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[GreenYes] REACH


Those are good comments, clearly REACH isn't enough, but it's a big start.
Keep in mind that a big part of REACH was to change the burden of proof
about product safety from the public to the companies-- putting the
precautionary principle into action. Under REACH, companies have to prove
their substance is safe before putting it on the market. Everywhere else,
the burden of proof is on us to prove it is causing us harm. And REACH is
also designed to improve communication up and down supply chains, which many
of you know doesn't happen much now. Companies making an end product often
have no idea what is actually in that product.

I replied last week to Eric's info about REACH but never saw it posted to
the group. I've copied it again below. Apologies if I'm repeating myself.


A good source for REACH information is UMass Lowell's Center for Sustainable
Production. The work closely with Andrew Fasey, who is one of the lead
authors of REACH. Andrew has just put together a 5 page briefing paper on
REACH for them which can be found on their website at
<> Their
website,, is a great source of information about REACH
and other activities related to safer and green chemistry.

The Lowell Center held a series of trainings about REACH around the country
this year, and also sponsored an Innovators Roundtable last year for forward
acting businesses to talk about Green Chemistry challenges and
opportunities. Proceedings of that meeting can be found at, and scroll down to Sustainable
Business and Safer Chemistry through the Supply Chain.

Here in MA over 40% of our exports are to Europe, and we're using that as
one of our arguments for the state to link economic development and
environment issues and support the growth of green chemistry and a healthy


Amy Perlmutter
Perlmutter Associates
23 Avon Street
Cambridge, MA 02138

On 12/28/06 2:58 AM, "GreenYes group" <noreply@no.address> wrote:

== 1 of 1 ==
Date: Wed, Dec 27 2006 2:49 pm
From: "retroworks"

Hi Eric,

Thanks for highlighting the REACH law in Europe for GreenYES.

I'd offer a note of caution. Applauding or denouncing products based
on the toxics they contain is a simple process with potentially
perverse outcomes, and environmentalists in this century need to look
at product lifecycles, not end-of-life contents. Most mercury in the
USA comes from gold, silver, and copper mining, not from the
smokestacks and recycling bins we are accustomed to regulating. None
of those is a toxic material, but gold and silver are primarily used
for vanity products (under 40% of those metals goes to engineering

REACH is not a bad thing, but it is derivative from "end of pipe"
regulation (even though it is being hailed as an alternative). It
begins with a toxic substance in a landfill or obsoletes bin, and
assumes that reducing that material will be better for the environment.
As I've said before, baby seal pelts are non-toxic, organic, and
reusable. Gold in a circuit board yields more mercury than the mercury
in a circuit board.

For 2007, I'd prefer a simple ban (Iike rhino horn, ivory, whale
hunting, and lead gasoline) to a new government agency which says gold
is good and lead is bad. Take a known product which is easily
replaced, immune to panic in a supply disruption, and which has an
effect we've studied from cradle to grave. Replacing all 18k gold with
14k gold (or better, 9k) would have a more profound effect on the
environment than ROHS (lead free solder) legislation.

Robin Ingenthron

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