#199: More Ways to Understand Growth.

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RACHEL'S HAZARDOUS WASTE NEWS #199
---September 19, 1990---
News and resources for environmental justice.
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Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
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[In RHWN #197, we introduced some tools that allow anyone to understand things that grow exponentially, which is to say, things that grow by a constant percentage of the whole in a constant time period, such as a bank account that grows at the rate of 6% each year. Most things that affect the environment are growing exponentially. Tools for understanding exponential growth are very useful because they allow us to see why we're in the situation we're in today.]

RULE 5: 

If you know some original amount, called N_sub_o, and some amount that it has grown to, N_sub_t, at some later time, t, you can calculate the value of k (the annual rate of change, expressed as a decimal fraction) by the following equation:

k = (ln(N_sub_t/N_sub_o))/t [Rule 5]

where:

ln means "natural logarithm of" (your $15 Radio Shack scientific calculator will give you the natural log of any number instantly);

N_sub_o is some original amount;

N_sub_t is the amount that it has grown to at some later time, t;

k = the annual percentage increase expressed as a decimal fraction (in other words, it's the value we've been calling p, divided by 100) [for example, if something is growing at 6% per year, p = 6 and k = 0.06];

t = time (in any units you care to choose).

In other words, take the amount N_sub_t at time t, divide it by N_sub_o (the original amount), take the natural log of the result, then divide that natural log by t. That will give you k; if you then multiply k by 100, you have p. Then you can use k and p with Rules 1 through 4 (given in RHWN #197) to learn important characteristics of the thing that's growing.

For example, the consumer price index grew from 133.1 in 1973 to 246.8 in 1980. What was the annual percentage rate of increase, p? To find p, first we calculate k. The annual increase rate (expressed as a decimal fraction), k, was:

(ln(246.8/133.1))/t

Since t = 1980-1973 = 7 years, and 246.8/133.1 = 1.85 and the natural log of 1.85 = 0.62, the value of k = 0.62/7, or 0.088; thus p = 0.088 x 100 or 8.8% per year increase. With this number in hand, we can use rules 1 through 4 to learn its other growth characteristics.

RULE 6: 

If a quantity is growing exponentially and you want to know how rapidly it is increasing by a factor of x (i.e., how fast it's increasing by a factor of, say, 5, or, as we might say, how long it takes to increase 5-fold), use this equation:

x folding time = ln(x)/k [Rule 6]

Example: 

If a bank account is growing at 6% per year, how long will it take for the amount in the bank to increase five-fold? The natural log of 5 = 1.61; 1.61/0.06 = 26.8. Therefore, a bank account growing at 6% per year will increase 5-fold in a period of 26.8 years.

RULE 7:

 If an exponentially-growing quantity has increased by a factor of x during some period of time, t, then the fractional increase, k, per unit time can be found by the equation

k = ln(x)/x folding time [Rule 7]

Example: 

The annual production of a very useful chemical increased 6-fold from 1949 to 1958. What was the annual percentage increase?

My scientific calculator tells me that the natural log of 6 = 1.79. The x folding time = 1958-1949 = 9. Thus k = 1.79/9 = 0.198 or 19.8% per year, an impressive annual rate of increase, which, by Rule 1, would lead to a doubling of that chemical's production every 70/19.8 = 3.5 years, and, by Rule 4, would lead to an increase by a factor of a million during one human lifetime. Impressive growth, indeed. (See Table 1 in RHWN #197.)

RULE 8:

If you want to know the total amount of an exponentially-growing quantity produced during time-period t, use this equation:

C = (N_sub_o/k)*(e**((k*t)-1)) [Rule 8]

where:

** means "raise to the power of"

* means "multiply by"

C = total amount produced during time-period t;

N_sub_o = the original amount;

k = the increase (expressed as a decimal fraction) per unit of time (for example, per year);

e = 2.718, the base of natural logarithms;

t = time (in any units).

For example, if 40,000 automobiles were produced in 1920 and car production increased 10% per year for the next 15 years, how many cars were produced, total, during the 15 years? N_sub_o = 40,000; k = 0.10; t = 15. Therefore, C = (40,000/0.10) (e**((0.10*15)-1)) = 1,392,676.

In writing the equation above, we've used an asterisk to indicate multiplication; in other words, 2*2 = 4, and we've used ** to indicate exponentiation, meaning "raised to the power of;" i.e., 2**3 = 8.

RULE 9:

During one doubling time, the growth in an exponentially-growing quantity equals all the growth that has occurred in all previous time. Thus if production of chemical XYZ is growing at 10% per year (doubling in 7 years), during the next 7 years we will produce an amount of chemical XYZ equal to all of the chemical XYZ that has been produced up to today.

These 9 rules can help us all understand why environmental problems have sneaked up on us, and why the growth of some things must be curbed.

Let's take an example. Let's say we learn from a magazine article that the synthetic organic chemical industry produced 38 billion pounds of chemicals in 1945 and since then has grown steadily at 6.5% per year. From that small amount of information, we can learn a lot. For example, from Rule 3 we can learn that annual synthetic organic chemical production in 1990 was about 708 billion pounds. By Rule 1 we can learn that total production is doubling every 10.8 years (we'll round it off and call it 11 years). By Rule 9, we can learn that during the most recent doubling-time (from 1979 through 1990), which happens to be the time since Love Canal was discovered, the chemical industry produced an amount of chemicals equal to the amount it produced during all time prior to the discovery of Love Canal. By Rule 8, we can learn that since 1945, the chemical industry has produced a total of 10.3 million million (or 1.03 x 10**13) pounds of chemicals, all of which has gone somewhere, and Rule 9 tells us that during the next 11 years they'll produce another 10.3 million million pounds. From Rule 4, we can learn that if the chemical industry keeps growing at 6.5% per year, during one human lifetime it will increase its size 90-fold; in other words, if the chemical industry keeps growing at its current rate, for every chemical factory in existence today, there will be 90 chemical factories just 70 years from now.

These facts help us understand why more and more people are complaining about chemicals affecting their lives: it isn't because of growing "chemophobia," it is because people are being exposed to more and more chemicals that are being released into the air and water that we all breathe and drink. A massive change--the "chemicalization of the environment"--has occurred during the past 50 years, and the problem is doubling in size every 11 years.

These facts can lead us to one more conclusion: since the chemical industry in all its trade publications constantly stresses the need for continuous growth at rates that match or exceed the historical rate of growth, we can conclude that executives in the chemical industry do not understand the implications of exponential growth. No one who has seen the heavily industrialized sections of chemical-producing states like New Jersey, Ohio, Louisiana, Texas and California can believe that we could survive 90 chemical factories where each chemical factory stands today. Growth of this industry has got to be curbed. By what means? By whatever non-violent means are necessary. Whatever it takes.

Further reading: Ralph Lapp, THE LOGARITHMIC CENTURY (Englewood Cliffs, NJ: Prentice-Hall, 1973). And: chapters 1 and 2 of Donella H. Meadows and others, THE LIMITS TO GROWTH (NY: Universe Books, 1972). And: Albert A. Bartlett, "The Exponential Function," THE PHYSICS TEACHER (October, 1976), pgs. 393-401.

--Peter Montague, Ph.D.

Descriptor terms: mathematics; chemical industry;

#197: How to Project Future Growth.

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RACHEL'S HAZARDOUS WASTE NEWS #197
---September 5, 1990---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
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========================Original Source========================

One of the important characteristics of environmental problems is the way they're growing. It is important for the public (and for news reporters and environmentalists) to understand growth. This is often easy to do because of the way most things grow. As Ralph Lapp has made clear in his book, THE LOGARITHMIC CENTURY, human population (and most of the things related to humans such as automobiles, chemicals and chemical wastes), are growing exponentially. This permits us to make accurate growth projections easily.

First a definition: A quantity is growing exponentially if it grows by a fixed percentage of the whole in a fixed time period. A familiar example of a quantity that is growing exponentially is a bank account that grows at 6% per year; it grows by a fixed percentage of the whole (6%) in a fixed period of time (a year).

There are some rules about exponential growth that allow us to make quick and accurate projections into the future.

RULE 1: To determine the doubling-time (d) for an exponentially-growing quantity, divide the annual percentage rate of increase (p) into 70.

d = 70/p [Rule 1]

where:

d = the time it takes for the quantity to double in size;

p = the annual increase expressed as a percentage.

Thus the savings account growing at 6% per year is doubling every 70/6 = 11.7 years. Thus $5 growing at 6% per year will grow to $10 in 11.7 years. By the same reasoning, a quantity that is growing at 10% per year--such as production of a chemical--will have a doubled annual production rate in 7 years. (For those who are curious, 70 is used because it is very close to 100 times the natural logarithm of 2, which is 0.693.)

RULE 2: If we know the doubling time for an exponentially growing quantity we can calculate the annual percentage increase (p) by using a variation of Rule 1.

p = 70/d [Rule 2]

where:

d = the time it takes for the quantity to double in size;

p = the annual increase expressed as a percentage.

If we are told that something is doubling in 5 years, we know that it is growing at 70/5 = 14% per year.

RULE 3: The fundamental equation for exponentially growing quantities is:

N_sub_t = N_sub_o*e**kt [Rule 3]

where:

N_sub_o is some original amount;

N_sub_t is the amount that it has grown to at some later time, t;

e is a constant, equal to 2.718 (it is the base of natural logarithms);

k = the annual percentage increase expressed as a decimal fraction (in other words, it's the value we've been calling p, divided by 100);

t = time (in any units you care to choose).

Don't be put off by the strange notation; N_sub_o is pronounced "N sub O" and N_sub_t is pronounced "N sub T." This is the way mathematicians and physicists like to talk about quantities, but once you get used to the odd way of expressing them, the ideas themselves are simple enough. To handle the arithmetic involved in such an equation, remember that when two items are written next to each other, it means that they should be multiplied together. In this example, k and t have been written kt and this means that k is multiplied by t. (We have also used an asterisk to indicate that two numbers should be multiplied by each other, so kt and k*t mean the same thing--multiply k times t.)

There is a standard order in which mathematical operations are carried out. First, any exponents should be evaluated (figured out). In this case, kt is an exponent, so you multiply k times t first. Next you carry out the exponentiation: in this case, you raise e to the power of k*t. (A $15 scientific calculator from Radio Shack can raise e to any power for you.) Next you carry out any multiplication or division; in this case, because they are written next to each other, you would multiply N_sub_o times whatever you got when you raised e to the power of kt. Last, you do any addition or subtraction; in this particular example there isn't any addition or subtraction indicated.

Parentheses are used to change the order in which mathematical operations are carried out; always do what's inside parentheses first. Start inside the innermost parentheses and work your way outward.

Example of Rule 3: If production of hazardous wastes is growing at 6.5% per year [thus doubling every 10.8 years] and if we produced 30 million tons of hazardous waste in 1980, how much hazardous waste will we be producing in 1995? N_sub_o = 30 million tons; t = 1995-1980, or 15; k = 6.5/100, 0.065. Therefore, N_sub_t (the amount of waste produced at time t), when t = 15, is e raised to the power of (0.065 x 15, or 0.975), times 30 million. Using a scientific calculator, we raise e to the power of 0.975 and we get 2.65. Therefore, the amount of waste to be produced in 1995 = 30 million tons times 2.65, or 79.5 million tons, assuming that the growth-rate continues to average 6.5% per year between 1980 and 1995.

RULE 4: If a quantity is growing exponentially, during one human lifetime (assumed to be 70 years) it will grow by a factor of 2 raised to the power of p, where p is the annual percentage rate of increase. (The phrase "it will grow by a factor of" means "its growth can be calculated by multiplying by.")

N_sub_t after 70 years = N_sub_o*2**p [Rule 4]

where:

N_sub_o is some original amount;

N_sub_t is the amount that it has grown to at some later time, t;

p = the annual increase expressed as a percentage.

Table 1 gives 2p for many typical values of p.

Thus when we say that production of chemical X is increasing at 10% per year, we can calculate that during one human lifetime the annual production rate of chemical X will increase by a factor of 2**10, or 1024. That is to say, if we produced 1,000,000 (one million) pounds of chemical X in 1980 and our production is growing at 10% per year, at the end of one human lifetime we will be producing 1,000,000 x 1024 = 1,024,000,000 (or more than one billion) pounds of chemical X annually.

At this point we should make the distinction between predictions and projections. A prediction is a statement of what someone thinks is going to happen. A projection is a statement of what will happen if things don't change. As we are using the term here, a projection is based only on the past record of the growth of something. A prediction may take into consideration many other factors besides the past record of the growth of something; for example, a prediction may take into account how we humans are likely to react to a scary projection of future growth. A projection can--by itself--make things change. (In other words, a projection may cause us to change our predictions.) Thus one is not predicting that we will increase our production of some chemical by a huge amount during one lifetime. One is simply projecting that--based on past growth records--such future growth will occur unless something changes. Sometimes the frightening implications of growth projections are--by themselves--sufficient for people to see that we've got to slow down some rate of growth.

Increasing
Quantity
(of anything)
.
150                                    *
.     Typical Curve Produced By
.     Exponential Growth               *
125   (Growth rate = 10% per year)
.                                     *
.
100                                 *
.
.                                 *
75
.                              *
.
50                        *
.
.                   *
25
.             *
.* * *  *
0 _______________________________________
.
1940   1950   1960   1970   1980   1990
.              TIME

Figure 1. Typical curve created by something growing exponentially. Notice that at the beginning, the curve is not rising steeply; as time passes, however, the curve becomes steeper and steeper. The larger the quantity becomes, the faster it grows; this is the main characteristic of things that grow exponentially.
======================================

Table 1. Various Powers of 2

If p equals	Then 2^p equals
2	4
3	8
4	16
5	32
6	64
7	128
8	256
9	512
10	1024
11	2048
12	4096
13	8192
14	16,384
15	32,768
16	65,536
17	131,072
18	262,144
19	524,288
20	1,048,576

Table 1. The value of 2 raised to the power of various annual rates of increase, p, expressed as a percentage.

--Peter Montague, Ph.D.
Descriptor terms: mathematics; predictions; exponential growth;

#395: Risk Assessment -- Part 3: Which Problems Shall We Ignore?

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RACHEL'S HAZARDOUS WASTE NEWS #395
---June 23, 1994---
News and resources for environmental justice.
==========
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
==========
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========================Original Source========================

Risk assessment became a hot topic in Congress in 1994. Earlier this year when the Senate passed a bill to elevate EPA [U.S. Environmental Protection Agency] to cabinet status, Bennett Johnston --a petrochemical senator from Louisiana --tacked on an amendment requiring EPA to conduct a risk assessment for every regulation the agency issues. The House of Representatives has not acted on the "EPA elevation bill" for fear that the Johnston amendment would snarl EPA in paper, making the agency even less effective. [1]

Representative Herb Klein has sponsored a new bill, H.R. 4306, called the "Risk Assessment Improvement Act of 1994," hoping to make EPA conduct all its risk assessments according to fixed guidelines.

The National Academy of Sciences in January issued a fat volume called SCIENCE AND JUDGMENT IN RISK ASSESSMENT that aims to improve EPA's risk assessments. Yes, risk assessment is enjoying great attention in Washington these days. Why?

The premier think tank on risk assessment --the Center for Risk Management in Washington, operated by Resources for the Future (RFF) --explains it this way: "The subject of risk assessment has leaped to prominence during the past year, both in Washington, D.C. and at the grass roots.... There are several reasons for the sudden interest in risk assessment, but the major underlying reason is the general recognition that government and private sector resources are scarce and that it is therefore necessary to understand what society gains from environmental laws and regulations. The only analytical method for determining this is risk assessment. Once the premise of scarce resources is accepted, the need to set priorities is unavoidable."

Really? Is it really true that in 1994, for the first time, people recognized that resources are scarce? As H.L. Mencken liked to say, "Balderdash." Resources have always been limited and people have always known it. The point of developing a Constitutional democracy in the 18th century was to allocate resources more fairly than a monarchy had ever managed to do. The whole point of "politics" is to influence the allocation of scarce resources. Will our town have a new nursing home or a new golf course? Will we subsidize public housing or give a tax break to the new incinerator? These are typical political choices in a world where resources are scarce. There is nothing new about scarce resources.

But risk assessment as a substitute for the political process is new. And think tanks to promote risk assessment as "the only analytical method" for learning what we gain from environmental laws are CERTAINLY new. Is risk assessment the ONLY way to analyze the benefits we get from environmental laws? What a silly idea. Who would support a think tank to promote such a silly, undemocratic idea? A recent newsletter from the Center for Risk Management lists the following "major corporate supporters:" Browning-Ferris Industries; the Chemical Manufacturers Association; the Dow Chemical Company; E.I. DuPont de Nemours & Co.; Monsanto Company; WMX Technologies [formerly Waste Management, Inc.]; the General Electric Foundation; and Philip Morris Companies, Inc., among others. "Other corporate contributors" listed in the newsletter are the American Petroleum Institute and the Union Carbide Foundation. In sum, the Center for Risk Management is supported by many of the corporations that have fostered environmental destruction on a global scale for 50 years. Why might these corporations want to promote risk assessment as a way of establishing environmental priorities?

When risk assessment is used to establish environmental priorities, the effect is to decide which problems will be ignored, which destructive behaviors will be tolerated. As we saw last week (RHWN #394), Judge Stephen Breyer, President Clinton's choice for Supreme Court justice and a self-styled expert on risk, says the nation is wasting money worrying about old chemical dumps, pesticides, and nuclear power. It is evident that Mr. Breyer has reached a personal political conclusion that people exposed to pesticides and industrial chemicals from old dumps don't matter much, and that nuclear power is safe. He believes the American people should ignore these problems and focus resources elsewhere. Naturally he's entitled to his views. 

Unfortunately, he wants to impose those views on the rest of us, and he proposes a vehicle for doing just that: an elite corps of risk assessment "experts" who will be "politically insulated" from Congress and from the American people. This elite corps would make risk decisions for the rest of us. The public would be less involved than presently. For example, Judge Breyer says, "For reasons I have mentioned, to achieve the public's broader health and safety goals may require forgoing direct public control of, say, individual toxic waste dumps." (African Americans and native people, beware.) 

And Judge Breyer explains how the elite corps group could defuse public concerns at the local level: the Judge says his system "offers the local [EPA] administrators insulation and protection from criticism. They can answer the locally posed question, 'Is our swamp clean now?' with, 'Yes, the swamp is clean; the risks are insignificant and national technical (system-based) standards say that is so.'" [2] Unfortunately, all the scientists in the world will never be able to determine by scientific methods that the risks of a contaminated swamp are "insignificant." Science cannot determine that. Chemicals that seem safe today are often recognized as dangerous tomorrow, and that will always be the case. 

Furthermore, science has no way to judge the consequences of exposure to many pollutants simultaneously. Therefore, decisions about how to treat contaminated swamps will always be largely political. Scientists are welcome to join the debate, just like any other citizens. The plain fact is, people are uneasy about strange, unnatural chemicals in their food and water, and even in their local swamp. (Most people are also aware that nuclear power plants can be used to make bombs, and that the threat of nuclear war, even as far from home as North Korea, is a big problem.) 

People are aware of evidence of increased birth defects, developmental disorders, cancer, and other illnesses associated with pesticides, and with strange chemicals leaking from Superfund dumps. Men today produce half the sperm their grandfathers did, most likely as a result of exposure to "acceptable" levels of unnatural industrial chemicals. (See RHWN #343.) IT IS RATIONAL TO BE CONCERNED ABOUT SUCH THINGS. In a democracy, people have a right to be concerned, and to advocate that resources be applied to their concerns. 

That is politics. That is the American democratic system. It is perhaps understandable that Dow and DuPont might want to substitute risk assessment for the political process because they can "talk turkey" with the risk experts, whereas the public cannot, and thus in a less democratic system these polluters might be spared the costs of cleaning up the massive quantities of environmental poisons they have released for 50 years.

Comparative risk assessment --or CRA, as it is know in the risk biz --is chiefly a means for increasing the political power of "experts" and reducing the political power of the general public. The experts will decide what is important and what is safe, and--if people like Judge Breyer have their way--the experts will be allowed to impose their views on the public. But CRA is not an objective, scientific enterprise; for reasons given in RHWN #393 and #394, it is distinctly a political process. CRA "experts" have no more legitimate claim to authority or power than anyone else in society.

Furthermore, CRA simply will not work: who expects people living near a Superfund dump to sit by while the risk experts tell them their problem is insignificant compared to global warming, or that society is better served by spending its money, say, subsidizing nuclear power? Using CRA to set environmental priorities is an invitation to continuous warfare at the local level. It will inevitably lead to new environmental injustices, as the voices of the public are excluded from the debate, and the "experts" --many of them the same people who created major environmental problems we now face --make more bad decisions in a political vacuum. CRA simply will not fly, unless we are willing to abandon democracy. It is apparent that Judge Breyer understands this and is willing to shrink our democratic freedoms so the experts can have their way with us. Is CRA really the "only" way to analyze problems of risk in a complex society? Of course not.

Instead of prioritizing environmental problems, thus admitting that certain problems will be ignored (and certain destructive behaviors will be tolerated), we could instead make a national commitment to solve all environmental problems. Every county (or even municipal) government could produce a "state of the environment" report that assessed what problems existed and what progress was being made toward (or away from) solutions. Environmental goals could be thrashed out as part of this report, which might be updated every 2 or 3 years. New information would be factored into each update.

As part of this process, every business might be required to complete an environmental audit that would discuss THEIR alternatives to reduce THEIR impact on the environment and public health. No one would be required to implement the alternatives, but merely to "rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated," as is required now of federal agencies preparing environmental impact statements under the National Environmental Policy Act.

The publication of environmental audits discussing all available alternatives might lead to public pressure on businesses to adopt environmentally sustainable practices. The pressure might consist of green labeling, taxes on toxics, consumer boycotts, laws, initiatives, or regulations. But these are simply the processes of an informed citizenry in a democracy and THAT is where debate about economic feasibility should come in.

There are many other possible ways to promote rational behavior toward the environment. The point here is not to insist on one particular approach, but to examine the most sensible means of addressing all environmental problems rather than claiming rationality for comparative risk assessment, an inherently irrational system of deciding which problems to ignore. [3]

--Peter Montague, Ph.D.

===============

[1] Terry Davies, "Message From the Director," CENTER FOR RISK MANAGEMENT NEWSLETTER (Spring, 1994), pg. 1. Available free from: Resources for the Future, 1616 P St., N.W., Washington, DC 20036; phone: (202) 328-5060.

[2] Stephen Breyer, BREAKING THE VICIOUS CIRCLE (Cambridge, Ma.: Harvard University Press, 1993), pgs. 73, 76.

[3] Thanks to Mary O'Brien for many ideas on risk assessment, though she bears no responsibility for their presentation here.

Descriptor terms: risk assessment; stephen breyer; epa; comparative risk assessment; bennett johnston; petroleum industry; us senate; house of representatives; congress; legislation; herb klein; national academy of sciences; nas; center for risk management; resources for the future; bfi; browning-ferris industries; cma; chemical manufacturers association; dow chemical; dupont; monsanto; wmx technologies; waste management, inc.; ge; general electric; philip morris; american petroleum institute; api; union carbide; superfund; radiation; nuclear power; pesticides; science; nepa; national environmental policy act; alternatives assessment; environmental audits; mary o'brien; terry davies;

#394: Risk Assessment -- Part 2: Judge Breyer's Prescription for Risk

=======================Electronic Edition========================
RACHEL'S HAZARDOUS WASTE NEWS #394
---June 16, 1994---
News and resources for environmental justice.
==========
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
==========
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========================Original Source========================

Reluctantly, President Clinton has nominated Stephen Breyer to the Supreme Court of the United States. Mr. Breyer presents himself as an expert on risk assessment; he has even written a book on the subject, BREAKING THE VICIOUS CIRCLE, subtitled TOWARD EFFECTIVE RISK 

REGULATION. [1]Examining Mr. Breyer's book on risk provides an opportunity to extend our discussion from last week#393 about the insuperable shortcomings of risk assessment. It will also help us learn what Mr. Breyer believes about risk in a democracy.

Risk assessment has 4 parts, says Mr. Breyer [pg. 9]: (1) identifying the potential hazard (i.e., defining the toxicity of the substance in question); (2) drawing a dose/response curve (i.e., deciding how much of a substance will cause how much damage); (3) estimating the amount of human exposure; and (4) categorizing the result (i.e., putting it all together to state the probability of a certain kind of damage).

Mr. Breyer says 2 of these 4 steps are particularly difficult: "In carrying out these activities, particularly in making dose/response and exposure estimates, regulators often find that they simply lack critically important scientific or empirical data: they do not know how many Americans inhale how much benzene at gasoline stations; they do not know the extent to which the biology of a rat or mouse resembles, or differs from, that of a human being. In such instances, they will often make a 'default assumption'--a formalized guess--designed to fill the gap and to permit the regulator to continue the analysis." [We note that Mr. Breyer is in complete agreement here with the risk expert we quoted last week, Joseph V. Rodricks; what Mr. Breyer calls "default assumptions," Mr. Rodricks called "science policy choices" but they are the same thing -- informed guesses.) Guesses to fill data gaps are not science. They are political judgments.]

Having defined risk assessment [correctly, we believe], Mr. Breyer now describes the larger problem of regulating risks, or "the vicious circle." The problem has 3 parts: public perception, Congress, and uncertainties in the regulatory process.

The problem of "public perception" is that the "experts" and the public often disagree on what's an important risk. For example, Breyer says, the public ranks toxic dumps and nuclear power as big risks but the experts rank them as small risks. [pg. 33]

The problem with Congress is that it is "not institutionally well suited to write detailed regulatory instructions that will work effectively" because (a) it writes one law at a time, (b) its committees have various priorities, and (c) "Finally, Congress is highly responsive to public opinion, as it ought to be." Even though Congress "ought to be" responsive to public opinion, the public "finds it difficult to order risk priorities" and therefore Congress has the same difficulty. [pg. 42] For these reasons, Congress can never be effective at dealing with risk, in Mr. Breyer's view.

The 3rd element of the "vicious circle," Mr. Breyer says, is the "enormous uncertainties, almost inevitably present, in any practical regulatory effort to carry out the four stages of risk assessment earlier described-- identifying the hazard, relating response to dose, estimating exposure, and characterizing the risk." [pg. 43]

The discipline called "toxicology" is part of the problem, says Mr. Breyer. "Like civil engineering, toxicology embodies as a disciplinary canon the importance of 'erring on the safe side.'" This assumption that we should err on the side of safety is a key part of the problem, Mr. Breyer says. He says, "Two scientifically plausible models for the risk associated with aflatoxin in peanuts or grain may show risk levels differing by a factor of 40,000." From this, Breyer concludes that, "With estimates that vary by such magnitudes, a simple retreat to the toxicological principle of erring on the side of safety will not solve the problem." [pg. 45]

He then goes on to emphasize how little science can actually tell us about the effects of most toxins on human health [again, agreeing with toxicologist and risk assessor Joseph V. Rodricks, whom we quoted last week]. Then Breyer says, "These uncertainties, knowledge gaps, default assumptions, guesses, and communications difficulties, all embodied in the technical regulatory process, spell trouble.... Such a system, in respect to small risks, and with assumptions of varying reasonableness, can produce random results." [pg. 48]

These uncertainties become political opportunities, Breyer says: "The very fact that the many assumptions required by uncertainties are not clearly derivable from science can make them a lightning rod for contending political forces. Regulatory bodies, after all, are politically responsive institutions, with boards, commissioners, or administrators appointed by the President, confirmed by the Senate, written about by the press, and, from time to time, summoned by Congressional committees to give public testimony. Their agendas, within limits, respond to the public's demands. Their choices of default assumptions, to a degree, can respond to the desire of the President, Congress, Congressional staffs, interest groups, or the agencies themselves to appear especially careful to err on the safe side, or, alternatively, to show sensitivity to economic costs." [pg. 49]

Having established that risk assessment is a highly political, not a scientific, enterprise, and is subject to pressures from "the public's demands," Mr. Breyer develops his solutions:

We can't change people, and we can't change Congress, so we've got to change the third element of the "vicious circle," Mr. Breyer argues. We've got to change the regulatory process.

Mr. Breyer's solution is a "small, centralized administrative group" [pg. 60] whose mission will be to develop risk regulations. This group must have 5 characteristics [pgs. 60-61]:

(1) a mission to develop a risk-regulating system, to create priorities within government programs, and to determine how to allocate resources to reduce risks.

(2) Interagency jurisdiction, to transfer funds, say, from the toxic waste program to vaccination programs and prenatal care, for example, Mr. Breyer says.

(3) A degree of "political insulation" so it can withstand "political pressures" that "emanate from the public directly or through Congress or other political sources."

(4) Prestige, so it can attract a capable staff.

(5) Authority, so that it has "a practical ability to achieve results," Breyer says. [Later, on page 72, Breyer suggests giving the group real power: "perhaps such a group would begin to consider whether proposed rules, regulations, or major agency actions are 'arbitrary, capricious, an abuse of discretion'--a legal authority that would bring with it enormous power," Breyer says.]

Are you getting the picture? Mr. Breyer says our problem is that we're wasting money on insignificant problems like toxic chemicals and nuclear power regulation. This occurs because the "experts" are outweighed in the political process by the general public, operating through Congress. The general public has different priorities from the experts. Congress listens too much to the public and not enough to the experts. Mr. Breyer is clearly saying, what we need is an elite corps of experts to make decisions for us about risk.

How would this elite group of risk assessors, empowered to create priorities, allocate resources, and achieve results, really work? Mr. Breyer offers 5 hints:

(a) They might simply declare some risks too small to worry about. These would be termed de minimus risks. [pgs. 64-67]

(b) They would call upon risk assessment expertise from outside government.

(c) The group would develop "models" to achieve "higher quality analysis and better results." In other words, better risk assessments.

(d) The group could develop a "risk agenda" and then look for practical ways to save money on some programs and transfer those funds to other programs. Here Breyer repeats his example of taking funds away from toxic waste cleanup and transferring them to pay for vaccinations, or prenatal care, or mammograms. [Clearly Mr. Breyer believes we are a society that cannot afford to clean up toxic wastes AND vaccinate our children AND provide prenatal care AND provide mammograms.]

(e) They might consider the risk-related impacts of future scientific changes, Breyer says: "Suppose, for example, that medical research identifies particular groups of persons genetically predisposed to develop cancer when exposed to certain chemicals. Society should not ignore their special plight. Yet it may prove nearly impossible, and sometimes inordinately expensive, to grant them a 'right' to the lowest possible risk and then limit society's use of chemicals to which they specially react. It might well be more effective to provide them with special counseling that includes information about how to avoid exposure to the carcinogens to which they are particularly susceptible." [pg. 67]

[Mr. Breyer is clearly ready to have his elite group declare null and void every citizen's right to clean air and water. And what about his suggestion that, instead of controlling toxic releases, we should tell people how to avoid particular toxins? How would we tell the eagles and the salmon to avoid toxins? Or don't they matter?]

Are there any precedents for similar groups operating anywhere in the world? Yes, says Mr. Breyer, France has the Conseil d'Etat, an elite civil service group that reviews the "administrative lawfulness" of government actions and proposed regulations. Is there any precedent in the U.S.? Yes, says Mr. Breyer; one is "the Armed Forces--not an open institution, but one which has successfully carried out its mission." [pg. 78]

Mr. Breyer does not seem to recognize that the chemical risk problems he seeks to remedy were created chiefly by two institutions: the armed forces, and private industry. Historically, both these institutions have enjoyed almost complete "political insulation" of the kind Mr. Breyer advocates for his elite corps of risk assessors. Furthermore, both of these institutions have always had access to the best technical experts money can buy. Indeed, technical experts shielded from political accountability were, and are, the main engine driving the global environmental crisis.

As for developing better risk assessments based on "better models": if science cannot provide consistent and reproducible results about risks, as Mr. Breyer correctly says science cannot, then his "better models" cannot be based on science. They must therefore be based on political judgments. Whose judgments? Those of Mr. Breyer's elite corps of politically insulated risk experts.

Is Mr. Breyer's final solution better than the democracy presently written into our Constitution? All we can say is, it would certainly be radically different.

                                                                         
--Peter Montague

===============

[1] Stephen Breyer, BREAKING THE VICIOUS CIRCLE (Cambridge, Ma.: Harvard University Press, 1993).

Descriptor terms: clinton; stephen breyer; breaking the vicious circle; risk assessment; supreme court; democracy;

#393: Risk Assessment -- Part 1: The Emperor's Scientific New Clothes

=======================Electronic Edition========================
RACHEL'S HAZARDOUS WASTE NEWS #393
---June 9, 1994---
News and resources for environmental justice.
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========================Original Source========================

A scientist who made himself wealthy by conducting risk assessments for industrial clients has now published a paperback book on the theory of risk assessment. CALCULATED RISKS, by Joseph V. Rodricks of Environ Corporation, is the best book we have yet seen on the theory of risk assessment -- lucidly written, and evenhanded so far as it goes. [1] If you want to understand the theory of risk assessment from the viewpoint of a successful risk assessor, this is the book for you.

Unfortunately, since the theory of risk assessment is quite different from the practice of risk assessment, Rodricks's book is little more than an enthusiastic description of the emperor's scientific new clothes.

In loving detail, Rodricks's book describes all the theoretical steps in a risk assessment. What the book does not discuss are:

(1) the insurmountable limits of science in determining chemical hazards;

(2) the environmental justice problems that government officials create when they use risk assessment to prioritize environmental problems; and

(3) the widespread destruction of the environment that is occurring because of our single-minded reliance on risk assessment;

(4) other, better approaches to establishing "safety" and to deciding environmental priorities, besides risk assessment.

This week and next,#394 we will discuss these 4 points.

The limits of science: Risk assessors are usually working with information that ranges from slim to none, and this will always be the case because the chemical industry invents new chemicals much faster than the government can test all their various negative effects. Rodricks acknowledges that our ignorance is vast: "Toxicologists know a great deal about a few chemicals, a little about many, and next to nothing about most," he says [pg. 146].

As Rodricks's book illustrates, the government often doesn't even know what toxic effects to test for. For example, Rodricks's book is as thorough and up-to-date as he could make it in 1992 (when the hardback edition first appeared), and yet it does not even mention chemicals that damage the endocrine system. The endocrine system, in wildlife and humans, is a complex set of bodily organs and tissues whose activities are coordinated by chemical messengers called hormones, which control growth, development and behavior. Bears hibernate because of chemical signals from the endocrine system, and women menstruate under control of their endocrine systems. In the past decade, evidence has accumulated that several dozen pesticides and other industrial chemicals mimic, or interfere with, hormones and thus disrupt the endocrine system. In both wildlife and humans, it is the reproductive system of unborn offspring that is most prone to disruption by hormone-like pollutants.

For 20 years, risk assessors like Rodricks -- well-meaning people inside and outside of government -- have given the green light to exposing people and wildlife to thousands of chemical compounds without understanding that some chemicals mimic, or interfere with, hormones. The very best risk assessments gave the answer "No problem" when in fact there were significant problems.

This is an insurmountable shortcoming of all risk assessments. If there are effects from chemicals that scientists have not suspected and studied, those effects will be ignored in a risk assessment. Furthermore, because it costs roughly $400,000 to $1,000,000 to study a chemical even crudely, major harm must be demonstrated before study commences. Therefore, the risk- assessment method of setting "safe" standards always requires that harm must be done to wildlife and humans before study begins.

Rodricks -- like every other person who makes a living conducting risk assessments -- is not deterred by the absence of information about chemical effects. When good data are not available, risk assessments are put together from "science policy choices" (a fancy name for informed guesses), assumptions, and speculation.

This is a key point. Rodricks [pg. 187] says, for example, that in most cases the relationship between dose and response at low levels of exposure is not known. (In other words, nobody knows how sick your child will get from eating small amounts of several poisons every day.) There are usually several "scientifically plausible models" that could describe the dose-response relationship, Rodricks says, and "scientists cannot be sure which is correct." Moreover, the different models "yield sometimes substantially different pictures of the risk for the same exposure," he says. And, "If a risk assessment is to be completed, a science policy choice (the phrase used by the NRC [National Research Council]) must be made about the model to be used.... SEVERAL SIMILAR CHOICES HAVING TO DO WITH OTHER UNCERTAINTIES ARE NEEDED TO COMPLETE MOST RISK ASSESSMENTS," Rodricks says [emphasis added]. In other words, guesswork is central to every risk assessment.

Interestingly, Rodricks does not elaborate on the "several similar choices" that go into every risk assessment--perhaps because to do so would reveal that risk assessment is not the scientific enterprise it appears to be, but is in fact largely a political exercise. Rodricks does say that, "To base risk assessment and risk management decisions upon such uncertain scientific knowledge is bad public policy" [pg. 227]. 

Unfortunately, his answer is not to reduce our reliance upon risk assessment but to do more studies, as if more studies will eliminate all the important uncertainties in our scientific knowledge of the effects of chemicals on humans and ecosystems. Dream on. (See RHWN #377.)

From the viewpoint of someone eager to dump exotic new chemicals into the ecosystem, this is the real beauty of risk assessment: no matter how flimsy the base of information, every risk assessment still gives the same satisfyingly numerical answer. Furthermore, the answer you get is completely dependent upon the "science policy choices" that you made, yet the final result appears to be entirely objective and impartial. A political choice swaddled in scientific trappings. This emperor is really a snappy dresser!

Back to our recently-discovered ignorance about hormone disrupting chemicals. In testimony before Congress last October, Richard Wiles of the Environmental Working Group in Washington, D.C., showed that we now put 220 million pounds of endocrine-disrupting pesticidal chemicals directly onto and into our food supply each year. [2] The pesticide found most often on fruits and vegetables is endosulfan and it is an endocrine-disrupter. Analysis of data from the Food and Drug Administration's (FDA) routine food monitoring program revealed endosulfan on 21 out of 22 samples (95%) of fruits and vegetables heavily consumed by infants and children, Wiles testified.

At the same hearing, Dr. Earl Gray, a section chief in U.S. EPA's Health Effects Research Laboratory, reported his latest findings on a fungicide called Vinclozolin -- a pesticide currently in use with EPA's approval. [3] "Vinclozolin, when administered to a pregnant rat, demasculinizes the male fetuses in a manner identical to the anti-androgenic drug flutamide and in effect these effects are so obvious that all of the males look like females at birth," Dr. Gray testified. He went on to say, "In the rats in vivo [in other words, in studies of living animals] this chemical blocks development of the fetal male rat reproductive system so that they have undescended testes, they develop a vaginal pouch like a female, the penis fails to develop normally, and they retain nipples which male rats do not normally do."

Congressman Henry Waxman (D-Ca.) asked Gray, "Do you think that Vinclozolin could have the same kinds of hormonal effects on humans?" Gray answered, "I think that is quite possible, and likely."

Earlier in the hearing, Dr. Theo Colborn, an expert on endocrine-disrupting chemicals, made the point that a single dose of some chemicals can disturb a baby's normal sexual development. She said, "Nor is it comforting for a woman to realize that it takes only one very low dose, it is called a hit, of an endocrine-disrupting chemical during one of the many critical stages of embryonic development during her pregnancy to change the course of sexual development of her baby." [4]

So long as we use risk assessment as our chief guide for allowing chemical exposures, we can expect an unending series of unpleasant surprises as today's "safe" dose is discovered tomorrow to be unsafe.

Joe Rodricks makes a clear distinction in his book between risk assessment and risk management. First you assess the risk, then government acts to protect the public, he says. Oh, this emperor is really looking natty! 

How does this work in the real world?

At the hearing last October, Congressman Waxman asked EPA's Dr. Lynn Goldman how long it would take before Vinclozolin would be removed from the American food supply. Note the rich fudge of risk assessor's language in Dr. Goldman's response:

"Well, the decision could involve a number of considerations. What we are going to be concerned about is the issue of not only the inherent risk of the pesticide, but also the science that tells us about the exposures that might be expected given the various uses that are allowed under the label, and so that there could be a variety of actions that are taken ranging from, as you suggested, perhaps not even allowing the registration to only allowing the registration on certain uses that are safe, to allowing all of the uses that are currently allowed if we are very certain that we have no exposures that would cause harm to those who might come in contact with it, so the decision--this piece of information is one piece of the scientific data that needs to be examined to make a good decision about this compound, but obviously a very important piece." [5]

How could EPA ever determine "uses that are safe?" How could EPA ever become "very certain" that "we have no exposures that could cause harm?" Science simply can never provide such assurances. So EPA will rely on--what else?--risk assessment.

How can we really be sure that no humans or wildlife will be harmed by Vinclozolin? There's only one way: Don't use any Vinclozolin. Pollution prevention.

===============

[1] Joseph V. Rodricks, CALCULATED RISKS (New York: Cambridge University Press, 1992; paperback edition, 1994).

[2] Wiles testimony in HEALTH EFFECTS OF ESTROGENIC PESTICIDES; HEARING BEFORE THE SUBCOMMITTEE ON ENERGY, COMMERCE AND ENVIRONMENT OF THE [HOUSE] COMMITTEE ON ENERGY AND COMMERCE... OCTOBER 21, 1993 SERIAL NO. 103-87 (Washington, D.C.: U.S. Government Printing Office, 1994), pgs. 29-37.

[3] Gray testimony in HEALTH EFFECTS..., cited in note 2 above, pgs. 123-126.

[4] Colborn testimony in HEALTH EFFECTS..., cited in note 2 above, pg. 38.

[5] Goldman testimony in HEALTH EFFECTS..., cited in note 2 above, pg. 127.

#378: Today's Toxics Policies Are "Ethically Unacceptable," Says Great Lakes Commission

=======================Electronic Edition========================
RACHEL'S HAZARDOUS WASTE NEWS #378 
---February 24, 1994---
News and resources for environmental justice.
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P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
==========
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========================Original Source========================

The long-awaited 7th biennial report of the International Joint Commission (IJC) was issued last week. The IJC is a government body with responsibility for maintaining and restoring environmental quality in the Great Lakes. Past IJC reports have recommended policies that, taken together, define an entirely new approach to the problem of persistent toxic substances.

The 7th IJC report once again calls for:

** phase-out ("sunsetting") of all persistent toxic substances from the Great Lakes ecosystem;

** a ban on the manufacture and use of chlorine;

** an end to reliance on risk assessment;

** a ban on solid waste incineration;

** a reversal of the policy that assumes chemicals are innocent until proven guilty;

** adoption of the principle of precautionary action (which says: wherever it is acknowledged that a practice could cause harm, even without conclusive scientific proof that it does cause harm, the practice should be prevented and eliminated);

** An end to chemical-by-chemical regulation, substituting an approach that eliminates whole classes of chemicals by "strategically preventing the formation of the persistent toxic substance in the first place."

The IJC defines toxic substances as anything that can "cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological or reproductive malfunctions or physical deformities in any organism, or its offspring, or which can become poisonous after concentrating in the food chain or in combination with other substances." The IJC defines a PERSISTENT toxic substance as one with a half-life in any medium (air, water, soil, sediment, or living things) greater than 8 weeks, or one that bioaccumulates in the tissue of living organisms. The half-life of a substance is the time it takes for half of the substance to degrade, go away or disappear.

The 1978 Great Lakes Water Quality Agreement, signed by the federal governments of the U.S. and Canada, insists that, "The discharge of toxic substances in toxic amounts be prohibited and the discharge of any or all persistent toxic substances be virtually eliminated." In its SIXTH BIENNIAL REPORT in 1992 the IJC said, "This statement is the cornerstone of the Agreement."

The 7th IJC report says that "conventional scientific concepts of dose-response and acceptable 'risk' can no longer be defined as 'good' scientific and management bases for defining acceptable levels of pollution. They are outmoded and inappropriate ways of thinking about persistent toxics," the report says.

The production and release of [persistent toxic] substances into the environment must, therefore, be considered contrary to the [1978 Water Quality] Agreement legally, unsupportable ecologically, and dangerous to health generally. Above all, they are ethically and morally unacceptable," the report says. It goes on to stress the need for a zero discharge policy for persistent toxic substances: "The limits of allowable quantities of these substances entering the environment must be effectively zero, and the primary means to achieve zero should be the prevention of their production, use and release, rather than their subsequent removal."

The IJC was created in 1909 by the governments of Canada and the U.S. to oversee the Boundary Waters Treaty, which guides Great Lakes-related behavior of the two nations. Starting in 1912, and again in 1945 and 1964 the IJC was asked by the two governments to report on water quality of the lakes. The studies revealed progressive deterioration. In 1972 and again in 1978 the two nations signed Water Quality 

Agreements aimed specifically at improving water quality in the lakes. The goal of the 1978 Agreement was broad: "to restore and maintain the chemical, physical and biological integrity of the waters of the Great Lakes Basin Ecosystem." It is up to the IJC to manage and monitor efforts to achieve the goals of the 1978 Agreement. In 1981, the IJC began issuing a report every two years, describing the condition of the lakes in relation to the goals of the 1978 Agreement.

The new (7th) report says, "The theme of this report is that the time has arrived for a major shift in the way decision-making takes place for the Great Lakes ecosystem. In particular, society must adopt a clear and comprehensive action plan to virtually eliminate persistent toxic substances that are threatening human health and the future of the Great Lakes ecosystem."

Early in the report, the IJC asks what might happen if people refuse to control persistent toxic substances? Here is a long, verbatim quotation from the report:

"We do not know what ALL of the effects of human exposure will be over many years. Future research will clarify whether low-level and long-term exposures, repeated exposures, or isolated short-term exposures at sensitive stages of fetal development are most critical. For the Commission, however, there is sufficient evidence NOW to infer a real risk of serious impacts in humans. Increasingly, human data support this conclusion.

"The questions then become: what--if any--risks of injury are we as individuals and as a society willing to accept? How long can we afford to wait before we act? Why take any risks of having such potentially devastating results? In this vein, the Commission poses a number of other specific but very fundamental questions:

"** What if, as current research suggests, the startling decrease in sperm count and the alarming increase in the incidence of male genital tract disorders are in fact caused in part as a result of IN UTERO [in the womb] exposure to elevated levels of environmental estrogens?

"** What if, as current research suggests, the epidemic in breast cancer is a result in part of the great numbers and quantities of estrogen-like compounds that have been and are being released into the environment?

"** What if the documented declining learning performance and increasing incidence of problem behaviour in school children are not functions of the educational system? What if they are the result of exposure to developmental toxicants that have been and are being released into the children's and parents' environment, or to which they have been exposed IN UTERO [in the womb]?

"The implications of ANY of the above questions being answered in the affirmative are overwhelming. The implications of ALL of the above questions being answered in the affirmative are catastrophic, in terms of human suffering and the potential liability for that suffering and attendant health costs. Mounting evidence points to the latter possibility. Surely, there can be no more compelling self interest to force us to come to grips with this problem than the spectre of damaging the integrity of our own species and its entire environment," the IJC said.

The new report puts risk assessment into perspective: "Risk assessment is useful in decision-making, especially in setting action priorities, but is not directly relevant to the basic virtual elimination commitment. The Commission does not accept the argument that the elimination of persistent toxic substances should be subject to a risk-benefit calculation, as that is not the approach of the [1978 Great Lakes Water Quality] Agreement," the report says.

Users and producers of persistent toxic substances had told the Commission that phase-out of toxic substances would cause job loss outweighing any long-term health benefits. They said risk-benefit analysis showed that virtual elimination of persistent toxic substances would not pay. The Commission rejected that argument explicitly, saying, "to continue resisting a strategy that changes our production and consumption habits and moves away from reliance on persistent toxic substances, will be disastrous in the long term from all perspectives."

The Commission called upon industry representatives to stop denying toxics problems and to focus on solutions: "Representatives of industry, when presented with evidence of ecosystem health concerns about substances used in commerce, should react by embracing open dialogue, data sharing and fact finding, to resolve rather than deny, concerns and effect an orderly and timely transition to those solutions," the IJC says.

The Commission called for an end to incineration anywhere in North America that could affect the Great Lakes: "A growing number of incinerators operate within the Great Lakes region, contributing significantly to the load of contaminants, especially from the low-temperature incineration of industrial, commercial and household refuse containing plastics and solvents, coated papers and many other products," the report says. "Any strategy towards virtual elimination and zero discharge of persistent toxic substances must address the significant inputs from incineration," the report says. "The Commission urges the stringent regulation of existing facilities throughout North America, taking into account the need to ensure the zero discharge of persistent toxic substances from those stacks to the Great Lakes."

The report calls upon "Governments, industry and labour [to] begin devising plans to cope with economic and social dislocation that may occur as a result of sunsetting persistent toxic substances." It calls upon "Labour unions [to] include in their negotiations the issue of transition to a sustainable economy without persistent toxic substances." And it calls upon citizens to get involved: "Citizens should constantly ask political, social and industrial leaders about the effects of the use and discharge of pollutants on this and future generations," the report says, noting that "The patience of many citizens seems to be near a breaking point."

"Maintaining a healthy society means more than failing to discover disease," the report says.

GET: International Joint Commission, SEVENTH BIENNIAL REPORT ON GREAT LAKES WATER QUALITY (Washington, DC and Ottawa, Ontario: International Joint Commission, 1994), 58 pages, available free from the International Joint Commission, 1250 23rd Street, N.W., Suite 100, Washington, DC 20440; telephone: (202) 736-9000.

  --Peter Montague, Ph.D.

Descriptor terms: international joint commission; ijc; waler quality; water pollution; treaties; cn; canada; u.s.; regulation; toxic substances; toxics; sunsetting; chlorine; incineration; bans; zero discharge; reverse onus; precautionary principle; principle of precautionary action; persistence defined;