Saturday, September 10, 2005

Accountability (3)

Any sufficiently advanced incompetence is indistinguishable from malice.

Remember when I said that we needed to have an unvarnished accounting of the disaster response for Hurricane Katrina, in order to be better prepared in the future? It’s looking like the chances of that happening are getting fainter and fainter. Beyond political maneuvering, there no value in the blame game, but an honest lessons-learned discussion would be nice.

A thought-provoking analysis, which should be read by anyone interested in being prepared for the next large disaster, was written last week by Laurie Garrett, at the height of the crisis at the Superdome and Convention Center. Some of the key points were: people who feel they have no reason to trust the government are unlikely to correctly respond to governmental instructions during a crisis; the ability of leadership to communicate with the public is critical to being able to respond appropriately; a sense of civilian leadership returning to the area needs to happen real soon, otherwise the refugees (I mean, displaced persons) will start to see themselves as under occupation; “[g]iven the overtones of racism, this could be explosive”.

Other good points she’s brought up were that the Mississippi Delta was America’s version of the tropics, from an ecological perspective. The flooding aftermath has left large pools of standing water that created extensive habitat for mosquitoes, at a time when America’s commitment to mosquito control has waned. Also, the experience in clearing mosquitoes from large, water-covered areas is in third-world countries, another reason why we should be reaching out to help from around the world (yes, I can hear ACSH and the Cato Institute from here shouting “bring back DDT!”). CDC’s perspective is:

Although infectious diseases are a frightening prospect, widespread outbreaks of infectious disease after hurricanes are not common in the United States. Rare and deadly exotic diseases, such as cholera or typhoid, do not suddenly break out after hurricanes and floods in areas where such diseases do not naturally occur. Communicable disease outbreaks of diarrhea and respiratory illness can occur when water and sewage systems are not working and personal hygiene is hard to maintain as a result of a disaster.

Another useful and brief resource on microbiological hazards that I’ve encountered is here on Medpage Today. CDC’s Katrina news and resources page also looks to be very useful.

Another thing to give one pause is the immense amount of debris and waste (including hazardous waste) that will be generated during the recovery. Hopefully, Ms. Garrett says, someone is giving thought to trying to recycle or reclaim some of this material for future levee construction or other construction purposes. The hundreds of thousands of now unemployed in the region could be put to work in green deconstruction, which would maximize the quantities of usable materials, as well as benefit the people. Another issue that will need to be addressed is indoor air quality, particularly molds and asbestos, in buildings that are water-damaged but not ready for demolition. As Ms. Garrett says, it would be a shame if all of it ended up in landfills. . .

. . . or worse; according to this account, reportedly from someone on the scene, the rumor is that debris removal in New Orleans will involve demolishing the structures and incinerating the waste. It’s hard to choose which is more exasperating – the potential air quality impacts; residuals disposal problem (burning all of that debris will leave behind a lot of ash that will have to be disposed of) or the waste of resources. Hopefully, this truly is just a rumor and not a sign that someone in a leadership position has their head firmly tucked up their ass.

The real test of “compassionate conservatism” will be how the mental health problems are addressed for hundreds of thousands of refugees. Displaced, broke, jobless, uprooted and disconnected from family and loved ones, one of the things they will need in the coming months is frequent and accurate information – about how things are going back home, the fate and location of family members, and as clear a message as possible of what’s going to happen next and when will they stop being displaced persons and start being citizens again; “[i]f government cannot inform, there is no government”. Of course this presumes there is a plan. . .

. . . such as the planning done when FEMA supposedly drilled for this contingency. FEMA and local authorities participated in the simulated disaster response to “Hurricane Pam” in 2004. Hurricane Pam, based on historical weather and damage data, brought sustained winds of 120 mph, up to 20 inches of rain in parts of southeast Louisiana and storm surge that topped levees in the New Orleans area. More than 60,000 fatalities occurred, one million residents were evacuated and 500,000-600,000 buildings destroyed in this scenario. According to FEMA’s press release, “[d]isaster response teams developed action plans in critical areas such as search and rescue, medical care, sheltering, temporary housing, school restoration and debris management. These plans are essential for quick response to a hurricane but will also help in other emergencies." FEMA seems to have been aware of the consequences from a Katrina-sized storm (notes to the inquisitive: read the statement of work for the “Southeast Louisiana Catastrophic Hurricane Plan from Talking Points Memo, then the post from Lenin’s Tomb on the plan that Integrated Emergency Management of Baton Rouge was supposed to have written for FEMA; I wonder if these are these the same critters). So what happened to make the plan fail so catastrophically?

Neo-conservatives wanted to reduce government “to the size where I can drag it into the bathroom and drown it in the bathtub", in the words of Grover Norquist. While that hasn’t happened (just the opposite, in fact), they’ve managed to hamstring government to the point that it apparently can’t perform even the most basic functions, such as safeguarding American from natural disasters. This is a significant problem. There is a lot that we individually and collectively can do to prepare and respond to disasters in our communities (this diary over at Daily Kos represents one such attempt). However, in the end, disaster response is not something that can be fully addressed by non-profits, faith-based organizations or privatization. It needs the involvement of government.


Postscript, September 11

The lessons-learned seems to be occurring. The catastrophic plan appears to have been incomplete, roles and responsibilities between federal and state/local officials were not clear, state and local officials were overwhelmed, and federal officials at the top were unresponsive at critical times in the crisis. Some people keep saying that “September 11th changed everything”, but from the looks of this, it seems that the changes were for the worse.

Lost in all of the noise is the ecological impact – oil spills, sedimentation, loss of the Gulf Coast fisheries, etc. The short attention spans of U.S. media being true to form, I had to read about it in a UK news outlet.

Important Events in Slow-Motion

While we obsess over the “blame game” with the disastrous disaster response to Hurricane Katrina, the fate of our species hangs in the balance. Got your attention? Good. Ok, so maybe it doesn’t really hang on this, but perhaps we could find the energy to multi-task and start having some national discussion about long-term reproductive health hazards. Over the past several years, members of the Aamjiwnaang First Nation community in Sarnia, Ontario have reported fewer births of male children. This community is in proximity to a heavily industrialized area, including several large petrochemical, polymer, and chemical industrial plants. Investigators have confirmed these observations of declining sex ratios (ratio of male to female births), and have recommended that potential exposures to endocrine-disrupting chemicals be investigated further.

Our narrative-driven, 24/7 news cycle simply doesn’t address slow-motion, and in this case, intergenerational issues. Along with the exposure assessments, epidemiology and risk assessment of the potential chemical exposures, we should be initiating research and public dialog on the issues of long-term effects from declining sex ratios. Maybe this isn’t a real problem, with regard to fertility or genetic variability (genetic variability being something very useful for a species to respond to environmental changes; something we will understand less about over time as education in evolutionary biology is suppressed in this country); or maybe it’s a critical problem that should be addressed with the environmental health equivalent of the Manhattan Project. Also, what kinds of explorations should be made into the long-term societal changes resulting from declining sex ratios; is the experience with the Chinese (population control laws limiting couples to one child combined with a preference for male offspring have distorted the sex ratio) useful in this regard? What about the experiences of countries that lost millions of males in wars (for example, European countries and Russia in World Wars I and II)?

Tuesday, September 06, 2005

On to Other Things for a Moment – Another Perspective on the Petition from Hell

This doesn’t have the urgency of creating an effective disaster response mechanism on the heels of the Hurricane Katrina debacle, but I didn’t want this news to grow too cold. From Effect Measure, I heard about the American Council for Science and Health’s (ACSH) initiative to kneecap some of EPA’s regulatory efforts, by challenging the agency’s carcinogen assessment guidelines through its Quality procedures. The ACSH’s intellectual basis for their efforts is published in their book, America's War on "Carcinogens": Reassessing The Use of Animal Tests to Predict Human Cancer Risk. I haven’t purchased a copy yet (I will be reviewing it in a future post), and their petition for a Request for Correction wasn’t up on EPA’s web site when I checked last weekend, so I don’t know the specifics about their complaint. But those wouldn’t be hard to figure out (a summary can be found here). Other things that ACSH says on their web site about America’s War on “Carcinogens” is:

American consumers should not be subject any longer to the “carcinogen du jour” scares that have dominated the headlines for the past five decades. Corporations should not be forced to withdraw perfectly useful and safe products from the market (or take unnecessary efforts to purge chemicals from the environment) just because a substance is labeled an animal carcinogen. In our pursuit of methods to reduce the risk of cancer in America, science and common sense, not rhetoric, scare tactics, and hyperbole, should prevail.

In this book, scientists associated with the American Council on Science and Health call upon Congress, the National Cancer Institute, the National Toxicology Program, our nation’s regulators, scientists from many disciplines, as well as members of the media to step back from the familiar but scientifically baseless mantra that “if it causes cancer in animals, it must be assumed to be a human cancer risk.” Such a simplistic, unscientific, inconsistent approach to ferreting out risks for human cancer is a losing strategy in the war on cancer.

Unless there’s a lot more to ACSH’s book, this is a cartoon depiction of carcinogen policy that scarcely resembles the actual agency approach (recently updated as of March 2005, months after publication of America’s War on “Carcinogens”). A summary of that approach, presented here, emphasizes full characterization of all of the information used to identify substances as carcinogens and characterize their dose-response (not just the animal bioassay data), and an expanded role for mode-of-action data (which responds in part to the ongoing concern that tumors observed in high-dose animal studies cannot be appropriately extrapolated to low-dose human exposure). A range of approaches for extrapolation from high-to-low dose settings are provided, not just the linear non-threshold model first published in the 1986 version of the carcinogen guidelines, and a favored whipping boy for the anti-carcinogenic regulatory crowd. In short, it is possible that ACSH is complaining about a carcinogen risk assessment policy that has been superseded for many years?

Some of the talking points from the book are in a Western Legal Foundation backgrounder produced by ACSH. It strays off topic at times (see for yourself), and today’s post isn’t the place to deconstruct the environmentalist blame-fest for all of humankind’s woes that are in it. Presented below are some of the talking points regarding carcinogen assessment from ACSH’s legal backgrounder; in some cases I’ve provided corresponding statements from EPA’s guidelines for carcinogen risk assessment; in others, some follow up commentary:

ACSH: The regulatory science practiced at the EPA/NTP is deficient and based on closely-held beliefs about high-dose animal testing, rather than upon relevant scientific or epidemiological data, and should be reevaluated and modified to conform to generally accepted scientific principles of risk assessment.

EPA: . . . [E]pidemiologic studies typically evaluate agents under more relevant conditions. When human data of high quality and adequate statistical power are available, they are generally preferable over animal data and should be given greater weight in hazard characterization and dose-response assessment, although both can be used (page 2-3).

ACSH: Rather than relying on a few high-dose rodent tests to label a substance “carcinogenic” (or a “likely carcinogen”), the totality of the data should be considered, including evidence from multiple species and human epidemiology when available.

EPA: Evidence considered includes tumor findings, or lack thereof, in humans and laboratory animals; an agent’s chemical and physical properties; its structure-activity relationships (SARs) as compared with other carcinogenic agents; and studies addressing potential carcinogenic processes and mode(s) of action, either in vivo or in vitro. Data from epidemiologic studies are generally preferred for characterizing human cancer hazard and risk. However, all of the information discussed above could provide valuable insights into the possible mode(s) of action and likelihood of human cancer hazard and risk. The cancer guidelines recognize the growing sophistication of research methods, particularly in their ability to reveal the modes of action of carcinogenic agents at cellular and subcellular levels as well as toxicokinetic processes.

Weighing of the evidence includes addressing not only the likelihood of human carcinogenic effects of the agent but also the conditions under which such effects may be expressed, to the extent that these are revealed in the toxicological and other biologically important features of the agent (page 1-12).


ACSH: This sort of approach is actually what FDA used for substances “grandfathered” at the time of the Delaney Clause, e.g., aflatoxin, a well studied and potent human carcinogen, is allowed to be present in foods at minute levels known to be without risk at those levels.

I guess the point being made here is that FDA has a distinctly different and superior approach to carcinogen risk assessment from EPA. I’m having to dredge up the history of aflatoxin regulation to understand this one better, but I have found a statement by Joseph Roderick from a 2001 conference, reminiscing about his time at FDA when aflatoxins were being addressed, and stating that “EPA has been quite good about guidelines, FDA has not done that, but their assessments are very much like EPA's.” That doesn’t sound so different to me.

ACSH: This same approach should be applied—based on sound science in risk analysis—to all suspected carcinogens, whether synthetic or natural.

EPA: The cancer guidelines cover the assessment of available data. They do not imply that one kind of data or another is prerequisite for regulatory action concerning any agent. It is important that, when evaluating and considering the use of any data, EPA analysts incorporate the basic standards of quality, as defined by the EPA Information Quality Guidelines (U.S. EPA, 2002a see Appendix B) and other Agency guidance on data quality such as the EPA Quality Manual for Environmental Programs (U.S. EPA, 2000e), as well as OMB Guidelines for Ensuring and Maximizing the Quality, Utility, and Integrity of Information Disseminated by Federal Agencies (OMB, 2002). It is very important that all analyses consider the basic standards of quality, including objectivity, utility, and integrity. A summary of the factors and considerations generally used by the Agency when evaluating and considering the use of scientific and technical information is contained in EPA's A Summary of General Assessment Factors for Evaluating the Quality of Scientific and Technical Information (U.S. EPA, 2003) (page 1-5).

It is difficult to imagine that guidelines highly unfavorable to industry could emerge from a regulatory agency under the thumb of the Office of Management and Budget (OMB) in the Bush Administration. There is a lot more to say about this topic (more on it later – this post was already a couple of days in the making), but for now it’s sufficient to say that there’s a distinctly different story to tell about how carcinogens are studied and regulated than the one coming from ACSH.

Friday, September 02, 2005

Accountability (2)

Revere over at Effect Measure has made point in the past that the relentless focus on homeland security, where homeland security is narrowly defined as threats by foreign terrorists, has put basic public health in the shadow. No disagreement here.

But when it comes to disaster preparation and response, you would think that it would be the pretty much the same whether we were talking about a hurricane, flooding, earthquake, “chemical terrorism” (for example, sabotage of the chlorine tanks at the local wastewater plant) or detonation of a radiation dispersal device (technical term for a "dirty bomb"). You obtain similar results with each of these hazards; a considerably-sized area is rendered uninhabitable, there are hundreds or thousands of casualties and tens or hundreds of thousands of people are displaced. The way you handle them should be fairly similar - mitigation, preparedness, response, recovery.

However, If this component of "homeland security" is so broken, what can the Bush Administration possibly do that would help us believe the rest of it works any better, and that homeland security in general wasn’t just money down the rathole?

Thursday, September 01, 2005

Accountability

One of the drawbacks of using the machines for cardio at my gym is that they are set up in front of TVs that are tuned to Fox, MSNBC, ESPN or something similar. Watching network or cable news just makes my teeth ache, but I was giving my knees and hips the week off from jogging, so around 5:30 Eastern today I got to watch on MSNBC FEMA director’s Michael Brown giving a press conference about the disaster response in New Orleans, while I was slaving away on the exercise bicycle.

According to him, everything is going as well as can be expected, the refugees (I mean, displaced persons) in the Superdome are getting food and water, most everyone is being orderly and patient, and he’s not aware of any disorder, or bodies in the street, or anything like that. However, that’s not what CNN is saying tonight (even contradicting his press statement about violence in the street), MSNBC’s cameraman at the Superdome sure seemed to be showing little more than really pissed off DPs, and then there is this guy who stayed behind (it’s not clear what for – to safeguard his company’s data perhaps?) and has liveblogged the whole thing. If what he says is to be believed, conditions in NOLA are very chaotic and dangerous right now, and are not getting much better with time.

It’s difficult to know what’s really happening right now. I’m not going to be as naive as Brad Delong, who says:

I guess I was naive.

I thought that in the wake of Katrina's passing we'd see flotillas of helicopters, fleets of boats, and public health and public safety professionals from all over the country giving booster shots and restoring order within hours. I expected to see rapid, active, and aggressive disaster-recovery response from rescue assets prepositioned nearby but out of the reach of the hurricane.

However, I am now curious about what’s been the history of disaster response, especially with the Clinton-era FEMA, when it was being led by a professional emergency manager (James Lee Witt) and not some political hack. Maybe the response takes this long even when it’s run capably, and maybe it doesn’t. Looks like I’ll have some reading to do, to know for sure. . . . My point about Michael Brown’s public statements, and those of his boss, Secretary of Homeland Security Michael Chertoff, is that they appear to follow the Bush Administration standard operating procedure, which is to lie their asses off when they’re in trouble. At some point, we are going to need an accurate appraisal of what happened, no matter how painful, so that there are some lessons-learned from this sorry episode to help make improvements in disaster preparation and response. But will the Bush Administration, in an effort to save face, suppress the facts about how the federal government responded to this crisis?

Note to Kevin Drum – you make some good points about the cluelessness of Bush Administration officials. But you have to wonder, where is the Governor of Louisiana in all of this?


Postscript, September 2, 2005

If the relief effort is going so well, why are we now receiving reports that troops are being sent to New Orleans with shoot-to-kill orders?

Oh, and for FEMA director Brown, who said:

"I don't make judgments about why people chose not to leave but, you know, there was a mandatory evacuation of New Orleans," he said.

Perhaps a lot of those people were poor, and had no access to the things to make an escape such as money and a car, unless there was help from the government. But that sounds too much like disaster preparation, which along with disaster mitigation, is not really FEMA’s mission now in the age of 9-11.