Realistic Detection Limits and the Political World - ACS Publications

Scientists are a special subset of that greater political community, and we have, over recent .... in ignorance of the actual degree of hazard involve...
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Realistic Detection Limits and the Political World Mike McCormack McCormack Associates, Inc., 508 A Street, S.E., Washington, DC 20003

My comments in this chapter are not particularly technical, unless one considers the subject of constructive and realistic political activity to be "social engineering". I propose to explore the interface between the realities of detection limits on the one hand; and the political world, and our obligations within i t , on the other. Probably the best starting point for such a discussion is the recognition that we are all part of the political community. Responsible scientists cannot avoid the obligations of being citizen-politicians in any free society. Scientists are a special subset of that greater political community, and we have, over recent decades, attracted ever-increasing attention within it. That attention has constituted a blessing in times of success, with acclaim and generous financial support; and a frustration in times of public confusion, incomprehension and fear. The people of any society may, of course, always be categorized according to any number of criteria. For the purpose of this discussion, it is fair, and not uncomplimentary, to define two groups within the population of this country: one in which the concepts of very large and very small numbers are comprehended, and operations with them easily understood, and in which the scientific method — and especially the meaningful interpretation of analytical data is appreciated; and the other group, within which this is not generally the case. For simplicity, we usually refer to these two groups as the scientific, and the non-scientific communities.

0097-6156/88/0361 -0064$06.00/0 © 1988 American Chemical Society

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Realistic Detection Limits and the Political World

I t frequently appears to me that there i s a mutuality of ignorance (and perhaps a "love-hate" relationship) binding — and at the same time — d i v i d i n g these two groups. For instance, a n a l y t i c a l chemists frequently seem unable to understand that their f e l l o w - c i t i z e n s without technical t r a i n i n g cannot understand what the chemists, or many other s c i e n t i s t s and mathematicians, are t a l k i n g about when they attempt to convey s c i e n t i f i c or mathematical information to the public on matters of s o c i e t a l concern, or why their information and recommendations are not r e a d i l y accepted. After a l l , this attitude assumes, s c i e n t i s t s know what they're talking about. Equally confusing, i n the minds o f many members of the non-scientific l a y p u b l i c , i s the generally more objective, l e s s emotional a t t i t u d e that most s c i e n t i s t s take toward presumed threats to human health and safety that — the public i s told — flow from s c i e n t i f i c and technological a c t i v i t y , e s p e c i a l l y i n the commercial, a g r i c u l t u r a l and i n d u s t r i a l world. "Those guys don't care — they're p r o s t i t u t i n g their i n t e g r i t y for a paycheck," so that attitude concludes. The ancient enemies o f humankind have always been ignorance and fear, which i n turn are the progenitors of s u p e r s t i t i o n , hatred, bigotry and the i s o l a t i o n o f one group from another. To a limited but disturbing extent, t h i s phenomenon has developed within t h i s country; and today a g u l f o f confusion, suspicion, fear, emotionalism and sometimes h o s t i l i t y l i e s between s i g n i f i c a n t portions of the s c i e n t i f i c and n o n - s c i e n t i f i c communities . Within the l e g i s l a t i v e arena, and within some portions of the press and e l e c t r o n i c media, t h i s has focused on r e a l or presumed r i s k s to human health and safety from the presence, or the possible presence, of " a r t i f i c i a l " (that i s , d e l i b e r a t e l y manufactured by humans) chemicals i n our food, water, medicines, a i r , the things we touch, or the ground upon which we walk. This often leads to the enactment of u n r e a l i s t i c l e g i s l a t i o n , and to regulations that attempt to override the basic laws of nature and the r e a l i t i e s o f the physical world. The challenge that we i n the s c i e n t i f i c community face arises from the fact that frequently only we understand that such a contradiction e x i s t s , l e t alone what a r a t i o n a l solution to i t may be. This s i t u a t i o n i s further complicated by the f a c t that the fear we are trying to overcome often gives r i s e to an emotionalism within which s c i e n t i s t s and even s c i e n t i f i c f a c t become suspect i n the minds o f some non-scientists. I t i s not uncommon to encounter the argument that s c i e n t i s t s i n a s p e c i f i c d i s c i p l i n e should be d i s q u a l i f i e d from providing information on issues involving that d i s c i p l i n e because "they are prejudiced". In addition, a s i g n i f i c a n t number of i n d i v i d u a l s , from the press and electronic media, from c e r t a i n a c t i v i s t and r e l i g i o u s groups, and even among elected public o f f i c i a l s , often encourage emotionalism with respect to science i n the minds of susceptible i n d i v i d u a l s . At that point, s c i e n t i s t s may throw up t h e i r hands, and tend toward open r i d i c u l e o f , and h o s t i l i t y toward, such i n d i v i d u a l s .

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DETECTION IN ANALYTICAL CHEMISTRY Of c o u r s e , t h i s only exacerbates the s i t u a t i o n . Since we are generally the ones who understand the basics of science related issues, i t i s incumbent upon us, as responsible c i t i z e n s i n a f r e e s o c i e t y , to speak out, p a t i e n t l y helping our non-scientific fellow c i t i z e n s understand; and leading them to responsible, constructive perspectives. This i s a never ending o b l i g a t i o n . Before anyone i n the s c i e n t i f i c community (and e s p e c i a l l y i n t h i s book) becomes over-inflated with self-righteousness, l e t me emphasize that we, as individuals and as a profession, are f a r from f a u l t l e s s or free from legitimate c r i t i c i s m with respect to our r e s p o n s i b i l i t i e s . Certainly more members o f the s c i e n t i f i c community — and chemists i n p a r t i c u l a r — should have recognized at an e a r l i e r date the hazards of i n d u s t r i a l p o l l u t i o n or the unlimited application of c e r t a i n p e s t i c i d e s to the numerous environments i n which we l i v e and work and play. Today i t seems almost impossible to us that any chemist could have been so unconcerned only several decades ago that he o r she would not speak up to protest such p r a c t i c e s . In addition, many members of the s c i e n t i f i c community have seriously damaged meaningful communication with the non-scientific community by the display o f an unbecoming arrogance; f a i l i n g to appreciate that t h i s increases h o s t i l i t y among those already suspicious. These comments are not intended as c r i t i c i s m or soul searching, but to help put the s i t u a t i o n into honest context. The fact i s that there i s a broad chasm of ignorance, suspicion and fear that separates the s c i e n t i f i c community from much of the p u b l i c , the press and l e g i s l a t o r s at the state and federal l e v e l . An increasing volume of l e g i s l a t i o n , s i n c e r e l y intended to p r o t e c t the p h y s i c a l environment, and to insure human h e a l t h and safety has been, and i s being enacted i n t h i s atmosphere. Much of the l e g i s l a t i o n has been proposed as a r e s u l t of honest concerns because of accidents involving chemicals or from emotional reaction to suggestions that some chemical which humans may contact may be a carcinogen or cause other physical harm. L e g i s l a t i o n i s often written i n ignorance of the actual degree of hazard involved; and allowable concentrations of hazardous substances have frequently been e s t a b l i s h e d without an adequate understanding of the r e s u l t i n g impact. This i s a s i g n i f i c a n t problem f o r a l l society, and i t w i l l probably continue u n t i l vigorous i n i t i a t i v e s are undertaken from within the s c i e n t i f i c community to a s s i s t more public o f f i c i a l s and more members of the news media appreciate the r e a l i t i e s involved and the importance of observing them. To be f a i r , the concepts involved i n such l e g i s l a t i o n make good sense to a casual observer from outside the s c i e n t i f i c community. I t seems obvious and l o g i c a l to many honest and sincere c i t i z e n s that i f a substance i s " t o x i c , " "hazardous" or "carcinogenic" that none of i t should be allowed i n our food or drink, i n the a i r we breathe or the ground on which

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Realistic Detection Limits and the Political World

we walk; none at a l l . The concentration, we are t o l d , should be zero. "Why not?" The suggestion that i t i s not p r a c t i c a l to t r y to reduce the concentration o f a hazardous substance to the minimal l e v e l at which i t can be detected (even ignoring cost) frequently seems t o c o n s t i t u t e a "cop-out"; and those who make such a suggestion may be suspected o f being i n league with some deliberate p o l l u t e r who would c a l l o u s l y endanger the health (or the l i v e s ) o f our c h i l d r e n . Analytical techniques that have been developed can now, for most substances, detect concentrations far below hazardous l e v e l s . The effect of these advances i n a n a l y t i c a l capability should be cause for s a t i s f a c t i o n . They w i l l help make poss i b l e future research, both theoretical and applied, including studies r e l a t i v e to human health and safety. However, there are those who i n s i s t on enacting l e g i s l a t i o n that would provide that either (1) the concentration of substances designated as carcinogens should be "zero", or (2) that the concentration o f some contaminants i n drinking water should be as low as detectable. Thus, each new accomplishment i n a n a l y t i c a l technologies that pushes the l i m i t o f detection o f any suspect chemical to a lower concentration, brings with i t the potential f o r new p o l i t i c a l problems. Such u n r e a l i s t i c provisions i n the law or regulations are, i n r e a l i t y , s e l f - d e f e a t i n g . However, i t i s d i f f i c u l t to persuade the non-scientist that they do not protect the public, and frequently cause the waste o f a great deal o f public and private money. There are ways to help the average c i t i z e n understand t h i s . For instance, at one part per b i l l i o n , there are s t i l l t r i l l i o n s o f molecules o f a foreign substance i n a glass o f water. The average c i t i z e n i s shocked to learn t h i s . Another way i s to point out that i n the r e a l world of drinking water and food, at parts per b i l l i o n , there i s some amount of almost everything i n almost everything. Another way to express t h i s t r u t h i s that a "chemically pure" substance (99-9999$ pure) s t i l l contains one part per m i l l i o n impurities. This i s equivalent to 100 d i f f e r e n t substances at 10 parts per b i l l i o n ; or, i f you l i k e , 10 foreign substances at 100 parts per b i l l i o n . Thus i t becomes extremely d i f f i c u l t to analyze a c c u r a t e l y f o r many substances at the l e v e l o f a few p a r t s p e r b i l l i o n because o f p o t e n t i a l contamination of the system from equipment, and from reagent impurities. (Most n o n - s c i e n t i s t s do not appreciate that a b i l l i o n i s one thousand m i l l i o n — and do not comprehend what a t r i l l i o n — or one part per t r i l l i o n means. Here i s an i l l u s t r a t i o n that may be o f value. Imagine ordinary glass marbles about 1/2 inch i n diameter — similar to the ones we played with when we were k i d s . An ordinary square card table w i l l hold about 10,000 such marbles, one layer thick, packed as densely as possible. For comparison, i t would take about two m i l l i o n marbles to cover the f l o o r o f an average size lecture h a l l .

DETECTION IN ANALYTICAL CHEMISTRY It would take about 40 b i l l i o n marbles to cover Central Park i n New York C i t y , one layer deep. Thus, one part per b i l l i o n would be about 40 marbles among a layer of marbles completely covering Central Park. We can r o u t i n e l y detect 40 parts per b i l l i o n of many substances i n water, but not necessarily i n natural systems containing other unknown substances i n higher concentrations; and i t may not be p r a c t i c a l , or even possible, to guarantee the removal of those 40 parts per b i l l i o n from any natural system — without e x o r b i t a n t cost. One t r i l l i o n marbles — one thousand b i l l i o n , or a m i l l i o n m i l l i o n , would cover a l l o f Manhattan Island and a l l of the Hudson River from the George Washington Bridge down to the Battery. Even i n those few cases when we can detect a few parts per t r i l l i o n — the equivalent of a handful of marbles scattered somewhere over Manhattan Island and that stretch of the River — i t would probably not make any sense to t r y to remove them.) You must help make that point, that detection of a chemical and standards s e t t i n g are separate a c t i v i t i e s , the one comprising a s t r i c t l y technical a c t i v i t y and the other, a s o c i e t a l value judgment. The b a s i c r a t i o n a l e for disengaging these two a c t i v i t i e s i s that the ubiquitous presence of other carcinogenic agents — a l l around us — swamps the p o t e n t i a l hazard, even of known carcinogens, at extremely low concentrations. Unfortunately, there has been too much uncertainty and confusion regarding the r e a l meaning and r e l i a b i l i t y of detection l i m i t s f o r t h e i r optimal use i n the world of l e g i s l a t i o n and regulation. I urge you to work toward a consistent d e f i n i t i o n and meaningful r e a l i z a t i o n of the l i m i t of detection from a t e c h n i c a l point of view, so that i t can be accepted by society as a l i m i t above which chemicals w i l l be found ( i f present) with an acceptable degree of c e r t a i n t y . This means that such l i m i t s must f u l l y take into account the r e a l sample c h a r a c t e r i s t i c s including the e f f e c t s of interference, contami n a t i o n , e t c . Otherwise, spurious l e v e l s f o r f a l s e positives or f a l s e negatives may lead to regulations that are too r e s t r i c t i v e or to pressures that make them too l e n i e n t . As with a l l s c i e n t i f i c measurements, working at l i m i t s o f d e t e c t i o n n e c e s s a r i l y involves a n a l y t i c a l uncertainty. However, t h i s c r e a t e s a s p e c i a l problem i n communication where such uncertainties are not generally understood. We must assure that our detection l i m i t s and, i n f a c t , a l l of our a n a l y t i c a l measurements are established with an adequate l e v e l of " c e r t a i n t y " , e s p e c i a l l y as assurance for p o l i c y makers seeking responsible standards. After a l l , they must assure t h e i r c o l l e a g u e s , constituents and the press that standards based on r i s k assessment make the most sense, and that s c i e n t i f i c a l l y v a l i d data have been used i n making such assessments. F i n a l l y , detecting a minute trace of a contaminant does not n e c e s s a r i l y make i t s economic removal p r a c t i c a l . This i s not immediately obvious to the average layman, but i t can be e a s i l y explained by extrapolating the concept to the point of absurdity. Can we remove one part per million?

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Realistic Detection Limits and the Political World

I f so, i s i t s t i l l possible to remove one part per b i l l i o n ? I f s o , and we find one part per t r i l l i o n , i s i t possible to remove i t , etc.? These r e a l i t i e s must be borne i n mind by s c i e n t i s t s who work i n the realm of detection l i m i t s when reporting their findings to non-scientists, and e s p e c i a l l y to lawmakers. This brings me back to our o b l i g a t i o n as c i t i z e n s . I hope you w i l l take this matter s e r i o u s l y . We a l l f a c e a monumental challenge. Fortunately, we have s c i e n t i f i c truth and common sense as our most e f f e c t i v e tools. We must add to that a dedication to serving our fellow c i t i z e n s by helping them understand, and putting the technology and i t s purposes into proper context. R E C E I V E D September 22, 1987