November 1994 (vol. 11, #1) 1601 N Tucson Blvd
#9, Tucson AZ 85716 c 1994 Physicians for Civil Defense
Mankind, long ravaged by pestilence, madness, impotence, infertility, birth defects, cancer, floods, and droughts, demands explanations and remedies. For several centuries spanning the Renaissance and Reformation, societal risk assessment was based on consensus: witches caused all of these problems, and every witch had to be found and destroyed.
Half a million people were burned at the stake, yet adversity continued. The witch hunters' zeal was unflagging; they demanded more resources. Once they accused a witch, there were no ``stopping rules'' that could terminate an investigation short of a revelation of guilt. The witch had to prove her innocence, a virtually impossible task.
The question was and is: ``Proof or Precaution: When Do We Act?'' Is there proof of guilt? ``If proof is defined as evidence, beyond any doubt, of a cause-effect link,...the answer is no. But this standard of proof will never be fulfilled, because of complex reality....We need a new standard of proof.''
This quotation comes not from the Malleus Maleficarum (The Hammer of the Witches, published in 1486), but from a 1993 Greenpeace report, printed on gray, Soviet-quality, recycled, 100% chlorine-free paper: Chlorine, Human Health, and the Environment: the Breast Cancer Warning. The report continues: ``We should not wait for scientific proof of harm before we take action: the use and discharge of chemicals that MAY cause harm should be avoided'': proof of innocence is required, even if impossible by definition.
The ascendancy of science has not banished disease and death. The incidence of breast cancer has been increasing partly because fewer women give birth at a young age, more women abort a first pregnancy, and more women live long enough to get cancer. Known risk factors account for only 20 to 30% of all breast cancers.
But we have an accusation. The suspect is organochlorines, especially dioxin. (This devilish compound might also cause endometriosis, birth defects, decreased sperm counts, feminization of men and masculinization of women, infertility, learning disability, immune suppression, and even floods and droughts through a link to global climate change). Q.E.D. ``EPA must address all known and suspected sources of dioxin in order to bring future releases of dioxin to zero'' (Greenpeace, Achieving Zero Dioxin: an Emergency Strategy for Dioxin Elimination, July, 1994).
This would mean the virtual elimination of chlorine-based chemistry. It would also mean immediate modification of all combustion device permits (e.g. for smelters and for incinerators of sewage sludge, tires, and hospital wastes). Even food waste would have to be segregated because table salt, when burned, can produce minute quantities of dioxin. Homes are full of products based on chlorine chemistry, such as plastic, and they could burn down. Greenpeace raised this concern but has so far stopped short of demanding the removal of furniture, appliances, cable sheathing, toys, garbage bags, etc., from existing homes.
What are the arguments for declaring an emergency?
1. More organochlorines are being produced. These compounds, which are ``foreign to nature,'' resist breakdown for decades or centuries, according to Greenpeace.
2. Organochlorines accumulate in fat tissue. Increased levels have been found in tumor tissue.
3. In certain animal experiments, organochlorines have been associated with cancer or other adverse effects.
4. Some breast cancers have estrogen receptors, estrogen may cause (or promote) breast cancer, and some organochlorines have estrogen-like effects.
The EPA estimates that a total of 25 kg of dioxin is deposited in the environment annually [an underestimate]. Yes, 25 kilograms, or 55 pounds, though Greenpeace prefers to say 25,000 grams. (For comparison, North Korea is believed to have stockpiled 1,000 tonnes of chemical warfare agents.)
Production of most bioconcentrating organochlorines (such as DDT) was stopped during the 1970s. Since then, the environmental level of these non-immortal agents has dropped by factors of ten or more (Abelson, Science 265:1155, 8/26/94).
It is not possible to reduce production of organochlorines to zero, not even if we stopped starving Rwandan refugees from burning wood. Canadian forest fires alone produce about 60 kg of polychlorinated dioxins each year (ibid.).
Still, Greenpeace urges action as fast as possible. An average adult has already accumulated 40 to 60 parts per trillion of dioxin in his tissues; his pre-industrial counterpart, Greenpeace claims, was ``almost totally free'' of this burden, though exposed to burning wood. [Does Greenpeace have a collection of pre-industrial cadavers? Has it determined how long dioxin persists in cadavers? How low a concentration is detectable?]
As Greenpeace says, certain compounds may be present in higher concentration in tumors than in adjacent normal tissue but this is likely to be an effect, not a cause of the tumor.
While dioxin was associated with more cancers in some experiments, rats receiving 0.001 µg/kg/day had fewer cancers, suggesting a protective effect (Science 265:1507, 9/9/94).
Greenpeace makes a distinction between ``xenoestrogens'' and natural estrogens. These ``foreign'' substances, too weak to suppress hot flashes or prevent conception, are assumed to be more potent carcinogens than human estrogen (itself never proved to cause breast cancer, despite millions of woman-years of experience with prescription drugs).
The early church, skeptical of witchcraft, dealt with individual cases by admonitions or excommunication. Early regulators targeted individual known toxins. Then a collective consciousness watershed occurred the Malleus or its modern equivalent, Rachel Carson's Silent Spring transforming the witch hunt into cohesive social policy, massive in scope, with establishment approval and support.
To banish devilish dioxin, Greenpeace would also purge thousands of other compounds known to be useful and not known to be harmful: mass collective guilt by association.
Few dared to speak against the Inquisition's witch hunt. It finally stopped when Inquisitor Alonso Salazar y Frias changed the rules of evidence: no torture, and no consideration of accusations unsupported by independent evidence (Clark, ``Witches, Floods, and Wonder Drugs,'' in Societal Risk Assessment: How Safe Is Safe Enough?, Plenum).
Will American science follow his example?
The most draconian Greenpeace-inspired measures cannot reduce dioxin production to zero.
And no risk-reduction measure ever reduces risk to zero. ``Regulatory policies designed to reduce specific risks to the public also indirectly create other risks.'' One mechanism is simply by increasing costs. A cost in the range of $5 million to $12 million (1990 dollars), borne collectively by many people, may cause one death by reducing discretionary income that might have been spent for personal risk reduction.
This concept, frequently elaborated in these pages, is gaining respectability (see Ralph Keeney, ``Sounding Board: Decisions about Life-Threatening Risks,'' N Engl J Med 331:193-196, 7/21/94).
The article also notes that the world is actually less risky than it was a generation ago, despite widespread belief to the contrary. ``Life expectancy in the United States has increased despite the scourges of cancer, AIDS, and violent crime.''
The cost of environmental regulation is enormous, but what does that mean in quantitative terms? Edward Denison of the Brookings Institution argued that environmental regulation reduced productivity growth by 0.25% per year. Without such regulation, real output between 1972 and 1991 would have been more than $700 billion higher (Bruce Bartlett, Wall St J, 9/14/94).
At the cost of one life per $12 million lost, ``risk reduc-tion'' cost 58,000 lives. Presumably, other lives were saved. How many? We don't know, and the EPA is under no obliga-tion to make an estimate.
According to a September poll conducted by the Tarrance Group on behalf of The Advancement of Sound Science Coalition (TASSC), 68% of scientists believe that researchers are under more pressure to conduct research to substantiate specific results. The same percentage said that scientific research is used to match pre-determined viewpoints of a government agency, thus making science the tool of a political agenda. The vast majority (83%) agreed that policymakers use science to advance their goals, such as regulation of asbestos, pesticides, and dioxins. And 82% think that the public overreacts to environmental health threats because they do not understand the scientific research (EPA Watch, 10/15/94).
Copies of the survey may be obtained from Katie Dodd at (800)369-6608.
To gain some perspective on the one-molecule hypothesis of cancer causation (and the significance of the Greenpeace ``zero means zero'' war against dioxin), consider Avogadro's number, the number of molecules in one gram-molecular weight (one mole) of any substance: 6 x 1023.
An 8 oz. glass of water (molecular weight = 18, density = 1 gm/cc, 1 cc = 0.034 oz) contains 1.4 x 1026 molecules of water. If a contaminant is present in the very low concentration of one part per billion, there are 1.4 x 1017 molecules of contaminant per glass.
Aflatoxin is one of the most potent human carcinogens known. In Phoenix, the accepted limit in milk is 0.5 ppb and in peanut butter somewhat more. Any food manufacturer adding milk or peanut butter to a product is adding g'zillions of mole-cules of a carcinogen to every serving. This is in direct violation of the Delaney Clause of the Food, Drug, and Cosmetic Act, which states that no human or animal carcinogen can be added to any food in any amount, not even a single molecule.
Because foods contain untold numbers of natural car-cinogens, it is probably unlawful to mix any foods together, or to add anything at all to any food.
Conclusions: (1) The Delaney Clause is absurd. (2) A lot of witches could dance on the head of a pin. (3) Greenpeace has a lot of molecules to worry about.
(Thanks to D.C. Dickson of Phoenix, Arizona)
Chernobyl fallout contained substantial amounts of short-lived isotopes, such as I133, which is more hazardous than the I131 used to treat Graves disease (Nature 371:556, 10/13/94).
These results show the importance of saturating the thyroid with non-radioactive iodine in the event of a Chernobyl-type disaster (see Nuclear War Survival Skills by Cresson Kearny).
Two of the original four Chernobyl reactors continue to operate. (One was knocked out three years ago by a fire.) Ukrainians want to keep the station running; no one is willing to give them enough money to compensate for the loss of $12 billion worth of electricity (Wall St J 10/17/94, p. A8), which could result in the loss of more than 1,000 lives.
American consumers have not felt the full brunt of federal restrictions on CFCs. A thriving black market, reminiscent of the Prohibition Era, has arisen to circumvent a $4.35 excise tax. CFCs such as freon can be made for as little as $.50 per pound, far less than the tax. Industrial nations will be forced to stop production by the end of 1995.
Though CFC substitutes are being manufactured, millions of pounds of CFCs will still be needed for existing equip-ment. Much of the black-market supply is believed to come from Russia, but other likely sources include India, China, and eastern Europe (AP 10/26/94).
``Who is so dense as to maintain...that all their witchcraft and injuries are phantastic and imaginary, when the contrary is evident to the senses of everybody?'' --Malleus Maleficarum