The International Council of Chemical Associations (ICCA) is calling for the UN Environment Programme to withdraw, or significantly revise, its draft review of lists of chemicals that are recognised as, or suggested to be, endocrine disrupting chemicals.
Unep’s draft assesses 24 existing EDC lists, and suggests 77 substances warrant further scrutiny, based on their inclusion in the following:
- the REACH candidate list;
- the Danish EPA list of EDCs; and
- the Substitute It Now (SIN) List, compiled by the NGO ChemSec.
In a statement prepared for submission to the public consultation on the review, the ICCA says the use of lists to identify EDCs and potential EDCs is problematic as they “lack scientific reliability and robustness”.
“Using these lists to select 77 chemicals for subsequent overview reports gives the illusion of certainty on the designation of these substances,” it adds.
This designation, the statement reads, exceeds the current state of the science and outpaces regulatory decisions on these substances. “Organisations that develop these lists seldom have access to the full breadth of toxicological data that are needed to adequately assess the endocrine-disrupting potential of these materials,” it says.
Further criticisms of the lists include:
- the lack of a "standardised approach to evaluate data quality"; and
- they do not require a weight-of-evidence analysis, which takes into account the number of studies that indicate whether a chemical is, or isn't, an EDC.
The trade body says that the list of 77 substances would risk providing distorted or biased information. It could also potentially “retard rather than advance scientific understanding”.
In a separate statement, the ACC, a member of the ICCA, says it is “surprised and concerned” by Unep’s commissioned report. “Lists often carry a veneer of authority that masks the capricious and unscientific process by which they are created and which allows organisations to parade them around as science,” it says.
The ACC “urges the immediate withdrawal” of the draft report, including its removal from Unep’s website.
Peter Smith, executive director of Cefic, also a member of the ICCA, told Chemical Watch that the most helpful step would be to "focus on building capacity in the target countries in the areas of risk assessment and the risk management of chemicals”.
“There is so much regulatory-related work still ongoing in developing countries, and the debate about the science [on EDCs] is continuing.” Capacity building, he says, will ensure that chemicals are used correctly and handled safely at all times.
According to the ICCA, the idea of developing a list of EDCs was considered and explicitly rejected by delegates, at last year’s UN chemicals summit (ICCM4).
The trade body says "the majority of stakeholders at the conference recognised that, in the absence of robust, credible evaluations of hazard and exposure, the compilation of a list would likely be inaccurate."
“It is difficult to understand why stakeholders should have invested the time and effort to produce a consensus outcome at [the conference], when Unep has since gone on to provide active support to the development of a report that purports to do exactly what Saicm stakeholders did not support.”
However, Joe Digangi, senior science and technical adviser at NGO Ipen, says the Unep report is responding to calls from more than 140 countries to identify EDCs.
He says that during the round of regional meetings preceding ICCM4, three UN regions - Africa, Asia-Pacific and Latin America - passed resolutions on EDCs that called on Unep and the WHO to “identify priority endocrine disrupting chemicals”.
And, at ICCM4, 15 countries, plus NGOs PAN and Ipen, submitted a conference room paper (CRP) that called for Unep to “compile a list of EDCs and potential EDCs,” he says. This was proposed through a draft but not included in the final resolution on the substances.
It is, however, included in the final ICCM4 report, which records issues raised and discussed at the conference.
In addition, Resolution IV/2, which includes actions to take forward on emerging policy issues, invites the “implementation of a plan of work” on EDCs, developed by Unep, the World Health Organisation and the OECD.
Under this workplan, Unep is tasked with compiling and disseminating overview reports. These will “focus on existing scientific knowledge of environmental exposure and impact, legislation, measures and gaps regarding known and selected potential EDCs (especially information from developing and transition countries) by 2017,” the workplan states.
Unep’s head of chemicals and waste branch, Achim Halpaap, told Chemical Watch that analysing and sharing already established lists of EDCs at the global level, is an exercise to disseminate information, consistent with "the work plan supported by ICCM4".
“Information sharing and analysis, rather than preparing a single global list of EDCs, is the main intention of these reports,” said Mr Halpaap . Further consultations with governments and stakeholders are planned to achieve this objective, he added.
In March, Unep commissioned the International Panel on Chemical Pollution (IPCP), a network of scientists, to develop five reports that give an overview of scientific knowledge, regarding environmental exposure and associated effects of the substances.
Unep has extended the consultation period on the draft review until 20 September.