A shocking look at how chemicals are tested in the US

When we eat, drink and use personal care products, we consume small amounts of pesticides every day. It’s hard—if not impossible—to avoid. The air we breathe at work or at home is full of hazardous air pollutants (HAPs). Fumes from airplanes, trucks, trains and cars, wood-burning fireplaces, industrial pollution from factories and refineries, VOC and solvent emissions from new carpet, paint and many household cleaning fluids all emit toxic odors in varying degrees and quantities. Yes, like it or not, we are all exposed to thousands of dangerous chemicals every day.

We know these pesticides and HAPs are not good for us. Our nose tells us. Our bodies tell us. But eliminating these chemicals is not going to happen any time soon as they are too ubiquitous and too important for our society to function. Food and drug companies, as well as our government, have recklessly disseminated thousands of chemicals without adequate testing on humans.

The Food and Drug Administration (FDA) oversees a large array of products such as food, drugs, and cosmetics (and much more) that affect the health and life of American citizens. According to fda.gov, “Companies and individuals who manufacture or market cosmetics (for example) have a legal responsibility to ensure the safety of their products. Neither the law nor FDA regulations require specific tests to demonstrate the safety of individual products or ingredients. The law also does not require cosmetic companies to share their safety information with the FDA.”

According to the United States President’s Cancer Panel (USPCP), “Some scientists maintain that current toxicity testing and exposure limit-setting methods fail to accurately represent the nature of human exposure to potentially harmful chemicals.” Below are six flaws in current testing methods and some of their unfortunate effects.

According to Andre Leu, President of the International Federation of Organic Agriculture, “ Our current scientific method used in toxicology is highly flawed because it makes this assumption: lower dosage = lower poisonous effect. This linear relationship has become the basis for determining the average daily intake (ADI) of many chemicals. At ultra-low levels of dosage, the chemical is considered too low to cause any health problems.

However, in a 2012 peer reviewed journal Endocrine Reviews, Vandenberg, et. al. showed that there were hundreds of published studies documenting the exact opposite, i.e. that chemicals became MORE toxic at low and often the lowest doses. It further concluded that “Experimental data indicate that endocrine disrupting chemicals and hormones do not have any observable adverse effects or threshold doses, and therefore no dose can ever be considered safe.” That means that the tiniest amounts are harmful whether we see any immediate effect or not or whether they exceed threshold limits set by the government or industry standards.”

Andre Leu explains this counterintuitive concept in his book, The Myths of Safe Pesticides this way: “Many scientists assume a chemical is relatively safe if it’s found in parts per million in the standard toxicology test, but at parts per billion or trillion they can act much like hormones. This is because at very low levels they could attach to hormone receptors, whereas at higher levels of dosage they were ‘ignored’ by the hormone receptors. If and when these chemicals attach themselves to the hormone, they send signals to the endocrine system to act as a hormone, or as an antagonist to the hormone, or block the normal functioning of the hormone and act as an endocrine disruptor.”

"Hormone receptors can be likened to locks in a door of the cell wall and a very small hormone acts like the key. In large doses, the chemical molecule is the wrong size and shape to fit into the lock, but the same chemical in a much smaller molecule can fit right into the receptor and unlock the door sending a false signal to the cell or block normal hormone signals, thereby disrupting the normal functioning of the cell.”

There is a substantial body of published research on endocrine disruption, and the current methods of toxicology testing used to permit chemical residues in our food and water are based on the assumption that all chemicals lose their toxicity as they decrease in quantity. This is clearly not correct for many chemicals.

According to the USPCP, numerous published studies link the endocrine disruption caused by common commercially available chemicals to many of the health problems such as obesity, type 2 diabetes, ADHD, depression, cancers of the sexual tissues and endocrine system, genital-urinary track malformations and lowered fertility rates and sperm counts.

The vast majority of chemicals have simply not been tested for their long-term affects on humans, pets or the environment. Some 800 chemicals are known or suspected to be capable of interfering with hormone receptors, hormone synthesis or hormone conversion. However, only a small fraction have been investigated in tests. Andre Leu says “ Setting low thresholds for chemicals is, therefore, not evidence-based science. It is decision-making based on data-free assumptions.”

According to Dr. Leu, “Part of this is due to how most testing is done on single chemicals in isolation in a lab. The reality of most chemicals is that they are used in combination with other chemicals creating a “chemical cocktail” that makes testing difficult and costly. Regulatory authorities tend to focus on the active ingredient in a cocktail and if it is below the “acceptable daily intake (ADI)” the cocktail as a whole is considered safe. They do not test the combinations of chemicals.”

According to a study by the World Health Organization (WHO) and the United Nations Environmental Program (UNEP), chemical cocktails can act synergistically—meaning that when individual chemicals at low levels combine with others at low levels, their mixture can create much higher levels of chemical toxicity than the two individually. This “additive effect” has been tested extensively and warns that it is scientifically unsound to test just one component of a mixture and assume that the entire combination in the formulation will respond in the same way.

Or, to put it another way, just because one chemical is considered safe (below the acceptable daily intake levels), it does not mean the rest of the cocktail is safe . Sometimes, simply the addition of water, which often contains pesticides, can change the dynamics enough to create an entirely new chemical more toxic than the original chemical!

Most of the insecticides, herbicides, and fungicides used in agriculture as well as adhesives, paints, finishes, and sealers used in building materials are complex formulations of both active and inert ingredients. The active ingredient is the primary chemical that acts as the pesticide or adhesive, while the other, so called “inert” ingredients, help to make it work effectively. Inert chemicals according to the USPCP, are often toxic, however, they are not tested for their potential to cause health problems.

According to the Environmental Protection Agency (EPA), pesticides approved for use contain nearly 900 active ingredients, many of which are toxic. Many of the solvents, fillers, and other chemicals listed as inert ingredients on pesticide labels are also toxic, but they are not required to be tested for their potential to cause chronic diseases such as cancer . Clearly, single chemical testing of active ingredients is not enough and can be misleading.

Another weakness in the standards of testing of chemicals is for “acute toxicity” or the amount that is fatal to animals or humans. The most referenced value is LD50. LD stands for Lethal Dose and 50 means the amount required to kill 50% of the test animals. The lower the number, (e.g. 100mg) the more toxic it is, because it takes less to kill the animal. LD50 testing is widely used as the main reference when judging a substance’s acute toxicity, or the adverse effects resulting from either a single exposure or multiple exposures in a short span of time. Adverse effects must occur within two weeks of the test to be considered acute toxicity. However, according to the USPCP, this measurement does not show the long-term toxic effects of a single chemical or compound .

Asbestos is a prime example of how measuring LD50 can be misleading in regards to a chemical’s toxicity. Asbestos does not have an LD50 because it is not acutely toxic. It is not a poison in the traditional sense. It is “technically possible” to eat asbestos and not be poisoned. However, a small amount of asbestos ingested into the lungs can result in asbestosis, lung cancer or mesothelioma all of which are fatal diseases.

Although there were studies as early as the 1920’s and 30’s linking asbestos to health problems, it was considered safe under the LD50 criteria. The asbestos industry and government regulators denied any dangers for decades. Such irresponsible neglect and misrepresentation resulted in thousands of unnecessary and cruel deaths worldwide with more to come, due to its 20-50 year latency for asbestos-related diseases.

A similar case can be argued for the study of low or no volatile organic compounds (VOCs) such as solvents and formaldehyde in paint and adhesives. Low levels or zero VOCs does not make a product safe, because many products contain numerous toxic chemicals that have been de-regulated.

As a result of OSHA requirements, many manufacturers have reduced or eliminated the amount of VOCs in their ingredients. While this has helped reduce the amount of smog and thereby improved the ozone layer of our atmosphere, manufacturers often substitute exempt VOC chemicals such as acetone or ammonia, both of which are hazardous to humans, to take their place. They are exempt simply because they do not contribute to the production of smog.

Hundreds of exempt VOCs are used throughout the industry and continue to cause complaints of headache, irritability, nausea and other physical symptoms. Our regulating authorities have created a VOC standard that purposefully ignores certain chemicals, and therefore, does not guarantee human safety. More on this in part 2.

Most of the chemical research done on humans does not take into account the special needs of children, the elderly, those with chemical sensitivities or pregnant women. It is well known, that all of the above are highly vulnerable to the slightest amount of chemicals and pesticides. Most of the testing protocols for chemicals, however, are based on mature animals and ignore the specific physiological differences between mature animals and the fetus, newborns, and developing young, including humans.

This is critically important, according to the USPCP, because “approximately 40 chemicals classified by the International Agency for Research on Cancer (IARC) as known, probable, or possible human carcinogens, are used in EPA-registered pesticides now on the market.” What is wrong with this picture?

The USPCP pointed out that these chemical contaminants are being passed on to the next generation, both prenatally and during breastfeeding. Numerous environmental contaminants can cross the placental barrier; to a disturbing extent, babies are born ‘pre-polluted.’ According to a 2009 study by the Environmental Working Group (EWG), up to 232 chemicals were found in the placental cord blood of newborns in the US. Many of these chemicals such as mercury and polychlorinated biphenyls, are known to harm brain development and the nervous system.

The USPCP report further states that “Cancer incidence in U.S. children under 20 years of age has increased…Leukemia rates are consistently elevated among children who grow up on farms, among children whose parents used pesticides in the home or garden…” Again, the assumption that low levels of chemicals will cause no health issues is clearly unfounded. The amount of peer-reviewed published papers showing a wide range of problems caused by pesticides to the fetus and newborn is substantial and compelling.

In sum, the testing methods used by the building industry, the food and drug industry, as well as our government, is shockingly inadequate and needs to change for the safety of us all. Understanding the limitations of these test methods should make you skeptical about any test results that you read in Material Safety Data Sheets, and will hopefully lead you to further discussion and deeper analysis of the real effects of these ingredients.

So, the next time someone tells you “it’s not that bad…a little bit won’t hurt you" —you may want to advise them why that is not a valid assumption.

——————————————————————————————————