NOT A VISION OF OUR FUTURE, BUT OF OURSELVES

By Wendell Berry

Attempting to deal with an enormity so staggering as the human destruction of Earth, it is difficult to resist the temptation to write out a "vision of the future" that would offer something better. Even so, I intend to resist. I resist, not only because such visions run the risk of error, but also out of courtesy. A person of my age who dabbles in visions of the future is necessarily dabbling in a future that belongs mostly to other people.

What I would like to do, instead, if I can, is help to correct the vision we Kentuckians have of ourselves in the present. In our present vision of ourselves we seem to be a people with a history that is acceptable, even praiseworthy. A history that we are privileged to inherit uncritically and with little attempt at rectification. But by the measures that are most important to whatever future the state is to have, ours is a history of damage and of loss.

In a little more that two centuries -- a little more than three lifetimes such as mine -- we have sold cheaply or squandered or given away or merely lost much of the original wealth and health of our land. It is a history too largely told in the statistics of soil erosion, increasing pollution, waste and degradation of forests, desecration of streams, urban sprawl, impoverishment and miseducation of people, misuse of money, and, finally, the entire and permanent destruction of whole landscapes.

Eastern Kentucky, in its natural endowments of timber and minerals, is the wealthiest region of our state, and it has now experienced more than a century of intense corporate "free enterprise," with the result that it is more impoverished and has suffered more ecological damage than any other region. The worst inflictor of poverty and ecological damage has been the coal industry, which has taken from the region a wealth probably incalculable, and has imposed the highest and most burdening "costs of production" upon the land and the people. Many of these costs are, in the nature of things, not repayable. Some were paid by people now dead and beyond the reach of compensation. Some are scars on the land that will not be healed in any length of time imaginable by humans.

The only limits so far honored by this industry have been technological. What its machines have enabled it to do, it has done. And now, for the sake of the coal under them, it is destroying whole mountains with their forests, water courses and human homeplaces. The resulting rubble of soils and blasted rocks is then shoved indiscriminately into the valleys. This is a history by any measure deplorable, and a commentary sufficiently devastating upon the intelligence of our politics and our system of education. That Kentuckians and their politicians have shut their eyes to this history as it was being made is an indelible disgrace. That they now permit this history to be justified by its increase of the acreage of "flat land" in the mountains signifies an indifference virtually suicidal.

So ingrained is our state's submissiveness to its exploiters that I recently heard one of our prominent politicians defend the destructive practices of the coal companies on the ground that we need the coal to "tide us over" to better sources of energy. He thus was offering the people and the region, which he represented and was entrusted to protect, as a sacrifice to what I assume he was thinking of as "the greater good" of the United States -- and, only incidentally, of course, for the greater good of the coal corporations.

The response that is called for, it seems to me, is not a vision of "a better future," which would be easy and probably useless, but instead an increase of consciousness and critical judgment in the present. That would be harder, but it would be right. We know too well what to expect of people who do not see what is happening or who lack the means of judging what they see. What we may expect from them is what we will see if we look: devastation of the land and impoverishment of the people. And so let us ask: What might we expect of people who have consciousness and critical judgment, which is to say real presence of mind?

We might expect, first of all, that such people would take good care of what they have. They would know that the most precious things they have are the things they have been given: air, water, land, fertile soil, the plants and animals, one another -- in short, the means of life, health and joy. They would realize the value of those gifts. They would know better than to squander or destroy them for any monetary profit, however great.

Coal is undoubtedly something of value. And it is, at present, something we need -- though we must hope we will not always need it, for we will not always have it. But coal, like the other fossil fuels, is a peculiar commodity. It is valuable to us only if we burn it. Once burned, it is no longer a commodity but only a problem, a source of energy that has become a source of pollution. And the source of the coal itself is not renewable. When the coal is gone, it will be gone forever, and the coal economy will be gone with it.

The natural resources of permanent value to the so-called coalfields of Eastern Kentucky are the topsoils and the forests and the streams. These are valuable, not, like coal, on the condition of their destruction, but on the opposite condition: that they should be properly cared for. And so we need, right now, to start thinking better than we ever have before about topsoils and forests and streams. We must thing about all three at once, for it is a violation of their nature to think about any one of them alone.

The mixed mesophytic forest of the Cumberland Plateau was a great wonder and a great wealth before it was almost entirely cut down in the first half of the last century. Its regrowth could become a great wonder and a great wealth again; it could become the basis of a great regional economy -- but only if it is properly cared for. Knowing that the native forest is the one permanent and abundant economic resource of the region ought to force us to see the need for proper care, and the realization of that need ought to force us to see the difference between a forest ecosystem and a coal mine. Proper care can begin only with the knowledge of that difference. A forest ecosystem, respected and preserved as such, can be used generation after generation without diminishment -- or it can be regarded merely as an economic bonanza, cut down, and used up. The difference is a little like that between using a milk cow, and her daughter and granddaughters after her, for a daily supply of milk, renewable every year -- or killing her for one year's supply of beef.

And there is yet a further difference, one that is even more important, and that is the difference in comprehensibility. A coal mine, like any other industrial-technological system, is a human product, and therefore entirely comprehensible by humans. But a forest ecosystem is a creature, not a product. It is, as part of its definition, a community of living plants and animals whose relationships with one another and with their place and climate are only partly comprehensible by humans, and, in spite of much ongoing research, they are likely to remain so. A forest ecosystem, then, is a human property only within very narrow limits, for it belongs also to the mystery that everywhere surrounds us. It comes from that mystery; we did not make it. And so proper care has to do, inescapably, with a proper humility.

But that only begins our accounting of what we are permitting the coal companies to destroy, for the forest is not a forest in and of itself. It is a forest, it can be a forest, only because it comes from, stands upon, shelters and slowly builds fertile soil. A fertile soil is not, as some people apparently suppose, an aggregate of inert materials, but it is a community of living creatures vastly more complex than that of the forest above it. In attempting to talk about the value of fertile soil, we are again dealing immediately with the unknown. Partly, as with the complexity and integrity of a forest ecosystem, this is the unknown of mystery. But partly, also, it is an unknown attributable to human indifference, for "the money and vision expended on probing the secrets of Mars... vastly exceed what has been spent exploring the earth beneath our feet." I am quoting from Yvonne Baskin's sorely needed new book, Under Ground, which is a survey of the progress so far of "soil science," which is still in its infancy. I can think of no better way to give a sense of what a fertile soil is, what it does, and what it is worth than to continue to quote from Ms. Baskin's book:

A spade of rich garden soil may harbor more species than the entire Amazon nurtures above ground... the bacteria in an acre of soil can outweigh a cow or two grazing above them.

Together [the tiny creatures living underground] form the foundation for the earth's food webs, break down organic matter, store and recycle nutrients vital to plant growth, generate soil, renew soil fertility, filter and purify water, degrade and detoxify pollutants, control plant pests and pathogens, yield up our most important antibiotics, and help determine the fate of carbon and greenhouse gases and thus, the state of the earth's atmosphere and climate.

By some estimates, more than 40 percent of the earth's plant-covered lands... have been degraded over the past half-century by direct human uses.

The process of soil formation is so slow relative to the human lifespan that it seems unrealistic to consider soil a renewable resource. By one estimate it takes 200 to 1,000 years to regenerate an inch of lost topsoil.

And so on any still-intact slope of Eastern Kentucky, we have two intricately living and interdependent natural communities: that of the forest and that of the topsoil beneath the forest. Between them, moreover, the forest and the soil are carrying on a transaction with water that, in its way, also is intricate and wonderful. The two communities, of course, cannot live without rain, but the rain does not fall upon the forest as upon a pavement; it does not just splatter down. Its fall is slowed and gentled by the canopy of the forest, which thus protects the soil. The soil, in turn, acts as a sponge that absorbs the water, stores it, releases it slowly, and in the process filters and purifies it. The streams of the watershed -- if the human dwellers downstream meet their responsibility -- thus receive a flow of water that is continuous and clean.

Thus, and not until now, it is possible to say that the people of the watersheds may themselves be a permanent economic resource, but only and precisely to the extent that they take good care of what they have. If Kentuckians, upstream and down, ever fulfill their responsibilities to the precious things they have been given -- the forests, the soils, and the streams -- they will do so because they will have accepted a truth that they are going to find hard: the forests, the soils and the streams are worth far more than the coal for which they are now being destroyed.

Before hearing the inevitable objections to that statement, I would remind the objectors that we are not talking here about the preservation of the "American way of life." We are talking about the preservation of life itself. And in this conversation, people of sense do not put secondary things ahead of primary things. That precious creatures (or resources, if you insist) that are infinitely renewable can be destroyed for the sake of a resource that to be used must be forever destroyed, is not just a freak of short-term accounting and t he externalization of cost -- it is an inversion of our sense of what is good. It is madness.

And so I return to my opening theme: it is not a vision of the future that we need. We need consciousness, judgment, presence of mind. If we truly know what we have, we will change what we do.

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Reprinted with permission from Missing Mountains: We went to the mountaintop but it wasn't there: Kentuckians write against mountaintop removal (Nicholasville, KY: Wind Publications, 2005).

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AUTISM RISK LINKED TO DISTANCE FROM POWER PLANTS

How do mercury emissions affect pregnant mothers, the unborn and toddlers? Do the level of emissions impact autism rates? Does it matter whether a mercury-emitting source is 10 miles away from families versus 20 miles? Is the risk of autism greater for children who live closer to the pollution source?

A newly published study of Texas school district data and industrial mercury-release data, conducted by researchers at The University of Texas Health Science Center at San Antonio, indeed shows a statistically significant link between pounds of industrial release of mercury and increased autism rates. It also shows -- for the first time in scientific literature -- a statistically significant association between autism risk and distance from the mercury source.

"This is not a definitive study, but just one more that furthers the association between environmental mercury and autism," said lead author Raymond F. Palmer, Ph.D., associate professor of family and community medicine at the UT Health Science Center San Antonio. The article is in the journal Health & Place.

Dr. Palmer, Stephen Blanchard, Ph.D., of Our Lady of the Lake University in San Antonio and Robert Wood of the UT Health Science Center found that community autism prevalence is reduced by 1 percent to 2 percent with each 10 miles of distance from the pollution source.

"This study was not designed to understand which individuals in the population are at risk due to mercury exposure," Dr. Palmer said. "However, it does suggest generally that there is greater autism risk closer to the polluting source."

The study should encourage further investigations designed to determine the multiple routes of mercury exposure. "The effects of persistent, low-dose exposure to mercury pollution, in addition to fish consumption, deserve attention," Dr. Palmer said. "Ultimately, we will want to know who in the general population is at greatest risk based on genetic susceptibilities such as subtle deficits in the ability to detoxify heavy metals."

The new study findings are consistent with a host of other studies that confirm higher amounts of mercury in plants, animals and humans the closer they are to the pollution source. The price on children may be the highest.

"We suspect low-dose exposures to various environmental toxicants, including mercury, that occur during critical windows of neural development among genetically susceptible children may increase the risk for developmental disorders such as autism," the authors wrote.

Study highlights

** Mercury-release data examined were from 39 coal-fired power plants and 56 industrial facilities in Texas.

** Autism rates examined were from 1,040 Texas school districts.

** For every 1,000 pounds of mercury released by all industrial sources in Texas into the environment in 1998, there was a corresponding 2.6 percent increase in autism rates in the Texas school districts in 2002.

** For every 1,000 pounds of mercury released by Texas power plants in 1998, there was a corresponding 3.7 percent increase in autism rates in Texas school districts in 2002.

** Autism prevalence diminished 1 percent to 2 percent for every 10 miles from the source.

** Mercury exposure through fish consumption is well documented, but very little is known about exposure routes through air and ground water. There is evidence that children and other developing organisms are more susceptible to neurobiological effects of mercury.

Implications

"We need to be concerned about global mercury emissions since a substantial proportion of mercury releases are spread around the world by long-range air and ocean currents," Dr. Palmer said. "Steps for controlling and eliminating mercury pollution on a worldwide basis may be advantageous. This entails greener, non-mercury-polluting technologies."

The U.S. Environmental Protection Agency (EPA) estimated environmental mercury releases at 158 million tons annually nationwide in the late 1990s, the time period studied by the Texas team. Most exposures were said to come from coal-fired utility plants (33 percent of exposures), municipal/medical waste incinerators (29 percent) and commercial/industrial boilers (18 percent). Cement plants also release mercury.

With the enactment of clean air legislation and other measures, mercury deposition into the environment is decreasing slightly.

Limitations

Dr. Palmer and his colleagues pointed out the study did not reflect the true community prevalence rates of autism because children younger than school age are not counted in the Texas Education Agency data system. The 1:500 autism rates in the study are lower than the 1:150 autism rates in recent reports of the U.S. Centers for Disease Control and Prevention.

Furthermore, the authors note that distance was not calculated from individual homes to the pollution source but from central points in school districts that varied widely in area.

Data sources

Data for environmentally released mercury were from the United States Environmental Protection Agency Toxics Release Inventory. Data for releases by coal-fired power plants came from the same inventory and from the Texas Commission for Environmental Quality. Data for school district autism came from the Texas Education Agency.

Journal reference: Palmer, R.F., et al., Proximity to point sources of environmental mercury release as a predictor of autism prevalence. Health & Place (2008), doi:10.1016/j.healthplace.2008.02.001.

REASONABLE DOUBT

By Ian Fairlie

Among the many environmental concerns surrounding nuclear power plants, there is one that provokes public anxiety like no other: the fear that children living near nuclear facilities face an increased risk of cancer. Though a link has long been suspected, it has never been proven. Now that seems likely to change.

Studies in the 1980s revealed increased incidences of childhood leukaemia near nuclear installations at Windscale (now Sellafield), Burghfield and Dounreay in the UK. Later studies near German nuclear facilities found a similar effect. The official response was that the radiation doses from the nearby plants were too low to explain the increased leukaemia. The Committee on Medical Aspects of Radiation in the Environment, which is responsible for advising the UK government, finally concluded that the explanation remained unknown but was not likely to be radiation.

There the issue rested, until a recent flurry of epidemiological studies appeared. Last year, researchers at the Medical University of South Carolina in Charleston carried out a meta-analysis of 17 research papers covering 136 nuclear sites in the UK, Canada, France, the US, Germany, Japan and Spain. The incidence of leukaemia in children under 9 living close to the sites showed an increase of 14 to 21 per cent, while death rates from the disease were raised by 5 to 24 per cent, depending on their proximity to the nuclear facilities (European Journal of Cancer Care, vol 16, p 355).

This was followed by a German study which found 14 cases of leukaemia compared to an expected four cases between 1990 and 2005 in children living within 5 kilometres of the Krummel nuclear plant near Hamburg, making it the largest leukaemia cluster near a nuclear power plant anywhere in the world (Environmental Health Perspectives, vol 115, p 941).

This was upstaged by the yet more surprising KiKK studies (a German acronym for Childhood Cancer in the Vicinity of Nuclear Power Plants), whose results were published this year in the International Journal of Cancer (vol 122, p 721) and the European Journal of Cancer (vol 44, p 275). These found higher incidences of cancers and a stronger association with nuclear installations than all previous reports. The main findings were a 60 per cent increase in solid cancers and a 117 per cent increase in leukaemia among young children living near all 16 large German nuclear facilities between 1980 and 2003. The most striking finding was that those who developed cancer lived closer to nuclear power plants than randomly selected controls. Children living within 5 kilometres of the plants were more than twice as likely to contract cancer as those living further away, a finding that has been accepted by the German government.

Though the KiKK studies received scant attention elsewhere, there was a public outcry and vocal media debate in Germany. No one is sure of the cause (or causes) of the extra cancers. Coincidence has been ruled out, as has the "Kinlen hypothesis", which theorises that childhood leukaemia is caused by an unknown infectious agent introduced as a result of an influx of new people to the area concerned. Surprisingly, the most obvious explanation for this increased risk -- radioactive discharges from the nearby nuclear installations -- was also ruled out by the KiKK researchers, who asserted that the radiation doses from such sources were too low, although the evidence they base this on is not clear.

Anyone who followed the argument in the 1980s and 1990s concerning the UK leukaemia clusters will have a sense of deja vu. A report in 2004 by the Committee Examining Radiation Risks of Internal Emitters (2 Mbyte PDF), set up by the UK government (and for which I was a member of the secretariat) points out that the models used to estimate radiation doses from sources emitted from nuclear facilities are riddled with uncertainty. For example, assumptions about how radioactive material is transported through the environment or taken up and retained by local residents may be faulty.

If radiation is indeed the cause of the cancers, how might local residents have been exposed? Most of the reactors in the KiKK study were pressurised water designs notable for their high emissions of tritium, the radioactive isotope of hydrogen. Last year, the UK government published a report on tritium which concluded that its hazard risk should be doubled. Tritium is most commonly found incorporated into water molecules, a factor not fully taken into account in the report, so this could make it even more hazardous.

As we begin to pin down the likely causes, the new evidence of an association between increased cancers and proximity to nuclear facilities raises difficult questions. Should pregnant women and young children be advised to move away from them? Should local residents eat vegetables from their gardens? And, crucially, shouldn't those governments around the world who are planning to build more reactors think again?

Ian Fairlie is a London-based consultant on radiation in the environment

HAIR DYES FOUND TO INCREASE CANCER RISK

By Jeremy Laurance, Health Editor

Hairdressers and barbers are at increased risk of developing cancer - because of their use of hair dyes. And the risks could extend to personal use of the dyes, according to international experts.

A review of the evidence by a panel of the International Agency for Research on Cancer (IARC) in Lyon, France, has found a "small but consistent risk of bladder cancer in male hairdressers and barbers".

A second review of the evidence on personal use of hair dyes found some studies suggesting a possible association with bladder cancer and with lymphoma and leukaemia.

But the panel found that the evidence was inadequate and concluded that personal use of hair dyes was "not classifiable as to its carcinogenicity to humans".

The panel was composed of 17 scientists who met last February to consider the latest evidence and update advice last issued by the agency in 1993.

Modern hair dyes are classified as permanent, semi permanent or temporary dyes. The permanent or oxidative hair dyes represent 80 per cent of the market and consist of colourless "intermediates" and couplers that, in the presence of peroxide, form the dyes by chemical reaction.

Dark hair dyes tend to contain the highest concentration of the colouring ingredients. The use of some such colourants was discontinued in the 1970s after positive cancer tests in rats.

Dr Robert Baan of the IARC and colleagues say in The Lancet Oncology: "A small but consistent risk of bladder cancer was reported in male hairdressers and barbers. Because of few supporting findings by duration or period of exposure, the working group considered these data as limited evidence of carcinogenicity and reaffirmed occupational exposures of haridressers and barbers as 'probably carcinogenic to humans'."

Copyright independent.co.uk

THE LINK BETWEEN TOXIC CHEMICALS AND GLOBAL WARMING

By Peter Montague

As never before, opportunity is knocking for activists. The solutions to global warming and chemical contamination are both peeking over the horizon and they look very much alike. The timing is perfect for building a global coalition to promote waste-free green chemistry (or clean production), end the rush toward coal-burning power plants, stuff the nuclear genie back into the bottle, power the future with sustainable solar energy, and advance environmental justice worldwide. From all this can flow many millions of truly green jobs.

Global warming and chemical contamination are two sides of the same coin, and solutions to both are now converging. Activists fighting coal, fighting nuclear, fighting dangerous waste technologies (landfills, incinerators and incinerators-in-disguise), fighting for the cleanup of superfund sites and brownfields and toxic emissions, fighting all the chemicals-and-health fights (childhood cancers, autism, diabetes, asthma, Parkinson's and so many other environment- linked diseases), and fighting for justice, joined with activists promoting solar, wind and biofuels, promoting tidal power and geothermal, promoting green jobs, clean production and green chemistry -- could now work together toward a common purpose. The combination would create a mountain of political power.

To curb global warming, we can transition as rapidly as possible to renewable solar, geothermal and tidal power, and to end chemical contamination we can transition as rapidly as possible to green chemistry. But to do either of these things, we first must get around one huge obstacle: the coal industry. I know that some influential people are saying that fossil fuels are over, that oil has peaked and coal is dead, but there's more to it than that.

Yes, perhaps oil has reached -- or soon will -- peak production and will be declining in volume each year, which foretells steadily rising prices (as we have seen -- a 10-fold increase since 2000). But coal is not dead. Coal executives are planning to turn coal into liquid fuels and into chemical feedstocks to replace oil. If they succeed, they will entrench coal for the next 100 years, derailing the drive toward green chemistry and clean production, and eliminating the incentives for renewable energy. This is a strategic fork in the road to the future. Which will we choose? This is a moment in history when activism can make a crucial difference.

There is still a huge (though surprisingly uncertain) amount of coal in the ground, especially in the U.S., and we would be naive to think that the people who own that coal are going walk away from it emptyhanded. Until it is all used up, they plan to (a) burn it for electricity, (b) turn it into liquid fuels (diesel, kerosene and jet fuel), or (c) turn it into chemical feedstocks (to create plastics, pesticides, solvents, etc.)-- or they will sell it to China, which will then burn it, liquify it, or turn it into chemicals. Peabody Energy of St. Louis, the largest private coal company in the world, opened an office in Beijing in 2005 because Chinese coal mines cannot keep up with demand, and U.S. coal exports are now helping fill that gap.

With coal-fired electric power now being fought to a standstill by a swarm of grass-roots activists all across the U.S., coal-to-liquids (CTL) and coal-to-chemicals are the most promising paths to salvation for the coal industry. Private chemical companies can build coal-to- chemical plants on their existing premises without getting any special licenses of the kind required for electric utilities. Eastman Chemical (formerly a part of Eastman Kodak) already derives 20% of its chemical feedstocks from coal and is thinking about pushing that up to 40%.[1] General Electric -- which sells coal gasification equipment needed for both coal-to-liquids and coal-to-chemicals -- wants to sell coal gasifiers to electric utilities, "But in the near term, turning coal to chemicals offers the most significant opportunities," says Edward C. Lowe, general manager of gasification for GE Energy.

Coal-to-liquids and coal-to-chemicals both use heat and pressure to break the molecular bonds in coal, producing gases (mostly carbon monoxide and hydrogen), which can be recombined to make various fuels and chemical feedstocks for paints, food additives, fertilizers, plastics, and all manner of other modern molecules. Germany commercialized these chemical processes before World War II, but after the war cheap oil shoved coal-gas technology to the back burner. Now oil is growing expensive and the chemical industry is paying roughly $40 billion per year for petroleum-based feedstocks, so that's a huge new market for Big Coal to penetrate. If they succeed, they're saved, if not, they're sunk. Their back is to the wall.

Coal-to-chemicals plants will try to bury their waste carbon dioxide (CO2) in the ground, just the way coal-fire power plants say they want to do -- so coal-to-chemicals and coal-to-liquid-fuels could provide a laboratory for the untried "carbon capture and storage (CCS)" technologies needed to create so-called "clean coal." If they can convince people that CCS works -- and will keep working safely for thousands of years into the future -- they're saved; if not, they're sunk. Current U.S. energy policy is providing large taxpayer subsidies to coal-with-CCS, starving the research budget for renewable energy.

The Wall Street Journal reported late last year that western chemical companies are now flocking to China to participate in coal- to- chemicals projects, some of which have an experimental carbon burial (CCS) component. Because of cheap labor and lax regulations, such plants cost 30% to 50% less to build in China than in the U.S. Several Chinese companies already use coal to manufacture vinyl chloride monomer, the building block of PVC ("vinyl") plastic, and American and European chemical firms want some of that action. "No one's made any real commitments yet, says the editor of Chemical Week magazine, "but it's clear that this is the beginning of a wave." (Get more data about coal gasification in China and worldwide from these slides.)

Coal-to-liquids and coal-to-chemicals will not develop in the U.S. without a knock-down fight. This is where a big coalition of toxics, environmental health, energy, and green jobs and environmental justice activists could weigh in: Stopping coal-to-chemicals is essential to create space for the emergence of clean production, green chemistry, renewable energy and green jobs with justice. We are not going to have a coal-based chemical industry and a green chemical industry. We'll have one or the other, not both. And the same is true for electric power: if the public can be convinced that "clean coal" is really clean and really safe, incentives for renewables will dry up. We'll have coal or renewables, not both.

Here's the thing. The Achilles' heel of the coal-to-chemicals industry, the coal-to-liquid-fuels industry, and the coal-fired electric power industry is carbon dioxide. Compared to petroleum-based fuels, coal-based fuels produce twice as much CO2 per gallon. With Wall Street already looking askance at all coal-based technologies because of the near-certainty that carbon emissions will face expensive regulation one of these days, plans to bury CO2 in the ground take on new urgency for the coal corporations. With it, they may have a future; without it, they're sunk. To stop coal, activists just have to frighten the money.

Rarely in history have activists on such a a broad range of issues been offered such a clear strategic opportunity to work together to kill a deadly, wasteful dinosaur like the coal-to-liquids, coal-to- chemicals and coal-to-electricity industries, simultaneously opening up a future of green possibilities for ourselves, for the world, and for our children.

MILLIONS OF 2-YEAR OLDS EXPOSED TO DANGEROUS LEVELS OF ROCKET FUEL

WASHINGTON -- A recent study by the US Food and Drug Administration (FDA) found that three quarters of 285 commonly consumed foods and beverages are contaminated with perchlorate, a toxic rocket fuel ingredient. According to the study, every day, the average two-year- old is exposed to more than half of the EPA 'safe' dose (RfD) of perchlorate from food alone. This is bad news for children in communities in 28 states who also are exposed to perchlorate through contaminated tap water. Very low levels of perchlorate in tap water will cause the average two year old to exceed EPA's safe exposure level.

Two-year-olds are particularly vulnerable because they eat and drink substantial amounts of food and water relative to their small size. An Environmental Working Group analysis of FDA data found that perchlorate levels as low as 4 parts per billion (ppb) in tap water could expose the average two-year-old to an unsafe dose of the rocket fuel contaminant every single day.

FDA's finding of high food exposures for small children makes clean up of perchlorate-contaminated water imperative. Perchlorate in tap water can be controlled through filtration and clean up. Perchlorate in food is harder to manage because the source of contamination is not clear, although contaminated irrigation water is one known source where levels could be reduced.

'Every final or proposed water standard for perchlorate fails to provide adequate protection for children,' said Dr. Anila Jacob, MD, a senior scientist at EWG. 'An average two-year-old drinking water with 4 ppb perchlorate will exceed the EPA's safe dose. New Jersey has set a standard at 5 ppb, California is at 6 ppb, and the EPA has issued a clean up standard of 24 ppb, nowhere near a level protective of children.'

Not only do children have higher exposures to perchlorate when compared with adults, they are also particularly susceptible to its adverse effects. Perchlorate acts by inhibiting the thyroid gland from taking up iodine from the circulation. Since iodine is the building block for thyroid hormone, perchlorate exposure can result in decreased thyroid hormone production by the thyroid gland. Adequate circulating levels of thyroid hormones are critical to maintaining normal growth and brain development during childhood.

'Pervasive perchlorate contamination of food underscores the need for a tough national drinking water standard to protect children. We need to take every action we can to minimize perchlorate exposures, and tough tap water standards are the logical first step. If we fail to act, we will needlessly expose millions of children to dangerous levels of this potent toxic compound,' said Dr. Anila Jacob, MD -- a Senior Scientist with EWG.

A recent report from the US Government Accountability Office finds that 28 states have communities in which perchlorate contaminates drinking water supplies at levels of 4 ppb or higher.

EWG is a nonprofit research organization based in Washington, DC that uses the power of information to protect human health and the environment. The group's analysis of the FDA study is available online at http://www.ewg.org/node/25875

WHY IS UNCLE SAM SO COMMITTED TO REVIVING NUCLEAR POWER?

By Peter Montague

The long-awaited and much-advertised "nuclear renaissance" actually got under way this week. NRG Energy, a New Jersey company recently emerged from bankruptcy, applied for a license to build two new nuclear power plants at an existing facility in Bay City, Texas -- the first formal application for such a license in 30 years.

NRG Energy has no experience building nuclear power plants but they are confident the U.S. government will assure their success. "The whole reason we started down this path was the benefits written into the [Energy Policy Act] of 2005," NRG's chief executive, David Crame, told the Washington Post. In other words, the whole reason NRG Energy wants to build nuclear power plants is to get bundles of free money from Uncle Sam. Who could blame them?

Other energy corporations are nuzzling up to the same trough. The federal Nuclear Regulatory Commission (NRC) is expecting to receive applications for an additional 29 nuclear power reactors at 20 sites. The NRC has already hired more than 400 new staff to deal with the expected flood of applications.

But the question remains, Can investors be fooled twice? Financially, the nuclear power industry has never stood on its own two feet without a crutch from Uncle Sam. Indeed, the nuclear power industry is entirely a creature of the federal government; it was created out of whole cloth by the feds in the 1950s. At that time, investors were enticed by offers of free money -- multi-billion-dollar subsidies, rapid write-offs, special limits on liability, and federal loan guarantees. Despite all this special help, by the 1970s the industry was in a shambles. The British magazine, the Economist, recently described it this way: "Billions were spent bailing out lossmaking nuclear-power companies. The industry became a byword for mendacity, secrecy and profligacy with taxpayers' money. For two decades neither governments nor bankers wanted to touch it."

Now the U.S. federal government is once again doing everything in its power to entice investors, trying to revive atomic power.

First, Uncle Sam is trying hard to remove the financial risk for investors. The Energy Policy Act, which Congress approved in 2005, provides four different kinds of subsidies for atomic power plants:

1. It grants $2 billion in insurance against regulatory delays and lawsuits to the first six reactors that get licenses and begin construction. Energy corporations borrow money to build plants and they must start paying interest on those loans immediately, even though it take years for a plant to start generating income. The longer the licensing and construction delays, the greater the losses. Historically, lawsuits or other interventions by citizens have extended the licensing timeline, sometimes by years, costing energy corporations large sums. Now Uncle Sam will provide free insurance against any such losses.

2. Second, the 2005 law extends the older Price-Anderson Act, which limits a utility's liability to $10 billion in the event of a nuclear accident. A serious accident at a nuclear plant near a major city could create hundreds of billions of dollars in liabilities. Uncle Sam has agreed to relieve investors of that very real fear.

3. The 2005 law provides a tax credit of 1.8 cents per kilowatt-hour for the first 6,000 megawatts generated by new plants. Free money, plain and simple.

4. Most important, the law offers guarantees loans to fund new atomic power reactors and other power plants using "innovative" technology. Investors need no longer fear bad loans.

One obvious conclusion from all this is that, more than 50 years into the nuclear enterprise, atomic power still cannot attract investors and compete successfully in a "free market." This industry still requires an unprecedented level of subsidy and other government support just to survive.

An energy corporation's motives for buying into this system are clear: enormous subsidies improve the chance of substantial gain. However, the federal government's reasons for wanting to revive a moribund nuclear industry are not so clear. If the "free market" won't support the revival of nuclear power, why would the federal government want to pay billions upon billions of dollars to allay investor fears?

It certainly has little to do with global warming. At the time the 2005 energy bill was passed by a Republic-dominated Congress the official position of the Republican leadership was that global warming was a hoax. Even now when some Republicans have begun to acknowledge that perhaps we may have a carbon dioxide problem, science tells us that nuclear power plants are not the best way to reduce our carbon dioxide emissions. They're not even close to being the best way. (Lazy journalists are in the habit it repeating the industry mantra that nuclear power produces no greenhouse gases. This is nonsense. Read on.)

Substantial carbon dioxide emissions accompany every stage of nuclear power production, from the manufacture and eventual dismantling of nuclear plants, to the mining, processing, transport, and enrichment of uranium fuel, plus the eventual processing, transport, and burial of nuclear wastes.

A careful life-cycle analysis by the Institute for Applied Ecology in Darmstadt, Germany, concludes that a 1250 megaWatt nuclear power plant, operating 6500 hours per year in Germany, produces greenhouse gases equivalent to 250,000 metric tonnes of carbon dioxide per year. In other (unspecified) countries besides Germany, the same power plant could produce as much as 750,000 metric tonnes of carbon dioxide equivalents, the Institute study shows. (See Figure 3, pg. 5)

The study concludes that, in the emission of global warming gases (measured per kilowatt-hour of electricity made available), nuclear power compares unfavorably to...

** conservation through efficiency improvements

** run-of-river hydro plants (which use river water power but require no dams)

** offshore wind generators

** onshore wind generators

** power plants run by gas-fired internal combustion engines, especially plants that use both the electricity and the heat generated by the engine

** power plants run by bio-fuel-powered internal combustion engines

Of eleven ways to generate electricity (or avoid the need to generate electricity through efficiency and conservation) analyzed by the Institute, four are worse than nuclear from the viewpoint of greenhouse gas emissions, and six are better.

[For a great deal of additional solid information showing that nuclear power is no answer to global warming, check in with the Nuclear Information and Resource Service (NIRS)].

A study completed this summer by the Institute for Energy and Environmental Research (IEER) in Takoma Park, Maryland concluded that it is feasible, within 35 to 60 years, to evolve an energy system to power the U.S. economy without the use of any nuclear power plants or any coal plants. See the IEER study, Carbon-Free and Nuclear-Free; A Roadmap for U.S. Energy Policy.

So the rationale for the U.S. government's Herculean efforts to revive a decrepit nuclear power industry cannot be based on concern for global warming or energy independence. The facts simply don't support such a rationale.

Whatever its motivation, the U.S. federal government is doing everything in its power to revive atomic power. In addition to removing most of the financial risk for investors, Uncle Sam has removed other obstacles like democratic participation in siting and licensing decisions.

Throughout the 1970s, energy corporations complained that getting a license took too long. In response, the Nuclear Regulatory Commission (NRC) has spent more than a decade "streamlining" the process for building nuclear plants. Most of the "streamlining" consists of new ways to exclude the public from information and decisions. For example, members of the public used to be able to question witnesses during licensing hearings. No more. There used to be two sets of hearings -- one for siting the plant, and another for constructing the plant. No more. These two set of issues have been rolled into a single license and a single hearing. The purpose is to accommodate the needs of the nuclear industry, to help it survive. As attorney Tony Roisman observed recently, "The nuclear industry has come to the agency [the NRC] and said, 'If you don't make it easy for us to get a license, we are not going to apply for one.'" So the agency is making it easy.

Perhaps it is natural for NRC commissioners to justify a strong bias in favor of keeping the nuclear industry alive even if safety and democracy have to be compromised. After all, if there were no corporations willing to build new nuclear power plants, soon there would be no need for a Nuclear Regulatory Commission. So NRC commissioners know in their bones that their first priority must be to keep the nuclear industry alive. Every bureaucracy's first priority is self-perpetuation. Furthermore, historically a position as an NRC commissioner can lead directly to a high-paying job, often in the nuclear industry itself.

To grease the skids for a nuclear revival, the most important change the NRC has made has been to creatively redefine the meaning of the word "construction." This change was enacted in April, 2007, with lightning speed -- six months from initial proposal to final adoption.

By way of comparison, it took the NRC eleven years to adopt regulations requiring drug testing for nuclear plant operators.

"Construction" has traditionally included all the activities undertaken to build a nuclear power plant, starting with site selection, evaluation, testing and preparation, construction of peripheral facilities like cooling towers, and so on. Even the earliest stages of siting are crucially important with a facility as complex and dangerous as a nuclear power plant.

In April of this year, the NRC officially redefined "construction" to include only construction of the reactor itself -- excluding site selection, evaluation, testing and preparation, construction of peripheral facilities and all the rest. At the time, one senior environmental manager inside NRC complained in an email that NRC's redefinition of "construction" would exclude from NRC regulation "probably 90 percent of the true environmental impacts of construction." Under the new rules, by the time the NRC gets involved, a company will have invested perhaps a hundred million dollars. Will NRC commissioners have the backbone to toss that investment into the toilet if they eventually find something wrong with the site? Or will they roll over for the industry and compromise safety?

The lawyer who dreamed up the redefinition of "construction" is James Curtiss, himself a former NRC commissioner who now sits on the board of directors of the nuclear power giant, Constellation Energy Group. This revolving door pathway from NRC to industry is well-worn.

One NRC commissioner who voted in April to change the definition of construction is Jeffrey Merrifield. Before he left the NRC in July, Mr. Merrifield's last assignment as an NRC commissioner was to chair an agency task force on ways to accelerate licensing.

In April, while he was urging his colleagues at NRC to redefine "construction," Mr. Merrifield was actively seeking a top management position within the nuclear industry. In July he became senior vice president for Shaw Group, a nuclear builder that has worked on 95% of all existing U.S. nuclear plants. Mr. Merrifield's salary at NRC was $154,600. Bloomberg reports that, "In Shaw Group's industry peer group, $705,409 is the median compensation for a senior vice president."

No one in government or the industry seems the least bit embarrassed by any of this. It's just the way it is. Indeed, Mr. Merrifield points out that, while he was an NRC commissioner providing very substantial benefits to the nuclear industry by his decisions, his concurrent search for a job within the regulated industry was approved by the NRC's Office of General Counsel and its Inspector General. From this, one might conclude that Mr. Merrifield played by all the rules and did nothing wrong. Or one might conclude that venality and corruption reach into the highest levels of the NRC. Or one might conclude that after NRC commissioners have completed their assignment inside government, everyone in the agency just naturally feels they are entitled to a lifetime of lavish reward from the industry on whose behalf they have labored so diligently.

As recently as this summer, Uncle Sam was still devising new ways to revive nuclear power. In July the U.S. Senate allowed the nuclear industry to add a one-sentence provision to the energy bill, which the Senate then passed. The one sentence greatly expanded the loan guarantee provisions of the Energy Policy Act of 2005. The 2005 Act had specified that Uncle Sam could guarantee loans for new nuclear power plants up to a limit set each year by Congress. In 2007 the limit was set at a paltry $4 billion. The one-sentence revision adopted by the Senate removed all limits on loan guarantees. The nuclear industry says it needs at least $50 billion in the next two years. Michael J. Wallace, the co-chief executive of UniStar Nuclear, a partnership seeking to build nuclear reactors, and executive vice president of Constellation Energy, said: "Without loan guarantees we will not build nuclear power plants."

The Senate and the House of Representatives are presently arm- wrestling over the proposed expansion of loan guarantees. In June, the White House budget office said that the Senate's proposed changes to the loan-guarantee program could "significantly increase potential taxpayer liability" and "eliminate any incentive for due diligence by private lenders." On Wall Street this is known as a "moral hazard" -- conditions under which waste, fraud and abuse can flourish.

All these subsidies to revive a dead duck run directly counter to free market ideals and capitalism's credo of unfettered competition. So the intriguing question remains, Why? Why wouldn't the nation go whole-hog for alternative energy sources and avoid all the problems that accompany nuclear power -- routine radioactive releases, the constant fear of a serious accidents, the unsolved problem of radioactive waste that must be stored somewhere reliably for a million years, and -- the greatest danger of all -- the inevitable reality that anyone who can build a nuclear power plant can build an atomic bomb if they set their minds to it. The recent experience of Israel, India, North Korea and Pakistan in this regard is completely convincing and undeniable.

So why is Uncle Sam hell-bent on reviving nuclear power? I don't have a firm answer and can only speculate. Perhaps from the viewpoint of both Washington and Wall Street, nuclear power is preferable to renewable-energy alternatives because it is extremely capital-intensive and the people who provide the capital get to control the machine and the energy it provides. It provide a rationale for a large centralized bureaucracy and tight military and police security to thwart terrorists. This kind of central control can act as a powerful counterweight to excessive democratic tendencies in any country that buys into nuclear power. Particularly if they sign a contract with the U.S. or one of its close allies for delivery of fuel and removal of radioactive wastes, political control becomes a powerful (though unstated) part of the bargain. If you are dependent on nuclear power for electricity and you are dependent on us for reactor fuel, you are in our pocket. On the other hand, solar, wind and other renewable energy alternatives lend themselves to small- scale, independent installations under the control of local communities or even households. Who knows where that could lead?

Then I think of the present situation in the Middle East. Saddam Hussein started down the road to nuclear power until the Israelis bombed to smithereens the Osirak nuclear plant he was building in 1981. That ended his dalliance with nuclear power and nuclear weapons -- but that didn't stop Don Rumsfeld and Dick Cheney from using Saddam's nuclear history as an excuse to invade his country and string him up.

And now something similar is unfolding in Iran. Iran wants nuclear power plants partly to show how sophisticated and capable it has become, and partly to thumb its nose at the likes of Don Rumsfeld and Dick Cheney -- and perhaps to try to draw us into another war that would indelibly mark us for the next hundred years as enemies of Islam, serving to further unite much of the Arab world against us.

Is this kind of thinking totally nuts? I don't think so. Newsweek reported in its October 1, 2007 issue that Dick Cheney has been mulling a plan to convince the Israeli's to bomb the Iranian nuclear power plant at Natanz, hoping to provoke the Iranians into striking back so that the U.S. would then have an excuse to bomb Iran. I'm not making this up.

So clearly there are more important uses for nuclear power than just making electricity. Arguably, nuclear reactors have become essential tools of U.S. foreign policy -- being offered, withheld, and bargained over. They have a special appeal around the world because they have become double-edged symbols of modernity, like shiny toy guns that can be loaded with real bullets. Because of this special characteristic, they have enormous appeal and can provide enormous bargaining power. Witness North Korea. And, as we have seen, nuclear reactors can provide excuses to invade and bomb when no other excuses exist.

So perhaps Uncle Sam considers it worth investing a few hundred billion dollars of taxpayer funds to keep this all-purpose Swiss army knife of U.S. foreign policy available in our back pocket. In the past five years, we've already devoted $800 billion to splendid little wars in Afghanistan and Iraq, at least partly to secure U.S. oil supplies. Uncle Sam's desperate attempts to revive nuclear power can perhaps best be understood as part of that ongoing effort at oil recovery.

Meanwhile, investors should think twice before buying into the "nuclear renaissance" because there's another "renaissance" under way as well: A powerful anti-nuclear movement is growing again and they will toss your billions into the toilet without hesitation. Indeed, with glee.

EARLY PUBERTY IN GIRLS TROUBLING

The trend raises the risk of breast cancer, emotional problems.

By Dorsey Griffith, Bee Medical Writer

American girls are entering puberty at earlier ages, putting them at far greater risk for breast cancer later in life and for all sorts of social and emotional problems well before they reach adulthood.

Girls as young as 8 increasingly are starting to menstruate, develop breasts and grow pubic and underarm hair -- biological milestones that only decades ago typically occurred at 13 or older. African American girls are especially prone to early puberty.

Theories abound as to what is driving the trend, but the exact cause, or causes, is not known. A new report, commissioned by the San Francisco-based Breast Cancer Fund, has gathered heretofore disparate pieces of evidence to help explain the phenomenon -- and spur efforts to help prevent it.

"This is a review of what we know -- it's absolutely superb," said Dr. Marion Kavanaugh-Lynch, an oncologist and director of the California Breast Cancer Research Program in Oakland, which directs tobacco tax proceeds to research projects. "Having something like this document put together that discusses all the factors that influence puberty will advance the science and allow us to think creatively about new areas of study."

The stakes are high: "The data indicates that if you get your first period before age 12, your risk of breast cancer is 50 percent higher than if you get it at age 16," said the report's author, biologist Sandra Steingraber, herself a cancer survivor. "For every year we could delay a girl's first menstrual period, we could prevent thousands of breast cancers."

Kavanaugh-Lynch said most breast cancer cells thrive on estrogen, and girls who menstruate early are exposed to more estrogen than normally maturing girls.

Steingraber's paper, "The Falling Age of Puberty in U.S. Girls: What We Know, What We Need to Know," examines everything from obesity and inactivity to family stress, sexual imagery in media sources and accidental exposures of girls to chemicals that can change the timing of sexual maturation.

Steingraber concludes that early puberty could best be understood as an "ecological disorder," resulting from a variety of environmental hits.

"The evidence suggests that children's hormonal systems are being altered by various stimuli, and that early puberty is the coincidental, non-adaptive outcome," she writes.

Steingraber's report is being released amid growing national interest in how the environment contributes to disease, particularly cancer.

California is at the forefront of the research movement. Among the ongoing efforts:

** The California Environmental Contaminant Biomonitoring Program, a five-year, state-funded project, will measure chemical exposures in blood and urine samples from more than 2,000 Californians.

** The Bay Area Breast Cancer and the Environment Research Center, a federally funded project run by scientists at Kaiser Permanente and the University of California, San Francisco, is studying predictors of early puberty through monitoring of environmental exposures in more than 400 Bay Area girls over several years.

For years, parents, doctors and teachers have recognized the trend in early puberty among girls, with little information to explain it.

Dr. Charles Wibbelsman, a pediatrician with Kaiser Permanente in San Francisco and a member of the American Academy of Pediatrics committee on adolescents, said he now routinely sees girls as young as 8 with breast development and girls as young as 9 who have started their periods. He said the phenomenon is most striking in African American girls.

"We don't think of third-graders as using tampons or wearing bras," he said. In fact, he said, pediatricians are having to adjust the way they do regular check-ups because the older approaches don't jibe with reality.

Steingraber acknowledges that some of the shift in girls' puberty is evolutionary, a reflection of better infectious disease control and improved nutrition, conditions that allow mammals to reproduce.

But since the mid-20th century, she said, other factors seem to have "hijacked the system" that dictates the onset of puberty.

Rising childhood obesity rates clearly play a role, she said, noting that chubbier girls tend to reach puberty earlier than thinner girls. Levels of leptin, a hormone produced by body fat, is one trigger for puberty, and leptin levels are higher in blacks than in other groups.

But obesity cannot alone be blamed for the shifts, she said. Steingraber's paper explored many other factors that likely play a role, including exposure to common household chemicals. And she cited findings that link early puberty with premature birth and low birth weight, formula feeding of infants and excessive television viewing and media use.

"My job was to put together a huge jigsaw puzzle," she said.

Steingraber also reported associations of early puberty with emotional and social problems. "The world is not a good place for early maturing girls," she said. "They are at higher risk of depression, early alcohol abuse, substance abuse, early first sexual encounter and unintended pregnancies."

The reasons for this may be related to the way these children are treated or because of the way puberty affects a child's judgment, she said.

"It's possible that developing an adult-style brain at age 10 instead of 14 makes you make decisions about your life that are not really in your best interest," she said.

Priya Batra, a women's health psychologist at Kaiser Permanente in Sacramento, said she's seen the effects on girls who "look like sexual beings before they are ready to be sexual beings," and counseled mothers worried about their daughters entering puberty too early.

"It's a stressful culture, and we have a lot of demands on children," she said. "It's hard when we add this other layer of early puberty."

From: New York Times, Sept. 6, 2007

SOME FOOD ADDITIVES RAISE HYPERACTIVITY, STUDY FINDS

By Elisabeth Rosenthal

Common food additives and colorings can increase hyperactive behavior in a broad range of children, a study being released today found.

It was the first time researchers conclusively and scientifically confirmed a link that had long been suspected by many parents. Numerous support groups for attention deficit hyperactivity disorder have for years recommended removing such ingredients from diets, although experts have continued to debate the evidence.

But the new, carefully controlled study shows that some artificial additives increase hyperactivity and decrease attention span in a wide range of children, not just those for whom overactivity has been diagnosed as a learning problem.

The new research, which was financed by Britain's Food Standards Agency and published online by the British medical journal The Lancet, presents regulators with a number of issues: Should foods containing preservatives and artificial colors carry warning labels? Should some additives be prohibited entirely? Should school cafeterias remove foods with additives?

After all, the researchers note that overactivity makes learning more difficult for children.

"A mix of additives commonly found in children's foods increases the mean level of hyperactivity," wrote the researchers, led by Jim Stevenson, a professor of psychology at the University of Southampton. "The finding lends strong support for the case that food additives exacerbate hyperactive behaviors (inattention, impulsivity and overactivity) at least into middle childhood."

Additional background reading:

P. Grandjean and P.J. Landrigan, "Developmental neurotoxicity of industrial chemicals," Environmental Health Perspectives Vol. 368 (December 16, 2006), pgs. 2167-2178.

In response to the study, the Food Standards Agency advised parents to monitor their children's activity and, if they noted a marked change with food containing additives, to adjust their diets accordingly, eliminating artificial colors and preservatives.

But Professor Stevenson said it was premature to go further. "We've set up an issue that needs more exploration," he said in a telephone interview.

In response to the study, some pediatricians cautioned that a diet without artificial colors and preservatives might cause other problems for children.

"Even if it shows some increase in hyperactivity, is it clinically significant and does it impact the child's life?" said Dr. Thomas Spencer, a specialist in Pediatric Psychopharmacology at Massachusetts General Hospital.

"Is it powerful enough that you want to ostracize your kid? It is very socially impacting if children can't eat the things that their friends do."

Still, Dr. Spencer called the advice of the British food agency "sensible," noting that some children may be "supersensitive to additives" just as some people are more sensitive to caffeine.

The Lancet study focused on a variety of food colorings and on sodium benzoate, a common preservative. The researchers note that removing this preservative from food could cause problems in itself by increasing spoilage. In the six-week trial, researchers gave a randomly selected group of several hundred 3-year-olds and of 8- and 9-year-olds drinks with additives -- colors and sodium benzoate -- that mimicked the mix in children's drinks that are commercially available. The dose of additives consumed was equivalent to that in one or two servings of candy a day, the researchers said. Their diet was otherwise controlled to avoid other sources of the additives.

A control group was given an additive-free placebo drink that looked and tasted the same.

All of the children were evaluated for inattention and hyperactivity by parents, teachers (for school-age children) and through a computer test. Neither the researchers nor the subject knew which drink any of the children had consumed.

The researchers discovered that children in both age groups were significantly more hyperactive and that they had shorter attention spans if they had consumed the drink containing the additives. The study did not try to link specific consumption with specific behaviors. The study's authors noted that other research suggested that the hyperactivity could increase in as little as an hour after artificial additives were consumed.

The Lancet study could not determine which of the additives caused the poor performances because all the children received a mix. "This was a very complicated study, and it will take an even more complicated study to figure out which components caused the effect," Professor Stevenson said.

Copyright 2007 The New York Times Company

From: New Scientist (pg. 44), Sept. 1, 2007

TOXIC COCKTAIL

By Bijal Trivedi

Today, and every day, you can expect to be exposed to some 75,000 artificial chemicals. All day long you will be breathing them in, absorbing them through your skin and swallowing them in your food. Throughout the night they will seep out of carpets, pillows and curtains, and drift into your lungs. Living in this chemical soup is an inescapable side effect of 21st-century living. The question is: is it doing us any harm?

There are good reasons to think that it might be. Not because of the action of any one chemical but because of the way the effects of different components combine once they are inside the body. As evidence stacks up that this "cocktail effect" is real, regulators around the world are rethinking the way we measure the effects of synthetic mixtures on health.

Environmentalists have long warned of this danger, but until recently there was no solid evidence to confirm their fears -- nor any to allay them. Most toxicity testing has been done on a chemical-by-chemical basis, often by exposing rats to a range of concentrations to find the maximum dose that causes no harm. It's a long way from gauging the effects of the complex mixtures we experience in everyday life, and that could be a dangerous omission.

"When you get a prescription the doctor will ask what else you are taking, because they are concerned about drug interactions, which everyone knows can be quite devastating," says Shanna Swan, director of the Center for Reproductive Epidemiology at the University of Rochester in New York. This also happens with chemicals like pesticides and endocrine disrupters, she adds. "You have to consider their interactions, and we are just starting to do that."

To assess the risk posed by such mixtures, a small number of scientists in Europe and the US are now testing chemical brews on yeast, fish and rats. The effects could be additive, or they might be synergistic -- that is, greater than the sum of the parts. They could even cancel each other out. Finding out is important, because we don't have enough data on many compounds to anticipate how they will interact when mixed. Other researchers are probing for associations between disease in humans and past exposure to groups of chemicals.

Andreas Kortenkamp, an environmental toxicologist at the School of Pharmacy, University of London, and his colleagues developed an interest in these mixture effects after they noticed a rise in endocrine disorders, suggesting that the body's hormonal systems may have been disrupted. In men there were increases in congenital malformations like hypospadia -- in which the urethra is on the wrong side of the penis -- and cryptorchidism, a condition in which the testes fail to descend into the scrotum. There was also a rise in testicular cancer and lower sperm counts. In women there were more breast cancers and polycystic ovaries.

These increases posed a conundrum for the researchers. When they examined people who had these disorders, and their mothers, they found they had only very low levels of the chemicals that are known to cause the disorders; in the lab, only much higher concentrations of these individual compounds have be found to produce the same effects. This led Kortenkamp to suspect that mixtures were the missing link. He wondered if the effects of different chemicals, acting through the same biochemical pathway, could add up.

Kortenkamp's group focused on groups of chemicals called xenoestrogens, compounds that disrupt the activity of the hormone oestrogen and induce the development of female sexual characteristics. High levels of xenoestrogens in the environment have been shown to feminise male fish, and have even driven one species in an isolated experimental lake in Canada almost to extinction.

In 2002 Kortenkamp and his colleagues tested a mix of eight xenoestrogens on yeast. These included chemicals used as plasticisers, sunscreen ingredients and others found in cooling and insulating fluids. In the mixture, each was below the level that toxicologists call the "no-observed-effect concentration" -- the level that should be safe. Sure enough, the combination triggered unusual effects in the yeast. Kortenkamp and his colleagues dubbed the mixture effect "something from nothing" (see Diagram).

Kortenkamp and his colleagues found that if the doses of all eight chemicals were simply added together, after adjusting for the varying potencies, this new cumulative dose could be used to predict the effect -- a principle called "dose addition". "This result was to be expected, but it had never been shown with endocrine disrupters until our work," says Kortenkamp. Intuitively this makes sense, he says: "Every mixture component contributes to the effect, no matter how small."

Since then the effect has been shown with other species, too. Kortenkamp and his colleagues now report that mixtures of xenoestrogens feminised males to varying degrees even though the individual components should have been harmless. In July this year the team showed that a blend of anti-androgens -- chemicals that block the effect of male sex hormones -- can work in the same way. They exposed pregnant rats to two common fungicides, vinclozolin and procymidone, and the prostate cancer drug flutamide, and then screened the male offspring for reproductive deformities. At higher doses, each of these three chemicals wreaks havoc with sex hormones, and they all do it via the same mechanism: they disrupt male development by blocking androgen receptors and so prevent natural hormones from binding. The researchers found that even when the chemicals were used in doses that had no effect when given individually to pregnant rats, a mixture of them disrupted the sexual development of male fetuses.

Earl Gray, an ecotoxicologist at the reproductive toxicology division of the US Environmental Protection Agency's Health and Environmental Effects Research Laboratory (HEERL) in Research Triangle, North Carolina, and his team also tried exposing pregnant rats to vinclozolin and procymidone. When they exposed the animals to the compounds individually, they too saw no effect. But when they combined the two, half of the males were born with hypospadia. Gray calls this phenomenon "the new math -- zero plus zero equals something".

Gray then tried the same experiment with phthalates -- the ubiquitous compounds that are used to soften plastics and thicken lotions, and are found in everything from shampoo to vinyl flooring and flexible medical tubing. They also disrupt male development, in this case by stopping the fetus from making testosterone. The mix of two phthalates that Gray used caused many of the same effects on male rat fetuses as a mixture of vinclozolin and procymidone.

It makes sense that chemicals targeting the same pathway would have an additive effect. But what about mixtures of chemicals that work via different mechanisms? Surely the individual doses of such chemicals would not be additive in the same way.

"The mixture of different chemicals shouldn't have had any effect. But it did"In 2004, Gray and his team put this to the test by mixing procymidone with a phthalate at levels that, on their own, would produce no effect. Because the chemicals work via different routes, he expected that the combination wouldn't have any effect either. But they did. Then the team mixed seven compounds -- with four independent routes of action -- each at a level that did not produce an effect. "We expected nothing to happen, but when we give all [the compounds] together, all the animals are malformed," Gray says. "We disrupted the androgen receptor signalling pathway by several different mechanisms. It seems the tissue can't tell the difference and is responding in an additive fashion."

All of this is throwing up problems for regulatory agencies around the world. Governments generally don't take into account the additive effects of different chemicals, with the exception of dioxins -- which accumulate to dangerous levels and disrupt hormones in the body -- and some pesticides. For the most part, risk assessments are done one chemical at a time.

Even then, regulation is no simple issue. First you need to know a chemical's potency, identify which tissues it harms and determine whether a certain population might be exposed to other chemicals that might damage the same tissue. Add in the cocktail effect and it gets harder still. "It is a pretty difficult regulatory scenario," admits Gray. "At this point the science is easier than implementing the regulatory framework."

Mixed up inside

For one thing, with many mixtures it's almost impossible to work out how much we're getting. The endocrine disrupter diethyl phthalate, for example, easily escapes from plastics and is in so many different products -- from toothbrushes to toys, and packaging to cosmetics and drugs -- that it would be difficult to work out the aggregate exposure from all sources, says Gray. This also makes it tricky to investigate possible links between chemical mixtures and disease. "Everyone has exposure to chemicals, even people living in the Arctic," says John Sumpter, an ecotoxicologist at Brunel University in London. "We can't go to a group with a mixture of nasty chemicals and then go to another who have had no exposure and compare their rate of breast cancer risk or sperm count. We are doing a scientific experiment by letting these chemicals accumulate in our bodies, blood and wildlife." That's why some researchers are suggesting new ways to gauge the effects of chemical mixtures on the body. For example, rather than trying to identify levels of individual xenoestrogens in a patient's blood, it may be more efficient to take a serum sample and determine the "oestrogenic burden" being imposed on their body from a variety of different sources by testing the sample on oestrogen-sensitive cells in the lab. "It might work well as a screening tool to identify people with potential problems," says Linda Birnbaum, director of the experimental toxicology division at HEERL. Then, for example, you could make cocktails of foods, water and other products from the person's life to try to identify the source of the chemicals. Nicolas Olea, a doctor and oncologist at the University of Granada, Spain, is already trying this kind of approach. He is exploring whether exposure to chemicals with oestrogenic activity leads to genital malformations like cryptorchidism and hypospadia in men, and breast cancer in women. He and his colleagues took samples from various tissues and measured the ability of the environmental contaminants in them to trigger the proliferation of lab-cultured oestrogen-sensitive cells. Because it is difficult to predict from a compound's structure whether it might have oestrogenic effects, a cell-based assay like this is a cheap way to screen potentially harmful chemicals. They found that the higher this "total effective xenoestrogen burden" the greater the chance the contaminants could disrupt oestrogen-dependent processes.

Others are cautiously optimistic about Olea's approach. "The concept is correct, I cannot comment on how well the cell effect tracks a cancer effect," says James Pirkle, deputy director of the US Centers for Disease Control's Environmental Health Laboratory in Atlanta, Georgia.

Shanna Swan is doing something similar. In a study published in 2005 she showed that boys whose mothers had had higher levels of five phthalates while their babies were in the womb had a shorter distance between the anus and genitals -- a marker of feminising activity. They also had higher rates of cryptorchidism compared to sons of mothers with lower phthalate levels. Swan devised a cumulative score to reflect exposure levels to all five phthalates and found that score was "very predictive of ano-genital distance".

The method is still expensive, and a regular "phthalate scan" isn't on the cards just yet. A potentially less costly approach, says Pirkle, is regular biomonitoring of subsets of the population to measure the levels of dangerous chemicals in blood and urine, and link particular chemicals to specific health effects. Every two years since 2001, the US Centers for Disease Control has published data on the US population's exposure to a range of potentially harmful chemicals. In 2005 the agency released data for 148 chemicals; next year it plans to release a report covering 275. While that number falls far short of the number of new chemicals entering the fray each year, Pirkle says that technology is making it ever easier to monitor new substances. The reports do not consider specific mixtures but include exposure data for each individual chemical to make it easier to calculate the likely effects of mixtures.

The European Union, meanwhile, is taking steps to control the number of chemicals being released in the first place. On 1 June its REACH (registration, evaluation, authorisation and restriction of chemical substances) regulations became law. The aim is to cut health risks associated with everyday chemicals by forcing chemical manufacturers and importers to register their compounds and provide safety information to the new European Chemicals Agency, based in Helsinki, Finland. This information must be provided before the chemicals are sold. The new law shifts the burden of responsibility for the health effects of chemicals from government to industry and is also intended to encourage the use of less harmful alternatives for the more toxic chemicals.

Not everyone is so worried about the cocktail effect. Some researchers even find it reassuring -- or at least not as bad as it could be. Kevin Crofton, a neurotoxicologist at the EPA, explored how a mixture of 18 polyhalogenated aromatic hydrocarbons found in electrical equipment, flame retardants and paints could disrupt thyroid hormone levels in rats. At the lowest doses of the mixture the effect on the levels of the thyroid T4 hormone was what you would expect from the principle of dose addition; at the highest doses the effect was twice that. "Some people would call that synergy," says Crofton, "but it is not a very big synergistic effect. It was a twofold difference."

He adds: "These results are quite reassuring because EPA's default to calculate the cumulative risk of mixtures is dose addition." Only recently, however, have scientists like Crofton been able to prove that this default is correct. "If it had been a 20-fold difference I would have said, 'Boy, the agency needs to look into how it is doing things.'"

Kortenkamp says that regulatory bodies seem to be starting to acknowledge that chemical-by-chemical risk assessment provides a false sense of security. In November last year around 100 scientists and EU policy-makers at the "Weybridge +10" workshop held in Helsinki concluded that mixture effects must be considered during risk assessment and regulation. The European Commission plans to spend more on probing the effects of environmental chemicals on human health.

For now, though, chemicals are an inescapable part of life. And while high-profile campaigns by pressure groups like WWF seek to alert us to what they see as the dangers of artificial chemicals, some toxicologists warn that they may be overstating the case. "I think you need to be careful about hyping the risk," says Crofton, referring to stories in which individuals have been screened for several hundred chemicals. "When you say I have 145 chemicals in my body, that in itself does not translate into a hazard. You have to know something about the dose, the hazard and how all these chemicals can add up." Olea, however, suggest that it is sensible to be cautious. "If you don't know it is good, assume it is bad," he says.

Like it or not, the chemicals are with us. "People can't keep phthalates [or other chemicals] out of their air, water or food," says Swan. "Most people don't have the information or money to do these things." A more productive approach might be to tell people how to limit exposure to harmful substances and request better labelling from manufacturers. "We need to put a lot of money into figuring out what these things do in real-world scenarios and take regulatory action," she says. "Just like we limited cigarette smoke exposure, we'll have to limit other exposures."

Bijal Trivedi is a freelance science writer based in Washington DC

Copyright Reed Business Inform

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From: The Daily Green, Sept. 4, 2007

EDITORIAL: A PREEMPTIVE STRIKE AGAINST TOXIC CHEMICALS

California Considers Schemes To Stop Pollution Before It Starts

In the United States, the use of potentially toxic chemicals has always had a leap-before-you-look regulatory approach, with the emphasis on producing innovative new products and solutions. Problem is, time and again substances thought to be harmless prove toxic, or persistent in the environment, and cleaning them becomes a costly both in health and dollars -- headache.

That's why it's good to watch California, which is considering two competing proposals that may be more complementary, according to a Los Angeles Times editorial, than they appear.

Gov. Arnold Schwarzenegger, a Republican, is pushing a "green chemistry" initiative that has the backing of business and industry in the Golden State. It would look at chemicals used and study their potential risks -- as well as potential alternatives.

Assemblyman Mike Feuer, a Democrat, has proposed a Massachusetts- style inventory of all hazardous chemicals used by California businesses, and require regular reports about their plans to reduce or eliminate their use.

The take-home message from both proposals is this: Business as usual isn't working. We've had too many man-made chemicals that turn out to prey on the health of humans or wildlife to let more into the environment without the closest of scrutiny. After all, we're talking about chemicals developed in labs -- chemicals that the human body and the environment have not evolved to process or defend themselves against.

Copyright Reuters

From: Financial Times (London, UK), Sept. 5, 2007

CLIMATE CHANGE DEBATE NEEDS REVOLUTION

By John Aglionby in Jakarta

A revolution of society on a scale never witnessed in peacetime is needed if climate change is to be tackled successfully, the head of a major business grouping has warned.

Bjorn Stigson, the head of the Geneva-based World Business Council for Sustainable Development (WBCSD), predicted governments would be unable to reach agreement on a framework for reducing carbon emissions at either a US-sponsored meeting in Washington later this month or at a United Nations climate summit in Indonesia in December.

Climate change is also expected to be high on the agenda at this week's annual summit of Pacific leaders in Sydney.

"It will probably get worse before it gets better before governments feel they've got the political mandate to act," he told the Financial Times during a visit to Jakarta. "We're going to have to go into some sort of crisis before it's going to be resolved. I don't think people have realised the challenge. This is more serious than what people think."

The "challenge", Mr Stigson said, is for developed nations to cut carbon emission levels by 60 to 80 per cent from current levels by 2050 if global emissions are to be kept below 550 parts per million. Global emissions at that level would keep average permanent global temperature increase below 3 degrees by 2050, a level beyond which most scientists say climate change would be significantly worse.

The WBCSD reached this conclusion after studying the Stern review on climate change, the International Energy Association's world energy outlook, and a recent International Plant Protection Convention review.

"I think it's beginning to dawn on people that we are talking about such a major change in society people are saying this is tougher than what we thought," he said. "How do you change society in a radical way in a democracy so the people you want to vote for you are also going to suffer the consequences of the policies that you put in place."

"I don't think we've seen that kind of a challenge in societal change happening peacefully. It's [only] happened in revolutions."

The 200 members of the WBCSD, which have a combined market cap of $6,000bn, are dismayed by politicians' lack of political will to address the issues, Mr Stigson said.

"We're very concerned by what we see and the lack of response from governments in grasping the responsibility they have in dealing with this issue," he said. "Our problem right now is that we...don't know what the policies are going to be beyond 2012. How do you take these issues into consideration when you build a new plant that's going to live for 30, 40 years."

The WBCSD want rich countries to agree on global targets for themselves while committing to developing nations $80-$100bn a year and technology to help them grow more sustainably.

"If that deal is not there, you'll be in a situation where India, China and Brazil will say, we're not going to get into any agreement," he said. "If I were betting my money now, I would bet that by 2012 the world will not have a global framework. We will have a patchwork of regional and national regulations that we have to make as compatible as possible."

Copyright The Financial Times Limited 2007

From: Courier-Post (Cherry Hill, N.J.), Aug. 13, 2007

OYSTERMEN 'IN THE FIGHT'

By Richard Pearsall

Port Norris, N.J. -- Thanks to the oyster industry, this old port at the mouth of the Maurice River once had more millionaires per capita than any other place in New Jersey.

Or so the story goes.

Those days are gone, the oyster fishery on the Delaware Bay having been decimated by not one, but two waves of parasites.

But the industry survives -- a few dozen oystermen still ply the bay -- and New Jersey is striving to ensure that the fishery at least holds its own.

"We're in the fight," said Eric Powell, director of the Haskin Shellfish Research Laboratory, the Rutgers outpost here dedicated to both research and managing the oyster beds.

Toward the latter end, the lab, in conjunction with the Army Corps of Engineers, the state Department of Environmental Protection (DEP) and others, has been dumping millions of clamshells into the bay each year for the past three years.

The idea is to encourage what's called "recruitment," building up a layer of the clean, hard surfaces that baby oysters, or "spat," love to grab hold of to get started in life.

The results so far are inconclusive.

Oystermen will be allowed to harvest 80,000 bushels from state managed oyster beds this year, slightly above the average of 70,000 bushels a year that has prevailed over the past decade.

But the number has gone up and down from year to year and is likely to continue to do so depending on the strength of the parasite that began afflicting the oyster beds in the 1990s.

"The mortality rate from disease is still too high," Powell said of dermo, which has proven to be a persistent enemy of the Eastern oyster. "This is one of the penalties of global warming."

Dermo is a warm-water disease, he explained, one that has moved up the East Coast, reaching New Jersey in the 1990s and now a problem as far north as the coast of Maine.

It also likes high salinity, so it is more of a problem in periods of drought when the salt line moves further up the bay.

"We can minimize the damage from dermo," Powell said, "but we can't eradicate it. It's going to take its toll. As a result, we're going to have to be more proactive."

The oystermen themselves seem to have found a niche market for their product and are looking more to protect and preserve than grow their industry.

"We want the industry to be stable," said Steve Fleetwood, an oystermen himself and the manager of the Hillard Bloom Packing Company in Port Norris.

"With the dermo still around, I don't know that any of us are really comfortable."

At its peak in the late 1920s, the oyster fishery sent some 500 boats and 4,000 men out on to the Delaware Bay, where they dredged up as many as two million bushels of oysters a year.

The captains of the schooners that sailed the bay got rich, as did the entrepreneurs who ran the shucking and packing houses in Bivalve and Shell Pile and the railroad barons whose cars carried the prized seafood to market.

"This was a boom town," said Megan Wren, surveying the now largely desolate area around her offices here at the Bayshore Discovery Project, a nonprofit whose mission is to preserve the history and culture of the region, but also to promote its future.

Nature turned out to be even crueler to the oyster fishery than the Great Depression, striking with two waves of parasites that, while not harmful to humans, are deadly to oysters.

In the 1950s, a parasite called MSX destroyed more than 90 percent of the harvestable oysters on the bay's bottom.

Then in the 1990s, just when the oyster beds were beginning to recover from MSX, the second parasite, dermo, struck.

Today about 70 boats, each with a license attached, dredge the Delaware Bay for oysters.

They still employ basically the same techniques as the sailing schooners that preceded their diesel-powered boats, dragging a steel cage along the bottom, pulling it up, then sorting out its contents on deck for the prized catch.

Rutgers and the DEP carefully monitor both the bay bottom and the catch, enabling them to control this year's catch and accurately establish a quota for next year.

The overall quota the state sets for the beds it manages is divided among the license holders, resulting this year in an allotment of about 1,100 bushels per boat.

"The number of licenses is limited," said Jason Hearon, fisheries biologist for the state DEP, "in part to keep the pressure for a bigger harvest down."

One problem facing the program is finding enough shell to use for seed strata.

"A few years ago this was a waste product they couldn't get rid of," Powell said of the clamshells. Now there is competition from road work and other uses.

"It's really criminal for shells to go anywhere but back into their natural environment," he concluded.

Reach Richard Pearsall at (856) 486-2465 or rpearsall@courierposton

From: Denver Post (Denver, Colo.), Sept. 3, 2007

GRASSLANDS ARE LOSING GROUND

By Katy Human Denver Post Staff Writer

On eastern Colorado's grassy rangeland, the dominant plant of the future may be one shunned even by the hungriest of cattle: fringed sage.

The unpalatable mint-green shrub increased in bulk by 40 times during climate change experiments conducted by the U.S. Department of Agriculture and Colorado State University, the scientists reported last week.

"It was a minor species at the beginning of the study, but by the end of four years, 10 percent of the aboveground cover was this species," said Jack Morgan, a USDA range scientist in Fort Collins.

"Here's a plant that may be a winner in a greenhouse future," Morgan said.

Grassland covers about 40 percent of Earth's land, Morgan and his colleagues

Scientists set up greenhouses on prairie 40 miles northeast of Fort Collins and then pumped carbon dioxide into some of them to see how that would affect the vegetation over four years. (Photo courtesy ARS Rangeland Resources Research Unit)wrote in a paper in the Proceedings of the National Academy of Sciences, and woody shrubs have been moving steadily into most of the planet's grasslands for more than a century. Scientists have attributed that livestock-unfriendly trend to many things, Morgan said, from the suppression of natural fires to overgrazing, drought and climate change.

"There's some who would debate if carbon dioxide and climate change were a factor," Morgan said. "But that's what our study shows - clearly."

Forty miles northeast of Fort Collins, on Colorado's northeastern plains, Morgan and his colleagues set up clear plastic greenhouses around plots of prairie.

They pumped extra carbon dioxide into some of the greenhouses, left ambient air in others, and followed plant communities in both -- and on normal prairie -- for four years.

Fringed sage increased its aboveground bulk by 40 times in the greenhouses with extra carbon dioxide, the team found. "That's a huge response," Morgan said. "I've not seen any plant in the literature that responds as much."

Other studies have shown that plant species react differently to climate change.

In Colorado's mountains, fields of wildflowers gave way to sage during warming experiments.

In a California grassland, species diversity dropped when scientists increased carbon dioxide levels.

On rangeland, the likely continued woody plant encroachment is not just an ecological problem. It's a financial one for ranchers, said Terry Fankhauser, executive vice president of the Arvada-based Colorado Cattlemen's Association.

"We know climate change is inevitable, and we know that means species changes," Fankhauser said.

More shrubs and fewer grasses would not be welcome changes, he said, although Colorado cattlemen have long had to deal with woody invaders.

"It's already a part of everyday ranch management," Fankhauser said. "We have to control those woody species to maintain native vegetation."

Staff writer Katy Human can be reached at 303-954-1910 or khuman@denverpost.com.

From: The New York Times (pg. A19), Aug. 24, 2007

SEEKING WILLIE HORTON

By Paul Krugman, Times columnist

So now Mitt Romney is trying to Willie Hortonize Rudy Giuliani. And thereby hangs a tale -- the tale, in fact, of American politics past and future, and the ultimate reason Karl Rove's vision of a permanent Republican majority was a foolish fantasy.

Willie Horton, for those who don't remember the 1988 election, was a convict from Massachusetts who committed armed robbery and rape after being released from prison on a weekend furlough program. He was made famous by an attack ad, featuring a menacing mugshot, that played into racial fears. Many believe that the ad played an important role in George H.W. Bush's victory over Michael Dukakis.

Now some Republicans are trying to make similar use of the recent murder of three college students in Newark, a crime in which two of the suspects are Hispanic illegal immigrants. Tom Tancredo flew into Newark to accuse the city's leaders of inviting the crime by failing to enforce immigration laws, while Newt Gingrich declared that the "war here at home" against illegal immigrants is "even more deadly than the war in Iraq and Afghanistan."

And Mr. Romney, who pretends to be whatever he thinks the G.O.P. base wants him to be, is running a radio ad denouncing New York as a "sanctuary city" for illegal immigrants, an implicit attack on Mr. Giuliani.

Strangely, nobody seems to be trying to make a national political issue out of other horrifying crimes, like the Connecticut home invasion in which two paroled convicts, both white, are accused of killing a mother and her two daughters. Oh, and by the way: over all, Hispanic immigrants appear to commit relatively few crimes -- in fact, their incarceration rate is actually lower than that of native-born non-Hispanic whites.

To appreciate what's going on here you need to understand the difference between the goals of the modern Republican Party and the strategy it uses to win elections.

The people who run the G.O.P. are concerned, above all, with making America safe for the rich. Their ultimate goal, as Grover Norquist once put it, is to get America back to the way it was "up until Teddy Roosevelt, when the socialists took over," getting rid of "the income tax, the death tax, regulation, all that."

But right-wing economic ideology has never been a vote-winner. Instead, the party's electoral strategy has depended largely on exploiting racial fear and animosity.

Ronald Reagan didn't become governor of California by preaching the wonders of free enterprise; he did it by attacking the state's fair housing law, denouncing welfare cheats and associating liberals with urban riots. Reagan didn't begin his 1980 campaign with a speech on supply-side economics, he began it -- at the urging of a young Trent Lott -- with a speech supporting states' rights delivered just outside Philadelphia, Miss., where three civil rights workers were murdered in 1964.

And if you look at the political successes of the G.O.P. since it was taken over by movement conservatives, they had very little to do with public opposition to taxes, moral values, perceived strength on national security, or any of the other explanations usually offered. To an almost embarrassing extent, they all come down to just five words: southern whites starting voting Republican.

In fact, I suspect that the underlying importance of race to the Republican base is the reason Rudy Giuliani remains the front-runner for the G.O.P. nomination, despite his serial adultery and his past record as a social liberal. Never mind moral values: what really matters to the base is that Mr. Giuliani comes across as an authoritarian, willing in particular to crack down on you-know-who.

But Republicans have a problem: demographic changes are making their race-based electoral strategy decreasingly effective. Quite simply, America is becoming less white, mainly because of immigration. Hispanic and Asian voters were only 4 percent of the electorate in 1980, but they were 11 percent of voters in 2004 -- and that number will keep rising for the foreseeable future.

Those numbers are the reason Karl Rove was so eager to reach out to Hispanic voters. But the whites the G.O.P. has counted on to vote their color, not their economic interests, are having none of it. From their point of view, it's us versus them -- and everyone who looks different is one of them.

So now we have the spectacle of Republicans competing over who can be most convincingly anti-Hispanic. I know, officially they're not hostile to Hispanics in general, only to illegal immigrants, but that's a distinction neither the G.O.P. base nor Hispanic voters takes seriously.

Today's G.O.P., in short, is trapped by its history of cynicism. For decades it has exploited racial animosity to win over white voters and now, when Republican politicians need to reach out to an increasingly diverse country, the base won't let them.

TWO FRIENDS DEBATE RISK ASSESSMENT AND PRECAUTION

By Peter Montague

Recently my friend Adam Finkel -- a skilled and principled risk assessor -- won two important victories over the Occupational Safety and Health Administration (OSHA).

In 2000, Adam was appointed Regional Administrator for OSHA in charge of the Denver office. When he began to suspect that OSHA inspectors were being exposed to dangerous levels of the highly-toxic metal, beryllium, he took precautionary action -- urging OSHA to test beryllium levels in OSHA inspectors. It cost him his job.

The agency did not even want to tell its inspectors they were being exposed to beryllium, much less test them. So Adam felt he had no choice -- in 2002, he blew the whistle and took his concerns public. OSHA immediately relieved him of his duties as Regional Administrator, and moved him to Washington where they changed his title to "senior advisor" and assigned him to the National Safety Council -- a place where "they send people they don't like," he would later tell a reporter.

Adam sued OSHA under the federal whistleblower protection statute and eventually won two years' back pay, plus a substantial lump sum settlement, but he didn't stop there. In 2005, he lodged a Freedom of Information Act law suit against the agency, asking for all monitoring data on toxic exposures of all OSHA inspectors. Meanwhile, OSHA began testing its inspectors for beryllium, finding exactly what Adam had suspected they would find -- dangerously high levels of the toxic metal in some inspectors.

Adam is now a professor in the Department of Environmental and Occupational Health, School of Public Health, University of Medicine and Dentistry of New Jersey (UMDNJ); and a visiting scholar at the Woodrow Wilson School, Princeton University. At UMDNJ, he teaches "Environmental Risk Assessment."

Earlier this summer, Adam won his FOIA lawsuit. A judge ruled that OSHA has to hand over 2 million lab tests on 75,000 employees going back to 1979. It was a stunning victory over an entrenched bureaucracy.

Meanwhile in 2006 the American Public Health Association selected Adam to receive the prestigious David Rall Award for advocacy in public health. You can read his acceptance speech here.

When Adam's FOIA victory was announced early in July, I sent him a note of congratulations. He sent back a note, attaching a couple of articles, one of which was a book review he had published recently of Cass Sunstein's book, Risk and Reason. Sunstein doesn't "get" the precautionary principle -- evidently, he simply sees no need for it. Of course the reason why we need precaution is because the cumulative impacts of the human economy are now threatening to wreck our only home -- as Joe Guth explained last week in Rachel's News.

In any event, I responded to Adam's book review by writing "A letter to my friend, who is a risk assessor," and I invited Adam to respond, which he was kind enough to do.

So there you have it.

Do any readers want to respond to either of us? Please send responses to peter@rachel.org.

From: Journal of Industrial Ecology (pg. 243), Oct. 1, 2005

ADAM FINKEL REVIEWS CASS SUNSTEIN'S BOOK, RISK AND REASON

A review of: Risk and Reason: Safety, Law, and the Environment, by Cass R. Sunstein. Cambridge, UK: Cambridge University Press, 2002, 342 pp., ISBN 0521791995, $25.00 (Also in paperback: ISBN 0521016258 $22.99).

By Adam M. Finkel

As someone dedicated to the notion that society needs quantitative risk assessment (QRA) now more than ever to help make decisions about health, safety, and the environment, I confess that I dread the arrival of each new book that touts QRA or cost-benefit analysis as a "simple tool to promote sensible regulation." Although risk analysis has enemies aplenty, from both ends of the ideological spectrum, with "friends" such as John Graham (Harnessing Science for Environmental Regulation, 1991), Justice Stephen Breyer (Breaking the Vicious Circle, 1994), and now Cass Sunstein, practitioners have their hands full.

I believe that at its best, QRA can serve us better than a "precautionary principle" that eschews analysis in favor of crusades against particular hazards that we somehow know are needlessly harmful and can be eliminated at little or no economic or human cost. After all, this orientation has brought us increased asbestos exposure for schoolchildren and remediation workers in the name of prevention, and also justified an ongoing war with as pure a statement of the precautionary principle as we are likely to find ("we have every reason to assume the worst, and we have an urgent duty to prevent the worst from occurring," said President Bush in October 2002 about weapons of mass destruction in Iraq). More attention to benefits and costs might occasionally dampen the consistent enthusiasm of the environmental movement for prevention, and might even moderate the on- again, off-again role precaution plays in current U.S. economic and foreign policies. But "at its best" is often a distant, and even a receding, target -- for in Risk and Reason, Sunstein has managed to sketch out a brand of QRA that may actually be less scientific, and more divisive, than no analysis at all.

To set environmental standards, to set priorities among competing claims for environmental protection, or to evaluate the results of private or public actions to protect the environment, we need reliable estimates of the magnitude of the harms we hope to avert as well as of the costs of control. The very notion of eco-efficiency presupposes the ability to quantify risk and cost, lest companies either waste resources chasing "phantom risks" or declare victory while needless harms continue unabated. In a cogent chapter (Ch. 8) on the role of the U.S. judiciary in promoting analysis, Sunstein argues persuasively that regulatory agencies should at least try to make the case that the benefits of their efforts outweigh the costs, but he appears to recognize that courts are often ill-equipped to substitute their judgments for the agencies' about precisely how to quantify and to balance. He also offers a useful chapter (Ch. 10) on some creative ways agencies can transcend a traditional regulatory enforcer role, help polluters solve specific problems, and even enlist them in the cause of improving eco-efficiency up and down the supply chain. (I tried hard to innovate in these ways as director of rulemaking and as a regional administrator at the U.S. Occupational Safety and Health Administration, with, at best, benign neglect from political appointees of both parties, so Sunstein may be too sanguine about the practical appeal of these innovations.)

Would that Sunstein had started (or stopped) with this paean to analysis as a means to an end -- perhaps to be an open door inviting citizens, experts, those who would benefit from regulation, and those reined in by it to "reason together." Instead, he joins a chorus of voices promoting analysis as a way to justify conclusions already ordained, adding his own discordant note. Sunstein clearly sees QRA as a sort of national antipsychotic drug, which we need piped into our homes and offices to dispel "mass delusions" about risk. He refers to this as "educating" the public, and therein lies the most disconcerting aspect of Risk and Reason: he posits a great divide between ordinary citizens and "experts," and one that can only be reconciled by the utter submission of the former to the latter. "When ordinary people disagree with experts, it is often because ordinary people are confused," he asserts (p. 56) -- not only confused about the facts, in his view, but not even smart enough to exhibit a rational form of herd behavior! For according to Sunstein, "millions of people come to accept a certain belief [about risk] simply because of what they think other people believe" (p. 37, emphasis added).

If I thought Sunstein was trying by this to aggrandize my fellow travelers -- scientists trained in the biology of dose-response relationships and the chemistry and physics of substances in the environment, the ones who actually produce risk assessments -- I suppose I would feel inwardly flattered, if outwardly sheepish, about this unsolicited elevation above the unwashed masses. But the reader will have to look long and hard to find citations to the work of practicing risk assessors or scientists who helped pioneer these methods. Instead, when Sunstein observes that "precisely because they are experts, they are more likely to be right than ordinary people. . . brain surgeons make mistakes, but they know more than the rest of us about brain surgery" (p. 77), he has in my view a quaint idea of where to find the "brain surgeons" of environmental risk analysis.

He introduces the book with three epigrams, which I would oversimplify thus: (1) the general public neglects certain large risks worthy of fear, instead exhibiting "paranoia" about trivial risks; (2) we maintain these skewed priorities in order to avoid taking responsibility for the (larger) risks we run voluntarily; and (3) defenders of these skewed priorities are narcissists who do not care if their policies would do more harm than good. The authors of these epigrams have something in common beyond their worldviews: they are all economists. Does expertise in how markets work (and that concession would ignore the growing literature on the poor track record of economists in estimating compliance costs in the regulatory arena) make one a "brain surgeon" qualified to bash those with different views about, say, epidemiology or chemical carcinogenesis?

To illustrate the effects of Sunstein's continued reliance on one or two particular subspecies of "expert" throughout the rest of his book, I offer a brief analysis of Sunstein's five short paragraphs (pp. 82-83) pronouncing that the 1989 public outcry over Alar involved masses of "people [who] were much more frightened than they should have been."1 Sunstein's readers learn the following "facts" in this example: ** Alar was a "pesticide" (actually, it regulated the growth of apples so that they would ripen at a desired time).

** "About 1 percent of Alar is composed of UDMH [unsymmetrical dimethylhydrazine], a carcinogen" (actually, this is roughly the proportion found in raw apples -- but when they are processed into apple juice, about five times this amount of UDMH is produced).

** The Natural Resources Defense Council (NRDC) performed a risk assessment claiming that "about one out of every 4,200 [preschool children] exposed to Alar will develop cancer by age six" (actually, NRDC estimated that exposures prior to age six could cause cancer with this probability sometime during the 70-year lifetimes of these children -- a huge distinction, with Sunstein's revision making NRDC appear unfamiliar with basic assumptions about cancer latency periods).

** The EPA's current risk assessment is "lower than that of the NRDC by a factor of 600" (actually, the 1/250,000 figure Sunstein cites as EPA's differs from NRDC's 1/4,200 figure by only a factor of 60 (250,000 ÷ 4,200). Besides, EPA never calculated the risk at one in 250,000. After Alar's manufacturer (Uniroyal) finished a state-of-the- art study of the carcinogenicity of UDMH in laboratory animals, EPA (Federal Register, Vol. 57, October 8, 1992, pp. 46,436-46,445) recalculated the lifetime excess risk to humans at 2.6 × 10-5, or 1 in 38,000. And, acting on recommendations from the U.S. National Academy of Sciences, EPA has subsequently stated that it will consider an additional tenfold safety factor to account for the increased susceptibility of children under age 2, and a threefold factor for children aged 2 to 16 -- which, had they been applied to UDMH, would have made the EPA estimate almost equal to the NRDC estimate that made people "more frightened than they should have been").

** "A United Nations panel... found that Alar does not cause cancer in mice, and it is not dangerous to people" (true enough, except that Sunstein does not mention that this panel invoked a threshold model of carcinogenesis that no U.S. agency would have relied on without more and different scientific evidence: the U.N. panel simply ignored the large number of tumors at the two highest doses in Uniroyal's UDMH study and declared the third-highest dose to be "safe" because that dose produced tumors, but at a rate not significantly higher than the background rate).

** A 60 Minutes broadcast "instigated a public outcry.. . without the most simple checks on its reliability or documentation" (readers might be interested, however, that both a federal district court and a federal appeals court summarily dismissed the lawsuit over this broadcast, finding that the plaintiffs "failed to raise a genuine issue of material fact regarding the falsity of statements made during the broadcast").

** The demand for apples "plummeted" during 1989 (true enough, but Sunstein neglects to mention that within five years after the withdrawal of Alar the apple industry's revenues doubled versus the level before the controversy started).

Sunstein's entire source material for these scientific and other conclusions? Four footnotes from a book by political scientist Aaron Wildavsky and one quotation from an editorial in Science magazine (although the incorrect division of 250,000 by 4,200 and the mangling of the NRDC risk assessment appear to be Sunstein's own contributions). One reason the general public annoys Sunstein by disagreeing with the "experts," therefore, is that he has a very narrow view of where one might look for a gold standard against which to judge the merits of competing conclusions. Perhaps Sunstein himself has come to certain beliefs about Alar and other risks "simply because of what [he thinks] other people believe," and comforts himself that the people he agrees with must be "experts."

Similarly, Sunstein makes some insightful points about the public's tendency to assume that the risks are higher for items whose benefits they perceive as small, but he fails to notice the mountains of evidence that his preferred brand of experts tend to impute high economic costs to regulations that they perceive as having low risk- reduction benefits. He accepts as "unquestionably correct" the conclusion of Tengs and colleagues (1995) that government badly misallocates risk-reduction resources, for example, without acknowledging Heinzerling's (2002) finding that in 79 of the 90 environmental interventions Tengs and colleagues accused of most severely wasting the public's money, the agency involved never required that a dime be spent to control those hazards, probably because analysis showed such expenditures to be of questionable cost- effectiveness.

Finally, Sunstein fails to acknowledge the degree to which experts can agree with the public on broad issues, and can also disagree among themselves on the details. He cites approvingly studies by Slovic and colleagues suggesting that laypeople perform "intuitive toxicology" to shore up their beliefs, but fails to mention that in the most recent of their studies (1995), toxicologists and the general public both placed 9 of the same 10 risks at the top of38 risks surveyed, and agreed on 6 of the 10 risks among the lowest 10 ranked. Yet when toxicologists alone were given information on the carcinogenic effects of "Chemical B" (data on bromoethane, with its identity concealed) in male and female mice and rats, only 6% of them matched the conclusions of the experts at the U.S. National Toxicology Program that there was "clear evidence" of carcinogenicity in one test group (female mice), "equivocal evidence" in two others, and "some evidence" in the fourth. "What are ordinary people thinking?" (p. 36) when they disagree with the plurality of toxicologists, Sunstein asks, without wondering what these toxicologists must have been thinking to disagree so much with each other. One simple answer is that perhaps both toxicologists and the general public, more so than others whose training leads them elsewhere, appreciate the uncertainties in the raw numbers and the room for honest divergence of opinion even when the uncertainties are small. These uncertainties become even more influential when multiple risks must be combined and compared -- as in most life-cycle assessments and most efforts to identify and promote more eco- efficient pathways -- so Sunstein's reliance on a style of expertise that regards uncertainty as an annoyance we can downplay or "average away" is particularly ill-suited to broader policy applications.

I actually do understand Sunstein's frustration with the center of gravity of public opinion in some of these areas. Having worked on health hazards in the general environment and in the nation's workplaces, I devoutly wish that more laypeople (and more experts) could muster more concern about parts per thousand in the latter arena than parts per billion of the same substances in the former. But I worry that condescension is at best a poor strategy to begin a dialogue about risk management, and hope that expertise would aspire to more than proclaiming the "right" perspective and badgering people into accepting it. Instead, emphasizing the variations in expertise and orientation among experts could actually advance Sunstein's stated goal of promoting a "cost-benefit state," as it would force those who denounce all risk and cost-benefit analysis to focus their sweeping indictments where they belong. But until those of us who believe in a humble, humane brand of risk assessment can convince the public that substandard analyses indict the assessor(s) involved, not the entire field, I suppose we deserve to have our methods hijacked by experts outside our field or supplanted by an intuitive brand of "precaution."

Adam M. Finkel, School of Public Health, University of Medicine and Dentistry of New Jersey Piscataway, New Jersey, USA

Note

1. This is admittedly not a disinterested choice, as I was an expert witness for CBS News in its successful attempts to have the courts summarily dismiss the product disparagement suit brought against it for its 1989 broadcast about Alar. But Sunstein's summaries of other hazards (e.g., toxic waste dumps, arsenic, airborne particulate matter) could illustrate the same general point.

References

Heinzerling, L. 2002. Five hundred life-saving interventions and their misuse in the debate over regulatory reform. Risk: Health, Safety and Environment 13(Spring): 151-175.

Slovic, P., T. Malmfors, D. Krewski, C. K. Mertz, N. Neil, and S. Bartlett. 1995. Intuitive toxicology, Part II: Expert and lay judgments of chemical risks in Canada. Risk Analysis 15(6): 661-675.

Tengs, T. O., M. E. Adams, J. S. Pliskin, D. G. Safran, J. E. Siegel, M. C. Weinstein, and J. D. Graham. 1995. Five hundred life saving interventions and their cost-effectiveness. Risk Analysis 15(3): 369- 390.

From: Rachel's Precaution Reporter #103, Aug. 15, 2007

A LETTER TO MY FRIEND WHO IS A RISK ASSESSOR

Dear Adam,

It was really good to hear from you. I'm delighted that you're now working in New Jersey, with joint appointments at Princeton University and at the School of Public health at the University of Medicine and Dentistry of New Jersey (UMDNJ). Everyone in New Jersey is taking a bath in low levels of toxic chemicals, so we need all the help we can get, and you're exactly the kind of person we most need help from -- honest, knowledgeable, committed, and principled. Your knowledge of toxicology and risk assessment -- and the courage you demonstrated as a government whistle-blower within the Occupational Safety and Health Administration -- are sorely needed in the Garden State, as they are everywhere in America.

I read with real interest your review of Cass Sunstein's book, Risk and Reason. I thought you did an excellent job of showing that Sunstein "has managed to sketch out a brand of QRA [quantitative risk assessment] that may actually be less scientific and more divisive, than no analysis at all." To me, it seems that Sunstein is more interested in picking a fight with his fellow liberals than in helping people make better decisions.

What I want to discuss in this note to you is your attack on the precautionary principle. In the second paragraph of your review, you wrote, "I believe that at its best, QRA [quantitative risk assessment] can serve us better than a 'precautionary principle' that eschews analysis in favor of crusades against particular hazards that we somehow know are needlessly harmful and can be eliminated at little or no economic or human cost. After all, this orientation has brought us increased asbestos exposure for schoolchildren and remediation workers in the name of prevention, and also justified an ongoing war with as pure a statement of the precautionary principle as we are likely to find ("we have every reason to assume the worst, and we have an urgent duty to prevent the worst from occurring," said President Bush in October 2002 about weapons of mass destruction in Iraq)."

The two examples you give -- asbestos removal, and Mr. Bush's pre- emptive war in Iraq -- really aren't good examples of the precautionary principle. Let's look at the details. All versions of the precautionary principle have three basic parts:

1) If you have reasonable suspicion of harm

2) and you have scientific uncertainty

3) then you have a duty to take action to avert harm (though the kind of action to take is not spelled out in the precautionary principle).

Those are the three basic elements of the precautionary principle, found in every definition of the principle.

And here is a slightly more verbose version of the same thing:

1. Pay attention and heed early warnings. In a highly technological society, we need to keep paying attention because so many things can go wrong, with serious consequences.

2. When we develop reasonable suspicion that harm is occurring or is about to occur, we have a duty to take action to avert harm. The action to take is not spelled out by the precautionary principle but proponents of the principle have come up with some suggestions for action:

3. We can set goals -- and in doing this, we can make serious efforts to engage the people who will be affected by the decisions.

4. We can examine all reasonable alternatives for achieving the goal(s), again REALLY engaging the people who will be affected.

5. We can give the benefit of the doubt to nature and to public health.

6. After the decision, we can monitor, to see what happens, and again heed early warnings.

7. And we can favor decisions that are reversible, in case our monitoring reveals that things are going badly.

Now, let's look at the examples you gave to see if they really represent failures of the precautionary principle.

The asbestos removal craze (1985-2000) was essentially started by one man, James J. Florio, former Congressman from New Jersey (and later Governor of New Jersey).

As we learn from this 1985 article from the Philadelphia Inquirer, gubernatorial candidate Florio was fond of bashing his opponent for ignoring the "asbestos crisis" and the 'garbage crisis.' In Mr. Florio's campaign for governor of New Jersey, the "asbestos crisis" was a political ploy -- and it worked. He got elected by promising to fix the asbestos crisis and the garbage crisis.

As governor, Mr. Florio's approach to the "garbage crisis" was to site a new garbage incinerator in each of New Jersey's 21 counties. At $300 to $600 million per machine, this would have set loose an unprecedented quantity of public monies sloshing around in the political system. Later it turned out that Mr. Florio's chief of staff had close ties to the incinerator industry.

I don't know whether Mr. Florio or his political cronies profited directly from the asbestos removal industry that he created almost single-handedly, but the decision-making for asbestos was similar to his approach to the "garbage crisis." He did not engage the affected public in setting goals and then examine all reasonable alternatives for achieving those goals. He did not take a precautionary approach.

In the case of garbage, Mr. Florio and his cronies decided behind closed doors that New Jersey needed to build 21 incinerators. He and his cronies then justified those incinerators using quantitative risk assessments.

Mr. Florio's approach to asbestos was the same: without asking the affected public, he decided that removal of asbestos from 100,000 of the nation's schools was the correct goal, and thus creating a new "asbestos removal" industry was the only reasonable alternative. You can read about Mr. Florio's "Asbestos Hazard Emergency Response Act of 1986" here.

So, the goal ("asbestos removal") was not set through consultation with affected parties. Perhaps if the goal had been to "Eliminate exposures of students and staff to asbestos in schools," a different set of alternatives would have seemed reasonable. Asbestos removal might not have been judged the least-harmful approach.

Even after the questionable decision was made to remove all asbestos from 100,000 school buildings nationwide, systematic monitoring was not done, or not done properly. Furthermore, the decision to remove asbestos was not easily reversible once removal had been undertaken and new hazards had been created.

So Mr. Florio's law created overnight a new asbestos removal industry, companies without asbestos removal experience rushed to make a killing on public contracts, in some cases worker training was poor, removals were carried out sloppily, monitoring was casual or non-existent, and so new hazards were created.

This was not an example of a precautionary approach. It was missing almost all the elements of a precautionary approach -- from goal setting to alternatives assessment, to monitoring, heeding early warnings, and making decisions that are reversible.

Now let's examine President Bush's pre-emptive strike against Iraq.

True enough, Mr. Bush claimed that he had strong evidence of an imminent attack on the U.S. -- perhaps even a nuclear attack. He claimed to know that Saddam Hussein was within a year of having a nuclear weapon. But we now know that this was all bogus. This was not an example of heeding an early warning, because no threat existed -- it was an example of manufacturing an excuse to carry out plans that had been made even before 9/11.

Here is the lead paragraph from a front-page story in the Washington Post April 28, 2007:

"White House and Pentagon officials, and particularly Vice President Cheney, were determined to attack Iraq from the first days of the Bush administration, long before the Sept. 11, 2001, attacks, and repeatedly stretched available intelligence to build support for the war, according to a new book by former CIA director George J. Tenet."

Fully a year before the war began, Time magazine reported March 24, 2003, President Bush stuck his head in the door of a White House meeting between National Security Advisor Condoleeza Rice and three U.S. Senators discussing how to deal with Saddam Hussein through the United Nations or perhaps in a coalition with the U.S's Middle East partners. "Bush wasn't interested," reported Time. "He waved his hand dismissively, recalls a participant, and neatly summed up his Iraq policy:" "F--- Saddam. We're taking him out." This President was not weighing alternatives, seeking the least-harmful.

The CIA, the State Department, members of Congress, and the National Security staff wanted to examine alternatives to war, but Mr. Bush was not interested. With Mr. Cheney, he had set the goal of war, without wide consultation. He then manufactured evidence to support his decision to "take out" Saddam without much thought for the consequences. Later he revealed that God had told him to strike Saddam. Mr. Bush believed he was a man on a mission from God. Assessing alternatives was not part of God's plan, as Mr. Bush saw it.

This was not an example of the precautionary approach. Goals were not set through a democratic process. Early warning were not heeded -- instead fraudulent scenarios were manufactured to justify a policy previous set (if you can call "God told me to f--- Saddam" a policy). As George Tenet's book makes clear again and again, alternatives were not thoroughly examined, with the aim of selecting the least harmful. For a long time, no monitoring was done (for example, no one has been systematically counting Iraqi civilian casualties), and the decision was not reversible, as is now so painfully clear.

This was definitely not an example of the precautionary approach.

So I believe your gratuitous attack on the precautionary principle is misplaced because you bring forward examples that don't have anything to do with precautionary decision-making.

Now I want to acknowledge that the precautionary principle can lead to mistakes being made -- it is not a silver bullet that can minimize all harms. However, it we take to heart its advice to m