"Our Challenge"
   An address by
   William D. Ruckelshaus
   U.S. Environmental Protection Agency
    'SCX FnvironmentsI Protection Agency
   United States
   Environmental Protection

 flemurks by William D. fluckeishaus, Administrator of
 U.S. Environmental Protection Agency, at the semi-
 annual meeting of the Chemical Manufacturers Associa-
 tion in New York City, November 8, 1983.
S. Environment?.!  Protection

Our Challenge
You have asked me to speak to you about the
"state of the environment." Well, there is little
question that the environment is in a better
state than it was in when I first had this job
thirteen years ago. Many major sources of gross
and obvious pollution have been controlled.
The number of days of unhealthy air in major
cities has declined virtually without a break
since 1974. Despite growth in the economy and
population, we have seen no decline in water
quality over the past several years and impor-
... if I had to sum up the present en-
vironmental situation in a phrase, I
would say that we're doing better and
feeling worse.
tant rivers have made remarkable comebacks. In
short, we have attained many of the environ-
mental goals we set for ourselves a decade ago.
Yet, if I had to sum up the present environmen-
tal situation in a phrase, I would say that we're
doing better and feeling worse.

The reason for this is plain to see. We have
shifted our attention and concern from prob-
lems that are relatively easy to see and solve to
those that are subtle and  vexing, from smoke
and sewage to the attempt to eliminate toxic
substances from the human environment.
I can tell you that this  shift has caused sub-
stantial problems for EPA; I don't have to tell
you the even greater problems it has created for
the chemical industry.  Having accumulated a
good deal of experience and confidence in con-
trolling the so-called conventional pollutants,
we find, with no little  dismay, that controlling
toxics is an entirely different sort of business.
Where we once dealt with a dozen or so pollu-
tants, we now must consider hundreds. Before,
we concentrated on removing familiar sub-
stances by the ton; now, we often must cope

.  . . we are now confronted with mate-
rials that may be able to cause serious
human health damage in vanishingiy
small  concentrations.
with the exotic and worry about micrograms be-
cause we are  confronted with materials
that may be able to cause serious human health
damage in vanishingly small concentrations.
Most important, our base of scientific research
in this area is inconclusive, which means that
we often cannot reliably distinguish between
trivial risks and important public health prob-
I am not sure that either EPA or the chemical
industry has responded well to this new chal-
lenge. In any  event, I want to share with you
my ideas about the nature of that challenge,
and about what the institutions we represent
can do, both individually and together, to meet
it more effectively.
You know, there's an old saying that goes, "It's
easy to climb mountains and it's easy to fall off
mountains. The hard part is climbing moun-
tains without falling off." Similarly, I can think
of easy ways  to have a healthy environment
and I'm certain you can think of easy ways to
have a healthy chemical industry. The hard
part is getting both at the same time.
 . . .  Jorge numbers of Americans are
 frightened that toxic chemicals in their
 environment may affect their health.
 To proceed intelligently in this direction, we
 must begin by accepting as fact that large num-
 bers of Americans are frightened that toxic
 chemicals in their environment may affect their
 health. The American people place an ex-
 traordinarily high premium on good health; we
 spend a greater proportion of our gross domes-

tic product on health than any other country.
The notion that health is being insidiously
affected by chemicals  thus bears a particularly
heavy emotional freight. For the moment we
must forget about whether these fears are jus-
tified or rational; the fear itself is an undeniable
reality and must be dealt with as such.
Equally apparent is the association made by
much of the public between the perceived
threat from toxic chemicals and the chemical
manufacturing industry. The public at large is, I
believe, quite indifferent to the proximate
source of the contaminants that worry it. The
great names in the industry, the major firms,
are virtually household words. It is no surprise
that when somebody uncovers a nasty dump or
when there is a highly publicized debate about
some toxic pollutant, most people think of the
well-known chemical  producers.
In a sense, EPA has done something similar, in
that we usually look for opportunities to control
major point sources of toxic pollutants,  irre-
spective of the proportion of emissions  such big
sources represent. It's  easier to control a dozen
sources than a thousand. Also, when EPA
comes under pressure to control a chemical, it
is natural to look to firms that can afford con-
trols. Once again, these are generally the major
I must tell you that I find something unsettling
about this. It reminds  me of the story about the
policeman who finds a drunk crawling  around
under a streetlight. He says he's looking for his
keys. The  policeman asks him if he dropped
his keys under the streetlight, and the drunk re-
plies, "No, I dropped them under my car, but
it's too dark to look down there."
For the industry giants to bear the brunt of pub-
lic and governmental blame is in one sense un-
fair. There is no industry that has devoted as
much energy and resources to health concerns
as the chemical manufacturing industry. Its
worker health programs are a model for other
industries, and I know from personal experi-
ence that when corporations in other fields
want reliable information on the toxicity of
products, they turn to the chemical industry.

On the other hand, the attitudes I describe are
not entirely capricious. The mistakes of the past
were real. For a long time—too long, in fact—
reputable firms disposed of wastes they knew
to be extremely hazardous in ways that can
only be described as disreputable: the guiding
philosophy seemed to be out of sight, out of
mind. Hazardous waste dumps are real. People
have been injured  through carelessness on the
part of industry.
Besides that, we all understand that there are
bad apples in every bunch. In the press of com-
petition, some firms may seek advantages in
ways that reflect badly on the industry in
general. As I noted, it is sometimes difficult for
the public to distinguish between the good guys
and the bad guys.
The most important factor fueling negative atti-
tudes toward the industry is, I believe, the atti-
tude of the industry itself toward the public's
concern about danger from toxic chemicals. The
public often sees industry representatives
pursuing a strategy made up of delay, of mak-
ing excuses, of avoiding responsibility, and of
self-serving assurances  that there is really noth-
ing whatever to worry about. If this strategy
was designed to allay public fears and reduce
the pressure on the industry, then it has cer-
tainly failed. Unfortunately, the perception that
economic interests are involved in statements
from the industry about the health effects of
chemicals renders  suspect in the public mind
all such statements.
.  . . I would caution you not to dismiss
public fears because your calculations
show them to be "irrational."
I think you have to accept the industry's lack of
credibility on health questions as a fact of life
deriving from complex historical and in-
stitutional factors. I understand how the many
competent and reputable scientists who work in
the industry might resent it. Decrying public
ignorance of factors involving their health may

assuage such resentment, but it only fuels nega-
tive public perceptions about the chemical in-
dustry's social conscience.
Nevertheless, you must continue to put forward
the facts at your disposal; indeed, it is essential
that you do so. The chemical industry is  our
greatest and most reliable source of information
on chemical species, on their behavior under
all conditions of physical state and mixture, on
controlling hazards and recycling wastes. De-
spite this acknowledged expertise,  I would cau-
tion you not to dismiss public fears because
your calculations show them to be "irrational."
We know, of course, that some public fears do
not stand up well before  statistical tests. For ex-
ample, a recent poll published in Scientific
American asked people from different groups to
place in rank order the risk of death from var-
ious causes. It was clear from the results that
many people have ideas about relative risk that
are at variance with any strictly statistical evi-
dence we have.
.  . .  public safety is a judgment, not a
mathematical calculation.
If, as the poll suggests, college students believe
that pesticides and nuclear power plants pre-
sent greater risks than boating or motorcycle
accidents (a supposition, I might add, not
strongly supported by actuarial statistics), then
they will seek to impose stricter controls on the
risks they believe to be more  important. There
is nothing inherently wrong with this; public
safety is a judgment, not a mathematical
calculation. As such, it is properly housed in
the political process. We can  try to change
these judgments over time, with evidence, with
research, but we do ourselves a disservice  if we
pretend that the concerns these political judg-
ments address are not "real."
We may ask, why is rational argument less than
convincing in discussions about toxic chem-
icals? Why aren't the judgments more in line
with our calculations? I believe it is because

public concern is centered on those dreaded
diseases that are plausibly connected with low
concentrations of toxic substances; that is, can-
cer and the genetic and reproductive disorders,
I think people sense that we really
don't know how and under what cir-
cumstances chemicals cause cancer;
they're right,  we don't.
and because, at the heart of our risk assess-
ments, there is, undeniably, a hollow place. I
think people sense that we really don't know
how and under what circustances chemicals
cause cancer; they're right, we don't.
There are over 400,000 deaths from cancer each
year. About two percent of children are born
with some  defect. How much of this toll is
associated with exposure to toxic chemicals?
Almost none? A lot? There are credentialed sci-
entists supporting extreme points on this spec-
trum and many in between. This uncertainty
imposes upon those with a responsibility to the
public, and I trust that includes all of us here, a
position of prudent concern.
I have no doubt some of this concern may
prove mistaken in years to come, but in this we
are very much in the position of the early Eu-
ropean sanitarians, who fought for sewer sys-
tems and other basic public health measures in
the early nineteenth century. These people did
not know about germs, and were roundly mock-
ed by people who believed there was no prov-
able connection between dirt and disease. In
fact, some  of the justifications the sanitarians
put forward to defend their projects appear
quaint and ridiculous to us now, and no doubt
our solemn pronouncements about cancer will
so appear to our posterity. But they built sewers
anyway. There is a lesson for us here about ac-
tion in the face of ignorance.
Let me explain how EPA is responding to this
problem, which we share,  of acting in the face
of ignorance. First, we accept risk assessment as

an important tool. Given the very great numbers
of possible regulatory objects of interest, it is in-
dispensable for setting priorities. It is also use-
ful as a means of demonstrating to a concerned
public that we are working on the most signifi-
cant risks. But note this: risk assessment can
seriously backfire if there is any suspicion that
policy interests (other than concern for public
health) have intruded into our calculations  of
risk. At EPA we have tried to disentangle risk
assessment, as a process, from the policy con-
siderations that go into making a final decision
about regulating a substance, which we call risk
management. I realize there is not an obvious
bright line between the two; still, I believe that
good public policy obliges us to make it as
bright as we can.
This is something that industry has not always
done, and the idea that economic interests pre-
vail over health concerns in industry statements
about risk has stuck in the public mind. I
should add  that there are some hopeful signs
that this is  changing. Much of the  industry  has
embraced the principle that risk assessments
must emerge from disinterested establishments.
I trust that this trend—whose exemplar is the
Chemical Industry Institute of Toxicology—will
The public must be convinced that
when we have a reasonable belief in an
unreasonable  risk we will move to re-
duce it, swiftly and decisively.
But risk assessment is not a solution to the
problem of public fear and public trust. It is my
belief that the key to the acceptance of any
body of analysis is the public perception of ac-
tion. The public must be  convinced that when
we have a reasonable belief in an unreasonable
risk we will move to reduce it, swiftly and de-
Now, we may not agree on whether such ac-
tions are worthwhile. We all know  how many

  assumptions go into risk assessments and how
  radically the assessments change when you
  vary them. If we often disagree on things that
  appear eminently possible to pin down, such as
  control costs, then of course we're going to fight
  over numbers that inhabit what one of our sci-
  entists ruefully calls "a mathematical
  fairyland." But although we are deeply com-
  mitted to finding the most cost-effective ways of
  controlling public health risks, we cannot wait
  for the last decimal point to be entered. I have
  no doubt that we will in the future require ex-
  penditures that your analysis shows control in-
  considerable risks. I think that society has told
  us to pay that price as a sort of insurance. In a
  certain sense, the actual, quantifiable risk
  reduction we obtain thereby is beside the point.
  We  are really buying freedom from fear, and
  most Americans are willing to pay a reasonable
  price to obtain it.

  Moreover, if we do not act decisively under the
  conditions I have described, the public trust in
  EPA will erode. Indeed, in some quarters it
  already has. Our friends in the environmental
  movement would like us to be strictly bound
  by statutory mandates so that we would have
  little freedom to perform the balancing and
  priority-setting operations implied by the term
  ... a strong and trusted EPA is the
  best friend the industry has.
 risk management. I don't think this is a correct
 approach. In terms of efficient public health
 protection it is no substitute for Agency flexibil-
 ity. But this flexibility will be granted us only if
 we are trusted, and in order to be trusted we
 must act where the facts warrant. This is an im-
 portant point for the industry to consider be-
 cause I believe the events of the last few years
 have shown that in the long run a strong and
 trusted EPA is the best friend the industry has.
MS. Environmental  Protection Agency
i  .   :-,-• V.  -. ib"gry
;:-..•  c:.'Ji:- reborn Street
Ci.,-•:.:;>•, Illinois  £0604

The chemical industry can help itself a great
deal in this matter by adopting a similar policy.
You can take actions that will capture the pub-
lic imagination and make you appear, in the
old phrase, part of the solution instead of part
of the problem. As to what actions would be
suitable, I will quote no less an authority than
your past chairman, Bill Simeral:
   "To start, we can clean up the dumps.
   .. .Abandoned dump sites are the single,
   most obvious symbol of everything the pub-
   lic believes to be wrong with the chemical
   industry. Whatever their impact on the en-
   vironment, rusted drums are poisoning the
   climate for the chemical industry in Wash-
   ington and across the nation. As long as we
   let the problem persist, we don't stand a
   chance at winning the confidence of the peo-

I couldn't agree more, and the same goes for us
in government. We have to stop playing "who
We have to stop playing "who struck
John" around the issue of responsibility
for hazardous waste sites.
 struck John" around the issue of responsibility
 for hazardous waste sites. We have to go
 beyond public relations and the legal niceties.
 The public is not going to stand still when rep-
 resentatives of a multibillion-dollar industry
 and government officials at all levels dance a
 minuet around cleaning up a site that has some
 little town scared half to death.
 As I noted, the management of your organiza-
 tion is aware of the need for movement on this
 issue, as are we. As you are probably aware, we
 have changed our policy regarding cleanup
 projects in that we now begin the actual site
 work before nailing down the details about who
 will ultimately bear the cost. In addition, I have
 encouraged an informal group made up of rep-
 resentatives of industry, the Agency and the en-
 vironmental community to  develop recom-
 mendations about how we can all  work

together to speed the cleanup. We expect rec-
ommendations from them early in 1984.
I view this sort of effort as an initial step in the
widening of the industry's assumption of re-
sponsibility  concerning toxic chemicals in the
environment. I think you will sooner or later
have to confront hazardous waste disposal in a
much more comprehensive way thn you have
in the past. I can't believe that the use of chem-
icals in general will increase as much as you
would like it to if people who use them in
It is in your ultimate interest to insure
that your customers can dispose of
wastes safely .  . .
commerce do not have a safe place to put
potentially hazardous waste. It is in your ul-
timate interest to insure that your customers
can dispose of their wastes safely even if this
means, in some cases, taking care of them
yourselves. The chemical industry must begin
to prepare itself for helping police the whole
cycle of use, disposal and recovery for a variety
of toxic chemicals.
Why should you do this? Isn't it sticking your
neck out? Isn't your job simply to make and sell
chemicals and realize a profit? In answer I
would turn to Peter Drucker's argument that
profit is a necessary condition of enterprise, but
not its ultimate end, which is to insure the sur-
vival and growth of the organization. I hope
that what I've said today, and what you have
heard from others both within and outside the
industry, convinces  you that the survival and
growth of the institutions you represent is in
some doubt if you do not act quickly, boldly
and convincingly to rid the environment  of tox-
ic substances where you can and stem the pub-
lic apprehension they engender.
This is your challenge, our challenge. I believe
rising to meet it is a necessary ingredient in the
prosperity of your industry and the well-being
of our country. We should get on with it.