Robert, et. al.
I will just add my final comments on the discussion and then forever hold my peace (at least on this topic).
While there are hundreds of examples of EPA overreach, I would just submit that the proposed regulation of any intermittent bodies of water such as water in a ditch or tiny temporary pond on a farmers field as being part of the Clean Water Act [Waters of the United States] would be a disaster (except for environmental consultants writing permits and taking water samples). This will be decided by the Supreme Court soon. Never fear my regulation loving friends, the EPA issued over 3900 new regulations (33,000 new pages in the Federal Register) during the Obama Presidency.
The Precautionary Principle has some merit which I will not discuss here. What is more important is the concept of those 100 million+ chemicals that Rob discusses for which "-it seems appropriate to assume that an unknown or untested chemical is harmful-". If the testing is dose-response, then we have full employment for all the Worlds Scientists for infinity. If you take the other approach that has been discussed-zero exposure-then it is simply a question of analytical sensitivity. I would submit with all my clever colleagues out there, you would be very hard pressed to find anything at the zero exposure level.
I leave you with this quote:
Hygiene is the corruption of medicine by morality. It is impossible to find a hygienist who does not debase his theory of the healthful with a theory of the virtuous. The aim of medicine is surely not to make men virtuous; it is to safeguard them from the consequences of their vices.
- H. L. Mencken
In 'The Physician', Prejudices: third series (1922), 269.
Zack
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of ILPI Support
Sent: Thursday, February 28, 2019 2:52 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Scientist says some pollution is good for you - a disputed claim Trump's EPA has embraced
I've enjoyed the musings and reparte on this. As a non-toxicologist my thought is this:
There are untold numbers of unique chemical substances, most of which are man-made which means, by definition, neither man nor the environment has co-evolved with them and established a natural equilibrium. Therefore, most of these are likely to have unknown and/or unexpected consequences (PFOA's, BPA, MTBE, PAH's PCB, etc as a few quick examples) because our bodies and the environment have not evolved mechanisms to deal with them at any level. In comparison, there are a handful of specific basic chemical building blocks that fit the criteria of being beneficial at the right dose - vitamins, trace elements etc.and our bodies and ecosystem have learned to benefit from or rely on these only after hundreds of thousands of years of evolution. And there are a similar number of "unnatural" products (e.g. medicines) that happen to interact in the right way to cause good (but often with a panoply of other undesired side effects) but only at the right level.
So if we put known "good" chemicals and drugs (again, somehow miraculously delivered in the exactly right dose for the exact population which requires them without inappropriately dosing anyone else) in the numerator and the 100 million+ compounds we know nothing about in the denominator, the results is effectively 0% of unknown compounds will be good for you at any level. While there certainly may be a chance that one is good for you at low levels the *probability* is vanishingly small. Right up there with finding a Goldilocks planet with life on it.
Therefore, it seems appropriate to assume that an unknown or untested chemical is harmful until proven otherwise. The burden of proof rests with the polluter to offer scientifically valid evidence to the contrary, ideally work performed by independent scientists.
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Just to stir the pot a little, I once read (years ago, and can't remember the source) that the radiation exposure during the horrific atomic bomb explosions in Japan, while for the most part quite deleterious, of course, were actually therapeutic in small doses to people far from the blast. (Sounds more like the radium craze of the early 1900s, I know, but it was an interesting article.)
Mark Adolf Pichaj • Assistant Professor • Department of Chemistry, Physics & Engineering • Lim 324 • x4866
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This discussion reminds me of the current conversation about oversight of DOE. The DOE has recently proposed order 140.1 which would significantly limit the Defense Nuclear Facilities Safety Board (DNFSB) oversight of the DOE and their contractors. This in light of many employee and public health issues that have occurred. Seems to me that we need more of these independent safety boards like the Chemical Safety Board (CSB) & DNFSB and not less.
With regards,
Michael N. Cooper MS, MPH, CIH
Certified Industrial Hygienist
I have to agree with Zack on this issue and we can all point to specific instances where something not right happened.. How about the EPA rushing thru rules in the last few weeks of the Obama administration without review or how about the mine flood with arsenic where no one at EPA was accountable and on and on from both scientific and political positions. We need the proper analysis of environmental problems with appropriate solutions not overboard either way with too much or not enough action. I too know several people at the EPA with whom I have worked with over the years and they are very good at what they do but oversight is needed.
The EPA has been out of control for years and needs to be reformed so that they can continue to achieve their mission without hysteria from the press.
I just couldn't let this pass. It is never "the EPA" that is out of control. Take some EPA employees to lunch. You will find that 90% of the employees in EPA are people like you and me, people just trying to do a job. What needs to be controlled is the politicians in power and the industries that own them.
When the wheels came off EPA's bus after the 9/11 building collapse, it was only the head of EPA, Whitman, who told people the air was safe as her handlers demanded. The individual EPA workers shook their heads in disbelief and often told us the truth off the record. And I happen to be a long-time friend of one of the whistleblower employees to went through hell trying to let people know the truth.
The curse of this representative republic is we get exactly what we vote for.
-----Original Message-----
From: Zack Mansdorf <mansdorfz**At_Symbol_Here**BELLSOUTH.NET>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Thu, Feb 28, 2019 5:30 am
Subject: Re: [DCHAS-L] Scientist says some pollution is good for you - a disputed claim Trump's EPA has embraced
This is total junk science. The entire field of industrial hygiene is based on the dose response model. To assume that any "toxic" has a zero threshold is crazy. The best example is the trace minerals that are necessary to support human life. My morning dose of caffeine is heart healthy but probably carcinogenic just like the alcohol in my red wine. Paracelsus said way back in the late 1400's that "-"Everything is a poison, nothing is a poison. It is the dose that makes the poison"
The point is that we do need to regulate air pollutants in a sensible manner that considers cost/benefit. The EPA has been out of control for years and needs to be reformed so that they can continue to achieve their mission without hysteria from the press.
To verify the actual toxicity of various pollutants/particulates, we need to have the data on human clinical trials, not on other species According to recent UNO report, 4.2 million deaths occur each year due to air pollution. Also, how we are going to measure low and high pollution.
This will be a good puzzle for Dr. Alan Hall, a toxicologist to interpret reported toxicological data published in peer review journals about some pollution is good for humans.
The title of this LA Times article speaks for itself. Interesting to hear what "mainstream" toxicologists have to say on this.
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