In October 2020, the European Commission published a Chemicals Strategy for Sustainability, which aims to reduce human and environmental exposure to hazardous chemicals, while enhancing the competitiveness and innovation of European industry. This strategy, adopted by the European Parliament in July 2020, responds to the “Zero Pollution” ambition of the Green Pact for Europe.

The project is facing some opponents, including senior members of the German Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung or Bfr), who argue that the toxicological risks of chemicals have already been minimized and are optimally regulated by the European Union.

In an article published on January 5, 2023, Erik Millstone, professor emeritus of science policy at the University of Sussex, and Peter Clausing, toxicologist and administrator of Justice Pesticides, explain the reasons for reinforcing the European Union’s regulation of chemicals, even though it is the most advanced in the world, based on the presentation of its limitations and on their intention to prioritize the protection of public health and the environment over commercial interests.

The limits contained in the current regulation are, for example :

(i) Taking into account the possible combination effects between multiple chemicals in the risk assessment. This assessment is limited to the cumulative effects of oral exposure to pesticides on only two endpoints, namely acute effects on the nervous system and chronic effects on the thyroid. In addition, combination effects under different routes of exposure (e.g., inhalation and/or dermal) and chemicals other than pesticides/biocides are not yet included.

(ii) The large uncertainties about the validity of extrapolative inferences from animal studies to human risks.

As they point out, “Chemical risk assessment policy decision-making operates in a contestable and often contested space because different groups of stakeholders have different and often conflicting interests”. And, the commercial interests that most guide chemical risk assessment policy today like to pretend to act in accordance with scientific considerations, when in fact they are value-judgmental, as the study criticized here from the German Federal Institute for Risk Assessment illustrates.

Their article, by crossing the views of the philosopher and the toxicologist, participates in the challenge of transforming the promises of the European Commission into real legislative changes.

Justice Pesticides

Support for the European Commission’s Draft (2020) Chemicals Strategy for Sustainability