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EPA Finalizes PVC Production Emissions Standard

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Dave Palmer
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Re: EPA finalizes a standard
Dave Palmer   3/13/2012 5:20:47 PM
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You can find uninformed people on any given side of any given issue.  Certainly there are examples of health or environmental scares which were not well-founded in fact. (There are also industry-funded groups which make a business of depicting well-founded concerns as unfounded scares, which can sometimes make it difficult to tell the difference).  But there are an awful lot of things which pose well-known risks to health and the environment, and vinyl chloride is one of them.  I don't  think anyone would seriously suggest that there are any beneficial effects of breathing vinyl chloride.

By the same token, no one is seriously suggesting that the only acceptable level of risk is zero and that we should end all PVC production immediately.  All human activities involve some level of risk -- just ask an insurance agent.  The challenge is to reduce the risk of harm to the lowest possible level, while maximizing the benefit to society.

Striking the proper balance is a difficult task.  In a democratic society, it's a task that we accomplish through free and open discussion.  When people take uninformed or extremist positions, this task becomes more difficult.  It's important to stick to the facts, and to look at all sides of a given question.  When we do this, we can arrive at good decisions.

Ann R. Thryft
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Re: EPA finalizes a standard
Ann R. Thryft   3/13/2012 12:38:39 PM
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William, I didn't say that only a few people in this state are concerned. Obviously, many of them are concerned about environmental issues, since we are a leading state in relevant legislation and various organizations. I did say that we are not living in fear or wanting to live in caves and eat rocks. I hardly see how anyone's credibility is damaged by the facts. There's a lot of cleaning up to do after over 100 years of ignoring all the problems. So a lot of noise apparently has to be made regarding cleaning things up and finding altemative methods, materials and processes. Here's a bumpersticker I like: "Maybe if we Ignore the environment it will just go away."

 

 

William K.
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EPA finalizes a standard
William K.   3/12/2012 8:31:39 PM
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Ann, I realize that our news here is probably a bit slanted, at least it looks slanted to me, and it is also true that the silent folks are not the ones who make the noise. So it is indeed possible that only a few folks in your state are the ones so very concerned. But just like the alarm that goes off falsely on to many occasions, their credibility does become damaged. Of course there are indeed examples of very real problems that should be corrected, but listening to some carrying on in a state of panic does indeed cast doubts on their credibility, and a loss of credibility by association may be undeserved, but it is certainly real. Although it is not fair, people are known by the company that they keep. And the ones that we hear are the ones that yell loudest, not that they are most representative, but that they are the loudest.

 

Ann R. Thryft
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Re: EPA: So how clean does clean have to be? Any standards?
Ann R. Thryft   3/12/2012 12:22:50 PM
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William, neither I nor anyone I know, here in California or elsewhere in the US, lives a "life filled with fear." What many of us do live are lives that include an awareness of our stewardship of the earth and its other life-forms, and taking responsibility for our actions that affect those other life-forms. A couple of principles I try to keep in mind are first, do no harm, which is part of the Hippocratic oath. And second, the easily observable principle that if you add a new ingredient of some kind to an existing ecosystem--such as dishwasher detergent into what was a clean lake or creek--it behooves you to assume that it will change that ecosystem, and quite possibly not for the better. Yet that has rarely, if ever, been the human approach to industry. So there are a few hundred years' worth of habits to change, including habits of thought.

Your statements about lab rats and "the degree of evidence" are simply not factual. Rats are chosen for experiments for several reasons, primarily because they a) have physiologies very similar to those of humans, and c) are small and have short life-spans, making longer-term effects more visible. Pigs also have physiologies very similar to those of humans but are larger and much more difficult to handle. Regarding evidence, there are well-established experimental statistical protocols that are followed. As Dave pointed out, the article discusses known carcinogens. As far as so-called  "acceptable" levels of risk, if you or your mother or your child  happens to become that 1 in 100,000 or even 1 in 1,000,000, you might decide that it's a good thing to have laws that ensure what we eat and drink and breathe contain very low levels indeed. Another thing about carcinogens: it can take decades of exposure to very low levels to have any effect.


Dave Palmer
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Re: EPA: So how clean does clean have to be? Any standards?
Dave Palmer   3/12/2012 11:46:33 AM
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@William K: There's a difference between minimizing exposure to risk and being a "slave to fear."

California's Proposition 65 requires companies to provide a warning on products which contain carcinogens in levels which are likely to cause one excess case of cancer per 100,000 exposed individuals over 70 years of exposure.  It also requires a warning for products which contain chemicals which cause birth defects or reproductive harm if the levels exceed one thousandth of the "no observable effect level."

I agree with you that this is an extremely low threshold of risk, particularly when it comes to birth defects or reproductive harm.  Then again, all that the law requires is that consumers be given a warning -- it doesn't actually ban the manufacture, sale, or use of these products.

As long as consumers understand that the level of risk required for a Prop 65 warning is relatively low, they can make an informed choice about the products they buy.

One virtue of the Prop 65 risk criteria is that they are fairly straightforward and consistent: one excess cancer per 100,000 exposed individuals or 1/1000 of the lowest level known to cause reproductive harm.  This may be extremely low, but at least it's easily understood.

In contrast, the criteria which OSHA uses to establish permissible exposure limits are far more complex, and far less consistent.  For example, the current OSHA limit on hexavalent chromium is likely to cause between 10 and 45 cancers per 1000 exposed individuals.  The previous OSHA limit (prior to 2006) allowed levels which would cause between 100 and 350 cancers per 1000 exposed individuals.  I doubt that most people would consider a 35% chance of contracting cancer to be an acceptable risk.

You're absolutely right that every human activity involves some level of risk.  However, I try to minimize the risks which I expose myself and my family to.  Having the information I need to be able to make informed decisions makes me more free, not less.

William K.
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Re: EPA: So how clean does clean have to be? Any standards?
William K.   3/9/2012 8:58:42 PM
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Living here in southeast Michigan, what I hear about California is what comes in the various trade publications and in the newspapers. What I very often hear is that another law has been passed in California demanding some change in a product or process because somebody has figured out some mechanization for being harmed by it. At the same time, the rest of the world would never consider or choose to use that product or process in such a manner. The rest of us continue to use products that are marked as "Known to the state of California to cause (something terrible)". The degree of evidence is often that a million times more of the material appeared to possibly have caused some problem in a lab rat.  That is the mindset that I am referencing in my statements. Admittedly the assertion that "everything" ias toxic is a bit of an exageration, but when many of us look in that direction that is certainly the impression that we get. 

My point is that a life spent in fear is a life spent in slavery, and as such it is probably a lot less fun than people were intended to live with. And once again, I believe that slavery is wrong in any way, shape, or form, no exceptions.

Aside from that, I do admit that I no longer seem able to experience fear as an emotion. Not certain just how I got to this point, but I seem to be there. That probably puts me in a different mode than those who fear a lot of things. I still avoid pain and stupidity, as well as unpleasant things, but that is different.

Ann R. Thryft
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Re: EPA: So how clean does clean have to be? Any standards?
Ann R. Thryft   3/9/2012 12:09:09 PM
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Dave, thanks for your clear-headed statements. For the record, William, I live in California, and I don't know anyone here who thinks that "almost everything is bad for you". Too much of anything is, indeed, usually harmful (except perhaps for love and laughter, corny as that may sound), including UV rays from the sun. California has often been a leading state in banning known harmful substances or passing laws that force industry to help create a more healthy environment (such as clean air)--perhaps that's what you meant. I also don't understand how recognizing that we must change some habits to stop harmful practices or eliminate harmful substances is "slavery." I guess to me, changing habits for the betterment of ourselves and of others is what responsible people do.


Dave Palmer
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Re: EPA: So how clean does clean have to be? Any standards?
Dave Palmer   3/9/2012 10:26:58 AM
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@William K: I have a hard time seeing this as an example of anyone "being enslaved by those who find toxicity in everything." EPA worked together with industry to come up with a standard which was achievable.  Industry may not have gotten everything they wanted, but they were part of the process, and seem to be relatively satisfied with the final rule.

Vinyl chloride monomer has been known to cause liver cancer and other cancers since at least the 1950s.  In 1974, in response to this, OSHA reduced the permissible exposure limit from 500 parts per million to 1 part per million.

Industry said that it would cost over $25 billion to meet this limit (over $120 billion in 2012 dollars), but later that year, one of the major producers developed a closed loop polymerization which drastically reduced workplace exposure.  This process was also more efficient.  The company which developed the new process licensed it to the other producers at a significant profit.  So rather than destroying the industry, this regulation actually led to significant advancement in the industry.

There is nothing about the die casting process which makes it necessary to dump PCBs into Lake Michigan. (In fact, there is nothing about the die casting process which requires PCBs at all).  And phasing out asbestos insulation did not lead to the end of the world.  The idea that there is a binary choice between destroying the environment and "sitting in caves and eating rocks" is simply not true.

William K.
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EPA: So how clean does clean have to be? Any standards?
William K.   3/8/2012 8:51:57 PM
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At some point there is going to have to come a reality check situation, at which time we will need to ask and decide as to if we wish to continue to enjoy some parts of life, knowing for certain that some things we do are bad for us, or if we would rather sit in a cave and eat rocks. 

My point is that almost everything is bad for you in states like CAlifornia, where they have not yet discovered that sunshine and fresh air also cause cancer. To live in frear is to be a slave to fear, and in most of the USA we decided a while back that slavery was not acceptable under any condition, no how, no way. I agree with that. So why are we being enslaved by those who find toxicity in everything?

There is of course the challenge of how to make things without any toxic anything. My suggestion is that we first give up smart phones and computers since the integrated circuit industry uses a lot of toxic stuff. ON the other side, perhaps we can realize that all of life includes risks, and accept that we do face risks, and that is how it is.

Ann R. Thryft
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Re: sad
Ann R. Thryft   3/8/2012 2:10:38 PM
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ChasChas, I'm sorry the article was depressing to you. I should think that living in a Superfund area would be depressing enough! I'm glad I live in a much cleaner area with a lot of oxygen produced by a lot of trees. Yet we have to fight pretty hard to keep those trees and this clean air intact. I think the superfund situations happen because we're not thinking ahead collectively and taking collective responsibility for the future. I'm reminded again of the "seventh generation" misquote from the Iroquois Constitution discussed on another article's thread. To me, this article was heartening, especially after I read about the lawsuits that sparked this ruling.


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