Led by CHEM Trust, the group includes Breast Cancer UK, the Hazards Campaign, Marine Conservation Society, the Angling Trust and Unchecked UK.
“As we evolve our national policies and approaches now we have left the EU, we have an opportunity to set ambitious goals and develop a world class system of chemical management. In doing so, it will help us meet our environmental targets to deliver our long term environmental ambitions and drive green chemical innovation to stimulate economic growth and jobs after Covid-19. We, therefore, urge this government to strongly consider our calls to action and to ensure this chemical strategy delivers ambitious and positive outcomes for our health and the environment,” says their joint letter to environment secretary George Eustice and his counterparts in the devolved administrations.
Their “12 key asks” appear to be a response to industry lobbying to weaken the UK REACH regime, which a separate group of academics last month warned could “critically compromise the UK’s ability to make evidence-based risk management decisions about chemical use”.
The development of the Chemicals Strategy was announced more than three years ago, in the 25-Year Environment Plan. But delays caused by no-deal Brexit planning and the pandemic have meant that little detail has emerged.
Anna Watson, head of advocacy at CHEM Trust, said: “The UK government must develop a Chemicals Strategy that properly protects citizens, wildlife, and the environment from hazardous chemicals. These 12 key asks must be prioritised to ensure this protection.
“The UK should also keep step with the ambitious EU Chemicals Strategy and EU chemical related regulations. Otherwise UK consumers and environment will be considerably less protected than in the EU, and this could give rise to the dumping of products on the UK market that do not meet EU safety standards.”
The EU strategy identified “significant weaknesses” in chemical controls, which have been largely inherited by the UK. Foremost among them was the need to have one assessment for each substance, rather than a multiplicity under REACH, pesticides, biocides and other regimes. It also promised to redouble regulatory efforts towards groups of chemicals, rather than considering the one-by-one, and a “zero tolerance” approach to non-compliance.
The strategy further promised to phase out all forms of highly-persistent PFAS chemicals, other than those considered to be “essential for society”.
Their demands are:
1. Apply the precautionary principle. “This is particularly important in consideration of sensitive development windows” such as in the womb or early childhood, says the paper, noting that it would also be consistent with recommendations made by the Commons’ Environmental Audit Committee two years ago.
2. Phase out the most hazardous chemicals from consumer products, for all non-essential uses. A clear timetable is needed to ensure that all chemicals considered to be carcinogenic, mutagenic, reprotoxic, endocrine disrupting, immunotoxic, neurotoxic, or are persistent, bioaccumulative and toxic are removed, particularly from toys, bedding, furniture and food contact materials.
3. A plan to address endocrine disrupting chemicals, including criteria to identify them, and consider there to be no threshold below which they do not have an impact on health.
4. Phase out the use of PFAS and other very persistent chemicals, “because remediation is ineffective once they have spread into the environment,” and they pose a threat to circular economy objectives.
5. Speed up regulation of harmful chemicals and avoid regrettable substitution by adopting a grouping approach, to reduce the risk of regrettable substitution by similarly toxic substances.
6. Address the combined exposure to chemicals – known as the ‘cocktail effect’ – by adopting a ‘mixture assessment factor’. The European Commission is currently working on the idea, though Brussels-based industry group Cefic has dismissed the idea as overly simplistic and “not based on sound scientific principles”.
7. Maintain and expand on workers’ health and safety, not least through extending safeguards on carcinogens and mutagens to reprotoxins.
8. Ensure a clean circular economy with products that are safe by design. “This must include a National Materials Datahub to ensure traceability for all substances in products and materials (ensuring full transparency)”, the development of which has stalled.
9. Develop an effective and transparent monitoring and alert system for chemicals in people and the natural environment, with easy access to data.
10. Stop the continued accumulation of legacy chemicals in the environment by providing a “timeline for the identification and elimination of the remaining sources” of polychlorinated biphenyls, brominated flame retardants and other such substances.
11. Remain aligned with EU REACH, “the de facto international gold-standard for chemicals regulation”. The government has repeatedly refused to do so, and the first proposals for restrictions under UK REACH have been described as signs of future divergence.
12. Ensure more transparency and use of all relevant science for assessing health risks.