Wednesday, August 24, 2005

The petition from hell

I should have known better. After all, I lived through the McCarthy years and the Reagan years. But I guess it's huiman nature to think things can't get any worse. Today, the right wing whores at the American Council on Science and Health (ACSH) filed a petition with the EPA to "eliminate 'junk science' from the process by which it determines whether a substance is likely to cause cancer in humans." (if you have a strong stomach, you can read this 1984ish statement on their press release)

The "junk science" they are referring to is the long-standing and well-confirmed practice of identifying chemicals likely to cause cancer in humans by testing them in animals. The animals (rodents) are a standard model for biological processes of relevance to humans (which is why drug companies and medical researchers have been using them for a century). They are well understood and are the only sentinels for detecting carcinogenicity of any use to public health. Since chemically induced cancer has a latency period of decades (typically 20 years or more), waiting for it to appear in human populations would meant that once detected, even if exposure would cease instantly (which can never happen), it would take another 20 or more years to eliminate the cancers from exposure (all the cancers induced in the 20 years exposure prior to detection). But even then, the chances of detecting any but the most powerful carcinogens in human populations (via epidemiology) is small. Epidemiology is a very insensitive tool. I say this with some authority, as I am a cancer epidemiologist specializing in chemical exposures and have authored numerous peer reviewed studies in that area over many years.

The main rhetorical lever ACSH employs is the use of high doses in the animal studies, doses that are much higher than usually faced by humans. But as ACSH knows well (but didn't divulge) there is a technical requirement for using these doses. If one were to use doses in animals predicted to cause cancer at a rate we would consider a public health hazard, we would need tens of thousands of animals to test a single dose, mode of exposure and rodent species or strain. This makes using those doses infeasible. Thus a Maximum Tolerated Dose is used, one that causes no other pathology except possibly cancer and doesn't result in more than a 10% weight loss. The assumption here is that something that causes cancer at high doses in these animals will also do so at low doses. This is biologically reasonable. It is a (surprising) fact, that most chemicals, given in no matter how high a dose, won't cause the very unusual and specific biological effect of turning an animal cell cancerous. Cancer cells are not "damaged" cells in the individual sense but "super cells," capable of out competing normal cells. It is only in the context of the whole organism that there is a problem. It is not surprising, then, that very few chemicals would have be ability to turn a normal cell into a biological super cell of this type. Estimates are that is far less than 10%, perhaps only 1% of all chemicals that have this ability. Thus western industrial civilization doesn't have to come to a screeching halt if we eliminate industrial chemical carcinogens from our environment.

We know of no false negatives with this process. Every chemical we know that causes cancer in humans also does so in rodents (with the possible exception of inorganic trivalent arsenic, which is equivocal). The reverse question, whether everything that causes cancer in animals also is a human carcinogen, is not testable without doing the actual natural experimen: waiting to see if people get cancer on exposure, an experiment ACSH is only too happy to conduct on the American people to make their corporate sponsors happy.

If ACSH executives want to be exposed to chemicals that cause cancer in animals that biologically are very similar to humans, that's their choice. But I don't want them to make it for me. This ACSH petition is so outlandish and outrageous one wouldn't think it would have a chance of passing scientific muster. But science means nothing to the Bush Administration.

And I thought things couldn't get any worse!