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ARTHUR DAEMMRICH
FORUM
risk frameworks and biomonitoring:
DISTRIBUTED REGULATION OF SYNTHETIC CHEMICALS IN HUMANS
| ENVISION BRIEFLY TWO hypothetical individuals. The first is a chemical engineer who works directly in the synthesis of compounds added to plastics to give them desired properties such as flexibility and hardness. By some analyses, this person has taken on voluntary risks related to the workplace; furthermore this person is protected by federal and state regulations governing chemical exposure and worker safety.1 The second is a vegan environmentalist who works in a natural foods store and enjoys hiking in national parks. This person makes lifestyle choices to avoid exposure to synthetic chemicals and may reasonably assume that federal laws regulating the introduction of new chemicals ensure safety under normal conditions. Yet when their blood is tested, they have similar levels—measured at parts per billion—of compounds known to cause harm at much higher doses. How should they interpret this finding? Is it possible that people with such different exposure to chemicals have similar "body burdens"?2 Because of the minute quantities of materials that all of us absorb through regular encounters with synthetics, this scenario of equivalent measures in two otherwise different people can occur. Whether drinking from plastic bottles while enjoying remote vistas, working at a chemical plant, or engaged in one of thousands of routine daily activities, we are exposed to trace amounts of industrial compounds that make their way into our bodies and environmental systems. |
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Over the past century, and at an accelerated rate in recent years, new analytical tools have made it possible to identify substances at a part per million, billion, or even trillion (the equivalent of finding a single grain of sand in an Olympic-sized swimming pool). In the United States, the Centers for Disease Control and Prevention (CDC) now regularly survey the population for the presence of 275 specific chemicals. In addition to the CDC surveys, biomonitoring studies carried out by academic scientists and by a variety of environmental NGOs are generating significant new data about the presence of chemicals in the U.S. population and eventually will measure changes in chemical presence over time. These efforts to measure and track chemicals pose a complex challenge to a regulatory system that historically was focused on controlling the physical location of hazardous compounds and measured risk based on a calculus of hazard and exposure.3 |
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This essay argues that new technologies for measuring synthetic chemicals in humans, innovations in the field of toxicology, and increased mobilization by environmental nongovernment organizations (NGOs) regarding chemical exposure are combining to undermine risk frameworks and regulatory systems built up over the past quarter-century. In effect, the very definition of risk used in regulatory decisions is at play as a result of biomonitoring's emerging measures of chemicals in bodies at parts per billion or below. I argue that a two-part shift is underway associated with biomonitoring: first, from regulating chemicals by physical location to regulating them by chemical reaction; second, from defining risk as a function of exposure to chemicals to basing it on the presence of compounds in the body. Regulating chemicals by location relied on clear delineations between industry and government, with central control and oversight by federal agencies producing visible environmental and human health benefits. Regulating chemicals by reaction will involve distributed controls and require greater cooperation among interested parties to define standards, carry out biomonitoring, and make policy decisions that draw on test results. Drawing on the historical trajectory of changing regulatory methods, this essay advances a regulatory framework that involves collaborative testing programs and information sharing among industry, NGOs, and government agencies. |
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