30
Oct
New European Union Looks at Chemical Mixtures
(Beyond Pesticides, October 30, 2020) The European Union (EU) adopted, in mid-October, a new strategy on chemicals — including pesticides — that seeks to deal with their combined (synergistic) and cumulative impacts on human and environmental health. A highlight of the new strategy is the acceleration of work, already begun across the EU, to address the “chemical cocktail” impacts of pesticides and other chemicals. Human exposures to such “cocktails” can happen through use of multiple different agricultural pesticides that can persist as residues on food, and via industrial processes and consumer products. Beyond Pesticides has insisted for years that, here in the states, the Environmental Protection Agency (EPA) has been way behind the eight ball in dealing with the potential synergistic and cumulative impacts of the pesticides its registers for use. Advocates have argued that the agency must be far more rigorous in evaluating impacts of exposures to multiple pesticides, as well as cumulative impacts.
The toxicity problem the EU seeks to address is that interacting chemicals can have synergistic effects, even at very low levels — effects greater than and/or different from the expected impacts of each chemical per se. Pesticides can also have cumulative “toxic loading” effects in both the immediate and long terms. The new EU strategy states that, though “it is currently ‘not realistic nor economically feasible’” to evaluate every possible combination of the thousands of chemicals used in industry and society, there is emerging scientific consensus that the impacts of chemical cocktails “‘need to be taken into account and integrated more generally into chemical risk assessments.’” Beyond Pesticides concurs.
The new strategy, EURACTIV reports, “is intended as a first step towards a zero pollution ambition for a toxic-free environment, as announced in the European Green Deal [EGD].” The strength of the new strategy could lie in its proposal to exercise a (weakened) form of the Precautionary Principle: to ban the most-toxic substances “automatically,” and to permit their use only on a case-by-case basis if they can be proven “indispensable to society.” Certainly, banning terribly toxic chemicals is a great step. However, the European Commission (EC) vice-president overseeing the EGD, Frans Timmerman, commented, “We need to make sure that chemicals are produced and used in a way that does not hurt human health and the environment,” adding that the new strategy will primarily affect harmful chemicals in consumer products, such as toys, cosmetics, textiles, and food packaging. Pesticides do not appear in his “primary targets” list.
It is difficult to tell, at this early juncture, how impactful this strategy will be. Comments by Virginijus Sinkevičius, the EU Environment Commissioner, appear a bit ambiguous and may belie some of the fanfare over the announcement. Prior to the October 14 public reveal of the new strategy, he had said, credibly, “The reality is that many chemicals are also hazardous by nature and may lead to irreversible damage to humans and to the environment.” He also indicated that, although “the EU already has the most advanced chemical policy in the world . . . there is room for improvement and that the shift to greener chemistry needs to happen quicker.”
Yet post-announcement, when asked by EURACTIV how much focus pesticides receive in the strategy, he indicated that it would address pesticides “in the sense that they are chemicals,” and added that they will “need to be produced and used more sustainably, as this is the overall objective of the strategy.” Whether this new approach will address the pesticide toxicity problem at scale or with the robustness required remains to be seen.
To its credit, the strategy document does say that the European Commission (EC), the independent, executive arm of the EU, will turn especial attention to compounds that act as endocrine disruptors, which many pesticides do. (Multiple health disorders are associated with endocrine disruption.) An excerpt from the text reads: “The [EC] will: propose to establish legally binding hazard identification of endocrine disruptors, based on the definition of the WHO, building on criteria already developed for pesticides and biocides, and apply it across all legislation; ensure that endocrine disruptors are banned in consumer products as soon as they are identified, allowing their use only where it is proven to be essential for society; [and] strengthen workers’ protection by introducing endocrine disruptors as a category of substances of very high concern.”
This new chemicals initiative was spurred by the recognition of several realities. One noted in the document is that, although the EU already has fairly ambitious chemical regulations in place, worldwide production of chemicals is expected to double in the next decade; use of synthetic chemicals is also expected to increase globally. Another catalyzing fact was EU biomonitoring results that demonstrate increasing numbers of distinct and harmful chemicals showing up in human blood and tissue samples. These include pesticides, plasticizers, pharmaceuticals, heavy metals, and flame retardants.
Information in a report out of the European Food Safety Authority (EFSA) earlier in 2020 no doubt had an impact, as well: a third of the food Europeans consume harbors residue from two or more pesticides. In addition, public sentiment in Europe, according to the strategy document, shows that 84% of Europeans are worried about health harms from chemicals in everyday products, and 90% are worried about impacts of chemicals on the environment.
Europe, and the EU specifically, have been more proactive than the U.S. on issues related to pesticide and chemical use, climate, and sustainability generally. For starters, there is the European Green Deal, which seeks to make Europe the “first climate-neutral continent” by “transform[ing] the Union into a modern, resource-efficient and competitive economy [in which] there are no net emissions of greenhouse gases by 2050, economic growth is decoupled from resource use, [and] no person and no place is left behind.” The EGD action plan intends to “boost the efficient use of resources by moving to a clean, circular economy, [and] restore biodiversity and cut pollution.”
In addition, the EU has its long-standing Common Agricultural Policy (CAP), for which the EC announced an update earlier in 2020. That update was touted as having far more focus (than the previous iteration) on “protecting the environment and biodiversity: the plan features climate change action, environmental care, and preserving landscapes and biodiversity.” Nevertheless, critics of this update were vociferous, claiming that aspects of it were just so much greenwashing, and contravened the goals of the developing EGD. A group of 21 scientists, for example, wrote a scathing letter endorsed by another 3,600, saying that the updated CAP was a failure and must be dramatically overhauled to “embrace organic practices and support small farmers.” March 2020 New York Times reporting on the CAP update “showed the disconnect between Europe’s green image and its farm policy, which has caused lasting environmental damage and left visible pockmarks across Europe.”
Back across the pond, pesticide (and chemical) regulation in the U.S. trails toxicological science in accounting for synergistic and cumulative effects. EPA continues to regulate pesticides primarily on a chemical-by-chemical basis. When it ventures toward addressing synergistic or cumulative impacts, it does so in a narrow way: e.g., for one active ingredient at a time, or for one class of organism. For example, in 2019, the agency requested public comment on a proposal to require data that could help determine synergistic effects of some pesticides; and a year ago, EPA announced a proposed interim process on assessment of potential synergistic effects of mixtures of active ingredients in pesticides on non-target organisms.
These steps are useful in a limited way, but are typical of EPA’s focus on “spot mitigation” of pesticide toxicity. Rather than a whack-a-mole approach to pesticide harms, the agency should adopt a precautionary approach that doesn’t subject everyone and everything to unknown and potentially harmful impacts of multiple pesticides, or a variety of pesticides over time, or to any pesticides, given individual vulnerabilities.
Beyond Pesticides wrote in July 2020, “Given the many thousands of chemical pesticides on the market, the complexity of trying to ensure ‘relative’ safety from them (especially considering potential synergistic interactions, as well as interactions with genetic and “lifestyle” factors), and the heaps of cash that fund corporate interests (i.e., selling these compounds) via lobbyists and trade associations, there is one conclusion. “Mitigation” of pesticide risks is a nibble around the edges of a pervasive poison problem; this approach does not at all adequately protect the fragility of life.”
Genuine solutions to the issue of chemical pesticide harms to people, ecosystems, and wildlife require the elimination of the use of synthetic chemical pesticides, fertilizers, and other toxic inputs, and the transition to agricultural and land management systems that work with nature, rather than fight against it. Regenerative, organic practices are the path to a livable future. Help support advocacy for that future: join Beyond Pesticides, advocate with decision makers in local communities, and please: vote for elected officials at every level that support genuinely protective regulation and a transition to non–chemically intensive agriculture and land management.
NOV. 3 ELECTION REMINDER: vote early if you still can; or bring your absentee/mail-in ballot to your precinct drop-off box NOW; or make sure you vote on Tuesday, November 3. Your health, and the planet’s, are on the ballot.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
