Environmental and occupational health can gather information and derive new knowledge more responsively if we understand how our studies are used in the big scheme of things. Every once in a while, it is important for scientists and professionals to step back and look at how the information we compile and the knowledge we derive from research is being used.
The documentation of previously hidden or underestimated health effects at increasingly low levels is not only important in its own right but an overlooked driver of technological innovation. Obsolete technologies are being replaced more rapidly than we might have believed, by innovations that are opening the door to a cleaner, higher-performing, and more sustainable future. That is what the technology revolution is all about, of course. In part because of the accompanying knowledge revolution, we now know so much more about the effects of pollution on people, even at what were once considered low levels. So why would we hesitate for a moment to demand more of technology in protecting health and improving environmental quality?
Once, technology usually made things worse by being inefficient and consuming more dirty energy. Now, for a change, technology is usually on our side. Once, it could be argued that attaining environmental standards was limited by the available technology. Now, environmental regulations become design specifications for the new technology. Suddenly, the only limits to progress seem to be the laws of thermodynamics.
That is why today is exactly the right time to tighten environmental standards, not to be satisfied with the progress made so far with current technology. Pollution standards should be thought through and revised downward before we as a society commit to new technology and investment options that will limit our choices in the future.
The process of health and environmental protection driving technology, through improving standards, benefits the fundamentals of the market economy. It does so by providing a truer and more correct accounting of costs. Once these costs are known with some confidence, the knowledge not only has a shaping effect on policy but also can have a driving effect on technology.
Our infrastructure is now being rebuilt, more slowly than one might like because of the erosion in municipal tax bases and the Great Recession. Because of the inexorable demand for cheaper, more efficient, sustainable, and less maintenance-intensive infrastructure, infrastructure is not just being rebuilt, as it once was, but transformed by new technology and innovation. Obsolete technologies are being displaced by alternatives that are cleaner and more sustainable.
This is, therefore, exactly the right time to review environmental standards and tighten them. Environmental standards become the design specifications for new technology, services, and products. As new options become available, we want the economy (ie, the market) to choose them on the basis of improved performance, enhanced safety, less impact on health, and honest accounting. New standards should therefore be thought through and revised now, before we as a society commit irreversibly to new technology and investment options that could limit our choices in the future.
Four recent and contemporaneous air quality-related measures from the US Environmental Protection Agency provide excellent examples. They are the EPA Clean Power Plan, the proposed EPA ozone air pollution standard, the mercury air toxics rule (which is already in effect), and the earlier actions to reduce fine particular air pollution. All four have been controversial and have provoked fierce opposition. Together, they do or will have the net effect of reducing particulate air pollution, reducing ozone generation, and reducing the emissions of more selective toxic substances into ambient air; the Clean Power Plan directly and the other measures indirectly will also reduce carbon emissions driving climate change.
Because of the broad measures and control technologies involved, measures to reduce carbon emission, reduce ozone formation, and reduce emissions of air toxics also reduce other air pollutants. This means that the benefits go beyond reduction of the specific target of each action and have many other positive effects. Working together, they make it easier to achieve air quality standards and have combined effects bigger than any one rule.
However, these standards have deeper dimensions than simply regulating hazards to provide health benefits. All four rest on the idea, seldom explicitly stated, that externalized costs, that is, costs currently absorbed by the community and nation in order to allow a polluter to produce a good or service, must be quantified. That is because they constitute a hidden subsidy, and therefore a distortion of the market. These costs are enormous for air pollution. Although they are calculated as anticipated benefits to be gained by improving air quality, health benefits are really one account in calculating the actualized current total cost to society. Externalized costs, in the form of health care costs, ill health, lost productivity, foregone use, and such are generally much greater than the cost of cleaning up pollution at the source, and so pollution represents a very bad deal for the community compared to effective, competent regulation.
One of the most important developments in these air quality regulations is the accounting of costs to society, so-called “externalized” costs, and using it to drive new technological futures. The emphasis has subtly shifted from cost/benefit (do health gains outweigh the cost of control?—they almost always do, in fact) to quantifying externalized costs and using recognition of these costs to drive improvement in technology, which results in much lower costs to society, greater efficiency, more participation by market forces, and better outcomes. At the same time, the state of the art has improved, and with the current conservative assumptions, the results are highly credible.
In the past, the argument was that adverse effects of pollution were outweighed by jobs, economic growth, and the need to stay competitive. However, that argument rested heavily on an accounting artifact: profits, economic benefit, and jobs have always been much easier to calculate than externalized costs, which depend on assumptions that can be debated. Now, thanks to environmental health scientists doing epidemiology, toxicology, and clinical research on pollution effects, we know better. The true cost of even moderate or low levels of pollution was finally revealed by the landmark studies of fine particulate air pollution, which showed unanticipated (in the 1980s) enormous effects in absolute terms for large populations.
In the past, dirty technology may have been all there was (although this is certainly arguable). Decisions therefore may have been based on the forced (and usually false, one should argue) choice of “take it or lose jobs.” As technology has developed, this logic no longer makes sense. In energy, for example, less polluting, more efficient, and safer alternatives have become available for energy production. Green chemistry is starting to transform our world of consumer products. Technology is not static and it can be guided.
Where it was once argued (speciously, one would say) that regulation introduced distortions into the market economy, it is now a market distortion to ignore or downplay real costs of production. It is a market failure not to harness the adaptability of technology by imposing environmental standards to which it must respond. Likewise, regulation along these lines makes the economy more efficient, because the cost of controls is a small fraction of paying for the consequences once pollution is released.
Analysis that quantify the externalized costs, properly conducted as in these four air quality measures, enlist market forces in the solution of the problem by putting costs back on the producer, making it a cost of production to be minimized, and by driving rather than passively accepting technological change. These four initiatives improve health by reducing air pollution and are closely linked with technology drivers and the environmental accounting principle of calculating actual costs to society and removing them from the public account by factoring them back into the cost of production, in the form of control technology or mitigating measures.
The impact of poor health and lost productivity on our society and economy is real. The regulations take into account these very real costs, which are unaccounted for in the current economy because they are absorbed by society, in the cost/benefit equation (which in most cases hugely favors regulation). By imposing the (much lower) costs of control on those parties who have created the pollution (and who stand to benefit), these regulations simply put the expense back where it belongs, accounted for honestly as part of the cost of production, which makes the market economy work better, not worse. Control of pollution at the source is also more efficient than spreading the costs across society in the form of ill health.
These regulations also result in a fairer and more just society because they remove a hidden, colossally inefficient, and unfair subsidy, one ultimately paid in health and environmental degradation and by children and neighbors. Customers in the community who use the energy produced or who buy the product will end up paying a fair cost, not beggaring their neighbor, whether their neighbor lives next door or downwind.
By imposing the (much lower) costs of control on those parties who have created the pollution (and who stand to benefit), these regulations simply put the expense back where it belongs, accounted for honestly as part of the cost of production instead of dumping the cost on the public. This actually makes the market economy work better and more efficiently, not worse, because absorbing the cost of poor health is actually nothing more than a hidden and deeply unfair subsidy to polluters.
Tee L. Guidotti
Editor-in-Chief
Archives of Environmental & Occupational Health