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House of Commons Environmental Audit Committee Toxic Chemicals in Everyday Life Twentieth Report of Session 2017–19 Report, together with formal minutes relating to the report Ordered by the House of Commons to be printed 10 July 2019 HC 1805 Published on 16 July 2019 by authority of the House of Commons
Environmental Audit Committee The Environmental Audit Committee is appointed by the House of Commons to consider to what extent the policies and programmes of government departments and non-departmental public bodies contribute to environmental protection and sustainable development; to audit their performance against such targets as may be set for them by Her Majesty’s Ministers; and to report thereon to the House. Current membership Mary Creagh MP (Labour, Wakefield) (Chair) Dr Thérèse Coffey MP (Conservative, Suffolk Coastal) Geraint Davies MP (Labour (Co-op), Swansea West) Mr Philip Dunne MP (Conservative, Ludlow) Zac Goldsmith MP (Conservative, Richmond Park) Mr Robert Goodwill MP (Conservative, Scarborough and Whitby) James Gray MP (Conservative, North Wiltshire) Ruth Jones MP (Labour, Newport West) Caroline Lucas MP (Green Party, Brighton, Pavilion) Kerry McCarthy MP (Labour, Bristol East) Anna McMorrin MP (Labour, Cardiff North) John McNally MP (Scottish National Party, Falkirk) Dr Matthew Offord MP (Conservative, Hendon) Dr Dan Poulter MP (Conservative, Central Suffolk and North Ipswich) Alex Sobel MP (Labour (Co-op), Leeds North West) Derek Thomas MP (Conservative, St Ives) Powers The constitution and powers are set out in House of Commons Standing Orders, principally in SO No 152A. These are available on the internet via www.parliament.uk. Publications © Parliamentary Copyright House of Commons 2019. This publication may be reproduced under the terms of the Open Parliament Licence, which is published at www.parliament.uk/copyright. Committee reports are published on the Committee’s website at www.parliament.uk/ eacom and in print by Order of the House. Evidence relating to this report is published on the inquiry publications page of the Committee’s website. Committee staff The current staff of the Committee are Lloyd Owen (Clerk), Leoni Kurt (Second Clerk), Ruth Cahir (Committee Specialist), Laura Grant (Committee Specialist), Laura Scott (Committee Specialist), Helen Muller (Committee Researcher), Jonathan Wright (Senior Committee Assistant), Baris Tufekci (Committee Assistant), Anne Peacock (Media Officer) and Simon Horswell (Media Officer). SContacts All correspondence should be addressed to the Clerk of the Environmental Audit Committee, House of Commons, London SW1A 0AA. The telephone number for general enquiries is 020 7219 8890; the Committee’s email address is email@example.com. You can follow the Committee on Twitter using @CommonsEAC.
Toxic Chemicals in Everyday Life 1 Contents Summary3 1 Introduction 5 Chemicals in society 5 Production of chemicals 5 Chemicals of concern 6 Toxicity9 Risk management 9 Previous inquiries 10 Our inquiry 10 2 Environment and human health impact of chemicals 11 Environment11 International chemicals management 11 Chemicals in the UK environment 12 Attitudes to chemicals 15 Human health 16 Body burden of chemicals 17 Biomonitoring18 Plastic packaging 20 3 Furniture and Furnishings (Fire Safety) Regulations 1988 23 Flame retardants 23 Fire deaths 24 1988 Furniture and Furnishings (Fire Safety) Regulations 27 2014 BIS consultation 31 2016 BEIS consultation 32 Industry views 33 Whistle-blower allegations 36 4 Environmental contamination around the Grenfell Tower 40 Environmental contamination testing 40 Response to findings of environmental contamination 42 Public Health England response 43 Toxicity of smoke 45 Exposure of firefighters 46
5 Product safety 48 Product testing 48 Products sold online 49 Resources for chemical testing 49 Product labelling 52 Innovations for consumers 54 Product safety after the UK leaves the EU 55 RAPEX55 6 Future UK chemicals policy 57 European Union 57 Strategy for a non-toxic environment 58 Framework on endocrine disruptors 58 Forthcoming Chemicals Strategy 59 Chemicals regulation in the event of EU exit 61 Stakeholder engagement 63 Acknowledgments66 Conclusions and recommendations 67 Annex 1: Glossary 74 Annex 2: Survey results 76 Formal minutes 80 Witnesses81 Published written evidence 82 List of Reports from the Committee during the current Parliament 84
Toxic Chemicals in Everyday Life 3 Summary Chemicals are pervasive in modern society and contribute to improved health and quality of life globally. However, current regulation does not account for the cocktail of chemicals we are exposed to. Hazardous chemicals and other pollutants are now ‘ubiquitous in humans and the environment.’1 Without a rapid transition to a more circular economy for chemicals, it will not be possible to implement the ambitions set out in the 25 Year Environment Plan or Resources and Waste Strategy. We call on the Government to use the forthcoming Chemicals Strategy to form the basis of a non-toxic environment in the UK. This should set out a clear, ambitious vision for the type of chemical environment we hope to live in. We need to better understand which chemicals we are exposed to in greatest measure and what the risk from that exposure is. To do this, a long-term, UK wide, human and wildlife biomonitoring programme should be established. The Chemicals Strategy should include objectives and priority areas for monitoring. It should also consider the mixtures of chemicals we are exposed to and lay out a plan for the remediation of harmful regulated substances in the environment. The 1988 Furniture and Furnishings (Fire Safety) Regulations have been under review for ten years with no reforms enacted. During this time, some of the most commonly used flame retardants have been classed as persistent organic pollutants and substances of very high concern. Inaction has allowed unnecessary and potentially toxic chemicals to continue to enter the public’s homes. Our Regulations should be brought in line with the rest of the world and the Government should develop a new flammability standard without further delay. Children’s products should be immediately removed from scope of the Regulations. Labels should clearly state if a furniture product has been treated with chemical flame retardants. It is clear that the Regulations are contested and there is no consensus; however, it is unacceptable a government department can take nearly three years to respond to a public consultation. The Minister must publish the responses before a new Prime Minister takes office on 24 July. Failure to do so will add to the view that the process is being deliberately delayed. We are troubled by the lack of urgency in response to findings of environmental contamination from chemicals around the Grenfell Tower site. Residents should be reassured that the presence of these chemicals is not harmful to their health and homes. We support calls for full health biomonitoring for residents, including specific monitoring for the effects of exposure to fire effluents. We also recommend that any local residents who have concerns about dusts or residues within their homes be offered the opportunity to have them tested for environmental contamination. Environmental contamination testing for chemicals should be carried out as standard in the immediate aftermath of major disasters. Chemicals are routinely used in consumer products where their presence is not indicated on the product label. Consumers have the right to know what chemicals are used in the products they purchase. The current budget for product safety compliance does not reflect the volume of products on the market and is failing to protect UK consumers. The Government should increase resources for product safety compliance by 10 percent a year in the upcoming spending review. Product labelling should be reformed to 1 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p viii.
4 Toxic Chemicals in Everyday Life ensure consumers are aware of which groups of chemicals have been used. This should include domestic pictograms to indicate if a substance meets the criteria for a substance of very high concern. A full list of chemical ingredients should be made available on the product website and direction offered to independent, scientific advice. Public Health Bodies should be given responsibility for monitoring, researching the impact of chemicals on public health, and recommending restrictions and other controls on groups of problematic chemicals. They should be given adequate funding and staffing for research and policy development.
Toxic Chemicals in Everyday Life 5 1 Introduction Chemicals in society 1. Chemicals are pervasive in modern society and have contributed to global improvements in human health, food security, productivity and quality of life. Production and consumption of chemicals are rising as the market for chemical-intensive products such as computers, furniture and personal care products grows.2 There is growing evidence that some chemicals cause products and wastes with hazardous properties which harm human health and the environment.3 According to the UN’s Global Chemicals Outlook, hazardous chemicals and other pollutants are now ‘ubiquitous in humans and the environment.’4 CHEM Trust contends that ‘the unpleasant reality [is] that we are constantly exposed to a cocktail of chemicals, something which is still largely ignored by chemical safety laws.’5 Production of chemicals 2. Chemical production globally has increased fiftyfold since 1950 and is forecast to treble in volume by 2050.6 The Lancet Commission estimates that over 140,000 new chemicals and pesticides have been synthesised since 1950. 5,000 chemicals produced in the greatest volume have become widely dispersed in the environment and account for almost all human exposure.7 Per capita consumption of chemicals is driven by economic growth in chemical intensive industries such as construction, agriculture, electronics, cosmetics, mining and textiles.8 Emerging economies are experiencing rapid growth in both production and consumption of chemicals.9 This increase in production means more chemicals in products, which means increased human, animal and environmental exposure.10 3. Global chemical sales were valued at €3.4 trillion in 2017 with China, the EU and US the largest producers.11 The UK is the seventh largest chemicals producer in the EU 28. The industry contributes £18 billion to the UK economy each year.12 The European Commission estimates there are over 100,000 chemicals on the EU market, only a small proportion of which have been evaluated for their impact on human health and the environment.13 Eurostat, the EU statistical office, estimates that the EU produced 81 million tonnes of chemicals hazardous to the environment and 219 million tonnes 2 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 4. 3 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 5. 4 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p viii. 5 CHEM Trust, No Brainer – The impact of chemicals on children’s brain development: a cause for concern and a need for action (March 2017), p 2. 6 Q6 7 The Lancet, The Lancet Commission on pollution and health (2017), p 462. 8 Dr Olwenn Martin (TCS0030), pp 4–5. 9 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p viii. 10 European Commission, Study for the strategy for a non-toxic environment of the 7th Environment Action Programme (2017), p 10. 11 CEFIC, Facts & Figures of the European chemical industry (2018), pp 6–7. 12 CEFIC, Facts & Figures of the European chemical industry (2018), p. 11; Chemical Industries Association (TCS0014), p 1. 13 European Commission, Study for the strategy for a non-toxic environment of the 7th Environment Action Programme (2017), p 10.
6 Toxic Chemicals in Everyday Life of chemicals hazardous to human health in 2017.14 Only 70 unique substances, and some related groups, are subject to restrictions under the EU’s Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation (REACH).15 Chemicals of concern 4. Our inquiry and this report are focused on chemicals most commonly found in consumer products and due to limitations of time and space, we were not able to focus on groups such as metals, pharmaceuticals, pesticides and nanomaterials in depth. Key terms Substance of very high concern (SVHC): A substance is classed as an SVHC under Article 57 of REACH if it meets the criteria for classification as carcinogenic, mutagenic or toxic for reproduction, is considered persistent, bio-accumulative and toxic or very persistent and very bio-accumulative, or causes an equivalent level of concern.16 Combined exposure: Exposure to multiple chemicals via one or several sources and routes.17 Regrettable substitution: The replacement of hazardous substances with structurally similar substances which exhibit similar hazardous properties.18 5. Substances of very high concern (SVHCs) are of particular interest to us. These are chemicals which are defined as having hazardous properties under Article 57 of REACH. To be considered a SVHC, a substance must meet the scientific criteria for classification as carcinogenic (cancer causing), mutagenic (having the ability to change genetic material) or toxic for reproduction, be considered persistent, bio-accumulative (accumulating in the body of animals and humans) and toxic or very persistent and very bio-accumulative or cause an equivalent level of concern.19 Once a substance is classified as of very high concern, it is added to REACH’s Candidate List. This places additional obligations on suppliers, including supplying safety information and informing the European Chemicals Agency (ECHA), if the substance is produced in quantities above the threshold of one tonne per producer/importer per year.20 Continued use of a substance of very high concern may be permitted if applicants can demonstrate that the substance is used safely or if it can be shown that there are no available alternatives.21 REACH Under REACH any substance manufactured in or imported to the EU in quantities above one tonne per year must be registered with the European Chemicals Agency (ECHA). The information requirements to assess the potential hazard and risk of a 14 Eurostat, Chemicals production and consumption statistics (December 2018). 15 ECHA, Substances restricted under REACH [accessed 18 June 2019]. 16 ECHA, Substances of very high concern identification [accessed 4 March 2019]. 17 European Commission, Something from nothing? Ensuring the safety of chemical mixtures (May 2018), p 2. 18 European Commission, Study for the strategy for a non-toxic environment of the 7th Environment Action Programme (2017), p 42. 19 ECHA, Substances of very high concern identification [accessed 4 March 2019]. 20 ECHA, Substances of very high concern identification [accessed 4 March 2019]. 21 ChemSec, Lost at SEA* (March 2019), p 3.
Toxic Chemicals in Everyday Life 7 substance are determined by the quantity of the substance. Registered substances can be added to the List of the Community Rolling Action Plan (CoRAP) for substance evaluation by ECHA or an EU member state. Substances are chosen based on a hazard and risk criteria defined by ECHA. Once listed, an individual substance is evaluated by member state(s) to determine if its use poses a risk to human health or the environment. If the evaluation concludes a substance is of concern, risk management measures are proposed including harmonised classification and labelling, identifying the substance as a substance of very high concern (SVHC), restricting the substance or proposing EU-wide occupational exposure limits, national measures or voluntary industry actions (outside of the scope of REACH).22 6. The EU has also identified endocrine disrupting chemicals as an area of concern. They are ‘substances that alter function(s) of the endocrine system and consequently cause adverse health effects in an intact organism or its progeny, or (sub)populations.’23 They are structurally similar to hormones. This enables them to act like naturally occurring hormones or alter the body’s ability to synthesise, release or eliminate hormones.24 They are mostly synthetic and are found in pesticides, metals, additives or as contaminants in food and cosmetics. Humans and wildlife are exposed to them through food, dust, water, inhalation or through skin contact.25 Thresholds of exposure are likely to exist for endocrine disrupting chemicals; however they may be very low for individual chemicals and depend on when the exposure occurs.26 In addition to endocrine disrupting chemicals, groups of chemicals which have been linked to ‘regrettable substitution’ in consumer products will also be considered including flame retardants, per-fluorinated chemicals and bisphenols. Regrettable substitution occurs when a hazardous substance is replaced with a structurally similar substance which exhibits similar hazardous properties.27 We heard evidence that the chemical bisphenol A (BPA) is an example of this. We identified that there were harmful health consequences of being exposed to bisphenol A sufficient to warrant a reduction in the tolerable daily limit that you are allowed to be exposed to. Lots of companies switched from bisphenol A to a highly related compound called bisphenol S to satisfy that this is a bisphenol A-free item, but bisphenol S has very similar toxicological properties to bisphenol A.28 CHEM Trust have argued that groups of chemicals should be regulated and controlled together, rather than regulating individual substances on a case-by-case basis. It is the regulation of single chemical substances that leads to regrettable substitution.29 22 UN Environment Programme, Overview Report III: Existing national, regional, and global regulatory frameworks addressing Endocrine Disrupting Chemicals (EDCs) (July 2017), p 15. 23 ECHA, Endocrine disruptor expert group [accessed 7 March 2019]. 24 OECD, OECD work on endocrine disrupting chemicals (March 2018), p 7. 25 ECHA, Endocrine disruptors and our health [accessed 7 March 2019]. 26 Munn, S. and Goumenou, M., Thresholds for endocrine disrupters and related uncertainties, Report of the Endocrine Disrupters Expert Advisory Group (2013), p 6. 27 European Commission, Study for the strategy for a non-toxic environment of the 7th Environment Action Programme (2017), p 42. 28 Q25 29 CHEM Trust (TCS0012), p 1.
report is set out below: A table of some of the groups of chemicals and their properties to be considered in this 8 Sample of groups of chemicals of concern to human health and the environment Chemical Group Uses Possible health effects Products Toxic Chemicals in Everyday Life Bisphenols (BPA, BPF, BPS) A main component in the Disrupts the reproductive and hormone Food can linings, plastic, manufacture of polycarbonate systems, increases the risk of cancer. electronic toys, paper receipts. plastics, epoxies, epoxy resin. Flame retardants Fire retardant. Persistent, bio-accumulative, toxic; some Furniture, electronics, building (brominated, kinds are also classified as carcinogenic, materials. organophosphate, toxic, disrupting the reproductive system; chlorinated) some disrupt the hormone system. Formaldehydes Bind pigments to the cloth. Fire Irritates mucous membranes and skin, can Toys, furniture, air fresheners. retardant. Wrinkle resistance. Water cause hypersensitivity, carcinogenic repellence. Adhesive in wood (nasal pathway). products. Parabens Preservative. Estrogenic effects, disrupts the hormone Shampoos, bath additives, system, sensitizing agent. lotions, creams, oils, sunscreens, toothpaste, baby wipes. Perfluorinated chemicals Water, grease and soil repellence. Carcinogenic, disrupts fertility. Waterproof clothing, non-stick including pans, toys. perfluoroalkylated substances (PFAs) (i.e. perfluorooctanoic sulfonate (PFOS) and perfluorooctanoic acid (PFOA)) Persistent organic pollutants Flame retardants, surfactants. Cancer risk, reproductive disorders, neuro- Banned under the Stockholm (PCBs, DDT, dioxins) behavioural impairment, endocrine Convention but still widely disruption, genotoxicity and increased birth dispersed in the environment defects. including in recycled products. Phthalates (DEHP, DBP, Plasticiser, usually found in soft Disrupts development and the hormone Plasticisers in PVC, furnishings, BBP) plastic, pellets for stuffing cuddly system, impairs fertility. clothing and food packaging. toys. Can also be used as a synthetic fragrance compound in scented toys. Source: Project NonHazCity [accessed 5 March 2019].
Toxic Chemicals in Everyday Life 9 Toxicity 7. We received several submissions highlighting that the level of toxicity of a chemical is determined by the dose. Examples included oxygen which is harmful if normal concentrations are increased fivefold30 and botulinum, a highly poisonous naturally occurring substance, used in cosmetics (known as Botox) to treat muscle spasms.31 The Paracelsus Principle states, ‘what is there that is not poison? All things are poison and nothing is without poison. Solely the dose determines that a thing is not a poison.’32 Modern toxicity thresholds are determined by the No Observed Adverse Effect Level (NOAEL) and Maximum Residue Levels (MRLs) for chemicals and pesticides in food.33 The Chemical Industries Association noted that developments in technology are enabling the detection of chemicals in our bodies and the environment in ever smaller amounts.34 Approximately 2,000 new chemicals are placed on the market each year. Only a small proportion of chemicals have ever been tested for toxicity and there is a lack of knowledge about how they interact in mixtures. Evidence is emerging of a complex network of problems which vary depending on the chemicals, mixes, species and environment.35 Risk management 8. The Royal Society of Chemistry outlined five principles to manage the risks from chemicals in everyday life: the precautionary principle, risk and impact assessments, mutual recognition, innovation and citizens’ ‘right to know.’36 The Chemical Industries Association supports a risk-based approach for chemicals management. It said, ‘considering both hazard and risk of chemicals alongside the potential benefits they bring to society is the most effective means by which they should be regulated.’37 We heard evidence from government bodies including the Food Standards Agency and Office for Product Safety and Standards indicating they follow this approach. 9. Professor Michael Depledge of the University of Exeter told us that the regulatory environment for chemicals is ‘firefighting’. He asked us to consider ‘what kind of chemical environment are we willing to live in in the coming years’38 and suggested a ‘do no harm’ approach, mirroring the medical approach where ‘effort is put in to try to minimise that harm.’39 Dr Michael Warhurst of CHEM Trust noted that there is a delay between the use of a chemical and identifying problems. He called for a more proactive approach to assessing the likely toxicity of chemicals with similar structures.40 30 Q475 31 Chemical Industries Association (TCS0014), p 2. 32 Grandjean, P., Paracelsus Revisited: The Dose Concept in a Complex World, Basic & Clinical Pharmacology & Toxicology, vol 119 (2016), p 1. 33 Grandjean, P., Paracelsus Revisited: The Dose Concept in a Complex World, Basic & Clinical Pharmacology & Toxicology, vol 119 (2016), p 1; Chemical Industries Association (TCS0014), p 2. 34 Chemical Industries Association (TCS0014), p 2. 35 Q6 36 Royal Society of Chemistry (TCS0034), pp 2–3. 37 Chemical Industries Association (TCS0014), p 2. 38 Q6 39 Q7 40 Qq131–133
10 Toxic Chemicals in Everyday Life Previous inquiries 10. The Committee held an inquiry into the future of chemicals regulation after the EU referendum in 2016–17. We heard from stakeholders including academics, environmental groups, business representatives and government agencies. The inquiry concluded that establishing a fully stand-alone system of chemicals regulation for the UK will be expensive for taxpayers and for industry and the Government should seek to remain involved in the ECHA’s registration process for chemicals as a minimum.41 The Government’s response was published in September 2017. The Committee followed up this inquiry with a one-off evidence session with stakeholders in December 2018 to consider further work required to prepare the chemicals industry if we leave the EU. Our inquiry 11. We launched a call for evidence on the impact of toxic chemicals in everyday life in February 2019. The inquiry held four oral evidence sessions which heard from leading academics in ecotoxicology, product safety experts, retailers and industry representatives. In addition, the inquiry ran a survey about the public’s knowledge of chemicals in consumer products. It received 589 responses and a summary of responses is provided in Annex 2. The inquiry also held outreach events at IKEA Greenwich and Victoria Leeds to gather consumer views about chemicals in consumer products. 12. As our inquiry considered the presence of chemicals in consumer products, two specific issues emerged: the Government’s review of the 1988 Furniture and Furnishings Regulations and environmental contamination around the Grenfell Tower site. This has been reflected in the structure of this report. The environmental and human health effects of chemicals in consumer products will be considered in Chapter Two. Chapter Three and Four will be case studies of the use of flame-retardant chemicals in UK furniture and environmental contamination from chemicals around the Grenfell Tower site. Product safety and the future regulatory environment for chemicals in the UK is discussed in Chapters Five and Six. 41 Environmental Audit Committee, Eleventh Report of Session 2016–17, Future of Chemicals Regulation after the EU Referendum, HC 912, p 4.
Toxic Chemicals in Everyday Life 11 2 Environment and human health impact of chemicals Environment 13. There is a vast array of chemicals in the environment. These span historical contaminants such as metals and persistent chemical pollutants to substances for modern use such as pesticides, pharmaceuticals, nanomaterials and chemicals in consumer products.42 They are released directly or as by-products of industrial and manufacturing processes, energy generation, agriculture and pharmaceuticals.43 The persistence and fate of chemicals in the environment is controlled by natural processes and ecosystems are exposed to complex chemical mixtures.44 In 2013, the UN estimated that 27 percent of total global ecosystem loss was due to chemical pollution.45 The Lancet Commission estimated that 9 million premature deaths worldwide were attributable to pollution in 2015 and it determined that ‘chemical pollution is a great and growing global problem’.46 It has a cumulative effect where the whole food chain is impacted ‘because different chemicals will have different effects on different parts of the ecosystem.’47 UK Research and Innovation said it is not yet known what contribution chemicals make towards biodiversity loss and environmental degradation.48 14. Professor John Sumpter of Brunel University told us that it is not possible to know which chemicals we should be most concerned about. Using the example of Teflon, he said that as one damaging chemical is restricted, over 1,000 similar chemicals are patented, with many still in use.49 Chemicals in the environment are managed through international conventions and by the EU’s REACH regulation. International chemicals management 15. The management of chemicals is included in Goals 3 and 12 of the Sustainable Development Goals. Target 3.9 aims to ‘substantially reduce the number of deaths and illnesses from hazardous chemicals’ while target 12.4 aims to ‘achieve the environmentally sound management of chemicals and all wastes throughout their life cycle.’50 International oversight of chemicals is provided by the United Nations Environment Programme, the OECD’s chemical safety and biosafety division and the World Health Organisation’s International Programme on Chemical Safety. The UN administers the Strategic Approach to International Chemicals Management, a policy framework to achieve the safe management of chemicals throughout their life cycle51 and published its second global 42 Q5 43 Centre for Ecology & Hydrology (TCS0025), p 3. 44 UK Research and Innovation (UKRI) (TCS0022), p 2. 45 Wildlife & Countryside Link (TCS0024), p 3. 46 The Lancet, The Lancet Commission on pollution and health (2017), p 462. 47 Q2 48 UK Research and Innovation (UKRI) (TCS0022), p 2. 49 Q4 50 UN Sustainable Development Goals, Goal 3: Ensure healthy lives and promote well-being for all at all ages; UN Sustainable Development Goals, Goal 12: Ensure sustainable consumption and production patterns [accessed 28 February 2019]. 51 SAICM, SAICM Overview [accessed 11 March 2019].
12 Toxic Chemicals in Everyday Life chemicals outlook in early 2019.52 It has also implemented global treaties to control the use of hazardous chemicals including the Basel, Rotterdam and Stockholm Conventions (on the trade in hazardous waste and ending the production of persistent organic pollutants).53 Persistent Organic Pollutants (POPs) 16. The 2004 Stockholm Convention [hereafter ‘the Convention’] aims to protect human health and the environment from persistent organic pollutants (POPs). POPs are organic chemical substances that remain intact for a long time, become widely distributed in the environment through natural processes, accumulate in the fatty tissue of organisms and are toxic to humans and wildlife.54 Food is the primary route of exposure for humans. Professor Mumford explained that ‘probably 80% to 90% of our foodborne contact with POPs is through animal products—through dairy, meat, fish and oils.’55 POPs can be toxic to the liver, kidney and nervous, reproductive and immune systems and cancer-causing.56 The Convention requires signatories to prohibit or eliminate the production and use of POPs. They must also take measures to ensure wastes containing POPs are managed in an environmentally sound manner. 28 chemicals are restricted under the Convention with a further three under review.57 The UK ratified the Convention in April 2005 and the Government has a national implementation plan for its delivery. The 25 Year Environment Plan commits the Government to fulfilling its obligations under the Convention including the elimination of polychlorinated biphenyls (PCBs) by 2025 and increasing the amount of material containing POPs being destroyed or irreversibly transformed by 2030.58 17. POPs continue to be found in the environment and organisms despite the Convention. Reports suggest that levels of PCBs in Europe have stabilised rather than continuing to decline.59 Dr Kimberley Bennett of Abertay University said that there has not been a substantial reduction in the environmental risk from POPs to seals in the North Sea in 15 years. This indicated that ‘relying on a ban of production and use is not sufficient to eliminate POPs from the environment and from the food chain in a timely way.’60 Professor Tamara Galloway from the University of Exeter told us that regulation has contributed to a fall in the concentration of PCBs in seafood and focused remediation can be effective in reducing levels of PCBs below toxic levels.61 Chemicals in the UK environment 18. The Government’s approach to chemicals in the environment is set out in the 25 Year Environment Plan and the 2018 Resources and Waste Strategy. The 25 Year Environment Plan is focused on POPs and the UK’s obligations under the Stockholm Convention.62 It does not consider chemical pollution or exposure from chemicals in consumer products.63 The Resources and Waste Strategy sets out how the Government will approach sustainable 52 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019). 53 Basel Convention; Rotterdam Convention; Stockholm Convention [accessed 19 June 2019]. 54 Stockholm Convention, What are POPs? [accessed 19 June 2019]. 55 Q152 56 Persistent Chemical Pollutants, POSTnote 579, Parliamentary Office of Science and Technology, July 2018, p 2. 57 Persistent Chemical Pollutants, POSTnote 579, Parliamentary Office of Science and Technology, July 2018, p 1. 58 HM Government, 25 Year Environment Plan (2018), p 30. 59 Plastics leading to reproductive problems for wildlife’, The Guardian, 27 February 2019. 60 Dr Kimberley Bennett (TCS0026), p 3. 61 Q5 62 HM Government, 25 Year Environment Plan (2018), p 30. 63 CHEM Trust (TCS0012), p 6.
Toxic Chemicals in Everyday Life 13 chemicals use as it moves towards a circular economy. It notes that ‘there are significant opportunities for resource efficiency savings in the chemicals sector.’64 Legacy chemicals in products were identified as a problem as they contaminate waste streams and pose a barrier to efficient recovery of resources. It cited Extended Producer Responsibility (EPR) and Eco-design as methods to address these issues.65 Wildlife and Countryside Link and CHEM Trust called on the Government to set targets for the reduction of chemicals in the environment. The Government needs to set targets and strategies for the reduction into the environment from all sources of all substances of regulatory interest (e.g. all SVHC on ECHA’s candidate list, all substances in the REACH Restrictions process). They also need to address emerging chemicals of concern (persistent, mobile, endocrine disruptors etc) that are found in everyday products such as many “new” bisphenols.66 The Natural Environment Research Council (NERC) is supporting research into the environmental risk from chemicals via its Emerging Risks of Chemicals in the Environment programme. This is expected to lead to a transformation in how chemical risk assessment is considered and moves towards an ecosystems approach.67 Extended Producer Responsibility 19. The Resources and Waste Strategy identified EPR as a method of reducing the contamination of waste streams by chemicals. The waste management of products containing harmful chemicals has a direct effect on the environment as toxic substances can be released into the air, water and soil. These toxins can leach from landfill, enter soil and water, travel long distances, accumulate in tissues of plants and animals, before entering human bodies. The management of plastic waste through incineration, gasification and pyrolysis can release toxic metals, dioxins, furans and acid gases. This can lead to direct or indirect exposure to toxic substances for workers and communities.68 20. In the Resources and Waste Strategy, the Government committed to an EPR scheme for bulky waste including mattresses, furniture and carpets by 2025.69 This is unlikely to be consulted on before 2020.70 Defra is also developing a strategy with local authorities and the waste industry to divert high risk items away from landfill.71 In evidence, Dr Thérèse Coffey, Parliamentary Under-Secretary of State for the Environment, was unable to give detail on the EPR scheme for bulky waste as it is still in early stages; however she confirmed that the ‘polluter pays’ principle will form an element.72 She acknowledged that chemicals used in bulky waste pose a technical challenge for identification and safe removal. The Environment Agency is working with industry to find a solution to dispose safely of brominated flame retardants.73 Cement kiln co-incineration was proposed as one 64 HM Government, Our waste, our resources: a strategy for England (2018), p 46. 65 HM Government, Our waste, our resources: a strategy for England (2018), p 46. 66 CHEM Trust (TCS0012), p 7; Wildlife & Countryside Link (TCS0024), p 3. 67 UK Research and Innovation (UKRI) (TCS0022), p 2. 68 CIEL et al., Plastic & Health: The hidden costs of a plastic planet (February 2019), p 2. 69 HM Government, Our waste, our resources: A strategy for England (2018), pp 38–9. 70 Environmental Audit Committee, Eighteenth Special Report of Session 2017–19, Fixing fashion: clothing consumption and sustainability: Government Response to the Committee’s Sixteenth Report, HC 2311, p 9. 71 Department for Environment, Food and Rural Affairs (TCS0040), p 9. 72 Qq518–519 73 Qq500–501
14 Toxic Chemicals in Everyday Life solution.74 Minister Coffey agreed that mandating the use of environmentally friendly alternatives to flame retardants would be a good approach ‘if it fulfils the principle of what it is there to do, which is safety and also [reducing] the risk from chemicals.’75 21. The Furniture Industry Research Association (FIRA) confirmed that they, alongside the British Furniture Confederation and National Bed Federation, have had discussions with Defra regarding the disposal of products containing flame retardants.76 In evidence, retailers were broadly supportive of an EPR scheme; however IKEA stressed the need for a harmonised approach.77 Amazon added that it would like the administration of the programme to involve the entire supply chain, including recyclers.78 Kingfisher noted the need to ensure it is designed correctly so that the market responds and the Government can help to facilitate information about approved recyclers.79 22. In May, the Mail on Sunday reported that Amazon destroys unsold stock in France.80 Following the reports, the French Prime Minister’s office reported that more than €650 million worth of consumer products are thrown away each year and the government moved to ban the destruction of unsold or returned consumer products including clothes, electrical items and cosmetics. The ban will be introduced within four years.81 Amazon was questioned about the practice in the UK and denied it took place: No. When I was talking about this earlier, I was talking about my knowledge of the UK’s work here, because I work in the UK office, is that we have a zero to landfill policy. I know that they are looking to try to continually improve that story everywhere across Europe. One of the challenges that we have in France is that donations are subject to VAT so there are fewer overall donation pathways as a result of that.82 23. It will not be possible to implement the ambitions of the Government’s 25 Year Environment Plan and the Resources and Waste Strategy without a rapid transition to a more circular economy for chemicals. We call on the Government to set ambitious targets for the reduction of chemicals in the environment. The forthcoming Chemicals Strategy should form the basis for the UK to develop a non-toxic environment by setting out a clear, ambitious vision for the type of chemical environment we hope to live in. It should lay out a plan for remediation of regulated substances in the environment with binding targets. 24. We recommend that the Government works with the EU environment plan and REACH to mandate the phase out of chemicals harmful to the environment. This should include a ban on the use of substances of very high concern, including those under the threshold level, ‘regrettable substitutes’ and groups of chemicals whose properties mean 74 Q511 75 Q509 76 Q371 77 Q314 78 Q315 79 Qq318–319 80 How Amazon destroys millions of new items it can’t sell with everything from TVs to kitchen equipment, books and nappies dumped in landfill sites, Mail on Sunday, 12 May 2019. 81 France to ban destruction of unsold consumer products, The Guardian, 4 June 2019. 82 Q325
Toxic Chemicals in Everyday Life 15 they do not easily breakdown in the environment. The Government should introduce an EPR to enable the furniture industry to invest in technology to ensure the safe disposal of hazardous wastes containing harmful chemicals such as brominated flame retardants. 25. The landfill and incineration of consumer products containing chemicals causes harm to the environment, workers and communities. Reports from France suggest this is happening in huge volumes to unsold stock. We restate the recommendation in our Fixing Fashion report and call on the Government to ban the landfill and incineration of unused and unsold consumer goods. Attitudes to chemicals 26. In 2017, a survey by the European Commission found that 90 percent of Europeans were worried about the environmental impact and 84 percent were worried about the health impacts of chemicals in everyday products. This indicated a higher level of public concern for chemicals than plastics.83 During this inquiry, we ran a similar survey to gauge the views of the UK public about chemicals in consumer products. The survey received 589 responses online and through outreach events at IKEA Greenwich and Victoria Leeds. There was a high level of awareness (79 percent) of potentially harmful chemicals in consumer products. The results mirrored the European Commission’s findings of overwhelming concern about the impact of chemicals in consumer products. 98 percent of respondents were somewhat or very concerned about the impact on the environment while 95 percent were somewhat or very concerned about the impact of their health. Beauty and laundry products, air fresheners, toys, clothing and shoes were of particular concern.84 27. We received written evidence of exposure to chemicals. Georgina Downs described the effects of her exposure to the organophosphate flame retardant, triaryl phosphate ester, via a faulty laptop. It was deemed a relatively high level exposure considering that the breakdown product of the OP [organophosphate] was still found in my body fat almost 3 months later in blood and fat tests that were taken at a medical and scientific laboratory at the end of October 2009. The body fat tests also found raised levels of another flame retardant called polybrominated biphenyls (PBBs). The extensive and subsequently diagnosed impacts on my eyes as a result of the exposure causing pain in the eyes, light sensitivity, acute problems with glare, dry eyes, significant disturbances in the field of vision (which is like looking through debris with how many black lines etc. there are), have been permanent ever since. Also, at the time and for a few weeks after I also had pinpoint pupils (a common feature of OP poisoning).85 83 European Commission, Special Eurobarometer 468 Report: Attitudes of European citizens towards the environment (2017), p 34. 84 Environmental Audit Committee, Survey results: Toxic Chemicals in Everyday Life [accessed 28 June 2019]. 85 UK Pesticides Campaign (TCS0050), pp 3–4.
16 Toxic Chemicals in Everyday Life Tracy Logan detailed her exposure to formaldehyde: Our toxic furniture installation occurred in April 2017. It involved built-in cabinets and wardrobes in our bedroom, which made our eyes sting for 10 days following installation. The furniture firm told us this was normal. Eleven days after installation, a BRE air quality investigator sampled the air in our bedroom. This showed our bedroom air to contain more than thirteen times the WHO’s safety limit for formaldehyde, over eighteen times the Building regulations for VOCs [volatile organic compounds] and four times over the WHO limit for styrene. Emissions were significantly higher inside a new wardrobe.86 Human health 28. The Lancet Commission concluded ‘the effects of chemical pollution on human health are poorly defined and its contribution to the global burden of disease is almost certainly underestimated.’87 It suggests that chemicals have the potential ‘to cause global epidemics of disease, disability and death.’88 This is linked to a lack of testing of chemicals for their safety and toxicity prior to be being placed on the market. Pre-market evaluation of new chemicals is a recent development and at present, is limited to a small number of high-income countries.89 The World Health Organisation (WHO) estimated the disease burden from chemicals as 1.6 million deaths and 45 million disability-adjusted-life-years in 2016.90 This was an increase on its 2012 estimates and it suggested it is likely to be an underestimate overall as data is only available for a small proportion of the chemicals to which people are regularly exposed.91 In the EU, the annual cost of exposure to endocrine disrupting chemicals alone is estimated at between €109 billion and €157 billion.92 29. Concentrations of chemicals identified in humans vary depending on the location. Higher levels of some flame retardants have been identified in developed countries while some pesticides are present in greater concentration in developing countries.93 Professor Depledge told us that research by the European Centre for Environment and Human Health also identified different socio-economic groups as a factor in the burden of chemicals. … [we looked at] people from different socioeconomic groups within the NHANES study, let us just say from wealthy people to very poor people. We looked at the body burden of chemicals that they had and they were very different. Wealthy people tended to have more mercury, probably from the consumption of shellfish, shrimps and things like that, and more pesticides from the golf course, whereas poorer people had more chemicals, say, from 86 Tracey Logan (TCS0045), p 2. 87 The Lancet, The Lancet Commission on pollution and health (2017), p 462. 88 The Lancet, The Lancet Commission on pollution and health (2017), p 480. 89 The Lancet, The Lancet Commission on pollution and health (2017), p 462. 90 WHO, The Public Health Impacts of Chemicals: Knowns and Unknowns - Data addendum for 2016 (2018), p 1. 91 WHO, Chemical Risk Assessment Network Newsletter (Spring 2019), p 2. 92 Trasande, L. et al., Estimating burden and disease costs of exposure to endocrine-disrupting chemicals in the European Union, The Journal of Clinical Endocrinology & Metabolism, vol 100 (2015), p 1245. 93 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 27.
Toxic Chemicals in Everyday Life 17 landfill sites and from air pollution. They end up with a different spectrum of diseases. We are only beginning to see how socioeconomic conditions interact with body burdens of environmental chemicals.94 30. Health conditions associated with exposure to harmful chemicals include developmental disorders, endocrine disruption, breathing difficulties, reproductive disorders, cancers and neurological disorders.95 Foetuses, children and pregnant women are most at risk.96 Baskut Tuncak, the UN Special Rapporteur on human rights and toxics, warned of children being born ‘pre-polluted.’97 Recent studies have discovered banned flame retardants in the umbilical cord blood of new-borns.98 Dr Michael Warhurst of CHEM Trust explained that ‘the most sensitive period is always development; it is always the foetus and the development of the brain.’99 Men and some occupations are also at risk in certain environments. Research by the University of Nottingham linked declining male fertility with concentrations of chemicals in the home.100 Firefighters are at greater risk from some carcinogenic per- and polyfluoroalkyl substances (PFAs) and flame retardants; cashiers from bisphenols used in till receipts.101 Research for the Health and Safety Executive (HSE) has shown higher instances of sinonasal cancer in furniture and textile industry workers exposed to formaldehyde and wood dust.102 Body burden of chemicals 31. Humans and animals are exposed to complex mixtures of chemicals from a variety of sources on a daily basis. This exposure can impact on human and environmental health, even if individual chemicals in a mixture are below their individual safety threshold levels. Moreover, chemicals do not act in a uniform way in mixtures and can have complex additive, synergistic or cancelling effects.103 Professor Depledge explained that as people are living longer, there is evidence that they are developing diseases earlier in old age.104 As we are now living longer, we are accumulating levels in our bodies that are much higher than ever before, so there is a much larger number of people with higher levels of these chemical mixtures than ever before and we do not know what the implications are of it.105 Professor Sumpter outlined that under current testing regimes, it is not possible to determine if there is a risk to human health from long-term, low-level chronic exposure.106 94 Q39 95 Changing Markets Foundation, Testing for Toxics: How chemicals in European carpets are harming health and hindering circular economy (October 2018), p 11. 96 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 30. 97 Pure Earth, Pollution knows no borders (2019), p 34. 98 UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 27. 99 Q133 100 School of Veterinary Medicine, University of Nottingham (TCS0038), pp 2–3. 101 Fidra (TCS0019), p 4. 102 HSE, The burden of occupation cancer in Great Britain (2012), p iii. 103 Davies, S., Annual Report of the Chief Medical Officer 2017: Health impacts of all pollution - what do we know? (2017), p 52; Dr Kimberley Bennett (TCS0026), p 3. 104 Q19 105 Q19 106 Q41
18 Toxic Chemicals in Everyday Life Biomonitoring 32. The Royal Society of Chemistry told us that with increasing data and awareness of the burden of chemicals, ‘we will seek as a society to know whether the chemicals observed in our biofluids (blood and urine) are presenting significant harm to the quality and longevity of life.’107 The EU’s Joint Research Centre is coordinating five research programmes: chemical mixtures in the environment (SOLUTIONS), human health (EuroMix, HBM4EU), endocrine disruption (EDC-MixRisk) and alternatives to animal testing (EUToxRisk). The purpose is to consider the links between mixtures and diseases and the interaction effects of chemicals.108 The UK government funds the annual Health Survey for England. This measures physical and mental health alongside wellbeing, social care and lifestyle behaviours of 8,000 adults and 2,000 children.109 UK Biobank, a registered charity and international health resource, has collected samples from 500,000 people aged between 40–69 including body scans and lifestyle questionnaires. These samples are used by researchers around the world investigating prevention, diagnosis and treatment of a range of serious illnesses. It receives funding from the Medical Research Council, Department of Health, Scottish and Welsh governments and other UK charities.110 HBM4EU (Human Biomonitoring for the EU) The HBM4EU programme is a five-year, EU member state initiative funded through Horizon 2020 to coordinate and advance human biomonitoring in the EU. It runs until 2021. The project is intended to harmonize procedures for biomonitoring enabling the collection of comparable data on human internal exposure to chemicals and mixtures of chemicals. To achieve this, the project is developing indicators to ‘describe the exposure and body burden of chemical mixtures, with an emphasis on defining priority mixtures and identifying the drivers of mixture toxicity.’111 To date it has listed 18 priority substances including chemical mixtures, bisphenols, flame retardants, per-/poly-fluorinated compounds and phthalates.112 It has been suggested that the UK is only participating in this programme in a limited way and is not fully involved in collecting data.113 33. Biomarkers can provide ‘a biological measure of current or historic exposure to a pollutant.’114 They provide a broader perspective than measuring concentrations of a pollutant in an environment as lifestyle factors are also accounted for. Through blood and urine sampling, information about individual exposure can be assessed which can inform estimations of the population’s exposure. Countries such as the US and Germany have used these surveys to monitor chemical exposure over time.115 To date, the Health Survey for England has not been used to study the effects of pollution, including from 107 Royal Society of Chemistry (TCS0034), p 5. 108 European Commission, Something from nothing? Ensuring the safety of chemical mixtures (May 2018), p 2. 109 NHS Digital, Health Survey for England - Health, social care and lifestyles [accessed 20 June 2019]. 110 UK Biobank, About UK Biobank [accessed 21 June 2019]. 111 HBM4EU, Exposure and Health [accessed 15 March 2019]. 112 Chemical mixtures pose ‘underestimated’ risk to human health say scientists, Horizon Magazine, 15 May 2019; HBM4EU, Substances [accessed 22 May 2019]. 113 Public Health England, UK Chemicals Stakeholder Forum - HBM4EU Presentation (June 2019), pp 11–12. 114 Davies, S., Annual Report of the Chief Medical Officer 2017: Health impacts of all pollution - what do we know? (2017), p 145. 115 Davies, S., Annual Report of the Chief Medical Officer 2017: Health impacts of all pollution - what do we know? (2017), p 145.
Toxic Chemicals in Everyday Life 19 chemicals. The Chief Medical Officer’s 2017 annual report noted that ‘the collection and storage of biological samples and health data mean that such studies using HSE data could be undertaken were funding to become available.’116 In a parliamentary debate on chemicals regulation after leaving the EU, Minister Coffey said the Government’s forthcoming Chemicals Strategy was intended to ‘support collaborative work on human biomonitoring.’117 34. We received evidence in favour of the UK establishing its own biomonitoring programme within the Chemicals Strategy.118 Breast Cancer UK said its understanding was that the UK could continue to participate in the HBM4EU project until its completion but may be unable to continue as part of any follow-on programme should we leave the EU without a deal. It suggested that the UK establish its own biomonitoring programme in such a scenario.119 Professor Sumpter described the potential benefits: … It seems a rather dull and routine thing to be doing, and yet biomonitoring—and, I would also argue, wildlife monitoring—is really our eyes and ears. It gives us another angle to see to what degree our chemical exposure is changing, increasing or decreasing, and how that may or may not be associated with health. Without that monitoring exercise, for many of our aspirations such as those mentioned in the 25-year environment plan, we would have no idea whether we would be achieving them.120 Professor Sumpter outlined that it would not be possible to monitor every chemical, so choices would have to be made on what to monitor. He suggested that the establishment of a programme would incur significant costs and take time to produce information.121 Professor Tim Gant of Public Health England said similar national studies in other EU countries cost in the region of €1 million annually.122 On its benefit for decision making, Professor Andrew Johnson of the Centre for Ecology and Hydrology cautioned that ‘it will not solve all the questions you wish to ask but it would be a vital part of the evidence you would need to come to those sorts of decisions.’123 35. Public Health England also supported the need for biomonitoring and further resource for the HBM4EU programme. Professor Gant said it would enable better understanding of ‘what exposures are within the population. Only with that information can you then start to calculate risk.’124 He proposed that this could be done via blood, hair, saliva and urine sampling.125 When questioned about the inclusion of a biomonitoring programme within the Chemicals Strategy, Minister Coffey said: I have tried to outline that we are still at very early stages. Some of this will depend on the scenario that we have for [EU] exit, but biomonitoring is important to follow the trends and identify problematic substances. We 116 Davies, S., Annual Report of the Chief Medical Officer 2017: Health impacts of all pollution - what do we know? (2017), p 145. 117 HC Deb, 1 February 2018,col 440WH [Westminster Hall]. 118 Q43 119 Breast Cancer UK (TCS0018), p 6. 120 Q44 121 Q47 122 Letter from Public Health England to EAC, 26 June 2019. 123 Q45 124 Q590 125 Q593
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