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ENVIROETHICS Home

ENVIROETHICS  2000

ENVIROETHICS 2000

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Subject:

Re: [Re: The Precautionary Principle--A Race to the Bottom?]

From:

Jim Tantillo <[log in to unmask]>

Reply-To:

[log in to unmask]

Date:

Fri, 12 May 2000 17:18:16 -0500

Content-Type:

multipart/alternative

Parts/Attachments:

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text/plain (264 lines) , text/enriched (615 lines)

>Your post about paranoia and precautionary principle was brilliant Jim.
>Knowing your general skeptical nature, I firmly believe that your skepticism
>is indeed pure, and that you have no "alterior motive" to oppose such paranoia
>about phthalates.  Nevertheless, I guess we must see what information John
>does have.

Hi Jamey,
John has graciously already gotten a copy of his paper to me, and it is a
very thorough review.  At least now I know why the chemistry is such that
baby teethers represent at least a potential threat: "Because phthalates
are used as softening agents they do not chemically bind to vinyls and may
leach out of toys and teething products while being used" (from John F).
The question yet remains whether the *dose* that teething babies would
receive is high enough to justify the scare.  Sounds like the risk
assessment jury is still out on that one . . . and there's probably more
risk from the phthalates leaching out of the food packaging in baby food
and infant formula than from toys, per se.

But it seems to me that the self-imposed ban --whether out of a healthy
fear of future lawsuits or out of a civic-minded sense of altruism--that
Mattel and some other manufacturers of baby pacifiers and teethers have
instituted for these kinds of products *is* in fact a sound precaution.  On
the other hand, panicking about *all* baby toys still seems to me to be a
bit of overkill.  Some of the links below refer to Greenpeace's virtually
monomaniacal crusade to ban *all* vinyl--and that seems like risk-aversion
overkill to me as well, given the state of the science as it remains today.

A couple of very helpful web sites that I've located include:
A 1999 article in CHEMISTRY AND INDUSTRY on divided expert opinion about
phthalates at http://ci.mond.org/current/991305.htm ; and  a National
Safety Council "chemical backgrounder" on DEHP, one of the most common
phthalates in children's products.
http://www.crossroads.nsc.org/ChemicalTemplate.cfm?id=103&chempath=chemicals

In addition, here is a web site that maintains a set of links that
represent a kind of chronicle of the the entire phthalate controversy, from
1998 to present:
http://www.800lawinfo.com/phtaates85.cfm .  The site is also very helpful
in case anyone here is thinking of filing a lawsuit for damages stemming
from your use of the pacifier or teether you sucked on as a kid--these guys
specialize in toxic torts, and all you've got to do is call 1-800-LAW-INFO
today!  <smile>  But actually, the list of press clippings they link to is
very helpful.

Jim T.



I also agreed with Steve about the hysteria about GMO.  The fact
>that some GMO are specifically designed to be compatible with pesticides makes
>at least those GMO less environmentally friendly.  As green as I am, my skin
>crawls when I hear platitudes like  "If God wanted us to ..... He would have
>given us........" or the said activity is an example of "humans trying to play
>God".  Almost nothing at all in our civilization is "natural"; and although
>Western materialism sometimes promotes innovation for innovation's sake, there
>are technologies that are unfortunately needed; simply for the present needs
>of modern civilization.
>Peace for All Beings
>Jamey Lee West
>
>
>
>
>Jim Tantillo <[log in to unmask]> wrote:
>
>> ---------------------------------------------
>>	Attachment:Ý
>>	MIME Type:Ýmultipart/alternative
>> ---------------------------------------------
>Hi again everyone, and hi John,
>
>Before I say anything about John's specific comments regarding phthalates:
>John, I would love to get a copy of your paper on phthalates, as I sense I
>am out of my league on this particular subject.  (If you have an electronic
>copy that you could send me off-list as an attachment, I would *very* much
>appreciate your sending that along.)  You may be right that phthalates
>represent a very real cause for concern.
>
>But as is so often the case with environmental health issues, I have a
>hunch that the phthalate issue is not so unambiguously simple.  As in every
>case of environmental risk, there are two fundamentally different attitudes
>one can have toward such risk: a high tolerance for (low) risk, and a "zero
>tolerance" attitude to (low) risk.  In some cases, the zero tolerance
>attitude borders on being an irrational paranoia of things that have little
>or virtually no likelihood of actually hurting us.
>
>Now, not knowing the specifics of the animal testing procedures (and
>eagerly looking forward to your summary of it) for phthalate toxicity, I
>would still hazard the guess that the various tests were a lot like other
>such tests:  extreme dosages of phthalate (10x or 100x or even 1000x more
>than what humans might encounter) were forced upon laboratory animals, with
>the results you report (testicular atrophy, etc.).  I have no doubt this is
>the case.  But then we still have to ask, what is the significance of those
>tests for inspiring the fear and concern over human children ingesting
>phthalates?
>
>The odds of children ingesting much of anything from the chewing and
>sucking on teethers seems to me to be almost infintesimally small.  I have
>two children, and speaking from my observations, I've never seen that my
>children were all that interested in teethers; and what little interest
>they had was limited to intermittant chewing (sucking really) for perhaps a
>period of about 2 to 3 months prior to the age of one year.  How is the
>fearful process of ingestion supposed to take place?  I see little or no
>evidence of plastic being sloughed off the teether.  (It's not like my dogs
>chewing a synthetic dog bone, which eventually does get chewed apart.)
>Does the ingestion of phthalate occur via osmosis?  Would a child have to
>suck on a thousand teethers for a thousand years in order to equal the dose
>the lab rats got in the toxicity tests?
>
>John wrote:
>>If I was a planning on being a parent, I would not have any toys such as
>>teethers, etc., near my baby. This is the application of the precautionary
>>principle. To take precautions one should not knowingly allow the substance
>>into the system of a fetus nor a baby.
>
>Given everything I know about science, acute toxicity animal tests, and
>children, I would have to say that this is not precautionary, this is
>paranoid.  Speaking as a parent, seems to me that there are an awful lot
>more things for me to worry about than the questionable risk of phthalate
>ingestion.  Falling out of windows; bee stings; milk allergies; etc. all
>kill thousands of kids every year.  The potential risk of harm from
>naturally occurring toxins in foods (e.g. peanut butter) is thousands of
>times greater than what likely has been identified in phthalates--although
>please correct me if I'm wrong.
>
>The point of my earlier post about the "precautionary principle" is that
>when such a belief is pushed to extremes, the result is just such
>irrational fear as is expressed in your statement, "If I was a planning on
>being a parent, I would not have any toys such as teethers, etc., near my
>baby."  As a parent I have much more potentially to worry about (and I
>*don't* worry about it) just in the routine and everyday ingestion of dirt
>that my kids experience from picking their dropped food off the floor and
>eating it.  With dust from four dogs, road dirt, winter salt, leftover
>household cleaners, dead bugs, house flies this time of the year, etc. all
>contributing to the dirt and grime that undoubtedly sticks to the dropped
>peanut butter sandwich that my kid proceeds to eat, I just don't see how
>phthalates measure up, risk-wise.
>
>The situation with phthalates can probably be compared to that concerning
>radon.  The U.S. EPA has set the regulatory structure guiding radon
>remediation at such a ridiculously low level of risk that professional
>toxicologists smirk at the whole thing.  When a house is bought or sold in
>New York today, a buyer can request a radon test.  If the test comes back
>with a result greater than 4.0 (don't know the units right off hand--just
>know the "magic number is 4.0), ppm or ppb let's say, than the seller
>generally gets to install a $1000+ radon remediation system in order to
>sell the house.  A professor in our department worked for EPA for twenty
>years on exactly that issue--and he says the significant figure in terms of
>real risk is somewhere on the order of 1000 ppm, or even 10,000 ppm.  Thus
>a reading of 3.8 versus a reading of 4.1 in a real estate house inspection
>radon test means *NOTHING* in reality, and yet it means all the difference
>in the world if you're trying to sell your house.  Why?  Because if you
>have a buyer prone to paranoia, that 0.3 ppm difference means all the
>difference in the world--when it should mean exactly NOTHING.
>Statistically there is no difference between a reading of 3.8 and a reading
>of 4.1--but that reading often means the seller has to cough up an extra
>1000 bucks just to sell the house.  In reality (i.e. in terms of actual
>risk), there is virtually no difference between a reading of 4.0 and a
>reading of 100.  The number is simply and arbitrarily set somewhere--and
>that 'somewhere' happens in the case of radon to be so pathetically low as
>to be meaningless.  The precautionary principle here as it is enshrined in
>public policy means irrational public policy.  People have lived with radon
>(a naturally occurring toxic) for hundreds of thousands of years--and we're
>all still here.  Cave men ate off dirt floors--and we're worried about
>ingesting phthalates from baby teethers.
>
>. . .  And this is also why the fear-mongering of environmental advocacy
>organizations like Greenpeace is a legitimate topic of concern for
>environmental ethics.
>
>>The application of Bayesian statistics here has no purpose...not if you were
>>to read my paper on the phthalates.
>
>Don't get me wrong . . . maybe you know something that I don't, that
>phthalates in baby teethers pose a real risk--I'd like to see the evidence.
>But one has to have a sense of proportion about these things--otherwise, we
>could never force ourselves to get out of bed in the morning for fear of
>all the things that might hurt us.  I bet there are many more fearful
>things for parents to worry about than phthalates in their kids' toys or
>GMO foods.
>
>Jim
>
>
>>In "Plastic Panics and the Perils of the Precautionary Principle," Bill
>>DurodiÈ, a research student at the London School of Economics, writes with
>>regard to the policy process in Italy:
>>
>>"The impending decision by the Italian government is therefore simply the
>>tail end of a process formalising self-regulatory action already taken by
>>retailers and endorsed by regional authorities, which have been mirrored
>>all over Europe and more recently, in the US. The actions of Greenpeace
>>have been identical throughout. By a carefully timed and crafted sequence
>>of stunts, press releases, and often unsubstantiated scientific papers,
>>their campaigners have, in the manner of precocious schoolchildren,
>>managed to play off all the major interested parties against one another.
>>
>>"Ironically, throughout this period new scientific evidence as to
>>potential harm has entirely contradicted the actions that were taken.
>>There is simply no cause for concern about the impact of phthalates in
>>babies' toys or elsewhere. Unfortunately, many measures by retailers and
>>regional governments were taken prior to the publication of the results
>>last autumn of a major study aimed at bringing clarity to some of the
>>research evidence. This indicated the risks posed to be so small 'that the
>>statistical likelihood cannot be estimated'. However, by applying the
>>so-called 'precautionary principle', now advocated by the European
>>Commission as a guide to all such investigations post-BSE, the CSTEE has
>>issued a series of opinions maintaining that there is 'cause for concern'.
>>
>>"These opinions have been based upon extrapolating from the worst
>>available data (for one particular compound this was 10,000 times greater
>>than the next nearest estimate), scaled up by a further factor of 100 for
>>safety, and based on exposure doses and times since recognised to have
>>been grossly exaggerated. It was also assumed that humans would suffer
>>from the most sensitive adverse effects noticed in experiments upon
>>rodents, although even the CSTEE accept that in the case of cancer this
>>'may have little relevance for humans', whilst the latest available in
>>vivo research indicates no effect upon reproductive capabilities.
>>Moreover, evidence that the majority of human consumption of phthalates
>>comes from food has studiously been ignored.
>>
>>"But the 'race to the bottom' logic of applying the 'precautionary
>>principle', which encourages caution and inaction in the absence of
>>absolute proof of safety, thereby reversing the usual scientific burden of
>>proof, will mean more than the wholesale replacement of childcare articles
>>and toys. In countries where the campaign has been successful the focus
>>has now moved onto medical devices such as flexible tubing, intravenous
>>bags, catheters and protective gloves. These have provided billions of
>>patient days of acute exposure with no evidence of adverse effects even
>>amongst the most exposed groups, such as patients receiving dialysis for
>>kidney disease. Yet, companies with a vital interest at stake, and who are
>>aware of the enormous social benefit brought by products which are
>>durable, disposable, flexible, inexpensive and safe, have proven to be
>>remarkably defensive in their stance."
>>(full text at http://www.esef.org/durodie.htm )
>
>
>
>
>
>
>
>
>
>
>
>
>>The application of Bayesian statistics here has no purpose...not if you were
>>to read my paper on the phthalates.
>>
>>Best regards,
>>
>>John Foster
>>
>>MSc candidate
>>Environmental Sciences,
>>
>>Royalroads University
>>Victoria, BC
>
>
>____________________________________________________________________
>Get free email and a permanent address at http://www.netaddress.com/?N=1

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