Scared to Death: How Chemophobia Threatens Public Health

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How Chem ophobiaThrea tens Publ ic Heal th

toScared

Death

Written by Jon Entine

Presented by the


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toScared

DeathHow Chemopho bia

Threatens Publ ic Heal th

A Position Statement of The American Council on Science and Health

By Jon Entine


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SCARED O DEA H: HOW CHEMOPHOBIA HREA ENSPUBLIC HEAL H. Copyrigh 2011 by Jon En ine. All righ s reserved.No par o his book may be used or reproduced in any mater wha soever wi hou writen permission excep in he case o brie quo a ions embodiein cri ical ar icles and reviews. For more in orma ion, con ac :

American Council on Science and Heal h1995 Broadway, Second FloorNew York, New York 10023-5860Tel. (212) 362-7044 Fax (212) 362-4919URL: htp://www.acsh.org Email: [email protected]

Publisher Name: American Council on Science and Heal hi le: Scared o Dea h: How Chemophobia Trea ens Public Heal h

Price: $15.95 Au hor: Jon En ineSubjec (general): Science and Heal hPublica ion Year: 2011Binding ype (i.e. per ec (so ) or hardcover): Per ec

ISBN 978-0-578-07561-7


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Tomas S. Allems , M.D., M.P.H.San Francisco, Cali .

Joshua Bloom, Ph.D.

American Council on Science andHeal h

Dean O. Cliver , Ph.D.Universi y o Cali ornia, Davis

Wolfgang Dekan , Ph.D.Universi y o WrzburgGermany

Julie Goodman, PhD., DABGradien Corp.

Rudolph J. Jaeger , Ph.D., DABNew York Universi y Medical

School

John W. Morgan , Dr.PH.Cali ornia Cancer egis ry

Gilber Ross, M.D.

American Council on Science andHeal h

David Schotenfeld , M.D., M.Sc.Universi y o Michigan

Tomas P. S ossel , M.D.Harvard Medical School

Elizabe h Whelan, Ph.D. American Council on Science andHeal h

Calvin C. Willhi e , Ph.D.Cali ornia Depar men o oxic

Subs ances Con rol

Acknowledgements

ACSH gra e ully acknowledges he commen s and con ribu ionso he ollowing individuals who reviewed his repor :


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Table of Contents

Executive Summary 1

Introduction

The Rise of the Environmental Movement 10

Evolution of the FDA

Silent Spring

Birth of the EPA

Environmental Risk 19

Carcinogenic Risk

Non-Carcinogenic RiskEndocrine Disruptors

Green ChemicalsNatural v Synthetic 28

Politics of the Precautionary Principle 33

Environmental NGOs and the Media 37

Reforming the Toxic Substances Control Act 39Presidents Cancer Panel Annual Report for 2008-2009 42

Case Study: Bisphenol APrecautionary Regulation 44

Campaigns Against BPA

Low Dose Theory

Ideological Regulation FDA and EPA Weigh In


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Case Study: AtrazineWeighing Risks and Benefits 58

Studies and Regulation

Harm Versus Risk

The Endocrine Disruptor Hypothesis Controversy 66

A Precautionary Future?

Implications for Public Health 73

Benefits of a Chemical Exceed Risks 73

Risks of Replacement or Amelioration Exceed Benefits 75

Psychology of Risk Perception 7

Trust in Scientists and Science 7

Appendix: Common Myths and Facts About Chemicals 83

Bibliography


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C H E M O P H O B I A :

the irrational fear of chemicals


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viii Scared to Death: How Chemophobia Threatens Pu blic Health


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1

Executive Summary

W hen Pamela Davis was pregnan wi h herdaugh er Meaghan, she s ar ed o worrabou con amina ion rom lead pain in hHoboken, New Jersey home. She read s ories abou chemicals in baby dollpo s, shower cur ains and carpe s. An ar icle on he In erne warned hapy cups were dangerous. A riend old her ha he brigh pink baby pajashe had goten as a gi were rea ed wi h oxic ame-re ardan s. Soon her

ire nursery seemed o pose mys erious hrea s o her unborn baby. Pamel rapped.

I news s ories and he In erne are o be believed, he dangers chemicals are increasing, cancer s alks us a every urn and our children a vulnerable. Syn he ic chemicals are essen ial or modern li e, bu our vie

hem are con ic ed. We rely on chemicals o improve human heal h. Pharmceu icals keep us heal hy. Plas ics are ound in every hing rom oys o medical supplies. Pes icides and herbicides boos ood produc ion and qui y. I s impossible o conceive o li e in he 21s cen ury wi hou he


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2 Scared to Death: How Chemophobia Threatens Pu blic Health

als and uels ha syn he ic chemicals have made possible. Bu rom soap sunscreens, drugs o DD , we are aced wi h an endless s ream o con using

messages abou he sa e y o chemicals we come in con ac wi h every dTe syn he ic ingredien s ha make up many produc s sugges he unknownand like many o us, Pamela Davis processes ha as ear. Once youre aware oone hing i jus spreads and you s ar ques ioning every hing, she said. Ycan drive yoursel absolu ely crazy rying o keep your baby heal hy.

Considering he con ic ing narra ives, he public has di cul y dis in-guishing be ween use ul and benign subs ances in produc s and hose ha

could pose dangers when misused. Highly publicized repor s o environmen-al, chemical and pharmaceu ical ca as rophes rom he Exxon Valdez and

BP oil spills o Bhopal o halidomideare mixed in erchangeably wi h exaggera ions and scare s ories abou chemicals ound in common plas ics or inour homes. Belie in he rela ive bene s o chemicals, rus in he indus

ha produce hem and con dence in governmen regula ors have never beenlower. Corpora ions ha produce chemicals are o en por rayed as greedy andindi eren . Ques ions persis abou he governmen s abili y o exercise oversigh responsibili ies.

Te perceived risk posed by common chemicals has grown even as re-search has raised doub s abou he assumed links o many chemicals o can-cer. Li es yle ac ors like a lack o exercise, smoking, alcohol consump ion anea ing habi s ha lead o obesi y con ribu e ar more o he overwhelmmajori y o cancers, while he misuse o chemicals is believed o rigger only

ew percen o he cases a mos . Ye , he chemophobia epidemic keeps gaiing momen um.

How does he public adjudge hazard, sa e y and risk? How sa e is sa e?Media percep ions and governmen regula ions are o en shaped by a ervor

ed by misconcep ions abou he widespread dangers o common chemicals. An illusion has developed ha chemicals can be divided in o ca egories o

sa e versus unsa e. Bu any subs ance, even ood and vi amins, can bharm ul i we consume oo much o i . Sa e y is rela ive, depending on requency, dura ion and magni ude o exposure. Tis obsession wi h chemi-

cals is unheal hy. Serious heal h challenges need o be orce ully con ron ed


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3Executive Summar y

bu he resources devo ed o challenging and removing rela ively innocuchemicals and developing subs i u essubs ances ha have o en no b

scru inized as much as he chemicals hey would replace and hus con eillusion o sa e ydiver us rom addressing known heal h risks. Tis chephobia can resul in he opposi e o wha was in ended: a decrease ra heran increase in public heal h.


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4

Introduction

T he public misunders anding o chemicals andrisk has arisen due o varie y o ac ors: advancein analy ical chemis ry allowing he de ec ion oever smaller amoun s o subs ances; evolu ion o he In erne and social mdia; emergence o environmen al advocacy organiza ions s a ed wi h com-mited ac ivis s bu o en ew scien is s; uncri ical or ou righ biased reporabou claims ha syn he ic chemicals are inheren ly risky; indus ry capi u

ion o campaigns agains heir produc s; governmen inclina ion o respono exaggera ed claims in poli ically sa e bu scien i cally unsound ways; anhe erosion o public rus in au hori y, including o governmen , indus ry ahe scien i c communi y.

Chemical manu ac uring is es ima ed o be a $3 rillion global en erprise

Te U.S. Environmen al Pro ec ion Agency (EPA) es ima es ha here are84,000 syn he ic subs ances in use in he world oday. Chemicals are used make a wide varie y o consumer goods, as well as produc s or he medicalagricul ural, manu ac uring, cons ruc ion and service indus ries. Te boom


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5Introduction

s ar ed in he early 20 h cen ury and accelera ed in he 1920s and 30sadvances in echnology leading o he crea ion o new orms o plas i

cluding nylon and syn he ic rubber, made rom pe rochemicals. Te use onewly developed chemicals played an impor an role in he Allied vic ory World War II.

In he pos war years, a coun ry on he cusp o sus ained prosperi y braced scien is s and indus ry as archi ec s o innova ion. Te 1950s broua uence o more Americans, leading o an increased demand or consumegoods, rom energy and de ergen s o plas ic, rubber and bers. A soph

ca ed pharmaceu ical indus ry arose. Agribusiness grew rapidly in respono bo h public concern abou eeding he world he Green evolu ion

made possible by he adven o pes icides and syn he ic er ilizersandesire or rui s and vege ables year-round. I was an era o growing adance and chemicals were viewed as essen ial componen s o his consum

ion revolu ion.Bu he complexi y o modern li e gradually in ervened. Drama ic gr

laid bare he inadequacy o cer ain public pro ec ions. Corpora ions, engines o progress, were also he main source o indus rial pollu an s

ouled our air, wa er and soil. Legi ima e concerns emerged over he uschemicals on arm produc s and in he making o consumer goods and druHighly sophis ica ed de ec ion echniques ha measure minu e levels ochemicals in blood and urine helped an anxie y. Fi y years ago, science couisola e a race chemical rom a cap ul dumped in o a swimming pool; nowhave ins rumen s ha can iden i y ha same chemical in he par s perin Lake Erie.

In response o he growing impac o chemicals, numerous ederal agcies, mos no ably he EPA, which regula es chemicals in he environmand he Food and Drug Adminis ra ion (FDA), which regula es oods adrugs, were ounded or expanded. Te Cen ers or Disease Con rol (CDC)

and he Occupa ional Heal h and Sa e y Adminis ra ion (OSHA) also eva e po en ially hazardous chemicals, par icularly hose ha cause, or mcause, cancer. Tese agencies have evolved in a clima e o increasing publimis rus o address he growing complexi y o modern produc ion and


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sumerism. Mos indus rial coun ries have comparable oversigh bodies. o-day, here are 170 syn he ic chemicals or exposure circums ances ha have

been classi ed by one such agency, he In erna ional Agency or esearch onCancer (IA C), as known or probable human carcinogens.Numerous chemicalsna ural and syn he ichave been inden i ed in

he environmen as dangerous a eleva ed levels o exposure and or whichgenuine cau ion is warran ed. For example, lead exposure can lead o neu-rological problems, including seizures, coma or dea h, which is why i s useis igh ly regula ed. Many workers exposed o asbes os, ano her na ural su

s ance, developed lung disease and cancer because i s oxic e ec s were noknown, regula ions were lax, ven ila ion sys ems were inadequa e, and hedid no wear pro ec ive clo hing. Workers who handle almos any chemical inhigh enough concen ra ions need special pro ec ions. Bu even a highly oxichemical should no necessarily be banned ou righ ; ha decision should be based on where and how a chemical is used and a wha concen ra ions. I spo en ial risks mus be balanced agains i s demons ra ed bene s.

Te public con roversy, however, exis s over rela ively common chemi-cals ound a minu e levels supposedly lurking in our oods and in everyday consumer produc s. Lurid headlines, such as Alarming Body Burden esul s:

es s eveal 300 Chemical Compounds in Newborn Babies (Lance 2008)or 89 o 116 Chemicals De ec ed in Americans Blood and Urine (Brown2009), used alarmis language. Al hough advocacy groups play an impor anrole in ocusing public aten ion on po en ial environmen al hazards, someNGOs (non-governmen al organiza ions) consis en ly exaggera e he hreagoing so ar as o por ray our houses, schools, hospi als and workplaces as

oxic cauldrons. By heir measure, ques ionable subs ances can be ound inmea s and sh, on rui s and vege ables. Te botled wa er indus ry, crea ed because people eared con aminan s endanger our ap wa er, now nds i selunder scru iny or selling wa er in plas ic con ainers made wi h chemicals h

modi y our hormones. Cookware and plas ic wrap, sippy cups and he cansused o package long-shel li e oods are por rayed as serious hazards. Dangelooms in cosme ics, oo hpas e and cleansers. Carpe s, drapes and cabine ryare sources o alarm. Te lis goes on and on.


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7Introduction

While scien is s may sco a his carica ure o risk and he implicha chemicals are inheren ly dangerous, such s ories are he calling car

many advocacy campaigns and are given credence in he media. Even as yoread his, people are snapping up he la es scare rea ise, No More Dir y Looks , which, according oimemagazine, unmasks he oxic ingredien s in main-s ream chemicals. (Walsh 2010)

Even as he hard evidence sugges Americans have never been sa er whi comes o exposure o chemicals and drugs, many people mis akenly beli we ace more environmen al hazards now han a any poin in his ory. T

unders andable. Over he years, he public has been rauma ized by oil sphe housands o dea hs and injuries associa ed wi h he me hylmercuryamina ion o Minama a Bay in Japan by he Chisso Corpora ion rom o 1968; he explosion a a Union Carbide pes icide plan in Bhopal in 19

and occupa ional exposures o vinyl chloride, benzene and aniline dyes. Teproblems caused by he drug halidomide, which was wi hdrawn in 1961, ldeep scars. Numerous drugs have been wi hdrawn in recen years because oheal h concerns such as cardiovascular oxici y (e.g. Vioxx/ o ecoxib; enramine, wi h en ermine called Fen-phen), liver damage (e.g. rovan/ rova

oxacin) or o her ill e ec s, some no su cien ly iden i ed during rials.Less clear-cu are con roversies over exposure o environmen al chem

cals such as Agen Orange (a Vie nam-era de olian ha con ained a dcompound), PCBs (polychlorina ed biphenyls, ound in indus rial uids) o

he pes icide DD (dichlorodiphenyl richloroe hane), in which scien ishave modi ed or even reversed heir assessmen s o oxici y. Equally plema ic are repor s abou he purpor ed dangers o chemicals ha we en

er regularly in common produc s, such as BPA (bisphenol A) and ph halaused in plas ics; he indus rial sur ac an PFOA (per uorooc anoic acidknown as C8), PBDE ( re re ardan compounds polybromina ed diphenye hers) and a razine, an herbicide.

Un or una ely, scien i c li eracy in he Uni ed S a es is abysmal. O200 h anniversary o Charles Darwins bir hday, a Gallup poll ound ha4 in 10 Americans believed in he science o evolu ion (Gallup 2009). Man journalis s do no have he raining or sophis ica ion o pu complex sc


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issues in con ex . Media s ories and Web pos s o en demonize commonly used chemicals ha scien is s and regula ors have ound o be per ec ly har

less. Unwarran ed ears are in ensi ed by he my h ha non oxic and grechemicals exis ha can replace he allegedly risky ones. Tese narra ives are bols ered by he mis aken belie ha he presence o a syn he ic chemicaany concen ra ion is dangerous. Te race o a chemical in he air, wa er oreven in our urine or blood is in i sel no necessarily some hing o be con-cerned abou . Te enaissance physician Paracelsus crys allized he cen ral

ene o oxicology, loosely ransla ed as, Te dose makes he poison.1 Our

bodies and he environmen are made up o housands o chemicals, na uraland syn he ic, ha heore ically could harm or kill us. Every chemical can bdangerous i he level o exposure is high enough. We need o weigh he ben-e s ha a chemical migh bring agains i s po en ial oxici yand a dose or level o exposure.

Tere are oxic hrea s in our environmen and i s impor an o iden ihem and ake appropria e ac ion, bu he pic ure pain ed in some quar ear overs a es he ac ual dangers. egula ion o chemicals is s ric er and m

e ec ive han i s ever been. Tere have been signi can advances in echnol-ogy and ways o handling chemicals by indus ry. Only a rickle o new drugsmakes i o marke each year. In he case o pes icides, or example, he crchemical indus ry es ima es ha only one in 139,000 new compounds sur- vive he gaun le rom he chemis s labora ory o he armers elds. po en ial produc ha makes i in o produc ion undergoes some 120 separa e es s aking 8 o 10 years a a cos o as much as $184 million (CropL America 2010).

Te poli ics o con es ed science can be a messy business or everyone.Te mo iva ions o indus ry and sel -proclaimed environmen al whi e knighare no always ransparen . In en ions are di cul o decons ruc when idology, nancial incen ives, academic repu a ions and public aten ion are in

play. While scien is s who accep priva e unding, even or a s udy o a su1 Te German axiom, Alle Ding sind Gi , und nich s ohn Gi ; allein die Dosis mach ,da ein Ding kein Gi is , ransla es more direc ly as, All hings are poison and no hing i wi hou poison, only he dose permi s some hing no o be poisonous.


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9Introduction

s ance ha s no a issue, risk being labeled by advocacy groups and acadscien is s as corrup , NGOs and universi y scien is s who endorse exa

a ed assessmen s o chemical risk are some imes posi ioning hemselvegovernmen gran s or publici y.Chemophobia is rising even while he ac ual danger o chemical con am

na ion or harm rom everyday exposures, par icularly in he workplace, decreased sharply over he years. Te very word chemical has become a ho buton. A recen na ional poll by he Universi y o Michigan ound hapublic ra es chemicals in he environmen almos as big a concern as

pregnancy, alcohol abuse and child neglec , and ar more dangerous han dpression or school violence (Universi y o Michigan Child Heal h Evalua iand esearch Uni 2010). Ye , researchers have ound ha more han 70 pcen o cancer cases can be linked o smoking and poor ea ing habi s ha

o obesi y, while exposure o chemicals causes only a ew percen o hea mos (Doll and Pe o 1981). Percep ions abou chemicals have become dis or ed ha many people are willing o orgo he unques ioned bene

heir use, such as in vaccines, because hey believe ha hey could poison children. Te resul is a socie y ha is increasingly wary o chemicals and ence in general, and suppor ive o he removal rom he marke o many uand in some cases irreplaceable chemicalseven when here is no evidence

ha hey pose serious risks and he subs ances ha replace hem are oes ed. Moreover, ou o poli ical expediency, he governmen is o en o respond o public scares by spending millions o dollars on ameliora i

research and mi iga ionmoney ha o en goes o organiza ions ha hnancial incen ive o main ain here are problems. I i s la er perceivehis money was ill used, he credibili y o bo h scien is s and he gover

are compromisedand he public in eres was no served.


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10

The Rise of theEnvironmental

Movement

In he early years a er WWII, he bene i s oindus rial chemicals and he posi ive role o indus ryin general, especially in improving he quali y o li eovershadowed environmen al concerns. Te agricul ural revolu ion was

rans orming he world, bringing unan icipa ed levels o sel -su ciency anprosperi y. Syn he ic pes icides were hailed as modern miracles in he batleagains pes s, weeds and hunger.

However, public ati udes oward wha were hen called conserva ion issues began o change. Pollu ion emerged as a serious problem. A noxious mix o sul udioxide, carbon monoxide and me al and coal dus descended on he Pennsylva-nia own o Donora in 1948 and London in 1952, killed more han en housandand sickened more han 100,000. Los Angeles was regularly in he grip o a smog-gy shroud. Fear o cancer rom pollu ion, radia ion, agricul ural chemicals, mys

erious microbes in our ood, wa er, wha everescala ed. I was he beginning a long, gradual decline in he con dence o Americans in indus ry and he abili yo governmen o pro ec hem (American Na ional Elec ion S udies 2009).


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11The Rise of the Environmental Movement

Evolution of the FDA

Growing concerns in he 1950s spurred legisla ive ac ion o amend quar er-cen ury-old Federal Food, Drug and Cosme ic Ac (FDCA) ro which he FDA had emerged. Congress had passed he FDCA in 1938 a e

he poisoning dea hs o more han 100 pa ien s who inges ed sul anilamedica ion in which die hylene glycol was mis akenly used o dissolve drug and make a liquid orm. Sa e olerances had been es ablished or avoidable poisonous subs ances bu he rules were vague because o he

dimen ary science o he imes. I became clear ha he old laws did noqua ely address he consequences o he surge in he use o complex chemon arms and in oods and heir possible implica ions or human heal h.

In 1954, Congress passed he Miller Pes icide Amendmen , which se solerances or pes icide residue on raw rui s and vege ables. Te Food A

di ives Amendmen , passed our years la er, in 1958, required premarkeclearances or subs ances in ended o be added o ood. Prior o ha

la ion, he FDA had o prove an addi ive was po en ially harm ul becould ob ain a cour order banning i s use. Tis law shi ed he responsibii y o prove sa e y o he manu ac urer, even hough sa e y he abriskcanno be proven by science.2 Te amendmen included he Delaney clause ha e ec ively banned any ood addi ive ha was shown o caucer in any species:

No addi ive shall be deemed o be sa e i i is ound o induce cacer when inges ed by man or labora ory animals or i i is ound,a er es s which are appropria e or he evalua ion o he sa eo ood addi ives, o induce cancer in man or animals. (Merill1997)

Tis law broke new ground as i invoked science as he way o assess ris

bu i was problema ic or o her reasons. Te language o he clause impha he resul s o cancer s udies in nonhuman species, such as roden s, c

2 Te limi o de ec ion always de ermines he ex en o wha we mean by sa e y,canno prove he absence o some hing only i s presence.


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ea ing cranberries and respec ed scien is s spoke ou o reassure he pu(Li e 1959).

Te cranberry scare o 1959 was ollowed wo years la er by a legi imcrisis involving halidomide, a seda ive. esponding o one o he bigmedical ragedies o modern imes, he governmen ordered he drug wdrawn rom he marke in 1961 a er i was ound o cause bir h de ec s1998). Te inciden led o much s ric er es ing on pharmaceu icals and p

icides be ore hey could be licensed and ed concerns ha ederal agemigh no be up o he ask o overseeing po en ially dangerous drug

chemicals.

Silent Spring

Te ca alyzing even or he modern environmen al movemen was publica ion o achel CarsonsSilen Spring in 1962 (Carson 1962). Carsonhad worked or years a he U.S. Fish and Wildli e Service, even ually becing he chie edi or o ha agencys publica ions. She argued in her boouncon rolled and unexamined pes icide use was harming and even killing noonly animals and birds, bu also humans. She indic ed indus ry and he eral governmen . Te book kicked o a public dialogue abou he a ec s chemicals on wildli e and he environmen .

Carsons primary arge was dichlorodiphenyl richloroe hane (DD )

an insec icide hen in widespread use in areas o he world where mala was endemic, because o i s e ec iveness in con rolling disease-carrymosqui oes. es ing by he U.S. Public Heal h Service and he FDAs vision o Pharmacology had ound no serious human oxici y rom DDand he chemicals inven or was awarded he Nobel Prize in 1948. A

ime o he books publica ion, DD had become an essen ial heal h weon around he world, saving millions o lives each year. Carson alleged h

DD was harming eagle and alcon eggs by hinning shells, which coullead o ewer ha chlings. Te i le o her book was mean o evoke a spseason in which no bird songs could be heard because hey had all vanishedas a resul o pes icide abuse.


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In 1955 he American Cancer Socie y had predic ed, Cancer will s rikeone in every our Americans ra her han he presen es ima e o one in v

Seven years la er, achel Carson would cleverly call her chap er on DDand human cancer One in Four. Even people who did no care much abou wildli e cared a lo abou heir own heal h and he heal h o heir childrTe grea es cancer hrea , o course, is no rom environmen al chemicals bu rom cigaretes. One o Carsons primary sources was Wilhelm Hueper,chie o environmen al cancer research a he Na ional Cancer Ins i u(NCI) and one o he leading researchers in his area. Hueper was so con-

vinced ha race exposures o indus rial chemicals were he major causeo cancer in humans ha he ocused ar less aten ion on obacco usage, which is now recognized as a ar grea er hrea . Te dangers o obacco wereaddressed comprehensively in he 1964 repor by he U.S. Surgeon Gen-eral causally linking smoking o lung cancer (Public Heal h Service 1964).Te obacco indus ry responded de ensively wi h a power ul disin orma-

ion campaign, ur her undermining he publics rus in corpora ions. Tahelped give credence o one o he cen ral argumen s o he environmenmovemen : indus ry was puting pro s ahead o he heal h o people and

he plane .Silen Spring may have been hin on he science o chemicals and cancer

bu i was a power ul and emo ionalour de orceor hose who believed haenvironmen al issues were being overlooked. Te 1960s were marked by agrowing sense ha he governmen and Corpora e America were alignedand indi eren o environmen al challenges. A percep ion ook hold haman himsel as well as rees and wildli e were an endangered species. Tecognoscen i began using an arcane ermecologyin re erence o a sci-ence o he environmen , hen s ill in i s in ancy.

As he decade drew o a close he Nixon Adminis ra ion, already on hede ensive because o Vie nam and a budding recession, ound i sel deal

ing wi h a number o high pro le environmen al challenges. When people wi nessed on elevision he de olia ion chemicals used in he jungles o Idochina, hey became even more recep ive o he environmen al concernsadvanced by Carson, consumer advoca e alph Nader and o hers. Legi i-


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ma e concern over air and wa er pollu ion began spreading in widening edies. Federal regula ors aced increasing pressure rom a skitish public

respond o concerns over he environmen and public heal h even in cas where he science did no jus i y in erven ion. Wha s now o en re erred o as he cyclama e scare is a case in p

Te popular ar i cial swee ener cyclama e, which had been designa ed aGRS (Generally ecognized as Sa e) since he 1950s, came under scru-

iny in 1969, when a s udy ound ha eigh ou o 240 ra s ed a mixsaccharin and cyclama es developed bladder umors. Te ra s had been e

high-dose levels comparable o humans inges ing 350 cans o die soda pday or mon hs. No o her labs could reproduce hese ndings, which are

hemselves o ques ionable signi cance. Bu modes concerns erup ed a na ional scare when an FDA scien is wen on ne work elevision disping pic ures o chick embryos ha su ered rom severe bir h de ec s being injec ed wi h cyclama es (Henahan 1977).

Wi h he Delaney clause in e ec , governmen regula ors believed had litle wiggle room. We recommend he cyclama e ban because o hlaw, no because here is any reason o believe ha i causes cancer in msaid one o he reviewers (Science News 1969). Spurred by a public ou corches ra ed by consumer ac ivis s, including Naders Public In eres search Group, he FDA banned cyclama es (Price 1970). Te success o han i-cyclama e campaign led o he publica ion o he Nader-inspired bTe Chemical Feas ( urner 1970), which raked he FDA or no regula ingdangerous ood addi ives.

Te alarmism served o rein orce he unscien i c s andard ha higdose s udies on animals are au oma ically applicable o humans. I alsogi imized he use o scien is s o endorse poli icized policy judgmendis urbing bu persis en patern ha undermines he con dence o public in supposedly independen scien i c exper s. Cyclama es rema

banned rom ood produc s in he Uni ed S a es, al hough he FDAsince publicly s a ed ha a review o all available evidence does no imphe swee ener as a carcinogen in mice or ra s.


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Birth of the EPA

Among he burning issues o he day were he alleged hrea s o DD anhe emerging concern ha popula ion grow h posed a ca as rophic hrea he u ure o he plane . One o he rs o he new wave o environm

advocacy groups, he Environmen al De ense Fund (now known as EDF orEnvironmen al De ense), was ounded in 1968 o speci cally arge DD , andi helped launch legal ac ions agains he use o he pes icide.

Te bes selling 1968 book Te Popula ion Bomb , by en omologis Paul

Ehrlich, blamed uncon rollable grow h in wha was hen called Te Tird World as he seed o all environmen al problems. He also railed agains DD .Te issue o res ric ing popula ion grow h played in o he deba e over DDin a disconcer ing way. Te public was con ron ed wi h Ehrlichs (erroneous)convic ion ha hundreds o millions o people would s arve o dea h in coming decades because o overpopula ion. Te issue o wi hdrawing an i-malar-ial programs as a means o popula ion con rol was broadly discussed and de-

ba ed. In his book, Ehrlich himsel appeared o blame DD or saving livesexacerba ing he overpopula ion problem:

Te in roduc ion o DD in 1946 brough rapid con rolover he mosqui oes which carry malaria. As a resul , hedea h ra e on he island [o Ceylon] was halved in less han adecade. Dea h con rol [DD use] did no reach Colombia

un il a er World War II. Each child adds o he impossible burden o a amily and o he despair o a mo her. (Ehrlich1968)

However unin ended, he exaggera ed ears abou popula ion grow hand environmen al degrada ion led many conserva ionis s o propose he un-

hinkable. Tey ac ively began deba ing Ehrlich over wha he called a dea hra e solu ion o hese combined problems. A deba e erup ed over banningDD as a way o cull he world popula ion hrough denying li e-saving spraying o agricul ural chemicals ( ober s 2010).

In response o growing public concern abou a varie y o environmen al


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challenges, he Whi e House se up a Ci izens Advisory Commitee on E vironmen al Quali y in 1969. Ta was ollowed by he signing on January

1970 o he Na ional Environmen al Policy Ac , which led o he ormo he EPA. Te agency assumed regula ory con rol o pes icides rom U.S.D.A. No surprisingly, deciding he a e o DD was he rs asknewly crea ed EPA.

Scien is s urged cau ion. Te Na ional Academy o Sciences reviewed evidence in 1970, declaring, In litle more han wo decades, DD has pre ven ed 500 million human dea hs due o malaria, ha would o herwise

been inevi able. Te EPA hearing examiner, Judge Edmund Sweeney, wholis ened o eigh mon hs o scien i c es imony abou he risks o DD

o a similar conclusion abou i s bene s, ound litle scien i c evidence opo en ial harm and recommended agains a ban. DD is no a carcinogenhazard o man, he wro e:

DD is no a mu agenic or era ogenic hazard o man. Te

uses o DD under he regis ra ion involved here do no havea dele erious e ec on reshwa er sh, es uarine organisms, wild birds or o her wildli e. Te adverse e ec on bene cialanimals rom he use o DD under he regis ra ions involvedhere is no unreasonable on balance wi h i s bene . Te useo DD in he Uni ed S a es has declined rapidly since 1959.Te Pe i ioners have me ully heir burden o proo . Tere is

a presen need or he con inued use o DD or he essen ialuses de ned in his case. [N]ecessary replacemen s wouldin many cases have more dele erious e ec s han he harmallegedly caused by DD . (EPA 1972b)

wo mon hs a er he Judges hearings, EPA Adminis ra or William uelshaus, acing remendous pressure rom he media and NGOs, se aside

Judges ndings and announced a broad ban on DD . He ci ed he resul s high-dose s udies in roden s and invoked he principles ou lined in he Daney clause, which un il ha ime had only been used in assessing he cnogenici y o ood addi ives. Te likelihood ha a ban would cos lives, w


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could have been assessed by cos -bene or risk-risk analysis, was no consid-ered. When i came o chemicals, percep ions and no scien i c evidence was

now driving he regula ory sys em. oday, 40 years a er DD was phased ou ,here is s ill no persuasive evidence ha i is a human carcinogen or can beheld responsible or widespread harm o wildli e.


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19

Environmental Risk

T he irs Ear h Day was held in 1970 shor be ore he ounding o he EPA. Wi h polluand he environmen ron and cen er in publics mind, Congress responded by passing laws and launching new reg-ula ory agencies. Key was he passage o he oxic Subs ance Con rol( SCA) o 1976. SCA se up guidelines giving he governmen au hor

o de ermine i indus rial chemicals presen an unreasonable risk o injuheal h or he environmen , and o ake ac ion wi h respec o chemicas ances and mix ures which are imminen hazards (EPA 2010). I speci c

arge ed polychlorina ed biphenyls (PCBs). Over he years, he core s ahas never been reau horized or amended, bu new oversigh responsibili ihave been added o regula e our addi ional chemicals: chloro uorocarbon

dioxin, asbes os and hexavalen chromium. SCA included a cos -beneclause requiring ha he governmen s au hori y should be exercised in a manner as no o impede unduly or crea e unnecessary economic barriers

echnological innova ion.


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In he la e 1970s and early 1980s, wo drama ic inciden sa Love Ca-nal, New York, and a imes Beach, Missouri ocused he aten ion o he

U.S. public on indus rial chemicals in he environmen . In 1978 he areaaround Love Canal, a neighborhood near Niagara Falls, was ound o be con-amina ed by a varie y o chemicals21,000 ons o oxic was e buried by

Hooker Chemical Company. Te public was soon inunda ed wi h s ories hachildren born in he communi y had high ra es o bir h de ec s and cance(Hea h, e al. 1984). A subsequen s a e-o - he-ar s udy by he CDC and o her na ional labora ories rejec ed he publicly accep ed claim ha he

ins caused serious gene ic abnormali ies or any marked rise in disease. Tis[s udy] sugges s ha no speci c rela ionship exis ed be ween exposure chemical agen s in he Love Canal area and increased requency o chromo-some damage, he s udy asser ed (Bo ey 1983).

In 1982, he news was lled wi h repor s ha concen ra ed levels o doxin had been discovered hroughou he own o imes Beach. La er, PCBs were also ound in he soil. Panic spread hrough he own, wi h every illnesmiscarriage and dea h o an animal atribu ed o he chemicals. Te EPA or-dered an evacua ion in 1983 and even ually declared i uninhabi able (Sun1983). As concerns moun ed, Presiden onald eagan ormed a dioxin ask

orce. A he ime, dioxin, which was being blamed or a varie y o illnesin Vie nam ve erans, was labeled as he mos oxic chemical syn hesized bman, based on high-dose s udies in guinea pigs.

Subsequen research on he e ec s o dioxin on humans and o her mam-mals led o a revised belie ha i s oxic e ec s are limi ed. No illnesses

imes Beach were ever linked o he presence o chemicals. Many exper sques ion whe her he razing o he own was necessary, ci ing he exampo Seveso, I aly, he si e o a disas er in 1976 ha exposed residen s ohigher levels o dioxin han hose ound in imes Beach and whose subse-quen cleanup allowed he ci y o con inue o exis . Te Love Canal inciden

led direc ly o he 1980 passage o he Comprehensive Environmen al e-sponse, Compensa ion, and Liabili y Ac (CE CLA), commonly known asSuper und (U.S. Congress 1980). Super und no only sensi ized people o

he widespread na ure o chemical con amina ion o soil and groundwa e


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21Environmental Risk

bu also led hem o recognize ha hazardous was es were no only prod by indus rial acili ies bu also by individuals in heir homes, as a numb

Super und si es were local land lls. Batles over wha o do wi h land lls las ed years and in some cases decades. Te designa ion o Super und siunderscored a belie in he inep ness o governmen and in amed he per

ion ha he public was no being adequa ely pro ec ed.esponding o growing concern abou chemical con amina ion, som

s a es and locali ies, convinced ha he ederal governmen was no proac ively enough, ook heir own legisla ive ac ions. In he mos s

example, in 1986 Cali ornians vo ed or Proposi ion 65, he Sa e Drink Wa er and oxic En orcemen Ac , which ushered in a sweeping regulaprocess or iden i ying and publicizing oxic chemicals (Cali ornia Oo Environmen al Heal h Hazard Assessmen 2010). Proposi ion 65 requi

he governor o publish a lis o po en ially dangerous chemicals. Tis which now includes hundreds o chemicals, many o which are no harma ypical exposure levels, mus be upda ed a leas once a year. I has almos ubiqui ous signs in gasoline ling s a ions, ire s ores, workplace

ail es ablishmen s (e.g. Macys, Home Depo ) and even a airpor boardramps warning ha everyday produc s or chemicals are known o he s aCali ornia o cause cancer, bir h de ec s or reproduc ive harm. Te ne eini ially was o s ir anxie y among Cali ornians and open up oppor uni iclass ac ion sui s, wi hou any measurable bene s o public heal h.

Carcinogenic Risk

Un il he 1960s, he s andards used by he governmen o de ermsa e y levels and manage risk were hopelessly imprecise and subjec ive. es ablish sa e levels or subs ances in he air, wa er or soil, regula ors n

o move rom he black/whi e quali a ive approach o ei her allowing o

ning a subs ance o a quan i a ive approach o de ermining how much osubs ance migh be allowable in each environmen al si ua ion. As he he

ocus on cancer and he ears associa ed wi h chemicals escala ed, noUniversi y o Cali ornia a Berkeley chemis Bruce Ames inven ed a q


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inexpensive es (now known as he Ames es ) o evalua e oxici y. His de ermines i any chemical o in eres migh cause mu a ions in he DNA

bac eriain vi ro(in a con rolled environmen , such as in a es ube or Pe ridish). I mu a ions were observed hen ha par icular chemical was considered likely o be a carcinogen in lab animals.

Te Ames es and he developmen o roden s modi ed o be cancer-prone led o an ul ra-cau ious oxicological evalua ion sys em and chemicaregula ory process. Over he years, wha many scien is s believe is a convolued mul i-s age model has been developed o ex rapola e animal risk o people

(1) Scien is s do a biological assay ( he Ames es ) on some pes icide,ood addi ive, preserva ive or o her chemical o nd ou i i is mu agenic

shows whe her he DNA o he bac eria is al ered in a signi can way.(2) I he chemical is con rmed as mu agenic, s udies are hen under-

aken o de ermine wha is called he maximum olera ed dose (M D) ohis chemical in ra s or mice. Te M D is he amoun o he chemical ha

almos kills a roden (or almos achieves ano her parame er, such as suppress-ing body weigh .) I is a dose ha , depending on he par icular chemical, ca be housands o millions o imes higher han a human could ever inges in li e ime.

(3) Nex , he roden s are ed jus 10 percen less han he maximum olea ed dose daily or heir en ire one- o wo-year li e ime.

(4) However, many chemicals canno be ed o roden s because he sub-s ances are so noxious a he dosages given. So scien is s o en use gavage ( orced eeding in o he animals gu every day, o en by injec ion), which ino how humans are exposed o he chemical, compromising he meaning ul-ness o he es .

(5) A er a year or wo, he roden s are sacri ced and scien is s coun uphe umors he animals accumula ed in various organs. Mos o he roden s he con rol group, ed a normal die , will have umors anyway because he

have been bred o be cancer prone. So, i he es group o roden s edomore likely injec ed wi hsome chemical a he highes dose has an averageo , say, our umors per animal in a par icular organ, and he con rol grouphas an average o only one umor per animal, hen he chemical being es ed


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is said o increase cancer incidence by 300 percen (s a is ical signi cancac ored in). Tis does no mean ha such a s udy proves a chemical will ca

adverse e ec s in ra s, le alone in humans exposed under more realis ic cdi ions. Ye , his nding, designed as a rs s ep in es ing a hypo hesisends up in a headline or in a media release rom one advocacy group or ano her atemp ing o use preliminary research o suppor a cause or moveme

(6) Nex , and o en under pressure rom he energized media and environmen al NGOs, a poli ical body, such as he European Parliamen or U.S. Congress, or a regula ory body, such as he EPA, will classi y and/or co

rm his chemical as a likely human carcinogen, as i roden s were no hmore han minia ure humans.

(7) Tese agencies hen es ablish an accep able level o he chemicalhe EPA calls i an upper es ima e o he riskusing wha s known

dose-response curve, which includes a large margin-o -sa e y ac or bon ma hema ical models. In moving o his new quan i a ive approach,ernmen scien is s began employing high-dose roden s udies and he sa basic assump ions implici in he Delaney clause: equa ing hese s udies ima es o wha migh happen o humans exposed o he same chema low doses. Bu here are no valida ed biological models ha quan irela ionship be ween he high-dose animal resul s and low exposure levelsperienced by humans.

Underscoring he rela ive arbi rariness o his process, he cu o levse di eren ly by di eren agencies rom coun ry o coun ry and even s

imes wi hin a coun ry. As in he case o he pes icide a razine, hese le vary by as much as 100 imes. (Te European sa e y cu o level is 1 par billion, while he World Heal h Organiza ion se s i a 100 ppb.)

Te resul is ha he scien i c conven ion o seting one number o rresen risk exaggera es he media and public percep ion o risk. Because one number resul s rom he assessmen process, i is no surprising ha

noring cau ionary guidance by regula ors, NGOs and he media selec coun ry or agency wi h he igh es cu o and hen por rays his numexac , as he bes es ima e o risk and as predic ive o cancer incidenc

ha miss a es wha a cu o number means. As he EPA no es, Te a


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risk [ rom exposure o a chemical] may be signi can ly lower and may indeedac ually be zero. I is impor an o recognize ha he use o his model res

in risk es ima es ha are pro ec ive, bu no predic ive o cancer inciden(EPA 1994)Employing his model, a range o chemicals, including amino riazole,

DD , cyclama es and Alar, a one ime or ano her, have been in he crosshairso environmen al groups because o supposed cancer-causing e ec s on hu-mans. oxicology s udies are impor an in public heal h because epidemiolo-gy is no very sensi ive, as you canno conduc experimen s on humans. Tey

serve as a basis or po ency es ima es and o er he oppor uni y o comparisks. However, he advan ages o hese s udies mus be balanced wi h hpo en ial o exaggera e risk. High-dose e ec s do no necessarily occur a lodoses and e ec s ha occur in es species do no necessarily occur in humanexposed o he same agen s.

Non-Carcinogenic RiskIn recen decades, here have been numerous claims linking chemical

exposures o a wide varie y o illnesses besides cancer: as hma, au ism, aen ion de ci disorder, congeni al mal orma ions, sperm quali y and quani y decline, diabe es, hear disease, Parkinsons and demen ia, among o her

(Sa er Chemicals, Heal hy Families 2010). o evalua e risks rom chemicals

ha migh cause e ec s o her han cancer, he EPA has developed an evaluaion model based on he general approach es ablished by he Ames es . I asumes he direc applicabili y o high-dose labora ory animal es s o huma wi h subjec ive addi ional sa e y ac ors buil in. Te EPA hen de ermines wha level a chemical causes an adverse reac ion in he animal mos sensi iv

o ha chemical when i is ed he chemical over he course o se periodime. Te sa e human exposure limi is se 100 imes (or more; Cali ornias

Proposi ion 65 uses 1,000 imes) below he highes dose ha is no expec eo cause an adverse reac ion i con inuously exposed o a cer ain chemical

When he da a are incomple e, regula ors ac or in he addi ional uncer ay by mul iplying he sa e y ac or, usually by 10 or even more, bringing


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sa e y margin, or margin o exposure, o 1,000 or more (10,000 imes in case o Proposi ion 65 lis ed chemicals; European regula ors discuss a mar

o exposure o 10,000 as su cien or pro ec ion agains severe e ec scarcinogenici y). So, or example, he sa e level or adul s would be se imes lower han wha has shown o adversely impac he mos sensi iv

ra ory animal a ec ed by ha subs ance, while or children or pregnan wen he sa e dose level would be se 1,000 imes or even 10,000 imes lowaccoun or individual di erences in humans.

Te EPA calls his he e erence Dose ( D). Te erm was originally

known as he Accep able Daily In ake (ADI), bu i was cri icized as poially misleading as i wasn clear who was judging accep abili y. oday

meanings o D and ADI are synonymous. Te D is he amoun osubs ance ha a person a a speci c weigh can ake orally every day oli e ime wi hou any appreciable heal h risk (wi h he exaggera ed margerror buil in) (Barnes and Dourson 1988). Clearly, nei her he D nor h ADI iden i es he amoun o exposure ha is known o cause adverse eI s an ou er limi ha assumes a li e ime o high-level exposure and isla ed by dividing no-e ec doses rom animal s udies by 100, 1,000, 10,00more. Tese levels are pro ec ive in he ex reme. Bu as wi h cancer expolevels, advocacy groups and he media o en use hese sa e dose gures a

hey are precise levels ha when exceeded by even he inies amoun pra heal h danger.

Endocrine Disruptors

As oxicological research has become more re ned, here has been an increasing ocus on he e ec s o chemicals and drugs on human reproduc ipregnan women, in an s and children. Our hormonal sys ems are acusensi ive o change. Tis heigh ened concern races back o he halidom

ragedy in 1961, which was ollowed a decade la er by he die hyls ilbe(DES) debacle. From abou 1940 o 1970, he syn he ic nons eroidal esgen DES was given o pregnan women under he belie i could rea nancy complica ions and losses. Te FDA subsequen ly wi hdrew DES ro


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use in pregnan women when i was shown o cause mal ormed u eruses andrare vaginal umors in emales who had been exposed o his drug in u ero

(Herbs , Ul elder and Poskanzer 1971). Al hough hese were only wo drugs among many housands on he mar-ke , he seriousness o hese problems ed a belie ha he pharmaceuindus ry could no be rus ed, and he governmen was lax in i s screenino drugs and chemicals and was no adequa ely exercising i s regula ory au

hori y. Unrealis ic expec a ions ha drugs (and all chemicals) should be riskree have occasionally led o bene cial drugs being has ily removed rom he

marke place. When repor s circula e ha someone, somewhere, has had anadverse reac ion, here are re exive calls or a ban and class ac ion atorneys join he ray.

Ta s wha happened in he case o Bendec in, a popular drug prescribedo rea nausea and vomi ing during pregnancy. In 1983, an Aus ralian re-

searcher linked i o a varie y o disorders, including e al mal orma ion. Trelease o he ini ial s udy ouched o a media renzy and demands by NGO

ha he governmen wi hdraw he drug. Lawsui s moun ed. Troughou hcrisis he drug remained legal under he rade name Diclec in in Canada andEurope, which s ood by s udies ha had ound he drug sa e. Bu he belguered manu ac urer believed i had no choice bu o pull i o he U.S. make . Soon a er i discovered ha William McBride, he scien is who claim

o have ound era ogenic e ec s (which could al er he developmen o embryo or e us) rom using he drug, had alsi ed his research. Te FDA subsequen ly ound no links o bir h de ec s and no cause or alarm (Ku chee al. 2003) (Willhi e and Mirkes 2005). Because o he nega ive publici yhowever, he drug was no rein roduced in he Uni ed S a es.

During he 1990s, based on s udies o sh and roden s, some universi y researchers began ocusing on he po en ial impac o chemicals ha appearin labora ory es s o mimic or impede he e ec s o endogenous hormone

such as es rogen. Ta s no in i sel a cause or concern. Clover, some rui whea and o her our and soy produc s (including ungal produc s a raclevels in whea and o her grains ha are processed in o bread, cereal pizza andeven beer) can also po en ially al er he way he hormones in our endocrine


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sys em work. Te na ural chemicals ha caused his e ec were known obively and innocuously as endocrine media ors.

By he early 1990s, some environmen al ac ivis s and scien is s beganmo ing a novel hypo hesis: Low doses o cer ain chemicals migh have a msevere impac han high doses. Tey argued ha he reproduc ive sys emanimals, including humans, migh no be subjec o he classic dose respocurve; here could be a non-mono onic response ( ich er 2007). Looking dis inguish he similar hormonal e ec s caused by syn he ic chemicals, coined he erm endocrine disrup ors, and he label s uck. Te erm w

chosen as a branding slogan, no unlike campaigners on abor ion issues labeing hemselves prochoice or proli e. Who would wan o risk disrup

he developmen o a newborn? Te novel no ion was promo ed in he beselling book,Our S olen Fu ure: Are We Trea ening Our Fer ili y, In elliand Survival?(Colburn, Dumanoski and Meyers 1996). Te media and somescien is s now use endocrine disrup ion in erchangeably wi h he objecdescrip ion reproduc ive hazard, even hough i carries s rong norma ivsocia ions.

While some scien is s believe here is persuasive evidence ha cercommon chemicals, such as he plas ic addi ive BPA, can adversely a ecman developmen , a er more han een years o research (Sharpe 2010o hers believe endocrine disrup ion remains a hypo hesis in search o daTe use o his novel paradigm has opened a new ron agains chemicals. Ss ances ha have no been proven o be carcinogenic in humans a commlevels o exposure he pes icides DD /DDE and dieldrin, dioxin, PCBPBDE, and PFOA, or exampleare now labeled po en ial endocrine disru

ors even hough he hypo hesis i sel remains in ques ion (Kamrin, Te LDose Hypo hesis: Validi y and Implica ions or Human isk 2007) (KamriBisphenol A: A Scien i c Evalua ion 2004).

Te media and cer ain NGOs now carelessly link various subs ances o

every hing rom human breas cancer o early puber y based on animal or race levels ound in he environmen or in human blood and urine. Nlonger is i necessary or cri ics o chemicals o nd evidence o ac ual his now su cien o iden i y me abolic changes in labora ory animals in sm


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should be prohibi ed or human consump ion, people cringe a he hough haproduce migh have some residues or ha chemicals can be ound in our blood

and urine. Ironically, one o he original proponen s o hose scary charac erizaions was Bruce Ames, when he was a young scien is in he 1960s. A er hdevelopmen o his es in he 1960s, Ames became a avori e o environmengroups, who recrui ed him o help in campaigns o ban pes icides and herbi-cides. In la er years, in par because o he discovery ha many na ural subs aes hough o be harmless were also mu agenic, he reversed his original posi ionand now campaigns agains chemophobia. oday Ames is known or his e or s

o educa e hose who re exively believe ha any hing na ural mus au omcally be sa er han any hing syn he ic.

As bioanalysis grew in sophis ica ion, Ames urned his sigh s oward hna ural world. He iden i ed 52 na ural pes icides, and evalua ed hem hsame way ar i cial pes icides are es ed, using high-dose roden s udies. O

he 52 na ural pes icides, 27 caused cancer. Te 52 pes icides Ames s udiedare only a rac ion o all na ural pes icides, and mos plan s con ain a varieo pes icides. As Ames wro e in a leter oSciencea er he Alar apple inciden ,[I] is probable ha almos every rui and vege able in he supermarkcon ains na ural plan pes icides ha are roden carcinogensand could bsubjec o a ban under he Delaney clause.3 He developed a rela ive index o

oxici y ha expresses he human po ency o a carcinogen as a percen agei s po ency o labora ory ra s and mice. Using his index, he hazard rom Ain a daily li e ime glass o apple juice came o 0.0017%. In comparison, hpossible hazard rom na ural hydrazines o consuming one mushroom a day was 0.1%, and ha rom a a oxin in a daily peanu buter sandwich was 0.03%(Ames and Gold 1989).

Te publics op concerns around ea ing are ypically ood poison-ing, BPA, BSE (bovine spongi orm encephalopa hy or mad cow disease),grow h hormones used in animals, animal eed, gene ically modi ed (GM)

oodand pes icides. Bu in odays ypical American die , 99.99 percen 3 Alar was used in apple produc ion as a grow h regula or. Te Na ural esources De enseCouncil, an environmen al group, helped s ir public concern in 1989 ha led o he wi hdrawo he chemical. See p. 44.


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inges ed chemicals (by weigh ) are na ural. Te average American ea s 1 1/grams o na ural pes icides a dayabou 10,000 imes more han he am

o ar i cial pes icides consumed. For example, roas ed co ee con ains vola ile chemicals. ( oas ing causes he orma ion o new chemical cpounds.) wen y-one o hose co ee chemicals have been es ed on rodenand 16 cause cancer. A cup o co ee includes 10 milligrams o carcinogen Among he oods highes in na ural pes icides are cabbage, broccoli, colgreens, Brussels sprou s, brown mus ard (ex remely high), black pepper (vehigh), nu meg, jasmine ea, rosemary and apples (wi hou Alar) (www.pn

org/con en /87/19/7777. ull.pd ).Some na ural crops con ain more pes icides han ones rea ed wi h

he ics. All po a oes na urally con ain solanine o pro ec hem againsSolanine is a a -soluble oxin ha in high concen ra ions can cause hana ions, paralysis, jaundice and dea h. Conven ional supermarke celery co

ains 800 par s per billion o he na ural chemical psoralen. Crea ed na u when he celery is s ressed, in high doses i s a poison ha can damage Dand issue as well as cause ex reme sensi ivi y o sunligh in humans. Orcelery, grown wi hou he aid o ar i cial pes icides, can con ain as mu6,200 ppb psoralensnearly eigh imes as much as celery harves ed conve

ionally (Moalem and Prince 2007). Farm workers who handle large quan iies o he organic celery develop skin rashes and burns. By any ra ional s

dard o risk assessmen , supermarke celery is sa er o harves and ea horganic al erna ive.

Does all his mean ha we should give up organic celery or conven ioal apples or abandon a vege arian die al oge her because we are exposedhigh doses o na ural pes icides? No a all. Te chemopreven ive e ec

he chemicals ound in oods ou weigh he carcinogenic impac o he npes icides. Bu i s also rue ha , as Ames has writen, he carcinogenicards rom curren levels o pes icide residue or wa er pollu ion are likely

minimal rela ive o he background levels o na ural subs ances. My es ima e or he number o cases o cancer or bir h de ec s caused bymade pes icide residues in ood or wa er pollu ionusually a levels hdreds o housands or millions o imes below ha given o ra s or mic


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close o zero (Ames and Gold 1989).Te cancer and chemical concerns igni ed by achel Carson and Paul Eh-

rlich and perpe ua ed by some NGOs were de ni ively addressed in a 1996repor rom he Na ional Academy o Sciences,Carcinogens and An icarcino- gens in he Human Die (Na ional Academies Press 1996). Te NAS conclud-ed ha levels o bo h syn he ic and na ural carcinogens are so low ha are unlikely o pose an appreciable cancer risk. An icipa ing he deba e over

he rela ive meri s o green chemicals, he NAS ound more danger in organics: Na ural componen s o he die may prove o be o grea er concern h

syn he ic componen s wi h respec o cancer risk, he scien is s wro e.I pes icides are banned a er being said o be dangerous using high-dose

roden exposure s udies, we are almos cer ainly rading a miniscule risk (cancer rom ar i cial pes icide residues) or a more cer ain one. As well- es ear i cial pes icides are phased ou , here will be grea er crop losses caused binsec s, heal hy rui and vege ables will become more expensive, and somepeople will no be able o a ord o ea hem as o en and will subs i u e carbhydra es. Overall heal h will su er and some people in ac will develop seri-ous complica ions rom obesi y, including diabe es. Tere is no such hing asa riskree world. Every choice is a rade-o o one risk or ano her. Assessinenvironmen al risk, par icularly in our ood supply, will remain a major chal-lenge going orward (Krewski, e al. 2009). oxici y es ing and risk ex rapola ion remain maters o ar as well as science.


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33

Politics of thePrecautionaryPrinciple

G rowing ou o he environmen al and Greemovemen s in Sweden and Germany in he1960s and 70s, he precau ionary principlehas become a key environmen al regula ory s andard in Europe and Canada. Al hough scien i c advisory panels o en resis applying he princii s in uence is growing year by year. I has ourished in in erna ional pos a emen s, conven ions dealing wi h high-s akes environmen al concer which he science is uncer ain, and na ional s ra egies or sus ainable dopmen . Ins ead o ac ing agains environmen al risks a er hey have assessed, i sugges s ha i is more appropria e o ake regula ory ac io

here is only he hin o danger. I s a hazard s andard, one ha is grareplacing he risk s andard s ill used (bu under assaul ) in he Uni ed S

and in mos o he res o he world when i comes o chemical regulaTe primary ounda ion o he precau ionary principle and he basis many globally accep ed de ni ions emerged ou o he work o he io Coence, or Ear h Summi , in 1992. Principle No. 15 o he io Declara ion no


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[A]pplica ion o he Precau ionary Principle is par o risk managemen , when scien i c uncer ain y precludes a ull as-

sessmen o he risk and when decision-makers consider hahe chosen level o environmen al pro ec ion or o human,animal and plan heal h may be in jeopardy (EU Commis-sion o he European Communi ies 2000).

By de ni ion, risk assessmen now includes a poli ical dimension basedon a chosen level o a perceived hrea . Al hough he precau ionary principl was no originally es ablished o complemen a scien i c approach o risk, has increasingly evolved o become a ool or he advancemen o he views more radical environmen and heal h advoca es.

Te U.S. sys em or regula ing chemicals relies primarily on peer-reviewedscience and risk assessmen using hazard and exposure da a and a weigh o evidence s andard. Bu precau ionary s andards are re ec ed in he FDCA o1938 and subsequen revisions, including he Delaney clause, as hey required

some measure o pre-marke proo o sa e y. On an absolu e basis, o courshis is scien i cally impossible because every hing, na ural and syn he ic, ca be shown o be oxic.

As a consequence o his developing worldwide precau ionary e hic, cau-ion is now hrotling he regula ory engine around he world. Lawmakers

o en respond o mere sugges ions o po en ial harm wi h reckless proposalsor bans or res ric ions wi hou any cos -bene analysis or assessmen o

unin ended risks ha such ac ions migh impose on our heal h and economy. When scien is s push back, he gridlock emboldens cri ics and heigh ens con-sumer anxie y bo h abou he exaggera ed dangers o wha are o en rela ivharmless subs ances and he governmen s apparen lack o abili y o regula

hese harm ul chemicals. Tis s ando has become even more pronouncedin recen years wi h he high-pro le campaigns agains ph hala es, BPA ana razine.

Even consumer labels and green guides, when misused, can underminecon dence in governmen oversigh and demonize chemicals ha have been

es ed and approved as sa e. Advocacy groups promo e hese guides as a way


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37Politics of the Precautionary Principle

o help he consumer hrough he hicke o dangerous chemicals, wheru h hey o en in ame an irra ional ear ha syn he ic subs ances ar

harm ul han na ural ones. A rose may be a rose. Bu ha rose-like ragrancin your per ume may be some hing else en irely, concoc ed rom any nu ber o he ragrance indus rys 3,100 s ock chemical ingredien s, he ble which is almos always kep hidden rom he consumer, asser s he Envmen al Working Group in an online dia ribe agains he cosme ic indus(Environmen al Working Group 2010). I wri es ha per umes o en con wha i calls secre chemicals no lis ed on labels ha can rigger se

lergic reac ions, cause cancer, impair neurological developmen or disruphormones, even a he minu e levels hese mys ery chemicals are suppose

ound in cosme ics. EWG provides no documen a ion or such exaggeraclaims.

EWG, EDF and o her NGOs propose labeling approved ingredien s based on how roden s are a ec ed when exposed a dosage levels a housaor more imes higher han wha migh be experienced by humans. So, orample, harmless per umes made by Calvin Klein, Jenni er Lopez, Vic oriSecre and o her brands would be labeled as carcinogens or endocrine disrup

ors or neuro oxins (Environmen al Working Group 2010). Such an addi ioo course, would be equivalen o adding a skull-and-crossbones o he ladooming a per ec ly sa e produc and hrowing a cloud over an en ire in

ry. Ye his EWG repor was approvingly dissemina ed hrough cybersand credulously ea ured by he mains ream media.

Environmental NGOs and the Media

Te rise o he environmen al movemen and he ragmen a ion omedia in he age o he Web have led o a growing in uence o advocacyganiza ions wi h he power o ampli y almos any argumen . Google ha

come he ul ima e megaphone. Even he mos discredi ed narra ive can oehold in cyberspace, winding i s way back in o mains ream discourse a

assuming a legi imacy ha would have long-since disappeared in a more crcal, linear age.


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Many advocacy NGOs have become mas ers a his kind o in orma ionmanipula ion. Teyve capi alized on he erosion o rus in au hori y, raisin

heir pro le o play an ou sized role in he na ional deba e over our environmen al u ure. Among he mos adep and well unded are EDF, he N DCGreenpeace, Na ional Wildli e Federa ion (NWF), Cen er or Science in hePublic In eres (CSPI), Union o Concerned Scien is s (UCS) and, more re-cen ly, EWG. Teyve also exploi ed advanced analy ical echniques ha measure very small levels o a chemical no only in he environmen , bu also inhuman issues and uids. NGOs now regularly provide heir own in erpre a-

ions o governmen s udies, publicizing wha hey claim are unders a emeno danger (Environmen al Working Group 2005) (Environmen al WorkingGroup 2010).

When chemical races are ound in our blood or urine, a wha ever level,he narra ive presen ed by in eres groups is o en one-sided. For example,

advanced echnological analyses o wa er samples have been used o show he presence o miniscule amoun s o drugs or agricul ural chemicals a lev

els ar below wha scien is s believe can cause an e ec on he mos sensianimalswi h an addi ional 100- old or 1,000- old level o sa e y buil Ta s why scien is s conclude ha hese chemicals as normally encoun eredin he environmen are no harm ul he exposure levels are jus oo low be meaning ul (Cen ers or Disease Con rol and Preven ion 2010). Un or u-na ely, ar icles ha demonize chemicals o en promp ci izens and poli ician

o ac has ily on he belie ha he presence o a chemical a any level linexorably o an adverse heal h e ec .

Te N DC campaign agains Alar in 1989 is he paradigma ic exampleo how a NGO helped rewri e he narra ive on a chemical once consideredrela ively innocuous. Te N DC worked wi h CBSs60 Minu eso promo ei s repor on he dangers o Alar ( he rade name or daminozide), a chemicasprayed on apples o regula e heir grow h and enhance heir color. Te Feb-

ruary 1989 broadcas , largely based on he N DC repor In olerable isk:Pes icides in Our Childrens Food old an audience o some 40 million peo-ple ha Alar was a dangerous carcinogen. Ten N DCs public rela ions rm,Fen on Communica ions, which has since become a gian in he P indus ry


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by working wi h environmen al campaigners, lobbied o her major news orgniza ions o ea ure he s ory.

David Fen on, he P companys ounder, s ruck gold when he go M yl S reep, hen one o Hollywoods hotes ac resses, o ron he s orhough she had no special knowledge o apples or Alar. Fen on eamed

wi h a long- ime riend, David Gelber, a producer a60 Minu es , which aireda hys erical ea ure. S reep subsequen ly es i ed be ore Congress and

V alk shows. No surprisingly, CBSs blockbus er repor sen he publica panic. School sys ems removed apples rom heir ca e erias, supermar

ook hem o heir shelves and orchard owners los millions o dollars ( o1990).

Backed in o a corner by he con roversy, he manu ac urer pulled Arom he marke a er he EPA wro e in a release, [L]ong- erm exposur

Alar poses unaccep able risks o public heal h, al hough he governmci ed no speci c s udy. Te high-dose research on which he EPA apparen l based i s has y commen s indica ed ha he only chance o human pois would come i a person a e housands o apples a day or years. Since hemous scare, vir ually every repu able scien i c body and leading scien iscluding he Na ional Cancer Ins i u e, he American Medical Associa ion World Heal h Organiza ion (WHO), and he U.S. surgeon general have gonon record as saying ha he use o Alar on apples never posed any serious r

Te manu ac urers decision o wi hdraw Alar valida ed wha is now s andard NGO campaign model: crea e scares (o en working hand-in-glove wi h ac ivis public rela ions agencies, such as Fen on, and complian jouis s, such as hose a60 Minu es) o pu indus ry on he de ensive and embar-rass governmen o cials in o making rash decisions based on public opiniora her han science. Ta cynical cycle has only exacerba ed public mis rus bo h indus ry and governmen .

Reforming the Toxic Substances Control Act

Considering he enor o he public discourse abou chemicals, i is ders andable why here is increasing public concern abou po en ial risk


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our ood, air, wa er, soil and consumer produc s. Te major anxie y wi hin in-dus ryand indeed o many scien is s around he worldis ha he weigh

o evidence delibera ions ha are he basis or mos U.S. regula ions will usurped by poli ics. Environmen al NGOs are arge ing he 1976 oxic Sub-s ances Con rol Ac (EPA 2010), which hey hope o evolve in o he coun

rys cen ral chemical oversigh legisla ion.Concern ha developing embryos, in an s and children are more sensi-

ive o chemicals han adul s led o he passage o he Food Quali y Pro ec Ac (FQPA) o 1996 (U.S. Congress 1996). Under he s a u e, he EPA wa

required o evalua e chemicals a a s ric er level han SCA, de ning sa eas a reasonable cer ain y ha no harm will resul rom aggrega e exposure

he pes icide chemical residue. Cos s and bene s could be a considera ionor non ood pes icide uses, bu or ood use only public heal h could be con

sidered. In 1998, he EPA aggressively revised i s approach o include an ad-di ional 10- old sa e y ac or or children (EPA 1998).

Te la es batle over SCA revolves around whe her he U.S. will con-inue o embrace a risk-based view o chemicals (bu modernized o re ec

scien i c da a on non-carcinogenic e ec s) or a precau ionary model ground-ed in ear o unknown or suspec ed hazards. Under he ac , manu ac urermus in orm he EPA o heir in en o manu ac ure a new chemical and pen evidence abou i s risks and po en ial bene s. egula ors mus weigh cos s o res ric ions agains he economic bene s o keeping he chemiin commerce. Te ac does no require assessmen o he sa e y o housando chemicals previously evalua ed and grand a hered in when he law wapassed; nor does i apply o subs ances regula ed under o her legal rame- works, such as he FDCA or he Federal Insec icide, Fungicide and oden-

icide Ac .O her han screening new chemicals and regula ing he ve designa ed

ones, he execu ion o SCAs manda e is vague, par ially because Congress

ailed o de ne wha cons i u es areasonablerisk o injury and how o evalua eha risk. One prominen cri ic, Andy Igrejas, environmen al-heal h campaigndirec or or he Pew Chari able rus s, main ains ha he U.S. has no rprogram o regula e indus rial chemicals, as a resul o SCAs deep aws


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(Case, Te eal S ory Behind Bisphenol A 2009). Tere is pressure rom envi-ronmen al advoca es o ex end o SCA provisions o he Delaney clause

now exis or syn he ic ood addi ives o o her chemicals, such as bisph(even hough BPA is no believed o be carcinogenic in humans). Accordino he Delaney clause, i a syn he ic ood addi ive causes cancer in es

a any dose i mus be prohibi ed. I more widely adop ed ha would amo a problema ic precau ionary es ; people are no ypically exposed

high doses given o labora ory roden s and i he animals ge cancer hano guaran ee ha humans exposed o lower doses will su er he same

EPA adminis ra or Lisa Jackson announced ha re orm o SCA whigh on her lis o priori ies when she assumed her posi ion in January 20Sena or Frank Lau enberg, Democra o New Jersey, has proposed overhauing he whole sys em o regula ing chemicals wi h he in roduc ion Kid-Sa e Chemical Ac , which would require manu ac urers o demons

heir sa e y in order o in roduce new chemicals or keep curren ones onmarke (U.S. Congress 2009). A House dra version o he bill would requi

he EPA o main ain a lis o 300 priori y chemicals o inves iga e baavailable scien i c evidence, considera ion o heir risk rela ive o o her cical subs ances and mix ures, presence in biological and environmen al mdia, use, produc ion volume, oxici y, persis ence, bioaccumula ion, or oproper ies indica ing risk.

I s unclear rom he dra bill wha cri eria would be used o designchemical as dangerous. Te recommenda ions are a hodge-podge, a mix opoli ics and precau ionary-based no ions. For example, in he proposed leisla ion, he non-carcinogenic BPA, ound sa e by all per inen U.S. ageand oreign scien i c advisory boards, is grouped in he same ca egory as lasbes os, cadmium and o her known carcinogens (Willhi e, Ball and McLelan 2008). Te major concern is ha he public bias agains all hings chemcal will be incorpora ed in ill-conceived legisla ion ha could undermine

long-s anding regula ory commi men ha relies on bes available da a


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Presidents Cancer Panel Annual Reportfor 2008-2009

Tese con radic ions were borne ou in he 2008-2009 repor by he Pres-iden s Cancer Panel, a hree-person commitee ha advises he Whi e Houseeach year on na ional cancer s ra egy (Na ional Cancer Ins i u e 2010). I o

ers a jarring insigh in o jus how endemic his new i era ion o chemophobhas become in our socie y.

Nearly 1.5 million new cases o cancer are expec ed o be diagnosed in he

U.S. each year; 562,000 Americans will die rom he disease. Approxima ely 41 percen o people in he U.S. will be diagnosed wi h cancer a some poinin heir lives. Te socie al cos s are s aggering: an es ima ed $243 billion each year. Te Execu ive Summary reads as i exposure o exogenous chemicals were he primary cause o hese cancers. Te repor is en irely devo ed o en vironmen al ac ors. I claims ha he propor ion o cancer cases riggerechemicals in he environmen has been grossly underes ima ed, warning o

grievous harm rom chemicals and o her hazards and a growing body o evidence linking environmen al exposures o cancer.

Te repor was sca hingly and bewilderingly received by many cancer andchemical exper s. Te panel ailed o invi e scien is s rom he FDA, EPANAS, NIOSH, OSHA or he Na ional oxicology Program (N P) o com-men on environmen al chemical risk, which raised doub s abou he repor sindependence and scien i c credibili y. In an analysis en i led Cancer e-por Energizes Ac ivis s, No Policy, eu ers Heal h and Science edi or noed, [ ]he repor rom he Presiden s Cancer Panel has underwhelmedmos mains ream cancer exper s and drawn only a puzzled response rom he Whi e House. Even members o Congress who usually are eager o show heyare gh ing o pro ec he public have been mos ly silen . Cancer exper s s

or he mos par ha we already know wha causes mos cases o cancer i s no pollu ion or chemicals lurking in our wa er botles (Fox 2010).

Michael Tun, an epidemiologis rom he American Cancer Socie y, wro e in an online response ha he repor was unbalanced by i s implica

ion and had presen ed an unproven heory on environmen ally induced


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43Case Study: Bisphenol A Precautionary Regulation

cancers as i i were a ac . Sugges ing ha he risk is much higher wheis no proo diver s aten ion rom hings ha are much bigger causes o ca

like smoking, Dr. Tun said.Te consensus among cancer exper s is ha obacco and die (obesiare he leading preven able causes o cancer, oge her making up hal o

hirds o all cases. In ec ions are believed o cause 15-20 percen o he c wi h radia ion, s ress, lack o physical ac ivi y and environmen al pollcausing he res . Maybe up o 4 percen o cancer in he Wes ern worcaused by con aminan s and pollu ion and ye we are chasing new, unknow

causes ra her han ocusing on ac ing on wha we know, said Graham Ci z, an epidemiologis a he Washing on Universi y School o MediciS . Louis and an adjunc pro essor a he Harvard School o Public HeaTings like his repor are making i harder o move he na ion o a healli es yle.

Te repor does acknowledge ha here is no hard evidence ha envronmen al ac ors play a signi can role in causing cancer200 pages in.

er sensa ional specula ion abou he po en ial dangers o cer ain chemhe repor concedes, A his ime we do no know how much environme

exposures in uence cancer risk. Te dear h o evidence did no s op he ahors rom proposing ha he governmen ac ively res ric chemicals

on consumer concerns, even absen evidence o ac ual harm and despi e cos s o such regula ion.


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Case Study:

Bisphenol A PrecautionaryRegulation

T he Presiden s Cancer Panel repor con ainsnumerous overs a emen s and inaccuracies, which re lec he panels reliance on heperspec ive o advoca es and selec scien is s ra her han a broad represea ion o scien is s mos amiliar wi h s udies on he chemicals commen

upon. One primary arge abou which he panel ge s considerable in orma-ion wrong is bisphenol A, an indus rial chemical used o add s reng h andexibili y o many plas ics and o make he epoxy resins ha are used o l

canned goods o preven con amina ion. In he opening leter o he presi-den , he panel no es, bisphenol A (BPA) is s ill ound in many consumerproduc s and remains unregula ed in he Uni ed S a es, despi e he growinlink be ween BPA and several diseases, including various cancers. Te panel-

is s urge he governmen o ake precau ionary measures o res ric i s usaTe con roversy surrounding bisphenol A drama ically illus ra es he virulence o chemophobia and he new orms i is aking. BPA is one o hmos ubiqui ous chemicals in he world. I has been in use or more han 50


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45Case Study: Bisphenol APrecautionary Regulation

years in he manu ac ure o polycarbona e plas ics and epoxy resins in is ry; in hermal paper produc ion; and as a polymeriza ion inhibi or

he orma ion o some polyvinyl chloride plas ics. I is ound in elec rDVDs, car dashboards, eyeglass lenses, and microwavable plas ic con aiers. Approxima ely 6 billion pounds are produced globally each year. Whenused as a building block in polycarbona e plas ic produc s, BPA makes hs rongerhard enough o replace s eel and ransparen enough o subs i

or glass. Polycarbona e can wi hs and high hea and has high elec rical ance. A presen , al erna ives or many o i s usessuch as in he pro

coa ing o me al can liners, where i does no a ec as e, helps prevenrial con amina ion and ex ends shel li e a a rela ively low cos do no

or mos oods (Lay on 2010).

Campaigns Against BPA

BPA is also one o he worlds mos s udied chemicalsi has been s jec o li erally housands o s udies. In 1982, he Na ional Cancer Insand he Na ional oxicology Program cleared i as a po en ial carcinog(Na ional oxicology Program 1982), and a review by he EPA endorsed isa e y in 1988 (EPA 1988). wen y years la er, in 2008, he FDA review

he s udies o da e and declared BPA sa e a es ima ed levels o humansure (U.S. Food and Drug Adminis ra ion 2008). A year la er, in 2009, und

pressure rom advocacy groups ha had sharply cri icized he ndings aexample o he Bush adminis ra ions alleged an i-science bias, he Ob Adminis ra ion announced he FDA would reassess he 2008 review.

For he pas our years, BPA has been under cons an atack by selec vironmen al groups, journalis s and some social scien is s campaigning o

he chemical ou righ or res ric i s use in produc s handled by in anchildren (Case, Te eal S ory Behind Bisphenol A 2009) (Vogel 2009). Te

poin organiza ion or much o his cri icism is EWG, which has been aclobbying or a ban since 2007. EWG is mos no ed or i s work lobbying ban o ph hala es. EWG does no have any scien is s wi h arge ed exin plas ics. Ta does no de er i rom regularly seeding he Web wi h


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sa ional, simplis ic and o en-misleading in erpre a ions o complex s udieFor example, in November 2009, as he environmen al communi y anxiously

awai ed he FDAs decision regarding BPA, EWG pos ed a repor on heHu -ing on Pos wi h he headline, BPA Wrecks Sex, Fouls Foodand Probably Worse (Shannon 2009).

Te public campaign conduc ed by EWG and o her advocacy organiza-ions has led o housands o s ories by mains ream news organiza ions an

on he web. Te Milwaukee Journal Sen inelalone has published no ewer han50 s ories or which i has won a bushel o journalism awardsexcoria ing

he governmen or no res ric ing or banning he use o BPA. I consis enrames he issue using wha can only be charac erized as sensa ional ac ic

In wha i calls a Wa chdog epor , he Journal Sen inelwarned ha BPA could cause, in humans, cancers o he breas , brain and es icles; loweredsperm coun s, early puber y and o her reproduc ive sys em de ec s; diabe eaten ion de ci disorder, as hma and au ism (Milwaukee Journal Sen inel2010)none o which is suppor ed by scien i c s udies or in erna ional reg-ula ory agencies.

A eedback loop has developed among news organiza ions and selec environmen al groups and consumer advoca es promo ing he view ha BPA iunsa e. In i s December 2009 issue,Consumer epor srepea ed un ounded al-lega ions ha BPA has been linked o a wide array o heal h e ec s includireproduc ive abnormali ies, heigh ened risk o breas and pros a e cancersdiabe es, and hear disease in humanserroneous claims ha subsequen ly

urned up in he Presiden s Cancer repor bu which have been rejec ed byhe N P, risk assessmen s by he FDA and he European Union. ejec inghe ndings o research au hori ies, he magazine urged he FDA o revise i

inadequa e and ou o da e s andards. (Consumer epor s 2009) TeCon-sumer epor sar icle inspired panic-inducing reac ion s ories a ABC News,

he Los Angeles imes , Fox News andTe New York imes , as well as hundreds

o o her ar icles in smaller publica ions and on he web. Te Susan G. Ko-men Founda ion was so overwhelmed and alarmed by calls rom righ ened women, i consul ed wi h a op exper in he eld, Melissa Bondy, an epidemologis a he Universi y o exas MD Anderson Cancer Cen er. [ ]here is


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47Case Study: Bisphenol APrecautionary Regulation

no evidence o sugges a link be ween BPA and risk o breas cancer, Boconcluded in a summary aler s ill pos ed on he ounda ions websi e (S

G. Komen or he Cure 2010).Considering he change in ideological complexion a he head o he FD ban proponen s were aken aback in January 2010 when he agency announci was s anding by i s 2008 conclusion ha BPA is sa e as used. I declarchemical posed negligible or minimal concern or mos adul s and is proven o harm children or adul s, concluding, [s] udies employing s andaized oxici y es s used globally or regula ory decision making hus ar ha

por ed he sa e y o curren low levels o human exposure o BPA. (FooDrug Adminis ra ion 2010) When asked direc ly i adul s or children acedreal heal h dangers, Joshua Shar s ein, M.D., he FDAs principal depu y cmissioner, minced no words: I we hough i was unsa e, we would be s rong regula ory ac ion (Na ional Ins i u es o Heal h 2010). While reaing here were no dangers, he FDA repor recommended ways o limi exsure o BPA and said i is unding more s udies.

In i s s udy, released our mon hs a er he FDA repor , he Whi e HCancer Panel ignored he FDAs conclusion ha BPA was sa e or adul sin an s and ha amilies should no change heir use o in an orm

ood. Ins ead, he repor ci ed selec ive and ou o con ex elemenFDA s a emen o rein orce he belie ha BPA is unsa e. Te panelisclaimederroneously ha he N P had said here is cause or concerabou he chemicals link wi h reproduc ive abnormali ies, when he N

ac concluded here was negl

Documents

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