Werner
I think your message is apposite, but I would like to add a rider to
your fourth point.
We must be able to identify and recognise the negative effects. To
illustrate this, let me cite CFCs. These were initially made as
refrigerants in the 1930s (Midgeley's patent was filed in 1928: the same
Midgeley who "invented" lead tetraethyl as an anti-knock compound for
motor fuels!!!). Yet Molina and Rowland's earth-shattering paper
hypothesising ozone-depletion was not published until 1974 and the
Montreal Protocol was not signed until 1987, a year before absolute
scientific proof of CFC's contribution to the ozone depletion was
established -- and CFCs are still being manufactured to this day in
industrial quantities.
Another example is carbon tetrachloride: strong suspicions of its
hepatic toxicity, neurotoxicity and potential carcinogenicity led to its
being banned as a cleaning solvent in the late 1950s in the western
world. Yet, today, thousands of tonnes are still being used in
developing nations for metal cleaning and dry cleaning, because it is
easy to manufacture and cheap. I once spilt some food down a jacket in a
developing country and I took it to a dry cleaners. My nasal
chromatograph detected CTC as the solvent and, while I was waiting to be
served, I observed a machine load of clothes being unloaded from a
machine, visibly still wet from the CTC. They were then taken to a girl
who started to press them immediately with an ordinary steam iron. Do
you think that the OSHA PEL of 10 ppm was respected? Probably nearer
1000 ppm.
I'll cite a third case, a modern one. About 1995, a new miracle solvent
was proposed for degreasing and defluxing in the electronics industry,
n-propyl bromide or nPB. It was initially claimed to be
non-ozone-depleting (and still is by some unscrupulous vendors) and of
low toxicity, with some manufacturers recommending an OEL of 200 ppm
(compared with an OSHA PEL of 100 ppm for trike and perc and 25 ppm for
methylene chloride). Even today, no chronic toxicity tests have been
completed and the US National Toxicology Program announced only last
month that they would START such tests so that OSHA could decree a PEL.
In the USA, no TRI or other reporting was required, so it appeared as an
attractive alternative to chlorinated solvents and the current global
production is estimated at about 10,000 tonnes per year and increasing
to a projected "upper bound" counting in the hundreds of thousands of
tonnes within a decade. Yet the environmental and toxicological effects
are still unknown, even though it is known to be ozone-depleting and
probably toxic. (To be fair, a couple of vendors have suggested exposure
limits, within the past two months, of 25 ppm, down from 100 ppm since
1998.) A Japanese researcher has published that it has shown severe
neurotoxicity and reproductive toxicity on rats at 200 ppm and advises
caution in its use. An isomer of nPB has also shown severe toxicity and
an epidemiological study has shown that iso-PB has caused severe
problems in humans. The Scientific Assessment Panel of the Montreal
Protocol has not yet started modelling its effect on the ozone layer
(will start next year). Yet nPB is on free, unrestricted sale as an
industrial solvent in most countries, even before its environmental and
toxicological effects are fully known, despite extreme suspicion of
danger, on both counts.
So, whereas I concur with you that restrictions should be applied where
negative consequences are apparent, how can we do so when the
bureaucratic process for determining the negative consequences is so
slow, throughout the world (not to mention applying restrictions)?
Unfortunately, industry (except the pharmaceutical industry) requires
that the onus of proof of negative consequences be placed on the
bureaucrats before any restrictive action can be taken. I believe that
the ideal would be to place the onus of proof that there are NO negative
consequences on the vendors, before they are allowed to sell a product,
with or without restrictions. But then I am told that this would stifle
innovation, even if it were to save human lives. What price innovation?
Brian
Werner Engelmaier wrote:
>
> Hi All,
> I have been following this debate for some time. and I have learned a lot. I
> have utmost respect for Brian, Günther, Eric and Gordon (and I do know them
> personally), both professionally and as human beings--and thus I am not very
> happy with the tone some of the exchanges have taken.
> First, I am certain all will agree, that this is a VERY complex subject
> matter, that even the lengthier epistles that have appeared here cannot do
> justice (but please keep them coming, they are very informative).
> Second, I also am quite sure, all of you (as am I), are rather frustrated
> that politicians (in the worst meaning of the word) have made this issue a
> near fait accompli, by innuendo, half-truths, and scaremongering to the
> general population, and that parts of the industry have jumped on the
> bandwagon to gain a temporary competitive advantage.
> Third, all human activities have both positive and negative consequences,
> some intended and others unintended.
> Fourth, these human activities should be performed to minimize the negative
> consequences. This may include a total ban, or a partial ban for certain
> uses, or other restrictions.
> Fifth, one of the strongest human motivations for or against doing something
> is economic (sure, some of us are altruistic, but most are not). The biggest
> problem we have is that the goods and services we buy do not include all the
> costs associated with them--only the costs to the point we buy them (and in
> many cases not even those considering cleanup and restoration of production
> sites, pollution damage, etc.). Thus, if the real complete costs of goods and
> services--including disposal, recycling, reclamation--were reflected in the
> purchase price, the consumer could and would make more appropriate choices.
> But, for this do happen requires worldwide agreement, cooperation, planing,
> and execution. This is UTOPIA--we all know it--we know it is so much easier
> to stir up conflicts, to pit one group against another, to gore somebody
> else's ox, than to agree on something. Thus, we are frustrated.
> All we can do is let our voices be heard, exchange honest opinions, and do so
> without personal acrimony. Our disdain should be directed at those who try to
> make public policy for self-serving reasons.
> Werner Engelmaier
>
>
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