Stichting Huize Aarde
SHA
SHA is a non-profit consultancy from the Netherlands, founded in 1992.
ID: 835328319472-27
Lobbying Activity
Response to Strategic approach to pharmaceuticals in the environment
26 May 2017
One of the first steps for a roadmap should be the use and definition of crucial concepts to be applied for policy making. With the right definition of the concepts to be used, the direction for thinking and acting will be determined.
Pharmaceuticals in the environment
Emphasis lies on the emission and existence of these molecules and resistant micro-organisms in a substrate. Although due to their characteristics these molecules and organisms are continuously and indiscriminately returning back to humans and animals, possibly causing health effects. It is recommended to put more emphasis on the environmental cycle of these particular molecules and organisms. Therefor we propose to change the name of the roadmap and coming policy into “Environmental cycle of pharmaceuticals and resistant micro-organisms”.
Green Pharmacy
In this case Green Pharmacy, being part of Green Chemistry, is a broad concept that includes the whole medicine chain and goes even further (Chr. Daugthon, 2003 a, b). It includes preventive measures as chemical free treatment and avoidance of human and animal disease. An example is prescribing lifestyle and animal management improvements. It also includes avoidance of the use of these essential molecules for economic (market, production) purposes. By rational prescribing, to give another example, considerable reductions could be achieved. Eg. 98% of the psycho-pharmaceuticals are not effective and by that not rationally used (P. Gøtsche 2015).
The environmental cycle of pharmaceuticals and resistant micro-organisms is eroding health care and causing high social and ecological costs. Considering effectivity and efficiency Green Pharmacy will try to avoid symptom control and therefor should be applied to and by the whole animal and human health sector. With an integrated approach short and long term social and ecological benefits will be achieved. Governments could create strong incentives for this very much needed social transition.
Risk Assessment
Another concept that needs to be defined is Risk Assessment. An assessment of the health effects of the environmental cycle of pharmaceuticals and resistant micro-organisms need to include all exposure routes, like water, food and air (Total Exposure Assessment). It is recommended not to have too many expectations from energy, time and money consuming assessments. Pharmaceutical cocktails will have countless short to long term effects on organisms due to their broad bio-reactive nature (all medicines have already many side effects during therapy). Moreover it appears that much used medicines like painkillers also act as endocrine disrupters and by that are bioactive in extremely low concentrations. Total risk assessments are needed, but will be an endless road.
Scope
It is recommended not to focus on Europe alone. It is already mentioned by other respondents, our medicines are being made in other continents with less workers safety and environmental restrictions and/or control. Moreover, the environmental cycle of pharmaceuticals and resistant micro-organisms is a global issue because contaminated people, animals, water, food and air go across borders and continents. Generally in the EU treatment of sewage, sludge and drinking water seems to be good. On a world wide scale the exposure through drinking water and with contaminated biosolids treated food will be much higher. The EU is an inseparable part of this globe, and therefor should be part of a worldwide solution.
Goal
The formulation of a clear broadly endorsed goal will be clarifying and determining. Avoidance of all pharmaceutical emissions by animals, humans, aquaculture, etc. should be considered as a goal to be achieved.
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