The trouble with regulations…

…is that they rely on assumptions, so regulations can only be as effective as their assumptions are accurate.

Regulations are also mired in verbosity and jargon, and steeped in complexity, making them nearly unapproachable by the average person. And yet, regulations are all that stand between us and the harm that comes from poisoning our air, food, and water. We have little choice but to rely on the expertise of others, who must write effective regulations and see that they’re enforced: a costly, but essential, function of government.

The foundation of all regulations are the assumptions upon which they’re built, so it’s obvious that if the assumptions are flawed, the regulations will likewise be flawed. Environmental chemists in Canada* have been examining the assumptions that underlie regulations addressing a major class of chemical pollutants—“persistent organic pollutants” (POPs)—that are persistent because they are resistant to breakdown, typically tending to accumulate in the food chain, especially in fatty tissue; organic because they are carbon compounds that are the subject of organic chemistry (very different from the “organic” of organic food); and pollutants because they are toxic to living organisms. Some better known POPs are pesticides, solvents, PCBs, and dioxins.

When regulatory agencies began addressing pollutants, it was understood that pollutants that bioaccumulate (by magnifying in concentration as one organism eats another, and is then eaten by another, etc., in increasing trophic levels right on up the food chain) are the most treacherous, because higher level predators (like us) can end up consuming very high amounts of a pollutant that was originally present in the environment at a relatively low level. Thus, the primary regulatory focus has wisely been on such bioaccumulating toxics known as POPs.

The trouble is that in defining POPs, regulators chose to measure their bioaccumulating potential in fish, for reasons that remain unclear to me. After all, we are not fish, and there are many non-fish terrestrial organisms, and we all have very different life circumstances, beginning with the fact that we are air-breathers. Indeed, this turns out to be a very flawed assumption in the regulatory model.

POPs have traditionally been evaluated using a measure called KOW, an indicator of a substance’s solubility in water, roughly:

• High KOW** substances are highly hydrophobic and poorly metabolized and poorly excreted in aquatic organisms, and tend to accumulate in fat, and this is a reliable predictor of which compounds will bioacumulate in fish.

• High KOA*** substances are only moderately hydrophobic, are poorly metabolized, and are poorly excreted, and thus will bioaccumulate, in air-breathing organisms.

Regulations currently address compounds that have a high KOW but not those that have a high KOA and therein lies the problem.

The graph below illustrates what happens in real food webs that are contaminated by a low KOW but high KOA compound, i.e, one that would not be considered bioaccumulative by current regulations:

Kelly, et al., 2007

Note the dotted blue line, that of the piscivorous (water-breather) food web. This data shows a lack of bioaccumulation (with the concentration of the ß-HCH remaining constant all the way up the food chain), and this data would be what current regulation is based upon.

In contrast, note the solid green line, that of the terrestrial (air-breather) food web. This data shows a strong bioaccumulation that occurs in just three trophic levels. Note also that the concentrations measured are on a logarithmic scale, so the concentration in the caribou is about 10 times that found in the lichens it grazes on, while the concentration in the wolf is another 100 times more concentrated than that of the caribou, or a 1000 times higher concentration than that of the organism at the base of the food chain.

Unsurprisingly, the solid blue line, indicating the marine mammal food web which includes both air- and water-breathers, has a slope that is intermediate to that of the other two food webs. However, the resultant concentrations in the top predators of this food web exceed those found in the terrestrial web, simply because there are more intermediate trophic levels. [Humans are included in the “marine mammal” food web because they are consuming both air- and water-breathing marine organisms.]

The key point here is that while the regulators assume that given its low KOW, ß-hexachlorohexane is non-bioaccumulative, and thus regulate it as such, it is actually highly bioaccumulative in the real-world environment that includes terrestrial organisms and marine mammals. The authors of this study estimate that about one-third of organic chemicals currently in commerce fall into this low-KOW / high KOA class of compounds, that may currently be regulated as toxic, but are not regulated as the more hazardous bioaccumulating class of toxic compounds that many of them are.

This is a very big deal, but unfortunately, the topic is sufficiently complex that news coverage is very scant. One hopes the regulators are paying attention in our stead.

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*2007. Kelly, B., Ikonomou, M., Blair, J. Morin, A., Gobas, F. “Food Web-Specific Biomagnification of Persistent Organic Pollutants.” Science, 317:236-239.

**High KOW compounds are more precisely defined as those substances having a high octanol-water partition coefficient, but a complete understanding of this is not needed for a general understanding of the issue.

***High KOA have a high octanol-air partition coefficient.

Hook, line, and sinker

Buried at the end of a page C11 New York Times story about the funeral of 17-year-old Pfc. Le Ron Wilson, killed in Iraq by a roadside bomb, is the following:

A few blocks away…it was break time at the military recruiting center… Two girls cantered streetward…out into the sunshine… “We go leafleting, we call people up about recruitment… A lot of people say ‘no’ right away because they think they have to go straight to Iraq, but that’s not true, there’s other things they could do.”

She was 14. Her companion was 15. All told, they said, nine teenagers, paid $7.15 an hour by the city’s summer job program, are working at the Jamaica recruiting center. Military recruiting, of course, is the work of professional soldiers, not teenagers in a summer program to learn how to hold a job.

Army recruiters will stop at nothing in their quest to ensnare the unwary. Demonstrably unable to meet their recruitment goals based on the merits of military service and our ongoing adventures in the Middle East, recruiters have resorted to dangling young girls as lures, the better to coax reluctant young men to suspend logical thought and to demonstrate their “manliness” to the young girls who are trained and paid to manipulate them into signing on the bottom line, signing their very lives away.

Very creative, these recruiters! And they get this recruiting assistance for free, by exploiting a city-sponsored summer jobs program, and by exploiting gullible young girls desperate to earn a few dollars and to gain some job experience. But what are they being trained to do? Is it the purpose of a summer jobs program to teach nascent employees how to lie, whether by omission or evasion or simple incomprehension? Just how likely is it that the young recruits will do “other things,” rather than ship out to Iraq? Numerically, what are the odds?

The girl’s wording is interesting too: “there’s other things they could do” and sounds to be straight out of a training video in how to manipulate your “sales” target. Well sure, they could end up being recruited straight out of basic training into the NASA astronaut program, or they could end up in the Presidential honor guard. But the odds of doing anything not involving shipping out to Middle East are what again? Oh, right: between slim and none.

This is an abominable use of a summer jobs program, and an unconscionable means of entrapment via post-pubescent hormonal imbalance. Surely so worthy a cause ought to be salable on its own merits! But if not, perhaps that in itself should be a powerful message sent to those who rule us. The choice that has been made (in OUR name) is instead to use the gullible to recruit the gullible, by manipulation and deceit, just one more example of the immorality of the entire enterprise.

All involved ought to be ashamed.

“Benevolent” child abuse

A story in today’s New York Times describes a major elbow surgery that parents are paying to have done to their children, solely in order to “improve” their pitching arms. Why is this even legal?

modified from original; color diagram modified from Human Anatomy, by Martini, Timmons, and Tallitsch (5th Ed.), 2006

The phrase “benevolent child abuse” was used in the article, an oxymoron if ever there was one, and I would strongly challenge its supposed benevolence. The pain and trauma and risks involved, and the unknown sequelae to be dealt with later in life should be enough to rule it out, but there are those for whom the lure of possible stardom by proxie is so intoxicating that they would happily subject their own children to pain and risk and trauma—what else could this be but child abuse?

“Although it is highly successful, the surgery may require two years for recovery. Infection, fractures, nerve irritation and numbness are possible. About 20 percent of pitchers do not return… Even when the risks are explained, and parents are told that many young pitchers eventually lose interest in the sport, Dr. Andrews said, ‘It doesn’t seem to faze them.’ ”

The child is not mature enough to make such a choice, and by what justification should the parent be able to order surgical (or chemo- or genetic-) “enhancements” to a child simply to suit their own dreams and desires? Do they have any comprehension of more likely failure of other parts (read: rotator cuff) when additional strength is “engineered” into vulnerable constituents of a system?

It is into this climate that the whole issue of genetic “enhancement” arrives. I find it all so disheartening from the individual autonomy perspective. There are cultures in which a parent retains sole authority over their child’s life in perpetuity, in matters of marriage choices and occupation and dress and freedom of movement and household location and personal relationships and basically every aspect of their daily life, for their entire lives—is this what we are moving toward in America? Do parents own their children? Have we really forgotten what freedom means? Isn’t the autonomy of one’s body pretty much the most fundamental sort of autonomy we have?

Very, very distressing.

The surge continues

data from globalsecurity.org

Open letter to Speaker Pelosi…

Are we a nation ruled by law, or are we not?

If we are a nation ruled by law, it is time for George Bush and Dick Cheney to be called to account for their many crimes against this country. Their actions are exactly what the founding fathers had in mind when they outlined the process of impeachment. To continue to give this administration a free pass literally puts our nation in grave peril. It is your duty as an elected representative to respond to the will of the people. It is your sworn duty to uphold the Constitution of the United States. The impeachment of President Bush and Vice President Cheney follows directly from these two, most fundamental, duties that comprise the primary responsibility of your office. Abdicating this responsibility in the interest of decorum or expedience is not an option. By what logic did you declare that “impeachment is off the table”?

If we are not a nation ruled by law, we might as well dissolve the legislature now, rather than continue with the ruse. At least then we would know where we, the people, stand. To allow this imperial presidency to continue with its grievous abuses, unchecked, is to declare by default that laws do not matter, and that our “checks and balances” are naught but a pretty pretense.

PLEASE: Begin impeachment proceedings against President Bush and Vice President Cheney, NOW!

James Madison wrote: “If the President be connected, in any suspicious manner, with any person, and there be grounds to believe he will shelter him, the House of Representatives can impeach him; they can remove him if found guilty...”

Madison’s words could not be more applicable than to President Bush’s commutation of Libby’s sentence (that was well within the sentencing guidelines)! President Bush’s commutation of Libby’s sentence demonstrates to all that Bush has “sheltered” (and will “shelter”) those who would cause real and lasting harm to our nation at his bidding, as Libby so clearly did.

We are suffering under a rogue administration, and until the House of Representatives steps up to the plate, this great nation of ours will be at great risk. This is exactly the purpose of the impeachment proceeding! If you have a reason to evade this most profound responsibility, please state it! It is not acceptable to simply decree that “impeachment is not on the table.” Impeachment is the only remedy at hand!

I am a lifelong Democrat, and have voted in every single election held since I came of age. As dismayed as I am regarding the Bush Administration, I have to say that I am almost equally dismayed with the anemic response of the Congress we elected in November 2006, with a few exceptions such as Henry Waxman and Patrick Leahy and Barbara Lee. There is no more important business for Congress at this moment in history than righting our ship of state (which of necessity includes impeachment proceedings against at least George Bush and Dick Cheney but probably should also include the impeachment of Attorney General Gonzales); returning all civil liberties to the citizenry; and extricating ourselves from the Mideast Follies of Bush-Cheney.

I beseech you: Begin impeachment proceedings as the top priority of business of Congress, immediately!

____________________________________

Send your own letter: http://www.speaker.gov/contact/

If you need further inspiration, listen to Bill Moyers as he discusses impeachment with Bruce Fein and John Nichols.

Mr. Bush, please note…

Here are three acceptable answers to one of the new naturalization test questions:

from pilot civics naturalization test

Surely, even you can see that yes, this means YOU…

America, Land of Really Big Eaters

Epitomizing for me the state of our nation on this glorious 4th of July:

original by: Reuters / Lucas Jackson (modified)

We just can’t cram it in fast enough.

Billions go hungry, while we support “competitive eating” as a sport. This “winner” crammed in 66 hotdogs, to which I can only say: BFD! This is not a “sport” by any stretch of the imagination! It is merely a uniquely American obscenity.

Billions go hungry, while we convert 27% of U.S. corn into fuel for our SUVs.

“The [corn] required to fill a 25-gallon SUV gas tank with ethanol [would] feed one person for a year.” Earth Policy Institute

As Michael Pollan so clearly delineates in The Omnivore’s Dilemma, most of what we eat can be traced to corn—meat, poultry, dairy, sweetener, cereal, many additives, beer, soft drinks, farmed fish, cooking oil, etc.—and corn prices have already risen by nearly 70 percent.

And now, while taxpayers and the environment foot the bill for corn production, food prices are already rising. But go ahead, fill up your SUV for a run to the corner market ten blocks away. Swill that corn to your heart’s content. Let’s take competitive eating to an all new level! Ain’t we special…

Oh, and PS: Do enjoy all the additional acetaldehyde that will be included in every breath of air: no extra charge!