Richard Denison, Ph.D., is a Senior Scientist.
My recent post about the new American Chemistry Council (ACC)-sponsored website, Kids + Chemical Safety, engendered some comments that go directly to the issues of scientific objectivity and independence.
The website says “TERA [Toxicology Excellence in Risk Assessment, manager of the site] was founded on the belief that an independent non-profit organization can provide a unique function to protect human health by conducting scientific research and development on risk issues in a transparent and collaborative fashion and communicating the results widely.” The “non-profit” descriptor – which TERA uses to describe itself no fewer than eight times on the site, including four times on this one page alone – seems intended to convey that TERA provides information that is purely objective and that it operates in a manner that is independent of who pays it to do its work.
It’s critical to recognize that being a non-profit does not conflate to, or somehow confer the right to claim, objectivity or independence. The National Rifle Association is a non-profit that clearly has strongly held and expressed opinions. EDF is also a non-profit, but I don’t pretend, as does TERA, that we don’t have a particular perspective and position.
So putting the issue of non-profit status entirely aside, we should judge TERA’s claim that its website provides information that is objective and independent based on its content, and that’s where it becomes quite clear that the information is neither.
There are two categories of information provided on the website: 1) topics that are largely outside of the vested interests of the site’s most prominent sponsor, the American Chemistry Council (ACC), and of its member companies; and 2) topics that fall squarely within those vested interests. These categories are treated very differently on the website.
Examples in the first category include pieces addressing lead-based paint in old houses, choking hazards posed by some toys, carbon monoxide poisoning risks in the home, and a new timely piece on minimizing hazards to children during the holiday season. These pieces largely deal with legacy contamination, physical rather than chemical hazards, natural hazards posed by certain foods and plants, and incidental contaminants from malfunctioning furnaces or improper home use of equipment that uses fuels. While all of these risks warrant the attention of parents, they are also quite conspicuous in being far removed from the financial interests of the chemical industry. The essays appear to be reasonably objective, are written mainly by staff at the Cincinnati Drug and Poison Information Center, and point to how serious the risks are and how important it is that they be addressed.
Then there are the other topics covered on the site that do touch directly on chemical risks. Many of these are in the headlines and involve issues in which the chemical and related industries have enormous financial stakes. These address whether chemicals in toys pose risks to children, whether organic food is safer, and asthma and its causes. These topics are treated wholly differently by TERA.
First, these essays are all written either by TERA staff or by staff from other chemical industry consulting firms, such as Exponent, that have a long track record of helping chemical companies avoid regulation. Second, they bend over backward to “put those hazards into context,” noting that many chemicals posing risks are naturally occurring and emphasizing risk factors other than chemicals. Third, they tout the efforts and money expended by companies to ensure the safety of their products, and maintain that extensive regulations are more than adequate to address the problem. Fourth, they ignore or seek to minimize research findings indicating potential or actual risk. Finally, they seek to shift responsibility for ensuring safety to the consumer or parent and away from manufacturers of chemicals or products containing chemicals at issue.
The piece on chemicals in toys is a case in point. Written by two scientists from Exponent, the main advice it offers is this: “The key things parents can do to minimize exposure to their children is to carefully select the toys they play with and follow the warning, if any, on the label.” That’s a handy shift in responsibility away from minimizing the presence of hazardous chemicals in such toys. Here’s the advice offered:
Parents need to consider two things: can the chemicals in the toy result in an exposure, and is this exposure associated with a health risk. In toxicology, this is described in the following equation:
Risk = Exposure x Hazard
In other words, it is important to consider not just the chemical levels in the toy, but also whether they can cause an exposure above a safe level.
How, then, is a parent to understand the risk, say, of their child playing with a toy that contains a phthalate plasticizer? For starters, the chemical won’t be listed on the label. Are these industry scientists really content telling parents they need not worry that a chemical known or suspected to cause development abnormalities is deliberately added to a toy by its manufacturer? And that the keys to their child being able to use the toy safely lie, not in ensuring such chemicals aren’t used in toys, but rather in parents reading the label, minimizing the amount of time the child puts the toy in his or her mouth, and “washing the child’s hands after use”?
As I said in my last post, the new website is very clever. The intermixing of relatively objective pieces written by more independent experts with propaganda pieces written by consultants to the chemical industry is the modern version of the salesman’s classic bait-and-switch.
The remainder of the content of the site – pieces touting risk assessment and peer review – parrots longstanding industry talking points such as how even water is risky at high enough doses. It also reveals the double standards that industry proponents offer up as common fare in debates over chemical safety. To cite but one of many examples, after vociferously arguing that only peer-reviewed studies of chemicals should be deemed credible, the essay on asthma categorically dismisses a large body of peer-reviewed studies linking chemical exposures to asthma and related conditions.
Moreover, the basis on which these studies are dismissed is a spurious argument: that in such studies, “animals are frequently exposed to extremely high concentrations, which do not represent our everyday exposures.” Put aside the fact that the website elsewhere discusses the need to rely on animal studies, and that industry routinely uses the results of such studies to influence regulatory decisions.
Conveniently omitted from this simplistic rendition is the longstanding scientific reason for why toxicologists typically use high doses of chemicals in studies using laboratory animals: Because a) we cannot for ethical reasons test chemicals directly on people, b) lab animals live far shorter lives than do we humans, and c) it is too costly and impractical (and unethical) to use large enough numbers of lab animals in a study to model the human population, such doses are used to ensure that a study will detect an effect, if one occurs, in a relatively short time and in a relatively small number of animals. While there are legitimate scientific debates as to whether such studies may actually obscure or miss effects that occur at low doses of exposure, resorting to such overly simplistic rhetoric does a disservice to the public discourse and reflects an underlying bias that permeates the website.
Why do I question TERA’s independence from its heavy reliance on funding from the chemical and related industries, including for this website? Given its long track record, if TERA were truly independent, it should be able to provide a long list of studies, comments filed with regulatory agencies and other documents wherein it proffers a conclusion or position that is in opposition to those taken by the parties who funded those studies or comments. I have yet to see such a case.
I would have no beef with TERA’s website if it described itself as what it is: a source of information that reflects its own or the industry’s positions and perspective, and is intended to provide a counterpoint to what parents or consumers may be hearing from others, EDF included. I will be the first to acknowledge there are (at least) two sides to this debate.
But it is simply unacceptable for TERA to make the eerily Fox News-like claim that the site is our “best source of balanced, scientifically accurate chemical health information.”