Imagine what our nation's health would look like if this were the policy for industrial chemicals in the U.S. For example, an NRDC report advising a precautionary approach to nanotechnologies compares modern nanomaterials to asbestos, a chemical that was new in the early 20th century. Because of our reckless and widespread use of asbestos in the United States we still have more than one death per hour—approximately 10,000 per year—as a legacy from past and continuing exposure to asbestos. The global death rate is estimated to be 10 times higher.
In April, 2007 a coalition of 11 global unions together representing over 300 million members in more than 150 countries launced a 'zero cancer in the workplace' campaign, noting that "over 600,000 deaths a year – one death every 52 seconds – are caused by occupational cancer, making up almost one-third of all work-related deaths."
Modern scientists with precautionary philosophies are turning back to the lab to re-design the periodic table in a manner that is sustainable, earth-friendly, and safe. Green Chemistry, as it is often called, is a fledgling but growing field of study; these inter-disciplinary scientific visionaries will, I hope, lead us to a future where chemistry and engineering are consistent with a healthy sustainable planet. The US EPA even has Presidential Awards for green chemistry innovations.
But, what do we do with our legacy of toxic industrial chemicals? Once a chemical or substance is determined to be hazardous, then if it is persistent, bioaccumulative, or highly toxic it should not be commercialized, and all health and safety information should be fully disclosed to workers, communities, and regulators.
We cannot turn back the clock, but we can move forward with more 'smarts'.
]]>Although the court awarded the injured parties much less in punitive damages than they had sought, the justices buried something very interesting in Footnote 17 on their decision.
In the footnote, part of Justice Souter’s majority opinion, the Court offered a short commentary, "The Court is aware of a body of literature running parallel to anecdotal reports, examining the predictability of punitive awards by conducting numerous 'mock juries' where different 'jurors' are confronted with the same hypothetical case...Because this research was funded in part by Exxon, we decline to rely on it."
In its footnote, the majority seems to recognize that industry-funded science is likely to be biased, and should be viewed with reasonable skepticism, if not rejected outright for consideration in judging a matter for which the funding industry has a financial or interest.
The Court’s thinking on this matter deserves consideration from the editors of scientific and policy journals, as well as federal and state regulators.
Misrepresentation or bias has been documented for industry-supported research on many hazardous industrial chemicals, including the low-dose effects of the plasticizer bisphenol A, tobacco-supported research on the health hazards of secondhand tobacco smoke, butadiene carcinogenicity, vinyl chloride carcinogenicity, perchlorate toxicity, and atrazine toxicity.
The International Agency for Research on Cancer, the premiere chemical evaluation program of the World Health Organization, acknowledges that, “a difficulty arises when an expert with relevant knowledge and experience has a real or apparent conflict of interest. This issue has become more visible in recent years, as commercial interests sponsor many epidemiological and experimental studies and some investigators develop a history of receiving research support from interested parties.”
What is the solution? At a minimum, scientific journals must enforce rigorous policies for public disclosure of conflicts, both financial and personal, for authors, peer reviewers, news writers, and even editors. The details of a best practices policy may vary by journal, but the critical elements must include disclosure of conflicts to editors and to the public.
NRDC will be hosting a workshop next week (July 12) of scientific journal editors, journal staff, scientists, and academics to develop a multi-stakeholder consensus on the critical elements of a best practices disclosure policy, with the hope that journals will adopt these elements without delay.
Instead of rejecting some science based on its source, the public interest is best served by scientific journals that enforce a rigorous policy of public disclosure. Editors should take all means necessary to protect the journal's objectivity, integrity, independence, and competence as its most valuable assets.
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Although the presence of the endosulfan is not responsible for the tragic deaths, one has to ask why endosulfan was even on the passenger ferry, since it had previously been banned for use in the Philippines. Endosulfan is highly toxic, persistent in the environment, and bioaccumulative in human and animal tissues. Some in the Philippines are asking why the ban has been lifted. Senator Pia Cayetano, the Chair of the Philippine Senate’s Committee on Environment and Natural Resources Committee according to the Manila Times said: "the Fertilizer and Pesticides Authority (FPA) should explain why it had lifted the ban on endosulfan, a highly toxic chemical ... banned in many countries, including the Philippines,” The Senator further noted that, “Its hazardous effects on human and the environment have been thoroughly documented and established by experts.”
Some manufacturers including FMC and Bayer CropScience are finally doing the right thing by cancelling their registration and getting out of the endosulfan business. A media release from FMC in 2002 announced that although it had sold the chemical for over 40 years, it was selling all EPA registrations and formulations to the Makhteshim Agan Group (MANA), and Israel-based company.
What kind of business ethics must a company have to pick up the registration of a chemical that is so toxic it is being dumped by other companies, and is subject to calls for a global ban?
In this blog I have reported on a petition to the US government for a ban on endosulfan from NRDC and over fifty-five prominent international scientists, medical doctors, nurses, and other health professionals. I have also reported on a ban-endosulfan petition originating with unions and worker protection advocates worldwide. And, I have reported on workers and activists in India being threatened with jail for calling for a ban on endosulfan in their country, where workers are poisoned and even killed from exposure to this very toxic pesticide.
While the campaign to ban the use of endosulfan continues worldwide, countries and their residents have the right to know what dangerous chemical substances are entering their borders. That is why endosulfan should be listed in the Rotterdam Convention at the upcoming decision in October of this year, which would force exporters to notify potential purchasers that endosulfan has been banned in many countries, called Prior Informed Consent.
We need to continue to press for global chemical policies that protect consumers, workers, wildlife and the environment from dangerous and unnecessary products like endosulfan. Expanding the publics’ right to know about what, where, and how chemicals are being used, as well as which ones are banned in other countries, are a cornerstone of a sound environmental and public health policy.
Meanwhile, companies that market chemicals that are highly toxic and persist in the environment must be forced to stop their deadly profiteering.
Colony collapse disorder (CCD) is devastating our bees. Anything that has its own name and acronym is serious! CCD describes the estimate loss of approximately 40% of the nation's bee colonies! No one understands exactly what causes CCD, and it's probably a combination of things: disease, viruses, weakened immune system, and toxic pesticides are all likely contributers.
These little plump creatures provide an essential service, asking only for a little consideration in return. The NRDC bee experts suggest the following considerations:
Private initiatives are helping a lot! Haagen Dazs is throwing $250,000 to the problem through its new ice cream flavor, Honey Bee Vanilla. Burt’s Bees natural personal care products donated $32,000 and the National Honey Board $13,000.
What can you do? Check out our NRDC website for more info and ideas you can try at home, including establishing a hive in your yard. And, for more bee information, check out this story in the NRDC magazine, On Earth.
]]>REACH loophole #1: There is no clear guidance for how to evaluate nanomaterials under REACH. ETUC calls for the "no data, no market" principle of REACH to apply to nanomaterials, and we agree!
REACH loophole #2: Materials manufactured or imported under 1 metric tonne per year don't need to be registered under REACH. Yeow! Many nanomaterials will fall through this hole because of their incredibly miniscule mass. Without registration requirements, no safety data would be required. ETUC calls for closure of this loophole, and we agree!
REACH loophole #3: Materials manufactured or imported under 10 metric tonnes per year aren't required to provide a chemical safety report. This means no safety data, no risk assessment, and where risk is identified there would be no requirements for risk management measures. ETUC says all nanomaterials registered under REACH should be accompanied by a chemical safety report, and, guess what? We agree!
In addition, ETUC calls for more health and safety research of nanomaterials, and more workplace protections. See the full ETUC proposal on their website. Go ETUC!
Back in the good ole' U.S. of A. we are still trying to get our government to regulate any toxic chemical in a precautionary manner. When will we get a, "no data, no market" approach to chemicals? Soon, I hope!
]]>NRDC summarized the findings of five different research groups that since 2004 have reported that single-walled carbon nanotubes (SWCNTs) cause lung damage in test rodents, including dose-dependent rapid lung inflammation, rapid progressive fibrosis, and granulomas.
Carbon nanotubes are atom-thick sheets of graphite formed into cylinders. They may be formed from a single layer of graphite or they may consist of multiple concentric layers of graphite, resulting in multi-walled carbon nanotubes. They are estimated to be 100-times stronger and six-times lighter than steel, making them useful to strenthen building materials. Already they are found in many consumer products including super-strong tennis rackets, hockey sticks, racing bike frames, car parts, and golf clubs.
The ropelike filaments of carbon nanotubes are long, thin, and insoluble; these qualities are associated with the cancer-causing effects of asbestos and other deadly fibers.
In the trade press (Nanowerk), Donaldson is quoted as saying that, " "The results were clear ...Long, thin carbon nanotubes showed the same effects as long, thin asbestos fibers."
The website of the Woodrow Wilson Center Project on Emerging Nanotechnologies notes that "widespread exposure to asbestos has been described as the worst occupational health disaster in U.S. history and the cost of asbestos-related disease is expected to exceed $200 billion, according to major U.S. think tank RAND Corporation."
But, dollars don't tell the human toll. NRDC reports that in the United States, we still have more than one death per hour—approximately 10,000 per year—as a legacy from past and continuing exposure to asbestos. The global death rate is estimated to be 10 times higher.
Today's study authors report their results thus: "Here we show that exposing the mesothelial lining of the body cavity of mice, as a surrogate for the mesothelial lining of the chest cavity, to long multiwalled carbon nanotubes results in asbestos-like, length-dependent, pathogenic behaviour. This includes inflammation and the formation of lesions known as granulomas. This is of considerable importance, because research and business communities continue to invest heavily in carbon nanotubes for a wide range of products under the assumption that they are no more hazardous than graphite. Our results suggest the need for further research and great caution before introducing such products into the market if long-term harm is to be avoided."
Recklessly exposing workers and the general population to deadly chemicals is neither humane nor civilized. Our society can do better this time around. Regulators must step in and prevent nanomaterials from being used in ways that may result in human exposure or environmental releases until they are safety tested and regulated.
]]>In a letter sent today to USDA Secretary Schafer and signed by 45 prominent public interest groups including Sierra Club, Greenpeace, Health Care Without Harm, and Consumers Union, the coalition argued that the NASS’s Agricultural Chemical Usage reports are the only reliable, publicly available source of data on pesticide and fertilizer use outside of California.
Elimination of this program will severely hamper the efforts of the USDA, the Environmental Protection Agency (EPA), land grant scientists, and state officials to perform pesticide risk assessments and make informed policy decisions on pesticide use. In particular, USDA and EPA will have difficulty tracking their progress in meeting their policy commitments to reduce the use of hazardous pesticides through adoption of Integrated Pest Management (IPM) practices and to support IPM research
NASS has regularly collected and published agricultural chemical use data since at least 1991 but has dramatically scaled back its program in recent years. First, the agency replaced its annual surveys of major field crops with biennial ones. Then, in the 2007 growing season, data collection was limited to just three crops—cotton, apples and organic apples. Now, NASS has taken the most drastic step—announcing that it will not collect agricultural chemical use data on any crops during the 2008 growing season.
The coalition letter was released today, the day before the U.S. Department of Agriculture (USDA) releases its scaled-back annual report on 2007 pesticide use in American agriculture, a coalition of 44 environmental, sustainable farming, and health advocacy organizations called on USDA to reverse its plan to eliminate its pesticide reporting program in 2008.
Elimination of USDA’s objective data will open the door wide to serious misinformation on pesticide use, charge the groups.
]]>The following is excerpted from website reports by the above groups:
Many cases of endosulfan-related poisoning, including fatalities, have been reported - in Benin, Colombia, Costa Rica, Cuba, Guatemala, India, Indonesia, Malaysia, Philippines, South Africa, Sri Lanka, Sudan, Turkey, and USA. It is one of the main causative agents of acute poisoning in Central America, in southern India and other areas.Endosulfan has caused congenital birth defects, reproductive health problems, cancers, loss of immunity, neurological and neurobehavioural problems amongst villagers in Kerala (India) who were exposed to 26 years of aerial endosulfan spraying on neighbouring cashew nut plantations.
Endosulfan may be the most important source of fatal poisoning among West Africa’s cotton farmers. In Benin’s cotton industry, endosulfan caused 400 accidental poisonings, including 53 deaths, between 2000 and 2003 - 69% of all pesticide poisonings. In a single province in Benin, at least 37 people died from endosulfan poisoning in just one season.
In 2007, the US Environmental Protection Agency (EPA) warned that “Occupational assessment for endosulfan indicates short- and intermediate-term risks for mixers, loaders, and applicators for the majority of uses, even with maximum Personal Protective Equipment (PPE) and engineering controls.”
From October 13-17, 2008 the POPs Review Committee will be meeting in Geneva to assess the potential to include endosulfan under the Convention on Persistent Organic Pollutants. An affirmative response from the Review Committee would trigger consideration at the political level leading to the potential global elimination of endosulfan in 2009.
Following this, from October 27-31, 2008 the Conference of the Parties to the Rotterdam Convention (PIC CoP4) will convene in Rome to decide on the inclusion of endosulfan in Annex III.
The above groups point out that this represents an unprecedented opportunity to press the international community to impose greater safeguards on the sale and distribution of endosulfan.
]]>Dr. Devra Davis, Director of the Center for Environmental Oncology, University of Pittsburgh Cancer Institute, and author of When Smoke Ran Like Water and the recently released new book, The Secret History of the War on Cancer, is also supporting a ban on endosulfan.
Dr. Philip J. Landrigan, a pediatrician and Director of the Center for Children’s Health and the Environment at the Mount Sinai School of Medicine in New York City is another of the many scientists supporting a ban on endosulfan.
These and many more public health experts all agree that it is time to say no, loud and clear, to this dangerous pesticide.
Endosulfan is a persistent, bioaccumulative, highly toxic pesticide. On that description alone it should be banned. In fact, the European Union and 20 other countries have already banned endosulfan. But, here in the U.S. about 1.4 million pounds of the chemical are used each year, primarily on cotton, cantaloupe, tomatoes, and potatoes according to data from the U.S. Environmental Protection Agency (EPA).
NRDC petitioned the EPA back in February to ban this 1950's hazardous pesticide.
In a parallel effort, a large coalition of public interest groups sent a letter today to EPA with the same message.
These efforts were joined by Arctic tribal governments and Indigenous groups that sent their own letter highlighting the specific risks to Arctic human and wildlife populations from the atmospheric transport of endosulfan to Arctic regions distant from use areas. Residues of endosulfan have been detected in multiple human tissues including blood, fetal placenta, breast milk, and breast fat tissue of Arctic populations.
And, back in February the Pesticide Action Network North America submitted a letter to EPA signed by over 13,000 citizens supporting a ban.
On Thursday of this week, NRDC scientists and lawyers will join with Indigenous groups, environmental health experts, and worker protection advocates in a meeting with EPA officials to voice our strong and unwaivering opposition to endosulfan.
Endosulfan is toxic to the nervous system and hormone systems. Health effects associated with endosulfan over-exposure include nausea, dizziness, convulsions in high doses, and death in extreme cases. Data from animal studies indicates it may damage the liver, kidneys, and testes. Severe affects, including birth defects and deaths, have been reported among workers and community residents in areas of India where endosulfan is routinely used.
Endosulfan's chemical cousins, the cyclodiene-like pesticides, have been either cancelled (toxaphene, mirex, kepone, dieldrin, aldrin, chlordane) or severely restricted (heptachlor) due to their hazardous nature. Yet, here in the U.S. endosulfan has been registered for use since the mid-1950s.
A editorial published this week by Jerold Schnoor, the editor of Environmental Science & Technology, called EPA "an Agency in crisis" that has abdicated its role as a protector of human health and the environment. Endosulfan could be added to the list of failures provided in the editorial.
EPA political appointees need to take a step back and let the science lead the way to health-protective regulations. Endosulfan is old-school chemistry and its time is up.
]]>Today the U.S. Senate Committee on Environment and Public Works will host oversight hearings on EPA Toxic Chemical Policies. Discussions will include new revisions that will delay and weaken the process EPA uses to update the Integrated Risk Information System (IRIS), which provides human health risk information on more than 540 environmental contaminants. NRDC and Environmental Defense Fund (EDF) jointly submitted a letter highly critical of these new procedures.
Also today, the independent investigation arm of Congress, the US Government Accountability Office (GAO), released the results of its investigation of the IRIS process. The report's findings confirm our fears; the new procedures are likely to gum up the ability of the IRIS program to complete robust credible chemical assessments. The GAO report notes that, "although EPA sent 32 draft assessments for external review in fiscal years 2006 and 2007, the agency finalized only 4 IRIS assessments during this time", and lists the first reason for this delay as, "new [Office of Management and Budget; OMB]-required reviews of IRIS assessments by OMB and other federal agencies".
The new procedures introduce an additional three opportunities for other federal agencies and the Office of Management and Budget to weigh-in on chemicals determined to be “mission critical,” bringing their total number of intervention points from one to four. We are very concerned that the new process will introduce delays, derail assessments, and institutionalize the growing influence of federal agencies such as the Department of Defense, Department of Energy, that are among the biggest contributors to toxic Superfund sites, as well as hundreds of additional contaminated counties across the country. These agencies have a clear interest in the development of risk assessments that lead to less protective environmental standards.
EPA assessments of regulated chemicals are publicly available on its IRIS database which contains EPA scientific consensus positions on potential human health effects from environmental contaminants. Although not a legal standard, the information from IRIS assessments is used by federal, state, and tribal regulators throughout the US and worldwide, in combination with exposure data, to set limits on toxic chemical releases and set cleanup standards for hazardous waste sites. The IRIS numerical values directly affect the safety of the water we drink, the air we breathe, and the soil that underlies our homes, schools, businesses, and parks.
The global importance of IRIS assessments is demonstrated by the fact that for the month of April 2008 the database website received on average approximately 600 requests daily from all over the world.
In our letter, NRDC and EDF push EPA to abandon these proposed changes and instead provide sufficient resources for the IRIS program to conduct rigorous, independent, and timely assessments of chemicals that impact human health and the environment, including chemical pollutants of the Federal agencies such as the Department of Defense and Department of Energy.
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Some elements from my testimony below:
Compounds such as nicotine, caffeine, and aspirin that are designed to influence our body’s normal chemistry have been identified as environmental contaminants since the 1980s, moving from sewage and human waste into waterways. As our use of pharmaceuticals increases, it is logical to expect them to turn up in our environment. Although the levels reported to contaminate our waterways are much lower than therapeutic doses, it would be naïve to think of this as ‘safe’, knowing that the agents are chemically reactive in our bodies, and that we are exposed daily over a life-time to multiple compounds in unknown combinations.
When a medical professional prescribes a drug, they are considering the patient’s health status, age, gender, nutritional status, and any other drugs that may cross-react. For example, a pregnant woman would not knowingly expose her fetus to chemicals that cause birth defects such as anti-seizure drugs. A doctor would not knowingly prescribe toxic chemotherapy agents to a healthy person. Yet, all these things and more are in our Nation’s drinking water. The Associated Press reported that pharmaceutical residues were detected in the drinking water of 24 major metropolitan areas across the country serving 41 million people. Detected drugs included antibiotics, anti-convulsants, and mood stabilizer drugs. These results were supported by findings of the U.S. Geological Survey that reported organic wastewater contaminants and pharmaceuticals in 80% of sampled streams- including antibiotics, hypertensive and cholesterol-lowering drugs, antidepressants, analgesics, steroids, caffeine, and reproductive hormones.
Pharmaceuticals and personal care products (PPCPs) may end up in the environment through waste from human or animal excretion, improper disposal such as flushing down a toilet, runoff from animal feeding operations, or leaching from municipal landfills. However they get there, they are contaminating our waterways and tap water systems.
Large animal feeding operations generate a large amount of antibiotic-contaminated waste that contaminates waterways and contributes to antibiotic resistant pathogens. Because many of the same antibiotics are used in both human and veterinary medicine, almost every bacteria that can cause infections in humans has developed resistance to at least one antibiotic, and some are resistant to multiple antibiotics. This means that when a person gets sick, the antibiotic that the health care provider may reach for, may not work. To tackle this problem, Environmental Defense Fund, American Academy of Pediatrics, and other health advocates petitioned the Food and Drug Administration in 2005 to prevent the use of important human antibiotics to be used in agriculture, so as to limit the risk of developing resistent pathogens that could infect humans.
The traditional toxicology dogma has been “the dose makes the poison” but when considering the toxicity from exposures to endocrine disrupting chemicals, the timing of exposure maybe more important than the dose. Exposures to endocrine disrupting chemicals during critical windows of development have been shown to have permanent effects such as infertility or cancer that may not arise until adulthood even though the exposure occurred during fetal or neonatal life. Yet, pharmaceuticals that mimic estrogen are excreted as waste by-products from the use of birth-control pills, menopause treatments, and cancer therapy.
In addition to human uses, endocrine disrupting steroids used in livestock operations contribute to widespread environmental contamination. Research by the US Geological Survey reported a high incidence of intersex fish in the Potomac watershed associated with sites of intense farming and high human population density; 75% of male smallmouth bass in the most densely populated heavily farmed Potomac basin had eggs in their testicles.
Despite the various safeguards and processes that EPA could have taken to develop a robust picture of the scope of the problem, the Agency has taken advantage of none of them.
The Safe Drinking Water Act requires EPA every five years to publish a list of currently unregulated contaminants that should be considered for potential regulation. For these lists EPA has identified 130 potential chemicals for regulation – none of which are pharmaceuticals or personal care products.
In 1999 EPA promulgated an unregulated contaminant monitoring rule that imposed various monitoring requirements on community water systems for a list of unregulated contaminants; there are no pharmaceuticals or personal care products identified for which water systems must monitor and report results to their customers.
The Safe Drinking Water Act requires community water systems to mail to each of their customers an annual report on the level of contaminants in the drinking water that they supply; there are no mandates to inform customers when pharmaceutical or personal care products are identified.
Congress mandated that EPA must address endocrine disrupting chemicals in drinking water; it has now been 12 years since this mandate and the Endocrine Disruptor Screening Program has failed to even start testing chemical contaminants.
The proposed FY09 funding for the USGS Toxics Program reflects a nearly $3 M cut; this will significantly reduce research capacity on new and understudied environmental contaminants, including pharmaceuticals and personal care products.
In addition to rectifying the above failures of EPA, some additional elements of a solution may include reducing the unnecessary prophylactic uses of antibiotics and steroid hormones in agriculture, and excessive uses in humans, to tackle the problem at its source. There is no question that we will also need to invest in our waste water and drinking water infrastructure, and to monitor and treat for the chemical contaminants that present the biggest health risks, and that can be removed or reduced using cost-effective methods.
Bottom line: our tap water is the still the safest choice of drinking water available, but this problem won't fix itself.
]]>The coalition included the Environmental Working Group (EWG) that had originally documented and publicized this story, the Center for Science in the Public Interest, Union of Concerned Scientists, Public Employees for Environmental Responsibility, the Institute for Agriculture and Trade Policy, and the Executive Vice President of the National Treasury Employees Union Chapter 280 that represents EPA professional staff.
Dr. Rice was an external peer reviewer of the EPA human health assessment for the polybrominated diphenyl ethers (PBDEs), a toxic class of chemicals that includes deca-BDE.
Today, Rep. John D. Dingell (D-MI), the Chairman of the Committee on Energy and Commerce, and Bart Stupak (D-MI), the Chairman of the Oversight and Investigations Subcommittee requested that EPA provide all its records relating to Rice's dismissal.
“The public depends on EPA peer review panels to help ensure the products they use every day are safe,” Dingell said in the media release. “The EPA seems to have a backwards way of composing these panels. EPA is disallowing scientists who have valid public health concerns about products, while encouraging participation by so-called experts who are paid by the chemical industry.”
“Dr. Rice’s dismissal from an EPA external peer review board at industry's request raises serious concerns about EPA’s scientific integrity,” Stupak said in the same media release. “External peer review boards are a valuable tool, but only if they are free from conflicts of interest. Thorough reviews by unbiased outside experts are critical to protecting the public’s health before new chemicals are placed on the market.”
PBDEs are brominated organic compounds. Global production of these chemicals is approximately 40,000 tons per year for use as fire retardants in plastics and textiles. These chemicals are environmentally persistent and are known to bioaccumulate. The EPA website says "environmental monitoring programs in Europe, Asia, North America, and the Arctic have found traces of several PBDEs in human breast milk, fish, aquatic birds, and elsewhere in the environment."
The effects of greatest concern to date are endocrine disruption effects and adverse effects on neurological development from early life exposures. Deca-BDE has been banned in Washington State and Maine.
As revealed and documented in the report by EWG, at the time Dr. Rice was removed from the expert review she had already completed her service to the EPA and had already submitted her comments on the assessment. Thanks to the investigations of the Environmental Working Group, many of the letters between the EPA and the PBDE industry are now publicly accessible on the EWG website, along with other helpful information.
Tellingly, the EPA action to remove Dr. Rice followed a letter to EPA from the American Chemistry Council’s Brominated Flame Retardant Industry Panel (BFRIP). The BFRIP letter illogically argues that Dr. Rice’s scientific publications should be seen as a ‘bias’, rather than evidence of her expertise. The chemical industry further questioned Dr. Rice’s impartiality by wrongly claiming that her testimony before the Maine legislature earlier in 2007 advocated a state phase-out of deca-BDE. In fact, Dr. Rice’s testimony was of a purely scientific nature. Dr. Rice testified on available alternatives to deca-BDE in her official capacity as a scientific expert employed by the Maine Center for Disease Control and Prevention.
Dr. Rice has no financial conflicts, and was never accused of that by the industry. Thus, she should never have been removed from the panel, according to the relevant EPA policies.
The industry letter specifically requested that Rice’s data, opinions, and conclusions not be considered by the Agency. In response to the ACC letter, EPA scrubbed every reference to Dr. Rice out of the final report, an action that as far as I know is unprecedented, and unnecessary since EPA is under no obligation to incorporate all the advice from any of its experts.
In stark contrast to EPA’s removal of a renowned and well-respected scientist who is free of financial conflicts, the Agency selected and retained Richard J. Bull of MoBull Consulting as a peer reviewer for the same assessment.
In 2004, Richard Bull had to resign from a National Academies committee after he failed to disclose industry ties as required by the law. NRDC met with the committee staff and produced paystubs from Lockheed Martin to Bull as evidence of these unacknowledged conflicts. Senators Boxer and Feinstein followed with a letter to the National Academies staff raising concern about Bull and the impartiality of the perchlorate committee. Finally, the National Academies asked Bull to resign from the committee.
The actions taken by EPA against Dr. Rice call into question the credibility of EPA management. The EPA is a publicly-funded regulatory Agency charged with protecting human health and the environment. When it allows itself to serve the interests of the polluting industries that it is charged with regulating, it has perverted its mission, compromised its credibility, and forsaken its mission.
The EWG report and the coalition letter requests that EPA immediately:
Anything less will compromise the ability of EPA to carry out its mission to protect human health and the environment.
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The action taken against ATEN is a very interesting case because silver is already a registered pesticide and antimicrobial agent. But, here EPA is going after the nanosilver ions. In September, 2007 the EPA issued a public notice that, "ion generators that incorporate a substance (e.g., silver or copper) ... for the purpose of preventing, destroying, repelling, or mitigating a pest (e.g., bacteria or algae)...are considered pesticides for purposes of FIFRA, and must be registered prior to sale or distribution." The notice further said that all products must apply to EPA for registration by March 21, 2008, if they want to continue to sell after that date.
EPA tells me that so far no companies have voluntarily come knocking on the EPA door to register their nanosilver-containing products. Instead, savvy companies are removing advertising claims that the product has pesticidal activity. For example, today the website for FresherLonger Miracle Food Storage containers by SharperImage now vaguely advertise a " Patent-pending silicone-gasket locking system" with no mention of nano anything. However, using the internet archive website wayback machine we can see that the same website in April of 2006 clearly bragged that its, "Patent-pending antimicrobial silver nanoparticles infused into the containers reduce growth of mold and fungus". And, the tab to more information on the archived website is very specific about its use of nanosilver, even saying, "Created by advanced nanotechnology ("nano" indicating one billionth), these silver nanoparticles average only about 25nm (nanometers) in diameter — 25 billionths of a meter; one 200 thousandth of a human hair. Their natural color gives FresherLonger Miracle Food Storage containers their distinctive golden hue."
The SharperImage is but one example of a manufacturer ducking its legal obligations to register its nanosilver products by removing claims of pesticidal activity from its advertising. NRDC has brought this to the attention of EPA, and will continue to do so until something is done about it.
Well over 100 consumer products claim to use nanosilver, according to the searchable Wilson Center database. The problem is that nanosilver, like silver, kills indescriminately. Both harmful and beneficial microbes are victims. The advantage, or disadvantage, of the nanoscale version is that it is much more toxic, more potent, than regular silver.
According to the Nanowerk News report, the IOGEAR products at issue were: wireless laser mouse with nano shield coating, laser travel mouse with nano coating technology, and wireless RF keyboard and mouse combinations. After being contacted by EPA, IOGEAR stopped making claims that their computer peripherals protect against germs, according to Nanowerk News.
You can run, but you cannot hide! Removing references to nanosilver without removing nanosilver isn't good enough for NRDC! And, hopefully it's not good enough for EPA and our other federal agencies charged with protecting human health and the enviroment.
]]>An August 2007 report by Friends of the Earth has more information on nanoparticles and sunscreens.
Many sunscreens contain nanoparticles of zinc or aluminum. At normal scale they are effective sunblockers, and at nanoscale they have the added cosmetic benefit of making the sunscreen more fluid and transparent instead of white. Is it worth the potential risk? I'll take my sunscreen thick and white, please.
Engineered nanoparticles are also in deodorants, toothpastes, shampoos, anti-aging creams, and nail polish....though labeling is not mandatory so the consumer is largely uninformed. In addition to the word 'nano', look for words like 'pulverized' or 'micronized' as a hint that the product may contain nanoparticles. Call the manufacturer if you are not sure...and, let me know what they say!
For more insight into the EU scientific committee's report, check out this post over at EDF's "Nanotechnology Notes" blog.
]]>The concept of clean production is developing sustainable, non-toxic solutions. This may mean using a safe chemical to replace a hazardous one. Or, it may mean using a different production process so that chemicals are not necessary. Or, it may even mean asking if we even need that stuff.
It’s a cradle- to-cradle design of stuff, instead of the -cradle-to-grave cycle that ends in landfills and waste dump sites. It’s fully reusable non-toxic carpets, its buildings in the desert that use the cool night air instead of air conditioning, its neighborhood designs that moves rainwater to lawns and gardens instead of streets and sewer systems, its using non-toxic chemicals from nature instead of laboratories.
The US EPA website on green chemistry says, “Green chemistry, also known as sustainable chemistry, refers to environmentally friendly chemicals and processes that result in: reduced waste, eliminating costly end-of-the-pipe treatments; safer products; and reduced use of energy and resources—all improving the competitiveness of chemical manufacturers and their customers.”
Using safe chemicals and safe industrial processes should also make good business sense. After all, if a company isn’t likely to explode, poison its workers, or leach toxic effluent into local waterways, then its regulatory burdens are reduced, its liability is reduced, and its costs of emissions controls and worker protections are reduced.
For example, lead in paints were restricted in 1971 (thanks, Prez Nixon) and banned in 1972 (after an unsuccessful court challenge by the lead industry), but the paint industry had already begun to phase it out in the 1940’s, not for health reasons (although its deadly health impacts were known in the 1930’s), but because leaded paint required more mixing and so ready-to-use paints using zinc and titanium pigments instead were being developed. In other words, lead, a very nasty toxic chemical that affects the brain, kidney, bones, blood, and even sperm, came out of paint partly because a safer replacement was also a better business choice.
Tragically, it took much longer to get tetraethyl lead out of gasoline. It was used as an additive because it increased the octane level and worked as an anti-knock agent, allowing the development of more powerful combustion engines. By 1959, 15% of the lead used in the US was for gasoline, resulting in thousands of tons of lead in our air, soil, water, and bodies. EPA proposed to ban leaded gasoline in 1972, but because of repeated challenges by the industry it took until 1995 when Congress outlawed it. Fortunately, by that time it had already largely been removed from gasoline, in large part because it interfered with the catalytic converters that were becoming increasingly popular to increase engine efficiency and reduce toxic emissions. Thus, it was a good business decision to let newer, cleaner technology drive lead out of gasoline.
Of course, this came far too late for the poor tetraethyl-lead workers that in 1924 gave DuPont’s famous “House of Butterflies” its name when it was publicized that the workers went crazy, seeming to grasp at invisible butterflies in the air, before dying of extreme lead poisoning. And, it came too late for the children that were poisoned by lead from gasoline; researchers estimate that the average reduction of 2.2-4.7 IQ points from lead poisoning has resulted in $100-300 billion dollars in lost productivity for the US economy. In other words, it makes good business sense to not poison our population with toxic chemicals.
Maybe DuPont’s old 1935 adage, “Better Things for Better living…Through Chemistry” could one day be true. What do you think about sustainable green chemistry?
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