=regulation =safety
Fairly often, I see products with
warnings such as "This product contains a chemical known to the State of
California to cause cancer." What that means is that the product contains at
least a little bit of something on a government list with over 900 chemicals on
it. Such warnings are common enough that customers are willing to accept
products with them, so companies are willing to accept having them, which makes
them more common.
A warning like that doesn't make me feel informed. It
leaves me wondering: What chemicals are present? How bad are they? How much
exposure is likely?
Before buying products, I usually read their
ingredient lists if available. I know enough chemistry to know the chemical
structures and reactivity of listed ingredients, enough molecular biology to
often understand how compounds can affect cells, and enough about manufacturing
to guess where and why most ingredients are used. Most people don't have those
skills, and (at least with the current educational system) it'd be unreasonable
to expect them to.
Most people don't bother to read ingredient lists of
products they buy. A common sentiment is: "If it was really dangerous it
would've been banned." The FDA and EPA operate primarily by banning things
rather than warnings, and when an agency has the power to ban things, it must ban things to credibly communicate them being dangerous.
If a
government is going to require a notice, it should think about what information
needs to be communicated and what the most efficient way to communicate it is.
When a company wants to do something, it will often find a good way to do it,
but when it's a legal requirement, its implementation will often be adversarial.
For example, the EU-required cookie warnings on websites often make it easier to
accept marketing cookies than to reject them. Such adversarial implementation
should have been anticipated, and the EU should have required a standardized and
carefully designed form instead.
Below is my proposal for
government-required safety warnings for products.
--:-:-:-:-----------------------------------:-:-:-:--
Companies selling a product to consumers must submit a list of materials used to a federal agency. That agency then evaluates them, makes a webpage describing their hazards, and assigns 3 numbers ranging from 0 to 100:
- a rating for
the hazards of normal use
- a rating for hazards to young children
unoccupied with it
- a rating for how hazardous the materials used are.
Here are some examples of
descriptions from that website:
(electrical device with cords
using PVC insulation)
This product uses PVC containing
lead-based stabilizers. Such PVC is used for electrical cord insulation.
Such stabilizers can be absorbed through the skin, and electrical cords are
handled during normal use. Lead is very toxic and even small amounts have
long-term effects, especially for brain development of exposed children.
(stain-resistant pants)
This product uses a
fluorinated surfactant to provide stain resistance. It can be absorbed
through the skin or by inhalation. Exposure can happen through wearing the
pants normally. The compound used may be a carcinogen, a liver toxicant, a
developmental toxicant, a immune system disruptor, and/or a hormone
disruptor. The compound used is persistent in the environment.
(small neodymium magnets)
When these magnets are eaten
repeatedly, they can cause serious internal injury by attracting each other
through the walls of the digestive system. Some young children will
repeatedly try to eat similar small objects.
Products would then be required to have the following printed on their packaging:
usage hazard: X
child hazard: Y
material hazard: Z
(a QR code leading to that website)
Ideally that labeling would
supersede some earlier requirements such as "known to the state of
California" warnings, and have some international coordination.
It's
possible that lobbying by companies would cause such a government agency to
overlook hazards. To mitigate that risk, the government websites for product
hazards could be required to, at the bottom, link to 3rd-party evaluations
(such as ones from other governments and nonprofits) that meet certain
criteria and list their 3 hazard ratings. If some linked group often had
better evaluations than the government agency responsible for ratings, it
would make that agency look bad, providing slightly more incentive for good
ratings.
Many product evaluations would be needed, done by multiple
government employees. Sometimes they'd happen to be unreasonably high or
low, so there should be an appeal process, where the seller or a competitor
or an advocacy group would pay a fee for a higher-level evaluator to
reconsider and potentially replace the initial hazard ratings. Such appeals
should, of course, be irreversible once started, to prevent companies from
cancelling them selectively according to leaked information.