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#704 - Modern Environmental Protection--Part 1, 20-Jul-2000

Two extraordinary books have just been published by MIT Press.
Together, they describe a fundamentally new approach to
environmental protection. This week we begin reviewing Joe
Thornton's PANDORA'S POISON.[1] Soon we will review Mary
O'Brien's MAKING BETTER ENVIRONMENTAL DECISIONS.[2] In these two
books, we see the best environmental thinking of the past 15
years really coming together. This is what we've all been waiting
for -- a new system for environmental protection that can unite
the various strands of the environmental community behind a few
shared goals and a common agenda. This IS powerful reason for
hope.

Using chlorinated chemicals as a case study,PANDORA'S POISON
reveals how (and why) the current system of environmental
protection has failed so miserably. To replace this failed
system, Thornton describes a fundamentally new approach.

Thornton is a scientist, a molecular biologist, and the bulk of
his book describes in detail the extensive damage that
chlorinated chemicals have already done to humans and wildlife.
Thornton shows that in just 60 years, the petrochemical industry
has contaminated every living thing on earth with novel
toxicants, some of which disrupt life's fundamental processes at
levels measured in parts per trillion (a proportion equivalent to
one drop in a train of tank cars 10 miles long). Introduction of
organochlorine chemicals by Dow, Monsanto, DuPont and others was
an unprecedented act of hubris combined with a studied ignorance
as to consequences. And of course it was all perfectly legal,
licensed and overseen by the world's most vigilant regulatory
agencies. How could this happen? Thornton tells us how.

The chemical industry now produces an astonishing 40 million tons
of elemental chlorine each year, which it then combines into
11,000 different chlorinated chemical products, plus thousands of
other unintended chlorinated byproducts, virtually all of which
are toxic and all of which eventually make their way into the
environment, where, for the most part, nature has no efficient
means for decomposing them. Most of these toxicants interfere
with the fundamental processes of living things. As a result,
"Every species on earth -- including humans -- is now exposed to
organochlorines that can reduce sperm counts, disrupt female
reproductive cycles, cause endometriosis, induce spontaneous
abortion, alter sexual behavior, cause birth defects, impair the
development and function of the brain, reduce cognitive ability,
interfere with the controlled development and growth of body
tissues, cause cancer, and compromise immunity. If we stopped all
further pollution today, these compounds would remain in the
environment, the food web, our tissues and those of future
generations for centuries," says Thornton, summarizing the
findings of more than a thousand scientific studies.(pg. 6)

Thornton makes it clear that the decision to add chlorine to
industrial organic chemicals was one of the most profound errors
that humans have ever made. He argues cogently that most
chlorinated chemicals should be phased out over the next several
decades, and we should adopt a new system of environmental
protection that would prevent such errors in the future.

Thornton is an excellent writer, so his book is easy to read, but
the book is also an intellectual tour de force, synthesizing
scientific information from toxicology, epidemiology, ecology,
molecular biology, and environmental and industrial chemistry.
But Thornton does not stop there; in the final chapters he delves
into history, ethics, and the philosophy of science to describe
and explain the system of environmental protection that allowed
the global organochlorine disaster to unfold. He labels the
current, failed system the "risk paradigm" and he proposes a
fundamentally new system for environmental protection, which he
calls the "ecological paradigm."

As Thornton says, "A paradigm is a total way of seeing the world,
a lens that determines how we collect and interpret data, draw
conclusions from them, and determine what kind of response, if
any, is appropriate."(pg. 7)

The "risk paradigm" tells regulators which problems are
important, and how to handle them. Unfortunately, it is an
entirely inadequate tool for managing chlorinated chemicals and
other persistent or bioaccumulative pollutants like mercury,
lead, asbestos, and biologically active radioactive elements such
as plutonium.

The risk paradigm tries to manage pollution one chemical at a
time by allowing chemical discharges so long as they don't exceed
a numerical standard of "acceptable" contamination. This approach
assumes that ecosystems have an "assimilative capacity," a
certain ability to absorb and decompose chemicals without harm,
and it assumes that humans can learn what that assimilative
capacity is. The risk paradigm also assumes that organisms, such
as humans or birds, can accommodate some degree of chemical
exposure with no or negligible adverse effects, so long as
exposure remains below the "threshold" at which toxic effects
become significant.

The "risk paradigm" aims to set "acceptable exposures," chemical
by chemical. The "risk paradigm" uses quantitative risk
assessment to establish "acceptable" exposures and regulators
then set discharge limits, chemical by chemical, intending to
make sure that "acceptable" exposure limits are never exceeded.
Industry then applies end-of-pipe control devices (filters,
scrubbers, etc.) to capture pollutants and move them to a
different place. That is how the current system of environmental
protection was designed, and that is how it operates today.
Obviously, it places great faith in science to discover how
nature works and to predict and understand harm in individual
organisms and in complex ecosystems -- a faith that is misplaced
because science is simply not up to the task.

The "ecological paradigm" is entirely different. As Thornton
says, "First and foremost the Ecological Paradigm recognizes the
limits of science: toxicology, epidemiology and ecology provide
important clues about nature but can never completely predict or
diagnose the impacts of individual chemicals on natural
systems."(pg. 10) The proper response to this inevitable
scientific uncertainty is to avoid practices that have the
potential to cause severe damage, even in cases in which we do
not have scientific proof of harm. This is the precautionary
principle, familiar to RACHEL'S readers. (See REHW #586.)
However, Thornton points out, the precautionary principle does
not tell us what kind of action to take. So we need to supplement
the precautionary principle with three additional principles:
zero discharge, clean production, and reverse onus. Together,
these ideas constitute a new "ecological paradigm" for protecting
the environment.

Zero discharge means we must eliminate rather than allow the
release of substances that persist or bioaccumulate (because they
remain in the environment, available to cause trouble). Their
persistence tells us that nature does not have means for handling
them.

Clean production emphasizes the redesign of products and
processes so they don't use or create toxic chemicals -- avoiding
trouble before it occurs. The point of clean production is to
seek out, and adopt, the least harmful alternatives.

Reverse onus is a new way of evaluating chemicals. Using the
principle of reverse onus, the burden of proof, which now rests
with society to prove that a chemical will cause harm, is shifted
to those who want to produce or use a novel chemical. Such people
must demonstrate in advance that their actions are not likely to
pose a significant hazard. Chemicals currently in use that cannot
meet this criterion will be phased out in favor of less damaging
alternatives.

In the "risk paradigm," a lack of data about a chemical is taken
as evidence of safety, so untested chemicals are allowed to be
used without restriction. The result is the current permissive,
laissez faire system in which anything goes until someone can
prove to a scientific certainty that significant damage has
occurred.

In contrast, the "ecological paradigm" amounts to "a program of
continued reductions in the production and use of all synthetic
[human-created] substances, with priority given to chemical
classes that are known to persist, or bioaccumulate, or cause
severe or fundamental disruptions of biological processes."(pg.
11) As Thornton says, "By reversing the onus in environmental
regulation, the Ecological Paradigm simply applies the standard
that society now uses for pharmaceuticals -- demonstrate safety
and necessity before a drug is licensed for introduction into
patients' bodies -- to chemicals that will enter our bodies
through the environment. Reversing the burden of proof would also
set straight the twisted ethics of the current system, in which
we mistakenly grant chemicals the presumption of innocence--a
right that was created for people--while humans and other species
are subject to a large-scale, multigenerational experiment of
exposure to untested and potentially toxic chemicals."(pg. 11)

Four Reasons Why the Risk Paradigm Has Failed

Reason#1: The risk paradigm only comes into play late in the
process of creating pollution. Under the risk paradigm, chemicals
are produced and used without any restrictions. However, just
before the chemicals are about to be discharged into the
environment, they are captured, treated and "disposed of" in a
landfill, incinerator or other device.

As Thornton points out, this end-of-pipe approach fails for four
reasons:

a) When the product itself contains poisons, pollution control
devices are useless. He gives the examples of pesticides sprayed
on a field, paint stripper sold to a handyman, and PVC [polyvinyl
chloride] pipe installed in a building that may one day burn
down, creating significant amounts of dioxin. In none of these
examples will end-of-pipe pollution control devices help.

b) Pollution control devices -- filters and scrubbers -- merely
shift contaminants from one place to another -- from the water to
the land, or from the land to the air (then back to the land
somewhere else). Eventually, captured pollutants always make
their way into the environment.

c) Control technologies deteriorate and break down just as all
mechanical systems must. Therefore, they don't always work as
well as they were designed to work and they release contaminants
increasingly as time passes.

d) Pollution control devices are only designed to capture a
certain proportion of the pollutants being created; beyond that,
control becomes prohibitively expensive, so a certain small
proportion of pollution always escapes. As total production
grows, the amount that escapes must grow too.

Reason #2: The concepts of assimilative capacity and acceptable
discharge -- the centerpieces of the risk paradigm -- don't work
for chemicals that persist or bioaccumulate. Chemicals that do
not break down rapidly in nature will build up in living things,
contaminating food webs. Natural systems have no "assimilative
capacity" for such chemicals and there can be no "acceptable"
discharges of such chemicals.

Reason #3: Risk assessment, another central tool of the risk
paradigm, doesn't work for systems as complicated as living
organisms in ecosystems because (a) most of the crucial
information about individual chemicals is missing; (b) our
measuring techniques are crude, so we can never be sure that a
contaminant level we believe is "harmless" is actually harmless;
(c) we are largely ignorant about how organisms function in
ecosystems so we cannot predict what will happen when we
introduce toxicants into such systems, especially when we
introduce multiple toxicants simultaneously, which is almost
always the case in the real world; (d) finally, there are genuine
surprises -- risk assessors may look for certain suspected
effects, find none, and declare a chemical harmless but the
chemical may turn out to cause an effect they did not
investigate, or an effect they never dreamed of.

Reason #4: Risk assessment was designed to deal with
well-defined, local, short-term hazards. But preventing major
local damage does not prevent the slow accumulation of global
damage, which is the cumulative result of millions of
technological decisions. "The local focus of the risk-based
system is intrinsically at odds with the problem of global
accumulation."(pg. 342) The problem of global accumulation is
what we're dealing with in the case of chlorinated chemicals
(like DDT), lead, mercury, and plutonium.

Finally, Thornton points out that, "Once global injury occurs,
the current system's methods for dealing with damage also break
down. The scope of this kind of damage -- large scale impairment
of the health of human and wildlife populations, contamination of
the entire food web -- is so vast that it can never be cleaned up
or repaired. The inability to trace causality to individual
actors means that victims cannot be compensated or individual
perpetrators held legally responsible. Most important, this
system, which requires a demonstration of a causal link before
action can be taken to eliminate the cause of a problem, cannot
even stop the damage it is doing when it finally becomes obvious;
the limits of epidemiology and the lack of local, determinate
causality mean that this requirement will never be satisfied.
Current institutions become paralyzed by their own unrealistic
standards of proof."(pgs. 342-343)

[More next time.]

--Peter Montague (National Writers Union, UAW Local 1981/AFL-CIO)

=====

[1] Joe Thornton, PANDORA'S POISON; CHLORINE, HEALTH, AND A NEW
ENVIRONMENTAL STRATEGY (Cambridge, Mass.: MIT Press, 2000). ISBN:
0262201240.

[2] Mary O'Brien, MAKING BETTER ENVIRONMENTAL DECISIONS; AN
ALTERNATIVE TO RISK ASSESSMENT (Cambridge, Mass.: MIT Press,
2000). ISBN: 0262650533.