Engineering Materials

Toxic Substances Reform Law: It's a Good Thing, and Maybe Also an Expensive Thing

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Toxic Substance MISregulation
GSKrasle   6/30/2015 2:27:51 PM
I am leery of any attempt to apply (admittedly necessary) regulation to chemical substances unless there is some way to guarantee the process to be insulated from politics, ignorance and hysteria.

There have been (in my opinion) some bad decisions made re regulating substances, and these have real cost, often at the expense of more significant concerns. One cost is in reducing the credibility and effectiveness of the regulation and regulatory authority. Risibility and Respectability are not compatible attributes.

Regulatory decisions need to be based on facts and made by people capable of understanding science, and who are insulated from political and other inappropriate influences.

I would like to relate some of the mistakes I believe have been made and some of the influences/lobbies that scare me lest they obtain influence.

First of all ROHS. Can anyone explain to me why lead bound-up in glass (of a CRT) is such a danger that the expense of disposing of CRT-based equipment has resulted in a big dumping problem, where waste places, green spaces and waterways are filling with otherwise-recyclable waste? Yes, lead solder is also a possible hazard, but how much better are the alternatives, really? And I have heard talk that the lead used in capacitors (a constituent of the 'PZT' ceramic they are made of) is 'next on the list.' That's just milligrams, and any alternative is, by definition, inferior! What would be the cost/benefit ratio?

I have seen articles talking about 'eliminating toxins like arsenic and phosphorus' from semiconductors. Granted, arsine and phosphine (and silane) used in the manufacturing process can be hazardous, but the quantities in the finished product, a chip, for example, though essential to function, are so vanishingly small compared to the general environmental distribution that there is really no rationale in worrying about them.

If you go to any place where people are discussing Organic Gardening, or gardening, horticulture, pesticides, etc., you will see folks self-righteously stridently and irrationally denouncing various chemicals and practices as inherently evil, deadly, worse-than-whatever-else-you-might-mention, often citing impressive-sounding invalid or discredited/rescinded/disgraced sources. This is the same circus that has damaged economic, social, environmental, health, and human welfare through lost opportunities of modern medical (vaccination), climate, and agricultural (genetic improvement/breeding) sciences. Often, unscientific attitudes have made it into law, been implemented as regulations, and have had substantial real costs.

The ease with which an unscientific or irrational idea can be accidentally or deliberately spread makes any system of regulation that is not specifically insulated from such influences dangerous. Look at how many people have signed-on to ban DHMO, and the reflexive fear people show when you inform that there is lead in the TV tube, mercury in their lights, drugs (at ppt, whatever that means) in their rivers, genes in their french-fries, and 'HFCS' in their soft-drinks. Toxins toxins toxins! Fearmongering is common, sometimes deliberately planted and fostered. And the mongers DO want to get their beliefs implemented into law.

William K.
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Re: Toxic Substance MISregulation
William K.   6/30/2015 3:18:18 PM
I was going to make a statement but GSK has already said it all. And quite correctly as well. Hysteria and panic seem to be the primary driving forces, multiplied by ignorance, that are pushing all of these new mandates.

One example, that RoHS panic, has resulted in an increase in electronic waste because of a decrease in reliability brought about by the hotter soldering needed. Regulations about the disposal of electronic waste would have been much smarter and a lot more effective, since they would also have controlled legacy devices.

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Re: Toxic Substance MISregulation
GSKrasle   6/30/2015 4:46:55 PM

Why Thank-You!

I hate to see electronics, especially OLD metals-rich electronics, disposed-of without a sincere recycling/recovery effort. If agencies had offered a bounty/subsidy on recovery of, say, lead, copper, and tin, then that stream would surely entrain the precious metals and maybe some of the others as well (Ta, Nb, Zr, W, Cd, Ni...). A 'pull' generally works better than a 'push'.

I wanted to add another example that particularly strikes me. Locally they have promulgated rather strict regulation of 'Toxic Solvents', limiting the amount and concentration of any effluent to be disposed down the drain. Of course, there is also a list enumerating these dangerous substances. Methyl chloride is on the list, and Benzene, of course, but so are Ethanol and Propanone (Acetone). This means it is illegal to dispose of urine or blood down the drain, and if you drink, you're doubly-prohibited from using the toilet.

Big companies had to stop supplying 'Wite-Out' because if they were big enough, the quantity of solvent in the typing-fluid would put them in violation (there was no 'qty per 1000 employees' provision).


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