Cancer Battles and the Sleep of Reason is an inquiry into the role of scientific experts in environmental health policy-making. The article first establishes two propositions: that there is no necessary relationship between science and environmental health policy; and that risk assessment is not the only science of environmental health. It then asks the question: why should policy-makers consult the scientific experts? If experts are to be consulted, there will have to be some way of grading experts as to the quality of their advice and their usefulness to policy-makers. A mode of grading experts is provided in Environmental Cancer—A Political Disease? by S. Robert Lichter and Stanley Rothman. But the arguments in this book are shown to be worthless; the book fails to address the underlying issue of why the experts should be consulted at all. The article concludes that experts are to be consulted whenever policy-makers consider their advice to be essential or useful. There is nothing in the scientific disciplines that entrenches them in the policy-making process; the opinions of scientific experts have no special place in environmental health policy.
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References
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The Ontario Ministry of the Environment Scoring System for Assessing Environmental Contaminants, Queen's Printer for Ontario, 1990, page 29.
2.
Opus supra, Preamble, page ii.
3.
For substitution analysis, see RossiM.EllenbeckerM., and GeiserK., “Techniques in Toxics Use Reduction”, New Solutions, 2.2, Fall, 1991. For a primitive attempt to construct a rating system for chemical pesticides, see BennettD., “Pesticide Reduction, A Case Study from Canada”, New Solutions, Fall 1991, pp 59–63. Hazard Assessment is a small but well-established scientific discipline in North America (though not, curiously, in Europe). See for instance, “Criteria to Identify Chemical Candidates for Sunsetting”, by ForanJeffrey A. Ph.D., and Glenn BarbaraA. MPH; New Solutions, Vol. 4, No 3, Spring 1994; “Comparative Evaluation of Chemical Ranking and Scoring Methodologies”, CCPTC, University of Tennessee, 1994.
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Environmental Cancer—A Political Disease? by LichterS. Robert and Rothman, Stanley, Yale University Press, 1999, p 81.
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The Chair of the House of Commons Standing Committee on Environment and Sustainable Development, the Hon. Charles Caccia MP, has a healthy skepticism about the testimony of all witnesses, whether they are experts, activists, or businesspeople. This has forced organizations like the Canadian Labour Congress to be utterly rigorous in their arguments and proposals, which is surely the way that public debate ought to be conducted.
6.
Commoner, Barry, Making Peace With the Planet, Pantheon, New York, 1990, pp 76–78. “The environmental failure has been very costly, not only in money but in burdening the still unresolved environmental crisis with a heavy heritage of poor public policy disguised as science and poor science disguised as policy” (Commoner, p. 78).
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Substitutions are likely to be counter-productive unless they are done in the context of an overall materials policy. See GeiserK., Materials Matter, Towards a Sustainable Materials Policy, MIT Press, Cambridge, 2001, Ch 8, “Reconsidering Materials Policies,” 8.4 “Detoxification.”
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For aspects of this controversy, see for instance, Rothman KennethJ. ed., Causal Inference, Epidemiology Resources Inc., Chestnut Hill, Mass., 1988; LillienfeldAbrahamE. M.D. M.P.H., D.Sc, and Lillienfeld DavidE. A.B., M.S. Eng., Foundations of Epidemiology, 2nd. Ed.O.U.P., New York1980; HernbergSven M.D., “Epidemiology in Occupational Health” in Developments in Occupational Medicine, ed. ZenzCarl M.D. D.Sc., Chicago-London, 1980, Ch. 1; DollR., “Interpretation of Negative Epidemiological Evidence of Carcinogenicity”, IARC Scientific Publications #65, Lyon, 1985, p 6. For the view that epidemiology does not establish causation at all, see the letter in the New York Times by PerlDaniel M.D., February 11, 1991.
10.
The reason that L&R [Ch. 3, What Is Environmental Cancer ?] allow mutagenesis to slide into carcinogenesis is based on (i) the contention that most mutagens are cancer initiators and (ii) the presumption that the only test for mutagenicity is the Ames test. Neither is correct. Not all chemicals with mutagenic potential are cancer initiators, far from it. There are more than a dozen lab tests in genetic toxicology. Researchers typically select a battery of such tests and can use the results for a number of purposes, e.g., a regulatory requirement that a certain set of results will indicate further testing; or to determine the future direction of research e.g., in pharmacology; or to rule out some substances from further exploration in finding practical applications for the substance or product. In these ventures, it is not as if a test or any set of tests establish whether or not a particular substance is to be classified as a “mutagen.” It is rather that “mutagenic potential” is measured in relation to an objective, such as one or more of those mentioned above. The formula “mutagen, therefore cancer initiator” is misleading and simplistic.
11.
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14.
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