#519: Ethical Hazards of Risk Assessment
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ETHICAL HAZARDS OF RISK ASSESSMENT
Not long ago, a state environmental official wrote us a
thoughtful letter about risk assessment:
"Recently I attended a public meeting as part of the process of
revising numeric criteria for 41 carcinogens and other toxicants
that bioaccumulate in fish consumed by humans.
"The [state environmental agency] and the EPA [U.S. Environmental
Protection Agency] would be satisfied if we could derive the
concentration in water of each contaminant that would result in a
risk level not greater than one-in-a-million to humans consuming
fish, and then sanctify that number in administrative rule.
"It occurred to me that we are missing the point. We are in
essence granting rights to chemicals, and chemical dischargers,
and denying them to people. The human population is not granted,
for example, a guarantee that there will not be more than an
additional one in 10,000 cancers in the population due to
exposure to all xenobiotics [toxic chemicals made by humans].
But chemical dischargers are given a guarantee for each chemical
of a defined allowable risk level they can impose on the human
population.
"We seem to have it backwards. Instead of defining a societally
acceptable risk to humans from ingesting contaminants, and then
apportioning allowable risk to each contaminant and discharger,
we grant each chemical a risk level, and do not even make the
effort of calculating the cumulative risk of all chemicals to
humans. If the latter is impossible, it is an argument for zero
discharge industries.
"Very few at the meeting were even aware that we were not talking
one-in-a-million risk level in any case, but 41-in-a-million,
considering all 41 contaminants in question.
"As well, industry argued for separating estuarine from marine
criteria, which would grant each chemical a two-in-a-million risk
level. Why not get really ridiculous and do it by fish species
--one-in-a-million risk level to humans from consuming each of
the following: cod, flounder, bass... [Furthermore,] the
allowable contaminant level we grant each chemical is not
'global.' As I understand it, the EPA would allow an additional
risk level for these chemicals from meat consumption, for example.
"Other obvious flaws in our risk assessment are that: we in [our
state] and in many other states do not even regulate most of the
126 EPA priority pollutants, let alone the 70,000 chemicals in
use by industry;
"It is probable that in some cases we are using insensitive
endpoints, for example widespread immune system damage may occur
at lower contaminant concentrations than those which produce
significant numbers of cancers;
"We ignore synergism [increased toxicity caused by multiplier
effects when two or more chemicals interact];
"We aren't necessarily taking into account sensitive human
sub-populations (immune depressed, or fetuses).
"What bothers me is the mismatch between the two ends of the risk
spectrum. At one end we have the guaranteed risk level granted
to chemicals of between one-in-100,000 and one-in-10-million; at
the other end we seem to have real increases in human health
deterioration, breast and testicular cancer, ADHD [attention
deficit hyperactivity disorder], and reduced sperm production, of
tens of percents. How do we get from one-in-a-million to tens of
percents, and which end of the spectrum should we offer a
guaranteed risk level?...
"Another thought: industry, in criticizing our methodology for
developing new and possibly more stringent criteria, piled one
difficult-to-address concern after another on us. Of course if
industry were footing the bill for the studies necessary to
address these concerns, perhaps they wouldn't have been as vocal.
Reverse onus..."
This state official --who obviously might lose his/her job if we
revealed his/her name (which, if you think about it, speaks sad
volumes about free speech in America) --was commenting on the
ethical dilemma of every risk assessor, which is this: assessing
risks is a natural and inevitable step for humans to take (we all
do a risk assessment before we dash across the street hoping to
avoid getting hit by a car). But risk assessment is now embedded
in our environmental laws at the federal and state levels in a
way that guarantees that the "rights" of industrial poisoners
will be protected by the apparatus of the state while citizens
will be first disempowered and then physically harmed by the risk
assessors' work. Risk assessors are now in the position of the
conductors and engineers who kept the trains running on time to
the death camps in Nazi Germany to minimize discomfort to their
passengers --they are just doing a job, honorably and to the best
of their ability, but the final result of every professional risk
assessor's work is the destruction of the natural environment,
one decision at a time, and the relentless spread of sickness
throughout the human and wildlife populations.
The only way to restore an ethical basis to risk assessment is to
embed it in a very different framework for decision-making.
Right now risk assessment is used to answer the following sort of
question: "How much of these 41 carcinogens can we give industry
the 'right' to dump into public waters without killing an
unacceptable number of citizens?" Anyone who helps the state
answer such an immoral question is essentially keeping the death
camp trains running on time. An ethical decision-making process
would ask a very different question: How can society's resources
be employed to minimize the use of chemicals known or suspected
of causing harm to humans and the environment? Within a
decision-making framework set up to answer THAT public policy
question, risk assessors could honorably use their skills,
talents, and knowledge to help society examine various
alternatives. Until then, risk assessment will continue to be a
raw political tool of the industrial powers-that-be, a means for
'managing' (manipulating) the anger, fear, and frustration of a
citizenry that knows it is being poisoned.
The raw political nature of formal risk assessment is being
demonstrated now in California, where Governor Pete Wilson's
administration has ordered state risk assessors to destroy
research data and internal records that fail to reflect the
state's final policy decisions on pesticides, toxic wastes, and
industrial-plant emissions. A memo issued by the California
Environmental Protection Agency's Office of Environmental Health
Hazard Assessment asks employees to cull files to ensure that
they contain only materials that reflect management findings.
"Please dispose of all documents... [electronic-mail] messages
and other communications prepared during the course of policy
formulation which contain other policy proposals not adopted or
reflected in the final decision," Charles Shulock, the office's
chief deputy director, wrote on April 19, 1996. The memo was
obtained by the WALL STREET JOURNAL.[1]
Mr. Shulock's memo argues that the new "records retention policy"
will protect sensitive "pre-decisional" deliberations and will
thus promote "robust internal discussions." But the state's
scientific staff sees it differently: "It's ridiculous and isn't
sincere. If they are concerned about free flow [of information],
they would not conceive of shredding very important scientific
evaluations," says Kristen Haynie, a spokesperson for the
California Association of Professional Scientists, a labor union.
One of California's nationally-known pesticide risk assessors,
Robert Howd,[2] said, "The state has hired us and pays us as
experts to exercise scientific judgment. Controlling the right
of scientists to decide what will be useful later would attack
our professionalism, our honor and the scientific process itself."
What Mr. Howd seems not to recognize is that the formal risk
assessment process, as it is typically practiced for
decision-making in the U.S. today, is not about honor or
professionalism or science. Baldly put, it is about making
political decisions, the aim of which MUST BE to accommodate the
industrial polluters who provide the mountains of cash necessary
for politicians to gain re-election and retain their power. If
one-in-a-million, or 41-in-a-million, or several percent of,
citizens are hurt in the process, so be it. (Until we get full
public financing of elections --to get the corrupting power of
private money out of our elections --this political dynamic will
continue to dominate decision-making, and risk assessment will
only be able to be conducted within this framework.)
Case in point: Robert Holtzer, a medical doctor and biochemist,
says he was told to ignore evidence that pesticides are causing
cancer and asthma among residents of Lompoc, California. Dr.
Holtzer says preliminary research by his agency suggested a
higher-than-normal incidence of lung and bronchial cancers, and
an increase in respiratory illnesses, among residents of Lompoc
Valley. He says further study is needed. "Despite the fact that
this looks like something, I was told to ignore it --don't study
it, don't talk about it," says Holtzer, who retired recently from
the California EPA's Office of Environmental Health Hazard
Assessment.[3]
Dr. Holtzer says, and his former supervisor confirms, that his
office was formally ordered to stop studying diseases in Lompoc.
For years, residents of Lompoc have been complaining that
pesticides sprayed on nearby fields of lettuce, broccoli and
flowers have been making them sick with flu-like symptoms.
In June Dr. Holtzer's former supervisor, David Siegel, wrote a
draft report on the Lompoc situation in which he concluded that
the data "did not provide findings of increased illness in the
Lompoc area." Dr. Holtzer and two of his colleagues who
collected the data in Lompoc --epidemiologist Richard Ames and
toxicologist Joy Ann Wisniewski --refused to sign their names to
Mr. Siegel's draft report. "We asked that our names not be
associated with the report," Dr. Holtzer said. Drs. Ames and
Wisniewski wouldn't comment for the record, thus silently
speaking volumes about the limits of free speech in late 20th
century America.
The manipulation of risk assessments in California for political
purposes is not unique or even unusual. Risk assessment, when it
is embedded within a decision-making process specifically aimed
at determining how much damage is 'acceptable' and specifically
NOT aimed at finding least-harmful solutions, is by its very
nature a clandestine political manipulation of the citizenry.
What's unusual in California is that the unethical political
manipulation is so obvious and so well documented that even the
WALL STREET JOURNAL finds it noteworthy.
--Peter Montague
(National Writers Union, UAW Local 1981/AFL-CIO)
[1] Mark Lifsher, "Technology & Health--California EPA Stirs
Anger by Ordering Disposal of Data Disputing Its Findings," WALL
STREET JOURNAL October 1, 1996, pg. B5.
[2] See, for example, Anna Fan, Robert Howd, and Brian Davis,
"Risk Assessment of Environmental Chemicals," ANNUAL REVIEW OF
PHARMACOLOGY Vol. 35 (1995), pgs. 341-368.
[3] Mark Lifsher, "California Journal: Cal-EPA Scientists
Complain Pesticide Data Were Buried," WALL STREET JOURNAL
[California Supplement] October 2, 1996, pg. CA1.
Descriptor terms: risk assessment; fish; wildlife; ethics;
regulation; alternatives assessment; pete wilson; robert holtzer;
cal epa; office of environmental health hazard assessment;
lompoc; ca; cancer; asthma; pesticides; david siegel; whistle
blowers; wall street journal; water pollution;
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--Peter Montague, Editor
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