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- To apply or not to apply - that is the question for business
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- Users help to test the new version of Chesar
- Guest column: Five year of REACH
- REACH and CLP impact : Chemicals legislation changing in Asia
- MEP Julie Girling visits ECHA: Understanding the role of the agencies
- Blogging about chemicals
- Helsinki Chemicals Forum 2012: Chemical safety in the spotlight
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Helsinki Chemicals Forum 2012: Chemical safety in the spotlight
The harmonisation of chemical regulations, communicating on the safety of chemicals, challenges to innovation and alternative testing methods were among the topics of the Helsinki Chemicals Forum from 24 to 25 May in Helsinki.
ECHA's Executive Director Geert Dancet opened the event by thanking industry and regulators for their efforts in the REACH and CLP systems, but reminded that a lot remains to be done. "Together, all of us being part of the interaction between industry and regulators, we are undoubtedly moving ahead on the road to safer chemicals. We in Europe have seen an enormous and supportive response by industry in living up to their obligations as duty holders under the REACH and CLP regulations. But nonetheless we cannot ignore that the quality of information provided has in a number of respects often fallen short of the legislator's expectations. We still have quite a long way ahead", he said.
Rob Visser, a former Deputy-Director from the OECD, spoke about the future of chemicals management. He convinced the audience that chemical safety will remain a policy priority in the future. "Chemical safety is not finished business. REACH is an excellent basis for risk management but chemical safety is a moving target. New types of chemicals are being developed constantly", he said. To move forward in the field of chemical safety Mr Visser highlighted the need to make regulatory convergence an international policy priority, to use the same or similar assessment tools and to further develop international cooperation on raising awareness and promoting mutual understanding of chemical safety globally.
HARMONISING REGULATIONS TO MINIMISE THE BURDEN FOR INDUSTRY AND AUTHORITIES
The first panel discussion tackled the regulatory convergence of chemicals legislation. Derek Knight from ECHA promoted the REACH system as an inspiration for worldwide convergence. "The philosophy and principles of REACH and CLP are transportable outside Europe as well. REACH is not perfect, but it is good enough, it targets the activities to get maximum effects", he said. Kaj Madsen, Senior Programme Officer of UNEP, brought the perspective of developing countries into the discussion. To achieve convergence, the developed countries need to assist developing countries by providing advice on the development of legislation, creating administrative institutions, building capacity and ensuring finance.
Manfred Marsmann from Bayer AG spoke about improving the regulatory framework by reviewing and eliminating overlaps and gaps, by mutual acceptance of methods and by strengthening the quality of regulations. To that end, he welcomed the review of REACH currently underway in the Commission.
Michael Walls, Vice President of the American Chemistry Council, highlighted the importance of clear objectives and priorities. "Minimising duplication and minimizing the burden on industry is one thing, but we should also enhance the information upon which regulatory decisions are made. If we can be clear about our objectives we can probably bring some significant work forward in this area", he said.
COMMUNICATING WITH THE GENERAL PUBLIC - ARE WE REACHING THE CITIZENS?
The challenge of communicating and popularising information on chemicals in order to reach the general public was discussed intensively in the second panel discussion. ECHA Director Andreas Herdina chaired the panel and pointed out the fact that at the moment there is a wealth of information shared among the insiders of the chemicals field but for the general public "we need to do more". David Azoulay, an environmental attorney from the Swiss firm Ciel, spoke about the importance of reaching out to the general public in a transparent way. "People need information to make an informed decision on whether to use or not to use a certain product", he said. According to Mr Azoulay there are shortcomings in ECHA's registered substances database. "Unfortunately, the situation is not much better now than it was prior to REACH. The ECHA database is very generic. The will is there but it is not enough. The database should be more comprehensive and easier to use."
Dr Hans Bender, representing the European Detergent and Cleaning Industry as President of A.I.S.E. , told the audience that industry sees itself as an expert in communicating with the general public, and that industry is taking voluntary action to enhance the knowledge of consumers. "Consumers' choices have the most impact on the environment; we need to make consumers more knowledgeable about the product and also about the use. On-pack labelling is the key, but it should be complemented with more detailed information on websites. Consumers want to understand which precautions they need to take when using a product", he said.'
Sylvia Maurer from The European Consumer Organisation (BEUC) represented consumer organisations on the panel. She told that consumer organisations are communicating about chemicals through comparative product testing in magazines, campaign websites and through social media. As an example of engaging consumers in social media, she mentioned an application developed in Norway to scan cosmetic products for endocrine disruptors. According to Ms Maurer the consumers ‘right to know', introduced by article 33 of REACH, does not work. "Companies do not seem to have a systematic management how to deal with the requirements of article 33", she stated. Although the starting point with consumer products is that they have to be safe, Ms Maurer sees a need for additional regulatory action. "Chemical safety is a moving target, which is why regulation needs to play a role. We also need a horizontal approach on chemicals across product groups to lower the exposure of general public."
| Ms Anne-Sofie Andersson and Dr Hans Bender debate substitution. |
Image copyright: HCF.
SUBSTITUTION OF CHEMICALS DEBATED
The issue of substitution and whether it is being encouraged by the new legislation was debated between Dr Hans Bender representing industry and Ms Anne-Sofie Andersson from ChemSec, an environmental NGO based in Sweden. Dr Bender was convinced that the legislation can encourage substitution but that substitution should not be an end in itself. "There is much more. Substitution is one element in the safe management of chemicals and it should ideally be part of a broader innovation effort. One central element to enable substitution in REACH is authorisation, which provides the framework and structure for the assessment of alternatives and substitution", he stated.
Ms Andersson mentioned two REACH processes that entice substitution: authorisation and the Candidate List. "Authorisation is not really working. It is going slow and has an uncertain outcome. Also, the relevance of third party contributions will depend on the information available and the time given to contribute, and more transparency on the process is needed. However, the Candidate List is working. It has created new thinking on what producers have in their portfolio. This is very important. The process could be quicker though", she said. According to Ms Andersson the substances of very high concern (SVHCs) and the Candidate List have raised awareness among industry about which chemicals to prioritise and focus on. "Substitution might have benefits such as saving money on waste costs, on take-back actions or on the impacts of bad reputation."
REGULATION AS DRIVER FOR INNOVATION
The second day started with a panel discussion on the relationship between innovation and regulation. Director Gwen Cozigou from the European Commission said that we should find the right balance between means that provide safety and means that enhance innovation. "Regulation can certainly play a positive role in innovation but it is to be looked at very carefully knowing that safety, competitiveness and innovation can play together but they can also conflict. The first source of innovation is not with us but with the private sector", he said.
Swiss consultant Wim Jetten sees that regulation alone cannot drive innovation. "Regulation alone is not going to give you a business reward, it needs more than that. Competitive, societal, financial and sustainability challenges are drivers that make you think what kind of products you would like to develop. However, regulation has a role in setting the conditions, directing, stimulation, setting timelines and ensuring a level playing field", he explained.
Dr Gernot Klotz, Executive Director of Cefic, pointed out that innovation is a mindset change, not just technology and that innovators have to deal with uncertainty. "Innovation is moving forward much faster than the regulatory processes. How are regulations maturing to back up innovation?" he asked.
ALTERNATIVE TESTING METHODS
The Helsinki Chemicals Forum concluded with a session on alternative testing methods to test long-term toxicity. Dr Erwin Annys, Director at Cefic, emphasised the role of OECD for achieving internationally agreed test methods, and the fact that REACH encourages the use of alternative methods. "It is mentioned in REACH that animal testing should be used only as a last resort. REACH promotes a variety of alternative possibilities: use of existing data, weight of evidence approaches, structure activity relationships, in vitro methods, grouping and read-across, and exposure based adaptation of information requirements", he said. All these methods should result in the same quality of information that would be received through traditional testing. "There must be a regulatory acceptance of the new methods and it has to give the same quality information as the traditional tests. The legal texts are not very flexible in their interpretation, which means that a lot of creativity is needed to use newly accepted test methods before all legislations are updated."
Dr Katy Taylor, Senior Science Advisor, from the British Union for the Abolition of Vivisection (BUAV), spoke about the bureaucratic, financial and attitudinal barriers to using alternative testing methods. According to Dr Taylor, harmonisation of alternative testing methods is great, but unfortunately takes a long time. "The EU waits for OECD acceptance. It takes two years from OECD acceptance until entering into the test method regulation. The attitudes also need to change. There is a failure to appreciate the shortcomings of animal tests, and sometimes regulators fail to inform industry of updates", she said. Dr Taylor concluded with a plea to both regulators and industry. "Let's invest more into the science and let's make sure that we have the [alternative test method] processes in place so that we can move on as soon as the science is there."
The next Helsinki Chemicals Forum will be held on 18-19 June 2013 in Helsinki.
Image: Panel members at the Helsinki Chemicals Forum are taking questions from the audience through an online message board. Image copyright: HCF.
Text by Hanna-Kaisa Torkkeli
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Biocidal Products Committee:
30 November-4 December (tentative)
Committee for Risk Assessment:
6-8 October (RAC-52B);
30 November-4 December (tentative);
7-11 December (tentative)
Committee for Socio-Economic
30 November-4 December (tentative);
7-11 December (tentative)
Member State Committee:
7-11 December (tentative)
Management Board meeting: