Piecemeal, and at long last, chemical manufacturers have begun removing the endocrine-disrupting plastic bisphenol-A (BPA) from products they sell. Sunoco no longer sells BPA for products that might be used by children under three. France has a national ban on BPA food packaging. The EU has banned BPA from baby bottles. These bans and associated product withdrawals are the result of epic scientific research and some intensive environmental campaigning. But in truth these restrictions are not victories for human health. Nor are they even losses for the chemical industry.
For one thing, the chemical industry now profits from selling premium-priced BPA-free products. These are usually made with the chemical substitute BPS, which current research suggests is even more of a health hazard than BPA. But since BPS is far less studied, it will likely take many years to build a sufficient case for a new ban.
But the true scandal of BPA is that such sagas have been repeated many times. Time and again, synthetic chemicals have been banned or withdrawn only to be replaced by others that are equally harmful, and sometimes are worse. Neonicotinoids, which the International Union for the Conservation of Nature (IUCN) credits with creating a global ecological catastrophe, are modern replacements for long-targeted organophosphate pesticides. Organophosphates had previously supplanted DDT and the other organochlorine pesticides from whose effects many bird species are only now recovering.
So the big and urgent question is this: if chemical bans are ineffective (or worse), what should anyone who wants to protect themselves and everyone else from flame retardants, pesticides, herbicides, endocrine disruptors, plastics and so on—but who doesn’t expect much help from their government or the polluters themselves—do?
What would an effective grassroots strategy for the protection of people and ecosystems from toxic exposures look like? Ought its overarching goal be a reduction in total population exposures and/or fewer chemical sales? Or should it aim for sweeping bans, such as of entire chemical classes? Or bans on specific usages (e.g. in all food or in all of agriculture)? Or on chemical use in particular geographic locations (e.g in/around all schools)? Or perhaps a better demand would be the dismantling (with or without replacement) of existing regulatory agencies, such as the culpable EPA? Or should chemical homicide be made a statutory crime? Or all of these together? And last, but not least, how can such goals be achieved given the finances and politics of our age?
The first task of chemical campaigning is to strip away the mythologies which currently surround the science of toxicology and the practice of chemical risk assessment. When we do this we find that chemical regulations don’t work. The chief reason, which is easy to demonstrate, is that the elementary experiments performed by toxicologists are incapable of generating predictions of safety that can usefully be applied to other species, or even to the same species when it exists in other environments or if it eats other diets. Numerous scientific experiments have shown this deficiency, and consequently that the most basic element of chemical risk assessment is scientifically invalid. For this reason, and many others too, the protection chemical risk assessments claim to offer is a pretense. As I will show, risk assessment is not a reality, it is a complex illusion.
This diagnosis may seem improbable and also depressing, but instead it reveals promising new political opportunities to end pollution and create a sustainable world. Because even in the world of chemical pollution, the truth can set you free.
The ensuing discussion, it should be noted, makes no significant effort to distinguish human health effects from effects on ecological systems. While these are often treated under separate regulatory jurisdictions, in practice, risks to people and ecosystems are difficult if not impossible to separate.
The story of the toxicological alarms surrounding BPA, which are diverse and scientifically extremely well substantiated, make an excellent starting point for this task.