STUDY ON LONG-TERM EFFECTS OF
CHEMICALS ON THE ENVIRONMENT
Summary of comments on the scoping of the Study
There have been over forty responses to the announcement, together with a small number of comments made on the Commission's website discussion forum. For the most part, the responses support the inclusion of the 18 issues raised in the announcement letter.
This paper draws out some of the key points. In particular, it discusses the types of substance and exposure to be included, and the degree to which animal testing issues should be addressed. The other points raised below will probably need to be addressed during the Commission's Study, but do not immediately raise major scoping issues.
Types of chemicals to be included:
1. Industrial chemicals (organic and inorganic)
2. Pesticides, biocides, and veterinary medicines
3. Chemicals used in the marine environment
4. Degradation products
5. Combustion products
6. Natural toxins
7. Nutrients.
The first two categories are at the core of the Study. Indeed, part of the purpose of the Study is to review the rationale for considering different types of chemicals in different regulatory regimes. The third category would include the consideration of chemicals used in offshore oil extraction, marine anti-foulants, and fish farming: these types of chemical have been mentioned in some of the responses (English Nature and the Marine Conservation Society amongst others).
Pollutants found in the environment as a result of degradation of the first three categories of chemical are often the route by which toxic effects are manifested.
Combustion products include sulphur and nitrogen oxides, as well as more complex chemicals such as dioxins. Their inclusion is mentioned in several responses, such as those from English Nature, the Royal Society of Edinburgh, Scottish Natural Heritage, and the Council for British Archaeology. Including more complex combustion products, such as dioxins, would dramatically increase the scope. That would apply with even greater force to the classical air pollutants, the major sources of which are associated with very different sectors of the economy to the rest of the chemicals in the Study, such as power generation and road transport. There is also a very large and distinct scientific literature on air pollution, probably rather more extensive than that for all other chemicals combined. It is likely that their inclusion would double the complexity of the Study, without providing much in the way of insight into other chemical issues.
The Study's main focus will be the way society uses and controls chemicals, but dioxins and other combustion products are created indirectly by poorly controlled processes, rather than used. The Study might wish to refer to variation in the impacts caused by the use of different chemicals (or alternative non-chemical techniques) in terms of the creation of combustion products, but in no more detail than it would compare the implications for transport or energy use as a result of different options.
Natural toxins, on the other hand, are intimately linked to the use of chemicals, particularly in food production. Several respondents (for example the Chemical Industries Association, Conseil Europeen de L'Industrie Chimique (CEFIC), the Food Standards Agency and the Natural Environment Research Council) have suggested that the Commission investigates the perception that synthetic chemicals are worse than their natural counterparts per se. The method of the assessment of the relative risks posed by natural toxins and synthetic chemicals would be essentially identical.
Nutrients have much in common with classical air pollutants. Indeed some major sources of nutrients are air pollutants such as nitrogen oxides from combustion, and ammonia from animal husbandry. However, there are also major contributions from fertilisers and detergents. The adverse effect of such pollutants is indirect - a result of over-stimulating the growth of lower organisms, leading to changes in the composition of the ecosystem.
Types of exposure to be included:
1. Exposure via the environment
2. Exposure via food
3. Consumer exposure
4. Occupational exposure.
There is no doubt that exposure of the natural environment and the exposure of humans via the environment and food are part of the Commission's Study. It is worth noting that several responses highlight that point source releases have been surpassed by diffuse releases as a cause for concern.
Several responses (for example Friends of the Earth, the Economic and Social Research Council, Greenpeace, and the Transport and General Workers Union) also make the point that consumer exposure (that is, public exposure as a result of the presence of chemicals in products they themselves use) in particular should be included. The rationale given for this varies. It is argued that direct consumer exposure is not well controlled in the UK, that it often swamps exposure via the environment, and that it may give a better understanding of the possible risks arising from other exposures.
A similar argument is put forward for occupational exposure (Transport and General Workers Union) although the argument for including this is perhaps weaker, given that many sensitive groups (such as children) are, by definition, excluded from assessment of effects resulting from occupational exposure, and that the area definitely lies outside the Commission's normal remit.
Recycling, sinks and remediation
A number of responses draw attention to sources of exposure to chemicals that, while definitely falling within the scope of the Study, have not previously been made explicit. A contributor to the discussion forum (David Hicks) makes the point that recycled construction materials are likely to be contaminated with a wide range of substances. The Royal Society of Edinburgh and Scottish Natural Heritage draw attention to the risk of endocrine disrupting chemicals adsorbed on sewage sludge being reintroduced into the environment as a result of land spreading. They go on to draw attention to potential for bioremediation (using bacteria, as opposed to the more accepted techniques of chemical clean up or removal and replacement) to clean up contaminated sites. The Council for British Archaeology points out the effects that conventional remediation techniques can have on archaeological sites.
The Natural Environment Research Council and the Scottish Environment Protection Agency warn of the need to consider the stability of pollutant sinks, and their potential to release chemicals into biologically accessible media at some point in the future.
Chemical and biological monitoring
Many respondents pick up on the reference to chemical and biological monitoring in the announcement. Friends of the Earth makes the point that monitoring should be focused less on chemicals that are already heavily regulated, and instead should take a broader, more proactive view looking for new problems. In particular, there needs to be a new focus on chemicals found in biological systems. Green Alliance emphasises that monitoring needs to be carried out by independent researchers. The Royal Society of Chemistry notes that the need is not so much for more sophisticated chemical monitoring, but the development of cheaper, more reliable methods.
Numerous comments are made about the value of research into developing effective biomarkers to act as sentinels for hazardous levels of chemical contamination in the environment (Department of the Environment, Transport and the Regions, Friends of the Earth, Ministry of Agriculture Fisheries and Food, and the Royal Society of Chemistry). The Natural Environment Research Council makes the point that basic research into understanding how ecosystems function and react to pollutants is also likely to give advance warning of threats that would not be picked up in laboratory based assessments.
Epidemiology
There are a variety of views expressed on the potential for epidemiology to answer questions on the risks associated with exposure to chemicals. The Food Standards Agency and the Worldwide Fund for Nature question whether epidemiology can pick out specific causes for subtle effects, given the number of confounding factors. On the other hand, the Department of Health sees potential for epidemiology, particularly when linked with improved environmental monitoring. The Royal College of General Practitioners thinks that general practitioners could be used much more in epidemiology studies. The Royal Academy of Engineering suggests that epidemiological experience on well studied substances should lead to the general use of lower assessment factors for extrapolating predicted no effect levels from laboratory based toxicity tests. A contributor to the website discussion forum (Alan Tomney, Parkinson's Disease Society) wonders whether the Study will address the risks from pesticide drift and queries whether there is a framework in place to allow the incorporation of poisoning incidents into the assessment process.
It is worth noting that the Commission's 21st Report Setting Environmental Standards (section 2.28) considered the value of epidemiology and noted that it was difficult for such studies to isolate exposure to one substance and went on to provide guidance for assessing such studies.
Effects
One of the most common themes in the responses is concern over the potential for effects arising from exposure to combinations of chemicals. A related theme is the possibility that environmental exposures to a range of chemicals might induce long-term effects in immune, reproductive and developmental systems in humans (the Food Standards Agency, Friends of the Earth, Ministry of Agriculture Fisheries and Food, and the Worldwide Fund for Nature). Friends of the Earth and the Worldwide Fund for Nature also draw attention to the potential for biomedical research to develop techniques to screen individuals for sensitivity to specific chemicals in the near future. The Ministry of Agriculture Fisheries and Food expressed concern at the possibility of long-term effects resulting from transient exposure, particularly in the light of the trend towards development of chemicals with specific biological activities.
Both the Royal Society of Chemistry and the Scottish Environment Protection Agency make the point that effects on ecosystem function are more important than those on single species. The implication is that effects on bacteria may be more important than those on macro-fauna. The Royal Society of Edinburgh and Scottish Natural Heritage remind the Commission that sub-lethal effects in environmental species should not be ignored as they can have a significant effect on population dynamics. They also, along with English Nature, express concern at the potential for second-generation rodenticides to cause environmental problems. The Royal Academy of Engineering adds that aesthetic effects should not be ignored in chemical assessments.
Animal testing issues
Organisations as diverse as the Chemical Industries Association and CEFIC, the Department of the Environment, Transport and the Regions, the Department of Health and Friends of the Earth raise the impact of chemicals assessment policy on animal testing. Most of the Department of the Environment, Transport and the Regions' postbag on the European Commission Chemicals Strategy concerns the huge increase in animal testing likely to result. It would seem difficult for the Commission to make recommendations on chemical assessment without addressing the issues of the acceptability of alternatives to animal testing, and the implications of the recommendations for animal testing.
Differentiating between short and long-term goals
The Department of the Environment, Transport and the Regions makes the point that there may need to be different strategies adopted in the long-term for the assessment of chemicals to those needed for reasons of pragmatism in the short-term. The Commission's usual focus is on the long-term, and it will need to consider how far the Study should attempt to come up with short-term fixes for longer-term problems. A factor in these considerations will be the likelihood of the Commission being able to influence short-term goals.
Regulatory issues
While there is a broad consensus in the responses on the need to incorporate social issues into chemical assessments, there are two very distinct views, represented by the Department of Trade and Industry and Greenpeace on the incorporation of economic considerations. These reflect deeper divisions on different communities of stakeholders' views of what drives regulatory decisions (and indeed what they believe is wrong with sustainable development). One side thinks that environmental concerns dominate, the other that short-term economic considerations consistently over-ride environmental protection. On a related issue, both the London School of Hygiene and Tropical Medicine and the Royal College of General Practitioners query the degree of trust that should be placed in self-regulation.
The Substitution Principle is mentioned in many responses, with a divergence of views on whether it should be based on hazard, as favoured by Friends of the Earth and Greenpeace, or risk, as favoured by the Chemical Industries Association, CEFIC, the Department of Trade and Industry and others. See in particular the annex to the Royal Society of Chemistry response, which also discusses the degree to which different risks can be compared.
The European Environment Agency report attached to their response points to implementation problems rather than a lack of regulations across Europe as one of the key issues, while the Scottish Environment Protection Agency notes that the division between devolved and reserved UK responsibilities on chemicals can create problems for the regulators in Scotland. The Ministry of Agriculture Fisheries and Food calls for better coordination generally between those responsible for chemical assessment and regulators. Greenpeace questions the effectiveness of existing approaches in providing drivers for changes to a more sustainable use of chemicals. The English Nature response notes that the introduction of Biodiversity Action Plan targets and Habitat Regulations could create important new drivers for more stringent controls over chemicals.
Other issues
The Royal Society of Edinburgh, Scottish Natural Heritage, and the Royal Academy of Engineering point to lessons on assessment and management that could be learnt from other fields, particularly those handling radioactive materials. Friends of the Earth believes that the regulatory focus should be on the role that chemicals perform, rather than the interests of the chemicals industry. A personal communication from Marek Mayer emphasises the potential for the development of a chemical services industry to further this philosophy.
The Environment Agency suggests that the Commission should focus on issues relevant to the levels of protection for humans and the environment, rather than inefficiencies in the assessment process.
The Chemical Industries Association and CEFIC contrast the public's fear of effects with the improvements in health and longevity attributable to the use of chemicals, questioning whether the risks that form the basis for the fears are real or perceived. The European Environment Agency report 'Chemicals in the European Environment: Low Doses, High Stakes?' co-produced with UNEP also discusses this point, though from a different viewpoint. The reports prepared by the Scottish Universities Policy Research and Assessment (SUPRA1) group for the Commission help to shed some light on the issues for the Study on public fears and underlying values. The Swedish National Chemicals Inspectorate (KEMI) suggests that there may be many hundreds of chemicals in use that cause adverse environmental effects. Greenpeace draws attention to the conflict between people's right to know about chemicals and the commercial confidentiality in the regulatory and assessment processes.
Finally, it is worth noting the comment from the Royal Society of Chemistry that the Study should keep in mind the needs of the developing world, where chemical pollution may sometimes be the lesser of two evils.
(1 The SUPRA reports should be posted on this website by end July 2001.)
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