The Blessed Margot on REACH.

Yes, she’s back, the blogosphere’s most overpaid leafleter, the Ever Fragrant and Blessed Margot Wallstrom favours us with her thoughts on the REACH Directive!! Stop the Presses and Alert the Media as we look into quite how badly an adult woman can misundertand economics! Fresh from her stunning success with this comment, (A deregulated market for air travel has created a bigger need for consumer/passenger protection.) our star of stage, screen and politics issues forth to defend her decision as Environment Commissioner to cripple European Industry, stifle innovation and pauperize our grandchildren! Roll Up, Roll Up for the show!!

Now I wouldn’t want to claim too much credit here but I do think that her decision to address REACH has at least a little bit to do with this comment that landed on her blog and the subsequent newspaper coverage of the subject. So I’ll claim some credit. So, with my annotations, here is what Margot says:

Several years ago I had a specialist doctor visiting me and he claimed that today’s adults have between 200 and 500 chemicals in their blood, substances that would not have been found in our grandfathers‘ or grandmothers‘ bodies. So I had my own blood tested for 77 chemicals whereof 28 were found; among them PCB and DBT (banned a long time ago in Europe). Most scary is that I have passed on a substantial amount of chemicals to my children through breastfeeding. This is not the stuff I want my boys to inherit first thing!

Yes, we know this story. So far you’ve told us that pan-European laws are imposed because middle aged women worry about their health. Fine. Now, think a little, yes, I know, a difficult process for some. These 28 chemicals in your body...have they done you any harm? Is there any evidence at all that any or all of them are going to cause you to so much as sneeze let alone take a nano second off your life span? No? So why are we spending, in the case of PCB for example, billions in banning its use and replacement with less effective (and more costly) alternatives? No, I’m not suggesting that it would be a good thing for children to mix into their porridge, but given the well known fact that it is the dose that makes the poison, are we absolutely certain that those tiny amounts are actually doing you any harm?

We are all exposed to thousands of chemicals on a daily basis. We find them in food, cosmetics, clothes, furniture, buildings, cars and electronic equipment.

and dogs and cats, and trees, walls, dirt, bodily fluids, last night’s fish supper and the pages of the thesaurus from which I cannot be bothered to continue the list. In fact, those pesky little chemicals get just everywhere, just won’t sit still for a moment. Grab a dictionary, shake all the nouns out of it and look at the pile you have there. All the things that those words represent are made of, you guessed it, chemicals. Really! Every physical object in the universe is made up of...chemicals! There’s 93 (or so, plutonium and americum are man made and we do worry about them and promethium is one of the 92 natural ones but at any one time there’s about 40 g on the planet so we don’t) elements that we worry about, and all things and everything are made up of varying combinations of them...what we call chemicals! You seem to be complaining that we live in the physical universe.

Most of them harmless, presumably, but more and more of the modern chemicals have inherent properties that are very dangerous; carcinogenic, toxic or hormone disturbing. Asbestos IS classified as a chemical and an example of this!

Indeed asbestos is classified as a chemical and we’d all be a lot happier if you were able to distinguish between the three types, blue, brown and white...the white actually being an entirely different chemical. I’m also not sure why modern chemicals are so amazingly dangerous. Hemlock worked pretty well for Socrates all those years ago didn’t it?

As a result we have increasing health and environmental problems; like allergies, cancers and reproductive effects.

Beg pardon? The rise in allergies is usually put down to the excessive cleanliness of the modern lifestyle. Immune systems are not being primed. Cancers are decreasing as you very well know, when correctly measured on an age related basis. Reproductive effects? Which ones? You mean that one about declining sperm counts?  As Bjorn Lomborg pointed out the most likely explanation there (and I’m not sure that the study has been repeated) is that men are having sex more often.

Harmful substances turn up in places where they do not belong, for example in breast milk or human tissue. The painful truth is that we know very little about many of the chemicals on the market.

The usual course of action when you don’t know something is to go and find out. Would be an interesting starting point for a discussion don’t you think?

Our current legislation in the European Union is flawed. It creates an artificial divide between existing chemicals and “those put on the market before a certain year“ and new chemicals which have to undergo a very slow and cumbersome monitoring. This stifles innovation.

Good grief! you mean a slow and cumbersome monitoring process stifles innovation? Quelle Surprise! So why do we have a slow and cumbersome monitoring process then?  Might it not be a good idea to simplify the process? No, of course not, how silly of me, we need to extend that process to all the old chemicals as well, much better, eh?

The European Commission has proposed a new chemicals legislation called REACH (Registration, Evaluation, Authorisation of Chemicals) allowing for better knowledge about chemicals, creating producer responsibility and substituting the most hazardous substances. It will replace around 60 pieces of legislation with one European law on chemicals. The starting point for discussion on REACH was that the level of protection of health and the environment is insufficient.

Ooooh, dear, horrible logical sin that, known as petitio principii. You started at the point that current legislation was insufficient. No, where you should start is with the question "is the current level of protection sufficient?"....now I know that law makers never actually do that, for if the current state of the law is sufficient, what need therefore for law makers....and come up with an answer to that question. Across the continent life spans are lengthening, disease continues to retreat, the general health continues to improve, poisoning, from whatever cause, continues to fall....y’know, the objective evidence is that health and the environment are protected just fine.

Since then scientific evidence is adding to the concern: for example French scientists point to a rather dramatic infertility increase linked to the use of chemicals. And what more proof do we need: especially when children are the first victims of hazardous substances?!

Which French scientist points to what increase in infertility for what reason? Brewer’s Droop?  Specifics here please, not just that the sky is falling. It’s also rather droll to worry about the children when this supposedly chemical induced infertility means there aren’t any. On that basis you’d have to conclude that the pill is the worst thing going....and in terms of oestrogens turning up in drinking water you’d be right, all those  women planning their family size peeing into the rivers you see.

To all of you who worry about competitiveness for the very important, from an economic and employment point of view, European chemicals industry

– “Yes“ there is a cost to more testing and better monitoring of chemicals (corresponding to around 0.1% of the annual turnover of this business)

Hunh? 0.1%? Where did you get that number from? Are you still stuck in some 50’s corporatist mind warp? Where large companies are the ones that make everything, invent everything and innovate everything?  Sure, Bayer gets squiddely billions from aspirin but that ain’t where the innovation is. It’s in people like me, as I pointed out to you, playing with variations in alloys. REACH is going to cost 100% of our annual turnover. Well, it would, if we remained inside the EU. Which we won’t. Sorry, we’ve already made the decision to relocate, indeed, change the very basis of our business. 

but there is an even higher cost of not doing it! As figures from WHO (World Health Organisation) and our impact assessment show. The health impact and costs for society are enormous! – “Yes“ we have to find a cost effective and less administratively burdensome legislation, whilst preserving the aim of achieving better protection for health and the environment, but the chemicals industry has to look at this as an investment in a “user safe” label on their products and the new rules will stimulate innovation.

Can you imagine food or car producers refusing to test or control their products!
Why exempt chemicals?

No one is suggesting that people should not be responsible for or should not test their products. Absolutely no one. We are suggesting that the method which you, in your wisdom, decided upon is disastrous, futile, economically illiterate and one that will kill many more people than will be saved.
I need to introduce you to an economic concept, something called opportunity cost. We can only do one thing with one set of resources. What we spend on testing every chemical on the planet cannot then be spent on doing something else, like bringing clean water to the poor, finding a cure for AIDS or teaching EU Vice Presidents the economic facts of life, however much that last would be the best use of any given set of resources. By forcing every manufacturer of a compound or chemical to spend $100,000 on testing it you are doing three things:

1) Raising the cost of innovation to the huge detriment of economic growth. This will kill people as even a basic look at history will show you. Wealth makes people live longer.

2) Stop small companies innovating at all. As this is where most invention and innovation actually happens, you ’ve just stalled the economic growth engine. Your grandchildren will not thank you for this.

3) You are moving huge economic resources from one place to another...and as you are having to do it by regulation, clearly from a more productive to a less productive use. This inefficiency lowers the amount that we can devote to other desirable ends.

In effect, Margot dearest, by forcing huge expenditure on the trivial levels of chemicals found in your tits you are condemning other, less fortunate, of our human brethren to death as we will have pissed away our wealth instead of using it to help them.

Well done, proud of you.