by Lois Kleffman, Kentucky Environmental Foundation
(The following is excerpted from "Public Health and Chemical Weapons Incineration" published by the Kentucky Environmental Foundation, March 1998, with funding from the Educational Foundation of America.)
Should we expose children, our most vulnerable population, to toxic chemicals if the exposure can be avoided? Should we build hazardous waste incinerators if alternative technologies with no toxic emissions are available?
The decision to incinerate mustard agent and the organophosphate nerve agents GB and VX, stockpiled at nine US sites, was made by the Army in 1982. Since that decision, chemical weapons incinerators have been built and are in operation at two of the sites--Johnston Atoll in the Pacific and Tooele, Utah. Analyses of the stack releases from the Johnston Atoll incinerator have shown that the products of incomplete combustion emitted into the atmosphere include PCBs, heavy metals, dioxin, dioxin-like compounds and nerve agent from the chemical weapons, plus many other substances, known and unknown, analyzed and not analyzed. Many effects of these emissions were not addressed in the risk assessments for chemical weapons incineration. Federal agencies, including the Army, do not know enough about the long-term effects of chronic exposure to chemical weapons incinerators' emissions, singly and in combination, to assume that the risk of this disposal process is acceptable.
Regulatory agencies in the US presume that toxic chemicals are innocent until proven guilty. Of the 1000 new chemicals that yearly enter commercial markets in the United States, federal agencies have the capability to study only about a dozen. Neither the US government nor anyone else will ever have the capacity to fully evaluate the dangers of the chemicals singly, much less in synergy with each other and the other 80,000 synthetic chemicals already produced. In the past 20 years, regulations have been issued to control only nine new chemicals. Synthetic chemicals are not regulated by federal agencies until they are proven injurious to humans and by then the harm is done. Such was the case with DDT (an organochlorine pesticide) and polychlorinated biphenyls (PCBs), two of the handful of these thousands of chemicals that have been studied in any depth. Due to possible cancer risks, the US restricted most uses of DDT in 1972 and in 1976, banned PCBs production. The regulations came too late--both are persistent in the environment and in human body fat. These toxic chemicals are everywhere and cannot be escaped. They cross placental barriers into women's' wombs. They are in mother's milk, which is rich in fat.
Another persistent chemical compound that has emerged in the past decade as one of the most dangerous chemicals ever tested is dioxin. Unlike DDT and PCBs, dioxin was not intentionally created, but is a by-product of the manufacture of certain chlorine-containing chemicals, the bleaching of paper with chlorine and incineration. Like PCBs and DDT, dioxin is carcinogenic, persistent and transgenerational and can be found almost everywhere. The US Environmental Protection Agency (EPA), in its 1994 Dioxin Health Assessment, reported that adverse health effects may be caused at or near the current background levels of dioxin which are 1-2 orders of magnitude higher than any virtually safe dose that might be calculated. Dr. Richard Clapp, a scientist with the Center for Environmental Studies of the John P. Snow Institute in Boston, Massachusetts, in his review of the EPA's dioxin report, contends that because of existing dioxin levels, our ultimate goal should be zero intake of dioxin and thus the Army's decision to incinerate chemical weapons, which will create more dioxin, is unjustifiable.
Dioxin and PCBs, both emitted from chemical weapons incinerators, in addition to being carcinogens, are known to be hormone disruptors. Hormones are the chemical messengers of the endocrine system that travel through the blood stream, turning on and off bodily processes. When they are disrupted in their functions, damage can be done to almost any system in our bodies. The results of research on the effects of exposure to hormone- disrupting chemicals have shown that such exposures have the most damaging effects on populations at times in their development when their reproductive, immune and central nervous systems are the most vulnerable. For example, the sons and daughters of many of the millions of mothers who took the synthetic hormone DES (diethylstilbestrol) in the 1940s, 50s and 60s have been diagnosed with reproductive cancers. DES' purpose was to prevent miscarriage; its unintended effect was to alter the reproductive systems of the unborn of the women who took it. The reproductive system of the developing fetus is particularly sensitive to hormonal disruption. Like PCBs and dioxin, DES is a synthetic chemical that can cause disruption of the fetal endocrine system and the long-term effects of this disruption can take many forms besides cancer, including high-risk pregnancies, miscarriages, reduction of the quantity and quality of sperm, urethral abnormalities and undescended testicles.
In addition to causing reproductive problems, hormone disruption can impair our immune systems. If the immune system is damaged in certain ways, it can allow pathogens to overwhelm our defenses and make us sick. Under other circumstances, the immune system goes haywire and attacks its host, causing major damage of a different kind, known as "autoimmune" diseases. A third class of immune disorders is allergic reactions, such as asthma, hay fever and food allergies. At least 45% of Americans are living with one or more chronic conditions due to impaired immune systems and recent research has shown that the impairment is caused by low doses of toxic chemicals acting singly or synergistically with other chemicals.
Despite evidence in the EPA's 1994 dioxin report that human reproductive and immune systems, among others, are harmed by low-level exposure to dioxin, the risk assessment for the Tooele chemical weapons incinerator, prepared for the permit process of Utah's Department of Environmental Quality (DEQ), totally ignored non-cancer health effects from the known low levels of dioxin and dioxin-like compounds emitted into the atmosphere through the incinerator's stacks. Ignored also were potential effects of chronic low-level exposure to uncombusted nerve agent that would be emitted through the stacks, especially during upset conditions.
Although evaluation of the potential effects from low-level exposure to chemical warfare agents is complicated because of the agents' high acute toxicity, long-term consequences from low-level exposure have been demonstrated, according to Dr. Robert Ginsburg, Research Director of the Midwest Center for Labor Research in Chicago, Illinois. He cites a study of children in communities near agricultural areas using organophosphate pesticides (close relatives to the organophospate nerve agents) that revealed a pattern of chronic eye problems ranging from reduction of vision to inability to fixate. In researching exposure to low levels of the organophosphate warfare agent VX, Dr. Jerry Buccafusco, Director of the Neuropharmacology Laboratory of the Department of Veterans Affairs Medical Center in Augusta, Georgia, found that after low-level exposure, rats exhibit long-term memory impairment.
Traditionally, animal research on toxic chemicals was done using large doses of a single chemical to determine whether or not the chemical is carcinogenic. However, in recent years, research has gone beyond the cancer paradigm in order to determine the relationship of low doses of toxic chemicals to the development of chronic diseases and the effects of chemicals interacting in combination with each other. Combinations of two and three pesticides have been found to be anywhere from 160 to 1600 times as powerful as any of the individual pesticides. Moreover, it has been found that one chemical by itself (chlordane) shows no hormone-disrupting effects, yet it magnifies the hormone-disrupting power of other chemicals when combined with them.
In the Tooele risk assessment, the possible effects from the interaction of the incinerator's stack emissions in combination with each other and in combination with the 25 tons of chlorine and the two tons of hydrochloric acid released into the air of Tooele County by Magnesium Corporation, the number one toxic polluter in the US, were not taken into consideration.
The interaction of a combination of toxic agents is the probable cause for the chronic illnesses diagnosed in more than 80,000 Gulf War veterans who were exposed to low levels of nerve agent when bunkers of stored chemical warfare agents were blown up in Iraq. Dr. Howard Urnovitz, Scientific Director of the Chronic Illness Research Foundation in Berkeley, California, has found that the veterans' chronic diseases are multi-factorial and multi-step; that they result from the interaction of combinations of chemical agents and can take decades to develop. Veterans of the Gulf War were given live virus vaccines and doses of pyridostigmine bromide before they were deployed. Urnovitz argues that military personnel were at risk before they went to the Gulf because of the toxic chemicals and viruses already present in their bodies. Scientists do not know the exact chemical interaction that has caused Gulf War veterans to become ill, just as scientists do not know what long-term effects could occur from the combination of emissions from chemical weapons incinerators and the 250 or more synthetic chemicals that have accumulated and are carried in our bodies.
Toxic chemicals like dioxin, PCBs and DDT bioaccumulate. Animals eating plants contaminated with synthetic chemicals store the chemicals in their fatty tissue. Bigger animals eat smaller animals and store even more of the chemicals. At the top of the food chain, humans get the biggest dose, inheriting all the toxic chemicals down the line. Children get the biggest dose of all. Especially prior to, or shortly after, birth, children have poorly developed systems for detoxifying chemicals. Children absorb chemicals more efficiently than adults, through their skin, their gastrointestinal tract and their lungs. They take in more calories per pound of body weight compared to adults. The EPA estimates that breast-feeding infants receive up to 12% of their lifetime exposure to dioxin from their mother's breast milk. These factors and others add up to many more toxic exposures for children than for adults.
In spite of these greater risks, Utah's DEQ regulators admitted in court to having intentionally removed breast-feeding infants from the Tooele incinerator risk assessment after they had calculated the dioxin dose for the infant as being 50 times greater than the dose considered safe by the US Agency for Toxic Substances and Disease Registry. Since non-cancer effects from dioxin for all populations were totally ignored in the assessment, non-cancer effects for fetuses, breast-feeding infants and young children were, of course, also ignored. Dr. Peter deFur, Affiliate Associate Professor of Environmental Studies at the Virginia Commonwealth University in Richmond, Virginia, criticizes the assessment and calls it incomplete for not adding the non-cancer risks for all populations, particularly the most vulnerable. DeFur contends that since the fetus is especially sensitive, fetal exposures should have been specifically assessed, just as exposures to breast-feeding infants should have been specifically assessed because of their dioxin intake through mother's milk.
Children are paying a heavy price for our toxic legacy. One out of every four children in the United States now lives with a chronic illness. Childhood cancer has risen 10.8% in the past decade. Asthma deaths among children and young people increased by 118% between 1980 and 1993. Children exposed to PCBs, passed to them by their mothers before birth, exhibit poor reading comprehension, difficulty paying attention and memory problems. We have already impaired the future of our children through the unbridled release of synthetic chemical agents. We must now act to eliminate further exposure both before and after birth. Since the Army's 1982 decision to incinerate, several non-toxins-emitting alternative technologies have been developed and successfully demonstrated to be effective in chemical weapons destruction. The Tooele incinerator risk assessment failed to assess whether the risks of toxic emissions could be avoided and failed to compare the risks of incineration to the risks of other disposal technologies.
Despite the evidence that the assessment inadequately addressed the serious health risks of chemical weapons incineration to children, born and unborn, the Army defended the DEQ incinerator risk assessment in two federal hearings and continued operations at the Tooele facility. The Army has failed to act protectively. To prevent further harm to vulnerable populations, the Army must look to safe alternative technologies, stop the incinerators that are in operation and reverse its plan to incinerate at other sites. In the case of emissions from incineration, as in the case with the release of all toxic chemicals, what we don't know can hurt us. What we didn't know in the past has hurt our children and the cycle must be stopped. No risk is acceptable if it is avoidable.
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