NADD - An association for persons with developmental disabilities and mental health needs

From the NADD Bulletin Volume XII Number 4

The Responsibility Gap in Chemical Management

Steven G. Gilbert, Ph.D., DABT, Institute of Neurotoxicology & Neurological Disorders

Books discussed in this article:

Doubt Is Their Product - How Industry's Assault on Science Threatens Your Health

By David Michaels

Oxford University Press, 2008. 327 pp.

ISBN: 978-0-19-530067-3

Exposed - The Toxic Chemistry of Everyday Products and What's at Stake for American Power

By Mark Schapiro

Chelsea Green Publishing, 2007. 216 pp.

ISBN: 978-1-933392-15-8

We are exposed to an array of unnecessary and potentially harmful chemicals from the moment of conception, through gestation, childhood, and during adulthood. Exposure to these chemicals occurs at home, at school, and at work, from the food we eat, the air we breath, and the water we drink ultimately over our entire life. We are exposed to ancient hazards, such lead, mercury, and arsenic, as well as to an alphabet soup of manufactured chemicals such as PCBs, dioxins, DDT, PBDEs, BPA, phthalates, insecticides, herbicides, and others. These chemicals are present in cosmetics, toys, household dust, plastics, shower curtains, car interiors, and even our food. Scientists have demonstrated that many of the chemicals in our products and chemical contaminates in our environment can cause learning disabilities and neurodevelopmental disorders (Gilbert, 2007). Who is responsible for ensuring that these chemicals do not cause harm? Two recent books provide some interesting contributions to the discussion about who is responsible for the chemicals in our environment.

Exposed, by Mark Schapiro, provides an easy to read and well-documented view of the ways we are exposed to some of these manufactured chemicals. For example, he addresses exposures to chemicals from cosmetics and personnel care products. Schapiro points out that the Food and Drug Administration (FDA) has little authority to regulate ingredients used in cosmetics; in fact, industry is not even required to list all the ingredients in their cosmetics products. In contrast, the European Union has a more rigorous product-testing program and has developed a list of chemicals banned from personal care products.

Shapiro also examines phthalates, a common chemical used to soften plastics. It is often used in soft plastic toys and books. In addition, phthalates are widely used in cosmetics and personal care products, including baby lotions. Use of these products can result in detectible levels of phthalate metabolites in the urine. The health effect from the body burden of phthalates has not been well studied, particularly in children.

A recurrent theme of Exposed is the lack of an effective chemical use policy in the United States. In contrast, the European Union has adopted a chemical use policy that requires industry to provide data on the safety of widely used chemicals. This program, called REACH, Registration Evaluation and Authorization of Chemical, is based on the precautionary principle (Gilbert, 2005). A key element of the European policy approach is that it requires that those who benefit from the sale of a chemical take responsibility for its safety. This is in contrast the US Environmental Protection Agency (EPA), which implements the current US chemical use laws (Toxic Substance Control Act); the EPA requires relatively little data from manufacturers on the safety of a chemical before the product is widely distributed. In the US there is precedent for a more precautionary approach for the use of potentially hazardous materials and this can be found at the FDA. The US FDA takes a precautionary approach when approving new medicines by requiring companies to provide sufficient data on the effectiveness and safety of their products prior to their distribution. The FDA performs extensive evaluation of the new medicine and requires the manufacture to advise users on potential hazards. The same could be done for chemicals we are exposed to from the products we use on a daily basis.

David Michaels in his book, Doubt Is Their Product, explores how companies often manufacture uncertainty about the potential adverse health effects of a chemical. One reason to do this is to delay or weaken government regulations and to keep potentially problematic chemicals on the market until there is public outcry or a mountain of evidence of adverse health effects. One example can be found in the ways the tobacco industry used industry-funded research and limited release of data to create uncertainty around the adverse health effects of tobacco products. This process was repeated with second hand tobacco smoke but has gradually failed with the recognition of the significant public health benefits of restricting smoking in public spaces.

Michaels's book is extensively referenced and provides examples of industry efforts to ensure profitability of their product, often at the expense of workers and taxpayers. In fact, corporate executives are there to do two things: 1) increase revenues by selling more product and 2) externalize or minimize costs. The tobacco industry externalized the lung cancer and cardiovascular health cost of smoking on to the tax payers while taking the profits for the executives and shareholders. There are also numerous examples where industry has taken advantage of workers by not informing them of potential health effects, for example, that asbestos causes lung disease and potentially cancer. Industry has repeatedly demonstrated a failure to take responsibility for the health effects of their products.

The scientific method is an easy target for exploiting uncertainty. The goal of science is to ask questions and describe the results of that exploration in terms of the probability that the discovery occurred by chance. Science is in the business of exploring and describing uncertainty. Michaels documents how industry misused the scientific method to confuse the legal and regulatory process demanding absolute proof and certainty, often ignoring scientific consensus of research findings. This strategy has had disastrous consequences for the health of the public, for the health of individuals, and for the environment.

One example is the efforts of US industry to forestall the reduction or elimination of lead in consumer products. In the 1920s the European League of Nations banned the use of lead in paint in Europe; however, due to industry pressure the US did not ban the use of lead in paint until 1978. Millions of homes in the US continued to use lead-based paint. Industry cited the lack of proof that lead causes adverse health effects while Europe governments took a precautionary approach that ultimately protected their children. This process was repeated when the lead industry convinced the government to allow leaded gasoline despite the threat of harm. Allowing lead to be added to gasoline was probably the worst public health policy ever made. The intersection of science and policy continues, as Michaels points out, when the CDC failed to lower the blood lead action level despite substantial evidence of harm at lower blood lead levels (Gilbert & Weiss, 2006).

An underlying theme of Doubt Is Their Product is that capitalism, as it is currently practiced, prioritizes short-term profits and stock prices over health of people and the environment. While individuals must take responsibility for their own health and wellbeing, the chemical content of the products they use is out of their control. Often there are few options or alternative products for people to choose from, or the nature of the possible adverse health effects is obscure. Industry is responsible for the amount and types of chemicals in use and now must take more responsibility to ensure that those chemicals do not harm humans and the environment. Unfortunately, the record is not reassuring. Industry has failed to assume responsibility for care or to voluntarily provide the assurance of chemical safety.

There is a role for government to provide a level playing field and safeguard the citizenry through stronger regulatory action and enforceable standards that protect human health and environmental. You cannot play a satisfying game of baseball, basketball, soccer, or football without rules and an umpire to enforce them. Industry, too, needs rules that protect all players, including the consumer, with government serving as the umpire. For startes there needs to be a basic set of rules that require testing of the chemical for efficacy and safety prior to commercial use and this information made available the public.

Exposed and Doubt Is Their Product eloquently demonstrate the need for chemical use policy reform in the United States. In particular, Michaels in Doubt Is Their Product provides a list of strategies and actions that are needed to institute chemical use policy reform, ensuring a healthier population, and an environment in which all children can reach and maintain their full potential. We have a right to know what is in our products and information on a chemical's potential effect on human health and the environment. I urge you to read these books and consider the urgent need for chemical use policy reform, which may require a more precautionary approach and a reform of current business practices.

References

Gilbert, S.G. (2007). (lead author). Scientific consensus statement on environmental agents associated with neurodevelopmental disorders. Developed by the Collaborative on Health and the Environment's Learning and Developmental Disabilities Initiative. (Available online at: http://www.iceh.org/pdfs/LDDI/LDDIStatement.pdf.)

Gilbert S.G. (2005). Public Health and the Precautionary Principle. Northwest Public Health, 22(1). http://www.nwpublichealth.org/archives/s2005/

Gilbert, S.G. & Weiss, B. (2006). A rationale for lowering the blood lead action level from 10 to 2 microg/dL. Neurotoxicology, 27, 693-701.

For further information please contact Dr. Gilbert at sgilbert@innd.org.

The NADD Environmental Health Project, funded by the John Merck Fund, provides professionals, families, and the general public with relevant information concerning toxic agents and their affects on neuro-development. For further information visit www.thenadd.org and click on "Environmental Health Project," or contact Ed Seliger, Project Coordinator, at eseliger@thenadd.org.