From the WSJ Opinion Archives
SCENE & HEARD
A Dose of Sanity
Christie Whitman shows she's not afraid of mice.
Stop the presses. Environmental Protection Agency Chief Christie Whitman might not be as much of a lost cause as previously assumed.
When the former New Jersey governor took over the EPA, nobody held out much hope. The agency she was stepping up to lead had become enamored of its own power, had succumbed to activists and had lost all capacity to make rational decisions about risk. Ms. Whitman was said to have a soft spot for environmental causes.
True to form, Ms. Whitman didn't pursue any real reform. Instead, she rolled over on the Clinton arsenic standards, and has continued to wage the previous administration's war against General Electric--insisting the company spend $5 billion on a misbegotten proposal for dredging the Hudson River. All that came after she chose to publicly waggle on about the perils of global warming.
But now comes news that the EPA is considering allowing human tests of pesticides, a move that has sent activists into a frenzy. On closer inspection, the tests themselves might not be such a hot idea from either a practical or ethical standpoint. But the announcement is important, nonetheless. It shows that Ms. Whitman--or at least some boss in the Bush administration--is aware of the shenanigans that have been going on the agency, and is signaling a willingness to do something about it.
At issue is the way in which the EPA and other health agencies decide whether to ban a substance. In 1958, Congress passed a provision called the Delaney Clause that banned any synthetic food chemical found to cause cancer in lab rodents. This "mouse is a man" concept, while interpreted and enforced in varying ways, has become a cornerstone in the way government agencies--even those, like the EPA, that have nothing to do with food additives--have come to evaluate everything from food additives to pesticides.
It didn't take long for groups opposed to synthetic substances in principle to figure out that fiddling with rat science was a fairly easy thing to do. Remember the old adage: It's the dose that makes the poison. Scientists know that if they just keep pumping something into a rodent, at some point it'll die. Of course that doesn't mean that humans ever would, or even could, be exposed to equivalent levels of these substances, or that trace amounts would have any effect. But rodent results are good enough for the EPA.
Consider the scare over Alar, a growth regulator used on apples. It turns out that in the real world a human would have to eat 28,000 pounds of apples a day for 70 years to equal the amounts given to the test animals.
But now the EPA has signaled that it might consider allowing data from human testing of pesticides to be part of regulatory decisions. The idea is that by using real people, we'll be able to more precisely measure just what humans can tolerate, or whether some of these substances have any effect whatsoever on our health.
Critics have come out screaming that the tests are unethical; some went so far as to suggest they violate the Nuremberg Code adopted after World War II. My own hunch is that a significant number of these groups--especially the environmental organizations--don't care so much about ethics as they do about losing their hold over the regulatory process. Still, there are some legitimate questions about administering substances to humans solely for the purpose of seeing how much they can take before they get sick.
A member of the American Crop Protection Association was quoted as saying that the risks to volunteers are "miniscule," and actually much lower than the risks of pharmaceuticals. The comparison however, isn't really valid. When people engage in medical tests, they do so not just to prove a drug is safe, but with the hope that it will provide some health benefit to them. For pesticides, there is no corresponding benefit for volunteers.
But perhaps the bigger question about human tests is whether they will have much practical effect. The truth is that even if the EPA allows human tests, and even if they prove that certain pesticides don't cause adverse reactions, the opposing groups would only come up with further demands. They'd claim that we still didn't know the long-term effects, or what the substance in question did to pregnant women, or to children, or whether it was more dangerous to people with immune deficiencies.
Despite the potential difficulties with the test, simply putting them on the table was a good idea. For starters, it shows that the Bush administration isn't asleep at the wheel. It has managed to identify one of the bigger shams within the agency. It knows these rules have been used to ban products willy-nilly, causing a greater number of American needless scares in the process and distorting the average person's understanding of acceptable risk.
With the problem identified--and even if human tests aren't the end solution--the Bush administration has put itself in a position to suggest other approaches--all of which would cut through the man-is-a-mouse malarkey. It might, for instance, suggest that animal tests be done on a wide variety of species--including monkeys--and that dose levels be evaluated in a more sensible way. It could also learn more on epidemiological studies that observe cancer and other chronic disease pattern in people who have, and have not, been exposed to certain additives or chemicals.
Perhaps most important, putting the idea of human tests on the table helps to call the activists' bluff. For years, groups like the Natural Resources Defense Council have argued that while they can prove the chemicals are harmful to animals, the pesticide industry can't prove they are safe for humans. Now that the industry has said it wants to try to prove they are safe for humans in a series of monitored experiments, the activists are saying they shouldn't even be allowed to try.
The truth, of course, is that many of these groups do not have a public-health strategy in mind. They see any man-made substances--no matter what their toxicity or dose--as harmful to Mother Earth. With their reluctance to really get to the bottom of the question, they only make it that much more obvious.
In the end, the Bush administration has a much harder task in front of it than simply changing the types of tests that are used in regulatory decisions. The administration must go to the roots, and attempt to restore the basic principles of common sense, rational risk evaluation, and cost-benefit analysis, to our agencies.
Common sense alone shows how silly our current policy over pesticides has been. "Over the past decades, all health status measures have dramatically improved, thanks in part to the increasing safety and nutritional content of our food supply," says Gilbert Ross of the American Council on Science and Health. "If pesticides were in any way dangerous, either acutely or chronically, would we not have seen some deleterious effects?"
Putting the question of human tests on the table is the first step toward confronting sensible questions like this.
Ms. Strassel is an assistant features editor of The Wall Street Journal's editorial page. Her column appears on alternate Thursdays.
