History
Early examples of legal enactments designed to consciously preserve
the environment, for its own sake or human enjoyment, are found
throughout history. In the common law, the primary protection was found in the law of nuisance, but this only allowed for private actions for damages or injunctions if there was harm to land. Thus smells emanating from pig sties, strict liability against dumping rubbish, or damage from exploding dams.
Private enforcement, however, was limited and found to be woefully
inadequate to deal with major environmental threats, particularly
threats to common resources. During the "Great Stink" of 1858, the dumping of sewerage into the River Thames began to smell so ghastly in the summer heat that Parliament had to be evacuated. Ironically, the Metropolitan Commission of Sewers Act 1848 had allowed the Metropolitan Commission for Sewers to close cesspits
around the city in an attempt to "clean up" but this simply led people
to pollute the river. In 19 days, Parliament passed a further Act to
build the London sewerage system. London also suffered from terrible air pollution, and this culminated in the "Great Smog" of 1952, which in turn triggered its own legislative response: the Clean Air Act 1956. The basic regulatory structure was to set limits on emissions for households and business (particularly burning coal) while an inspectorate would enforce compliance.
Notwithstanding early analogues, the concept of "environmental
law" as a separate and distinct body of law is a twentieth-century
development.
The recognition that the natural environment was fragile and in need of
special legal protections, the translation of that recognition into
legal structures, the development of those structures into a larger body
of "environmental law," and the strong influence of environmental law
on natural resource laws, did not occur until about the 1960s. At that
time, numerous influences - including a growing awareness of the unity
and fragility of the biosphere;
increased public concern over the impact of industrial activity on
natural resources and human health; the increasing strength of the
regulatory state; and more broadly the advent and success of environmentalism as a political movement
- coalesced to produce a huge new body of law in a relatively short
period of time. While the modern history of environmental law is one of
continuing controversy, by the end of the twentieth century
environmental law had been established as a component of the legal
landscape in all developed nations of the world, many developing ones, and the larger project of international law.
Pollution control
Air quality
Industrial air pollution now regulated by air quality law
these are studied in enviromental studies
Water quality
A typical stormwater outfall, subject to water quality law
Water quality laws govern the release of pollutants into water resources, including surface water, ground water, and stored drinking water.
Some water quality laws, such as drinking water regulations, may be
designed solely with reference to human health. Many others, including
restrictions on the alteration of the chemical, physical, radiological, and biological characteristics of water resources, may also reflect efforts to protect aquatic ecosystems
more broadly. Regulatory efforts may include identifying and
categorizing water pollutants, dictating acceptable pollutant
concentrations in water resources, and limiting pollutant discharges
from effluent sources. Regulatory areas include sewage treatment and disposal, industrial and agricultural waste water management, and control of surface runoff from construction sites and urban environments.
Waste management
A municipal landfill, operated pursuant to waste management law
Waste management laws govern the transport, treatment, storage, and disposal of all manner of waste, including municipal solid waste, hazardous waste, and nuclear waste, among many other types.
Waste laws are generally designed to minimize or eliminate the
uncontrolled dispersal of waste materials into the environment in a
manner that may cause ecological or biological harm, and include laws
designed to reduce the generation of waste and promote or mandate waste
recycling. Regulatory efforts include identifying and categorizing waste
types and mandating transport, treatment, storage, and disposal
practices.
Contaminant cleanup
Oil spill emergency response, governed by environmental cleanup law
Environmental cleanup laws govern the removal of pollution or contaminants from environmental media such as soil, sediment, surface water, or ground water.
Unlike pollution control laws, cleanup laws are designed to respond
after-the-fact to environmental contamination, and consequently must
often define not only the necessary response actions, but also the
parties who may be responsible for undertaking (or paying for) such
actions. Regulatory requirements may include rules for emergency
response, liability allocation, site assessment, remedial investigation,
feasibility studies, remedial action, post-remedial monitoring, and
site reuse.
Chemical safety
Chemical safety laws govern the use of chemicals
in human activities, particularly man-made chemicals in modern
industrial applications. As contrasted with media-oriented environmental
laws (e.g., air or water quality laws), chemical control laws seek to
manage the (potential) pollutants themselves. Regulatory efforts include
banning specific chemical constituents in consumer products (e.g., Bisphenol A in plastic bottles), and regulating pesticides.
Resource sustainability
Impact assessment
Environmental impact assessment (EA) is the assessment of the environmental consequences
(positive and negative) of a plan, policy, program, or actual projects
prior to the decision to move forward with the proposed action. In this
context, the term "environmental impact assessment" (EIA) is usually used when applied to actual projects by individuals or companies and the term "strategic environmental assessment" (SEA) applies to policies, plans and programmes most often proposed by organs of state. Environmental assessments may be governed by rules of administrative procedure regarding public participation and documentation of decision making, and may be subject to judicial review.
Water resources
An irrigation ditch, operated in accordance with water resources law
Water resources laws govern the ownership and use of water resources, including surface water and ground water. Regulatory areas may include water conservation, use restrictions, and ownership regimes.
Mineral resources
Mineral resource laws cover several basic topics, including the
ownership of the mineral resource and who can work them. Mining is also
affected by various regulations regarding the health and safety of
miners, as well as the environmental impact of mining.
Forest resources
A timber operation, regulated by forestry law
Forestry laws govern activities in designated forest lands, most commonly with respect to forest management and timber harvesting. Ancillary laws may regulate forest land acquisition and prescribed burn practices. Forest management laws generally adopt management policies, such as multiple use and sustained yield,
by which public forest resources are to be managed. Governmental
agencies are generally responsible for planning and implementing
forestry laws on public forest lands, and may be involved in forest inventory, planning, and conservation, and oversight of timber sales. Broader initiatives may seek to slow or reverse deforestation.
Wildlife and plants
Wildlife
laws govern the potential impact of human activity on wild animals,
whether directly on individuals or populations, or indirectly via
habitat degradation. Similar laws may operate to protect plant species.
Such laws may be enacted entirely to protect biodiversity,
or as a means for protecting species deemed important for other
reasons. Regulatory efforts may including the creation of special conservation statuses,
prohibitions on killing, harming, or disturbing protected species,
efforts to induce and support species recovery, establishment of
wildlife refuges to support conservation, and prohibitions on
trafficking in species or animal parts to combat poaching.
Fish and game
Fish and game laws regulate the right to pursue and take or kill certain kinds of fish and wild animal (game).
Such laws may restrict the days to harvest fish or game, the number of
animals caught per person, the species harvested, or the weapons or
fishing gear used. Such laws may seek to balance dueling needs for
preservation and harvest and to manage both environment and populations of fish and game. Game laws can provide a legal structure to collect license fees and other money which is used to fund conservation efforts as well as to obtain harvest information used in wildlife management practice.
Principles
Environmental
law has developed in response to emerging awareness of and concern over
issues impacting the entire world. While laws have developed piecemeal
and for a variety of reasons, some effort has gone into identifying key
concepts and guiding principles common to environmental law as a whole.
The principles discussed below are not an exhaustive list and are not
universally recognized or accepted. Nonetheless, they represent
important principles for the understanding of environmental law around
the world.
Sustainable development
Defined by the United Nations Environment Programme
as "development that meets the needs of the present without
compromising the ability of future generations to meet their own needs,"
sustainable development
may be considered together with the concepts of "integration"
(development cannot be considered in isolation from sustainability) and
"interdependence" (social and economic development, and environmental
protection, are interdependent). Laws mandating environmental impact assessment and requiring or encouraging development to minimize environmental impacts may be assessed against this principle.
The modern concept of sustainable development was a topic of discussion at the 1972 United Nations Conference on the Human Environment (Stockholm Conference), and the driving force behind the 1983 World Commission on Environment and Development (WCED, or Bruntland Commission). In 1992, the first UN Earth Summit resulted in the Rio Declaration,
Principle 3 of which reads: "The right to development must be fulfilled
so as to equitably meet developmental and environmental needs of
present and future generations." Sustainable development has been a core
concept of international environmental discussion ever since, including
at the World Summit on Sustainable Development (Earth Summit 2002), and the United Nations Conference on Sustainable Development (Earth Summit 2012, or Rio+20).
Equity
Defined by UNEP to include intergenerational equity - "the right of
future generations to enjoy a fair level of the common patrimony" - and
intragenerational equity - "the right of all people within the current
generation to fair access to the current generation's entitlement to the
Earth's natural resources" - environmental equity considers the present
generation under an obligation to account for long-term impacts of
activities, and to act to sustain the global environment and resource
base for future generations. Pollution control and resource management laws may be assessed against this principle.
Transboundary responsibility
Defined
in the international law context as an obligation to protect one's own
environment, and to prevent damage to neighboring environments, UNEP
considers transboundary responsibility at the international level as a
potential limitation on the rights of the sovereign state. Laws that act to limit externalities imposed upon human health and the environment may be assessed against this principle.
Public participation and transparency
Identified
as essential conditions for "accountable governments,... industrial
concerns," and organizations generally, public participation and
transparency are presented by UNEP as requiring "effective protection of
the human right to hold and express opinions and to seek, receive and
impart ideas,... a right of access to appropriate, comprehensible and
timely information held by governments and industrial concerns on
economic and social policies regarding the sustainable use of natural
resources and the protection of the environment, without imposing undue
financial burdens upon the applicants and with adequate protection of
privacy and business confidentiality," and "effective judicial and
administrative proceedings." These principles are present in environmental impact assessment, laws requiring publication and access to relevant environmental data, and administrative procedure.
Precautionary principle
One of the most commonly encountered and controversial principles of environmental law, the Rio Declaration formulated the precautionary principle as follows:
- In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where 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.
The principle may play a role in any debate over the need for environmental regulation.
Prevention
- The concept of prevention . . . can perhaps better be considered an overarching aim that gives rise to a multitude of legal mechanisms, including prior assessment of environmental harm, licensing or authorization that set out the conditions for operation and the consequences for violation of the conditions, as well as the adoption of strategies and policies. Emission limits and other product or process standards, the use of best available techniques and similar techniques can all be seen as applications of the concept of prevention.
Polluter pays principle
The polluter pays principle stands for the idea that "the
environmental costs of economic activities, including the cost of
preventing potential harm, should be internalized rather than imposed
upon society at large." All issues related to responsibility for cost for environmental remediation and compliance with pollution control regulations involve this principle.
Theory
Environmental
law is a continuing source of controversy. Debates over the necessity,
fairness, and cost of environmental regulation are ongoing, as well as
regarding the appropriateness of regulations vs. market solutions to
achieve even agreed-upon ends.
Allegations of scientific uncertainty fuel the ongoing debate over greenhouse gas regulation, and are a major factor in debates over whether to ban particular pesticides.
In cases where the science is well-settled, it is not unusual to find
that corporations intentionally hide or distort the facts, or sow
confusion.
It is very common for regulated industry to argue against environmental regulation on the basis of cost. Difficulties arise in performing cost-benefit analysis of environmental issues. It is difficult to quantify
the value of an environmental value such as a healthy ecosystem, clean
air, or species diversity. Many environmentalists' response to pitting
economy vs. ecology is summed up by former Senator and founder of Earth Day Gaylord Nelson, "The economy is a wholly owned subsidiary of the environment, not the other way around." Furthermore, environmental issues are seen by many as having an ethical or moral
dimension, which would transcend financial cost. Even so, there are
some efforts underway to systemically recognize environmental costs and
assets, and account for them properly in economic terms.
While affected industries spark controversy in fighting
regulation, there are also many environmentalists and public interest
groups who believe that current regulations are inadequate, and advocate
for stronger protection. Environmental law conferences - such as the annual Public Interest Environmental Law Conference in Eugene, Oregon - typically have this focus, also connecting environmental law with class, race, and other issues.
An additional debate is to what extent environmental laws are
fair to all regulated parties. For instance, researchers Preston Teeter
and Jorgen Sandberg highlight how smaller organizations can often incur
disproportionately larger costs as a result of environmental
regulations, which can ultimately create an additional barrier to entry
for new firms, thus stifling competition and innovation.
Around the world
International law
Global and regional environmental issues are increasingly the subject of international law.
Debates over environmental concerns implicate core principles of
international law and have been the subject of numerous international
agreements and declarations.
Customary international law
is an important source of international environmental law. These are
the norms and rules that countries follow as a matter of custom and they
are so prevalent that they bind all states in the world. When a
principle becomes customary law is not clear cut and many arguments are
put forward by states not wishing to be bound. Examples of customary
international law relevant to the environment include the duty to warn
other states promptly about icons of an environmental nature and
environmental damages to which another state or states may be exposed,
and Principle 21 of the Stockholm Declaration ('good neighbourliness' or
sic utere).
Numerous legally binding international agreements
encompass a wide variety of issue-areas, from terrestrial, marine and
atmospheric pollution through to wildlife and biodiversity protection.
International environmental agreements are generally multilateral (or sometimes bilateral) treaties (a.k.a. convention, agreement, protocol, etc.). Protocols
are subsidiary agreements built from a primary treaty. They exist in
many areas of international law but are especially useful in the
environmental field, where they may be used to regularly incorporate
recent scientific knowledge. They also permit countries to reach
agreement on a framework that would be contentious if every detail were
to be agreed upon in advance. The most widely known protocol in
international environmental law is the Kyoto Protocol, which followed from the United Nations Framework Convention on Climate Change.
While the bodies that proposed, argued, agreed upon and
ultimately adopted existing international agreements vary according to
each agreement, certain conferences, including 1972's United Nations Conference on the Human Environment, 1983's World Commission on Environment and Development, 1992's United Nations Conference on Environment and Development and 2002's World Summit on Sustainable Development have been particularly important. Multilateral environmental agreements
sometimes create an International Organization, Institution or Body
responsible for implementing the agreement. Major examples are the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and the International Union for Conservation of Nature (IUCN).
International environmental law also includes the opinions of
international courts and tribunals. While there are few and they have
limited authority, the decisions carry much weight with legal
commentators and are quite influential on the development of
international environmental law. One of the biggest challenges in
international decisions is to determine an adequate compensation for
environmental damages. The courts include the International Court of Justice (ICJ), the international Tribunal for the Law of the Sea (ITLOS), the European Court of Justice, European Court of Human Rights and other regional treaty tribunals.
Africa
According to the International Network for Environmental Compliance and Enforcement (INECE), the major environmental issues in Africa are “drought and flooding, air pollution, deforestation, loss of biodiversity, freshwater availability, degradation of soil and vegetation, and widespread poverty.” The U.S. Environmental Protection Agency (EPA) is focused on the “growing urban and industrial pollution, water quality, electronic waste and indoor air from cookstoves.” They hope to provide enough aid on concerns regarding pollution before
their impacts contaminate the African environment as well as the global
environment. By doing so, they intend to “protect human health,
particularly vulnerable populations such as children and the poor.” In order to accomplish these goals in Africa, EPA programs are focused
on strengthening the ability to enforce environmental laws as well as
public compliance to them. Other programs work on developing stronger
environmental laws, regulations, and standards.
Asia
The Asian
Environmental Compliance and Enforcement Network (AECEN) is an agreement
between 16 Asian countries dedicated to improving cooperation with
environmental laws in Asia. These countries include Cambodia, China,
Indonesia, India, Maldives, Japan, Korea, Malaysia, Nepal, Philippines,
Pakistan, Singapore, Sri Lanka, Thailand, Vietnam, and Lao PDR.
European Union
The European Union
issues secondary legislation on environmental issues that are valid
throughout the EU (so called regulations) and many directives that must
be implemented into national legislation from the 28 member states
(national states). Examples are the Regulation (EC) No. 338/97 on the
implementation of CITES; or the Natura 2000 network the centerpiece for
nature & biodiversity policy, encompassing the bird Directive
(79/409/EEC/ changed to 2009/147/EC)and the habitats directive
(92/43/EEC). Which are made up of multiple SACs (Special Areas of
Conservation, linked to the habitats directive) & SPAs (Special
Protected Areas, linked to the bird directive), throughout Europe.
EU legislation is ruled in Article 249 Treaty for the Functioning
of the European Union (TFEU). Topics for common EU legislation are:
- Climate change
- Air pollution
- Water protection and management
- Waste management
- Soil protection
- Protection of nature, species and biodiversity
- Noise pollution
- Cooperation for the environment with third countries (other than EU member states)
- Civil protection
Middle East
The U.S. Environmental Protection Agency is working with countries in the Middle East
to improve “environmental governance, water pollution and water
security, clean fuels and vehicles, public participation, and pollution
prevention.”
Oceania
The main concerns on environmental issues in the Oceanic Region are “illegal releases of air and water pollutants, illegal logging/timber trade, illegal shipment of hazardous wastes, including e-waste and ships slated for destruction, and insufficient institutional structure/lack of enforcement capacity”. The Secretariat of the Pacific Regional Environmental Program (SPREP)
is an international organization between Australia, the Cook Islands,
FMS, Fiji, France, Kiribati, Marshall Islands, Nauru, New Zealand, Niue,
Palau, PNG, Samoa, Solomon Island, Tonga, Tuvalu, USA, and Vanuatu. The
SPREP was established in order to provide assistance in improving and
protecting the environment as well as assure sustainable development for
future generations.
Australia
The Environment Protection and Biodiversity Conservation Act 1999
is the center piece of environmental legislation in the Australian
Government. It sets up the “legal framework to protect and manage
nationally and internationally important flora, fauna, ecological
communities and heritage places”.
It also focuses on protecting world heritage properties, national
heritage properties, wetlands of international importance, nationally
threatened species and ecological communities, migratory species,
Commonwealth marine areas, Great Barrier Reef Marine Park, and the environment surrounding nuclear activities. Commonwealth v Tasmania (1983), also known as the "Tasmanian Dam Case", is the most influential case for Australian environmental law.
Brazil
The Brazilian government created the Ministry of Environment
in 1992 in order to develop better strategies of protecting the
environment, use natural resources sustainably, and enforce public
environmental policies. The Ministry of Environment has authority over
policies involving environment, water resources, preservation, and
environmental programs involving the Amazon.
Canada
The Department of the Environment Act establishes the Department of the Environment in the Canadian government as well as the position Minister of the Environment.
Their duties include “the preservation and enhancement of the quality
of the natural environment, including water, air and soil quality;
renewable resources, including migratory birds and other non-domestic
flora and fauna; water; meteorology;" The Environmental Protection Act
is the main piece of Canadian environmental legislation that was put
into place March 31, 2000. The Act focuses on “respecting pollution
prevention and the protection of the environment and human health in
order to contribute to sustainable development." Other principle federal statutes include the Canadian Environmental Assessment Act, and the Species at Risk Act.
When provincial and federal legislation are in conflict federal
legislation takes precedence, that being said individual provinces can
have their own legislation such as Ontario's Environmental Bill of Rights, and Clean Water Act.
China
According to the U.S. Environmental Protection Agency,
"China has been working with great determination in recent years to
develop, implement, and enforce a solid environmental law framework.
Chinese officials face critical challenges in effectively implementing
the laws, clarifying the roles of their national and provincial
governments, and strengthening the operation of their legal system." Explosive economic and industrial growth in China has led to significant environmental degradation, and China is currently in the process of developing more stringent legal controls. The harmonization of Chinese society and the natural environment is billed as a rising policy priority.
Ecuador
With the enactment of the 2008 Constitution, Ecuador became the first country in the world to codify the Rights of Nature. The Constitution, specifically Articles 10 and 71-74, recognizes the inalienable rights of ecosystems
to exist and flourish, gives people the authority to petition on the
behalf of ecosystems, and requires the government to remedy violations
of these rights. The rights approach is a break away from traditional
environmental regulatory systems, which regard nature as property and
legalize and manage degradation of the environment rather than prevent
it.
The Rights of Nature articles in Ecuador's constitution are part
of a reaction to a combination of political, economic, and social
phenomena. Ecuador's abusive past with the oil industry, most famously the class-action litigation against Chevron, and the failure of an extraction-based economy and neoliberal reforms to bring economic prosperity to the region has resulted in the election of a New Leftist regime, led by President Rafael Correa,
and sparked a demand for new approaches to development. In conjunction
with this need, the principle of "Buen Vivir," or good living—focused on
social, environmental and spiritual wealth versus material
wealth—gained popularity among citizens and was incorporated into the
new constitution.
The influence of indigenous groups, from whom the concept of
"Buen Vivir" originates, in the forming of the constitutional ideals
also facilitated the incorporation of the Rights of Nature as a basic
tenet of their culture and conceptualization of "Buen Vivir."
Egypt
The Environmental Protection Law
outlines the responsibilities of the Egyptian government to
“preparation of draft legislation and decrees pertinent to environmental
management, collection of data both nationally and internationally on
the state of the environment, preparation of periodical reports and
studies on the state of the environment, formulation of the national
plan and its projects, preparation of environmental profiles for new and
urban areas, and setting of standards to be used in planning for their
development, and preparation of an annual report on the state of the
environment to be prepared to the President."
India
In India, Environmental law is governed by the Environment Protection Act, 1986.
This act is enforced by the Central Pollution Control Board and the
numerous State Pollution Control Boards. Apart from this, there are also
individual legislations specifically enacted for the protection of
Water, Air, Wildlife, etc. Such legislations include :-
- The Water (Prevention and Control of Pollution) Act, 1974
- The Water (Prevention and Control of Pollution) Cess Act, 1977
- The Forest (Conservation) Act, 1980
- The Air (Prevention and Control of Pollution) Act, 1981
- Air (Prevention and Control of Pollution) (Union Territories) Rules, 1983
- The Biological Diversity Act, 2002 and the Wild Life Protection Act, 1972
- Batteries (Management and Handling) Rules, 2001
- Recycled Plastics, Plastics Manufacture and Usage Rules, 1999
- The National Green Tribunal established under the National Green Tribunal Act of 2010 has jurisdiction over all environmental cases dealing with a substantial environmental question and acts covered under the Water (Prevention and Control of Pollution) Act, 1974.
- Water (Prevention and Control of Pollution) Cess Rules, 1978
- Ganga Action Plan, 1986
- The Forest (Conservation) Act, 1980
- Wildlife protection Act, 1972
- The Public Liability Insurance Act, 1991 and the Biological Diversity Act, 2002. The acts covered under Indian Wild Life Protection Act 1972 do not fall within the jurisdiction of the National Green Tribunal. Appeals can be filed in the Hon'ble Supreme Court of India.
- Basel Convention on Control of TransboundaryMovements on Hazardous Wastes and Their Disposal, 1989 and Its Protocols
- Hazardous Wastes (Management and Handling) Amendment Rules, 2003
Japan
The Basic Environmental Law is the basic structure of Japan’s environmental policies replacing the Basic Law for Environmental Pollution Control and the Nature Conservation Law.
The updated law aims to address “global environmental problems, urban
pollution by everyday life, loss of accessible natural environment in
urban areas and degrading environmental protection capacity in forests
and farmlands.”
The three basic environmental principles that the Basic
Environmental Law follows are “the blessings of the environment should
be enjoyed by the present generation and succeeded to the future
generations, a sustainable society should be created where environmental
loads by human activities are minimized, and Japan should contribute
actively to global environmental conservation through international
cooperation.”
From these principles, the Japanese government have established policies
such as “environmental consideration in policy formulation,
establishment of the Basic Environment Plan which describes the
directions of long-term environmental policy, environmental impact
assessment for development projects, economic measures to encourage
activities for reducing environmental load, improvement of social
infrastructure such as sewerage system, transport facilities etc.,
promotion of environmental activities by corporations, citizens and
NGOs, environmental education, and provision of information, promotion
of science and technology."
New Zealand
The Ministry for the Environment and Office of the Parliamentary Commissioner for the Environment were established by the Environment Act 1986.
These positions are responsible for advising the Minister on all areas
of environmental legislation. A common theme of New Zealand’s
environmental legislation is sustainably managing natural and physical
resources, fisheries, and forests. The Resource Management Act 1991
is the main piece of environmental legislation that outlines the
government’s strategy to managing the “environment, including air, water
soil, biodiversity, the coastal environment, noise, subdivision, and
land use planning in general.”
Russia
The Ministry of Natural Resources and Environment
of the Russian Federation makes regulation regarding “conservation of
natural resources, including the subsoil, water bodies, forests located
in designated conservation areas, fauna and their habitat, in the field
of hunting, hydrometeorology and related areas, environmental monitoring
and pollution control, including radiation monitoring and control, and
functions of public environmental policy making and implementation and
statutory regulation."
Vietnam
Vietnam is currently working with the U.S. Environmental Protection Agency on dioxin remediation and technical assistance in order to lower methane emissions.
In March 2002, the U.S and Vietnam signed the U.S.-Vietnam Memorandum
of Understanding on Research on Human Health and the Environmental
Effects of Agent Orange/Dioxin.
