normative needs of democracy. It encouraged the inclusion of the perspectives from a variety of stakeholders, resulting in learning by all participants. The goal of this process was to produce more rational and legitimate public health outcomes.
Initiatives such as “Understanding Risk” and The Presidential and Congressional Commission on Risk Assessment and Risk Management (1996-1997) strived to make risk assessment a more democratic process. However, as events have shown, they represent lost opportunities for involving all of us in risk and public health decisions that affect all of us. We’re back to just carping and complaining about chemical exposures with little effect.
There’s a lot of outrage over this, as written here (and other sources). But in reading the actual documents, this is an attempt to measure effects of pesticide use on children in normal households. The government isn’t spraying pesticides in homes. They’re merely monitoring families with young children who routinely use pesticides. I see fellow online left-leaners carelessly throwing about the descriptor “Mengele” without reading the actual study information.
EPA didn’t do a good job of engaging stakeholders (clearly so – a U.S. Senator threatened to hold up confirmation of the administrator-nominee if he didn’t cancel the study). And, EPA was internally conflicted about the wisdom and ethics of the situation. But I think Dangerousmeta is correct. I wonder how many of those objecting to the study actually read the protocol?
The TCE Blog kindly linked to yesterday’s post, and as you can see for yourself in the comments, quite rightly challenged me to clarify what I meant when I said we all have to do the heavy lifting with regard to controlling TCE exposures.
Environmental management has been a drama with the players being government and regulated entities (industries and federal agencies such as the DOD) and workers and communities serving as the audience. Go over to Confined Space, and you will find examples of how workers do not compete on a level playing field with employers when it comes to health and safety, while government agencies are less and less serving their role of equalizer. The process for investigating and cleanup of a groundwater contaminant plume under a community is sufficiently complex that it’s difficult for communities to contribute to the problem-solving. Most people just don’t have the time (or make the time – see below) and the resources to engage and become part of the decision-making.
At the same time, leaving the management of these issues to government officials and industry representatives could lead to you being disappointed in the outcome (say, if you’re the one with TCE vapor in your basement). For example, EPA withdrew in 1989 the toxicology information for TCE used in risk assessments and risk-based decision making. The agency jump-started the process for reassessing TCE risks in 2000. We may see some resolution of that reassessment within the next two years, but more time will be needed before those results are translated into regulatory policy. Faster action is happening in some places, but it is very much on a site-by-site basis, dependent on the initiative of individuals – members of the affected communities who are motivated to engage, and governmental officials and industry representatives who are willing to be proactive.
That last point seems to be the key. Jared Diamond says, "[i]t is easy and cheap for the rest of us to blame a business for helping itself by hurting other people.” However, he also says that we, the public, have the responsibility and power to compel industries to achieve higher environmental, health and safety standards, either directly or through our politicians.
In the recent past, I’ve been less than optimistic about the willingness of our politicians to step up and address environmental issues. However, this might be something to consider: there are possibly 400,000 workers who might be exposed to TCE. This is based on a 20 year old survey, and current statistics aren’t known, but may be similar. Hundreds and perhaps thousands of communities may be affected by TCE contamination in soil and groundwater. How many voters and consumers are represented by these communities and workplaces? Many of these people are members of unions, churches or other organizations. They have friends and relatives. Altogether, are these individuals enough to form a viable political and economic bloc, based on the common thread of above-ambient TCE exposure?
For instance, after the public became concerned about the spread of mad cow disease, and after the U.S. government’s Food and Drug Administration introduced rules demanding that the meat industry abandon practices associated with the risk of spread, meat packers resisted for five years, claiming that the rules would be too expensive to obey. But when McDonald’s Corporation then made the same demands after customer purchases of its hamburgers plummeted, the meat industry complied within weeks. . . . The public’s task is to identify which links in the supply chain are sensitive to public pressure: for example, McDonald’s, Home Depot and Tiffany’s, but not meat packers, loggers, or gold miners.
The trick now is to find the parallels within the supply chain for TCE. Some more work needs to be done to create this political and economic critical mass, though. James Howard Kunstler, speaking in regard to peak oil, observes:
It has been very hard for Americans - lost in dark raptures of nonstop infotainment, recreational shopping and compulsive motoring - to make sense of the gathering forces that will fundamentally alter the terms of everyday life in our technological society.
This state of affairs applies just as well to environmental health problems as resource issues. Perhaps the TCE Blog could serve as a focal point, or rallying point, for linking together the diverse elements of public society, who have above-ambient TCE exposure in common, into a special interest group with real influence.
For some weeks, I’ve been struggling with a post on TCE, trying to answer to my satisfaction several questions. These included: whether or not we’re spending too much time trying to understand a very small risk, or spending too much time arguing over something that’s a clear environmental health problem; how significant of a cancer risk are we facing with a substance that shows relative risks less than two in epidemiological studies:
Analytical studies of individual risk factors today often show relative risks of only 1.5 to 2, and these are difficult to translate into preventive recommendations.
Although epidemiologists have become more introspective with questions on the utility of epidemiologic studies for providing insight on associations of relative risks of 2.0 or lower (Taubes, 1995, Monson, 1980), epidemiologic evidence continues to inform the hazard step in risk assessment and is increasingly examined for dose-response inferences.
and, how did we end up with an 17 nanograms per cubic meter (ng/m3) of TCE in air (a tiny, tiny amount), corresponding to a 1 in 1,000,000 excess lifetime cancer risk, as a regulatory guidance level? For that matter, how did we end up with 1 in 1,000,000 as a target level for evaluating cancer risks to the public? Here’s one perspective – you might not agree with it, but it’s thought-provoking.
These questions have proven to be difficult and time-consuming to answer for TCE. However, the stakes are large – more and more, TCE is showing up in air samples in peoples’ basements, and the costs for remediation of TCE-contaminated soil and groundwater potentially run to several billions of dollars. A substantial portion of those costs are borne directly by us taxpayers, for contamination at Superfund sites with no responsible parties (i.e. sites where the individuals who contaminated the environment can’t possibly pay for the cleanup) and contamination at Federal facilities.
Some would argue that TCE is a classic case that argues for imposition of the precautionary principle:
When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.
“What should we do when the safe and the dangerous are inextricably intertwined?” It is foolish to seek maximum benefit without considering the risks involved, but it is just as foolish to pursue minimum risk without regards for the cost. It is madness to ask for zero risk. Risk management is a balancing act.
This issue has been thrown in to the lap of the National Academy of Sciences. Some will hope, for the sake of decision makers, homeowners with TCE in their basements, and workers exposed to TCE everywhere, that the NAS will pass some kind of miracle and show us the path between neglecting a potentially significant threat to human health and alarming people with possibly needless precaution. I’m not that optimistic. A successful resolution to the TCE problem requires all of us to do some of the heavy lifting. This wasn’t the TCE post I’ve been trying to write, but then again, cancer epidemiology and pharmacokinetic modeling aren’t terribly relevant without this kind of framework.
In a paper to be published in Environmental Health Perspectives, studies are presented indicating that initiating precautionary measures for EMF exposures may trigger concerns, amplify perceptions of risks and reduce trust in public health protection.
Thankfully, I don’t appear to have much of a wingnut audience, so that the risk is small that someone will turn this into an endorsement of sound science. The authors make the point that the precautionary principle needs to be applied with some discretion, a view apparently shared by the World Health Organization.
I suspect that one of the causes for these findings is the enormous gulf between the scientists doing the risk assessments and the decision makers responsible for the risk management. Risk assessment and risk management are supposed to be distinct processes. However, risk assessors appear to have a problem in characterizing and synthesizing their findings in a manner that is usable to risk managers. Risk managers understanding of the issues of scientific uncertainty, cumulative risks, risk prioritization, etc. is often too limited to make the best use of risk information. Risk assessors who streamline and simplify their findings so much for the benefit of risk managers essentially are making policy choices about what information is used in decision making – becoming the risk managers themselves, a role they are not particularly suited to serve.
Back in the dimly-remember mid-1990s, several documents were published that discussed how the assessment of environmental health risks could be improved. One of these, “Understanding Risk: Informing Decisions in a Democratic Society” published in 1996 by the National Academy of Sciences (NAS), addresses the topic of using risk assessment to make better informed and more trustworthy decisions about human and environmental health risks. While the book focuses on the limitations of risk assessment that cause it to fall short of these expectations, it makes a key point that “[a]cceptance of risk decisions by a broad spectrum of the interested and affected parties is usually critical to their implementation”.
The lessons don’t seem to have taken. And I guess ignorance is bliss.
Posting remains light in deference to the current needs of the day job, but there were a few things that I wanted to share before I forgot about them.
Bob Whitson is showcasing James Howard Kunstler’ new book, The Long Emergency, a wakeup call for modern society about the hazards awaiting it from peaking oil production. Kunstler recently published an essay in Rolling Stone (reprinted elsewhere if the link goes down) that summarizes the book. He’s not very kind to us, but as the people who have let the Bush Administration design our energy policy, we deserve it:
It has been very hard for Americans - lost in dark raptures of nonstop infotainment, recreational shopping and compulsive motoring - to make sense of the gathering forces that will fundamentally alter the terms of everyday life in our technological society. Even after the terrorist attacks of 9/11, America is still sleepwalking into the future. I call this coming time the Long Emergency.
Most immediately we face the end of the cheap-fossil-fuel era. It is no exaggeration to state that reliable supplies of cheap oil and natural gas underlie everything we identify as the necessities of modern life - not to mention all of its comforts and luxuries: central heating, air conditioning, cars, airplanes, electric lights, inexpensive clothing, recorded music, movies, hip-replacement surgery, national defense - you name it.
The ever-reliable Environmental Health News provides a couple of interesting items. First, this review paper published in the open-source Public Library of Medicine discussing cumulative exposures particularly with regard to developmental neurotoxicity risks to children. Next, a commentary by the National Resources Defense Council and other, to be published in Environmental Health Perspectives, alleging that the EPA gave industry a disproportionate voice in developing quantitative toxicity values for vinyl chloride. The resulting values, which are used in risk assessments, are considered by NRDC to not address the range of adverse effects associated with vinyl chloride exposure. I don’t have an opinion on it yet, prior to doing my own reading on the topic.
I unfortunately will not be able to attend the conference, “Defining the Future of Public Health”, being held at Boston University this weekend, but if you’re within striking distance on the east coast, you should try to get there. I’d be interested in hearing about it if someone is interested in sponsoring something similar in the Midwest. *With a nod to Mystery Science Theater 3000
Is the concept of peak oil just in the news cycle right now, or is it really a tipping point? Does making it onto the front page of USA Today make it a real issue? In case you want to chalk this up to environmentalist alarmism, it might be useful to note this story in the Financial Times.
According to the FT, oil importing countries will be encouraged to implement emergency oil-saving measures, if supplies dip by one to two millions barrels per day (characterized as a moderate supply disruption). This news comes from the International Energy Agency, who has published a review draft of a book titled: Saving Oil in a Hurry: Measures for Rapid Demand Restraint in Transport:
A core mission of the International Energy Agency (IEA) is energy supply security. Indeed, the Agreement on an International Energy Program (I.E.P.), the treaty signed by all IEA member countries, obliges IEA member countries to not only to maintain emergency oil reserves, but also to apply voluntary and mandatory measures for reducing oil consumption on very short notice during an oil supply disruption. As the transport sector in most OECD countries is the prime consumer of oil, this sector should be a central focus of IEA member countries’ emergency oil demand restraint programmes.
This book provides a new, quantitative assessment of the potential impacts and costs of oil demand restraint measures in transport, under the conditions of a supply disruption or other oil-related emergency. In short, there appear to be opportunities to achieve substantial reductions in transportation oil demand quickly and cheaply – if countries are prepared.
If countries are prepared is the operative phrase. Of course, with the Cato Institute telling us to stop whining because gas is cheaper now than in 1973, when adjusted for inflation, and Vice-President Cheney admonishing us that "[c]onservation may be a sign of personal virtue but it is not a sufficient basis for a sound, comprehensive energy policy," getting some people motivated to prepare for oil shocks may pose a bit of a problem. Despite the VP’s admonition, it may be worthwhile to pay attention to the advice from the IEA. After all, establishment of the IEA was prompted by 1973 oil embargo that followed the fourth Arab-Israeli war.
Keep in mind, what the IEA proposes are short-term measures to smooth out disruptions in supply. However, these could very well become ways of life for us because, before too long, $50 per barrel oil will be a thing of the past.
At least the air quality will start getting better, if we drive our cars less often.
