Journal of Environmental Policy & Planning

ISSN: 1523-908X (Print) 1522-7200 (Online) Journal homepage: http://www.tandfonline.com/loi/cjoe20

Baselining pollution: producing ‘natural soil’ for an

environmental risk assessment exercise in Chile

Sebastián Ureta

To cite this article: Sebastián Ureta (2017): Baselining pollution: producing ‘natural soil’ for an
environmental risk assessment exercise in Chile, Journal of Environmental Policy & Planning, DOI:
10.1080/1523908X.2017.1410430

To link to this article: https://doi.org/10.1080/1523908X.2017.1410430

Published online: 29 Nov 2017.

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 JOURNAL OF ENVIRONMENTAL POLICY & PLANNING, 2017
https://doi.org/10.1080/1523908X.2017.1410430

Baselining pollution: producing ‘natural soil’ for an environmental risk

assessment exercise in Chile
Sebastián Ureta
Departamento de Sociología, Universidad Alberto Hurtado, Santiago, Chile

ABSTRACT ARTICLE HISTORY

Baselines are used extensively in environmental regulation and usually serve as a Received 5 April 2017
proxy of a certain ‘natural’ environment upon which the potential toxicity of a Accepted 23 November 2017
certain substance is assessed. However, there is nothing natural or automatic about
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KEYWORDS
the process via which baselines are created. Most of the time they are produced Baselines; pollution;
through a series of baselining practices in which heterogeneous entities are environmental risk
assembled in highly idiosyncratic ways, a process always crisscrossed by technical, assessment; valuation;
political and ethical issues. This particular paper, based on material collected while traceability
observing an environmental risk assessment exercise carried out in an abandoned
mining waste dump in northern Chile, looks at two kinds of practices that are
especially salient. On the one hand, there is the recognition of a certain
‘naturalness’ of a particular piece of soil, a process in which visual valuation
processes play a central role. On the other hand, there is the creation of
‘traceability,’ through which the particular extracted sample is linked to a series of
entities, gaining in the process validity as representative of the ‘natural soil’ existing
in this particular patch. In the conclusion, both operations will be connected with
different difficulties that current environmental regulation faces in dealing with
polluted sites such as the one under study.

Introduction
For a number of public agencies throughout the world, environmental risk assessments (ERA) have become in
recent decades the de facto standard for dealing with environmental issues related to toxics and pollution. Orig-
inating in the U.S. in the 1970s (for an historical overview see Boudia, 2014), the formal aim of this method-
ology is ‘to estimate and characterize the probability that harm to human health or ecosystems will occur from
exposure to substances in the environment’ (Holifield, 2012, p. 594). The calculation of this probability rests on
what is known as the source–pathway–target framework, or the assumption that for pollution to occur it is not
only necessary to have a polluting entity (a source) but the entity must also have a way to travel (a pathway) to
certain receptor(s) causing them certain harm (a target). Therefore, pollution for ERA is always a relational
effect, never the property of a certain entity.
Although originally the global spread of these notions appeared to open up promising paths for dealing with
pollution-related issues more effectively, especially in countries lacking any other form of environmental regu-
lation, in practice the concrete application of ERA ‘has frequently been overshadowed by controversy and a
measure of disenchantment’ (Ball, 2002, p. 529). This situation is largely due to several problematic character-
istics usually associated with ERA implementations such as its technocratic character, the lack of consideration
of social issues and the problems of determining effects, among other factors (for an overview of the main cri-
tiques see Holifield, 2012, p. 594). As a consequence there is nowadays the widespread habit among actors from
academia and civil society to see ‘the existing politics of risk governance as somewhat fixed and unimpeachable’

CONTACT Sebastián Ureta sureta@uahurtado.cl

© 2017 Informa UK Limited, trading as Taylor & Francis Group
 2 S. URETA

(Reno, 2011, p. 524), little more than complex mechanisms through which ‘the risks … [pollutants] pose are
reified, isolated, and reduced as problems to be managed, remediated, and mitigated by experts and their
actions controlled and supported by quantification and fancy computational modeling’ (Little, 2010, p. 51).
This perception has motivated an ample research agenda among scholars and activists on ERA: its weak-
nesses, necessary corrections and (potential) alternatives. Looking to complement the mainstream emphasis
on affected communities, a growing area of interest for these endeavors has been ‘to understand the concept
of risk as it is defined and used by practitioners, and then to recognize the role risk plays in transforming
the collective’ (November, 2008, p. 1526). The focus here has been on analyzing the complex relations between
pollutants and human bodies (for an overview see Checker, 2007). This research has produced a rich body of
detailed case studies, usually showing how ‘the facts produced through risk assessment emerge not through the
neutral, transparent application of the scientific method, but instead through a set of often messy practices and
interactions’ (Holifield, 2012, p. 595). However, the downside of this prominent focus is that it does not really
consider as a proper research topic another set of relations that are key for ERA processes: the relations between
potential pollutants and a certain ‘natural’ baseline condition.
In formal terms baselines can be understood as the ‘documented or reconstructed historic state of being for a
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particular aspect of nature – an ecosystem, a place, a watershed’ (Craig, 2014, p. 87). So, assembling a baseline is
always an attempt to enact a certain ‘natural state’ to which the polluted entity will be compared. The origin of
the concept in pollution-related issues is manifold, although there are two areas in which it occupies an
especially salient place: environmental law and ecological restoration. From a legal point of view, the concept
is intimately related with the notion of environmental harm, given that ‘the concept of harm necessarily
requires a comparison with some normatively superior baseline condition’ (Aagaard, 2011, p. 1507). In the
case of ecological restoration the situation is similar, given that ‘the first hurdle in recognizing change in integ-
rity is the selection of a benchmark state against which other states can be compared’ (Angermeier & Karr, 1994,
p. 693). In both cases, baselines appear as a device that allows the actors involved ‘to identify changes that have
occurred in a natural system of interest and to set … goals for that system’ (Craig, 2014, p. 87). Besides its prac-
tical roles, the making of baselines has a strictly political role; helping to demarcate a space that is strictly ‘scien-
tific’ in the usual contemptuous deployment of environmental regulation, especially about controversial issues
(Barandarian, 2015). All in all, the enactment of baselines serves as a compulsory stage for several different
kinds of intervention in pollution-related issues such as ERA, allowing the actors involved to establish, in con-
trast, the characteristics of the issue and the best way to deal with it.
In recent years, the processes through which baselines are assembled, and even their very existence, have
come under sustained criticisms for a number of reasons. In the first place, several authors have raised criti-
cisms about the assumptions underlying baselines. Chief among them is the notion of ‘naturalness’ or the inter-
related belief in the existence of
(1) … a state of the environment that existed at some previous point in time (i.e. authentic or original nature), (2) it is a state
of the environment that exists in the absence of human modification (i.e. pristine or wild nature), and (3) it is associated with
a slow, or ‘natural,’ rate of change. (Hull & Robertson, 2000, p. 100)

Such naturalness, a remnant of the modernist separation between humans and nature, gives baselines an unrea-
listic foundation due to the practical impossibility of enacting a version of a ‘pristine’ environment in which no
human presence is detected.
Furthermore, a second set of queries deal with baselines’ subjective/normative character. Derived from the
well-known concept of the ‘shifting baseline syndrome’ (Pauly, 1995), some authors have argued that a ‘deeper
difficulty with baselines is that they insert normativity into putatively descriptive claims. Baselines operate nor-
matively to the extent that they compete for a default normative position’ (Aagaard, 2011, p. 1523). Thus in
practice baselines, rather than being objective, function as norms: ‘they are both descriptive (scientific) and pre-
scriptive (political); they are used to describe what is and to prescribe what ought to be’ (Hull & Robertson,
2000, p. 98).
Finally, and on methodological grounds, several questions have been raised about the sources from which base-
lines are constructed. On the one hand, it is argued that when using historical records the actors involved ‘too often
 JOURNAL OF ENVIRONMENTAL POLICY & PLANNING 3

adopt historical baseline data uncritically, … without closely examining the manner in which these accounts were
recorded, transmitted, and interpreted by past generations’ (Alagona, Sandlos, & Wiersma, 2012, p. 50). On the
other hand, when trying to build baselines out of reference sites there are several complex (but often un-proble-
matized) issues regarding the match between two (or more) sites when designing one of them as the baseline,
especially regarding their supposedly shared relevant ecological components (White & Walker, 1997).
Such criticisms, however, have not been accompanied by a strong research agenda on baseline production in
the environmental humanities and social sciences. On the contrary, to date ‘there have been few attempts to
document the history of efforts to establish ecological baselines for science and conservation’ (Alagona et al.,
2012, p. 51). Such inattention has been especially damning for our understanding of processes such as ERA
in which entities like ‘nature’ and even ‘society’ exist mostly through baselines. After all, in ERA ‘only what
is considered as being of value can be at risk’ (Corvellec, 2010, p. 145). Polluted entities cannot be risky as
such. It is only through establishing connections with a certain kind of baseline that they become a subject
of risk. So if we do not have insights into how such baselines are produced, we are blind to a key aspect of
how pollution-related regulation works.
In order to help fill this void, this paper aims to describe the practices and devices involved in setting up a
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baseline in one particular application of the ERA framework in Chile,1 using a science and technology studies
conceptual framework. Based on these elements, I am going to call this process baselining, understanding it as
the set of practices through which the human and nonhuman participants in an environmental issue establish a
baseline. To my current knowledge, there has been no research on baselining as a practical accomplishment, as
something that is not only a recourse to history and/or norms but also a compulsory set of practices and
materials that actors involved in environmental regulation have to accomplish in order to deal with pollution,
usually involving a large variety of devices, practices and forms of knowledge and never a stranger to contro-
versies, messes and power struggles.

Mining waste and polluted soils in Chile

Since its partial nationalization in the 1970s, mining has been called ‘the wage of Chile’ given its substantial con-
tribution to the country’s GDP. However, there is something that this industry produces in a far larger amount
than the valued minerals that constitute this wage: waste. It is calculated that copper mining alone annually pro-
duces around 500 million tons of different wastes (99% of the total material extracted). A significant part of this
waste (usually reaching around 50%) is technically known as ‘tailings,’ or ‘the ground-up gangue from which
most of the valuable mineral(s) … has been removed’ (Lottermoser, 2007, p. 153). Besides gangue, tailings
include several chemical additives such as ‘organic chemicals, cyanide, sulfuric acid, and other reagents used
to achieve mineral recovery’ (p. 154), some of them highly toxic. Tailings are stored in large dams located in
the vicinity of mines, built to contain waste in an indefinite way. However, usually after the mines have closed
down these dams are abandoned, originating multiple forms of pollution. Given this, abandoned tailings dams
are regularly mentioned in discussions about the environmental liabilities of the mining industry in Chile.
After decades of inaction, since the turn of the century Chile’s Ministry for the Environment (MMA) has
started to address this issue. Taking USEPA guidelines as its inspiration, in 2012 it published a guide establish-
ing the procedures to identify and remediate soils polluted by mining activity (MMA, CORFO, & Fundación
Chile, 2012). In line with the ERA framework, the guide follows a source/pathway/target model in accordance
with which for pollution to occur there must be (1) a particular source of pollution, (2) a pathway allowing its
movement and (3) a receptor that gets affected by it.
With respect to the first step, a key activity is the determination of the presence and concentration of pol-
lutants in each particular site under study. This determination is only possible after contrasting the concen-
trations of the chemical components present on the site with a baseline, defined in the following terms:
The baseline or background is defined as the natural concentration of an element in soil that has not been altered by human
activity. Hence, a soil is free of contaminants when its [pollutants concentration] is located inside the baseline. … Back-
ground levels are highly dependent on the composition of the parent material and the mineralization process occurred
during soil formation, but also from the size of particles, clays, and contents of organic materials. As a consequence, the
 4 S. URETA

content of trace elements varies amply making inappropriate the use of generic background concentrations. In summary,
background values are characterized by a great spatial and temporal variability. … Given the above, background samples
should be extracted from zones without or with little anthropic intervention, that are located in the vicinity of the Ground
with Potential Presence of Pollutants, given that the geological processes involved in soil formation must be similar (MMA,
CORFO, & Fundación Chile, 2012, p. 59)

In the opening line, we can see naturalness at play right away in the demand that baselines should be made of
‘natural concentrations’ of elements, clearly establishing the baseline as a pristine space surrounding the pol-
luted entity. Then it is affirmed that for pollution to exist in a determinate soil its concentrations of certain
pollutants must be above the average level of the baseline. If the average concentrations of the components
under study on the site are equal or inferior to those of the baseline, then it is not considered polluted. Finally,
the quote states that, given that soil characteristics are highly site-specific, baselines should be made out of
samples extracted in ‘zones without or with little anthropic intervention’ located as close as possible to the
site under study.
This centrality of the setting of baselines took on the process was not strange. As studied by Barandarian
(2013, 2015), baselines constitute an especially central component of Chile’s environmental regulation processes.
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Since the establishment of the first environmental institutions after return of democracy in 1990, the notion of
building a grand national baseline in contrast to which evaluate all kinds of environmental issues has been a fan-
tasy keenly followed by state officials and environmentalist alike (Barandarian, 2013, pp. 93–94). As a conse-
quence, the making of baselines has never been seen as a secondary task; actually is one of the main ways in
which scientists can have an impact on environmental regulation in the country (Barandarian, 2015).
Starting from the recognition that ‘there is no detailed diagnosis in Chile about closed down industrial facili-
ties, something that makes practically unknown the quantity and characteristics of polluted soils and areas’
(MMA, 2011, p. 119), in 2011 the MMA hired Investigación sobre Suelos y Contaminación (ISC), a univer-
sity-based applied research lab, to carry out the first application of the guide by conducting a general assessment
and classification of a number of heavily polluted soils. The location chosen for this test was the Atacama region
in northern Chile, an area identified in previous research as containing the highest concentration of abandoned
tailings dumps in the country (JICA & SERNAGEOMIN, 2007). The final report of this project identified 23
sites with potential presence of pollutants, recommending ‘confirmatory research’ on the ones presenting the
highest concentration of pollutants. In 2014, the MMA again hired ISC to run the second phase of the process,
this time conducting a proper ERA of two tailings dumps located in the area, known as Aguada and Maleza,
identified in the previous project as the ones containing the highest concentration of several pollutants,
especially mercury and arsenic.
In order to carry out this task a team of chemists was sent to the site to collect soil samples in September
2014. I accompanied them in this process as a participant observer. Following the guide, a key task besides
taking tailings samples was to constitute a baseline sample in comparison with which their toxicity would be
determined. In this case, the baselining was formed from two interrelated sets of practices: valuating naturalness
and constituting traceability.

Valuating naturalness
We arrived at Aguada early in the morning and started taking soil samples right away. The tailings dump was a
rectangular-shaped flat and empty wasteland lying between a river and a chain of mountains. As a guideline for
the sampling process, we had a work plan stating the exact location where each one of the 80 tailings samples
must be extracted, including its coordinates and position on a map. In parallel it was indicated that 14 ‘background’
samples should be collected, 6 from each site and 2 from an inter-site location. However, the work plan included no
information whatsoever about where such samples should be taken or the characteristics of the ‘natural’ soil. Fol-
lowing the MMA guide, it was understood that the location and characteristics would be decided directly in the field.
Thus, at first, baselining entailed conducting site-specific valuation practices, looking at both the location
and the characteristics of the soil for it to be considered as a valid baseline sample, as could be seen in the fol-
lowing field notes:
 JOURNAL OF ENVIRONMENTAL POLICY & PLANNING 5

At midday, and after some discussion, we agreed to start taking baseline samples on the mountainside surrounding the site to
the south. Pedro (a chemist), Andres (a technician) and I drove until reaching the first slopes of the mountains in order to take
the samples. A couple of minutes later we stopped at our destination. ‘I think somewhere around here, don’t you?’ said Pedro
looking at the slope through the truck’s windshield. ‘Here?’ replied Andres in a doubtful tone, ‘Let’s walk a bit and take it further
up.’ Pedro looked at him. ‘But [samples taken] so high are not useful because, I think, the idea is to be as close as possible to the
tailings.’ Without more discussion, we got out of the truck. Outside it was quite windy and very hot. The slope going up to the
mountains was rocky and irregular, and with the exception of some dry brush it was almost completely devoid of vegetation.

After looking at it for a moment Pedro asked, ‘You don’t think these are tailings? No way, aren’t they? Or do you want to go
further up?’ After walking around a bit Andres commented that between some rocks a couple of meters away there seemed to
be some soil that could be useful as background. As we walked in this direction he asked, in a mockingly solemn tone, ‘Has
any man ever put their feet here?’

As can be seen from the notes, baselining at first became mostly the application by Pedro and Andres (and,
to a lesser degree, myself) of a ‘skilled’ (Grasseni, 2004) or ‘professional’ (Goodwin, 1994, 2000) vision, or a
‘socially situated, historically constituted body of practices through which the objects of knowledge which ani-
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mate the discourse of a profession are constructed and shaped’ (Goodwin, 1994, p. 606). What is key here is that
‘such vision is not a purely mental process, but instead something accomplished through the competent deploy-
ment in a relevant setting of a complex of situated practices’ (p. 626), a complex process that is full of ‘objects,
images and bodily patterns that structure and guide perception’ (Grasseni, 2004, p. 44).
However, and in contrast with the cases analyzed by Grasseni and Goodwin, in practicing this vision we had no
‘coding schemes’ (Goodwin, 1994) in the form of any kind of standard device to help us to classify and/or identify
‘natural’ soils in the area. Instead, we were forced to develop an emergent (and evanescent) frame of perception that
could help us visually identify the ‘right’ kind of location and soil to be extracted as a baseline sample.
In the later section of the notes, we can already see a first element of this frame, in the form of a visual assessment
of the site as a whole in search of the exact spot to take the samples. At first, when looking from inside the truck,
there is a disagreement between Pedro and Andres on the issue. While Andres does not seem convinced that they
should take the samples right at the beginning of the slope, Pedro is worried that going upwards would mean that
the necessary geological connection between the sample and the area in which the tailings are located would be lost.
However, the valuation changes when we get out of the truck and Pedro makes a direct visual appraisal of the soil
directly beneath us. As his words reveal, for him it looks almost exactly the same as the soil at the dump where we
have been taking samples the whole morning, raising the doubt whether this could be also tailings and not the
‘natural’ soil we were looking for. Natural soil should look different from the soil of the dump, although it is
not stated in which way. Thus, more than a pre-stated classificatory scheme, this initial visual valuation arises
from Pedro’s physical engagement with the dump and its surroundings on this particular day.
Some other elements of this valuation frame emerged once we started actually digging for samples:
We stopped at the site signaled by Andres and Pedro asked him to remove the most superficial layer of soil. In response,
Andres complained that by doing this ‘You are already interfering with the place!’ Pedro answered, ‘We have to remove the
superficial layer because it is everything that arrives [with the wind] … all this fine material is brought by erosion, maybe for
this reason [the right place] is further up, because here we have everything, everything is concentrated here.’ He stopped, taking
a good look at the soil Andres was removing. ‘In fact, look at how thin it is … ’

After discarding the sample we started walking again, further up the slope of the mountains. After a few minutes we reached
a small platform where soil was visible between the rocks and Andres started digging again.

P [Pedro]. It’s not very consolidated, it’s curious, I mean it seems like it was created with the same [material as the previous
place] … it seems that it’s not soil, it doesn’t look like soil, no.

A [Andres]. I was going to say the same thing, this is pure sand …

P. It surprises me how sandy it is … but the tailings, strictly speaking, where are they? [He looks to the plain, trying to identify
where the tailings end] they reach those trees, then this may be as well … this looks different, can you see? Do you know what?
Maybe there [he points to a small gorge further up], on this part of the slope … there has already been a lot of interference here
… further up could be the spot, because particles do not continue further up … let’s continue up and take it right there, I like it!
 6 S. URETA

We continued further up the slope, advancing slowly because the terrain is very irregular and full of stones. Finally we
arrived at a new site well up the slope [Figure 1] where Pedro and Andres moved a rock sitting in the middle of a small
depression, revealing a dark and compact soil. Upon sighting it, Pedro exclaimed in a triumphant tone, ‘Here we have
soil!’ Andres started digging and putting the contents extracted with the shovel into a plastic bag.

This extract shows us more clearly the kind of qualities that ‘natural’ soils must have. The main issue
seemed to be to find soils that visually looked different from the ones we had seen in the morning.
The difference was constructed by adding several things to the process. At first, in Pedro’s words, we can
see the existence of a particular ‘frame of perception’ (Grasseni, 2004) guiding the way he sees our surround-
ing environment in the form of a theory about erosion in the area and the characteristics of eroded tailings.
In accordance with this frame, tailings are assumed to be quite mobile due to the strong winds that charac-
terize the area. After being established, the frame starts ‘actively constrain[ing], shap[ing] and allow[ing]
the perception, conceptualisation and computation of [our surrounding] reality’ (Grasseni, 2004, p. 47)
by making soils that look ‘thin,’ ‘sandy’ or ‘not very consolidated’ undesirable as places to take baseline
samples.
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This is what we found at the first place where we dug: soils appearing solely as ‘fine material’ and so, for
Pedro, having a heightening chance of having been carried by the wind from somewhere else, at worst the
nearby tailings dump. At the second site, the situation was more or less the same, with soils appearing again
as ‘sandy’ and ‘not very consolidated,’ forcing Pedro to make a panoramic visual evaluation concerning the like-
lihood of them having been carried over from the tailings dump by strong winds, recognizing the difficulties of
establishing a demarcation between the dump and its environment.
Finally it was decided to move upwards, given that ‘particles do not continue further up,’ adding then a par-
ticular agency of tailings to the perceptual frame. In this third location, Pedro and Andres agreed on their valua-
tions about the kind of entity they were looking for, a darker and compact soil that seemed much closer to their
notions about how a ‘natural’ soil of the area should look. The presence of a rock above the selected patch is key
to this recognition by adding a layer of seemingly undisturbed naturalness to the soil beneath it.

Figure 1. Taking background samples in Aguada. Source: the author.

 JOURNAL OF ENVIRONMENTAL POLICY & PLANNING 7

Thus visual valuations of naturalness were at the very center of the practices through which certain grams of
local soil became the key material components of this particular baseline. These valuations were formed by a
heterogeneous array of practices and devices, such as affective perception of the environment, a frame of per-
ception based on a theory about the dynamics of local tailings, a classification scheme of soils (clayey, sandy,
compact, dark), relations with other entities (such as the rock above the selected patch) and, no less important,
calls for authority. Occupying prominent places among these entities were notions about the need for natural-
ness demanded by the guide, or a pristine character of the sampled soil, that in practice translated into the
search for a site (mountainside) and kind of soil (dark and compact) that appeared to both Pedro and Andres
as different as possible from the tailings dumps, ensuring in this way its inclusion as representative of the natu-
ral conditions of the area.
In all, visual valuation practices occupied a central position in this particular ERA process, confirming Beck’s
(2006, p. 332) affirmation that ‘without techniques of visualization … risks are nothing at all’. In order to exist,
toxicity needs to be made visible. Such visibility, following the ERA framework, emerges in contrast with certain
baseline conditions that are visually assessed as not being polluted, as seen in this section. However, no matter
their centrality, visualizations alone would not produce a valid baseline. In parallel a further process must be
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produced: traceability.

Assembling traceability
Putting a few hundred grams of soil into a plastic bag was only the start of the process of producing a valid
baseline. Baselines are never merely samples, grams of soil in this case, but they must also make a persistent
statement about their validity as such. In particular, they must be able to effectively mobilize to all the different
sites involved in the ERA process the original valuations about the correct ‘naturalness’ of these grams of soil, as
seen in the previous section. They must remain a valid spokesperson of this natural soil, especially in sites
located far away from Aguada and Maleza and without the constant assistance of Pedro and Andres in remem-
bering the reasons why these samples were selected among so many other possibilities. Given that these samples
in particular were to be shipped to ISC’s labs in Santiago located 800 kilometers south, to become proper base-
lines their naturalness had to become traceable to their points of origins all along the way.
Constituting such traceability is not given or automatic. On the contrary, an ‘infrastructure of referentiality’
(Latour, 1999) must be assembled along with each soil sample in order to make them traceable at every point of
their movement from the field to the lab. Such traceability had to be assembled in several locales, starting
directly in the field on the very same day that the samples were taken. Most of the practices and devices involved
in the process converged towards one particular device that served as the main technology of traceability behind
the whole process: the ‘cadena de custodia’ (chain of custody).
Widely used in legal processes, chains of custody are usually defined as ‘the entire sequence of agents and
practices involved in the identification, collection, transportation, storage, and handling of evidence’ (Lynch,
Cole, McNally, & Jordan, 2010, p. 114). Most of the time chains of custody are composed of an ample het-
erogeneity of entities, from numbers to material devices, also including the practices and human actors
involved in mobilizing samples of evidence from one place to another. In this regard, it quite commonly
‘becomes impossible to specify in advance just which “elements” make up the chain of custody’ (p. 135).
What is taken to be a valid component of a chain of custody changes all the time, frequently involving enti-
ties that were unaccounted for (and even actively forbidden) at the beginning of the process, a multiplicity
that was quite present in this case.
In arguing about chains of custody, the members of the research team frequently used a reverential tone, even a
fearful one, implying that any kind of breach of the chain would mean that the whole process would be tarnished,
possibly forcing them to start all over again. For this reason, the ‘continuity’ of the samples’ chain of custody was
frequently mentioned as one of the main tasks of the process, the only way in which they could prove the sample
collecting had been done in the ‘correct’ way. However, when I asked them, puzzled by a term that I have never
heard before, what the chain of custody actually was, I received several answers. For some of them it was a filled-
out log, for some a particular kind of label attached to the bags with samples, while for others it was a set of pictures
 8 S. URETA

taken in the field. In the end, all these entities constituted the chain of custody, the assemblage through which a
bag with a few hundred grams of soil was to be accepted in several locales as the valid spokesperson of the ‘natural’
soil of a particular location in northern Chile.
A first key component of the chain of custody was a form called ‘Registro de Muestreo’ (Sampling Registry),
including information such as the location of the field, the date of collection and type (soil, sediment, water,
etc.) of the samples, a sample ID and coordinates, among others. Overall, the registry functioned as a meeting
point of several ‘coding schemes’ (Goodwin, 1994) that allowed the traceability of the samples to be established.
For this reason, Pedro and Marcela, the two leading chemists in the group, carried it everywhere. Once the site
for a sample was selected, the first activity was to add all the information about it to the log. Without a complete
log recording, all the samples taken with their ID and coordinates, the chain of custody would be broken at its
very first link.
This practice went hand in hand with a second key activity: labeling the bags containing the samples. With-
out correct labeling, the sample, whether tailings or backgrounds, simply does not exist. After all, during most of
their movement, ‘the samples will remain attached to their original context solely by the fragile link of the num-
bers inscribed in black felt-tip pen on the little transparent bags’ (Latour, 1999, p. 46). For this reason, this task
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was given special care.

To correctly create these labels in the case of baseline samples was not easy, as became clear on the afternoon
of our third day in the field.
We were in Maleza, late in the afternoon. The site was much smaller than Aguada, an empty flatland just a hundred meters
long by fifty meters wide, surrounded by agricultural fields. We had been collecting tailings samples for most of the day and
now we had to collect background samples, our last task of the day. After searching for a while we agreed that a hill located at
the back of the tailings dump appeared to be a valid ‘natural’ location, so we start taking samples there. My duty during most
of the day had been to take photographs and write down the labels to be attached to the bags containing the soil samples. At
one point I asked Pedro how I should label the next sample. He said that ‘this would be VB7, instead of AGU it’s MAL …

VB7 … S … we are going to follow the correlative [numbering], then we put 700, wait, let me think … we said that we were
going to have 80 samples [of tailings], right? We have also 8 duplicates, its 88, plus the 6 baselines [ from Aguada] its 94,
right? This would be 95’ He starts writing something in the field log but after a couple of seconds stops and adds, in a doubtful
tone, ‘Wait a bit, let’s label this one [differently], let’s put MAL VB S 01 through 07 and we just erase the rest, because we need
the baseline value … because I don’t know if Marcela … if I’m following the correlative [numbering] with the water samples
that we took first, and we need the baseline labels to be [sequential]’.

The label was composed of several units, each one connecting the sample with a particular frame of refer-
ence. The first one (MAL) refers to the place where the sample was taken, Maleza in this case. The second (VB)
indicates that the sample is a ‘Valor de Base’ or baseline sample. The third (S) indicates that the sample is soil.
Finally, the last one (95 at first and 07 at the end) refers to the location of the sample in relation with all the
samples taken during fieldwork. In all, the label establishes the chain connecting each particular sample to sev-
eral other entities: the place, the notion of a baseline, the need to collect soil samples and all the other collected
samples. Each one of them constitutes a link in the chain of custody, a materialization of the traceability that
will make each sample credible once in the lab in Santiago.
However, to be able to do this work the label needed to be placed within a correlative numbering sequence
connecting it with all the other samples collected during fieldwork. If this sequence is not respected they run the
risk of losing the reversibility of the chain, a key component of its traceability, as Latour emphasizes when ana-
lyzing a similar case in Brazil:
an essential property of this chain is that it must remain reversible. The succession of stages must be traceable, allowing for
travel in both directions. If the chain is interrupted at any point, it ceases to transport truth-ceases, that is, to produce, to
construct, to trace, and to conduct it. (1999, p. 69)

A chain of custody that was not respected at every step would jeopardize the traceability of the process.
In the passage above, the risk of losing the correlative numbering was related to the fact that we had been
working in two teams, carrying out the same kind of tasks. This division allowed us to make quick progress but
came at a cost of an increased risk of making a mess of the labeling, as the two groups could use the same label
 JOURNAL OF ENVIRONMENTAL POLICY & PLANNING 9

for different samples or create a non-correlative sequence. In order to avoid such an outcome Pedro and Mar-
cela, the heads of each group, met regularly to coordinate, checking which points they had already done, divid-
ing the ones still remaining and assigning the right kind of label to each of them.
This coordination had been easy for the tailings samples, given that each one had a location and a code
assigned in advance. However, in the case of baseline samples, the situation was not so straightforward. As
seen above, these samples had no extraction coordinates assigned and did not even have a general code.
Such indeterminacy became a problem when introducing them into the numbering of the chain of custody.
With the first bunch of samples, which came from Aguada, Pedro decided to include the background samples
right after the 40 tailings samples collected there, starting at the number 41 and ending at 47. As seen above, at
first he had the intention of doing the same with Maleza samples, assigning the first one the number 95 and so
on. However, earlier in the day he had a discussion with Marcela about this issue, in which she objected to this
inclusion, arguing that background samples should have their own chain of custody. The matter had not been
solved, but Pedro had become doubtful about his method, so at the end he decided to assign temporary labels to
the samples, to be replaced later by the definitive ones, in order not to risk having a bunch of invalid samples
back in Santiago.
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Finally, a third component of the chain of custody were two kinds of pictures that had to be attached to the
fieldwork dossier to be sent to both the ISC and the MMA. I was put in charge of this task. The first ones
(Figure 2) were a composite formed by (1) the labeled plastic bag containing the sample, (2) a small whiteboard
on which the label of the sample was written down, (3) an electronic thermometer showing the soil temperature
at the sampling point and (4) the hole were the sample was extracted.
The main function of this image was to make visible the connection between the key components of the
baseline: the hole in the ‘natural’ soil where the sample has been extracted, the bag containing the sample
and the label. The overall purpose of the picture was to provide, in a similar way to that of the case analyzed
by Goodwin, ‘a texture of intelligibility that unifies disparate … [elements] into a coherent object. These …
[elements] in turn provide evidence for the existence in this patch of dirt of an instance of the object proposed
by the category’ (Goodwin, 1994, p. 610).

Figure 2. Example of the sample composite. Source: the author.

 10 S. URETA
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Figure 3. Example of ‘referent’ picture. Source: the author.

The second kind of image that each sample had to include had the objective, in Pedro’s words, of ‘showing
where [the sampling point] is located and all this … we need to have a referent.’ As can be seen in Figure 3, the
purpose is to represent the particular landscape in which each sample was taken, especially stressing its ‘natural’
character. In the search for this effect, I was instructed to take the picture a couple of meters away from the
actual sample point, hopefully including several ‘natural’ landmarks of the surrounding area, an effect that I
usually achieved only after some testing and consulting with Pedro and Andres. In parallel, they also instructed
me to take a picture while they were collecting the sample, in order to show the actual process to their counter-
parts at the ISC and the MMA. The picture then constitutes a natural landscape and places the sampling situ-
ation in it.
Through their vivid visuality both images aimed to convey what the other components of the chain of
custody could hardly do: a sense of reality of the fieldwork, the ultimate proof that the work had been done
correctly. Especially given the absence of previous guidelines, these images represented the most palpable
way of showing the characteristics of the baseline location, especially emphasizing its ‘natural’ character.
The power of the chain of custody lies precisely in this last point, in the way in which (when functioning)
it is able to mobilize the naturalness enacted in the valuation practices to multiple different locales, while in
the process replacing several of its idiosyncrasies with standardized entities. Therefore, assembling traceabil-
ity is always a process of establishing a certain degree of connection, of referentiality, between multiple
things, from the place in which the samples are collected through all the multiple locations where they
are expected to be taken, as a valid spokesperson of a natural soil. In such a process, as Latour (1999,
p. 70) recognizes, some things are lost and new ones are added, usually meaning (when the process is suc-
cessful) the progressive replacement of the samples’ particularities by standard qualities, helping them to
move from being highly specific entities towards becoming a general ‘kind’ of natural soil of the area, uni-
versally accepted as a baseline.
 JOURNAL OF ENVIRONMENTAL POLICY & PLANNING 11

Conclusions
We spent our final day of fieldwork indoors, mostly in Marcela’s hotel room. Scattered on the floor, covering it
almost in its entirety, were plastic bags containing soil samples collected at Aguada and Maleza. We sorted them
out, checking that their labeling was in accordance with the information included in the registry and, in several
cases, correcting labeling mistakes to make the chain of custody consistent from the first to the last sample. This
was the moment in which I took Figure 4, showing a selection of the samples lying on the floor. This selection
shows the material sameness existing between baseline samples (the right row, labels starting with VB) and tail-
ings samples. With the exception of the code on their labels, they were the same: transparent plastic bags con-
taining a few hundred grams of grayish soil.
However, once in the ISC lab in Santiago, the VB samples were going to be taken simply as baselines, as valid
representatives of the ‘natural’ soil of the area surrounding Aguada and Maleza. Later on, and following the
ERA framework, such samples would become the cornerstone against which the toxicity of the samples of tail-
ings would be assessed and remediation practices decided (or discarded). They were going to become utterly
‘objective’ and, hence, impenetrable by any questioning, especially given the high scientific status of baselines
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on Chile’s environmental regulation (Barandarian, 2013).

As seen in this paper, this ‘naturalness’ was not a given. Entities such as baselines do not exist naturally in the
form of pristine entities and/or landscapes. They have to be produced through very site-specific baselining pro-
cesses, usually in parallel with the (potentially) polluted entities. In particular, here we have seen baselining as
involving (at least) two interrelated processes: valuating naturalness and assembling traceability. Each one of
them, I believe, presents us with paths that should be further explored to get a more nuanced understanding
of pollution-related issues and their regulation.
On the one hand, the analysis of valuation practices showed how the process of selecting an exact location
and kind of ‘natural’ soil included the participation of a myriad of different entities, several of whom were quite

Figure 4. Tailings and background samples resting on the floor of Marcela’s room. Source: the author.
 12 S. URETA

speculative and site-specific, and hence, open to being challenged and replaced. Through the consideration of
these valuation practices, the whole notion of a baseline was transformed, from the usual version of an immu-
table ‘pristine’ natural background to a device emerging from a messy mixture of previous knowledge, idiosyn-
cratic judgments and comparisons between highly heterogeneous groups of entities.
By highlighting such practices, however, I am not arguing for the need to replace valuation practices by
more ‘objective’ procedures, hoping to avoid its undeniable ‘bias’ (Ball, 2002). On the contrary, I believe
that such a ‘bias’ is not a problem but a necessary component of the process. What we need, on the con-
trary, to make ERA processes more well-rounded is to make them evident; to open up the valuation pro-
cesses embedded in ERA. Firstly, by becoming aware of (and making explicit) the uncertainties surrounding
them and, secondly, by including several entities that have traditionally been excluded: history, possible
futures, local populations, nonhuman soil components, etc. The aim should be to transform valuating prac-
tices into properly political platforms on which multiple notions and judgments regarding the past, present
and future of local environments (and the role of pollution in them) could be discussed and decided upon.
For example, on the case of mining waste remediation, an alternative baseline setting process could start by
inviting the population living in the vicinity of the site, in order to discuss with them different possibilities
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regarding the conditions that they think a baseline for the site should include. Such discussion should not
only include valuations about the past or ‘natural’ conditions of the site, but also more speculative judgments
about the possible futures for the area. In parallel, different kinds of expertise (besides environmental toxi-
cology) should be considered in the process, especially the ones coming from biology, soil science and ecosys-
tems sciences, in order to take into account not only the chemical characteristics of soil, but also the myriad of
living entities populating it. Both additions would definitely make the whole process of baseline setting much
more cumbersome and slow, being the possibility of open disagreements quite likely, as in any other kind of
political platform. However, from the lengthy discussion and bargaining that would necessarily follow,
much more complex versions of baselines could emerge.
On the other hand, the description of the practices and devices involved in assembling the traceability of
samples help us to visualize how baselines are never singular and well-defined entities but assemblages that con-
tinually move back and forth between the multiple locations where environmental regulation processes such as
ERA are carried out. In doing so, they continually gain and lose attributes and components, all with the final
aim of establishing a certain validity about the correct ‘naturalness’ of the samples being collected.
Both valuation practices and traceability become in retrospect invisible: baselines simply standing for some
sort of unpolluted environment whose process of production appears as merely technical. However, as seen
here, there are no baselines without baselining. ‘Nature’ is not just waiting there to be accounted for. It has
to be produced, usually using the same tools used to produce pollution. For this reason, in environmental regu-
lation processes such as ERA, pollution and baselines should be seen (and studied) in parallel, as the result of
very concrete practices and materials.
Finally, in studying baselining one key challenge is to do it without diminishing the ontological status of
pollution. To claim that baselining constitutes a key activity in the enactment of pollution-related issues is
not meant to show, returning to Douglas (1966) culturalism, that pollution exists merely as a projection of
certain social categories. On the contrary, pollution and baselines are entities with a very concrete ontol-
ogy and endowed with particular (if different) agencies. The main point that this article tried to raise
was that they are usually enacted by similar processes (and at similar times), that they emerge out of
messy bundles of practices and, hence, that to better understand one of them we have to necessarily consider
the other.

Note
1. The fieldwork on which this paper is based was carried out by the author in September 2014 and consisted mainly of par-
ticipant observation with a team of environmental chemists while measuring two tailing deposits in the Atacama region of
Northern Chile. The names of the individuals, institutions and specific locations involved have been changed to protect their
anonymity.
 JOURNAL OF ENVIRONMENTAL POLICY & PLANNING 13

Disclosure statement
No potential conflict of interest was reported by the author.

Funding
This research was carried out with funding from Chile’s National Council for Science and Technology (CONICYT), Fondo de
Fomento al Desarrollo Científico y Tecnológico, grant number 1170153.

Notes on contributor
Sebastián Ureta is an associate professor at Departamento de Sociología, Universidad Alberto Hurtado (Santiago, Chile). He has a
Ph.D. in Media and Communications, London School of Economics (2006). From 2012 and onwards he has been developing a
research project focused on the toxic politics surrounding industrial waste in Chile, in particular the massive waste produced by
the country’s booming mining industry.
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