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#235 - Chemical Regulation -- Part 2: What 'Toxics Use Reduction' Is Not, 28-May-1991

Global pollution by toxic chemicals is increasing. Chemical
contamination now contributes to the following kinds of problems:
global warming, ozone depletion, acid rain, rising cancer rates,
increasing asthma, the widespread poisoning of children by lead,
escalating rates of Parkinson's disease and of Lou Gehrig's disease,
growing infertility among American men and women in their prime
reproductive years, the contamination of breast milk, a new disease
called "multiple chemical sensitivity," and more. Yet current
approaches to regulation do not incorporate ways of dealing with the
continued spread of chemicals worldwide. As we saw last week, two
researchers at Oak Ridge National Laboratory (ORNL) recently published
a brief catalog of global pollutants and, using EPA (U.S. Environmental
Protection Agency) methods for assessing cancer risk, they concluded
that the "background" cancer risk from just 11 chemicals is one-in-a-
thousand, which is about 1000 times more risk than EPA would usually
allow any individual polluter to create. (ENVIRONMENTAL SCIENCE &
TECHNOLOGY Vol. 25 [May, 1991], pgs. 814-819.) Here is the heart of the
problem: by focusing only on controlling risks to the "most exposed
individual," EPA has allowed thousands of small polluters to dump
chemicals into the environment; together these small sources add up to
a big hazard, yet none of them individually presents a large enough
hazard for EPA to officially notice.

To prevent pollutants from spreading everywhere on earth, we must
prevent the introduction of dangerous pollutants into all media: air,
water, and soil. To do this, we must either use fewer dangerous
chemicals, or we must destroy them before they are released into the
environment. In the case of metals, which can never be destroyed, we
must use less of them. In the case of toxic organic chemicals, such as
dry cleaning fluid (tetrachloroethylene, also known as
perchloroethylene, or perc), we can either use less of it or we must
destroy it after we use it, before it gets away from us. An organic
chemical is considered "destroyed" when it is broken down into its
elements. (There are only 92 naturally-occurring elements and
everything on Earth is made up of combinations of these 92 building
blocks. It is worth noting that some of the building blocks themselves
are toxic, so these will need to be used in strict moderation, or not
at all, if we are to avoid poisoning the earth. Thallium, mercury, and
cadmium fall into this category. Elemental chlorine probably belongs in
this category as well--see RHWN #225.)

Any organic molecule that can be put together can also be taken apart--
"destroyed"--for a price. That's the hitch. After a chemical like perc
has cleaned someone's clothes a few times, it is dirty and not very
useful. It is ready for discard. Now would be the time to "destroy" it.
EPA's solution to this problem is to burn it in an incinerator.
Unfortunately, as the ORNL researchers noted "...emissions from
incinerator stacks tend to release pollutants directly into the
atmosphere." In fact, incinerators release unburned chemicals directly
via the stack but also via leaks and spills during transport and
handling. Moreover, once chemicals are in an incinerator's combustion
chamber, they can recombine into new chemicals (called PICS--products
of incomplete combustion) which can be more toxic, more long-lived, and
all together more dangerous than the chemicals the incinerator was
supposed to destroy. Incineration is good at limiting a polluter's
liability, but it is not a solution to chemical contamination--it is
part of the problem.

There are other ways to destroy organic molecules besides incineration,
but they are generally not used because they are expensive.
Furthermore, even if we could afford to use more efficient machines for
destroying organic molecules, routine spills and leaks during normal
handling of large quantities of chemicals would poison the planet
sooner or later, so reducing the use of organic chemicals (at least
those that are toxic, or are persistent in the environment, or that
enter food chains) seems the only real solution. This is what is
generally meant by pollution prevention, or toxics use reduction (TUR).
What exactly is toxics use reduction? Let us try to say what it is not.

(1) Toxics use reduction is not reducing the concentration of toxics.
If you have one pound of toxins mixed with one pound of water and you
add another pound of water, you have cut the concentration of toxins,
but you have done nothing to protect the environment. It is the total
quantity of toxins entering the environment that is important, not the
concentration. So toxics use reducion will seek to reduce the total
mass (amount) of toxins entering the environment, regardless of
concentration. (We note that EPA permits issued to polluters describe
the allowable levels of pollution as a particular concentration. This
reflects the EPA's desire to protect the most exposed individual not
the general environment. These permits are a key part of the EPA
approach that has allowed the global pollution problem to get entirely
out of hand.)

(2) Toxics use reduction is not EPA's recently announced Industrial
Toxics Project (ITP). In January, 1991, EPA chief Reilly announced with
great fanfare a voluntary "pollution prevention" program. Reilly asked
600 industrial polluters to voluntarily reduce their emissions of 17
toxic chemicals by 33% by 1992 and by 50% by 1995.

This sounds good on paper. However, industry will measure and report
its own progress. EPA will not check on the accuracy of the data.
Industry reports its emissions of these chemicals each year under the
law known as SARA Title III (specifically the part that calls for the
Toxics Release Inventory, or TRI). Reporting is known to be inaccurate.
In fact, when the Chemical Manufacturers Association asked EPA to allow
TRI-reported emission reductions to be applied as a "pollution credit"
under the new Clean Air Act, EPA refused, saying that the Clean Air Act
was a regulatory program that needs better data than a strictly
voluntary program could provide. It seems apparent that Mr. Reilly's
ITP will allow industry to claim great progress toward pollution
prevention, progress that George Bush will no doubt take credit for
during his next election bid. Meanwhile, EPA admits that the data will
be flakey, not of suitable quality to form the basis of a regulatory
program. This is the lesson we can learn from William Reilly: effective
pollution prevention will not be voluntary and it will require careful
bookkeeping by proper authorities. One good way to achieve this would
be to levy a tax on each pound of pollution, which would put Internal
Revenue Service (IRS) into the business of measuring pollution so it
could collect the tax. Self-reporting by industry might work, with IRS
doing spot checks, if corporate officers could be penalized for lying
about emissions as they might for lying about income.

(3) Toxics use reduction is not risk reduction. EPA has managed to
define most environmental problems in terms of "risk assessment"--a
mathematical procedure based on so many half-baked assumptions that it
allows an accomplished risk assessor to reach any conclusion he or she
sets out to reach. (See RHWN #194, #195, #204.) Since EPA now defines
"pollution" largely in terms of risks as revealed through risk
assessments, it seems only logical that the agency will soon start to
define "pollution prevention" in terms of reduced risks as revealed by
risk assessments. No doubt when Mr. Bush's election campaign is in full
swing, EPA will announce that its voluntary emissions-reduction program
has achieved a giant reduction in the risks to which the public is
subjected, and this will be declared a major victory for pollution
prevention. EPA will not have made a single measurement of an actual
decline in the amount of any dangerous chemical entering the
environment (which is the only true measure of toxics use reduction)--
but Mr. Bush will nevertheless declare himself the pollution prevention
President. The Bush-Reilly toxics use reduction plan has the important
advantage that it will not interfere one whit with the continued
poisoning of the planet for profit.

--Peter Montague

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Descriptor terms: global environmental problems; toxic substances;
disease; ozone depletion; global warming; cancer; reproductive
disorders; breast milk; mcs; oak ridge, tn; epa; risk assessment; air
pollution; water pollution; pollution prevention; cleaning fluids;
thallium; mercury; cadmium; chlorine; organic chemicals;
perchloroethylene; pics; incineration; tri; sara; george bush;
regulation; monitoring; voluntary emissions-reduction program;