UP FRONT 05
and the sun, outside of our atmosphere, allows us the ability to place a permanent warning of the incredible potential of our sun to cause bodily harm, and to have this warning visible to all. In this way, with the assistance of the ESA, we regulators have met our obligation to the public, who can now make a fully informed decision about how much protection they need in daylight.” Informed of the failure of the SLuM to deploy in outer space the letters spelling out the carcinogen warning, Señor von Vonnenburg could only be heard muttering “merde” under his breath as he retreated to the privacy of the golf course locker room. Piotr Mickey, founder of the Committee Opposed to Excess Information and Safety Talk, COExIST, couldn’t be reached for direct comment, but the COExIST office did release a commentary. “No one in their right mind thought that looking at the sun and seeing a hazard warning was a reasonable idea. Only those opposed to personal responsibility and with a dim view of basic human intelligence would attempt to put a warning on either titanium dioxide or the sun. We celebrate the failure of the SLuM as a blow against government regulation run rampant. We’d like to think the failure of SLuM is a sign of some common sense in outer space, as there certainly seems to be a dearth of common sense here on earth.” END TRANSMISSION Nope, nobody I know of has actually proposed blocking sunlight in lettershapes to spell out a carcinogen warning about the damaging rays of the sun. But work proceeds apace to create a regulation that would require titanium dioxide (TiO²) carcinogen warnings, not just on TiO² itself, but on any product containing it. There is also some significant opposition to the proposed regulation, and I have overheard an opponent give the sun versus TiO² carcinogen strength comparison. What do we actually know about the question of requiring additional carcinogen warnings for TiO²? Well, it’s almost certain that decades and decades of inhaling pure TiO² dust can give one lung cancer. However, TiO² has also long been GRAS (Generally Recognized As Safe) as an ingredient in oral medications, such as pills, tablets, and capsules. In fact, if you’ve ever swallowed a white pill or any medicine with white writing on it, you’ve most likely already
eaten titanium dioxide. Not only is TiO² used in oral medicines, it is also used in paint. In paint, both as a liquid and as a dried solid, it’s difficult to get adversely affected by the TiO². It isn’t absorbed through the skin, you don’t breathe it in, and adults don’t eat it. Yeah, you might ask, but what about young children eating old paint chips? Well, it’s not the same as eating old lead paint chips, because the lead has some acute toxic effects, and TiO² doesn’t. Still, especially in children’s not yet fully developed bodies, there may be some slightly higher chance of some disease, such as cancer, later in life. But, really, what good would a product warning label do about children eating old paint? First of all, by the time dried paint is old enough to start flaking off, how likely is it that the empty paint container is still around? Second, if it is around, how likely is it that someone will read it? And third, does anyone, seriously, even one single person, believe that a parent or guardian would stop a child from eating paint chips because of a carcinogen warning, but not stop them in the absence of such a warning? Can you picture it? “I’m sorry, Kimmi, I can’t let you eat those paint chips any longer, because they might be a carcinogen.” It seems to me that there’s a line somewhere between reasonable hazard warnings and excessive warnings. And don’t forget that any warnings the public believes are excessive reduce the effectiveness of those warnings that are wholly and totally justified. It only takes a few warnings being viewed as poppycock before all warnings are viewed as poppycock. It also makes a difference if the public perceives that ‘everything’ has hazard warnings on it. When it’s impossible to find products without warnings, then ‘everything’ is dangerous, and ‘everything’ gets all lumped together. Then the specifics of how and why something is dangerous get ignored in favor of the general conclusion that “oh heck, everything’s dangerous”. For goodness sake, water, H²O itself, has an oral LD50! The means if someone drinks enough water the L in the LD50 kicks in, ‘Lethal’. Yes, it is possible to die of water intoxication, and people have done so. You did notice those five letters T O X I C in the middle of “intoxication” didn’t you? So, yes, we do have a line between reasonable and excessive
warnings, and currently water is on one side of it and chlorine gas is on the other. I’m not always sure where that line is, and it is different for different regulations, but I do think that Dangerous Goods (DG) regulations have already crossed it. Let’s talk about the ‘dead tree, dead fish’ warnings on otherwise hazardous goods. What good is done by having that mark next to any other DG label or placard? Is there any emergency responder anywhere who would say something like, “Sure, we can let that corrosive or poison or self-heating or <insert hazard here> liquid drain into the bay…, oh wait, we can’t do that, because it’s also a Marine Pollutant.”? Really? I’ve talked to a few emergency responders about this, and it’s a pretty general - but strong - rule that the hazardous spill needs to be contained. And that general rule applies even in the absence of an EHS/MP warning. I can see a tremendous amount of value in including EHS materials in Class 9, but I don’t see any added value in adding EHS/MP warnings to materials already in Classes 1 to 8. I think the ICAO/IATA approach to Mark, the dead fish (yes, the dead fish is named Mark, because he isn’t a label nor a placard), in which it only applies to Class 9 materials with a proper shipping beginning Environmentally Hazardous…, is probably the most sensible approach, and should be adopted by other DG regulations. I’m okay with carcinogen warnings on pure TiO², but when in different forms perhaps those warnings are excessive and wasted. By the way, if they ever do put letters into space, so everyone on earth can be warned of the powerfully carcinogenic property of the sun’s rays, which language would that warning be in? And how would we measure the font size? A man in the fitness center has a gym bag with a button on it, and the button says: Eat Well, Stay Fit, Die Anyway. Oh, wait, that man is me. This is the latest in a series of musings from the porch swing of Gene Sanders, principal of Tampa-based WE Train Consulting; telephone: (+1 813) 855 3855; email gene@wetrainconsulting.com.
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