Health Care Without Harm Europe
HCWH Europe
Health Care Without Harm Europe is a non-profit organization working to transform healthcare to reduce its environmental footprint and lead in environmental health and justice.
Lobbying Activity
Meeting with Tilly Metz (Member of the European Parliament) and European Public Health Alliance
1 Sept 2025 · AMR Interest Group
Response to EU rules on medical devices and in vitro diagnostics - targeted evaluation
20 Mar 2025
Health Care Without Harm (HCWH) Europe welcomes the opportunity to contribute to the European Commission's call for evidence on the evaluation of the Medical Devices Regulation (MDR). As a non-profit organisation dedicated to sustainable and harm-free health care, HCWH Europe also leads the Global Green and Healthy Hospitals network in Europe, representing over 9 000 health care institutions in the WHO European Region committed to more sustainable practices. This submission presents targeted recommendations based on discussions with sustainability experts, hospital members and industry representatives. It outlines a vision for a more circular, non-toxic approach to MDR - one that will increase the EU's resilience to supply chain disruptions, incentivise sustainable medtech innovation, support the relocation of the medtech industry within Europe, and align with the Union's circular economy goals, ultimately creating a better healthcare system for patients and the planet. Please find our detailed recommendations in the attached file.
Read full responseMeeting with Paul Speight (Head of Unit Environment) and European Environmental Bureau and
14 Feb 2025 · EU chemicals regulations / REACH revision
Meeting with Tilly Metz (Member of the European Parliament)
5 Feb 2025 · Sustainable healthcare
Meeting with Pascal Arimont (Member of the European Parliament)
15 Jan 2025 · Sustainable healthcare systems for healthier EU citizens
HCWH Europe Urges Broad Phase-Out of All Bisphenols
8 Mar 2024
Message — The organization calls for a comprehensive ban on the entire group of bisphenols in food contact materials and medical devices. They demand stricter limits on recycled materials and the inclusion of paper and cardboard in the regulation.123
Why — These measures would protect patients and healthcare workers by reducing hazardous chemical exposure from equipment and food.4
HCWH Europe urges tougher EU rules on healthcare packaging waste
24 Apr 2023
Message — The organization proposes a 15% waste prevention target and including medical device packaging. They also want to eliminate hazardous chemicals and strengthen producer responsibility.12
Why — Reducing waste would lower high financial and environmental costs for hospitals.3
Impact — Producers would bear the full financial burden of packaging recovery and treatment.4
Response to Promoting sustainability in consumer after-sales
5 Apr 2022
Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission’s initiative to promote more sustainable use of goods throughout their useful life through reuse and repair.
Crucially, this initiative cannot be achieved without also addressing consumption of healthcare products. Globally, healthcare accounts for 4.4% of global carbon emissions and in the EU, the healthcare sector is the third biggest contributor to global healthcare emissions after the US and China. Approximately 75% of healthcare emissions derive from the supply chain, i.e. production, transport, and the use and the disposal of goods and services.
Single-use products are a large part of the healthcare sector’s negative environmental impact - they contribute to the growing disposable culture that has emerged in the sector, increasing waste and greenhouse gas emissions. The significant quantity of single-use products used in healthcare has not only increased the sector’s waste, pollution, and environmental impact, but it has also increased healthcare expenditure and made supply chains vulnerable to disruption. Solutions to increase the reuse and repair of products in healthcare already exist, therefore the sector should not be overlooked in the development of this important initiative.
Additional information can be found in the attached document.
Read full responseResponse to Recommendation for strengthened actions against antimicrobial resistance
16 Mar 2022
Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission’s call for evidence on antimicrobial resistance (AMR) that aims to set concrete objectives and activities to strengthen national action against AMR, mainly in the area of public health where the EU has limited competence. Please find attached our detailed response.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
18 Feb 2022
Health Care Without Harm (HCWH) Europe welcomes the initiative to review the EU waste framework and to decrease the negative environmental impacts of waste management. HCWH Europe agrees that the priority objective of the initiative should be to decrease waste generation altogether - this can be achieved by respecting the waste hierarchy and looking firstly at upstream solutions.
Crucially, this initiative cannot be achieved without addressing waste from the healthcare sector, which is often overlooked. The large majority of waste produced by the healthcare sector is non-hazardous (85%) and is similar to household waste. Over 50% of non-hazardous waste from hospitals is paper, cardboard, and plastics, while the rest comprises discarded food, metal, glass, textiles, and wood. (WHO, (2014). Safe management of wastes from health-care activities, 2nd ed.www.who.int/water_sanitation_health/publications/safe-management-of-wastes-fromhealthcare-activities/en/)
HCWH Europe recommends:
1. Improve healthcare waste segregation
2. Phase down incineration
3. Treat waste within the European Union
4. Improve healthcare recycling rates
5. Build a toxic-free future
6. Protect workers and their rights
Additional information on each of these measures can be found in the attached document.
Read full responseResponse to Measures to reduce microplastic pollution
17 Jan 2022
The European Commission’s proposed initiative to reduce microplastic pollution is an excellent opportunity to introduce ambitious and binding mandatory regulatory action to address this issue.
Urgent action is needed to address the increasing number of microplastics released in the environment and their health and environmental impacts. HCWH Europe urges the European Commission to adopt a precautionary approach and prioritise the most effective action first, namely source-directed interventions such as prevention and reduction, before mitigation downstream, e.g. use-oriented interventions and end-of-pipe capture. Prevention at source should be at the core of this initiative. Supply chain changes in product design as well as production processes and practices will also be needed for effective results.
We encourage the European Commission to include the following important considerations in this initiative.
The definition of microplastics should not include a lower limit for size. Nanoplastics can be even more threatening to health and the environment than microplastics and are very difficult to detect. On-going research also shows that nanoplastics can enter cells and pass the blood-brain barrier. Importantly, the definition needs to include (bio)degradable, water-soluble, and liquid polymers - their degradability is doubtful and their effects on environment and health remain severe. Soluble polymers can be very persistent and toxic in the environment.
The scope of this initiative should cover all the different sources of microplastics, not just the three main sources proposed – secondary microplastics from degradation of larger items also need to be addressed.
While some voluntary approaches already exist, it is clear that they have not succeeded in addressing this growing issue, so we should not rely on them – new legally binding measures are needed.
In addition to the physical release of microplastics, the European Commission must also consider the toxicity of additives present in microplastics and address them accordingly.
The roadmap rightly proposes to correct knowledge gaps, but the focus should be on monitoring and measuring microplastic pollution from all sources in order to prevent it. Harmonising measuring methods can be a complementary action.
In addition to their environmental impact, microplastics are a growing threat to public health due to their proven toxicity, the fact that they are vectors for disease, and their contribution to antibiotic resistance, among others. The healthcare sector itself can also be a large source of microplastics, both primary and secondary, and it should not be exempt from this initiative. Textiles are widely used in healthcare, and especially now as more hospitals are looking to increase their reusable solutions, it is important that the problem of microplastics is tackled. HCWH Europe proposes the following measures.
- Set minimum Ecodesign and consumer-oriented labelling requirements to minimise the tendency to release and generate microplastics from production, use, and end-of-life.
- Mandatory requirements should oblige producers to optimise their manufacturing and fabrics selection to prevent microplastic release during both production and use of the product.
- Improve product design as well as increasing and improving the use of mitigation technologies, e.g. filters, to reduce the wear of products during treatment, washing, and drying.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
27 Oct 2021
Health Care Without Harm (HCWH) Europe welcomes the initiative of having a policy framework for bio-based, biodegradable, and compostable plastics (BBP and BDCP), and fully supports the precautionary approach proposed in the roadmap. While the proposed policy framework is much needed, it is also important to note that BBP and BDCP are not inherently sustainable nor are they in line with the circular economy model, and they should not be seen as a systematic replacement for single-use plastic items, both common use and healthcare-specific. The waste hierarchy should be respected, and prevention and reuse solutions should be the top priority.
There is a growing awareness of the problem of plastics in healthcare, but healthcare facilities are increasingly adopting BBP and BDCP alternatives to replace single-use plastics. This is despite the fact that reusable options are available for many of these products: not only items used in food services, but also healthcare-specific items such as medicine cups, basins or bowls used in surgeries, pharmaceutical packaging, etc. These options are mistakenly seen as environmentally friendly, and the information available can be confusing for some procurers. There is also a growing push from the industry towards environmentally conscious healthcare providers to encourage them to adopt bio-based/biodegradable items. For example, staff at a maternity ward in France wanted to switch to glass containers for artificial milk for babies, and suppliers were promoting bio-based options instead.
Clear definitions, terminology and labels should be created, and vague terms such as ‘bioplastics’ or claims suggesting the absence of plastic should be prevented. Measures should also be taken to ensure that no creative accounting on bio-based content would be allowed - this can be achieved through stricter regulation and monitoring. The term ‘biodegradable’ should be restricted altogether, as it has been done in France (1).
It is also crucial that the policy framework considers the potential presence of toxic chemicals in BBP and BDCP – a recent study has shown that these can present similar in-vitro toxicity to conventional plastics (2). Any BBP and BDCP item put on the market should be toxic-free.
HCWH Europe also encourages the Commission to consider the real and most likely end-of-life scenarios for these items, which are incineration or landfill. In the case of BDCP, it is important to note that many of the tests for biodegradability are conducted in very specific environments that are not often present in natural systems. Compostable plastics should be reserved for very specific applications (e.g. compostable bags for the collection of organic waste) under specific conditions, i.e. that no reuse alternatives exist, and there is adequate infrastructure for separate collection along with a guarantee that compostable plastics can be accepted and treated.
(1) Rethink Plastic Alliance (2021) Moving from single-use plastics: how is Europe doing? Assessment of European countries' transposition of the Single Use Plastics Directive. https://rethinkplasticalliance.eu/wp-content/uploads/2021/06/SUP-Assessment-Design-final.pdf
(2) Zimmermann, L., Dombrowski, A., Völker, C., & Wagner, M. (2020). Are bioplastics and plant-based materials safer than conventional plastics? In vitro toxicity and chemical composition. Environment International, 145, 106066. https://www.sciencedirect.com/science/article/pii/S0160412020320213
Read full responseResponse to Evaluation and revision of the general pharmaceutical legislation
20 Apr 2021
Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission’s inception impact assessment on the evaluation and revision of the general pharmaceutical legislation that aims to ensure access to affordable medicines, foster innovation, and enhance security of supply in the framework of a stronger European Health Union.
We strongly support the revision of the general pharmaceutical legislation as part of the Pharmaceutical Strategy; the European Commission must ensure alignment with the European Green Deal and its zero-pollution ambition for a toxic-free environment as well as with the New Industrial Strategy and its aim of an industry that paves the way to climate-neutrality.
Because of our expertise and mission, we would like to focus our response on the environmental challenges identified under point 5 Vulnerability of supply of medicines, quality, environmental challenges and sustainability. We would also like to comment specifically on policy option J related to supply chain oversight and transparency and policy option K related to environmental sustainability and environmental risk assessments.
Pharmaceutical residues have been found in the environment all over the world, including in the EU, and can have a negative impact on animal and plant life and ecosystems more generally. There is specific evidence of this, such as renal failure in vultures, impaired reproduction in fish, and inhibited growth of aquatic species.
Pharmaceutical pollution is also closely linked to the development and spread of antimicrobial resistance (AMR) – a global health threat that is already responsible for an estimated 33,000 annual deaths in Europe alone. If no effective action is undertaken, research shows that AMR could kill 10 million people a year by 2050 globally.
There is a crucial need to strengthen the EU regulatory framework as active pharmaceutical ingredients (APIs) are still mostly excluded from EU environmental regulations. As global consumption of human and veterinary medicines increases, the problem of pharmaceutical pollution will only get worse. Our detailed comments can be found in the attached document.
Read full responseResponse to Mercury – review of EU law
31 Mar 2021
Health Care Without Harm (HCWH) Europe appreciates the opportunity to provide feedback on the Inception Impact Assessment on the Revision of Regulation (EU) 2017/852 on mercury.
An extremely toxic and persistent metal, mercury is one of the World Health Organization (WHO)’s top ten chemicals of major public health concern. Exposure to mercury – even very small amounts – is a particular threat to children’s development in utero and early life whilst their brains and nervous systems are still forming. It is estimated that within the EU, more than 1.8 million children are born every year with exposures to the most toxic form of mercury (methylmercury) above the limit of 0.58 microg/g, and approximately 200,000 births exceed 2.5 microg/g, a limit proposed by the WHO. Estimates put the total annual benefits of preventing mercury exposure within the EU at more than 600,000 IQ points per year, corresponding to an economic benefit between €8,000 million - €9,000 million per year. [ehjournal.biomedcentral.com/articles/10.1186/1476-069X-12-3].
We strongly support the EU’s plans to phase-out one the largest remaining intentional use of mercury in the EU, dental amalgam, before 2030. As shown in a recent study carried out on behalf of the European Commission by Wood-Deloitte (July 2020), phasing-out dental amalgam is technically and economically feasible. Based on the experience in Sweden - specific medical cases that justify the use of dental amalgam appear to be extremely rare with only one case in 2017 and none in 2018, from a population of 10 million citizens.
We also agree that, without further legislative action, significant amounts of dental amalgam are still expected to be used in the coming years in the EU. We cannot ignore the fact that any continued use of mercury contributes to the existing stock of mercury in the environment in the EU and worldwide, and consequently continued exposure for humans. There is sufficient evidence that mercury is released from dental amalgam from daily erosion and throughout the life of dental fillings. Mercury separators at dental care clinics have a limited effect on limiting leakage of mercury to the environment. For effective long-term reduction, an amalgam phase-out is needed. We support the earliest date considered in the study: 2025. Ambitious measures are necessary to achieve the objective of the Regulation on mercury, i.e. to ensure a high level of protection of human health and the environment from anthropogenic emissions and releases of mercury and mercury compounds. Phasing-out of dental amalgam will also undoubtedly help to achieve Zero Pollution ambition for a toxic-free environment announced in the European Green Deal. It is simply impossible to ensure public health without balanced environmental ambitions.
Dentists should take responsibility for the environmental impacts of their work and contribute as individuals and as associations to EU and global objectives to ultimately end the use of dental amalgam. Dental practitioners, with their expertise and experience, could also further contribute to research on mercury-free and safer materials. Such research would not only assist the EU but also the global community. Unlike dental amalgam, mercury-free materials have been subject to continuous technical improvements in the past years and this trend is expected to continue.
European communities will appreciate phasing-out of amalgam as we strive to protect our planet for future generations.
Read full responseResponse to Revision of the Energy Performance of Buildings Directive 2010/31/EU
18 Mar 2021
Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this IIA.
Our changing climate is already having a significant impact on our health through, for example, extreme weather events, changes in communicable diseases, and respiratory illnesses exacerbated by poor air quality. According to The Lancet, climate change is the “largest public health threat of the 21st Century”. It is, therefore, HCWH Europe’s position that public health must be central in our fight against climate change - the climate crisis is a health crisis.
The EPBD is not compatible with the EU's increased climate ambitions. HCWH Europe supports the Commission's aim to strengthen the existing legal framework under Option 3, with a view to increase the annual energy renovation rate and foster deep energy renovation. HCWH Europe would like to see a stronger focus on public health as a driver for increased ambition and advocates for a carbon neutral Europe by 2040, with a 65% reduction in GHG emissions by 2030. Meeting this ambition requires higher binding energy targets for 2030 and the need to at least triple the current annual energy renovation rate, increasing their depth significantly and moving towards a fully renewables-based energy supply. Additionally, an improved EPBD offers several health co-benefits, such as better protection from heatwaves and cold spells and improved air quality.
Healthcare's climate footprint is equivalent to 4.7% of net EU emissions, and nearly a quarter of this emanates from the energy used in buildings. Improving the efficiency of these buildings through traditional and non-traditional means (e.g. green infrastructure) will reduce emissions, promote better healing and healthier populations, and reduce operating costs. Furthermore, healthcare facilities are amongst the most visible within our communities and offer an excellent opportunity to demonstrate leadership. Healthcare has a significant role in supporting the EU's climate ambitions, particularly by harnessing its market power to influence the construction industry to develop safer, more resilient, greener, and healthier building products and systems. HCWH Europe would therefore advocate for stricter requirements within an earlier time frame being placed upon public buildings, where supported by appropriate investment programmes.
When applied through a broader package of support, EPCs can be a useful tool. Under the current approach, however, Member States have adopted different methodologies to varying standards and transparency. Innovation is being engineered out due to methodological constraints, and consumers have been left unconvinced and confused about their validity and how to apply the results (BPIE, 2020). Revising the EPBD offers an opportunity to strengthen these requirements. Regulations must promote better harmonisation and standardisation, with particular emphasis on methodology, the range of improvement measures included, the ability to incorporate new/innovative solutions and the training and qualification requirements for certifiers. Finally, additional measures should be introduced to ensure EPCs are adopted within a broader framework of support to promote better acceptance and utilisation.
It is vital that a revised EPBD is harmonious with the revised EED and RED and the introduction of mandatory green public procurement targets in line with the new Circular Economy Action Plan. In particular, these Directives should work together to remove inefficient, fossil fuel-based installations from our buildings by banning these in new buildings and phasing them out of existing buildings.
Finally, a revised EPBD must be accompanied by broader enabling measures that reduce/remove the non-regulatory barriers to energy renovations, e.g. reducing upfront costs, raising public awareness, and upskilling the construction sector. Such measures might include financial incentives, advisory services, toolkits, and technical assistance.
Read full responseResponse to EU strategy for sustainable textiles
2 Feb 2021
We welcome the European Commission recognising the urgent need to build an EU textiles strategy that will move the textile sector towards a carbon neutral, toxic-free, circular economy. As a network of European hospitals and healthcare providers, healthcare systems and local authorities, HCWH Europe emphasises the importance of expanding the circularity of products and materials used in the medical sector. How we currently produce, use, and dispose of these products is emblematic of our linear economy. The global healthcare sector accounts for 4.4% of total global carbon emissions, and evidence also shows that the supply chain drives 75% of emissions within EU healthcare. HCWH Europe strongly recommends better alignment between decarbonisation and dematerialisation policies.
We focus our feedback on technical textiles - an umbrella term for a plethora of textiles used for function and performance. Technical textiles are used in a broad range of industries, including healthcare and medical where they play a very important role. Common medical textiles applications include patients’ linen, bedding, surgical gowns and aprons, uniforms, caps, masks, surgical drapes. This sub-category of technical textiles also includes personal protective equipment (PPE) such as masks or respirators, which play a pivotal role in the current COVID-19 pandemic. Currently, the overwhelming majority of medical textiles used in the EU are disposable and these resources are lost after their first use. Their production causes significant environmental, climate, and social impacts through the consumption of resources, water, land and chemicals as well as emitting greenhouse gases and pollutants.
The COVID-19 crisis has clearly revealed the desperate need for a sustainable approach to providing and using/re-using PPE. The medical textile industry now has an opportunity to increase production and/or design new types of environmentally sustainable protective clothing that help us prepare for future crises, that would be washable and reusable, and therefore reduce the resources used and amount of medical waste contributing toward environmental pollution. Improving supply chain resilience and reducing the environmental and climate impacts of textile production and use - whilst maintaining economic and social benefits — requires a systemic change towards circularity. A coordinated and harmonised response at EU level is needed to address structural change towards sustainable design, production, consumption and disposal of technical textiles.
Our detailed comments can be found in the attached document.
Read full responseMeeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and
20 Jan 2021 · Discussion on minimum sustainability criteria for public procurement
Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and European Environmental Bureau and
20 Jan 2021 · VC Meeting - Discussion on minimum sustainability criteria for public procurement.
Response to Commission Regulation amending Annex XIV to REACH
5 Jan 2021
Health Care Without Harm (HCWH) Europe supports the European Commission’s proposal to update Annex XIV of the REACH Regulation for the phthalates DEHP, DBP, BBP, and DIBP (plasticisers) due to their endocrine disrupting properties.
Over the last 20 years, HCWH Europe and HCWH US have campaigned for the reduction of products containing hazardous chemicals and use of safer alternatives in healthcare. [1,2,3,4] Bis (2-ethylhexyl)phthalate (DEHP) is one of the most well-studied harmful substances and is still present in a number of medical devices.
HCWH Europe promotes the substitution of harmful substances in medical devices by demonstrating that many alternatives with safer toxicological profiles are available on the market. In Europe, phthalate-free or PVC-free medical devices are available for nearly all product categories except blood bags for red blood cells. [5, 6]
Progressive manufacturers, health systems, hospitals, and health practitioners have been leading this change so far. Many European healthcare providers have already moved to eliminate DEHP and PVC from healthcare practice and HCWH Europe has highlighted a number of examples in recent years. [4, 5] The proposal to update the entries in Annex XIV to the REACH Regulation for DEHP is a much awaited and welcomed regulatory action that will accelerate the move towards substitution of this harmful chemical.
On this occasion HCWH also strongly encourages medical device manufacturers to switch, whenever possible, directly to PVC-free alternatives. HCWH’s recent report [7] outlines up-to-date research on the hazard of phthalates, particularly DEHP, but also recognises the importance of reducing PVC (vinyl) because of hazards associated with every stage of the life cycle of the material: production, use, and disposal.
In Europe, the Vienna Hospital Association hospitals and Stockholm County hospitals serve as excellent examples of PVC and phthalate elimination. [3]
Notably, more and more industrial customers are already asking us about PVC alternatives, which is often driven by the requirements of hospitals. This trend is likely to intensify. [8]
References
[1] https://noharm-uscanada.org/issues/us-canada/scientific-reports-phthalates
[2] https://noharm-uscanada.org/issues/us-canada/take-action-reduce-pvc-and-dehp
[3] Health Care Without Harm Europe. (2007) PVC/DEHP phase-out is possible anywhere in Europe: Model hospitals show how to succeed. https://noharm-europe.org/sites/default/files/documents-files/2675/PVC_DEHP_Phase-Out_Europe.pdf]
[4] Health Care Without Harm Europe. (2014) Non-toxic Healthcare: Alternatives to Phthalates and Bisphenol A in Medical Devices. https://noharm-europe.org/EDCs-report
[5] Health Care Without Harm Europe. (2019) 2nd edition of Non-toxic Healthcare: Alternatives to Phthalates and Bisphenol A in Medical Devices. https://noharm-europe.org/sites/default/files/documents-files/6154/2019-12-03_HCWH_Non_Toxic_Healthcare_2_WEB.pdf
[6] Disposable bags, tubes and accessories for health care. https://www.nordic-ecolabel.org/product-groups/group/?productGroupCode=098
[7] Health Care Without Harm. (2020) Polyvinyl chloride in health care A rationale for choosing alternatives. https://noharm-uscanada.org/sites/default/files/documents-files/6222/Polyvinyl chloride in health care - A rationale for choosing alternatives - 1-31-2020.pdf
[8] https://www.raumedic.com/topics/pvc-free-plastic-solutions
Read full responseResponse to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil
26 Oct 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission’s roadmap for the EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil – building a Healthier Planet for Healthier People”.
The EU needs to fully integrate and mainstream the zero-pollution ambition into all its policy developments, and must aim for a genuine minimisation of pollution from chemicals and products harmful to the environment and health. This ambition must apply to all sectors – the healthcare sector should not be exempt.
Harmful chemicals can be found in a wide range of products used in healthcare settings – disinfectants, medical devices, furniture, electronic equipment, solvents, pharmaceuticals, and food products – all of which can pollute the environment and negatively affect human health.
Reducing pollution must be combined with a phase-out of hazardous substances in product design (especially where viable and cost-effective alternatives already exist), and with initiatives supporting better treatment and disposal practices of healthcare waste. The World Health Organization (WHO) points to the incineration of healthcare waste as a source of dioxins, furans, and particulate matter emissions that pollute our air.
The current COVID-19 crisis has increased recognition on the importance of the healthcare industry and that the products fundamental to the delivery of modern healthcare are essential to society safety and health. In particular, this crisis has revealed the urgency to ensure strong protection of citizens’ health and the importance of decoupling economic growth from the increase of pollution and resource consumption.
The volume of healthcare-related products and consequent volume of medical waste is rising steadily – not only due to a growing population and increase in patients, but crucially because the healthcare sector has become more and more reliant on single-use items and products with disposable packaging.
The healthcare industry must intensify its efforts towards clean energy, substitution with safer chemicals, greener pharmaceuticals, safer and clean production, and ultimately ensure higher safety, circularity, durability, and sustainability of their products.
Our detailed comments can be found in the attached document.
Read full responseResponse to Industrial pollution - revision of the European Pollutant Release and Transfer Register
23 Oct 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission’s inception impact assessment on the European Pollutant Release and Transfer Register (E-PRTR) that aims to help achieve the objectives of the European Green Deal on biodiversity, circular economy, climate neutrality, and zero pollution.
We would particularly like to express our support for aspect 3 “Inclusion of additional pollutants” described in the inception impact assessment and call for the inclusion of Active Pharmaceutical Ingredients (API) emissions that can be discharged by pharmaceutical manufacturers during the production process within the scope of the E-PRTR.
Regulation EC 166/2006 already imposes a reporting obligation to “installations using a chemical or biological process for the production on an industrial scale of basic pharmaceutical products” under Article 3(a), but this does not apply for APIs which are not included in Annex II despite high risk for the environment and human health.
There is scientific evidence that even low concentrations of pharmaceuticals in the environment have harmful effects on animal and plant life, including renal failure in vultures (1), impairment of reproduction in fish (2), and inhibition of growth of certain aquatic species (3). Some also accumulate in fish, livestock, and vegetables as well as enter our drinking water.
UN Environment also identified the discharge of drugs and particular chemicals into the environment as one of the most worrying health threats today (4) as they can contribute to the development and spread of antimicrobial resistance (AMR), which is annually responsible for an estimated 33,000 deaths (5) and more than €1.5bn in healthcare costs and productivity losses (6) in the EU.
Pharmaceuticals can enter the environment throughout their life cycle, including during the production stage. The discharge of APIs during the pharmaceutical manufacturing process is a particularly serious issue in third countries but pollution downstream from manufacturing facilities has also been observed in the EU and has been subject to increasing attention (7).
As the EU considers bringing strategic pharmaceutical production back to Europe, it is increasingly crucial that the E-PRTR captures discharges of APIs from manufacturing facilities to provide easily accessible, key environmental data in order to allow for proper scrutiny and ensure that polluting companies are held to account.
This data would also provide useful evidence in relation to objective 2 of the Strategic Approach to Pharmaceuticals in the Environment and to challenge 7 of the roadmap to the Pharmaceutical Strategy as well as support necessary actions to meet the zero-pollution ambition at the core of the European Green Deal.
(1) https://journals.plos.org/plosbiology/article?id=10.1371/journal.pbio.0040066
(2) https://pubmed.ncbi.nlm.nih.gov/15579420/
(3) https://pubmed.ncbi.nlm.nih.gov/21919043/
(4) https://www.unenvironment.org/news-and-stories/press-release/antimicrobial-resistance-environmental-pollution-among-biggest
(5) https://www.thelancet.com/journals/laninf/article/PIIS1473-3099(18)30605-4/fulltext
(6) http://www.ec.europa.eu/commfrontoffice/publicopinion/index.cfm/ResultDoc/download/DocumentKy/84386
(7) https://ec.europa.eu/info/sites/info/files/study_report_public_consultation_pharmaceuticals_environment.pdf
Read full responseResponse to Persistent organic pollutants - annex I amendment
29 Sept 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to provide feedback on this Draft delegated regulation, we are disappointed however, that the process leads to a new exemption for perfluorooctanoic acid (PFOA) applicable to medical devices.
The Stockholm Convention includes an exemption for invasive and implantable medical devices, as well as for medical textiles.[1] Civil society had already expressed concerns about existing derogations and how they were granted.[2] By introducing the Unintentional Trace Contaminant level of 2 mg/kg for medical devices other than implantable devices and invasive devices, the EU regulation will in fact allow a substantial level of PFOA in all medical devices on the EU market, for at least next 2 years.
PFOA is linked to major health issues such as kidney and testicular cancer, and thyroid disease. Evidence shows that humans are in danger of exposure to trace quantities of PFOA (above intake of 4.4 nanogram per kilogram of body weight per week.[3] The EU limit value in drinking water has been proposed as 100 nanogram per litre, yet the “trace” quantities to be allowed in medical devices are in range of milligrams (1,000,000x higher). A logical doubt arises if contaminant should be still considered as “trace” contaminant in such case.
The restriction dossier developed by Germany and Norway submitted in 2014 proposes a threshold of 0.002 mg/kg for PFOA and PFOA related substances in order to ensure that these substances were not intentionally applied.
During the Stockholm Convention POPs Review Committee evaluation, MedTech Europe estimated the total intentional use of PFOA or related substances in all medical devices (500,000 medical technologies) is 20g between 2015 – 2030.[4] [5] Additionally considering the size of the European market, this level of 2mg of unintended contamination per kg of device mass is very high and simply unacceptable.
The Draft delegated regulation states that “some of the articles (including some critical to treat patients) contain PFOA and its salts above the allowed limit of 0.025mg/kg” – yet not one example of such medical device is demonstrated. It would be beneficial to grant an exemption only for individual products that provide a critical application and have no PFOA-free alternatives, as opposed to a whole group of articles under a generic name of non-invasive and non-implantable devices.
Releases of PFOA and related compounds into the environment occur throughout products’ life cycles (manufacture, use, and disposal). Human exposure to PFOA typically takes place during consumption of contaminated drinking water and food, inhalation of contaminated indoor air and dust, or from consumer products containing PFOA, its salts and related compounds. In fact, a large proportion of the European population already exceeds safety levels.[3]
No one is in favour of disrupting the supply of lifesaving and life enhancing medical technologies, but it is regrettable that this argument is used by the medical devices industry to excuse the non-compliance within their supply chains and to push for a last-minute exemption for a broad category of products.
It must be ensured that EU laws are properly enforced, data is disclosed, and that unnecessary pollution is avoided especially if we are to achieve the EU’s ambition of a zero pollution and a toxic-free future.
REFERENCES
[1] UNEP/POPS/COP.9/30
[2] https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12057-Amendment-of-Regulation-EU-2019-1021-on-persistent-organic-pollutants-as-regards-the-listing-of-PFOA-in-Annex-I/F501740
[3] https://www.efsa.europa.eu/en/efsajournal/pub/6223
[4] https://www.medtecheurope.org/resource-library/the-european-medical-technology-industry-in-figures-2019/
[5] UNEP-POPS-POPRC13FU-SUBM-PFOA-MedTechEurope.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this Inception Impact Assessment proposal. We believe that the EU should commit to more ambitious climate and energy targets to limit temperature increases to 1.5°C and safeguard the environment, safety, and prosperity of people in Europe and worldwide. HCWH Europe would like to see a stronger focus on public health as a driver for increased ambition, and advocates for a Europe that is carbon neutral by 2040, with a 65% reduction in GHG emissions by 2030.
Our changing climate is already having a significant impact on our health through, for example, extreme weather events, changes in vector-borne diseases, and respiratory illnesses exacerbated by poor air quality. According to The Lancet, climate change represents the “largest public health threat of the 21st Century.” It is, therefore, HCWH Europe’s position that public health must be central in our fight against climate change - the climate crisis is a health crisis.
In tackling the coronavirus pandemic, European leaders have demonstrated that they are willing to make difficult decisions and do all that is necessary to protect the health of their citizens. The same principle must apply to tackling the climate emergency if we are to keep global temperatures below 1.5°C.
As it stands, the targets currently outlined within the Renewable Energy Directive (RED) are not compatible with the Paris Agreement, nor the forthcoming changes to the EU's climate target - a greater level of ambition is needed. HCWH Europe advocates for an increase to the EU's renewable energy targets to at least 50% by 2030 and 100% by 2050, and that such targets should be binding.
To facilitate this acceleration, it is vital that the EU address any real or perceived barriers that hinder uptake of renewable technologies and we believe that reframing the renewable energy agenda as a public health issue can strongly support this. For example, by introducing health impact assessments for the development and construction of any new energy infrastructure. Furthermore, it is clear from the National Energy & Climate Plans that not all member states approach the introduction of renewable technologies with the same level of enthusiasm, presenting a clear need for binding national targets.
HCWH Europe welcomes the health considerations noted within the IIA, however, greater emphasis needs to be placed on health and the healthcare sector. Increasing Europe's ambition and accelerating the roll-out or renewable technologies will help to reduce energy poverty and pollution, both of which will improve health, quality of life and wellbeing, and reduce the associated burdens on healthcare systems.
The public sector has a significant role to play in terms of leadership. Any revision of the RED should also give greater support to public bodies, such as public health services, to lead on this transition. Furthermore, it should consider placing specific requirements/targets on the healthcare sector to drive this leadership and realise the benefits of incorporating renewable technologies, including reduced greenhouse gas emissions, lower operating costs, and improved resilience through greater energy security.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
21 Sept 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this Inception Impact Assessment proposal. We believe that the EU should commit to more ambitious climate and energy targets to limit temperature increases to 1.5°C and safeguard the environment, safety, and prosperity of people in Europe and worldwide. HCWH Europe would like to see a stronger focus on public health as a driver for increased ambition, and advocates for a Europe that is carbon neutral by 2040, with a 65% reduction in GHG emissions by 2030.
Our changing climate is already having a significant impact on our health through, for example, extreme weather events, changes in vector-borne diseases, and respiratory illnesses exacerbated by poor air quality. According to The Lancet, climate change represents the “largest public health threat of the 21st Century.” It is, therefore, HCWH Europe’s position that public health must be central in our fight against climate change - the climate crisis is a health crisis.
In tackling the coronavirus pandemic, European leaders have demonstrated that they are willing to make difficult decisions and do all that is necessary to protect the health of their citizens. The same principle must apply to tackling the climate emergency if we are to keep global temperatures below 1.5°C.
As it stands, the targets currently outlined within the Energy Efficiency Directive (EED) are not compatible with the Paris Agreement, nor the forthcoming changes to the EU's climate target - a greater level of ambition is needed. HCWH Europe advocates for an increase to the EU's 2030 energy targets to at least 45% for energy savings, and that such targets should be binding.
HCWH Europe welcomes the health considerations noted within the IIA, however, greater emphasis needs to be placed on health and the healthcare sector. Increasing Europe's ambition and accelerating energy efficiency activities will reduce energy poverty, create healthier and warmer homes and reduce air pollution, all of which will improve health, quality of life and wellbeing, and reduce the associated burdens on healthcare systems. The healthcare sector itself also stands to gain through reduced greenhouse gas emissions, lower operating costs, and improved resilience and energy security.
The public sector, including healthcare, has a significant role to play in terms of leadership. Article 5 ('Exemplary role of public bodies’ buildings') requires more weight. There is an opportunity to place more stringent requirements on the public sector with regards to the construction and renovation of public buildings.
Any revision of the EED, needs to be done through a lens of achieving 100% of our energy from renewable sources. With that in mind, Article 14 ('Promotion of efficiency in heating and cooling') is no longer compatible, given that many cogeneration facilities rely on natural gas as their primary source of fuel. This section therefore needs to be revised to account for a greater ambition for renewable technologies.
Read full responseResponse to Empowering the consumer for the green transition
27 Aug 2020
Health Care Without Harm (HCWH) Europe welcomes and supports the CEAP initiative to strengthen the role of consumers in the green transition by improving the availability of products environmental information and increasing protection against misleading claims.
Regardless of which proposed policy option the European Commission agrees on, it is essential that healthcare products are considered. We must ensure that the environmental footprint of these products is acknowledged and addressed. The production, consumption, and disposal of many healthcare products pollute the environment, with severe consequences for human health; harmful chemicals in a wide range of healthcare such as disinfectants and pharmaceuticals pollute the environment and negatively affect human health. This is especially relevant in these times when consumers are increasingly using products such as PPE and disinfectants.
We strongly encourage the Commission to consolidate the capacity for sustainable purchases by improving available information for consumers and protecting them from misleading product claims. This would greatly facilitate purchasing sustainable products, strengthen demand for green products, and stimulate markets for climate-neutral and circular products and services.
Providing reliable and comprehensive information on environmental characteristics should be a mandatory requirement for all products available on the EU market, including healthcare products. The 16 indicators from the Environmental Footprint methods should be used assess the sustainability of a product. HCWH understands the complexity of such an endeavor, and suggests starting with providing reliable environmental information for products with the highest environmental footprint or that are most commonly found on the market. The final goal, however, should be that all products have this information available in the future.
We welcome the second policy option proposed in the roadmap and support the implementation of a new stand-alone consumer protection instrument that would impose strict requirements and regulate information regarding products’ environmental characteristics – this would effectively control and prevent attempts of greenwashing. Under this new instrument, greenwashing should be clearly defined and prohibited, and companies should be held accountable for breaching it.
More comprehensive feedback on greenwashing and companies’ sustainability claims can be found in our response to the EC public consultation Roadmap on Environmental performance of products & businesses – substantiating claims.
Read full responseResponse to Environmental claims based on environmental footprint methods
27 Aug 2020
Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission introducing a standard methodology for assessing products’ environmental impacts and requiring companies to substantiate environmental claims. This initiative is relevant for our members who are in need of a strong and coherent product policy framework for environmental claims that can protect and empower not only consumers, but also public procurers. Please, find our detailed feedback attached.
Read full responseResponse to Sustainable use of pesticides – revision of the EU rules
4 Aug 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to provide feedback on this initiative to reduce overall pesticide use and encourage a wholesale transition to nature-friendly farming. Our detailed contribution can be found in the PDF attached.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
4 Aug 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to provide feedback on packaging requirements and other measures to prevent packaging waste. Our detailed contribution can be found in the PDF attached.
Read full responseResponse to Pharmaceutical Strategy - Timely patient access to affordable medicines
6 Jul 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission roadmap on a Pharmaceutical Strategy for Europe. The Strategy provides a unique opportunity to make the pharmaceutical sector more transparent and ensure environmental sustainability in line with the European Green Deal and the New Industrial Strategy for Europe.
We agree that is necessary to adopt an approach covering the whole life-cycle of pharmaceutical products and welcome the acknowledgement that “the way environmental risks are addressed needs to be improved”. Because of our expertise and mission, we would like to focus our response on this specific challenge.
Medicines are not an ordinary commodity. They are used to diagnose, treat, and prevent diseases. At the same time, pharmaceutical residues can enter the environment throughout their life cycle and impact terrestrial and aquatic ecosystems. They can accumulate in fish, livestock, and vegetables as well as enter our drinking water.
Pharmaceutical pollution is also closely linked to the development and spread of antimicrobial resistance (AMR) – a global health threat that is already responsible for an estimated 33,000 annual deaths in Europe alone. If no effective action is undertaken, research shows that AMR could kill 10 million people a year by 2050 globally.
771 different pharmaceutical substances have been detected in the environment across the world to date. As global consumption of human and veterinary medicines increases, this problem will only get worse. And yet, active pharmaceutical ingredients (APIs) are still mostly excluded from EU environmental regulations.
The Strategy provides an opportunity to address the impact of medicinal products on the environment and human health. This requires both legislative and non-legislative measures to mitigate environmental risks towards a toxic-free environment. These measures should promote responsible and transparent production, procurement, consumption, and disposal of pharmaceuticals.
In this context, HCWH Europe, as a network of European hospitals and healthcare providers, healthcare systems, and local authorities, calls on the Pharmaceutical Strategy to support an innovative, responsible, and transparent pharmaceutical industry that ensures zero-discharge from production and mitigates its environmental footprint and that of its products.
Our detailed comments can be found in the attached document.
Read full responseResponse to Chemicals strategy for sustainability
20 Jun 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on the European Commission roadmap on a Chemicals strategy for sustainability. The European Commission now has a golden opportunity to set out a long-term chemicals strategy that genuinely prioritises health and environmental protection under the European Green Deal.
We agree that the current Covid-19 crisis “increases the urgency to step up action in the chemicals area in order to ensure that stronger protection of citizens’ health will also enable and support the socio-economic recovery of the European industry producing and using chemicals essential to society and health”. We welcome the parallel recognition of products fundamental in the healthcare sector (medical equipment, pharmaceuticals, disinfectants)” as those being essential to society safety and health.
We however caution against misusing the Covid-19 crisis as a reason for “increasing production of chemicals in Europe” without, first and foremost, ensuring adequate enforcement and compliance with existing legislation, and addressing a number of gaps, weaknesses and challenges that EU chemical policies still need to tackle. The Covid-19 pandemic has revealed the urgent need to shift to a more holistic approach to the production and management of chemicals. An effective chemicals strategy must aim at genuine minimisation of the production, emission and use of chemicals harmful to environment and health, and those used in the healthcare sector should not be exempted.
The EU’s support for medical equipment, pharmaceuticals or disinfectants should not take place through business as usual, i.e. through increased production of chemicals and supplies (placing a higher number of existing products on the market). Research and innovation towards more safe and sustainable alternatives should be a priority. The COVID-19 pandemic has highlighted challenges around availability of personal protection equipment (PPE) and has demonstrated how disastrous consequences our dependence on single-use / disposable products can be in terms of compromising care of patients and safety of healthcare workers. Generation of enormous amounts of waste, as a result of such practice, should not be ignored either.
The chemicals strategy must recognise that it will require a tremendous innovation to move away from hazardous chemicals in the healthcare sector, where a wide range of products – including disinfectants, medical devices, medical textiles, and electronic equipment – contain harmful chemicals which are polluting the environment and negatively affect human health. Many of those products (and therefore chemicals used therein) are recognised as essential because they provide for vital functions for society. However, the “essentiality” of hazardous chemicals should not be considered as permanent; rather, constant efforts are needed to search for safer alternatives. Withdrawing or minimising exemptions for substances of very high concern in medical products will encourage industry to intensify their efforts towards safer substitution, and ultimately ensure higher safety, circularity, and sustainability of those products.
In this context, HCWH Europe, as a network of European hospitals and healthcare providers, healthcare systems and local authorities, calls on EU policy makers to support an innovative and responsible industry that shifts its production to more circular solutions, of which safety and sustainability is well proven before being placed on the market.
This will ensure that the chemicals strategy will play an important role in the development and implementation of technologies necessary to transform the healthcare sector into a more circular model.
Our detailed comments can be found in the attached document.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
27 Apr 2020
Health Care Without Harm (HCWH) Europe welcomes the objective of creating a taxonomy to help identify economic activities considered environmentally sound to support the EU’s goal to reach carbon neutrality in 2050.
As a civil society organisation promoting circular economy and sustainable climate-friendly solutions in healthcare, HCWH recommends better alignment between decarbonisation and dematerialisation policies, and support for economic activities that accelerate the transition to a circular economy in which products are designed for sustainability, materials are reused and recycled, and waste is prevented. Such measures would also directly contribute to achieving the EU’s zero pollution strategy.
Increasing quantities of waste are used sometimes as a justification for their use as a feedstock in electricity generation, and Waste-to-energy (WtE) incineration is erroneously promoted as a low-carbon source of energy. A number of reports indicate that much of what is currently used as incinerator feedstock could instead be recycled or composted, resulting in carbon savings and other environmental benefits (1). Reductions of materials input through reuse and recycling would require less energy, in turn reducing pollution and greenhouse gas emissions. Waste incineration requires a constant flow of materials and creates therefore a lock-in effect for linear economy. Technology based on the burning of waste by definition contradicts the EU’s efforts towards circular economy and targets related to waste prevention.
Moreover, CEWEP (Confederation of European Waste-to-Energy Plants) states that WtE plants fulfil the task of destroying microbiological pollutants (like viruses) and this is imperative in connection with the COVID-19 epidemic.
HCWH strongly disagrees with the use of the current pandemic as an argument for WtE as a sustainable activity for health and the environment. Waste associated with COVID-19 should be managed no differently than other infectious waste. Both the World Health Organization and the United Nations Environment Program (UNEP) have endorsed steam-based or other non-incineration methods of disinfection over incineration because of the persistent organic pollutants (POPs) produced by incineration. Incineration is also a great deal more expensive than steam-based technologies and also has a higher carbon footprint. Trapping energy from the burning of waste materials is the most polluting and expensive form of energy generation (2).
WtE must therefore be excluded from the EU Green Taxonomy.
References:
1. The impact of Waste-to-Energy incineration on climate. Policy Briefing. September 2019 – Zero Waste Europe. https://zerowasteeurope.eu/downloads/the-impact-of-waste-to-energy-incineration-on-climate/
2. Health Care Without Harm | Coronavirus update: Health care waste management factsheet
https://noharm-global.org/documents/health-care-waste-management-coronavirus-update
Read full responseResponse to 2030 Climate Target Plan
15 Apr 2020
Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this Inception Impact Assessment proposal. We believe that the EU should commit to more ambitious climate and energy targets to limit temperature increases to 1.5°C and safeguard the environment, safety, and prosperity of people in Europe and worldwide. HCWH Europe would like to see a stronger focus on public health as a driver for increased ambition, and advocates for a Europe that is carbon neutral by 2040, with a 65% reduction in GHG emissions by 2030.
Our changing climate is already having a significant impact on our health through, for example, extreme weather events, changes in vector-borne diseases, and respiratory illnesses exacerbated by poor air quality. According to The Lancet Countdown, climate change represents the “largest public health threat of the 21st Century.” It is, therefore, HCWH Europe’s belief that public health must be central in our fight against climate change - the climate crisis is a health crisis.
In tackling the coronavirus pandemic, European leaders have demonstrated that they are willing to make difficult decisions and do all that is necessary to protect the health of their citizens. The same principle must apply to tackling the climate emergency if we are to keep global temperatures below 1.5°C.
General
Section B of the proposal lists a number of key topics that will be addressed through this impact assessment, but does not explicitly include health. We believe public health should be included and should take centre stage in the outputs presented.
In terms of outputs, the assessment should consider the changes needed to ensure the alignment and integration of climate and health policies. Additionally, it is important to recognise the purchasing power of the European healthcare (and wider public) sector and assess how this might be used to drive demand for low carbon products, services and works.
Economic impacts
Accelerating GHG reductions brings a number of health-related economic benefits across the medium to long terms, and these should be considered within the impact assessment. Reducing fossil fuel combustion in the energy and transport sectors, for example, should improve air quality and reduce the associated health impacts. This in turn should bring economic benefits in terms of higher economic productivity (due to fewer sick days) and reduced healthcare costs. Additionally, increased mitigation efforts might bring longer term economic benefits, such as reducing the risk of climate-related extreme weather events.
There is significant opportunity for decarbonising healthcare by 2030, particularly in terms of buildings and transport; the sector has a key role to play in meeting a more ambitious target. Careful consideration, however, should be given to supporting policies (e.g. EPBD, ETS, etc.) and the impact these might have on the sector without clear support for investment. For example, the majority of hospitals operating out to 2030 will have already been built and will therefore fall out with the EPBD's energy requirements. Additionally, reducing ETS thresholds or including a wider range of non-domestic buildings could have a negative financial impact in the short term. Furthermore, with so many vehicles on the road operating as a result of healthcare operations (NHS England estimates 1 in 20 vehicles), this proposal should consider how the EU can best support an acceleration in the uptake of renewables in the transport sector and encourage a reduction in road traffic.
Social impacts
HCWH Europe welcomes the considerations given to public health and wellbeing, however, a broader view, beyond just air quality is necessary to allow for more robust decision making. For example, other factors that positively impact the health and wellbeing of citizens include increased energy efficiency, reduced energy costs, healthier buildings, and reduced risk from climate-related extreme weather events.
Read full responseMeeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)
15 Apr 2020 · To discuss the zero-pollution action plan
Response to Revision of Non-Financial Reporting Directive
26 Feb 2020
Health Care Without Harm (HCWH) Europe welcomes and supports the revision of the Non-Financial Reporting Directive and provides feedback to ensure that the future legislation contributes to the sustainable development agenda. The NFRD can support increased green investment, sustainable public procurement, and responsible consumption. Our detailed contribution can be found in the PDF attached.
Read full responseResponse to Climate Law
5 Feb 2020
Health Care Without Harm (HCWH) Europe welcomes proposals to enshrine the EU's ambition for climate neutrality by 2050 in law. Furthermore, we support aims to transform the way in which EU policies are made and to set the long-term vision for meeting the 2050 objective through all policies, in a socially-fair and cost-efficient manner. Pease find our full feedback in the attached file.
Read full responseMeeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)
27 Jan 2020 · The role of healthcare in the Green Deal
Response to A new Circular Economy Action Plan
20 Jan 2020
HCWH Europe welcomes and supports the New Circular Economy Action Plan and would like to provide feedback to ensure that the plan contributes to reducing the negative health and environmental impact of the products used in the healthcare sector. Our detailed contribution can be found in the PDF attached.
Read full responseResponse to Fitness Check on endocrine disruptors
10 Jul 2019
Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on this Roadmap.
The measures taken so far by the EU to ensure a high level of protection of human health and the environment from endocrine disrupting chemicals (EDCs) are not sufficient. The 2018 European Commission Communication "Towards a comprehensive European Union framework on endocrine disruptors" should in no way be considered an update of the 1999 Community Strategy for EDCs. This 11-page document fails to provide any proposal for specific measures, a timeline, targets, an action plan, or a budget.
Concrete action to prepare the next European strategy on endocrine disrupting chemicals (EDCs) is long overdue and urgently needed. The EU chemicals legislation must govern all types of EDCs to minimise the overall exposure to endocrine disruptors. Protecting specific population groups that are particularly vulnerable to EDCs such as unborn children and adolescents should be a focal point.
The Fitness Check should also ensure that all provisions on EDCs are fit for purpose to guarantee a clean circular economy and a non-toxic environment.
Our detailed contribution can be found in the PDF attached.
Read full responseResponse to Establishment of a methodology of measurement of food waste
4 Apr 2019
As a stakeholder of the EU Platform on Food Losses and Food Waste, Health Care Without Harm (HCWH) Europe recognises that food waste is a global problem. One that needs to be addressed to advance social justice, build community wealth, fulfil food and nutrition needs, and ensure environmental sustainability. For this reason, we welcome this consultation and the ambition to work towards a methodology to measure food waste along the food supply chain, differentiating between diverse sectors.
More attention, however, must be given to the healthcare sector, which faces higher levels of food waste than other food service sectors due to its unique challenges. For example: customised dietary options based on medical conditions, unpredictable changes in patients’ appetites, the unpredictable number of patients and visitors, extended hours of service; and varying snack and meal times. All these factors mean that food waste in healthcare settings is a complex issue requiring technical expertise, careful execution, and the involvement of staff, patients, and visitors.
Despite these challenges, we know that food waste in the healthcare sector can be reduced and could offer cost savings (please find good practice examples on www.foodforhealthcare.org/case-studies). Hospitals and health systems could re-invest these savings in procuring high quality, healthy, and sustainable food, therefore reducing malnutrition and the environmental impacts of their food service.
For this reason, HCWH Europe recommends:
1. A clear, consistent, and more specific methodology for measuring food waste across all levels (national, regional, and local) and sectors (including healthcare) in order to benchmark performance.
2. Food waste should also be measured in economic costs, including environmental and social externalities, and these should be measured across the life-cycle of food and food products.
3. A comprehensive online platform should be used to measure and monitor food waste, and tools and resources should be made available to not only measure food waste but to also support actions for preventing and reducing food waste.
4. Food waste measurement methodologies should be linked to binding food waste targets at the national, local, and/or sectoral level, to encourage prevention and reduction. Food waste also needs to be tackled more holistically across policies such as the Circular Economy Package and the Common Agricultural Policy. We therefore encourage the European institutions to fundamentally rethink, and create connections between their policies to encourage circularity and prevent and reduce food waste.
5. As food waste continues along the whole food supply chain, including primary production; guidelines should be created that enable Member States to at least voluntarily measure their food waste at all stages of the food supply chain. Such guidelines should also include harvesting to help reduce economic losses to farmers and address the increasing impacts of intensive agriculture upon the planet and our health.
Given its size and economic and social influence, the healthcare sector is well placed to lead on preventing food waste, starting with measurement. By implementing healthy and sustainable food strategies, healthcare providers can improve public and environmental health and begin to address socio-economic disparities that exist within our communities.
Yours sincerely,
HCWH Europe
Read full responseMeeting with Vytenis Andriukaitis (Commissioner) and
1 Jun 2018 · Pharmaceuticals in the environment
Response to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)
9 Nov 2017
Health Care Without Harm Europe is a non-profit European coalition of hospitals, healthcare systems, healthcare professionals, local authorities, research/academic institutions and environmental and health organisations. It currently has 84 members in 26 countries of the WHO European Region, including 17 Member States of the European Union.
Having reviewed the Roadmap, we still would raise a few points. Firstly, will the pollutant limit levels be set taking into account the purpose of the re-use of the waste water? This question should also be clarified as regards sludge.
Quality standards for the urban waste water should be established depending on the purpose of the re-use of the waste water. These standards should also take into account the presence of new types of pollutants. Is the list of pollutants capturing the risks present in today’s environment and addressing the resulting health risk?
The Directive should include provisions regarding limiting discharges of priority substances – hazardous substances, including pharmaceuticals, and also for bacteria. These measures would also help contain the spread of AMR. And this would, in turn, ensure an appropriate quality of the water downstream in urbanised zones. In short, a more stringent set of UWWT requirements should be considered.
We feel that this exercise should also strive for a greater policy coordination between this and other relevant EU instruments regulating water use (e.g. the Water Framework Directive). This would be a way to address the challenge of the emerging pollutants.
Read full responseResponse to Strategic approach to pharmaceuticals in the environment
22 May 2017
Health Care Without Harm Europe (HCWH) Europe is a European network of hospitals and healthcare systems, local authorities, healthcare professionals, and environmental and health organisations. HCWH Europe is a non-profit, membership-based organisation, located in Brussels that currently counts 82 members in 25 European countries (WHO Europe region), of which 16 are Member States of the European Union. www.noharm-europe.org
HCWH Europe’s mission is to transform the healthcare sector worldwide so that it becomes environmentally sustainable and no longer a source of harm to the environment and human health. HCWH Europe leads the only Europe-wide campaign addressing the issue of pharmaceutical residues in the environment and their environmental impact: Safer Pharma (www.saferpharma.org). The aim of this campaign is to achieve new EU legislation that will curb pharmaceutical pollution, and EU laws that will take action towards a measurable reduction of pharmaceuticals in the environment.
HCWH Europe welcomes the roadmap proposals, and in particular the important recognition of:
-The expansion of the strategic approach to address pharmaceutical pollution in more environmental matrices (e.g. water, soil, etc.)
-The need to identify and address knowledge gaps in the field
-The need to address pharmaceutical pollution throughout the lifecycle of pharmaceuticals
HCWH Europe suggests the following additions to the roadmap:
Part A, under the heading: “Problem the initiative aims to tackle”, HCWH Europe would like to insert the data from the German Environment Agency report of 2016 highlighting that 4,000 active pharmaceutical ingredients are being used in prescription drugs, over the counter therapeutic drugs, and veterinary drugs.* This new data should replace the data present on the roadmap referring to 3000 APIs being on the market.
*German Environment Agency (2016) Pharmaceuticals in the environment - the global perspective (please see attached document).
Part B under the heading: “What does the initiative aim to achieve and how”, HCWH Europe recommends to include the following details for how to achieve the defined goals:
- Use the risk assessment of pharmaceuticals in the environment when addressing the knowledge gaps
- Include the risk assessment of metabolites, transformation products, and mixtures in different environmental matrices
- Point out the need to establish a procedure for defining threshold values for single and mixture pharmaceutical residues in different environmental matrices
- Propose more support under EU Horizon 2020 and other EU research funding streams to address knowledge gaps and carry out the afore mentioned risk assessments
- Propose the same type of support for the development of green pharmaceuticals (“benign by design”) i.e. are easily biodegradable and harmless to the environment. The roadmap should also stress the need for guidelines at the EU level in defining "green pharmaceuticals’’
Part C under the heading: “Better regulation – Consultation strategy”, HCWH Europe suggests to include more opportunities for dialogue with NGOs, the pharmaceutical industry, the food and beverage industry, and farmers.
Further reading: https://www.thebureauinvestigates.com/stories/2017-05-06/big-pharmas-pollution-is-creating-deadly-superbugs-while-the-world-looks-the-other-way
Read full responseResponse to Revision of the Drinking Water Directive
24 Mar 2017
Health Care Without Harm (HCWH) Europe agrees that the DWD provision on products and materials in contact with drinking water permits too much legal flexibility. Therefore, in terms of policy options, we would prefer to have legislative measures in place instead of soft non-legislative options to address this issue.
The development of a strategic approach on pharmaceuticals in the environment in the framework of Directive 2013/39/EU is of high importance in this context because inaction at this level can hamper the coherence and implementation of the DRW. Improved outcomes for a coherent legislative proposal can only be achieved by taking into account the impact assessment for both the DRW and the one on pharmaceuticals in the environment. It seems to us that it would not make sense to consider only the DRW impact assessment without taking into consideration the work that should be carried out within the strategic approach on pharmaceuticals, as these are clearly linked.
We also agree that it is difficult to establish direct causal and statistical relations between drinking water quality and human health impacts. However, we strongly believe that all policy measures should be taken using the precautionary principle, whereby in cases where scientific data do not permit a complete evaluation of the risk, legislative measures should be considered to preserve the health of the European citizens.
Read full response