Rationalising inaction

The second theme to emerge from this book concerns the hand-in-glove relationship that has developed between industry, politicians and the civil service. Whenever efforts have been made to impose controls, however modest, on the activities of our most polluting industries, civil servants have done their level best to water down those controls - or worse stills to stifle them at birth.

To choose an example at random: consider the support given to the highly polluting pesticide industry by successive British governments. As Chris Rose notes: [26]

recent research in the Kew Public Records Office by Maurice Frankel of the Campaign for Freedom of Information, has revealed how early attempts to bring pesticides under a comprehensive system of legal controls in order to protect farmworkers, the public and the environment, were undermined and finally defeated by concerted lobbying from within the civil service on behalf (if would appear) of the pesticide industry. Official papers from the early 1950s show how civil servants deliberately manoeuvered and steered 'expert' committees away from imposing legal controls - and even rewrote and reversed their findings.

Rose goes on to comment:

the ministry not only went out of its way to help manufacturers and commercial users of farm chemicals to fend off controls over their use, it also played a considerable role in undermining controls over the sale of pesticides in shops.

It is worth considering some of the expedients resorted to by government, industry and the civil service to prevent the imposition of controls not only over the use of pesticides but over other destructive activities.

A question of evidence

The most obvious expedient is to insist that there is no 'scientific evidence' that a particular product or activity is in fact harmful, and hence no need to control it. Most people generally accept such an assurance at its face value, especially if it is provided by a well-known and highly qualified scientist. Few realise that such an assurance is often only 'true' because no one has ever bothered to look for the evidence - in other words, there is 'no evidence' because the necessary research has never been undertaken to find it.

The point is made by Erik Millstone with regard to food additives. [27] "When industry says that there is no evidence of any chronic hazards from additives", he writes, "this does not mean that it has looked for such hazards." The truth is that there has been very little research into the effects of food additives on our health.

Nor, for that matter has there beep much research on the environmental effects of agricultural chemicals. As Harry Walters recently noted in an article in The Eco!ogist, agricultural research in Britain has been "concentrated on the most cost-effective ways of using the new machines, fertilisers, pesticides and herbicides"; environmental research has been "virtually ignored and has remained neglected to this day." [28]

The fact that the environmental effects of the majority of chemicals have never been examined has not prevented successive British governments from encouraging their use. This the Agricultural Development and Advisory Service (ADAS) has encouraged the use of more and more nitrate fertilizers, though it has never conducted "any research on the quality of food produced or on the health of those who eat it.".

Chris Rose notes that "the complete absence of figures for the amounts of different pesticides used on farms makes the detailed study of pesticide related cancers, nervous disorders, or other potential effects extremely difficult, if not impossible." In addition, "baseline environmental monitoring has been studiously ignored or even reduced, so ministers can safely reply that there is 'no evidence' of problems." Nor does the government have much idea of the extent to which drinking water is contaminated since "data on pesticides detected in rivers and groundwater are not held centrally." [29]

Worse still, as David Wheeler of the University of surrey points out, Britain's water authorities have been specifically asked by the Department of the Environment "under direct instructions from ministers ... effectively to ignore contamination of the public water supplies by pesticides". [30] It would clearly be an embarrassment for the public to know the extent to which its drinking water is contaminated with such poisons.

Even when environmental research is undertaken, it is often carried out with the apparent aim of justifying the continued use of a chemical or the continuation of a given policy. In 1982, for example, Sir Derek (now Lord) Rayner was appointed to conduct an audit of research undertaken by the Ministry of Agriculture, Fisheries and Food (MAFF). Commenting on the need to continue monitoring the biological effects of dumping waste at sea, Rayner listed the three reasons why such monitoring should be carried out:

1. Because the (Oslo and London) Conventions require it;
2. As a check on paper predictions of the effects of dumping;
3. In order to demonstrate to national and international opinion that dumping is safe. [31]

Research to demonstrate that dumping is safe? Whatever happened to scientific objectivity?

Another tactic is to fund research which attempts to pin the blame for environmental damage or adverse health effects on factors which are either outside our control or whose regulation does not demand any drastic changes in policy. Thus, although many eminent epidemiologists now believe that between 50 and 80 percent of human cancers are caused by exposure to radiation or to chemicals in the environment, little research is devoted to the environmental causes of cancer. Instead, the bulk of the funding goes on researching the mechanisms of carcinogenesis at the cellular level and the role that viruses play as possible causes of cancer.

Similarly, Nigel Dudley notes that, according to Steve Elsworth of Friends of the Earth, "The CEGB's scientific research is framed so that it does not ask the question 'what causes acid rain?', but rather 'what apart from sulphur oxide emissions could cause acid damage to the environment?' " [32]

What is 'scientific evidence'?

Even when sufficient data have been acquired to justify the banning of a dangerous environmental pollutant, government scientists often insist that it does not constitute 'scientific evidence'. Thus, although the literature on the connection between nitrosamines and cancer is extensive, this does not prevent government medical advisers from declaring the link to be 'not proven'.

This brings us to the rarely discussed question of what actually constitutes 'scientific evidence'. One of its necessary features is that it must have been obtained by a qualified scientist. This is not a frivolous comment. Often evidence which incriminates a chemical or an activity as harmful is dismissed by the authorities because it has been gathered by a layman, rather than a scientist.

For example, reports by farmers of abortions and birth defects among sheep following their exposure to the herbicide 2,4,5-T, have invariably been classified as "anecdotal evidence" - no matter how many cases are reported by farmers, or how well documented those reports might be. In effect, 'scientific evidence' is a commodity over which scientists have a virtual monopoly - which is of course very convenient, since most of them are employed directly or indirectly by government or industry. Those who are not are unlikely to obtain funding for the relevant research.

Another feature of scientific evidence is its claimed indubitability. But is it really possible to guarantee that a chemical is completely safe? It is certainly difficulty, if not impossible to prove the harmfulness of a chemical substance epidemiologically. Erik Millstone makes this point with regard to food additives:

With 3,500 or more additives being used in millions of combinations, and often in minute quantities (some products contain up to 30 different additives), it is next to impossible for epidemiology to identify any long-term or chronic effects from using particular food additives. [33]

Even under laboratory conditions, it is difficult to prove for certain that a chemical is 100 percent safe. Consider, for example, the problems of testing for carcinogenicity:

• Cancer tends to have a long 'latency' period - that is, it takes a considerable time (5 to 30 or more years) after exposure to a carcinogenic agent before the disease manifests itself. Clearly it is very difficult (if not impossible) to carry out experiments over such a period of time. Yet to expose laboratory animals to large doses over shorter periods (thus artificially reducing the latency period) may give misleading results.
• Cancer can be caused by exposure to numerous chemicals. Since we are exposed to a vast number of possible carcinogens (it is reckoned that some 9,000 different synthetic organic chemicals are in current everyday use, and many of them are either established or suspected carcinogens), a slight carcinogenic effect on the part of an individual chemical could be of significance. However, to test for slight carcinogenic effects is complicated and expensive, since it requires exposing large numbers of laboratory animals to very small doses. Not surprisingly, such tests are rarely carried out.
• Any comprehensive safety test would have to test for all the additive effects and (more difficult still) the synergic effects of all the different combinations of chemicals to which we are exposed.
• It is logistically impossible to carry out all the tests which would be required to establish that a chemical is safe beyond all doubt. To reveal every possible carcinogenic, let alone mutagenic or teratogenic, effect would necessitate testing sufficient samples of every possible combination of all the chemicals introduced into our environment, over a long enough period for the tests to yield meaningful results. Among other things, there are probably not enough technicians, laboratories or indeed laboratory animals available in the world, much less in Britain, to carry out the vast number of experiments which would be required to undertake such tests.
• The tests carried out on laboratory animals, living in totally artificial conditions, cannot be taken as providing hard and fast evidence as to the effects of a chemical on human beings living in the real world. Thalidomide, for instance, had hundreds of times less effect on laboratory hamsters than on human beings.

The myth of 'acceptable levels'

If we take all these, and many other factors, into account, one cannot avoid coming to the conclusion that the 'scientific evidence' to which government scientists attach so much importance does not amount to very much in the way of a guarantee of safety. All we can hope to establish is the probability that a chemical is harmful, and that should be regarded as sufficient information to act upon. Were such an approach to be adopted, however, few of the chemicals we use today would be permitted.

Faced with that reality, the authorities have frequently reacted by simply burying their heads in the sands. Thus a spokesman for MAFF's Advisory Committee on Pesticides (ACP) actually told one of us, Edward Goldsmith, in a telephone conversation in 1977 that there was no evidence that synergic effects existed - this despite a large body of research to the contrary. Indeed, the scientific literature makes it clear that synergic effects are present more often than they are absent.

The refusal of MAFF scientists to face up to the existence (let alone the dangers) of synergy is reflected in the 'permissible' levels which the ministry sets for pesticide residues in food. Those levels are based on the implausible assumption that whilst it is unsafe to consume more than a given amount of a single pesticide, it is perfectly safe to consume a cocktail of many different pesticides - so long as the level of each pesticide in the cocktail does not exceed the permitted level. The truth is that it is impossible to set a safe level for a given pesticide when our food contains tens if not hundreds of pesticide residues - not to mention all the other chemicals purposefully introduced into it by the food industry.

In fact, few of the 'acceptable' levels which have been set for exposure to pollutants (be it pesticides or other dangerous substances) have any serious biological basis. More often than not the 'acceptable' exposure level to a pollutant is the lowest level acceptable to the industry which generates it.

Angela Singer shows how this is so with respect to exposure to asbestos. [34] Indeed the Health and Safety Executive (HSE) has itself admitted that the officially accepted level of asbestos particles in the air we breathe is "of no biological significance"; the level being no more than "an empirical level which we have some hope of enforcing" or "merely what engineering controls achieve".

Other examples abound. Consider the following extract, for instance, from the 1967 Report of the Food Additives and Contaminants Committee on Aldrin and Dieldrin Residues in Food.

We should like to recommend that no aldrin and dieldrin be permitted in milk and baby foods but we are aware that with the great sensitivity of analytic methods it has become possible to detect very low residues of aldrin and dieldrin in food and also that at present it would be impossible to produce milk or baby foods that were entirely free from aldrin and dieldrin. For these reasons we reluctantly decide against a zero tolerance and recommend that a limit of 0.003 ppm be placed on aldrin and dieldrin in liquid milk, this being the lowest practicable limit of analysis. We recommend a corresponding limit of 0.02 ppm in baby foods (including dried milk) which would take account of the difference in residues likely to be found in liquid and dried products. We also recommend that all ingredients for baby foods should be chosen by manufacturers with a view to keeping the aldrin and dieldrin content to the lowest possible level. While these limits seem to us realistic, we do not accept them readily or with equanimity. [35] (Our emphasis.)

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Notes

26.	Chris Rose, Chapter 11, "Pesticide Controls", pp.136-7.
27.	Erik Millstone, Chapter 15, "Food Additives", p.184.
28.	A. H. Walters, "Nitrates in Food", The Ecologist Vol. 15 No. 4, 1985.
29.	Chris Rose, Chapter 12, "Pesticides: An Industry out of Control", p.160.
30.	David Wheeler, "Britain's Polluted Drinking Water", The Ecologist Vol. 16 No. 2/3,1986.
31.	The Rayner Scrutiny Committee on Fisheries Research and Development, Draft Report 1982.
32.	Nigel Dudley, Chapter 8, "Acid Rain and British Pollution Control Policy", p.96.
33.	Erik Millstone, Chapter 15, "Food Additives", p.184.
34.	Angela Singer, Chapter 17, "Asbestos", pp.198-209.
35.	Report of the Food Additives and Contaminants Committee on Aldrin and Dieldrin Residues in Food, HMSO, London 1967.