Friday 14 May 2004

In particular WWF finds its view at odds with the Committee's in that WWF fundamentally believes that to protect wildlife and humans there is a need for mandatory substitution of hazardous chemicals where a safer alternatives exists.

Gwynne Lyons, WWF Toxic Policy Officer, said:

"the Science and Technology Committee seem to be out of touch with the concerns of ordinary people and parents as 93 per cent of UK citizens believe that chemicals negatively affect their health. Surely it is reasonable to expect a legal requirement to substitute particularly nasty chemicals with safer substances where possible."

Specific policy points

Safer chemical substitutes
WWF considers that the availability of a safer chemical substitute should by itself be grounds for refusing a chemical authorisation for use. Therefore WWF disagrees with the committee's findings that REACH should not bring in mandatory substitution for the chemicals of high concern.

WWF believes that it is unwise to think that market mechanisms will ensure that chemicals of high concern are replaced. Using a demand based market mechanism is not sufficient because it may be difficult for a new entrant to capture enough of the market given the likely higher costs of newly developed 'safer chemicals' as compared to older dirty chemicals which have long ago offset their research and development costs.

Chemicals of high concern
WWF considers that a chemical of high concern should only be authorised for use when there is an over-riding societal need for that chemical, and no safer alternatives, and measures to minimise exposures are in place. It is difficult to be sure that chemicals are adequately controlled over their entire life-time therefore substitution of chemicals of high concern is a more robust option.

WWF disagrees with the Committee that provided industry can show 'acceptable control of the risk' they should be able to gain an authorisation to use a chemical of high concern. Past experiences with the current assessment process has exposed difficulties in showing that a particular chemical presents an unacceptable risk. This has led to inaction and has been an obstacle to finding a safer way of doing business.

However, WWF is encouraged by the conclusion that 'adequate control' of chemicals of high concern must mean that the risks of exposure to humans or the environment to the chemical are remote.

WWF agrees with the committee that when a chemical of high concern is authorised industry should deliver a substitution plan showing how they will phase out its use over time

Registration of chemicals
The Science and Technology Committee support, along with WWF, a pre-registration phase for all chemicals and moreover conclude that volume should form the basis for prioritising the order in which chemicals go through the registration regime. However, the Committee goes on to propose an additional layer of analysis - exposure data coupled with preliminary and existing toxicity data - to further determine the order in which chemicals are queued into the registration process . WWF does not agree, because under REACH, chemicals of lower concern have less onerous testing requirements anyway, and such a modification could give rise to administration problems and legal challenges.

WWF supports a pre-registration phase, primarily to ensure mandatory data sharing.

WWF believes that all registration dossiers should be independently audited therefore WWF disagrees with the committee who suggest a programme of spot checks.

On the issue of one registration per chemical the Science and Technology Committee's view contradicts both the UK Government's and WWF's position. The committee considers that it is 'untenable' to make it a legal requirement for the formation of consortia to prepare joint registrations; they believe that this should only be encouraged. DEFRA has consulted lawyers on this issue, and the legal requirement proposal is gaining support within the European Union.

The WWF Chemicals and Health Campaign
WWF is calling for the phase out of two classes of chemicals - those that are very persistent and very bioaccumulative (VPVB) and those that can disrupt our hormone systems (EDCs).

Over 60 top EU scientists have already signed a Declaration urging the need for action to substitute endocrine disrupting chemicals and chemicals that accumulate in living tissues for safer alternatives. By testing blood WWF has shown that people across the UK and Europe are contaminated with a cocktail of highly toxic man made chemicals.