I Wish I Were Far From the Madding Crowd

March 25, 2010

The need for information about toxic substances in articles

For consumers to make informed decisions about whether the products we’re buying are safe, we need information about what is in them.  The following report discusses that issue.

Toxic substances in articles: the need for information
This report explores the benefits that can be gained by improving the provision of information on chemicals in articles.

Executive Summary (excerpt)

This report describes the problem of the lack of information on chemicals in articles. It illustrates specific cases where problems caused by chemicals in articles occur in all life cycle stages: manufacturing, use, recycling and disposal. The report explores the benefits that could result from the development of an internationally standardized information system for the chemical contents of articles; the challenges of disseminating such information; and existing models that could inform such a system. While an information system is not a substitute for other policy mechanisms to mitigate the harms from toxic substances in articles, it can be a powerful compliment [sic].

Note: This report was an input to the further development of the Strategic Approach to International Chemicals Management (SAICM), adopted in February 2006, in particular to the objectives on knowledge and information (Objective 15) of its Overarching Policy Strategy and to some of the activities in the Global Plan of Action. The report was presented at an informal international workshop on stakeholders’ information needs on chemicals in articles in Geneva in February 2009.

The report was commissioned by the Swedish Chemicals Agency (KemI), with funding from the Nordic Chemicals Group under the Nordic Council of Ministers. Responsibility for its contents rests with the authors. The authors are Rachel I. Massey and Janet G. Hutchins at the Massachusetts Toxics Use Reduction Institute, Joel Tickner at the Lowell Center for Sustainable Production and Monica Becker, Monica Becker & Associates.

Contents

Understanding the Problem: Case Studies of Toxic Substances in Articles

  • Case Study 1: Perfluorinated compounds (PFCs) in waterproof  textiles
  • Case study 2: Lead in children’s toys and jewelry
  • Case study 3: Nonylphenol ethoxylates: Water contaminants from textile manufacturing and use
  • Case study 4: Toxic materials in personal computers
    Toxic materials in personal computers include lead, cadmium, mercury, beryllium, antimony, brominated flame retardants, perfluorinated compounds, and polyvinyl chloride plastic.
  • Implications for policies addressing information on substances in articles

Models for information management

Existing legal requirements for information on substances in articles

  • California: Notification of chronic health effects and Toxics Information Clearinghouse
  • Maine and Washington: Notification of toxics in children’s products
  • Mercury products legislation
  • Restriction on Hazardous Substances: EU and China
  • Management of Information on Chemicals in Articles under REACH
  • Globally Harmonized System (GHS) for Classification and Labelling of Chemicals

Voluntary systems

  • Industry-specific systems
  • Corporate Restricted and Preferred Substance Lists
  • Consumer-oriented Databases
  • Voluntary Environmental Performance Labelling (Eco-labels)

The way forward

  • Toward an Internationally Standardized System
  • Scope of the system

Read full report (PDF – 2.28 MB)

March 21, 2010

You say you want an Industrial Revolution (Cradle to Cradle, part 3)

McDonough and Braungart.  Cradle to Cradle: Remaking the Way We Make Things.

Remember the assignment McDonough and Braungart gave?  To design a system that creates enormous amounts of waste, lots of pollution, and burying or burning the results?  (Summarized in Nature doesn’t have a design problem. People do.” (Cradle to Cradle, part 2)

To explain how such a system evolved, they summarize the history of the Industrial Revolution, plus consequences of development of new technologies, increase in urbanization, and the design decisions that accumulated over time. Focus on selling the greatest volume of goods to the greatest number of people.  Shift from manual labor to efficient mechanization.  Mass production (for example, of automobiles).

Industry and natural “capital”

Western society had conflicting views of nature.  On the one hand, nature was a source of natural “capital” that seemed practically bottomless, a “mother earth” that was perpetually regenerative and could absorb all things and continue to grow.  On the other hand, it was also viewed a hostile and dangerous, as something to be conquered and tamed.

The Industrial Revolution was linear—making products and getting them to consumers without thinking about much else.  We now have a much different view of the world, one that recognizes that ecosystems are delicate, complex, and interconnected, and more vulnerable than we ever imagined.

The Industrial Revolution brought about many positive changes such as higher standards of living, increased life expectancy, improved medical care, and more widely available education.  However, fundamental flaws in the infrastructure design have resulted in devastating consequences.

The industrial system was designed on a linear, one-way “cradle-to-grave” model.  In such a system resources are extracted to make products which are sold, then eventually disposed of in a landfill or incinerator.  (Resources that are extracted include coal, oil, natural gas, iron, and so on.)

Buyers are called “consumers,” but McDonough and Braungart point out that consumers actually consume very little.  Most things are designed to be thrown away.

But where is “away”?  Of course, “away” does not really exist.  “Away” has gone away.

And we’re not very efficient at using what we do extract.  According to some studies, more than 90% of materials extracted to make durable goods in the U.S. become waste almost immediately.  (And only about 5% of the raw materials involved in the process of making and delivering a product end up in the product.)

It just occurred to me that McDonough and Braungart’s use of the Titanic as a metaphor for our industrial infrastructure may been appropriate in another way.  Did the Titanic sink itself?  No, it hit an iceberg, 90% of which lies below water.  In other words, the waste and trash we see, the 10%, is just the tip of the wasteberg.

McDonough and Braungart note that “built-in obsolescence” is part of the design of many products.  In fact, reflecting on this, I realized that the selling point of some products is their disposability.  That is to say, our desire for convenience has been an important part in developing the linear cradle-to-grave model.  I believe this also drives our approach to many diseases.

Rather than deal with a problem at the source, we look for a silver bullet, or a magic pill of some kind, to get us out of situations.  In some ways, this brings to mind Aron’s discussion of the role of Highly Sensitive Persons in society.  She notes that immigrant societies like those of the U.S., Canada, and Australia tend to value sensitivity (awareness) less than more mature societies.

So we charge blindly forward, expecting to be able to figure out some creative way to get ourselves out of any situation we find ourselves in.  (This is reinforced by the TV shows we watch, where many problems are solved in 30 to 60 minutes.)

In the short term, it’s easier to deal with things after the fact.  Responding comes naturally to us.  To be fair, we need to be able to respond appropriately to all sorts of different situations.  We can’t prepare for every contingency.

But when we’ve gotten to the point where business as usual is slowly killing the planet we should realize that we need to rethink the way we make things.  For example, in a recently published review of the scientific literature on plastics and health risk [1] (press release), Prof. Rolf Halden points out that the 300 million tons of plastics  produced would fill a series of train cars encircling the globe. He notes: “We’re doomed to live with yesterday’s plastic pollution and we are exacerbating the situation with each day of unchanged behavior.”

There is also a growing consensus that plastics and their additives are not always the benign companions we once assumed them to be.  Bisphenol A and phthalates, used in the production of many plastics, are thought to present risks to human health.

In addition, for many years, scientists assumed that polymers like plastics would not be much of a problem in terms of chemical effects.  However, it was discovered that chemicals associated with the production of such polymers such as Teflon® are accumulating in people’s bodies.   So-called perfluorochemicals were listed in the CDC National Exposure Report for the first time.

Future post – More reasons why the old industrial infrastructure’s approach has gotten us where we are.

*********
Halden, R.  “Plastics and Health Risks,” Annual Review of Public Health, Vol. 31: 179-194 (March 2010) – Abstract | Full Text | PDF (183 KB) – full text costs $)

March 17, 2010

EPA and Children’s Environmental Health

Lax regulations on toxics put kids at risk, experts testify

(from CNN’s “Paging Dr. Gupta” blog)

The above post concerns a hearing held to hear about a report from the Government Accountability Office (GAO) on EPA’s progress in protecting children from environmental threats.  It discusses the challenges EPA faces in protecting children’s health.  (To be fair, many people acknowledge that shortcomings in the Toxic Substances Control Act, or TSCA, are responsible for EPA’s being unable to protect children and others from environmental pollutants.)

I’m not usually one to plug particular networks, but I thought the following mentioned in the Dr. Gupta blog might be of interest.

CNN editor’s note: Dr. Sanjay Gupta looks at the environment and health in an upcoming hourlong investigation, Toxic Towns USA, airing April 24 at 8 p.m. ET

Documents from the hearing

Children are exposed to many sources of potentially-harmful environmental pollutants

from the GAO Report Highlights

Selected report contents:

  • Background
  • EPA Has Not Focused Attention on Children’s Health in Agencywide Priorities, Strategies, and Rulemakings

Includes a figure showing the steps where children are considered in the EPA rulemaking progress.  The report does note that some offices within EPA more consistently incorporate considerations for children’s health in their work than others, but notes that at least one other federal agency does not even seem to do that.

  • In Recent Years, EPA Has Not Fully Utilized Its Office of Children’s Health and Other Child-Focused Resources
  • Opportunities Exist for EPA to Lead and Coordinate National Efforts to Protect Children from Environmental Threats
  • Recommendations for Executive Action
  • Matter for Congressional Consideration
  • Appendix II
    EPA Policy on Evaluating Health Risks to Children
  • Appendix III
    Executive Order 13045 and Amendments
  • Appendix IV
    EPA Regulations Subject to Executive Order 13045

From GAO’s summary: “In 1997, Executive Order 13045 (from the EPA website) mandated that agencies place a high priority on children’s risks and required that policies, programs, activities, and standards address those risks. In response, the Environmental Protection Agency (EPA) created the Office of Children’s Health Protection and convened the Children’s Health Protection Advisory Committee….

“…While EPA leadership is key to national efforts to protect children from environmental threats, EPA’s efforts have been hampered by the expiration in 2005 of certain provisions in the executive order. For example, the Task Force on Children’s Environmental Health provided EPA with a forum for interagency leadership on important federal efforts, such as the National Children’s Study.”

GAO recommended that Congress consider the following:

Because EPA alone cannot address the complexities of the nation’s challenges in addressing environmental health risks for children, Congress may wish to consider re-establishing a government-wide task force on children’s environmental health risks, similar to the one previously established by Executive Order 13045….

Full Committee Hearing entitled, “Hearing on the Government Accountability Office’s Investigation of EPA’s Efforts to Protect Children’s Health”

The hearing mentioned in CNN’s blog – Held by the Senate Committee on Environment and Public Works, Wednesday, March 17, 2010, 10:30 AM EDT

[Webcast]

From the Committee’s Hearing page:

Chairman Barbara Boxer will convene the Full Committee for a hearing on the Government Accountability Office’s (GAO) investigation of the Environmental Protection Agency’s (EPA) children’s health program. The committee will also examine what can be done to strengthen protections for children.

Senator Bill Nelson (D-FL) is also expected to give testimony on the federal government’s role in investigating children’s health issues and how that can be improved.

GAO documents

Environmental Health: High-level Strategy and Leadership Needed to Continue Progress toward Protecting Children from Environmental Threats
GAO-10-205,  January 28, 2010
Summary (HTML)   Highlights Page (PDF)   Full Report (PDF, 83 pages)

Environmental Health: Opportunities for Greater Focus, Direction, and Top-Level Commitment to Children’s Health at EPA

GAO-10-545T,  March 17, 2010
Summary (HTML)   Full Report (PDF, 12 pages)

EPA’s response

Peter Grevatt, the director of EPA’s Office of Children’s Health Protection, stated in his written testimony:

EPA agrees that the GAO report reflects well the early history and progress of the Agency’s children’s health protection efforts. The report accurately portrays the Agency’s challenges in addressing children’s  environmental health, and sets forth sound recommendations on steps that could be taken to better incorporate protection of children’s health as an integral part of EPA’s everyday business.

Grevatt also noted that EPA Administrator Lisa Jackson had designated the protection of children’s health as one of her top priorities.  He then described how EPA would implement its strategy to protect children’s health.

EPA’s strategy on children’s health (starts on p.4 of the testimony—specific components are listed under each item in the testimony)

  1. EPA will use the best science to ensure that regulations provide for protection of children’s environmental health by actively addressing the potential for unique childhood vulnerability and exposure. Our goal is to reduce negative environmental health impacts on children through rulemaking, policy, enforcement and research that focus on prenatal and childhood vulnerabilities.
  2. Protecting children through safe chemicals management.
  3. Coordinate national and international community based programs to eliminate threats to children’s health while measuring and communicating our progress.

Children’s health protection at EPA

Office of Children’s Health Protection website

Basic information about the Office of Children’s Health Protection

America’s Children and the Environment

(more…)

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