The European Union (EU) adopted, in mid-October, a new strategy on chemicals — including pesticides — that seeks to deal with their combined (synergistic) and cumulative impacts on human and environmental health. A highlight of the new strategy is the acceleration of work, already begun across the EU, to address the “chemical cocktail” impacts of pesticides and other chemicals. Human exposures to such “cocktails” can happen through use of multiple different agricultural pesticides that can persist as residues on food, and via industrial processes and consumer products. Beyond Pesticides has insisted for years that, here in the states, the Environmental Protection Agency (EPA) has been way behind the eight ball in dealing with the potential synergistic and cumulative impacts of the pesticides its registers for use. Advocates have argued that the agency must be far more rigorous in evaluating impacts of exposures to multiple pesticides, as well as cumulative impacts.
The toxicity problem the EU seeks to address is that interacting chemicals can have synergistic effects, even at very low levels — effects greater than and/or different from the expected impacts of each chemical per se. Pesticides can also have cumulative “toxic loading” effects in both the immediate and long terms. The new EU strategy states that, though “it is currently ‘not realistic nor economically feasible’” to evaluate every possible combination of the thousands of chemicals used in industry and society, there is emerging scientific consensus that the impacts of chemical cocktails “‘need to be taken into account and integrated more generally into chemical risk assessments.’” Beyond Pesticides concurs.
A panel of government officials, discussing whether the OECD could develop an inventory of chemicals on the market around the world, agreed that this would require significant resources but could benefit multinational exporting companies by reducing national notification obligations.
In a session of the OECD’s chemicals management virtual conference, held on 3-4 November, best practices were looked at for setting up and maintaining such an inventory. The panel, comprising representatives of national and regional agencies in the US, EU and Vietnam, posed the question of feasibility and what benefits it could bring.
Le Viet Thang, deputy head of the conventions and international cooperation division of Vietnam’s chemicals agency, said that as a developing nation in the process of creating its own inventory, a global centralised system would offer more insight into where chemicals are being used locally and internationally.
The same chemical can be listed on many inventories in the EU, Japan, South Korea and the US, he said. An international inventory could recognise national or regional lists and harmonise them, helping businesses avoid confusion over national notification obligations, and potentially reduce authorities’ work with industry to identify the status of the chemical in a particular country.
For example, if two countries use different terminology for their inventories, it becomes difficult for an exporting company to know if their chemicals are ‘existing’ or ‘new’ in the destination country.
Bob Diderich, head of the OECD’s environmental health and safety division, told Chemical Watch it’s likely that developing a global inventory will increase the number of ‘existing’ chemicals and therefore reduce the burden on companies, because less of their chemicals will need to be notified as ‘new’.
Yvette Collazo, director of the Office of Pollution Prevention and Toxics at the US EPA, agreed that it would be a useful tool, despite the effort needed to obtain the data and manage it. “Not only [would a global inventory be useful] for the different countries and regions but also the multinational companies and supply chains,” she said.
Taking a different perspective, Jukka Malm, Echa’s deputy executive director, said there is “certainly room for jurisdictions to work closer together on developing inventories, however, adopting a single, international inventory that would serve everyone” may not be the best available option because there is such variation in chemicals management approaches.
He suggested benefits would result from improved methodologies that still recognise countries may develop different regulatory frameworks. This is important, he said, because chemical inventories are designed to serve a country or region’s regulatory system and therefore any international work must consider these variations in approaches.
“But I do realise that a lot more support can be provided to help countries, especially developing nations, develop inventories and chemicals management frameworks,” he added.
Mr Malm said another useful project would be to try and identify the differences and overlaps between inventories. “This is not as easy as it may seem because, for example, you can have the same chemical on more than one inventory but it could be differently identified in each list,” he said.
This increases the time it takes for authorities and industry to identify how a substance is restricted in a certain country and in turn identify potential alternatives, he added.
Mr Diderich said forming a global chemicals inventory would “indeed be a great endeavour and clearly a topic that the OECD could look into”.
However, he said the challenges would be to obtain and designate the required resources, which would be vast for such a global system, and long-term maintenance would need to be assured – all requiring a lot of funding.
The panel also identified other “affordable” projects that the OECD could initiate. Most significantly, it suggested the organisation develop a best practice guide for establishing an inventory.
Mr Diderich acknowledged the “high interest” in understanding the overlap between inventories. To address this, “improving consistency in the use of chemical ID descriptors sounds like a valuable first project,” he added.
The OECD plans to discuss in the coming days how it can take forward projects to address issues highlighted during the two-day conference.
Beyond Pesticides, 30 October 2020
; Chemical Watch, 6 November 2020