New Solutions: The Drawing Board is a monthly feature produced by the journal New Solutions. Read more about it here.
By Richard Clapp
The President's Cancer Panel report released on May 6 had some strong findings and recommendations on ways to reduce the cancer burden caused by workplace exposures. This is welcome news to U.S. workers and trade unions, who have been largely left out of the cancer prevention conversation for the past few decades. Notably, the panel members wrote in their cover letter to President Obama, "With the growing body of evidence linking environmental exposures to cancer, the public is becoming increasingly aware of the unacceptable burden of cancer resulting from environmental and occupational exposures that could have been prevented through appropriate national action...our Nation still has much work ahead to identify the many existing but unrecognized environmental carcinogens and eliminate those that are known from our workplaces, schools, and homes."
In the introductory section of the report, the authors state:
Weak laws and regulations, inefficient enforcement, regulatory complexity, and fragmented authority allows avoidable exposures to known or suspected cancer causing and cancer-promoting agents to continue and proliferate in the workplace and the community. Existing regulations, and the exposure assessments on which they are based, are outdated in most cases, and many known or suspected carcinogens are completely unregulated. Enforcement of most existing regulations is poor. In virtually all cases, regulations fail to take multiple exposures and exposure interactions into account. In addition, regulations for workplace environments are focused more on safety than on health. Industry has exploited regulatory weaknesses, such as government's reactionary (rather than precautionary) approach to regulation. Likewise, industry has exploited government's use of an outdated methodology for assessing 'attributable fractions' of the cancer burden due to specific environmental exposures. This methodology has been used effectively by industry to justify introducing untested chemicals into the environment.
The PCP report also disputes the widely quoted estimates of avoidable cancer deaths resulting from occupational exposures developed by Doll and Peto in 1981. They noted that these estimates are based on information that is thirty years out of date and fail to take into account our current understanding of the multifactorial, multistage process that leads to cancer. The authors of the PCP report do not attempt to update the Doll and Peto estimates, instead claiming that the true burden of occupational cancer is unknown. They go on to recommend that information about the number of workers currently exposed to carcinogens or circumstances (such as light at night) that may lead to cancer should be collected and assessed. In the meantime, they simply state that we can "act on what we know."
Another remarkable section of the report addresses the unequal burden of cancer borne by certain segments of the population. In the words of the authors, "People from disadvantaged populations...are more likely to be employed in occupations with higher levels of exposure (e.g., mining, construction, manufacturing, certain service sector occupations) and to live in more highly contaminated communities. For example, Louisiana and Mississippi are known as 'Cancer Alley' because of the more than 100 chemical plants and oil refineries in the area and the high concentration of poor populations with limited health care access." This is notable in that while other reports by government agencies and cancer organizations have noted cancer "disparities," the President's Cancer Panel went further to implicate occupation and industrial exposures in poor communities as part of the cause.
Worker health and safety advocates in California have pointed to another disparity in cancer prevention: the much higher level of exposure allowed in workplaces than in the community to the same carcinogen. The PCP report notes this and quotes Dr. Adam Finkel, who previously presented at a governmental meeting on industrial carcinogens. "This is where the real unacceptable part of this problem is," notes Dr. Finkel. "That the individual probabilities of cancer to workers are orders of magnitude greater than we accept in the general environment."
Agricultural exposures to farm-workers and their families received attention through mention of the National Cancer Institute and National Institute for Environmental Health Sciences-sponsored Agricultural Health Study, which includes more than 89,000 participants, including private and commercial pesticide applicators and their spouses. This research has already shed light on the carcinogenic effect of several pesticides used in the U.S. and will provide more insight as it progresses and the cohort is followed for more years. The PCP authors note the disproportionate exposures that three to five million migrant farm-workers and their children experience in the country. In response to concerns over health effects resulting from pesticide exposure, the PCP recommends eating "to the extent possible, food grown without pesticides or chemical fertilizers and washing conventionally grown produce to remove residues."
Another remarkable section of the report deals with exposures to carcinogenic substances and radiation in and around military installations in the U.S. and elsewhere. The authors describe numerous examples of chemical contamination, including trichloroethylene and perchloroethylene contamination of drinking water at Camp Lejeune, in North Carolina; Agent Orange contamination during the Vietnam conflict; chromium contamination at a water treatment facility in the current Iraq conflict; and many sources of radiation exposure in the development and testing of nuclear weapons around the U.S. and Marshall Islands in the Pacific Ocean. Implicit in this section is the notion that service in the military, both short-term and long-term, can be understood as potentially hazardous workplace exposure, with service members, their families and communities being affected by carcinogens at much higher rates than the general population.
The report ends with a series of recommendations, including a call for stronger enforcement of existing laws and regulations, as well as updating the current regulatory framework so that it is more protective of workers and others exposed to carcinogens in their communities. The PCP explicitly recommends that a new "precautionary, prevention-oriented approach should replace current reactionary approaches to environmental contaminants in which human harm must be proven before action is taken to reduce or eliminate exposure." They support a new chemicals policy such as proposed in the Safe Chemicals Act, which was introduced in the Congress at about the same time the report was released.
As expected, the report has been attacked representatives of mainstream cancer organizations, but it has also received widespread praise in many media. Worker health and safety advocates will find much that is useful in the report. For example, the PCP call for stricter regulation of workplace exposures supports persistent demands for updating Occupational Safety and Health Administration (OSHA) carcinogen standards. The report also calls for reducing military exposures and compensating those who have been harmed by previous military activity, such as the Marshall Islanders. The advocates of current legislation filed on behalf of exposed Camp Lejeune veterans will also find support from the Panel, as will those advocating for environmental justice and an end to the unequal burden of carcinogenic exposures in low-income and minority communities.
The impact this report will have on U.S. governmental agencies and new legislation remains to be seen. But the report acts as a straightforward and uncompromising consideration of the deficiencies in current approaches to cancer prevention, specifically the unacceptable burden of occupational cancer. It was a refreshing change from the usual cursory or even silent treatment of this burden in most reports of this type. For once, a report of this magnitude provides wind at our backs, instead of a headwind.
Richard Clapp is an epidemiologist who has forty years experience in public health practice, research and teaching. He is Professor Emeritus at Boston University School of Public Health and Adjunct Professor at the U. of Mass.- Lowell School of Health and Environment.
The PCP's call to "act on what we know" is a key unpinning of harm prevention. It is also rightfully informed by a history of polluters and others with economic interest to obstruct precautionary action by insisting we don't (and may never) know enought to act.
I hope educators (especially in our schools of public health) incorporate the 2010 PCP report in their curriculum.
I'm a little confused by Dr. Clapp's article when he says that the President's Cancer Panel Report says that, in the military "service members, their families and communities [are]being affected by carcinogens at much higher rates than the general population". I served over 13 years as an Air Force Bioenvironmental Engineer, running industrial hygiene and environmental programs in several Air Force bases. I do not concur that military members and their families are exposed to carcinogens "at much higher rates than the general population." This sounds as an assumption rather than a statement of fact. The drinking water in military bases has to meet EPA Safe Drinking Water Act standards. There are strong environmental protection programs implemented at each military base. Military industrial workplaces have to comply with OSHA regulations, even if Federal OSHA has no jurisdiction over the uniformed military (it does has juridiction over Fedral employees in military bases).
Please let's not make this kind of assumption. There are industrial hygienists and military public health professionals in each military service. Talk to them, review their records, and then come to a conclusion.
Jorge A. Delucca, MS, MA, CAIH
I'm not sure who Jorge Delucca is referring to in his comment. If he means that the President's Cancer Panel members should not make assumptions, I urge him to read pages 77-87 of the report where they document numerous examples of military toxic and radiation exposures. If he's referring to me, I have personally visited and talked to personnel at several military bases and nuclear weapons facilities and have drawn my own conclusions based on my observations. Most recently, I visited Camp Lejeune, North Carolina, where Marines and their families were exposed to the highest concentrations of PCE and TCE of any community in the U.S. The total population exposed over three decades or more is well over 500,000
I noticed that Major Delucca was involved in air monitoring at the Tinker Air Force Base in Oklahoma. The ATSDR Public Health Assessment of that base found TCE concentration of 1642 ppb in one well and concluded, "it is likely that people were exposed to concentrations of TCE above the MCL of 5 ppb." If Major Delucca means that civilians may routinely be exposed to this level or more, he may be right, but both situations are threats to health and should be mitigated. It is no comfort to point out that we're all (military personnel and civilians) exposed equally to carcinogens in our workplace an communities.
I see you read about me in the internet. Yes, I was Deputy Chief of Bioenvironmental Engineering at Tinker AFB between 1993 and 1997 when I retired from the Air Force. In 1996 I wrote a Capstone project on the Drinking Water Quality Monitoring Program of Tinker AFB as part of my Master of Science degree at the University of Oklahoma College of Public Health. On page 4 of this document (sorry, it is not in the internet, I'm reading my hard copy) I wrote "The Tinker water distribution system consists of 20 operational water wells." In the ATSDR Public Health Assessment of Tinker AFB that you are quoting (reference #111 of this document is my memorandum of air sampling results for TCE from a creek leaving the base)paragraph 4 of the section on Base Supply Wells mentions that "contamination was detected in base supply wells 18 and 19 at levels that could have posed a public health hazard if people were exposed directly to those concentrations". It is a bit confusing when the report says "However the contaminant concentrations that people were exposed to are unknown" (it took me a few minutes to understand that it is referring to prior to the contamination being discovered). The rest of the sentence reads "...but are expected to be less than those in the contaminated base wells...water from contaminated wells was diluted by uncontaminated water from other base wells." The levels of TCE were monitored by my office (analyzed by the State Department of Health) and were consistently well below the MCL of 5 ppb during the years I was there. The last sentence in this page says: "The Air Force removed the contaminated wells from service permanently the same year (1983) contamination was detected." So yes, there was exposure to toxic chemicals years ago, but not since the environmental management programs were implemented in the early 1980's. I have never worked at Camp Lejeune, but the water quality is probably under control or the base should be drinking bottled water, something to research.
My problem is that your article appears to say that military workers and families are being exposed today to these hazards when in fact it was people in years past that were exposed. The Department of Defense implemented in the early 1980's the Installation Restoration Program (IRP) which is the DOD version of the EPA Superfund to identify assess and remediate environmental contamination sites in military bases and protect the health of workers, military families and the surrounding population. On or about 1995, a radioactive waste site at Tinker AFB was cleaned up (I was Base Radiation Safety Officer at the time). When I retired in 1997, a second radioactive waste site was being remediated (radiation levels were insignificant around the sites prior to cleanup and were in areas where no one was exposed). I hope that I have helped clarify this issue.
Jorge A. Delucca, Major, USAF (Retired)