There are many examples of this type of blanket condemnation of a product
based on hazard not risk. When Prop 65 was first implemented, the
manufacturer of "White Out" was told the 15 mL bottles would need to carry a
P65 warning because it was Perc-based. The product was reformulated to the
water-based version, which did not work worth a damn. This led to the
development of the White-Out tapes for typo correction. Fortunately, word
processors soon replaced this cumbersome error correction tool.
I do not see a way around this hazard/risk misconception until we have a
population sufficiently educated to comprehend the distinction. I am not
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From: ACS Division of Chemical Health and Safety
[mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Stuart, Ralph
Sent: Friday, January 13, 2017 8:05 AM
Subject: Re: [DCHAS-L] EPA Proposes to Limit the Use of Two Toxic Chemicals
in Paint Removers.
> Then we'll either start seeing exotic (and pricey to ridiculously price)
HFC blends that don't work very well or we'll hear about people using
flammable cleaners in energized applications.
Thanks for sharing your thoughts on this. I have had similar frustrations
many times when people blame a chemical rather than the way it's used for
the problems it can create. And often, as in the cases you cite, many other
technologies are built on top of the use of a particular chemical. I think
that a broader systems view of the problem of hazardous chemicals is needed
to avoid creating a lot of unexpected disruption downstream... There's a lot
of educational work between here and there, though.
Ralph Stuart, CIH, CCHO
Chemical Hygiene Officer
Keene State College
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