Regulatory Agency Functions

When contemplating work-related or domestic environmental guidelines, many turn to regulatory agencies for guidance. There is an inherent flaw with this process.

Regulatory agencies, whether local, state, or federal have a variety of responsibilities.

1) One of them is to prevent immediate and obvious dangers from occurring. An example is regulation preventing irresponsible handling of chemical such as Chlorine, to preclude an immediate health hazard to the user, and the immediately neighboring public. Another example is guidance in working with voltages that can produce shock, and death on contact.

2) One is to provide guidelines for chemical or other exposures that will prevent evident localized or systemic damage within a prescribed amount of time. This is mainly a period of short duration such as a few hours or days.

3) Another responsibility is to provide guidelines for exposures that will or may produce illnesses over a long period of time.

4) The last and most important is to keep the peace, preventing the public from becoming alarmed en masse, with unpredictable consequences.

The latter two responsibilities have an inherent conflict.

When considering biological interaction with chemistry and other exposures, long-term effects can take 20+ years to manifest themselves. This presents a dilemma. Since immediate impact cannot be detected, it becomes problematic to identify the consequences of any specific low-level exposure. Epidemiological studies, which are time-based long-term studies, can help in this determination, unfortunately however, only after the fact.

When considering environmental conditions that are already compromised with chemical and other factors, regulating agency guidelines that indicate the need to reduce levels significantly will tend to incite public discomfort, court actions, and industry attacks on agency action. That being the case, the agencies are constrained into simply accepting the situation as is (or possibly only nibbling at problems), issuing no guidelines or providing ones that simply reinforce the placebo that everything is fine, if we simply do not make the situation worse.

-------------------------------------------------------

Experiential identifications based on sound scientific methods have been made of certain environmental factors, and the levels at which they will produce biological impact codified. These levels are generally several magnitudes smaller than regulating agency guidelines. These levels will not acquire sanction by regulating agency or industrial interest, simply because they could produce panic, and unpredictable consequences.

The idea that some technical systems have been put in place before there was sufficient knowledge to determine that they were safe, does not justify the continued replication of their established engineering and their grandfathering into a "safe" status.

However, it also does not justify the public having free and unrestricted ability to prosecute the myriad of industries involved.

Since evidence is available, it makes sense for the public, industry, and regulating agencies, to come to agreements regarding low level biological interaction mechanisms, and make an effort to reduce "established" environmental aggressors on an ongoing basis, without disrupting life and business cycles, instead of promoting legal pursuits that make lawyers the only winners.

However, this author is not so naive as to think that a selfless attitude will prevail when legions of alligators are searching for the me-mine pot of gold because they perceive a wrong done to them by others. So problems will keep on being unwittingly built into structures by individuals looking for a least expense, and people like me will keep on getting paid to educate the "victim" and identify the problem.


The Moral Right

-------------------------------------------

contact the author

-------------------------------------------

© 2007
Environmental Assay Inc. / Sal La Duca


Sal La Duca
Building Biologist
BS, BBEC/BBEI, CIEC
FCC Licensed

792 Green St.
Phillipsburg NJ 08865 USA
908-454-3965

Services and Resources