The cleaner the enviroment, the more desperate enviros become to tackle the Next Big Scare.
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If you can find siloxanes in the environment at all, it’ll typically be in the parts per trillion level in the outlet of wastewater treatment plants. (One part per trillion is roughly the equivalent of about one drop of a liquid placed in the amount of water that would be contained in five hundred 30,000 gallon railroad tank cars.) It’s hard to justify worrying about any chemical in that kind of tiny concentration, but it would be downright lunacy to raise concerns over a class of compounds that has been studied as thoroughly as siloxanes. Study after study has failed to find any evidence to suggest that they present a threat to human health or the environment at the levels they are typically found in the environment, an assertion supported by the government of Canada for a typical siloxane called D5.
Yet, even though siloxanes have been thoroughly studied and are sufficiently removed in water treatment plants, the EPA is determined to conduct a massive study targeting the compounds. The companies that produce siloxanes, represented by the Silicone Environmental Health and Safety Council (SEHSC), have proposed voluntarily monitoring of siloxanes in the discharge from five worst-case wastewater treatment plants, and four industrial sites that have direct discharges from surface waters. The EPA originally asked for a program that would involve more than 40 sites, but has reduced that request down to a still-arbitrary 25 sites.
The difference between the two plans is significant for a couple of reasons. One is cost, which industry will bear. EPA’s plan remains substantially more expensive than the industry plan, an expense that cannot be justified by any evidence to suggest that siloxanes are present in the environment in concentrations large enough to be of concern.
But, it’s the second reason that is most troubling and most representative of the EPA’s approach to risk issues. The chemical industry has justified — correctly in this writer’s opinion — their plan on the basis of its being a worst-case study. Because siloxanes are used in consumer products, the worst cases are relatively easy to identify: find large population centers that could represent greater siloxane discharges. While that kind of common sense approach might make sense to you and me, the EPA has officially said that it has no interest in a worse-case approach. That’s a problem. That’s a big problem.
The reason one takes a worst-case approach when doing a risk assessment, especially when one has strong reason to suspect that the worst-case will be pretty darn insignificant, is that it prevents a lot of wasted effort and misuse of limited resources. If you can’t find any substantial risk in the worst-case, there’s no reason to go any further. However, when the federal agency tasked with managing and prioritizing environmental risks declares that it has no interest in such a science-based approach, one must question the Agency’s intentions.
The political agenda here is clear. And the synergistic relationship between Obama’s EPA and the environmental movement appears to be growing ever stronger. Thus, when an organization like the Sierra Club expresses concern about a particular chemical’s fate in the environment, the EPA will duly gather all of the data it can about that chemical, not in order to determine if there is a risk worth addressing, but rather to manage a risk whose existence and magnitude the Agency has preordained.
That’s where we’re headed, if we haven’t already arrived there. In order to exist, the EPA must find new segments of society and the economy to regulate. In order to survive, environmental organizations and advocates must invent and inflate new “risks” that will frighten the gullible into opening their wallets. When the two come together, as they are now, there’s no room left for science.
A man of faith in a godless age is hitting Americans where it hurts.
Mr. and Mrs. American Spectator Reader, let P.J. O’Rourke talk sense to your kids.
In Britain, defending your property can get you life.
It won’t take long for conservatives to scratch this presidential wannabe off their 2008 scorecard.
Was the President done in by the economy, or by the politics of the economy?