Somebody's Got It Wrong

Needed: U.S. Interagency Review, Global Harmonization of Dioxin Exposure Guidelines

New U.S. EPA dioxin risk characterization differs vastly from new guidelines issued by United Nations/World Health Organization, European Commission, U.S. ASTDR

If you thought that scientists the world over, scrutinizing basically the same research, would reach the same conclusion on dioxin exposure risk - you'd be wrong. (The accompanying charts show you just how wrong.) Though the numbers and the differences between them seem vanishingly small, they matter. They can affect public health, environmental and economic policies of industrial nations and the developing world. They can definitely affect U.S. employment and investment.

Given the existing uncertainties in understanding whether there is any threat to human health from the declining environmental background levels of dioxin, one thing is certain: we need to begin the process of coming up with a range of numbers that all nations can accept based on agreement within their scientific communities. And first, we need to put our own house in order.

In the USA: As widely reported, the U.S. Environmental Protection Agency (EPA) has been revising its draft Dioxin Reassessment since 1995. EPA's Reassessment concludes that minute background levels of dioxin in the environment pose a bigger health risk to people than EPA said in 1995 (though levels have been declining sharply).

As the charts show, this finding is in sharp disagreement with the findings of major international health organizations and governments - even our own government. For example, the U.S. Agency for Toxic Substances and Disease Registry (ASTDR) concluded last year that current background levels do not represent a health risk. The U.S. Department of Agriculture and the Food and Drug Administration have not found that background levels of dioxin have posed a risk.

Controversies over EPA's interpretation of dioxin data, the transparency of its process, and the influence of competing political agendas have shadowed the Reassessment for years. Most recently, the EPA's Science Advisory Board identified significant problems with the Reassessment and a substantial minority of its members did not agree with key EPA findings. This split among SAB members led to charges by environmental activists that the SAB had been rigged by industry. Industry's position has been key EPA findings have not been supported by the raw data, and that some within EPA have appeared determined to magnify the theoretical risk far beyond any observable level.

Seeking resolution, the EPA Administrator has decided to support a government inter-agency review process on dioxin science. This will bring together experts and stakeholders from EPA, the Department of Agriculture, the Food and Drug Administration and other U.S. Government agencies. ARCC supports the U.S. interagency review. USDA and FDA have approached the National Academy of Science to review dioxin science as well.

In the rest of the world: The United Nations / World Health Organization's (UN/WHO) global food additives safety committee has just released its new dioxin risk characterization. The European Commission (EC) has just issued a new assessment of dioxin exposure guidelines as well.

The numbers don't match up: According to EPA's Reassessment, the U.S. environmental background level of dioxin may be 100 to 1,000 (one thousand) times greater than acceptable (no adverse health effects) for human exposure. But according to the new United Nations/World Health Organization and the European Commission guidelines, the current U.S. environmental background level appears to be about 50-75 percent below the level that could potentially cause adverse health effects.

Important considerations for America: Importantly, EPA has not yet issued revised U.S. dioxin exposure guidelines based on the findings of its Reassessment - but if the Reassessment serves as its main reference point, then U.S. exposure guidelines could be lowered dramatically in comparison to the rest of the world. While scientists continue to disagree vehemently over whether the declining background environmental levels of dioxin pose any real health risk, one thing is certain: a unilateral lowering of U.S. exposure guidelines would have a major adverse effect on large-scale U.S. based industries, exports, workforces and government expenditures, while competing foreign producers, workers and governments would benefit at U.S. expense.

Beyond the U.S. interagency review, it appears essential that the world's governments should try to establish more uniform exposure guidelines for dioxin. Dioxin emissions and exposures have declined sharply in the U.S. and Europe since the mid 1980s due to better regulation and technology advances. These advances have occurred even as the output of the modern chlorine chemistry based industries has increased. This has maintained strong economic performance with high-paying jobs for U.S. workers. Global guidelines would level what is in danger of becoming a topsy-turvy playing field, ensuring fair competition and environmental protection worldwide.

The unions and companies of the ARCC are committed to continued pollution reduction in combination with policies that support U.S. jobs, communities and economic growth. As we've said before: clean up pollution - don't shut down industries!