Science, regulations, and the safe handling of chemicals

Abstract

Diverse scientific, technical, and technological factors must be considered when developing chemical safety regulations which may have to bridge many segments of industry. The handling and disposal of chemical wastes, too, have their own unique problems at every stage in the chain. Unfortunately, regulatory initiatives based on sound scientific and factual evaluation have often been lacking in the regulatory process. Some examples of ill-conceived regulations are the Occupational Safety and Health Administration's original generic cancer policy; the Environmental Protection Agency's 1979 proposal for an airborne carcinogen policy; and a move by the Food and Drug Administration in 1979 to regulate carcinogen residues in meat and poultry on the basis of unproven science. Industry realized that poor regulations would be far worse than no regulations at all. As one response, the American Industrial Health Council (AIHC) was formed to promote the integration of sound science into regulatory policies and decisions relating to chronic health hazards. This paper, presented as a speech before the Industrial Research Institute in May of 1982, describes the AIHC's proposals. The AIHC defined a logical decision process consisting of four steps leading to the selection of appropriate regulatory responses. The first three steps, Hazard Identification, Hazard Evaluation, and Risk Evaluation, are called the risk assessment process. The final stage is Regulatory Response. Use of this process can bring about the right kind of partnership between science and society in the regulatory process. These principles are so general they can be applied in regulatory areas beyond those originally intended, such as the problems of hazardous waste sites. An example of a bad approach to dealing with hazardous waste is the Love Canal waste site. In this case, the regulators did not first seek sound scientific facts on which to base societal value judgments. A positive example of hazardous waste site management implementing this four-step process is the McColl disposal site in Fullerton, California. While some aspects of the investigation are still in the Hazard Identification stage, others have moved into the second stage of Hazard Evaluation. This is a case where there has been a deliberate avoidance of leaping to conclusions before the existence and the degree of hazard have been determined so that the risks can be assessed and the proper responses made. A framework for decision making represents a common-sense approach. The AIHC's principles have not been fully embedded in the legislative or regulatory processes of this country, but the opportunity now exists to get these principles and methodologies embedded in the laws as they are amended, in regulations as they are created, and in policies as they are devised.