We very much welcome this inquiry, as the main chemical exposures for humans and wildlife come from emissions from everyday products, such as furniture and food packaging. Some of these exposures come from chemicals that are still being used, others come from chemicals which have been banned but are still present in products in our homes, or from persistent pollution of the environment.
Our overarching message to the inquiry – as spelled out in our written submission – is that there needs to be faster, more protective and more comprehensive regulation of chemicals at UK, EU and at International levels in order to protect ourselves, wildlife and future generations from hazardous chemicals.
This message was also echoed in the inquiry’s first evidence session which heard from four UK Ecotoxicologists who sit on the UK Government’s Hazardous Substances Advisory Committee and advise Government on substances which have the potential to harm human health and the environment.
Thousands of chemicals in use
The inquiry heard from the scientists about the huge challenge of there being 1000s of man-made chemicals used in everyday products.
Professor Sumpter, from Brunel University, said in his evidence:
“There is a huge number of chemicals in use. Most of them are in the environment and many of them are in you and me, to start there. As far as which chemicals should we be most concerned about, the simple answer is we don’t really know. ……….
Then we try to regulate things like PCBs but while we are regulating those, you might think that perhaps with these persistent chemicals new ones are not appearing, but they are and I will give you a quick example. If you use a frying pan today, it is probably coated with Teflon. It is a chemical, a so-called PFA[S]. It is one of the toughest chemicals ever produced. It does not degrade in the environment, it is absolutely everywhere, albatrosses are full of it and that sort of thing. We are trying to restrict that but in the meantime over 1,000 other similar chemicals have been patented and many of them are still in use. We are still putting into the environment large numbers of pretty much unidentified, highly persistent chemicals.
That is where we are, which makes it almost impossible to answer questions like: what should we be most concerned about? I wish I could.”
In addition to the challenges of gathering information on 1000s of man-made chemicals there is the problem that during a life-span humans and wildlife are exposed to multiple chemicals. The Committee heard that this leads to an incredibly complex picture of chemical and species interactions in different environments.
Professor Depledge, Emeritus Professor, at the University of Exeter Medical School said:
“The kind of question that we might pose is what kind of chemical environment are we willing to live in in the coming years, by 2030, by 2040. At the moment we all have a vast array of chemicals in our blood and our tissues, as do organisms in the environment.
Evidence emerges that these are giving rise to all kinds of problems with different chemicals, different mixes for different species in different environments. It is a very complex area, but if you were to say that we wanted to do something about it one of the challenges is to try to define a chemical environment that we would find acceptable to live in. Once we have done that, we need to develop policies that will take us to that place.”
As we pointed out in our recent blog, researchers have found that even at real life concentrations, mixtures of hormone disrupting chemicals interfere with brain development and growth through impacts on the thyroid hormones which are essential for brain development.
Regrettable substitution and grouping
Another significant problem that the EAC wanted to explore was the issue of regrettable substitution. This is where a chemical that has found to be harmful is replaced by a closely-related chemical which has not been regulated yet but later turns out to be similarly harmful. The example of the bisphenols was given by Professor Galloway from Exeter University.
She told the committee:
“We identified that there were harmful health consequences of being exposed to bisphenol A sufficient to warrant a reduction in the tolerable daily limit that you are allowed to be exposed to.
Lots of companies switched from bisphenol A to a highly related compound called bisphenol S to satisfy that this is a bisphenol A-free item, but bisphenol S has very similar toxicological properties to bisphenol A. ………As you say, it was a regrettable substitution before the full toxicological profile could be assessed.”
Professor Sumpter referred to the fact that the regulators are “firefighting”, while Professor Johnson from the Centre for Ecology and Hydrology warned that continual vigilance is needed to address this issue. The replacement chemical may even be worse than the original chemical which has been banned. And Mary Creagh MP, Chair of the Committee, referred to this approach as:
“The regulatory approach is a whack-a-mole. One pops up, whack it; another one pops up, the same thing.”
CHEM Trust highlighted the issue of regrettable substitution in the report “From BPA to BPZ: a toxic soup?” which we released in March 2018. One of the recommendations we put forward to address the issue of regrettable substitution is to take a ‘grouping” approach to regulating chemicals of similar structure.
Impact of Brexit on chemical regulation in the UK
The Committee were also keen to hear views from the scientists on the impact of the UK leaving the European Union (EU) and the EU-wide chemical regulation REACH.
Professor Depledge said:
“From my point of view, to follow the EU standards is probably an extremely wise idea for the UK to continue to do. ……but if the UK were to try to set up a similar organisation to ECHA or the European Environment Agency on that scale, I think we would struggle tremendously”.
The Committee expressed its own concern that when the UK leaves the EU the new UK chemical regulator would not replicate the technical and stakeholder committees that feed in to current EU chemical regulation.
Professor Johnson advised that :
“any new organisation must be credible from the start and must have as much popular support as possible at the beginning. I would perhaps take a view similar to yourselves that as much influence as possible from external bodies and a range of experts who are allowed to play a role is really important. We do not want to get off to the wrong start should such an agency be formed. It should be as open as possible, as transparent as possible and take as much advice as possible.”
CHEM Trust has also raised the issue of a lack of stakeholder involvement in the government’s plans for a no-deal Brexit, and in our view the UK should aim to stay as close as possible to REACH. We consider that any new regulatory system would be expensive to create and would be very unlikely to provide the same level of protection of public and the environment.
More to come…
During the inquiry the committee is also investigating the way that UK fire regulations lead to the use of large volumes of flame retardant chemicals in UK furnishings. We will write more about this in a future blog, but in the meantime you can read the oral evidence given by two witnesses – Gareth Simkins – who has covered this issue as a journalist and Terry Edge – who was a civil servant in the UK government department responsible for fire safety regulations.