California’s Chemophobic Political Science

Without chemicals life would be damned hard.

Greetings from Chemophobifornia

Alcohol is a chemical, for crying out loud, and without it, many of us find life damned hard. Oh sure, there are other important chemicals too, I suppose. Salt is a chemical and sort of important. Water is a chemical; it’s useful in making beer and wine. Oxygen is a chemical; it’s got my vote for breathing. And Adenosine triphosphate is a chemical that, like beer, without it, life would be damned hard (it’s an energy-carrying compound found in the cells of all living things).

Yep, chemicals are the stuff of life. Yet for many the word “chemical” conjures thoughts of meth labs and industrial factories, even the dictionary says so. A chemical is, “a compound or substance that has been purified or prepared, especially artificially.” The dictionary’s definition must have been written in Chemophobifornia, Land of Proposition 65.

In 1986, we Chemophobifornians passed Proposition 65, “The Safe Drinking Water and Toxic Enforcement Act,” aka, the Lawyer Full Employment Act. The American Council on Science and Health (ACSH) explains what the act was meant to do, “[Proposition 65] was created with the intent of improving public health through reductions in the incidence of cancer and adverse reproductive outcomes that might result from exposure to potentially hazardous chemicals.” ACSH points out the law has not exactly lived up to its purpose, “the law makes no mention of level of exposure, which means that it doesn’t really indicate the level of risk, or indeed if any health risk actually is present from some trace amount of some allegedly toxic chemical.” (italics in original)

Welcome to California, home of chemophobia and flawed risk assessment. Photo source

It is because of the Safe Drinking Water and Toxic Enforcement Act that we have Prop 65 signs in every California Starbucks. Lawyers sued to warn customers that coffee beans at Starbucks—and this is true—have been roasted.

Welcome to the Hotel Chemophobifornia

Disneyland Prop 65 Warning

Prop 65 warning in a grocery store. Photo source

Prop 65 warning on a car window. Photo source

These signs are—excuse my fucking French—fucking everywhere. Hotels, motels, mini-marts, coffee shops, pit stops, fast food restaurants, slow food restaurants, parking garages, gas stations, grocery stores, amusement parks, car dealerships, car repair shops, nursery and hardware stores, nail care, hair care, beauty parlors, massage parlors (I don’t have firsthand knowledge, so to speak, on that one), etc.

“…it’s largely not because the warnings are necessary or meaningful,” food lawyer Baylen Linnekin wrote in a Reason article, “Eat Food and Die”, “but because the state—or even private individuals or their heroic lawyers—can sue those who fail to display these worthless signs.” If it’s a business big enough to be sued, it has a Prop 65 warning sign. These signs stoke cancer fears from chemicals, especially those that sound odd or unfamiliar and faintly ominous to many.

Into this quagmire of cognitive dissonance, step chemophobic special interest groups, purporting to represent the public while quacking pseudoscience. These activist environmental organizations conflate facts into slogans and sound bites to parade them around proudly as though they were scientific fact. Worst of all, these groups have the ears of politicians and bureaucrats in California. California’s fear of chemicals is their foil. Value signaling is their currency.

One of these groups, the Environmental Working Group (EWG—aka the Environmental Worrying Group), applauds California as leading the way in chemically induced fear.

“An analogy might be helpful here,” says ACSH regarding EWG’s messaging technique. “Domesticated dogs come in a huge range of sizes from tiny Chihuahuas to huge Mastiffs. They also come in a huge variety of personalities, from breeds which you could easily trust with a baby to those which have been bred for aggressiveness and which have been known to maim and kill people.  If anti-dog activists were to propose that any dog should be avoided and that people should move to towns that exclude all dogs, most people would dismiss the idea as ridiculous.” So, when your state is recognized by EWG as being progressive and “good,” that’s bad. It means you have been had. Your wallet will be lighter; you’ll be paying more but getting nothing in return.

Josh Bloom—who holds a Ph.D in organic chemistry and is Senior Director of Chemical and Pharmaceutical Sciences at the American Council on Science and Health—has posted the scientific equation that groups such as EWG use:

“Honest discussion of dose = (Less money)2

Be Afraid. Be Very, Very Afraid.

On July 5, 2017 (tomorrow as I write this), California’s State Water Resources Control Board—the California entity that enforces the federal Safe Water Drinking Act (not to be confused with Prop 65, “The Safe Drinking Water and Toxic Enforcement Act,” confused?, that’s exactly what they want you to be)—is scheduled to consider lowering the limit on perchlorate (four oxygen atoms attached to one chlorine atom) because, and this is true, present-day instrumentation is more sensitive. (My open letter to them here)

The ability to detect chemicals at ever lower levels has led to a conflation of hazard and risk. Hazard is the potential thing happening, say water poisoning. Risk is the possibility of this thing happening, you have to drink water (a lot of water).

Here Josh Bloom exposes an exposé on lead levels in baby food by the Environmental Defense Fund:

“EDF‘s analysis of 11 years of FDA data found:

  • Lead was detected in 20% of baby food samples compared to 14% for other foods.
  • Eight types of baby foods had detectable lead in more than 40% of samples.
  • Baby food versions of apple and grape juices and carrots had more samples with detectable lead than the regular versions.

“Source: ‘Lead in food: A hidden health threat. FDA and industry can and must do better.’

“I’ll take it a step further. If we had analytical instrumentation even more sensitive than the incredibly sensitive detectors that now exist, lead would be detected in 100% of baby food, 100% of other foods, and 100% of all apple and grape juice. It’s a damn good thing that instrumentation isn’t more sensitive. Think of how many children would be in danger then.”

I wonder if California’s State Water Resources Control Board knows that “every person and animal that ever lived has an average of about 20,000,000 plutonium atoms in their bone marrow,” Brian Dunning of Skeptoid points out, “simply because we live on this planet.”?

I am sure with sensitive enough equipment, we could find plutonium, one of the most dangerous substances on earth, in our water; I bet that California’s State Water Resources Control Board would go apeshit.

Part 2 soon: Value Signaling Left Turns.















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Industrial Chemicals and the Cancer Epidemic

Welcome to California, home of chemophobia and flawed risk assessment. Photo by the author.

The Sierra Club mulls the question, “Why are so many people getting cancer?” And then, without evidence, answers itself (like homeless guy on the corner), “One reason may be the legal release of millions of pounds of cancer-causing chemicals into our air and waterways.”

Similarly, Rachel Carson asserted that “more American school children die of cancer than from any other disease.” What she said was technically true. However there was not an increase in childhood cancer; there was a decrease in other childhood diseases. In the era Carson was writing people were, at last, spending twice as much on medicines than on funerals. A welcome change from fifty years before when the numbers were the reverse (in 1910, childhood mortality was around 1 in 5; by 1960 it was 1 in 33. and today it is around 1 in 140. In the same way, Rachel Carson used a statistical sleight of hand to show a greater percentage of children, I can say an American male’s lifetime risk of developing cancer is 1 in 2 and 1 in 3 for an American female. It’s true but it’s not the whole story.

The real reasons for the cancer “increase” are more prosaic: medical screening can detect cancer much earlier and people are living long enough to develop cancers because they aren’t dying earlier from other causes. The Mayo Clinic says, “Cancer is caused by changes (mutations) to the DNA within cells. The DNA inside a cell is packaged into a large number of individual genes, each of which contains a set of instructions telling the cell what functions to perform, as well as how to grow and divide. Errors in the instructions can cause the cell to stop its normal function and may allow a cell to become cancerous.”

Because the United States, and the world, has more people, it may appear that more people than ever have cancer. This, in fact, may be true; however, as Ronald Bailey reports, “The cancer death rate has dropped by 23 percent since 1991, translating to more than 1.7 million deaths averted through 2012, according the latest Cancer Statistics 2016 report from the American Cancer Society (ACS).”

Let’s get back to the homeless guy on the corner, I mean, the Sierra Club and its question, “Why are so many people getting cancer?” The American Institute for Cancer Research (AICR) throws cold river water on their answer (the muttering homeless guy did need a bath). The AICR in its 2001 report said, “Exposure to all manufactured chemicals in air, water, soil and food is believed to cause less than 1% of all cancers.”

The overall cancer death rate rose during most of the 20th century, largely driven by rapid increases in lung cancer deaths among men as a consequence of the tobacco epidemic. Steady reductions in smoking, as well as advances in cancer prevention, early detection, and treatment, have resulted in a 23% drop in the cancer death rate, from a peak of 215.1 (per 100,000 population) in 1991 to 166.4 in 2012.

You can take the American Cancer Society’s word about cancer or you can go to the crazy guy on the corner. He always has something to say.

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How do experts determine the safe level of a chemical?

“The main rule in toxicology is that ‘the dose makes the poison’. At some level, every chemical becomes toxic, but there are safe levels below that,” wrote Bruce Ames, who is the creator of the Ames Test which determines if a chemical is mutagenic.

Welcome to California, home of chemophobia and flawed risk assessment. Photo by the author.

A Prop 65 sign in a Starbuck’s Coffee outlet. Photo by the author.

Ames says that in the 1970s the prevailing thinking was that “we should assume that even low doses might cause cancer, even though we lacked the methods for measuring carcinogenic effects at low levels.” The assumption has never left, one need only to look at the ever-present Proposition 65 signs or listen to Vani Hari (aka the Food Babe).

At the time experts also assumed that:

  1.  only a small proportion of chemicals would have carcinogenic potential
  2. testing at a high dose would not produce a carcinogenic effect unique to the high dose; and
  3. carcinogens were likely to be synthetic industrial chemicals.
    It is time to take account of information indicating that all three assumptions are wrong. – Bruce Ames, 2005.  (my emphasis)

Ames points out that our test for carcinogenicity of feeding animals near-fatal doses of the chemical is flawed because, “High doses can cause chronic wounding of tissues, cell death, and consequent chronic cell division of neighboring cells, which would otherwise not divide.”

How should a “safe” level be arrived at?

The basic steps to arriving at a safe level are:
  1. Determine a Point of Departure:

    This means to review the scientific data available on the toxicity of a compound and select the most sensitive endpoint. So if a chemical causes liver toxicity at a concentration of 1 mg/kg, kidney toxicity at 50 mg/kg and stomach ulcers at 0.1 mg/kg – the 0.1 mg/kg would be selected as the point of departure because if you pick a concentration that prevents stomach ulcers, you will by design also protect against the liver and kidney toxicity (because you need higher concentrations of the chemical to cause those). Furthermore, typically you are looking to pick a NOAEL (No Observable Adverse Effect Level) as a Point of Departure (POD), as this is the highest concentration of a “substance at which there are no biologically significant increases in frequency or severity of any effects in the exposed humans or animals.” (International Council on Harmonisation, 2011)

2. Determine how many modifying factors or uncertainty factors you should use.

The International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH) appendix 3 gives examples of the modifying factors to use, depending on what kind of study was conducted to determine the POD. Modifying (or uncertainty) factors provide a cushion to human exposure based on factors like which animal was used for the study, the duration of the study and whether the POD is a “No Observable Adverse Effect Level” (NOAEL) or LOAEL.

The “safe” level is really a concentration that would be highly unlikely to cause an adverse effect in even the most sensitive individuals. Using the modifying factors (in step 2 of appendix 3), this concentration results in a very conservative value. These “safe” levels are referred to as PDE (Permissible Daily Exposure), ADI (Acceptable Daily Intake), RfD (Reference Dose) and other things depending on the agency that is generating them, but they all mean the same thing: the level that would not be expected to produce an adverse effect. These values are expressed as either mg/day (where an adult body weight of between 50 and 70 kg is used as a “typical” body weight) or expressed as mg/kg body weight/day.

That’s it. The equations used, and the modifying factors suggested also differ slightly between agencies, but the general concept remains the same.
So when a safe level is determined by toxicologists using best available science, and regulators arbitrarily increase the safety factors, Schnell correctly notes, “the general public commonly misinterprets those bureaucratically generated ‘safe’ levels of exposure as legitimately established thresholds of effect…”
As Frank Schnell, who is a Board Certified PhD in Toxicology, explained, “If you’re standing near the rim of the Grand Canyon admiring the view, you’re probably safe. Nevertheless, as improbable as it is, it’s not entirely impossible that a very strong gust of wind might blow you over the edge. To make sure that you were safe, even under very windy conditions, you could step back ten paces or so–that’s what regulators call a ‘safety factor.’ But, to imagine that stepping back 100 paces, or even a mile, would make you even more safe under implausible conditions (a tornado?) would be not only misguided, but counterproductive, as well, because then you couldn’t see the Grand Canyon, at all.”


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