Understanding the President’s Cancer Panel Report[1]

The May 6 report of the President’s Cancer Panel is significant for several reasons. First, the things it says: Environmental contaminants probably cause many more cancers than are commonly acknowledged. The mix of contaminants people are exposed to, especially children, make the risks much higher than from any one source. We need to warn people about the steps they can take to reduce their exposure, and to carefully study chemicals and technologies that can affect human well-being before they are released for general use. Specific contaminants discussed in the report include bisphenol A, formaldehyde, radon, radiation from cell phone usage, and a range of other carcinogens and endocrine disrupters. The report urges systematic monitoring of environmental contaminants, exposure level in humans, and health outcomes. It endorses a precautionary approach to contaminants that can affect human health.

[By the way, there are things you can do to reduce your own and your children’s’ exposure: choose food, household chemicals, toys and play spaces that have few chemicals—read labels, look through http://householdproducts.nlm.nih.gov/, don’t use plastics in your microwave oven, spend less time at the mall (flame retardants on all of those fabrics), wash new clothes a couple of times before wearing them, use a filter for your tap water, limit time with a cell phone held next to your head or on a belt, limit CATscans and other uses of x-rays, and have your house checked for radon.]

In the United States we do not employ a precautionary approach. Quite the contrary, our laws specify that industry is free to deploy new substances and technologies unless there is a compelling reason to suspect people will be harmed. The big test for effects on health is conducted by exposing millions of people.

Consider the example of neurotoxins. The EPA maintains a list of known neurotoxins, two hundred and one in all.[2] Only three have been thoroughly investigated for presence in the environment, exposure levels and health effects on people. All three—PCBs, lead, and mercury—have been found to harm people, particularly children, and have become targets of programs to reduce their release. We do not take strong action on the others, or drastic action on mercury, because of the high burden of proof required under our laws—and because programs to do so are opposed by big contributors to Congress.

The top scientists who study neurotoxins, endocrine disruptors and other widespread contaminants believe they are responsible for serious health problems, including asthma, autism, and behavioral disorders in children.

We so not routinely conduct studies of exposure to environmental contaminants, as the President’s Cancer Panel advocates.[3] When such tests are conducted, we find people harbor dozens of toxic chemicals at levels that threaten their health.[4]

The Report warns we will not beat cancer as long as we continue to expose people to thousands of carcinogens. 

Here is what the Report does not say. It is presented to the a public, and to a public policy community, that is debating how to think about, and design policies for, risks to human health. It is widely accepted that public policy should pay some heed to risk. Given scarce budget dollars, we are under an ethical obligation to spend money wisely. More should be spent on the risks we are more likely to encounter, and from which we are more likely to suffer dire consequences.

That argument has won the day in the world of public policy. We need to understand how to do it right. Industry insiders and advocacy groups generally argue for risk-based decision making, but against the systematic testing and monitoring advocated in the Report. Why?

Consider an example from the world of food safety. Let us agree our knowledge of risk should not come from incidence of illness due to food borne pathogens. The point is to prevent illness and death, without conducting field experiments that sicken and kill people.

An industrialized food system generates new risks all the time, through the invention of new processes and chemicals. Most risks from these innovations are going to be unknown, such as in the recent news story about salmonella in hydrolyzed vegetable protein (HVP—which is really MSG produced by means other than fermentation). HVP is sold as an ingredient for other products. Most of those subsequent products will be heated enough to kill salmonella—but perhaps not all of them. The food finally served to consumers may or may not be cooked just before eating. So the risk is, to be precise, unknown.

Opponents of testing have a point. If a company that buys HVP tests it and finds contamination, it is obligated to report the result to the FDA. The company that sent them the HVP must then track down all the other shipments that might also have been contaminated, and perhaps recall all of them, before enough information is available about the extent of contamination (note: the FDA lacks the power to compel a recall in this situation). The recall will have cost food processors and sellers a lot of money. And, in that situation, the risk to eaters is unknown. From a regulatory view, we are right back where we were, with the addition of a lot of bad feeling about government regulation. Is this an argument for not testing—unknown risk if you do test, unknown risk if you don’t?

The question points to an absurdity. Of course we are better off knowing that a particular shipment of HVP is contaminated. It sets into motion a search for the contamination, a fix, and dissemination of the knowledge acquired so that other food processors can improve, based on experience. The two states of unknown risk are not at all equivalent.

A system of testing, in food safety and in environmental contaminants, will reduce risks to health. Right now we don’t know by how much. Opponents of testing are right that testing introduces financial risk. But to not test destroys our ability to make decisions based on risk. It introduces a bias against public health, a bias in favor of making money at the expense of public health. We are a capitalist country, but to oppose testing is a dodge.

The European Union is now running its REACH program (Registration, Evaluation and Authorization of Chemicals), which should produce, over the next ten years, data on the likely health impacts of the 100,000 or so chemicals that are now used in industrial, food, and other applications.[5] The Report and other studies insist that something like REACH is required here.[6] There will be arguments in the US over whether we will use EU data on risks from chemicals. Right now we are completely unprepared to cope with this impending flood of data.[7]

If we want a risk based decision system we need to know about risks. It is within our power to start a REACH-like testing of chemicals, and we need it to support risk based decision making. To advocate risk based decision making without the testing is a dodge.

That is the context of the President’s Cancer Panel report. We will not make significant progress against cancer until we adopt the precautionary approach to exposure. The political forces that oppose it will fight it. They will probably win.

NOTES

1. The report is available online at http://deainfo.nci.nih.gov/advisory/pcp/pcp08-09rpt/PCP_Report_08-09_508.pdf. It’s official title is 2008–2009 Annual Report, President’s Cancer Panel, and the title page reads Reducing Environmental Cancer Risk: What We Can Do Now.

2. P. Grandjean, P.J. Landrigan, “ Developmental neurotoxicity of industrial chemicals,” Lancet Published Online November 8, 2006DOI:10.1016/S0140-6736(06)69665-7.

3. In addition to the Report, see General Accountability Office, Biomonitoring: EPA Needs to Coordinate Its Research Strategy and Clarify Its Authority to Obtain Biomonitoring Data, April, 2009, GAO-09-353; and General Accountability Office, Testimony of John B. Stephenson before the Subcommittee on Environment and Hazardous Materials, House Committee on Energy and Commerce, April 25, 2007, Perchlorate: EPA Does Not Systematically Track Incidents of Contamination, GAO 07-797T.

4. See Is It In Us? Chemical Contamination of Our Bodies, Commonweal Biomonitoring Resource Center and the Body Burden Work Group, 2008; and Bobbi Chase Wilding, Kathy Curtis, Kristen Welker-Hood, Hazardous Chemicals in Health Care: A Snapshot of Chemicals in Doctors and Nurses, Physicians for Social Responsibility, 2009.

5. A comparison of the US and EU approaches to controlling toxic substances is in General Accountability Office, Chemical Regulation: Comparison of U.S. and Recently Enacted European Union Approaches to Protect against the Risks of Toxic Chemicals, August 2007, GAO 07-825.

6. See also, for example, Toxicity Testing in the 21^st Century: A Vision and a Strategy, Committee on Toxicity Testing and Assessment of Environmental Agents, National Research Council, 2007; and Science and Decisions-Advancing Risk Assessment, Committee on Improving Risk Analysis Approaches Used by the U.S. EPA, National Research Council, 2009.

7. See FDA Science and Mission at Risk, Report of the Subcommittee on Science and Technology, Prepared for FDA Science Board, November 2007, pp. 45-51.

[1] The report is available online at http://deainfo.nci.nih.gov/advisory/pcp/pcp08-09rpt/PCP_Report_08-09_508.pdf. It’s official title is 2008–2009 Annual Report, President’s Cancer Panel, and the title page reads Reducing Environmental Cancer Risk: What We Can Do Now.

[2] P. Grandjean, P.J. Landrigan, “ Developmental neurotoxicity of industrial chemicals,” Lancet Published Online November 8, 2006DOI:10.1016/S0140-6736(06)69665-7.

[3] In addition to the Report, see General Accountability Office, Biomonitoring: EPA Needs to Coordinate Its Research Strategy and Clarify Its Authority to Obtain Biomonitoring Data, April, 2009, GAO-09-353; and General Accountability Office, Testimony of John B. Stephenson before the Subcommittee on Environment and Hazardous Materials, House Committee on Energy and Commerce, April 25, 2007, Perchlorate: EPA Does Not Systematically Track Incidents of Contamination, GAO 07-797T.

[4] See Is It In Us? Chemical Contamination of Our Bodies, Commonweal Biomonitoring Resource Center and the Body Burden Work Group, 2008; and Bobbi Chase Wilding, Kathy Curtis, Kristen Welker-Hood, Hazardous Chemicals in Health Care: A Snapshot of Chemicals in Doctors and Nurses, Physicians for Social Responsibility, 2009.

[5] A comparison of the US and EU approaches to controlling toxic substances is in General Accountability Office, Chemical Regulation: Comparison of U.S. and Recently Enacted European Union Approaches to Protect against the Risks of Toxic Chemicals, August 2007, GAO 07-825.

[6] See also, for example, Toxicity Testing in the 21st Century: A Vision and a Strategy, Committee on Toxicity Testing and Assessment of Environmental Agents, National Research Council, 2007; and Science and Decisions-Advancing Risk Assessment, Committee on Improving Risk Analysis Approaches Used by the U.S. EPA, National Research Council, 2009.

[7] See FDA Science and Mission at Risk, Report of the Subcommittee on Science and Technology, Prepared for FDA Science Board, November 2007, pp. 45-51.