By
Jennifer Nalbone, Great Lakes
United
This presentation discusses
an unmet need in striving
to prevent Aquatic Nuisance
Species invasions - the need
to adopt environmental soundness
and pollution prevention as
our working principles.
“Environmental soundness”
is based on an ecosystem approach—looking
at how human actions affect
the well-being of the entire
Great Lakes ecosystem and
maintaining the biological,
physical and chemical integrity
of the ecosystem as we satisfy
the needs of the human species.
Achieving environmental soundness
recognizes that our cultures,
societies, and economies are
part of the ecosystem. Humans
functioning within an ecosystem
must resolve not to destabilize
or irreparably damage it.
Soundness takes into account
that we cannot address an
environmental issue—even
one as critical as ANS–by
solely focusing on trying
to fix the problem, rather
than modifying the practices
that cause the problem. Great
Lakes ANS may be an indication
that a cultural, social or
economic practice is unsustainable
and should be modified. The
alternative is losing the
integrity and value of this
unique freshwater environment.
The actions taken to prevent
and control ANS will have
repercussions. We are challenged
to ensure these repercussions
do not create or accelerate
other forms of environmental
degradation. The National
Invasive Species Act applies
this concept when it urges
the use of environmentally
sound methods, and defines
them as,
Methods, efforts, actions
or programs to prevent introductions
or control infestations of
aquatic nuisance species that
minimize adverse impacts to
the structure and function
of an ecosystem and adverse
effects on non-target organisms
and ecosystems and emphasize
integrated pest management
techniques and non-chemical
measures.
Further, there has been a
growing shift in thinking
about how to address environmental
issues. The historical way
of thinking was that a certain
level of health or environmental
damage was acceptable, that
a certain degree of proof
of that damage was needed
before taking action to mitigate
it. In this scenario, risk
assessment is the best mechanism
to determine harm. A newer
way of thinking, embraced
by international bodies such
as the United Nations Environmental
Program and the International
Joint Commission, addresses
environmental issues from
a prevention paradigm and
uses the precautionary principle
as its foundation. This principle
states in part,
Environmental measures must
anticipate, prevent and attack
the causes of environmental
degradation. Where there are
threats of serious or irreversible
environmental damage, lack
of scientific certainty should
not be used as a reason for
postponing measures to prevent
environmental degradation.
If we commit to adopting the
ecosystem approach and precautionary
pollution prevention, we must
examine all options to stop
the primary vector for ANS
introductions into the Great
Lakes. If one approach is
adopted, such as ballast water
treatment, we must choose
to develop and use treatments
that do not exacerbate chemical
pollution in the basin.
It is apparent that the Great
Lakes region has not adopted
the ecosystem approach when
dealing with ANS, because
we are not critically examining
the feasibility alternatives
such as banning untreated
ballast water discharge from
foreign ships into the Great
Lakes or facilitating the
establishment of modified
trading patterns or transfer
stations to preempt the need
for foreign ships to enter
the Lakes at all. At the very
least, commitment to the ecosystem
approach in the Great Lakes
would mandate a serious examination
of options beyond only ballast
water treatment.
Unfortunately, the current
approach taken by the region
to prevent ANS introductions
via ballast water is limited
to developing ballast water
treatments and technologies
while maintaining the current
trade patterns and the ability
of foreign ships to discharge
ballast water in the Great
Lakes. This appears to be
the only approach available
to North American coastal
waters, which are also undergoing
irreparable damage from ANS.
However, for the Great Lakes,
this limited approach constrains
our ability to examine whether
a more sustainable mechanism
to move goods exists, both
economically and environmentally.
It also assumes that access
to the waters of the Great
Lakes is identical to access
to coastal waters of North
America, and improvements
in ballast water management
on the Great Lakes must be
identical to improvements
in management on coastal waters
of North America.
Fortunately, within the limited
approach, there seems to be
agreement that biological
pollution prevention is the
only effective means to prevent
ANS introductions. However,
we must remain in harmony
with the environmental issue
on which pollution prevention
was founded; that is, chemical
pollution prevention.
What follows is a brief presentation
of the constraints and restrictions
that will be encountered if
a popular potential biocide
– chlorine-based disinfectants
– were used for ballast
water treatment.
There are many regulations
on the use of chlorine, sodium
hypochlorite and chloramines
to cleanse drinking water.
Chlorine-based disinfectants
effectively kill many microorganisms.
They also have a strong tendency
to react with organic material
creating trihalomethanes (THMs).
THMs are cancer causing and
the EPA regulated THM exposure
to a maximum concentration
of 100 parts per billion in
drinking water. They also
set 0 (zero) as the maximum
contaminant level goal for
some individual THMs, which
is the level of exposure where
there are no known or expected
health risks.
In addition to chlorine readily
reacting with organic material
to form THMs, chlorine also
has an even stronger propensity
to react with metals. This
means that chlorine products
have the potential to corrode
ballast tanks and discharged
chlorine-treated ballast water
can contain residuals that
kill fish. Fish breathe oxygen
directly out of the water,
by binding oxygen to iron
in their bloodstream. Even
small amounts of chlorine
residuals bind to this iron
and can starve the fish of
oxygen, effectively suffocating
the fish. If ballast water
were to be treated with chlorine-based
disinfectants, regulations
would likely require treated
ballast water to contain extremely
low concentrations of residual
chlorine in the discharge
water in order to protect
fish-- levels possibly comparable
to human drinking water standards.
Not only are there regulations
to applications of chlorine-based
disinfectants, progressive
policies around the world
are stressing the need to
move away from the restricted
cost-benefit use of chemicals
towards non-chemical alternatives
and pollution prevention.
To that effect, the United
States Congress adopted a
pollution prevention policy,
US Code, Title 42, Chapter
133, which states:
The Congress finds that:
1) The United States of America
annually produces millions
of tons of pollution and spends
tens of billion of dollars
per year controlling this
pollution.
2) There are significant
opportunities for industry
to reduce or prevent pollution
at the source through cost-effective
changes in production, operation,
and raw material use. Such
changes offer industry substantial
savings in reduced raw material,
pollution control, and liability
costs as well as help protect
the environment and reduce
risks to worker health and
safety.
3) The opportunities for
source reduction are often
not realized because existing
regulations, and the industrial
resources they require for
compliance, focus upon treatment
and disposal, rather than
source reduction; existing
regulations do not emphasize
multi-media management of
pollution; and businesses
need information and technical
assistance to overcome institutional
barriers to the adoption of
source reduction practices.
4) Source reduction is fundamentally
different and more desirable
that waste management and
pollution control. The Environmental
Protection Agency needs to
address the historical lack
of attention to source reduction….
The Congress hereby declares
it to be the national policy
of the United States that
pollution should be prevented
or reduced at the source whenever
feasible; pollution that cannot
be prevented should be recycled
in an environmentally safe
manner, whenever feasible;
pollution that cannot be prevented
or recycled should be treated
in an environmentally safe
manner whenever feasible;
and disposal or other release
into the environment should
be employed only as a last
resort and should be conducted
in an environmentally safe
manner.
In addition to the constraints
of federal policy and regulations
to control toxic exposure,
there are social factors constraining
the use of chlorine-based
disinfectants as ballast water
biocides.
Here are two examples of community
efforts to promote alternatives
to the use of chlorine and
chlorine pollution prevention.
Toronto Environmental Alliance
is an active proponent of
pollution prevention and has
worked with the city of Toronto
to adopt chlorine free purchasing
policies. They also encouraged
Toronto to incorporate chlorine-free
disinfection alternatives,
such as ultraviolet radiation,
in their water treatment facility
upgrade plans. Canadian Auto
Workers, Local 200, in Windsor,
Ontario was instrumental in
getting the city of Windsor’s
water treatment plant to significantly
reduce the amount of chlorine
used by incorporating ozone
treatment into their facility.
Many other examples exist
that illustrate community-level
efforts to prevent chemical
pollution from entering the
basin’s freshwater supply.
Groups such as these would
likely oppose the additional
release of chlorine-based
disinfectants into the basin’s
freshwaters.
When we are dealing with an
environmental problem with
catastrophic and irreversible
impacts like ANS, we must
examine the problem by taking
an ecosystem approach and
critically examining whether
our cultural, social or economic
practices are unsustainable
and need to be modified. Only
through this approach can
we identify all alternatives
to solving such a critical
environmental problem. Here
in the Great Lakes we are
fortunate to have many viable
alternatives for ballast water
management due to the unique
constructed access to the
basin that are not available
to the rest of North America.
We also must strive to address
the problem in an environmentally
sound manner, in a manner
that does not contradict or
undermine ongoing efforts
to protect and restore the
biological, chemical and physical
integrity of the environment.
The statement has been made
at this symposium, that there
will be greater increases
of funding allocated to ANS
prevention when we bring forth
an obstacle-free approach.
As we work collectively in
the Great Lakes region to
address ANS, the stakeholders
under the banner of Great
Lakes United that I represent
strongly state that the use
of biocides, their release
and the release of their byproducts
into the environment is an
obstacle.
Despite the current limited
approach, a very encouraging
point is that we have viable
non-chemical ballast water
technologies that are being
field tested, and many more
stand-alone technologies are
waiting for ballast water
standards to be set before
they are modified for shipboard
application. In fact, non-chemical
technologies are arguably
on comparable timelines as
chemical control experimentation.
And unlike chemical controls,
we can improve upon the efficacy
of these non-chemical technologies
without increasing risk to
the environment, or compromising
worker safety from exposure
to chemicals or their by-products.
I challenge the Great Lakes
Aquatic Nuisance Species Panel
to take an ecosystem approach
consistent with the concepts
and practices of soundness
and pollution prevention—both
biological and chemical. Addressing
ANS invasions in this manner
will lead to progressive,
sound, effective and sustainable
technologies, programs and
economies in this region that
will be compatible with other
countries developing ballast
water management strategies.
By adopting an ecosystem approach
based on the principles of
environmental soundness and
pollution prevention, the
Great Lakes region will continue
to be global leaders in the
fight to prevent the spread
of ANS.
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