From: Roger McClellan <roger.o.mcclellan**At_Symbol_Here**ATT.NET>
Subject: Fw: [DCHAS-L] [DCHAS-L] ACS Policy Statement on Safety in the Chemistry Enterprise- INCOMPLETE
Date: Mon, 16 Jan 2017 18:49:53 +0000
Reply-To: Roger McClellan <roger.o.mcclellan**At_Symbol_Here**ATT.NET>
Message-ID: 1707710456.4333367.1484592593910**At_Symbol_Here**

Re:Risk, Safety, Hazard and Exposure

To all:
I have followed with interest the recent exchange concerning EPA s recent actions effectively banning several chemicals. A number off participants in the discussion have noted confusion over some of the basic concepts and definitions involved. Many of these exchanges have noted the need to educate the public on these matters.

I applaud Ralph Stuart for his efforts on these matters and appreciate his distributing an advance copy of the ACS Public Policy Statement - "Safety in the Chemistry Enterprise". I appreciate that the statement is well-intentioned and obviously needed. However, with all due respect, I do not think the Statement is ready for release either as a "Public Policy Statement" or as a Statement to Guide the Actions of ACS Members and other scientists. The major problem with the statement is that it is incomplete and , as such, introduces more confusion rather than enlightenment. The Statement fails fails to clearly define risk, safety, hazard and exposure, these concepts are at the core of any discussion of these matters.

Let me indicate at the beginning of this communication that we are dealing with some very complex matters. To communicate on these matters we need clarity of language and definitions. I have been involved in these issues for decades. I grew up near the Hanford Nuclear complex and was introduced to the concepts of risk, safety, hazard and exposure as a youngster. These concepts were central to my career as a scientist at the Hanford Laboratories, later at the Atomic Energy Commission and with the Lovelace organization and as President of the Chemical Industry Institute of Toxicology and , more recently, as an independent advisor. Starting in the 1960s I began serving on advisory committees dealing with these matters including chairing the National Research Council Committee on Toxicology. In 1990 I was elected to what is now the National Academy of Medicine of the National Academies. Through my career I have observed and participated in many vigorous debate over the issue!
s of risk, safety, hazard and exposure for a wide range of issues including radiation, chemicals , and biological agents and a range of other factors with a host of different outcomes from cancer, functional impairments of health to climate change. I have heard Nobel Laureates shout at each other as to whether hazards are different than risks. I am a charter member of the Society for Risk Analysis and have just reread a charge they offered to a committee to help define these and related terms. I was over-whelmed by the language, it reminded me of the exchange in Lewis Carroll's classic book, "Through the Looking Glass".

Humpty Dumpty said -" When I use a word it means just what I choose it to mean - neither more or less". Alice responded, "The question is whether you can make words mean so many different things.". Humpty Dumpty responded -"The question is which is to be master - that's all"

In my opinion, the scientific community is a major part of the problem. By and large, it exists as a collection of silos - chemists, physicists, Medical Doctors, Veterinarians, chemical engineers, etc. We struggle within the individual disciplines to communicate with one another. Communication among individuals from different disciplines is even more challenging and is often quite rare,. For example, did any one involved in writing the ACS Statement on "Safety in the Chemical Enterprise engage in dialogue with SRA members or with individuals on the numerous National Academy committees that have advised EPA , FDA and other agencies on matters of risk, safety, hazard and exposure. The contents of the ACS statement suggest an absence of such dialogue.

Without a clear understanding of the profound differences in definitions for risk , safety, hazard and exposure within the ACS and within other scientific and engineering communities It is not possible to engage in communications with other communities that make up the public. The scientific community needs to get its act together!

In my opinion, a part of the problem with communication on issues of risk, safety, hazard and exposure is that the issues are at the interface between science, politics, governance, academe, industry and the economy of which we are all a part. Moreover, these are not just issues of science, they involve ideologies and personal preferences. Indeed, it is my opinion that decisions on these issues are not hampered by lack of scientific knowledge but differences in personal ideology and preferences.

I will submit that I think some scientists place undue weight on describing in short hand the hazardous properties of agents, including specific chemicals They frequently hold the view this is the end of the story. Some of these individuals hold the view that if an agent can be added to a list of agents that are carcinogenic to humans, have potential for producing endocrine effects, etc, the agent should be banned from commerce. I have a different view point, I think the challenge is to move beyond banning the agent to defining the conditions under which the agent can be safely used . I am quite comfortable knowing my body is full of very active chemicals including low levels of formaldehyde . Thankfully, that is the case -- I am still alive. I think the creation of lists of chemicals, such as the International Agency for Research on Cancer does for chemicals evaluated as to their carcinogenic hazard is an important step. However, the challenge for scientist and engine!
ers working with other parts of the public to define the conditions of use that will limit exposure and ,thus, risk to acceptable levels. Let me quickly add that acceptable risk is a policy judgement informed by both science and public input.

I appreciate the opportunity to use this forum to express my views. I do urge the ASC to retract and revise the Policy Statement on :" If you truly think the current version of :Safety in the Chemical Enterprise"is satisfactory try it out on your significant others, your parents and your neighbors and see if they find it informative. I am pleased with the use of the word hazard in paragraph 4. However, the words risk, safety, hazard and exposure need to be defined in paragraph 2.

I encourage further debate and dialogue on these matters which are of importance to us as professionals and, most of all, to Society at large.

Roger O. McClellan, DVM, MMS, DSc(Honorary)
Diplomate - ABT and ABVT
Member- National Academy of Medicine .
Editor- Critical Reviews in Toxicology
Independent Advisor - Toxicology and Risk Analysis
Albuquerque, NM

--- On Sat, 1/14/17, Secretary, ACS Division of Chemical Health and Safety wrote:

> From: Secretary, ACS Division of Chemical Health and Safety
> Subject: [DCHAS-L] ACS Policy Statement on Safety in the Chemistry Enterprise
> To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
> Date: Saturday, January 14, 2017, 7:26 AM
> On a topic related to the
> conversation about the challenges of chemical safety policy,
> in December, the ACS Board of Directors approved an ACS
> policy statement on "Safety in the Chemistry Enterprise". It
> is not yet on the ACS web site, but can be found on the
> DCHAS web site at
> The statement is the product of a collaboration between the
> ACS Committee on Chemical Safety and Division of Chemical
> Health and Safety, assisted by the ACS Office of Public
> Affairs and Public Policy.
> - Ralph
> Ralph Stuart
> secretary**At_Symbol_Here**
> Secretary
> Division of Chemical Health and Safety
> American Chemical Society
> ---
> This e-mail is from DCHAS-L, the e-mail list of the ACS
> Division of Chemical Health and Safety.
> For more information about the list, contact the Divisional
> secretary at secretary**At_Symbol_Here**

This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**

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