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De Omnibus Dubitandum - Lux Veritas

Tuesday, May 20, 2014

Environmentalism at Wit’s End Part II By Joseph L. Bast

Welcome to the New Paradigm, Same as the Old Paradigm

By Joseph L. Bast, February 19, 2000
A review of Joe Thornton, Pandora’s Poison: Chlorine, Health, and a New Environmental Strategy (MIT Press, 2000)

Part I - Part III - Part IV

“To cope with this new type of danger, we need a new scientific and institutional model designed specifically for synthetic chemical pollution,” writes Thornton. (343) Thornton calls this new model the “Ecological Paradigm.” Its four principles are:

#          The Precautionary Principle, which says we should not wait for scientific proof of harm before prohibiting activities that might be dangerous, so long as the advocates of prohibition are able to meet a standard of proof called “weight of evidence”;

#          Reverse Onus, which says corporations that propose to introduce new chemicals into the environment should first have to prove that they will cause no harm to anyone;

#          Zero Discharge, which says some chemicals are so very bad that no emission level is safe; and

#          Clean Production, which says it is better to eliminate the use of bad chemicals early in the production process than to regulate them at the end of the pipeline (336-349).

Readers who follow the debate over environmental policy will notice there is nothing “new” about this “new” paradigm. Indeed, all of its components were widely discussed in the 1980s. They were first brought together and called a “new paradigm” (to my knowledge) in a 1993 article in the weekly British science journal, New Scientist, written by two Greenpeace staffers and titled “How Science Fails the Environment.”

Why, if this paradigm is not new, does Thornton repeatedly represent it as being new? Well, it would be quite a coincidence that the “new scientific and institutional model” needed to cope with the newly discovered threat of organochlorides were the same one that environmentalists have been advocating for different reasons for the past two decades. What are the odds of that happening? Small enough, perhaps, to think the threat of organochlorides is being used to advance some other agenda. Better, Thornton must have thought to himself, to represent old ideas as new and bury their tracks.

A week after “How Science Fails the Environment” appeared, an answer appeared in the same journal, written by Alex Milne. “The Greenpeace approach is not anti-science,” wrote Milne, “although there is a lot of that about. But neither is it science. So what is it? It is moral philosophy at least, and religion probably. All that scientists can say to Greenpeace is: Sorry, your application for membership in the scientific community has been carefully considered -- and rejected.”

Seven years later, should Greenpeace’s application still be rejected?

The Precautionary Principle: Still Junk Science

The precautionary principle, to begin with, is not entirely wrong in its intent; indeed, it is the philosophy that underlays regulation of pharmaceuticals drugs and much of the modern regulatory state. (Some would say much of what is wrong with the modern regulatory state, but that debate is for another day.) To his credit, Thornton makes a much more serious run at making a “weight-of-evidence” case against organochlorines as a class than did Theo Colborn and other past critics. Besides presenting a circumstantial case composed of a large number of epidemiological studies, he argues a deductive case can be built on the “well-understood aspects of the chemistry of the chlorine atom itself.” (204)

In the past, Greenpeace has used the precautionary principle to smuggle into discussions flawed and unreliable studies that have been rejected by the scientific community, not because they fail to separate the effects of multiple chemicals or other faults that Thornton attributes to conventional scientific practice, but because they violate much more basic scientific standards such as honest reporting of results, sound data collection techniques, sufficient sample sizes, and replicability. Many such studies have been produced over the years, and they form the myths and legends of the culture of the environmental movement. But they tell lies.

Thornton, alas, doesn’t rise above his organization’s history on this score. He states as fact that organochlorines damage human “reproductive systems by mimicking or blocking the activity of the steroid hormones that regulate reproductive function and behavior,” (61) but it is just this claim that EPA, independent scientists, and the New York Times found unsupported. We get a superficial review of the debate over the average male sperm count, which Thornton claims today “is about half of what it was in 1940,” (120) a statement at odds with current consensus views. He airily dismisses the problems of confounding factors by not reporting the biggest ones (increased frequency of ejaculation and exposure to artificial light) and by saying Great Lakes herring gulls “do not wear tight underwear.” (127)

About those gulls . . . Thornton tells tales of the feminization of herring gulls in the Great Lakes (124) without mentioning that they feed primarily from open garbage dumps, not fish and other wildlife. Similarly, we’re told Lake Apopka in Florida shows that high doses of organochlorides caused alligators to have “extremely small penises” (123) but there is no mention of the fact that alligators migrate between lakes, so the adults at Lake Apopka probably were not born there, and male alligators are hard to distinguish from female alligators even in the absence of any supposed “gender-bender” chemicals.

Thornton reports on the rising incidence of precocious puberty among girls in the U.S., (127) but skews his report to hide the fact that only black girls are showing any change, a fact that means the phenomenon almost certainly cannot be explained by exposure to organochlorides. He reports “a small German study” and two studies of women in India that might show health effects on women of exposure to organochlorides, (131) but neglects to report a major American study showing no relationship between exposure to DDE (a product of the breakdown of DDT) and breast cancer. He admits (unlike Colborn) that “all of these studies are subject to common epidemiological problems, particularly small study populations that may not reflect the characteristics of the rest of the country and a failure to control for confounding factors,” (131) but the U.S. study of DDE was relatively free of these problems. Why did he choose not to report it?

He attributes the failure of fish-stocking efforts in Lake Michigan to PCBs, DDT, and dioxin in the Great Lakes, (137) an attribution most wildlife experts in the region would say is far from proven. Like Colborn, he relies heavily on the Jacobson study of Michigan mothers of newborns who consumed fish, (139, 144) a study thoroughly discredited by small sample size, data collection flaws, failure to control for counfounding behaviors, and lack of replication.

He tells the story of Love Canal in Niagra Falls, New York, but manages to leave out any mention of the authoritative health surveys that show no harm to any of the residents and, indeed, no misconduct on behalf of Hooker Chemical Company. (227) He claims that researchers have found evidence of synergistic effects when humans and laboratory animals have been exposed to combinations of organochlorides, (281) but never mentions the infamous Tulane study, the one attempt to gain genuine scientific credibility for the synergy claim that was withdrawn by its authors when it was revealed that they had falsified data.

In a chapter titled “Organochlorines and Cancer,” Thornton repeats claims of a “cancer epidemic” made popular by Sam Epstein, Ralph Nader, and few others during the 1970s and 1980s. He makes numerous false statements here, at least when compared with such sources as the National Cancer Institute, which recently reported that age-adjusted cancer fatality rates in the U.S. are falling, and Sir Richard Doll and Dr. Richard Peto, who recently wrote, “Overall, cancer mortality among young adults in the United States is decreasing quite rapidly, and much of the decrease cannot plausibly be attributed to improved therapy.” (Journal of the National Cancer Institute, June 1981)

Falling cancer rates are not a new phenomena: cancer morality rates for every age group under 55 fell between 1970 and 1989, and the rise in cancer rates in the 55 to 64 year-old groups was sufficiently low to produce a negative rate of change in cancer rates for the entire under-65 age cohort. (Statistical Abstract of the U.S., 1992) Only rates for the over-65 crowd show significant increases, and experts such as Doll and Peto warn that those rates are unreliable due to the rising availability of tests that allow doctors to more frequently diagnose cancers at the time of death. The picture looks even better when lung cancer cases, attributable to heavy smoking and not exposure to organochlorides, are removed from the data.

Thornton is blind to all this data. Instead, we are treated to studies in Sweden (Sweden?); alarming and unsupported claims that ozone depletion is causing epidemics of skin cancer and immune system suppression, (164-165) studies that seem to show no relationship between exposure to organochlorines but which, upon closer inspection, do; and so on.

This reviewer is neither a scientist nor sufficiently current on secondary sources to judge Thornton’s commentaries on Agent Orange, Monsanto workers accidentally exposed to dioxin, or the “25 million cases of acute occupational pesticide poisonings each year.” (300) By the time I read these accounts, my confidence in Thornton’s credibility was too low for them to make much impact on me. If he was misleading or inaccurate about issues on which I am well informed, why should I trust him on issues about which I am less certain?  The short answer is, I can’t.

Reverse Onus and Industrial Planning

Reverse Onus, the second principle in Thornton’s “new” paradigm, requires manufacturers to prove a negative universal statement -- that their new product will not cause any harm to anyone -- a logically impossible task, since new data could always be discovered that disprove the assertion. As Alex Milne wrote back in 1993, “there can be no absolute proof of ‘safety’ or ‘harmlessness’ even if we want there to be one. We have to live with risk.” At a minimum, reverse onus would discourage the process of trial and error that leads to gradual improvement in safety. The effect of reversing the burden of proof would therefore be to increase, not reduce, risk.

Thornton hears this criticism and says he would impose a lower, weight-of-evidence, standard of proof on manufacturers. (359) But the precautionary principle in the hands of industry critics trumps anything that manufacturers could say or do to defend themselves. The existence or absence of past harms, according to Thornton, is not admissible evidence in the debate over whether or not to ban future production of a product: only the possibility of injury matters. (360) If we grant some of Thornton’s many assumptions about toxicology, epidemiology, and ecosystems (discussed below), then a prima facie case can be built against virtually any manufacturing process.

Who, in Thornton’s ideal world, would put manufacturers on trial for the safety of their current and proposed products (including those unintended products of their current and proposed production processes)? “A transition planning board that includes representatives of all affected stakeholders, such as workers, communities, environmentalists, the general public, and the businesses that use and produce chlorine-based products.” (356-7)

Once the chlorine industry is placed under the people’s control and “sunset,” writes Thornton, similar boards would be created to run other industries. “In this larger context, the democratic approach like the transition planning process could be extended to evaluate other classes of substances and technologies as candidates for phaseout and to implement sunsetting procedures for the ones that are deemed ecologically undesirable.” (428) Industries on Thornton’s hit list include nuclear energy, forestry, mining, fishing, and farming. (428)

The true price of surrendering the principles of conventional science to Thornton’s “new” paradigm starts to become clear at this point. Scientists are not to be entrusted with the task of measuring risks (417, 420, 422) and business leaders are not to be entrusted with the decision of deciding what is or is not efficient. (400) Instead, we will all sit down around a big table and reach a consensus on what “our” businesses should do.

It will be a lively dialogue among “workers (a.k.a. union leaders), communities (a.k.a. non-governmental organizations), environmentalists (a.k.a. Greenpeace staffers), the general public (chosen how?), and the businesses that use and produce chlorine-based products (a.k.a the only stakeholders at the table who are risking their own capital and stand to lose money if the board’s advice turns out to be faulty).”

I pray the reader doesn’t think this reviewer is expressing doubt that such a scheme would work in practice, because I believe it would work very much as Thornton expects. The board would begin cautiously, deferring to the expertise of business leaders and the community’s desire for jobs. Then it would gradually stop approving new products and production processes, citing the precautionary principle. Then it would call for the gradual phasing out of the manufacturer’s current product line, to be replaced by a new product (market and price as yet unknown) thought by the majority of board members to pose a smaller risk to human health and burden on the environment. The manufacturer will disappear, whether through bankruptcy, simple abandonment, or stress-induced heart disease, and the anti-market environmentalist’s ideal will have been attained: No production, no consumption, no pollution, no disturbance of the global ecological system. (Part III to follow)

Joseph Bast is president of The Heartland Institute and coauthor of Eco-Sanity: A Common-Sense Guide to Environmentalism.

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