Friday, December 15, 2006

REACH for the sky (and it will cost the earth)

This is an imperfect world in which we live and, in a reflection of this reality, the blogosphere also has its fair share of ridiculous, preening amateurs who make me knash my teeth in frustration. Few embody this principle, along with a monumental inability to see reason and a mind corrupted by socialism, as The Ever Blessed And Frangrant* Margot Wallstrom.

Today, TEBAF Margot has seen fit to communicate, to we poor serfs, her lofty thoughts upon a subject on monumental importance.

A deal is REACHed!

Good god! What can it be? Have we just discovered how to manipulate an Einstein-Rosen Bridge? Discovered a fail-safe cure for cancer? No, nothing so beneficial. Naturally.
Finally we will have new European legislation on chemicals, replacing around 40 existing directives. It has been a long, winding road with intensive lobbying, tough negotiations and strong reactions also from other parts of the world. It is a compromise, for sure (see my previous post on this). But the most important is: COMPARED WITH TODAY‘S SITUATION
  • it will improve our knowledge about the thousands of chemicals that we use every day,

  • we reverse the burden of proof : from public authorities having to prove that a chemical is dangerous to producers having to provide information, test and hopefully prove that it is NOT dangerous or that we can manage the risks

  • we raise the level of protection for human health and the environment

  • we have created incentives and signals to industry to gather more information and test their chemical products

  • substitution of the most hazardous substances will start.

It should come as no surprise to anyone that I think that Wallstrom is one of the stupidest and most vacuous people on the planet; it is typical of the woman's almost coy idiocy that she should not actually detail what the REACH Directive actually comprises. Margot is, after all, only the Commissioner in charge of communicating the EU's benefits to we serfs: one can hardly expect her to explain REACH in any concrete terms.

Never mind, for our very own Tim Worstall spelt out the implications some time ago.
Two chemicals, in a formulation, yes, pretty sure this would be covered under REACH. Value? $80,000 or so. Cost of testing? $100,000 or so. It’s difficult to see how doubling the cost of experimenting with alloys moves us closer to the goals of the Lisbon Agenda, the creation of the most innovative economy in the world.

Quite. But it gets worse.
It does, of course, as with everything in this nightmare being built for us, get worse. At various times over the research program we have shipped slightly different formulations, 1% scandium, 10% scandium and are toying with the idea of a 5% scandium product. Different combinations of chemicals there, so Kachingg! another $100,000 each to be spent under the new, upcoming system, for which of course we have to thank Ms. Wallstrom.

More. We are also part of a group (including again Airbus, also QinetiQ, UMIST, Oxford University and others) looking at whether these scandium containing alloys will help make aluminium easier to weld. It’s an area where the research being done in Europe is well ahead of that in other regions. The end aim is to be able to weld aircraft fuselages, saving some 10% of the weight of each aircraft. A huge benefit not just for manufacturers but also reducing fuel consumption immensely.

Now, the kicker here is that there are many more variations of the welding rods possible, desired. There are formulations with 2.2% scandium, 1.8%, others with 1% copper, 0.5% magnesium, all with slightly different properties and thus all likely to be used in future. In fact, at least 10 likely variations. Oops! that’s a cool million $ just for the welding rods, for of course all of these are different formulations of chemicals and so all need to be tested under REACH.

This is a stunning amount of money and if TEBAF Margot thinks that this is, in some way, going to benefit EU consumers, then she is even stupider than I thought (and this would be something of an achievement).
The cost of the testing of new chemicals and formulations, combinations of them, is what has been added up. What has not been even noticed is the costs of all the new formulations that will not be made, as the costs of testing them are vastly greater than the resources available to do so. It is small companies that drive economies, create most of the new jobs, do most of the innovating, people setting up with a bright idea on a string and a prayer, and imposing a cost of $100,000 on each and every one of these will mean that tens of thousands, hundreds of thousands of ideas, are never pursued, not really quite the way in which we should be striving towards the goals of the Lisbon Agenda now is it?

Exactly so. You see, the way that we have generally regulated chemicals is by the simple expedient of the market: if a company poisons its customers, it is not going to keep those customers very long. We have also relied on some government regulation but it is important to realise that we have, generally speaking, allowed chemicals to go to market unless they are proven to be dangerous.

What REACH does is to assume that all chemicals are dangerous (and, by extension, that all companies are keen on harming their customers) unless proven otherwise.

This is, of course, an interesting reflection of the differing legal systems employed on the continent. Generally speaking, under British Common Law code, people are allowed to do anything as long as it is not specifically forbidden; under the Roman legal system (employed by, for instance, France), you are not allowed to do anything unless it is officially sanctioned by the law.

And the effect of this legislation? Well, job losses are inevitable, of course.
Research conducted by the UEAMPE, which represents SME's in Europe, suggest as many as 150 000 jobs could be lost to the German chemicals industry with a knock-on effect on the livelihoods of 1.25 million workers in related industries.

And don't forget all of those beneficial chemicals that will not now be developed (or, at least, not in the EU); and, of course, REACH applies to any imported goods too.

Thank you, Margot; really good work on that one.

Naturally, it almost goes without saying that our spineless, useless media have not bothered to consider the implications.

* © Tim Worstall, for which we give thanks.