#185: Human Harm From Low-Level Exposure.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #185
---June 13, 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 ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com
========================Original Source========================

HUMAN HARM FROM LOW-LEVEL EXPOSURE.

The federal government is proposing to allow large quantities of "low level" radioactive wastes to be declared non-radioactive ("below regulatory concern," or BRC, is their phrase for it; see RHWN #183). These radioactive wastes would then be handled like ordinary household trash; they would be transported, landfilled, incinerated, reused (for example, radioactive tools) or recycled (for example, radioactive metals) along with everything else we discard each day. Such a change would expose Americans randomly to more ionizing radiation than they are exposed to today. Government and industry both argue that this is acceptable. Industry uses one justification, government uses another. Many people in the nuclear industry argue that small increases in ionizing radiation aren't dangerous at all. They argue that there is a threshold dose of radiation, below which no effects occur, and above which people may be harmed (see RHWN #184). They say the BRC program will not expose anyone to a dose of radiation greater than the threshold dose, and therefore the BRC program will cause no harm.

Government approaches the matter differently. The U.S. Environmental Protection Agency (EPA) argues that any amount of radiation causes some damage to a large population of exposed individuals; they subscribe to the "linear theory" of radiation damage (see RHWN #184). They have set limits for radiation exposure based on the moral premise that it is acceptable to kill one citizen out of every 100,000 citizens by exposing them to radiation. Since the BRC program will not cause exposures that would kill more than one in every 100,000 citizens (and the linear theory tells them that, in reality, the program will kill many fewer people than one in every 100,000), the government argues that the BRC program is acceptable because it will save billions of dollars for the nuclear power industry (which must soon dismantle its aging nuclear reactors and put them "away" somewhere) and for the government itself (which must eventually clean up millions of pounds of radioactive contamination lying around near weapons factories).

Unfortunately, there is now very substantial evidence, from studies of human beings exposed to radiation, that both industry and the government have misunderstood (intentionally or not) the dangers of low levels of ionizing radiation. (By "low levels" we mean within the range 0 to 5 rem [centi-Sievert].)

The most compelling evidence comes from studies of 91,231 people who survived the atomic bombings of Hiroshima and Nagasaki in Japan in 1945. Contrary to popular belief, most of these survivors received only very low exposures to ionizing radiation. Their health has been continuously monitored by international scientific organizations, so they represent the best available information on the effects of low levels of ionizing radiation on humans. The bomb survivor data now shows without doubt that there is no safe dose of radiation and, furthermore, that the lowest doses have caused the greatest cancer increases per unit of radiation. (In other words, the shape of the dose-response curve is supra-linear; see RHWN #184.) This means that both the industry assumption (threshold theory) and the EPA's assumption (linear theory) seriously underestimate the dangers from exposure to low levels of ionizing radiation. Furthermore, the Japanese data reveal another important fact about low-level radiation: young humans (children and infants) are more sensitive to the effects of low levels of ionizing radiation than are older humans. We will discuss the Japanese data in detail at another time.

Here we will discuss more recent human data provided by accidents that released large amounts of ionizing radiation at Chernobyl (Soviet Union, 1986), Three-Mile Island (Pennsylvania, U.S.A., 1979), and Savannah River (Georgia, U.S.A., 1970). These accidents are the subject of a shocking new book: Jay Gould and Ben Goldman, DEADLY DECEIT, cited in our last paragraph. Page numbers inside parentheses in our text refer to this book. Like the Japanese bomb survivor data, these three accidents indicate that the lowest doses of ionizing radiation cause the greatest human damage per unit of radiation. This provides confirmation that the government's estimate of the hazards of low-level radiation is low; that is to say, today's allowable limits for human exposure to ionizing radiation will allow more deaths than our government officially admits. How many more is the question. Bomb survivor data indicate 30 times more, but even this may be low, according to Gould and Goldman.

The three accidental releases of large quantities of radiation also confirm what the bomb survivor data are showing: that infants and children are the most sensitive to damage from low levels of ionizing radiation. 

Consider these facts:

The Chernobyl nuclear power plant blew up on April 26, 1986; nine days later, radioactivity monitoring stations in Washington state (9,000 miles from Chernobyl) detected radioactivity in rainfall. By May 16th, 50 EPA monitoring stations detected radioactive iodine-131 in cow's milk all across the U.S. Our government said "no problem." Now government data, analyzed by Gould and Goldman, show that in May, 1986, there was a 5.3% increase in the U.S. death rate, compared to the previous year; the chances are less than one in a thousand that this increase occurred by chance. During June, 1986, the infant mortality rate in the U.S. was 12.3% higher than it had been in June, 1985, and in some parts of the country it was much higher; for example, in the south Atlantic states, the infant mortality rate in June, 1986, was 28% higher than it had been the previous year. Based on this, and on much additional evidence that we haven't space to review, Gould and Goldman suggest that current EPA limits on exposures to low level radiation may need to be tightened by as much as a factor of 1000 (pg. 21).

In November and again in December, 1970, two nuclear rod meltdowns occurred at the Savannah River nuclear weapons plant in Georgia. The plant was operated for the government by DuPont, who never told the public anything about these accidents until Senator John Glenn grilled Dupont officials in public hearings in late 1988. To this day, DuPont claims that no radiation escaped outside the plant, but official government measurements of radioactivity in rain throughout the southeastern U.S. reveal highly suspicious increases immediately after the accidents. In South Carolina in December, 1970, rain carried six times as much radioactivity as it had carried in December, 1969. Radioactivity was also measurable in local fish; fish in the Savannah river contained radiation levels 100,000 times higher than fish sold in New York City in 1971. A child who ate 1/4 pound of catfish from the Savannah River in 1971 would have received a radiation dose equivalent to 20 chest xrays. Infant mortality in South Carolina in January, 1971, was 24% higher than it had been a year earlier; in contrast, infant mortality declined that month over the entire U.S. and over the southeastern states taken as a whole. During the following summer (May through September) infant mortality in South Carolina was 15% higher than it had been the previous year. Again, we are omitting a wealth of detail.

March 28, 1979, a meltdown at the Three Mile Island (TMI) nuclear power plant spewed more than 10 million Curies of radioactivity into the environment, most of it into the air. Because the radiation dispersed quickly, most people received only low levels of exposure. Government and industry spokespeople have repeatedly assured the public than no one was harmed. However, the government's own health data tell quite a different story. Comparing the period three months prior to the accident against the period four months after the accident, Pennsylvania's infant mortality rate increased 16% and the state of Maryland's increased 41%. All together, Gould and Goldman calculate that perhaps as many as 50,000 deaths occurred during 1980-1982 as a result of the TMI accident (pg. 63).

This is an important book. Any individual fact in the book may be disputed, but the cumulative weight of the evidence is persuasive. And though we generally do not give much credence to conspiracy theories, if you read this book from cover to cover, you will have difficulty believing that your government is telling the full truth about the effects of low-level radiation. We suggest that you act prudently to protect yourself and your family: do whatever it takes to keep BRC wastes out of your community.

Get: Jay M. Gould and Benjamin A. Goldman, DEADLY DECEIT; LOW-LEVEL RADIATION, HIGH-LEVEL COVER-UP (New York: Four Walls Eight Windows Press [P.O. Box 548, Village Station, New York, NY 10014], 1990). $19.95

And: Keep in touch with Nuclear Information Resource Service (NIRS), 1616 P Street, NW, Washington, DC 20036; (202) 328-0002, and the Radioactive Waste Campaign, 625 Broadway, 2nd floor, New York, NY 10012; (212) 473-7390.

--Peter Montague, Ph.D.

Descriptor terms: brc; radioactive waste; llw; book review; deadly deceit; tmi; three mile island; savannah river, ga; dupont; jay gould; ben goldman; radiation; health effects; hiroshima; nagasaki; nuclear weapons; chernobyl; meltdown; pa, ma; groundwater;

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

=======================Electronic Edition========================
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
==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com
========================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;