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Fundamental Flaws

Posted on Mar 26, 2008
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Workers spraying pesticide on crop seed.The Alliance for a Healthy Tomorrow seeks to correct fundamental flaws in government policies that allow damage to our health and environment.

The result of these current policies is that toxic substances end up in our bodies without our knowledge or consent. We have seen that ignoring early warning signs can result in serious illness.

The tragic histories of lead and mercury, for example, demonstrate the harm caused when government and industry do not take action to protect public health. We have also seen that acting on early warnings can prevent widespread harm, as in the case of the drug thalidomide.

Flaw #1: Potential toxins are not usually tested for safety before use.
Most chemicals, pollution and technologies are treated as if they were safe until proven otherwise. While the Food and Drug Administration (FDA) requires that drugs be thoroughly tested before they are mar-keted, the government historically has allowed chemicals that can have equally powerful impacts on our health to be released into the air and water. Approximately 80,000 chemicals are licensed for use in commerce today. The U.S. Environmental Protection Agency (EPA) has estimated that fewer than 10% of the industrial chemicals produced in the largest quantities (over one million pounds per year) have undergone even a limited set of tests to assess their health effects on humans.

Most tests look only for acute toxicity or cancer-causing properties. Potential harm to a child's nervous system is rarely investigated. In fact, as of 1998, only 12 chemicals had been tested according to EPA standards for their impact on the developing human brain. Even less is known about what happens when people and ecosystems are repeatedly exposed to more than one chemical at a time. Yet recent tests by the U.S. government have found hundreds of chemicals in the blood and urine of Americans. In addition, many of these synthetic chemicals go into products sold in stores.

While the federal Consumer Product Safety Commission frequently takes action to prevent safety hazards in products, chemical toxicity hazards to consumers are far less regulated. No pre-market safety testing or approval has been required under any federal law for chemicals in cosmetics, toys, clothing, carpets or construction materials, to name just a few obvious sources of chemical exposure in everyday life. Products like hair spray, hair dye, pacifiers, stain repellants, glues, and children's toys have been put on the market, only to be found, after decades of widespread use, to contain toxic compounds at unsafe levels.

Flaw #2: The government usually takes action only after harm is proven and widespread.
Government decisions on whether to control, limit or ban a potentially damaging chemical, technology or waste product are usually a political battle between those citizens who want health protections, the manufacturers or business proponents, and government officials. For years, business proponents such as chemical companies and other polluters have argued that government must not take action to restrict their use or production of toxins until there is definitive scientific proof of a cause and effect connection between their activities and serious health or environmental harm.

But definitive "proof" of harm is very hard to obtain with current scientific tools. The lack of scientific proof of harm is too often misinterpreted as proof of safety. When faced with uncertainty, government authorities have erred on the side of allowing harmful pollution and toxins in products. They act only after the damage is quantifiable scientifically and is widespread. We call this the "count the bodies" approach to public health protection.

Flaw #3: Certain levels of harm are accepted and allowed by government authorities.
Current environmental and chemical policies focus on establishing “acceptable” levels of harm from toxins rather than on seeking ways to prevent harm in the first place. Government regulators have set up a policy of “risk management” that includes setting standards for “acceptable risk.” For example, the U.S. EPA (Environmental Protection Agency) has set a standard for environmental pollution that allows an “acceptable risk” of one “extra” cancer death for every one million people exposed to one pollutant from one source.

In the workplace, the federal government standard is that one “extra” cancer death is an “acceptable level” for every 1,000 workers who are exposed to a chemical. Even worse, these “acceptable levels” are usually based on studies of healthy adult males—not children, older people, or others who are more physically vulnerable. In reality, everyone is exposed to many pollutants from many sources. The people who make these decisions may think of those numbers as mere statistics, but the result of their decisions is that real people are getting sick and dying.

Increasingly, government regulators are required to use “cost-benefit analysis” in their decision-making. This analysis assigns a monetary value to illness and death, and compares this to the cost of pollution controls or regulations. As a result, government regulators rely on mathematical formulas that are inherently biased toward short-term business costs (which can be more easily counted) and against protecting long-term public health (where costs are neither fully known nor quantifiable). If the projected cost of pollution controls is more than the value put on saving lives and protecting public health, then the pollution is often allowed to continue.

Flaw #4: Powerful special interests obstruct government action to protect our health.
Polluting industries have conducted a coordinated campaign to promote these flawed policies and to obstruct health-protective policies that would restrict their products or processes. Corporations have often used their financial and political power to block protective action by our government. For example, since the 1950’s the chemical industry has systematically blocked efforts to require safety studies on the compounds it produces.

Lobbying groups for the chemical, plastics, and oil industries have great impact on government policies and action. In order to win legal permission from government officials to pollute, companies frequently conceal, deny and downplay the potential harm to health caused by their emissions or products. Polluting corporations have insisted that the current policy of “acceptable risk” is necessary to support a growing economy. They take government regulators to court to block protective health and environmental policies. They consistently try to advance their economic interests with scientific arguments about uncertainty and lack of cause-effect proof of harm.The delays that result place our health at risk.