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The Cancer Prevention & Education Society

CPES

To reduce the incidence of cancer and other diseases by reducing human exposure to harmful chemicals

Lobbying Activity

Response to Update of concentration limit values of persistent organic pollutants in waste

30 Jul 2020

It is vital to meet the Stockholm Convention objective to protect human health and the environment from persistent organic pollutants (Stockholm Convention 2010). Therefore POPs should not be present in recycled materials and therefore limits should be much lower than currently allowed. POPS have been banned for good reason and it is entirely wrong that they can remain in the circular economy where they continue to pose a threat to both health and the environment. Nor should they be incinerated as this can lead to the formation of dioxins and contamination of fly ash. We therefore kindly ask the European Commission to lower POPs content limits as follows: • 1 ppb (= 1 ng/g WHO-TEQ) for PCDD/Fs + dl-PCBs with additional limit of 50 pg WHO-TEQ/g (0.05 ppb) of these substances for untreated waste used on land surface • 100 ppm (= 100 mg/kg) for HBCDD • 50 ppm (= 50 mg/kg) for sum of PBDEs (including Deca-BDE) • 100 ppm (= 100 mg/kg) for SCCPs • 10 ppm (= 10 mg/kg) for sum of PFOA/PFHxS and related substances In order to meet the obligations set in Article 5 of the Stockholm Convention, we also call for legislation to allow other technologies to be used for the destruction of POPs waste so as not to form new POPs which incineration of waste does. As a final comment we believe that the EC should be much more proactive and anticipatory in preventing persistent and toxic chemicals from ever being used in the first place. It is well known that halogenation of chemicals renders them more persistent and we therefore fully support a class based approach to chemicals containing them. We call on the EC to work more closely with ECHA and other agencies to promote class based approaches to chemicals to avoid the problem of regrettable substitution. Attached is a list of references about sources, exposures and effects of flame retardants many of which are halogenated and therefore problematic from a waste management perspective, not least because of the absence of labels allowing easy identification of restricted chemicals.
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Response to Criteria to identify endocrine disruptors for plant protection products

21 Jul 2016

The Cancer Prevention & Education Society calls on the EU Commission to make significant changes to the proposed criteria for identifying endocrine disrupting chemicals (EDCs). The current proposal fails to address this pressing public health threat and fulfil the legal mandate to protect the health of humans, animals and the environment from exposure to these chemicals in our daily lives. The proposed criteria requires such a high amount of evidence that it will be nearly impossible to identify more than a small number of substances posing a threat to human health & environment from hormone disruption. In contrast, current lists of potential EDCs include over 800 substances. Over 1300 scientific studies link exposure to EDCs to spiralling rates of hormone-related cancers such as breast or testicular cancer, fertility problems, diabetes, obesity & behavioural problems in children. The World Health Organization has called EDCs a ‘global threat’. The health costs of diseases associated with EDC exposure are estimated at 158 billion € yearly in the EU. The Commission has ignored the majority of respondents to its 2015 public consultation who supported the most effective use of science to protect humans and wildlife, especially vulnerable groups such as pregnant women, babies and children. In the 7th Environmental Action program, the EU committed to minimising EDCs exposure. To achieve this goal, 2 major aspects need to be changed: 1) The Commission proposes to identify EDCs only if they are known to have adverse effects in humans or wildlife not intended to be affected. The word ‘known’ means to have proof. Demanding such proof weakens the current law which says to regulate those substances that ‘may’ cause harm (like for carcinogens that ‘may cause cancer’). Such a high burden of proof blocks expert opinion about the likelihood of an effect and is unacceptable, as it is likely to result in damage to humans and the environment before action is taken. This contradicts the precautionary approach enshrined in the EU Treaty and built into the biocide & pesticides laws. It also clashes with the current successful approach of identifying & ranking carcinogens and chemicals toxic to reproduction. Substances should be identified as EDCs when they are known or presumed to have adverse effects. The Commission should act on the existing scientific knowledge and the best option for health is an approach with 3 categories according to the level of evidence. 2) The Commission proposes widening the current exemption for those pesticides identified as EDCs into a major loophole. Changing `negligible exposure’ to ‘negligible risk´ would allow continued uncontrolled exposure to these EDCs. This is unacceptable. The Commission has gone beyond their identification task, weakening the law by reintroducing specific risk assessments for pesticides identified as EDCs in the future The proposal must be rectified to ensure a high level of protection for health and the environment, preventing endocrine-related diseases for Europeans and averting damage from our ecosystems. France, Sweden and Denmark have already expressed their disagreement http://goo.gl/oU3QDS. The world’s leading experts on EDCs - the Endocrine Society https://goo.gl/MNE4c7 and other scientists http://goo.gl/u0LtIl have strongly criticised the proposal, as have certain industry sectors who believe the criteria should be stronger to identify and phase out potentially harmful materials http://goo.gl/pmYHkh. EDCs are a threat to our society’s current & future public health and prosperity. Europe must take a leading role in regulating EDCs, as this will stimulate innovation so that all industries in the various sectors develop and use better and safer alternatives. Our everyday exposure to these chemicals – in our food, cosmetics, homes, countryside, work places, schools, & hospitals, must stop to protect the health of current and future generations.
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