From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Chemical Safety headlines (10 articles)
Date: Mon, 14 Feb 2022 17:12:14 +0000
Reply-To: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Message-ID: 905015534.2029079.1644858734409**At_Symbol_Here**mail.yahoo.com
In-Reply-To <3D411C24-C5A4-406B-8D52-51A73087EE9B**At_Symbol_Here**rstuartcih.org>


It's a little spooky that chromated arsenicals are considered a green alternative to anything...
Ya think?   EPA is spooky.  Like most of their regs, the way around this pentachlorophenol rule is already programmed into it by the industries that commented and lobbied during its creation.  It didn't even cause one manufacturer's heart to skip a single beat.

As long as activists waste their time, energy, and money banning individual bad-actor chemicals, each of which has dozens of understudies waiting eagerly in the wings, industry will happily be acting their roles as the losers in the phony public charade.  While the activists are trying to fund raise on their successful ban, the manufacturers are already putting out SDSs on the products containing one or more of the untested, look-alike substitutes for the banned chemical.  Those chemicals will be called trade secrets.  That means it will be at least 5 years before the activists even know what the chemical is and 20 years before there is enough data to even attempt to ban it.  And maybe never. 

And there's a gaggle of look-alike understudies awaiting their turn to replace every potentially banned chemical.  

There is only one rule I have seen EVER in the US that requires chemicals substituted for the bad actors to undergo toxicity tests BEFORE they are used as replacements.  It is the phthalate plasticizers in children's products rule under the CPSC rules in about 2008.  This law called for the testing the current plasticizers one by one and I think there are 6 or 7 that are now considered safe enough at limited levels for children's toy and articles.  And if you want to add a new one, you have to have the reproductive and developmental data to prove it is safe first.  ALL chemical regulations should do this.

Monona


-----Original Message-----
From: Ralph Stuart <ralph**At_Symbol_Here**RSTUARTCIH.ORG>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Mon, Feb 14, 2022 10:57 am
Subject: Re: [DCHAS-L] Chemical Safety headlines (10 articles)

> >Has anyone read over this reg?  I don't have time.  But the same kind of regulation was proposed in the 1980s and the manufacturers of on art conservation product just switched to pentachlorophenol laureate and keep selling it.  Is this reg going to apply to pentachlorophenol's many siblings?
>
I glanced through the EPA announcement on this and I don't see any indication that it addresses any sibling chemicals. The comments seem focused on waste management aspects of pentachlorophenol itself.

It's a little spooky that chromated arsenicals are considered a green alternative to anything...

- Ralph

Ralph Stuart, CIH, CCHO
ralph**At_Symbol_Here**rstuartcih.org


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