President-elect George Bush has named William Reilly to head the U.S.
Environmental Protection Agency (EPA). What can we expect from Mr.
For about 20 years, Mr. Reilly has directed the Conservation Foundation
in Washington, DC. In 1987, the Foundation published a 614-page
blueprint for environmental protection, called STATE OF THE
ENVIRONMENT, A VIEW TOWARD THE NINETIES. Everyone should read at least
three chapters: 3: "Toxic and hazardous pollutants," 7: "America's
waste: managing for risk reduction," and 8: "Toxics in the air:
reassessing the regulatory framework." The book is much stronger and
more coherent than anything the EPA has ever published. Therefore, at
the very least, you will be able to confront local EPA officials by
reading passages from this book at public hearings, prefacing your
remarks with, "Here's what your leader has to say on this subject."
If we can believe his book, Mr. Reilly will make a difference in at
least three areas at EPA: (1) he will make more intelligent and
restrained use of risk assessment; (2) he will emphasize the need for
reliable information about wastes and their consequences; and (3) he
will give greater emphasis to waste reduction.
Mr. Reilly's book says, "The best way to make sense out of the complex
components and paths of waste streams is to examine the different kinds
and degrees of risk and damage they create." (pg. 419). In principal,
we agree. However we have all had "risk assessment" used against us by
industry and its supporters in government. They focus the discussion on
one aspect of "hazard," usually the potential to cause cancer in
humans. They simply don't discuss any other health consequences, and
they ignore non-human species entirely. Then they use a mathematical
model to show how the chemical will move through the environment. (The
mathematical model itself may be based on guesswork but it often seems
convincing to local officials because its results are spit out by a
computer.) They use these results to show that, based on one or two
studies of mice or guinea pigs, the amount of chemical likely to reach
the "average" person will only cause "acceptable" numbers of cancers.
What is the "average" person? A completely healthy, well-to-do white
male in the prime of life. What is an "acceptable" number of cancers?
Industry and its supporters in government assume they have the "right"
to kill one person in a million each year by exposure to each chemical
for which a risk assessment is being done. (Where they got this "right"
they never say.)
But risk assessment doesn't have to be carried out in this crude way.
Mr. Reilly's book seems to indicate he'd do it differently.
Risk assessment asks two questions: First, what is the inherent hazard
of the chemical? And, second, how can humans and other creatures become
exposed to it?
Mr. Reilly's book recognizes that both hazard assessment and exposure
assessment are exceedingly complex. Hazard assessment is complex
because so little is known about the effects of most chemicals. "The
science of risk assessment is relatively undeveloped. The National
Research Council concluded in a 1984 report that fewer than 2 percent
of the chemicals currently used for commercial purposes have been
tested sufficiently for a complete health hazard assessment to be made.
Adequate information to support even a partial hazard assessment is
available for only 14 percent of the chemicals; for 70 percent, no
information is available. Moreover, these percentages refer only to
human health hazards. In general, environmental hazards are even less
well understood...." (pg. 425)
Additional complexities include these: Some chemicals degrade into
other, more toxic chemicals. For example, in the environment,
trichloroethylene (TCE) may be transformed into vinyl chloride or
1,2dichloroethylene, substances that are 2.5 and 5 times more potent
than the original solvent. (pg. 422)
A single source of waste can endanger humans and, by a different route,
wildlife, and can create an aesthetic nuisance with serious economic
consequences (making beaches unfit for swimming, for example). Thus,
there may be multiple risks from one chemical discharge.
Mr. Reilly discusses the difficulties in assessing exposure to
The pathways of movement through the environment may be exceedingly
complex and indirect. Air pollution may fall to the ground and become
water pollution, eventually making its way to the oceans. Furthermore,
it is difficult to assess the sensitivity of the people and the
environment that will be exposed. A person's health, age, and exposure
to other chemicals (besides the one being assessed) will affect that
person's sensitivity to a chemical. For example, a person with asthma
responds differently to air pollution than a person without asthma. A
child may absorb more lead than an adult because children have a higher
metabolic rate and are more active, and because some children eat dirt.
Mr. Reilly emphasizes the need for reliable information about wastes:
"The first priority is to get more information about what wastes are
entering the environment, how they are entering, and in what
quantities.... [such information] is useful to... governments in
planning for emergencies, [and] in setting priorities for regulatory
action...." (pg. 454)
Mr. Reilly also thinks we need new information on health effects of
chemicals. He says, "Much attention has been focused on cancer, and the
ability to assess the risk from carcinogens has increased considerably
in the past 10 years. Comparable progress needs to be made in improving
methods to assess other types of health and environmental effects.
After all, exposure to some chemicals can affect people's reproductive,
immune, and nervous systems and can cause other problems as well." (pg.
455) Mr. Reilly's book also indicates the importance of pollution
prevention. He says, "By contrast, the most effective, as well as most
economical, way to reduce the risks associated with wastes in many
cases is to reduce the amount that is generated and released to the
environment." (pg. 410)
Mr. Reilly's book lists seven reasons why industry may want to reduce
its production of wastes. Notice that strategies of the grass roots
environmental movement play a key role in several of Mr. Reilly's 7
1) higher cost of managing waste;
2) financial liability from lawsuits;
3) difficulties in siting new waste management facilities;
4) difficulties getting permits for existing waste management
5) difficulties cleaning up existing facilities;
6) shortages of liability insurance;
7) public concern about toxics.
Don't get us wrong. You will need to remain vigilant and aggressive in
dealing with William Reilly's EPA. But George Bush certainly could have
done a lot worse.
Get: William Reilly and others, STATE OF THE ENVIRONMENT: A VIEW TOWARD
THE NINETIES (Washington, DC: Conservation Foundation [1250 24th St.,
NW, Wash., DC 20037; phone: (202) 293-4800], 1987; $19.95 per copy.
Descriptor terms: epa; william reilly; waste reduction; pollution
prevention; waste avoidance; waste minimization; conservation
foundation; risk assessment;