Rachel's Precaution Reporter #60
Wednesday, October 18, 2006

From: Washington State Public Health Association .........[This story printer-friendly]
October 16, 2006

WASHINGTON STATE PUBLIC HEALTH ASSOCIATION ADOPTS PRECAUTION

[Rachel's introduction: The Washington State Public Health Association endorsed the precautionary principle October 16 "as a vital component of our preventive approach to public health in Washington State, advancing the goal that all people have an opportunity to reach and maintain their full potential."]

Title: Endorsing the Precautionary Principle as a Public Health Tool for Preventing Harm from Persistent Bioaccumulative Toxic Chemicals (PBTs)

Whereas: Every resident of Washington State has an equal right to conditions that protect and promote human health, including a healthy and safe environment, with all children of Washington State having an equal right to conditions that ensure they can reach and maintain their full potential, and

Whereas: Washington State recognizes that "health is a state of complete physical, mental and social wellbeing, not merely the absence of disease or infirmity" and a fundamental human right[1]; and

Whereas: Many conditions, including asthma, cancer, Alzheimer's disease, Parkinson's disease, birth defects, behavioral disorders, Autism, and chemical sensitivities, have been linked to environmental toxicants which incur enormous individual and societal costs in Washington State[2] and nationally[3]; and

Whereas: This growing knowledge confers an ethical responsibility and duty to make decisions that promote and maintain human and environmental health, thereby preventing disease, illness or disability[4,5]; and

Whereas: A principle for guiding activities to promote a healthy and safe environment and encourage human health is known as the Precautionary Principle, which consists of four basic elements: 1) taking preventive action in the face of uncertainty, 2) shifting the burden of responsibility of safety to the proponents of an activity; 3) exploring and implementing safer alternatives to possibly harmful actions, and 4) increasing public participation in decision making; and

Whereas: While scientific studies have determined that even low-level exposures to PBTs may cause serious and permanent health and neurodevelopmental harm, it is difficult to directly attribute a particular exposure to a particular illness or injury, emphasizing the need to take action to prevent harm[6]; and

Whereas: The precautionary principle holds that when an activity threatens harm to human health or to the environment, precautionary measures should be taken, even if cause-and- effect relationships are not fully established scientifically[7,8]; and

Whereas: Taking precautionary action is the common sense idea behind many adages, such as "be careful", "better safe than sorry" and "look before you leap" and is inherent in the understanding of the Hippocratic oath of "first, do no harm", in essence, the principle goes hand in hand with prevention, the cornerstone of public health; and

Whereas: Precautionary action is the basis of many activities designed to protect the health and safety of United States citizens, such as requirements of the federal Food and Drug Administration to ensure that new drugs are efficacious and safe before being placed on the market, requirements of the federal Occupational Safety and Health Act of 1970 that require employers to provide safe workplaces and working conditions, and the Food Quality Protection Act of 1996 that acknowledges additional protection for children; and

Whereas: The precautionary principle has been incorporated in international environmental treaties and in health, environment and educational policies of numerous governmental entities in the United States, including the city of San Francisco, and that Seattle includes a statement on the precautionary principle in the City's Comprehensive Plan[9, 13]; and

Whereas: The precautionary principle is a highly effective decision- making tool for reducing negative and costly effects on human health resulting from exposure to environmental toxicants[10]; and

Whereas: The Washington State Department of Ecology has developed a comprehensive strategy, based on preventing harm to human and environmental health, to reduce and eventually eliminate persistent bioaccumulative toxic chemicals (PBTs), further developing an accompanying PBT Rule which incorporates tenets of prevention [11,12] and

Whereas: The Washington State Departments of Ecology and Health have developed chemical action plans recommending phase out of mercury[13] and polybrominated diphenyl ethers (PBDEs)[14] in order to protect human and environmental health; and

Whereas: The precautionary principle's preventive foundation promotes environmental and economic justice to protect the environment and to safeguard the health of all people of Washington State; and

Whereas: The precautionary principle has been endorsed by the American Public Health Association, with the APHA stating it "Reaffirms its explicit endorsement of the precautionary principle as a cornerstone of preventive public health policy and practice[15,16,17] and by hundreds of other organizations nationally and internationally, including the American Nurses Association[18]

Therefore, Be It

Resolved, that: The Washington State Public Health Association (WSPHA) endorses the Precautionary Principle as a policy-making, educational and advocacy tool for preventing harm to health, behavior and neurodevelopment from exposures to PBTs in Washington State; and be it further

Resolved, that: The WSPHA endorses the precautionary principle as a vital component of our preventive approach to public health in Washington State, advancing the goal that all people have an opportunity to reach and maintain their full potential.

References

[1] WHO Alma-Ata Declaration (1978).

[2] Davies, K. Economic Costs of Diseases and Disabilities Attributable to Environmental Contaminants in Washington State. Davies, K. "How Much Do Environmental Disabilities and Diseases Cost?"; Northwest Public Health; Fall/Winter 2005.

[3] Landrigan, P. J., Schechter, C. B., Lipton, J. M., Fahs, M. C., and Schwartz, J. (2002). Environmental pollutants and disease in American children: estimates of morbidity, mortality, and costs for lead poisoning, asthma, cancer, and developmental disabilities. Environ Health Perspect 110, 721-8.

[4] Gilbert, S. (2005). Ethical, Legal, and Social Issues: Our Children's Future. Neurotoxicology 27.

[5] Rosenblatt, R. A. (2005). Ecological change and the future of the human species: can physicians make a difference? Ann Fam Med 3, 173-6.

[6]. Szpir, Michael. Tracing the Origins of Autism: A Spectrum of New Studies; Environmental Health Perspectives Volume 114, Number 7, July 2006.

[7] Tickner, J. A. (2002). Precautionary principle encourages policies that protect human health and the environment in the face of uncertain risks. Public Health Rep 117, 493-7.

[8] Gilbert, S.G. (2005). Public Health and The Precautionary Principle. Northwest Public Health, Spring/Summer 2005, 4.

[9] Environment Element, City of Seattle's Comprehensive Plan, Department of Planning & Development (2005).

[10] Ashford, N. A. (2004). Implementing the Precautionary Principle: incorporating science, technology, fairness, and accountability in environmental, health, and safety decisions. Int J Occup Med Environ Health 17, 59-67.

[11] Washington State Department of Ecology; Proposed Strategy to Continually Reduce Persistent Bioaccumulative Toxins (PBTs) in Washington State, Ecology publication #00-03-054;

[12] Washington State Department of Ecology, PBT Rule Chapter 173-333 WAC;

[13] Washington State Department of Ecology and Department of Health; Washington's Mercury Chemical Action Plan;

[14] Washington State Department of Ecology and Department of Health; PBDE Chemical Action Plan

[15] Raffensperger, C., Tickner, J., ed. (1999). Protecting Public Health & the Environment: Implementing the Precautionary Principle. Island Press, Washington, D.C.

[16] APHA Policy Statement #9606: The Precautionary Principle and Chemical Exposure Standards for the Workplace. APHA Policy Statements; 1948-present, cumulative. Washington, DC: American Public Health Association.

[17] APHA Policy Statement #200011: The Precautionary Principle and Children's health. APHA Policy Statements; 1948-present, cumulative. Washington, DC: American Public Health Association.

[18] List of endorsing organizations as well as additional information on the Precautionary Principle is in the Seattle Precautionary Principle White Paper: A Policy Framework for Adopting the Precautionary Principle. The white paper and more updated date information is available here.

Individuals and Organizations Endorsing the Resolution, "Endorsing the Precautionary Principle as a Public Health Tool for Preventing Harm from Persistent Bioaccumulative Toxic Chemicals (PBTs):

Karen Bowman, MN, RN, COHN-S Washington State Association of Environmental and Occupational Health Nurses

Patricia Butterfield, PhD, RN Professor and Chair, Dept. of Psychosocial and Community Health Nursing University of Washington

Judy Huntington, MN, RN Executive Director Washington State Nurses Association

Elise Miller, M, Ed. Institute for Children's Environmental Health

Molly Parker MD, MPH

Janet Primomo, PhD, RN Associate Professor, University of Washington, Tacoma

L.B. Sandy Rock, MD, MPH

Margaret Shield, PhD Coordinator, Toxic-Free Legacy Coalition

Washington State Nurses Association

Washington Physicians for Social Responsibility

Institute of Neurotoxicology & Neurological Disorders

Institute for Children's Environmental Health

Selected State Organizations Which have Publicly Supported Phase Out of PBTs

Washington State Public Health Association Washington State Medical Association Washington Academy of Family Physicians Washington Chapter of the American Academy of Pediatrics Washington State Nurses Association Washington Physicians for Social Responsibility Washington State Association of Occupational Health Nurses

Selected Organizations Supporting Precautionary Principle

American Public Health Association -- The Precautionary Principle and Children's Health -- The Precautionary Principle and Chemical Exposure Standards for the Workplace -- (APHA-pdf)

American Public Health Association (2002) -- The Precautionary Principle and Children's Health American Nurses Association Washington State Nurses Association, Supporting Precautionary Approach Towards Occupational and Environmental Health American Commission for Environmental Cooperation -- North American Environmental Law and Policy Series, Volume 10 Access to environmental information / The precautionary principle. (accessed: 13 June 2005). Physicians for Social Responsibility (National PSR) Washington Physicians for Social Responsibility City of San Francisco (2002) -- SF Precautionary Principle Ordinance Los Angeles Unified School District (2nd largest district in USA) City of Seattle; Introduction to Comprehensive Plan Berkeley City Council Resolution, October 2003, which also called for the development of a precautionary principle ordinance, beginning with an Environmentally Preferable Purchasing Policy within a year. California Cal/EPA -- Environmental Justice Action Plan Portland, Oregon Earth Charter World Trade Center Clean Up -- NYCOSH statement

Submitting Primary Author: Steven G. Gilbert, PhD, DABT -- WSPHA Member -- Yes INND (Institute of Neurotoxicology & Neurological Disorders) 8232 14th Ave NE Seattle, WA 98115 Ph: 206.527.0926 Fx: 206.525.5102 E-mail: sgilbert@innd.org Web: www.asmalldoseof.org

Co-Author: Kate Davies, M.A., D.Phil. -- WSPHA Member -- Yes Core Faculty, Environment & Community Antioch University Seattle 2326 Sixth Avenue Seattle, WA 98121 206 268 4811 kdavies@antiochsea.edu

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From: Washington State Public Health Association .........[This story printer-friendly]
October 16, 2006

WASHINGTON PUBLIC HEALTH ASSOCIATION ENDORSES CHEMICAL PHASEOUTS

[Rachel's introduction: The Washington State Public Health Association on October 16 adopted a resolution endorsing the phaseout of persistent bioaccumulative toxic chemicals.]

Resolution

Submittal: October 2006 Annual Meeting

Title: Supporting Safer Chemicals Policies to Benefit Human and Environmental Health

Whereas: Harmful chemical exposures pose the greatest threat to children and women before and through reproductive age, impacting children's health, development, behavior and learning, with exposure to neurotoxic chemicals in critical child development periods linked to lifelong deficits in brain function[1]; and

Whereas: The 'chemical trespass' nature of toxic environmental exposures makes it difficult or impossible for persons to opt out of exposure on behalf of themselves or their children, necessitating societal measures to protect people, especially children, against exposure, since many of the chemicals are ubiquitous and personal action has limited ability to reduce exposure; and

Whereas: Persistent bioaccumulative toxic chemicals (PBTs) are linked to serious health effects including birth defects, learning and behavioral disorders in young children, cancers, and reproductive failure[2]; and

Whereas: PBTs persist in the environment, bioaccumulate and biomagnify in food chains[3]; and

Whereas: Studies have found high levels of PBTs, polychlorinated biphenyls (PCB)s, lead and polybrominated diphenyl ethers (PBDEs) as well as other hazardous chemicals such as pesticides and phthalates, in the bodies and homes of Washington residents[4]; and

Whereas: The risk evaluation of PBTs is commonly calculated on individual chemicals while children and the general population are exposed to multiple chemicals and the risks of these mixtures have not been assessed; and

Whereas: Recent scientific studies have documented rapidly rising levels of PBDEs in human breast milk, with levels in Puget Sound women documented at levels from 20 to 40 times higher than their European and Japanese counterparts[5]; and

Whereas: The Centers for Disease Control (CDC) has conducted body burden testing through urine and blood samples, with study results finding significant levels of dioxins, heavy metals, pesticides and other chemicals[6]; and

Whereas: A small-scale body burden study has been conducted in Washington State, the Pollution in People report, showing the presence of at least 26 and as many as 39 toxic chemicals in 10 individuals[7]; and

Whereas: In addition to health impacts suffered by families, individuals, and children, significant economic costs are associated with illnesses linked to environmental exposures, with over $2 billion per year in health care costs tied to diseases and disabilities linked to environmental contaminants[8]; and

Whereas: More than half of the over 15,000 high-production- volume synthetic chemicals used widely in consumer products and dispersed into the environment, are untested for toxicity[9]; and

Whereas: Companies, once motivated to adopt alternative measures, have demonstrated the feasibility of using safer materials, chemicals and processes, and

Whereas: Phasing out the use of potentially toxic chemicals is an essential step in reducing these exposures in crucial fetal, infant and childhood stages of development, as well as reducing these exposures in general populations, through environmental, including fish, contamination[10]; and

Whereas: The Washington State Department of Ecology has finalized its Regulation on Persistent Bioaccumulative Toxic Chemicals, addressing phase out of PBTs[11]; and

Whereas: The Washington State Public Health Association supports the elimination of PBTs, in order to keep persistent toxic chemicals from entering the environment in order to prevent harmful exposures"[12], including elimination of PBDEs[13];

Therefore, Be It

Resolved, that: The Washington State Public Health Association (WSPHA) supports safer chemical policies to achieve the phase out of hazardous chemicals, including persistent bioaccumulative toxic chemicals; and, be it further

Resolved, that: The WSPHA encourages further development and use of safer, cost-effective alternative products, materials, and processes, including research and development of 'green chemistry', which encourages chemical technologies that reduce or eliminate the use or generation of hazardous substances in the design, manufacture, and use of chemical products[14]; and, be it further

Resolved, that: The WSPHA urges that companies be required to provide full information on the health effects of all chemicals placed into the marketplace, with particular attention to potential effects in groups at life stages most harmed by chemical insults, e.g. young children and women who are pregnant or nursing.

[1] Chemicals in the environment and developmental toxicity in children: A public health and policy perspective. Environmental Health Perspective, 108 (3), S443-S448; Goldman, L.R. and Koduru, S.H. (2000).

[2] Environmental Protection Agency; Persistent Bioaccumulative Toxic Chemical Program; About PBTs

[3] Ibid.

[4] Sick of Dust: New Report Finds Hazardous Chemicals in Household Dust; March, 2005. And: Flame Retardants in the Bodies of Norwest Residents; Northwest Environmental Watch, Sept. 2004

[5] Northwest Environmental Watch: Flame Retardants in Puget Sound Residents, First Round of Results from a Study on Toxic Body Burdens; February 2004: p. 2

[6] Centers for Disease Control and Prevention. (2005). Third national report on human exposure to environmental chemicals. Atlanta, GA

[7] "Pollution in People: A Study of Toxic Chemicals in Washingtonians"; Schreder, Erika, Washington Toxics Coalition; May, 2006.

[8] "What We Know and What We Need to Know", January, 2005 Davies, Kate, MA, DPhil;

[9] Children's Health and the Environment: A New Agenda for Prevention Research; Philip J. Landrigan,1 Joy E. Carlson,2 Cynthia F. Bearer; Volume 106, Number S3, June 1998

[10] Madsen, Travis and et al. Growing Threats: Toxic Flame Retardants and Children's Health, 2003 and Schecter, Arnold, MD, Birnbaum, Linda, et.al. Polybrominated Ethers (PBDEs) in US Mothers' Milk Environmental Health Perspectives Volume 111 Number 14 November 2003, p: 1723-1729

[11] Washington State Department of Ecology, Persistent Bioaccumulative Toxins Regulation; February, 2006

[12] Washington State Public Health Association, 2004 Support Letter for Phasing Out Persistent Bioaccumulative Toxic Chemicals

[13] Adopted Resolution #-04-03 : Protecting Public Health by Phasing Out Polybrominated Diphenyl Ethers (PBDEs) -- Toxic Flame Retardants 2003-2004.

[14] US Environmental Protection Agency; Green Chemistry Mission Statement; Green Chemistry: Making It Real in the World. Collaborative on Health and the Environment Partnership Call. June 19, 2006. Transcript and background resources available here.

Individuals Endorsing Resolution "Supporting Safer Chemicals Policies to Benefit Human and Environmental Health":

L.B. Sandy Rock, MD, MPH

Richard Grady, MD Co-Chair, Environment & Human Health Committee Washington Physicians for Social Responsibility

Therese M. Grant, PhD

Laura Hart, MD

J. David Heywood, MD

Sally Goodwin, MD

Charles E. Weems, MD

Katherine Davies M.A., D.Phil.

Janet Primomo, PhD, RN

Karen Bowman, MN, RN, COHN-S

Martin D. Fleck Executive Director Washington Physicians for Social Responsibility

Selected List of Organizations Supporting Phase out of PBTs, including PBDEs, through either resolution, or through letters presented to the Washington State legislature:

Washington State Public Health Association Washington Chapter of the American Academy of Pediatrics Washington State Medical Association Washington Academy of Family Physicians Washington State Nurses Association Washington Physicians for Social Responsibility Washington State Association of Occupational Health Nurses Institute of Neurotoxicology & Neurological Disorders Institute for Children's Environmental Health

Submitting Authors:

Submitting Primary Author: Steven G. Gilbert, PhD, DABT -- WSPHA Member -- Yes INND (Institute of Neurotoxicology & Neurological Disorders) 8232 14th Ave NE Seattle, WA 98115 Ph: 206.527.0926 Fx: 206.525.5102 E-mail: sgilbert@innd.org Web: www.asmalldoseof.org

Co-Author: Nancy Dickeman, MA -- WSPHA Member -- Yes Toxics Coordinator Washington Physicians for Social Responsibility 4554 -- 12th Ave NE Seattle WA 98105 Ph: (206) 547-2630 -- main office (206) 354-2170 -- cell nancyd@wpsr.org

Co-Author: Margaret Shield, PhD -- WSPHA Member -- Yes Coalition Coordinator, Toxic-Free Legacy Coalition 4649 Sunnyside Ave N, Ste. 540 Seattle WA 98103 Ph: 206-632-1545 ext 123 mshield@toxicfreelegacy.org

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From: Environmental Commons ..............................[This story printer-friendly]
October 12, 2006

MENDOCINO COUNTY MOVES FORWARD WITH PRECAUTION POLICY

[Rachel's introduction: Mendocino County, California, will apply precaution to stormwater runoff.]

By Britt Bailey

The precautionary principle was adopted as county-wide policy in Mendocino County, California June 28, 2006. The county has now identified two departments to begin implementing a pilot project incorporating the principle in decision-making.

The County Executive's Office has chosen the Water Agency and the Environmental Health deoartments. The project proposed as a pilot is the Stormwater Discharge Program. This offers a very exciting prospect because the Plan has a clearly precautionary intent-- to decrease the amount of toxins, pesticides, fertilizers, pathogens, metals, etc... getting into untreated waters, including streams and rivers receiving runoff from impervious surfaces and land uses.

We believe that applying the Precautionary Principle to this existing and required program will result in reducing untreated discharges that contribute high levels of pollutants to receiving water bodies. Pollutant levels from these illicit discharges have been shown in EPA studies to be high enough to significantly degrade water quality and threaten aquatic, wildlife, and human health.

The Mendocino Partnership for the Precautionary Principle invites the public to get involved as we move forward with incorporating the Precautionary Principle into the Stormwater Discharge Plan. A key piece of the Precautionary Principle involves public participation. Public meetings will be announced on our website. The next meeting will be held in November. We will be sending an announcement when the date and time is finalized.

Please see latest update to the website:

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From: Greenwire ..........................................[This story printer-friendly]
October 13, 2006

INDUSTRY GIRDS FOR SPRAWLING E.U. REGULATORY SCHEME

[Rachel's introduction: The chemical industry continues to oppose REACH, Europe's proposed new precautionary chemicals policy -- but the handwriting is on the wall. REACH is coming, in one form or another.]

By Russell J. Dinnage

A landmark European Commission plan for overhauling chemical regulations is on its way to becoming law.

Five years in the making, REACH -- the Registration, Evaluation, Authorization and Restriction of Chemicals Act -- is a 600-page tome that has been making the rounds in government offices and corporate headquarters throughout Europe, generating thousands of public comments for European Union officials to review. The proposal is on track to become law sometime next year.

Some experts are questioning U.S. readiness for a such a sweeping proposal that figures to reshape the global regulatory landscape for chemical manufacturers and all businesses that use chemicals.

"Businesses in the United States are completely not focused on this topic," said Angela Logomasini, who tracks risk and environmental policy for the Washington-based Competitive Enterprise Institute. "The reality of REACH is that it will affect everything in the business. From downstream manufacturers, importers, domestic users -- people are not aware that it could become a globally focused phenomenon."

But it is not easy to assess REACH's effect on U.S. interests. There is, first of all, a lack of consensus about how deeply the law would dig into industry's bottom line.

The Bush administration, for example, considers REACH "a very important issue," but it has yet to produce an official evaluation of its potential economic impact on the U.S. chemical industry, said Matt Braud, spokesman for the Department of Commerce's International Trade Administration.

Nonetheless, the administration has a strong opinion on REACH. "In our view, and as expressed by many other governments, the E.U.'s proposal remains overly expansive, burdensome and would be difficult to implement effectively," Braud said. "We believe the E.U.'s stated objectives of protecting human health and the environment are worthy policy goals; however, achieving those goals must be applied in ways that are consistent with the E.U.'s obligations to its trading partners under the World Trade Organization."

Small and mid-sized U.S. chemical companies are keenly aware of REACH "and are actively preparing for its impacts," said Jim Cooper, a spokesman for the Synthetic Organic Chemical Manufacturers Association.

The American Chemistry Council, which represents large companies, did not return calls for comment on REACH's potential financial effect, and DuPont Chemical Corp. spokesman Dan Turner said the company is examining REACH but it does not have any comprehensive financial impact estimates yet. A price tag in the billions

REACH would require the registration of more than 30,000 chemical substances used in manufacturing within 11 years for the stated purpose of protecting human and environmental health. The proposal resembles the Federal Insecticide, Fungicide and Rodenticide Act, which regulates pesticides in the United States.

A November 2005 Government Accountability Office report said REACH would "eliminate the distinction between new and existing chemicals and require chemical companies to submit certain basic information on chemical products produced over certain volumes."

Specifically, REACH affects all chemicals manufactured in or imported into the European Union in quantities of 1,000 kilograms (2,204.6 pounds) or more.

REACH's Article 23 requires all chemical companies doing business in Europe to submit testing data to the new European Chemicals Agency. If a substance has qualities deemed "carcinogenic, mutagenic or toxic," further testing must be conducted at a company's expensive on animals and results submitted to the agency for a safety review.

Of 30,000 substances expected to come under regulation in 2010, 1,500 are estimated to have carcinogenic qualities, the European Union says.

No one can say with certainty how much it will cost to register a substance. But the E.U.'s 2003 "Extended Impact Assessment" estimates it would cost about $250,000 per chemical -- or $15 billion for the industry as a whole over the 11 to 15 years it is expected to take to fully implement the regulation.

Another study -- "E.U. 2004 REACH: the Impact of REACH" -- puts the total industry testing cost at $3 billion and estimates that it will cost between $10,000 to $37,000 to register a single substance, depending on the size of the registration and whether animal testing is needed.

And then there is a study by the German chemical industry association, BDI, predicting REACH will cause a 1.4 percent loss of production for German manufacturers and the loss of 150,000 to 2.3 million jobs.

Cooper, of the chemical manufacturers group, predicts testing will quickly become an expensive burden. "Most of the official estimates from the European Commission... do not seem to take into account administrative costs, analytical method development, consulting fees, interpretation of test results and other potential burdens," he said. Cooper's group puts the cost of screening level tests for a single chemical at about $250,000."For some chemicals, it will be in the millions of dollars," Cooper said. "As with certain pesticides, companies will probably choose to leave those markets rather than pay for the testing."

Deadline looms

Most U.S. companies preparing for REACH implementation are pointing to the 2008 deadline for pre-registering chemicals. A chemical that is not pre-registered cannot be sold in the European Union.

Rob Donkers, the environment counselor to the European Commission's U.S. delegation, said a manufacturer can pre-register by sending an e- mail or even a postcard to the European Chemicals Agency that includes the name of the company and the substances they want to register.

"It's just to signal an intention to be involved in the program and does not stop production or importation," Donkers said. He dismissed the 2004 E.U. study that says industry pre-registration costs would range from $62 million to $125 million.

But Cooper and Logomasini see the pre-registration being a lot more complicated than Donkers maintains.

"It is unlikely that the E.U. will have the resources or infrastructure in place to handle all of the pre-registrations, let alone sorting through them all and determining which companies should be playing in which sandboxes," Cooper said.

Said Logomasini: "The fact that the E.U. officials are saying all pre- registration will require is for a company to send in a postcard shows that they have no idea what they are doing."

'A driver for innovation'

REACH is currently being read, debated and amended in the European Parliament's Environment Committee. From there, it will likely go to a plenary session of the full parliament the week of Nov. 13, Donkers said (Greenwire, Oct. 10).

After a full parliament vote, he said, the measure will go to the Council of Minister for a second reading in early December, when the ministers will decide on new amendments. If there is contention over the amendments, the proposal will go to a conference committee next March for a vote on proposed changes.

"So by the summer of 2007... we will see full passage," Donkers said. It would still take "another few years" until various administrative agencies and the act "can be implemented effectively on a day-to-day basis."

Donkers predicted that REACH would "serve as a driver for manufacturing and process innovation" and assure consumers that products are safe.

"REACH will benefit companies that are more responsive and have a no- questions-needed attitude about the safety of their products," Donkers said. "Industries that are responsible will have a competitive edge under REACH."

But Logomasini said REACH will present a global regulatory morass for industry.

"Quite frankly they have no idea what they are doing in Europe," Logomasini said. "There's no enforcement plan for this act. The E.U. is simply saying 'trust us,' but even they don't know what it's going to cost. It just doesn't seem rational, and I don't think we should trust the bureaucracy when they say the impact will be minimal."

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Rachel's Precaution Reporter offers news, views and practical examples of the Precautionary Principle, or Foresight Principle, in action. The Precautionary Principle is a modern way of making decisions, to minimize harm. Rachel's Precaution Reporter tries to answer such questions as, Why do we need the precautionary principle? Who is using precaution? Who is opposing precaution?

We often include attacks on the precautionary principle because we believe it is essential for advocates of precaution to know what their adversaries are saying, just as abolitionists in 1830 needed to know the arguments used by slaveholders.

Rachel's Precaution Reporter is published as often as necessary to provide readers with up-to-date coverage of the subject.

As you come across stories that illustrate the precautionary principle -- or the need for the precautionary principle -- please Email them to us at rpr@rachel.org.

Editors:
Peter Montague - peter@rachel.org
Tim Montague - tim@rachel.org

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