Bioethics and society
THE HYPOTHETICAL SCENARIO
The U.S. Environmental Protection Agency is in the midst of a review process to determine whether to ban the herbicide atrazine or to allow its continued use.
You have been brought in as an ethics advisor as part of this process. The EPA has asked you to write a report about the ethical and political dimensions of the decision before them. Lucky you! You have just completed a training (ESPM 162 Unit IV) that gave you many conceptual tools and examples to help you do this.
You are one of several representatives from different disciplines who are presenting evidence about atrazine in the decision-making process. The EPA has asked you to consider the evidence from the experts below in the report you’re writing.
INSTRUCTIONS
Write a 900 – 1,100 word report that tells the EPA whether you advise the agency to ban atrazine or allow its continued use. Clearly explain why you made this decision by detailing what you feel are the most salient ethical and political dimensions of agricultural use of atrazine in the U.S.
Academic goal
Strong assignments will include clear, well-articulated links between the course concepts, readings, lectures, and details about atrazine.The goal of this assignment is to demonstrate your understanding of:
• Ethical and regulatory frameworks for environmental health decision-making (utilitarian vs rights-based approaches, distributive & procedural justice, cost-benefit analysis, precautionary principle, risk analysis, democratizing decision-making)
• The role of science, scientific data, and scientific uncertainty in environmental health decision-making processes
RESEARCH& CITATIONS
We have included useful information about atrazine below. You are also strongly encourage to do your own research.
BACKGROUND DETAILS
Product details
• Atrazine is a product of Syngenta. The company maintains that the chemical composition of the product is a trade secret.
• More than 76 million pounds of atrazine are used each year in the U.S.
Maximum Contaminant Level
• The U.S. EPA used a risk analysis model to set a Maximum Contaminant Level (MCL) for drinking water (the level at which exposure from drinking the water is considered to be safe). The MCL for atrazine is set at 3 parts per billion.
Regulatory precedent
• Other countries have come to very divergent decision about atrazine
• Based on a cumulative risk assessment, the U.S. EPA has stated that “the risks associated with the pesticide residues pose a reasonable certainty of no harm” and that atrazine is “not likely” to cause cancer in humans.
• Taking a precautionary approach, the European Union banned its use based on data associating it with health and environmental problems.
TESTIMONY & EVIDENCE
Epidemiologist
• A number of studies have identified associations between atrazine exposure and risk of cancers.
o A higher risk of ovarian cancer was observed in a study of women farm workers exposed to atrazine. However, this study could not show a statistically significant correlation between exposure and cancer, could not demonstrate a dose-response relationship, and could not control for potentially confounding factors such as smoking.
o Another study found a higher incidence of breast cancer in regions (demarcated as counties) with a medium to high level of exposure, which was determined by assessing the use of atrazine on agricultural fields and levels of atrazine in drinking water.
o A higher risk of a cancer called non-Hodgkin’s lymphoma was also observed in several studies of male agricultural workers who mixed or applied atrazine. However, a re-analysis of these studies found that when exposure to other pesticides was taken into consideration, there was little association between exposure to atrazine and the risk of developing non-Hodgkin’s lymphoma.
o An independent scientific panel which assessed all available scientific information in 2009 noted strong evidence pointing towards an association between atrazine and certain types of rare cancers (including thyroid and ovarian) and called for more research funding to investigate these links.
• Studies have also demonstrated possible endocrine disrupting effects of atrazine exposure including male infertility and increased risk of miscarriage or of having an underweight or premature baby.
• Several studies assert that there is no statistically significant correlation between atrazine and human health effects. However, most of these studies have authors affiliated with Syngenta, the manufacturer of atrazine.
Toxicologist
• Several studies found either a higher number or earlier appearance of mammary gland tumors in rats fed a moderate to high level of atrazine. These studies suggest that atrazine could be a possible breast cancer causing agent. However, similar studies in a different breed of rat found no correlation.
• A growing body of toxicological data suggests that atrazine is an endocrine disruptor. Amphibian studies have shown that atrazine disrupts hormone production by inhibiting the production of testosterone and inducing the production of estrogen. It has also been associated with sexual abnormalities, immune failure, retardation of growth and development, and birth defects.
Environmental justice advocate
• Rural communities are exposed through contamination of drinking water.
o During peak agricultural seasons, levels of atrazine in drinking water have been known to exceed the MCL, reaching up to 9-10 parts per billion for weeks.
• Farmers and farm workers are more heavily exposed to atrazine than the general population.
o Note the details provided about farm worker health risks by the epidemiologist above
o Farm workers also typically suffer cumulative exposure from multiple pesticides in addition to atrazine
• While all containers of atrazine include instructions on “best” and “safe” use, the instructions are typically written in English. For the majority of farmworkers in the U.S., English is a second language; they may not be able to read instructions.
• In the U.S., farm workers are excluded from the protections of legislation that applies to workers in other sectors, such as the National Labor Relations Act and Fair Labor Standards Act. This means they are often paid less than the minimum wage, do not have any formal grievance process for unfair or unsafe working conditions, and are not unionized.
Ecologist
• Atrazine is found in surface waters (lakes, rivers, and streams) where it typically degrades within 100 days.
• Atrazine can also migrate through soil to groundwater; once it leaches into groundwater, it can remain for decades.
• Some studies have found that fish and amphibians exposed to atrazine in surface water suffer a range of health effects including reproductive problems, compromised growth, and damaged immune function.
• In estuaries, atrazine has been demonstrated to inhibit photosynthesis in phytoplankton, which may negatively affect higher level species in the aquatic food chain such as clams and oysters that rely on phytoplankton as a food source.
• Atrazine can be an effective tool to help farmers practice agricultural methods that decrease soil erosion (a major agricultural problem) by reducing the number of times a farmer plows his or her field, this is called conservation tillage.
Economist
• Atrazine is a more affordable option for farmers than other herbicides.
• Several studies have tried to weigh the costs and benefits of using atrazine:
o Syngenta asserts that the cost of an atrazine ban would be $555 million annually. This is based on the idea that atrazine increases corn yields by 6%, farmers do not choose an alternative pesticide, and that consumers have no preference for organic food.
o The U.S. Department of Agriculture has estimated the aggregate economic loss to society of banning atrazine to be $355 million annually.
o A university-affiliated economist doing a meta-analysis argued that yields were only increased by 1-4%, and in some locations yield was not increased at all. The economist argued that this does not justify using a potentially dangerous pesticide.
COURSE CONCEPTS FROM UNIT IV
Better Living Through Chemistry
• Chemical body burden
• Toxic trespass
• Endocrine disruption
• Transcorporeality
Unintended Consequences
• Technological optimism
• Eco-socio complexity
• Antibiotic use in animal agriculture
Environmental Justice
• Distributive justice
• Procedural justice
• Cost-benefit analysis
• Utilitarian vs rights-based models
• CHAMACOS study
• A Tale of Two Sandys
• Climate justice
Risk Analysis
• Epidemiology
• Toxicology
• Sources of uncertainty
• Blackboxing
• The case of asbestos
A Precautionary Approach
• The case of DBCP
• The case of BPA
• “Guilty until proven innocent” / “innocent until proven guilty”
• “Lack of proof of harm does not equal proof of lack of harm”
• “Toxic soup”
• John Snow
Debating “sound science”
• Manufacturing doubt
• Contested knowledge
Democratizing Decision-making
• Technocracy
• Citizen science
• The case of Love Canal
• Right to Know