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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