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The EU Eco-label and Health 6 Improving the coverage of health aspects
6.1 Strengthening health aspects in the methodology of criteria developmentBased on an analysis of the criteria documents for the chemical products selected, it is obvious that the criteria for the health aspects covered in general are more stringent than the requirements of the related chemicals legislation. On the other hand, should health aspects in future be given a higher emphasis in a revised regulation, health should be seen in a life cycle perspective in line with environmental loads. The assessment of health impacts should cover health aspects related to consumers as well of workers environment. The experience of including health in life cycle assessments is, however, limited. Although the ISO standard for life cycle inventories includes two impact categories regarding health (human toxicity and occupational health), only two published methods include health aspects /13, 14 / and very often these aspects are excluded during the initial process of system definition. Based on the indicative assessment matrix for life cycle inventory (Annex 1 of the Regulation) and the ISO principles of LCA, a tentative matrix for health aspects is outlined in table 6.
Table 7. Tentative indicative assessment matrix for health in an LCA perspective (to be considered for the extension of Annex 1 of the Regulation) For each phase of the product’s life cycle it must be considered which of the dominant exposure routes are relevant: Skin contact, inhalation or ingestion. For the consumer, all three exposure routes are usually relevant. For workers environment only skin contact and inhalation are to be included as ingestion is only relevant in connection with accidents. As the present experience of health life cycle assessments is limited, there is a need for elaboration of a relatively simple approach, which may be further detailed, based on experience from criteria work, the newly established EU Commission IPP LCA platform and from research work. At the moment a number of initiatives are underway. The most important are summarised below /13/
6.2 More stringent health criteria regarding chemical substances ?The analysis of 6 criteria documents indicates varying coverage of health aspects. To basically achieve a more uniform coverage, a health assessment guideline for criteria development should be elaborated. The guideline should include methods of assessment as well as sources for information on international regulation of chemicals. Many of the criteria documents only relate to the EU classification system, which is a well-known and well-harmonized system, for evaluation of the hazardous properties of chemical substances. However, this could be supplemented by references to other official lists of substances, such as:
The scope of the Regulation contains an overall demand that substances which have been classified as acutely toxic or which possess CMR properties according to the EU classification regulations cannot be awarded the Eco-label. In the light of the increased problem with hypersensitivity in the population it seems reasonable that this demand be extended also to include products that are classified as sensitizing. More stringent requirements regarding sensitizing substances should also be considered. It might also be relevant to expand the general demand for the product classification to include products that are classified as harmful to health or at least as harmful to health with risk phrases related to serious or irreversible effects including R48 (Danger of serious damage to health by prolonged exposure) and R68 (Possible risk of irreversible effects). Based on the criteria for indoor paints and varnishes, a theoretical example of more stringent criteria regarding content of chemical substances is outlined in Annex 6. An evaluation has not been carried out of the consequences on the number of products that may be able to obtain the Eco-label. The overall result of the analysis is outlined in Table 7 Table 7 Theoretical outline of higher stringency of criteria for ingredients in indoor paints and varnishes
6.3 A balanced health and environmental scope of the Regulation?The Regulation has been examined in order to suggest amendments to the text to include health aspects on equal terms with environmental aspects. 6.3.1 Purpose and principlesArticle 1 deals with the purpose and principles of the Regulation. Article 1, sections 1 and 2 may be amended as stated in bold in the text box. Article 1, sec. 1 Article 1, sec. 2 6.3.2 ScopeArticle 2 deals with the scope of the Regulation. Regulation articles 1 and 2, sec. 2b and c and sec. 3 are suggested to be adjusted as stated below. Article 2, sec.1 Article 2, sec. 2b and 2c
Article 2, sec.3 Article 2 sec. 4 contains the general demands for classification of products that can obtain the Eco-label. As discussed in the previous section, the health consideration may be strengthened by extending the general demand for classification of products to also include products classified as sensitizing and harmful to health (possibly only certain R-phrases). It is suggested that the Regulation article 2 sec. 4 be changed as stated below: Article 2, sec. 4 When elaborating the general demands for product classification, the basis has been chemical products but it would be possible to cover articles by similar demands, e.g. by adding a demand stating that articles are not allowed to release substances with these classifications. 6.3.3 Environmental requirementsIt is suggested to amend the heading of article 3 ”Environmental requirements” to ”Environmental and health requirements” or ”General requirements”. Article 3 deals with the methodological basis, and as life cycle methods regarding health are at a preliminary step a demand for life cycle based health assessments should be given a relatively high degree of freedom. It is suggested to amend article 3 sec. 1and 2 as indicated in the boxes below. It is anticipated that annex 1a and b may refer to the environmental and health assessment matrix respectively (health matrix as suggested in section 6.1). Article 3 sec. 2a and 2b are suggested to be composed as stated below: Article 3 sec. 1 Article 3, sec. 2
6.3.4 AnnexesAnnex I is suggested to be supplemented by a an assessment matrix regarding health (ref. Section 6.1 of the report). Annex II describes the methodological requirements for establishment of the eco-label criteria. ANNEX II Introduction Life cycle considerations (LCC) Improvement analysis
Proposal of the criteria Annex III describes the design of the Eco-label. As mentioned in section 5.3 there is a need for the phrases to be authored in an easily understandable language. It might be relevant to demand that at least one of the phrases be related to health. Suggestions for amendments and additions to annex III are stated below: ANNEX III Shape of the label Box 2 contains information about the reasons for the award of the eco-label… The information will be in the form of a brief description in words and will be authored in a clear and easily understandable language. No less than one and no more than three phrases will be stated of which at least one shall pertain to health. This is an example:
Fodnoter [3] Carcinogenic, Mutagenic or Repro-toxic [4] Persistent, Bioaccumulative and Toxic [5] Very Persistent or Very Bioaccumulative
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