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COMMENT BY:
James D. Wilson, Senior Fellow
Once upon a time this periodic Report on Carcinogens played a useful role in educating the public. That time is now past. We know, now, that the capacity to induce tumors in a test animal or in humans is not an intrinsic property of any substance. Starting a cancer requires the confluence of several factors, including the ability of the animal to repair injuries to its genetic material. The most one can say, qualitatively, is that some chemicals are more likely than others to induce cancer, given exposure, everything else being equal. The Report does identify many of the substances that fall into the "more likely" category, but by no means all. It also includes many that would not usually be placed in this category by cancer biologists, because they aren't very potent. But they happen to have been tested at some juncture, for some reason. We also know now that effective management of risks from exposure to chemicals that might "cause cancer" requires a robust quantitative component. We need to know just how potent different substances really are, and to be able to compare those potencies with how much we are likely to ingest, inhale, consume, or otherwise absorb. The Report says nothing about the quantitative aspects of exposure to the substances chosen for "listing." Thus it is not of terribly much value to the public. It might be suggested that NTP add quantitative information to the Report. Yet that raises the specter of duplicating existing efforts. The job of ascertaining potencies and exposures is one that the regulatory agencies -- FDA, EPA, OSHA, MSHA, etc. -- claim as their own responsibility. They are correct to do so. They are, by now, fully aware of the potential some substances have for inducing cancer, and can obtain the information needed to estimate exposure within their various spheres of activity. NTP cannot easily do this. Thus it seems to me that, in the spirit of improving the performance of government, Secretary Shalala should ask Congress to relieve her Department of the burden of updating this now-obsolete Report. Please note that this opinion is mine alone, and should not be taken to represent a position of Resources for the Future. Resources for the Future is a not-for-profit policy research institution devoted to informing policy deliberations related to issues of natural resources and the environment; it does not take positions on individual policy decisions.
James D. Wilson, Sr. Fellow |
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