in the 21st century
|
| Advancing the principles of
freedom in the 21st century |
| IV. Chemicals and Management of Waste |  |
For many, the mere mention of toxic chemicals immediately conjures up images of a skull and crossbones, of dead fish floating on poisoned water, of barren soils, and of people made sick by chemicals in food, water, and air. Likewise, many people believe most chemicals produced by manufacturing processes are bad and should be banned. "Toxic chemicals" to them are synonymous with "synthetic" or "man-made" chemicals, while chemicals in "organic" or "natural" foods or products are perceived to be benign.
The popular division between man-made and natural is incorrect, however. Toxic substances occur naturally, and humans and other life forms cope with them as part of everyday existence. A chemical is or is not a risk depending on how it is used and how living things encounter it. Arsenic, a deadly poison, is naturally found in wheat and other foods. Humans produce hydrochloric acid in their stomachs to aid in digestion, and our stomach\u2019s lining provides protection from the acid. While salt is essential in our diet, it can be lethally toxic in high enough concentrations.
Paracelsus, a 16th Century Swiss physician, made the key point that "Poison is in everything, and no thing is without poison. The dose makes it either a poison or a remedy." Dr. Bruce Ames, who developed one of the most frequently used tests for cancer-causing potential, wrote, "The vast bulk of the chemicals humans are exposed to are natural, and for every chemical some amount is dangerous."1
For instance, Ames has found that coffee is about 50 times more carcinogenic than DDT, and more than 66 times more carcinogenic than the most dangerous present-day pesticide, called ETU.2 Coffee is made up of over 1,000 chemicals, 70 percent of which are thought to be carcinogenic.3 Yet, the U.S. Environmental Protection Agency (EPA) does not ban or even regulate exposure to coffee because these carcinogens are not harmful in the concentrations found in coffee. Yet, the United States and other nations banned DTT because of the misperception that it was dangerous at any concentration. Ames reminds us that many chemicals serve vital functions when used properly. It is only when they are not used properly that problems can occur.
Toxic chemicals can clearly cause damage and must be treated with respect. When used properly, however, they carry little risk for either people or the environment. Extreme reaction to a perceived toxic threat is usually counterproductive and can be the result of deliberate scare campaigns conducted by activist pressure groups that are legally exempt from the false advertising laws that govern the conduct of corporations. This was the case in the 1989 Alar scare perpetrated by the Natural Resources Defense Council, Fenton Communications, and a gullible CBS 60 Minutes. The scare terrified mothers and created economic devastation for the United States apple industry, which used this safe chemical to prevent unripe apples from dropping from the trees.4 It also brought much new revenue to the NRDC, Fenton, and CBS.
Government officials can also politicize risk, thereby creating fear when risk is actually low. Dioxins, for instance, are a group of chemical compounds that can be released naturally in volcanic eruptions and forest fires, and by human activities like trash burning, metal smelting, fuel burning, and bleaching paper pulp. While some dioxins are highly toxic and carcinogenic in laboratory tests, many studies have shown that dioxin is non-genotoxic in its cancer analysis.5
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Figure 1 The U.S. EPA has arbitrarily set the maximum "safe" level of dioxin 100 to 1000 times lower than any other agency or government in the world. |
The EPA labeled dioxins a "known human carcinogen" in 1994 but its scientific advisors rejected that conclusion. In June 2000, The EPA tried again. Relying on its own methods to estimate cancer risks, EPA's 2000 dioxin risk assessment claimed the cancer risk is ten times higher than the agency estimated in 1994.6 The EPA estimate is completely out of line with assessments conducted by government and scientific agencies in the rest of the world. The Chlorine Chemistry Council reports that the EPA set its "safe" daily exposure to dioxins at levels 100 to 1,000 times lower than safe levels determined by the Joint United Nations Food and Agriculture Organization/World Health Organization Expert Committee on Food Additives, the European Commission Scientific Committee on Food, the governments of Canada, Japan and the Nordic nations, and the U.S. Agency for Toxic Substances and Disease Registry.
It gets worse. Research presented at the 23rd International Symposium on Halogenated Environmental Organic Pollutants in 2003, showed that at high body levels, humans eliminate from their bodies traces of dioxin three to five times faster than previously thought. This research "cast doubt on the commonly used estimate of dioxin cancer potency, a cornerstone of the EPA's draft health risk assessment of this substance."7
Applying the EPA's risk estimates to real world situations leads to ludicrous results. One serving of Ben and Jerry's vanilla ice cream contains 200 times the EPA's "safe" level of dioxin. Even more worrying for anyone who takes the EPA's risk estimate literally, the background level of dioxin in the United States is presently 100 times higher than the EPA deems safe for human exposure.8
In spite of the highly controversial science used to justify its stringent and very costly regulations for dioxin emissions, the EPA's regulations have been extremely successful in reducing dioxin. The combination of EPA regulations and voluntary efforts in industry dramatically reduced dioxin emissions by 92 percent between 1970s and 2004 in the United States.9 Human levels of dioxin have followed a similar path. The levels of dioxin in the average U.S. resident are so low that a 2003 study by the U.S. Center for Disease Control and Prevention (CDC) reported dioxin levels in the blood were below levels of detection.10
These examples do not necessarily lead to the conclusion that regulations should not be used to reduce risk. But large government agencies are rarely a good source of information to define risk and formulate regulations because it is subject to the myriad of political agendas within bureaucracies. No one can be certain what led the EPA to its high estimates of risk, but the agency has invested much time and effort to convince the public that its regulations are important for the public's health.
Another deficiency of government agencies establishing risk and regulations is that they rarely factor the costs of their actions. Congress actually forbids the EPA to consider cost in some environmental laws. Without considering cost, however, limited financial resources will be squandered on poster-child issues like DDT and dioxin, while other far more serious health issues do not get addressed.
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Figure 2 Median cost per life-year saved for different sectors of society in 1993 dollars. Source: Tengs et al. "Five-hundred life-saving interventions and their Cost Effectiveness." Risk Analysis, 1995, 15:371 |
Tengs et al. calculated the costs of government programs that are designed to save lives. It costs almost nothing "per life-year saved" to reduce the lead in gasoline from 1.1 g (gram) to 0.1 g. However, to control arsenic emissions at glass manufacturing plants would cost $51 million per life-year saved and to control benzene (a highly toxic chemical) emissions at rubber tire manufacturing plants would cost $20 billion per life-year saved.11 The question is where best to spend our limited dollars. In almost every case, the cost of protection from environmental toxics like dioxin is many orders of magnitude higher than saving lives in health care, residential safety, transportation safety and occupational safety. (See chart)12
The real cost comes when the zeal for saving lives suffers the Law of Unintended Consequences, in which the cure is worse than the problem. Such is the case for the drumbeat by many environmentalists to eliminate pesticides. These special interest groups claim that hundreds of Americans die annually due to man-made pesticide-caused cancer. In contrast to that claim, a group of prominent scientists found that the number of pesticide-caused cancer deaths is at most 20 a year, and may be zero. That number of 0 to 20 estimated deaths can be compared to the 300 people who die annually from drowning in their bathtubs,13 and 2000 that die of cancer from eating spices.14 Since eliminating pesticides would cost between $20 billion and 300 billion annually, the minimum cost per life saved would be $1 billion.15
An immediate consequence of eliminating pesticides would be increased food prices, especially for fruits and vegetables. Increased prices will force people of limited means to reduce their fruit and vegetable consumption with the tragic unintended consequence that cancer rates will increase. A decrease of fruit and vegetable consumption of just 10 percent in the United States is estimated to cause an increase in cancer deaths by about 26,000.16 In other words, banning the use of pesticides in the United States might save 20 people, but 26,000 lives could be lost doing so.
In spite of the overwhelming evidence that pesticides are not a significant cause of cancer, people remain fearful and are easily persuaded by emotionally-charged advocacy literature that pesticides are extremely dangerous to public health. This phenomenon is explained by Dr. Robert Scheuplein, head of the Food and Drug Administration's office of Toxicology in the early 1990s. He explains:
"When risks are perceived to be dread, fatal, unfamiliar, uncontrollable by the individual, unfair, involuntary, and potentially catastrophic, they are typically of great public concern (or 'high outrage'). When risks are perceived as voluntary, controllable by the individual, familiar, equitable, easily reducible, decreasing and non-catastrophic, they tend to be minimized by the public (or 'low outrage')."17
Scheuplein's observation is a reflection of human nature. Opportunistic activist groups take advantage of this phenomenon by playing on public concern. Because issues like dioxin and pesticides strike primal fears, boring factual education rarely convinces people that there is no problem. The only effective means of maintaining balance in an emotionally-charged issue is in maintaining unbiased regulatory agencies. However, when those agencies appear to join hands with activists, as is the case with dioxin and pesticides, the system of checks and balances can no longer function properly. Overly restrictive regulations are imposed resulting in squandering limited resources and harming people and the economy.
There is an even more troublesome side to regulatory agencies joining activist causes—the Law of Unintended Consequences. To reach the goals established in the 1990 Amendments to the Clean Air Act, the EPA required oil companies to add oxygenates to gasoline sold in the nation's ten smoggiest cities. Methyl Tertiary Butyl Ether (MTBE) quickly became the additive of choice. Although MTBE is not known to be carcinogenic, it has been indirectly linked to testicular, kidney and liver cancer, as well as leukemia and lymphoma in laboratory rats.18 The Centers for Disease Control also reports MTBE exposure is linked to health symptoms including: headache, dizziness, burning sensation of nose or throat, coughing, nausea, vomiting, and disorientation.19 Because of its high solubility, MTBE spreads quickly, polluting ground water and causing it to taste and smell like turpentine. Leaking underground tanks at corner gas stations forced wells to close. A mere spoonful of MTBE can foul the water in an Olympic-sized swimming pool sufficiently to smell it.
MTBE has been detected in water supplies of all 50 states, and in cities of all sizes. New York has identified 1500 sites, with 400 on Long Island alone. California has identified upwards of 10,000 sites. Santa Monica, California was hit hard in 1995, forcing the city to shut down half of its wells and import 80 percent of its water. Human health has been affected. In Alaska, so many people became ill, the state declared an epidemic, finally banning MTBE in 1994.20 Many other states have also reported adverse health reactions: Montana, Illinois, Arizona, Iowa, New York, Colorado, Maine, Massachusetts, and Pennsylvania.21
Incredibly, the EPA knew about some of these problems before it authorized MTBE use. Yet, it forged ahead anyway and mandated billions of dollars of retrofitting refineries to inject MTBE into gasoline. Once the magnitude of the problem was determined, the EPA refused to ban the substance, forcing nearly two dozen states to partially or totally ban it.22 Other states are considering bans. Yet it wasn't until 2000 that the EPA even started to consider banning it.
The overriding question in the MTBE issue is why the EPA chose to use MTBE to solve one problem when it knew beforehand that it would create other environmental problems? Why has it taken so long to take action once it was clear that MTBE was creating one of the biggest environmental problems in the history of the United States? Several states have already sued the EPA, potentially exposing the federal government to enormous liability claims. The cleanup costs alone will likely cost industry and local governments billions of dollars. Had a private company done the same thing, its corporate officers would have been brought up on criminal charges.
In summary, the question of toxic chemicals becomes one of balancing risk. Chemicals don't present a health risk to people or the environment, if used correctly. Just how much we spend on preventing exposures to toxics that are proven or suspected to cause health risks should be balanced against the benefits to society and the compared to the benefits of spending limited dollars elsewhere. Whether because of political pressure, personal political agendas, or some other reason, government regulatory agencies are falling well short of this goal everywhere in the world.
The above examples pointedly reveal how the Law of Unintended Consequences can prevail when only a few overzealous government employees are given the power to develop policy that has an enormous impact on people to whom they are not accountable. As such, it graphically illustrates the potential global tragedy that can result from international governance of environmental regulations. Sustainable development, as envisioned by the U.N., calls for giving even more power and autonomy to U.N. officials to stop anything they believe is not sustainable. If the EPA can be insensitive to opposing ideas and facts when they are only slightly accountable to the people over whom they have jurisdiction, it can only be surmised that a totally unaccountable U.N. bureaucracy nobly administering their vision of sustainable development would have virtually no motivation to correct a potentially flawed policy. Such a scenario, to be sure, would be most troubling, and thus should be avoided at all costs so as to better serve the public interest.
Hazardous and Radioactive Waste
Hazardous waste is the term given to the waste generated at home, school and work that poses a danger to human health or the environment. If not disposed of correctly, it can damage our air, land and water. The EPA identifies four categories of hazardous waste: corrosive, ignitable, reactive, and toxic. American industry alone produces 320 million tons of hazardous waste every year. According to the EPA, 288 million tons of this is wastewater managed in treatment systems or pumped into injection wells. Twenty-seven million tons of industrial and household hazardous wastes are disposed of by methods other than incineration, and 5 million tons are incinerated each year.23
Following a fatal chemical-release accident in Bhopal, India, the U.S. Congress enacted the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986, to promote emergency planning, minimize the effects of such accidents, and provide the public with information on releases of toxic chemicals in their communities. Section 313 of EPCRA established the Toxics Release Inventory (TRI), a national database that identifies 650 chemicals and the facilities at which they are used.24 The TRI tracks chemicals manufactured and used at identified facilities, as well as the annual amounts of these chemicals released in routine operations or accidents.
TRI is an excellent system for getting information about chemicals to first respondents and community leaders who understand chemicals, toxicity, risk management and how to safeguard a community. However, it has been abused greatly by both the EPA and NGO green activists like Greenpeace. They have used the data to disseminate raw information to people who don't understand its context and limitations, and thus freighten communities into demanding that companies either shut down or relocate otherwise safe facilities.
Critics of the TRI reported on one unintended consequence from its inception. It provides invaluable information to terrorists about where chemicals are stored, how many people might die from a release, and details of the containment structures and processes to guard against a release. In the wake of the 9/11 terrorist attacks, the EPA finally removed TRI data from its website. At a minimum, centralized policies like TRI may not be in the public interest. Again, the potential for abuse by an unaccountable government agency and its NGO partners should be more than sufficient not to advance the U.N. sustainable development concept.
Household hazardous wastes include leftover household products that contain corrosive, toxic, ignitable, or reactive ingredients.25 Many communities in the United States offer a variety of options for safely managing these wastes. While not always convenient, they can help to reduce future pollution. The primary problem is identifying if, and under what circumstances a waste item becomes hazardous. Environmental bureaucracies have a tendency to lump anything that might conceivably be a future problem in this category, even if it is not a problem today, and generally frown at concentrations of chemicals which are currently found in the waste. The best solution for this is local control, where the federal government serves as an advisor and the local government sets the rules on hazardous waste. In some cases, like batteries and tires, commercial recycling has provided a viable solution.
Commercial hazardous waste has a long history and is involved with recycling, breakdown into harmless substances, and storing toxics in long-term containment. Since this kind of storage is very expensive and costly to the user, companies have been very innovative in finding ways to recycle or develop markets for them. Vitrification or incineration at extremely high temperatures, in kilns that have state-of-the-art air recycling and pollution control systems, is one of the best ways to get rid of toxic chemicals.26
Free markets that reprocess waste product from other commercial processing plants into useful new chemicals is a potential alternative to disposal. However, the Basel Convention on the Transboundary Shipment of Hazardous Wastes makes it impossible to send many chemical wastes to countries that would otherwise welcome such cheap sources of chemical feedstock for their processing and reprocessing plants. Many countries signed onto this accord, believing it was designed to protect them. They did not realize how it would be used to prevent them from acquiring feedstock because certain developed countries (mostly in Europe) did not want any cheap foreign competition for their own chemicals industries.
Containment is the choice of last resort. Once companies can no longer dump their waste into rivers, oceans or dump sites, free market incentives create the ability to find alternative uses.
Much of the controversy over nuclear power centers on the lack of a disposal system acceptable to politicians and the public. As a result, progress on nuclear waste disposal is widely considered a prerequisite for any future growth of nuclear power.
Concerns about past abuses haunt the technology and complicate public acceptance. Russia, for instance, used the Arctic Ocean as a dumping ground for many types of nuclear waste, some of which has a half-life of thousands of years. If the polymer containers in which the waste is stored deteriorate, they may create future containment problems. This represents a case of an unaccountable government-owned industry choosing short-term solutions that could cause severe problems in the future.
There is some good news for the Arctic dump sites, however. Investigations by the International Arctic Sea Agency have tentatively shown that the nuclear waste provides no immediate threat to either humans or the Arctic eco-system. This optimistic conclusion is based on the fact that despite the detection that leakage has already occurred, the radioactive elements of the waste remain localized to the specific waste sites.27
Planned nuclear waste disposal in the United States will be far more secure, though concerns remain. Under the Nuclear Waste Policy Act of 1982 (NWPA) and 1987 amendments, the Department of Energy (DOE) has selected Yucca Mountain, Nevada, for housing a deep underground repository for spent nuclear fuel and other highly radioactive waste. The state of Nevada has fought DOE's efforts on the ground that the site is unsafe, pointing to potential volcanic activity, earthquakes, water infiltration, underground flooding, nuclear chain reactions, and fossil fuel and mineral deposits that might encourage future human intrusion.
DOE contends, however, that extensive and exhaustive studies have shown that Yucca Mountain is a suitable depository site, although studies of the site should continue. A "viability assessment" issued by the DOE December 18, 1998, concluded, "no show stoppers have been identified to date at Yucca Mountain." A Draft Environmental Impact Statement completed by the Energy Department in July 1999 supported those findings. The planned Yucca Mountain repository is not scheduled to open until 2010 at the earliest, more than a decade later than the 1998 goal specified by NWPA. Because scientists believe the geologic formations have remained undisturbed for millions of years, it appears technically feasible to isolate radioactive materials from the environment until they decay to safe levels. "There is no scientific or technical reason to think that a satisfactory geological repository cannot be built," according to the National Research Council.
While no one can be certain the geology will remain stable for the needed 10,000 year period, the Yucca site does offer the safest depository. Local residents remain concerned, however, and every means should be taken to monitor the site for safety purposes and ensure that proper security and safety protocols are followed.
Each American produces about 4.4 pounds of waste daily. During the course of a year, the U.S. produces some 229 million tons of municipal waste, up from 2.7 pounds per person per day in 1960.28 This has given rise to claims that the U.S. is running out of landfill space. However, Americans ship less waste to landfills than they did in 1979 because of incineration, recycling, and composting. Currently, in the United States, 30 percent is recovered and recycled or composted, 15 percent is burned at combustion facilities, and the remaining 56 percent is disposed of in landfills.29 Consequently, out of 229 million tons of waste produced, only 128 million tons wind up in America's landfills.
Incineration offers one alternative to landfills. Many incinerators built during the 1980s did not burn hot enough, thereby emitting unacceptable levels of polluting gases into the atmosphere. However, improvements in technology since the 1980s have reduced emissions of polluting gases and it is now possible to attain 99.99 percent cleaning of incinerator stack emissions.30 In 2001, 97 communities in the U.S. utilized solid waste incinerators, "waste to energy" (WTE) facilities.31 That generated substantial amounts of electricity in state-of-the-art, non-polluting plants. In goes a steady stream of garbage, and out comes electricity, ash that is perhaps 10% of the wastes' original volume and recycled metals and glass that can be readily collected from the ash. (Even bottle caps, paper clips, staples and metal bottoms from cardboard juice boxes can be extracted from the ash. Previously, these items would have gone to landfills).
Although incineration technologies are available, the preferred method of disposal continues to be landfills. The popularity of landfilling (largely because of cost factors) by local communities has fueled the claim that the world is running out of space for landfills, especially in the United States. Fortunately, these claims are untrue. If the U.S. continues to produce 128 million tons of landfill waste for the next one-hundred years, the total space required would fill up a block fifteen miles square, and one hundred feet deep. Assuming there are only 2,000 landfills in America, each landfill would only require less than 0.12 additional square miles to dispose of all the waste in the next 100 years. Even with an ever increasing amount of landfill waste, only a slightly larger area would be required—nineteen miles on a side.32 When spread out over thousands of landfills in America, the seemingly insolvable problem disappears.
It is also extremely unlikely that landfills will cause an increase in cancer-related deaths. The EPA estimates that the 6,000 landfills in the U.S. will only cause 5.7 cancer-related deaths over the next 300 years,33 and it's almost equally likely that they will cause no deaths.
The biggest problem with solid waste is the age-old "Not In My Back Yard," or NIMBY syndrome. Solid waste dumps create truck traffic, some smells, and reduce property value. Thus the solid waste problem is a political issue, not one of insufficient space. Modern landfill sites are kept clean to comply with contracts written between waste disposal companies and government entities and regulations, hidden behind trees and berms, and often capped by gasification systems that collect escaping methane for use in power plants. Also bear in mind that garbage and landfills are a price of being people. Even the Anasazi and Romans had garbage and landfills.
One solution to the NIMBY problem is for the local city or county government to purchase sufficient land to act as a buffer zone between the landfill and adjacent residential development. The site can also be located in industrial areas which are not as sensitive to this issue. Finally, the city or county can compensate local residents for the inconvenience by reducing their property taxes and giving them free trash service or reduced electricity rates (especially if some of the electricity comes from gasification or WTE facilities). Nonetheless, these options are generally very expensive solutions that will, in the free marketplace, place increasing pressure on the waste industry to develop more cost-effective alternatives.
Agenda 21 claims that the problems with chemicals, toxic waste and solid waste are so massive that only international solutions are possible if the world is to become sustainable. As defined by Freedom 21, every one of these problems are either greatly exaggerated or can be solved most effectively at the local or national level. The powerful, unaccountable form of global governance proposed in Agenda 21 by the United Nations and international community opens the governing process up to inefficiency, corruption and abuse.
Agenda 21 cannot work. Ironically, almost all the topics addressed in the sustainable development issues above are resolved by eliminating poverty. Although Agenda 21 calls for eliminating poverty as a necessary step, it is incapable of doing so as described in the introduction and Chapter 1 of this Freedom 21 document. Tragically, global governance as envisioned in Agenda 21 can only make poverty worse thereby exacerbating all the problems outlined in Agenda 21.
There is a direct correlation between the waste produced per person and per capita income.34 The wealthier a developing nation becomes, the more waste they will produce. At the same time, however, the wealthier the nation the more environmental protection they can afford. Since developing nations will not have to reinvent-the-wheel concerning waste disposal, they will be able to employ existing technology to cost-effectively dispose of their increasing amounts of solid waste. However, wealth creation still remains the highest priority—something Agenda 21 and global governance as envisioned by the United Nations is incapable of doing.
Chemicals are not inherently bad. All things are comprised of chemicals. How chemicals are used determines whether they harm or help people and the environment.
Nature produces toxic chemicals. Many toxic chemicals are naturally produced, including the vast majority of pesticides. Natural does not necessarily mean better or safe.
Perceived toxic chemical threats can invoke the Law of Unintended Consequences. Applying an environmental "solution" without first determining its consequences can create problems far worse than the original problem.
Risk analysis done by government agencies are often politicized. Too often the internal politics and agendas of agencies, bureaucrats, and outside pressure groups and the media politicize the science used in developing regulations for a specific law. Likewise, industry is biased by-self interest. Although there is no perfect mechanism for determining risk, that does not mean that risk cannot be estimated and problems resolved.
Government agencies tend to lump real and potential chemical hazards into one group. Not all hazards contain the same risk under all circumstances. Yet, government agencies often lumps them all together for their ease of administration, or to increase regulatory power, funding, or notoriety.
Sustainable solutions must be prioritized before implementing. Billions of dollars can be spent on perceived problems that have low benefits for people and/or the environment compared to other, less glamorous problems.
There is more than adequate space for solid waste disposal. The problem is political, not physical, and centers on legitimate NIMBY concerns.
Where possible, free market solutions are usually better than regulatory solutions. Hazardous waste problems can often be met with creative use of markets and reformulation rather than repressive and expensive regulations.
Nuclear waste can be safely contained, but strict protocols must protect neighboring communities. While controversial, permanent repositories such as the Yucca flats site in Nevada should provide a safe storage for spent nuclear fuel. Reprocessing spent fuel could eliminate most of the waste currently needing storage.
Notes and Citations
1 Bruce Ames and Lois Gold. "The Causes and Prevention of Cancer: the Role of Environment." Biotherapy 1998, 11:212.
2 Ibid, p. 214 and Bruce Ames, Renae Magaw and Lois Gold. "Ranking possible carcinogenic hazards," Science, 1987, 236:273.
3 Bruce Ames and Lois Gold. "Paracelsus to Parascience: the Environmental Cancer Distraction." Mutation Research, 1990, 447:4.
4 Dixy Lee Ray. Environmental Overkill (Washington, D.C.: Regnery Gateway, 1993), p.174-175.
5 "A Comparison of Dioxin Risk
Characterization," The Chlorine Chemistry Council, May 2002.
www.heartland.org/pdf/15207.pdf
6 James Taylor. "Is EPA ready
for the truth about dioxin?" Environment & Climate News, The
Heartland Institute. July 2002, 5(6):18.
www.heartland.org/environment/jul02/editorial.htm
7 Janet Flynn. New Research
Questions EPA's Dioxin Assumptions. Chlorine Chemistry Council. August
26, 2003.
www.heartland.org/pdf/15203.pdf
8 James Taylor. "Is EPA ready for the truth about dioxin?".
9 "Trends in Dioxin Levels in
the Environment and in Humans." Chlorine Chemistry Council, June 1,
2004.
www.heartland.org/pdf/15201.pdf
10 "Trends in Dioxin Levels in the Environment and in Humans." Chlorine Chemistry Council, June 1, 2004. www.dioxinfacts.org/sources_trends/treands_04_10_04.html
11 Tammy Tengs, et al. "Five-hundred life-saving interventions and their Cost Effectiveness." Risk Analysis, 1995, 15:371.
12 Ibid.
13 Len Ritter, Clark Heath Jr., Elizabeth Kaegi, Howard Morrison and Susan Sieber. "Report of a Panel on the Relationship Between Public Exposure to Pesticides and Cancer." Cancer, 1997, 80:2,027.
14 Robert Scheuplein. "Do Pesticides Cause Cancer?" Consumers' Research Magazine 74(12):30-33.
15 Bitchel Committee. Rapport fra hovedudvalget. The Committee to evaluate the full consequences of a total or partial phase-out of pesticide use. Copenhagen: Danish Environmental Protection Agency. 1999, p. 129. And, Ibid, Repport fra den tvaerfaglige økologigruppe: økologiske scenarier for Danmark. In: Bjorn Lomborg, p. 246-247. The Bitchell Committee determined the cost would impact the Danish economy by 3 percent of its Gross Domestic Product (GNP). Taken as a percentage of agricultural production in the U.S., Lomborg determined it to be $93 billion, while taking it as a percentage of the U.S. GNP is $277 billion.
16 Bjorn Lomborg. The Skeptical Environmentalist (Cambridge, New York: Cambridge University Press, 2001), p. 247.
17 Robert Scheuplein. "Do Pesticides Cause Cancer?" Consumers' Research Magazine 74(12):30-33.
18 John Howard (AP) "Gas Additive Poses Cruel Choice: Clean Air or Clean Water? MTBE Detected in All 50 States," Arizona Republic, January 23, 2000, 14(32).
19 "Public Health
Statement." Agency for Toxic Substances and Disease Registry, Division
of Toxicology, (no date), p. 3.
www.atsdr.cdc.gov/toxprofiles/tp91-c1.pdf
20 "MTBE; Cleaning Up the Air or Increasing Our Cancer Risk?" Paper, Allied-industrial, Chemical, and Energy Workers International Union—Local 8-675. February 19, 2000.
21 Ibid.
22 "State Actions Banning
MTBE (Statewide)." US Environmental Protection Agency,
EPA-420-B-04-009, June 2004.
www.epa.gov/mtbe/420b04009.pdf
23 "Alternatives to
Incineration: There's more than one way to remediate."
Environmental Health Perspectives, October 1994, 102(10).
ehp.niehs.nih.gov/docs/1994/102-10/innovations.html
24 "What is the Toxic
Release Inventory (TRI) Program." Toxic Release Inventory (TRI)
Program. U.S. Environmental Protection
Agency.
www.epa.gov/tri/whatis.htm
25 Household Hazardous
Wastes. Environmental Protection
Agency.
www.epa.gov/epaoswer/non-hw/muncpl/hhw.htm
26 "Offsite Thermal
Treatment of Low-level Mixed Waste." U.S. Dept. of Energy,
DOE/EA-1135, May 1999.
www.hanford.gov/docs/ea/ea1135/section-6.html
27 environment.about.com/library/weekly/aa011198.htm
28 "Basic Facts, Municipal
Solid Wastes," U.S. Environmental Protection Agency,
undated.
www.epa.gov/epaoswer/non-hw/muncpl/facts.htm
29 Ibid.
30 "Alternatives to
Incineration: There's more than one way to remediate."
Environmental Health Perspectives, October 1994,
102(10).
ehp.niehs.nih.gov/docs/1994/102-10/innovations.html
31 "Basic Facts, Municipal
Solid Wastes," U.S. Environmental Protection Agency, undated.
www.epa.gov/epaoswer/non-hw/muncpl/facts.htm
32 Bjorn Lomborg, p. 207. Adjusted for the increase in solid waste disposal since Lomborg's book was published.
33 Eban Goodstein. "Benefit-cost Analysis at the EPA." Journal of Social Economics, 1995, 24(2):375-389.
34 Bjorn Lomborg, p. 206.