Thanks for the analysis, and I mostly agree with your interpretation (having done no further research into this myself), but I’m confused how dividing by 1000 is the problem here. The levels are “basically fine” because 9*-they are well below the FDA/EPA limits, but the CA levels are only about 1 order of magnitude lower, not 3. If they had divided by 100, would we be interrogating their divisor choice? (The current implication is that that arbitrary approach would have been fine since it would correspond to FDA/EPA levels). It makes me think that maybe the impetus to question the arbitrary approach mainly stems from the conclusions not fitting our palate.
I think if the proposition had required the state to set a level for ongoing exposure, that would be fine. But instead it tells the state that the way they have to do that is by determining the level of single dose that just barely doesn’t give birth defects and dividing by 1,000. This is a really rough proxy, and ignores things like how quickly different materials are shed from the body. Learning that they were using such a rough measurement mostly pushes me in the direction of ignoring their level and paying attention instead to the levels that the federal government sets.
(I also initially misunderstood the role of the 1000x adjustment and edited the post based on Facebook discussion)
To answer your question, if they instead had a divisor of 100 or 10 I would still be advocating to put very little weight on their limit.
Thanks for the analysis, and I mostly agree with your interpretation (having done no further research into this myself), but I’m confused how dividing by 1000 is the problem here. The levels are “basically fine” because 9*-they are well below the FDA/EPA limits, but the CA levels are only about 1 order of magnitude lower, not 3. If they had divided by 100, would we be interrogating their divisor choice? (The current implication is that that arbitrary approach would have been fine since it would correspond to FDA/EPA levels). It makes me think that maybe the impetus to question the arbitrary approach mainly stems from the conclusions not fitting our palate.
I think if the proposition had required the state to set a level for ongoing exposure, that would be fine. But instead it tells the state that the way they have to do that is by determining the level of single dose that just barely doesn’t give birth defects and dividing by 1,000. This is a really rough proxy, and ignores things like how quickly different materials are shed from the body. Learning that they were using such a rough measurement mostly pushes me in the direction of ignoring their level and paying attention instead to the levels that the federal government sets.
(I also initially misunderstood the role of the 1000x adjustment and edited the post based on Facebook discussion)
To answer your question, if they instead had a divisor of 100 or 10 I would still be advocating to put very little weight on their limit.