Thank you.
Let me say something briefly about PFOS and phthalates and then draw a more general conclusion from it.
I think the important thing to watch on PFOS and PFOA, and this is certainly now being discussed in the Stockholm Convention, a group that is looking at new chemicals, is the science of what else breaks down to those. There's quite a belief in some evidence that virtually all the perfluorinated compounds will transform in the environment to PFOS and PFOA, but there's a lot of scrambling now to make that connection. The question in the Stockholm Convention is whether just to list PFOS or whether to list the other substances that break down to PFOS in the environment.
With regard to phthalates, this I think is more illustrative of one of the problems that I didn't mention that are important for your consideration in CEPA. The IJC in the early 1990s talked about sunsetting chemicals. This raises what's sometimes called the “sunrise issue”. If you're sunsetting chemicals, then what are you bringing in as alternatives? There are two ways, I believe, of looking at the sunrise issue.
With phthalates, initially there was absolute denial there was any problem with any phthalate, ever, and it took an enormous amount of activity by scientists and public interest against an extremely powerful lobby to demonstrate particularly the neonatal effects and other serious effects. Eventually, certain phthalates were banned for children's toys and other such uses. Although phthalates are not persistent, they are so widely used that people and the environment have large burdens of these, not because they persist, but because they're re-exposed so frequently. You have the same body burdens that you would have with something that's persistent.
The way it works with this and other chemicals is a lot of times many very similar chemicals can achieve the same function. You defend one as long as you can defend it and then you bring out a new one and then it will take 15 years to build a case on that one. On the one hand, the sunrise problem is a difficulty in the way new chemicals are often promoted. You take one that's structurally and chemically very similar to the one you're phasing out and you put it in because you know you've got 15 to 20 years before the case on that one can be made.
Generally, and I think this is something reflected in CEPA and that should be changed, the sunrise problem comes up in a different way, and in a way that's often misused. We heard about dry cleaning--and it's not trichlorethelene, it's perchloroethylene, the four carbon--