Trying to keep track of what is safe and isn't is basically impossible for an individual.
I tried for years to avoid PFAS and friends, only to discover my sofa was covered in it.
What's the point.
But the problem here is that we just don't know. We know about a few worrisome problems and signs, but we don't have a clear picture like we do with lead or asbestos.
We could switch from "allow by default" to "deny by default", but I'm not even sure that would help. Often problems are hard to find even once its widespread.
We also don't want to foster a "chemicals are bad" attitude more than it already exists.
I think the right answer is more funding for long-term rigorous studies. That way we know.
There's no heuristic shortcut for actually learning about the subject. Without doing the homework, all we can say is that it seems plausible that there might be a problem.
But if you don't learn anything then you're just another person saying their opinion on the Internet, like the rest of us.
I don't see why so many people these days need to reduce everything to this type of false dichotomy.
And it's also a question of how much concern is enough? I would argue that currently the threshold is set far, far too high.
It's a choice we make all the time. For anything you read about, are you curious enough to investigate it further, or are you going to let it go by?
You work with what you have right now.
While emerging evidence should be used to change guidelines, we should not be at the mercy of corporations wishing to increase their profit margins with unknown chemicals.
You don't have to work with what you have only just invented and don't understand.
You're talking about bottles and pans. We have managed with bottles and pans for a thousand years before pfas.
Cast iron, steel, glass, ceramic
We have thousands of years of evidence that these things are safe
Edit: traditional? That's not even what that means anyway. Old?
Yes, but it's certainly possible to rule out entire classes of harms by asking the right questions before putting a product on the market. Maybe 100% safe is impossible but 99% is still a pretty low bar/standard when it comes to health/pollution risks.
The problem is in the current situation, corporations push toxic products on everyone that they either know to be toxic or really don't want to find out. Then we wait for people to get sick and die, then finally after it becomes a too big scandal for corporate PR and government regulators to pretend they didn't see, they start to maybe study the problem and issue guidelines.
This timeline is so broken and we see the same thing in the medical world where substances we'd known to be harmful for years/decades kept on being marketed and prescribed to unknowing patients. I personally have no faith in governments (who created or benefited from these abuses), but if you're a believer in regulations, the bare minimum they can do is publish 100% of toxicity claims/studies without any delay from submission (public inbox).
This could help in that whistleblowers are often coming forward with such claims (such as the EDF nuclear whistleblower lately) but it's hard for them to find a platform, and for the public to get informed.
One aspect we have, is defense materials being mass-produced for potentially large-scale warfare, then really raking in the bucks when a consumer application can be found. That way everybody wants some, not just soldiers. And if it's consumable, so much better since that calls for continuous mass-production. And where's it all going to end up? What part of the environment? Well, that's diferent for different materials.
Sometimes a material itself is highly disruptive, other times it's the vast quantities that end up being mass-produced.
Even then the risk of an unforseen toxic outcome has always been underestimated.
There's always some risk left no matter the rigor of testing. Shouldn't keep us from doing our best.
Slightly off topic: The recent movie starring Mark Ruffalo, Dark Water, is excellent. It covers PFAS and one lawyer’s fight to bring it to light. Very similar to the excellent “A Civil Action” starring John Travolta in the 90s or early 2000s (obligatory: the book is far better than the movie).
I dunno, I kinda think we do want to foster that.
Why don't we want to foster this? If some compound is unknown, it seems prudent to assume its a risk until proven otherwise. Then you can calculate whether or not the possible miniscule or nonexistent benefit is worth the potentially miniscule or catastrophic downside.
Some might respond that this would hamper progress, but really it would just hamper sales. You can continue to learn things without testing on the general public. And if you can't, then maybe that's no excuse to test it in prod.
Thats not what you mean, right?
That's some serious woo and you just pulled it right out of your ass. Infant botulism. Anthrax. Cyanide. Belladonna. Poisonous mushrooms.
Without some heavy qualification, this seems unlikely to be true.
Maybe if you restrict it to things that have successfully gone through some sort of heavy trials, but even then there are plenty of things that get through with a tiny upside (like the recent alzheimers drug that made headlines). And most things don't make it through trials.
If you open it up to any concoction that humans have discovered or whipped up in a lab, hoo boy.
Edit: my running definition here would be any kind of compound that we've isolated and attempted to sell.
Does it fully degrade in soil and/or seawater in a reasonable time. If it does not, are the components that remain high-molecular-weight polymers or are they small molecules?
What happens to it in a mammal body? Does it accumulate or is it excreted or otherwise eliminated?
Does it contain harmful elements (which inherently cannot degrade)?
Does aging or UV exposure change the answer to #1?
Does it contain contaminants that are problematic as above?
By these standards, PFOA would massively fail. PTFE might pass by itself but might fail the contaminant test. Historical industrial discharges from fluorochemical plants would fail.
And just to be clear I'm not the least bit in the laissez-faire camp of "allow anything and let the market decide what's safe" either. Regulation is critical, but it has limits and we (as in taxpayer-funded research facilities etc.) should be regularly reexamining whether the benefits outweigh the downsides for all industrially produced chemical substances.
Suppose that there was no evidence that PFOA was harmful. Should we allow unlimited use of it?
It's not the pure economic harm I'm worried about. Such a molecule might well be a key part of a genuine solution to reducing GHG emissions.
When populations reach the point where they start genuinely thinking being dead or never being born is better than contributing to the problem they stop having kids, and start looking at suicide. Maybe you're at that point already, and if you made the choice to die in order to help, or by way of example, I wouldn't fault you for it, but your feelings on the matter should never become someone else's problem and it should never justify the actions of someone causing, or allowing someone to cause, large numbers of people to suffer.
Because already people
1. Have profound misunderstanding of what is a "chemical"
2. have profound Ignorance of how very very few things in life are "provably knowingly completely safe"
It's not that we would "eliminate a few bad chemicals" with that approach, it's that we would eliminate virtually everything. And let's not start with "let's use natural stuff" and get into silly argument as to how do you define it and how do you prove it safe (as people are also profoundly ignorant on what is "natural" or how provably safe it is).
Everything will kill you. You will die. Note that I am not advocating nihilistic approach of "anything goes" / rampant markets / zero oversight, but I'm also not advocating nihilistic approach of "nothing goes". Human body and interactions are mind numbingly complex and I don't know how you demonstrate, conclusively, anything without testing in prod or even then, for given value of "conclusively". I doubt we would leave apples for sale if we tried to decompose them and prove all compounds within it conclusively safe.
I mean it's snark, but it's as legitimate as "if we evolved from apes, why are there still apes" and you hear that all the time.
I ask people to point at something not made out of chemicals.
5% of time there's enlightenment.
95% of the time I get a testy "you know what I mean", to which 70% of the time I manage not to respond with "yes, but do you?? "
The things that have been around for generations and we haven't yet discovered deal breaking issues in should obviously get a pass (unless something is eventually found of course).
When a company comes out with a flashy new product that has a novel use of a compound, we should be skeptical by default, especially if it is something that eventually makes its way onto or into our bodies somehow.
I'm not asking for complete safety. I'm just suggesting that we don't presume "safe enough" by default.
Apples are fine. When you do some novel shit to that apple before it gets to me, no thanks, I'll wait and see. Whatever the benefit is, its probably not for my sake (it's probably good for margins though), and if it is it's probably not that much better than a plain old apple.
Sunscreen is regulated by the FDA unlike all other cosmetic products, and is considered a cosmetic in Korea, Japan, Canada and Asia. The end result is that there are a lot of new sunscreen formulations no one wants to put through the FDA process despite several attempts at simplification by the FDA and Congress; a new sunscreen chemical hasn’t been approved since the turn of the century.
The problem is that the already approved 15 or so chemicals either have side effects of their own, or have bad cosmetic properties (bad texture, bad mixing, leaves white color on skin, etc.). We may actually be exposing people to more risk from skin cancer due to the lack of products that people actually want to apply to their skin daily.
It’s not like the FDA requires studies to be done in USA, so it’s hard(er) to argue that this is a case of regulatory capture.
It sounds like the evidence base for the non-FDA products isn’t there beyond “people in blank have used it and we can confirm they didn’t immediately die but otherwise we don’t really know”.
Meanwhile, I can’t just import a European car and register it, even though it has met almost entirely overlapping safety standards.
In that time frame some of these ingredients like bemotrizinol have been available to hundreds of millions of people. If there was a risk of something like thalidomide babies here, it would’ve been observable by now.
History of usage doesn’t make something safer than the tested options. And a lot of potential issues aren’t immediately obvious.
Sunscreen is not a cosmetic product, the intended effect of the product is not cosmetic. It makes perfect sense to regulate sunscreen as a drug. I'm really glad if they aren't letting people in the US lather up their faces with sunscreen lotions that can't demonstrate themselves to be "generally recognized as safe and effective". People are using sunscreen more than ever these days.
If the products were so good that everyone would buy them over our tired old sunscreen formulas, and if they don't poison people or the planet, then someone will take the time and pay the money to meet that standard and they will make back their investment very quickly as they put every other sunscreen company in the US out of business. If no one has done that yet and you are so confident in these new sunscreens why not take a shot yourself?
I mean, what is the working definition of "cosmetic"? Toothpaste and moisturizer are considered cosmetic by the FDA even though they certainly have health applications.
> they will make back their investment very quickly
The key words here are very quickly. According to the GAO, the process is anything but: https://www.gao.gov/assets/gao-18-61-highlights.pdf
> Return on investment. The testing FDA requested is extensive, would cost millions of dollars, or take several years to conduct, according to sponsor representatives. Some stakeholders and sponsor representatives said that sponsors are currently working to develop newer sunscreen ingredients and are therefore reluctant to invest in the testing FDA requested for the older ingredients covered by the pending applications.
So it's unclear that this process is worth it when the foreign cosmetics companies can just sell to the other 7.6B people not covered by these requirements, and the products might no longer be manufactured by the time they are approved for use in the US. Also, no ingredient has successfully made it through in the past 22 years, so it's not clear that spending all that money will actually result in actually being able to sell the ingredient.
In addition, according to the same GAO report, the FDA requires animal testing. It is a really big movement right now in consumer cosmetics that the consumers who are paying for premium products also want cruelty-free products, so the required FDA testing may actually make the products unmarketable.
> if they don't poison people or the planet
To be clear, the approved ingredients don't necessarily do this either. Only two ingredients of the approved 16 are deemed to be GRASE (generally recognized as safe & effective) by the FDA. Two are just not safe, and the remaining 12 do not have enough data. https://www.fda.gov/drugs/understanding-over-counter-medicin...
Similarly, some PFAS compounds are now known to interact with certain receptors involved in lipid metabolism. So it can also be determined as biologically active in vitro.
There's just so much more that can be done about this on the regulatory side than is done currently.
It's not like the companies developing these chemicals don't know that they're likely to have the same activity. It's just pharmacology. Similar structures tend to have similar activity.
I definitely second GPs suggestion of having the burden of proof reversed like that. It would greatly reduce the work required by researchers, too.
Interestingly, BPA was actually known to have estrogenergic properties in the 30s shortly after it was first isolated, and was first researched as a potential estrogen replacement. With the right regulation this could have been caught close to a century ago...
You're right we're not completely certain, but I think it would be prudent to immediately cut back on all PFAS except scenarios where no viable alternative exists since they are so hard to remove from the environment. As nice as non-stick PFAS pans are, they need to go for now until we know more.
Many of these things we don't know are because it would be unethical to do the experiment to give some people PFAS and some people no PFAS and see if the PFAS group get more diseases.
Instead, we allow PFAS to be used indiscriminately, and then afterwards regret it.
Experimentation of potentially harmful things on people should be allowed if the alternative is giving the same potentially harmful thing to everybody with no experimentation done.
Yet the changes are really obvious by now. I've been on a hike in the northern Alps a few days ago. I know the mountain quite well, and it should be teeming with life this time of the year, insects, birds, but it was eerily quiet across the whole altitude range. The river in my hometown should carry yearly floodwaters from snowmelt, but this year there was not a hint of a flood. The all-time temperature record was shattered (again), though. Forest fires in areas that never saw any just decades ago. Clean windshields in mid-August. Either no rainfall for months, or several 1000-year floods, nothing in between. Silence where there have been annoyingly loud crickets and frogs since forever.
I guess we're running a deeply, deeply dangerous experiment on the biosphere and I'm not convinced anymore that it's going to be fine. I have a feeling it's going to be very, very much not fine at all.
I think there are other significant factors to consider as well.
In the US at least I think regulation, in our current day, has failed in many areas due to 1) the slowing down of decision makers to become informed and make decisions (see congress for stagnation in passing legal regulations) 2) industries or large industry players have waged effective influence campaigns in mainstream and scientific communities to push a friendly agenda or inject uncertainty which has nock on affects when it comes to funding (see pesticides like neonics and glyphosates, oil and gas companies with respect to global warming and plastic recycling, tobaco companies and smoking causing cancer, …), and 3) a certain degree of capture in regulatory agencies by industry (industry players later work for the regulatory agency or the reverse, as well as other tactics). 4) the politicization of regulation (not sure how much this can be helped though).
It’s a mess.
> We could switch from "allow by default" to "deny by default", but I'm not even sure that would help.
There may be a middle ground here. As a chemic becomes more widely used that could trigger required enhanced testing by a regulatory agency as well as research grants looking into their safety.
And as a chemical becomes ever more widely used rigorous long-term studies could be required.
I’m not sure what the right long term answer is but I can’t help but think there is some fundamental mismatch of top down regulation by regulatory bodies in a market based system where companies are innovating and also creating these harms / negative externalities. In the former regulators are slow, reactionary, and often substantial harm must have already occurred for a regulation to be passed. The latter is a dynamic and fast moving system where companies are ruled by a fitness function which is often myopic and locally greedy.
It seems introducing another market for regulation could offer a solution by using one dynamic system to regulate another. Carbon credits is an example of this. However two or more interacting systems will make things much harder to reason about and may have their own significant flaws if not designed well (for example trees are planted but then die earlier than expected or are later harvested after the carbon credits have been sold).
The book was published over a decade ago, so news travels slowly sometimes, even to regulators.
[1] Slow Death By Rubber Duck https://www.amazon.com/Slow-Death-Rubber-Duck-Everyday/dp/15...
People, people. Why do you all expect regulation to work in the presence of corruption?
All regulations break down with high enough stakes. We are in this mess right now, because we made the mistake of thinking that regulations will be good enough to stop it.