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By Aaron Wildavsky - But Is It True?: 1st (first) Edition
This is a book about citizenship in a scientific and technological age. Its subject is the relationship between knowledge and action in major environmental and safety issues. That relationship involves charges that modern technology can harm human beings, other living creatures, and the natural environment. The evidence cited is based on scientific understandings, which have been modified through political processes and have led to governmental actions.
- GenresNonfiction
Unknown Binding
First published April 21, 1995
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May 1, 2011
Put down that apple! Don’t you know the pesticide residue on it causes cancer? Don’t add that sugar substitute to your coffee, it causes cancer. But mom, I don’t wanna change schools, all of my friends are there. I don’t care; you’re switching to one that doesn’t have asbestos in its buildings. I don’t want you catching lung cancer.
Wildavsky lambasts the current regulatory state and its two most pernicious arms, the EPA and FDA, for generating such conversations and worries. His methodology is to investigate various scares or panics instigated by these organizations over the last half century, examine the regulations or bans passed in response, and then critically evaluate the effectiveness of the responses. Wildavsky discusses the cranberry scare of 1959, dieldrin, saccharin, PCBs, DDT, dioxin, Agent Orange, the Times Beach relocation, asbestos, Alar, arsenic in drinking water, global warming, and other supposed toxins and environmental hazards.
The EPA and FDA adhere to a concept called the precautionary principle in assessing risk. The principle holds “that to avoid irreparable harm to the environment and to human health, precautionary action should be taken: Where it is acknowledged that a practice (or substance) could cause harm, even without conclusive scientific proof that it has caused harm or does cause harm, the practice (or emissions of the substance) should be prevented and eliminated.” In other words, the set of assumptions under which these agencies operate are exceedingly conservative and balance any doubt in favor of banning the suspect substance. For example, part of a law known as the Delaney Clause was added as an amendment to the Food, Drug, and Cosmetic Act in 1958; said clause states: “No additive shall be deemed safe if it is found to induce cancer when ingested by man or animal.” Significantly, there is no de minimis exception to the Delaney Clause, which means no matter how small the risk may be, the FDA is required to classify the additive as unsafe. See Pub. Citizen v. Young, 831 F.2d 1108 (D.C. Cir. 1987) (holding there is no de minimis exception applicable to Delaney Clause without specific congressional intent to allow it, even when the color additive in question had a 1 in 19 billion chance of causing cancer).
The arguments commonly put forth supporting the precautionary principle as applied to food additive risks include:
1. It’s not fair – children are at more risk than adults because they eat more food in proportion to their body sizes than adults. Growers reap the benefits from using Alar while everyone shares the risks.
2. It’s involuntary – people know the risks of driving a car and sitting in the sun, but they don’t choose the risks of some substances that are put in their food.
3. Consumers can’t control their risk – there is control over driving, there isn’t control over whether Alar is in the food.
4. Someone is responsible – naturally occurring pesticides exist in nature, which is different from people adding synthetic ones through action.
5. It’s unnecessary – if consumers don’t want Alar in their apples, it shouldn’t be there.
Wildavsky, through his series of case studies, reveals the problems with the precautionary principle. The problems are many and vary with the substance considered, but two main themes emerge. First, the assessment of the actual risk of the substances is often wildly inaccurate. The FDA uses, as part of its conservative disposition, a linear, non-threshold approach to toxins. This means that toxins are always considered harmful to human health, even in trace amounts, and the amount of the substance has a linear relationship to harm. For example, arsenic is uniformly fatal to humans if a high enough quantity is ingested in a short period of time. The assumption of the FDA, then, is that smaller amounts of arsenic are proportionally as dangerous. The problem with that assumption is that there is no evidence to support it and plenty of evidence showing that small quantities of arsenic can be eliminated from the human body with no deleterious effects. Accidental epidemiological studies (studies done on humans that generally are not intentional because of moral prohibitions but sometimes arise out of happenstance) show that arsenic can cause soft tissue cancer if subjects are exposed to 600 micrograms/liter or more in their drinking water for several months or longer. Other studies show no harmful effects at levels of 300 micrograms/liter in drinking water. So we should set the limit at 300 micrograms/liter, right? Wrong. The EPA has set the current acceptable level of arsenic in drinking water at 10 micrograms/liter. Why? Because of the arbitrary assumption that lower is better despite a dearth of evidence indicating any difference to human health between 0, 10, and 300 micrograms of arsenic per liter of water.
Most studies of carcinogens are conducted on lab rats. Rats are injected with or forced to consume huge quantities of the tested substance for their entire lives, which is approximately two years, after which time scientists exam the rats to see if there are increased cancer rates. There are several problems with animal studies involving difficulty in extrapolating risk from animals to humans because of physiological and biochemical differences between the species. For example, saccharin has been shown in lab tests to cause bladder tumors in rats—but only male rats and only because male rats naturally produce in their bodies a chemical that humans do not, and that chemical is thought to react with the saccharin to cause the bladder tumors. Therefore, because humans don’t produce this chemical that reacts with saccharin to cause cancer in male rats, the same risk is not applicable to humans. Nonetheless, the FDA behaved as if the risk were identical, attempting to ban saccharin. After huge public outcry Congress finally declared that saccharin was not harmful to humans.
The single biggest problem with animal tests is the quantity of the substance ingested or injected into the test subjects. The lab rats consume such large quantities that no human could possibly ingest equivalent proportions. The cranberry scare of 1959 began because of residues of a weed killer, aminotriazole, found on some cranberries. Tests by the FDA and American Cyanamid, the producer of aminotriazole, on lab rats indicated that the substance could potentially cause cancer in extremely high doses. Wildavsky scales the tests up to human-size thusly: “To put the rat dose in perspective, if a 150-pound man ate a pound of cranberries every day of his life, all contaminated at the maximum residue level of 1 ppm requested by American Cyanamid, he would ingest a dose (scaled by relative body weights) about 1,500 times lower than the 10 ppm dose in rats that caused a growth in one of the ten rats, which may or may not have been cancerous and may or may not have been caused by the 3-AT.” Another example involves nitrites used to cure meat. The quantities of nitrites given to lab animals would be the equivalent of a human eating 586 pounds of cured meat daily.
The fundamental observation of toxicology is that the poisonous effects of chemicals depend on the dose. The doses given to lab animals frequently bear no relation to the amount of exposure any human is likely to face. At high enough doses, virtually any substance becomes harmful or fatal, and all of the following have been shown to cause cancer in lab animals: vitamin A, salt, apples, bananas, broccoli, brussels sprouts, cabbage, mushrooms, and oranges. Wildavsky uses the analogy of a milk room to illustrate the risk of small doses. If you place someone in a sealed room and completely fill it with milk, he will drown. If you lower the level halfway, he may or may not drown. If you lower the level still further, to where the floor is covered with 1 inch of milk, it becomes difficult to drown. If you lower the milk level to 1/100th, 1/1,000th, or 1/1,000,000th of an inch, it becomes virtually impossible for this person to drown. These are the levels of exposure people faced as some chemicals were regulated or banned.
Inaccurate risk assessment is the first major theme running against the precautionary principle. The second major theme Wildavsky explores is the utter lack of cost/benefit analysis with regard to the bans. Even conceding that these substances can be harmful in large doses, humanity is not served by focusing only on the potential risks of the substances. The substances exist because they served some useful function. For instance, saccharin is vital to the health of many diabetics who would suffer adverse health effects without it; PCBs had wide application as a fire-resistant substance in transformers, pesticides, paint, and industrial machinery; DDT nearly eradicated malaria in the U.S., Europe, Chile, parts of the Soviet Union, and other areas of the world by 1959; Agent Orange was used in Vietnam in an attempt to save the lives of American soldiers who were ambushed by Viet Cong using the jungle as cover; asbestos was used widely because of its fire-resistant and insulating properties; nitrites help preserve meat and prevent food-related illnesses like botulism; and Alar kept apples on the vine longer which lowered the costs of collecting apples and getting them to consumers.
Ignoring the benefits of widely used substances can cause significant problems for a host of reasons. For one thing, there may not be a readily available alternative. In the case of nitrites, does the small risk of cancer posed by eating unfathomable quantities of meat outweigh the much higher risk of botulism or other food-borne illness? Certainly not. Today, malaria claims the lives of approximately 750,000 people every year, many of which are in Sub-Saharan Africa. DDT has not been shown to cause adverse human effects, even at high levels, but it may cause reproductive problems for some birds of prey. A flat ban on DDT has risked millions of human lives in the decades since Rachel Carson’s Silent Spring, which, from what I can tell, was largely about robins dying because of DDT. (Full disclosure, I haven’t read the book and she may very well speculate about the negative human health effects of DDT.) The point is that the pros and cons of DDT should be openly and honestly discussed and weighed before a flat ban is imposed. Carson may be willing to trade the lives of legions of Africans for some birds, but that hardly strikes me as morally praiseworthy.
Another important consideration with regard to the pros and cons of bans is that the remedial measures in dealing with substances may be more risky than doing nothing. Wildavsky gives as the most prominent example asbestos removal. Asbestos can cause mesothelioma when the small fibers enter the lungs. Asbestos is a naturally occurring mineral to which everyone in the world is exposed just by breathing. The people who came down with mesothelioma often faced higher concentrations of asbestos because of occupational hazards when they installed it or worked with or near it on a regular basis for decades. Moreover, the risks of asbestosis and mesothelioma greatly increase if one also smokes cigarettes. After fear of asbestos spread, Congress passed the Asbestos Hazard Emergency Response Act in 1986. This act paid schools billions of dollars to remove asbestos. The problem is that the removal itself disturbed the asbestos and kicked up the fibers into the air, thus making the air more dangerous than if the remedial work had not been done at all. Moreover, the amount of fibers in even the worst schools was equivalent to the ambient levels of asbestos in cities like Los Angelos and Philadelphia. So, in short, billions of dollars were spent in an effort that, at best, made the air inside school buildings similar to air outside school buildings and, at worst, made the air inside school buildings less safe than if no action had been taken at all.
The final consideration of ignoring costs and benefits are the economic implications of bans or remedial work. Perhaps a common reaction is that economics shouldn’t factor into discussions about safety, but this reaction is naïve and uninformed because economics is inextricably linked to health and safety. As wealth increases, so does longevity and health. This is as true for nations as it is individuals. Wealthier people and nations can afford more things that make them safer including food, medicine, housing, machinery that performs dangerous tasks, etc. Wildavsky points out that Ralph Keeney has estimated that a decline in living standards of each $7.5 million is responsible for one early death. Assuming this figure is roughly accurate, the billions and billions of dollars lost when cranberry crops were destroyed, apples were wasted, PCBs were flushed out of transformers, and asbestos was needlessly removed from buildings represent thousands of lost lives or early deaths.
Wildavsky’s work is quite technical and detailed. His aim is to inform citizens about the importance of understanding the scientific studies that inform policy decisions and also the incentives regulators face. In short, regulators have every incentive to be overly conservative because they take much less flak if they are too cautious than if they are too lenient. The problem, as Wildavsky amply demonstrates, is that this overly cautious disposition leads to incorrect risk analysis and inefficient decision making that ultimately causes more harm than good. Of all the substances considered, Wildavsky concludes that only the ban on CFCs was probably worthwhile.
With this review completed, I’m off to eat an apple, perhaps laced with pesticides, and gulp tap water, perhaps riddled with arsenic. Neither worries me a bit.
Wildavsky lambasts the current regulatory state and its two most pernicious arms, the EPA and FDA, for generating such conversations and worries. His methodology is to investigate various scares or panics instigated by these organizations over the last half century, examine the regulations or bans passed in response, and then critically evaluate the effectiveness of the responses. Wildavsky discusses the cranberry scare of 1959, dieldrin, saccharin, PCBs, DDT, dioxin, Agent Orange, the Times Beach relocation, asbestos, Alar, arsenic in drinking water, global warming, and other supposed toxins and environmental hazards.
The EPA and FDA adhere to a concept called the precautionary principle in assessing risk. The principle holds “that to avoid irreparable harm to the environment and to human health, precautionary action should be taken: Where it is acknowledged that a practice (or substance) could cause harm, even without conclusive scientific proof that it has caused harm or does cause harm, the practice (or emissions of the substance) should be prevented and eliminated.” In other words, the set of assumptions under which these agencies operate are exceedingly conservative and balance any doubt in favor of banning the suspect substance. For example, part of a law known as the Delaney Clause was added as an amendment to the Food, Drug, and Cosmetic Act in 1958; said clause states: “No additive shall be deemed safe if it is found to induce cancer when ingested by man or animal.” Significantly, there is no de minimis exception to the Delaney Clause, which means no matter how small the risk may be, the FDA is required to classify the additive as unsafe. See Pub. Citizen v. Young, 831 F.2d 1108 (D.C. Cir. 1987) (holding there is no de minimis exception applicable to Delaney Clause without specific congressional intent to allow it, even when the color additive in question had a 1 in 19 billion chance of causing cancer).
The arguments commonly put forth supporting the precautionary principle as applied to food additive risks include:
1. It’s not fair – children are at more risk than adults because they eat more food in proportion to their body sizes than adults. Growers reap the benefits from using Alar while everyone shares the risks.
2. It’s involuntary – people know the risks of driving a car and sitting in the sun, but they don’t choose the risks of some substances that are put in their food.
3. Consumers can’t control their risk – there is control over driving, there isn’t control over whether Alar is in the food.
4. Someone is responsible – naturally occurring pesticides exist in nature, which is different from people adding synthetic ones through action.
5. It’s unnecessary – if consumers don’t want Alar in their apples, it shouldn’t be there.
Wildavsky, through his series of case studies, reveals the problems with the precautionary principle. The problems are many and vary with the substance considered, but two main themes emerge. First, the assessment of the actual risk of the substances is often wildly inaccurate. The FDA uses, as part of its conservative disposition, a linear, non-threshold approach to toxins. This means that toxins are always considered harmful to human health, even in trace amounts, and the amount of the substance has a linear relationship to harm. For example, arsenic is uniformly fatal to humans if a high enough quantity is ingested in a short period of time. The assumption of the FDA, then, is that smaller amounts of arsenic are proportionally as dangerous. The problem with that assumption is that there is no evidence to support it and plenty of evidence showing that small quantities of arsenic can be eliminated from the human body with no deleterious effects. Accidental epidemiological studies (studies done on humans that generally are not intentional because of moral prohibitions but sometimes arise out of happenstance) show that arsenic can cause soft tissue cancer if subjects are exposed to 600 micrograms/liter or more in their drinking water for several months or longer. Other studies show no harmful effects at levels of 300 micrograms/liter in drinking water. So we should set the limit at 300 micrograms/liter, right? Wrong. The EPA has set the current acceptable level of arsenic in drinking water at 10 micrograms/liter. Why? Because of the arbitrary assumption that lower is better despite a dearth of evidence indicating any difference to human health between 0, 10, and 300 micrograms of arsenic per liter of water.
Most studies of carcinogens are conducted on lab rats. Rats are injected with or forced to consume huge quantities of the tested substance for their entire lives, which is approximately two years, after which time scientists exam the rats to see if there are increased cancer rates. There are several problems with animal studies involving difficulty in extrapolating risk from animals to humans because of physiological and biochemical differences between the species. For example, saccharin has been shown in lab tests to cause bladder tumors in rats—but only male rats and only because male rats naturally produce in their bodies a chemical that humans do not, and that chemical is thought to react with the saccharin to cause the bladder tumors. Therefore, because humans don’t produce this chemical that reacts with saccharin to cause cancer in male rats, the same risk is not applicable to humans. Nonetheless, the FDA behaved as if the risk were identical, attempting to ban saccharin. After huge public outcry Congress finally declared that saccharin was not harmful to humans.
The single biggest problem with animal tests is the quantity of the substance ingested or injected into the test subjects. The lab rats consume such large quantities that no human could possibly ingest equivalent proportions. The cranberry scare of 1959 began because of residues of a weed killer, aminotriazole, found on some cranberries. Tests by the FDA and American Cyanamid, the producer of aminotriazole, on lab rats indicated that the substance could potentially cause cancer in extremely high doses. Wildavsky scales the tests up to human-size thusly: “To put the rat dose in perspective, if a 150-pound man ate a pound of cranberries every day of his life, all contaminated at the maximum residue level of 1 ppm requested by American Cyanamid, he would ingest a dose (scaled by relative body weights) about 1,500 times lower than the 10 ppm dose in rats that caused a growth in one of the ten rats, which may or may not have been cancerous and may or may not have been caused by the 3-AT.” Another example involves nitrites used to cure meat. The quantities of nitrites given to lab animals would be the equivalent of a human eating 586 pounds of cured meat daily.
The fundamental observation of toxicology is that the poisonous effects of chemicals depend on the dose. The doses given to lab animals frequently bear no relation to the amount of exposure any human is likely to face. At high enough doses, virtually any substance becomes harmful or fatal, and all of the following have been shown to cause cancer in lab animals: vitamin A, salt, apples, bananas, broccoli, brussels sprouts, cabbage, mushrooms, and oranges. Wildavsky uses the analogy of a milk room to illustrate the risk of small doses. If you place someone in a sealed room and completely fill it with milk, he will drown. If you lower the level halfway, he may or may not drown. If you lower the level still further, to where the floor is covered with 1 inch of milk, it becomes difficult to drown. If you lower the milk level to 1/100th, 1/1,000th, or 1/1,000,000th of an inch, it becomes virtually impossible for this person to drown. These are the levels of exposure people faced as some chemicals were regulated or banned.
Inaccurate risk assessment is the first major theme running against the precautionary principle. The second major theme Wildavsky explores is the utter lack of cost/benefit analysis with regard to the bans. Even conceding that these substances can be harmful in large doses, humanity is not served by focusing only on the potential risks of the substances. The substances exist because they served some useful function. For instance, saccharin is vital to the health of many diabetics who would suffer adverse health effects without it; PCBs had wide application as a fire-resistant substance in transformers, pesticides, paint, and industrial machinery; DDT nearly eradicated malaria in the U.S., Europe, Chile, parts of the Soviet Union, and other areas of the world by 1959; Agent Orange was used in Vietnam in an attempt to save the lives of American soldiers who were ambushed by Viet Cong using the jungle as cover; asbestos was used widely because of its fire-resistant and insulating properties; nitrites help preserve meat and prevent food-related illnesses like botulism; and Alar kept apples on the vine longer which lowered the costs of collecting apples and getting them to consumers.
Ignoring the benefits of widely used substances can cause significant problems for a host of reasons. For one thing, there may not be a readily available alternative. In the case of nitrites, does the small risk of cancer posed by eating unfathomable quantities of meat outweigh the much higher risk of botulism or other food-borne illness? Certainly not. Today, malaria claims the lives of approximately 750,000 people every year, many of which are in Sub-Saharan Africa. DDT has not been shown to cause adverse human effects, even at high levels, but it may cause reproductive problems for some birds of prey. A flat ban on DDT has risked millions of human lives in the decades since Rachel Carson’s Silent Spring, which, from what I can tell, was largely about robins dying because of DDT. (Full disclosure, I haven’t read the book and she may very well speculate about the negative human health effects of DDT.) The point is that the pros and cons of DDT should be openly and honestly discussed and weighed before a flat ban is imposed. Carson may be willing to trade the lives of legions of Africans for some birds, but that hardly strikes me as morally praiseworthy.
Another important consideration with regard to the pros and cons of bans is that the remedial measures in dealing with substances may be more risky than doing nothing. Wildavsky gives as the most prominent example asbestos removal. Asbestos can cause mesothelioma when the small fibers enter the lungs. Asbestos is a naturally occurring mineral to which everyone in the world is exposed just by breathing. The people who came down with mesothelioma often faced higher concentrations of asbestos because of occupational hazards when they installed it or worked with or near it on a regular basis for decades. Moreover, the risks of asbestosis and mesothelioma greatly increase if one also smokes cigarettes. After fear of asbestos spread, Congress passed the Asbestos Hazard Emergency Response Act in 1986. This act paid schools billions of dollars to remove asbestos. The problem is that the removal itself disturbed the asbestos and kicked up the fibers into the air, thus making the air more dangerous than if the remedial work had not been done at all. Moreover, the amount of fibers in even the worst schools was equivalent to the ambient levels of asbestos in cities like Los Angelos and Philadelphia. So, in short, billions of dollars were spent in an effort that, at best, made the air inside school buildings similar to air outside school buildings and, at worst, made the air inside school buildings less safe than if no action had been taken at all.
The final consideration of ignoring costs and benefits are the economic implications of bans or remedial work. Perhaps a common reaction is that economics shouldn’t factor into discussions about safety, but this reaction is naïve and uninformed because economics is inextricably linked to health and safety. As wealth increases, so does longevity and health. This is as true for nations as it is individuals. Wealthier people and nations can afford more things that make them safer including food, medicine, housing, machinery that performs dangerous tasks, etc. Wildavsky points out that Ralph Keeney has estimated that a decline in living standards of each $7.5 million is responsible for one early death. Assuming this figure is roughly accurate, the billions and billions of dollars lost when cranberry crops were destroyed, apples were wasted, PCBs were flushed out of transformers, and asbestos was needlessly removed from buildings represent thousands of lost lives or early deaths.
Wildavsky’s work is quite technical and detailed. His aim is to inform citizens about the importance of understanding the scientific studies that inform policy decisions and also the incentives regulators face. In short, regulators have every incentive to be overly conservative because they take much less flak if they are too cautious than if they are too lenient. The problem, as Wildavsky amply demonstrates, is that this overly cautious disposition leads to incorrect risk analysis and inefficient decision making that ultimately causes more harm than good. Of all the substances considered, Wildavsky concludes that only the ban on CFCs was probably worthwhile.
With this review completed, I’m off to eat an apple, perhaps laced with pesticides, and gulp tap water, perhaps riddled with arsenic. Neither worries me a bit.
March 3, 2014
This book reviews past environmental issues of the day. He looks at the science known at the time of the law (or regulation) being made to see if the law matched what was currently known. He further examines science since that time to see if the law matches what is currently known. The list of topics include asbestos, dioxin, ozone, agent orange, the love canal, DDT, and many more.
Most of this book was great. It is good to see someone take the other side on environmental issues. And on most issues reviewed the author did an excellent job with the science. It is maddening how many laws have been made based on bad science. It also drives me crazy that when later science alters the original conclusion, there is no mechanism to review the law to see if it is still justified.
The author does a good job of establishing the point that unnecessary regulation lowers the standard of living for everyone and that by lowering the standard of living these laws might actually be causing more health problems than they stop.
Those shown in the worst light in this book are those that advance a media agenda without an understanding of the science. They can and do make things worse while somehow still claiming the moral high ground.
I disagreed with most of the "solution" the author proposed. To have each citizen actually read the original science articles and understand them before making policy decisions is unrealistic. I don't have a better solutions however. Ideally media would actually present the science about the issue, rather than be advocate journalists, working to prove a particular point.
Most of this book was great. It is good to see someone take the other side on environmental issues. And on most issues reviewed the author did an excellent job with the science. It is maddening how many laws have been made based on bad science. It also drives me crazy that when later science alters the original conclusion, there is no mechanism to review the law to see if it is still justified.
The author does a good job of establishing the point that unnecessary regulation lowers the standard of living for everyone and that by lowering the standard of living these laws might actually be causing more health problems than they stop.
Those shown in the worst light in this book are those that advance a media agenda without an understanding of the science. They can and do make things worse while somehow still claiming the moral high ground.
I disagreed with most of the "solution" the author proposed. To have each citizen actually read the original science articles and understand them before making policy decisions is unrealistic. I don't have a better solutions however. Ideally media would actually present the science about the issue, rather than be advocate journalists, working to prove a particular point.
September 12, 2007
Had some interesting ideas, but slow.
Displaying 1 - 3 of 3 reviews