The threats are grave

The World Wide Fund for Nature’s (WWF’s) short and simple answer to the question, is that the threats that we face from chemicals are many, varied and very grave indeed. Effects on wildlife and worrying human health trends indicate that we have been carrying out an uncontrolled global experiment contaminating both humans and wildlife with a cocktail of manmade substances. The effect of that cocktail is unknown.

Therefore a major overhaul of behaviour and attitude towards chemicals management going beyond mere legislation is needed. WWF has been working on chemicals policy for many years 1 ; and currently, because of the window of opportunity to influence the proposed European Union (EU) chemicals legislation, WWF UK is running a Chemicals and Health Campaign 2 .

WWF’s raison d’etre is to protect future generations of humans and wildlife. We cannot do this in a world spinning in a toxic soup. The toxic soup cocktail that currently exists can undermine the very biological processes and biochemical reactions that are fundamental to the viability and future of all species.

There is now global contamination that extends from the once pristine Arctic to tropical environments. Manmade or synthetic chemicals are now ubiquitous contaminants in the form of ‘old’ and now banned organochlorine chemicals and pesticides like PCBs and DDT, to the much more modern and currently used brominated flame retardants like PBDEs. Furthermore, there are unknown numbers of endocrine disrupting chemicals being released into the environment.

WWF is a science-based organisation that uses peer review literature as the starting point for the development of our chemicals policy. We also use three additional tools: (1) the ‘weight of evidence’; (2) ‘lessons from the past’; and (3) the precautionary principle to further develop our position.

We also feel risk assessment has its role to play in our decision-making, but only in conjunction with other specific factors where chemical threats in the environment are concerned. If hazard, fate and behaviour data indicate a chemical may be deleterious to health or the environment, WWF feels that is enough for the precautionary principle to be used to control, and where necessary, phase out that substance.

Furthermore, in the case of environmental contamination there are other specific factors that need to be taken into account when we try and assess the threats we face from chemicals. Examples of those factors are: (1) specific sensitivities (eg asthma); (2) fetal sensitivity (or other vulnerable groups); and (3) worst-case scenarios. An example of this would be where foetal sensitivity is so great early in gestation that the old toxicological formula of ‘the dose makes the poison’ is at the very best out of date, and at worst wrong and dangerous. Now that the foetus is known to be so sensitive in the early weeks, it must be agreed that ‘dose plus timing’ makes the poison.

The Current Spectrum of Views on Chemicals Management – particularly REACH (Regulation, Evaluation and Authorisation of Chemicals) – is the current EU Commission proposal for a new EU Chemicals Regulation that would replace some 40 other pieces of legislation. All parties agree that the old legislation is not working and that something better is required.

In a nutshell, the top-line aims of REACH are to protect humans and wildlife from the threat of chemicals without negatively affecting the competitiveness of the EU chemical industry. There is a spectrum of views on this issue, including industry, government, the medical community and the non-governmental organisations (NGOs).

Bearing in mind the human health protection aims of REACH, WWF finds it surprising and worrying that the UK Department of Health (DoH) is not a robust actor in the current discussion. We all know that Department of Environment Food and Rural Affairs (DEFRA) is the lead, but surely DoH has a view? WWF, though repeatedly asking, has failed to elicit that view from DoH. Perhaps the department will give its view in this debate….

Until all parties genuinely adhere to those top-line aspirations of REACH, it is WWF’s view that we need to lobby robustly to make our policy position known. Otherwise we feel that the protection of human health, wildlife and the wider environment will be undermined by commercial desires.

What will REACH deliver? Until the REACH proposals arrived there was not a level playing field for chemicals. Old or existing substances on the market prior to 1981 had ‘squatters rights’ and could stay on the market and continue to be used though they had little or no safety data. Post-1981 chemicals had to go through more safety data testing. However, REACH means that there is a reversal of the burden of proof and chemical companies must show that their chemicals are safe before they go on the market regardless of the date first used.

REACH also calls for an element of substitution of chemicals. However, it is WWF’s view that the Commission’s proposal is much too weak and should ‘demand’ the substitution of a more hazardous chemical with a less hazardous one if that alternative exists.

In addition, the WWF feels that the EU proposals on the authorisation of the use of a ‘dangerous’ chemical are weak. In WWF’s opinion, where a substance of concern is used because there is no alternative and there is overriding societal need, that authorisation to use the chemical should be short term or time limited only.

The chemical industry has indicated that it does not want all aspects of REACH, since it will cost too much money to implement. WWF’s view is that industry cannot afford not not test its chemicals and products. Furthermore, the health benefits that will be delivered by REACH and associated cost savings enormously outweigh the costs to industry.

REACH also offers the opportunity to produce ‘greener’ products, thus leading to competitive advantage.

In trying to develop a chemicals policy in Europe (and wider afield) that genuinely protects future generations of humans and wildlife, WWF is carrying out the Chemicals and Health Campaign with associated reports and biomonitoring activities. The blood samples of the volunteers that we have tested indicate that in some cases young children are more contaminated than their parents or their grandparents. This is extremely worrying because we do not know what the effect of this cocktail of chemicals could be, especially when homeostatic responses and the endocrine system are so sensitive.

With the uncontrolled global experiment of chemicals on life, there is no ambiguity – the threats we face from chemicals are too great.

Elizabeth Salter Green is head of the toxics programme at the World Wide Fund for Nature.