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August 2001

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Subject:
From:
Charles Dolci <[log in to unmask]>
Reply To:
Charles Dolci <[log in to unmask]>
Date:
Thu, 30 Aug 2001 09:00:22 -0700
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This "the precautionary principle" is an interesting principle. It does no good
to show that the metal/chemical/whatever has a net benefit to humans or the
environment; that is not relevant. If it does ANY harm then it must be banned. I
doubt that fire would be able to pass the precautionary principle standard.
Would any medicine be able to pass this standard if it was shown that 0.01
percent of the population might suffer an adverse reaction from it, even if it
benefits 99.9% of those to whom it is administered.
Seems to be a resurrection of the Luddites.

Charles Dolci

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*Thread-Topic: [LF] Reasons behind EU activities
*Thread-Index: AcErUakVoTD08JYTQlO3pm7rUsPgAwFE+aOg
*From: Kay Nimmo <[log in to unmask]>
*Subject: Re: [LF] Reasons behind EU activities
*To: [log in to unmask]
*Content-Transfer-Encoding: 8bit
*X-MIME-Autoconverted: from quoted-printable to 8bit by kimba.Eng.Sun.COM id
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*
*Dear Gordon
*
*It is vital to understand the precautionary principle upon which much
*future legislation will be based, and of which the Ospar convention is
*an example i.e. a metal/chemical cannot be used unless it is proven to
*be of no danger to humans or the environment. This varies from the
*previous approach which was to wait until some harm had been done (and
*discovered) until a substance ban was implemented. This aproach
*therefore leads on to the 'principle of substitution' and also
*'prevention at source' (meaning effectively that it is preferable not to
*use a hazardous material as this is the only way to ensure no
*environmental contamination).
*
*Under the precautinary principle it is the responsibility of industry to
*demonstrate that a product does NO harm, NOT the responsibility of
*legislators to show that a product does harm.
*
*Whether I agree is not important, however, you should understand that
*this aproach effects all metals and chemicals (and therefore products)
*in all sectors, not just electronics. If you wish to challenge hazardous
*materials bans then you will need to challenge the basis of the
*precautionary principle.
*
*Kay
*
*-----Original Message-----
*From: Davy, Gordon [mailto:[log in to unmask]]
*Sent: 22 August 2001 22:28
*To: [log in to unmask]
*Subject: [LF] Reasons behind EU activities
*
*
*Kay Nimmo has suggested researching "some of the actual reasons behind
*the
*EU activities to ban hazardous substances", and offers a link to a web
*page
*(Ospar) as an example of a source of useful information.
*The example she offers does not measure up to her billing. It provides a
*long list of "candidate substances" and identifies some selection
*criteria
*by which they got to be on it, namely materials that (evidently in
*someone's
*opinion):
*        (i) due to their highly hazardous properties, are a general
*threat
*to the aquatic environment;
*        (ii) show strong indications of risks for the marine
*environment;
*        (iii) have been found widespread in one or more compartments of
*the
*maritime area, or may endanger human health via consumption of food from
*the
*marine environment;
*        (iv) reach, or are likely to reach, the marine environment from
*a
*diversity of sources through various pathways.
*But what she said would be found there is missing: the reasoning - the
*documentation that connects any listed material and the assertion of
*risk.
*How are we to know that they got it right? In normal scholarship, one
*publishes the studies that have been conducted so that the work can be
*critiqued. Such scholarship is missing here, and in many other
*environmentalist sites that I've seen. It seems that we are expected to
*have
*faith in the organization. Maybe they are all too busy to provide the
*missing information. (I commented some time back about a site that
*claimed
*that rosin is a significant threat to the environment. No matter that it
*is
*derived from trees.)
*At the risk of over-repetition, environmental activists keep talking
*about
*"risks". But in the particular case of lead, speculating about risks is
*specious, since we know that lead was deliberately introduced into the
*environment for decades, and is still there. Instead of considering
*risks of
*what might happen, all we need to do is to find the consequences of what
*has
*already happened. The reality is that the amount of new lead getting
*into
*the environment has been reduced (drastically) since the removal of lead
*from gasoline, and so has the amount of lead getting into people. If for
*example lead is believed to be "a general threat to the aquatic
*environment", it would be appropriate to discuss how lead from gasoline,
*fishing sinkers, and shotgun pellets affected the aquatic environment in
*the
*past, whether things are getting better or worse, and the extent to
*which
*banning lead in computers and keeping CRTs out of landfills is going to
*help.
*The site also espouses "the precautionary principle" (not defined on the
*page - I hope that this isn't just a fancy phrase for being
*superstitious),
*and the "principle of substitution, i.e. the substitution of hazardous
*substances by less hazardous substances or preferably non-hazardous
*substances where such alternatives are available", without reference to
*any
*sort of cost-benefit analysis. Perhaps these people mean well, but if
*they
*want influence others by force of reason and logic (as opposed to such
*other
*options as propaganda, political action, and coercion), they will need
*to
*improve their page substantially.
*Kay implied that she knows of sources that explain the reasoning behind
*the
*bans, and don't just assert. Perhaps she would be willing to share them
*with
*the forum. (I've been seeking this info for a long time, and have pretty
*much concluded that it doesn't exist.) We all know that lead that gets
*into
*people (or aquatic life) is bad. That may be interesting, but it's
*irrelevant. The critical challenge is to show (not just assert) that
*taking
*a particular course of action (such as prohibiting the sale of certain
*kinds
*of products that contain lead or recycling electronic products) would
*bring
*about a noticeable reduction in blood lead levels, and that it would be
*worth what it would cost. If it fails to meet these requirements, then
*it's
*time to pick a new project. Somehow we need to get that message across
*to
*the activists. If she agrees, maybe Kay has some suggestions of how it
*might
*be accomplished.
*
*Gordon Davy
*Baltimore, MD
*[log in to unmask]
*410-993-7399
*
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