If the Environmental Protection Agency bans something, it must be dangerous, right? Well...
If you read the wording of a lot of EPA announcements and regulations carefully, you'll find that they are often issued "due to concern," etc., meaning we don't really know that X is dangerous, but we know there's been some hubbub over it, so we're issuing tighter regulations on X, a warning about X, or a gradual phaseout of X in response to public concern. If EPA's being especially responsible, they may also have taken into account some marginal, hypothetical, tentative, sketchy worries from a small subset of the scientific community.
It seems regulated chemicals, unlike people, are not innocent until proven guilty. They can be brutally suppressed on little more than suspicion of wrongdoing. But it's not this vast regulatory power I'm concerned about right now (and after the past few months of listening to arguments over Iraq, I have to admit I'm a bit tired of politics ). Almost as troubling as that regulatory power itself is the tendency of people to casually assume that the regulation of chemicals and the process of scientifically investigating chemicals are synonymous. Wrong. Each can occur independently of the other.
EPA is arguably the most powerful regulatory agency in the world. Luckily, it does allow interested members of the public to weigh in as it makes decisions, so American Council on Science and Health president Dr. Elizabeth Whelan weighed in on behalf of our organization with Comments on the Environmental Protection Agency's Draft "Guidelines for Carcinogen Risk Assessment" and the Draft "Supplemental Guidance for Assessing Cancer Susceptibility from Early-Life Exposure to Carcinogens".
ACSH's comments make the simple point that when, for instance, EPA contemplates enshrining the rule that children are to be considered ten times more vulnerable to chemicals in the environment than adults, that's a purely regulatory decision, not the scientific truth about chemicals. In fact, it's bogus on two different levels, and ACSH has a publication explaining each level:
First, it's unlikely that the tiny amounts of synthetic chemicals we typically encounter are dangerous not even the ones that can be detected in the human body, as explained in Traces of Environmental Chemicals in the Human Body: Are They a Risk to Health? Presence and harm are two different things (a point I'll make when I speak at a conference on health scares, if anyone wants to join me in London: http://www.Spiked-Online.com/PanicAttack).
Second, it is not necessarily the case that children are especially vulnerable to chemical exposure. They may even be more resistant in some cases, one of many surprising but scientifically well-supported points made in Are Children More Vulnerable to Environmental Chemicals? So the rather arbitrary assumption that children are at ten times the risk that adults are (which may itself be zero or close to it) from chemicals is more a regulatory convention than a scientific conclusion.
Of course, for legal purposes, one often needs to make generalizations, but we live in a media/political environment in which the pronouncements of regulators, often designed to appease activists, easily become the basis of litigatiom, as well as for arguments leading to more and more regulatory action and increasingly shaky science: "EPA clearly established that chemical levels had to be ten times lower for kids, but some readings show we're exceeding the allowable amount, so we need new studies to see if those excessive levels are harming people and new laws to more tightly control industry..."
Unrealistic regulations become self-fulfilling prophecies, leading to stricter and still more unrealistic regulations. One helpful step toward easing the situation would be admitting that the conclusions of the political scientists and the conclusions of the medical scientists are not one and the same. In health matters, the latter should be regarded as more reliable.
