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Status og perspektiver for kemikalieområdet

Summary

Ch. 1. Introduction

Purpose

The purpose of preparing a discussing paper of the National Agency of Environmental Protection's (Danish EPA) work on chemical substances is to gain an overview of the use of chemical substances, to outline current knowledge of quantities discharged and occurrences in the environment, as well as to describe current efforts and the goals of national and international experts in the field. Another goal is to propose initiatives with special reference to the priorities of future efforts in this area.

Scope

This report covers the parts of the regulation of chemical substances that are within the competency of the Danish EPA.

Definitions

A plethora of concepts and designations is used in the field of chemistry which, if not unambiguous, can cause misunderstandings. The report therefore contains a number of definitions of the concepts and designations used most widely today.

Ch. 2. Use of chemical substances and products

Number of substances and products

It is assumed that about 100,000 chemical substances are marketed at the global level. These substances form components of chemical products (cleaning agents, paints, etc., and pesticides, etc.) and of goods/industrial products (furniture, newspapers, plastic pots, etc.).

Generously estimated, about 20,000 chemical substances, about 100,000 different chemical products and over 200,000 goods/industrial products are marketed in Denmark.

The greatest part of the chemical substances that are used in production and housekeeping, or that are contained in consumer goods, will be discharged into the environment sooner or later, where they can have detrimental effects on the health or environment.

Ch. 3. Discharge into and occurrences in environment

Substances that disturb natural balance

A number of substances cause environmental problems in the air water and soil, as well as in connection with waste. As far as naturally-occurring substances are concerned, such as carbon dioxide, sulphur dioxide and nitrogen, it is not the presence of the substances per se that is responsible for problems in the environment, but the artificially increased quantities that disturb the natural balance thereby causing secondary problems.

A number of actions plans for e.g. the aquatic environment, energy and transport have already examined in detail the problems associated with discharging of these substances and have set targets for the reduction thereof. This group will therefore not be discussed further in this report.

Substances that load the environment

The actual theme is substances that load the environment, understood in part as man­made substances that are alien to the environment and, in part, as naturally­occurring substances, which are spread in inappropriate quantities through man's activities. This latter group includes the heavy metals which, in contrast to most organic substances, are not degraded biologically, photo­chemically or through heat treatment, but which are deposited widely in nature.

Concerning substances that load the environment, the Danish EPA has hitherto concentrated its efforts on the heavy metals, pesticides, substances known to disrupt the atmospheric ozone layer and, to a certain extent, VOCs, PAHs and dioxins. It is therefore not surprising that our body of knowledge of the discharged quantities and occurrences in the environment of these groups of chemical substance is great.

Ch. 4. Current efforts

Four additions

Current efforts towards avoiding pollution and other hazards to public health and the environment due to chemical substances can be classified according to the following basic additions to policy:

a source­oriented addition, where the basic point of departure is that efforts target the various sources that affect the environment. Such sources include, for instance, industrial enterprises, waste water plants, waste incinerators and agriculture;

a medium­oriented addition which, as its basic point of departure, targets the condition of the soil, air, sea, groundwater and fresh water. Depending on the condition of a given medium, a decision is made as to whether an effort is needed ­ for reasons of maintaining or improving the quality of the environment ­ to target the discharges that affect that medium;

a chemicals­oriented addition, where the basic point of departure of the effort is the properties and fate in the environment of the individual chemical substance or group of substances. In this case, efforts include the assessment of hazards and the risk assessment of chemicals, as well as approval schemes and measures for limiting usage;
a product­oriented addition, the basic point of departure of which is that it is only possible to understand the total loading on the environment, and assign priorities accordingly, if the environmental loading due to products is considered over their entire life cycles.

We have many years' experience of the two first additions, which form the foundation of the Environmental Protection Act. Hitherto, the emphasis of the source­oriented and medium­oriented efforts has characteristically been on direct discharges of chemicals into the media soil, air and water. Waste has thus functioned as a safety valve for pollutants, the direct discharge into the environment of which was prohibited. This approach has been replaced today by a better understanding of our environmental problems, with the primary accent on a more prophylactic approach. Cleaner technology, environmental management, green accounting, etc., are typical examples of this.

The chemicals­oriented addition forms the foundation of the Chemical Substances and Products Act ­ an act characterised by the fact that it follows chemical substances "from the cradle to the grave". Thus, the regulation of chemicals cuts across the traditional subdivision into sectors and media. This effort is also prophylactic and the best results are attained if individual efforts are made as close as possible to the original sources.

The product­oriented addition is aimed at the total environmental loading resulting from the manufacture, storage, use, transport and final disposal of goods and products. The goal of the product strategy is to promote the development and marketing of products that possess improved environmental characteristics. This goal can only be attained through the support and assistance of all relevant players, together with contributions made in a number of international forums. Its strategy combines the presentation of current knowledge and stimulation of requests for products with the regulation of behaviour in connection with the content, and manufacturing, distribution and final disposal, of the products. In contrast to the others, we still only have an embryonic experiential basis for this addition.

Control methods

A broad spectrum of control methods ­ "soft" as well as "hard" ­ is used in the regulation of chemical substances. Typical methods include requirements on labelling and packaging, prohibitions, restrictions on use, economic measures, agreements, green purchasing policies and subsidisation schemes.

International forums

A number of international organisations are employed on the regulation of chemical substances. An appendix has been drafted in connection with the report. This appendix lists the chemical substances that are covered by decisions made in international forums. It shows that largely the same chemical substances are discussed in the various forums ­ including heavy metals, pesticides and persistent organic compounds.

Ch. 5. Areas of difficulty

Effects of many substances unclear

One major problem is the great number of chemical substances which are used in large quantities, despite the fact that there is little information on their effects on public health and the environment.

Conversely, obtaining complete information on all of the substances in our society is a insurmountable task. Although this is partly because of the sheer number of substances, it is also due to the fact that new information on the possible effects of substances will continue to be uncovered.

Indecision

The greatest difficulty, therefore, is rather that we are unable to make decisions on the basis of the large quantity of available ­ but assuredly incomplete ­ data. This applies equally to Danish and international restrictions on use, including decisions made at the EU level. It must also be admitted that greater ability and will to decide could mean that decisions are made that later prove to be wrong.

Regulation of the content of finished products is only carried out to a very limited extent. It is emerging that a number of the serious environmental problems now at the top of the environmental agenda concern indirect discharges, in the form of waste, residual products and various slags and sludges. If these problems are to be solved, it will be necessary to adopt a programme that can also deal with such "diffuse" discharges. This can best be done by a programme that is implemented as close as possible to the original source.

Ch. 6. Proposed future initiatives

Internationally ties

The Danish EPA has proposed, or already started, initiatives aimed, for instance, at transforming the body of relevant scientific knowledge/data into decisions that can limit the undesirable effects of chemical substances. Since this area is to a large extent bound by international directives, conventions and agreements, we must stress the overall importance of Denmark working actively for a high level of protection in the international forums that have environmentally­detrimental substances on their agendas.

List of undesirable substances

We propose to promote reduction and discontinuation of the use of environmentally­hazardous substances. The Danish EPA has prepared a draft for a list of substances that are undesirable in products due to their effects on man and/or the environment, in production, use and/or final disposal. This list can be found as Appendix 2 of the report.

Speeding work on chemicals

In connection with EU work in the field of chemicals, the Danish EPA proposes various initiatives which can speed the task of classifying chemical substances (the development of simple test methods, use of computer models and classification of groups of substances, etc.) and explains how we wish to assign priorities in work on the risk assessment of chemical substances.

Involving relevant parties

Finally, we stress the importance of presenting better information to the general public and of involving purchasers and environmentally­aware consumers. We propose an extension of the obligations of manufacturers and importers to declare the content of their products.

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