WITHIN THE EUROPEAN UNION
Within the context of the commitments made in international and regional fora, the European Union has a wide latitude to act in dealing with the threats posed
by Endocrine Disrupting Chemicals (EDCs). In view of the transboundary movements of EDCs, which can be carried by air, along rivers and ocean currents and in
animals as part of the food chain, and in products, this issue clearly needs to be addressed at European Union level, as well as by the EU Member States.
A considerable amount of EU legislation relevant to these areas has already been passed, for example Directives on water quality and hazardous substances.
WWF recommends therefore that the European Union should take the following actions:
- 1. General
- A. The European Union should recognise EDCs as a danger to human and wildlife health and, based on the precautionary principle, should take
appropriate actions to reduce the use of EDCs and to educate European consumers.
The precautionary principle states that action should be taken to avoid potentially damaging impacts of substances that are persistent, toxic and liable to
bioaccumulate even where there is no scientific evidence to prove a causal link between emissions and effects.
- B. The Union should ensure implementation at national and European level, as appropriate, the relevant international Treaties and commitments made in
international forums regarding preventative action on EDCs, such as OSPAR, the North Sea Conference and the Barcelona and Helsinki Conventions.
- 2. Existing Legislation
- C. All existing EU legislation should be reviewed for its content in addressing EDCs - ie a "horizontal review" of all Directives with EDC
implications. To achieve this the European Commission should prepare a timetable and budget for a phased approach to this task for implementation as soon as
possible with completion by the year 2000.
- D. The European Commission should establish an EDCs Unit to coordinate actions across the different legislative sectors of agriculture, environment,
fisheries, industry, research, consumers, public health and others.
- E. On the basis of the review the European Commission should amend its current legislation, again on a phased, timetabled approach to reduce the
release of EDCs into the environment and to reduce the risk to human and wildlife health, for this and future generations.
- 3. New EU Legislation - General Principles
- WWF proposes the following general principles for new EU legislation:
- F. The European Commission should prepare internal guidelines of a horizontal nature to ensure that in drafting any new legislation the threats posed
by EDCs are addressed.
- G. The burden of proof should be shifted to chemical manufacturers. Risk assessment should be re-defined as a methodology for keeping untested
chemicals off the market - and of eliminating the chemicals of most concern in an orderly and timely fashion, instead of keeping questionable chemicals on the
market until they are proved to be harmful.
- H. The emphasis should be on prevention of exposure to EDCs for both human and wildlife populations.
- I. The interactions among compounds (synergistic efforts) should be considered and not just the effects of each chemical individually.
- J. Account should be taken of cumulative exposure from different sources for example air, water and food.
- K. Standards should be set to protect vulnerable organisms and life stages, paying particular attention to endangered species and their habitats.
Standards should also be set which protect the most vulnerable such as children and women of child bearing age.
- L. Producers and manufacturers of food, of consumer goods and of other potential sources of exposure, should be required to monitor their products
for contamination.
- M. The fullest possible information should be made available to citizens, while preserving any real need for commercial confidentiality, based on the
citizens right to know, and their right to choose to protect themselves against undesired exposures. The exchange of information between researchers, business,
state authorities and NGOs must be ensured. In addition, product registers for the national markets should be established to support priority-setting for the
assessment and reduction of exp osure to EDCs.
- 4. New EU legislation - Specific Recommendations
- N. The focus of new legislation should be on two areas:
- Consumer awareness and education coupled with the citizen's right to know.
- Policies relating to pesticides and other chemicals especially registration and control.
- Specific activities with respect to each of these headings are:
- N.1. Consumer Awareness/Education/Right to Know
- The EU should:
- N.1.1 Establish a pollutant release and transfer register (PRTR) across the Union including toxic chemicals in products as per the OECD Guidance.
- N.1.2 Ensure adequate labelling of toxic chemicals in products.
- N.1.3 Ensure that the levels of contamination of fish are regularly monitored by the appropriate authorities and that the public is informed.
- N.1.4 Inform consumers of the risks of using certain plastics in contact with food and advise on how to minimise these contacts.
- N.1.5 Inform consumers, and particularly those at highest risk such as children and women of childbearing years, on consumption levels of natural products with high risk from pesticides.
- N.1.6 Ensure the chemical content of drinking water is regularly monitored and that the public is informed.
- N.1.7 Take steps to require mandatory public information regarding use of pesticides in the urban and rural environment.
- N.1.8 Ensure the generation of product (not substance) registers for the national markets in order to support priority setting for the assessment and
reduction of the exposure to EDCs.
- N.2. Pesticides and Other Chemicals
- The EU should:
- N.2.1 Implement Pesticide Reduction Programmes in all Member States.
- N.2.2 Improve the testing requirements for pesticides as well as for existing and new chemicals under Directives 91/414/EEC and 79/831/EEC to include
assays for steroidogenic, thyroid and other endocrine related effects.
- N.2.3 Promote standardisation and international harmonisation of tests for steroidogenic, thyroid and other endocrine related effects.
- N.2.4 Speed up the implementation of the EU programme on existing hazardous substances and ensure systematic screening of pesticides and industrial
chemicals to identify EDCs and quantify their specific activity.
- N.2.5 Introduce an authorisation scheme for industrial chemicals, parallel to the regulation of pesticides, leading to the establishment of
positive lists of approved chemicals.
- N.2.6 Ensure the comprehensive phase out of all pesticides classified as Persistent Organic Pollutants (POP) under the various legal instruments to
control POPs and ensure that EDCs are not substituted for the POPs when they are phased out.
- N.2.7 Undertake a critical analysis of the use of the newer generation pesticides in current use, including hazard and risk assessment and phase out
those with EDC properties by priority.
- N.2.8 Amend labelling regulations to ensure that all ingredients (active and inert) not being classified completely are labelled as "non-tested"
("not assessed"). Packaging should not be subject to confidentiality or if there is genuine confidentiality to ensure that the label shows the ingredients to be
"toxic".
- N.2.9 Implement OECD recommendations on "heavy metals".
- N.2.10 Phase out the use of phthalates, nonyl phenols and bisphenol A; ensure that consumers are aware of the dangers of plasticisers.
- 5. The Global Research Effort
- O. The European Union is an extremely powerful force within the developed world and the world in general. Therefore the EU should take the lead in
the global effort in identifying solutions for minimising the impact of EDC now and in future generations. The EU should support the call for an immediate and
independent global research effort, and one that is open and transparent. Further, the EU should provide sufficient financial support for this research effort,
and encourage significant donations from European industry.
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