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8-Misc: New books on environmental protection and risk assessments

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TITLE:  Modern environmental protection - Two new books
SOURCE: RachelŐs Environment & Health Weekly #704 & #706
        Environmental Research Foundation , USA;
DATE:   July 21 & August 17, 2000

-------------------- archive: --------------------

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. 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.

ENVIRONMENTAL STRATEGY (Cambridge, Mass.: MIT Press, 2000). ISBN: 

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 

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 
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 
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 

 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 
(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 
(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)


Once in a while a really important new idea comes along -- or an old 
idea gets applied in important new ways. Mary O'Brien's proposal for 
"alternatives assessment" instead of "risk assessment" falls into 
this category -- innovative and important. No doubt I'm biased 
because our organization hired O'Brien so she could find the time to 
write a book on this subject. The book has just been published by MIT 
Press.[1] O'Brien's basic idea is astonishingly simple but also 
delightfully subversive of the status quo. Her idea is that we should 
all take a CONSUMER REPORTS approach to decision-making. Just as the 
well-known consumer magazine examines a range of available options 
before recommending a particular toaster or TV, all decision-makers 
(public AND private) should examine a full range of options before 
committing to a new project or new technology. The least-damaging 
option should be chosen. In other words, we should look before we 

O'Brien's approach makes such good sense that you might think all 
decision-makers would be using it already. But that's not how 
decisions are made in the industrialized world. Instead of examining 
a full range of alternatives, decision-makers generally decide what 
they want to do, then they hire a risk assessor to convince everyone 
that the damage they are about to do is "acceptable." By the time 
damage becomes apparent, they're hauling loot to the bank. At that 
point, stopping them is almost impossible. The cumulative result of 
this "risk-based decision-making" is a severely degraded and stressed 
global ecosystem. To put it bluntly, the global ecosystem is being 
shredded by people who are building roads, filling wetlands, logging 
forests, damming rivers, vacuuming fish from the oceans, overgrazing 
grasslands, depleting topsoil, wasting and polluting water, and 
dumping persistent chlorinated chemicals, toxic metals, greenhouse 
gases, and nitrogen into the environment on a massive scale. Each of 
these damaging activities is justified and deemed to be "acceptable" 
on the basis of a risk assessment.

Sometimes risk assessments are very formal, filling 1000 pages or 
more with mathematical formulas and technical data. On the other 
hand, most risk assessments are so informal that you might not even 
recognize them as risk assessments -- they may consist of a mere 
sentence or two. Examples: "Silt runoff will be kept within 
acceptable limits by the use of hay-bale barriers, so our 
construction project on the edge of the Bay will kill very few fish." 
Or "Naturally-occurring chemicals in food cause more cancers than 
this pesticide will cause, so it would be silly and a waste of money 
to worry about the presence of this pesticide in your cornflakes."

Risk assessment is the most powerful intellectual tool that the 
poisoners and destroyers of the planet have ever invented. It is 
their battering ram AND their camouflage. It provides "cover" for 
just about any damaging activity that anyone might want to undertake. 
Risk assessment is used to justify exposing workers to toxic 
chemicals and radiation; to justify clearcutting and other harmful 
practices in irreplaceable forests; to justify automobile emissions 
and the resulting killer smogs; to justify allowing silt and topsoil 
to escape into rivers and streams; to justify cleanup standards for 
radioactive contamination and for chemical dumps, accidents and 
spills; to justify dams; to justify suburban growth and encroachment 
onto farmlands; to justify fishing and hunting quotas; to justify 
contaminating our food with pesticide residues and other additives; 
to justify destroying habitat needed by endangered species; to 
justify "acceptable levels" of industrial toxicants in ourl drinking 
water; to justify new road construction in roadless areas... and on 
and on. In a nutshell, for any particular activity, risk assessment 
(a) how much damage will be caused,
(b) to what degree will humans and non-humans be "exposed" to the 
damage, and
(c) will the local consequences be "acceptable"? Naturally, what is 
"acceptable" is a political judgment.
If you ask the owner of a chemical factory how much money should be 
spent to prevent cancer in a worker, you'll get one answer. If you 
ask the same question of the worker, you'll get a different answer. 
What is deemed "acceptable" is a matter of raw political power. Thus 
risk assessment is not a "scientific" exercise -- it is a highly 
political mixture of prejudices, biases, guesses, estimates, some 
scientific facts, and many ethical judgments -- all masquerading as 
"objective" science.

Even the question, "How much damage will be caused?" is a political 
question. The answer depends upon how hard you are willing to look, 
what kinds of damage you are willing to consider, and how much 
scientific ignorance you are willing to acknowledge. The truth is, 
scientists can never figure out whether pesticides on a child's 
cornflakes (for example) are "safe" or "insignificant" because
(a) there are dozens or hundreds of adverse effects to consider, and -
- if history is any guide -- new ones will be discovered tomorrow;
(b) the pesticide effects will be added on top of whatever other 
stresses the child may be experiencing (medical drugs, auto exhaust, 
paint fumes, second-hand cigarette smoke, divorced parents, chronic 
ailments, excessive ultraviolet radiation from the sun because of a 
depleted ozone layer, and so on);
(c) children (like all organisms) have differing abilities to cope, 
and a unique history of exposure to hazards; and
(d) all organisms, like all ecosystems, are simply too complex for 
science to understand sufficiently to allow reliable prediction of 

In reality, risk assessments simply omit all these complexities -- 
which is to say, they ignore the real world and thus are a special 
brand of science fiction. Scientists (or journalists) who assert that 
exposures to industrial chemicals are "harmless" or "insignificant" 
are participating in a fraud because they are pretending to know 
things that cannot be known. When a risk assessor's work is used to 
expose people to unnecessary hazards without their consent, it 
crosses the line and becomes grossly immoral.

Risk assessment always asks the wrong question: it asks how much 
damage is safe instead of asking how little damage is possible. 
Furthermore, risk assessment conveniently never asks, "Is the 
proposed activity needed?" It never asks, "Is the proposed activity 
ethical?" It never asks, "What will be the cumulative impact of this 
activity combined with all the other damaging activities to which 
humans and non-humans are exposed at this location?" And risk 
assessment never, ever asks, "Are there less damaging ways to 
accomplish the same purpose?" On the other hand, all these questions 
are central to an "alternatives assessment." Thus alternatives 
assessment is wonderfully subversive because it asks fundamental 
questions about "business as usual." Risk assessment, on the other 
hand, simply greases the skids for "business as usual."

Starting about 1975, industrialists hoped that risk assessment would 
become the permanent key to imposing harmful decisions on an 
unwilling public -- and for a couple of decades it seemed to be 
working. Corporate risk assessors -- and a phalanx of third-rate 
journalists transformed into highly-paid "risk communicators" -- like 
to dress up in white lab coats and hang stethoscopes around their 
necks, then accuse their critics of being "irrational" devotees of 
"bad science." Monsanto, Dow Chemical and other major polluters have 
spent hundreds of millions of dollars promoting the idea that risk 
assessment is the very definition of "good science." Harvard 
University houses a polluter-funded "center" for risk assessment, 
which pumps out an endless stream of shameless propaganda aimed at 
convincing the American public that we all need to make more 
decisions based on risk assessment, because risk-based decisions are 
"unbiased," "impartial," "neutral," "rational," and based on "sound 
science."[2] Sound familiar? The NEW YORK TIMES maintains at least 
one staffer who writes almost nothing but risk-based propaganda on 
behalf of polluting industries.[4] In this, he joins a long list of 
distinguished corporate toadies like John Stossel, Gregg Easterbrook, 
Elizabeth Whelan, and Michael Fumento.

U.S. Supreme Court justice Stephen Breyer went the next step in his 
book, BREAKING THE VICIOUS CIRCLE , subtitled, "Toward Effective Risk 
Regulation."[3] Judge Breyer suggested that we set up a "small 
centralized administrative group, charged with a rationalizing 
mission" within the federal government, with the power to impose 
their risk-based decisions the public, democracy be damned. Like 
religious fanatics, this risk assessment crowd wants us to believe 
that they have found the truth and the way -- the only way. But 
really all they've found is a new way to justify shredding the 
biosphere to make money. It's just a one more scam to provide cover 
for traditional destructive behavior. In her book, Mary O'Brien 
devotes sections to Why business loves risk assessment, Why 
government agencies use risk assessment, and Why many scientists live 
with risk assessment even though they know risk assessment isn't 
mainly a scientific activity -- it is mainly a political weapon 
wielded by the powerful to have their way with the rest of us.

O'Brien's book is filled with provocative ideas. For example, our 
government -- and many others, like the Harvard risk assessors[2] -- 
recommend "comparative risk assessment" to rank environmental 
problems from important to unimportant. The rationale is that we 
don't have enough money to solve all our problems, so we should spend 
our scarce dollars on the most important. O'Brien challenges that 
thinking: "It is noteworthy that comparative-risk-assessment 
processes rank environmental problems. It would be just as logical to 
rank which behaviors are causing the greatest environmental problems, 
or who is causing the greatest environmental problems, or which 
social arrangements allow or encourage people to cause environmental 
problems. By focusing on environmental problems rather than on 
problematic behaviors, problematic people, or problematic social 
arrangements, the comparative-risk-assessment group can pretend that 
the problems just 'happened' and that no identifiable individuals or 
businesses caused them." (pg. 121)

O'Brien suggests that, in a democracy, all businesses and government 
agencies should be required to explore, on paper, and in 
understandable language, their options for causing the least possible 
environmental damage. She says, "All potentially environmentally 
degrading activities, public or private, should be subject to public 
scrutiny of alternatives. The public deserves to know that those who 
pollute, extract, consume, emit, incinerate, or abandon are aware of 
their technological options for minimizing disturbance of the 
environment."(pg. 122) But of course this won't happen any time soon 
because, as O'Brien says, "If you wanted to get approval to undertake 
a particular hazardous activity, would you want people asking big 
questions about the activity? Would you want people to think that the 
hazards or the potential risks were unnecessary? Alternatives 
assessment threatens the status quo. Alternatives assessment can make 
social change seem both desirable and possible."(pg. 136)

Is risk assessment 100% bad? Not necessarily. In a thorough analysis 
of a full range of alternatives, risk assessment might play a role. 
It is risk assessment of only one or a few options that O'Brien wants 
to eliminate.

Please urge your local library and bookstore to order MAKING BETTER 
ENVIRONMENTAL DECISIONS from MIT Press.[1] Starting this fall, Mary 
O'Brien will be available to give a talk, debate a risk assessor, 
lecture at your local university, or consult with your citizen group 
or your government, to help discover how "alternatives assessment" 
can improve decisions in your area of interest. She can be reached by 
--Peter Montague

ALTERNATIVE TO RISK ASSESSMENT (Cambridge, Mass.: MIT Press, 2000). 
ISBN 0-262-15051-4.
[2] See for example David Ropeik, "Let's Get Real About Risk," 
WASHINGTON POST August 6, 2000, pg. B1.
[3] See REHW #394. Stephen Breyer, BREAKING THE VICIOUS CIRCLE; 
University Press, 1993; paperback edition 1995); ISBN 0674081153.
[4] See for example John Tierney, "Tracing the Toxins to Your TV," 
NEW YORK TIMES August 18, 2000, pg. A25.


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