Rachel's Precaution Reporter #64

"Foresight and Precaution, in the News and in the World"

Wednesday, November 15, 2006.........Printer-friendly version
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Table of Contents...

Brescia Declaration on Prevention of the Neurotoxicity of Metals
  A group of eminent scientists has called for worldwide reductions
  in exposure to toxic lead, mercury and manganese. They recommend that
  the U.S. cut its lead standard for children by half.
Scientists Say Pollution Is Harming Children's Brains Worldwide
  Scientists from Holland and the U.S. have identified 202 industrial
  chemicals with the potential to damage the human brain and these
  are likely to be the "tip of a very large iceberg," they say
Chemical Industry Advice on How To Oppose Precaution
  The chemical industry is conducting a worldwide campaign opposing
  the precautionary principle. Here is one of the industry's most recent
  strategy papers.
Chemical Industry Says Exposure To Pesticides Benefits Children
  The chemical industry wants to halt a trend sweeping the
  nation that is reducing children's exposure to chemical pesticides
  in schools. Here is some of the industry's reasoning.


From: American Journal Of Industrial Medicine, Nov. 14, 2006
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By Philip Landrigan and others**

On 17-18 June, 2006, the Scientific Committee on Neurotoxicology and
Psychophysiology and the Scientific Committee on the Toxicology of
Metals of the International Commission on Occupational Health (ICOH)
convened an International Workshop on "Neurotoxic Metals: Lead,
Mercury, and Manganese -- From Research to Prevention (NTOXMET)" at
the University of Brescia [Brescia, Italy]. Scientists and physicians
from 27 nations participated.

Data were presented for each of the three metals on environmental
sources, fate and distribution; human exposure; clinical, subclinical,
and developmental neurotoxicity; epidemiology; risk assessment; and
prospects for prevention. Ongoing and future studies were described
and discussed.

For each of the metals, initial recognition of neurotoxicity occurred
in the context of high-dose exposure. For example, lead poisoning was
first recognized in miners, smelters, and type setters, methylmercury
poisoning in inhabitants of the fishing community of Minamata, and
manganese poisoning in miners and ferroalloy workers. Subsequent
development of more sensitive and sophisticated analytical instruments
led to the recognition of subclinical toxicity [toxicity without overt
symptoms] and developmental neurotoxicity at progressively lower
levels of exposure. In each case, the extent of toxicity was much
greater than initially appreciated and the size of the affected
population much larger. Many decades typically elapsed between the
initial recognition of neurotoxicity and the initiation of programs
for prevention. Early warnings were frequently ignored and even
actively resisted.

The historical observation that long delays had typically elapsed
before the initiation of prevention prompted extensive discussion at
the Workshop about the need to develop more effective strategies. From
this discussion, a series of recommendations emerged on future
directions for research and prevention of the neurotoxicity of metals.

At the closing session of the International Workshop at Brescia, the
following recommendations on the prevention of the Neurotoxicity of
Metals were adopted by consensus:

Intensified attention must be paid to early warnings of neurotoxicity.
Clinical observations or toxicological data suggesting the existence
of neurotoxicity including subclinical and developmental toxicity must
be taken very seriously. Such observations should prompt consideration
of prudent preventive action.

All uses of lead including recycling should be reviewed in all nations
and uses contributing to environmental and human exposures, such as
uses in toys, paint, water pipes, building materials, solder,
electronics, medications, and cosmetics ended. The transfer of these
products from one country to another should also be avoided. This
approach has been adopted successfully in the EU and needs to be
extended worldwide.

In particular, tetraalkyllead must be eliminated without delay from
the gasoline supplies of all nations. The removal of organic lead from
gasoline has produced declines of greater than 90% in population mean
[average] blood lead levels in industrially developed nations, and
this success is now being repeated in some of the developing nations.
This action represents one of the great public health triumphs of the
late 20th century and needs urgently to be extended to all nations.

Current exposure standards for lead need urgently to be reduced.
Current standards were established many years ago and do not reflect
recent advances in scientific knowledge about toxic effects at levels
of exposure below these standards. The Brescia Workshop recommends

* For children, the action level, which triggers community prevention
efforts to reduce exposure sources, should be immediately reduced to a
blood lead concentration of 50 ug/L [50 micrograms/Liter = 5
micrograms per deciLiter] in nations worldwide. This level is proposed
as a temporary level that may need to be revised further downward in
future years as new evidence accumulates on toxicity at still lower
blood lead levels. This reduction of the blood lead action level will
reduce the incidence of subclinical neurotoxicity in children as well
as the delayed consequences of developmental toxicity.

* For industrial workers, the standard for lead in blood should be
reduced immediately to 300 micrograms/Liter in nations worldwide.
Additional consideration should be given to further reducing this
standard to 200 micrograms/Liter and below in the years ahead. This
reduction in exposure standard will reduce the incidence of
subclinical neurotoxicity and other toxic effects during the working
life and responds to new documentation presented at the Workshop that
long-term lead exposure increases the risk of dementia in later life.

* For female industrial workers of reproductive age, the standard for
lead in blood should be reduced immediately in nations worldwide to
the lowest obtainable, preferably to 50 micrograms/Liter [= 5
micrograms/deciLiter], a level consistent with the recommended blood
lead standard for children. Lead passes freely across the placenta
from the maternal to the fetal circulation to enter the developing
brain where it causes prenatal brain injury. This recommended
reduction in maternal lead exposure will reduce the incidence of fetal
neurotoxicity in the offspring of women workers.

Exposures of pregnant women and women of reproductive age to
methylmercury need to be reduced to prevent subclinical fetal
neurotoxicity. Evidence is strong that prenatal exposure to
methylmercury causes fetal neurotoxicity. Consumption of fish with
high mercury concentration by pregnant women is the primary route of
exposure. More than 50% of the mercury in fish may be of industrial

Strategies for reducing mercury exposure recommended by the Brescia
Workshop are the following:

* All industrial uses, recycling processes, and other industrial input
of mercury into the environment should be reviewed in all nations, and
non-essential uses should be eliminated and releases controlled. This
approach has been successfully introduced in the EU and is actively
promoted by the United Nations Environmental Programme.

* Mercury emissions from coal-fired power plants need to be curtailed.

* All chloralkali plants worldwide should be urgently converted to
alternative technologies that are not based on mercury, and mercury
stores and wastes must be safely deposited.

* Gold mining with mercury must be controlled and enforced with safety
guidelines, and alternative technology should be promoted.

* Dietary advisories should be developed as effective, culturally
appropriate means to limit childbearing women's consumption of fish
contaminated with methylmercury. Taking into account nutrient contents
and availability, healthy diets should be recommended with fish and
seafood containing minimal levels of contamination.

Exposures of pregnant women and young children to manganese need to be
reduced to prevent subclinical neurotoxicity. Important new data on
the neurotoxicity of manganese were presented at Brescia. In adult
workers, these data suggest that manganese produces subclinical
neurotoxicity at levels of exposure below those that produce
parkinsonism. In children, evidence from two recent epidemiological
studies suggests that exposure to manganese in early life causes
subclinical developmental neurotoxicity.

The addition of organic manganese compounds to gasoline should be
halted immediately in all nations. The data presented at the Brescia
Workshop raise grave concerns about the likelihood that addition of
manganese to gasoline could cause widespread developmental toxicity
similar to that caused by the worldwide addition of tetraalkyllead to
gasoline. In light of this information, it would be extremely unwise
to add manganese to gasoline.

Exposure standards for manganese need to be reconsidered. The drinking
water standards for manganese in many countries are not based on
health concerns, and those that are, do not protect against
developmental neurotoxicity resulting from exposures in utero and in
early postnatal life. The current occupational exposure standard may
not protect workers against subclinical neurotoxicity. The value for
air manganese concentration in inhalable/total dust of 100 mg/m3
should be adopted to protect the workers from prolonged exposure and
consequent long-term effects.

Economic impacts of the neurotoxicity caused by metals must be
considered. The costs of toxicity may be far greater than the costs of
pollution control. The major contributor to these costs is damage to
the developing central nervous system. Such injury can result in
lifelong loss of intelligence and motor capacities, permanent
psychological disturbances, and disruption of behavior. These effects
can produce reduction of economic productivity, and when this
reduction occurs widely across a society, the resulting economic
impacts are great. The costs of pollution recur annually in each
exposed birth cohort, adults, and elderly while the costs of control
are one-time costs. Need is great for continuing research into the
neurotoxicity of metals. Recent studies of neurotoxicology of each of
the metals discussed at the Brescia Workshop inform us that we can
anticipate harmful effects of increasingly lower levels of exposure to
metals, previously f. considered safe as larger studies using
sensitive measures of exposure and outcome, and better statistical
techniques are conducted.

a. For lead, mercury, and manganese, much remains to be learned about
the delayed consequences of developmental toxicity and the prolonged
exposure to low levels in the adults, as possible causes of
neurodegeneration. This research is critical to guide both future
research in metals as paradigms of neurotoxic pollutants and targeted
programs of prevention.

b. Prospective cohort studies from birth are needed, parallel to study
on adults and elderly with a retrospective assessment of exposure.

c. Neurotoxicological research, including research on developmental
neurotoxicology, is needed on metals not considered at the Brescia
Workshop -- arsenic and aluminum, in particular, and on interactions
with essential elements, pesticides, and persistent organic

d. Research is needed into genetic and other factors that contribute
to susceptibility to metal toxicity.

e. Research is needed into various determinants of the rearing
environment, including the social setting, that can modify the
exposure indicators to neurotoxic metals


Philip Landrigan is a member of the ICOH Scientific Committees on
Toxicology of Metals and Neurotoxicology and Psychophysiology.

Monica Nordberg is the Chair of the ICOH Scientific Committee on
Toxicology of Metals.

Roberto Lucchini is the Chair of the ICOH Scientific Committee on
Neurotoxicology and Psychophysiology and member of the Scientific
Committee on Toxicology of Metals.

Gunnar Nordberg was the past Chair of the ICOH Scientific Committee on
Toxicology of Metals.

Philippe Grandjean is a member of the ICOH Scientific Committees on
Toxicology of Metals and Neurotoxicology and Psychophysiology.

Anders Iregren was the past Chair of the ICOH Scientific Committee on
Neurotoxicology and Psychophysiology.

Lorenzo Alessio is a member of the ICOH Scientific Committee on
Toxicology of Metals.


** Statement authored by Philip Landrigam,[1] Monica Nordberg,[2]
Roberto Lucchini,[3] Gunnar Nordberg,[4] Philippe Grandjean,[5] Anders
Iregren,[6] and Lorenzo Alessio[1]

[1] Department of Community and Preventive Medicine, Mount Sinai
School of Medicine, One Gustave L. Levy Place, New York

[2] Institute of Environmental Medicine, Karolinska Institutet,
Stockholm, Sweden

[3] University of Brescia, Institute of Occupational Health, Ple
Spedali Civili, Brescia BS, Italy

[4] Department of Public Health and Clinical Medicine, Umea
University,Environmental Med- icine, Umea, Sweden

[5] Institute of Public Health, University of Southern Denmark,
Winslowparken, Odense, Denmark

[6] National Institute for Working Life, Chemical Risk Assessment,
Stockholm, Sweden

* Correspondence to: Philip Landrigan, Department of Community and
Preventive Medicine, Mount Sinai School of Medicine, One Gustave L.
Levy Place, Box 1057, NewYork 10029-6574. E-mail:

The views presented in the Declaration are the consensus reached by
the participants in the workshop and do not necessarily reflect the
decisions or stated policies of the affiliation organizations.

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From: Daily Telegraph (UK), Nov. 9, 2006
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By John von Radowitz

Millions of children worldwide may have suffered brain damage as a
direct result of industrial pollution, scientists say.

An explosive report talks of a "silent pandemic" of
neurodevelopmental disorders caused by toxic chemicals spilling into
the environment.

They include conditions such as autism, attention deficit disorder,
mental retardation and cerebral palsy. All are common and can result
in lifelong disability, but their causes are largely unknown.

The scientists, from Holland and the US, identified 202 industrial
chemicals with the potential to damage the human brain, and said they
were likely to be the "tip of a very large iceberg". More than 1,000
chemicals are known to be neurotoxic in animals, and are also likely
to be harmful to humans.

The researchers made an urgent call for much tighter worldwide
controls on chemicals, and a "precautionary approach" to testing. Dr
Philippe Grandjean, from the Department of Environmental Medicine at
the University of Southern Denmark in Winslowparken, one of the
study's two authors, said: "The human brain is a precious and
vulnerable organ.

"And because optimal brain function depends on the integrity of the
organ, even limited damage may have serious consequences. Even if
substantial documentation on their toxicity is available, most
chemicals are not regulated to protect the developing brain. Only a
few substances, such as lead and mercury, are controlled with the
purpose of protecting children.

"The 200 other chemicals that are known to be toxic to the human brain
are not regulated to prevent adverse effects on the foetus or a small
child." Grandjean and co-author Professor Philip Landrigan, from the
Mount Sinai School of Medicine in New York, trawled a range of
scientific data sources to compile their evidence.

Five substances for which sufficient toxicity evidence exist were
examined in detail -- lead, methylmercury, arsenic, polychlorinated
biphenyls (PCBs) and toluene. In each case, the dangers came to light
the same way.

First, there was a recognition of high dosage toxicity in adults, and
records of isolated episodes of poisoning among children. This was
followed by a growing body of epidemiological evidence that lower
levels of exposure in children led to neurobehavioral defects.

Pinning down the effects of industrial chemical pollution is extremely
difficult because they may not produce symptoms for several years or
even decades, said the scientists. This was why the pandemic is
"silent". The damage caused by individual toxic chemicals is not
obviously apparent in available health statistics.

But the extent of the sub-clinical risk to large populations is
illustrated by the legacy of lead. Virtually all children born in
industrialised countries between 1960 and 1980 must have been exposed
to lead from petrol, said the researchers. Based on what is known
about the toxic effects of lead, this may have reduced exceptional IQ
scores of above 130 by more than half, and increased the number of
scores less than 70.

Other results of lead exposure included shortened attention span,
slowed motor coordination and heightened aggressiveness. In later
life, early damage from lead can increase the risk of Parkinson's and
other neurodegenerative diseases.

Today, it is estimated that lead poisoning in children costs the US
economy $A55 billion each year. One in six children is thought to have
some kind of developmental disability, usually involving the nervous

Developing brains are much more susceptible to toxic chemicals than
those of adults, pointed out the scientists. Interference with complex
changes taking place in the developing brain can have permanent
consequences. And research had shown that this vulnerable period lasts
from the foetal stage of life through infancy and childhood to

Writing in the online version of The Lancet medical journal, the
scientists conclude: "The combined evidence suggests that
neurodevelopmental disorders caused by industrial chemicals has
created a silent pandemic in modern society.

"Although these chemicals might have caused impaired brain development
to millions of children worldwide, the profound effects of such a
pandemic are not apparent from available health statistics.
Additionally... only a few chemical causes have been recognised, so
the full effects of our industrial activities could be substantially
greater than recognised at present."

In the EU, 100,000 chemicals were registered for commercial use in
1981, and in the US, 80,000 are registered. Yet fewer than half had
been subjected to even token laboratory testing, said the report, and
in 80 per cent of cases there was no information about potential
danger to children.

Although new chemicals went through more rigorous testing, access to
the data could be restricted for commercial reasons. In the EU, a new
testing program called Reach is planned under proposed legislation
that will enforce tighter controls.

But the scientists said that even this does not go far enough, since
it fails to emphasise the importance of testing chemicals for
developmental neurotoxicity. "Toxicity testing protocols for chemicals
need to be expanded to include examination of neurobehavioral
functions," they said.

There was a mixed reaction to the research from other experts.

Professor Mark Hanson, director of developmental origins of health and
disease at Southampton University, said: "The authors have put their
finger on something which is important and which will not go away. The
review, in a way, is timely because it will stir up debate and
hopefully generate more research in this area. There is no need to
panic, but we can't ignore this possible problem."

Professor Alan Boobis, from the section of experimental medicine and
toxicology at Imperial College London, said: "The authors of this
review have raised an issue of significant concern, but some of the
evidence in support of the conclusions lacks rigour. This is a risk
management issue. In implementing the precautionary principle, it is
important to take into account all relevant information and not just
the potential harm that might result from inaction."

Professor Nigel Brown, head of the faculty of medicine and biomedical
sciences at the University of London, criticised the report, saying
the authors "verge on scaremongering". He said: "From their
assertions, the authors conclude that the combined evidence suggests
that neurodevelopmental disorders caused by industrial chemicals has
created a silent pandemic in modern society. This is a gross

"It is possible that there is a problem. We should be aware of this
and we should study the problem, but there is currently not a shred of
evidence of a pandemic."

Copyright 2006 News Limited

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From: American Legislative Exchange Council, Oct. 12, 2006
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The "precautionary principle" is a term invented by environmental
alarmists to justify their opposition to technological progress. It
essentially states that one must conclusively "prove" that a proposed
action or advancement poses no risk of human or environmental harm
before being deemed lawful. This asserted burden of proof is
deliberately worded to be a very difficult standard to attain. It is
impossible to "prove" that a hypothetical result, no matter how far-
fetched, absolutely cannot occur (i.e., one cannot prove a negative).

The practical effect of the precautionary principle is to ban almost
anything that is not "natural." It prays on irrational fears
regarding technology rather than relying on empirical scientific
research. An example of the stifling effect of the precautionary
principle can be found regarding genetically improved crops. For
three decades biotechnology, operating under stringent government
regulatory scrutiny, has produced greater yields, higher nutrition,
and crops requiring ever-decreasing amounts of pesticides, with not a
single person ever experiencing any adverse health effects.
Nevertheless, environmental activists operating under the
precautionary principle continue to assert that genetically enhanced
crops should be banned because such an extensive record of human and
environmental success does not constitute "proof" that genetically
enhanced crops pose no human health risks. All we have seen,
precautionary principle advocates argue, is anecdotal evidence that
perhaps no harm has yet occurred.

One need not have an overactive imagination to see the stifling, if
not destructive, effect the precautionary principle can have on
scientific progress and our standard of living. There is little good
that can be accomplished, and much evil that can result, from
abandoning our current EPA and FDA regulatory procedures in favor of a
"precautionary principle" that, if adopted 10,000 years ago, would
have us still living in the Stone Age.

Talking Points:

* Current EPA and FDA rules, regulations and procedures already
rigorously ensure environmental health and consumer safety. There is
no need to abandon a system that encourages advances in human welfare
for an overly alarmist agenda that will stifle scientific and societal

* The precautionary principle itself forbids implementation of
the precautionary principle: proponents have failed to conclusively
"prove" that the adoption of the precautionary principle will not
cause more societal harm that good.

* Application of the precautionary principle 10,000 years ago
would have kept us in the Stone Age, as there was no "proof" that
mining, using, and disposing of bronze, iron, etc., would not cause
environmental or human health harm. Application of the precautionary
principle 100 years ago would have banned automobiles, air travel,
electricity, and other modern essentials as well. Application of the
precautionary principle today will seem just as ridiculous and
progress-stifling to our children's children 100 years from now.

* Application of the precautionary principle to biotechnology --
as activists frequently seek -- would have negated tremendous recent
gains in global crop yields and nutrition, and would have negated
dramatic recent reductions in the need for pesticides.

* Application of the precautionary principle to biotechnology --
as activists frequently seek -- would have negated numerous life-
saving medical advances.

* The precautionary principle will outlaw many of the scientific
advancements that have come to define modern society.

* From an economic standpoint, studies show that application of
the precautionary principle in Europe has the effect of a 15 percent
tax on new capital investment.

Additional Sources:

Guldberg, H., "Challenging the Precautionary Principle," Spiked
Online, July 1, 2003.

Milloy, S., "U.S. Should Not Import European Laws," November 17,

"Precautionary Principle," Competitive Enterprise Institute.

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From: American Legislative Exchange Council, Oct. 28, 2006
[Printer-friendly version]



Anti-chemical activists are pushing for bills to eliminate or
drastically reduce the use of pesticides in schools. Some measures
attempt to completely ban pesticides in schools, others attempt to
greatly reduce pesticides in schools, while others mandate onerous
paperwork requirements that discourage pesticide use.

The bills are unnecessary because the U.S. Environmental Protection
Agency already requires extensive pesticide testing and conducts risk
assessments on various subpopulations, including children, to insure
that no sensitive individuals are at risk.

Additionally, the Food Quality Protection Act now requires that
manufacturers of pesticides specifically consider the possibility of
sensitivity to infants and children from exposure, which often
requires an extra 'safety protection factor' for use.

Exposure levels to humans from pesticide use are required to be at
least 100 times (required by law and sometimes this increases to 300
or even a 1000 times) below the no-observed adverse effect level in
the most sensitive species, using the most sensitive toxicological
endpoint. Thus, there is inherent conservatism in the permissible
exposure levels established for safe use by humans.

Pesticide restrictions in schools do more harm than good by failing to
balance the virtually nonexistent pesticide risks against the very
real harm done to children by allowing insects and rodents to thrive,
resulting in increased allergy and disease problems.

Talking Points:

* The Environmental Protection Agency rigorously tests all
commercial pesticides to ensure that children will not be harmed by
pesticide exposure.

* EPA errs on the side of extreme caution in its exposure
assumptions, resulting in maximum exposure levels that are typically
tens, hundreds, of even thousands of times less than what would be
necessary for any plausible health risk to exist.

* Pesticides play a vital role in protecting our children in
school. This is especially true considering that most schools provide
on-site lunch services that are a magnet for ants, roaches, rats and
other disease-spreading pests.

* So-called biological controls -- such as introducing spiders to
pray on cockroaches -- are far less effective than safe pesticide
treatments and introduce their own set of potential health problems.

* Cockroaches are among the most prevalent child allergens and
sources of asthma attacks, with 20 percent of all children being
allergic to cockroaches. Without proper pest control, cockroach feces
and decomposing cockroach bodies trigger severe allergy and asthma
episodes in homes and schools.

Additional Sources:

Assessing Health Risks from Pesticides, U.S. Environmental
Protection Agency.

Logomasini, A., "State Legislatures Face Anti-Pesticide Bills,"
Environment & Climate News, August 1, 2004

Milloy, S., "Pesticides Not a Threat to Students," August 9, 2005

Milloy, S., "Unwarranted Warning," April 21, 2000

Taylor, J., "Pesticide bans put children at risk from roaches,
rodents," Environment & Climate News, July 1, 2002

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  Rachel's Precaution Reporter offers news, views and practical
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  principle? Who is using precaution? Who is opposing precaution?

  We often include attacks on the precautionary principle because we  
  believe it is essential for advocates of precaution to know what
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