Which Environmental Risks Are Worth Addressing?

By Michael Gough
November 22, 1996

Thank you for inviting me. I’m delighted to be here, and honored that you asked me to talk.

I am going to talk about two ideas that determine which environmental risks are addressed. I don’t say “addressed first” because, in practice, all environmental risks are treated as equally urgent. The two ideas are the precautionary principle and statements that chemicals in the environment are a big risk to human health.

The precautionary principle says that you shouldn’t do anything unless you can be certain that nothing bad will result. It is played as an intellectual trump card and used to divide good from evil. Its proponents are pictured as good—working to save lives and health. Its opponents, working to make changes—more food production, greater efficiency, more comfort—are pictured as risk takers or risk imposers and therefore evil. Understandably, there’s a reluctance to oppose the precautionary principle.

Fundamentally, the precautionary principle engenders fear. Fear of the future, fear of new things, fear of change come immediately to mind, but carried to a logical end by a 9-year-old girl, it culminates in fear of her mother’s hands. The mother asked the little girl why she never ate all of her sandwiches and left some oddly shaped pieces on her plate. The little girl replied that she didn’t eat the parts that her mother had touched because of the germs on her mother’s hands. The mother said that the germs didn’t make her sick and that they wouldn’t make her daughter sick either. After all, the mother said, you’ve eaten lots of food that I’ve touched, and it’s not made you sick.

The little girl responded with something like, “You can’t prove it won’t.”

That’s the precautionary principle. It’s a big burden for the 9-year-old, her mother, and us.

Cancer has been the mother of environmental health risks. I expect that most of you have heard, “The environment causes 90 percent of all cancers,” or if the speaker was less of an alarmist, 80 or 70 or some other percent.

There is no evidence for such statements. The statements stem from willful and intentional twisting of what scientists were saying about the causes of cancer in the 1950s and 60s. In fact, scientists did say that environment causes some major proportion of cancer, but they used “environment,” to include everything with which we come into contact—what we smoke, eat, drink, take as medicine, radiation from the sun and X-rays, etc.

Dr. John Higginson, the first director of the International Agency for Research on Cancer, first said something like “environment causes more than 75 percent of cancer.” When he realized his words were being twisted, he told Science magazine that

most people…have used the word ‘environment’ purely to mean chemicals…. The ecological movement, I suspect, found the extreme view convenient…. People would love to be able to prove that cancer is due to the general environment or pollution. It would be so easy to say ‘let us regulate everything to zero exposure and we have no more cancer.’ The concept is so beautiful that it will overwhelm a mass of facts to the contrary.

Seventeen years later, all I can say is that Higginson was right.

 I’m going to be talking about the percentage of cancer that may be caused by environmental exposures, and you may want to translate those percentages into numbers. About 500,000, half a million, Americans die annually from cancer, so one percent of cancer deaths is about 5,000 deaths. (Cancer accounts for about one-quarter of the 2,000,000 deaths each year.)

What do we know about the environment and cancer? In 1981, Sir Richard Doll and Richard Peto estimated that pollution caused about two percent of all cancers. In 1987, EPA’s report Unfinished Business presented the agency’s estimates of how many cancers were associated with various chemicals and radiation in the environment. For whatever reasons, EPA didn’t add up their numbers. I did, and the total was between one and three percent of all cancers. Day before yesterday, the New York Times reported a new study from the Harvard School of Public Health; it too found that the environment is associated with no more than two percent of cancers. (In 1990, I calculated what percentage of cancers the agency’s regulatory program might affect. If EPA’s risk estimates are accurate (they’re intentionally skewed to the high side) and if EPA could eliminate (it can’t) all those risks, cancer rates would fall by between 0.6 and 1.2 percent. And, of course, they might not fall at all.)

 I can hear people who believe that every effort should be expended on environmental cancer saying, “So what? It’s just a bunch of calculations. We can come up with our own calculations.”

So let’s turn from analysis to actions and results. In the mid 1980s, the National Cancer Institute set out goals for the year 2000. It included such things as reducing smoking, increasing the eating of fruits and vegetables, increasing the use of early detection methods, and making improvements in detection methods and treatments. There was no mention of environmental exposures. The conclusion has to be that their contribution was too trivial to be included.

There was dramatic, positive news about cancer mortality last week. Philip Cole and Brad Rodu of the University of Alabama published a report that concluded cancer mortality rates have fallen three percent since 1990. Even better, the drop in mortality rates appears to be accelerating, and the NCI, which is doing its own analysis of cancer mortality, has already confirmed Cole and Rodu’s results. Richard Klausner, the director of NCI, said, “This is the news we’ve been waiting for.”

So what are we doing right? About what you’d think. There’s less smoking, less drinking, less exposure to the sun, and we’ve reduced occupational exposures to carcinogens. Early detection and better treatment have also played a role. But nowhere do Cole and Rodu mention environmental carcinogens. Environmental exposures don’t figure in the improvement in cancer mortality despite EPA’s writing thousands of pages of regulations and requiring the expenditure of billions of dollars in compliance.

EPA regulations cost about $7.6 million for each hypothetical life-year saved. It’s a high price: The Federal Aviation Administration saves a life-year for every $23,000 it spends; 300-times less than EPA requires. I remind you that the FAA estimates are based on accidents that kill and maim real people. EPA’s are based on studies of laboratory rats.

Two years ago, the 104th Congress roared into Washington, and among many other things, it promised “regulatory reform” based on “sound science.” Not much happened.

To argue that EPA would benefit from “sound science” is to accept that its goals are rooted in reality. That’s the wrong approach. I think that Congress has to open up the question to “What do we expect EPA to do?”

In particular, “Do we expect EPA to make a difference in human cancer rates?” If the answer is “No” or “We don’t know,” I think a strong argument can be made to discontinue EPA’s relentless risk assessment and risk management directed at any chemical that it can think of.

Congress can ask such questions. It may not answer them for years, but getting the questions out into the open will bestow legitimacy on them.

I did not say that the goal should be to stop EPA regulations. Its regulations are expensive and often unnecessary, but they go through a process of hearings and reviews and citizens have opportunities to object. EPA risk assessments, by themselves, can lead to unnecessary and expensive actions. They instill fear and can cost great amounts of money and there are few opportunities to oppose them.

Next month, Cato will publish a book named Haunted Housing, written by Cassandra Moore. The book details the poor science behind four environmental risks that affect prices of homes—indoor radon, EMF (electromagnetic fields), asbestos, and lead paint.

In some parts of the county, radon inspections have become as common as termite inspections, and the brother of the guy who does the inspection for radon is in the business of “remediating” homes to reduce radon levels.

Utility companies have been sued left and right because of EMF, and millions of dollars have been spent on burying transmission lines with the costs of litigation and burying passed onto rate-payers.

Is that asbestos around those old heating ducts? Better remove it before you try to sell your house. Here’s the card of a company that does that kind of work.

If you’ve got lead paint in the apartment building or the house you’re going to sell, be sure to tell the potential buyer and give him the EPA brochure that warns about the dangers of lead paint. Otherwise there’s a big fine every time you forget.

Lead is regulated. Radon, EMF, and asbestos are not. EPA’s publicizing its estimated risks from radon has caused real estate agents to require inspections and escrow accounts and remediation because they are afraid of liability down the road. EPA abandoned an EMF regulatory program because the data were too weak. In contrast to its drum beating about the risks of radon, EPA has been very quiet about the non-risk status of EMF. In fact, the precautionary principle has been translated into “prudent avoidance,” which is intended as guidance for citizens in dealing with EMF. EPA’s widely publicized and congressionally mandated program directed at asbestos in schools in the 1980s convinced many people that asbestos in building is a threat to health. In 1990, EPA said it wasn’t, but how many people have heard the message?

The point is that EPA feeds fears, people respond to the fears, and costs and problems mount up. There’s no expectation that any of the money spent will make much difference, if any, to health. Regulatory reform won’t touch problems like indoor radon, EMF, and asbestos. They were never regulated.

There is no incentive for EPA to rely on sound science. It thrives on finding and publicizing and regulating risks. Improvement lies in getting EPA and the federal government out of risk assessment and letting the market work.

Two years ago, Cato published The Cato Handbook for Congress, which included many suggestions for reducing the federal presence. The second edition, to be published in January, includes a recommendation that Congress repeal the laws that require EPA pre-market notification or review of new chemicals and pesticides. Instead, companies would have to certify that their products are safe and they would, of course, face legal actions if their products injured people or the environment.

In a similar vein, we are now working on a Cato “Policy Analysis” that argues that FDA should not have authority to require pre-market approval of medical devices. Manufacturers would be required to certify that their products—whether tongue depressors or heart-lung machines—are safe, and they would face legal actions if something went wrong.

For both chemicals and medical devices, we argue that the market can assure safety and that the federal government has no necessary role. That may sound radical, but everyday, everyone of us handles complicated, lethal devices that the government has not approved. Electricity can kill, and many of us don’t understand it very well, and we don’t worry about it. We don’t worry about it because Underwriters Laboratories, Inc. certifies electrical devices as safe.

By the way, the next time you’re hooked up to a heart-lung machine and you have a minute, look around. Somewhere on that machine there’ll be a UL mark that certifies the safety and functioning of the electrical system in the machine.

If the government gets out of pre-market approval of chemicals and medical devices, we can be certain that UL-like organizations will appear to test and certify new products. Moreover, just as UL is now facing competition from other third-party organizations that want to sell their testing and certification services, I expect competition in the market for certification of chemicals and medical devices.

Here, at last, I come to the topic of my talk, which is going after the most serious risks first. The first step is to ask questions about which risks deserve our attention at all. After that, I think that we need to devise ways that don’t involve the federal government to deal with risks. Remember EPA’s $7.6 millions for each life-year saved, based on rat tests, and remember also that EPA may have saved zero lives. I don’t think that we want to confine our thinking and talking to helping EPA do a better job. The question should be “Do we want EPA doing the jobs it’s doing?” And, the organization that has to be convinced to ask that question is Congress.

Director of Risk and Science Studies at the Cato Institute.

A talk delivered to Resource Development Council for Alaska, Inc.