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2 minutes ago, MicroB said:

 

Project 2025 states on day one it will downsize the EPA.

 

Banning or restricting pesticides needs two steps.

 

1. Assessing which pesticides to ban, on the basis of harm. The move will require consideration of not just existing pesticides, but also derivastives; will a pesticide manufacturer attempt to evade a ban by tweaking the formula, for instance.

 

The EPA, a creation ironically of Richard Nixon, is under resourced; Trumpf, during his first administration, rolled back more than 100 EPA regulations, designed to protect Americans and the American environment, because the regulations were seen as hurting American industry

 

https://www.nytimes.com/interactive/2020/climate/trump-environment-rollbacks-list.html

 

During his tenure, he attempted to cut the EPA budget by 30% each time. This resulted in cutting of the scientists and inspectorate, through hiring freezes, early retirements and job elimination. It takes years to built up a technical capability, and so rebuilding the EPA is not something that can be done quickly; the skillset has gone. The EPA already had a tough job recruiting, because its looking for people with the same skillsets as industry. The people who eschew a career industry in favour of a career in the EPA are tremendously motivated in what they do, and what they do is a good thing.

 

The cuts have harmed the EPA's abilties to identify harmful chemicals (though these capabilties were never that great. Consider the EPA's efforts to ban asbestos, which were a complete debacle. The problem was that industry helped write the regulations that the EPA was working to. Which meant when there is a need to ban something, the EPA is obliged the consider the least burdensome approach, rather than simply banning something. This has lead to paralysis in the agency:

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1764141/

 

Until 2007, the EU followed the same approach to classifying chemicals, through a risk based approach, which means EPA officials have to prove a chemical is harmful. This leads to decades of the public being exposed to harm before a chemical is removed.

 

In 2007, the EU switched to a Hazard-based approach; the burden (and the cost) was placed on the manufacturer to prove their product is safe (REACH Directive). The US tried something similar through a Democrat bill, the 2005 KID Safe Chemicals Act. Lobbyists and Republicans killed it. The Toxic Substances Control Act saw reform in 2016, to try and remove the "least burdensome" language. Between 2016 and 2022, the agency only managed to ban one substance, asbestos. Lack of funding has meant that of the top 10 chemicals identified to be looked at, only a handful will be banned. before 2025. So forget about a whole raft of additional pesticides.

 

On the list waiting to be banned:

  • 1-Bromopropane (draft risk assessment just done)
  • Carbon Tetrachloride (draft risk assessment very soon)
  • C.I. Pigment Violet 29 (PV29)
  • Cyclic Aliphatic Bromide Cluster (HBCD)
  • 1,4-Dioxane
  • Methylene Chloride
  • N-Methylpyrrolidone (NMP)
  • Perchloroethylene
  • Trichloroethylene (TCE)

 

I cannot see Trumpf adopting legislation simiar to REACH (which itself is imperfect); to him, it will sound too Communist, industry will claim the costs are burdensome, and either push back or demand Federal compensation for the extra costs of doing business.

 

I've had conversations like this during my career. In Northern Ireland, the water utility is still part of the government. The NI Water Service was very worried about a local well known brewery. During the beer making process, spent Wort, which is high in carbohydrate, is dumped into the sewage system. This extra load of CHO kills the system; makes it rapidly  go anaerobic. I had discussions with the brewer, revolving around the company installing their own treatment works, to treat their waste before it enters the municipal system. The push back was this was expensive, and would probably lead the brewery to cancel other projects, maybe job losses, even pulling out of Northern Ireland. This was Northern Ireland, just after the Good Friday Agreement, and after the Republican terrorists had their US revenue stream cut. No one wanted to go back to the bad old days. So the taxpayer sucked up the cost of dealing with industries' waste.

 

2. In addition to having the technical ability to assess harmful chemicals, to ban their use in agriculture, you need an inspectorate to monitor the farms. Thats expensive. Won't happen if Project 2025 slashes budgets to the bone. One of the outcomes of a risk based assessment is that chemicals are banned for certain uses but not others. A restriction won't necessarily stop production or import. Risk assessment considers the hazard (will the chemical cause cancer in blond haired blue eyed kids) but also liklihood (ie driven by eating contaminated food stuffs). So a ban might be instigated on that sunflower field, because people will eat the oil or seeds. But it might not be implemented to repress weeds in an ornamental garden, because no one is going to eat the flowers (or unlikely to).

 

There is nothing wrong really with the REACH approach, but it does add to the cost of business. Funnily enough, for medical devices, it was the other way around. It was a lot easier to get a medical device put on the market in Europe that the US. Medical devices undergo all sorts of clinical assessment to determine efficacy and safety. The FDA is concerned with both, and frequently turn down applications if they feel the tests is not good enough. For instance, the best way to screen for colorectal cancer is not colonoscopy; that's most useful if there is something  to be wrong, which in general, with the exception of Germany (to an extent), Europe follows. So Europe has strong stool testing programmes; blood in your stool is a red flag for possible CRC, triggering a colonoscopy. US doctors would like the same and there are stool screening programmes, but with very poor uptake. Which is why the ACA added free colonoscopies, because a colonoscopy was better than nothing.

 

People don't like the stool test for understandable reasons. Its dirty. So the holy grail is a blood test. Two companies, Exact Sciences and Epigenomics, came up with "new" tests. Exact Sciencesis a US company. Its really a lab service. Their test was still a stool test, which involves exactly the same test for blood as the $10 stool test. But they carry out additional genetic analyses to detect cancer specific markers. It has a similar specificity as the present $10 test, but better sensitivity. The cost is $3000. The FDA granted it approval on the basis that it was at least as good as the existing $10 test. By all accounts, the test has sold very well/

 

Epigenomics in a German test. They came up with a test kit that could be sold to any hospital lab, utilising something called methylated PCR. Normal hospital lab instruments could be used. The cost per test was going to be about £250 to the lab. I suspect the cost to the payer would be $400-500. The test was very sensitive, but it failed a little on specificity because it could also pick up some lung cancers early on. The FDA rejected it, because of that, despite Epigenomics arguing that a blood test would see more people get screened, resulting in the early identification of more cancers, and better survival rates.

 

The older European system was argued that it meant there was more innovation and European patients were able to access technologies 6 years sooner than in the US. But on the other hand, it might result in bad devices getting on to the market. One of the incongruities of the regulations around blood tests is that Europe only considered the safety of the lab tech. So, in a HIV test, they would consider the risk of exposure to infectious agents, rather than the risk to the patient if they got the wrong result (a disaster either way).

 

Thats all changing, to something more like the FDA, where makers have to demonstrate their devices work. Predictable moans; a French manufacturer of acupuncture needles complained he needed to produce clinical data that acupuncture works.

 

It's sheer fantasy that Trumpf will add to the cost burdens of corporations by requiring them to switch to alternative pesticides, or that he will even fund the EPA properly . If Kennady was persuaded by this, he was hoodwinked.

 

Here's the paradoxl many of Trumpf's supporters are actually in favour of quite leftwing policies, such as governmental interferance in a private life, government interferance in business, restricting free trade. This is an old video, but it makes me laugh about these old anarchists supporting Trumpf in 2020.

 

 

 

Easy to ban bad chemicals. Why has not Democrats done it? Had 12 years

Edited by maesariang
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Posted
21 minutes ago, MicroB said:

 

Project 2025 states on day one it will downsize the EPA.

 

Banning or restricting pesticides needs two steps.

 

1. Assessing which pesticides to ban, on the basis of harm. The move will require consideration of not just existing pesticides, but also derivastives; will a pesticide manufacturer attempt to evade a ban by tweaking the formula, for instance.

 

The EPA, a creation ironically of Richard Nixon, is under resourced; Trumpf, during his first administration, rolled back more than 100 EPA regulations, designed to protect Americans and the American environment, because the regulations were seen as hurting American industry

 

https://www.nytimes.com/interactive/2020/climate/trump-environment-rollbacks-list.html

 

During his tenure, he attempted to cut the EPA budget by 30% each time. This resulted in cutting of the scientists and inspectorate, through hiring freezes, early retirements and job elimination. It takes years to built up a technical capability, and so rebuilding the EPA is not something that can be done quickly; the skillset has gone. The EPA already had a tough job recruiting, because its looking for people with the same skillsets as industry. The people who eschew a career industry in favour of a career in the EPA are tremendously motivated in what they do, and what they do is a good thing.

 

The cuts have harmed the EPA's abilties to identify harmful chemicals (though these capabilties were never that great. Consider the EPA's efforts to ban asbestos, which were a complete debacle. The problem was that industry helped write the regulations that the EPA was working to. Which meant when there is a need to ban something, the EPA is obliged the consider the least burdensome approach, rather than simply banning something. This has lead to paralysis in the agency:

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1764141/

 

Until 2007, the EU followed the same approach to classifying chemicals, through a risk based approach, which means EPA officials have to prove a chemical is harmful. This leads to decades of the public being exposed to harm before a chemical is removed.

 

In 2007, the EU switched to a Hazard-based approach; the burden (and the cost) was placed on the manufacturer to prove their product is safe (REACH Directive). The US tried something similar through a Democrat bill, the 2005 KID Safe Chemicals Act. Lobbyists and Republicans killed it. The Toxic Substances Control Act saw reform in 2016, to try and remove the "least burdensome" language. Between 2016 and 2022, the agency only managed to ban one substance, asbestos. Lack of funding has meant that of the top 10 chemicals identified to be looked at, only a handful will be banned. before 2025. So forget about a whole raft of additional pesticides.

 

On the list waiting to be banned:

  • 1-Bromopropane (draft risk assessment just done)
  • Carbon Tetrachloride (draft risk assessment very soon)
  • C.I. Pigment Violet 29 (PV29)
  • Cyclic Aliphatic Bromide Cluster (HBCD)
  • 1,4-Dioxane
  • Methylene Chloride
  • N-Methylpyrrolidone (NMP)
  • Perchloroethylene
  • Trichloroethylene (TCE)

 

I cannot see Trumpf adopting legislation simiar to REACH (which itself is imperfect); to him, it will sound too Communist, industry will claim the costs are burdensome, and either push back or demand Federal compensation for the extra costs of doing business.

 

I've had conversations like this during my career. In Northern Ireland, the water utility is still part of the government. The NI Water Service was very worried about a local well known brewery. During the beer making process, spent Wort, which is high in carbohydrate, is dumped into the sewage system. This extra load of CHO kills the system; makes it rapidly  go anaerobic. I had discussions with the brewer, revolving around the company installing their own treatment works, to treat their waste before it enters the municipal system. The push back was this was expensive, and would probably lead the brewery to cancel other projects, maybe job losses, even pulling out of Northern Ireland. This was Northern Ireland, just after the Good Friday Agreement, and after the Republican terrorists had their US revenue stream cut. No one wanted to go back to the bad old days. So the taxpayer sucked up the cost of dealing with industries' waste.

 

2. In addition to having the technical ability to assess harmful chemicals, to ban their use in agriculture, you need an inspectorate to monitor the farms. Thats expensive. Won't happen if Project 2025 slashes budgets to the bone. One of the outcomes of a risk based assessment is that chemicals are banned for certain uses but not others. A restriction won't necessarily stop production or import. Risk assessment considers the hazard (will the chemical cause cancer in blond haired blue eyed kids) but also liklihood (ie driven by eating contaminated food stuffs). So a ban might be instigated on that sunflower field, because people will eat the oil or seeds. But it might not be implemented to repress weeds in an ornamental garden, because no one is going to eat the flowers (or unlikely to).

 

There is nothing wrong really with the REACH approach, but it does add to the cost of business. Funnily enough, for medical devices, it was the other way around. It was a lot easier to get a medical device put on the market in Europe that the US. Medical devices undergo all sorts of clinical assessment to determine efficacy and safety. The FDA is concerned with both, and frequently turn down applications if they feel the tests is not good enough. For instance, the best way to screen for colorectal cancer is not colonoscopy; that's most useful if there is something  to be wrong, which in general, with the exception of Germany (to an extent), Europe follows. So Europe has strong stool testing programmes; blood in your stool is a red flag for possible CRC, triggering a colonoscopy. US doctors would like the same and there are stool screening programmes, but with very poor uptake. Which is why the ACA added free colonoscopies, because a colonoscopy was better than nothing.

 

People don't like the stool test for understandable reasons. Its dirty. So the holy grail is a blood test. Two companies, Exact Sciences and Epigenomics, came up with "new" tests. Exact Sciencesis a US company. Its really a lab service. Their test was still a stool test, which involves exactly the same test for blood as the $10 stool test. But they carry out additional genetic analyses to detect cancer specific markers. It has a similar specificity as the present $10 test, but better sensitivity. The cost is $3000. The FDA granted it approval on the basis that it was at least as good as the existing $10 test. By all accounts, the test has sold very well/

 

Epigenomics in a German test. They came up with a test kit that could be sold to any hospital lab, utilising something called methylated PCR. Normal hospital lab instruments could be used. The cost per test was going to be about £250 to the lab. I suspect the cost to the payer would be $400-500. The test was very sensitive, but it failed a little on specificity because it could also pick up some lung cancers early on. The FDA rejected it, because of that, despite Epigenomics arguing that a blood test would see more people get screened, resulting in the early identification of more cancers, and better survival rates.

 

The older European system was argued that it meant there was more innovation and European patients were able to access technologies 6 years sooner than in the US. But on the other hand, it might result in bad devices getting on to the market. One of the incongruities of the regulations around blood tests is that Europe only considered the safety of the lab tech. So, in a HIV test, they would consider the risk of exposure to infectious agents, rather than the risk to the patient if they got the wrong result (a disaster either way).

 

Thats all changing, to something more like the FDA, where makers have to demonstrate their devices work. Predictable moans; a French manufacturer of acupuncture needles complained he needed to produce clinical data that acupuncture works.

 

It's sheer fantasy that Trumpf will add to the cost burdens of corporations by requiring them to switch to alternative pesticides, or that he will even fund the EPA properly . If Kennady was persuaded by this, he was hoodwinked.

 

Here's the paradoxl many of Trumpf's supporters are actually in favour of quite leftwing policies, such as governmental interferance in a private life, government interferance in business, restricting free trade. This is an old video, but it makes me laugh about these old anarchists supporting Trumpf in 2020.

 

 

 

Trump's concern for the environment was clearly delineated when he appointed an oil industry executive as his Secretary for the Environment.

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