Are "Chemicals of Concern" Lists Really Blacklists for Chemicals?

As the TSCA reform process moves in fits and starts, with serious questions being raised recently because of the poor health of its major sponsor, Senator Lautenberg, and the continuing anti-science politics of the ranking minority member, one question floats to the surface. Does creation of a "concern list" mean that those chemicals will become blacklisted on the marketplace?

In short, probably yes.

Many countries have what can be called "negative lists," that is, lists of chemicals that the country believes are in need of either greater scrutiny to discern risk, or where risk has already been found to be unacceptable and the chemicals are slated to be banned or severely restricted. Besides the country by country lists, there are also international negative lists of chemicals to be banned or restricted, e.g., the persistent organic pollutants and CFCs in the Stockholm Convention and Montreal Protocols. There are also "positive lists" in which chemicals are added after they have been evaluated and found to be safe. It's possible we may be headed in the positive list direction with the new TSCA, but for now let's focus on the negative lists.

EPA has indicated in its recently released "action plans" that it will use one of the authorities it already has under the existing TSCA law to create what is called a Section 5(b)(4) Concern List. In Europe, the REACH regulation, which requires registration of all chemicals, both existing and new, also has a separate track called Authorization (the "A" in REACH). Under Authorization the new European Chemicals Agency periodically publishes a list of "candidate chemicals" that are "substances of very high concern" that will then be evaluated for possible banning and restriction.

The result of these "negative lists" is the same as for other negative lists, including ones such as the Wal-Mart list of chemicals they do not want to see in their products. Formulators and end product makers get pressure from consumers to remove these "bad chemicals" from their products, so they start to push back on their suppliers, who push back on the manufacturers of the basic chemicals, who start looking for alternatives that provide the same functionality without the risk.

So is this a good thing? Well, yes and no. Often a chemical gets targeted not so much for its actual risk but for its perceived risk or for its hazard, which because of the lack of exposure may actually not cause a risk at all. On the other hand, without any kind of pressure to replace inherently hazardous materials with inherently less hazardous ones, there isn't any incentive for companies to find alternatives. Why would a company spend a lot of money doing R&D to find a chemical to replace one that they already make, has extensive market penetration, and brings them significant profit? They won't, at least unless the manufacturer believes that some future event or change in attitudes or policy will cause his original chemical to become less favorable to the market. For market forces to work there has to be the potential for significant upside return on investment. Consumers have indicated they are willing to pay a little more to purchase more sustainable products, though it is often difficult to know if new products, e.g., cleaning products, are "green washers" versus "greenwashing." But without there being a way to identify "problem chemicals," the consumer has no way to make informed choices in the market place. Thus their only recourse is to assume that all chemicals in all products have been adequately tested and found to be safe. Consumers have come to realize that that is not the case and thus are less willing to simply take it for granted. Hence, the reason why negative lists may be one mechanism to encourage greater review of chemical safety.

Scientist Norman Borlaug, "Father of the Green Revolution," Has Died

The man known as the "father of the green revolution," agricultural scientist Norman Borlaug, has died at the age of 95.

Many probably have never heard of Norman Borlaug, but he arguably did more to increase crop yields and reduce hunger in developing countries than any other individual. His research and activism in bringing the benefits of that research direct to the farmers both here and abroad led to a movement that came to be known as the "green revolution." And because of it, world food production more than doubled in the thirty years between 1960 and 1990. In two countries that benefited most from the new crop varieties, Pakistan and India, yields of wheat and other grains more than quadrupled over that period.

While most scientists toil without recognition for most of their careers, Borlaug was one of only five people who have won all of the Nobel Peace Prize, the Presidential Medal of Freedom and the Congressional Gold Medal. To that he can add the Padma Vibhushan, which is awarded by the President of India to "recognize exceptional and distinguished service to the nation in any field..." According to his Wiki article, Borlaug's discoveries have been estimated to have saved over 245 million lives worldwide (others estimate the green revolution averted global famine during the second half of the 20th century, which saved perhaps 1 billion lives worldwide). His work in India and Mexico are well known in agricultural, scientific, and humanitarian circles.

Needless to say, with an impact that large there were also criticisms. The green revolution, and Borlaug's programs involving genetic cross-breeding of plant species, were seen by some as being unnatural. In addition, large scale monocultures (picture a large expanse of wheat or corn fields) tend to reduce biodiversity, in addition to often increasing the amount of pesticides and fertilizers used, which can be damaging to the top soil and the subsistence farming of rural families in under-developed areas. Another concern is that these techniques create large profits for agribusiness and agrichemical corporations while widening social inequality in the recipient countries. While these concerns may be valid, Borlaug felt that keeping people from starving more than compensated for any of these drawbacks.

Scientists who speak out for the science (even if it's just to correct the misrepresentations that others make of that science), are sometimes looked on with disdain both by those for whom the science is ideologically inconvenient and by pure scientists who feel the scientist should remain in the lab and let others handle policy. Borlaug had a different philosophy. According to a wonderful article just published about him:

Equal parts scientist and humanitarian, the Iowa-born Borlaug realized improved crop varieties were just part of the answer, and pressed governments for farmer-friendly economic policies and improved infrastructure to make markets accessible.

We should remember that without scientists informing our policy-makers, our rivers would still be catching fire, our neighborhoods would still be exposing us to toxic waste, our country would have never made it to the moon, our air would still be thick enough to see (and kill), and our existence and that of many other species on this planet would come into question.