Lead in Paint, why???

This is how you’re supposed to regulate chemicals, burden of proof on the manufacturers, makes sense because they are the ones who have the most information, and the most to gain or lose. So, you have the right motivators with the right tools to ensure that a decision can be reached in the right amount of time. If you reverse the burden of proof, the group (people/government) with incomplete information and little monetary motivation is going up against a group (the industry) which has all the information on its side, and powerful monetary motivation to do nothing, because in doing nothing, the burden of proof will ensure that they win.

Makes so much sense, doesn’t it!

EU bans 22 hair dye chemicals feared unsafe – Yahoo! News

BRUSSELS, Belgium – The European Commission said Thursday it would ban 22 hair dye substances, following the release of a scientific study that concluded the long-term use of these chemicals could cause bladder cancer. The ban will go into effect Dec. 1. “Substances for which there is no proof that they are safe will disappear from the market,” said European Union Industry Commissioner Guenter Verheugen.

Well said, sir, way to motivate industry to prove safety!

“Our high safety standards do not only protect EU consumers, they also give legal certainty to (the) European cosmetics industry.”

A crucial point, industries adjust to regulation very well, as long as the regulation is clear, stable and consistently applied. Not to say that they don’t work to undermine the regulations at times, but most of the time, stability is more important than the regulation itself. The regulation just gets added to the cost of doing business, and you protect yourself against lawsuits, you have plausible deniability, all the good stuff.

The Commission had asked the cosmetics industry to provide safety files for all chemicals used in hair dyes to prove they do not pose a health risk for consumers. The ban concerns 22 chemicals for which no safety files were submitted by producers.

Nice, no proof = no sale.

Priority and Toxic Chemical Reduction | Resource Conservation Challenge | US EPA

Priority and toxic chemicals make up a fairly limited volume, yet potentially hazardous portion of the nation’s waste stream. We are working to eliminate or reduce priority chemicals and other chemicals of national concern from commercial products, waste streams, and industrial releases through pollution prevention, waste minimization, and recycling/reuse.The 31 priority chemicals are federal priorities because they are persistent, bioaccumulative, and highly toxic. We’re focusing on reducing priority and toxic chemicals to better protect human health and the environment.

By substituting or eliminating certain chemicals in their manufacturing processes, companies produce less waste and thus lower their waste disposal costs. Our goal is to substantially reduce the volume and toxicity of priority chemicals in waste by asking companies to voluntarily:

• Substitute safer alternatives when they can;
• Minimize the amount of priority chemicals they use, if they can’t substitute for them;
• Maximize their recycling efforts;
• Practice cradle-to-cradle chemical management; and
• Design products to minimize exposure to, and release of, priority chemicals during manufacturing and use.

Sounds good, and Worldchanging has more:

But nowhere near the progress some companies are making on their own in cleaning up toxic emissions — not simply to be good guys, but to reduce their costs, liabilities, and exposure to activist and shareholder pressures. And, in some cases, to meet their customers’ growing demands for less-toxic or nontoxic alternatives to business as usual.

Read the whole post, which sounds ambivalent about the scheme. The idea is Environmental Good Sense 101, use less, or none at all, practice cradle to grave economics and minimize exposure. Simple stuff, huh. The biggest problem, however, is that by setting limits on a voluntary basis, you always run the risk of setting the bar too low, and then indulging in relentless and pointless self congratulation about how the “market” solved everything, and how rules are so, well, 1970s?

you need a good mix of

1. Regulation, which sets a minimum, health based bar
2. Flexibility to the business on how to achieve their targets
3. Market systems to trade emission credits, etc
4. Voluntary industry-government initiatives like the one above
5. Relentless citizen activism that forces governments/business to act
6. Community outreach and education so consumers can make informed choices
7. Costing mechanisms that actually reflect free market efficiencies (no stupid subsidies, accurate costing of “externalities”, etc. )

Yeah, this does not fit neatly into the Mano a Mano, you’re with us/you’re against us false dichotomy of choice that seems to beset almost every policy debate (environmental or otherwise). It seems that you never have to do one or the other, but a bit of both, or all of them at the same time.

In the meanwhile, the voluntary program will work, but only in areas in specific instances where it is to a company’s advantage.

BTW, I think that good old fashioned regulation in Europe – See Reach and many many more existing regulations, such as this one for PCBs and Dioxins which I know a little too much about, have a little more to do with American companies reducing POP levels that they care to admit!

There’s been some progress on the coal fired power plants I had railed on about recently.
In Big Buyout, Utility to Limit New Coal Plants – New York Times

Under a proposed $45 billion buyout by a team of private equity firms, the TXU Corporation, a Texas utility that has long been the bane of environmental groups, will abandon plans to build 8 of 11 coal plants and commit to a broad menu of environmental measures, according to people involved in the negotiations. The roster of commitments came through an unusual process in which the equity firms asked two prominent environmental groups what measures could be taken to win their support. The result is an about-face from the company’s earlier approach to climate-change issues, and includes a goal of returning the carbon-dioxide emissions by TXU to 1990 levels by 2020. Environmental groups said yesterday that they had never known of a financial deal with such an ambitious built-in environmental component.

Better than nothing. This is good news for sure. But as I mentioned previously, the Sanders (Good ol’ socialist!) Bill calls for an 80% reduction from 1990 levels by 2050. This is required to cap CO₂ levels at 450 ppm and avoid the worst effects of global warming. So, while reducing CO₂ to 1990 levels sounds impressive in a breathlessly written NY Times article. It is not nearly enough. This is exactly what I was afraid of when I mentioned the moratorium word! In the absence of regulation, or a clear policy, private equity companies, power plants, and other plutocrats are setting the US global warming agenda. They are establishing the floor plan, meaning, we’ll set the bar near the floor and not budge. Yes, I know, the NRDC and Environmental Defense were involved, and this part is definitely good…

TXU will discard plans to build eight of 11 proposed new coal plants, which would have been major new sources of emissions. Those plants — which would have added more than 9,000 megawatts of new capacity, the equivalent of 3.5 percent of the nation’s current coal-fired power — had been part of a planned $10 billion expansion of coal-fired electricity.

TXU, which is based in Dallas, also intends to expand the renewable energy portion of its portfolio and reduce or offset its emissions significantly, said people who were familiar with the plans.

All very good, but as I talked about previously (man, way too much self reference, not a good thing!), a book called Reality Check just out assesses voluntary actions by various companies in the US, Europe and Japan and comes to the following conclusion:

Most of the programs it studies have positive results, but they are
small compared with business-as-usual trends and the impact of other
forces–such as higher energy prices. Importantly, potential gains may
be quickly exhausted as the “low-hanging fruit” is picked up by
voluntary programs.

Now tell me that this agreement does not fit this frame!

A friend pointed me in the direction of this letter by EPA union leaders about the upcoming re-registration of some very commonly used organophosphate and carbamate pesticides. This ens-newswire article provides an excellent summary.

In the absence of “a robust body of data” the union leaders remind Johnson that the Food Quality Protection Act requires the EPA to use “an additional 10-fold safety factor in its risk assessments when setting pesticide tolerances.

This is the key point, and the reason that Pesticide industry and the EPA came up with the infamous “CHEERS” study (talk about Kafkaesque naming!) to study children’s exposure knowing fully well that they would not be able to accurately assess health effects on children with an observational study. The hope was that using a short term “study” that assessed acute toxicity, they would be able to “prove” no significant harm to children and get rid of the safety factor. A factor of 10 is big, and the pesticide manufacturers hate it because the tolerances become low enough that people will be over-exposed.

Isn’t that the whole point of a safety factor? We are still figuring out what happens at low levels of exposure to certain pesticides. This is truly an Environmental Justice issue. It is not the children of EPA administrators eating non-organic fruits and veggies that are going to be exposed. The gains from eating organic food vs. non-organic are dwarfed by the incidental exposure of the families of farmworkers and other people applying pesticides. Yes, you guessed it, they do not tend to be particularly rich or influential, but they are most in need of protection from government to ensure that their children do not get exposed to levels that may be harmful. This is not about shopping at Whole Foods, which is where most of elite America hears about pesticides, this is about the people being exposed to much higher doses. The safety factor is a must to keep them safe.