Two recently published books are at opposite poles regarding the risks imposed by the addition of synthetic chemicals into our environment. One book is “Legally Poisoned: How the Law Puts Us at Risk from Toxicants” by Carl Cranor. The title speaks for its side in the argument. The other book is “Scared to Death: How Chemophobia Threatens Public Health” a multi-author book edited by Jon Entine.
The arguments in Legally Poisoned center on the view that Americans are unwilling guinea pigs exposed to thousands of toxic synthetic chemicals and that more than 200 “toxicants” show up in the body when testing for these chemicals.
The Forbes posting “Chemical is not a four-letter word” reviews both books. In Legally Poisoned, Cranor says:
“…..because we are all “contaminated” it has become impossible to determine which chemicals are causing toxic effects, such as cancer.”
Cranor considers exposure of humans to chemical compounds to be unethical experimentation without informed consent:
“Because most substances are subject [only] to post-marketing regulation, the existing legal system results in involuntary experiments on citizens. The bodies of the citizenry are invaded and trespassed on by commercial substances, arguably a moral wrong.”
As to what to do, Cranor advocates the Precautionary Principle, which would require “that all new products, technologies or activities be prohibited or withdrawn from the market or heavily regulated until there is incontrovertible proof of their safety.”
Scared to Death responds challenging the assertion that these chemicals are “not” tested. They walk one through the many tests that are undertaken to establish a maximum tolerated dose (MTD) in test animals. From this
……an “acceptable” level of human exposure or intake is established that is many orders of magnitude lower than the MTD; it is commonly so low, in fact, that the risk, as the EPA puts it, “may indeed actually be zero.” (Risk is the arithmetic product of hazard – the intrinsic ability to cause injury — times exposure.)
Scared to Death also notes that: “In fact, we exist in a sea of chemicals; indeed, we are chemicals. Some are natural and some are man-made but neither group is intrinsically more or less safe.”
Every chemical, whether natural or synthetic, has some potential toxicity. Indeed, even drinking too much water can be harmful – leading to a condition called psychogenic polydipsia. What matters is the inherent toxicity of each individual chemical and the amount and route of exposure.
Life expectancy in the industrialized countries is constantly increasing, cancer rates are down almost across the board and people are generally healthier. The imposition of more chemophobic, precautionary regulation would unnecessarily turn back the clock to a time when vast numbers of people died from preventable infections, crop yields were devastated by insects and our lives were altogether less convenient.
Finally with respect to application of the Precautionary Principle, Scared to Death says: “Having to prove the absence of risk would strand civilization in the blind alley of needing to prove a negative. Worse, it raises the question of how we can even identify risks and test for them since we cannot foresee them all.”
“Scared to Death argues that regulatory decisions should be dictated by science and the application of established risk assessment techniques rather than according to the sort of precautionary paralysis advocated by Cranor that would deprive the world of lifesaving drugs, disinfectants, pesticides and countless other products that enhance the quality (and length) of our lives. Putting it another way, there are risks inherent in not using new products or technologies, such as vaccines to prevent influenza, insecticides to control disease-carrying mosquitoes or bacteria to clean up oil spills.”
Ordinarily a commentator on a book reads it and understands the background pertinent to assessing it before commenting.
The comment, “Fear of Synthetic Chemicals” falls short on both counts.
“Legally Poisoned: How the Law Puts Us at Risk from Toxicants,” (Harvard, 2001) is centrally based on scientific research into the developmental basis of disease. This is the view that “in utero nutrition and/or in utero or neonatal exposures to environmental toxicants alter susceptibility to disease later in life.” (Heindel, 2008)
Developing children can be predisposed to disease or health depending upon the environment in the womb. If toxic chemicals are in the womb, developing fetuses are contaminated with them. Industrial chemicals, some toxic, have been documented in the womb and up to 200 have been found in newborns.
The vast majority of industrial chemicals have not been tested for toxicity or for toxicity to developing children. Both Mr. cbdakota and Mr. Entine appear to believe that all humanly created chemical products are tested before exposures.
This is simply false. Moreover, they are unfamiliar with provisions of the Toxic Substances Control Act (TSCA), with reports from the U.S. EPA and with reports from the U.S. Governmental Accounting Office that reveal TSCA requires no toxicity testing of new chemical creations. Pharmaceuticals, pesticides and new food additives (to some extent) legally must be tested for toxicity before commercialization.
For new chemicals the EPA only requires, “all available data on chemical identity, production volume, by-products, use, environmental release, disposal practices, and human exposures.” NO TESTING FOR TOXICITY. (http://www.chemalliance.org/topics/?subsec=27&id=689)
A substantial percentage of 80,000 substances now in commerce lack toxicity data, although some voluntary efforts have sought to improve this. The EPA has required testing on only 200 of this universe in the 34 years since TSCA became law in 1976 and only after public exposure. (GAO, 1995, 2009)
If Scared to Death asserts that all commercial chemicals go through legally required testing before commercialization, it is mistaken, as the above sources reveal.
Legally Poisoned also does not use the words “precautionary principle.” An electronic search yields only one entry for “precautionary” and that is in a footnote. Mr. cbdakota would know this if he had read the book.
Moreover, nowhere does Legally Poisoned assert that there must be “incontrovertible proof of safety” for commercial chemicals. That word is not used in the book. This is simply Mr. cbdakota’s invention. It appears he is making up something to attribute to Legally Poisoned. The quotation he cites is not mine or in the book.
Legally Poisoned argues that good public health laws should be based on good science, including the developmental origins of health and disease. Mr. cbdakota may not know of this science, but it is critical for having laws that can protect our children, grandchildren, great grandchildren and future generations.
A far better regulatory policy than we have at present would utilize the best science available to test products and conduct risk assessments before they enter commerce. The current alternative—based on what we know about the developmental origins of disease, toxic contamination of our children and ourselves, and the surprising susceptibility of humans to pesticides and industrial chemicals—is far worse for our children.
Current laws governing the vast majority of commercial chemicals treat our children and us as guinea pigs.
Does Mr. cbdakota believe that the current system of protecting the public health is just fine: permit the vast majority of industrial chemicals into commerce without any legally required toxicity data, and later if children are harmed, react to the problem?
Moreover, such a retroactive approach is at odds with protections for people in medical experiments. Human volunteers in clinical trials for pharmaceuticals may not be exposed to proposed drugs without substantial preliminary testing to ensure risks are minimized. There must also be scientific and ethical oversight of the experiment.
A retroactive approach is also at odds with the laws for pharmaceuticals, pesticides and new food additives that must undergo legally required testing. These sectors of our commercial life do not seem to be deprived of products because of paralysis.
Premarket testing will miss some toxicants, but we must do the best we can. Indeed pharmaceuticals and pesticides have been well documented to cause harms to children during development. Nonetheless their legal structure for public health protections should be adopted with appropriate changes to protect our children.
Carl F. Cranor
Distinguished Professor of Philosophy and faculty member, Environmental Toxicology Graduate Program
University of California, Riverside
Carl Cranor, except all that wonderful research does not take into account hormesis.