This post follows on from the one last week about the four new SVHCs, which discussed technical compliance with the substances holding SVHC designation.
Last week we covered these facts about SVHCs (Substances of Very High Concern):
- This is a designation brought in under REACH
- Some SVHCs are Authorised, that is requiring an extra permission to be used in the EU, with a view to them being banned
- Some SVHCs are due to be considered for Authorisation
- Others have been considered and have not been Authorised, but have been retained on the Candidate List (where SVHCs are held)
- ECHA runs the process on behalf of the European Commission
What I want to discuss in this second post is the question “Is the SVHC and Authorisation process a good thing as a whole?”
It is clear that the SVHC and Authorisation is a heavily politicised process.There are numerous points where the public, and especially the NGOs (Non Governmental Organisations, i.e. charities and lobby groups) can comment.And boy, do they comment!
For example, the International Chemical Secretariat, ChemSec, based in Sweden, run the SIN List, the Substitute It Now list (for those of us with long memories, it was originally “Stop It Now”)..
Their website states: “All ChemSec’s work aims to speed up the transition to a world free of hazardous chemicals”.
The SIN List is a full list of chemicals which would attract the SVHC designation currently on the EU marketplace.In effect, they have taken ECHA’s own SVHC criteria, and applied them to every chemical they can find which meets those criteria.
Their website looks official.The SIN list sounds official.They make some big claims about being taken seriously, and some companies do take the SIN list seriously, and won’t have SIN list chemicals in their inventory.
But ChemSec was originally founded by WWF Sweden and Friends of the Earth Sweden.They’re not official, they’re not regulators, they’re campaigning NGOs with a political agenda to remove all hazardous chemicals from the world, as per their quote above.
And the SIN list is just their own “wish list” of chemicals they’d like to see banned in the EU.
By the way, their SIN List criterion isn’t based on a close understanding of what these chemicals are need for, or why they may be useful.It isn’t because there have been major scandals about poisonings or industrial incidents.It’s simply based on the intrinsic hazards of the chemicals themselves.
Yet the whole point about hazards, that is the dangers from chemicals, is that this does not describe risk.
Risk = hazard x exposure is a simple way of capturing this idea.
If you have a very hazardous chemical which is handled entirely in sealed systems and then fully reacted into a much less hazardous product, the risk to human health may be significantly lower than from a hazardous product which is handled and dispersed more widely.
The SVHC process at ECHA allows risk assessment to be made, but in the juvenile world of the NGOs, hazardous = bad = ban it, regardless of the consequences.
Another quote from ChemSec’s website
“ChemSec – the International Chemical Secretariat – is an independent non-profit organisation that advocates for substitution of toxic chemicals to safer alternatives. We do this because these substances represent one of the biggest and most serious threats to our health and environment.”
So let’s examine this claim in a bit more detail, shall we?
This reads as if these people truly believe that cancer caused by chemicals is more important than the benefits from using chemicals, which include:
- Clean drinking water
- Reliable sewage treatment to keep water clean for drinking and for the environment
- Secure reliable agricultural food supply through the judicious use of:
- Veterinary medicines
- Modern transport to ensure:
- Safe movement of goods and people around the world, and within individual countries (rail, sea, air, road)
- Cleaning chemicals to ensure
- Hospitals and doctors surgeries are clean
- Abattoirs and food factories are clean
- Restaurants are clean
- Domestic kitchens are clean
- Metallurgical chemicals and metal treatment chemicals so that
- We can have modern metals and machine tools
- Surgical instruments for operations
- Many different metal objects and machines, such as fridges and washing machines, laptops and TVs
- Chemicals like cement and tar, so we can make concrete and build houses, bridges and roads safely
- Semiconductors, which need Hydrofluoric acid to etch them, which are the foundation of modern communications
- Textile treatment chemicals which allow us to spin and weave very fine materials for use in:
- Fishing nets
- Special applications such as surgical dressings
- Colour chemicals which are not just used in fashion items such as clothing, hair dyes and cosmetics, home décor etc, but also for:
- Safety signs and markings on roads, in factories and in other hazardous situations
- Dyes for staining microscope slides to show up biological materials for identifying pathogens, plant and animal species
- Colour coding to ensure peoples’ safety in a variety of ways, such as partially sighted people being able to tell the difference between the floor, walls and worksurfaces in a kitchen; or colour coding of different phamaceuticals so sick people take their pills on the correct day
- Plastics which go into so many things we use every day:
- Laptops and iPads
- Mobile phones
- Cars, planes and trains
- Domestic appliances
- Industrial plant and equipment
- Surgical instruments
- Food containers
(On a side note, I’d like to see the people who fund, and work for, the International Chemical Secretariat follow their own advice for a year.Let them go to an island and remove all those toxic chemicals they’re so worried about.They’ll have to dig a well for water, have latrines, hunt, fish and grow their own food, try to keep it fresh or preserve it somehow, deal with their illnesses safely etc.And no modern devices like smart phones, of course.I doubt they’d last a year, the authorities would probably have to rescue survivors after a few weeks.But it’d make great television, “Chemical Free Island”, perhaps? (with thanks to my friend Sam for the TV idea!)).
The action of the NGOs indicate that they believe that hazardous chemicals can be removed from western life, and substituted with low or no hazard chemicals.
It is true that some chemicals, such as solvents, can be replaced by lower-hazard materials.
However, this seems to be being driven as much by the change from CHIP to CLP, at least as much as it is by the SVHC process.(For example, if a product label suddenly has 4 symbols when before it had 2 symbols, people will often want to make changes to reduce the perceived hazard, even though the product is exactly the same as it was before).
And the approach of ChemSec to banning things simply because they are toxic ignores a very important point about why we use hazardous chemicals in the first place.
We often use chemicals because of their hazardous properties, not in spite of them.Reactivity, toxicity, ecotoxicity, flammability and explosivity are all desirable functions in the correct context, for example.
- If you’ve ever taken an antibiotic for an infection, you’ve killed millions of pathogenic bacteria in your own body
- Toxic chemicals are often used as chemotherapy agents, giving a low dose to try to destroy cancer and allow the patient to live
- Hydrofluoric acid is a very hazardous substance – but without it, there would be no silicon chips, and therefore no mobile phones, or tablets, or even laptops
The ChemSec mindset also fails to recognise that many low or no hazard products are made by reacting hazardous chemicals together, so we may need “nasty chemicals” in order to make “nice chemicals”.
There is also a world of difference between a substance being used inside the well-regulated European chemical industry, and being available to the general public.
Surely there should be some recognition of the fact that we have the tightest health and safety and environmental standards in the world, and that hazardous chemicals can be handled in a safe way by industry which should not be allowed to be used by consumers.
Another problem with the ChemSec approach is that it does not appreciate the steps which have already been taken by industry in Europe, the USA and other developed countries to try to substitute hazardous chemicals with less hazardous ones.Under COSHH, for example, there has been a push towards substitution of hazardous chemicals long before REACH came into force.
What has been found is that, in some instances, chemicals are needed because they can do a specific job much better than any alternative, in fact there may even be no alternative.
If we are to continue to use natural rubber, then toluene is by far and away the best carrier for rubber particles, which in turn are required to make high-pressure and high-temperature gaskets and seals used in the high hazard industries such as oil and nuclear (I know about this because one of my clients makes these types of gasket).
ChemSec’s attitude is that it is possible to substitute all hazardous chemicals with less hazardous ones, but that’s just as realistic as believing in a magic money tree (although all their work is funded through grants, so maybe they believe in that, too).
NGOs seem to think there is a magic chemicals tree, where non hazardous chemicals can be found to replace all the hazardous ones, and work just as effectively.
If we are using hazardous chemicals because of their hazardous properties, then you can’t replace them with non-hazardous chemicals, because they won’t work.
And you can’t just design chemicals.It may be possible to try to model their effects, but in industry, chemicals are often discovered, rather than conceived and then “built”.
- there’s a new type of blue pigment which was discovered by accident, see https://www.youtube.com/watch?v=EdNXytuJpxA&t=18s , which is very reminiscent of how Perkin discovered mauveine, see https://en.wikipedia.org/wiki/Mauveine
- the process for finding a new herbicide (which I’ve seen when I visited Rhone Poulenc’s agricultural site back in the 1990s) is simply taking as many chemicals as you can find, putting them onto young plants, and seeing what has an effect
- and pharmaceutical research is called “drug discovery” for a reason
There is no “magic chemicals tree”, and the fact that ChemSec appears to think it’s possible to remove toxic chemicals from society without fundamentally altering the way we live (and not in a good way) is very worrying, considering the amount of influence they seem to have.
Not only is there no “magic chemicals tree”, but this quest to prioritise novel chemicals may come back to bite people. In my opinion, it can be more risky to stop using a hazardous material which is well understood, to go with a novel chemical which is poorly understood.
What will happen if the novel chemical turns out to be more hazardous than originally thought?
Or what if substitution is proposed with a more hazardous chemical, as has been suggested for sunblock, where Titanium Dioxide (non hazardous under CLP currently) would be replaced with Zinc Oxide (hazardous under CLP).
While the SVHC process continues, it’s certainly going to have an effect on the European chemical industry.
For starters, it’s incredibly bureaucratic and time-consuming, which is one reason why people are steering away from using SVHCs on the Candidate List.
It’s also very expensive if you have an essential raw material which ends up being Authorised, and you have no choice but to apply for an Authorisation.
The overall impact of the SVHC process is tending to push chemical use out of the EU and into China, India, Vietnam etc.
Purely from the European perspective, this makes the environment in Europe potentially safer. But what is going to happen to people and the environment where these chemicals will be made and used instead?
The health and safety standards in these countries are nowhere near as high as in Europe, and their environmental standards are often low to non-existent.The amount of plastic in rivers demonstrates this clearly: https://www.scientificamerican.com/article/stemming-the-plastic-tide-10-rivers-contribute-most-of-the-plastic-in-the-oceans/ .
The SVHC process isn’t removing chemicals from use globally, it’s simply offshoring them from a very well-regulated environment, where workers are protected and the environment is kept as clean as possible, to countries where life is cheap, and the environment is just a convenient way of disposing of industrial waste.
This is not making the world a safer place.
It’s making it more dangerous for people in poorer, less developed countries.
It’s moving the problem, not solving it.
The NGOs like ChemSec don’t seem to understand this, or if they do, they don’t seem to care.
There is another way in which the SVHC process is dangerous, which is about the ability of the European chemical industry to respond to future crises.
We do not know where the next wonder drug for curing cancer is coming from, or a chemical needed to provide a vaccine against an epidemic.Because of this unknown, we also do not know what raw materials will be required to make said wonder drugs.
It is surely more important for public health to ensure a vibrant chemical industry with as many chemicals available on the market as possible, than to ban substances on the basis of hazard rather than risk.
And it is dangerous, in my view, to rely on other countries to provide all our goods, medicines etc, because in a crisis, they will surely prioritise their own people, rather than continuing to sell on the open market.
So if we were to stop the SVHC process, what should we do instead?
Most, if not all, of the genuinely beneficial impacts of the SVHC process revolve around preventing dangerous substances being used by consumers, or in a widespread way.
These could easily be handled under the Restriction process, which is legally enforceable, and pre-dates REACH.It would allow useful hazardous chemicals to be retained on the industrial market, while prohibiting their use to consumers.
Nobody in the chemical industry sets out to harm people, on the contrary we try to use chemicals so society can benefit from them, while minimising the downsides.
In my opinion, the SVHC process is not a good thing, and needs to be rethought, or scrapped, urgently.
GHS Classification Courses from TT Environmental Ltd
12th August 2019
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