The
consequences of status quo chemical policy are becoming increasingly clear
Editor's
note: This is adapted from a lecture Zoeller gave at the 51st Session
of International Seminars on Planetary Emergencies: Science for Peace the World
Over, in Erice, Italy, in August. It has been lightly edited.
Chemicals
are manufactured for use in almost everything with which humans come into
contact including food, plastics, personal care products, clothing and building
materials.
In
addition, manufactured chemicals contaminate our environment in ways not always
anticipated in air, dust, food and water.
Most
of these chemicals are derived from crude oil; in fact, petrochemical
production is now driving oil demand. This demand for petrochemicals is
expected to increase.
It
is therefore important to recognize that only a few – and a minuscule
percentage – of chemicals with which we come into contact have been tested for
human safety.
The
cause of chemical exposures to the human population is profit and convenience.
If the production and use of chemicals resulting in human exposures were not
profitable, they would not be produced and used.
If
consumers did not feel that products containing petrochemicals were worth the
money, they would not buy them.
A
hidden issue is that consumers most often are unaware of the chemicals to which
they are being exposed.
Born
pre-polluted
Every
baby born – at least in the developed world – has well more than 100 industrial
chemicals in their bloodstream at birth, demonstrating that they are
exposed in utero.
In
other words, humans are born pre-polluted.
This
is a well-known situation among governments, so it is important to ask not
only why and how the human population has
become exposed to hundreds of chemicals, but also why we allow it to
continue.
If
a man in a suit were to knock on your door every morning offering a teaspoon of
clear liquid to your children, you would certainly decline the offer, even if
they said it was "government approved."
So
why do we accept it when the exposures are "hidden"?
If
chemical exposures are benign, then these questions are not important.
However, there is sufficient scientific evidence to conclude that chemical exposures are currently causing harm to the human population, and that their effects profoundly increase health care costs, decrease the quality of life for millions of people, reduce cognitive function and increase the expression of neurobehavioral disorders, and that at least some of these effects can be passed from one generation to the next without further chemical exposure.
However, there is sufficient scientific evidence to conclude that chemical exposures are currently causing harm to the human population, and that their effects profoundly increase health care costs, decrease the quality of life for millions of people, reduce cognitive function and increase the expression of neurobehavioral disorders, and that at least some of these effects can be passed from one generation to the next without further chemical exposure.
These
are observations that have been confirmed by many of the world's most credible
scientific organizations including the World Health Organization, the United
Nations, many medical societies, and international groups of independent health
science professionals.
We
are, in short, affecting not only individuals and populations, but also human
society and its future as we know it.
Why
does it continue?
To
begin to understand why we continue to contaminate the human population, it may
be useful to break this large question down into more focused questions.
For
example:
- Why do suppliers of products continue to make products with chemicals for which there is evidence of harm?
- Why do consumers continue to ignore known risks?
- Why do regulators (government agencies charged with public health protection) continue to approve chemicals for which there is evidence of harm?
Within
this context, it is germane to emphasize that an important mechanism by which
chemical exposures can harm the general population is by interfering with
hormones. This is important because hormones control many – if not most –
processes of human development and physiology.
In
addition, the few chemicals that are evaluated for safety are evaluated by a
strategy that is tuned to identify acute toxicity, not endocrine disruption.
We
know for certain that a variety of chemicals and chemical classes affect human
health by interfering with hormone systems.
These include lead, mercury, polychlorinated biphenyls (PCBs), polybrominated diphenyl ethers (PBDEs) and other flame-retardants, perchlorate, some pesticides, BPA and other estrogenic chemicals.
These include lead, mercury, polychlorinated biphenyls (PCBs), polybrominated diphenyl ethers (PBDEs) and other flame-retardants, perchlorate, some pesticides, BPA and other estrogenic chemicals.
In
general, there are two inter-dependent reasons to explain each of these
questions posed above. The first is that governments employ an antiquated
discipline that informs us about toxicity and safety.
This system is based on the 400 year-old concept that the "dose makes the poison."
This system is based on the 400 year-old concept that the "dose makes the poison."
The
implication of this concept is that everything is toxic at some dose. In this
way, arsenic is the same as water – it just takes more water to kill a person
than it does arsenic.
This
false equivalency supports a regulatory system that calculates the risk of harm
to humans exposed to a variety of chemicals from pesticides designed to interact
with biological systems to plasticizers, flame-retardants or heavy metals that
are used only for their product functionality.
But,
what is the harm that risk calculations are designed to prevent? Operationally,
those harms, or adverse effects, are defined by the tests employed to evaluate
the hazard. Cancer studies identify carcinogens; reproductive studies identify
reproductive toxicants; endocrine studies identify endocrine disruptors;
immunology studies identify immune toxicants.
These
tests are prescribed studies with measurements that have been approved by
various committees. However, there is good reason to question both the
sensitivity of these measurements to identify hazards, and the degree to which
they reflect hazards to the human population.
In
addition, hazard identification is only the first step in calculating risks;
the potency of the chemical and the exposure of humans to the chemical must
then be determined to calculate risk.
For
example, researchers who work for or with industry defined the potency of
chemicals that act like the female hormone estrogen by their ability to affect
the weight of a rat uterus. This is a standard measure of estrogen activity
used by industry and by the government, but there are other, more sensitive
measures, such as the ability of estrogen to affect brain development.
Therefore,
risk calculations of chemicals that act like the female hormone estrogen (e.g.,
BPA) are often based on its ability to affect the weight of a rat uterus. The
lack of sensitivity of traditional measures of potency of chemicals to
interfere with hormones is generalizable across endocrine systems.
In
addition, if the measurement (e.g., uterine weight) is not plausibly reflective
of a risk of disease or disability in the human population, it is difficult to
understand why it is employed other than that it is the traditional measure.
Likewise,
estimates of exposures are error prone at best. For example, reports of the
effect of perchlorate in drinking water on thyroid function in newborn babies
used measures of perchlorate exposure in municipal water supplies in Las Vegas,
Nevada (contaminated) compared to Reno, Nevada (not contaminated) as a
surrogate measure of exposure.
Perchlorate
is known to inhibit thyroid function and thyroid hormone is essential for
normal brain development. Therefore, calculating the risks associated with
perchlorate exposure has important public health implications.
However, more recent studies demonstrate that everyone is exposed to perchlorate, independent of municipal water contamination; therefore, risk estimates were flawed based on these early reports using city of residence as a surrogate for exposure to perchlorate.
However, more recent studies demonstrate that everyone is exposed to perchlorate, independent of municipal water contamination; therefore, risk estimates were flawed based on these early reports using city of residence as a surrogate for exposure to perchlorate.
A
second reason that the status quo of human chemical exposures continues is that
financial self-interest motivates campaigns to confuse both the public and
regulatory agencies with the goal of limiting or avoiding regulations.
The strategies employed, well-documented in a number of legal cases, range from outright fraud and corruption to the selective manipulation of information to make a chemical or product appear safe.
The strategies employed, well-documented in a number of legal cases, range from outright fraud and corruption to the selective manipulation of information to make a chemical or product appear safe.
These
two categories of explanations for the status quo are not mutually exclusive.
The "principle" that the "dose makes the poison" lends
itself quite readily to manipulation because it creates a false equivalency
between chemicals that are causing harm in the human population and those
(e.g., water) that are not.
Moreover, it relies on potency as a primary metric, when potency is neither relevant to hazard identification nor an absolute metric.
Moreover, it relies on potency as a primary metric, when potency is neither relevant to hazard identification nor an absolute metric.
There
are two additional issues: One is that regulatory decisions are made by
government agencies in secret collaboration with the industries that
manufacture the chemical. It is secret because the data provided to regulatory
agencies are proprietary.
However,
the people from government and industry involved in these negotiations and
decisions are not experts in human health and therefore must necessarily make
decisions based on traditional ways of interpreting traditional data.
The
second is that there seems to be a general acceptance that petrochemical-based
products are required for modern life and that environmental regulations
negatively impact market competitiveness.
The
concept that petrochemical-based products are required for modern life implies
necessarily that we cannot manufacture safer products using bio-based
feedstocks and green chemistry. This is a particularly unflattering and
pessimistic view of human society and it should be summarily rejected.
The
concept that environmental regulations negatively impact market competitiveness
has been refuted over and over again by a variety of economic studies.
Thus,
when governments overtly move to restrict or eliminate environmental
regulations, they are acting neither to protect public or environmental health
nor to protect the market. Rather, they are acting to protect the market share
of industries currently dominating the market.
In
other words, the chemical industry and regulatory system has evolved to
maintain itself rather than to protect public health.
Implications
of inaction
The
consequence of this status quo is becoming increasingly clear. Non-communicable
disease now results in more deaths per year than communicable diseases, and
these chronic diseases profoundly impact quality of life and the global
economy.
The
human health effects of exposures to only a few endocrine disruptors for which
there is sufficient data alone cost the economy hundreds of billions of dollars
per year, not to mention impacting quality of life.
In
addition, there is a cultural cost to the status quo of chemical regulations.
A
large number of chemicals are known to affect brain development and cognitive
function. Loss of IQ as well as increasing the incidence of neurobehavioral
disorders in generations of children can have profound effects on society.
It is germane here that the U.S. Centers for Disease Control and Prevention has recently reported that the incidence of autism in the U.S. is now 1 in 40 children.
It is germane here that the U.S. Centers for Disease Control and Prevention has recently reported that the incidence of autism in the U.S. is now 1 in 40 children.
Moreover,
there is increasing evidence that the health effects of endocrine disrupting
chemicals can be passed from one generation to the next.
What
will be required for the status quo to change?
We
must first admit that this status quo is not sustainable and is responsible for
contributing significantly to human health and global economic challenges. That
admission will provide the political will to begin to change this status.
It
isn't simply a matter of loving our children more than we love money.
Rather
it is a matter of clearly evaluating the system we have created and the price
we are paying for its maintenance.
It may not be uncommon that human enterprises reach a point where more effort goes into maintaining the status quo than adapting to new data to refine and improve the system.
It may not be uncommon that human enterprises reach a point where more effort goes into maintaining the status quo than adapting to new data to refine and improve the system.
But
we can and should do better, both for our future and for our economy.
Reducing
chemical exposure should be considered "low hanging fruit."
Dr.
R. Thomas Zoeller, Ph.D., is Professor of Biology at the University of
Massachusetts, Amherst. His research focuses on the role of thyroid hormone in
brain development and the mechanisms by which environmental endocrine
disruptors can interfere with thyroid hormone action in the developing brain.