My Feedback to the EU Chemicals Strategy for Sustainability

The European Commission is conducting a consultation on its Chemicals -Strategy for Sustainability Roadmap. When I saw the subtitle: “toxic-free EU environment”, I thought maybe I should contribute to the discussion. The EU seems to be embarking on another hazard-based approach to handcuff EU research and innovation under the guise of the EU Green Deal. I tried, I mean, I really tried to be civil in my contribution (and I almost made it). Here is my (4000 character) contribution.

This consultation comes at an important moment in history.

  • Human health systems have been decimated by the COVID-19 coronavirus pandemic. Without strong (toxic) disinfecting chemicals, innovative (plastic) PPE and chemicals used by the pharmaceutical and medical communities, millions more would have lost their lives.
  • As locusts are ravaging crops in Africa and Southern Asia leading to a likely famine affecting millions, humanity is in desperate need of agricultural chemical technologies to produce higher yields.
  • As Western democracies are entering a severe economic depression, now is not the time for European regulators to be handcuffing science, industry and technology.

We should be reminded how the innovative products and substances chemistry has brought humanity have protected the vulnerable. This is the moment for rational thinking and practical policy.

Here is my feedback (acting as a private European citizen).

Find the proper place for the precautionary principle

There has never been a dialogue in the EU on how the precautionary principle should be used. While the EC has a Communication, in practice, European chemicals policy followed the EEA’s Late Lessons definition of precaution (reversal of the burden of proof). This imposes the precautionary principle as a preliminary condition replacing any risk management process.
The EEA version states that unless a substance, product or process can be proven (with certainty) to be safe, precaution must be taken. Certainty and safety are emotional concepts that demand zero risk (something most scientists consider impossible).
Precaution has a place in EU chemical policy, but as the last step in the risk management process, not in place of it. If exposure to a chemical cannot be reduced (to as low as reasonably achievable), only then should precaution be applied.

Take a risk-based policy approach

A risk-based policy approach considers whether our exposure to hazards is harmful (eg, exposure to low doses of chlorine are not harmful). The hazard-based approach merely considers whether the hazard is harmful. If for example you cannot prove with certainty that chlorine is not an EDC, then it must be banned (despite the benefits it provides for drinking water).
The Sustainable Use of Pesticides Directive is hazard-based and is widely agreed by actors in the European Commission and industry to be unworkable. The Roadmap for a European Chemicals Strategy for Sustainability seems to be using similar hazard-based terminology.

Adopt a scientific language on chemicals

Too often regulators use language on chemicals that seem to be scripted by the activist community. Regrettably this European Chemicals Strategy for Sustainability call for feedback uses such non-scientific terminology. Some examples:

“Toxic-free EU environment”
Everything is made of chemicals and all chemicals are toxic (it’s the dose that makes the poison). Water at a certain dose is toxic. That the European Commission would put a call for a “toxic-free EU environment” in the title of their call is embarrassing.

“Hazardous chemical”
All chemicals are hazardous but it is our exposure to them that determines the risk. Hazards are insignificant if we’re not exposed to them.

What the EU should be seeking is a chemical risk management strategy.

“Safe alternative”
Safety is an emotional concept meaning different things to different people. As every substance is toxic, in reality nothing is “safe” (at certain exposure levels). This is a misconception of the precautionary mindset. Scientists, by their nature, are continually seeking safer alternatives and exposure reductions.

What the EU should be seeking is a “safer” chemical risk management strategy.

The European Commission has to stop pandering to small anti-industry activist groups paid to undermine public trust in the safety of chemicals and start using responsible, scientific language.

Thank you
David Zaruk
Zaventem, Belgium

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