A new study underscores the wisdom of reducing the risks of mercury and other pollutants rather than relying on risk avoidance measures such as fish consumption advisories. Mercury’s adverse effects are not limited to human health; its harms are felt throughout our ecosystems. According to this most recent study, released today by the Biodiversity Research Institute, mercury harms a broader swath of wildlife than previously recognized, including many bird species that are not piscivorous. This finding echoes those of studies in the Great Lakes published this fall, which concluded that a larger number of species were adversely affected by mercury contamination than previously understood by scientists.
From a regulatory perspective, the harms of mercury contamination might be addressed by risk reduction – measures that require the sources of mercury pollution to reduce or prevent mercury releases into the environment – or by risk avoidance – measures that leave it to those who are exposed to protect themselves from mercury permitted to enter or remain in the environment. The EPA’s recent rule regulating coal-fired power plants’ mercury emissions is an example of the former approach. An example of the latter approach was the George W. Bush administration’s suggestion, upon proposing an exceedingly lax rule for power plants (ultimately vacated by the D.C. Circuit), that people protect themselves from the continued mercury contamination by consulting national and local fish consumption advisories.
I have elaborated the many perils of relying on risk avoidance in lieu of risk reduction elsewhere. Among the limitations of depending on risk avoidance measures such as fish consumption advisories, ozone alerts, and “keep out” signs, are the facts that these measures are unjust and ineffective in practice. They simply don’t result in “the same amount” of protection for human health, as proponents of such measures hope.
Today’s study highlights another problem: risk avoidance is myopic. Because risk avoidance measures target only specific, direct threats to human health, they fail to address adverse effects on any non-human components of ecosystems. Signs erected along our bays and lakes warning that fish intake should be limited due to mercury contamination obviously don’t reach the eagles, bears, and other species that depend on fish. Websites are not consulted by a wood thrush.
Such myopia is at odds with the understanding that human health is but one end of our environmental law and policy goals – an understanding enshrined in many of our nation’s environmental statutes. Moreover, even if one were concerned chiefly with impacts to human health, a reliance on risk avoidance fails to appreciate the myriad ways in which human health is indirectly impacted when non-human health is impaired. As the Great Lakes studies found, mercury’s adverse impacts on piscivorous fish include harms to their reproductive success and survival – resulting, of course, in depletion of species relied upon by humans for food.
Human health is inextricably linked with ecological health. Today’s study underscores the importance of reducing mercury and other toxic contamination at the source.
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Catherine O'Neill | January 24, 2012
A new study underscores the wisdom of reducing the risks of mercury and other pollutants rather than relying on risk avoidance measures such as fish consumption advisories. Mercury’s adverse effects are not limited to human health; its harms are felt throughout our ecosystems. According to this most recent study, released today by the Biodiversity Research […]
| January 20, 2012
For more than a century, the United States took the lead in organizing responses to international environmental problems. The long list of environmental agreements spearheaded by the United States extends from early treaties with Canada and Mexico on boundary waters and migratory birds to global agreements restricting trade in endangered species and protecting against ozone […]
Alice Kaswan | January 19, 2012
The Clean Air Act’s potential to address the nation’s greenhouse gas emissions is slowly being unveiled. EPA’s expected announcement of highly-anticipated new source performance standards for power plants by the end of January will reveal whether the agency has the political will to use its existing authority to re-shape the United States’ dependence upon high-carbon […]
Rena Steinzor | January 17, 2012
A panel of business leaders comprising President Obama’s Council on Jobs and Competitiveness today published a “Road Map to Renewal,” including proposals for expanded oil and gas drilling, and, of particular interest, five pages of policy recommendations related to regulation. Among them were procedural proposals aimed at further hamstringing regulatory agencies in their effort to […]
Holly Doremus | January 14, 2012
Cross-posted from Legal Planet. Clearly I need to slow down Rick’s internet connection to get him to stop scooping me. Rick reported earlier that the President has floated a proposal to reorganize the Commerce Department and related agencies which would apparently include moving NOAA (all of NOAA, according to OMB’s Jeffrey Zeints, not just its ESA […]
Holly Doremus | January 11, 2012
Cross-posted from Legal Planet. As usual, I’m behind Rick on commenting on the latest Supreme Court development. (In my defense, it is the first day of classes, although I know that’s not much of an excuse.) Unlike Rick, I didn’t attend the oral argument (see lame excuse above), but having read the transcript I agree […]
Matt Shudtz | January 10, 2012
On Monday, GAO released its latest installment in what has become a somewhat regular series of reports on EPA’s Integrated Risk Information System (IRIS) program. In 2008, GAO warned that “the IRIS database was at serious risk of becoming obsolete because the agency had not been able to keep its existing assessments current, decrease its […]
| January 9, 2012
If environmental cases had their own Olympics, the dispute between Chevron and Ecuador would be a contender for multiple gold medals. It seems to have a shot not only at winning the award for the largest damages, but also for running the longest and appearing in the most courtrooms. To recap: Residents of the Amazon […]
Rena Steinzor | January 9, 2012
With a reverential nod to maverick economist Jeff Madrick, who wrote a popular book of the same name, I begin today a series of blog posts entitled “The Age of Greed” that is designed to shine a bright spotlight into the dark corners where Washington lobbyists are busy looting the protection of public health, worker […]