The government is now under attack for listing chemicals that cause cancer. Apparently it’s bad for business. Keep in mind that chemicals that cause cancer will keep on doing so whether the government lists them or not. But, without getting listed, people, including workers, may not know to protect themselves. Isn’t killing workers also bad for business? It’s certainly a bad way to do business!
The listing I’m talking about is in the government’s Report on Carcinogens (ROC), issued every second year (biennially) by the National Toxicology Program (NTP), a part of the National Institute for Environmental Health Sciences (NIEHS). This is a good example of our government dollars hard at work to help consumers, communities, and workers to be better informed about how to prevent cancer and promote health. Congress first mandated the Report in 1978.
This week the House Committee on Science is hosting a hearing titled, “How the Report on Carcinogens Uses Science to Meet its Statutory Obligations, and its Impact on Small Business Jobs” (details here). In other words, it’s a Congressional hearing to amplify chemical industry talking points and grill government scientists. The chemical industry has long had the same position: the public’s right to know about toxic chemicals – both their effects, and their releases – will unnecessarily frighten the public, and lead to a push for use of safer chemicals, or non-chemical alternatives, which will result in a loss of jobs in the cancer-causing chemical sector. The argument puts the interests of narrow segments of the chemical industry – such as formaldehyde and styrene manufacturers – ahead of public health, and ahead of a fully functioning market where information is available and consumers are able to make their choices based on that information. Obviously, that is not a very winning argument with the public, which is why the chemical industry and House Republicans are dressing it up as a supposed inquiry into the credibility of the process government scientists have used to reach the conclusion that formaldehyde is a known human carcinogen, and that styrene is “reasonably anticipated to be a human carcinogen.”
The science staff that develops the Report on Carcinogens conducts extensive reviews of the scientific literature, multiple peer reviews, and provides multiple opportunities for public comment, and review by its Board of Scientific Counselors (BOSC) which includes industry, government, and academic scientists (process details are here). This rigorous, transparent, and exhaustive scientific process results in short easy-to-read summaries of the science that supports the chemicals that are listed in the ROC. The ROC only lists chemicals that are either “known” or “reasonably anticipated” to cause cancer in humans.
The chemical manufacturers and their experts-for-hire make some specific attacks on the ROC (read them here) which I’d like to address below:
1) The chemical industry says that the ROC is redundant with assessments conducted by the EPA (the IRIS program) and by ATSDR (the ToxFAQs program), and sometimes these other government hazard assessments are not in perfect agreement, causing confusion among the public. Therefore ROC and the other programs should be consolidated or eliminated.
In contrast to the EPA and the ATSDR programs, the ROC program is based out of one of the National Institutes of Health, and is designed to be purely scientific, not regulatory. As a result, the ROC doesn’t determine safety thresholds or any other kind of numerical limit on the chemicals it assesses. Instead, the program is designed purely to perform the most thorough and authoritative scientific assessment of the evidence of whether a chemical does or does not cause cancer. When industry attacks this it is attacking the latest science. But, the cancer risks won’t go away by silencing the science or the ROC.
2) The chemical industry says the ROC only considers the positive studies that find cancer, rather than the overall ‘weight of evidence’, which would also consider studies that do not find an effect.
The chemical industry is flat-out wrong on this point. They are conflating the final brief written cancer summaries with the process that leads up to those summaries. The fact is that when NTP is putting together the ROC they do review all the studies – including both those that find cancer, and those that don’t. In many cases, the staff or peer reviewers conclude that the overall evidence does not support listing a chemical as a carcinogen, so it does not end up in the ROC. Once there is agreement that a chemical is a carcinogen and should be listed in the ROC, the final summaries are fairly short – just a few pages - and emphasize the most informative and highest quality science that supports the final listing decision. Including every possible study in the final write-up on a chemical would make the report hugely long and unreadable for most people. Perhaps that’s what the chemical industry wants.
3) The chemical industry says that it is wrong to accept cancer data (for example epidemiology evidence from workplace studies) if the mechanism that explains why that chemical causes cancer cannot be fully explained.
The fact is that understanding how a chemical causes cancer often comes much later than the evidence that it does so, and in many cases we still don’t know how a chemical causes cancer - but the scientific evidence shows that it does. For example, we have study after study showing that people that are exposed to formaldehyde are at higher risk of leukemia – studies from thousands of workers in different occupations across multiple countries. Are we supposed to ignore all those people with leukemia just because we cannot fully explain (on a molecular level) how it is happening? The formaldehyde industry is asking us to ignore the obvious evidence that is right in front of our eyes. There are many other examples: We still don’t know exactly how lead damages kid’s brains, but we know it does and we banned lead from house paint in 1978 and from gasoline in 1986. Congress banned PCB’s long before scientists understood how they caused cancer. Since then we’ve learned more about the mechanism, but if we’d waited then lots more kids would have had permanent lead-induced brain damage and more people would have had PCB-related cancer. There is still controversy about how smoking kills, but we don’t allow smoking in public places. Industry is making a dangerous and insidious argument consistent with its historical and current efforts to cover up evidence of harm caused by its deadly products (for documented examples see Doubt is Their Product by David Michaels).
4) The chemical industry says that the ROC should allow more opportunities for public (i.e. industry) comment, and should have to respond to each of the public’s comments, and allow the Board of Scientific Counselors (BOSC) to have final say over the ROC.
The fact is that the new process for preparation of the ROC has six public comment opportunities, including both the submission of written comments and in-person comments at public meetings. BOSC itself didn’t want to be a final decisive voice on the ROC listings because it felt that it did not have deep enough chemical-specific expertise. Moreover, the BOSC reviewed the new process and generally agreed with it, so industry’s request has already been considered and rejected by the scientific expert committee. The truth is that this process is already public-commented to death. In practice, industry submits the same set of comments over and over again, at least on their priority (read: lucrative) chemicals. How many opportunities do they need to reiterate the same old arguments? The ROC staff and BOSC rejected industry’s request for even more needless rounds of comment as a blatant delay tactic. Letting the chemical industry argue forever will not lead to better science.
In conclusion, the ROC process is a model for how to summarize the state-of-the-science on chemicals and cancer. It lays all the information out for public scrutiny and comment, evaluates the quality of the data, and says exactly how it will come to a decision to list or not to list the chemical under review. The truth is that this effort by the chemical industry to attack the ROC and tie its process up in knots is part of its larger goal of defending its toxic products by silencing the evidence of harm.
I released a report recently called The Delay Game that outlines a frequent industry defense routine we call the Four Dog Defense. 1) My dog (product) doesn’t bite, 2) My dog bites, but it didn’t bite you, 3) My dog bit you, but it didn’t hurt you, and 4) My dog bit you, and hurt you, but it wasn’t my fault. The chemical industry is attacking the ROC and other government assessments of toxic chemicals in the hopes of shutting down evidence that its dog bites. But, the dog keeps biting, and people who are exposed to these chemicals keep getting sick. The truth hurts!