xxiv
Abel Wolman
This Conference gives us an opportunity to rehearse the considerations which should
guide us in making our best contribution to the health and welfare of society. A few
months ago, Dr. H. E. Stokinger, in the United States, presented several guidelines for
investigators. Parenthetically, Dr. Stokinger is the chief of the Laboratory of Toxicology
and Pathology of the National Institute for Occupational Safety and Health, of the
United States Department of Health, Education and Welfare. He dignified his suggestions
in a series of commandments,* as follows:
"1. Standards must be based on scientific facts, realistically derived, and not on
political feasibility, expedience, emotion of the moment, or unsupported information.
"2. All standards, guides, limits and so on, as well as the criteria on which they are
based, must be completely documented.
"3. Avoid the establishment of unnecessarily severe standards. This admonishment runs
against the current tide of boiling popular enthusiasm for cleaning up pollution
completely. But it is time that popular enthusiasm cool down, to recognize the
consequences of establishing goals instead of standards.
"4. Determine realistic levels.
"5. Interpret the 'Delaney clause' with informed scientific judgment. This much
maligned clause has become an excuse for oncologists to use inappropriate and
unrealistically high levels in testing for carcinogenic potential.
"6, Determine trends, not pro tempore monitoring. The most flagrant violations of this
commandment are the recommendations . . . regarding mercury .. . One moment's reflection would reveal that the concentration of mercury in the oceans has not changed
perceptibly since the white men reached these shores, and that men have eaten these fish
»and lived and died without signs or symptoms of mercury poisoning. This is not to say
that local, aqueous mercury or other excess pollutants should not be spotted, and, when
possible, controlled, but that the thoughtless and irrational extension of a local finding to
global dimensions is inconceivable in persons of sound mind!
"7. Delimit banning.... The banned food additives were either unnecessary or could
be readily substituted with less harmful substances. Not so the totally banned DDTt and
alkyl mercury compounds. First, DDT does not present an 'imminent hazard' to public
health, despite misstatements to the contrary; second, its use for controlling the spread of
malaria and African trypanosomiasis is unexcelled, and equivalent substitutes are not
available at this time."
To these precepts, other cautions should be recorded. It is unfortunate that rarely are
the consequences of decision making so set forth as to make clear, not only monetary
costs and benefits, but the far more subtle resultants. Remote and intangible
consequences are rarely assessed, because these so often lend themselves to exaggeration
both for good and evil results. For example, the purification of water is often in a low
cost category, while the processes for waste treatment of very high efficiency are more
expensive. Choices between them are too often determined by emotion rather than by
reasonably familiar quantitive parameters.
Similarly, threats of economic disaster due to abatement measures and costs are
*H. E. Stokinger. How to Achieve a Realistic Evaluation. Science, 174, 662-665 (November 12,
1971). Jour. American Water Works Association, 64, No. 4 (April 1972).
tThe ban has so far been lifted by the Environmental Protection Agency. (A.W.)
Abel Wolman
This Conference gives us an opportunity to rehearse the considerations which should
guide us in making our best contribution to the health and welfare of society. A few
months ago, Dr. H. E. Stokinger, in the United States, presented several guidelines for
investigators. Parenthetically, Dr. Stokinger is the chief of the Laboratory of Toxicology
and Pathology of the National Institute for Occupational Safety and Health, of the
United States Department of Health, Education and Welfare. He dignified his suggestions
in a series of commandments,* as follows:
"1. Standards must be based on scientific facts, realistically derived, and not on
political feasibility, expedience, emotion of the moment, or unsupported information.
"2. All standards, guides, limits and so on, as well as the criteria on which they are
based, must be completely documented.
"3. Avoid the establishment of unnecessarily severe standards. This admonishment runs
against the current tide of boiling popular enthusiasm for cleaning up pollution
completely. But it is time that popular enthusiasm cool down, to recognize the
consequences of establishing goals instead of standards.
"4. Determine realistic levels.
"5. Interpret the 'Delaney clause' with informed scientific judgment. This much
maligned clause has become an excuse for oncologists to use inappropriate and
unrealistically high levels in testing for carcinogenic potential.
"6, Determine trends, not pro tempore monitoring. The most flagrant violations of this
commandment are the recommendations . . . regarding mercury .. . One moment's reflection would reveal that the concentration of mercury in the oceans has not changed
perceptibly since the white men reached these shores, and that men have eaten these fish
»and lived and died without signs or symptoms of mercury poisoning. This is not to say
that local, aqueous mercury or other excess pollutants should not be spotted, and, when
possible, controlled, but that the thoughtless and irrational extension of a local finding to
global dimensions is inconceivable in persons of sound mind!
"7. Delimit banning.... The banned food additives were either unnecessary or could
be readily substituted with less harmful substances. Not so the totally banned DDTt and
alkyl mercury compounds. First, DDT does not present an 'imminent hazard' to public
health, despite misstatements to the contrary; second, its use for controlling the spread of
malaria and African trypanosomiasis is unexcelled, and equivalent substitutes are not
available at this time."
To these precepts, other cautions should be recorded. It is unfortunate that rarely are
the consequences of decision making so set forth as to make clear, not only monetary
costs and benefits, but the far more subtle resultants. Remote and intangible
consequences are rarely assessed, because these so often lend themselves to exaggeration
both for good and evil results. For example, the purification of water is often in a low
cost category, while the processes for waste treatment of very high efficiency are more
expensive. Choices between them are too often determined by emotion rather than by
reasonably familiar quantitive parameters.
Similarly, threats of economic disaster due to abatement measures and costs are
*H. E. Stokinger. How to Achieve a Realistic Evaluation. Science, 174, 662-665 (November 12,
1971). Jour. American Water Works Association, 64, No. 4 (April 1972).
tThe ban has so far been lifted by the Environmental Protection Agency. (A.W.)