What raised my concern was the campaign’s central emphasis this year: “The day will focus on the impacts of mercury on the unborn …,” said an email. Then, at EEN’s website, the page on “Mercury & the Unborn” claimed, “Approximately one in every six babies in the U.S. are born with harmful mercury levels in their blood.” Finally, a fact sheet on “Mercury and the Unborn Child” claimed, “The main source of mercury pollution is dirty air released by coal-burning power plants.”
Those three things raised my suspicions and set me about obeying Scripture’s command to “test all things, hold fast what is good” (1 Thessalonians 5:21).
The reference to coal-burning power plants was immediately suspect. Why? First, because 20 to 80 percent, probably about 70 percent, of mercury deposited in the U.S. actually comes from non-U.S. sources. Second, because coal has been in the Greens’ crosshairs for decades. Yet coal power plants provide about 50% of America’s electricity (as EEN admits) at a fraction of the cost and with much greater reliability than “Green” alternatives like wind and solar (which EEN promotes), and affordable, reliable electricity is crucial to human well being. The drive to reduce its use conveniently serves radical environmentalists’ desire to de-industrialize Western civilization—a goal that would necessitate a much smaller, much poorer, much less healthy, much shorter-lived human population. EEN doesn’t share this radical environmentalist goal, but by joining the effort to reduce coal use, it promotes it, even if unintentionally.
Ironically, this means EEN’s promoting stiff mercury emission regulations, which would force reduced use of coal and steep increases in electricity prices, links concern for the unborn (a clear appeal to Christians’ pro-life sympathies) with a radical environmentalist agenda that EEN does not embrace—an agenda that is distinctly anti-human and would lead to far higher rates of disease and premature death than the mercury exposure the EEN wants to reduce—even if its claims about mercury were true.
But they’re not.
I’d seen similar claims before, about half a dozen years ago. The campaign’s literature offers no source for the statistics. Their most likely origin, however, seems to be an ad by the environmental advocacy group Friends of the Earth in USA Today in 2004 that claimed, “One in six American women of childbearing age has absorbed enough mercury to endanger a developing fetus,” and “630,000 babies are born each year with a dangerous level of mercury in their blood.” There’s another possible source. Not long before that ad appeared, Natural Resources Defense Council’s (NRDC) Climate Center Director David Hawkins had testified before Congress, “One in 12 [not six] women of childbearing age has mercury levels above EPA’s safe health threshold. … Nationally, this translates into … more than 300,000 newborns at risk of neurological impairment from exposure in utero.”
Those claims, however, badly exaggerated findings of a survey of mercury in Americans’ blood by the Centers for Disease Control. In reality, fewer than 1 in 1,000 American women had levels as high as those associated with even very subtle neurological effects (not with broader cognitive and intellectual performance) in children.
What accounts for the difference between “one in six” or “one in 12” and “1 in 1,000”? NRDC and Friends of the Earth confused what the U.S. Environmental Protection Agency (EPA) calls the “Reference Dose” with “a dangerous level.”
On the contrary, EPA’s Reference Dose is intentionally set unrealistically low—kind of like the old rabbinic tradition of building a “fence around the law.” For instance, since Mosaic law forbade working on the Sabbath, the rabbis determined not to spit on a dirty rock on the Sabbath, lest the spittle perform the work of moving some dirt—though they were free to spit on a clean rock.
EPA’s Reference Dose is like that. Here’s how EPA established it.
First, it established the “Benchmark Dose” (BD): the “lowest threshold dose level” (85 parts per billion) that resulted in reduced scores on one particularly sensitive neurological test related to very subtle effects (but not on other neurological tests related to broader cognitive and intellectual measures). Understand: that was the lowest level with any detectable effect, no matter how subtle. Second, it added a “statistical safety factor” by adopting the lower limit (58 parts per billion) of the 95 percent confidence level for the BD as its “Benchmark Dose Lower Limit” (BMDL). Third and finally, for even greater safety’s sake, it added an “uncertainty factor” (to account for uncertainties in individual responses across the population) by dividing the BMDL by 10 to get what it called its Reference Dose: 5.8 parts per billion. (That proportion is analogous to the first 7-3/4 feet of a trip to the moon, or the first 5.8 seconds out of 31.7 years.)
In short, EPA’s Reference Dose is multiples lower than necessary to ensure safety. To put it differently, while EPA is sure there’s no significant risk of harm at exposures below the Reference Dose, it doesn’t assert that exposures above it are harmful.
As a result, claims that mercury emissions from coal power plants are putting one in six unborn babies at risk of neurological harm are at best badly exaggerated, at worst, outright false. Rather than one in six (which would be about 690,000), the number is more likely about one in 1,000 (about 4,130). And the risk of harm to them is actually vanishingly small, while the harm, when it does occur, is also so subtle as to be almost undetectable.
Of course we want to keep risks to a minimum, especially for helpless babies, but sometimes reducing one risk involves increasing another—which is why medications come with lists of side effects, and some are banned after we learn their risks outweigh their benefits. Could it be that way with regulations to reduce mercury emissions?
Yes. In 2001 the Energy Information Administration estimated it would cost about $8.4 billion (in 2001 dollars) to achieve a 90 percent reduction in coal power plants’ mercury emissions. A standard estimate is that every $15 million (in 1999 dollars) in regulatory costs leads to the loss of one statistical life. This means the $15 million regulatory cost would cause 560 extra deaths. That’s deaths. And I suppose everyone would agree that death causes more than subtle neurological harm.
EEN’s goal would have another unintended harmful effect, too. Eating lots of fish undoubtedly reduces the risk of cardiovascular disease (heart attack and stroke). While EEN wants people at low risk from mercury to eat plenty of fish for that benefit, it also wants young children and women of childbearing age to be warned to eat less fish. Yet a study published in the Journal of Environmental Economics and Management found that an advisory about the risks of mercury from eating fish, despite its making the necessary qualifications, nonetheless resulted in reduced fish consumption by some consumers not considered at risk. The result? They were put at higher risk of cardiovascular disease.
The National Day of Prayer for Creation Care sounds like a good idea. Those behind it no doubt sincerely want to help others. But things just aren’t as simple as EEN makes them appear.
By all means, pray—and work—for a clean, healthful, beautiful planet. And while you’re at it, pray for discernment, for yourself and all God’s people.
[A shorter, less technical version of this article appeared last week in The Washington Times and at Crosswalk.com.]
