Eliminating toxic chemical threats - A new framework
There is an emerging intellectual and policy framework for addressing toxic chemical threats. It is a framework which focuses on pollution prevention rather than pollution control, the precautionary principle as a methodology for decision-making, the end of individual chemical risk assessment, and the need for democratic control of production decision.
by Gary Cohen
THE continued production, use and disposal of chlorinated chemicals is now being challenged by regulatory, legal and citizen actions around the world. Such actions are likely to increase in coming years as additional data about chlorine's widespread environmental, occupational and public health impacts become more widely discussed. At the heart of these challenges are the emerging frameworks of pollution prevention instead of pollution control, the precautionary principle as a methodology for decision making, the end of individual chemical risk assessment, and the need for democratic control of production decisions. The time is ripe for a broad alliance of the environmental health, environmental justice and labour movements to push for the elimination of chlorinated chemicals while at the same time ensuring a just transition for workers and communities dependent on chlorinated-chemical production.
A new framework
There is an emerging intellectual and policy framework for addressing toxic chemical threats that represents a dramatic departure from the pollution control strategy that the US government has pursued for the last 25 years. This new framework has four components:
prevention instead of pollution control
precautionary principle as a new methodology of decision making
The IJC identifies a class of chemicals called 'persistent toxic substances' that cannot be safely regulated. These include chemicals that 'cause death, disease, behavioural abnormalities, cancer, genetic mutations, physiological or reproductive malfunctions or physical deformities in any organism or its offspring, or which can become poisonous after concentrating in the food chain'. This list also includes chemicals that bioaccumulate (become more concentrated as they move up the food chain), and chemicals that are persistent (with half-lives greater than eight weeks in any medium - water, air, sediment, soil or living things). If a chemical falls within these classifications, it should be eliminated. This approach does not require exhaustive causal proof of harm. Rather, decisions are based on the 'weight of evidence.' When there is reasonable documentation that certain chemicals are linked to certain effects, this evidence is sufficient to trigger preventative measures to eliminate that toxic source. Since virtually all chlorinated chemicals studied to date exhibit one or many of these characteristics, the IJC recommended in its 1992 report that these chemicals should be eliminated from the Great Lakes ecosystem.
end of individual chemical risk assessment
Approximately 70,000 different chemicals are now in commercial use with nearly six trillion pounds produced annually in the US. More than 80% of these chemicals have never been screened to learn whether they cause cancer, much less tested to see if they harm the nervous system, the immune system, the endocrine system or the reproductive system. The current US approach is also not based on real life exposures since people and animals are not exposed to one chemical in isolation, but rather are exposed to a dizzying array of toxic chemicals.
A preventive and precautionary approach seeks to shift the burden of proof onto the chemical manufacturers to prove that a chemical is not hazardous to human health or the environment before it is introduced to commercial use, rather than wait for massive injury before any protective action is taken.
control over production decisions
In 1991, the Environmental Protection Agency (EPA) offered an amnesty to companies that disclosed internal toxicological research that had not been made public to date. Eleven thousand different studies were submitted by more than 120 companies, many of them with damaging information about chemical products in commercial use. Similarly, companies engage in 'junk science' on a routine basis to show that a particular chemical is not harmful and does not merit restrictive regulation. In case after case, industry works to protect its market share, despite significant evidence that its products may be killing people.
Nor can production decisions be left in the hands of government regulators. The past few decades have clearly demonstrated that corporate interests have poisoned the political and regulatory process, while workers, communities and the environment have all suffered significant harm. The US government has for the most part protected the interests of the polluters against the interests of working people and the environment.
In the new approach to toxics, workers and communities will need to assert not only the right to know about toxic chemicals, but also the right to participate in decisions about their continued production and use. Without exercising this right, there is no way for workers to protect their long-term interests and their health.
Persistent toxic substances
The conceptual framework described above is the cornerstone of both national and international efforts to address chlorine chemistry. Among those efforts are four unique but connected initiatives to restrict the uses of chlorine chemicals:
IJC of the Great Lakes acknowledges that chlorine is toxic, persistent
American Public Health Association (APHA), the country's oldest public
health association, has passed two resolutions in the last three years
advocating the elimination of chlorinated chemicals.
United Nations Environment Programme is spearheading a global treaty process
that will create a mechanism for phasing out persistent organic pollutants
US environmental health and justice movement is developing a comprehensive
strategy to phase out the uses and dangerous waste disposal of chlorinated
chemicals across a wide array of industrial sectors.
There are compelling reasons why the debate about the phaseout of chlorinated chemicals will intensify in the next few years:
toxicity and exposure is much worse than scientists and policymakers previously
is a great deal of research and debate about the ability of certain chemical
compounds to cause endocrine disruption at critical stages of foetal and
public health crisis related to environmental contamination is reaching
There are initiatives happening on the international and national levels aimed at restricting the production, use and dangerous disposal of chlorinated chemicals. These efforts are likely to increase over the next decade due to a combination of escalating health effects, new research on endocrine disruption and vigorous broad-based citizen action campaigns. We must develop a broad alliance working for these changes that includes environmental health and justice forces and labour to push for a transition away from a toxic, chemically-addicted economy to a saner, healthier, more sustainable world. (Third World Resurgence No. 90/91, Feb-March 1998)
The above article is reproduced (without footnotes) from the Global Pesticide Campaigner (Vol. 7, No.4). Gary Cohen is Co-Coordinator for Health Care Without Harm, an international campaign designed to reform the pollution practices of the health care industry. He can be contacted at 41 Oakview Terrace, Jamaica Plain, MA 02130; phone (617) 524-6018; fax (617) 524-7021; email firstname.lastname@example.org