Forbes_Letter_and+Stanford_UCB+response,+July+2010 -...

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RESPONSE TO OPINION PIECE BY DR. HENRY I. MILLER (“California’s Bad Chemistry”) PUBLISHED AT on July 14, 2010 As scientists who carry out research on the synthesis, use, and fate of chemicals, we respectfully disagree with our colleague Henry Miller in his July 14 opinion piece on California's Green Chemistry Initiative, a proactive effort that has the potential to establish a scientifically robust process for identifying unsafe chemicals in consumer products and stimulating the development of safer alternatives. While there are some areas of the draft regulations that can and should be improved, Miller’s criticisms are not substantive. Almost every day another consumer product is found to contain chemicals that none of us would knowingly want our children, or ourselves, to be exposed to. Chemical after chemical is banned, often to be replaced by a substitute chemical that poses risks that are similar to or worse than the original, or that are unknown. Banning individual chemicals is ineffective and expensive. We need a systematic process in place to identify those chemicals of greatest concern, provide an analysis of safer alternatives, and give consumers and businesses vital information about the products they purchase. Dr. Miller criticizes California's draft regulation as ignoring "unintended consequences". But this regulation was designed to avoid the "unintended consequences" that occur when substitute chemicals turn out to be harmful. California will specifically require that any substitute chemical go through the same analysis required of the original chemical. It’s a “win win win”: the consumer gets a better product, the manufacturer avoids a costly recall, and Californians do not suffer years of exposure before finding out that a replacement chemical was a "regrettable substitute." While Miller raises the point that "the dose makes the poison," it is well recognized in toxicology that many factors affect dose, such as the conditions under which a chemical is used. Evidence is also mounting that some chemicals, such as endocrine disruptors, have toxic effects at minute doses (parts per trillion). Clearly it makes sense to prioritize chemicals based on their potential for exposure and toxicity. And that is precisely the point of the draft regulation’s “Guiding Precepts” (Section 36301.1): “prioritization processes should seek to identify and give priority to those chemicals…that pose the greatest public health and environmental threats, are most prevalently distributed…and for which there is the greatest potential for consumers or environmental receptors to be exposed … in quantities that can result in public health or environmental harm.” Another principle outlined in the draft regulation is that solvents be phased out "when possible." The solvents in question are not benign solvents, such as water, but rather toxic organic solvents that threaten groundwater supplies. Some of these solvents cause cancer. The
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  • Fall '10
  • Rafinejad
  • Stanford University, DR. HENRY I. MILLER, Engineering  Stanford University, Green  Chemistry, Green  Chemistry Initiative

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Forbes_Letter_and+Stanford_UCB+response,+July+2010 -...

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