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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"

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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  observational  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  changes  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  0  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) 


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43 


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46 


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47 


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48 


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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  Singer.  PrvD..  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  siyports  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  misrquesentatlons,  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 
estaWidwd  die  U^.  Weadier  Satellite  Service,  served  as  its  first  director,  and  leo^ved  a  Gold 
Medal  award  from  die  VS.  D^artment  of  Oommeree  for  this  c<MUribntion. 

Eaily  in  my  career  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 
icasMuanoe  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  cxisteaoe  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 
rhlorifK  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  Almospherie  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  conggencc  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,  deaeases  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|polhaion. 
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  prtpjicd  (w  ilie  sjrnipasjum  drdiraifd  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. 

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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? 
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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. 

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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 
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1994. 

36.  USEPA  (U.S.  Environmental  Protection  Agency).  Protection 
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assessment  of  the  risks  of  stratospheric  modification. 
Washington.  DC:  (January)  1987:  chap.  7.  quoted  in  Benedick. 
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planet.  Cambridge:  Harvard  University  Press:  1991:  21. 


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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 
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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.HRmroN 

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. 

0    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  fipiing  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  cities  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  detades  of 
several  other  completely  unreactive  gases,  one  lighter  than  air  (neon)  and  some  heavier  than 

14 


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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. 


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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, 

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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  created  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 
lafrllirc  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  stratospheric 

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 


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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 


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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 —liiinii  [■'■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  iAifHMMtMiiUeio*eazo«6Hieplati«guMtK— ilnbgrrepbce.  Tbe  perflaomaied  compoaadi.  sooie 
<rf  wbitfc  a»  beiae  iwiidterBd  a»  iriiiii—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 

CwM*de»aB— af  a»«<^  rhuiff  wMbeaae  ifffgy  iyr^h^  ia  aailiiilMiaiufciate  rhMff  Tbe 
e»ieMofo«rabaiQrio«iii—r  aaycawmettoriyioapeaficcaBKt  will  Ifltety  prove  w  be  importaaKJeatific 
■p«tiod8CMiowirt,BiaitpBedK»edbBMa»-««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 

fiwiat.fcibaiaMiaflararr  ii  rrfrnriin  rnnriaar  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 

^^....^^^^^^^ 

0 

^^^^ 

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 
anthropogenic  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. 


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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  ■ 


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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 


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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! 


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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 


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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 


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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 


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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  1986  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 

0 

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, 
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enue Code,  CEi  relies  entirely  on  donations  from  corporations,  foundations,  and 
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For  more  information  contact 

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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      0  -  $32. 1 

•  Domestic  refrigeration  —  $  4.0  -  $  8.0 

•  Commercial  refrigeration  —  $  3.0  -  $  5.4 

•  Chillers  —  $  4.4.$5  0 

•  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 0  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 0  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 0  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 0  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. 


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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  0  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 
0 
2 
0 
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 


TECHNOLOGY:  Journal  of  The  Franklin  Institute 
The  170th  year  of  Publication 


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Director 

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US.  Department  of  Agriculture 
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324 


Board  of  Directors 

Frederick  Seitz,  Chairrnan, 
Rockfffelhf  University 

Bruce  N.  Ames, 

University  0l  CaStoma 

at  Berkeley 

Willia  M.  Hawkins. 
Lockheed  Corporation  (ret.) 


John  H.  Moore, 
George  Mason  University 

William  Nierenberg, 

Scripps  Institution  of 

Oceanography 

Chauncey  Starr, 
Electric  Power 
Research  Institute 


Science  Advisory  Board 

Sallte  Baliunas,  Chaiirrian. 
Harvard-Smithsonian 
Center  lor  Astrophysics 

Hugh  W.  Ellsaesser , 

Lawrence  Uvermore 

National  Laboratory  (ret.) 

Jerry  Grey. 

American  Institute  ol 

Aeronautics  S  Astronautics 

JohnMoCanhy. 
Stanlord  University 

Kenneth  G.  McKay. 
ATiT/Bel  Lalxraiories  (ret.) 

Henry  I.  Miller, 
Stanford  University 

Robert  Sproull. 
University  of  fiochester 

Kenneth  M.  Waison. 
San  Diego  Marine 
Physics  Laboratory 

Lowell  Wood. 
Larwrance  Livermore 
Nafioiial  Laboratory 


Executive  Director 

Jeffrey  Salmon 


Tel,    (202)296-9655 

Fax.    (202)296-9714 

E-Mail    71553.3017@ 
Compuserve.COM 


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  Synyosium.  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  puiatylntellactMalmpyetition 
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  peip«tt»toi»  in  these  cases  felt 
tliemsetves  under  InMnM  pieiiuw  to  compete 
for  scarce  rMouroas,  evon  by  cheating  if  neces- 
sary. As  the  pwaauw  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  aaaembta -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^- 
difiite  an  intense  campaBnon  lui  acanoe  resowoes 
such  as  n jsaitli  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 
refieietJ  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  referees 
perform  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  researchers  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  Btotechnotogy  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  wimliig  !■  wmtmm  (vMok  cannvt  b*  dMitad),  It  dmivti  mora  aawniy  wty*  of  nwMi« 
4HitiMittatlv»  opinion  poMlo  than  tfwt  fcfcwid  at  lart  wook'*  maatli^  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  lwtoi**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  funding,  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  sci- 

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 
hsatX  b«»—  chanaln«  social  aWtudaa 
maka    mora    dHfafanea    than    ilalfcUnf 


others,  iodudine  the  chairmar^  of  the 
f*'^  f l-^bai  wanningjMll  hf^'""*  '*"  i'"- 

•'^"•inri  f"*"  «  VTV*^"  TP'"sr  tpaterial- 
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 
contfact  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  confcieiice  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  cijufetence  and  meant  to  advise  spon- 
sors, as  well  as  governments.  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  mcmbfcti,  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'  —  ihiunaehfcs 
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 
oojtttctatioo  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,  onf  of  whose 

BTTIfY  lj°*)^  ^  to  obtain  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  Ciinii  Wu»»,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  Scptrmhw  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  iiwtannrs  in  wbkb  faer  leseaidi  was  insgipnpdatefy 
imhthitt^    Oa  October  19,  she  reqwnded  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  cnmpsny. 


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  0  (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 


Board  of  Diroctors 

r>Mend(  S«<D.  Chwnwi, 
Roditltlhr  Unvfstf 

BnjcaN.  AmM. 

Univtttiiy  ol  CathmiM 

UBtrktIey 

Willis  M  Hawtani. 
Lockheed  Cotportaon  (rtt.J 


John  H.  Moors. 
G90rg»Uascn  Unvarsir/ 

William  NterontMrg. 

Saipiis  InsiluSon  of 

OcMitosnfhf 

Chauncay  Sorr. 
Electric  Pow9f 
Rnetnh  Insoiule 


Sclanc*  Advisory  Board 

Satti«  BaliunAS.  Chaimian, 
Hanard-  Stnihsonan 
Center  toe  Aslrtjphysica 

Hugh  W.  Etsaessw. 

Lawf9nc0  Uvetmofe 

National  Laboranty  (ret) 

J«fry  Grey. 

American  Insvtute  ol 

Aeronautics  A  Astronautics 

JohnMoCwthy. 
Stanford  Unhwaitf 

Ksnrwih  G.  McKay. 
A  Ti  T/8eU  Laboraioriea  (rat.) 

Henry  I.  Miller. 
Stanford  University 

Rotiert  Sproull, 
University  of  f^ochester 

Kennech  M.  Walaon. 
San  Diego  Marine 
Pfyysics  Laboratory 

LcwellWood. 
Lawrence  Livermote 
Nationat  Laboratory 


Executive  Director 

Jeffrey  5aJiTx)n 


Tel.    (202)296-9655 

Fax.     (202)296-9714 

E-Mail     71553.3017@ 
Compuserve.COM 


GEORGE   C.   MARSHALL   INSTITUTE 
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  Amwkii'^ 


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, 
(fiacaaetoarfaidiq^,  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, 
uiiMuaat  and  mvestigtfi<Hi  of  the  UV  dose  relation- 
shq»  in  animal  models  and  determination  of  die  influ- 
lOBe  at  other  paeameteis  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 
wfctocent  aevos  count  studies. 

7.  AanfiMBCHt  of  the  role  of  UV  inununosuppression  in 
»Bd*nt«Mi  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  ocCTplioaal  skia  diieaae  have  been 
slowly  inrwfijMing;  agdcakoral  and  mauufacluriug  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. 


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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 


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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. 


0  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 


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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 


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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 


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Atmospheric  Hazards  to  the  Skin 


Proceedings  of  toe  Nationai,  CoNraxENCE  on  Environmental  Hazards  to  the  Skin 


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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 


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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. 


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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 

^^ 

o 

j^fl^^^^^^^^^^^B 

£ 

.^^^^^^^^^^^^^^^H 

S20 

.i^fl^^^^^^HP 

Si 

.^^^^^^^^^^^    ■ 

0 

^—\- i 1 1 \ 1 1 1 1 

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 


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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 


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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 


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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 


c;  c  c: 


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 

OtSTANT] 

ENVIRONMEffT 

SITES 

crrOKMES   - 

UNA  »■      (iwri 

<i-io) 

OlMc 

mamm 

•■ 

1 
t 

LC,  Aarad  intlgK 
prvMntatlon 

krflanimnoy  cda 

AKartd  mtlgMi 
prannutlon 

1                                                1 

®^X(^ 

T                          T 

Rgure3 

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. 


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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? 


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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). 


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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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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'). 


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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 


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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. 


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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  Detection  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 
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induction,  and  Langerhans  cell  depletioiL  Proc  Natl 
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397 


3.  Towes  GB,  Bergsticsser  PR,  Streilein  JW,  et  al.  Epider- 
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hypersensitivity  or  unresponsiveness  follows  skin 
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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  nevomelanocytic 
nevi;  acrolentiginous  melanoma,  which  occurs  on 
unexposed  areas  (feet  and  hands)  and  which  is  also 
most  common  in  populations  with  brown  and  black 
skin. 


FtecmaKB  or  nc  NAmuL  Cuauucx  on  ENvnoNOKrAL  Hazaids  to  nc  Sxw 


399 


Therefore,  a  cursory  view  of  the  causation  of  melanoma 
would  suggest  that  primaiy  melanoma  has  little  to  do  with 
sunlight  exposure  except  for  lentigo  meligna  melanoma, 
which  all  agree  Is  similar  to  NMSC  with  respect  to  a  sun- 
induced  etiology.  Some  major  ai^guments  against  the  solar 
cause  of  melanoma  are: 

1)  Primary  melanoma  of  the  skin  of  white  persons  has  the 
highest  incidence  in  young  and  middle-aged  persons 
(primarily  malignant  melanoma  is  the  second  most 
prevalent  mahgnancy  of  males  age  30-49). 

2)  The  site  of  origin  is  not  on  the  most  exposed  areas 
(bead  and  neck)  but  on  the  upper  back  and  on  the  legs 
of  females. 

3)'    Melanoma  in  whites  is  seen  not  in  outdoor  workers  but 
in  indoor  professionals  who,  in  fact  have  only  week- 
end, albeit  often  intense,  exposures. 
Nevertheless,  five  special  committees  of  the  National 
Academy  of  Sciences  over  a  period  of  6  years  (1976-1982) 
carefully  exatiuned  the  role  of  sunlight  in  maUgnant  mela- 
noma and  concluded  that  UVR  is  unequivocally  a  major 
etiologic  factor  in  NMSC.  and  the  UVR  may  play  a  role  in 
the  development  of  some  maligiuuil  melanomas  of  white 
persons.  The  EPA  sponsored  a  complete  two  year  study  by 
a  committee  of  statisticians  and  epidematologists  corvcen- 
trating  on  the  role  of  sunlight  in  the  etiology  of  malignant 
melanoma  and  concluded  that  solar  radiation  does  play  a 
role  in  the  development  of  malignant  melanoma  of  the  skin 
in  whites. 

Two  major  factors  cited  in  this  EPA  committee  report 
were; 

1)  The  rising  incidence  of  melanomas  with  changes  in 
patterns  of  exposure,  particularly  with  respect  to 
increasing,  intermittent,  intense  sun  exposure  of  certain 
anatomic  sites.  Consistent  with  this  fact  is  an  increased 
incidence  in  higher  socioeconomic  classes  (profession- 
als) and  in  indoor  workers.  The  dramatic  increase  in  the 
incidence  of  malignant  melanoma  in  the  skin  of  whites 
in  the  last  two  decades  (more  than  600%)  is  explained 
by  changes  in  hfestyle  —  afHuence.  shorter  work  week, 
more  leisure  time  and  more  trips  to  the  beach,  more  sim 
exposure  in  winter  in  the  suimy  parts  of  the  world,  and  a 
striking  emphasis  on  outdoor  sports  activities. 

2)  The  data  repotting  that  individuals  who  move  to  sunny 
dimates  (Australia,  California,  Israel)  have  higher  rates 
of  melanoma  than  those  who  i^emain  in  their  country  of 
origin.  This  is  particularly  accentuated  in  individuals 
arriving  at  or  just  before  the  age  of  puberty  ( 10  to  14 
years).  A  recent  large  study  from  Australia  has  revealed 
that  in  deaths  from  melanoma  among  immigrants  to 
Australia  compared  to  Australian-bom  residents  by 
region  of  birth,  the  highest  mortality  was  for  persons 


bom  in  Australia,  next  England,  and  then  Ireland/ 
Scotland/Wales.  These  groups  are  largely  a  population 
with  Skin  Phototypes  I  and  C.  Mortality  was  lowest  in 
people  from  Central  and  Eastern  Europe  and  from 
Western  and  Eastern  Asia,  populations  with  Skin 
Phototypes  III.  IV,  and  V. 

Looking  at  the  ozone  depletion-increased  UVB  deleteri- 
ous effects  on  the  global  biosphere,  indirect  effects  on 
humans  include  UVB  damage  to:   (1 )  zooplankton,  which 
are  important  in  the  aquatic  food  chain,  critically  affecting 
the  supply  of  fish  for  human  consumption:  and  (2)  phy- 
toplankton.  which  fix  carbon  dioxide.  If  this  reservoir  were 
reduced  there  would  be  an  increase  in  global  warming  by 
the  "greenhouse"  effect 

Of  more  immediate  interest  are  the  direct  effects  on 
humans,  which  are  dose-dependent  cumulative  and  irre- 
versible causing:  (1)  increased  incidence  of  skin  cancers  of 
melanocytes  and  keratinocytes;  (2)  damage  to  the  eye. 
leading  to  age-related  nearsightedness,  deformation  of  the 
lens  capsule  and  nuclear  cataracts;  and  (3)  damage  to  T- 
lymphocytes,  thus  reducing  defenses  against  infections 
(such  as  herpes  simplex  or  cutaneous  leishmaniasis). 

Recommendation: 

The  dermatologist  is  the  primary  physician  for  the  manage- 
ment of  the  patient  with  skin  cancer,  and  for  this  reason, 
needs  to  be  involved  in  the  ozone  depletion  problem  on  a 
national  and  international  level. 

Reference 

Fitzpatrick  TB.  Trends  in  dermatology:  Ozone  deple- 
tion and  the  dermatologist:  need  we  prepare  for  the 
consequences  of  a  UVB  "holocaust"  in  the  next  c&cade? 
Year  Book  of  Dermatology.  Chicago:  Mosby-Year 
Book  1990:  xiii-xxii. 


ftoaaxKB  OF  nffi  Nauqnal  CoraaiBKE  on  ENvntomofr/U.  Hazards  to  iw  Son 


400 


Naturally  Occurring  Hazards 
TO  THE  Skin 


PliOC£EDO«SS  OF  THE  NATIONAL  CONFEKENCE  ON  EnVIRONMEOTAL  HaZARES  TO  IKE  SKIN 


401 

Dilemmas  and  Opportunities  to  Prevent 
Poison  Ivy,  Oak,  and  Sumac  Dermatitis 

William  L.  Epstein,  M.D. 


Poison  ivy  and  poison  oak.  together,  represent  the  single 
most  common  cause  of  itchy  allergic  skin  reactions  in  the 
United  States,  and  they  are  biologically  inseparable.'-^  If 
you  are  allergic  to  one,  you  will  certainly  react  to  the  other. 
Approximately  half  the  adult  population  in  the  United  States 
is  clinically  sensitive  to  poison  ivy/oak.  This  means  that 
half  the  population  will  get  a  rash  if  they  have  contact  with 
poison  ivy/oak  leaves.  Another  35%  are  subclinically 
sensitive;  if  they  come  into  contact  indiscriminately  and/or 
have  a  heavy  exposure,  they  will  get  a  rash.  This  leaves 
only  10-15%  who  are  truly  immune,  either  by  early  expo- 
sure to  the  allergen  or  a  tolerogen  or  by  some  genetic 
happenstance.   Poison  ivy/oak  dermatitis  is,  perhaps,  the 
most  important  clinically  relevant  skin  disease  that  can  be 
unambiguously  and  completely  related  to  the  environment 
Furthermore,  it  is  a  uniquely  North  American  affliction. 

Although  weeds,  plants  and  trees  containing  similar  and 
cross-reacting  allergens  exist  in  other  parts  of  the  world, 
(especially  South  America  and  Asia),  these  plants  are  either 
not  so  ubiquitous  as  poison  ivy/oak,  and/or  their  chemicals 
are  not  so  allergenic  for  humans,  so  that  relatively  few 
people  in  the  rest  of  the  world  are  naturally  sensitized  by 
exposure  to  the  uiushiol  oil.  For  example,  the  weeds  did 
not  grow  naturally  in  Europe  until  they  were  transplanted 
there,  around  the  time  of  World  War  II.  Now  the  plants  are 
slowly  spreading  across  Europe.  On  the  other  hand,  poison 
ivy-sensitive  travelers  from  the  United  States  can  develop 
surreptitious  eruptions  after  exposure  to  urushiol-containing 
exotic  plants,  trees  and  foliage  and  artifacts  tnade  from 
them. 

Despite  minimal  governmental  support  over  the  years, 
much  has  been  learned  about  the  plants,  the  offending 
chemicals  (urushiol)  and  the  inmiunological  response  of 
humans  to  these  obnoxious  weeds.  Botanists  inform  us  that 
in  spite  of  being  widely  distributed  in  nature,  these  plants 
are  very  selective  in  their  growth  habits.  Also,  there  is  no 
such  thing  as  a  "generic"  poison  oak  or  poison  ivy  leaf. 
One  catmot  rely  on  the  old  saying  "leaves  three,  leave  it  be". 
Often  leaves  occur  in  fives,  sevens,  nines,  etc.  and  their 
shapes  are  distinctive  only  for  the  region  where  they  grow. 
If  the  plants  are  transported  to  other  habitats,  they  will  grow 
in  different  forms.  Thus,  poison  ivy  tends  to  develop  as  a 
vine  crawling  up  trees  and  poles  to  reach  the  sim,  whereas 
poison  oak  has  the  propensity  to  form  a  shrub  or  small  tree. 


sometimes  with  limbs  suitable  for  carving  a  gavel  or  spear. 
In  another  environment,  however,  poison  oak  becomes  a 
crawling  vine  and  presimiably  poison  ivy  would  form  a 
shrub  in  the  desert  Another  biological  problem  is  that  the 
allergenic  chemical  (urushiol)  is  a  light,  colorless  oil  that 
courses  throughout  the  veins  just  under  the  surface  or 
epicarp  of  the  weeds.  It  runs  through  all  levels,  from  the 
roots  to  the  tips  of  the  fruit  and  the  leaves,  much  like  the 
lymphatic  system  in  humans.   Although  the  urushiol  oil 
recedes  ftxjm  the  leaves  in  autumn,  when  they  dry  up  before 
falling  olT,  it  flows  back  into  the  stalk  and  roots.  As  a 
result,  the  stark  formless  sticks  are  booby  traps  for 
outdoorsmen  in  the  dead  of  winter.  The  good  news  is  that 
their  growth  patterns  are  more  limited  than  omnipresent 
For  instance,  they  do  not  grow  above  4000  feet  so  the 
Rockies  and  Sierras  are  safe  havens.  They  also  do  not 
naturally  grow  in  rainforests,  in  hot  humid  climates  such  as 
Hawaii,  nor  in  Alaska,  and  they  abhor  the  desert  unless  it 
rains.  They  do  grow  luxuriously  in  temperate  climates 
where  it  is  hot  and  wet  in  the  simmier.  along  lakes  and 
streams  in  the  Midwest  Northeast  and  Southeast  and  the 
seashores  on  the  East  and  West  The  country  is  permeated 
with  these  bothersome  weeds  in  the  very  places  where  most 
of  the  populace  goes  to  vacation. 

An  equally  large  corpus  of  knowledge  is  available  about 
the  chemistry  of  urushiols,  so  that  one  could  easily  invent 
strategies  to  prevent  or  interdict  their  actions  on  human 
skin.  However,  as  is  the  case  with  the  HTV  virus,  extensive 
knowledge  has  not  led  to  clinical  solutions.  We  know  that 
urushiols  are  a  group  of  catechols,  with  a  long  carbon  side 
chain  at  ring  position  3,  ranging  from  c-13  (characteristic  of 
poison  sumac)  to  c-15  (characteristic  of  poison  ivy)  to  c-17 
(characteristic  of  poison  oak).  The  differences  among  the 
catfaechols  are  in  the  saturation  of  the  side  chain,  which 
ranges  from  fully  saturated  Oeast  antigenic)  to  3  unsaturated 
bonds,  with  the  dience  being  the  most  antigeiuc.  These  side 
chains  determine  specificity  of  the  response  and  die  carbons 
at  ring  positions  4,  5  aixl  6  determine  protein  bonding  and 
whether  the  chemical  will  be  a  sensitizer  or  a  tolerizer.  If 
the  carbon  positions  4  and  S  are  available  for  protein 
binding,  they  will  preferentially  attack  amino  bonds  on 
proteins  and  act  as  sensitizers.  However,  if  the  sixth  ring 
position  is  available,  it  will  preferentially  bind  to  cysteine 
moieties  on  proteins  and  cause  tolerance  or  non-reactivity.' 


PWXXQXNOS  OF  1HE  NaTKIUL  CoHltMUUCE  ON  ENVnONMENTAL  HaZAUS  TD  THE  SkW 


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Potentially,  this  chemical  infonnation  could  be  useful  in 
devising  tolerizing  compounds  to  prevent  people  from 
becoming  sensitized  to  the  weeds. 

As  indicated  above,  approximately  one-I'alf  of  the  250 
million-plus  pc^Hilation  of  the  United  States  is  clinically 
sensitive,  and  more  Aan  two-thirds  could  react,  so  a  major 
need  exists  for  effective  treatments  and/or  preventive 
measures.  Approximately  10%,  or  somewhere  between  15 
and  25  million  people,  are  so  sensitive  that  they  require 
treatment  by  deimatologists,  usually  injection  or  ingestion 
of  large  doses  of  corticosteroids.  This  treatment  is  palliative 
and  generally  results  in  healing  over  a  10  to  14  day  poiod, 
but  the  annoyance  and  disability  is  staggering.  Nearly  1% 
of  Workman's  Compensation  in  the  state  of  California  is 
spent  in  the  care  of  poison  oak  dermatitis.  Although  avoid- 
ance is  the  best  preventive,  it  is  seldom  practical,  especially 
in  the  industrial  setting  of  outdoor  workers,  so  that  other 
approaches  must  be  sought  Despite  the  immense  amount 
of  knowledge  available  about  the  botany,  biology,  immu- 
nology, and  chemistry,  the  govenunent  has  provided  very 
little  fmancial  support  for  prevention  or  adfxpialp  treatment 
of  the  disease.  To  date,  pharmaceutical  manufacturers  of 
corticosteroids,  the  main  systemic  treatment  for  severe 
poison  ivy/oak  dermatitis,  have  been  the  major  contributors 
to  our  citizens'  health.  In  recent  years  methods  of  preven- 
tion have  become  piqmlar,  particularly  with  outdoor  work- 
ers. Some  effective  barrier  creams  have  been  developed  but 
these  catiK  strictly  at  the  behest  of  industry,  not  in  the 
public  good.  The  FDA  is  required  by  law  to  investigate  the 
safety  and  efficacy  of  all  preventive  preparations  that  would 
be  applied  to  the  skin  with  the  aim  of  preventing  poison  ivy/ 
oak  dermatitis.  This  ruling  has  blocked  a  number  of  useful 
compounds  £rom  the  market,  and  some  of  these  are  sold 
ttirough  industrial  supply  houses  without  any  claims  other 
than  skin  protection.  This  could  be  changed  by  a  specific 
edict,  making  development  of  siKh  topical  agents  an 
exception  to  the  law.  Considering  the  enormity  of  die 
problem  and  the  recognized  safety  of  these  chemicals,  some 
of  which  are  used  in  cosmetics,  our  society  would  be  well 
served,  bt  addition,  govenunent  agencies  such  as  the 
Department  of  Agriculture  should  contract  with  the  clothing 
industry  to  develop  light,  poison  ivy/oak  retardant  clothes 
for  use  by  firefighters  and  other  outdoor  workers  at  high  risk 
for  exposure  to  these  weeds. 

Other  af^xoaches  being  carried  out  without  government 
support  include:  ( 1 )  the  development  of  chemicals  that 
could  act  as  tolergens;'  and  (2)  strategies  to  take  advantage 
of  the  more  recent  observation  that  when  people  are  hy- 
posensitized  by  ingestion  of  the  imishiol  oil,  they  actually 
produce  an  immunoglobulin  that  seems  to  block  the  T  cell 
receptor.*  With  this  information,  it  shoukl  be  possible  to 
develop  a  "vaccine"  that  might,  temporarily  or  for  long 


periods  of  time,  prevent  people  from  getting  the  rash. 

In  plain  words,  it  is  abimdantly  clear  that  the  potential 
to  prevent  or  interdict  poison  ivy/oak  dermatitis  is  near  at 
hand,  because  we  have  erKxigh  basic  information.  What  we 
need,  however,  is  the  financial  and  administrative  support  of 
appropriate  goverrmiental  agencies  to  make  this  a  reality  for 
the  large  number  of  American  citizens,  including  teenagers, 
outdoor  workers  and  enthusiasts  atxl  othos  who  suffer  the 
scourge  of  poison  oak  and  poison  ivy. 

ReferencBs 

1.  Epstein  WL.  Poison  oak  and  poison  ivy  domatitis.  In: 
Adams  RM,  ed.  Occupational  skin  disease.  2nd  ed, 
Philadelphia:  WB  Saunders  Co.,  1990:536-542. 

2.  Epstein  WL.  Occupational  poison  ivy/oak  dermatitis. 
Dermatologic  Clinics.  In  press. 

3.  Dunn  IS,  Castagnoh  N,  Byers  VS.  Influence  of  chemi- 
cal reactivity  of  uiushiol  type  haptens  on  sensitization 
and  induction  of  tolerance.  Cell  Immimol  1986;97:189- 
1%. 

4.  Stampf  JL,  Castagnoli  N,  Epstein  WL,  et  al.  Suppres- 
sion of  uroshiol-induced  delayed-type  hypersensitivity 
responses  in  mice  with  serum  IgG  inuniux)globulin 
from  human  hyposensitized  donors.  J  Invest  Dermatol 
1990;95:363-365. 


nucEsaNos  CF  IKE  Nauonm  i^nmma  an  ENvnoracNTAi.  Hazahs  to  im  San 


403 


The  Effects  of  Sunught  on  the  Young  and  Elderly 

Robert  S.  Stem,  M.D. 


Other  presenters  at  this  symposium  have  discussed  the 
adverse  effects  of  sun  exposure,  including  nonmelanoma 
skin  cancer  (basal  cell  and  squamous  cell  cancer)  (NMSC). 
photodamage,  and  melanoma.'  Strong  evidence  exists  that 
increased  exposure  to  the  sun  increases  the  likelihood  or 
extent  of  NMSC  and  photodamage."  Both  NMSC  and 
photodamage  are  most  often  manifested  in  older  persons. 
Photodamage  is  defined  as  wrinkling,  irregular  pigmenta- 
tion and,  perhaps  most  importantly  from  a  societal  perspec- 
tive, changes  in  the  actual  function  of  skin,  including 
increased  peimeabihty,  decreased  abihty  to  withstand 
trauma,  and  diminished  capacity  to  heal.  The  role  of 
childhood  exposures  to  the  sun  in  causing  these  changes  is 
probably  substantial.  A  variety  of  alterations  in  immune 
fimctions,  both  in  the  skin  and  systemically,  appear  to  be 
mediated  by  exposure  to  sunlight''  The  clinical  consequenc- 
es of  these  alterations  in  humans  remains  controversial. 

Risks  and  Benefits  of  Light  Exposure 

In  considering  the  consequences  of  sun  exposiue  in  the 
young  and  elderly,  it  is  important  to  remember  that  sun 
exposure  is  associated  with  benefits  as  well  as  risks.  Many 
individuals  feel  good  when  they  are  exposed  to  the  sim. 
The  warm  glow  one  gets  at  the  beach  is  largely  a  conse- 
quence of  infrared  radiation.  Exposure  to  fiill  spectrum 
visible  light  may  also  have  a  salutary  effect  on  mood. 
Completely  separating  exposure  to  that  part  of  the  solar 
spectrum  that  is  beneficial  or  pleasurable  from  that  which  is 
harmfijl  is  difficult,  if  not  impossible.  Further,  the  relative 
risks  and  benefits  vary  between  individuals  and  with  age.  In 
addition,  we  need  to  remember  that  certain  effects  of  the  sun 
(i.e.,  tanning)  that  dermatologists  may  devalue  are,  in  fact,  a 
source  of  pleasure  to  many.  In  older  age  groups,  exposure 
to  the  ultraviolet  radiation  from  the  sun  may  be  an  important 
source  of  vitamin  D,  critical  to  propo'  calciimi  metabolism.' 
Even  if  dermatologists  beUeve  that  tanning  is  not  desirable, 
we  should  not  discoimt  that  which  makes  people  happy  and 
is  not  socially  destructive  or  tremeiHlously  risky.  Tte  value 
of  other  persons'  pleasures  cannot  be  dismissed  merely 
because  dermatologists  disapprove. 

The  risks  of  sun  exposure  are  modified  by  a  patient's 
health  and  medication  use.  Exposure  to  certain  photosensi- 
tizing drugs  or  chemicals  increases  the  risk  of  both  acute 
and  chronic  adverse  effects  of  the  sun.  Not  only  does  the 
use  and,  hence,  risk  of  potentially  photosensitizing  chemi- 
cals vary  with  age,  but  the  health  consequences  of  such 
reactions  may  be  especially  important  in  the  young  or 


elderiy.  Also,  strategies  to  limit  the  adverse  effects  of  stin 
exposure  may  have  different  impact  on  the  quality  of  daily 
life  in  the  young  and  elderly. 

Oeariy,  the  cost  of  either  treating  or  preventing  adverse 
effects  of  sun  exposure  vary  with  age.  The  cost  of  avoiding 
or  reversing  adverse  effects  of  sun  exposure  are  also  likely 
to  vary  with  age,  and  are  especially  important  to  the  young 
and  elderly.  The  special  importance  of  sun  exposure  in 
youth  and  the  older  age  groups  is  related  to  quantitative 
differences  in  exposure,  to  qualitative  differences  in  effect 
per  unit  of  exposure  and,  particulariy  for  older  persons,  to 
past  exposures. 

One  reason  sun  exposiue  in  childhooj  and  older  age  is 
so  important,  compared  to  other  stages  of  life,  is  the  amount 
of  time  available  for  exposure  to  the  sun  during  these 
periods,  especially  compared  to  the  middle  years.  In  a 
temperate  industrial  society  such  as  ours,  the  number  of 
days  available  of  exposure  per  year  is  far  higher  in  child- 
hood and  after  retirement  than  during  working  life.  During 
childhood  an  individual  spends  an  average  of  about  three 
times  as  much  time  in  the  sun  per  year  compared  to  middle 
age.'  The  adverse  effects  of  greater  exposure  per  year 
during  childhood  than  adult  life  may,  in  fact,  exceed  this 
simple  quantitative  difference  in  exposure  level. 

Sun  Exposure  and  SItin  IMalignancies 

The  exact  relationship  between  total  or  omiulative  sun 
exposive  and  the  risk  of  melanoma  is  not  yet  clear.  Expo- 
sure to  sunlight  in  childhood  appears  to  be  an  especially 
important  determinant  of  the  risk  of  melanoma.  Homan' 
found  diat  individuals  migrating  to  AustraUa  before  puberty 
had  a  risk  of  melanoma  comparable  to  native  Australians, 
whereas  those  who  migrated  after  age  18  maintained  the  far 
lower  risks  of  lifelong  residents  of  their  native  northern 
countries.  At  least  two  other  findings  suggest  that  child- 
hood sun  exposure  patterns  may  be  particulariy  important 
determinants  of  lifelong  melanoma  risk.  An  association 
between  multiple  painful  simbums  in  childhood  and  a 
higher  risk  of  melanoma  has  been  reported.'  An  association 
between  the  amoiml  of  sun  exposure  diuing  childhood  and 
the  number  of  nevi  that  develop  has  been  established'  A 
greater  number  of  nevi  is  a  risk  factor  for  melanoma. '° 
For  nonmelanoma  skin  cancer,  epidemiologic  data 
suggest  ttiat  the  risk  increases  exponentially  with  increased 
total  exposiue  to  UVB.'  Doubling  exposure  iixneases  risk 
about  four-fold.  Therefore,  a  halving  of  childhood  exposure 
would  result  in  a  more  than  50%  decrease  in  lifetime  risk.' 


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There  is  also  a  delay  or  latency  period  betwerai  exposure 
and  the  development  of  skin  canes.  Therefore,  reducing 
exposure  in  childhood  reduces  lifetime  risk  and  increases 
the  age  of  onset  among  those  who  develop  a  tumor.  The 
impact  of  a  skin  tumor  in  a  young  peison  is  likely  to  be 
greater  than  the  impact  in  an  older  or  elderiy  individual  with 
respect  to  cost,  disfigurement,  and  years  of  life  lost 
Nonmelanoma  skin  cancers  that  develop  in  younger  persons 
may  also  be  more  aggressive  than  those  seen  in  older 
persons." 

Classic  tbeoies  of  carcinogenesis  suggest  tfiere  are  two 
important  steps  in  cancer  development,  initiation  and 
promotion."  UltraWolet  &xjm  sunlight  may  be  bodJ  an 
initiator  and  a  promoter.    As  a  result,  exposure  in  older 
individuals  might  be  especially  important  in  promoting  the 
final  development  of  nonmelanoma  skin  cancer  in  individu- 
als with  substantial  prior  exposure  to  the  sua  In  this  way, 
sun  exposure  in  the  elderiy  may  be  especially  important  in 
tumor  formation.  We  know  that  persons  with  a  prior  history 
of  nonmelanoma  skin  cancer  in  a  sunny  climate  are  about 
50%  more  likely  to  develop  an  additional  tumor  than  are 
persons  living  in  a  less  sunny  area  of  die  United  States." 
Premalignant  lesions  known  as  actinic  keratoses  may 
regress  in  winter  and  appear  to  be  more  likely  to  progress 
when  exposed  to  the  sun.    This  clinical  observation  sup- 
ports the  possibihty  of  an  especially  important  role  for 
exposure  late  in  life  on  the  development  of  nonmelanoma 
skin  cancer  in  those  with  substantial  exposure  to  ultraviolet 
radiation  (or  other  carcinogens)  eariy  in  life.  More  recently, 
an  Australian  study  of  persons  with  actinic  keratoses 
demonstrated  that  regular  use  of  sunscreen  over  one  sununer 
decreased  the  rate  of  formation  of  actinic  keratoses." 
Therefore,  sunscreen  use  may  decrease  the  risk  of  squamous 
cell  cancer  in  persons  who  have  or  are  at  high  risk  for  the 
development  of  [xemalignant  actinic  keratoses.  These  are 
most  often  the  middle-aged  or  elderiy." 

Dr.  Margaret  Kripke  pointed  out  the  immune  effects  of 
sunlight  and  their  possible  adverse  consequences.  In  mice, 
young  animals  seem  especially  susceptible  to  developing 
iiiunune  alterations,  leaving  them  at  higher  risk  of  skin 
cancer  as  a  consequence  of  ultraviolet  exposure  eariy  in 
life.*  Whether  these  observations  in  animals  are  relevant  to 
humans  is  not  yet  known,  but  prudence  suggests  that  we 
consider  such  potential  adverse  immune  effects  of  child- 
hood exposure. 

We  are,  in  general,  a  medicated  society  and  the  tnmiber 
of  medications  used  increases  with  age.  Many  medicatioas 
to  treat  hypertension,  arthritis,  aixl  irregular  heart  beat  are 
pbotosensitizers.  Oeariy,  their  use  is  greatest  in  okler 
Americans.  n\aking  phototoxic  reactioDS  with  sun  exposure 
particularly  problematic  for  the  eklerty. 

Abundant  evidence  exists  that  die  extent  of 


photodamage  or  photoaging  is  a  fimction  of  cumulative  sun 
exposure,  especially  among  fair  skinned  Caucasians.^  Most 
attention  has  focused  on  the  cosmetic  consequences  of 
photoaging.  The  importance  of  these  changes  to  our 
population  is  evident  in  the  biUions  of  dollars  spent  each 
year  to  cover  or  revCTse  them.  Less  often  noted  is  the 
fiiDctional  impairment  resulting  fiom  photodamage  cxxa- 
bined  with  aging.  For  example,  loss  of  skin  integrity  can 
occur  with  less  trauma  and  ulcers  and  infections  can  occur 
as  a  consequence.  Wound  healing  takes  longer.  The  cost  of 
these  injuries  is  enormous.  Not  yet  known  is  the  relative 
importaiKe  of  recent  exposure  vctsus  childhood  exposure  to 
the  sun  on  the  cosmetic  or  functional  degradation  in  skiiL 
Neither  do  we  know  the  extent  to  which  these  problems  can 
be  ameliorated  or  reversed  by  subsequent  sun  protection. 

Economic  Implications 

There  is  no  question  that  sun  exposure  leads  to  substantial 
health  consequences  and  economic  costs.  Most  of  the 
600,000  normielanoma  skin  caixsrs  that  develop  each  year 
in  the  United  States  could  have  been  prevented'  The 
treatment  of  these  lesions  costs  hundreds  of  millions  of 
dollars.  Given  the  exposure  pattons  detailed  above, 
mathematical  models  tell  us  that  a  substantial  majority  of 
these  tumors  could  have  been  prevented  with  sunscreen  use 
in  childhood.  Based  on  mathematical  modeling,  the  cost  of 
each  nonmelaiKjma  skin  catKer  prevented  by  childhood 
sunscreen  is  about  five  dKiusand  dollars.'  Geariy  this  cost 
far  outweighs  the  cost  of  treating  these  timiors.  Other  types 
of  sun  avoidaiKx  may  also  have  substantial  health  conse- 
quences. In  the  elderiy.  discouraging  outdoor  activity  may 
result  in  decreased  physical  activity  with  subsequent  impact 
on  psychological  and  physical  well  being,  including  in- 
creased risk  of  cardiovascular  disease.  It  is  common  practice 
to  advise  individuals  who  have  developed  a  nonmelanoma 
skin  cancer  (who  are  often  elderiy)  to  be  especially  prudent 
in  avoiding  the  sun."  Although  the  higher  risk  of  a  new 
squamous  cell  cancer  in  populations  in  taore  southern  parts 
of  the  United  States  argues  thai  sun  exposure  subsequent  to 
a  first  squanxxis  cell  cancer  impacts  upon  subsequent  risk, 
the  increase  in  absolute  risk  is  relatively  nxxlest."  Wh^her 
reducing  the  rate  of  actinic  keratosis  formatioa  will  substan- 
tially reduce  the  risk  of  cancer  over  the  kng-term  is  not  ye( 
established."  Clearly,  loss  of  time  outdoors  may  have  an 
especially  great  impact  upon  okter  iixhviduals.  As  Uttle  as 
we  know  about  the  relationship  between  sun  exposure 
within  particular  periods  of  life  ai>d  the  risk  of  melanoma 
and  nonmelanoma  skin  cancer,  we  know  even  less  about  the 
relation  between  exposure  to  the  sun  at  various  poiods 
during  a  lifetime  and  photoaging. 

In  spite  of  the  clear  adverse  effects  of  sun  exposure  both 
in  cfaiklhood  and  older  age  groups  that  I  have  detaikd,  the 


Puc^nos  CF  nc  NAmuL  Cciiuukz  on  Bnvbomoital  Hazaub  id  m  Sm 


405 


ways  we  have  to  avoid  these  adverse  effects  are  not  without 
cost  So  far,  we  have  only  two  ways  of  reducing  sun 
exposure:  (I)  staying  out  of  the  sun:  and  (2)  using  sun- 
screens. Both  approaches  are  problematic  to  many.  Staying 
out  of  the  sun  usually  means  less  outside  activity,  with 
subsequent  loss  of  enjoyment  and  less  cardiovascular 
fitness.   Sunscreens  are  expensive,  inconvenient,  may  be 
uncomfonable  or  have  adverse  effects.   Perhaps  most 
worrisotne.  the  use  of  a  sunscreen  may  be  used  as  a  justifi- 
cation to  increase  actual  time  in  the  sun,  with  little  net 
reduction  in  total  ciunulative  exposure  to  carcinogenic 
radiation.  The  possible  result  is  increased  exposure  to 
longer  wavelengths  of  ultraviolet."  Of  greatest  concern  is 
the  possibility  that  as  individuals  spend  more  time  in  the 
sun  without  burning  (which  is  possible  for  fair  skinned 
persons  who  use  sunscreens),  exposure  to  ultraviolet-A 
(UVA),  especially  longer  wavelengths  of  UVA,  will 
increase.  Recent  animal  experiments  suggest  UVA  may  be 
particularly  important  in  the  etiology  of  melanoma.'^ 

Future  Research 

The  points  I  have  raised  iixlicate  the  need  for  further  clinical 
and  epidemiologic  research.  First  we  need  a  better  defiiu- 
tioo  of  the  relationship  between  dose  and  wavelength, 
timing  and  age  to  die  adverse  effects  of  the  sun  exposure. 
Second,  we  need  betto'  ways  to  identify  individuals  who  are 
susceptible  to  ultraviolet  damage.  If  we  can  identify  those 
indiWduals,  eiiiciait  preventive  strategies  can  be  developed 
and  persons  not  at  substantial  risk  from  sun  exposure  need 
not  forego  the  pleasures  and  benefits  of  the  sun  to  the  same 
extent  Qearly,  we  also  need  to  develop  photoprotection 
methods  that  are  more  acceptable  to  the  user.  These  should 
be  more  economical  and  without  substantial  adverse  risks. 
Unfortunately,  at  present  there  are  few  candidate  agents 
likely  to  meet  all  these  requirements. 

Although  preventive  strategies  are  inherently  appealing, 
we  also  need  clinical  research  on  the  risks  and  benefits  of 
alternative  approaches  to  reversing,  limiting,  or  treating  the 
adverse  effects  of  long-term  exposure  to  sunlight  Evalua- 
tion of  the  ultimate  consequences  of  the  use  of  topical 
retinoids  and  other  agents  that  are  claimed  to  rever% 
photoaging  are  still  needed.  Although  there  have  been  some 
promising  results  in  special  high-risk  groups,  to  date  the 
experience  with  oral  chemoprevention  of  nonmelaiKMna  skin 
cancer  in  humans  with  retinoids  and  antioxidants  such  as 
betacanxene  has  been  largely  disappointing."'"  We  need  to 
consider  new,  safe,  aixl  effective  strategies  for 
chemoprevention,  and  to  develop  methods  to  identify  ttiose 
persons  who  would  benefit  from  their  use.  Mote  immedi- 
ately, we  need  to  measure  better  the  advert  consequences 
of  long-term  sim  exposure.  This  includes  measuring  the 
impact  of  iKXimeUmoma  skin  cancer  on  an  individual's  life, 


detennining  the  relative  cost  and  benefit  of  different  thera- 
peutic approaches  to  treatment  of  skin  tumors  and 
photodamage,  and  developing  a  better  understanding  of  how 
patients"  preferences  can  be  better  incorporated  into  preven- 
tive strategies  and  treatment 

References 

1.  Taylor  CR,  Stem  RS,  Leyden  JJ,  et  al.  Photoaging/ 
photodamage  and  photoprotection.  J  Am  Acad 
Dermatol  1990;22:1-15. 

2.  van  der  Leun  JC.  UV-carrinogenesis.  Pholocbem 
Photobiol  1984;39:861-868. 

3.  Kripke  ML.  Photoimmunology.  Photochem  and 
Photobiol  1990;52:919-924. 

4.  Matsuaka  LY,  Worsman  J,  Hanifan  N,  et  al.  Chronic 
sunscreen  use  decreases  circulating  concertiations  of 
25-hydrDxyvitarain  D.  A  preliminary  study.  Arch 
Dermatol  1988;124:802-804. 

5.  Stem  RS,  Weinstein  MC,  Baker  SG.  Risk  reduction  for 
nonmelanoma  skin  cancer  with  childhood  sunscreen 
use.  Arch  Dermatol  1986;12:2537-2545. 

6.  Holman  CD,  Armstrong  BK.  Cutaneous  malignant 
melanoma  and  indicators  of  total  acciunulated  exposure 
to  the  stm:  An  analysis  separating  histogenetic  types.  J 
Natl  Cancer  Inst  1984;73:75-8Z 

7.  Lew  RA.  Sober  AJ,  Cook  N,  et  al.  Sun  exposure  habits 
in  patients  with  cutaneous  melanoma:  A  case  control 
study.  J  Domatol  Surg  Oncol  1983;9:981-986. 

8.  Gallagher  RP,  McLean  DI,  Yang  CP,  et  al.  Suntan. 
sunburn,  and  pigmentation  factors  and  the  fiequeiKy  of 
acqiured  melaiKx:ytic  nevi  in  children.  Similarities  to 
melanoma:  The  Vancouver  Mole  Study.  Arch  Dermatol 
1990;126:770-776. 

9.  Gallagher  RP,  McLean  DI,  Yang  CP,  et  al.  Anatomic 
distribution  of  acquired  melaiKicytic  nevi  in  white 
children.  A  comparison  with  melanoma:  the  VaiKouver 
Mole  Snidy.  Arch  Dermatol  1990;12:6466-6471. 

10.  Leffell  DJ,  Headington  JT,  Wong  DS,  et  al.  Aggressive- 
growth  basal  cell  carcinoma  in  young  adults.  Arch 
Dermatol  1991;127:1663-1667. 

11.  Boutwell  RK.  Model  systems  for  defining  initiation, 
promotion,  and  progression  ^tf  skin  neoplasms.  Prog 
Clin  Biol  Res  1989,298:3-15. 

12.  Karagas  MR,  Stukel  TA,  Greenberg  ER,  et  al.  Risk  of 
subsequent  basal  cell  carcitKima  and  squamous  cell 
carcinoma  of  the  skin  among  patients  with  prior  skin 
cancer.  Skin  Cancer  Prevention  Study  Group.  JAMA 
1992;267:3305-3310. 


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13.  Thompson  SC,  JoUey  D,  Maries  R.  Reduction  of  solar 
keratoses  by  regular  sunscreen  use.  N  Engl  J  Med 
1993^29:1147-1151. 

14.  Robinson  JK.  Behavior  modificatioa  obtained  by  sun 
protection  education  coupled  with  removal  of  a  skin 
cancer.  Arch  Dermatol  1990;126:477-481. 

15.  Garland  CF,  Garland  FC,  Gorham  ED.  Rising  trends  in 
melanoma  an  hypothesis  concerning  sunscreen  effec- 
tiveness. Ann  Epidemiol  1993:3:103-110. 

16.  Sedow  RB,  Giist  E,  Thonq>son  K,  et  al.  Wavelengths 
effective  in  induction  of  malignant  melanoma.  Proc 
Natl  Acad  Sci  USA  1993;9a666fr6670. 

17.  Kraemer  KH,  DiGiovanna  JJ,  Moshell  AN,  et  al. 
Prevention  of  skin  cancer  in  xeroderma  pigmentosum 
with  the  use  of  oral  isotretinoin.  N  Engl  J  Med 
1988;318:1633-1637. 

18.  Greenberg  ER,  Barron  JA,  Stukel  TA,  et  al.  A  clinical 
trial  of  beta  carotene  to  prevent  basal-cell  and  squa- 
mous-cell  cancers  of  the  skin.  The  Skin  CaiKer  Preven- 
tion Study  Group.  N  Engl  J  Med  1991;325:1324. 

19.  Tangrea  JA,  Edwards  BK,  Taylor  PR.  et  al.  Long-term 
therapy  with  low-dose  isotretinoin  for  prevention  of 
basal  cell  carcinoma:  A  multicenter  clinical  trial. 
Isotretinoin-Basal  Cell  Carcinoma  Study  Group.  J  Natl 
Cancer  Inst  1992;84:328-332. 


Fm^ncB  or  m  Natuul  Ccnbonce  on  ENVBOMioHrAL  Hazjuob  io  tw  Sa4 


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Tanning  Salons 

Vincent  A.  DeLeo,  MX). 


Introduction 

Tanning,  or  hyperpigroentadon  by  solar  radiation,  of  itself  is 
not  deleterious  to  skin.  It  is.  however,  a  marker  of  toxicity 
or  skin  damage.  Since  depth  of  tan  is,  within  a  given  skin 
type,  directly  related  to  the  quantity  of  radiation  absorbed  by 
the  skin,  it  represents  a  fairly  accurate  record  of  recent, 
cumulative  toxicity. 

Solar  or  natural  tanning  is  the  effect  of  a  natural  envi- 
ronmental hazard,  ultraviolet  radiation  from  the  sun. 
Technological  advaiKemenI  has  allowed  hunuuis,  however, 
to  produce  and  deliver  this  light  with  artificial  sources. 
Although  "sun  lamps"  have  been  in  use  for  years,  the  fad  for 
artificial  tans  and  development  of  places  of  business  (the 
sole  purpose  of  which  is  to  sell  taiming)  are  relatively 
receoL 

The  first  artificial  source  used  to  treat  humans  was  the 
carbon  arc  lamp.  Introduced  by  Finsen  to  treat  TB,  this 
invention  resulted  in  his  being  awarded  the  Nobel  Prize  in 
1903.  The  introduction  of  mercury  vapor  lamps  of  various 
pressures  with  the  addition  of  phosphor-containing  glass 
housing  for  fluorescent  tube  sources  followed.  Such 
sources  were  probably  first  used  for  purely  cosmetic  purpos- 
es, that  is,  to  induce  taiming,  when  tanning  came  into  vogue 
in  Western  Europe  and  the  Americas  within  the  last  40 
years.  Eariy  "sunlamps"  were  broad  spectrum  sources  that 
induced  pigmentation  with  UVB  (290-320  nm)  radiation. 
Their  utilization  was  limited  by  the  capacity  of  that  radia- 
tion to  induce  acute  toxicity  or  sunburn. 

In  the  1970s  modem  photomedicine  was  bom  with  the 
development  of  fluorescent  sources  that  could  deliver  high- 
intensity  ultraviolet  A  (320-400  nm)  or  longwave  radiation. 
Such  sources  were  used  fcH'  psoralen  photochemotherapy, 
and  psoralen  ultraviolet  A  (PUVA)  has  been  extensively 
utilized  to  treat,  more  or  less  successfully,  an  array  of 
deimatologic  diseases.  The  downside  of  the  technological 
advaiK£  was  that  such  sources  could  induce  taiming  with 
relatively  little  burning.  Since  such  sources  were  primarily 
UVA  in  output,  the  minimal  pigmentation  dose  was  less 
than  the  minimal  erythema  dose,  unlike  UVB  sources  or 
nahiral  solar  radiation.  The  manufacturing  of  such  sources 
to  produce  so-called  "safe  tans"  increased  rapidly  and  sun- 
tanning  parlors  or  solaria  were  boiTL 

Ussgo  Psttem 

The  tanning  industry  grew  3(X)%  annually  from  1980-198S, 
and  in  1987  advertising  for  salons  in  the  Yellow  Pages  grew 
at  an  manniiJiing  ss%  —  making  it  the  fastest  growing 


listing  category  that  year.  In  its  advertisements  for  new 
franchise  owners,  a  leading  sun  lamp  manufacturer  estimat- 
ed that  "annual  equipment  sales  have  already  grown  to  three 
hundred  million  dollars  ($300,000,000).  Retail  sales  of 
tanning  services  are  estimated  to  be  above  a  billion  dollars 
per  year"." 

By  1989  it  was  estimated  by  the  industry  that  200,000 
sun-tanning  units  were  in  operation,  half  of  them  in  18,000 
tanning  parlors  and  the  other  half  in  health  and  fitness  clubs, 
resorts  and  beauty  parlors.  Today,  an  estimated  one  million 
individuals  visit  such  institutions  on  any  given  day  and 
probably  12-24  million  people  (at  least  5%  of  the  popula- 
tion) in  the  U.S.  are  regular  users.  Surveys  iji  the  UK, 
Denmark  and  the  Netherlands  show  that  10%  of  the  popula- 
tion use  solaria  yearly." 

Two  survey  studies  of  tanning  salons,  one  in  the  UK  in 
1985'  and  one  in  Michigan  in  1989^,  found  that  the  mean 
estimated  age  of  the  user  was  26  years  in  the  U.S.;  50%  of 
the  UK  users  were  between  16  and  30  years  old.  Shocking- 
ly, the  Michigan  study  foimd  a  two-year-old  child  was  the 
youngest  user  and  only  half  of  the  salons  had  age  restric- 
tions. Over  80%  of  the  UK  users  were  women.  The  most 
commonly  cited  reasons  for  visiting  the  salons  was  to 
prevent  burning  from  subsequent  natural  exposure  and  for 
"appearance,"  that  is,  to  achieve  tanning.  A  smaller  percent- 
age of  customers  claimed  to  visit  the  salon  for  treatment  of 
skin  diseases,  including  psoriasis,  acne,  and  eczema. 

The  median  number  of  sessions  for  each  individual  was 
less  than  30  in  the  UK,  but  almost  10%  of  users  reported 
between  100  and  1000  visits.  Almost  half  of  the  users 
classified  themselves  as  having  Type  I  or  II  skin.  In  other 
words,  these  are  the  individuals  at  greatest  risk  for 
photodamage,  who  are  least  likely  to  actually  benefit 
cosmetically  for  their  risk  and  expense.  Extrapolating  the 
data  in  an  admittedly  unscientific  way,  one  could  estimate 
that  of  the  10  to  IS  million  Americans  who  visit  solaria 
yearly,  5  million  at  least  are  light  skinned  individuals  at 
great  genetic  risk  for  developing  photoaging  and  skin 
cancer.  Probably  1  to  2  million  users  are  "tanning  junkies" 
who  visit  salons  twice  or  more  per  week  on  average. 

Soums 

There  are  no  data  as  to  exactly  what  artificial  sources 
are  presently  being  utilized  in  taiming  salons  in  the  USA. 
Certainly  the  majority  use  predominantly  UVA-emitting 
fluorescent  tube  sources.  So<alled  Type  I  sources  contain 
UVA  1  (340-400  nm)  and  UVA  2  (320-340  nm)  and  a 


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37 


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relatively  lai^e  quantity  of  UVB.  Type  II  sources  contain 
primarily  UVA  1  with  little  UVA  2  and  less  UVB«.  While 
(ximarily  UVA  in  output,  many  sources  also  produce 
significant  UVB  inadiation.  In  fact,  the  percentage  of  UVB 
in  such  sources  is  estimated  to  range  from  0.04%  to  6.9%, 
and  in  one  study  done  in  Arkansas'  where  output  was 
surreptitiously  measured  in  actual  salons,  UVB  content 
ranged  from  0.03%  to  3.5%.  While  a  few  UVA  metal- 
halide  sources  are  utilized  in  Europe,  these  are  not  conunon 
in  the  U.S.  Oess  than  1%). 

The  irradiance  of  Type  I  sources  in  the  UVA  range  is 
about  8  mW/cm2  and  25  mW/cm2  in  the  Type  n  sources. 
In  the  Arkansas  study,  the  measured  irradiance  in  the  16 
salons  ranged  from  5-19  mW/cm2.  Utilizing  the  same 
probes  at  midday  in  June  in  Arlcansas  the  solar  irradiance 
was  3.8  mW/cm2  wi±  about  6.5%  UVB.  While  some 
salons  limit  exposure  to  15  minutes  on  first  treatment,  the 
most  popular  exposure  was  30  minutes.  Depending  on  the 
source,  the  UVA  exposure  could  be  equivalent  to  3  hours 
(cff  14  to  45  J/cm2)  of  natural  UVA  and  exposures  of  UVB 
that  would  certainly  exceed  minimal  erythema  doses.' 

Acute  Adveree  Effects 

It  is  scientifically  accepted  that  solar  radiation  is  damaging 
to  human  skin.  Such  radiation  is  responsible  for  acute 
effects,  including  sunburn  and  immune  modulation  and  the 
delayed  effects  of  carcinogenesis  and  photoaging.  In  select 
individuals  or  under  the  influence  of  certain  exogenous 
chemical  factors,  such  radiation  also  produces  abnormal 
responses  caUed  photosensitivity.  The  ability  of  artificial 
sources  to  produce  all  of  these  effects  can  be  postulated 
based  on  knowledge  of  the  emission  spectra  of  the  sources 
utilized  and  the  action  spectra  of  the  adverse  effects. 

We  know  from  animal  studies  and  some  human  data 
that  while  UVB  is  most  efficient  at  producing  erythema, 
immtme  imdulalion,  carcinogenesis,  and  photoaging,  UVA 
can  act  alone  to  induce  these  effects  and  can  potentiate  the 
induction  of  these  effects  by  UVB  radiation.  This  suggests 
thai  tarming  salon  radiation,  even  with  Type  II  sources  that 
contain  only  small  quantities  of  UVB,  can  cause  these 
effects. 

Actual  data  on  salon  toxicity  is  sparse  but  growing.  In  a 
controlled  study,  33  hospital  staffers  in  Scotland  underwent 
ten  15-minute  exposures  over  a  2  week  period  for  tanning'°. 
A  fiill  60%  experienced  at  least  minimal  sunbutning  and 
one-third  complained  of  itching.  A  similar  study  from  the 
UK  in  which  31  individuals  were  delivered  twelve  20 
minute  -30  minute  Type  n  lamp  exposures,  revealed  85%  of 
individuals  experiencing  bum  and  77%  complained  of 
itching.  In  the  UK  survey  study  of  sun-bed  users  in  a 
positively  biased  population,  19%  repotted  episodes  of  sun 
burning  and  28%  complained  of  itching'.  In  1989.  the 


Centers  for  Disease  Control  and  Prevention  (CDCP) 
surveyed  physicians  in  Wisconsin;  31  of  43  dermatologists 
and  41  of  301  emergency  room  physicians  responded. 
Those  72  physicians  reported  treating  a  total  of  220  patients 
for  taiming  device  bums  in  the  previous  12  month  period. 
Thirty-nine  of  the  reported  bums  were  second  degree  bums, 
all  of  sufBciem  extent  to  warrant  seeking  medical  attention. 
Sixty  percent  of  the  patients  sustained  their  injuries  in 
taiming  salons  and  40%  at  home.  "Sunburn"  in  taiming 
salons  is  certainly  not  an  unusual  event". 

Another  acute  effect  of  taiming  salon  usage  is  induction 
or  exacerbation  of  abnormal  photosensitivity  responses. 
Such  responses  occur  naturally  to  solar  exposure  and 
include  photochemical  sensitivity  to  agents  taken  systemi- 
cally  or  applied  topically  to  the  skin;  reactions  to  radiation 
caused  by  genetic  or  metabolic  conditions,  including  the 
porphyria  and  rarer  conditions  like  xeroderma  pigmentosa 
and  Bloom's  Syndrome;  diseases  of  other  organ  systems 
associated  with  cutaneous  photosensitivity,  like  collagen 
vascular  disease  and  HIV  infections;  and  diseases  of  im- 
known  cause,  in  which  the  primaiy  response  is  limited  to 
the  photosensitive  emption,  like  polymorphous  light 
empdon.  The  critical  difference  between  these  cutaneous 
responses  and  the  more  normal  responses  of  sunburn  and 
photoaging  is  that  the  action  spectra  for  the  vast  majority  of 
these  responses  fall  within  the  UVA  range.  They,  therefore, 
are  more  likely  to  occur  in  reaction  to  tanning  salon  light 
than  to  natural  sun  exposure,  where  the  dose  rate  in  the 
range  is  considerably  lower. 

The  linkage  between  tanning  salon  exposure  and  such 
reaction  is  for  the  most  part  anecdotal.  It  is  possible  that 
some  of  the  sunburns  reported  in  the  previous  discussion 
were  clinically  photosensitized  responses,  since  an  "exag- 
gerated-sunburn" response  is  one  type  of  photodmg  reac- 
tion. Considering  the  exposure  of  our  population  to  these 
chemicals,  coupled  with  1  million  visits  to  salons  per  day, 
the  incidence  of  photochemical  adverse  effects  must  be 
significant. 

In  the  prospective  controlled  study  among  Scotland 
hospital  workers,  12%  (4/33)  individuals  developed 
polymorphous  Ught  emption  (PMLE);  in  the  controlled  UK 
study,  42%  (13/31)  were  affected"".  This  idiopathic 
photosensitivity  has  been  reported  to  occur  in  approximately 
10%  of  the  normal  population  of  young  adults  in  this 
country.  Since  75%  of  all  affected  patients  are  sensitive  in 
flje  UVA  range,  12%  in  the  controlled  study  is  probably  a 
reasonable  incidence  rate.  In  the  UK  survey,  28%  of 
patients  developed  itching  and  8%  developed  rash'.  Neither 
rash  or  itch  was  more  clearly  defined,  but  in  all  likelihood 
were  either  polymorphous  light  eruption  or  photochemical 
sensitivity. 

The  field  of  photoimmunology  is  a  relatively  new  one. 


PRocEEDiNas  OF  mE  Natonal  Coiriience  cn  ENvnoKMorrAL  Hazaxes  to  iw  Sun 


409 


Scientists  working  in  this  area  have  heightened  our  aware- 
ness of  skin  as  an  immune  organ.  As  for  sunburn  and 
carcinogenesis,  the  action  spectnim  for  suppression  peaks  is 
in  the  UVB  range,  but  UVA  alone  is  active. 

Twelve  30-minute  tanning  sessions  suppres,sed  skin  test 
response  to  DNCB,  decreased  Langeihans  cell  number, 
decreased  the  number  of  circulating  T4  helper  lymphocytes 
and  reduced  natural  killer  (NK)  cell  activity.  Decreased 
lymphocyte  response  to  mitogen  and  decreased  ability  to 
repair  DNA  lesions  by  unscheduled  DNA  synthesis  were 
found  in  peripheral  lymphocytes  after  a  single  salon  tanning 
session.  Most  of  the  responses,  with  (he  exception  of 
suppression  of  NK  cell  activity,  were  attributed  to  the  UVB 
present  in  the  tatming  sources."  " 

Chronic  Adverse  Effects 

As  might  be  expected,  it  is  more  difficult  to  obtain  data 
conceniing  the  chronic  effect  of  tanning  salon  usage. 
Present  information  about  the  effect  of  such  radiation  on 
skin  cancer  and  photoaging  is,  therefore,  based  on  extrapola- 
tions from  in  vitro  studies,  animal  studies,  retrospective  case 
controlled  studies  and  anecdotal  '■aTwrts. 

In  vitro  cell  culture  studies  in  a  variety  of  cell  types 
reveal  that  UVA-induced  DNA  damage  is  mutagenic  and 
can  affect  important  second  messenger  systems  with 
activation  of  lipases  and  kinases  and  expression  of  impor- 
tant gene  products.  In  animals,  UVA  alone  is  caticinogenic 
and  can  act  to  promote  photo-  or  chemically-initiated 
nonmelanoma  skin  cancers.  Kligman  and  her  colleagues 
have  shown  that  UVA  alone  can  induce  dermal  toxicity, 
including  elastosis  and  alterations  of  dermal  matrix  constitu- 
ents contributing  to  photoaging. 

Recently,  Bech-Thomsen  and  colleagues  reported  a 
study  in  which  mice  were  treated  with  3  commonly  used 
UVA  tatming  sources  at  normally  utilized  doses.  All  three 
sources,  even  a  Type  11  source  with  very  Utile  UVB  and 
UVA  2  contamination,  were  capable  of  inducing  skin  cancer 
alone.  In  an  attempt  to  reproduce  the  client  pattern  of 
utilizing  tatming  salons  before  vacationing  for  "protection," 
the  mice  were  treated  with  tanning  light  followed  by  solar 
simulated  light  The  two  Type  I  sources  actually  enhanced, 
rather  than  suppressed,  tumor  development  The  Type  Q 
source  was  not  protective  but  neither  did  it  enhance  tuiiKX' 
development 

Diffey  has  developed  a  statistical  model  for  risk  assess- 
ment for  carcinogenesis  from  taiming  salon  use'^ ".  This 
model  is  based  on  the  assumption  that  the  spectrum  for 
nonmelanoma  skin  cancer  is  similar  to  the  spectrum  for 
erythema,  and  the  risk  assessment  is  based  on  total  cumula- 
tive dose,  corrected  for  erytfaemal  effectiveness.  It  does  not 
consider  more  than  additive  augmentation,  which  might 
occur  if  UVA  acted  in  a  promotional  matmer  in  the  carcino- 
genic process.  Utilizing  Type  n  sources  with  little  contami- 


nating UVB,  Diffey  estirrutted  that  ten  30  minute  sessions  per 
year  used  annually  from  20  years  of  age  increase  the  risk  of 
developing  nonmelanoma  skin  cancer  by  only  5%  at  middle 
age.  Increasing  usage  to  once  per  week  increases  the  risk  to 
30%  above  baseline;  for  chronic  users  or  "tanning  junkies" 
with  more  than  100  sessions  per  year,  the  risk  of  developing 
skin  cancer  by  middle  age  is  doubled. 

The  risk  for  development  of  melanoma  hum  taruiing 
salon  use  is  more  troublesome.  No  widely  accepted  animal 
iTKXJel  for  HKlanoma  is  available,  so  die  action  spectrum  for 
that  more  severe  mmor  is  undefined;  it  may  not  mimic  the 
spectnun  for  erythema.    Statistically  modeled  risk  assess- 
ment is,  therefore,  impossible.  A  patient  was  reported  by 
Roth  and  colleagues  with  UVA-induced  lentigines  after  1 .3 
years  of  two  taiming  sessions  per  week".  A  similar  patient 
was  repotted  by  Jones  and  colleagues".  Anecdotal  reports 
of  melaiKjma  after  artificial  tanning  include  9  of  270 
patients  in  a  London  melanoma  clinic"  and  one  Danish 
patient  with  a  melanoma  beneath  the  watchband,  skin 
exposed  only  during  artificial  tatming." 

In  a  detailed  case-controlled  study  of  583  patients  with 
melanoma,  Walter  and  colleagues"  reported  that  the  odds  of 
having  used  an  artificial  tanning  device  was  1 .88  and  1 .45 
higher  in  males  and  females  respectively  with  melanoma  as 
compared  to  normal  controls.  The  risk  of  artificial  tatming 
and  melanoma  was  increased  with  increased  usage  of  the 
devices. 

All  of  these  data  support  the  concept  that  usage  of 
tarming  salons  should  be  considered  risky  behavior.  Such 
usage  certainly  induces  skin  burning  and  various  types  of 
cutaneous  pathology  that  require  acute  medical  attention. 
That  attention,  other  than  causing  discomfort  to  the  individ- 
ual, results  in  a  cost  to  society  both  for  treatment  of  the 
toxicity  by  our  health  care  system  and  in  terms  of  days  lost 
in  die  workplace. 

Beneficial  Effects 

And  what  is  the  benefit  of  tanning  salon  usage  to  the 
population?  Patients  go  to  tanning  salons  primarily  for 
three  purposes:  (I)  for  cosmetic  tanning;  (2)  to  "pre-tan"  in 
an  attempt  to  protect  skin  before  outdoor  exposure;  and  (3) 
to  treat  disease.  Tanning  does  occuir  with  artificial  sources 
but  not  so  much  as  one  might  probably  expect  Only  60% 
of  the  hospital  staffers  who  received  10  exposures  devel- 
oped a  noticeable  tan  in  the  Scottish  study;  in  the  UK 
controlled  study,  all  patients  developed  some  tan  after  12 
exposures'-'".  As  expected,  those  who  tan  pooriy  in  natural 
Sim  (Type  I  &  n  skin)  also  tan  pooriy  with  artificial  sources. 
The  tans  achieved,  however,  were  not  very  photoprotective. 
SPF-like  determinations  an  artificially  tanned  skin  revealed 
mean  protective  factor  for  sunbuming  to  be  only  3.2  and  3.9 
in  those  two  studies. 


Proceedings  of  ike  Nauonal  Conibiencx  on  ENvmoNMEm'/u.  Hazams  to  me  SnN 


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In  a  survey  of  tanning  salon  users  who  claimed  usage  for 
disease  treatment,  all  61  respondents  reported  subjective 
improvement  in  psoriasis,  acne  and  eczema.  Other  con- 
trolled studies  make  such  claims  ^>pear  to  be  placebo  effect, 
since  the  therapeutic  action  spectra  for  psoriasis  and  eczema 
are  primarily  in  the  shorter  wave  range.  Recent  reports  of 
UVA  1  treatment  of  atopic  eczema  still  do  not  warrant 
unsupervised  UV  exposure  in  the  salon  setting. 

In  the  user  survey,  82%  of  solarium  users  claimed  to 
'Yeel  more  relaxed,  more  self  confident  or  happier"  after 
using  the  sunbed.  Seasonal  affective  disorder,  or  SAD,  is 
certainly  a  real  entity  that  can  be  treated  with  light.  The 
therapeutic  action  spectrum  for  that  disease  is  in  the  visible 
range,  however,  not  the  UV.  The  psychological  effect  of 
aitificial  taiming  is,  therefore,  more  likely  related  to  per- 
ceived cosmetic  benefit'. 

Photoreactivation,  that  is,  UVA-visible  light  induced 
repair  of  UVB  damaged  DNA,  has  been  extensively  studied 
and  may  be  impottant  in  human  skin.  The  UVA-invisible 
induction  of  the  reparative  enzyme,  however,  must  follow 
the  UVB-induced  lesion  production.  Since  aitificial  tanning 
itxitinely  precedes  and  does  not  follow  natural  sunbathing, 
such  a  benefit  from  tanning  salons  is  purely  theoretical. 

Finally,  the  single  known  beneficial  effect  of  UV 
exposure  of  the  skin  is  vitamin  D  production.  The  action 
spectrum  for  that  response  is  in  the  UVB  range.  Devgun 
and  colleagues  in  their  controlled  tanning  smdy  measured 
increased  serum  25-hydroxyvitamin  D  in  their  subjects  after 
artificial  tatming.  In  this  era  of  vitamin  D-fortified  dairy 
products,  however,  this  benefit  seems  of  minimal  impor- 
tance". 

Summary 

In  summary,  artificial  tanning  is  of  no  benefit  other  than 
cosmetic.  The  acute  risks  of  such  activity  are  known,  and 
evidence  exists  that  long  term  risks  are  significant  What 
should  we  do,  therefore,  to  prevent  this  man-made  environ- 
mental hazard  from  damaging  our  population?  An  easy 
answer  is  to  prevent  the  utilization  of  ultraviolet  light 
sources  for  tanning.  Such  devices  are  monitored  by  the 
Center  for  E)evices  and  Radiological  Health  of  the  Food  and 
Drug  Administration.  The  regulations  concerning  use  of 
these  devices  are  given  in  the  1985  Federal  Register  publi- 
cation entitled  Sunlamp  Products;  Performance  Standard; 
Final  Rule.  The  monograph  gives  standards  for  the  irradi- 
ance  of  the  sources.  Interestingly,  pure  UVB  sources  are 
acceptable.  It  regulates  timer  setting  (although  it  is  permis- 
sible for  the  times  to  be  reset  by  the  user);  protective 
eyewear  is  mandated.  A  warning  statement  is  required  and 
instruction  for  use  to  "avoid  or  minimize  potential  injury"". 
These  regulations  are  similar  to  those  regarding  tobacco 
usage.  Further  regulation  at  the  federal  level  is  unlikely. 


The  most  effective  measures,  first  and  foremost,  are 
consumer  education.  Through  established  programs 
developed  by  the  AAD,  the  Skin  Cancer  Foundation,  the 
American  Cancer  Society  and  the  Skin  Pbototrauma  Fbun- 
dation,  consumers  should  be  educated  about  the  deleterious 
effects  of  all  UV  radiation.  Stress  should  be  placed  on  the 
fact  that  the  tanning  of  any  type,  including  tanning  salon 
usage,  is  dangerous.  The  educational  process  must  begin  in 
infancy  and  be  strongly  reinforced  through  the  risk-taking 
adolescent  period.  The  focus  should  not  just  be  on  skin 
cancer,  but  on  the  unattractiveness  of  photoaging.  Our 
colleagues  in  pediatrics  and  the  public  school  systems  must 
become  more  involved  in  the  process.  The  press,  especially 
leisure,  fimess,  and  beauty  magazines,  along  with  radio  and 
television  entrataimnent  programs,  should  be  our  greatest 
allies  in  this  process. 

References 

1 .  Bickers  OR,  Epstein  JH,  Fitzpatrick  TB,  et  al.  Risks 
and  benefits  bom  high-intensity  ultraviolet  A  sources 
used  for  cosmetic  purposes.  1985;12:380-381.Special 
Report . 

2.  Sunlight,  Ultraviolet  Radiation,  and  the  Skin.  NIH 
Consensus  Development  Conference,  May  8-10,  1989. 
Program  and  Abstracts. 

3.  Mutzhas  MF.  Beneficial  effects  of  intentional  ultravio- 
let exposure  in  taiuiing  parlors.  NIH  Consensus  Devel- 
opment Conference,  May  8-10,  1989.  Program  and 
Abstracts. 

4.  Gange  RW.  Commercial  intentional  ultraviolet  expo- 
sure: Tanning  parlors.  NIH  Consensus  Development 
Conference,  May  8-10,  1989.  Programs  and  Abstracts. 

5.  Diffey  BL.  Use  of  UVA  sunbeds  for  cosmetic  tanning. 
Br  J  Dermatol  1986;l  15:67-76. 

6.  Beyth  R,  Hunnicutt  M,  Alguire  PC.  Tanning  salons:  An 
area  survey  of  proprietors'  knowledge  of  risks  and 
precautions.  J  Am  Acad  Dermatol  24:277-282. 

7.  Hawk  JLM.  Sunbeds.  Br  J  Med  1983086:327. 

8.  Gies  HP,  Roy  CR.  Elliot  G.  Aitificial  suntanning: 
Spectral  irradiance  and  hazard  evaluation  of  ultraviolet 
sources.  British  Physics  1986',50:691-703. 

9.  Bruyneel-Rapp  F,  Dorsey  SB,  Guin  JD.  The  tanning 
salon:  An  area  survey  of  equipment,  procedures,  and 
practices.  J  Am  Acad  Dermatol  1988;18: 1030-1038. 

10.  Rivers  JR,  Nonis  PG,  Murphy  GM,  e«  al.  UVA 
simbeds:  Tanning,  pholoprolection,  acute  adverse 
effects  and  immunological  changes.  Br  J  Dermatol 
1989;120:767-777. 


Pmxxedinqs  or  the  Naucnal  COsbuence  cm  ENvncMiiENrAL  Hazaids  to  the  Son 


411 


11.  injuries  associated  with  ultraviolet  tanning  devices  - 
Wisconsin.  Mofbidity  and  Mortality  Weekly  Report. 
JAMA  1989061:3519-3520. 

12.  Hei%y  P.  Hasic  E,  Edwards  A.  et  al.  Immunologica] 
effects  of  solarium  exposure.  Lance<  1983:545-548. 

13.  Larcom  LL,  Moms  TE,  Smith  ME.  Suppression  of 
immunocompetence  and  DNA  repair  capacity  by 
exposure  in  commercial  taruiing  salons.  1990,82:1361. 
Correspondence. 

14.  Larcom  IX,  Morris  TE,  Smith  ME.  Tanning  salon 
exposure  suppression  of  DNA  repair  capacity  and 
mitogen-induced  DNA  synthesis.  Photochem  and 
Photobiol  1991;53:51 1-516. 

15.  Hersey  P,  MacDonald  M,  Henderson  C,  et  al.  Suppres- 
sion of  natural  killer  cell  activity  in  humans  by  radiation 
from  solarium  lamps  depleted  of  UVB.  J  Invest 
Dermatol  1988;90:305-310. 

16.  Bech-Thomsen  N,  Wulf  HC,  Poulsen  T,  et  al. 
Photocarcinogeoesis  in  hairless  mice  induced  by 
ultraviolet  A  tanning  devices  with  or  without  subse- 
quent solar-simulated  ultraviolet  irradiation. 
Photodermatol  Photoinununol  Photomed  1991:8:139- 
145. 

17.  DifPey  BL.  Cosmetic  solaria  and  malignancies  of  skin. 
Photodennatol  1987;4:273-276. 

18.  DifTey  BL.  Analysis  of  the  risk  of  skin  cancer  from 
stinlight  and  solaria  in  subjects  living  in  northern 
Eurt^K.  Photodermatology  1987;4:118-126. 

19.  Roth  DE,  Hodge  J,  Callen  JP.  Possible  ultraviolet  A- 
induced  lentigines:  a  side  effect  of  chronic  tanning  salon 
usage.  J  Am  Acad  Dermatol  1989-,20:950-954. 

20.  Jones  SK,  Moseley  H.  Mackie  MM.  UVA-induced 
melanocytic  lesions.  Br  J  Dermatol  1987;117:111-115. 

21.  Retsas  S.  Sunbeds  and  melanoma.  Br  Med  J 
1982;286:892. 

22.  Brodthagen  H.  Malignant  melanoma  caused  by  UVA 
suntan  bed?  Acta  Dermatovener  (Stockholm) 
1981;62:356-357. 

23.  Walter  SD,  Matrett  LD,  Ftiom  L.  et  al.  The  association 
of  cutaneous  malignant  melanoma  with  the  use  of 
sunbeds  and  sunlamps.  Am  J  Epidemiol  1990;131:232- 
243. 

24.  Devgun  MS,  Johnson  BE,  Patoson  CR.  Tanning, 
protection  against  sunburn  and  vitamin  D  fonnation 
with  a  UVA  sunbed.  Br  J  Dermatol  1982;107:275-284. 


25.  Sunlamp  products;  Performance  standard;  final  rule. 
Dept  of  Health  and  Human  Services,  Food  and  Drug 
Administration.  September  6,  1985;  Federal  Register, 
36547-36552. 


PUX^DMB  OF  nE  NAnONAL  CoMCRBCe  ON  ENVBCMMBtTAL  HaZAKDS  TO  nC  SON 


412 


Plant  DERMArms 

Jere  D.  Guin,  M.D. 


Parthbiium  Dermaitds  (Parthenium  hysterophows  Linn): 
A.  Parthenium  Dermatitis  in  India  {The  Scourge  of  India) 

Transmission  in  Contaminated  Seed  from  Texas 

About  1958  the  United  States  shipped  seed  wheat  to  India 
as  a  humanitarian  gesture.  After  it  genninated,  Parthenium 
hysterophorus,  an  American  weed  alien  to  India,  grew  out 
with  the  wheat  It  was  first  seen  near  Bombay  (in  the  Poona 
area)  but  spread  rapidly  from  there.  After  a  dam  broke,  the 
ensuing  flood  carried  the  seed  downstream  over  the  region.' 
This  weed  is  extremely  aggressive  in  India,  crowding  out 
useful  vegetation  and  causing  problems,  especially  in  the 
dairy  industry  and  in  agriculture.^  This  plant  is  caUed  wild 
feverfew  or  carrot  weed  in  the  United  States,  but  in  India  it 
is  called  "Congress  weed."  (Reports  differ  as  to  how  that 
started,  but  one  can  imagine.)  Parthenium  hysterophorus  is 
a  member  of  the  family  Compositae,  which  includes  many 
of  the  daisy-like  flowers,  (dandelion,  asters,  and  chrysanthe- 
mum) as  well  as  ragweed,  cocklebur,  and  a  wide  variety  of 
garden  plants. 

The  new  resident  in  the  flora  of  India  threatens  the 
human  as  well  as  the  plant  population,  as  it  causes  an 
allergic  dermatitis  in  epidemic  numbers  and  can  be  life 
ruining  in  its  severity.'^  The  allergens  are  found  in  glandu- 
lar tissue  in  hair-like  structures  on  the  surface  of  the  plants. 
Because  it  looks  like  something  has  been  blown  onto  the 
skin,  many  people  assume  one  rash  results  from  contact 
with  (he  pollen. 

Widespread  Distribution  lias  Produced  Extensive  Exposure 

Originally  the  disease  was  seen  in  the  southwestern  United 
States  ';  it  was  recognized  and  described  in  the  early 
writings  of  a  Dallas  dermatologist,  Bedford  Shelmire,  MX). 
The  plant  is  distributed  along  the  Gulf  Coast  and  lands 
surrounding  the  Caribbean  to  northern  Argentina.  It  has 
now  been  reported  in  not  only  India,  but  also  China,  Viet- 
nam, certain  Pacific  Islands,  South  Africa,  Mozambique, 
Madagascar  in  Africa  and  Australia.' 

The  eruption  usually  starts  in  exposed  areas  but  may 
involve  almost  the  entire  body  surface,  producing  thicken- 
ing of  the  skin  of  the  face  to  cause  a  "leonine  fades"  as  seen 
in  lepromatous  leprosy.  In  the  United  States  it  occurs 
especially  in  agricultural  workers.  This  is  probably  also  true 
in  India,  although  there  it  occurs  in  all  walks  of  life  and 
causes  many  cases  of  exfoUative  erythroderma,  an  eruption 
essentially  covering  (he  entire  skin  surface,  head  to  toe. 


While  in  the  U.S.  the  eruption  from  this  plant  is  largely 
seasonal  (May  to  Decembery,  it  grows  all  year  in  India. 
Lonkar  "  describes  the  progression  from  eyelids  to  patches 
on  the  face  to  neck,  antecubital  and  other  exposed  sites  to 
involvement  of  the  total  skin  surface.  The  eruption  may 
spare  areas  where  pigment  is  lost  fix>m  vitiligo.'  The  reason 
for  this  phenomenon  is  not  clear. 

Attempts  at  Control 

Eradication  efforts  have  been  unsuccessful  with  additional 
exposure.  Many  assume  that  herbicides  are  not  used 
because  they  are  not  effective,  but  the  problem  is  more 
economic  than  scientific.  Budgetary  constraints  have 
permitted  only  the  hiring  of  persons  to  pull  the  weed,  and 
this  has,  perhaps,  compounded  the  problem. 

Gender  and  Age  Specificity 

The  eruption  largely  affects  older  males.  Children  em- 
ployed to  uproot  the  plant  in  the  "destroy  Parthenium" 
campaign  apparently  did  not  become  allergic,  while  over 
half  the  adult  males  hired  to  uproot  the  weed  were  found  to 
be  allergic  on  testing  and  4%  had  the  rash.  Sharma  reported 
that  1 1  of  55  Compositae-allergic  persons  were  female.' 
The  percentages  vary,  probably  on  the  basis  of  exposure, 
but  the  incidence  in  males  is  regularly  higher. 

PutatWe  Specificity  of  the  Antigen  and  its  Oiasteromer 
Rao,  et  al.  *  found  parthenin  in  P.  hysterophorus  to  which 
costus-sensitive  persons  reacted.  That  chemical  is  also 
found  in  other  related  plants.  This  is  probably  because  P. 
hysterophorus  also  contains  the  chemical  abrosin,  but  so 
does  ragweed.  If  one  is  allergic  to  that  chemical  he  or  she 
would  break  out  to  both  plants.  The  structure  of  that  type 
chemical  is  sometimes  very  slightly  different  when  the  plant 
grows  in  a  different  hemisphere  producing  a  stereoisomer, 
with  a  rearranged  structure  of  the  same  formula.  While  the 
chief  allergen  is  thought  to  be  parthenin,  there  are  at  least 
three  allergenic  sesquiterpene  lactones,  which  can  cause 
allergy '  and  perhaps  more '. 

Airborne  Spread 

There  are  arguments  for  and  against  the  theory  of  of  air- 
borne spread.  The  most  cogent  for  pollen  as  a  cause  is  the 
location  of  the  rash  in  exposed  sites,  at  least  primarily. 
While  it  has  been  suggested  that  dust  can  spread  the  erup- 
tion, there  is  strong  evidence  against  the  idea,  as  most 
species  causing  the  allergy  do  not  have  the  causative 


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chemicals  in  their  pollen.  Also  most  sufferers  improve  on 
moving  from  the  farm  to  the  city,  despite  high  urban  pollen 
counts.  This  has  recently  been  discussed  at  length.-" 

Treatment 

Pieman  and  Pieman  '"  reported  prevention  with  cysteine  in 
experimental  animals,  but  this  may  not  be  practical  in 
people  (it  is  malodorous).  Guin  described  successful 
treatment  with  PUVA.  "  and  azathioprine  is  reported  to  be 
beneficial.''  Oral  hyposensitization  is  a  classic  treatment, 
but  nonavailability  in  the  United  States  prevents  current  use 
in  this  country.  However,  it  has  recently  been  used  with 
success  in  India." 

B.  Dermatitis  Secondary  to  Ragweed  and  other  Compositae" 

Disease  Patterns  and  Differential  Diagnosis 

Reactions  occur  to  more  than  one  plant  in  many  cases, 
because  multiple  plants  make  the  same  chemical  and  many 
of  the  causative  chemicals  are  so  closely  related  that  the 
patient  may  break  out  bom  plants  to  which  he/she  has  never 
been  exposed. 

Patterns  of  ttie  Rasli 

Atopic  Eczema  Pattern 

Weed  sensitivity  can  very  closely  mimic  the  pattern  of 
childhood  eczema,  involving  the  bends  of  the  arms,  legs, 
wrists  and  ankles  as  well  as  the  face  and  neck  with  thicken- 
ing of  the  skin  similar  to  what  is  called  "atopic"  eczema." 
The  differences  suggesting  weed  allergy  are  onset  later  in 
life,  failure  to  respond  to  treatment,  worsening  in  the 
summer  and  clearing  in  the  winter  (the  reverse  of  atopic 
eczema)  and  sparing  of  the  feet  where  shoes  would  pro- 
tect." 

Photodermatitis 

These  patients  for  some  reason  also  become  light  sensitive; 
i.e.,  when  exposed  to  test  doses  of  bght  they  react  to  much 
less  light  than  it  normally  takes  to  bum."  The  pattern  of  the 
rash  in  weed  allergy  usually  is  a  little  different  from 
photodermatitis  in  that  areas  protected  from  direct  bght 
exposure,  such  as  the  under  surface  of  the  chin,  the  eyelids 
and  the  areas  back  of  the  ears,  are  involved  in  weed  allergy 
but  not  initially  in  light  sensitivity.  About  46%  of  persons 
diagnosed  as  photoallergic  are  also  weed  allergic,  so  routine 
testing  for  both  is  done  for  either  diagnosis." 

Hand  Eczema  Pattern 

This  may  occur  from  ragweed  or  perbaps  Chrysanthemum, 
but  in  our  area  it  most  commonly  is  seen  with  allergy  to 
bitterweed. "  Often  it  is  not  suspected  until  screening  tests 
show  weed  allergy,  or  until  the  patient  develops  a  more 
typical  eruption  elsewhere." 


Exfoliative  Dermatitis  " 

This  pattern  is  a  rash  from  head  to  toe  sparing  very  few,  if 
any,  areas,  and  scaling  so  severe  that  scales  cover  the  sheets 
on  the  bed.  Patients  lose  weight  and  their  skin  becomes 
thick,  especially  from  chronic  rubbing.  The  pattern  is  more 
typical  of  Panhenium  dermatitis,  but  it  can  also  occur  with 
other  Compositae. 

Localized  Pattern 

This  is  typical  of  cocklebur  and.  perhaps,  Magnolia.-'— 
The  localized  pattern  can  mimic  poison  ivy  dermatitis  in  the 
acute  phase  or  neurodermatitis  in  the  chronic  phase.^ 

Tlie  Geographic  Location 

The  problem  is  largely  rural  but  there  are  exceptions."-* 
Some  who  assume  the  allergens  are  airborne  because  of  the 
pattern,  claim  that  these  cases  are  caused  by  pollen,  but  the 
evidence  does  not  substantiate  that  concept"-'*-*  Dust  is  a 
factor  in  a  few  cases,  but  most  occur  from  direct  contact 
with  weeds  or  the  oleoresins  from  them. 

Age/Gender  Difference 

This  allergy  typically  involves  older  males,  but  both  sexes 
and  all  races  are  susceptible.  It  is  rare  in  children.  The 
reason  is  not  known,  but  it  may  be  something  other  than 
exposure,  since  children  used  as  weed  pullers  do  not  seem 
to  have  the  same  risk  as  older  adults.-^  Ragweed  dermatitis 
primarily  occurs  in  agricultural  workers,  but  may  affect  city 
dwellers  occasionally.  Ragweed  dermatitis  is  now  reported 
in  Austraha,  having  imported  the  weed  from  the  United 
States.  Incidence  is  greater  in  men,  with  older  data  showing 
about  20: 1  between  males/females  and  more  recent  data 
about  4: 1 . 

Underlying  Causes  and  Metliods  of  Confirming  Diagnosis 

In  some  cases  the  incidence  is  related  to  the  opportunity  for 
exposure.  Certainly  no  one  in  India  would  have  the  prob- ' 
lem  had  the  weed  not  been  transported  in  seed  wheat.  Also, 
the  condition  seems  to  clear  in  farmers  who  change  occupa- 
tions and  move  to  town.^-''' 

Older  males  are  more  at  risk,  and  certain  occupations, 
such  as  farming  or  logging,  are  particularly  likely  to  be 
associated  with  such  allergies,  as  the  plants  to  which  the 
workers  are  exposed  are  quite  sensitizing.  Weed  pullets 
hired  to  try  to  eradicate  a  sensitizing  weed  are,  of  course,  at 
risk.  Hobby  gardeners  also  develop  allergy  to  some  plants 
more  often  because  of  opportunity. 

Treatment  and  ttie  Environment 

Weeds  abound  in  disturbed  areas.  With  so  much  of  the  land 
developed,  the  number  can  be  very  high,  and  for  some 
species  the  opportunity  for  transport  in  world  commerce  has 
increased  providing  that  species  with  a  new,  more  compati- 


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ble  legation  where  it  can  thrive.  Removal  of  the  person  from 
exposure  is  effective,  once  the  condition  is  recognized. 
Attempts  to  tamper  with  the  ecology  using  natural  enemies 
have  so  far  been  ineffective. 

Medical  treatment  so  far  comprises  medications  affect- 
ing the  immune  system  and  light  in  the  form  of  UVA  with  a 
sensitizer  (PUVA  =  P  for  psoralen,  the  sensitizer,  and  UVA 
for  longer  wave  length  ultraviolet  light). 

Probishs  wnx  Florida  Houy  (Schinus  wrebiihthifolius): 
In  the  mid  1920's,  Henry  Nerling,  a  writer  and  horticultur- 
ist, reported  an  exciting  new  and  effective  ornate  shrub 
produced  dense  masses  of  scarlet  berries  at  Christmas 
time.^  This  species,  Schinm  terebinthifolius,  seems  to  be 
especially  suited  to  Florida.  Although  it  and  a  close  rela- 
tive, S  molle,  were  both  introduced  into  California,  only  the 
latter  is  now  naturalized  there.  As  early  as  1891  this  species 
was  introduced  into  Bradenton,  Florida  and  was  readily 
cultivated  from  seed.  The  plant  was  introduced  into  Ceylon 
at  about  the  same  time  and  spread  rapidly  to  Hawaii.  This 
plant  was  also  spread  through  the  commercial  seed  trade." 
S  terebinthifolius  is  often  erroneously  called  the  Brazihan 
pepper  tree.  However,  Schinus  molle  is  used  to  produce 
pepper,  while  the  fruits  of  S  terebinthifolius  do  not  have  that 
quality.' 

Because  S  terebinthifolius  is  eaten  by  many  species  of 
birds,  it  has  been  rapidly  disseminated,  becoming  an 
aggressive  weed  where  established,  impinging  on  the 
natural  ecosystems  in  much  of  the  state  of  Florida  Hazards 
include  asthma  and  sinus  problems,  as  well  as  skin  irrita- 
tion, which  has  been  attributed  to  N-alkylphenols.*"'   Skin 
"irritation"  has  also  been  attributed  to  cardanol  and  the  firxiit 
of  the  plant  The  plant  also  contains  delta-3-carene  and 
phellandrene  in  some  quantity.  The  cardanol  supposedly 
causes  a  delayed  type  of  skin  "irritancy"." 

The  aggressive  spread  of  this  plant  throughout  the 
tropical  portion  of  Rorida  has  become  a  major  problem  for 
individuals  in  that  region  who  are  concerned  with  the  native 
ecology.  S  terebinthifolius  apparently  will  not  grow  where 
the  soil  has  a  salt  content  greater  than  five  parts  per  thou- 
sand, and  it  does  not  tolerate  freezing  well."-"  While  an  N- 
alkylphenol  has  been  blamed  for  the  skin  eruption,  several 
investigators  have  not  found  that  type  chemical.  Brian 
Meyer,  then  at  Purdue  University,  found  a  nonadecyl 
phenoUc,  but  could  not  publish  this  because  no  other 
specimens  fiom  the  same  species,  fruiting  or  flowering, 
contained  a  similar  chemical.  Certainly,  it  was  there  one 
time,  but  it  was  not  there  at  other  times.  What  this  means  is 
not  clear. 

Many  dermatologists  in  Florida  believe  that  this  plant 
will  cross-react  with  poison  ivy  or  at  least  pnxluce  a  poison 
ivy-like  deimatitis  in  some  members  of  the  population. 


This  needs  to  be  conflrmed  in  an  animal  study,  but  it  may  not 
be  easy  to  do  if  the  chemical  content  of  the  plant  is  as 
variable,  as  has  been  reported.  The  plant  is  unquestionably 
a  major  problem  in  Florida  ecologically,  if  not  medically.  5 
terebinthifolius  is  much  less  allergenic  than  several  irritant 
species  found  in  Florida,  but  the  widespread  distribution  of 
this  plant  and  its  tendency  to  expand  its  territory  is  a  major 
worry,  particularly  for  individuals  living  and  working  in  this 
area. 

A  number  of  methods  of  plant  eradication  have  evolved 
in  the  recent  past,  including  burning,  which  tends  to  reduce 
the  number  of  colonies,  and  various  herbicides. 

Liverworts 

In  the  Pacific  Northwest  a  moss-Uke  plant  growing  on 
decaying  logs  causes  numerous  cases  of  allergic  skin 
eruptions.  Interestingly  it  contains  the  same  family  of 
chemicals  found  in  the  garden  Compositae  and  related 
weeds,  even  though  it  is  not  related  botanically.  This 
eruption  can  be  severe  in  woodcutters.  Some  species  of  diis 
family  are  so  allergenic  that  patch  testing  the  patient  can 
cause  the  allergy."  Feverfew  cross  reacts  with  frullania  as 
does  elecampane,  so  testing  to  those  plants  will  often  detect 
frullania  allergy.* 

Gmden  Compositae 

Many  species  of  garden  plants,  both  domesticated  and  wild, 
can  cause  the  same  type  of  rash.  Wild  plants  include 
bitterweed  (Helenium  amarum),  cocklebur  (Xanlhium 
subsp),  marshelder  (ha  xanthifolia),  dandelion  (Taraxacum 
officinale),  yarrow  (Achilles  millefolium),  etc.  Domesticat- 
ed (and  sometimes  wild)  plants  include  sunflower 
(Helianthus  annuus).  Chrysanthemum  subsp,  feverfew 
(Tanacetum  parthenium),  tansy  (Tanacetum  vulgare), 
Amica,  elecampane  (Irwla  helenium),  and  many  others. 
Unrelated  plants  causing  dermatitis  from  similar  chemicals 
include  magnolia,  laurel  and  a  liverwort,  frullania. 

Mayweed,  Anthemis  coiula,  can  cause  severe  irritant 
(and  sometimes  allergic)  reactions  in  farm  workers.  In  a 
recent  report  from  California,  O'Malley  and  Batba  " 
described  a  bhstering  eruption  in  42  farm  workers  that  had 
qualities  suggestive  of  a  nonalletgic  (irritant)  reaction.  The 
severity  paralleled  time  of  exposure,  and  covered  areas  were 
commonly  involved.  These  workers  had  been  employed 
pulling  weeds  in  a  beet  field.  The  causative  plant  has  a 
licorice-like  odor,  and  is  called  "dog  fennel"  or  stinkweed  as 
well  as  mayweed,  a  name  derived  from  the  usual  time  it 
blooms. 

The  progression  from  redness  at  19  hours  to  prominent 
lesions  at  two  days  and  blisters  at  six  days  might  suggest  an 
allergic  contact,  but  the  evidence  is  better  for  a  delayed 
irritant,  as  it  can  be  produced  in  volunteers  never  previously 


Proceedings  of  the  National  Coniqience  on  ENvntoNMENTAL  Hazards  to  ttie  Sion 


415 


exposed.  The  irrilanl  component  has  been  reported  to  be 
valeric  acid  (pentaenoic)  acid,  but  no  proof  is  given." 

Primuu  Dermatitis 

In  Europe,  where  poison  ivy.  oak  and  sumac  are  not  native, 
the  leading  cause  of  plant  dermatitis  may  be  caused  by 
primula  obconica,  the  German  primrose.  Is  this  relevant  to 
the  United  States?  Probably.  In  a  single  dermatologist's 
practice,  Epstein  "  recently  saw  nine  patients  with  primula 
dermatitis  in  the  San  Francisco  area  in  a  two-year  period. 

The  primrose  is  a  house  plant  in  most  of  the  United 
States,  as  it  requires  a  wanner  climate  to  survive  outdoors. 
The  plant  contains  a  chemical  called  primin,  and  in  those 
who  are  allergic  it  causes  a  patchy  rash  on  the  hands,  often 
with  streaks  of  vesicles  (watery  bumps),  and  a  rash  on  the 
face,  not  unlike  poison-ivy  dermatitis.  Milder  cases  can  be 
difficult  to  recognize.  The  usual  sufferer  is  an  older  woman 
with  house  plants.  In  the  San  Francisco  area.  Primula 
obconica  may  be  seen  growing  outdoors;  therefore,  working 
in  the  garden  is  sometimes  a  risk  factor.  So  many  persons 
in  Europe  develop  primula  reactions  that  dermatologists  at 
many  centers  routinely  test  for  allergy  to  it.  Overall  about 
\%  are  allergic.  "  but  over  2%  of  women  are  allergic."' 
Primin.  a  paraquinone  (the  same  type  chemical  found  in 
most  allergenic  woods),  is  a  stronger  sensitizer  than  similar 
plant  allergens.'*' 

iFIRfTATION  FROM  SpURGES  (EuPHORBIACEAE) 
Members  of  this  family  are  variously  affected  ecologically 
by  the  activities  of  humans.  The  manchineel  tree,  perhaps 
the  best  known  member,  is  decreased.  (At  least  its  numbers 
are  fewer  in  the  United  States.)  The  botanical  name  is 
Hippomane  mancinella,  which  means  "little  apple  that 
drives  horses  crazy."  The  latex  (sap)  released  from  injuries 
to  the  plant  cause  severe  irritation  to  the  skin,  often  with 
pain  and  blistering.  The  putative  individual  susceptibility 
has  not  been  adequately  investigated.  The  lore  of  this  plant 
is  extensive.  For  example,  native  Americans  repaid  the 
Spanish  conquerors  by  adding  a  few  branches  of  manchineel 
to  their  well  water.  Lord  Nelson  almost  died  from  being 
poisoned  by  the  natives  who  used  sap  from  manchineel  to 
poison  supplies  for  the  British  navy.  Although  the  pollen 
and  nectar  of  the  manchineel  are  not  toxic,  Selika,  the 
heroine  in  the  opera  "L'Africaine,"  supposedly  died  from 
inhaling  its  deadly  blossoms  on  Madagascar.  Unfortunate- 
ly, Madagascar  is  several  thousand  miles  distant  from  the 
nearest  machineel  tree,  but  it  nevertheless  made  for  a  good 
story.  The  irritant  material  in  the  latex  is  a  cocarcinogen, 
and  this  is  a  danger  to  those  exposed.  A  drop  of  the  latex  in 
the  eye  causes  excruciating  pain  and  blindness  for  about  a 
month.  Repeated  exposure  can  result  in  permanent  blind- 
ness. 


The  manchineel  is  related  to  a  number  of  plants  intro- 
duced to  the  house  or  yard,  including  the  candelabra  cactus. 
Euphorbia  lactea,  often  grown  as  a  hou.seplant,  the  monkey 
pencil  tree.  Euphorbia  tirucalli.  sometimes  grown  in 
warmer  climates  as  an  exotic,  and  many  others.  All  of  these 
plants  are  extremely  irritant. 

The  bull  nettle  is  not  a  nettle  but  comes  from  the  same 
family  as  the  manchineel.  It  inhabits  the  coastal  sands  over 
a  wide  range,  although  the  plant  taxonomy  changes  from  the 
Southeast  to  Texas  to  Mexico  and  beyond.  It  has  stickers 
with  irritant  hairs  that  can  cause  severe  pain.  The  nature  of 
the  irritant  remains  to  be  elucidated. 

NettuRash 

Nettles  are  increased  in  disturbed  areas;  some  are  alien 
species  introduced  into  this  country  many  years  ago.  The 
species  around  the  United  States  vary  with  the  geographic 
location,  but  the  mechanism  of  activity  is  probably  the 
same.  These  plants  cause  hives  (rather  than  an  eczematous 
eruption)  on  contact,  by  introducing  chemicals  into  the  skin 
through  tiny  stinging  hairs  on  the  siuface  which,  according 
to  Oliver,  et  al.  ■"  are  fine  tubes  with  a  bulb  at  the  tip.  The 
bulb  breaks  off  on  penetrating  the  skin,  releasing  the  fluid 
contents  into  the  skin.  Inflammatory  mediators  found  in 
these  hairs  include  histamine,  acetyl  choline,  *"  serotnin,  " 
leukotrienes,  *  and  a  mitogen  for  lymphocytes  through 
interleukin-1  and  receptor  production,  *''  perhaps  inducing  a 
lymphocytic  response.*  The  triad  of  mast  cell,  mast 
satellite  cell,  "  and  lymphocyte  was  noted  by  Goncalo." 

A  number  of  plants  cause  mechanical  irritation  and 
many  are  greatly  increased  in  areas  disturbed  by  man.  A 
good  example  is  blackberry  (Rubus  suhsp),  also  called 
brambles.  Some  cause  granulomatous  reactions,  as  seen  in 
sabra  dermatitis  from  Opuntia  microdasys  and  other  spe- 
cies."-" 

Another  form  of  irritation  occurs  in  plants  contain- 
ing calcium  oxalate,  such  as  dumb  cane  or  dieffenbachia 
Species  with  significant  levels  have  been  found  in  at  least 
215  plant  families."  Typical  reactions  occur  from 
diefTenbachia  and  Arisaema  (Jack-in-the-pulpit).  The  name 
"dumb  cane"  acknowledges  the  severe  lesions  in  the  mouth 
resulting  from  chewing  the  stem,  which  prevents  the  victim 
from  speakini.  Esophageal  erosions  can  occur  after  swal- 
lowing.'^ 

References 

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2.  Lx)nkar  A,  Nagasampagi  BA,  Narayanan  CR,  et  al.  An 
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Proceedings  of  the  Nattcnai  Conference  on  ENVlRONME^fTAL  Hazards  to  the  Skin 


416 


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4.  Towers  GHN,  Mitchell  JC.  The  cunent  status  of  the 
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5.  Lonkar  A.  Mitchell  JC,  Calnan  CD.  Contact  dermatitis 
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8.  Rao  PV,  Mangala  A,  Towers  GH.  et  al.  Immunological 
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9.  Sohi  AS,  et  al.  Allergenic  nature  of  Parthenium 
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10.  Pieman  J,  Pieman  AK.  Treatment  of  dermatitis  ftom 
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1 1.  Guin  JD.  Baker  GF,  Mitchell  JC.  Persistent  open  patch 
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12.  Srinivas  CR,  Balachandran  C,  Shenoi  SD,  et  al. 
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14.  Schmidt  RJ.  Compositae.  Clin  Dermatol  I986;4:46- 
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15.  Guin  JD,  Skidmore  G.  Compositae  dermatitis  in 
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16.  Frain-Bell  W.   Photosensitivity  and  Compositae 
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17.  Wrangsjo  K,  Ros  AM,  Wahlberg  JE.  Contact  allergy  to 
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1 8.  Ducombs  G,  Benezra  C,  Talaga  P,  el  al.  Patch  testing 
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19.  Guin  JD.  Plant  dermatitis  in  handbook  of  contact 
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21.  Guin  JD.  Sesquterpene-lactone  dermatitis.  Immi>nol 
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22.  Guin  JD,  Schosser  RH,  Rosenberg  EW.  Magnolia 
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23.  Shelmire  B.  Contact  dermatitis  from  vegetation. 
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24.  Howell  JB.  Sensitivity  to  common  weeds.  Contact 
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25.  Hjorth  N,  Roed-Petersen  J,  Thomsen  K.  Airbome 
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26.  Mitchell  JC.  Fisher  AA.  Dermatitis  due  to  plants  and 
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27.  Lonkar  A.  "Destroy  Parthenium"  campaign.  Contact 
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28.  Workman  RW.  History  of  Schinus  in  Florida.  In: 
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29.  Mack  RN.  The  commercial  seed  trade,  an  eariy  dispers- 
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30.  Morton  JF.  Plants  poisonous  to  people  in  Florida  and 
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31.  Skopp  G,  Opferkuch  HJ,  SchwenkerG.  N-alkylphenols 
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32.  Stahl  E,  Keller  K,  BUnn  C.  Cardanol  is  an  irritant  in 
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33.  Mytinger  L,  WiUiamson  GB.  The  invasion  of  Schinus 
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35.  Goncalo  S.  Occupational  contact  dermatitis  to  Frullania. 
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43.  OUver  F,  Amon  EU,  Breathnach  A,  et  al.  Contact 
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45.  Collier  HOJ,  Chesher  GB.  Identification  of  5-hydrox- 
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46.  Czametzki  BM,  Thiele  T,  Rosenbach  T.  Immunoieac- 
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47.  Le  Moal  MA,  Truffa-Bachi  P.  Urtica  dioica  agglutinin, 
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48.  Wagner  H,  Wilier  F,  Kreher  B.  Biologically  active 
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49.  Breathnach  AS.  Development  and  differentiation  of 
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Prociedincs  of  the  National  T" 


J  F*AfiBrwMwrAi  Hazards  to  the  Skjn 


418 


Tropical  and  Temperate  Plant  Contact  Allergens 

Eloy  Rodriguez,  Ph.D. 


Allergic  contact  dennatitis  (ACD)  is  considered  to  be  the 
result  of  reaction  between  a  reactive  low  molecular  weight 
compound  (a  hapten)  and  a  protein  present  in  the  skin.  This 
combination  of  the  skin  protein  and  plant  product  will  result 
in  the  formation  of  a  novel  molecular  sinicture  not  recog- 
nized by  the  body's  inunune  system.'  The  immune  system 
will  attempt  to  eliminate  this  novel  protein  hapten  combina- 
tion through  the  inflammation  responses  it  has  developed  to 
eliminate  the  foreign  proteins  of  bacteria,  or  other  infectious 
disease-causing  organisms.  These  defensive  reactions  cause 
the  swelling,  itching,  and  redness  associated  with  ACD. 
Prolonged  interaction  between  the  lymphocytes  of  the 
immune  system  will  ultimately  result  in  pus-filled  vesicles 
that  characterize  severe  allergic  response. 

The  types  of  plant  chemicals  that  cause  ACD  share 
several  characteristics:^ 

1)  They  are  comparatively  small  Oow  molecular  weight). 

2)  They  are  lipophilic  (soluble  in  fats  or  lipids),  which 
facilitates  penetration  of  the  skin. 

3)  They  are  extremely  reactive  chemicals  that  combine 
easily  with  skin  proteins. 

The  fact  that  the  reactions  of  ACD  require  mediation  by 
the  immune  system  is  made  evident  by  the  delay  (generally 
12-72  hours)  required  for  the  symptoms  to  occur.'  This 
delay  is  contrasted  with  the  more  immediate  reactions  of 
irritant  compounds  that  do  not  require  processing  by  the 
immune  system.  These  irritant  compounds  can  be  found  in 
many  species  of  the  Euphorbiaceae,  Brassicaceae,  and 
Ranimculaceae.' 

The  family  of  plants  that  cause  the  greatest  number  of 
cases  of  ACD  is  the  Anacardiaceae,  a  predominantly 
tropical  family  with  a  few  members  in  the  temperate  regions 
(poison  ivy,  poison  oak,  and  poison  sumac).  The  genera  of 
the  Anacardiaceae  reported  to  cause  allergies  are  given  in 
Table  1.'  The  chemical  compounds  that  cause  the 
allergenicity  of  this  family  are  a  series  of  phenoUc  com- 
pounds (Figure  1 )  with  an  attached  side  hydrocarbon  chain 
or  alkyl  group.  PhenoUc  compoimds  with  two  adjacent 
hydroxy  groups  are  termed  alkyl  catechols  -  (Structures  A 
and  B).  Phenolic  compounds  with  a  single  hydroxy  group 
are  termed  simple  alkyl  phenoUcs  (compound  type  C). 
Phenolic  compounds  with  two  hydroxyl  groups  that  are 
separate  are  termed  alkyl  resorcinols  (compounds  D  and  E). 
A  phenoUc  compound  with  an  acidic  catboxyl  group  is 
termed  anacardic  acid  (compound  F). 

The  alkyl  catechols  are  strong  irritants  and  strong 


allergens.  The  allergenic  constituents  in  poison  ivy  and 
poison  oak  are  catechols  with  alkyl  side  chains  with  15  or 
17  carbons,  respectively  (Figures  2,  3).'  Most  of  the  genera 
of  the  Anacardiaceae  that  have  been  reported  to  be  allergen- 
ic contain  alkyl  catechols  (see  Table  II).' 

Alkyl  resorcinols,  simple  alkyl  phenoUcs,  and  anacardic 
acid  type  compounds  are  also  highly  reactive  chemicals  and 
strong  irritants.  However,  they  are  responsible  for  a  much 
smaUer  number  of  cases  of  ACD  than  the  alkyl  catechols 
found  in  poison  ivy.  Still,  the  aUcyl  resorcinols  do  present  a 
significant  problem  stimulating  cross-reactions  in  people 
who  are  allergic  to  the  aUcyl  catechols.  There  apparently  is 
enough  similarity  in  structure  to  stimulate  the  immime 
system  of  many  people  who  are  allergic  to  the  alkyl  cate- 
chols. These  cross  reactions  with  the  aUcyl  resorcinols 
explain  the  allergic  responses  of  many  traveUers  to  tropical 
fruits  such  as  mangoes,  or  the  fruit  of  cashew  trees.  Alkyl 
resorcinols  can  also  be  found  in  other  groups  of  plants  that 
occasionally  cause  problems  in  people  who  are  allergic  to 
poison  ivy.*  These  plants  include  members  of  the 
Proteaceae,  a  tropical  plant  family  that  includes  the 
macademia  nuts  and  various  ornamentals  such  as  Banksia. 
Many  tourists  who  go  to  Hawaii  get  a  severe  ACD  from  the 
leis  (flower  garlands)  that  include  flowers  of  Grevillea 
subsp.'' 

Another  tropical  plant  family,  the  Araceae,  contains 
alkyl  resorcinols  that  cross  react  with  the  aUcyl  catechols. 
The  common  omamental  tropical  foliage  plants  from  the 
genera  Philodendron,  Dieffenbachia,  Spathiphyllum, 
Colocasia,  and  Caladium  are  all  members  of  this  family. 
These  particular  plants  are  the  most  common  decorative 
plants  found  in  restaurants  and  doctors'  offices.'"" 

ONA  Damage  from  Contact  Sensitizers 

Recent  research  has  revealed  disturbing  evidence  about 
the  aUcyl  catechols  and  alkyl  resorcinols.  In  vitro  studies 
have  estabUshed  that  these  chemicals  will  cut  DNA  in  the 
presence  of  a  metal  catalyst.'^  Damage  to  DNA  could  result 
in  irreversible  damage  to  the  ceUs"  genetic  machinery  and 
could  ultimately  lead  to  skin  cancer  (Figure  3).  It  appears 
that  the  semiquinone  radical  wiU  break  the  sugar  phosphate 
bonds  that  form  the  backbone  of  the  DNA  molecule.  The 
author's  laboratory  is  following  up  on  this  important 
research  to  discover  the  full  significance  of  this  threat  to  the 
skin.  If  these  alkyl  resorcinols  and  aUcyl  catechols  do  pose  a 
serious  threat  to  the  DNA  of  skin  cells,  it  will  stimulate  new 
ideas  about  the  role  of  ACD.  It  is  possible  that  ACD  is  a 


Proceedings  of  the  National  Conference  on  Environmental  Hazards  to  ive  Skin 


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419 


response  of  the  immune  system  to  rid  the  skin  of  dangerous 
chemicals  that  threaten  the  DNA  of  the  body."  Chemical 
combinations  between  skin  proteins  and  particularly  danger- 
ous chemical  haptens  could  be  recognized  by  the  immune 
system,  which  would  then  dispose  of  the  threatening 
chemicals  in  the  fastest  and  most  effective  manner  possible. 
In  other  words,  the  symptoms  associated  with  ACD  are  the 
results  of  attempts  of  the  immune  system  to  destroy  any 
hapten  protein  combination  or  cell  contaminated  with  these 
dangerous  DNA-threatening  chemicals. 

To  follow  up  and  further  evaluate  the  threat  to  skin 
DNA  posed  by  the  chemicals  that  cause  ACD,  we  tested 
other  allergens  for  their  capacity  to  damage  DNA.  The 
allergenic  prenylated  hydroquinones  from  the  plant  family 
Hydrophylaceae  have  many  chemical  similarities  to  the 
alkyl  catechols  and  alkyl  resorcinols.  In  vitro  tests  have 
established  that  prenylated  hydroquinones  will  also  cleave 
DNA  under  similar  conditions  and  consequently  pose 
threats  to  the  DNA  of  the  skin  cells.''"' 

Another  important  group  of  chemicals  that  cause  many 
cases  of  ACD  around  the  world  is  the  sesquiterpene  lac- 
tones." These  chemicals  are  found  in  several  plant  families, 
such  as  Magnoliaceae  (the  Magnolia  family),  Apiaceae  (the 
carrot  family),  and  the  very  large  Asteraceae  (sunflower 
family).  The  initial  perusal  of  the  structure  indicates  few 
similarities  between  the  sesquiterpene  lactones  and  the 
alkylated  phenolics.  However,  in  vitro  experiments  indicate 
that  the  sesquiterpene  lactones  also  damage  DNA  by 
breaking  the  sugar  and  phosphate  bonds." 

This  capacity  to  damage  DNA  is  not  a  characteristic  of 
all  contact  allergens,  since  other  experiments  have  shown 
that  allergenic  polyacetylenic  compounds  (a  minor  class  of 
contact  allergens)  do  not  damage  DNA."  "  However,  the 
fact  that  the  three  most  common  and  conspicuous  causes  of 
ACD  do  damage  DNA  should  cause  us  to  investigate  this 
question  more  seriously.  The  suggestion  that  the  allergic 
response  is  a  defense  against  the  small  molecules  that 
threaten  DNA  should  not  be  dismissed  too  easily  as  an 
overly  facile  explanation.  Research  at  the  author's  laborato- 
ry will  continue  to  assess  the  threat  posed  by  the  identified 
allergens  and  any  new  allergens  isolated  from  previously 
investigated  plants.  Several  examples  of  plant  allergens  that 
are  less  notorious  can  be  investigated.  Numerous  cases  of 
ACD  have  been  reported  from  carpenters,  cabinet-makers, 
and  sawmill  employees  who  work  with  wood  from  tropical 
trees."  Others  coming  in  contact  with  these  trees  undoubt- 
edly suffer  from  ACD;  however,  these  people  live  in  the 
remote  areas  of  underdeveloped  tropical  countries  and  have 
little  contact  with  doctors.  Paralecunda,  Jacaranda, 
Tabebuia  from  the  Bignoniaceae  and  Tectona  from  the 
Verbenaceae  contain  quinones  such  as  lapachonone  and 
lapachol  that  cause  problems. '^  Other  cases  of  ACD  are 


caused  by  quinones  from  several  species  in  the  legume 
family.  These  include  bowdichione  from  Bowdichia  and 
the  melhoxydalbergione  from  several  species  of  Dalbcrgia, 
and  Machaerium.  Other  cases  of  ACD  have  occuned  with 
workers  in  furniture  factories  that  use  wood  from  species  of 
Khaya.  From  the  Meliaceae,  anthothecol,  a  triterpenoid, 
was  identified  as  the  hapten.  Chlorophora  from  the 
Moraceae  contains  phenolics  that  cause  outbteaks  of  ACD, 
and  Mansonia  from  the  Sterculiaceae  contains  mansonons, 
orthoquinones  that  cause  many  cases  of  ACD.  In  vitro 
experiments  will  be  conducted  to  investigate  the  potential  of 
these  compounds  to  damage  DNA. 

There  are  many  other  examples  of  plants  that  cause 
ACD  in  which  the  hapten  has  not  been  identified.  Prelimi- 
nary work  with  Asimina  of  the  Annonaceae  indicated  that 
unidentified  acetogenins  from  this  family  are  potential 
sensitizers.-"  Reports  that  another  plant  from  ihe 
Annonaceae,  Ylang  Ylang  (Caiumga  adoraium),  causes 
ACD  are  widespread  and  resulted  in  its  removal  from  many 
cosmetics.  Future  research  should  be  conducted  to  identify 
the  allergenic  principles  of  these  plants  and  to  evaluate  the 
threat  that  these  compounds  might  pose  to  the  DNA  of 
human  skin. 

References 

1 .  Von  Blombeig  BME,  Bruynzeel  DP,  Scheper  RJ. 
Advances  in  mechanisms  of  allergenic  contact 
dermatitis:  in  vitro  and  in  vivo  Research.  In:  MarzuUi 
FN,  Maibach  HI,  eds.,  Dermatotoxicology.  New  York: 
Hemisphere,   1991. 

2.  Lampe  KF.  Toxic  effects  of  plant  toxins.  In:  Klassen, 
CD,  Andur  MO,  DouU  J,  eds.  Toxicology.  New  York, 
Macmillan,  1980. 

3.  Baer  RL,  Berman  B.  Role  of  Langerhans  cells  in 
cutaneous  inununological  reactions.  In:  Safai  B,  Good 
RA,  eds.  Immunodermatology.  New  York;Plenum 
Publishing,  1981. 

4.  Evans  FJ,  Schimdt  RJ.  Plant  and  plant  products  thai 
induce  contact  dermatitis.  Planta  Medica  1980:386:289- 
316. 

5.  Mitchell  JD.  Poisonous  Anacardiaceae.  Advances  in 
Economic  Botany  1990;8:103. 

6.  Gross  M,  Baer  H,  Fales  HM.  Urushiols  of  poisonous 
Anacardiaceae  phytochemistry,  1975;14:263-266. 

7.  Corbett  MD,  Billets  S.  Characterization  of  poison  oak 
urushiol.  Journal  of  Pharmaceutical  Science 
1975;64:17I5. 

8.  Epstein  WL:  The  poison  ivy  picker  of  Pennypack  Park: 
The  continuing  saga  of  poison  ivy.  Journal  of  Investiga- 
tive Dermatology  1987;88:7s-lls. 


SO 


PSOCEEDINGS  OP  THE  NATIONAL  CONFERBd  ON  ENVmONMENTAL  HAZARDS  TO  T«E  SKIN 


420 


9.  Mitchell  JC,  Rook  A.  Botanical  ermatology:  Plants  and 
plants  products  injurious  to  the  skin. 
VancouverGreengrass,  1979. 

10.  Hammershoy  O,  Verdich  J.  Allergenic  contact 
dermatitis  from  Philodendron  scandens.  Contact 
Dermatitis  1980;6:95-98. 

11.  Reffstnip  T,  Boll  PM.  Allergenic  5-alkyl  and  5-alkenyl 
resorcinols  from  Philodendron  species.  Phytochemistry 
1985;24:2563-2565. 

12.  Wasser  C,  Silva  F,  Rodriguez  E.  Urushiol  components 
as  mediators  in  DNA  strand  scission.  Experientia 
1990;46:500-502. 

13.  Profet  M:  The  function  of  allergy-immunological 
defense  against  toxins.  Quarterly  Review  of  Biology 
1991;66:23-62. 

14.  Reynolds  G,  Epstein  W,  Terry  D,  et  al.  A  potent 
contact  allergen  from  Phaceha  (Hydrophyllaceae). 
Contact  Dermatitis  1980,6:272-274. 


15.  Aregullin  M,  Rodriguez  E.  UnpubUshed  laboratory 
experiments. 

16.  Rodriguez  E,  Epstein  WL,  Mitchell  JC.  The  role  of 
sesqiuteipene  lactones  in  contact  hypersensitivity  to 
some  North  and  South  American  species  of  feverfew 
(Parthenium-Compositae).  Contact  Dermatitis 
1977;3:155-162. 

17.  Gafher  F,  Epstein  W,  Reynolds  G,  et  al.  Human 
maximization  test  of  falcarinol,  the  principle  contact 
allergen  of  English  ivy  and  Algerian  ivy  (Hedera  helix, 
H.  canariensis).  Contact  Dermatitis  1988;19:125-128. 

18.  Woods  B,  Calnun  CD.  Toxic  Woods.  Brit  J  Derm 
1976;95:1-97. 

19.  Benezra  C.  Plant  contact  dermatitis.  St.  Louis:Mosby, 
1985. 

20.  Avalos  J,  Rupprecht  JK,  McLaughlin  JL,  et  al.  Guinea 
pig  maxirrtization  test  of  Paw  Paw,  Asimina  triloba 
(Annonaceae).  Contact  Dermatitis.  1993;28:1-3. 


Table  I 

Poisonous  Anacardiacae  of  The  United  States, 
West  Indies,  Mexico  and  Central  America 


Anacardiutn 

Campospenna 

Mangifgra 

Cotinus 

Spondias 

Comocladia 

Toxicodendnim 

Schinus 

Mauria 

Astronium 

Uetopium 

Pseudosmodingium 

Toxicodendnjm 


J.O.  Mitclietl.  Advances  in  Economic  Bolanut,  103  (1990) 


Table  II 

Principal  Allergenic  Chemistry 
of  Poisonous  Plants 

Pentadecyl-Catechols 
Gluta 
Holigarna 
Lithraa 
Uetopitum 
Semecarpus 
SmotSngium 
Toxicodendron 

Heptadecyl-catechols 
Gluta 
Lilhrea 
Uetopium 
Semecarpus 
Toxicodendnjm 

Pentadecyl-resordnols 
Anacardium  ocddentale 

Heptadecyl-resorcinols 
Uangitera  indica 

Salicylic  Add  Derivatives  (anacardic  add,  etc 
Anacardium  ocddentale 
Pentaspadon  subsp. 

Pentadecyl -phenols 
Anacardium  ocddentale 

Quinols 
Campnosperma  auriculatum 

J.D  Mttchel  AdvancBS  in  Economic  Bolam/B.  103.  199t 


ntOCSnNGS  OP  THE  NaTIWML  CoNigiENCS  ON  ENVUtONMENTAt  HAZARDS  TO  IKE  SlON 


421 


Principal  Chemistry  of  Allergens 


FAitaeaidIc  Add 


Figure  1 


Allergenicity  of  3-lieptadecylcatechols 


ToxicodBndmn  dversHobum .  Anacardiacaae 


H*ptadacalrtenylcat«cho< 


Hgure3 


Allergenicity  of  3-pentadecylcatechols 


ToMicxxtendmn  ractcans.  Anacardlaceae 


Figure  2 


Pentadecatrienylcatechol 


Proceedings  of  the  Nattonai  '^'T«reBP>jrF  on  ENvntoNMEKTAL  Hazards  to  toe  Skin 


422 


Marine  Eruptions 

Joseph  W.  Burnett,  M.D. 


Introduction 

Water  covers  three-quarters  of  the  earth's  surface  and  is 
distributed  over  many  climates  containing  diverse  animal 
species,  which  are  arranged  in  progressive  food  chains.  The 
earth's  aquatic  area  should  not  be  regarded  as  a  simple 
system,  but  rather  as  a  dynamic,  multiphased  environment 
with  diverse  specific  events  occurring  at  the  surface  and  at 
various  depths.  Indeed,  other  ecological  alterations  can 
determine  saline  content,  temperature,  currents  and  wind 
forces.  The  most  superficial  film  surface  exposed  to  the 
earth's  atmosphere  is  a  "microcosm"  of  its  own.  The 
interaction  of  living  organisms,  water,  and  air  is  in  constant, 
delicate  balance  and  flux.  Alterations  in  the  shoreland  affect 
sedimentation  runoff,  integrity  of  the  benthic  layers,  and  the 
entrapment  of  solar  energy  within  the  aquatic  phase.  This 
dynamic  environment  can  be  accidentally  or  dramatically 
affected  by  human  pollution,  especially  since  humans  can 
contaminate  water  because  of  an  "out  of  sight,  out  of  mind" 
philosophy. 

Scientific  Background 

Many  factors  in  the  marine  environment  affect  human  skin 
structure  and  function.  Acute  ultraviolet  Ught  exposure 
produces  erythema,  increased  cutaneous  blood  supply,  and 
rupture  of  the  epidermal  barrier,  and  is  known  to  promote 
radiation-induced  diseases.  Venoms  ftom  marine  animals 
can  produce  a  spectrum  of  diseases  that  primarily  involve 
the  skin  but  may  be  accompanied  by  immediate  or  delayed 
constitutional  or  systemic  problems.   Marine  envenomations 
occurring  worldwide  are  caused  by  a  multitude  of  different 
stinging  animals  and  are  extremely  conmion.  [Xiring 
Christmas  week,  1990,  approximately  100,000  Portuguese 
man-of-war  stings  were  experienced  in  the  two  counties 
closest  to  Miami.  It  is  estimated  that  approximately  one 
half  to  one  milUon  envenomations  occur  annually  in  the 
Giesapeake  Bay  from  a  single  animal.  At  least  four  human 
fatalities  from  Jellyfish  stings  have  occuned  in  the  continen- 
tal United  States  in  the  past  twenty-five  years. 

Bacterial-induced  disorders  in  hunuin  skin  can  occur 
following  hematogenous  dissemination  or  local  inoculation 
during  bathing.  Vibrio  and  mycobaterial  infections,  as  well 
as  bacterial  folliculitis,  afflia  bathers  at  American  beaches. 
Algal  blooms  result  in  disruption  of  marine  organisms  into 
the  air,  where  they  release  toxins  into  the  environmenL 
These  agents  cause  irritation  of  mucosa  as  well  as  the 
central  body.  Protozoa  and  itiunature  larval  forms  of 
hydroids  induce  "swimmers'  itch"  and  "swimmers'  erup- 


tion," respectively.  Small  Crustacea  can  produce 
cymothodism.  Parasitic  or  viral  diseases  can  be  spread 
between  persons  through  aquatic  media  by  contact  with 
polluted  efnuents,  or  even  proximity  to  nearby  swimmers. 
Increased  deposits  of  both  chemical  and  physical  pollutants 
can  produce  mechanical  injury  to  the  skin,  as  well  as  serious 
exterruil  and  internal  diseases.  Seafood  ingestion  is  thought 
to  cause  human  disease  in  approximately  0. 1  %  of  fish 
meals.  These  diseases  may  be  induced  by  bacteria  or 
toxins,  the  concentration  of  which  in  the  fish  can  be  in- 
creased as  a  consequence  of  their  feeding  period.  Mollusks, 
which  transmit  hiunan  disease,  can  carry  large  amounts  of 
pathogens  or  toxic  material  as  a  consequence  of  their  filter- 
feeding  practices. 

The  hazards  of  these  di.sorders  to  humans  and  their  skin 
is  increased  by  secondary  factors,  such  as  environmental 
climate.  Additionally,  climate  and  solar  irradiation  directly 
influence  the  protective  effect  of  the  skin's  mechanical 
barrier  and  the  immune  system.  Also,  the  genetics  of  the 
host  and  the  effect  of  and  current  medications  may  adverse- 
ly affect  the  patient's  ability  to  ward  off  marine-induced 
disorders. 

In  onler  to  understand  the  environmental  hazards  to  the 
skin  we  must  increase  our  knowledge  of  the  effect  upon 
marine  ecology  of  water  climate,  which  may  be  associated 
with  global  warming,  nuclear  power  plant  cooling,  and  solar 
energy  absorption  in  the  water  layer. 

Rainfall  deletion  effects  appeared  in  the  ecology  of  the 
Chesapeake  Bay,  1972,  following  Hurricane  Agnes,  result- 
ing in  a  decreased  population  of  crabs  and  jellyfish.  During 
that  particular  storm,  the  saline  content  of  the  90-foot 
charmel  under  the  Bay  Bridge  dropped  from  1.2%  to  zero. 
Eutrophication  of  large  marine  bodies,  as  well  as  lakes,  has 
affected  our  country  along  the  coastlines  and  in  the  northern 
Midwest  Water  bodies  afflicted  with  this  problem  show 
altered  pholoplankton  and  bacterial  contents.  Consequent 
changes  in  the  food  chain,  the  quantity  and  quality  of  fish, 
and  the  presence  of  dinoflagellate  toxins  released  to  the  air 
were  noted.  Increased  sedimentation  occurring  after  storms 
and  resulting  from  highway  construction  and  agricultural 
practices  is  a  significant  problem  in  the  upper  Chesapeake 
Bay  and  other  areas.  Sedimentation  within  the  water  alters 
the  solar  energy  absorption  and  changes  the  phototropic 
response  of  marine  animals.  Acid  rain  has  polluted  the 
northern  portions  of  our  country  for  several  decades, 
resulting  in  demonstrated  alterations  in  the  fish  and  un- 
known alterations  in  other  marine  organisms. 


PROraEMNGS  Of  niE  NaTIONAI.  CotfifXENCE  ON  ENVIRONMEIfrAL  HAZARDS  TO  THE  ShN 


423 


Industrial  effluenu  and  pesticides  can  be  concentrated  in 
many  marine  animals.  Investigators  studied  the  effect  of 
pesticides  in  the  Chesapeake  Bay  upon  jellyfish  and  found 
that  these  venomous  animals  could  concentrate  chemicals 
and  be  used  as  early  warning  detection  systems  for  in- 
creased adverse  chemical  concentrations.  The  increased 
presence  of  sediment,  chemicals,  industrial  pollution,  and 
alterations  in  the  pH  can  affect  larval  settling,  early  repro- 
duction, and  growths  of  several  animals.  Ozone  depiction 
and/or  global  warming,  if  real,  will  dramatically  affect  the 
marine  environment  with  alterations  in  both  marine  life  and 
their  environmental  hazards.  The  role  of  ultraviolet  energy 
on  human  cutaneous  immunological  integrity  is  of  current 
interest  of  many  dermatologists.  It  is  quite  possible  that 
ultraviolet  light-induced  cutaneous  immunosuppression  may 
play  an  additive  or  synergistic  role  in  human  response  to 
marine-induced  rashes.  The  investigators  have  shown  that 
jellyfish  envenomation  may  cause  significant  acute  immun- 
osuppression and  have  speculated  upon  an  additive  effect  of 
sunhght  on  this  abnormality. 

Economic  Loss 

The  economic  loss  resulting  fiom  marine-induced  eruptions 
is  vast.  It  must  be  calculated  in  terms  of  loss  of  work  time, 
deterioration  of  specific  industries,  depressed  seashore 
property  values  and  consequent  tax  loss,  loss  of  recreation 
and  resort  usage,  and  soil  erosion.  The  exact  cost  is  difficult 
to  determine,  because  most  of  the  eruptions  and  disorders 
associated  with  the  marine  environment  are  entities  produc- 
ing low  mortality  but  high  acute  morbidity.  Because  of  the 
transient  nature  of  the  resulting  disorders,  exact  case 
incidence  figures  are  impossible  to  record. 

Future  Research  Needs 

Future  research  Is  needed  to  better  delineate  the  methods  by 
which  humans  can  be  injured  by  the  varied  venoms  and 
toxins  within  marine  animals.  There  should  be  an  increased 
effort  to  quantitate  the  ultraviolet  and  thermal  alterations 
affecting  the  marine  environment  as  well  as  humans. 
Second,  the  degree  of  human  immunosuppression  induced 
by  ultraviolet  light  and  marine  envenomation  singly  or 
synergistically  needs  quantification.  Third,  increased  efforts 
to  understand  the  effect  of  sedimentation,  agricultural 
runoff,  and  industrial  pollutants  upon  the  reproductive 
stages  of  venomous  or  edible  marine  life  should  be  institut- 
ed. Finally,  efforts  should  be  designed  to  study  the  means 
by  which  physical  or  mechanical  control  procedures  can  be 
exerted  to  prevent  these  disorders.  Such  procedures  could 
be  instituted  at  the  shoreline,  at  sewage  effluent  sites,  at 
resort  areas,  and  at  the  sites  of  industrial  production  at  the 
water's  edge. 

The  primary  research  priority  on  the  cutaneous  pathoge- 
nicity of  marine  environmental  hazarxls  should  be  the 


quantification  of  the  extent  of  ozone  depletion  effect  and 
global  warming.  The  control  of  bacterial  or  physical 
material  dumped  into  the  sea  should  be  of  high  priority, 
since  it  may  be  an  easier  matter  to  control. 

Educational  Needs 

Increased  education  of  the  public  as  well  as  the  medical 
profession  should  be  a  primary  aim.  Beachside  advertising 
and  warnings  have  been  helpful  m  Australia  and  should  be 
increased  in  America.  Increased  public  awareness  will 
follow  as  increased  communication  within  our  society 
(Kcurs.  The  American  news  media  already  does  an  excel- 
lent job  of  reporting  many  of  the  factors  in  major  newspaper 
articles,  lay  journals,  talk  shows,  and  local  television  clips. 
Many  physicians,  particularly  dermatologists  at  beachside 
areas,  are  aware  of  local  marine-induced  disea.ses.  Nonethe- 
less, there  is  a  considerable  lack  of  expertise  in  this  field 
among  medical  specialists.  The  advocacy  g:oups  intere.sted 
in  this  environmental  problem  comprise  environmental 
preservation  groups  and  industrial  societies.  There  are  no 
appropriate  advocacy  groups  composed  of  patients  with 
activities  directed  toward  medical  treatment  and  prevention 
in  this  regard.  Thus,  the  allies  in  this  area  would  be  groups 
such  as  the  United  States  Life  Guard  Association,  the 
California  Surf  Riders  Association,  the  Sierra  Club, 
Greenpeace,  hotel  and  resort  associations,  beach  operator 
societies,  and  municipahties  having  beachfront  activities. 

Legislative  Examples 

-Past  examples  of  successful  legislation  enacted  in  this  area 
include  numerous  conservation  proposals  for  beachside 
erosion  and  seafood  quality.  Legislation  to  affect  venomous 
marine  animals  includes  the  Garmatz  Jellyfish  Control  Act 
passed  in  the  late  1960s  in  the  United  States  Congress,  and 
the  Jellyfish  Action  Plan  instituted  by  the  UN  Environmen- 
tal Control  Program  for  the  Mediterranean  passed  in  the 
1980s.  These  two  programs  illustrate  the  possibihiy  of 
interaction  of  public  agencies  between  various  countries  arid 
various  states  within  a  single  country  in  order  to  produce 
both  funding  and  policing  of  environmental  goals. 

References 

1 .  Worrest  RC,  Grant  LD.  Effects  of  ultraviolet-B  radia- 
tion on  terrestrial  plants  and  marine  organisms.  In: 
Ozone  Depletion:  Health  &  Environmental  Conse- 
quences. Jones  RR,  Wigley  T,  eds.  Wiley  &  Sons, 
Ltd,  1989. 

2.  Kalkstein  LS,  Giannini  SH.  Global  wanning  and  human 
health:  does  a  teal  threat  exist?  New  Biologist 
1991;3:727-728. 

3.  Sarokin  D,  Shulkin  J.  The  role  of  poUudon  in  large 
scale  population  disturbances.  Environmental  Sci  & 
Tech  1992;26:1476-1484. 


54 


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Ozon*  daplttion 
-    Stratoftph«ric 


]> 


Incrcostd 
ullroviolet-8 


Flooding 

Sonitotion 


Ozone  mere  est 
-  Troposphere 


Core  i  no  gen  ta  it 
Cataracts 


Figure  1 

The  effects  of  atmospheric  CFCs  on  global  warming  and  ozone  depletion  and  their  subsequent 
effects  on  man  (see  reference  1). 


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Dermatology  and  the  Environment 

Neal  S.  Penneys,  M.D.,  Ph.D. 


Most  of  us  do  not  appreciate  the  remarkable  way  our  skin 
protects  us  from  the  random  acquisition  of  an  endless  array 
of  infectious  agents.  Because  of  the  skin's  tough  exterior,  it 
represents  an  uncommon  portal  for  entry  of  serious  infec- 
tious processes  in  healthy  persons.  All  of  us.  however,  have 
suffered  the  superficial  bacterial,  viral  and  fungal  infections 
that  can  follow  disruption  of  the  external  layers  of  the  skin. 
Many  of  the  infections  described  below  can  be  acquired 
globally,  at  work  or  at  play,  but  are  classified  in  the  area 
where  they  are  most  often  encountered. 

Infections  Acquired  in  the  Woilcptace 

In  general,  the  majority  of  cutaneous  infections  acquired  in 
the  workplace  follow  some  form  of  traumatic  disruption  of 
the  skin  that  permits  entry  of  the  pathogen.  Characteristic 
risks  are  associated  with  certain  work  activities.  For 
example,  gardeners  who  work  with  thomed  plants  or  who 
do  potting  with  sphagnum  moss  are  at  risk  for  infection  by 
sporotrichosis,  a  fungal  disease  that  produces  characteristic 
linear  spread.  Following  inoculation,  the  primary  infection 
develops  slowly,  usually  as  a  cratered  sore  on  the  finger  or 
extremity.  After  a  period  of  time,  this  fiingal  infection 
spreads  through  the  regional  lymphatics,  prxxlucing  a 
characteristic  linear  array  of  nodules  progressing  centrally. 
Once  recognized,  treatment  is  relatively  simple,  using 
systemic  antifungal  medications.  Gardeners  and  others  who 
work  in  relatively  unclean  situations  associated  with  risk  of 
trauma  can  also  acquire  a  variety  of  cortunon  superficial 
bacterial  infections  following  cutaneous  disruption. 

Characteristic  cutaneous  infections  can  also  follow 
contact  with  animals  or  fish.  Dairy  workers  acquire  a  form 
of  pox  virus  known  as  "milker's  nodules"  on  their  hands, 
after  contact  with  infected  udders.  Sheep  handler's  can 
develop  a  similar  affliction  known  as  "orf."  These  infec- 
tions are  cUnically  characteristic  and  self-limited.  These 
examples  represent  a  small  sample  of  the  most  recogrjzable 
and  clinically  characteristic  infections  acquired  at  work;  the 
list  of  possible  infections  is  as  diverse  as  is  the  array  of 
work  environments. 

Infections  Acquired  During  Leisure  Activities 

A  wide  spectrum  of  infections  can  be  acquired  at  leisure. 
One  of  the  most  well-known  is  the  tick-bome  Lyme  disease. 
This  is  a  potentially  serious  systemic  infection  acquired 
through  a  tick  vector.  During  feeding,  the  tick  transmits  the 
agent,  a  spirochete,  that  causes  Lyme  disease.  The  tick  is 
quite  small  and  easily  missed.  Children  playing  in  wooded 


areas  and  hikers  are  at  significant  risk  of  exposure  to  the  tick 
in  certain  regions  of  the  United  States  at  certain  times  of  the 
year.  Once  implanted,  inoculation  of  the  spirochete  produc- 
es a  characteristic  skin  lesion  known  as  erythema  chronicum 
migrans.  Early  recognition  of  the  lesion  leads  to  appropriate 
therapy,  before  more  advanced  stages  of  Lyme  disease 
ensue.  A  second  tick-bom  serious  systemic  infection 
acquired  through  the  skin  is  Rocky  Mountain  spotted  fever. 
Once  the  agent  gains  entry,  a  complicated  series  of  symp- 
toms follows;  a  characteristic  skin  rash  frequently  permits 
early  diagnosis  and  therapy.  Rocky  Moimtain  spotted  fever 
can  be  fatal  if  not  recognized  and  treated  expeditiously. 

Other  classes  of  infective  agents  are  acquired  during 
leisure  activities.  Certain  types  of  infection,  primarily 
atypical  mycobacteriiun,  can  be  inoculated  through  the  skin 
fh)m  brackish  water.  Persons  who  have  and  maintain 
aquariums  or  boats  are  at  risk  for  these  infections.  The 
initial  lesion  is  similar  to  that  of  sporotrichosis,  in  that  a 
nodule  is  formed  with  a  crater  at  the  site  of  entry.  These 
infections  can  spread,  generally  in  a  linear  array  up  the 
lymphatic  chain.  As  with  many  of  these  infections,  early 
recognition  leads  to  effective  therapy.  Other  bacterial 
processes  can  also  be  associated  with  typical  leisure  time 
activities.  One  of  the  best  known  is  pseudomonas 
folliculitis  acquired  in  hot  tubs,  a  characteristic  follicular 
disease  associated  with  a  recent  history  of  hot  tub  use. 
Culture  of  water  from  the  spa  generally  confirms  the 
presence  of  the  infectious  agent. 

Other  life-threatening  and  fatal  infectious  processes  can 
be  inoculated  through  the  skin.  The  most  pertinent  example 
is  acquisition  of  HTV.  HTV  infection  can  be  acquired  in  a 
number  of  well-known  ways,  including  passage  of  the  virus 
through  the  skin.  In  the  work  environment,  accidental 
puncture  with  infected  needles  and  surgical  instruments 
leads  to  an  HTV  infection  rate  of  approximately  0.2%  This 
is  significant,  considering  that  it  represents  the  acquisition 
of  an  irreversible  infectious  process.  HIV  transmission 
through  the  skin  has  also  been  documented  in  other  circum- 
stances, including  the  use  of  contaminated  tattoo  needles 
and  by  means  of  open  genital  sores  at  the  time  of  inter- 
course. 

Governmental  Goats 

As  with  all  of  the  multitude  of  interactions  in  life,  it  is  not 
possible  to  eradicate  potentially  dangerous  interactions 
between  man  and  the  environment  Reasonable  goals 
include  the  dissemination  of  information  concerning 


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avoidance  to  populations  at  risk  for  acquisition  of  the 
infection.  Dairy  workers  should  know  about  milker's 
nodules;  gardeners  about  sporotrichosis;  hikers,  about  Lyme 
disease.  An  iimovative  mechanism  of  information  dissemi- 
nation could  be  developed  with  the  assistance  of  the  Ameri- 
can Academy  of  Dermatology.  For  example,  pamphlets 
detailing  the  risks  of  acquisition  of  sporotrichosis,  the 
modes  of  acquisition,  the  appearance  of  the  skin  lesions,  and 
the  recommended  treatments  could  be  made  available  at 
nurseries  and  garden  stores.  Pamphlets  describing  the 
modes  of  acquisition  of  tick-bom  diseases  could  be  avail- 
able at  sporting  goods  stores.  A  flexible  program  of  vector 
control  should  be  available  and  in  use.  If  an  epidemic  of 
Lyme  disease  is  occurring,  then  the  infected  host  population 
should  be  defined  and  controlled.  If  mosquito-bome 
diseases  are  prevalent,  then  mosquito  control  is  the  most 
efficient  way  of  preventing  disease. 

To  reiterate,  a  collaboration  between  dermatologists  and 
govemment  could  lead  to  a  more  efficient  dissemination  of 
information  regarding  acquisition  of  infections  through  the 
skin.  Inevitably,  this  would  lead  to  decreased  incidence  of 
infection,  increased  worker  productivity  and  better  enjoy- 
ment of  our  leisure  time. 


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Man-Made  Hazards  to  the  Skin 


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Recognition,  Surveillance  and  Trends 
IN  Man-Made  Hazards  in  the  Workplace 

C.G.  Toby  Mathias,  M.D. 


Occupational  skin  disorders  are  important  causes  of  morbidi- 
ty and  disability  in  the  wortq>lace.  In  1982.  the  National 
Institute  for  Occupational  Safety  and  Health  (NIOSH) 
included  skin  disorders  on  its  list  of  ten  leading  work- 
related  diseases  and  injuries.'  Effective  strategies  to  prevent 
occupational  skin  disease  caused  by  man-made  hazards  in 
the  workplace  must  be  based  first  on  recognition  of  occur- 
ring cases,  followed  by  more  specific  identification  of  high 
risk  causal  agents,  occupations,  and  industries  of  employ- 
ment Surveillance  systems  for  monitoring  occupational 
skin  diseases  must  rely  on  information  reported  by  employ- 
ers, physicians  and  workers. 

Employer-Based  Reporting  Systems 

The  Annual  Survey  of  Occupational  Injuries  and  Illnesses, 
conducted  by  the  Bureau  of  Labor  Statistics  (BLS),  has 
monitored  the  occurrence  of  occupational  skin  diseases 
since  1972.  This  survey  is  based  on  a  representative, 
random  probability  sample  of  approximately  280,000 
employers  in  private  industry  selected  across  all  50  states, 
the  District  of  Columbia,  and  U.S.  territories  and  posses- 
sions. The  survey  covers  civilian  private  sector  employers 
but  excludes  the  military,  pubhc  sector  employers,  small 
farms  with  fewer  than  1 1  employees,  private  household 
industries,  and  self-employed  individuals.   Participation  is 
mandatory  for  selected  companies,  which  must  record  all 
new  cases  of  occupational  skin  diseases  that  occur  during 
the  survey  year.  Incidence  rates  are  expressed  per  number 
of  fiill-time  employees,  where  2000  hours  (40  hours  per 
week  X  50  weeks)  worked  by  any  combination  of  employ- 
ees equals  one  fiill-time  employee.  Data  fiom  this  survey 
are  most  useful  for  monitoring  trends  and  identifying  high 
risk  industrial  classifications.-  Incidence  rates  measured  in 
this  survey  declined  gradually  from  16.2  per  10,000  full- 
time  workers  in  1972,  to  a  low  of  6.9  per  10,000  workers  in 
1986,  tut  have  increased  steadily  since  then.  The  incidence 
rate  in  1990  was  7.9  per  10,000  workers,  or  almost  61,000 
total  new  cases.  There  are  no  readily  apparent  explanations 
for  this  trend. 

Agricultural  and  manufacturing  industries  have  consis- 
tently had  high  relative  risks,  almost  five  and  three  times 
greater  respectively,  than  other  industrial  classifications. 
Within  the  major  industrial  classifications  of  agriculture  and 
manufacturing,  agricultural  crop  production  and  leather 


product  manufacturing  have  the  highest  incidence  rates, 
measured  at  39.4  and  27.4  per  10,000  fiill  time  workers  in 
the  1984  aimual  survey.  Despite  a  lower  incidence  rate  of 
8.1  per  10,000  fiill  time  workers,  the  health  services  indus- 
tiy  ranks  number  one  in  incurring  the  largest  number  of 
cases,  with  an  estimated  3,900  cases  in  1984. 

Physician-Based  Reporting  Systems 

Workers'  compensation  insurance  is  mandated  by  federal 
law  to  cover  all  legitimate  medical  and  lost  work-time 
expenses  resulting  from  occupational  injuries  and  illnesses. 
Administrative  boards  exist  in  all  states  and  are  tun  by  state 
agencies.  Although  originally  intended  for  economic 
analysis,  data  routinely  collected  by  these  state  agencies  on 
workers'  compensation  claims  (WCC)  may  be  adapted  for 
surveillance  of  occupational  skin  diseases.  All  cases  are 
seen  and  reported  by  physicians  in  accordance  with  various 
state  laws.  In  addition  to  the  obvious  advantages  of  confir- 
mation of  occupational  causation  determined  by  physicians, 
such  reporting  systems  collect  more  specific  information  on 
types  of  skin  disease,  causal  agents,  and  occupations,  in 
addition  to  industries  of  employment 

In  the  state  of  California,  a  physician  diagnosing  and 
treating  an  occupational  skin  disease  is  required  to  file  a 
"doctor's  first  report  of  injury"  with  the  California  Depart- 
ment of  Industrial  Relations  immediately  following  the 
initial  evaluation.  The  filing  of  this  report  results  in  prompt 
payment  for  services  rendered.  Data  on  occupational  skin 
diseases  for  the  reporting  year  1977  were  extensively 
analyzed,  and  the  results  pubUshed  in  1982.'  In  1977,  the 
state  received  17,462  doctors'  first  reports  for  an  estimated 
8.5  million  workers  covered  by  the  state  Workers'  Compen- 
sation Act  The  case  rate  was  21  per  10,000  workers,  twice 
the  national  average  rate  of  10.5  per  10,000  workers  record- 
ed in  the  BLS  annual  survey  for  the  same  reporting  year. 
Contact  dermatitis  accounted  for  92.2%  of  all  reported 
cases,  skin  infections  for  5.4%,  and  miscellaneous  skin 
conditions  for  the  remaining  2.4%.  Of  all  reported  cases, 
19.5%  lost  at  least  one  day  from  work.  Agricultural  and 
manufacttiring  industries  had  the  highest  relative  risks  with 
incidence  rates  of  86  and  41  per  10,000  workers  respective- 
ly, compared  to  national  rates  of  44.3  for  agriculture  and 
24.5  for  manufacturing  recorded  in  the  BLS  annual  survey. 
The  leading  man-made  causes  were  cleaning  compounds 


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(including  soap,  water,  detergent),  solvents,  particulate  dusts 
(including  fiberglass),  plastic  resins,  petroleum  products 
(excluding  solvents),  agricultural  chemicals,  textiles,  acids, 
metals,  and  cutting  fluids 

The  Supplementary  Data  System  (SDS)  is  a  national 
database  maintained  by  the  BLS  and  abstracted  from 
infonmation  reported  on  WCC  filed  in  individual  states  that 
voluntarily  participate  in  the  system.  Unlike  the  annual 
survey,  injury  and  illness  data  are  derived  from  costs 
occurring  in  both  the  private  and  public  sector  and  reported 
to  state  workers'  compensation  agencies.  The  SDS  provides 
supplementary  information  on  a  number  of  variables 
associated  with  occupational  injury  and  illness,  including 
type  of  illness,  occupation,  causal  agent,  part  of  body 
affected,  age  and  gender.  Identities  of  affected  workers  and 
employers  are  not  entered  into  the  SDS  file.  Although  the 
SDS  is  a  pool  of  data  from  participating  states,  reporting 
criteria  for  entering  cases  into  the  SDS  are  not  uniform  from 
state  to  state.  While  some  states  enter  all  their  WCC  into 
the  SDS,  others  enter  only  those  cases  associated  with  a 
specified  number  of  lost  work  days  (e.g.,  at  least  one  lost 
work  day,  or  at  least  eight  lost  work  days).  In  spite  of  these 
variances,  the  SDS  contains  a  sizable  national  cross-section 
of  information  on  WCC.  An  analysis  of  1981  SDS  data 
found  excellent  correlation  of  risk  ranking,  based  on  inci- 
dence rates,  for  both  major  and  two-digit  standard  industrial 
classifications  between  SDS  and  annual  survey  data.'  Thus, 
further  analysis  of  SDS  data  for  specific  industries  of 
employment  identified  with  high  incidence  rates  in  the  more 
reliable  annual  survey  may  provide  useful  insights  into 
important  variables  associated  with  occupational  skin 
disease.  For  example,  further  analysis  of  the  1981  SDS  data 
for  agriculture  found  that  48.2%  of  occupational  skin 
disease  cases  were  caused  by  naturally  occurring  plants, 
trees,  or  vegetation,  and  another  10.1%  by  miscellaneous 
food  products.  Only  19.1%  were  caused  by  chemicals, 
including  pesticides. 

The  Health  Examination  Survey  is  a  series  of  progiains 
conducted  by  the  National  Center  for  Health  Statistics  in 
which  health  data  are  collected  on  segments  of  the  general 
U.S.  population  by  direct  physical  examinations,  tests,  and 
measurements  on  selected  representative  samples  of  the 
civilian,  noninstitutionalized  population.   From  1971  to 
1 974,  the  National  Health  and  Nutrition  Examination 
Survey  (NHANES  I)  collected  data  on  the  prevalence  of 
skin  conditions  from  a  national  probability  sample  of 
20,749  selected  persons,  aged  1  to  74  years.*  Each  individ- 
ual was  examined  by  a  dermatologist.  Although  the  study 
was  designed  primarily  to  obtain  data  on  the  general 
population,  Umited  information  on  occupational  skin 
disease  was  obtained.  Approximately  one-third  of  all 
survey  participants  were  found  on  examination  to  have 


significant  skin  disease,  and  almost  10%  of  these  persons 
considered  their  conditions  to  be  a  handicap  to  their  em- 
ployment or  housework  (1%  severe,  9%  minimal).  Neariy 
one-fourth  (23.9%)  of  adults  aged  18  to  74  with  significant 
skin  diseases  associated  their  conditions  with  occupational 
exposure  to  chemicals,  fumes,  vapors,  oils,  insecticides,  or 
prolonged  immersion  of  hands  or  feel  in  water.  The  propor- 
tion of  skin  conditions  associated  with  occupation  exposure 
was  more  than  twice  as  high  among  men  (32.4%)  than 
women  (14.4%). 

Worker-Based  Reporting  Systems 

The  National  Health  Interview  Survey  (NHIS)  is  an  annual 
statistical  sampling  survey  conducted  through  personal 
interviews  of  household  members  by  the  National  Center 
for  Health  Statistics  at  selected  sites  across  the  country. 
This  survey  is  designed  to  make  national  estimates  of  health 
characteristics  for  the  civilian,  noninstitutionalized  popula- 
tion. Each  year,  special  health  surveys  may  be  added  to  the 
core  survey.  In  1988,  the  National  Institute  for  Occupation- 
al Safety  and  Health  (NIOSH)  added  an  occupational  health 
survey,  focusing  on  individuals  aged  1 8  and  older  who  had 
been  employed  in  a  civilian  job  at  any  time  during  the 
preceding  year.  This  supplemental  survey  contained  a  series 
of  questions  about  dermatitis,  defined  as  "dermatitis, 
eczema,  or  any  other  red,  inflamed  skin  rash"  occurring  in 
the  12  months  prior  to  interview;  acne  was  excluded  from 
the  responses.  Contact  dermatitis  was  defined  as  dermatitis 
"caused  by  chemicals  of  any  other  substance  that  had  gotten 
on  the  skin"  of  participating  subjects.  If  subjects  with 
contact  dermatitis  had  gotten  the  chemicals  or  other  sub- 
stances on  their  skin  while  at  work,  contact  dermatitis  was 
considered  occupational.  Data  on  dermatitis  from  this 
survey  are  self-reported,  and  no  attempt  was  made  to 
confirm  or  corroborate  any  response  by  direct  physical 
examination,  review  of  the  medical  records,  or  any  other 
method. 

Extrapolating  the  survey  results,  we  can  project  that  of 
the  approximately  127  million  people  employed  in  civiUan 
jobs  in  the  U.S.  during  1988,  14.9  miUion  (1 1.7%)  have 
experienced  dermatitis.  Of  those  reporting  dermatitis, 
22.7%  reported  that  the  rash  was  caused  by  skin  contact 
with  chemicals  or  other  substances,  i.e..  contact  dermatitis. 
Of  those  reporting  contact  dermatitis.  68%  (representing  2.3 
million)  reported  that  they  had  gotten  the  chemicals  or 
substances  on  their  skin  while  at  work.  This  translates  into 
an  estimated  prevalence  rate  of  181  per  10.000  workers. 
Assuming  cases  which  lasted  less  than  365  days  at  the  time 
of  interview  to  be  new  cases,  the  conesponding  incidence 
rate  would  be  136  per  10.000  employees.  Further  analysis 
of  this  data  confirms  suspicions  of  serious  underreporting  of 
occupational  skin  diseases  in  other  health  surveys.*  Only 


62 


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430 


22.4%  of  individuals  in  this  survey  who  experienced 
occupational  contact  deimatitis  reported  their  conditions  to 
their  employers,  and  only  1 .6%  filed  a  WCC. 

Surveillance  and  Prevention 

The  ultimate  goal  of  all  occupational  disease  surveillance 
programs  should  be  prevention  of  further  occupational 
illnesses.  National  surveillance  programs  such  as  the  BLS 
Annual  Survey,  the  SDS,  and  the  NHIS,  hold  the  identities 
of  participating  workers  and  employers  as  confidential;  only 
high  risk  occupations  and  industries  of  employment  are 
described.  These  surveys  offer  opportunities  only  for 
indirect  intervention  primarily  through  educational  efforts 
aimed  at  large  occupational  groups  (e.g.,  unions),  employers 
(e.g.,  trade  associations),  or  occupational  physicians  caring 
for  these  large  groups.  State  workers'  compensation 
agencies,  on  the  other  hand,  include  the  identities  of  affected 
workers  and  employers  as  part  of  the  WCC  databases. 
Thus,  state  workers'  compensation  databases  offer  potential 
opportunities  for  surveillance  systems  to  direct  information 
to  employment  sites  where  cases  are  actually  occurring. 

In  order  to  determine  the  feasibility  of  using  state  WCC 
data  for  such  a  purpose,  an  analysis  of  WCC  data  filed  in 
Ohio  for  the  five  year  period  1980  to  1984  was  undertaken.' 
This  analysis  assumed  that  limited  federal  or  state  resources 
would  be  available  for  direct  intervention,  and  focused  on 
companies  filing  the  highest  number  of  claims  for  skin 
disease.  The  analysis  fiirther  assumed  that  preventive 
strategies  would  be  most  effectively  focused  on  occupations 
or  causal  agent  exposures  fiequently  associated  with  claims 
from  any  one  company.  During  the  five-year  study  period, 
102  Ohio  companies  filed  six  or  more  claims  (average  >  1 
claim  per  year).  Within  85  (63.7%)  of  these  102  compa- 
nies, either  the  same  occupation  or  causal  agent  was  impU- 
cated  in  over  50%  of  claims  filed.  This  suggests  that  active 
intervention  strategies  to  prevent  occupational  skin  disease 
can  be  both  feasibly  and  economically  directed  at  employ- 
ment sites  following  primary  identification  of  companies 
filing  high  numbers  of  occupational  skin  disease  claims,  and 
secondary  identification  of  high-risk  occupations  or  causal 
agent  exposures  within  these  companies. 

References 

1 .  National  Institute  for  Occupational  Safety  and  Health. 
Proposed  national  strategies  for  the  prevention  of 
leading  work-related  diseases  and  injuries.  Part  U. 
Association  of  schools  of  pubUc  health,  1988. 

2.  Mathias  CGT,  Morrison  JH.  Occupational  skin  diseas- 
es. United  States.  Results  from  the  Bureau  of  Labor 
Statistics  annual  survey  of  occupational  injuries  and 
illnesses,  1973  through  1984.  Arch  Dermatol 
1988;124:1519-1524. 


3.  California  Division  of  Labor  Statistics  and  Research. 
Occupational  skin  disease  in  California,  with  special 
reference  to  1977.  San  Francisco:  California  Depart- 
ment of  Industtial  Relations,  1982. 

4.  O'Malley  M,  Thun  M,  Morrison  J,  et  al.  Surveillance  of 
occupational  skin  disease  using  the  Supplementary  Data 
System.  Am  J  Ind  Med  1988;13:291-299. 

5.  Johnson  MLT.  Skin  conditions  and  related  need  for 
medical  care  among  persons  1  -74  years.  United  States, 
1971-1974.  Hyattsville:  National  Center  for  Health 
Statistics;  1978.  DHEW  PuWication  PHS  79-1660. 

6.  Discher  DP,  Kleinman  GP,  Foster  FJ.  Pilot  study  for 
development  of  an  occupational  disease  surveillance 
method.  Washington,  DC:  U.S.  Government  Printing 
(Dffice;  1975.  WEW  PubUcation  No.  NIOSH  78-182. 

7.  Mathias  CGT,  Sinks  TH,  Seligman  PJ,  et  al.  SurveU- 
lance  of  occupational  skin  diseases;  a  method  utilizing 
workers'  compensation  claims.  Am  J  Ind  Med 
1990;17:363-370. 


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431 


Percutaneous  Absorption  of  Hazardous  Substances 
FROM  the  Environment:  Systems  Vaudaron 

Ronald  C.  Wester,  Ph.D.,  and  Howard  I.  Maibach,  M.D. 


Introduction 

Contamination  of  ground  water,  surface  water  and  soil,  and 
the  transfer  of  contaminants  to  the  human  body,  are  of 
major  concern.  The  obvious  first  assumption  is  that  con- 
taminants are  ingested  in  drinking  water.  However,  when 
the  large  surface  area  of  skin  is  exposed  to  contaminated 
water  by  bathing  and  swimining.  skin  absorption  may  also 
be  significanL  Brown,  et  al..  suggested  that  skin  absorption 
of  contaminants  in  water  has  been  underestimated  and  that 
ingestion  may  not  constitute  the  sole,  or  even  the  primary, 
route  of  exposure.- 

Industrial  growth  has  resulted  in  the  production  of 
organic  chemicals  and  toxic  metals,  the  disposal  of  which 
results  in  contamination  of  water  supplies.  For  swimmers 
or  bathers,  the  skin,  the  largest  organ  of  the  body  (surface 
area  approximately  18.000  cm^)  acts  as  a  lipid  sink  (stratum 
comeum)  for  lipid  soluble  contaminants.  The  skin  also 
serves  as  transfer  membrane  for  water  and  whatever  con- 
taminants may  be  dissolved  in  it 

Hazardous  substances  can  cause  adverse  effects  in 
humans  only  if  exposure  occurs.  Soil,  recently  recognized 
as  a  potentially  important  mediimi  of  exposure,  is  a  medium 
with  which  human  skin  has  constant  contact.  This  can  be 
work-related  (fanning;  waste  hazard  disposal),  recreational 
(gardening),  or  a  child's  delight  (beach;  sand  box). 

A  major  dilemma  in  estabUshing  regulatory  limits  for 
environmental  pollutants  is  the  establishment  of  standards 
or  limits  for  chemical  concentrations  in  soil  at  industrial  and 
residential  sites.  Factors  and  assumptions  used  to  predict 
the  bioavailability  of  a  chemical  from  soil  significandy 
affect  the  establishment  of  a  virtually  safe  dose  or  accept- 
able daily  exposure  level  of  a  compound  in  soil.  The  two 
major  concerns  in  setting  relevant  contamination  levels  are 
public  safety  and  cost/feasibility  of  cleanup.  Public  safety 
depends  upon  the  inherent  toxicity  of  the  hazardous  chemi- 
cal and  its  bioavailabiUty  (rate  and  extent  of  systemic 
absorption).  The  cost  of  remediation  varies  dramatically 
with  the  level  to  which  soil  must  be  decontaminated; 
excessive  remediation  means  that  limited  resources  will  be 
spent  without  providing  additional  protection  of  public 
health. 

The  cost.  thus,  in  human  health  welfare  and  dollars  to 
safeguard  people  and  the  environment  is  tremendous. 
Decisions  regarding  this  should  be  based  on  fact,  and 


accurate,  useful  scientific  data  can  provide  the  facts  to  make 
appropriate  judgments.  The  key  to  accurate,  usefiil  scientif- 
ic data  is  validation  of  the  systems.  This  paper  will  briefly 
discuss  some  validation  points  relevant  to  percutaneous 
absorption. 

Percutaneous  Absorption  Systems 

Table  I  summarizes  in  vitro  and  in  vivo  percutaneous 
absorption  of  some  environmental  hazardous  substances 
from  water,  soil  and  model  vehicles  (acetone,  mineral  oil, 
trichlorobenzene).  The  percent  dose  absorbed  was  deter- 
mined in  vitro  with  human  skin  moimted  in  glass  diftiision 
cells,  and  in  vivo  in  the  Rhesus  monkey."  " 

Note  that  dose  accumulation  within  the  receptor  fluid 
(either  human  plasma  or  buffered  saline)  is  relatively 
nonexistent.  If  decisions  were  made  based  only  on  receptor 
fluid  accumulation,  the  concept  of  percutaneous  absorption 
of  hazanious  substances  would  not  exist  This  is  because 
most  of  the  compounds  are  very  lipophilic  and  will  not 
partition  into  the  receptor  fluid.  Table  II  gives  the  octanol: 
water  partition  coefficient  for  some  of  these  chemicals.  The 
receptor  fluid  simply  caimot  solubilize  these  compounds; 
thus  the  receptor  fluid  is  not  validated  for  percutaneous 
absorption  of  these  compounds. 

Table  I  also  gives  skin  content  for  doses  absorbed  in 
vitro.  Assuming  that  a  chemical  will  penetrate  skin  and  not 
be  soluble  in  receptor  fluid,  then  perhaps  the  skin  content 
might  predict  percutaneous  absorption.  In  fact  this  seems 
more  predictive;  skin  contents  of  chemicals  compare  more 
favorably  with  in  vivo  values  for  lipophilic  chemicals. 

The  in  vivo  percutaneous  absorption  shows  that  these 
chemicals  are  highly  absorbed.  This  suggests  that  these 
environmental  hazardous  substances  can  readily  partition 
out  of  their  environmental  vehicles  (water,  soil,  spray)  and 
be  absorbed  through  skin.  The  in  vivo  data  are  from  the 
Rhesus  monkey.  Table  III  shows  that  the  Rhesus  monkey  is 
validated  as  an  in  vivo  animal  model  relevant  to  humans  for 
percutaneous  absorption.'-' 

Therefore,  there  appears  to  be  some  sense  of  security  in 
using  data  generated  from  the  Rhesus  monkey  in  vivo  and 
from  human  skin  content  in  vitro  (especially  where  in  vitro 
absoiption  data  are  produced  conciurently  with  vahdated  in 
vivo  data). 


Proceedinos  of  the  National  Ccnfekence  on  ENvmoNMEwrAL  Hazards  to  the  Skin 


432 


Material  Balance:  Accountability 

The  preceding  discussion  pointed  out  the  importance  of 
examining  skin  content  as  well  as  receptor  fluid  accumula- 
tion. It  is  possible  in  an  in  vitro  study  to  achieve  material 
balance.  Table  IV  shows  the  in  vitro  percutaneous  absorp- 
tion of  alachlor  over  time  (0-8  hours).  Data  are  represented 
as  dose  accumulation  in  receptor  fluid,  skin  digest,  skin 
wash  (soap  and  water),  apparatus  wash,  and  final  account- 
ability.' The  same  type  of  material  balance  can  be  achieved 
in  vivo  (Table  V),  and  the  animal  need  not  be  sacrificed." 
The  system  of  accountability  is,  thus,  validated  for  material 
balance.  Again,  there  is  a  sense  of  security  in  knowing 
where  all  of  the  dose  resides. 

Assumed  Default  Absorption 

Percutaneous  absorption  values  are  a  necessary  component 
of  health  hazard  assessment.  However,  chemicals  are  being 
produced  at  a  rate  faster  than  regulatory  agencies  can  assess 
their  absorption.  The  United  States  Environmental  Protec- 
tion Agency'  rightly  is  trying  to  develop  predictive  equa- 
tions to  assess  percutaneous  absorption.  This,  then,  gives  an 
assumed  default  absorption  value.  Default  value  is  a 
number  for  which  values  greater  than  it  are  considered 
excessive.  An  example  is  Table  VI,  where  the  assumed 
default  absorption  equation  for  metals  from  water  is  a  K"^ 
(permeability  coefficient  for  absorption  ft^m  water)  of  1  x 
10'  cm/hr.  For  cadmium,  the  default  value  is  3x  that  of  the 
measured  value,  but  250x  above  that  of  the  arsenic  mea- 
sured value.  Thus,  the  system  of  assumed  default  values 
lacks  proper  validation. 

In  VivoSkin  Decontamination 

Table  VII  gives  Aroclor  1242  removal  in  vivo  from  Rhesus 
monkey  skin  with  five  successive  washes  following  a  15- 
minute  skin  application  time.  Soap  and  water, 
tiichlorobenzene,  and  mineral  oil  were  able  to  remove  all  of 
the  Aroclor  1242  on  the  skin  with  five  washes,  and  at  least 
80%  was  removed  with  successive  washes.  Ethanol  was  not 
very  effective,  removing  only  63%  of  the  PCBs  in  five 
successive  washes. 

Table  Vni  gives  the  in  vivo  skin  decontamination  of 
Aroclor  1242  for  time  periods  beyond  the  initial  15-minute 
application  time.  With  trichlorobenzene  vehicle  no  differ- 
ences were  seen  through  1  hour.  However,  at  3  hours  the 
amount  of  Aroclor  1242  removed  was  decreased,  and  this 
compromised  ability  to  remove  Aroclor  1242  continues  at  6 
and  24  hours.  By  24  hours,  only  about  25%  of  the  PCBs 
can  be  recovered  from  the  surface  of  the  skin.  With  mineral 
oil  as  the  vehicle,  soap  and  water  was  able  to  remove  about 
70%  of  the  PCBs  over  a  3-hour  period.  This  decreased  to 
50%  at  6  hours,  and  only  30%  of  the  PCBs  could  be 
removed  at  24  hours.  Mineral  oil  was  more  efficient  in 


removing  the  PCBs  following  the  initial  15-minute  period 
(the  PCBs  were  in  mineral  oil  on  the  skin).  This  decontami- 
nation ability  quickly  disappeared  in  10  minutes.  By  24 
hours  only  45%  of  the  PCBs  could  be  recovered  bom  the 
surface  of  the  skin." 

Thus,  it  is  important  to  know  if  soap  and  water  will 
remove  a  chemical  from  skin.  It  is  paramount  to  know  that 
percutaneous  absorption  in  vivo  is  an  ongoing  process, 
subject  to  change  with  time.  Regulations  in  terms  of  safety 
decontamination  need  take  into  account  the  above  when 
validating  for  human  safety  guideUnes. 

Toxicokinetics 

The  percutaneous  absorption  of  pentachlorophenol  (PCP) 
from  acetone  vehicle  was  29.2  +/-  5.8%  of  total  dose 
apphed  for  a  24  hour  exposure  period.  Compared  to  other 
compounds'-  the  absorption  of  PCP  would  be  considered 
high.  In  vivo  absorption  fiom  soil  was  3.3%  for  DDT, 
13.2%  for  benzopyrene,  and  4.2%  for  chlordane.  Addition- 
ally, the  'X^  excretion  for  PCP  in  urine  was  slow,  measured 
at  a  half-life  of  4.5  days  for  both  intravenous  and  topical 
application.  If  biological  exposure  is  considered  in  terms  of 
dose  X  time,  the  PCP  biological  exposure  can  be  considered 
high. 

The  percutaneous  absorption  of  PCP  from  soil  vehicle 
was  also  high  (24.4  +/-  6.4%)  and  not  statistically  different 
ftom  acetone  vehicle  (Table  DC).  The  study  of  Reigner,  et 
al,'  and  this  study,  show  PCP  to  have  good  bioavailability, 
both  topical  and  oral;  PCP  also  exhibits  an  extensive  half- 
life.  This  suggests  that  PCP  has  the  potential  for  extensive 
biological  interactions. 

Thus,  percutaneous  absorption  can  be  expressed  as  in 
vivo  topical  bioavailability  where  pharmacokinetic  data  such 
as  half-life  can  be  integrated  with  toxicological  data. 
Validation  of  such  a  system  gives  an  integrated  meaning  to 
the  interactions  of  chenucals  in  a  bving  system. 

Discussion 

Table  I  lists  an  impressive  collection  of  chemicals  that 
contaminate  the  environment  Potential  human  health 
hazard  assessment  requires  a  bioavailability  section  where 
absorption  into  the  himian  body  is  calculated.  It  is  impor- 
tant that  the  parameter(s)  used  to  gather  bioavailability  data 
be  validated,  because  the  costs  in  dollars  and  human  health 
can  be  very  large.  It  is  paramount  that  any  percutaneous 
absorption  data,  preferably  both  in  vitro  with  human  skin 
and  in  vivo  in  humans  or  a  relevant  animal  model,  be 
derived  fiom  vaUdated  systems. 


Proceedings  of  the  National  Confedence  on  Environmental  Hazards  to  the  Son 


433 


References 

1 .  Bronaugh  RL.  Wester  RC,  Bucks  DAW.  In  vivo 
percutaneous  absorption  of  fragrance  ingredients  in 
Rhesus  monicey  and  man.  Fd  Chem  Toxicol 
1990;28:369-373. 

2.  Brown  HS,  Bishop  DR.  Rowans  CA.  The  role  of  skin 
absorption  as  a  route  of  exposure  for  volatile  organic 
compounds  (VCX^s)  in  drinking  water.  Am  J  Public 
Health  1984;74:479-484. 

3.  Franz  TJ.  Lehman  P.  Percutaneous  absorption  of 
tetinoic  acid  in  monkey  and  man.  In:  Reichen  U,  Shroot 
B,  eds.  Pharmacology  of  retinoids  in  the  Skin.  Basel: 
Karger,  1989:174-180. 

4.  Reigner  BG,  Gungon  RA,  Hoag  MK.  et  al.  Pentachlo- 
rophenol  toxicokinetics  after  intravenous  and  oral 
administration  to  rat  Xenobiotica  1991;21:1547-1558. 

5.  US  EPA  integrated  risk  information  systems.  Office  of 
Health  and  Environmental  Assessment  Cincintuti, 
1992. 

6.  Wester  RC,  Maibach  HI.  Percutaneous  absorption  in  the 
Rhesus  monkey  compared  to  man.  Toxicol  Appl 
Pharmacol  1975;32:394-398. 

7.  Wester  RC,  Maibach  HI.  Cutaneous  pharmacokinetics: 
10  steps  to  percutaneous  absorption.  Drug  Metab  Rev 
1983;14:169-205. 

8.  Wester  RC,  Maibach  HI.  In  vivo  animal  models  for 
percutaneous  absorption.  In:  Bronaugh  R,  Maibach  HI, 
eds.  Percutaneous  Absorption.  2nd  ed.  New  York: 
Dekker,  1989:221-238. 

9.  Wester  RC,  Maibach  HI.  In  vitro  testing  of  topical 
pharmaceutical  formulations.  In:  Bronaugh  R.  Maibach 
HI,  eds.  Percutaneous  Absorption.  2nd  ed.  New  York; 
Dekker,1989:653-659. 

10.  Wester  RC,  Maibach  HI,  Bucks  DAW,  et  al.  Percutane- 
ous absorption  and  skin  decontamination  of  PCBs.  In 
vitro  studies  with  human  skin  and  in  vivo  studies  in  the 
Rhesus  monkey.  J  Toxicol  Environ  Health 
1990;31:1235-1246. 

11.  Wester  RC,  Maibach  HI,  Bucks  DAW,  et  al.  Percutane- 
ous absorption  of  { "C)  DDT  and  { "C)  benzoapyrcne 
from  soil.  Fund  Appl  Toxicol  I990;15;510-516. 


12.  Wester  RC,  Bucks  DAW,  Maibach  HI.  Percutaneous 
absorption  of  hazardous  substances  from  soil.  In: 
MarzulU  F,  Maibach  HI,  eds.  Dermatoioxicology.  4th 
ed.  New  York:  HemisphcrB,199l:l  11-121.. 

13.  Wester  RC.  Maibach  HI.  Sedik  L.  et  al.  Percutaneous 
absorption  of  { "Cl<hlordane  from  soil.  J  Toxicol 
Environ  Health  1992;35:269-277. 

14.  Wester  RC,  Maibach  HI.  Sedik  L.  et  al.  In  vitro  percuU- 
neous  absorption  of  cadmium  from  water  and  soil  into 
human  skin.  Fund  Appl  Toxicol  1992;19:1-5. 

15.  Wester  RC,  Maibach  HI,  Sedik  L,  et  al.  Percutaneous 
absorption  of  pentachlorophenol  from  soil.  Fund  Appl 
Toxicol  1993;20:68-71. 

16.  Wester  RC,  Maibach  HI,  Sedik  L,  et  al.  Percutaneous 
absorption  of  PCBs  from  soil:  In  vivo  Rhesi'i  monkey, 
in  vitro  human  skin,  and  binding  to  powdered  human 
stratum  comeum.  J  Toxicol  Environ  Health 
1993;39:375-382. 


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Table  I 


In    vitro  and  In   vivo    Percutaneous     Absorption 


Compound  Vehicle 


%  Dose  Absorbed 
In     vitro  In    vivo 

Skin  Receptor    fluid 


DOT 

acetone 
soil 

18.1  ±  13.4 
1.0  ±  0.7 

0.08 
0.04 

±  0.02 
±  0.01 

18.9  ±  9.4 
3.3  ±  0.5 

Benzo(a)pyrene 

acetone 
soil 

23.7  ±  9.7 
1.4  ±  0.9 

0.09 
0.01 

±  0.06 
±  0.06 

51.0  ±  0.06 
13.2  ±  3.4 

Chlordane 

acetone 
soil 

10.8  ±  8.2 
0.3  ±  0.3 

0.07 
0.04 

±  0.06 
±  0.05 

6.0  ±  2.8 
4.2  ±  1.8 

Pentachlorophenol 

acetone 
soil 

3.7  ±  1.7 
0.11   ±  0.04 

0.06 
0.01 

±  0.09 
±  0.00 

29.2  ±  5.8 
24.4  ±  6.4 

PCBs   (1242) 

acetone 

TCBto 

mineral  oil 

soil 

a 

a 

10.0  ±  16.5 

2.6  ±  2.8 

0.1 
0.04 

a 
a 

±  0.07 
±  0.05 

21.4  ±  8.5 
18.0  ±  3.8 
20.4  ±  8.5 
13.8  ±  2.7 

PCBs   (1254) 

acetone 

TCBi) 

mineral  oil 

soli 

a 

a 
6.4  ±  6.3 

1.6  ±  1.1 

a 

a 

0.3  ±  0.6 

0.04  ±  0.05 

a 
14.6  ±  3.6 
20.8  ±  8.3 
14.1   ±  1.0 

Arsenic 

water 
soil 

1.0  ±  1.0 
0.3  ±  0.2 

0.9  ±  1.1 
0.4  ±  0.5 

2.0  ±  1.2 
3.2  ±  1.9 

2.4-D 

acetone 
soil 

a 
1.4    ±  1.2 

a 
negligible 

8.6  ±  2.1 
15.9  ±  4.7 

Cadmium 

water 
soil 

12.7  ±  11.7 
0.13    ±  0.05 

0.6 
0.07 

±  0.2 
±  0.03 

a 
a 

'  Study  not  done 

*  Trichlorobenzene 

Note:     PCBs  exist  in  transformers  in  trichlorobenzene  and  mineral  oil  vehicles. 


PROCEEDINOS  Of  THE  NaTXWAL  CONFERENCE  ON  EnVKONMEOTAL  HAZARDS  TO  THE  SkIN 


Table  II 


435 


Octanol:Water     Partition     Coefficient     of 
Environmental     Hazardous     Substances 


Chemical 


Log 

P  o/w  > 

6.1 

5.54 

6.19 

5.01 

very 

lipophilic 

Benzo(a)pyrene 

Chlordane 

DDT 

Pentachlorophenol 

RGBs  (mixture) 


Log  partition  coefficient  between  octanol  and  water. 

Numbers  above  0  (zero)  are  lipophilic;  large  numbers  such  as 
these  make  the  compounds  extremely  lipophilic 


Table  I 


In  vivo  Percutaneous  Absorption   in   Rhesus  Monkey  and   Man 


Compound 


%   Do«a  Ab«Oft»«d 
Rhetut   monkey         Man 


2,4-Dinltrochlorobenzene* 

Nitrobenzene* 

Cortisone* 

Testosterone* 

Hydrocortisone* 

Benzoic  add* 

Diethyl  maleaie^ 

DOie 

Retinoicadd' 

2,4-0 


52  t  4 

54±6 

4±1 

2±1 

S±3 

3±2 

18  ±10 

13  ±3 

3t1 

2±2 

60±8 

43  t  16 

68t7 

54±7 

19  ±9 

10  ±4 

2±1 

1  ±0.2 

9±2 

6t2 

<  WsMir  M  al  (t989a) 

b  BnMiuigti  •!  al  (19S0) 

c  WMtK  at  al  (iseob) 

d  Franz  and  Lahman  (1889) 

These  are  data  collected  over  the  years  Irom  many  laborakirtes.  Ttie  rhesus 
monkey  Is  a  good  animal  model  to  predict  potential  percutaneous  atisoiption  in  man. 

Proceedings  of  the  Nmwnal  Conference  on  ENvntoNMENT/u.  Hazards  to  the  Skin 


436 


Table  IV 


In    vitro    Human    Skin    Absorption    and    Distribution    of    Alaclilor 
from    Water    over   Time 


Parameter 

Percentage   applied 

dose 

0.5     hou 

rs             4    hours 

8    hours 

Receptor  fluid  (plasma) 

0.01 

0.28 

0.82 

Skin  digest 

19.6 

30.5 

33.1 

Si(ln  wash 

77.0 

61.4 

43.3 

Apparatus 

0.3 

1.0 

9.0 

Total  accountability 

96.91 

93.2 

86.2 

The  distribution  of  dose  within  the  parameters  of  the  study  give  a  sense  of 
security  as  to  validation  of  the  study. 


Table  V 


In    vivo    Percutaneous    Absorption    of    Chlordane 
in    Rhesus    Monkey:      Dose    Accountability^ 

Percent    applied    dose 
(mean   ±   SD) 
lor    vehicle 


Soap-and-water   wash   sequence 


Water 
Chaint>er 

Residue  soil/membrane 
Systemic  at>sort>ed 
Accountability' 


14.3  ±11.6 

33.6  ±  13.4 

3.7  ±  34.9 

15.3  ±  3.6 

1.8  ±  0.9 

10.6  ±  2.9 

0.2  ±  0.1 

1.8  ±  0.4 

2.8  ±  3.6 

4.2  ±  1.8 

56.5  ±  15.9 

1.0  ±  0.3 

4.2  ±  1.8 

6.0  ±  2.8 

80.3 

72.0 

*  No  fecal  or  tissue  analyses. 

Dose  accountability  in  vivo  Is  possible  without  sacrifice  of  the  animal.    Similar 
accountability  would  thus  be  possible  In  human  studies. 

Proceedincs  of  the  National  Conference  on  Envkonmeotai.  Hazards  to  toe  Sbn 


Table  VI 


437 


Assumed     Default     Absorption 
Metals    KWp  of  1  X  10-3    cm/hr 


Compound 


Default    value 


Measured    value 


Difference 


Arsenic 
Cadmium 


10.1   ng/cm2 
1.8  ng/cm2 


0.04  ng/cm2 
0.6  ^g/cm2 


x250 
x3 


Table  VII 


"Working'  default  values  should  be  validated  by  scientific  study,  rather  than  accepted  at 
face  value. 


Aroclor   1242    Removal   from    Rhesus   Monkey   Skin 

with    Successive    Vtfashes    Following    Initial 

15-Mlnute     Application     Time 


Successive 
wash    number 

Percent   dose 

removed 

Soap   and   araMr 

Hin*nl    ell 

Ethsnel 

1 

62.4  ±  13 

79  ±  12 

64±  5 

51  ±7 

2 

19  ±9 

14  ±4 

21  ±6 

8±2 

3 

7±2 

5±1 

10  ±2 

21  1 

4 

3±1 

3±1 

5±1 

1  ±0 

5 

2±1 

1  ±1 

3±2 

1  ±  1 

Total 

93  ±7 

102  ±  7 

102  ±9 

63  ±4 

MM*:    Application 

vehicle  is  trichtorobeniene. 

Pkxxedings  of  ike  National  Confesence  on  Environmeotal  Hazarib  to  the  Skin 


438 


Table  VIII 


In   vfve   Skin    Decontamination    of   Areelor    1242    PCBa 
aa  Porcant  Appllad   Doaa  Removad 


Tim    launal 
p«*uollesU«« 

nt  pcai* 

Triehlerebantaiw 

vahlel* 

MliMnI    oil 

mklel* 

Urn   M4   >MM* 

iraMcta 

Mnwn   oa 

ilkaaol 

•«»    M<    MM 

WriOTI    M 

0.0 

93±7 

102  ±7 

63±4 

102  ±9 

71  ±18 

90±  10 

10  m 

87±  10 

86±9 

68±S 

95±6 

71  ±27 

68±  19 

1h 

81  ±  11 

92±e 

72  ±8 

79  ±  11 

71  ±33 

63  i  28 

3h 

63  ±17 

74  ±12 

49±3 

74  ±8 

68±  13 

64±  15 

eh 

57±2e 

58  ±15 

S2±7 

56±  12 

51  ±30 

65±22 

841) 

as  ±13 

25  ±19 

2B±7 

36±8 

30  ±14 

45±40 

NatK  MMn  1 80  tor  4  Wimit  monkay*. 
■FoUowIno  15-inln  ikJn  application  biMfvtl. 
'with  20%  (v/v)  Ivoty  UquM  toap^watw. 

It  Is  important  to  realize  that  In  vivo  percutaneous  absorption/decontamination  Is  an  ongoing  process, 
subject  to  change  with  time. 


Table  K 


In   vivo    Percutaneous    Absorption    of 
Pentachlorophenol    in    Rhesus    Monkey 


Parcant  dosa* 


Topical 


Soli  Aealona  Intra 


Percent  dose  absort)ed  24.4  ±  6.4  29.2  ±  5.8  — 

Surface  recovery*'  38.0  ±  13.4  59.6  ±  4.1  — 

Half-life   (days)  4.5  4.5  4.5 

'  Mean  ±  SD  for  four  animals. 

^  Includes  chamber,  residue,  and  surface  wasties. 

Pentachloiophenol  exhibits  extensive  sidn  absorption  and  a  long  haH-life.  Thus 
the  dose  X  time  says  interactions  between  pentachtorophenol  and  biological  tissues/cells 
is  extensive. 

PROCEEDINaS  OF  THE  NAIWrML  CoMFQieNCE  ON  ENVRONMBn'AL  HaZARIB  TO  HE  SdN 


Contact  Dermatitis 

Robert  L.  Rietschel,  M.D. 


Contact  dennatitis  is  an  altered  state  of  skin  reactivity 
induced  by  exposure  to  an  external  agenL  Substances  that 
pnxluce  this  condition  after  single  or  multiple  exposures 
may  be  irritant  or  allergic  in  nature.  Direct  tissue  damage 
results  from  contaa  with  irritants.  Tissue  damage  by 
allergic  substances  is  mediated  through  immunologic 
mechanisms.  The  most  common  morphologic  presentation 
is  dermatitis  (eczema),  but  other  patterns  are  encountered 
including  urticaria,  purpura,  and  erythema  multiforme. 
Chemical  burning  is  a  paradigm  for  acute  irritant  contact 
dermatitis,  while  poison  ivy  is  a  paradigm  for  aUeigic 
contact  dermatitis. 

Epidemiology 

Contact  dermatitis  is  a  common  reason  for  consulting  a 
dermatologist  and  constitutes  approximately  5.7  million 
physician  visits  per  year.  All  age  groups  are  affected,  but 
there  is  a  slight  female  predominance  of  the  condition,  as 
reflected  in  patients  seen  for  diagnostic  patch  testing. 

The  complex  nature  of  the  chemical  environment  in 
which  we  live  (natural  and  synthetic)  brings  the  skin  into 
contact  with  many  potential  exposures.  These  may  or  may 
not  pose  a  hazard,  depending  on  itxlividual  susceptibiUty. 

Over  2800  agents  have  been  identified  as  potential 
allergens,  and  the  number  of  potential  irritants  is  countless, 
since  humans  are  potentially  exposed  to  over  65,000 
substances.  The  severity  of  contact  dermatitis  ranges  from  a 
mild,  minor  nuisance  to  job-threatening  and  even  life- 
threatening  situations. 

With  over  2800  potential  allergens  in  the  environment, 
designing  a  simple  test  to  screen  patients  with  rashes  and 
identify  the  cause  is  a  bit  Uke  developing  a  single  blood  test 
to  screen  for  all  causes  of  cancer  or  all  forms  of  infection. 
The  patch  test,  which  is  the  only  reUable  aid  to  diagnosis, 
requires  nof>-irritating  concentrations  of  each  suspected 
allergen  or  mixes  of  categories  of  allergens.  About  200 
different  allergens  or  groups  of  allergens  are  available 
worldv^de,  but  only  20  are  available  under  FDA  license  for 
purchase  and  diagnostic  use  in  the  United  States  (Table  T). 
An  increase  in  the  availability  of  diagnostic  materials  would 
expand  the  ability  of  practicing  physicians  to  identify 
accurately  the  envinmmental  causes  of  contact  dermatitis. 

Once  a  new  cause  of  contact  dermatitis  is  identified  in  a 
physician's  office,  it  is  difficult  to  identify  the  magnitude  of 
the  problem  in  the  population  at  large.  This  is  true  even  for 
groups  of  physicians  carefully  tabulating  their  collective 
patient  data.  Good  epidemiologic  surveys  of  U.S.  popula- 
tion groups  are  sorely  lacking.  Only  one  study  of  four 


allergens  in  a  U.S.  general  population  gives  some  estimate 
of  the  magnitude  of  the  environmental  problems.  The  four 
allergens  studied  were  neomycin,  benzocaine,  nickel  and 
ethylenediamine.  The  prevalence  of  positive  reactions  was: 
nickel  5.8%,  neomycin  1.1%,  ethylenediamine  0.43%  and 
benzocaine  0.17%.  Nine  percent  of  women  were  nickel- 
sensitive,  compared  with  0.9%  of  men.  Few  diseases 
receiving  public  attention  rival  the  prevalence  of  nickel 
allergy,  which  affects  nearly  I  in  10  women  and  approxi- 
mately 14.5  million  Americans. 

While  dermatologists  can  produce  lists  of  the  allergens 
most  frequently  encountered  in  an  office  practice  setting, 
there  has  been  little  interest  in  Anther  environmental 
surveillance  of  these  materials.  Deiunark  established  a 
national  data  base  of  chemical  products  that  contained 
47,400  products,  27,800  of  which  were  fully  computerized 
A  list  of  43  skin  sensitizers  was  developed  from  medical 
reports,  and  the  number  of  pixxhicts  containing  each  of  these 
materials  varied  fh>m  30  to  more  than  1300. 

This  level  of  use  of  potential  sensitizers  guarantees  the 
public  will  repeatedly  be  exposed  to  potential  skin  allergens. 
Since  only  some  people  will  express  allergy,  while  others 
remain  inunune  or  tolerant  upon  exposure,  it  will  be  neces- 
sary to  protect  those  who  must  avoid  contact  with  a  specific 
substance.  Banning  materials  with  high  sensitizing  rates 
would  be  a  sound  business  practice,  since  no  one  would 
want  their  product  to  have  the  reputation  of  being  as  user- 
frieiKDy  as  poison  ivy.  Premarket  testing  usually  keeps  such 
products  off  the  shelf.  But  most  sensitizers  affect  a  much 
smaller  segment  of  the  population  and  with  varying  degrees 
of  severity.  How  can  a  technologically  advancing  society 
keep  the  benefits  of  new  chemicals  and  at  the  sait>e  time 
protect  citizens  who  might  risk  allergy  by  fiirther  exposure? 
An  excellent  model  exists  in  the  Fair  Packaging  and  Label- 
ing Act,  which  requires  ingredient  disclosure  on  consiuner 
products.  This  legislation,  initiated  by  a  desire  to  provide 
comparison-shopping  information  for  consumers,  has 
played  an  important  role  in  consimier  health  by  allowing 
people  with  specific  allergies  or  simple  health  concerns  to 
choose  (voducts  that  will  do  no  harm  or  provide  less  risk. 
The  European  dermatologic  community  is  pushing  for 
adoption  of  a  U.S.-style  law  for  health  reasons  at  this  time. 

While  the  United  States  did  well  with  consumer  prod- 
ucts, it  has  not  been  as  successful  with  salon-care  products 
distributed  for  "professional  use  only."  A  voluntary  label- 
ing program  was  recentiy  adopted  by  industry  but  appears  to 
be  falling  short  of  its  goals. 


Proceedings  of  the  National  Confekence  on  Envdonmental  Hazards  to  the  Skin 


T3 


440 


Praventhre  Approaches 

Is  it  possible  to  identify  problems  and  generate  preventive 
medicine  strategies  in  the  field  of  contact  dermatitis?  The 
Danes  have  provided  two  examples  of  how  this  can  be  done 
with  major  industries  and  high-frequeiKy  allergens. 

Cbromate  in  cement  causes  a  great  deal  of  contact 
dermatitis  in  the  construction  industry  and  was  a  frequent 
cause  of  occupational  disability  among  men  in  this  trade. 
The  addition  of  iron  in  the  fonn  of  ferrous  sulfate  makes 
cbromate  in  cement  less  Ukely  to  penetrate  skin  and  cause 
dermatitis.  A  requirement  that  ferrous  sulfate  be  added  to 
cement  in  Denmark  has  drastically  reduced  the  number  of 
affected  workers  over  the  past  1 1  years.  In  Derunark, 
nickel,  the  leading  cause  of  contact  dermatitis  among 
women  there,  as  it  is  in  our  country,  was  attacked  head-on 
by  establishing  a  standard  for  nickel  release  in  consumer 
products  that  would  be  unlikely  to  induce  allergy.  Statutory 
Order  No.  472.  June  27,  1989,  required  that  nickel-contain- 
ing objects  release  no  more  than  0.5  |ig/cmVweek. 

What  then  can  be  done  to  help  the  public  prevent 
contact  dermatitis? 

1)  Label  for  the  presence  of  known  sensitizers  those 
prxxlucts  expected  to  come  in  contact  with  human  skin 
in  routine  use.  Which  sensitizers?  We  could  start  with 
the  20  FDA-approved  items  as  reasonably  problematic 
based  on  years  of  experience  and  medical  reports  (a 
paradigm  for  this  exists  *ith  tartrazine,  a  yellow  food 
dye  the  presence  of  which  is  declared  on  products). 

2)  Set  threshold  limits  for  allergen  release  from  prxxlucts 
known  to  be  significant  cutaneous  hazards.  Standards 
for  both  nickel  and  chromate  exist  in  Denmark  and  have 
been  found  workable. 

3)  Increase  epidemiologic  surveys  to  establish  safety 
profiles  for  materials  on  the  market  for  which  a  body  of 
medical  literature  suggests  ptxiblems  exist 

4)  Establish  a  task  force  to  develop  standards  for  reporting 
new  medical  findings  to  appropriate  govenunent 
agencies  when  allergens  are  detected  by  groups  such  as 
the  North  American  Contact  Dermatitis  Group  and  the 
International  Contact  Dermatitis  Research  Group. 

5)  Increase  the  supply  of  allergens  available  for  diagnostic 
contact  dermatitis  work.  It  is  very  difficult  to  identify 
allergens  without  diagnostic  tools. 


Table  I 

The  current  twenty  allergens  approved  liy  FDA: 

benzocaine 

meicaptobenzothiazole 

colophony 

p-phenylioediamiDe 

imidiazolidinyl  mea 

cinnamic  aldehyde 

lanolin  alcohol 

caitiaimx 

neomycin  sulfate 

Ihiurammix 

fonnaldehyde 

etbylenediamine 

epoxy  lesin 

quatemum  IS 

p-teit  butylphenol  fotiruddefayde  resin 

meicapto  mix 

black  rubber  mix 

potassium  dichiDmale 

balsam  of  Peru 

References 

1.  Prystowsky  SD,  Allen  AM,  Smith  RW,  et  al.  AUergic 
contact  hypersensitivity  to  nickel,  neomycin, 
ethylenediamine  and  benzocaine.  Relationships  between 
age,  sex,  history  of  exposure,  and  reactivity  to  standard 
patch  test  and  use  tests  in  a  general  population.  Arch 
Dermatol  1979;115:959-%2. 

2.  Meiuie  T,  Rasmussen  K.  Regulation  of  nickel  exposure 
in  Denmark.  Contact  Dermatitis  1990;23:57-58. 

3.  Storrs  FJ,  Rosenthal  LE,  Adams  RM,  et  al.  Prevalence 
and  relevance  of  allergic  reactions  in  patients  patch 
tested  in  North  America  -  1984  to  1985.  J  Am  Acad 
Dermatol  1989;20:1038-1045. 

4.  Nethercott  JR,  Hobiess  DL,  Adams  RM,  et  al.  Patch 
testing  with  a  routine  screening  tray  in  North  America, 
1985  through  1989: 1.  Frequency  of  response.  Am  J 
Contact  Dermatitis  1991;2:122-129. 

5.  Wass  U,  Wahlberg  JE.  Chromated  steel  and  contact 
allergy.  Reconmiendation  concerning  a  "threshold  limit 
value"  for  the  release  of  hexavalent  chromium.  Contact 
Dermatitis  1991;24:114-118. 

6.  Flyvholm  MA.  Contaa  allergens  in  registered  chemical 
products.  Contact  Dermatitis  199125:49-56. 

7.  Avnstorp  C.  Follow-up  of  workers  from  the  prefabricated 
concrete  industry  after  the  addition  of  ferrous  sulphate  to 
Danish  cement   Contact  Dermatitis  1989;20:365-371. 

8.  Menne  T,  Brandup  F,  Thestrup-Pedersen  K.  et  al.  Patch 
test  reactivity  to  nickel  alloys.  Contact  Dermatitis 
1987;16:255-259. 


Procsdings  of  the  Nauonal  Conibidke  on  Enviiionmb(tal  Hazards  to  the  Skin 


441 


Pesticides  and  Skin  Disease 


Frances  J.  Storrs,  M.D. 


A  pesticide  is  a  substance  or  mixture  of  substances  intended 
to  prevent,  destroy,  repel  or  mitigate  any  pest  A  pesl  is 
described  as  any  plant  or  animal  (bacteria,  fiugi,  mammal. 
or  virus)  detrimental  to  man.  Other  definitions  exist  as  well, 
but  (he  one  just  mentioned  is  that  presently  used  by  the 
Environmental  Protection  Agency  (EPA). 

As  of  1991,  the  EPA  estimates  that  25,(XX)  pesticide 
formulations  exisL  These  formulations  contain  approxi- 
mately 750  active  ingredients,  of  which  200  might  be 
described  as  leading  ingredients.  Over  2.7  billion  pounds  of 
active  pesticide  ingredients  are  used  each  year  in  the  United 
Slates.  This  information,  as  well  as  information  concerning 
the  toxicity  of  these  25,000  formulations,  what  protective 
clothing  might  be  worn  to  protect  against  them,  and  what 
sorts  of  re-entry  periods  are  necessary  for  crops  being 
sprayed  with  these  pesticides,  can  be  obtained  by  contacting 
the  Pesticide  Hot  Line  (1  800/858-PEST).  This  Hot  Line  is 
an  EPA-funded  resource  located  at  Texas  Tech  University 
in  Lubbock,  Texas.  The  individuals  who  answer  the  phone 
are  knowledgeable  and  helpful.  Another  resource  for 
information  about  pesticide  use  in  the  U.S.  is  the  Farm 
Chemicals  Handbook  published  by  the  Meister  Publishing 
Company,  37733  Euclid  Avenue,  WiUoughby,  Ohio  44094, 
216^2-2000. 

Agriculture  and  Occupational  Skin  Disease 

California  is  a  good  place  to  look  for  information  about  the 
association  of  pesticide  exposure  and  industry.  Approxi- 
mately one-third  of  all  the  agricultural  workers  in  the  U.S. 
work  in  California.  California  is  also  a  state  that  has  well- 
kept  statistics  for  work-related  diseases.  These  data  are  not 
always  current,  but  by  and  large,  they  stay  within  the  same 
range  bom  year  to  year. 

According  to  the  California  data,  approximately  45%  of 
all  occupationa]  illness  in  all  work  classifications  involves 
Ifae  skin.  About  4%  of  the  California  work  force  is  em- 
ployed in  agriculture.  Fourteen  percent  of  all  occupational 
skin  disease  in  California  is  in  agriculture.  Agriculture  and 
manufacturing  present  the  greatest  occupational  skin  disease 
risk  in  California  and  in  all  of  the  United  States.  In  the  mid- 
1970s,  these  rates  were  6.1/1(X)0  employees  in  agriculture, 
3.5/1000  in  manufacturing,  and  1.8/1000  in  all  other 
industries.   Furthermore,  70%  of  all  agricultural  occupation- 
al disease  is  found  on  the  skin,  whereas  in  manufacturing, 
43%  of  occupational  disease  is  on  the  skin. 

In  1988  O'Malley  MA  and  Mathias  CGT,  coUected 
information  concerned  with  the  distribution  of  lost  work- 


time  claims  for  skin  disease  in  California  agriculture  fiDm 
1978  to  1983.=  Of  2,355,802  employees  working  in  agricul- 
nire  during  that  period  2722  lost-work-tinie  claims  for  skin 
disease  were  identified.  This  is  a  rate  of  1 1 .5  cases/10,000 
individuals  employed  in  agriculture.   Seventy-eight  percent 
of  these  individuals  were  men,  with  a  median  age  of  27.8 
years.  Further,  O'Malley  and  Mathias  note  skin  disease  that 
was  associated  by  the  workers  with  plants  accounted  for 
52%  of  the  disease,  chemicals  for  20%,  food  products  for 
13%,  and  miscellaneous  explanations  in  15%  of  the  instanc- 
es. 

It  is  widely  believed  that  the  vast  majority  of  skin 
disease  that  might  be  associated  with  agricultural  work  and 
in  particular  with  pesticides  is  not  reported.  Some  studies 
estimate  that  only  one  in  five  of  all  affected  workers  consult 
medical  help  of  any  sort.  In  a  most  unusual  study  in  1992 
Gamsky  TE,  et  al.,  visited  and  closely  examined  759 
Hispanic  woricers  in  the  grape,  citrus,  and  tomato  fields.' 
These  individuals  were  either  tipping,  pulling,  or  turning 
grape  canes  or  harvesting  citrus  and  tomatoes.  Frve  pesti- 
cides were  used  on  the  grapes,  8  on  the  citnis,  and  1 1  on  the 
tomato  crops.  Seven  himdred  forty-seven  of  the  759 
workers  were  Hispanic,  98%  were  interviewed  in  Spanish, 
and  only  1%  had  more  than  a  high  school  education. 
Depending  on  the  crop,  between  59%  and  89%  were  male. 
The  nature  of  agricultural  workers  makes  complete  repott- 
ing very  difficult  and  unless  actual  visits  are  made  to  work 
places,  as  was  done  in  the  Gamsky  study,  very  little  specific 
information  about  the  actual  presence  of  skin  disease  in 
these  work  places  can  be  accurately  assessed. 

Pesticides  and  Skin  Disease 

Pesticides  can  cause  many  different  sons  of  skin  problems, 
though  it  is  widely  believed  that  contact  dennatilis  of  either 
an  irritant  or  allergic  sort  is  that  most  often  associated  with 
pesticide  exposure.  When  Gamsky  and  his  co-workers 
visited  these  agricultural  work  places,  they  discovered  that 
12%  of  the  workers  interviewed  had  had  some  sort  of  a 
"rash"  lasting  more  than  2  days  in  the  past  12  months. 
When  they  examined  the  workers  bom  the  waist  up,  they 
found  that  27%  had  pusmles,  17%  acne,  14%  lichenified 
hand  dermatitis,  13%  keratosis  pilaris,  10%  conjimctival 
erythema,  8%  paronychia,  8%  excoriations,  2%  contact 
dermatitis,  and  0.5%  other  kinds  of  dermatitis.  None  of  the 
citrus  workers  had  contact  dermatitis,  but  0.8%  of  the 
tomato  workers  and  5.5%  of  the  grape  workers  had  contact 
dermatitis.  This  spread  of  physical  findings  highlights  the 


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75 


442 


importance  of  actually  examining  individuals  with  com- 
plaints attributed  to  pesticides  or  to  other  substances  in  the 
woitplace.  Many  of  these  findings  were  most  likely 
unrelated  to  work  and  occur  in  all  populations  to  some 
degree. 

When  Gamsky,  et  al.,  looked  specifically  at  patients 
with  lichenified  hand  dermatitis,  they  discovered  that  the 
vast  majority  of  these  people  were  grape  workers;  in  some 
work  crews,  as  many  as  50%  of  the  workers  had  lichenified 
band  dermatitis.'  Only  12%  of  tomato  workers  and  4.2%  of 
citrus  workers  had  this  problem.  Individuals  working  with 
grapes  were  not  harvesting,  but  manipulating  the  grape 
canes.  When  the  workers  wore  gloves,  they  had  less 
difficulty.  It  was  noted  that  there  was  more  contact 
dermatitis  in  grape  fields  treated  with  multiple  pesticides, 
whereas  lichenified  hand  dermatitis  was  tremendously 
increased  in  grape  areas  that  used  sulfur  only  (34%  vs  17%) 
as  opposed  to  multiple  pesticide  use. 

In  1989,  O'Malley,  et  al.,  noted  that  some  agricultural 
areas  have  almost  no  reported  pesticide  association  with 
skin  disease,  whereas  others  have  a  significant  amount' 
This  was  the  case  with  forestry,  where  there  were  no 
complaints  of  pesticide-associated  disease,  despite  the  faa 
that  many  pesticides  are  used  in  forestry.  In  forestry,  600 
cases  per  10,000  workers  were  attributed  to  plants,  and 
these  plants  were  almost  always  poison  oak.  This  was  in 
contrast  to  horticulture  and  crop-related  workers,  who  had  a 
rate  of  skin  disease  of  23/10,000  workers,  which  was 
associated  with  pesticides,  and  36/10,000,  which  was 
associated  with  plants  (both  poison  oak  and  otho-  plants  that 
were  mostly  irritant). 

Pesticides  can  cause  many  different  skin  diseases: 

1)  Irritant  contact  dermatitis  has  been  associated  with 
Omite  (propargite),  methyl  bromide,  petroleum  prod- 
ucts, sulfur,  captan  and  glyphosphate.  O'Malley  noted 
that  propargite  (Omite*)  was  the  #1  pesticide  associated 
with  skin  disease  in  California  in  the  1978-83  case 
material  and  accounted  for  1 8.7%  of  the  cases.  Sulfiir 
and  glyphosphate  (Round-Up*)  accounted  for  15.1% 
and  4.1%  respectively  of  die  cases.  It  was  felt  that  all  of 
these  cases  most  likely  induced  an  irritant  contact 
dermatitis,  which  is  almost  always  the  most  common 
form  of  contact  dermatitis. 

2)  Allergic  contact  dermatitis  has  been  associated  with 
caitiamates,  thiurams,  organophosphates,  captan, 
organomeroirials,  pyrethrum,  and  triazines  (anilazine  or 
dyrene). 

3)  Chloracne  has  been  associated  widi  pentachlorophenol 
and  dioxins  present  as  degradation  products  in  some 
halogenated  aromatic  compounds  (chloracneagins). 

4)  Folliculitis  has  been  associated  with  various  oils,  with 


kerosene,  and  with  chlorinated  hydrocarbons. 

5)  Depigmentation  has  been  associated  with  various 
phenolics,  such  as  carbyne. 

6)  Photo-allergic  contact  dermatitis  has  been  attiibuted  to 
etfaoxyquin  and  other  growth-stimulating  compounds, 
as  well  as  to  salicylanilides.  The  salicylaniUdes  as  well 
as  phenothiazine  have  been  precipitants  of  photosensi- 
tivity, but  mostly  in  the  past,  as  they  are  Uttle  used  at 
(be  present  time. 

7)  Nail  changes  have  been  associated  with  skin  diseases; 
paraquat  is  the  chief  culprit 

8)  Contact  urticaria  has  been  associated  with  DEET. 

9)  Ulcerations  of  various  sorts  can  be  caused  by  any 
pesticide  that  causes  severe  irritation  or  a  chemical 
bum. 

10)  Hemorrhagic  necrosis  has  been  attributed  to  coumarin 
derivatives. 

1 1)  Porphyria  has  been  precipitated  by  epidemics  of 
hexachlorobenzene  exposure  in  the  past  and  has  also 
been  rarely  associated  with  phenoxyacetic  acid  expo- 
sures. 

12)  Paresthesias  have  been  attiibuted  to  synthetic  pyre- 
throids. 

Other  pesticides  that  have  appeared  on  the  list  of 
pesticide-associated  skin  diseases  generated  by  O'Malley, 
Mathias  and  Coye  in  1989  include  methyl  bromide  (3.3%), 
captan  (2.0%),  paraquat  (1.2%),  diazinon  (0.9%),  carbaiyl 
(0.6%),  malathion  (0.6%)  and  zineb  (0.4%).  The  natijre  of 
the  disease  attributed  to  these  pesticides  is  not  described.  A 
few  of  them  may  have  been  allergic' 

Pesticide-associated  skin  disease  is  much  more  common 
in  individuals  ditecUy  working  with  pesticides.  These 
include  people  such  as  ground  appUcators  and  actual  field 
workers.  Nursery  workers  have  low  associations  of  pesti- 
cide-related skin  disease,  as  do  people  working  in  forestry. 

An  important  thing  to  highlight  is  that  in  these  smdies, 
few  if  any  instances  of  scientific  documentation  exist  that 
directly  indict  a  pesticide  as  causing  a  large  group  of  cases 
of  allergic  contact  dermatitis.  The  vast  majority  of  such 
reports  are  very  rare  and  exist  as  isolated  case  reports. 
There  are  better  studies  documenting  the  association  of 
pesticide  and  irritant  contact  dermatitis.  A  particulariy  well 
known  one  is  that  of  Saunders  DI,  et  al.,  which  described  an 
outbreak  of  Omite-CR*  induced  dermatitis  among  more  than 
100  orange  pickers  in  Tulare  County,  California.' 

Chloracne 

Certainly  one  group  of  chemicals  that  is  well-studied  in 
association  with  skin  disease  includes  the  chloracneagins. 
These  halogenated  aromatic  compounds  include 


76 


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443 


polyhalogenated  biphenyls  (for  example.  PCBs), 
polyhalogenated  dibenzofurans,  contaminants  of 
polychlorophenyl  compoimds  such  as  2,4.5-T  (a 
phenoxyacetic  acid),  pentachlorophenol  and 
trichlorophenol.    2,3,7,8-letrachlorodibenzoparadioxin 
(TCDD)  does  appear  as  a  contaminant  of  these  chemicals 
and  can  be  associated  with  chloracne. 

These  chemicals  are  potent  teratogens  as  well  as 
acneagins  and  the  skin  is  of  particular  interest  in  their  study, 
in  that  changes  in  the  skin  can  be  one  of  the  earliest  indica- 
tors of  their  presence  in  the  environment.  Chloracne  is 
note-worthy  clinically  in  that  it  presents  with  many  straw- 
colored  cysts  that  look  like  simple  blackheads  and  occur 
classically  lateral  to  the  eye,  behind  the  ear,  on  the  cheeks, 
forehead  and  neck,  and  on  the  external  genitalia  (particularly 
the  scrotum).   Individuals  with  chloracne  itch,  sometimes 
develop  hypertrichosis  and  hyperpigmentation,  and  com- 
plain of  skin  fragility.  The  onset  of  this  problem  can  occur 
within  weeks  of  exposure  to  the  substances  and  can  last  for 
years. 

Pesticides  are  Also  Used  Non-Agriculturally 

Pesticides  used  in  agriculture  often  are  used  non-agricultur- 
ally  as  well.  Dithiocarbamates  may  find  use  in  the  rubber 
industry,  as  may  thiurams.  C^tan  can  be  used  in  cosmetics 
and  has  been  used  in  the  past  in  popular  shampoos. 
Dinitrochlorobenzene  is  used  by  physicians  to  treat  some 
diseases  and  to  detect  the  ability  to  mount  an  allergic 
reaction.  Mercurials  are  used  as  preservatives.  Pyrethroids 
are  used  to  treat  diseases  such  as  lice  and  scabies,  as  is 
lindane.  Warfarin  is  used  as  a  medical  anticoagulant  and 
isothiazolinones  are  used  as  preservatives  in  cosmetics  and 
in  the  woriqplace,  in  paints  and  coolants.  Malathion  is  used 
topically  in  some  countries  to  treat  cutaneous  infestations. 
Formaldehyde  is  used  as  a  preservative  in  cosmetics,  paints 
and  coolants  and  also  finds  use  in  many  construction 
environments,  such  as  in  insulation  in  a  polymerized  ftnm. 
Phenothiazines  have  medicinal  uses. 

Plants  as  Actual  Cause  of  Some  Pesticide-Suspected 
Dermatitis 

It  is  im(X>rtant  to  remember  that  all  agricultural  skin  disease 
is  not  pesticide-induced.  The  lack  of  a  suspicion  of  pesti- 
cide-induced disease  in  the  California  forestry  industry  has 
already  been  noted.  Of  the  other  sorts  of  explanations  for 
agriculturally-associated  skin  disease,  plants  must  be  placed 
very  near  the  top  of  the  list  By  and  large,  the  vast  majority 
of  diseases  that  are  at  first  attributed  to  pesticides  are  finally 
associated  with  plant  exposure  in  the  workplace.  Chemicals 
containing  furocoumarin  are  an  excellent  example  of  plant- 
associated  agricultural  dermatitis.  In  Oregon  and  in  Califor- 
nia, small  epidemics  of  phyto-photo-dermatitis  have  been 


associated  with  fennel  and  celery.  "Mayweed"  or  "dog 
fennel"  (Anthemis  coiula)  has  been  reported  to  cause  severe 
irritant  dermatitis  in  fields  where  it  grows  as  a  weed.  In 
these  instances,  workers  were  exposed  to  plants  that  had 
been  treated  with  pesticides,  but  it  was  the  alkaloids  in  the 
weeds  (Anthemis  cotuta)  that  correctly  explained  the 
extensive  bullous  diseases  that  inany  experienced 

In  addition  to  these  instances  of  phyto-pholo  and  irritant 
dermatitis,  there  are  also  cases  of  allergic  contact  dermatitis 
that  can  be  traced  to  plants  after  having  been  attributed  at 
first  blush  to  pesticides.   Plants  containing  sesquiterpene 
lactones  in  the  Compositae  family  of  plants  are  particularly 
suspect  here.  These  plants  are  often  weeds  (sagebrush, 
ragweed,  sneeze  weed),  but  can  also  be  ornamental  plants 
(the  common  florist's  chrysanthemum).   People  working 
with  these  plants,  such  as  florists  and  gardeners,  often 
erroneously  suspect  pesticides  as  the  source  of  their  prob- 
lems. In  short,  the  entire  working  environment  of  the 
agricultural  worker  must  be  examined  before  pesticides  are 
absolutely  indicted  as  the  cause  of  skin  complaints. 

Future  Studies 

A  problem  with  pesticide-associated  skin  disease  is  that  the 
actual  prevalence  of  skin  disease  in  workplaces  where  there 
is  a  significant  amount  of  pesticide  exposure  has  not  been 
studied  first-hand.  Dr.  Michael  O'Malley  and  his  co- 
workers at  the  Worker  Health  and  Safety  Branch  of  the 
California  Department  of  Food  and  Agriculture  in  Sacra- 
mento are  making  efforts  to  do  exactly  these  sorts  of  studies 
at  the  present  time.  It  is  suspected  that  irritant  contact 
dermatitis  associated  with  pesticides  is  much  more  wide- 
spread and  probably  much  more  disabling  than  has  been 
appreciated.  The  usual  nature  of  this  working  population 
(migrating,  and  relatively  uneducated)  makes  it  particularly 
difficult  to  study.  Good  studies  in  the  future  will  need 
excellent  fiinding  that  will  allow  access  to  stable,  identifi- 
able populations.  Those  employers  who  have  the  means  of 
tracking  their  workers  and  who  will  allow  access  to  them, 
will  be  able  to  provide  the  populations  that  will  be  most 
profitably  explored.  Case-controlled  studies  that  have 
controlled  populations  and  a  prospective  cohort  will  be  most 
valuable. 

In  addition  to  these  stable  populations,  future  studies 
will  need  to  examine  the  possible  presence  of  enhancing 
factors  in  the  workers,  such  as  atopy  (asthma,  hay  fever  or 
eczema  in  the  worker  or  a  first-degree  relative).  It  is 
increasingly  appreciated  that  an  atopic  diathesis  in  workers 
can  predispose  them  to  dermatitis,  particularly  in  wet-work 
environments.  Towards  this  end,  funding  for  clinical 
studies  directed  towards  contact  dermatitis  and  especially 
toward  hand  dermatitis  should  be  sought 

It  is  important  that  the  background  of  other  skin  diseas-  - 


Proceedings  of  the  Natxinal  Conference  on  Environmental  Hazards  to  the  Skin 


444 


es  that  have  nothing  to  do  with  pesticides  or  plant  exposure 
be  documented,  and  that  cases  not  be  inappropriately 
attributed  to  pesticides.  Self-medication  also  needs  to  be 
considered.  Environmental  determinants  such  as  tempera- 
ture and  humidity,  the  presence  of  wet-work  and  other 
iiritanLs  in  the  workplace,  plants  and  insects  that  are  present, 
and  protective  clothing  that  is  worn  are  all  features  that  need 
to  be  known  in  order  to  impact  the  prevalence  of  this 
complaint.  Even  the  Umited  studies  that  have  been  done  to 
this  date  show  that  protective  clothing  has  greatly  dimin- 
ished the  prevalence  of  pesticide-associated  complaints. 

In  addition  to  actual  skin  diseases,  it  is  important  to 
appieciate  that  pesticides  are  readily  absorbed  through  the 
skin.  It  is  believed  that  in  addition  to  the  respiratory  and 
oral  routes,  percutaneous  penetration  is  a  prominent  expla- 
nation for  acute  and  chronic  organophosphate  poisoning. 
There  have  even  been  instances  of  deaths  associated  with 
the  percutaneous  penetration  of  unusually  potent  pesticides 
such  as  paraquat 

All  agricultural  skin  disease  is  not  pesticide-induced. 
Scientific  documentation  of  definite  pesticide-induced  skin 
disease  is  not  presently  available,  but  can  be  acquired, 
particularly  if  well-mounted  studies  are  appropriately 
funded.  In  instances  where  pesticide  dermatitis  is  docu- 
mented, there  is  little  question  that  irritant  dermatitis  is  the 
most  common  pesticide-induced  skin  disease.  It  is  impor- 
tant to  remember  that  chemicals  used  as  pesticides  are  also 
used  elsewhere.  Patch-testing  can  document  the  presence  of 
these  chemicals  as  allergens,  but  this  testing  must  be  done 
very  cautiously;  at  the  present  time,  accurate  patch-testing 
concentrations  do  not  exist  CaUfomia  Department  of  Food 
and  Agriculture  patch-testing  studies  are  in  progress  now. 

Well-supported  studies  that  rely  on  scientific  methodol- 
ogy and  that  have  direct  access  to  involved  workers,  are 
most  likely  to  document  the  magnitude  of  this  problem. 
The  magnitude  of  pesticide-associated  skin  disease  is 
suspected  to  be  greater  than  is  presently  described.  The 
nature  of  the  working  population  makes  these  studies 
difficult  but  they  are  greatly  needed  and  the  working 
population  deserves  them. 


References 

1 .  Farm  Chemicals  Handbook.  Willoughby:Meister 
Pubhshing  Co. 

2.  O'Malley  MA.  Mathias  CGT.  Distribution  of  lost- 
work-tim  claims  for  skin  disease  in  California  agricul- 
ture: 1978-1983.  Am  J  Indust  Med  1988;14:715-720. 

3.  Gamsky  TE.  McCurdy  SA.  Wiggins  P,  et  al.  Epidemi- 
ology of  dermatitis  among  California  farm  workers.  J 
Occup  Med  1992;34(3):304-310. 

4.  O'Malley  MA.  Mathias  CGT,  Coye  MJ.  Epidemiology 
of  pesticide-related  skin  disease  in  California  agricul- 
ture: 1978-1983.  In:  Dosman  JA,  Cockroft  DW.  eds. 
Principles  of  health  and  safety  in  agriculture.  Boca 
Raton:CRC  Press,  1989;301-304. 

5.  Mathias  CGT.  Epidemiology  of  occupational  skin 
disease  in  agriculture.  In:  Dosman  JA,  Cockroft  DW. 
eds.  Principles  of  health  and  safety  in  agriculture.  Boca 
Raton:CRC  Press.  1989;  285-287. 

6.  Saunders  DL.  Ames  RG,  Knaak  JB.  et  al.  Outbreak  of 
Omite-CR-induced  dermatitis  among  orange  pickets  in 
Tulare  County.  California.  J  Occup  Med 
1987;29(5):409-414. 

7.  Hogan  DJ.  Pesticides  and  other  agricultural  chemical. 
In:  Adams  RM,  ed.  Occupational  skin  disease. 
Philadelphia:W.B.  Saunders.  1990;546-577. 

8.  Shmunes  E.  Keil  J.  The  role  of  atopy  in  occupational 
dermatoses.  Cont  Derm  1984;11:174-178. 

9.  Lammintausta  K.  Kalimo  K.  Atopy  and  hand  dermatitis 
in  hospital  wet  work.  Cont  Derm  1981;7:301-308. 


PROCIEDINaS  OF  IKE  NxnONAL  CoNFEXENCE  ON  ENVDtONMEIirAL  HAZARDS  TO  THE  SkIN 


445 


Cosmetics 

WilmaF.Beigfeld,M.D. 


Cosmetics  are  defuied  by  the  Federal  Food,  Drug,  Cosmetic 
Act  of  1938  as  substances  or  preparations  used  for  cleans- 
ing, altering  appearance,  or  promoting  attractiveness.   Soaps 
used  for  toiletry  and  household  cleansing  are  excluded.  The 
Cosmetic,  Toiletry,  and  Fragrance  Association  (CTFA) 
broadly  defines  this  $19  billion  US  industry  as  toiletries 
33%.  hair  care  22%,  skin  care  18%,  fragrances  15%,  and 
face  makeup  14%. 

The  1993  International  Cosmetic  Ingredient  Dictionary 
.  Usts  6,105  different  ingredients  and  25,605  chemical 
synonyms  and  trade  names.  This  dictionary  represents  an 
international  collaborative  effort  by  the  CTFA,  Committee 
De  Liaison  Des  Associations  Europeans  De  Illes  3  De  La 
Peifime  De  Products  Cosmetiques  De  Toilet  (COUPA), 
European  Community  (EC)  and  the  Japanese  Cosmetic 
Industry  Association  (JCIA).  "This  collaborative  effort  was 
initiated  so  that:  ( 1 )  Consumers  are  assured  that  ingredients 
are  identified  by  single  labeling  name  regardless  of  source 
of  raw  materials  or  nationality  of  the  original  product;  (2) 
Dermatologists  and  other  speciaUsts  are  assured  of  widely 
disseminated  scientific  information  which  helps  identify 
agents  responsible  for  adverse  reactions;  (3)  Scientists  are 
assured  that  information  from  scientific  and  other  technical 
publications  will  be  referenced  under  a  uniform  name  and 
that  multiple  names  for  the  same  material  will  not  lead  to 
confiision,  misidentification,  or  loss  of  the  essential  infor- 
mation; and  (4)  The  cosmetic  industry  is  able  to  track  the 
safety  and  regulatory  status  of  ingredients'  efficacy  on  a 
worldwide  basis,  enhancing  its  ability  to  market  safe 
products  that  are  in  compliance  with  a  variety  of  national 
regulations".  (International  Cosmetic  Ingredient  Dictionary 
Sthed.  VIU) 

It  is  estimated  that  persons  use  one  cosmetic  product 
daily.  These  are  applied  once  to  multiple  times  daily  to 
sldn,  mucus  membianes,  eyelids,  hair,  and  nails.  Products 
are  described  as  "leave-on"  or  "rinse-off"  and  may  be  in 
aerosols  or  ingested. 

Cosmetics  can  be  separated  into  two  broad  groups, 
diose  that  are  used  mainly  to  beautify  and  those  that  have 
therapeutic  or  preventive  properties.  The  degree  of  allow- 
able change  to  the  skin  as  a  therapeutic  or  preventive 
property  in  a  cosmetic  product  is  solely  dependent  on  the 
view  of  the  Federal  Food  and  Drug  Administration  (FDA). 
In  cosmetics,  the  active  ingredients  are  present  in  lower 
concentrations  than  in  over-the-counter  (OTC)  preparations 
and/or  prescription  pnxlucts.  Products  controlled  by  the 
FDA,  OTC  Division,  iiKlude  sunscreens,  OTC  microbials. 


keralolytics  and  wart  preparations. 

Regulations 

The  cosmetic  industries  are  regulated  primarily  by  two 
federal  laws:  The  Federal  Food,  Drug  and  Cosmetic  Act  of 
1938  with  its  color  additive  amendment  of  1962,  and  the 
Fair  Packaging  Label  Act  of  1966.  The  important  food 
additive  amendment  of  1958,  often  referred  to  as  the  De 
Laney  Amendment,  is  probably  one  of  the  most  important 
regulatory  amendments  for  cosmetics.  The  amendment 
states  "no  additive  will  be  deemed  to  be  safe  if  it  is  found  to 
induce  cancer  when  ingested  by  man  or  animal  or  if  it  is 
found,  after  testing  appropriate  for  evaluation  of  the  safely 
of  food  additives,  to  induce  cancer  in  man  or  animal."  This 
amendment  emphasizes  that  cosmetics  and  foods  are  to  be 
safe  for  consumer  use.  The  regulation  of  these  acts  and 
laws  is  the  responsibility  of  the  FDA  and  the  Federal  Trade 
Commission  (FTC).  Under  the  Federal  Food  and  Drug 
Administration  Act,  a  voluntary  FDA  registration  has  been 
initiated  in  regard  to  new  products,  ingredients  within 
products  experienced  in  the  market,  and  warnings  of 
possible  adverse  events.  In  the  1980s,  a  number  of  domes- 
tic issues  concerning  animal  testing  and  cosmetic  labeling 
arose.  In  1986,  Proposition  65,  the  California  Safe  Drinking 
Water  Intoxicant  Enforcement  Act,  required  manufacturers 
to  prove  that  the  ingredients  in  their  products  contained  no 
significant  risk  of  causing  cancer  or  reproductive  toxicity.  If 
not,  a  manufacturer  would  be  required  to  include  a  warning 
label  on  any  product  containing  an  ingredient  "known  to 
cause  cancer  or  reproductive  toxicity."  The  warning 
requirements  took  effect  in  February  1988. 

In  1987,  the  color  additive  amendment  of  I960  was 
interpreted  to  mandate  a  stria  inteqiretation  of  the  De  Laney 
anticancer  clause  as  it  applied  to  cosmetics.  In  1988, 
Oregon  Congressman  Ronald  Weyden  held  a  series  of 
hearings  concerning  cosmetic  safety  and  inadequate  federal 
regulation.  In  response  to  those  hearings,  the  CTFA 
launched  three  initiatives:  (1)  a  voluntary  ingredient 
labeling  pfx>gram  for  cosmetic  products  sold  exclusively  in 
salons;  (2)  an  effort  to  increase  industry  participation  in  the 
voluntary  reporting  program;  and  (3)  the  preparation  of  a 
report  that  listed  the  status  of  each  of  the  approximately 
1,(XX)  allegedly  toxic  chemicals  contained  in  cosmetics. 
Existing  FDA  safety  regulations  ptigrams  include:  (I)  a 
cosmetic  product  ingredients  statement  program;  (2)  a 
cosmetic  establishment  registration  program;  and  (3)  a 
product  experience  group  for  adverse  reactions.  Other  non- 


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federal  regulated  controls  include  the  CTFA's  safety 
commiOee,  Ibe  Cosmetic  Ingredient  Review  Panel(CIR) 
developed  in  1972,  Consumer  Federatioa  of  America, 
scientific  publications  of  adverse  reactions,  industries' 
product  development  and  pieinatketing  testing,  and  industri- 
al competition.  The  mamity  of  safety  monitoring  of 
cosinetics  is  voluntary  and  includes  FDA,  the  industry,  the 
consumer,  the  scientist,  and  industrial  competitiotL  Interna- 
tional industry  also  sponsors  a  self-regulatory  group,  The 
International  Fragrance  Association  located  in  Geneva. 
Switzeriand. 

Cosmetic  Ingredient  Review 

The  Cosmetic  Ingredient  Review  Panel,  established  in  1976 
by  the  CTFA,  has  a  primary  mission  to  look  at  specific 
ingredients  and  their  safety.  It  has  seven  official  members 
v^th  expertise  in  dermatology,  toxicology,  chemistry  and 
pathology,  and  itKludes  representatives  from  consumer 
groups,  industry  and  the  FDA.  The  panel  considos  chemis- 
try, use,  biology,  animal  toxicology,  phototoxicology, 
mutagenicity,  carcinogenicity,  teratogenicity,  clinical 
assessment  of  safety  and  epidemiology.  Panel  reviews  and 
final  tepoits  are  published  in  the  Journal  of  the  American 
College  of  Toxicology.   Pres«itly  serving  on  the  Committee 
ate  Wilma  F.  Bergfeld,  MX).,  Chair,  dermatologist  and 
dermatopathologist;  Donald  V.  Belsito,  M.D.,  dermatologist 
and  inununologist;  Curtis  Klassen.  PhJ).,  toxicologist; 
William  W.  Carlton  DVM,  PhX>.,  aniinal  toxicologist  and 
pathologist;  Arnold  L.  Schroeter,  MX).,  dermatologist, 
dermatopathologist,  and  immuiK)pathologist;  Thoinas 
Slaaga,  Ph.D.,  toxicologist;  and  Ronald  Shank,  PhX>., 
toxicologist 

As  of  1993,  404  ingredients  had  been  reviewed  for 
safety.  Of  these  404  ingredients,  1 1  were  deemed  unsafe; 
information  for  27  was  insufficient  to  determine  safety,  aixi 
S7  were  found  to  be  safe  with  restrictions,  leaving  279  safe 
as  used  (Table  I)- 

In  review,  of  the  381  ingredients  listed  by  Rep.Weyden 
that  are  used  in  cosmetics,  nine  appear  on  the  CIR  priority 
list  and  40  have  been  reviewed.  Thirty-one  of  the  40  have 
had  their  reviews  completed  Of  these,  three  hair  dyes  were 
found  unsafe  due  to  possible  carcinogenicity.  Data  on 
urocanic  acid  and  arachanotic  acid  were  deemed  insufficient 
to  determine  their  safety.  Both  these  ingredients  ate  suspect 
for  immunosiqipression,  carcinogenicity,  or 
photocatcinogenicity. 

Advene  Events  —  Clinical  Eiperience 

Cosmetics  aie  considered  extremely  safe,  representing  less 
than  a  2%  risk  of  contact  dermatitis  or  allergy  in  the  general 
population.   Possible  immunosuppression,  carcinogenicity, 
photocarcinogenicity  are  new  issues  for  soine  of  the  lesser- 


used  cosmetic  ingredients  currently  under  review  by  the 
CIR. 

The  classic  adverse  reactions  to  cosinetics  have  been 
contact  allergy  (the  most  common),  irritation,  acne,  pigmen- 
tary changes  and  nail  and  hair  damage.  The  prevalence  of 
these  reactions  has  been  assumed  to  be  between  2%  and 
26%  of  the  population  as  reported  by  dermatologists  and  the 
public  respectively.  The  major  allergens  that  have  been 
identified  are  mainly  preservatives,  fragrances,  emulsifiers, 
and  occupational  exposiue.  The  most  common  culprits  in 
the  occupational  exposure  group  are  paraphenylenediamine 
(hair  dye),  glyceryl,  tfaioglyoolate  (hair  straightener)  and 
nickel  sulfate  (instruments).  A  major  occupatioiud  irritant 
has  been  secondary  to  ammonium  thioglycolate  (cold  wave 
chemical)  and  detergents.  Skin  allergies  have  been  noted 
primarily  in  skin  care  products  56%,  nail  cosmetics  13%, 
perfumes  11%,  hair  cosmetics  8%,  deodorant  7%,  lip 
cosmetics  5%.'  The  common  profile  for  cosmetic  reaction 
is  as  follows:   female>male,  white>non-white,  with  primary 
involvement  of  the  head  and  neck,  60%  in  individuals  with 
iHxmal  sldn.  Only  21%  of  individuals  have  concomitant 
other  skin  disease  such  as  atopic  dermatitis.  In  addition,  the 
cosmetic  reaction  is  known  to  last  eight  days,  in  86%  of  the 
individuals  [North  American  Contact  Dermatitis  Group 
(NACDG)  repon].  The  at-risk  individuals  are  diose  with 
(I)  presence  of  a  dermatitis,  and  (2)  Celtic,  Mediterranean 
or  black  derivatioiL 

Consumer  Opinion 

In  1992,  the  American  Academy  of  Dermatology  (AAD) 
conducted  a  public  opinion  survey  of  1,800  individuals 
prior  to  its  National  Conference  on  Envirotunental  Hazards 
to  the  Skin.  This  survey,  which  polled  clinical  case  expen- 
ence,  found  that  females  were  at  greater  risk  than  males  for 
cosmetic  adverse  events  (21%  in  females  and  3%  in  males) 
with  metal  allergy  (20%  female  vrasus  6%  males).  Occupa- 
tional-induced, adverse  reactions  similarly  were  higher  in 
females  (9%)  than  males  (1.3%).' 

Conclusions 

Cosmetics  are  remarkably  safe  products,  but  their  mass 
pubUc  use  has  resulted  in  a  number  of  adverse  reactions. 
These  iiKlude  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  etixir 
method.  Studies  of  the  relation  of  contact  dermatitis  to 
cosmetics  in  the  US  and  Europe  found  that:  (I)  4%  to  5%  of 
patch-tested  patients  had  contact  dermatitis  to  cosmetics;  (2) 


nKKEHXNas  OF  HE  NATntuL  CoMOBCE  ON  ENvncNMDtrAL  Hazaus  to  the  SnN 


447 


the  cause  in  many  cases  was  noc  apparent  to  either  the  patient 
or  physician;  (3)  skin  care  and  hair  care  pfxxhicts  account  for 
most  reactions;  (4)  most  reactions  occur  in  adult  women;  (S) 
face  and  periorbital  regions  were  the  most  commonly 
involved;  and  (6)  fiagrances  and  (Hcservatives  were  the  most 
common  causes  of  skin  reactions.  Groups  instrumental  in 
reviewing  the  safety  of  US  cosmetic  ingredients  are:  Federal 
Food  and  Drug  Administration,  the  Cosmetic  Ingredient 
Review  Ptxigram,  the  Research  Institute  of  Fragrance 
Materials,  and  the  North  American  Contact  Dermatitis 
Group. 

References 

1.  Opinion  Research  Corporation.  Public  Communication, 
ItK.,  for  the  American  Academy  of  Dermatology. 
Environmental  hazards  to  the  skin.  1992. 

2.  Adams  RM,  Maibach  HI.  A  five-year  study  of  cosmetic 
reactions.  J  Am  Acad  Dermatol  198S;13:1062-1069. 

3.  Andersen  FA.  Annual  Report  of  cosmetic  ingredient 
review,  CTFA.  1993. 

4.  Andersen  FA.  CIR  Compendium.  Discussion  and 
conclusion  of  CIR  cosmetic  ingredient  safety  assess- 
ment February  1,  1994.  Abstract 

5.  Bergfeld  WF,  Elder  RL,  Schroeter  AL.  The  cosmetic 
ingredient  review  self-regulatory  safety  program. 
Dermatol  Clin  1991;2:105-122. 

6.  deGrool  AC.  Cutaneous  hazards  associated  with  the 
uses  of  cosmetics  in  the  enviroiunental  threat  to  skin. 
Endorsements:  G  Plewig,  Martin  Dunitz  1992,  United 
Kingdom,  Lotulon,  pp  173-176. 

7.  Eiermann  H,  Larsen  W,  Maibach  HI,  et  al.  Introspective 
study  of  cosmetic  reactions  1977-1989.  J  Am  Acad 
Dermatol  1982;909-917. 

8.  Federal  Food  and  Drug  Cosmetic  Act  as  Amended, 
ChaptCT  Vl-Cosraetics.  1989;  Section  601,  602, 
603:140-141.  Supplement  of  Document  US  Environ- 
ment Printing  Office,  Washington,  DC  20402. 

9.  FDA's  cosmetic  handbook.  US  Department  of  Health 
and  Human  Services.  Public  Health  Sovice,  Food  and 
Drug  Administration,  October  IS,  1992. 

10.  Larsen  WG,  et  al.  A  primer  on  cosmetics.  J  Am  Acad 
Dermatol  1991. 

11.  Marks  JG.  Cosmetics.  In:  Adams  R,  ed.  Medical 
occupational  skin  disease.  2nd  ed.  WB  Saunders  Co.; 
1990:326-348. 


12.  Marks  JG,  DeLeo  V A.  Cosmetics  and  fragrances.  In: 
Contact  and  occupational  dermatology.  Mosby  Year 
Boot  1992:134-156. 

13.  Menninger  J,  McEveis  GN,  eds.  International  cosmetic 
ingredient  dictionary  association.  5th  ed.  The  Cosmetic 
Toiletry  and  Fragrance  Association;  1993. 


Table  I. 

Ingredients  Deemed  Unsafe  By  CTFA 

AnItaaicnifaU'Aiilknidm 

chloracetamide 
foimalddiyde 
P-hydroxyanisole 
'Methamine 
Dyes 

HCBhie#l 

4  methoxy-m-pbenylenediainine 
4  methoxy-m-phenylenediamine  sulfate 
4  methoxy-m-phenylenediamine  Hcl 
'HydroquinoDe 

Ollicn 

"monoethanolainiiie 
"polyounetbyleiie  urea 

Restricted  Use: 

•Only  rinse  off 
**Liinit  concentratioa 


PtOCXEDINGS  OF  IKE  NAnOMAL  CoNRSENCE  ON  ENVBONMEOTAL  HaZAKIS  TO  1HE  SlON 


448 


Perspectives  on  E>mronmental 
Hazards  to  the  Skin 


RtOCBDINCB  OF  THE  NaIUNAL  CoNBtBKE  ON  ENVnONMENTAL  HAZARDS  TO  THE  SdN 


449 


One  Dermatologist's  Involvement 
IN  Local  Environmental  Issues 

Robert  M.  Soderstrom,  M.D. 


President  Bergfeld,  fellow  members  of  the  Academy  and 
guests.  I  am  honored  to  address  this  conference  on  the 
environment  convened  by  the  American  Academy  of 
Dermatology.  I  have  been  asked  today  to  describe  my 
experience  as  chair  of  the  environmental  committees  for 
both  the  Genesee  County  Medical  Society  of  Flint,  Michi- 
gan, and  the  Michigan  State  Medical  Society.  It  has  been 
an  interesting,  in  some  cases  eye-opening,  in  all  cases 
stimulating  and  rewarding  involvement  Over  time,  we 
have  learned  some  valuable  lessons,  and  I  think  we  have 
developed  some  guidelines  that  might  be  useful  for  those  of 
you  considering  local  involvement  in  environmental  issues. 
I  am  happy  the  Academy  has  had  the  insight  and  determina- 
tion to  give  these  issues  the  focus  they  deserve. 

Grass  Roots:  Local  Medical  Societies 

My  involvement  as  a  physician  began  in  earnest  in  the  fall 
of  1989.  The  issue  was  one  peripheral  to  most  dermatolo- 
gists: the  landfill  disposal  of  so-called  low-level  radioactive 
waste.  Michigan  had  been  selected  as  one  of  the  repository 
states,  and  several  midwestem  states  were  to  send  their 
radioactive  waste  there  for  disposal.  One  of  the  rural 
communities  selected  as  a  potential  disposal  site  was  not  far 
from  Flint  Several  people  from  that  community  ap- 
proached our  county  medical  society  when  they  were  told 
by  the  state  that  it  was  American  medicine  that  was  respon- 
sible for  the  need  to  establish  a  dump  site  in  their  midst  and 
one  that  would  be  radioactive,  it  was  estimated,  for  at  least 
500  years.  They  wanted  to  know  what  in  the  world  Ameri- 
can medicine  was  doing  that  would  require  such  a  site. 

When  they  first  came  to  us,  frankly,  we  didn't  know  the 
answer  to  that  question.  As  physicians  providing  them  with 
care,  however,  we  felt  we  had  a  responsibility  to  find  out 
We  appointed  an  environmental  committee,  which  I  agreed 
to  chair,  and  we  began  to  investigate  the  issue. 

To  make  a  long  story  short,  we  soon  found  out  that 
American  medicine  contributes  very  little,  indeed,  to  a  500- 
year  radioactive  waste  dump.  Clinical  medicine  produces 
virtually  no  long-lived  radioactive  waste.  Research  medi- 
cine produces  a  tiny  amount  and  even  those  isotopes  are 
ones  that,  for  the  most  part,  dissipate  in  a  year  or  two. 
Virtually  all  the  long-lived  radioactivity  in  a  radioactive 
dump  site  was,  in  fact  a  byproduct  of  the  power  industry, 
but  the  powers-that-be  were  happy  to  let  medicine  seem  to 


be  the  reason  such  a  dump  was  being  established. 

The  process  we  followed  served  us  well,  and  it  is  the 
process  I  wish  to  focus  on.  not  the  issue.  We  had  a  small 
committee,  six  people,  and  we  insisted  that  one  of  them  be  a 
radiologist  given  the  nature  of  the  problem.  We  decided  to 
develop  a  fully  referenced  position  paper,  just  like  we  would 
if  we  were  planning  pubhcation  in  a  medical  journal.  It 
outlined  the  different  types  of  radioactive  waste  and  dis- 
cussed our  concerns  with  trying  to  store  it  for  hundreds  of 
years  in  a  water-logged  environment  like  Michigan's.  It 
addressed  the  health  concerns  of  possible  exposure  of  the 
community  to  long-lived  radioactive  isotopes,  and  it 
concluded  with  our  reasons  for  opposing  such  a  site  in 
Michigan  and  our  proposals  for  alternatives.  We  gained 
approval  for  the  position  paper  from  the  environmental 
committee  and  then  we  asked  for  the  approval  of  the  23- 
member  county  society  board.  Again,  we  made  a  special 
effort  to  involve  two  radiologists  who  happened  to  sit  on  the 
county  society  board.  One  thing  I  will  say  here:  I  have 
been  very  impressed  with  the  expertise  and  enthusiasm  of 
my  medical  colleagues  when  I  have  called  upon  them  for 
help  on  these  issues,  and  I  think  you  will  be,  too. 

The  opposition  of  the  Genesee  County  Medical  Society 
to  a  low-level  radioactive  waste  site  in  Michigan  has  been 
pivotal  in  the  debate.  Our  position  paper  was  crucial:  we 
distributed  it  at  our  initial  press  conference,  and  we  made 
endless  copies  available  to  members  of  the  public,  environ- 
mental groups  and  politicians.  The  dump  site  was  not 
opened;  the  state  ended  up  leaving  the  Midwest  program, 
and  much  of  our  effort  since  then  has  been  directed  toward 
changing  poorly  designed  federal  legislation.  Our  work  has 
been  very  well  received  by  the  public  and  we  have  testified 
on  this  issue  before  the  Michigan  and  Ohio  legislatures  as 
well  as  Congress. 

Our  next  effort  began  about  a  year  ago.  Advisories 
against  fish  consumption  in  the  Great  Lakes,  especially  for 
pregnant  women  and  children,  have  been  in  effect  for  years. 
We  decided  that  Michigan's  physicians  have  a  responsibili- 
ty to  attack  the  root  cause:  the  pollution  that  makes  fish 
unsafe  in  the  first  place.  Again,  we  developed  a  position 
paper,  fiilly  docimiented.  In  it  we  discussed  the  nature  of 
the  pollutants  and  the  mountains  of  scientific  research 
showing  developmental  problems  among  exposed  wildlife. 
We  focused  on  recent  human  research  suggesting  learning 


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85 


450 


impairments  among  children  of  women  who  were  regular 
fish  eaters.  We  ended  by  endorsing  the  goal  of  zero  dis- 
charge for  chlorinated  hydrocarbons,  PCBs  and  dioxin  in 
the  Great  Lakes  basin. 

Again  we  sought  approval  of  the  environmental  com- 
mittee and  the  county  society  board,  but  this  time,  we  went 
further.  We  sought  and  achieved  approval  of  a  resolution 
endorsing  zero  discharge  for  PCBs  and  dioxin  in  the  Great 
Lakes  basin  firom  the  Michigan  State  Medical  Society.  This 
effort  brought  the  state  society  considerable  attention  from  a 
number  of  sources:  the  public  at  large,  journalists,  state 
government,  environmentalists.  The  Michigan  State 
Medical  Society  is  now  intimately  involved  with  groups 
around  the  Great  Lakes  working  for  better  water  quality  and 
a  safe  fishery  for  our  children.  The  response  of  the  pubhc  to 
seeing  their  physicians  involved  in  issues  of  this  kind  has 
been  overwhelmingly  positive. 

Recommendations 

So  what  general  advice  might  I  give? 

1 .  Look  for  a  local  issue.  Enviroiunental  issues  run  the 
gamut  and  some  can  be  esoteric.  We  have  tried  to 
prioritize  issues  of  importance  to  our  community,  and 
we  have  tried  to  focus  on  one  a  year.  It  is  easy  to 
dissipate  your  efforts. 

2.  Use  your  local  medical  hbrary.  Computer  searches  can 
find  anything.  Just  as  you  can  search  for  articles 
discussing  psoriasis  and  cyclosporine,  you  can  run 
requests  for  toxic  landfills  and  bladder  cancer  or  high 
voltage  lines  and  leukemia  or  air  pollution  and  child- 
hood asthma  or  ozone  depletion  ^id  melanoma.  I  have 
found  our  local  Ubrarian  to  be  an  endless  resource. 

3.  Develop  a  position  paper  before  going  public.  It 
provides  your  colleagues  with  the  same  reference  points 
and  it  is  an  excellent  way  to  provide  the  press  and  the 
public  with  the  information  you  consider  important 

4.  Use  the  expertise  of  your  medical  colleagues.  Physi- 
cians are  a  talented  group.  In  many  communities  across 
America  we  are  the  only  trained  scientists  in  town.  I 
have  found  physicians  happy  and  eager  to  contribute  to 
and  to  unite  behind  these  issues. 

5.  Focus  on  coiTununity  health,  especially  the  health  of  our 
children.  Do  not  compromise  on  this.  As  physicians, 
we  must  be  health  advocates.  Some  people  will  not 
like  what  we  say,  just  as  die  tobacco  industry  doesn't 
like  to  hear  us  criticizing  cigarettes,  but  we  have  great 
credibility  on  these  issues,  and  we  must  speak  for  our 
commiuiity's  health. 


6.  Involve  organized  medicine.  Our  professional  organiza- 
tions should  be  leaders  on  these  issues.  Every  environ- 
mental issue  I  have  looked  at  becomes,  in  essence,  a 
health  issue,  and  we  should  be  leading  advocates. 

7.  Once  you  have  taken  a  position,  let  policymakers  know 
and  let  them  know  again  and  again.  They  hear  from 
polluters,  they  hear  from  statisticians  doing  risk  analy- 
sis, they  hear  from  bureaucrats,  and  they  need  to  hear 
bom  us.  And  when  they  do,  we  need  to  advocate  for 
the  health  of  our  communities. 

In  closing,  let  me  urge  you  to  become  involved.  Our 
experience  has  been  an  overwhelmingly  positive  one. 
People  do  want  to  hear  from  their  physicians  on  these 
important  issues.  Thank  you. 


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The  Environment  and  Medicine 


Bernard  D.  Goldstein,  M.D. 


Physicians  have  long  recognized  the  role  of  the  environment 
in  human  disease.  The  notion  that  residents  of  different 
cities  had  different  health  problems  was  recognized  by 
physicians  of  antiquity,  including  Hippocrates.   Ramazzini's 
work  in  the  late  17th  century  led  him  to  become  known  as 
the  father  of  occupational  medicine,  through  his  clear 
description  of  the  role  of  the  work  environment  in  human 
disease.  He  also  briefly  described  a  community  environ- 
ment problem  that  has  remarkable  resonance  for  today.  It 
included  a  local  physician  using  parish  death  records  to 
show  an  increase  in  wasting  diseases  of  the  chest  which,  he 
contended,  was  caused  by  acid  emissions  from  a  nearby 
industrial  plant  In  the  resulting  lawsuit,  the  defendant 
industiiahst  successfully  brought  in  expert  wimesses, 
including  government  physicians,  to  rebut  the  claim. 

The  situation  briefly  described  by  Ramazzini  inevitably 
focuses  our  attention  on  the  issue  of  attribution.  Today  we 
recognize  that  chronic  pulmonary  disease  can  be  caused  by 
long  term  exposure  to  acid  aerosol;  but  we  also  recognize 
that  poorer  people,  who  presumably  have  a  higher  risk  of 
tuberculosis  uiuelated  to  industrial  exposure,  are  more  likely 
to  live  in  areas  with  industrial  emissions.   Hindsight  in  this 
case  does  not  permit  us  to  determine  which  side  was  correct 
in  its  attribution  of  the  cause  of  wasting  disease  of  the  chesL 
However,  we  still  have  the  same  problem:  with  the  excep- 
tion of  a  few  endpoints  (eg,  mesotheUoma),  environmental 
conditions  cause  disease  for  which  there  are  many  other 
causes.  Thus,  we  know  that  lung  cancer  can  be  caused  by 
radon,  asbestos  and,  most  likely,  diesel  exhaust  However, 
we  have  difficulties  in  attributing  the  extent  to  which  any  of 
these  factors  is  responsible  for  overall  limg  cancer  rates  or 
for  disease  in  a  specific  patient  Similarly,  we  know  that 
renal  disease  can  be  caused  by  a  variety  of  chemicals, 
sometimes  in  an  idiosyncratic  manner.  However,  for  the 
unfortunate  many  who  have  idiopathic  end-stage  renal 
disease,  we  do  not  know  the  extent  of  chemical  causation. 

Chemical  and  physical  agents  may  also  be  responsible 
for  infraction  with  disease  processes,  iitcluding  possibly 
exacerbation  of  auto-inunune  disorders  such  as  lupus 
erytbematosis,  based  on  analogy  to  drug-induced  models  of 
lupus.  The  role  of  ultraviolet  light  in  producing  skin  cancer 
is  unquestionable,  but  its  role  in  affecting  immunity  is  only 
now  being  explored. 

One  of  the  more  regrettable  aspects  of  increased  public 
awareness  and  concern  about  the  environment  is  the  loss  of 
credibility  of  almost  all  the  organizational  stakeholders. 
Through  a  series  of  public  relations  debacles,  iixlustry  has 


lost  almost  all  believabihty  by  the  general  public,  and 
government  is  not  far  behind.  Even  environmental  groups 
have  come  in  for  some  degree  of  public  distrust  from  their 
overuse  of  "the  sky  is  falling"  pronouncements.  This  loss 
of  credibility  has  greatly  complicated  response  to  environ- 
mental problems,  and  has  driven  up  the  costs  of  environ- 
mental controls  to  often  prohibitive  levels.  Polls  show  that 
the  public  ranks  physicians  very  high  in  terms  of  credibility, 
but  very  low  in  terms  of  their  knowledge  about  environmen- 
tal matters.  Thus,  knowledgeable  physicians  have  an 
opportunity  to  provide  a  public  service  of  great  societal 
value  by  serving  as  an  effective  source  of  information  about 
environmental  matters. 

Unfortunately,  pubUc  concern  about  physician  expertise 
in  the  area  of  environmental  health  has  been  well  merited. 
There  are  few  specialists  in  the  area:  most  are  found  in 
academic  programs  and  have  expertise  in  occupational 
health.  More  importantly,  studies  have  shown  envirotunen- 
tai  health  issues  are  a  negligible  part  of  the  undergraduate, 
postgraduate  or  continuing  medical  education  of  generalist 
or  specialist  physicians.' 

Opportimities  for  physician  involvement  in  environ- 
mental issues  are  many.  Every  commimity  has  one  or  more 
environmental  issues  of  concern  to  the  public,  ranging  firom 
the  over  100  million  Americans  who  live  in  areas  where 
ozone  levels  exceed  the  allowable  health  standard,  to  the 
close  to  1000  localities  that  have  Superfund  waste  disposal 
sites  in  their  backyards.  Many  local  organizations  would 
welcome  physician  involvement,  from  advice  on  a  specific 
issue  to  a  general  discussion  of  environmental  health.  In 
my  experience  the  feedback  from  groups  such  as  the  garden 
club,  the  local  chapter  of  the  Sierra  Gub  or  a  local  church  or 
synagogue  has  been  excellent  and  gratifying.  As  in  any- 
thing else  we  do  as  physicians,  when  we  do  not  know  the 
answer  to  a  specific  question,  it  is  important  to  say  so. 

An  area  where  physicians  can  be  of  particular  help  is  in 
the  communication  of  the  extent  of  the  health  risk.  Risk 
communication  is  a  particularly  problematic  area.  Often  an 
attempt  is  made  to  compare  the  risk  of  an  environmental 
hazard  with  other  risks,  such  as  smoking,  automobile 
accidents,  lightning,  etc.  While  such  comparisons  can  be  a 
useful  conceptual  rtiler,  they  are  fraught  with  difficulties  and 
are  often  perceived  by  an  affected  public  as  inappropriate  to 
their  concerns.  For  example,  cigarette  smoking  or  hang 
gUding  are  voltmtary  risk  exposures,  while  exposure  to  a 
noxious  efHuent  from  a  nearby  faaory  is  not  For  personal- 
ly controllable  risks,  such  as  automobile  accidents,  individu- 


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452 


als  often  believe  that  the  risk  relates  only  to  those  who  are 
bad  drivers  or  drunk  drivers  and  does  not  pertain  to  them. 

At  the  Environmental  and  Occupational  Health  Sciences 
Institute  we  try  to  use  like  measures,  rather  than  unlike,  in 
describing  risk  to  the  pubUc.  For  example,  in  a  Valdez, 
Alaska  study  of  risk  due  to  benzene  exposure  from  the  oil 
tanker  terminal  at  the  end  of  the  Trans- Alaska  pipeline,  we 
compared  the  risk  of  leukemia  from  terminal  activities  to 
the  risk  of  leukemia  from  all  other  sources  of  benzene  in  the 
community,  which  were  much  greater.  In  response  to 
questions  as  to  whether  this  represented  a  public  health  or 
medical  risk,  we  pointed  out  that  the  measure  "personal 
benzene  exposure  from  all  sources"  for  nonsmokers  was  far 
less  than  occurred  in  those  who  smoked  cigarettes  or  were 
exposed  to  significant  amounts  of  environmental  tobacco 
smoke.  It  should  be  noted  that  public  health  authorities  had 
not  publicized  the  threat  of  leukemia  due  to  benzene  in 
tobacco  smoke  as  a  means  of  encouraging  people  to  stop 
smoking,  presumably  because  the  risk  was  too  low  to  be  of 
public  health  or  medical  significatKe.^ 

A  risk  comparison  we  use  is  the  lifetime  risk  of  death 
due  to  an  airplane  hitting  you  while  you  are  on  the  ground. 
That  risk  is  about  four  in  one  million,  far  higher  than  most 
people  guess.'  The  risk  is  not  a  function  of  one's  own  skills, 
is  not  voluntary  ot  optional,  is  of  no  benefit  to  anyone,  is 
not  an  act  of  nature,  but  is  understandable  by  the  public. 
We  particularty  use  this  comparison  for  situations  in  which 
individuals  contemplate  specific  Ufestyle  changes,  such  as 
moving  from  a  community  where  publicity  about  low  level 
risk  (eg,  one  in  100,000  or  1,000,000)  has  raised  concern 
about  the  health  of  themselves  or  their  families.  Public 
authorities  may  decide  to  act  on  the  risk  because  millions 
are  exposed,  but  are  loaflie  to  explain  that  the  risk  is  too 
small  to  guide  individual  activities.  Although  it  would  be 
effective,  people  do  not  attempt  to  lessen  the  risk  of  air- 
planes bitting  them  on  the  ground  by  such  activities  as 
putting  the  bedroom  in  the  basement  or  reinforcing  die  roof 
with  steel.  This  is  because  one  risk  is  recognized  as  being 
too  small  to  guide  our  daily  activities.  However,  as  citizens 
we  do  want  to  support  governmental  actions  that  lessen  this 
risk  to  all  of  us.' 

In  conclusion,  rapid  advaiKes  in  basic  biological 
science,  particulariy  in  molecular  biology  and  neuroscienc- 
es,  will  provide  us  widi  new  tools  of  unprecedented  power 
to  allow  estimation  of  environmental  health  risk.  Develop- 
ing, understanding  and  translating  this  information  for 
public  use  will  be  of  utmost  importance  if  this  planet  is  to 
survive.  As  physicians  we  have  both  an  opportimity  and  an 
obligation  to  ensure  that  this  hiqjpens. 


References 


Institute  of  Medicine.  Role  of  the  primary  care  physi- 
cian in  occupational  and  environmental  medicine. 
Washington,  DC:  National  Academy  Press;  1988. 
Goldstein  BD,  Dickason  OE,  Morresey  L,  et  al.  Com- 
munication of  risk  due  to  community  and  workplace 
petroleum  exposure.  Indoor  Environ,  Switzerland, 
November  5,  1993. 

Goldstein  BD,  Demak  M,  Nortfaridge  M,  et  al.  Risk  to 
groundlings  of  death  due  to  airplane  accidents:  A  risk 
communications  tool.   Risk  Analysis  1992;12:339-341. 


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Dermatology  AND  THE  Environment:  A  Leadership  Opportunity 

John  T.  Grupenhofif,  Ph.D. 


In  March,  1990,  in  the  Journal  of  the  American  Academy  of 
Dermatology  (JAAD),  an  editorial  appeared  luider  my  name 
regarding  the  opportunity  for  dermatology  to  lake  a  leader- 
ship position  in  relation  to  present  environmental  degrada- 
tion around  the  world.  Opening  comments  indicated  that: 
I     Dermatology  is  being  presented  with  a  imique  opportu- 
nity to  serve  the  needs  of  its  patients  and  the  public 
worldwide. 
I     The  sidn  is  a  major  barrier  to  insults  from  a  disturbed 
and  polluted  environment  and  will  become  increasingly 
besieged. 
I     Dermatologists  have  already  developed  warning 
systems  in  a  public  information  structure  to  deal  with 
several  environmental  insults.  By  building  on  these,  a 
program  that  deals  more  widely  with  these  problems 
can  be  fashioned  to  the  benefit  of  patients,  the  public 
health,  and  the  status  of  dermatology. 
The  editorial  noted  that  the  Academy  has  considerable 
experience  in  environmentally-related  activities  and  cited 
the  successful  skin  cancer/melanoma  screening  program 
established  by  the  Academy  in  1984.  That  program, 
enhanced  by  Congressional  resolutions  and  presidential 
proclamations,  has  created  one  of  the  best  public  education 
programs  any  medical  specialty  has  ever  developed. 

A  dermatologist  (Dr.  Darrell  Rigel)  brought  to  die 
attention  of  the  Congress  the  potential  threats  of  a  dimin- 
ished ozone  layer  and  its  impUcations  for  potential  increases 
in  skin  cancer. 

The  problems  of  occupational  carcinogens  and 
dermatosis  were  raised  by  the  Academy  in  Washington  at  a 
national  symposium  for  the  prevention  of  occupational  skin 
conditions  in  April,  1989. 

Also,  it  was  indicated  that  the  appropriate  disposal  of 
medical  waste  was  then  the  subject  of  deliberation  by  an 
Academy  conunittee  (a  document  has  since  been  promulgat- 
ed). 

Finally,  my  editorial  indicated  that  Academy  leaders 
readily  took  on  the  issue  of  dangers  of  tanning  machines, 
which  showed  their  concern  about  man-made,  itKloor 
enviroimiental  threats  and  their  willingness  to  protect  the 
public  health  in  this  regard. 

Those  examples  illustrated  my  point  that  dermatologists 
are  already  in  die  forefront  on  envirotunental  issues.  They 
also  illustrate  the  opportunity  to  incoiporate  those  programs, 
and  others,  into  an  overall  systematic  and  consolidated 
environmental  policy  thnist  to  position  dermatologists  as 


leaders  in  environmental  protection. 

Questions  raised  in  that  editorial  remain  important: 
What  are  the  known  environmental  impacts  of  polluted  air, 
water,  and  land  on  the  skin  ot  on  other  organs  that  may  be 
first  expressed  in  the  skin?  Which  of  them  need  immediate 
action  or  further  research  (and  which  agencies  should  fiind 
such  research)?  What  can  be  learned  about  environmental 
problems  from  other  medical  disciplines  and  allied  scientific 
disciplines  (eg,  marine  biologists  and  veterinarians,  who  are 
confronting  the  rapidly  increasing  incidence  of  skin  tumors 
and  similar  skin  diseases  in  fish  and  other  sea  animals, 
including  Crustacea  that  have  diseased  shells  such  as 
"bumspot"  or  "hotspot")  that  has  relevance  for  human  skin? 
What  can  be  learned  from  the  growing  bases  of  research 
data  at  the  Environmental  Protection  Agency  and  other 
agencies  about  the  impact  on  the  skin  of  human  populations 
near  toxic  waste  sites  or  near  river  or  ocean  discharge  pipes 
of  chemical  polluters?  What  can  be  learned,  to  take  a  more 
far-ranging  example,  from  skin  reactions  during  NASA 
space  flights  that  can  be  applicable  to  our  eatthbound 
human  population?  What  can  interested  researchers  and 
agencies  tell  us  about  the  environmental  deterioration  in  the 
Eastern  bloc  or  in  underdeveloped  countries,  and  the 
dermatologic  problems  there  that  might  be  present  here  in 
the  United  States,  now  or  in  the  funire?  How  can  die 
intranational  dermatologic  community  become  involved  to 
deal  with  diese  issuesT' 

National  Association  of  Physicians  tor  tfie  Enviranment 
(NAPE)* 

Dermatology  can  also  work  in  conjunction  with  other 
medical  societies  on  these  issues. 

In  March,  1990 1  wrote  an  editorial  carried  simulta- 
neously in  the  Journal  of  Environmental  Health  and  the 
American  Journal  of  Industrial  Medicine,  calling  for  the 
establishment  of  a  National  Association  of  Physicians  for 
the  Environment  (NAPE).  Dermatology  can  have  a  major 
role  to  play  in  diat  activity. 

That  organization  has  now  applied  for  S01(cX3)  non- 
profit organization  status,  which  it  expects  shoitly.  Dr. 
Peyton  Weary,  a  long-time  leader  in  dermatology,  has 
agreed  to  become  a  member  of  the  organizing  board  of 
NAI^  and  has  been  elected  to  the  position  of  president- 

*NAFE  is  the  designated  United  States  member  of  the 
receraly  formed  (1990)  International  Society  cf  Doctors  for 
the  Environmera  (ISDE),  organized  by  national  chapters. 


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454 


elect  At  the  same  time  that  NAPE  is  being  organized,  a 
similar  international  organization  is  forming,  the  Interna- 
tional Society  of  Doctors  for  the  Environment  (ISDB).  Late 
in  1990,  a  Swiss  physician  named  Dr.  Werner  Nussbaumer 
wrote  to  12,000  Swiss  practitioners  expressing  his  concern 
about  the  deterioration  of  the  world's  environment  and  its 
impact  on  human  health.  Over  3,000  doctors  joined  the 
organization.  Surprised  and  pleased  at  the  response.  Dr. 
Nussbaimier  contacted  medical  colleagues  in  other  coun- 
tries. In  less  than  three  years,  over  20  national  organizations 
of  Doctors  for  the  Envirotunent  have  formed  or  are  forming, 
and  active  physicians  are  attempting  to  organize  their 
colleagues  in  nearly  30  other  countries.  NAPE  is  a  member 
oflSDE. 

American  dermatology  has  an  immense  influence  on 
dermatology  worldwide;  perhaps  by  working  with  the  ISDE 
we  can  bring  to  physicians'  organizations  worldwide 
materials  developed  by  this  Academy. 

Let  me  now  deal  with  the  structure  and  intentions  of  the 
National  Association  of  Physicians  for  the  Envirormient. 

NAPE  has  been  developed  to:  (1)  work  with  the 
national  medical  specialties  and  subspecialties,  with  nation- 
al, state,  and  local  medical  societies,  and  with  individual 
physicians  to  deal  with  the  impacts  of  environmental 
pollutants  on  the  organs,  systems  or  disease  processes  best 
known  to  them;  (2)  inform  physicians,  patients  and  the 
public  about  the  impact  of  pollutants  and  the  necessary 
personal  and  pubUc  health  steps  that  should  be  taken  to 
reduce  or  eliminate  those  pollutants;  and  (3)  involve  physi- 
cians in  environmental  issues  global  in  nature,  such  as 
protection  of  biological  diversity.  Health  professional 
organizations,  non-profit  environmental  and  pubUc  intoest 
organizations  concerned  with  environment  and  health  issues 
are  invited  to  become  organizational  members.  All  individ- 
uals, not  only  physicians,  can  join. 

Background 

In  recent  years,  physicians  have  become  increasingly 
interested  in  and  concerned  about  our  deteriorating  environ- 
ment, and  the  potential  impact  of  that  deterioration  on 
human  health;  physicians  ate  the  most  widely  distributed 
scientifically-trained  professionals  in  the  U.S.  Although 
several  organizations,  especially  those  concerned  with 
public  health  and  environmental  and  occupational  health, 
have  been  leaders  in  these  matters  for  many  years,  physi- 
cians generally  have  not  had  access  to  organizational 
Structures  closely  tied  to  their  specialties  through  which  to 
participate  actively. 

Also,  no  association  of  medical  societies  has  existed  to 
pull  together,  in  an  interdisciplinary  fashion,  these  growing 
envirotunental  concerns  of  the  specialties.  What  is  needed 
is  a  group  that  will  act  as  a  conveno',  a  transfer  agent  of 


information,  a  forxmi  to  debate  and  build  consensus  on  the 
issues,  and  to  develop  public  information  and  education 
programs,  as  well  as  physician  education  and  action  pro- 
grams both  nationally  and  locally.  NAPE  was  formed  to  fill 
that  need. 

The  potential  influence  of  NAPE  is  considerable. 
Nearly  all  U.S.  physicians  (about  500,000)  belong  to  one  or 
more  medical  specialty  or  subspecialty  societies,  as  well  as 
national,  regional,  state  and  local  generic  medical  organiza- 
tions. Many  serve  on  hospital  boards  and  many  are  also 
active  leaders  in  their  cotimiunities. 

Physicians  are  much  more  likely  to  involve  themselves 
in  environmental  issues  if  their  medical  specialty  or  other 
medical  organizations  are  involved.  They  depend  upon,  and 
trust,  these  medical  specialties  for  judicial  policy  develop- 
ment and  continuing  professional  education  and  informa- 
tion. 

Medical  specialty  organizations  already  have  in  place  a 
national  physician  education  process  for  their  membership. 
Their  peer-reviewed  journals  and  other  periodicals  assure 
scientifically  sohd  information  upon  which  physicians  base 
their  medical  activities.  These  publications  are  focused  on 
specific  bodily  organs  or  systems,  or  diseases. 

Medical  societies  have  a  systematic  policymaking 
apparatus  and  have  experienced,  intelligent  and  able  leader- 
ship working  through  strong  volimteer  cotrmiittee  systems. 
They  all  have  commtmications  and  information  materials 
development  teams.  They  have  staff  to  help  analyze  policy 
proposals  and  make  recommendations  in  an  effective  way  to 
policymakers. 

All  specialties  have  close  relationships  with  the  Nation- 
al Instimies  of  Health  (NW)  —  most  institutes  ate  orga- 
nized to  deal  with  such  specialties.  The  National  Cancer 
(oncology)  Institute  and  the  National  Heart  (cardiology). 
Lung  (thoracic)  and  Blood  (hematology)  Institutes  are 
examples.  The  NIH  maintains  an  enormous  computerized 
information  retrieval  system  with  vast  amounts  of  scientific 
Uterature  that  can  be  accessed  by  individual  physicians 
anywhere  in  the  world.  Much  of  that  information  can  be 
utilized  to  deal  with  environmental  health  issues. 

Many  medical  specialty  societies  also  have  close 
connections  with  other  government  agencies,  such  as  the 
National  Science  Foundation,  the  Environmental  Protection 
Agency,  and  the  National  Institute  of  Occupational  Safety 
and  Health.  All  medical  societies  seek  to  enlarge  their 
contacts  with  the  public,  and  are  perceived  to  be  eager  to 
work  with  environmental  and  other  organizations  on 
envirotunental  health  issues. 

All  medical  specialties  have  international  components: 
many  foreign  medical  leaders  have  trained  in  the  U.S.  and 
continue  those  close  ties. 


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Dermatology  and  Senioii 

Dennatology  has  an  opportunity  for  leadership  not  only  in 
the  National  Association  of  Physicians  for  the  Environment, 
but  also  with  regard  to  seniors.  Since  many  pollutants  are 
cumulative  over  a  lifetime  and  cause  toxic  effects,  physi- 
cians should  generally  be  especially  concerned  about  seniors 
and  the  environment.  In  addition,  as  is  now  known,  UV 
radiation  and  some  chemicals  induce  dermatosis  over  time, 
potentially  impacting  on  seniors  more  severely  than  other 
populations.  Therefore,  I  see  a  major  opportunity  for 
dermatologists  to  become  involved  working  with  the  senior 
centers  across  the  country  (of  which  there  are  1300),  and 
with  the  American  Association  of  Retired  Persons  (AARP), 
in  terms  of  melanomas  and  skin  cancer  education  and  skin 
problems  in  the  senior  community. 

In  1990, 1  wrote  a  paper  calling  for  a  Senior  Environ- 
ment Corps,  which  has  now  been  established.  One  of  the 
major  issues  of  that  group  is  to  study  and  respond  to 
environmental  impacts  on  body  organs  and  systems  of 
seniors,  to  inform  and  to  work  with  them.  Dr.  Weary  serves 
on  the  board  of  directors  of  that  organization  as  well.  The 
American  Association  of  Retired  Persons  (AARP),  the 
Envirotmiental  Protection  Agency,  and  about  15  national 
environmental  organizations  and  federal  agencies  are  now 
developing  the  Environmental  Alliance  for  Senior  Involve- 
ment (EASI).  Dermatology  could  take  a  major  role  in  this 
effort  as  well. 

National  Council  on  Health  Care  and  the  Environment 

Recently  I  developed  the  concept  of  a  National  Cotmcil  on 
Health  Care  and  the  Environment  The  goal  of  this  organi- 
zation is  to  form  an  association  of  all  health  providers,  their 
scientific  colleagues  and  suppliers.  It  would  also  seek  to 
promote  and  support  environmental  responsibility  within 
the  health  care  field.  Such  an  organization  would  have  the 
following  objectives,  among  others: 

1.  To  promote  responsibility  for  the  environment  as  an 
integral  part  of  the  healing  mission  of  health  care; 

2.  To  encourage  the  use  of  environmentally-sensitive 
products  and  packaging  in  health  delivery; 

3.  To  promote  policies  and  technologies  for  medical  waste 
management  that  are  sensitive  to  the  environment  of  the 
community;  and 

4.  To  encourage  conservation  and  the  efficient  use  of 
energy  in  the  operation  of  health  facilities. 
Membership  would  be  open  to  all  health  care  providers, 

including  physicians,  their  associates  (such  as  nurses  and 
physicians'  assistants),  hospitals,  other  health  faciUlies, 
health  industry  suppliers,  waste  management  service 
providers,  health  and  life  insurance  groups,  medical  media, 
pharmaceutica]  organizations,  biotechnology  associations. 


coalitions  of  voluntary  health  organizations,  energy  efficien- 
cy and  conservation  suppliers,  as  well  as  policy  makers  and 
environmental  and  other  interest  groups. 

NAPE  Activities  since  the  AAD  National  Conference  on 
Environmental  Hazards  to  the  Skin 

Since  the  conference  was  convened,  NAPE  has  imder- 

taken  the  following  activities: 

I      Co-sponsored  a  national  organizational  conference, 
developed  its  proceedings,  developed  conference 
videotapes  and  audiotapes,  and  initiated  publication  of  a 
newsletter. 

I      Testified  four  times  before  Congressional  committees 
(about  relationships  to  EPA.  NASA.  DOD.  NIH).  One 
Congressional  appearance  already  has  generated  an 
important  document  —  the  National  Institutes  of  Health 
has  just  released  a  report  indicating  its  willingness  to 
work  with  NAPE.  Eleven  institutes  and  offices  of  NIH 
described  potential  relationships  as  a  result  of  a  legisla- 
tive request  by  the  Senate  Subcommittee  on  Labor- 
HHS-Education.  Two  proposals  made  in  Congressional 
testimony  in  April  1993  regarding  an  international 
conference  on  the  protection  of  biological  diversity  and 
its  importance  as  the  source  for  new  pharmaceuticals 
and  other  medical  products  are  being  acted  upon  ja  the 
Congress. 

I     Briefed  the  American  Medical  Association 's  Lonf 
Range  Planning  Council  and  the  Council  on  Research: 
NAPE  wishes  to  collaborate  with  the  AMA  on  issues  of 
environment  and  health. 

I      Welcomed  13  medical  societies  to  membership  as  of 
June  6,  1994.  These  include  American  Academy  of 
Dermatology,  American  Academy  of  Otolaryngology  - 
Head  and  Neck  Siu^ery,  Inc.,  American  Academy  of 
Hematology,  American  Society  for  Head  and  Neck 
Surgery,  the  Society  of  Nuclear  Medicine,  the  Wilder- 
ness Medical  Society,  the  American  Medical  Associa- 
tion, the  American  Academy  of  Otolaryngic  Allergy, 
the  International  Foundation  for  Dermatology,  the 
Association  of  University  Environmental  Health 
Science  Centers,  the  Pennsylvania  Medical  Society,  the 
Genesee  County  Medical  Society  (Michigan),  and  the 
American  Society  for  Dermatologic  Siu^ery,  Inc. 

The  following  major  projects  are  being  undertaken  by 
NAPE,  in  addition  to  other  organizational  inatters  described 
above: 

I     Air  Pollution  Conference:  Under  a  grant  from  the 
National  Institute  of  Environmental  Health  Sciences 
(NIEHS),  NAFE  will  be  holding  a  national  conference 
on  November  18,  1994,  at  the  National  Press  Oub  on 


PKOdEDINCS  OF  HIE  NaIVMU.  CONFQtENCX  ON  ENVKONMBTAL  HAZARDS  TO  T\m  SlON 


91 


456 


"Air  Pollution:  Impacts  on  Body  Organs  and  Systems." 
A  preconference  bringing  together  nearly  all  of  the 
speakers  for  the  November  conference  was  held  at  the 
American  Medical  Association  Washington  Office  on 
April  29,  1994.  It  is  expected  that  approximately  25 
speakers,  most  from  medical  specialty  societies,  will 
comment  upon  air  pollution  impacts  on  each  organ  and 
system  of  the  human  body  (not  only  the  lung,  which  has 
been  well  studied). 

At  the  conclusion  of  the  conference,  a  "white  paper", 
which  will  be  composed  of  "chapters"  containing  each 
speaker's  paper,  will  be  utilized  in  the  medical  commu- 
nity. A  major  pubUc  education  effort  will  be  undertak- 
en, and  hopefully  pamphlets  will  be  developed  by  the 
various  medical  specialty  societies  for  distribution  to 
patients  and  the  public  from  the  conference.  Funding 
for  a  lO-minute  video  will  be  sought. 
Protection  of  Biological  Diversity:  The  U.S.  Senate,  in 
its  appropriations  bill  of  1993,  included  language 
calling  for  the  National  Institutes  of  Health  to  have  an 
international  conference  on  biological  diversity,  particu- 
larly as  it  impacts  on  pharmaceuticals  and  biological 
products  derived  bom  the  natural  world.  The  Fogarty 
International  Center  at  the  NIH  will  be  the  lead  agency. 
The  Smithsonian  Institution  is  the  likely  venue,  perhaps 
at  the  auditorium  of  the  "Old  Castle."  A  steering 
committee  met  in  mid- April,  1994  to  begin  organization 
of  the  conference,  and  outstanding  speakers  from 
various  fields  relating  to  biological  diversity,  including 
pharmaceuticals,  biotechnology,  legal  issues,  agricul- 
ture, etc.,  will  be  included.  It  is  hoped  that  the  confer- 
ence proceedings  will  be  published.  The  main  focus  of 
the  publicity  will  be  on  medical  specialty  organizations 
so  that  specialists  can  understand  which  drugs  that  they 
are  using  are  derived  from  the  natural  world,  and  thus 
can  understand  better  the  need  for  protection  of  biologi- 
cal diversity. 

UV  Index/Sun  Radiation  Protection:  Under  a  grant 
from  the  EPA,  NAPE  is  organizing  an  effort  to  reach 
out  to  all  of  the  medical  specialty  organizations,  public 
health  groups,  other  medical  and  health  organizations, 
as  well  as  the  medical  and  environmental  news  media, 
to  alert  them  to  the  upcoming  development  of  a  national 
UV  Index,  which  is  being  developed  by  the  National 
Weather  Service  (NWS)  and  the  Environmental  Protec- 
tion Agency  (EPA).  Expected  target  date  for  public 
announcement  is  summer  1994,  though  some  scientific 
issues  remain  to  be  ironed  out  relating  to  measurements 
by  satellite,  and  whether  to  present  the  forecast  as  "clear 
sky"  or  to  incorporate  local  cloud  conditions.  The 
information  will  be  provided  by  the  NWS  to  media 


outlets  in  over  170  cities,  just  as  information  is  now 
being  sent  for  daily  weather  briefings. 
NAPE  has  constructed  an  educational  plan  for  continuous 
health  profession,  patient  and  public  education.  It  is 
expected  that  this  will  be  at  least  a  two  year  project 
I      "Greening"  of  Medical  and  Health  Professional 

Community:  A  proposal  has  been  developed,  and  likely 
will  be  funded,  for  the  development  of  manuals, 
education  piugrams,  and  other  educational  materials  for 
the  medical  and  general  health  professions  community 
(including  the  research  community,  veterinarian  organi- 
zations, etc.)  to  make  practices  in  all  these  ofRces  more 
environmentally  sound,  from  recycling  to  cleaning 
solvents,  to  energy  savings.  It  is  projected  that  this 
project  will  come  on  line  in  September,  1994,  and  will 
take  about  a  year.  Already  two  medical  specialty 
organizations  have  indicated  a  willingness  to  join  in  this 
effort,  and  the  AMA  has  indicated  considerable  interest 
in  involving  itself.  Indications  are  that  elements  of  the 
American  Hospital  Association  will  also  join  the  effort 
NAPE  also  will  be  working  with  Concurrent  Technolo- 
gies, Inc.,  part  of  the  National  Defense  Center  for 
Environmental  Excellence  of  Johnstown,  Pennsylvania, 
which  has  a  Department  of  Defense  (DoD)  grant  to 
"green"  all  hospital  and  medical  facilities  of  the  DoD 
from  hospitals  through  to  battlefield  and  other  field 
situations.  There  is  a  possibility  that  the  American 
Veterinary  Medical  Association  will  also  join  in  the 
effort. 

Summary 

Dermatology  has  an  enormous  range  of  opportunities  to 
make  itself  better  known  to  the  American  public  in  terms  of 
protection  of  the  environment  and  of  individuals  suffering 
frx>m  the  impacts  of  environmental  pollutants  of  various 
forms. 


Proceedinos  of  the  National  Confhience  on  EnviRONMEifl'AL  Hazards  to  the  Skin 


457 


Health  Promotion  for  Older  Americans 

Jeanne  Snodgrass,  EdD. 


My  role  this  morning  is  to  talk  a  little  about  why  dermatolo- 
gists should  be  interested  in  older  people.  Who  are  these 
folks?  And  where  are  they?  As  well,  we'll  consider  some 
suggestions  of  how  to  reach  older  folks  and  provide  some 
time  for  questions. 

As  a  member  of  the  Executive  Board  of  the  Health 
Promotion  Institute  of  the  National  Council  on  Aging 
(NCOA),  my  interest  is  in  advocacy  and  education  related 
to  all  aspects  of  health  in  oldo'  people.  The  HPI  has  already 
worked  with  the  Optometric  Association  on  a  project  related 
to  vision:  it  has  also  worked  with  pharmaceutical  associa- 
tions on  the  use  of  medicines  and  high  blood  pressure 
education:  and  it  is  beginning  an  association  with  the  Senior 
Environment  Corps  regarding  the  relationship  of  environ- 
mental education  and  health  issues. 

I  found  very  little  in  any  of  the  resources  I  consulted 
related  to  health  promotion  dealing  with  dermatology.  Yet 
you  know  and  I  know  that: 
I     Skin  changes  are  a  natural  part  of  aging: 
I     Melanomas  and  other  skin  cancos  are  increasing  at  an 

alarming  rate; 
I     Excessive  sunlight  as  a  result  of  the  decreased  ozone 

layer  creates  greater  exposure  for  the  skin; 
I     The  toxic  nature  of  our  polluted  environment  is  ab- 
sorbed through  the  skin:  and  that  all  these  things  are 

concerns  for  our  oldo'  population. 
I  believe  you  have  tried  to  impact  future  generations  of 
older  people  about  care  of  the  skin,  and  I  am  pleased  that 
you  are  interested  in  taking  a  look  now  at  health  concerns 
related  to  dermatology  and  diose  who  have  already  aged. 
DetiKigraphically  speaking,  you  no  doubt  know  that  the  size 
of  this  cohort  is  increasing  dramatically  as  the  Baby 
Boomers  reach  middle  and  old  age,  that  we  are  living 
longer,  and  that  the  numbers  of  those  85-I-  and  even  over 
100  years  old  are  increasing  rapidly.  Many  of  these  older 
people  are  living  in  the  "Sun  Belt",  in  Florida  and  Califor- 
nia and  Arizona,  and  as  a  result  should  be  more  conconed 
abou  skin  care. 

What  else  do  we  know  about  this  age  group  called 
older?  Periiaps  the  primary  characteristic  is  its  varied 
constituency:  no  longer  is  the  myth  of  "poor,  ill,  and 
institutionalized"  accurate. 

Many  are  active  and  involved  in  all  of  life  —  many  for 
longer  years. 

But  we  are  cofKcnied  because  we  know  that  older 


bodies  are  more  vulnerable  to  disease: 

I     Food  and  medicines  are  utilized  differently  in  older 

people: 
I     Many,  especially  women,  live  alone  and  have  no-one  to 

help  them  with  various  health  checks: 
I     Most  want  to  make  their  own  decisions  affecting  dieir 

lives: 
I     All  want  to  be  treated  with  dignity  and  acceptance;  and 
I     Most  go  to  a  doctor  only  when  something  is  definitely 

wrong.  Most  older  people  rely  on  their  doctors  to 

recommend  tests  or  screenings  and  Usten  to  advice 

given  by  their  primary  physicians. 
Important  also  to  consider  is  that  Medicare  offers  only 
limited  coverage  for  preventive  services.  So  where  does 
that  leave  dermatologists  in  terms  of  what  you  can  do  and 
how  you  can  reach  older  people  with  education  and  health 
promotion  related  to  skin  care? 

You  are  the  ones  knowledgeable  about  what  informa- 
tion or  service  needs  to  be  transmitted  to  folks  SO  or  60  and 
older.  Perhaps  the  few  suggestions  I  have  time  for  can  help 
you  get  that  information  to  the  people  who  would  benefit 
from  it 

Health  Promotion  Programs 

In  the  older  adult  network  are  organizations  working  for  the 
well-being  of  our  older  population.  These  are  organizations 
involved  with  direct  services,  advocacy  groups,  research 
groups,  publications  oriented  to  older  folks,  etc.  A  broad 
network  exists. 

Health  promotion  programs  are  found  in: 

a)  Group  health  plans 

b)  Hospitals 

c)  Recreation  departments 

d)  Universities 

e)  National  organizations  such  as  the  National  Council 
on  Aging  (NCOA)  and  the  American  Association 
of  Retired  Persons  (AARP). 

The  NCOA  is  an  umbrella  organization  of  practitioners 
assisting  the  elderly  in  rural  areas.  They  work  in  senior 
centers  and  have  volunteers  helping  seniors  maintain  their 
independence  in  their  own  homes.  There  are  different 
groups  working  with  some  aspect  of  aging.  Hopefully, 
dermatologisis  will  become  involved  with  the  Health 
Promotion  Institute  (H.P.I.)  of  the  NCOA  in  some  joint 


PlKXEEDINaS  OF  THE  NATIONAL  CoMI€llENCE  ON  ENVntONMENTAL  HaZAUB  TO  THE  SlON 


«3 


458 


project  The  AARP  has  an  Eldercare  Institute  that  is  woildng 
nationaUy  as  well.  Others  included  the  Administration  On 
Aging,  a  federal  agency  within  the  department  of  Health  and 
Human  Services;  the  National  Institute  on  Aging,  at  the 
National  Instiutes  on  Health,  (part  of  the  Department  of 
Health  and  Human  Services):  ODPHP  National  Health 
Information  Center,  the  National  Women's  Health  Network; 
and  the  American  Society  on  Aging  and  the  American 
Gerontological  Association  —  both  professional  organiza- 
tions. 

A  number  of  sports  organizations  also  might  prove 
valuable  channels  for  education: 

a)  The  National  Senior  Women's  Tetuiis  Association 

b)  The  United  States  Tennis  Association 

c)  The  National  Senior  Sports  Association 

d)  Senior  Gaines  and  Senior  Olympics  (usually 
organized  on  state  levels) 

On  the  local  level.  Area  Agencies  on  Aging  mandated 
through  the  national  Older  Americans  Act  work  through 
county  and  state  governments  as  Departments  on  Aging, 
within  Departments  of  Health  or  Social  Services,  or  other- 
wise titled.  The  organizational  patterns  vary  widely  acfx>ss 
the  country.  In  addition,  of  course,  are  individual  health 
promotion  programs  at  senira  centers,  churches,  in  recre- 
ation programs,  etc.,  and  educational  work  with  primary 
care  physicians  regarding  the  importance  of  monitoring  skin 
health  and  early  refenal  as  is  needed.  The  journal  publica- 
tions of  the  professional  organizations  provide  a  channel  for 
information,  as  do  the  specialty  magazines  directed  to  the 
older  persons  themselves,  such  as  New  Choices,  Modem 
Maturity,  Perspectives  on  Aging,  etc. 

It  would  seem  to  me  that  three  efforts  on  the  part  of  the 
Dermatology  Academy  would  be  effective  and  are  needed: 

1)  Becoming  actively  involved  with  education  and  primary 
preventive  measures  that  older  persons  can  take  on  their 
own; 

2)  The  provision  of  preventive  services  for  early  detection 
of  problems;  and 

3)  Involvement  with  the  promotion  efforts  to  achieve 
Medicare  coverage  of  preventive  services. 


Proceqiincs  of  ns  Nauonal  Conference  on  ENvnoNMEKtAL  Hazards  to  tvb  San 


459 


Appendices 


PUXSUNCB  OF  THE  NaTOIUL  CoMBIENCE  OM  ENVnCMMBfTAL  HaZAUS  TO  THE  SON 


460 


A.  Contributois  to  the  Proceedings 

Thomas  Anderson,  MJ). 

Associate  Professor 
Department  of  Dermatology 
University  ofMicfugan 
Arm  Arbor,  MI 

Ole  Baadsgaard,  MJ). 

Associate  Professor 
University  of  Copenhagen 
Department  of  Dermatology 
Geraofte  Hospital 
Copenhagen,  Denmark 

WDma  F.  Bergfeld,  MD. 

Past  President,  American  Academy  of  Dermatology 
Head  Clinical  Research,  Department  of  Dermatology 
Cleveland  Clinic  Foundation 
Cleveland.  OH 

Joseph  W.  Burnett,  M  J). 

Professor,  Department  of  Dermatology 
University  of  Maryland  School  of  Medicine 
Baltimore,  MD 

Kevin  D.  Cooper,  M  J). 

Associate  Professor 
Department  of  Dermatology 
University  of  Michigan 
Ann  Arbor,  Ml 

Vincent  A.  DeLeo,  MD. 

Vice  Chairman  and 

George  Fox  Assisiaru  Professor  of  Dermatology 

College  of  Physicians  and  Surgeons 

of  Columbia  University 

New  York.  \Y 

John  H.  Epstein,  MJ>. 

Clinical  Professor  of  Dermatology 
University  of  California  School  of  Medicine 
San  Francisco,  CA 

y/mam  L.  Epstein,  MJ). 

Professor,  Department  of  Dermatology 
University  of  California 
San  Francisco.  CA 

TlKHnas  B.  Fltzpatridi,  MJ). 

Professor  Emeritus 
Department  of  Dermatology 
Harvard  Medical  School 
Boston.  MA 


Lowen  A.  Goldsmith,  MD. 

Professor  and  Chair.  Department  of  Dermatology 
University  of  Rochester 
Rochester.  NY 

Bernard  D.  Goldstebi,  MD. 

Director 

Emironmerttal  &  Occupational 
Health  Sciences  Institute 
Piscataway.  NJ 

John  T.  Gnipenlioff,  PbJ). 

President 

Science  and  Health  Communications  Group.  Inc. 

Bethesda,  MD 

Jere  D.  Guin,  MD. 

Professor  and  Chairman 

Department  of  Dermatology 

University  of  Arkansas  for  Medical  Sciences 

Little  Rock.  AR 

Howard  K.  Koh,  MD. 

Associate  Professor  of  Derrruaology.  Medicine 
and  Public  Health 

Boston  University  School  of  Medicine 
Boston,  MA  ' 

Hillel  S.  Koren,  PhJ). 

Director.  Human  Studies  Division 
United  Slates  Environmental  Protection  Agerury 
Health  Effects  Research  Laboratory 
Research  Triangle  Park.  NC 

Margaret  L.  Kripiu^  PhJ). 

Professor  and  Chairman,  Department  of  Immunology 
University  of  Texas  M.D.  Anderson  Cancer  Center 
Houston,  TX 

Gordon  LeVee,  PhJ). 

Research  Associate 
Invnunodermalology  Unit 
Department  of  Dermatology 
University  of  Michigan 
Ann  Arbor.  MI 

Howard  L  Maibach,  MJ). 

Professor  of  Dermatology 

University  of  California  Medical  School 

San  Francisco.  CA 


Proceedings  of  the  National  Conhxence  on  Envii)onmb4tal  Hazariis  to  ike  Sun 


461 


CG.  Toby  Mathias,  MD. 

Su^  Dtrmaxologist 
Group  Health  Associates 
Cincinnati.  OH 

Lois  Obertielinaii 

Research  Associate 
immunodermatology  Unit 
Department  of  Dermatology 
University  of  Michigan 
Ann  Arbor,  Ml 

Neal  S.  Penneys  MJ). 

Chairmaru  Division  of  Dermatology 
Sl  Louis  University  School  of  Medicine 
St  Louis.  MO 

Robert  L.  Rietscfad,  MJ). 

Chairman,  Department  of  Dermatology 
The  Ochsner  Clinic 
New  Orleans.  LA 

Darrd  S.  Rigel,  MJ). 

Clinical  Associate  Professor 
Department  of  Dermatology 
New  York  University 
New  York.  NY 

Eloy  Rodriguez,  PhJ). 

Professor  of  PhytochemLtry  and  Toxicology 
College  cf  Medicine  and  School  of  Biological  Sciences 
University  of  California,  Irvine 
Irvine.  CA 

Jeanne  Snodgras§,  EdJ). 

Professor  Emeritus 

George  Washington  University 

Washington.  DC 

Arthur  J.  Sober,  MJ). 

Associate  Professor  of  Dermatology 
Massachusetts  General  Hospital 
Boston,  MA 

Robert  M.  Soderstrom,  MJ). 

Chairman.  Task  Force  on  the  Environment 
for  the  Michigan  State  Medical  Society 
Flint.  MI 

Robert  S.  Stem,  MJ). 

Associate  Professor 
Department  of  Dermatology 
Harvard  Medical  School 
Beth  Israel  Hospital 
Boston.  MA 


Frances  J.  Storrs,  MJ). 

Professor.  Department  of  Dermatology 
Oregon  Health  Sciences  University 
Portland  OR 

Ricliard  Tnily,  VADM  (Ret) 

Former  Administrator 

National  Aeroruiutics  and  Space  Administration  (NASA) 

Alexandria.  VA 

Ronald  C.  Wester,  PhJ). 

Research  Dermatologist 
Department  of  Dermatology 
University  of  California,  San  Francisco 
San  Francisco.  CA 


PiiocfeDiNas  CF  iro  National  CoNresBCE  on  Envronmektai.  Hazauis  to  the  Skin 


462 


B.  Corporate  Supporters  for  the  National  Conference  on 
Environmental  Hazards  to  tlie  Skin  and  Conference 
Proceedings 

Benefactors:  $40,000  -  $50,000 

Roche  Dermatologies 

Ortho  Phannaceuticals  Corporation 

Dermik  Laboratories,  Inc. 


Petrons: 


$8,000   $12,000 

Unilever  Research  VS. 

Chesebrough  -  Ponds  U.SA. 

Warner  Laml>ert  Company 

The  Procter  &  Gamble  Company 

United  States  Environmental  Protection 
Agency,  Health  Effects  Research 
Laboratory  (for  support  of  the  Atmospheric 
Hazards  section) 

$3,000  -  $5,000 
Neutrogena  Dermatologies 
The  Andrew  Jergens  Company 
Schering-Ploagh  Heattheare  Products 
Cosmair,  Inc. 


The  Academy  wishes  to  express  its  appreciation  to  the 
University  of  Michigan.  Department  of  Dermatology,  for 
their  assistance  in  obtaining  the  educational  grant  fh>m 
the  Environmental  Protection  Agency. 


C.  Conference  Planning  Committee 

Wihna  F.  Bergfeld,  MJ). 

1992  President.  American  Academy  of  Dermatology 
Head,  Clinical  Research,  Department  of  Dermatology 
Cleveland  Clinic  Foundation 
Cleveland,  OH 

Lowell  A.  Goldsmith,  MJ). 

Professor  and  Chair,  Departmem  of  Dermatology 
University  of  Rochester 
Rochester.  NY 

John  H.  Epstem,  MJ). 

Clinical  Professor  of  Dermatology 
University  of  California  School  of  Medicine 
San  Francisco.  CA 

William  L.  Epstein,  MJ). 

Professor.  Department  of  Dermatology 
University  of  California 
San  Francisco,  CA 

Darrell  S.  Rigel,  MJ). 

Clinical  Associate  Professor 
Department  of  Dermatology 
New  York  University 
New  York.  NY 

James  S.  Taylor,  MJ). 

Head,  Section  of  Industrial  Dermatology 
Cleveland  Clinic  Foundation 
Cleveland.  OH 

Consultants  to  the  Planning  Committee 

John  T.  Gnipenhoff,  PhJ). 

President.  Science  and  Health  Communication  Croup,  Inc. 
Bethesda,  MD 

William  M.  Narva,  MJ). 

Senior  Advisor.  Cutaneous  Biology  Research  Center 
Massachusetts  General  Hospital 
Boston,  MA 

Peyton  E.  Weary,  MJ). 

Chairrrum,  Department  of  Dermatology 
University  of  Virginia  Hospital 
Charlottesville,  VA 


PROCXEnNGS  OF  THE  NaTWNjU.  CoNKRENCX  ON  ENVnONMEKTAL  HaZAKHS  TO  IKE  SlON 


o 


BOSTON  PUBLIC  LIBRARY 


3  9999  05984  232  6 


ISBN  0-16-052519-5 


9  780160"525193 


90000