Another observation from the July 29th hearing was the extent to which debate over chemicals managment is circumscribed by the concept of hazard as opposed to risk. The witness testimony, as well as the question/answer exchanges, stressed the need to find “safer chemicals” to replace “toxic, persistent, and/or bioaccumulative chemicals” currently on the market.
However, as any first year toxicology student can attest, “the dose makes the poison.” A chemical demonstrating toxic properties in the laboratory can nonetheless be used with minimum risk provided that exposures are controlled. For example, most of us readily accept the presence of cadmium and other metals in auto batteries because the sealed battery housing, coupled with deposit and recycling programs, minimize the potential for human and environmental exposure.
It would be unfortunate if legislators miss a chance to significantly improve how we manufacture, distribute, use, and dispose of chemicals by continuing to focus on toxicity (in the abstract) as opposed to risk (in real-world context). This is one of a number of areas where a more informed embrace of scientific principles could benefit the final legislative product.
6 comments:
Rich, I understand the value of "risk" determinations that are informed by exposure. As a practical matter, however, would a TSCA oriented toward risk assessment require even more data from chemical producers and processors--including evaluations of use and exposure that they are not in the best position to provide?
This becomes tied in with the discussion of "aggregate" exposures. I'm not sure how this complex array of data can be managed--by the company? By EPA?
Professor, you bring up a critical point. Please see tomorrow's (Thursday's) post on how aggregate and cumulative exposures would be modeled--and by whom.
I'm with a national environmental organization--my friends at TSG will probably figure out which one--but I want to keep these comments personal to me. Please, let's stand up for the priority of inherent safety, i.e., inculcating non-toxicity (human and environmental) at the molecular level. We all know what exposure controls the BP well was designed to have. But technology is by its nature fallible, and it is more responsible to minimize toxic effects at the chemical level than to rely on exposure controls.
In his book "The One Percent Doctrine", Pulitzer Prize winning author Ron Suskind examines the formation of public policy based upon political goals rather than geopolitical realities. The applicable quote was "If there is a 1% chance , then we have to treat it as a certainty (in terms of our response). This has been the topic of many a backyard BBQ since it was formed in 11/2001.
The comparison between "risk and response" (in a singular event scenario) as opposed to "risk and toxicity" (toxicity here in the cumulative sense) are different arguments, and need to be distinguished appropriately.
Pardon my HTML error, using the greater and less than symbols in my last post.
It should read "If there is a greater than 1% chance that Pakistani scientists (give up the goods to) Al Qaeda", then...
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