Sarah Palin once mocked our President by asking him, “How’s
that Hopey Changey think working out for you?”
It struck me that hope and change or, more specifically, the hope for positive change is, or should be, an important and positive human attribute. Indeed, I see the opposite sentiment as resignation, stagnation and despair which really does not serve anyone well.
In the interest of full disclosure, I have to admit that I am a hard core Pollyanna, whose Cambridge
Online Dictionary definition is: a person who believes that
good things are more likely to happen than bad things, even when this is very unlikely. Indeed,
I have been predicting that the general widespread acceptance and application
of quantitative human health risk assessment will happen within the next two years for more
than 25 years! It has been argued that
this has not happened to date as the vast majority of chemical exposures and
risk are not well characterized. See
previous posts:
- We do not estimate Quantitative Risk for Most Chemicals (May 24, 2013)
- Why Isn’t Risk Assessment Done on All Chemicals? (October 28, 2013)
- Exposure Modeling Data Base Needs (August 8, 2014)
- We do NOT spend enough on Risk Assessment (November 24, 2014)
I do want to point out some of the remarkable advances that
have occurred over the last 25 years within the science and practical tools of human health exposure/
risk assessment. From my perspective, most
of them have come from volunteers within the committees of the American Industrial Hygiene Association. The Exposure Strategies and Modeling Books
and the associated modeling software have been great advances on the exposure assessment
side. I think most of my colleagues,
however, will agree that we could do a lot more given more resources.
On the toxicity side of things the situation is much worse. Except for a few promising exemptions (like EPA ToxCAST),
it has remained stagnant for years as we do not have nearly enough exposure
limits and necessary improvement in their documentation do not even appear to
be on the horizon.
All of this is not to say that some companies and
organization do not recognize the importance of doing the exposure or toxicity
work to provide good assessment of chemical risk in order to do a rational and
responsible job of managing the risk.
They have what I call “enlightened self-interest”; they understand the importance and proper place
of doing this as the “right thing to do” and in the long run “good business”. Most of my clients fall into this category;
however, I must tell you that I do not have many clients. If you want some more insight into one aspect
of this reality from someone with a lot more field experience than I do, check
out the following post on this blog:
IH’s Dirty Little Secret (January 26, 2014)
Indeed, some companies and their organizations see their
relationship with regulators as essentially adversarial, indeed, as covertly but un-apologetically war-like. As a Risk Assessment Scientist working for a
large chemical company in the 1970s through 2003, I participated in industry group
meetings where I saw this attitude first-hand.
Below is a small and edited excerpt from a letter I wrote to
a staffer for such a group many years ago asking their advice:
“I believe that it is not accurate or useful to accuse or think of the regulators as not using science. It implies that we own the scientific truth and I tell you that we do not. We may have some more or less sophisticated scientific information that supports a less conservative regulation but our interpretation may not be compelling to the regulators who obviously have a different perspective. More important, they own the risk management call. It’s not that they do not use science but the reality is that they use “their” science and not “ours”. We need to work on understanding their perspective and their standard of proof while gaining some common ground and building consensus.
Our science policy should be one of cooperation, understanding and bridging and not confrontation. If the science that we developed is particularly well done then historically the difference between “their” science and “ours” should narrow. There are a few examples of this but they all involved considerable expense to do the work that needed doing.”
The letter went on to seek advice from the staffer as to
whether I should ever openly voice such an opinion and advocacy for change in
policy and approach. The response was
that it would not be appreciated and I was advised to not give it voice.
That was almost 15 years ago and general opposition to
practical and meaningful reform of the chemical regulatory process including
the need for risk assessment in this country continues to receive serious
opposition from groups speaking for the industry.
I believe that the industry in general would do so much better to broadly
embrace enlightened self-interest and work for rational regulation and significant
development of the science. That remains
my fervent hope but I am an admitted Pollyanna. Indeed, it is entirely possible that the cold
hand of regulation may be the only force that will ultimately catalyzes and provides real change and advancement in the science.
