Posts Tagged ‘Disease Burden’
Well, maybe a few. Such as the quote from the West Virginia woman. . .
How can we get digital cable and Internet in our homes, but not clean water?
. . . after having to treat her kid for skin lesions because he’s bathed in water contaminated with nickel, or get crowns on the teeth of another kid of hers after metals-contaminated drinking water has eroded the enamel off the kid’s teeth.
How about, “because we care more about digital cable and Internet than clean water”. How about, “because we’ve learned to not think of clean water as a right that we have to continue to fight for”. How about “because the political will which was around 40 years ago to give us the Clean Water Act and the Safe Drinking Water Act is has disappeared”. How about, “because we abrogate this responsibility for our health, leaving it in the hands of politicians and bureaucrats”.
The tone of the New York Times article implies that the government should be doing more, such as more stringent enforcement, or beefing up the resources of regulatory agencies. Helpfully, the article provides a database that allows readers to identify violations of Clean Water Act or Safe Drinking Water Act regulations in their area. There are similar products available from EPA such as EnviroFacts and the TRI database. However these all reflect operational and management metrics – how many permit violations have occurred or how many pounds of chemicals are emitted – which don’t really say anything about environmental conditions or the risks encountered by humans or the ecosystem. These still reflect the “command and control” style of environmental management which some in EPA through the Unfinished Business and Reducing Risk reports were considering to be obsolete as long as 20 years ago. Not addressed in the New York Times article is the idea that the existing command and control regulatory structure developed in the 1970s and 1980s NPDES, RCRA, Clean Air Act permitting and enforcement – is broken.
There is some recognition that a new framework for environmental protection is needed, which acknowledges that health and ecological risks are related to where a community is located, that multiple and overlapping sources of contaminant releases might affect members in that community, and that the best measure of risk is based on what types and levels of contaminants those individuals are exposed to. EPA has developed frameworks for community-based risk assessment and cumulative risk assessment, which acknowledge:
In many cases, human health often is directly related to where one lives. Certain communities, groups, or individuals within a community may be more at risk than others from multiple exposures to chemicals based on the location of a town; the individual’s location within a town; activities, such as commuting to work or school or exercising; dietary patterns of residents; or socioeconomic status. Focusing on the community provides a rational starting point for developing, evaluating, and applying cumulative risk tools to determine the risk of chemical mixtures.
Of course, characterizing risks with this framework involves more monitoring, particularly from the locations where the people or affected wildlife are located, possibly including biomonitoring using biomarkers and genomic markers. The current tools such as EnviroFacts and the TRI, which don’t really tell you anything about what you’re being exposed to aren’t what’s needed for community-based risk assessment. Also, the existing regulatory and legal framework, which is source- and industry-based, becomes an impediment to this very sensible risk-based approach. Who “owns” the liability and responsibility for what pollution? How do you prove that my releases (says the local chemical company) are producing your body burden? That regulatory framework is also going to become an impediment to implementing sustainable chemical production techniques (“green chemistry”), an initiative that also will revolutionize environmental protection.
Without a new paradigm in environmental protection that’s community-based, or oppressive enforcement of the current command and control regulatory framework, we’ll continue to have problems such as kids getting rashes and having their teeth fall from contaminated drinking water.
Enter data judo (to be continued).
With all of the handwringing, I mean debate, about health care reform these, I wonder if anyone is going to get around to talking about and dealing with some of the underlying factors that would actually keep us from getting sick. Or, are the conversations going to continue to be about money and political power? Trying to do things to reduce the disease burden, which might correspondingly promote reform, doesn’t seem to be a prominent part of the discussion yet.
What prompted this line of thought was the announcement that David Michaels was being nominated as administrator of the Occupational Safety and Health Administration (OSHA). Dr. Michaels is an epidemiologist, and has prior experience with issues of protecting worker health. He will have a role in reducing the occupational disease burden, which indirectly may support health care reform.
How important is occupational disease? The annual burden of occupational disease mortality was estimated in 2003 by NIOSH researchers to be 49,000, with a range from 26,000 to 72,000. When added to the approximate 6,000 deaths from occupational accidents, work becomes the 8th leading cause of death in the U.S., after diabetes and ahead of motor vehicle accidents. The causes of deaths from occupational diseases were selected respiratory diseases, cancers, cardiovascular disease, chronic renal failure, and hepatitis. The annual cost of occupational illnesses and injuries has been estimated to be between $128 and $155 billion per year.
Something that might help reduce the occupational disease burden is to bring occupational exposure standards up to date, and make them relevant in light of today’s toxicological and epidemiological research.
The Occupational Safety and Health Administration (OSHA) is responsible for developing standards that will assure, “. . . that no employee will suffer material impairment of health or functional capacity even if such employee has regular exposure to the hazard. . . for the period of his working life.” In other words, achieving a safe and healthful workplace occurs through setting enforceable workplace standards that are based on allowable limits for worker exposure. OSHA hasn’t done a lot of exposure standards development in recent years. The easy answer would be to blame the G.W. Bush Administration business-friendly policies as the reason for this inaction. But exposure standards had been a problem long before the Bushies seized power.
OSHA sets enforceable Permissible Exposure Limits (PELs) which are regulatory limits on the amount or concentration of a hazardous substance that can be in the air in a workplace. When the OSH Act was enacted in 1970, OSHA needed PELs for lots of hazardous substances, right away. For this purpose OSHA reached out to use Threshold Limit Values (TLVs). TLVs are non-enforceable guidelines developed by the American Conference of Governmental Industrial Hygienists (ACGIH). TLVs “refer to airborne concentrations of substances, and it is believed represent conditions under which nearly all workers may be repeatedly exposed, day after day, without adverse effect”.
Years passed. TLVs were updated from time to time. The National Institute for Occupational Safety and Health began developing Recommended Exposure Limits (RELs), non-enforceable exposure limits similar in concept to TLVs. In 1989, OSHA tried to update its PELs, by adopting TLVs and RELs which presumably were based on more recent and better scientific data. That rule was thrown out of court in 1992 ironically in a suit brought by the AFL-CIO. The court directed OSHA to do risk assessments. . . on nearly 400 chemicals. So, the PELs returned to their obsolete, 1970 values (when OSHA was first enacted) which in many cases are based on even older science. With few exceptions, OSHA hasn’t attempted to promulgate new exposure standards, and Congress apparently hasn’t seen fit to push matters along, either.
The situation isn’t all bleak. TLVs have been updated, and while they are non-enforceable, the employers who are concerned about protecting the health of their workers have some better benchmarks than PELs. While NIOSH hasn’t been involved with standards development in awhile, EPA continues, slowly, to evaluate the dose-response of chemical substances through IRIS, the Integrated Risk Information System. Someday though, the EPA toxicologists and the industrial hygiene community will need to get on the same page regarding how to set thresholds of protectiveness – there are distinctly different philosophies used for the general public versus workers. That’s a topic for another day.
Looking at Dr. Michael’s biosketch, it’s apparent that the man knows something about exposure limits. Should his appointment be confirmed by the Senate, it will be interesting to see how he responds to the challenge of reforming PELs.
I’ll update this with links later. I’m tired, and there’s too much to do right now.