Greetings to President-Elect Obama's Transition Team

Hi President-elect Obama’s transition team and thanks for stopping by. You’re asking people for their ideas on energy and the environment, and here’s my contribution. My apologies in advance for not using the dinky comment box provided on your website, but this does allow me to develop ideas a little more fully. I’ll be brief.

Vapor intrusion is a growing problem with hazardous waste sites being cleaned up under Superfund and RCRA Corrective Action. Vapor intrusion occurs where there is contamination of soil or groundwater with volatile chemicals such as the solvent TCE, the dry-cleaning chemical PCE or petroleum hydrocarbon constituents such as benzene. If there are buildings located near the volatile contaminants in soil and groundwater, these can migrate into indoor air and can be inhaled by the occupants. Residents in communities affected by vapor intrusion are concerned about the health risks from inhaling these volatile chemicals. I speak about this issue as someone who has investigated vapor intrusion at hazardous waste sites across the U.S., and has participated in many national conferences on vapor intrusion sponsored by EPA, Air and Waste Management Association and other organizations.

One solution to vapor intrusion is to install engineering controls to prevent the volatile chemicals from entering a building. These are the same types of engineering controls that have been used for many years to prevent radon from entering buildings. These engineering controls work by preventing the leakage of air through the floors and walls of a building, a fact which spawned the idea of linking mitigation of vapor intrusion with building energy conservation. “Green building” techniques increase energy efficiency and improve indoor air quality in buildings by eliminating air leakage and by reducing the pressure differences between outdoors including the subsurface and indoors - the same strategy as used for mitigating vapor intrusion.

Linking green buildings concepts and vapor intrusion provides a significant opportunity to promote vapor mitigation and reduce health risks, while achieving co-lateral environmental benefits such as energy conservation with corresponding reductions in greenhouse gas emissions. An example of the growing importance of building optimization is shown in the principles of building design that are incorporated into Executive Order (EO) 13423, enacted in January 2007. This EO requires federal agencies to achieve reductions in greenhouse gas emissions and energy use. Some of these reductions will occur through the sustainable design and operation of buildings.

There are some barriers that need to be overcome to achieve this linkage of hazardous waste cleanup and energy conservation. Guidance and new regulations may be needed to change the mind-sets of regulatory agencies which don’t see these engineering controls as permanent measures for reducing vapor intrusion risks. A regulatory bias against vapor-resistant construction as a remedial measure for controlling vapor intrusion can delay final cleanup decisions and can represent a barrier to the development of brownfield sites. There may also be research needs to fully integrate building energy conservation methods with the control of vapor intrusion. Another important question to be answered is how to give responsible parties – those on the hook for cleaning up the Superfund or RCRA sites – “credit” for doing and paying for more work than what’s specifically required for cleanup.

Green jobs and new forms of collaboration and teamwork in hazardous waste site cleanup are some of the benefits from linking vapor intrusion and building energy conservation. I am working with my colleagues to flesh out these ideas, and give them wider visibility. I cordially invite you to be a part of that effort. Thank you.

Precaution and Risk Assessment – A Counterpoint

Last year, Adam Finkel and Peter Montague exchanged views on the precautionary principle and risk assessment, which Dr. Montague kindly published. The occasion was Dr. Finkel’s review of Cass Sunstein’s book Risk and Reason. I much appreciate Dr. Finkel writing the review. The shorter Cass Sunstein I gleaned from Dr. Finkel’s review is: risk assessment beyond its role in managing environmental protection, is also anti-stupid medication for the millions of people who can’t think rationally about risk. I’ve already seen enough examples of risk analysts talking down to the other participants in environmental management, so I’ll probably pass on reading the book. I also wonder if it’s escaped Dr. Sunstein’s notice that the attitudes many people have about risks and risk assessments are shaped by a lack of trust, frequently justifiable, in experts, regulators, and responsible parties, coupled with the inability of analysts to articulate clearly the nature of health and environmental risks and the inability of decision makers to define how risk management activities address those risks.

My thinking about the precautionary principle has evolved of late, to the point that I recant my statement that it’s probably inarticulate as being overly harsh. Still, I feel that the way the precautionary principle is expressed by many is more as of a series of aspirations rather than a framework for reducing risks, and it still needs something like risk assessment yoked to it to be useful for decision makers. But as valuable as Dr. Finkel’s and Dr. Montague’s debate is, I don’t look at risk assessment/precautionary principle as a duality or even a continuum. And I know that Dr. Montague’s statement that “[r]isk assessment is the most powerful intellectual tool that the poisoners and destroyers of the planet have ever invented” isn’t correct - otherwise I wouldn’t be having to fight so hard to get funding for the risk assessments I’m responsible for preparing.

Several years ago, Dr. Finkel captured some interesting thoughts about risk assessment in a paper titled, “Disconnect Brain and Repeat After Me: Risk Assessment is Too Conservative”. When I return to the “debate” of risk assessment versus precautionary principle, I’ll provide some observations based on this paper.

Evil Corn

For me, reading political blogs is akin to smoking – it’s a filthy habit. These days, I read largely for amusement because the amount and quality of actual information I glean from them is generally pretty small. And it soaks up more of my time than is really good for me. While it doesn’t justify the time I expend, I do run across a nugget from time to time. For example, here’s a tidbit about GM (genetically modified) foods breathlessly posted by Christy Hardin Smith over at Firedoglake. She’s alarmed because there may be some recent and preliminary evidence that corn modified to produce Bacillus thuringensis (Bt) toxin may produce infertility in mice, and therefore we’re all going to become sterile. Per standard operating procedure with ideologues who slice the world into good guy/bad guy narratives (GMOs = Monsanto = BAD), the post was thin on details, but there was a trail of breadcrumbs pointing to some richer sources of information which looked interesting enough to break my blogging fast. As I peeled this onion, I found that this issue has more complexities which, if you want to do more than foam at the mouth about how evil Monsanto is, need to be explored and incorporated into the policy discussion. For now, I’m going to pass on commenting on her subsequent handwringing about linkages of Bt corn and infertility with reproductive health risks associated with endocrine disrupting chemicals. The liberal blognoscenti can get educated about cumulative risk assessment some other time.

Gourmet magazine online has more of the story on Bt corn here. The Center for Food Safety press release has a link to the study. The study itself is published by the Austrian Federal Ministry for Health, Family and Youth, which is responsible for regulation of genetically-modified organisms under European Union directives. There, that wasn’t so hard was it? I’m not going to demand that folks wade through the entire 105 page report, but they could at least struggle through the page and a half executive summary.

The researchers fed mice a diet of 33% genetically modified corn which produces Bt toxin along with control groups fed 33% non-genetically modified corn. Two different kinds of reproductive studies were performed, a multi-generation study where the mice were fed GM (or non-GM) corn and bred over four successive generations, and a “reproductive assessment by continuous breeding” where the same generation of mice were fed GM (or non-GM) corn but delivered four successive litters. These studies were designed to identify reproductive hazards, and don’t directly reflect the risks associated with the patterns or levels of consumption of GM corn by humans (this kind of work is combined with other research to address those questions).

The multi-generation study is probably inconclusive; the differences in numbers of offspring between the GM and non-GM groups were not considered to be statistically significant. The experimental design involved 24 breeding pairs of mice per study group. Would larger study groups produce more statistical power? The “reproductive assessment by continuous breeding” (RACB) study showed significantly reduced numbers of offspring in the mice fed GM corn. The investigators state that the multi-generation study design is less physiologically demanding on the animals compared with the RACB design – suggesting that the RACB study might have been more sensitive.

The Austrian investigators did some admittedly cool genomic testing, which reportedly identified some differences in metabolic pathways between the GM and non-GM mice. This kind of genomic testing is in its infancy, so there isn’t a lot of experience in how to use the data. But many feel there’s a lot of potential value in genomic techniques.

Monsanto questions these results, noting the overall higher offspring mortality in both the GM and control (i.e. non-GM) groups in the RACB study, and pointing to flaws and limitations in the presentation of the results. Its position is that when the results are correctly interpreted, they don’t indicate a reproductive effect. Monsanto also questions the data quality of the genomic testing as well as the interpretation of the results.

This is as it should be. Think what you will of Monsanto, but I found its comments a useful counterpoint in my understanding of the Austrian study. Monsanto might have a fair criticism in blasting the Austrian government by doing science by press release. When you do that, someone with a megaphone, who might not worry over the details, is bound to broadcast the wrong message. The question people should be concerned about is not “is GM corn in my food going to make me sterile”, but rather why we are examining long-term reproductive effects of genetically modified foods, consumed by hundreds of millions of people, years after they’ve been introduced into the foodchain.

However, solving that puzzle requires revisiting the history of the safety assessment of GMOs, and is just going to have to wait for another day (that blogging versus day job tension again).

Footnote: there’s a nice primer on genetically modified Bt corn over at the Science Creative Quarterly, published by the University of British Columbia.