Arsenic: Science Regulation and Public Policy Lecture at Harvard School of Public Health pm, Friday May 4th 2001 by Richard Wilson Mallinckrodt Research Professor of Physics Harvard University

ARSENIC Metal Molecular weight Melting Point C Specific Gravity 5.73 Many compounds and minerals

Arsenic has been used for over 3000 years As 2 O 3 ARSENLITE by roasting As 2 S or FeAsS As 2 S 3 ORPIMENT PbHAsO 4 SHULTENITE KH(ASO 2 ) 2 Fowler’s Solution CH 3 AsO(ON 2 ) 2 CH 3 AsO(OH)ONa Pesticides with various names

Non-Ferrous Smelters Coal Burning Cotton Gins Cigarette smoke Common Sources

Early Information (pre 1986) Acutely Toxic to Rodents and People Used as Medicine Fowler’s solution 1% in alcohol Cure for Syphilis (recent) cure for leukemia

Early Information (pre 1986) contd Skin lesions and Cancers 1897 Lung cancer from pesticides 1920s lung cancer from smelters 1950s angiosarcoma from pesticides BUT no cancers in rodents

Early Misconception (pre 1986) Rodents dont get cancer, therefore people wont Inhalation a special case with non-linearity (but Zeise and I contested that)

Preliminary warning TSENG et al found skin Tumors in TAIWAN BUT They appeared to follow a threshold relationship.

THE GREAT SURPRIZE In 1986 C J Chen And collaborators reported internal cancers in the same area of Taiwan IGNORED FOR 5 YEARS! Why? Only a Chinese study (as bad as the Russians?) 1990 Allan Smith 1991 Byrd,Lamm Wilson took him seriously

THE GREAT SURPRIZE The internal cancers seemed to be linear with dose and the risk is huge. BUT: An ecological study and Only in one location and there might be another cause

THE VINDICATION CHILE ARGENTINE INNER MONGOLIA BANGLADESH WEST BENGAL NO PREVIOUS STUDY INCONSISTENT

LOW DOSE LINARITY the regulatory default Crump Guess and Peto of 1975

CRITICAL ISSUES FOR LINEARITY The POLLUTANT ACTS in the same way as WHATEVER ELSE INFLUENCES THE CANCER RATE CANCERS CAUSED BY THE POLLUTANT ARE INDISTINGUISHABLE FROM OTHER CANCERS

e.g ARSENIC THE ARGUMENTS APPLY TO ANY CARCINOGEN

Arsenic risk Skin lesions may be unique There may be a threshold at ppb (Data from Taiwan and also from Inner Mongolia) BUT Internal cancers may be different

Is there a Threshold? For a common cancer (lung cancer) a threshold is hard to prove because at 50 ppb a 1% risk is in the background For a common cancer the Peto argument applies

Toxicologists like Thresholds Few (if any) toxicologists address the Peto argument. ?? Threshold for bladder cancer and not for lung cancer?? ED01 data on 2 DAA linear for liver threshold for bladder anticarcarcinogen for others WHY IS THERE SO MUCH CANCER IF EVERYTHING HAS A THRESHOLD?

Many Legislators still want < 1 in a million! Where does this leave regulation of arsenic? Limits should be 5 ppt! (not practical)

Arsenic risk For internal cancers At 500 ppb Measured Risk (Chile) is 10% If linear, risk is one in a million at 5 parts per trillion!! “background” is about 2 parts per billion

NOTHING SAID ABOVE SAYS THAT THE MEDICAL OUTCOME IS CANCER it applies to all chronic effects Reduction in lung function caused by air pollution

Many Legislators still want < 1 in a million! (pessimistically calculated using LNT) Should arsenic be treated differently from Trichloroethylene (TCE) (or vice versa)? WHY?

MY CONCLUSION (REPEAT OF 20 YEARS AGO) IT IS NOT POSSIBLE TO REGULATE A ONE IN A MILLION LIFETIME RISK CONSISTENTLY ATTEMPTS TO DO SO ARE ARBITRARY and CAPRICIOUS

How should we dispose of ARSENIC? 1970 Spray 40,000 tons a year on our crops and forget it! WHY NOT TREAT IT LIKE LONG LIVED HIGH LEVEL NUCLEAR WASTE? Equally likely for LNT to apply MUCH more ARSENIC than nuclear waste (Cohen 1977 Revs. Mod Phys)

How should we dispose of ARSENIC? (contd) EPA says that Arsenic need not be put in a secure landfill. BUT If the proposed EPA regulations for Yucca Mountain are applied No water system in USA and not much agricultural land would be in compliance.

Unreasonable consistency is the hobgoblin of small minds (Emerson) BUT Regulators have a duty (rarely performed) to explain each inconsistency This duty is even bigger for the National Academy of Sciences

Can One Prove a threshold? MAYBE if one focusses on the right question: Similarity to Asbestos Benzene

Can One Prove a threshold? (2) MEREWEATHER”S QUESTION (1937) Is it ASBESTOS or is it the ASBESTOSIS that is caused by asbestos that causes the lung cancers? If the former LNT is likely If the latter LNT is less likely

Can One Prove a threshold? (3) There semes to be a threshold for SKIN LESIONS (should be studied further) Are lung cancers more or less likely if there are skin lesions? (Allan Smith may tell us)

Can One Prove a threshold? (4) Are the lung cancers really indistinguishable from background cancers? If NOT Peto’s argument does not apply Try DNA matching on lung tumor samples. Similarly for asbestos cancers, radiation leukemias etc.