The right-to-know is, or should be, an inalienable and fundamental democratic principle with the probable exception of national security concerns. Industry claims of confidentiality and trade secrecy are often a serious deterrent to the recognition of potential risks from carcinogenic and other wise toxic products. There is thus an urgent need to develop international rules to restrict claims of confidentiality to what is unarguably essential to protect independently validated proprietary information, exclusive of any health considerations. All other information on the carcinogenic and otherwise toxic risks of a product, drug or process must be automatically and fully released and made fully available to the public. It should, however, be emphasised that, with limited exceptions, the right-to-know in most nations is more honoured in the breach than in the observance.
There is a critical and overdue need to extend right-to-know requirements and legislation to the overseas operations, particularly in lesser developed countries, of corporations of the US and other major industrialised nations. Such requirements should encompass occupational, environmental and human rights practices requiring all corporations to report on their operations in foreign countries (Archer, 2001).
The greatest incentive to toxics use reduction is public knowledge of their identity and routes of avoidable exposure, particularly when safe alternatives are available. Right-to-know initiatives are thus among the most practical and potent political strategies in the war against cancer and against untested new products and technologies. Critical steps in this direction have already been developed in Europe with recent requirements for labelling genetically engineered foods.
It must be stressed, however, that labelling per se is inadequate unless accompanied by an explicit 'Red Flag' warning of recognised cancer and other health, environmental and occupational risks, and also of poorly defined or potential risks, such as is the case with genetically engineered milk and foods. Furthermore, labelling should not be used as a justification for the authorisation of new candidate carcinogens or for the continued use of carcinogenic products already in commerce. It must be stressed that labelling is no substitute for a moratorium or ban. Labelling is not only discriminatory to uneducated and lower socio-economic population groups, but may encourage industry to target such groups and penetrate national markets by price regulation strategies.
5.1. Consumer Products
Mainstream industry consumer products - foods and beverages, cosmetics and toiletries, and household products including home, lawn and garden pesticides - contain a wide range of undisclosed carcinogens - ingredients, contaminants and precursors - which pose major, but generally unrecognised, avoidable risks of cancer.
Examples of carcinogens in 12 common consumer products, 'The Dirty Dozen', none labelled with any cancer warning, are listed in Table 1 (Epstein, 1998, Table 17.4 and Appendix XIV). The gravity of these risks is illustrated by the following examples:
The dirty dozen consumer products.
Beef Frankfurters - (e.g. Oscar Mayer Foods Corporation)
Whole Milk - (e.g. Borden or Lucerne)
COSMETICS and TOILETRIESTalcum Powder - Johnson & Johnson, Inc.
Labelled Toxic Ingredient - Talc, Carcinogenic.
Note: Substantive evidence of causal relation to ovarian cancer.
Cover Girl Replenishing Natural Finish Make-up (Foundation) - Procter & Gamble, Inc.
Crest Tartar Control Toothpaste - Procter & Gamble. Inc
Alberto VO5 Conditioner (Essence of Neutral Henna) - Alberto-Culver USA, Inc.
Clairol Nice 'n East (Permanent Haircolor) - Clairol, Inc.
Note: Substantive evidence of causal relation to lymphoma, multiple myeloma, and other cancers.
HOUSEHOLD PRODUCTSAjax Cleanser - Colgate-Palmolive, Inc.
Unlabeled Toxic Ingredient - Crystalline Silica, Carcinogenic.
Zud Heavy Duty Cleanser - Reckitt & Colman, Inc.
Lysol Disinfectant Spray - Reckitt & Colman, Inc.
Zodiac Cat & Dog Flea Collar - Sandoz Agro, Inc.
Ortho Weed-B-Gon Lawn Weed Killer - Monsanto Co.
Note: Substantive evidence of causal relation to lymphoma, soft tissue sarcoma, and other cancers.
Consumer product legislation is well overdue. All foods, grown with the application of carcinogenic pesticides should be clearly labelled with a cancer warning, the name of each carcinogenic pesticide and the concentrations of its residues. Of particular concern are the high residues of multiple carcinogenic pesticides in grains, vegetables and fruit. Recent estimates indicate that by the age of one, cancer risks from residues of just eight common pesticides in 20 infant foods exceed the lifetime 'acceptable' cancer risks estimated by the US Environmental Protection Agency. US meat should also be clearly labelled as contaminated with residues of carcinogenic sex hormones (Epstein, 1998), as should US milk be labelled as a genetically engineered product, for which the public health hazards have been fully documented (Epstein, 1998; Epstein, 2001). Similarly, irradiated meat, poultry, eggs, and produce should be prominently labelled as 'irradiated', especially in view of their carcinogenic, mutagenic, nutritional and other risks. This requirement is in sharp contrast to efforts by industry, with complicity of the United States Food and Drug Administration and Department of Agriculture, to use labels with misleading euphemistic absurdities such as 'cold pasteurisation' or 'electronic pasteurisation' (Epstein and Hauter, 2001).
While ingredients of cosmetics and personal care products are generally identified on their labels by a long list of chemicals, this is meaningless to the overwhelming majority of consumers in the absence of any 'red flag' warning of the wide range of multiple carcinogenic ingredients, contaminants and precursors in most products. Similarly, the complete composition of all household cleaning and other products, including home, lawn and garden pesticides, should also be clearly labelled, together with cancer warnings for each listed carcinogenic ingredient. Consumer product legislation should require data and affidavits in support of claims of safety for organic or other products. Consideration should also be given to the granting of tax incentives to the manufacturers of safe alternative products.
5.2. Prescription DrugsA recent survey of 241 high volume US prescription drugs reported that nearly half posed cancer risks based on carcinogenicity tests designed by their manufacturers to prove safety (Moore, 1998). Many carcinogenic drugs have been identified at low test dosages, near or at therapeutic levels. These risks are compounded by the fact that carcinogenic drugs are often administered individually or in various combinations to tens of millions of patients, sometimes for decades and starting in childhood. One leading authority has claimed that prescription drugs may pose the single most important class of unrecognised and avoidable carcinogenic risks for the entire US population (Moore, 1998).
To argue that such risks are more than justified by their very real benefits is to posit a false dilemma, especially in view of the fact that patients are rarely affirmatively and explicitly informed of these risks, and of the availability of safer and effective alternatives. Legislation is urgently required to ensure that the pharmaceutical industry provides clear and explicit information on carcinogenic prescription and non-prescription drugs which should also be labelled with clear warnings of such risks. Physicians should also be required to endorse these warnings, provide patients with information on safe and effective alternatives, and be held accountable for failure to do so.
5.3. Occupational CancerIn addition to the use of controlled production and closed system technologies and other control systems including local exhaust ventilation, workers and their representatives have inalienable rights to be given full information on the identity of all carcinogens, including raw materials, intermediates, impurities and final products, to which they are exposed by explicit labelling and posting. Additionally, they are entitled to quantitative information on levels of inhalation and skin exposure for each carcinogen. All such information should be made available to workers on a daily basis, and also reported to the responsible regulatory authorities.
5.4. Environmental CancerCitizens are entitled to full access to information from local and national government on their avoidable carcinogenic exposures from air and water. Such information is likely to encourage industry to reduce environmental emissions and discharges of carcinogenic and toxic pollutants and also to encourage more stringent governmental regulation.
Every regional municipal authority should be required to provide consumers with a complete list of carcinogenic contaminants and their concentrations in drinking water together with each water bill. Similarly, every chemical, mining and nuclear industry should be required to disclose to local communities and regional and national governments a complete listing of all carcinogens, including intermediates and products, they use, process, manufacture and dispose. They should also be required to disclose the amounts of each carcinogen they discharge into surrounding air and water. No industry should be allowed to operate unless it provides ongoing quantitative information on smokestack and other atmospheric emissions of carcinogens in the air of its perimeter and in the local community.