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Hanlon Principle: Normativity and Heavy Metals (II)

Second part on this comparison between the Hanlon principle and the behavior of the paint and coating formulation sector presents some interesting questions and analyses.

by M.Sc. Ph.D. Julián A. Restrepo R.*

In the first part the theory about the meaning of the Hanlon Principle was introduced which highlights the theme of human stupidity over evil. Later we talked about the design and coatings and formulation where we delved into the different tools that are available today to perform a correct job. We will now look at how the Hanlon Principle is applied to paints and coatings.

"The Hanlon Principle" in the world of paintings
In a previous writing, he had already made a timid introduction to the "Hanlon Principle", analyzing some situations in the world of coatings:

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- Cost reduction of formulations hastily: This can lead to not adequately completing all the required technical information and an incomplete economic analysis can be had, which in the long run can lead to over-costs: If a measure is implemented with the aim of reducing costs, without dedicating the necessary time in the associated analyses required, there may be "hidden costs" and other unconsidered variables, which, if taken into account, could have determined that such a measure did not lead to the projected savings.

- Hot decisions, bad decisions: In some companies there are strong pressures for the fulfillment of results and indicators, for the reduction of the size of their development teams (number of people). The issue is that if this reduction is not done properly, that is, thinking long-term (and not short-term!) or decisions are made hastily, it may turn out that such teams end up dispensing with "key personnel" and now have the risk of "leakage of key information" and that it is available in the "labor exchange".

At this point I will give a twist to this writing, since it will go from being a technical document to an opinion article, where I intend to spin three concepts about which the reader will already be wondering: What does the "Hanlon Principle", the design of coatings and the normativity and toxic heavy metals have in common?

Thus, after the various news and alerts generated around toxic heavy metals in 2016, it would have been expected that in 2017 we would have a law or regulation on the subject. But I was surprised to find that we do have progress on the issue of regulation, with Resolution 1154 of June 22, 2016: "Paintings. Labelling regulation for water-based architectural paints type emulsion", but has nothing to do with the issue of heavy metal content in paints. In summary, it is a law that will begin to take effect from March 29, 2017, which motivates strict regulations for the labeling of water-based architectural paints (in the case of the Colombian market, vinyl type 1, 2 and 3). 

The fact is that the issue has generated some misinformation in the paint industry of our country, since it is understood that the government intends to regularize a part of the informal sector of paintings, which obliges that water-based architectural paintings clearly declare compliance with the associated national regulations (NTC 1335, for interior paints and NTC 5828, for high-strength exterior paints). 

For this reason, some local suppliers have organized events (such as aquaterra: "Aquaterra in the face of Resolution 1154") or prepared consultation documents on the network (such as Andercol:"Andercol tells you the details of Resolution 1154 of 2016") [15], to make this regulation more understandable. We could reason that if there is coherence of the reality of the paint market sector and the applicable legislation, there should not have been so much surprise and misinformation on the subject of Resolution 1154, since it would be a regulation that would be expected to arrive.

Analyzing in detail, I think we could say that issues associated with the regulation of toxic compounds would be more important when regulating the paint market, such as the issue of volatile organic compounds (VOCs), toxic heavy metals, halogenated compounds and solvents or persistent organic pollutants (POPs). Thinking about regulating the market for water-based architectural paints in terms of ensuring that the user is certain that their purchase product will meet a certain quality standard, can give them a guarantee of good performance, but, from my point of view, the issues associated with the toxicity of these materials should take precedence over performance. Although, logically, both are important, I think we do not intend to have on the market a water-based architectural paint that adequately meets a certain framework of quality specifications, forgetting the inherent toxicity of the product itself. 

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For example, and I will use a slightly demonic example, some paint supplier might think that they could have a paint for such an application formulated with lead carbonate instead of titanium dioxide, at a lower cost and meeting resistance to abrasion, washability, etc.

In turn, if we take into account the development and infrastructure, roads and communication routes in our countries (developing countries), we might think that it would be more important to regulate compliance with the performance specifications associated with, for example, road demarcation paints, where parameters such as color, retro-reflectance, resistance to exteriors, resistance to abrasion, vehicular traffic, high temperatures, heating and cooling cycles during the day, as well as resistance to greases, lubricants, oils and fuels, become a key element to contribute to road safety, both for drivers and pedestrians. In other words, wouldn't it make more sense to regulate the performance of road demarcation paints rather than architectural paintings for domestic use? Likewise, shouldn't the very composition of architectural paintings have been regulated for the subject of toxic heavy metals, instead of regulating only their performance?

Final comments
We have already exposed that various elements currently surround the market environment and the development of paints and coatings, being perhaps some of the most important: Globalization, Climate Change, environmental regulations, the massive use of the Internet and social networks, the use of materials from renewable sources, the search for alternative energies, the interest in travel and new sensations, the exploration of space, Nanotechnology, new materials, etc. All these elements exert an increasingly strong pressure on the painting companies, and also, the consumer looks for products that have a better cost/ benefit ratio, since he is increasingly better informed and therefore successful marketing processes become increasingly difficult. Added to this is the fact that, increasingly, these companies consider more elements and financial indicators to measure the balance of their efforts to increase the competitiveness of their companies in relation to their competitors [1h,i]. 

The fact that, as has been discussed in this paper, there is no coherence between what the market reports against what is regularized, indicates that perhaps you are not going in the same direction or you have different interests. And I will allow myself, perhaps as a science fiction writer, to pose the following future panorama: you do not start by regulating paints or various consumer products in terms of their content of toxic heavy metals and POPs, the issue is that paradoxically in the future, when it wants to be done, it simply will not be possible: Since this will depend on future generations (if anything, COPs allow them to exist!), In addition, they will tend to have higher levels of toxic pollutants (by bioaccumulation), while today the people in charge of making the related laws will simply be unable to do so because these levels of pollutants have already begun to affect them (lack of memory, ability to reason, etc.).  

It is a panorama that closely resembles (maintaining distances, they are comparable), to that of other ancient civilizations that disappeared. It is precisely this situation that has motivated me to relate the "Hanlon Principle", the design of coatings and regulations, with the effect of toxic heavy metals, and the fact that today we do nothing decisively to regulate their use in latin American industry, can only be related to the "Hanlon Principle": "Never attribute to evil what can be explained by stupidity."

Likewise, the various companies, in the same market, must cooperate with each other to maximize their profits (according to the "Nash Equilibrium"), instead of pointing to each other, indicating that some do not comply or have products with a high content of heavy metals or polluting compounds. Thus, in addition to being creative for product development, paint companies should be creative in the approach of their strategies, and in the way they relate to their competitors. The "Nash equilibrium" indicates that it is better to cooperate rather than compete, to maximize collective benefit.

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Finally, we can reason according to "Ockham's Razor": "The simplest answer is the right one", and perhaps the simplest thing is to regulate environmental impact (toxic heavy metals, for example) as well as the performance of products. But, due to bureaucratic issues, surely this is not possible, so I believe that consumer safety should always be first and think about a Sustainable Development scheme. 

Thinking about regulating paints on performance issues, and then entering them into regulation for environmental issues, will only introduce more unnecessary work or lead to the "invention of the bicycle again and again": When each manufacturer ensures that it complies with the applicable performance regulations, it must verify that it complies with the regulations associated with environmental issues and surely this can lead to new changes in its formulations, which must be maintained in the initial performance schemes. Fortunately, the paints and coatings industry has been an industry that has always been very dynamic and adaptive to the challenges that are presented to it.

References part II
[1] h) Restrepo, J.A. "Tools for the development of coatings, part I". Inpralatina, Vol. 20, No. 1, Jan/Feb 2015 pp. 17-20; i) Restrepo, J.A., "Tools for the development of coatings, part II". Inpralatina, Vol. 20, No. 2, Mar/Apr 2015 pp. 14-17
[15] http://www.andercol.com.co/images/pdf/legislacion-andercol-2017.pdf 

* M.Sc. Ph.D. Julián A. Restrepo R. Advisor and Technical Consultant in Coatings. [email protected] - Medellin, Colombia.

Duván Chaverra Agudelo
Author: Duván Chaverra Agudelo
Jefe Editorial en Latin Press, Inc,.
Comunicador Social y Periodista con experiencia de más de 16 años en medios de comunicación. Apasionado por la tecnología y por esta industria. [email protected]

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