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A Small Dose of Toxicology Beyond Risk Assessment to Precautionary Precautionary Assessment Getting Out of the Risk Assessment Box: Precautionary Approaches for Public Health (Critical Analysis of Risk Assessment & Alternative Approaches) How Chemicals Affect Your Health Steven G. Gilbert, PhD, DABT A Small Dose of Toxicology www.asmalldoseof.org www.toxipedia.org Beyond Risk Assessment to Precautionary Risk Assessment "We should remember that risk assessment data can be like the captured spy: If you torture it long enough, it will tell you anything you want to know." (William Ruckelshaus -1st administrator of U.S. EPA 1984.) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Outline Risk Assessment – Arbitrary and Capricious Vision and Ethics Principles of Risk Assessment Risk Assessment - examples Weaknesses of Risk Assessment Beyond Risk Assessment to Precautionary Assessment A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Vision for Child Health “Children can develop and mature in an environment that allows them to reach and maintain their full potential.” A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Human & Environmental Health “Conditions that ensure that all living things have the best opportunity to reach and maintain their full genetic potential.” S. Gilbert (1999) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Socially responsible white guys? A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 The First Bioethicist Aldo Leopold "A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise." Aldo Leopold, 1949, A Sand County Almanac ---------- 1887 - 1948 ---------A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Limits on Freedom “An ethic, ecologically, is a limitation on freedom of action in the struggle for existence” Aldo Leopold A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 “The Commons” The Tragedy of the Commons By Garrett Hardin, Science, 1968 A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Technical Solutions “It is our considered professional judgment that this dilemma has no technical solution.” The Tragedy of the Commons By Garrett Hardin, Science, 1968 A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Problems – Solutions? A Small Dose of Toxicology Lead and kids Fetal alcohol syndrome Nuclear disarmament Bioterrorism Ocean Fisheries Persistent chemicals The Commons Beyond Risk Assessment to Prec – 09/19/07 Sir Austin Bradford Hill "All scientific work is incomplete - whether it be observational or experimental. All scientific work is liable to be upset or modified by advancing knowledge. That does not confer upon us a freedom to ignore the knowledge we already have or postpone the action that it appears to demand at a given time. " Sir Austin Bradford Hill (1965) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Determining Causation 1. 2. 3. 4. 5. 6. 7. Strength of association Consistency of findings Biological gradient Temporal sequence Biologic or theoretical plausibility Coherence with established knowledge Specificity of association Sir Austin Bradford Hill (1965) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Principle “When an activity raises threats of harm to human health or the environment, precautionary measures should be take even if some cause and effect relationships are not fully established scientifically.” Wingspread Conference, 1998. A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Central components • Setting goals (Health indicators) • Taking preventive action in the face of uncertainty • Shifting the burden of responsibility to the proponents of an activity (Who benefits?) • Exploring a wide range of alternatives to possibly harmful actions (Is it necessary?) • Increasing public participation in decision making (transparency of information & environmental justice) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Key Words of Toxicology Dose / Response Hazard X Exposure = Risk Individual Susceptibility A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Modern Risk Assessment Developed in 1960-1970s Concern over increased cancer rates Expanded to non-cancer effects A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Perspective "If someone had evaluated the risk of fire right after it was invented, they may well have decided to eat their food raw." Julian Morris of the Institute of Economic Affairs in London A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Quantitative Risk Assessment Process of estimating association between an exposure to a chemical or physical agent and the incidence of some adverse outcome. National Research Council, Risk Assessment in the Federal Government: Managing the Process. National Academy Press, Washington, DC, 1983 A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Steps in Risk Assessment Hazard Identification Exposure Assessment Dose-Response Assessment Risk Characterization A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 What Hazard? Obvious Death, Cancer, Acid burn, Birth defect, asthma ….. Subtle Decreases in learning and memory (lead) Loss of potential Sensitivity of the individual (child) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Hazard Identification Review human and animal data to determine if a chemical or agent has biological effects. A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Toxicity Endpoints Carcinogenicity Mutations Altered immune function Teratogenicity Altered reproductive function Neuro-behavioral toxicity Organ-specific effects Ecological effects (wildlife, environmental persistence) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Exposure Assessment Route of exposure (skin, oral, inhalation) Amount of exposure (dose) Duration of exposure To whom (animals, humans, environment) Children, other sensitive individuals A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Exposure Issues • • • • • • Home environment Workplace (occupational) School Food Consumer products Global and local environment A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Dose-Response Assessment How much exposure to a chemical or agent will cause what effect? Dose – Response A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Some Jargon LOAEL – Lowest Observed Adverse Effect Level (mg/kg) NOAEL – No Observed Adverse Effect Level (mg/kg) RfD – Reference Dose (mg/kg-day) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Response Greater Dose – Greater Response ED50 Threshold (NOAEL) LOAEL Dose A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Risk Characterization Risk = Hazard X Exposure Hazard (including sensitive populations) –Low dose extrapolation Exposure – Route of exposure, amount, duration • dermal, oral, inhalation, injection – To Whom? Sensitive Individuals? A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Use of Uncertainty Factors Divide Dose by Power of 10 • Human variability • Interspecies extrapolation • Children • Subchronic to chronic extrapolation • Absence of a NOAEL • Database uncertainty A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Human Variability Human Subject Variability • • • • • Lifestyle – risk of exposure to …. Occupation – risk of exposure to …. Breathing & digestion – uptake of chemicals Metabolism & kidney function – elimination Age, gender & disease – susceptibility to toxicity • Socio/economic facts A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Doubt / Uncertainty "Doubt is our product since it is the best means of competing with the 'body of fact' that exists in the mind of the general public.“ 1969 an executive at Brown & Williamson owned by R. J. Reynolds Tobacco Company (Doubt Is Their Product by David Michaels in Scientific American, June 15, 2005) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Use of Uncertainty Factors Animal Dose Response Data NOAEL (No Observed Adverse Effect Level) or LOAEL Divide by 10 (Account for inadequate animal data) Divide by 10 (Animal to Human Extrapolation) Divide by 10 (Human Variability or Individual Sensitivity) Reference Dose (RfD) Or Acceptable Daily Intake (ADI) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Mercury & Toxicology A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 The Mercury Cycle A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Atmospheric Hg A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Neurobehavioral Effects • Blindness - Deafness • Cerebral Palsy - Seizures • Abnormal reflexes & muscle tone • Retarded motor development • Visual and Auditory Deficits • Delayed motor development • Human and animal data A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Effects On The Brain Decrease in Brain Size Cell loss Disorganization of cells Cell migration failures Behavioral effects – learning and memory A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Fetal Effects of MeHg A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Animal - Risk Assessment MONKEY - 25 µg/kg - LOAEL RAT - 10 µg/kg - LOAEL RAT - 50 µg/kg - replicated A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Animal - Risk Assessment 2.5 µg/kg - NOAEL (animals) 0.25 µg/kg - Human 0.025 µg/kg - Sensitive populations (the rule of dividing by 10) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Human - Risk Assessment • 10-20 ppm hair - LOAEL • • 40-80 ppb blood - LOAEL • • 0.645 µg/kg • • 0.06 µg/kg - RfD • Gilbert, S.G., and Grant-Webster, K.S. Neurobehavioral effects of developmental methylmercury exposure. Env. Health Persep. 103(Suppl 6), 135-142, 1995. A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 MeHg Consumption Limits US EPA – 0.1 ug/kg-day US FDA – 1 ppm (mg/kg) in tuna A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Ancient Awareness "Lead makes the mind give way." Greek Dioscerides - 2nd BC A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Agency Blood Lead Levels Acceptable Childhood Blood Lead Levels Blood Lead (ug/dl) 60 60 50 40 40 30 30 25 20 20 15 10 10 2 0 CDC CDC 1960 1973 CDC CDC WHO EPA 1975 1985 1986 1986 CDC CDC 1990 2006? Agency and Year A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Recycling Lead A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Limitations of Risk Assessment Lack of adequate data Most sensitive endpoint Low dose extrapolation Exposure information Multiple chemical exposures Complex – expert driven – undemocratic Individual sensitivity Narrow perspective – Ethical?? A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Assessment An approach to evaluating the scientific, safety, community, ethical, and social issues related to a compound or procedure. Community / Social Issues Exposure Issues Hazard / Toxicity A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Assessment Community / Social Issues G = Goal N = Need F = Future Generations D = Democratic, community based process A = Alternatives A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Assessment Initial G N F D A Parameter Score Comment Community / Social Issues Evaluate effects on the community and related social issues. G=Goal 1-3 1-a lot, 2-some, 3-little. Does this move forward the goal of human and environmental health? 1-3 1-a lot, 2-some, 3-little or not sure. Ask the question: Is it necessary? Do we really need this? 1-3 1-little, 2-some, 3-high impact. Is there a potential impact on future generations of humans and other species? 1-3 1-a lot of community involvement and consultation, 2-some, 3-little. Was the community consulted early and often in the process? Was the process democratic and inclusive. 1-3 1-alternatives were carefully considered, 2-some consideration, 3-no consideration. Where alternatives considered? 5-15 5-good, supportive of health and community 15-poor, not supportive of health or community N=Need F=Future Generations D=Democratic, community based process A=Alternatives Total A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Assessment Exposure Issues E = Exposure M = Multiple exposures Ch = Children exposed CP = Consumer products O = Occupational exposure F = Food exposure A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Assessment Exposure Issues Evaluate potential exposure issues. E E=Exposure 0-3 0-none, 1-little, 2-some, 3-high. Do we have control over the exposure? M M=Multiple exposures 0-3 0-none, 1-little, 2-some, 3-high. Is there exposure to other chemicals with similar hazard? Ch Ch=Children exposed CP CP=Consumer products O O=Occupationa l exposure F F=Food exposure Total A Small Dose of Toxicology 0,3,5 0-none, 3-little, 5-some or high or don't know. Children are often more vulnerable. Are children being exposed. 0-3 0-not in consumer products, 1-little, 2-some, 3- a lot or do not know. Is this compound in consumer products? 0-3 0-no occupational exposure, 1-little, 2-some, 3- a lot or do not know. Is there occupational exposure? 0-3 0-not in food supply, 1-little, 2-some, 3- a lot or do not know. Is the compound present in the food supply. 0-20 0-no exposure, no problems 20-significant exposure, serious concern Beyond Risk Assessment to Prec – 09/19/07 Precautionary Assessment Hazard / Toxicity H = Hazard IS = Individual Sensitivity EC = Ecological hazard UC = Uncertainty V = Volume P = Persistent A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Assessment Hazard / Toxicity Evaluate potential hazards. H H=Hazard 1-low, 5-some, 10-high. Follow classical hazard evaluation, pick endpoint, exam relevant quality studies (cancer, reproductive, neurotoxicity, irreversible) IS IS=Individual Sensitivity EC EC=Ecological hazard V V=Volume 1,5,10 1-3 1-little 2-some, 3-a lot. Determine if any individuals are more sensitive than health adult such as the very young or old. 1-3 1-little 2-some, 3-a lot. Is it a hazard to other species or the environment? 1-5 how much is produced (1=research only, 2=<1000 lbs, 3=<10,000, 4=<100,000, 5=>100,000 or do not know) 1-3 1-little persistence 2-some, 3-a lot of persistence or do not know. Is the compound presistent in the environment? P P=Persistent B B=Bioaccumul ate 1-3 1-little 2-some, 3-a lot. Does it bioaccumulative in humans or animals or move up the food chain? UC UC=Uncertaint y 1-3 1-little 2-some, 3-a lot. How certain is the information? 7-30 7-low hazard 30-significant hazards or unknowns, serious concern Total A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Assessment Lead Community / Social Issues - 12/15 Exposure Issues – 16/20 Hazard / Toxicity – 27/30 A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Rights and Policy • We have a right to an environment in which we can reach and maintain our potential • A matter of POLICY not Risk Assessment A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Precautionary Principle “When an activity raises threats of harm to human health or the environment, precautionary measures should be take even if some cause and effect relationships are not fully established scientifically.” Wingspread Conference, 1998. A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Central components • Setting goals (Health indicators) • Taking preventive action in the face of uncertainty • Shifting the burden of responsibility to the proponents of an activity (Who benefits?) • Exploring a wide range of alternatives to possibly harmful actions (Is it necessary?) • Increasing public participation in decision making (transparency of information & environmental justice) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 WSPHA 2006 Resolutions The Washington State Public Health Association (WSPHA at www.wspha.org) unanimously adopted two important resolutions at the 13th Annual Washington State Joint Conference on Health that addressed human health and the environment. “Endorsing the Precautionary Principle as a Public Health Tool for Preventing Harm from Persistent Bioaccumulative Toxic Chemicals (PBTs)” Resolved that - “The WSPHA endorses the precautionary principle as a vital component of our preventive approach to public health in Washington State, advancing the goal that all people have an opportunity to reach and maintain their full potential.” A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 WSPHA 2006 Resolutions “Supporting Safer Chemicals Policies to Benefit Human and Environmental Health”. This resolution addressed the need to 1) reduce exposure to PBTs, 2) encourages development and use of safer, cost-effective alternative products, materials, and processes, 3) development of ‘green chemistry’, and 4) provide full information on the health effects of all chemicals placed into the marketplace. A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Seattle Initiative City Comprehensive Plans • Every citizen of Seattle has an equal right to a healthy and safe environment. • Seattle sees the Precautionary Principle approach as its policy framework to develop laws for a healthier and more just Seattle. • Seattle Precautionary Principle White Paper (www.asmalldoseof.org) Seattle PP working group – CHE-WA A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Asthma & Diabetes Survey Measures of Percent Ever Having Had Asthma and Diabetes Diagnoses, Seattle, 19942002 14.0 asthma weighted percent of survey respondents 12.0 10.0 8.0 6.0 diabetes (excluding during pregnancy) 4.0 2.0 Data Source: Behavioral Risk Factor Surveillance System, Washington State Department of Health and Centers for Disease Control Prepared by: Public Health- Seattle & King County, EPE, 5/04 0.0 1994 1995 A Small Dose of Toxicology 1996 1997 1998 1999 2000 2001 2002 Beyond Risk Assessment to Precautionary Overweight & Obese Survey Measures of Percent Overweight and Obese, Seattle, 1994-2002 70.0 60.0 weighted percent of survey respondents overweight 50.0 40.0 30.0 20.0 obese 10.0 Data Source: Behavioral Risk Factor Surveillance System, Washington State Department of Health and Centers for Disease Control Prepared by: Public Health- Seattle & King County, EPE, 5/04 0.0 1994 1995 1996 1997 1998 1999 2000 2001 2002 year A Small Dose of Toxicology Beyond Risk Assessment to Precautionary Conclusion The Precautionary Principle is part of the evolution in our thinking and decision making toward ensuring human and environmental health. A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Estimated Costs - National Estimated Costs of Pediatric Disease of Environmental Origin, United States,1997 (billions) Lead Poisoning Asthma Cancer Neurobehavioral Disorders TOTAL Best Estimate Low Estimate High Estimate $43.4 $43.4 $43.4 $2.0 $0.3 $9.2 $0.7 $0.2 $4.6 $2.3 $0.7 $18.4 $54.9 $48.8 $64.8 (From “Environmental Pollutants and Disease in American Children,” Landrigan, Schechter, et.al., 2002) A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Estimated Costs - Washington Diseases and disabilities (asthma, cancer, lead exposure, birth defects, and neurobehavioral effects) attributable to environmental contaminants. Disease/Disability (2004 $ million) Best Direct Indirect Range Estimate Costs Costs $1,600Childhood $1,875 $310.6 $1,565 $2,200 Adult & $2,800child $2,734 $782.1 $1,953 $3,500 Kate Davies Economic costs of diseases and disabilities attributable to environmental contaminants in Washington State. Antioch University Seattle 2005. http://washington.chenw.org/pdfs/EnvironmentalCosts.pdf A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Characteristics of Risk Characteristic Knowledge Newness Voluntariness Control Dreadedness Catastrophic potential Equity Level Little known Much known Old New Not voluntary Voluntary Not controllable Controllable Little dread Great dread Not likely Likely Distributed Undistributed Adapted from Kraus and Slovic (1988), Risk Anal., 8: 435. A Small Dose of Toxicology Examples Food additives Alcoholic drinks Guns Space travel Crime Rock climbing Natural disasters Smoking Vaccination Nerve gas Sunbathing War Skiing Hazardous dump Beyond Risk Assessment to Prec – 09/19/07 Risk Perceptions Unknown w DNA Research Nuclear Power w w Herbicides Pesticides w Little Dread w Anesthetics w Power Tools Alcohol w w Motor vehicles A Small Dose of Toxicology Asbestos Known Knowable Newness Lack of scientific knowledge Exposure is unknown/unknowable w w Food coloring Saccharin w Microwave ovens w w Aspirin Dreaded w Smoking Dread Catastrophic potential Involuntariness Personal risk Inequity w Dynamite w Warfare w Handguns Beyond Risk Assessment to Prec – 09/19/07 The Potential of Children A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Additional Information National Research Council, Risk Assessment in the Federal Government: Managing the Process. National Academy Press, Washington, DC, 1983 World Health Organization - The International Programme on Chemical Safety (IPCS) – Risk Assessment –http://www.who.int/pcs/ra_main.html U.S. Environmental Protection Agencies National Center for Environmental Assessment (NCEA) – http://cfpub.epa.gov/ncea/ A Small Dose of Toxicology – Risk Assessment - http://www.asmalldoseof.org/toxicology/risk_assessment.php A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07 Risk Assessment A Small Dose of Toxicology Beyond Risk Assessment to Prec – 09/19/07