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The EEA and UNEP Annual Message 2 on the State of ’s Environment

Chemicals in the European Environment: Low Doses, High Stakes?

Office for Official Publications of the European Communities The EEA and UNEP Annual Message 2 on the State of Europe’s Environment

Chemicals in the European Environment: Low Doses, High Stakes? Contents Acknowledgements

Preface ...... 2 The rep o r t was written and edited by David David Stanners (Programme Manager, Gee (EEA), with substantial contributions European Environment Agency). Summary ...... 3 from David Stanners, Domingo Jiménez- 1. Introduction ...... 4 Beltrán (EEA), from Prof. Philippe Bour- Layout and graphics: HØILAND DESIGN, 2. Chemicals without borders ...... 5 deau and Prof. B. Jansson of the EEA Copenhagen, Denmark. Scientific Committee, and from David 3. Many chemicals, but limited toxicity data ...... 7 Ogden and Jim Willis of UNEP. Printed on official environmentally ap- 4. Risk assessment ...... 8 proved paper with vegetable-based print- Comments were also gratefully received ing inks. 5. Ecological and human impacts ...... 11 from very many individuals, but final 6. Some policy initiatives for reducing risk ...... 16 responsibility for the report rests with The publication is approved under the EEA and UNEP. Nordic environmental seal, Svanen. 7. A new paradigm for chemicals management? ...... 19 Licence no 241 006. 8. Conclusions ...... 26 The project was co-ordinated by Mr Ronald G. Witt (Regional Co-ordinator Environmentally certified and Acronyms ...... 27 UNEP/ DEIA/GRID – Geneva) and Dr EMAS-approved. References ...... 28

The EEA and UNEP have published this state of the Legal Notice environment message on “Chemicals in the European Neither the European Environment Agency nor the expression of any opinion whatsoever on the Environment” in order to UN E P , nor any person or company acting on their part of UNEP or the European Environment raise awareness of the issues, behalf, is responsible for the use which may be Agency concerning the legal status of any and to help build the public and political support needed made of the information in this publication. country, territor y, city or area, or of its author- for all to enjoy the benefits The designations employed and the presenta- ities, or concerning the delimitation of its fron- of chemicals, but at a re- tion of material in this publication do not imply tiers or boundaries. duced cost both to nature and human society. 2 Chemicals in the European Environment: Low Doses, High Stakes?

Preface

Following the first joint annual message on is not far behind. Talks on a worldwide water stress in 1997, the EEA and UNEP POPs treaty began soon after in Montreal. are pleased to publish a statement on an- These global talks are critical for Europe other subject of prime concern: Chemicals because POPs released in one part of the in the Environment. As “watchers” of Eur- world can be transported to regions far ope’s Environment, these statements aim away from their original source. to raise public and political awareness on Encouraging as these efforts may be, a critical or emerging issues to facilitate great deal remains to be done because pre v e n tative action by governments and many thousands of chemicals are on the others. market but without adequate information This year’s annual message comes to you on their fate and impact on people and at a time when international activity in ecosystems. chemicals and the environment is moving As the costs of conducting toxicity testing into higher gear. The European Commis- of these chemicals and their degradation sion has begun a review of EU policies on products under realistic conditions of chemicals, and governments have recently exposure would be very large, considera- agreed the text of the so-called “prior in- tion is being given to reducing progres- formed consent” or PIC Convention, regu- sively – but substantially – unwanted expos- lating international trade in hazardous ures to potentially hazardous chemicals chemicals. PIC will establish an interna t i o n - that persist and accumulate in the environ- al alert list and help developing co u n t r i e s ment: this seems to be an appropriate ap- obtain the information they need to pro- plication of the precautionary principle to tect their citizens and their environment. the problems of chemicals. By preventing unwanted imports of dan- At the same time, more risk assessments gerous chemicals, this convention will pro- and improved implementation of existing vide a first line of defence against future laws are urgently needed if an appropriate tragedies. balance is to be struck between the risks Meanwhile, rapid progress is also being and benefits of chemicals. made in reducing releases and emissions These different issues require the partici- of persistent organic , or POPs. pation of civil society and increased public We now understand that in addition to the awareness and education. We must also deaths and acute effects caused by direct provide industry with long-term scenarios and immediate contact, POPs – which in- that they can adjust to by developing effi- clude some of the most toxic chemicals cient and lower-cost alternatives which will ever made – can cause cancer, allergies, enable them to stay in business by doing damage to the central and peripheral ner- sustainable business. vous systems, diseases of the immune sys- Clearly, solutions must be tailored to the tem, reproductive disorders, interference properties and uses of each particular with normal infant and child development, chemical and groups of chemicals, as well as well as damage to wildlife. as to each country’s unique circumstances. European countries have adopted an But action must be taken quickly. Each agreement on POPs under the Convention year that passes without effective action on Long-Range Transboundary Air Pollu- will result in decades of additional, unin- tion at the fourth European conference of tended exposure to chemicals that are like- environment ministers in June 1998 in ly to be harmful to human health and the Aarhus, Denmark. The global community environment.

Domingo Jiménez-Beltrán Klaus Toepfer Executive Director Executive Director European Environment Agency UNEP Summary 3

Summary

• Manufactured chemicals are widespread particularly to sensitive groups such as in the air, soil, water, sediments and bio- children and pregnant women, and to ta of Europe’s environment, following parts of the environment. the marketing of up to 100,000 chemi- cals in the EU, their use and disposal, • The evidence for some chemical and degradation. hazards in some people is increasing, particularly for neurotoxins, endocrine • There is a serious lack of monitoring disruptors that may damage develop- and information on these chemicals; mental and reproductive health, cancers their concentration and dispersion in and allergies. The evidence on disturb- air, water, sediments, soils, species and ances to wildlife and ecosystems from food; and related exposures and effects low level chemical exposures is also in- on people and ecosystems. creasing.

• Various control measures have reduced • Because some of these hazards are risks, and some emissions and concen- serious, irreversible and take a long trations are declining in Europe, parti c u - time to appear, action to reduce expos- larly of a few persistent organic pollu- ure without waiting for certain proof tants (POPs) and heavy metals, but of harm is now included in many inter- some of these concentrations remain at national agreements (the “precaution- levels that may be hazardous. ary principle”).

• Current toxicity risk assessments are • This encourages (as a supplement to based mainly on single substances, but toxicity testing) the reduction and pre- people and ecosystems are generally vention of exposure through reducing exposed to very complex mixtures. chemical “loads” in the environment, particularly of substances that persist • For 75% of the 2,000 - 3,000 large vol- and bio-accumulate and which therefore ume chemicals on the market there is are a potential threat to people and the insufficient toxicity and eco-toxicity data environment. publicly available for “minimal” risk assessment under OECD guidelines. • Many laws exist to protect workers, con- sumers and the environment, but their • The costs in time and res o u r ces of filling implementation and effectiveness can the toxicity and exposure data gaps for be poor. the thousands of chemicals in use, their breakdown products and relevant mix- • Awareness of the environmental and tures, will be large, as the comprehen- social costs (“externalities”) of chem- sive toxicity testing of one substance icals is increasing, along with the associ- costs an estimated ECU 5 M. ated use of taxes on chemicals to bring these costs into market prices, thereby • While there is little direct scientific evi- encouraging greater eco-efficiency in dence of widespread ill health or eco- their production and use. system damage being caused by most manufactured chemicals, apart from • There is increasing use of public infor- layer depletion, impacts from fos- mation, both about chemicals in con- sil fuel combustion emissions, and acute sumer products and about emissions of impacts, such as from accidents or local chemicals to the environment, and they spillages, “no evidence” does not neces- appear to be effective in encouraging sarily mean “no effects”. The difficulties less hazardous production and use of and costs of detecting effects, the long chemicals. time lags between exposure and some effects, and the absence of relevant stud- • Chemical fe e d s t o c k s fr om “softer” chem- ies and data mean that the widespread icals than fossil fuels, such as plants, are exposures to low doses of chemicals may being developed. be causing harm, possibly irreversibly, 4 Chemicals in the European Environment: Low Doses, High Stakes?

1. Introduction

Ma n u f a c t u r ed chemicals play a key role in unless they enter the manufactured chem- the provision of a large range of goods and ical processes, they are not covered here. se r vices that support our lifestyles and econ- nomies. However, even small amounts of Some are mentioned, but parti- some chemicals can endanger human cular legal controls on pesticides and bio- health and the environment. With increa s - cides are not covered in this survey. ing quantities of such chemicals in the en- vi r onment and improved scientific under- The current rep o r t aims to improve public standing of their effects on people and eco- aw a r eness by exploring four key questions systems, the challenge is to find the right co n c e r ning the management of chemicals: balance between the benefits and risks of chemicals. This is a “dilemma for modern 1. How many chemicals are there on the society: we use chemical substances to solve prob - market and what is known about their lems, but we don’t know the price we have to pay ha z a rd s ? in terms of health and environment. We cannot 2. What is known about how chemicals exclude the risk of unpleasant surprises from move through and accumulate in the chemicals of the kind man has repeatedly experi - en v i ro n m e n t ? enced in the past.” (KEMI, 1998.) 3. What are the known and suspected human and ecological risks from expo- To what extent is Europ e ’ s use of chemicals su r e to chemicals? af fecting people and the environment? 4. What are the current and emerging Paracelsus, the 16th century father of the policy initiatives for reducing or elimin- science of poisons (toxicology) said “A l l ating these risks ? substances are poisons: it is the dose that deter- mines whether they act as a poison or a rem e d y ” Th e r e are many uncertainties about the (C a s s a r ett and Doull, 1980). A chemical impacts of chemicals on people and the may be potentially harmful (toxic), but if en v i r onment, but the scientific and policy th e r e is no, or very little ex p o s u r e (“ d o s e ” ) complexities are better appreciated and to people or the environment, there is no understood than they were just a decade or chance, or risk of harm (Fig. 1). so ago. This has encouraged the develop- Figure 1 Both toxicity and sufficient exposure are ment of a “new paradigm” in chemicals risk ne c e s s a r y to cause harm management based on the “prec a u t i o n a r y principle” and on the provision of incen- tives to reduce the total “dose” of chemicals potentially hazardous to the environ m e n t .

Ho w e v e r , as seen with the CFC chemicals In this context, the European Commission that have damaged the , it is has begun a stock-taking of the legislative very difficult to know, or predict, what the in s t r uments governing chemicals, com- harmful level of exposure to chemicals mencing in 1998 with the review of: may be, and then to ensure that actual • the classification, packaging and exposures in the environment are kept labelling of dangerous substances Di- below those levels. Certainty in these mat- rective No 67/548/EEC ters is rare, so all who have a stake in the • the existing substances Regulation, risks of harm from chemicals – the public, (EEC) No 793/93. businesses, policy-makers and scientists – have a role in trying to determine an ac- The focus of this rep o r t is manufactured ceptable “dose” of chemicals for human- chemicals in Europe, but some informa t i o n kind and for the planet. relates only to the EU, or to developments in other countries in the OECD (Orga n i s a - Natural chemicals are also widespread in tion for Economic Co-operation and Devel- the environment and may cause problems opment), which reflect the global nature of for human health and ecosystems, but the production and use of chemicals. 2. Chemicals without borders 5

2. Chemicals without borders

Most chemicals find their way into the en- The “Grasshopper” Effect: Figure 2 vironment via millions of consumer, agri- Pathways and Processes involved in the cultural and industrial products and pro- long-range of semi-volatile cesses. Once in the environment, they can Persistent Organic Pollutants (POPs) persist for long periods of time or break down into other chemicals with their own risks. They may also produce health or environmental effects when they act to- gether with other natural or manufactured chemicals that are already in the environ- ment.

Tracking the pathways, fate and exposure implications of chemicals is essential for effective risk management, but it is com- plex. It requires:

1. identifying the flows of each chemical and its by-products through the econ- omy, from or synthesis to manu- facture, marketing and use, and on to possible recycling and ultimate disposal; Source: CCEC, 1997

2. estimating emissions, pathways and depositions both to and from air, water, ef fect (Fig. 2). POPs released in one part sediment and soil from the processes of the world, via pesticides for example, and products at each stage of their life can, through a repeated (and often season- cycle and identifying transformations of al) process of release, deposit, release, and each chemical and resulting compounds; deposit again, be transported to regions far away from their original source. This is 3. constructing an area model why POPs can be found in the Arctic, (or “regional mass balance”) for assess- thousands of kilometres from any major ing the inputs, outputs, and fate of the source of POPs. chemicals on a geographic basis, and then estimating the likely exposures of Heavy metals such as lead, cadmium and people and ecosystems to the chem- more complex POPs like dioxins can also icals. disperse over long distances. For example, cadmium in the Rhine basin in Germany This kind of analysis req u i r es data and has been on the increase for many years in f o r mation which is only available for very due to pollution from a number of source s , few chemical substances (EEA, 1998a). including oil combustion, steel prod u c t i o n , zinc refining, cadmium plate manufactur- Some organic (-based) substances ing, and municipal waste disposal (Fig. 3). persist in the environment, travel long Because cadmium accumulates in soils and distances and consequently circulate glob- groundwater, efforts to reduce cadmium ally. This means that although these persi- pollution could take about 15 years to start stent organic pollutants (POPs) can be reversing the upward trend. Inhabitants of found almost anywhere, it is difficult to the region may be exposed to cadmium identify where they originated, let alone greater than the World Health Organiza- the pathways by which they travelled. tion’s recommended maximum acceptable levels, especially if the soil is acidified (Stig- One of the main ways that the most volatile liani and Anderberg, 1994). Similarly, some POPs travel is through the “grasshopper” pesticides can percolate slowly through soil 6 Chemicals in the European Environment: Low Doses, High Stakes?

Figure 3 Estimated build-up of cadmium in POPs can also travel through living organ- agricultural soils in the Rhine Basin isms and can become increasingly concen- 1950-1988 trated in the tissues of animals at high levels of the food chain, such as predatory birds and mammals, including humans. This “bio-magnification” can, for example, increase concentrations of polychlorinated biphenyls (PCBs) to many million times their initial presence in the physical envir- onment.

The ways in which humans and the envir- onment are exposed to chemicals are thus multiple and complex, and exposure to Source: mixtures, not just single substances, is Stigliani & Anderberg, 1994 common. However, enough is known about the exposures and effects of certain substances, including some POPs and and accumulate in groundwater and river heavy metals, to justify reducing exposure sediments long after their use has stopped. to them and to other chemicals that also For example, pyrethroid insecticides have persist and bioaccumulate. In addition, been detected in river sediments at 10,000 more research is needed in order to better times the level in the river water, where any understand the movements and metabol- monitoring of chemicals is usually focused. ism of the thousands of other chemicals (Neal et al., 1997, 1998). released and present in the environment. 3. Many chemicals, but limited toxicity data 7

3. Many chemicals, but limited toxicity data

The world-wide chemicals industry pro- High Production Volume Chemicals, based duced 400 million tons of chemicals in mainly on their hazardous potential. Data 1995. Europe is the largest chemicals-pro- on these chemicals is available in the Inter- ducing region in the world, accounting for national Uniform Chemical In f o rm a t i o n 38% of the total; Western Europe alone Database (IUCLID) held by the European accounts for 33% (UNECE, 1997). Chem- Chemicals Bureau (ECB) of the EC’s Joint icals production and use provide 2% of Research Centre, Ispra, Italy. Europe’s GDP and 7% of its employment. The EU exports 22% of its chemicals (by In addition to chemicals that are placed value) and imports 15%. Germany pro- on the market, either as intermediates vides 26% of EU chemicals production, within a production process, or as part of France 19% with the UK and Italy each final products, there is the unintentional providing 12% in 1996 (CEFIC, 1997). formation of chemical by-products in a number of processes, such as energy pro- Chemicals production grew roughly in line duction and metal refining, which can also with GDP until 1993 when it began to grow impact on the environment. faster. The “chemicals intensity” (i.e. the volume of chemicals per unit of GDP) of The rise in the quantities and the variety Europe’s economy is now therefore higher of substances released and accumulating than it was five years ago (Fig. 4). This in Europe’s environment increases the growth, however, has been limited to potential for damage to human health and Western Europe. In Central and Eastern the environment. The level of these risks is European countries (where GDP declined determined by their toxicities and by their by 35% from 1989 to 1995), chemicals pro- “doses” to people and/or ecosystems. duction has declined. Production seems to “Risk assessment” is used to try and iden- have bottomed out now, however, and is tify potentially harmful exposure levels so on the way to recovery in Bulgaria, the that they can be avoided. Czech Republic, Estonia, Hungar y, Poland and Slovenia. Sales of pesticides in Europe, by value and by tons of active ingredients, fell between 1991 and 1995 but have risen since then (ECPA, 1997).

The number of existing chemicals on the market is large, but the exact number is unknown. Over 100,000 were registered in the European Inventory of Existing Com- mercial Chemical Substances (EINECS) in 1981, but the current estimate of marketed Western European chemical industry Figure 4 chemicals varies widely, from 20,000 to as production and GDP many as 70,000 (Teknologi-Rådet, 1996). Little is known about the toxicity of about 75% of these chemicals (NRC, 1984; EDF, 1997). Several hundred new substances are marketed each year after some basic pre- market toxicity testing and these are regis- tered in the European List of Notified Chemical Substances (ELINCS), which presently contains about 2,000 chemicals. Of the existing chemicals, some chemicals have been selected for risk assessment by the EU, in the framework of OECD’s pro- gramme on co-operative investigation of Source: CEFIC, 1997 8 Chemicals in the European Environment: Low Doses, High Stakes?

4. Risk Assessment

The EU initially focused on the hazard Although searching more databases reveals assessment of new chemicals put on the more data, the results from recent surveys market after 1981 which were required to by the US EPA and the Chemical Manufac- have some pre-market toxicity testing. In turers Association of America confirms 1993, the EU began to assess the risks of that about 75% of chemicals have insuffi- the 100,000 existing and 2,000 new chem- cient toxicity or eco-toxicity data for preli- icals that have no, limited, or adequate minary OECD risk assessments (CMA, toxicity and/or eco-toxicity data, starting 1998). with those whose production exceeds 1,000 tonnes a year (Fig.5). There are 2,500 of More toxicity and eco-toxicity data is held these high production volume chemicals by companies and regulatory authorities in (HPVCs) which are currently being assess- the EU and elsewhere. Some of this is con- ed by the European Chemicals Bureau fidential and not available to the public for (ECB). These risk assessments are perf o rm - peer review, but some is being made avail- ed by the EU and Member States, and they able to the authorities and the public. require comprehensive information and data, which are often not available. It is difficult to even broadly classify chem- icals as “dangerous”, under labelling re- For about 75% of the 3,000 or so chemicals in quirements, for example, without minimal la r ge-scale use, the “minimal” toxicity data toxicity data (Tem a n o r d, 1997). Box 1 illus- req u i r ed by the OECD for a prel i m i n a r y tr a t e s these main toxicity data gaps. Filling assessment of health hazards to humans is not these gaps is a priority, but a costly one. publicly available (NRC, 1984; EDF, 1997). Costs vary from ECU 100,000 for a basic Si m i l a r l y , little is known about eco-toxicity. set of toxicity data to an estimated ECU 5 million for the comprehensive toxicity testing of one substance, and up to ECU Box 1 Some toxicity and exposure data gaps 15 million for exceptional cases where • No adequate toxicity data for about 75% of field testing and monitoring are needed substances in use (Teknologi-Rådet, 1996). • No adequate ecotoxity data for 50-75% of There is also a need for the toxicity testing the priority (HPVC) chemicals reviewed by the EU of mixtures (EHP, 1997a), since current risk assessments are usually based on single sub - • A “major lack” of human health and exposure stances. Mixtures may be more or less toxic Source: European Environ- data for these priority chemicals ment Agency, based on NRC than the additive effects of single sub- (1984), EDF (1997), van • Chemical structure data (QSARs) may provide stances. Thousands of animals are needed Leeuwen et al. (1996), and only a reliable estimate of the aquatic toxicity for these tests, a practice which itself is also van der Wielen (1996) of 15-20% of HPVCs. a controversial issue. Steps are being taken to minimise use of animals in toxicity test- Box 2 Some other chemical data deficiencies ing by the European Centre for the Valida- • Production and use of marketed substances tion of Alternative Methods of the Joint and their presence in consumer products; Research Centre. The relevance of animal • Pathways, fate and concentrations of test results for risks to humans is also diffi- chemicals in the environment; cult to establish, and is complicated by spe- • Human and ecosystems total exposure cies dependent effects. For example, including multiple exposures and mixtures; humans are 100 times more sensitive to • Identity of sensitive subgroups of people, the birth-defect impact of thalidomide other species and ecosystems; than rats (Epstein, 1978). Some chemicals may be harmful to rats at high doses, but • Nature and costs of impacts on people and not to humans at lower doses. the environment and their distribution;

Source: European • “Eco-efficiency” ratios for the production/use There are also data gaps concerning the Environment Agency of chemicals. pathways and use of chemicals and related 4. Risk Assessment 9

Many chemicals, limited toxicity data Figure 5

HPVC High Production Volume Chemicals, i.e. production over 1,000 tons/year Little/no toxicity = less than OECD minimum for screening Limited toxicity data available for OECD/EU screening (e.g. only 20-30% of substances have useable data on cancer or reproduction)

EINECS: European Inventory of Existing Commercial Chemical Substances Note: In addition to the EU existing chemicals risk as- IUCLID: International Uniform Chemical Information Data Base sessment programme, both Adequate toxicity for EU risk assessment (including some cancer/ the OECD and WHO/IPCS reproductive/neurotoxic data) but inadequate data on consumer or have completed detailed risk assessments covering about environmental exposures 200 priority chemicals. ELINCS: European List of Notified Chemical Substances (New Substances) Limited data available for basic toxicity screening Source: EEA, based on CEC (1996), NRC (1984), EDF 400 risk assessments carried out by Member States (confidential data) (1997) and ECB (1998). ex p o s u r es (Box 2), which makes risk assess- the public. However, available financial ment difficult, especially when the identity res o u r ces are only sufficient for an adequate of the chemicals is difficult to establish assessment of about 20-30 chemicals per (Johnston et al., 1996). The time taken to year. Assessments of 10 chemicals were complete risk assessments is causing con- completed under the EU existing chem- cern (, 1996), and the quality icals risk assessment programme by the of most of the toxicity data submitted by end of 1997 (F i g . 5) . Progress will acceler- businesses to the regulatory authorities is ate in 1998, during which another 25 risk not checked by the authorities. assessments are expected to be completed.

More than 10,000 existing chemicals will The EU’s risk assessment programme is be on the ECB database (IUCLID) by the part of the legal scheme to reduce the end of 1998. This is a data source for the risks of use of dangerous chemicals for authorities of Member States and for risk man and the environment. Besides that it assessments, and ECB will make the non- fits into the OECD programme on the co- confidential part available to industry and operative testing and assessing of HPV 10 Chemicals in the European Environment: Low Doses, High Stakes?

Chemicals. The OECD and their member process of risk assessment and risk reduc- countries are currently working on 240 tion. The problem of accumulative expos- chemicals and have completed 109 initial ures to chemicals with similar biological risk assessments over the last decade. Of effects has recently been addressed by the these, 86 substances were considered of Food Quality Protection Act, 1996, in the “low” risk, 13 needed more testing or ex- USA. This req u i r es the government to con- po s u r e information, and, for 10 substances, sider total risk from several ex- further risk management measures were posures, rather than from single expos- considered necessary, in some exposure ures, when setting “acceptable pesticide situations (OECD, 1998a). The World residues and daily intakes.” Health Organization, through its Inter- national Programme on An exposure-based assessment that uses (IPCS) and partners, UNEP and the Inter- the persistence and spatial range of the national Labour Organisation (ILO), have chemical as an indicator of environmental also conducted peer reviewed risk assess- threat requires less data, and can usually ments of chemicals since 1976. Over 200 be performed faster, than a toxic effects assessments have been completed and based risk assessment (Berg and Scherin- published in the WHO Environmental ger, 1994). It can also help to identify any Health Criteria Monographs, with most gaps between those who benefit from providing numerical “guideline values” for chemicals and those who bear the environ- exposure limits designed to protect people mental or health damage, as chemicals and the environment from damage. Sum- with a high persistence and spatial range maries of key scientific studies are pub- can distribute costs over a much wider area lished in their new Concise International than that which receives the benefits, as, Chemical Assessment Documents (CICAD), for example, with CFCs and ozone layer of which the first 6 were published in 1998 damage. It has been suggested that (IPCS, 1998). In addition, IPCS also evalu- exposu r e-based threat assessment could be ates chemicals in food and pesticides, pro- us e d for the initial screening of chemicals, ducing “acceptable daily intakes” limits for complemented by toxic effects risk assess- over 1,000 food additives and 220 pesti- me n t , where this is likely to be cost effect- cides. Measures are being taken to harmo- ive and where data is available (Scheringer, nise these approaches to risk assessment 1997). and to minimise duplication between the EU, the OECD and IPCS programmes. Exposure potential is also important for assessing the toxic risks from chemical There is also an increasing focus on the emissions – those assessment methods that chemical properties of groups of chemicals, incorporate the most comprehensive such as those that pe r s i s t and bi o - a c c u m u l a t e , human exposure data seem to produce the rather than on the specific toxicity of single best estimates of risk, which can vary by 3 substances (Teknologi-Rådet, 1996; Swe- orders of magnitude (i.e. by 1,000 times), dish Ministry of Environment, 1997), and depending on the method chosen (Hert- this may help to speed up and focus the wich et al., 1998). 5. Ecological and human impacts 11

5. Ecological and human impacts

Ecological Impacts exposure to chemicals for many people. Major stationary and mobile sources of Although the ecological impacts of chem- exposure, such as factory chimneys, may icals are complex, some effects are well- now account for less than 25% of total documented. The effects on various ani- exposure, according to US estimates mals, birds (Campbell and Cooke, 1997) (Wallace, 1993). and fish (Cameron & Berg, 1994; Stebbing et al., 1992), include birth defects, cancers, Another problem in identifying risks from and damage to nervous, reproductive and chemicals arises from the need to account immune systems (see Box 4). For example, for the effects of other causal agents such dichlorodiphenyl trichloroethane (DDT) as smoking, radiation, and natural toxins, was implicated in the early 1970s as the which can also cause ill-health or ecologic- cause of reproductive failure in eagles and al damage, either separately, or sometimes other birds, due to the thinning of egg in combination with manufactured chem- shells. Since then, a number of other cases icals (EEA, 1998b). Furthermore, there are involving wildlife have been studied, in- usually large gaps in time between an ex- cluding large fish kills and declines in sea posure to a chemical, the observation of mammal populations. Contamination of possible ill effects, and a medical or scien- fish by , PCBs and other toxic tific assessment about association and caus- chemicals appears to be increasing in the ation (Box 3). Health prob l e m s , such as USA (NRDC, 1998) and evidence about cancer or allergies, are difficult to under- the effects of low-level but possibly wide- stand when they involve several, often spread contamination of fish is increasing inter-dependent causes, of which “chem- in Europe (Matthiessen, 1998; Tyl e r , 1998). ical cocktails” may only be a part. The level, Recent results from the UK, for example, and burden of proof of harm, are also crit- suggest that the incidence of feminisation ical issues in risk assessment (Gee, 1995; and other sexual disruption in fish “is high- Bro-Rasmussen, 1997). People at risk and er than previously thought and is associated other stakeholders including consumer with discharges from treatment works” (EA, 1998). Association and causality Box 3

The complexity of ecosystems, such as the It is sometimes fairly easy to show that a meas- ure of ill-health (e.g. the number of admissions North Sea, makes risk assessment very dif- to hospital per day) is associated with a possible ficult without extensive multi-disciplinary cause, such as the day-to-day variation in levels research and integrated assessments of air pollutants. However, to show that a causal (MacGarvin, 1994; Neal, et al., 1998). relationship exists is more difficult. A number of guidelines or tests have been developed to help assess this. These include identifying whether Human Impacts there is a “dose-response relationship” between the proposed causal factor and the effect, whether the sequence of events makes sense Clear scientific evidence for many impacts (i.e. the cause always precedes the effect), of manufactured chemicals on human checking the consistency of results between dif- health (except for some occupational ex- ferent studies, and the way in which the results posures) is also complex and difficult to of different studies fit together (coherence). identify. This is partly because people are exposed to many different substances and Proof of causality is often very difficult but, by the application of these and other criteria, an their breakdown products via indoor and expert judgement as to whether an association outdoor pollution from several pathways, is likely to be causal can often be made. Where including air, water, food and passage effects are likely to be serious and/or irrevers- through the skin. Since the 1970s, there ible, then a low level of proof, as in the “precau- has been increasing concern in particular tionary principle”, may be sufficient to justify about consumer goods, including food, actions to remove or reduce the probable which can be one of the main routes of causes (WHO & EEA, 1997). 12 Chemicals in the European Environment: Low Doses, High Stakes?

Box 4 Some examples of ecological impacts and possible causes The association/causation is assessed on the scale: 1 = no observed association, 2 = suspected association, 3 = weak association, 4 = clear association, 5 = significant association.

Observation/impact Sensitive species Substance Association/ causation Large scale Eggshell thinning guillemot, eagle, osprey, DDT 5 peregrine falcon Reproduction seal, otter PCB 4 Skeleton malformation grey seal DDT, PCB 2 Pathological changes seal PCB, DDT, 3 metabolites Reproduction mink PCB 5 Reproduction osprey DDT, PCB 4-5 Reproduction eagle DDT, PCB 2-3 Reproduction salmon chlorinated 2 substances Large scale - pulp and paper industry Induction of perch chlorinated/ 3 metabolising enzymes unchlorinated organic mixture/ Dioxin compounds Local/regional - pulp and paper industry Induction of metabolising perch chlorinated/ 3-4 enzymes unchlorinated organic mixture/ Dioxin compounds Spine malformations four-horned sculpin chlorinated 3-4 unchlorinated organic mixture Local, forest industry Induction of metabolising perch chlorinated/ 4-5 enzymes unchlorinated organic mixture Dioxin compounds Spine malformations four-horned fish chlorinated/ 4-5 unchlorinated organic mixture Larvae damages sea mussel chlorinated/ 3 Source: unchlorinated Swedish EPA, 1993 organic mixture 5. Ecological and human impacts 13

and trade union groups need to be in- Children may be particularly at risk from volved in risk assessments (NRC, 1996; chemicals because of their greater biologic- Consumers’ Association, 1997). al sensitivity and greater exposure to en- vironmental pollution relative to body Despite the difficulties of identifying and weight (NRC, 1993; McConnell, 1992; assessing potential risks, there is evidence Bearer, 1995). Their physiological and in- about the health effects of manufactured tellectual development may be impaired by chemicals in humans, including cancer, exposure to chemicals (Rodier, 1995; cardiovascular and respiratory diseases, Rylander et al., 1995; Jacobson, 1996; - allergies and hypersensitivity, reproductive Grand Jean et al., 1997). Low-level pesti- disorders, and diseases of the central and cide contamination of food (infants con- peripheral nervous systems. These poten- sume eight times more food per kilogram tial health impacts and some of their pos- of body weight than adults, making this a sible causes are summarised in Box 5. more significant exposure pathway; CICH, 1997) and of residential surfaces and toys Some chemicals clearly cause cancers in in the UK and USA is being reported some exposed groups, but the role of chem- (Pesticides Trust, 1998, Gurunathan et al., icals in overall cancer causation is unclear 1998). Some regulatory authorities are and disputed (Doll, 1992; Epstein, 1998). giving special attention to the higher levels Any excess cancer mortality from a chem- of risk to children from pollution (US EPA, ical is likely to be restricted to a 1996). For example, the Food Quality Pro- section of the population, so mortality tection Act in the USA req u i r es the govern- rates for entire populations can often be ment to add an extra margin of safety to weak and insensitive indicators of environ- the risk assessment of chemicals that chil- mental health effects from pollution. Low dren may be exposed to. levels of exposure to chemicals, including pesticides, may suppress the immune res- Cancer in children in the USA is increas- ponse defences of the body, leaving people ing (Pogoda, 1997; EHP, 1998; Rachel’s mo r e susceptible to diseases from virus e s , EHW, 1998), and a large-scale study of parasites, bacteria and tumours (WRI, childhood leukemias and other cancers in 1996). the UK has found them to be associated with living close to industrial plants, par- Th e po t e n t i a l l y ha z a rd o u s ef fects of pharma - ticularly where fossil fuels were being used ceutical chemicals, such as greater resist- or processed (Knox & Gillman, 1997). ance to animal antibiotics and contami- nation of water supplies (Envirolink, 1998) The causes of an increased incidence of are not covered further in this summary. testes cancer and breast cancer in humans, and of the effects on wildlife rep ro d u c t i o n Chemical pollutants that may affect repro- of en d o c r i n e - d i s r upting chemical substances ductive health and new-born children in- that have been observed in many coun- clude certain metals (e.g. lead and methyl tries, are largely unknown. Changes in the mercury), pesticides (e.g. DDT), industrial environment, as well as in lifestyle, may be chemicals (e.g. PCBs), and other responsible (Colburn, 1993, CEC et al., substances (Foster & Rousseaux, 1995; 1997; EA, 1998 – see Box 6). CJPH, 1998, in press). Exposures can occur through the placenta and breast milk (Jen- It is the widespread presence of small sen, 1996; Rogan, 1996), and some may amounts of many chemicals which is caus- cause small abnormalities of the immune ing increasing concern, because alone, or response system. However, the WHO and in combination with other agents, they others conclude that the benefits of breast- may contribute to cancer, allergies (UCB, feeding outweigh the risks of pollutants in 1997), impacts on reproduction and the breast milk (Weisglas-Kuperus et al., 1996; immune response system, and neurotoxic WHO, 1996). effects (NRC, 1992; Kilburn, 1998). The 14 Chemicals in the European Environment: Low Doses, High Stakes?

Box 5 Some health effects of chemicals

This is a summary of the main health effects of chemicals. The link with chemicals varies from well- known causal relationships such as benzene and leukaemia, to suggestive associations, such as chemical sensitivity and pesticides. Most harmful effects are the result of many causes acting together, such as genetics, lifestyle, radiation, diet, pharmaceuticals, chemicals (manufactured and natural), smoking and , including indoor and outdoor exposures. It is also im- portant to consider sensitive groups, such as the elderly, children, the embryo, the sick, and preg- nant women, who may be affected at much lower doses than others.

Health effect Sensitive group Some associated chemicals* Cancer All asbestos Polycyclic aromatic hydrocarbons (PAHs) benzene some metals some pesticides several hundred animal carcinogens some solvents natural toxins Cardiovascular especially elderly carbon monoxide diseases arsenic lead cadmium cobalt calcium magnesium Respiratory diseases children, especially inhalable particles asthmatics sulphur dioxide nitrogen dioxide ozone hydrocarbons some solvents terpenes Allergies and all, especially children particles hypersensitivities ozone nickel chromium Reproduction adults of reproductive polychlorinated biphenyls (PCBs) age DDT phthalates Developmental foetuses, children lead * Examples only mercury other endocrine disruptors

Source: Nervous system foetuses, children PCBs EEA, based on Swedish EPA disorders methyl mercury (1996); WHO (1995); lead EHP (1997b); Ashford, (1998); manganese Williams (1997) and aluminium Kilburn (1998) organic solvents 5. Ecological and human impacts 15

The “Weybridge Report” on endocrine disruptors Box 6

The EEA has summarised the results of the and mammals, including humans. Report from the European Workshop on the • Compared with the situation in the US, there impact of Endocrine Disrupters on Human are few cases of reproductive ill-health in Health and Wildlife (CEC et al., 1997) as follows: wildlife in the EU where the effects could be definitely associated with endocrine-disrup- There is increasing evidence and concern about ting substances. rising trends of reproductive ill health in wildlife and humans, and some substances have been • However, some cases exist within the EU area implicated, but there are great uncertainties where adverse endocrine effects, or repro- about the causes of reproductive ill health. ductive toxicity, in birds and mammals coin- cide with high levels of anthropogenic sub- Key conclusions are: stances, shown to have endocrine-disrupting • Sufficient evidence exists that testicular properties in some test systems. cancer rates in humans are increasing. • The considerable uncertainties and data gaps • The apparent decline in human sperm counts could be reduced by the recommendations in some countries was likely to be genuine. on research and monitoring into exposure and effects in wildlife and humans. • There is insufficient evidence to definitely establish a causal link between the health • Current eco-toxicological tests, studies and effects seen in humans with exposure to risk assessments are not designed to detect chemicals. endocrine-disrupting activities. • The major route of exposure to Endocrine • Meanwhile, consideration should be given to Disrupting Substances (EDS) is usually by reducing the exposure of humans and wildlife Source: European ingestion of food, and to a lesser extent to endocrine disrupters in line with the Environment Agency based water. It is valid for terrestrial animals, birds “precautionary principle”. on CEC et al., 1997

timing of exposure to some chemicals is part of the human population will be affected. important, particularly for endocrine-dis- We are only able to assess risks in a very general rupting substances, where exposures and simplified manner” (van Leeuwen et al., during the first 30 days after conception 1996). seem to be critical. Although exposure to chemicals may be very low for most people Despite the difficulties of risk assessment, (i.e. in parts per million or trillion of air, there are many government and industry water or food), some chemicals at such low policies in place which have been designed doses can be potent. For example, estra- to protect people and the environment by diol, the body’s key oestrogen hormone, minimising the risks of manufactured operates at concentrations of parts per tril- chemicals. lion-equivalent to one drop of water in 660 “rail tankers” (Brekine, 1997). And some chemicals may be more harmful at lower doses than at higher doses, since, for ex- ample, damaged cells may cause more harm than dead cells, and higher doses can trigger detoxification activity which is not triggered by lower doses (Lodovic et al., 1994).

A recent and comprehensive review of the risk assessment of new and existing chem- icals concluded: “At the present level of under - standing we cannot adequately predict adverse effects on ecosystems, nor can we predict what 16 Chemicals in the European Environment: Low Doses, High Stakes?

6. Some policy initiatives for reducing risk

There are over a dozen the Directive (the SENSE project; VROM, Directives on chemicals control (Fig. 7) 1998). concerning classification and labelling, marketing and use, risk assessment, and All European countries have extensive protection of workers, consumers and the national legislation in the field of chem- environment. Compliance with, and enfor- icals. For example, a review of UK legisla- cement of these Directives is uneven, in tion on the control of chemicals (exclud- part because it can be difficult for industry ing pharmaceuticals and poisons) listed 25 to know how best to achieve compliance relevant Acts of Parliament which were with several sets of regulations. For exam- overseen by seven government depart- ple, in the dyestuffs industry, a highly com- ments and augmented by over 50 sets of petitive business involving many innovative regulations (Haigh, 1995). A similar pat- and potentially hazardous chemicals, a tern of multi-departmental policy response study of the Notification of New Substan- exists in many EU countries, which is ces Directive (the NONS project, VROM prompting efforts to streamline such legis- 1996) in the 15 Member States of the EU lation and to shift the focus of policy meas- found that many new substances being ures from “downstream” impacts of control used had not been reported to the regula- on workplaces, consumers and ecosystems tory authorities, or even identified. Their to “upstream” reduction of exposure po- use was not properly recorded, and in tential and prevention (Gottlieb, 1995; some cases they were inadequately label- St e i n g r a b e r , 1997) (Fig. 6). The Integrated led. About 45% of the 96 companies visit- and Control Direc - ed in most countries of the EU did not tive of the EU obliges large plants to adopt conform to this Directive. However, a such a comprehensive approach to pollu- follow-up project revealed some improve- tion prevention. ments, with just 32% of the 100 companies inspected in this sector not conforming to In addition to EU Directives and regional

Figure 6 A framework for analysing policy responses to chemical impacts

Policy responses have mainly ocused on the “down- st re a m ” impact of chemicals, generally moving from “A” to “B” over time. This has esulted in many chemical laws, enforced by several government departments, with associated difficulties of co-ordination.

Policies at “C” focus on the “upstream” sources of chem- icals, via the integrated pre- vention of exposures that threaten health and the en- vironment, e.g. the Integra- ted Pollution Prevention and Control (IPPC) Directive. The “need” for certain chemicals is also being addressed by several stakeholders.

Source: European Environment Agency 6. Some policy initiatives for reducing risk 17

Elements of Chemicals Control in the European Community Figure 7

Source: CEC, 1994

initiatives, European countries are guided (POPs), including 16 pollutants: aldrin, by a number of regional and international chlordane, chlordecone, DDT, dieldrin, treaties. The Convention on Long-Range dioxins, endrin, furans, heptachlor, hexa- Transboundary Air Pollution (LRTAP), bromobiphenyl, hexachlorobenzene, hexa- adopted in 1979 under the auspices of the chlorocyclohexane (including the Economic Commission for Lindane), mirex, polycyclic aromatic hy- Europe (UNECE), covers Europe and drocarbons, PCBs and toxaphene. The North America. This Convention includes other protocol covers certain heavy metals measures for eliminating or restricting use, (cadmium, lead and mercury). reducing consumption and unintentional emissions or contamination, eliminating The Chemical Industry Sustainable Eco- waste and improving the management of nomic and Ecological Development pro- chemicals. It features two new protocols gramme (CHEMISEED), managed by the signed at the pan-European Ministerial United Nations Economic Commission for meeting at Aarhus in June 1998. One prot o - Europe (UNECE), focuses mainly on har- col covers Persistent Organic Pollutants monising legislation, cleaning contamin- 18 Chemicals in the European Environment: Low Doses, High Stakes?

ated sites, and promoting the eco-efficient Soon after completing PIC, governments use of chemicals in Central and Eastern began negotiations (June 1998) on a Europe. The UNECE Working Group on global convention dealing with persistent Abatement Technology is helping coun- organic pollutants (POPs). Its purpose will tries to comply with the 1991 Volatile Or- be to reduce and/or eliminate the release ganic Compounds (VOC) Protocol, under into the environment of those POPs which the LRTAP Convention, which came into pose significant threats to human health force in 1997. and wildlife. Although the convention negotiations are to focus initially on a list The voluntary Prior Informed Consent of 12 POPs, they will include the develop- (PIC) procedure has been developed by ment of criteria and a process for identi- UNEP and the Food and Agriculture Or- fying additional POPs for international ganization (FAO) of the United Nations. action. These negotiations under the In March 1998, governments completed auspices of UNEP are to be completed by negotiations to transform PIC into a legal- the year 2000. ly binding convention for strengthening the management of certain hazardous Co-ordination of international work on chemicals in international trade. Under chemicals has been facilitated by the IFCS PIC, governments will be required to stop which was established in 1994 as called for the export of listed chemicals to other in Chapter 19 of Agenda 21 of the 1992 countries that have indicated that they do UN Conference on Environment and not want them imported, provided the Development. The IFCS provides policy importer does not manufacture or import guidance and strategies for implementa- the substance from another source for tion of the major programme areas con- domestic use. Thus, chemicals can be pre- tained in this chapter, including hamoni- vented from entering countries where the sation of risk assessments and chemical risks they pose are deemed unacceptable classification, information exchange, risk by the recipient country. reduction and chemicals management capacity building. 7. A new paradigm for chemicals management? 19

7. A new paradigm for chemicals management?

There are many possible approaches to im- ated into many environmental treaties, this proving the safe management of chemicals principle featured in the 1992 Rio Declar- at both the national and regional levels. ation on Environment and Development Chemical risks are frequently reduced or (as Principle 15): managed through bans, use restrictions, classification and labelling schemes, con- “In order to protect the environment, the pre - taminated-land policies, environmental cautionary approach shall be widely applied liability legislation, civil actions, and other by States according to their capabilities. Where strategies. Increasingly, European policy- there are threats of serious or irreversible makers are moving towards an approach damage, lack of full scientific certainty shall that relies more on co-operation and in- not be used as a reason for postponing cost- centives rather than on “command-and- effective measures to prevent environmental control” regulations. This is based on new degradation.” perceptions about what is important in chemical pollution (Box 7). This “new The precautionary principle permits a paradigm” for chemicals management in- lower level of proof of harm to be used in cludes the following approaches: policy making whenever the consequences of waiting for higher levels of proof may • The precautionary principle. The data be very costly and/or irreversible. The UN deficiencies described in this report and Intergovernmental Panel on Climate the increasing awareness of scientific com- Change recently used the precautionary plexity and uncertainty have led public principle in concluding that “the balance authorities to emphasise the “precaution- of evidence… suggests a discernible human in- ary principle” as a prudent response to fluence on global climate” (IPCC, 1995). potential chemical hazards. Now incorpor- When applied to chemicals, the prec a u t i on -

Perceptions of what is important in chemical pollution: 1970s and 1990s Box 7 1970s 1990s – same as 1970s plus: occupational health consumer health, health of ecosystems local/regional focus national/international focus limited, unquantified economic damage large, quantifiable economic damage exposures from air and surface water total exposures via air, surface and groundwater, soil, sediments, food and consumer products “point” sources of pollution e.g. chimneys “diffuse” sources, e.g. agriculture, food, consumer products single -substance approach multi-pollutant/mixtures single-effects e.g. leukaemia multi-effects e.g. reproductive impacts “end-of-pipe” approach to pollution control “clean” production and integrated pollution control; “life-cycle” assessment of impacts production processes products and use labelling and use instructions public information on chemical releases and transfers “sell-and-forget” chemical “products” product stewardship; chemical “services” (e.g. solvents) (e.g. degreasing services) specific regulations “framework” regulations, taxes, voluntary agreements, “responsible care”, etc. Source: EEA expansion of toxicity-focused risk assessment of exposure reduction based on “precautionary Table 3, p. 248 in van single substances principle” and persistence/bioaccumulation Leeuwen et al., 1996 20 Chemicals in the European Environment: Low Doses, High Stakes?

ary principle can mean reducing the po- problems have helped to stimulate measu- tential for exposure to substances that per- res that increasingly focus on exposure sist and bio-accumulate in the environ m e n t reduction rather than on more toxicity without waiting for certain evidence of testing. An example of this approach in- toxicity. It also involves putting the burden cludes the OECD pesticide risk reduction of proving that a substance is “harmless” programme (OECD, 1998b) and the Swe- onto producers and importers (KEMI, dish pesticides reduction programme 1998). Instead of assuming chemicals are (Ekström and Bernson, 1995). “innocent until proven guilty” of damage via strong evidence of toxicity and actual These approaches, based on weighing the harm, the new approach assumes hazard- costs and benefits of precautionary action ous potential from the chemical’s ability to to reduce exposure against the time, cost persist and bio-accumulate in animals or and uncertainty involved in single sub- the environment. stance toxicity testing and risk assessments, have also been used by international agree - It is argued that this is a more equitable ments that address common sea or river and cost-effective approach (Scheringer, basins. Their main objective has been to 1997). reduce overall chemical loads (or “dose”), starting with priority substances for which • E x p o s u re re d u c t i o n . The impact of there is already sufficient toxicity data to chemicals can be reduced by action at dif- cause concern. For example, a 1990 Minis- ferent points in their environmental life- ters’ Declaration committed European cycles, from pre-market screening to clean- governments to reducing the inputs from ing up contaminated soils. However, action rivers and estuaries to the North Sea of a can be delayed by the lack of knowledge group of 36 toxic chemicals to less than about toxicities, persistence and other 50% of their 1985 levels by 1995; total in- basic properties, as well as the slow pro- puts of dioxins, mercury and cadmium gress in conducting risk assessments, which had to be reduced by 70%. More recently, normally have to be completed before risk- the 1995 Fourth Ministerial Conference in reduction measures are agreed. These Esbjerg, Denmark, on the Protection of the North Sea, committed signatory states to ending all discharges, emissions and Box 8 4th North Sea Conference of Ministers – losses of hazardous substances within 25 Esbjerg, 1995 years (Box 8). Some of the main national The prevention of pollution by hazardous and international chemical reduction ini- substances tiatives are shown in Box 9.

“The Ministers Agree that the objective is to In addition, many “clean production” ini- ensure a sustainable, sound and healthy North Sea ecosystem. The guiding principle for achie- tiatives have led to reductions in chemical ving this objective is the precautionary principle. exposures in Europe both within work- places and the general environment (MSF, This implies the prevention of the pollution of 1994; UNEP, 1994; JOCP, 1997). Some the North Sea by continuously reducing dischar- business organisations, such as the World ges, emissions and losses of hazardous substan- Business Council for Sustainable Develop- ces thereby moving towards the target of their ment (WBCSD) encourage clean produc- cessation within one generation (25 years) with the ultimate aim of concentrations in the envi- tion through the idea of “eco-efficiency” ronment near background values for naturally which includes the proposal to “minimise occurring substances and close to zero concen- toxic dispersion” (WBCSD, 1996). In the trations for man-made synthetic substances. USA, the Massachusetts Toxic Use Reduc- tion Act, 1989, has resulted in firms using The Ministers agree that in this work scientific 20% fewer toxic chemicals and generating assessment of risks is a tool in setting priorities 30% less (Becker and Geiser, and developing action programmes.” 1997). 7. A new paradigm for chemicals management? 21

Some current initiatives on reduction of exposure to chemicals Box 9

Instrument/Proposal/Location Year Objectives 1 Esbjerg Declaration on the North Sea 1995 Eliminates release of persistent, bio- accumulating and toxic substances to the North Sea over 25 years 2 Basle Convention on 1989 Objectives are to control trans-bound- ary movements, to manage and mini mise Hazardous Wastes 3 UNECE POP protocol 1998 Reduce exposure to POPs 4 UNECE Heavy metal protocol 1998 Reduce exposure to heavy metals 5 HELCOM Convention 1998 Implementation of the Visby targets 6 OSPAR Convention 1998 Implementation of the Esbjerg target 7 UNEP POPs Convention 1998-2000 Reducing/eliminating releases of POPs to the environment 8 UNEP-FAO PIC Convention 1996-1998 Limits imports and exports of hazardous chemicals and pesticides 9 OECD Chemicals & Pesticide 1994 Share information/criteria on risk Risk Reduction reduction programmes 10 Intergovernmental Forum on 1994 To implement Chapter 19 of Rio Chemical Safety Declaration, including risk reduction programmes 11 1987-2040 To phase out certain ozone depleting substances 12 EU Fifth Environment Action Programme 1991-1994 To achieve “significant reduction of pesticide use per unit of Land” 13 EU Sustainable Use of Plant Protection 1994-1998 Analyse use, impacts and reduction Products potential for agricultural pesticides 14 Danish Minister Report on Future 1997 25 substances/groups of substances Initiatives on Chemicals dentified for priority phase-out, selected from 100 “undesirable” substances 15 Swedish Government Report on 1997-2007 10-year phase out of all products Chemicals Policy containing persistent & bio-accumu- lating substances; giving rise to ser- ious/irreversible effects; or containing lead, mercury, cadmium 16 Norwegian targets for prioritised 1996-2010 Discharges of hazardous chemicals to chemicals be substantially reduced by 2010 (e.g. lead, cadmium, mercury, dioxins, PAHs; or phased out by 2005 Source: European (e.g. halons, PCBs, PCPs) Environment Agency

• From Products to Services. As users of rather than just or pesticide pro- chemicals do not want the chemical “pro- ducts. This is similar to the change in ducts” as such, but just the “services” that focus from products to services in other their chemical prop e r ties bring, some chem- sectors such as energy and water where ical suppliers of solvents or pesticides, for companies are now selling energy or water example, are beginning to sell “degreasing services, including demand-side manage- services” or “pest management services” ment measures, rather than just supplies 22 Chemicals in the European Environment: Low Doses, High Stakes?

of energy or water. This shift in focus from the costs and benefits of chemicals, some pr oducts to services can transform the rel a - of which are illustrated in Box 10. Evaluat- tionship between chemicals, profits and ing these is difficult, especially if monetary the environment because the chemical it- values are needed (DoE, 1995). However, self shifts from being the source of profit recent reports from the US, Japan and to being a cost item for the chemical sup- OECD illustrate how such cost/benefit plier. The chemical becomes part of a and cost effectiveness evaluations can help wider package of added-value services, in- improve policy decisions (Morgenstern, cluding greater responsibility on the sup- 1998; JPRHDPC, 1997; OECD, 1998c). plier for the chemical’s safe use and rela- Most firms involved in toxic use reduction ted equipment. This increases the incen- in Massachusetts, for example, achieved tive on the supplier to reduce both the cost savings from reduced chemicals use quantity and hazards of the chemical, per (Becker and Geiser, 1997). The US and unit of service delivered, and to increase Japanese studies show net social benefits its durability by, for example, recycling. from the environmental regulation of pol- This can provide a “triple dividend”: one luting substances, such as stratospheric for the customer, one for the supplier and ozone and lead in petrol. one for the environment. Considerable innovation is needed to expand this shift Measures that address the contamination from products to services beyond the solv- of just one medium – be it water, land, or ents and pesticides parts of the chemical air – risk merely transferring the problem industry (Stahel, 1998). to another medium. An integrated, multi- ple pollutant/multi-effect approach is • Cost-effectiveness and Multiple Benefit/ therefore needed, which assesses both the Costs Approach. Deciding upon appropri- main and secondary benefits as well as the ate policy responses requires weighing up costs of chemicals control.

Box 10 Some illustrative benefits and costs of manufactured chemicals BENEFITS COSTS - fewer pests - fires/explosions - less infections from bacteria - acute/chronic poisoning - better protection/storage of food - genetic and other health damage - lighter/more durable attractive/ cheaper consumer products - groundwater contamination - profits and jobs - species/eco-system damage - scientific progress - other pollution damage e.g. ozone layer CHARACTERISTICS OF THE BENEFITS AND COSTS - well known - not well known - taken for granted - feared - obvious - not so obvious - short-term - often long-term - rarely irreversible - often irreversible - evenly distributed - unevenly distributed Source: European Environment Agency - easy to monetise - not easy to monetise 7. A new paradigm for chemicals management? 23

•Voluntary programmes. Chemical risks Even outside formal voluntary program- are already being reduced through a num- mes, business can anticipate the need to ber of voluntary industry initiatives. For reduce risks from conventional chemicals. example, companies in The Netherlands For example, the increased awareness of have initiated voluntary reduction pro- the hazards of fossil fuel combustion and grammes via agreements with the regula- associated chemical feedstocks is encour- tory authorities. In 1989, they introduced a aging some businesses to develop other Control Strategy for reducing emissions of raw materials based on the “soft” chemistry volatile organic compounds (VOCs) from of agricultural products (von Gleich, 1991), industry, small businesses and households. an industry which was developing in the The Strategy envisages a reduction of 63% USA in the 1930s before the oil industry in emissions by 2000 compared to 1981 grew to become the dominant source of levels, via reduction plans containing over chemicals (Hale, 1934). However, not all 100 separate measures. Within the frame- “soft” chemistry feedstock and products, work of the OECD’s Risk Management such as those described in Box 11, will Programme, companies producing certain necessarily be less harmful than those brominated flame retardants have volun- tarily agreed to stop their production. An EEA review of voluntary agreements (EEA, Some “soft chemistry” initiatives Box 11 1997) concluded that the Dutch chemical • Mitsui Toatsu of Japan has announced plans industry scheme has been environmentally to produce biodegradable in 30,000- effective and has encouraged the develop- ton facilities in Japan, Europe and the US by 2001, using a corn and potato starch base. ment of environmental management sys- tems. • The US Department of Energy, under its Alternative Feedstocks Programme, has The EEA review concluded more generally signed a US$7M contract with Applied Carbo-Chemicals to manufacture chemical that most other agreements studied could feedstock from renewable farm crops such not be evaluated because there was no as corn, which promises to be cheaper and monitoring data or consistent reporting. better than petroleum-based feedstock. The Voluntary agreements seemed to be of feedstock will be targeted on the polymers, most use as complements to other policy coatings, inks and dyes markets, which are measures such as regulations and taxes. growing at 10% per year in the US. The com- pany ACC says that the new feedstock is 20- 50% cheaper than conventional oil-based Meanwhile, a “Responsible Care” program- supplies. me, promoted by the European Chemical Industry Council (CEFIC, 1996), has been • Donlar CO has won a Chal- lenge Award from the US EPA for a process adopted in 21 European countries. This that substitutes biodegradable polyasparate programme encourages the cross-fertilisa- for polyacrylic acid, a key compound in dis- tion of ideas and best practices. The pro- posable nappies, which can account for 2% of gramme, based on the original Canadian solid waste in US . initiative, is designed to improve the chem- • Monsanto’s “Biopol” group manufactures the ical industry’s health, safety, environmen- PHA polymer from fermented micro-organ- tal and quality performance, as well as isms and is developing a plant-based route communications with the public concern- to PHA, based on soya or canola. ing products and plant operations. How- • The Fraunhofer institute for Holzforschung ever, participation by employees and in Germany is developing industrial fibres unions in the responsible care program- from flax, while the German Institute for Food mes seems to be limited (ICEM, 1997), Packaging has developed a fibre reinforced even though some research shows union based on casein protein. representatives to be more knowledgeable • The use of hemp seed oil to produce paints about chemicals regulations than their em- and varnishes (which was the main feedstock ployers (HSE, 1997). in the US prior to 1937), and hemp fibre for Source: European bags, shirts and paper, is increasing. Environment Agency 24 Chemicals in the European Environment: Low Doses, High Stakes?

based on oil. A full life-cycle assessment is agreed in 1998, and this will further en- needed for the evaluation of alternatives courage the provision of chemical infor- (EEA, 1998c). mation to the public.

• Improved public and consumer The OECD has published guidance on the information. Information is playing an in- Pollutant Release and Transfer Registers creasingly important role in controlling (PRTR) (OECD, 1996) which will help to chemical pollution, both in support of spe- establish emissions inventory and public cific regulations and taxes, and as a stand- right-to-know programmes. Experience alone policy tool. For example, the EU’s with the US Toxics Release Inventory in “Seveso” Directive on Hazardous Installa- the USA shows that it can stimulate reduc- tions obliges employers to provide infor- tions in toxic chemical emissions both mation to the nearby public. The EU Clas- directly and via stimulus to voluntary sification and Labelling Directive promotes actions, such as the successful “33/50” the provision of clearer product informa- chemicals-reduction programme of the US tion. The proposed European Polluting EPA, which has led to a more than 50% Emissions Register, to which the public reduction in emissions of 33 hazardous shall have access under the Integrated Pol- chemicals (OECD, 1997a). The OECD lution Prevention and Control Directive, guidelines on PRTR are being promoted by 2002, will provide chemical release data under the IFCS programme, with support from production facilities on a three-yearly from UNITAR and UNEP. basis. Some European countries (Denmark, France, the Netherlands, Sweden, and the Another type of information tool is the UK) already have some provision for pub- Chemical Product Register in Denmark, lic access to chemicals data. A UNECE Finland, France, Norway and Sweden, Convention on public participation and which can be particularly useful in track- access to environmental information was ing chemicals contained in consumer pro- ducts (KEMI, 1994).

Finally, general information for the public, Box 12 Some environmental “externalities” particularly chemical employees and con- of chemicals sumers, is extensively produced through- • costs of cancers, reproductive and other out the EU and elsewhere, such as by the chronic health impacts; International Programme on Chemical • costs of acute health effects; Safety (IPCS, 1996; UNEP, 1997). For ex- • public costs of fire & explosions; ample, IPCS, in co-operation with the EU, has produced over 1,300 Chemical Safety • costs of pollution to air, crops, inland water, Data Cards and over 200 Pesticide Data soil, sediments and seas; Sheets to help reduce the risks of handling • costs of damage to non-human species; chemicals at work. • costs of damage to the stratospheric ozone layer; The EEA has produced a guide on Envi- • costs of registration, testing, assessing and ronmental Risk Assessment, Approaches, classification not borne by companies; Experiences and Information Sources • costs of permits, inspections & enforcements (EEA, 1998b). not borne by companies; There is as yet little data on the effective- • cost of monitoring/sampling not borne by companies; ness of information provision in Europe on changing consumer behaviour towards • cost of contamination clean up not borne by chemicals, but some evidence on benzene companies; in petrol (Fouquet, 1997) suggests that it Source: European • losses of land value; fear; nuisance, smells in can be effective, particularly via the mass Environment Agency the vicinity of plants. media. 7. A new paradigm for chemicals management? 25

• Use of economic instruments. In 1993, chemicals via environmental taxes. Cur- the EU’s Fifth Environmental Action Pro- rent candidates for eco-taxes on particular gramme recommended an increased use chemicals at the Member State or EU le- of economic instruments to help imple- vel, based on the likely size of their “ex- ment the “polluter pays” principle and the ternalities”, include heavy metals, chlorin- incorporation of environmental “external” ated products, POPs, fertilisers and pesti- costs, such as , into market cides (DETR, 1997; RSPB, 1998). prices, via taxes. Environmental taxes can be very effective “Externalities”, which are the environmen- if they are well-designed and form part of tal and social costs of economic activity a package of measures, including the use that are not borne by producers and users, of tax revenues to stimulate actions to and therefore not included in the market reduce the use of a substance (EEA, 1996). price of their products, can be substantial Various European states already impose (EEA, 1996). For example, the “external- taxes on pesticides, fertilisers, ozone-deple- ities” of the transport sector have been ting substances, sulphur dioxide, nitrogen estimated at around 4% of EU GNP (Mad- oxides, chlorinated solvents (e.g. on tetra- dison, 1996) and attempts are now being chloroethylene, and made to “internalise” these into prices dichloromethane in Denmark) and toxic (ECMT, 1998). The main categories of the wastes, as well as on leaded petrol and “external” costs of chemicals which, apart high-sulphur diesel fuel in several Euro- from pesticides (Pearce, 1997), have yet to pean countries. The use of taxes to “in- be evaluated, are summarised in Box 12. ternalise” the social costs of chemicals into Although monetary evaluation of some ex- market prices, combined with other risk ternalities is controversial, it can help to management measures, will encourage the provide a basis for the incorporation of more “eco-efficient” use of chemicals these social costs into the market price of (WBCSD, 1996; OECD, 1997b). 26 Chemicals in the European Environment: Low Doses, High Stakes?

8. Conclusions

This short survey of the state of informa- tion and action on manufactured chem- icals in Europe reveals that we may face serious, if hard-to-identify risks, but also that measures to reduce these risks are available.

Much progress has been made since the publication of Silent Spring, Rachel Carson’s warning about the rising costs of chemical pollution in 1962 (Carson, 1962; Lear, 1998). However, the possible effects on humans and ecology of the many combina- tions of chemicals available for exposure is encouraging the search for much greater “eco-efficiency” in their production and use.

The current European Commission review of chemicals will help to clarify and addres s “the weaknesses” (DETR, 1998a, 1998b) in pre s e n t policies for managing chemicals in the EU. The aim must be to strike the right balance between different approaches to the risks of chemicals, and to the costs and benefits of their use, based on the judi- cious application of the “precautionar y principle”.

There is great scope for improvement. For example, our best chemical plants are still ve r y inefficient in their use of energy and in their production of wastes (MSF, 1994) compared with the quiet chemical elegan- ce involved in any natural plant such as the clover, symbol of the UK Cleaner Pro- duction Programme. Those companies and countries which first succeed in emul- ating nature’s elegance will provide a great service to the environment and human society (Fussler, 1996). Acronyms 27

Acronyms

CEC Commission of the European Chemical, Energy, Mining and Communities General Workers Unions, Geneva CEFIC European Chemical Industry IFCS International Forum on Chemical Council, Brussels Safety CFC ILO International Labour Organisation CHEMISEED Chemical Industry-Sustain- IPCS International Programme on able Economic and Ecological Chemical Safety Development programme IPCC Intergovernmental Panel on CICAD Concise International Chemical , UN Assessment Documents IUCLID International Uniform Chemical CICH Canadian Institute of Child Information Database. European Health, Ottawa Chemicals Bureau of the EC’s Joint CMA Chemical Manufacturers Research Centre. Association, USA JOCP Journal of DDT dichlorodiphenyl trichloroethane (Elsevier), Amsterdam DETR Department of the Environment, KEMI The Swedish National Chemicals Transport and Regions, Inspectorate, Stockholm DoE Department of the Environment, LRTAP Long-Range Transboundary Air London Pollution EA Environment Agency, England MSF Manufacturing Science Finance and Wales Union, London EDF Environmental Defense Fund, NAS National Academy of Sciences, USA Washington NONS Notification of New Substances Directive – Enforcement Project EEA European Environment Agency, Copenhagen NRC National Research Council, Washington EC European Commission NRDC National Resources Defense ECB European Chemicals Bureau Council, Washington ECMT European Conference of Ministers OECD Organisation for Economic of Transport Co-operation and Development ECU European currency unit PAHs polycyclic aromatic hydrocarbons EDS endocrine-disrupting substances PCBs polychlorinated biphenyls EHP Environmental Health Perspec- PIC prior informed consent tives, N. Carolina, USA PRTR Pollutant Release and Transfer EINECS European Inventory of Existing Registers Commercial Chemical Substances POPs persistent organic pollutants ELINCS European List of Notified RSPB Royal Society for the Protection of Chemical Substances Birds, UK (lists “new” substances) SENSE Solid Enforcement of Substances EPA Environmental Protection Agency, in Europe Washington UCB Institute of Allergy, Brussels EU European Union UN United Nations EU15 All 15 Member States of the EU UNECE United Nations Economic FAO Food and Agricultural Organiza- Commission for Europe tion (UN) UNEP United Nations Environment GDP gross domestic product Programme HP V C s high production volume chemicals VOCs volatile organic compounds HSE Health and Safety Executive, WBCSD World Business Council for London Sustainable Development ICEM International Federation of WRI World Resources Institute, Washington 28 Chemicals in the European Environment: Low Doses, High Stakes?

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VROM, 1996. European Inspection Project On The Notification Of New Substances, Final Report of the NONS Project, Ministry of Housing, Spatial Plan- ning and Environment (VROM), the Netherlands. Contents Acknowledgements

Preface ...... 2 The rep o r t was written and edited by David David Stanners (Programme Manager, Gee (EEA), with substantial contributions European Environment Agency). Summary ...... 3 from David Stanners, Domingo Jiménez- 1. Introduction ...... 4 Beltrán (EEA), from Prof. Philippe Bour- Layout and graphics: HØILAND DESIGN, 2. Chemicals without borders ...... 5 deau and Prof. B. Jansson of the EEA Copenhagen, Denmark. Scientific Committee, and from David 3. Many chemicals, but limited toxicity data ...... 7 Ogden and Jim Willis of UNEP. Printed on official environmentally ap- 4. Risk assessment ...... 8 proved paper with vegetable-based print- Comments were also gratefully received ing inks. 5. Ecological and human impacts ...... 11 from very many individuals, but final 6. Some policy initiatives for reducing risk ...... 16 responsibility for the report rests with The publication is approved under the EEA and UNEP. Nordic environmental seal, Svanen. 7. A new paradigm for chemicals management? ...... 19 Licence no 241 006. 8. Conclusions ...... 26 The project was co-ordinated by Mr Ronald G. Witt (Regional Co-ordinator Environmentally certified and Acronyms ...... 27 UNEP/ DEIA/GRID – Geneva) and Dr EMAS-approved. References ...... 28

The EEA and UNEP have published this state of the Legal Notice environment message on “Chemicals in the European Neither the European Environment Agency nor the expression of any opinion whatsoever on the Environment” in order to UN E P , nor any person or company acting on their part of UNEP or the European Environment raise awareness of the issues, behalf, is responsible for the use which may be Agency concerning the legal status of any and to help build the public and political support needed made of the information in this publication. country, territor y, city or area, or of its author- for all to enjoy the benefits The designations employed and the presenta- ities, or concerning the delimitation of its fron- of chemicals, but at a re- tion of material in this publication do not imply tiers or boundaries. duced cost both to nature and human society.