4 ms·

A bunch of comments here are roughly "there's not great evidence that these are harmful" -- but is that the right standard? Or should there be an obligation to

by abeppu 2y ago

A bunch of comments here are roughly "there's not great evidence that these are harmful" -- but is that the right standard? Or should there be an obligation to provide evidence that something is "safe" in order to use it in some consumer applications (like food packaging)? It's tempting to say that we should conclusively establish that something isn't harmful before we use it absolutely everywhere ... but what standard of evidence would be both achievable and ethical? Because generally people aren't getting acutely ill after eating food from a plastic package, we're left with the possibility that accumulative impacts over years might be harmful -- but it doesn't seem feasible to run long term studies where a treatment group is exposed to plastics for decades and a control group is not. It hardly seems achievable to do correlation studies, because you often don't know what's been in the packaging for all the food you've consumed, which may not even be in your control.

Aurornis 2y ago
How do you propose proving a negative?
- mrcode007 2y ago
  With modus tollens https://en.wikipedia.org/wiki/Modus_tollens https://en.wikipedia.org/wiki/Modus_tollens
- esoterae 2y ago
  I think the civil burden of proof should apply here. Upon the preponderance of the evidence. Given so many studies that exhaustively show correlative effects of phthalates with metabolic and endocrine disruption, especially strongly during developmental stages, I think even that burden of proof is met. Sure, you can't prove something doesn't exist, but you can make a reasonable determination that given exhaustive study, given correlative negative effects can be ascribed to no other known cause, and given that this is natal and pediatric health especially at stake, we should say until such time as a causative link is proven to lie elsewhere these chemicals should not be used in consumer goods out of an abundance of caution. The redirection of that claim would be "these profits are more important than moving to protect bodily health especially for those unable to protect themselves, given what we currently know." Honestly, no knowledge is perfect, but upon the balance we must rest our sacrosanct right to health.
lolinder 2y ago
Your second paragraph is a very good argument against requiring that everything used in food packaging be shown to be safe before it can be used. Can we reasonably run such a study to prove that wax paper is safe? What about plain paper? Do we just require all food producers to use no packaging at all until these controlled longitudinal studies are completed? If we allow them to use packaging, how do we define in a principled way what packaging is allowed while there are still unknowns? One possibility would be to say that if something is currently widely used in some significant (think 5%) portion of the industry then we allow it, but that has two problems: First, it wouldn't exclude phthalates anyway, so it doesn't address the current concern. Second, it might exclude future packaging materials that we think might be safer than our current materials but which have yet to be tested.
- wizzwizz4 2y ago
  > One possibility would be to say that if something is currently widely used in some significant (think 5%) portion of the industry then we allow it, We could say "if it was used in the ancestral environment for similar purposes, and is not known to be harmful". Much of that stuff is bad, but our bodies have mitigations for it. (e.g. tannins leached from wooden bowls: harmful in principle, but we can metabolise them so it's fine)
- Retric 2y ago
  Ideally rigorous testing should happen before something becomes common, but it isn’t the only option. Nothing stops you from a temporary ban say 20 years to allow for testing. Doing this for every chemical at the same time is impossible, but we can also cycle through existing chemicals. Hypothetically, if phthalates exposure was responsible for 5% of cancer deaths that’s 30,000 dead Americans per year and we might not notice without a ban. It’s unlikely for this specific chemical to be that bad, but we don’t know.
- westurner 2y ago
  Cellulose and algae are considered safe for human consumption and are also biodegradable; but is that an RCT study? CO2 + Lignin is not edible but is biodegradable and could replace plastics. "CO2 and Lignin-Based Sustainable Polymers with Closed-Loop Chemical Recycling" https://onlinelibrary.wiley.com/doi/10.1002/adfm.202403035 https://onlinelibrary.wiley.com/doi/10.1002/adfm.202403035 What incentives would incentivize the market to change over to sustainable biodegradable food-safe packaging?
Night_Thastus 2y ago
1. It's a lot harder to prove something is 100% assured safe then the other way around 2. Every substance/material/etc that is investigated and banned incurs overhead on taxpayers and industry directly. What you're asking for would be extremely prohibitive to getting anything done at all.
- abeppu 2y ago
  To be clear, I'm not asking for anything. I'm raising a question, because I'm genuinely conflicted. It seems intractable to test everything for long enough to know that it's safe. On the other hand, the 20th century had some good examples of cases where we understood that something harmful only very long after it was in the environment (e.g. leaded gasoline). Also to be clear, at no point did I say 100% about anything. Please do not attempt to put words in my mouth, or to fight a straw man. We can all acknowledge that empirical studies don't give 100% certainty about anything. But it does also seem fundamentally problematic for us to make substances or materials ubiquitous in our environments faster than we can study them. We then also arrive at a methodological problem, where, for example we cannot meaningfully study whether long-term low-level exposure to PFAS are causing impacts on fertility in part because there is not a population that hasn't already had that exposure.
  - ryandrake 2y ago
    It doesn't seem like there's really a right answer. There is such a wide spectrum between "yolo everything into the market and find out later whether it is dangerous" and "don't do anything unless it's proven safe." I personally feel we can afford to throw innovation under the bus a little more than we do today, in exchange for more safety assurances, but reasonable people can disagree about it.
cush 2y ago
I think a lot of people might look at this kind of regulatory intervention and think it might be overstepping because of a lack of evidence. Like, are they acting prematurely? The answer is a definitive, no. Feasibility is irrelevant. It’s about scale. Once a substance is handled and consumed by no less than 100% of the population, with no viable way to replace these substances without a ton of work, it’s way too late. There are legitimate scientific concerns that we are currently damaging the human gene pool. Good regulations work well. It took a global effort to ban the CFCs that were destroying the ozone layer, and it’s completely repaired now.
- abeppu 2y ago
  I don't know why this got down-voted so much. Maybe scaling up too fast is the biggest part of the problem. Perhaps, putting it in a framing familiar to tech folk, if we have a new version of some important component of our application, "push it to 100% in prod before doing any data analysis because it hasn't been proven to be harmful to engagement" or whatever, probably wouldn't be acceptable to most of us. Maybe you do an A/B test and initially launch the new version to 5% and watch some stats, and if it does well, you scale up from there, incrementally expanding the audience and doing more data analysis. But that analysis depends on their being a population which you know hasn't received the new version. The problem happens when a switch to selling stuff in plastic/plastic-lined packages is driven by parties who don't have the interest or the ability to release to only a slice of the population, collect the data or do this analysis (and to roll back when the data shows a negative impact).
jjk166 2y ago
You can't prove things are safe, at best you can say harm hasn't been observed under these test conditions. In particular things with accumulative impacts may not show any signs of danger until millions of people have been using them for years. The only valid approach is to collect data as we go and make iterative changes as our understanding improves, we can not count on getting things right at the outset.
- deciplex 2y ago
  > You can't prove things are safe, at best you can say harm hasn't been observed under these test conditions. Are we doing that?
  - jjk166 2y ago
    Yes.
cynicalpeace 2y ago
For me, the standard is: if the material was used pre-industrial age, it's far more likely to be "safe". Any person could overintellectualize this point and find exceptions. But it's just common sense.
- __MatrixMan__ 2y ago
  I agree. I'm reminded of "the naturalistic fallacy" which asserts > Things are not necessarily safe just because they're natural Whatever "natural" means. It's not wrong exactly, but I think it distracts from some adjacent, non-fallacious inductive/anthropic reasoning: > Things that have not harmed your ancestors are less likely to harm you than a novel thing which your ancestors did not come in contact with. The former (safer) thing is more likely to end up with the label "natural" than the latter, newer thing. So "natural" ends up correlating with "safe" more often than chance would have it.
  - s1artibartfast 2y ago
    Why do we think our ancestors were not harmed? do we have any reason at all to think that?
    - __MatrixMan__ 2y ago
      Because we exist. Admittedly, "healthy enough to procreate" is not a high bar, but it's pretty good in comparison with no bar at all. Yeah, there are cases where they were unaware of the harm--like lead. We should absolutely be finding better ways to identify and mitigate harms of that sort. But in the absence of reliable information from such efforts, natural==safe is a viable heuristic. And I'd say that our scientific establishment is not sufficiently hardened against attempts by companies to tamper with scientific consensus in cases where that consensus might be bad for business--so an absence of reliable information is indeed our reality.
      - s1artibartfast 2y ago
        I think natural==safe is a terrible heuristic for the exact reason you said. Healthy enough to procreate is a low bar, and many natural things provide a benefit in terms of procreation but detrimental to health. Almost everything in nature is a trade-off between how much it'll harm you and how much it'll help you procreate. This reminds me of how whales get the Bends from diving despite 50 million years of evolution. People question whether it causes them pain, and it stands to reason that it would cause them pain to prevent them from diving more than necessary. Nature isn't inherently kind, it is results oriented. You can make a valid argument that avoiding something entirely is usually safer than something, as few things provide a protective effect. However, when you talk about substitutions, all bets are off.
maxlybbert 2y ago
In the US, at least, food regulations (and food packaging regulations) are relatively recent. And when they started, instead of requiring everybody prove that everything they’d been doing was safe, they came up with the idea of identifying substances or practices as Generally Recognized as Safe ( https://www.fda.gov/food/food-ingredients-packaging/generally-recognized-safe-gras https://www.fda.gov/food/food-ingredients-packaging/generall... ), and then requiring safety analysis on new substances or practices. And things can lose their GRAS status if new evidence turns up.
Vt71fcAqt7 2y ago
>is that the right standard? Or should there be an obligation to provide evidence that something is "safe" in order to use it I agree but the FDA might not have the legal authority to ban chemicals that are already in use that haven't been proven to be harmful. That is the case with the EPA IIRC. Although I think there actually is a lot of evidence pointing towards phthalates being harmful especially in utero.

by abeppu 2y ago

Aurornis 2y ago

How do you propose proving a negative?

mrcode007 2y ago
With modus tollens https://en.wikipedia.org/wiki/Modus_tollens https://en.wikipedia.org/wiki/Modus_tollens
esoterae 2y ago
I think the civil burden of proof should apply here. Upon the preponderance of the evidence. Given so many studies that exhaustively show correlative effects of phthalates with metabolic and endocrine disruption, especially strongly during developmental stages, I think even that burden of proof is met. Sure, you can't prove something doesn't exist, but you can make a reasonable determination that given exhaustive study, given correlative negative effects can be ascribed to no other known cause, and given that this is natal and pediatric health especially at stake, we should say until such time as a causative link is proven to lie elsewhere these chemicals should not be used in consumer goods out of an abundance of caution. The redirection of that claim would be "these profits are more important than moving to protect bodily health especially for those unable to protect themselves, given what we currently know." Honestly, no knowledge is perfect, but upon the balance we must rest our sacrosanct right to health.

lolinder 2y ago

Your second paragraph is a very good argument against requiring that everything used in food packaging be shown to be safe before it can be used. Can we reasonably run such a study to prove that wax paper is safe? What about plain paper? Do we just require all food producers to use no packaging at all until these controlled longitudinal studies are completed? If we allow them to use packaging, how do we define in a principled way what packaging is allowed while there are still unknowns? One possibility would be to say that if something is currently widely used in some significant (think 5%) portion of the industry then we allow it, but that has two problems: First, it wouldn't exclude phthalates anyway, so it doesn't address the current concern. Second, it might exclude future packaging materials that we think might be safer than our current materials but which have yet to be tested.

wizzwizz4 2y ago
> One possibility would be to say that if something is currently widely used in some significant (think 5%) portion of the industry then we allow it, We could say "if it was used in the ancestral environment for similar purposes, and is not known to be harmful". Much of that stuff is bad, but our bodies have mitigations for it. (e.g. tannins leached from wooden bowls: harmful in principle, but we can metabolise them so it's fine)
Retric 2y ago
Ideally rigorous testing should happen before something becomes common, but it isn’t the only option. Nothing stops you from a temporary ban say 20 years to allow for testing. Doing this for every chemical at the same time is impossible, but we can also cycle through existing chemicals. Hypothetically, if phthalates exposure was responsible for 5% of cancer deaths that’s 30,000 dead Americans per year and we might not notice without a ban. It’s unlikely for this specific chemical to be that bad, but we don’t know.
westurner 2y ago
Cellulose and algae are considered safe for human consumption and are also biodegradable; but is that an RCT study? CO2 + Lignin is not edible but is biodegradable and could replace plastics. "CO2 and Lignin-Based Sustainable Polymers with Closed-Loop Chemical Recycling" https://onlinelibrary.wiley.com/doi/10.1002/adfm.202403035 https://onlinelibrary.wiley.com/doi/10.1002/adfm.202403035 What incentives would incentivize the market to change over to sustainable biodegradable food-safe packaging?

Night_Thastus 2y ago

1. It's a lot harder to prove something is 100% assured safe then the other way around 2. Every substance/material/etc that is investigated and banned incurs overhead on taxpayers and industry directly. What you're asking for would be extremely prohibitive to getting anything done at all.

abeppu 2y ago
To be clear, I'm not asking for anything. I'm raising a question, because I'm genuinely conflicted. It seems intractable to test everything for long enough to know that it's safe. On the other hand, the 20th century had some good examples of cases where we understood that something harmful only very long after it was in the environment (e.g. leaded gasoline). Also to be clear, at no point did I say 100% about anything. Please do not attempt to put words in my mouth, or to fight a straw man. We can all acknowledge that empirical studies don't give 100% certainty about anything. But it does also seem fundamentally problematic for us to make substances or materials ubiquitous in our environments faster than we can study them. We then also arrive at a methodological problem, where, for example we cannot meaningfully study whether long-term low-level exposure to PFAS are causing impacts on fertility in part because there is not a population that hasn't already had that exposure.
- ryandrake 2y ago
  It doesn't seem like there's really a right answer. There is such a wide spectrum between "yolo everything into the market and find out later whether it is dangerous" and "don't do anything unless it's proven safe." I personally feel we can afford to throw innovation under the bus a little more than we do today, in exchange for more safety assurances, but reasonable people can disagree about it.

cush 2y ago

I think a lot of people might look at this kind of regulatory intervention and think it might be overstepping because of a lack of evidence. Like, are they acting prematurely? The answer is a definitive, no. Feasibility is irrelevant. It’s about scale. Once a substance is handled and consumed by no less than 100% of the population, with no viable way to replace these substances without a ton of work, it’s way too late. There are legitimate scientific concerns that we are currently damaging the human gene pool. Good regulations work well. It took a global effort to ban the CFCs that were destroying the ozone layer, and it’s completely repaired now.

abeppu 2y ago
I don't know why this got down-voted so much. Maybe scaling up too fast is the biggest part of the problem. Perhaps, putting it in a framing familiar to tech folk, if we have a new version of some important component of our application, "push it to 100% in prod before doing any data analysis because it hasn't been proven to be harmful to engagement" or whatever, probably wouldn't be acceptable to most of us. Maybe you do an A/B test and initially launch the new version to 5% and watch some stats, and if it does well, you scale up from there, incrementally expanding the audience and doing more data analysis. But that analysis depends on their being a population which you know hasn't received the new version. The problem happens when a switch to selling stuff in plastic/plastic-lined packages is driven by parties who don't have the interest or the ability to release to only a slice of the population, collect the data or do this analysis (and to roll back when the data shows a negative impact).

jjk166 2y ago

You can't prove things are safe, at best you can say harm hasn't been observed under these test conditions. In particular things with accumulative impacts may not show any signs of danger until millions of people have been using them for years. The only valid approach is to collect data as we go and make iterative changes as our understanding improves, we can not count on getting things right at the outset.

deciplex 2y ago
> You can't prove things are safe, at best you can say harm hasn't been observed under these test conditions. Are we doing that?
- jjk166 2y ago
  Yes.

cynicalpeace 2y ago

For me, the standard is: if the material was used pre-industrial age, it's far more likely to be "safe". Any person could overintellectualize this point and find exceptions. But it's just common sense.

__MatrixMan__ 2y ago
I agree. I'm reminded of "the naturalistic fallacy" which asserts > Things are not necessarily safe just because they're natural Whatever "natural" means. It's not wrong exactly, but I think it distracts from some adjacent, non-fallacious inductive/anthropic reasoning: > Things that have not harmed your ancestors are less likely to harm you than a novel thing which your ancestors did not come in contact with. The former (safer) thing is more likely to end up with the label "natural" than the latter, newer thing. So "natural" ends up correlating with "safe" more often than chance would have it.
- s1artibartfast 2y ago
  Why do we think our ancestors were not harmed? do we have any reason at all to think that?
  - __MatrixMan__ 2y ago
    Because we exist. Admittedly, "healthy enough to procreate" is not a high bar, but it's pretty good in comparison with no bar at all. Yeah, there are cases where they were unaware of the harm--like lead. We should absolutely be finding better ways to identify and mitigate harms of that sort. But in the absence of reliable information from such efforts, natural==safe is a viable heuristic. And I'd say that our scientific establishment is not sufficiently hardened against attempts by companies to tamper with scientific consensus in cases where that consensus might be bad for business--so an absence of reliable information is indeed our reality.
    - s1artibartfast 2y ago
      I think natural==safe is a terrible heuristic for the exact reason you said. Healthy enough to procreate is a low bar, and many natural things provide a benefit in terms of procreation but detrimental to health. Almost everything in nature is a trade-off between how much it'll harm you and how much it'll help you procreate. This reminds me of how whales get the Bends from diving despite 50 million years of evolution. People question whether it causes them pain, and it stands to reason that it would cause them pain to prevent them from diving more than necessary. Nature isn't inherently kind, it is results oriented. You can make a valid argument that avoiding something entirely is usually safer than something, as few things provide a protective effect. However, when you talk about substitutions, all bets are off.

maxlybbert 2y ago

In the US, at least, food regulations (and food packaging regulations) are relatively recent. And when they started, instead of requiring everybody prove that everything they’d been doing was safe, they came up with the idea of identifying substances or practices as Generally Recognized as Safe ( https://www.fda.gov/food/food-ingredients-packaging/generally-recognized-safe-gras https://www.fda.gov/food/food-ingredients-packaging/generall... ), and then requiring safety analysis on new substances or practices. And things can lose their GRAS status if new evidence turns up.

Vt71fcAqt7 2y ago

>is that the right standard? Or should there be an obligation to provide evidence that something is "safe" in order to use it I agree but the FDA might not have the legal authority to ban chemicals that are already in use that haven't been proven to be harmful. That is the case with the EPA IIRC. Although I think there actually is a lot of evidence pointing towards phthalates being harmful especially in utero.