Kay
Whereas I am not against the precautionary principle, it can be applied
ONLY if there is an a priori case to show that a product or a process
may be hazardous either to life or the environment. Otherwise, we could
close every factory in the world. The only reasonable manner of
establishing such a case would be to have expert scientists to conduct a
literature search and, failing the discovery of a reasonable presumptive
argument, then conduct a risk assessment.
Let me cite a case of which I have deep personal knowledge. I co-chair a
task force charged by the Parties to the Montreal Protocol to study
n-propyl bromide (nPB), a controversial solvent used, inter alia, for
cleaning electronics assemblies. The actual affect of this substance on
the ozone layer is still unknown, as the mechanism is different to other
ozone-depleting substances, such as CFCs. The Parties cannot therefore
introduce it into the list of controlled substances until the
atmospheric scientists have completed their modelling (possibly next
year). There is, nevertheless presumptive evidence that it may be a
considerable danger to the ozone layer, but depending on its place of
emission (unlike CFCs). Even worse, there is increasing evidence that
nPB may be quite toxic and therefore unsuitable as a cleaning solvent
unless extreme precautions are taken (some authorities, including one
manufacturer, puts it more or less on a par with carbon tetrachloride,
which was banned for solvent use in most countries 40 or more years
ago). I presented a report to the Open Ended Working Group of the
Parties last month, recommending that the precautionary principle could
be applied on the combined grounds of toxicity and potential effect on
the ozone layer, by means of a Decision (as opposed to an Amendment,
required for introducing a new controlled substance) stating a
recommendation to Parties not to use the substance until further
evidence is forthcoming. This recommendation was not adopted by the
OEWG, despite some support, on the grounds of insufficient knowledge. My
personal view is that this was possibly a mistake as I consider there is
sufficient scientific evidence to warrant such a measure, but the UN
cannot afford to make such a recommendation and then have the
manufacturers on their backs if it later proves the substance is
harmless. This is their privilege.
Another case in which I'm involved is trichloroethylene. This has been
given a compromise EU labelling requirement on the flimsiest pretext of
a flawed epidemiological study in a single member-state. Yet, fully
documented and multiple studies with large cohorts have been conducted
in many other countries, demonstrating that the member-state's
conclusions are totally erroneous. Yet the labelling would have one
think that the substance is much more dangerous than it is, as
categorically proven. This is the precautionary principle gone mad, the
complete opposite to the nPB case.
You already know my views on lead in solder, so I won't expound them
again, other than to say that WEEE is another case of the precautionary
principle gone mad on the grounds that there is no a priori scientific
case to suppose there is a danger and that the resultant environmental
harm may be worse than the "cure".
Brian
"Davy, Gordon" wrote:
>
> 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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Search previous postings at: www.ipc.org > On-Line Resources & Databases > E-mail Archives
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