In December of 2011, Susan Dudley, the Director of the George Washington University Regulatory Studies Center proposed something radical in her presentation: “EPA’s Mercury and Air Toxics Rule Will Not Improve Public Health.” The radical aspect of this presentation seems self-evident. She begins:
“The estimated $90 billion per year and 11,000 premature deaths avoided are derived not from reducing the toxic emissions that EPA is statutorily obligated to address (and which its press releases tout), but by counting what it refers to as ‘co-benefits.’”1
The discussion of why these are not feasible estimates, though absolutely fascinating, are not necessarily the focus of this paper (though certainly a phenomenal reason for re-evaluation of the process environmental cost-benefit). Dudley illustrates a great point: what is the real impact of Mercury? Acutely, the compound is renown for neurological damage. With these new EPA protocols:
EPA’s public emphasis on reducing mercury emissions is extraordinarily misleading. Its analysis places an upper bound value on the benefits of reducing exposure to toxic mercury emissions at $.006 billion (not per year, but total present value) and predicts even the most highly exposed children will gain 2/10ths of one percent of an IQ point (.002 IQ point) as a result of these regulations. These are the only “direct” benefits EPA presents in support of the rule. Scientists suggest even these very small effects greatly overstate the likely effects of the rules on children’s health, arguing that EPA “systematically ignored evidence and clinical studies” in developing these health estimates.1
She also addresses the problems of child and senior premature death estimates, as well as dissecting the “EPA’s claim that the “rule will provide employment for tens of thousands of Americans, by supporting 46,000 short‐term construction jobs and 8,000 long‐term utility jobs” by showing the loss of jobs created as a result of this new rule were not included in this “net job creation.”1
Regardless, Mercury does remain a very toxic and viable problem…especially in your home. Director Dudley makes excellent points: acute impact of these rules does not cause for an offset of the cost-benefit aspect of Mercury mitigation. The problem, though, is not in the acute aspect of this chemical: this chemical’s chronic impact is really the overwhelming problem. Mercury poisoning generally does not impact someone until it has accumulated in large doses, in either the organic or inorganic form. Mercury emitted from smokestacks undergo methylation, which allow for deposition on other organic material. As this methylmercury would be fairly evenly distributed atop of water surfaces, one assumes an initial uniform distribution in fish populations. This organic mercury, when ingested by fish, sits in different organs, specifically the liver and brain. Since as more Mercury is ingested, larger amounts accumulate, as bigger fish eat smaller fish, the levels of Mercury escalate in larger fish predators. Therefore, when humans eat these larger fish, the levels of mercury in the larger fish are passed on to them. This caused for over 2200 victims and nearly 1800 deaths due to this chronic, toxic influence. This is especially problematic in pregnant women, as fish are generally encouraged to pregnant and nursing mothers, as to elevate omega-3-fatty acid levels.
Have this many chronic, toxic deaths occurred due to bioaccumulation in the United States?
Not as many, no, but a very different problem is occurring. This whole, unique process was explained in “Mercury exposure – it’s not just fish,” a lecture by Professorial Lecturer Herman Gibb at GWU. This being said, heavy amounts of products in the US have been found in make-up, skin whitening products, soaps, creams, and other household appliances. Really, the mitigation of Mercury from air is only part of the problem. Bioaccumulation occurring in people from commercial products also impacts this whole process. The increase in total mercury, whether organic or inorganic, results in historically high levels. These levels of mercury and methylmercury can result in kidney failure, renal failure, neuronal function, or any number of factors, and can impact any number of developmental problems in neonatal and developing children. In conjunction, with rising mercury levels, historically high levels of Mercury were shown in those using these commercial products in Virginia and California in a recent study conducted by Professor Gibb (source unknown).
The research then expressed how high levels of Mercury from factories correlate to high blood levels in susceptible sub-populations. The good news? Levels seen in the emissions exposure in the test subjects from the study are not generally found in America due to EPA regulations. In conjunction, products with elevated levels are generally made in the United States. Therefore, the elimination of both of these factors seem not only reasonable, but probable. In conjunction, with current CPSP regulations, most of these issues are not even potential hazards. This being said, these events do have relatively minor impact in day-to-day events, which culminate into major chronic outcomes, which should take attention. Further research in to all Mercury products needs to be undergone, and in conjunction, research in to “true” benefits of the EPA ruling with this consumer product data compilation will offer a more full view of the most susceptible populations, as EPA analysis always does.
The function of the EPA’s rules are precautionary – protect the most susceptible sub-population as to make sure no potential adverse health impacts will occur. In conjunction, “co-factors” really cannot be avoided in chronic studies; chronic impacts cannot really express direct cost-benefit one-to-one correlation, and therefore co-factors must somehow be included in the cost-benefit. Perhaps what EPA should do is offer the initial cost-benefit, followed by a co-factor adjustment by private consulting company. Or, perhaps the EPA should adjust co-factor input as a function of population generally undergoing chronic or acute Mercury toxicity, as opposed to universal input. Or perhaps…. that is not the point. Fair assessment and cross-institutional input in to these new measures need to occur in order to fully realize the impact of rulings.