" In 1989, the Environmental Protection Agency ("EPA") considered air pollution regulations on "phosgene," a toxic gas used in the manufacture of pesticides and plastic. Approximately one billion pounds of phosgene is produced annually in the United States.16 Tragically, phosgene was used in chemical warfare in the Iran-Iraq War, and was anticipated to be used in Project Desert Storm.
As part of their research, the EPA scientists analyzed how different doses of phosgene affected the lungs, particularly of the people living around the manufacturing plants that process the gas. They found that except for local irritation to the skin, eyes and upper respiratory tract, the lungs could be considered the target organ of phosgene gas. Even at intermediate and low concentrations, phosgene destroys enzymes in the lungs. This causes fluid build up, and can lead to death by "drowning."17
Until then, the EPA scientists depended solely on animal experiments to predict the effect of the gas on humans. Human data would naturally be the ultimate preference to work from, but it was rarely available. To date, no information about intentional exposure in occupational settings exists for the EPA to analyze.18
Because of the lack of human data connected to the gas, scientists in the EPA's Assessment Branch suggested using the Nazi data on phosgene, since the Nazi experiments provided comparatively more data on humans, rather than the existing data derived from animal research."