October 2021 Director’s Corner
My husband and I recently joined my daughter and her husband for a day of flyfishing on Yellow Breeches, a beautiful limestone and well-known trout stream in south-central Pennsylvania. It was a remarkable Fall Day; the air was dry, the sky blue and clear, a slight breeze ruffling the leaves on the wooded banks, the water clear, and the sandy bottom holding stones of a perfect size for gentle riffles and float lines. If you are a flyfisherman, have come upon one while walking along a stream, or are a fan of A River Runs Through It, you can understand its ability to mesmerize, this generally unsuccessful presentation of a feathery insect imposter to a wily fish. While both novice (myself) and experts may enjoy highly differential rates of success, I would venture to say that both experience the same sort of Zen that standing in a stream can bring. And so imagine the disarming moment when I looked down at my waders and suddenly had a thought that stopped me in mid-cast; might I be the very thing that was introducing PFAS, a potentially toxic chemical that is resistant to degradation, into this aquatic ecosystem (if you are new to the issue, check out https://www.epa.gov/pfas/basic-information-pfas for some basic information)?
Given the recent CRC Roundtable on contaminants of emerging concern (CECs), I’ve been reflecting on how often I unsuspectingly find myself to be part of the environmental problem and wondering how that comes to pass. An answer may lie in the implementation of the Precautionary Principle in US environmental regulation of chemicals. The Precautionary Principle states that, “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically” (Raffensberger and Tickner, 1999)1. The primary avenue of implementation of the Precautionary Principle in the regulation of chemicals is through the Toxic Substances Control Act (originally passed in 1976 and revised significantly in 2016), but its efficacy is challenged by the sheer number of chemicals and their essential role in modern life, with more than 95% of all manufactured goods and articles relying on them. A recent inventory found more than 350,000 chemicals that are registered for global production and use, almost triple that estimated by earlier surveys (Wang et al., 2020). If we simply consider the US, the situation is a bit less overwhelming, although the exact number is highly contested. EPA has more than 85,000 chemicals listed on its inventory of substances that fall under TSCA, but the exact amount of those that are currently in the marketplace is unknown2. Since TSCA’s enactment in 1976, the EPA has only banned nine chemicals from production, import, and use in the US; the gap would suggest that the implementation of the Precautionary Principle is far behind. Why is the gap so large? Is the standard of regulation so high that only a few substances exhibit risks that are considered unacceptable? Is there a paucity of adequate data on the effects of chemical substances because of limitations in analysis and detection? Is the burden of proof misplaced? Finally, is the very way that science is conducted and/or communicated part of the problem?
While they are all probably in play, this last one is particularly relevant for those of us that are science provisioners. A paper written over two decades ago (Kriebel at al., 2001) examined the implications of the precautionary principle for environmental scientists, specifically examining its methodologies and considering ways that research can be more helpful to those who would act with precaution. In other words, how we might be most helpful to policy makers without compromising integrity and objectivity. The recommendations included the following:
- A need for better methods to study whole systems and the interactions of various causal factors
- Engagement and use of multidisciplinary teams
- Expanded research to find ways to characterize, express, and communicate uncertainty (e.g., Bayesian methods)
- Standard inclusion of formal sensitivity analyses in which the investigator assesses the degree to which results are changed by using different assumptions or analytic methods (e.g., research methods and models)
- Strong environmental monitoring programs with accompanying formal evaluations of the effectiveness of management actions and policies (and the potential for unintended consequences)
- A need for “joining edge” research (as opposed to “cutting edge”), where the results of the work of many disparate disciplines are synthesized to reach insights not possible by individual researchers.
The term “precautionary principle” came into English as a translation of the German word Vorsorgeprinzip and has an alternative translation as “foresight principle”, which emphasizes anticipatory action. The main article in this issue highlights the work of researchers who are practicing foresight while doing their work in alignment with the above recommendations. Let us support, in the best possible way, the use of foresight and precaution in the making of decisions.
1The statement went on to list four central components of the principle: taking preventive action in the face of uncertainty; shifting the burden of proof to the proponents of an activity; exploring a wide range of alternatives to possibly harmful actions; and increasing public participation in decision making.
2Lower estimates are 38,304 chemicals reported in use from 2006 through 2016 under the Toxic Substances Control Act (TSCA), and 8707 reported in 2016 from EPA’s Chemical Reporting Database which requires manufacturers to report chemicals they produce domestically or import into the United States.
Kriebel, D., Tickner, J., Epstein, P., Lemons, J., Levins, R., Loechler, E. L., Quinn, M., Rudel, R., Schettler, T., & Stoto, M. (2001). The precautionary principle in environmental science. Environmental health perspectives, 109(9), 871–876. https://doi.org/10.1289/ehp.01109871
Raffensperger C, Tickner J, eds. (1999). Protecting Public Health and the Environment: Implementing the Precautionary Principle. Washington, DC. Island Press.
Zhanyun Wang, Glen W. Walker, Derek C. G. Muir, and Kakuko Nagatani-Yoshida. (2020). Toward a Global Understanding of Chemical Pollution: A First Comprehensive Analysis of National and Regional Chemical Inventories. Environmental Science & Technology 2020 54 (5), 2575-2584. DOI: 10.1021/acs.est.9b06379