The top 10 weekend getaways, the 15 best white chardonnays or 25 ways to reuse common household items. It’s virtually impossible to scour the internet these days without coming across a list. They’re everywhere! I think their popularity is due to lists being easy to skim. Lists are a fast and digestible way to approach a wide range of topics.
One such popular list is our very own SIN List, which actually turns ten today. Originally created when a number of companies approached us and asked what chemicals we thought were going to end up on the, at the time, soon-to-be Candidate List. Now it has a life of its own and its tenth birthday is naturally something we want to celebrate.
At first I thought to use this space to write about its global importance, how the Commission has called it a driver for innovation, how UNEP says it is one of the few relevant lists of hormone disruptors of concern or how Dow Jones has included it in its sustainability indices.
Then I thought I should maybe write something about all the third-party labels, verification schemes and chemical compliance consultants that include it in their criteria. Or the ever-growing number of users all over the world.
“I would like to address why we haven’t removed a single chemical from the SIN List”
But I’m not going to do that.
Instead I would like to take the opportunity to address why we haven’t (yet) removed a single chemical from the list, even though many companies asked us to (both nicely, and not so nicely). I write yet because, hypothetically, it’s not like we couldn’t remove substances from the list. If new scientific data proved us wrong in some case we would of course consider delisting the chemical in question.
Twice we have received legal threats; delivered as letters written on expensive-looking paper, filled with legal jargon. When deciphered they both basically read: “Remove this and this chemical from the SIN List or else we will sue the crap out of you.” But thanks to the strong Swedish freedom of speech legislation we’ve been in the clear.
Most of the time there haven’t been any outspoken threats though. More commonly, companies that either produce or use a specific chemical have tried convincing us to delist it.
During these talks there’s normally a host of arguments that keeps coming back.
And, following the list theme, I thought I’d share the top six arguments why ChemSec should remove a certain chemical from the SIN List – and our reasons not to.
1. “Putting ‘our substance’ on the SIN List has had serious consequences for our business economy.”
This is at the very least an honest argument, but at the same time it is not something we would consider paying attention to. Our mission is to protect human health and the environment. But – and this is important – we believe it is perfectly possible for a company to do the same, and make money at the same time. Smart businesses do not invest in problematic chemicals – they invest in the solutions.
2. “The ‘SIN’ name is scaring our customers away. They have a low scientific understanding.”
We actually think the SIN name is really smart. It’s an acronym – Substitute It Now – but the name also reminds many people of sin in Christianity. Coming from a very non-religious part of the world (northern Europe) we still understand how this pun may strike a chord, or even be offensive, to people with a closer Christian connection. Still, it makes the message very clear: stay away from these chemicals!
But apart from the strong name, the very nature of the list means it is not something for the tabloids or even most news media. It’s not intended to be used by regular consumers – the SIN List is aimed at companies and policy makers. ChemSec offer guidance and science-based data that can be used to make smart business decisions. Smaller companies often lack resources to produce equivalent data, but to claim they don’t understand or that they’re easily scared is not a good reason to withhold factual information about toxic chemicals according to us.
3. “We have studies showing that this substance is actually safe”
The SIN List is based on publically available, peer-reviewed data, from scientific studies that have been published in a scientific journal. Many times universities or other similar entities, with no personal interest in any chemical, have been responsible for the studies. It’s true that many companies have data of their own, partly because the law says they need to, but the SIN List builds solely on publically published data.
4. “The exposure to this chemical is extremely small.”
The SIN List is based on the intrinsic properties of chemicals. That means we only take into account whether a chemical is toxic or not when we consider putting it on the list. We do not consider how, why, how much, or where it may be used. The SIN List’s legal counterpart, the Candidate List in the EU’s chemicals legislation REACH works in the exact same way, and the use of chemicals is not discussed until the next legal step: the authorisation process.
5. “This chemical is very useful and important.”
Very much the same answer as for question number four: whether a chemical is important or not has nothing to do with its intrinsic properties.
6. “We are not using this substance in our products any longer, but we would like to recycle material in which it is present.”
The importance of recycling and the circular economy is growing by the day. The way you approach hazardous chemicals in recycled material can vary. Basically, there are two different arguments:
- “Re-use is so important that it doesn’t really matter what the recycled materials contain”, or
- “Make sure that the materials we use and produce do not contain hazardous chemicals so that we can recycle them safely”.
To no one’s surprise, we think the second argument is the only one that holds up here. The circular economy gives added weight to the issue of why it is so important to phase-out the most hazardous chemicals, based solely on the fact that they are hazardous. This is because no one can predict where these chemicals will be used in the perpetual life-cycle of recycled materials.
But seeing as this is a day of celebration I would like to end on a positive note and thank everyone who has helped to make the SIN List into the robust and scientific tool it is. We’ve had incredible background work done by scientists around the world. Thanks also to the tireless advisory committee filled with dedicated experts from European NGOs. And thank you to all the experts in science and policy from member states, universities and companies, who have provided valuable input over the years.
And of course, thanks to everyone who uses the SIN List, who visits the database and who gives us feedback. We are always considering how to further improve and develop it, so keep it on your radar to stay up to date.
Executive Director, ChemSec