ECHA

The upcoming Helsinki Chemicals Forum gives us all a chance to look at chemicals policy in a broader context as we hear about successes towards sustainability. I am looking forward to hearing about safer and more effective new substances, new processes and new manufacturing technologies, but I sometimes wonder whether we need to challenge ourselves to think even further 'outside the box' if we are to make bigger leaps forward in safer chemicals beyond 2020.

It is sometimes said that what you measure is what you get and for that reason, I would like us to start thinking about qualitative measures that we can consider when thinking about chemicals. What about things like the conservation of molecular structures throughout a process? Or the renewability of raw materials needed in a manufacturing process? Both of these issues are really important because we need to be resource efficient and therefore reduce waste and all kinds of 'losses' during a process.

These are core elements for sustainable chemistry. However, they are difficult to address with our current toolbox of indicators. I think that the concept of entropy helps us to get nearer to the essence of sustainability.


Entropy – a way of addressing qualitative aspects within a cost/benefit analysis

Dr Thomas Jakl. Image: ECHA.

Thinking about entropy gives us a way of evaluating processes and products that cannot be achieved by conventional approaches. Conventional approaches can describe and explain the effects of a substance, and make them consistent and comparable by monetising them, but they are very limited when describing more qualitative aspects, or the basic principles of a process.

I'm talking about qualitative aspects like the impact on civil society caused by loss of species diversity; the consolidation and controllability of material flows; energy usage and information contained in chemical structures. These can be taken account of and described much more clearly using the concept of entropy, and this would add an important dimension to the current methodology of cost/benefit analysis.

For this to work, entropy must be used in a way that is both expedient and consistent with its original meaning, and not reduced to a measure of disorder. So, what do I mean by entropy? Well, if you take a look at what all the approaches to entropy have in common, increases in entropy always involve a loss – of useful energy, of structure, of information and, ultimately, of quality. It is a hard concept to grasp and describe however.

So, I recommend that we take a two-step approach. First, I would like to look at how entropy has been used in other situations to see how we could make best use of it when describing the sustainability of chemicals. That should lead to developing an approach to entropy based on scientific findings. Secondly, this approach should then be used as a basis for applying entropy as an indicator that can be understood and used by companies and the authorities working for the safe and sustainable use of chemicals.

It seems to me that by adopting this kind of approach, entropy can help us evaluate processes and products to determine their suitability as part of a viable economic system in the long term. This would be a far richer picture than a simple cost/benefit approach.


Epigenetics – understanding the communication between chemicals and the living

‘How' and ‘when' external factors interact with biological systems will certainly be the way in which we judge them in the future.

Epigenetics is redefining biological understanding about the relationship between living organisms and their environment. External factors – such as chemicals – can alter how genetic information in our DNA is (de-)activated and transformed without changing the genetic code itself. These activity patterns may be reversible, or they may also be passed on to subsequent generations.

Epigenetic changes are associated with serious adverse health effects, including cancer and endocrine disruption. A number of effects related to epigenetic regulation are already considered relevant for risk assessment – in particular:

1. Effects caused by substances that directly affect the way the genome is activated or deactivated, for example, by DNA methylation, and may induce changes in regulatory pathways.
2. Epigenetic modes of action of chemicals that are known to be hazardous (e.g. endocrine disruptors, carcinogens), specifically those leading to irreversible changes in the organism.
3. Effects that pass on to subsequent generations.

But epigenetic effects may also differ in substantial ways from the other effects/adverse outcome pathways that we currently consider in risk assessment. The time lapse between exposure and adverse outcomes, for example, may differ significantly from the ‘classical' toxic effects when epigenetic mechanisms are involved.

For us to be able to fully understand the epigenetic effects of chemicals, we will need to know much more about the pathways of epigenetic regulation, the links between the disruption of endocrine and epigenetic systems and the adverse outcome pathways relevant for risk assessment. We'll also need to know whether the effects of environmental stressors on epigenetic pathways are larger than any underlying physiological variability.

In my view, it is only a matter of time before risk assessment methodologies will have to understand this new language about the interaction between the living world and its surroundings.


Resource efficiency – services instead of barrels

Finally, there is one further quality aspect which will increasingly shape the way we look at chemicals' use.

The focus for chemicals' management will widen from assessing hazards and risks towards monitoring and continuously optimising how they are applied and used – thereby making resource efficiency a goal for future chemicals policy.

In short, we are moving from ‘using the right chemicals' to ‘using chemicals right'. This is where service-based concepts, such as chemical leasing, are key. For example, this is the only current business model where the economically-driven goal for the manufacturer or producer is to use less.

When manufacturers are paid for their chemical's performance rather than their quantity, it will be in their best interest to focus on performance rather than volumes sold. If manufacturers are paid per unit, their prime economic interest will be that the product is used as efficiently as possible.

How could this fit into the REACH philosophy? In my view, goals for resource efficiency should be required by the legal framework and could subsequently be fine-tuned and agreed upon on a case-by-case basis between the authorities and companies. Detailing resource efficiency as part of applications for authorisation to use substances of very high concern, or as part of a new requirement for continuous optimisation to be documented in the chemical safety report, could be monitored by ECHA.

Together with the Member States, ECHA could compile and evaluate data gathered by companies to demonstrate the appropriate use of chemicals to check whether the envisaged effect does in fact materialise.

I can clearly see that entropy, epigenetics and efficiency will frame the mind set for chemicals' policy beyond 2020, because they help us to focus on quality: of design, of effects and of applications.

Dr Thomas Jakl
Deputy Director General, Ministry of Environment, Austria; Member of ECHA's Management Board
 

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