Angry Toxicologist

Every party needs a pooper, that’s why Scienceblogs invited me.
Enemy? Really? Yes, it can be. Read on; It doesn’t have to be.

A commentary in Nature Nanotechnology discusses the European Environment Agency report, Late Lessons from Early Warnings. The basic idea is to make recommendations so that nanotech can grow with the idea that if you ignore risks and get dealt a nasty surprise, the public backlash will doom the whole field. They came up with a list of 12 lesssons: some are as old as the hills and probably won’t followed; all would be welcome if they were followed.

Among the lessons that we won’t learn from (considering name change to Cynical Toxicologist) are the ones the commentary groups under “Heed the ‘warnings’”, “consider wider issues” and “retain regulatory independence” (hah!). Everybody knows this is what’s supposed to happen and it doesn’t; it’s not specific to nanotech. There are some that should stop and make you think, however. Lessons 5 and 8 (accounting for real world conditions and using layperson knowledge) are often dismissed as going beyond the worst case scenario. Anyone who has ever worked in a factory knows how much of a joke it would be to assume that the product conforms to the standard. Talking to the workers on the floor really changes how you think about potential risks. But what I really want to write about is lesson 12…

You say scientists, I say enablers. Let’s call the whole thing off.

My favorite is lesson 12, the “paralysis by analysis” lesson. Everyone likes to ask for more information instead of putting their ass on the line and making a decision. I can’t tell you how many gov’t advisory committees I’ve almost pulled my hair out at because the committee as a whole doesn’t want to make any recommendations other than ‘we need more research’. I can recall three where committee members specifically asked if they had to answer the question put before them as they’d rather not make judgements, and can’t recall a single one where the members didn’t want to change the questions posed to it. More data. More research. Uncomfort with uncertainty. When science meets public health, it gets ugly. Really ugly. It sounds pretty easy to say you’re going to use a weight of evidence approach until you try and apply it to a decision that will have a drastic effects on the public, the gov’t, and industry. It’s oh so tempting to pull up your ‘more research’ security blanket around you and refuse to make a decision. It’s not only tempting, it’s how we’re trained as scientists: look at data, formulate hypothesis, test hypothesis, repeat. It’s tough to break that mold and replace it: look at data, formulate hypothesis, act.

Because this is used so often, the costs in health, money, and manpower are astronomical. Think about the debate over global warming as an example. This is actually at a pretty good stage compared to most scientific debates over a public health issue. Most are stuck doing ever more research to try and confirm something that most people know while everyone mumbles about what we don’t know. With global warming at least we also have a large number of scientist saying we need to do something. So here’s my lesson 13 (et al.) and professional plea to other scientists out there: Whatever science you practice, take a stand about what you work on, be passionate about people and the data, understand that regulators need advice from advisory boards-not more confusion, understand that making decisions and being open-minded are not mutally exclusive, and most importantly, locate your spine and act in accordance with this discovery or confirmation as the case may be. Thank you.

Comments

#1 Hank Roberts
July 28, 2008

> Anyone who has ever worked in a factory knows how
> much of a joke it would be to assume that the product
> conforms to the standard.

Sausage and the law …
#2 AngryToxicologist
July 28, 2008

I’ve worked in a factory, make my own sausage, and have seen bills drafted. Comparatively, making sausage is a beautiful thing. Also comparatively, getting a group of scientists together to make recommendations that effect policy makes The Jungle sound like a nice place to vacation.
#3 Rogue Epidemiologist
July 28, 2008

When I was in grad school, I remember learning about the precautionary principle in environmental health. Basically, the text taught us that all things, even in the most minute concentrations had the potential to cause some kind of harm, and therefore it would be better for all of us to eliminate all traces of whatever material may be ailing us. I thought to myself, “This is why we can’t have nice things.”

I agree, Angry Tox, that public health folks need to be passionate about the things we study. I have immense fervor for my work (I started prowling SciBlogs just to watch Orac and denialism blog rail against the anti-vaxers). In taking a stand, we also need to defend an acceptable level of risk, too. Otherwise, the only recommendation we can make to people is to live out their sad little lives in sterile, padded rooms.
#4 JLowe
July 29, 2008

The one point you raise that warrants further discussion is the characterization of scientists as the decision makers in an environmental or public health problem. Scientists aren’t and shouldn’t be the decision makers – that’s the role of the regulators, politicians and the citizens. However, that’s generally a pretty innumerate and unscientific bunch, when it comes to understanding risk problems. In addition, most scientists are pretty poor at explaining risk problems to the other stakeholders. Finally, I’ll argue that none of the decision makers and few of the scientists really understand uncertainty, how to assess it and how to address it in decision making, or what really constitutes “acceptable risk”. And this is with a level playing field (i.e. where manufactured uncertainty isn’t in play).

My favorite whipping horses here are chlorinated solvents. Why is it so difficult to phase out PCE use in dry cleaning? Why is it so difficult to develop groundwater standards for TCE (20 years in the making, and still counting)?
#5 John Beaty
July 29, 2008

“When the question is, Why don’t they?, the answer is always, ‘Money’” Phasing out PCE would basically close many Mom and Pop type dry-cleaners, and implementing goundwater standards would affect many different business-type activities. Not that I think we shouldn’t do it, but politically, it’s a real problem.
#6 JLowe
July 29, 2008

The only real political problem is a lack of backbone to do the job (i.e. phasing out PCE) right. Low-interest financing is available for the Mom and Pop dry cleaners to convert over to “wet cleaning” alternatives. The South Coast Air Quality Management District has had this kind of program available for years. The other political problem to be solved is pressuring the garment industry to modify its labeling to accommodate non-solvent based dry cleaning fluids.

As for the groundwater cleanup issue, if we had the political will to regulate using risk-based approaches that involve an assessment of the potential for exposure and adverse effects, rather than using arbitrary technology-based standards, cleanups might be less expensive while being no less protective of public health. But, again, we lack the backbone to incorporate risk-based approaches into environmental regulations.
#7 AngryToxicologist
July 30, 2008

I generally agree with JLowe’s comments but I’d disagree with the following.

I’ll argue that none of the decision makers and few of the scientists really understand uncertainty, how to assess it and how to address it in decision making, or what really constitutes “acceptable risk”. And this is with a level playing field (i.e. where manufactured uncertainty isn’t in play).

My experience is that they understand it quite well but they are simply wimps, to put it politely. This is why we have scientific advisory boards to begin with. The whole idea is quite stupid; the experts are already working for the agency that convenes the boards. The EPA (or whoever, they’re just the worst offenders) knows what the right thing to do is. They just want cover to make a certain decision and hope the board gives it to them. The problem is that the board is made up of people that are more controversy shy than they are.
#8 zay?flama
August 2, 2008

The South Coast Air Quality Management District has had this kind of program available for years. The other political problem to be solved is pressuring the garment industry to modify its labeling to accommodate non-solvent based dry cleaning fluids.
#9 Kar?nca Yumurtas? Ya??
August 2, 2008

In addition, most scientists are pretty poor at explaining risk problems to the other stakeholders. Finally, I’ll argue that none of the decision makers and few of the scientists really understand uncertainty, how to assess it and how to address it in decision making, or what really constitutes “acceptable risk”. And this is with a level playing field (i.e. where manufactured uncertainty isn’t in play).
#10 Kar?nca Yumurtas? Ya??
August 2, 2008

they’re just the worst offenders) knows what the right thing to do is. They just want cover to make a certain decision and hope the board gives it to them. The problem is that the board is made up of people that are more controversy shy than they are.
#11 Hank Roberts
September 16, 2008

This might be the place to ask how you react when you read comments like this one:
http://www.reuters.com/article/rbssConsumerGoodsAndRetailNews/idUSPEK27908420080916?pageNumber=2&virtualBrandChannel=0

——excerpt_follows——

Another dairy industry expert, Li Zhiqi, told the China Reform Daily that melamine was widely used. “At every step, people can add melamine to boost the quality of milk,” Li said.

——end_excerpt———–

There’s an old joke every writer has heard, about the writer and the editor who, after their plane crashed in the desert, hiked, then walked, then stumbled, then crawled across the sand for days, and almost dead, came across a rise and saw an oasis — a couple of trees, a few bushes, and a tiny pool of open water. They crawled down to it.

The writer leaned over and started to drink — and then a yellow stream arched over his shoulder and splattered into the little pool.

The writer rolled over and screamed at the editor, who continued to urinate — “What are you doing??”

And the editor replied, “I’m improving it.”

So. Forget that. Now we can tell the real story, instead, about the expert on children’s milk products and how his industry boosts the “quality” of the milk.

Have we explained why there’s no sign of intelligent life in the universe yet, by the only example we have of failure thereat?
#12 Hank Roberts
September 16, 2008

“… the problem is far bigger ….”
http://online.wsj.com/article/SB122158011929343485.html?mod=googlenews_wsj
#13 Hank Roberts
September 21, 2008

Ah, I should’ve guessed, I’m not cynical enough yet.

Sellers had diluted the milk with water.

They then added melamine to hide that.

http://online.wsj.com/article/SB122188076442559769.html
“… Melamine, an industrial chemical, can boost apparent protein presence, helping mask dilution or protein deficiency that otherwise could be spotted in companies’ quality tests….”
#14 Hank Roberts
September 21, 2008

One last one. It’s not just melamine. To add it to milk, melamine has to first be dissolved in something like formaldehyde!

Basic point is — any time there’s a boom, a sudden increase in the use of anything, there’s motivation for fraud. Milk use in China skyrocketed recently.

http://ap.google.com/article/ALeqM5jLXpq9YQBdZkaSRyRtY6IE57xcIQD93B7NMO0

—–excerpt——

… watered down their milk to increase volume and then added the industrial chemical melamine, which is high in nitrogen and artificially appears to boost protein content.
… Experts have expressed skepticism that so many farmers would know to add melamine to milk as the chemical is not water-soluble and must be mixed with formaldehyde or another chemical before it can be dissolved in milk.

————–end excerpt——-

I know somewhere there’s been academic study of the basic point, that any time a market suddenly goes into a rapidly increasing pattern, fraud emerges because it becomes easy to sell fake stuff to people very eager to buy-buy-buy. Especially when there’s little or no regulation, inspection, or recordkeeping.

Okay, I’ll quit banging on your thread here. I hope you’ll carry your main point further though. It’s an important one.
#15 Estetik
November 17, 2008

One of the very best discussions. Each of the guests was both knowledgeable and cranky, and Dvorak let them speak
#16 Hank Roberts
November 30, 2008

One more. Though maybe nobody’s here but the spammers now.

We know it was the interaction effect that causes the crystals in the kidneys.

Read this. Is this guy saying exactly what he’s saying?
I need an anger checkup from a toxicologist here.

http://www.google.com/hostednews/ap/article/ALeqM5j7SAbhJj3By_isZUoRAgTOPHzwkQD94OM2CG0

——
FDA sets melamine standard for baby formula

By JOAN LOWY and JUSTIN PRITCHARD � 14 hours ago

WASHINGTON (AP) � Two months ago, federal food regulators said they were unable to set a safety threshold for the industrial chemical melamine in baby formula. Now, however, they found a way to settle on a standard that allows for higher levels than those found in U.S.-made batches of the product.

Food and Drug Administration officials on Friday set a threshold of 1 part per million of melamine in formula, provided a related chemical is not present. They insisted the formulas are safe.

The development comes days after The Associated Press reported that FDA tests found traces of melamine in the infant formula of one major U.S. manufacturer and cyanuric acid, a chemical relative, in the formula of a second major maker. The contaminated samples, which both measured at levels below the new standard, were analyzed several weeks ago.

The FDA had said in early October it was unable to set a safety contamination level for melamine in infant formula.

Dr. Stephen Sundlof, the FDA’s director of food safety, said Friday the agency was confident in the 1 part per million level for either of the chemicals alone, even though there have been no new scientific studies since October that would give regulators more safety data. He had no ready explanation for why the level was not set earlier.

The standard is the same as the one public health officials have set in Canada and China, but is 20 times higher than the most stringent level in Taiwan.
——end excerpt———

Let me read that again:

“… melamine in the infant formula of one major U.S. manufacturer and cyanuric acid, a chemical relative, in the formula of a second major maker.”
…
“… Sundlof, the FDA’s director of food safety, said Friday the agency was confident in the 1 part per million level for either of the chemicals alone ….”

Do you feel the need of a “but” after this?
How about after reading about the interactions
http://www.google.com/search?q=%2Bmelamine+%2B“cyanuric+acid”+%2Bcrystal
maybe now?

Like, keep your infant on only ONE brand, don’t change brands, and hope nothing else changes, because the two chemicals interact, and we know this from experience as well as lab work and theory?

Like, but why release this on the Saturday of a long holiday weekend?
#17 Hank Roberts
November 30, 2008

I’m putting further followup over here:

http://scienceblogs.com/effectmeasure/2007/05/melamine_followup.php
#18 Estetik
December 31, 2008

Dr. Stephen Sundlof, the FDA’s director of food safety, said Friday the agency was confident in the 1 part per million level for either of the chemicals alone, even though there have been no new scientific studies since October that would give regulators more safety data. He had no ready explanation for why the level was not set earlier.
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January 1, 2009

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March 25, 2009

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#33 arac kiralama
April 6, 2009

Talking to the workers on the floor really changes how you think about potential risks. But what I really want to write about is lesson 12…
#34 sac ekimi
April 6, 2009

Dr. Stephen Sundlof, the FDA’s director of food safety, said Friday the agency was confident in the 1 part per million level for either of the chemicals alone, even though there have been no new scientific studies since October that would give regulators more safety data. He had no ready explanation for why the level was not set earlier.
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Every party needs a pooper, that’s why Scienceblogs invited me. Enemy? Really? Yes, it can be. Read on; It doesn’t have to be.
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April 8, 2009

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April 10, 2009

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#40 isagenix
April 20, 2009

Two months ago, federal food regulators said they were unable to set a safety threshold for the industrial chemical melamine in baby formula. Now, however, they found a way to settle on a standard that allows for higher levels than those found in U.S.-made batches of the product.
#41 Sun Tan Lotion
April 24, 2009

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April 25, 2009

“When the question is, Why don’t they?, the answer is always, ‘Money’” Phasing out PCE would basically close many Mom and Pop type dry-cleaners, and implementing goundwater standards would affect many different business-type activities. Not that I think we shouldn’t do it, but politically, it’s a real problem.
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April 25, 2009

Among the lessons that we won’t learn from (considering name change to Cynical Toxicologist) are the ones the commentary groups under “Heed the ‘warnings’”, “consider wider issues” and “retain regulatory independence” (hah!). Everybody knows this is what’s supposed to happen and it doesn’t; it’s not specific to nanotech. There are some that should stop and make you think, however. Lessons 5 and 8 (accounting for real world conditions and using layperson knowledge) are often dismissed as going beyond the worst case scenario. Anyone who has ever worked in a factory knows how much of a joke it would be to assume that the product conforms to the standard. Talking to the workers on the floor really changes how you think about potential risks. But what I really want to write about is lesson 12…
#44 estetik cerrahi
April 28, 2009

Among the lessons that we won’t learn from (considering name change to Cynical Toxicologist) are the ones the commentary groups under “Heed the ‘warnings’”, “consider wider issues” and “retain regulatory independence” (hah!). Everybody knows this is what’s supposed to happen and it doesn’t; it’s not specific to nanotech. There are some that should stop and make you think, however.
#45 isagenix
April 29, 2009

retain regulatory independence” (hah!). Everybody knows this is what’s supposed to happen and it doesn’t; it’s not specific to nanotech. There are some that should stop and make you think, however.
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July 17, 2009

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January 10, 2010

Every party needs a pooper, that’s why Scienceblogs invited me. Enemy? Really? Yes, it can be. Read on; It doesn’t have to be.
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January 10, 2010

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January 14, 2010

“Heed the ‘warnings’”, “consider wider issues” and “retain regulatory independence” (hah!). Everybody knows this is what’s supposed to happen and it doesn’t; it’s not specific to nanotech. There are some that should stop and make you think, however.
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June 19, 2010

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June 26, 2010

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#70 Isagenix
August 28, 2010

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July 11, 2011

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