Cold Fury

Harshing your mellow since 9/01


A tried-and-true tactic originating with the Soviets, now brought to its fullest flower by their American understudies.

Even before the manipulation of numbers became commonplace, the manipulation of words was a major tool in keeping the fear alive. Simple words in common usage, like “risk”, “known”, “similar” and “equivalent” were given esoteric meanings that bore little resemblance to their definitions in Webster’s Dictionary and of which the general public was completely unaware.

Thus, unbeknownst to the average citizen, EPA’s so-called quantitative cancer risk assessments have never quantitatively assessed the true risk of potentially carcinogenic exposures. In EPA’s 1986 Risk Assessment Guidelines, the following, uncharacteristically honest, and seldom quoted (except by me) statement was made: “The true risk is unknown and may be as low as zero.” Obviously, if the “true” risk is unknown, then the “risk” that is supposedly quantified in EPA risk assessments cannot be the “true” risk. Throughout my career as an ATSDR toxicologist, I routinely quoted the “zero true risk” statement in all of my toxicological evaluations for health assessments that addressed potential cancer hazards on site. And, it never failed to irritate agency management, and even some of my colleagues.

Originally, EPA classified chemicals as “known”, “probable” or “possible” carcinogens. These classifications were strictly defined. In particular, a substance could be classified as a “known Human Carcinogen” only if sufficient epidemiological evidence existed to establish a cause-and-effect relationship between cancer and exposure to that substance. However, in 1996 (the date of the first draft), EPA rewrote its Cancer Risk Assessment Guidelines (CRAGs) to allow it to classify substances as known human carcinogens in the absence of any epidemiological evidence of a cause-and-effect relationship. The final draft of EPA’s new CRAGs was not actually published until 2005, but, 5 years earlier (2000), dioxin (2, 3, 7, 8-tetradichlorodibenzodioxin) became the first chemical to which the new CRAGs were applied, resulting in that chemical’s re-classification as a “known” human carcinogen. 

On November 28, 2006, late in my career as an ATSDR toxicologist, I delivered an in-house lecture entitled “Frank’s Last Word on Dioxin” to a very small audience. I concluded my lecture by predicting that the next “bogus human carcinogen” would be trichloroethylene. Just 5 years later (September 2011), TCE was, indeed, declared by EPA to be a “known” human carcinogen, notwithstanding all of the toxicological & epidemiological data to the contrary.

When they were originally created, both federal agencies had legitimate problems to solve. But, EPA quickly became a victim of its own success. As the environment became cleaner, there were fewer and fewer real environmental problems to address. So, they began inventing them, initially by just making their dose-specific health guidelines and media–specific comparison values smaller to create the impression of increased “risk”. Then, they would make the unsubstantiated and over-used claim that chemical X “is now more toxic than previously thought”. But, it was almost never true.

If all this is confusing, it was meant to be. Because, when something unintelligible is expressed mathematically and claims to be “scientific”, the tendency is for most people to assume that it is just “over their heads” and accept it uncritically. However, in this instance, as Seven of Nine said in Star Trek Voyager (Season 6, Episode 2), “You are being confused by irrelevant data; Ignore it.” In reality, the sole purpose of EPA’s scientifically bankrupt HEC method for evaluating the “risk” associated with “equivalent” inhalation exposures was to rescue the cherished (but counterintuitive) bureaucratic assumption that humans are more sensitive to the adverse effects of chemical exposure than are experimental animals.

It is an entirely defensible argument that, in order to protect the public health in the face of unresolved uncertainties, it is often necessary that agencies charged with that responsibility should “err on the side of safety”. However, that argument does not justify intentionally erring on the side of the absurd. For, there is with all things a point of diminishing returns. And, when we start basing expensive public policy decisions on the mere possibility that an implausible thing might happen, then we may as well start building airports for UFOs.

Don’t give them any bright ideas, buddy, they’ll get around to it soon enough. But the EPA is hardly alone in their ongoing campaign to sow FUD via rejiggering the mother tongue:

Two parties, two vocabularies. One positive, one negative — very bad, evil in fact.

Consider the testimony by Michael Cohen last week in front of various Congressional committees.

For example, since he worked for Donald Trump, Cohen was described about a million times as a “fixer.” Democrats, on the other hand, have lawyers.

Hillary Clinton paid hundreds of thousands of dollars to Democrat operatives who then bought or made up false Russian dirt on Trump — that was opposition research. Republicans, on the other hand, “collude!”

Republicans lie, Democrats misspeak.

Democrats plan, Republicans scheme.

If a Democrat changes his or her position on an issue, they have evolved … grown. Republicans “flip-flop.”

Whenever an unfamiliar politician is ensnared in some scandal, you naturally wonder which party he or she is a member of. If the “embattled” pol is a Republican, affiliation is usually noted in the headline, or at the very latest in the first paragraph.

If, however, you reach the third paragraph of the story without his party being identified, you can be absolutely certain you are reading about a Democrat miscreant.

A lot more to both of these articles, all of which you should read.


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"America is at that awkward stage. It's too late to work within the system, but too early to shoot the bastards." – Claire Wolfe, 101 Things to Do 'Til the Revolution

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