Rain Causes Cancer!

… But Only In California

Even rain water cannot meet California’s proposed limits on hexavalent chromium ( aka chromium-6, Cr(VI), “Erin Brockovich Chemical” ).   The .06 ppb ( part per billion ) limit is more stringent that the .08 ppb actually present in rainwater.  ( See Kieber et al, Environ. Sci. Technol., 2002, 36 (24), pp 5321–5327 )  In fact, certain areas have rainwater which greatly exceed the the proposed standard, with 10 to 30 times higher concentrations.

Let the Enviro-Scare Begin

In the shadow of California’s announcement, various environmental groups and the Water Purification Industrial Complex have jumped on the bandwagon.   The EWG’s report makes it sounds as if most municipal water supplies are unsafe, cause cancer, and so on.   They disclose their bias with the cover of the report:

From this pipe, to your baby's sippy cup.

And on the landing page for their chromium web site:

"You may already be dead!"

But read the report.    With the exception of Norman, OK the highest levels detected were within 10 times the amount found in rain water.   So if this is such a ghastly toxin, its practically everywhere in comparable amounts.   If its in the rain, its in your vegetable garden.

Thats not your fathers rainwater

So you could argue that rainwater is much more contaminated now because of man’s industrial revolution, the dark satanic mills, and so on.   The inconvenient truth is that chromium in levels in precipitation today are only about 2-3 times that in pre-industrial times – which is to say very low.   This means that plants and animals and even humans have been exposed to hexavalent chromium in trace amounts – forever.

Are we clear?

It is likely that, as in many biological system, we have a capacity to clear chromium from systems, or at least accomodate it.   Individual cells and the organism as a whole have natural ability to remediate small quantities of toxic metals.   This is where the science is lacking.   We know that 10000 ppb is very bad.   We have to assume .03 ppb,  the pre-indistrial exposure from rain water, must be OK.  ( Barbante, et al, Environ. Sci. Technol., 2004, 38 (15), pp 4085–4090 )   What we don’t know is what happens in between.    There is also some research from chrome platers and welders which suggests individuals vary greatly with respect to their ability to tolerate exposure.   This furthering the idea that we have a capacity to deal with the metal in minute amounts.   Determining this tipping point is necessary, when does the exposure go from inconvenient to deadly.   It begs the question, how does California know .06 ppb is the right value?

Oh, you think I'm ugly? Have you seen my wife?

Its Bad, but Compared To What?

Chromium in bad stuff, certainly in high concentrations ( 10,000 times the California limit ), more so if you are an embryo.   It causes cancer, it screws with the normal operation of DNA, it destroys DNA.   But even in the Hinkley California, the source of Brockovich’s famous case, the connection is not as clear cut.    The total number of cancers occuring over the long term were, in fact, about average.   So its possible that the touchstone case in support of Cr(VI) fears is, at best, requiring some explanations.

The number of new cancer cases observed in the census tract encompassing Hinkley does not differ significantly from the number expected when considering the age, sex, race/ethnicity, and population size of the census tract. Similar null findings were made for colorectal cancer, breast cancer, nasopharyngeal carcinoma, lung cancer, lymph node cancer and prostate cancer, with no significant excess in the number of new cancer cases identified for the 1988-1993 time-period.   -  Desert Sierra Cancer Surveillance Program Report

Its a very curious toxin that causes cancer and disease only when a lawsuit is pending.   Real carcinogens don’t work that way.   Their effects do not dry up after exposure stops.   What appears to have happened in Hinkley is remarkable, to say the least.   Its likely is that many people were compensated in a case where there were very few victims, and that Hinkley was a case of good ( or bad? ) lawyering, rather than good science.  So while it is easy to judge chromium exposure by a blockbuster movie, its not wise.

Everything Causes Cancer

California’s own assessment is based on a multitude of studies, many with ridiculously high exposure scenarios.  In one study, rats were fed an incredible 50 mg of chromium / day. For a human being that would be approximately 5 grams of chromium / day.   To give you a sense for how rediculous this is, you would need to drink 400,000 liters of water a day from Norman Oklahoma’s “tainted” water supply to reach these levels.    Or one olympic swiming pool per day if you lived anywhere else There were some tests where the doses were significant higher.   Certainly it is not possible to dispute the studies, but it should give pause to anyone drawing conclusions from them.

Delicious, but deadly!

Its another example of “everything causes cancer when you eat enough of it.”   Remember that Black pepper causes cancer. Turns out that the human equivalent was like feeding a human 12 cups, yes measuring cups, of ground pepper per day.   I’m getting cancer just thinking about it!   Oh, you like orange juice?   Bad new, d-limonene which is the characteristic oil of citrus fruit, causes cancer.   Given a large enough sample of people, say millions or billions, one of them will get cancer from even the smallest doses of almost anything we willingly subject ourselves to.

Its worth noting that Prop 65 includes all manner of “toxins.”    Marijuana smoke, for example, is a Prop 65 toxin which the state encourages people to consume.   Wood dust.   Super Glue.   Shale oil.   Saccharin, which carried a warning for decades, was delisted.   Safrole, a component of the essential oil of sasafras.

Efficacy, Who Needs Efficacy

Its certainly possible that one out of 10,000 or even one out of 100 cancers is caused by chromium.   But in the grand scheme of thing, its easier to make 1% or .01% of smokers stop smoking to gain the same effect, by taxing them, which costs us nothing.

Even with the compelling movie, or despite it, the issue is that the science has not yet addressed the threshold for toxicity.  Obviously zero would be better than non-zero.  But what is the cost?   Could that money better go to keeping more people from smoking.  A dead by cancer is a death by cancer.   And saying “zero” is the limit is a substitute for doing the research and making a policy decision based on actual risks.

Alligators In The Sewers!

So what is a better test?   The best test I can think of is measuring excreted chromium.   That is to say, instead of testing the input, test the output.   Collect urine from residents in these areas and compare the excreted chromium levels with the chromium levels in the water supply.   This is the only way to determine if we are fixing the right problem.   Chromium is bad, but we have assumed it gets into us from drinking the water.   Its bad science not to look at, uh, the other end to determine where the chromium is going.

In this way we will know if drinking water is the primary factor in our total chromium exposure, or simply a factor, or an insignificant factor.   Don’t we want, both from a health standpoint, and from an economic standpoint, spend money to fix the actual problem?

We're from the government, and we are here to help... ourselves to your wallet.

Public Policy Driven By Fear

As stated above, we know where some of the chromium is coming from: our taps.   And suppose we buy into it being a terrible toxin at any concentration.  What we do not know is where it is going. If, and only if, there is a causal connection established between chromium in tap water and our total exposure, should we be spending any money on this.   That EPA has jumped on the policy-by-fear bandwagon is, sadly, something I;ve come to expect.   But it also means that any rational way forward will be lost, as once EPA makes its grandiose proclamation of global doom, with great speed and effectiveness we are regulated into the poor house.

Winners and Losers

Obviously the losers are “us” and “us.”   If the Cr(VI) problem is a real rather than imagined problem, we have all been screwed by it for decades.   If not, then we have to think about the people who would benefit from the fear.   Obviously water purifier companies, which manufacture reverse osmosis systems – the only real way to remove the chromium.   These units are expensive, and have a consumable filter which needs to be replaced.   In addition, the RO filter needs to be protected from particulates and hard water, so you’ll end up with a water softener most likely, which itself leads to hundreds of dollars in consumables a year, forever.

If you have a municipal water source, just think of a “big” version of the above.   There are some bio-remediation techniques in which bacteria / plants take up the heavy metals to reduce the levels below that deemed unsafe.   But with the levels being so low, even the techniques are ineffective.   So again, this leads to reverse osmosis systems being installed.  Curious.  Its almost as if every road leads to reverse osmosis systems being installed.   How did we manage to make it through the last century without them?

See, its that simple!

I wonder who makes and sells them?   Follow the money…. right back to the very people advancing the policies?   Perhaps.   That’s an untested hypothesis.

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