Dear Charles
Of course, the principle can be taken to various extremes depending on
the situation but in general it is fairly well established.
Watch out now for a new principle; the unnecessariness principle. See
below!
Kay
Unnecessary chemicals
Editorial by Danish EPA Director General Steen Gade in the Danish EPA
magazine MiljøDanmark, July 2001
Perfumed socks. Maybe it's about time we began discussing a new
principle - the unnecessariness principle. Over 20,000 chemical
substances are available in Denmark and new chemical substances are
constantly being developed. It is quite a jungle to disentangle and
organise. These chemicals give us many benefits, but often there is
great uncertainty with regard to how these substances affect the
environment and our health.
It is when dealing with such matters that the authorities and policy
makers must try to decide when and where uncertainties are so great that
the precautionary principle should be applied, and therefore initiatives
should be taken to limit the use of chemical substances.
It is not an easy task. Denmark is struggling in the EU for far better
investigation of chemicals and for industry to have far greater
responsibility for examining substances before they are taken into use.
But perhaps it is time for us to begin discussing a new principle - the
unnecessariness principle. For example, the next time I want to buy a
pair of socks, I could find myself faced with a new choice: with or
without perfume? I know that perfumed socks are now a possibility. The
question is, are they a necessity?
In the case of chemical substances that we know are acutely harmful to
our health and the environment, there is no doubt in my mind: they must
either be banned altogether or restricted in some way. However, there is
also a grey zone of chemical substances that we at the EPA have begun
calling unnecessary chemicals.
Unnecessary because the substances make no difference as to whether the
products work. Perfumed socks are a good example. They undoubtedly add
colour to some people's lives, but of course the perfume does not make
the socks last longer, etc. Other examples are antibacterial substances
in cutting boards, toothpaste and other cosmetics.
The unnecessariness principle concerns the unnecessary chemical
substances in products we use everyday. This grey zone of chemical
substances does not put our health and the environment at risk here and
now, but as an environmental authority, we are concerned that they could
cause problems in the longer term.
Should the use of unnecessary substances in products be banned or
limited? Or should consumers have the freedom to choose for themselves
in the supermarket? And do consumers actually have the knowledge
required to make this choice? Should the products be labelled or contain
a declaration? Should consumers receive this information in the form of
pamphlets or leaflets - or perhaps even an easily accessible database?
And who should actually decide what is unnecessary?
Opinions probably differ. Some people would perhaps like to see a little
for every taste on the shelves and think that people should be allowed
to choose for themselves, while others would like to see products
containing unnecessary chemicals removed from the market altogether.
We are all consumers, of course, and as a consumer, I myself like to
know what is in the products I put in my trolley. Also, I do not think
that the EPA, as an authority, can expect people to spend time and
energy finding out for themselves what chemicals products contain.
The unnecessariness principle raises many questions about what the EPA,
as an authority, should do - and right now, there are no clear answers.
We have just begun discussing these matters - and we would very much
like to receive ideas and opinions. Have you come across unnecessary
chemicals in your everyday life? Do you think it is too big a task for
people to find out for themselves what is in the products they buy? Do
you care whether there is perfume in washing powder or nappies? And is
this really something in which the authorities should get involved?
-----Original Message-----
From: Charles Dolci [mailto:[log in to unmask]]
Sent: 30 August 2001 17:00
To: [log in to unmask]
Subject: Re: [LF] Reasons behind EU activities
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
*MIME-Version: 1.0
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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
CAA16196
*
*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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