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Recent cases involving dieldrin and PVC dramatize need for coherent toxic substances legislation
There are nine toxic substances, according to the waterway effluent standards proposed by the U.S. Envi ronmental Protection Agency. Actual ly, the list is much longer, but pres ent provisions for defining them are limited to those provided for under the Federal Water Pollution Control Act (FWPCA). Although a bill dealing with toxic substances in a more comprehensive way is in the offing, as yet the Senate and Flouse have been unable to agree on its contents.
There are other laws that deal with chemicals that are toxic, of course( such as the Federal Insecticide, Fun gicide and Rodenticide Act (FIFRA), as amended in 1972, and the Air Pol lution Control Act and its amend ments. But these laws, too, are con cerned with toxic substances only in indirect ways. Lacking a bona fide toxic substances law, the EPA has had to rely upon the water quality provisions.
Under this mandate, the EPA, in December 1973, proposed effluent standards for aldrin, dieldrin, benzi dine, cadmium, cyanide, endrin, DDT (DDD, DDE), mercury, PCB's, and toxaphene. The standards are based upon water quality criteria proposed in October 1973, and are designed to protect against short-term and long term toxic damage to man, animals, and other organisms. The EPA says final standards will be promulgated in June of this year,
In addition, the agency has pub lished a list of pollutants from which it may identify toxic substances in the future. According to the Sept. 7, 1973, Federal Register (Vol. 38. No. 173), the EPA plans to examine ar senic, selenium, chromium, lead as bestos, severin, zinc, chlordane, lin dane, acridine, hydroquinone, orthocnlorophenol. beta-naphthol, alphanaphthol. beryllium, nickel, antimony, heptachlor, camphor, methyl parathion, parathion, di-n-butyl phthalate. The agency also will examine other pollutants, including chlorinated hy
drocarbons, organophosphates; met als (heavy), and materials listed as occupational carcinogens by the De partment of Labor in the May 3, 1973, Federal Register (Vol, 38, No. 10929).
Four criteria
In choosing pollutants for its initial list, the EPA set up four criteria The
first one concerns the actual or po tential damage that a water dis charge of these materials may create. Specifically, it seeks to deter mine whether bioaccumulations, car cinogenic, mutagenic, and teratogen ic effects, and high acute toxicity,
are produced.
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The second criterion seeks to de termine the nature and extent of toxic effects associated with the pol lutant. the extent to which discharges of the pollutant have been identified,
and the production, distribution, and use pattern of the pollutant. It re quires documented evidence show ing that discharges oLthe compouno, or a subsequent combined form of the compound, result in damage to important organisms.
The third criterion concerns the setting of effluent standards for pollu tants on the list. The fourth criterion concerns the overall environmental effect of the control measures avail able, including the possible effect upon groundwater and other environ
mental media. The use of substitute products is suggested where avail able.
The inadequacy of the water quali ty act by itself to deal with the total problem of toxic substances was un derscored recently with the realiza tion that polyvinyl chloride, which is not strictly speaking a waterway threat, nevertheless has serious toxic properties. So far some 12 cases of
angiosarcoma, a rare liver cancer, have been found among PVC work ers in Kentucky, New York, Texas, West Virginia, and Great Britain. While this plastic product--used for a variety of purposes including wrap ping foods--is thought to be inert in its solid state, the low levels of vinyl
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chloride gas that may escape from PVC are not. Medical researchers feel PVC's are greatly understudied. New compounds yearly
Scientists at an American Cancer Society's science writers' seminar in St. Augustine, Fla., recently estimat ed that some 10,000 new chemical compounds are introduced into the environment each year. Besides the problem of keeping tabs on all these chemicals, such substances as PVC seem to have a delayed effect in the harm they do to individuals Scien tists say the PVC-tnduced cancers observed today had their origin 15-35 years ago. Also, it has been said that thousands of men and women have died of cancers caused by asbestos following work-related exposures between 1930 and 1950.
The advantages of knowing the toxic properties of a chemical in ad vance was shown recently when the EPA moved to have several mil lion broiler chickens destroyed be cause of contamination by the pesti cide, dieldrin. It was found that the dieldrin levels in the chickens, appar-
408 Environmental Science & Technology
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where field surveys verify the exis tence of infections that could cause significant damage to dry pea crops. Other restrictions are being imposed to ensure that the DDT is properly used, and that record-keeping and monitoring are undertaken. Under a similar program last year, less than half the total dry pea acreage was
treated.
power the EPA to make a premarket review of each new chemical to be produced; the House bill would not require this. A second difference concerns the priority of the federal law. The House bill would allow the EPA regulatory authority only if a problem could not be regulated by an existing state or local law. The Sen ate bill asks that the agency be em-
Contacts are encountered
almost daily
Data are beginning to show long-term harm can arise for workers who spend years around polyvinyl chloride , products. Less well i understood are the possible effects to the consumer whose total exposure is considerably less. Another undecided question is just when do pesticide and insecticide chemicals warrant use. In many cases they increase crop and timber yields, but also harm birds and other animals
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ently confined to the state of Missis sippi, were as high as 10 times the permitted level. Although the eco nomic loss was staggering, a serious health threat to humans was avoided.
In yet another toxic substance matter, EPA administrator Russell E, Train reversed an earlier ruling on DDT and will allow its use in two `trial" instances this summer But the decision-making had the benefit of a DDT data base, which is at least partly the result of prior listing of it under the water quality law Train
said the agency was well aware of DDT's toxic properties, but that in sects in both of these cases present a more serious threat to the environ ment. Right or wrong, at least an ed ucated decision was possible
The first of these rulings allows limited use of DDT to control an ex pected pea leaf weevil infestation in Washington and Idaho The second involves the use of DDT against the tussock moth in Oregon, Idaho, and Washington. The use of DDT. in both cases, carries certain restrictions
As for pea leaf weevil use. the chemical will be permitted only
Administrator hopeful
Train said, in making the tussock moth use decision, that the permis sion "is not a directive from EPA that DDT be used this summer against the tussock moth." He said it's hoped that no actual emergency will arise, that the egg hatch will not pro duce such large numbers of the in sect. The Forest Service will deter mine whether an actual emergency exists. In its caterpillar stage, the moth eats the needles of the Douglas and other fir trees--thus defoliating and killing them.
What a Toxic Substances Control Act could do, if passed by Congress, is to ensure the study of, and imme diate and strict control of, those chemicals that may kill or injure the unsuspecting citizen. It also could unify into one coherent bill, provi sions presently contained in other federal legislation.
As for the present status of legisla tion, both houses passed toxic sub stance bills last session, but the bills died when crucial differences could not be worked out. The Senate bill, the stronger of the two, would em
powered to act according to which
ever federal bill would deal most ef
fectively with the problem.
The growing concern over environ
mental poisonings from toxic chemi
cals is by no means restricted to the
United States, although the problem
is most severe in industrialized
countries. The Society of Toxicology,
(SOT), which met in Washington in
March, was asked to provide data
upon which toxicological decisions
could be reached worldwide. Frank
C. Lu, chief of food additives for the
World Health Organization (WHO),
Geneva, Switzerland, requested in
formation especially in cases where
manufacturers' research facilities are.
too small to provide toxicological
data.
This worldwide interest is essen
tial, but such groups as WHO lack
legal mandates to enforce toxic sub
stances policy This realization
makes the efforts, undertaken in in
dividual countries such as the United
States, loom large indeed. What we
do will affect the health and safety of
millions of people here, and perhaps
millions of others worldwide,
WSF
Volume 8, Number 5, May 1 974 409
CUSAROSS 02246
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