Letters to the Editor
Following are Letters to
the Editor that were written to express concerns
about the manner in which
significant public health risks were being addressed:
The following letter
to the editor appeared in the Forum section of the Summer 1985
edition of Issues
in Science and Technology, published by the National Academy of Sciences.
It responded to
an article in which the former head of the Environmental Protection Agency
appeared to set
forth the Reagan Administration’s approach to risk assessment.
Issues in Science
and Technology
Earon S. Davis,
J.D., M.P.H.
Forum
William Ruckelshaus’s article (Issues, Spring 1985) thoughtfully presented some aspects of the serious dilemmas we face with the largely unknown health risks posed by toxic chemicals. However, Ruckelshaus has artfully dodged basic social problems involved with his approach to risk. He also contributes to the incorrect impression that “conventional” pollutants (for example, lead, carbon monoxide, and oxidants) no longer pose important hazards. Following are concerns that have been consistently ignored or trivialized in this “acceptable risk” debate.1. If we know so very little about the true health hazards of toxic chemicals, why do we allow so many substances to enter or remain in commerce with little or no testing for chronic health effects? As Ruckelshaus will admit, we know almost nothing of the cumulative and synergistic effects of the myriad chemical exposures each person faces. In addition, cancer is only one toxic hazard, but discussion of others, such as birth defects, infertility, immune dysfunctions and neuro-psychiatric disorders is generally perfunctory or nonexistent in current risk assessments.
2. Increased risks from toxic chemicals are not inevitable. Ruckleshaus’s perspective trivializes the public’s demand for zero risk. Polls have shown that the public is willing to accept the economic and lifestyle consequences of near zero-risk environmental policies*. (Public referenda asking local citizens to choose between jobs and health are not much better than extortion.) Certainly, benefits to the public for each particular use/exposure could be balanced against their risks, but the risks must be known.
3. What about justice for the victim? Even if society finds a risk worth accepting, what happens to the ultimate victim? Currently, there is no effective system for identifying victims, let alone compensating them. Should this be the task of the company that created the risk and benefited from it?
Could not a reasonable person conclude that we have already taken too many risks regarding toxic chemicals? If so, perhaps we should shift our perspective on “acceptable” risks and go to a new, “zero-based environmentalism” in which the burden of creating (or continuing) a health risk is tempered by an equal burden of proof of the risk and guarantees of financial responsibility and just compensation for victims.
The risks that we are already doomed to face an environmental health catastrophe in the coming years may be small, but we just do not know. Is it worth increasing that risk? And if we already have taken that risk (via incrementalism and regulatory neglect), is it too late to hedge our bets? These are questions to which we deserve straightforward answers.
Earon S. Davis, J.D., M.P.H.
Editor
Ecological Illness Law Report
Evanston, Illinois
*Council on Environmental Quality, Public Opinion on Environmental Issues: Results of a National Public Opinion Survey (Washington, D.C., Government Printing Office, 1980).
Revised 1-18-08