By JAMES KROHE JR.

TOXICS: Where to begin?

One of the most perplexing issues facing the state and nation is regulation of toxic substances. Toxics are not an event, but a condition, one that defies generalizations. They are not just wastes; they are found in products we use at home and in the workplace, Regulations do exist on toxics, but not all toxics are regulated. Everything about toxics relates to risk.

There will be four more articles in this series on toxics. The second one in April will explain how risks are assessed when dealing with toxic substances. This series is made possible through grants from the Illinois Environmental Protection Agency and The Joyce Foundation.

THERE is a machine called a gas chromatograph/mass spectrometer which can detect the presence in the atmosphere of such gases as benzene in concentrations as rarefied as a few parts per trillion. Such machines may be understood not just as mechanical marvels but as symbols of the attempt to see and control the flow of toxic chemicals through the environment. They are expensive to buy and complex to run. They are sophisticated, and a little slow. And with them regulators can grab answers about toxics out of thin air.

Toxics are not an "environmental problem" in the 1970s style. They are a public health problem, and that poses awkward challenges to regulators who less than a decade ago measured the fatal effects of pollution in terms of dead fish. Regulators face not only the need to collect more information but more kinds of information.

The official national register of chemical substances bulges with more than nine million names. Of these, human ingenuity has contrived ways to make money from the manufacture and use of roughly 70,000, and another thousand or so new ones are introduced each year. Not all of these chemicals are toxic, although those that are not cannot reliably be identified at the moment, since only a handful have been exhaustively analyzed for possible effects on human health.

Illinois industry may be in decline, but there are still more than 10,000 smokestacks in the state, each capable of adding its own peculiar part to the state's toxic burden. Its exact rank is disputable, but Illinois is among the nation's top producers of toxic industrial wastes. Officially designated hazardous wastes comprise only one galaxy in the universe of toxics, but the volume of such leftovers suggests the magnitude of that universe. Any precise accounting is difficult; Illinois is home to tens of thousands of chemical plants, and foundries and pesticide plants and plating shops and paint manufacturers and electronics assemblers.

Estimates of the amount of officially defined hazardous wastes generated each year in Illinois vary from roughly 400 million gallons to 2.7 billion gallons. The smaller amount is derived from Illinois Environmental Protection Agency (IEPA) records, which are acknowledged to be incomplete; the larger is extrapolated from national data by methods acknowledged to be crude. In 1982 Senate President Philip J. Rock and Illinois Atty. Gen. Neil F. Hartigan formed a task force to study aspects of the hazardous wastes problem in Illinois. Concluded one task force committee, helplessly, "There is no basis on which to choose one estimate as better than another." Their conclusion might serve as a motto for toxics policymakers.

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Condition not event

What we face in toxics is not the familiar possibility that we don't know enough to act, but that we cannot know enough. The blind men touching the proverbial elephant had it easy. They had only to describe the large and ungainly beast they could not see, not regulate it. Regulation — including the regulation by the marketplace, which in theory is exercised inexorably if unconsciously by consumers making informed choices — depends utterly on knowledge. The world's ignorance about conventional pollutants has been ameliorated by decades of sustained scientific investigation; except for the heavy metals, toxics have been a topic of scientific inquiry since only about World War II. Partly as a result, practically nothing is "known" about the health effects of toxics in the way that it is known that typhoid fever is caused by the Salmonella typhosa bacillus.

Early research into toxics' health effects suggests disquieting questions but no real answers. Regulations about the use and disposal of toxics thus are based on provisional scientific truths, with the result that both are especially subject to revision, even contradiction. The regulation of conventional pollutants proceeded from a consensus about cause and effect, and disputes typically were over means more than ends. In the case of toxics there is no consensus, and everything is in dispute.

Unlike conventional pollution, toxic pollution is less an event than a condition. The laws, the administrative structures, the sampling protocols, even the language of environmental regulation that evolved during the hopeful campaigns against conventional pollutants in the 1970s are biased toward pollution that is discrete, episodic and comprehensible in both its causes and its effects. Toxics, on the other hand, tend to be pervasive, persistent, mobile and mysterious.

Eliminating conventional pollutants was never as simple as plugging up a pipe, but it is simpler than plugging up the many leaks by which toxics enter the water, soil and air. Hazardous wastes, we have learned, don't stay dead even after they've been buried, but can return to haunt the living. Certain organic solvents such as carbon tetrachloride can eat through clay landfill linings; the landfilling of liquid wastes was banned in Illinois as of 1985 as a result. Heavy metals are so armored against biological or chemical assault that they are practically immortal; unfortunately, the steel drums they are stored in are not. Flares installed to burn off the gas methane produced by decomposition of garbage in landfills may also be releasing buried PCBs (polychlorinated biphenyls) back into the atmosphere. Even securely lined landfills can, perversely, fill up with rainwater and overflow, a phenomenon known as the bathtub effect. Volatile organic compounds evaporate from sewage treatment plants where they arrive after having been flushed down sewer drains. Waste oils are often contaminated by heavy metals such as cadmium, arsenic or lead; when they are burned as boiler fuel they release unknown quantities of those toxics into the air.

The blind men touching the proverbial
elephant had it easy. They had only to describe
the large and ungainly beast they could
not see, not regulate it

Similarly, emissions of particulates and hydrocarbon intermediates (the latter the large class of petroleum fractions that includes solvents and plastics) have been dropping in Illinois to "just" (the Illinois EPA's word) 377,000 tons in 1982. But as Roger Kanerva, the IEPA's manager of environmental programs, put it in testimony to a U.S. Senate subcommittee in 1984, "available data is inadequate to define the extent of toxic chemical substances," in those emissions.

The unhappy lesson of the 1970s was that most of the accepted methods of disposing of toxics in fact merely moved them. Indeed, the then-cures often proved more confounding that the diseases. Factory wastes were no longer dumped into rivers, which could be cleaned up, but into landfills where they risked spoiling groundwater formations, which can't. Common house hold plastics could be burned instead of buried, in low-temperature municipal incinerators that transform those plastic molecules into dioxins. For those inclined to such conclusions, the 1970s offer a cautionary tale about the risks of regulating in advance of the facts.

Limitless scale

It was not only the nature of toxic pollution that was misconstrued in the 1970s but its scale. Cleaning up hazardous waste is itself such a daunting task that it is easy to forget that industrial waste is what is left over from some thing else. To an inattentive public, toxics are things that are dumped. Toxics, however, are also manufactured, transported, burned in boilers and used in factories, put into cans and bottles and sold in supermarkets. "Once generated or transported into the state," reads the IEPA's major policy statement on toxics, issued in 1984, "chemical substances may become toxic problems in a number of ways." Exposure of workers who use them is one such way. So are spills, "air releases" and other emergencies, and the home use of commercial products containing toxic ingredients.

In one form or another, toxics flow through an advanced industrial economy like blood through a body. For example:

• Illinois' chemical industry makes, or imports for use, roughly 3,600 different substances, many of which remain untested for toxic effects; total chemical production in the state has been more than 60 million tons annually in recent years, according to USEPA estimates.

• Nearly 75 million pounds of chemicals designed to kill insects, weeds and fungi are sprayed and spread on Illinois each year. Fewer than a quarter of the state's farmers have received specific training in the safe use of such chemicals, nor is there a feasible way to monitor the disposal of leftovers.

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• The quantity of pesticides used for such tasks as mosquito abatement or lawn care off the farm in Illinois is not known. There are probably as many cockroaches as corn rootworms in Illinois, and the attempts to exterminate them may also pose grave risks to humans; a study by the Chicago-based Citizens for a Better Environment (CBE) suggested that city dwellers are exposed to from two to six times more pestisides than rural residents are.

• Illinois hasn't had a Bhopal-type accident at one of its dozens of chemical plants, but it isn't because one can't happen. Mini-Bhopals are in fact quite common. Typical is the leak of chlorine gas in January from a Downers Grove electronics plant, which left 11 workers needing hospital treatment. During the five-year period, 1978-1982, roughly 4,000 such emergencies involving leaks or spills occurred in the state and affected several thousand people, ranging from death to the inconvenience of temporary evacuation. A more recent audit by the IEPA suggested that chemical plant safety plans and procedures were "poor" in 8 percent of the plants that make and handle toxic chemicals in the state.

• Nearly 4,000 Chicago children were treated for lead-related conditions in 1982, a number which may safely be assumed not to include all such cases. Much of the lead that appears in the blood of inner-city children is thought to come from the combustion (much of it illegal) of leaded gasolines. The soils near major auto thoroughfares in some cities is so laden with lead that, in the words of a CBE researcher, "If the soils were in a barrel, they would be considered hazardous wastes."

The risks to health posed by an oil refinery and a neighborhood dry cleaners differ largely in degree, not kind, in other words. IEPA director Richard J. Carlson elaborates. There is "too much emphasis" on the regulation of toxics in the form of hazardous wastes in the federal programs, he complains. "Nobody is concerned about hazardous wastes in common household products," he says, "or in sanitary landfills." The average Illinoisan generates nearly 1,800 pounds of municipal solid waste — garbage — each year. Garbage is objectionable to neighbors principally because of its smell, and to city halls because of its bulk. But while it is not regulated as hazardous under IEPA regulations, even ordinary garbage contains its share of poisons — empty spray paint cans, old batteries, unrinsed pesticide containers.

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What can't be tossed out often is flushed out: Contaminated motor oil, solvents such as paint thinners and other materials identical to their industrial counterparts in everything except quantity are washed into municipal sewage plants. Depending on their chemical personality, they there evaporate or are flushed out with effluent, collect in sludges (which in turn pose their own disposal problems) or wreak havoc on the bacterial populations on which advanced sewage treatment depends. To some sewage plant operators, Mr. Clean, the popular household cleaner whose active ingredient is toxic to bacteria, is a dirty name.

Evidence is accumulating that the typical U.S. home may pose far graver risks to its inhabitants than does the world at large. Drain and oven cleaners, paint removers and thinners, aerosol propellants, glues, spray insecticides, lawn weed killers, used motor oil — all are, or harbor, toxic substances. Foods, both fresh and processed, contain pesticide residues, as well as dyes and other contaminants. Nor is toxic pollution in the home always the result of chronic, low-dose exposures. For example, recent federal studies confidently assert that people using commercial paint removers in poorly ventilated basement and garage workshops are thus exposed to concentrations of methylene chloride — a halogenated hydrocarbon that causes lung and liver tumors in mice — that reach 3,000 parts per million. The maximum safe exposure level recommended by the federal Occupational Safety and Health Administration is 75 parts per million.

Regulating the uncharted

The IEPA, on whose back most of the regulatory responsibility for toxics lies, may be likened to the mapmakers of an earlier century who sat poised on the edge of an unknown continent, armed against ignorance with only the crudest surveying tools. Examples:

• Toxic pollution tends to be specific to this waste stream, that industry or this dump site. Participants at a 1981 symposium at Rockefeller University admitted that they didn't know much, but they did know that generalizations about the health effects of toxics from one dump site to another "should always be considered unreliable."

• The reporting categories set up under the various toxic control statutes are often vague or incongruous, reflecting variously either political fudging or scientific uncertainty. In the latter case, for instance, PCBs are not defined as hazardous under the regulations of the federal Resource Conservation and Recovery Act, although they are under the Toxic Substances Control Act.

• Underreporting of waste, accidents, etc. may be assumed to be chronic due to ignorance, criminal evasion or plain confusion. The CBE, for instance, estimates that only about a third of the estimated cases of misuse of commercial pesticides in Illinois is reported each year.

Regulation is commonly misunderstood as the means
by which government controls what is
"out there." Just as often it is the means
by which [it] finds out
what is out there

Measuring toxics by the millions of gallons is scarcely harder than measuring them by the molecule. The technology exists to measure molecules in concentrations as scarce as a few parts per trillion. This is a necessary achievement: Some toxics, like dioxins, are thought to cause harm in doses that slight. The ability to track toxics so assiduously also pushes regulators' grasp past their reach. Only a few years ago, a substance present in the air or water in even a parts-per-billion concentration could be said not to be present at all when measured by instruments capable only of detecting it in the parts-per-million range. That air or water might still be poisoned, but from a regulatory point of view it was immaculate. Such helpful ignorance is no longer so easy to maintain.

Regulation is commonly misunderstood as the means by which government controls what is "out there." Just as often it is the means by which government finds out what is out there. While Illinois' system of monitor wells, ambient air samplers, emergency dump site analyses, waste shipment manifests, and so on, is widely held to be inadequate to the scope of the toxics problem, the system is providing regulators with a swelling stream of facts. IEPA's data files, for example, contain the results of 160,000 analyses of sewage effluent and surface water for toxic metals done between 1978 and 1984; that's 160,000 tests for one class of toxics in one "receiving medium."

Indeed, such is the size of that data stream that regulators risk being drowned in it. Toxics have made clear the differences between mere data and information. "I'm appalled," says William Frerichs, assistant chief of the Illinois attorney general's environmental control division. "We have accumulated a lot of information, but it isn't put to its best use." Toxics are regulated under 17 major acts, many of which require different definitions and different methods of gathering and storing data. In fact, data sometimes isn't even comparable within agencies like the IEPA.

Programs designed to supply information often end up confusing it. The Illinois auditor general recently followed the paper trail left by the manifest system set up to track the movements of certain designated hazardous wastes from dock to dump in Illinois. The auditor general found that the data thus collected were inaccurate, in complete, underverified and out of date. The response to the audit by Robert Kuykendall, manager of the IEPA land pollution control division, revealed the pride of a wounded bureaucrat and inadvertently revealed some of what is wrong with the system: "The manifest system does not, and cannot, track every shipment of ... waste from cradle to grave. ... it does accurately track all hazardous waste manifests." It is interesting to note that one of the first pieces of information published by the fledgling Hazardous Waste Research and Information Center of the Illinois Department of Energy and Natural Resources concluded with a complaint about how little usable information there is on the topic of hazardous wastes. The report cited "lack of consistency" and "major anomalies" in available information. Efforts are underway by all involved agencies to reduce this babble to a common tongue understandable by all, but progress is predictably slow.

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In addition to the obvious technological limits, data collection has bureaucratic limits as well. In the simplified world described in EPA regulations, individuals are assumed to be exposed to toxics in one medium at a time, and the effects of toxics on vulnerable organisms are assumed to be isolated and independent. People endure multiple exposures, however, from air, water and (less directly) soil. Concentrations of arsenic in the air, for instance, properly concern the air pollution control administrator, but it is the concentrations of arsenic in human blood and flesh by whatever means they entered the body that must concern the physician.

Current regulations also tend not to take into account the sinister synergy of toxics. They assume that people are exposed to one toxic at a time, not the dozens revealed by the busy monitors. As Jacob Dumelle, long-time chairman of the Illinois Pollution Control Board, once put it, "The Illinoisan is the integrator of all these insults to health." Some toxics known to be damaging to certain organs have their virulence magnified by the presence of certain other toxics. A recent example in the news: Smoking is bad for you, says the U.S. surgeon general. Inhaling asbestos fibers is bad for you, too. Inhaling asbestos and smoking — as roughly half the workers in asbestos-related industries are thought to do — leaves you five to 10 times more likely to develop lung cancer than people doing either alone.

Tracking toxics in what has been called the "inner environment" of a single human body is bewilderingly complex. Tracking them in groups of bodies has proven, so far atleast, to be practically impossible. Public health risk assessments, especially those based on chronic exposures of disparate populations to minute doses of many different toxics, are seldom more than estimates based on extrapolations based on assumptions. However shaky the numbers may be about toxic concentrations in the environment at large, the inferences drawn from them about disease often are far shakier — what a learned critic once described, with the minimum respect consistent with professional politeness, as "toxicological guestimation" and "epidemiological number-crunching."

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It remains true in both regulation and science that the quality of the answers one gets depends on the quality of the questions one asks. And research into toxic effects, especially in chronic doses, remains in its infancy, "Conclusive information is very difficult to find," explains Gilbert Zemansky, head of the Illinois Pollution Control Board's science section. "Answers are several years down the road, even if the country devotes the resources necessary for research."

State information initiatives

The recent uncertainty of the federal commitment to environmentalism has made state funding for research all the more important. Information was the key component of Gov. James R. Thompson's chemical safety initiative unveiled in the spring of 1984. "Current available information does not provide sufficient data for . . . policy development," Thompson told the General Assembly in announcing the plan. The ungenerous might translate his words to mean that the state doesn't know that it's doing. Says Dumelle on the Illinois situation, "General environmental research sort of got lost." Administrative reorganizations left the responsibility for such research in the hands of the Department of Energy and Natural Resources (DENR) beginning in 1978, a time when energy and not the environment preoccupied state and federal budgetmakers.

As a result of Thompson's chemical safety plan, Illinois is hurrying to catch up. The IEPA has expanded its monitoring and analysis capacities, including a new emphasis on testing of toxics for biological effects, in pursuit of the ambition to take IEPA's testing programs "to the next level of scientific sophistication." Another direct result of Thompson's plan is the new Champaign-based Hazardous Waste Research and Information Center, which operates under DENR to coordinate "problem assessment" research for both state agencies and industry. DENR researchers have recently linked toxic waste hot spots with vulnerable aquifers, and the IEPA as a result plans expansion of its groundwater monitoring system. (For more detail on the Hazardous Waste Research and Information Center, see "Hazardous wastes: putting the priority on information," January 1986, pp. 21-22.)

One can't do more until one knows more has become the general precept in many agencies. The Illinois Pollution Control Board has added a science section to keep its members abreast of developments in the field. The Department of Public Health has expanded its staff to include a toxicologist and an epidemiologist, in part a response to the widening of that agency's historical realm of concern about bacterial and inorganic pollutants to the more exotic organic toxics. The new staff will also study correlations between public health risks and hazardous waste sites in accordance with the state's new Environment Toxicology Act, which might be called one of the General Assembly's own chemical safety initiatives. The Department of Public Health has also opened the Illinois Health and Hazardous Substances Registry, a data repository where the incidences around the state of cancers, "adverse pregnancy outcomes" such as miscarriages, and occupational diseases will be recorded; it is a disease atlas that will help future researchers draw crucial connections between toxic cause and health effect.

Public health risk assessments
. . . are seldom more than estimates based on extrapolations
based on assumptions

The Hartigan-Rock task force, which met in 1983, included a committee on public health. That committee concluded: "There is presently no comprehensive method available for predicting health effects associated with existing hazardous waste sites. Predictions are based on a variety of assumptions and a relatively small amount of data with unknown accuracy."

What is true of hazardous waste disposal sites is also generally considered true for toxics in other environments.

The IEPA has its own phrase for the condition, warning that the public will have to learn to live with "a residual of uncertainty" when it comes to toxics.

But does our present ignorance preclude action? It would be easy to conclude that regulation would be imprudent. The risks of not regulating are real, if undefinable, but there are also risks in regulating the wrong things, or in regulating the right things in the wrong ways. After all, the landfills that today are threatening groundwater supplies were touted 20 years ago as ways to protect rivers and streams.

The public health experts assembled for the 1983 task force created by Rock and Hartigan concluded that on balance action was justified. Cochaired by Dr. Samuel Epstein of the University of Illinois Medical Center, who is the author of the widely regarded books, The Politics of Cancer and Hazardous Waste in America, the task force's public health committee stated that the available data justified regulation "to reduce the potential for future adverse health effects." That ambition falls far short of the optimism expressed by the Congress in the 1970s; then, the ambition was not limited to reducing pollution's potential for harm but was determined to eliminate the harm.

Not for the first time, it is politicians who must rush in where scientists fear to tread. Writing 20 years ago in the Yale Review, government professor Lynton Caldwell pointed out that biological facts (we don't know enough) in conflict with popular truths (the government should protect us) can be reconciled only politically. Conflicts not resolvable in the labs, in other words, must be resolved in law. As biology comes to play a bigger and bigger part in our politics, Caldwell warned in 1964, politics will almost inevitably become a bigger part of biology.

James Krohe Jr. is associate editor for the Illinois Times in Springfield and is author of two in-depth Illinois Issues series related to the environment: one on water and the other on soil.

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