There are up to 100,000 chemicals on sale in
Europe. Their production has increased enormously since World War Two, and their
residues have now spread widely into air, soil, water, sediments, wildlife and
its habitats, and even us. Their cost to human health and to the environment are
only now becoming evident.
For the vast majority of these substances, no adequate
toxicity data has been collected. For three-quarters of the chemicals used in
the largest amounts, there is insufficient toxicity data available for even a
minimal risk assessment under OECD guidelines.
Two reports, one from the European Environment Agency/UNEP(1)
and one from Friends of the Earth (FoE)(2), list the usual suspects linked to
chemicals: cancer, endocrine-disruption, decreasing sperm counts, and allergies.
All three refer to the precautionary principle, by which measures to protect
health and the environment can be taken without full scientific certainty. And
each paper demonstrates how completely differently it can be interpreted in
practice.
The paper from the Department of the Environment, Transport
and the Regions (DETR), Sustainable production and use of chemicals(3),
precedes a White Paper due in 1999.
Two European factors were particularly important in prompting
the review. The inter-governmental Oslo and Paris Convention (OSPAR) in 1998
requires drastic reductions of hazardous emissions into the North Sea. And
during the UK's Presidency of the EU, it dawned on UK ministers just how slow
and totally impractical the process of assessing chemicals under the Existing
Substances Regulations has become.
Seeking to balance industry interests with the concerns of a
wider society, the DETR quietly admit that the cost of carrying out the risk
assessments on these substances is now greater than the regulatory system can
bear. A comprehensive toxicity testing programme for just one substance is
ECU 5 million.
So, on the one hand, the government remains convinced that
given unlimited time and resources a full risk assessment based on sound
scientific principles is needed, on the other, they seek practical short-cut
solutions.
The DETR proposal for a system of selective testing, using
indicators to determine if a substance falls into a group of generically
hazardous chemicals-such as persistents, bio-accumulaters, or
endocrine-disruptors-is pragmatic, constituting a form of fast-track risk
assessment. And their recognition of the need to prioritise the assessment of
high volume chemicals is clearly rational.
FoE's report(4) comprises a briefing and a Joint
statement on chemicals and health onto which individuals and organisations
can sign. Focusing particularly on health risks to babies and children, the
report's author, Dr A Michael Warhurst, explains why dangerous chemicals can
remain on the market yet under suspicion for so long: "Making a causal link
. is almost impossible . The only way such a link can be proven in humans is
to expose a group, say pregnant mothers, to a known dose of a chemical, and
compare their health and their children's development, with another identical
group."
Yet in seeking to off-load the burden of assessment
regulation, the government courts industry to such an extent that a balanced
strategy is in jeopardy. The prospect of widespread industry
self-regulation-even with 'a system of auditing company assessments'-is
one for concern.
The EEA/UNEP report sets out in stark detail the gaps in
toxicity data for thousands of chemicals in use, and the need for the
forthcoming EC review of chemicals regulations.
But the report's authors describe a 'new paradigm' in
chemicals management, an approach based more on cooperation and incentives
rather than on 'command and control' regulations.
The risk assessment model in this report, based on what we
now know of the mobility of persistent pollutants in the environment, describes
an enormously complex and sophisticated new system. If it is necessary to know
the 'flow' of these chemicals globally, the task of assessing the impact of
each new substance, not just alone but in combination with thousands which are
already present, is a vast one. But evidence of unanticipated pollution
demonstrates its necessity: POPs in the arctic, for example, and concentrations
of synthetic pyrethroids in river sediments at 10,000 times the level in the
river water itself.
The report cites what is potentially the most radical new
legislative development in the world: the US Food Quality Protection Act,
requiring the government to consider the total risk of all multiple chemical
exposures when setting acceptable pesticide residue and daily intake levels.
Consumers should be protected from the risks chemicals pose
to health and the environment. FoE is encouraging people to write to the
Environment Minister Michael Meacher asking for the right to know what is in all
products and a comprehensive pollution inventory to give people information on
local sources of pollution. (AC)