Environmental Risk Archives

In an open letter to Greenpeace International, Richard Tren, Director of the organization "Africa Fighting Malaria", calls on Grenpeace to clarify its stance on the use of DDT for controlling malaria, and asks that it account for what it has done to follow through on its stated commitment "to seeing more effective methods for combating malaria" -- presumably because DDT is either ineffective or is saddled with unacceptable side effects.

Excerpts from the full letter follow:

[O]ver 1 million people, mostly children, die from malaria every year, and the parasites cause approximately 500 million cases annually. A highly effective method of malaria control is to spray small amounts of insecticide on the inside walls of houses -- a process known as Indoor Residual Spraying (IRS) … DDT is one of the most effective public health insecticides for IRS programs ...

Thousands of studies into the possible human health effects of DDT have failed to definitively demonstrate any actual human harm attributable to DDT. [Comment by IMGrant: This is not for lack of trying. Researchers have tried to pin some adverse public health effect on DDT for half a century, and yet failed to come up with something definitive. This suggests that if DDT has an adverse impact on public health, it's pretty minor. In this case, the answer to Sherlock Holmes' question as to "why the dog didn't bark" is that there probably was no dog in the first place.] Given the colossal burden caused by malaria, any rational risk-benefit assessment would conclude that DDT should be used. [Aside: Indeed Richard Tren is right on this one. See: Indur M. Goklany, The Precautionary Principle: A Critical Appraisal of Environmental Risk Assessment (Cato Institute, Washington, DC, 2001), available from Amazon.]

Due to its ongoing efficacy and its long record of safe use in malaria control, many countries continue to use DDT. Others, such as Uganda and Tanzania, are attempting to revitalize their IRS programs and use DDT, other insecticides and other interventions. The use of DDT in this way is specifically authorized by the Stockholm Convention on Persistent Organic Pollutants (POPs) and is recommended by the World Health Organization (WHO).

On 2 August, 2006, Australian Broadcasting Corporation (ABC) ran a story on the World Health Organization's (WHO) endorsement of the public health insecticide DDT for malaria control. The report quoted Greenpeace scientist Dr David Santillo's reaction to the endorsement:

"That certainly raises some quite substantial concerns and, if there's substantial funding coming from the US to support that, then that does sound very much like a step in the wrong direction … I think where that funding is better placed is in developing the availability of alternative strategies.

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CEI's Angela Logomasini assesses efforts to improve chemical plant security.

Indur Goklany's review of Cass Sunstein's Risk and Reason recently appeared in Politics and the Life Sciences. Goklany broadly endorses Sunstein's diagnosis of the regulatory state, and generally shares his view that cost-benefit analysis (CBA), despite its reliance on technocratic expertise, far from being undemocratic is, in fact, critical to developing better [and more reliable] information, without which, in Sunstein's words, "neither deliberation nor democracy is possible."

Goklany, however, takes a much more skeptical view of the achievements of 1970s evironmentalism than does Sunstein. He notes:

One cannot, however, embrace Sunstein's evaluation of 1970s environmentalism... with equal enthusiasm. Clearly it has significantly improved America's quality of life, but progress toward solving its worst environmental health problems was well underway before 1970. Between 1900 and 1970 the death rate due to various water-related diseases (typhoid and paratyphoid, various gastro-intestinal diseases, and dysentery) dropped from 1,860 to below 10 (per million), an improvement of 99.5 percent. The Clean Water Act and the Safe Drinking Water Act, however, date to 1972 and 1974. Similarly, substantial air quality improvements preceded the 1970 Clean Air Act (CAA) for those pollutants and areas where they were of greatest concern. In many cases air quality improved faster before, than after, 1970, something glossed over in EPA's retrospective analysis of the CAA, and Sunstein's review of that study.

Moreover, the 1972 DDT ban, one of 1970s environmentalism's signal achievements, reduced global DDT production, and stigmatized its use. The subsequent reluctance of international aid agencies to fund its use contributed to malaria's resurgence in developing countries, with especially tragic consequences for Sub-Saharan Africa whose malarial death rate, which had dropped from 1,840 to 1,070 (per million) between 1950 and 1970, rebounded to 1,650 in 1997, corresponding to an increase in absolute deaths from 300,000 in 1970 to a million in 1997. This increase in malaria, and its effects on human productivity, is one reason why Sub-Saharan Africa is one of world's few regions where life expectancy declined, and poverty and hunger increased, over the past decades.

The review also raises fundamental questions regarding the "standard" levels of protection against cancer causing risks that are used in risk analysis:

The reader would surely have benefited had Sunstein applied the same intellectual rigor and clarity of thought that permeate this book to some fundamental questions raised by his diagnosis of the current regulatory state. For instance, what is the significance of protecting against a lifetime increase in cancer of 1-in-1,000 or 1-in-1,000,000 (as agencies attempt to do) when the lifetime risk of dying from (as opposed to contracting) cancer in the U.S. is currently 1-in-4.5, and the lifetime risk of dying is 1-in-1 (p. 135)? Moreover, regardless of what value is assigned to a life, is it justifiable for society (as opposed to private parties) to assign in a CBA, say, $6 million to "save" a life if more lives could be "saved" at the same cost via other means?

Goklany also raises the question as to how -- or whether -- success or failure of risk regulation can be meaningfully measured:

Sunstein's scheme for reforming the regulatory state also doesn't address how, or even whether, success or failure of risk regulation can be measured post facto. Without such measurements accountability and mid-course corrections are virtually impossible.

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At the Campaign for Fighting Diseases website, Richard Tren, director of Africa Fighting Malaria, writes that German chemical company Bayer has supported the European Union's threats against Uganda should the country decide to use DDT in its malaria control programme.

Not only is this scandalous -- it is a major conflict of interest. Tren points out that "[A Bayer representative] sits on the board of the World Health Organization's Roll Back Malaria (RBM) coalition - as do other commercial contractors to US Agency for International Development (USAID)."

Tren is a signatory to the Kill Malarial Mosquitoes Now (KMMN) declaration, what Tren calls "A new coalition which has emerged in the US to focus the minds of USAID in their malaria control efforts."

IPN has just published a new book co-authored by Gary Marchant, a professor in both the Arizona State University law school and school of life sciences. The book - Arbitrary and Capricious: The Precautionary Principle in the European Union Courts - explores how the principle has been employed in over 60 court decisions. Marchant concludes:

No one can argue against being safe rather than sorry. But the precautionary principle is flawed in theory and practice, and its enshrinement sets Europe down a path that will wreak havoc on the economy and public health of not only itself but also its trading partners.’

Today, Gary has an article in the Wall Street Journal Europe - "Unprincipled Precaution" (link to article on IPN's website) - which explores some of the book's themes. [for WSJ subscribers - original link]

by

Indur M. Goklany

We are constantly bombarded with claims that weather-related events will get worse over time, at least in part because of global warming. So one should expect that aggregate deaths and death rates due to weather-related extreme events worldwide would have trended upward in recent decades.

But do they?

The following bar chart shows (approximate) aggregate trends in these critical measures between 1900 and 2004 for "weather-related extreme events", namely, droughts, extreme temperatures (both extreme heat and extreme cold), floods, landslides, waves and surges, wild fires and wind storms of different types.[1]

Yes, there is a trend here, but is it upward?

This, of course, begs the question as to why, if the globe is warming, matters aren't getting worse?

Curves like this illustrate that due diligence requires that analyses and/or claims of future impacts should be accompanied, at a minimum, by checks of whether their future projections match with past reality. Of course, as your mutual fund advisor will tell you, "past results are not necessarily indicative of future performance." True, but one should have to reconcile the two, matching the past and the present with the future. And this goes not just for impacts (e.g., deaths and death rates) but also assumptions that feed into impacts assessments. For example, how reasonable is an assumption of 1 percent growth per year in carbon dioxide concentrations when historically it has averaged 0.40 percent per year from 1959 to 2004, during which period it only once exceeded 0.75 percent (year-to-year increase)?

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Thirty leading British scientists have condemned The Lancet, a prestigious British medical journal, for "scare-mongering" and "desperate headline seeking," according to this report in the London Times. (Link via The Corner.)

"Under the editorship of Richard Horton, the publication of badly conducted and poorly refereed scare stories has had devastating consequences for individual and public health, in the UK and abroad, and carried a high economic cost,” read a statement signed by thirty fellows of the Royal Society, including two Nobel Laureates. In recent years The Lancet has published several controversial papers that have had to be retracted or qualified after publication, including studies purporting to show helath risks from the measles, mumps, and rubella (MMR) vaccine and GMO potatoes.

This is not an April Fool's joke. As the NYT reports, environmental groups are largely happy with the EPA's new cancer guidelines. Might this, in itself, be a reason to worry?

In theory, the unfunded mandates reform law passed in the 104th Congress prevents the imposition of new unfunded mandates. The Safe Drinking Water Act was also reformed in 1996 to give local water systems more flexibility and further lighten the mandate burden. But some are not sure it worked out that way.

When I was out in Oregon last weekend I noticed this editorial decrying EPA rules requiring additional water filtration systems to address the virtually non-existent cryptosporidium threat in Portland's water supply. According to the Oregonian:

The risk of contracting crypto from drinking Portland tap water is close to zero. Not zero, we should emphasize, because it could theoretically happen, but the odds are against it. It's not something to sit up nights worrying about. And it's not something that ratepayers of the Portland Water Bureau should invest up to $60 million or more to eradicate.

It is one thing for the EPA to inform local communities about potential risks in local water supplies. It is quite another to force local communities to adopt "protective" measures that are unwanted and may come at the expense of other, more important local priorities.

The editorial was headlined "GOP Should Help City Get Waiver." Perhaps. On ther other hand, maybe politicans of both parties should find ways to grant state and local governments greater flexibility in environmental policy.

Does anyone know the current state of hair sample testing for mercury? It would appear that Greenpeace is still running its nationwide campaign to encourage people to pay $25 for a mercury hair testing kit.

According to a WebMd story from a few years back, there are serious concerns about how accurate hair sampling is as a testing method. So I am curious whether hair sampling has improved its reputation or whether the interim results from Greenpeace should be considered questionable.

My guess is that $25 might be better spent as part of a mammagram, prostate exam, or even a dentist appointment.

Besides purchasing a kit, Greenpeace recommends that you host a mercury testing house party. Who's in the house!!!?? Merc- merc. Who's in the house? Mercury!!!

Those folks at Greenpeace know how to have a good time, but they fail to leave enough instructions on how to really whoop it up. When I throw my mercury testing parties, I like to make it a theme night, so be sure to have something from one of the Mercury Record labels playing in the background. For instance, Bob Marley or Bon Jovi as artists of Island Records, a Mercury label, really spice things up. Then, I like to serve lots of fish. Finally, everybody takes a shower using Aveda Products, in honor of the company's sponsorship of the Greenpeace hair testing project. If you aren't having fun by that point, well, down a few bottles of Mercury Rising and call me in the morning.

The monstrous and tragic events of September 11, 2001 continue to reverberate throughout public policy. Environmental policy is no exception. This was the subject of the Environmental Law Section panel, “Democracies Die Beyond Closed Doors: Secrecy in the Age of Terrorism,” at the Association of American Law Schools annual meeting. Moderator and University of Maryland law professor Rena Steinzor opened the session noting that concerns about terrorism and homeland security has both pushed environmental policy to the back-burner and heightened Washington, D.C.’s natural tendency toward secrecy. Environmentalist efforts to require disclosure of information about environmental risks have been set back substantially due to security concerns. More broadly, courts and the public are arguably more sympathetic to arguments about the need for executive branch secrecy. To given one example, Professor Steinzor noted a proposal to withhold disclosure of critical infrastructure information from Department of Homeland Security environmental impact statements.

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Nick Kristof begins today's NYT column thusly:

If the U.S. wants to help people in tsunami-hit countries like Sri Lanka and Indonesia - not to mention other poor countries in Africa - there's one step that would cost us nothing and would save hundreds of thousands of lives.

It would be to allow DDT in malaria-ravaged countries.

Of note, none of the environmentalists Kristof called was willing to oppose DDT use across the board. Even Rick Hind of Greenpeace -- the group that has called for phasing out the use of all chlorine compounds for any purpose -- said "If there's nothing else and it's going to save lives, we're all for it. Nobody's dogmatic about it." Now that's progress.

A recent article published in the LA Times reports that researchers have found air pollution is reducing mountain snowfall, a critical source of water for the West. The entire article is found here. The gist of the aricle is that pollution--primarily particulate matter acting as nucleation sites--reduces the amount of snow fall by reducing the water content of individual snow flakes. The dire warning is that the West will likely run out of water by continued air pollution.

This study of course raises the question of whether historical seeding efforts have been successful or a waste of time (I think not.) More importantly, it fails to recognize the historical downward trend in pollutant loading overall.

Reaction to an EPA announcement on mercury and river fish yesterday, exemplified by USA Today's lead story today, Warnings on river, lake fish jump (note that the print headline is different from the more circumspect web headline), could reasonably be described as alarmist. Take the first paragraph in the USA Today story, for example:

One third of the nation's lake waters and one-quarter of its riverways are contaminated with mercury and other pollutants that could cause health problems for children and pregnant women who eat too much fish, the Environmental Protection Agency said Tuesday

(Emphasis added). As the story notes, the warnings are not about fish in general but about fish caught from those particular lakes and rivers. Nowhere in the story is it estimated how many women eat so much river-caught trout that they may be at risk.

Moreover, as the story intimates, the "jump" in the headline is probably an artifact of increased reporting in two states. The EPA fact sheet (PDF link) says quite clearly (p.4):

In 2003, the geographic extent of the states under advisory for mercury was 13,068,990 lake acres and 766,872 river miles. The increase in acres and river miles under advisory is a result of the issuance of statewide mercury advisories by Montana and Washington in 2003 and the addition of rivers to Wisconsin’s statewide advisory.

All of which makes this statement from the Sierra Club outright misleading:

Today the Environmental Protection Agency announced in its 2003 National Listing of Fish and Wildlife Advisories that 766,872 miles of America's rivers and 13,068,990 lake acres are contaminated with so much poisonous mercury that the fish aren't safe to eat -- that is a more than 60 percent increase for river miles and an eight percent increase for lake acres since the 2002 report.

This increase is astounding considering that the technology exists right now that would put us on the road to cleaning up 90 percent of toxic mercury emissions from coal-fired power plants by 2008. As America's waters get more contaminated, the Bush administration continues dragging its feet, even endorsing a plan that would delay cleaning up mercury emissions from power plants for at least a decade and setting targets so weak that the industry will be allowed to emit three times more mercury after 2018.

Mercury emissions in the US for which humans are responsible dropped from about 375 tons per year in 1989 to 117 tons per year in 1999*.

Moreover, the EPA's health warnings themselves are based on studies from the Faroe Islands which inadequately controlled for the Islanders' diet, which contained a fair proportion of whale meat. A useful discussion of the science underlying EPA's guidelines on mercury and health is available here (PDF link).

The actual basis for the alarmist reaction is flimsy, to say the least.

UPDATE: Environmentalist blogger JLowe agrees that the Sierra Club reaction is inappropriate.

* Corrected from earlier numbers.

"Most asbestos lawsuits in the United States are being brought by claimants who are probably not sick," according to a new study, Nature reports. According to the study, expert witnesses in asbestos cases are vastly overstating the extent of alleged asbestos-related harms.

Robert F. Kennedy, Jr. has been known to make exaggerated claims -- utterly ridiculous, completely laughable statements -- about environmental issues.

This quote from him may explain why:

I have so much mercury in my body right now, having tested it recently, that if I were a woman of childbearing years, my child, according to Dr. David Carpenter, the national authority on mercury contamination, would have cognitive impairment -- permanent IQ loss.

Hmmm....

In the same interview, from Grist magazine, the following exchange occurs:

Grist: So if you were to tell our readers the single most important environmental action they should take, what would it be?

Kennedy: If your choice is to buy a Prius or go work for a politician who is going to implement the CAFE standards, you better work for the politician. The most important thing you can do is participate in the political process. Support the environmental groups that wage legal action and lobby for these bills. Get rid of the politicians who are whoring for industry. It's more important than recycling. It's more important than anything you can do.

So rather than drive a small, fuel-efficient car, Kennedy advises, it is better for you to vote for a politician who will force you to drive a small, fuel-efficient car.

Why not eliminate the middleman?

That is, if you want to take your life in your hands. In 2002, the U.S. government's National Academy of Sciences released a report (Effectiveness and Impact of CAFE Standards 2002) saying that since CAFE standards were imposed in 1975, an additional 2,000 deaths per year can be attributed to the down-sizing of cars required to meet these fuel efficiency standards.

The National Center has a webpage devoted to fuel economy standards, our Fuel Economy Information Center. Stop by and take our quick poll: Should CAFE standards be raised, lowered or left where they are?

Do ice cream sales cause rape? Of course not. Yet, as Eugene Volokh points out, ice cream production strongly correlates with the incidence of rape. The statistically signficiant incidence is 0.84 (perfect correlation would be 1.0). An astute reader might surmise that rates of rape and ice cream production appear to correlate because they are each correlated with something else: warm weather. The incidence of each climbs dramatically in the summer -- and that is where the connection ends. Correlation does not equal causation.

This is equally true when talking about chemicals and the environment. Many of the correlations between industrial activities and various health or environmental problems that purportedly "demonstrate" causation are equally bogus. It takes more than a pattern to demonstrate that a given substance is responsible for a given harm.

State Farm Insurance is telling those in the wildland-urban interface to engage in some preemptive protection for wildfires or risk losing their insurance.

Joe Bast, president of The Heartland Institute, has a very interesting transcript on his website. It is from a speech he gave about environmentalism to the Libertarian Party Convention.

Among other things, Joe addresses the current state of the environment, his past as a self-described "hippie freak" and critiques a talk given earlier at the convention by the executive director of the Sierra Club.

Anyone interested in environmental issues will enjoy the transcript from Joe's talk about Common Sense Environmentalism.