After working in the field of chemicals policy for 10 plus years, you find that some chemicals come back over and over again, not unlike Arnold Schwarzenegger’s character in “The Terminator”. You think you put him out of action, but no. A red lamp-eye suddenly lights up again and it starts all over, the monster making good on its promise: “I’ll be back.”
One of those chemicals is resorcinol, which we added to the SIN List in 2011. It is a textbook example of an Endocrine Disrupting Chemical (EDC), since it has been known for many decades to interfere with thyroid hormones. However, it has neither been officially recognized as an endocrine disrupting chemical, nor regulated yet.
Resorcinol is manufactured or imported to the EU in amounts between 1,000 and 10,000 tons annually. It has a wide variety of uses – in production of rubber and plastics, but also in cosmetic products, especially hair dye. It is classified as acutely toxic to the environment and irritating to the skin and eyes.
“This is how the cold and relentless machinery works”
This week at the REACH Committee meeting, we expect the Commission to finally make the decision that would place resorcinol among other SVHCs (Substances of Very High Concern) on the REACH Candidate List.
So why has it taken so long to get here? There are a number of ingredients to this story, tactics that are not unique to the case of resorcinol, but have been efficient in stalling regulation of many other well-known hazardous chemicals. This is how the cold and relentless machinery works:
First of all, the development of EDC criteria is a political failure of magnitude, as we have previously reported. Paved by court cases, industry lobby and never-ending impact assessments, the road from scientific knowledge to political action has been infinitely long.
Resorcinol exemplifies two of the main controversies regarding EDC criteria: What should be included when defining the endocrine system? And can safe limit values be established for EDCs?
The effects of resorcinol on the thyroid gland have been well known since it was discovered in the 1960s that patients treated for skin lesions with resorcinol-containing creams developed different adverse thyroid effects. When the EDC issue started to gain attention, resorcinol manufacturers actually argued against the thyroid to be defined as part of the endocrine system. Luckily, this tactic was not successful.
The other controversy regards “potency”. Is there a concentration limit under which the substance can be safely used? Endocrinologists say no. This limit is not possible to identify, due to low-dose effects, delayed effects, and other tricky things concerning how hormones function. And when the EDC criteria for pesticides and biocides (criteria are still to be established for REACH and CLP) were finally established, “potency” was not included.
Still – in the discussions about resorcinol under REACH – an argument against identifying it as an EDC has been that effects are mainly seen after exposure to high doses.
The “E” in “REACH” stands for “substance Evaluation”, a process where substances of potential concern is divided among member states for further scrutiny. The evaluating country ultimately provides recommendations on how to tackle the substance.
Resorcinol was evaluated by one country, which eventually came up with the conclusion that no further actions were needed. These conclusions are not binding, and other countries disagreed. France presented a thorough dossier outlining the endocrine disrupting effects of resorcinol and nominated it for the REACH Candidate List.
This action, to go against another member state’s recommendation, was heavily criticized, and likely a reason why the member states did not manage to agree on resorcinol. Instead, the issue was forwarded to the Commission.
The SVHC criteria category “Substances of Equivalent Level of Concern” (ELoC) is meant to capture substances for which there are no criteria yet. EDCs are mentioned as the example of such chemicals in the legal text.
In practice, it has been required – according to certain criteria – to show that a substance is both an EDC and of equivalent level of concern. ELoC criteria include elements like irreversible effects, impaired quality of life and societal concern.
In the case of resorcinol, this system led to a strange conclusion, or rather a non-conclusion: While the member states agreed that resorcinol is an EDC, a few countries voted against the “ELoC” identification, leaving the Commission to decide.
In the case of resorcinol, there is a strong and very competent industry task force, which has closely followed, commented and influenced all events related to the substance for more than twenty years: From the issue of whether the thyroid gland is part of the endocrine system and if potency is required for EDC identification, to how member states may handle substance evaluation differently.
Through the Chemicals Strategy, the Commission is committed to “ensure that endocrine disruptors are banned in consumer products as soon as they are identified, allowing their use only where it is proven to be essential for society”.
The future of resorcinol is now in the hands of the Commission. We hope that their decision will be guided by science and the EDC identification agreed by member states, and not industry tactics intended to further delay all regulatory actions on resorcinol.
To be continued… Or rather: “We’ll be back.”