EDITORIAL The protection quandary At this point I know that CHC13 and its sister halomethanes are in my drinking water and that they result from an effort to protect me from microbiologic harm with chlorine disinfection. I believe that the relevant chemistry is probably complex, involving reactive sites on humic macromolecule(s) and OC1-, which may or may not have anything to do with the classic “haloform reaction.” I also believe that CHC13 produces a dose-related tumorigenic response in certain test animals at dosages considerably higher than those I routinely ingest. I worry that lower concentrations of CHC13 and/or its analogues in my drinking water may produce the same effect in me. The difference in my personal decisions to know, believe, or worry is related to the availability of factual evidence which ranges from substantial to circumstantial for these three judgments. I wonder which I want to be protected from-harms that I know of, those that I believe in, or those that I am worried about? With involuntary exposures like the water I must drink or the air I breathe, I have every expectation that effective government regulations and agency enforcement procedures will protect me from known and believable insults (e.g., radiation, arsenic, pesticides, etc.) as a bare minimum. I’m shamelessly uncertain about protection from my worries-I may settle for something akin to hand holding-but I certainly don’t want them ignored, and it hardly seems protective to wait for some poor soul(s) to become the first unassailable evidence of harm before the federal Goliath moves. This must be the meaning of protection, that the costs of stopping protective policies that are ultimately shown to be unnecessary are inherently less than the costs of acting too late. This was the refreshing spirit behind the passage of the Safe Drinking Water Act, and it materialized from a sad previous
history of environmental inaction, underestimation, and legislative caution. A House subcommittee on environment and health is now considering proposed amendments to this act which would impose stricter burdens of proof on EPA in establishing maximum contaminant levels in drinking water and would remove the administrator’s present authority to require treatment of any kind. The spirit behind this amendment is not the kind of protection I want. It presumes that I place a higher priority on the costs of meeting standards that future data may show to be too strict than I do on protection from the potential harm while the matter is being studied. Well, I don’t want a Safe For Now (we think) Drinking Water Act. I want the administrator of EPA to protect me from any contaminant that may have any adverse effect on my health. I want the hazards studied continuously, discussed openly, and the standards revised when new knowledge permits. If some, but not.al1, specialists believe a hazard exists, then I’m woriied; if some hazards cannot be adequately monitored for, then I want the administrator to require treatment to remove them. The present law (PL 93-523) gives me this protection. I realize I can’t be protected from everything-and the less the scientific evidence of risk, the less I am willing to pay for protection. The cost estimates I have seen for meeting the T H M regulation and the now withdrawn carbon-treatment regulation seem worth it to me. Cost/benefit analyses, burden of proof, national surveys, and more research are all fine with me. Just don’t stop protecting me in the meantime.
Volume 14, Number 7, July 1980
757
