Review of 2016: The 5 biggest mistakes by the Commission and more
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Review of 2016: The 5 biggest mistakes by the Commission and more

It’s Christmas time again, and beyond that 2017 is approaching fast. But before we all log off and spend some well-deserved time out of the office, we want to take you back, reminisce and think about some of the most memorable events, quotes and actions of 2016 according to ChemSec.

Five biggest mistakes by the Commission in 2016

  1. Granting authorisation to use lead chromates in paint even though European industry stopped using it 30 years ago and there are known alternatives.
  2. Overstepping its legal mandate in the process for establishing EDC criteria, when changing the pesticides derogations from a hazard-based to a risk-based approach.
  3. Granting authorisation to use DEHP in recycled material even though it works against the idea of Circular Economy
  4. Really taking its time (over two and a half years) before adding new substances to annex XIV.
  5. Proposing insufficient new limit values for occupational health, including exposure limits for Chromium VI, which will lead to cancer in every tenth worker.

A prevalent misconception among media, politicians and others is that industry finds chemical regulations ineffective, burdensome and a threat to their profits. This is largely a result of chemicals manufacturers lobbying on their own behalf while also claiming to speak on behalf of downstream users, such as consumer goods manufacturers, retailers and others. In reality, there are a many companies who put a lot of effort towards reduced use of hazardous chemicals.

Five great things companies did this year

  1. A coalition of companies sent a letter to the Commission, calling for the much-delayed EDC criteria to be put in place swiftly.
  2. The adidas Group decided to be 99 percent PFC free by the end of 2017.
  3. Apple has not only made their restriction list public, but also their phase out plans.
  4. H&M backs the restriction of CMRs in textiles.
  5. Coop Denmark removed all bisphenols from three of their largest brands of tin cans.

What We Talk About…

5 most mentioned people in ChemSec’s Policy meetings

  1. Matti Vainio, Head of Unit: Risk Management, ECHA
  2. Klaus Berend, Head of Unit REACH at European Commission, DG Grow
  3. Björn Hansen, Head of Unit: Chemicals. European Commission, DG Environment
  4. Geert Dancet, Executive Director, ECHA
  5. Vytenis Andriukaitis, EU Commissioner for Health and Food Safety

This year something started stirring in Europe when it comes to the risk versus the hazard based approach to assessing chemicals, and it became more and more evident that a number of stakeholders want to eliminate the hazard approach and reintroduce chemicals legislation based solely on risk. During 2016 ChemSec has been vocal about this looming threat, in articles, presentations, meetings and in social media, for example. And every time you talk about risk and hazard there are always, without exception, a couple of ideas that risk advocates rehash. So, here is…

…Top twitter comments from risk advocates that we already heard infinite variations of in the past!

1. But why use hazard here and not e.g. to ban cars (26,000 road deaths/yr)? #EU needs consistent #regulation! @EuroDonald

ChemSec comment: Of course it is not really relevant to compare products such as cars with individual chemicals, which constitute only parts of products. ChemSec wants to replace hazardous chemicals that meet the criteria for Substances of Very High Concern, SVHCs, in products with safer ones. ChemSec do not want to ban entire product categories.

2. Hazard based approach is populistic and fear based, ruling out sensible sustainable solutions. @EdmarMeuwissen

ChemSec comment: In the end the decision to use a chemical is always a policy decision and not a scientific “truth”. Which risks are we willing to take? How many cancer cases are we willing to accept in order to keep on using chromium-plated cosmetic containers for example? In our minds the answer is zero, and therefore the EU can ban this substance based solely on its intrinsic carcinogenic hazard.

3. Just about everything from water to nitrogen to vitamins is intrinsically hazardous. Exposure, when, where, how, how much matters = risk! @ajadams2807

ChemSec comment: Risk assessments build on assumptions and can therefore never provide total protection. Even though uncertainty factors are built into the equation, they can never fully protect us from the unexpected, for example a leak, an unexpected exposure or an accident, or an unintended or unexpected use. It is impossible to foresee all the possible uses of a product throughout its lifecycle.

Merry Christmas and a Happy New Year!

/ChemSec Team