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---May 29, 1991---
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Global pollution by toxic chemicals is increasing. Chemical contamination now contributes to the following kinds of problems: global warming, ozone depletion, acid rain, rising cancer rates, increasing asthma, the widespread poisoning of children by lead, escalating rates of Parkinson's disease and of Lou Gehrig's disease, growing infertility among American men and women in their prime reproductive years, the contamination of breast milk, a new disease called "multiple chemical sensitivity," and more. Yet current approaches to regulation do not incorporate ways of dealing with the continued spread of chemicals worldwide. As we saw last week, two researchers at Oak Ridge National Laboratory (ORNL) recently published a brief catalog of global pollutants and, using EPA (U.S. Environmental Protection Agency) methods for assessing cancer risk, they concluded that the "background" cancer risk from just 11 chemicals is one-in-a-thousand, which is about 1000 times more risk than EPA would usually allow any individual polluter to create. (ENVIRONMENTAL SCIENCE & TECHNOLOGY Vol. 25 [May, 1991], pgs. 814-819.) Here is the heart of the problem: by focusing only on controlling risks to the "most exposed individual," EPA has allowed thousands of small polluters to dump chemicals into the environment; together these small sources add up to a big hazard, yet none of them individually presents a large enough hazard for EPA to officially notice.

To prevent pollutants from spreading everywhere on earth, we must prevent the introduction of dangerous pollutants into all media: air, water, and soil. To do this, we must either use fewer dangerous chemicals, or we must destroy them before they are released into the environment. In the case of metals, which can never be destroyed, we must use less of them. In the case of toxic organic chemicals, such as dry cleaning fluid (tetrachloroethylene, also known as perchloroethylene, or perc), we can either use less of it or we must destroy it after we use it, before it gets away from us. An organic chemical is considered "destroyed" when it is broken down into its elements. (There are only 92 naturally-occurring elements and everything on Earth is made up of combinations of these 92 building blocks. It is worth noting that some of the building blocks themselves are toxic, so these will need to be used in strict moderation, or not at all, if we are to avoid poisoning the earth. Thallium, mercury, and cadmium fall into this category. Elemental chlorine probably belongs in this category as well--see RHWN #225.)

Any organic molecule that can be put together can also be taken apart--"destroyed"--for a price. That's the hitch. After a chemical like perc has cleaned someone's clothes a few times, it is dirty and not very useful. It is ready for discard. Now would be the time to "destroy" it. EPA's solution to this problem is to burn it in an incinerator. Unfortunately, as the ORNL researchers noted "...emissions from incinerator stacks tend to release pollutants directly into the atmosphere." In fact, incinerators release unburned chemicals directly via the stack but also via leaks and spills during transport and handling. Moreover, once chemicals are in an incinerator's combustion chamber, they can recombine into new chemicals (called PICS--products of incomplete combustion) which can be more toxic, more long-lived, and all together more dangerous than the chemicals the incinerator was supposed to destroy. Incineration is good at limiting a polluter's liability, but it is not a solution to chemical contamination--it is part of the problem.

There are other ways to destroy organic molecules besides incineration, but they are generally not used because they are expensive. Furthermore, even if we could afford to use more efficient machines for destroying organic molecules, routine spills and leaks during normal handling of large quantities of chemicals would poison the planet sooner or later, so reducing the use of organic chemicals (at least those that are toxic, or are persistent in the environment, or that enter food chains) seems the only real solution. This is what is generally meant by pollution prevention, or toxics use reduction (TUR). What exactly is toxics use reduction? Let us try to say what it is not. (1) Toxics use reduction is not reducing the concentration of toxics. If you have one pound of toxins mixed with one pound of water and you add another pound of water, you have cut the concentration of toxins, but you have done nothing to protect the environment. It is the total quantity of toxins entering the environment that is important, not the concentration. So toxics use reducion will seek to reduce the total mass (amount) of toxins entering the environment, regardless of concentration. (We note that EPA permits issued to polluters describe the allowable levels of pollution as a particular concentration. This reflects the EPA's desire to protect the most exposed individual not the general environment. These permits are a key part of the EPA approach that has allowed the global pollution problem to get entirely out of hand.)

(2) Toxics use reduction is not EPA's recentlyannounced Industrial Toxics Project (ITP). In January, 1991, EPA chief Reilly announced with great fanfare a voluntary "pollution prevention" program. Reilly asked 600 industrial polluters to voluntarily reduce their emissions of 17 toxic chemicals by 33% by 1992 and by 50% by 1995.

This sounds good on paper. However, industry will measure and report its own progress. EPA will not check on the accuracy of the data. Industry reports its emissions of these chemicals each year under the law known as SARA Title III (specifically the part that calls for the Toxics Release Inventory, or TRI). Reporting is known to be inaccurate. In fact, when the Chemical Manufacturers Association asked EPA to allow TRI-reported emission reductions to be applied as a "pollution credit" under the new Clean Air Act, EPA refused, saying that the Clean Air Act was a regulatory program that needs better data than a strictly voluntary program could provide. It seems apparent that Mr. Reilly's ITP will allow industry to claim great progress toward pollution prevention, progress that George Bush will no doubt take credit for during his next election bid. Meanwhile, EPA admits that the data will be flakey, not of suitable quality to form the basis of a regulatory program. This is the lesson we can learn from William Reilly: effective pollution prevention will not be voluntary and it will require careful bookkeeping by proper authorities. One good way to achieve this would be to levy a tax on each pound of pollution, which would put Internal Revenue Service (IRS) into the business of measuring pollution so it could collect the tax. Self-reporting by industry might work, with IRS doing spot checks, if corporate officers could be penalized for lying about emissions as they might for lying about income.

(3) Toxics use reduction is not risk reduction. EPA has managed to define most environmental problems in terms of "risk assessment"--a mathematical procedure based on so many half-baked assumptions that it allows an accomplished risk assessor to reach any conclusion he or she sets out to reach. (See RHWN #194, #195, #204.) Since EPA now defines "pollution" largely in terms of risks as revealed through risk assessments, it seems only logical that the agency will soon start to define "pollution prevention" in terms of reduced risks as revealed by risk assessments. No doubt when Mr. Bush's election campaign is in full swing, EPA will announce that its voluntary emissions-reduction program has achieved a giant reduction in the risks to which the public is subjected, and this will be declared a major victory for pollution prevention. EPA will not have made a single measurement of an actual decline in the amount of any dangerous chemical entering the environment (which is the only true measure of toxics use reduction)--but Mr. Bush will nevertheless declare himself the pollution prevention President. The Bush-Reilly toxics use reduction plan has the important advantage that it will not interfere one whit with the continued poisoning of the planet for profit.
--Peter Montague, Ph.D.

Descriptor terms: global environmental problems; toxic substances; diseases; ozone depletion; global warming; cancers; reproductive disorders; breast milk; mcs; ornl; oak ridge national laboratory; epa; risk assessment; air pollution; water pollution; pollution prevention; cleaning fluids; thallium; mercury; cadmium; chlorine; organic chemicals; perc; pics; incineration; tri; sara; bush administration; regulation; monitoring; voluntary emissions-reduction program;

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