DOCTORS FOR DISASTER PREPAREDNESS NEWSLETTER 

 

November 1992 Vol. IX, No. 6

 

THE HIGH RISK OF ``ZERO-RISK'' POLICY

 

Less can be more in the search for safety.

``Paradoxically, overconcentration on danger has led to neglect of safety: measures to increase safety often end up decreasing it,'' states Aaron Wildavsky in his pathbreaking book Searching for Safety (Transaction Publishers, 1988). In developing a strategy for optimizing safety, Wildavsky notes the serious side effects of social policies that dictate rigid, redundant controls on low-probability sources of risk. One of many such effects is a decrease in available global resources. The result: more preventable deaths, because ``richer is safer'' and ``wealthier is healthier.''

Let's consider a few low-probability risks: Environmental Protection (EPA) regulations governing benzene storage are aimed at workers who face a risk of one in 1.6 million. Occupational Safety and Health Administration (OSHA) rules on formaldehyde are aimed at workers who face a risk of one in 1.5 million. And EPA land-disposal regulations address a safety risk of one in 43 million.

The EPA estimates risks by first extrapolating from rodent tests that administer a chemical in a massive daily dose just short of the amount needed to kill the animals instantly. The next step is to postulate an imaginary ``Most Exposed Individual'' (MEI) who lives on the property line of the emissions source and breathes the highest level of emissions 24 hours a day for 70 years. The EPA assumes that everyone is an MEI.

To put some of these risks in perspective: The risk of getting cancer from breathing formaldehyde in indoor air at work for one day is the same as the risk of cancer from drinking two glasses of beer or two cans of cola.

Even under these pessimistic assumptions, the EPA itself estimates that only 1,700 to 2,700 cancers per year (0.2 to 0.3% of the 855,000 cases diagnosed in 1983) are caused by exposure to air pollutants.

An anonymous EPA executive stated that the most effective way for the EPA to combat cancer would be to give the entire EPA budget to the National Cancer Institute.

Very effective ways to decrease indoor air pollution have been developed by the private sector, because poor air quality causes lost productivity and lawsuits. A steady stream of new products is advertised in magazines such as Indoor Air Review, Pollution Equipment News, Environment, and the Journal of Environmental Health. Two low-technology methods are: (1) to open a window or (2) to grow plants. NASA research on manned space flights led to the idea that plants can remove airborne toxins. Soviet space scientists seek to market this knowledge as a cure for ``sick buildings.'' It has been shown that one or two Boston ferns for every 100 square feet of office area can reduce formaldehyde concentration to an undetectable level. Plants can also remove benzene and trichloroethylene and probably many other pollutants as well. Toxin-eaters include the azalea, poinsettia, dieffenbachia, gerbera daisy, corn plant, pot mum, Chinese evergreen, and various species of philodendron, schefflera, chrysanthemum, tulip orchid, and ligustrum.

The government way to attack pollution is to promulgate regulations. EPA land-disposal regulations cost $3.5 billion for every hypothetical life saved. According to one estimate, the air toxins section of the amended Clean Air Act will cost from $20-$30 billion (about 10 to 15 times the entire budget of the National Cancer Institute) to reduce cancer by a maximum of 350 to 500 cases per year (at a cost of $40-$86 million per cancer avoided). A more realistic estimate is that three to five cancers per year would be averted at a cost of $4-$9 billion each. A 1987 OSHA limit on occupational exposure to formaldehyde imposes a cost of $86 billion per life saved. And a 1990 EPA regulation governing wood preservatives imposes a cost of $5.7 trillion per life saved (implying that the EPA would be willing to spend the entire GNP to avert a single premature death).

These calculations of lives saved, however, do not constitute a net benefit. The cost of compliance with regulations constitutes an enormous, regressive, hidden tax that reduces the disposable income of all. The Heritage Foundation estimated the cost of federal regulations to be between $8,338 and $17,134 per household (compared with an average acknowledged federal tax take of $11,000). These are dollars that cannot be spent for preventive medical care, safer cars, or countless other things that result in improved health and safety. One study concluded that every time society spends from $5-12 million in regulatory costs, a preventable death results from lowering the standard of living.

Based on this analysis, every time the government requires industry to spend more than $12 million to save a life, it kills more people than it saves.

The mortality is probably higher because the regulatory costs are not spread evenly. The burden falls more heavily on lower-income workers, for whom a decrease in income is more likely to result in decreased health and safety. With $10 billion in regulatory costs, a man earning close to the minimum wage would have an increased probability of dying that is 10 times the increase for a man earning $33,000 and 218 the increase for one earning $66,000.

The cost of proposed indoor-air regulations, counted in jobs rather than lives, is estimated to be about one job lost per $110,000 in regulatory costs (or 180,000 jobs lost per $20 billion in regulatory costs). The losses are heaviest in small businesses.

The gross cost of federal regulations in 1990 was approximately $562 billion, double the defense budget. Between January 1990 and January 1992, the private sector lost nearly 1.5 million jobs, not counting those that were simply not created (David Littman, Wall Street Journal 4/21/92). For five successive years since 1986, fewer new businesses were incorporated each year. This is an ominous finding because small businesses are responsible for most new jobs, the Fortune 500 being net job-losers (Theodore Forstmann, Wall Street Journal 3/31/92).

The gain in safety due to regulations should always be weighed against the benefits of alternative uses of the money. For example: A space in an excellent blast shelter still costs around $300, and a year's supply of grain under $200.

 

[REF: Dwight R. Lee, ``The Next Environmental Battleground: Indoor Air,'' National Center for Policy Analysis, 12655 North Central Expy, Suite 720, Dallas, TX 75243, (214-386-6272. NCPA publishes research reports on a variety of economic and regulatory issues.]

ENVIRONOMICS CONFERENCE SCHEDULED

 

The First Annual Conference of ECO (the Environmental Conservation Organization) will be held in Reno, Nevada, February 18-20 at the Reno Hilton Hotel. The theme of the conference will be the balance of environmental and economic interests. Speakers will include Dr. William Hazeltine, Dr. Dixy Lee Ray, and Senator Steve Symms (R-ID). Global warming will be discussed by Dr. Hugh Elsaesser of Lawrence Livermore National Laboratory and Dr. Robert Balling of Arizona State University. Cost to nonmembers of ECO is $100. For further information, contact Donna Ambrose at 708-344-1556, PO Box 9, Maywood, IL 60153.

 

 

Send all correspondence (manuscripts, address changes, letters to editor, meeting notices, etc.) to:

DDP, 1601 N. Tucson Blvd. #9, Tucson, AZ 85716, telephone 520-325-2680.