Putting the Public into Alternatives Assessment
This essay is in response to: How can innovations in technology and research reduce exposures to toxic chemicals?
Progressive health experts, community
leaders, and workplace safety specialists have long recognized the need to
replace dangerous chemicals with safer ones in order to protect human health
and the environment. Forward-thinking experts have advocated that many
industrial and workplace hazards could be eliminated or reduced through the thoughtful
incorporation of inherently safe (or safer) materials and technologies. Properly conducted, the alternative
assessment framework offers a robust scientific approach to assessing the
safety of alternative chemicals, materials, and products to replace harmful
ones. Alternative assessment is necessary if we are to transition our economy
away from its current over-reliance on hazardous and polluting materials.
However, if such assessments are not conducted in a manner that is transparent,
consistent, and inclusive then they will be subject to many of the same manipulations
and suspicions that plague current risk assessment decisions.
can include replacing a hazardous chemical with a safer one, replacing a
particular technology so that hazardous chemicals are no longer required, or
redesigning a product so that the chemical is no longer needed. It doesn’t
necessarily mean using completely benign chemicals. For example, a rocket fuel
propellant may have to be combustible, but it doesn’t also need to impair
hormone activity. The little batteries in children’s shoes that light them up
don’t have to contain mercury to do the job. An alternative assessment can help
identify safer replacement chemicals, or even non-chemical alternative
processes or products. In all cases, care must be taken to make sure that the
assessment of alternatives is thorough, so that risk-trading is at least
downwards and not just from known to unknown risks.
assessments can be extremely complex, the public must have timely, accurate,
and accessible information about what goes into the assessment, including
assumptions, extrapolations, uncertainties, and knowledge gaps. Risks
are not just measured or calculated or estimated or modeled – they are also
experienced, and not usually by the risk assessors, experts, or representatives
of the polluting industry.
The corruption of
information by regulated industries and their paid experts has led to the
corruption of public knowledge about the risks that come with public exposure
to toxic substances. There are many published accounts of chemical industry
attempts to subvert regulations through interference with government risk assessments,
withholding critical information, selective release of incomplete data, and
endless efforts to delay a risk assessment by claiming that more data is
coming. In addition, collaborations between industry and government have
contributed to the imbalance of information and power.
With inaccurate information,
regulators and the public are ignorant or misinformed about the risks
associated with exposures to potentially hazardous materials, leading to
ineffective evaluations of risks and alternatives.
alternative assessments would drive the innovation of sustainable and
socially-beneficial materials and safer technologies. Unfortunately, the Toxic
Substances Control Act (TSCA), our nation’s failed law for regulating hazardous
substances, needs to be rewritten to effectively apply alternatives assessments
to prevent unnecessary exposure to harmful new and existing chemicals where
safer alternatives are available. The Safe Chemicals Act of 2010, introduced by
Senator Lautenberg in April, would require EPA to establish incentives for the
development of safer alternatives, including market incentives for available
alternatives and a research grant program to develop new ones for priority
hazardous chemicals. The House bill, called the Toxic Chemicals Safety Act of
2010, introduced in July by Representatives Rush and Waxman, establishes a
review process for safer alternatives to existing chemicals, and additionally
requires new chemicals to be proven safe before they enter the market. If
Congress passes strong chemical reform legislation then in addition to creating
a market advantage for safer alternatives, it will create ‘green’ job
opportunities conducting alternative assessments.
For more on Alternatives Assessment Frameworks see: http://www.chemicalspolicy.org/alternativesassessment.lowellcenter.php
For more on TSCA reform policies
Meticulously documented examples of
data manipulations by the chemical industry are reported in the following books
and report: Doubt Is Their Product:
How industry’s assault on science threatens your health (Michaels, 2008); Deceit
and Denial: The deadly politics of industrial pollution (Markowitz and
Rosner, 2002); and, Rewriting the Rules: The Bush administration’s assault
on the environment (NRDC, 2002).
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