For any fine artist, this is important. Take a few minutes to give official feedback on this proposed ban of all Cadmium artist pigments in the EU. While it may not seem important to those of us who do not live there, it will have far reaching effects, including no longer being able to get some of the best paints made today because they are manufactured over there. Here are the comments I submitted: - While the motivation of the proposed restriction is laudable- namely reduction in public consumption of Cadmium via agricultural exposure originating from artist’s materials use- the prohibitive actions being proposed are unsubstantiated, unnecessary, based on falsely informed conjecture, and are highly detrimental to all professional artists. While the documentation accompanying the proposed regulation repeatedly state that cadmium from artists paints are assumed to end up in waste water, no evidence is provided to substantiate for that assumption. Furthermore, the assumption is made that the rate of cadmium deposited into waste water resulting from artist’s use is 0.5% of the volume sold as artists pigment, but, once again, no evidentiary justification for that figure is provided. For the sake of discussion, even if those assumptions are considered accurate for the moment, the anticipated reduction in cadmium deposits to agricultural soil is only 0.0014% of the total cadmium introduction which occurs. Let me repeat that: the assumed and unsubstantiated impact from artist’s pigment is only 0.0014% of the total annual addition of cadmium to agricultural soils. That means 99.9986% of all cadmium introduction is from sources other than artist’s pigments. According to the report’s own figures, the assumed impact of that 0.0014% has on the health of the public is incredibly small statistically. Of the nearly 380,000 annual cases of breast cancer in the EU, an increase of only 16 instances could statistically be attributed to artist’s use of cadmium pigment. That figure doesn’t list fatalities, but all instances of the disease. There are thousands of societal, industrial, and environmental factors that have a far more profoundly damaging impact on public health, so why is this incredibly disruptive intrusion into professional artistic practice even being proposed or considered? Turning aside from the questionable and negligible influence of the proposed prohibition, let us consider the highly detrimental economic, aesthetic, technical, and practical disruption to professional fine artist the ban will have. The report attending the cadmium ban claims that there are excellent and suitable alternatives to cadmium pigments. That claim is horrendously incorrect. There are no substitutes for the pigment intensity, visual saturation, light-fastness, opacity, or tinting strength of cadmium paints. There have been cadmium alternatives sold in poor quality and student grade paints for many years, but most professional fine artist do not use them because they are truly inferior. Consider the following: 1) Paint Mixing and Handling- The colour mixing properties of Cadmium paints are unparalleled by other proposed substitutes. When mixed with other pigment colours, cadmiums behave and interact in a manner that cannot be duplicated by other options. 2) Tinting Strength- When mixed with white, other pigments do not have the ability to create the same intensity of colour at a high level of brightness. Alternatives to cadmium also do not retain their important particular hue when mixed with white, but shift in perceptual colour. That same intense pigment strength is also vital in achieving desired colour values when mixed with other pigments. 3) Opacity and Covering Power- Pigment alternatives that are superficially similar in hue do not have anywhere near the same level of opacity possessed by cadmiums. This means that the artist cannot effectively cover lower layers of paint when desired. That may not seem important to the uneducated, but it eliminates the ability to use varying degrees of viscosity in the application of paint or to achieve a vast range of effects that are possible with cadmiums. Simply put, removing cadmium as an option critically hamstrings and hobbles the potential of every professional artist. 4) Cadmium colours are permanent and light-fast to a degree which substitutes cannot begin to match. Light fastness is not just of minor importance to serious and professional artists, it is imperative. The longevity of a painting depends on using pigments and materials that are highly stable, both physically and visually over time. Even the very best of the secondary options used to replace cadmium paints are far less light fast. This means certain pigments in a painting will degrade, change, and fade over time. Such changes can completely destroy a priceless piece of art work, ruin an artist’s career, and result in costly litigation 5) Unintended Repercussions- The proposed regulation repeatedly asserts that the alternative pigments are actually lower in cost and will thus benefit artists economically, but it is readily apparent the replacements are problematic and inferior in many ways. While it is absurd to assert that lower cost is an acceptable or viable exchange for inferior and problematic products, there are other economic impacts of imposing the use of alternatives that are glaringly left our of consideration. The proficiency of highly skilled artists relies on their technical experience, knowledge, and familiarity with their tools and media. Forcing a change in those tools and media is not a mere inconvenience, it is a potentially catastrophic disruption, amounting to years or decades of stolen experience, development, and life investment. The impact is far more wide reaching, though. If pigments that are inferior and less light fast are all that is available to artists, then artwork will not be able to be displayed without special precautions, whether in homes, businesses, or museums. Special and very expensive framing, lights, screens, windows, and other considerations will be required for proper preservation of art. Those precautions will incur enormous cost and burden. With, or even without preventative measures, the inferior light fastness and longevity of artwork created using alternative pigments will result in damaged art. Such losses and corruption of valuable art will result in substantial harm to fine artists, collectors, investors, companies, and institutions such as museums. It is clear, according to the very numbers and information provided to ostensibly justify a sweeping government ban, that there is negligible effect on public health incurred by the use of cadmiums by professional artists. By the researchers own figures, which rely on multiple unsubstantiated assumptions, the use cadmium by artists account for less than 0.00425% of all cadmium related illnesses in the EU! Compare that to the far reaching and profoundly detrimental consequences that this onerous and intensely restrictive ban will have on many thousands of professional fine artists. Who is going to quantify and provide restitution for the enormous monetary and personal loss imposed externally upon them? But the proposed ban doesnt just harm individual artists, it places the entire art industry and art infused culture of the European Union at a disadvantage on the world stage. Enacting this regulation would be a tragic disservice to all who are involved with and recognize the importance of art, whether in the private, public, or government sectors.
Posted on: Wed, 02 Jul 2014 20:14:42 +0000
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