How we’re protected from chemical exposures.

4 03 2014

I always thought I wouldn’t have to worry about some things – like, oh,  incoming missiles,  terrorist plots, and chemicals which could destroy me – because I thought my government would have something in place to protect me.  But the recent chemical spill in West Virginia changed that: for those of you who don’t know, that was a spill of  about 10,000 gallons of what is called a “coal cleaner”  into the Elk River, contaminating the water supply of 300,000 people.

When I first began looking into the chemicals used in fabrics, and finding out that the soft, luscious fabrics we surround ourselves with every day are filled with chemicals that can cause me grievous harm, I was stopped in my tracks when someone suggested that the government wouldn’t let those chemicals in products sold in the USA – so how could fabrics contain those chemicals?   I didn’t have an answer for that, because at the time I too thought  that “of course the government must have laws in place to make sure we aren’t exposed to dangerous chemicals”!

The current regulation of chemicals in the US dates back to 1976 and the Toxic Substances Control Act (TSCA), which regulates the introduction of new or already existing chemicals.

But before talking about the TSCA, let’s first take a quick look at what’s changed since 1976,  because our understanding of the extent and pathways of chemical exposures has fundamentally changed since then.

We now know that the old belief that “the dose makes the poison” (i.e.,  the higher the dose, the greater the effect)  is simply wrong.  Studies are finding that even tiny quantities of chemicals – in the parts-per-trillion range – can have significant impacts on our health.  We’re also finding that mixtures of chemicals, each below their “no observed effect level”, may have greater environmental impacts than the chemicals alone.   In other words, toxins can make each other more toxic:   a dose of mercury that would kill 1 out of 100 rats, when combined with a dose of lead that would kill 1 out of 1000 rats – kills every rat exposed.

We also now know that timing and order of exposure is critical –  exposures can happen one after the other, or all at once.  The possible combinations of exposures is huge and knowledge is limited about the effects of mixed exposures.  During gestation and through early childhood  the body is rapidly growing  under a carefully orchestrated process that is dependent on a series of events.  When one of those events is interrupted, the next event is disrupted – and so on –  until permanent and irreversible changes result. These results could be very subtle — like an alteration in how the brain develops which impacts, for example, learning ability.  Or it could result in other impacts like modifying the development of an organ predisposing it to cancer later in life.

Add to that the concept of individual susceptibility.  For instance a large part of the population is unable to effectively excrete heavy metals, so their body burden accumulates faster, and their illnesses are more obvious.  They are the “canaries in the coal mine” in an environment that’s becoming increasingly more toxic.

We’re finding that chemicals migrate from products into the environment (and remember, we are part of the environment).

And this is where it gets really interesting:

Each of us starts life with a particular set of genes, 20,000 to 25,000 of them. Now scientists are amassing a growing body of evidence that pollutants and chemicals might be altering those genes—not by mutating or killing them, but by sending subtle signals that silence them or switch them on at the wrong times.  This can set the stage for diseases which can be passed down for generations.  This study of heritable changes in gene expression – the chemical reactions that switch parts of the genome off and on at strategic times and locations –  is called “epigenetics”.

They’re finding that exposure to chemicals is capable of altering genetic expression, not only in your children, but in your children’s children – and their children too.  Researchers at Washington State University found that when pregnant rats were exposed to permethrin, DEET or any of a number of industrial chemicals, the mother rats’ great grand-daughters had higher risk of early puberty and malfunctioning ovaries — even though those subsequent generations had not been exposed to the chemical.[1]  Another recent study has shown that men who started smoking before  puberty caused their sons to have significantly higher rates of obesity. And  obesity is just the tip of the iceberg—many researchers believe that epigenetics  holds the key to understanding cancer, Alzheimer’s, schizophrenia, autism, and  diabetes. Other studies are being published which corroborate these findings.[2]

With the advent of biomonitoring, and a growing recognition of the importance of early life exposures, low dose effects and epigenetics, the science linking environmental exposures to biological effects (i.e., disease) is becoming overwhelming.

And here’s why the Toxic Substances Control Act of 1976 is not doing the job of protecting us:

  • We assume the TSCA is testing and regulating chemicals used in industry. It is not:
    • Of the more than 60,000 chemicals  in use prior to 1976, most were “grandfathered in”; only 200 were tested for safety and only 5 were restricted.  Today over 80,000 chemicals are routinely used in industry, and the number which have been tested for safety has not materially changed since 1976.  So we cannot know the risks of exposing ourselves to certain chemicals.  The default position is that no information about a chemical = no action.
    • For those of you who don’t know, the spill in West Virginia was of “crude MCHM”, or 4-methylcyclohexanemethanol, one of the chemicals that was grandfathered in to the Toxic Substances Control Act of 1976.   That means that nobody knows for sure what that chemical can do to us.
      • Carcinogenic effects? No information available.
      • Mutagenic effects? No information available.
      • Developmental toxicity? No information available.     Lack of information is the reason the local and federal authorities were so unsure of how to advise the local population about their drinking  water supplies.  (And by the way, in January, 2014,  a federal lawsuit was filed in Charleston, WV, which claims that the manufacturer of MCHM hid “highly toxic and carcinogenic properties” of components of MCHM, hexane and methanol, both of which have been tested and found to cause diseases such as cancer.)
  • We assume that the TSCA requires manufacturers to demonstrate their chemicals are safe before they go into use.  It does not:
    • The law says the government has to prove actual harm caused by the chemical in question before any controls can be put in place.  The catch-22 is that chemical companies don’t have to develop toxicity data or submit it to the EPA for an existing product unless the agency find out that it will pose a risk to humans or the environment – which is difficult to do if there is no data in the first place.  Lack of evidence of harm is taken as evidence of no harm.
  • We assume that manufacturers must list all ingredients in a product, so if we have an allergy or reaction to certain chemicals we can check to see if the product is free of those chemicals.  It does not:
    • TSCA allows chemical manufacturers to keep ingredients in some products secret.   Nearly 20% of the 80,000 chemicals in use today are considered “trade secrets”.  This makes it impossible for consumers to find out what’s actually in a product.  And there is no time limit on the period in which a chemical can be considered a trade secret.

These limitations all help to perpetuate the chemical industry’s failure to innovate toward safer chemical and product design.  It’s one of the reasons the USA is one of the few nations in the world in which asbestos is not banned in many products.

In 2013, the Chemical Safety Improvement Act (CSIA) was introduced, however it does not deliver the critical fixes needed to fix the TSCA, although it is an improvement to the TSCA.  The Natural Resources Defense Council suggests some steps that we must take to reform the TSCA, and these apply to the CSIA also:

  • Require new and existing chemicals be assessed for safety – with mandatory and enforceable deadlines.  “Innocent until proven guilty” should not apply to chemicals.
  • Establish safety standards, especially with regard to children and other vulnerable groups.
  • Give the EPA the authority to protect the public from unsafe chemicals, including expedited action for those deemed the most toxic.
  • “Grandfathering in” spells trouble for the future.
  • Ensure the public’s right to know about the safety and use of chemicals.
  • Allow states to maintain laws which exceed federal protections to safeguard their citizens.
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Can you find out what’s in your fabric?

28 03 2013

I was one of those people who thought that manufacturers were not “allowed” to sell me any product that contained something that might harm me. As I quickly learned, that’s basically not true in the United States – especially with respect to fabrics. The EU is light years ahead of the US with their REACH program, designed to replace the most harmful chemicals with less toxic alternatives, but even that program focuses only on only the most high volume chemicals used in industry.
Let me just remind you why knowing what chemicals are used for processing your fabrics is important:
Because fabrics – all fabrics – are by weight about 25% finishing chemicals (i.e. dyes, finishes, softeners, etc.) And because the textile industry uses over 2000 chemicals routinely, how do we know the mix in the fabrics we’re living with are safe?
Well, you can ask the store where you’re buying the sheets or shirts – but they’ll probably look at you blankly.
You can demand information from the manufacturer. But often they don’t know the answers. To illustrate why this is, let’s take one example. Let’s pretend we’re a mill and we have just woven an organic cotton fabric, and we want to dye it. We can choose from many dyes, but settle on one called “Matisse Derivan” manufactured by Derivan Fabric Dye. Because dyes are made up of many chemicals, and because they’re proprietary, it’s next to impossible to find out what is in the particular dye you’re buying. So you might think the MSDS sheet would give us the information.
MSDS sheets are sometimes used to substantiate the “safety” of a chemical product by requiring the listing of chemical components by CAS number, which is a unique numeric identifier of a chemical substance which links to a wealth of information about that chemical. But the reality is that many of the chemicals used in industry (textile or otherwise) have never been evaluated for toxicity, and therefore in the toxicity evaluation there is no data to refer to. In addition, proprietary components do not need to be listed. So the sheets have inaccurate or missing information. According to a 2008 study, between 30 – 100% of products analyzed contained chemicals not declared on an MSDS.(1)
The MSDS sheet for Matisse Derivan (click here to see the sheet) for example, lists these substances in the composition of the dye:

SUBSTNACE                                   CAS NUMBER

  • Pigments                                             Various
  • water-based acrylic co-polymer      Proprietary
  • surfactants, dispersants, etc.           Various
  • ammonia                                             1336-21-6
  • water

In looking at an MSDS sheet, you might also find that any hazard classification or risk phase has “not been established” and “the toxicological properties of this product have not been thoroughly investigated”, or the hazard classification might be identified as “non hazardous” according to various codes, such as the TSCA. These codes are woefully inadequate as is now known (click here for more information) so to say that a chemical is non hazardous according to a code that dismisses all chemicals for which there is no data – well, you can see the problem.
There is also a lack of enforceable quality criteria, probably one of the reasons the sheets are of such poor quality.
Because testing has been done to establish wastewater criteria, some studies have shown what types of chemicals are found in textile wastewater from dyes, such as one which found benzidine, vinyl-p-base and 4-aminoazobenzene – all quite toxic.(2)
Once you get the information on the dyestuff used you’re one chemical component down  – and maybe 20 to go, because in most fabrics these functional areas also require chemical treatments:
Textile auxiliaries (such as complexing, wetting, sequestering, dispering agents; emulsifiers), textile chemicals (dyes, dye-protective, fixing, leveling agents; pH regulators, carriers, UV absorbers); finishes (stain, odor, wrinkle resistance).
And finally, even if you were able to find out which particular chemicals are used in a product, it’s possible that you won’t know what you’re looking at. For example, most everyone knows to avoid formaldehyde, but manufactures can legally use over 30 different trade names for formaldehyde, such as:
• Formalin
• Quaternium-15
• Methanal
• Methyl Aldehyde
• Methylene Oxide
• Oxymethylene
• Bfv
• Fannoform
• Formol
• Fyde
• Karsan
• Methaldehyde
• Formalith
• Methylene Glycol
• Ivalon
• Oxomethane

[1] http://www.ncbi.nlm.nih.gov/pubmed/18651574

(2)  Rehorek, A and Plum, A; Characterization of sulfonated azo dyes and aromatic amines by pyrolysis gas chromatography/mass spectrometry; Analitical and Bioanalytical Chemistry, Aug 2007; 388(8): 1653-62.





Something YOU can do!

20 04 2011

We’ve pointed out in several blog postings the names of various chemicals that are used in textile processing which are known to cause cancer.   These include (but aren’t limited to) antimony, pentachlorophenol, methylene chloride, arsenic, formaldehyde, phthalates, benzenes, PVC, sulfuric acid, acrylonitrile.  The fabrics we live with are full of chemicals that are known to cause cancer.  But so are lots of other products on the shelves of stores across America. And as Greenpeace reminds us, one American will die from cancer every minute during 2011.

Many Americans assume that their government protects them from exposure to chemicals that might harm them.  But according to GreenAnswers.org, it does not:

“Here’s a disturbing fact: The 33 year-old law that is supposed to protect Americans from exposure to toxic chemicals is so outdated that China legally exports toxic materials into the U.S. that are not only banned in Japan and Europe, but can’t even be used domestically in China.

Here’s another: Of the 82,000 chemicals available for use in the U.S., only about 200 have been required to be tested for safety.

Thousands of chemicals that have not been tested for safety are used in common items found in homes across America: in children’s toys and bottles, in food cans and soda can linings, in our mattresses, computers, shampoos, lotions and more.

Due to this unchecked exposure, the U.S. Centers for Disease Control and Prevention have found toxic chemicals in the bodies of virtually all Americans. Some of these are linked to increases in prostate and breast cancers, diabetes, heart disease, lowered sperm counts, early puberty and other diseases and disorders.

Unlike every other major environmental law, the nation’s main chemical safety law, Toxic Substances Control Act (TSCA), has never been significantly amended since it was adopted in 1976. TSCA has serious flaws that prevent it from ensuring chemical safety in the U.S. It needs to be reformed and strengthened for our safety.

About one year ago, the National Cancer Institute (NCI) presented the President’s Cancer Panel report, in which they said that environmentally caused cancers are “grossly underestimated” and “needlessly devastate American lives.”

The report blames weak laws, lax enforcement and fragmented authority, as well as the fact that in the U.S., chemicals are assumed to be safe unless strong evidence proves otherwise.

Also about one year ago, in April, 2010, U.S. Senator Frank Lautenberg (D-NJ) announced legislation to overhaul TSCA.  It was called the “Safe Chemicals Act of 2010”. 
But one year, six congressional hearings and 10 “stakeholder sessions” later, the bill was killed, a testament to the combined clout of the $674 billion chemical industry, the companies that use those chemicals in their products,  and the stores that sell them.(1)

But Greenpeace thinks the issue is too important to let die.  It is joining up with 200 coalition groups to deliver a petition to President Obama in early May, asking him to make it a top priority to stop the use of cancer-causing chemicals in American products. (PLEASE join us, and sign the petition!  Click here).

Here’s the letter from Greenpeace:

One American will die from cancer every minute this year.

We all know someone impacted by cancer.   Yet despite the devastation it causes to our friends and families, it’s perfectly legal for companies to add known cancer-causing chemicals to products we use every day in our homes, schools and workplaces. That can change.

President Obama has the ability to reverse decades of failed policies and set the course for a national cancer prevention strategy that includes eliminating the use of cancer-causing chemicals in everyday products. But he’s not going to do it if people everywhere don’t speak out.

The NCI report’s final recommendation was for the President to “most strongly use the power” of his office to eliminate human exposure to cancer-causing chemical. We couldn’t agree more. Show him that you agree as well by signing the petition.

Cancer is a horrible disease but it can be prevented. It’s high time we made cancer prevention one of our highest national priorities.

For a safer and healthier future,

Rick Hind
Greenpeace Toxics Campaigner

All I can say is: amen.

REFERENCES:

(1) http://www.politicsdaily.com/2010/10/13/reform-of-toxic-chemicals-law-collapses-as-industry-flexes-its-m/





Lead and fabrics

27 10 2010

We published a post about lead in fabrics about a year ago, but I thought it was important enough to remind you of the dangers of lead in fabrics, because we’re starting to see claims of “heavy metal free” dyestuffs used in fabrics.  What does that mean?

Lead is considered one of those “heavy metals’ , along with mercury, cadmium, copper and others – all highly toxic to humans.  “Heavy metal” is defined as any metallic element that has a relatively high density and is toxic or poisonous at low concentrations.

Heavy metals are natural components of the Earth’s crust. They cannot be degraded or destroyed.  Interestingly, small amounts of these elements are common in our environment and diet and are actually necessary for good health. Lead can even be found in natural fibers, such as cotton, flax and hemp, which can absorb it from the environment.
It’s when our bodies have to deal with large amounts of these heavy metals that we get into trouble.   Heavy metal poisoning could result, for instance, from drinking-water contamination (e.g. lead pipes), high ambient air concentrations near emission sources,  intake via the food chain or through skin absorption – and in the case of  crawling children, from inhaling carpet particles or other abraded textiles in dust.  For some heavy metals, toxic levels can be just above the background concentrations naturally found in nature. Therefore, it is important for us to inform ourselves about the heavy metals and to take protective measures against excessive exposure.  Lead accounts for most of the cases of pediatric heavy metal poisoning, according to the Agency for Toxic Substances and Disease Registry (ATSDR).

Lead is a neurotoxin – it affects the human brain and cognitive development, as well as the reproductive system. Some of the kinds of neurological damage caused by lead are not reversible.  Specifically, it affects reading and reasoning abilities in children, and is also linked to hearing loss, speech delay, balance difficulties and violent tendencies. (1)

A hundred years ago we were wearing lead right on our skin. I found this article funny and disturbing at the same time:

“Miss P. Belle Kessinger of Pennsylvania State College pulled a rat out of a warm, leaded-silk sack, noted that it had died of lead poisoning, and proceeded to Manhattan. There last week she told the American Home Economics Association that leaded silk garments seem to her potentially poisonous. Her report alarmed silk manufacturers who during the past decade have sold more than 100,000,000 yards of leaded silk without a single report of anyone’s being poisoned by their goods. Miss Kessinger’s report also embarrassed Professor Lawrence Turner Fairhall, Harvard chemist, who only two years ago said: ‘No absorption of lead occurs even under extreme conditions as a result of wearing this material in direct contact with the skin’. ”

This was published in Time magazine,  in 1934.  (Read the full article here. )

According to Ruth Ann Norton, executive director of the Coalition to End Childhood Lead Poisoning, “There are kids who are disruptive, then there are ‘lead’ kids – very disruptive, very low levels of concentration.” 
Children with a lead concentration of less than 10 micrograms ( µ) per deciliter (dl = one tenth of a liter) of blood scored an average of 11.1 points lower than the mean on the Stanford-Binet IQ test. (2)   Consistent and reproducible behavioral effects have been seen with blood levels as low as 7 µ/dl (micrograms of lead per tenth liter of blood), which is below the Federal standard of 10 µ/dl.   The image depicts what happens to human beings at the various levels of lead in blood.  Scientists are generally in agreement that there is no “safe” level of blood lead.  Lead is a uniquely cumulative poison:  the daily intake of lead is not as important a determinant of ultimate harm as is the duration of exposure and the total lead ingested over time.

Lead is widely  used in consumer products, from dyestuffs made with lead (leading to lead poisoning in seamstresses at the turn of the century, who were in the habit of biting off their threads) (3), to lead in gasoline, which is widely credited for reduced IQ scores for all children born in industrialized countries between 1960 and 1980 (when lead in gasoline was banned).  Read more about this here.

Lead is used in the textile industry in a variety of ways and under a variety of names:

  • Lead acetate                     dyeing of textiles
  • Lead chloride                   preparation of lead salts
  • Lead molybdate             pigments used in dyestuffs
  • Lead nitrate                     mordant in dyeing; oxidizer in dyeing(4)

Fabrics sold in the United States, which are used to make our clothing, bedding and many other products which come into intimate contact with our bodies, are totally unregulated – except in terms of required labeling of percentage of fiber content and country of manufacture.  There are NO laws which pertain to the chemicals used as dyestuffs, in processing, in printing,  or as finishes applied to textiles, except those that come under the Toxic Substances Control Act (TSCA) of 1976, which is woefully inadequate in terms of addressing the chemicals used by industry.   With regard to lead, products cannot contain more than 100 ppm – despite many studies that show there is no safe level for lead. In fact, the Government Accounting Office (GAO) has announced that the 32 year old TSCA needs a complete overhaul (5), and the Environmental Protection Agency (EPA)  was quick to agree! (6).  Lisa Jackson, head of the EPA,  said on September 29, 2009 that the EPA lacks the tools it needs to protect people and the environment from dangerous chemicals.

Fabrics are treated with a wide range of substances that have been proven not to be good for us.  That’s why we feel it’s important to buy third party certified FABRICS, not just certified organic fibers (which do nothing to guarantee the dyestuffs or finish chemicals used in the fabric) such as GOTS (Global Organic Textile Standard) or Oeko Tex, both of which prohibit the use of lead in textile processing.

The United States has new legislation which lowers the amount of lead allowed in children’s products – and only children’s products.   (This ignores the question of  how lead  in products used by pregnant  women may affect their fetus.  Research shows that as the brains of fetuses develop, lead exposure from the mother’s blood can result in significant learning disabilities.)  The new Consumer Product Safety Improvement Act (CPSIA) had requirements to limit lead content in children’s products (to be phased in over three years) so that by August 14, 2011, lead content must be 100 ppm (parts per million) or less.

However there was an outcry from manufacturers of children’s bedding and clothing, who argued that the testing for lead in their products did not make sense, because:

  • it placed an unproductive burden on them, and
  • it required their already safe products to undergo costly or unnecessary testing.

The Consumer Product Safety Commission voted to exempt textiles from the lead testing and certification requirements of the CPSIA, despite the fact that lead accounts for most of the cases of pediatric heavy metal poisoning, according to the Agency for Toxic Substances and Disease Registry (ATSDR).

So let me repeat here: the daily intake of lead is not as important a determinant of ultimate harm as is the duration of exposure and the total lead ingested over time.

Children are uniquely susceptible to lead exposure over time, and  neural damage occurring during the period from 1 to 3 years of age is not likely to be reversible.  It’s also important to be aware that lead available from tested products would not be the only source of exposure in a child’s environment.  Although substantial and very successful efforts have been made in the past twenty years to reduce environmental lead, children are still exposed to lead in products other than toys or fabrics. Even though it was eliminated from most gasoline in the United States starting in the 1970s, lead continues to be used in aviation and other specialty fuels. And from all those years of leaded gasoline, the stuff that came out of cars as fuel exhaust still pollutes soil along our roadways, becoming readily airborne and easily inhaled.   All lead exposure is cumulative – so it’s important to eliminate any source that’s within our power to do so.

(1) “ ‘Safe’ levels of lead still harm IQ”, Associated Press, 2001

(2) Ibid.

(3) Thompson, William Gilmsn, The Occupational Diseases, 1914, Cornell University Library, p. 215

[4] “Pollution of Soil by Agricultural and Industrial Waste”, Centre for Soil and Agroclimate Research and Development, Bogor, Indonesia, 2002.   http://www.agnet.org/library/eb/521/

(4) http://www.atsdr.cdc.gov/toxprofiles/tp13-c5.pdf

(5) http://www.rsc.org/chemistryworld/News/2009/January/29010901.asp

(6) http://www.bdlaw.com/news-730.html





Do we need a national plastics control law?

20 10 2010

John Wargo wears at least three hats:  he is a professor of environmental policy, risk analysis, and political science at the Yale School of Forestry & Environmental Studies, he chairs the Environmental Studies Major at Yale College, and is an advisor to the U.S. Centers for Disease Control and Prevention.  He published this opinion on plastics in the United States last year – and I couldn’t have said it better myself:

Since 1950, plastics have quickly and quietly entered the lives and bodies of most people and ecosystems on the planet. In the United States alone, more than 100 billion pounds of resins are formed each year into food and beverage packaging, electronics, building products, furnishings, vehicles, toys, and medical devices. In 2007, the average American purchased more than 220 pounds of plastic, creating nearly $400 billion in sales.

It is now impossible to avoid exposure to plastics. They surround and pervade our homes, bodies, foods, and water supplies, from the plastic diapers and polyester pajamas worn by our children as well as our own sheets, clothing and upholstery,  to the cars we drive and the frying pans in which we cook our food.

The ubiquitous nature of plastics is a significant factor in an unexpected side effect of 20th century prosperity — a change in the chemistry of the human body. Today, most individuals carry in their bodies a mixture of metals, pesticides, solvents, fire retardants, waterproofing agents, and by-products of fuel combustion, according to studies of human tissues conducted across the U.S. by the Centers for Disease Control and Prevention. Children often carry higher concentrations than adults, with the amounts also varying according to gender and ethnicity. Many of these substances are recognized by the governments of the United States and the European Union to be carcinogens, neurotoxins, reproductive and developmental toxins, or endocrine disruptors that mimic or block human hormones.

Significantly, these chemicals were once thought to be safe at doses now known to be hazardous; as with other substances, the perception of danger grew as governments tested chemicals more thoroughly. Such is the case with Bisphenol-A (BPA), the primary component of hard and clear polycarbonate plastics, which people are exposed to daily through water bottles, baby bottles, and the linings of canned foods.

Given the proven health threat posed by some plastics, the scatter shot and weak regulation of the plastics industry, and the enormous environmental costs of plastics — the plastics industry accounts for 5 percent of the nation’s consumption of petroleum and natural gas, and more than 1 trillion pounds of plastic wastes now sit in U.S. garbage dumps — the time has come to pass a comprehensive national plastics control law.

One might assume the United States already has such a law. Indeed, Congress adopted the Toxic Substances Control Act (TSCA) in 1976 intending to manage chemicals such as those polymers used to form plastics. Yet TSCA was and is fundamentally flawed for several reasons that have long been obvious. Nearly 80,000 chemicals are now traded in global markets, and Congress exempted nearly 60,000 of them from TSCA testing requirements. Among 20,000 new compounds introduced since the law’s passage, the U.S. Environmental Protection Agency (EPA) has issued permits for all except five, but has required intensive reviews for only 200. This means that nearly all chemicals in commerce have been poorly tested to determine their environmental behavior or effects on human health. The statute’s ineffectiveness has been recognized for decades, yet Congress, the EPA, and manufacturers all share blame for the failure to do anything about it.

In contrast, the European Union in 2007 adopted a new directive known as “REACH” that requires the testing of both older and newly introduced chemicals. Importantly the new regulations create a burden on manufacturers to prove safety; under TSCA the burden rests on EPA to prove danger, and the agency has never taken up the challenge. Unless the U.S. chooses to adopt similar restrictions, U.S. chemical manufacturers will face barriers to their untested exports intended for European markets. Thus the chemical industry itself recognizes the need to harmonize U.S. and EU chemical safety law.

The most promising proposal for reform in the U.S. is the “Kid-Safe Chemical Act,” a bill first introduced in 2008 that would require industry to show that chemicals are safe for children before they are added to consumer products. Such a law is needed because there is little doubt that the growing burden of synthetic chemicals has been accompanied by an increase in the prevalence of many illnesses during the past half-century. These include respiratory diseases (such as childhood asthma), neurological impairments, declining sperm counts, fertility failure, immune dysfunction, breast and prostate cancers, and developmental disorders among the young. Some of these illnesses are now known to be caused or exacerbated by exposure to commercial chemicals and pollutants.

Few people realize how pervasive plastics have become. Most homes constructed since 1985 are wrapped in plastic film such as Tyvek, and many exterior shells are made from polyvinyl chloride (PVC) siding. Some modern buildings receive water and transport wastes via PVC pipes. Wooden floors are coated with polyurethane finishes and polyvinyl chloride tiles.

Foods and beverages are normally packaged in plastic, including milk bottles made from high-density polyethylene. Most families have at least one “non-stick” pan, often made from Teflon, a soft polymer that can scratch and hitchhike on foods to the dinner table. Between 1997 and 2005, annual sales of small bottles of water — those holding less than one liter — increased from 4 billion to nearly 30 billion bottles.

The billions of video games, computers, MP3 players, cameras, and cell phones purchased each year in the United States use a wide variety of plastic resins. And the almost 7.5 million new vehicles sold in the United States each year contain 2.5 billion pounds of plastic components, which have little hope of being recycled, especially if made from polyvinyl chloride or polycarbonate.  The American Plastics Council now estimates that only about 5 percent of all plastics manufactured are recycled; 95 billion pounds are discarded on average yearly.

The chemical contents of plastics have always been a mystery to consumers. Under federal law, ingredients need not be labeled, and most manufacturers are unwilling or unable to disclose these contents or their sources. Indeed, often the only clue consumers have to the chemical identity of the plastics they use is the voluntary resin code designed to identify products that should and should not be recycled — but it offers little usable information.

The true costs of plastics — including the energy required to manufacture them, the environmental contamination caused by their disposal, their health impacts, and the recycling and eventual disposal costs — are not reflected in product prices.  Adding to the environmental toll, most plastic is produced from natural gas and petroleum products, exacerbating global warming.

Plastics and Human Health

The controversy over BPA — the primary component of hard and clear plastics — and its potential role in human hormone disruption provides the most recent example of the need for a national plastics control law.

Normal growth and development among fetuses, infants, children, and adolescents is regulated in the body by a diverse set of hormones that promote or inhibit cell division. More than a thousand chemicals are now suspected of affecting normal human hormonal activity. These include many pharmaceuticals, pesticides, plasticizers, solvents, metals, and flame retardants.

Scientists’ growing interest in hormone disruption coincided with a consensus within the National Academy of Sciences that children are often at greater risk of health effects than adults because of their rapidly growing but immature organ systems, hormone pathways, and metabolic systems. And many forms of human illness associated with abnormal hormonal activity have become more commonplace during the past several decades, including infertility, breast and prostate cancer, and various neurological problems.

BPA illustrates well the endocrine disruption problem. Each year several billion pounds of BPA are produced in the United States. The Centers for Disease Control and Prevention has found, in results consistent with those found in other countries, that 95 percent of human urine samples tested have measurable BPA levels. BPA has also been detected in human serum, breast milk, and maternal and fetal plasma. BPA travels easily across the placenta, and levels in many pregnant women and their fetuses were similar to those found in animal studies to be toxic to the reproductive organs of the animals’ male and female offspring.

Government scientists believe that the primary source of human BPA exposure is foods, especially those that are canned, as BPA-based epoxy resins can migrate from the resins into the foods. In 1997, the FDA found that BPA migrated from polycarbonate water containers — such as the five-gallon water jugs found in offices — into water at room temperature and that concentrations increased over time. Another study reported that boiling water in polycarbonate bottles increased the rate of migration by up to 55-fold, suggesting that it would be wise to avoid filling polycarbonate baby bottles with boiling water to make infant formula from powders.

Scientists have reported BPA detected in nonstick-coated cookware, PVC stretch film used for food packaging, recycled paperboard food boxes, and clothing treated with fire retardants.

Since 1995 numerous scientists have reported that BPA caused health effects in animals that were similar to diseases becoming more prevalent in humans, abnormal penile or urethra development in males, obesity and type 2 diabetes, and immune system disorders. BPA can bind with estrogen receptors in cell membranes following part-per-trillion doses — exposures nearly 1,000 times lower than the EPA’s recommended acceptable limit.

In 2007, the National Institutes of Health convened a panel of 38 scientists to review the state of research on BPA-induced health effects. The panel, selected for its independence from the plastics industry, issued a strong warning about the chemical’s hazards:

“There is chronic, low level exposure of virtually everyone in developed countries to BPA… The wide range of adverse effects of low doses of BPA in laboratory animals exposed both during development and in adulthood is a great cause for concern with regard to the potential for similar adverse effects in humans.”

The American Chemistry Council, which advocates for the plastics industry, has criticized most scientific research that has reported an association between BPA and adverse health effects. The council’s complaints have included claims that sample sizes are too small, that animals are poor models for understanding hazards to humans, that doses administered in animal studies are normally far higher than those experienced by humans, that the mechanism of chemical action is poorly understood, and that health effects among those exposed are not necessarily “adverse.”

Research on plastics, however, now comprises a large and robust literature reporting adverse health effects in laboratory animals and wildlife at even low doses. Claims of associations between BPA and hormonal activity in humans are strengthened by consensus that everyone is routinely exposed and by the rising incidence of many human diseases similar to those induced in animals dosed with the chemical. Two competing narratives — one forwarded by independent scientists and the other promoted by industry representatives — have delayed government action to protect the health of citizens through bans or restrictions.

Action Needed

How has the plastics industry escaped serious regulation by the federal government, especially since other federally regulated sectors that create environmental or health risks such as pharmaceuticals, pesticides, motor vehicles, and tobacco have their own statutes? In the case of plastics, Congress instead has been content with limited federal regulatory responsibility, now fractured among at least four agencies: the EPA, the Food and Drug Administration, the Consumer Product Safety Commission, and the Occupational Safety and Health Administration. None of these agencies has demanded pre-market testing of plastic ingredients, none has required ingredient labeling or warnings on plastic products, and none has limited production, environmental release, or human exposure. As a result, the entire U.S. population continues to be exposed to hormonally active chemicals from plastics without their knowledge or consent.

What should be done? The Kids Safe Chemical Act represents a comprehensive solution that would apply to all commercial chemicals including plastic ingredients. Yet the nation’s chemical companies, with their enormous political power, are not likely to agree to assume the testing costs, nor are they likely to accept a health protective standard. Rather than pass another weak statute, Congress should consider a stronger alternative.

The nation needs a comprehensive plastics control law, just as we have national laws to control firms that produce other risky products, such as pesticides. Key elements of a national plastics policy should include:

  • tough  government regulations that demand pre-market testing and prohibit chemicals that do not quickly degrade into harmless compounds. Exempting previously permitted ingredients from this evaluation makes little sense, as older chemicals have often been proven more dangerous than newer ones.
  • The chemical industry itself needs to replace persistent and hazardous chemicals with those that are proven to be safe.  Plastics ingredients found to pose a significant threat to the environment or human health should be quickly phased out of production. Congress chose this approach to manage pesticide hazards, and it has proven to be reasonably effective since the passage of the Food Quality Protection Act in 1996.
  • Federal redemption fees for products containing plastics should be set at levels tied to chemical persistence, toxicity, and production volume. These fees should be high enough that consumers have a strong incentive to recycle.
  • We need mandatory labeling of plastic ingredients, in order to allow consumers to make responsible choices in the marketplace.
  • Finally, manufacturers should take responsibility for cleaning up environmental contamination from the more than one trillion pounds of plastic wastes they have produced over the past 50 years.