Scientific Debate of Climate Change on Social Networking Sites

Climate change, or global warming, is a popular topic of scientific debate on various social networking sites. Proponents on either side studiously present their factual evidence supporting their views and....

...sorry, I can't write that with a straight face. The truth is there is no real scientific debate on the issue of climate change on social networking sites. On the other hand, there is a lot of noise about the issue.

The fact is that after over three decades of research on the issue, thousands of peer-reviewed studies, and many compilations of the state of our knowledge on the topic, a clear scientific consensus has been reached that climate change is occurring and that human activities are playing a significant role in that occurrence. The debate now is on what policies best allow us to deal with the realities of the science.

But that doesn't stop the denialists from continuing to post their obfuscatory message, largely determined by ideology and then rabidly seeking any information they deem to support the conclusion needed to ratify that ideology. While there are probably many typologies of denialists, there are three distinct forms that seem the most vocal.

The cut-and-paster: This particular form of denialist largely relies on opinions copied verbatim out of blogs. They tend to suggest these blogs are "science" despite the fact that blogs are not peer-reviewed. To date, no one has even attempted to offer a convincing argument for why we should simply accept anything written on a blog as science. For why peer-review is irrelevant. For why having to withstand the scrutiny of the entire scientific community isn't important. For why a blogline known for supporting and being supported by purely ideological funders is science, but decades of scientific study and thousands of peer-reviewed publications is "ideological." These cut-and-pasters are relatively innocuous because they clearly don't understand science, but do tend to get annoying when they use every opportunity to insert their pastings into even totally unrelated threads.

The focused irrelevant: The second form of denialist is the kind that latches on to the "Al Gore invented global warming" canard or the "I saw some photographs and now I'm a climate expert" fantasy. Notwithstanding the fact that someone who normally posts non-science (e.g., humor) is an unlikely source for discovering something "that scientists who study climate change somehow missed," the naiveté of the presentation should speak for itself. First, the suggestion that scientists who use the data don't understand the quality of the data is simply silly, as the scientific process verily forces the discussion of every aspect of the related science. All uncertainties are then incorporated into the analysis. And second, focusing on one part of the data input and suggesting that it invalidates the remainder of the data used in the analysis demonstrates a significant lack of understanding of how science works in general and how climate science works specifically. It's like showing photos of a close up of a 2-inch square of plastic that makes up the bumper of a car (without showing the car itself), and saying that a smudge on that 2-inch square allows you to say that the car does not exist. The folks in this type of denialist simply show their lack of understanding by their incessant carping on the one red ball and ignoring all the blue balls as if they aren't there.

The poser: By far the least prevalent, but the most insidious, is the poser. Posers know full well that most people don't understand the science, and so go out of their way to "sound scientific." We are expected to simply ignore the fact that they suddenly have become "climate experts" after only writing fiction in the past (okay, technically they still are writing fiction). We should be taken in by the use of "official looking" but irrelevant (and laughably simplistic) calculations because, well, because they look official. They look scientific. We should assume that because there are some mathematical formulas in the post that anything and everything said must therefore somehow be accurate. The goal is to look technical, and thus by appearing to "talk over the heads" of most non-scientists, presume an air of authority. [What these posers are actually looking for is the smugness they can assume when someone effectively says "Ooh, he used math formulas I don't understand, so he must be smart, so he must be right."] The poser knows that he is posing, but does it anyway, caring little that he misrepresents the science, or that the "technical stuff" presented is largely wrong or irrelevant anyway. For the poser, the same 2-inch square of plastic is used to state definitively what kind of car it is, what year it was produced, how many miles it has traveled, how tall the driver is, and whether the driver had eggs or waffles for breakfast that morning. The problem is, because the calculations are wrong, the 2-inch square of plastic is not even from the bumper of a car, but from some random pile of plastic that is only barely related to the manufacture of a car. So the whole exercise is meaningless anyway.

Luckily, these folks mostly just talk to themselves. There is a tendency for them to gather together to mutually stroke each others egos and pat each other on the back for the supposed wittiness of their deceptions.

The point of this article, of course, is to say that science is not actually "debated" on social networking sites. Scientific debate must, and does, go on constantly in the peer-reviewed literature and at scientific conferences, among real scientists. While there are a good number of actual scientists on social networking sites, mostly they understand that scientific debate goes on elsewhere. In the past, many of these scientists have confronted the few lonely climate change denialist holdovers, pointing out the inconsistencies in their arguments, the lack of veracity of their sources, and the shear silliness of some of the calculations (I mean really, if you can post a calculation in a social networking site article then it clearly is not sufficient to describe the complexities of atmospheric, oceanic, continental, chemical, solar, and man-made influences to climate change). Unfortunately, denialists tend not to learn, and in fact conveniently forget, all of the information presented by real scientists, and thus simply repeat over and over the same points as if no discussion has taken place. Often, when faced with refutation of their posits, they turn abusive (or merely whine). And while scientists are used to arguing over details - after all, that's what we do - we do not suffer gladly those who show a lack of intellectual integrity. After a while scientists simply stop trying to explain to those who actively choose not to learn.

So for the most part scientists ignore the cut-and-pasters, focused irrelevants, and posers (with occasional forays just to get humor from their silliness) and rely on real peer-review with fellow real scientists doing real science in real scientific venues. Of course, we will still post articles related to science for informational purposes, but the actual scientific debate is done elsewhere.

SURPRISE!! - US Government Asks for Public Input on Scientific Integrity

In a surprise move, the US government published in the Thursday, April 23rd Federal Register a "request for public comment" on a scientific integrity memo. This relates to the memorandum issued by President Obama on March 9, 2009, in which he required "the Director of the Office of Science and Technology Policy (OSTP)to craft recommendations for Presidential action to ensure scientific integrity in the executive branch." I discussed the memo in a previous post.

The Federal Register notice "solicits public input to inform the drafting of those recommendations." The notice asks "a series of questions to help guide the public in responding to this request."

As defined in the current Federal Register notice, the six principles of the President's March 3rd memorandum, and on which public comments are solicited are:

(a) The selection and retention of candidates for science and
technology positions in the executive branch should be based on the
candidate's knowledge, credentials, experience, and integrity;

(b) Each agency should have appropriate rules and procedures to
ensure the integrity of the scientific process within the agency;

(c) When scientific or technological information is considered in policy decisions, the information should be subject to well-established scientific processes, including peer review where appropriate, and each agency should appropriately and accurately reflect that information in complying with and applying relevant statutory standards.

(d) Except for information that is properly restricted from disclosure under procedures established in accordance with statute, regulation, Executive Order, or Presidential Memorandum, each agency should make available to the public the scientific or technological findings or conclusions considered or relied on in policy decisions;

(e) Each agency should have in place procedures to identify and
address instances in which the scientific process or the integrity of
scientific and technological information may be compromised; and

(f) Each agency should adopt such additional procedures, including any appropriate whistleblower protections, as are necessary to ensure the integrity of scientific and technological information and processes on which the agency relies in its decision-making or otherwise uses or prepares.

There is a 21 day period for public comment from April 23, 2009 to May 13, 2009.

The fact that this request for public comment relates to a presidential memorandum - which generally are edicts from the President without any public input - is a sign of a greater openness not just in providing the final results but also the underlying research and the process that went into developing the final outcome. It instills a greater degree of public confidence in the scientific process. It also gives all viewpoints - dissenting opinions as well as proponents - a chance to be heard. Which is likely to increase the chances of strong science-based policy decisions being made with less ideological manipulation.

More Chemical Testing from EPA - The 3rd HPV List

Coming soon to a Federal Register near you, the USEPA is expected to publish its third list of high production volume (HPV) chemicals. Technically the "list" is a proposed test rule authorized under Section 4 of the Toxic Substances Control Act (TSCA). Affected industry and other stakeholders will have time to provide comment on the approximately 29 HPV chemicals on the list, after which the EPA will publish a final rule. For the previous two test rules industry was given approximately 24 months to complete the specific health and safety testing identified in the rule.

This test rule is part of the ongoing process stemming from the voluntary HPV Chemical Challenge Program, which was initiated in 1998. Under the program, companies were asked to compile available environmental health and safety data on a list of 2,800 chemicals that were manufactured in or imported into the U.S. in quantities of greater than one million pounds. But several hundred of these were not sponsored by industry and thus were considered "orphan" chemicals. Since then EPA has been slowly reviewing the available data and issuing - now mandatory - requirements for companies to test these chemicals.

The process has been quite lengthy. The first rules was proposed in 2000 and only finalized in 2006. Another proposed rule was published last year and has yet to be finalized. The fact that the process takes so long and handles only small numbers of the thousands of chemicals on the Inventory has been part of the impetus leading some activists to argue for reform of TSCA. In short, the feeling is that there has to be a better way to ensure that chemicals are proven safe being placed, or continuing to be placed, on the market.

Which gets the crux of the problem. While the voluntary HPV program and these testing rules focus on only the highest production volume chemicals - an important prioritization tool but limited in scope - there are approximately 63,000 chemicals that were grandfathered onto the TSCA Inventory without substantive review. Add to that the 30,000 new chemicals added since then in which very limited data were actually provided, thus requiring EPA to assess them largely based on modeling and comparison with chemicals of similar structure.

The ChAMP process is starting to look at medium production volume chemicals, that is, those greater than 25,000 pounds. There is also a desire at EPA to extend ChAMP to looking on inorganic chemicals and to "reset" the TSCA Inventory, though these "enhancements" are currently under review by the new administration. All of this leads into what both advocacy groups and industry agree is a need to revamp the TSCA law. Industry favors something more like ChAMP, while many advocacy groups prefer something more like the Kid Safe Chemical Act that has been introduced in Congress twice before (though was never acted upon even in committee).

Some of the many issues driving TSCA reform include the problem that increased testing (which is needed to prove safety) means increased used of animal models, which animal welfare advocates such as PETA find objectionable. Whether the onus should be put on EPA to review and prioritize chemicals for testing, e.g., via the test rules above, or on industry to do a full suite of base set testing to prove safety is also a subject of heavy debate. As is how much any new law should subsidize "green chemistry" and substitution mechanisms that would either encourage the development of inherently safer chemicals and/or force more hazardous chemicals off the market even though safer substitutes may not be available. Furthermore, should the new law mandate or encourage the development and use of new assessment methods such as in vivo being defined by the National Center for Computational Toxicology’s ToxCast Program. While these tests will eventually lead to less animal testing, they carry a greater degree of uncertainty as to what any observed results might actually mean, as I have noted in a previous post.

So, the end result of TSCA Reform is still too far away to accurately predict. But as I will continue to discuss on these posts, there are several areas of agreement that are beginning to emerge.

TSCA Reform Seems Inevitable - But Which TSCA Reform?

It's a done deal. Okay, not actually a "done deal." But it seems clear that some sort of TSCA reform is on its way. TSCA, of course, is the Toxic Substances Control Act, which has been the authority for chemical control in the US for over 30 years. Not much has changed since it was passed, and not many of the 63,000 chemicals grandfathered onto the TSCA Inventory have had comprehensive data reviews. New chemicals, on the other hand, all have gone through some review by the EPA, but even here there is no requirement to provide health and safety data so most of the analysis is done by computer modeling and comparison to similar chemicals.

As reported here previously, Senator Lautenberg and Representatives Waxman and Solis introduced the Kid Safe Chemical Act back in 2005 and again in 2008. On both occasions it never got out of committee. Senator Lautenberg is adamant that he will reintroduce it this year. But then what?

In a recent hearing both industry and advocacy groups provided their input in to what TSCA reform should look like. Industry, in particular Cal Dooley of the American Chemistry Council, acknowledged that some sort of TSCA reform is necessary. Environmental groups such as the Environmental Defense Fund agreed that a change is needed. But the agreement stops there.

There are two main options on the table, with lots of options in between. One option is to reintroduce the Kid Safe Act, which would be a radical departure from the current TSCA law, and a bit too close to the European REACH program for industry's tastes. Some environmental groups, e.g., the Environmental Working Group, are in favor of the Kid Safe Act approach. Industry favors something that tweaks the current authority incumbent in TSCA but perhaps not assertively used enough in the past by EPA. EPA itself seems to be leaning in favor of TSCA reform that looks much like its current ChAMP program. Industry generally agrees with that idea.

The difference of opinion is largely one of who has the onus. With the current TSCA and ChAMP, the EPA has the onus of determining that a chemical is not safe, something that has been hard to do given the lack of data available for most chemicals. With the Kid Safe Act and other REACH-like options, the burden shifts almost entirely to industry to prove their chemicals are safe enough to remain (if already existing) or be put (if new) on the market. There are advantages and disadvantages of each approach, which I will examine in coming posts.

USEPA Seeking Scientific Information on CO2-caused Ocean Acidification

Think global warming affects only the air temperature? Think again. The oceans matter also when it comes to climate change. Carbon dioxide (CO2) could lead to big changes in the ocean, and most of it would not be good. According to the Center For Biological Diversity (CBD) in a petition filed last year, new science shows that increasing levels of CO2 in the atmosphere are acidifying ocean waters. The result is impairment in the ability of coral and other marine invertebrates to build and maintain exoskeletons (the hard parts on the outside that keep them together).

To evaluate the petition, EPA is seeking scientific and policy information on ocean acidification caused by CO2. They need this information to help them decide whether to revise their current pH water criterion, a move which could lay the groundwork for regulating greenhouse gases through the Clean Water Act. EPA published a notice of data availability in an April 15 Federal Register notice, and asked for commenters to provide existing information about ocean acidification as well as new scientific data and policy suggestions for addressing acidification. The goal is to use the information to decide whether to grant the CBD petition, which asked the agency to revise its national marine criterion for pH to protect marine life.

Because of the interconnectedness of the issue, EPA is soliciting information on technological advances in rapid, continuous, or remote monitoring of pH; long term data that demonstrate acidification; and methods to evaluate pH variability. They are also seeking estimates for survival rates for coral and non-coral organisms, as well as any methods for weighing the impact of acidification in comparison to other stressors, such as storm damage and overfishing. Finally, the EPA would like individual states to offer their experience on implementing the current pH standard and for experts to suggest scientifically defensible approaches to set and monitor pH criteria.

The ramifications of this decision are potentially expansive. EPA's decision on the pH criteria could set an ecological goal for future CO2 limits. The resultant criteria are non-binding, but they inform state water standards, and that could in turn require the setting of emission limits at the state level to achieve the standards. This action is a part of a myriad of actions the EPA is contemplating in an effort to address climate change through regulations. Other actions include the reconsideration of the previous administration's denial of California's request to regulate CO2 from vehicles, reevaluation of a Bush EPA memo barring regulation of CO2 in power plant permits, and the preparation of a climate change endangerment finding that could set the stage for regulations across many programs and agencies. As I have mentioned in the past, the Obama administration is taking climate change issues very seriously and has filled many of his key environmental and energy positions with personnel experienced and active in those areas.

"Architect of the REACH Regulation" Calls for UN Panel on Chemicals

Margot Wallström is European Commission vice-president and the force behind the development and passage of the European Union's Registration, Evaluation and Authorization of Chemicals (REACH) regulation.

She is also now a conference room.

Okay, technically she isn't herself a conference room. But one of the two conference rooms in the new European Chemicals Agency (ECHA) conference center inaugurated April 3rd is named after her (the second is named after Guido Sacconi, the European Parliament's rapporteur for REACH). The new conference center, located at ECHA headquarters in Helsinki, Finland, is one of the most modern facilities available, including computer panels and microphones for each of the 200 seats.

In her invited remarks at the inauguration Ms. Wallström called for a new high level UN panel that would "tackle the risks from chemicals in the same way that the Intergovermental Panel on Climate Change (IPCC) is doing for climate change." The new UN panel would consist of a team of independent researchers. While she didn't provide further details at the ECHA event, you can read more about it here (assuming you can read Swedish).

Mr. Sacconi, while not present at the ECHA unveiling, recently made the news as he, in conjunction with Europe's largest trade union, published a list of 306 chemicals that they consider to be of very high concern.

Ms. Wallström isn't the only one calling for more chemical control. Dr Thomas Jakl, Chairman of ECHA’s Management Board, in response to a question from the students about the role of consumers, implored them to "be active, seek out information on chemicals...ask manufacturers what is in the products that you buy. Man made chemicals are in the blood of every single one of us – they should be a matter of concern for us all.”

Cleaning Products Coming Clean - What Really Is In Windex?

Sure, we all know what is in Windex. Right? Isopropanol, 2-Butoxyethanol, Ethylene glycol n-hexyl ether, Water, and Ammonia. Well, now you can go to a new web site set up by S.C. Johnson & Son Inc. called www.WhatsInsideSCJohnson.com to describe most of the ingredients for its Windex cleaner, as well as for its Glade, and Shout brands.

The company is part of a recent trend. Other manufacturers of household cleaning products have begun disclosing the chemicals in some of their products. For example, Clorox Co. lists ingredients for its Formula 409 and other products at TheCloroxCompany.com. Seventh Generation Inc., which has long disclosed most of the ingredients for its eco-friendly cleaning products, last year started explaining chemical names in terms that consumers can better understand on its labels. And Procter & Gamble Co. plans to list its ingredients online and describe them in consumer friendly terms.

S.C. Johnson announced in March that they would disclose the ingredients in all of its home cleaning and air cleaning products. If you go to the S.C. Johnson site, for example, you can see the breakdown of its Windex Outdoor Multisurface Cleaner in terms of what each chemical does. Mostly it is Water, of course, but also listed are: 2-(8-Methylnonoxy) Ethanol (Cleaning Agent), Sodium Xylene Sulfonate (Wetting Agent), Sodium Citrate (Stabilizer), and Sodium Carbonate (pH Balancer). The plan to disclose ingredients includes products with fragrances, which generally have been closely guarded trade secrets. Other companies are less sure about doing this, because it is confidential business information; they would prefer a general category called "fragrances, dyes and preservatives." But S.C. Johnson says they prefer the "palate approach" that would give consumers all the information they need to make choices.

The move is not purely altruistic. Consumers have been asking for more information on ingredients in terms they can understand. So in a sense, companies are responding to market pressures. But they are also responding to pressure from advocacy groups who are pressing for greater disclosure. Environmental Working Group, for example, has been visibly campaigning against the use of phthalates in products, and this disclosure will make their use more obvious (and thus likely increase demand for their removal). While both FDA and European regulators have approved the use of phthalates and the industry says they are safe, personal care products are being forced by public insecurity to reformulate their products. Other groups are also pressuring industry to list all their ingredients. A lawsuit filed in February by EarthJustice on behalf of several environmental groups seeks to force Procter & Gamble, Colgate-Palmolive, Reckitt-Benckiser (makers of Woolite), and Church and Dwight (makers of Arm and Hammer products) to list all of their ingredients.

All of this ties in with other programs that seek greater disclosure of ingredients and their health and safety, such as REACH in the EU and TSCA reform in the US and worldwide Ecolabelling efforts. California's development of a new "Green Initiative" will also exert pressure to both disclose their ingredients and show that they are safe. Those companies that lead the way will likely gain market share as consumers more and more focus on products they feel are more sustainable.

These efforts are receiving a boost from industry trade groups that recently set up joint guidelines to encourage use of a standardized format for presenting the technical information. "Consumers want to know more to ensure the safety of their family," says a Procter & Gamble spokesman. "The industry is changing along with that."

Chemical Control Reform - Kids Safe Out...ChAMP In?

As discussed here previously, the US is taking a hard look at its 30+ year old chemical control law, the Toxic Substances Control Act (TSCA). Many argue that the law is outdated, both because it doesn't require health and safety data for new chemical notifications and because the bar for regulating existing chemicals seems too high a hurdle. Around 63,000 existing chemicals were grandfathered onto the TSCA Inventory with no health and safety review, and only a handful have seen such reviews since.

Options abound. Should the US pursue a system more like the new chemical control law in Europe, called REACH, which requires that manufacturers and importers of all chemicals - existing and new - provide a dossier summarizing health and safety for all intended uses? Or something more like the Canadian prioritization review and management program in which the government does the hard work of the initial screen for all existing chemicals? Or something like the Kid Safe Chemical Act that has twice been introduced by the US Congress before?

This week at the annual GlobalChem chemical industry conference being held in Baltimore, MD, Jim Jones, EPA's acting toxics and pesticides chief, told attendees at the GlobalChem chemical industry conference in Baltimore, that at the office's first meeting with new EPA Administrator Lisa Jackson, she told staff that “‘ChAMP is fine, but I want to see more, more quickly.’”

ChAMP is the current semi-authorized by TSCA mechanism that EPA has been using to maximize the value of the reams of data received under the voluntary HPV Challenge program between 1998 and 2008. But ChAMP goes further, with proposed enhancements that would "reset" the TSCA Inventory, look at moderate volume chemicals, and inorganic high production volume chemicals that were excluded from the original HPA Challenge.

Jones' comments signal that EPA may be leaning toward TSCA Reform that mirrors more the ChAMP program than the Kid Safe Act. Environmental and health advocacy groups have favored the Kid Safe Act because it puts the onus on producing data on the manufacturers of chemicals, similar to REACH in the EU. Industry favors something more like ChAMP, which initially would require more Agency effort during the screening process, but may provide for a quicker review and prioritization. Once chemicals are prioritized for more in-depth review, industry would provide specific data focused on addressing any real or perceived concerns.

Jackson has hinted on more than one occasion since taking office that she favors the current chemical management system as a basis for reforming the program. The ChAMP program was initiated following former President Bush's commitment to complete the characterizations of Inventory chemicals by 2012 as part of the 2007 Security and Prosperity Partnership agreement with Mexican and Canadian officials.

Officially though, the administration has not yet taken a position on TSCA reform, but Jones suggests that "the administrator is “very interested” in the issue and has discussed the issue “with her small political team several times.” Meanwhile, EPA will continue to use its existing TSCA authorities to regulate substances that are of concern. While Congress is mulling the future of TSCA, EPA has been more assertive in using such TSCA authorized tools as test rules and enforcement actions. It also has been very busy reviewing the data received from the HPV Challenge and issuing hazard and risk prioritizations.

Ten Replies...Advocacy vs Science (From Helicity)

I came across a very interesting blog called Helicity that was replying to the replies of a climate change skeptic (to his earlier post). I thought many of his responses were both patient and insightful, and it's a topic I have covered myself. For those (like me) who aren't familiar with it, helicity is a meteorological term that, "in the most general sense, illustrates to what extent a fluid flows in a corkscrew manner. It’s used in forecasting the likelihood of tornadic development through the Storm Relative Helicity scale (SRH)." The blog's author, "Daniel ‘counters’ Rothenberg, a student of Atmospheric Science at Cornell University," uses helicity as a metaphor for the wild spinning of academic and everyday life.

It's a long post, and I highly recommend you read it. I hope Daniel won't mind that I've included a couple of excerpts here that I found interesting.

Regarding consensus:

"What does “consensus” mean? It means that the people that actually do climate science generally reach the same conclusions and interpretations of the data they work with. In climate science, there is a strong consensus that AGW is the best interpretation of the pertinent data. What this response fails to hit almost entirely is that it’s not the consenus that matters; it’s how that consensus came to be. In the case of climate science, AGW continues to be supported by new lines of evidence. It allows us to answer questions, but also to ask more questions. The important thing is that ain’t nobody done gone and knocked AGW’s knee-caps out! There is a consensus precisely because not only is AGW the most robust explanation of the data out there, but no one has come and falsified it yet."

Regarding peer-review (or lack of it):

"You know, when a skeptics scientific thesis can thoroughly be debunked and refuted in a short, few-paragraph blog post, is it any wonder that it can’t pass the muster of peer-review? Peer-review is far from a perfect, flawless process, and it certanly can insulate the scientific establishment from major changes - even changes which prove to be necessary. But the issue isn’t politics in the peer-review process; it’s flawed science wasting peer-reviewers time."

Regarding refuting data:

"If someone has a serious issue with the latest Mann paper (or any paper in the climate science literature), then it’s about time that they draft a formal refutation and publish it. I can guarantee that if the refutation is legitimate, it won’t have any problem making it into a respected journal. If skeptics are really sitting on AGW-shattering calculations and have better theories formulated, then they need to start publishing them. The problem is that they don’t."

As I said, these are only excerpts from the Helicity post. I recommend reading it in its entirety.

[And for those who are easily confused...this is a blog, so it isn't science, merely an opinion about science.]

European Trade Union Lists 306 "Substances of Very High Concern" - Will this Blacklist Safe Chemicals?

The European Trade Union Confederation (ETUC), based in Brussels, published a "Trade Union Priority List for Reach Authorisation," featuring a list of 306 chemicals that ETUC says “are of very high concern.” ETUC is calling on European Union (EU) member states to include the list of 306 chemicals on the candidate list of substances for authorization under the EU’s Registration, Evaluation, and Authorisation of Chemicals (REACH) program.

As I have noted previously, REACH is the new chemical control law in Europe and it requires all manufacturers and importers of chemicals to "register" them within a specific time frame if they want to continue using chemicals that have already been on the market. New chemicals must be registered before going on the market, with registration requiring a substantial dossier compiling all of the health and safety data, as well as exposure scenarios for every intended use of the chemical.

In addition to the registration (the "R" in REACH), there is a requirement for certain "substances of very high concern" (SVHC) to receive authorization for continued use (the "A" in REACH). Authorization requires the manufacture to submit an application that includes all of the usual health and safety data in a dossier, and also a plan for its substitution by substances of lesser concern. Authorization is for a limited time and for specific uses only, and only to allow development of alternatives.

Last fall the European Chemicals Agency (ECHA) issued the first of what will be regular lists of "candidate" chemicals, i.e., those substances for which Authorization will be necessary of the manufacturers or importers want to keep the sustance on the market for a while longer (otherwise, they will simply be banned). The first candidate list contained 16 chemicals.

While only ECHA is responsible for issuing the candidate list, other organizations have jumped on the "list" bandwagon in an effort to suggest chemicals they think ECHA should nominate for Authorization. ETUC is particularly concerned about 191 chemicals identified as causing occupational diseases (e.g., acrylamide, bisphenol A, and formaldehyde). Last year a group of European environmental organizations under the collaboration name ChemSoc issued a SIN List (Substitute It Now) of substances they felt were of high concern. In addition, individual Member States of the European Union can suggest chemicals of particular interest to them.

As noted, only ECHA can issue the candidate lists, but with ETUC, ChemSoc and surely others issuing their own lists there is a definite potential for blacklisting. Even the candidate list itself doesn't say the chemicals listed need to be banned or severely restricted, only that they are in need of a much closer look. Some of the candidate list chemicals will eventually be removed as new information is made available by the manufacturers. But having a list of chemicals that someone arbitrarily says are of "very high concern" can be very damaging to busy as downstream users are hesitant to use chemicals that are being targeted. Compare the several hundreds of chemicals on ETOC's list (306) and the SIN list (200) versus only 16 on the first ECHA candidate list and you can see the potential for blacklisting even before there is any formal evaluation of the data.

ETUC says its goal is to contribute to the practical implementation of the authorization phase of REACH. ETUC says it endorses an approach where risks of certain chemicals are controlled and the most hazardous chemicals are replaced with safer alternatives. While all of the chemicals listed by ETUC supposedly meet the REACH criteria for classification as ‘substances of very high concern,’ (i.e., persistent, bioaccumulative, toxic or carcinogenic, mutagenic, or reproductive toxicants), the ETUC list goes further as it "ranks chemicals by reference to their intrinsic toxicological properties and identifies those that cause occupational diseases which are recognised at EU level.”

We'll see how these independent lists affect the market, which could very well substitute away from chemicals that can be safely used and toward chemicals that may actually have a greater impact on human health and the environment.

New NOAA Administrator Jane Lubchenco Says Science is Her Top Priority

Dr. Jane Lubchenco took over the National Oceanographic and Atmospheric Administration (NOAA) on March 22, 2009. A day later she did a joint interview with writers from two of the most prestigious science news journals - Science and Nature. When asked what her top priorities were as she took over the agency, she responded "Clearly, science is a priority for me."

Expanding on that idea, Dr. Lubchenco said:

It's my belief that a resilient society and economy depend on informed decisions regarding environmental challenges and resource-management issues. The role of science is to provide the knowledge to do that informing. Those decisions might be made by individuals or governments or by companies; I believe those decisions will be better if they are informed by science. I use "informed" judiciously because I don't think the science should dictate any particular outcome. Decisions are going to take into account a number of different things — values, politics, economics — but science should be at the table in a way that is understandable and relevant and credible and salient. NOAA, as an applied-science agency, has the responsibility to develop and communicate and use science to make policy and management decisions, but also to inform policy and management decisions that are made by others.

When asked whether there was "a big problem in terms of scientists being muzzled in the last administration," she said that it's probably hard to know for sure, but that "as we move forward science will be respected; it will not be muzzled. It will not be distorted. And scientists will be free to share their scientific findings whether they fit any preconceived policy or not." She also indicated that she and John Holdren, the new presidential science adviser and director of the Office of Science and Technology Policy, would be reviewing all policies and practices to ensure scientific integrity.

Lubchenco also said that one thing she would like to do is "establish a National Climate Service in partnership with other agencies."

The full interview can be read in Nature magazine.

USEPA Offers "Strategic Plan" for Evaluating the Toxicity of Chemicals

This week the USEPA released a "Strategic Plan for Evaluating the Toxicity of Chemicals," which departs from "the traditional risk assessment approach that relies heavily on data generated through the intentional dosing of experimental animals." As most people know, animal welfare issues have led to a desire to find non-animal testing methods. At the same time there is pressure to provide data that adequately characterizes the hazards and risks of industrial and consumer chemicals.

According to EPA, while the traditional approach

"has provided EPA with sound science to support regulatory decision making over the past several decades, EPA must address ever-increasing demands, including consideration of complex issues such as cumulative exposures, life-stage vulnerabilities, and genetic susceptibilities, not to mention the increasing number of chemicals and cost of toxicity testing. A new approach is proposed to address these demands, an approach based on the application of advances in molecular biology and computational sciences to transform toxicity testing and risk assessment practices."

Based on a 2007 report by the National Research Council (NRC) of the National Academies, "Toxicity Testing in the 21st Century: a Vision and a Strategy," an Agency workgroup coordinated to produce the new Strategic Plan that "focuses on identifying and evaluating "toxicity pathways," i.e., cellular response pathways responsible for adverse health effects when sufficiently perturbed by environmental agents under realistic exposure conditions."

While EPA expects that the new paradigm will "create more efficient and cost-effective means to screen and prioritize for further assessment the tens of thousands of chemicals that are already found in the environment," there is some question as to whether that expectation is realistic. For example, I see four major challenges.

1) Developing and validating the methodologies: Development of new methods generally takes many iterations to determine the conditions that provide the most information with reliability and repeatability. Thus, it will likely be quite a few years before the methods being developed can be used for decision-making. Can we wait that long?

2) Translating expressions of exposure at the gene, protein, molecular, and cellular levels to the target organ and organism level: Whereas a standard animal study provides easily interpretable and accepted measures of toxicity (e.g., death, loss of body weight, reduced reproduction), the new methods provide much more nuanced results whose toxicological significance may be very difficult to establish. These subtle responses may simply be adaptive rather than result in diminished capacity.

3) Communicating why this is better than the current QSAR-based screening methods: The new methods will serve only as screening tools for prioritizing chemicals for further review. Ultimately the final risk management decision-making may still be based on the established standard testing methods. EPA will need to explain why these new screening level methods are better than the current US approach to screening chemicals. This may be especially difficult given that a Canadian prioritization program reviewed the 23,000 chemicals on its existing chemicals inventory based largely on existing study data and QSAR analysis.

4) Funding: The 2007 NRC report “Toxicity Testing in the 21st Century” suggested that transitioning into this new computational, informational, and molecular-based strategy would require $100M in funding every year for a period of 10-20 years. Given the current economic situation and competing issues such as climate change, TSCA reform, green chemistry, endocrine disruption, and others, it is hard to imagine that adequate funding can be made available for this endeavor.

Scientists as political activists?

I mentioned previously the climate change conference held in Copenhagen, which was designed to stimulate some activism on the part of scientists in preparation for December's much anticipated international climate change conference. Despite this goal, however, one point made repeatedly was that "formulating an action plan to curb climate change is not the job of scientists."

Herein lies a dilemma (wrapped inside a conundrum, or is it the other way around).

Scientists traditionally prefer to do the science and leave the policy development to others. For one thing, public policy must consider many more things than just the science. There are sociological, economic, political, and pragmatic considerations. But at the same time politicians are asking scientists, for example climate change scientists, what action they should take to address the problem. Unfortunately, while they can predict what may happen, it's even more difficult to provide guidance on what to do about it. This is true for a couple of reasons.

First, models can never provide a perfect prediction of how and where the climate will change. One participant in Copenhagen noted: "Tell me what the stock market will do in 100 years and I will tell you what the climate will do." Second, most climate scientists will tell you that their role does not include policy formulation. They can provide scenarios of what will happen if emissions hit certain thresholds, but when politicians ask what is the absolute maximum amount of CO2 we should allow, there is no easy answer. In the end, it depends on how much risk we are willing to take. That, and how good we are at predicting tipping points.

So the organizers of the Copenhagen conference hoped that they can encourage scientists to take a more active role and speak not as scientists but as concerned citizens. Some may feel uncomfortable with "blurring the line between science and activism," but they also know that no one understands the risks better than they do and no one is better placed to give informed opinions.

One positive note from the current Obama administration is that he has placed scientists in key appointee positions, jobs that too often in the past have gone to political friends whether they know anything about science or not. These scientists as risk managers are "people who are willing and able to weigh up the risks, costs and benefits of various degrees of action."

Global Warming Denialists Turning on Themselves as Their Climate Change Titanic Sinks

I did a post a while back about a "Climate Skeptics Conference" held in New York City. According to Andrew Revkin, writing in the Scotland in Sunday newspaper, it may just have been a last hurrah for the global warming denialist industry.

Case against climate change melting away

For example, from the linked article:

"But large corporations such as Exxon Mobil, which in the past financed the Heartland Institute and other groups that challenged the climate consensus, have reduced support. Many such companies no longer dispute that the greenhouse gases produced by burning fossil fuels pose risks.

From 1998 to 2006, Exxon Mobil, for example, contributed more than $600,000 (£414,000) to Heartland, according to annual reports of charitable contributions from the company and company foundations.

Alan Jeffers, a spokesman for Exxon Mobil, said by e-mail that the company had ended support "to several public policy research groups whose position on climate change could divert attention from the important discussion about how the world will secure the energy required for economic growth in an environmentally responsible manner"."

And:

"But Kert Davies, a climate campaigner for Greenpeace, said that the experts giving talks were "a shrinking collection of extremists" and that they were "left talking to themselves"."

And this long piece from the article above:

"But Lindzen also criticised widely publicised assertions by other sceptics that variations in the sun were driving temperature changes in recent decades. To attribute short-term variation in temperatures to a single cause, whether human-generated gases or something else, was erroneous, he said.

Speaking of the sun's slight variability, he said: "Acting as though this is the alternative (to blaming greenhouse gases] is asking for trouble."

S Fred Singer, a physicist often referred to by critics and supporters alike as the dean of climate contrarians, said: "As a physicist, I am concerned that some sceptics, a very few, are ignoring the physical basis.

"There is one who denies that CO2 is a greenhouse gas, which goes against actual data," Singer said, adding that other sceptics wrongly contend that "humans are not responsible for the measured increase in atmospheric CO2."

There were notable absences from the conference this year. Russell Seitz, a physicist from Cambridge, Massachusetts, delivered a speech at last year's meeting. But Seitz, who has lambasted environmental campaigners for distorting climate science, now warns that the sceptics are in danger of doing the same thing.

The most strident advocates on either side of the global warming debate, he said, are "equally oblivious to the data they seek to discount or dramatise".

John Christy, an atmospheric scientist at the University of Alabama who has long publicly questioned projections of dangerous global warming, most recently at a House committee hearing last month, said he had skipped both Heartland conferences to avoid the potential for "guilt by association"."

As we have seen, many of the global warming denialists have been pushing the very "party line" that their lauded "shills and charlatans" (plus, of course, the real scientists with real concerns) are now criticizing as very misguided ideologically based opinions.

Keep in mind, this was at the "Skeptics Conference" and these are the words of the "skeptics" themselves. Apparently skeptics are beginning their "every man for himself" race to the lifeboats as their Titanic sinks (perhaps after hitting a melting iceberg).