Formaldehyde in Trailers and Other Things You Thought Were Taken Care of Years Ago

It’s been a bit of a surprise to hear about this issue of refugees from Hurricane Katrina being exposed to formaldehyde emissions from the wood paneling in their trailers. Not because of the fact that thousands of people are still living in emergency trailers two years after the disaster; indifference and sometimes callous behavior, especially directed at the most vulnerable members of society, is a calling card of the Bush Administration. Not because FEMA’s lawyers advised not performing air sampling because it would imply FEMA ownership of the problem; I’ve seen lawyers give that kind of advice before. But that 20 years after this problem had first been discussed, we’re still having the problem of people breathing formaldehyde emitted from pressed-wood products. The IARC has concluded there is sufficient evidence both in humans and laboratory animals that formaldehyde is carcinogenic.

Air monitoring sponsored by the Sierra Club has shown that 83 percent of the trailers tested in Mississippi, Louisiana and Alabama have concentrations of formaldehyde in air above 0.1 ppm. This study reported formaldehyde concentrations as high as 0.34 ppm, which is higher than the ACGIH short-term exposure limit (it is recommended that worker exposure to the short-term exposure limit be held to 15 minutes, with no more than four excursions per day). NIOSH recommends a short-term exposure limit of 0.1 ppm. These are worker exposure limits, intended for use by industrial hygienists for controlling workplace exposures, and not for use with the general public. For the public, ATSDR has developed Minimal Risk Levels for different durations of exposure. The MRL for “intermediate” duration exposure (from 14 to 365 days) is 0.03 ppm, while a MRL for “chronic” duration exposure (365 days or greater) is 0.008 ppm.

According to testimony given yesterday at the House Oversight Committee hearing, what FEMA was using as a level of concern was 0.3 ppm. Now, there isn’t any statement describing what action is taken if that level was achieved, but one hopes it was to relocate the residents to safer housing. However, there is a whiff that FEMA’s response was to largely study the problem to death, and figure out methods for mitigation. However, some of what they came up with for mitigation was laughable, including increasing ventilation with outside air, while keeping indoor temperatures and humidity low – a bit of a challenge under Gulf Coast conditions. The industrial hygienist who testified yesterday hit on the solution, being that FEMA should focus attention on getting residents into permanent housing, and out of the trailers for good.

In demonstration of the power of the Intertubes, someone has started a blog focusing on the issues of indoor air quality in “temporary” trailers.

Soft Drinks: and You Worry About the Benzene?

Consumption of sugar-sweetened beverages, and in particular, carbonated soft drinks may be a key contributor to the current epidemic of overweight and obesity. High-fructose corn syrup, a principal ingredient in these beverages has been suggested as a cause of the increased incidences of obesity and metabolic syndrome in the US. sugar-sweetened soft drinks contribute more than 7 percent of Americans’ calories, making them the largest single source of calories in the US diet. They contribute to the erosion of tooth enamal and dental caries. Consumption of caffeine and phosphoric acid in colas may have an adverse effect on bone mineral density in older women. Consumption of sugar-sweetened foods, including sweetened beverages and soft drinks, are being investigated as risk factors in pancreatic cancer. As if that isn't enough, Coca-Cola has been studied as a possible animal carcinogen.

With all of that, what is it that people worry about? Trace levels of benzene formed from the reaction of sodium benzoate and ascorbic acid. While I'm pleased that action is being taken to get a carcinogen out of the food supply (though the term "food" applies very loosely to sugar-sweetened beverages and soft drinks), I question the wisdom of being concerned about the benzene at all; there's more than enough evidence to persuade a reasonable person that drinking sugar-sweetened beverages, and particularly carbonated soft drinks is a really bad idea for your health. If you sat down and did the math, you might find that the cancer risks from the benzene exposure are probably trivial by comparison.

Getting Carbon Neutral Just Got a Bit Trickier

Awhile back, the non-profit group Clean Air-Cool Planet conducted an independent review of retail carbon offset providers. The goal of the report, is to encourage more transparency and quality across retail offset providers. Carbon offsets in concept allow an individual or an organization to reduce their greenhouse gas emissions by making payments for activities that overall mitigate emissions. Examples of offset methods include reforestation, investment in renewable energy or energy conservation projects, or purchasing emissions trading credits.

Offsets are controversial, in that it can be difficult to verify that they achieve real emissions reductions. Some providers offer certification to demonstrate that “their” offsets are reducing emissions. The Clean air-Cool Planet report discusses in further detail the intricacies and pitfalls of becoming carbon neutral. Some are frankly scathing of the process, damning it as a way of maintaining business as usual without making any real effort to reduce emissions. George Monbiot likens the process to the selling of indulgences in the Middle Ages, for people wishing to pay to redeem their sins without actually having to do anything to stop sinning (though there is something appealing about equating SUV ownership with sin. . . .).

Now, a new report from Integrated Sustainability Analysis-UK, a consultancy (what the British call “consulting firms”), raises more questions about the definition of the carbon footprint.

Despite its ubiquitous public use however, the scientific literature is surprisingly void of clarifications, let alone definitions of the term 'carbon footprint'. This report explores the apparent discrepancy between public and academic use of the term ‘carbon footprint’ and suggests a scientific definition based on commonly accepted accounting principles and modelling approaches. It addresses methodological questions such as system boundaries, completeness, comprehensiveness, units and robustness of the indicator.

It makes sense when you think about it. You’re plugging your airline miles into a web page, and it tells you how much more your ticket costs to be “carbon neutral”. That’s scarcely transparent. You can’t even be sure that the arithmetic is being done correctly, even before considering the more substantive methodological questions raised in ISA-UK’s report. Those who are truly interested in going the offsets route for reducing your contribution to greenhouse gas emissions need to get themselves more educated about these matters. Joel Makower over at WorldChanging has a good summary of the CA-CP report for those not sufficiently interested to wade through it. His take home point is:

You've got to ask good questions when buying offsets; the report suggests several questions to ask. Whether you'll fully grok the answers, of course, is a whole 'nother thing.

His article is informative, but he sort of leaves it up to you to figure out specifically what questions to ask. I’m ok with learning about it, but then again, I already know where to find the GHG Protocol.

Must Read Article on Bisphenol-A in the Public Library of Science

There’s a great piece of science journalism over on the Public Library of Science – Biology written by Liza Gross, highlighting Fred vom Saal with the University of Missouri and his work studying the developmental effects of endocrine disrupting chemicals, particularly the plastic monomer bisphenol-A (BPA).

Dr. vom Saal started his research with the risks of exogenous estrogens with diethylstilbestrol (DES). From 1938 to1971, U.S. physicians prescribed DES to pregnant women to prevent miscarriages and avoid other problems with pregnancy. At the time, it was thought that miscarriages and premature births occurred because some pregnant women did not produce enough estrogen naturally, and that the use of DES was safe. It is estimated that 5-10 million pregnant women and the children born of these pregnancies were exposed to DES.

However, what Dr. vom Saal is best known for is the controversy regarding the possible health risks from the endocrine effects associated with low-dose exposure to BPA. BPA is used as the monomer to manufacture polycarbonate plastic. Polycarbonate is used as the lining for most food and beverage cans, as dental sealants, and as an additive in other widely used consumer products. BPA is one of the highest-volume chemicals produced worldwide. Heating of containers to sterilize food, the presence of acidic or basic food or beverages, and repeated washing of polycarbonate containers have all been shown to result in an increase in the rate of leaching of BPA. According to the Centers for Disease Control (CDC), most everyone in the U.S. is exposed to trace levels of BPA, based on urinary monitoring data.

BPA is a textbook example of an environmental toxicology and health policy problem. It's a commercially important chemical substance. Nearly all of us are constantly exposed to low levels of it. The mechanisms for potentially adverse health effects are subtle and occur at low levels of exposure. The most vulnerable populations for these effects are young children, both during pre-natal development and in infancy. The kinds of biological effects observed in laboratory animals with low levels of exposure include stimulating the growth of prostate (in males) and mammary tissues (in females), potentially increasing susceptibility to carcinogenicity later in life; alterations in hormonol with effects such as early onset of sexual maturation; and neurobehavioral effects. Recently, one study provided indications that BPA might promote insulin resistance, a risk factor for diabetes. These effects can be observed at levels around 10-fold greater than levels of exposure in humans, which is not a comfortable margin of safety. As yet, adverse effects have not been observed in humans, though there hasn't been a concerted effort made to examine human populations.

Assessment of the human health risks from exposure to BPA gets really bogged down in arguments over the weight of evidence considered by different groups reviewing the evidence, disagreements about what really constitutes a significant adverse human health effect, the financial sponsorship of those groups, and arguments over differences in testing methods used by various investigators. Whether or not a low-dose estrogenic effect can be detected seems to depend on numerous factors including the strain of test animal used, purity of the chemicals used, timing of the dosing, composition of animal feeds and whether or not a positive control (a test group dosed with a known endocrine disruptor such as DES). The history of the scientific review of BPA further obscures the public debate. Ms. Gross chronicles the progression from government agency (the National Toxicology Program) concluding in 2001 there was credible evidence of low-dose estrogenic effects, to review by the Harvard Center for Risk Analysis report sponsored by the American Plastics Council which concluded that the evidence was weak that low-dose estrogenic effects were present in the animal studies, to the rebuttal co-authored by vom Saal in 2005 that called for a new risk assessment of BPA, to the 2006 follow-up by Gradient Corporation which amplified the conclusions from the HCRA report.

The article brings up the topic of the "expertise-for-hire" syndrome which produces scientific information that calls into question our understanding of potential occupational or environmental health risks, particularly when the studies in question indicate there may be adverse health effects. The outcome is the call to delay or defer risk-reduction activities until further studies can be conducted, because there isn’t sufficiently compelling evidence that a health risk exists and warrants action. David Michaels and Celeste Monforton, at George Washington University have written extensively on this topic (I blogged one of their articles a few years ago). More information on this subject of "manufactured uncertainty" can be found at the Project on Scientific Knowledge and Public Policy website. What the manufactured uncertainty tactic accomplishes is to provide a counter-point which responds nicely to the media's urgent need to create a simplistic, dramatic narrative of two opposing points of view; an approach that is used sell airtime, newspapers or magazines, but isn't terribly helpful for informing the public about an important environmental health policy issue.

The commentary co-authored in 2005 by vom Saal and endocrinologist Claude Hughes observed that most of the industry-funded studies concluded that adverse estrogenic effects were weak or non-existant, while the studies that were government-funded identified adverse effects. While there's no cry of foul play or anything like that, vom Saal suggested many investigators were unfamiliar with the methods used to study low-dose estrogenic effects:

“The moment we published something on bisphenol A, the chemical industry went out and hired a number of corporate laboratories to replicate our research. What was stunning about what they did,” vom Saal says with a mix of outrage and bemused disbelief, “was they hired people who had no idea how to do the work. Each of the members of these groups came to me and said, ‘We don't know how to do this, will you teach us?’”

There's always a risk in placing a lot of emphasis on findings from one lab that others can't replicate. However, a quick search of PubMed seems to show recent papers from multiple investigators observing low-dose estrogenic effects, so it seems that there is some reproducibility, one of the gold standards of scientific evidence. Another controversy with BPA research is that the source of funding seems to influence whether or not adverse effects are detected in an animal study. It's a complex matter. According to vom Saal and his co-author, Claude Hughes, the industry-funded studies lacked positive controls or used insensitive animal strains. Hughes does allow for the possibility of publication bias in the government-funded studies (i.e. do the studies with negative results get published?). To further complicate matters, there are various opinions regarding what gets considered as an adverse health effect in a laboratory animal, and how that is considered in a human health risk assessment. Coincidentally, NTP has recently published proceedings from a workshop on the relevance of rodent bioassays in assessing hormonally-induced reproductive tumors, which expresses a concern that currently available animal models aren't adequate for assessing these hormonally-induced effects.

Sorting through all of this must be tough for the non-specialist public and decision makers. The kinds of adverse effects being observed in laboratory animals sound like really bad things, but they seem to be pretty hard to detect and its difficult to say how they relate to human health. At the same time, how conclusive does the evidence from animal studies need to be before you start taking steps to reduce exposure? With DES, the evidence of adverse effects was first observed in humans, then confirmed with animal studies, which is not exactly the environmental health surveillance model you'd want to emulate. It comes down to a policy and philosophical judgment with the competing philosophies being "sound science", deferring action until we know or have fully assessed the health risks and the precautionary principle of taking protective action based on a more conservative interpretation of limited data. Such arguments can only be partially informed by the science.

I'm wondering if we could split the difference, while we're figuring out what the rodent data are telling us about BPA. There's probably enough evidence to argue that a sensible course would be to act now to restrict the uses with the highest potential for human exposure. These probably would be the food and beverage containers and dental appliances, where BPA is being leached and ingested. There are other uses that we probably don't have to worry about just this moment - how much BPA are you going to absorb through your fingertips from a polycarbonate compact disc? However, I'm not optimistic that a policy of moderation is going to have too many takers. As Jim Hightower said, "the only things in the middle of the road are yellow stripes and dead armadillos"; the plastics industry is going to stubbornly defend all uses; the endocrine disruption activists will stubbornly argue that we need to ban polycarbonates; both sides will have their experts, which prolong rather than resolve the scientific controversy; and the mainstream media gets to have conflict, narrative and drama, which might be great for attracting readers or viewers, but provide little for informing them.

Altogether this was a nice piece of science journalism, and as you can see, gave me a bit to think about. If you are new to the topic of BPA and confused by the sound bites you read in the mainstream media, this is a great place to start learning about this chemical and the associated environmental health issues.

Warning – Incoming Screed About Tiresome Liberal Bromides

Reading Huffpo is a guilty pleasure and I really need to discipline myself to stop it. Then, I’ll have additional time to do more useful stuff, such as reading Fark. And, I won’t have to read blog editorials titled, “Will Congress Derail Attempts to Reduce the Terrorist Threat from Toxic Trains,” from Charlie Cray, director for the earnest-sounding Center for Corporate Policy.

The ride started out a little bumpy for me:

By virtue of the fact that it is unwilling to phase out the production of chlorine -- a gas that was eliminated from use in warfare after WW I -- the chemical industry and its major customers that use and transport the deadly green-yellow substance have condemned towns across the country to be perpetual potential targets for terrorist attacks.

The industry's claim is that they don't need to make safer substitutes so long as their plants are guarded by the 4 G's -- guards, guns, gates and gadgets.

Ok, let’s hold up here for a moment. In all of that, was there even a flash of realization that WE ultimately are the major customers of the chemical industry? If we didn’t have a fondness for safe drinking water and PVC, there wouldn’t be a lot of chlorine moving around by rail.

Some in Congress understand the threat and have attempted to taken action. Rep. Markey (D-MA) led the way in the House with an amendment to the Rail and Public Transportation Security Act of 2007 (H.R. 1401) that would dramatically enhance rail security and safety by re-routing ultra-hazardous cargo, such as chlorine gas, around high threat urban areas.

The bill was adopted in the House by a bi-partisan vote (299 to 124) on March 27th. Nevertheless, there is still plenty of resistance to the re-routing language in the Senate, where it would likely need approval from both the Commerce, Science and Transportation Committee and the Committee on Homeland Security and Government Affairs.

Congress can reduce the threat to tens of millions of people immediately with this rerouting requirement. . .

Can anyone see Congress doing anything that’s going to reduce any threat “immediately”? H.R. 1401 was referred to the Senate on March 28, 2007. The status of the bill according to THOMAS is, “Received in the Senate and Read twice and referred to the Committee on Commerce, Science, and Transportation.” It’s not even on the Senate committee hearing schedule right now. Since Congress has punched out for the summer, this probably won’t get any traction until fall, unless it gets lost in the 2008 budget shuffle. Until the time when the Senate leisurely takes up this matter, or the next chlorine tank car derails (which will speed things up a bit). Until then, you can do some reading up on this issue, courtesy of the CRS.

The top-down approach of time-consuming arguing and horse-trading in Congress, followed by time-consuming rule-making in a regulatory agency, followed by time-consuming implementation by the chemical and rail industries, is no way to get something done “immediately” (does anyone else fail to understand the process of how you get from legislation to something tangible being implemented). How about a grassroots approach? For example, what about providing funding for communities, particularly the small communities such as Minot, ND and Graniteville, SC which are in the rail corridor hazard footprints, along with funding for some nonprofit organizations such as EWG, to work on this issue? It would be kind of like a secular version of faith-based initiatives. They could use that money for litigation, social marketing or public relations campaigns to create financial pain and adverse corporate image which might persuade transportation companies into providing safer routing.

. . . but ultimately, to eliminate the threat we need to phase chlorine out of industrial use, just as we've for the most part eliminated it as a tool of war. The way to do so has been described many times, including by Joe Thornton in his book, Pandora's Poison (MIT).

This is blindingly obvious to the point of absurd. There’s a lot of stuff like this we have to get done, like we have to stop driving our cars and trucks so much, to keep oil imports from becoming critical national security and economic problems; and we should eat our (minimum) five servings a day of fruits and vegetables and exercise an hour a day to stave off chronic diseases that mushroom health care expenses to 16 percent of our total economic output; and we should adopt energy conservation measures to stave off disastrous climate change. We’re not moving too fast on any of them. For myself, I’m skeptical that Congress is going to be more than marginally effective in addressing any of these problems, including hazmat transport safety. The argument of “let Congress do it” smacks of serious inside-the-Beltway-out-of-touch-with-reality thinking. The kind of thinking almost enough to persuade one to believe that Matt Taibbi’s obnoxious article about liberals makes a good point.

Maybe now I will have to read Pandora’s Poison to see what the magic formula is for phasing out chlorine. I’m ok with adding to the list I’ve started finding alternative disinfectants for drinking water. Here’s where you can start doing your reading on the subject, if you want to convince your local politicians and water treatment operators to make the change. Kicking the PVC habit could be tougher, but if you’re interested in looking into that, you can start here. Right now, I’d be happy with a baby step, such as phasing out PCE for dry cleaning.

Oh, and I’m not that sure that phasing out chlorine as a war gas is a good analogy for phasing it out as an industrial chemical. I think chlorine was replaced in World War I because we found better toxic gases to poison soldiers with.