When an activity raises threats of harm to human health or environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically.

—Wingspread Statement on the Precautionary Principle

One crisis that PR firms rarely anticipate is the possibility that their own internal documents may be leaked to the public. This happened to the Ketchum PR firm in 1991 when one of its own employees, apparently offended by some of the techniques proposed in a “Draft Crisis Management Plan for the Clorox Company,” faxed a copy of the plan to the Seattle office of Greenpeace USA.

The Ketchum plan, designed to counter situations in which environmentalists might launch a major campaign against Clorox household bleach, attempted to “provide a ‘crystal ball’ pinpointing some of the issues which could arise over the next year. For each scenario we have suggested different levels of attention and response.” Examples included:

• “Crisis Scenario #1: Chlorine Free by 93. Greenpeace has announced a worldwide effort to rid the world of chlorine.” In this Ketchum scenario, Greenpeace releases a study linking chlorine exposure to cancer; demonstrators hold a rally outside the Clorox corporate headquarters; and reporters “interview three unsuspecting Clorox employees, on their way to lunch, who agree that the safety of chlorine may be in question.” In this sort of situation, Ketchum advised, the company’s objective should be to “make sure this is a one-day media event with no follow-up stories.” To achieve this, Clorox would announce that it “will seek an independent, third-party review of the Greenpeace study and promise to report back to the media. (While this last strategy may seem to be counter to the objective, the independent study will gain little media attention if it supports the company position; its primary value will be to cause reporters to question Greenpeace’s integrity and scientific capabilities.)” Simultaneously, a PR crisis management team would begin “alerting key influentials, scientists, government environmental and health officials, and others previously identified as potential allies. . . . Names of independent scientists who will talk about chlorine are given to the media. (These names are assumed to be already on file as per Master Crisis Plan.)”

• “Crisis Scenario #2: Back to Natural. The movement back to more ‘natural’ household cleaning products is gaining momentum.” In this scenario, a prominent newspaper columnist targets the environmental hazards of liquid chlorine bleach, and consumers begin turning to safer, natural cleaning products such as vinegar and borax. Anti-Clorox picketing campaigns occur in 10 major U.S. cities. Once again, the third party technique figures prominently in Ketchum’s response plan: “An independent scientist is dispatched to meet with the columnist and discuss the issue. Teams of scientists, independent or from Clorox or both, are dispatched to the 10 cities to conduct media tours. . . . [Crisis management team] arranges for sympathetic media, local, state and national governmental leaders, and consumer experts to make statements in defense of the product. These statements are then widely distributed in the affected communities. . . . Industry association (Chlorine Institute?) advertising campaign: ‘Stop Environmental Terrorism,’ calling on Greenpeace and the columnist to be more responsible and less irrational in their approach. . . . Consider video and audio news release to affected markets. . . . Conduct research to determine if and how a slander lawsuit against the columnist and/or Greenpeace could be effective.”

• “Crisis Scenario #3: National Toxicology Program (NTP) Study.” In this scenario, an NTP study concludes that chlorine is an animal carcinogen, attracting “widespread national media coverage.” In response, Ketchum proposes, “third-party scientific experts are brought to Washington to testify and advise both Congress and the EPA. . . . Third-party spokespeople are scheduled for major television and newspaper interviews. Industry generates grassroots letters to legislators calling on them to show restraint.”

Each of these scenarios and strategies entailed the recruitment, prior to any specific crisis, of “ambassadors in the scientific community to gain third-party credibility for Clorox environmental messages. . . . In addition to the relatively small group of scientists and academicians the Clorox Company will tap as spokespersons, the Crisis Team also must educate a broad network of scientific, medical and academic organizations that may be called upon by the media to comment on any health or environmental concerns. These groups include the American Medical Association, the American Academy of Pediatrics, . . . the American Academy of Family Physicians, as well as key chapters of the American Public Health Association. Third-party scientists working with the Clorox Company will provide the peer credibility needed to dialogue with these groups.”¹

Public disclosure of the Ketchum plan prompted the usual corporate disavowals. “Clorox management was not involved in its preparation, and is not acting on its recommendations,” said Clorox spokesperson Sandy Sullivan. Ketchum president David Drobis insisted that there was nothing unusual or inappropriate about the plan. “It shouldn’t be surprising that any company has such a plan,” he said. “In fact, it would be more surprising to find out that a major company didn’t.”²

In an interview with Executive Report, a business publication, Ketchum president Paul Alvarez explained further. “We routinely envision worst-case circumstances for our clients. That’s our job,” he said. “In the case of Clorox, we knew Greenpeace was very hot on the whole chlorine issue and we were concerned—as was the client—that Clorox, which doesn’t use chlorine, might be a mistaken target.”³

In fact, Clorox does use chlorine—specifically, sodium hypochlorite, a chlorine-based chemical that is widely used as a bleaching compound and disinfectant. What Alvarez probably meant to say is that sodium hypochlorite is generally regarded as safe for the environment. Even Greenpeace, which has campaigned heavily for a phase-out of all industrial uses of elemental chlorine, regards household bleach as a low-priority concern.⁴

Ketchum may indeed have been just doing its job. It is ironic, however, that many PR firms are willing to “envision worst-case circumstances for our clients” while working assiduously to prevent the public from envisioning worst-case scenarios that may affect human health and the environment. Nowhere is this more clear than in the high-stakes PR battle over organochlorines—the class of chlorine-based chemicals that Greenpeace does oppose. Environmentalists and public health advocates believe organochlorines threaten us with everything from cancer to sterility and birth defects. For more than a decade, however, the chemical industry—working through a variety of trade associations, including the Chemical Manufacturers Association, the Chlorine Institute, the Chlorine Chemistry Council, the Vinyl Institute, the National Association of Manufacturers, and the U.S. Chamber of Commerce—has been working to persuade the public and government policymakers that there is no threat at all.

The two sides in this debate both have access to the same scientific information, although they interpret it differently. Fundamentally, however, the difference between the two sides does not revolve around science. It revolves around a concept known as the “precautionary principle.”

Looking Before Leaping

Most of us learned some version of the precautionary principle as children. Our parents taught us to look both ways before crossing the street and admonished us that we were “better safe than sorry.” As a guideline for social and environmental policy, the precautionary principle has emerged in recent years as an expression of the growing realization that human technological advances have made it possible to do previously unimaginable damage to human health and the environment. With new power comes new responsibility, and the precautionary principle aims to anticipate and prevent potential disasters before they occur.

The principle has been formulated in various ways. “When there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation,” stated the 1992 United Nations Earth Summit Conference in Rio de Janeiro. Versions of the precautionary principle have been incorporated into several international treaties, including the Kyoto Protocol on global warming, and it has been enacted into law on a Europe-wide basis in a treaty that states, “Community policy on the environment . . . shall be based on the precautionary principle and on principles that preventive action should be taken, that environmental damage should as a priority be rectified at source and that the polluter should pay.” In January 1998, an international panel of scientists, grassroots environmental activists, government researchers, and labor representatives from the United States, Canada, and Europe formulated the “Wingspread Statement on the Precautionary Principle,” which defined the principle as follows: “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically.”

“To foresee and forestall is the basis of the precautionary principle,” explain Carolyn Raffensperger and Joel Tickner in their book, Protecting Public Health and the Environment. “It is the central theme for environmental and public health rooted in the elemental concepts of ‘first do no harm’ and ‘an ounce of prevention is worth a pound of cure.’ . . . Scientific uncertainty about harm is the fulcrum for this principle. Modern-day problems that cover vast expanses of time and space are difficult to assess with existing scientific tools. Accordingly, we can never know with certainty whether a particular activity will cause harm. But we can rely on observation and good sense to foresee and forestall damage.”⁵

The reason that scientific uncertainty is the fulcrum for the precautionary principle is that the harm associated with technological innovations is often impossible to prove at the time the new technology is introduced. When DDT was discovered, for example, it was considered a safe alternative to toxic metallic compounds then in use. Chlorofluorocarbons (CFCs) were also considered extraordinarily safe when they were introduced for use as coolants in refrigerators, and remained in use for decades before scientists discovered their destructive effect on the earth’s ozone layer. There was a scientific basis for concerns about leaded gasoline at the time of its introduction, but no irrefutable scientific proof. In each of these cases, waiting for proof to appear meant that action was not taken until serious damage to health and the environment had already occurred. Amassing unambiguous proof is a long and costly process, particularly after a product is in widespread use and industries have a vested interest in defending it. The idea behind the precautionary principle is that a lack of conclusive scientific evidence should not be used as an excuse for failing to take measures to protect human health and the environment.

Of course, like any guideline the precautionary principle can be abused. “One problem is that the precautionary principle could become a very convenient way to protect domestic industry and agriculture,” observes Jean Halloran of Consumers Union. “Let’s say for example that hothouse tomatoes grown in Holland are cutting significantly into U.S. hothouse tomato sales because the Dutch tomatoes are much more flavorful. The U.S. tomato industry searches around for a scientist-for-hire and finds one who will say that the tomato varieties that happen to do well in Dutch hothouses also have slightly higher levels of a toxic chemical that affected cell reproduction in one lab test done at the scientist-for-hire’s lab. He is also willing to lay out a theory whereby in a worst-case scenario this could suggest reproductive difficulties in 20 percent of the people who eat the Dutch tomatoes for three years or more. U.S. tomato growers demand a ban on imports under the precautionary principle.”

Obviously, some balance needs to be struck between hypothetical scenarios and actual plausible risks. “As a practical matter in these situations, one ends up weighing the scientific uncertainty against the benefits,” Halloran says. “In the case of bovine growth hormone, with zero benefits to consumers, there’s no reason to tolerate any risk, no matter how farfetched or small. With a new cancer drug, we’ll tolerate a lot of risk. With beef hormones, we can imagine two different societies coming to different judgments, but we can also imagine the beef industry in one of those societies distorting science to exaggerate or underestimate a risk in order to influence how society ends up feeling.”⁶

Most people probably think that the precautionary principle is already part of the process of evaluating and approving risky or unfamiliar chemicals, products, and industrial practices. To a casual observer, there might not seem to be a lot of difference between an industry lobbyist who talks of “assessing risks with sound science” versus an environmentalist who talks of “acting to mitigate potential risks before they appear.” In the real world, however, the differences are much greater than mere linguistics. Today’s regulatory system essentially allows anything to be released into nature unless it is proven unsafe by scientific data, which is defined to mean measurable harm. In practice, this means that preventive action is not taken until damage has already been done.

In 1998, for example, the U.S. Department of Agriculture attempted to promulgate standards for “organic agriculture” that would have defined any practice as “organic” provided it did not produce measurable degradation of soil quality. “One of the ways we could document ‘degradation’ to soil quality was measurable damage to earth worms,” says North Dakota organic farmer Frederick Kirschenmann, a member of the National Organic Standards Board. “But every soil scientist working with earth worms and soil quality with whom I have conferred has told me that it sometimes takes years to establish cause-effect relationships between farming practices and earth worm populations. And even then it is almost impossible to document precisely which practice causes the degradation. That means that under this regulatory scheme (i.e., risk assessment) we might have to allow ecologically damaging practices for years because we can’t say no before we can document degradation. This is especially true with respect to soil, since soil scientists are still debating how to measure soil quality, and since soil microbe communities are only now beginning to be understood. . . . It will be years before we will be able to determine which microbes cause which effects in soil and plant systems. And then some years more before we learn how to manage soil to take advantage of this miniature world of ecosystem services—critical to our understanding of organic agriculture. In the meantime, using the risk assessment model, certifiers would not be allowed to prohibit practices we suspect might be harmful to this microbial community, because we can’t yet prove it by establishing the necessary cause-effect data.”⁷

As Kirschenmann observes, this “risk management” approach runs contrary to the precautionary principle that has historically defined organic agriculture. “We have always operated on the assumption that we did not possess the cleverness to understand the intricate interrelationships of nature’s biological and evolutionary systems,” Kirschenmann says. “Consequently we have no choice but to act with caution. That is why we have always said ‘no’ to exogenous [foreign] materials, unless they were absolutely necessary, and the material had been proven safe, rather than merely not proven unsafe.”⁸

Adopting the precautionary principle shifts the burden of proof in decisions about whether to adopt new technologies. It prioritizes safety over innovation, and this is precisely why conventional business interests prefer to use risk analysis, which makes it easier to spin rationales in favor of business-as-usual. “In the face of scientific uncertainty, decision-makers who are responsible for the welfare and safety of the public are more frequently choosing what has become known as the precautionary principle,” complains Gregory Bond, corporate director of product responsibility at Dow Chemical. “This approach is being demanded by consumers and the general public, particularly in Europe where the Bovine Spongiform Encephalopathy (Mad Cow Disease) epidemic caused widespread outrage. Application of the precautionary principle has many in industry very concerned, because it is viewed as starting down a ‘slippery slope’ that could result in public policies based on theories, fear, and innuendo rather than sound science.”⁹

For the chemical industry, the precautionary principle is revolutionary because there are tens of thousands of chemicals that have already been introduced into common use without careful testing for long-term health effects. For the biotechnology industry, the principle is dangerous because thousands of products in development involve genetically modified foods, medical treatments, and other processes that they believe are safe but whose safety cannot be proven except in practice. For the automobile, fossil fuel, and mining industries, the precautionary principle is dangerous because growing evidence of global warming threatens to impose substantial changes on the way they do business. In their eyes, therefore, the slogan “better safe than sorry” means economic disruption, lost profits, and controversy—all because of risks that they are not convinced even exist.

The End of All We Hold Dear

“The precautionary principle holds that a manufacturer must prove that its product does no harm, before it can be marketed,” complains Jack Mongoven, president of the Washington-based public affairs firm of Mongoven, Biscoe & Duchin (MBD). Writing in eco.logic, an anti-environmentalist newsletter, Mongoven warned that “activists want to use this weapon to control the behavior of other Americans . . . [to] revolutionize American thinking about regulation, constitutional law, and government’s role in society. . . . If the type of thinking that underpins the precautionary principle prevails, future historians may refer to the last score of years of the twentieth century as the ‘Death of the Linear Period’ or the ‘Birth of the Holistic Age’ ”—as the end, in other words, of “devotion to logic and the abstract purity, clarity and certainty of Euclid and Aristotle,” which “provided Western civilizations with the basis for scientific learning and its tools for progress.” He warned that corporations need to “take the precautionary principle seriously, and develop a strategy to deal with it. . . . If industry does not participate in the process and ensure that logic and sound science prevail, it will have to live with the consequences, including the kind of fuzzy thinking which brought us the likes of the precautionary principle.”¹⁰

Like Gregory Bond, Jack Mongoven views the precautionary principle as a rhetorical ploy that appeals to the general public’s inability to think rationally or grasp the principles of science. “The modern day ‘common knowledge,’ as understood by most Americans, stems not from examination of facts, but from analogy and individual or group intuition,” he complains. Although Mongoven himself is not a scientist, he passes judgment on a variety of scientific issues, invariably reaching conclusions that match the interests of his clients. “Errors in common knowledge abound,” he states, “such as the impact of a 10 percent decrease in the ozone layer, the potential impact of global warming, the impact of manmade as compared to natural toxins, and the impact of acid rain. The unconscionable establishment of public policy based on known error to serve the ends of an individual or group is compounded when the issue involves science, because the average American is ignorant of science and of scientific method.”¹¹

You have probably never heard of Mongoven, Biscoe & Duchin before. It is a company that deliberately maintains a low profile, in keeping with its mission as a sort of ongoing corporate spy operation, expert in providing what it calls “public policy intelligence.” Its company literature describes it as “a public affairs firm specializing in issue management. It helps clients anticipate, cope with and respond to movements for change in public policy which would adversely affect them.”¹² MBD is highly secretive about its activities and refuses to name its clients, but an internal company document says they “are almost all members of the Fortune 100, and six are members of the Fortune top 20.”¹³ Known clients have included Monsanto, DuPont, Philip Morris, Shell Oil, and the Chlorine Chemistry Council, an offshoot of the Chemical Manufacturers Association that was formed in 1993 to combat a growing body of evidence linking chlorine-based chemicals to a wide-ranging series of environmental and health problems.

MBD’s services do not come cheap. Regular clients pay a retainer ranging from $3,500 to $9,000 per month. In addition, it produces special reports on specific organizations, which it sells to its corporate clients for upward of $1,000 per copy. According to MBD literature, the groups it routinely monitors are involved with issues including: “acid rain, animal rights, clean air, clean water, endangered species, environmental groups/movements, greenhouse effect, ozone layer, rainforest, global climate change, . . . superfund, hazardous and toxic wastes, environmental justice, drinking water, risk assessment/sound science, women’s and children’s health, . . . incineration, ocean waste, packaging, disposables, polystyrene, recycling, landfills, waste-to-energy conversion, . . . Eastern European developments, The Green Party (non-US), Greenpeace International, . . . indoor air pollution, dioxin, chlorine, organic farming/sustainable agriculture/[low impact sustainable agriculture], pesticides, . . . multiple chemical sensitivities, endocrine system disruption, . . . biotechnology—all phases, . . . vegetarianism/veganism, . . . oil spills, wetlands.”¹⁴

MBD promotional literature boasts that it maintains “extensive files” on “forces for change,” which “often include activist and public interest groups, churches, unions and/or academia.”¹⁵ A typical dossier includes an organization’s historical background, biographical information on key personnel, funding sources, organizational structure and affiliations, publications, and a “characterization” of the organization aimed at identifying potential ways to co-opt or marginalize the organization’s impact on public policy debates.¹⁶

To compile this information, MBD tries to get on the mailing list of nonprofit organizations, and its employees read activist newsletters and other publications to keep tabs on controversial issues that may affect its clients. Its field operatives telephone members of the groups they monitor, politely asking detailed questions while doing their best to sound sympathetic to the people they interrogate. They have on occasion misrepresented themselves, claiming falsely to be journalists, friends of friends, or supporters of the groups they monitor.¹⁷ Most of the time, however, they simply give very limited information, identifying their company only by its initials and describing MBD euphemistically as a “research group” that works to “resolve contentious public policy issues in a balanced and socially responsible manner.” During the heat of the Monsanto company’s campaign to win FDA approval for genetically engineered recombinant bovine growth hormone (rBGH), for example, MBD operative Kara Ziegler placed information-gathering calls in a single day to rBGH opponents including U.S. senator Russ Feingold; Dr. Michael Hansen of Consumers Union (the publisher of Consumer Reports magazine); and Francis Goodman, a Wisconsin dairy farmer. In June of 1996 another MBD employee, Emily Frieze, phoned environmental activist Paul Orum to ask about activities regarding ethylene glycol, a highly toxic poison used in antifreeze. The call came at a time when ethylene glycol manufacturers were lobbying to have the chemical removed from the government’s Toxic Release Inventory of right-to-know chemicals. In May of 1996, an MBD operative who identified herself as Tanya Calamoneri contacted Ann Hunt, executive director of the Citizens for Alternatives to Chemical Contamination (CACC), a Michigan group located near the headquarters of Dow Chemical, the nation’s largest producer of chlorine. Calamoneri wanted information about an upcoming environmental conference that CACC was sponsoring. “I asked which group she represented,” Hunt said. “Her response was ‘MBD,’ which she characterized as a public policy and research consulting group. I later learned that it was Mongoven, Biscoe and Duchin, chief consultants and dirt-diggers for the Chlorine Chemistry Council. . . . It amazes me that the forces of darkness are that interested in what a little grassroots group in central Michigan is doing.”

Mongoven claims to be “outraged” by the charge that any of these information-gathering practices are unethical. “We always identify exactly who we are,” he says. “In every case, we had identified ourselves as a Washington consulting firm. I don’t think that makes you a spy.”

The people his company snoops on, however, think differently. Australian writer and environmental activist Bob Burton took particular offense to a misleading MBD “survey” that he received in the mail. The accompanying cover letter, written by Jack Mongoven’s son Bart, sought Burton’s “assistance in a significant research undertaking” to “promote improved understanding and cooperation between major businesses and consumer- and environmentally-oriented interests throughout Asia and the world. . . . We would be very appreciative if you or a colleague could send us via phone, fax or mail some information about your organization. We obviously would welcome any materials that you believe would give us an accurate picture of your group—its basic structure, issue concerns, activities (past, present and future), alliances and goals. Perhaps you would be able to include samples of any newsletters or other publications your group publishes. In addition, we would be grateful for any thoughts you may have regarding the overall situation in your country and in Asia with respect to the issues you care about.” This information would be used, Mongoven promised, to help “corporate decision makers . . . develop a better appreciation of the public interest movement.”¹⁸

Whatever gratitude MBD claims to feel when activists cooperate by answering its questions, however, it doesn’t express that appreciation in any meaningful way, such as sending them copies of the reports it writes about them. Those reports are stamped confidential and sold only to MBD’s clients.

Defending the Free Enterprise System

Like many people in public relations, Jack Mongoven began his career as a journalist. He later moved into politics as a Republican party operative, serving as director of press relations for the Republican National Committee and in advisory roles to the Nixon, Ford, and Reagan presidencies. His work as an anti-activist began in 1981 when he was hired to help the Nestlé corporation cope with a massive protest against its infant-formula marketing practices in Third World countries. Nestlé was the world’s largest seller of infant formula, which provided a profitable outlet for surplus milk produced in Europe and the United States. Using advertisements, brochures, and free product samples distributed in hospitals, Nestlé and other multinational corporations successfully persuaded many Third World mothers to switch from breast-feeding to formula. The advertisements argued that use of store-bought infant formula was supported by medical experts, that it was more scientific, that it was healthier for babies, and that mothers who cared about their children would use modern formula instead of the old-fashioned breast method.

What Nestlé’s promotional materials failed to mention was that powdered infant formula could be fatal to children in the Third World, where people often lack the clean drinking water needed to dilute it, let alone facilities to sterilize feeding utensils. Cecily Williams, a pediatric physician in Africa, was one of the first to identify the problematic nature of the practice. After “seeing day after day this massacre of the infants by unsuitable feeding,” she stated bluntly that “misguided propaganda on infant feeding should be punished as the most criminal form of sedition, and that these deaths should be regarded as murder.”

Nestlé responded with a broadside accusing its critics of “an indirect attack on the free world’s economic system.” As vice president of the Nestlé Coordination Center for Nutrition (NCCN), Jack Mongoven began collecting files on the various churches, student groups, trade unions, women’s organizations, and health workers who had joined a boycott of Nestlé products. The strategy behind this surveillance, according to NCCN president Rafael Pagan, was “to separate the fanatic activist leaders—people who deny that wealth-creating institutions have any legitimate role to play in helping the Third World to develop—from the overwhelming majority of their followers.”

This notion that corporate critics are dupes of “fanatic activists” has served as the prototype for Mongoven, Biscoe & Duchin’s subsequent work for other corporate clients.

• In 1987, Mongoven and Pagan developed a plan, code-named the “Neptune Strategy,” to neutralize boycotts of Shell Oil related to its business activities in apartheid South Africa. The plan involved creation of a third-party group called the Coalition on Southern Africa, which countered calls for Shell to divest its South African holdings by talking of ambitious plans to promote education and training of South African blacks and develop black-black business links between South Africa and the United States. In reality, COSA was a deceptive paper front group with no resources to carry out these goals.¹⁹

• In the 1990s, MBD gathered intelligence for the Monsanto Company and Philip Morris’s cheese division at Kraft General Foods aimed at identifying critics of Monsanto’s genetically engineered bovine growth hormone.

• In the 1990s, it developed PR plans for chemical and meat-industry clients anxious to counter the work of consumer and environmental groups that were raising concerns about the harmful effects of dioxin and other chlorine-based chemicals.

• In 1997, MBD’s work became the focus of a minor scandal when agricultural journalist Alan Guebert discovered that the National Pork Producers Council (NPPC) had paid MBD some $48,000 to investigate groups, including the National Farmers Union, the Iowa Citizens for Community Improvement, the Center for Rural Affairs, the Land Stewardship Project, and the Missouri Rural Crisis Center. NPPC is a quasigovernmental organization that gets most of its funding in “pork checkoff funds” that farmers are required to pay when they market their pigs, in return for which the NPPC is supposed to represent the interests of farmers by helping to promote pork. However, $24 million of the $45 million in checkoff funds comes from America’s largest 40 producers, and it is the large producers who really call the shots within the organization. The larger corporate producers have been building massive factory farms that not only pollute the environment with noxious odors and manure runoffs, but also threaten the livelihood of many of the smaller, independent hog farmers among the NPPC’s 80,000 members. MBD’s report to the NPPC was aimed at advising it on how to counter “agricultural activist groups” that oppose construction of new corporate hog facilities. These activist groups were in fact defenders of small family farms, and their farmer-members were understandably unhappy to learn that their own trade organization had hired a PR firm to investigate them .²⁰

What we know about MBD comes primarily through two sources: the company’s literature, which it distributes sometimes at industry meetings, and leaked internal documents provided by whistle-blowers. The “Neptune Strategy,” as well as MBD’s work for Philip Morris and Monsanto on bovine growth hormone, its work on the chlorine issue, and its work for the National Pork Producers Council, are each examples of MBD activities that came to light when persons working for the company or one of its clients chose to provide copies of internal MBD documents to outside groups that were the target of its surveillance activities.

There are, of course, certain limitations to the conclusions that can be drawn from looking at leaked documents. MBD’s internal memoranda provide snapshots into moments of time and pieces of advice provided by an influential adviser to major corporations, but they do not reveal which specific suggestion was followed and which was ignored. Nevertheless, consistent patterns and themes recur in MBD’s advice to each client, themes which are also consistent with the advice that Ketchum provided to Clorox and with the crisis management strategies that PR firms have developed for other companies dealing with environmental and health issues. Taken together, the evidence suggests that MBD’s advice is in keeping with the standard practices of PR crisis management.

In 1996, a whistle-blower leaked two documents produced by MBD to map out “the battlefield for chlorine” on behalf of the Chlorine Chemistry Council (CCC), a chemical industry trade association. The earliest of the two documents was titled “Activist Update: Chlorine” and was dated May 18, 1994. The second, titled “Re: Activist Report for August” and dated September 7, 1994, included “a list of all the recommendations we provided CCC in August as to how best to counter the activists. The main recommendation—to mobilize science against the precautionary principle—still applies and dovetails with the long-range objectives regarding sound risk assessment.” These documents provide only a fragmentary picture of MBD’s work for the Chlorine Chemistry Council. Nevertheless, they provide some indication of the scope of the chemical industry’s enemy list, and the strategies that it is willing to pursue in order to defeat them.

Mongoven’s correspondence with the CCC also reveals a corporate mind-set that is overtly hostile to the environmental, consumer, and women’s health groups that it monitors. The groups mentioned in its 1994 reports to the CCC included the Sierra Club, Greenpeace, Ralph Nader’s U.S. Public Interest Research Group (PIRG), the Clean Water Network of the Natural Resources Defense Council, a New York-based environmental research group called INFORM, a St. Louis environmental group called the Gateway Green Alliance, the Women’s Economic and Development Organization (WEDO), and the National Wildlife Federation. In the May memorandum, Mongoven alerted the CCC about the Clean Water Network’s warning that “chlorine causes birth defects, reproductive problems, cancer and other human- and animal-health problems.” In response to these concerns, Mongoven stated, the Clean Water Network “is expected to expand its assault . . . to press attacks on other areas of chlorine chemistry—product-by-product, step-by-step, application-by-application.” ²¹

Mongoven expressed particular alarm at the 1994 publication of Fertility on the Brink by the National Wildlife Federation (NWF), a group that he described as “highly respected by mainstream environmentalists, conservationists, industry and government.” Like the Clean Water Network, he noted, Fertility on the Brink “attributes fertility and reproductive problems to exposure to chlorine-based chemicals. The report depicts widespread and devastating effects on the reproductive, endocrine and immune systems of humans and animals as a result of exposure to an environment permeated with chlorine-based chemicals.”²²

Rather than express concern about these “complex and severe effects,” however, MBD worried about the chlorine industry’s image. Mongoven accused the NWF of using “the issue of fertility as a vehicle to play on the emotions of the public and its concern for future generations.” Moreover, he added, “anti-chlorine activists are also using children and their need for protection to compel stricter regulation of toxic substances. This tactic is very effective because children-based appeals touch the public’s protective nature for a vulnerable group. . . . This tactic also is effective in appealing to an additional segment of the public which has yet to be activated in the debate, particularly parents. . . . The tone of the debate will focus on the needs of children and insist that all safeguards be taken to ensure their safety in development. For most substances, the tolerances of babies and children, which includes fetal development, are obviously much lower than in the general adult population. Thus, ‘environmental policies based on health standards that address the special needs of children’ would reduce all exposure standards to the lowest possible levels.”²³

Most people, of course, regard “concern for future generations” and “the special needs of children” as something more than mere emotionalism. For MBD, however, such concerns are not only irrational but a threat to science itself. “Anti-chlorine groups will probably devise tactics which promote the adoption of the ‘precautionary principle,’ ” Mongoven warned, although “the principle, which shifts the burden of establishing a chemical’s safety to industry, is unlikely to be adopted. The debate over the ‘precautionary principle’ will elevate the dioxin issue to a more conspicuous level. . . . This is a critical time for the future of risk assessment as a tool of analysis. The industry must identify the implications posed by the ‘precautionary principle’ and assist the public in understanding the damage it inflicts on the role of science in modern development and production.”²⁴

The Chlorine War

Jack Mongoven’s preoccupation with the precautionary principle is a reaction to an emerging body of controversial science regarding a class of chlorine-based chemicals—including DDT, dioxin, PCBs, and many others—that have come to be labeled “hormone mimickers” or “endocrine disruptors.” Prior to the 1990s, much of the debate over these chemicals was shaped by the legacy of science writer Rachel Carson and her 1962 environmental classic, Silent Spring. For years, concerns about these chemicals focused on whether they could cause cancer, and indeed there is a substantial body of scientific evidence suggesting that this is the case. The focus on cancer, however, has tended to obscure the fact that these chemicals also interfere with the hormonal messaging systems that control body development during fetal growth and infancy, thereby affecting growth, the reproductive and immune systems, and even personality, intelligence, and behavior. Although the science surrounding the “endocrine disruptor hypothesis” is still incomplete, leading researchers and scientific bodies have called for precautionary action now to avert the threat of serious harm to the environment and human health.

The role of DDT as a hormone mimic was observed as early as 1950, when researchers noticed that roosters exposed to DDT failed to develop male characteristics. DES was synthesized in 1938 by British scientist Edward Charles Dodds. At the time of its discovery, it was hailed by leading researchers and gynecologists as a synthetic form of estrogen, the female sex hormone. Doctors began prescribing DES for women with problem pregnancies, and eventually 4.8 million pregnant women worldwide would use the synthetic hormone—a massive and irresponsible experiment, as it turned out. In 1971, DES was linked to vaginal cancer in daughters whose mothers had taken the drug during the first three months of pregnancy. Subsequent research would also link DES with reproductive problems, including deformities of the genitals.

It was the hormonal effects of yet another chlorine-based chemical—dioxin—that served as the catalyst for the Chlorine Chemistry Council’s concerns and its decision to hire Jack Mongoven. Dioxin has been a subject of fierce debate since the 1970s, when it earned a reputation as one of the most toxic substances known to humans.²⁵ Formed as an unintentional by-product of many industrial processes such as waste incineration, chemical manufacturing, and pulp and paper bleaching, dioxin tends to bioaccumulate in fatty tissue, which means that it can be found at elevated concentrations in foods such as meat and dairy products. Dioxin was a toxic component of the Vietnam war defoliant Agent Orange, was found at Love Canal in Niagara Falls, New York, and was the basis for evacuations at Times Beach, Missouri, and Seveso, Italy. In 1985, an EPA risk assessment found that dioxin causes cancer in animals and probably in humans as well.

In 1985 and again in 1988, the EPA conducted risk assessments of dioxin, concluding in both cases that it should be classified as a probable human carcinogen. However, scientific data regarding its effect on humans has been limited, in part because scientists have not been certain how much dioxin people are exposed to, and also because of the difficulty in separating dioxin’s effects from the confounding effects of the many other chemicals to which people are routinely exposed. In 1990, a group of scientists representing both industry and the public health/environmental communities met at a conference, held at the Banbury Center of Cold Spring Harbor Laboratory in New York, which called for a new and more comprehensive EPA risk assessment. For industry, the hope was that a new risk assessment would conclude that the risks from dioxin were lower than previously estimated. The Chlorine Institute went so far as to have Edelman, its PR firm, issue a news release which falsely claimed that the Banbury Conference had reached a “consensus” to the effect that “dioxin is much less toxic to humans than originally believed.”²⁶ Although this claim was later retracted following angry complaints by several conference participants, EPA administrator Bill Reilly stated publicly that dioxin seemed less dangerous than previously thought. With industry’s blessing, he began a third EPA assessment of dioxin. Unfortunately for industry, the results of that reassessment ran contrary to expectations.

EPA’s reassessment took almost four years and cost $4 million. In addition to dioxin, the agency also considered a range of “dioxin-like” chemicals such as PCBs that are known to produce similar effects. It commissioned separate scientists from both inside and outside the agency to draft each chapter of the study, which ultimately involved the participation of about 100 scientists, including non-EPA scientists who peer-reviewed each chapter. In 1994, a six-volume, 2,000-page draft report was released and opened to public comment. It concluded that in addition to promoting cancer, dioxin and a number of other similar chemicals can disrupt the endocrine, reproductive, and immune systems, and that they can do this to a developing fetus at extremely low levels of exposure. Owing to pressures from industry, however, the draft report has become such a hot potato that EPA staff has become reluctant to talk about it publicly. As of late 2000 (the date of this writing), the finalized risk assessment remains unpublished.

“EPA’s study indicated that there is no safe level of dioxin exposure and that any dose no matter how low can result in health damage,” admitted the 1994 MBD advisory to the Chlorine Chemistry Council. “New findings on the mechanism of dioxin toxicity show that tiny doses of dioxin disrupt the action of the body’s natural hormones and other biochemicals, leading to complex and severe effects including cancer, feminization of males and reduced sperm counts, endometriosis and reproductive impairment in females, birth defects, impaired intellectual development in children, and impaired immune defense against infectious disease. . . . Further, dioxin is so persistent that even small releases build up over time in the environment and in the human body.”²⁷

Some of the strongest concerns about the effect of endocrine-disrupting chemicals have come from observations of their effect on wildlife. In California, ecologists have found an abnormally high ratio of female to male seagulls. In polluted parts of Florida, panthers have un-descended testicles and endocrinologists have observed abnormally small or deformed penises in alligators near a former Superfund pollution cleanup site. In Great Britain, biochemists have noticed “hermaphroditic” fish with both male and female genitals breeding in wastewater effluent. Arctic seals and polar bears have shown declining fertility. In humans, a series of studies have shown an alarming decrease in male sperm counts in different parts of the world, which have plummeted to half the level found 60 years ago.

Researchers have been able to replicate many of these effects in laboratory experiments with captive animals. At the University of California at Davis, toxicologist Michael Fry found that injecting the eggs of seagulls with DDT would cause ferminization of the testes tissue in baby male gulls and result in sterile adults. In one study, 79 percent of monkeys exposed to dioxin developed endometriosis (the development of endometrial tissue in females in places where it is not normally present).

Chlorine Plus Carbon

What DDT, DES, dioxin, and PCBs all have in common, along with many other endocrine-disrupting solvents and pesticides, is that they belong to a class of chemicals called organochlorines—organic compounds containing chlorine bonded to carbon. In nature, chlorine makes up less than 0.2 percent of all chemicals, but some 15,000 organochlorines are now commercially manufactured and marketed, and approximately half of the endocrine disruptors identified to date have been organochlorines. “This doesn’t mean that all chlorine compounds behave the same way, but virtually every organochlorine that’s ever been tested has been found to cause at least one significant adverse effect,” says biologist Joe Thornton, the author of Pandora’s Poison: Chlorine, Health and a New Environmental Strategy. ²⁸ Although organochlorines are rare in nature, they are produced in the manufacture of pesticides, herbicides, petrochemicals, plastics, and paper. They wind up in such common products as household cleaners, plastic wraps, food containers, children’s toys, compact disks, car doors, tennis shoes, and TV sets. Chlorinated chemicals are also introduced into water as a result of pulp and paper bleaching and through the use of chlorine to treat sewage and disinfect drinking water.

Chlorine-based chemicals are valued in the commercial world because they retain their potency for long periods of time. This very durability, however, also means that they remain in the environment for a long time after they have been released. DDT, for example, continues to accumulate to alarming levels in the fatty tissues of Great Lakes fish nearly a generation after its use was banned in the United States. Likewise, PCBs are still ubiquitous in the environment despite having been banned in 1976 because of links to human cancer.

Given the expense and difficulty involved in individually testing each of the 15,000 organochlorines currently in use, many environmental groups believe that this is a case where the precautionary principle should apply. Rather than assuming that each chemical is safe until it is proven otherwise, they believe that industry should bear the burden of proving a chemical’s safety or else find a safer alternative. Greenpeace has called for a 30-year phaseout of organochlorines. In addition to environmental groups, a number of governmental and other organizations have reached similar conclusions:

• The International Joint Commission on the Great Lakes (IJC) is an environmental policy group organized by the U.S. and Canadian governments that focuses on the Great Lakes region. In 1986, the IJC’s science advisory board drew up a list of 362 toxic compounds found in the Great Lakes and noted that at least half of these were chlorinated chemicals. In 1992, it recommended phasing out the use of chlorine and chlorine-containing industrial feedstocks as part of an effort to restore and protect the Great Lakes ecosystem.

• In October 1993, the American Public Health Association (one of the groups targeted as a potential ally in Ketchum’s PR plan for the Clorox Company) called for the eventual elimination of chlorine-based bleaches in the paper and pulp industry. In March 1994, the APHA called on industry to reduce or eliminate chlorinated organic compounds and processes and to introduce lower-risk alternatives. “Virtually all chlorinated organic compounds that have been studied exhibit at least one of a wide range of serious toxic effects such as endocrine dysfunction, developmental impairment, birth defects, reproductive dysfunction and infertility, immunosuppression, and cancer, often at extremely low doses,” it noted in a policy statement.²⁹

• The Paris Commission on the North Atlantic, representing 15 European governments and the European Community, has recommended that emissions of chlorine-containing compounds be reduced and that European governments adopt programs to phase out their use.

Don’t Say Maybe, Baby

The debate over endocrine disruptors was first introduced to a popular audience with the 1996 publication of Our Stolen Future by authors Theo Colborn, Dianne Dumanoski, and Pete Myers. Our Stolen Future acknowledged the difficulties and the limited knowledge that currently surrounds the theory of endocrine disruptors. “Because of our poor understanding of what causes breast cancer and significant uncertainties about exposure, it may take some time to satisfactorily test the hypothesis and discover whether synthetic chemicals are contributing to rising breast cancer rates,” they stated, adding that “the magnitude of this threat to human health and well-being is as yet unclear.”³⁰

Given the unanswered questions that still exist and the serious potential harm that may be caused by endocrine disruptors, Colborn, Dumanoski, and Myers recommended further research, coupled with efforts to minimize unnecessary chemical exposures. Like Greenpeace, their position was based partly on emerging science and partly on the precautionary principle. “Shift the burden of proof to chemical manufacturers,” they urged. “To a disturbing degree, the current system assumes that chemicals are innocent until proven guilty. This is wrong. The burden of proof should work the opposite way, because the current approach, a presumption of innocence, has time and again made people sick and damaged ecosystems. We are convinced that emerging evidence about hormonally active chemicals should be used to identify those posing the greatest risk and to force them off the market and out of our food and water until studies can prove their impact to be trivial.”³¹

The attack on the book was instant and vicious. The Wall Street Journal called it an environmental “hype machine.” The Competitive Enterprise Institute, an industry-funded Washington think tank, released two separate studies attacking the book, as did another libertarian outfit called Consumer Alert, which labeled Our Stolen Future “a scaremongering tract.” The industry-funded Advancement of Sound Science Coalition called a press conference to introduce 10 scientific skeptics who described the book as “fiction.” The American Council on Science and Health (ACSH), another long-standing, industry-funded defender of DDT, dioxin, and other chemicals, obtained a copy of the book in galley form months before publication and prepared an 11-page attack on it before it even hit bookstores. Toxicologist and ACSH member Stephen Safe called the book “paparazzi science.” In a debate with authors Colborn and Myers, ACSH president Elizabeth Whelan even attacked the caution with which the book presented its analysis. “Our Stolen Future uses the word ‘might’ 30 times,” she said. “The word ‘may,’ 35 times. We didn’t bother counting all the ‘could’s.”

Myers replied that he found it ironic to be “now criticized for using ‘might’ and ‘may’ and the caution with which we present some of the discussion. . . . When the book first came out, there were words put in our mouths that concluded we . . . had exaggerated the data. In fact, there were calls made to scientists who had not yet had the opportunity to read the book, and those claims were put in front of them, and of course they responded, ‘That would be ridiculous. That would be unscientific.’ But now that people have had the opportunity to read the book, and have discovered the care with which the arguments are presented, some folks are trying to find other ways to criticize the conclusions by ridiculing the care we take in stating them.”³²

The Cure for Prevention

In one of Jack Mongoven’s memos to the Chlorine Chemical Council, he expressed particular alarm at the Clinton administration’s appointment of Dr. Devra Lee Davis to assist in formulating government policy regarding breast cancer. “As a member of the Administration, Davis has unlimited access to the media while her position at the [Department of] Health and Human Services helps validate her ‘junk science,’ ” he wrote. “Davis is scheduled to be a keynote speaker at each of the upcoming . . . breast cancer conferences . . . sponsored by Women’s Economic and Development Organization (WEDO). Each conference is expected to emphasize a regional interest. . . . Topics include ‘Environment and Breast Cancer,’ ‘Organochlorines, Pesticides and Breast Cancer’ and ‘Environmental Justice.’ ”

In response, MBD advised the Chlorine Chemistry Council to shadow and preempt the WEDO conferences. “It is important in all cases to stay ahead of the activists,” he stated, “e.g., get to the New Orleans media and opinion leaders before the Chemical Week Chlorine Conference and the same in each of the cities where WEDO will hold conferences this fall. Let me know if you need more, e.g., we maintain calendars of anti-chlorine events and could include same if you would like.”³³ Prior to the 1994 WEDO conference in Dayton, Ohio, Mongoven recommended that the CCC use another of its PR firms, Ketchum Public Relations, to schedule “editorial board meetings in Dayton prior to . . . Davis’ speech,” and “enlist legitimate scientists in the Dayton area who would be willing to ask pointed questions at the conference.”³⁴

Although Mongoven calls Devra Lee Davis a “junk scientist,” she is in fact one of the world’s leading researchers into environmental causes of cancer and chronic disease. The holder of advanced degrees in both physiology and epidemiology, she has taught at the Mt. Sinai Medical Center, Rockefeller University, and other prestigious schools. She is a member of both the American College of Toxicology and the American College of Epidemiology. She has advised leading health officials, including the Surgeon General and the Deputy Assistant Secretary for Women’s Health, on a variety of cancer-related issues, and is the founder of the International Breast Cancer Prevention Collaborative Research Group, an organization dedicated to exploring the causes of breast cancer. An epidemiologist and former senior science adviser at the U.S. Department of Health and Human Services Department, she has authored more than 140 articles in publications ranging from Scientific American to the Lancet and the Journal of the American Medical Association. She has organized international meetings on the subject of cancer and, as a frequent speaker to women’s groups, is not only a scientist but an activist in the cause of cancer prevention.

Davis’s work is significant—and controversial—because it goes directly to the question of whether environmental factors other than smoking are causing an increase in cancer rates. In 1989, she compiled one of the few systematic comparisons of recent changes in deaths from cancer. Drawing information from millions of death certificates in six industrialized countries, she documented an increase since the 1960s in deaths from breast cancer, brain cancer, kidney cancer, myeloma, melanoma and non-Hodgkin’s lymphoma. None of these types of cancer had been linked to cigarette smoking. Davis noted also that these increases have occurred during a period when deaths from heart disease—another major disease linked to tobacco—have fallen.³⁵ “Both heart disease and cancer share a number of common causes, including cigarette smoking, heavy alcohol drinking, and possibly diets high in fat and low in fiber and anti-oxidants,” Davis notes. Nevertheless, “trends in these diseases are in opposite directions . . . with heart disease declining, while some forms of cancer are increasing.”³⁶ The trend is not uniform across all age groups. Improvements in treatment have led to dramatic decreases in cancer deaths among children. Death rates have increased, however, in people aged 45 or older. “We’re not talking about small increases here,” Davis says. Since the early 1970s, “some of these cancers have increased 25 percent to more than 200 percent.”³⁷

Breast cancer, in which Davis has taken a particular interest, may be linked to the endocrine-disrupting effects of dioxin and other chemicals. Estrogen, the hormone that makes women feminine, is a well-known breast cancer risk factor. Early menstruation, late menopause, not bearing children, and alcohol use all raise the level of women’s lifetime exposure to estrogen, and they have all been associated with higher-than-average rates of breast cancer. In recent years, research by Davis and other scientists has pointed to synthetic chemicals that Davis calls “xenoestrogens,” meaning “foreign estrogens”—as another risk factor.³⁸ “It seems quite obvious, doesn’t it?” Davis says. “There’s only one common thread tying together all of the known risk factors: The more estrogen exposure in a woman’s life, the greater her risk of breast cancer.” She adds, “We have tended to assume that because estrogen is a hormonal thing, a woman’s thing, there’s nothing we can do about it. Why haven’t we looked at these environmental chemicals that we now know can act like estrogens?”³⁹

Some research into this possibility began in the 1990s. Various studies have found elevated breast cancer rates among women who work in chemical plants or near hazardous waste sites, or whose drinking water has been contaminated with organochlorines. In 1992, Frank Falck, an assistant clinical professor at the University of Connecticut School of Medicine, analyzed tissue samples from 40 women who had biopsies of suspicious breast lumps. Compared with lumps judged benign, those that were cancerous showed much higher levels of organochlorines.⁴⁰ In a larger study that was published in 1993, biochemist Mary Wolff studied 14,290 women in New York who visited a mammography clinic between 1985 and 1991. She found that breast tissues with cancerous malignancies contained higher concentrations of DDT and PCBs. Women with higher levels of DDE (a breakdown product of DDT) in their blood faced as much as a fourfold increase in their risk of developing breast cancer.⁴¹

These results are tentative and scientifically controversial. Most studies, including some in which Wolff also participated, have not found evidence to support the hypothesis that DDT and PCBs increase breast cancer risk.⁴² What is clear, however, is that in the last 50 years, breast cancer rates have risen dramatically almost everywhere in the industrialized world. In 1960, one woman in 20 in the United States could expect to be diagnosed with breast cancer in her lifetime. Today the number is one in eight. In the United States alone, 1.6 million women currently have diagnosed cases of the disease. Each year, 182,000 new cases are detected, of which 46,000 will lead to death.⁴³

There is no question that the reported rate of breast cancer has been rising. The question is how to interpret this increase. Opponents of the environmental thesis claim that the increase is a statistical artifact due to better medical screening procedures that detect cases of breast cancer which previously would have gone unreported. Davis, however, points to research which shows that even after factors like improved mammography are taken into account, “a sustained one percent annual increase in breast cancer mortality has occurred since the 1940s. Others have also documented increased mortality from breast cancer in a number of industrial countries.”⁴⁴ And these are studies of deaths from breast cancer, not merely of detected cases. If improved screening saves lives, and if treatment methods are improving, better screening would be expected to cause a decline in the mortality rate.

Davis’s research implies that curtailing pollution is important in order to prevent cancer. “With respect to breast cancer, most of the confirmed risk factors, which relate to reproductive behavior and dietary factors, are not easily changed by social policy,” she observes. “Many of the proposed interventions to reduce breast cancer involve the lifelong use of pharmaceutical agents or the advocacy of radical changes in diet, lifestyle, or even reproductive behavior. As to the latter point, a generation of women that has struggled long for reproductive freedom is unlikely to embrace eagerly suggestions that place constraints on their reproductive choices.”⁴⁵ Unlike lifestyle factors, however, environmental exposures to xenoestrogens can be changed through policies that place stricter limits on pollution. “We don’t have to wait for conclusive proof,” Davis says. “It took 100 years from the first warnings about tobacco until we finally got tough. We must not wait that long to act against the epidemic of breast cancer.”⁴⁶

Rather than efforts to identify environmental causes affecting cancer rates, however, much of the scientific research and public discussion has focused on treatments—the so-called “race for the cure.” On paper, about a third of the U.S. National Cancer Institute’s $2 billion annual budget is dedicated to prevention research, but those are “rubber numbers,” according to longtime cancer researcher John C. Bailar III of McGill University. Most of what the institute calls “prevention” is actually basic research into the cellular mechanisms of cancer development rather than epidemiological studies and prevention trials. Research into cellular mechanisms and molecular biology has yet to accomplish much by way of saving lives, but it is politically safe research because it doesn’t rock many boats. A researcher who studies cell biology doesn’t have to risk getting hammered by the tobacco industry, agribusiness, or chemical manufacturers. “The prevention of cancer on a big scale is going to require that we change our habits, change our life styles, clean up the workplace, clean up the environment, change the consumer products that contain hazardous materials,” says Bailar. “It’s going to mean a whole new approach to everyday living.”⁴⁷

The story with breast cancer research is much the same as the story with research into other types of cancer. Instead of prevention, researchers focus on the basic cellular research or on various treatments for women who already have the disease. The major treatments are surgery, chemotherapy, and radiation—termed “slash, poison, and burn” techniques by Dr. Susan Love, a breast surgeon at the University of California at Los Angeles and author of Dr. Susan Love’s Breast Book.⁴⁸ Prior to the 1980s, in fact, no major studies on preventing breast cancer had ever been approved by the National Institutes of Health, the clearinghouse that awards the bulk of U.S. government medical research grants. NIH officials note that funding for breast cancer research has increased consistently since that time, but even in recent years several promising studies have been rejected, postponed, or abandoned.

Women and Children First

“It is obvious that the battleground for chlorine will be women’s issues—reproductive health and children,” Jack Mongoven observed in his 1994 memorandum to the Chlorine Chemistry Council. To counter the recommendations of scientists like Devra Lee Davis, he advised the CCC to mobilize the third party technique behind a campaign to create the impression that the pro-industry status quo was essential to public health. “It is especially important to begin a program directed to pediatric groups throughout the country and to counter activist claims of chlorine-related health problems in children,” he wrote. “Prevent medical associations from joining anti-chlorine movement. Create panel of eminent physicians and invite them to review data regarding chlorine as a health risk and as a key chemical in pharmaceuticals and medical devices. Publish panel’s findings and distribute them widely to medical associations and publications. Stimulate peer-reviewed articles for publication in JAMA [the Journal of the American Medical Association] on the role of chlorine chemistry in treating disease. . . . Convince through carefully crafted meetings of industry representatives (in pharmaceuticals) with organizations devoted to specific illnesses, e.g., arthritis, cystic fibrosis, etc., that the cure for their specific disease may well come through chlorine chemistry and ask them to pass resolutions endorsing chlorine chemistry and communicate their resolutions to medical societies.”

“I think of myself as jaded,” said Charlotte Brody of the Center for Health, Environment and Justice after reviewing MBD’s leaked documents, “but it still takes my breath away to see a professional, totally amoral directive that editorial visits be done because the scientific information that Devra Lee Davis has is too dangerous to go unfiltered.” Brody was also struck by MBD’s “recommendations that the chlorine industry should go to health groups and sign them up to defend the benefits of chlorine, without telling them what they are really signing up for, and before we can get to them and talk about how dioxins and other endocrine disrupters are harming their health. MBD doesn’t suggest going out and talking about why dioxin isn’t as dangerous as we say. Instead, it’s a much more clever and insidious strategy, where they sign up people with cystic fibrosis to defend the benefits of chlorine chemistry by suggesting to them that without chlorine there will never be a cure for their disease. They don’t even bring up dioxin, but they falsely suggest that we would bring an end to pharmaceutical research.”

The CCC and other chemical-industry trade associations appear to be following Mongoven’s advice. In December 1994—three months after Mongoven advised the CCC to “mobilize science against the precautionary principle”—the National Journal reported that the CCC “has increased its budget substantially. The council this year amassed a lobbying and public relations war chest of about $12 million—compared with about $2 million in 1993—from such members as Dow Chemical Co. and Occidental Chemical Co. The campaign to defend chlorine could expand to $15 million in 1995, according to a recent report in Chemical and Engineering News.” About a third of that budget was being spent on research, such as financing a “scientific review panel” to challenge the conclusions of the EPA’s dioxin reassessment. “In anticipation of the EPA report, the council hired Ketchum Public Relations to orchestrate a 30-city tour last summer in which scientists sympathetic with the industry’s positions met with news media representatives and community leaders to play down fears about dioxin,” the National Journal reported.⁴⁹

“We identified a number of independent scientists and took them on the road,” explained Mark Schannon, an associate director of Ketchum’s Washington office. In this context, of course, “independent” means pro-industry, as Schannon tacitly admitted. “Basically what we’re trying to do is assure that industry’s voice is heard by people who make policy decisions,” he said.⁵⁰

“After a year and a half of fighting regulatory and legislative threats, the Chlorine Chemistry Council . . . says it is shifting to a longer range goal of building a science base from which to argue its case,” reported the trade publication Chemical Week, quoting CCC operating committee chairman Leon Anziano, who said, “We want to move from firefighting to long-term advocacy of sound science.”⁵¹

The CCC is only one of several industry groups that have mobilized to fight the chlorine war. Others include the Chlorine Institute, the Chemical Manufacturers Association, the Vinyl Institute, the National Association of Manufacturers, and the U.S. Chamber of Commerce. Each of these has a public relations budget, and staff to write newspaper op-ed pieces, testify before Congress or the EPA, appear on news shows as “experts,” and speak to civic groups. In addition to Mongoven, Biscoe & Duchin, other PR firms that have been hired as footsoldiers include Goddard*Claussen/First Tuesday; the Jefferson Group; John Adams Associates; Keller & Heckman; Ketchum Communications; and Nichols Dezenhall.⁵²

The pesticide, plastics, pulp and paper, household products, oil, and cosmetics industries have all mobilized to defend chlorine chemistry against its environmentalist critics. The food industry has also weighed in, mindful that dioxin accumulates in fatty tissue and is therefore omnipresent in meat and dairy products. Coordinated by the National Cattlemen’s Beef Association, the food industry’s “Dioxin Working Group” includes the National Milk Producers’ Federation, American Society of Animal Science, National Broiler Council, National Turkey Federation, International Dairy Foods Association, American Sheep Industry Association, National Pork Producers Council, American Meat Institute, National Renderers Association, American Farm Bureau Federation, and the National Food Processors Association. In his report to the CCC, Mongoven noted that these groups “have a history of strong relations with the Agriculture Department, and it’s certain they will use these solid ties to put pressure on EPA through Agriculture.”⁵³

I Love Danger

In addition to bringing pressure to bear on the chlorine issue itself, Mongoven advised the Chlorine Chemistry Council to take measures that would directly attack the precautionary principle. “Bring the state governors in on the issue of risk assessment by communicating the benefits to them from being able to rely on a national standard,” he advised. “Establish third-party entities devoted to developing these standards in the near future. Take steps to discredit the precautionary principle within the more moderate environmental groups as well as within the scientific and medical communities.”⁵⁴

In 1999 alone, industry-allied groups mounted at least two forums aimed at attacking the precautionary principle. On June 3 and 4, 1999, the heavily industry-funded Harvard Center for Risk Analysis hosted a conference titled “The Precautionary Principle: Refine It or Replace It?” Funders of the conference included the CCC and the Chemical Manufacturers Association, along with the right-wing Koch Foundation, funded by Koch Industries, one of the largest oil pipeline operators in the United States and a notorious polluter.⁵⁵ In January 2000, Koch Industries agreed to pay a record $35 million in civil fines and restitution for hundreds of oil leaks in six states, the largest fine ever imposed on a single company for violations of the Clean Water Act.

Promotional material for the conference noted that the precautionary principle “is playing an increasingly influential role in public policy toward technologies that pose potential risks to public health, safety and natural resources. The principle is invoked frequently in Europe, and it is now beginning to enter policy discussions in North American and Asia. . . . Concerns have been raised that the precautionary principle may be too simplistic to guide decision-makers facing complex choices involving technologies with uncertain risks, benefits and costs to current and future generations. . . . We will . . . examine the role of the precautionary principle in the following regulatory case studies: biotechnology, synthetic chemicals, electric and magnetic fields, and global climate change.”

Recognizing again the important role that women would play in the debate, Mongoven advised that “an ideal partnership to undertake such a national debate” on the precautionary principle “would be the League of Women Voters and the American Chemical Society. These two organizations could in turn attract other credible organizations—and even accept corporate donations for the project—without jeopardizing their credibility. Clearly, given the issue’s importance to women’s organizations and children’s welfare organizations, these and reasonable environmental groups also should be encouraged to participate.” Perhaps the League of Women Voters turned out to be unavailable. Instead, an antifeminist lobby group called the Independent Women’s Forum, which receives 90 percent of its funding from the conservative Olin, Coors, Bradley, and Carthage Foundations, hosted a conference titled “Scared Sick” in February 1999 at the National Press Club in Washington, D.C. IWF’s science adviser, psychiatrist Sally Satel, opened the event by commenting that “women, as a group, tend to be more risk-averse. That’s why the IWF has chosen to explore the relationship between unjustified fears and health and science policy.”⁵⁶

The leadoff panel was an attack on the precautionary principle moderated by Neal B. Freeman, CEO of the Blackwell Corporation and producer of the PBS show “TechnoPolitics.” Freeman echoed Mongoven’s complaint about “holistic mind-sets” and the death of “linear thinking” before warming to the main theme of the day. The precautionary principle, he said, “jumped the ocean about ten years ago in the campaign to suppress the chlorine chemistry industry. Now it pervades policy debates. It informs—or misinforms—the global warming debate, the debate over the biotechnology industry, and . . . the whole cluster of women’s health issues. We can be thankful that the precautionary principle does not yet govern our creative lives. If it did, Columbus would not have discovered this continent, Thomas Edison would not have illuminated it, and Philo T. Farnsworth would not have transmitted television pictures of it.”

“If we must ensure that things are safe, how are we ever to cross streets?” fretted panelist David Murray of the Statistical Assessment Service (STATS), a conservative think tank that markets itself to journalists as an expert source for interpreting statistical and scientific news. “Must every pedestrian be so outfitted as to survive an encounter with the Metrobus?” Murray asked. “And how do we understand the potential benefits of certain things that are unforeseen? . . . The precautionary principle was mercifully never adopted by life on earth at its inception. After all, most mutations are deleterious. . . . What we have had to be most adapted for, as a species, is change itself.”

“The precautionary principle itself is a hazard both to our health and our high standard of living,” added panelist Elizabeth Whelan of the industry-funded American Council on Science and Health, arguing that efforts to fight pollution could lead to a collapse in the American standard of living, thereby creating “more poverty, more people without health insurance, and less access to health care generally. . . . Go back to what your mother said: ‘When in doubt, throw the precautionary principle out.’ ” Apparently the mothers of Murray and Whelan gave different advice than most moms, who usually advise their kids to look both ways before crossing the street, and who use the phrase “when in doubt, throw it out” as a precautionary principle for avoiding questionable foods.

The hypocrisy in these attacks on “environmentalist scaremongering” is that the attackers themselves rely heavily on rhetorical appeals to exaggerated fears. Will the economy really collapse if we protect kids from air pollution? Does “holistic thinking” really mean an end to scientific progress and Western civilization?

Jack Mongoven’s hostility to the precautionary principle is ironic because he himself is a practitioner of the precautionary principle with respect to the reputations and profits of his clients. MBD does not wait to be called before responding to the activist menace. Its ongoing surveillance of environmental, consumer, and church groups is designed to anticipate criticisms of his clients long before those criticisms are even aired in the news or other public forums. “It is important in all cases to stay ahead of the activists,” he advised the Chlorine Chemistry Council.

In its campaigns against environmentalists and consumer groups, Mongoven, Biscoe & Duchin has helped create its own form of fearmongering in which industry appears as an innocent giant under attack from “radicals” who, in the words of MBD’s Ronald Duchin, “want to change the system; have underlying socio/political motives,” and see multinational corporations as “inherently evil. . . . These organizations do not trust the . . . federal, state and local governments to protect them and to safeguard the environment. They believe, rather, that individuals and local groups should have direct power over industry.” In one memo to the chlorine industry, Mongoven argues that concerns about endocrine disruptors reflect “a grand strategy . . . to give Greenpeace a strong lead on the issues but to use various groups—some of which are more acceptable to the mainstream—to appear to lead specific issues, thus giving the overall campaign the appearance of a widespread, generally accepted grassroots uprising against chlorine chemistry.”