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Full text of "Scientific integrity and public trust : the science behind federal policies and mandates : case study 1, stratospheric ozone, myths and realities : hearing before the Subcommittee on Energy and Environment of the Committee on Science, U.S. House of Representatives, One Hundred Fourth Congress, first session, September 20, 1995"

SCIENTinC INTEGRITY AND PUBUC TRUST: THE SCIENCE B& 
HIND FEDERAL POUCIES AND MANDATES: CASE STUDY 1- 
STRATOSPHERIC OZONE: MYTHS AND REALITIES 



Y 4. SCI 2:104/31 

Scientific Integrity and Public Tro... 

ANG 

BEFORE THE 

SUBCOMMITTEE ON 
ENERGY AND ENVIRONMENT 

OF THE 

COMMITTEE ON SCIENCE 
U.S. HOUSE OP REPRESENTATIVES 

ONE HUNDRED FOURTH CONGRESS 

FIRST SESSION 



SEPTEMBER 20, 1995 



[No. 31] 



Printed for the use of the Committee on Science 




SCIENTinC INTEGRTTY AND PUBUC TRUST: THE SCIENCE 
BEHIND FEDERAL POUCIES AND MANDATES: CASE STUDY 
1-STRATOSPHERlC OZONE: MYTHS AND REALITIES 



HEARING 

BEFORE THE 

SUBCOMMITTEE OX 
ENERGY AND EMIROXMEXT 

OF THE 

COMMITTEE ON SCIENCE 
U.S. HOUSE OF REPRESENTATIVES 

ONE HUNDRED FOURTH CONGRESS 
FIRST SESSION 



SEPTEMBER 20, 1995 



[No. 31] 



Printed for the use of the Committee on Science 




U.S. GOVERNMENT PRINTING OFFICE 
20-413 WASHINGTON : 1996 

For sale by the U.S. Government Printing Office 

Superintendent of Documents, Congressional Sales Office, Washington, DC 20402 

ISBN 0-16-052519-5 



COMMITTEE ON SCIENCE 



ROBERT S. WALKER, Pennsylvania, Chairman 



F. JAMES SENSENBRENNER, Jr., 

Wisconsin 
SHERWOOD L. BOEHLERT, New York 
HARRIS W. FA WELL, Illinois 
CONSTANCE A. MORELLA, Maryland 
CURT WELDON, Pennsylvania 
DANA ROHRABACHER, California 
STEVEN H. SCHIFF, New Mexico 
JOE BARTON, Texas 
KEN CALVERT, California 
BILL BAKER, California 
ROSCOE G. BARTLETT, Maryland 
VERNON J. EHLERS, Michigan 2 
ZACH WAMP, Tennessee 
DAVE WELDON, Florida 
LINDSEY O. GRAHAM, South Carolina 
MATT SALMON, Arizona 
THOMAS M. DAVIS, Virginia 
STEVE STOCKMAN, Texas 
GIL GUTKNECHT, Minnesota 
ANDREA H. SEASTRAND, California 
TODD TIAHRT, Kansas 
STEVE LARGENT, Oklahoma 
VAN HILLEARY, Tennessee 
BARBARA CUBIN, Wyoming 
MARK FOLEY, Florida 
SUE MYRICK, North Carolina 

David D. Clement, Chief of Staff and Chief Counsel 

Barry Beringer, General Counsel 

TiSH Schwartz, Chief Clerk and Administrator 

Robert E. Palmer, Democratic Staff Director 



GEORGE E. BROWN, Jr., California RMM i 

RALPH M. HALL, Texas 

JAMES A. TRAFICANT, Jr., Ohio 

JAMES A. HAYES, Louisiana 

JOHN S. TANNER, Tennessee 

PETE GEREN, Texas 

TIM ROEMER, Indiana 

ROBERT E. (Bud) CRAMER, Jr., Alabama 

JAMES A. BARCIA, Michigan 

PAUL McHALE, Pennsylvania 

JANE HARMAN, California 

EDDIE BERNICE JOHNSON, Texas 

DAVID MINGE, Minnesota 

JOHN W. OLVER, Massachusetts 

ALCEE L. HASTINGS, Florida 

LYNN N. RIVERS, Michigan 

KAREN McCarthy, Missouri 

MIKE WARD, Kentucky 

ZOE LOFGREN, California 

LLOYD DOGGETT, Texas 

MICHAEL F. DOYLE, Pennsylvania 

SHEILA JACKSON-LEE, Texas 

WILLIAM P. LUTHER, Minnesota 



Subcommittee on Energy and Environment 

DANA ROHRABACHER, CaUfornia, Chairman 



HARRIS W. FAWELL, Illinois 

CURT WELDON, Pennsylvania 

ROSCOE G. BARTLETT, Maryland 

ZACH WAMP, Tennessee 

LINDSEY O. GRAHAM, South Carolina 

MATT SALMON, Arizona 

THOMAS M. DAVIS, Virginia 

STEVE LARGENT, Oklahoma 

BARBARA CUBIN, Wyoming 

MARK FOLEY, Florida 

STEVEN H. SCHIFF, New Mexico 

BILL BAKER, California 

VERNON J. EHLERS, Michigan 

STEVE STOCKMAN, Texas 

ROBERT S. WALKER, (PA) (ex-officio) 



JAMES A. HAYES, Louisiana 

DAVID MINGE, Minnesota 

JOHN W. OLVER, Massachusetts 

MIKE WARD, Kentucky 

MICHAEL F. DOYLE, Pennsylvania 

TIM ROEMER, Indiana 

ROBERT E. (Bud) CRAMER, Jr., Alabama 

JAMES A. BARCU, Michigan 

PAUL McHALE, Pennsylvania 

EDDIE BERNICE JOHNSON, Texas 

LYNN N. RIVERS, Michigan 

KAREN McCarthy, Missouri 

GEORGE E. BROWN, Jr., (CA) (ex-officio) 



1 Ranking Minority Member 

2 Vice Chairman 



(II) 



CONTENTS 



WITNESSES 



September 20, 1995: Page 

Hon. John T. Doolittle, Representative in Congress of the United States 

from the 4th District of California 13 

Hon. Tom DeLay, Representative in Congress of the United States from 

the 22d District of Texas 20 

Panel 1: 

Robert T. Watson, Associate Director of Environment, Office of Science 
and Technology Policy, Executive Office of the President, Washington, 
DC 30 

Dr. S. Fred Singer, president, the Science and Environmental Policy 

Project, Fairfax, VA 50 

Dr. Daniel L. Albritton, Director, Aeronomy Laboratory, Environmental 

Research Laboratories, NOAA, Boulder, CO 65 

Dr. Sallie Baliunas, senior scientist, the George C. Marshall Institute, 
Washington, DC 123 

Dr. Richard Setlow, Associate Director, Life Sciences, Brookhaven Na- 
tional Laboratory, Upton, NY 133 

Dr. Margaret L. Kripke, professor and chairman, department of immunol- 
ogy. University of Texas, M.D. Anderson Cancer Center, Houston, TX ... 145 
Panel 2: 

Hon. Mary Nichols, Assistant Administrator for Air and Radiation, Envi- 
ronmental Protection Agency, Washington, DC 189 

Kevin Fay, Alliance for Responsible Atmospheric Policy, Arlington, VA .... 203 

Ben Lieberman, environmental research associate. Competitive Enter- 
prise Institute, Washington, DC 226 

Dr. Richard L. Stroup, senior associate. Policy Economy Research Center, 

Bozeman, MT 263 

Dr. Dale K. Pollet, project leader, entomology, Louisiana Cooperative 

Extension Service, Baton Rouge, LA 271 

APPENDIX 

Appendix 1 — Statements for the record: 

Opening statement submitted by the Hon. James E. Hayes, Representa- 
tive in Congress of the United States from the 7th District of Louisi- 
ana, and ranking Democratic member, Subcommittee on Energy and 
Environment 293 

Statement submitted by the Hon. Henry A. Waxman, Representative 
in Congress of the United States from the 29th District of California .... 296 

Statement submitted by Rafe Pomerance, Deputy Assistant Secretary 

of State, U.S. Department of State 298 

Appendix 2 — Questions and answers for the record: 

Dr. S. Fred Singer 307 

Appendix 3 — Additional materials for the record: 

Remarks by Dr. John H. Gibbons, Assistant to the President for Science 
and Technology, "Sound Science, Sound Policy: The Ozone Story," Uni- 
versity of Maryland at College Park, September 19, 1995 311 

Letter dated October 11, 1995, to the Hon. Dana Rohrabacher, Chairman, 
Subcommittee on Energy and Environment, by Dr. Robert T. Watson, 
Associate Director for Environment, Office of Science and Technology 
Policy 320 



(III) 



IV 

Page 
Appendix 3 — Additional materials for the record — Continued 

Letter dated October 19, 1995, to the Hon. Dana Rohrabacher, Chairman, 
Subcommittee on Energy and Environment, by Dr. Sallie Baliunas, 
senior scientist, George C. Marshall Institute 324 

Letter dated November 15, 1995, to Sir John Maddox, editor, Nature, 
by the Hon. George E. Brown, Jr., ranking Democratic member, Com- 
mittee on Science 336 

Letter dated November 17, 1995, to the Hon. George E. Brown, Jr., 
ranking Democratic member. Committee on Science, by Sir John Mad- 
dox, editor. Nature 338 

Letter dated December 18, 1995, to the Hon. George E. Brown, Jr., 
ranking Democratic member, Committee on Science, by Dr. Sallie 
Baliunas, senior scientist, George C. Marshall Institute 343 

Associated Press article dated May 1, 1992, entitled '"Ozone hole' fails 
to materialize as feared, NASA says" 347 

Enclosures to letter dated September 18, 1995, to the Hon. George E. 
Brown, Jr., ranking Democratic member. Committee on Science, by 
Rex A. Amonette, M.D., president, American Academy of Dermatology .. 348 



SCIENTIFIC INTEGRITY AND PUBLIC TRUST: 
THE SCIENCE BEHIND FEDERAL POLICIES 
AND MANDATES 

CASE STUDY 1— STRATOSPHERIC OZONE: 
MYTHS AND REALITIES 



WEDNESDAY, SEPTEMBER 20, 1995 

House of Representatives, 

Committee on Science, 
Subcommittee on Energy and Environment, 

Washington, DC. 

The Subcommittee met at 9:37 a.m., in room 2318 of the Ray- 
burn House Office Building, the Honorable Dana Rohrabacher, 
Chairman of the Subcommittee on Energy and Environment, pre- 
siding. 

Mr. Rohrabacher. The hearing of the Energy and Environment 
Subcommittee will come to order. 

And Mr. DeLay will be here momentarily. Mr. Doolittle is here 
already and they will have testimony for us in the beginning. 

But first, I will begin with an opening statement. 

I am Congressman Dana Rohrabacher, Chairman of the Commit- 
tee. 

On February 3, 1992, then-Senator Al Gore told the United 
States Senate that, and I quote, "If atmospheric conditions con- 
tinue as they are for a few weeks, there could be an ozone hole 
above heavily-populated areas in the northern hemisphere. There 
could well be an ozone hole above Kennebunkport." 

And I remember that time period very well because I remember 
the Senator coming to one of the hearings that we had for the 
science hearings with many cameras in tow and newsmen in tow, 
in which he made the same prediction. 

But on the Senate floor, he went on to predict that there would 
be, and I remember, I believe he made the same predictions here 
with us, that there would be 300,000 additional — that's addi- 
tional — skin cancer deaths in the United States. And he envisioned 
a future in which children would have to hide from the sun when 
out to play. 

We now know that the hole in the sky over Kennebunkport was 
bunk. 

I have a little headline here for you, which, a few months after 
Senator Gore was before our committee, predicting the hole, the 
newspaper headline reads: "Ozone Hole Fails to Materialize as 
Feared." 

(1) 



Well, we now know that the hole in the sky over Kennebunkport 
was bunk. We can see it. We can analyze it. And this hole epi- 
sode — and there may be a pun intended, I don't know — turned out 
to be another, basically "the-sky-is-falling" cry from an environ- 
mental Chicken Little, a cry we've heard before when the American 
people were scared into the immediate removal of asbestos from 
their schools, which turned out to be exactly the wrong method and 
the wrong way of going about to tackle the problem, and when the 
American people stopped eating apples, causing millions and mil- 
lions of dollars' worth of loss to apple farmers because they were 
afraid of Alar. 

This time, the scare-mongers managed to stampede the Congress 
and the President of the United States. President Bush sped up 
what had been a deliberate timetable to phase out CFCs around 
the world. 

But that wasn't good enough. The U.S. unilaterally imposed an 
onerous excise taix on CFCs which has, as it always does, led to a 
thriving black market, which is what we see in the United States 
today. 

In July of this year, a senior U.S. Customs agent called bootleg 
CFCs, "almost as profitable as dope." 

As this funny circus goes on, we have to ask ourselves — does the 
science justify the actions that have been taken and the billions 
that have been spent? Instead of maintaining a deliberate pace, our 
country rushed head-long to ban the substances people rely on to 
cool their homes, their cars, and their refrigerators to keep fruits 
and vegetables and other food fresh. 

Was this justified by science? 

Even if we accept the premise that these chemicals are harmful 
to the stratospheric ozone layer, what is the actual risk of, say, ex- 
tending the phase-out period of CFCs in vehicles, as compared to 
the impact on the American consumer faced with replacing such 
expensive equipment? 

Are we getting objective science from our regulatory agencies, or 
are scientists with unconventional views being shut out of the proc- 
ess? 

These are some of the issues that will be aired at this, the first 
of a series of hearings on scientific integrity and the public process. 
Contrary to what you might have heard, this hearing is not going 
to be about whether we are for or against skin cancer. The Amer- 
ican people deserve better of their government than scare tactics 
that are designed to intimidate and repress rational discussion. 

During the course of these hearings, this Subcommittee will air 
views that are politically correct and politically incorrect. We will 
take a close look at the science behind regulations which govern- 
ment officials and the media have presented largely in emotional 
terms, and we will hear from both sides equally — I want to repeat 
that — we will hear from both sides equally, and I am hoping today 
to promote a dialogue between the various points of view, rather 
than just trying to have one view prevail over the other or trying 
to schedule one view early on in the hearing and not letting the 
other view be heard until the very end of the hearing, which far 
too often in the past was modus operandi for the congressional 
committees. 



For today's hearing, we are pleased that some of the most promi- 
nent scientific and economic experts on stratospheric ozone have 
agreed to testify. 

With this, I will now turn and ask my esteemed colleague, who 
I have great respect for, who chaired the overall Science Committee 
for a number of years, and now is with us, gracing us with his 
presence and his expertise, former Chairman Brown. 

Would you like to make an opening statement? 

Mr. Brown. I appreciate the Chairman's courtesy in allowing me 
the privilege of making an opening statement. I'm really substitut- 
ing here for the Ranking Minority Member, Congressman Hayes, 
who couldn't be present, but will, I hope, present a statement. 

Let me first say that I, as you do, welcome these hearings. What 
we badly need for all of science in this country is a better public 
understanding of the basis on which science is conducted and the 
basis on which regulatory decisions are made based upon that 
science. 

And I will compliment the Chairman for the way in which he has 
phrased the question and on his fairness in terms of setting up a 
hearing in which we do have good representatives of both sides 
who are appearing and making their case. 

And I hope that we can publicize the results of this hearing in 
such a way that it will contribute to the understanding of the 
American people on how science policy and science regulatory mat- 
ters are conducted. 

And they have been flawed in the past. I would be the first to 
agree with that. 

I note with some interest the Chairman's opening statement 
about the Vice President and Senator Gore's statement and I will 
admit that that was an effort to focus attention, in a very highly 
visible way, on an issue which the Senator turned out to be slightly 
exaggerating the consequences. 

Now if he were the first politician that had ever done that, I 
would feel that we might have a case here. But that rather typi- 
cally represents the way that politicians go about getting interest 
focused on an issue which they are concerned with. 

The process today is how we really need to hold hearings and to 
prepare the basis for legislation in a sounder and longer-term way. 

And I say this without intending to criticize the Vice President. 
I watched with great admiration as he exploited every opportunity 
to focus public attention on science issues while he was a member 
of this Committee. He did it in a good way and I think that Mr. 
Rohrabacher is doing a very good job in trying to perhaps now 
bring about a broader-based view on how some of these things are 
done. 

So, Mr. Chairman, I welcome the hearing. This is a very impor- 
tant issue. The global warming issue is one that we will be in- 
volved in through both policy and appropriations. We're into the 
level of billions of dollars per year in the area of atmospheric 
science and it's only appropriate that we act with great prudence 
with regard to that, with regard to ozone, yes. 

It's my personal feeling that the scientific case for ozone deple- 
tion is by now extremely strong, if not overwhelming. Of course, 
this will be explored by the witnesses that we have before us. 



If there ever was a way in which, an example of how good science 
was developed, I think the ozone issue illustrates that process. 

I might say that our history of concern for ozone depletion goes 
back at least a full generation when it was one of the issues that 
came up in connection with our discussion of whether to develop 
a fleet of supersonic aircraft, probably 20-odd years ago. And it was 
thought at that time that the aircraft would destroy the ozone 
layer and cause the problems that we now blame on 
chlorofluorocarbons. 

That proved to be a slight exaggeration. We never put up the 
fleet of supersonic transport. But it was not because of their impact 
on the ozone layer. It was the impact on our pocketbooks which we 
were worried about. 

Mr. Chairman, I will ask unanimous consent that my full state- 
ment be put into the record at this point. 

Mr. ROHRABACHER. Without objection. 

[The full statements of Subcommittee Chairman Rohrabacher 
and Ranking Minority Member Brown follow:] 

Opening Statement, Hearing on Ozone Depletion, September 20, 1995 

On February 3, 1992, then Senator Al Gore told the U.S. Senate that "if atmos- 
pheric conditions continue as they are for a few weeks, there could be an ozone hole 
above heavily populated areas of the northern hemisphere. . . . There could well be 
an ozone hole above Kennebunkport." 

Senator Gore then went on to predict 300,000 additional skin cancer deaths in the 
United States and envisioned a future in which children would have to hide from 
the sun in the when out at play. 

We now know that "the hole in the sky over Kennebunkport" was bunk. 

On May 1, the headlines read, "OZONE HOLD FAILS TO MATERIALIZE." 

This whole episode (no pun intended) turned out to be another cry that "the sky 
is falling" from an environmental chicken little — a cry we've heard before when the 
American people were scared into immediate removal of asbestos from schools and 
stopped eating apples because of Alar. 

This time they managed to scare the President of the United States. 

President Bush sped up what had been a deliberate timetable to phase out CFCs 
around the world. 

But that wasn't good enough. The U.S. unilaterally imposed an onerous excise tax 
on CFCs which has, as it always does, led to a thriving black market. 

In July, a senior U.S. Customs Agent called bootlegged CFCs "almost as profit- 
able as dope." 

Does the science justify the actions that have been taken and the billions that 
have been spent? 

Instead of maintaining a deliberate pace, our country rushed headlong to ban the 
substances people rely on to cool their homes, cars and refrigerators. Is this justified 
by the science? 

Even if we accept the premise that these chemicals are harmful to the strato- 
spheric ozone layer, what is the actual risk of, say, extending the phase out of CFCs 
in vehicles, compared to the impact on the American consumer faced with replacing 
expensive equipment? 

Are we getting objective science from our regulatory agencies or are scientists 
with unconventional views shut out of the process? 

These are some of the issues that will be aired at this first of a series of hearings 
on "Scientific Integrity and the Public Process." 

Contrary to what you might hear today, this hearing is not about being for or 
against skin cancer. The Ajnerican people deserve better from their government 
than scare tactics designed to intimidate and repress rational discussion. 

During the course of these hearings, this subcommittee will air views politically 
correct and incorrect. 

We will take a close look at the science behind regulations which government offi- 
cials and the media have presented largely in emotional terms and hear from both 
sides equally. 

For today's hearing, we are pleased that some of the most prominent scientific 
and economic experts on the stratospheric ozone issue have agreed to testify. 



Opening Statement by the Honorable George E. Brown, Jr. 
accelerated phaseout of stratospheric ozone depletion substances 

Mr. Chairman, I welcome today's hearing as an opportunity to set the record 
straight on the issue of ozone depletion and the Montreal Protocol. This is perhaps 
one of the most important success stories that we have on how "good science" has 
been transformed into "good policy". 

By any measure imaginable, there now exists a true consensus regarding the 
science of ozone depletion. Research in the U.S. and other countries supported by 
both the industry and Government has provided policy makers with a base of knowl- 
edge that underlies some of the most sophisticated cost-benefit analyses ever cairried 
out. Today, the science is even stronger than when the original Montreal Protocol 
was signed. 

The results we will hear today should provide ample proof that the Montreal Pro- 
tocol has worked. The Government and industry, acting together, have averted the 
dire scenarios that dominated the headlines a decade ago. Moreover, we can point 
with pride to the international leadership role we have developed in this area. 

Finally, while several issues remain, the transition to substitutes has gone 
smoothly with no major economic dislocations. To be certain, some individuals will 
feel the pinch — higher future costs for CFCs, diminishing availability of stockpiles, 
higher maintenance costs for old equipment and so on. 

Many of us who own Beta format VCRs, 33V3 RPM records, and typewriters have 
experienced these same frustrations. While I do not mean to trivialize the cases we 
will hear, they should be factored into an overall cost-benefit framework and should 
not, by themselves, drive public policy. An analysis of costs alone provides a dis- 
torted and one-sided picture of the effects of the phase-out of CFCs. 

I am mindful, of course, that some in Congress will be seeking to reverse the 
progress that has been made in phasing out ozone depleting chemicals and even 
abandon our international commitments altogether. I strongly feel that this would 
be a tragic and irresponsible mistake. 

I want to commend the Chairman for working with us to structure a balanced 
hearing today and I am confident that all points of view will be aired. We have in- 
vited representative voices from the overwhelming scientific consensus that has 
helped us understand the atmospheric dynamics associated with CFCs. Of course, 
the reality is that there are skeptics regarding ozone depletion — and we have in- 
vited some of the most prominent of those skeptics here today. 

I beUeve there is a place for such skeptics. Their challenges can provide intellec- 
tual stimulation and they can perform a valuable role in keeping the science "hon- 
est". I would hope though, that at the end of the day, our public policy is based on 
the predominant view, the peer reviewed science, and the international consensus. 
I do not believe any other rational path exists. 

Congress, as an institution, lacks scientific expertise to make judgements between 
competing claims. The only source of internal science advice to Congress, the Office 
of Technology Assessment, is being exterminated as a budget saving move. Given 
this situation, we cannot responsibly choose to follow the guidance of the scientific 
fringe — no matter how intriguing and no matter how much their message may fit 
with our own preferences and prejudices. 

I will close by reminding my colleagues that we have come a long way in develop- 
ing the international consensus on ozone depletion. U.S. leadership in this area has 
been supported by three Administrations. U.S. negotiators will be meeting again 
this October to review the progress we have made. I hope that we will take a re- 
sponsible view here today and provide our side with the support they will need in 
carrying out these important talks. 

I would like to insert into the record a letter we received from the American Acad- 
emy of Dermatology regarding the relationship between ozone depletion and skin 
cancer. I believe my colleagues will find it compelling. I look forward to the testi- 
mony of our other witnesses here today. 



6 

Mr. Brown. Furthermore, I would like to include as a part of my 
statement a letter we received from the American Academy of Der- 
matology regarding the relationship between ozone depletion and 
skin cancer. (See Appendix 3 for enclosures.) 

The American Academy of Dermatology, of course, includes those 
medical professionals who deal most with the issue of skin cancer 
and their statement should have considerable weight because of 
that. 

Mr. ROHRABACHER. That will be included, without objection. 

Mr. Brown. And two additional matters. I would like that the 
statement of our colleague, Henry Waxman, who could not be 
present, be included in the record. (See Appendix 1.) 

He is currently involved in the Clean Air Act and could not be 
here because of that. 

Mr. ROHRABACHER. Without objection, it will be put in the 
record. 

Mr. Brown. And furthermore, a statement by the science advisor 
to the President on ozone depletion, Dr. Jack Gibbons. (See Appen- 
dix 3.) 

Mr. ROHRABACHER. That will be put in the record, without objec- 
tion, as well. 

[The information follows:] 



InnD: American Academy of Dermatology 



1350 1 Street. N.W.. Sun e 880 
Washinctton, DC. 2000S-33I9 



ii\KiH2/»42..VVS,^ 
V >(1>/X42-1.(^S 



\iirl'miilnl-h.l„l 



September 18, 1995 



The Honorable George E. Brown, Jr. 
Ranking Democratic Member 
Committee on Science 
U.S. House of Representatives 
2320 Raybura House Office Building 
Washington, DC 20515-6301 

Dear Congressman Brown: 

On behalf of Ae American Academy of Dermatology, 1 am pleased to respond to your 
September 13 letter requesting the Academy's views on "the relationship between UV 
radiation and the various fonns of malignant and non-malignant skin cancer. " As you know, 
the Academy is dedicated to educating Americans about the dangers of skin cancer. Over 
tfie past decade, dermatologists have conducted free skin cancer screening clinics, screened 
over 1 miUion Americans, distributed thousands of skin cancer booklets and bookmarks, and 
conducted a concerted public information campaign to alert the American people to the 
dangers of the sim's rays. 

1 cannot understate the seriousness of the skin cancer problem. Today, skin cancer is the 
most common and most rapidly increasing form of cancer in the United States. In fact, there 
are now more cases of skin cancer in the United States than all other cancers combined In 
1989, Ae Academy proclaimed skin cancer to be an "undeclared epidemic," a phrase that has 
since been adopted by the Centers for Disease Control and Prevention (CDC). Half of all 
cancer diagnoses are for skin cancer, and one American in six will develop skin cancer in his 
or her lifetime. This year, nearly 1.2 million Americans will be diagnosed with non- 
melanoma skin cancer. According to a recent survey of dermatologists, an additional 80,000 
Americans m^ be diagnosed with mahgnant melanoma Altiiough highly curable if detected 
and treated early, nearly 10,000 Americans will die of skin cancer this year ~ about 7,500 
from malignant melanoma and the rest from non-melanoma skin cancers. 

Basal cell carcinoma is the most common form of non-melanoma skin cancer and is 95% 
curable. Basal cell usually presents as a slow-growing, raised, translucent nodule that may 



American Academy of Dermatology 



The Honorable George E. Brown, Jr. 
Sqjtember 18, 1995 
Page 3 



a pencil azsa. If you have any of these warning signs, the Academy urges you to visit your 
dermatologist or personal physician, immediately. 

With this background, let me try to address die specific issues dted in your letter. 

"Is there compelling laboratory or observationa l evidence that UV-B 
radiation is related to the incidence of skin cancer cases including 
'Tfffaffl'ffW ffffrf non-melanoma cancers?" 

The American Academy of Dermatology strongly believes that a decline in stratospheric 
ozone will be injurious to human health. As you know, the stratospheric ozone layer 
regulates the degree of ultra-violet (UV) irradiance on the earth's surface. Ozone is a 
selective filter, blocking all ultra-violet C (UVC) radiation, some ultra-violet B (UVB) 
radiation, and litde ultra-violet A (UVA) radiation. 

Recendy, scientists at the World Meteorological Organization (WMO) reported that the 
seasonal hole in the earth's ozone layer over Antarctica is growing faster dian ever and is 
already twice the size that it was at this same time last year. The ozone is also deteriorating 
over die northern hemisphere, but to a lesser extent. The WMO reports that ozone over 
Europe and North America has diminished 10%-15% since 1957, and the ultra\iolet 
radiation has increased 13%-15%. 

Even small decreases in ozone levels may result in a significant increase in die amount of 
UVB radiation at the earth's surface. Increased exposure to UVB radiation is deleterious to 
human skiiL UVB radiation causes sunburn, the {^toaging of the skin and, since 1 894, has 
been definitively hnked to the devdopment of non-mdanoma skin cancers. Decreases in the 
integrity of our stratos{^eric ozone will significandy increase the incidence of sunburn, 
accelerate the aging process, increase die incidence of non-melanoma skin cancers (as well 
as decease the age of onset for these cancers), and impact other skin disease. Exposure to 
UV radiation can initiate or aggravate certain serious diseases such as lupus erythematosus, 
porphyrias, hopes simplex, and other infectious diseases. Exposure to the sun can adversely 
affect individuals who are taking many medicadons, including over-the-counter drtigs like 
ibuprofen and diuretics, and may impede certain vaccinations. 



American Academy of Dermatology 



The Honorable George E. Brown, Jr. 

September 18, 1995 
Page 2 



crust, become ulcerated and possiUy bleed without treatment Individuals with light hair and 
eye color and a fair complexion are considered to be at Ugh lisk for this form of skin cancer. 
Basal cell carcinoma rarely metastasizes. It can, however, a£fect underiying structures, 
causing considerable damage, disfiguronent, and disability. I have enclosed several explicit 
photographs, highUghting the significant damage caused by basal cell carcinoma 
Dermatologists consider these cancers to be a very serious condition. 

Squamous cell carcinoma is anodier form of non-melanoma skin cancer and is also 95% 
curable, if propoiy treated in its early stages. Typically, squamous cell carcinoma appears 
as a raised, red or pink scaly nodule or wart-like growth on die face, hands, or ears. 
Squamous cell carcinomas can grow in size, cluster, and spread to other parts of the body. 
Squamous cell cardnoma is two to three times more common in men than in women. I have 
also enclosed examples of squamous cell carcinomas to illustrate that diese non-melanoma 
skin cancers are equally serious. 

MaUgnant mdanoma is the most deadly form of skin cancer, and die eighdi most diagnosed 
cancer in our nation. The incidence rate of maUgnant melanoma per 1 00,000 Americans is 
increasing at the rate of 4.2% per year, faster than that of any other cancer. The mortality 
rate for malignant melanoma is also increasing, but fortunately at a much slower rate. 

Malignant mdanoma begins in the body's melanocytes, the skin cells that produce die dai^ 
protective jxgment called melanin. It is melanin that is responsible for suntanned skin, acting 
as a partial protection against the sun's damaging rays. Melanoma may suddenly appear 
without warning, but it may also begin in or near a mole or other dark spot in the skin. 
Having dark brown or black skin is not a guarantee against melanoma Afiican Americans 
can develop mdanoma, eq)ecially on die palms, soles, under finger and toenails, and in the 
moudi. Malignant mdanoma is die leading cancer in young women in their twraities and is 
second only to breast cancer for women in dieir thirties. 

For years, the Academy has recommended diat every American examine his or her skin 
fi-equentiy to look for die dangers signs of melanoma, also known as die ABCD's of 
mdanoma "A" stands for asymmetry ~ one half of die lesion is unlike the other. "B" is 
for border irregularity - a scaUoped or poorly circumscribed border. "C" stands for color 
variabiUty — does the color of the lesion vary fixim area to area or has die lesion changed in 
color. "D" is for diameter - lesions should be no larger than 6 millimeters, the diameter of 



10 

American Academy of Dermatology 



The Honorable George E. Brown, Jr. 
SqXember 18, 1995 
Page 4 



"Is there compelling evidence that a decrease in stratospheric ozone and the 
consequent increase in UV-B will lead to an increase in the incidence of 
skin cancer? 

The Academy believes that there is sufiScient evidence that a decline in stratospheric ozone 
will result in a higher incidence of skin cancer. For each 1 % depletion of ozone, the rate of 
squamous cell carcinoma is expected to increase by 2%-5%, and the rate of basal cell 
carcinoma by l%-3%. That same 1% decline in ozone integrity is expected to increase the 
incidence of melanoma mortality by .8% to 1.5%. It has been reported that a 10% reduction 
in stratospheric ozone could increase squamous cell carcinoma rates by 16%- 18%. 

"Is there any basis for the claim that '...melanoma is mainly due to UV-A. 
which is not absorbed by ozone. Therefore, melanoma rates should not Ik 
qffected by chan ges in the ozone layer. '?" 



While the action spectrum for melanoma is not complete, there is consensus among 
dermatologists and phctobiologists that there is a linkage between malignant melanoma and 
UVB radiation. Excessive exposure to the sun and childhood sunburns are accepted as a 
cause of melanoma, especially among light-skinned people Dermatology does not accept 
that UVA is solely responsible for the development of malignant melanoma 

Of course, an increase in incidence will certainly be accompanied by a commensurate 
increase in treatment and other costs associated with skin cancer. It is estimated that over 
$1 biUion are spent annually in the United States for the treatment of malignant melanoma. 
As mahgnant melanoma is highly underreported (most are treated on an outpatient basis and 
hence are not reported to most cancer registries), this number may be well below the true 
cost of treatment. Increases in incidence, especially incidence of more advanced cases of 
malignant melanoma, would proportionately increase treatment costs. 

Until the ozone layer repairs itself we can only hope to mediate these dire predictions by 
taking action to stabilize the ozone and by making important changes in our sun habits and 
dothing choices. The Academy is working with the CDC for new and better ways to educate 
the population, especially children, about the dangers of sun exposure. Of course, the most 
effective preventive method is sun avoidance, especially deliberate sunbathing. There is no 
such thing as a safe tan. If you must be in the sun between the peak hours of 10:00 am and 



11 



American Academy of Dermatology 



The Honorable George E. Brown, Jr. 
September 18, 1995 
Page 5 



4:00 pm, the following i^ecautions are recommended wear a wide-brimmed hat, sunglasses 
and protective, tightly-woven clothing as well as a broad spectrum sunscreen with a sun 
protection fact (SPF) or at least 1 5. Sunscreens should be e^jplied twenty minutes prior to 
going outdoors. Water-resistant sunscreens should be reapplied often, especially after 
swimming or strenuous exercise. Remember, sun protection is also important during the 
winter and on cloudy days. 

In addition, the Academy believes that the newdy created UV Index will prove to be an 
important tool in our efforts to educate Ae pubhc about the dangers of sun exposure. Similar 
indexes have proven valuable in Austraha, New Zealand, and many other countries. The UV 
Index is a joint program of the National Weather Service, the Environmental Protection 
Agency, and the CDC. The UV Index measures the amount of solar radiation that reaches 
the earth on a scale of 1-10. Public health education messages have been developed to 
educate individuals about the importance of taking protective measures. Currently, the 
National Weadier Services provides the UV Index in 58 cities. The Academy supports a fiill 
national roll-out of this important program to the 160 cities currendy served by the National 
Weather Service. 

I hope that this information is helpful. If I or the Academy can be of fiirther assistance to 
you and the conunittee, please do not hesitate to call on us again. 



Sincerely 




Rex A. Amonette, MD. 
President 



RAA/ch 
Enclosures 



12 

Mr. Brown. And I thank the Chairman for his courtesy. 
Mr. ROHRABACHER. Thank you very much. And I appreciate the 
distinguished former chairman of the Science Committee being 
with us today. He has a treasure house of experience and we ap- 
preciate him sharing that with us today. 

Now we have two members with us. If they would Hke to give 
very short opening statement. 

No? And Mr. Ehlers, would you like to give a short opening state- 
ment? 
Mr. Ehlers. Thank you, Mr. Chairman. 

First, I also commend you for calling the hearing. I think this is 
an issue that should be aired for a number of reasons which will 
emerge during the hearing. 

My comments that I will offer will be short and just from my per- 
spective as a scientist, and also in the context of Congressman 
Brown's statement. I will be offering them as a politician who 
doesn't exaggerate. 

So we hope they can shed a little light on this. 
I think the key point to remember is that most of the issues we'll 
be discussing today are what Alvin Weinberg, former director of 
Oak Ridge, called trans-scientific issues. They are scientific in their 
origin, but they're in a sense beyond science because we cannot do 
the experiments. We cannot go up and create an ozone hole and see 
what the impact is. 

And so we can merely observe, model, predict. Then observe 
again, model again, predict again. 
This results in large uncertainties in the scientific results. 
And the difficulty is that, as a result of that, you will find sci- 
entists on both sides of issues and to compound the difficulty, advo- 
cates of one position or another will tend to look only at the evi- 
dence offered by the scientists who support their position and wave 
that triumphantly and say that science proves that such and such 
a policy is right or it proves it is wrong. 

I think it is very important for us, those of us who are laymen 
and those of us who are scientists, to be very careful in this area. 
I think it's important to be objective. It's important to be holistic 
and look at the entire picture and not latch onto just one particular 
contaminant and say the world is going to end if we don't take care 
of that, without recognizing the issues that are brought forward by 
that action. 

As Garrett Harden once observed, you can never do just one 
thing to the environment. You do one thing, it has repercussions 
in many ways. 

So be objective. Be holistic. Be patient. It takes time to work out 
the science in some of these issues. It may take a decade or two. 
In the meantime, we have to be very careful in interpreting and 
understanding the results. 

And finally, be prudent. Act on the information you have, but 
don't go overboard and set up a major policy which it turns out is 
extremely difficult to change once the science is found to be more 
firm, more definite, and requires a change in policy. 

So my plea to everyone on all of these issues is to understand 
the limitations of science, not trum.pet a particular result as ending 



13 

the debate simply because it supports your position and, above all, 
be objective, be holistic, be patient and be prudent. 

Thank you, Mr. Chairman. 

Mr. ROHRABACHER. Mr. Ehlers, of course, is one of the few sci- 
entists that we have here in Congress. We have a large number of 
lawyers, but just a few scientists. His opinion is respected and 
thank you very much for those words of wisdom. 

Before we seat our first panel, we have two colleagues who have 
drafted legislation affecting the CFC ban here with us for remarks. 
One is Congressman Tom DeLay, who will be arriving momentar- 
ily. He is the distinguished Majority Whip. 

And my friend and colleague and fellow moderate from Califor- 
nia, Congressman John Doolittle. Mr. DeLay will be here to speak 
with us about H.R. 475, which would repeal provisions of the Clean 
Air Act affecting the production of CFCs. 

Mr. Doolittle has drafted legislation which would return the 
phase-out of CFCs to the original schedule. That was before Sen- 
ator Gore created the stampede. 

And I would ask Mr. Doolittle to step forward now and if he 
could be recognized for five minutes. 

Mr. Doolittle? 

STATEMENT OF THE HONORABLE JOHN T. DOOLITTLE, A REP- 
RESENTATIVE IN CONGRESS FROM THE 4TH CONGRES- 
SIONAL DISTRICT OF THE STATE OF CALIFORNIA 

Mr. Doolittle. Mr. Chairman, and Members of the Subcommit- 
tee, I appreciate your holding this hearing. I think it's vital that 
we air these issues. 

Mr. Chairman, I'm going to leave to the capable scientists that 
will follow me today, and their testimony, discussion as to whether 
sound science justifies any ban on the production of CFCs. 

My own belief is that the question is still very much open to de- 
bate. 

I am convinced, however, that although further research may 
possibly support a future phase-out of CFC production, to date, 
there has not been a sufficient showing of scientific evidence to jus- 
tify the current and rapidly approaching ban date of December 31, 
1995. 

That's why today I am introducing legislation that, if enacted, 
would push the ban on CFC production back to the original date 
set in the Clean Air Act amendments of 1990, which is January 1, 
2000. 

There are several reasons why I believe we should adopt this pol- 
icy. 

First, the so-called scientific findings that precipitated the accel- 
eration were retracted by NASA, the agency that first announced 
them. 

Under the Clean Air Act, in the 1987 Montreal Protocol, CFCs 
were to be phased out with a total ban in production taking effect 
on January 1, 2000. 

But in February of 1992, NASA scientists held an emergency 
press conference to announce that an ozone hole similar to the ones 
over Antarctica would soon open over the Arctic and parts of North 



14 

America. The story was widely reported as a looming environ- 
mental catastrophe. 

Time magazine showcased the impending disaster on the cover 
of its February 17 issue. 

Within days, the U.S. Senate voted 96 to zero to accelerate the 
phase-out. President Bush agreed. According to author Ronald Bai- 
ley, less than a month after its emergency press conference, "sat- 
ellite data showed that the levels of ozone-destroying chlorine had 
dropped significantly and provided absolutely no evidence of a de- 
veloping ozone hole over the United States." 

NASA waited until April to announce at another press conference 
that a large Arctic ozone hole had been, quote/unquote, "averted." 

Did NASA's admission allay the fear and panic whipped up by 
the earlier prediction of apocalypse? 

Clearly not. The retraction received far less attention than the 
initial announcement. And in what must have been a very busy 
news week. Time magazine buried NASA's admission in four lines 
of text in its May 11 issue. 

Thus, despite the fact that the primary threat used to justify ac- 
celeration of the CFC ban never materialized, the accelerated 
phase-out remains in place. 

The second reason I support returning the ban to its original 
date is because of the astronomical costs associated with the accel- 
erated phase-out. There is a large amount of CFC-dependent refrig- 
eration and air-conditioning equipment in use today. Higher CFC 
costs and onerous EPA regulations have already resulted in sub- 
stantially higher repair costs for these systems. 

Ben Lieberman of the Competitive Enterprise Institute, whom I 
believe you will hear from today, has estimated the cost of the ac- 
celerated CFC ban, that that cost could reach as high as $100 bil- 
lion. Some feel that this estimate is too conservative. 

But, as it stands, this total represents $1,000 per-household tax. 

Such an enormous drain on the nation's economy would have to 
be considered, even in the face of a proven environmental catas- 
trophe. Yet, as I have mentioned, and as others will testify, the 
science behind the accelerated ban remains unsubstantiated. 

The third reason to delay the ban is because the cost-benefit 
analysis originally performed by the EPA to justify acceleration 
was flawed. The EPA under-estimated the costs I just referred to, 
and over-estimated the benefits. 

Among the primary benefits, according to the EPA, was protec- 
tion against melanoma skin cancer. A 1993 study, however, con- 
cluded that this cancer is caused by longer wavelength ultraviolet 
radiation, UVA, which is not screened by ozone, not by UVB, which 
is. 

In other words, a rise in the incidence of melanoma cases does 
not depend on the level of ozone in the atmosphere. 

Thus, the benefits EPA attributes to banning CFCs at the close 
of this year have been grossly overstated. 

Mr. Chairman, in closing, I want to touch upon one more point 
that was raised in a Wall Street Journal article recently, entitled, 
"Controversy Is Brewing Over the Effects of Chemicals That Are 
Replacing CFCs." 



15 

An official from DuPont was asked about the possible harmful ef- 
fects revealed by the study. The official dismissed the researcher's 
conclusions, saying they were based on worst-case scenarios. 

Mr. Chairman, the extreme environmental movement uses every- 
thing based on worst-case scenarios. It's dismaying to see that Du- 
Pont apparently is using that now. 

From today's testimony, Mr. Chairman, you will discover that 
worst-case scenarios have been driving this debate. Those of us 
who are skeptical about the need for an accelerated ban note that 
under the proponents' own worst-case scenario, the increased risk 
of skin cancer — imagine this — the increased risk of skin cancer that 
one would face without the ban is equivalent to moving 60 miles 
closer to the equator, for instance, from Washington, D.C. to Rich- 
mond, Virginia, or perhaps Beverly Hills down to where you surf 
in Laguna — if that's where you surf. Some place in your district, 
I'm sure — that Laguna isn't somebody else's. 

Instead of responding with scientific facts, some NASA scientists, 
EPA officials, and extreme environmental organizations have 
forced this imminent CFC phase-out on the American people using 
fear and doomsaying. 

It was the EPA that predicted in 1987 that 3 million skin cancer 
deaths would occur in the United States unless CFC production 
were curtailed. And it was NASA that predicted in 1992 that an 
ozone hole would open over much of the United States, Europe and 
Russia. 

I hope this Subcommittee today will look at all of the facts in- 
volving the use of CFCs and their effect on the environment. I be- 
lieve we should not allow the prohibition of CFCs to take place 
until Congress weighs the true costs and benefits of the accelerated 
ban. 

Sound science must be the basis for all future decisions we make 
on this important issue and I commend the Chairman and this 
Subcommittee for using this forum to search for the truth. 

[The complete prepared statement of Mr. Doolittle follows:] 



16 



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Testimony of 
le Honorable John T. Doofetle 




before 

Energy and Environment Subcommittee 
House Committee on Science 

Septanber20, 1995 



Mr Chainnan, Mwnbers of the subcommittee, thank you for allowing me this opportunity 
to testify here today Td like to b^in by thanking the distinguished chairman for holding this 
hearing on what I believe is a very important issue. 

I would also commend to the Members of the subcommittee the insights of Dr. Singer of 
The Science and Environmental Policy Project and Mr Ben Liebeiman of the Competitive 
Enterprise Institute, both of whom have b^n very helpful in keeping me informed of the shaky 
science and high costs associated with the impending ban on the production of 
chlorofluorcarbons. I had not had the opportunity to meet Dr. Baliunis and Dr Setlow before 
today, but I am familiar with their work in this area and am glad the subcommittee will get the 
benefit of their testimony. 

Mr. Chairman, I will leave to these capable scientists the discussion as to whether sound 
science justifies any ban on the production of CFCs. My belief is that the question is still very 
much open to debate. I am convinced, however, that although further research may possibly 
support a fijture phaseout of CFC production, to date, there has not been a sufiBcient showing of 
scientific evidence to justify the current and rapidly-approaching ban date of December 3 1 

That's why today I am introducing legislation that, if enarted, would push the ban on CFC 
production back to the original date set in the Clean Air Act Amendments of 1990 That original 
date was January 1 , 2000. My bill requires that the EPA issue regulations allowing the 
production of CFCs and halons listed as class I substances in accordance with section 604(a) of 
the Clean Air Act In addition, my legislation would restore prior law in determining the base tax 
amount for excise taxes on CFCs. 



17 



Mr. Chainnan, I would like to take a few minutes to explain why I do not believe we 
should allow the CFC ban to take efiFect at the end of this year, rather than the original year 2000 
date. 

Rrrt, the so-called scientific findings that precipitated the acceleration were retiarted by 
NASA, the agency that first announced them Under the Clean Air Act and the 1987 Montreal 
Protocol, CFCs were to be phased out with a total ban on production taking effect on January 1, 
2000 But in February 1992, NASA scientists held an "emergency" press conference to announce 
that an ozone hole, similar to the ones over Antarctica, would soon open over the Arctic and parts 
of North America. The story was widely reported as a looming environmental catastrophe Time 
magazine showcased the impending disaster on the cover of its February 17 issue 

Within days, the Senate voted 96 to to accelerate the phaseout President Bush agreed 
According to author Ronald Bailey, less than a month after rx& emergency press conference, 
"satellite data showed that the levels of ozone-destroying chlorine... had dropped significantly and 
provided absolutely no evidence of a devdoping ozone hole over the United States." NASA 
waited until April to announce at another press conference that a large arctic ozone hole had been 
"averted." 

Did NASA's admission allay the fear and panic whipped up by the earlier prediction of 
apocalypse? Not quite. The retraction received for less attention than the initial announcement. 
And in what must have been a busy news week, rune magazine buried NASA's admission in four 
lines of text in its May 1 1 issue. 

Thus, despite the fact that the primary threat used to justify acceleration of the CFC ban 
never materialized, the accelerated phaseout remains in place 

Another reason I support returning the ban to its original date is because of the 
astronomical costs associated with the accelerated phaseout. Thwe is a large amount of 
CFC-dependent refrigeration and air-conditioning equipment in use today. Higher CFC cosU and 
onerous EPA regulations have already resulted in substantially higher repair costs for these 
systems One auto mechanic from Atlanta w*o was in Washington recently for the White House's 
Small Business Conference said that he was embarrassed to hand his customers the bill after 
recharging their cars' air-conditioners 

Although I will defer to Ben Lirf)erman on the specifics of the cost estimates, I know that 
he found the cost of the accelerated CFC ban could reach as high as $100 billion Some feel that 
this estimate is too conservative, but as it stands, this total represents a $1,000 tax on every 
household in America. 

Such an enormous drain on the nation's econom> would have to be considered even in the 
&ce of a proven environmental catastrophe. Yet, as I have mentioned and as others will testify, 
the science behind the accelerated ban remains unsubstantiated 



18 



A third reason to delay the ban is because the cost-benefit analysis originally performed 
by the EPA to justify acceleration was flawed. The EPA underestimated the costs I just referred 
to and overestimated the benefits. Among the primary benefits, according to the EPA, was 
protection against melanoma skin cancer. A 1993 study, however, concluded that this cancer is 
caused by longer wavelength ultraviolet radiation (UVA) which is not screened by ozone, not by 
UVB, which is. In other words, a rise in the incidence of melanoma cases does not depend on the 
level of ozone. If this conclusion is true, the benefits EPA attributes to banning CFCs at the close 
of this year have been greatly overstated. 

Lastly, we have not allowed time for stable CFC replacements to develop. Again, I am 
guessing that Ben Lid)erman will address this topic in more detail, but it is certainly worth 
mentioning now. Before we replace CFCs, we had better make certain that we have workable 
and safe replacements. It is not clear that we are there yet. Just a month ago, an article appeared 
in the Wall Street Journal entitled "Controversy Is Brewing Over the Effects Of Chemicals That 
Are Replacing CFCs." In explaining a study that concluded that CFC replacements may produce 
a toxic byproduct, Tracey Tromp of the Atmospheric and Environmental Research Inc. said, "Our 
concern is that we know abnost nothing about the alternatives [to CFCs]." 

Mr. Chairman, in closing, I want to touch upon one more point that was raised in the 
Journal article. An official fi-om DuPont was asked about the possible harmful effects revealed by 
the study. The official dismissed the researchers' conclusions, saying they were based on 
worst-case scenarios. 

From today's testimony, Mr Chairman, you will discover that worst-case scenarios have 
been driving this debate. Those of us who are skeptical about the need for an accelerated ban 
note that, under the proponents' own worst-case scenario, the increased risk of skin cancer one 
would face without the ban is equal to moving 60 miles closer to the equator, for instance, fi'om 
Washington to Richmond. Instead of responding with scientific facts, some NASA scientists, 
EPA officials, and extreme environmental organizations have forced this imminent CFC phaseout 
on the American people with fear and doomsaying. It was the EPA that predicted in 1987 that 3 
million skin cancer deaths would occur in the United States unless CFC production were 
curtailed. And it was NASA that predicted in 1992 that an ozone hole would open over much of 
the United States, Europe, and Russia. 

I hope this subcommittee will look at all of the fiicts involving the use of CFCs and their 
effect on the environment. I believe we should not allow the prohibition of CFCs to take place 
until Congress weighs the true costs and benefits of the accelerated ban. Sound science must be 
the basis for all future decisions we make on this important issue, and I commend the chairman 
and this subcommittee for using this forum to search for the facts. 



19 

Mr. ROHRABACHER. Mr. Doolittle, thank you very much for your 
legislation and your testimony today. 

Ms. Rivers, do you have some questions that you'd like to ask? 

Please proceed. 

Ms. Rivers. ITiank you, Mr. Chair. And thank you. Representa- 
tive Doolittle. 

When I hear people say things like the evidence is not sufficient 
at this time, it perks up my ears and it almost forces me to ask 
the question, what would you consider to be sufficient evidence for 
action to be taken in this area? 

Mr. Doolittle. I think we need a clear scientific conclusion that 
there is a definite cause for the problem and that so-called problem 
is producing definite effects. 

Theories or speculation about it are not sufTicient. We need 
science, not pseudo-science. I think we've been in an era of pseudo- 
science where these dire consequences are portrayed in order to 
achieve a certain political objective. 

Ms. Rivers. Are you a scientist? 

Mr. Doolittle. I am not. 

Ms. RiVers. You are not. Have you found in peer-review articles 
or in the broader scientific discourse that people are saying, this 
really is not a problem? 

Mr. Doolittle. I have found that there is no established consen- 
sus as to what actually the problem is. I found extremely mislead- 
ing representations by the government and government officials 
that are not founded on sound science. 

Ms. Rivers. That's what I was asking about, is not government 
scientists, necessarily, but peer-review articles, where scientists 
who are out in academia who are doing this on a regular basis. 

Could you give me an example of some of the peer-reviewed pub- 
lications that you consulted in formulating your opinion that 
there's no science? 

Mr. Doolittle. Well, you're going to hear from one of the sci- 
entists today. Dr. Singer. 

Ms. Rivers. Dr. Singer doesn't publish in peer-reviewed docu- 
ments. 

Mr. Doolittle. You know, I'm not going to get involved in a 
mumbo-jumbo of peer-review documents. There's politics within the 
scientific community, where they're all intimidated to speak out 
once someone has staked out a position. 

Ms. Rivers. Right. 

Mr. Doolittle. And thankfully, under this Congress, we're going 
to get to the truth and not just the academic politics. 

Ms. Rivers. And when I went to the University of Michigan, one 
of the first things that I was taught about science is that you look 
at the methodology of anyone who is making claims. 

And the general way to feel certain that you're getting good 
science is that you put your ideas out in a straightforward way in 
a peer-reviewed publication and you allow others who are doing the 
same work to make comments, to criticize, to replicate your find- 
ings. 

And what I'm asking you, in your search for good science, is what 
peer-reviewed documentation did you use to come up with your de- 
cision? 



20 

What good science did you use to rely on? 

Mr. DOOLITTLE. And my response to you is it is the proponents 
of the CFC ban that have the burden of producing the good science. 

I do not have that burden. 

They have failed to meet their burden and until and unless they 
meet that burden, we should role back that date. I believe the 
extra years that we provide may give that opportunity. 

Ms. Rivers. Where I started this line of questioning was with 
your statement that the reason you oppose this is that there's not 
sufficient proof. I asked you what sufficient proof would be? You 
told me good science. I asked you, did you actually consult any of 
the sources that would be considered good science in scientific cir- 
cles? And you said, no. 

So I'm back to what are you 

Mr. DOOLITTLE. I didn't say, no. I consulted Dr. Singer, who is 
a very authoritative source, and I will stand with the doctor. 

Ms. Rivers. Okay. Thank you. 

Mr. ROHRABACHER. Of course, today, there are two questions. 
Number one, we have to define the problem. And number two, we 
have to say whether the solution that has been put forward, and 
that is, banning CFCs and having a major speed-up of that ban, 
whether or not that actually works and whether or not it is worth 
the cost to the consumer and to the American people. 

We'd now like to, with the permission of my colleagues, I'd like 
to call on Mr. DeLay. 

Thank you very much, Mr. Doolittle. I appreciate your comments 
very much. 

You've already been introduced, Mr. DeLay. Sometimes it's very 
difficult for me when I'm talking about my colleagues and introduc- 
ing them, and I almost introduced Mr. DeLay as the Minority 
Whip. 

It just feels so good to introduce you as the Majority Whip. Mr. 
DeLay, if you would like to proceed. You've already been intro- 
duced. 

STATEMENT OF THE HONORABLE TOM DeLAY, A REPRESENT- 
ATIVE IN CONGRESS FROM THE 22D DISTRICT OF TEXAS 

Mr. DeLay. Well, thank you, Mr. Chairman, and I do apologize 
for being late. The meeting with the Speaker ran a little longer 
than we thought and it's hard to get up and leave for the Speaker. 

But I do appreciate you allowing me the opportunity to partici- 
pate in this very important debate on the phase-out of CFCs and 
the depletion of the ozone layer. 

Let me start, Mr. Chairman, by saying that I recognize the im- 
portance of clean air and a healthy environment. There's been a lot 
said about those of us that are asking for reasonableness and good 
science when you make regulations and disrupt people's lives. 

But dirty air and harmful ultraviolet rays affect me and my fam- 
ily just as much as any other American. 

I'm here today because I believe that the science underlying the 
ban on CFCs and the connection between health and ozone deple- 
tion is debatable. 

We all know, or some of us know, that recent studies have shown 
that as much as 95 percent of light-induced melanoma is caused by 



21 

visible spectrum of light, and not by the ultraviolet light that is fil- 
tered by the ozone layer. Evidence of this nature justifies a com- 
prehensive review of the impact of the CFC ban on our health and 
on our economy, thereby on the lives of the American families. 

As everyone at this hearing knows, the Clean Air Act Amend- 
ments of 1990 require that CFCs, a widespread class of refrig- 
erants used in air conditioners and refrigerators and billions of dol- 
lars' worth of equipment, to be phased out of production out of fear 
that CFCs leak into the atmosphere and deplete the earth's ozone 
layer. 

What is not so well known is that this ban is the result of a 
media scare some years ago from individuals who have not backed 
away from a number of their claims. 

Most notably, on February the 3rd of 1992, just as an example 
of the kind of scare, the NASA scientists called an emergency press 
conference to announce that severe ozone depletion over the Arctic 
and a large part of North America was imminent, which received 
extensive media coverage and aroused much alarm amongst Ameri- 
cans. 

Just a few months later, and with much less fanfare, NASA 
quietly admitted that its prediction was wrong. The retraction went 
largely unnoticed and had no effect on law. 

Scientific evidence has shown that natural resources dominate 
the stratospheric chemicals that are suspected to cause ozone de- 
pletion. This evidence indicates that the ozone hole is controlled by 
climatic factors, rather than the amount of chemicals in the atmos- 
phere. 

Just this past July, the Washington Post reported that a team 
of scientists from MIT had shown that the concentration of ozone- 
depletion CFCs in the atmosphere is declining. While some sci- 
entists would have us believe that the depletion of the ozone layer 
is the result of decades of environmental negligence, they would 
also have us believe that the current phase-out of CFCs, which has 
been in place for less than a decade, is responsible for the remark- 
ably swift reduction in the level of CFCs in the atmosphere. 

I'm inclined to believe that we are not giving Mother Nature 
nearly enough credit. 

It's clear that man-made CFCs do not have as much of an effect 
on the atmosphere as normal climatic fluctuations. 

With CFC production in the United States scheduled to end by 
the end of this year, owners of air conditioning and refrigerating 
equipment are having to prematurely replace their equipment or 
use substitutes, many of which are distinctly inferior. 

In the rush to replace CFCs, it is obvious that little or no 
thought has been given to the long-term effects of the new com- 
pounds on our environment. 

Recent studies indicate that some of the replacement compounds 
significantly increase acid rain levels. In addition, the compounds 
being produced to replace CFCs are unpredictable and in some 
cases, dangerous. Some of the replacement compounds are highly 
flammable and others have been plagued by sudden and unex- 
pected explosions. 

CFCs affect the lives of almost every American, however. Almost 
no thought was given to how the CFC ban will affect the consum- 



22 

ers who bear the brunt of the costs. This phase-out may well be the 
single most expensive environmental measure to date with an esti- 
mated cost of $50 to $100 billion over the next decade — and every 
red cent will come out of the pockets of the American family. 

According to Ben Lieberman of the Competitive Enterprise Insti- 
tute, the most immediate impact on consumers is the increased 
cost of maintaining car and truck air conditioners. Americans own 
140 million air-conditioned vehicles which use CFC-12 as their re- 
frigerant, and the most common problem is the loss of refrigerant 
through leaking. 

Service stations are now charging $50 to $200 more than they 
used to for this repair, since the law requires them to take addi- 
tional steps to reduce the amount of refrigerant that escapes dur- 
ing services. 

Drivers that cannot afford to have their cars retrofitted with new 
air conditioning equipment, at a cost of as much as $1,000, will 
have to compete for dwindling supplies of CFCs at greater in- 
creased costs. At the time the ban was implemented, CFCs cost in 
the neighborhood of $1 a pound. Now they cost as much as $15 a 
pound. 

As might be expected, these skyrocketing prices have given rise 
to a flourishing international CFC black market. 

The phase-out will also affect the cost and quality of domestic re- 
frigerators. Refrigerators using CFC substitutes will cost $50 to 
$100 more, and probably need replacement three to five years soon- 
er than their CFC-12 predecessors. 

The absurdity is that refrigerators only use four to six ounces of 
refrigerants each, so they are negligible contributors to atmospheric 
CFC levels. 

And finally, I would like to point out that very little consider- 
ation has been given to the potential effect of this ban on energy 
consumption in the United States. Evidence indicates that CFCs 
are more energy-efficient than replacement compounds. This means 
we will need more gasoline to operate our cars and trucks and 
more electricity to support the needs of home and industrial refrig- 
eration units. 

If this is the definition of environmental progress, the need for 
a comprehensive review of this ban is self-evident. 

Is the cost worth it? I don't think so, especially when scientific 
evidence linking CFCs to atmospheric damage is ambiguous. 

While scientists offer the American public a dizzying array of 
facts and opinions on the relative importance and status of the 
ozone layer, billions of dollars are being spent to develop a new 
technology that may not even be necessary. 

Mr. Chairman, I commend you for holding these timely and im- 
portant hearings. Congress needs to review this issue thoroughly, 
and the American people need to understand the real dangers and 
the real costs associated with banning CFCs. 

Ultimately, we must make sure that we are not jumping out of 
the frying pan and into the fire. 

[The complete prepared statement of Mr. DeLay follows:] 



23 



STATEMENT OF THE HONORABLE TOM DeLAY 

THE COMMITTEE ON SCIENCE 
SUBCOMMITTEE ON ENERGY A^fD ENVIRONMENT 

The Real Cost of the CFC Ban 

September 20, 1995 

Mr. Chairman, thank you for allowing me the opportunity to participate 
in this very important debate on the phaseout of CFCs and the depletion of the 
ozone layer. 

Let me start by saying that I recognize the importance of clean air and a 
healthy environment. Dirty air and harmful ultraviolet rays affect me and my 
family just as much as every other American. I am here today because I 
believe that the science underlying the ban on CFCs, and the connection 
between health and ozone depletion is debatable. 

Recent studies have shown that as much as 95 % of light-induced 
melanoma is caused by the visible spectrum of light, and not by the ultraviolet 
light that is filtered by the ozone layer. Evidence of this naoire justifies a 
comprehensive review of the impact of the CFC ban on our health and on our 
economy. 

As everyone at this hearing knows, the Clean Air Act Amendments of 
1990 require chlorofluorocarbons (CFCs), a widespread class of refrigerants 
used in vehicle air conditioners, refrigerators, and billions of dollars worth of 
equipment, to be phased out of production out of fear that CFCs leak into the 
atmosphere and deplete the earth's ozone layer. 

What is not so well known is that this ban is the result of a media scare 
some years ago from individuals who have now backed away from a number 
of their claims. 



24 



Most notably, on February 3, 1992, NASA scientists called an 
"emergency" press conference to announce that severe ozone depletion over the 
Arctic and a large part of North America was imminent, which received 
extensive media coverage and aroused much alarm. A few months later, and 
with much less fanfare, NASA quietly admitted that its prediction was wrong. 
The retraction went largely unnoticed and had no effect on law. 

Scientific evidence has shown that natural sources dominate the 
stratospheric chemicals that are suspected to cause ozone depletion. This 
evidence indicates that the ozone "hole" is controlled by climactic factors 
rather than by the amount of chemicals in the stratosphere. 

Just this past July, the Washington Post reported that a team of scientists 
from MIT have shown that the concentration of ozone -depleting CFCs in the 
atmosphere is declining. While some scientists would have us believe that the 
depletion of the ozone layer is the result of decades of environmental 
negligence, they would also have us believe that the current phaseout of CFCs, 
which has been in place for less than a decade, is responsible for the 
remarkably swift reduction in the level of CFCs in the atmosphere. I am 
inclined to believe that we are not giving Mother Nature nearly enough credit- 
-it is clear that man-made CFCs do not have as much of an effect on the 
atmosphere as normal climactic fluctuations. 

With CFC production in the United States scheduled to end by the end of 
this year, owners of air conditioning and refrigeration equipment are having to 
prematurely replace their equipment or use substitutes, many of which are 
distinctly inferior. 



25 



In the rush to replace CFCs, it is obvious that little or no thought has 
been given to the long-term effects of the new compounds on our environment. 
Recent studies indicate that some of the replacement compounds significantly 
increase acid rain levels. In addition, the compounds being produced to 
replace CFCs are unpredictable and in many cases dangerous. Some of the 
replacement compounds are highly flammable and others have been plagued by 
sudden and unexpected explosions. 

CFCs affect the lives of almost every American, however, almost no 
thought was given to how the CFC ban will affect the consumers who to bear 
the brunt of the costs. This phaseout may well be the single most expensive 
environmental measure to date with an estimated cost of $50 to $100 billion 
over the next decade-and every red cent will come out of the pockets of 
American families. 

According to Ben Lieberman of the Competitive Enterprise Institute, the 
most immediate impact on consumers is the increased cost of maintaining car 
or truck air conditioners. Americans own 140 million air.conditioned vehicles 
which use CFC- 12 as their refrigerant, and the most common problem is a loss 
of refrigerant through leaking. Service stations are charging $50 to $200 more 
than they used to for this repair since the law requires them to take additional 
steps to reduce the amount of refrigerant that escapes during servicing. 

Drivers that cannot afford to have their cars retro-fitted with new air 
conditioning equipment, at a cost of as much as $1000, will have to compete 
for dwindling supplies of CFCs at greatly increased costs. At the time the ban 
was implemented, CFCs cost in the neighborhood of $1 per pound. Now they 
cost as much as $15 per pound. As might be expected, these skyrocketing 
prices have given rise to a flourishing international CFC black-market. 



26 



The phaseout will also effect the cost and quality of domestic 
refrigerators. Refrigerators using CFC substitutes will each cost $50 to $100 
more and probably need replacement 3 to 5 years sooner than their CFC- 12 
predecessors. The absurdity is that refrigerators only use about 4 to 6 ounces 
of refrigerants each, so they are negligible contributors to atmospheric CFC 
levels. 

Finally, I would like to point out that very little consideration has been 
given to the potential affect of this ban on energy consumption in the United 
States. Evidence indicates that CFCs are more energy efficient that the 
replacement compounds. This means we will need more gasoline to operate 
our cars and trucks and more electricity to support the needs of home and 
industrial refrigeration units. If this is the definition of environmental 
progress, the need for a comprehensive review of this ban is self-evident. 

Is the cost worth it? I don't think so, especially when scientific evidence 
linking CFCs to atmospheric damage is ambiguous. While scientist offer the 
American public a dizzying array of facts and opinions on. the relative 
importance and status of the ozone layer, billions of dollars are being spent to 
develop a new technology that may not even be necessary. 

Mr. Chairman, I commend you for holding these timely and important 
hearings. Congress needs to review this issue thoroughly, and the American 
people need to understand the real dangers and the real costs associated with 
banning CFCs. Ultimately, we must make sure that we are not jumping out of 
the frying pan, and into the fire. 



27 

Mr. ROHRABACHER. Thank you very much, Mr. DeLay. The legis- 
lation that you have offered will come to grips with many of the 
problems that yoU brought up today. 

Before I ask some of our colleagues to comment, you're basically 
saying that this ban, the environmental impact of what we have to 
do because of the ban, could be worse than the problem itself. 

Is that right? 

When you say that the energy requirements on the alternatives 
are increasing, and would increase the necessity of using more fuel, 
what you are actually saying, then, is more carbo — they're not car- 
bohydrates. 

Carbohydrates is what you eat. 

Mr. DeLay. Hydrocarbons. 

Mr. ROHRABACHER. Hydrocarbons are going into the atmosphere. 

Mr. DeLay. Well, certainly. I'll tell you, Mr. Chairman, and I 
said it during the debate of the Clean Air Act of 1990. Hardly any- 
one was listening, about 35 members were. And warned about 
some of the things that were being done with very little scientific 
basis to it. 

In fact, in the case of the acid rain section of the Clean Air Act, 
the NAPAP study was totally ignored. 

This is a perfect example of why we desperately need some sort 
of risk assessment, cost-benefit analysis in the promulgating of 
these regulations. 

Mr. ROHRABACHER. And some of the other problems you men- 
tioned, besides the fluorhydrocarbons, the idea that there might be 
some kind of acid rain. 

And actually, I've read somewhere where there might be some in- 
creased cause or risk of cancer by some of the alternatives to CFCs. 

Is that correct? 

Mr. DeLay. Well, I think you're going to have some panels of sci- 
entists that probably speak to that better than I will. But I think 
it's pretty clear, or at least there is another school of thought that 
is not tied to Chicken Little approaches to the environment, that 
suggest that particularly the CFCs are not doing the damage to the 
ozone layer that has been claimed. 

Mr. ROHRABACHER. So, just in summary, the ozone may not be 
threatened as we are being told, and even making the matter 
worse, some of the solutions for this problem that may or may not 
exist, actually may cause more damage to the environment. And 
that's what you're worried about. 

Mr. DeLay. And that's what I'm worried about. 

Mr. ROHRABACHER. Thank you very much. Do some of my col- 
leagues — I guess Mr. Roemer or Ms. McCarthy? 

Mr. Roemer, would you like to ask a question? 

Mr. Roemer. Mr. Chairman, certainly Mr. DeLay has advocated 
cost-benefit analysis, and that's something that our Committee has 
worked very, very hard on. 

I'm a strong supporter of the cost-benefit analysis and pushed 
that when we were in the majority as the Democratic Party and 
have worked in bipartisan ways with the new majority to get that 
through this Committee and to get it on the floor. And I'm hopeful 
that we can come up with a bill. 



28 

You mentioned that you'd like to see more peer review and cost- 
benefit analysis in this particular area. I guess I would just ask for 
your comments on the "Scientific Assessment Of Ozone Depletion: 
1994". 

In the back of it, starting on page 29 and going through page 36, 
are seven pages of scientists that have contributed to this study as 
peer reviewers. 

I know that you are a strong advocate of NASA, as I am, al- 
though we disagree on the space station. There are a host of dif- 
ferent scientists from NASA Langley and Goddard and a host of 
different space centers. 

Don't you think that this is something, after seven pages of peer 
reviewers, that that's something that you and I are trying to get 
in terms of scientific basis for these kinds of studies, although you 
might disagree with what the result is? 

Mr. DeLay. I do agree. The problem is, as has been happening, 
frankly, in the environmental movement for years, and as was out- 
lined in an excellent book called "Toxic Terror" by Dr. Elizabeth 
Wayland, who is president of the American Society of Health and 
Safety, I think is the name of the organization. 

The problem has been, is that, and it's my experience as a sci- 
entist — my education is in biology and biochemistry — is that you 
look at everybody and everything and consider all approaches to 
developing, during the scientific method, to developing a conclu- 
sion. And you don't weight it to one way or another. You want to 
gain all the information you can and make a decision based upon 
all the information. 

And I haven't seen this study, so I can't comment on this particu- 
lar study. But it's been my experience that a selective group, in 
fact, is usually taken — well, let me put it a different way. 

The conclusion is usually written before the study is even done, 
in many cases. And we can show you time and time again where 
that is the case. 

In fact, politics has entered into it and you can look at the his- 
tory of the NAPAP study, where the Executive Director came under 
criticism and indeed was fired when the study was going contrary 
to what some people wanted the conclusion to be. 

So I think, because you're having this hearing, because people 
from different points of view are being heard, then Congress can 
make an intelligent decision. 

Mr. ROEMER. I would just say that in looking through the dif- 
ferent scientists listed over these seven pages, from NASA and 
Harvard and Maryland and international institutes of science and 
MIT, New Zealand, Germany, France, Japan, Russia, that the poli- 
tics would be so different, that there probably is not some kind of 
consensus that they reach beforehand. 

But I would be interested in your comments. 

Mr. DeLay. I can give you a list of scientists, too, Mr. Roemer. 
I can give you scientists at the National Research Council. I can 
give you scientists at the Lawrence Livermore National Lab. I can 
give you scientists from Norway. 

Mr. Roemer. They're in here. They're in here. Livermore is in 
here as well, too. 



29 

Before I ask another question, let me yield to the gentlelady from 
Michigan. 

Ms. Rivers. Thank you, Mr. Roemer. 

Mr. DeLay, one of the things that you just said struck me. You 
said that one of the problems out there in science today is that peo- 
ple don't want to look at both sides of the thing. They have a deci- 
sion of what they want already. And then you proceeded to say 
that you never looked at the most important study on this issue, 
the most broadest, the one that has world-wide input. 

Why did you not consult the assessment on ozone depletion when 
you put together your proposal and built your position? 

Mr. DeLay. Well, I just haven't been presented with the study 
of late. I'll be glad to read it and give you my assessment of it. 

Ms. Rivers. Thank you. 

Mr. Roemer. I'd just say — is that my time, Mr. Chairman? I 
don't have time for any other questions? 

Mr. Rohrabacher. One more question. 

Mr. Roemer. And it's more of a statement than a question, and 
if you want to comment on it, Mr. Delay, I'd be happy to hear your 
comments. 

Certainly, there are different assessments and results in this 
than what you've said today. The industry-led results and scientific 
basis that worked closely with President Bush called for the policy 
that has been developed over the last few years. 

Your assessment today has been largely based upon a think tank 
and their assessment, rather than the industry-based. 

Mr. DeLay. That's not true. My assessment is from reading peo- 
ple like Fred Singer, who I think is testifying before this Commit- 
tee, reading Amie Goldback from Norway, reading others. 

We also have a problem here, too. We're creating an environ- 
mental industry that now, in fact, I've even heard from some peo- 
ple that have spent a lot of money complying with the CFC ban, 
and now they're very resistant to looking at lifting that ban be- 
cause they've already spent a lot of money in compliance with gov- 
ernment regulations. 

Mr. Roemer. I just think we're going to have many interesting 
opinions from the panels today and it would be helpful for you to 
read this study and to listen to the various opinions being offered 
today. 

And then we'd love to have you testify again to our Committee 
based upon that broad-based analysis. 

Thank you, Mr. Chairman. 

Mr. Rohrabacher. Thank you, Mr. Roemer. In fact, that's a per- 
fect segue into — with no objection, the Chair will request that we 
move forward with the scientists, rather than making this a discus- 
sion between various elected officials on this issue. 

We have distinguished scientists with us today. In fact, the Chair 
has gone out of the way to make sure that both sides are equally 
represented by prestigious individuals in the scientific community, 
so that we can have a dialogue on the issue with the experts, rath- 
er than between ourselves. 

I'd like to thank Mr. DeLay very much. 

Mr. DeLay. Thank you, Mr. Chairman. 



30 

Mr. ROHRABACHER. You have a piece of legislation that deals 
with this issue. Mr. Doolittle has a piece of legislation that deals 
with it as well. 

We thank you very much for your testimony. 

Mr. DeLay. Thank you, Mr. Chairman. 

Mr. ROHRABACHER. And the panel will be seated. Panel No. 1 
will be seated. 

I'll tell you what I will do. I will make the introductions as they 
are seated. 

Now with us, Dr. Robert T. Watson, who is the associate director 
of environment for the White House Office of Science and Tech- 
nology Policy, and is a former director of NASA's Stratospheric 
Ozone Program. 

We also have with us, Dr. S. Fred Singer, who is professor emeri- 
tus of environmental science at the University of Virginia, and is 
founder and president of the Science and Environmental Policy 
Project in Fairfax, Virginia. 

Also with us is Dr. Daniel Albritton, and he is director of NOAA's 
laboratory in Boulder, Colorado, and cochairs the United Nation's 
Ozone Science Assessment Panel. 

We have with us as well, Sallie Baliunas. She is a research astro- 
physicist at the nonpartisan George C. Marshall Institute and 
chairs their science advisory board. 

We have with us, Professor Margaret Kripke, who chairs the de- 
partment of immunology at the M.D. Anderson Cancer Center in 
Houston, Texas. 

And Dr. Richard Setlow, who is associate director of life sciences 
at Brookhaven National Laboratory. 

Before you start, let me tell you the ground rules. 

Your complete testimony will be in the record. Without objection, 
we will make their complete testimony a part of the record. 

But I will ask each of you to summarize with five minutes. And 
if you can summarize in five minutes, you will have much longer 
to speak afterwards because what I'm hoping to do is to promote 
a dialogue between members of the panel, as well as Members of 
this Committee. 

So if you could summarize to five minutes, it will be very helpful 
to the Committee because it will help promote the dialogue. And 
if you can go to your central points, I think that we can get to the 
important issues and the areas of contention, of honest disagree- 
ment, which is why we're here today. 

So, with that, I think, Dr. Watson, we will begin with you. 

STATEMENT OF DR. ROBERT T. WATSON, ASSOCIATE DIREC- 
TOR OF ENVIRONMENT, OFFICE OF SCIENCE AND TECH- 
NOLOGY POLICY, EXECUTIVE OFFICE OF THE PRESIDENT, 
WASHINGTON, DC 

Dr. Watson. Thank you, Mr. Chairman. 

My name is Robert Watson. I'm the associate director of environ- 
ment in OSTP. I co-chair the International Ozone Assessment 
Panel, the former director of NASA's Stratospheric Ozone Program, 
and have published extensively in the peer-reviewed literature on 
key chemical processes occurring in the atmosphere. 



31 

I greatly appreciate being given the opportunity to present the 
latest scientific findings of the international community to you and 
your Subcommittee. 

It's a pleasure to be able to address what I believe to be a real 
success story — credible science combined with technological ad- 
vances that have led to informed policy formulation at the national 
and international level. 

The scientific community, industry, environmental organizations, 
and governments have all worked towards a common goal — the 
cost-efiective protection of human health and our vital ecological 
systems. 

The American public can be proud that the U.S. provided sci- 
entific and policy leadership, and partisan politics were put aside 
to protect the health of Americans. 

My testimony represents the views of the very, very large major- 
ity of the international scientific community from academia, indus- 
try, government labs, and environmental organizations, not the 
views of single individuals with few, if any, relevant publication in 
the peer-reviewed journals. 

Hundreds of scientists from developed and developing countries, 
some of whom at one time were skeptics, have been involved in the 
preparation and peer-review of each of these assessments. 

I believe it's particularly important to note that industry sci- 
entists and industry-sponsored research played a vital role in these 
assessments. 

The key issues are very simple. The ozone layer limits the 
amount of UV-B radiation reaching the earth's surface. Thus, a de- 
crease in ozone will lead to an increase in UV-B radiation reaching 
the earth's surface. Increased levels of UV-B reaching the earth's 
surface will, not may, have adverse consequences for human 
health, ecological systems, and air quality. 

There is absolutely no doubt that the major sources of atmos- 
pheric chlorine are from human activities, not from natural 
sources. Human activity is also a major source of atmospheric bro- 
mine. 

Photochemically-active halogen species can catalytically destroy 
stratospheric ozone. Each chlorine molecule can destroy tens of 
thousands of ozone molecules and bromine is at least 50 times 
more efficient. 

Since the late 1970s, ground-based, balloon and satellite data 
have documented significant decreases in column content of ozone 
over Antarctica, about 60 percent, as shown in one of my figures 
in my testimony, and drastic changes in the vertical distribution, 
close to 100 percent loss of ozone at certain altitudes. 

The Antarctic ozone holes in 1990, 1992, 1993, and 1994, were 
the most severe on record. 

As we speak today, and as expected, satellite, balloon, and 
ground-based data show that the Antarctic ozone hole is once again 
developing in the fashion similar to the last few years. 

There is absolutely no doubt that the springtime Antarctic ozone 
hole is due to the increasing concentrations of anthropogenic chlo- 
rine and bromine. This conclusion is based on combining extensive 
ground, aircraft, balloon and satellite data with laboratory data 
and theoretical modeling. 



32 

The speculative and totally unsubstantiated hypothesis of Dr. 
Singer presented before Congress a few weeks ago is totally incon- 
sistent with the observational data and theory. 

With respect to global ozone, the observational data, as I've 
shown in figure 4 of my testimony, provides conclusive evidence 
that ozone depletion is occurring at all latitudes, except the tropics, 
and in all seasons. 

Analysis of extensive ground-based Dobson and TOMS data 
through 1994 has shown that column ozone has decreased by 5 to 
6 percent in summer in the northern hemisphere, 9 to 11 percent 
in winter/spring in the northern hemisphere, 8 to 9 percent in 
southern mid-latitudes on a year-round basis. 

Figure 5 in my testimony also shows the seasonal and latitudinal 
trends, illustrating the very significant trends at middle and high 
latitudes. 

In each case, the natural periodic and episodic fluctuations are 
taken into account — solar cycle, season and volcanic activities. 

The weight of scientific evidence strongly suggests that the ob- 
served mid-latitude ozone trends are due in large part to anthropo- 
genic chlorine and bromine. 

Ozone depletion is expected to peak within the next year or so, 
reaching about 6 to 7 percent ozone depletion in northern mid-lati- 
tude in summer and fall over the USA, and 12 to 13 percent in 
winter over northern mid-latitudes, and about 11 percent in south- 
ern mid-latitudes. 

The projected changes in column ozone would be accompanied by 
15 percent, 8 percent, and 13 percent increases in surface 
erythemal radiation in winter/spring in the northern mid-latitudes, 
summer/fall at northern mid-latitudes, and in the southern hemi- 
sphere year-round. 

The link between a decrease in stratospheric ozone and an in- 
crease in surface UV has been further strengthened in recent 
years. Measurements in Antarctica, Australia, Canada and Europe 
have shown under clear-sky conditions when column ozone de- 
creases, the amount of UV-B increases, exactly as expected by the- 
ory. 

DeLuisi of NOAA has recently concluded that the signal in the 
Robertson Bergometer that so many people talk about is so noisy 
due to day-to-day changes in UV-B, and calibration of the monitors 
was so flawed, that no reliable data and trends can be derived. 

Recent data suggests from the TOMS instrument that it is an ob- 
served increase in ultraviolet radiation in early summer, spring 
and late autumn at latitudes polar to 40 degrees north. 

Of particular importance for human health are the increases in 
the incidence of non-melanoma skin cancer, melanoma skin cancer, 
eye cataracts, and a possible suppression of the immune-response 
system. 

Some, such as Fred Singer and Sallie Baliunas, try irresponsibly 
to trivialize the issue of ozone depletion by noting that an ozone de- 
pletion of the magnitude observed is equivalent to only moving 
south by 100 miles or so. 

The reason this risk is even this low is the success of the Mon- 
treal Protocol and its Amendments and adjustments. 



33 

Without these international agreements, we would be facing fu- 
ture increases in UV-B radiation of possibly 40 to 50 percent by 
the middle or the end of the next century, and the comparable dis- 
tance to move would be more like 1,000 miles or so. 

There's a large difference in skin cancer rates between cities in 
the northern half of the U.S. and those in the southern half. The 
difference for white, Anglo-Saxon males in Albuquerque and Se- 
attle is at least a factor of five difference. 

In conclusion, the Montreal Protocol and its amendments and ad- 
justments are a success story that will in the future save thou- 
sands of American lives each year. Who amongst us would want to 
turn back the clock by weakening the Montreal program, leading 
to the deaths of innocent Americans for the sake of a few dollars? 

[The complete prepared statement of Dr. Watson follows:] 



34 



Statement of 

Dr. Robert T. Wategu 

Assbciate DirecJoi-ef'Environinent 

Office oTScIence and Technology Policy 

Executive Office of the President 

before the 

Subcommittee on Energy and the Environment 

Committee on Science 

United States House of Representatives 

September 20, 1995 

Mr. Chairman and Members of the Subcommittee: 

My name is Robert T. Watson, I am Associate Director of Environment in the Office of 
Science and Technology Policy, a co-chair of the International Ozone Assessment Science 
Panel, and the former Director of NASA's Stratospheric Ozone Program. I greatly appreciate 
being given the opportunity to present the latest scientific findings of the international 
community to you and your subcommittee. It is a pleasure to be able to address what I 
believe to be a real success story: credible science, combined with technological advances dtat 
lead to informed policy formulation at the national and international level. The scientific 
community, industry, environmental organizations and governments all worked towards a 
common goal: the cost-effective protection of human health and our vital ecological systems. 
The American public can be proud that the U.S. provided scientific and policy leadership, and 
partisan politics were put aside to protect the health of Americans. 

My testimony represents ^e views of the very very large majority of the international 
scientific community from academia, government laboratories, environmental organizations 
and industry, not the views of single individuals with few, if any, relevant publications in 
peer-reviewed journals. Hundreds of scientists, from developed and developing countries, 
some of \^diom were at one time skeptics, have been involved in the preparation and peer- 
review of each of a series of international scientific assessments conducted under the auspices 
of the World Meteorological Organization and the United Nations Environment Programme. 
Assessments have been issued in 1981, 1983, 1989, 1991, and the latest in 1994. I believe it 
is particularly important to note that industry scientists and industry sponsored scientists (e.g., 
research sponsored by the Chemical Manufacturers Association Fluorocarbon Program Panel) 
have played a vital role in each of the assessments. 

In 1994, three state-of-the-art assessments were conducted in response to the mandate of the 
Vienna Convention for the Protection of the Ozone Layer and its Montreal Protocol on 
Substances that Deplete the Ozone Layer. These assessments included: (i) an assessment of 
our understanding of the processes controlling the present distribution and rate of change of 
atmospheric ozone; (ii) an assessment of the environmental impacts of ozone depletion; and 
(iii) an assessment of the technological feasibility and economic costs associated with the 

1 



35 



substitution of substances controlled under the Montreal Protocol. The scientific assessment 
was co-chaired by Dr. Daniel Albritton of NOAA and myself; the impacts assessment was co- 
chaired by Dr Jan van der Lean of the Netherlands and Dr. Manfred Tevini of Germany; and 
the technology/economics assessment was chaired by Dr. Stephen Anderson of U.S. EPA. 

The need for sound science and risk assessment as the basis for regulatory policy is absolutely 
critical in this and other environmental issues. I believe that the scientific basis for decision- 
making in the ozone issue is excellent, far better than for most other environmental issues. 
This is largely because of the long-term commitment to a sound scientific research program 
by both Congress, and by this and previous Administrations. The research programs from 
NASA, NOAA, NSF, EPA, DOE and others provide much of the basic foundation for these 
assessments. 

My testimony will provide answers to what I believe are a number of the key science issues 
of policy relevance: (i) Why do we care about the ozone layer?; (ii) What controls the amount 
of ozone in the atmosphere?; (iii) Is there any evidence that human activities are changing the 
atmospheric concentration of ozone?; (iv) What is tiie effect of the Montreal Protocol?; (v) Is 
there any evidence of increased levels of UV-B radiation?; and (vi) What are the human 
health impacts of ozone depletion? 



Why do we care about the ozone layer? 

o The Eardi's ozone layer limits the amount of harmful ultraviolet-B (UV-B) radiation (280- 
320 nm) reaching the Earth's surface. Thus a decrease in ozone will lead to an increase in 
UV-B radiation reaching the Earths surface. 

o Increased levels of ultraviolet radiation (UV-B) reaching the Eardi's surface, will , not may, 
have adverse consequences for human health, ecological systems and air quality. Of 
particular importance for human health are increases in the incidence of non-melanonia 
skin cancer (between half and one percent of all cases are fatal), melanoma skin cancer 
(with a very high fatality rate), eye cataracts, and a possible suppression of the immune- 
response system. 



What controls the amount of ozone in the atmosphere? 

o The abundance of stratospheric ozone is controlled by the balance between die production 
of ozone and the loss of ozone. Ozone production is controlled by the rate of photolysis 
of molecular oxygen, where-as ozone loss is governed by a series of complex chemical 
reactions involving oxygen-, hydrogen-, nitrogen-, chlorine- and bromine-containing 
species. The large majority of these chemical reactions are well understood over the 
complete range of stratospheric temperature and pressure conditions. 



36 



Ozone depletion occurs when the rate of loss of ozone increases because of human 
activities. This is predicted, and has been observed to occur, when human activities 
increase the atmospheric concentrations of chlorine and bromine species. 

There is no doubt that the major sources of atmospheric chlorine are from human 
activities (e.g., chlorofluorocarbons, carbon tetrachloride, and methylchloroform), not from 
natural sources such as methyl chloride, volcanoes or sea spray. Natural sources of 
chlorine account for only 0.6 ppbv: less than 20% of total chlorine loading. The 
atmospheric concentrations of HCl and HF have been observed to increase over the past 
few decades: totally consistent with the major source of atmospheric chlorine being 
anthropogenic halocarbons. Human activities are also a major source of atmospheric 
bromine (methyl bromide and halons). 

Long-lived chlorine- (e.g., chlorofluorocarbons and carbon tetrachloride) and bromine- 
(halons) containing chemicals have no significant removal processes in the lower 
atmosphere. Consequently, weadier patterns distribute them uniformly over the whole 
globe and transport diem up into the stratosphere where the bulk of the Earth's protective 
ozone layer resides. 

Shorter-lived chemicals such as methylchloroform (a source of chlorine) and methyl 
bromide (a source of bromine) do have chemical removal processes in the lower 
atmosphere. Hence only a fraction of these chemicals emitted into Ae atmosphere reach 
the ozone layer. Even these chemicals are relatively well mixed throughout the globe, 
with slightly higher concentrations in the northern hemisphere where most of the 
emissions occur. 

These long- and shorter-lived organic halocarbons are broken down by photochemical 
processes in the stratosphere into what are called "reservoir and photochemically active" 
inorganic species. The photochemically active species (atoms and radicals) then 
catalytically destroy stratospheric ozone dirough a series of chemical processes. These 
chemicals are very efficient in destroying ozone: each chlorine molecule can destroy tens 
of thousands of ozone molecules, and bromine is even more efficient in destroying ozone. 
In fact bromine is at least SO times more efficient than chlorine in destroying ozone than 
chlorine per molecule. 

Antarctica is a very special situation. Chlorine and bromine are much more efficient in 
destroying ozone over Antarctica than over mid-latitudes because of the unique 
meteorological conditions in the stratosphere. These unique meteorological conditions 
produce veiy cold temperatures which causes water vapor to condense into ice crystals. 
These ice crystals transform most of the chlorine in the stratosphere from reservoir species 
into "photochemically active" forms that can destroy ozone in the presence of sunlight. 
Hence, almost all of the chlorine is available to destroy ozone over Antarctica. 



37 



Is there any evidence that human activities are changing the atmospheric concentration 
of ozone? 

o Observational data shows that ozone is being depleted in Antarctica and at mid- and high- 
latitudes in both hemispheres. The magnitude of the ozone depletion over Antarctica is so 
large that a statistical analysis of the data is not needed: greater than 60% in column 
content and close to 100% loss at certain altitudes. In contrast, the magnitude of ozone 
depletion at middle and high latitudes is smaller, such that statistical procedures are 
required for an accurate determination of the trend. However, it is quite clear from the 
work of statisticians from universities, government laboratories and industry that global 
ozone depletion is occurring at a very significant rate. 

Polar Ozone: 

o Since the late-1970's ground-based, balloon and satellite data have documented significant 
decreases in the total column content (Figure 1) ~ and even more drastic changes in the 
vertical distribution (Figure 2) ~ of ozone over Antarctica every spring-time. The 
Antarctic "ozone holes" of 1992, 1993 and 1994 were the most severe on record (deepest 
and greatest areal extent), extending over the v\^ole Antarctic continent: an air mass close 
to the size of North America. In each of these years, ozone was locally depleted by more 
than 99% between 14 and 19 km. 

o As we speak today, satellite, balloon and ground-based data show that the Antarctic ozone 
hole is once again developing in a fashion similar to the last few years. 

o There is no doubt that the spring-time Antarctic ozone hole is due to die increasing 

concentrations of anthropogenic chlorine and bromine, not caused by methane and carbon 
dioxide as suggested by F. Singer in his recent speculative and unsubstantiated 
Congressional testimony of August 1, 1995 (before the House Commerce Committee, 
Subcommittee on Oversight and Investigations). The consensus that chlorine and bromine 
are responsible for the ozone hole is a conclusion based on combining extensive ground, 
aircraft, balloon and satellite data, with laboratory data and theoretical modeling. Figure 
3 shows the strong anti-correlation between the abundances of ozone and chlorine 
monoxide, the key ozone-destroying species, i.e., as the abundance of chlorine monoxide 
increases the concentration of ozone decreases. 

o A substantial Antarctic ozone "hole" is expected to occur each spring for many more 
decades because stratospheric chlorine and bromine abundances will approach the pre- 
Antarctic-ozone-"hole" levels (late- 1970s) very slowly during the next century. 

o In the late-winter/early-spring periods of 1991/1992 and 1992/1993, chemical losses of 
ozone up to IS- 20% at some altitudes have been deduced from a series of intense 
observations in the Arctic. These observations, coupled with model calculations, increase 



38 



our confidence in the role of chlorine and bromine in the observed ozone destruction. The 
year-year variability in the photochemical and dynamical conditions of the Arctic limits 
the ability to predict ozone changes in future years. 

Global Ozone: 

o The observational data provides conclusive evidence that ozone depletion is occurring at 
all latitudes, except the tropics, during all seasons. Analysis of extensive ground-based 
Dobson data and TOMS and SBUV satellite data through 1994 has shown ozone has 
decreased by about S-6% in summer and 9-11% in winter/spring in northern mid-latitudes, 
and by 8-9% at southern mid-latitudes on a year-round basis. At northern mid-ladtudes, 
the downward trend in ozone between 1981 - 1991 was about 2% per decade greater 
compared to that of the period 1970 • 1980. Natural periodic and episodic fluctuations are 
taken into account (solar cycle, seasonal, volcanic, etc.). Figure 4 shows die observed 
global ozone trends from 1979 to 1994, after allowing for the effects of solar variability, 
die quasi-biennial oscillation (QBO) and seasonal cycles. Figure 5 shows the observed 
ozone trends by season and latitude, illustrating significant trends at middle and high 
latitudes. 

- Periodic fluctuations in ozone caused by changes in the 1 1 -year solar cycle can be 
removed from the record relatively well. The magnitude of solar cycle-induced 
changes in ozone have been estimated from ground-based Dobson data (30-40 year 
record) and the TOMS satellite data (IS year record). The best estimate probably 
comes from the Dobson network, where Reinsel et al. concluded that the maximum to 
minimum variation was 1.18±0.66%. Combining all data suggests that the peak-peak 
magnitude of the solar cycle effect is between 1 and 2%, significantlv less than the 
derived human-induced trend. 

- The magnitude of the seasonal cycle, depends on geographic location, and while much 
larger than the human-induced trend, is easy to remove quite accurately from the 
record because of the large number of repetitive cycles. 

• Random fluctuations, e.g., daily-weekly fluctuations caused by changes in 

"meteorological" conditions in the troposphere and stratosphere, cannot be removed, 
but are taken into account in the trend analysis using autocorrelation techniques. 

- Episodic fluctuations, caused by volcanic eruptions, cannot, a priori, be easily removed 
as the magnitude of the effect varies from one eruption to another. However, the 
effect of a volcanic eruption lasts for only a few years, hence cannot be the cause of 
any observed long-term trend. 

o The weight of scientific evidence strongly suggests that the observed mid-latitude 

downward trends of ozone are due in large part to anthropogenic chlorine and bromine. 
This conclusion is based on combining ground, aircraft, balloon and satellite data, with 
laboratoiy data and theoretical modeling. Figure 6 shows how well a theoretical model 
simulates the diurnal cycle of the abundances of key atmospheric constituents. 



3d 



What is the effect of the Montreal Protocol? 

The rate of increase of atmospheric chlorine and bromine has slowed considerably in 
recent years demonstrating the effectiveness of the Montreal Protocol and its amendments. 
Even so, the mid-latitude ozone loss and the hole over Antarctica are not expected to 
disappear until the middle of the next century because of the very long atmospheric 
residence times for the CFCs and halons, i.e., human emissions between 1960 and today 
will affect the health of future generations. 

Human-induced ozone layer depletion is expected to peak around the year 1998, since the 

peak stratospheric chlorine and bromine abundances are expected to occur then. Based on 

extrapolation of current trends, observations suggest that the maximum ozone loss, relative 

to the late 1960s, will likely be: 

(i) about 12 - 13% at Northern mid-latitudes in winter/spring; 

(ii) about 6 - 7% at Northern mid-latitudes in summer/fall; and 

(iii) about 11% (with less certainty) at Southern mid-latitudes on a year-roimd basis. 

These projected changes in column ozone would be accompanied by 15%, 8%, and 

1 3% increases, respectively, in surface erythemal radiation, if other influences such as 

clouds remain constant. 

Without the Montreal protocol and its amendments and adjustments future levels of 
atmospheric chlorine and bromine would be far higher than today (Figure 7). Hence, 
future levels of ozone depletion, ground-level UV-B, and cases of skin cancer would be 
substantially higher than today. Figure 7 shows how the Copenhagen amendments limit 
peak stratospheric chlorine loading to about 3.S ppbv, decreasing to about 2 ppbv by about 
2050, at ^^4lich time mid-latitude ozone depletion and the Antarctic ozone hole should 
have recovered. Even with the Montreal Protocol, stratospheric chlorine levels were 
projected to continually increase, exceeding 10 ppbv in the latter part of the century. 



Is there any evidence of increased levels of UV-B radiation? 

o The link between a decrease in stratospheric ozone and an increase in surface ultraviolet 
(UV) radiation has been further strengthened in recent years. Measurements in Antarctica, 
Australia, Canada and Europe have shown that under clear sky conditions when column 
ozone decreases the amount of UV-B radiation increases by the amount expected from 
theory (Figure 8). Large increases of surface UV are observed in Antarctica and the 
southern part of South America during the period of the seasonal ozone "hole." 
Furthermore, elevated surface UV levels at mid-to-high latitudes were observed in the 
Northern Hemisphere in 1992 and 1993, corresponding to the low ozone levels of those 
years. 



40 



The international assessment noted the lack of a decadal (or longer) record of accurate 
monitoring of surface UV levels: the UV-B network which operated between 1974 and 
198S was limited to only a few polluted sites in the USA, hence not representative of die 
USA. let alone other locations around the globe. The assessment also noted variations in 
UV-B introduced by clouds and other factors precluded the unequivocal identification of a 
long-term trend in surface UV radiation. It should be noted that the magnitude of ozone 
depletion between 1974 and 1985 over the USA was only about 2% in summer and S% in 
winter, a level very difficult to detect given the limited number of sites, local pollution 
problems, high variability of UV-B induced by variations in ozone and cloud cover, and 
the low sensitivity of the instruments. J. DeLuisi of NOAA has concluded that the signal 
from UV-B is so noisy due to day-to-day changes in UV-B, and *he calibration of die 
monitors was so flawed, that no reliable trends can be determined from the data. The 
UV-B flux may have even increased (as expected) over that time period, but it would not 
have been detected by the network ~ it would have been overwhelmed by the calibration 
problems. The original data sets and documentation for the network no longer exists, so it 
is impossible to reconstruct an accurate data base from the monitoring network. 

Recent data, since the international assessment, suggest that is highly unlikely that there is 
no long-term trend in UV-B. Statistically significant (2-sigma) UV-B trends during 
spring, early summer and late autunm at latitudes between 60 degrees North and 60 
degrees South can be derived from TOMS satellite measurements. In addition, satellite 
estimated UV-B fluxes agree very well with ground-based measurements for all observing 
conditions (cloud plus aerosols and clear sky). 



What are the human health impacts of ozone depletion? 

o As stated earlier, ozone depletion will lead to increases in the incidence of non-melanoma 
skin cancer, melanoma skin cancer, eye cataracts, and a possible suppression of the 
immune-response system. 

o Let me just discuss briefly just one issue, that of UV-B radiation and non-melanoma skin 
cancer. For every 1% sustained increase in UV-B radiation there will be an approximate 
2% increase in the incidence of non-melanoma skin cancer in light-skinned people. The 
current incidence rate of non-melanoma skin cancer in the United States is approximately 
750,000 new cases each year, of which between O.S and 1% of these cases will result in 
death. Even those cases diat do not result in death, are a significant cost to individuals 
and health care services. Ozone depletion is expected to peak within the next few years at 
about 6-7% over Northern mid-latitudes (including the United States) in summer/fall and 
about 13-14% in winter/spring. Thus a sustained ozone depletion will lead to a significant 
increase (about 1 5%) in the incidence of non-melanoma skin cancer and associated deaths: 
clearly an important public health issue for the United States. 



41 



o Some try, irresponsibly, to trivialize the issue of ozone depletion by noting that an ozone 
depletion of the magnitude observed is equivalent to only moving south by a hundred 
miles or so. The reason the risk is even this low is the Montreal Protocol and its 
amendments and adjustments. Without these international agreements we would be facing 
future increases in UV-B radiation of possibly 40-50 percent by the middle or end of the 
next century, and the comparable distance to move would be more like a thousand miles 
or greater. If there were an increase in UV-B radiation so that people living in Boston 
experienced an equivalent of the radiation they expect when they visit Miami, most people 
would consider that change to be highly significant. There is a big difference in skin 
cancer rates between cities in the northern half of the U.S. and those in the Southern half 
For example, the skin cancer rates for fair-skinned males in Albuquerque were approx. 
700 per 100,000 versus 150 per 100,000 in Seattle, a factor of 5 increase. 



Conclusion 

o Human-induced stratospheric ozone depletion is occurring at all latitudes except the 

tropics. This results in an increase in ultraviolet radiation at the Earth's surface, which is a 
serious human health issue for Americans. 

o Those that suggest the Montreal Protocol is not needed or too expensive, clearly must put 
a low value on the thousands of future lives saved annually in the U.S. alone. 



42 



Historical Springtime Total Ozone Record 
for Halley Bay, Antarctica (76°S) 



400 - 




1995 



43 



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47 




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50 

Mr. ROHRABACHER. Dr. Watson, thank you very much. 
Dr. Singer, I heard your name mentioned several times. Maybe 
you'd like to testify next. 

STATEMENT OF DR. S. FRED SINGER, PRESIDENT, THE 
SCIENCE AND ENVIRONMENTAL POLICY PROJECT, FAIRFAX, 
VA 

Dr. Singer. I wish I could give as emotionally charged a presen- 
tation as my colleague has just done. But I'll try to be calm and 
factual. 

I'm a scientist who has worked for a number of years on atmos- 
pheric and ozone problems. 

My relevant biography is given in the testimony. I've also at- 
tached to my testimony a recent peer-reviewed article that I've 
written on the ozone issue. It lists further peer-reviewed articles 
that I've written in the last few years. 

I'm very distressed that Congresswoman Rivers was not able to 
find some of my peer-reviewed articles. I think there are about 200 
of these in the literature and I'd be glad to supply a list. 

But perhaps it's her staff that's at fault. So I should not blame 
her for this. 

I was asked to supply some examples of lack of scientific integ- 
rity in dealing with the ozone CFC issue. 

I thought I would list about half a dozen of these and you'll find 
them listed in my testimony and hopefully, thoroughly explained. 
These are cases where the science was twisted, shaped, in order to 
gain certain ideological objectives. There was never a case where 
the actual facts were, shall we say, misstated, where there was ac- 
tual wrong information presented. 

But~it was presented in such a way as to give a misleading im- 
pression. 

You, ladies and gentlemen, here are being today misled, bam- 
boozled, and otherwise manipulated by some of the testimony that 
you've just heard. 

My job today, I think, is to expose this to you, and I'd like to do 
that. I hope there will be many questions to me so that I'll have 
a chance to comment in some detail on the way in which the sci- 
entific information has been misrepresented to you in order to 
achieve certain political objectives. 

I'm fortunate to have Dr. Baliunas here. She's the distinguished 
research astrophysicist at the Harvard Observatory. She'll be ad- 
dressing the issue of ozone depletion, or so-called ozone depletion. 

But let me address the issue which is an important one of the 
possible or claimed rise or increase in ultraviolet radiation. 

You know, the people who believe that ozone has been depleted 
are looking very, very hard for some evidence for an increase in ul- 
traviolet radiation to prove that ozone has been depleted. 

They've not been able to find it. 

If you look, for example, at Dr. Watson's testimony on page 7, 
you'll find some convoluted language, saying that various factors 
have precluded the unequivocal identification of a long-term trend 
in surface UV. 

What this means is that he has no evidence. 



51 

Later on he says, it's highly unlikely that there is no long-term 
trend in UV-B. 

Again, this means that he has no evidence. 

But why doesn't he have any evidence for an increase in UV? I'll 
tell you why. Because the evidence we have shows that UV-B did 
not increase. It decreased. The evidence was published and covers 
the period of 1974 to 1985. 

Now let's see how he deals with the evidence, how does he ex- 
plain it away. 

Well, first he says, the instrument is no good. Bad calibration. 
Well, when it's pointed out that the instrument is okay, then he 
says, well, okay. The instrument is fine, but the record is too noisy. 
The UV goes up and down. You can't tell if there's a trend. 

When you point out that the same argument applies to ozone, he 
then goes to the same argument. He says, well, pollution increased 
in the atmosphere £ind that's what absorbed the UV. 

But the EPA tells us that pollution has decreased in the United 
States as a result of the Clean Air Act, so that's a difficult problem 
for him. 

Well, fortunately, to the rescue comes a publication in Science 
magazine in 1993, claiming that UV-B over Toronto has increased 
by up to 35 percent per year. Thirty-five percent per year — that's 
a very large trend if it goes on for many years. 

We examined that paper. By the way, the paper was supposed 
to be peer-reviewed. We published a paper in Science showing that 
the analysis was incorrect, based on faulty statistics, and that the 
trend of UV-B was zero. Zilch. Nothing. Nada. 

There was no trend and the paper is wrong. And it's still being 
quoted, not only by Dr. Watson, but also in the Scientific Assess- 
ment of 1994 that has been referred to earlier. 

Well, after he shows that you cannot detect the UV trend, he 
then goes to a nonsequitur. If you can't get it here, you switch to 
something else. 

The nonsequitur is, well, UV-B has increased in the Antarctic 
whenever ozone decreased. 

Well, of course it would do that if there's a clear sky. What he 
doesn't tell you is that as soon as ozone increases, the UV-B de- 
creases. 

In other words, it goes up and it goes down. 

But if you look at his testimony, you'll find only references to 
cases where the UV-B goes up. It's like telling you that it gets 
warmer every July and never tells you that it gets colder in Decem- 
ber. 

It leaves you with the impression that this is going to be a very 
hot climate some day. 

Finally, there's a suggestion that the satellite instrument, the 
TOMS instrument, has measured a UV trend on the surface. 

I know something about the instrument. I designed it many 
years ago. If you read his testimony carefully, you'll find out that 
the UV trend that he talks about is not measured. It's derived from 
the TOMS instrument. It is estimated. 

In other words, it's calculated. It's not a direct measurement of 
UV reaching the surface of the Earth. There simply is no evidence 
for this. And this is crucial, I think, because it is UV at the surface 



52 

of the Earth that's supposed to produce all the harmful health ef- 
fects that we're talking about. It's supposed to produce all the skin 
cancer that we're talking about, and I hope I'll have a chance later 
on to comment on this, but I'd better stop at this point. 

Mr. ROHRABACHER. Do you have a 30-second summary that you'd 
like to make? 

Dr. Singer. Yes, only one point here. You often hear the state- 
ment from Dr. Watson and others that the depletion of ozone is 
worse than expected. Or that the ozone hole this year is worse than 
expected. Or that the increase in UV is worse than expected. 

Expectations are based on theory, on calculation. 

If you think about the statement for a minute, it sounds awful. 
It's very frightening. Isn't it scary — "worse than expected." 

What it really means is that the expectation, the theory, is 
wrong. Or the observations are wrong. Or, more likely, thej^re both 
wrong. 

Thank you. 

[The complete prepared statement of Dr. Singer follows:] 




63 



The Jcience t Environmental Policy N^i 

4084 UnJversfty Drive, Suite 101 

Fairfax. VA 22030-6812 

Tel: (703) 934-6940, Fax: (703) 352-7535 

S. Ff»d Sin ger. Prv D.. President 

TESTIMONY OF SjfpRED SINGER, PhD" 

PRESIDENT, THE SaENCB-A-EI^VIRONMENTAL POLICY PROJECT 

Heariog oo "Stretosphoic Ozone: Myths and Realities" 

HoQse Science Conunittee, Subconunittee on Eneigy and Environment 

September 20, 199S 

Mr. Cbainnan, Ladies and Gentleinen. 

My name is S. Ftei Singer. I am professor emeritus of environmental adences at die University 
at Virginia and tiie founder and president of The Science & Environmental Policy Project in 
l^iiftx, Viigioia, a non-paitisan non-profit research group. I Iiold a skepdcal view on the 
adequacy of the science dial siyp or t s our coirent stratospheric ozone policy-namely, to phase 
oat chlorafloorocaitxuis (GPCk) on an aocelenued schedule. 

Vice Ptesident Al Gore keeps lefeoing to scientist skeptics as a "dny minority outside the 
mainstxeam." Others tiy to discredit scientist skiq>tic8 by lumping diem together with fiioge 
political gfoapt. To counter such mis r q u e s e ntatl ons, let me present my geoeial scientific 
qualifications and diose relevam to the ozone issue. 

Relevant BadcETOond: 

I hold a d^iee in engineering tnm Ohio Stale and a PhJD. in physics from ndnoetoo Umversity. 
For mote than 40 yean, I have specialized in atmospheric and space physics. I received a 
Special Oommendadon from Rresident Elsenhower for die eady design <tf satellites. In 1962. 1 
e s taWidwd die U^. Weadier Satellite Service, served as its first director, and leo^ved a Gold 
Medal award from die VS. D^artment of Oo mmer ee for this c<MUribntion. 

Eaily in my car e er I devised die instrument used to measure strato^iheric ozone from satellites. 
As a DepoQr Assistant Adnnnistrtior of die U.S. Environmental Rrotecdoo Agency in 1971, 1 
chaired an intcniepartmetital panel of sdeotlsts loddng into the possible effects on sBatospheric 
oaone of a proposed fleet ci tapetsotac transports ^STs). Ours was the first group to examine 
possible damage to die ozone bQfer fh»m human activities and look into poteodal health 
oooseqoeoces. hichiding skin canoers. During diis period I published the li^pothesis that 



54 



anthroposenic mettuuie, fixMn cattle raising and rice growing, ooold deplete stratospheric ozone'. 
In tbe late 1980s I saved as Chief Sdeotist of the U.S. Depaitment of TYanspoitatloo and also 
provided expert advice «> tbe White House on the ozone issue. 

gxa ^ka of Bailnrea of Scientific Integrity: 

Today's hearing on scientific integrity as telated to the strato^heric ozone layer is well timed. 
The Unted Nations Enviroiuneat Programme and the secretariat for die Montneal Protocol [oa 
Substances diat Deplete die Ozone Layer] designated Sq>tetnber 16 as the fiist anoaal 
Intenuoional Dey for the Presenration of the Ozone LiQrer. The White House, spurted on by die 
EPA. has extended tiant oelefantioa into a whole wask. This should remind us tfiat ozone 
dq>letioo is no longer Just a scientiflc debate; entrenched domestic and intematiooa] bureaucra- 
cies, not to meatioa commercial interests, now have a considerable stake in keqiing alive fears 
of an ozone catastn^hc 

TUs moiniag, I will touch oo seveial topics that relate to the dieme of scientific faitegri^ 

• Hnt. I want to state deariy diat there is no scientinc consensus on ozone deidetion or its 
consequences. "Consensus" is a political concept, not a scientific one. It is used mainly to gain 
icasMua noe for an ideological position and to avoid having to examine the scientific arguments 
in detail. Consensus has been claimed also tot die global wanoing issue. The oCBcial ttpon 
Crotn the UN-qMosored Intei]govenunental Pnel on dimaie Qiange mentiwis the cx isteao e of 
"minority" views, but the editon could not, or perhaps would not, "accommodate" them*. The 
IPOC editors thus achieved "consensus" by ignoring contrary evidence and disseodag views. 
Much die same has been true in the ozone issue. 

In view of the present policy to ban CPCs by tbe end of 1995, why spcad a lot of energy fighting 
A fitit aeconq>in I ddnk die best answer was given by an enviroomeotil activist on an ABC 
New9-"ffighdinc" tdevision program in I^ebraary 1994. Michael Oppenhdmcr of the 
EnviioaineDtal Defense Pond complained diat "if [skqidcal sdeotists] can ^ die pafalk to 
believe that ozone wasn't wordi acting on, diat Aey [the public] were led in die wrong 
direcdon>.« then diere it do leasoa fer the ptibUc to beUnre «nytfaing about any envlronnnentil 
issue." Given the activist groaps' miserable record of unfounded scares about the global 
environment, such a reaction may be warranted. 

• Ndd, I want the record to diow diat tbe 1987 Montreal Protocol [on Substances that Dqilete 
die Oaone Layer] wis n^odated widiout adequate concern fyr ackntific evideooe. Hie chief 



' S. P. Stf^er. "StEitiiVtak Water Vapoor Increase Doe to Hiiman AeliTilia,' N^^ 
(W71) 

* CSMmm e»M|«; Tk //VC SeteMtfk AjMSMMf («dilBd by J.T. Ho^^ 



^\ 



55 



U.S. negotiator, State Depanment official Richard Benedick, prowDy revealed in his 1991 book. 
Ozone Diplomacy, oo page 2: "Pcrhayw tbc most extraordinaty aspect of the treaty was its 
iiTq>osition of substantial short-temi economic costs-^against ooproved future dangers— dangers 
dial rested on scientific theories laUier than oa fiim data." Again, on page 18: In Joly 1987, 
practically on the eve of the final negotiating session in Montreal. NOAA concluded that the 
'scientific community is cuneady divided as to whether existing data on ozone trends provides 
soffictenc evidence... that a chlorine-induced ozone destruction is occuniAg." 

Benedick does not mention the fact that, as late as 1988, published evidence on stratoq>beric 
rh lori f K showed no vp^niA trend, tibius indicating that neither CFQs nor other manmade 
chemkals were contriboting significantly to the total— over and above known natural sources like 
volcanoes and oceans. An axticle by MIT professor Ronald Prinn, in a book edited by Prof. 
Sherwood Rowland and puUished in 1988. makes this point quite clear'. 

It is apparent from die above quotes diat the negotiators and their scientific supporters were not 
ct all inhibitBd by the absence of scientific evldeace-or indeed by the presence of contraiy 
infQtxnadon^ 

• Thini, the self-constituted Ozone Trends Panel first announced die existence of global ozone 
depletion in a March 1988 press conference, but did not present Its supporting analysis for review 
until omch latei'. A soidy of die OTP data by two independent American scientists, whidi was 
widely distributed as a prq>rint, showed cleariy that, even after thev thought thev had 
tucoessfullv "tubtracdiwt'' the natural variations by statistical methods, the so-called "depletion 
trend" dq>ended on the choice of time inteival-ie.. die year the analysis starts and ends*. 
Curiously, this result, which shows die dominance of the la^gje (natural) solar-cycle variation of 
ozone, was left otit of a later published paper involving the same authors as collaborators with 



' R. G. Prinn, "How Kne die Al m ospheri e Caaoen&atioas of the Halocnboos Chanted?* in The Chanltit 
Aamphtrt (P. S. Sowiaad and L S. A. laksca, cds.). pp. 33-4S, John Wiley, New Yodc. 1988. 

' In an artkk of i)lBcfa 16. 1995. adeoce editor 11m lUdfoid of ttw Mandwster Gtianfian c^^ 
paafcaatcdatdietiineofibePRitKolMCOdatiooK "..iess.jtliit dte tioie in the osone wodd wipe out life aO 
over die wodd.* S«Kh feais were eaooonged by 'aoAoritative' statoncnts; lUdfiiMd qinles « oC(^ 
HttiaalSdeMePDandaiian, vanity as late as 1989: It's (enUyiag. If these osooe holes knpgpawiiviifaediis. 
Ibeyll eventDtlly eat the wodd.* 

' ILA. Kerr, Stienee 239. pp. 1489^1 (Much 2S, 1988): aa account of the ptess c on gg e n c c and executive 
•nouiiaiy on "dcplelioa' by Ozooe Ttends Ruel. 

* WJ. iM and 1> BislMp. of AJDied<Slgoil Gap.: quoted b S J'. Silver. "WhM OooM Be Qmsi^ 
Oepletk»rfa Qtmalelmpaatf Solar VcfUbOitf (K.H.SdMtientndA.Addns.eds.)NASAPublici<ioo3086. 
1990 



56 



govemmeat scientists^ 



There is also a stUi umcsolved dispute about die quality of the data themselves. The OTP, and 
the sabseqoent UN-sponsored assessment groups, have never grappled with objections published 
by two Belghm researchers in 1992*. These scientists showed that the ozone readings were 
contaminated by air pollution and termed the reponed ozone trend "fictitious." Because of 
simiiar absorption of ultraviolet, de a eases in sulfur dioxide, brought about by reduced industrial 
emissions, were being falsely read as decreases in ozone. 

Global ozone dq;>letion is sdll a controversial subject Starting with the OTP press conference, 
depletion has generally been reported to be "worse than expected." This statement should 
produce tiie logical conclusion that the CFC-ozone theory (on which "expectation" must be based) 
is wrong, or ^ observatioos are wrong, or they are both wrong. 

• FtMBth, another press confiereoce, airasged by NASA on F^tvuary 3, 1992-during crucial 
Congressioaal bearings on the NASA budget and well before the end of the series of strato^heric 
observadons-implied die threat of an Arctic ozone hole. The resulting nationwide scare led the 
Bush WUte House to advance the phaseout of CFCs to December 31. 199S. 

The Arctic ozone hole never hiqipeoed-somediing NASA scientists could have predicted at the 
time of the press conference. Informatioa leaked to a journalist indicated diat NASA scientists 
had midJanuaiy sateDitB data diowing that stratospheric chlorine was already in decline. Yet 
the agency went ahead widi the February 3 press conference and refused to reveal this 
information and allay ptAlic fears until a second NASA press conference tliree months later, on 
April 30^. 

• Fifdi, the "smoldnggun'of ozone depletion activists is, of course, an increasing trend of solar 
nlttaviolet radiation at the eai^'s sorfsce. All of the published evidence before November 1993 
had shown no such trend. Then, a research paper in Science magazine claimed upward trends 



^ ILD. Bojhov. L. Bishop. WJ. KIl. OJC Reinsel. and 0.C liao. 'A ttalistical etad aaalysb of revised tottl 
Dobaon ooMe data owerihe Northern Reni^iiat,' y. (TaopAjir. X<r. 95, 9785-9807. 1990 

*D.DeMiier and H.DeBacker.ltevisioa of 20 years DiAsm Total Ozone Data itf Ucde (Beigluiii): Hciiiioas 
Dotaoo Total Oaono IVends BadBoed by Suite Dioxide IVends,' J. Oteplip. R«s^ Vol 97. p^ S921-S937. April 
20, 199Z They dcaoostnaeltatteDqbaooeMBe meter can aiisimeiprct<KdownwawlttqidcfSO|pol h aio n . 
tiviog rise to a "Iktitioai* ciDaae (rend. TlKir tfai^ wn ooofitned by a tide 9oiq> ^ 
Woriohop oTtfielPOC and dwiDt'lOnneAssessaicnt Panel. Hmtwis. May 17-19.1993 

* R. BaSey, EcoSemu St. Ktetm's hess. 1993, p.120: aad private coouaonication by dK aoAor 

A 



67 



of as much as 35 percent per year-without giving any estimate of the margin of crroi^'. This 
widely touted result, featured in a press release by Science and still being cited by the EPA and 
environmental activist groups, was shown to be completely spurious". The analysis was based 
nn fjinlty statistiw. thr "nmd" wis mo. 

Only later was it learned that the paper had been first submitted to the British scientific journal 
Nature, but had been rejected in the peer-review process. It's still somewhat of a mystery how 
this article passed the review process of Science. 

There is still no evidence for an increased trend of stirface UV to match a putadve ozone 
dq)Ietion trend 

• Finally, there is the Setlow experiment, which demonstrates that malignant melanoma skin 
cancers are mainly caused by a region of the UV spectrum that is not absorbed by ozone and 
therefore not affected by changes in the ozone layer^^ When the EPA is not ignoring this 
result, it is attacking it on the basis that Setlow experimented with fish and that fish are not 
people". (Ironically, the EPA expresses no such qualms when using rats to determine the 
carcinogenicity of chemicals.) In the meantime, the EPA has resisted Congressional requests to 
revise its cost-beoeSit analysis backing the Montreal Protocol, which was based oo the wholly 
unjustified assumption of 3 million additional skin cancer deaths. 

Condurion; 

The bottom line is this: Cnnently available scientific evidence does not support a ban on the 
production of chlorofluorocarbons (CFCs or 6eonsX halons, and especially methyl bromide*^. 
There certainly is no Justification for the accelerated phaseout of CFCs, which was instituted in 
1992 on nodung more than a highly questionable and widely criticized NASA press conference. 
Yet becatise of the absence of full sdendiic debate of the evidence, relying instead on unproven 



'* J.B. Kerr and C.T. McBlioy, "Evideooe for Luft Upward IVends of tJIftaviofet-B Radiadoa Uak«d to Omae 
Depioliao.- Sdetcc M2, 1032-1Q34 (12 Nov. 1993} 

" PJ. Michads, $F. Singer. P.C Knqipeiiberger, * Analyilng olttavioiet-B ladiation: b tfwre a nend? Science 
1*4, pp. 1341^ CZ7 May 1994) 

'* R. Setlow el al 'Wavdeogtfas efibctive in lAduction of malignant meJaaama' Fnc. ffail. Aevd. Set. USA 90. 
«6d64670.Jalyl993 

" Letter firom Paul L. Sto^man, EPA, to Coflgiessmao John DooHttie, dated Nov. 9. 1994 

'^ Par backup aee aoached pat>licaiion: SJ'. Singer. The Obmc^TC Detede: Hasty Aciioa, Shaky Sckace,* 
Tedmohgy: J. FnmkUa ItaOtuu 332A, 61.66, 1995 



58 



theories, we now have an international treaty that will conservatively cost the U.S. economy some 
$100 billion dollars'^. 

The history of the CFC-ozone depletion issue is rife with exan^les of the breakdown of scientific 
integrity: selective use of data, faulty {plication of statistics, disregaid of contraiy evidence, and 
other scientific distortions. The policy before and since the Montreal Protocol has been driven 
by wild and irresponsible scare stories: EPA's estimate of millions of additional sldn cancer 
1 deaths, damage to immune systems, blind sheep in Chile, the woridwide disappearance of frogs, 
plankton death, the collapse of agriculture and ecosystems. 

The latest example of "science by press release" is the scare story about a massive ozone hole, 
fed to die media in Sept 1995 b)r the Geneva-based Worid Meteorological Organization. "At 
its present rate of growth [it] might grow to record-breaking size...." said Riuneo Bojkov, a well- 
known WMO alarmist But then again, it might not-according to NASA scientist Paol Newman. 
Australian meteorologist Paul Lefamann agrees: The hole will change its shape, volunw, and Uze 
daily »a it grows; he concludes that its final size is not predictable by comparing data now with 
those of a year ago. 

These scare stories caitnot pass what I call the common-sense test: A projected 10 percent UV 
iitcrease from a wor^t-case global ozone depletion is the equivalent of moving just 60 miles 
closer to the equator", say from Washington, D.C, to Richmond, Virginia. New Yorkers 
moving to Florida experience a more than 200 percent increase in UV becanse of the change in 
latitude. Why aren't they dropping like flies? Mail-order nurseries in the upper midwest ship 
field'grown plants all over the United States. Why don't these plants die? 

Scientists involved in ozone research have known these facts from the beginning, but only a few 
have acknowledged them puUidy. 



" B. Lkherroan, The High Cost tf Cool', Corapetiiive Enjoprlsc Institote. Wad>ington DC. 1994. He 
estimates (he tcn-ycar cost for US aiuamobiks alooe between $24 and $49 billion. 

** WMO Report "ScieotiSc Assessment of Oxone I>q>Ietion' Global Otone Retearch and Monitoring Frojtel- 
Rep( No. 2S. Wodd Kdet Qrganlzadoo, Geneva CH 1211. 1991 (Fig I MO) 



Tcclmolosy: Journal o/Tlic Franklin Insiiiiiie. Vol. 332A. pp. 61-66. I99S 1072.9240/95 Sj.OO^-.OO 

Princed in ihc USA. All righis rciervcd. Copyrigh( O 199} Cocnizanc Communicacion Corporaiion 



COMMENTARY 

THE OZONE-CFC DEBACLE: HASTY ACTION, SHAKY 
SCIENCE 



encs & EnvirervnantaJ Policy Pro|«cl, Fairfax. VA 



TF 941 1-260 C(Rtccivtd 27 January 1995: oectpud 16 March 1995) 



By iniemacional agreement, (he manufacture of 
chlorofluorocarbons (CPCs) is supposed (o cease in the 
United Stales and most other developed nations by the 
end of 1995. Motorists will face shortages when they try 
to recharge their air conditionen; with the cost for repair 
or retrofit likely in the multi-hundred dollar range; the 
10-y cost for U.S. automobiles is estimated as between 
$24 and 549 billion (1). The U.S. Environmental 
Protection Agency (EPA), anticipating a potential 
consumer revolt, had to persuade a reluctant OuPont 
Corporation to rescind its voluntary commitment to 
close down its production line by the end of 1994 (2). 
(Hoechst AG actually closed down its CFC production 
in Germany on April 16, 1994) 

Yet in spite of the hardships caused by the hasty 
phaseout of CFCs and other suspected ozone-depleting 
halocarbons. the EPA has never questioned the 
adequacy of the science that forms the basis for its 
phaseout policy. The facts are that the scientific 
underpinnings are quite shaky: the data are suspect: the 
statistical analyses are faulty: and the theory has not 
been validated (3,4). The science simply does not 
suppon this premature and abrupt removal of widely 
used chemicals — at great cost to the economy. This fact 
seems finally to have been recognized by legislators: in 
early 1995. Republican Congicssman from Texas, Tom 
Delay, introduced a bill. H.R. 475, to repeal the 
provisions in Title VI of the 1990 Clean Air Act 
regulating the production and use of CFCs. 

If one examines the history of governmental CFC 
policy, one finds that it is based mainly on panicky 
reactions lo press releases from EPA, National 

Tliis paper was pr tpjicd (w ilie sjrnipasjum d rd i raifd lo Oixy L.ee Rjy. For 
reasons beyond Uie contjol 01' the editor it could not appear in the volume 
dedicated to thai topic. 



Aeronautics and Space Administration (NASA), and 
National Oceanographic and Atmospheric 
Administration (NOAA) about skin cancer and possible 
Arctic ozone holes — stimulated and amplified by 
environmental pressure groups and the media — rather 
than on published work that has withstood the scnitiny 
of scientific peers. Credence has been given to EPA 
"estimates" of millions of extra skin cancer deaths, to 
lurid stories about ozone depletion leading to blind 
sheep, to the travails of whales in the Antarctic, and to 
the worldwide disappearance of frogs and toads. It is 
perhaps characteristic of this topic that so many of the 
scary announcements have led off with some statement 
like: "The depletion of ozone is worse than 
expected" — starting with the March 1988 press 
conference by the Ozone Trends Panel (5). Yet since 
"expectation" must be based on theory, the discrepancy 
with observations means, logically, that either the theory 
is wrong or the data are wrong, or both are wrong! 

For the general public, and even for the tiained 
scientist, these scientific controversies are difficult to 
sort out. It is indeed a multi-faceted problem, a chain 
with many links connecting the release of CFCs into the 
atmosphere with the laccurrence of skin cancer. Briefly, 
the steps are postulated as follows (6): 

1 . CFCs with lifetimes of decades and longer become 
well-mixed in the atmosphere, percolate into the 
stratosphere, and there release chlorine. 

2. Chlorine, in its active form, can destroy ozone 
catalyticaily and thereby lower its total amount in the 
stratosphere. 

3. A reduced level of ozone results in an increased level 
of solar ultraviolet radiation reaching the surface of the 
earth. 



60 



S. F. Singer 



4. Exposure lo increased UV leads lo increases in skin 
cancer. 

Each "of these four steps is controversiaj. has not been 
sufficiently substantiated, and may even be incorrect 
(7,8). One can reasonably conclude that policy is 
rushing far ahead of the science. 

SCIENTIFIC UNCERTAINTIES AND 
CONTROVERSIES 

It is generally agreed that natural sources of 
iropospheric chlorine (volcanoes, ocean spray, etc.) are 
four to five orders of magnitude larger than man-made 
sources (9). But it is what gets into the stratosphere that 
counts. The debate has degenerated into arguing about 
how much chlorine is rained out in the lower 
atmosphere (10) rather than measuring whether 
stratospheric chlorine is actually increasing. 

Contrary to the claims of some skeptics, CFCs do 
indeed reach the stratosphere; the secular increase of 
fluorine, in the form of HF, as reponed by Belgian 
researcher R. Zander, may be sufficient proof (1 1,12). 
But as late as 1 987, Zander found no long-term increase 
in HCI, suggesting that stratospheric chlorine comes 
mostly from natural sources, which are not expected to 
increase over time. The situation changed in 1991. 
however, when NASA scientist C. Rinsland published 
data showing HCI increasing at about half the rate of 
HF, suggesting both natural and man-made sources 
(13). Yet the Montreal Protocol to freeze CFC 
production and roll it back to lower levels was signed in 
1987, at a time when published work still indicated 
little, if any, contribution from CFCs. 

(Earlier aircraft- based observations of HCI increases 
between 1978 and 1982 by NCAR researchers Mankin 
and Coffey (14) were used to justify a CFC phaseout, 
even as late as 1993 (15,16), in spite of the fact that 
their data series was judged to be of poor quality and 
too short; according to MIT Professor Prinn, their 
published rate of increase of stratospheric chlorine 
could well be close to zero, in agreement with Zander's 
1987 result (17). In any case, Mankin and Coffey 
themselves ascribe their observed 1982 increase to the 
volcano El Chichon (18) rather than to CFCs). 

The question of global ozone depletion has been 
bedeviled by doubts about the quality of the data. 
Readings from Dobson ground observatories can be 
contaminated by long-term trends in SO, pollution of 
the lower atmosphere. DeMuer and DeBacker have 
demonstrated that the Dobson ozone meter can 
misinterpret the downward trend of SO; pollution, 
civins rise to a •■fictitious" ozone trend (19). (Their 



finding was confirmed by a task group, chaired by 
Robert T. Watson, in a Joint Workshop of the EPCC and 
the International Ozone .^ssessment Panel in May 
1993). 

Another, quite separate problem is produced by the 
extreme noisiness of the ozone record. To establish the 
existence of a small, long-term trend it is necessary to 
eliminate the large natural variations, especially also 
those correlated with the 1 1 -y sunspot cycle. This is an 
impossible task given the shortness of the record and the 
virtual absence of data on long-term variations of the 
solar far-UV radiation that produces ozone in the upper 
atmosphere. The analysis fails a simple lest: The "trend" 
is found to depend strongly on the choice of time 
interval (20). An additional problem in identifying a 
man-made trend arises from long-term trends in sunspot 
number, and therefore long-term ozone trends of natuiTil 
origin (21). 

Thus, the issue of whether the global ozone layer 
shows a steadily depleting trend is still controversial. 
Satellite data on global ozone content are not subject to 
interference from low-altitude pollution, but long-term 
calibration drift presents a problem; the TOMS data 
from satellites appear to have a calibration drift due to 
nonlinearities in the photomultiplier (22). In any case, 
the shonness of the record. 1979 to present, makes the 
solar-cycle correction problematic (23). 

The Antarctic ozone "hole", an annual short-lived 
thinning of the layer first identified in 1985, is a genuine 
phenomenon whose intensity has increased markedly 
since about 1978. Its proximate cause is unquestionably 
stratospheric chlorine, but its fate may be controlled 
more by climate factors and the presence of particulates 
than by the concentration of chlorine itself (24); the hole 
may persist even if the chlorine level were to drop 
below the 1978 value. In any case, no theoretical 
predictions exist that can be tested by future 
observations. 

Nor is the CFC-ozone theory itself in good shape. 
Over the years, its predictions for long-term, global 
ozone depletion have varied widely; during the early 
eighties the National Academy of Sciences published 
values that gradually decreased from 1 8% down to 3%. 
Since the discovery of the ozone hole, there have been 
no funher quantitative predictions published because it 
was recognized that the existing theory could not cope 
with the heterogenous destruction processes that 
depended more on particulate surface area than on the 
level of chlorine (25.26). 

The theory could not describe ozone variations 
caused by the (hetereogenous) reactions on paniculaies 
(volcanic debris, aerosols, etc.) in the lower stratosphere 



61 



Oione-CFC debacle 



and therefore was not able to predict the Antarctic 
ozone hole. In the upper stratosphere, where only 
gas-phase (homogeneous) reactions take place, the 
theory predicts larger changes than are actual ly observed 
(27). 

There is marked disagreement also among the 
satellite ozone data (28): In the upper stratosphere, 
trends seen by the SBUV instrument are negative, while 
SAGE I and n data show slightly positive trend values; 
in the lower stratosphere, SAGE shows much larger 
decreases than SBUV — up to 3%-6%/y in the equatorial 
region, a result that is difficult to explain from CFC 
theory. 

In the lower stratosphere, recent model calculations 
and observations indicate that chlorine-based ozone 
destruction may be rate-limited by the amounts of OH 
and HO; radicals (29,30). If borne out, then increasing 
stratospheric water vapor — as a result of rising 
tropospheric methane from human activities, such as 
cattle raising and rice growing^ould play a significant 
role in ozone chemistry (31). 

CONCERNS ABOUT SKIN CANCER 

The major public concern about a possible depletion 
of ozone comes from the fear that solar UV-B 
(280-320 nm) radiation reaching the surface will 
increase, typically by 10%. Yet UV-B intensity 
increases naturally by about 5000% between pole and 
equator, there is less ozone traversed when the sun is 
closer to the zenith (32). Hence a 10% increase at mid- 
latitudes translates into moving 60 miles (100 km) to the 
south, hardly a source for health concerns. 

There has been, of course, a determined search for a 
secular increase in UV-B to match the presumed 
depletion of ozone. But no such trends had been 
observed (33) until publication in November 1993 of a 
startling increasing trend, between 1989 and 1993. over 
Toronto. Canada (34). Close examination, however, 
revealed that this "smoking gun" was mostly smoke. 
The authors confused a shon-lived increase at the end of 
their record with a long-term trend (35). 

The driving force behind the policy to phase out 
CFCs has always been the fear of skin cancer, 
panicularly malignant melanoma. The EPA has 
predicted 3 million additional skin cancer deaths by the 
year 2075 as a result of ozone depletion (36,37). But 
unlike basal and squamous cell skin cancers, which are 
easily cured growths caused by long-term exposure to 
UV-B. melanoma does not show the same characteristic 
increase towards lower latitudes (38) (Surprisingly, 
European data on melanoma incidence show a reverse 
latitude effect). 



It is clear therefore that the rising incidence of 
melanoma over the past 50 y cannot be due to any 
changes in the ozone layer. Non-melanoma (basal cell 
and squamous cell) skin cancers are clearly linked to 
chronic exposures to UV-B, as judged from the 
increasing incidence towards lower latitudes: melanoma 
exhibits a different epidemiology and often occur on 
areas of the body not chronically exposed to the sun. 
Yet the clear link to solar exposure suggests that 
changes in lifestyle leading to greater exposure to the 
sun may be the main cause of melanoma. 

A breakthrough in our understanding of the 
mechanism of melanoma induction came with the 
experiments of Dr. Richard Setlow and colleagues at the 
Brookhaven National Laboratory. To measure the action 
spectrum of UV radiation for melanoma induction, they 
exposed hybrids of the fish genus Xiphophorus to 
specific wavelengths in the UV-A and UV-B range. The 
animals had been back-cross bred to have only one 
lumor-supprcssor gene; inactivation of this gene in a 
melanoblast or melanocyte then permits the melanoma 
to develop (39). The experimenters found that the action 
spectrum (sensitivity per quantum) was reasonably flat 
across the UV-B and UV-A regions. Because of the 
much greater number of UV-A photons, they conclude 
that 90%-95% of melanomas are caused by UV-A (40). 
But UV-A is not absorbed by ozone at all. and 
therefore melanoma rates would not be affected by 
changes in stratospheric ozone. This imponant finding 
undercuts one of the main reasons for the Montreal 
Protocol and all subsequent regulations (41). 

A final point should be emphasized: If people 
exposed themselves to sunlight using sunscreens that 
merely prevent sunburns (prrxiuced by UV-B), they will 
increase their exposure to melanoma-inducing UV-A 
radiation. While long-term tanning may be somewhat 
ptDtective, episodic or recreational exposures expose 
melanocytes to exceptionally high levels of dangerous 
UV-A (42). The best protection may be clothing or 
avoiding the sun altogether. 

POLICY ACTIONS: DUMPING THE MONTREAL 
PROTOCOL 

The above discussion demonstrates that the scientific 
evidence does not support the Montreal Protocol and all 
subsequent efforts to phase out CFCs, halons. methyl 
bromide, carbon tetrachloride, and other important 
chemicals. Substitutes will surely be found, but much 
testing will be necessary to establish their safety and 
effectiveness (43). Then there is the huge cost, 
estimated at over S200 billion worldwide, of replacing 



62 



S. F. Singer 



capital equipment that cannot accept the substitutes 
(44), plus the as yet unquantified additional costs of 
regulatory uncenaimy, as activists attack many CFC 
substitutes as "ozone-unfriendly" and demand their 
early phaseout. The American public may not take 
kindly to those who are imposing a SI 000 burden on 
every household with no obvious beneTit. It will be 
interesting to see whether the new scientific results, and 
a scrutiny of the older ones, will force also a 
re-examination of existing policies. 

This scrutiny has already begun. California 
Congressman John Doolinle. in an October 18. 1994 
letter to EPA Administrator Carol Browner, suggested 
that EPA revise its 1987 cost-benefit analysis in light of 
the new scientific results on melanoma. In reply, EPA 
seems unwilling to accept Setlow's results until 
confirmed in a mammalian species, and raised various 
other objections. In a private communication to me. 
dated November 29, 1994. Setlow points out that both 
fish and humans have melanocytes that produce the 
pigment melanin, whose absorption of a LTV-A photon 
is presumed to lead to DNA damage within the 
melanocyte cell. In dealing with the other EPA 
objections, Setlow states that "one cannot use 
epidemiological data that relate skin cancer to latitude 
to determine what wavelengths are important in skin 
cancer induction. If the EPA does not understand this 
simple point, it should not be involved in cost-benefit 
analysis." 

Might the U.S. withdraw from the .Montreal 
Protocol? "Scientific evidence indicates that CFCs are 
causing no substantive damage to our atmosphere." 
Congressman DeLay has stated in introducing his bill. 
From his frontal assault on the Clean Air Act it is but a 
short step to call for U.S. withdrawal from the 
international agitement entered into in 1987. ostensibly 
to "protect" the global ozone layer (though at the time 
there was no hard evidence that it needed protecting). 
Withdrawal from the Protocol and canceling the ban on 
CFCs may seem improbable at this late stage, 
however — in view of the physical, political, and 
emotional investments that have been made. _ 
International bureaucrats. federal regulators, 
environmental zealots, and especially chemical 
manufacturers are all counting on governments to 
abolish these chemicals in favor of substitutes that are 
often unproven or nonexistent. 

Yet momentum against Montreal is building. In 
addition to Representatives DeLay and Doolittle, other 
members of Congress, on both sides of the aisle, are 
raising concerns about the precipitous phaseout of CFCs 
ft'reons). fire-fighting bromocarbons (halons). and the 



near-irreplaceable agricultural fumigant methyl 
bromide. The concerns could sky-rocket when 
motorists find themselves without air- 
conditioning — short of paying extortionary prices. 

Less satisfactory than dumping Montreal, but more 
likely as a first step, might be a delay in the phaseout 
date of halocarbons. perhaps returning it to the year 
2000. That was the date in effect in 1992 before 
President Bush advanced the phaseout, stampeded by a 
misleading NASA press conference, which raised fears 
of an "ozone hole over Kennebunkport," and a panicky 
Senate resolution, spearheaded by then-Senator Al 
Gore. Michigan Democrat John Dingell initiated an 
inquiry into the press conference that started it ail, but 
has failed to follow through. Perhaps the time has come 
to complete his investigation into the events of February 
1992. 

The absence of a sufficient scientific base for the 
ozone issue is not yet widely recognized, and a 
halocarbon phaseout is by now well supported by 
entrenched constituencies, including even some 
scientists who have staked their reputation and research 
budgets on this issue. Nevenheless, it is important for 
the future of scientific inquiry to permit free and open 
debate on the shortcomings of the CFC theory and the 
other scientific "facts" that have been used to shore up 
the Montreal policy. This will take time, however, and 
some attention by the Congress. 

The trend in recent years has been towards stifling 
debate by various means: denial of research funds to 
younger academic researchers who hold 
"unconventional" views; the muzzling of senior 
scientists in government service; even the dismissal of 
federal appointees who boldly suggest that theories be 
validated by measurements. It is in this climate of 
intimidation and ad hominem attacks that Congress has 
been vainly trying to get at the facts. Yet with the 
federal research budget for "global change" now at the 
level of $2.1 billion a year — topping even the budget of 
[ihe National Cancer Institute — it should not be too 
lifficuli to find the answers. 

EFERENCES 

1. Lieberman. 8. The high cosi of cool. Washington. DC: 
Competitive Enteiprije Insiilute: 1994. 

2. Zurer. P. Antarctic ozone hole could double in size. Chem. 
Eng. News 69(1): 7; (January 7) 1991. 

.'. S;necr. S. F. Ozone depieiion Chcm. Enc. News 7lf28): 2: 
i/ufv I2» 199) 



Ozone-CFC debacle 



4. Singer. S. F. Ozone deplecion theory. Science 261:1 101: 1993. 

5. Kerr. R. A. Stratospheric ozone is decreasing. Science 
239:1489-1491: 1988. 

6. Rowland. F. S. Chloronuorocaitons. stratospheric ozone, and 
the Antarctic "Ozone Hole". Singer. S. F.. ed. Global Climate 
Change. New York. NY: Paragon House: 1989. 

7. Singer. S. F. Stratospheric ozone: science and policy. Singer. 
S. p.. ed. Global Climate Change. New York, NY: Paragon 
House: 1989. 

8. Singer. S. F. My adventures in the ozone layer. Nat. Rev. 
41(1 1): (June) 1989. 

9. Maduro. R. A.: Schauerhammer. R. The holes in the ozone 
scare. Washington. DC: 21st Century Science Associates: 
1992. 

10 Tabazadch. A.: Turco. R. P. Stratospheric chlorine injection by 
volcanic eruptions: HCL scavenging and implications tor 
ozone. Science 260:1082-1086: 1993. 

11. Zander. R. et al. Monitoring o( the integrated column of 
hydrogen fluoride above the Junglraujoch Station since 
1977— the HF/HCI column ratio. 1. Atmos. Chem. 5:383-394: 
1987. 

12. Zander. R. el al. Column abundance and the long-term trend 
01' hydrogen chloride (HCI) above the Jungi'raujoch Station. 
J. Atmos. Chem. 5:395-404; 1987. 

13. Rinsland. C. P. et al. Infrared measurcmenis of HF and HCI 
total column abundances above Kitt Peak 1977-1990. J. 
Gcophvs. Res. 96(D8): 15523-15540; 1991. 



U. .\lankin. W. G.: Coffey. M. T. Latitudinal distributions and 
temporal changes of stratospheric HCI and HF. 1. Ceophys. 
Res. 88:10776-10784; 1983. 

15. Rowland. F. S. President's lecture: the need for scientific 
communication with the public. Science 260:1571-1576: 
1993. 

16. Rowland. F. S. Letter to Science. Science 261:1 102: 1993. 

1 7. Prinn. R. C. How have the atmospheric concentrations of the 
halocarbons changed? Rowland. F. S.: Isakscn. I. S. A. eds.. 
The Changing Atmosphere. New York: John Wiley. 1988: 33- 
■18. 

1 8. .Mankin W. C.; Coffey. M. T. Increased stratospheric hydrogen 
chloride in the El Chichon cloud. Science 226:170; 1984. 

1 9. DeMuer. 0.: DeBacker. H. Revision of 20 years Oobson total 
ozone data at Uccle (Belgium): fictitious Oobson total ozone 
trends induced by sulfur dioxide trends. 1. Ceophys. Res. 
97:392 1 -3937. 1992. 

20. Singer. S. F. What could be causing global ozone depletion? 
Schatien. K. H.: Arking. A. eds.. Climate impact of solar 
variability. Washington. DC: NASA Publication 3086: 1990. 



21. Angell. 1. K. On the relation between atmospheric ozone and 
sunspot number. J. Clim. 2;I4(M-I4I6: 1989. 

22. McPelers. R. D. el al. Ozone observations and trends, 
presented Dec. 7. 1994 at Fall Meeting of Am. Ceophys. 
Union (Abstracts A32B-2 J.6. pp. 1 24-5). 

23. Herman. I. R. el al. Global average ozone change from 
November 1978 to May 1990. 1. Geophys. Res 
96:17.297-17.305: 1991. 

24. Singer. S. F. Does the Antarctic ozone hole have a future? Eos 
(Transact. Am. Geophys. Union) 69(47); 1588: 1988. 

25. Singer. S. F. Ozone, skin cancer, and the SST. Aerosp. Am 
(AlAA) 32(7); 22-26: (July) 1994. 

26. Newman. P. A.: Wesoky. H.: Singer. S. F. Leners to 
Aerospace America. Aerosp. Am. 33(3); 9-11: (March) 1995. 

27. WMO (World Meteorological Organization) Scientific 
assessment of ozone depletion. Global Ozone Research and 
Monitoring Project. Report No. 25. Geneva; WMO 1991. 

28. Rush. D. W. et al. Comparison of satellite measurements of 
ozone and ozone trends. J. Ceophys. Res. 99:501-1 1: 1994. 

29. Ravishankara, A. R. et al. Do hydrofluorocarbons destroy 
stratospheric ozone? Science 263: 71-75; 1994. 

30. Wennberg. P. O. et al. Removal of stratospheric 0, by radicals: 
in siiu measurements of OH. HO.. NO. NO;. CIO. and BtO. 
Science 266: 398-404: 1994. 

3 1 . Singer. S. F. Stratospheric water vnpour increase due to human 
activities. Nature 223; 543-547; 1971. 

32. WMO (World Meteorological Organization) Scientific 
assessment of ozone depletion. Global Ozone Research and 
Monitoring Project Repon No. 25. Geneva: SVMO 1991: Fig. 
11-10. 

33. Scotto. J. et al. Biologically effective UV radiation: surface 
measurements in the U.S.. 1974-1985. Science 239:762: 1988.. 

34. Kerr. J. B.: McElroy. C. T. Evidence for large upward trends 
of Ultraviolet-B radiation linked to ozone depletion. Science 
262: 1032-1034: 1993. 

35. Michaels. P. J.: Singer. S. F.: Knappenbercer. P. C. Analyzing 
Ultraviolet-B ndiaiion: is theie a trend.' Science 264: 1341-2: 
1994. 

36. USEPA (U.S. Environmental Protection Agency). Protection 
of siratosphenc ozone. Fed. Res. 52: 47486: (December 14) 
1987. 

37. USEPA (U.S. Environmental Protection Agency). An 
assessment of the risks of stratospheric modification. 
Washington. DC: (January) 1987: chap. 7. quoted in Benedick. 
R. E. Ozone diplomacy; new directions in safeguarding the 
planet. Cambridge: Harvard University Press: 1991: 21. 



64 



S. F. Singer 



38. ScDKo. J. e( al. Indications of future decreasine trends in 
skin-melanoma mortality among whites in the United Slates. 
Int. J. Cancer 49: 490; 1991. 

39. Setlow. R. B. Animal model for ultraviolet radiation-induced 
melanoma: Platytlsh-Swordtail hybrid. Proc. Nat. Acad. Sci. 
USA 86: 8922-8926: 1989. 

40. Setlow. R. B. et al. Wavelengths effective in induction of 
malignant melanoma. Pioc. Nat. Acad. Sci. USA 90: 
6666-6670: 1993. 



41. USEPA fU.S. Environmental Protection Agency). Protection 
of stratospheric ozone: final nile. Fed. Reg 5$- 63018' 
(December 10) 1993. 

42. Setlow, R. B.: Woodhead. A. D. Temporal changes in the 
incidence of maiicnant melanoma: explanation from action 
spectra. Mutat. Res. 307:365-374: 1994. 

43. Zurer.' P. Acetic otone levels predicted to decrease. Chem 
Eng. News 70(20): 27: 1992. 

44. Bushee. D. E. CFC phaseout: future problem for air 
conditionine equipment? CRS-Libniry of Congress. Repon for 
Congress 93-2825. April 1993. 



65 

Mr. RoHRABACHER. Dr. Albritton. 

STATEMENT OF DR. DANIEL L. ALBRITTON, DIRECTOR, AER- 
ONOMY LABORATORY, ENVIRONMENTAL RESEARCH LAB- 
ORATORIES, NOAA, BOULDER, CO 

Dr. Albritton. Thank you, Mr. Chairman, Members of the Sub- 
committee. 

My name is Dan Albritton. I'm director of NOAA's Aeronomy 
Laboratory in Boulder, Colorado. 

For over 30 years, our laboratory has studied atmospheric chem- 
istry, including the chemistry of the ozone layer. 

In addition, in the past several years, I've served as co-chair, 
along with my colleague. Dr. Watson, of the Ozone Science Assess- 
ment Panel of the United Nations Environment Program. 

Our job there has been to coordinate the preparation of the sci- 
entific assessments of the world-wide ozone science community. 

In these two capacities, I certainly appreciate the invitation to 
appear before the Subcommittee and to summarize the current un- 
derstanding that the world-wide ozone community has of ozone de- 
pletion. 

Let me underscore right at the outset that the summary that I'm 
about to give you is not my own assessment. It is indeed the state- 
ment of the vast majority of the active and practicing world's ozone 
researchers regarding the current state of understanding of ozone 
depletion based upon their own results and their own laboratories, 
their field observations and their atmospheric monitoring and their 
theoretical modelling. 

As part of the advice to world government's on the ozone layer, 
this ozone community has prepared a series of such state of under- 
standing assessments. 

In 1985, they prepared this summary, which was used as input 
by governments for decisions under the Montreal Protocol in 1987. 

In 1989, they updated their ozone understanding for the discus- 
sions of governments in the London Amendment in 1990. And in 
1991, they updated it further to describe the new findings over the 
last years. Aiid that was input to the Copenhagen Amendments in 
1992. 

And now, as you have already cited, the world science community 
has summarized a current viewpoint on ozone depletion and its ex- 
ecutive summary is the article in the short book that you have as 
part of your package. 

These periodic assessments by the community have been deemed 
to have very high value. They are, first of all, scientific documents. 
They're based upon the published extensive scientific literature 
read by colleagues world-wide. 

Therefore, they are a solid basis for decision-making, in contrast 
to anecdotal statements or privately published viewpoints. 

They are pure science. The community makes no policy rec- 
ommendations. That's the job of others, like yourselves, that are 
entrusted with the public welfare. 

Secondly, these are majority statements. In fact, the very, very 
vast majority. This assessment was prepared by 250 scientists 
world-wide and peer-reviewed by 150 others. 



66 

It's therefore a touchstone of the opinion of the large community. 
This is in contrast to the sporadic and separate statements reflect- 
ing the opinions of either one person or a small group of individ- 
uals. 

Fourthly, it's an international assessment and it draws from the 
world scientific community — all nations, all viewpoints, and there- 
fore, international problems can be addressed on a common playing 
field. 

And finally, the scientific scope is comprehensive. Both the natu- 
ral changes in ozone and the human-induced changes in ozone are 
considered together. And that's much more comprehensive than a 
single statement about a single observation or a single publication. 

Let me indicate to you the four key conclusions from this. And 
I'll do it in a graphical form to supplement the points that my col- 
league. Dr. Watson, mentioned. 

The first point is that very large seasonal depletions of the ozone 
layer continue year after year to be observed in Antarctica. Forty 
years of Antarctic ozone data records show that this began in the 
1970s and has grown larger since then. 

This first chart shows the normal ozone layer as the solid line 
and the dashed line shows what's happened during the ozone hole. 
The hatched area indicates the ozone that's lost over Antarctica 
every year. 

As Dr. Watson mentioned, the cause of this is certain. It's the an- 
thropogenic man-made compounds of chlorine and bromine, in com- 
bination with the special conditions of Antarctica, that has acceler- 
ated the ozone depletion there, in contrast to elsewhere. 

Mr. ROHRABACHER. Dr. Albritton, could I just stop you right 
there for one second? I want to clarify that point. 

Dr. Albritton. Certainly. 

Mr. ROHRABACHER. You're saying that the natural — you just said 
it was caused by man-made. 

Dr. Albritton. That's right. 

Mr. ROHRABACHER. You're suggesting, then, that natural causes 
do not contribute to this? 

Dr. Albritton. Natural causes are not the source of the down- 
ward trend and growing size of the ozone hole year by year. 

Mr. ROHRABACHER. Okay. Thank you. 

Dr. Albritton. The evidence for this are direct observations that 
the ozone-depleting compounds are 100 times larger in Antarctica 
than one would expect without the special conditions of Antarctica 
and the chlorine there. 

Secondly, in every place that these compounds are high, ozone is 
low. 

And thirdly, that these ozone losses and high depleting com- 
pounds appear in the presence of the ice particles that accelerate 
the chlorine effect in Antarctica. 

The second point I wanted to underscore visually with you is that 
ozone depletion continues to be observed by the eye over much of 
the globe. 

The second chart shows how the ozone levels have changed over 
the past 30 years of observations from the ground-based network. 
The top box gives the raw data that these instruments take and 
in that you can see the very clear, reproducible, year-by-year an- 



67 

nual cycle of ozone simply because, like much of the planet, ozone 
depends in part on solar activity. 

The lower panel shows the data after this well-known annual 
cycle and other variations of natural causes like solar activity and 
dynamics have been taken out. 

My point is, regardless of which one you look at, the downward 
trend of the last 15 years is clear. 

The third point that I wanted to underscore with you is that 
when ozone is depleted above, ultraviolet radiation increases at the 
surface. 

The third chart shows data taken over long time periods that in- 
dicate that any time ozone goes down, as you move toward the left, 
that ultraviolet radiation goes up. And those changes are very close 
to what one would expect from the scattering of ultra-violet radi- 
ation and the absorption by ozone. And therefore, it is an absolute 
certainty that if one reduces ozone overhead, you will increase the 
ultra-violet radiation at the surface. 

The final point I wanted to make is looking ahead to the future. 

Point number four. The maximum ozone losses will likely occur 
in the next ten years, and thereafter our ozone layer will slowly re- 
cover. And let me explain what I mean by that. 

This chart shows what has been. It also shows what might have 
occurred. And thirdly, it shows what is now anticipated if compli- 
ance with our international agreements is maintained. 

In particular, solid curve on the left shows the observed and 
measured growth of the ozone depleters since 1950 up until 
present. 

That means the burden of atmospheric chlorine has increased 
four times over the natural levels. If there had been no agreed- 
upon change in the production of those, the upper dotted curve in- 
dicates how chlorine would have grown in the atmosphere had 
there been no Montreal Protocol. 

And finally, the dashed curve on the lower bottom scale on the 
right indicates what one would expect for atmospheric chlorine if 
there is full compliance with agreements that are to date. 

Notice that that recovery is slow, and this is a very crucial 
point — that once placed in the atmosphere, CFCs and other com- 
pounds live a very long time. They outlive us. And therefore, even 
if decisions are made now, the recovery takes a very long time. And 
this indicates the point that if one waits, two larger effects on 
downward ozone trend are observed to take any actions or to have 
reversed actions. 

It implies that the consequences of that will continue well into 
the next century. 

In summary, Mr. Chairman, let me just note that this hearing 
actually began about 20 years ago, when scientists recognized the 
possibility that our own actions could inadvertently effect the ozone 
layer. And over that period, some of the world's brightest and most 
productive atmospheric scientists have sharpened the picture of 
that initial point. 

Several of those scientists are in the U.S. National Academy of 
Sciences because of their ozone research. They have focused on un- 
derstanding that problem and they have focused on telling you and 
others their story based on the world-wide opinion of scientists. 



68 



And so I conclude by noting that while I am speaking for them, 
it is the world-wide ozone research community that you just heard 
from. 

Thank you, sir. 

[The complete prepared statement of Dr. Albritton (and the Exec- 
utive Summary) follow:] 



/^ TESTIMONY OF \ 

( nttjr>/^vrF.T. t. AT.HR mroN 

DIRECTOR, AERONOMY LABORATORY 

ENVIRONMENTAL RESEARCH LABORATORIES 

NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION 

U. S. DEPARTMENT OF COMMERCE 

BEFORE THE 

SUBCOMMITTEE ON ENERGY AND ENVIRONMENT 
COMMITTEE ON SCIENCE 



20 SEPTEMBER 1995 



Mr. Cfaainnan and Members of the Subcommittee: 

My name is Dan Albritton. In brief, I am Director of NCAA's Aeronomy Laboratory 
in Boulder, Colorado, which studies the cheanistiy and dynamics of the Earth's atmosphere. 
I am also Cochair, along with Dr. Robert Watson (USA) and Dr. Piet Aucamp (South 
Afiica), of the Ozone Science Assessment Panel of the United Nations Environment 
Programme, which provides scientific input to the Montreal Protocol on Substances that 
Deplete the Ozone Layer. In these two capacities, I appreciate this opportunity to appear 
before your Subcommittee to discuss the scicntiiic understanding of stratospheric ozone 
depletion. 

As you requested, I will focus this testimony on the scientific understanding of the 
ozone layer and of the impact of human activities on it. This text will summarize three 
aspects. (1) the series of scientific assessments that the world ozone research commimity 
has made of the state of that understanding. (2) the key points of the current scientific 
understanding of the ozone layer that were described in the most recent of those assessment 
reports, and (3) answers to common questions about ozone that were prepared as part of the 
"Scientific Assessment of Ozone Depletion: 1994". 



L SCIENTIFIC ASSESSMENTS BY THE WORLD RESEARCH COMMUNITY 

In 1994, the worldwide ozone-science research community prepared the seventh in their 
series of assessments of the scientific vmdcrstanding of ^e Earth's ozone layer and its 



70 



relation to hiwnanlfinH - "Scientific Assessment of Ozone Depletion: 1994", pp. 580. (Copies 
are available for the Subcommittee members, if desired.) This as.ses«mient report vsdll be 
part of the information \xpoa. which the Parties to the United Nations Montreal Protocol will 
base dieir fixture decisions regarding protection of the stratospheric ozone layer. There are 
two companion reports to this scientific assessment They focus on (i) the environmental' 
and heal^ effects of ozone layer depiction and on (ii) the technology and economic 
iii^>lications of mitigation approaches. 

This series of scientific reports prepared by the world's leading experts in the 
atmospheric sciences under the intematioiuil auspices of the World Meteorological 
Organization (WMO) and the United Nations Environment Programme (UNEP) are listed 
below. The chronology of those scientific assessments aitd the relation to the international 
policy process are summarized as follows: 

Scientific Assessment 

'The Stratosphere 1981 Theory and 

Measuremems". WMO No. 11. 
"Atmospheric Ozone 1985". 3 vol. 

WMO No. 16. 



Year 
1981 


Policv Process 


1985 


Vienna Convention 


1987 


Montreal Protocol 


1988 





1989 

1990 
1991 

1992 

1992 
1994 



London Amendment 



Copenhagen Amendment 



"Internationa] Ozone Trends Panel Report 1988" 

2 vol. WMO No. 18. 

"Scientific Assessment of Stratospheric Ozone: 

1989". 2 vol. WMO No. 20. 



"Scientific Assessment of Ozone Depletion: 

1991". WMO No. 25. 

"Methyl Bromide: Its Atmospheric Science, 

Technology, and Economics" (Assessment 
Supplement). UNEP (1992). 

"Scientific Assessment of Ozone Depletion: 
1994". WMO No. 37. 



(1995) Vienna Amendment (?) 



71 



The genesis of Scientific Assesanent of Ozone Depletion: 1994" occuned at the Fourth 
meeting of the Conference of die Parties to the Montreal Protocol in Copenhagen, 
Denmark, in November 1992, at which the scope of the scientific needs of the Parties Nv-as 
defined. The formal planning of the present report was a workshop m 1993 at which an 
intertiationa] steering group crafted the outline and suggested scientists from the world 
community to serve as authors. The first drafts of the ch^ters were examined at a 
meeting in early 1994 at which the authors and a small number of international experts 
improved the coordination of the text of the chapters. 

The second draft was sent out to 123 scientists worldwide for a mail peer review. 
These anonymous comments v«re considered by the authors. At a meeting in Switzerland 
during the summer of 1994, the responses to these mail review comments were proposed by 
the authors and discussed t^ the 80 participants. Final changes to the chapters were 
decided i^ion, and the Executive Summary was prepared by the participants. The ^oup 
also focused on a set of questions commonly asked about the ozone layer. Based upoa the 
scientific understanding represented by the assessments, answers to these common questions 
were prepared. 

As the report documents, the "Scientific Assessment of Ozone Depletion: 1994" is the 
product of 29$ scientists firom 36 countries, rqvesenting the developed and developing 
world, who contributed to its preparation and review (230 scientists prqiared the report and 
147 scientists participated in tlie peer review process). What follows in this testimony is a 
summary firom the report of their current understanding of the stratospheric ozone layer and 
its relation to humankind. 

While the "Scientific Assessment of Ozone Depletion: 1994' is a scientific document, 
its value to decision makers is considerable. The reasons for this arc several fold: 

o It is strong single concise statement from the large majority of the atone sclent^ 
community. In the assessment, the magor representatives of the ozone research community 
speak at one time and one place r^arding the current understanding of ozone depletion. 
The report, djctefore, is a c^nmon reference point for decision makers, in contrast to 
sporadic and separate statements reflecting the opinions of one person or a few individuals. 

o It is an international scientific assessment. With it, all nations have a common basis of 
scientific input for their decision making, as opposed to several national statements. 
Vi^iere appropriate, scientists &om developing countries are involved in preparing the 
assessment to the fullest extent possible. 

o The scientific scope is comprehensive. With the report, decis ion makers have available 



72 



a single, homogeneous sununaiy of the current scientific understanding of the whole ozone- 
change phenomenon, ranging from the agents that cause change to the ozone-layer 
responses. This is more uscfiil than separate reviews of components of the phenomenon 
done at dififercnt times and perhaps for different purposes. 

Both natural and human-Induced ozone-layer changes are considered In contrast to 
considering only the perturbation of the ozone layer by human activities, the assessmert 
places that human-induced change in the context of the observed and predicted changes 
thai are a natural part of the ozone layer. The comparison of the two affords immediate 
and straightforward insight into the significance of the human-induced perturbations relative 
to the natural variations. 



73 



XL RECENT MAJOR SdENTIFIC FINDINGS AND OBSERVATIONS 

The laboratory mvestigations, atmospheric observations, and theoretical and modeling 
studies of the past few years have provided a deeper understanding of the human-influenced 
and natural chemical changes in the atmosphere and their relation to the Earth's 
stratospheric ozone layer and radiative balance of the climate system. The "Scientific 
Assessment of Ozone Depletion; 1994" reported several key ozone-related findings, 
observations, and conclusions and are the basis for the points summarized below. 

Changes in Ozone-Dq>lcting Gases 

; o The atmospheric growth rales of several major ozone^iepUting substances have slowed, 
derrtonstrating the expected impact of the Montreal Protocol and its Amendments and 
Adjustments. The abundances of the human-produced chlorofluorocarbons (CFCs), carbon 
tecrachloricic, methyl chloroform, and halons in the atmosphere have been monitored at 
global ground-based sites since about 1978. Over much of that period, the annual growth 
rates of these gases have been positive. However, the data of recent years clearly show that 
the growth rates of CFC-ll, CFC-12, halon-1301, and halon-1211 are slowing down. The 
abundance of carbon tetrachloride is actually decreasing. The observed trends in total of 
these chlorine-containing compounds are consistent with reported production data, 
suggesting less emission than the TTWYinmim allowed under the Montreal Protocol and its 
Amendments and Adjustments. Peak statospheric tot^ chlorine/ bromine loading in the 
troposphere, most of which is human-produced, is expected to occur in 1994, but the peak 
in tbe stratospheric will lag by about 3-5 years. Since the stratospheric abundances of 
chlorine and bromine arc expected to continue to grow for a few miore years, increasing 
global ozone losses are predicted (other things being equal) for the remainder of the decade, 
with gradual recovery in the 21st century. 

o The atmospheric abundances of several of the CFC substitutes are increasing, as antidpatexi 
With phaseout dates for the CFCs and other ozone-depleting substances now fixed by 
international acgirrments, several Kydrochlorofluorocarbons (HCFCs) and 
hydrofluorocarbons (HFCs) are being manu£uxured and used as subsritutes. The 
atmospheric growth of some of these compounds (e.g., HCFC-22) has been observed now 
for several years. 

o Methyl bromide continues to be viewed as a significant ozonedepleting compound 
Increased attention has been focused upon the ozone-depleting role of methyl bromide. 
Three potentially major anthropogenic sources of atmospheric methyl bromide have been 
jHfnfififd (soil fumigarion, biomass burning, and the exhaust of automobiles tising leaded 



74 



gasoline), in aiidicion to the natural oceanic source. Wkile the magmtude of the 
atmospheric photochemical removal is well understood, there are significant uncertainties 
in quantifying the oceanic sink for atmospheric methyl bromide. The Ozone Depletion 
' Potential (ODP) for methyl bromide is calculated to be about 0.6 (relative to an ODP of 1 
for CFC-U). 

' Changes in Midlatitude and Equatorial Ozone Abundance 

o Downward trends in total<olumn ozone continue to be observed over much of the globe, 
and their magnitudes are larger than those predicted by numerical ozone-loss models. Decreases 
in ozone abundances of about 4 - 5% per decade at midlatitudes in the Northern and 
Southern Hemispheres continue to be observed by both ground-based and satellite-borne 
monitoring instruments. At midlarintdrt, the losses continue to be miich larger during 
winter/spring than during summer/^ in both hemispheres, and the depletion increases 
with latitTjde, particularly in the Southern Hemisphere. Little or no downward trends are 
observed in the tropics (20#N - 20#S). While the current two-Himrnsiooal stratospheric 
models simulate the observed trends quite weU during some seasons and latitiides, they 
imderestimate the trends by factors of up to three in winter/spring at mid- and high 
latitudes. Several known atmospheric processes that involve chlorine and bromine and that 
affect ozone in the lower stratosphere are difficult to model and have not been adequately 
incorporated into these models. 

o Record low global ozone levels were measured over the past two years. Anomalous ozone 
decreases were observed in the midlatitudes of both hemispheres in 1992 and 1993. The 
Northern Hemispheric decreases were larger than those in the Southern Hemisphere. 
Globally, ozone values were 1 - 2% lower than would be cxpeaed from an extrapolation of 
the trend prior to 1991, allowing for solar-cycle and periodic meteorological effects. The 
1994 global oz6^ levels are returning to values closer to those expected from the longer- 
term downward trend. 

o The stratosphere was temporarily perturbed by a mapr volcanic eruption. The eruption of 
Mt. Pinatubo in 1991 led to a large increase in sulfate aerosol in the lower stratosphere 
throughout the globe. Reactions on sulfate aerosols resuhed in significant, but temporary, 
changes in the cbcmiral pardtioning that accelerated the photochemical ozone loss 
associated with reactive hydrogen, chlorine, and bromine compounds in the lower 
stratosphere in midlatitudes and polar regions. These and other recent scientific findings 
strengthen the conclusion of the previous assessment that the weight of scientific evidence 
suggests that the observed taiddie- and high-laritude ozone losses are largely due to 



75 



anthropogenic chlorine and bromine compounds. The observed 1994 recovery of global 
ozone is qualitatively consistent with observed gradual rediictions of the abundances of 
these volcanic particles in the stratosphere. 

Changes in Polar Ozone 

o The Antarctic ozone "holes" of 1992 and 1993 were the most severe on record. The 
Antarctic ozone "hole" has continued to occur seasonally every year since its advent in the 
late-1970s, with the occurrences over the last several years being particularly pronounced. 
Satellite, balloon-borne, and ground-based monitoring instruments revealed that the 
Antarctic ozone "holes" of 1992 and 1993 were the biggest (arcal extent) and deepest 
( rpipipn 'yn amounts of ozone overhead), with ozone being locally depleted by more than 
99% between about 14 - 19 kilometers in Oaober, 1992 and 1993. It is likely that these 
larger-than-usual ozone depletions could be attributed, at least in part, to sulfate aerosols 
from Mt. Pinatubo increasing the effectiveness of chlorine- and bromine-catalyzed ozone 
destruaion. A substantial Antarctic ozone "hole' is expcaed to occur each austral spring 
for many more decades because stratospheric chlorine and bromine abundances will 
approach the pre-AntarctioK)zone-"hole' leveb (late- 1970s) very slowly during the next 
century. 

o The conclusion that human-produced Marine and bromine compounds, coupled with surface 
chemistry on natural polar strazospheric particles, are the cause of polar ozone depletion has 
been furxher strengthened Laboratory studies have provided a greatly improved 
understanding of how the chemistry on the surfaces of ice, nitrate, and sulfate particles can 
increase the abundance of ozone-depleting forms of chlorine in the polar stratospheres. 
FurtherxDore, satellite and in situ observations of the abundances of reactive nitrogen and 
chlorine compounds have improved the explanation of the different ozone-altering 
properties of the Antarctic and Arctic 

o Ozone losses have been detected in the Arctic winter stratosphere, and their links, to chlorine 
and bromine chemistry have been established Studies in the Arctic lower stratosphere have 
been expanded to include more widespread observauons of ozone and key reactive species. 
In the late-wtnter/early-spring period, additional chemical losses of ozone up to 15 - 20% at 
some aktcudes are deduced from these observations, particularly in the winters of 1991/2 
and 1992/3. Model calculations constrained by the observations arc also consistent with 
these losses, increasing the confidence in the role of chlorine and bromine in ozone 
destruction. The inteiannual variability in the photochemical and dynamical conditions of 
the Arctic polar voncx continues to limit the ability to predia ozone changes in future 



76 



years. 

Ozone Depletion and Radiation 

o The link between a decrease in stratospheric ozone and cm increase in surface ultraviolet 
(UV) raSation has been further strengthened. Measurements of UV radiation at the surface 
under clear-aky conditions show that low overhead ozone yields high UV radiation and in 
the anjoiint prediaed by radiaiive-inmsfer theory. Large increases of stirface UV are 
observed in Antaraica and the southern part of South America during the period of the 
seasonal ozone "hole." Fmthermore, elevated surface UV levels at mid-to-high latitudes 
were observed in the Northern Hemisphere in 1992 and 1993, corresponding to the low 
ozone levels of those years. However, the lack of a decadal (or longer) record of accurate 
monitoring of surface UV levels and the variation introduced by clouds and other faaors 
have precluded the unequivocal identification of a long-term trend in surface UV radiation. 

o ■ Stratospheric ozone losses cause a ghbaltnean negative radiative forcing of the dimate 
system. In the 1991 scientific assessment, it was pointed out that the global ozone losses 
that were occurring in the lower stratosphere caused this region to cool and result in less 
radiation reaching the surface-troposphere system. Recent model studies have strengthened 
this picture. A long-term global-mean cooling of the lower stratosphere of between 0.25 
and 0.4 degrees Celsiijs per decide has been observed over the last three decades. 
Calculations indicate that, on a global mean, the ozone losses between the 1980 and 1990 
offect about 20% of the radiative forcing due to the wcU-mixing greenhouse-gas bcrcases 
during that period (i.e., carbon dioxide, methane, nitrous oxide, and halocarbons). 

Future Ozone Changes 

The research findings of the past few years that are summarized above have several 
major implicadons as scientific input to governmental, industnai, and other choices 
re^uding hunuui-infhicnced substances that lead to depletion of the stratospheric ozone 
layer and to changes of the radiative forcing of the climate system: 

o The Montreal Protocol arid its Amendments and Adjustments are reducing the impact of 
anthropogenic halocarbons on the ozone layer and should eventually elimirtate this ozone 
depletion. Based on assumed compliance with the amended Montreal Protocol 
(Copenhagen, 1992) by all nations, the stratospheric chlorine abundances will continue to 
grow from their current levels to a peak, around the turn of the century. The future total 
bromine loading will depend upon choices made regarding future human producaon and 
emissions of methyl bromide. After around the turn of the century, the levels of 
stratospheric chlorine and bromine will begin a decrease that will continue into the 21$t 



77 



aiui 7?n^ cencuries. The rate of decline is dictated by the long residence times of the 
CFCs, carbon tetrachloride, and halons. Global ozone losses and the Antarctic ozone 
"hole" were first discernible in the late 1970s and are prediaed to recover in about the year 
2045, other things being equal. The recovery of the ozone layer would have been 
impossible without the Amendments and Adjustments to the orig^al Protocol (Montreal, 
1987). 

o Peak gU>bal ozone losses are expected to occur during the next several yean. The ozone 
layer will be most affected by human-influenced perturbations and susceptible to natural 
variations in the period around the year 1998, since the peak stratospheric chlorine and 
bromine abundances are expected to occur then. Based on extrapolation of current trends, 
observations suggest that the maximum ozone loss, relative to the late 196Qs, will likely 
be: 

(i) about 12 - 13% ai Northern midlaticudes in winter/spring (i^., about 2.5% above 
current levels); 

(ii) about 6 - 7% at Northern midlatitudes in summer/fall (i.e., about 1,5% above 
current levels); and 

(iii)about 11% (with less certainty) at Southern nudlatitudes on a year-round basis (Le., 
about 2.5% above current levels). 

Stich changes would be accompanied by 15%, 8%, and 13% increases, respectively, in 
surface erythemal radiation, if other influences such as clouds remain constant. Moreover, 
if there were to be a major volcanic eruption like that of Mt. Pinatubo, or if an extremely 
cold and persistent Arctic winter were to occur, then the ozone losses and UV increases 
could be larger in individual years. 

o Approaches to lowering stratospheric chlorine and bromine abundances are limited. 
Further controls on ozone-depleting substances would not be expected to significantly 
change the fi pi i ng or the magnitude of the peak stratospheric halocarbon abundances and 
hence peak ozone loss. However, there are four approaches that would steepen the initial 
fall from the peak halocarbon levels in the early decades of the next century: 

(i) If emissions of methyl bromide from agricultural, structural, and industrial activities 
were to be elisoiiuted in the year 2001, then the integrated effective futiire chlorine loading 
above the 1980 level (which is related to the cumulative future loss of ozone) is prediaed 
to be 13% less over the next 50 years relative to full compliance to the Amendments and 
Adjustments to the Protocol. 

^ If emissions of HCFCs were to be totally eliminated by the year 2004, then the 
integraced effective future chlorine loading above the 1980 level is predicted to be 5% less 
over the next 50 years relative to full compliance with the Amendments and Adjustsoents 
to the Protocol 

Qii)If halons preseiuly contained in existing equipment were never released to the 



78 



azmosphere, then the integrated effeaive future chlorine loading above the 1980 level is 
prediaed to be 10% less over the next 50 years relative to full compliance with the 
Amendments and Adjustments to the Protocol. 

pv) If CFCs presently contained in existing equipment were never released to the 
atmosphere, then the integrated effective future chlorine loading above the 1980 level is 
prediaed to be 3% less over the nea 50 years relative to full compliance with the 
Amendments and Adjustments to the Protocol. 

o Failure to tuihtre to the intfmaiiorud agreements trill delay recovery of the ozone layer, li 
. there were to. be additional production of CFCs at 20% of 1992 levels for each year 
through 2002 and ramped to zero by 2005 (beyond that allowed for coimtries operating 
tinder Article 5 of the Montreal Protocol), then the integrated effective future chlorine 
loading above the 1980 level is predicted to be 9% more over the next 50 years relative to 
full compliance to the Amendments and Adjustments to the Protocol. 

p Many of the substitutes for the CFCs and halons are also notable greenhouse gases. Several 
CFG and halon substitutes arc not addressed under the Montreal Protocol (because they do 
not deplete ozone), but, because they are greenhouse gases, fall under the purview of the 
Framework Convention on Climate Change. There \s a wide range of values for the 
Global Warming Potentials (GWPs) of the HFCs (150 - 10000), with about half of them 
having values comparable to the ozone-depleting compounds they replace. The 
perfluorinated compounds, some of which are being considered as substitutes, have very 
large GWPs (e.g., 5000 - 10000). These are examples of compounds whose current 
atmospheric abundances are relatively small, but are increasing or could increase in the 
future. 

o Consideration of the ozone thattge will be one necessary ingredient in ttnderstanding climate 
change. The extent of our ability to attribute any r\imite change to specific causes will 
likely prove to be important scifntifir input to decisions regarding predicted human- 
inducttl ?nflii^n/-i»t on the rMm^tt' system. Changes in ozone since pre-industrial times as a 
result of human activity are believed to b«ve been a significant inflnmrr on radiative 
forcing; this human influence is t-rprrtfA to continue into the foreseeable future. 



m. COMMON QUESTIONS RAISED ABOUT THE OZONE LAYER 

The above points «nmman'y«> the current scientific undemanding of the ozone layer and 
Its deletion by human-produced cfaenicab. But often more-general questions arise - for 
OBtapit, by the public - aboot this environmental issue. The "Scientific Assessment of 
Ozone Dq>letioas: 1994* also addressed the information needs of this aodienoe by 

10 



79 



including a set of common questions about ozone, with answers by the scientific 
community prepared for a general readership. This section of the assessment report is 
attached (without figures) as Aimex 1 to chis testimony. 

Mr. Chairman, this concludes my prepared text. I would be pleased to answer any 
questions that you or the Subcommittee may have. 



. 11 



80 



ANNEX 1. COMMON QUESTIONS ABOUT OZONE 

Ozone is exceedingly rare in our atmosphere, averaging abom 3 molecules of ozone for 
every ten million air molecules. Nonetheless, atmospheric ozone plays vital roles that 
belie its small numbers. This Appendix to the "World Meteorological 
OrganizaiionAJnited Nations Environment Programme (WMO/UNEP) "Scientific 
Assessment of Ozone Depletion: 1994* answers some of the questions that are most 
commonly asked about ozone and the changes thai have been occurring in recent years. 
These common questions and their answers were discussed by the 80 scientists from 26 
countries who participated in the Panel Review Meeting of the "Scientific Assessment of 
Ozone Dq>lction: 1994." Therefore, this information is presented by a large group of 
experts from the international scientific community. 

Ozone is mainly foiind in two regions of the Earth's atmosphere. Most ozone (about 
90%) resides in a layer between approximately 10 and 50 kilometers (about 6 to 30 miles) 
above the Eanh's surface, in the region of the atmosphere called the stratosphere. This 
stratospheric ozone is commonly known as the 'ozone layer." The remaining ozone is in 
the lower region of the atmosphere, the troposphere, which extends from the Earth's 
surface up to about 10 kilometers. 

"While the ozone in these two regions is chemically identical (both consist of three 
oxygen atoms and have the chemical formula "Oj"), the ozone molecules have very 
different effects on humans and other living things depending upon their location. 

Stratospheric ozone plays a beneficial role by absorbing most of the biologically 
damaging ultraviolet sxmlight called UV-B, allowing only a small amount to reach the 
Earth's surface. The absorption of UV radiation by ozone creates a source of heat, which 
actually forms the stratosphere itself (a region in which the temperature rises as one goes to 
higher altitudes). Ozone thus plays a key role in the temperature structure of the Earth's 
atmosphere. Furthermore, without the filtering aaion of the ozone layer, more of the 
Sun's UV-B iiuliation would penetrate the atmosphere and would reach the Earth's surface 
in greater amounts. Many experimental studies of plants and animals, and clinical studies 
of hiu:ians, have shown the harmful effects of excessive exposure to UY-B radiation (these 
are discussed in the WMO/UNEP reports on impacts of ozone depletion, which are 
companion documents to the WMO/UNEP scientific assessments of ozone depletion). 

At the planet's surface, ozone comes into direct contact with life-forms and displays its 
destructive side. Because ozone reacts strongly with other molecules, high levels are toxic 
to living systems and can severely damage the tissues of plants and animals. Many studies 
have documented the harmful effects of ozone on crop production, forest growth, and 

12 



81 



. iiunun licalrh. The substantial negative effeas of sxir^ce-level tropospheric ozone from 
tbis (iiroct toxiocy contrast with the benefits of the additional filtering of UV-B radiation 
that it provides. 

With these dual aspects of ozone come two separate environmental issues, controlled by 
' different forces in the atmosphere. In the troposphere, there is concern about increases in 
ozone.' Low-lying ozone \s a key component of smog, a familiar problem in the 
atmosphere of many cit i e s around the world. Higher than usual amounts of sur^u^level 
ozone are now increasingly being observed in rural areas as welL However, the ground- 
level ozone concentrations in the smoggicst cities are very much smaller than the 
ooncentrations routinely found in the stratosphere. 

There is widespread scientific and public interest and concern about losses of 
stratocpfaeric ozone. Ground-based and satellite instruments have measured decreases in the 
amount of stratospheric ozone in our atmosphere. Over some parts of Antarctica, \xp to 
60% of the total overhead amount of ozone ^own as the "column ozone') is depleted 
during September and Oaober. This phenomenon has come to be known as the Antarctic 
'ozone hole." Smaller, but still sigaificant, stratospheric decreases have been seen at other, 
more-populated regions of the Earth. Increases in sur6ux UV-B radiauon have been 
observed in associaiion with decreases in stratospheric ozone. 

The scientific evidence, accumulated over more than two decades of study by the 
intemarional research commuoity, has shown that human-made chemicals are responsible 
for the observed depletions of the ozone layer over Antarctica and likely play a major role 
in ^bal ozone losses. The ozone-deleting compounds contain various combinations of 
the chrmical elements chlorine, fluorine, bromine, carbon, and hydrogen, and are often 
described by the general term halocttrb&ns. The compounds that contain only carbon, 
chlorine, and .fluorine are called chhnfluorocarhons, usually abbreviated as CFO. CFCs, 
carbon tetrachloride, and methyl chloroform are important human-made ozone-depleting 
gases that have been used in many applications ioduding refrigeration, air conditioning, 
foam blowing, cleaning of electronics components, and as solvents. Another important 
group of human-made halocarbons is the hdlons, which contain carbon, bromine, fluorine, 
and (fa some cases) chlorine, and have been mainly used as fire extinguisbants. 
Govemmenu have decided to discontinue production of CFCs, halons, carbon 
tetrachloride, and methyl chloroform, and industry has developed more 'ozone-friendly* 
substitutes. 

Two responses are natural when a new problem has been identified: cure and 
prevention. When the problem is the destruction of the stratospheric ozone layer, the 
corresponding quesuons are: Can we repair the damage already done? How can we 

13 



82 



prevent further desmiction? Remedies have been investigated that could (I) remove CFCs 
selectively from our atmosphere, (li) intercept ozone-depledng chlorine before much 
depletion has taken place, or (til) replace the ozone lost in the stratosphere (perhaps by 
shippii^ the ozone from cities that have too much smog or by malfi'ng new ozone). 
Because ozone reacts strongly with other molecules, as noted above, it is too unstable to be 
made elsewhere (e.g., in the smog of cities) and transported to the stratosphere. When the 
huge volume of the Earth's atmosphere and the magnitude of global stratospheric ozone 
depletion are carefully considered, approaches to cures quickly become much too 
expensive, impractical, and potentially damaging to the global environment. Prevention 
involves the tntemationally agreed-upon Montreal Protocol and its Amendments and 
Adjustments, which call for elimination of the production and use of the CFCs and other 
ozone-damaging compounds within the next few years. As a rcsuh, the ozone layer is 
expected to recover over the next fifty years or so as the atmospheric concentrations of 
CFCs and other ozone-depledng compounds slowly decay. 

The current understanding of ozone dq>leTion and its relation to humankind is 
discussed in detail by the leading scientists in the world's ozone research commxmity in the 
ScUm^ Assessment ofOzont Dtple^on: 1994. The answers to the common questions posed 
below are based upon that understanding and on the information given in earlier 
WMOAJNEP reports. 



How Can Chlorofluorocarbons (CFCs) Ge( to the Strazosphere If They're Heavier than Aiii 

Although the CFC molecules are indeed several times heavier than air, thousands of 
measurements have been made from balloons, aircraft, and satellites demonstrating that the 
CFCs are actually present in the stratosphere. The atmosphere is not st^^ant. Winds mix 
the atmosphere to altitudes far above the top of the stratosphere much faster than 
molecules can settle according to their weight. Gases such as CFCs that are insoluble in 
water and relatively tmrcaciive in the lower atmosphere (below about 10 km) are quickly 
mJYfd and therefore reach the stratosphere regardless of their weight. 

Mtich can be learned about the atmospheric fate of compounds from the measured 
dianga in concentration versus altitude. For nrample, the two gases carbon tetrafluoride 
(CF^, produced mainly as a by-product of the manufacture of aluminum) and CFC-11 
(CCljF, used in a variety of human aoivities) are both much heavier than air. Carbon 
tetrafluoride is completely unreactive in the lower 99.9% of the atmosphere, and 
measurements show it to be nearly uniformly distributed throughout the atmosphere as 
shown in the figure. There hav« also been measurements over the post two d et ade s of 
several other completely unreactive gases, one lighter than air (neon) and some heavier than 

14 



83 



air (argon, krypton), which show that they also mix upward uniformly through the 
stratosphere reganlless of their weight, just as observed with carbon tetrafiuoride. CFC-11 
is unreactive in the lower atmosphere (below about 15 km) and is similarly uniformly 
mixed there, as shown. The abundance of CFC-11 decreases as the gas reaches higher 
altitudes, where it is broken down by high energy solar ultraviolet radiation. Chlorine 
released from this breakdown of CFC-11 and other CFCs remains in the stratosphere for 
several years, where it destroys many thousands of molecules of ozone. 



Vf'hat is the Evidence that Stratospheric Ozone is Destroyed by Chlorine and Brvminef 

Laboratory studies show that chlorine (CI) reacts very n^idly with ozone. They also 
show that the reactive chemical chlorine oxide (CIO) formed in that reaaion can undergo 
further processes which regenerate the original chlorine, allowing the sequence to be 
riq>eated very many times (a "chain reaction"). Similar reactions also take place between 
bromine and ozone. 

But do these ozone^iestroying reactions occur in the real world? All of our accumulated 
scientific experience demonstrates that if the conditions of temperature and pressure arc 
like those in the laboratory studies, the same chemical reactions will cake pLce in nature. 
However, many other reactions including those of other chemical species are often also 
taking place simultaneously in the stratosphere, making the connections among the changes 
difiicult to untangle. Nevertheless, whenever chlorine (or bromine) and ozone are found 
together in the stratosphere, the ozone-destroying reaaions must be taking place. 

Sometimes a small number of chemical reactions is so important in the natural 
circumstance that the connections are almost as clear as in laboratory experiments. Such a 
sitxiation occurs in the Antarctic stratosphere duuing the springtime fonnation of the ozone 
hole. During August and September 19S7 - the end of winter and beginning of spring in 
the Southern Hemisphere - aircraft equipped with many different initmments for 
measuring a large number of chemical species were flown repeatedly over Antarctica. 
Among the chemicals measured were ozone and chlorine onde, the reactive chemical 
identiHed in the laboratory as one of the participants in the ozone-destroying chain 
reacaons. On the first fi'^^f^ southward imm the southern tip of South America, 
relatively high concentrations of ozone were measured cveiywhere over Antarctica. By 
mid-September, however, the instruments recorded low conoentratiotu of ozone in regions 
where there were high concentrazioiu of chlorine oxide and vice versa, as shown in the 
figure. Flights later in Sq>tcmber showed even less ozone over Antarctica, as the chlorine 
continued to react with the strato^heric ozone. 



15 



84 



Independent measuremenis made by these and other instruments on this and other 
airplanes, from the grotind, from balloons, and from satellites have provided a detailed 
understanding of the chemical reaaions going on in the Anurcdc stratosphere. Regions 
with high concentrations of reactive chlorine reach temperatures so cold (less than 
approximately -80*C, or -112*F) that stratospheric clouds form, a rare occurrence except 
during the polar winters. These clouds facilirare other chemical reactions that allow the 
release of chlorine in sunlight. The chrmical reaaions related to the clouds are now well 
iwdeistood through study under laboratory conditions mimirWing those found naturally. 
Scientists are working to understand the role of such reactions of chlorine and bromine at 
other latitudes, and the involvement of panicles of sulfuric add from volcanoes or other 



Does Mou of the 0}UfTint in the Stratosphere Come from Human or Natural Sourcei? 

Most of the chlorine in the stratosphere is there as a result of himian activities. 

Many compounds containing chlorine arc released at the ground, but those that dissolve 
in water cannot reach stratospheric altitudes. Large quantities of chlorine are released from 
evaporated ocean spray as sea salt (sodium chloride) aerosol. However, because sea salt 
dissolves in water, this chlorine quickly is taken up in clouds or in ice, snow, or rain 
droplets and does not reach the stratosphere. Another ground-level source of chlorine is its 
use in swimming pools and as household bleach. When released, this chlorine is rapidly 
convened to forms that dissolve in water and therefore are removed from the lower 
atmosphere, never reaching the stratosphere in significant amounts. Volcanoes can emit 
large quantities of hydrogen chloride, but this gas is rapidly converted to hydrochloric acid 
in rain water, ice, and snow and does not reach the stratosphere. Even in explosive 
volcanic plumes that rise high in the atmosphere, nearly all of the hydrogen chloride is 
scrubbed out in predpiution before reachii^ stratospheric altitudes. 

In contrast, human-made halocarbons - such as CFCs, carbon tetrachloride (CCLO ^"><^ 
methyl chloroform (CHjCClj) - are not soluble in water, do not react with snow or other 
natural smf^ces, and are not broken down chemically in the lower atmosphere. While the 
exhaust firom the Space Shuttle and from some rockets does inject some chlorine directly 
into the stratosphere, this input is very small (less than one percent of the annual input 
from halocarbons in the present stratosphere, assuming nine Space Shuttle and six Titan TV 
rocket launches per year). 

Several pieces of evidence combine to esublish human-made halocarbons as the primary 
source of stratospheric chlorine. First, measurements have shown that the chlorinated 
spedes that rise to the stratosphere are primarily inanufaauicd compounds (mainly CFCs, 

16 



85 



carbon tetrachloride, methyl chloroform, aad the HCFC substitutes for CFCs), together 
with small amounts of hydrochloric add (HCI) and methyl chloride (CHjCl) which are 
partly natural in origin. The natural contribution now is much smaller than that from 
human activities, as shown in the figure below. Second, in 1985 and 1992 researchers 
measured nearly all known gases containing chlorine in the stratosphere. They found that 
human emissions of halocarbons plus the much smaller contribution from natural sources 
could accoimt for all of the stratospheric chlorine compounds. Third, the incrozse in total 
stratospheric chlorine measured between 1983 and 1992 corresponds with the known 
increases in concentrations of hiunan-made halocarbons during that time. 

Can Changes in the Sun'i Output Be RespondhUfor the Obtenxd Changes in Ozonef 

Stratospheric ozone is primarily cr e a te d by ultraviolet (UV) light coming from the Sun, 
so the Sun's output affects the rate at which ozone is produced. The Sun's energy release 
(both as UV lig^t and as charged particles such as elearons and protons) does vary, 
especially over the well-known 11-year simspot cycle. Observations over several solar 
cycles (since the 1960s) show that total global ozone levels decrease by 1-2% from the 
inaTimiifn to the minimum of a typical cycle. Changes in the Sun's output cannot be 
responsible for the observed long-term changes in ozone, because these downward trends 
art much larger than 1-2%. Further, during the period since 1979, the Sun's energy output 
has gone from a maximum to a minimum in 1985 and back through another maximum in 
1991, but the trend in ozone was downward throughout that time. The ozone trends 
presented in this and previous international scientific assessments have been obtained by 
evaluating the long-term changes in ozone conoentrarions after accounting for the solar 

infliifnf»» 



. When Did the Antarctic Ozone Hole Firjt Appearf 

The Antarctic ozone hole is a new phenomenon. The figure shows that observed 
ozone over the British Antarctic Survey station at Halley Bay, Antarctica first revealed 
obvious decreases in the early 1980$ compared to dau obtained sinoe 1957. The ozone hole 
is formed each year when tfaeze is a sharp decline (currently up to 60%) in the total ozone 
over most of Antarctica for a period of aboixt two months during Southern Hemisphere 
^ring (September and October). Observations from thne other stations in Antarctica, 
also covering several decades, reveal similar progressive, recent decreases in springtime 
ozone. The ozone hole has been shown to resuh from destruction of stratospheric ozone 
by gases nontatntog chlorine and bromine, whose sources are mainly human-made 
halocarbon gases. 

17^ 



86 



Before the stratosphere was aiicatd by hunun-made chlorine and bromine, the 
naturally occurring springtime ozone levels over Antarctica wax about 30-40% lower than 
springtime ozone levels over the Arctic This natural difference between Antaraic and 
Arctic conditions was first observed in the late 1950s by Dobson. It stems £rom the 
exceptionally cold temperatures and different winter wind patterns within the Antarctic 
stratosphere as compared to the Arctic This is not at all the same phenomenon as the 
marked downward trend in total ozone in recent years referred to as the ozone hole. 

Changes in stratospheric meteorology cannot explain the ozone hole. Measurements 
show that wintertime Antaraic stratospheric temperatures of past decades have not 
changed prior to the development of the hole each September. Groimd, aircraft, and 
l a frl l irc measurements have provided, in contrast, clear evidence of the importance of the 
chemistry of chlorine and bromine originating from humanrmade compounds in depleting 
Antarctic ozone in recent years. 

A single report of extremely low Antarctic winter ozone in one location in 1958 by an 
unproven technique has been shown to be completely inconsistent with the measurements 
depicted here and with all credible measurements of total ozone. 

Vfiy is the Ozone Hole Observed over Antarctica When CFCs Are Released Mainly in the 
Northern Hemispheref 

Human emissions of CFCs do occur mainly in the Northern Hemisphere, with about 
90% released in the latitudes corresponding to Europe, Russia, Japan, and North America. 
Gases such as CFCs that arc insoluble in water and relatively unreactive are mixed within a 
year or two throughout the lower atmosphere (below about 10 km). The CFCs in this 
well-mixed air rise from the lower atmosphere into the stratosphere mainly in tropical 
latitudes. Winds then move this air poleward - both north and south - from the tropics, 
so that air throu^iout the stratosphere contains nearly the same amount of chlorine. 
However, the meteorologies of the two polar regions are very different from each other 
because of major differcnors at the Earth's sur^ce. The South Pole is part of a very large 
land mass (Antarctica) that is completely surrounded by ocean. These conditions produce 
very low stratoapheric temperanues which in turn lead to formation of clouds (polar 
stiatospheric clouds). The clouds that form at low tenq>enRure3 lead to chemical changes 
that promote r^id ozone loss during September and October of each year, resulting in the 
ozone hole. 

In contrast, the Earth's vatiaoe in the northern polar reg;ion lacks the land/ocean 
symmetry characteristic of the southern polar area. As a consequence, Arctic st r a t os ph eric 

18 



87 



air 15 generally much wanner tiun in tbe Antarciic, and fewer clouds form there. 
Tiierefore, the ozone depletion in the Araic is much less than in the Antarctic 



Is the Depletion of the Ozone Layer Leading to an Increase in Ground-Level Ultraviolet 
Radiationf 

The Sun emits light over a wide range of energies, with about two f>eroent given off in 
the form of high-energy, ultraviolet (UV) radiation. Some of this UV radiation (UV-B) is 
especially effective in causing damage to living things, including sunburn, «lct'n cancer, and 
eye damage for humans. The amount of solar UV radiation received at any particular 
location on the Earth's surface d^>ends upon the position of the Stm above the horizon, on 
the amount of ozone in the atmosphere, and upon local cloudiness and pollution. 
Scientists agree that in the absence of changes in clouds or poUuzion, decreases in 
atmospheric ozone will increase ground-level UV radiation. 

The largest decreases in ozone during the last decade have been observed over 
Antarctica, especially during each September and October when the "ozone hole" forms. 
During the last several years, simultaneous measurements of UV radiation and total ozone 
have been made at several Antarctic sutions. Vhen the ozone amounts decrease, UV-B 
increases. Because of the ozone hole, the UV-B intensity at Palmer Station, Antarctica, in 
late October, 1993, was more intense than found at San Diego, California, at any time 
daring all of 1993. 

In areas where small ozone depletion has been observed, UV-B increases are more 
difScult to detect. Detection of UV trends associated with ozone decreases can also be 
complicated by changes in cloudiness or by local pollution, as well as by difficulties in 
keeping the detection instriunent in precisely the same condition over many years. Prior 
to the late 1980s, instruments with the necessary accuracy and stability for measurement of 
small long-term trends in grotind-level UV-B were not employed. Recently, however, such 
instruments have been used in the Antarctic because of the very large changes in ozone 
being observed there. When high-quality measurements have been nude in other areas far 
from major cities and their associated air pollution, decreases in ozone have regularly been 
acconq>anled by increases in UV-B. The dau from urban locations with older, less 
specialized instruments provide much less reliable information, especially because good 
simultaneous measurements are not available for any changes in cloudiness or local 
pollution. 



How Severe Is the Ozone Depletion Now, and h It Expected to Get Worse? 

19 



88 



SdentiGc evidence shows chat ozone depletion catued by human-made chemicals is 
continuing and is expected to persist until chlorine and bromine levels are reduced. 
Worldwide monitortag has shown that stratospheric ozone has been decreasing for the past 
two decades or more. Globally averaged loses have totaled about 5% since the mid-1960s, 
with cumulative losses of about 10% in the winter and spring and 5% in the summer and 
autumn over locations such as Europe, North America, and Australia. Since the laie-1970s, 
an ozone "hole" has formed in Antarctica each Southern Hemisphere spring (September / 
October), in which up to 60% of the total ozone is depleted. The large increase in 
atmospheric concentrations of human-made chlorine and bromine compounds is 
responsible for the formation of the Antarctic ozone hole, and the weight of evidence 
indicates that it also plays a major role in midlatitude ozone depletion. 

During 1992 and 1993 ozone in many locations dropped to record low values: 
springtime depletions exceeded 20% in some populated northern midlatitude regions, and 
the levels in the Antarctic ozone hole fell to the lowest values ever recorded. The 
unusually large ozone decreases of 1992 and 1993 arc believed to be related, in part, to the 
volcanic eruption of Mount Pinatubo in the Philippines during 1991. This eruption 
produced large amounts of stratospheric sulfate aerosols that temporarily increased the 
ozone depletion caused by human-made chlorine and bromine compounds. Recent 
observations have shown that as those aerosols have been swept out of the stratosphere, 
ozone concentrations have returned to the depicted levels consistent with the downward 
trend observed before the Mount Pinatubo eruption. 

In 1987 the recognition of the potential for chlorine and bromine to destroy 
stratospheric ozone led to an international agreement flhe United Nations Montreal 
Protocol on Substances thai Deplete the Ozone Layer) to reduce the global production of 
o20ne-depleting substances. Since then, new global observations of significant ozone 
depletion have prompted amendments to strengthen the treaty. The 1992 Copenhagen 
Amendments call for a ban on production of the most damaging compoimds by 1996. The 
assessment report shows past and projected future stratospheric abundances of chlorine and 
bromine: (a) without the Protocol; (b) under the Protocol's original provisions; and (c) 
tmder the Copenhagen Amendments now in force. Without the Montreal Protocol and its 
Amendments, continuing human use of CFCs and other compotmds would have tripled 
the straospheric abundances of chlorine and bromine by aboiu the year 2050. Ciirrent 
scientific understanding indicates that such increases would have led to ^obal ozone 
deletion very much larger than observed today. In contrast, under current international 
agreements, which are now reducing and will eventually eh'minate human emissions of 
ozone-depleting gases, the stratospheric abundances of chlorine and bromine are expected to 
reach their maximum within a few years and then slowly decline. All other things being 

20 



89 



equal, the ozone layer is expected to return to normal by the middle of the next century. 

In summary, record low ozone levels have been observed in recent yean, and 
substantially larger future global depletions in ozone would have been highly likely 
without reductions in human emissions of ozone-depleting gases. However, worldwide 
compliance with current international agreements is rapidly reducing the yearly emissions 
of these compounds. As these emissions cease, the ozone layer will gradually improve over 
the next sevoal decades. The recovery of the ozone layer will be gradual because of the 
long times reqtured for CFCs to be removed from the atmosphere. 



21 



90 



World Meteorological Organization 
Global Ozone Research and Monitoring Project — Report No. 37 



SciENTiHC Assessment of 
Ozone Depletion: 1994 



Executive Summary 



National Oceanic and Atmospheric Administration 

National Aeronautics and Space Administration 

United Nations Environment Programme 

World Meteorological Organization 



91 



Preface 



The present document contains key summaiies from the Scientific Assessment of Ozone Depletion: 1994. The full 
assessment report will be part of the information upon which the Parties to the United Nations Montreal Protocol will 
base their future decisions regarding protection of the stratospheric ozone layer 

Specifically, the Montreal Protocol on Substances That Deplete the Ozone Layer states (Article 6): ". . . the Parties 
shall assess the control measures ... on the basis of available scientific, environmental, technical, and economic infor- 
mation." To provide the mechanisms whereby these assessments are conducted, the Protocol further states: ". . . the 
Parties shall convene appropriate panels of experts" and "the panels will report their conclusions ... to the Parties." 

Three assessment reports have been prepared during 1994 to be available to the Parties in advance of their meeting 
in 1995, at which they will consider the need to amend or adjust the Protocol. The two compatuon reports to the 
scientific assessment focus on the environmental and health effects of ozone layer depletion and on the technology and 
economic implications of mitigation approaches. 

The scientific assessment summarized in the present document is the latest in a series of seven scientific reports 
prepared by the world's leading experts in the atmospheric sciences and under the international auspices of the World 
Meteorological Organization (WMO) and the United Nations Environment Programme (UNEP). The chronology of 
those scientific assessments and the relation to the international policy process are sununarized as follows: 

Scientific Assessment 

The Stratosphere 1981 Theory and Measurements. 

WMO No. 11. 

Atmospheric Ozone 1985. 3 vol. WMO No. 16. 

International Ozone Trends Panel Report 1988. 
2 vol. WMO No. 18. 

1989 Scientific Assessment of Stratospheric Ozone: 

1989. 2 vol. WMO No. 20. 

1990 London Amendment 

1991 Scientific Assessment of Ozone Depletion: 1991. 

WMO No. 25. 

1992 Methyl Bromide: Its Atmospheric Science, Technology, and 

Economics (Assessment Supplement). UNEP (1992). 

1992 Copenhagen Amendment 

1994 Scientific Assessment of Ozone Depletion: 1994. 



Year 


Policy Process 


1981 




1985 


Vienna Convention 


1987 


Montreal Protocol 


1988 





WMO No. 37. 



( 1 995) Vienna Amendment (?) 



The genesis o( Scientific Assessment of Ozone Depletion: 1994 occurred at the 4th meeting of the Conference of the 
Parties to the Montreal Protocol in Copenhagen, Denmark, in November 1992, at which the scope of the scientific needs 
of the Parties was defined. The formal planning of the prese.nt report was a workshop that was held on 1 1 June 1993 in 



92 



Virginia Beach, Virginia, at which an international steering group crafted the outline and suggested scientists from the 
world community to serve as authors. The first drafts of the chapters were examined at a meeting that occurred on 2 - 4 
March 1994 in Washington, D.C., at which the authors and a small number of international experts improved the coor- 
dination of the text of the chapters. 

The second draft was sent out to 1 23 scientists worldwide for a mail peer review. These anonymous comments 
were considered by the authors. At a Panel Review Meeting in Les Diablerets, Switzerland, held on 18-21 July 1994, 
the responses to these mail review comments were proposed by the authors and discussed by the 80 participants. Final 
. changes to the chapters were decided upon, and the Executive Summary contained herein was prepared by the partici- 
pants. 

The group also focused on a set of questions commonly asked about the ozone layer Based upon the scientific 
understanding represented by the assessments, answers to these common questions were prepared and are also included 
here. 

As the accompanying list indicates, the Scientific Assessment of Ozone Depletion: 1994 is the product of 295 
scientists from the developed and developing world' who contributed to its preparation and review (230 scientists 
prepared the report and 147 scientists participated in the peer review process). 

What follows is a summary of their current understanding of the stratospheric ozone layer and its relation to hu- 
mankind. 



' Participating were Argentina. Australia, Austria, Belgium, Brazil, Canada, Chile, Cuba, Czech Republic, l>enmarlc. Egypt. France, Geimaiiy, 
Greece, Hungary, India, Iran, Ireland. Israel, Italy, Japan, Kenya, Malaysia, New Zealand, Norway, Poland. Russia, South Africa, Sweden. Switzer- 
land. Taiwan. The Netherlands. The People's Republic of China. United Kingdom, United Stales of America, and Venezuela. 



Executive Summary 



Recent Major Scientific Findings and Observations 

The laboratory investigations, atmospheric observations, and theoretical and modeling smdies of the past few years 
have provided a deeper understanding of the human-influenced and natural chemical changes in the atmosphere and 
their relation to the Earth's stratospheric ozone layer and radiative balance of the climate system. Since the last interna- 
tional scientific assessment of the state of understanding, there have been several key ozone-related findings, 
observations, and conclusions: 

The atmospheric growth rates of several major ozone-depleting substances have slowed, demonstrating the 
expected impact of the Montreal Protocol and its Amendments and Adjustments. The abundances of the 
chlorofluorocarbons (CFCs), carbon tetrachloride, methyl chloroform, and halons in the atmosphere have been 
monitored at global ground-based sites since about 1978. Over much of that period, the annual growth rates of 
these gases have been positive. However, the data of recent years clearly show that the growth rates of CFC- 1 1, 
CFC-12, halon-1301, and halon-121 1 are slowing down. In psirticular, total tropospheric organic chlorine in- 
creased by only about 60 ppt/year (1.6%) in 1992, compared to 1 10 ppt/year (2.9%) in 1989. Furthermore, 
tropospheric bromine in halons increased by only about 0.25 ppt/year in 1992, compared to about 0.85 ppt/year in 
1989. The abundance of carbon tetrachloride is actually decreasing. The observed trends in total tropospheric 
organic chlorine are consistent with reported production data, suggesting less emission than the maximum al- 
lowed under the Montreal Protocol and its Amendments and Adjustments. Peak total chlorine/bromine loading in 
the troposphere is expected to occur in 1994, but the stratospheric peak will lag by about 3 - 5 years. Since the 
stratospheric abundances of chlorine and bromine are expected to continue to grow for a few more years, increas- 
ing global ozone losses are predicted (other things being equal) for the remainder of the decade, with gradual 
recovery in the 21st century. 

• The atmospheric abundances of several of the CFC substitutes are increasing, as anticipated. With phase- 
out dates for the CFCs and other ozone-depleting substances now fixed by international agreements, several 
hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) are being manufactured and used as substi- 
tutes. The atmospheric growth of some of these compounds (.e.g., HCFC-22) has been observed for several years, 
and the growth rates of others (e.g., HCFC-142b and HCFC-14lb) are now being monitored. Tropospheric 
chlorine in HCFCs increased by 5 ppt/year in 1989 and about 10 ppt/year in 1992. 

• Record low global ozone levels were measured over the past two years. Anomalous ozone decreases were 
observed in the midlatitudes of both hemispheres in 1992 and 1993. The Northern Hemispheric decreases were 
larger than those in the Southern Hemisphere. Globally, ozone values were I - 2% lower than would be expected 
from an e..trapolation of the trend prior to 1991, allowing for solar-cycle and quasi-biennial-oscillation (QBO) 
effects. The 1994 global ozone levels are returning to values closer to those expected from the longer-term 
downward trend. 



94 



The stratosphere was perturbed by a major volcanic eruption. The eruption of Mt. Pinatubo in 1991 led to a 
large increase in sulfate aerosol in the lower stratosphere throughout the globe. Reactions on sulfate aerosols 
resulted in significant, but temporary, changes in the chemical partitioning that accelerated the photochemical 
ozone loss associated with reactive hydrogen (HOx), chlorine, and bromine compounds in the lower stratosphere 
in midlatimdes and polar regions. Absorption of terrestrial and solar radiation by the Mt. Pinatubo aerosol result- 
ed in a transitory rise of 1°C (globally averaged) in the lower-stratospheric temperature and also affected the 
distribution of ozone through circulation changes. The observed 1994 recovery of global ozone is qualitatively 
consistent with observed gradual reductions of the abundances of these volcanic particles in the stratosphere. 

Downward trends in total-column ozone continue to be observed over much of the globe, but their magni- 
tudes are underestimated by numerical models. Decreases in ozone abundances of about 4-5% per decade at 
midlatitudes in the Northern and Southern Hemispheres continue to be observed by both ground-based and satel- 
lite-borne monitoring instruments. At midlatitudes, the losses continue to be much larger during winter/spring 
than during summer/fall in both hemispheres, and the depletion increases with latitude, particularly in the South- 
era Hemisphere. Little or no downward trends are observed in the tropics (20°N - 20°S). While the current two- 
dimensional stratospheric models simulate the observed trends quite well during some seasons and latitudes, they 
underestimate the trends by factors of up to three in winter/spring at mid- and high latitudes. Several known 
atmospheric processes that involve chlorine and bromine and that affect ozone in the lower stratosphere are 
difficult to model and have not been adequately incorporated into these models. 

Observations have demonstrated that halogen chemistry plays a larger role in the chemical destruction of 
ozone in the midlatitude lower stratosphere than expected from gas phase chemistry. Direct in situ measure- 
ments of radical species in the lower stratosphere, coupled with model calculations, have quantitatively shown 
that the in situ photochemical loss of ozone due to (largely natiual) reactive nitrogen (NO,) compounds is smaller 
than that predicted from gas phase chemistry, while that due to (largely namral) HO, compounds and (largely 
anthropogenic) chlorine and bromine compounds is larger than that predicted from gas phase chemistry. This 
confirms the key role of chemical reactions on sulfate aerosols in controlling the chemical balance of the lower 
stratosphere. These and other recent scientific findings strengthen the conclusion of the previous assessment that 
the weight of scientific evidence suggests that the observed middle- and high-latitude ozone losses are lai;gely due 
to anthropogenic chlorine and bromine compounds. 

The conclusion that anthropogenic chlorine and bromine compounds, coupled with surface chemistry on 
natural polar stratospheric particles, are the cause of polar ozone depletion has been further strengthened. 

Laboratory studies have provided a greatly improved understanding of how the chemistry on the surfaces of ice. 
nitrate, and sulfate particles can increase the abundance of ozone-depleting forms of chlorine in the polar strato- 
spheres. Furthermore, satellite and in situ observations of the abundances of reactive nitrogen and chlorine 
compounds have improved the explanation of the different ozone-altering properties of the Antarctic and Arctic. 

The Antarctic ozone "holes" of 1992 and 1993 were the most severe on record. The Antarctic ozone "hole" 
has continued to occur seasonally every year since its advent in the late- 1970s, with the occurrences over the last 
several years being particularly pronounced. Satellite, balloon-borne, and ground-based monitoring instrurttents 
revealed that the Antarctic ozone "holes" of 1992 and 1993 were the biggest (areal extent) and deepest (minimum 
amounts of ozone overhead), with ozone being locally depleted by more than 99% between about 14 - 19 km in 
October, 1992 and 1993. It is likely that these larger-than-usual ozone depletions could be attributed, at least in 
part, to sulfate aerosols from Mt. Pinatubo increasing the effectiveness of chlorine- and bromine-catalyzed ozone 
destruction. A substantial Antarctic ozone "hole" is expected to occur each austral spring for many more decades 
because stratospheric chlorine and bromine abundances will approach the pre-Antarctic-ozone-"hole" levels 
flate- 1970s) very slowly during the next century. 

S 



95 



Ozone losses have been detected in the Arctic winter stratosphere, and their links to halogen chemistry 
have been established. Studies in the Arctic lower stratosphere have been expanded to include more widespread 
observations of ozone and key reactive species. In the late-winter/early-spring period, additional chemical losses 
of ozone up to 15 - 20% at some altitudes are deduced from these observations, particularly in the winters of 1991/ 
2 and 1992/3. Model calculations constrained by the observations are also consistent with these losses, increasing 
the confldence in the role of chlorine and bromine in ozone destruction. The interannual variability in the photo- 
chemical and dynamical conditions of the Arctic polar vortex continues to limit the ability to predict ozone 
changes in future years. 

The linl( lietween a decrease in stratospheric ozone and an increase in surface ultraviolet (UV) radiation 
lias been further strengthened. Measurements of UV radiation at the surface under clear-sky conditions show 
that low overhead ozone yields high UV radiation and in the amount predicted by radiative-transfer theory. Large 
increases of surface UV are observed in Antarctica and the southern part of South America during the period of 
the seasonal ozone "hole." Furthermore, elevated surface UV levels at mid-to-high latitudes were observed in the 
Northern Hemisphere in 1992 and 1993, corresponding to the low ozone levels of those years. However, the lack 
of a decadal (or longer) record of accurate monitoring of surface U V levels and the variation introduced by clouds 
and other factors have precluded the unequivocal identification of a long-term trend in surface UV radiation. 

Methyl bromide continues to be viewed as a significant ozonenlepleting compound. Increased attention has 
been focused upon the ozone-depleting role of methyl bromide. Three potentially major anthropogenic sources of 
atmospheric methyl bromide have been identified (soil fumigation, biomass burning, and the exhaust of automo- 
biles using leaded gasoline), in addition to the natural oceanic source. Recent laboratory studies have confirmed 
the fast rate for the BrO -t- HO2 reaction and established a negUgible reaction pathway producing HBr, both of 
which imply greater ozone losses due to emissions of compounds containing bromine. While the magnitude of 
the atmospheric photochemical removal is well understood, there are significant uncertainties in quantifying the 
oceanic sink for atmospheric methyl bromide. The best estimate for the overall lifetime of atmospheric methyl 
bromide is 1 .3 years, with a range of 0.8 - 1 .7 years. The Ozone Depletion Potential (ODP) for methyl bromide is 
calculated to be about 0.6 (relative to an ODP of I for CFC- II). 

Stratospheric ozone losses cause a global-mean negative radiative forcing. In the 1991 scientific assessment, 
it was pointed out that the global ozone losses that were occurring in the lower stratosphere caused this region to 
cool and result in less radiation reaching the surface-troposphere system. Recent model studies have strengthened 
this picture. A long-term global-mean cooling of the lower stratosphere of between 0.25 and 0.4°Cydecade has 
been observed over the last three decades. Calculations indicate that, on a global mean, the ozone losses between 
1980 and 1990 offset about 20% of the radiative forcing due to the well-mixed greenhouse-gas increases during 
that period (i.e., carbon dioxide, methane, nitrous oxide, and halocarbons). 

TTopospheric ozone, which is a greenhouse gas, appears to have increased in many regions of the Northern 
Hemisphere. Observations show that tropospheric ozone, which is formed by chemical reactions involving 
pollutants, has increased above many locations in the Northern Hemisphere over the last 30 years. However, in 
the 1980s, the trends were variable, being small or nonexistent. In the Southern Hemisphere, there are insufficient 
data to draw strong inferences. At the South Pole, a decrease has been observed since the mid-1980s. Model 
simulations and limited observations suggest that tropospheric ozone has increased in the Northern Hemisphere 
since pre-industrial times. Such changes would augment the radiative forcing from all other greenhouse gases by 
about 20% over the same time period. 



96 



•' The atmospheric residence times of the important ozone-depleting gases, CFC-11 and methyl chloroform, 
and the greenhouse gas, methane, are now better known. A reconciliation of observed concentrations with 
known emissions using an atmospheric model has led to a best-estimate lifetime of 50 years for CFC- 1 1 and 5.4 
years for methyl chloroform, with uncertainties of about 10%. These lifetimes provide an accurate standard for 
gases destroyed only in the stratosphere (such as CFCs and nitrous oxide) and for those also reacting with tropo- 
spheric hydroxyl radical, OH (such as HCFCs and HFCs), respectively. Recent model simulations of methane 
perturbations and a theoretical analysis of the tropospheric chemical system that couples methane, carbon monox- 
ide, and OH have demonstrated that methane perturbations decay with a lengthened time scale in a range of about 
12-17 years, as compared with the 10- year lifetime derived from the total abundance and losses. This longer 
response time and other indirect effects increase the estimate of the effectiveness of emissions of methane as a 
greenhouse gas by a factor of about two compared to the direct-effect-only values given in the 1 99 1 assessment. 

Supporting Scientific Evidence and Related Issues 

Ozone Chances in the Tropics and MiDiATrruDES and Their Interpretation 

• Analysis of global total-column ozone data through early 1994 shows substantial decreases of ozone in all sea- 
sons at midlatitudes (30° - 60°) of both hemispheres. For example, in the middle latitudes of the Northern 
Hemisphere, downward trends of about 6% per decade over 1979 - 1994 were observed in winter and spring and 
about 3% per decade were observed in summer and fall. In the Southern Hemisphere, the seasonal difference was 
somewhat less, but the midlatitude trends averaged a similar 4% to 5% per decade. There are no statistically 
significant trends in the tropics (20°S - 20°N). Trends through 1994 are about 1 % per decade more negative in the 
Northern Hemisphere (2% per decade in the midlatitude winter/spring in the Northem Hemisphere) compared to 
those calculated without using data after May 1991. At Northem midlatitudes, the downward trend in ozone 
between 198 1-1991 was about 2% per decade greater compared to that of the period 1970 - 1980. 

• Satellite and ozonesonde data show that much of the downward trend in ozone occurs below 25 km {i.e., in the 
lower stratosphere). For the region 20 - 25 km, there is good agreement between the trends firom the Stratospheric 
Aerosol and Gas Experiment (SAGE I/II) satellite instrument data and those from ozonesondes, with an observed 
annual-average decrease of 7 ± 4% per decade from 1979 to 1991 at 30° - 50°N latitude. Below 20 km, SAGE 
yields negative trends as large as 20 ± 8% per decade at 1 6 - 17 km, while the average of available midlatitude 
ozonesonde data shows smaller negative trends of 7 ± 3% per decade. Integration of the ozonesonde data yields 
total-ozone trends consistent with total-ozone measurements. In the 1980s, upper-stratospheric (35 - 45 km) 
ozone trends determined by the data from SAGE I/II, Solar Backscatter Ultraviolet satellite spectrometer 
(SBUV), and the Umkehr method agree well at midlatitudes, but less so in the tropics. Ozone declined 5 - 10% 
per decade at 35 - 45 km between 30°- SO°N and slightly more at southern midlatitudes. In the tropics at 45 km, 
SAGE I/Il and SBUV yield downward trends of 10 and 5% per decade, respectively. 

• Simultaneous in situ measurements of a suite of reactive chemical species have directly confirmed modeUng 
studies implying that the chemical destruction of ozone in the midlatitude lower stratosphere is more strongly 
influenced by HO, and halogen chemistry than NO, chemistry. The seasonal cycle of CIO in the lower strato- 
sphere at midlatitudes in both hemispheres supports a role for in situ heterogeneous perturbations {i.e., on sulfate 
aerosols),^ but does not appear consistent with the timing of vortex processing or dilution. These studies provide 
key svip)>(^rt for the view that sulfate aerosol chemistiy plays an important role in detennining midlatitude chem- 
ical ozone destruction rates. 



97 



The model-calculated ozone depletions in the upper stratosphere for 1980 - 1990 are in broad agreement with the 
measurements. Although these model-calculated ozone depletions did not consider radiative feedbacks and tem- 
perature trends, including these effects is not likely to reduce the predicted ozone changes by more than 20%. 

Models including the chemistry involving sulfate aerosols and polar stratospheric clouds (PSCs) better simulate 
the observed total ozone depletions of the past decade than models that include only gas phase reactions. How- 
ever, they still underestimate the ozone loss by factors ranging from 1.3 to 3.0. 

Some unresolved discrepancies between observations and models exist for the partitioning of inoi;ganic chlorine 
species, which could impact model predictions of ozone trends. These occur for the CIO/HCI ratio in the upper 
stratosphere and the fraction of HCl to total inorganic chlorine in the lower stratosphere. 

The transport of ozone-depleted air from polar regions has the potential to influence ozone concentrations at 
middle latitudes. While there are uncertainties about the importance of this process relative to in situ chemistry 
for midlatitude ozone loss, both directly involve ozone destruction by chlorine- and bromine-catalyzed reactions. 

Radiosonde and satellite data continue to show a long-term cooling trend in globally annual-average lower-strato- 
spheric temperatures of about 0.3 - 0.4°C per decade over the last three decades. Models suggest that ozone 
depletion is the major contributor to this trend. 

Anomalously large downward ozone trends have been observed in midlatitudes of both hemispheres in 1992 and 
1993 (i.e.. the first two years after the eruption of Mt. Pinatubo), with Northern-Hemispheric decreases larger than 
those of the Southern Hemisphere. Global-average total-ozone levels in early 1993 were about 1% to 2% below 
that expected from the long-term trend and the particular phase of the solar and QBO cycles, while peak decreases 
of about 6 - 8% from expected ozone levels were seen over 45 - 60°N. In the first half of 1994, ozone levels 
returned to values closer to those expected from the long-term trend. 

The sulfur gases injected by Mt. Pinatubo led to large enhancements in stratospheric sulfate aerosol surface areas 
(by a maximum factor of about 30 - 40 at northern midlatitudes within a year after the eruption), which have 
subsequently declined. 

Anomalously low ozone was measured at altitudes below 25 km at a Northern-Hemispheric midlatitude station in 
1992 and 1993 and was correlated with observed enhancements in sulfate-aerosol surface areas, pointing towards 
a causal link. 

Observations indicate that the eruption of Mt. Pinatubo did not significantly increase the HCl content of the 
stratosphere. 

The recent large ozone changes at midlatitudes are highly likely to have been due, at least in part, to the greatly 
increased sulfate aerosol in the lower stratosphere following Mt. Pinatubo. Observations and laboratory studies 
have demonstrated the importance of heterogeneous hydrolysis of N2O5 on sulfate aerosols in the atmosphere. 
Evidence suggests that CIONO2 hydrolysis also occurs on sulfate aerosols under cold conditions. Both processes 
perturb the chemistry in such a way as to increase ozone loss through coupling with the anthropogenic chlorine 
and bromine loading of the stratosphere. 



• Global mean lower stratospheric temperatures showed a marked transitory rise of about I °C following the erup- 
tion of Mt. Pinatubo in 1991, consistent with model calculations. The warming is likely due to absorption of 
radiation by the aerosols. 

Polar Ozone Depletion 

• In 1992 and 1993, the biggest-ever (areal extent) and deepest-ever (minimum ozone below 100 Dobson units) 
ozone "holes" were observed in the Antarctic. These extreme ozone depletions may have been due to the chem- 
ical perturbations caused by sulfate aerosols from Mt. Pinatubo, acting in addition to the well-recognized chlorine 
and bromine reactions on polar stratospheric clouds. 

• Recent results of observational and modeling studies reaffirm the role of anthropogenic halocaibon species in 
Antarctic ozone depletion. Satellite observations show a strong spatial and temporal correlation of CIO abun- 
dances with ozone depletion in the Antarctic vortex. In the Arctic winter, a much smaller ozone loss has been 
observed. These losses are both consistent with photochemical model calculations constrained with observations 
from in situ and satellite instruments. 

• Extensive new measurements of HCl, CIO, and CIONO2 from satellites and in situ techniques have confirmed the 
picture of the chemical processes responsible for chlorine activation in polar regions and the recovery from those 
processes, strengthening current understanding of the seasonal cycle of ozone depletion in both polar regions. 

• New laboratory and field studies strengthen the confidence that reactions on sulfate aerosols can activate chlorine 
under cold conditions, particularly those in the polar regions. Under volcanically perturbed conditions when 
aerosols are enhanced, these processes also likely contribute to ozone losses at the edges of PSC formation 
regions (both vertical and horizontal) just outside of the southern vortex and in the Arctic. 

• Satellite measurements have confirmed that the Arctic vortex is much less denitrified than the Antarctic, which is 
likely to be an important factor in detemuning the interhemispheric differences in polar ozone loss. 

• Interannual variability in the photochemical and dynamical conditions of the vortices limits reliable predictions of 
fiiture ozone changes in the polar regions, particularly in the Arctic. 

Coupling Between Polar Regions and MmLATrruDES 

• Recent satellite observations of long-lived tracers and modeling studies confirm that, above 16 km. air near the 
center of the polar vortex is substantially isolated from lower latitudes, especially in the Antarctic. 

• Erosion of the vortex by planetary-wave activity transports air from the vortex -edge region to lower latitudes. 
Nearly alt observational and modeling studies are consistent with a time scale of 3 - 4 months to replace a substan- 
tial fraction of Antarctic vortex air. The importance of this transport to in situ chemical effects for midlatitude 
ozone loss remains poorly known. 

• Air is readily transported between polar regions and midlatitudes below 1 6 km. The influence of this transport on 
midlatitude ozone loss has not been quantified. 



12 



99 



Tropospheric Ozone 

• There is observational evidence that tropospheric ozone (about 10% of the total-column ozone) has increased in 
the Northern Hemisphere (north of 20°N) over the past three decades. The upward trends are highly regional. 
They are smaller in the 1980s than in the 1970s and may be slightly negative at some locations. European 
measurements at surface sites also indicate a doubling in the lower-tropospheric ozone concentrations since ear- 
lier this century. At the South Pole, a decrease has been observed since the mid- 1980s. Elsewhere in the Southern 
Hemisphere, there are insufficient data to draw strong inferences. 

• There is strong evidence that ozone levels in the boundary layer over the populated regions of the Northern 
Hemisphere are enhanced by more than 50% due to photochemical production from anthropogenic precursors, 
and that export of ozone from North America is a significant source for the North Atlantic region during summer. 
It has also been shown that biomass burning is a significant source of ozone (and carbon monoxide) in the tropics 
during the dry season. 

• An increase in UV-B radiation (e.g., from stratospheric ozone loss) is expected to decrease tropospheric ozone in 
the background atmosphere, but, in some cases, it will increase production of ozone in the more polluted regions. 

• Model calculations predict that a 20% increase in methane concentrations would result in tropospheric ozone 
increases ranging from 0.5 to 2.5 ppb in the tropics and the northern midlatitude summer, and an increase in the 
methane residence time to about 14 years (a range of 12 - 17 years). Although there is a high degree of consis- 
tency in the global transport of short-lived tracers within three-dimensional chemical-transport models, and a 
general agreement in the computation of photochemical rates affecting tropospheric ozone, many processes con- 
trolling tropospheric ozone are not adequately represented or tested in the models, hence limiting the accuracy of 
these results. 

Tremds in Source Gases Relatinc to Ozone Changes 

• CFCs, carbon tetrachloride, methyl chloroform, and the halons are major anthropogenic source gases for strato- 
spheric chlorine and bromine, and hence stratospheric ozone destruction. Observations from several monitoring 
networks wortdwide have demonstrated slowdowns in growth rates of these species that are consistent (except for 
carbon tetrachloride) with expectations based upon recent decreases in emissions. In addition, observations from 
several sites have revealed accelerating growth rates of the CFC substitutes, HCFC-22, HCFC- 141b, and HCFC- 
142b, as expected from their increasing use. 

• Methane levels in the atmosphere affect tropospheric and stratospheric ozone levels. Global methane increased 
by 7% over about the past decade. However, the 1980s were characterized by slower growth rates, dropping from 
approximately 20 ppb per year in 1980 to about 10 ppb per year by the end of the decade. Methane growth rates 
slowed dramatically in 1991 and 1992, but the very recent data suggest that they have started to increase in late 
1993. The cause(s) of this behavior are not known, but it is probably due to changes in methane sources rather 
than sinks. 

• Despite the increased methane levels, the total amount of carbon monoxide in today's atmosphere is less than it 
was a decade ago. Recent analyses of global caitran monoxide data show that tropospheric levels grew from the 
early 1980s toabout 1987 and have declined from the late 1980s to the present. Thecause(s) of this behavior have 
not been identified. 



13 



100 



Consequences of Ozone Changes 

• The only general circulation model (GCM) simulation to investigate the climatic impacts of observed ozone 
depletions between 1970 and 1990 supports earlier suggestions that these depletions reduced the model-predicted 
wanning due to well-mixed greenhouse gases by about 20%. This is consistent with radiative forcing calcula- 
tions. 

• Model simulations suggest that increases in tropospheric ozone since pre-industrial times may have made signif- 
icant contributions to the greenhouse forcing of the Earth's climate system, enhancing the current total forcing by 
about 20% compared to that arising from the changes in the well-mixed greenhouses gases over that period. 

• Large increases in ultraviolet (UV) radiation have been observed in association with the ozone hole at high south- 
em latitudes. The measured UV erUiancements agree well with model calculations. 

• Clear-sky UV measurements at midlatitude locations in the Southern Hemisphere are significantly larger than at 
a corresponding site in the Northern Hemisphere, in agreement with expected differences due to ozone column 
and Sun-Earth separation. 

• Local increases in UV-B were measured in 1992/93 at mid- and high latitudes in the Northern Hemisphere. The 
spectral signatures of the enhancements clearly implicate the anomalously low ozone observed in those years, 
rather than variability of cloud cover or tropospheric pollution. Such correlations add confidence to the ability to 
link ozone changes to UV-B changes over relatively long time scales. 

• Increases in clear-sky UV over the period 1979 to 1993 due to observed ozone changes are calculated to be 
greatest at short wavelengths and at high latitudes. Poleward of 45°, the increases are greatest in the Southern 
Hemisphere. 

• Uncertainties in calibration, influence of tropospheric pollution, and difficulties of interpreting data from broad- 
band instruments continue to preclude the unequivocal identification of long-term UV trends. However, data 
from two relatively unpolluted sites do appear to show UV increases consistent with observed ozone trends. 
Given the uncertainties of these studies, it now appears that quantification of the natural (i.e., pre-ozone-reduc- 
tion) UV basehne has been irrevocably lost at mid- and high latitudes. 

• Scattering of UV radiation by stratospheric aerosols from the Ml Pinatubo eruption did not alter total surface-UV 
levels appreciably. 

Related Phenomena and Issues 
Methyl Bromide 

• Three potentially major anthropogenic sourx:es of methyl bromide have been identified: (i) soil fumigation: 20 to 
60 ktons per year, where new measurements reaflinn that about 50% (ranging from 20 - 90%) of the methyl 
bromide used as a soil fumigaiu is released into the atmosphere; (ii) biomass burning: 10 to SO ktons per year, and 
(iii) the exhaust of automobiles using leaded gasoline: 0.5 to 1 .5 ktons per year or 9 to 22 ktons per year (the two 
studies report emission factors that differ by a factor of more than 10). In addition, the one known major natural 
source of methyl bromide is oceanic, with emissions of 60 to 160 ktons per year. 



101 



Recent measurements have confirmed that there is more methyl bromide in the Northern Hemisphere than in the 
Southern Hemisphere, with an interhemispheric ratio of 1.3. 

There are two kjiown sinks for atmospheric methyl bromide: (i) atmospheric, with a lifetime of 2.0 years ( 1 .5 to 
2.S years): and (ii) oceanic, with an estimated lifetime of 3.7 years ( 1 .5 to 10 years). The overall best estimate for 
the lifetime of atmospheric methyl bromide is 1.3 years, with a range of 0.8 to 1.7 years. An overall lifetime of 
less than 0.6 years is thought to be highly unlikely because of constraints imposed by the observed interhemi- 
spheric ratio and total known emissions. 

The chertiistry of bromine-induced stratospheric ozone destruction is now better understood. Laboratory mea- 
surements have confirmed the fast rate for the BiO + HO? reaction and have established a negligible reaction 
pathway producing HBr, both of which imply greater ozone losses due to emissions of compounds containing 
bromine. Stratospheric measurements show that the abundance of HBr is less than I ppt. 

Bromine is estimated to be about 50 times more efficient than chlorine in destroying stratospheric ozone on a per- 
atom basis. The ODP for methyl bromide is calculated to be about 0.6, based on an overall lifetime of 1 .3 years. 
An uncertainty analysis suggests that the ODP is unlikely to be less than 0.3. 



Aircraft 



Subsonics: Estimates indicate that present subsonic aircraft operations may be significantly increasing trace 
species (primarily NO,, sulfur dioxide, and soot) at upper-tiopospheric altitudes in the North- Atlantic flight cor- 
ridor. Models indicate that the NO, emissions from the current subsonic fleet produce upper-tropospheric ozone 
increases as much as several percent, maximizing at northern midlatitudes. Since the results of these rather 
complex models depend critically on NO, chemistry and since the tropospheric NO, budget is uncertain, little 
confidence should be put in these quantitative model results at the present time. 

Supersonics: Atmospheric effects of supersonic aircraft depend on the number of aircraft, the altitude of opera- 
tion, the exhaust emissions, and the background chlorine and aerosol loadings. Projected fleets of supersonic 
transports would lead to significant changes in trace-species concentrations, especially in the North-Atlantic 
flight corridor. Two-dimensional model calculations of the impact of a projected fleet (500 aircraft, each emitting 
15 grams of NO, per kilogram of fuel burned at Mach 2.4) in a stratosphere with a chlorine loading of 3.7 ppb, 
imply additional {i.e., beyond those from halocarbon losses) annual-average ozone column decreases of 
0.3 - 1.8% for the Northern Hemisphere. There are, however, important uncertainties in these model results, 
especially in the stratosphere below 25 km. The same models fail to reproduce the observed ozone trends in the 
stratosphere below 25 km between 1980 and 1990. Thus, these models may not be properly including mecha- 
nisms that are important in this crucial altitude range. 

Climate Effects: Reliable quantitative estimates of the effects of aviation emissions on climate are not yet avail- 
able. Some initial estimates indicate that the climate effects of ozone changes resulting from subsonic aircraft 
emissions may be comparable to those resulting from their CO2 emissions. 



15 . 



102 



Oiome Depletion Potentials (ODPs) 

• If a substance containing chlorine or bromine decomposes in the stratosphere, it will destroy some ozone. 
HCFCs have short tropospheric lifetimes, which tends to reduce their impaa on stratospheric ozone as compared 
to CFCs and halons. However, there are substantial differences in ODPs among varic.-!is substitutes. The steady- 
state ODPs of substitute compounds considered in the present assessment range from about 0.01 - 0. 1 . 

• Tropospheric degradation products of CFC substitutes will not lead to significant ozone loss in the stratosphere. 
Those products will not accumulate in the atmosphere and will not significantly influence the ODPs and Global 
Warming Potentials (GWPs) of the substitutes. 

• Trifluoroacetic acid, formed in the atmospheric degradation of HFC-134a, HCFC-123, and HCFC-124, will enter 
into the aqueous environment, where biological, rather than physico-chemical, removal processes may be effec- 
tive. 

• It is known that atomic fluorine (F) itself is not an efficient catalyst for ozone loss, and it is concluded that the 
F-containing fragments from the substitutes (such as CF3O,) also have negligible impact on ozone. Therefore, 
ODPs of MFCs contaimng the CF3 group (such as HFC- 134a, HFC-23, and HFC- 125) are likely to be much less 
than 0.001. 

• New laboratory measurements and associated modeling studies have confirmed that perfluorocarbons and suIAir 
hexafluoride are long-lived in the atmosphere and act as greenhouse gases. 

• The ODPs for several new compounds, such as HCFC-225ca, HCFC-225cb, and CF3I, have been evaluated using 
both semi-empirical and modeling approaches, and are found to be 0.03 or less. 

Global Warming Potentials (GWPs) 

• Both the direct and indirect components of the GWP of methane have been estimated using model calculations. 
Methane's influence on the hydroxyl radical and the resulting effect on the methane response time lead to substan- 
tially longer response times for decay of emissions than OH removal alone, thereby increasing the GWP. In 
addition, indirect effects including production of tropospheric ozone and stratospheric water vapor were consid- 
ered and are estimated to range from about 15 to 45% of the total GWP (direct plus indirect) for methane. 

• GWPs, including indirect effects of ozone depletion, have been estimated for a variety of halocaibons, clarifying 
the relative radiative roles of ozone-depleting compounds (i.e., CFCs and halons). The net GWPs of halocarbons 
depend strongly upon the effectiveness of each compound for ozone destruction; the halons are highly likely to 
have negative net GWPs, while those of the CFCs are likely to be positive over both 20- and 100-year time 
horizons. 



Implications for Policy Formulation 

The research findings of the past few years that are summarized above have several major implications as scientific 
input to governmental, industrial, and other policy decisions regarding human-influenced substances that lead to deple- 
tion of the stratospheric ozone layer and to changes of the radiative forcing of the climate system: 



103 



The Montreal Protocol and its Amendments and Adjustments are reducing the impact of anthropogenic 
haiocarbons on the ozone layer and should eventually eliminate this ozone depletion. Based on assumed 
compliance with the amended Montreal Protocol (Copenhagen, 1992) by all nations, the stratospheric chlorine 
abundances will continue to grow from their current levels (3.6 ppb) to a peak of about 3.8 ppb around the turn of 
the century. The future total bromine loading will depend upon choices made regarding future human production 
and emissions of methyl bromide. After around the turn of the century, the levels of stratospheric chlorine and 
bromine will begin a decrease that will continue into the 21st and 22nd centuries. The rate of decline is dictated 
by the long residence times of the CFCs, carbon tetrachloride, and halons. Global ozone losses and the Antarctic 
ozone "hole" were first discernible in the late 1970s and are predicted to recover in about the year 2045, other 
things being equal. The recovery of the ozone layer would have been impossible without the Amendments and 
Adjustments to the original Protocol (Montreal, 1987). 

Peak global ozone losses are expected to occur during the next several years. The ozone layer will be most 
affected by human-influenced perturbations and susceptible to natural variations in the period around the year 
1998, since the peak stratospheric chlorine and bromine abundances are expected to occur then. Based on extrap- 
olation of current trends, observations suggest that the maximum ozone loss, relative to the late 1960s, will likely 
be: 

(i) about 12 - 13% at Northern tnidlatitudes in winter/spring (i.e., about 2.5% above current levels); 
(ii) about 6 - 7% at Northern midlatitudes in summer/fall (i.e., about 1 .5% above current levels); and 
(iii) about 11% (with less certainty) at Southern midlatitudes on a year-round basis {i.e., about 2.5% above 
current levels). 

Such changes would be accompanied by 15%, 8%, and 13% increases, respectively, in surface erythemal radia- 
tion, if other influences such as clouds remain constant. Moreover, if there were to be a major volcanic eruption 
like that of Mt. Pinatubo, or if an extremely cold and persistent Arctic winter were to occur, then the ozone losses 
and UV increases could be larger in individual years. 

Approaches to lowering stratospheric chlorine and bromine abundances are limited. Further controls on 
ozone-depleting substances would not be expected to significantly change the timing or the magnitude of the peak 
stratospheric halocarbon abundances and hence peak ozone loss. However, there are four approaches that would 
steepen the initial fall from the peak halocarbon levels in the early decades of the next century: 

(i) If emissions of methyl bromide from agricultural, structural, and industrial activities were to be eliitiinated 
in the year 200 1 , then the integrated effective future chlorine loading above the 1 980 level (which is related 
to the cumulative future loss of ozone) is predicted to be 13% less over the next 50 years relative to full 
compliance to the Amendments and Adjustments to the Protocol. 

(ii) If emissions of HCFCs were to be totally eliminated by the year 2004, then the integrated effective future 
chlorine loading above the 1980 level is predicted to be 5% less over the next 50 years relative to full 
compliance with the Amendments and Adjustments to the Protocol, 

(iii) If halons presently contained in existing equipment were never released to the atmosphere, then the inte- 
grated effective future chlorine loading above the 1980 level is predicted to be 10% less over the next 50 
years relative to full compliance with the Amendments and Adjustments to the Protocol. 

(iv) If CFCs presently contained in existing equipment were never released to the atmosphere, then the integrat- 
ed effective future chlorine loading above the 1980 level is predicted to be 3% less over the next 50 years 
relative to full compliance with the Amendments and Adjustments to the Protocol. 



iZ 



104 



ctolheMenHfiaMlapccacatiwadeii^reMvetyaftteaaaeiiT^K If iboe were u> be 
addUoMl imdKtiM of CFCt « 20% of 1992 le»eb Sdt eacfa 3iear dn^ 2002 Md camped lo zm> by 20M 

rill Jill Ih ■*!■ Ill fi —l i iinii [■'■i.iiilii liliili Tiirilt TlliMii iiriiilninT) Itiinllir iwrirTilrffrnr r 

fmmt diadtc loodag above tte 1980 lewd tt ptedicied to be 9% oxve over (he aoa SO yean lebiive lo fall 
s Kt *e AaeadMoB Md AAMOaeaB 19 te Proioco! 




ifarlheCFCs^hilMiMeilMa0UUegreenbciDsega*eL Sevstal CFC and hakn 
t aK aot addhNKd Mder dK Moatneil Pnioool (becave Aejr do aot depieie ozooe). bai, becaoie ibey 
tin I- fill — I* I Il» iwiii ■ nf Ih rrwiminri rnmrnrinn nn rtimtr TTi-wtr Tbereiiawide 
fM^ of nlKt fior «K Caobol WtasMc I^NBMiak (GWPt) of ibe HPCf M50 - 10000). widi aboM baif of ifaem 
hawag i A i fHMMtMiiU eio*eazo«6Hieplati«g uMtK — i ln bgrrepbce. Tbe perflaomaied compoaadi. sooie 
<rf wbitfc a» beiae iwii dterBd a» i rii ii i —pg . hwe vpy taiBe GWP» (eg., 5000 10000). Hkk ape examples of 

mill— li mh Mil 1 ■1111*1 lii ii—ilwi 1 1 ■! n l»iii Ij iiiiJI Urn ui i iiij m iniirt ■rrnir "w rtir 

f*3re 

Cw M* de»a B — af a»«<^ rhuiff wMbeaae i fffg y i yr^h^ ia aai l iii l Mi a i u fciate rhMff Tbe 
e»ieMofo«rabaiQrio«iii—r aaycawmettoriyioapeaficcaBKt will Ifltety prove w be importaaKJeatific 
■p«tiod8 CMi o w i rt, B ia i t pB e d K»e dbBMa»-««dacedi^lBe«ct»OBftediaiaiety«eni. Qtaage* ia ozone noce 
pte-iadaMtBi daes at a Knh of baana acbvky are beiiewed to bi»e beea a tagaificaat isflueace oa radiative 

f i w ia t. fcibaiaMiaflararr ii rrfrnriin rnnr ia ar iTilir fnrrr-riHr frrrr 



105 



Common Questions about Ozone 



Ozone is exceedingly rare in our atmosphere, 
averaging about 3 molecules of ozone lor 
every ten million air molecules. Nonettie- 
less, atmospheric ozone plays vital roles that belie its 
small numbers. This Appendix to the World Meteoro- 
logical Organization/United Nations Environrver)! 
Programme (WMO/UNEP) Scientific Assessment of 
Ozone Depletion: 1994 answers some of the questions 
that are most commonly asked about ozone and the 
changes that have been occurring in recent years These 
common questions and their answers were discussed by 
the 80 scientists from 26 countries who participated in 
the Panel Review Meeting of the Scientific Assessment of 
Ozone Depletion: 1994. Therefore, this information Is 
presented by a large group of experts from the interna- 
tional scientific community 

Ozone is mainly found in two regions of the Earth's atmo- 
sphere. Most ozone (about 90%) resides in a layer 
between approximately 10 and 50 kilometers (about 6 to 
30 miles) above the Earth's surface, in the region of the 
atmosphere called the stratosphere. This stratospheric 
ozone is commonly known as the "ozone layer." The re- 
maining ozone is in the lower region of the atmosphere, 
the troposphere, which extends from the Earth's surface 
up to about 10 kilometers The figure below shows this 
distribution of ozone in the atmosphere. 

While the ozone in these two regions is chemically iden- 
tical (both consist of three oxygen atoms and have the 
chemical formula "O3"), the ozone molecules have very 
different effects on humans and other living things de- 
pending upon their location. 

Stratospheric ozone plays a beneficial role by absorbing 
most of the biologically damaging ultraviolet sunlight 
called UV-B, allowing only a small amount to reach the 
Earth's surface. The absorption of UV radiation by ozone 
creates a source of heat, which actually forms the strato- 
sphere itself (a region in which the temperature rises as 
one goes to higher altitudes). Ozone thus plays a key 
role in the temperature structure of the Earth's atmo- 
sphere Furthermore, without the filtering action of the 
ozone layer, more of the Sun's UV-B radiation would 
penetrate the atmosphere and would reach the Earth's 
surlace in greater amounts. Many experimental studies 
of plants and animals, and clinical studies of humans, 
have shown the harmful effects of excessive exposure to 
UV-B radiation {these are discussed in the WMO/UNEP 
reports on impacts of ozone depletion, which are com- 



panion documents to the WMO/UNEP sclentHic assess- 
ments of ozone depletion). 

At the planet's surface, ozone comes into direct contact 
with life-forms and displays its destructive side. Be- 
cause ozone reacts strongly with other molecules, high 
levels are toxic to living systems and can severely dam- 
age the tissues of plants and animals. Many studies 
have documented the harmful effects of ozone on crop 
production, forest growth, and human health. The sub- 
stantial negative effects of surface-level tropospheric 
ozone from this direct toxicity contrast with the benefits 
of the additional filtering of UV-B radiation that it pro- 
vides. 

With these dual aspects of ozone come two separate en- 
vironmental issues, controlled by different forces in the 
atmosphere. In the troposphere, there is concern about 
increases in ozone. Low-lying ozone is a key component 
of smog, a familiar problem in the atmosphere of many 
cities around the world. Higher than usual amounts of 
surface-level ozone are now increasingly being observed 
in rural areas as well. However, the ground-level ozone 
concentrations in the smoggiest cities are very much 
smaller than the concentrations routinely found in the 
stratosphere. 

There is widespread scientific and public interest and 
concern about losses of stratospheric ozone. Ground- 
based and satellite instruments have measured 
decreases in the amount of stratospheric ozone in our 
atmosphere. Over some parts of Antarctica, up to 60% of 
the total overhead amount of ozone (known as the "col- 
umn ozone") is depleted during September and October. 
This phenomenon has come to be known as the Antarctic 
"ozone hole " Smaller, but still significant, stratospheric 
decreases have been seen at other, more-populated re- 
gions of the Earth. Increases in surface UV-B radiation 
have been observed in association with decreases in 
stratospheric ozone. 

The scientific evidence, accumulated over more than two 
decades of study by the international research communi- 
ty, has shown that human-made chemicals are 
responsible for the observed depletions of the ozone lay- 
er over Antarctica and likely play a major role m global 
ozone losses. The ozone-depleting compounds contain 
various combinations of the chemical elements chlorine, 
fluorine, bromine, carbon, and hydrogen, and are often 
described by the general term t)alocarbOns. The com- 



106 



pounds that contain only carbon, chlorine, and fluorine 
are called chlorofluorocarbons. usually aobreviated as 
CFCs. CFCs, carbon tetrachloride, and methyl chloro- 
form are important human-made ozone-depleting gases 
that have been used in many applications including re- 
frigeration, air conditioning, foam blowing, cleaning of 
electronics components, and as solvents. Another im- 
portant group of human-made halocarbons is the 
halons, which contain carbon, bromine, fluorine, and (in 
some cases) chlorine, and have been mainly used as fire 
extinguishants. Governments have decided to discon- 
tinue production of CFCs, halons, carbon tetrachloride, 
and methyl chloroform, and industry has developed 
more "ozone-friendly" substitutes. 

Two responses are natural when a new problem has been 
identified: cure and prevention. When the problem is the 
destruction of the stratospheric ozone layer, the corre- 
sponding questions are; Can we repair the damage 
already done? How can we prevent further destruction? 
Remedies have been investigated that could (i) remove 
CFCs selectively from our atmosphere, (ii) intercept 
ozone-depleting chlorine before much depletion has tak- 
en place, or (iii) replace the ozone lost in the stratosphere 
(perhaps by shipping the ozone from cities that have too 



much smog or by making new ozone). Because ozone 
reacts strongly with other molecules, as noted above, it 
is too unstable to be made elsewhere (e.g.. in the smog 
of cities) and transported to the stratosphere. When the 
huge volume of the Earth's atmosphere and the magni- 
tude of global stratospheric ozone depletion are carefully 
considered, approaches to cures quickly become much 
too expensive, impractical, and potentially damaging to 
the global environment. Prevention involves the interna- 
tionally agreed-upon Montreal Protocol and its 
Amendments and Adjustments, which call for elimina- 
tion of the production and use of the CFCs and other 
ozone-damaging compounds within the next few years. 
As a result, the ozone layer is expected to recover over 
the next fifty years or so as the atmospheric concentra- 
tions of CFCs and other ozone-depleting compounds 
slowly decay 

The current understanding of ozone depletion and its re- 
lation to humankind is discussed in detail by the leading 
scientists in the world's ozone research community in the 
Scientific Assessment of Ozone Depletion: 1994. The 
answers to the common questions posed below are 
based upon that understanding and on the information 
given in earlier WMOAJNEP reports. 



Atmospheric Ozone 




Stratospheric Ozone 
(The Ozone Layer) 



Tropospheric Ozone 



• Contains 90% of Atmosphenc 
Ozone 

• Beneficial Role: 

Acts as Pfimary UV Radiation 
ShieU 

• Current Issues: 

- Ijng-term Gkibal 
Downward Trends 

- Springtime Antarctic Ozone 
Hole Each Year 



' Contains 10% of Atmospheric 
Ozone 

• Harmful Impact: Toxic Effects 
on Humans and Vegetation 

• Current Issues: 

- Episodes of High Surface 
Ozone in Urt>an and 
Rural Areas 



Ozone Amount 

(pressure, milli-Pascals) 



20 



107 



How Can Chlorofluorocarbons (CFCs) Get to the Stratosphere 
If They're Heavier than Air? 



Although the CFC molecules are indeed several times 
heavier than air, thousands of measurements have been 
made Irom balloons, aircraft, and satellites demonstrat- 
ing that the CFCs are actually present in the stratosphere. 
The atmosphere is not stagnant. Winds mix the atmo- 
sphere to altitudes far above the top of the stratosphere 
much faster than molecules can settle according to their 
weight Gases such as CFCs that are insoluble in vtrater 
and relatively unreactive in the lower atmosphere (below 
about 10 km) are quickly mixed and therefore reach the 
stratosphere regardless of their weight. 

Much can be learned about the atmospheric fate of com- 
pounds from the measured changes in concentration 
versus altitude. For example, the two gases carbon tet- 
rafluoride (CF4, produced mainly as a by-product of the 
manufacture of aluminum) and CFC-1 1 (CCI3F, used in a 
variety of human activities) are both much heavier than 



air. Carbon tetrafluoride is completely unreactive in the 
lower 99.9% of the atmosphere, and measurements 
show it to be nearly uniformly distributed throughout the 
atmosphere as shown in the figure. There have also been 
measurements over the past two decades of several other 
completely unreactive gases, one lighter than air (neon) 
and some heavier than air (argon, krypton), which show 
that they also mix upward uniformly through the strato- 
sphere regardless of their weight, just as observed with 
carbon tetrafluoride. CFC-11 is unreactive in the lower 
atmosphere (below about 15 km) and is similarly uni- 
formly mixed there, as shown. The abundance of 
CFC-11 decreases as the gas reaches higher altitudes, 
where it is broken down by high energy solar ultraviolet 
radiation. Chlorine released from this breakdown of 
CFC-11 and other CFCs remains in the stratosphere for 
several years, where it destroys many thousands of mol- 
ecules of ozone. 



Measurements of CFC-11 and CF4 



40 




v> 




CF4 


V 


•Vn^CFC-ll 




•5 30 


^^....^^^^^^^ 







^^^^ 




JC 


^^^^^ 










« 20 


- 


s. 


■5? 




X 








«- 






< 10 


1 1 1 1 


1. 1 



0.01 ai 1.0 10.0 100 
Atmospheric Abundance 

( in ports per trillion ) 



1000 



Stratosphere 



/WW 

Trcposptiere 



108 



What is the Evidence that Stratospheric Ozone 
is Destroyed by Chlorine and Bromine? 



Laboratory studies show that chlorine (CI) reacts very 
rapidly with ozone They also show that the reactive 
chemical chlorine oxide (CIO) formed in that reaction 
can undergo further processes which regenerate the 
original chlorine, allowing the sequence to be repeated 
very many times (a "chain reaction"). Similar reactions 
also take place between bromine and ozone. 

But do these ozone-destroying reactions occur in the real 
world? All of our accumulated scientific experience dem- 
onstrates that if the conditions of temperature and 
pressure are like those in the laboratory studies, the 
same chemical reactions will take place in nature. How- 
ever, many other reactions including those of other 
chemical species are often also taking place simulta- 
neously in the stratosphere, making the connections 
among the changes difficult to untangle. Nevertheless, 
whenever chlorine (or bromine) and ozone are found to- 
gether in the stratosphere, the ozone-destroying 
reactions must be taking place. 

Sometimes a small number of chemical reactions is so 
important in the natural circumstance that the connec- 
tions are almost as clear as in laboratory experiments. 
Such a situation occurs in the Antarctic stratosphere dur- 
ing the springtime formation of the ozone hole. During 
August and September 1987 - the end of winter and be- 
ginning of spring in the Southern Hemisphere - aircraft 
equipped with many different instruments for measuring 
a large number of chemical species were flown repeated- 



ly over Antarctica. Among the chemicals measured were 
ozone and chlorine oxide, the reactive chemical identi- 
fied in the laboratory as one of the participants in the 
ozone-destroying chain reactions. On the first flights 
southward from the southern tip of South America, rela- 
tively high concentrations of ozone were measured 
everywhere over Antarctica. By mid-September, howev- 
er, the instruments recorded low concentrations of ozone 
in regions where there were high concentrations of chlo- 
rine oxide and vice versa, as shown in the figure. Flights 
later in September showed even less ozone over Antarc- 
tica, as the chlorine continued to react with the 
stratospheric ozone. 

independent measurements made by these and other in- 
struments on this and other airplanes, from the ground, 
from balloons, and from satellites have provided a de- 
tailed understanding of the chemical reactions going on 
in the Antarctic stratosphere. Regions with high concen- 
trations of reactive chlorine reach temperatures so cold 
(less than approximately -SOX, or -112°F) that strato- 
spheric clouds form, a rare occurrence except during the 
polar winters. These clouds facilitate other chemical re- 
actions that allow the release of chlorine in sunlight. The 
chemical reactions related to the clouds are now well 
understood through study under laboratory conditions 
mimicking those found naturally. Scientists are working 
to understand the role of such reactions of chlorine and 
bromine at other latitudes, and the involvement of parti- 
cles of sulfuric acid from volcanoes or other sources. 



Measurements of Ozone and Reactive Chlorine 
from a Fiiglit into tlie Antarctic Ozone Hoie 



2S00 


* ,-v Own* 






2000 


'x A / 


' 




,«» 


■^^w'l 














(ScaJe «i RiflW) J 


Afltarac 
PoiaiA- 





Latitude {D»gr»«s Sou*i) 



109 



Does Most of the Chlorine in the Stratosphere 
Come from Human or Natural Sources? 



Most of the chlorine in the stratosphere is there as a re- 
sult of human activities. 

Many compounds containing chlorine are released at the 
ground, but those that dissolve in water cannot reach 
stratospheric altitudes. Large quantities of chlorine are 
released from evaporated ocean spray as sea salt (sodi- 
um chloride) aerosol. However, because sea salt 
dissolves in water, this chlorine quickly is taken up in 
clouds or in ice, snow, or rain droplets and does not 
reach the stratosphere. Another ground-level source of 
chlorine is its use in swimming pools and as household 
bleach. When released, this chlorine is rapidly convert- 
ed to forms that dissolve in water and therefore are 
removed from the lower atmosphere, never reaching the 
stratosphere in significant amounts. Volcanoes can emit 
large quantities of hydrogen chloride, but this gas is rap- 
idly converted to hydrochloric acid in rain water, ice, and 
snow and does not reach the stratosphere. Even in ex- 
plosive volcanic plumes that rise high in the atmosphere, 
nearly all of the hydrogen chloride is scrubbed out in 
precipitation before reaching stratospheric altitudes. 

In contrast, human-made halocarbons - such as CFCs, 
carbon tetrachloride (CCU) and methyl chloroform 
(CH3CCI3) - are not soluble in vrater, do not react with 
snow or other natural surfaces, and are not broken down 
chemically in the lower atmosphere. While the exhaust 



from the Space Shuttle and from some rockets does in- 
ject some chlorine directly into the stratosphere, this 
input is very small (less than one percent of the annual 
input from halocarbons in the present stratosphere, as- 
suming nine Space Shuttle and six Titan IV rocket 
launches per year). 

Several pieces of evidence combine to establish human- 
made halocarbons as the primary source of stratospheric 
chlorine. First, measurements (see the figure tjelow) 
have shown that the chlorinated species that rise to the 
stratosphere are primarily manufactured compounds 
(mainly CFCs, carbon tetrachloride, methyl chloroform, 
and the HCFC substitutes for CFCs), together with small 
amounts of hydrochloric acid (HCI) and methyl chloride 
(CH3CI) which are partly natural in origin. The natural 
contribution now is much smaller than that from human 
activities, as shown in the figure below. Second, in 1985 
and 1992 researchers measured nearly all known gases 
containing chlorine in the stratosphere. They found that 
human emissions of halocarbons plus the much smaller 
contribution from natural sources could account for all of 
the stratospheric chlorine compounds. Third, the in- 
crease in total stratospheric chlorine measured between 
1985 and 1992 corresponds with the known increases in 
concentrations of human-made halocarbons during that 
time. 



Primary Sources of Chlorine Entering the Stratosphere 




no 



Can Changes in the Sun's Output Be Responsible 
for the Observed Changes in Ozone? 



stratospheric ozone is primarily created by ultraviolet 
(UV) ligtit coming from the Sun. so the Sun's output af- 
fects the rate at which ozone is produced. The Sun's 
energy release (both as UV light and as charged particles 
such as electrons and protons) does vary, especially 
over the well-known 11 -year sunspot cycle. Observa- 
tions over several solar cycles (since the 1960s) show 
that total global ozone levels decrease by 1-2% from the 
maximum to the minimum of a typical cycle. Changes in 
the Sun's output cannot be responsible for the observed 
long-term changes in ozone, because these downward 



trends are much larger than 1-2%. Further, during the 
period since 1979, the Sun's energy output has gone 
from a maximum to a minimum in 1985 and back 
through another maximum in 1991, but the trend in 
ozone was downward throughout that time. The ozone 
trends presented in this and previous international sci- 
entific assessments have been obtained by evaluating 
the long-term changes in ozone concentrations after ac- 
counting for the solar influence (as has been done in the 
figure below). 



Global Ozone Trend (60°S-60°N) 




1960 



1982 



1984 



1986 1988 
Year 



1990 



1992 



1994 



» 



Ill 



When Did the Antarctic Ozone Hole First Appear? 



The Antarctic ozone tiole is a new phenomenon. The fig- 
ure shows that observed ozone over the British Antarctic 
Survey station at Halley Bay, Antarctica first revealed ob- 
vious decreases in the early 1980s compared to data 
obtained since 1957. The ozone hole is formed each 
year when there is a sharp decline (currently up to 60%) 
in the total ozone over most of Antarctica for a period of 
about two months during Southern Hemisphere spring 
(September and October). Observations from three other 
stations in Antarctica, also covering several decades, re- 
veal similar progressive, recent decreases in springtime 
ozone. The ozone hole has been shown to result from 
destruction of stratospheric ozone by gases containing 
chlorine and bromine, whose sources are mainly hu- 
man-made halocarbon gases. 

Before the stratosphere vras affected by human-made 
chlorine and bromine, the naturally occurring springtime 
ozone levels over Antarctica were about 30-40% lower 
than springtime ozone levels over the Arctic. This natu- 
ral difference between Antarctic and Arctic conditions 
was first observed in the late 1 950s by Dobson. It stems 



from the exceptionally cold temperatures and different 
winter wind patterns within the Antarctic stratosphere as 
compared to the Arctic. This is not at all the same phe- 
nomenon as the marked downward trend in total ozone in 
recent years referred to as the ozone hole and shown in 
the figure below. 

Changes in stratospheric meteorology cannot explain 
the ozone hole. Measurements show that wintertime 
Antarctic stratospheric temperatures of past decades 
have not changed prior to the development of the hole 
each September. Ground, aircraft, and satellite measure- 
ments have provided, in contrast, clear evidence of the 
importance of the chemistry of chlorine and bromine 
originating from human-made compounds in depleting 
Antarctic ozone in recent years. 

A single report of extremely low Antarctic winter ozone in 
one location in 1958 by an unproven technique has been 
shown to be completely inconsistent with the measure- 
ments depicted here and with all credible measurements 
of total ozone. 



Historical Springtime Totai Ozone Record 
for Halley Bay, Antarctica (76°S) 




112 



Why is the Ozone Hole Observed over Antarctica 

When CFCs Are Released Mainly in the Northern Hemisphere? 



Human emissions of CFCs do occur mainly in the North- 
ern Hemisphere, with about 90% released in the 
latitudes corresponding to Europe, Russia, Japan, and 
North America. Gases such as CFCs that are insoluble in 
water and relatively unreactlve are mixed within a year or 
two throughout the lower atmosphere (below about 10 
km). The CFCs in this well-mixed air rise from the lower 
atmosphere into the stratosphere mainly in tropical lati- 
tudes. Winds then move this air poleward - both north 
and south - from the tropics, so that air throughout the 
stratosphere contains nearly the same amount of chlo- 
rine. However, the meteorologies of the two polar 
regions are very different from each other because of 
major differences at the Earth's surface. The South Pole 
is part of a very large land mass (Antarctica) that is com- 



pletely surrounded by ocean. These conditions produce 
very low stratospheric temperatures which in turn lead to 
formation of clouds (polar stratospheric clouGs). The 
clouds that form at low temperatures lead to chemical 
changes that promote rapid ozone loss during Septem- 
ber and October of each year, resulting in the ozone hole. 

In contrast, the Earth's surface in the northern polar re- 
gion lacks the land/ocean symmetry characteristic of the 
southern polar area. As a consequence, Arctic strato- 
spheric air is generally much warmer than in the 
Antarctic, and fewer clouds form there. Therefore, the 
ozone depletion in the Arctic is much less than In the 
Antarctic. 



1979 



Schematic of Antarctic Ozone Hole 

1986 



1991 




26 



113 



Is the Depletion of the Ozone Layer Leading to an Increase in 
Ground-Level Ultraviolet Radiation? 



The Sun emits light over a wide range of energies, with 
about two percent given oft in the form of high-energy, 
ultraviolet (UV) radiation. Some of this UV radiation 
(UV-B) is especially effective in causing damage to living 
things, including sunburn, skin cancer, and eye damage 
for humans. The amount of solar UV radiation received 
at any particular location on the Earth's surface depends 
upon the position of the Sun above the horizon, on the 
amount of ozone in the atmosphere, and upon local 
cloudiness and pollution. Scientists agree that in the ab- 
sence of changes in clouds or pollution, decreases In 
atmospheric ozone will increase ground-level UV radia- 
tion. 

The largest decreases in ozone during the last decade 
have been observed over Antarctica, especially during 
each September and October when the "ozone hole" 
forms. During the last several years, simultaneous mea- 
surements of UV radiation and total ozone have been 
made at several Antarctic stations. As shown in the fig- 
ure below, when the ozone amounts decrease, UV-B 
increases. Because of the ozone hole, the UV-B intensity 
at Palmer Station, Antarctica, in late October, 1993, was 



more intense than found at San Diego, California, at any 
time during all of 1993. 

In areas where small ozone depletion has been observed, 
UV-B increases are more difficult to detect. Detection of 
UV trends associated with ozone decreases can also be 
complicated by changes in cloudiness or by local pollu- 
tion, as well as by difficulties in keeping the detection 
instrument in precisely the same condition over many 
years. Prior to the late 1980s, instruments with the nec- 
essary accuracy and stability for measurement of small 
long-term trends in ground-level UV-B were not em- 
ployed. Recently, however, such instruments have been 
used in the Antarctic because of the very large changes 
in ozone being observed there. When high-quality mea- 
surements have been made in other areas far from major 
cities and their associated air pollution, decreases in 
ozone have regularly been accompanied by increases in 
UV-B. The data from urban locations with older, less 
specialized instruments provide much less reliable infor- 
mation, especially because good simultaneous 
measurements are not available for any changes in 
cloudiness or local pollution. 



Increases in Erythemal (Sunburning) UV Radiation 
Due to Ozone Reductions 



South Pole, Antorctico 
Feb 1991 - Oec 1992 




-40% 



Chonge In Ozone 
( Spring vs. Autumn, for the Some Solar Angle) 



27 



114 



How Severe Is the Ozone Depletion Now, 
and Is It Expected to Get Worse? 



Scientific evidence shows that ozone depletion caused 
by human-made chemicals is continuing and is expected 
to persist until chlorine and bromine levels are reduced. 
Worldwide monitoring has shown that stratospheric 
ozone has been decreasing for the past two decades or 
more. Globally averaged losses have totaled about 5% 
since the mid-1960s, with cumulative losses of about 
10% in the winter and spring and 5% in the summer and 
autumn over locations such as Europe, North America, 
and Australia. Since the late-1970s, an ozone "hole" has 
formed in Antarctica each Southern Hemisphere spring 
(September / October), in which up to 60% of the total 
ozone is depleted. The large increase in atmospheric 
concentrations of human-made chlorine and bromine 
compounds is responsible for the formation of the Ant- 
arctic ozone hole, and the weight of evidence indicates 
that it also plays a major role in midlatitude ozone deple- 
tion. 

During 1 992 and 1 993 ozone in many locations dropped 
to record low values: springtime depletions exceeded 
20% in some populated northern midlatitude regions, 
and the levels in the Antarctic ozone hole fell to the low- 
est values ever recorded. The unusually large ozone 
decreases of 1992 and 1993 are believed to be related, in 
part, to the volcanic eruption of IVIount Pinatubo in the 
Philippines during 1991. This eruption produced large 

Ozone-Dorrxiging Stratospheric Chlorine/BrDmine 

15000 



•~ 12000 

c 

.9 I 

'B 

!a 9000 



• 


1 

Protocol / /. 


- 


/ / 


■ 


/ / 


. 


/■ / 


. 


/■ / 


. 




: 


/ / ■ 


• 


/ y 


• 

/ 
y 


1 ■ ■ ■ ■ 1 



1950 »I975 ZqpC aces 2050 2075 2100 



amounts of stratospheric sulfate aerosols that temporari- 
ly increased the ozone depletion caused by human-made 
chlorine and bromine compounds. Recent observations 
have shown that as those aerosols have been swept out 
of the stratosphere, ozone concentrations have returned 
to the depleted levels consistent with the downward trend 
observed before the Mount Pinatubo eruption. 

In 1987 the recognition of the potential lor chlorine and 
bromine to destroy stratospheric ozone led to an interna- 
tional agreement (The United Nations Montreal Protocol 
on Substances that Deplete the Ozone Layer) to reduce 
the global production of ozone-depleting substances. 
Since then, new global observations of significant ozone 
depletion have prompted amendments to strengthen the 
treaty. The 1992 Copenhagen Amendments call for a ban 
on production of the most damaging compounds by 
1996. The figure shows past and projected future strato- 
spheric abundances of chlorine and bromine: (a) without 
the Protocol; (b) under the Protocol's original provi- 
sions; and (c) under the Copenhagen Amendments now 
in force. Without the Montreal Protocol and its Amend- 
ments, continuing human use of CFCs and other 
compounds would have tripled the stratospheric abun- 
dances of chlorine and bromine by about the year 2050. 
Current scientific understanding indicates that such in- 
creases would have led to global ozone depletion very 
much larger than observed today. In contrast, under cur- 
rent international agreements, which are now reducing 
and will eventually eliminate human emissions of ozone- 
depleting gases, the stratospheric abundances of 
chlorine and bromine are expected to reach their maxi- 
mum within a few years and then slowly decline. All 
other things being equal, the ozone layer is expected to 
return to normal by the middle of the next century. 

In summary, record low ozone levels have been observed 
in recent years, and substantially larger future global de- 
pletions in ozone would have been highly likely without 
reductions in human emissions of ozone-depleting gas- 
es. However, worldwide compliance with current 
international agreements is rapidly reducing the yearly 
emissions of these compounds. As these emissions 
cease, the ozone layer will gradually improve over the 
next several decades. The recovery of the ozone layer 
will be gradual because of the long times required for 
CFCs to be removed from the atmosphere. 



^^ 



115 

List of International Authors, 
Contributors, and Reviewers 



Assessment Co-chairs 

Daniel L. Albritton, Robert T. Watson, and Piet J. Aucamp 
Chapters and Lead Authors 

Part 1 . Observed Changes in Ozone and Source Gases 

Chapter 1. Ozone Measurements (Neil R. P. Harris) 

Chapter 2. Source Gases: Trends and Budgets (Eugenia Sanhueza) 

Part 2. Atmospheric Processes Responsible for the Observed Changes in Ozone 

Chapter 3. Polar Ozone (David W Fahey) 

Chapter 4. Tropical and Midlatitude Ozone (Roderic L Jones) 

Chapters. Tropospheric Ozone (Andreas Voh-Thomas and Brian A. Ridley) 

Part 3. Model Simulations of Global Ozone 

Chapter 6. Model Simulations of Stratospheric Ozone (Malcolm K. W. Ko) 
Chapter?. ModelSimulationsof Global Tropospheric Ozone (Frode Stordal) 

Part 4. Consequences of Ozone Change 

Chapter 8. Radiative Forcing and Temperattire Trends (Keith P. Shine) 
Chapter 9. Surface Ultraviolet Radiation (Richard L McKenzie) 

Part 5. Scientific Information for Future Decisions 

Chapter 10. Methyl Bromide (Stuart A. Penkett) 

Chapter 1 1 . Subsonic and Supersonic Aircraft Emissions (Andreas Wahner and Marvin A. Getler) 

Chapter 12. Atmospheric Degradation of Halocarbon Substimtes (R.A. Cox) 

Chapter 13. Ozone Depletion Potentials, Global Warming Potentials, and 

Future Chlorine/Bromine Loading (Susan Solomon and Donald J. Wuebbles) 

Coordinators: Common Questions About Ozofie 

Susan Solomon NOAA Aeronomy Laboratory US 
F. Sherwood Rowland University of California at Irvine US 

Authors, Contributors, and Reviewers 

Daniel L. Albritton NOAA Aeronomy Laboratory US 

Marc Allaan Koninklijk Nederlands Meteorologisch Instituut The Netheriands 

FredN. Alyea Georgia Institute of Technology US 

Gerard Ancellet Centre National de la Recherche Scientifique France 

Meinrat O. Andreae Max-Planck-Institut fiir Chemie Germany 

James K. Angell NOAA Air Resources Laboratory US 

Frank Arnold Max-Planck-Institut fUr Kemphysik Germany 



116 



Roger Atkinson University of California at Riverside US 

Elliot Atlas National Center for Atmospheric Research US 

Piet J. Aucamp Department of Health South Africa 

Linnea M. Avallone University of California at Irvine US 

Helmuth Bauer Forschungszentrum fUr Umwelt u. Gesundheit Germany 

Slimane Bekki University of Cambridge UK 

Tibor B£rces Hungarian Academy of Sciences Hungary 

T. Bemtsen Universitetet I Oslo Norway 

Lane Bishop Allied Signal US 

Donald R. Blake University of California at Irvine US 

N.J.Blake University of California at Irvine US 

Mario Blumthaler University of Innsbruck Austria 

Greg E. Bodeker University of Natal/NTWA South Africa 

Rumen D. Bojkov World Meteorological Organization Switzerland 

Charles R. Booth Biospherical Instruments US 

Byron Boville National Center for Atmospheric Research US 

Kenneth P. Bowman Texas A&M University US 

Geir Braathen Norsk Institutt for Luftforskning Norway 

Guy P. Brasseur National Center for Atmospheric Research US 

Carl Brenninkmeijer National Institute of Water and Atmospheric Research New Zealand 

Christoph Brilhl Max-Planck-Institut fUr Chemie Germany 

William H. Brune Pennsylvania State University US 

James H. Butler NOAA Climate Monitoring and Diagnostics Laboratory US 

Sergio Cabrera Universidad de Chile Chile 

Bruce A. Callander United Kingdom Meteorological Office UK 

Daniel Cariolle M£t£o-France, Centre National de Recherches M£t£otologiques France 

RichanJ P. Cebula Hughes STX US 

William L. Chameides Georgia Institute of Technology US 

Sushil Chandra NASA Goddard Space Right Center US 

Marie-Lise Chanin Centre National de la Recherche Scientifique France 

J.Christy University of Alabama at Huntsville US 

Ralph J. Cicerone University of California at Irvine US 

G.J.R. Coetzee Weather Bureau South Africa 

Peter S. Connell Lawrence Livermore National Laboratory US 

D. Considine NASA Goddard Space Right Center US 

R.A. Cox National Environmental Research Council UK 

Paul J. Ciutzen Max-Planck-Institut fUr Chemie Germany 

Derek N. Cunnold Georgia Institute of Technology US 

John Daniel NOAA Aeronomy Laboratory/CIRES US 

Malgorzata Deg6rska Polish Academy of Sciences Poland 

John J. DeLuisi NOAA Air Resources Laboratory US 

Dirk De Muer Institut Royal M£t£orologique de Belgique Belgium 

Frank Dentener Wageningen Agricultural University The Netherlands 

Richard G. Derwent UK Meteorological Office UK 

Terry Deshler University of Wyoming US 

Susana B. Diaz Austral Center of Scientific Research (CADIC/CONICET) Argentina 

Russell Dickerson University of Maryland US 



117 



J. Dignon Lawrence Livermore National Laboratory 

Ed Dlugokencky NOAA Climate Monitoring and Diagnostics Laboratory 

Anne R. Douglass NASA Goddard Space Flight Center 

Tom Duafala Methyl Bromide Global Coalition 

James E. Dye National Center for Atmospheric Research 

Dieter H. Ehhalt Forschungszentnim JUlich 

James W. Elkins NOAA Climate Monitoring and Diagnostics Laboratory 

Christine Ennis NOAA Aeronomy Laboratory/CIRES 

D. Etheridge CSIRO Division of Atmospheric Research 

David W. Fahey NOAA Aeronomy Laboratory 

T. Duncan A. Fairlie NASA Langley Research Center 

Donald A. Fisher E.I. DuPont de Nemours and Company 

Jack Fishman NASA Langley Research Center 

Eric L. Fleming Applied Research Corporation 

Frank Flocke Forschungszentnim JUlich 

Lawrence E. Flynn Software Corporation of America 

P.M. de F. Fbrster University of Reading 

James Franklin Solvay S.A. 

Paul J. Eraser CSIRO Division of Atmospheric Research 

John E. Frederick University of Chicago 

Lucien Froidevaux California Institute of Technology/Jet Propulsion Laboratory 

J.S. Fuglestvedt Center for International Climate & Energy Research 

Reinhard Furrer Freie UniversitSt Berlin 

Ian E. Galbally CSIRO Division of Atmospheric Research 

Brian G. Gardiner British Antarctic Survey 

Marvin A. Geller State University of New York at Stony Brook 

Hartwig Gemandt Alfred Wegener Institut 

James F. Gleason NASA Goddard Space Flight Center 

Sophie Godin Centre National de la Recherche Scientifique 

Amram Golombek Israel Institute for Biological Research 

Ulrich GOrsdorf Deutscher Wetterdienst 

Thomas E. Graedel AT&T Bell Laboratories 

Claire Granier National Center for Atmospheric Research 

William B. Grant NASA Langley Research Center 

L J. Gray SERC Rutherford Appleton Laboratory 

William L. Grose NASA Langley Research Center 

J. Gross Max-Planck-Institut fUr Cbemie 

A.S. Grossman Lawrence Livermore National Laboratory 

Alexander Gruzdev Russian Academy of Sciences 

James E. Hansen NASA Goddard Institute for Space Studies 

Neil R.P. Harris European Ozone Research Coordinating Unit 

Shiro Hatekeyama National Institute for the Environment 

D.A. Hauglustaine Centre National de la Recherche Scientifique 

Sachiko Hayashida Nara Women's University 

G.D. Hayman Harwell Laboratory/AEA Environment and Energy 

Kjell Heniiksen University of Troms0 

Emest Hilsenrath NASA Goddard Space Flight Center 



US 
US 
US 
US 
US 

Germany 
US 
US 

Australia 
US 
US 
US 
US 
US 

Germany 

US 

UK 

Belgium 

Australia 

US 

US 

Norway 

Germany 

Australia 
UK 
US 

Germany 

US 

France 

Israel 

Germany 
US 
US 
US 
UK 
US 

Germany 

US 

Russia 

US 

UK 

Japan 

France 

Japan 

UK 

Norway 

US 



118 



David J. Hofmann NOAA Climate Monitoring and Diagnostics Laboratory US 

Stacey M. Hollandsworth Applied Research Corporation US 

James R. Holton University of Washington US 

Lon L. Hood University of Arizona US 

0ystein Hov Universitetet I Bergen Norway 

Carleton J. Howard NOAA Aeronomy Laboratory US 

Robert D. Hudson University of Maryland US 

D. Hufford Environmental Protection Agency US 

Linda Hunt NASA Langley Research Center US 

Abdel M. Ibrahim Egyptian Meteorological Authority Egypt 

Mohammad Ilyas University of Science Malaysia Malaysia 

Ivar S.A. Isaksen Universitetet I Oslo Norway 

Tomoyuki Ito Japan Meteorological Agency Japan 

Charles H. Jackman NASA Goddard Space Flight Center US 

Daniel J. Jacob Harvard University US 

Colin E. Johiuon UK Meteorological Office/AEA Technology UK 

Harold S. Johnston University of California at Berkeley US 

Paul V. Johnston National Institute of Water & Atmospheric Research New Zealand 

Roderic L. Jones University of Cambridge UK 

Torben S. j0rgensen Danish Meteorological Institute Deamark 

Maria Kanakidou Centre National de la Recherche Scientifique France 

Igor L. Karol A.I. Voeikov Main Geophysical Observatory Russia 

Prasad Kasibhatla Georgia Institute of Technology US 

Jack A. Kaye NASA Goddard Space Right Center US 

Hennie Kelder Koninklijk Nederlands Meteorologisch Instituut The Netheriands 

James B. Kerr Atmospheric Environment Service Canada 

M.A.K. Khalil Oregon Graduate Institute of Science and Technology US 

Vyacheslav Khattatov Central Aerological Observatory Russia 

Jeffrey T. Kiehl National Center for Atmospheric Research US 

Stefan Kinne NASA Ames Research Center Germany 

D. Kinnison Lawrence Livermore National Laboratory US 

Volker Kirchhoff Instituto Nacional de Pesquisas Espaciais Brazil 

Malcolm K.W. Ko Atmospheric and Environmental Research, Inc. US 

Ulf K6hler Deutscher Wetterdienst Germany 

Walter D. Komhyr NOAA Climate Monitoring and Diagnostics Laboratory US 

Yutaka Kondo Nagoya University Japan 

Janusz W. Krzyicin Polish Academy of Sciences Poland 

Antti Kulmala Worid Meteorological Organization Switzeriand 

Michael J. Kurylo NASA Headquarters/NIST US 

Karin Labitzke Freie UniversitSt Beriin Germany 

Murari Lai Indian Institute of Technology India 

K.S. Law University of Cambridge UK 

G. LeBras Centre National de la Recherche Scientifique France 

Yuan-Pern Lee National Tsing Hua University Taiwan 

Franck Lefinm Mitfo France, Centre National de Recherches M<tforologiques France 

Jos Leiieveld Wageningen University The Netherlands 

Robert Lesclaux University de Bordeaux 1 France 



119 



Joel S. Levine 
Joel Levy 
J. Ben Liley 
Peter Liss 
David H. Lister 
Zenobia Litynska 
Shaw C. Liu 
Jennifer A. Logan 
Nicole Louisnard 
Pak Sum Low 
Daniel Lubin 
Sasha Madronich 
Jen7 Mahlman 
Gloria L. Manney 
Huiting Mao 
W. Andrew Matthews 
Konrad Mauersberger 
Archie McCulloch 
Mack McFarland 
Michael E. Mclntyre 
Richard L. McKenzie 
Richard D. McPeters 
Gerard Migie 
Paulette Middleton 
Alvin J. Miller 
Igor Mokhov 
Mario Molina 
Geert K. Moortgat 
Hideaki Nakane 
Paul A. Newman 
Paul C. Novelli 
Samuel J. Oltmans 
Alan O'Neill 
Michael Oppenheimer 
S. Palenni 
Ken Patten 
Juan Carlos Pelaez 
Stuart A. Penkett 
Joyce Penner 
Thomas Peter 
Leon F. Phillips 
Ken Pickering 
R. Bradley Pierce 
S. Pinnock 
Michel Pirre 
Giovanni Pitari 
Walter G. Planet 



NASA Langley Research Center US 

NOAA Office of Global Programs US 
National Insitutute of Water & Atmospheric Research New Zealand 

University of East Anglia UK 

Defence Research Agency UK 

Centre of Aerology Poland 

NOAA Aeronomy Laboratory US 

Harvard University US 

Office National d'Etudes et de Recherches A6rospatiales France 

United Nations Environment Programme Kenya 

University of California at San Diego US 

National Center for Atmospheric Research US 

NOAA Geophysical Fluid Dynamics Laboratory US 

California Institute of Technology/Jet Propulsion Laboratory US 

State University of New York at Albany/ASRC US 
National Institute of Water & Atmospheric Research New Zealand 

Max-Planck-Institut fiir Kemphysik Germany 

ICI Chemicals and Polymers Limited UK 

E.I. DuPont de Nemours and Company US 

University of Cambridge UK 
National Institute of Water & Atmospheric Research New Zealand 

NASA Goddard Space Flight Center US 

Centre National de la Recherche Scientifique France 

Science and Policy Associates US 

NOAA National Meteorological Center US 

Institute of Atmospheric Physics Russia 

Massachusetts Institute of Technology US 

Max-Planck-Institute fiir Chemie Germany 

National Institute for Environmental Studies Japan 

NASA Goddard Space Flight Center US 

University of Colorado US 

NOAA Climate Monitoring and Diagnostics Laboratory US 

University of Reading UK 

Environmental Defense Fund US 

Universita' degU Studi-l'Aquila Italy 

Lawrence Livermore National Laboratory US 

Instituto de Meieorologia Cuba 

University of East Anglia UK 

Lawrence Livermore National Laboratory US 

Max-Planck-Institut fUr Chemie Germany 
University of Canterbury New Zealand 

NASA Goddard Space Flight Center US 

NASA Langley Research Center US 

University of Reading UK 

Centre National de la Recherche Scientifique France 

Universita' degli Studi-l'Aquila Italy 

NOAA National Environmental Satellite, Data and Information Service US 



33 



120 



R. Alan Plumb 
Jean-Pierre Pommereau 
Lamom R. Poole 
Michael J. Prather 
Margarita Pr^ndez 
Ronald G. Prinn 
Joseph M. Piospero 
John A. Pyle 
Lian Xiong Qiu 
Richard Ramaroson 
V. Ramaswamy 
William Randel 
Philip J. Rasch 
A.R. Ravishankara 
William S. Reeburgh 
C.E. Reeves 
J. Richardson 
Brian A. Ridley 
David Rind 
Curtis P. Rinsland 
Aidan E. Roche 
Michael O. Rodgers 
Henning Rodhe 
Jose M. Rodriguez 
M. Roemer 
Franz Rohrer 
Richard B. Rood 
F. Sherwood Rowland 
Colin E. Roy 
Jocben Rudolph 
James M. Russell ID 
Nelson Sabogal 
Karen Sage 
Ross Salawitch 
Eugenio Sanhueza 
K.M. Sarma 
Toru Sasaki 
Sue M. Schauffler 
Hans Eckhait Scheel 
Ulrich Schmidt 
Rainer Schmitt 
Ulrich Schumann 
M.D. Schwarzkopf 
Gunther Seckmeyer 
Jonathan D. Shanklin 
Keith P Shine 
H.W. Sidebottom 



Massachusetts Institute of Technology US 

Centre National de la Recherche Scientifique France 

NASA Langley Research Center US 

University of California at Irvine US 

Universidad de Chile Chile 

Massachusetts Institute of Technology US 

University of Florida US 

University of Cambridge UK 

Academia Sinica China 

CWfice National d'Etudes et de Recherches A^rospatiales France 

NOAA Geophysical Fluid Dynamics Laboratory/Princeton University US 

National Center for Atmospheric Research US 

National Center for Atmospheric Research US 

NOAA Aeronomy Laboratory US 

University of California at Irvine US 

University of East Anglia UK 

NASA Langley Research Center US 

National Center for Atmospheric Research US 

NASA Goddard Institute for Space Studies US 

NASA Langley Research Center US 

Lockheed Corporation US 

Georgia Institute of Technology US 

Stockholm University Sweden 

Atmospheric and Enviroiunental Research, Inc. US 
TNO Institute of Environmental Sciences The Netheriands 

Forschungszentrum JUlich Germany 

NASA Goddard Space Flight Center US 

University of California at Irvine US 

Australian Radiation Laboratory Australia 

Forschungszentrum JUlich Germany 

NASA Langley Research Center US 

United Nations Environment Prdgramme Kenya 

NASA Langley Research Center US 

Harvard University US 

Instituto Venezolano de Investigaciones Cientificas Venezuela 

United Nations Environment Programme Kenya 

Meteorological Research Institute Japan 

National Center for Atmospheric Research US 

Fraunhofer Institut ftir Atmospharische Umweltforschung Germany 

Forschungszentrum JUlich Germany 

Meteorologie Consult Germany 

DLR Institut fUr Physik der Atmosphare Germany 

NOAA Geophysical Fluid Dynamics Laboratory US 

Fraunhofer Institute for Atmospheric Environment Germany 

British Antarctic Survey UK 

University of Reading UK 

University College Dublin Ireland 



34 



121 



p. Simmonds University of Bristol UK 

Paul C. Simon Institut d'Aeronomie Spatiale de Belgique Belgium 

Hanwant B. Singh NASA Ames Research Center US 

Paula Skfivinkovi Czech Hydrometeorological Institute Czech Republic 

Herman Smit Forschungszentrum Jiilich Germany 

Susan Solomon NOAA Aeronomy Laboratory US 

Johannes Staehelin Eidgenossische Technische Hochschule Zurich Switzeriand 

Knut Stamnes University of Alaska US 

L Paul Steele CSIRO Division of Atmospheric Research Australia 

Leopoldo Stefanutti Instituto di Riccrea suUe Onde Elettromagnetiche del CNR Italy 

Richard S. Stolarski NASA Goddard Space Flight Center US 

Frode Stordal Norsk Institutt for Luftforskning Norway 

A. Strand University of Bergen Norway 

B.H. Subbaraya Physical Research Laboratory India 

Nien-Dak Sze Atmospheric and Environmental Research, Inc. US 

Anne M. Thompson NASA Goddard Space Flight Center US 

Xue X. Tie National Center for Atmospheric Research US 

Margaret A. Tolberl University of Colorado US 

Darin W. Toohey University of California at Irvine US 

RalfToumi University of Cambridge UK 

Michael Trainer NOAA Aeronomy Laboratory US 

Charles R. Trepte NASA Langley Research Center US 

Adrian Tuck NOAA Aeronomy Laboratory US 

R. Van Dorland Koninklijk Nederlands Meteorologisch Instimut The Netheriands 

Karel Vanicek Czech Hydrometeorological Institute Czech Republic 

Geraint Vaughan University of Wales UK 

Guido Visconti Universita' degli Studi-l'Aquila Italy 

Andreas Volz-Thomas Forschungszentrum Jiilich Germany 

Andreas Wahner Forschungszentrum Jiilich Germany 

Wei-Chyung Wang State University of New York at Albany/ASRC US 

David I. Wardle Atmospheric Environment Service Canada 

David A. Warrilow UK Department of the Environment UK 

Joe W. Waters California Institute of Technology/Jet Propulsion Laboratory US 

Robert T. Watson Office of Science and Technology Policy US 

E.C. Weatherhead NOAA Air Resources Laboratory US 

Christopher R. Webster California Institute of Technology/Jet Propulsion Laboratory US 

D. Weisenstein Atmospheric and Environmental Research, Inc. US 

Ray F. Weiss Scripps Institution of Oceanography US 

Paul Wennberg Harvard University US 

Howard Wesoky National Aeronautics and Space Administration US 

Thomas M.L. Wigley University Corporation for Atmospheric Research US 

Oliver Wild University of Cambridge UK 

Paul H. Wme Georgia Institute of Technology US 

Peter Winkler Deutscher Wetterdienst Gennany 

Steven C. Wofsy Harvard University US 

Donald J. Wuebbles University of Illinois US 

Vladimir Yushkov Central Aerological Observatory Russia 



35 



122 



Ahmed Zand Tehran University Iran 

Rudi J. Zander University of Liege Belgium 

Joseph M. Zawodny NASA Langley Research Center US 

Reinhard Zellner Universitat Gesamthochschule Essen Germany 

Christos Zerefos Aristotle University of Thessaloniki Greece 

Xiu Ji Zhou Academy of Meteorological Science China 



Sponsoring Organizations Liaisons 

Rumen D. Bojkov World Meteorological Organization Switzerland 

K.M. Sarma United Nations Environment Programme Kenya 

Daniel L. Albritton National Oceanic and Atmospheric Administration US 

Michael J. Kurylo National Aeronautics and Space Administration US 

Coordinating Editor 

Christine A. Ennis NOAA Aeronomy Laboratory/CIRES US 

Editorial Staff 

Jeanne S. Waters NOAA Aeronomy Laboratory US 

Publication Design and Layout 

University of Colorado at Boulder Publications Service; 
Elizabeth C. Johnston 

Patricia L. Jensen 
Andrew S. Knoedler 

Conference Coordination and Documentation 

Rumen D. Bojkov World Meteorological Organization Switzerland 

Marie-Christine Charriite World Meteorological Organization France 

Christine A. Ennis NOAA Aeronomy Laboratory/CIRES US 

Jeanne S. Waters NOAA Aeronomy Laboratory US 

Conference Support 

Flo M. Ormond Birch and Davis Associates. Inc. US 
Kathy A. Wolfe Computer Sciences Corporation US 



36 



123 

Mr. ROHRABACHER. Dr. Albritton, I appreciate your fine testi- 
mony today and the testimony we've heard. 

I would suggest to our members that we go and vote and we 
come immediately back after the vote and then we will hear the 
next testimony and finish up the panel and then go into the ques- 
tion period. 

So we are in recess for ten minutes. 

[Recess.] 

Mr. ROHRABACHER. Ladies and gentlemen, we will move along. 
We will proceed. 

Dr. Watson, I want you to know that I am never concerned with 
people with beards who aggressively make their case. [Laughter.] 

Dr. Baliunas. 

STATEMENT OF DR. SALLIE BALIUNAS, SENIOR SCIENTIST, 
THE GEORGE C. MARSHALL INSTITUTE, WASHINGTON, DC 

Dr. Baliunas. Thank you. Mr. Chairman and Members of the 
Committee, I am a research astrophysicist. The following statement 
is my personal view of the technical issues and does not represent 
any institutional position. 

The following is drawn from the peer-reviewed literature and 
from the WMO reports. 

Chart 1 on the easel — thank you — shows ozone fluctuations be- 
tween 1957 and 1991 and these data are the northern hemisphere 
ozone measurements from ground-base stations. 

The ozone decrease over most of the world that is everywhere but 
the Arctic and Antarctic has been stated as roughly three-tenths 
percent per year between 1978-79 and 1994. 

However, note three aspects of the ozone record. 

First, accurately subtracting the large natural effects is difficult. 

And, two, selecting starting points for the analysis over relatively 
short records affects the outcome. 

And three, plotting the chart on this kind of scale magnifies very 
small changes. 

Now because they cover a longer interval of time than the sat- 
ellite data, these data more clearly reveal the extent of natural var- 
iability. The record also indicates the level of natural variability be- 
fore the 1970s, before any substantial anthropogenic impact on 
ozone. 

Now ozone levels change by a large amount every year between 
spring and fall. Over Washington, D.C., ozone varies annually by 
25 percent, some 80 times greater than the stated anthropogenic 
decline. An average season has been subtracted from the data in 
Chart 1, leaving other natural factors — for example, changes in the 
sun's ultra-violet output or changes in the upper atmosphere wind 
patterns of the earth, and any other trends. 

Additional factors which are not currently corrected in records 
may also exist. For example, decades-long shifts in meteorological 
patterns. 

Now the trends of ozone decline are usually established for two 
starting points— 1970 and 1978 or 1979. 

In the records shown in Chart 1, 1970 is the year of maximum 
ozone level for the entire 34-year record, and 1978-79 is a minor 
peak in the record. 



124 

Mr. RoHRABACHER. Excuse me for interrupting your testimony 
here. 

So you are saying that the year that is being used to judge all 
the rest of the years on the amount of ozone was one of the highest 
levels of ozone. 

Is that correct? 

Dr. Baliunas. Look on the chart. The very highest peak there — 
maybe Debbie could point to the year 1970, and follow it up to the 
top, the very highest peak in this 34-year record. A minor peak of 
1978-79, fortuitously, when the satellites happened to be launched, 
or coincidentally. 

Mr. ROHRABACHER. Okay. And you're suggesting that that skews 
the analysis? 

Dr. Baliunas. That choosing those end-points in a very short 
record, if one does not understand all the physical causes of ozone 
change, does tend to skew the records, indeed. 

Mr. ROHRABACHER. Thank you. 

Dr. Baliunas. And the fact that the observed trends depends on 
the selection of end points means that the trend has some uncer- 
tainty and is not reliably determined. 

Finally, Chart 1 shows the ozone fluctuations of a few percent on 
a greatly magnified scale. However, the zero point on the scale is 
missing. The total amount of ozone and its variations are shown in 
Chart 2. 

These are the exact same data as in Chart 1 and show the ozone 
fluctuations in perspective, and again, the seasonal data, the large 
seasonal data, are missing. 

Now as for the accelerated phase-outs, the observational evidence 
casts doubt on a substantial rapid thinning of ozone over most 

Mr. ROHRABACHER. Excuse me, again. Can you tell us what you 
think the significance of that chart is? 

Dr. Baliunas. The first chart shows that the small changes have 
been magnified on the scale. This chart shows the entire column 
of ozone above our heads. 

Mr. ROHRABACHER. And your conclusion from that is? I'm not 
going to put words in your mouth. I just want to know what you 
conclude because I think I know what you conclude. 

Dr. Baliunas. This is what the total amount of ozone looks like. 
One can draw one's own conclusion about the level of variability of 
several tenths percent per year, and determining that. 

Mr. ROHRABACHER. It doesn't look like there's much variation. 

Dr. Baliunas. It is difficult to see on this scale. 

Mr. ROHRABACHER. Thank you. 

Mr. Ehlers. Mr. Chairman, may I also ask a clarification on the 
chart? 

Mr. ROHRABACHER. Yes. Certainly. 

Mr. Ehlers. You said that this chart was the same as the pre- 
vious one, except you're including the whole scale. But wasn't the 
first one percent change rather than 

Dr. Baliunas. That's right, rather than the entire column. 

Mr. Ehlers. Now you don't have units on the first one. Are those 
percentage points? They're not Dobson units. 

Correct? 



125 

Dr. Baliunas. That's right. The average Dobson level on the 
other one is slightly over 300. You can tell by looking at this chart, 
by looking at the mean level there, zero. 

Mr. Ehlers. Right. But I'm just clarifying. 

Dr. Baliunas. Yes. The other chart is percent change from the 
average. 

Mr. Ehlers. And where it says minus two, it means minus two 
percent? 

Dr. Baliunas. Minus two percent. 

Mr. Ehlers. From the average. 

Dr. Baliunas. Right. 

Mr. Ehlers. Thank you. 

Mr. Olver. Mr. Chairman? 

Mr. Rohrabacher. Yes. 

Mr. Olver. As long as we're butting in here to clarify charts, 
may I do a little bit of that, too? 

Mr. Rohrabacher. That's absolutely fine, yes, sir. 

Mr. Olver. Dr. Baliunas, you just said — I think I heard you said 
a couple of times, the total amount of ozone. 

When you say the total amount of ozone, is that meant to mean 
the total amount of ozone in the atmosphere integrated over all de- 
grees? 

Dr. Baliunas. The Dobson unit is a column, one centimeter 
square, to be specific, above the ground. This is averaged over the 
northern hemisphere of ground station. 

Mr. Olver. The northern hemisphere. 

Dr. Baliunas. Northern hemisphere. It excludes the Arctic only 
from 30 degrees to 60 degrees north. 

Mr. Olver. So the data that you're talking about in this is an 
integrated set of columns from over the northern hemisphere 

Dr. Baliunas. From ground stations. From 30 to 60 degrees 
north, yes. 

Mr. Olver. Thirty to 60 degrees. 

Dr. Baliunas. That's right. 

Mr. Olver. Only in the northern temperate zone. 

Dr. Baliunas. That's right. 

Mr. Olver. Okay. 

Dr. Baliunas. This would cover — this is land-based stations in 
North America. 

Mr. Olver. Are these data in your — 

Dr. Baliunas. These are mentioned in the WMO report. They 
are included in my testimony. 

Mr. Olver. It's included in your testimony. 

Dr. Baliunas. They are not my research. It's peer-reviewed lit- 
erature, again. 

Mr. Olver. But just to make sure I understand. This is just the 
northern hemisphere. 

Dr. Baliunas. Right. Ground-base data, no ocean coverage. 

Mr. Olver. Could your aide show the previous chart again? It 
was on very briefly as I was coming back in, so that I might see. 

Dr. Baliunas. That's the percent change from that mean. 

Mr. Olver. In that northern temperate zone. 

Dr. Baliunas. In that same, right, northern hemisphere. 

Mr. Olver. Thirty to 60 degrees. 



126 

Dr. Baliunas. Right. And these two charts are included in the 
testimony. 

Well, indeed, based on these small trends, the 1994 world mete- 
orological executive summary estimates the cumulative ozone im- 
pact loss in the next 50 years if all the CFCs currently contained 
in refrigerators, air conditioners, et cetera, were released. 

Since most of the CFCs are already in the atmosphere, prevent- 
ing the release of CFCs in existing equipment would have little ef- 
fect. 

In fact, it would avoid an additional maximum ultra-violet-B ex- 
posure equivalent to a move 1,000 yards closer to the equator. 

Now the penalty for a four-year delay in the phase-out, what 
would the delay of setting back the manufacturing date for CFCs 
to the original year 2000 from 1996, cost in added UV-B exposure? 

Similarly, assume the maximum future loss of 1.5 percent as 
given in the WMO 1994 report for the northern mid-latitudes in 
summer and fall, and assume that loss, that maximum loss, is sus- 
tained for four more years. 

The effect of that four-year delay would be equivalent to moving 
20 miles closer to the equator for four years. Such small increases 
in UV-B are hardly significant when compared to the natural fluc- 
tuations in UV-B. For example, 50 percent seasonal changes. 

Given the background of large natural fluctuations, such small 
increases in UV-B also cannot be reliably extrapolated to yield a 
small risk. 

Mr. ROHRABACHER. Excuse me, again. I'm sorry for interrupting. 

You say the seasonal changes. When is the season that is the 
maximum UV-Bs? 

Dr. Baliunas. Spring, summer, fall. 

Mr. ROHRABACHER. That's the maximum time of exposure, when 
we have exposure for human beings? 

Dr. Baliunas. The maximum — let me get this exactly right. 

Over Washington, D.C., ozone varies 25 percent. 

Mr. ROHRABACHER. Right. 

Dr. Baliunas. And it drops from the spring to the fall and then 
recovers the following spring. 

Mr. ROHRABACHER. Okay. Now, let me put it this way, in another 
way. 

The ozone layer is thickest in the winter or in summer months? 

Dr. Baliunas. It is thickest in the — ozone levels drop in the 
spring. So it's thickest towards the spring in the northern hemi- 
sphere and drops in the fall. 

Mr. ROHRABACHER. Okay. You can continue. 

Dr. Baliunas. And, of course, the sun is changing at a slightly 
different angle. So the amount of UV-B exposure is maximum usu- 
ally in the late spring, early summer. 

Mr. ROHRABACHER. Okay. Go right ahead. 



127 

Dr. Baliunas. I'm finished. My last sentence, just to reiterate — 
the effect of the four-year delay would be equivalent to moving 20 
miles closer to the equator for four years. Such small increases in 
UV-B are not significant compared to the natural variations of 50 
percent at the latitude of Washington, D.C., and given this large 
backdrop, can't be extrapolated to meaningful levels of risk. 

Thus, the delay of four years would entail no significant risk to 
public health. 

[The complete prepared statement of Dr. Baliunas follows:] 



128 



Ozone Variations and Accelerated Phaseout of CFCs 
U.S. House of Representatives SubcsmSfittee on Energy and Environment 
5iM>bCT2io/t9e5 
Sallie Balinnas \ 



I am a research astrophysicist and Chair of the Science Advisory Board of the George C 
Marshall Institute, a nonpartisan science and public policy research group. The following 
statement is my personal view of the technical issues and docs not represent any institutional 
position. 

The accelerated phaseout of some stratospheric-ozone-depleting substances (SODS), 
moved from 2000 to 1996, arose partly from a 1992 prediction of severe ozone loss over North 
America. That prediction of severe loss is nov*' knovm to be incorrect Two topics will be 
reviewed to show why tfie accelerated phaseout mi^t be reconsidered: 

1. Global Ozone Chai^;e« 

The ozone decrease over the rest of the world — that is, everywhere but in the Arctic 
and Antarctic — has been stated as rougtily three-tenths of a percent per year between 1978- 
1979 (when satellites were launched to make the first global ozone measurements)) and 1991 
(before the eruption of Mt Pinatubo, which complicates the interpretation of tiw ozone record. 
There are two major difficulties in the analysis of the ozone record which affect the 
determination of a trend of a few tenths per cent per year: (1) accurately subtracting the nattiral 
effects; and (2) selecting starting points for ti^e analysis in relatively short records. 

Qiazt 1, showing the ozone fluctuations between 1957 and 1991 (prior to the eruption of 
Mt Pinatubo), underecores the difficulties involved in determining a trend of a few tenths 
percent per year: These data are the Northern Hemisphere (latitudes 30 to 60 degrees N) ozone 
measurements from ground-based stations (Krzyscin 1994). Because they cover a longer 
interval of time than the satellite data, they more dearly reveal the extent of natural variability, 
and thus the difficulty of determining the SODS<aused trends. The record is also of interest 
because it indicates the level of natural variability before the 1970s, and before the significant 
buildup of SODS in the atmosphere and thtts any substantial anthropogenic impact on ozone. 

The first diffimlty in determining a trend as small as 0.3% per year is the fact fiiat ozone 
levels vary ruiturally by large amoimts. For example, ozone levels drop by a larg^ amount 
every year between spring and fall (in the Nortiiem Hemisphere) and tficn recover. Over 
Washington, DC, ozone varies annually by 25%, some 80 times greater than the stated 
an thr opo gen ic decline. 

Ozone also varies because of other natural factors, including changes in the upper 
atmosphere wind patterns of the earth (the quasi-biennial oscillation, or QBO, which introduces 
ozone fluctuations over periods of 2-3 years), and the sim's xdtravioJet output, which varies 
every 11 years. Additional factors which are not corrected in the records may exist, for 
example, decades-long shift in meteorological patterns (Komhyr et al. 1991). 

Because the magnitudes of these natural effects are so large, they must be accurately 
knovwi before the anthropogenic trend can be deduced firom the data. One of the important 
factors contributing to dUs natural variability is changes in the sun's ultraviolet flux, which 
catise the creation and dissociation of ozone. But large variations in the stm's ultraviolet output 
are known to occur and are unpredictable. Furdiermore, tiiey have not been measured 
accurately even for one solar cycle. Instead, proxies are used to estimate the ultraviolet flux 
changes, for example, the 10.7 cm radio flux. NASA-Goddard researchers (Herman et al. 1991) 
found that ozone increased from 1978 - 1991 after they subtracted from the satellite ozone data 



129 



the known influences as well as the proxy of tfie solar effect. That increase is an error that 
means that the estimate of the solar contribution by proxy is uncertain. 

Fiirther evidence of the difficulty in subtracting the effects of solar variability by proxy 
can be seen in the earKer ozone measuicments (Chart 1). In 1957 the most intense peak in the 
entire four-century span of sunspot observations was recorded. That highest of sunspot peaks 
should have produced the highest ultraviolet output from Ae stm, and therefore, a very hi^ 
ozone peak. Yet the ozone from tiie Northern Hemisphere shown in Chart 1 was very low in 
the late 1950s - roughly as low as at present If the proxy method were used to estimate the 
effect of the sun on ozone in 1957-58, the very high ultraviolet flux expected for the sun would 
lead to a substantial reduction in the corrected ozorw levels. The corrected 1957-58 levels would 
appear even lower than they are in the chart. This result reveals both the uncertainty of the 
pro5<y method and the large range of natural variability. 

Two additional features to note in this record are: 

(i) The trends in ozone decUne in the 1994 WMO report are estimated for two starting 
points: 1970 and 1978-79 (the latter is the start of the global ozone records measured by 
satellites). But trend analyses based on relatively short tlrrve intervals can be skewed by the 
endpoints choeen. In fact, in the case of the Northern Hemisphere data shown, 197D is a year of 
maximum ozone abundance for tiie entire 34-year record, and 1979 is a minor peak of ozone in 
the record. So choosing 1970 or 1978-79 as tiSe starting point creates the maximum possible 
downward trends in ozoi\e since Sien. The selection of other starting points, for example, 1976 
or 1957, would indicate no significant downward trend since ther\. The fact that the inferred 
trend depends entirely on the selection of the endpoints meai\s ftat the trend has not been 
reliably detemuned. 

(ii) Plotting the data in tiiis way emphasizes very small changes in ozone. Chart 1 
shows the ozone fluctuation of a few percent on a greatly magnified scale, after the average 
seasonal fluctuation has been subtracted. However, the zero-point of the scale is missing. The 
total amount of ozone and its variations are shown in Chart 2. These are the same data as m Chart 
1. On this scale, the fluctuations in ozone are seen to be insignificant. 

A longer ozone record comes from Tromso, Norway (Henriksen et aL 1994). It covers a 
very limited geographical region, but spans some 50 years, from 1935 to 1989. Although these 
measurements are less precise than the satellite measurements, they give a better indication of 
natural variability because of the greater lengti\ of the record. This 50-ye» record shows large, 
natural fluctuations over Tromso. For example, ozone dropped 15% over tiiree years in ttie 
early 1940s. In the early 1960s, the ozone was roughly 10% lower than today. All these 
fluctuations occurred prior to widespread use of SODS, and must be natur^^L 

2. Uhniviolet-B 

Instead of increasing, UV-B measured at eight stations either decreased or did not 
change at ground level between 1974 and 1965 (Scotto et al. 1988). A recent recalibration of 
those data by NOAA researchers (DeLuisi et al., 1995, private communication) yields a 
tentative, small positive trend, but only for dear sky conditions, with no significant, increasing 
trend for all-«ky data. A sustained effort of UV-B monitoring from 1975-1990 at a Smithsonian 
laboratory in Maryland (Correll et al. 1992) shows that UV-B dosage dropped 2D% there 
(latitude 40N) between 1979 and 1990, when ozone dechrwd about 3-4% . 

Toronto researchers (Kerr and McElroy 1993) began a high-quality UV-B measuring 
program in 1989. Those data, properly reanalyzed by Michaels et aL (1994), aiul recent 
unpublished updates iiKhided in the 1994 WMO report, also show no significant increasing 
trend in UV-B. 



130 



The Executive Summary of the 1994 WMO report concludes: "Uncertainties in 
calibration, influence of tropospheric pollution, and difficulties in interpreting data from broad- 
band instruments continue to preclude the unequivocal identification of long-term trends^ (p. 
xv)" 

As for media reports of eye and sidn diseases increasing in Chile during times of ozone 
declines and UV-B increases related to the Antarctic polar vortex, a team of Johns Hopkins 
physicians and researchers (Schein 1995) foimd "no increase in ... conditions attributable to UV- 
B exposure ... for periods of known ozone depletion compared with control periods." Those 
researchers note that the extra UV-B exposure on a few days resulted only in a 1% increase in 
annual UV-B exposure. 

Coftdtisions 

The observational evidence casts doubt on (a) a substantia! thinning of ozone over most 
of the world, and (b) iricreasing trends in UV-B radiation. The accelerated phaseouts, such as 
the 1992 decision to end U.S. production of some SODS at the end of this year instead of 1999, 
occurred partly in response to theoretical predictioi« made in 1992 of severe ozone depletion 
for the high latitudes of North America. The magnitude and impact of that prediction are now 
seen to have been greatly exaggerated, [n fact, the 1994 WMO report (p. 3.29) says, "In the 
Arctic, ozone increases are found in both 1992 and 1993..." 

Some replacement coolants are posited as strong agents of global waurming, and have 
entered the international negotiatior\s on limits to greenhouse gases. Current policy discussions 
to eliminate from use those replncement chemicals threaten to create another series of phaseouts 
to some yet as undefined substitutes. 

According to the WMO 1994 Executive Summary, eliminating all emissions of methyl 
bromide from agricultural, structural and industrial use in 2001 would alleviate some of the 
cumulative ozone loss over the next 50 years. Assuming the maximum theoretical UV-B 
increase from the cumulative loss of ozone, how much additional UV-B exposure wiD be 
averted by this proposed elimination of methyl bromide? Since UV-B strengthens toward the 
equator, the maximum projected UV-B dosage avoided is equivalent to a move less than three 
miies closer to tiw equator. 

The 1994 WMO Executive Summary also estimates the ciunulative ozone loss in the next 
50 years if all CFCs currently contained in refrigerators, air conditioners, etc, were released. 
Since most of the CFCs are already in the atmosphere, preventing the release of CFCs in 
existing equipment would have little effect. In fact, it would avoid an additional maximum UV- 
B exposure equivalent to a move 1000 yards closer to the equator for 50 years. 

Peaalfy for a 4-year delay in SODS pha5«out 

What would a delay of 4 years — setting the date of the manufacturing ban for CFCs 
like CFC-11 and CFC-12 back to tiie original year 2000 from 1996 - cost in added UV-B 
exposure? Assume that the maximum future loss of 1.5%, as given in the WMO 1994 Executive 
Summary for Northern midlatitudes in summer and fall, is sustained for 4 more years. The 
efiect of the 4-ycar delay would be equivalent to moving less th/m 20 miles closer to Ae e<{uator 
for 4 years. Such small increases in UV-B are hardly sigruficant compared to the natural 
fluctuations in UV-6, for example, 50% seasonal changes at the latitude of Washington, EXZ. 
Thus, the delay woxild entail no significant risk to public health. 



131 




132 




133 

Mr. ROHRABACHER. Dr. Setlow, we'd ask you to testify now. And 
then right after your testimony, we will then break for the vote and 
come back for the final witness, and then for questions for the 
whole panel. 

I think that's probably the best way we should go about it. 

Dr. Setlow. 

STATEMENT OF DR. RICHARD SETLOW, ASSOCIATE DIRECTOR, 
LIFE SCIENCES, BROOKHAVEN NATIONAL LABORATORY, 
UPTON, NY 

Dr. Setlow. Thank you, Mr. Chairman. 

I'm going to speak about biology in two aspects. One is to tell you 
a fish story, and I'm sure in Congress, you're very familiar with 
such things. 

The second is to tell you something about the uncertainties in 
our knowledge. You've just been hearing about the uncertainties in 
our physical knowledge. I assure you that the uncertainties in our 
biological knowledge are much, much greater, probably ten- to a 
hundred-fold greater. 

We don't know how to extrapolate or predict what the biological 
effects might be of ozone depletion and ultra-violet increases at the 
surface of the earth among humans, plants, animals, eco-systems 
and so on. 

I just want to call your attention to the fact that in a rational 
world, the funding should be proportional to the uncertainty. If 
we're uncertain about something, we should put more money into 
finding that out than if we're not. 

In the case of the ozone depletion story, the funding has been in- 
versely proportional to the uncertainty. The greater the uncer- 
tainty, the less the funding. 

That is to say, biology has never received adequate funding to 
solve the questions, the answers to which you need. And I will ex- 
emplify this with a fish story and tell you a little bit about skin 
cancer and melanoma. 

You have to remember that cancer is a very complicated disease. 
It involves many steps — initiation, progression, immune-surveil- 
lance, and so on. 

We don't know which is the rate-limiting step in environmental 
carcinogenesis. Remember that. 

I'm going to describe to you an experiment that tells you about 
the initiation, the start of the process, by producing damage to 
DNA, and we know that damage to DNA is important because indi- 
viduals who are defective in the ability to repair DNA have skin 
cancer prevalances 1000 or more fold greater than the normal. 

But we don't know about the normal population. We know about 
the repair-deficient population. 

So what we really need is some knowledge about animal models. 
Since we don't easily do experiments on people, we're not permitted 
to do that, and we have to count on epidemiological data, and the 
epidemiological data really are built upon a pre-conceived notion of 
animal models, we must rely on animal models. 

There is no good animal model at the moment that will tell us 
what wavebands of ultra-violet give rise to melanoma. 



134 

I assume you all know that most skin cancer comes from sun- 
light exposure. But which portions of sunlight is the question. 

The only convenient model at the moment is a model using fish, 
small tropical fish that have been bred to be very sensitive to mela- 
noma induction, deliberately. So that a short exposure in the lab- 
oratory of these little fish gives rise to the start of a melanoma that 
is perceptible by a few months and can be scored. And in this way, 
we measure the sensitivity as a function of wavelength, inducing 
melanomas. 

We find that the most sensitive wavelength is in the UV-B re- 
gion of the spectrum. But that is not the whole story because we 
have to worry about how much UV-B and UV-A is actually in nat- 
ural sunlight. There's much more UV-A in sunlight than UV-B. So 
what we're really interested in is the product of the two. 

I have a table in my text which shows for nonmelanoma skin 
cancer and for melanoma skin cancer, the values for UV-A and 
UV-B, the sensitivities per unit energy, and how much of skin can- 
cer on a mouse model for humans would give rise to nonmelanoma 
skin cancer — about 95 percent, roughly speaking, of UV-B is the 
important one. 

In the case of melanomas, 90 percent of the effect would come 
from UV-A. 

Now when I say melanomas, you must remember, these are ex- 
periments done with fish. Are you willing to extrapolate from fish 
to humans? Well, I'm willing to extrapolate from fish to humans 
because, after all, fish have DNA. They have melanocytes. They 
have melanin. And they get melanomas. 

Many people are not very happy about extrapolating this fish 
story to humans, and so that's an uncertainty. The big uncertainty 
lies not in the data on fish, but on whether it's valid to extrapolate. 
This is a big biological problem. 

Moreover, our experiments deal with the initiation, the first step 
in cancer induction in these fish because they've been bred to be 
sensitive to that. 

What about all the other steps in humans — progression, immuno- 
surveillance? How do they depend upon wavelength? 

So the point I'm trying to make is that the cancer depends on 
lots of steps about which we have limited knowledge. We know one 
step very carefully for fish. We know some of these steps for mice 
for nonmelanoma skin cancer. 

My conclusion is that the large increase in skin cancer over the 
years, especially melanoma, I should say, over the years, four to 
five percent per year, well documented, good scientific, peer-re- 
viewed data, arises obviously not from anything to do with ozone 
depletion because melanoma has been increasing for 50 years. 

It has to do with our lifestyles, how we go out in the sun, how 
we apply sunscreens. Sunscreens screen out the UV-B. And those 
of us that like to go out in the sun put them on and stay out for 
a longer time and we get UV-A. 



135 

And so, hypothetically, this is the reason for the increase in 
melanoma. It is our Ufestyle. It is not ozone depletion. 

Whether you make the extrapolation, as I say, requires other 
models and a lot more knowledge. 

Thank you. 

[The complete prepared statement of Dr. Setlow follows:] 



136 

Testimon^f Richard Setlow 
f before the 
United States^Housfr-ofl^epresentatives 

Conmittee on Science 
Subcommittee on Energy and Enviroranent 



September 20. 1995 



Sunlight and Malignant Melanoma: 

Prediction of the Effects of Ozone 

Depletion and Sunscreen Use 



137 



Sunlight and Malignant Helanooa: Predictions of the Effects 
of Ozone Depletion and Sunscreen Use 

Richard Setlow* 

Brookhaven National Laboratory 

Upton. New York 11973 

Before discussing sunlight exposure and human skin cancer. I make a 
few general philosophical remarks on the concerns of ozone depletion and 
UV increases. The concerns are mostly biological --the effects on humans, 
animals, plants, and terrestrial and aquatic ecosystems. The quantification 
of these concerns involves the product of two different estimations: 1) 
the increase in UVB for a given decrease in stratospheric ozone and 2) the 
increase in biological effects for a given increase in UVB. The first is 
estimated from physical and chemical measurements and theory and has uncer- 
tainties of - 10-203;. The second depends on biological measurements and 
theory and is uncertain, I am sorry to say, by a factor of 2-10, i.e. 
lOO-l.OOOX. There is an impedance mismatch between the physicochemical and 
the biological uncertainties. Even if we knew the physicochemical values with 
great precision, we cannot now predict the biological effects with certainty. 
It should be obvious to you that the funding- -the determiner of scientific 
effort --should be proportional to the uncertainty. I regret that since the 
1970s through the present the funding has been inverslv proportional to the 
uncertainties, the greater the uncertainty, the less the funding. Thus, 
for example, it is not clear which of the several steps in carcinogenesis- - 
initiation, promotion/progression, immunological surveillance, metastasis- -is 
the rate limiting step for skin cancer induction in normal humans. This is 
especially the case for melanoma. 

A recent article (Journal of the American Medical Association. August 9, 
1995, page 445) indicates that there are "now an estimated 1 million new cases 
of skin cancer each year in the United States." Skin cancer deaths number 
- 9,000 per year of which 7,200 are due to malignant melanoma. Malignant 
melanoma of the skin has been increasing A-SX per year for approximately 50 
years- -obviously not the result of changing ozone. It is associated in a 
complex way, compared to non-melanoma skin cancer, with exposure to sunlight 
(Armstrong & Kricker, Melanoma Res. 3, 395-401 [1993]). It is more connnon 



*I am a Sr. Biophysicist and the Associate Director for Life Sciences. I have 
a Ph.D. in Physics from Yale University and have been working in the field of 
biophysics and on the effects of ultraviolet radiations on molecules, viruses, 
cells, and animals since the early 1950s. I was elected to the National 
Academy of Sciences in 1973 and have served on numerous coiranittees dealing 
with the effects of radiations. I was a member of the National Research 
Council Climatic Impact Committee from 1972 until it issued its Report in 
1975. I have been recognized nationally and internationally for my work. 
My most recent research deals with an experimental model --fish- -that may 
be used to determine the wavelengths effective in melanoma induction. 



138 



in fair skinned individuals and its prevalence is higher at low latitudes. 
The fact that individuals deficient in repair of DNA damage have a melanoma 
prevalence over 1,000 -fold greater than normal individuals is evidence that 
sunlight -induced DNA damage is an initiating stimulus for melanoma. The 
effects of DNA damage are ameliorated, in part, by human DNA repair systems, 
systems that may be quantitatively more effective than in mouse or in fish. 

Epidemiological evidence and data from experiments with mice indicate 
that chronic exposure to UVB- -the shorter UV in sunlight that is absorbed 
by DNA and is mostly screened out by stratospheric ozone- -is the most 
effective spectral range for inducing non-melanoma skin cancer. Similar 
data for malignant melanoma are not as clear, but they indicate that the 
spectral regions not affected by ozone depletion- -presumably the longer 
UVA wavelengths- -are important ones. At present, the only useful animal 
model to measure the wavelengths effective in light-induced melanoma induction 
is small backcross hybrid tropical fish, bred to be very sensitive to induc- 
tion. (Several mammalian models are now being developed.) The biological 
effect of UV depends upon the biological sensitivity in different spectral 
regions, such as UVB and UVA. the amount of sunlight in these spectral regions 
and how the biological response varies with the dose- -the dose-response rela- 
tion. The latter is not really known for human melanoma induction. However, 
the wavelength sensitivity for the initiation of melanoma is known from 
experiments on fish. There is appreciable sensitivity for melanoma induction 
in the UVA region. Because of the large amounts of UVA in sunlight, the UVA 
in sunlight is the most effective spectral range for melanoma induction in 
fish. Is it appropriate to extrapolate from fish to humans? I think so. but 
there is no consensus yet. The wavelength sensitivities of the other steps 
in carcinogenesis are not known although human epidemiological data seem to 
indicate that UVB exposure is not of major importance (Magnus. Int. J. Cancer 
47. 12-19 [1991]). A simple summary of our results is given in the following 
table. 



APPROXIMATE RELATIVE VALUES FOR SKIN CANCER 
INDUCTION BY UVB AND BY UVA 



Non- melanoma (mouse) 





energy in 
sunlight 


X 


sensitivity per ^ 
unit energy 


^ sensitivity 
to sunlight 




UVB 
UVA 


1 
50 




1 

0.001 




1 
0.05 1 


95* from 
UVB 


Melanoma (fish) 














UVB 
UVA 


1 
50 




1 

0.2 




1 

> 

10 


90* from 
UVA 



139 



The results on fish- -a fish story- -if extrapolated to humans indicate: 
1) any ozone depletion and attendant UVB increase will have only a small 
effect on melanoma induction, and 2) the use of sunscreens that principally 
absorb UVB. so as to minimize sunburn, encourage individuals to spend more 
time in the sun and so increase their UVA exposure and increase the risk of 
melanoma initiation. A recent case-control epidemiological study indicates 
that melanoma prevalence is higher among individuals using sunscreens than 
those who do not (Int. J. Cancer 61, 749-755 [1995]). 

A brief summary of our experimental results is given in a chapter in 
a book entitled. Ozone - Sun - Cancer: Molecular and Cellular Mechanisms 
Prevention Conference , published in 1995. A copy of the chapter is attached. 
I would appreciate it if it were included in the record of my testimony. 



140 



FocuS 

Ozone 

Sun 
Cancer 

Molecular and cellular 

mechanisms 

Prevention 

L. Dubertret, R. Santus, P. Morliere 

editors 



1995 



IHlllll/llllll 

LES EDITIONS 

IMSBHiVl 



141 

Cancer of the melanocytic system 

R.B. Setlow* 



Most skin cancer among Caucasians is associated with exposure to sunlight 
[1], and damages to cellular DNA are implicated as initiating events be- 
cause repair-deficient individuals (xeroderma pigmentosum) are orders of 
magnitude more susceptible than normal individuals. Within reasonably 
homogenous populations, skin cancer increases toward low latitudes, but 
this association does not indicate the wavelength regions involved in cancer 
induction. At present, the only animal model suitable for determining the 
wavelengths effective in melanoma induction are certain inter- and intra- 
species hybrids of the small fish, Xiphophorus. Genetic evidence indicates 
that the hybrids contain only one tumor suppressor gene and, therefore, are 
very sensitive to cancer induction by single exposures to light [4]. I and my 
colleagues [3] exposed 5-day old fish, in spectrophotometer cuvettes, to dif- 
ferent monochromatic wavelengths and fluences. The fish were kept for two 
months in tanks shielded with yellow plastic, so as to minimize the possibil- 
ity of photoreactivation, and were scored at four months. The melanoma 
prevalence increased with exposure to a maximum of ~ 0.5 (Fig. 4-1). The 
fluence-response curves were fitted to surviving fraction = a + b (l-e'"^), 
where a is the background prevalence with no exposure, b is the maximum 
induced prevalence, k is the sensitivity parameter (the cross section for mel- 
anoma induction), and E is the incident fluence. The value of k at 302 nm 
was 0.05 mVJ giving a mean melanoma inducing exposure, for swimming 
fish, of 200 J/m^, corresponding to 3.5 cyclobutane pyrimidine dimers per 
Mbp of DNA in irradiated fish skin. At this wavelength the mean erythemal 
dose for a stationary human is 400 J/m^ [2]. 

The sensitivities at the other wavelengths tested, relative to the value of 
1.00 at 302 nm, are given in Fig. 4-2a, along with the action spectrum for 
human erythema and the mid-summer sun's spectrum at 41°N latitude. 
The melanoma sensitivity in the UVA^ region is orders of magnitude greater 

* Biology Department, Brookhaven National Laboratory, Upton, New York 11973 
USA. 



142 



Photocarcinogenesis anirnal models 127 



• • 


(a) 




9* 






O 

3 " 






r 










6 oj- 










«j- 










01 















1000 MOO •000 SOOe moo 7000 




1000 



MOO MOO 



Fig. 4-1 Fluence response curves for melanoma induction in hybrid fish by 
a) 405 nm, and b)313 nm. The errors are standard deviations. The background 
level at 405 nm is less than at 313 nm. The latter experiment used fish maintained 
in the ambient light of a shaded greenhouse. The former used fish maintened in 
tanks screened, for two months, by yellow plastic. We interpret the difference as 
indicating that visible light is effective in melanoma induction. 



128 Ozone sun cancer 



143 



1 10^ 



(a) 




Human Efythenu <j, 
Pamsh. et al . 1982 



■1 



300 340 3«0 

Wavdengtti (nm) 



- (b) 




A 



Human "O 

E(yni«na \ - 

^(jVB— UVA «— vtsiWt 

J I y L 



260 300 340 380 420 

Wavelength (run) 



Fig. 4-2 a: Action spectra for melanoma induction and human erythema normal- 
ized to 1.00 at 302 nm. Note the exponential sensitivity scale, b: The relative sun- 
light effective dose versus wavelength. 



than for erythema, and sunHght contains much more UVA than UV B. The 
product of the sun's spectrum multipHed by the action spectrum is the rela- 
tive sunhght dose as a function of wavelength (Fig. 4-2b). If the human ac- 
tion spectrum were similar to the fish spectrum, UV B would contribute 
only 5 to 10% of the melanoma inducing effect and 90 to 95% could be as- 
cribed to UV A and visible. Hence, O3 depletion would have a negligible ef- 
fect on melanoma incidence. The high sensitivity to UV A may be explained 
by free radicals or other activated products formed in melanin which then 
may affect cellular DNA. Since most sunscreens absorb much more UV B 
than UVA [1]. Individuals who use UV B sunscreens and increase their ex- 
posure time to the sun, would increase their UV A carcinogenesis dose. An 
8-fold increase in exposure time by an individual using an SPF 8 UV B sun- 
screen would result in a 5 to 6-fold increase in melanoma inducing dose. 

Hence, the habits of sun exposure, especially the use of sunscreens, would 
greatly increase the melanoma inducing dose and could be responsible for 
the melanoma epidemic and exponential increase, 5% a year for 40 or more 
years. 



144 

Photocarcinogenesis animal models liiy 

This work was supported by the Office of Health and Environmental Research 
of the U.S. Department of Energy. 



Key-note references 

1. DiFFEY BL: The need for sunscreens with broad spectrum protection. In Urbach 
F (Ed.), Biological Responses to Ultraviolet A Radiation, Valdenmar Pub. Co. Over- 
land Park, Kansas, 1992, pp. 321-328. 

A careful examination of monochromatic protection factors and the relative expo- 
sures as a function of wavelength when using different sunscreens. 

2. Parrish JA, Jaenicke KF, Anderson RR: Erythema and melanogenesis action 
spectra of normal human skin. Photochem Photobiol 1982 36: 187-191. 

Data from 250 nm to 405 nm (see Fig. 4-2a). Note that the values of the ordinate 
in Fig. 4-la of this reference are too large by a factor of 10. 

3. Setlow RB, Grist E, Thompson K, Woodhead AD: Wavelengths effective in in- 
duction of malignant melanoma. Proc Natl Acad Sci USA 1993 90: 6666-6670. 

The fish model, described in ref 2, was used to determine the melanoma suscepti- 
bility to single exposures to 302, 313, 365, 405, and 436 nm (see Fig. 4-2a). 

4. Setlow RB, Woodhead AD, Grist E: Animal model for ultraviolet radiation- 
induced melanoma: Platyfish-swordtail model. Proc Natl Acad Sci USA 1989 86: 
8926-8926. 

A description of useful animeil models, Xiphophorus maculatus xXiphophorus hel- 
leri backcross hybrids that develop malignant melanomas within 4 months of expo- 
sure to sunlamp radiation > 290 nm or > 304 nm delivered as one or 20 treatments. 
Exposure of the fish to visible fluorescent light after UV reduces the tumor preva- 
lence to background levels. 

5. Urbach F: Ultraviolet radiation and. skin cancer. In Smith KC (Ed.), Topics in 
Photomedicine, Plenum, New York, 1984, pp. 39-142. 

A comprehensive review of the photobiology, epidemiology and clinical aspects of 
non-melanoma and melanoma skin cancer throughout the world. 



145 

Mr. ROHRABACHER. Doctor, thank you very much. We're going to 
break now and just go vote and come right back and proceed with 
the testimony and then the questioning with the entire panel. 

So this hearing is now in recess. 

[Recess.] 

Mr. RoHRABACHER. The hearing will come back to order and 
move forward. As Members come in, we will permit them to partici- 
pate. I'd like to thank all the witnesses so far. We're going to have 
questions and answers of the entire panel after Dr. Kripke presents 
her testimony. And then, we will break for lunch after the ques- 
tioning of this panel and before we call the next panel. 

So, Dr. Kripke. 

STATEMENT OF DR. MARGARET L. KRIPKE, PROFESSOR AND 
CHAIRMAN, DEPARTMENT OF IMMUNOLOGY, UNIVERSITY 
OF TEXAS, M.D. ANDERSON CANCER CENTER, HOUSTON, TX 

Dr. Kripke. Thank you, Mr. Chairman. 

My name is Margaret Kripke and I am here as a scientist who 
works in the area of health effects of UV-B radiation. 

My research over the past 20 years or so has focused on the role 
of UV-B radiation in both melanoma and non-melanoma skin can- 
cer and on the effects on the immune system. 

In addition, I currently serve on the United Nations Environ- 
ment Programme Panel that reviews the health effects of ozone de- 
pletion according to the Montreal Protocol. And much of my testi- 
mony today is based on the panel's 1994 assessment, which rep- 
resents the collective wisdom of scientists all over the world who 
carry out research in this field. 

And it is, if I may paraphrase, the conclusion of this document 
that even a small increase in UV-B radiation present in sunlight 
is likely to have important consequences for plant and animal life 
on earth and will almost certainly jeopardize human health. 

The best studied harmful effect of UV-B radiation on human 
health is the induction of non-melanoma skin cancers, basal and 
squamous cell carcinomas. 

Now, as has been mentioned earlier, the incidence of these skin 
cancers in the United States is already enormous. It's approaching 
a million new cases per year. This number has been increasing 
steadily over the past several decades. 

And additional increases, beyond those already observed, will 
certainly result from ozone depletion. 

You also heard this morning that currently CFC phase-out sce- 
narios predict that stratospheric ozone levels will reach a minimum 
in the next few years and then will gradually return to baseline 
levels by about the year 2050. 

Well, what will that do to skin cancer incidence? 

Because of the long latent period, the lag period from ultra-violet 
exposure to skin cancer incidence, this means that the increase in 
skin cancer incidence will be with us much longer than 2050. 

In fact, it will probably only begin to peak in around the year 
2050. 

So the skin cancer increases due to increased ultra-violet radi- 
ation are likely to be with us well into the next century and clear 
to the end of the next century. 



146 

Chronic exposure to ultra-violet radiation also is associated with 
several harmful effects on the eyes. The most important of these 
is cataract, which causes blindness in about 17 million people 
world-wide. And it is clear that the incidence of cataract will in- 
crease if UV-B levels rise. 

Now, what about melanoma skin cancers? 

As you heard from Dr. Setlow, there is great uncertainty in the 
wavelengths of ultra-violet light that contribute to melanoma. 
These uncertainties preclude our ability to estimate the impact of 
ozone depletion on this tjrpe of skin cancer at the present time. 

It is very important to know what are the wavelengths of ultra- 
violet light involved in melanoma skin cancer. If UV-B is the pre- 
dominant wavelength, then the impact of ozone depletion can be 
considerable. 

If UV-A is the principal cause of melanoma, then the impact of 
ozone depletion is much less. 

But I will point out, based on Dr. Setlow's testimony, that the 
effect is not zero. 

There is some circumstantial evidence in humans for a causal 
role of UV-B radiation in melanomas from past studies, but I think 
there is newer data from molecular approaches to this problem that 
promise to provide us with a more direct answer to this question. 

Very recent molecular studies on human melanomas point to a 
role for UV-B radiation in melanoma induction, but so far, they do 
not point to a role for UV-A radiation. 

Now although these findings are still preliminary and incom- 
plete, they point very strongly toward a causal role of UV-B radi- 
ation in the development of some melanomas in humans. 

UV-B radiation also perturbs the body's immune system. Now 
our immune system is what protects us against infectious diseases 
and certain kinds of cancer. And so, an3rthing that could have an 
impact on immune function has the potential to jeopardize human 
health by increasing the incidence or the severity or the duration 
of infectious diseases and certain kinds of cancers as well. 

The ability of UV-B radiation to alter and to decrease the body's 
immune function is well demonstrated in laboratory animal mod- 
els. It has also been demonstrated in animal m.odels that ultra-vio- 
let radiation decreases immunity to infectious agents, such as her- 
pes virus, leishmania, mycobacterial infections, which cause leprosy 
and tuberculosis, Candida, trichinosis, Lyme disease, the list goes 
on. 

In most of these disease models, immune responses to the infec- 
tious organisms are diminished and the severity or duration of dis- 
ease is increased. 

There is now also substantial evidence that UV-B radiation can 
alter and decrease immune function in humans, including one 
study showing that the immune response to leprosy is decreased in 
human skin exposed to UV radiation. 

This study is one of the only ones available in humans that in- 
vestigates the effect of ultra-violet radiation on the immune re- 
sponse to an infectious organism. 

But I think the message is very clear. Both the animal studies 
and the limited data available in humans give us reason to believe 



147 

that increased UV-B radiation could increase the severity of some 
infections in human populations. 

Furthermore, skin pigmentation, which is protective against skin 
cancer, does not provide much protection against the immuno- 
suppressive effects of ultra-violet light in humans, suggesting that 
the population at risk is very large and not limited to the light- 
skinned individuals who are at risk for skin cancer. 

Now because infectious diseases constitute an enormous public 
health problem world-wide, any factor that has the potential to re- 
duce immune defenses and increase the severity of infectious dis- 
eases is likely to have a devastating impact on human health. 

At the present time, however, not a single prediction about the 
impact of ozone depletion on a single infectious disease in a single 
geographic location in human beings is available. 

And this is not because the problem is not important, but it is 
because there is no information on which to base this type of an 
assessment. 

My last point is that, finally, UV-B radiation may also adversely 
affect human health indirectly, by interfering with the food chain, 
by means of its effects on crops, plants and marine organisms. 

I think it is very ironic and very unfortunate that the two poten- 
tial health consequences of ozone depletion that could have the 
greatest impact on human health by affecting the food supply, by 
affecting infectious diseases, which are in fact the two greatest 
health problems in the world, are the two areas in which we have 
the least amount of available relevant information. 

Thank you, Mr. Chairman. 

[The complete prepared statement of Dr. Kripke follows:] 



148 



HUMAN HEALTH EFFECTS OF ULTRAVIOLE T-B RADIATION 




Kripke, Ph.D. 



Vivian D>-Sinith-^hair in Immunology 

Professor and Chairman, Depanmcnt of Immunology 

The University of Texas M. D, Anderson Cancer Center 

Houston, Texas 



United States House of Representatives 
Committee on Science 
Subcommittee on Energy and Environment 



Hearing on Accelerated Phaseout of 
Stratospheric Ozone Depletion Substances 



September 20, 1995 



149 



INTRODUCTION 

My name is Margaret Kripke, and I am here today as a scientist 
and expert in the area of health effects of UV-B radiation. My 
research over the pasc 20 years has focused on the role of UV-B 
radiation in both melanoma and nonmelanoma skin cancer and on 
the effects of UV-B radiation on the immune system. In addition to 
my personal research expertise in this field, in 1987, I chaired a 
subcommittee of the U.S. EPA Science Advisory Board that reviewed 
the EPA's document on the science behind the causes and effects of 
stratospheric ozone depletion, and I currently serve on the United 
Nations Environment Programme Panel that reviews the 
environmental effects of ozone depiction every 4 years, in 
accordance with Article 6 of the Montreal Protocol. Much of my 
testimony today is based on the panel's 1994 assessment of the 
available scientific information on ozone depletion (1), which 
represents the collective wisdom and consensus of scientists all over 
the world who carry out research in this field. 



OVERVIEW 

The amount of UV-B radiation in natural sL-nlight is dependent 
on the concentration of ozone molecules in the atmosphere. Reducing 
the ozone concentration would increase the amount of UV-B radiation 
reaching the surface of the earth. Even a small increase in the 
amount of UV-B radiation present in sunlight is likely to have 
important consequences for plant and animal life on earth and will 
almost certainly jeopardize human health. The best understood 
harmful effects of UV-B radiation on human health arc its ability to 
cause basal and squamous cell cancers of the skin and eye damage, 
including cataract, which can lead to blindness. Sufficient 
information is now available to permit quantitative estimates of the 
impact of ozone depletion on nonmelanoma skin cancer and cataract. 



150 



UV-B radiaiion also contributes to the devciopmenl of 
melanoma skin cancer and perturbs the body's immune system in 
ways that can reduce immunity to infectious agents. These effects 
are poorly understood, and therefore, the magnitude of the impact of 
increased UV-B on these health problems cannot be estimated at the 
present lime. UV-B radiaiion may also adversely affect human 
health indirectly by interfering with the food chain. On a global 
scale, the potential of UV-B radiation to increase the infectious 
disease burden, cause blindness, and reduce the world's food supply 
constitute the most important possible consequences of increased 
UV-B radiation for the world's populations. 

EFFECT OF UV-B RADIATION ON BASAL AND SQUAMOUS 
CELL CANCERS OF THE SKIN 

Most basal and squamous cell carcinomas of the skin occur on 
the most heavily sun-exposed body sites of lighi-skinncd individuals, 
and the incidence rates of these cancers increase with age. These 
observations, coupled with years of laboratory studies of animal and 
cell culture models, demonstrate that cumulative lifetime exposure to 
solar UV-B radiation is the most important cause of these non- 
melanoma skin cancers. The incidence of these .skin cancers in the 
U.S. is already enormous and is approaching 1 million new cases per 
year. The number has been increasing steadily over the past few 
decade.s. and additional increases in the rate of non-melanoma skin 
cancer development, above and beyond those already observed, will 
result from ozone depiction. Current CFC phascout scenarios predict 
that stratospheric ozone levels will reach a minimum around the 
year 2000 and will gradually return to 1950 levels by the year 2050. 
Because of the long latent period for the development of non- 
melanoma skin cancers, however, this pattern of ozone depletion will 
cause the incidence of skin cancer to continue to rise at least until the 
year 2050 and probably beyond. The latest estimates indicate that 
for a ]% reduction in ozone, the incidence of non-melanoma skin 
cancer will increase by 2.0 + 0.5%. With approximately 1.25 million 
new cases of skin cancer each year worldwide today, this means that 



151 



a sustained 10% decrease in average ozone concentraiion would lead 
to 250,000 additional non-melanoma skin cancers each year. 

EFFECTS OF UV-B RADIATION ON THE EYES 

Chronic exposure of the eyes to UV-B radiation is associated 
with several deleterious effects on vision. These effects are 
independent of eye and skin color; thus, the population at risk is 
very large. UV-B radiation contributes to the formation of cataract, 
which causes blindness in 17 million people worldwide. It is 
estimated that a 1% decrease in ozone concentration will increase the 
incidence of cataract by around 0.5%; however, the exact number is 
uncertain because the wavelengths of UV-B radiation involved are 
not precisely defined. It is certain, however, that the incidence of 
cataract will increase if ambient UV-B levels rise unless mitigating 
behaviors are adopted. In countries where sunglasses and cataract 
surgery are not readily available, the problem of blindness caused by 
cataract will undoubtedly increase. 

EFFECT OF UV-B RADIATION ON MELANOMA SKIN CANCER 

Melanoma, a cancer of pigment producing cells, accounts for 
only about 4% of skin cancer cases in the U.S., but it is responsible for 
more than 60% of the deaths. Based on many epidemiological and 
laboratory studies, it is now clear that exposure to solar UV radiation 
is a major risk factor for human melanoma in light-skinned 
populations. However, major uncertainties preclude our ability to 
estimate the impact of ozone depiction on this type of skin cancer at 
the present time. Fir.st. the role played by UV in melanoma 
development is not well understood and is probably quite complex; 
second, the dosc-rcsponsc (how melanoma incidence is related to the 
amount and frequency of UV exposure) is not understood; third, the 
exact waveband of UV involved in melanoma development (action 
spectrum) has not been established. 

The question of waveband is panicularly important because 
wavelengths in the UV-A region of the spectrum (320-400 nm) will 



152 



5 



be minimaUy affected by ozone depiction, whereas those in the UV-B 
region (280-320 nm) will be strongly affected. There is some 
circumstantial evidence for a causal role of UV-B, which has been 
reviewed extensively in the past (1). However, molecular 
approaches to this problem promise to provide a more direct answer 
to this question. Recent molecular studies of human melanomas 
point to a role for UV-B in melanoma induction, but do not provide 
evidence of a role for UV-A (2). In one of these studies, a melanoma 
susceptibility gene called MTS-1 was analyzed in 30 human 
melanoma cell lines for the presence of UV-spccific mutations; 37% 
of the melanomas had mutations in this gene, and 67% of the 
mutations were of the types caused by UV-B. The most common 
type of mutation caused by UV-A radiation (3) was not found among 
31 mutations in MTS-1 analyzed in various studies to date. These 
studies suggest that a minimum of 25% of melanomas may involve 
UV-B exposure. The actual percentage may be much higher because 
more than this one gene is likely to be involved in melanoma 
development, and a direct alteration in DNA is only one of several 
way.s in which UV-B can contribute to cancer induction. Although 
these findings are still preliminary and incomplete, they point 
toward a causal role of UV-B radiation in melanoma development in 
humans. 

EFFECTS OF UV-B RADIATION ON THE IMMUNE SYSTEM 

The immune system is the body's main defense mechanism 
against infectious diseases. In addition to providing protection 
against bacterial, viral, fungal, and parasitic infections, the immune 
system also protects against the development of certain types of 
cancer, particularly those associated with cancer viruses and UV 
radiation. Any impairment of immune function could jeopardize 
health by increasing su.sceptibility to infectious diseases, increasing 
the severity or duration of infections, or increasing the incidence of 
certain cancers. 

The immunosuppressive effects of UV-B radiation in laboratory 
animals are well documented. Immune responses initiated or 



153 



elicited within UV-B-irradiated skin arc diminished, and 
immunization through UV-B-irradia(cd skin can lead to a long-lasting 
slate of unresponsiveness to the immunizing agent. With higher 
doses of UV-B. immune responses initiated at unexposed sites may 
also be suppressed. The.se findings led to concerns that immunity to 
infectious diseases might also be compromised by UV irradiation, 
resulting in an increase in the severity or incidence of certain 
diseases. This possibility wa.*? borne out in a number of rodent 
models of infectious diseases, including cutaneous herpesvirus 
infection, leishmaniasis, mycobacterial infections similar to 
tuberculosis and leprosy, candidiasis, trichinosis, AIDS, and Lyme 
disease (borrcliosis). In all of these disease models, immune 
responses to the infectious organism was diminished, and the 
severity of the disease was increased. Only with one disease, 
schistosomiasis, was no effect of UV irradiation found. Why 
resistance to this particular disease is unaffected by UV-B irradiation 
is unknown, which makes it impossible to predict which diseases will 
be affected and which will not. 

There is also substantial evidence that UV-B alters immune 
function in humans by mechanisms similar to those described in the 
rodent models, although much less information is available for 
humans. The immune response to chemicals applied to UV-B- 
irradiated human skin is reduced, and long-lasting unresponsiveness 
has been observed in some individuals. One recent study 
demonstrated that the immune response to the leprosy bacillus 
elicited in UV-irradiatcd skin of healthy, immune subjects was 
significantly reduced, compared to that in unirradiated skin of the 
same individuals (4). This study is one of the few to date in human 
subjects that investigates the effect of UV radiation on the immune 
response to an infectious organism. 

Taken together, information from the animal models and the 
limited data available in humans give reason to believe that 
increased UV-B radiation could increase the severity of some 
infections in human populations. Furihcrmorc, skin pigmentation 



154 



docs not seem to provide much protection against the 
immunosuppressive effects of UV irradiation in humans, suggesting 
that the population at risk of such effects is very large. Because 
infectious diseases constitute an enormous public health problem 
woridv^ide, any factor that reduces immune defenses and increases 
the severity of infectious diseases is likely to have a devastating 
impact on human health. At the present time, however, not a single 
prediction about the impact of ozone depletion on a single infectious 
disease in a single geographic location can be made. Unless 
additional information is obtained, this situation will not change. 



REFERENCES 

1. UNEP report on Environmental Effects of Ozone Depiction 1994. 
Ambio 24:138-196, 1995. 

2. Pollock PM, Yu F, Qiu L, Parsons PG, Hay ward NK. Evidence for 
U.V. induction of CDKN2 mutations in melanoma cell lines. Oncogene 
11:663-668, 1995. 

3. Drobetsky EA, Turcotie J, Chateauncuf A. A role for ultraviolet A 
in solar mutagenesis. Proc Natl Acad Sci USA 92:2350-2354. 1995. 

4. Ccstari TF, Kripkc ML, Baptista PL, Bakos L. and Ducana CD. 
Ultraviolet radiation decreases the granulomatous response to 
lepromin in humans. J Invest Dermatol 105:8-13, 1995. 



155 

Mr. ROHRABACHER. Thank you very much, Doctor. I would note 
that your testimony does have a lot of "may"s and "could"s in it, 
and that you actually are highlighting that, to the sense that you're 
saying that further study must take place and that not enough 
study has been done to make the conclusions of what may or could 
happen. 

I think that's really an important consideration when looking at 
this issue. 

Before we go on to questions, and I'll go directly to the Members 
of the Committee, but let me just say one thing for the record from 
the Chairman's point of view. 

And that is that quite often in history, we see cases where all 
of the experts are on one side and within a few years, all the ex- 
perts are on the other side. 

So, I am not swayed by arguments that here's a big list of sci- 
entists that are on my side and you only have a smaller group of 
scientists on your side. 

I'm just not swayed by that at all. 

I note that five years ago, the idea of a single-staged orbit rocket 
system for the United States was derided. Today, everybody in the 
industry looks at that. That is our great hope, for a single-staged 
orbit. 

But five years ago, it was being laughed off as just something 
that eccentrics argued in favor of. And this can be shown time and 
time again. 

I understand that, for example, in the case of when someone has 
certain diseases, for example, and — I'm thinking about heartburn. 
What's the disease I'm talking about here? 

Ulcers. Where the medical profession has a totally different view 
of ulcers today than it had five years ago, and that the vast major- 
ity of doctors swore that it had something to do with acid and ten- 
sion and now they claim it's bacteria. And in fact, they used to say, 
drink a glass of milk. And now they say that's the very worst thing 
you can possibly do. 

So when we're looking at things like the ozone hole, or we're 
looking at things that deal with scientific judgments, let us be hon- 
est enough to look at the arguments, rather than trying to belittle 
the other person's position by saying that these are erratic argu- 
ments, rather than going to the heart of the argument. 

That's what we have a panel of people before us today for, who 
have different points of view. And what we're interested in is which 
one of those views is correct, not who has more people on their 
side. 

With that 

Mr. BOEHLERT. Mr. Chairman, may I just make an observation 
there? 

Mr. ROHRABACHER. Certainly. 

Mr. BoEHLERT. First of all, I want to compliment you on the com- 
position of the panel because, obviously, we have diverse points of 
view represented on the same panel. 

And I know you and I have discussed this many times, the frus- 
tration we had when we were in the minority, that the alternative 
side was called at 4:00 in the afternoon, after everybody had de- 
parted. 



156 

This is refreshing to see this balance on this panel. 

But I would make this other observation. I think we have to go 
with the best available science at the time. We're never going to 
have absolute certainty. 

And the example you use, the single-staged orbit rocket, that was 
an engineering problem, a little bit different than hard science, as 
we're discussing it. 

But I want to compliment you very much for the composition of 
this panel and the manner in which you're conducting the hearing. 

Mr. ROHRABACHER. Okay. Thank you very much. And Mr. Ehlers 
will be the first Member of the Committee to have questions. And 
we will, as I say, hopefully, try to have questions that are aimed 
at promoting dialogue among the panelists. 

Thank you. 

Mr. Ehlers. Thank you, Mr. Chairman. The very first is a spe- 
cific question to the last member of the panel. This issue of immu- 
nology relating to this, or immune response, is new to me. 

It wasn't quite clear to me from your testimony how this works. 
Are you talking only about those infections or diseases which enter 
through the skin, and that irradiated skin has a reduced immune 
response? Or is it a more general, systemic problem? 

Dr. Kripke. In the animal models at least, there are two ways 
in which ultra-violet light can change the body's immune system. 
One is exactly as you've stated, where an organism, a foreign sub- 
stance, comes through UV-irradiated skin and then the immune re- 
sponse to that organism is decreased. 

But it is also true in the animal models that ultra-violet irradia- 
tion causes systemic immune suppression, so that some organisms 
can be introduced at non-irradiated sites and still have an in- 
creased disease-causing pathway. 

Mr. Ehlers. Okay. As a fair-skinned individual, this makes plain 
why I get sick all the time. [Laughter.] 

I would like to go back to my opening statement and relate to 
that and then ask all of you to respond to a specific question. 

I made my comments at the beginning about the uncertainty of 
a good deal of scientific evidence when it's difficult to do the experi- 
ments, which it is in this case, certainly. 

It seems to me the disagreement we have on the panel reflects 
this difficulty. But it seems to me it's at different stages. 

If you look at the issue of the presence of CFCs or their kin in 
the atmosphere, that can be determined with a fair degree of cer- 
tainty. We now have satellite measurements of that and other ap- 
proaches. It's working quite well. 

So we have a good deal of certainty there. 

The impact of the presence of CFCs on ozone, the total amount 
of ozone there is less well understood, I believe, and certainly not 
as accurately measured. Partly, I believe, because the mechanism 
may not be totally understood, largely because of the natural fluc- 
tuations in ozone. 

So it seems to me that there, you're introducing a fair amount 
of uncertainty. 

But the real issue that we get concerned about and the basis 
upon which we form public policy is the health effects of the ozone 
depletion. 



157 

I appreciated Dr. Setlow's comment about the funding is in- 
versely related to the uncertainty, and I think that's a very valid 
point. 

But I would be interested in the response of each of you to the 
following question — what should we do as a Federal Government to 
try to reduce the uncertainty involved here? Where are the most 
fruitful areas of research in determining what we really have to 
know in terms of public policy? 

And that is, what is the correlation between CFC use and health 
effects? 

That's, I think, the crux of what we're examining here as a panel 
today. And which areas of science need the most research? Where 
are the greatest uncertainties in that? Is it perhaps the fact that 
there are other ozone-depleting chemicals around that we haven't 
observed as carefully and don't know the effects on? 

What can we do in terms of control of the natural chemicals up 
there? Can we have anything to do with that, such as methane and 
others? 

Just a whole host of questions here and the time is limited, so 
I'd like to have you each try to zero in on what you as an individ- 
ual panel member think we should be doing in terms of trying to 
pin down this uncertainty, get the kind of results that will convince 
not only me, but Chairman Rohrabacher and others of the proper 
avenue to take in public policy. 

Dr. Watson. 

Dr. Watson. Thank you. I start with a premise which is slightly 
different. 

I believe we do know enough to firmly establish the relationship 
between human activities and loss of ozone. I don't think there's 
any question whatsoever based on incredible amounts of laboratory 
data, of both homogenous — that's gas-phase — and heterogenous 
chemistry or observations of aircraft, balloon and satellites. 

There is no doubt in my mind and the large majority of scientists 
that we have established cause and effect over Antarctica. None 
whatsoever. And that when you have ozone depletion over Antarc- 
tica, you get more UV-B. 

The two big areas where I do believe we do not have what some 
people would like to see as sufficient evidence is well-determined 
trends of ultra-violet radiation at the earth's surface, at mid-lati- 
tudes, where we all live. And also whether or not there is a direct 
relationship, or what that relationship is, between ultra-violet B 
radiation and melanoma. 

So I believe we have established beyond doubt the ozone is de- 
pleting because of human activities. Unfortunately, we do not have 
the right ground-based system at mid- latitudes to observe that 
predicted increase in ozone. But we also do know that some of the 
health effects are well established, that is, UV-B and 
nonmelanoma. And as Dr. Kripke said, even in those cases, half to 
one percent of the cases are fatal. 

So we have got a link. The two weaknesses, therefore, ground- 
based observed at mid-latitudes of UV-B, and a better understand- 
ing of some of the non-melanoma health effects, the other things 
other than non-melanoma. 

Mr. Ehlers. Thank you. 



158 

Dr. Singer. I'd like to comment on your question. Your question 
relates to the health effects. 

I'm not a health scientist and therefore, I have to use what I 
would call a common-sense approach to this problem. 

We've heard from Dr. Kripke about what she regards as the dev- 
astating health effects of a small increase in UV-B. By small in- 
crease, I suppose she means five or ten percent, the type of in- 
crease that's being envisioned as a result of the putative ozone de- 
pletion. 

I just want to point out that if you move from New England to 
Florida, you get an over 200 percent increase in UV-B because of 
the steeper sun angle. It has nothing to do with ozone, really. It's 
the steeper sun angle, same amount of ozone. 

And therefore, if the effects were really devastating, looking at 
it now as a physicist, not as a health scientist, I would expect to 
see all kinds of epidemics in Florida, people whose immune sys- 
tems were collapsing. 

I would see epidemics of cataracts and all sorts of things because 
of the much, much higher levels of UV-B in Florida, which exist 
naturally. 

Mr. ROHRABACHER. Well, Dr. Singer. Let's ask the two, then. 

Are there such epidemics taking place in Florida of cataracts and 
melanomas? 

Dr. Kjiipke. I can't answer the question about cataracts. That's 
not my area of expertise. Perhaps someone else can. 

Mr. ROHRABACHER. Is there any information on cataracts because 
cataracts was something that was brought up earlier. It was in 
your testimony, I believe, that it would have an impact on cata- 
racts. 

Do we have any evidence for it? 

Dr. Singer. Well, I've read a paper by Professor Schlein. Oliver 
Schlein is a professor of ophthalmology at Johns Hopkins Univer- 
sity. He published a paper this year, in April of 1995. The work 
was supported by EPA and NASA. 

He went down to the Antarctic to study the effects on eyes of in- 
creased UV-B. He reported no effect. 

Mr. ROHRABACHER. What about between the northern part of the 
United States and the southern part of the United States? 

Dr. Kripke. I think that the part of the world that is more likely 
to be affected are parts of the world where sunglasses are not 
available and cataract surgery is not available. 

There are ways to decrease the impact of ultra-violet radiation 
on the eyes, such as wearing sunglasses. We can prevent blindness 
from cataracts by cataract surgery. 

So I think the place that you would expect to see the biggest im- 
pact of those kinds of effects of ultra-violet light are in underdevel- 
oped countries where those mitigating factors are not available. 

Mr. ROHRABACHER. Do we have any evidence of that happening? 

Dr. Kripke. I can't answer that question. 

Ms. Rivers. The nonmelanoma cancer. 

Mr. ROHRABACHER. Nonmelanoma cancer. 

Ms. Rivers. Is it not true that there are higher incidences in cli- 
mates closer to the equator? 



159 

Dr. Kripke. That is clearly true. There is a latitude gradient for 
skin cancers. 

I don't think there's any question that nonmelanoma skin cancer 
is related to ultra-violet B radiation. I can't imagine that there is 
still anyone in the world who doesn't believe that UV-B radiation 
is not the major cause of nonmelanoma skin cancer. 

So one thing we can say for absolute certainty is that if UV-B 
radiation at the earth's surface increases, there will be more cases 
of nonmelanoma skin cancer. 

I don't think anyone will argue with that. 

Dr. Singer. Just to complete my answer to you, I agree that in- 
creased UV-B will produce more nonmelanoma skin cancers. 

The question really is how many more? 

Mr. ROHRABACHER. Dr. Setlow, you're the other health specialist 
with us on the panel today. 

Dr. Setlow. You have to understand that my background origi- 
nally was in physics, and that makes me an expert in health. 
[Laughter.] 

Mr. ROHRABACHER. Thank you. 

Dr. Setlow. The important point about diseases is that they 
have to be enumerated. And in the case of certain cancers, there's 
a good registry. They're reported. Melanoma is reported. 
Nonmelanoma is not reported really in any rational way, and cata- 
racts certainly are not reported to a central registry. 

So it's very difficult to get those data over the U.S. It's very easy 
to get melanoma data and, with special surveys, nonmelanoma. 

And it's very clear, as Margaret Kripke said, there's a lot more 
nonmelanoma in sunny climates. The best and biggest comparison 
comes between Australia and Norway, similar kinds of fair-skinned 
populations. 

Nonmelanoma in Australia is about 20-fold greater than in Nor- 
way, a tremendous difference. Melanoma in Australia is only about 
two-fold greater than in Norway. 

So there's either a very different dose response relation or a very 
different wavelength relation, which you can't tell from the epide- 
miology. 

Mr. ROHRABACHER. I think the central question is whether or not 
this relates to the depletion of the ozone and how does that fit in 
with this? 

Dr. Albritton. 

Dr. Albritton. Thank you, Mr. Chairman. 

I am an atmospheric chemist and by no means an expert in 
health. The only area of health that I am an expert in is that of 
airline food on human beings. [Laughter.] 

But I do know who to check with on advice. I pointed out earlier 
that there is an assessment panel on effects and Dr. Kripke partici- 
pated in that and described it on hers. And I did recall, and as I'm 
asked questions on areas that I don't know anything about, having 
looked up issues in the health effects assessment. 

You had asked about cataracts. Let me just read to you the oph- 
thalmologist's reports in the health effects assessment. 

It's noted that a 1 percent increase in stratospheric ozone deple- 
tion has been predicted to be associated with a 0.6 to 0.8 percent 



160 

increase in cataracts. This estimate, although crude, has not been 
improved upon since the last assessment. 

So that's their current statement on the role of ozone depletion 
and cataracts. 

Thank you. 

Mr. Ehlers. Dr. Baliunas next? 

Dr. Baliunas. The question was where to put areas of research 
funding. 

I would guess accurate UV-B ground-level measurements are 
really needed because the current measurements are fraught with 
uncertainty. 

There also should be, and I believe there is, research on the envi- 
ronmental and health impacts of the replacement chemicals that 
are being phased out. 

So we thoroughly understand their impact on the environment as 
well, whether or not the replacements are causing, will cause acid 
rain problems. 

Mr. Ehlers. Thank you. Dr. Setlow. 

Dr. Setlow. I come back more or less to my original statement. 
And that is we're concerned, not because of the ultra-violet, but be- 
cause of the effects on life on Earth. And therefore, there has to 
be more money put into the area of greatest uncertainty. 

What are the effects on biological systems? 

I'm sorry to say that, in most cases, you're only going to get this 
by putting more money into that field. And I'm not sure exactly 
how to do it. I can give you my prejudices, but they're only preju- 
dices. 

I happen to be prejudiced in favor of fundamental research. Tell 
people you have to know something about these effects. And if 
there's money, lo and behold, the answer, might/may appear. 

Without that, the answer will not appear. 

Mr. Ehlers. Dr. Kripke. 

Dr. Kripke. I also — I guess we all have our own biases based on 
our background and interest in this area. 

But I think the most important thing from my perspective is un- 
derstanding what are the consequences of UV-B radiation. And 
again, we have very little information on some of those potentially 
important effects. 

I think the two most important ones, really, are the 
immunological, potential immunological effects of UV-B radiation 
because the order of magnitude of that problem may be large. Lots 
of people are susceptible. It doesn't take much ultra-violet light to 
alter the immune system. 

The other area of uncertainty I think it's very important to have 
information on is melanoma. I think we are currently in a stage 
of scientific development where a little bit of money put into that 
question for human melanomas will probably go a long way. 

I think we can get some useful answers by doing some critical 
experiments in humans of that kind. 

I agree with Dr. Baliunas that I am concerned about replacement 
CFC compounds, and I think that we do need to know what are 
the potential health consequences of those compounds as well. 

So those would be my three areas where I think we need more 
information and/or more research. 



161 

Mr. Ehlers. Thank you. And Mr. Chairman, it appears that the 
consensus is that we need better data on UV reaching the earth, 
both UV-A and UV-B, but especially UV-B. 

Secondly, identify the effects of that on human health. 

And thirdly, take a look at some of the replacement chemicals. 

Thank you very much. 

Mr. ROHRABACHER. Mr. Ehlers, thank you very much. 

Now Mr. Olver. 

Mr. Olver. Thank you, Mr. Chairman. 

I'm glad somebody summarized the last five or six statements be- 
cause I'm not sure that I would have been able to have picked out 
exactly what that summary was from the comments made. 

Let me just ask a quick question of Dr. Singer and Dr. Baliunas. 

Do you think there should be any controls on the CFCs that are 
being produced at the present time, given the data that we have? 

Dr. Singer. This is really not a scientific question, I take it. You 
want my personal feelings on it? 

Mr. Olver. Yes. 

Dr. Singer. I really have no strong personal feelings about CFCs. 
My real concern in this whole matter, the reason I'm in this, I don't 
have a vested interest in this matter at all. It's just to make sure 
that the science that backs our policies is properly conceived, the 
science is properly done. 

Mr. Olver. Well, does the science, as it is now, suggest that we 
should or should not be controlling CFCs? 

Dr. Singer. I'm more concerned about the fact that I see the 
science being misused, mishandled, distorted. That's been my 
theme. 

Mr. Olver. Okay. 

Dr. Singer. And I'd like to make sure that all sides of the sci- 
entific issue are aired and properly discussed. 

Mr. Olver. Would you like to answer that, comment on it? 

Dr. Baliunas. Well, I also have no preference. Some of the nar- 
row question addressed here of the accelerated phase-out or delay 
over the next four years, as the advancement of the phase-out from 
the year 2000 to 1997. 

Mr. Olver. You're against the phase-out, the advancement of the 
phase-out? 

Dr. Baliunas. Not personally. It's just that it involves a broader 
issue than the science. It involves the risk/benejfits. And I can't 
comment on those, and the second panel shall. 

It involves an economic question as well. 

Dr. Singer. Can I come back to your question? Perhaps I can 
shed some more light on this. 

Specifically, I am in favor of delaying the phase-out to the origi- 
nal date of 2000. I'm not against the phase-out of CFCs, as such. 

But I think that we're proceeding in a very hasty way, on the 
basis, for example, of a theory which has never been proven. 

Let me just remind you of the fact that this theory that underlies 
all of this, the so-called CFC ozone theory, was not able to predict 
the Antarctic ozone hole, the biggest thing we have, a genuine 
event, genuine phenomenon. 

Never predicted by the theory. It came as a complete surprise. 



162 

Well, this theory has been changing every year. Every year. You 
look at the National Academy of Sciences and study their reports. 
Every two years, they've come up with a prediction of ozone deple- 
tion which was different by a large amount. 

Therefore, I think it pays for us to kind of take stock and do a 
good job on the theory, on the observations, on the UV-B measure- 
ments, before we take hasty and, I think, economically very de- 
structive actions. 

Mr. Olver. I guess I'm fearful that if one waited until the cer- 
tainty of the chemistry and the immunology in a process like this, 
that we may have been left with something which is either irre- 
versible or exceedingly difficult to reverse, the timeframes on that. 

I recognize and I'm sensitive to what the Chairman had said ear- 
lier about theories. It was only earlier in this century that the first 
people who suggested plate tectonics were essentially driven from 
their field in disgrace. But now everybody in those fields certainly 
believes it. 

I was kind of curious. Let me — it's terrible. I would like to follow 
a number of different points of questioning here. But I'm sort of cu- 
rious from Doctors Watson and Albritton. 

If you took the spectrum of scientists over a range of from zero 
concern about this issue to — zero to 100 scale, where the 100 is in- 
tense alarm over the issue — where are the number of scientists? 
Where is the scientists? 

You have your data with large numbers of scientists who sign on 
to what is an average kind of position. But where is that averaged 
positioned? 

Some of them do not view the same alarm as some others within 
those who have signed on to the data. And where are those who 
have not signed on? How many of them — what's the distribution of 
atmospheric scientists or people who work over this whole issue, if 
I may ask? 

Would anyone be able to give me what the distribution looks like, 
where they are on that scale? 

Dr. Watson. Obviously, I'm biased. I've been associated with 
international ozone assessment since 1981 and I've either chaired 
or cochaired with Dr. Albritton all of the assessments involving 
hundreds of scientists from around the world, and they do come 
from all walks of life. 

As I said in my testimony 

Mr. Olver. Where is the center of the distribution? 

Dr. Watson. I believe that 95 to 100 percent of the scientists — 
I can't say 100, because, obviously, there's two at this table who do 
not believe it — 95 to at least 99 percent of the scientists believe 
those documents on the table in full. 

Mr. Olver. All right. I'm not going to get an answer in the terms 
that I was looking for it, in any case there. But that's okay. I can 
understand why that might be. 

Let me follow a question here between the two biologists, one 
physicist, actually, who's admitted to being a physicist rather than 
a biologist, on this question. 

In the data, Dr. Setlow, in your data, you have mentioned that 
in fish melanoma, 90 percent is UV-A, 90 percent comes from 



163 

UVA. And in mouse melanoma, nonmelanoma, 95 percent is UV- 
B. 

In fish, is nonmelanoma also very heavily UV-B? Is this some- 
thing that I should be able to take away, that nonmelanoma is 
heavily UV-B? 

I'm not sure that one can have melanoma in mice. 

Dr. Setlow. One can have melanoma in mice. 

Mr. Olver. And is that heavily UV-A? Do I see that across all 
of the animal kingdom? 

Dr. Setlow. The experiments on mice have not been completed 
for melanoma. 

Mr. Olver. Some of you physicists, give me a relatively narrow 
range of what UV-A and UV-B is. 

Dr. Setlow. Okay. UV-B, depending on to whom you speak, is, 
roughly speaking, 290 to 320 nanometers. 

Mr. Olver. Yes. 

Dr. Setlow. And that is what is absorbed by ozone, primarily. 

Mr. Olver. That's B. 

Dr. Setlow. That's B. UV-A goes from 320 to 400. That's the 
visible. 

Mr. Olver. Okay. Now, if we're talking about that, you have in- 
dicated that the rate-limiting step in the biological process on mela- 
noma is not known. I think I've got that correct, that you think the 
rate-limiting step is not known. 

It seems to me that, while we may be looking at broad spectra 
here, that what is likely to be happening, likely to be happening — 
I'm perhaps way out on a limb on this — but where there would be 
specific site processes within the DNA molecules or non-DNA mol- 
ecules since only a portion — is all of this affected? 

You spoke of DNA molecules. Is all the melanoma believed to 
come from reactions in the DNA molecules? 

Dr. Setlow. The simple answer is yes. The more complicated an- 
swer is that DNA absorbs strongly in the UV-B region. And every- 
one believes that UV-B definitely affects DNA directly. 

Mr. Olver. Is the belief that this is really kind of a general, 
across the spectrum of UV-B, or is in site-specific locations 
where 

Dr. Setlow. No, no. 

Mr. Olver [continuing]. On the DNA molecule? 

Dr. Setlow. All the UV-B, from, roughly speaking 

Mr. Olver. That take in specific energy. 

Dr. Setlow. In specific places in the DNA. 

Mr. Olver. Specific places, this is going to be rather specific en- 
ergy. 

Mr. ROHRABACHER. Mr. Olver, I'll let you finish this line of ques- 
tioning, but we should move on. 

So if you could wrap it up. 

Dr. Setlow. I don't think this is the question to get into an 
elaborate discussion of absorption. 

Mr. Olver. Well, that may well be. I think what I was surprised 
at was your comment after — and I'll finish with this — that while 
we don't know what the rate-limiting step is, which is specific 
chemical reaction steps, that's the very implication of the rate-lim- 
iting step that goes on in this process, that then you followed that 



164 

by saying that you — I think I've got this correct — that you believe 
that melanoma is not ozone-related, but life-style-related. 

You, as a physicist and a biologist working in this field, have 
moved from what research gets very specific, to an extremely gen- 
eralized kind of a comment. 

Mr. RoHRABACHER. As a surfer, as the only surfer in the room, 
I'm going to say this is the last question. 

So go right ahead. 

Mr. Olver. Fine. 

Dr. Setlow. Okay. I said, if you assume that humans are like 
fish, that conclusion held. The complication is that melanoma 
arises in pigment cells, melanocytes. And melanin absorbs at all 
wavelengths and it is possible that energy, light energy absorbed 
in melanin, may ultimately affect DNA by indirect mechanisms. 

Mr. Olver. And the melanin itself is part of that DNA molecule. 

Dr. Setlow. No, it is not. It's another thing. Let's call it a sen- 
sitizer, if you like. 

There are a whole bunch of pigments. 

Mr. Olver. What does it mean, then, that you tell that it comes 
from DNA, from alterations of the DNA. 

Dr. Setlow. Oh, yes. 

Mr. Olver. But the melanin, which is specifically absorbing the 
UV-B, is not part of the DNA molecule. 

Dr. Setlow. The melanin is sitting on the side. The melanin ab- 
sorbs energy and goes — whap, to the DNA. 

Mr. Olver. Oh, I see. 

Dr. Setlow. That's the way it would happen. 

But what I meant by rate-limiting steps is the initiation, the 
start of an altered cell comes from a change in the DNA, whether 
directly by light energy absorbed in the DNA or absorbed melanin, 
perhaps. 

Mr. Olver. So the melanin, in this instance, is acting somewhat 
like a free radical. 

Dr. Setlow. Correct. 

Mr. Olver. Once it has absorbed the energy and then that is the 
thing in its free-radical state that attacks the DNA molecule and 
it is the alteration of the DNA molecule that produces the mela- 
noma. 

Dr. Setlow. That's a possibility, yes. That's an explanation. 

Mr. Olver. And the melanin is back in a position to 

Dr. Setlow. What I was thinking 

Mr. ROHRABACHER. Thank you. 

Dr. Setlow [continuing]. On the rate-limiting step. 

Mr. ROHRABACHER. Thank you, Mr. Olver. And maybe you'd like 
to finish. 

Dr. Setlow. You start with an aberrant cell that can give rise 
to a melanoma. But there may be immuno-suppressive effects that 
prevent that cell from growing and becoming malignant. And so, 
the immune system may be important also in melanoma develop- 
ment. If you have a good immune system, you may have less mela- 
noma. 

We don't know which is the most important. 

Mr. ROHRABACHER. Thank you very much, Doctor. 



165 

Mr. Olver. Mr. Chairman, no question. But I still am quite sur- 
prised that after this discussion, and even as we've just gone 
through this, that Dr. Setlow is so specific about how one does this 
and then says that it's life-style, as opposed to not knowing what 
the rate-limiting steps are. 

Mr. ROHRABACHER. The good doctor may well mean that we surf- 
ers who spend our time out in the sun voluntarily for a large num- 
ber of hours have more of a chance of getting melanoma than a 
nun who's totally covered by her cloak. 

Those are choices that people make. 

Mr. BOEHLERT. Are you saying that nuns don't surf? [Laughter.] 

Mr. ROHRABACHER. Well, we'll get back to that one later. 

Now we'll have Ms. Rivers, who may want to ask Mr. Singer 
about his peer review, the number of peer-reviewed articles that 
he's written. 

Ms. Rivers. Before I do that, I would like to ask Dr. Watson, Dr. 
Albritton, Dr. Setlow, and Dr. Kripke, if they are familiar with a 
publication called the Journal of the Franklin Institute, with what 
regard that journal is held in the scientific community, and if they 
know whether or not it is maintained in the library of the institu- 
tion at which they work? 

Dr. Watson. This is a journal ^ that came to my attention this 
morning for the first time. It is not in the library of the White 
House. It began in 1994, with a circulation of 400 people. 

It is obviously in a number of libraries and businesses and a 
number of institutions. We understand its circulation is 400. 

Ms. Rivers. Okay. Dr. Albritton, are you familiar with it, or is 
it in your institution? 

Dr. Albritton. That journal is not in our institution. I'm not 
aware of it, nor have I heard it discussed at ozone-related scientific 
meetings. 

Ms. Rivers. Okay. Dr. Setlow. 

Dr. Setlow. I'm familiar with it from my early, early days as a 
physicist, but I have not seen it for many years and, to the best 
of my knowledge, it is not in our institution at the present time. 

Ms. Rivers. Dr. Kripke. 

Dr. Kripke. I've never heard of it. 

Ms. Rivers. Okay. Thank you. Dr. Singer, I have a list of docu- 
ments that, having talked to a lot of people, seem to have general 
agreement that these are the fora in which this issue is discussed 
on a regular basis. 

I'd be curious to know if you believe there are others that should 
be on this list, and we'll see if others agree — Science, Nature, Geo- 
physic Research Letter, the Journal of Geophysical Research, At- 
mosphere and Environment, Physics Today, the Journal of Physical 
Chemistry, and the Journal of Chemical Physics. 

Are you aware of others that you think have that sort of broad 
readership and broad contribution that should also be on this list, 
such as — in the area of ozone depletion, the discussion of ozone de- 
pletion. 

Dr. Singer. Well, I would probably list another half-dozen jour- 
nals. 



'See letter from Dr. Watson to the Chairman pertaining to this section of the dialogue. 



166 

Ms. Rivers. Such as? 

Dr. Singer. EOS, which is the house journal of the American 
Geophysical Union. 

Ms. Rivers. Okay. I'll let you stop with that. 

I went back through because I wanted to be careful about what 
I said. I went back through our information. And from at least 
1980, in the document list that I gave you here, which are the 
main journals of discussion in ozone depletion, we found only one 
article by you — and that was not an article. That was a comment, 
a technical comment, over the last 15 years. 

Am I incorrect? Have you actually published in peer-reviewed 
documents of these calibers in the last 15 years, articles on ozone 
depletion, original research on ozone depletion? 

Dr. Singer. Well, you have a list attached to my testimony and 
you're very free to peruse any of the references therein. 

Ms. Rivers. Well, I'm asking you, the question that I'm asking 
you. 

Dr. Singer. Including references in Science and Nature, which 
are listed there, and EOS. 

Ms. Rivers. I have Science, a technical comment in Science. 

Dr. Singer. How many would you be satisfied with? 

Ms. Rivers. Well, EOS which you just gave me, I understand is 
a newsletter and not a peer-reviewed document. 

Dr. Singer. That's not true. 

Ms. Rivers. Okay. 

Dr. Singer. Not true. 

Ms. Rivers. We have a difference of opinion. But my statement 
earlier, which came around the comments about published re- 
search 

Dr. Singer. And actually. Technology is also peer-reviewed. The 
Journal of the Franklin Institute is peer- reviewed, and I wish the 
editor were here to reassure you. 

Ms. Rivers. But it has not the caliber or the distribution of the 
list that I read a few moments ago. 

Dr. Singer. I have no idea what the distribution is. 

Ms. Rivers. Okay. 

Dr. Singer. I was asked by the editor to write an article, which 
I did. 

Ms. Rivers. But my question is, in these documents, these well- 
recognized scientific, peer-reviewed documents, have you published 
anything other than the technical comment, which is a response to 
someone else's article, on ozone depletion in the last 15 years? 

Dr. Singer. Ozone depletion hasn't been around as a subject for 
that long. 

Ms. Rivers. Or for however long they've been around. Well, then 
you said earlier you published 200 articles. 

Dr. Singer. How far back do you want to go? 

Ms. Rivers. Well, if ozone depletion hasn't been around for many 
years, or for that many years, but you claim that you've published 
before on ozone depletion, I'm finding stuff only from the early '70s 
by you on ozone depletion and earlier. 

Dr. Singer. 1971, there's a fundamental paper on ozone deple- 
tion. 

Ms. Rivers. Okay. So it existed at least then, ozone depletion. 



167 

Dr. Singer. You can start there if you like, certainly. 

Ms. Rivers. All right. I'm curious to know, and I have to say, the 
reason I didn't ask 

Dr. Singer. I don't see the relevance to your question, but please 
go ahead. 

Ms. Rivers. Dr. Baliunas, the question about whether you had 
the document, I notice that both of your institutes, the George Mar- 
shall Institute and the Science and Environmental Policy Project, 
have the same chairman of the board of directors and have three 
board of science advisors in common, which is pretty interesting. 

What other collaboration do the two organizations have? 

Dr. Singer. Let me answer that question, if I can. 

I don't think that we have any formal collaboration that I can 
point to. 

Am I wrong on this? 

Dr. Baliunas. No collaboration underway and none that we've 
ever done. 

Ms. Rivers. Okay. Just a coincidence that the same people are 
on the board. 

Dr. Baliunas. Just a coincidence. 

Mr. Rohrabacher. Ms. Rivers, your time is just about up. 

Ms. Rivers. Thank you. 

Mr. Rohrabacher. If you have one last question to ask. 

Ms. Rivers. I do. Given that the overwhelming number of sci- 
entists who are working on this topic fall on the other side of both 
Dr. Baliunas and Dr. Singer, I wonder what your explanation for 
that is. 

Is there some sort of conspiracy to keep them 

Dr. Singer. Yes, I have an explanation. 

Ms. Rivers. Okay. Great. 

Dr. Singer. Would you like to hear it? 

Ms. Rivers. Yes, I would. 

Dr. Singer. In the case of the ozone depletion work, my work has 
been ignored. My papers have been ignored and you will not find 
a reference to an3rthing that I've published in here, no matter when 
it was published. 

In the case of global warming, we have actual evidence which I 
can cite to you, because in the case of global warming, we have a 
published book called Global Climate Change. And in the book, the 
editors of the book, who happen lo include Dr. Watson, say that 
there was a minority of scientists who did not agree with the con- 
clusions. 

They failed to state whether the minority was one percent or 49 
percent, so we don't know. But they do say that they couldn't ac- 
commodate the views of the minority. And they didn't. 

Ms. Rivers. Okay. Dr. Albritton, would you like to respond to 
that, given that you've worked on these issues? 

Dr. Albritton. Yes. I am confused by Dr. Singer's statement 
that his paper was ignored. His one paper that has been referred 
to, the comment, is referenced on page 9.21 of the current assess- 
ment. 

It also references the reply of the original authors about whom 
he was commenting. 



168 

And so we not only had included the original paper. We included 
comments and discussion related to both sets of comments on that 
paper. 

Ms. Rivers. Thank you. Thank you, Mr. Chair. 

Mr. ROHRABACHER. Just a note before we go on to Mr. Boehlert, 
that there have been times in history, and I think the panel will 
agree, and probably everyone in this room will agree, when the 
large majority of scientists changed their views on something that 
they were very adamant about. 

Just to follow up on your question, has there been any situation 
where — and quite often, when the vast majority of scientists be- 
lieved in something, they actually were somewhat aggressive and 
somewhat repressive towards other people who brought up another 
point of view. 

Has anyone on this panel experienced that? In other words, 
maybe some scientists are keeping their head low because the fact 
is that the common knowledge of the day happens to be that ozone 
is a major problem and anybody questioning that might feel some 
pressure. 

Does anyone want to comment on that possibility? 

Dr. Singer. My comment on that is that my impression is that 
a large majority of scientists do support the present ozone story. 

Mr. ROHRABACHER. Yes. 

Dr. Singer. Dr. Watson, at the last hearing last month, referred 
to me as a minority of one. I think he mJght want to change his 
mind after today. At least we have two or maybe more here. 

The problem is that there are many, many scientists who do not 
speak up. And the reason they do not speak up is because they do 
not want to lose their research funding. 

I have personal experience with this and I think Dr. Baliunas 
can probably enlighten you on this matter further. 

Mr. ROHRABACHER. Dr. Baliunas — well, Dr. Watson first, and 
then Dr. Baliunas. 

Dr. Watson. Thank you, Mr. Chairman. 

You're absolutely correct. The majority of scientists have in some 
cases been proven wrong, as history tells us. 

I think after the international ozone trends panel came out in 
1988, where we first noted the ozone trends, not only in Antarctica, 
but in high northern latitudes, there was a real question of wheth- 
er they were correct or not. 

Allied Chemical vehemently believed they were wrong. So did 
DuPont and so did many of the chemical industry. 

A country, the Soviet Union, at that time also believed they were 
completely wrong. 

Allied Chemical put some of their very best statisticians on the 
job to try and disprove the ozone assessment. The Soviet Union 
also put some of their best statisticians. 

That's what I mean when, many times, minority views, the ma- 
jority views have been challenged by the minority. They now are 
key players in the international assessment. 

So I believe that not all funding comes from the U.S. Govern- 
ment. It comes from some very conservative governments around 
the world, and it also comes from industry. 



169 

Mr. ROHRABACHER. And Dr. Watson, now that it is the commonly 
accepted position that the ozone hole is a major threat, do you be- 
lieve that some people might be a little, let's say, heavy-handed in 
their dealings with people who disagree with them on this issue? 

Dr. Watson. Obviously, as you say, I speak aggressively and I 
would not deny that. 

However, I do believe that through the international peer-review 
process, and journals, I believe the minority of scientists have 
many, many avenues through which they can get their minority 
views to the public. 

Mr. ROHRABACHER. Dr. Baliunas, would you like to comment? 

Dr. Baliunas. Most chilling is that I've been directly told by offi- 
cers of federal funding agencies not to apply for funding to work 
on, quote, certain questions, in this area. 

They give two reasons. 

One is that answering these questions would undermine the pos- 
sibility of getting new funds. And this suggests a complete break- 
down of the peer-review process. 

In addition, answering these questions, or even investigating 
them, might deter policymakers from, quote, doing the right thing. 

Mr. ROHRABACHER. I think that that is — this is what happened 
to you? 

Dr. Baliunas. This is what happened to me, personally. There 
are many other stories, but they are hearsay, and so, I don't want 
to repeat them. 

Ms. Rivers. Mr. Chair, we should get names and dates and 
places and investigate this, because if there are agents, scientific 
agencies in this country who are giving that kind of information, 
we should know it. 

So I would ask that Ms. Baliunas give times and names. 

Dr. Baliunas. I would be glad to submit that. In fact, I've been 
badgered. My staff has been badgered in the last several days, my 
superiors, by an advocacy group, once the witness list came out. 

The employer that employs me is unrelated to this testimony. 
Nevertheless, they've been calling and calling and calling and badg- 
ering them, and this has had great effect. It's disrupted my work 
environment. It's an attempt to intimidate me and to censor 
my 

Ms. Rivers. This was a federal employee that was doing this? 

Dr. Baliunas. No. This is an advocacy group, going to one of my 
employers completely unrelated. 

Ms. Rivers. You started out when you said applying for grants 
for the Federal Government. 

Dr. Baliunas. Those were federal employees. 

Ms. Rivers. And you can give us names and times? 

Dr. Baliunas. Yes. And what I did early this morning, but did 
not send, was, due to these institutional pressures, I almost with- 
drew from this hearing. I just did not fax this to you at the last 
moment. 

Mr. ROHRABACHER. I do think that that is a rather significant 
element that's been introduced into the testimony today. And it 
also reflects that some people who are naturally not inclined to 
buck the common knowledge, that perhaps there's been even some- 
thing that's been added to that in the sense that, today, when we 



170 

have so many people involved in science that actually receive their 
funds from federal grants, that this is a very serious charge. 

We'll go back to that. 

Mr. Boehlert, we have time for five minutes' worth of questioning 
from you, and then we will break for the vote. 

Mr. Boehlert. Mr. Chairman, I'd like to observe, we've had a 
depletion problem of our own. 

When Dr. Ehlers, who has a Ph.D in physics, left, the scientific 
expertise of this group up here declined by 100 percent. [Laughter.] 

We have difficulty because we're generalists at best, for the most 
part. So we have to look to the experts for advice to guide our pol- 
icymaking. 

And when the preponderance of scientific testimony supports one 
direction, that usually is a direction I am comfortable with. 

So, Dr. Albritton, I'd like to ask — I'm sure there was some dis- 
pute in all the studies you cite there. But how broad and how deep 
was the consensus? 

Dr. Albritton. A few points on that, sir. 

First of all, the summary of the document was prepared by the 
peer review panel and authors, all simultaneously. And that is, the 
wording and the consensus statements in here were agreed upon 
by over 80 international scientists that included not only the au- 
thors of the chapters, but those who had written, peer-reviewed 
them, and also participated in a verbal peer review. 

I would indicate, in terms of this booklet and the words in there, 
that the agreement of that group that prepared the larger book was 
100 percent. 

Mr. Boehlert. Let me be very specific. Dr. Singer made a num- 
ber of assertions disputing whether UV-B is increasing. 

What do you believe is wrong with his assertions? 

Dr. Albritton. Would you repeat that, sir? 

Mr. Boehlert. Well, Dr. Singer made a number of assertions 
disputing whether UV-B is increasing. He made those assertions. 
And I'd like to know what you think is wrong. 

Dr. Albritton. Yes. I'd reply to that in two ways. 

What is absolutely sure, numerous data sets indicate and dem- 
onstrate with direct measurements of overhead ozone and surface 
UV, that when overhead ozone decreases, that surface UV in- 
creases. 

That's been shown, as indicated earlier, in several studies, direct 
measurements. 

What we lack because of the shortness of the measuring record 
is any long-term trend in the change of UV. Several reasons for 
that. 

It's a difficult measurement. Some of the earlier studies were 
placed in areas where pollution could interfere with that, and that 
the modern instruments started only a few years ago. 

So I fully support the research statements made earlier that we 
need to foster and support that start that we've made. 

But the fact that we have not yet observed over that time scale 
a trend, does not imply that a loss of ozone would — that there's 
anything incorrect about the loss of ozone and the increase of UV. 

That is extremely well understood. 

Mr. Boehlert. Just a quick two-parter. 



171 

Should we be concerned with ozone depletion, even if we don't 
know its full impact? 

And do any of you dispute the assertion that man-made chemi- 
cals contribute to ozone depletion? Anyone dispute the second part 
of it? 

Dr. Albritton. As far as I can tell from the involvement in sci- 
entific conferences, following the literature that was cited earlier, 
participating in these assessments, the practicing ozone research 
community believes that if CFCs were to continue to increase in 
the atmosphere, that stratospheric ozone layer would continue to 
deplete. 

Mr. BOEHLERT. I was talking about our side when Dr. Ehlers left. 
Dr. Olver over there is a scientist, too. 

What about the first part of the question? Should we be con- 
cerned with ozone depletion, even if we don't know its precise im- 
pact? 

Dr. Watson. I think the answer is, yes, sir. And that's the way 
I think most of these documents are written, and that is, we do not 
know all of the implications of ozone depletion, but we know some. 

As the two medical experts on this panel have said, and the 
international scientific community has said, if there's an increase 
in ultra-violet radiation, we will certainly see an increase in non- 
melanoma skin cancer. 

While only a half to one percent of those cases are fatal, it is still 
a very serious human health issue. There are costs associated with 
that nonmelanoma skin cancer and, indeed, unfortunately, a num- 
ber of such people do die. 

So that we know quite well. 

So even with that information alone, we can say it's a human 
health issue. 

With respect to other issues, such as the effects on food, natural 
terrestrial eco-systems, suppression of immune system, there are 
indications that there would be adverse effects. 

My personal belief would be, even if we only knew ozone led to 
an increase in nonmelanoma skin cancer, with some level of fatali- 
ties, that in itself is enough to be concerned about, and all of these 
other factors, such as suppression immune response system, mela- 
noma, impacts on the ecological system, would make it further an 
issue to be concerned about. 

Mr. BoEHLERT. Dr. Singer. 

Dr. Singer. I'd like to explain why I disagree. 

You cannot tell from any evidence we have how much 
nonmelanoma skin cancer is produced by a change in ozone. 

I know that Dr. Watson claims that if UV increases by one per- 
cent, then skin cancer will increase by two percent. 

That number cannot be maintained, in my view. It is not correct. 
Ill explain why that is so. 

The clue comes from the fact that skin cancers of all sorts have 
been increasing for the last 60 years. It has nothing to do with 
changes in UV, nothing to do with changes in ozone. It has, as Dr. 
Setlow correctly pointed out, it has a lot to do with change in life- 
style. 

People expose themselves more to the sun than they did many 
decades ago. That's the clue. 



172 

And now, specifically, when Dr. Watson mentions that the skin 
cancer rate, the nonmelanoma skin cancer rate, is five times great- 
er in Albuquerque than in Seattle, and uses this as a way of get- 
ting at the numerical value, I can show you that he's wrong on two 
counts. 

In the first place, this bill has a built-in assumption which as- 
sumes that you have as many clear days in Seattle as you do in 
Albuquerque. 

That's not a valid assumption. 

The second assumption is that people in Albuquerque or New 
Mexico and Arizona wear raincoats all the time, like they do in Se- 
attle, and cover themselves. 

That's not true, either. 

There's more exposure to the sun in warmer climates. And that 
fact alone can explain a great deal of the increase in skin cancer. 
We don't know how much of it. But, certainly, from the historical 
evidence, I would say a great deal of it. 

Mr. ROHRABACHER. Dr. Singer, with that, we will have to break. 
We will recess for just about 10 minutes. We'll come back for about 
10 more minutes of questioning for the panel, and then we will 
break for lunch before the next panel. 

So thank you very much. We are in recess for 10 minutes. 

[Recess,] 

Mr. ROHRABACHER. I call this hearing into order again. 

Seeing that none of my fellow members are here at this point, 
I will just move forward some questions. As I say, as we finish this 
round of questioning, we will break for half an hour for lunch and 
then have the second panel. 

First of all, I have a series of questions that I'd like to ask. 

One thing, some of the questions early on, and some of the testi- 
mony earlier brought up some questions. 

First of all, I guess I should ask Dr. Albritton this. When Dr. 
Baliunas suggested that when we were talking about measuring 
and trying to determine depletion of ozone, that you were using as 
your benchmarks the highest year of ozone — a year where you had 
the highest level of ozone. 

Now, perhaps you could — and by the way, I understand how you 
can use charts to prove things. And if you do that, doesn't that 
skew the whole chart? And is that the case? And does that skew 
your findings? 

Dr. Albritton. Mr. Chairman, we actually did a different ap- 
proach than what was described here. 

We had no single one starting point on the downward trend. We 
actually included the previous years as the baseline to determine 
that starting point. And that way you don't unduly weight it with 
any one starting point. 

In the report back on this, we examined the sensitivity of choos- 
ing the year in which the downward trend may have started. And 
it is a relatively small sensitivity because of the point that I men- 
tioned; namely, we're fitting with a curve that looks very much like 
a hockey stick where there is a level period and then a linear 
trend. 

That decreases any weight on a starting point. 

Thank you. 



173 

Mr. ROHRABACHER. Well, is it possible that — let me ask you this. 

Is it possible that we could have had ozone holes in the Antarctic 
or elsewhere in the world in the many, many hundreds or millions 
of years that the earth has been around, before? 

Dr. Albritton. All the evidence obtained from direct measure- 
ments over Antarctica is that it requires elevated levels of chlorine 
and bromine to cause the ozone hole that we observe now. 

Indeed, the early part of the monitoring record in Antarctica, one 
saw variations that were limited to the natural variations that one 
sees in ozone in that area. And it was roughly in the 1980s that 
the observational records showed the overall downward trend. 

So I would take from that that without elevated chlorine in the 
past, that would not have occurred, what we see now. 

Mr. ROHRABACHER. So there weren't ozone holes in the past. 

Dr. Albritton. No, sir. 

Mr. ROHRABACHER, Is that accepted by the panel? I'm not sure. 

Yes, sir. Dr. Singer? 

Dr. Singer. I don't accept this statement. I published on it in 
EOS, as a matter of fact, in 1988. 

My view is as follows. It's very different from the one just pre- 
sented and differs from the view presented by Watson. 

The hypothesis I have is that chlorine is in fact the agent that 
affects ozone, but only in the presence of the ice particles. And I 
think this is supported by the present evidence. 

Now what does it take to make ice particles? It takes water 
vapor and a low temperature. 

Therefore, if we had had in the past, and we have a long past 
on this earth, several billion years, if we'd had in the past a cli- 
matic situation that gave you very low temperatures and water 
vapor in the stratosphere, I think you would have had ozone holes. 

And by the same token, if the stratosphere should not warm up, 
or if the water vapor content of the stratosphere would go down, 
the ozone hole would disappear, even if we have chlorine in the 
stratosphere. 

That is the view that I have. It's a hypothesis. It should be test- 
ed. 

Mr. ROHRABACHER. Dr. Watson, would you like to comment on 
that? 

Dr. Watson. Thank you. Dr. Singer is obviously absolutely cor- 
rect. You must have ice crystals. 

There was enough water vapor and ice crystals back in the last 
20 or 30 years. But there's something much more important. You 
have to have chlorine. You need a specific amount of chlorine. 

What we've done is we've not only looked in the laboratory. 
We've measured in the field exactly the concentrations of the chlo- 
rine. 

The amounts of chlorine pre-Antarctic ozone hole, pre-human ac- 
tivities, was only about six-tenths of a part per billion, not enough 
to cause the observed change. 

So you need cold temperatures and you need the elevated levels 
of chlorine that have been put in there by human activities. 

It can very, very easily be demonstrated. In fact, I would abso- 
lutely welcome a paper by Dr. Singer to be peer-reviewed by the 
scientific audience. 



174 

Mr. ROHRABACHER. Earlier on, when we were talking about — I 
guess what I'm tr5dng to get at is whether or not the ozone is pos- 
sibly a naturally occurring phenomenon that could have been — ^we 
do know that it's cyclical within the year because we've seen that 
some times of the year it's bigger, and other times of the year, it 
almost disappears, if not disappears altogether. 

There's something natural going on here as well. Don't the natu- 
ral occurrences have something to do with this, as well as simply 
what mankind is involved with? 

And I'll open that up to the panel. Maybe first, Dr. Albritton, or 
Dr. Singer, either one. 

Dr. Albritton. Yes, thank you. Ozone is a naturally-occurring 
compound. It's made by the sun's rays and it was removed over its 
million original years by natural chemical processes. 

And so the balance of the ozone layer that has existed ever since 
we've had an atmosphere is a balance between the solar input like 
the water coming into the bathtub, and natural chemical processes 
that drain it away. 

That level does fluctuate. It fluctuates because the natural proc- 
esses fluctuate. 

For example, it fluctuates with the intensity of the sun. It fluc- 
tuates with the intensity of the removing chemicals. 

We've observed the level of that fluctuation. That level of fluctua- 
tion is much smaller than the general downward trend that we've 
seen in ozone over the 1980s. 

What we've done is we've taken a natural chemical cycle like 
chlorine and we've augmented the amount of chlorine in the atmos- 
phere, so it's like enlarging the hole at the bottom of the bathtub. 

With the same input, the water level tends to gradually go down, 
superimposed on that natural fluctuation as it goes down. 

Mr. ROHRABACHER. The CFCs that are produced here, I take it 
what you're sajdng is that the CFCs that are produced here have 
the impact on the Arctic ozone hole. 

Why is it that we don't have them creating the ozone hole over 
the northern hemisphere? 

Dr. Albritton. That's a very good question. 

Mr. ROHRABACHER. Do the CFCs do that here? 

Dr. Albritton. Why does the ozone hole appear over the south- 
ern hemisphere and not exactly in the same manner over the 
northern hemisphere? 

Mr. ROHRABACHER. Right. And do our CFCs contribute to the 
ozone hole there? 

Dr. Albritton. Yes, sir. CFCs having a very long lifetime are 
distributed all over the globe. 

Mr. ROHRABACHER. Okay. 

Dr. Albritton. It's the special nature of our planet being asjnn- 
metric in the way the land masses are distributed. 

Over Antarctica, you have a continent. You have a high-elevation 
continent. You have it surrounded entirely by oceans, which iso- 
lates this area and lets it be the coldest of the two poles. 

So, in brief, the reason that the large number of ice particles 
form in the stratosphere over Antarctica is that that is a colder end 
of the planet than the north. 



175 

The reason the north is warmer is all of our land masses, with 
their mountains, are in the northern hemisphere. And so the dy- 
namics of the air bouncing off those mountains make the Arctic a 
lot warmer place. 

Mr. ROHRABACHER. So that global warming, if it's true, is going 
to solve this problem for us. 

Is that what we can conclude? 

Dr. Watson. Mr. Chairman, unfortunately, it's exactly the oppo- 
site of that. [Laughter.] 

The carbon dioxide that we put into the atmosphere is predicted 
to warm the lower part of the atmosphere. It's actually part of 
Fred's thesis that it is that CO2 that's cooling the lower strato- 
sphere. 

So, actually, more carbon dioxide would make this problem 
worse. 

Mr. ROHRABACHER. All right. I was being a little facetious there, 
I'll have to admit. 

Dr. Singer. 

Dr. Singer. Mr. Chairman, you asked the other question, which 
is why do people count ozone depletion from the year 1970, when 
it was the maximum? 

Obviously, if you did that, you'd always get a decrease. 

What we have to do in order to — let me say, I don't accept the 
idea of ozone depletion, as yet. I'm not convinced that the present 
data conclusively demonstrate it, and I'll explain why. 

The natural variations are very large and you have to remove the 
natural variations, stick to the 11-year solar cycle in the record, be- 
fore you can decide whether or not there is really a trend, a long- 
term trend. 

It's a very simple problem. It's a very difficult problem to do. 

In my view, you cannot do this if the record is very short. You 
cannot do this if the record is only two or three solar cycles. You 
have to have a longer record. 

Unfortunately, to get a longer record takes time. You can't hurry 
the situation. Even if you throw money at it, you can't speed it up. 

I know that this is something that we'll do. 

But now let me tell you what happened. The ozone trends panel 
came up, as Dr. Watson reports, and Albritton reports, with their 
story in 1988. At the same time, an independent team of scientists 
working at Allied Signal, if that's correct, did an independent anal- 
ysis. Their names are Hill and Bishop. 

They published their analysis in a preprint, which I have. This 
preprint showed, and I believe I quote them correctly because I had 
long discussions with them. But even if you try to take out the nat- 
ural variations, the so-called trend still depends on when you start 
and when you stop. It depends on your selection of time interval. 

And then something very curious happened. They published their 
work finally in a peer-reviewed, refereed journal, together with 
some other scientists, some of whom were government scientists. 
And suddenly, that part of their work disappeared. It was never 
mentioned again. 

Mr. ROHRABACHER. It was lost in the ozone hole. [Laughter.] 

Dr. Singer. Something like that. 

Mr. ROHRABACHER. Dr. Watson, go right ahead. 



176 

Dr. Watson. If Dr. Albritton could actually hold — in the silver 
document there, the Bishop data is actually in there with Bill Hill. 
He actually does a sensitivity analysis of taking out the solar cycle, 
the seasonal cycle. 

It also shows the sensitivity to changing the starting point. 

It did not disappear. It's actually in the international assess- 
ments. And as Dr. Albritton said earlier, it's a relatively small ef- 
fect. 

In other words, you broadly get the same effect, whether you 
start in 1965 or 1975. 

Allied was extremely concerned about that. At that time they 
were the second largest producer of CFCs in the world. They did 
not want to phase them out. 

Their own analysis showed that there's some sensitivity, but it's 
small. 

Mr. ROHRABACHER. I would hope after the hearing today, you 
folks could maybe go into that document and apparently Dr. Singer 
thinks there's something that's not there and you believe some- 
thing is there, and you can determine that for yourself. 

Dr. Singer. This is not a peer-reviewed document. This is not a 
publication that has been mentioned by Congressman Rivers as a 
peer-reviewed journal. 

In the peer-reviewed journal, the Journal for Geophysical Re- 
search, Hill and Bishop don't mention this, the fact that the trend 
depends very strongly, I think — it's a matter of judgment — ^very 
strongly on when you start and when you stop, on the selection of 
time interval. 

Let me also mention 

Mr. ROHRABACHER. Before we get stuck on this one issue. 

Dr. Singer [continuing]. Allied Signal is now the largest manu- 
facturer of CFC substitutes. 

Mr. ROHRABACHER. And before we get stuck in this one area, 
we'll let Dr. Albritton have one last thing, and I have a couple 
more questions. And we'll move on to Members of the Committee 
who have not had a chance to ask, and then some other Members 
who have some other questions. 

Dr. Albritton. Just a tiny footnote to end that discussion. 

Mr. ROHRABACHER. Yes. 

Dr. Albritton. Dr. Lane Bishop is a lead author on the current 
chapter of the ozone trends panel here. 

Mr. ROHRABACHER. All right. And we'll talk about that later. 

Now, Dr. Albritton and Dr. Watson, you both refer to the Mon- 
treal Protocol as effective. And in fact, during your testimony, Dr. 
Watson, you actually said — well, this can only be calculated as to 
what if we didn't have it? This is going to be the results that would 
have been detrimental. 

What are Russia, China, and India, the three countries that rep- 
resent a majority of the world's population, doing to carry out the 
Montreal Protocol? 

Dr. Watson. India and China also have to follow the same 
phase-out schedule as the developed world, but with a ten-year lag. 
They have agreed at the international forum that they will also 
phaseout. 



177 

They also, however, need technical and financial help to phase 
out. That's why there's something called the Montreal Protocol 
Trust Fund, of which the United States contributes about 25 per- 
cent, which unfortunately this Congress decided to eliminate in the 
President's budget. 

My view is India, China, and Russia will all follow the inter- 
national obligations and phase out the CFCs, assuming there is in- 
deed financial and technical support to help them. 

Mr. ROHRABACHER. But they're not now, and they're having no 
impact at all in those countries, right? 

Those countries are still operating — their activities have not been 
altered because of the protocol. Isn't that correct? 

Dr. Watson. The activities in Russia have been altered and the 
activities in India and China, they are following what they signed 
up for. That is, a complete phaseout, like us, ten years after us. 

Mr. ROHRABACHER. Well, what about reports that these countries 
are becoming the source of actually manufacturing more CFCs and 
involvement in a huge black market that's been developing all over 
the free world right now? 

Dr. Watson. I honestly cannot address that. But, hopefully, you 
could maybe address that to the next panel, which may have got 
more expertise on that subject. 

It's just outside my expertise. 

Mr. ROHRABACHER. All right. That's a fine suggestion. 

Let me just ask this. If people were allowed to keep freon in their 
air conditioners, as was planned until the year 2000, and we didn't 
speed up this situation, as we did because of — and I might add, the 
stampede created by a political leader and group of political people 
who, I think, created a false alarm, what would be the difference 
today in the world's ozone layer? 

Dr. Albritton. We made an estimate of that using the same 
techniques that were done for the international assessment. And 
let me rephrase your question slightly. 

It would be impossible to go backward to the early 1987 levels 
because measures have already been done to reduce those. 

But we calculate that if one were to continue at the 1995 present 
emission levels up to the year 2000, and that is, delay that phase- 
out, that in terms of the total amount of ozone that will be lost be- 
tween now and, say, the middle of the next century, it would add 
five percent more loss total to that ozone. 

That would be a 20-year period where the ozone depletion would 
be approximately one percent higher, and others can translate that 
into the health effects. 

Mr. ROHRABACHER. So it would be one percent higher if we 
wouldn't have moved forward. 

Dr. Albritton. The total effect of delaying it that 5 years is to 
add 5 percent more ozone depletion over the next 50 years. 

Mr. ROHRABACHER. But where was the 1 percent, again? 

Dr. Albritton. The actual year-by-year ozone decrease in the 
next 20 years would be one percent more than we had anticipated. 

Mr. ROHRABACHER. And do we see any major health impacts 
from that? 

Dr. Kripke. Well, according to the 1994 assessment, there were 
some calculations made about what happens to skin cancer inci- 



178 

dence, nonmelanoma skin cancer incidence, under several different 
scenEU'ios of phase-out. 

It shows that, with the Copenhagen Amendment to the Montreal 
Protocol, which is the current scenario that we are operating 
under, that even under the best conditions, which these represent, 
there will still be a 25-percent increase in nonmelanoma skin can- 
cer in the year 2050, in comparison to what it was in 1980. 

And this is at approximately 50 degrees north latitude. 

So even under the very best scenario of phaseout, there will be 
more cases of skin cancer than there were before. 

So I think there's no question that decreasing the rate of phase- 
out will have an impact, a significant impact on nonmelanoma skin 
cancer. 

Mr. ROHRABACHER. We'll let the next panel decide whether or 
not, and we'll talk about the costs that were related to speeding 
this up, and whether or not the number of skin cancer cases and 
the cost related to skin cancer cases would sometimes, if treated 
early on, are negligible costs. And sometimes if they're not treated 
early on, are somewhat expensive. 

Dr. Kripke. May I respond to that, please, Mr. Chairman? 

Mr. ROHRABACHER. Not until I finish the statement. Then you're 
very welcome to respond. 

And that is, compared to the billions of dollars that are taken out 
of our economy by the decision to speed this up — there is an im- 
pact. 

For example, earlier, you were complaining that we didn't have 
money for the research of certain diseases. Well, that money is 
coming out of the same pot that's disappearing because we sped up 
the process. 

This is all coming out of the same economy. 

And if money is not absolutely necessary to spend the money, 
and it costs us, let's say, $20 billion out of our system, or some peo- 
ple would estimate it at much higher levels, the cost of speeding 
this up, that money is now not available for education, for health 
care, for the research that you support. 

And please do comment on that. 

Dr. Kripke. I think one misconception, one popular misconcep- 
tion needs to be set straight for the record. Which is that it's not 
true that a delay in seeking treatment for nonmelanoma skin can- 
cer is responsible for increased economic costs. 

There are many cases of nonmelanoma skin cancer which are le- 
thal, which are aggressive, which are invasive. 

We happen to have a particularly high incidence of such cancers 
in the State of Texas. And it is not true that these skin cancers 
are aggressive, disfiguring and life-threatening because there is a 
delay in seeking treatment. 

That is a misconception. 

Mr. ROHRABACHER. You mean, in other words, some people who 
don't seek treatment earlier would go through the same problem, 
anyway. It's just something out of control. 

Dr. Kripke. That is correct. Clearly, early diagnosis is very im- 
portant for skin cancer and for getting treatment. But it is not true 
that early diagnosis will prevent all serious cases of nonmelanoma 
skin cancer. 



179 

Mr. ROHRABACHER. I don't think I used the word, prevent. I don't 
think that ever came up until this moment. j 

Dr. Kripke. The other point I'd Uke to make is that 
nonmelanoma skin cancer has a significant economic and psychp? 
logical burden as well. 

It is not as life-threatening as melanoma skin cancers, as we all 
know. But nonmelanoma skin cancer is a serious disease. If any of 
you have had it, you will know that it can be cosmetically disfigur- 
ing. It occurs 

Mr. ROHRABACHER. Would you, then, and as my staff member 
recommends, which is a good question, would you then recommend 
that people not move from the northern part of the United States 
to more central United States or southern United States, in order 
to — because the risk is just too high? 

Dr. Kripke. I wouldn't recommend anything. I don't recommend 
people where they should live. 

Mr. ROHRABACHER. You've been recommending something all 
day. I mean, the fact is you're here to testify about risks. But 
you're not willing to tell someone because of the increased — it 
sounds like to me you're saying the increased risk is dramatic. But 
yet, that increased risk, as we've heard in earlier testimony, is in- 
creased as much as moving from one part of the country to the 
other. 

You don't think that we can then recommend people not to move 
from Maine to Florida? 

Ms. Rivers. Mr. Chairman, would you yield for a moment? 

Mr. ROHRABACHER. Not until the question is answered. Thank 
you. 

Dr. Kripke. I think we can recommend that if people do move 
from Maine to Florida, that they need to try to protect themselves 
from the increased ultra-violet radiation that they will undoubtedly 
experience. Just as we will have to try to tell people to protect 
themselves from increases in UV-B radiation that are caused by 
ozone depletion. 

Mr. ROHRABACHER. Did you see this report that I have here, and 
it's from the American Journal of Public Health? It was reported 
in 1995, it says. 

It's a study in Chile, in fact, of southern Chile, that says that the 
study does not support existing lay reports that, basically, the 
ozone hole is causing any more cancer. 

Have you seen this report? 

Dr. Kripke. Yes, I'm aware of that study. And that study refers 
specifically to the ozone hole over the Antarctic. 

You will be aware that there were originally some reports in the 
news media of cataracts in rabbits and all kinds of bizarre health 
effects that were possibly attributed to the ozone hole over the Ant- 
arctic. 

There has been no scientific substantiation of those claims based 
on the study that you're quoting. 

That does not mean that IJV-B radiation does not cause skin 
cancer. 

Mr. ROHRABACHER. I believe that — maybe you could draw that a 
little bit closer to me, the relationship there. 



180 

I thought that the depletion of the ozone, like the ozone hole, was 
what was going to cause us to have more of that. 

Dr. Setlow. But skin cancer results from a chronic exposure 
over many years to sunlight. The ozone hole has not been with us 
for a terribly long time. And it isn't there for most of the year. 

So the fact that there's an ozone hole does say that there's going 
to be more ultra-violet than usual. But, of course, the amount of 
ultra-violet isn't very great in those few months. 

And so it's a question of the integrated exposure, not the instan- 
taneous exposure, that gives rise to skin cancer. 

Mr. ROHRABACHER. So, in the long run, it will happen. 

Ms. Rivers. Mr. Chair? That's what I was seeking recognition on 
earlier because I've heard this argument get put forward a couple 
of times about, it's the same as moving 60 miles south. 

But my understanding of it is that the ozone layer would be de- 
pleted at a rate of 3 to 4 percent. And so, when you look at 
compounded effects over time, that the risk gets larger and larger 
and larger. 

Is that a correct assessment. Dr. Watson? 

Dr. Watson. Because of the international regulations, the Mon- 
treal Protocol — and we do need all countries to obey the Montreal 
Protocol — ^we believe ozone depletion will finally peak, maximize 
about 7 percent less over mid-latitudes in summer than what it 
was, say, in 1970. 

The effect that 7-percent ozone depletion will not be an instanta- 
neous rise in the number of skin cancer cases. It's the chronic expo- 
sure, as both Margaret Kripke and Dr. Setlow have said. 

We will see the effect of ozone depletion today in 20, 30, 40 years 
ahead. And so, we will expect to see those increases in the future, 
not today. 

Mr. RoHRABACHER. However, you did say earlier in your testi- 
mony, had we not gone forward with the Montreal Protocol, that 
things would have been a lot worse. And that sort of doesn't coin- 
cide with what you just said. 

Dr. Watson. I think it does, sir. What I mean is, because of the 
Montreal Protocol, we've managed to limit ozone depletion to only 
seven or eight percent. 

Without the Montreal Protocol, we would probably in the future 
be looking at ozone depletions of 10, 20, even 30 percent. 

Mr. RoHRABACHER. But in the earlier testimony, you did mention 
some health impact. I don't have it right on the top of my head 
now, but I remember you mentioning that. 

Dr. Watson. I think after you read it carefully, sir, you'll find 
it is consistent. 

Mr. ROHRABACHER. All right. Thank you very much. 

I'd now like to call on the distinguished former Chairman of the 
Science Committee, Congressman Brown. 

If you have any questions for the panel, please feel free. 

Mr. Brown. I apologize first to the panel because I haven't been 
able to be present this morning. We're having a mark-up in an- 
other committee and I will be required to leave again shortly for 
a vote in that committee. 

But as I said this morning, I wanted to compliment the Chair- 
man on arranging for this hearing. I think it will do a great deal 



181 

to enlighten the public on some of the factors involved and action 
on these long-term potential environmental threats. And also on 
the scientific processes involved. 

And I want to commend the witnesses for the job that they have 
done. 

Let me suggest just a couple of questions. One, I gathered the 
impression here earlier that the Chairman perhaps was suggesting 
that the speed-up in action taken in 1992 to phase out CFCs might 
have been due to some hysteria created by careless politicians rais- 
ing the threat of tragedy striking or something of that sort. 

Was there any such relationship between the 1992 action and 
any political propaganda that may have been issued around that 
time that may have been favorable to an earlier phase-out? 

Dr. Watson. 

Dr. Watson. If I could answer that, sir. Several people have 
mentioned the NASA press statement that was made in February 
of 1992. 

The statement that was made was absolutely correct, and indeed, 
as it was followed on by then- Senator Al Grore was correct. If the 
conditions, meteorological conditions, had continued, there would 
have been a significant loss of ozone over Kennebunkport. 

It was a prediction with all the right caveats. 

I personally believe that had no effect on the international nego- 
tiations, for a very simple reason. As was also stated by April of 
that year, there had been not a retraction, but a clarification of the 
situation. The clarification was that there was no ozone hole over 
Kennebunkport because the meteorological conditions changed. 

Now the Copenhagen Amendments were signed in November of 
1992, a full eight months after even the so-called retraction by 
NASA. The Senate in this country, in a very bipartisan manner, 
didn't ratify that until a full year after that situation. 

So, in my view, Mr. Chairman, the reasons that the Copenhagen 
Amendments were so forcefully pushed through internationally — 
who don't care about NASA press statements — and within the Sen- 
ate, was they observed that we by now had seen global ozone deple- 
tion at all seasons, except for the tropics. And it was that informa- 
tion that pushed the amendments to the Montread Protocol. 

Mr. Brown. Do any of the other witnesses wish to contradict or 
add to that? 

I pointed out this morning that the habit of politicians of making 
what might be fairly outrageous statements is not confined to the 
vice president or to any other single politician. 

I do it myself, on occasion. [Laughter.] 

Dr. Singer. I think I would like to make a short statement to 
balance or put into perspective what Dr. Watson just said. 

What brings me into this whole question that we're discussing 
today is this deplorable way in which policy is being made by press 
release. 

Mr. Brown. Yes. 

Dr. Singer. And I think this is very, very bad. Very bad. It pre- 
vents and precludes the careful examination of the evidence and it 
will lead us, I think, into situations that are extremely costly, into 
hasty actions that are unjustified by scientific evidence. 

In my testimony, I give a large number of examples. 



182 

Right now, for example, this week, we're faced with a press re- 
lease from the World Meteorological Organization by a well-known 
ozone activist who tells us that the ozone hole this year is going 
to be worse than it's ever been. 

How does he know that? Well, he's only seen it for the first few 
days. 

But we have, fortunately, some balance in this. A NASA scientist 
has said, this is not true — Paul Newman. 

It's in my testimony. 

Another scientist in Australia has said, it's impossible at this 
stage to predict what the eventual ozone hole would be like. It may 
well be worse than it was last year, or it may be less. 

But it illustrates how press releases are being used — or misused, 
I should say — to force all kinds of political action that may be 
harmful to our economy. 

Mr. Brown. Well, Dr. Singer, let me say that I agree thoroughly 
with the principle that you've espoused. I don't believe in policy 
being made by press release, either. 

Did you want to respond to that, Dr. Watson? 

Dr. Watson. Yes, because I would also like to concur that we 
should not make policy by press release. I want to add just one 
more thing. 

President Bush obviously was the President that for the United 
States made the decision to negotiate the Copenhagen Amend- 
ments. 

He did not, I'm quite convinced, look at the NASA press release. 
Alan Bromley was his science advisor at the time and Alan 
Bromley took advice from a large number of people and discounted 
that press release. 

So I do not believe we or President Bush made policy by looking 
at a press release. 

Mr. Brown. Well, the general principle is sound, that we 
shouldn't. And we've seen that in many, many situations. 

I was very disturbed, serving on the agriculture committee, when 
I saw the first press releases about the bad effect of Alar on apples. 

There is some underlying basis for being worried about Alar. But 
there was no basis for assuming that there would be an epidemic 
of cancer in children because of what we were doing. And yet, the 
press releases would seem to indicate that. 

This bears out your point. 

Now let me say in defense of politicians, that it's sometimes very 
difficult to convey to the public a true sense of a very complex situ- 
ation. And that happens to be true in the case of ozone. 

It is illustrated by a couple of charts which I'd like to raise a 
question about now. 

Dr. Watson, you have in your testimony a chart labelled Figure 
4, which says, global ozone trend — 60 degrees south of 60 degrees 
north. And it seems to indicate a substantial decreasing trend in 
ozone. 

Dr. Baliunas, you have a chart labelled Chart 2, northern hemi- 
sphere ozone, which seems to show no trend in terms of any de- 
crease in ozone. 

And at the first blush, the two charts would seem to be con- 
tradictory. And yet, I note, Dr. Baliunas, that your chart says only 



183 

northern hemisphere ozone and it's measured in some abstruse 
unit which I've never heard of, Dobson units. And it extends from 
1955 to 1990. 

Dr. Watson, your chart only extends from 1975 to 1994. It is not 
measured in the same abstruse unit. Apparently the chart shows 
percent deviation from monthly average. 

Now, I ask you, is the apparent contradiction in what these two 
charts seem to say real or not? 

Dr. Baliunas. There's several factors to note in this Chart 1 and 
Chart 2, which were the same data. 

Mr. Brown. And I'm using this to illustrate the point that some 
of these things are difficult to convey to the public. 

Dr. Baliunas. Yes. These are ground-based data from the north- 
ern hemisphere ozone, slightly different from the data in Dr. Wat- 
son's testimony. 

Mr. Brown. Which eQso includes southern hemisphere. 

Dr. Baliunas. Which also includes southern hemisphere. The 
northern hemisphere data that I show from the ground-based sta- 
tions agrees where the satellite data overlap with it in those re- 
gions. 

And the data I show here in Chart 1 and Chart 2 have been cor- 
rected for the spring to fall seasonal change, but no other effect. It 
hasn't been corrected for the solar effect. It hasn't been corrected 
for the QBO, and it has not been corrected for any other volcano 
impact. 

Dr. Watson's chart I believe does correct for those. So there's not 
real contradiction. It's just that he's charting it to show the trend. 
I was showing some of the natural variability. 

So two different aspects. 

Mr. Brown. But your chart does not show as much, what looks 
like variability, as his chart does. 

Dr. Baliunas. Well, if you look at the percent change, my Chart 
1, which is the same as Chart 2, I still have a lot of natural varia- 
bility, but there is a trend in the latter part of the data that would 
be reflected in his. 

Mr. Brown. I see, yes. 

Dr. Baliunas. If I were to correct everything out, Chart 2 is the 
same data, but on an absolute scale in terms of these Dobson units, 
which is the amount of ozone in the column. 

Mr. Brown. Did you wish to comment, Dr. Watson, about that? 

Dr. Watson. Yes. 

Mr. Brown. And I'm looking for guidance as to how we can con- 
vey this kind of information to a public who doesn't understand 
these things. 

Dr. Watson. Exactly. What the scientists wanted to portray in 
my Figure 4, which is this from the International Ozone Assess- 
ment — it's not my work, personally--was to try and show what 
were the effects of human interactions on the ozone there. 

They took the ozone record from both satellite and from ground- 
based stations and they then took out seasonal fluctuations. They 
took out the effect of what we call the quasi-biannual oscillation. 
That's changes in the weather patterns every two years. And they 
took out the seasonal cycle. 

So you could take out the natural effects on the ozone there. 



184 

What you have left is that trend £ind what one can clearly see, 
there was approximately a 5-percent ozone depletion between 1979 
and 1994. 

If you actually just flip over the page to my Figure 5, you can 
actually see how it is very sensitive to latitude. There is no change 
in the tropics independent of season, and you have a large change, 
larger change, as you move to the mid- and higher latitudes of both 
the northern and southern hemisphere. 

So in the ozone assessment, we try to get the information most 
relevant to policymakers. We try to separate out the long-term 
trend. 

That has nothing to do with natural variability. 

Mr. Brown. All right. I thank you for that explanation. 

Incidentally, do either of the charts, or do any of you, find vari- 
ation here that coincides with the 11- or 12- or 13-year sunspot 
cycle? 

Does that have any bearing on this? 

Dr. Baliunas. Well, all charts of this sort respond to the 11-year 
cycle. It's the solar ultra-violet flux that has to do with this. 

Mr. Brown. Yes. 

Dr. Baliunas. The ultra-violet flux is not directly measured, un- 
fortunately, over this entire interval and has to be determined by 
proxy. 

Mr. Brown. Well, I appreciate this explanation. I think it's help- 
ful to me. 

I apologize again for not being able to spend more time with you. 
I would enjoy it very much. And I thank you, Mr. Chairman. 

Mr. Rohrabacher. I'll have to say that we've had a long panel 
here. I'm hungry, myself. I haven't had anything to eat today. 

Mr. Olver. I'm quite willing to go without lunch for about 5 
more minutes. 

Mr. Rohrabacher. Out of courtesy to my colleague, I will go for- 
ward with another 5 minutes. But let me note just one thing before 
we go into the last round of questioning, then. 

Ajad that is, caveats — I believe that caveats sometimes are not 
properly used. And I know that you've got to say that this is what 
I believe, except, or could be or may be, and all this. 

When I was a journalist, every time I hear people using caveats, 
usually, and I'm not claiming this of this panel at all, but usually, 
caveats are used to create misimpressions. 

I would just warn the panel and warn the Members of the Com- 
mittee, et cetera, that caveats, we should be very skeptical when 
caveats are used. 

Admittedly, when you're trying to be honest about it, it might 
prove just the opposite, meaning that some caveats are used be- 
cause someone realizes that someone on the other side might be 
correct and there might be some avenue there that you're leaving 
yourself open to an honest discussion. 

That's one thought. 

And the other thing. In terms of whether or not the political mis- 
use of certain information created policy in terms of what the ozone 
hole was going to do over the northern hemisphere, one need only 
to say, look at the vote that took place after Mr. Gore's presen- 
tation before this Committee and for his speeches. 



185 

It was a vote of 96 to zero. And I'm sure that there were many 
Republicans that were rather skeptical before. But Mr. Gore up 
there saying, absolutely, there was going to be this ozone hole, I 
bet there was a caveat in there somewhere that probably made it 
clear that it wasn't absolute, but it just sounded like he was saying 
it was absolutely going to happen. 

There were a lot of Republicans that were skeptical who went 
right along with it. And what happened was that the ozone hole 
failed to materialize. 

That's really what we're talking about here. If we're going to 
make policy, let's make it based on things that are real. 

And one last thing before we let Mr. Olver have his 5 minutes 
of questioning. And that is, one of the other things that we have 
to have in order to determine policy is a free and open discussion. 

And perhaps the most disturbing thing that's come out of this 
hearing is not whether or not caveats are being used and whether 
people disagree on this. But instead, what Dr. Baliunas has stated 
very clearly for the record is that there was an attempt to stifle her 
discussion of this issue. 

Now all over the United States, we've heard talk about what's 
politically correct and politically incorrect and heard about there 
are certain forces in our society that are intolerant of disagree- 
ment. 

When we start hearing reports that distinguished scientists and 
the people who are looking into an issue like this have had threats 
that they shouldn't come and testify, or that they shouldn't partici- 
pate in the discussion of an issue, this is very serious. And perhaps 
that's the most serious thing that came out of this hearing today. 

I plan to follow through with Dr. Baliunas on this, and I will be 
contacting directly those groups within government, and outside of 
government as well, that think that they can try to stifle discussion 
on issues like this. 

Ms. Rivers. Mr. Chair, can we make sure that the findings — 
first, the accusations and the findings are a part of the official 
record so that since this was raised in the course of this discussion, 
it will be on the record for Congress and the American people? 

Mr. Rohrabacher. Would you submit for the record a letter de- 
tailing efforts that have been made, that you believe were made on 
this issue, not just for this hearing, but over your discussion of this 
issue, that you've seen where groups inside government and out- 
side government have tried to stifle discussion of this issue? 

Dr. Baliunas. I will. 

Mr. Rohrabacher. So we can expect that. 

Ms. Rivers. And please, specificity is important in these kinds 
of accusations. 

Mr. Rohrabacher. That's correct. 

Ms. Rivers. Dr. Watson. 

Dr. Watson. Yes, Mr. Chairman. I view that as one of the most 
serious things I've heard today. I know this Administration would 
certainly like to know of any wrong-doing by any federal employee 
who has tried in any way to threaten or coerce Dr. Baliunas. 

So we would like, through you, Mr. Chairman, that when infor- 
mation, written information, is documented, is sent to you, I cer- 



186 

tainly will take this to the President's science advisors and other 
relevant people in the Administration. 

Mr. ROHRABACHER. We will do a preliminary investigation of 
this, and I can tell you that if we find there to be validity to this 
charge, that there will be another hearing and we will have people 
called before this Committee and put under oath to see what 
they're doing. 

I can guarantee you that right now. 

Mr. Olver, you've got 5 minutes while my stomach is growling. 

Mr. Olver. Thank you very much, Mr. Chairman. 

I was very grateful for the former Chairman's and Ranking 
Member's discussion here. But I have been working in the same 
kind of direction, trying to figure out — I've been looking, having 
had a little bit more time to think about these graphs and so forth. 

I'm still a bit puzzled. Let me ask a few quickies here. 

Do we all agree on the scientific side of this panel, the atmos- 
pheric side of the panel, at least, without the biological side, be- 
cause I really want to talk about the ozone layer itself here, that 
there is little seasonal variation in the tropics of ozone? 

Is that relatively agreed? Okay. And may I use the tropics as 30 
north to 30 south, or is that not a fair usage? Roughly. Roughly? 
Okay. 

All right. So if we agree that that is relatively nonseasonal, and 
we also agree — let me see if this is true, that there is an agreement 
on the part of the scientists that the ozone problem depletion oc- 
curs more in the southern hemisphere around Antarctica because 
that's where the ice crystals are. It's colder. Ice is necessary, along 
with the chlorine or fluorine or bromine or something or other, in 
there. 

Is that also agreed on? Okay. 

Now, if that's the case, then there is something really puzzling 
about these two pieces of data. Even after one corrects, as the 
Ranking Member had gone through, and recognizing that Dr. 
Baliunas's data is only for — well, cover 50 years, 40 years, what- 
ever. And the data on the part of Dr. Watson is really only 15 
years. 

So you're only looking at the eastern end of this data on the part 
of Dr. Baliunas. And that's falling, where it looks only at the north- 
ern hemisphere, which the 30 to 60 on the northern side, which is 
less subject to the closeness to the great hole that appears season- 
ally each year in the southern hemisphere. And yet, the percent- 
ages that are being shown there are plus or minus only a few per- 
cent. Even at its peaks it's zero and goes to minus four. Whereas, 
the data that covers and averages across everjrthing, all four of 
these sectors, from plus 60 to minus 60, is data that shows a trend 
here going at the 6 percent level. 

Which suggests, at least, that the corrections that Dr. Baliunas 
has agreed have been made in the data, must be pretty dramatic 
for that set of data to also be true. 

If you follow that — I see some people sort of nodding roughly. So 
the general thing. 

If we've corrected for everything and haven't over-corrected and 
so forth, then there's some pretty dramatic differences between 
these two data, sets of data, as they have been put forward. 



187 

Now let me just follow with Dr. Singer for a minute. 

I think I understand from what you saiid that you feel that one 
should be considering several cycles, several sun cycles, solar cy- 
cles, 11-year solar cycles. And we really only have data going back 
maybe three cycles, while we've had CFCs. 

I think the argument is that you can't yet tell whether CFCs, 
CVCs, whatever, has had much effect on this because we haven't 
been able to go back more than a couple of cycles while we were 
producing these things. 

Is that what I'm hearing? 

Dr. Singer. You're partly correct, sir. 

The reason we need a number of solar cycles has nothing to do 
with CFCs, as such. It has to do with the fact that each solar cycle 
is different from each other. The sunspot number in each cycle is 
different. 

Mr. Olver. Okay. 

Dr. Singer. They're sort of sui generis. In other words, you can- 
not 

Mr. Olver, But you have said that the maximum ozone occurred 
a couple of cycles ago and so ever3rthing obviously is going to go 
downhill from that because that was maximum. 

Dr. Singer. Yes, sir. 

Mr. Olver. What is the nature of our data? You've said, yes, you 
agree to that. 

Dr. Singer. We have ground-based ozone data only since 1957. 

Mr. Olver. So we've got three cycles' worth of ground-based 
ozone data. 

Dr. Singer. On a global scale, yes. 

Mr. Olver. And before that, we don't know. 

Dr. Singer. Before that, we have ozones 

Mr. Olver. So how can you say that that was at a maximum at 
the time that CFCs and so forth began to come in, if we don't have 
that ground-based data in the first place? 

Dr. Singer. Ground-based data on a global scale only started in 
1957. 

Mr. Olver. But then, how can you say that that was at a maxi- 
mum at that time? Clearly, it's gone down since that time. 

Dr. Singer. Actually, we have a record of global ozone, actually, 
observation, since 1957. And according to the information pub- 
lished, ozone showed a maximum in 1970 and then started to go 
down. 

Mr. Olver. Basically, three cycles. 

Dr. Singer. The question is, is this due to solar effects or natural 
changes, or is it due to CFCs? 

Mr. Olver. But your comment, if I remember correctly, was that 
you're not convinced that the ozone layer depletion has anything to 
do with CFCs and it may be just natural phenomena that would 
have been there is we looked back farther. 

Dr. Singer. Yes. 

Mr. Olver. If we looked back six or more cycles farther back, 
that we would see a series of cycles along these lines. 

Dr. Singer. Yes. And the reason I think so 

Mr. Olver. Do you agree that the ozone layer, that the ozone 
hole is expanding, is larger than it was some years ago? 



188 

Dr. Singer. That's an interesting question. Let me answer all of 
these interesting questions, if I can. 

Mr. ROHRABACHER. This will have to be the last question. 

Dr. Singer. Starting with the ozone hole. The ozone hole, as I 
mentioned before, was not predicted by the theory. This is why I'm 
skeptical of the present theory. 

The present theory cannot even predict what the hole will be like 
next year, or 10 years from now, or 20 years from now. The reason 
for this is that the hole is pretty much controlled by climate 
changes and not by ozone concentration — sorry — ^by chlorine con- 
centration at this stage. 

The hole, as I mentioned before, is genuine. It's a transient phe- 
nomenon. 

Now the question of global ozone is quite different from the ques- 
tion of the Antarctic hole. The question is what was the global 
ozone like before 1957? 

My answer is I wish we knew. But we do have some idea because 
we have sunspot number observations and we know that ozone de- 
pends on the sunspot number in some way. The more sunspots you 
have, the more ozone you have in the atmosphere. 

And that's why, since sunspots have an 11-year cycle, you see an 
11-year cycle also in the ozone in the last 35 years. 

Now, you may know that sunspots have varied tremendously 
over the last two hundred years. There was a period of time around 
1700 when there were no sunspots for many years, for some rea- 
son. We don't know why. 

Actually, Sallie Baliunas is probably a greater expert on this 
than I am and will tell you that this is so. 

And my supposition is that ozone should have varied by tremen- 
dous amounts naturally because of these large natural variations 
in sunspot number. 

Mr. Olver. I have a feeling that I could understand this. 

Mr. ROHRABACHER. That's the opposite feeling that I have. 
[Laughter.] 

As the Chairman, I'm going to use the Chairman's prerogative to 
give Dr. Watson 30 seconds to summarize his reaction to that last 
statement, out of fairness, and then to call a halt to this panel. 

Dr. Watson. Two quick questions. Dr. Singer is right. We only 
have about 30 years or three solar cycles of global ozone. We have 
some individual stations like at Rosa that go back to 1930, six solar 
cycles. 

So when we've analyzed over six solar cycles 

Mr. Olver. Where? 

Dr. Watson. At Rosa in Switzerland. When we take that data 
and all the satellite data and all the global ground-based data, we 
tend to believe, based on a lot of analysis, that the maximum solar 
variability is only 1 to 2 percent. 

And yet, what we're observing in many latitudes is ozone deple- 
tions of 5 to 10 percent. 

So the solar variability is small compared to the observed trends. 

Mr. Olver. It's a correction that you make. 

Dr. Watson. It's a correction and it's taken into account in all 
statistical analysis. 



189 

Mr. ROHRABACHER. With that, I'm sure that the transcript of this 
hearing will be perused by people who have much greater depth of 
understanding of these issues than the Chairman. 

I want to thank each and every one of you. I appreciate your tes- 
timony. I think this has been very thought-provoking. It's also 
thought-provoking to people who are decision-makers and have 
some scientific background. 

I think we've accomplished something here today. 

So thank you all for participating. I'm going to have lunch. We 
will be back in one-half hour, which makes it 2:15, we'll reconvene. 

We're in recess. 

[Whereupon, at 1:45 p.m., the Subcommittee recessed, to recon- 
vene at 2:15 p.m., of the same day.] 

Afternoon Session 

Mr. ROHRABACHER. I'd like to welcome all of you back and wel- 
come the second panel for today. 

I think that the last panel provided some very thought-provoking 
intellectual confrontations. I was very pleased that we had the 
issue for what I consider to be a high level of debate on a very im- 
portant issue. 

Our second panel consists of: 

Mary D. Nichols, who serves as Assistant Administrator for Air 
and Radiation at the Environmental Protection Agency; 

Ben Lieberman, an environmental researcher, an environmental 
researcher with the Competitive Enterprise Institute; 

Kevin Fay is with the Alliance for Responsible Atmospheric Pol- 
icy, an industry-sponsored organization; 

Richard Stroup is an economics professor at Montana State Uni- 
versity and a senior associate with the Policy Economy Research 
Center in Montana, as well; and finally. 

Dale Pollet. He is a project leader at the Louisiana Cooperative 
Extension Service. 

Jimmy Hayes is not here to introduce you, but he was schedule 
to. So I am sure he is at a hearing, making his vote count. 

So, Mr. Pollet, and the rest of you, I'd like to welcome you to the 
hearing today. 

I think we will then start off with Ms. Nichols. 

STATEMENT OF THE HONORABLE MARY D. NICHOLS, ASSIST- 
ANT ADMINISTRATOR FOR AIR AND RADIATION, UNITED 
STATES ENVIRONMENTAL PROTECTION AGENCY, WASHING- 
TON, DC 

Ms. Nichols. Thank you, Mr. Chairman. 

Mr. ROHRABACHER. And again, if we could do, as we did with the 
first panel, try to look at 5 minutes and then we'll have some dis- 
cussion between us afterwards. 

Thank you. 

Ms. Nichols. I'll do my best to summarize my summary of my 
testimony. 

I'd like to start off by saying, Mr. Chairman, that I believe that 
the global phase-out of CFCs and other ozone-depleting chemicals 
is a model of the proper relationship between science, economics, 
and international diplomacy. 



190 

It rest on an overwhelming consensus within the community of 
qualified scientists, economists, and business analysts. 

The phase-out policy was developed under Presidents Reagsin 
and Bush, with strong bipartisan support, and the Clinton Admin- 
istration is proud to carry it forward to its completion. 

In addition, it enjoys overwhelming international support with 
150 nations having become parties to the Montreal Protocol. 

And indeed, to the best of my knowledge, Mr. Chairman, this is 
the only country in the world which is even considering the possi- 
bility of altering the phase-out schedule. 

Mr. Chairman, protecting the ozone layer should be a matter of 
common ground. And I am puzzled and dismayed that, apparently, 
it is not. 

I am particularly concerned by Congressman DeLay's legislation 
that would entirely repeal the ozone layer protection provisions of 
the Clesin Air Act, as well as by Congressman Doolittle's proposal 
which is only a little less drastic, to roll back the CFC phase-out 
deadline to 2000. 

I believe that these proposals would be disastrous, not only to the 
ozone layer, but also to the health of the American people, because 
they would exalt what I think have to be considered fringe views 
on science and economics over the international scientific consen- 
sus, as well as wreaking havoc in industries that have invested 
very large sums of money, talent and effort to make a smooth tran- 
sition away from CFCs. 

They would also, of course, put the United States in violation of 
the Montreal Protocol and break faith with the other nations of the 
world that have been and are doing their part to protect the ozone 
layer. 

I've been asked to focus primarily on the decision that was made 
in 1992, before my arrival here in Washington, to accelerate the 
CFC phase-out deadline from 2000 to 1996. 

And I'd just like to point out that the decision, I believe, having 
looked at it again, was right at the time that it was made and is 
even more clearly justified in retrospect today. 

I'm not going to go through all of the arguments on the climate 
issue. I think you heard a lot from the scientists this morning. 

Rather simply to say, I'm not a scientist. I'm not here in that ca- 
pacity. I'm a policy-maker and have been for many years in areas 
that deal with science and environmental policy. 

In making the decisions about implementing this program, I 
need to rely on the work of scientists. 

And I have to say that when you look at the list, such as the one 
that's on that chart that's in front of you, of the international at- 
mospheric chemists who have completed the review of the chem- 
istry on ozone depletion for the United Nations's evaluation that 
was most recently completed, and who signed on to the assessment 
that supports the phase-out, on the one side, compared with the 
list on the other side, I think it is compelling to a person in my 
position. 

I have been charged to act in defense of the environment, using 
the best sound science at our disposal. I believe that, in that con- 
text, numbers, or at least numbers of reports by people with the 
appropriate credentials, do have to count. 



191 

Now, on the issue of the costs and the benefits of the phase-out, 
and whether the health effects are justified, I'm sure you're going 
to be hearing a lot more about that from others. 

I'd simply like to use the chart here again — I did ask to have a 
couple of things blown up, simply because I think it's a good illus- 
tration—that even if you ignore the difficulties about melanoma in 
terms of the lack of an exact cost-benefit, or cost risk to dose re- 
sponse ratio, and simply focus on the non-melanoma sldn cancers 
about which there is essentially 95 percent agreement among the 
health scientists on this issue, the costs of the program, of the 
phase-out program, are exceeded by the benefits by as much as 700 
to one. 

Now that's a cumulative number, admittedly, over the whole pe- 
riod of the program. 

So I would simply say that with respect to the accelerated phase- 
out— that is, moving it from the year 2000 to the year 1996 — the 
incremental cost of doing that was about $9.9 billion. That's mostly 
in retrofitting things that would otherwise have been replaced. And 
the benefits range there, again, just for the nonmelanoma cancers, 
is approximately $220 to $860 billion. 

I think, in the work that we do, that's an extremely attractive 
investment. 

I'd also like to just briefly focus on the major controversy, and 
that is on the report by the CEI. And I know Mr. Lieberman is 
here and he will adequately defend his own report. But I'd like to 
just simply highlight why it is that we differ in our assessment of 
the costs and benefits from the data that's put forward in that re- 
port. 

CEI claims that the phase-out will cost $45 to $100 billion. We 
conclude that those numbers are way off. And they're way off be- 
cause of a couple of key errors in the way that the assessment was 
done. 

Primarily, these have to do with some incorrect assumptions 
about replacement schedules, an assumption that refrigerators 
usmg HFC will cost $50 to $100 more, which is not true, an as- 
sumption that the new technology is more prone to breakdowns, 
which has not proven out to be true, failure to consider the im- 
proved energy efficiency of the new refrigerators, which nets a ben- 
efit of more than $5 billion over a ten-year period to the consumers. 
As well as errors in the cost of retrofits and mistakes about the via- 
bility of alternatives. 

I think that I'll leave that up here and we'll, I'm sure, want to 
refer to it later in questions and answers. 

But I'd just like to conclude by saying that we at EPA are proud 
of the work that we have been doing in implementing the Montreal 
Protocol. We feel that it's a success story not only for the environ- 
ment, but for the business community as well. 

Thank you for your interest. 

[The complete prepared statement of Ms. Nichols follows:! 



192 



TESTIMONY^F MARY D. NICHOLS 

ASSISTANT ADMINISTRAJOR^R 

A\RhiB-RAD\AT\OH 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

BEFORE THE 

SUBCOMMITTEE ON ENERGY AND ENVIRONMENT 

OF THE 

COMMITTEE ON SCIENCE 

U.S. HOUSE OF REPRESENTATIVES 

September 20, 1995 



Mr. Chairman, Members of the Subcommittee, thank you for the opportunity to 
testify before you on protection of the stratospheric ozone layer. The global phaseout of 
CFCs and other ozone-depleting chemicals is an unparalleled triumph of the soundest 
possible science, economics, and diplomacy. It rests on an ovenvhelming consensus 
within the community of qualified sdentists. The same consensus exists among 
qualified economists and business analysts on the costs and consequences of the 
phaseout. The phaseout policy was developed under Presidents Reagan and Bush with 
strong bipartisan support, and the Clinton Administration is proud to carry it footvard to 
completion. This policy rightly enjoys overwhelming public support in this country and 
around the worid. One hundred and fifty nations have become parties to the Montreal 
Protocol, the treaty through which the phaseout is being accomplished woricf-wide. 

Mr. Chairman, protecting the ozone layer should be a matter of common ground 
between us. I am both puzzled and dismayed that, apparently, it is not. 

I am especially dismayed by Congressman Delay's proposal to entirely repeal the 
ozone layer protection provisions of the Clean Air Act, and by Congressman Doolittle's 



193 



2 

proposal - only one step less drastic - to rollback the CFC phaseout deadline to 2000. 
These proposals would be disastrous to the ozone layer and to the health of the 
American people. They would exalt fringe views on science and economics over the 
intemational scientific consensus. They would wreak havoc in industries that have 
invested very large sums of money, talent, and effort in carrying out the smooth 
transition away from CFCs. Finally, they would put the United States in violation of the 
Montreal Protocol and break faith with other nations that, under that treaty, have done 
their part in the global effort to protect the ozone layer. 

I have been asked to focus primarily on the scientific basis for accelerating the 
CFC phaseout from 2000 to the beginning of 1996, and on the economic costs of doing 
so. This decision was right when it was made under the Bush Administration in 1992, 
and it is even more cleariy justified in retrospect today. Some of the witnesses here 
today, who stand for outside the consensus of qualified experts, claim that the benefits 
of this step were exaggerated and the costs underestimated. Building on the testimony 
of Drs. Watson, Albritton, and Kripke, I will address why the critics are wrong on both 
the science and the economics. 

You will recall that the original Montreal Protocol was negotiated and signed in 
1987 under PreskJent Reagan. President Bush was twk» responsible for accelerating 
the phaseout of ozone-depleting substances, first in 1990 and again in 1992, to the 
current end-of-year deadline for ending CFC production. The decision to speed up the 
CFC phaseout to 1 996 was taken domestically under the Clean Air Act and 
intemationally under the Montreal Protocol. As you are aware. Section 606(a) of the 



194 



3 
1990 Clean Air Act Amendments directed the Administrator to accelerate the phaseout 
if any one of three conditions existed: . 

• if at any time an assessment of current scientific information pointed to the 
need for a more stringent schedule to protect the environment; 

• if the availabifity of substitutes for listed substances made a more stringent 
schedule practicable, taking into account technological achievability, 
safety, and other relevant Actors; qt 

• if the Montreal Protocol was modified to phase chemicals out more rapidly 
than the then-existing Clean Air Act schedule. 

All three of these conditions were met in 1 992, and remain valid today. 

Addressing the first criterion, it is important to realize that the scientific basis for 
accelerating the phaseout did not represent simply EPA's view of the science. From the 
very beginning, EPA has relied on intemational scientific ozone assessments conducted 
by several hundred of the world's leading atmospheric and health scientists, who 
reviewed all available data. These assessments represent the definitive statement on 
the state of the science and provide the soundest possible basis for EPA and 
intemational action. The 1992 scientific assessment further strengthened the link 
between CFCs and ozone depletion and showed that ozone depletion was taking place 
at a substantially greater rate than had been thought just two years before, when the 
deadline of 2000 was adopted. The most recent scientific assessment, issued eariier 
this year (Scientific Assessment of Ozone Depletion: 1994; WMO Report 37), confirms 
the conclusions of the 1 992 assessment concerning the effects of CFCs. 



195 



4 

You have heard various complaints about these assessments from witnesses 
this morning. The substantive issues they raised were fully examined and thoroughly 
rejected through the science assessment process. Basing policy on these scientific 
assessments cleariy represents the use of sound science. To reject those assessments 
based on the complaints you have heard today would mock sound science. 

For example, the claim has been made that (1) UV-B radiation plays no rote in 
the development of melanoma skin cancer and (2) therefore we need not be concerned 
about ozone depletion. The first proposition is extreme: the preponderance of evkJence 
suggests that UV-B does in ^ct play a significant role in causing melanoma, although 
the exact dose-response relationship appears complex. 

The second proposition is also misguided. The accelerated CFC phaseout would 
still be easily justified even if there were ng link between UV-B and melanoma skin 
cancers, because over 85% of the quantified health t>enefits of the phaseout come from 
avoiding non-melanoma skin cancers and cataracts. 

We have also heard it said that ozone depletion woukJ increase UV-B radiation 
by no more than if you moved a few hundred miles south - whk^ people do all the time. 
The reality is more serious. Cities near the equator receive about 20% more UV 
radiation than cities further from the equator, and skin cancer rates in cities closer to the 
equator are higher. For example, in a recent study, skin cancer rates for white males in 
Albuquerque, New Mexico were approximately 700 per 100,000 versus 150 per 100,000 
for a similar population in Seattle. Given current depletk>n rates of about 5% at 
midlatitudes, people living in Washington, D.C. experience the equivalent of the 
radiation they would have received if they visited Jacksonville, Florida. While it may not 

■ ■ J ■ 



196 



5 
matter if one person moves south, the reality of ozone depletion is a move south for the 
entire U.S. population. The change in lifetime risk for the susceptible population for 
developing skin cancer is significant. 

We are cun^ntly experiencing depletion of approximately 5% at midlatitudes. 
Moreover, if no action had been taken to limit CFCs, depletion would eventually have 
reached as high as 20% or more , and UV-B increases and resulting increases in skin 
cancers would have been drastic indeed. 

Let me tum now to the second criterion set forth in the Clean Air Act: whether 
the increased availability of substitutes for CFCs made it practical to speed up the 
phaseout to 1996. Due to the maricet signals created by the phaseout, and to the 
remari<able efforts of hundreds of finms in dozens of industries, the rate of technological 
changes have exceeded all expectations. Once consensus existed on the need to 
replace these substances, producers and manufacturers responded quickly and shifted 
to alternatives. Because of these advances, no industry challenged moving the 
deadline up to 1996. 

As to the third statutory criterion, the Parties to the Montreal Protocol decided in 
1992 to move the CFC phaseout up to 1996. Methyl chlorofomi and carbon 
tetrachloride were also scheduled for phaseout by 1996, and halons were given a 
deadline of 1994. The United States is one of 150 countries that is a Party to the 
Protocol. We supported the 1996 deadline then, as did all our economic competitors. I 
am not aware of any country in the worid that is considering any rollback on its CFC 
phaseout commitment. In fact, much of Europe completed the phaseout last year. I 



197 



6 

should also note that any move to postpone the domestic phaseout deadline would put 
this country in violation of the Montreal Protocol and intemational law. 

I would now like to tum to the costs and benefits of our phaseout program. 
Thorough cost and benefit analyses were undertaken both in 1990 for the decision to 
phase out by 2000, and in 1992 to support the acceleration to 1996. These studies 
reflect years of research on cause, effect, costs, and benefits. On the cost side, we 
have extensively involved all aspects of industry - producers and users, big and small 
companies, original equipment makers and service and repair industries. 

Our studies and all inputs and comments from others were made public for 
comment. We are confident that the numbers accurately reflect the costs and benefits 
of this program. 

Based on these extensive regulatory impact analyses, EPA's 1992 analysis 
indicates that the benefits of the phaseout exceed its costs by a factor of up to 700 to 1 . 
If we were to update this analysis based on the information available in the 1994 
intemational assessments, this ratio of benefits to costs would continue to be 
ovenwhelming. We estimated that the total cumulative cost of the current 1 996 
phaseout requirements would be approximately $10 billion for the period 1989-2000, 
and approximately $46 billion over the period 1989-2075, based on a 2% discount rate. 
The total public health benefits from reduced cases of skin cancer, cataracts, and other 
health effects are estimated to be between $8 and $32 trillion over the same period (the 
range depends on the assumed value of a life). As noted above, 85% of the program's 
benefits come from avoided non -melanoma skin cancers. The bottom line is that we 
are getting an incredibly large bang for the buck! 



198 



7 

Despite these extensive analyses, some recent reports have outlandishly inflated 
the costs of the phaseout. For example, the Competitiveness Enterprise Institute (CEI) 
in its report, The High Cost of Coot," begins with demonstrably wrong Actual 
assumptions, makes numerous methodological errors, and thus reaches unsupported 
conclusions. 

For exampile, the report erroneously implies that for many applications, existing 
air-conditioning and refrigeration equipment will have to be discarded and replaced 
immediately. This is just plain wrong. Existing equipment can remain in use indefinitely, 
and substantial amounts of recycled CFCs will be available to repair that equipment for 
years to come. 

Further, industry has been extremely successful in developing low-cost retrofits 
for existing equipment and highly energy-efficient new equipment that wori<s without 
CFCs. Overall costs will be relatively low because these energy efficiency gains 
significantly reduce lifetime operating expenses. In ^ct, in some sectors, such as 
household refrigeration and building chillers, it will often pay for homeowners or building 
owners to replace current equipment well before it has broken down. 

Another emor the CEI report assumes that HFC-1 34a refrigerators will cost $50 
to $100 higher than similar CFC-12 refrigerators. The leading refrigerator makers 
disagree, however. According to them, the prices of these appliances will not increase 
as a result of the altemative refrigerant. CEI's report also assumes that new technology 
is more prone to ^ilure. But manufecturer warranties have not changed for the new 
HFC-1 34a appliances. Again, CEI has feiled to consider that these new appliances are 



199 



8 
up to 30% more energy efficient, and will net consumers energy savings of $5.1 billion 
over the next 10 years. 

The CEI report also claims that the average cost of a mobile air-conditioner 
retrofit is $433. In ^ct, the extra cost of a retrofit (over prior repair costs) was estimated 
in 1991 to be $217. Because substantial progress continues to be made, the most 
recent estimate is that a minimum cost retrofit (one that is made when other major 
repairs are needed) will cost under $100. The marketplace has also responded to the 
production phaseout by building significant reserves of CFC-12 for sale and use after 
the production ban, which will permit millions of car owners to avoid retrofit entirely. 
Additionally, a number of firms are developing and testing innovative refrigerants that 
could even further reduce car owners' repair costs. 

In sum, EPA estimates the cost of the phaseout to be $4 billion to the 
refrigeration and air-conditioning sector over a 12-year period. While this is not an 
inconsiderable sum, it is less than 1/10th to 1/25th of the inflated $45-100 billion figure 
from CEI. 

L^t me tum briefly to another ozone-depleting substance, methyl bromide, which 
is scheduled to be phased out domestically under the Clean Air Act in 2001 . Methyl 
bromide is a pesticide used in a substantial variety of agricultural applications. The 
1992 and 1994 intemational scientific assessments have concluded that it is a powerful 
ozone<lepleting chemical and an important contributor to ozone depletion, especially in 
the near term. The 1994 UNEP Scientific Assessment of Ozone Depletion, peer- 
reviewed by over 250 scientists, found that the ozone-depleting potential for methyl 
bromide is 0.6. The range of uncertainty would bring it to no lower that 0.3 and no 



200 



9 
higher than 0.9. Even the lowest end of this range exceeds the 0.2 threshold that 
makes a chemical a class I ozone depleting substance that must be phased out under 
the Clean Air Act. The 1994 Science Assessment states that "Methyl bromide 
continues to be viewed as a significant ozone-depleting compound." Additional 
research is ongoing to address outstanding uncertainties, and to define the precise 
OOP, which may turn out to be slightly higher or lower than 0.6. The Assessment also 
stated that the elimination of anthropogenic methyl bromide emissions is the single most 
effective policy to further reduce ozone destruction over the next several years. 

Farm users of methyl bromide are understandably concemed that they do not 
currently have satis^ctory substitutes for all uses of this chemical. I understand and am 
sympathetic to their concern. In the long run, the critical issue, though, is not whether 
technically and economically adequate alternatives for all methyl bromide uses are 
available now, but whether they will be available by the time the phaseout deadline 
arrives. There will not be a single chemical that replaces ail of the many uses of methyl 
bromide. Alternatives to methyl bnsmide are often pest-specific, and can reduce pest 
levels when used as part of an overall integrated pest management program. 
Numerous chemical and non-chemical methods may effectively control many of the 
pests on which methyl bromide is used. Research on additional altematives is under 
way and will likely result in a wide range of options. Viable alternative materials need 
not be identical to methyl bromide, but must effectively and economically manage pests 
now being controlled by methyl bromide. , . 

We fully recognize, however, that there is no guarantee that acceptable 
altematives will be available for all uses of methyl bromide prior to 2001. We believe 



201 



10 
that having a safety valve - allowing continued production for specified essential uses 
where no alternatives exist - is an important part of this process. To this end, we are 
willing to work with stakeholders to craft an appropriate safety valve that would permit 
applications for essential use exemptions if they are needed as the phaseout deadline 
approaches. 

The recent bill introduced by Congressman Miller is not an acceptable solution to 
the problem. It would retum to the regulatory structure of the 1950's and 1960's by 
overriding both the Clean Air Act and the Federal Insecticide, Fungicide and 
Rodenticide Act and retuming effective control over this pesticide to USDA. The bill 
would place the U.S. out of compliance vkrith the Montreal Protocol through which this 
country has achieved unprecedented intemational cooperation to protect the ozone 
layer under presidents of both parties. The bill would also replace the innovative, 
market-driven phaseout process which has worthed flexibly and successfully for other 
ozone-depleting chemicals with a complicated "command and control" regime requiring 
specific rulings for thousands of current methyl bromide uses. By effectively blocking 
the phaseout of methyl bromide in the U.S., the bill would ensure higher levels of 
dangerous ozone depletion. We are willing to worit with stakeholders on an essential 
use provision, as I have said. A broad rollback of the methyl bromide phaseout is 
simply not waranted. 

In closing, we must stay the course if we are to be successful in restoring the 
ozone layer. We must continue our leadership role by meeting our phaseout 
commitments as a Party to the Montreal Protocol, and ensuring that we take the 
responsible road of decreasing skin cancer and cataract risks for our children and future 



202 



11 
generations. This is where sound science and sound pdicy lead. I urge you to join and 
support us in this effort. 

Thanit you. Mr. Chairman, Members of the Subcommittee for your attention. I 
would be happy to answer any questions you may have. 



203 

Mr. ROHRABACHER. Mr. Fay, we've got a vote that's coming up 
in about 13 minutes. So you've got 5 minutes. 
Then we'll break and we'll vote and we'll come right back. 

STATEMENT OF KEVIN FAY, ALLIANCE FOR RESPONSIBLE 
ATMOSPHERIC POLICY, ARLINGTON, VA 

Mr. Fay. Thank you, Mr. Chairman. 

You have my formal written testimony before you. I'll try to 
quickly summarize our written statement. 

At the outset, let me tell you that I represent the businesses and 
industries, large and small, who have had to live with this issue 
for the last 20 years. We're very interested in a good environment. 

But we're also very interested in a good economic climate in 
which to do business. We're interested in balanced budgets, regu- 
latory reform, low taxes, and other such desirable things. 

But there are so many myths and misrepresentations on this 
issue, it's difficult for policy-makers and for businessmen often- 
times to know which way to turn. 

Let me make one thing real clear. 

No one, no one, not us, not the environmentalists, not EPA, not 
the scientific community, not the media, and not political policy- 
makers, can claim the mantle of complete virtue on this issue. 

First of all, I can state without any doubt, as one who has lived 
throughout this entire 20-year process on this, the acceleration of 
the phase-out of CFCs in 1992, had nothing to do with the Feb- 
ruary, 1992 press conference by NASA. 

The decades-long examination of ozone science is well understood 
and supported by expert industry scientists. 

From our perspective, while we may disagree on the rates of 
chsinge or estimates of environmental effects, we long ago reached 
an agreement on the appropriate course of action. 

There's no question that political opportunists have taken their 
shots at us and at the American consumers through the adoption 
of multi-billion-dollar excise taxes or through the adoption of cer- 
tain unnecessary regulations mandated by the Clean Air Act. 

Political opportunists continue to try to take advantage of this 
issue. Recent efforts to try to portray the so-called analysis as fact, 
such as CEI has done, or to somehow link the deaths, as he tried 
to do recently in his op-ed piece, the deaths in the Chicago 
heatwave, is shocking in its irresponsibility. 

Even Fred Singer this morning agreed that CFCs should be 
phased out. 

What we are debating is the rate of change both in the environ- 
ment, in the industry, and among the public. 

The crux of the policy debate appears here to be over about four 
to five years of CFC production. 

The realities are the fundamental scientific basis for the CFC 
phase-out is credible and has remained basically unchanged since 
the original policy decision to phase out production of the com- 
pounds. 

The producer and user industries acted responsibly in moving 
quickly to develop and implement safe and effective substitute 
technologies that allowed that phase-out to be accelerated. 



204 

Because of that quick action, further harsh measures regarding 
other compounds such as HCFCs, are unnecessary today. 

Much work remains to be done, however, in order to ensure full 
compliance with the protocol both here and at the international 
level, including completion of the phase-out in developing countries. 

Much still can be done to reduce the costs and regulatory bur- 
dens imposed as a result of the congressionally mandated excise 
taxes and certain provisions of the Clean Air Act. 

While we think the examination of the scientific activities is cer- 
tainly useful, we believe that the proper congressional focus at this 
time should be the streamlining of policies in effect in this country 
and at the international bargaining table. 

This should be done in order to ensure the completion of the 
transition out of ozone-depleting CFCs while maintaining our eco- 
nomic competitiveness. 

We have several suggestions. 

At the international level, the U.S. should take a strong position 
that there's no need to alter the protocol's control schedule on 
HCFCs. The protocol's technology and assessment panel experts, of 
which we have participated, have agreed that HCFCs are critical 
in order to achieve the CFC phase-out. 

The protocol parties must continue progress to have the develop- 
ing countries eliminate their reliance on CFCs. The treaty does 
provide for a delay of phase-out in these countries. 

Many major developing countries, including Brazil, China, Mex- 
ico and Malaysia, have announced phase-outs well in advance of 
the treaty requirements. 

The U.S. should be fostering these actions by fulfilling its exist- 
ing financial commitment to the protocol multilateral fund, rather 
than eliminating funding, as has been proposed in the current ap- 
propriations process. 

According to one estimate, the government has collected more 
than $6 billion in ozone depletion excise taxes from U.S. consumers 
of CFCs. It is difficult to understand the justification for not fund- 
ing the protocol efforts since the American taxpayer has paid for 
it. 

The more quickly developing countries phase out of CFCs, the 
more likely that U.S. technologies, with their accompanying jobs, 
could be adopted in order to accomplish this objective. 

Because of the quick action to address the issue internationally, 
the parties to the protocol should also be encouraged not to revisit 
the treaty every two years in anticipation of major amendments. 

This is what they've been doing. 

The basic framework is working well and should not now be re- 
visited unless there is significant new scientific information. 

At home, several steps could be taken in order to streamline the 
regulatory provisions. 

The Congress could eliminate several provisions of Title 6 of the 
Clean Air Act amendments that have the potential to impose great 
costs, but which provide no significant environmental benefit. 

The labelling provisions, particularly with regard to HCFCs, 
should be deleted altogether. 

The safe alternatives program could be sunset once there is no 
nexus to substitution of ozone-depleting compounds. In fact, the al- 



205 

liance has filed a legal challenge to the EPA snap program in order 
to prevent unnecessary overreaching. And provisions eliminating 
the use of substitutes in so-called non-essential products could be 
deleted. 

Continued increases in the ozone depletion excise tax, which is 
scheduled to continue going up every year, should be ended. In fact, 
if the Congress is truly concerned about the cost to the consumer 
of the ozone protection program, it could adopt a tax credit for 
equipment retrofits. 

The alliance believes that such a program could be revenue-neu- 
tral in the near- term. 

Finally, the government must continue to enforce the laws con- 
cerning the illegal import of CFCs. The illegal imports and the 
avoidance of excise tax in these compounds m^e CFCs more avail- 
able, reduce the incentive for users to shift, and penalize legitimate 
companies who are complying with the laws. 

The illegal imports create the impression in the marketplace that 
CFCs are plentiful and that retrofits can be deferred. 

They're also frustrating the attempts of legitimate businesses to 
plan for the post-production period. 

Finally, the effects science should be continued. We do not have 
a good scientific understanding of ozone depletion effects. There is 
no question about that. We've known that all along. It's shocking 
that it has not been done. 

I will stop there and let you go vote. 

Thank you. 

[The complete prepared statement of Mr. Fay follows:] 




206 



Alliance for Responsible Atmospheric Policy 

2111 Wilson Boulevard 
Arlington, Virginia 22201 
703-243-0344 
Fax 703-243-2874 



TBSTrMON\^OF 

KEVIN Fi^ 

ALLUNCE FOR RfiSPeNSfBirEATMOSPHERIC POLICY 

HOUSE COMMITTEE ON SCIENCE 

SUBCOMMITTEE ON ENERGY AND ENVIRONMENT 

SEPTEMBER 20, 1995 

Thank you Mr. Chairman, and members of the Committee. My name is Kevin Fay; and I 
am counsel to the Alliance for Responsible Atmospheric Policy. I am pleased to appear 
before you on behalf of the approximately 250 industry members of the Alliance. The 
Alliance is a U.S. industry coalition that was organized in 1980 to address the issue of 
stratospheric ozone depletion and efforts at that time by the United States government to 
unilaterally further regulate the production and use of chlorofluorocarbons, or CFCs. 
Today, the Alliance coordinates industry participation in the development of reasonable 
international and U.S. government policies regarding ozone protection. 

We are particularly pleased to have the opportunity to address the topic before the 
committee today: "Stratospheric Ozone: Myths and Realities". Over the last two 
decades, it appears that the ozone protection issue has generated enough myths and 
discussion to fill several books. It has become difficult to separate these myths from 
reality. 

E>epending on the "politically correct" vantage point, the ozone depletion story is either 
about industry and technology bringing about global destruction in pursuit of fmancial 
gain; or in the alternative, environmentalism and social engineering out of control. From 
our perspective, the ozone depletion issue is about complex scientific information 
concerning the impacts of technology on the environment, and efforts to lessen these 
impacts in as cost-effective manner as possible. 

The realities are: 

--that the fundamental scientific basis for the CFC phaseout is credible, 
and has remained basically unchanged since the original policy decision to phase out 
production of the compounds; 



207 



"that the producer and user industries acted responsibly in nwving quickly 
to develop and implement safe and effective substitute technologies that allowed the 
phaseout to be accelerated; 

—that because of quick action by industry, further harsh measures 
regarding other compounds such as HCFCs are unnecessary; 

-that much work remains to done in order to ensure full compliance with 
the Protocol at the international level, including completion of the phaseout in developing 
countries and better enforcement of trade in illegally imported material; and 

-that much can be done to reduce costs and regulatory burdens imposed as 
a result of Congressional mandated excise taxes and certain provisions of the Clean Air 
Act 

A brief review of ozone protection history would be helpful at this point. 

When the Alliance was organized in 1980, the ozone depletion theory was six years old. 
However, a panel of industry scientific experts, the Fluorocarbon Program Panel of the 
Chemical Manufacturers Association, had been meeting since 1972 to consider the 
question of what happens to CFCs in the atmosphere. 

CFCs and CFC-reliant technologies developed over the last several decades contributed 
substantially to the quality of life for our society. In 1980 we believed that rigorous 
scientific analysis would eventually disprove what was then considered to be an unproved 
scientific theory. 

When it was organized, the Alliance's goals were to ensure that any regulatory decisions 
be based on the best scientific information available; that any proposals for action be 
pursued at the international level, particularly in light of the global nature of the issue and 
the tremendous competitiveness concerns for the industries that could be affected; and 
that any proposals not single out specific industries for regulatory scrutiny (as had been 
done in the late 1970's with the U.S. aerosol ban.) We have achieved these goals because 
sound science has resulted in internationally agreed upon controls which are responsible 
and cognizant of societal needs in specific sectors. 



208 



In 1986, the comprehensive assessment of ozone science was released by NASA and the 
World Meteorological Organization (WMO). It was on the basis of the information 
contained in that assessment, information that industry experts had assisted in developing, 
that industry representatives came to the conclusion that the potential existed for serious 
and unacceptable future environmental risks, if CFC growth continued well into the next 
century. It was an appropriate and responsible result. 

On September 16, 1986, the Alliance publicly released a statement which acknowledged 
this information, and issued the first call by industry for the negotiation of an agreement 
at the international level to limit the production of these compounds. (Attachment 1). 
The Montreal Protocol was completed and signed exactly one year later. The original 
treaty then called for only a 50% reduction in the production of CFCs and a freeze in 
halons by 1998. 

The treaty was the first signal to the marketplace to accelerate development of CFC 
substitutes. The view at the time by many in industry was that CFCs could still be used, 
but that stopping growth in their use would be difficult. The "race was on", however, to 
develop and implement safe and effective alternatives if companies were going to 
compete with technologies that were to be economically viable. 

The scientific developments after completion of the Protocol focused both on the 1986 
discovery of the Antarctic ozone hole and continued refinements of the atmospheric 
models based on better observational data from the atmosphere and the laboratory. 
Again, industry scientists were familiar with this work and integral to its completion. 
Scientific consensus developed around several key elements; 

—atmospheric chlorine concentrations appeared consistent with emissions of CFC 
compounds since their production began in the 1930's; 

--the Antarctic ozone hole appeared to develop when stratospheric chlorine 
concentrations reached 2 parts per billion; 

—the ozone hole appeared to result from a complex series of chemical reactions 
and the unique Antarctic meteorology which triggered the availability of free chlorine 
radicals in the atmosphere when the first sunlight of springtime appeared. The primary 
source of the chlorine came from chlorine- and bromine-containing compounds; and 



209 



-continued use and emissions of chlorinated and brominated compounds, 
including CFCs were projected to result in a substantial increase in atmospheric chlorine 
and bromine over the next several decades, even with the Montreal Protocol reductions. 

The NASA/WMO Ozone Trends Panel Executive Summary of March 15, 1988 led 
policymakers to conclude that production of CFC compounds needed to be eliminated 
altogether. The scientific information led to the 1990 amendments to the Protocol to 
phase out these compounds by the year 2000. Efforts to identify CFC substitutes were 
accelerated even further. 

E)omestic events had also focused additional attention on the issue, with the adoption by 
Congress over industry objection, of the excise tax on ozone depleting compounds in 
1989; and with the completion of the 1990 Clean Air Act Amendments. The tax, which 
rose from $1.25 per pound of CFCs to $5.35 this year is a severe penalty on consumers. 
The message to the industry was clear - these compounds were going to be taxed, reduced 
and ultimately phased out. It was clearly in industry's interest to do everything possible 
to introduce substitute technologies as rapidly as possible. The industry's goal was to 
manage the transition away from ozone depleting chemicals, while preserving the 
benefits their technologies provided along with the desirable health and safety 
characteristics that these technologies provide. 

A multi-billion dollar investment in new technologies was needed to shift manufacturing 
techniques and introduce new products relying on new compounds such as 
hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), and other chemical or 
not-in-kind technologies. 

At the same time, the Alliance continued to call to policymakers' attention the problem of 
dealing with the existing base of CFC-reiiant installed equipment, particularly air 
conditioning and refrigeration equipment, which has been estimated to be worth more 
than $135 billion. This issue was paramount when the Alliance was founded in 1980, as 
well as in 1986 when we called for international action. Our grounds for opposition to 
the excise tax was that it is unfair to tax consumers who had no other recourse but to pay 
the tax in order to have their motor vehicles and equipment serviced. It was primary in 
our request during the Clean Air Act Amendment debate for an exemption from the 
production phaseout for the service of this equipment. 



210 



In 1991-92, in the face of the continuing drumbeat of additional scientific reports of the 
worsening atmospheric conditions, policymakers were moving once again to accelerate 
the reduction schedule. Technology assessments completed internationally and here in 
the United States concluded that technologies would soon be available to eliminate the 
need for CFC compounds in most manufacturing applications. 

The transition fix)m CFCs was slowed due to the uncertainty over policies which might 
have been adopted concerning the HCFC substitutes. The HCFCs were deemed essential 
by the Protocol experts in order to achieve a CFC phaseout. Some European countries 
had already proposed eliminating HCFCs by the year 2000. The transition was also 
slowed by delays in implementing certain provisions of Title VI of the Qean Air Act 
Amendments, particularly Section 612 dealing with the approval of "safe alternatives" 
(known as the SNAP Program). Also of great concern was the implementation of other 
Title VI provisions, particularly labeling, which had the potential to impose substantial 
costs on products that ultimately would have been borne by consumers, and the continued 
problem that no policymaker seemed willing to address: the problem of the existing 
equipment base. 

The existing equipment issue was particularly vexing because neither the Clean Air Act 
Amendments nor the Montreal Protocol contained any provision or procedure for 
assuring the continued viability of this equipment. To our knowledge, no environmental 
program has ever before or since required the kind of massive scale retrofit of millions of 
commercial and consumer products. Industry needed a strategy to deal with this concern. 

As a result, the Alliance filed a petition with the Environmental Protection Agency (EPA) 
on February 11, 1992 to accelerate the phaseout of CTFCs consistent with anticipated 
^availability of technology implementing CFC substitutes. (Alliance press releases and a 
summaiy of the petition are enclosed as Attachment 2). In retiun, the Alliance requested 
the government to provide a reasonable period of assured usage for the HCFC 
technologies; defer the majority of the labeling requirements; provide a policy framework 
for assuring production of CFCs for the existing equipment base; and accelerate the 
determinations of safe alternatives under section 612 of the Clean Air Act Amendments. 

As a result of this petition and other efforts, the CFC phaseout was accelerated to January 
1, 1996 as part of the 1992 Copenhagen amendments to the Montreal Protocol. More 
importantly, the industry received approvals of its alternatives under the SNAP program; 
the domestic labeling provisions were essentially delayed; the parties to the Protocol 

5 



211 



adopted a schedule allowing use of the HCFCs until 2030; and the Protocol was amended 
to put in place a process for seeking an essential use exeinption for continued CFC 
production. 

An important lesson was learned during this period and the HCFC use strategy that was 
adopted actually incorporates a "service tail" as part of the production schedule so that the 
existing equipment problem being experienced on CFCs would be much reduced with 
respect to HCFCs. 

The United States is currently in its last year of CFC production for domestic use under 
the Protocol and Clean Air Act requirements. Use of these compounds during the last 
five years has consistently been less than that allowed by the treaty. The reductions are 
due to several factors, including: 

—more rapid replacement of CFCs with substitute compounds or not-in- 
kind technologies than was previously anticipated; 

—greater efforts to reduce servicing losses as a result of the high cost of the 
CFC refrigerant and the implementation of now mandatory rules prohibiting the venting 
of refrigerants; 

—more careful management of the use of the compounds in all sectors, 
including electronic solvent cleaning, medical uses, high efficiency insulating foams, etc.; 
and 

—a black market for CFCs. 

Despite these lower than projected use levels, concern remained high for the existing 
equipment base. As a result, manufacturers, distributors, wholesalers, building owners, 
and refrigeration service networks, have adopted their own strategies for assuring the 
needed supply of the compounds in the post- 1995 CFC-phaseout period. These strategies 
have required the investment of millions of dollars in CFC banks, assistance programs for 
customers concerning retrofit decisions, as well as efforts with large customers to bank 
their own multi-year supply of refrigerants for this equipment. 

There is no easy or uniform solution to this issue. The charges made by some, however, 
that the "impact on consumers was scarcely considered," is not accurate. The fact is that 



212 



industry actions have been guided by unprecedented concern by the affected industries 
for the costs on their customers, and on the health, safety and welfare of the users of the 
existing and substitute technologies. It is possible that problems in performance or other 
parameters will arise with the substitutes. That is the inevitable risk of an accelerated 
phaseout. Industry has done its best to avoid such problems. 

Management of the ozone depletion issue continues to be an unprecedented effort on the 
part of industry, government, and yes, responsible environmental group representatives to 
address a unique global concern. We have expended more than $6 billion to implement 
these new technologies on a world wide basis. 

As we stated at the outset, the myths of ozone depletion do not stand up to credible 
scrutiny. The reality is that the Montreal Protocol process has worked much better than 
anyone has anticipated. The focus is not on whether the science justified the actions that 
were taken. There was enough scientific consensus on which to make credible policy 
decisions. Industry has participated in that process and, to the best of our ability, 
provided guidance on the means to accomplish the environmental protection agenda in as 
cost-effective a manner as possible. 

The Alliance believes that the proper Congressional focus should be the streamlining of 
policies in effect in this country and at the international bargaining table. This should be 
done in order to ensure the successful completion of the transition out of ozone-depleting 
CFCs, while maintaining our economic competitiveness. We have several suggestions. 

At the international level, the United States should take a strong position that there is no 
need to alter the Protocol's control schedule on HCFCs. The Protocol's technology and 
assessment panel experts have agreed that HCFCs remain critical to the elimination of 
CFCs, and further tightening of controls on these compounds provide little or no benefit, 
particularly if such actions were to encourage continued developing country usage of 
CFCs. Concern for growth and continued production of CFCs in developing countries 
should be a priority since such activity could severely slow recovery of the ozone layer. 

The Protocol parties must continue progress to have developing countries eliminate their 
reliance on CFCs. The treaty provides for a delayed phaseout of CFCs in these countries. 
Many major developing countries, including Brazil, China, Mexico, and Malaysia, have 
announced phaseouts well in advance of the treaty requirements. The U.S. should be 
fostering these actions by fulfilling its existing financial commitment to the Montreal 

7 



213 



Protocol Multilateral Fund, rather than eliminating funding as has been proposed in the 
current appropriations process. (According to one estimate, the government has collected 
more than $6 billion in ozone depletion excise taxes from U.S. consumers of CFCs. It is 
difficult to understand the justification for not funding the Protocol efforts since the 
American people are paying for it through this tax.) 

The more quickly developing countries phase out of CFCs, the more likely that U.S. 
technologies, with their accompanying jobs, could be adopted in order to accomplish this 
objective. 

Because of the quick action to address the issue internationally, the Parties to the Protocol 
should also be encouraged not to revisit the treaty every two years in anticipation of 
major amendments. The basic framework is working well and should now be revisited 
only upon significant new scientific information. 

At home, several steps could be taken in order to streamline regulatory provisions. The 
Congress could eliminate several provisions of Title VI of the Clean Air Act 
Amendments that have the potential to impose great costs, or subject specific industries, 
small businesses, and consumers to potential liability for no significant environmental 
gain. The labeling provisions, particularly with regard to HCFCs should be deleted 
altogether, the SNAP program should be sunset once there is no nexus to substitution of 
ozone depleting compounds (the Alliance has filed a legal challenge to the SNAP 
program in order to prevent unnecessary overreaching on the part of EPA); and 
provisions eliminating the use of substitutes in so-called "non-essential products" could 
be deleted. Decisions by government are not as efficient as the marketplace. 

Continued increases in the ozone depletion excise tax should be ended. In fact, if the 
Congress is truly concerned about the costs to the consumer of the ozone protection 
program it could adopt a tax credit for equipment retrofits. The Alliance believes that 
such a program would be revenue neutral in the near-term. 

Finally, the government must continue to enforce the laws concaming the illegal import 
of CFCs. Illegal imports and the avoidance of excise tax on these compounds make 
CFCs more available, reduce the incentive for users to shift to alternatives, and penalize 
legitimate companies who are complying with U.S. laws. The illegal imports create the 
impression in the marketplace that CFCs are plentiful, and that retrofits can be deferred. 



8 



214 



The illegal imports are frustrating the attempts of legitimate businesses to plan for the 
post-production period through stockpiling. 

Just because the Montreal Protocol has worked well does not mean, as some would have 
it, that all future global environmental initiatives would be patterned after the Protocol's 
ban on specific chemicals, or that it means the creation of some supranational regulatory 
body. The Protocol was designed to address a unique set of scientific, economic, and 
environmental circumstances that was not well understood by the public, the media, or for 
that matter, many policymakers. It is difficult to envision a similar set of circumstances 
on other more typical environmental issues. It is encouraging to note that when the 
circumstances warranted such action, that governments and industries alike were able to 
put aside more parochial concerns and act in the interest of the general public good. 

Because of industry's active role in understanding the science, and assessing the economic 
and policy issues, we believe that the process has gone better than it could have. The 
costs involved are real. While the benefits are still being assessed, we stand by our record 
of rapid response and participation in this process. We encourage the Congress to further 
enhance this process by using hearings such as these to better understand the issues, and 
to streamline the regulatory procedures and the burdens they entail, but to also remain 
tnindful of the historical perspective involved with the establishment of the original 
policy objectives within which we have had to operate. 



215 



ATTAOHMBMT I 



STATEMENT 

OF 

RICHARD BARNETT 

CHAIRMAN 

ALLIANCE FOR RESPONSIBLE CFC POLICY 

September 16, 1986 

National Press Club 

Washington. D.C 

Good Morning Ladies and Gentlemea* 

I have a brief statement that I will read after which I will be happy to answer your questions. 
The Alliance for Responsible CFC Policy was organized six years ago to represent the interests of users and pro- 
ducers of chlorofluorcartwns (CFCs). This was in response to what we considered to be an unwarranted proposal by 
the U.S. Environmental Protection Agency ( EPA) to cap and eventually reduce production of this unique family of 
chemicals which have contributed so significantly to the quality of life of all Americans and to people around the 
world. The proposed EPA action was based on the theory that CFCs are emitted into the atmosphere uid, because 
of their unique stability, eventually reach the earth's protective ozone layer, where they may deplete the ozone 
through a complex series of reactions. 

In the belief that government ought not regulate based on an improven or unverified theory. Alliance members 
established some basic goals with regard to the ozone depletion theory, CFC usage, and potential government 
policies. 

First, it was our desire to encourage the pursuit of adequate credible scientific research on this important environ- 
mental issue, and then to ensure that any government policy be based on the best and most current scientific 
information: 

Second, it was our goal to encourage efforts to resolve this issue in the international arena because of its global 
scope and to prevent any unproductive, harmful, unwarranted unilateral domestic regulatory program that would 
injure U.S. industry to the benefit of our international competition; 

Third, it was our goal to amend the Clean Air Act to provide greater international emphasis on this issue and to 
give better guidance to the EPA Administrator regarding stratospheric ozone protection activities and the need 
for regulation. 

In the six years that have gone by, we feel that much has been accomplished to obtain our goals, but we believe 
that much remains to be done. 

We have seen wide swings of Tindings from conflicting scientific reports regarding CFCs and ozone depletioa 
With as much as we have learned from the intensive scientific scrutiny, we have also learned that there is a lot we still 
do not know. We beUrve the scientific research must continue. 

In the intervening years, the Alliance has informed our political leaders, administrative oGFicials, and the publio- 
at-large, as to the many benefits that CFCs offer to our society, in comfort control, food preservation and prepara- 
tion, energy efficiency, cleaning and sterilization processes, and many other uses, as well as the tremendous 
contribution to worker and consumer health and safety. 

Additionally, we have been an active participant in efforts to promote greater international cooperation, as exem- 
plified by our support for the Vienna Convention for Protection of the Ozone Layer, and our participation in domes- 
tic and international efforts to address ozone protection issues such as the recently concluded series of workshops 
sponsored by EPA and the United Nations Environment Programme. 

As you can imagine, the Alliance's activities as a coaUtion require the active physical as well as financial par- 
ticipation of our member companies. We have worked to live up to our name and be an Alliance for Responsible 
CFC Policy. To do so requires a constant evaluation of the complex scientific economic and environmental policy 
issues confronting us and maintaining and, if necessary, adjusting our position in accordance with the most current 
information available to us. 

In 1 980, the Alliance urged that at least 3 to S years was necessary to allow the scientific research to continue and 
to gather critical monitoring information regarding the projections being made by computer models. Therefore, the 
1 986 release oftheNASA/WMO science assessment on stratospheric ozone was an important event with regard to 
our own continuing evaluadon process. 

In general, I want to stress that the Alliance does not believe that the scientific information demonstrates any 
aetoal risk from current CFC use or emissions. We recognize, however, the growing concern for potential ozone 
depletion and climate change as a resuh of large future growth of CFC emissions and the buildup of many other trace 
gases in the atmosphere, and the concern with the discovery of imexplained phenomena such as the large reductions 
in ozone levels during the Antarctic spring. 

M 



216 



The science is not sufficiently developed to tell us that there is no risk in the future. In fact, all of the computer 
models calculate that large future growth in CFC emissions may contribute to significant ozone depletion in the lat- 
ter half of the next century. 

We support fiuiher scientific research and believe that regulatory policies should be periodically reexamined in 
the light of additional research fmdings. 

On the basis of current information, we believe that large future increases in fully halogenated CFCs (the most 
durable ones, thought to contribute most to ozone depletion) would be unacceptable to future generations and, in our 
view, it would be inconsistent with the goals of this Alliance to ignore the potential for risk to those future 
generations. 

The Alliance, therefore, believes that a responsible policy is necessary that meets four criteria. The policy 
must 

—provide some assurance that we never reach the "doomsday" scenarios that have been put forth; 

—foster the spirit of international cooperation needed to reach scientific consensus on this issue and the need for 
an appropriate global response; 

-fulfill our responsibilities as businessmen and women to our shareholders, employees, and customen; 
and 

—recognize the substantial contributions that CFCs make to the quality of our lives, and to the health, safety, 
and economic benefit of workers and consumers alike. 

I am pleased to announce to you today, that the Alliance Board of Directors approved the following policy state- 
ment on September 4th. We believe this policy statement meets the criteria I have just stated 

Further, we believe that this policy is a significant step in the direction of developing a positive approach to the 
issue of global ozone protection and the responsible use of CFCs. We recognize that the process of developing these 
prudent precautionary measures and establishing specifics will not be easy. As a coalition of many companies and 
industries, we may expect more specific policy suggestions from our members. We look forward to contributing to 
the development of the broader consensus on this issue, and hope that others will join us in a spirit of international 
cooperation as we pursue the difficult tasks necessary to achieve a global policy consensus in the months and 
years ahead. 
Thank you. 



1-2 



217 



ATTACHMBHT 2 



ALLIANCE FOR RESPONSIBLE CFC POLICY 

1901 NORTH FORT MYER DRIVE. SUITE 1200 

ARLINGTON. VIRGINIA 22209 

(703) 243-0344 



FAX (703) 243-2874 

For Immediate Release For Information Contact: 

Kevin Fay 703-243.0344 

ALLIANCE PETITION SEEKS MORE THAN 50% REDUCTION IN 
OZONE DEPLETION COMPOUND ALLOWANCES 

Washington D.C., February 11, 1992 - The Alliance for Responsible CFC Policy, 
an industry coalition composed of CFC and HCFC producers and users, today petitioned 
U.S. Environmental Protection Agency (EPA) Administrator William Reilly to accelerate 
the phaseout schedule for CFCs and certain atmospheric long-lived HCFCs. 

Alliance Executive Director Kevin Fay stated, 'The accelerated schedule we have requested 
EPA to implement domestically and internationally for phasing out these ozone-depleting 
compounds is more than a 50% reduction from that which is currently allowed by the 
Montreal Protocol. It is consistent with technological and economic feasibility, the health 
and safety concerns of workers and consumers, and environmental protection needs. It 
represents a difficult but realistic schedule for the phaseout of these compounds. " 

The Alliance petition was filed in acknowledgment of substantial technological advances as 
well as in response to announcements over the last year concerning additional 
measurements of potential ozone depletion around the globe. The significant proposed 
reduction schedule is possible, according to the Alliance, because of progress made by 
industry in developing ozone protective CFC replacement technologies. These 
technologies are identified in the December 1991 United Nations Environment Programme 
(UNEP) Technology and Economic Assessment Report 

The Alliance petition requests that the ban on the production and use of CFCs for new 
equipment take place on January 1, 1996. Presently, both the Montreal Protocol and the 
Clean Air Act require that production of CFCs be ended by January 1, 2000, although it is 
likely that the Protocol will be revised later this year. 

The Alliance also believes that the present CFC phasedown schedule can be accelerated at a 
rate which is achievable in light of industry's technological capabilities. Therefore, the 
following production schedule has been requested in tcxlay's petition: 

Percentage Production of 198 6 Baseline Levels 



Year 


Montreal Proiwol 


Clciwi Air Act 


Alliance Petition 


1993 


too 


75 


50 


1994 


100 


65 


40 


1995 


50 


50 


25 


1996 


50 


40 


0* 


1997-1999 


15 


15 


0* 


2000 








0* 



*exemptionfor service of equipment, to he determined in future technical assessments. 



218 



"While industry has made substantial progress in reducing CFC production and usage, 
encouraging recovery and recycling of the compounds, and making a safe transition to 
alternative compounds significant hiffdles still remain. The petition takes into consideration 
the time it will take for EPA to determine whether the alternatives are acceptable for a period 
of time to justify their production. It also represents a very demanding schedule upon 
which industry can complete its implementation of the alternatives in the products and 
processes that use them," Fay said. 

The petition also recognizes the needs of consumers and businesses who own over $135 
billion of existing equipment such as automobile air conditioners, refrigerators, and large 
air conditioning systems which operate on CFCs. While some have advocated that the total 
CFC production phascout occur between 1995 and 1997, the Alliance requests that from 
January 1, 1996 until January 1, 2000, a limited amount of production be allowed annually 
to service and maintain existing refrigeration and air conditioning equipment This amount 
is to be determined by future technology assessments on the availability of cost-effective 
retrofit technology and the success of CFC recycling and reclamation efforts. 

Any anempt to eliminate CFC production without consideration of the existing equipment 
would create a potential shortfall of necessary refrigerant to service this equipment Such a 
shortfall would result in the early obsolescence of this equipment, and reduced operating 
efficiencies which could cause increased energy consumption by this equipment. While 
CFC recovery and recycling will make up for some of the shortfall, no study has indicated 
that a shonage can be eliminated through even the most aggressive recycling and 
conservation efforts. 

The petition also requests acceleration of the phaseout schedule for HCFC-22, HCFC- 
141b, and HCFC-142b beyond the current Clean Air Act requirements. Under the Alliance 
petition, production of these compounds for use in new products or equipment would be 
ended by January 1, 2010. Total production of these HCFCs would be ended by January 
1. 2020. 

The Alliance For Responsible CFC Policy, organized in 1980, is a coalition of U.S. 
companies that produce CFCs, HCFCs, and HFCs, as well as products and processes that 
rely on these compounds. CFCs and HCFCs are used extensively as refrigerants in air 
conditioning and refrigeration equipment, including motor vehicles; as solvents in the 
electronics industry; as blowing agents for the manufacture of high efficiency foam 
insulation and foam packaging; and as sterilants and medical aerosols in the health industry. 

-30- 



219 



Table 1 

ACTIOMS REQUESTED BY ALLIANCE PETITION 

Accslerated Phaseout of CFCs: 

Allowable Annual Production 
Year of 1986 Quantities 

1993 50% 

1994 40% 

1995 25% 

1996 0% for new equipment 
1996-1999 Allocation for service of 

equipment manufactured 
before Jan. 1, 1996 
(amount to be determined) 
2000 0% 

No production of CFCs after January 1, 1996 for use in 
equipment manufactured after that date. 

A production allowance from 1996-1999 (amount to be 
determined based on 1986 levels) for service of 
refrigeration and air-conditioning equipment 
manufactured before Jan. 1, 1996. 

Accelerated phaseout of HCFC-22, HCFC-141b and HCFC- 
142b: 

After Jan. l, 2010 No such HCFCs allowed to 

be produced for use, or 
used, in new products and 
equipment. 

After Jan. 1, 2020 No production allowed. 

Limited one-year waiver from accelerated CFC phaseout 
for applications where no substitutes are viable 

Minimum period of 15 years for safe alternatives 

Deferral of labeling except for containers or products 
containing CFCs until Jan. l, 1995 

Exemptions for products demonstrated as essential under 
Section 610(d) (2) 

Coordination of U.S. actions with Montreal Protocol 
negotiations 



220 



ALLIANCE FOR RESPONSIBLE CFC POLICY 

1901 NORTH FORT MYER DRIVE. SUITE 1200 

ARLINGTON. VIRGINIA 22209 

(703) 243-0344 



FAX (703) 243-2874 

For Immediate Release For Information Contao: 

Kevin Fay 703-243-0344 

ALLIANCE PLEDGES SUPPORT FOR PRESIDENT'S PROGRAM ON 
OZONE LAYER, PETITIONS EPA FOR PROMPT ACTION 

WASHINGTON, D.C., February 11, 1992 - The Alliance for Responsible CFC 
Policy, an industry coalition composed of CFC and HCFC users and producers, endorsed 
the call today by President Bush to accelerate the domestic and international efforts to 
protect the eanh's ozone layer, and filed a petition with EPA requesting acceleration of the 
phaseout schedule for cenain ozone depleting compounds. "The United States, both 
government and industry, will maintain its leadership position in the global ozone 
protection effort," said Kevin Fay, the Alliance Executive Director. "The President's action 
today is responsive to the environmental concerns announced last week by NASA, and 
consistent with the technological advances achieved by industry in developing substitute 
chemicals and technologies. ' 

The CFC Alliance has urged that the critical steps necessary to accelerate the 
phaseout of CFC compounds are: 

-the rapid approval by EPA of industry developed substitutes as required 
by the Clean Air act; 

"development of an action plan to deal with the huge base of existing 
installed equipment, primarily refrigeration and air condinoning equipment; 

"invigorated diplomatic efforts to ensure the participation of all nations, 
particularly the developing nations, in the Montreal Protocol process; and 

-swift action by the Federal government to implement procurement policies 
for ozone protecting technologies, as well as recycling, reclamation, and 
retrofit programs for government owned existing equipment. 

"The President's proposal addresses several of these key elements. U.S. industry 
will actively assist the Bush Administration in the prompt implementation of these steps," 
said Fay. "The Montreal Protocol has achieved an unprecedented level of cooperation in 
addressing this serious global environmental concem. Without the technical, financial, and 
political support of the U.S. government, as well as industry, the world would be unable to 
deal with this environmental crisis. U.S. industry pledged its support in 1986 to address 
this issue in a responsible manner. Our support for the President's action today is 
consistent with that commitment." 

"The use of market mechanisms to implement the Montreal Protocol have been 
largely responsible for the industry's ability to reduce its reliance on CFCs well-ahead of 
current regulatory mandates, " said Fay. According to EPA figures, the U.S. has already 
reduced its reliance on CFCs 40% greater than that required by the Protocol. 



221 



In response to the President's call to U.S. CFC producers to immediately reduce 
CFC production to 50% of 1986 baseline levels. Fay indicated that he believed that the 
U.S. producers, Allied-Signal, DuPont, Elf Atochem. and LaRoche, would respond 
affirmatively. 

At the same time, the Alliance pointed out that the President's plan achieves the 
environmental objective while recognizing the needs of American consumers and small 
business. In 1996, the United States will have 130 million automobiles, 160 million 
refrigerators and freezers, 5 million commercial refrigeration and air conditioning systems, 
and 80,000 large building chillers that run on CFCs. This equipment, valued at more than 
$135 billion, will require a mix of recycled CFCs, a limited amount of new CFC 
production, and the application of cost-effective retrofit technologies in order to avoid huge 
capital obsolescence costs to the economy. 

The Alliance reponed that it filed a petition with EPA today to accelerate the CFC 
reduction schedule, achieving a phaseout of production by December 31, 1995. The 
petition also seeks a limited exemption from the phaseout in order to service the existing 
equipment base. The exception would only be utilized if subsequent technical 
developments do not produce cost-effective solutions for retrofitting this equipment and 
reclaimed and recycled refrigerant is unable to provide for its needs. The petition is 
consistent with the President's action. 

The petition also seeks an accelerated phaseout of the atmospheric long-lived 
HCFCs, bridging compounds needed in order to complete the CFC phaseout. The Alliance 
requests that long-lived HCFC production be phased-out in 2020. The petition also 
addresses other issues penaining to the implementation of Title VI of the Clean Air Act 
Amendments of 1990, including labeling deferrals, and identification of safe alternatives. 

The Alliance For Responsible CFC Policy, organized in 1980, is a coalition of 
U.S. companies that produce CFCs, HCFCs, and HFCs, as well as products and 
processes that rely on these compounds. CFCs and HCFCs are used extensively as 
refrigerants in air conditioning and refrigeration equipment, including motor vehicles; as 
solvents in the electronics industry; as blowing agents for the manufacture of high 
efficiency foam insulation and foam packaging; and as sterilants and medical aerosols in the 
health industry. 

-30- 



222 



1994/1995 Membership List 
Alliance for Responsible Atmospheric Policy 



3M Comoany 

A. Cook Associates. Inc. 

Abbott Laboratones 

Abco Refrigeration Supply Corp. 

Acme • Miami 

American Electronics Association (AEA) 

Air Comfort Corporation 

Air Conditioning Contractors of America 

Air Conditioning & Refrigeration Institute 

Air Conditioning Suppliers. Inc. 

Air Products 

Alliance Pharmaceutical Corporation 

AlliedSignal 

American Auto. Manufacturers Assoc. 

American Frozen Food Institute 

American Pacific Corporation 

American Refrigerant Reclaim Corporation 

American Thermaflo Corp. 

American Trucking Associations 

Amtrol. Inc. 

Anderson Bros. Refrigeration Service. Inc. 

Apex Ventilations 

ARCA/MCA 

Arizona Public Service Co. 

Arjay Equipment Corporation 

Arrow Air Conditioning Service Company 

Arthur D. Little. Inc. 

Ashland Inc. 

Astro-Valcour Inc 

Association of Home Appliance Manufacturers 

AT&T 

Ausimont USA 

Automotive Consulting Group. Inc 

Bard Manufacturing Co. 

Beltway Heating & Air Conditioning Co. Inc. 

Beverage-Air 

Big Bear Stores Co. 

Blue M Electric 

Building Owners and Managers Association (BOMA) 

Booth Refrigeration Services Conditioning 

Bristol Compressors 

c/o Moog Training Center 

Camer Corporation 



223 



Celotex 

Center for Appiiea Engineering 

Central Coating Company, Inc. 

Cetylite Industnes. Inc. 

Chemical PacKaging Corp. 

Chemtronics. inc. 

Clayton Auto Air. Inc. 

Commercial Refrigerator Manufacturers Association 

Copeland Corporation 

Day Supply Company 

Oow Chemical U.S.A. 

E.l. Dupont De Nemours and Company 

E.V. Dunbar CO. 

Eastman Kodak 

Ebco Manufacturing 

Electrolux/White Consolidated 

Elf Atochem Nonh America. Inc. 

Elliott-Williams Company. Inc. 

Engineering & Refrigeration. Inc. 

Falcon Safety Products. Inc. 

FES Inc. 

Flex-0-Lators. Inc. 

Foam Enterprises. Inc. 

Foamseal, Inc. 

Food Marketing Institute 

Foodservice & Packaging Institute 

Ford Motor Company 

Forma Scientific 

Fox Appliance Parts of Augusta 

Franke Filling, Inc. 

Fras-Air Contracting 

Free-Flow Packaging Corp. 

Freightliner Corporation 

Gardner. Carton & Douglas 

Gebauer Company 

General Electric Company 

General Motors 

Graineer 

Gulfcoast Auto Air 

H. C. Duke & Son. INc. 

Hale and Dorr 

Halocarbon Products Corporation 

Halsey Supply Co.. Inc. 

Harold Electnc Co. 

Henry Valve Company 

Highside Chemicals 

Hill Refrigeration Corp. 

Howard/McCray Refrigerator Co.. Inc. 



224 



Hugnes Aircraft Company 

Hussmann Corooration 

ICl Americas Inc. 

IG-LO. Inc. 

Illinois Supply Company 

IMI Cornelius Company 

Institute of Heating & Air Conaitioning Industries 

Institute of International Container Lessors 

Integrated Device Tecnnology inc. 

International Assoc, of Refrigerated Warehouses 

International Cold Storage Co.. Inc. 

International Mobile Air Conditioning Assoc. 

International Pharmaceutical Aerosol Coalition 

Interstate Truckload Carriers Conference 

Johnson Controls 

Joseph Simons Co. 

Keyes Refngeration. Inc. 

King-Weyier Equipment Co.. Inc. 

Kline & Company Inc. 

Kraft General Foods 

KYSOR WARREN 

LaRoche Chemicals 

Lennox Industries 

Liggett Group Inc. 

Lintem Corporation 

Lohllard 

Lowe Temperature Solutions 

Luce. Schwab & Kase. Inc. 

Malone and Hyde Inc. 

Manitowoc Equipment Works 

Marine Air Systems 

MARVCO Inc. 

Maytag Corporation 

McGee Industries. Inc. 

Mechanical Service Contractors of America 

Merck & Co.. Inc. 

Meti-Span Corporation 

Miles Inc. 

Mobile Air Conditioning Society 

Monsen Engineering Co. 

Montgomery County Public Schools 

Moog Automotive Inc. 
Moran, Inc. 



225 



Nat. Assoc. Of Plumoing-Heating-Cooiing Contractors 

National Assn. of Food Eouipment Manufacturers 

National;Automobile Dealers Association 

National Refrigerants, Inc. 

National Training Centers. Inc. 

NO Slate Board of Refrigeration 

Neaton Auto Products Mfg., iNc. 

New Mexico Engineenng Res. Instit.-U of NM 

North Colorado Medical Center 

Northern Illinois Gas 

Northern Research & Engineenng Corporation 

Northland Corporation 

Norton Company-Sealants Division 

O'Brien Associates 

Omar A. Muhtadi, Inc. 

Omega Refngerant Reclamation 

Orb Industries. Inc. 

Patterson Frozen Foods. Inc. 

Peirce-Phelps. Inc. 

Pennzoil Company 

Perlick Corporation 

Polyisocyanurate Insulation Manufacturers Association (PIMA) 

Polycold Systems Intemational 

Premier Brands Ltd. 

Ralph Wright Refrigeration 

Rawn Company, Inc. 

Reeves Refrigeration & Heating Supply, inc. 

Refrigeration Engineenng. Inc. 

Refrigerant Management Services 

Refrigeration Service Engineers Society 

Refron 

Revco Scientific 

Rhode Island Refrigeration Supply Comp, Inc. 

Ritchie Engineering Co.. Inc. 

Rite Off 

RJR Nabisco 

Robinair Division. SPX Corp 

RSI Co. 

Rule Industries. Inc. 

SCM Glidco Organics 

Scott Polar Corporation 

Service Supply of Victoria. Inc. 

Servidyne Inc. 

Sexton Can Company 

Sheeting, Metal. Air-Conditioning Contractors National Association (SMACNA) 

South Central Co.. Inc. 



226 

Mr. ROHRABACHER. Thank you, Mr. Fay. We have about 8 min- 
utes left before this vote — 7 minutes. Which means that I'll have 
to run over and vote. 

I'll be very interested in hearing your analysis of how the Senate 
was able to vote 96 to zero and it had nothing to do with President 
Gore's presentation to the Senate and to this House committee sev- 
eral years ago. 

Mr. Fay. I'll be happy to discuss it. 

Mr. ROHRABACHER. So we'll be looking forward to that and we're 
in recess, then, for, say, 15 minutes. 

[Recess.] 

Mr. ROHRABACHER. Someone was just telling me about the ozone- 
eating radiator that he had seen and all these exciting things. 

Now, Mr. Lieberman, you're the next witness. You seem to have 
been the focus of several comments during the prior testimony. So 
I'm looking forward to hearing your testimony. 

Mr. Lieberman. I have a lot of friends. [Laughter.] 

Mr. ROHRABACHER. GrO right ahead, Mr. Lieberman. 

STATEMENT OF BEN LIEBERMAN, ENVIRONMENTAL RE- 
SEARCH ASSOCIATE, COMPETITIVENESS ENTERPRISE INSTI- 
TUTE, WASHINGTON, DC 

Mr. Lieberman. Mr. Chairman, I'd like to thank you and the 
other Members of the Subcommittee for the opportunity to speak 
to you about ozone deletion and the CFC phaseout. 

This is an issue that I have followed for two years as an environ- 
mental research associate with the Competitive Enterprise Insti- 
tute. 

My comments will focus on the consumer impact of the acceler- 
ated CFC phase-out. Unfortunately, this is a side of the issue that 
has been largely ignored. For many years, the proponents of the 
phase-out have dominated the debate with exaggerated claims of 
environmental gloom and doom. 

But now that the environmental threat is proving to have been 
overstated, more people are starting to ask questions about how 
much this will cost them. 

In addition, millions of Americans have gotten a wake-up call in 
the form of substantially higher air-conditioner repair bills, a trend 
that will greatly increase in the years to come. 

The air conditioning and refrigeration industry has become an 
ally of the EPA in supporting the CFC phase-out. For the most 
part, the refrigerant and equipment makers have already stopped 
producing CFCs £ind CFC-using equipment and have switched to 
production of substitutes. 

At this point, they want CFCs out of the picture as soon as pos- 
sible so they can start selling the substitute systems. 

This is one environmentaJ issue where big government and big 
industry are now on the same side. Both are lined up against the 
consumer. 

I would like to present some basic facts about what is occurring 
and will continue to occur to air conditioning and refrigeration 
costs. 

The most costly category is motor vehicle air conditioners. There 
are approximately 140 million car and truck air conditioners that 



227 

use CFC-12. I estimate that the cost of a car air conditioner repair 
has increased about $100, on average. 

Thus, the approximately 20 miUion that need repairs each year 
cost $2 bilHon more annual. The cost will be even higher in future 
years. 

Another category of affected equipment is the refrigeration sys- 
tems in approximately three-quarters of a million restaurants, food 
stores, and other small businesses. 

The added cost could reach several thousand dollars per facility, 
one more onerous regulatory burden on small businesses. 

Also affected are the chillers that air condition large office build- 
ings, and residential refrigerators. In all, the total cost could reach 
$100 billion, although there is some controversy over that, over the 
next decade, or about $1000 per household. 

I would also like to add that the cost burden of the CFC phase- 
out is being disproportionately shouldered by American consumers. 
There is a misconception that the costs of the CFC phase-out are 
equally shared among the peoples of the world. 

Although there is an international phase-out of CFCs, most of 
the costs are being incurred here in the U.S. For one thing, the 
U.S. has more affected equipment than any other nation and there 
are several costly provisions that only affect Americans. 

Also, developing nations such as China, India, and Mexico, have 
a ten-year delay in phasing out CFCs. 

Further, unlike the U.S., many other nations are not strongly en- 
forcing the phase-out. For example, the evidence, the anecdotal evi- 
dence I've hard is that black market CFCs are readily available 
throughout much of western Europe and at prices lower than in 
the U.S. 

Thus, the argument that this is a globally-shared burden is spu- 
rious and unilateral relief for American consumers would not be 
unfair. 

The costs have been exacerbated by the acceleration of the CFC 
phase-out from the January 1, 2000 deadline in the Clean Air Act, 
to the end of this year. 

This is true for several reasons. 

First, for the large volume of CFC equipment currently in exist- 
ence, the accelerated phase-out will interfere with its continued 
use. Many perfectly good systems will have to be prematurely re- 
placed or retrofitted when CFCs become scarce, probably in 1997, 
maybe 1998. 

On the other hand, a slower phase-out would have allowed most 
existing systems to live out their useful lives and then be replaced 
in due course by non-CFC systems. 

In addition, the abrupt phase-out of CFCs is resulting in the in- 
troduction of substitute refrigerants and equipment being rushed 
into service with minimal field testing and many technical bugs yet 
to be worked out. 

Consumers would be better off if they could continue using their 
CFC systems until the new systems have been improved upon. But 
the accelerated phase-out denies them this option. 

Further, many have raised environmental concerns about several 
leading CFC substitutes. For example, HCFCs, which are now used 
as replacements for CFCs in several applications, are themselves 



228 

being considered for an accelerated phase-out by the parties to the 
Montreal Protocol, based on the belief that they also contribute to 
ozone depletion. 

HFC-134a, the most common substitute, has been called a con- 
tributor to global warming. And recently, a scientific study reported 
that the breakdown products of several CFC-substitutes may dam- 
age wetlands. 

There are also safety and toxicity concerns that have not been 
adequately addressed. And whenever asked for firm assurances 
that these substitutes won't also be later restricted, EPA has al- 
ways balked. 

Thus, it may well be that after consumers are forced to endure 
the abrupt and costly phase-out of CFCs, they will be subject to a 
second phase-out for the CFC substitutes that were rushed into use 
and then later found to be environmentally unacceptable as well. 

These problems could be substantially reduced by allowing a few 
more years of limited CFC production. 

The Doolittle Bill would return the phase-out deadlines to those 
in the 1990 Clean Air Act, allowing limited CFC production until 
the year 2000. 

We have heard testimony from some scientists that this small 
amount of additional CFC production, really about one percent 
compared to what's already out there, will make very little dif- 
ference from an environmental standpoint. But it would be enough 
to save American consumers billions of dollars. It will enable those 
with CFC equipment to continue using their systems with CFCs for 
at least a few more years, by which time we will better know which 
substitute refrigerants are technically and environmentally accept- 
able. 

This will avoid the problem of expensive false starts. It will also 
spare equipment owners from having to rely on black market and 
recycled refrigerants which are lacking in quantity and quality, by 
providing a supply of new and pure refrigerants. 

Thank you. 

[The complete prepared statement of Mr. Lieberman follows:] 



229 



Testimony of Ben Lieberman 

Environmental Research Associate, Competitive Enterprise Institute 

before the 

Subcommittee on Energy and Environment of the Committee on Science 

U.S. House of Representatives 

September 20, 1995 

Mr. Chairman, I would like to thank you and the other 
members of the subcommittee for the opportunity to speak to you 
about ozone depletion and the CFC phaseout. This is an issue 
that I have followed for two years as an environmental research 
associate with the Competitive Enterprise Institute. 

My comments will focus on the consumer impact of the 
accelerated CFC phaseout. Unfortunately, this is a side of the 
issue that has been largely ignored. For many years, the 
proponents of the phaseout have dominated the debate with 
exaggerated claims of environmental gloom and doom. The widely 
publicized predictions of skin cancer and cataract epidemics, 
crop failures, destruction of the ocean food chain, animals going 
blind, and so forth, have tended to overshadow concerns about the 
costs of eliminating CFC production. But now that the 
environmental threat is proving to have been overstated, more 
people are starting to ask questions about how much this will 
cost them. In addition, millions of Americans have gotten a wake 
up call in the form of substantially higher air-conditioner 
repair bills, a trend that will greatly increase in the years to 



230 



come. For the first time, the cost side of the CFC phaseout is 
getting the attention it deserves. 

To the limited extent the EPA has addressed the costs, they 
have not been honest with the American people. Their extremely 
low cost estimates have no basis in reality, and cannot stand up 
to scrutiny. Also, the air-conditioning and refrigeration 
industry has become an ally of the EPA in supporting the 
accelerated CFC phaseout. For the most part, the refrigerant and 
equipment makers have already stopped producing CFCs and CFC- 
using equipment and have switched to production of substitutes. 
In effect, the impending phaseout has forced them to market 
products that cannot compete with the proven reliability of CFCs. 
At this point, they want CFCs out of the picture as soon as 
possible so they won't have to deal with the problem of 
convincing consumers to abandon existing CFC systems that are 
serving them so well for expensive substitutes that have no track 
record. A return to CFC production, even a temporary one, will 
cost the industry money, because it will enable millions of 
owners of existing CFC-equipment to continue using their systems 
for several more years. And every piece of CFC equipment that 
stays in use is one less piece of new equipment that gets sold. 
It is not surprising that industry groups oppose any additional 
CFC production and tend to downplay the problems for consumers 
caused by the accelerated CFC phaseout. This is one 
environmental issue where big government and big industry are now 
on the same side. Both are lined up against the consumer. 



231 



since both the EPA and industry have not been forthcoming 
regarding the real costs of the phaseout, I would like to present 
some basic facts about what is occurring and will continue to 
occur to air-conditioning and refrigeration costs. Although the 
bulk of the consumer impact will take place in the next few 
years, consumers have already been affected to the tune of 
several billion dollars, and a number of troubling problems have 
begun to emerge. I believe that the accelerated CFC phaseout may 
become the single most expensive environmental measure ever. 

There are several categories of air-conditioning and 
refrigeration equipment impacted by the phaseout. The most 
costly category is motor vehicle air-conditioners. There are 
approximately 140 million car and truck air-conditioners that use 
CFC-12. Most owners of pre-1994 cars or trucks are affected. 
Model year 1994 and newer vehicles use a substitute refrigerant, 
HFC-I34a. I estimate that the cost of a car air-conditioner 
repair has increased about $100 on average, thus the 
approximately 20 million that need repairs each year cost $2 
billion more annually. The cost will be even higher in future 
years, particularly if CFCs become prohibitely expensive or 
unavailable, which many predict to occur by 1997 or 1998. If 
this happens, owners will have to retrofit their vehicles to use 
a CFC-substitute. Retrofit costs vary from model to model, but a 
typical cost is $200 to $500. And there are serious questions as 
to how long a retrofit will last. 



232 



Another category of affected equipment is the refrigeration 
systems in approximately three quarters of a million restaurants, 
food stores, and other small businesses. The equipment used in 
these establishments already costs more to repair, due to higher 
refrigerant and labor costs. And if CFCs become scarce by 1997 
or 1998, much of it will have to be prematurely replaced or 
retrofit, which can cost thousands of dollars - one more onerous 
regulatory burden on small businesses. 

Another affected category of equipment is the chillers that 
air-condition large buildings. These systems are very expensive 
to purchase and install, and the phaseout will necessitate a 
number of premature replacements and costly retrofits of existing 
CFC systems over the next decade. 

Residential refrigerators are also affected. Because of 
their importance in our lives and widespread use, even a small 
increase in the costs of non-CFC refrigerators, or decline in 
their quality and reliability, can have a substantial effect. 

The phaseout will also affect states and municipalities, as 
well as the federal government. Millions of pieces of air- 
conditioning and refrigeration equipment are publicly owned. 
From the refrigeration systems in school cafeterias to public 
hospitals to air-conditioned federal buildings, governments are 
also going to pay more and taxpayers will foot the bill. 

In all, the total costs could reach $100 billion over the 
next decade, or about $1,000 per household. Beyond the dollar 
costs is the impact on human health. Air-conditioning, far from 



233 



being a luxury item, is a life saving technology, particularly 
during heat waves. Refrigeration is also important in providing 
a safe and inexpensive food supply and plays a vital role in 
medical care. Regulations that raise the cost and lower the 
availability and quality of air-conditioning and refrigeration 
could impact the health of our nation. 

I would also like to add that the cost burden of the CFC 
phaseout is being disproportionately shouldered by American 
consumers. There is a misconception that the costs of the CFC 
phaseout are equally shared among the peoples of the world. 
Although there is an international phaseout of CFCs, most of the 
costs are being incurred here in the U.S. For one thing, the 
U.S. has more affected equipment than any other nation. In 
contrast, the Scandanavian countries, which have taken the lead 
in demanding stringent phaseout deadlines, have much less to lose 
because they have far less air-conditioning equipment. Also, 
developing nations such as China, India, and Mexico have a ten 
year delay in phasing out CFCs, and several nations, including 
Russia, have indicated that they will not comply with the current 
deadlines. In addition, there are provisions that only affect 
Americans, like the onerous EPA regulations requiring expensive 
and time consuming procedures during repairs of air-conditioning 
and refrigeration equipment, as well as the heavy excise taxes on 
CFCs. Further, while our government is trying hard to crack down 
on the burgeoning black market in CFCs, other nations are making 
scant enforcement efforts. For example, the anecdotal evidence 



234 



I've accumulated suggests that black market CFCs are readily 
available throughout much of Western Europe, and at lower prices 
than in the U.S. Thus, the argument that this is a globally 
shared burden is spurious, and unilateral relief for American 
consumers would not be unfair. 

The costs have been exacerbated by the acceleration of the 
CFC phaseout from the January 1, 2000 deadline in the original 
1990 amendments to the Clean Air Act, to the January 1, 1996 
deadline we have right now. This is true for several reasons. 

First, for the large volume of CFC equipment currently in 
existence, the accelerated phaseout will interfere with its 
continued use. Many perfectly good systems will have to be 
prematurely replaced or retrofit when CFCs become scarce. On the 
other hand, a slower phaseout would have allowed most existing 
CFC systems to live out their useful lives, and then be replaced 
in due course by non-CFC systems. With automotive air- 
conditioners, for example, normal fleet turnover results in 10% 
of older cars going off the road each year. And since new cars 
no longer use CFCs, we would have seen a steady decline in the 
number of CFC-using motor vehicle air-conditioners without a 
draconian phaseout and its accompanying costs. 

In addition, the abrupt phaseout of CFCs is resulting in the 
introduction of substitute refrigerants and equipment being 
rushed into service with minimal field testing and many technical 
bugs yet to be worked out. Few knowledgeable engineers believe 
these new systems will be as reliable and last as long as their 



235 



CFC-using counterparts. Consumers would be better off if they 
could continue using their CFC systems until the new systems have 
been improved upon. But the accelerated phaseout denies them 
this option. 

Further, scientists and environmentalists have raised 
concerns about several leading CFC substitutes. For example, 
HCFCs, which are now used as replacements for CFCs in several 
applications, are themselves being considered for an accelerated 
phaseout by the parties to the Montreal Protocol, based on the 
belief that they also contribute to ozone depletion. HFC-134a, 
the most common substitute, has been called a contributor to 
global warming. And recently, a scientific study reported that 
the breakdown products of several CFC-substitutes can accumulate 
in wetlands, and concluded that the ecological consequences could 
be serious. There are also safety and toxicity concerns that 
have not been adequately addressed. And, whenever asked for firm 
assurances that these substitutes won't also be restricted, EPA 
has always balked. Thus, it may well be that after consvimers are 
forced to endure the abrupt and costly phaseout of CFCs, they 
will be subject to a second phaseout for the CFC substitutes that 
were rushed into use and then later found to be environmentally 
unacceptable as well. The costs of such false starts could add 
billions to the phaseout's ultimate price tag. 

Also, the accelerated phaseout is going to become far more 
costly than expected because refrigerant recovery and recycling, 
which is mandated by the law and the EPA regulations, is turning 



236 



out to be a disappointment. Despite optimistic statements by the 
EPA that recovery and recycling of exisiting CFCs will provide an 
ample supply to meet future damand, it is clear that it will fail 
to do so. Thus far, the quantity and quality of recycled 
refrigerant is far below expectations. In some cases, recycled 
CFCs are so contaminated that they can actually damage a system. 
The trade press is replete with articles such as "Recovered 
Refrigerant: Where is It?" (Air Conditioning, Heating, and 
Refrigeration News, May 16, 1994) . And the fact that there is a 
growing black market is also evidence that recycled refrigerants 
are not sufficient to meet demand. 

These problems could be substantially reduced by allowing a 
few more years of CFC production. The Doolittle Bill would 
return the phaseout deadlines to those in the 1990 Clean Air Act, 
allowing limited CFC production until the year 2000. We have 
heard testimony from scientists that this small amount of 
additional CFC production will make very little difference from 
an environmental standpoint. But it would be enough to save 
American consumers billions of dollars. It will enable those 
with CFC ec[uipment to continue using their existing systems with 
CFCs for at least a few more years, by which time we will better 
know which substitute refrigerants are technically and 
environmentally acceptable. This will avoid the problem of 
expensive false starts. It will also spare equipment owners from 
having to rely on black market and recycled refrigerants which 



237 



are lacking in quantity and quality, by providing a supply of new 
and pure refrigerant. 

In conclusion, the accelerated phaseout of CFCs will be very 
costly to consumers, particularly over the next few years. 
Allowing an additional amount of limited CFC production until 
2000 would be environmentally inconsequential, but would greatly 
reduce the costs to consumers. Not doing so may well lead to a 
consumer backlash. 



238 



CEI 



CEI 



Environmental 
studies program 



CKI 


THE fflGH COST OF COOL 


CKI 


The Economic Impact of the CFC 
Phaseout in the Uniied States 


CKI 
CT^J 


Ben Lieberman 


CKI 




CKI 


June 1994 


CKI 





COMPETmVE ENTERPRISE INSmVTE 
1001 Connecticut Avenue NW. Suite 1220 
Washington. DC 20036 
(202)331-1010 Fax:(202)331-0640 



239 



The Competitive Enterprise Institute 

The Competitive Enterprise Institute (CEi) is a pro-market public policy group 
committed to advancing the principles of free enterprise and limited government 
Founded in 1984 by Fred L. Smith, Jr., CEI emphasizes the mariceting and imple- 
mentation of classical liberal ideals. 

CEI utilizes a five-point management approach to affecting public policy: analysis, 
education, coalition building, advocacy and litigation. Its purpose is to advance 
the free-mari(et agenda, believing limited government and competition best serve 
the public interest 

A non-profit tax-exempt organization under Section 501(c)(3) of the Internal Rev- 
enue Code, CEi relies entirely on donations from corporations, foundations, and 
private individuals with an interest in restoring individual liberties and economic 
freedom. All contributions are tax deductible. 

For more information contact 

Competitive Enterprise Institute 

1001 Connecticut Avenue, N.W. 

Suite 1250 

Washington. DC 20036 

202/331-1010 > 



240 

THE HIGH COST OF COOL 

The Economic Impact of the CFC Phaseout 
Ben Lieberman 

EXECUTIVE SUMMARY 



Chlorofluorocarbons (CFCs) are an imponant class of compounds. They have an impact on 
the life of nearly every American. Yet, as a result of environmental fears, their production will 
soon be eliminated - by the year 1996. In making this decision, little consideration was given to the 
costs of eliminating such a widely used class of compounds over a relatively short period of time. 

This study examines the probable economic cost of the CFC phaseout on the refrigeration 
and air conditioning sector in the United States. The estimated cost of the CFC phaseout is $44.5 to 
S99 4 billion over the next decade. This estimate breaks down as follows (figures in billions): 

• Vehicle air conditioners — S28.0 - S42.0 

• Energy consumption — S - $32. 1 

• Domestic refrigeration — $ 4.0 - $ 8.0 

• Commercial refrigeration — $ 3.0 - $ 5.4 

• Chillers — $ 4.4.$5 

• HCFCs & HCFC Equipment — $ 5 1 - $ 6.9 

Compliance with the law will impose large up-front costs on businesses and individuals. Much 
equipment will need to be replaced or modified (retrofitted). 

After decades of fine-tuning and extensive field experience, air conditioning and refrigera- 
tion equipment using CFCs has become very reliable. In contrast, most CFC replacements are new, 
and manufacturers are still near the bottom of the learning curve in making the massive technologi- 
cal changes necessary. 

Because of the accelerated phase-out, which provides a limited time frame in which to end 
dependence on CFCs, non-CFC systems are being rushed into use, despite many unsolved problems. 
In effect, a multi-billion dollar field test of experimental equipment is being conducted at consumer 
expense. The frequency of break downs, and the costs of repairs can be expected to increase for 
many applications. 

The CFC phaseout may well be the single most expensive environmental measure taken to 
date During the policy debate, the costs were underemphasized to the point that they never became 
an important factor. The impact on consumers was scarcely considered. It may be too late to 
reverse course on the CFC phaseout, but it can serve as a lesson for the future. 



241 

THE HIGH COST OF COOL 

The Economic Impact of The CFC Phaseout 
In the United States 

byBenLiebennan 



INTRODUCTION 

Chlorofiuorocaibons (CFCs) are an important class of compounds. They 
are the refrigerants used in over S 100 billion worth of air-conditioning and 
refrigeration equipment in the US. They have an impact on the life of nearly every 
American, as many people own CFC -using equipment and purchase goods and 
services that rely on CFCs. 

As a result of environmental fears, their production will soonbe eliminated. 
A number of scientists have argued that CFCs and other compoundsdeplete the 
earth's ozone layer.' Accordingtothetheory.CFCmoleculesthatescapeintothe 
atmosphere at ground level eventually rise to the upper atmosphere (stratosphere), 
where they are broken down by sunlight and release their chlorine atoms. The 
chlorine atoms then destroy ozone molecules, leading to depletion ofthe strato- 
sphericozone layer Since the ozone layerpartiallyshidds the earth from incoming 
ultraviolet radiation, itsdepletion is prediaed to lead to an increase in ultraviolet 
radiation reachingground level.' Because increased ultraviolet radiation levels 
could adversely affect human health and the environment, the Congress and the 
international community have outlawed the production of CFCs by the end of 
1995 

In making this decision, there was littleconsideration given to the costs of 
eliminating such a widely used class of compounds over a relatively short period 
oftime IntheU S..thesecostswiUbebetween$44.5 to S99.4 billion over the 
next decade for refiigeration and air-conditioning alone. This amounts to 
approximately S44S to S994 per household. These costs should have been taken 
into account during the CFC phaseout decisionmaking process. 

The federal go venunent, once it chose to embark on the accelerated CFC 
phaseout, has tried to minimize the issue of the costs to the public. While 
overstating the dangers of ozone depletion in numerous reports, hearings, and 
press conferences, agency officials and legislators have often underemphasized 
the economic consequences and human impact of eliminating CFC production 
by 199S ' The few studies that estimate the costs tend to understate them, 
while overstating the environmental bene6ts of eliminating CFCs.* As a result. 



CFCs have an 
impact on the life 
of nearly every 
American. 



Utbtrman: The High Cost of Cool 



Pigel 



242 



There was little 
consideration 
given to the costs 
of eliminating 
such a widely used 
class of com- 
pounds over a 
relatively short 
period of time. 



the public has accepted the CFC phaseout in near total ignorance of the impact it 
will have on them. 

This paper will attempt to provide a realistic assessment of the costs in the 
U.S. ofeliminating CFC production by 1995. It will be limited to the impact on 
refrigeration and air-conditioning', and will emphasize the costs that, directly or 
indirectly, will be imposed on American consumers over the courseofthe next ten 
years. 



THE CURRENT STATE OF THE LAW 

Both international and U.S. lawrestriatheproductionofCFCs.* In 1987, 
the international community responded to fears of global ozone depletion by 
ratifying the Montreal Protocol on Substances That Deplete the Ozone Layer 
(Montreal Protocol). Itwas signed initially by 24nations, including theUS. and 
most major CFC producers. Today the Montreal Protocol has 1 23 signatories. 
It originally called for an eventual SO percent reduction in global CFC production, 
but has since been amended to require a total phaseout, except for "essentiaT uses, 
by the end of 1 995 for developed nations and 2005 for developing nations.' 

Domestically, the Congress included provisions to the Clean Air Aa 
Amendments of 1990, which set production limits on CFCs, culininating in a 
total phaseout by the year 2000. In February 1992, the phaseout was 
accelerated in response to a NASA press conference, where several scientists 
predicted a severe depletion of the ozone layo- over North America during the 
winter.' The Seruteunanimously passed an amendment urging president Bush to 



roo ■ 



-«00-r' 
I 400 -K 



200- 
100 ■ 



U.S. PRODUCTION OF CFC-ll AND CFC-12 
1987 - 1997 



;z=?i 



.^^IPI 



■"iiiiTn 



^!^=P^ 



\/, ^ / ^^d^ 



1»I7 19il 1919 1990 1991 199J 1991 1994« I99S* I99«« I997* 

•ToialCPC >r»<iaMsliaiuia<«iicn«U 1 li« Yt«r 

SOL'KCE:/lir-Ca>i<ineMi>ig, HtaaKgandR^hfraiKmNtwi 



Page 2 



Litberman: Tht High Cost of Cod 



248 



moveupthephaseoutdateto 1995, towhichthcpresident agreed.' Afewmonths 
later. NASA admitted that their prediction was incorrect, but the accelerated 

phaseout was unaffected. '" 

In response to Congress, the EPA recently promulgated the regulation that 
outlines the phaseout. ' ' Generally, CFC productionis limited to 25 percent of 1 986 
production levels for 1994 and 1995, with a complete end to production on 
January 1. 1996 " Estimates ofpast and projected CFC production in the U. S. 
are displayed in the chart above. In addition, a related class of compounds called 
HCFCs is being phased out under a slower timetable. " The EPA has also imposed 
regulations regarding the manner in which air-conditioning and refrigeration 
equi pment is serviced and disposed of, in an attempt to reduce the atmospheric 
release of existing CFCs. '* 



CFCs are rapidly 
becoming scarce. 



AN OVERVIEW OF THE COSTS 

Before analyzing the effect of the phaseout on specific end uses, it is 
worthwhile to take an overall view ofits impaa. Compliance with the law will 
impose largeup-front costs on businesses and individuals, as much equipment will 
need to be replaced or modi- 
fied (retroiined) In addition. 



ESTIMATED CFC PHASEOUT COSTS 

REFRIGERATION AND AIR-CONDITIONING 

1994 through 2003 

(figures in Sbillions) 



Cost 



there will be inaeases in ongo- 
ing operational expenditures 
as a result of higher 
maintainance costs, refinger- 
ant costs and energy consump- 
tion This will add as much as 
$9 94 billion annually overthe 
next decade to the cost of 
meeting America' s refrigera- 
tion and air-conditioning needs. 
The breakdown of the costs 
over the next decade assessed 
in this paper is displayed in the 
table at right and the chart 
below 

Equipment Costs 

In the US, there is 
approximately $135 billion 
worth of air<onditioning and 
refrigeration equipment in com- 
mercial and domestic use.'' Much ofthis equipment has a usefiil life of 10 to 25 
years, needs additional refiigerant to make up for leakage over time, and is not 
designed to work wnth non-CFC refiigerants.'* Because CFCs are rapidly 
becoming scarce, much equipment will have to be prematurely replaced or 

Ltbtrman: The High Cosi of Cool 



Range 



Vehicle Air-Conditioners 


28.0 - 42.0 


Energy Consumption 


0-32.1 


Domestic Refrigeration 


4.0- 8.0 


Commercial Refrigeration 


3.0- 5 4 


ChiUen 


44-5.0 


HCFCs and HCFC Equipment 


5.1-6.9 


TOTAL 


44.5-99.4 



Note: The following ire not included in the tbove analysis: refrigerated 
transportauon, indusinal refrigerauon, medical and laboratory equipmenc, 
dehumidificrs, vending rinchinei. water coolers, dnnking founuins. 



Page 3 



244 



CFC PHASEOUT COSTS 
ESTIMATED DISTRIBUTION 



QjTBbc RA^Axn 




retrofitted to use CFC alternatives. 
Billionsof dollars in additional equip- 
ment and installation outlays will be 
required to maintain the status quo. 

Even after the current base of 
equipment is replaced, there may be 
ongoingincreases in equipment costs. 
There are some indications that the 
alternative systems will havea shorter 
useful lifethan their CFC-usingcoui>- 
terparts, but it is difficult to icno w for 
certain as non-CFC equipment has 
only recently come into use. Al- 
though the potential costs of more 
frequent replacements could be high, 
they cannot be accurately estimated 
at this time and will not be included in 
the total accounting. 



OPERATIONAL COSTS 



In effect, a multi- 
billion dollar field 
test of experimen- 
tal equipment is 
being conducted 
at consumer ex- 
pense. 



Maintenance 



After decades offine-tuning and extensive field experience, air-condition- 
ingand refiigeration equipment usingCFCshadbecomeve:yreliable. In contrast, 
most CFC replacements are new, and manufacturers are still near the bottom of 
the learning curve in making the massive technological changes necessary. 
Properly matching equipment with these new refiigerants will take several more 
years. This task is fijrther complicated by the faa that many non-CFC refrigerants 
have inherent chemical and thermodynamic properties that make them difficult to 
manage. 

Under ordinary circumstances, extensive research and development 
would be completed by industry prior to new equipment being introduced in 
the market. However, because of the accelerated phaseout, which provides 
a limited time firame in which to end dependence on CFCs, non-CFC systems 
are being rushed into widespread use, despite many unsolved problems. In 
effect, a multi-billion dollar field test of experimental equipment is being 
conducted at consumer expense. The frequency ofbreakdowns, and the costs 
of repairs can be expected to increase for many applications. 

Further, the rapid introduaion of numerous new refrigerants has 
thrown the refirigeration and air-conditioning service industry into a state of 
confusion. In the last few years, no less than 1 new refrigerants have come into 
use, and more are on the way. '^ Some have unique equipment requirements and 
servicing needs, which are currently being discovered through trial and error. " 



Page 4 



Liebtrman: The High Coil of Cool 



245 



Further, because some of the new refrigerants are chemically incompatible with 
others, service equipment that comes in contart with one refrigerant (for example 
recovery devices or gauges) may cause contamination iflater used on asystem with 
a different refrigerant. Unless servicemen own and maintain several sets of 
dedicated equipment, refrigerant cross-contamination will become a serious 
problem 

The situation is so complex that even skilled servicemen admit that they are 
of^en not certain as to the proper procedure. Costly mistakes made during 
installation, routine maintenance, and repairs will be common for many years, 
imposing significant costs on equipment owners. 

Also, refrigerant recovery rules, requiring servicemen to take measures to 
prevent refrigerant leakage during servicing, and rules requiring leak detection and 
repair, are time consuming and require expensive equipment, adding to the'costs 
of repairs and maintainance " 

Air-conditioning and refrigeration servicing has become more costly." 
Some servicemen estimate that they will be charging clients about 25 percent more 
than they had previously However, the total increase in maintenance costs cannot 
be determined at this time, as most of these costs are incurred after equipment has 
been in use for a few years, and non-CFC equipment has only recently made 
inroads into the American market. Because of the uncertainties, these costs will 
not be included in the total accounting, except in those cases where it is specifically 
noted. 

Refrigerant Use 

Before the phaseout took effect, the market price of the most common 
types of CFC refrigerants, CFC-11 and CFC-12. was less than $1.00 per 
pound wholesale. Today, as a result of production limits and excise taxes, they 
cost approximately S8 GO to SIO 00 per pound at the wholesale level, and up 
to twice that for some retail users." This amount is expected to rise 
considerably in the months and years ahead. In 1994 and 199S, the quantity 
of CFCs allowed to be produced is about 180 million pounds annually, but 
based on recent years, considerably more than that will be needed. ° After 
January 1, 1996, when all production ends, cost increases will further 
accelerate due to limited supplies." Predictably, a black market in CFCs is 
developing." 

Refrigerant recovery and subsequent recycling orreclamation, though 
required by law, is not likely to make up for the shortfall. There are limitations 
on how much refrigerant can be recovered and reused.** Also, compliance has 
not been widespread, particularly among those servicing equipment with a 
small refiigerant charge." 

The leading replacement refrigerants are also expensive. Unlike CFCs, 
the patents on which have long since expired, many of these new compounds are 
still underproprietary protection." Others are more expensive to produce. The 



Costly mistakes 
made during 
installation, rou- 
tine maintenance, 
and repairs will be 
common for many 
years. 



A black market in 
CFCs is develop- 
ing. 



Ueberman: Tht High Cost of Coot 



PigeS 



246 



In nearly every 
case, thephaseout 
ofCFCs will re- 
sult in higher costs 
and decreased 
performance. 



most common replacement, hydrofluorocarbon- 1 34a{HFC- 1 34a), costsat least 
$7 00 per pound. " In addition, some replacement refrigerants require expensive 
lubricants and additives in order to function properly. Cheaper alternatives, such 
as ammonia and hydrocarbons, have limitations — flammability, toxicity, regula- 
tory barriers — that will take several years to overcome, and are not likely to be 
widely used in the U S . in the near future. 

Before the stringent production restrictions were in effect, the US 
produced and consumed approximately 650 to 700 million pounds of CFCs 
annually, at least 300 million of which were used as refrigerants." Conserva- 
tively estimating a $5.00 per pound increase in the current cost of CFCs and 
alternatives over the pre-phaseout cost of CFCs, an additional $1.5 billion per 
year will be spent on refrigerants. Most of these costs are included in the costs 
of new equipment and retrofits, and are not separately discussed. 

Energy Use 

Air-conditioning and refrigeration are energy intensive, consuming 
about 28 percent of the nation' s elearicity . '^ CFCs are currently used in many of 
these applications. Their replacement has raised concerns about the impact on 
energy consumption. 

As refrigerants, CFCs are relatively energy efiScient. Their thermody- 
namic properties — thermal conductivity, latent heat of vaporization, boiling 
point — are nearly ideal, for a variety of applications. In contrast, many of the 
leading replacements, such as HFC- 1 34a, are not as well suited, and a loss in 
energy efficiency (relative to comparable CFC-using equipment) is unavoid- 
able." In addition to thermodynanuc efficiencies, there may be other problems 
with non-CFC systems that will lead to greater energy use." 

One hypothetical estimate of the annual increase in overall electricity 
use resulting from a CFC phaseout gives the range of 1 3 to 94 billion kWh/yr, or 
(assuming $ 0.06 per KWh) $0.78 to $5.64 billion dollars." The middle ofthis 
rangeamounts to an additional energy cost of53 21 billion per year. 

Other recent studies bythe EPA, DOE and the alternatives industry found 
little or no energy penalty. ^ They compared the efficiencies of new alternative 
systemsutilizing optimized engineering design with theold and infenorty equipped 
CFC systems they are replacing. Relative efficiencies of comparable CFC and 
non-CFC systems were not considered." The energy efficiency gains in new 
equipment are due to technological advances largely unrelated to the refrigerant 
chosen, although the CFC phaseout may have provided the impetus for immediate 
implementation of these costly improvements. In effect, the e£5ciency gap between 
new non-CFC and old CFC systems is being narrowed, and in some cases 
eliminated, but at the expense ofhigher equipment costs. 

Nonetheless, the gap between comparable CFC and non-CFC systems 
persists. However, the extent of this gap is difficult to determine, as the energy 
efficiency of new non-CFC equipment is currently being improved, and the 



Page 6 



Uebentum: The High Coil of Cool 



247 



efficiency of comparable CFC systems can only be speculated, as CFCs are no 
longer being used in stste of the an equipment In addition, the CFC phaseout has 
accelerated the retirement rates for old, inefiRcient systems. For these reasons, it 
is hard to estimate what energy consumption would have been without the CFC 
phaseout, and what it will be with the phaseout. 

For the purposes of this study, the assumed range of increased annual 
energy expenditures is SO to S3 2 1 billion, or SO to $32 I billion over the next 
decade Thelowendofthisrangeassumesthatenergyuseforair-conditioningand 
refrigeration will be no different than if there there been no CFC phaseout. The high 
end, which represents the middle ofthe range discussed previously, estimates a 
penalty of about 2 percent of total energy consumption. 

THE DVIPACTON SPECIFIC END USES 

The higher initial and ongoing costs discussed above will affect most kinds 
of refrigeration and air-conditioning applications. In nearly every case, the 
phaseout of CFCs will result in higher costs and decreased performance. The most 
heavily affected applications wiU each be discussed separately. 

Vehicle Air-Conditionen 

Americans own approximately 1 40 million automobiles and trucks that 
use CFCs in their air-conditioners.^ Unless willing to do without air-conditioning, 
these owners are faced with two choices — continue using CFCs, or retrofit their 
system to use an alternative refrigerant. Either choice entails increased costs. 

Continue UsingCFCs: 

Generally, vehicle air-conditioners run without problems for the first few 
years, and then need servicing once every two or three years thereafter. The most 
common problem is refrigerant leakage. Approximately 20 million cars and trucks 
are brought in for air-conditioner servicing each year." 

The accelerated phaseout already has increased the cost of servicing. 
Servicemen are required to comply with refrigerant recovery rules in order to 
reduce the amount of refrigerant that escapes during servicing.'* This takes 
as much as a half hour and requires equipment costing about SI, 000 As a 
result, labor costs for air-conditioner servicing have gone up. 

The cost ofthe refrigerant, CFC- 12, has also increased from under 
SI 00 per pound to as much as SIO.OO wholesale and about twice that retail. 
.\ vehicle may need up to three pounds to be fully operational. The cost is 
expected to rise further, particulariy in 1996 when all production ends. 

It is nowillegal to sell small cans of CFC- 1 2to the public, which were used 
to recharge vehicle air-conditioners." Consideringthat 60 to 80 million pounds 
of refrigerant were sold in these cans, it is reasonble to assume that millions of 
people recharged their o\yn vehicle air-conditioners, at minimal cost.'' They are 
no longer able' to do so Now tlfey are forced to take their vehicles to an EPA- 



Approximatefy 20 
million cars and 
trucks are brought 
in for air-condi- 
tioner servicing 
each year 



Uebtrman: The High Cost of Cool 



Page 7 



248 



The auto industry 
has spent several 
hundred million 
dollars to redesign 
vehicle air-condi- 
tioning systems. 



certified mechanic or dealer whenever their air-conditioner needs servicing, and 
pay the market price for refrigerant and labor. 

As a result, recharging an air-conditioner low on refrigerant, which cost 
between $20 and $40 as recently as 1991 (and just a few dollars for do-it- 
yourselfers), currently averages approximately S 1 00.*' This figure will increase, 
possibly doubling by 1996, if CFC-12 costs continue their present trends. 
Performing repairs on a system, such as fixing a leak, averages S26S, a20 percent 
increase over the 1 99 1 average." This amount is also likely to increase with time. 
Also, the number of vehicle owners being persuaded by servicemen to spend 
considerably more to repair leaks rather than "top oS" (adding lost refiigia-ant 
without repairing the leak) will inaease, in order to avoid the possibility of further 
CFC- 1 2 losses in the fijture.*' In Florida and parts of California, leak repair is 
required by state law. 

Retrofit: 

CFC-using air<onditioneis can be modified to use an alternative refrig- 
erant, HFC- 134a. However, this is an expensive changeover, requiring the 
replacement of several components, including the hoses, safety valve, 0-ring seals, 
drier, and possibly the condenser, as well as a thorough flushing of thesystem to 
remove all traces of CFC- 1 2 and mineral oil, which act as contaminants in the 
presence ofHFC- 134a. The estimated average cost ofa retrofit is S433.** Also, 
there are unanswered questions as to the performance and reliablity of retrofits.^ 
It is unlikely that many consumers will choose the retrofit option, unless CFC- 1 2 
becomes prohibitively expensive ortotally unavailable. 

Tptal CgStS F«?r Exiting VghitlWi 

Assuming the 1 40 ntillion CFC-using vehicles need an average of two 
more air-conditioner repairs or recharges before they are retired over the 
course of the next ten years, and each servicing averages S 1 00 to S 1 SO more 
than a comparable pre-phaseout servicing, the increased cost will be S28 to 
S42 billion over the next decade.** The total will be even higher if difiSculties 
in obtaining CFC- 1 2 force a large number of people to retrofit their vehicles. 
The option of simply not repairing an inoperative CFC-12 air-conditioner is 
also costly, as it will reduce the resale value of a vehicle by several hundred 
dollars."' 

New Vehicles: 

New car and truck air-conditioners are now designed to use HFC- 
134a. Introduced in a few models in 1992 and 1993, HFC-134a air- 
conditioners will predominate in 1994 models. The auto industry has spent 
several hundred million dollars to redesign vehicle air-conditioning systems 
and retool assembly lines to accommodate the changes. Eventually, these costs 
will be passed on to consumers in one form or another. 



Pages 



Liebtrman: The High Cost of Cool 



249 



It is unlikely that HFC- 1 34a systems will be as reliable as CFC-12 
systems*' High failure rates after several years in use may be common. Unlike 
CFC-using systems, which (excepting minor repairs and occasional re- 
charges) often lasted as long as the vehicle, a number of HFC- 1 34a air- 
conditioners will probably need a major repair during the vehicle's useftjl life. If 
so. owning and maintaining a new HFC- 1 34a air-conditioner for the life of the 
vehicle will cost sevieral hundred dollars more than a comparable pre-phaseout 
CFC system Any additional costs will become apparent only after the new HFC- 
134a air-conditioners have been subjected to a few yearsof use.** Because these 
costs are speculative, they are not included in the total accounting forthis paper. 

Domestic Refigeraton 

There are abflyrMftMban refrigerators in domestic use m the U.S." 
Nearly every household has at least one. They are reasonably priced and 
extremely reliable, often providing 15 or more years of trouble-free service. 
Until recently, nearly all used CFC-12 as their refrigerant. The phaseout will 
have relatively little effect on these refiigerators. as less than 5 percent ever 
require servicing due to refrigerant leakage. 

However, refrigerator manufacturers are already preparing for the 
phaseout. As a result of CFC-12 shortages and price increases, several 
refrigerator manufacturers have begun to make the transition to non-CFC 
refrigerators, well ahead of the January 1 , 1 996 phaseout date. By that time, 
all newly manufactured refrigerators will be CFC-free. 

As with vehicle air-conditioners, the alternative refiigerant of choice 
for new domestic refHgerators is HFC- 134a." Although it is too early to 
determine the price of these new refrigerators, at least one introductory model 
is priced S 1 00 higher than a comparable CFC refirigerator, most ofwhich range 
from $500 to $ 1 ,500, depending on the brand name and features." Assuming 
a S50 to SI 00 increase per reftigerator, the nearly 10 million domestic 
refrigerators (and stand-alone fi'eezers) sold each year will cost an additional 
$0 5 to $10 billion.'* 

Assuming HFC- 134a refrigerators predominate beginning in 1996, the 
cost over the next decade will be S4.0 to $8.0 billion. 

HFC- 1 34a refrigerators may use more energy than an equivalent CFC 
system ** Like vehicle air-conditioners, ^FC-134a refrigerators are unlikely 
to be as reliable and long-lasting as their CFC-using counterparts. " Expensive 
repairs may be common, some necessitating replacement, particularly after 
about 8 years of use. Because the first HFC- 1 34a refHgerators are only a few 
years old, there is no direct evidence regarding their long-term reliability. ** If 
they prove less durable than CFC refrigerators, the cost of additional repairs 
and premature replacements could be significant. This potential cost is not included 
in thetotal accounting. 



TTiere are about 
150 million 
refrigerators in 
domestic use in 
the U.S. 



HFC-I34a 
refrigerators are 
unlikely to be as 
reliable and long- 
lasting as their 
CFC-using coun- 
terparts. 



Lieherman: The High Coil of Cool 



P»ge9 



250 



TTiere is no legal 
requirement that 
CFC equipment 
be retired, only 
that CFC produc- 
tion cease. 



Chillen 

There are at least 80,000 chillers operating in the United States. " Chillers, 
so called because they chill water which is used to cool air, are the most efficient 
means to air-condition large buildings. They also provide the cooling in certain 
industrial applications. About 65,000 arelow-pressurechiUers that useCFC-1 1, 
and most of the rest are high-pressure chillers that operate with CFC- 1 2, HCFC- 
22, or R-500 (a mixture that includes CFC- 12)." These systems are expensive 
to purchase and install and are expected to last more than 20 years. Most contain 
a thousand or more pounds of refrigerant, and often have high leak rates. ** Thus, 
the future of this equipment has been significantly affeaed by the phaseout. 

Thus far, less than 1 percent of chillers have been replaced or retrofited 
to usenon-CFC refrigerants."* Most will still be reliant onCFCs when production 
comes to an end in 1996.*' 

Chiller owners are faced with several choices, and must make them in a 
short period of time and with limited information. Basically, they can contiraje to 
use CFCs, retrofit existing equipment to use an alternative refrigerant, or replace 
their system with a totally new non-CFC chiller. Each choice entails significant 
additional costs. Which option is appropriate in each case depends on the type 
and condition of the chiller, and the characteristics of the building it is located ia 
It also depends on the future availability of CFCs and the rate of non-CFC 
technological breakthroughs. Atthispoint,thenumberofchillerownersthatwiU 
chooseeachoptionarulthetotalcostcanoniybeestimated. ThethreeoptionswiU 
be discussed in turn. 

Continue Using CFCs: 

There is no legal requirement that CFC equipment be retired, only that 
CFC production cease. Existing CFC chillers can be used beyond the phaseout 
date, provided that suflBcient refrigerant is available. However, with CFC 
production to end in 1995, the only way of assuring the long-term operation of 
CFC chillers is to minimize the amount of additional refiigerant needed. This 
requires refiigerant containment, i.e. taking steps to reduce refrigerant leakage, 
and recovering(ratherthan venting) refrigerant during maintenance and servicing 
(bothofwhicharealso regulatory requirements). It also necessitates storing extra 
CFCs forfliture use." ThisoptionisparticlarlyattractiveforCFC-l Ichillersin 
good working order, whereleakagecanbereducedtoaminimum." Assuming 
that about half (30,000 to 35,000) of the CFC-1 1 chiller owners choose this 
option over the next decade, and the average cost is approximately S20,000 to 
S30.000partsandlabor,**thetotalcostoverthenextdecadewiI]beS0.6toS1.05 
billion dollars. 

Retrofit: 

For about 1 5 ,000 to 20,000 existing chillers, retrofitting to use alternative 
refrigerants is an economically sound decision. Perhaps 10,000 to 15,000 CFC- 
1 1 chiller owners, anxious to end theirreliance on CFCs. will choose to retrofit to 



Page 10 



Lieberman: The High Cost o/Cool 



251 



HCFC- 1 23 Retrofitting will also be chosen by the owners of many relatively new 
CFC-12 and R-SOO chillers, because difficulties in reducing leakage makes 
continued reliance on CFCs risky, and total replacement would be wasteful. They 
can be retrofit to use HFC-n4a. In either case, a retrofit entails extensive 
modifications to a chiller** Retrofit costs range from $10,000 to well over 
S 1 00.000 ** Assuming an average retrofit cost of S50,000, the total cost of 
retrofitting chillers will be S0.7S to $ 1 .00 billion over the next ten years. 

Premature Replacement. 

Since continued reliance on CFCs or retrofitting involves significant costs 
and risks, some building owners may choose to purchase and install anew chiller." 
Assuming 30,000 existing chillers will have been replaced in the next 1 years," 
and half of these replacements are anributable to old chillers in need of replacement 
anyway, 15,000 replacementscanbeattributedtothephaseout. New chillers vary 
in cost depending on size, and the cost ofmstallation depends on the features of 
each building. Assuming an averagecost ofS 1 20,000, these chillers will add S 1 . 8 
billion to the phaseout cost." 



Primarily because of safety concerns surrounding some of the replacement 
re&igerams, new building code requirements for buildings with chillers are likely to 
become law."* The American Society of Heating, Refrigeration, and Air- 
ConditioningEngineer5(ASHRA£) sets the model standardswhichnearlyali local 
building codes follow.^' Standard 34 categorizes refirigerants based on their 
toxicity and flammability. The most commonly used CFCs and HFC- 1 34a are 
listed as A 1 , because they have low toxicity and low flammability. HCFC- 1 23 is 
classified B 1 , because ofhigher toxicity and low flammability.^ Standard 1 S now 
requires that equipment rooms with a class A 1 -using chiller have ventilation 
systems, oxygen monitors, and a self-contained breathing apparatus. B 1 -using 
chillers require a refrigerant vapor detector and alarm system in addition to these 
requirements. The typical cost ofbringing abuilding into compliance will be fix)m 
$ 1 0,000 to $20,000. " Assuming an averageofS 1 5,000, the cost for all 80,000 
chillers will be $ 1 . 2 billion. 

Total Costs: 

Within the next two years, chiller ownen will have to make the transition 
to a market where CFCs, if available, will be very expensive. The total cost of 
continuingtheuseofCFCs, retrofitting, orreplacingchillers, as well asthe cost of 
compliance with new safety standards will be $4.4 to $5.0 billion over the next 
decade. 

Commercial and Institutional Refrigeration 

There are at least five million (and probably closer to ten million) pieces of 
CFC -using commercial and institutional refiigeradon and freezing equipment in the 
US." They are used in the 24,000 supermarkets and 228,000 smaller food 



TTtere are safety 
concerns sur- 
rounding some of 
the replacement 
refrigerants. 



Uebermtm: The High Cost of Cool 



Page It 



252 



A typical super- 
market will cost 
approximately 
$45,000 to retro- 
fit. 



stores," 729,000 restaurants, bars, hotels, schools, and other places that serve 
food and drink,'* and approximately 200,000 other businesses (pharmacies 
liquor stores, florists etc.) that require such equipment." Complying with the law 
will be a complex and expensive task. 

These applications require equipment that provides a large volume of 
storage space for refrigerated or frozen items. Like chillers, these systems are 
expected to last a long time and occasionally leak, requiring additional CFC 
supplies to stay operational. Therefore, over the next decade, most of them 
will be retrofit to run with alternative refrigerants." As with chiller owners, 
the majority of aflfeaed establishments have not yet done anything, thus the 
total costs can only be estimated at this time. It is assumed that these costs 
will eventually be passed on to consumers. 

Supermarkets and Food Stores: 

Retail refrigeration equipment falls into two general categories, medium 
and low temperature. Medium temperature equipment includes meat, fish, dairy, 
delicatessen, and produce cases, and walk-in coolers for storage. Most medium 
temperature systems use CFC- 12. Low temperature applications include multi- 
deck fi-ozen food cases, closed door freezer cases, and open chest type freezers 
and walk-in freezers. Most of this equipment uses a mixture called R-S02, which 
contains CFCs. Supermarkets typically have about 30 medium and low tempera- 
ture systemi while convenience stores and other small food retailers have fewer 
than 1 0, and the systems tend to be smaller than their supermarket counterparts. 

The cost of retrofitting a singlesystem in a supermarket is approximately 
51,500." Thus, a typical 30-system supermarket will cost approximately 
S4S,000 to retrofit. ThisamountstoSl. I billion nationwide. Smallerfood stores 
will probably range from $3,000 to $5,000 each, or $0.7 to $1.1 billion 
nationwide. 

Food Service: 

The 729,000 restaurants and other places that serve food or drinks 
typically have 1 or fewer pieces of equipment. In addition to having the same 
types of equipment used in food stores, they will also have ice machines and 
small, self-contained equipment for storing and serving food and drinks." 
Typical retrofit costs are estimated to be in the $1,000 to $3,000 range, for 
a total of $0.7 to $2.2 billion. 

OtherCommercial Uses: 

At least 200,000 other businesses use refrigeration, usually fewer than 
fivepieces of self-contained equipment. The retrofit cost to these businesses will 
probably average of $250 to $500 each, or $0.5 to $ 1 .0 billion in total. 



Page 12 



Utbermcm: The High Con o/Cool 



253 



Total Costs: 

Well over one million establishments will have to make changes in their 
refrigeration equipment in order to cope with the lack CFCs The total cost 
for these businesses and institutions will likely be $3 0-$5 4 billion. 



HCFC Equipment 

In addition to CFCs, a related class of refrigerants called 
hydrochlorofluorocarbons (HCFCs) are also being phased out of produaion, 
but under a slower timetable. In the U. S . , HCFC-22, the most commonly used 
HCFC. will be phased out beginning in 2010 " However, it is possible that 
the deadline will be accelerated. 

HCFC-22 is used in 43 million central air-conditioners in America's 
homes, and in about 2 million air-conditioners in other buildings." The 
refrigerant recovery rules also apply to HCFC-22 equipment. On average, 
central air-conditioners require the type of servicing necessitating recovery 
once every five years. Thus, in a given year, approximately 20 percent of the 
nation's central air systems will require refrigerant recovery. Assuming nine 
million of these procedures are performed on residential and other central air- 
conditioners annually at a typical charge of $40 to $60,** the total cost will 
be S360 to SS40 million annually, or S3. 6 to SS.4 billion over the next decade. 
Further, air-conditioners use about half of the 300 million pounds of HCFC- 
22 produced each year." Thepriceof HCFC-22 has doubled from aboutSl per 
pound to S2.'' AssumingthepriceremainsatS2 per pound, an additional SISO 
million will be spent annually on HCFC-22 for air-conditioning, or S 1 . S billion over 
the next decade. Added to the refrigerant recovery costs, the increased costs 
associated with HCFCs will total $5 1 to $6.9 billion for the next ten years. 

In addition to central air-conditioners. HCFCs are used in some chillers, 
commercial refrigeration units, and other equipment. Also, a number of CFC 
systems are being retrofit to use HCFCs. A future supply ofHCFCs will be needed 
to maintain these systems. If the HCFC phaseout is accelerated, as some predict, 
the additional cost of compliance would be great. 

Other Equipmentand Uses 

In addition, other types of CFC-using air-conditioning and refrigeration 
equipment will also be affected, but are not separately discussed. Refrigerated 
transports (trucks, rail cars, ships, sea-land containers), refirigeration used in 
industrial processes, medical and laboratory equipment, dehumidifiers, water 
coolers and drinking fountains, and vending machines are not included. In 
aggregate, the cost of replacing or retrofitting these systems will be significant, but 
are left out of the total accounting for this paper. 



Hydrochlorofluoro- 
carbons (HCFCs) 
are also being 
phased out of 
production 



Lieberman: The High Cost of Coot 



254 



Finally, it must also be remembered that CFCs are also used for other 
applications besides refrigeration and air-conditioning. CTCs have been used as 
cleaning agents, solvents, and as blowing agents for foam insulation. The 
accompanying chart displays the distribution of CFC uses in the United States 

priorto the signing ofthe Montreal 
Protocol. Note that before the 
phaseout, refrigeration accounted for 
less than half of total CFC use in the 
United States. 



DISTRIBUTION OF CFC USES 
PRIOR TO MONTREAL PROTOCOL 




SOCKCE AlliaiKC fort RespomiMcCFC Polky 



CONCLUSION 

The total costs of the CFC 
phaseout on refrigeration and air- 
conditioning will be an estimated 
$44.5 to $99 4 billion overthe next 
decade (see table on page three)." 
These costs will ultimately be borne 
by consumers, and will average $445 
to $994 per household. This in- 
cludes direa cost increasesof own- 
ing and maintaining a vehicle air- 
conditioner, an air-conditioned residence, and a refrigerator, as well as indirect 
cost increases affecting such things as food and rents in commercial buildings. 
However, this estimate does not include a wide-range of other costs that will be 
felt by consumers, including decreased convenience and efficiency. 

Moreover, the phaseout has forced the reallocation of corporate research 
and development monies The demand to meet the phaseout's requirements in 
time has meant that other, potentially more lucrative, investments have been 
deferred. These foregone opportunities are difficut, if not impossible, to measure, 
but represent additional costs imposed by the phaseout 

The CFC phaseout will likely become the single most expensive environ- 
mental measure taken to date. During the policy debate, the costs were 
underemphasized to the point that they never became an important factor. The 
impaa on consumers was scarcely considered. However, as consumers begin to 
pay for this policy they will recognize that environmental measures can be 
expensive undertakings. It may be too late to reverse course on the CFC 
phaseout, but it can serve as a lesson for the future. 



Page 14 



Leberman: The High Cost o/Cooi 



255 



ABOUT THE AUTHOR 

Ben Lieberman is an environmental research associate at the Competitive 
Enterprise Institute. He is author of "Stratospheric Ozone Depletion and the 
Montreal Protocol: A Critical Analysis" in Buffalo Envitotunental Law 
Journal, Spring 1994 Mr Lieberman holds a J D. from the George Wash- 
ington University National Law Center. 



Ufhtnmm: Tht High Cosi of Cool Pige 15 



256 



ENDNOTES 

' SeeM J Molina andF. S Rowland. "Stratospheric sink for chJorofluoromethanes: chlorine atom-catalysed 
destruction of ozone," Mi/we 249(1974): 810-812; ExecutiveSunmaryoftheOzone Trends Panel, March 15, 
1988, Synthesis of the Reports of the Ozone Scientific Assessment Panel, Environmental Effects Assessment Panel, 
Technology and Economic Assessment Panel, Prepared by the Assessment Chairs for the Parties to the Montreal 
Protocol, (November 1991). 

'Ibid. 

> For example, during the Senate debate on the acceleration ofthephaseout date from 2000 to 1995, many Senators 
repeated claims of increases in skin cancer, cataraas, immune system suppression, as well as crop failures and 
destruction of the ocean food chain that are said to be occurring as a result of an increase in ground level ultraviolet 
radiation caused by ozone depletion. However, direct measurements of ultraviolet radiation show no such iiKrease. 
In effect, the feared consequence of ozone depletion, a significant global increase in ultraviolet radiation, is not known 
to be occurring Thus, the claims ofhuman health and environmental consequences are purely speculative. At the 
same time, none of the Senators seriously discussed the costs of eliminating CFCs. See Congressional Record, 
(February 6, 1992), SI 128 - SI 138. 

* See ICF Incorporated, Reguiatory Impact Analysis: Compliance With Section 604 of the Clean Air Act for 
the Phaseout of Ozone DepletingChemicals, (July 1 , 1 992), and addendum. (The costs of eliminating CFCs are 
calculated a S9 billion through the year 2000, and the benefits, largely the millions of additional cases of skin cancer 
assumed to be averted by the phaseout, are calculated to exceed costs by as much as S3 1 trillion). 

' In addition to their role as refrigerants, CFCs, HCFCs and related compounds slated for phaseout have literally 
hundreds of uses in agriculture, manufacturing, medicine, insulation, and fire suppression. In a number of these 
applications, alternative compounds are either more expensive or less effeaive than the compounds they are 
replacing. A detailed discussion of these costs is beyond the scope of this study. 

' With limited exceptions, the law restricts CFC production and consumption (production plus imports minus 
exports) regardless of the end use. Specific restrictions on each end use could have afforded the opportunity to tailor 
the law to quickly proscribe CFC use in applications where CFC replacements are effective and economical (such 
as solvents and cleaning agents), while allowing more time in applications where rapid CFC elimination poses a 
substantial hardshi p (as in several refrigeration and air-conditioning uses). However, an across the board phaseout 
was chosen, partly for political reasons. See Dan McInnis,"Ozone Layers and Oligopoly Profits." in Greve and 
Smith, eds^Environmental Politics: Public Costs, Private Rewards, (New York: Praeger, 1992), p 145, 

' Essential uses are narrowly defined to include uses that are necessary for health and safety reasons or are critical 
to the functioning of society. In addition, it must be shown that there are no available substitutes that are acceptable. 

' NASA News, Scientists Say Arctic "Ozone Hole" Increasingly Likely (February 3, 1992). 

* Congressional Record, (Febtuaty 6, 1992), S1128-S1138. 

'" NASA News, NASA Spacecraft Finds Large Arctic Ozone Depletion Averted (April 30, 1 992). 

" 58 Federal Register 650li - 65082. 

'^ DuPont, the largest CFC producer, had voluntarily agreed to cease production one year eariier than required. 
However, the EPA, fearing shortages, persuaded them to continue production until thephaseout deadline. 



Page 16 Leberman: The High Cost of Cool 



257 



" 58 Federal Register 65025 - 65028. 

" Clean Air Act Amendments of 1 990. Sections 608 and 609; 58 Federal Register 28660 - 28734. 

" Congressional Research Service, "CFC Phaseout: Future Problem for AirConditioning Equipment''" ( Aprill , 
1993). p 4. 

'•Ibid. 

' ' Had the phaseout been slower, industry could have settled on the best replacement refiigerant for each application. 
Such standardization would have reduced the costs and complexitiesof moving away from CFCs. But with so little 
ti me to act, and the replacement technologies still in the early stages, a large number of competing refrigerants have 
been introduced into the market, many of which will become obsolete in the next few years, as the best refrigerants 
emerge from the pack. The same is true for the many oils, filter driers and other components now on the market. 

" For example, choosing the correct filter drier for an air-conditioning or refrigeration systemused tobe an easy task. 
Now, with numerous combinations of refrigerants, oils, and additives, it isdi£5cult to know which type of filter drier 
will perform satisfactorily. The incorrect choice can cause damage to a system by filing to properly remove enough 
moisture, or by filtering out oil additives. 

"Clean Air Act Amendments of 1990, Sections 608 and 609; 58 Federal Register 28660 - 28734. 

" See "The Alternative Solution," Refrigeration Service Contracting, (November 1993), pp. 20-26. 

" Informal survey ofthreewholesalersintheWashington,D.C area, March. 1994; Omnibus Budget Reconciliation 
Actofl989, and subsequent revisions. (The tax is $4 3 5 per pound in 1994, rising to $5. 3 5 in 1995.) 

" "Refrigerant Shortfall Challenges Chiller Owners," Air Conditioning, Heating and Refrigeration News 
(March 22, 1993), pp. 2-3. 

" Congressional Research Service, "CFC Phaseout: Future Problem for Air Conditioning Equipment?" 
(April 1. 1993), pp. 9-11. 

-•' Imported CFC- 12 Bypasses Tax, Sells For Less, Say Producers." Air-Conditioning, Heating and 
Refrigeration Ne^vs (Ma.y 16. 1994), pp 1-2. 

" For example, in automobile air-conditioners, some or all of the refrigerant has already leaked out before a 
vehicle is brought in for servicing, and little or none is lef^ to be recovered. In cases of repairs of hermetic 
compressor motor burnouts, the refrigerant may be too contaminated to be reused. Also, if two or more 
recovered refrigerants are commingled, the entire mixture may be unusable. 

•* See "Recovery-Recycling Unit Sales Still Soft", Air Conditioning. Healing and Refrigeration News (My 
19, 1993), pp. 20-22; "ACCA Members Cite Poor Quality, Lack of Good 'Used' Refirigerant", Air 
Conditioning. HeatingandRefrigeraiionNewsiSeptembeT6, 1993); "Recovered Refrigerant: Where is it?" 
Air Conditioning. Heating atid Refrigeration News {May 16. 1994). pp 3-4. 

2'McInnis.p. 148 

" Informal survey of thre^ wholesalers in the Washington, D.C. area, March 1 994. 



Uebtrman: The High Cost of Cool ''■8* ' ' 



258 



"ChemicaJ Manufacturers Association, Production. Sales, and Calculated Release ofCFC-llandCFC-l2 
Through 1988, Mclnnis, p 138, 1993 Statistical Panorama, /!//■ Co«J///onwg, Heating and Refrigeratior 
News, (March 29, 1993), at 24. 

""CFCs: The Challenge ofDoing Without", Electric Power Research Institute Journal, vol. 14. no 6(1989), 
p6 

" James M Calm, Charactersitc Efficiencies and Costs For Air-Conditioning Equipment With Selected 
Refrigerant Altematives{y\r^wii:. Air-Conditioning and Refrigeration Institute, 1991 ). 

" For example, air-cooled condensers on some retrofitted CFC-12 and R-502 condensing units are slightly 
undersized, and during periods of hot weather will lead to higher discharge pressures and greater energy use. 
Also, systems using non-CFC refrigerant blends require a fairly critical charge of refrigerant to maintain peak 
efficiency. Thus, even a small leak will significantly increase energy consumption, as compared to CFC 
systems where leakage had a smaller impaa on efficiency. Further, refrigerant cross-contamination may reduce 
energy eflSciency, particularly in commercial refrigeration systems. 

w'CFCs: The Challenge ofDoing Without," Electric Power Research Institute Journal, vol. 14, no. 6(1989), 

p. 10. 

" EPA, Moving to Alternative Refrigerants, November 1993; Alternative Fluorocarbons Environmental 
Acceptability Study and the US. Department of Energy, Energy and Global Warming Impacts of CFC 
Alternative Technologies (December 1991). 

"Ibid. 

•* American Automobile Manufacturers Association of the United States, Motor Vehicle Facts and Figures, 
annual; Montreal Protocol, Report of the Refrigeration, Air-Conditioning and Heat Pumps Technical Options 
Committee, (December 1991), Figure 10.1; 1993 Statistical Panorama, Air Conditioning, Heating and 
Refrigeration News (March 29, 1 993), p. 7. 

" Ward Atkinson, Sun Test Engineering. 

'» Clean Air Act Amendments of 1 990, Section 609. 

"Ibid. 

"Atkinson 

" 1993 Mobile Air-Conditioning Society. /wVi<E/5tfrvic«fZ)afti^oo/(;. 

« Ibid. 

" Many vehicle air-conditioning systems develop slow leaks, which cause the gradual loss of refrigerant Leakage 
frequently occurs through high and low side Schrader valves, by difiusion through aging and hardened hoses, and 
through the compressor shait seal. These minor leaks rarely damage the system, provided the pressure in the system 
remains above atmospheric, and merely necessitate the addition of a pound or two of refrigerant. However, now 
that a CFC recharge costs more, and future supplies are uncertain, some people may choose to have the leak 
repaired, although such a Job will probably cost S2S0 or more. Many servicemen, for obvious reasons, are 
encouraging customers to repair leaks rather than top off a system. Others, as a matter of policy, refuse to top oflF 



Page 18 Liebtrman: The High Cost of Cool 



259 



systemsunless leaks are repaired. Some are telling customers that federal law requires leak repairs, which is not 
the case 

** Montreal Protocol, Report of the Refrigeration, Air-Conditioning and Heat Pum ps Technical Options Committee, 
(December 1 99 1 ). p 1 73 (Some 1 992 and 1 993 CFC air-conditioners were designed to be easily retrofit to HFC- 
1 34a, and the cost will be lower For older cars, depending on the model and year, the retrofit costs range fr^om $250 
to $800) 

" HFC- 1 3 4a and the poly alky lene glycol (PAG) oil used with it cannot operate properly in a system which previously 
used CFC- 1 2 and mineral oil unless virtually all ofthe original refrigerant and lubricant is removed from the system. 
Mineral oil is not miscible with HFC- 1 34a and any any left behind will reduce heat transfer and interfere with fluid 
flow Residual CFC- 1 2 will combine with HFC- 1 34a to form an azeotrope, generating higher internal pressures. 
It can be expected that some retrofits will fail because the system was not thoroughly flushed. Further, HFC- 1 34a 
operates at a much higher discharge pressure, which will place a life-shonening strain on the system, particularly when 
stalled in traffic on hot days. 

** The low end of this range assumes that future servicing costs will be only slightly higher than current costs, while 
the high end assumes significant cost increases, particularly after 1 99S . 

'^Putnam, Hayes & Banlett, Inc., Report for the U.S. Department of Energy, Assessment ofthe Impacts 
Associated with a Total CFC Phaseout (My 10, 1989), p. 11. 

" The higher discharge pressures ofHFC- 1 34a will likely cause an increase in compressor failures. See "Race 
Against Time", Design News (October I, 1990). pp. 132-136. Further, the polyalkylene glycol (PAG) oil 
used as a lubricant is extremely hygroscopic (water attracting). See Tecumseh Products Company. Guidelines 
For Utilization of R 134a. Thus, ambient moisture may be drawn into a system during servicing or after a 
collision or other major leak, which can lead to system failure. Also, HFC- 1 34a, unlike CFC- 12, does not form 
wear-reducing metal chlorides See ARI Tech Update, Lubrication is The Key Issue in CFCPhaseout (August 
1 993 ) And. as with all new technologies that have not been thoroughly tested, there will likely be unforseen 
problems that develop after a few years of actual use. 

'* Several automotive engineers with major auto makers privately admit that they expect an increase in the 
number of vehicle air-conditioners needing a major repair to stay in operation, particularly after about five 
years of use. 

"Congressional Research Service, CFCPhaseout: Future ProblemforAir Conditioning Equipment? (April 
1, 1993). p5 

" The fact that HFC- 1 34a is the most widely used replacement refrigerant, despite its many drawbacks, is a 
consequence ofthe acceleration ofthe phaseout date from the year 2000 to the end of 1 995 Given the lead times 
needed by manu&cturers, many industries had to make hasty decisions as to which replacement to use. A number 
of other refrigerants are more promising than HFC- 1 34a but need a few more years of research and development 
before being ready for use. On the other hand, HFC- 1 34a was one ofthe first replacements developed and mass 
produced and was chosen largely because it was the best refrigerant available on such short notice. And, once an 
industry commits to a particular refrigerant, it is very expensive to switch to another. As a result, HFC- 1 34a-will 
likely see widespread use for many years, even in applications for which it is not ideally suited. 

""AGreenerWay to Keep FoodCool," Washington Po^t. Home Section(April 14, 1994), p. 5; lleftigerators 
For A Wiser Worid". Consumer Reports (February 1994), pp. 80-86. 



Uthtrman: The High Cost of Cool •*•«* ' ' 



260 



""1994 Statistical Panorama," Air Conditioning. Heating and Refrigeration News {\^n\ 1 1, 1994), p 32 

« Montreal Protocol, Report of the Refrigeration. Air Conditioning and Heat Pumps Technical Option'' 
Committee (Dtctmbtr 1991), p. 80. HFC- 134a is primarily a medium temperature refrigerant, and is not wci. 
suited for American refrigerators with a large freezer section, which operate at a coil temperature of about - 1 0* F 
At this low temperature, HFC- 134a may exhibit reduced capacity versus CFC-12. See Dupont, Retrofit 
Guidelinesfor Sifl'A li-ta in Stationary Equipment Some comparisons obfuscate the relative efficiencies by 
comparing an advanced design HFC- 1 34a model with a basic CFC- 1 2 model, or by using theoretical rather than 
actual efficiencies See EP\, Multiple Pathways to Super-Efficient Refrigerators Note that there may also be 
aslight decline in efficiency resulting from CFC-blown foam insulation used in refrigerator walls and doors being 
replaced by substitute foams. 

" The polyol ester (FOE) oil chosen to be used in HFC- 134a refrigerators is 1 00 times more hygroscopic than the 
mineral oil used with CFC- 1 2. IC for example, the system experiences a leak during mo ving or is left open for more 
than 1 S minutes during servicing, enough moisture can enter to cause chemical reaaions that may damage the 
compressor or block the capillary tubes, the latter requiring replacement of the entire hermetic system. In addition 
to moisture problems, HFC- 1 34a and POE oils have a low tolerance for other contaminants, (such as residual 
chlorine in servicing equipment that was also used to repair aCFC system). As a result, HFC- 1 34a refrigerators 
will suffer more frequent breakdowns, some of which cannot be repaired. See Whiripool Corp., HFC-I34a 
Refrigerant Service Procedures. 

'* The experience with CFC- 1 2 refrigerators when they were new may be repeated with the new HFC-1 34a units. 
The first models worked well initially, but suffered unexpected problems after several years of use. For example, 
the oil originally chosen broke down, causing capillary tube blockage, and a new oil with additives had to be 
developed. Also, theinsulationprotectingthemotorwindingswasweakenedbyunexpectedreactionsbetweenthe 
refrigerant, oil, and trace impurities, and had to be replaced with a new type ofinsulating material. These and othe 
technical problems were totally unanticipated when the systems were initially designed and tested. They revealed 
themselves only after years of field experience. The same is likely to occur with the new HFC- 1 34a systems. 

" 1993 Survey, Air-Conditioning and Refrigeration Institute. 

'•"1993 Statistical Panorama," Air Conditioning. HeatingandRefrigerationNews,Maxz\\29, 1993, pp. 6-7 

'* Alternative Fluorocarbons Environmental Acceptability Study and the US Department ofEnergy, Energy and 
Global Warming Impacts of CFC Alternative Technologies (December, 1991)ch.6and App. E. 

""SlowConversiontoNon-CFCsWorriesChillerManufacturers," AirConditioning. HeatingandRefiigera- 
tion News (April 12, 1993), p. 3. 

" Ibid. 

" S pecifically, refrigerant containment first requires a thorough inspection of the system for leaks, and replacement 
of any gaskets or connections that show signs of deterioration. Then, a high efficiency purge unit is installed, which 
allows the system to be periodically purged of air without refrigerant also escaping. Isolation valves are installed at 
the oil sump to reduce refrigerant leakage during oil changes. Pressurizing devices, which reduce leakage when the 
chiller is not in use, and safety relief valves which prevent total loss of charge in an emergency may also be necessary 
Older chillers may require eddy current testing of the condenser tubes in order to detect any weaknesses in them 
CFC monitoring devices may be installed to aid in early leak deteaion. Since some leakage will still occur, an extra 
supply of refrigerant needs to be obtained, and placed in a tank or drum suitable for long term storage. Refrigerant 
recovery devices will also be necessary for use during servicing. 



Page 20 Lelnrman: The High Cost of Cool 



261 



"CFC-I I chillers operate at sub-atmospheric pressures, thus not much refrigerant leaks out On the other hand, 
CFC- 1 2, CFC-22 and R-500 operate at pressures above atmospheric, and a line break, for example, could cause 
the entire refrigerant charge to escape. 

** Informal survey of three chiller cbnfrattors, March 1 994 (Actual cost is dependent on the size, age, and condition 
ofthe chiller and building.) 

** A retrofit of a high-pressure chiller involves modifications ofthe geardrive and impeller (in order to reduce the 
loss in capacity), and careful system flushing ofthe old refrigerant and oil. Finally, a charge ofHFC- 1 34a and 
compatible ester-based lubricant is added. Low-pressure chiller retrofits to HCFC- 123 require modifications of 
the motor and impeller, as well as replacement of motor windings, 0-rings, gaskets, and seals In both cases, 
refrigerant recovery equipment will have to be procured. 

•* Retrofit costs average $50 - $70 per ton, and chillers that are candidates for retrofit are in the 200 - 3000 ton 
range. The term ton refers to the amount of cooling required to freeze one ton of water in aday, or 1 2,000 Btu/hour, 
and isthe common unit for measuring cooling capacity. SeeEPA,A/ov;/»y to Alternative Refrigerants, TenCase 
Histories, (November 1993); "OneCompany's Strategy", Engineered Systems, (September 1993). 

*' Chiller owners who continue to use CFCs run the risk of needing additional CFCs at some fiiture date and not 
beingable to obtain it. Also, retrofits to HCFC- 1 23 and HFC- 1 34, consideringthe initial cost, expected useful life, 
and operating costs, may not be as attractive as a total replacement in some cases. In addition to new systems using 
HCFC- 1 23 or HFC 134a, HCFC-22 chillers using screw compressors are gaining market share because of their 
efficiency and versatility. 

" An Air-Conditioningand Refiigeratkin Institute survey of chillermanu&cturers estimates that 22,0OOCFC cMllera 
will have been replaced by non-CFC chillers by the year 1 996. 

""One Company 's Strategy," Engineered Sysiem% ( September 1 993 ). (Estimated cost of chiller replacement 
is $275 -$375 per ton.) 

" Strictly speaking, these new requirements are not a direct consequence ofthe CFC phaseout, and in fact are 
applicabletochillersthatuseCFCs. However, theirpromulgationoccurredasaresult of concemsoverthetoxicity 
of replacement refrigerants, particularly HCFC- 1 23 . 

"See "Taking The FearFactorOutofRefngerants." £n^/wer«>(/5v5leOTj(January 1994), pp. 42-47 (Most local 
building codes have not yet made these revisions, but are expected to make them v^thin the next two years. ) 

"Ibid 

" Informal survey of three chiller contractors, March, 1 994. 

" Sutement ofthe Air-Conditioning and Refrigeration Institute on Depletion ofthe Stratospheric Ozone Layer. 
January25, 1990. (Thisisaveryroughestimate, and islikdy too low, given thenumberofestablishmentsusingsuch 
equipment. Other estimates are lower, but exclude many categories of equipment. ) 

" Statistical Abstract ofthe UnitedStates 1993, "Retail Foodstores-Number and Sales, by Type: 1980 to 199 1," 
p. 777. 

^* Statistical Abstraflqf the UnitedStates, "Commercial and Institutional Groups-Food and Drink Sales: 1980 
to 1 993," p. 779. 



LubenHtm. The High Com o/Cool Page 21 



262 



" Statistical Abstract of the United States, "Retail Trade Establishments-Number, Sales, Payroll, and 
Employees, by Kind ofBusiness: 1 987," p. 775. 

" Some ofthis equipment, particulariy the smaller systems, will practice containment and continue using CFCs for 
as long as supplies are available. Nonetheless, it is assumed that most existing systems will be retrofit within the next 
ten years. 

" "Allied Signal's AZ-SO Alternate Refrigerant Well-Received By Texas Supermarket Chain", AirConditioning. 
Heating and Refrigeration News (January 24, 1994), p 76. A retrofit of a commercial refiigeration system 
involves removing the original CFC charge, replacing the filter drier, recharging the system with a new refiigerant and 
compatible oil (medium temperature refiigerant replacements include MP-3 3 , MP-3 9, MP-66, and HFC- 1 34a, 
while low temperature replacements include AZ-50, HP-62, HP-80, HP-8 1 , HFC- 1 25, and HCFC-22), and a 
check of the system for proper performance. A supermarket will require about 300 hours of labor, while a 
convenience store may require 30 hours or less. 

** Thus far, very few self-contained systems have been retrofit It is expected that their owners will continue to use 
CFCs until they are no longer available, and then retrofit or replace the equipment. Retrofit costs will probably be 
in the $200-5300 range. 

"58 Federal Register 60 1 5 8 . (Another HCFC, HCFC- 1 23 , is being used in many new and retrofit chillers, and 
is discussed in that section. Its production will be fi'ozen in 20 1 S and eliminated in 2030. ) 

" US Bureau of the Census, Current Housing Reports; Energy Information Administration, Commercial 
BuildingCharacteristics: 1 989, Table 86. (There are also about 50 million window air-conditioners, which are not 
significantly impacted by the phaseout. Large buildings are cooled by chillers, and are discussed separately.) 

" Informal survey of 5 residential air-conditioning servicemen in the Washington, DC. area, March 1 994. 

•*" 1994 Statistical Panorama." Air-Conditioning, Heating and Refrigeration News (April 11, 1994),pp.25- 

26. 

" Informalsurveyofthree wholesalers in the Washington, DC. area, March 1994 (The other half ofHCFC-22 
production is used chillers and commercial equipment and is discussed separately.) 

^ Had the phaseout not been accelerated fi-om 2000 to 1 995, the cost would have been about one quarter of this 
amount 



Page 22 Utbtrman: Thi High Cost of Cool 



263 

STATEMENT OF PROFESSOR RICHARD L. STROUP, SENIOR AS- 
SOCIATE, POUCY ECONOMY RESEARCH CENTER, BOZEMAN, 
MT 

Dr. Stroup. Thank you. I am an economist. My experience as di- 
rector of the Office of Policy Analysis of the Department of the In- 
terior for a few years in the early 1980s gives me some background 
here to make some observations. 

My job there, the job of the office I directed, was to give man- 
agers, decision-makers — ^the secretary, the assistant secretaries — 
the other side of the story. 

The Secretary and the Assistant Secretaries recognize that every 
agency, whether it's a pro-development agency like the Bureau of 
Mines or a preservationist agency like the U.S. Fish and Wildlife 
Service, or a scientific agency, like the U.S. Geological Survey, all 
agencies tend to cite facts, to cite data and to interpret data so as 
to enhance their budgets and so as to support the policy stands 
that they've already taken. 

I believe that the question before Congress is the following — is 
the evidence on CFC impacts on the ground sufficient to force some 
serious risks and some large costs onto the American public? 

To promote public health and to promote other environmental 
goals, we do w£int to avoid risks. And I believe that all policy 
choices available here, every one of them, involves risks. 

But also, we want to promote the development of citizen wealth 
and incomes because wealthier is healthier. 

I believe the accelerated ban harms this particular goal. 

The key question then is: Will the known costs and the added 
risks that we force onto Americans by banning CFCs rapidly, will 
those problems be counter-balanced, offset by the benefits of re- 
duced stratospheric ozone depletion? 

Ben Lieberman has detailed some, or he details in his written 
testimony some of the dollar costs. I might add that, as an econo- 
mist, it's pretty clearly obvious that you cannot lower the dollar 
cost to consumers by restricting their options. 

You cannot make it better for the dollar costs of consumers by 
taking away options from them. 

I want to show the basis for expecting risks, serious health risks, 
from the ban of CFCs, or the ban of any other widely-used chemical 
or material. 

I'll use the bans on asbestos use and the de facto bans on asbes- 
tos resulting from some very pessimistic interpretation of asbestos 
health risks relative to the assumed gEiins from using substitutes. 

And I want to cite a few sentences here from a case that was be- 
fore the 5th Circuit Court of Appeals. I want to cite a few sentences 
from the three-judge panel's opinion. 

The case is Corrosion-Proof Fittings v. EPA, 1991. 

The three judges in their opinion said the following: 

"We are concerned with the EPA's evaluation of substitutes, even 
in those instances in which the record shows that they are avail- 
able. The EPA explicitly rejects considering the harm that may 
flow from the increased use of products designed to substitute for 
asbestos, even when the probable substitutes are known carcino- 
gens." 

And then they go. 



264 

"Many of the substitutes that EPA itself concedes will be used 
in place of asbestos have known carcinogenic effects." 

And they go on. 

"Eager to douse the dangers of asbestos, the agency inadvert- 
ently actually may increase the risk of injuries Americans face." 

The court then references, "EPA's explicit failure to consider the 
toxicity of likely substitutes." 

One final sentence from the court here. 

"In short, a death is a death, whether occasioned by asbestos or 
by a toxic substitute product." 

I want to move now to another result, not a toxic result, but an- 
other result of the overemphasis of one risk relative to others. And 
that is, as some in this room know, the extremely pessimistic inter- 
pretation of asbestos science by advocates also led to the horribly 
tragic results of the Challenger tragedy. 

The maker of the asbestos-containing putty used to seal the O- 
rings of the Challenger stopped producing the putty because of the 
public asbestos scare and the fear of asbestos lawsuits, which were 
burgeoning at that time. They stopped producing the stuff. 

So a new putty had to be used. 

The new arrangement failed. The seven astronauts died a fiery 
death, traumatizing millions of us who saw the tragedy. 

There are arguments about whether NASA should have seen the 
problem and acted differently. But no one to my knowledge argues 
that the old 0-ring system with the original putty would have 
failed. 

I don't know of anyone that makes that argument, that it would 
have failed anyway. 

That 0-ring system, that old 0-ring system that was no longer 
available, like CFCs today, had a proven track record of safety and 
effectiveness. 

I believe that Ben Lieberman is right, that the monetary costs 
of quickly phasing out CFCs are large. Many alternatives have to 
be tested to discover which is the best for every application. 

When that has to be done quickly, it won't be done as thoroughly. 

Like asbestos, CFCs can certainly be replaced. But not without 
sacrificing many benefits, such as safe, cheap refrigeration, which 
increases food safety and has other advantages as well. 

As Dr. Robert Watson of NASA, who we heard from earlier this 
morning, has put it, and I quote here. He was quoted in 1988: "If 
we banned all CFCs tomorrow, probably more people would die 
from food poisoning than would die from ozone depletion." 

Fortunately, we did not ban it tomorrow. There have been tech- 
nological improvements since Dr. Watson said that. But a key 
trade-off remains — more costly equipment will be used more spar- 
ingly. Refrigerators will be smaller and fewer than they otherwise 
would have been had the CFCs and the technological change over 
time, too, been made available. 

By contrast, refrigerators that are less costly and require less en- 
ergy when they're used with equally advanced equipment using 
CFC substitutes, would allow more and larger refrigerators, provid- 
ing safer foods, causing less food poisoning, and in fact, less cancer 
as well. 



265 

Time is an important element in advancing technology. Reducing 
the time available before the substitutes have to be found and per- 
fected and made available to ordinary people is surely increasing 
the cost of the substitutes. 

Mr. ROHRABACHER. Time is also important in the hearing, Mr. 
Stroup. [Laughter.] 

Dr. Stroup. Okay. 

Mr. ROHRABACHER. If you would like to give a 30-second sum- 
mary, go right ahead. 

Dr. Stroup. All right. How much do we risk by reversing the ac- 
celeration of the CFC ban in the U.S.? 

I don't expect any agency or the head of any lab which is better 
financed when the public and the Congress strongly have a concern 
about this because that leads to better funding. 

I don't expect any scientist in that position to say, it is not a 
problem. 

I, and virtually every scientist, will say, it is a problem. It's only 
a question of how big a problem. I think the evidence is that, over- 
all, our children will thank us if we reverse the acceleration of this 
phase-out. 

[The complete prepared statement of Professor Stroup follows:] 



266 



Prepared Testimony of Richard L. Strou^ 3 
Before the Subcommittee oB ^pergy _and-Jhe'Enviroiunent 
of the House Committee on Science 
September 22, 1995 

Mr. Chairman and Committee members: I want to thanlc you for the opportunity to 
provide my views on the economics of policies regarding the accelerated U.S. phaseout of 
CFCs. I am an economist and have been applying economic analysis to environmental and 
natural resource questions since my participation in the 1960s, as an economics doctoral 
candidate, in the Air Resources Program at the University of Washington. My dissertation, on 
the economics of controlling sulfur dioxide emissions, was written under the sponsorship of 
that program. Since that time I have been researching, writing and teaching about 
environmental and natural resource issues as an economics professor at Montana State 
University and as a senior associate of the Political Economy Research Center. Under the 
Intergovernmental Personnel Act, I also served for two and a half years as Director, Office of 
Policy Analysis, at the U.S. Department of the Interior. 

Cost of the Accelerated Phaseout of CFCs 

A number of costs will be imposed by the accelerated phaseout of CFCs. Some of them 
have been estimated. The phaseout is intended to provide benefits, of course, in the form ot 
decreased depletion of stratospheric ozone. The existence of some benefit, in the form of 
reduced destruction of stratospheric ozone seems clear, although the size and importance of 
that benefit is very much in question by scientists and others, due to the uncertainty of the 
impact of CFCs on the complicated chemistry of the ozone, and on the UVB reaching the 
earth's surface. Large costs due to the phaseout seem unavoidable, although here again there 
are serious questions about just how large they will be. Cost estimates of certain cost 
components are available. The most comprehensive cost estimates are, I believe, those of Mr. 
Ben Lieberman, who is with us today. However, these and other estimates must, of necessity, 
be based on assumptions about technological innovations that are still being tested, and m 
some cases innovations that are still being researched. These dollar figures cannot and do not 
claim to give the fiill picture. In my remarks, I would like to share with you some 
considerations that should be included in the analysis of how science is used in policies that 
phaseout the manufacture and use of CFCs. 

Proper decisionmaking requires fully and impartially examining both the gains claimed 
for any policy option, and the sacrifices imposed by that policy. It is important to recognize 
that those sacrifices will be real. Even when they are expressed as expenditures of dollars, the 
dollar figures represent real sacrifices and real harms to people. Among these are health risks 
imposed by the accelerated phaseout of CFCs. 

Costs Are Not Just Monetary Costs 

The monetary costs of quickly phasing out CFCs are large. Many alternatives must be 
tested to discover which is best for each application. Currently, due to the accelerated 
phaseout, different refrigerants are being used to replace CFCs in various uses. To avoid 
mixing these substitutes, separate facilities must be built and maintained, and it is important 

1 



267 



that refrigerants must not, for technical reasons, be accidently mixed. Yet mistakes are made 
despite the expense of the separate facilities. If there were more time for detailed testing in 
laboratories, these compounds would be more extensively tested before being used in the field, 
so that fewer of them would be "field tested" to the extent that they are. As a result, fewer 
problems would probably occur. This and other problems increase the likelihood that mistakes 
will affect efficiency, cost and even the safety of those working with and near the refiigerants. 

But there are other harms likely to be done as well. CFCs can be replaced, but we will 
sacrifice their many benefits, such as safe, cheap refrigeration, which increases food safety 
and has other advantages. The accelerated phaseout of CFCs is increasing cost and thus, for 
many people, reducing availability. Dr. Robert T. Watson, of NASA, has put it, "If we 
banned all CFCs tomorrow, probably more people would die from food poisoning than would 
die from depleting ozone."' Of course some technological improvements have been made 
since Dr. Watson said this, but the key tradeoff remains: more costly equipment will be used 
more sparingly. 

By contrast refrigerators that are less costly and require less energy than those with 
equally advanced equipment using CFC substitutes, would allow more and larger refrigerators, 
providing safer foods and causing less food poisoning and less cancer.^ While technological 
advances in refiigeration equipment are continuing, as they would if CFC use were not being 
phased out, we should not attribute most of the advances we see in refrigeration technology to 
the CFC ban. Many would occur without the ban. To allow CFC use for a longer period 
would almost surely make refrigeration cheaper than it will be with the accelerated phaseouL 
Time is an important element in advancing technology; reducing the tinte available before 
substitutes must be found and perfected is surely increasing the cost of those substitutes. 

In contrast, allowing more time would reduce the costs of the changeovCT. Making 
more time available would also decrease the likelihood of costly mistakes, safety hazards and 
failures. The artificial speedup means that replacements and the equipment needed for them 
are less fiilly researched before decisions must be made; and they are less fiilly tested before 
they come into use. Our knowledge of their safety is unnecessarily limited under this policy. 

The Presumed Benefits of Technology Forcing 

It is often claimed that benefits from policies such as the rsq)id phaseout of CFCs wiU 
bring important advantages by forcing industry into technological improvements. New 
technologies to reduce the problems of chemically less stable replacements fnr the forbidden 
CFCs will surdy appear, and they may even provide spinoff boiefits. But that is likely to be 
true of any K&D expenditures; and if R&D projects could be chosen to address a wider array 
of goals rather than being forced by law into mitigating the problems from rq>Iacing CFCs 
very rapidly (and thus in a more costly fashion), we should expect greater total benefits. Only 
if there woe severe costs brought on by the failure to accelerate the replacement, and thus 
avoided by rapid replacement, would the shift of resources to the accelerated replacement be 
likely to provide superior returns to the forced investment. 

Potential Environmental Problems from Accelerated Phaseout of CFCs 

New chemical products that will escape into the atmosphere, especially when they are 
adopted r^idly, pose a potential threat to the environment. Replacements for CFCs are no 



268 



exception. T. K. Tromp and his colleagues, writing recently in Nature, the prestigious British 
journal of science, pointed out the potential problem of three of the proposed replacement 
compounds, theorizing that the breakdown products from those substitutes might become 
concentrated in certain wetlands. The breakdown products, if concentrated, can harm certain 
sensitive species. The concentration problem is theoretical rather than actual and measured at 
this point, but then so is the problem of increased UVB reaching the surface of the earth due 
to CFCs. Neither danger may in fact be serious, but the costs of replacing CFCs are much 
more likely than the simply theoretical costs of not doing so. In addition, the danger from 
reversing the acceleration, and phasing out the use of CFCs over, say, 4 additional years, 
should be quite small. 

Business Support for the Accelerated Phaseout of CFCs 

Despite the meager health benefits that may be gained by accelerating the CFC 
phaseout, and the ^parent high cost of the phaseout, which may include sonw theoretical 
problems such as the concentration in nature of chemical breakdown products from 
replacements, the acceleration policy will receive some prominent support. That support will 
in part come from businesses that provide (or will try to provide) substitutes for CFCs. Such 
businesses can be expected to support the rs^id phaseout of CFCs for the same reason that 
suppliers to the military support larger budgets to procure the products they make, and 
highway construction firms support larger highway constniction budgets. Supplien of CFC 
substitutes, like suppliers to the military and to the highway program, want to increase the 
demand for their products, and to increase it as soon as possible. They are investing in 
providing the new products, and they will gain more profits if demand tot their products is 
stimulated more, and earlier, by the accelerated phaseout. 

Mistaking Costs for Benefits 

Costs of programs such as the accelerated CFC phaseout are sometimes viewed, 
falsely, as benefits to society. The argument made is that demand for new equipment due to 
the policy will spur the economy, and that jobs are created by the need to scrq) functioning 
refrigeration or air conditioning units, for example. But this is very much like viewing a 
terrible hurricane as a generator of benefits because it creates a huge demand for rebuilding 
what the hurricane has destroyed. Similarly, considering this production and these jobs as a 
benefit of the program requiring that economical, working equipment be replaced, is simply 
wrong. Any net benefits accruing to society firom replacing CFCs more quickly will come 
from reducing the harmful effects of CFCs, not from the increased demand. Forcing users to 
replace economical, functioning equipment with new equipment to meet the law is, in itself, a 
cost to be borne, not a benefit. 

Wealthier Is Healthier and More Environmentally Sound 

Here, as in all of environmental policy, it is important to recognize the importance of 
income and wealth, in providing our society with both the willingness and the ability to make 
sacrifices for a better environment. Poorer people are usually willing to settle for lower 
environmental quality, just as they must settle for lower quality food, housing and clothing. To 
reduce ozone depletion from CFCs on an accelerated basis will impose sacrifices of income 



269 



and wealth, as these are usually measured. 

Richer nations-those having experienced significant economic growth-are 
environmentally cleaner and more healthful than are poor nations.' There are at least two 
reasons for this: First, to become richer, societies develop technological tools that use 
resources more efficiently and thus place less stress on the natural environment, per unit of 
output. Second, people who have met their most basic needs and do not need to worry about 
where the next meal will come from will demand a better environment and can afford it, just 
as they demand better food, shelter and medical care. Results from one study suggest that 
when community income rises by one percent, community demand for environmental quality 
rises by three times that amount. In other words, the demand for environmental quality rises 
with income at about the same rate as does the demand for BMWs!* 

The correlation between income and environmental quality will not surprise anyone 
who knows that the memben of environmental groups such as the Sierra Club have incomes 
that, on average, are double those of the average American.' Any policy that reduces a 
nation's income will reduce its willingness and ability to pay (in economists' lingo, its 
demand) for environmental quality. Policies that promote economic growth will leskd to better 
environmental quality. 

Reasonable estimates of costs for the accelerated phaseout of CFCs run into the tens of 
billions of dollars. The impact of this goes beyond the creature comforts and market goods 
that we normally consider, and even beyond environmental goods and services: wealth and 
efficiency are among the most important risk-reducing and health-enhancing factors in all 
societies. Such a policy is good on balance for the environment only if it brings siihstantial 
benefits to offset the resulting reduction in demand for other environmental programs. 

It is important to recognize that economic growth does not £avor only those whose 
personal incomes rise. That is, it isn't just individually affluent people who benefit from a 
society's wealth and economic efficiency. Any person, whether rich or poOT, is much better 
off to be caught in a disaster such as a flood or an earthquake in a rich country than in a poor 
one. A rich nation can protect itself better against foreseen dangers and unforeseen 
developments as well.^ To the extent that nations (and humans generally) have the advantages 
that come from societal wealth, they have by far the best hope to avert ot survive crises from 
threats of almost any imaginable risk, firom a large meteor on a collision course with Earth to 
a new and niore virulent form of AIDS. Richer societies are more resilient. If 'insurance' 
against a particular risk, such as some increase in the threat of increased UVB reaching the 
earth, is bought at the cost of reduced economic growth, then a decline in the automatic 
insurance represented by wealth, and the societal resilience it provides, is one of the costs 
borne by future generations. It is a cost that might be worth bearing, but surely not without 
careful consideration. 

Inquiries like this hearing, into the application of science as applied to regulatory 
policy, are conducted for good reason. The pressures and incentives facing political and 
bureaucratic decisionmakers help to explain regulatory inefficiency. Efficiency, after all, has 
no political constituency. Each important political group naturally seeks advantage for itself 
and for its point of view firom the political system. The political system cannot operate 
efficiently when doing so gets in the way of powerful interest groups or populist passions. 
Unfortunately, an agency estimating the costs and benefits of its proposed regulations tend to 



270 



bias the results to support the policy of the agency. That is, any agency has what Justice 
Stephen Breyer calls "tunnel vision.* It readily sees the benefits of what it has set out to do, 
but seldom sees the full costs of that chosen course of actions when others can be made to 
bear those costs. 

The accelerated phaseout of CFCs is, in my view, a very costly policy. The tendency 
to ignore or understate costs causes inappropriate optimism about the ease of replacing CFCs 
on an accelerated basis. I am confident that our children will, in all likelihood, thank us if this 
policy is reversed. 

ENDNOTES 

1. Watson was quoted by Alston Chase, in Chase's column in Outside magazine March, 
1988. 

2. In addition to reduced food poisoning, for example, cancer of the stomach was reduced by 
the availability of home refrigeration, according to Howson, et al., in 'The Decline in 
Gastric Cancer ^idemiology of an Unplanned Triumph,* in Epidemologic Reviews, Vol. 8, 
(1986), p. 2. 

3. See World Bank economist Marian Radetzke's, 'Economic Growth and Environment,* 
presented at a World Bank Symposium November 21-22, 1991, for a review of the evidence 
and reasons why the relationship between economic growth and environmental quality tends 
to be positive. 

4. These results were reported by Donald Coursey, economist at the University of Chicago, 
in *The Demand for Environmental Quality,* a paper presented January 1993 at the annual 
meeting of the American Economic Association in Anaheim, CA and in private conversations 
since that time. 

5. A 1986 survey of readers of the Sierra Club magazine indicated that the median household 
income was $46,100, compared with median household income in the U.S. of $23,618. A 
full 83% had graduated firom college, while among Americans as a whole, 19.4% had 
completed four or more years of college in 1983. (Sierra Qub majgazine data provided by the 
Sierra Club, 530 Bush St, San Francisco, CA 94108.) 

6. Perhaps the best comprehensive treatment of this general topic was presented by the late 
Aaron Wildavsky in Searching for Sitfety (New Brunswick: Transaction Press, 1988), 
especially in Ch. 3. 



271 

Mr. ROHRABACHER. Thank you, Mr. Stroup. 
I know it's very difficult for an economist. 
Dr. Stroup. And a professor, too. 

Mr. ROHRABACHER. And a professor, too. But I will refrain from 
a joke about laying economists head to head, and I'll just refrain. 
Dr. Stroup. Thank you, sir. [Laughter.] 
Mr. ROHRABACHER. Dr. Pollet. 

STATEMENT OF DR. DALE K. POLLET, PROJECT LEADER, EN- 
TOMOLOGY, LOUISLVNA COOPERATIVE EXTENSION SERV- 
ICE, BATON ROUGE, LA 

Dr. Pollet. Mr. Chairman, Members of the Subcommittee, my 
name is Dale Pollet and I am entomology project leader for the 
Louisiana Cooperative Extension Service. 

My full credentials are part of the written record submitted to 
the Committee. 

You have asked that I address the economic impacts of the 
phase-out of methyl bromide. Attached to my written statement are 
various references, well-accepted economic analyses. They consist- 
ently show the loss of methyl bromide will severely impact Amer- 
ican farming and food production. 

American farmers depend on methyl bromide to grow, store, 
transport, and process more than 100 vegetables, fruits, grains and 
fiber. 

Mr. Chairman, in your State of California, the phase-out will se- 
verely harm the production of grapes, strawberries, carrots, wal- 
nuts, pecans, cherries and other berries, rice, citrus, tomatoes, pep- 
pers, plums and melons. 

If the ban takes effect, California's fast-growing agricultural ex- 
port business will come to a stop since Japan and other major mar- 
kets require that imported produce must be fumigated with methyl 
bromide. 

The ports of Los Angeles, San Diego and Oakland will lose sub- 
stantial revenues. Methyl bromide is also used in the ports of New 
Orleans and Baton Rouge to fumigate cut flowers, grains, vegeta- 
bles, propagative plant material, lumber, and lumber products. 

Oakland's American Presidents Line reports that it alone would 
lose $50 million in revenues annually. Introduction of a new de- 
structive pest into California would cost farmers in that state $1.2 
billion and would affect 14,000 jobs. 

Methyl bromide currently prevents that from happening. 

Louisiana would not do much better. Our rice mills depend on 
methyl bromide to meet Food and Drug Administration cleanliness 
standards. Louisiana strawberry growers — a $10.7 million indus- 
try — will suffer immeasurably, as will the tree nurseries and our 
reforestation efforts. 

Members of the Subcommittee, the phase-out of methyl bromide 
will hurt agriculture in the northwest and the southeast, the grain- 
producing states — California, Florida, Michigan, New York and 
Texas. 

Narrowly stated, in terms of jobs and income, the economic im- 
pact of the U.S. phase-out will be significant. 

For example, the U.S. Department of Agriculture studied just 21 
crops in five states and projected $1.5 billion in direct economic 



272 

losses. But dollars do not begin to describe the impact of America's 
pending loss of methyl bromide. 

The loss of methyl bromide will contribute to the slow but clear 
loss of American food production independence. For more than a 
decade, American growers have been moving their operations to 
Chile, Mexico and other nations which respect and encourage farm- 
ing. Many American farmers simply will not be able to compete in 
the U.S. market or any other without methyl bromide — and not one 
other agricultural exporting nation plans to ban methyl bromide. 

Our problem is no one here has ever been hungry and we take 
agriculture for granted. 

Food is as close as the nearest store. 

Mr. ROHRABACHER. Dr. PoUet, do you have any overall estimate 
as to the cost to agriculture if this was banned? 

Dr. POLLET. To the family? 

Mr. ROHRABACHER. No, no. Just the cost, overall, in the billions 
of dollars. 

Dr. PoLLET. Well, just using the information that we had, the 
cost from just those five states on those 21 commodities was a bil- 
lion and a half dollars. 

Mr. ROHRABACHER. Billion and a half dollars. 

Dr. POLLET. To supplement that, you'd probably have to multiply 
that number several times over to get anywhere close to what it 
would be. 

Mr. ROHRABACHER. Okay. Well, that's substantial. Proceed. 

Dr. PoLLET. The loss of methyl bromide will affect American nu- 
trition at a time when our own government urges us to eat five 
fresh fruits and vegetables daily as a means of preventing cancer 
and heart and circulatory disease. 

Most farmers are lucky to make a profit a few times a decade. 
The loss of methyl bromide does not simply mean lower yields. It 
means fewer farmers with lower jdelds, higher prices, reduced 
quality, and a decreasing likelihood that Americans will eat right. 

The loss of methyl bromide will affect America's ability to fight 
world hunger. The government of India — at a recent meeting of the 
nations participating in the Montreal Protocol — said that the loss 
of methyl bromide will seriously affect food storage. 

The government of Kenya warns of food riots if methyl bromide 
is banned. 

Ironically, Mr. Chairman, the loss of methyl bromide will have 
some negative impacts on the environment. I already have men- 
tioned that reforestation may be harmed by this phase-out. But po- 
tentially more damaging would be agriculture's return to several 
liquid and solid chemical pesticides which could upset existing IPM 
programs which have reduced pesticide usage. 

Removal of methyl bromide would therefore be in opposition to 
the President's program to reduce pesticide usage and would in- 
crease pressure on environmental and water quality controls and 
worker safety. 

I say potentially more damaging because EPA already has 
banned or severely limited the use of all of these chemicals and will 
not guarantee that any will be available after the January 1, 2001, 
phase-out of methyl bromide. 



273 

Farmers simply do not have true alternatives to methyl bromide 
at present and if something new is developed now, it would require 
ten-plus years and $50 to $100 million to get it through the re- 
quired process before it would be available to the agricultural com- 
munity if it passes all the tests. 

There is no such alternative on the horizon. 

Therefore, let us assume that there are no uncertainties about 
methyl bromide's impact on the ozone layer. Will the most optimis- 
tic environmental benefits be greater than the damage we will 
cause with this phase-out? 

Then let us assume, as so many others have concluded, that we 
don't know if a phase-out of methyl bromide will have any impact 
on the ozone layer. Are we recklessly destroying American agri- 
culture with this phase-out? 

I end my statement with that question, but would be pleased to 
answer the Subcommittee's questions. 

[The complete prepared statement of Dr. PoUet follows:] 



274 



^^A^^ Louiilina Stale University 

Ll^*%J Agricultural Center 

^-» "^-^ Louisiana Cooperative Extension Service 



Mailing Addrass P Boi 25100 
Baton Rouge LA 70884-5100 

Oflica: KnappHag 

(504) 386-4141 

Fax: (504) 388-2478 



INFORMATION PROVIDED BY: 

/^ DR. DALE K. POU^IySPEClAUST 
V.^^ KNTOMOLOey PROJECT 
LA CX>OPERATIVE EXTENSION SERVICE 
BATON ROUGE, LA 



, A SMI* nvtiwr in M* CaopaoKw Enaralen ^aMm 



275 



Hearing before the Subcommittee on Energy and Environment 

Committee on Science 

United States House of Representatives 

Wednesday. September 20. 199S 

Statement of Dale Pollet, Ph.D. 

Project Leader, Entomology 

Louisiana Cooperative Extension Service 



Mr. Chairman, Congressman Hayes, Members of the Subcommittee, my name is Dale Pollet. 
I am entomology project leader for the Louisiana Cooperative Extension Service. My full 
credentials are part of the written record submitted to the subcommittee. 

You have asked that I address the economic impacts of the phaseout of methyl bromide. 
Attached to my written statement are various well-accepted economic analyses. They 
consistently show that the loss of methyl bromide will severely impact American farming and 
food production. 

American farmers depend on methyl bromide to grow, store, transport and process more 
than 100 vegetables, fruits, grains and fiber. 

Mr. Chairman, in your state of California, the phaseout will severely harm the production 
of grapes, strawberries, carrots, walnuts, pecans, cherries and other berries, rice, citrus, 
tomatoes, peppers, plums and melons. 

If the ban takes effect, California's fast growing agricultural export business will come to a 
stop since Japan and other major markets reqtiire that imported produce must be fumigated 
with methyl bromide. The Ports of Los Angeles, San Diego and Oakland will lose 
substantial revenues. Methyl bromide is also used in the ports of New Orleans and Baton 
Rouge to fumigate cut flowers, grains, vegetables, propagative plant material, lumber and 
lumber products. Oakland's American Presidents Line reports that it alone will lose $50 
million in revenues annually. Introduction of a new destructive pest into California would 
cost farmers in that state $12 billion and would affect 14,000 jobs. Methyl bromide 
currently prevents that from happening. 

Congressman Hayes, Louisiana will not do much better. Our rice mills depend on methyl 
bromide to meet Food and Drug Administration cleanliness standards. Louisiana strawberry 



276 



growers ($10.7 million industiy) will suffer immeasurably as will tree niu^ries and our 
reforestation efforts. 

Members of the Subcommittee, the pbaseout of methyl bromide will hurt agriculture in the 
Northwest and Southeast, the grain-producing states, California, Florida, Michigan, New 
York and Texas. Narrowly stated in terms of jobs and income, the economic impact of the 
U.S. phaseout will be significant For example, the U.S. Department of Agriculture studied 
just 21 aops in five states and projected $1.5 billion in direct economic losses. But, dollars 
do not begin to describe the impact of America's pending loss of methyl bromide. 

• The loss of methyl bromide will contribute to the slow but clear loss 
of American food production independence. For more than a decade, 
American growers have been moving their operations to Chile, Mexico 
and other nations which respect and encourage farming. Many 
American farmers simply will not be able to compete in the U.S. 
market or any other without methyl bromide - and not one other 
agricultural exporting nation plans to bein methyl bromide. Our 
problem is no one here has ever been hungry, and we take agriculture 
for granted. Food is as close as the nearest store. 

• The loss of methyl bromide will affect American nutrition at a time 
when our own government urges us to eat five fresh finiits and 
vegetables daily as a means of preventing cancer and heart and 
circulatory disease. Most fanners are lucky to make a profit a few 
times a decade. The loss of methyl bromide does not simply mean 
lower yields. It means fewer farmers with lower yields, higher prices, 
reduced quality, and a decreasing likelihood that Americans will eat 
right 

• The loss of methyl bromide will affect America's ability to fight world 
hunger. The government of India - at a recent meeting of the nations 
participating in the Montreal Protocol - said that the loss of methyl 
bromide will seriously affect food storage. The government of Kenya 
warns of "Yood riots" if methyl bromide is banned. 



277 



• Ironically, Mr. Chairman, the loss of methyl bromide will have some 
negative impacts on the environment. I already have mentioned that 
reforestation will be harmed by this phaseout. But, potentially more 
damaging would be agriculture's return to several liquid and solid 
chemical pesticides which could upset existing EPM programs which 
have reduced pesticide usage. Removal of methyl bromide would 
therefore be in opposition to the president's program to reduced 
pesticide usage and would increase pressure on enviroiunental and 
water quality controls and worker safety. 

I say "^tentially" more damaging, because EPA already has banned 
or severely limited the use of all of these chemicals, and will not 
guarantee that any will be available after the January 1, 2001 phaseout 
of methyl bromide. Farmers simply do not have true alternatives to 
methyl bromide at present and if something is developed now, it would 
require 10 plus years and $50 to $100 million to get through the 
required process before it would be available to the agricultural 
community if it passes all tests. There is no such alternative on the 
borizen. 

Therefore, let us assume that there are no uncertainties about methyl bromide's impact on. 
the ozone layer. Will the most optimistic environmental benefits be greater than the 
damage we will cause with this phaseout? 

Then let us assume - as so many others have concluded - that we don't know if a phaseout 
of methyl bromide will have any impact on the ozone layer. \re we recklessly destroying 
American agriculture with this phaseout? 

I end my statement with that question but would be pleased to answer the Subcommittee's 
questions. 



278 



REFERENCES 

1. The Biological & Economic Assessment of Methyl Bromide 

by The National Agricultural Pesticide Impact Assessment Program 

2. Comparing the Benefits and Cost of EPA's Proposed Phaseout of Methyl Bromide 

Dudley, S. and Mannix, B. - Methyl Bromide Working Group 

3. California Agriculture July - August 1995 - Vol. 49 Number 4 

4. Monitor Vol. 1 No. 1 Spring/Summer '94 

5. IFC Newsletter Bulletin 30 August 1995. Great News for Methyl Bromide 

6. Methyl Bromide Working Group 

7. American Forest and Paper Association - AFPA Final Comments 

on EPA's Proposed Rule to Phaseout Methyl Bromide 



1. James Sargent - Great Lakes Chemical Company, West Lafayette, Indiana 

2. Charles Welchel - USDA, APHIS, New Orleans, LA 

3. Jeny Bartlett - Degesch, Reserve, LA 

4. Doug Curtis - Hendrix and Dail, Greenville, NC 

5. John Pyzner - LA Cooi)erative Extension Service, Calhoun, LA 

6. James Boudreaux - LA Cooperative Extension Service, Baton Rouge, LA 

7. Tad Hardy - LA Department of Agriculture & Forestry, Baton Rouge, LA 
9. Dalton Monceau - The Industrial Fumigant Company, Jennings LA 

10. Lynn Mayes - The Industrial Fumigant Company, Olathe, KS 

11. Allen Fugler - LA Pest Control Association, Baton Rouge, LA 



279 

Mr. ROHRABACHER. Thank you very much. Interestingly enough, 
my district has very few farmers. But one was visiting my office 
just the other day, a young man who runs a strawberry farm. 

He brought his issue up, independent, not knowing that I was in- 
volved in this hearing whatsoever, and just told me how devastat- 
ing this was going to be to his personal and his family income and 
to his business in general. 

We have a vote on, as you can tell. I think what we will do is 
I will call a recess and I will come back, and when we come back, 
that will be the last recess we take and we will go into some ques- 
tions and get this hearing done with. 

And let me just say, I think that this has been a fantastic panel. 
I think already you've really raised some important questions and 
I want to see some discussion between you and hopefully, I'll go 
vote and we can come back and have that discussion. 

So I thank each and every one of you. I'm sorry for making you 
wait another 10 minutes. 

We are recessed for 10 minutes. 

[Recess.] 

Mr. ROHRABACHER. The Subcommittee will reconvene. 

First of all, let me say for everyone to hear, I remember, and I'm 
not going to go through some of the things that I've remembered 
in other hearings and everybody is sick and tired of hearing these 
memories that I've got of horror stories that didn't turn out to be 
true, whether we're talking about the ozone hole or these other 
things. 

I do remember one, however, when I was in my younger years, 
when they banned cyclamates. 

Do you all remember cyclamates? 

Now I will hope that the panel will correct me if I am wrong, if 
my memory has some sort of ozone holes in it. [Laughter.] 

But that about a year or two ago, they decided that they were 
wrong about cyclamates and that cyclamates actually weren't the 
health threat. 

And what had happened was the American industry put hun- 
dreds of millions of dollars into developing this, basically a means 
of having a diet drink and helping people's health, by the fact that 
they could drink a cola and have less calories and thus, build up 
less fat or whatever, from drinking cola. 

And then, all of a sudden, the FDA decided — and there was some 
evidence that would indicate that there was going to be a health 
threat. Cyclamates were banned, but cyclamates were never 
banned in Canada. 

And so, when they came back, what we saw out of this was not 
something that made us any better, but instead, we saw about a 
billion dollars' worth of wealth evaporate from our society. And our 
economist friend there understands that when you do things like 
that, that actually means that people are not as well off. 

People's lives, people don't eat as well because of things like this. 
They don't live at a higher standard of living. There's an anxiety 
level among poor people who might be a notch or two higher in the 
economic order if we didn't waste that kind of money. 

And when you waste money like this in a society, there are 
health implications to wasting the money in the first place. 



280 

And what we are looking at now, and one of the things that we 
want to focus in on with this panel, is whether or not the benefits 
in terms of, number one, we've talked about the risks in the first 
panel, but what are the costs and the benefits of what has been, 
of the solution that we've heard in terms of banning CFCs? 

Let me first say that I — and I repeat this for the third time in 
the hearing — I am not impressed with lists of people, these are all 
the guys that agree with me, and look how little the list is for the 
people who disagree with me, and thus, my arguments hold more 
water. 

That doesn't go with me at all because I have, in my life, been 
a single voice on several issues and after a few years, finding that 
everybody agreed with me after a few years, when in the begin- 
ning, nobody agreed with me. 

What counts are the arguments on your side, do they withstand 
scrutiny and do they withstand the challenge of someone else's po- 
sition? 

I'd like to ask Ambassador Nichols, basically today — ^Adminis- 
trator, not Ambassador. Excuse me. 

Ms. Nichols. I appreciate the promotion. 

Mr. ROHRABACHER. That's all right. [Laughter.] 

You had stated in your testimony on August 1st, before the Com- 
merce Committee, that your cost/benefit analysis was 1000 to 1 
ratio and today you seem to testify that it was 700 to 1 cost/benefit 
ratio. 

And some of my staff who read your former testimony as well as 
your current testimony sort of picked that up. We were kind of 
wondering what happened in between there? 

Ms. Nichols. I went back, actually, and asked the staff — I think 
I may have mentioned this in my earlier summary of the testi- 
mony — to give a more conservative estimate based on not including 
the information about the melanoma cancers versus the 
nonmelanoma cancers because, as you heard from the medical wit- 
nesses earlier, although there's a pretty strong correlation between 
the radiation and the melanoma cancers, there's a question mark 
about exactly what level of exposure causes what amount of cancer 
risk. 

And so, I simply decided to exclude that data and come up with 
a lower number. 

Mr. ROHRABACHER. That's a very good answer. 

Now we've talked a little bit in the hearing about the growing 
black market production of CFCs, especially in China and India, 
and possibly Russia. But also, I might add, I come from California 
and people are talking about that now in terms of being a major 
Mexican export to the United States, just like some other products 
that are illegal. 

So what is the actual benefit? If we end up with a black market 
in these things, what's the actual benefit? Isn't the damage that's 
being done to our economy and the fact that we're paying so much 
more, the fact that it's going into a black market rather than a 
market where people are pajdng taxes and it's being done above 
the board? 

What is the offset on this? 



281 

Ms. Nichols. Let me just make one comment. I think Mr. Fay 
would also like to say something, if that's all right. 

Mr. ROHRABACHER. That's fine. 

Ms. Nichols. I just wanted to say that I had an opportunity to 
actually visit China for the Administration as part of the signing 
of a research agreement. 

And while I was there, I visited the ministry in China that has 
control over their CFC production and actually was shown the CFC 
factory that they used to have that has now been shut down in 
compliance with the Montreal Protocol. 

It's true that the rest of the world is lagging behind the U.S. in 
the phase-down. The developing countries were given an extra ten 
years before they had to completely get out of the business of pro- 
duction. 

But if you look at the growing market in China for refrigerators, 
which is the appliance that everybody buys — the minute they get 
a TV set and get a little extra money, they get a home refrigerator 
so that they don't have to go to the market every day. 

The refrigerators that they are now bujdng because of the Mon- 
treal Protocol are CFC-free refrigerators and they're more energy- 
efficient. 

So that, in the long run, this is helping the global situation. 

Mr. RoHRABACHER. Does anyone on the panel have anything that 
is contrary to that one thing about China? 

Mr. LiEBERMAN. I do know that there was one Chinese official 
who was threatening to build 100 more CFC facilities recently un- 
less they get more money. 

Mr. Fay. Let me add to that. 

There's been a lot of misinformation about the developing coun- 
tries. 

China just announced last week that they are accelerating their 
phase-out. They're not legally required to phase out. They're al- 
lowed to grow under the treaty. That's designed because of their 
tremendous needs for the population. 

But they have announced their goal just last week of accelerating 
the phase-out to the year 2005. 

Russia is not in compliance with the protocol. I can tell you that 
very frankly. Russia has announced they are closing down all of 
their factories, with the exception of one, which will continue to 
manufacture, and we think that the Russian production is the larg- 
est source of black market material in the United States right now. 

Mr. RoHRABACHER. But they've announced they're closing. 

Right? 

Mr. Fay. They have announced they're closing. 

Mr. ROHRABACHER. Announcements in tours are very impressive. 

Mr. Fay. Well, it's very difficult to get anybody's attention in 
Russia on anything right now. And closing CFC plants, surpris- 
ingly, is pretty high on their priority list, but it's not right up 
there. 

Mr. ROHRABACHER. Mr. Fay, do you believe that the black mar- 
ket problem in CFCs is going to decrease, then? 

Mr. Fay. As soon as the Congress eliminates the excise tax, yes, 
sir, I do, because that is what's creating the black market, is the 
$5.35 tax on the compounds. 



282 

It's equivalent of a $10-per-gallon gasoline. 

Mr. ROHRABACHER. Well, let's move to the Administration. 

Will you be supporting this? 

Ms. Nichols. I don't think I'm authorized to have a position on 
that issue. 

Mr. RoHRABACHER. Is the Administration considering supporting 
the elimination of CFC taxes? 

Ms. Nichols. I'm not aware of £iny such request that's been 
forthcoming that I've seen. 

I would note, however, for the record, that the proceeds of that 
tax do not come to the EPA budget. 

Mr. Fay. Mr. Chairman, I would, note as you well recognize, the 
tax bills originate in the House. This tax proposal originated with 
the Reagan Administration. 

Whatever we want to do with it, we'll be happy to work with you 
and anyone else who would consider restructuring the tax, either 
so that it is to be used for the issue from which you're taking the 
money, or at least capping it so that it doesn't continue to grow. 

Mr. RoHRABACHER. Did the Reagan Administration really origi- 
nate this, or was this something originated in Congress that just 
happened to be signed during then? 

Mr. Fay. No. The Reagan Administration originated this. 

Mr. ROHRABACHER. Is that right? I thought we were against 
tEixes. 

Mr. Fay. It was. They were. The theory here was it was a wind- 
fall profits tax, since we were going to be reducing supply, that, 
somehow or other, that the private sector would gain windfall prof- 
its. 

Therefore, we had to protect them from themselves. 

Mr. ROHRABACHER. That shows you the danger of those windfall 
profits tax ideas. [Laughter.] 

Professor, did you have something to add to this? 

Dr. Stroup. Yes. The question, I guess, if the CFCs are being 
smuggled in only because of the tax, my question is to EPA or Mr. 
Fay, why are the other countries growing larger in their production 
of CFCs, given that EPA at least claims that the new refrigerator 
technologies and the things actually being produced are cheaper 
than CFCs? 

So the consumers are benefited by this, not harmed by this. If 
that's true, why aren't American companies underselling the CFC 
machines and the CFCs abroad? 

Mr. Fay. The fact is that the developing country plans, frankly, 
have them growing in both technologies right now. We just assume 
they only grow in the new technology. 

But if they have the production capacity in existing plants, they 
have been looking to expand that capacity by debottlenecking 
plants. 

Mr. ROHRABACHER. Okay. Let me note that I am known in China 
as a China-basher. 

It's not really accurate. If the Chinese do things, if the Chinese 
regime does things, if it as a regime has the policies that are pro- 
democratic and are amicable to the rest of the world, that's fine. 
I would applaud them. 



283 

But, usually, this monstrous regime does many things that are 
just opposite to that and sometimes they actually take people 
around to gulag camps that are nothing more than playgrounds 
until the person leaves. 

And I'm not sure whether or not — I mean, I know that they've 
been stealing from California. Not only do they steal our CDs £ind 
our records and the creations of our artistic community, but to rub 
it in, the army has built these factories and they actually reproduce 
this and all the profit from reproducing it and selling it overseas 
in competition with our own people goes to help strengthen the Red 
Chinese army. 

Now they've made an announcement that that practice is stop- 
ping, too. I'm anxious to see that stop and I hope that they are tell- 
ing the truth. 

I wouldn't bet my refrigerator on it. 

Mr. Fay. Our attitude on that is, just as arms control with the 
Russians and the Chinese, trust but verify. 

Mr. ROHRABACHER. Right. Right. One issue that we'd like to dis- 
cuss, and Ms. Rivers, you have some time now as well to ask as 
many questions as she'd like. Or Mr. Ehlers. 

What about the issue that the alternative is really just as poten- 
tially damaging as what you're getting rid of? 

WTiat about this issue that, like with asbestos, where they said, 
oh, you've got to get rid of all the asbestos. And later on, we found 
out, by trying to get rid of it, we actually put more people at risk. 

What about all of these substitutes actually being worse than the 
original problem in terms of the risks to people's health? 

Ms. Nichols. Mr. Chairman, I think Congress learned some les- 
sons from the cyclamate issue, perhaps, or others, in terms of alter- 
natives and wrote in a provision in the Clean Air Act that required 
testing of alternatives to CFCs to make sure that they, number 
one, were better from the ozone-depleting point of view, and two, 
didn't create other unintended consequences for health or the envi- 
ronment. 

Mr. ROHRABACHER. Well, what about this one that creates acid 
rain? And the other one that creates a cancer problem for the wet- 
lands. 

Ms. Nichols. To the best of my knowledge, the acid rain issue 
is a phony issue. It was alleged at one time that there would be 
more energy used because the substitutes wouldn't be as efficient 
as the CFCs, and therefore, you'd have more power plants churning 
out more sulphur oxides and causing acid rain. 

Mr. ROHRABACHER. All right. 

Ms. Nichols. Not true. 

Mr. ROHRABACHER. That's not true. 

Ms. Nichols. As it has happened 

Mr. ROHRABACHER. There was just a scientist — I think it was Mr. 
Singer, in fact, testified pretty early 

Ms. Nichols. Well, the facts have simply turned out to the con- 
trary, that the substitutes have been part of the redesign of equip- 
ment to make it more efficient. And we're seeing actual savings in 
energy used by these refrigerants. 

So we were right, for once. 



284 

Mr. ROHRABACHER. Unfortunately, I didn't bring that up to the 
panel of scientists earlier because I do remember the point specifi- 
cally that CFCs are a rather efficient way. 

But now what you're saying is actually the new alternatives are 
more efficient. 

Ms. Nichols. The alternatives, per se, aren't what's causing the 
improvement in efficiency. It's that in designing the products in 
order to use the new refrigerants, the manufacturers have also re- 
designed other aspects of the equipment. 

So that the total product, which is what you buy, is more energy- 
efficient. 

Mr. ROHRABACHER. Mr. Lieberman is about ready to jump out of 
his chair. So please move forward. 

Mr. Lieberman. This energy-efficiency argument is extremely 
misleading. 

Actually, CFCs are, in almost every application, more efficient, 
not less efRcient, than comparable non-CFC systems. 

It is true if you replace a 25-year-old dinosaur of a CFC system 
with a brand new, state-of-the-art, non-CFC system, you'll see an 
improvement in energy efficiency. 

That improvement has nothing to do with the refrigerant being 
used. It has to do with technological improvements independent of 
the refrigerant used. 

And as a matter of fact, if CFCs could still be used in state-of- 
the-art equipment, we would see a gain in efficiency. 

So EPA actually has energy-efficiency on the wrong side of the 
ledger. Compared to a no-phase-out scenario, none of us are talking 
about that, but compared to a no-phase-out scenario, we would see 
equipment far more efficient than anything available today. 

Mr. Fay. I'm going to flat out disagree with Mr. Lieberman. 

Mr. ROHRABACHER. All right. 

Mr. Fay. You've got two lawyers up here talking about stuff that 
we ought to have engineers discussing, Mr. Chairman. 

But, frankly 

Mr. ROHRABACHER. That's all right. We've got lawyers making 
lawyers making laws here, too. [Laughter.] 

Mr. Fay. There seems to be a suggestion that the industry glee- 
fully spent $6 billion retooling and investing to convert out of these 
compounds so they could do it again because they know they're not 
quite as good. 

Well, that's just not true. 

The industry — ^these compounds that we've converted to have 
been around a long time. These compounds, we have spent nearly 
$100 million. They are the most thoroughly studied chemicals in 
the history of chemical development. 

There are thousands of chemicals out there that we use on a 
daily basis that we have no clue what their impacts may be on 
health, environment, whatever. 

The user industry, the producer industry studied these from a 
toxicity standpoint, from £in environmental standpoint in terms of 
breakdown products, from an energy-efficiency standpoint. 

And for these people to sit here and somehow make light of the 
investment that these industries made in good faith, and these 



285 

products, is absolutely ridiculous. And to make them and be wrong 
is even worse. 

Mr. ROHRABACHER. Well 

Mr. Fay. Now wait a minute. You talked earlier, in the earlier 
panel about policy-making by press release. And it's the same kind 
of — excuse my language — the same kind of crap we get from either 
the environmental side — excuse me — the environmental side or 
these advocacy groups who want to come in and use us as their fod- 
der. 

It's got to stop. That's what the American people are sick of. 

The industry came in and said we can solve this problem. Here's 
how we think we'll do it, we can do it. Here's how long we think 
it will take. 

And now they want it to stop. 

Mr. ROHRABACHER. Mr, Fay, we should hesitate to use that lan- 
guage. 

Mr. Fay. I'm sorry. 

Mr. ROHRABACHER. Okay. Thank you. 

Mr. Fay. I apologized in advance. 

Mr. ROHRABACHER. I slip at times myself, but I try not to. 

Let me shift the argument, then, away from refrigeration to what 
Mr. Pollet was talking about in terms of the effect that this will 
have on agriculture, because this is totally different than what 
we're talking about in CFCs in refrigeration. 

Mr. Pollet has made some arguments that ethyl — methyl bro- 
mide — earlier on, I was talking about carbohydrates in the air. I 
don't want to make a mistake again. 

But Mr. Pollet was talking about the billions of dollars that this 
will cost and we're talking about not only direct cost of billions of 
dollars, but also a loss of competitiveness for American agriculture 
overseas, which this is a major impact on our economy, a major im- 
pact on the well-being of many families which this is the way they 
earn their living. 

Could you folks address that? 

Mr. Fay. Let me just say, look, I heard every argument this 
morning in the earlier panel by Mr. Doolittle, Mr, DeLay that we 
made in 1983, okay? 

We used to say the same thing. It was only a 60-mile move 
south, that you couldn't replace the chemicals. 

We found out we could. Does methyl bromide have some serious 
problems in terms of being able to limit their use? 

Absolutely. 

Do we have a problem because when Congress adopted the Clean 
Air Act, they didn't put a provision in there for essential use ex- 
emptions, which we said you had to do, which they didn't do on the 
existing equipment base for refrigerants, which we said you had to 
do? 

Absolutely. 

So we're sitting here saying that the issue is fake, that we've got 
all these scientists debating whether it's a real issue or not a real 
issue. 

Industry and farmers and consumers, they don't have time for 
that. We've got to make a policy decision. We're going to move on 
and correct the problems with the law, not that debate. 



286 

Mr. ROHRABACHER. The policy suggestion that you're making 
then is that we make an exception for agriculture on this? 

Is that what you're saying? 

Mr. Fay. If in fact there is a need for an essential-use exemption 
for agriculture, yes. But does that mean that they can't do any- 
thing? No, it doesn't. We've seen that time and again. 

But do they need an essential-use exemption for the existing 
equipment base of automobiles? None of that existed. We managed 
to get that in 1992 in the treaty by which we're operating. That did 
not exist and we managed to get that in there because we finally 
got somebody to pay attention. 

Mr. ROHRABACHER. Administrator Nichols, is there any support 
within the Administration about this type of exemption? 

Ms. Nichols. Yes, Mr. Chairman. I have met personally with 
representatives of grower organizations here in town, along with 
the Deputy Secretary of Agriculture, Rominger. Both of us are Cali- 
fornians and maybe that has something to do with it. 

But we've also had support from the White House for working on 
some specific language that would create the ability to give an es- 
sential-use exemption for agricultural uses that cannot be sub- 
stituted. 

Mr. ROHRABACHER. Let me recommend that the Administration 
move forward very quickly on this so that the agricultural interests 
and the people who we're talking about here will understand, be 
able to take a look at what their alternative is and the alternative 
that you're offering. 

Ms. Nichols. I think the basic principle, as has been suggested 
in other areas, should be that they would be granted in enough 
time in advance so that the users would know what was available 
to them, but that there would be a careful set of criteria to make 
sure that we continue to maintain the incentive for research on al- 
ternatives. 

Mr. ROHRABACHER. Mr. PoUet, would you like to comment on 
that? 

Dr. POLLET. Yes. There really are no other materials. You talk 
about Telon-2. Telon has been banned in California and it's strictly 
for pneumatocides. Whereas, methyl bromide will take out insects, 
diseases, and I'm talking about bacteria and viruses as well, nema- 
todes, also weed seeds. 

And there's no other material on the market, either now or con- 
ceivably in the future, that will work that effectively. 

If you take that material off the market 

Mr. ROHRABACHER. We're talking about an exemption now that 
would permit you to use it. 

Is that what you're advocating, Mr. Fay? 

Ms. Nichols. Excuse me. To be careful about that, it depends on 
the use. 

There is no single compound that does everything that methyl 
bromide does. There's no question about that. Methyl bromide is an 
extremely effective biocide. It kills everything in its path. 

For certain purposes, there are substitutes. 

Mr. ROHRABACHER. But, Mr. Fay, were you advocating that there 
be an exemption for this? 



287 

Mr. Fay. I'm not advocating a blanket exemption for agricultural 
uses, no. I'm saying if there's a need for an exemption in these 
areas, then that's something that the Congress should look at. 

If there's a need for an exemption in other areas, that's some- 
thing that the Congress should look at. The Congress should leave 
itself some outs in case, just as you say, if the data changes or in- 
formation proves to be wrong. 

Mr. ROHRABACHER. But you're not willing to advocate that now. 

Mr. Fay. An agricultural exemption, just a flat-out blanket ex- 
emption? 

Mr. ROHRABACHER. For the methyl bromide here. 

Mr. Fay. No. No. It's not my issue. We have not worked on the 
methyl bromide products. They are late coming into the issue. I un- 
derstand that. And in terms of — I can't speak to the availability of 
substitutes on that basis. 

Mr. ROHRABACHER. Well, let me just say that this gentleman rep- 
resents not just himself here. If you listen to what he had to say, 
this is really important to the well-being of our country. 

Mr. Fay. No, no. I understand that. And as I pointed out, we 
made all of the same arguments about 15 years ago. 

Mr. ROHRABACHER. Okay. Well, we take him very 

Dr. POLLET. Let me just say this. It's not just agriculture. There 
are a lot of PCOs and whatnot, use this in the fumigation of homes 
for pesticide control, and things like the Formosan termite, which 
is extremely difficult to control. 

It's probably one of the most economical ways of doing it. 

If you have to do something with the Formosan termite, it usu- 
ally takes you three or four applications of other materials. 

Mr. ROHRABACHER. Mr. PoUet, thank you very much. 

I'm going to turn now to Mr. Ehlers first, and then Ms. Rivers. 

Mr. Ehlers. Ms. Rivers. 

Mr. ROHRABACHER. Is that right? Pardon me. 

Ms. Rivers. 

Ms. Rivers. Thank you, Mr. Chair. 

I want to ask a sort of bottom-line question. But before I do that, 
I want to go back to the issue that Mr. Fay raised because I was 
heading in the same direction, which is this whole idea that we 
have been condemning public policy being developed in the press 
or through anecdote. 

And frankly, we've had some problems here on this Committee 
sometimes. 

And as I was going through the testimony and listening to folks, 
two things really jumped out at me that I think I want to ask 
about. 

One is directed to Professor Stroup. And that was your sugges- 
tion that the imposition of the accelerated phase-out of CFCs has 
increased the price and lowered the energy-efficiency of refrigera- 
tion units and that the effect of this is that fewer people will be 
able to purchase home refrigeration, which in turn will cause dele- 
terious health effects, such as food poisoning and stomach cancer. 

Before I ask my question, it's interesting. We were having a dis- 
cussion around a similar topic here around energy efficiency and 
the cost of refrigeration. I was amazed when I was able to get data 



288 

from the Livermore labs that in fact the cost of refrigerators has 
gone down significantly over the last 25 years. 

I'm very interested in knowing specifically how large the price in- 
creases for home refrigeration you project. And where you deter- 
mine that these significant health risks come from. 

I'm asking, I guess, for your underlying data for both of those as- 
sumptions. 

Dr. Stroup. Well, first of all, I don't disagree that the price of 
refrigeration is coming down. That's not the point. 

As Mr. Ben Lieberman said earlier, that relates to two things. 
One is the technological trend. We have constant improvement in 
automobiles. We have constant improvement in refrigerators. We 
have constant improvement in almost everything — computers, you 
name it. 

Some of that technological trend has, I believe, been soaked up, 
so to speak. It's been a smaller decline in the cost of refrigeration 
than it would have been, I believe. 

What I have read is that CFCs are thermodynamically more effi- 
cient than their substitutes. That's the basis for my statement. 
Plus what I said earlier, which is that you cannot, I think, make 
consumers better off dollar-wise by taking away options from them. 

I just don't think that that is likely to happen. 

Ms. Rivers. The other thing that was interesting in the Liver- 
more data is that there are more kinds, more and different kinds 
of refrigerators available than there was 25 years ago. 

Dr. Stroup. Sure. 

Ms. Rivers. So in fact there's a greater efficiency. 

But your answer begs the question, which is, if in fact the actual 
cost of refrigeration is not going up and is not likely to go up under 
these changes, where do you get the argument that the elimination 
of CFC is going to produce greater incidences of food poisoning and 
stomach cancer? 

Dr. Stroup. If there would have been a 20-percent reduction — 
suppose there has been a 10-percent reduction. I don't know what 
that number really is. But suppose there could have been a larger 
reduction. 

Then refrigerators would be more available. Then they would be 
larger. Then the food poisoning would fall because the potato salad 
brought in from the picnic is more likely to be refrigerated and so 
on. 

Ms. Rivers. So you're sa5dng that it's purely hypothetical. You 
have no data to suggest that this would actually happen. 

Dr. Stroup. I don't know what the partial is. All I know is I read 
that the thermodynamic efficiency of CFCs is greater than any of 
its substitutes. 

And how can you conclude anything else? 

Ms. Rivers. And you say that since there is an efficiency dif- 
ference, that your projection is that refrigeration will cost more. 

So that it's pure speculation on your part, is what you're saying. 

Dr. Stroup. It's pure logic. And I have no data beyond that logic. 
That's correct. 

Ms. Rivers. Thank you. The other similar issue that I would like 
to raise, and this I would like to address to Mr. Lieberman. 



289 

And that is relative to statements that you presented in — I be- 
heve it's The Washington Times. Yes, The Washington Times. Ar- 
guing that the death of hundreds of people in Chicago was a direct 
result of these changes around CFCs. 

And I would like to know, particularly given that Mr. Ted Rees 
from the Air Conditioning Institute immediately contradicted you 
and the Cooke County coroner's office also immediately contra- 
dicted you. 

What were the underlying data that you relied on to make your 
comments in the paper? 

Mr. LlEBERMAN. I think if you read my article and if you submit 
it to the record 

Ms. Rivers. I have. 

Mr. LlEBERMAN [continuing]. You'll see that I was actually very 
careful. I was speaking in hypothetical terms. 

Mainly, this was an article that the Chicago heatwave should be 
a warning for the future, that if further reductions in the availabil- 
ity of refrigerants and further increases in costs are going to be im- 
plemented, is being discussed by the parties of the Montreal Proto- 
col, namely, a more drastic reduction in the phase-out, or drastic 
acceleration of the phase-out of HCFC-22, if that was to occur, 
then future heatwaves would definitely be affected. 

I was very, very careful to say that — I don't remember my exact 
language, but I said that there's no evidence that anyone was actu- 
ally hurt. But the possibility cannot be discounted. 

I'm just theoretically saying that, in broad terms, if you make 
air-conditioning more expensive, you will make it less available. 

Ms. Rivers. So what you're saying then is you just used the 
death of 500 people as a platform on which to make your point. 

Thank you. 

Mr. LlEBERMAN. Yes. 

Mr. ROHRABACHER. I think the witness also was suggesting that 
there were enough caveats to cover him. We've heard a lot about 
caveats. 

Ms. Rivers. You mentioned that earlier, that caveats are often 
used as an opportunity to not tell the truth. 

Mr. Rohrabacher. No, no. That's right. Caveats are — how- 
ever 

Ms. Rivers. I have one more question, I'm sorry. And this is the 
bottom-line question that I made reference to. 

Mr. Rohrabacher. Maybe we can let Mr. Liebermann just have 
one chance to answer. 

Ms. Rivers. Okay. 

Mr. Rohrabacher. Go right ahead, Mr, Liebermann. 

Mr. LlEBERMAN. I suppose I shouldn't have written an article 
that gave them some fodder to discredit me. 

I'm a newcomer. I haven't written much, so there wasn't much 
to pick on me for, and this was the best they could do. 

Read it yourself. You'll see, 

Ms. Rivers. It's pretty good, you have to admit. 

Mr. Rohrabacher. Mr. Liebermann, I wouldn't apologize, 

Mr. LlEBERMAN. Read it for yourself. 

Mr. Rohrabacher. I wouldn't apologize. All I would say is, when 
I saw your article, I remember that I had been driving around all 



290 

summer in a car without air-conditioning and I was sweating and 
I felt really bad this summer. 

I had a tendency to think that maybe this had something to do 
with the increase in the price of freon, that it had something to do 
with this CFC ban. 

I don't think it was a jump of logic to suggest that maybe some 
other people up in Chicago were sweating and maybe it had a dele- 
terious effect on their health. 

I don't know any information about it, but I was sure sweating 
and I was angry about it. So apparently you were, too. 

Mr. LlEBERMAN. I would also add that the hypotheticals that 
were necessary to come up with cost/benefits of $32 trillion in 
EPA's regulatory impact assessment I think also deserve a closer 
look as well. 

Mr. ROHRABACHER. Okay. 

Mr. LlEBERMAN. I don't know if there are $32 trillion around. 

Mr. ROHRABACHER. Ms. Rivers, do you have one more question, 
please? 

Ms. Rivers. I do. 

Mr. ROHRABACHER. And then we'll go to Mr. Ehlers. 

Ms. Rivers. Okay. I'd like to address this to Ms. Nichols. 

And that is, I've heard a lot of arguments about the economic 
consequences of continuing with the elimination of these chemicals. 

But in talking to a variety of people, I have also heard people 
talk about the economic effect of rolling back and not going for- 
ward. 

Could you speak at all to the costs to industry or the country in 
general if we choose now to abort in the middle of this process? 

Ms. Nichols. We have not done an analysis of the effects, let's 
say, of the proposal that is in Mr. Doolittle's "Dear Colleague" let- 
ter to rollback, partly because the effects are somewhat unknow- 
able, since it's a violation of the Montreal Protocol Treaty. We don't 
know what the effects on the rest of the world would be in terms 
of the overall effect on the ozone hole. 

So you'd have to just look at the cost to industry and the invest- 
ments that have been made on that side in reliance on the current 
date. 

We know, obviously, some companies are actually moving ahead 
of the deadline to get ahead and we'd have to go back and do a 
more careful look at that. 

So I can't really give you any numbers right now. But, clearly, 
directionally, it would be a disadvantage to those firms that have 
made the investment. 

Ms. Rivers. Mr. Fay, can you speak to that? 

Mr. Fay. It would be hard to say what the costs are because the 
phase-out is complete. There are — ^but for a few exceptions, there 
are no major equipment manufacturers in this country any longer 
using CFC compounds. 

And the chemical companies, what they make from now on will 
only be what they're allowed to make as a result of the exemption 
for developing countries and to ship overseas. 

I can tell you that if it's going to come from somewhere, if you 
roll back the phase-out, if the material could somehow find its way 
legally into the country, it would come in from China, India or Rus- 



291 

3ia, because there are no companies in this country that I'm aware 
jf who have any intention or interest in — I don't know how many 
people got back into cyclamates, Mr. Chairman, but they're not 
looking into restaring their CFC plants. 

Mr. ROHRABACHER. I would agree with the witness that that's 
maybe true of companies. 

I can tell you that there are a lot of people out there who are 
looking for freon for their air conditioner. 

Mr. Fay. There is plenty of refrigerant available. The production 
bas not ended from that standpoint this year. 

Mr. ROHRABACHER. Yes. 

Mr. Fay. It's expensive, yes. 

Mr. ROHRABACHER. That's right, yes. If you earn as much as a 
Washington lawyer, it's not so bad. But if you're some regular 
buman being, it's a pretty expensive proposition. 

Mr. Fay. When the Congress puts a tax on it, the equivalent of 
1 10 a gallon on gasoline, it's going to be expensive. 

We were opposed to the tax. We didn't support it. I mean, it's ex- 
pensive. 

Mr. ROHRABACHER. Boy, I'll tell you. I don't remember Ronald 
Eleagan doing that, but I guess he did. [Laughter.] 

Mr. Fay. The other side of the aisle very gleefully adopted it, I 
can assure you. [Laughter.] 

Mr. ROHRABACHER. They never met a tax they didn't like. 

Mr. Lieberman, did you want to say something. You got kind of 
beat up there. 

Mr. LIEBERMAN. Well, I do want to add that the Doolittle bill ac- 
tually does roll back the tax. It doesn't eliminate it. It rolls it back, 
Congressman Doolittle being a moderate, obviously. 

Mr. ROHRABACHER. Right. Okay. WeU, thank you very much. 

Mr. Ehlers. 

Mr. Ehlers. Thank you, Mr. Chairman. It's been a long day, so 
[11 be brief. 

I would just like to pin down this efficiency issue a little bit bet- 
ter. 

Mr. Lieberman, Professor Stroup, you both made the comment 
that the thermodynamic efficiency of HFCs is lower than the CFCs. 

Can you give me the data on that? Why is that? How much lower 
is it? 

Mr. Lieberman. I don't have the exact data, but I can certainly 
give that to you and submit it for the record. 

Mr. Ehlers. Mr. Fay, perhaps you know. 

Mr. Fay. I don't have the precise figures. Technically, from a 
chemical-for-chemical basis, that is true. 

Mr. Ehlers. By what percentage? 

Mr. Fay. I couldn't tell you. But they've been able to engineer 
around that. 

A couple percent, I'm told. 

Mr. Ehlers. That's extremely small because the variation of effi- 
ciency of compressors is greater than that, depending on how care- 
fully you build them, what the tolerances are, and so forth. 

So it's basically a non-effect, then. 

Mr. Fay. Well, on a global scale, a couple percent actually ends 
up being a lot. But the chemicals themselves 



292 

Mr. Ehlers. No. I'm saying, if we're worried about a couple per- 
cent, then we ought to worry about the engineering of the compres- 
sors, too. 

Mr. Fay. Exactly. That's exactly it. 

Mr. Ehlers. Because that exceeds a couple percent variation. 

Thank you, Mr. Chairman. I think I made the point. 

Mr. ROHRABACHER. Thank you very much. And I would like to 
note for everyone gathered that we do have several new pictures 
on the wall. 

There's a new painting over here. I imagine that has something 
to do with the ozone hole. [Laughter.] 

And there's another one over here [indicating]. I think that is 
less abstract. I think that has something to do with the aerospace 
industry. 

I have thoroughly enjoyed your testimony today. 

Mr. Ehlers. Mr. Chairman, I believe that's a pollution vacuum. 

Mr. ROHRABACHER. A pollution vacuum. 

Mr. Ehlers. That's sucking all the pollution away from the earth 
and right out to the sun. [Laughter.] 

Mr. ROHRABACHER. This is why we have a scientist here, to open 
and broaden our horizons of the possibilities and potentials of the 
human mind. 

I want to thank you all. I appreciated your testimony. This has 
been — I think it's been a very fine hearing, where we had a con- 
trast of opinions, which is what the purpose of this was. 

I appreciate all of you coming. Thank you very much. 

The hearing is adjourned. 

[Whereupon, at 4:16 p.m., the hearing of the Subcommittee on 
Energy and Environment was adjourned.] 



APPENDIX 



JIMMY HAYES 
WASHINGTON OFFICE; 



UlfvWt*. LA 70901 



CongrtSB of the lanittd States 

Jl^oust of Sleprnfentatibnt 
aaSasljington, BC 20515-1807 



DISTRICT OFFICES: — , ^ 

.ooE«».«.k,n l|oiu(e of Sleprnfentatibnt 



September 20, 1995 




JJ/amv/ Hay^ 
Member or Congress 

Opening Statement by Congressman Jimmy Hayes (D-LA) , 

Ranking Democrat on the House Subcommittee on 

Energy and Environment, regarding 

the Ozone Depletion hearing 

Mr. Chairman, the issue of stratospheric ozone depletion that 
is before our Subcommittee today may be somewhat unclear in its 
public policy and economic implications, but not in its scientific 
foundations. 

Theories regarding the adverse impact that both natural and 
man-made Chlorof luorocarbons (CFC's) have had on ozone depletion 
enjoy some of the most broad-based support of any matter of 
environmental interest. Principles of chemistry confirm that CFC's, 
which are inert and stable substances on earth, react with ozone in 
the upper atmosphere to draw away oxygen molecules, thus destroying 
the ozone. 

The agreement of over forty nations under the Montreal 
Protocol and subsequent amendments represented the acknowledgement 
of the policy makers, industries, and scientists throughout the 
developed and developing world that a problem existed and that a 
collective solution was the only workable strategy to address the 
situation. At the time of the Protocol, U.S. manufactures sold 
about $750 million in compounds annually to about 5,000 customers 
in refrigeration, air-conditioning, automotive, plasticfoam, and 
electronic industries. Those industries then produced $27 billion 
in goods and services per year directly dependent on CFC's. 

The Sxibcommittee is well aware of my position on how 
government, more specifically the federal government, should 
perform its oversight function over the environment. We must 
utilize the best available and most credible science --peer 
reviewed science -- and we must ensure that relevant risks, costs, 
and benefits to society are appropriately weighed. I firmly 
believe that, with only limited fiscal, natural, and human 
resources, it is indeed government's responsibility to allocate its 
resources in a way that maximizes their effectiveness. We can 



(293) 



294 



protect our environment without writing thousands of pages of 
regulations and prohibitions. We must focus on the most pressing 
problems -- those that pose the most risk to our society, not those 
that yield minimal benefit for too high a price. 

It is for these reasons that I believe that postponing the 
phase -out of CFC's would be a waste of our limited resources. When 
factoring the investments that have already been directed toward 
the phase-out in terms of time, money, human capital, etc..., the 
costs involved in the delay would surely outweigh the benefits. 
Economic principles tell us that choices boil down to utility. 
Billions of dollars have already been spent to develop viable 
substitutes and it is my understanding that those products and 
technologies are on-line to take over the market. Businesses which 
produce and are dependent on CFC's would not have changed their 
production and utilization processes unless some benefit -- utility 
-- was gained that justified these important investments. 

This is not to say that there are not issues which remain in 
doubt. After all, someone once said that "everyone knows in 
research there are no final answers, only insights that allow one 
to formulate new questions." 

For example, I fully recognize and agree with the legitimate 
concerns of some of my constituents that the cost associated with 
replacing or repairing refrigerators, car air conditioners, or 
commercial chillers will continue to be exorbitant. Mr. Lieberman 
makes this point in his testimony. The industry has made the 
capital equipment problem among its top priorities. It is my hope 
that stockpiles of CFC's and grandfathering some of this equipment 
may acceptably resolve some of this dilemma. I will work with the 
Chairman, my constituents, and other interested stakeholders to 
move our policy in a suitable direction. 

Finally, I wanted to touch on the much more complex issue of 
the phase -out of methyl bromide. Methyl bromide's primary uses 
center around pre-planting treatment of soils to control insects, 
pests, fungus, and certain other diseases. It can also be employed 
for post harvesting fumigation of agricultural commodities for 
prevention and removal purposes as well as structural fumigation 
where grain is stored. 

Whereas research into CFC's effect on ozone depletion has been 
conducted for decades, scientists have only tied methyl bromide to 
ozone depletion since 1991. Unlike CFC's, data does not as 
explicitly and unequivocally assert that man-made occurrences of 
bromine in the atmosphere outnumber natural sources . 



295 



Under Title VI of the Clean Air Act Amendments, methyl bromide 
has been classified as exhibiting ozone depletion potential (ODP) 
and is targeted for phase-out by the year 2001. It is worth noting 
that methyl bromide is not part of the phase -out schedule under the 
Montreal Protocol dealing with the elimination of CFC's worldwide. 
U.S. phase- out is unilateral. While the upcoming Protocol 
conference in Vienna is expected to discuss methyl bromide, the 
disagreement in the scientific community over its precise ODP and 
its impact on meeting the ozone stabilization deadlines, no 
decisions regarding its international disposition are likely to be 
made. No other major agricultural exporting nation plans to ban 
methyl bromide. 

With this in mind, I welcome Dr. Dale Pollet of the Louisiana 
Cooperative Extension Service to the Subcommittee to testify on the 
threat to the agricultural community of a unilateral phase-out of 
methyl bromide. Dr. Pollet received his Ph.D. in Entomology from 
Virginia Tech and his B.S. from Louisiana State University. He has 
been a leader in our state of addressing the impacts of a number of 
pest control methods and been involved in the development of the 
Integrated Pest Management efforts with the Louisiana Cooperative 
Extension Service. 

In his statement. Dr. Pollet points out the $1.5 billion in 
direct economic losses due to a premature phase -out schedule of 
methyl bromide prior to the development of viable substitute 
products. He also alludes to the consequences of a ban on the rice 
mills of Louisiana, many of which, I might mention, are located in 
the Seventh District. 

According to USDA's own data, of the estimated 135 commodities 
that require fumigation as condition of import or export, only 17 
have an alterative treatment currently approved and 93 are under 
review. The three chemicals which perform these substitute 
functions are being examined by EPA for potential carcinogenic 
effects. Remember also that these are all post harvest function 
which only account for approximately 5% of methyl bromide uses. No 
acceptable substitutes have been approved for pre- treatment. 

I would conclude by saying that even if substitute 
technologies were available today, it could still take up to ten 
years to ensure approval under the FIFRA process. Methyl bromide 
is the alternative to many chemicals long banned by federal 
regulators, and herein lies the predicament. Assuming that 
scientific consensus is reached on the ozone depletion effects of 
methyl bromide, a process must be formulated to ensure that the 
options to methyl bromide produce an overall environmental benefit. 

I applaud the Chairman for the timeliness of this proceeding 
and am looking forward to hearing the testimony. 



296 



Statement of Rep. Henry A. Waxman 

Before the Subcommittee on Energy and Environment 

Committee on Science 

September 20, 1995 

The ozone depletion program in the Clean Air Act is one of the 
strongest, best-justined environmental programs in the world. 

There are three fundamental reasons why the ozone depletion 
program has been a success. 

First, the science of ozone depletion is well established. Virtually 
the entire international scientific community agrees that ozone depletion is 
a severe environmental threat. There is overwhelming evidence that there 
is an ozone hole; that man-made chemicals are causing this hole; and that 
if this hole is not repaired, widespread ecological damage and harm to 
human health will result 

Second, the ozone controls established in the Montreal Protocol and 
the Clean Air Act Amendments of 1990 are succeeding. We have already 
phased-out completely one class of ozone-depleting chemicals, the halons. 
At the end of this year, we will complete the phase-out of CFCs. These 
controls have been achieved with none of the economic hardship or 
dislocation feared when we passed the 1990 Clean Air Act. 

Third, responsible U.S. industry supports the ozone depletion 
program. The major CFC makers like DuPont and the major CFC users 
like the auto companies have already found effective substitutes for ozone- 
dq)leting chemicals. Often these substitutes save more in energy- 
efficiency than they cost. These U.S. industries want to see the ozone 
deletion program successfully completed — they do not want it rolled 
back. 

I realize that there are some in Congress, including the Majority 
Whip Tom DeLay, who want to repeal the ozone depletion provisions of 
ibt Clean Air Act. This is simply an irresponsible and extreme position. 
Tliose who want to get rid of controls on ozone-depleting chemicals are 
for out of the mainstream. They are pushing an agenda that lacks 
scientific support, would jeopardize health and environment worldwide, 
and is opposed by responsible U.S. industry. 

The ozone depletion program has always had bipartisan support in 



297 



the past. In 1987, President Reagan signed the Montreal Protocol, the 
international agreement protecting the ozone layer. In 1990, Congress 
adopted title VI of the Clean Air Act, which further accelerated the phase- 
out of ozone-depleting chemicals, with overwhelming bipartisan support. 
In 1992, President Bush again accelerated the phase-out of ozone- 
depleting chemicals in 1992. 

In light of this history and the proven success of the ozone depletion 
program, ^is bipartisan support should continue today. 



298 



STATEMENT SUBMITTED BY 

DEPUTY ASSISTANT SECRETARY RAFE POMERANCE 

DEPARTMENT OF STATE 

HOUSE SCIENCE COMMITTEE 

SUBCOMMITTEE ON ENERGY AND ENVIRONMENT 

SEPTEMBER 20, 199 5 

Mr. Chairman, I would like to thank you for affording 
me the opportunity to submit for the record the following 
statement on the current state of international 
stratospheric ozone agreements. 

Ozone depletion, a problem common to all mankind, 
transcends national frontiers. Man-made compounds have 
in recent years posed a threat to the gaseous layer of 
the stratosphere which serves to screen out Ultraviolet-B 
radiation. Increasing amounts of such radiation only 
raise the risk of added cases of skin cancer, reduced 
agricultural production and damage to aquatic ecosystems, 
etc. The international response to such depletion — 
viz., the 1985 Vienna Convention for the Protection of 
the Ozone Layer and the follow-on 1987 Montreal Protocol 
on Substances that Deplete the Ozone Layer — have been 
paradigms of international cooperation. 

The Protocol, to which nearly 150 countries have now 
acceded, has gained virtually universal acceptance. This 



299 



- 2 - 

has been due principally to three reasons: (1) the 
excellent scientific analyses which have served as the 
underpinning for the adopted control measures; (2) 
support among business circles, especially in the United 
States; and (3) the creation of the Montreal Protocol 
Multilateral Fund in London in 1990. The Fund was 
established to assist Article 5 nations (i.e., developing 
countries whose per capita consumption of 
chlorof luorocarbons (CFCs) was relatively low) to meet 
their Protocol phaseout obligations with respect to 
ozone-depleting substances (ODS) . 

The Article 2 Parties (i.e., developed countries) 
agreed to support the Fund because (1) assistance was 
limited to the incremental or "extra" phaseout costs; (2) 
aid was to be given only to those developing countries 
whose consumption of ODS was historically very low; and 
(3) the amount of the Fund was a small price to pay to 
protect the large domestic investments that developed 
countries had made to phase out ozone-depleting 
compounds. To date, some $350 million has been disbursed 
for more than 800 activities in over 85 developing 
countries. When completed, these projects are expected 
to result in a one-quarter to one-third reduction of 
developing countries' use of controlled ODS. It is 



300 



- 3 - 

important to highlight the fact that a number of Article 
5 countries, which are currently required to freeze their 
consumption and production of CFCs in 1999 and phase out 
by 2010, are moving to phase out even more rapidly than 
scheduled. 

The current situation we now face with regard to the 
Multilateral Fund poses major difficulties. The United 
States was the major force behind the Fund's $510 million 
replenishment (the U.S. share is abut $114 million) for 
the three year-period beginning in 1994. We are, 
however, now confronted with the situation of being 
unable to pay our annual voluntary contributions to the 
Fund. As a result of Congressional cuts in State 
Department and EPA requested appropriations in previous 
years, we are presently some $28 million behind in our 
voluntary contributions. Absent appropriations along the 
lines of the $51 million requested by the Administration 
for FY 1996, it is inevitable that we will fall further 
behind. This situation resonates with a certain degree 
of irony given our leadership position in developing 
technologies that reduce the effects of ODS. U.S. 
industry could stand to gain substantially more from 
Fund-related activities. For example, a New Jersey 
manufacturer has won a $10 million contract for supplying 
technologies to help an agricultural concern in the 
Philippines phase out its use of ODS. 



301 



- 4 



The efficacy of and need for the Protocol and its 
London and Copenhagen Amendments of 1990 and 1992, 
respectively, are beyond question. I would also like to 
add that the Protocol and its subsequent amendments were 
negotiated by the Reagan and Bush Administrations, both 
of which recognized the absolute importance of acting to 
assert U.S. leadership in addressing this environmental 
threat. In a report entitled "Scientific Assessment of 
Ozone Depletion: 1994", the world's leading atmospheric 
scientists reported a diminution in the rate of growth of 
major ozone-depleting substances in the stratosphere 
(i.e., CFCs and halons) . In fact, the scientific 
community has observed an actual reduction in levels of 
methyl chloroform, another ozone-depleting compound. 

In November, approximately 150 nations will meet in 
Vienna to commemorate the tenth anniversary of the 
Convention, as well as to hold the Seventh Conference of 
the Parties of the Montreal Protocol, At this 
Conference, the Parties will consider additional phaseout 
measures for developing countries with respect to their 
production and consumption of CFCs, halons, carbon 
tetrachloride and methyl chloroform (i.e.. Annex A and B 
substances). In addition, the Protocol Parties will 
review developed country obligations with respect to 
hydrochlorof luorocarbons (HCFCs) and methyl bromide and 
threshold control measures for developing countries for 



302 



- 5 - 



the latter two ozone-depleting substances. 

At the recently concluded Twelfth Open-Ended Working 
Group Meeting of the Parties to the Montreal Protocol in 
Geneva, a session designed to lay the foundation for 
November's Conference of the Parties, a subgroup of 
developing and developed countries presented their report 
on additional developing country phaseout measures with 
respect to CFCs, halons, etc. The group recommended a 
series of scenarios for consideration by the Conference 
of the Parties which entail different environmental and 
financial costs. 

In considering the matter of CFCs, it is also 
important to reiterate the fact that no delegation in 
Geneva, not even those which are experiencing 
difficulties meeting their phase out commitments, 
questioned the scientific basis for the phaseout of the 
production and consumption of these compounds. 

At the Open-Ended Working Group meeting, the United 
States continued to advocate the belief that a universal 
phaseout for methyl bromide on the part of both developed 
and developing countries is perhaps the single most 
important measure that can now be adopted to protect the 



- 6 - 

ozone layer. I note that no final agreement was reached 
on the definitions of the methyl bromide quarantine and 
pre-shipment exemptions in Geneva. This is a matter of 
great importance to American agriculture. We also 
broached in a plenary session in Geneva the idea of 
establishing a "critical agricultural use" exemption for 
methyl bromide. The proposal, which evoked a great deal 
of developed and developing country interest, would 
permit the post-phaseout use of methyl bromide where, 
inter alia, substitutes are neither commercially 
available, effective, nor economically feasible. 

While the United States stands alone in articulating 
the need for an across-the-board universal 2001 phaseout 
for methyl bromide, a number of countries such as 
Austria, Canada, Denmark, Germany, The Netherlands, 
Sweden, Switzerland, etc. have embraced the concept of an 
Article 2 country phaseout by 2001. Australia and Malawi 
continued in Geneva to support the notion of a developing 
country freeze on methyl bromide consumption. 

Concerning HCFCs and developed countries, we argued 
strongly for the maintenance of the status quo with 
respect to both the ultimate 2030 phaseout date and the 
3.1 percent cap. While the Nordic nations and the EU 



304 



- 7 - 

continued to stress the need to advance the phaseout 
date, Australia, Canada, Italy, Japan, South Africa etc. 
have gone on the record as endorsing our position. As to 
developing countries, we made an equally strong pitch for 
an HCFC freeze in 2000 at 2000 levels. 

We also succeeded in Geneva in getting the Working 
Group to recommend to the Conference of the Parties the 
approval of all of our "essential use" nominations for 
controlled substances (e.g., CFCs for metered dose 
inhalers) . 

In considering the foregoing, it is important to note 
that in Geneva the G-77 countries and China made it very 
apparent that Article 5 countries needed, among other 
things, information from the Protocol's Technology and 
Economic Assessment Panel (TEA?) on the economic and 
financial implications associated with various methyl 
bromide and HCFC control scenarios, as well as data on 
the economic implications attendant to the remaining 
Annex A and B phaseout scenarios. In addition, the 
developing countries requested the Multilateral Fund's 
Executive Committee to give them a notional indication of 
future contributions to the Fund based on currently 
agreed control measures. The reports of the TEA? and the 



305 



- 8 - 

way to framing the debates and ultimate outcomes in 
Geneva. 

In assessing the state of the Protocol, it is also 
important to cite the fact that Russia and several other 
countries with economies in transition (CEITs) lack the 
means to meet their CFC phaseout commitments by January 
1, 1996. While the Central European nations, according 
to a TEAP study, will only have short periods of 
non-compliance (i.e., 1-2 years with support from the 
Global Environment Facility), the case is very much 
different with respect to the Russian Federation and 
other nations formerly part of the Soviet Union. In 
addition, most of the CEITs have, of late, failed to meet 
their voluntary contributions to the Multilateral Fund. 
Such contributions are supposed to constitute some 15% 
(about $77 million) of the Fund. 

In conclusion, the ozone layer continues to 
deteriorate. It is imperative, therefore, to meet this 
threat. Complacency will only negate the gains made to 
date and will only put off further, if ever, the time 
when the ozone layer will be restored. A recently 
released World Meteorological Organization (WMO) report 
cited last week by the Washington Post observes that the 
seasonal ozone hole over Antartica continues to expand. 



306 



- 9 - 

The report indicates that the hole is now the size of 
Europe. 

The United States will only be able to maintain its 
leadership position in the Montreal Protocol 
negotiations, as well as in other international 
environmental fora, if we are in a position to make good 
on our voluntary contributions. Given the global nature 
of the problem, such contributions, relatively small in 
size, will redound to the benefit of not only thSv 
developing world, but also to the American people. 

/ 

Thank you Mr. Chairman. 



307 



Appendix 2 
answers to questions derived from the september 20, 1995 hearing 
submitted to chairman dana rohrabacher by dr. s. fred singer 

1. Please list peer-reviewed scientific journals in which you have published. 

(Answer) Journal of the Franklin Institute, Physical Review, Physical Review Letters, Reviews 
of Geophysics, Journal of Geophysical Research, Transactions of the American Geophysical 
Union, Astrophysical Journal, Physics of Fluids, Icarus, Environmental Geology, Environmental 
Conservation, Environmental Science and Technology, Meteorology and Atmospheric Physics, 
Science, Nature. This is not a complete list; there may also be others. I have published well 
over 150 scientific papers. 

2. Your name is not listed as a contributor or reviewer in the 1994 WMO Ozone 
Assessment. Why is that? 

(Answer) It has been the sad experience of many of my colleagues that their critical comments 
and objections are ignored by the editors, but that their names are then cited as if they approved 
of the Assessment. For example, in the 1990 IPCC Report, the editors explicidy acknowledged 
the existence of dissenting views, but then stated that they "could not accommodate them." The 
editors did not identify the dissenters, did not reveal how many dissented, nor state the substance 
of the dissenting views. 

The 7-page list of scientists (exhibited also by witness Mary Nichols as evidence of a 
"consensus") certainly looks impressive; but, I would note, there is no way of determining how 
many actually agree with the overall conclusions of the AssessmenL 

3. You appended to your testimony your recent publication in the Journal of the Franklin 
Institute. Does it contain new scientific information? 

(Answer) It is primarily an up-to-date review of the evidence, but it also contains some new 
information. It points out for the first time that a theoretical paper (by Ravishankaia ct al.) and 
an experimental paper (by Wennberg et al.), both published in Science in 1994, lead to the 
interpretation that the major destroyer of ozone in the lower stratosphere derives from water 
vapor, rather than from CFCs. But water vapor is now increasing, likely because of human 
activities.* If this hypothesis is correct, then a ban on CFC production would not achieve the 
desired result 

4. In his testimony Dr. Watson doubts your hypothesis that increasing levels of atmospheric 
methane and carbon dioxide are causing the Antarctic ozone hole. Please comment 

(Answer) Dr. Watson misquotes me and is wrong as well. It is generally accepted that chlorine 
cannot remove ozone without the presence of ice crystals. Ice crystals require water vapor and 
low temperatures. In 1988, 1 published the hypothesis that ice crystals are rate-linuting for ozone 



308 



removal, rather than just the concentration of chlorine; increasing methane increases stratospheric 
water vapor and carbon dioxide lowers the temperature.* Dr. Watson may not be aware that the 
same idea was published more recently by Blake and Rowland, without attribution to my earlier 
paper. 

5. The WMO released a report this month (September 1995) claiming a more rapid increase 
in the Antarctic ozone hole. What is your comment? 

(Answer) It is generally agreed that the AOH is controlled more by climatic factors than by the 
concentration of atmospheric CFCs, more or less as I hypothesized in 1988.* I note, for 
example, that the 1994 hole was smaller than the 1992 and 1993 events, but of course there was 
no press release. With respect to 1995, 1 will let other scientists speak to the issue: 

The latest example of "science by press release" is the scare story about a massive ozone 
hole, fed to the media in Sept 1995 by the Geneva-based World Meteorological 
Organization. "At its present rate of growth [it] might grow to record-breaking size...," 
said Rumen Bojkov, a well-known WMO alarmist But then again, it might not- 
according to NASA scientist Paul Newman. Australian meteorologist Paul Lehmann 
agrees: The hole will change its shape, volume, and size daily as it grows; he concludes 
that its final size is not predictable by comparing data now with those of a year ago. 

6. Please comment on EPA's cost-benefit analysis for a CFC ban, and comment particularly 
on the costs and benefits for poorer nations. 

(Answer) I am completely puzzled by the unrealistic benefit numbers, up to $32 trillion, put forth 
by EPA. The numbers seem to be growing, in spite of the reduced skin cancer threat from a 
putative ozone depletion. Their methodology should be presented in detail and then carefully 
examined. I suspect that they've not dealt realistically with the number of deaths from melanoma 
and non-melanoma skin cancers. I also suspect that they have used an unrealistic discount rate 
in arriving at a benefit-to-cost ratio of 700 to 1000. 

As far as tropical nations are concerned, their benefits would be close to zero, since ozone 
is not predicted to be depleted in the equatorial region. On the other hand, their costs in terms 
of morbidity and mortality will be very much higher than in developed countries, since they will 
fmd it more difficult to purchase new air conditioners and refrigerators. 

7. The American Academy of Dermatology has linked melanoma and the Antarctic ozone 
hole Please comment 

(Answer) It is true that Dr. Darrell Rigel has testified that skin cancer incidence has more than 
doubled since the AOH developed in the late 1970s. But of course, his statement is misleading, 
or perhaps even designed to mislead: 

• An Antarctic ozone depletion cannot possibly affect skin cancer rates in the United 
States, some 10,000 miles away. 



309 



• Cancers develop only after a latency period of decades. 

♦ Melanoma skin cancers have been increasing, by some 800 percent since 1935, clearly 
related to lifestyle changes and not to any change in ozone. 

8. In his testimony, Dr. Watson claimed that a 1% increase in UV-B radiation would lead 
to a 2% increase in the incidence of non-melanoma skin cancers (NMSC). Do you support 
this estimate? 

(Answer) I believe his result is incorrect. It is derived by noting that the incidence of NMSC 
is five times greater in Albuquerque than in Seattle; (clear-sky) UV intensity increases by a factor 
of 2.5 as one moves towards the equator. But one cannot simply relate the ratio of skin cancers 
to the ratio of UV-B. Watson's high ratio of 2:1 hides two unjustified assumptions: (i) that the 
fraction of clear days in Seattie is equal to the number of clear days in Albuquerque, and (ii) that 
people in Albuquerque walk around in raincoats rather than short-sleeved shirts and typically get 
no more body exposure per day than people in Seattle. When these two assumptions are allowed 
for, the skin cancer-to-UV ratio may well drop by a large factor. 

9. Please comment on the need and urgency for a production ban on methyl bromide. 

(Answer) I have addressed this issue on August 1, 1995, in testimony to the House Commerce 
Committee, Subcommittee on Oversight and Investigations. Briefly: 

• Methyl bromide (MeBr) comes mainly from natural sources, like the ocean. 

• MeBr has a lifetime in the atmosphere of only about 1 year, unlike CFCs. This means 
that if a problem arises and production is stopped, the enhanced level will quickly decay down 
to the natural level. 

• I note that Dr. Watson's testimony constantly refers to "stratospheric chlorine and 
bromine." But there is no published evidence I know of that stratospheric bromine is increasing. 
The amounts present there are minute and extremely difficult to detect. 

10. What would you do about CFCs at this stage of our present knowledge? 

(Answer) As I stated in my testimony, I do not have a vested interest either for or against CFCs 
or other chemicals. Since CFCs are increasing in the atmosphere, a tax rather than production 
controls might be the most appropriate policy measure. A higher price would encourage both 
conservation and recycling, and thereby reduce the amounts released into the atmosphere. 



"Docs the Antarctic ozone hole have a future?" Eos 69. 1588 (1988) 



310 



11. You have expressed doubts about the reality of ozone depletion. Please explain. 

(Answer) It is difficult if not impossible to remove the natural variations from the ozone record 
in order to detect the existence of a small downward trend-presumably due to manmade 
chemicals. The attached graph, taken from a research paper by NOAA scientist Jim Angell, tells 
the story. It shows the strong, but not perfect correlation between total ozone and sunspot 
number, since global ozone measurements were started in 1957. It also shows that each sunspot 
cycle is different Unfortunately, it would require ozone data over many cycles to permit the 
statistical removal of the sunspot variation from the ozone record and allow reliable extraction 
of a small, long-tenn trend. 

The lower graph displays another phenomenon: the great variability of the sunspot 
maximum over the last 300 years, showing the existence of natural trends lasting for decades. 
This means that an observed ozone trend, even if real, may not necessarily be anthropogenic; it 
could be natural. 



2 

2 

2 


1 1 1 


1 

NORTH 


\/' ^ ^ 


POLAR 
NORTH 


-v/ ' ^-^ 


TEMPERATE 



uj 100 




1960 1970 1980 1990 

Fi(Brc I. Toul ozone chanjc On %) *<><! snaipoc oninbcr (Antell. 1919). 




FipacZ. Aiowal mean unupot nnsber R It ouxinu of (he ll-ycyclc. A.O. 164} >a 
present, to deaoosruc lont.iena trendi in solir jciivity. Evident is the IO-ye*t "CleiJJ- 
berg cycle" (cxireou ihown « tritn jlej) impojcd on i pcniuent tiie jinee the M»onder 
• Minimum. 



Appendix 3 

Remarks by 

Dr. John H. Gibbons 

Assistant to the President for Science and Technology 

Sound Science, Sound Policy: The Ozone Story 

University of Maryland at College Park 

September 19, 1995 

Good morning. I'm delighted to be here to talk to a group that 
includes the next generation of environmental scientists and engineers. 
It's appropriate to be talking today to those who will be conducting 
research and developing policy in the future because what is happening 
now in Washington will shape your opportunities. This is Ozone 
Awareness Week and the ozone story is one of the best examples I 
know of sound science leading to sound policy. However, at the same 
time that we celebrate this success, investments in environmental 
science and technology are under attack in Congress under the guise of 
balancing the budget. 

Achieving a balanced budget is also a priority for the Clinton 
Administration. We're in our third year in a new era of deficit 
reduction, and that hasn't happen since Truman was President. But this 
Administration is committed to balancing the budget while maintaining 
investments in the future, in education and science and technology. We 
believe that deficit reduction and wise public investment are totally 
consistent goals. It's no accident that industries that grew out of 
federal investment in science and technology ~ industries as diverse as 
agriculture, aeronautics, computers, biotechnology and medical equipment 
- today dominate the world's markets. In fact, economists estimate 
that over the past fifty years, innovation has been responsible for as 
much as half of our Nation's economic growth. Science and technology 
are key for a strong economy, for public health and safety, and 
improving environmental quality. We must continue a strong commitment 
to environmental R&D so we can better understand how the global 
environment ~ our life support system - actually works, and how to be 
wise stewards of that support system. Over the long-term this kind of 
investment pays enormous dividends to the people. 

Let's look at an example of one such payoff - the stratospheric 

(311) 



312 



ozone story. I'm sure most of you know what ozone is — a 
fascinating, highly reactive, unstable molecule consisting of three 
atoms of oxygen. Ozone occurs both near the Earth's surface ~ where it 
is a major constituent of smog, and in the region of the upper 
atmosphere six to thirty miles above the surface. Paradoxically, while 
surface ozone is harmful to human health and the environment, the 
"other" ozone - that in the stratosphere - is absolutely necessary for 
life. 

Research has been key to understanding stratospheric ozone 
which blankets the Earth and helps make it a liveable planet. 
Stratospheric ozone forms an invisible shield protecting us from the 
hazardous ultraviolet - or UV - radiation that streams towards the Earth 
continuously from the Sun. UVB radiation can directly harm people. 
For every 1% increase in UV-B radiation, there will be an about a 2% 
increase in non-melanoma skin cancer in light-skinned people. We 
currently have about 750,000 new cases each year in the U.S., of which 
between 1/2 to 1% will result in death. Increased exposure to UVB 
can also cause cataracts—already the 3rd highest cause of blindness in 
the US. Increased UV-B is also associated with decreased immune 
system response in all populations. 

Without the Montreal Protocol and its amendments (international 
agreements to phase out ozone-depleting chemicals), we would be 
facing future increases of 40-50% of UV-B in the next century as 
opposed to expected peaks of 6-7% in the summer/fall and 13-14% in 
the winter/spring. 

The story of how we reached these international agreements 
began twenty years ago when two research scientists, Mario Molina and 
Sherwood Rowland, hypothesized that chlorofluorocarbon molecules 
(CFCs) are stable enough to diffuse to the stratosphere where the sun's 
ultraviolet radiation would split off the chlorine atom, whereupon each 
chlorine atom would act as a catalyst, destroying thousands of molecules 
of ozone. 

Back then there was little but laboratory data to support the 
theory. No one had looked for an ozone hole in the sky- - we didn't 
even have the tools to try. There was no long-term record 
demonstrating that ozone levels were declining on a global basis. There 



313 



were no satellite, aircraft or balloon-based measurements of trace gas 
species showing the intermediate steps in the process leading to 
chlorine-driven destruction of ozone. In fact, all we really knew was 
that CFC concentrations in the atmosphere had been rising and that a 
seemingly plausible, but unproven, hypothesis existed that chlorine from 
CFCs could destroy ozone. 

CFCs were invented in the early 1930s as a replacement for 
hazardous compounds like ammonia then widely used as refrigerants. 
CFCs are odorless, extremely stable, relatively non-toxic and 
nonflammable. Not surprisingly their use quickly spread to a wide 
range of industrial and consumer applications, from refrigeration to 
aerosols propellants to foam products and eventually as solvents in the 
electronics industry. 

Given the scientific consensus that now exists, it is hard to 
imagine the controversy that surrounded this theory two short decades 
ago. In part, this controversy was driven by the lack of clear and 
convincing evidence in support of the theory, but also largely because 
of concern that CFCs were critical to our quality of life and no 
substitutes existed to replace them. 

How then did we quickly evolve from a politically charged 
situation in the late 1970s to today where 150 nations of the world have 
agreed to phase-out CFCs by the end of this year in all developed 
countries and soon thereafter in developing countries? 

First and foremost, this issue has been driven by major and 
definitive advances in our scientific understanding. We have gone well 
beyond our rudimentary knowledge in 1974 of the impact of CFCs on 
ozone chemistry. While uncertainties remain, we are confident about 
the atmospheric processes that control stratospheric ozone and the role 
that CFCs and other chlorinated and brominated compounds have on 
those processes. 

The most striking example of this concerns the so called 
Antarctic Ozone Hole. When ground-based and satellite data were first 
published showing the existence of this ozone hole, which opens in the 
Antarctic spring, the scientific community, not to mention the public at 
large, were taken completely by surprise. No models or theories had 



314 



predicted any such phenomenon. At first, the scientific community was 
at a loss as to explain its cause. Was it due to CFCs, the result of 
some meteorological conditions, or was some other unknown factor at 
work here? Was the condition unique to Antarctica, to polar conditions 
in general, or likely to affect global ozone levels? 

These were more than interesting questions for the scientific 
conmiunity to debate. Just about the same time news about the ozone 
hole surfaced in the scientific literature, nations were coming together 
to discuss what actions they should take to protect the ozone layer. 
But a definitive policy decision was dependent on a sound scientific 
understanding of the issue. 

In what must be considered record time and with broad 
international and public and private sector cooperation, two major 
scientific campaigns were organized in 1987 and again in 1988 to 
collect data concerning the Antarctic ozone hole. Based on extensive 
field measurements, lab experiments and modeling, the consensus view 
emerged that CFCs cause the depletion of ozone over Antarctica. 

This finding brought a sense of urgency to policy makers. As 
we all know, ozone is a global issue and requires a global response. 
Reductions in the use of CFCs in the United States ~ even though the 
United States was the major source of CFCs ~ were not going to solve 
the problem if other nations continued to expand their own use. 
Subsequently, a series of international scientific studies were 
conducted. These reviews began in the 1970s and were formally 
brought into the Montreal Protocol when it was signed in 1987. They 
have become the bedrock against which policy decisions are taken. 

The original Protocol called for a 50% reduction in CFCs by 
1998, but also called for periodic review of scientific and technology 
issues. The first such review was issued in 1989 and lead to the 
Parties agreeing that on the basis of new scientific information that 
even greater reductions were needed to protect the ozone layer, and that 
chemical substitutes had advanced enough to make practical the full 
phase-out of CFCs by the end of the century. I'd like to emphasize that 
extraordinary technological progress in developing CFC alternatives by 
the industrial sector permitted a faster phase-down. A similar process 
in 1992 led to agreement that CFCs would be phased out in the developed 



315 



world by the end of this year. The recent 1994 international assessment 
of the situation confirms the soundness of the science and phase-out 
policy. 

Let me summarize the evidence that is now very clear and broadly 
accepted by experts around the planet: 

1 . There is no doubt that the major source of atmospheric chlorine 
and bromine is from human activities (e.g., CFCs and Halons), 
not from natural sources such as volcanoes or sea spray. 

2. There is no doubt that downward trends of stratospheric ozone 
are occurring at all latitudes, except the tropics, during all 
seasons. Extensive ground-based data and satellite data have 
shown that since 1970 ozone has decreased by about 5-6% in 
summer and 9-11% in winter/spring in northern mid-latitudes, 
and by 8-9% at southern mid-latitudes on a year-round basis. 
The weight of scientific evidence suggests that the observed mid- 
latitude downward trends of ozone are due primarily to 
anthropogenic chlorine and bromine. 

3. There is no doubt that the spring-time Antarctic ozone hole is 
due to anthropogenic chlorine and bromine — based on combining 
ground, aircraft, balloon and satellite data, with laboratory data 
and theoretical modeling. 

4. During periods of declining ozone, stations in Antarctica, 
Australia and mountainous regions in Europe, have shown that 
ground-level UV-B increases, as expect 

5. The rate of increase of atmospheric chlorine and bromine in the 
atmosphere has slowed considerably in the last few years, 
demonstrating the effectiveness of actions taken under the 
Montreal Protocol and its amendments. Even so, and if 
everything goes forward smoothly, the mid-latitude ozone loss 
and the hole over Antarctica are not expected to disappear until 
the middle of the next century 

While the story I have told so far shows science, technology, 
and policy moving forward in harmony, I must also report that recently 



316 



a discordant note has been struck. Amazingly, there are those today on 
Capitol Hill who don't want to believe that the ozone hole exists, who 
won't trust the evidence of startling observations year after year 
showing a hole over Antarctica the size of the United States. Just last 
week, the World Meteorological Organization announced that the hole is 
beginning to open again, as predictable as Old Faithful. Within a few 
weeks, some 60% of the total overhead ozone will be depleted. 

Even as the hole opens. Congress is holding hearings tomorrow 
to question the science of ozone depletion and the soundness of the 
phaseout. Incredible. The scientific community has spoken time and 
time again, with a virtually unanimous voice, that the phenomenon is 
real, and the problem is immediate and that fortunately, due to early 
action, effective chemical substitutes for CFCs are available. Industry 
agrees. 

Yet, tomorrow. Congress will give a few vocal skeptics equal 
standing with the hundreds of scientists represented by the 
international assessments. Such ideologically driven attempts to paint 
a distorted picture of the scientific consensus on climate change and 
ozone depletion are highly regrettable. You can not wish ozone holes 
away. Refusing to face the facts won't change the facts. Healthy 
skepticism is an essential and treasured feature of scientific analysis. 
But willfiil distortion of evidence has no place at the table of 
scientific inquiry. 

I firmly believe that the American people expect the federal 
government to support science and technology so that we can continue 
to discover, learn about, and deal with phenomena like ozone depletion. 
The American people do not want this country to put its head into the 
sand and hope that problems simply go away. They understand that 
ignorance is assuredly not the route to our salvation! 

Congressional leaders have said they want to fully support basic 
scientific research. But their proposals to cut the funds for global 
climate change research - including funds for stratospheric ozone 
research - suggest their deeds do no match their words. For example, 
though over a trillion dollars of insured property along the U.S. 
Atlantic coast is vulnerable to sea level rise caused by global warming. 
Congress is proposing major cuts in the research needed to help protect 



317 



this investment. Despite one of the worst hurricanes seasons in 
decades, scientific research at NOAA aimed at understanding climate is 
targeted for cuts of between 30 and 40%. NASA's Mission to Planet 
Earth, which combines satellite measurements with ground-based research 
and analysis in the first comprehensive study of the planet we live on, 
was slated for a $300 million (25%) cut next year by the House of 
Representatives. Fortunately, and due in no small part to the 
leadership of your Senator, Barbara Mikulski, the Senate has not gone 
along with this extreme action, limiting their cuts to $60 million. 

Proposals to eliminate the National Biological Service and the 
Environmental Technology Initiative, eviscerate the Superfund research 
budget, and slash more than 40% of the funding for energy efficiency 
and renewable energy research rest on the same know-nothing stance as 
do proposals to gut the effective enforcement of the Clean Water Act 
and the Clean Air Act. Unbelievably, just last week Congress attached 
riders on to the budget reconciliation bill that would disband all 
Department of the Interior surveying and mapping activities by October 
1996. If enacted, it would end research on water quality, natural 
hazards, land use, and ecosystems. Does Congress really think we don't 
need maps to chart our way forward? 

Although Congress continues to profess support for regulatory 
decision making based on sound science and credible economic analysis, 
their actions belie their rhetoric. They say they favor more risk 
assessment and cost/benefit analysis, yet they are cutting the very 
research programs that provide the scientific information required to do 
such analysis. 

Not only does Congress not want to know some of the answers, 
they also don't want you to know. For example Congress has proposed 
to severely limit the public's right to know by limiting expanded 
information on chemical releases into communities. We think citizens 
have the right to know. The House Appropriations bill for the 
Department of Transportation even includes a rider prohibiting the 
labeling of tires for rolling resistance so that consumers won't know 
which will help them save gas ~ and money. 

But we know that lack of information is always more expensive 
in the long run. A successful market economy fundamentally depends 



318 



on the availability of accurate information. We in the Clinton 
Administration believe that rather than putting our heads in the sand 
and blindly groping for short-term budget savings, we recognize and 
protect key investments for the future - investments that are just as 
important as debt reduction and will lead to real, long-term 
improvements in the economy, environment, health, and security. 

Some crises in the global environment, like ozone depletion, 
climate change and loss of biodiversity have long time constants— on the 
order to decades to centuries to develop and, if they can be reversed, 
the time needed for recovery is much longer~on a time scale 
somewhere between human and geological time. Political time scales 
are more often on the scale of hours to days. 

Rene Dubos recognized our focus on fast-changing or short-term 
phenomena as one of the great tragedies of humankind. Adlai 
Stevenson spoke about Americans in particular as "those people who 
never really see the handwriting on the wall until their backs are up 
against it." The crises I see developing cannot be solved by ignoring 
them. In fact, they will continue to grow worse as long as we refuse to 
address them. 

Those of you sitting in this room will be part of the group that 
must address, and I hope, help us solve these problems. But we today 
must assure that you have the tools for that task tommarrow. If our 
nation is to be a leader in the 21st century, it must excel in 
education, science, and technology. The nations that are able to take 
advantage of new opportunities and that can respond to environmental and 
economic challenges will be our future leaders. They will be nations 
geared toward the future, not the past. 

Many members of Congress are acting upon the general 
impression that government is inevitably intrusive and wasteful. This 
Administration disagrees. We believe that the government can be a 
force for good in the life of the nation ~ that government can help 
create, for the future, a more perfect union ~ and we will stand by 
that conviction no less fervently than the Founding Fathers. The 
lessons of stratospheric ozone: scientific discovery and analysis, 
innovative technology, invention of substitutes, and diplomatic 
agreements of cooperation between governments can combine to avert majo 



319 



planetary problems. Let us see this episode through successfully and 
apply its lesson to the other challenges that beset us. To do less 
would be to betray ourselves and our children. 



320 



EXECUTIVE OFFICE OF THE PRESIDENT 
OFFICE OF SCIENCE AND TECHNOLOGY POLICY 

WASHINGTON, DC- 20500 



October 11, 1995 



The Honorable Dana Rohrabacher 

U.S. House of Representatives 

Chairman 

Subcommittee on Energy and Environment 

B-374 Raybum House Office Building 

Washington, DC 20515 

RE: Hearing on "Stratospheric Ozone: Myths and Realities," Wednesday, 

September 2, 1995, 9:30 a.m., Room 2318 of the Rayburn House OfTice Building 

Dear Mr. Chairman: 

The purpose of this letter is to clarify my answer to a question asked by 
Congresswoman Rivers before the Subcommittee on Energy and Environment, "Hearing on 
Scientific Integrity and Public Trust: The Science Behind Federal Policies and Mandates 
Case Study 1 — Stratospheric Ozone: Myths and Realities" on September 20, 1995. 

The following paragraphs reflect the text I wish to clarify (currently page 105 of the 
printed testimony attached, line 2468): 

"... Ms. RIVERS. Before I do that, I would like to ask Dr. Watson, Dr. Albritton, 
Dr. Setlow, and Dr. Kripke, if they are familiar with a publication called the Journal of the 
Franklin Institute, with what regard that journal is held in the scientific community, and if 
they know whether or nor it is maintained in the library of the institution at which they 
work? 

Dr. WATSON. This is a journal that came to my attention this morning for the first 
time. It is not in the library of the White House. It began in 1994, with a circulation of 400 
people. 

It is obviously in a number of libraries and businesses and a number of institutions. 
We understand the circulation is 400. 

Ms. RIVERS. Okay. Dr. Albritton, are you familiar with it, or is it in your 
institution? 

Dr. ALBRITTON. That journal is not in our institution. I'm not aware of it, nor 
have I heard it discussed at ozone-related scientific meetings. 

Ms. RIVERS. Okay. Dr. SeUow? 



321 



Dr. SETLOW. I'm familiar with it from my early, early days as a physicist, but I 
have not seen it for many years and, to the best of my knowledge, it is not in our institution 
at the present time. 

Ms. RIVERS. Dr. Kripke? 

Dr. KRIPKE. I've never heard of it." 

I wish to clarify for the record that the journal Congresswoman Rivers was referring 
to in her initial question cited above was, TECHNOLOGY; Journal of the Franklin Institute 
not Journal of the Franklin Institute. These are two distinct journals, published by two 
separate publishers. 

S. Fred Singer's four page commentary titled, "Commentary: the ozone-CFC 
debacle: hasty action, shaky science," appeared in TECHNOLOGY: Journal of the 
Franklin InstiOite, Vol. 332A, No. 1, 1995. 

I have confirmed with Bob Miranda (914) 592-7720 an employee of the 
TECHNOLOGY Journal's publisher. Cognizant Communications Corporation, Elmsford, 
New York and the Library of The Franklin Institute (215) 448-1200 that TECHNOLOGY: 
Journal of the Franklin Institute was first published in die latter half of 1994 and has a 
distribution of 400. 

The Journal of the Franklin Instimte - first published in 1826 ~ has been in existence 
for approximately 170 years, and is as old The Franklin Institute itself - established in 1824 
in Philadelphia, PA - the same cannot be said for TECHNOLOGY. 

Dr. Setlow's response that he was familiar with the Journal was undoubtedly in 
reference to the Journal of the Franklin Instititte not TECHNOLOGY. 

For your convenience, I have included the cover page and publisher information for 
TECHNOLOGY. 

I would like a footnote added to the text of my response directing readers to an 
appendix which corrects any misunderstanding about the publication in question. 

If you have any questions pertaining to this letter or any other matter, please call me 
at (202) 456-6202. 



Sincerely, 



Robert T. Watson 
Associate Director for Environment 



323 



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GEORGE C. MARSHALL INSTITUTE 

1730 M Street. N.W., Suite 502 
Washington. D.C. 20036-4505 



October 19, 1995 



Chairman Dana Rohrabacher 
Subcommittee on Energy and Environment 
United States House of Representatives 
Washington, D.C. 20515 

Dear Mr. Rohrabacher: 

During testimony before the House Subcommittee on 
Energy and Environment on September 20, 1995, 1 was asked to 
provide certain information to the Subcommittee, in v*n-iting. 
The information requested concerns evidence for a lack of free 
and open inquiry in scientific matters related to global change 
research. 

First, it may be helpful to provide some information on 
my background. I received my PhD degree in astrophysics from 
Harvard University in 1980 and have been a research physicist at 
the Harvard-Smithsonian Center for Astrophysics in Cambridge, 
Massachusetts, since then. I am a contract employee of the 
Smithsonian Institution; that is, my salary, benefits, overhead, 
rent, supplies, support for my scientific experiments, equipment, 
etc., including the costs of student researchers, employees and 
scientists working on my programs are funded by contracts. 

Enclosed is my curriculum vitae; as noted, I am also Depu- 
ty Director of Mount Wilson Institute — which has managerial 
responsibility for Mount Wilson Observatory — whose physical 
plant is worth roughly $70 million. The Observatory is where 
the bulk of my research has been conducted since 1980. In addi- 
tion, I serve as Senior Scientist at the George C. Marshall Insti- 
tute, a nonprofit science and public policy research group. I also 
donate considerable cime to science education, especially for 
programs helping minority and female students. 

I have authored and co-authored more than 125 papers in 
the peer-reviewed literature; a list can be provided upon request. 

This brief introduction is intended to demonstrate that I 
have been successfully competing for scientific funding through- 



325 



out my professional life. It was thus a great disappointment to learn that scientific 
competence is not always the dominate factor in climate change research. 

At scientific conferences, conversations on the deterioration of scientific 
ethics in global change research are common. I suspect this deterioration reflects 
the effect of increased competition for increasingly scarce scientific funding. 
Three personal experiences follow: 

1. In April, 1990, 1 attended a climate change symposium at Goddard Space 
Flight Center, in Maryland. At that meeting I had a coffee-break conversation 
with an official in the atmospheric science program of the National Science 
Foundation (NSF). I asked for information on the possibility of applying for 
funds to study the impact of long-term variations in the Sun on both the earth's 
climate and the ozone layer. The research rationale is that the Sun's variations 
are one of several natural influences that must be accurately known so the best 
estimate of the human-made effects can be determined. 

I was told such research would not be considered for funding because it 
might raise doubts regarding the importance of anthropogenic influences on the 
environment. I was further informed those doubts could have two undesirable 
consequences: first, they would give policymakers an excuse to forego mitigation 
efforts; second, they would jeopardize the possibility of getting more funds for 
climate change research The next day at the meeting, I asked the official to 
clarify his position. I was told never to mention the conversation had occurred. 

I do not know if the views of one official would actually affect the proposal 
process. However, my status as a researcher, who needs successful proposals to 
survive, meant I never pursued the matter; and indeed, I never submitted a 
proposal to NSF in the area of climate change. 

2. Prior to my September 20, 1995 testimony before your subcommittee, 
pressure was exerted on me by the advocacy group. Ozone Action. In a July 28, 
1995 issue of Ozone Action News, this organization described me as one who 
"... gather[s] bad out-of-date studies..." on stratospheric ozone variation. There 
was no evidence offered to substantiate of this claim. On September 18, Ozone 
Action called the Public Relations Office of the Smithsonian Observatory to ask if 
my pending testimony were an official position of the Smithsonian Institution. 
The Public Relations Office responded that my testimony was not official. 

The next morning, September 19, Ozone Action sent someone to inspect 
the 990 taix forms of the George C. Marshall Ir\stitute, in order to determine the 
source of funding for my work at that organization. Later that day, the Public 
Relations Office of the Smithsoruan sent me a message that Ozone Action had 
faxed to that office the cover of one of my Marshall essays on ozone. Ozone 
Action included the brief biography that the Marshall Institute provides for the 
authors of its reports. My biography included the fact that I am a scientist at the 
Harvard-Smithsonian. The voice-mail message from the Public Relations Office 



326 



of the Smithsonian said Ozone Action was "desperate to link my testimony to 
the Smithsonian." 

Such conduct by Ozone Action was, I oelieve, meant to engage institutional 
pressures on me not to appear at the hearing. The result of this intimidation was 
that late on the eve of the hearing, I drafted a letter to you withdrawing from 
testifying. The letter was never sent because I decided not to succumb to these 
tactics and to appear anyway. 

3. My cortfidence in the p)eer-review process has been shaken by an episode 
involving the editors of the journal Nature. In October, 1992, my colleagues and 
I submitted a manuscript to Nature on work relating to changes in the Sun, 
which might have impact on terrestrial climate change. The manuscript re- 
ceived treatment unprecedented in my 15 years of experience. Briefly: The paper 
was held in the review process for 14 months and apparently went through five 
different referees and three different editors. After two referees accepted the 
paper, the editors kept trying until they found a referee who would recommend 
rejection. This violates Nature's stated policy of accepting manuscripts approved 
by two reviewers. 

Even more indefensible, one reviewer suggested our resiilts were a direct 
consequence of my funding from a foundation supported by an oil company.^ 
The clear implication was that I had doctored my findings to please a corporate 
interest. This was a mere assertion, however, since the reviewer offered no 
evidence to support this attack on my integrity. Yet the attack was implicitly 
accepted by Nature's editors since it was forwarded by them to us without 
comment or disavowal. 

After this shameful episode, we submitted the manuscript to the most 
prestigious journal in astrophysics. The Astrophysical Journal. The Astro- 
physical Journal accepted it for publication immediately. 

The lack of editorial objectivity in some scientific journals, as I have 
described briefly, raises questions about the peer review process. Enclosed is a 
p>erceptive comment on this matter by Dr. David Goodstein, Vice Provost and 
Professor of Physics and Applied Physics at Cal Tech, which recently appeared in 
The American Scientist. He describes the breakdown of the peer review process 
as a result of increased competition for decreasing research funds. 

The situation has deteriorated in the last year. In September, 1994, a press 
statement released by Intergovernmental Panel on Climate Change (IPCC) offi- 
cials stated that "The world's climate is at serious risk." This press statement was 
drafted before the meeting of the panel of scientists advising the IPCC at which 



'The particular choice [of analysis] made in this paper, and its implications for the global 
warming debate, may be considered desirable by some of the sponsors listed in the 
acknowledgements, but it is not science." Anonymous reviewer for Nature, December 31, 
1993. 



327 



the findings referred to in the press statement were supposed to be disctissed. In 
violation of IPCC rules, the scientific drafts had not been distributed to partici- 
pants prior to the meeting. The scientists on the IPCC panel were not even 
informed of the existence of this IPCC release beforehand, although it nominally 
represented their opinion. An editorial in Nature ^called this "commurxication 
by press release" and "a rotten way to conduct international business." 

In December 1994, a conunentary in Nature ^referred to the "rapid politi- 
cization of the climate debate" and concluded, "Under pressure, even scientists 
will deliver what their paymasters prefer to hear." 

As you see, my experiences are a part of a much larger problem. I hope this 
information, requested by the Subcommittee, is helpful. 

Sincerely, 

Sallie Baliunas 

Enclosvires: Cvuriculum Vitae 

American Scientist commentary on deterioration of peer review 

Nature editorial on IPCC press release 

Nature commentary on politicization of climate change research 



Z "IPCC's ritvial on global warming," Nature 371, 269 (1994). 
3. Nature 372, 402 (1994). 



328 



SALLEE BALIUNAS, Astropiiysicbt 



ACADE\aC APPOINTMENTSj 



19%0-preseni 
\9S9-present 

1990 
1980 

EDUCATION: 

1980 

1975 
1974 



Astroidiyricist, Smithsonian Astrophysical Observatory 
Adjunct Professor, Center of Excellence in Information Systems 

at Tennessee State University 
Visiting Scholar, Dept of Physics and Astronomy, Dartmouth College 
Reseaseb Associate of Harvard College Observatory 



Ph.D. Harvard University 
A.M. Ibrvaid University 
B.S. Villanova University 



HONORS AND PRIZES: 

1993-1994 Wesson Fellow, Stanford University 

1988 Bok Prize. Harvard University 

1988 Newton Lacy Pierce Prize, American Astronomical Society 

1987 Villanova University Alumni Medallion Award 

1980-1985 Langley Abbot Fellowship, Smithsonian Institution 

1979 Donald E. Billings Award in Astro-Gcopbysics, Univ. of Colorado 

1 977- 1 979 Amelia Earbeait Fellowship, Zonta International Corp. 

OTHER APPOINTMENTS: 

1991-present Deputy Director, Mount Wilson Institute 

1969-pnsera Member, Board of Trustees, Mount Wilson Institute 

1993-prejrenr Board of Directors. Astrooomic&l Society of the Pacific 

1993 Committee of Visitors, Astronomical Sciences, NSF 

1992-pr«CT»/ NSF Advisory Committee for Astronomical Sciences (ACAST) 

1992-1993 Ptar Review Panel on Carbon Dioxide Limits for Tennessee 

Valley Autfaority 
1992-prgsent NSF-RKE (Radiative Inputs from Sun to Earth) Steering Ctte 

1990-1993 NASA Science Operations Management Operations Working 

Qioiq) (SOMOWG) 
1987-91 Chaitman, Sdeooe Advisory Board, Mount Wilson Institute 

1 984- 1 987 AURA Observatoiics ' Visidng Committee 

International Ultraviolet Explorer (lUE) Satellite 

1985-87; 1989-92 Users' Gotnniiltee 
]9^i-present Guest Invcstigalor 

1989-1990 Sciendflc Oigwuzing Committee, NASA/ESA/SERC 

lUE Synyo siu m. Toulouse, Prance 



329 



Automaiic Photoelectric TeUscopeJ (AFT) 

l9iS-preserU Organizer, 3nl and 4th Summer Workshop 

\9i6-present Science Advisory Panel, Smithsonian-Faiibom Observatories 

1988-1991 Co-otsanizer of 9th, iOth, 1 1th IA.P.PJ». Symposia 

Editorial, Educational and Other Advisory Appointments 

1993-prtsent Chair, E^iotial Board, Publications tf the Astronomical 

Society of the Pacific 
1 99 M 994 Editorial Board, Solar Physics 

\99Z-present Organizer, Smitltsonian Institution Associates Annua] 

Expedition to Mount Wilson Observatory 
1991-prf5«n/ Chair. Science Advisory Board, George C. Marshall Institute 

1992-1993 Scientiflc Organizing Committee, lAU CoUoq. 143, Solar 

Irradiance Changes 
1992-1993 Organizer, American Association of the Advancement of Science session, 

What Attropkysics Can Tell Us about Climate Change, Boston. MA, 1993 

1992 Guest Editor. Annual Review of Astronomy and Astrophysics 

1993 Scientific Organizing Committee, Optical Astronomy from the Earth 
and Moon, lOSdi Meeting of the Astronomical Society of the Pacific. 
San Diego, CA. 

1989-1990 Science Advisory Board, George C. Marshall Institute 

1992 Editor, Proceedings of Robotic Observatories Symposium 

1989-1990 Science Panel, Astronomy and Astrophysics Survey Connnittee 

(J. Babcall, Chairman) 
1989-1990 Co-Chair. Scientific Organizing Conunittce, 101st Meeting 

AstrowMnical Society of the Pacific, Boston, MA 
1989 Chair. ROSAT X-ray Satellite Peer Review Panel. Hot Stars 

1987-1992 Astronomy Committee. Maria Mitchell Observatory 

\W1 -present SYNCM" Steering Coraraittec, NOAO 

\9i5-presera Lecturer, Smitlisonian National Associate Program 

\S9\ -present Advisory Board. Learning Technology Center, Vanderbilt 

Univenity 
1984 Editor, Proceedings of the Third Cambridge Workshop on Cool 

Stars, Stellar Systems and the Sun 
1981,1983 Organizing Committee, Cambridge Cool Stars Workshop n. m 

PROFESSIONAL SOCIBTIES: 

American Astronomical Society 

American Geofriiysica] Union 

American Physical Society 

Astronomical Society of the Pacific 

International Astronomical Union 

Sigma Xi 

Solar Physics Division, American Astronomical Society 



P. 07 



330 



M.\>. i.( A^I^H't 



Peer Review 
after the big crunch 



David Goodstein 



According to modon cosntalogy, the uni- 
verse began about 10 blUlon years ago in 
an event known as ths Big Bang. It has 
been expanding ever since. VSfie do not know 
whether it will go on ei^andlng forever, li the 
density of matter in the universe is suffidentiy 
lai;^. gravitatioru] (oroe* wUI eventually cause it 
to stop expanding and tfi«n to start filling back 
in upon itself. U that happens, tine universe will 
end in a second catadytinic event Aat cosmoki- 
gists call the Big CncKK 

I have a rather anaiogov* theory of the histt>ry 
ot science. According to thia theory, modem sd- 
erwe appeared on the scene in Exirope almost 300 
years ago, and in this coontry a littla more than a 
century aga In each case it prooeadcd to expand 
at a frightening exponential rate The phenotne- 
ncw is shown on Figiue 1, a eemt-logarithinic plot 
of number versus year. The upp«r curve, first 
published around 1960 by Derek da Solla Price, 
shows the cumulative nmnber of scientific jour- 
nals founded worldwide. For 200 vears, from 
1750 to 1950 (when the plot was ir»<te) the num- 
ber increased by a factor of 10 every 50 years, ex- 
trapolating to one million today (there are actu- 



Dmui L Caodsltin is vie* pnsaH *iti fnfaaai ofpltyiia and 
tpplitd ^ytit$ M Iht OJifomit liutUtiHofVKluiolag^, ahcrr 
ht ku btm m Ihe /araltif for mart Uxm IS yon. In 1995 he 
lull rwmnl iks Trmnk I. GlUoan DHHngialtBl Ttanhlitg tnd 
Savin Pnfaior. H«« Ihtnlharafmair Hmn 100 nrxnortur 
IkksMdthtbookStatmofMtmt.piMhiitiim l975byPtm- 
Itce Hull and rciuiieiliyDootT Plot in 7985. Hf ArMtmwion 
Kiimtrvus KitiKt ami aadanie fmndt, indydlns Hic SnuuUng 
Rti'Inr Board of lilt KKiTUescofttod ttm CommHm on Eifual 
OpporlHitiites in Scrcncr gnd EMfinerring, a Ntrtional Science 
tmniLiiiiin ontiiglii eemmiUte- HtitOie hoti ami pnietl A'- 
rcKlor of "The t'lfChankitt UnivtrM." ait atemrd-tri/rnmg and 
fuuitf/y uud 52-iKirl caUtgt phynfc* tdttoune koni on Ais pa^ 
ular lecltirts at Calltdt. AMrtU: OgieeoftlK Pmmt. Caltedt. 
PaMdoiii.CA 91123. 



ally about 40,000). To check Price's assertion that 
any measure of the size of science would have 
the same brfiavior, I have plotted on the sanw 
scale a« number of Ri.D.'s granted in physics in 
the United States- That started around 1870, and 
grew even bster for 100 yeari. 

Exponential expansion cannot go on forever, 
and so the expansion of science, unlike the ex- 
pansion of the univeree, was guaranteed to come 
to an end. I believe tiiat in American scienoe, the 
Big Crunch took place about 25 years ago — after 
two decades ^t saw the enormous postwar ex- 



uuu.uuu - 


/ 




/ 




/ 


100,000 - 


/ 




«>« 




/• 




/• 


10,000- 


scientific journals »^ 




•/ 




/ 




^ • . 


1,000- 


^ *•••• 




/ 




/ " .• 




/ 


100- 


4 • 




r 


10- 


. ..^ 




,• • / U.S. Ph.O'a In phyiics 




• / <pwy«^ 


1- 


f , . .■ , 



1800 1900 

year 



Figtu* 1. Th* cad of Sciowc'c Big Bug. 



199S Seplxwber-Oadbtf 401 



P. 08 



331 



pansion of acMlemia and Itw OMtion of eotpo- 
rate and govanunent rtMaxch bboratoria* all 
around ihc US. in rcapoftM to •oonoBik growth 
and the Cold War. Tht^ood tliM|>«nded forever 
arotmd ^970, w one can Mt from the grapK By 
importing ttudents and amploylng Fh-D.'s as 
temporary posidocs, wAhawflMtcKed tinw out, 
pntending that notMnghaa dunfetd' wailing for 
the good time* io return. For a quarter-century 
we ha ve been trying to lgnoi« fl«e end of the 
great expansion of AiMdean idenee. What we 
have to do now is iotv» a pioblann that h«> never 
even occurred to the OMBlologlM: What do you 
do jfter the Big Crund<7 

The crisea moat taUoad about a>« the shortage 
of jobs and reacardi funda. Bttt they are jtist the 
beginning. Under lUaw from dioae problem*, 
other parts <rf ^ tdanttflc enlerpdae have start- 
ed showing signs 0^ dlabaH. Ot« of ttte most es- 
sential U the aurttei of liiancaiy and ethical be- 
havior among sdentlfta. Wiurt had always 
previously bean a p uiatylntell actMalmpyetition 
has now become an IntanM competition for 
scaice resources- The p«bUc am) the scientific 
community have both been shocked in recent 
yevs by an incraase in Sw mxhbtt of case* of 
fraud comnUtted by setantiata^ There b little 
doubt that tht p e ip «tt »t oi» in these cases felt 
tliemsetves under InMnM pieiiuw to compete 
for scarce rMouroas, evon by cheating if neces- 
sary. As the pw a auw InowwJ. this idnd of dis- 
honesty is almost sura la become mote common. 

The pressure fat tmnumn haa become severe 
enough that I believe ana of the crudal piDan of 
tite whole ediflee, peer coviaw, is in grave danger 

Peer review is uwd by adanlifie jounuUs to de- 
cide what to pubbah. K Is alao tawd by gnmting 
agencies to dcdde %vlttliMaaRli <p mq>port Ob- 
viously, sound dedsianB on wh«t«o publish and 
wtut research to auppoct an crudsUy iac^ortant 
totttepnyerhmctinnlnyofadance-fcwnraledl- 
tors uftiaOy send manoKXiptB siaboiitted to tern 
to referees who i«maln anonymous to ttie au- 
tlvMS of the manuscript hmding agencies some- 
times do the same, eygtrily for mall projects, 
and sometimea a aaemb ta -panate of rsMTMS to 
Judge proposals fbr large pcotect*. 

Peer review is quits asood way to identify 
valid adenee. It was wonaatfuUy well suited to 
an eariler era when ptognts in sdanoe was limit- 
ed only by te nuflnbarof good Ideas available. 
Peer review is not at an aoasd, hmivevar, to a^- 
d i fii te an intense campaBnon lui acanoe resowoes 
such as n j s aitl i funds or p*gef in prestigious 
Journals. The reason ia ob«iou* enough. The ref- 
eree, who is always among d«e few cenuine ex- 
perts in the field, has an dbvioua «On&t of inter- 
est. It would take impoasibly high ethkal 
standards for referees to fail to use their privi- 



leged ancnymihr to their own advantage. Moat 
sdhntisti do hcdd themselves to high staiulards 
of integrity, but as time goes on, more and moie 
ref i eietJ have tiieir ethical standards eroded by 
Iha tmfair reviews thsy receive whan thay are au- 
tlvKS. Thus dw wlxoie system is in peilL Peer re- 
view is one anvmg many examples of practioes 
duit were well suited to the time or exponential 
cxpansioa tnit that will become Increasingly dys- 
functional in the difficult future we fac*. 

Editors of scientific jounuds and program offi- 
cers at funding agencies have the au)St to gain 
bom peer review. They steadfastiy refuse to be- 
lieve that anything miglit be wrong wid) the sys- 
tem. Their jobs are made easier because they 
have never had to take rasponsibUlty for deci- 
sions. They are also never called to account for 
their choice of referees, who in any case always 
have the proper credentials. Since ths r ef erees 
p erform a profeaaional service, afanoat alvays 
without pay, dte prioiaty re^xvtsibilUy of the ed- 
itor or program olTiiei is to protect tha referee. 
Thus referees are never called to account for 
what d<ey write in their reviews. As a result dtey 
are able, with relative impunity, to delay or deny 
funding or publication to their rival*. When mis' 
coiuluct of this kind happens, it is the referee 
%vho is guilty, but it is d« editors and piogiam of- 
ficers who an responaible for propagating « sys- 
tem llut makes misconduct almost inevitable. 
TMs kind of misconduct is. I fear, rampant in all 
fields of science. 

Recently, as part of a talk to a large audience of 
mostly young rese arc hers at at extremely prw- 
tigious university, ] outlined titis analysis of the 
crisis of peer review. The moderatoc a famous 
senior sdenUst was incredukMi*. He asked dte 
audience how many disagreed with my heresy 
No one re^onded. Then he asked how many 
agreed. Every hattd in t)w house went up. Many 
in my generadon wish to believ» dwt nooiing im- 
pottsnt has dianged in dte tvay we conduct the 
buaineas of doing scienae. We are wrong. Busi- 
ness as usual is tw kmger a real option for how 
we oof^uct the cntcrerlae of science. 

We mtist find a radically difierent social struc- 
ture to otganize it search and education in sci- 
enoe after the Big Crutch. The institutionB of the 
scientific enterprise cvotved to suit an enviran- 
mant Very difiieiettt fiom dte otte we live in now, 
and torn die one we fMe in the future. Unless we 
can figure out how to guide it, the tianaitian is 
lUc^ to be mesay and p«ii\ful for the partici- 
pants. So fai; we hove iwl even admitted that die 
problem exists- 

I think %ve have our work cut out for us. 

(NMe: A similar tfisnisrtm appssrsd in the /WW issue 
cf Btotec h notogy 113:€1SV 



*n AnMncanSctacrtbtVolmaaa 



P. 09 



332 



NATURE ■ VOL 371 



nature 



22 SEPTEM8ER 1994 



IPCC's ritual on global warming 



If the tUTMt of global wi mli ig !■ wmtmm (vMok cannvt b* dMitad), It dmivti mora aawniy wty* of nwMi« 
4HitiMittatlv» opinion poMlo than tfwt fcfcwid at lart wook'* maa tl i^ at Maaatrleht 



So the giecnhouse effect is reil, then? That will be the fii« 
reaction of those who fead oflast week 's meednji « Vfaasiricht 
of the latergovenuneaal Panel on OiauOt Cban^ (I?CC), 
which is prepsring its second UMSsaMot of the extent to 
which greenhouse gtaes in the atmosphen will aflect the 
Earth's radiatioi: balance. By ail account* (but seepage 274), 
carbon dioxide has contimied to acctuinilata, but ooty half as 
quickly as carbon dioxide is generated by iha cofsbuatioa of 
fuel (The remainder ii probably locked 19 in tbe Moqilwte, 
or dissolved in the oceans, tempotarily or oiherwna.) And 
while the concentratioa of methane in the atmoaphera is 
increasiog at a decelerating rata, IPCC nyi that, molecule 
for molecule, its effect on climate is greater tban pravioutly 
allowed. But interested readers (of whom there are in prin- 
ciple about S billion) will have to wait until the sacietuiat 
has taken account of last wc«k's discussion, and until 
Cambridge University Press has turned the outcome into 
type, before they will be able to weif^ die ({uality of the 
discussion. 

This is a rotten way to conduct intematiottal butlnets, fiu 
more so because literally everyone in the world will eventu- 
ally be affected by it Last week's reports frtMn Maastricht 
suggest that the goal of restraining emissiotu of carbon 
dioxide Mow those of 1990 (the European Union's collec- 
tive goal) will be insufficient even to prevent a ftutfaer 
doubling of carbon dioxide c«icentiation in the atmosphere. 
That has been on the cards from the outset, but the apponioa- 
mem of allowable emissions among the potential claimants 
on them will be a much more difficult ta^ than tfaa negotia- 
tion of the Convention on Climate Changt at Rio de Janeiro 
two years ago, where it must have seemed to many that a 
mere signature could prevent climatic deterioratioti. If IPCC 
is serious (and there is no reason to bti'Kve otherwise), it 
should now be doing everything it can U> make the flirther 
agreements that will be necessary winnable. 

Communication by press release and ''Executive Sum- 
mary" (a euphemism for sound-bites directed at those who 
do not read) is no way In which Co do thai. What the world 
needs i.i a measured criticai review of the literature on 
greenhoiue gases and their effects on climate, perhaps 
covering the period since the last assessment in 1990. That 
IS exactly how the UN Scientific Committee on Energetic 
A(omic Radiation (UNSCEAR) has conducted its business 
since its creation at the instance of the govemmam of India 
in the 1 930%. Such a framework is an entirely suitable vehicle 
for considered opinions on the significance of emerging 



trends, and indeed is particularly well-suited to the consid- 
eration of the global wanning problem, where uturertainties 
BOW extant are likely to be removed as the years pass. A 
useflil fomiat fbr IPCC's reports would be a listing of the 
continuing uncertainties and a periodic discussion of the 
extctit to which they had been removed 

On this occasion, the press release put out from Maastricht 
declares that "Mieicientilic consensus established in 1 990 by 
the IPCC on climate scieiKe still holds". What does that 
mean? Certainly iKSt that IPCC or its sptfosoring afpncies, 
the UN Environmental Programme at>d the World Meteoro- 
logical Organization, were the first to def oe the global 
warming issue (which was almost the single-handed crea- 
tion of Dr Roger Revelle at Harvard Univerttty). Unanim- 
ity? Nobody denies tiiat carbon dioxide is a greenhouse gas, 
but argument persists in the research community about the 
effects on climate. To be persuasive, IPCC must show that it 
has given these issues the respectful considerations their 
origins command. Sadly, we shall not know for some time 
whether that essential obligation has been discharged. Zj 

Discoveries for Africa 

AMca 4o*«fVM « Wg ahM* of tha prhto In oarty homMd 
Qiacoiiorioa * 



The interest of the accounts on pages 306-312 and 330-333 
of the latest austtalopithecine species to be recovered from 
Ethiopia is unlikely to be overlooked. With an age estimated 
at 4.4 million years, Austntlopiihecus ramulus is almost a 
million years older than A. irfarensii and that much closer to 
the probable divergence of the hominid tine from that of the 
Great Apes, estimated by molecular cladists at about 4-6 
million years ago. That means that the most conspicuous gap 
In the pre-human fossil record has been filled even though, 
as always, the need for Amher specimens to yield more detail 
will remain. 

Inienst and importance apart it is important that a few 
temptations should be avoided. The similarity a{A. ramidui 
with the chimpanzee, rather than the gorilla, is remarked on 
by the authors ofthe new discovery as welt us by Or Bernard 
Wood (see page 280). That will lead many to conclude that 
Pun. the chimpanzee, was the closest living rotative to the 
early hominids. But that is inference only, absent a better 
understanding than at present ofthe course of evolution of 



P. 10 



333 



COMMENTARY 



A scientific agenda for climate policy? 



Sonja A. Boehmer-Christianssn 



TtM comptonMntery l wto i* *U of ellmat* icivnttat*, mrtlorail and lnt«fn«t<ona< buraaucraciaa and pollticlaiw Imv« 
so far datarmlnaO tha pofltlcal dynamiea of tta CMuri fnunUfl( dabata. But naoica at* now baglimintf to appaaf. 



Coi^ntovEUY continues to lurrtnind the 
Framework Convention on CliBUie 
Change, signed at the Earth Summit in 
Rio in 1992. While preparations are ooder 
way for the first meeting of Hw sigiu»rtei 
10 the ccnventtotv due to be held in &sr)tn 
next yur, the Kicntific comffluniiy, reprt- 
jenled t;y the IntergowntflMntal ftuwl on 
Qunate Change (IPCC). (i already under 
fitr fur its delay in coning tip with satii- 
(actory advice 

Greater scientifie eartaiatyovar dioute 
change is unlikely until eaity in (he next 
century. Indeed, there are doubti over 
whether we shall ever loiaw eooufh about 
climate change in advance of the policy 
decisioni needed to bead o£f potential 
dangers. Bui poiicymakers cofitraue to 
hope that, with nifBdent fundi n g, the 
appropriate Mientiiic knowledge can be 
produced according to a tmetable. 

The dimat* traaty raquiraa indoitrial 
countries to try to stabilize their nalioaal 
greenhouse gij emintona at 1990 tevell by 
thv year 2000. No binding targets beyond 
2tXX) have been a|peed: hideed, hope* ate 
fading (hat this can be achieved gtobafly. 
At Rio. the treaty was left dcHbetateiy 
imprecise to eoture both that the United 
Slates signed, and (hat the entire iitue 
remam open to future research result*. 

Reductions in emisaions have alraady 
been achieved, though priniBnty ai a 
result of the recession and (for exatnpie in 
the former East Germany) deindusttial- 
iMtion. In some eotintries, (be rapid 
replacetneni of ct>al and ojt by leai car- 
bon- intensive fuels may be tufBcicnl to 
achieve stabilization of emistiom. But 
energy systems are difficult (o turn 
around, and bnth developn>ent goals and 
wiciopolitical expectations ar« stow to 
change 

The problem Ucs not with nature but 
with society. Given this fact wby have 
governments, despite their alleged con- 
cern over climate change, concentrated on 
funding research in the physical sciences 
10 investigate the subject? ^ 9 theae sc i- 

Tiking global warming seriously 
requires giving attention to issues such as 
the choice of fuels and Icchnolngics, ener- 
^ pricing and investments'. High eco- 
nomic stakes are invoWed. A.% a result, 
hiith thu climate treaty and its underiying 
.NcicntiHc debute huve become ^mep( up in 
gloh.il energy politics. The naponsibtlity 
given (u science it great — perhaps too 
much «> f<ir institutions iniTemrtngly 

400 



dependent on 'soft' contract research 
lacotne. 

Scientists naturally prefer to ejEperi- 
■nent with mathematical models of the 
Eanh's various systems free of responsi- 
bility for policy'. Uncertainty is their tecu- 
riiy. Indeed, some can already be seen 
withdrawing from policy involvemenL For 




OMionstratlan against tha UK tax an 
hsa tX b«»— chanaln« social aWtudaa 
maka mora dHfafanea than ila l fcU n f 



others, io dudine the chairmar^ of th e 
f*'^ f l-^ bai wannin gjMll hf^'""* '*" i'"- 

•'^"•inri f"*" « VTV*^" T P'"sr tpateri al- 
ifjnand for a 'new organixing principle' — 
the preservation of the Eanb. Yet global 
warming could not hove entered Interna- 
tional politics without the support of influ- 
ential voices from the scientific 
community. 

How and why did ■dientists create pub- 
lic concern in the first place? And why was 
this taken up — fur tw rapidly (or many 
«cicnii!>is — not only by environinental- 
iits. but also by governments? The politi- 
cal energy lUMdiid to turn a resusirch topic 
into a treaty with major implicatii)fls wns 
getier.ited surprisingly quickly, even 
(hough it can sdll be ;itgucd (hat the tn:a(y 
does little more th.in codify the research. 
diilii oillection and mimitnrinf; needed to 



underpin future national policies. 

MuCta of the answer lies in shifts in tha 
energy market in the 1980$ During this 
decade, both the Cbemobyi accident and 
cheap fossil energy challenged forecasts ot 
energy demand, and imited the involve- 
ment of energy interests in global politics. 
Energy prices generally collapsed in the 
middle of the decade and have remained 
tow. This reversed the situation of the 
1970a, when both the expansion of nuclear 
power and major riisearch and dcvelop- 
inem efforts on tenewable energy tech- 
nologies created major institutioaal 
I 'intetests. By the 19808. these institutions 
flmuid themselves under threat, and there- 
fore began lobbying via well-establiihed 
cbanneta inside governments, leaving 
green rhetoric to ttie media, environmen- 
Vuil givups and UN agencies. 

Global warming can therefore be said 
to have gained its political relevance less 
from scientiCic evidence and speculation 
than from the unexpected collapse of fuel 
prices, which recreated an earlier world of 
, cheap energy. A 60 per cent drop in oil 
prices occurred oi\ly months after scten- 
tisu had made a sweeping statement on 
the possible dangers arising from growing 
fossil fuel consumption. The 'green' ener- 
gy losers consequently tried to 'capture' 
the expected regulatory process, while 
coal (and to a lesser extent oiL for which 
substitution was harder) became the tnain 
villains. 

So far, the oil Industry, rather than 
nudcar power, has been the major win- 
ner. With expensive European coal liicely 
to disappear altogether, aiul the former 
Soviet Union opening up iu resources to 
Tthe West, natural |^ is replacing both 
I coal and nudcar power In unregulated 
rmarkets. Oas has become the 'rational' 
choice for generating eleetridty. with 
lower fuel and labour costs, reduced emis- 
sions, and the added bonus of avoiding 
further investments in costly acid rain 
abatement technologies, such as flue gas 
destUphurizadon . 

Where this strategy aroused protests. 
the greenhouse effect wai cited in fustifi- 
cation. When the C0llap«e of <)il prices 
reduced (ax revenue, the privaiizatinn of 
eleetridty became even more desirable. 
Individual* and firms were urged (o invest 
in eo«:rgy-\aving measures, if only to 
reduce cost increases. 'No regret ptilicies', 
rather than precaution, b«<.-ame the 
respiiniie ni scientific uncen,iimy As » 
result, piiiicies could he rationalized a.s 

NATURE VOL 372 1 DECEMBER 1994 



P. 11 



334 



COMMENTARY 



.'ironmenial. even though adopted for 

rer reamns. The nuclear kibby had 

Kcted to rv*p a greater reward from i» 

•ly in<.tMn)cni in rc«arth: it now joified 

; chorus calling fur energy prices to 

irrnulize' the external ayU3 of iaciit 

:lv inviting subsidies for itself, or ttxa- 

n tor competitors — preferably both- 

Thc British govemraent, for one. dlv 

vered thaL by changing the fuel mix. 

-polludon control was ^aaible with the 

ppon of industry, leading to lower gen- 

ating costs. EtrWrunmentalists could be 

commodated. as well as vfocal iobfaie* 

pporting energy efficiency and rciiew> 

lies. Still other groups again wanted to 

II cleaner lechnolo^cs to industiializiiig 

luntries — and then promote prtvatiza- 

JB In order to malce profitable Invest- 

ents — or detaandcd constraints on 

.-ivaie mobiliiy. Supporters of the idea of 

.-ological modernization taw cbmate- 

unge policies as step* towards saiatain- 

i4e developmeni Vast amounts of dMa 

n 'global change' would not only aetve 

:sc»rch. but also make the Earth's tur- 

ICC more visible for all who could afford 

) use the ticw Earth observation maps. 

Global warming was also attractive to 

olilicians because of its value to both 

riilcs and supporters of deregulation 

olicics. In Britain, for example, separate 

roups pursuing commercial interests, for- 

Ign policy goab and domestic politics 

ach discovered their own uses for the 

vanning hypothesis- For some, the oppor- 

unities included the pursuit of global 

xaentific research agendas, for otbeix, the 

:nhao«mcni of bureaucratic power at 

10^^^ Some saw the possibility of thwait- 

ng the ambitions of the European Com- 

nission (EC) in Brussels by making sure 

hai decision-making powers remain out- 

iidc EC forums in tbe hands of less effi- 

;ieni — and poorly financed — UN 

hodies. 

Calls for envlroninental regulation 
were generally attractive to environmental 
burcaucraciev Having been created In the 
early 19705. these had remained ralauvely 
weak, and often closely tied to research m 
ihe n-jiural sciences. Global wanning 
allowed national bodies to expand their 
Influence — both domestically and inter- 
nationally — while organizations such at 
the UN Environment Programme 
(UNEP) and the World Meteorological 
Offanizaiinn (WMO) have bcM able to 
attract nwisiderably more aticniion and 
funding. FuRhermore. bekanered 
miiional politicians gained a world stage 
on which m indulge in global green 
rhciimc- Without, as yet, having ui face 
ivrtios of domntic imptvmentatinn. A di- 
mate trtai) became desirable to many 
groups — iHil not major mea.<iures lo 
rctlu^'c cmcviiiin.v 

Wt c;in mm ink h«»w. and why, iKicntif- 
ic' in>iiuition> initialed the dcbaic. and 
ho» Ihcx tiihscqucniK rcvponduJ to iu 

AMTURE VOL 373 1 DECEMBER 1994 




politktoatioo. tn 1985, a group of research 
identisa, ecdiogistt, eUreaic and energy 
demaiid modeUcn laijniy from Sweden. 
Canada, tbe United Suies and the United 
'f-isf*™" OKt in 19SS in VlUacb, Austria. 
UNEP, WMO and the International 
Couaca of SdentiSc Union (ICSU) spon- 
toied tbe oonterenoB, wUch abo attraaed 
nipport from maior anviroamcntAenergy 
reaMrcfc bodk* such as the InwnMitioiial 
Imittute for AppHad Syncais Analytis, 
Harvard Univeraty and the StixUiohn 
EitviRiuiliMK Iitttittite. 

Only MO (overnoietK nentim attend- 
ed Ibis 19SS sytnnodmit, one from the UK 
Meteorological Ofllca. tbe other from tbe 
US Depattmeni of Energy'. The gauntlet 
thrown to the world was therefore largely 
Etimpean, the main chaOcnfen being 
contf a c t reaearcfa fandtutiotw with inier- 
e«ti in the carboti cyde and climatic vari- 
abibty. 

Hm VUladi cotifareace dtew the attert- 
tion of poUcymaken to the dangers of 
global warning, and tbe need for more 
dimate related retearch. ICSU had just 
fmalixed in Iniernational Oeospfacre- 
BfoMriicre Protranme (lOBP). Deval- 
opeo in tbe United Sutes during the early 
19801, and adopted by the ICSU in 1986. 
it wouM addreu tbe problem jointly with 
the Wtorid Climate Researdi Programme 
fWCRP). which had been let op in 1979. 
and was abo taeklag new tasks'. 

Wirmiiv was a high but uncertain risk. 
It was alio expected to happen soon 
if — a* energy demand forecasters pre- 
dicted — CO. concentrations were to 
double within 'decades. This assumption 
has bMIl ioGOtporatcd into all existing 
moM* and adopted by IPCC. with the 
United Sutcs and the Netherlamb pio- 
vidii^ emission sceturio* for the finn 
report in which the dates for such dou- 
bling were (bed. 

In this context, stringent regulations 
would be needed to preveni warming, 
opening up energy nwrkeK to 'green' 
tcchntikigics findudln; fast breeders). 
Pan CO. increatn made wanning intu- 
itively more crediNc. althtiugh cynics 
poinicd iwi that mtidcl prvdictionsi can 
always be munipulaicd. Scvcrul policii 
mvusurvs were ruc«nimviHk-d. iniiuding a 



global legal instrument requiring coun- 
tries to reduce the emtetion of greenhouse 
gases, panicularly CO.. 

The VUlach c o nfci eiice had been oi^a- 
nited by individuali who formed the core 
of the Advisory Oroup on Grcenhooae 
Gases (AGGO). a small panel agreed at 
the cijufet en ce and meant to advise spon- 
sors, as well as go ver n men ts. Consisting 
only of faidcpeadent (nott-govcmment) 
scientists, it remained a major infhienoe 
on UN-related activity until 1990. 

Tbe message erf the ViUach meeting 
Spread rapidly, backed up by the Brundi- 
land Report and its meisage of sustain- 
able developtnani. Diplomatic drdes had 
already been alerted b^ individDals such as 
tbe fbfmcr Biitiah di^omat Sir Crispen 
Tickell, who studied dimate change at 
Harvard while on secondment in the late 
1970a, and has siiKe maintained dote 
links with scientists in Europe and the 
United States. In the mid-1980s. Tickell 
helped to percuadc tbe Britilb Prime Min- 
ister Maifuct Thatcher that global warm- 
ing wu an issue that deserved both bar 
attention and generous Aindiog. He 
appears to have been equally perstiaaive 
with the EC tbe United Nationv the 
Britista Foreign Offioe. and ICSU. 

With the suppon of environmenlaliK 
networks pursuing their own goals, the 
new global threat soon flourished. The 
public became alarmed. Many govern- 
ments, especially those (such as the Unit- 
ed States) who depend on fossil fuel, did 
not like AGOG, but preferred tbe WMO. 
which they are able to influence directly 
through national representatives. 

The WMO decided to 'capture' the 
AjGGG In 1987. its executive proposed to 
set up a small body of experts frum coun- 
tries strong in dimatc-changc research, 
induding a small number of people repre- 
senting other nations and international 
scientific bodies such as ICSU. The IPCC 
evolved (rum this Idcit during the subse- 
quent politicization «t the issue. Formally 
set up in autumn IMIW by rhe WMO and 
UNEP. iLi activities arc utmimlk-d by gnv- 
cmmeni appotnlecii who. in prai-tiuu. tend 
ui be influential governiiK-ni wicntitts 
with connections to the WMO and other 
intomalionji hiidii-v 



COMMENnUlY 



335 



Elective IPCC teadenfaip fell to i 
small gnMp of cocmmttee mcm bfcti, OKMt 
of whom hod ttroog links to NA^A, H 
w«ll u larfa national labonumlM end 
meteorological ofBcci. The ntetitb oei- 
woria Supporting two of tbe three woridDg 
groupa which were set up in 1988 •tnHdjr 
existed as paru of Worid CUmate 
Rctcarch pTOfraanae. The fim of IkMe, 
for example, the icieaoe mmmbmu 
group, is maaaged thmugfa tiM XJK M«e- 
otologicaj OfSce, and ftiodcd by the 
DepartiDcnt of the Envirooment. Tb* aeo- 
ond worfcJDg group, which n looldog at (he 
impact of climate change, was id the 
bands of the Rusaiant, Rroogiy tupponcd 
by Australia, but has reoently nuod a 
home within NASA, with a chainnao who 
advises (be US president. 

tflidajly. govrmment oSidaia aitd np- 
rescntabves of vahou* praaittre fraa^ 
formed the third, iesa peraancnt group. 
This was tikjtd to pitMhtce rtaibtic 
response strategics' on the baiia of the 
'scientiftc' inputa froa tfaa othar two 
groups — even though these wrre Mt yet 
available, impact* and neapooMt ware 
combined in 1993, white a new granp waa 
set up to look at 'cro«-aitting' oapacta. 
with conttifautions frocn a wider rang* at 
social sciences. 

In 1990, the WMO infonned pohcy- 
makers that they should coniidaT thacDO- 
scntus views of the scientific oammnity 
as timeiy aoeumci^u' of the dimate 
threat*. The IPCC wai made avaiJafafe to 
them as a 'single established louioa' (or 
informatioo on this subject, and whiia the 
comaunee's task would not be to d«fiiic 
or set up research progruimMi. its raoois- 
mendationj would t>e of value to tha a^n- 
aes responsi'Me for meaicfa — ((SU, 
WMO and UNfEP 

The IPCC 1990 acience atacasmsiitWM 
produced by Britain, with (naior a « <> taix« 
from a small group research^ oasaa *d- 
ence inside NASA. It provided political 
legitimacy to a nahtMtal fctearch aiMKla 
coordinated globally by ICSU. WMO and 
UNEP. and already defined — in the con- 
text of the wanning threat by (.He ICStf's 
Committee on Probiemt of the Enviton- 
ment, SCOPE — for the 198S VDIach 
meeting' 

IPCC reports sununarlzc tha flndfaigt 
of its research networks, with drafUiig and 
editing earned out by nnall groups of lead 
authors. These tend to be aeleaad l^thc 
science managers, who al*o draft DPCC 
policymakers' summaries' — ih iunae hf c s 
important political documents aadtkiiful 
exercises in scientific ambiguity'. AwWely 
praised jdeniific consensus' of 1990, 6or 
uamplc. which a<*e<«ed the pioepects of 
climate change, uied language which 
lumultaneously allowed Oracnpeaoe to 
call fur a target of reducing erainiCM by 
60 per cent, and the L7K T>ea«iiy to con- 
clude that no actic<i was neeosd until 
more jcicntiiic certainty was availahU — 
4«a 



each citing the larae source. 

A second auestraent exerctae is in 
preparation. But the credible regioiul 
predictions and rmissiao models so 
uifcntly desired by pohcytnaken are not 
yet available. Global expenminution 
oofuinues. 

So far, there has been littie redirtction 
of fiohal energy policy to take aoeoutit of 
ttM potential threat of global wartoing. 
This bilura could be biamed on tiie tdeo- 
tiflc oamnuuiity. on falling energy pricea 
o< on politicaans. Only if it could b« tbown 
that identista intenaonaily created a more 
powerful threat than dte evidence suggest- 
ed, could this lack of reqxiaae be consid- 
cied ^''m^' There is some evidence for 
thilV although a responaivcneas of 
'science' to both internal need and exter- 
nal prestura is surety not surprisiog. 

But given both the energy potitia of 
the oud-1980s, and the large number of 
noiMCientlfic acton involved, the rapid 
o ojtttctatioo of the climate debate 
occurred in a context of scientific ambiva- 
leDee. influeaced by forces beyood the 
«ntrol of tci»9ce. Global policy on global 
waniUBg is emerging from untidy pcriitlcal 
processes — not thnMigh techttoctatic 
dedgn. Given tfaa sdeniific uacertaintses 
that itill exist, this may weO be for the 
bait. 

IPCC has undoubtedly boosted 
raaaarch activities in countries with strong 
alBOipherii:. oceanographic and Space 
raaaarch capacities. It has also stinialatad 
laatbetnatiaU modeUtng of some global 
isacro-econamic (actors as well as of car- 
bon emissions related to fiiels, demand 
and technologies. Most of the OECD 
oouottiea, as well as thou in the EU, now 
poetess itiajor global environmental 
change reaeareh programmes which alto 
cooaidcr fotiitutlona and broader social 
qoeitioas. 

There have been rewards to thoae insti- 
tations in advanced counides who. with 
(he help of enviroiunentalists, have been 
able to link science policy to at least sym- 
bolic coounitmeots to the global anviron- 
dtent. Furthermore, uncertainties in 
sdentific advice have served the interests 
of reseerch by reinforcing calls for extra 
research fimds. 

But poiicical battles over the knowledge 
bate gave also frown. This may explain 
the withdrawal of science Into adopting a 
(Dore neutral position on appropriate pol- 
icy responses than appears (o be the case 
between 198S and 1992. locidenuUy the 
pteparatory phau for the Rio conference 
and for beciiming the implemenution of 
the IGBP Now Ihat iheauthorlty of sci- 
ence ha.1 been weakened, claims to both 
policy relevance and truth — as well as 
the capacity of the natural tciencas to 
deliver policy advice that can be quickly 
implrmented — can legitimately be ques- 
tioacd. The creation of knowiedge at 
increasing rates by a few individuals 



engaged in a political game, on f of whose 

BTTIfY lj°*)^ ^ to obta in ft""<i''f tr^ tti^r 

""" imr ""'" *"^'"— -^ '*" •"*)' '*'-' 

envirofunentai problems ore defined atwl 
pnoritiaed. 

Resltunce to univcTuUst and political- 
ly 'neutral' claims made by Western politi- 
daos in the naioe uf scieoce eppears to be 
growing, while appeals to ethics and luues 
such as fairness, equiry and 'sodal ewlu- 
sion' are growing stroagcr. 

(r 1971 the American cJinutologisi R. 
A. Biyion voiced 'a sneaking suspicion' 
that tiilt for more data and monitoring 
prior to the Stockhchs Coofereoce were 
"tnottly for the care and feeding of big 
computen"'". He tficcvlated that it wxsuld 
be more appropriate to monitor parame- 
ters with a more direct hnpact on human 
welfare. In Rio in 1992 it wis agreed that 
the world sbotdd be cooceriMd that over 
12 ffiillion children a year die from pre- 
ventable diseases. But the types of icience 
and technoloc that promise coffimerdal 
coapctitivencss tad political power do 
not addfett such Isnies. 

tntifts will 






the short term, than relevant 
letaon that has to be continuoas(y 
releamr. Policy-related advisory networks 
need to become mor? sopiiisticated and 
less self-serving — and policymakers to 
develop broader decition-mabng struc- 
tures — to prevent this from tiappening. 
This cannot mean listening to green or 
energy lobbtee to tlie exclusion of all otb- 
ets. Advisers and dedslon-maken need 
each other, but knowledge funded by soft 
tnoney and created under conditions of 
dictated relevanct aitd compedtive bid- 
ding is tuiely unlikely to inspire the 
degree of trust upon which wise policy 
oust be bcsed. □ 

Sorve A. Boehm«rCMatiafisen ia a 
tenlor na»aKh Whm at m^ Scianee Pot- 
Icy Raaaareh Untt at the Unl\/9rsity of 
Suaae*. Brighton BNl 9RF. UK. 

-a> Mwoasiu. (Ab«wt. i«ui 

4. fll«en«(^aM0<M«aDrn«Mn*<Ca^*'MMOr)tM 
iM«MManl of C«tar OObM m OVMt ^wmvuw 



v—en aiaooMw lais n»<o wi. a»-ii » . isesi. 
t. nn wnM C ii n ii W u »»,ii» iw? icoi fWMO Tea 

8. M0I1 i. a ^HMM". H. L <adk) C&iMW 0«WI^' 
Semnc*. knp«ct«. PtKr P>voM»ei 9/v«* 5#c«w 
HMrW CUmMV Cort%,Tnc* tC«n,»i0|i Un««i«(<r P<MI 
•rwvO. IWli 

T. SoMn a 4* jr. tM» m* OlMMtouM CMf C C*naf«; 

oi»w» «"«fto »/ w , n iscow i» wmr. CKfmtw. 
taam. 
a Houfriec. I. ft w. i«ai CMntf* cmt^ rn« vcc 



^■iiiiwMin. s.* ei«,sy<'i^r>*««winwrtf4. 



^— '(I««l. 



ACMMWaaoCMCNTS. r*ua 



NATURE VOL 372 • 1 OECEMBER 1994 



P. 13 




336 



U.S. HOUSE OF REPRESENTATIVES 

COMMITTEE ON SCIENCE 

SUTTE Z3» RAVBUm HOUSE OfFKX atMiMNC 

WASHWGTON. DC ]«1$^I01 

(m>21S-C371 



Novonber 15. 1995 




Jotaa Maddox, Editor 

Mane 

1234 MtfioDal Press BoUdmg 

529 i4th Stmt NW 

WMOoBpoa, D.C. 20045-2200 

DmMr. Maddox: 

Oo Scptr mhw 20, Hie Comminee caaveaed a hearing to egamiae varioos questkws 
i ^ ^n ^ m^ the Kjwwtfr iatecnty ^ ^ ataae defdetioa ttooiy. Datiiig tbe ooime of tfait 
InniiV' *>^ witness, Dr. Sallk BaHnnw, AHed thst sfae bad tnoomttavi a breakdown in tbe 
tnditiooi of fine and open sckodfic inquiry rebted to this issue. Sbe was requested at dnt point 
to supfiiy tfae C'^unittrr wttb specific iiw ta nnr s in wbkb faer leseaidi was insgipnpdatefy 
i m hthit t^ Oa October 19, she reqwnde d to the Connditee. 

Ian wxiliiig you to ascettsin die fiKts smroandnqg one poitioo of ber response leiattag 
to tfae edkodal pcAcks of Ntfnre magarine. In part, she asserts tbe foOowiog: 

o In October 1992, the submitted a maausciqit lefatiBg to changes in die Sun winch hsd 
j«iyit jtinm fiir^obal cliiiige. 

o The ""■■■-■ 'if was held for review for 14 modfhs Md went tbnagh five <&fifeieat 
referees and three dtffereot eifiton. 

o Two nfisrees MxeptBi the p^ier bat ttie ediiun kept trying to find a aluxx, who wonld 
reoommeiid R^ectno. 

o One reviewer snggested her resabs weie a dinct coose^MOoe of her flinifliig ftoo a 
finindiitioo svpported by an oil cnmp s ny . 



TUs attack was aooqited by the editors ud tbe paper was icjected. 



337 



^. JbfanMaddox 

FigeTwo 
11/15/95 



AMtoagfi these xueitioos do not nggest any violitiaa of Uw, they do ieapLy a lack of 
tibjeadvity oo tbe put of Nature maf^nr. If tnie, this would be an e^edally troobiiiig aspect 
hi the peer review pnoeas that poUcy maken nHUt depend oo. 

I woald deqily qipieciate yourieview of this malter. 

SMcrely, 




338 



nature 



Pcriws Sottlh 
** DiMi MnnK 
: DUdon Nl 9XW 

i|7 Novenib«r 1995 '"'• -M«»i/;»33«oo 

XI novwiauw* j.:7»j Kb: *i^ Oil /I 8*3 4596/7 

R ipresentative George B. Bro%ra Jr 
Riziking Democratic Mendber 
OS House of Representatives 

^onnitcce on Science 
Saice 2320 Rayburn House Office Building 
Washington. DC 20515-6301 

Oiar Mr Brown: 

Itiank you for your letter of 15 November, enquiring about the 
fkcts surrounding Dr Sallie Baliunas'G interaction with Mattire 
in 1992-3. la several particulars, the laformstior. that Dr 
Ealiunas gave you is incorrect. Although we follow a policy of 
lot disclosing the steps taken in dealing with individual 
n anuscripts , on this occasion Dr Baliunas tias in my judgment 
forfeited the right to privacy, for which reason I atn isending 
1 ou a copy of an internal note to me by or Laura Garwin, 
Ihysical Sciences Editor of Nature for the past eight years. 

lou will see from Dr Garwin's note that Jr Baliunas has failed 
to disclose that she submitted four versions of her article at 
^ arious intervals . The paper was seen by four referees , not 
Jive; this number of referees is by no means unprecedented, 
ind the reasons are given in Dr Qarwin's note. Two referees 
(id not "accept the paper" ,- of the four referees consulted. 
<inly one (referred to as referee 2 in Dr Garvin's note) 
] inished the review process by recoorecnding publication. Dr 
I Aliunas also misrepresents Nature when she refers to a 
' stated policy" that we accept any paper reconmended by two 
j'eferees; there is no such policy, explicit or otherwise. More 
(lamaging is her assertion that we "kept trying until they 
: lound a referee who would recommend rejection',- we simply 
jlollowed the sensible course of going tc u person who would be 
i ible j:o judge the technical issues that had b^' that rime 
1 tecoos apparent . 

ilsgarding ireferee 3's mention of the authors' sources of 
funding, this was not "accepted by the editors"; it was 
roaqplecely irrelevant to our decision. (Nor w^is j'^ a direct 
kttack on the authors' integrity, its Dr Baliunas suggests. The 
phrase "it is not science" referred to the tact that the 
luthors had not given any justification for their choice of 
itatistical averaging method, when othei choices would tMvm 
yielded different outcomes.) The decision to reject the paper 
fas madie on purely technical grounds, which tne authors have 
lever chosen to rebut . 

tmere] 



339 



^•presentative George B. Brown Jr 

7 November 1995 
I^ge 2 

ehali send a copy of this letter and its enciosuri?! to Dr 
ftaliunas. We understand that Dr Baliuuas's letter does not 
lorm part of her testimony, but if a reference to it is made 
in th« record, we would naturally be grateful if this response 
could be similarly referred to. Naturally, one of nry- 
colleagues or I would be glad to provide you with a forroal 
:r«buLLeil if you viohod for ch<it . 

rou may think this a trivial matter, but we pride ourselves on 
:he car« with which we deal with authors ' manuscripts aiad are 
laturally angered when what we do is miprapresented . 



fours sincerely, 

i 
Sir John Maddox 
Bditor 



r>rA^<-U\r 



340 

qrohn Maddox frcxn Laura Garwin 10 November 1995 
icistory 0t Zbaag 8107 7 2B 

Paaer arrived 2C Oct 1992 -- assigfned to David Lindley. Ac that 
boint a related paper (Lockwood I.04771A) by sojue of the sams 
Authors (Skiff. Radick, Baliuaas and Lockwood were on both 
bapers) was still vmder consideration; it was accepted on 29 
Octcrfser (published 17 December) . The Lockwood paper looked at 
brightneee variability in 33 Sun- like stars and concluded that 
the Sun i« in an vniisiially steady phase (as regards brightness, 
although not as regards chromospheric magnetic activity) , 
conc>ared to these others. They speculated that there mic^t be 
ciioss when the Sun exhibits nucb larger brightness changes. 

In Zhang 210772B, the authors refined their comparisons of the 
Sun and Sun- like stars and found a correlation between 
chromo^beric activity, luminosity (brightness) , and sunspot 
n;w4>er, allowing them to reconstruct the Sun's brightness back 
to the tinie of the Maunder tainioum. Ihey concluded that solar 
brightness changes have been substantial (as much as 0.7%), and 
that climate changes such as the Little Ice Age and the recently 
observed irazming trend can be accounted for entirely by solar 
variability. (So zio need for an enhanced greenhouse effect.) 

The paper was rejected on 9 Decevber (just over five weeks from 
submission) with a letter saying that "neither reviewer finds 
the reasoning. .. .persuasive". Both referees caid that the 
arguments depended an assuoptions that were not clearly stated 
or explored; both also found the conclusions speculative. He 
concluded that "a more sophisticated and coci^rehensive treattoint 
(would be] needed, both to justify the selecti<» of a subset of 
stars from the overall sample and to give a proper accounting of 
all the uncertainties and variables involved." 

On 30 December, the authors aumilt:toGi » revised vf^rBiun, with 
resiponses to the referees. By this time David Lindley had left 
Mature, so Karl took the paper over. One of the original 
referees (let's call him referee 0) was unavailable, so we went 
back to the other one (referee l) , plus a replacement for 
referee (referee 2) . Referee l still had reservations about 
the statistics, but felt that they could be dealt with by 
further revision. Referee 2 reconsnended against publication, but 
largely oa the grounds of clarity — altliough tua may also have 
bad worries about the statistics (referee 2's report wasn't very 
Clear) • KdXl felt chat there "could well be something for us 
iirtre", nnd -jo^m the Authorn an op*n-CndGd tltCiSion (PtQ) on 30 
Jpril 1993. 



341 



.p. 2 



Ob 5 May we received a further revised version, with axx 
aiQ>lao«tlon of how this paper related to the Lockwood paper 
(^hi9 had been a source of confusion for tis and our referees, as 
ttie relationship between the two papers was not very clear and 
s seined to be contradictozy) . We went back to referees l and 2. 
Heferee l felt that his reservations about the statistics had 
sot been adaquately addressed, and reconmended against 
piiblication. Referee 2 reconmended publication- but of a 'versiea 
ttot we did not seel (He sent us a fax saying he recomoended 
publication of a version dated 26 June, whereas the version w^ 
tad been sent arrived in our offics on 5 May. He had also been 
in direct discussion with the authors, and we were not told the 
Gubstanca of their conversation.} Karl must have been away whan 
3t became tine to make a decision, so Phil gave the authors 
snother open-ended decision (P«Q) on 22 Scptesfcer, saying that 
'we cannot offer to publish the paper unless {the relationship 
letween it and the Lockwood paper] can be clearly resolved in a 
iurther revised nanuscript" . 

<n U October the authors submitted a finail revised version, 
linally, the methodology was sufficiently clezu: for Karl to 
mderstand what they had done, and how it related to the 
lockwood paper. He decided that we needed a real statistician 
referee l is a climate eacpert who uses statistics in his woi^, 
Init not a professional statistician) to evaluate the 
iiethodology. The statistician (referee 3) found the paper to be 
iieriously Clawed (and, incidentally, an instifficient advance on 
]nrevious work), and we rejected it on 31 Deoeaber. 

lio, contrary to Dr Baliunas's assertions, only one (not two) of 
our thz«e referees reeomaended publication, ihe time between 
original submission and final rejection was indeed fourteen 
laonths. but in that time the p«^>er was revised three times azui 
inderwent four rounds of review. The first decision was made in 
:ive w«eks. The ps^er was seen by four referees (not five) . It 
fas handled by three editors because David Lindley left /Tacure 
It the end of 1992. (It is ^ite cocinon for a file to be handled 
ay more than one editor during its life, as we routinely handle 
Me files of colleagues who are away from the office.) 

Par from "trying (to find] a referee who would recoaraend 
rejection", there are two identifiable junctures in the file's 
bdstory imere the editor concerned could justifiably have 
rejected the papier but chose to give it another chance. The 
first was in April 1993, when Karl decKSed that there "coui4 
well be something for us here"; the second was in September o£ 
that year, when l^xil decided to give the authors another chance, 
4-v «.._.*, ^n*a-^a^ 1 v,as inclitted not tc do so. 



342 



-p. 3 



Finally. the quote from r«feree 3 regarding Dr Baliunas's 
sources of funding was most certainly not a factor in our 
dtcision regarding the paper. We regret the fact that Dr 
Biliunas felt insulted 1^ it, and in retrospect perhaps we 
sliould have discociated ourselves from the coniaent, but it is 
completely irrelevant to the rejection of Dr Baliunas's paper. 



343 



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Lockheed Cotportaon (rtt.J 



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American Insvtute ol 

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JohnMoCwthy. 
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Henry I. Miller. 
Stanford University 

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1730 M Street, N.W.. Suite 502 
Washington. D.C. 20036-4505 



December 18, 1995 



The Honorable George Brown 
U.S. House of Representatives 
Washington, D.C. 20515 

Dear Congressman Brown: 

Sir John Maddox sent me copies of his letter and the memo 
by his colleague, Laura Garwin, regarding Nature 's review of 
our paper on solar brightness changes. 

Sir John indicates that the handling of our manuscript, 
which extended over a 14-month period, was not unprece- 
dented. This is not so in my experience. As I stated in my letter 
to Congressman Rohrabacher, I have published more than 125 
papers in peer-reviewed scientific journals, including Nature, 
and the treatment of this manuscript by Nature is unique in my 
professional experience. 

To clarify an issue raised by Dr. Garwin: There were five 
reviewers of the paper, not four. Dr. Garwin noted reviews by 
four referees: Referees 0, 1, 2 and 3. However, Referee 2, who 
chose to reveal his identity to us (he was Dr. O.R. White of the 
High Altitude Observatory), sent both to us and to Nature an E- 
mail on 3/23/93 saying, "In reviewing your paper for Nature, I 
had several discussions with Dr. Andy Skumanich about your 
results and the analysis. He had originally been asked to be the 
third referee, but declined because of time constraints. His 
counsel has been invaluable ..." 

Thus the comments by Referee 2 (White) actually were the 
product of two reviewers — White and Skumanich. Nature 
knew of this development from White's E-mail of 3/23/93 and 
apparently accepted it. Skumanich is a competent referee for our 
paper and we have no complaint about this. However, the 
bottom line is that a total of five reviewers actually generated the 
reviews sent to us. 



344 



The more serious issues relate to the handling of our mcinuscript by 
Nature. A review of Sir John's materials and a re-examination of our file on this 
matter leads me again to the conclusion that the handling of the p)eer review 
process for this manuscript was highly unusual on the part of Nature's editors 
and at least one reviewer. The record also suggests that this unusual treatment 
was related to implications read into our results (although not contained in our 
manuscript) to the effect that global warming could be explained as the product 
of natural factors of climate change — in this case, the sun — instead of 
manmade greenhouse gases. 

These conclusions are based on the following irregularities in the review 
process. 

1. Dr. Garwin's memo indicates that Nature selected a climate expert — 
designated as Referee 1 by Dr. Garwin — as one of two reviewers of our paper. 
Why did Nature choose a climate expert? Only one sentence of the original 
manuscript referred to terrestrial climate. The paper is concerned entirely with 
stellar astrophysics and solar variability. A climate expert can know little or 
nothing about the basic facts, current literature, and observational and theoretical 
methodology in those fields, and cannot serve as a competent referee for this 
paper. 

2. Referee 3 referred explicitly in his review to the paper's "implications 
for the global warming debate." By this time we had already dropped the single 
sentence that mentioned climate, so that the paper contained no hint whatso- 
ever of a climate connection. Referee 3 had no reason to view the paper in the 
context of the politically sensitive global warming issue, or any climate question; 
or, in fact, as anything but a contribution to stellar and solar physics. Yet Referee 
3 did so. The fact that he did indicates that Referee 3 was giving the paper a 
political rather than a technical reading. 

This impression is confirmed by the further statement in Referee 3's 
review in which he suggested that we had fraudulently doctored our main result 
because one of our funding sources (the Mobil Foundation) was connected to the 
oil industry. This remark by Referee 3 indicated a biased reading of the paper, 
which taints his technical comments. Nature's editors should have replaced this 
referee as soon as they read that statement suggesting that our results had been 
doctored to suit an oil industry sponsor. Dr. Garwin writes, "Perhaps in retro- 
spect we should have dissociated ourselves from the comment," but dissociation 
would not have been enough. The taint of that political reading should have 
been removed from the review process by the replacement of Referee 3 with 
another referee. 

In sum, these circumstances indicate that Nature's editors and at least one 
referee were reading into the paper's results a politically sensitive implication — 
the importance, or lack thereof, of manmade global warming. They were not 
handling it as an analysis in stellar astrophysics and solar physics, although 100% 
of the paper's content was in those fields and 0% dealt with climate. 



345 



One other feahire of the Nature review was also highly irregular, ai\d 
surely a departure from normal procedures of peer-review. As of 4/20/93, 
Referee 1 had agreed v^th our response to his principal criticism of the original 
manuscript, and had conditionally accepted the revised version. He vvTote, "I 
recommend publication subject to the author's dealing with the following issues, 
which," he wrote, " should be relatively easy to deal with." 

Five months later, he reversed himself and recommended rejection. Why 
did he change his mind? In the interim, someone — either Nature's editors or 
Referee 2 — had given him Referee 2's comments. The materials forwarded to 
us by Nature indicate that these materials had affected his thinking. How do we 
know this? Because Referee 1 wrote in his review received by us from Nature 
on 9/22/93, that his reservations "have been echoed and amplified by the other 
referee (emphasis added)." 

The point to having two or more referees is to secure independent reviews. 
When Referee 1 was given access to Referee 2's review. Referee I's review was 
no longer independent — as Referee 1 explicitly acknowledges in the passage 
quoted above. 

3. Sir John states that the rejection of the paper was on "purely technical 
grounds," connected v^th our "choice of statistical averaging method." The 
latter comment was taken from the review by Referee 3, who is described by Dr. 
Garwin as a professional statistician. This comment by Referee 3, is without 
merit. We would have been delighted to rebut Referee 3's comments on our 
statistical procedures and demonstrate that, but we were not given the 
opportunity to do so. 

Finally, as a confirmation of the high technical quality of our mjmuscript 
and the correctness of its statistical analyses, I note that after rejection by Nature 
the paper was submitted for publication in the Astrophysical Journal and 
accepted seven weeks later. Furthermore, there were no critical comments by 
the reviewer on our statistical analysis. The Astrophysical Journal covers a 
narrower field than Nature, but it is the leading publication in the world in the 
field of astrophysics — as prestigious as Nature within its larger field — and its 
editors pride themselves as much as Nature's editors on the care with which 
they deal with authors' manuscripts. 



Sincerely, 

Sallie Baliunas 
Senior Scientist 






cc Sir John Maddox 

Congressman Robert Walker 
Congressman Dana Rohrabacher 



346 



FoUowup Questions Submitted to The Honorable Joseph F. Vivona— Enclosure 2: Page 6 of 

15. On page 469 of Volume 2 (of 5) of the FY 1997 Congressional Budget Request, it is 
stated: "Up to 35 million metric tons of potential carbon equivalent emissions will be 
reduced, helping the country meet its energy needs without harming the global 
environment. " 

Please document the claim of reductions of "[u]p to 35 metric tons", including 
accompanying assumptions. 

16. On page 469 of Volume 2 (of 5) of the FY 1997 Congressional Budget Request, it is 
stated: "Over this period [to 2010], the export market potential for renewable energy 
technologies is greater than $1 trillion." 

Please document this statement, and clarify whether or not the export market potential 
referred to above encompasses only renewable technologies or all electrical generating 
capacity. 

17. Page 470 of Volume 2 (of 5) of the FY 1997 Congressional Budget Request contains the 
following performance measures for renewable energy technologies for the year 2000: 



Technology 
Photovohaics 



Solar Thermal Electric 



Solar Domestic Hot 
Water 



Performance Obiective 

500 megawatts installed 
domestically and 200 
megawatts overseas. 

400 megawatts domestic 
and 200 megawatts 
overseas. 

3,700 megawatts domestic 
and 4,000 megawatts 
overseas. 

500 megawatts domestic 
and 2,500 megawatts 
overseas, installed or 
under development. 
Reduce electric peak loads 
by 2,000 megawatts from 
domestic Geothyermal 
Heat Pumps. 

1,200 megawatts of new 
electric power domestic, 
and 800 megawatts 
overseas; 600 million 
gallonsofbiomass-derived 
transportation fuels 
produced per year. 

Increase market 
penetration by 40 to 60 
percent. 



Cost Reduction Goal 

10 to IS cents per kilowatt-hour 
from the current level of over 20 
cents. 

Less than ten cents per kilowatt- 
hour from approximately 17 cents 
(solar only mode) today. 

2.5 cents per kilowatt-hour for good 
wind areas from the current four to 
five cents. 

3.5 cents per kilowatt-hour for 
average grade resources compared 
to current S to 8 cents per kilowatt- 
hour. 



Reduce the cost of ethanol from 
biomass by SO percent by the year 
2010 fat>m the current cost of SI .22 
per gallon. 



25-40 percent reduction in installed 
cost. 



347 



'Ozone hole' fails 
to materialize as 
feared, NASA says 



THE ASSOCIATED PRESS 

The dread "ozone bole" never ma- 
terialized over the Nonheni Hemi- 
sphere last winter despite early 
findings of huge amounts of ozone- 
destroying chemicals in the air, 
NASA scientists reported yesterday 
Not only that, but other govern- 
ment scientists announced that bac- 
teria found in Potomac River mud 
can eat up the vcrjrcfaenilcaU that 
have alarmed environmentalists iti 
recent years by attacking the Earth% 
ozone layer. 

The NASA scientists, reviewing 
results of seven months' observa- 
tions, said that after a record 
buildup of ozone-damaging chem- 
icals last January the amounts rap- 
idly dissipated because of sudden 
warming in February and March. 

While the tests continued to show 
a thinning of the ozone layer that 
protects the earth from ultraviolet 
rays, the sudden warming prevented 
any severe ozone depletion over the 
Arctic region, the sdentistB said. 

Nevertheless, they said, the poten- 
tial for severe ozooe destrucdoa 
over parU of the United States, 
Canada and Europe remains a mat- 
ter of serious concern because of the 
high concentrations of destructiw 
chlorine that were detected. ' 

"With so much chlorine in the 
stratosphere, a slight temperature 
diflTerence can make an enormous 
difference in the potential fbr ozone 
depletion." said Joe Walters, one of 
the NASA scientists involved in the 
ozone observation program. 

Chlorine monoxide, a man-made 
chemical byproduct, reacts 
chemically to destroy ozone. Scien- 
tists have found that its destructive 
potential is greatest in cold weather 
when there are ice crystals. 

The scientists, part of « team as- 
sembled by the National Aeronaut- 
ics and Space Administration, said 
that while the ozone hole that had 
been feared never materialized, 
there was still a 10 to 20 percent 
ozone loss over the Northern Hemi- 
sphere last winter. 

"It (was) not an ozone bole," added 
James G. Anderson, a Harvard Uni- 
versity professor of chemistry and a 
NASA project scientist, but "the 
amount of ozone destroyed this year 
is still significant" 

Meanwhile, the U.S. Geological 
Survey reported yesterday that sci- 



entists probing river muck have dis- 
covered bacteria that can eat 
chlorofluorocarbons, the main 
chemicals threatening the ozone 
layec 

The bacteria that break down 
chlorofluorocarbons, known as 
CFX^s, were found along the Potomac 
River in Virginia and in pond, marsh 
and swamp sediments in Maryland, 
South Carolina and Virginia, offl- 
dals said. " 

In recent years scientists have 
blamed CPCs for much of the re- 
ported damage to the ozone layec 

The CFC-eating bacteria are 
harmless to humans, but can operate 
only in the absence of oxygen, ac- 
cording to Derek Lovley, a micro- 
biologist working at the Geological 
Survey in Reston. 

Oxygen-free environmoits exist 
woridwide in swamps, marshes, rice 
paddies and other wetlands, he 
noted. In addition. CFXT-containlng 
products are often disposed of in 
landnUs, which are also oxygcn- 
freA ■ . ■ ■ 

Mr. Lovley said he grew a mix of 
bacteria from the sediments in the 
presence of levels of CFCs Cound in 
the atmosphere, and some of the 
chemicals were destroyed by tlie 
bacteria. The test was part of a se- 
ries of experiments involving tlie 
ability of bacteria to eliminate coo- 
taminants, he said. 

Previously, it had been thought 
that bacteria could not degrade 
CFCs, he said. "But we knew that 
similar chemicals are degraded by 
bacteria, so we thought that maybe 
it just hadn't been tested in an 
(oxygen-free) environment," he 
said. 

Mr. Lovley and hydrologist Joan 
C. Woodward reported their discov- 
ery in the May issue of Envinmmen- 
tal Science and Itechnology mag- 
azine. 

As the CFCs circulate in the lower 
atmosphere they penetrate slightly 
into wetlands and soils, giving the 
bacteria a chance to destroy at least 
some of the chemicals. And since the 
chemicals can remain in the air for 
many years, "mechanisms that re- 
move even a minor fraction of ttie 
CFC-11 and CFC-12 in the lower at- 
mosphere will have a significant 
long-term impact on the amounts 
that reach the stratosphere," Mr. 
Lovley said. 



A-P- 



348 



< ,( 



American Academy of.Dennatology 





National Conference on 
Environmental Hazards to the 

October 15-16, 1992 - 




ComprehensivePosition Statement 



s0^1^.e. 



V • /o 






^ 1938 -^^ 




349 



Introduction and Purpose of the Conference 

The American Academy of Dermatology's National Confer- 
ence on Environmental Harzards to the Skin, October 1 5- 
16, 1992. in Washington, D.C. was the first comprehensive 
meeting to discuss effects of the world's deteriorating 
environment on the skin. 

Wilma F. Bergfeld. M.D., president of AAD, was 
chairman of the Conference, ftesenters included 30 experts 
in the fields of medicine, environmental issues, government 
regulation and research. These experts also participated in 
developing a consensus statement leading to an action plan. 

The Conference explored three different environmental 
areas including the issue of ozone depletion and other 
atmospheric hazards; occupational/man-made hazards; and 
naturally occurring hazards to the skin. 

Generous corporate support for this program was pro- 
vided by the following sponsors: Roche Dermatologies, 
Ortho Pharmaceuticals Coqwration, Dermik Laboratories, 
Inc., Unilever Research U.S., Chesebrough-Ponds 
U.S. A., Warner Lambert Company, United States Environ- 
mental Protection Agency, The Procter & Gamble Com- 
pany, Neutrogena Dennatologics,The Andrew Jergens 
Company.Schering-Plough Healthcare Products, Cosmalr, 
Inc. 

Executive Summary 

This report summarizes the deliberations of the two-day 
meeting. The objectives of the conference were: 

■ To define a set of wide-ranging issues related to skin 
and the environment; 

■ To begin to define the magnitude of the problem; and 

■ To have a set of consensus panels address the needs and 
opportunities for increased research, education, preven- 
tion and legislative action. 

The first half-day was devoted to the status of ozone 
depletion in the atmosphere which leads to increased 
ultraviolet B (UVB) at the earth's surface with consequent 
increases in skin neoplasms, including melanoma. The next 
half-day speakers discussed some of the natural plant, 
marine animal and terrestrial animal effects on human skin. 
On the final half-day experts discussed the man-made, 
especially the industrial hazards which affect the skin. 

A supplemental meeting report summarizes scientific 
deliberations and has more detailed versions of the recom- 
mendations. The needs summarized are in research, public 
and professional education which relate to educational 
programs, preventive programs, and research applicable to 
more than one set of these environmental hazards. These 
needs offer the AAD new opportunities to educate the 
public-at-large. 



This summary highlights the major recommendations of 
the supplemental report and includes recommendations for 
the atmospheric hazards, other natural hazards and the man- 
made hazard sections of the report. The detailed body of tht 
report should be reviewed to obtain supporting data and for 
more detailed versions of the initiatives which should be 
addressed. 

A. Research Needs: 

1 . Better definition of environmental changes and the 
extent of dermatology-related problems due to 
environmental factors. 

■ Improved quantification of the changes in UVB at 
the earth's surface related to alterations in the 
ozone layer. 

■ Improved surveillance reporting and investigation 
of environmentally and occupationally caused 
skin diseases. Identification of the pertinent risk 
factors for disorders such as irritant and allergic 
contact dermatitis and skin tumors including 
melanoma. Use of cohort studies to find the real 
prevalence of pesticide-induced skin disease. 

2. Definition of the basic mechanism of environmen- 
tally-caused disease. 

■ Definition of the action spectra for the production 
of melanoma. 

■ Further evaluation of action spectra for 
nonmelanoma skin cancer. 

■ More precise definition of the effects of acute and 
chronic exposure to UVB and ultraviolet A 
(UVA) on skin, the inmiune system and adaptive 
and repair functions of skin after UV injury. 

■ Determination of the genetic factors predisposing 
to skin cancers and melanoma, contact dermatitis 
and irritant dermatitis and definition their molecu- 
lar basis. 

■ Characterization of the plant allergens causing 
contact and photocontact dermatitis and urticaria 
and definition of the molecular basis of their 
action. Development of new patch tests for plant 
agents including sesquiterp)enes. 

■ Delineation of the mechanism by which marine 
venoms and toxins (e.g., brown recluse spiders) 
injure the skin. 

■ Development of better information about the 
cutaneous and systemic toxicity of agents before ' 
they are introduced into the environment Devel- 
opment of systems for reporting on the toxicity of 



350 



J 



new agents to ^ a{^)ropriate governmental 

agencies. 

Encouragement of motivational research to get 

optimum acceptance of prevention programs. 



B. Development of New Protective, Preventive and 
Therapeutic S^axisx 

■ Envelopment of better sunscreens aiKi other 
photbfxotective agents including establishing oi^- 
mum guidelines for their use. 

■ Development of nevy barrier preparations for contact 
and irritant dermatitis. 

■ Development of new plant varieties which lack 
highly allergenic compounds. 

■ Development of new antisera vaccines and diagnostic 
agents for toxic ardirc^xxl reptile toxins. 

■ Development of new Ixoad-spectrum antimicrobial 
^ents for topical use including the development of 
new preservatives for skin preparations. 

■ Increased research on physical and chemical engi- 
neering to improve the handling of toxic substances 
by workers. 

■ Further studies to c^>timize protective clothing. 

>C. Prevention by Education and Early Disease DetectioD: 

■ Development of better measures to assess the effec- 
tiveness of mass skin cwsxx screening programs. 

■ EiKxniragement of sim avoidance and avoidarKe of 
sunburn. Determination of the effectiveness of 
programs to have daily "sun intensity" measures 
brcradcast by local media to decrease sun exposure. 

■ Continuation and increased emphasis on sldn cancer 
screening programs including more active participa- 
tion of senior citizen groups. Encouragement of 
programs which will allow treatment of skin cancers 
in patients who are underinsured at economically 
disadvantaged. 

D. Public Education 

■ Development of a major program in public education 
on the "ABCD" rules for detecting melanoma with 
media, milk carton panels and mass media. 

■ Development and coordination of enhanced programs 
in sun education, plant hazards and marine hazards 
for the pediatric age group. This should include 
support of education by pediatricians and school 
nurses with pamphlets, videotapes, game kits, etc. 

■ Establishment of goals that by graduation from tlie 
eighth grade students should know principles fA sun 



protection, be able to identify dw most aDetgeok 
plants and know how to identify smd avoid Ifae i 
poisonous and venomous creatures in die Uniled 
States. 

■ Incorporation of healdi and safiEty coDcens aboot the 
wot1q>lace environment in school and ooDefe heattt 
programs. 

■ Education pamphlets and videos for waiting rooo* 
on die avironment and effects of changes m dae 
ozone layo*. 

■ Special education programs for older Ameacan 
(especially for men who in tbe past, in coDtnut to 
women, have neglected to examine ttieir ddn). 
Determination of medical specialties, (int^na) 
medicine, urology, etc.) and oonmnmity sites hayipir 
potential for such education. 

■ Aloting die public to die danger of tanning sakav. 

■ Development, support and eacouagemeat of pro- 
grams for workers and mmagement oo prafcr 
techniques of personal hygiene to minimiat ooca|nr 
tional risks in die worlqilace. 

E. Physidan Edncatkn 

■ Increased education on the effect of tbe aeimeauBik, 
including the work environment on the skis, flt *B 
phases of undograduate and postgradoalB metficd 
education. 

■ Devetofmient of cmqxiter-linked datiribaaes for 
occiqietional and oivironmental hazards wift li*li>it 
of resource individuals for usual and serioQt vnA- 
tions. 

■ Emphasis of all environmental edocadoo in deniift- 
tc^ogy residency training pcogrms fnl stfoog 
encouragement of active programs^ la patch tesliBi ii 
die residencies. 

F. PubHc Actfoo: 

1. Coalitions 

■ i^fl<tw»hip in coalitions to increase findfaig for 
health research rdated to die 
Association with all natirmal and 

mr^tiPtX nrgnniCTtinna at;«ivdy WMfcillg ta 

prove tlie enviroonent 

■ Involvemett widi senior ddacB graUjpa 
respect to setting standanls for 
health. Active support of ddn 
efforts. InchuionofpRWEativeoHeaaa 
teed part of die Medicare prognBL ^ v^ 

■ Partidpation widi gratis mcb at die A mwk i i '^ 



351 



Cancer Society, Centers for Disease Control, Skin 
Cancer Foundation and senior citizen groups to 
expand and enhance educational efforts. Institu- 
tion of a formal clearing house or a formal 
coalition of these groups and organizations for this 
purpose. 

■ Establishment of "Industry-AAD" roundtable with 
the sunscreen and sun protective manufacturers 
and the AAD (FDA could also be included) so 
that the needs and specifications for new products 
can be discussed. 

2. Legislative and Regulative Action 

■ Tighter regulation of the tanning booth industry 
including prohibiting the use of tanning facilities 
by minors, informing the public of the risks, 
limiting total dose people can be exposed to. 

■ Testimony at all the appropriate congressional 
committees to get increased funding for those 
governmental/regulatory agencies which support 
research on the environment. 

■ Support of all national and international measures 
to decrease the production and spreading of ozone 
depleting chemicals in to the environment. 

■ Modification of FDA rules to encourage the 
development of new topical agents and vaccines 
for poison ivy and poison oak. 

■ Setting of threshold limits for allergen release for 
consumer and environmental products known to 
have significant skin hazards. Development of 
maximum allowable levels of exposure to irri- 
tants. 

■ Support of the 1988 National Institute on Occupa- 
tional Safety and Health (NIOSH) strategy 
document. 

■ Detailed labelling of all products which come in 
contact with human skin including beauty salon 
products and over-the-counter products. 

■ Increased supply of allergens available for diag- 
nostic contact dermatology testing. 

■ Assurance of a full-time occupational dermatolo- 
gist on the staff of NIOSH. 

Other Actions at the Environmental Conference: 

■ Passed resolution supporting the acceleration of the ban 
on ozone depleting chemicals and sent to AAD president 
for signature. 

■ Passed resolution of Dr. June Robinson concerning the 
availability of care for underinsured patients with cancer 



which was detected in the AAD skin cancer screening 
program. This was forwarded to president for presenta- 
tion to the Board. 

AAD Vision and Mission Statement on the 
Environment 

The skin is the body's major interface with the environment. 
The dermatologist has a special respwnsibility for advocat- 
ing and insuring a healthy environment with respect to those 
factors which affect the skin. Those factors include the 
ozone level in the atmosphere, natural plant and animal 
toxins and allergens, and occupational and man-made 
chemicals which adversely affect the skin. The AAD 
accomplishes those missions by a comprehensive program 
of professional and public education, the encouragement of 
basic and clinical research into the effects of these agents 
and the prevention of their effects, and when necessary, the 
encouragement of new legislation. The AAD works closely 
with other organizations having similar aims. 



What the AAD has Done Concerning the 
Environment 

1 . Suntan parlor legislation 

2. Skin cancer screening 

3. School curricula on sun protection 

4. Medical waste policy 

5. Advisory council resolutions on ozone layer; need to 
seek legislation to decrease release of CFC and encour- 
age substitutes and to support all scientific efforts to 
monitor UVL levels. 

6. National Conference on Enviroiunental Hazards to the 
Skin. 

AAD Organizational Proposals 

It is proposed that the Academy's Committee on Organiza- 
tional Structure consider the establishment of a Council on 
Skin and the Environment. Under this Council could be 
placed all current task forces and committees dealing with 
this issue. 

In addition to the above, it is recommended that a new 
task force on Cancer as an Occupational Disease be insti- 
tuted. Again, this entity could be placed under the new 
Council on Skin and the Environment. 

The organizational entities dealing with environmental 
concerns should seek to establish coalitions with other 
medical, industrial, governmental and public groups having 
an interest in this area. 



352 



Atmospheric Effects on the SIdii 

L Introduction 

There are ever increasing public concerns that the atmo- 
-'spheric changes leading to a decrease in the ozone layer will 
lead to fiuther acceleration in the cunent rapid increases in 
the rates of skin cancer including melanoma. 

Sunlight is one of the natural hazards to our skin and 
cannot be avoided; however, many of these dangers are also 
sources of pleasure and balancing and assessing risk and 
benefit ratios have to be considered. The sun is necessary 
for life to exist on the earth; it provides joy by wanning our 
bodies and souls on winter days; however, over-exposure to 
sunshine wiU surely cook our skin. Children who have had 
repeated, severe sunburns may develop mahgnant melano- 
mas 20-40 years later. Today's happy beach boys and girls 
are tomorrow's dyschromic, wrinkled and wizened older 
adults who require dermatologic care for their keratoses and 
skin cancers. Skin cancers including melanoma, and 
frequent sunburns will undoubtedly become more common 
in the near future as the ozone is depleted by the chlorofluo- 
rocarbons (CFSs) and volcanic emissions, allowing more 
ultravicdet light B (UVB) to reach the earth's surface. The 
availability and advertising by the tanning parlor business is 
a dangerous sop to human vanity. Tanning salons do not 
give a "safe" tan; 30 minutes under the lamp will cause 
^damage nearly equivalent to three hours of intense sunshine. 

Increase in Melanoma and Skin Cancer: 
The incidence of malignant melanoma is now increasing 
faster than any other cancer in the United States and world- 
wide. The death rate from melanoma for men is also 
increasing faster than any other cancer in the U.S. 

Of considerable concern is the fact that melanoma is 
being seen in younger and younger persons. Melanoma is 
the most frequent cancer in women ages 25-29, and the 
second most frequent (after breast cancer) in women ages 
30-34. Similar increases have been noted in Europe and 
Australia in this age/gender group. 

This woridwide trend of increasing melanoma and 
noimielanoma skin cancer rates suggests that global factors 
are influencing these effects. Although lifestyle changes 
(e.g., increased leisure time) have provided a significant 
influence on skin cancer increases, ozone depletion may 
play an important role for future increases. 

Ozone: 

The relationship between ozone depletion and skin canper is 
complex. Increased sun exposure leading to skin cancer 
was noticed first almost 100 years ago. Ozone acts as a 
filter of ultraviolet radiation from the sun striking the earth. 
^ However, the effects of ozone are selective in that it totally 
blocks the shorter wave ultraviolet C, partially filters 
ultraviolet B, and provides minimal protection from ultra- 



violet A. Therefore, small changes in ozone result in the 
greatest changes in ultraviolet B. Levels of ultraviolet B 
penetration in the earth's surface are most important in 
determining skin cancer effects. 

Recent studies have shown that ozone depletion is 
occurring. This loss is not merely limited to Antarctica, the 
site where the "hole" in the ozone layer was first noticed. A 
3-5% decrease in ozone over the last ten years has been 
noted in the northern temperate latitudes. The major causes 
of ozone depletion are related to human activity. Chlo- 
rofluorocarbons used as refrigerants and propellant gases 
catalytically destroy stratospheric ozone. Even with a total 
ban on die use of these chemicals by the year 2000, it will 
take 50 to 1(X) years to achieve resolution of the ozone holes 
in Antarctica and temperate latitudes. Despite the most 
stringent controls on CFC emissions, ozone depletion will 
continue to worsen for at least the next 20-40 years. 

(Quantitative predictions on the effects of ozone depletion 
on skin have been made since 1971 and are being improved 
as new data are becoming available. The EPA estimates 
that 12,000,000 additional cases and 210,000 additional 
deaths will occur from ozone loss due to C!FCs during the 
next 50 years. The most recent prediction by the United 
Nations Environmental Program (UNEP) is that a 1% 
decrease in ozone will ultimately lead to a 2-3% increase in 
the incidence of nonmelanoma skin cancer. Melanoma rates 
are also directly related to UVB exposure. However, the 
dose-effect relationship is complicated and the measure- 
ments of ground UVB levels are inconsistent Pollution, 
cloud cover and other factors also make these calculations 
not straightforward. Therefore, specific quantitative predic- 
tions of the degree of increase expected in skin cancer are 
difficult to make at this time. 

Ultraviolet B has also been shown to locally and sys- 
temically suppress specific immune fimctions in mice. In 
model animal systems, UVB radiation suppresses the 
generation of delayed or contact hypersensitivity responses, 
including responses to vaccines, infections aid UV-induced 
tumor antigens. UVB can also inhibit die immune response 
to potent allergens in humans. Of concern is recent informa- 
tion that pigmentation may not be protective against UV 
affects on the immune response in humans. 

Economic Implications: 

The economic implicadons of ozone depletion and other 
atmospheric effects on the skin will also continue to grow. 
Increased medical costs including physician visits and 
hospitalizations will be seen with the increased incidence of 
skin cancer, other photosensitivity related disorders and 
immune suppression. 

Nonmedical consumer costs may also be elevated by the 
increased necessity for die use of sunscreens. Several 
hundred million dollars are cuirentiy spent annually on sun 



353 



protectkn products and this amount will surely increase. 
Sales xA protective clothing and other sun |»otection devices 
increase as their necessity becomes more evident 

Increased levels of UVB will lead to increased 
photoaging of the population with subsequent expenditures 
OD beauty and "anti-aging" formulations also rising. 

¥)aaS^/, dme may be impact on the travel and leisure 
industry as concerns about sim exposure may lead to fewer 
trips to sunny vacation areas. 

Tbere may be additional long-range economic implica- 
tion for industries in providing extra protection for their 
Mr-skinned woikers. The timing of outside work and 
lecrealiooal activities may have to change. 

d. Needs for FMnzv Research 

The need fat research in ozone de{detioo and its effects on 
the sldn will become increasingly important in the future. 
In ofder to accmately assess Ae overall impact on health, 
quantitative analyses are needed to determine UVB radia- 
lini effects oo mediaiisms which regulate the bealdi of the 
lUa. This new phase of quantitative questions will require 
ftft dtiUzatioa o€ existing research capacity. A major 
oxpansiai in this directipn is essential. Matt specific 
leaeaicfa needs inchide: 

Dt^metry end Action Spectra: 

L Qmncificadon of the ^lecific ultraviolet radiation levels 
dMt leach At earth's stafax using both satellite and 
gRMBid-based datxi in a formal national program. 

2. Development of dose - effect relationships and action 
ipecna of dtnviolet radiation in terms (rf melanoma and 
winmebnoiiia ddn cancCT risk. 

Epidemiology: 

3. Qostfificadoo of specific bealA risks of ultraviolet 
ffwiiarion it^Oiy in terms of mechanisms, incidence, 
(fia caa etoarfaidiq^, and economic costs. 

4. BeOtr qiartitative measures of melanoma and 
noomebnama skin cancer inddeooe. 

Kdhgkxd Measurement of UV Effects: 

5. in tenos ot mdoioma and notunelanoma skin cancer, 
ui i Mua at and mvestigtfi<Hi of the UV dose relation- 
shq» in animal models and determination of die influ- 
lOBe at other paeam et eis such as hormonal, immuno- 
lo^calaod pramoiiooal fKtors on cancer develqiment 

6. Devetopoiett and evaluatioi of prospective markers fra- 
fetart metannma incidence rates such as age cohort 
w fc tocent aevos count studies. 

7. AanfiMBCHt of the role of UV inununosuppression in 
»B d* nt«M i aitd mo-meianoma sldn cancer development 
Qlrificatian of the extent and degree of immunosup- 

ia hmnans caused l^ acute and chronic expo- 



sure to natural and artificial light 

8. Evaluation of the role of UV immunosuppression in 
infectious diseases, AIDS and vaccine program effec- 
tiveness. 

9. Evaluation of adaptive, repair and biologic mechanisms 
to ultraviolet damage in the skin. 

10. Study of the phenomenon of the long latent period 
between childhood exposure and the subsequent devel- 
opment of melanoma. ^ 

a. Undo^tanding in molecular terms how light causes 
chronic damage to skin. 

b. Detomination of the genetic basis for susceptibility 
to melanoma and nonmelanoma skin cancer develop- 
ment. 

c. Identification of genes, cytokines, chemicals, and/or 
metabolic pathways that can modulate the acute 
sunburn response. 

Improved Sunscreens: 

11. Development of improved and more cosmetically 
acceptable sunscreens with better broad spectnun (UVA 
& UVB) protection to lessen increased ultraviolet 
damage from ozone depletion. 

12. Development of more accurate measures of UVA and 
UVB protection in sunscreens. Also consideration of a 
floor, rather than a cap on SPF values. 

13. Development of other (nonsunscreen) methods for sun 
jKotection and for reduction of DNA damage, such as 
new clothing design and materials. 

Preventive Programs: 

14. Better measures of the effectiveness of mass skin cancer 
screening i»ograms. 

15. Development of a national program to provide a local 
"sun intensity" index for distribution to the media to 
alert the public and increase public awareness. 

16. Development of appro|xiate guidelines for sunscreen 
usage, sun avoidance and protection measures, espe- 
ciaOy for children, adolescents and teenagers. 

a. Definition of chemoj»eventative agents useful in 
reducing acute and chronic UV effects, including 
skin cancer production, by topical application and/or 
suppression. 

Advanced Melanoma: 

17. Develcqnnent of a cure for metastatic malignant mela- 
noma given the fact that more of these lesions will be 
seen as a function of prospective ozone depletion. 



354 



m. Needs for Future Education 

Melanoma and nonmelanoma skin cancer are perhaps the 
most clear cut case of cancers where early detection and 
reatn-ent are key. If these cancers are caught and treated 
early, they are virtually 100% curable. However, when the 
^lesions are advanced, morbidity and mortality can ensue. 

The best way to detect melanoma early is to increase 
public and physician awareness of the problem. The 
"A,B,C,D" rules of early detection in melanoma have 
helped in this regard. ["A" — Asymmetry. One half of a 
lesion does not match the other half. "B" — Border irregu- 
larity. The edges are ragged, notched or blurred. "C" — 
Color. The pigmentation is not uniform. "D" — Diameter 
greater than six millimeters (about the size of a pencil 
eraser). Any growth in size of a lesion should be of con- 
cern.] Programs in Scotland and Australia have shown the 
value of public education programs and mass screenings in 
terms of lowering mortality and morbidity from melanoma. 
The 1992 National Institutes of Health Consensus Confer- 
ence report on the detection and treatment of early mela- 
noma confirms the value of these screening programs and 
suggests their increased future use. 

Other items that may increase the effectiveness of 
education in this area include: 

1) Development of preventive surveillance systems such as 
melanoma risk models to identify those at highest risk 
for developing the cancer so that educational efforts can 
be designed. 

2) Development of an educational program for pediatric 
sun protection. Since almost 80% of skin cancer risk 
occurs prior to age 20, this age group must be targeted. 
Materials for distribution to mothers during perinatal 
visits and in newborn nurseries are also needed. 

3) Creation of a brochure for patients and the public about 
the relationship of skin cancer and ozone for physicians' 
waiting rooms and meetings to demonstrate 
dermatology's concern. 

4) Development of programs targeted to older Americans. 
An example of successful dissemination is the SKIN 
CANCER PREVENTION program of the American 
Academy of Dermatology which has been ongoing since 
1985. Volunteer clinical dermatologists have uncovered 
a large number of early skin cancers. But this is only a 
small proportion of the 600,000 skin cancers that are 
treated each year and the probable 200,000 - 400,000 
unrecognized cases. What is needed is a coordinated 
national program to promote awareness, patterned on the 
experience in Australia. 

5) Alerting the public to the dangers of tanning salon use. 
This warning should be an integral part of all skin 
cancer prevention programs. 



Prevention: 

Both short and long range efforts to improve prevention .of 
melanoma and nonmelanoma skin cancers will also be 
important in the future. Related areas include: 

1 . A national education effort targeted to the general 
population with emphasis on high risk persons. 

2. The American Academy of Dermatology Skin Cancer 
Screening Program has evaluated over 600,000 persons 
in the past eight years with thousands of skin cancers 
detected. Enhanced secondary prevention efforts to 
detect skin cancer and increased pubUc awareness are 
needed. 

3. Support and treatment should be sought for uninsured, 
economically disadvantaged persons who have skin 
cancers detected through the screening efforts. 

4. Increased involvement in envirotmiental efforts. 

5. Initiation of steps to make sun protective products 
available to all. 

6. Encouragement of sun avoidance. 

7. Planning of sun protective environments. 
Physician Education: 

Increased education at all levels beginning in medical 
school extending through graduate medical education will 
be needed in the areas of atmospheric effects on the skin. 
Only approximately 1/3 of skin problems present to derma- 
tologists. Primary care physicians need to be aware of the 
problems related to skin cancer. They will need to be 
involved in assisting both in the screening and treating of 
these newly occurring lesions. 

rv. Needs for Future Public Action 

Coalitions: 

Because of the magnitude of problems of environmental 
pollution affecting the skin, the full burden of prevention 
activities should not be borne by dermatologists alone. It is 
critical that coalitions be developed widi: 

1 . Research organizations, to encourage increased funding 
for the types of research previously discussed; 

2. Environmental organizations interested in skin related 
environmental health issues; 

3. Other medical specialists concerned with environmental 
health issues (i.e., pulmonologists concerned with air 
pollution); 

4. New organizations of physicians, (national and world- 
wide), concerned about these issues. This could include 
worldwide research activity, as well as policy develop- 
ment. 



355 



Prospective Legislation and Policy Issues: 
For example, government cannot regulate personal sunlight 
exposure, but it can regulate UV exposure in tanning salons. 
Ideally, these salons should be closed. Until that goal is 
achievable, a national program is needed to: a) fully 
regulate the industry; b) prohibit tanning parlor use by 
minors; c) provide adequate enforcement of regulation; d) 
adequately inform the public of the inherent risks of this 
dangerous behavior; and e) limit the artificial radiation dose 
to which citizens can be exposed. Other policy issues 
include: 

1 . Increased funding for research. This should include 
funding for immunologic and epidemiologic studies 
related to the skin. Also, treatments for the effects of 
atmospheric changes (i.e., increased rates of skin cancer) 
need also to be studied. 

2. Support for programs for evaluation of public health 
education effect on behavior modification in terms of 
skin cancer prevention. 

3. Coverage from all third party insurers and medicare for 
skin cancer examination and prevention. 

4. National funding of skin cancer screening efforts. Also, 
possible tax credits for preventive cancer measures such 
as screenings need to be evaluated. 

5. Support for domestic and worldwide initiatives to ban 
CFCs and other ozone depleting chemicals. 

Interaction With Public Agencies and Industry: 

1 . At the international level, pubhc agencies such as the 
WHO, UN, the UICC and others will be critical. It will 
be important to link our efforts to those in other coun- 
tries where significant work is also currently occurring 
(i.e., AustraUa). 

2. On the national front, close cooperation with the Envi- 
ronmental Protection Agency, NASA and others in- 
volved in the causes and effects of ozone depletion will 
also be critical. 

3. There needs to an increase in congressional awareness 
by providing an educational briefing for new members 
and staff on issues of ozone depletion and skin cancer in 
coordination with a skin cancer screening for tho.se 
persons. Similar programs can be organized with other 
influential groups such as the National Press Club. 

4. Coalitions with other organizations, such as the Ameri- 
can Cancer Society, Centers for Disea.se Control, NIH, 
Skin Cancer Foundation, and senior citizen groups, to 
expand and enhance public education and screening 
efforts need to be established. The environmental 
concerns of the AAD need to be disseminated to simi- 
larly interested groups. 



At the state and local levels, collaboration with local 
environmental protection agencies and state health 
organizations will be critical in a similar way. Coordi- 
nation with local school systems, especially in sunbelt 
areas can also be useful. Medicine also needs to work 
with state education boards to include sun protection 
issues in school curricula. 

Coordinated efforts with industry and photobiology 
researchers to develop more efficacious and acceptable 
sunscreens need to be encouraged. 



356 



L fatndaelSaa 

iaSaai hazatds to our sldn are everywbore md cannot be 
avoided. A fit^ to die beach or p»k bol^ many dangos for 
the vacationer. Marine animals, such as jellyfish, rockfish, 
and mana rays, contain potent vencmis that am give a 
painful surprise to the unwary bather. Swimmer's itdi and 
swimma's rash are caused by a flatwcxm and larval forms 
of hydroids respectively. Cuts and abrasions fircnn coral and 
rocks allow entry c^ bacteria such as Vibrio and Mycobacte- 
ria that infect the skin. Localized profusions of algal growth 
cause dermadtis and mucous membrane initation. On the 
edge of the beach, irritant plants such as wild blackberry 
brambles, bull nettle, poison ivy and poisoa oak luric along 
with many biting ffies and mosquitoes that cause rashes or 
mcKe severe diseases, such as sand-fly fever. 

Poison ivy and poison oak are majcH- hazards and are 
found at die lower elevations in all parts of the United 
States. Anyone playing or hiking through the foothills, cool 
fraests, or valleys near streams and waterways, is likely to 
come in contact with diese plants. Qose to half of adults in 
the United States can recall a bout of poison ivy dermatitis 
in their younger years that caused great distress and discom- 
fort Other irritant plants exist in the same areas, many 
^wing members of die spurge or stinging netde plant fami- 
lies. People who sit under a Machineel tree in South 
Florida often get large blisters firom the sap that oozes from 
a leaf or stem. Several plants in the sunflower family have 
allergenic airborne pollen that causes a contact dermatitis 
that can become chronic and disabling. Many wild flowers 
are in this family and some such as Girysanthemum, 
Dahlias, and Magnolia have been domesticated for yard and 
flower gardens and pose dangers to the unwary homeowner. 
The allergens are naturally occurring chemicals which also 
are known to poison livestock. Many other plants such as 
Algerian and English ivy and Primula obconica can also 
cause severe allergic rashes. In the home or office one is 
not safe, since ornamental plants such as Dieffenbachia 
(dumb carte) have dangerous calcium oxalate raphids that 
damage die mouth and tongue of children who chew the 
leaves. Other cases of dermatitis are caused by cuttings of 
the Rorida Holly (Brazilian pepper tree) diat are brought in 
as an ornament at holiday time. One caimot escape the 
scourge of plant dermatitis when traveling abroad, such as 
in South America and Asia, since many tropical trees and 
bushes, such as mangoes, cashew nut shells, etc., contain 
chemical compounds that are similar to the constituents in 
poison ivy and poison oak and consequendy cause a rash in 
>eople who have become allergic to these plants in the 
CJnited States. In addition, chemicals from poison ivy and 
other plants can damage DNA and possibly cause other skin 



disordas, such as cancer. 

PrastHioos snakes oco^y all ecological zones except tlie 
higher altitudes and nortfaan forests: About 8,000 peofrie in 
the United Stipes are bitten each year and 15 will die; 
mostly the very young or very old. The brown rechise 
spider causes dramatic skin damage and can OHnmonly be 
found in homes, bams, borage buildiDgs and capjpgrounds; 
no single treatmeitt has proven to be entirely effective. 

Any breaching of the skin barrio' can transmit diseases 
diat afflict the skin <x the emire body. Lyme disease is 
spread by bites of several species of ticks and is character- 
ized by skin rashes, arthritis, heart and nerve damage. 
Mycobacterial granulomas are ctmmion among pec^le who 
clean flsh tanks and boats. Hot tubs also sfxead bacteria 
diat cause folliculitis. HIV infections generally enter 
through the skin from unprotected sex or intravenous drug 
injections; howev^, it can also be acquired from the needle 
of a tattoo artist Persons infected with HIV suffer from a 
variety of opportunistic bacterial and fungal infections of 
the skin. 

The economic cost of diese natural hazards and problems 
is enormous in terms of quality of life, time lost from wmk 
and expenses for treatment either by physicians or the use 
of over the counter medications. 

Future trends, if left unchecked, will probably lead to 
even greater prevalence of these consequences particularly 
considering the tendency towards shorter work weeks, more 
time off and more leisure time for working adults and early 
retirement for many. 

n. Needs for Future Researdi 

Plant dermatitis research should: 

1 . Focus on means of preventing or reducing poison ivy/ 
oak sensitivity; 

2. Continue to isolate and characterize plant chemicals that 
cause contact and photocontact dermatitis; 

3. Explore means to improve lexical barrier preparations 
that effectively prevent irritant and allergic contact 
dermatitis; 

4. Explain in molecular terms the basis for irritant and 
urticarial responses caused by plants; 

5. Investigate plant genes that can be manipulated to 
reduce production of irritant and allergenic chemicals; 

6. Study die mutagenic and tumor producing potential of 
plant chemicals that damage DNA; and 

7. Develop a reliable patch test screen for sesquiterpene 
lactone dermatitis. 

Future marine biology research should: 
1 . Delineate mechanisms by which marine venoms and 
toxins injure humans; 



JO 



357 



2. Investigate the humaA immunosuppression induced by 
marine envenomation by itself or synergistically with 
UV; 

3. Study the means by which physical or mechanical 
control procedures can be exerted to prevent these 
disorders; 

4. Measure effects of industrial pollutants upon the repro- 
ductive stages of venomous or edible marine life; and 

5. Make an increased effort to quantify UV and thermal 
alterations affecting the marine environment. 

Future research with arthropods and reptiles should: 

1 . Develop effective antisera, vaccines, and diagnostic 
reagents; 

2. Detail the molecular sequence of events leading to 
massive tissue destruction following brown recluse 
spider bites; and 

3. Explore means of neutralizing the toxic effects of 
venoms by emergency administration of neutralizing 
agents. 

Research on trauma induced infections should: 

1 . Identify generic molecular signals that distinguish 
infection from skin injury; 

2. Identify nonimmune mechanisms of antimicrobial 
activity that will be useful as topical preventatives; and 

3. Develop new broad spectrum antimicrobial agents for 
topical use. 

m. Needs for Future Education 

1 . I'ublic education is at the heart of any program to 
prevent or reduce skin injury by environmental hazards. 
But to be truly effective, input is required from the 
interested news media, teachers at all levels of educa- 
tion, private business, philanthropic agencies, state, 
regional and national agencies involved in public 
education and the medical scientific community. The 
interest in the Secretary of Education in designating a 
coordinator for education of the public about skin 
hazards from the environment should be encouraged. 
This activity should be assisted by a centralized registry 
of qualified volunteer consultants to insure that dissemi- 
nated information is correct and germane. 

2. There should be increased beachside advertising and 
warnings against exposure to excessive solar radiation 
and dangerous marine animals. Educational efforts 
should be coordinated nationally and aimed at those 
giving instruction in water safety, diving, lifeguard 
certification, as well as emergency room and paramedi- 
cal staff. These educational efforts should be based on 
information from a panel of experts. 



3. The public should be instructed on proper identification 
of poison ivy/oak/sumac and the principles of preven- 
tion, first aid treatment and physician referral. Children 
especially need to learn the risks of injuries from other 
plants as well. The educational program should be 
coordinated at the state or regional level. 

4. The public needs to learn how to identify dangerous 
snakes and spiders. Educational efforts should be 
coordinated nationally and aimed at those involved in 
outdoor activities. Emergency room and paramedical 
staff and physicians should be made familiar with 
appropriate fu'st aid and medical treatment of these 
injuries. These educational efforts should be based on 
information from a panel of experts. 

5. Education of general physicians and dermatologists 
should be undertaken by the American Academy of 
Dermatology under the umbrella of a nationally coordi- 
nated education plan. 

rV. Needs for Future Public Action 

An area amenable to regulation, or alternatively, deregula- 
tion, is prevention of poison ivy/oak dermatitis. FDA 
regulations need to be amended to allow development of 
topical blocking agents. The government and industry 
should be encouraged to develop prophylactic vaccines. 
Laws need to be written to encourage orphan drug develop- 
ment in this field. 

In the field of marine dermatological problems, there 
needs to be: 

1 . More legislation and action to curb beachside waste and 
erosion, and limit pollution and sediment ninoff into 
public waters; and 

2. The establishment of better seafood quality. 

Finally, advocacy and environmental groups should become 
more aware of skin hazards from the environment, and they 
should work with medicine to promote public education and 
legislation to ease the personal and economic burdens seen 
in our growing leisure society. 



11 



358 



Man-Made Hazards 

L IntroductkHi 

'' The skin is ttie largest organ in the body and is a major 
interface between humans and their (Aysical, chemical and 
biological environments. It is a foremost pmtal of entry of 
potentially hazardous agents and is a particularly vulnerable 
target for damage firom man-made occupational and envi- 
rormiental diseases and injuries. It is a uniquely accessible 
model system to detect hazards and to study mechanisms of 
a wide variety of biologic functions, including adaptive 
processes and adverse reactions. 

This section provides an overview of man-made hazards 
to the skin, emphasizing occupational conditions, and lists 
specific needs for future research, education and public 
acticm as part of an overall strategy to prevent envirotunen- 
tal skin diseases. Dramatological problems arise from 
exposure from home, work and recreation. Most of die data 
comes from studies dealing with occupational hazards. 
Occupational skin dismders are impratant causes of 
morbidity and disabiUty in the workplace. Recognizing this 
in^xnlance, the U.S. Department of Labor commissioned a 
StaiKlards Advisory Committee on Cutaneous Hazards in 
1978 which issued recommendations for improved surveil- 
lance, preventicHi and research. In 1980, the National 
Wnstibite for Occupational Safety and Health (NIOSH) 
^ characterized occupational skin disease as one of the most 
povasive occupational health problems in America. In 
1982, NIOSH placed skin disorders (Xi its list of ten leading 
work related diseases and injuries. This list "was based on 
diree criteria — frequency of occurrmce, severity and 
amenability to prevention. The list also served as a focal 
pdnt to devel(^ strategies for preventing these occupational 
problems. In 1988, NIOSH and die Amoican Academy of 
Dermatology jointly ^xmsored a national synqiosium to 
discuss specific measures to implenieiit the NIOSH National 
Strategy for the Prevention of Dermatrdogical Conditions. 
That document and related reports so-ves as the basis for 
fiirtba recommendations in this rqraH 

Prevalence, Severity and Importance: 
Efifiective strategies for the prevention of occupational skin 
diseases at either stale or natiooal levels must be based on 
systems aqnble of delecting cases firflowed by more 
specific identificatioo (tf high risk oocapadoas, industries of 
employmeot and causal agents. Such systems tdy oa 
infiormadoo reported by three sources: employers, piqra- 
dans or enqrioyees. Emfrioyer-based reporting systems 
sodi as the Bureau of Labor Statistics Annual Swey of 
Occupaliciial Iqnries and ninesaes are most usefiil far 
( '»»n«»«*n»iiig trends. Recent data firam this sorvey snggest 
ttm iaddenoe rates for ocCT p lioaal skia diieaae have been 
slowly inrwfijMing ; agdcakoral and mauufaclu riug industries 



have the highest relative risks. Occupational skin disorders 
are the second most common occupational disease in the 
U.S. Skin disease, the vast majority of which is attributable 
to effects of toxic chemicals, still accoimts for greater than 
30% of all reported occupational diseases. The incidence 
rate in 1990 was 7.9 per 10,000 woticers, producing almost 
61,000 total new cases. 

As many as 2S% of all skin disease patients lose an 
average of eleven days from wcvk annually. Assuming a 
ten to fifty fold underreporting, the estimated costs of 
dermatologic diseases due to lost worker productivity, 
medical costs and disability payments may range between 
$222 million and $1 billion. Acoxdingly, woiIl related skin 
disorders are a health problem, a wwker productivity 
problem, and an economic problem. Most important to 
consider is diat they are preventable. 

Contact Dermatitis: ( 

Contact dermatitis is by far the most common occupational 
skin disease and is also a major nonoccupational, environ- 
mental problem. Contact dermatitis is a common reason f<»i 
consulting a dermatologist and accounts for approximately 
5.7 million physician visits per year. Irritant contact 
dermatitis (as from chemical bums, solvents, soaps, dusts, 
detergents, oils and greases) accounts for 80% of all cases 
and allergic contact dermatitis (as from contact with poison 
ivy, other plants, metals, rubber additives, plastics, resins 
and biocides) accounts for 20% of cases. The prognosis for 
occupaticmal contact dermatitis is surprisingly poor. As 
many as 25% of workers with contact dermatitis devek^ 
persistent domatitis which remains unchanged or even 
worsens despite discontinuance of exposure or change in 
jobs. ArK>ther 50% improve, but still have some degree of 
exacerbations. Only approximately 25% of workers requir- 
ing medical care completely recover bom contact 
dermatitis. 

The diagnosis of allogic contact dermatitis is made by 
diagnostic patch testing, and at present only 20 allergens are< 
approved for diagnostic use by the FDA. Significant 
allergens remain in the environment and are largely umego- 
lated. Few diseases receiving public attention rival the 
presence of nickel allergy which affiects nearly one in ten 
waaaen and approximately 14.5 million Americans. Safe 
exposure limits for nickd in coosuiiict products have been 
estaUisbed, but safe exposure timits for most other aUergem 
are uidmown. Three ooumries m Europe now reqinire 
labding <rf ni(Ael containing objects or regular the amount 
of nickel which may be present m jeweby. Oood 
epidemiologic stxides on many aUeigens are unavailable, bi»| 
reasonable preventive measures can be taken in the form oi 
inqifoved product labeling. 



12 



359 



Skin Cancer: 

In addition to the number of skin cancers due to ultraviolet 
light, some chemicals and compounds have been associated 
with the development of skin cancer. Arsenic, whether 
present in well water, medicines, pesticides or industrial 
processes, is a well-known cause of squamous cell and basal 
cell carcinoma. Polycyclic aromatic hydrocarbon contain- 
ing substances, such as coal tar pitch, mineral oil or anthra- 
cene, have also been repeatedly implicated in nonmelanoma 
skin cancer formation. The possibility of a relationship 
between malignant melanoma and PCBs, various organic 
chemicals, pharmaceutical agents, and vinyl chloride has 
been raised. Prevention of occupational skin cancer in- 
volves the aggressive regulation of the use of cj^.cer causing 
chemicals and ultraviolet light exposure, combined with 
worker education and surveillance. 

Other Skin Disease: 

Up to 5% of occupational skin dfsease may be caused by 
infection from a variety of micro-organisms. Examples 
include herpes simplex in health care workers and anthrax in 
wool handlers. Less than 5% of workers compensation 
claims are due to other disorders such as oil folliculitis and 
chloracne, pigmentary changes including post-inflammatory 
hyperpigmentation and chemical leukoderma, and contact 
and systemic urticaria. 

Skin injuries are an important cause of hospital emer- 
gency room visits and workers compensation claims. 
Punctures and lacerations account for 80% of skin injuries, 
thermal and electrical bums account for 12% and chemical 
bums another 2%. 

Percutaneous Absorption: 

Until the I960's it was generally believed that the integu- 
ment of man was able to screen out most noxious chemicals 
from the environment. Since then, with the availability of 
improved analytic technology, the situation is the exact 
reverse — very few studies exist that do not demonstrate at 
least some percutaneous penetration of most chemicals. 
Skin exposure may occur directly from raw materials, from 
contaminated work surfaces or from toxins inadvertently 
generated during the manufacturing process. Important 
examples include aniline (methemoglobinemia and bladder 
cancer), cyanide salts (acute cellular a.sphyxia and death), 
benzene (aplastic anemia, leukemia), and mercury (central 
nervous system intoxication, kidney failure). Of the more 
than 85,000 chemicals listed in the Registry of Toxic 
Effects of Chemical Substances as of November 1986, less 
than 1,600 have reported dermal LD50 data, and only 1,300 
have any reported cutaneous irritant effects; more specific 
quantitative dose response data are virtually nonexistent. 
Numerous human, animal and in vitro models have been 
developed to study both quantitative and qualitative aspects 



of percutaneous absorption. Each has strengths and weak- 
nesses, but with current analytic data it is possible to greatly 
refine the risk assessment for man from chemical exposure. 
Most animal studies, in which dosing is by the oral or 
parenteral route, require percutaneous penetration for 
extrapolation to use in humans. 

Pesticides: 

Over 25,(X)0 pesticide formulations are currently available 
in the U.S. Approximately 750 active ingredients (of which 
200 are common) are used in these formulations. Pesticides 
are the most important chemical class for acute or chronic 
systemic toxicity due to percutaneous absorption. Thus, 
skin protection is critical in preventing systemic poisoning. 
When pesticides cause skin disorders they usually precipi- 
tate irritant contact dermatitis. This problem, which may be 
much more prevalent than is now recognized, is a particular 
area where proper protective clothing and exposure precau- 
tions are not followed. In fact, the presence of contact 
dermatitis among pesticide-using agricultural workers could 
be used as an indication of inadequate protection from the 
pesticide. Plants in the agricultural work-space can also 
cause dermatitis and may not be suspected if pesticides are 
also present. The actuarial prevalence of skin diseases in 
agricultural workers is unknown and requires study. Aller- 
gic contact dermatitis fixjm pesticides is uncommon. 
Chloracne is also rare, but when it does occur, it usually 
represents an important marker of systemic exposure to 
highly toxic herbicide chemicals. 

Cosmetics: 

Cosmetics are remarkably safe products, but their mass 
public use has resulted in a number of adverse reactions. 
These include burning or irritation of the skin, allergic 
contact dermatitis, photosensitivity, acne, contact urticaria 
and other disorders. Most information on these reactions 
comes from reports in the medical literature or consumer 
reports to manufacturers or the FDA. While some individu- 
als with adverse reactions seek medical care, the vast 
majority change to another product by the trial and error 
method. From studies of the relation of contact dermatitis 
to cosmetics in the U.S. and Europe it was found that 1) 
four to five percent of patch tested patients had contact 
dermatitis to cosmetics, 2) the cause in many cases was not 
apparent to either the patient or physician, 3) skin care and 
hair care products account for most reactions, 4) most 
reactions occur in adult women, 5) face and periorbital 
regions were the most commonly involved and 6) fragrances 
and preservatives were the most common causes of skin 
reactions. Groups which have been instrumental in review- 
ing the safety of cosmetic ingredients are: the Cosmetic 
Ingredient Review Program, the Research Institute of 
Fragrance Materials, and the North American Contact 
Dermatitis Group. 



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Prevention and.Con$rol of Man-Made Hazards: 
Eovirotmaeatal eagioeeridg control measures sudi as 
isolatkm, enclosure, substitution and ventilation are tbe first 
.xiority in preventing occupational and aivironmental skin 
disorders. Replacement of contact aller^genic substances 
with non-aUeigenic substances has been successfully 
enq>loyed. Howevca-, elimination and substitution are not 
always viable ofMions. Personal protective equipment and 
clodnng (PPEQ are important devices which require 
prudent selection based on chemical and [rfiysical properties 
of tbe PPEC and the nature of die chemical exposure. ' 
Incomplete criteria for PPEC selection are available for use 
with mixtures of chemicals. Dermatitis may also be caused 
OT aggravated by CPC use. Recent repwte of latex allergy 
suggest this is a major new occupational health problem 
involving as maity as 7% of health care, workers. These 
individuals are also affected by an array of other medical 
and consumer latex devices. Consumers and normiedical 
workers wearing rubber gloves may also have latex allergy. 
Severe allergic reactions and death from latex barium enema 
tips prompted the FDA to issue alerts to the medical profes- 
sion and latex manufacturers and schedule an international 
latex conference in Baltimore in November 1992. 

Tbe effectiveness of barrier creams remains controversial 
and unproven, although recent strides have been made with 
ooison ivy sensitive individuals. 

Predisposing Factors and the Role of the Dermatologist: 
A number of predisposing factors are important in the 
development of environmental skin disease. These include 
environmental temperature and humidity, personal cleanli- 
ness, and preexisting or latent skin disease, especially atopic 
harHf eczema. Ultimately, the diagnosis is based not only 
on medical data, but also, on technical information about 
industrial processes and job performance. Dermatologists 
are trained to diagnose a vast collection of skin diseases and 
are able to determine whether a skin disorder is or is not 
job-related. Prevention is intimately tied to accurate 
diagnosis arxl treatment 

Although during the last two decades certain strides have 
been made in the U.S. in the prevention and control of num- 
made hazards, there is still much to be done. The creaticMi 
of OSHA, NIOSH, the EPA, NISHS and other agencies in 
the late 1960's and eariy 1970' s, the labeling of over-the- 
counter cosmetics in 1977, and the more recent availability 
of Material Safety Data Sheets (MSDS) are examples. 
However, we are without the necessary motivation, training 
and equipment to adequately study patients with allergic 
contact dermatitis, especially those whose disease originates 
from their occupation. Thousands of Americans each year 
<re left without a correct diagnosis with far-reaching 
consequences not only for them personally, but for the 
economy as well. 



n. Needs for Future Research 

For medical and surgical conditions of tbe skin Ae role of 
tbe denn^ologist is indisputaUe, as no otber physician 
groiq) has tbe expeitise in (bagixisis and managemoit of 
such diseases. 

1. Identification of &ivironmental Dermatoses by their 
Cause and the Populations at Risk. 

a) General: 

1. Improvement in the use of existing surveillance 
and reporting data to genoate additional infuvma- 
tion on causes of environmental skin discxders. 
For example, the Bureau of Labor Statistics will 
begin to collect OSHA 101 Logs which will 
provide supplemental data on causal agents as part 
of their aimual survey. 

2. Increased epidemiological investigations to 
identify uruecognized enviroiunental causes of 
dermatological diseases. 

b) Specific: 

1. Characterization of impcHtant risk fact(»^ and 
causal agents r^ponsible for high rates of skin 
disease in the home, at work and in recreation. 
For example, the prevalence of dermatitis from 
cosmetics, as well as risk factors contributing to 
its occurrence, could be surveyed through the 
National Health Interview Survey. 

2. Study of the risk factors which contribute to 
persistence or chronicity of contact dermatitis. 

3. Expanded epidemiological studies of workers 
exposed to suspected causes of melanoma. Study 
of clusters of cases of melanoma. 

4. Improved tumor registry data and collection of 
data for skin cancer incidence and mortality to 
study the associaticm with environmental factors. 

5. Identification of specific high risk workplaces 
through workers compensation claims. 

6. Development of better methods to identify other 
enviroiunental high risk situations such as reports 
filed in compliance with section 8 of the Toxic 
Substances Control Act 

7. Use of new surveillance techniques to identify 
high risk cutaneous exposures such as data 
collected by the North American Contact 
Dermatitis Group and the National Occupational 
Exposure Survey which contains quantitative 
information on high risk exposures in home, 
industry and occupation. 

8. Use of cohort studies to identify the actual 
prevalence of pesticide related skin diseases and 
assess the value of contact dermatitis in pesticide 



14 



361 



users as a marker of unprotected exposure, 
c) Basic/Applied Research: 

1 . Study of existing cutaneous toxicology models 
(animals or in vitro) to characterize dose-response 
relationships of cutaneous exposure, in order to; a) 
provide more accurate estimates of actual risk, b) 
assist health care providers in their diagnosis of 
probable causal agents and c) facilitate future 
establishment of cutaneous exposure standards. 

2. Development of better and more information 
about cutaneous and systemic toxicity of newly- 
developed chemical substances must be obtained 
before they are widely introduced into the envi- 
ronment. 

3. Linkage of priorities for percutaneous absorption 
research to prioritized multiple causes of environ- 
mental diseases and/or widescale exposure (e.g., 
toxins, carcinogens, mutagens, teratogens, immu- 
nosuppressants). 

4. Enhanced research on the pathomechanism of all 
causes of environmental skin diseases, especially 
irritant and allergic contact dermatitis, pigmentary 
disorders, acne, immunosuppression and 
carcinogenesis. The nature of chronic inflamma- 
tory processes following environmental exposure, 
in particular, remains to be delineated. Such work 
could further primary and secondary preventive 
actions. Study of the mechanisms of induction 
and response to skin tumors is needed to provide 
measures of susceptibility and possible ways to 
intervene once the process has begun. Biomarkers 
of susceptibility, if established, could be very 
useful in counseling workers who might be at risk. 

5. Increased interaction with the research grant 
review committees of NIH on research topics of 
interest to AAD with regular bilateral and multi- 
lateral meetings. 

2. Development of Improved Preventive Techniques and 
Control Technology. 

a) Increased research on physical and chemical engi- 
neering to improve handUng of toxic substances for 
workers. 

b) Further studies to optimize protective clothing. 

c) Coordination of existing guidelines for proper use, 
decontamination and disposal of protective clothing. 

d) Encouragement of development of more effective 
protective creams. 

e) Setting of threshold limits for allergen release from 
consumer and enviroimiental products known to be 
significant cutaneous hazards. 



Encouragement of development of maximum 
allowable levels of exposure to irritants by a coali- 
tion of the interested academic, industrial and 
governmental parties. 
3. Implementation of Prevention and Control Measures. 

a) Evaluation of effective approaches to health care 
delivery for environmental skin conditions. 

b) Development of computer-linked data bases to 
disseminate and exchange information among health 
professionals. 

III. Needs for Future Education 

Dermatologists often have a key role as primary educators. 
Better educational tools and methods could improve the 
effectiveness of their role. In prevention and treatment 
dermatology should foster education of physicians in 
training as well as other health professionals. 

1 . Development of programs to educate the public, includ- 
ing workers and management, on proper techniques for 
personal hygiene to minimize environmental risks of 
skin disease. 

2. Education of health care professionals in dermatology, 
pediatrics, family practice, internal medicine, emergency 
medicine and occupational medicine by improving core 
curricula of various residency training and CME pro- 
grams. 

3. Stressing the importance of environmental health in 
dermatology training programs. 

4. Requiring u-aining in occupational dermatology by well- 
trained individuals to include patch testing (including 
photo-patch testing) and contact dermatitis for dermatol- 
ogy residents. 

5. Addition of environmental health and safety concerns 
into existing health curricula in schools and colleges. 

6. Encouragement of motivational research and application 
of innovative techniques to increase compliance with 
effective measures to prevent environmental skin 
disease. 

7. Development of educational campaigns for the mass 
media should be directed at increasing the overall 
awareness and prevention of environmental cutaneous 
hazards. 

rv. Needs for Future Public Action 

Dermatologists should play a key role with other cognate 
professionals and scientists involved in the field of environ- 
mental health in formulating priorities and public policy. 
1 . Interaction with Public Agencies. 

a) Support of the 1988 NIOSH strategy document. 

b) Labelling the ingredients of those products that are 
expected to come in contact with human skin in 



15 



362 



routine use. For example, over-the-counter dnigs 
(including sunscreens) and salon products (CPSC, 
FDA, EPA, etc.). 

c) Increasing the supply of allergens available for 
diagnostic contact dennatitis wotk by requesting an 
exemption of FDA regulations for registration of 
patch test allergens so that additional aUergens 
cuirendy available in Europe may be made available 
for diagnostic use in the United States. Alternatively, 
in the absence of existing, approved aUergens for 
diagnostic contact dennatitis testing, the FDA should 
be petitioned to evaluate its existing legal authority to 
determine if there is a mechanism by which approved 
allergens for diagnostic purposes may be imported 
into the United States from countries which have 
regulated, licensed suppliers. 

d) Establishment of a task force to develq) standards for 
repotting new medical findings to appropriate 
governmental agencies when new aUergens are 
detected. 

e) Continued support of NIOSH efforts by the AAD to 
include an occupational dermatologist on its staff 
who can also faciUtate the transfer of information 
between the two organizations. 

f) Urging of adequate supprat for extramural research 
on occupational and environmental skin disease. 

CoaUtions - Interaction with public and private interest 
groups and medical oiganizatioiis to provide education 
and liaison with communities. 



16 



364 




365 




366 




367 




368 




369 




370 



American Academy of Dermatology 




National Conference on 
Environmental Hazards to the Skin 

October 15-16, 1992 



Proceedings 



^♦^""♦"''^o^ ©1994 by the American Academy of Dermatology, Schaumburg, Illinois 
I AAD : No part of this publication may be reproduced without the prior written 
'«*,^"%^°" permission of the American Academy of Dermatology. 



371 



Foreword 

Wilma F. Bergfeld, MD. 



As the 1992 president, American Academy of Dermatology, 
one of my major initiatives during the presidency was to 
organize and sponsor the fii^t comprehensive interdiscipli- 
nary meeting to discuss the effects of the world's deteriorat- 
ing environment on the skin. This was the first National 
Conference on Environmental Hazards to the Skin, held in 
Washington, D.C., October 15-16, 1992. The theme of the 
meeting was to develop an action plan to conquer the 
growing problem, as depicted by an imaginative introduc- 
tion video and developed in depth by thirty experts in the 
field of medicine, environmental issues, government 
regulations and research. The major role of the meeting was 
to identify and define the environmental problems, establish 
a need for monitoring and surveillance, and ultimately 
address prevention or control of environmental hazards to 
the sJdn. The conference explored three different environ- 
mental areas: (1 ) hazards of ozone depletion and ultra violet 
light; (2) naturally-occurring hazards; and (3) man-made 
hazards. Concerns common to all of the areas included 
adverse events of immimosuppression and tumor produc- 
tion; secondary concerns included infection and contact 
dermatitis. 

The consensus panel of experts addressed the needs and 
opportunities for increased research, education, presentation 
and legislative action in their final consensus report which 
represents a strategic action plan for the American Academy 
of Dermatology. 

AAD Environmental Mission Statement 

The skin is the body's major interface with the environment 
The dermatologist has a specific responsibility for advocat- 
ing and insuring a healthy environment with respect to those 
factors which affect the skio. Those factors include the 
ozone level and the atmosphere, natural plant and animal 
toxicants and allergens, and occupational and man-made 
chemicals that adversely affect the skin. The American 
Academy of Dermatology accompUshes those missions by a 
comprehensive program of a professional and public 
education, the encouragement of basic and clinical research 
into the effects of these agents and the prevention of their 
effects, and when necessary, the encouragonent of new 
legislation. 

Current AAD Action 

The American Academy of Dermatology has already formed 
meaningful coalitions with the American Cancer Society, the 
American Academy of Otolaryngology-Head and Neck 



Surgery Foundation, Inc, and the National Association of 
Physicians for the Environment. In addition, through the 
1992 visionaiy strategic plan, a Section on Cotnmunication 
and the Enviroimient was established which placed 
environmental issues as a high priority of the American 
Academy of Dermatology. Under the Section of 
Conunurucation and the Environment, chaired by Wilraa F. 
Bergfeld, M.D.. are two major councils: the Communica- 
tion Council, chaired by Patricia K. Farris, M.D. and the 
Envirotunental Council, chaired by Lowell A. Goldsmith, 
M.D. This reorganization strengthens and coordinates 
specific environmental committees, namely contact 
demutitis, epidemiology, melanomas/sk<;i cancer (atmo- 
spheric) and occupational dermatology. Other continuing 
environmental initiatives include suntan parlor "protection" 
legislation, skin cancer screening programs, school and 
pubUc educational programs regarding sun. sun protection 
and skin cancer. The development of the waste disposal 
poUcy, the formation of the industrial roundtable discussion, 
and greater interaction with the FDA regarding sunscreens 
and contact allergy, have been most successfiil. The 
American Academy of Dermatology is certainly on the 
forefixint of the single most current pubUc issue and that is 
the deteriorating environment. 

Executive Summary: Environmental Hazards on tlie Sicin 

The following executive summary of the consensus docu- 
ment titled Environmental Hazards to the Skin represents 
the American Academy of Dermatology's action plan. 

This report summarizes the deliberations of the two-day 
meeting. The objectives of the conference were: 
■ To define a set of wide-ranging issues related to skin 

and the environment; 
I To begin to define the magnitude of the problem; and 
I To have a set of consensus panels address the needs and 
opportunities for increased research, education, preven- 
tion and legislative action. 

The first half -day was devoted to the status of ozone 
depletion in the atmosphere which leads to increased 
ultraviolet B (UVB) at the earth's surface with consequent 
increases in skin neoplasms, including melanoma. The next 
half-day, speakers discussed some of the natural plant, 
marine animal and terrestrial animal effects on human skin. 
On the final half-day, experts discussed the man-made 
(especially industrial) hazards that affect the skin. 

A supplemental meeting report simimarizes scientific 



Pkocebdinqs of the National CoNnxscE ow ENvmoNMENiAL Hazakds to t«e Skin 



372 



deliberations and has more detailed versions of the recom- 
mendations. The needs sirnimaiized are in research, public 
and professional education which relate to educational 
programs, preventive programs, and research applicable to 
more than one set of these environmental hazards. These 
needs offer the AAD new opportunities to educate the 
public-at-large. This summary highlights the major recom- 
mendations of the supplemental report and includes recom- 
mendations for the atmospheric hazards, other natural 
hazards and man-made hazard sections of the report The 
detailed body of the report should be reviewed to obtain 
supporting data and for more detailed versions of the 
initiatives which should be addressed. 

A. Research Needs: 

1 . Better definition of environmental changes and the extent 
of dermatology-related problems due to enviroimiental 
factors. 

I Improved quantification of the changes in UVB at 
the earth's surface related to alterations in the ozone 
layer. 

I Improved surveillance reporting and investigation 
of environmentaUy- and occupationally-caused skin 
diseases. Identification of the pertinent risk factors 
for disorders such as irritant and allergic contact 
dermatitis and skin tumors including melanoma. 
Use of cohort stiidies to find the real prevalence of 
pesticide-induced skin disease. 

2. Definition of die basic mechanism of environmentally- 
caused disease. 

I Definition of die action spectra for the production 

of melanoma. 
I Further evaluation of action spectra for 

nomnelanoma skin cancer. 
I More precise definition of die effects of acute and 

chronic exposure to UVB and ultraviolet A (UVA) 

on skin, the immune system, and adaptive and 

repair fimctions of skin after UV injury. 
I Determination of the genetic factors predisposing to 

skin cancers and melanoma, contact dermatitis and 

irritant dermatitis, and definition of their molecular 

basis. 
I Characterization of the plant allergens causing 

contact and photocontact dermatitis and urticaria. 

and definition of the molecular basis of their action. 

Development of new patch tests for plant agents 

including sesquiterpenes. 
I Delineation of the mechanism by which marine 

venoms and toxins (eg, brown recluse spiders) 

injure the skin. 



I Development of better information about the 
cutaneous and systemic toxicity of agents before 
they are introduced into the environment Develop- 
ment of systems for reporting on the toxicity of new 
agents to the appropriate governmental agencies. 

I Encouragement of motivational research to get 
optimum acceptance of prevention programs. 

B. Development of New Protective, Preventive and 
Ttierapeutic Agents: 

I Development of better sunscreens and other 
photoprotective agents including establishing 
optimum guidelines for their use. 

I Development of new barrier preparations for 
contact and irritant dermatitis. 

I Development of new plant varieties which lack 
highly allergenic compounds. 

I Development of new antisera vaccines and diagnos- 
tic agents for toxic arthropod reptile toxins. 

I Development of new broad-spectrum antimicrobial 
agents for topical use, including the development of 
new preservatives for skin preparations. 

I Increased research on physical and chemical 
engineering to improve the handling of toxic 
substances by workers. 

I Further studies to optiinize protective clothing. 

C. Prevention by Education and Early Disease Detection: 

■ Development of better measures to assess the 
effectiveness of mass skin cancer screening pro- 
grams. 

I Encouragement of sim avoidance and avoidance of 
sunburn. Determination of the effectiveness of 
programs to have daily "sun intensity" measures 
broadcast by local media to decrease sun exposure. 

I Continuation and increased emphasis on skin 
cancer screening programs, including more active 
participation of senior citizen groups. Encourage- 
ment of programs which will allow O^atment of 
skin cancers in patients who are underinsured or 
economically disadvantaged. 

0. Public Education: 

I Development of a major program in public educa- 
tion on die "ABCD" rules for detecting melanoma 
with media, milk carton panels and mass media. 

■ Development and coordination of enhanced pro- 
grams in sun education, plant hazards and marine 
hazards for the pediatric age group. This should 
include support of education by pediatricians and 



PReOEDINOS OF THE NATIONAL CONTQIENCE ON ENVKONMEhfTAL HAZARDS TO THE SlON 



373 



school nurses with pamphlets, videotapes, game kits, 
etc. 

■ Estabhshment of goals that by graduation from the 
eighth grade students should know principles of sun 
protection, be able to identify the most allergenic 
plants and know how to identify and avoid the 
major poisonous and venomous creatures in the 
United States. 

I Incorporation of health and safety concerns about 
the workplace environment in school and college 
health programs. 

I Education pamphlets and videos for waiting rooms 
on the environment and effects of changes in the 
ozone layer. 

I Special education programs for older Americans 
(especially for men who in the past, in contrast to 
women, have neglected to examine their skin). 
Determination of medical specialties, (internal 
medicine, urology, etc.) and community sites 
having potential for such education. 

I Alerting the public to the danger of tanning salons. 

I Development, support and encouragement of 
programs for workers and management on proper 
techniques of personal hygiene to minimize occupa- 
tional risks in the workplace. 

E. Physician Education: 

I Increased education on the effect of the environment 
(including the work environment) on the skin, at all 
phases of undergraduate and postgraduate medical 
education. 

I Development of computer-linked databases for 

occupational and environmental hazards with listing 
of resource individuals for usual and serious 
conditions. 

I Emphasis of all environmental education in derma- 
tology residency training programs and strong 
encouragement of active programs in patch testing 
in the residencies. 

F. Public Action: 
Coalitions 

I Leadership in coalitions to increase funding for 
health research related to the environment. Associ- 
ation with all national and international medical 
organizations actively working to improve the 
envirotunent. 

I Involvement with senior citizen groups with respect 
to setting standards for environmental health. 
Active support of skin cancer screening effrats. 



Inclusion of preventive care as a guaranteed part of 
the Medicare program. 

■ Participation with groups such as the American 
Cancer Society, Centers for Disease Control, Skin 
Cancer Foundation, and senior citizen groups to 
expand and enhance educational efforts. Institution 
of a formal clearinghouse or a formal coalition of 
these groups and organizations for this piupose. 

I Establishment of "Industry-AAD" roundlable with 
the sunscreen and sun protective manufacturers and 
the AAD (FDA could also be included) so that the 
needs and specifications for new products can be 
discussed. 

Legislative and Regulative Action 

■ Tighter regulation of the tanning booth industry, 
including prohibiting the use of tanning facilities by 
minors, informing the public of the risks, and 
limiting total dose people can be exposed to. 

I Testimony at all the appropriate congressional 
comminees to get increased funding for those 
governmental/regulatory agencies which support 
research on the environment. 

I Support of all national and international measures 
to decrease the production and spread of ozone- 
depleting chemicals into the environment. 

I Modification of FDA rules to encourage the 

development of new topical agents and vaccines for 
poison ivy and poison oak. 

I Setting of threshold limits for allergen release for 
consumer and environmental prtxlucts known to 
have significant skin hazards. Development of 
maximum allowable levels of exposure to irritants. 

■ Support of the 1988 National Institute on Occupa- 
tional Safety and Health (NIOSH) strategy docu- 
ment. 

I Detailed labelling of all products which come in 
contact with human skin, including beauty salon 
products and over-the-counter products. 

I Increased supply of allergens available for diagnos- 
tic contact dermatology testing. 

I Assurance of a full-time occupational dermatologist 
on the staff of NIOSH. 

Wilma F. Bergfeld. M.D., is past president of the American 
Academy of Dermatology. The National Conference on Environ- 
mental Havzrds to the Skin was convened during her term as 
AAD president and she served as the Conference's presiding 
officer. She currently chairs the AAD Section on Communica- 
tiotis and the Environment. 



PROCEEDINaS OP TOE NAnONAL CONFEKENCT ON EnVKONMEOTAL HaZAROS TO THE SkIN 



374 



Introduction 



Lowell A. Goldsmith, M.D. 



Depicting the effects of the environment on man, and man on the environment, 
requires a large canvas and a rich palette. Focusing on the effects of the environ- 
ment on the skin, one organ system, permitted us to describe the complexity of the 
skin's interactions with physical, chemical and biological agents in the environment. 
In the coming decade, these interactions will be defined in a much more sopfiisticat- 
ed fashion. The interactions between various environmental agents is just beginning 
to be defined. The role of genetic diversity and an individual's reaction to the 
environment will be a major factor to consider. The skin contains biological 
systems for protecting against environmental damage and also has systems that may 
accentuate biological damage or may transfer those deleterious effects to other 
organs. Our authors, in a series of papers, have outlined these effects and processes 
and their potential for damage. 

It was the consensus of this conference that dermatologists, other physicians, 
and scientists, in addition to all citizens, have the responsibility to be activists in the 
process of protecting and repairing our environment. This will entail major commit- 
ments to public education and public pohcy development at the local, slate, national, 
and international levels. This is no small task, biit the conferees were confident that 
the American Academy of Dermatology can be a major and important force so that 
the world will have an improved environment because of our efforts. 

I would like to thank all of the authors and the American Academy of Dermatol- 
ogy, especially Ginny Thiersch and Tom Pearson, for their assistance, and Darrell S. 
Rigel, M.D. for his role in implementing the computerized real-time consensus 
portion of the conference. I appreciate the faith that Wilma F. Bergfeld, M.D. had in 
giving me a role in conference planning, implementing consensus portions of the 
conference and in the editing of these proceedings. 

Lowell A. Goldsmilh, M.D. 



Lowell A. Goldsmith. M.D., served at co-chair of the 1992 AAD National Conference on 
Environmental Hazards to the Skin. He currently chairs the Academy's Council on the 
Environment and serves as a member of the AAD Board of Directors. 



Proceedinos of the Nationai. Conference on Environmeotal Hazards to the Skin 



375 



Keynote Address 
Understanding Earth's Enyironment: The View From Space 

Richaixi Truly. VADM (Ret.) 



I have spent most of my professional days in America's 
space program. My experience has extended from flying 
aboard the space shuttles Enterprise. Columbia, and Chal- 
lenger, to managing various space endeavors both in the 
national security arena and at National Aeronautics & Space 
Administration (NASA). Most recently, I served as the 
NASA Administrator, a post I left April ist of this year 
( 1 992). It may not seem at first glance that there is a logical 
and direct connection between my work in space and yours 
with threats to the himian skin, but in fact there certainly is. 
For example, just a few days ago the most recent results 
were publicly released about the current ozone depletion, 
which can best be described as the "mother of all ozone 
holes." This vital information is only obtainable and 
trackable on a global basis via satellite. Today the atmo- 
spheric physics of this ozone fanning are analyzed routinely 
and in large part by scientists in or sponsored by NASA and 
the National Oceanic and Atmospheric Administration 
(NOAA). They will be a part of your discussion the better 
part of this morning. 

My good friend. Dr. Bob Watson, vidll update you this 
morning as to how NASA sees this issue as a part of the 
upcoming subject. 1 look forward to the upcoming discus- 
sion as. I am sure you do. I'm also hoping to be joined with 
you this evening at the reception by another friend of mine 
and an astronaut. Dr. Kathy Sullivan. Kathy has flown 
several times in space and is the first woman to ever make 
an extra vehicular activity, or space walk. She is currently 
the chief scientist at NOAA. Just 22 short years have passed 
since Neal Armstrong made that final step off of the bottom 
ladder rung of the lunar module named Eagle onto the dusty 
surface of another body of our solar system. I personally 
believe that the Apollo exploration of the moon will be the 
event for which this century will be remembered. Not the 
World Wars, not Viemam, but Apollo, for Apollo represents 
the final achievement of the first baby step of the human 
dream of ultimate exploration. I further beUeve that the 
exploration of the planet Mars, not by America but by a 
future coalition of nations, will dominate the history books 
that chronicle the exploits of the 21st century. 1 must add 
that I have also always thought that Apollo's most signifi- 
cant contribution to history was not the view that it gave us 
of the moon, but the view it gave us of our fragile precious 



earth. That is where the connection between our profe-ssions 
comes into play. 

For more than 30 years, humans have made space the 
proving ground for expanding the human potential. For 
more than 30 years, our activities in space have embodied 
the human urge to explore the unknown, to open new 
horizons, and to push back frontiers that limit our goals here 
on earth. Our early missions from planet earth have ex- 
panded our understanding of the solar system, the galaxies, 
and the universe, and we have seen strange new worlds as 
never before. We have come to realize that space flight 
holds the key to understanding our own world, planet earth, 
in its entirety as a global system. Going into space has 
opened our eyes to what we know and what we don't know 
about the earth. In less than half the span of a human 
lifetime, flargely through the findings of the spacebome 
sensors) humankind has transformed its view of the earth's 
land masses, its oceans, its atmosphere, and its solar envi- 
ronment. 

These words about the unique view of earth as seen 
from above are not figurative to me. I am one of those 
lucky mortals who have seen earth literally from a global 
prospective. From orbit, the everchanging nature of the 
planet earth is startling, on scales ranging firom seconds and 
hours to thousands and millions of years. From the perspec- 
tive of space, there are no national boundaries. From out 
there, the dynamic nature of our global environment is as 
dramatic as it is visible. Moimtain peaks reach up that have 
evolved over hundreds of millions of years, while eddies 
visible in ocean currents change minute by minute as you 
watch them. From out there, earth's land and sea, the ice 
and atmosphere driven from above over untold millennia by 
the solar environment are seen to come together as a system 
— a very, very complex and fragile system. But recent 
developments are robbing this system, not from above but 
from below. 

Your space program today has many parts, unlike the 
early days when Apollo was the central and driving theme. 
From space station Freedom to the exploration of the outer 
planets, your space program is a national jewel. A vital part 
of the program, which deals with the earth sciences, helps to 
provide to the policy makers the answers on why and how 
onr planet is changing and what we can and must do to cope 



Proceedings of the National Conference on Envkonmental Hazards to the Skin 



376 



with future global change. Having analyzed the earth with 
this space data, we see a complex and dynamic world that is 
more than the sum of its parts. It is a fragile system in 
which disruptions at any point reverberate throughout the 
whole. But unlike times past, many of these disruptions 
have recendy been brought about by human activities. We 
now know that the economic and technological activities 
over the past few generations have undoubtedly contributed 
significantly to global change. Humans are most definitely 
now a critical part of earth's balance. It is clear that we have 
a lot to leam about how to be constructive in this equation. 
To our collective great discredit, we have contributed in 
large measure to depleting the ozone layer, to transforming 
once fertile lands to arid forests and deserts, to deforestation 
of tropical and other forests and to creating acid rain, and 
possibly, possibly, we have introduced a new and unstable 
factor into the equation of the earth's long-stable and natural 
greenhouse effect. 

Certainly the effects of human activities amount to an 
experiment on our own home without complete knowledge 
of the experiment's effect. The good news is, (and princi- 
pally, I believe, as the direct result of the impact of those 
early Apollo photographs of our blue planet) that we are 
now positioning ourselves to understand the consequences 
of our actions. Once sufficiently understood, I trust we will 
be able to do something about them together. Every nation 
will have a role to play in solving these problems, because 
global problems will require global solutions executed on an 
international scale. It is imperative that we join together to 
correlate and integrate measurements from space and the 
ground all over this globe. 

At the heart of these efforts, and essential to their 
success, is NASA's leadership through its Mission to Planet 
Earth program. The aim is to provide comprehensive 
observations from space requiring, in large part concentra- 
tions of orbiting, advanced remote sensing instiimientation, 
and in some cases, mission lifetimes extending over a 
decade or more. 1 am very proud to say that the first 
sateUite of the Mission to Planet Earth program left the 
launch pad while I was NASA AdrainisQ-ator. The principle 
thrust of this Mission to Planet Earth is called the Earth 
Observing System, which is well underway and will fly 
beginning in this decade. Polar orbiting satellites will 
utilize improved sensors for simultaneous observations of 
global variables. 

In our long human history, continents have been 
mapped, mountains have been climbed, the great ice 
expanses of our poles have been discovered and trekked. 
Brave men and women have lost their lives for a purpose as 
simple as peeking over the next hill, climbing to the next 
precipice, or diving to a new and crushing depth. Always 
the next achievement was made possible by new technolo- 



gy. Today, through America's space program, our society 
has set into motion a unique use of new technology on a 
scale never before attempted, fust to understand and then to 
affect the very home on which we all depend. At the same 
time, and also using new technology, you have a huge and 
interim responsibility to understand the detrimental medical 
effects of die ill-advised actions already taken. You have 
the daunting task of dealing with healdi effects that have not 
yet matured and are not yet well understood today. 

I admire your work and that of the Academy and know 
that your very presence at this vital national conference will 
be a part of the difference you will make. I fervenUy 
believe that togedier we have the opportunity to ensure that 
the precious gifts of our bountiful earth can be passed on to 
future generations. America's space program intends to 
continue to play a leading role in helping to secure our 
future for the sake of the entire world community and future 
generations. 

I want to thank you again for the opportunity to be here 
with you this morning. 



Proceedings of the National Conference on Envkonmeotal Hazards to toe Skin 



377 



Atmospheric Hazards to the Skin 



Proceedings of toe Nationai, CoNraxENCE on Environmental Hazards to the Skin 



378 



Environmental Atmospheric Issues 
AND Their Effects on Skin Cancer 

Darnell S. Rigel, M.D. 



Introduction 

The most commonly diagnosed cancer in the world is skin 
cancer. One in three of all cancers diagnosed is a skin 
cancer. At cuirent rates, 1 in 6 Americans will develop skin 
cancer during their lifetime. In 1993, over 700,000 new 
cases of skin cancer will be diagnosed in the U.S. and 9,100 
persons will die of this malignancy (Figure 1). The inci- 
dence of the most dangerous type of skin cancer, malignant 
melanoma, is increasing faster than any other cancer in the 
U.S. and worldwide, and has doubled in the U.S. over the 
last decade. Given these numbers, skin cancer is a serious 
public health problem that will only increase in magnitude 
into the next century.' 

Causation Issues 

Most of the risk factors associated with skin cancer have 
been well documented. The key risk factors for skin cancer 
J are primarily phenotypically related. Persons with fair skin, 
light eyes, red or blond hair, those who tan poorly and 
sunburn easily are at the highest risk. 

All of these risk factors have a common theme that 
points to the etiology of skin cancer. Increased susceptibili- 
ty and exposure to ultraviolet B (UVB) radiation (290 nm- 
320 nm) is direcdy related to greater risk for the develop- 
ment of skin cancer. UVB intensity increases with proximi- 
ty to the equator. Queensland, Australia, an area with fair- 
skinned persons living closest to the equator, has the highest 
skin cancer rate in the world. Also, increased altitude 
allows for a greater UVB intensity. UVB intensity increas- 
es about 4% for every 1 ,000 feet of elevation. Populations 
in mountainous areas, therefore, have disproportionately 
high skin cancer rates. 

Environmental Factors Influencing SIcin Cancer Rates 

It is clear that factors influencing the degree of UVB 
irradiance on the earth's surface should, directly or indirect- 
ly, influence skin cancer rates. The most important environ- 
mental factor regulating this phenomenon is the stratospher- 
ic ozone layer. 

Ozone (Oj) is the primary filter that reduces the levels 
of UV radiation reaching the earth's surface. However, 
ozone is a selective filter, it blocks all of the shorter UVC 
band radiation, more of the longer wave UVA radiation, and 
only part of the UVB band. This selectivity becomes 



important in that small decreases in ozone levels can result 
in a significant increase in the amount of surface UVB 
radiation (Figure 2). 

Stratospheric depletion was first suggested in 1%9 by 
Dr. Sherwood Roland and his associates. NASA studies 
showed a 3%-9% depletion in the temperate zones during 
the 1980s. A recent NASA report using data from the 
Nimbus satellite showed a significantly increased rate of 
ozone depletion in 1992, especially in the mid-latitude 
areas.^ 

The U.S. Environmental Protection Agency (EPA) 
estimates for each 1% decrease in ozone (Figure 3), melano- 
ma mortality worldwide will increase l%-2%. In 1987, the 
EPA estimated that if no attempts were made to stop ozone 
depletion, 145 million cases of skin cancer and 2 million 
ad<iitiona] deaths between then and the year 207S would be 
directly attributed to this problem. Because of these con- 
cerns, in 1987 the Montreal Protocols were rabfied by 46 
countries. This treaty limits the production of ozone- 
depleting chemicals, such as chlorofluorocarbons (CFC), 
and promotes increased development of "ozone-safe" 
substitutes. The terms of the treaty were strengthened in 
1990 and again in 1992 to phase out CFC products more 
rapidly. Under the current rules, the U.S. must end CFC 
production by the end of 1995. 

However, even an immediate total ban on CFC products 
will not stop the rise in skin cancer rates into the next 
century. CFCs are relatively inert and act as catalysts in the 
reaction that destroys ozone. Due to their inertia, CFCs 
persist at the stratospheric level for decades. One molecule 
of CFC can destroy hundreds of thousands of molecules of 
ozone over many years. Also, CFCs may continue to escape 
into the atmosphere from old space refrigeration and air 
conditioning units unless rigorous recovery rules are 
adopted. Finally, from 10 to 20 years may elapse Irom the 
time a person is damaged from UVB radiation until a skin 
cancer becomes clinically apparent.' Therefore, even with 
the most aggressive measures, it is clear that skin cancer 
rates will continue to rise well into the 21st century. 

Other environmental factors also will influence skin 
cancer rates. If global warming continues, the warmer 
weather will lead to more outdoor time with less clothing 
coverage, resulting in more UVB exposure. On the other 
hand, increased ground-level pollution in urban areas 



Proceedings of the National Conference on Environmental Hazards to the Skin 



379 



produces some protection fh>m UVB iiradiance. It will take 
computer models more sophisticated than those cunently 
available to determine more accurately the net effects of 
these confounding factors. 

Measures to Combat Environmental Effects on Skin 
fencer Rates 

Both short- and long-range action plans must be developed 
to combat the effects of the environment on future skin 
cancer trends. Recognizing this need, the American Acade- 
my of Dermatology organized this conference on environ- 
mental hazards to the skin. Physicians should be conscious 
of the environmental effects on health in general and should 
support local, national and international legislation and 
regulations that promote "ecological soundness." The 
projected rise in skin cancer rates means that primary care 
physicians may need more and broader training in the 
recognition and diagnosis of early lesions. Skin cancer is 
perhaps the most clear-cut case for neoplasm where this 
early detection and treatment are key. When found and 
treated early, even melanoma is virtually 100% curable. 
However, no current effective treatment exists for advanced 
melanoma. For these reasons, expanded education of 
physicians at the medical student level through post- 
graduate levels will be increasingly important. 

In addition to education of medical professionals, the 
lay public's baseline knowledge of this problem must be 
increased. This will happen indirectly, as more people will 
know persons who will develop skin cancer as the rates rise. 
However, mass public education efforts such as those that 
have already been successful in Australia need to be devel- 
oped worldwide. 

In the United Slates over the past eight years, more than 
3,000 dermatologists voluntarily screened about three 
quarters of a million Americans for skin cancer as part of 
the American Academy of Dermatology's National Skin 
Cancer Screening program. Thousands of skin cancers have 
been detected, most in their early treatable phase. 

Mass screenings provide more than the immediate 
benefits of detection. Screenings allow an opportunity to 
present a "teachable moment" to attendees regarding skin 
cancer issues. As a result, mass screening programs can 
also raise pubUc awareness of the increasing problem. 

Improved methods of protection from UVB radiation 
need to be developed. Broader spectrum, more cosmetically 
acceptable sunscreens will be important In addition to 
topically applied formulations, other forms, such as long- 
acting oral and parenteral preparations, will be developed. 
Better forms of lightweight, tighter weave fabric may be 
needed to deal with the warmer temperatures and increased 
UV radiation that may be present in the next century. 
Fmally, and perhaps more importantly, thoe is a need to 



thiiJt of sun protection in broader, more creative ways. For 
example, the planting of more shade trees would fit within 
the guidelines for these creative needs. 

Summary 

Current environmental tre ids forecast a continued signifi- 
cant rise in skin cancer rates well into the 21st century. 
Better environmental regulation and physician and public 
awareness of this problem may partially ameliorate this 
problem. 

References 

1 . Friedman RJ, Rigel OS, Kopf AW. Malignant melano- 
ma in the 1990s: The continued importance of early 
detection and the role of physician examination and 
self-examination of the skin. CA 1991;41:201-226. 

2. Ozone depletion greater than estimate. Wall Street 
Journal, April 23, 1993:BI2. 

3. Brown J, et al. Lag from exposure to appearance of 
melanoma in World War II veterans serving in the 
South Pacific. Int J Dermatol 1988;14:31. 



Proceedings of ira Naiton/u. Conference on Environmeotal Hazards to the Skin 



380 



Figures 




QUAMOUS CELL 



Figure 1: 

Skin cancer accounts for approximately 2/3 of cancers in the 
U.S., although only 5% of these skin cancers are malignant 
melanoma. This group accounts for 75% of the deaths from 
skin cancer. 



t 


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8 10 12 

% OZONE LOSS 



Figure 3: 

Each 2% decrease in ozone projects to a 1 %-2% increase in 
worldwide melanoma mortality. 



3 0.001 




300 310 320 

WAVELENGTH (NM) 

I SURFACE UV H) TOTAL UV 



Figure 2: 

The most important protection the ozone layer provides 
from solar ultraviolet radiation occurs in the UVB (290 nm- 
320 nm) band. Shorter wavelengths of UV (UVC band) are 
almost fiiUy absorbed, while the larger UV (UVA band) are 
virtually unblocked. Because of this selective filtration in 
the UVB band, small changes in ozone concentration can 
lead to greater changes in ground UVB levels. 



Proceedincs of the National Confesence on ENvnoNMENTAL Hazards to the Skin 



381 



Atmospheric Effects on the Biology of the Skin 

Maigaret L. Kripke, Ph.D. 



Human activities associated with increasing industrialization 
and population growth over the last century have 
dramatically altered the atmosphere surrounding our planet 
These changes are modifying our immediate enviroiunent in 
significant ways. Specifically, decreases in the concentra- 
tion of stratospheric ozone are expected to increase the 
amount of UVB radiation in ambient sunlight; urbanization 
and industrialization are increasing the concentration of 
chemical pollutants in the air we breathe; and increases in 
CO, production may be increasing global temperatures and 
altering global climate by means of the greenhouse effect 
(Table I). Because skin is our primary interface with our 
environment, all hazards present in the environment as a 
result of these atmospheric changes have the potential to 
interact with the skin. This paper will focus on the effects 
of UV radiation on the skin because this is the area where 
we have the most information and where the most recent 
progress has been made. 

Ultraviolet Radiation 

The most thoroughly smdied environmental hazard to the 
skin is ultraviolet (UV) radiation. Wavelengths in the UVB 
(280 nm-320 nm) region of the solar spectrum are the most 
deleterious for human skin; they cause sunburn, skin cancer, 
and immimological alterations. These wavelengths are also 
the most strongly affected by ozone depletion. UVA (320 
nm-4(X) nm) radiation also has deleterious effects on human 
skin, including sunburn, photoallergic responses, changes 
associated with aging, and possibly skin cancer induction; 
however, it is much less efficient than UVB radiation, and 
its- presence in simlight is much less affected by the concen- 
tration of ozone. Solar UVC (200 nm-280 nm) radiation 
does not normally reach the surface of the earth because it is 
filtered out by ozone and moisture in the air. 

The deleterious effects of UVB radiation on human skin 
are well documented (Table 11). Decreases in the concentra- 
tion of stratospheric ozone are expected to increase the 
incidence of sunburns, accelerate changes in the skin 
associated with aging, increase the incidence of basal and 
squamous cell carcinomas, and decrease their age of onset. 
The incidence of cutaneous melanoma and its mortality rate 
are also expected to increase. UV radiation also alters the 
immune system and causes immune suppression under 
certain circumstances. However, the significance of these 
changes for human health is still unclear. 



Immunological Effects of UVB Radiation 

The most recently described and peihaps the most important 
effect of UVB radiadon on human skin is its ability to 
modify certain immune reactions. The immune system is 
the body's primary defense mechanism against infection 
and plays a role in resistance to certain cancers. Any factor 
that reduces immune function, whether external (radiation, 
toxic chemicals) or internal (stress) is potentially detrimen- 
tal for human health. 

Because the main immunological organs (spleen, 
thymus, and lymph nodes) are internal and are not directly 
exposed to UV radiation, the finding that UV radiation 
could suppress systemic immune responses was initially 
quite surprising. However, we now know that all effects of 
UV radiation on immune function described to date are 
mediated through the skin. 

The effects of UVB radiation on immune function are 
generally divided into two types: local and systemic. Local 
effects are defined as alterations in immune function to 
antigens introduced into the UV-radiated sites. The experi- 
mental model originally described by Streilein. Bergstresser 
and colleagues involves exposing mouse skin to four 
suberythemal doses of UVB and applying a contact sensitiz- 
ing chemical onto the site of irradiation. This results in a 
reduction of the CHS response and the appearance of 
antigen-specific suppressor T lymphocytes in the lymphoid 
organs. The suppressor cells prevent the subsequent 
irutiation of a CHS response at an unirradiated site. The 
mechanism of this effect of UVB radiation is still under 
investigation, but it seems to involve at least two compo- 
nents: an alteration in the function of antigen-presenting 
cells in the skin (called epidermal Langerhans cells), and the 
release of iimnunologically active molecules from UV- 
irradiated skin (TNF-a and perhaps CIS-urocanic acid). 
Note that although the effect is local, in the sense that the 
antigen must be applied to the site of irradiation, it results in 
systemic inunime suppression by virtue of the circulating T 
suppressor cells (Figure 1). 

A second local immunological alteration is illustrated 
by injecting melanoma cells and cells of other antigenic 
nmiors into UV-irradiated ear skin. This results in an 
enhanced outgrowth of the tumors and inhibition of tumor 
rejection in immunized mice. The mechanism of this effect 
is not known. 

Systemic immune suppression is defined as a reduction 
in immune responses initiated at non-irradiated sites. The 



Procodings of ihe Nauonal Confekence on ENVlRO^MBirAL Hazadis to ihe Sax 



382 



experimental models involve exposviig mice to UVB 
radiation and immunizing them by injecting an antigen 
subcutaneously. or painting a contaa sensitizing chemical 
on the skin at an unexposed site. Exposure to UVB radia- 
tion results in a reduction of the delayed hypersensitivity or 
CHS response and the induction of antigen-specific suppres- 
sor T lymphocytes. Recent evidence suggests that these 
effects of UV radiation are mediated by immunological 
mediators produced by keratinocytes in response to DNA 
damage (Figure 2). 

The relationship between local and systemic effects of 
UV irradiation is not clear, but it is possible that small doses 
of UV radiation bring about the local release of cytokines 
that alter immune function within the irradiated site. On the 
other hand, higher doses of or continued exposures to UV 
radiation cause the release of these and perhaps additional 
cytokines into the circulation, where they affect immune 
responses initiated at distant sites (Figure 3). Strategies for 
preventing these effects of UV irradiation include the use of 
substances that limit DNA damage (UVB sunscreens), 
increase DNA repair (DNA repair enzymes), inhibit the 
activity of specific immunosuppressive cytokines (anti-IL- 
10,-TNF-a, and CIS-UCA antibodies), or prevent cytokine 
release (Table m). 

Implications of UV-lnduced Immune Suppression for 
Humans 

Although most information on UV-induced immiuie 
alterations comes from studies of laboratory animals, 
studies on human subjects are increasing (Table fV). In 
general, these studies support the findings from animal 
models. For example, suberythemal doses of UVB radia- 
tion alter the appearance of epidermal Langethans cells in 
human skin. Recent studies by Streilein and by Cooper 
demonstrated that contact sensitization of UV-irradiated 
hiunan skin also results in a reduced CHS response, and that 
some individuals are unresponsive to resensitization, 
suggesting that suppressor cells may have been induced. 
The Streilein study suggested, in addition, that there are 
differences in individual susceptibility to UV-induced 
immiue suppression, and that such susceptibility may 
constitute an additional risk factor for the development of 
skin cancer. Importantly, skin pigmentation seems to have 
relatively little influence on susceptibility to UV-induced 
immune suppression, implying that the population at risk of 
immune suppression from UVB radiation is not hmited to 
the light-skiimed population that is susceptible to develop- 
ment of UV-induced skin cancers. Identification of the 
genetic factors associated with susceptibility to UV-induced 
immune suppression is obviously a priority. Recent studies 
by Streilein, et al., in the mouse model suggest that genes 
controlling the production of TNF-a and the response to 



bacterial toxins are key elements in determining susceptibili- 
ty to UV-induced immune suppression. 

Oth»' immune alterations associated with exposure of 
humans to UVB radiation include changes in the proportioa 
of white blood cells and decreased responsiveness of 
lymphocytes to stimulation in vitro. It should be noted that 
immune suppression by UVB radiation is selective, in that 
not all types of immune responses are affected. Delayed 
and contact hypersensitivity responses and resistance to skin 
tumors is impaired, but other responses such as antibody 
production and graft rejection do not appear to be altered. 

The most important question for human health raised by 
these studies is: E>o these UV-induced immunological 
alterations contribute in any significant way to the patho- 
genesis of infectious diseases? Unfortunately, no informa- 
tion is available on this question in humans. However, 
recent animal model studies of infectious diseases have 
demonstrated that under the appropriate conditions of UV 
irradiation and infection, acute exposure to UV radiation can 
inhibit the delayed hypersensitivity response to a variety of 
microorganisms, both locally (herpes simplex virus, Leish- 
mania) and systemically (Candida, mycobacteria). More 
importantly, UV irradiation has been shovra to cause mrae 
severe disease from herpes simplex virus, to activate HIV 
transcription in vitro and in vivo, to impair the clearance of 
mycobacteria, and to accelerate death from chronic infection 
with Mycobacterium lepraemurium (Table V). Because UV 
radiation appears to cause similar alterations in inuiune 
fimction in humans, it is important to investigate the 
potential of increased UVB radiation to magnify certain 
infectious disease processes. 

Implications for Ottier Atmospheric Hazards 

One of the most important impUcations of the effects of UV 
radiation on the immune system is the illustration of the 
intimate connection between the skin and the immune 
system. Skin serves not only as a barriCT to the extonal 
environment and a sensor for the central nervous system, 
but also as a sensor of the external envirormient ioc the 
immune systettL Thus, factors that directly affect the skin 
have the potential to affect not only the physiology of the 
skin itself, but the immune system as well. It is, therefore, 
possible that chemical pollutants in the air and in the 
workplace, paiticulariy those with the ability to cause DNA 
damage, may also cause immunological alterations by 
means of their interactions with the skin. 

How global warming will affect the structure and 
function of the skin can only be surmised at present Be- 
cause of the enormous adaptive ability of humans to survive 
in different climates, a few degrees' rise in global tempera- 
ture will probably not cause undue stress on the physiology 
of the skin. It has been reported, however, that a small 



PROCEEDINaS OF HIE NATIONAL CoNRRENCE ON ENVIRONMENTAL HAZARDS TO THE SkIN 



383 



increase in ambient lemperanire increases the rate of skin 
cancer prcxluction in a mouse nxxlel; the mechanism of this 
effect is unknown. More importantly, global warming is 
predicted to change the geographic distribution of certain 
infectious diseases. Changes in local conditions of rainfall, 
humidity, and temperature are expected to alter the distribu- 
tion pattern of infectious agents and disease vectors and to 
cause the migration of human populations. Such disrup- 
tions would probably be reflected in the appearance of 
cutaneous diseases not normally present in the immediate 
environment 

References 

1 . Cooper KD, Oberhelman L, Hamilton TA, et al. UV 
exposure reduces immunization rates and promotes 
toleraiK£ to epicutaneous antigens in human: relation- 
ship to dose, CDla-DR-i- epidermal macrophage 
induction, and Langerhans cell depletion. Proc Natl 
Acad Sci USA 1992;89:8497-8501. 

2. Cruz PD, Bergstresser PR. The low-dose model of 
UVB-induced immimosuppression. Photodermatol 
1988;5:151-161. 

3. DeFabo EC, Noonan FP. Mechanism of immune 
suppression by ultraviolet irradiation in vivo. I. Evi- 
deiKe for the existence of a unique photoreceptor in 
skin and its role in photoinmiunology. J Exp Med 
1993; 1 57:84. 

4. Jeevan A, Gilliam K, Heard H, et al. Effects of ultravio- 
let radiation on the pathogenesis of Mycobacterium 
lepraemurium infection in mice. Exp Dermatol 
1992;1:152-160. 



5. Jeevan A, Kripke ML. Impact of ozone depletion on 
immune function. Wori Resource Review 1993;S:141- 
155, 

6. Luger TA, Schwarz TS. Epidermal cell derived 
cytokines. In: Bos, JD, ed. Skin inunune system. 
Boca Raton: CRC Press, 1989:257. 

7. Kripke ML. Irrununological unresponsiveness induced 
by ultraviolet radiation. Immunological Reviews 
1984;80:87-102. 

8. Kripke ML. Effects of UV radiation on tumor immuni- 
ty. J NaU Cancer InsL 1990;82:1392-1396. 

9. Morison WL. Effects of ultraviolet radiation on the 
iitunune system in humans. Photochem Pholobiol 
1989,50:515-524. 

10. Ullrich SE. Mechanism involved in the systemic 
suppression of antigen-presenting cell function by UV 
irradiation. KeratitKx^yte-derived IL-IO modulates 
antigen-presenting cell fiinction of splenic adherent 
ceUs. J Immunol 1994;152:3410-3416. 

1 1 . Vermeer M, Streilein JW. Ultraviolet B light-induced 
alterations in epidermal Langerhans cells are mediated 
in part by tumor necrosis factor-alpha. Photodermatol 
Pholoimmunol Photomed 1990;7:258-265. 

12. Vermeer M, Schmieder GJ, Yoshikawa T, et al. Effects 
of ultraviolet B light on cutaneous irrunime responses of 
humans with deeply pigmented skirL J Invest Dermatol 
1991;97:729-734. 

13. Yoshikawa T, Rae V, Bruins-Slot W, et al. Susceptibili- 
ty to effects of UVB radiation on induction of contact 
hypersensitivity as a risk factor for skin cancer in 
humans. J Invest Dermatol 1990;95:530-536. 



Proceedings or the National CoNratENCx cn ENVOtONMENFAL Hazards id he Skin 



384 



Table I 

Sources of Atmospheric Hazards for Skin 

Event Consequence 

Ozone depletion UVB radiation 

Urbanization, industrialization Air pollution 

CO (Greenhouse Effect) Global warming 



Table III 




Strategies for Prevention 


Approach 


Methods 


Limit DNA Damage 


UVB Suncreens 


Increase DNA Repair 


DNA Repair Enzymes 


Inhibit Specific Cytokines 


Anti-IL-10, TNF, QS-UCA 


Prevent Cytokine Release 


Chemical Mediators (?) 



Table V 



Infectious Agents Influenced by UVB Irradiation 

(Murine IVIodels) 

Herpes Simplex Vims 

Leishmania Major 

Candida Albicans 

Mycobacterium Bovis (BCG) 

Mycobacterium Lepraemurium 

HIV, Maids Retrovirus 



Table II 
Harmful Effects of UVB Radiation on Human SMn 

Sunbum 

Aging 

Skin Cancer 

Immune Suppression 



Table IV 



Immune Alterations in Humans 

Altered Langeihans Cells 

Altered Antigen Presentation in Skin 

Decreased Contact Hypersensitivity Response 

Decreased Circulating T Lymphocytes 

Reduced Lymphocyte Function in Vitro 



PnXeBDBKS OF TOE NATIONAL CONFStENCC ON ENVnONMENTAL HAZARDS TO THE ShN 



385 



MODEL: IMMUNOLOGIC EFFECTS OF 
LOW-DOSE UVB 




T ANsradAn 



Figure 1 

Local suppression of contact hypersensitivity (CHS) by low- 
dose UVB-radiation. UVB exposure impairs the antigen-pre- 
senting function of epidermal Langerhans cells dJC). This could 
occur by means of direct DNA damage to the LC, which 
migrates to the draining lymph node (DLN); alternatively, or in 
addition, UV-induced cytokines or factors (e.g., cisurocanic 
acid) may alter the activity of LC. UVB radiation causes the 
release of inununonwdulatory cytokines, particularly TNF-a. 
DNA damage has been implicated as an initiator of this effect 
Application of a contact sensitizer to the UV-inadiated skin 
results in a decreased CHS response and induction of suppressor 
T lymphocytes. 



Antigen 



MODEL: UV • INDUCED SYSTEMIC IMMUNE 
SUPPRESSION 



ONAOwnag* 

i 
CytoWiM Ralaaa* 

i 
Irnmun* Systwn 

Suppnaaor C*ll 
Induction 




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Figure 2 

Systemic suppression of delayed or contact hyi)ersensitivity 
responses by UVB radiation. UVB radiation causes DNA 
damage and cytokine release in kertinobytes. Immunomodu- 
latory cytokines (e.g. IL-IO) shift the immune responses from 
an effector (T^) to a suppressor (T^) pathway in response to 
antigens introduced at non-irradiated sites. 



MODEL FOR UVB-INDUCED IMMUNE SUPPRESSION 


UV 












LOCAL 




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Model for UVB Induced Inmiunosuppression. Figure 3 pre- 
sents one possible model for how various factors and events 
operate in UVB induced immunosuppression. Inmiune re- 
sponses initiated or eUcited in UV-inadiated skin are influ- 
enced by alterations in cutaneous antigen presenting cells and 
cytokine production. With sufficient UV radiation, cytokines 
reach the circulation and later iimnune responses at distant 
sites. Cytokines released in response to UV shift the immune 
response from a TH, (delayed type hypersensitivity) response 
to a THj (antibody, DTH suppression) response. 



PtOCXEDDiaS (V TIE National CONRIIENCE ON ENVnONMENTAL HaZARIX TD THE SUN 



386 



Atmospheric Effects on the Epidemiology 
AND Incidence of Skin Cancer 

Arthur J. Sober, M.D. 



Dr. Paul Unna reported the observation of a relationship 
between exposure to sunlight and the occuirence of non- 
melanoma skin cancer (NMSC) in 1894. This relationship 
has been amply confinned since. Over the past 40 years 
there has been a remarkable increase in the incidence rates 
for both non-melanoma skin cancers (basal cell carcinoma 
and squamous cell carcinoma) and malignant melanoma. 
At the present time, approximately 700,000 NMSC and 
33,000 malignant melanomas are diagnosed annually. Both 
increases appear to relate to increases in occupational and/or 
recreational solar exposure. 

The anatomic distribution of the non-melanoma skin 
cancers fits a chronic sun exposure model, in that most of 
these tumors occur on areas of greatest sim exposure. 
Brodkin and Kopf demonstrated that approximately 90% of 
the basal cell carcinomas occur on the head and neck. From 
the SEER data of Scott, three out of four squamous cell 
carcinomas in males and three out of five squamous cell 
caiciix>mas in females occur on the head and neck. For 
lentigo maligna melanoma, as studied by Koh, et al., nearly 
all occur on the head and neck in chronically sun-exposed 
skin. While the distribution of melanoma overall does not 
fit the area of maximum sun exposure, nonetheless, areas 
that are chronically protected fiom sim exposure, such as the 
undeipants oc bra areas in females and the boxer shorts area 
in males, are less frequently affected. The differences in 
occurrence on male ear and scalp (increased compared to 
females) has also been related to solar exposure. Areas 
covered by bathing suits appear to be spared in both gen- 
ders, and the increased frequency of melanoma on the lower 
leg io women has been related to differences in clothing 
pattern compared to the male. The distribution of melano- 
mas in xeroderma pigmentosum, in which a defect in the 
repair of ultraviolet damage to DNA exists, shows a distri- 
bution of ntelanoma similar to those for melanoma patients 
in general. 

UV Dosimetry 

Ultraviolet B intensity varies with latitude. There is a 
strong latitude gradient in the United States for the inci- 
dence of squamous cell carcinoma, basal cell carcinoma and 
melanoma. The steepest of these latitude gradients is for 
squanKHis cell carcitK)ma and the least steep is for malignant 
melanoma. Hgures 1-4 show the latitude gradient existing 



for squamous cell carcinomas in men and women and for 
basal cell carcinoma in men and women. A direct relation- 
ship between the intensity of ultraviolet B in an area and die 
incidence of these two types of skin cancer has been shown. 
A similar but less steep gradient exists for maUgnant 
melanoma. Within the United States, a two and a half to 
three-fold difference exists in melanoma incidence rates 
between Massachusetts and southern Arizona. 

Effect Of Altitude 

UVB increases approximately 15% every 3000 meters of 
altimde. The dosimetric effect on humans can be seen in 
the study by Dr. Robin Marks in which the incidences of 
actinic keratoses were compared in Melbourne, Australia 
versus Maryborough, which are at similar latitudes but 
differing altitudes. The rate of occurrence of actinic 
keratoses in Maryborough was about 14% higher than 
Melbourne, reflecting die former's higher altitude. 

Effect of Cloud Cover 

Qouds can teduce the amount of ultraviolet B reaching the 
surface of the earth by both reflection and Ught scatter. 
Nonetheless, a good portion of ultraviolet B can traverse 
cloud cover, even on a cloudy, cool day, substantial 
amounts of UVB reach the earth's surface. 

Other Factors 

As important as the above relationships are, the percentage 
of population that falls into "at-risk" groups is crucial. 
Constitutional susceptibility plays a major role in determin- 
ing the rates of incidence of all three (orms of skin cancer at 
any given geographical location. For example: for non- 
melanoma skin cancers, the aimual incidence in black South 
Africans is reported as less than one per hundred thousand 
per year, whereas for white Australians with similar solar 
exposure, the rate is greater than 800 per hundred thousand 
per year. Similarly the rates for white Anglo-Saxon males 
in New Mexico was 485 per hundred thousand per year, for 
Hispanic males living in the same region, 64 per hundred 
thousand pa year for the years 1977-78. Equally important 
to constitutional factors is the behavior pattern of the 
population. Is the population outdoor-oriented, sun- 
seeking, or have educational and behavioral snodifications 
resulted in ultraviolet protection measures? 



PmcEHiiNas OF urn Nai»ul Conibibkz on Envkonmental Haz^uus to the Son 



387 



Effects of Ozone Depletion 

The effects of ozone depletion will result in increased 
ultraviolet B reaching the earth's surface and will thereby 
increase all skin cancers with etiologies related directly or 
indirectly to ultraviolet B. The Environmental Protection 
Agency (EPA), in October 1986, estunated that for each 1% 
depletion of ozone, the squamous cell carcinoma rate will 
increase 2% to 5%, and for each I % depletion of ozone, the 
basal cell carcinomas will increase 1% to 3%. The same 
1% decrease in ozone concentration is estimated to increase 
melanoma mortality by 0.8% to 1.5%. 

A recent paper by Moan and Dahlback reaffirms the 
inverse relationship between latitude and incidence rates of 
basal cell carcinoma and squamous cell carcinoma in 
Norway and for melanoma in Norway, Finland, and Swe- 
den. They estimate that for a 10% ozone reduction, a 16%- 
18% increase in squamous cell carcinoma rates will occur. 
This magnitude of ozone decrease would also be associated 
with a 19% increase in melanoma in males and a 32% 
increase in females. The EPA estimates that a 2.5% per 
year increase in chlorofluorocariwn (CFC) production will 
result in an additional one million skin cancers and 20,000 
additional deaths over the lifetime of the existing U.S. 
population. The EPA has also (xedicted that over the next 
SO years 12,000,000 additional cases of skin cancer, and 
210,000 skin cancer-related deaths in the United Stales will 
result from ozone depletion. 

These dire predictions assume the "at-risk" population 
will not change the amount of time spent out-of-doors nor 
change behavior in either active or passive ways. Active 
changes in behavior includes reduction of absolute outdoor 
time or reduction of exposure time during peak ultraviolet 
intensity (10:00 am to 3:(X) pm), the use of protective 
clMhing, and increases in application of sunblocks of high 
sun protection factor value. Passive responses include the 
increase in structural protection against ultraviolet exposure, 
such as planting shade trees, or the use of awnings or 
po^olas, or changing schedules of sporting events to avoid 
times of peak UVB. 

Prom this discussion, it is apparent that there are 
important carcinogenic consequences on the cutaneous 
human surface from increased amounts of ultraviolet 
exposure. However, most of these health problems for 
humans can be prevented by cunently available technology. 



References 

1 . Brodkin RH. Kopf AW, Andrade R. Basal-cell 
epitheUema and elastsois: A comparison of distribution. 
In Uibach F (ed): the biologic effects of ultraviolet 
radiation. Oxford, Pergamon Press 1989:581-618. 

2. Fitzpatrick TB, et al (eds). "Gearing Up" for the effects 
of high-intensity solar UVB. Dermatologic Capsule and 
Comment 1992;14:1-3 (March). 

3. Htzpatrick TB. Trends in dermatology: Ozone deple- 
tion and the dermatologist. Need we prepare for the 
consequences of a UVB "holocaust" in the next decade? 
Year Book of Dermatology. 1990. Chicago: Mosby- 
Year Book; 1990, xiii-xxii. 

4. Hoffman JS, Longstreth J. Ultraviolet radiation and 
tnelanoma with a special focus on assessing the risks of 
stratospheric ozone depletion. Washingtoii, D.C.: EPA 
400/1-87/OOlD December, 1987. 

5. Koh HK, Michalik E, Sober A), et al. Lentigo maligna 
melanoma has no better prognosis than other types of 
melanoma. J Clin Oncol 1985;2:994-1001. 

6. Marks R. Freckles, moles, melanoma and the ozone 
layer A tale of the relationship between humans and 
their environment Med J. Australia 1989;151:611-613. 

7. Moan J, Dahlback A. The relationship between skin 
cancers, solar radiation and ozone depletion. Br J 
Cancer 1992;65:916-921. 

8. Scotto J, Fears TR, Fraimieni Jr, JF. Incidence in 
noiunelanoma skin cancer in the United States. Publi- 
cation No. (NIK): 2-2433. ms, NIH. NCI, December, 
1981. 



(Note: Figures used in the currem manuscript were original- 
ly published in Scotto, et al. above and shown as Figures 
IS. 16, 17 and 18). 



PROCBDNB of 1W NaTUML CaNOBCB ON ENVBCMk«NTAL Hazahb td tw Skh 



388 



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Figure 1 

Annual age-specific incidence rates ( 1 97 1 -72 and 1 977-78) for 
squamous cell carcinoma of the skin among white males, 
according to annual UVB measurements at selected areas of 
the United States, with regression lines based on exponential 
models (from Scolto'). 



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Figure 2 

Annual age-specific incidence rates (1971-72 and 1977-78) 
for squamous cell carcinoma of the skin among white 
females, according to annual UVB measurements at selected 
areas of the United States with regression lines based on 
exponential models (from Scotto*). 












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HgureS 

Annual age-specific incidence rates (197 1 -72 and 1977-78) for 
carcinoma of the skin, basal cell only, among while males, 
according to annual UVB measutemoits at selected areas of 
die United States, with regression lines based on exponential 
models (from Scooo*). 



Figure 4 

Annual age-specific incidence rates ( 1 97 1 -72 and 1 977-78) for 
carcinoma of the skin, basal cell only, among white females, 
according to atuual UV-B measurements at selected areas of 
the United States, with regression lines based on exponential 
tiKxlels (from Scotto'). 



PnXX&XNQS OF THE NATIONAL CONRIIDICE ON ENVntONMENTAL HAZARDS TO THE SlON 



15 



389 



Prevention Against the Results 
of the lx)ss of atmospheric protection 

John H. Epstein, M.D. 



What can we do to prevent the damage that a reduction in 
atmospheric protection might cause to our collective skins 
due to lays from the sun? 

The primary rays that cause cutaneous injury fall in the 
ultraviolet region. In the early 1930s this region was 
divided arbitrarily into three spectra; UVC, which extends 
from either 100 or 200 nra to 280 nm; UVB, including rays 
between 280 and 315 nm, and the UVA spectrum, between 
315 and 400 nm. No rays shorter than 290 nm reach the 
earth from the sun, primarily because they are absorbed by 
ozone in the stratosphere. The UVB rays comprise the most 
effective damaging rays from the sun that do impinge on 
our skins.' The UVA rays also are responsible for injury.^ 
The atmosphere allows us to survive not only by supplying 
0, for us to breathe and COj for plants on which we live; it 
also absorbs UVC radiation that would destroy us and at 
least half of the UVB that arrives at our stratosphere. 
However it generally absorbs very little of the UVA radia- 
tion. At present calculations, no increased UVC will get 
through, and there is obviously no expected effect on UVA. 
However, increased amounts of UVB and shorter UVB will 
be expected to get through to us with a reduction in the 
ozone protection.^ This increase has been detected in 
Antartica during the time of ozone depletion.'' This in- 
creased UVB penetration has recently been recorded over 
North America.' Thus far, we are concerned with probabili- 
ties, rather than specific information on damage. Our 
primary concern is what could or perhaps is happening, 
when more UVB gets to us. Since this is a cutaneous 
problem-oriented symposium, this paper will review 
potential hazards to the skin and their prevention. 

Let us start a discussion of what UVB does to the skin. 
It is, of course, primarily responsible for the initial type of 
injury, the acute sunburn response. 

The damage that occurs extends well beyond the 
erythema and edema we see clinically. This includes 
inhibition of DNA, RNA and protein synthesis and mitoses 
formation, labilization of lysosomal membranes with release 
of and/or formation of inflammatory factors such as hydro- 
lytic enzymes, prostaglandins and the inlerleukins.' 

Cell death is prominent, resulting in the sloughing of 
dead cells that we know as post-sunbum "peeling". A more 
serious effect than cell death is mutation fonnation. With 
repeated acute injuries chronic photo-cutaneous damage and 
skin canca induction can occur.' 



Two positive aspects of UVB exposures are that (1) 
protection may be enhanced by new pigment formation; and 
(2) vitamin D synthesis is initiated in the epidermis. We 
should note that if the skin received enough UVB energy to 
induce new pigment formation, it has received enough to 
produce cell damage.'' 

The UVA rays can augment the acute phototoxic effects 
of the UVB rays.' In experimental animals they have been 
shown to augment the carcinogenic effects of UVB rays, 
and in large enough amounts, the UVA rays can induce skin 
cancers by themselves.' Thus, although a reduction in the 
ozone layer won't influence UVA penetration, the present 
amount of UVA could further augment the potential in- 
crease of UVB penetration. 

Certain people are at greater risk than others. These 
include patients with a lack or loss of pigment, such as those 
with occulocutaneous albinism and vitiligo, or people with a 
pigment dilution problem, such as patients with the 
Chediak-Higashi syndrome or phenylketonuria (PKU). 
Also at hsk are those with a defect in their DNA repair 
mechanisms, such as we see in patients with xeroderma 
pigmentosum. 

But the most common concern is found with light- 
complected people, especially those of Celtic origin. Their 
basic problem is that they sunburn easily. With repeated 
injuries they develop chronic actinic damage, actinic 
keratoses, and skin cancers. Such persons start with acute 
sunburn reaction, progress to the chronic leathery appear- 
ance with subsequent development of actinic purpura and 
stellate scarring, actinic keratoses, and ultimately skin 
cancer formation.' 

An increased amount of UVB would be expected to 
aggravate certain diseases such as the polymorphous light 
eruptions, lupus erythematosus, and certain infections such 
as herpes simplex, as well as, perhaps, to suppress the 
immune system. 

This leads next to prevention of the UVB induced 
damage. There are three main avenues of approach: (1) 
avoiding the noonday sua primarily between 10 am and 3 
pm or 4 pm, since the UV B rays drop off markedly towards 
the edges of the day because of the increased distance they 
must travel through the atmosphere; (2) wearing protective 
clothing; and (3) using potent sunscreens. 

Considering first the time of day, the edges of the day 
are safest Thus, sunrise and sunset are not only beautiful 



PtOCSDINaS OF THE NATIONAL CONnXENCE ON ENVnONkffiNTAL HAZARDS TO TOE SUN 



17 



390 



but from a UVB point of view are relatively safe. Of couise 
the night air is safe and will continue so, even with in- 
creased UVB penetration. Avoiding the midday sun can 
, reduce your UVB exposure by around 60%.' 

lliough the sun reaches more people at die edges of the 
day, you can tell by your shadow that the rays have farther 
to travel, which markedly reduces the amount of the shorter 
UVB rays reaching the earth. We should note that sunburn 
rays may reach us through a variety of circumstances, 
including reflection from appropriate surfaces, expostire at 
high altitudes and skylight distribution. 

The white sands of a beautiful beach are excellent 
reflectors of UVB rays but water is not The snow on a high 
mountain top is even more dangerous, because one is closer 
to the sun at such altitudes and the UVB reflection is also 
immense. Even hiding under a parasol or a shade tree will 
not exclude the sky light, which can contain a lot of UVB, 
especially in an equatorial location. 

It should be noted that, in general, water does not reflect 
much UVB radiation, and in the same vein, it does not 
protect Thus, we can get simbumed on an overcast day or 
when we are swimming with most of our bodies submerged 
under water. This may lead to a severe injury, because the 
water and the overcast sky teduce the heat and allow us to 
spend more time in the sun because of a lack of discomfort 
Mechanical protection is the mainstay in preventing UVB 
damage. This includes clothes, hair styles, sunscreens and 
sunblocks. 

The classic "cowboy look" shows a significant appreci- 
ation for sun protection. Wide-brimmed hats protect much 
of the face, as well as the scalp. Hats are also especially 
important to people with sparse hair covering, since the 
scalp is the site of greatest potential exposure. Wearing a 
wide-brimmed hat can reduce the UV radiation to die head 
and neck by about 70%.' Long-sleeved shirts are also of 
great value. A ti^tiy woven garment is much more 
effective than loosely woven material. New garments 
promise even greater protection than those already available. 
Actually appropriate clothing should teduce UV penetration 
by 100%.' 

Appropriate hair styles tnay provide significant protec- 
tion. The trend to long hair may be, dermatologically, a 
very wise preventive procedure. This brings us to sun- 
screens and sunblocks. These materials protect the viable 
cells of the skin against sun damage by absorbing or 
reflecting the injurious rays. Most sunscreens contain 
chemicals such as PABA, PABA esters, benzephenooes, 
cinnamates, salicylates and anthranilates, which are incorpo- 
rated into cream lotion or gel vehicles. The chemicals 
absorb the offending rays and prevent them from reaching 
skin cells. They can be appUed in invisible films that are 
cosmetically acceptable as well as effective. 



Sunblocks such as zinc oxide, titanium dioxide and iron 
oxide reflect and scatter the offending rays. Thus, a thick 
layer of ziiK oxide will <ct as a barrier against UV penetra- 
tion. Unfottimately, until recendy, for simblocks to be 
effective, they had to be applied in thick, cosmetically 
unacceptable coats. However, the development of micron- 
ized techniques has allowed the use of these sunblocks 
along with sunscreens to supply excellent cosmetically 
acceptable sim protection. The only effective sunscreen is a 
strong sunscreen. This refers to the concept of sun protec- 
tive factors or SPF. The SPF represents the amount of time 
or UVB energy that is required to produce a mild erythema 
with the sim.screen in place, divided by die time or amount 
of UVB energy requited to produce a mild sunburn without 
the sunscreen. Thus, if one bums mildly in 20 minutes, the 
use of a sunscreen with an SPF of 15 would prevent such 
mild burning for up to 3 hours. Since there is no advantage 
in getting damaged by the sun now versus in the fliture, 
when potentially we will be exposed to even more UVB 
radiation, everyone, even people with dark skin, should 
reduce their risk factors by using sunscreens with SPF 
values of 15 or more. A sunscreen with an SPF of 16 will 
reduce UVB radiation penetration to the skin by 94%.' 

In summary, die bottom line is that if — or peth^ 
'when' would be a better word — the increased UVB 
penetration of the atmosphere occurs due to ozone depletion 
in the stratosphere, protection will be even more necessary 
than it is now. The most important issue then will be the 
same one we are facing now: convincing people to protect 
themselves with the measures already available. 

Retarences 

1. Urbach F. Potential effects of altered ultraviolet radia- 
tion on human skin cancer. Ftiotocbem-Photobiol 
1989;50:507-513. 

2. Epstein JH. Non-melanoma skin cancer overview 
1992. Photomed-Photobiol 1992;14:49-56. 

3. Coldiron BM. Thinning of the ozone byer facts and 
consequences. J Am Acad Dermatol 1992',27:653-662. 

4. Farman JC, Gardiner BG, Shanklin JD. Large losses in 
total ozone in Antattica reveal seasonal c lOx/NOx 
interaction. Nature 1985315:207-210. 

5. Kor JB, McElroy CT. Evidence for large upward trends 
in ultraviolet-B radiation linked to ozone depletiott 
Science 1993;262:1032-1034. 

6. Epstein JH; Smith KC, ed. Pbotomedicine, die science 
of photobiology. 2nd ed Boca RaIon:CRC Press Inc., 
1988:155-192. 



hOC^DINQS CF n<E NATIOi' 



HUAUS TD HE Sdn 



391 



7. Urt>ach F, ed. Biological responses to ultraviolet-A 
radiation. Overland ParicValdenmar Publishing Co., 
1992. 

8. Epstein JH. Pbotocaicinogenesis, skin cancer and aging. 
In: Belin AR, Kligman AM, eds. Aging and the skin. 
New York; Raven Press, 1988:307-329. 

9. Marks R, Fraser P. Ozone depletion and human health: 
fact or fiction. In: Burgdorf WHC; Katz SI, eds. 
Dermatology: Progress and perspectives. The Proceed- 
ings of the 16th World Congress of Dermatology. New 
York: Parthenon Publishing Co., 1992:111-115. 



Proceedings cf the Nationai. CoraBRENCE cn Envdummektal Hazards to ihe Skin 



392 



Current Status of Nahonal Programs 
For Early Detec tion and Screening for Melanoma/Skin Cancer 

Howard K. Koh, M.D. 



The Conceptual Basis of Screening 

Not all cancers are amenable to screening. Screening is 
most effective when; 

1) The disease is highly prevalent and causes considerable 
moibidity and mortality; 

2) The natural history of the disease is known; 

3) Early treatment can prevent morbidity and mortahty; 
and 

4) An acceptable, safe, and inexpensive screening test 
exists.' 

By these criteria, many would contend that cutaneous 
melanoma has theoretical appeal for screening. The disease 
is increasingly prevalent, with death rates rising faster than 
any other cancer (except lung cancer). Compared to other 
types of cancer, the natural history of invasive melanoma is 
fairly well understood, and early treatment can prevent 
death. Melanomas can arise from a preexisting melanocytic 
nevus and the tumor is accessible. The screening examina- 
tion (a visual examination by a qualified observer) is safe, 
acceptable, takes several minutes and regarded by many as 
reliable in diagnostic situations. Finally, since some 
melanomas affect the back and posterior legs (which cannot 
be viewed easily by the person with the lesion), screening 
examinations could theoreticaUy improve detection of these 
lesions." 

In an attempt to stem the rising incidence of melanoma, 
the AAD began an annual free skin cancer screening and 
education program in 1985. In May of each year, local and 
national media pubUcize nsk factors and warning signs for 
skin cancer (particularly melanoma), and publicize the 
availabiUty of free screening clinics. Volunteer dermatolo- 
gists staff these screenings and provide examinations to 
those who attend. Since the program's inception, the 
number of peiwns screened has risen steadily. Through 
1993, about 6(X),0(X) Americans have been screened in this 
process. Millions more have learned about the warning 
signs of melanoma/skin cancer and received educational 
material by way of pamphlets, newspapers, or radio and 
television.* 

Skin cancer screening is unique because in addition to 
being a screening, it is an inherently educational process. 
The occasion allows the dermatologist to teach the screenee 
about the possible signs of cancer, especiaUy with respect to 
his or her moles. One of dermatology's challenges is to 



exploit the unique visibiUty of the skin and align education 
and screening to enhance early detection.' 

In the absence of formal skin cancer screening studies, 
examination and evaluation of the AAD program can yield 
critical iniial data. 

1) How does publicity affect mass screening? 

The AAD experience qualifies as "mass screening" a large 
segment of the pubUc. Once the organizers decide to target 
a large scattered population, methods used to inform this 
group are newspaper, radio, and television publicity. These 
methods have a variety of public health effects. In addition 
to promoting the screening itself, the publicity campaign 
may lead to some undetected constructive behavior, through 
both primary prevention (such as modification of sun 
exposure behavior) and early detection outside of mass 
screening (such as increased self examination of the skin or 
scheduling a visit to a personal physician for a skin exami- 
nation). As a result, AAD mass screening for melanoma is 
inextricably part of a larger cancer control effort that 
includes a pubUcity and pubUc education campaign.'-^ 

2) Which populations should be screened? 

In other cancers, such as cervical cancer, sometimes the 
inappropriate population, (i.e., people at low risk) show up 
for screening. To determine if a similar problem affected 
AAD skin cancer screening, those who attended screenings 
in Massachusetts in 1987 were surveyed to test the hypothe- 
sis that persons selecting themselves to be screened have a 
higher risk for skin cancer than the general population. 

Test data showed that the AAD program in Massachu- 
setts predominanUy attracted persons with risk factors (e.g., 
peiwnal or family history of melanoma, high numbers of 
moles, tendency to 'oum when exposed to the sun, or a 
history or severe or blistering sunburn) and with greater risk 
estimates for the screened, populauon when compared with 
controls. Fully 86% of those screened had at least one risk 
factor for melanoma, partly because 81% said they were 
sun-sensitive; 78% had at least two of the risk factors." 

Additional analysis found that the screening population 
was 98% white, about 66% women, and well-educated 
(51% had some college education). In addition, the 
scieenees' median age of 53 is similar to that of melanoma 
cases in the general U.S. population.' 

Targeting screening to high-risk persons should be the 



PiMXHiXNGS w ira National CoNiBiEWi ON Enviwxmeotal Hazawjs TO TOE S™ 



21 



393 



most efficieni form of cancer screening. Screening family 
members of melanoma patients may increase both the yield 
and predictive value of the screening test. Studies of family 
kindreds in the United States and Europe have shown that 
active surveillance resulted in the detection of disea<ie at an 
early, thin stage.^ ' However, since one of the primary goals 
of screening is to prevent death, the program should make 
special efforts to reach persons who are at risk for advanced 
diseases. New data demonstrate that melanoma mortality is 
rising fastest in older white men (over age 50), for reasons 
unclear.' Thus, until further data accrue, the AAD will 
begin to focus future screening and educational efforts on 
older white men as a strategy to prevent death firom melano- 
ma. Also, some preliminary data indicate that white 
persons of higher socioeconomic status (SES) are at risk for 
melanoma, but those of lower SES may be more likely to 
die of the disease.'" Hence white low SES populations may 
also be appropriate target groups. 

3) What is the yield of screening or how many confirmed 
sidn cancers are found? 

The AAD screening protocols contain no formal mechanism 
for following patients in these scattered populations to 
obtain the definitive diagnosis. Persons with suspected skin 
cancers are encouraged to consult their own physicians or 
dermatologists to undergo biopsy and appropriate treatment. 
In Massachusetts, comprehensive follow-up of people who 
have come into screening sessions has been ongoing since 
1986. For the period 1986-1989, the final diagnosis on 
about 85% of the 5644 persons who were screened was 
confirmed. In this group, 16 melanomas (of which 7 were 
in situ lesions), 176 nonmelanoma skin cancers and 75 
dysplastic nevi were confirmed. This is a yield of I mela- 
noma for every 352-627 persons screened (159/100,000 to 
284/100,000) depending on inclusion or exclusion of in situ 
lesions." Similar yields of melanoma have been reported 
from other screening programs. Skin cancer screening of 
2564 persons in the Netherlands found 10 confirmed 
melanomas (including 1 lentigo maligna), a yield of 1 
melanoma for 285 persons (excluding the lentigo maligna 
from analysis). Overall, these high yields depend on 
whether in situ lesions are included or excluded and repre- 
sent data from a prevalent screen; if people came back for 
repeat (incident) screening, the yield should drop. However, 
these data also supptAt the earlier conclusion that high-risk 
people are appropriately selecting themselves to be 
screened, thereby boosting the yield. 

We have also begun to document and analyze the 
pathoIogy<onfinned melanomas foimd nationally in AAD 
screening (Table I). In 1992-93, 195,660 persons were 
screened and 3285 of them (1.6%) has suspected melanoma. 
As a first attempt at foUow-up, we contacted these persons 



and their treating physicians by mail and telephone. We 
successfiilly contacted 97% of these persons and recieved 
complete pathology data for 72% of participants. Among 
257 persons with melanomas found in screening, more than 
98% were local (AJC Stage 1 and 2) lesions. Of the 253 
Stage 1 and 2 lesions, 45% were in situ. Of the 139 
invasive lesions, 62% were less than 0.76 mm thick and 
25% were between 0.76-1.50 mm. Only 7% of the lesions 
were equal to or greater than 1.51 mm thick- We compared 
screen-detected cases to the United States Surveillance, 
Epidemiology, and End Results (SEER) pcpulation-based 
cancer registry and noted trends suggesting fewer advanced 
cases in AAD screenees (8.6% AAD, 16.8% SEER, 
p<0.001).'' 

These results are preliminary. Without a formal control 
group, accurate projections about improved mortality are 
impossible. Furthermore, these data are subject U) bias. 
Screening may tend to detect the least aggressive tumors 
Oength bias). It is possible that some, or many, of the 43 in 
situ lesions would never have progressed to invasive cancer. 
Advancement of diagnosis through screening may not 
prevent death Oead time bias). In addition, individuals 
whose cases were detected through screening programs are 
self-selected and perhaps more health-conscious than the 
general population. As already mentioned, it remains to be 
seen if the.se programs can attract older men and persons 
with low SES (individuals both at risk for advanced disease 
and most likely to die firom their disease). In summary, we 
can say that most of the melanomas in AAD screening are 
thin Stage 1 lesions with high projected five year survival, 
but the impact of screening on mortality remains unknown. 

4) Can we prove that screening saves iives? Should 
melanoma/skin cancer screening be general health 
policy? 

Ultimately, it is critical to test in a rigorous fashion wbetbo' 
or not melanoma/skin cancer screening can save lives. At 
present, with AAD mass screening of scattered populations, 
there is no appropriate control group. Ideally, decreased 
mortality in a randomized controlled trial needs to be 
demonstrated, as was done in the Health Insurance Plan of 
New York (HIP) study of mammography and physical 
examination for breast cancer. (This randomized study 
showed a consistent decline in mortality after long follow- 
up for those who were screened and received 
mammography as opposed to those who did not.) Another 
alternative may be studies to demonstrate decreasing 
nK>rtality rates after '.videspread initiation of screening 
practices, such as with cervical cancer and pap smear in 
Scandinavia and Iceland. Fmally, once skin cancer screen- 
ing becomes more prevalent, case-control studies might be 
\yoTth investigating further.''* 



Procqdings of the Naixinai CnNFERENCE ON Envikonmektal Hazards to the Sun 



394 



While skin cancer screening has theoretical appeal, little 
data and no definitive evidence exist that screening saves 
lives. It should be emphasized that the AAD program 
rqnesents only one type of screening - episodic mass 
screening by dermatologists on self-selected individuals. 
Ultimately, screening as part of a routine physical examina- 
tion by the primary care provider (case-finding) may be the 
most comprehensive way to decrease melanoma mortality.- 
Opportunities to improve case-finding exist, since Massa- 
chusetts data indicate that most persons with newly diag- 
nosed melanoma have a physician and see that physician in 
the year prior to diagnosis. However, there is no clear 
consensus as to whether skin cancer screening should 
routinely be incorporated into the physical examination. 

In light of diis, should skin cancer be general pubhc 
health policy? Presently, the major public health poUcy 
organizations differ in their recommendations. The Ameri- 
can Academy of Dermatology and American Cancer 
Society support general skin cancer screenings, while the 
UlCC Project on Evaluation of Screening for Cancer does 
not However, the U.S. Preventive Services Task Force and 
others recommend screening for specific high-risk groups. 
Targeted screening, self-screening, screening at work sites 
and health fairs are other strategies that have to be properly 
investigated.' 

Conclusion 

Over the next few decades, screening and education for 
melanoma/skin cancer will receive increasing worldwide 
attention. The unique visible aspects of skin cancer enhance 
the potential of combining screening and education for 
melanoma control. Theoretically, appeal for screening 
exists but no specific evidence shows at the present time 
that it is effective. We need more data and information to 
prove definitively that these efforts improve early detection 
and save lives. 

Acknowledgement 

This study was suppcsted in part by grant SK07-CA 01380- 
04 from the National Institutes of Health. 



References 

1 . Miller AB, ed Screening for cancer. Orlando: Academ- 
ic Press, 1985. 

2. Koh HK, Lew RA, Prout MN. Screening for melanoma/ 
skin cancer theoretic and practical considerations. J Am 
AcadDeimatol 1989;20:159-175. 

3. Koh HK. Cutaneous melanoma. N Engl J Med 
1991;325:171-182. 

4. Koh HK, Norton LA, Geller AC, et al. Confirmed 
melanomas found in national skin cancer screening. 
Submitted, Cancer, 1994. 

5. Koh HK, Geller AC, Miller Dr, et al. Early detection of 
melanoma: an ounce of prevention may be a ton of 
work. J Am Acad Dermatol 1993;28:645-647. 

6. Koh HK. GeUer AC, Miller DR, et al. Who is being 
screened for melanoma/skin cancer? Characteristics of 
persons screened in Massachusetts. J Am Acad 
Dermatol 1991;24:271-277. 

7. Masii GD, Qark WH, Jr., Guerry D, IV, et al. Screen- 
ing and surveillance of patients at high risk for malig- 
nant melanoma results in detection of earUer disease. J 
Am Acad Dermatol 1990;22:1042-1048. 

8. Vasen HFA, Bergman W, VanHaerlingen A, et al. The 
famiUal dysplastic nevus syndrome; natural history and 
the impact of screening on prognosis. A study of nine 
famihes in the Netherlands. Eur J Cancer Clin Oncol 
1989,25:337-341. 

9. Geller AC, Koh HK, Miller DR, et al. Death rates of 
maUgnant melanoma among white men in the United 
States, 1973-1988. MMWR 41:20-27. 

10. Geller AC, Miller DR, Lew RA, et al. Mahgnant 
melanoma. Another cancer that disproportionately 
affects the socioeconomically disadvantaged. In Press, 
American Journal of Public Health, 1994. 

1 1 . Koh HK, GeUer AC, Miller DR et al. Evaluation of 
melanoma/skin cancer screening in Massachusetts 
1986-1989. American Public Health Association. New 
York: 1990. Abstract 



PtOCECDIHOS OF HIE NATIONAL CONIBIDKE ON ENVntONMEOTAL HaZAKDS TO THE SlON 



TaUtI 



395 



stage and tliicknen o1 melanomas found in AAD screening (1992-1993) 
compared to those recorded In SEER Registries (1990) 





AAOSatening 


SEER Cases 




•(»)• 


(K*r 




257 


3050 


LOCAL 


253(98.4) 


2864(93.9) 


In situ 


114(45.0)" 


851 (29.7)' 


Invasive 


139(55.0)»» 


2013(70.3)' 


<0.76njm 


84 


928 


0.76-1^ mm 


34 


375 


1.51-3.99 mm»" 


15 


245 


4.00 muH-*** 


3 


83 


Unknown 


3 


382 



DISTANT AND REGIONAL** 



4 (1.6) 



186 (6.1) 



* Percentages by stage and thickness are computed among cases of known status (unknowns excluded) 
** Percent of local disease 
*** Advanced cases less common in AAD screening (22/257) {8.6%) than in SEER (514/3050) ( 16.8%) (p=0.001, chi- 
square) 



Pucamos or iw Naioul Ccnobci oh EmrnxqwiiLlttiABX to he Skw 



396 



Ultraviolet Effects on Human Immune Responses 

Kevin D. Cooper, M.D., Lois Oberfielman, Gordon LeVee, Ph.D., Ole Baadsgaaid, M.D., 
Thomas Anderson, M.D., and Hillei Koren, Ph.D. 



Introduction into the environment of compounds that have 
now been found to catalyze the destruction of stratospboic 
ozone has resulted in ozone depletion in the stratosphere of 
not only the Antarctic, but now also the Arx^tic. Ozone 
depletion is now distinctly measurable over populated areas 
in both the Southern and Northern Hemispheres. Combined 
with human societal/behavioral trends, humans have been, 
and will continue to be, exposed to significant and increas- 
ing flux densities of UV radiation, in particular UVB. 
However, as yet it has not been possible to extrapolate from 
murine studies the impact of increased UVB radiation on 
immune suppression, nor to quantitate to what degree 
immune suppression results in altered infectious disease 
patterns, vaccine effectiveness, photoaging, or even skin 
cancer incideiKe.' Furthermore, it is not clear how much of 
our population is at risk. Are pigmented segments of the 
population protected against UV-induced irtmiunosuppres- 
sion or not? Do sunscreens really protect against irtmiune 
suppression as well as they do against sunburn erythema? 
A quantitative assessment of dose effects of UV irradiance 
on human immune reactivity is needed to begin to address 
these issues. Toward that end, we have utilized a human 
bioassay in which normal volunteers are exposed to UV 
radiation at the immunization site with a potent immuno- 
gen, (dinitrochlorobenzene, DNCB).' Groups of subjects 
with Types I-III skin (fair-moderately fair skin) who re- 
ceived varying doses or schedules of UV radiation from a 
bank of 1^20 fluorescent sunlamps (rich in UVB), were 
compared in their ability to mount an ittunune response to 
DNCB following the irrununization.^ The investigators 
found a linear UV-dose-responsive inhibition of immime 
responsiveness, with a detectable decrease first occurring at 
0.75 of the individual's minimal erythemal dose (MED) and 
reaching complete inhibition of responsiveness for 95% of 
subjects if 2 MED was administered every day for four days 
prior to itimumization. Similar inhibition occurred if 
sensitization to DNCB was administered through skin that 
received a single 4 MED exposure three days prior. The 
effect did not carry to a distant site; that is, immunization 
with another, unrelated iramunogen (diphencyclopropenone, 
DPCP) at a site distant from the sunburn was essentially 
unaffected by the UV exposure. There was no distant 
irtununosuppression even if total body exposure to 4 doses 
of either 0.75 MED or 1.5 MED were administered prior to 
sensitization (the DPCP sensitization site and the elicitation 
sites were protected prior to sensitization). Approximately 



25-30% of the subjects receiving etythemagenic doses of UV 
were tendered tolerant (long term active unresponsiveness) to 
die DNCB; that is, even if the DNCB was provided as 
subsequent immunization through skin that had not been 
UVB-exposed, these subjects could no longer be inmiunized 
to DNCB, indicating an active effect on the itrunune systenL 
The degree of irrmitmosuppression correlated with both the 
degree of Langerhans cell depletion that occurs after UVB 
and die occurrence of macrophage infiltration in the sun- 
burned site.'-" 

These data indicate that hunuins are inmiunosuppressed 
at highly relevant levels of UV exposures commonly 
encountered by the population. They also indicate that the 
immunosuppression is not likely to result in immunosup- 
pression of responses to agents etKounteted in other organ 
systems or distant sites. Of interest is that in a similar type 
of assay, subjects with a past history of skin cancer were all 
found to be the most susceptible to UV-induced immuno- 
suppression.'*" Furthermore, immunosuppression by UVB 
was not limited to fair skinned subjects, indicating that 
tanned Caucasians, as well as more deeply pigmented 
subjects, are contained within the "at risk" population.'" To 
determine if the UV doses resulting in inunune suppression 
in humans might be sufficient to increase the risk of certain 
adverse health effects in humans, extrapolations from 
murine data will be needed. Comparison of the relation- 
ships between human and murine dose response curves for 
suppression of contact sensitivity can be performed with 
currently available data." The relationship to other disease 
processes, such as tumor susceptibiUly or infectious disease 
alteration, may also be able to be determined, but careful 
attention to dose response relationships, Ught sources, and 
die relevance of the murine models must be givea"'" 

References 

1. DeFabo EC. Noonan FP. Urocanic acid, 
photoimmunology and ozone depletion: Hiunan health 
imphcations. In: Holick MF, Kligman AM, eds. 
Biological effects of light Walter de Gruyter & Co.. 
1992: 387-396 

2. Cooper KD. Oberhehnan L. HamUton TA, et al. UV 
exposure reduces immunization rates and promotes 
tolerance to epicutaneous antigens in hunums: Relation- 
ship to dose, CDla-DR-t- epidermal macrophage 
induction, and Langerhans cell depletioiL Proc Natl 
Acad Sci USA 1992;89:8497-8501. 



PnOCSDINGS OF THE NaTIOKAL GjNFESElCE ON ENVlKONMENrAL HAZARDS TO THE SlON 



25 



397 



3. Towes GB, Bergsticsser PR, Streilein JW, et al. Epider- 
msi Langertians cell density determines whether contact 
hypersensitivity or unresponsiveness follows skin 
painting with DNFB. J Immunol 1980;124:445^53. 

4. Aberer G, Schuler G, StingI G, et al. Ultraviolet light 
depletes surface markers of Langeihans cells. J Invest 
Dermatol 1981,76:202-210. 

5. Cooper KD, Fox P, Neises G, et al. Effects of ultravio- 
let radiation on human epidermal cell alloantigen 
presentation: Initial depression of Langerhans cell- 
dependent function is followed by the appearance of 
T6-Dr-f cells that enhance epidermal alloantigen 
presentation. J Immunol 1985;134:129-137. 

6. Scheibner A, HolUs DE, McCarthy WH, et al. Effects 
of sunlight exposure on Langerhans cells and melano- 
cytes in iuiman epklennis. Pbotodennatol 1986;3:15- 
25. 

7. Tjemlund U, Juhlin L. Effect of UV-inadiation on 
immunological and histochemical markers of Langer- 
hans cells in normal appearing skin of psoriatic patients. 
Arch Dermatol Res 1982;272:171-176. 

8. Czemielewski JM, Masouye I, Pisaoi A, et al. Effect of 
chronic sun exposure on human Langerhans cell 
densities. Photodermatol 1988;5:116-120. 

9. GUchrest BA. Soter NA, Stoff JS. et al. The human 
sunburn reaction: Histologic and biochemical studies. J 
Am Acad Dermatol 1981;5:411-422. 

10. Vermeer M. Schmieder GJ, Yoshikawa T, et al. Effects 
of ultraviolet B light on cutaneous immune responses of 
humans with deeply pigmented skin. J Invest Dermatol 
1991;97:729-734. 

11. Cooper KD, Neises GR, Katz SI. Antigen-presenting 
OKMS-t- melanophages appear in human epidermis after 
ultraviolet radiation. J Invest Demiatol 1986:86:363- 
370. 

12. Cooper KD, Duraiswamy N, Hammerberg C, et al. 
Neutrophils, differentiated macrophages, and monocyte/ 
macrophage antigen presenting ceUs infiltrate miuine 
epidermis after UV injury. J Invest Dermatol 
1993;101:155-163. 

13. Baadsgaaid O, Fox DA, Cooper KD. Human epidermal 
cells from ultraviolet light-exposed skin preferentially 
activate autoreactive CD4+2H4+ suppressor-inducer 
lymphocytes and CD8-t- suppressor/cytotoxic lympho- 
cytes. J Immunol 1988;140:1738-1744. 



14. Schmieder GJ, Yoshikawa T. Mata SM. el al. Cumula- 
tive sunlight exposure and the risk of developing skin 
cancer in Florida. J Dermatol Surg Oncol 1992;18:517- 
522. 

15. Yoshikawa T, Rae V, Brtiins-Slot W, et al. Susceptibili- 
ty to effects of UVB radiation on induction of contact 
hypersensitivity as a risk factor for skin cancer in 
humans. J Invest Dermatol 1990;95:530-536. 

16. Noonan FP, De Fabo EC. Ultraviolet-B dose-response 
curves for local and systemic immunosuppression are 
identical. Photochem Pbotobiol 1990;52:801-810. 

17. Ansel JC, Mountz J, Steinberg AD, et al. Effects of UV 
radiation on autoimmune strains of mice: Increased 
mortality and accelerated autoimmunity in BXSB male 
mice. J Invest Dermatol 1985;85:181-186. 

1 8. Giaiuiini SH, DeFabo EC. Abrogation of skin lesions in 
cutaneous leishmaniasis. In: Hart DT. ed. 
Leishmaniasis: The first centenary (I885-I985) New 
Strategies for Control. NATO ASI Series A: Life 
Sciences. London: Plenum Publishing Co., 1987. 

19. Jeevan A, Gilliam K, Heard H, et al. Effects of ultravio- 
let radiation on the pathogenesis of mycobacterium 
lepraemurium infection in mice. Exp Dermatol 
1992;1:152-160. 

20. Jeevan A, Evans R, Brown EL, et al. Effect of local 
ultraviolet irradiation on infections of mice with 
Candida albicans, Mycobacterium bovis BCG. and 
Schistosoma mansoni. J Invest Dermatol 1992;99:59- 
64. 

21. Noonan FP, DeFabo EC, Kripke ML. Suppression of 
contact hypersensitivity by UV radiation and its rela- 
tionship to UV-induced suppression of tumor immuni- 
ty. Photochem Photobiol 1981;34:683-689. 

22. Bumham DK, Mak CK, Webster RJ, et al. Relationship 
between inducible H-2 expression and the immunoge- 
nicity of murine skin neoplasms. I. Evidence that the 
immunogenicity of ultraviolet radiation<hemically 
induced tumors is associated with their susceptibility to 
gamma-interferon-mediated enhancement of H-2Kk 
expression. Transplantation 1989;47:533-542. 

23. Howie SE, Norval M, Maingay JP. Alterations in 
epidermal handling of HSV-I antigens in vitro induced 
by in vivo exposure to UV-B UghL Immunology 
1986;57:225-230. 



PitocEEDiNas OF TOE Nauonal CanftBKE ON Envbonmektal HuMias TO TOE Shn 



Ozone Deplction, Increased UVB Intensity, and Skin Damage 

Thomas B. Rcq)atrick, MX>., Ph.D. 



It is a truism that when considering a potentially deleterious 
environmental change, one should anticipate the worst case, 
and prepare for it Ozone depletion has already occurred in 
the Antarctica and would continue in the future, even if 
CFC production were stopped today; the 100-year half-life 
of chlorine in the stratosphere means the problem of in- 
creased UVB intensity will be around for another century. 

Historical Considerations 

For over past two decades many in govenunent (U.S. 
Congress, the executive branch, the EPA) and in science 
and medicine (photobiologists and photodermatologists) 
yawned when the question was raised: would ozone deple- 
tion result in increased UVB intensity on the earth's surface 
and lead to harmful human effects, especially increased 
incidence of melanoma and iKMimelanoma sidn cancer? 
Two decades ago, the comnxHiest types of the serious folal 
skin cancer (superficial spreading and nodular melanoma) 
were not believed to be related to sun exposure. This 
disbeUef in the role of solar UVR in the etiology of tnelano- 
ma has now been turned around as a result of extensive 
epidemiological studies, most specifically the large case- 
control studies in Australia. The prevailing belief now is 
that melanoma of the skin is, in part, caused by sim expo- 
sure in certain populations at risk. 

Future Outlook 

The EPA now predicts 12 millioa more sldn cancers and 
210,000 additional skin-cancer deaths in the U.S. during the 
next 50 years. In 1991, the UN Environment Program 
released a report containing two dire predicticms: (1) I.7S 
million additional cases of cataracts by the year 2000 if the 
ozone layer diminishes another 10% by the end of the 
decade and (2) a worldwide skin cancer rate increase of 26% 
by the year 2000 if the earth's ozone layer continues to be 
depleted at current rates. 

Therefore, we must now prepare the population for 
itxscased UVB intensity. While this will be important for 
aU latitudes, it is especially a problem in high latitudes 
whoE cooler sutmner temperatures prevail at midday, when 
UVB intensity is highest With cool tempciatures, people 
are recreating or working outside during the midday. It 
must be remembered that UVB exposure, unlike heat, does 
not provoke any immediaie warning signs; the exposure 
cxpaiena is silent, surreptitious, and the skin reactioas 
(sunburn) are delayed for IS to 20 hours later. Those higb- 
lisk persons wiD be facing the prospect, in 10 to 20 yean, of 



suimner UVB intensities in heavily populated northern cities 
of the same magnitude as summer UVB intensities that in 
1992 prevailed in Tucson, Arizona. But people in Tucson 
generally avoid the midday summer sun, because of the 
intense heat; in the northern latitudes the population elects to 
recreate in midday sun. In the words of Noel Cowanl: 

Al twelve noon the natives swoon 

Ami no further work is done 

But mad dogs and Englishmen 

Co out in the midday sun. 

This ominous combination of cool temperatures and 
high intensity UVB now prevails in certain parts of Borneo; 
Caucasians who live there develop solar keratoses before 
puberty! Solar keratoses can be regarded as a biological 
dosimeter for cumulative UVB damage. 

The skin is the major human surface to be attacked, and 
dermatologists and researchers in collalxnation with indus- 
try need now to explore every possible method of helping 
high-risk UVR-induced skin cancer-prone patients protect 
against the development of disfiguring epitheUal cancers 
and fatal malignant melanomas. 

The major skin cancers (basal cell and squamous cell 
carcinomas and maUgnant melanoma) have diverse etiolo- 
gies. However, the evidence for sunUght as a major etiolo- 
gy for nonmelanoma skin cancer (NMSC) is unequivocal. 
NMSC has the highest itKidence in a high-risk population 
of white skiimed people with inability to tan (Skin 
Phototypes I and II) and occurs much more fiequently in 
outdoor workers such as telephone Unemen, sailors, farmers, 
ranchers, and in older persons who have been exposed to 
Sim for many years. A good example would be golfers who 
spend months in Florida in the winter and then sununer in 
northern latitudes. The sites of NMSC (exposed areas of the 
head and neck, dorsiun of the forearms and hands) also are 
strong evidence that simUght is a major cause. 

Melanoma EUology 

Primary malignant melanoma of the skin has varied 
expressions and some types seem to have little or no 
relation to exposure to sunlight, such as malignant 
melanoma arising in congenital nevome