A REPORT CRITIQUE OF THE BIOLOGICAL AND CLIMATE EFFECTS RESEARCH (BACER) EFFECTS OF STRATOSPHERIC MODIFICATION BY AN AD HOC STUDY GROUP TO THE ECOLOGY ADVISORY COMMITTEE AND THE ENVIRONMENTAL HEALTH ADVISORY COMMITTEE SCIENCE ADVISORY BOARD U.S. ENVIRONMENTAL PROTECTION AGENCY JULY 20, 1977 ------- EPA NOTICE This report has been written as a part of the activities of the Agency Science Advisory Board, a public advisory group providing extramural scientific information to the Administrator and other officials of the Environmental Protection Agency. The Board is structured to provide a balanced expert assessment of scientific matters related to problems facing the Agency. This report has not been reviewed for approval by the Agency and hence its contents do not represent the views and policies of the Environmental Protection Agency, nor does mention of trade names or commercial products constitute endorsement or recommendation for use. ------- UNIVERSITY OF CALIFORNIA, IRVINE BERKELEY • DAVIS • IHVINE • LOS ANCELES • RIVERSIDE • SAN DIECO • SAN FRANCISCO SANTA BARBARA • SANTA CRUZ CALIFORNIA COLLEGE OF MEDICINE DEPARTMENT OF COMMUNITY AND ENVIRONMENTAL MEDICINE IRVINE, CALIFORNIA 92717 July 20, 1977 Dr. Norton Nelson Chairman Environmental Health Advisory Committee Institute for Environmental Medicine New York University Medical Center 550 First Avenue New York, New York 10016 Dr. Gordon H. Orians Chairman Ecology Advisory Committee Institute for Environmental Studies University of Washington Seattle, Washington 98105 Dear Doctors Nelson and Orians: I am pleased to transmit, herewith, the report of the Ad Hoc Study Group to critique the document, Biological and Climate Effects Research (BACER)--Effects of Stratospheric Modification. The Study Group has attempted to address itself to the issues contained in your letter of charge of March 4, 1977. I believe it addresses the issues as objectively and comprehensively as was possible considering the lack of specifics and details contained in the document. The Study Group hopes that this report will be helpful. I would be glad to make myself available to you to clarify any aspect of this critique. James H. Sterner, M.D. Clinical Professor of Occupational Medicine and Industrial Health Care ii ------- BIOLOGICAL AND CLIMATE EFFECTS RESEARCH (RACER) EFFECTS OF STRATOSPHERIC MODIFICATION AD HOC STUDY GROUP Dr. James H. Sterner, Chairman Clinical Professor of Occupational Medicine College of Medicine University of California, Irvine Dr. Sidney W. Benson Professor Department of Chemistry University of Southern California Dr. John L. Buckley Whitney Point, New York *Dr. Keith McCree Program Manager Advanced Energy and Resources Research and Technology National Science Foundation Dr. Warren P. Porter Professor of Zoology University of Wisconsin, Madison Dr. Ruth A. Reck Senior Research Chemist Research Laboratories General Motors Corporation Dr. Richard B. Setlow Senior Biophysicist Brookhaven National Laboratory Dr. Raymond R. Suskind Director Department of Environmental Health University of Cincinnati * * * * * Dr. J Frances Allen, Staff Officer, Science Advisory Board *On leave from College of Agriculture Texas A§M University, Bryan, Texas iii ------- Preface A letter of November 19, 1976, (Appendix A) from Dr. Wilson K. Talley, Assistant Administrator for Research and Development, to Dr. Emil M. Mrak, Chairman of the Executive Committee of the Science Advisory Board, points out that EPA has been assigned the role of lead Agency for the Federal interagency research program on the biological and climatic effects of stratospheric ozone reduction. This program is based on multi-year plans developed by ad hoc interagency Technical Task Groups. His letter requests the Science Advisory Board to review the long-tern plans and the set of objectives that have been identified as being critical and hence studies selected for funding under the short term program--$4 million during Fiscal Year 1977. In response to this request the Board's Executive Committee at its meeting January 4-5, 1977, assigned the responsibility for critiquing this material jointly to the Ecology Advisory Committee and the Environmental Health Advisory Committee. In response to this assignment the Chairman of the Ecology Advisory Canmittee and the Chairman of the Environmental Health Advisory Committee established an Ad Hoc Study Group to evaluate the document, Biological and Climate Effects Research (BACER)-- Effects of Stratospheric Modification" In a letter of March 4, 1977, (Appendix B) Dr. Orians, Chairman of the Ecology Advisory Committee, and Dr. Nelson, Chaiiman of the Environmental Health Advisory Committee, addressed to Dr. James H. Sterner, Chairman of the Ad Hoc Study Group, directed the Ad Hoc Study Group to critique the material in two contexts, as follows: ... whether major errors of omission or commission can be seen in the short-tern program, whose tasks have been selected primarily to reduce ranges of uncertainties or to identify potential problem areas where knowledge presently is virtually non-existent. ... assuming approval of the long-term program, a more measured assessment of its adequacy to provide the infomiation required of regulatory decision-makers, the lack of which currently makes it difficult to meaningfully forecast the impacts of stratospheric ozone depletion, is needed. iv ------- The Ad Hoc Study Group's report will be presented to the Ecology Advisory Committee and to the Environmental Health Advisory Committee for appropriate action. The Study Group held its first meeting April 6 and 7, 1977. Presentations were made by Mr. George Wirth, Chairman of the Chlorofluorocarbon Work Group, Office of Toxic Substances, and by Dr. Herbert Wiser, Director of the BACER Program. (See Appendix C for list of attendees.) The Study Group held a working session on May 19, 1977, to consider the draft critique and preparation of the final report. This report will include general conments on the overall program plans and then consider in more detail the sections of the document. v ------- TABLE OF CONTENTS Page Preface iv I. INTRODUCTION 1 II. COMMENTARY ON OVERALL PROGRAM 2 III. COMMENTS ON INDIVIDUAL SECTIONS 4 A. Climate Change and Monitoring of UV 4 B. Biological (Non-Human) Research 7 1. Terrestrial Plants 7 2. Aquatic and Terrestrial Animals 10 C. Human Health Effects Research 14 D. Special Instrumentation 18 E. Program Management 19 F. Training 20 IV. APPENDICES A. Letter of November 19, 1976, from Dr. Wilson K. Talley to Dr. Emil Mrak B. Letter of March 4, 1977, from Dr. Gordon H. Orians and Dr. Norton Nelson to Dr. James H. Sterner C. Names of Attendees at the April 6-7, 1977 meeting of the Ad Hoc Study Group D. Reference Materials and Resources vi ------- I. INTRODUCTION Depletion of ozone in the stratosphere is a future and long- range problem. Neither the research nor the commitment to it can be a short range one as it has been up to now. The general nature of the problem has been known since 1971. Since then the uncer- tainties in the physical and chemical parameters have been reduced appreciably, but the uncertainties in the biological ones are still uncomfortably large. We need long-range and up-dated predictions for regulatory purposes. To make good predictions we need not only research over a number of years but a viable basic research effort to identify new parameters for consideration or new procedures to solve old problems and for the early identification of unsuspected new ones. It is important to emphasize that no one group is wise enough to foresee the future uncertainties and possibilities related to ozone depletion. What is needed is continuous surveillance of the problem by knowledgeable photobiologists and climatologists, not only deliberately but indirectly via basic research; for example, four years ago no one would have suspected that visible light would ameliorate the effects of UV radiation on people. Now as a result of experiments of human cells in culture this amelioration is recognized as a good possibility. - 1 - ------- II. COMMENTARY ON OVERALL PROGRAM The Study Group is concerned that the Agency, in the process of program development, may have failed to utilize to the extent desirable the talent and knowledge of photobiologists and other scientists actively working in the field of biological and climate effects research. For example, within the Federal Government, there are competent scientists in the Department of Interior, U.S. Fish and Wildlife Service who are well equipped to conduct or oversee extramural research on non-human biological effects especially related to wild birds, mammals, and aquatic organisms. Yet there is no evidence that they were involved in planning the RACER Program. Furthermore, the Rosters of the Interagency Task Groups consist almost entirely of Government representatives, and consequently failed to include much of the best scientific exper- tise on the subject. Although the Task Groups may have called on outside consultants for advice, it appears to the Study Group that this advice was not adequately followed in laying out the written program. While the Study Group recognizes the potential self- interests inherent in participation in planning by the relatively small comnunity of scientists working in the area of photobiology, such potential self-interest also exists for the Roster members in so far as they represent agencies that use funds for inhouse research. It seems probable that seme individuals could be found who are not likely to be recipients of funds under the program, but who are deeply knowledgeable and whose wisdom of insight would strengthen the program planning. Finally, while the Study Group recognizes the need to include scientist-administrators on the Task Groups so as to assure adequate commitment of their agencies to participation in the program, it also believes that working scientists active in the research area within the agencies would make valuable contributions to the program plan. The Study Group commends the RACER Staff on the design of the research plan for FY 1977 and 1978. There are few, if any, tasks the Study Group believes should be eliminated. The document and briefing provided to the Study Group described the aspirations of EPA, but are insufficient to permit the Study Group to judge the likelihood that the research objectives will be achieved. Several comments are directed to this point: specifically the comments on importance of exposure sources in biological experiments, exposure estimation in epidemiological studies, and exposure estimation in field studies. The Study Group would need approximately an order- of-magnitude more data to evaluate critically the individual objec- tives and to see if these objectives can be accomplished within three years. (Some of the objectives [Section III-C] obviously cannot be accomplished within this time.) - 2 - ------- The Study Group is much concerned that there is so little attention devoted to climatic change--(but recognizes that this work may be included in NQAA's studies). Climatic change may well have the most far-reaching effects of stratospheric change-- some efforts toward predicting changes in biological productivity, attendant upon shifting temperature, are essential. Even small changes in productivity could substantially alter the food supply of the world. In a world already unable to adequately feed itself, lessened productivity could be catastrophic, whereas increased productivity could be an enormous boon. - 3 - ------- III. COMMENTS ON INDIVIDUAL SECTIONS A. Climate Change and Monitoring of UV Attention is called to the Objectives listed on page 4 of the FY 1978 Interagency Budget Request. Objective 1: 'Develop understanding of changes of global mean and variance of climate variables (the statistical description of UV, visible and infrared radiation, temperature, precipitation and winds near the surface of the earth) resulting or related to changes in the stratosphere." Current information is not adequate for statistically relating stratospheric and tropospheric data. There- fore, such correlation does not merit a top-priority goal. Since there is currently no understanding of the mechanism involved, effort in this area would not be productive at the present time. There is little scientific basis for correlating one parameter with 1,2/ another, since in general circulation modeling studies drastically different stratospheric changes appear with amazingly similar tropospheric changes. On the other hand, it is much more important to look for mathe- matical instabilities, if any, which might relate strato- spheric and tropospheric changes. Objective 2: "Develop understanding of changes of regional climate variables (UV and visible radiation intensities, temperature, precipitation and winds) with changes in global- mean changes." Understanding changes in regional climate is important mainly to the extent that the changes can be related to global changes. The relationship of global to regional changes merits emphasis. 1/ Syukuro Manabe and Richard T. Wetherald, "The Effects of Doubling the COo Concentration on the Climate of a General Circulation Model, J. Atmos. Sci. 32: 3-15 (1975). 2/ Richard T. Wetherald and Syukuro Manabe, "The Effects of Changing the Solar Constant on the Climate of a General Circulation Model," J. Atmos. Sci. 32: 2044-2059 (1975). - 4 - ------- Objective 3: "Monitor ultraviolet (principally UF-B) radiation spectroradiometrically with narrow band resolution over a range from 280 to 320 nm in several locations of different latitudes in the world." This objective should have been 290 - 350 nm with a band pass of 5 to 10 ran because a) there is not sufficient energy < 290 nm to make it worth measuring and b) smaller band passes are not needed either for biological experiments, or for reconstructing the sun's spectrum at the earth's surface. Objective 4: "Monitor ultraviolet (principally UV-B) radiation by single observation of erythemally weighted radiation, repeated at half hour intervals during daylight hours, at principal experimental locations. (This includes calibration, instruments, observations, data recording and reduction, analysis and publication of results.)" It is important that this Objective be carried out in locations similar to the one used for Objective 3 and at locations used in epidemiological surveys. Objective 5: "Develop missing elements between the National Stratospheric Research Plan results and BACER." Climate changes due to the chlorofluorocarbons (CFC) may arise either from a direct heating in the troposphere by the greenhouse effect or from an indirect mechanism which relates stratospheric ozone changes with tropospheric CFC concentrations. The impact of CFC's on the earth's climate system must be approached as a global problem but details relating to man's activities and the assessment of consequences must be related to local and regional changes. Combined with any direct effects of CFC's are the related changes in the humidity and hydrological cycle which can aggravate the impact on agriculture such as changes in local precipitation. - 5 - ------- For FY 1978 and beyond it is noted that the climate study- objectives do not include the following, listed in priority. 1. Introduction of the direct effect of chlorofluorocarbons in the available general circulation models of the atmosphere (while these are highly simplified and imperfect models, they are still the best available means of estimating the climatic consequences). Determination of the changes in the hydrological cycle and the regional impact on agriculture; and the feedback and initial effects of oceans, surface albedo, clouds, and aerosols would produce useful information. 2. Development of a statistical model to describe the present global atmosphere and its recent history using available terres- trial and satellite data so that short-term statistical fluctu- ations would be resolved from longer trends. Using the available general circulation models to determine the relative climatic importance of different observed and predicted parameter changes and determining at what latitudes and in what regions climatic impacts are/will be greatest would be of value. 3. Looking for triggering mechanisms (instabilities) relating stratospheric changes with tropospheric climate changes. 4. Determining how global parameter changes can affect regional and local climate. Adopting accelerated programs along the lines of (1) and (2) is necessary. Whereas it is desirable to continue to compute the climatic consequences of changes in the major radiation absorbing atmospheric constituents it would also be highly beneficial to add the lesser effects brought about by the addition of chlorofluorocarbons and airborne particles (aerosols). This scientific information would lend support to regulatory decisions long before any climatic effect is observed. Much of the fundamental data to be used in general circulation models is now in existence and it is only necessary for those who use the advanced circulation models to be encouraged (through funding) to add these minor constituents and to report their results in the open scientific literature where the information can be scrutinized by the scientific community. This probably will not be done without a formal request. - 6 - ------- B. Biological (Non-Human) Research 1. Terrestrial Plants So far as is known, plants do not get cancer, but they probably do get damaged by ultraviolet radiation. In the field the damage may be analogous to sunburn in humans. Thus the objective of the plant sciences section of the BACER program is to find out whether or not plants get "sunburned," and if so, at what rate, and how much greater this rate might be if the national flux of UV radiation were to be increased by a few percent. By analogy with sunburn in humans, where protective mechanisms such as increase in pigments or skin thickness plays an important role, it seems likely that plants will have several defense mechanisms, and that some plants will be more affected than others. Very little is known at present about the mechanisms of either the damage or the defense against it. The public reaction to a slight increase in the rate of "sunburning" of plants is likely to be negligible in comparison with the reactions of an increase in the incidence of cancer in humans, however slight. The economic implications are unknown, because the pathology of the subject is still in its infancy. Until the pathology is much further developed (and this will 3/ take "more than a few years," according to the N.A.S. Committee), it will be difficult to assess the economic impact of a slight increase in the rate of damage by solar UV. As an exploratory program to establish a pathology of UV in plants, the BACER program appears to be well designed. It. . follows closely the suggestions made by the N.A.S. Committee.— In the three years of proposed funding, it is unlikely to develop beyond the exploratory phase, i.e., it should be possible, by the end of that period, to produce a list of typical symptoms (if any) and to suggest some reasons for them. A critical need exists for close collaboration between physicists and engineers who design equipment and biologists who design experiments. The program director should maintain this collaboration at all costs. He should ensure that biological experiments in which control of the physical instru- mentation is not of sufficiently high standard are eliminated from the program. 3/ Halocarbons: Environmental Effects of Chlorofluoromethane Release, Nat. Acad. Sci., Washington, D.C. 1976, p. 15. 4/ Ibid, p. 25. - 7 - ------- In reference to specific objectives on page 5 of the FY 1978 Interagency Budget Request, the following points should be noted. Objective 1: "Determine amounts (dose and dose- rate) of UV-B radiation reaching plant parts (e.g., leaves, meristems, reproductive organs) through plant canopies." The feasibility of doing this with plant canopies is questioned. Objective 2: "Determine the potential for effects of UV-B on soil and leaf bacteria (decomposers and remineralizers) and consequent effects on plants." The Study Group concluded that this objective is unrealistic since UV radiation does not penetrate the surface of the soil. Objective 3: "Determine whole plant response to UV-B radiation by selected agricultural and natural plants (i.e., effects on photo- synthesis, productivity, yield, repro- ductive capacity, nitrogen fixation ability, etc.) as functions of stage of development, dose, dose-rate, and wave length with attention to possible synergisms." The Group concluded that the determination of whole plant responses is important, but it is unrealistic to do this with monochromatic radiation in the time available. The experiments should be done with polychromatic radiation, using solar simulators. Objective 4: "Determine simple predictors at the molecular, cellular and tissue levels (e.g., cuticle thickness, pigmentation and repair capacity, organelle changes, etc.) for whole plant sensitivity so as to allow generalization to other plants not feasibly studied." The development of simple predictors is very important and this experiment is a good one. - 8 - ------- Objective 5: "Determine effects of UV-B on competitive interactions between different plant species and between plant hosts and pathogens/ pests." The Study Group questions that this objective can be attained in three years. Objective 6: "Supplement existing studies on temperature, precipitation, and wind on plants." Objective 7: "Conduct modeling studies of effects on yield of climatic changes (UV-B temperature, precipitation, wind)." Objectives 5, 6, and 7 should receive less emphasis as indicated by the budget figures presented. It is not clear that Objective 7 can be achieved with any reliable predictability. - 9 - ------- 2. Aquatic and Terrestrial Animals a. Effects of Increased UV Due to Stratospheric Modification The effects on natural populations of animals of changes in UV-B radiation due to stratosphere manipulation is uncertain because there are no dose response curves for possible biological effects, no knowledge of how much additional UV-B radiation repair mechanisms can withstand, no way to predict genetic adaptability of organisms, and no good present model of climate effects of stratosphere manipulation or of climate effects on population dynamics. However, substantial damage caused by gradual increase in UV-B radiation seems unlikely because of 1) animal pigments, e.g., melanin, which are very efficient light absorbers, 2) repair mechanisms and 3) potential genetic adaptation. There is a major gap in our knowledge of the capacity for genetic change by popula- tions of animals to accommodate increased UV-B radiation. It seems likely that if there are effects on animals of changes in UV-B or climate, it will be in highly inbred strains of domestic animals and in human populations where there has been little environmentally related genetic selection. The Study Group feels that much of the proposed BACER budget for animal research has much too high a priority. Findings for each BACER proposal objective in "Animals Including Insects" are listed below. Objective 1: "Survey literature for potential detrimental effects of UV-B on animals other than those already identified as susceptible." The literature survey done in the Climatic Impact Assessment Program (CIAP) monographs seems exhaustive already. Another such survey does not seem justified. Objective 2: "Determine the extent of potential losses among farm animals resulting from increased UV-B (cancer eye in herefords, pink eye exacerbation in cattle and sheep, sunburn in swine, etc.)." Implementation of BACER proposals concerning domestic animals is questionable, since exposure problems could be handled in the short-term at least for intensively managed animals by such means as providing shade in the form of covered open shelters or trees. In the longer- term hybridizing breeds with those containing more pig- ment would result not only in more photoprotection, but also in better productivity as well, since much of animal husbandry has not yet taken advantage of hybrid vigor as have plant breeders. - 10 - ------- Objective 3: "Determine the potential effects on birds' eyes (photokeratitis) which may interfere with competi- tive ability and hence survival." How will such experiments be done? The possible effects of photokeratitis in wild birds does not at present seem a likely possibility, since thresholds for rabbits, monkeys, and man as established by Pitts and Tredici, 1971,1/ (1) show a threshold value at 280 nm two orders-of-magnitude higher than the integrated solar energy available during the day at 290-295 nm in midsummer at the latitude of the Canal Zone. Furthermore, since short wave ultraviolet is diffuse, a laterally oriented eye of a bird would usually be inte- grating ultraviolet over only the upper half of the hemis- phere it "sees," thereby reducing the energy incident on the eye to one half that measured by a surface oriented parallel to the ground. Objective 4: "Determine effects of UV-B on physiology and behavior (e.g., development, pollina- tion capacity, pheromone response, navi- gation ability, etc.) of beneficial and non-beneficial insects exposed to solar radiation." It does not seem likely that insects will be affected substantially by increased UV radiation, since they are shielded from it during development. They are heavily pigmented, and with more ultraviolet they might be able to navigate even better. Not only is there no evidence that this is an important effect, but theoretically a 10% change in UV-B is unimportant in insect behavior. The following comments refer to the Objectives listed under Aquatic Organisms on pages 7-8 of the FY 1978 Interagency Budget Request. Objective 1: "Determine the responses to UV-B of the basic food organisms, phytoplankton and zooplankton (i.e., effects on photo- synthesis, productivity, nitrogen fixing ability, survival, etc.) as functions of dose, dose-rate, and wavelength." The Study Group finds this objective to be the most potentially informative of all the proposed animal experiments. 5/ D.C. Pitts and T.J. Tredici, "The Effects of Ultraviolet on the Eye," Am. Int. Hyg. Assoc., J., 32: 235-246 (1971). - 11 - ------- Objective 2: "Determine the effects of UV-B on survival and development of eggs and larvae of commercially important species as functions of dose, dose- rate, and wavelength." Unless solar simulators are also used in carrying out the research specified in Objectives 1 and 2, the objectives will not be achieved. Objective 3: "Determine simple predictors for the responses of phytoplankton, zooplankton, and eggs and larvae of commercially important species to allow generaliza- tion to organisms not feasibly studied." This objective does not appear to be feasible, since genetic responses are unknown. Even if this should be feasible, it would take many years to achieve. Objective 4: 'Determine effects of UV-B on competitive interactions between different phyto- planlcton, zooplankton and larval species with attention to detrimental community structure shifts." This cannot be achieved in two years, if ever. Objective 5: "Determine the potential effects of enhanced UV-B on the capacity of fresh water ecosystems to purify contaminated water." It does not seem likely that UV-B will have a substantial impact here given the capacity for genetic shift in microorganisms. Objective 6: "Incorporate UV-B effects into models of ecosystem interactions, where feasible, to develop a generalized assessment of the impact of climatic change." Since the information needed to achieve Objective 6 will require many years to accumulate, the Study Group finds that this objective merits only a low priority. - 12 - ------- Objective 7: "Determine penetration of narrow wavebands of UV-B into various natural waters with attention to absorption and scattering by biota. Correlate UV-B penetration with existing data on visible light penetration through biota-containing waters to allow generalization to global waters. Does the National Oceanic and Atmospheric Administration know that it is to correlate its data with those data obtained from Objectives One through Six? b. Climate Effects of Stratosphere Modification It is apparent that there is a major research gap in coupling macroclimate-microclimate-animal thermal and mass balances. Such coupling is needed for predictability of climate effects on activity patterns, e.g., timing of pollination and predation timing, and for assessing the effects on food and water requirements for maintenance, growth, and reproduction of key food (chain) animals. It is observed that in the short-term no provisions have been made in BACER to explore mechanisms for reducing exposure of long- lived domestic animals, e.g., shade or shelter or modified breeding programs to introduce more pigment into sensitive breeds. In the long-teim, no evidence is presented that two important areas of research will be explored. These areas include: ... supporting genetic research directed toward predicting rates of phenotypic change in wild populations of animals. ... supporting research into climate effects on animal thermal and mass balances that would affect activity patterns and food and water requirements, thereby affecting population dynamics and community ecology. - 13 - ------- C. Human Health Effects Research The acquisition of critical data about health effects is a major function of a program designed to document regulatory action. It must be understood, however, that the state of the science is such that most of the objectives in the health effects area cannot be attained in a period of two years. It is anticipated that important research efforts will be started and yield seme significant information in that period; new methods and instrumentation may be designed and tested but one cannot anticipate major solutions to be forthcoming in the currently allotted time. This is particularly true in the most critical areas-- for example, the study of health effects in defined populations through prospective epidemiological studies. If these are properly designed they will require up to 10 years to yield this desired information, but they must be started now. The objectives as they are now stated may, only with careful interpretations and explanations, cover the important gaps in know- ledge and research. Such interpretations and indicated directions would make than acceptable. Epidemiologic studies (see pages 15 and 16), it is agreed, should receive the highest priority. It must be understood, however, that two types (referred to in Objectives 1 and 2) are needed: 1) retrospective studies for which data from the already existing sources may be both incomplete and of limited accuracy, 2) prospective studies which may provide a rich yield of good infoimation if the protocols are properly designed and carried out. These efforts require not only skill of epidemiologists but require the expertise of clinical investigators with knowledge and experience in the field of human organ system reactions to UV-B in a variety of settings. This knowledge includes genetic, cultural, and environmental factors that influence UVR action on skin and an understanding of the cutaneous and ocular patterns of reactions. Scholars of cutaneous and ophthalmologic biology are the types of investigators needed here. In the epidemiologic and clinical study programs, the assessment of frequency and severity of neoplastic reactions such as epidermal cancer, actinic precancerous changes as well as melanoma should be underscored. Consider- able emphasis should be given to the non-neoplastic reactions as described under Objective 3. - 14 - ------- The following comments relate to specific objectives. Objective 1: "Obtain improved epidemiological data to enable a more precise estimate of the potential increase in melanoma and non-melanoma skin cancer resulting from ozone reduction/increased UV-B." o The present experimental design utilizes only two southern cities. Neither of these cities is included in the non-melanoma data of the Third National Cancer Survey (TNCS). Hence, most of the epidemiological data to be collected will be from regions of lower ultraviolet flux and lower cancer incidence. It is doubtful whether the data will give appropriate infor- mation for improving the calculation on the change in skin cancer with ultraviolet radiation nor will it give information about the increase in incidence as a function of time. o No data will be obtained from areas within the State of Texas. TNCS obtained data from Dallas and a survey from the M. D. Anderson Hospital obtained data from many other localities within the State. Thus, there has been a good beginning in Texas but the beginning is not followed up. o There has been no provision for using dosimeters on people. Hence, there will be no clear-cut way of estimating how much, if any, of the latitude depen- dence of skin cancer is a result of ultraviolet levels and how much is a result of life style para- meters. Unless such data are obtained we are no better off than using the data obtained in CIAP. 0 There is no provision for measuring the spectral irradiances in the cities used in the survey, although there is provision for making measure- ments with the Robertson-Berger meters. However, these meters do not necessarily measure the proper spectral distribution and it would be futile to do extensive epidemiological work without an equiva- lent amount of effort going into the spectral properties of sunlight in the areas studied. - 15 - ------- 0 All of the epidemiological surveying and analysis does not have to be done by the National Cancer Institute. EPA should be able to grant monies to non-federal academic units for this purpose with- out going through the National Cancer Institute (NCI). In the past, surveys other than NCI's within the United States and elsewhere have supplied information that has been of great use in analyzing both melanoma and non-melanoma problems. Objective 2: "For the identification of the most susceptible subpopulation, determine from follow-up studies the influence of other factors on skin cancer induction (e.g., life style, occu- pation, skin type [complexion and/or experimentally determined erythema response] ethnicity, etc.). Also, determine the extent of recurrence and subsequent cases, cause of death (more susceptible to other types of cancer? less susceptible?) etc." Refer to page 14 for comment on this objective. Objective 3: "Examine the potential impact of increased UV-B on aspects of human health other than skin cancer, especially eyes." It is not clear whether these analyses will be on new data or on existing data. If on new data, how will the data be obtained? If on existing data, what are they? Such studies require inclusion of a thorough evaluation of non-neoplastic reactions such as photosensitivity reactions of the skin and eye including phototoxic as well as photoallergic reactions. These are now common- place reactions to one or more chemical agents found in occupational exposures, in drugs, cosmetics, toilet goods, household materials, foods, etc. Some of these have action spectra in UV-B and/or UV-A ranges. Such studies may also provide a model for detecting human effects using UVR exposure of short duration. - 16 - ------- In the epidemiological and clinical study programs, determination of the changes in frequency and severity of non-neoplastic reactions associated with moderate and long-term exposure and/or genetic considerations is essential. These include premature aging, pigment damage, solar elastosis and degeneration, actinic cheilitis, poikiloderma, skin wrinkling, scarring, and atrophy. To this list of nonneoplastic reactions which require assessment are the disease states that increase vulnerability to UV-B and/or UV-A: solar urticaria, polymorphous light eruption, lupus erythe- matosus, poikiloderma of Civatte, the genetically determined problem associated with faulty DNA repair-- xeroderma pigmentosum--and many others. Objective 4: "Obtain information at the molecular, cellular and tissue levels, regarding the mechanisms of induction of skin cancer, skin damage (aging) and eye damage by solar UV, as functions of dose, dose rate, and wavelength, with attention to synergisms with other factors (wavelength, temperature) The thrust of research about mechanisms of UV-B damage on cells and tissues is covered in Objective 4. It is urgent that the synergistic or enhancing influence of chemical agents be carefully examined in man. The common source of agents listed above are important since new materials with potential for photochemical injury are introduced with some frequency. A more important reason for studying combined chemical-UVR effects in man and experimental animals is the energy crisis that will result in the more extensive use of fossil fuels: coal, shale oil products, liquid and gaseous fuels frcm coal that may involve effluences containing polynucleararomatic compounds (PNA's) and other photosensitizing compounds. Many PNA's have phototoxic properties. Finally, in order to provide critical information regarding dose-response relationships through epidemiological studies, it will be necessary to design and develop a simple and inexpensive UV-B/ UV-A exposure badge (Section III D, Special Instru- mentation) . - 17 - ------- D. Special Instrumentation Since it is technically very difficult to simulate a small increase in the natural flux of UV radiation, it is essential to have close collaboration between the engineers and physicists who design the equip- ment and the biologists who design the experiments. The absence of this close collaboration in the past has led to a great deal of poor quality research in this field. The fact that such collaboration is built into the BACER program augurs well for the scientific quality of the expected results. The program director should maintain this collaboration at all costs. He should ensure that biological experiments in which control of the physical instrumentation is not of sufficiently high standard are eliminated from the program. A vigorous program of development of new instruments and standards should be maintained throughout the program. There is a great need for adequate solar simulators for both laboratory and field experiments. There is also a strong need for the design and development of simple and inexpensive UV-A/UV-B badge type dosimeters that can be used to determine the effects of differences in the actual exposure conditions for human subjects. - 18 - ------- E. Program Management The elements of Program Management seem appropriate to the proposed broad frame of the FY 1978 BACER plan. It is assumed that this will be revised in accordance with the scope of the program that is adopted. - 19 - ------- F. Training Although the Study Group has been informed that the training aspect of BACER is unacceptable for funding, the Group wishes to make two points. Organizing workshops to be held in association (coincident or contiguous) with several national scientific meet- ings could be most rewarding. The use of research grants rather than traineeships to train new investigators will work only to the extent universities participate in research carried out in BACER. - 20 - ------- APPENDIX A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. O C 20460 NOV 1$ 19/6 OFFICE OF RESEARCH ANO DEVELOPMENT Dr. Emil M. Mrak Chancellor Emeritus University House University of California Davis, California 95616 Dear Emil: As you may recall, there was a brief discussion, during the October 14 meeting of the SAB Executive Committee, of planned research into the effects caused by a reduction in stratospheric ozone. EPA has been assigned the role of lead Agency for the short-term (through Fiscal Year 1977) Federal interagency research program on the biological and climatic effects of stratospheric ozone reduction. This program, which is being funded at $4 million during Fiscal Year 1977, is based on multi-year plans developed by ad hoc interagency Technical Task Groups. Transmitted with this letter for your review are these long-term plans, along with the detailed set of objectives which we have identified as being most critical and hence studies selected for funding under the short-term program. I would like to request that the Science Advisory Board critique this material in wo contexts, as follows: • First, we need to know as soon as possible whether major errors of omission or commission can be seen in the short-term program, whose tasks have been selected primarily to reduce ranges of uncertainties or to identify potential problem areas where knowledge presently is virtually non-existent. • Second, assuming approval of the long-term program, we need a more measured assessment of its adequacy to provide the information required of regulatory decision-makers, the lack of which currently makes it difficult to meaningfully forecast the impacts of stratospheric ozone depletion. Dr. Herbert L. Wiser, Principal Physical Science Advisor in my office, will be the source of any information which you may need to conduct this review. Sincerely ey Assi _ rator for Research and Development ------- APPENDIX B UNITED STATES ENVIRONMENTAL PROTECTION AGENCY %PRa^ WASHINGTON, D C 20460 March 4, 1977 OFFICE OF THE ADMINISTRATOR Dr. James H. Sterner Chairman Ad Hoc Study Group on Effects of Stratospheric Modification College of Medicine University of California, Irvine Irvine, California 92717 Dear Dr. Sterner: The Environmental Protection Agency has been assigned the role of lead agency for the short-terni (Fiscal Year 1977) Federal interagency research program on the biological and climate effects of stratospheric ozone reduction. This program, which is being funded at $4 million during Fiscal Year 1977, is based on multi-year plans developed by ad hoc interagency Technical Task Groups. In response to an Agency request for Science Advisory Board review, the Executive Committee at its January 4-5, 1977, meeting assigned the critique of the document, Biological and Climate Effects Research (BACER)--Effects of Stratospheric Modification jointly to the Ecology Advisory Committee and the Environmental Health Advisory Committee. This document includes long-term plans and the set of objectives that have been identified as being most critical, and hence studies selected for funding under the short-term program. It is requested that the Ad Hoc Study Group critique this material in two contexts, as follows: First, whether major errors of omission or commission can be seen in the short-term program, whose tasks have been selected primarily to reduce ranges of uncertainties or to identify potential problem areas where knowledge presently is virtually non-existent. ------- Second, assuming approval of the long-term program, a more measured assessment of its adequacy to provide the information required of regulatory decision-makers, the lack of which currently makes it difficult to meaning- fully forecast the impacts of stratospheric ozone depletion, is needed. The M Hoc Group's report will be presented to the Ecology Advisory Conmittee and to the Environmental Health Advisory Committee for appropriate actions. In view of the involvement of these Committees it is urged that the Ad Hoc Study Group complete its report by May 20, 1977, to assure a timely response to the Agency's request. Sincerely Gordon H. Orians Chairman Ecology Advisory Committee NOx cuii ncisuit Chairman Environmental Health Advisory Committee ------- APPENDIX C ECOLOGY ADVISORY COMMITTEE--ENVIRONMENTAL HEALTH ADVISORY COMMITTEE AD HOC STUDY GROUP ON BIOLOGICAL AND CLIMATE EFFECTS RESEARCH (BACER)-- EFFECTS OF STRATOSPHERIC MODIFICATION Attendees April 6-7, 1977 Meeting BACER STAFF Dr. E. C. DeFabo Dr. James R. Hibbs Mr. Charles Plost Dr. Louis J. Schoen Mr. Neal J. Whitney Dr. Herbert Wiser OFFICE OF TOXIC SUBSTANCES Mr. George F. Wirth SCIENCE ADVISORY BOARD STAFF Dr. J Frances Allen Mrs. Beth Bemis Dr. Joel Fisher Dr. Alphonse Forziati Mrs. Ilene Stein ------- EP1.2 BACER US EPA A Report Critique Of The Biologi- cal And Climate Effects Research (Bacer) Effects, Of Stratospheric Modification EP1. 2 BACER LIBRARY U 3 lavtomoMalal Pretention Agaoef Corvatlis Environmental Reseafch Lab 200 S W 35th Street ------- APPENDIX D Reference Materials and Resources 1. Department of Health, Education and Welfare, Food and Drug Administration; Environmental Protection Agency; Consumer Product Safety Commission. Fully Halogenated Chlorofluro- alkanes. Proposed Prohibitions and Nature of CPSC Action. Federal Register, Vol. 42, No. 93, May 13, 1977. 2. FY 76-77 (Financial) Commitments--RACER Program. 3. H.R. 783. January 4, 1977. A Bill to authorize and direct establishment of a coordinated National program relating to climate and for other purposes. 4. Interagency Task Force on Inadvertent Modification of the Stratosphere Other than Flurocarbons. Report, March 1976. Potential Modifiers of the Stratosphere Other than Fluro- carbons . 5. National Academy of Sciences Report, 1976. Halocarbons: Effects on Stratospheric Ozone. 6. National Academy of Sciences, 1976. Halocarbons: Environmental Effects of Chlorofluromethane Release. 7. National Academy of Sciences Report, September 1976. Ozone and Other Photochemical Oxidants. 8. Biometry and Epidemiology Contract Review Committee, National Cancer Institute (extramural reviewers for NCI research on BACER). 9. Biological and Climate Effects Research--Policy Group Roster. 10. Biological and Climate Effects Research--Technical Task Group Roster. ------- |