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Subject:

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

From:

VeggieBiggs <[log in to unmask]>

Reply-To:

[log in to unmask]

Date:

Mon, 12 May 00 13:49:59 EDT +0000

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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.  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:  
>	MIME Type: multipart/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
>Durodié, 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


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