The cleaner the enviroment, the more desperate enviros become to tackle the Next Big Scare.
America’s massive and well-funded environmental industry is always in need of new worlds to conquer, or at least to attack with broom and dustpan. But the irony behind the modern-day environmental movement in America is that the more successful the movement is, the more petty subsequent goals necessarily become. There is no other choice. The big environmental organizations have mouths to feed and rents to pay just like any other business. They’re not going to offer up an attaboy to the nation and close up shop just because America has reached a level of environmental purity that would have been impossible to imagine just 50 years ago.
Risk, and more specifically the way that average American perceives risk, is the crux of the matter. So long as Joe and Josephine McOrdinary believe that substantial environmental hazards exist that threaten the well-being of themselves and their children, the environmental movement will continue to maintain traction and, most importantly from its perspective, a healthy balance in its checking account. The flip side of that scenario is the one that strikes terror into the hearts of Sierra Club fundraisers, for if the public ever perceives that today’s environmental risks are really pretty mundane, the good times will be over.
The pressing need to find new problems to solve is moving the big environmental organizations in new directions. Their unending search for risks to micromanage and overinflate are leading towards a growing war on chemistry and common sense. The key for the American people will be for the U.S. Environmental Protection Agency (EPA) to leave the fringes to these environmentalists and pursue a smarter course that truly defines risk for American consumers.
The fact remains that because American industry is greatly improving its environmental practices and is proactively addressing all the “big problems,” there’s only one way for the EPA to stay relevant: find little “problems” — even tiny, infinitesimal ones — and inflate them into issues of tremendous importance. Combine the poorly understood concept of risk, a technically ignorant mainstream media, and a public that has been conditioned to equate the word “chemical” with “deadly poison” and you have the ideal conditions to do just that. And if that kind of approach to environmental management sounds as if it will require the services of a public relations firm rather than a team of scientists, no matter. The environmental movement has been comfortable working in this manner for decades.
It’s all about The Next Big Scare. It always has been. The focal point of the latest Next Big Scare involves four letters: TSCA, which stands for the Toxic Substances Control Act. Passed in 1976, TSCA provides a comprehensive approach to the safe manufacture and use of chemicals in the United States. Certainly the EPA seems to think so, based on its own thumbnail description of the Act. Here’s how the EPA describes what TSCA is at its website:
• It requires pre-manufacture notification for “new chemical substances” before manufacture.
• It requires testing of chemicals by manufacturers, importers, and processors where risks or exposures of concern are found.
• The EPA must issue Significant New Use Rules (SNURs) when it identifies a “significant new use” that could result in exposures to, or releases of, a substance of concern.
• The EPA maintains the TSCA Inventory, which contains more than 83,000 chemicals. As new chemicals are commercially manufactured or imported, they are placed on the list.
• It requires those importing or exporting chemicals to comply with certification reporting and/or other requirements.
• It requires reporting and record-keeping by persons who manufacture, import, process, and/or distribute chemical substances in commerce.
• It requires prompt reporting if any chemical not in the TSCA Inventory presents a substantial risk of injury to health or the environment.
Sounds pretty comprehensive, doesn’t it? Sure, there are tweaks that could be added to modernize TSCA and make it more efficient, such as a sensible prioritization plan proposed by the American Chemistry Council. But for the most part TSCA has been pretty effective at doing what it was designed to do: prevent the public and the environment from being exposed to dangerous amounts of exceptionally toxic chemicals.
Unfortunately, the demands of Next Big Scare require us to believe that TSCA isn’t doing its job, that there are either: 1) large amounts of moderately toxic chemicals that have somehow slipped through the TSCA net, or 2) there are tiny amounts of incredibly toxic chemicals that have done so.
Of particular concern is EPA’s focus, in the name of risk management, on chemicals that may be found in the environment in incredibly tiny concentrations. The Agency’s approach to siloxanes, an innocuous class of compounds used in a variety of ways, including personal care products, lubricants, certain plastics, etc., is a prime example.
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