Last week CHEM Trust submitted a response to the UK Government’s consultation on their revised UK Marine Strategy Part 1. The response details our concerns that the strategy provides a limited and misleading assessment of hazardous chemicals in UK marine waters.
The problem of Marine pollution
Numerous hazardous, man-made chemicals contaminate the marine environment and have adverse effects on marine wildlife. These include many flame retardant chemicals, some per- and polyfluoroalkyl substances (PFAS), phthalates, parabens, UV filters and bisphenols. PFAS are known as ‘forever chemicals’ due to their extreme persistence, and have a negative impact on marine mammals.
Other chemicals such as pharmaceuticals and pesticides have been found in UK rivers and estuaries, which lead to the marine environment. Some pharmaceuticals with hormone disrupting properties have been linked to the feminisation of male fish.
Lessons from the past
Marine sediment is also highly contaminated with the toxic and persistent Polychlorinated Biphenyls (PCBs), which are almost impossible to remove. PCBs, which were used in industrial transformers and building products, were largely phased out in the 1980s and are now subject to a global ban, but continue to pollute the marine environment due to their persistence. They cause reproductive problems in wildlife and are threatening the survival of the UK’s killer whale population, which has not had a calf for over 20 years.
This inability to resolve historic contamination from PCBs emphasises the need to act swiftly now to reduce the pollution from other highly persistent chemicals, such as PFAS, to reduce the likelihood of similar situations developing in the future.
An insufficient approach
The UK Government’s current approach to dealing with this chemical pollution, outlined in the UK Marine Strategy, is insufficient.
The Strategy explains how the UK will implement the EU’s Marine Strategy Framework Directive. This Directive calls for EU member states to put in place measures to achieve ‘Good Environmental Status’ in their marine waters by 2020. This is defined as:
“The environmental status of marine waters where these provide ecologically diverse and dynamic oceans and seas which are clean, healthy and productive”
Alongside the revised strategy, the UK Government published an updated assessment of their progress towards GES for 15 key descriptors, such as contaminants (including chemical pollution), marine litter, and biological diversity.
The assessment provides a worrying picture of the state of UK seas, as 11 of the 15 descriptors will not reach Good Environmental Status by 2020.
Surprisingly, contaminants is one of the 4 descriptors for which the UK Government states that good status has been ‘largely achieved’. CHEM Trust’s analysis is that this conclusion is misleading for a number of reasons:
- The list of chemical pollutants monitored in territorial waters is extremely short. In addition to metals and polycyclic aromatic hydrocarbons (PAHs), only two groups of man-made chemicals were assessed: polychlorinated biphenyls (PCBs) and polybrominated diphenyl ethers (PBDEs). This does not reflect the full range of chemical substances that pollute UK marine waters, such as those listed above. If you don’t look, then you won’t find.
- There is a lack of monitoring data for many biogeographic regions, meaning that some pollutants could not be assessed in all UK regions. For example, only 4 out of 8 UK biogeographic regions had sufficient data to be assessed for PAHs in biota. It was also not possible to determine if the target set out in the strategy for PBDEs in biota and sediment had been met, due to a lack of assessment criteria.
- Historic PCB contamination will continue to be a problem in the marine environment, as the UK Government will not remove contaminated sediment for ‘technical and financial reasons’.
What about Brexit?
Despite stating numerous links between the UK Marine Strategy and pieces of EU legislation, such as the Water Framework Directive, the strategy makes no reference to the UK’s likely departure from the EU.
Given these links to crucial EU environmental directives, we are deeply concerned by the lack of information from the Government on how Good Environmental Status will be achieved and maintained for chemical pollutants post-Brexit.
Although the UK has committed to copy-across EU environmental laws, they have not made any commitment to improve these laws as the EU does (known as ‘dynamic alignment’.
Our recommendations for protecting UK seas from chemical pollutants
In our submission we make set of recommendations for the UK Government, including asking that it:
- Extend the list of chemical pollutants monitored in territorial waters;
- Create a clear process to identify emerging chemicals of concern;
- Formulate a clear process to revise safety thresholds as new evidence emerges, and to deal with non-threshold substances;
- Set clear targets to reduce the production and emission of chemical pollutants;
- Clarify its post-Brexit plans.
CHEM Trust would also like the Government to correct their assessment that Good Environmental Status has been ‘largely achieved’ for contaminants, and ensure it reflects the real state of chemical pollutants in UK seas.
Dr Julie Schneider, campaigner at CHEM Trust, said:
‘Invisible chemical pollution is damaging the balance of the ocean’s ecosystems, such as the long-lived chemicals PCBs which are still threatening the survival of orca populations around the UK decades after being banned. Many more of these long-lived, poorly degradable chemicals are still being produced, in spite of their lasting impact on the marine environment. The Marine Strategy should call for urgent action to take such chemicals off the market to protect marine wildlife and human health.’
Working with other environmental NGOs through Wildlife and Countryside LINK
CHEM Trust has also submitted comments to the consultation in collaboration with Wildlife and Countryside LINK, a coalition of over 50 wildlife and environment NGOs including CHEM Trust. Find out more about LINK here.
CHEM Trust’s Dr Julie Schneider wrote a guest blog for LINK, ‘The battle of contaminated UK seas has not yet been won’, which outlines the reality of the state of UK marine waters.