Viewpoint: ‘Toxic-free EU’? Why Europe’s naive Green Deal is scientifically illiterate and could cripple innovation for years to come

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July is usually a good month for environmental activism in Europe. Many people are on holiday and nobody feels like getting into an argument when the weather is so nice. Journalists are no longer at their desks so even if an exposé falls on their lap, they wouldn’t bother reading it. So July is a good time to sneak through some ridiculous policy that will promote the Green Degrowth agenda and hamper European innovation for a generation to come.

So it was at the European Parliament this past July. The representatives of the European public did not simply rubber stamp the European Commission’s program for a “toxic-free EU” – the Chemicals Strategy for Sustainability (the chemophobic chapter of Ursula von der Leyen’s myopic Green Deal), they introduced a radical activist agenda into a Parliamentary resolution that that looked more like an Endocrine-Disrupting-Chemical-Free Europe strategy document than one guided by science, intellect and foresight. Large parts of this parliamentary resolution were clearly written by these activist lobbyists. The words “endocrine disruptor” or “EDC” appeared in this short resolution 30 times.

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Yes… The EU will be “toxic-free”!

Anyone who had read this European Parliament resolution would find a regrettably long tirade of chemophobic, reckless and scientifically ignorant environmentalist campaign points. I haven’t seen this much stupid on chemicals since the early days of REACH (when EU Environment Commissioner Margot Wallström wept at a press conference begging her sons to forgive her for poisoning them with her breast milk). I can only suppose that most MEPs had not read the resolution since it passed by an overwhelming majority of 579 votes to 18 (with 84 abstentions). Either that or this class of MEPs are the most illiterate, ignorant and irresponsible group to have ever represented the interest and future of 446 million Europeans.

[I] joined in the European Commission consultation on their strategy for a “toxic-free EU”. He then took some time to read the European Parliament resolution and thought it would be useful to share some of their more “erudite and insightful” points. The indented parts are taken from the official adopted text, approved on July 10, 2020. It took only three sentences into the Parliament resolution for the drafters of this text to demonstrate they had no idea about how the chemical industry works.

3. Considers that ensuring that all uses of chemicals, materials and products are safe, sustainable and circular by design is an essential upstream measure not only to protect human health, achieve a toxic-free environment (air, water, soil) and protect biodiversity, but also for achieving a climate-neutral, resource-efficient, circular and competitive economy

Chemistry 101

Chemicals produced upstream are destined for the applications of end-users downstream. Most of the chemical waste, energy and exposure happen with downstream users so the MEP’s goal of targeting the upstream producers is, well, rather pointless (unless attacking big corporations is your ultimate goal).

An example: A chemical company can design and produce a flame retarding substance to protect plastics from burning, and do so sustainably. A downstream user, molding parts for computers or engines, will add the substance into an extruder with plastic pellets. The worker may toss the bag into the domestic waste bin or hose down the factory floor with trace chemicals going into the environment.

chemophobia fear of chemicals or working with chemicals
Credit: Psych Times

So while activist groups take their swings at the big chemical companies upstream, it is the downstream use of chemicals that is important for controlling the release into the environment or causing human health issues. That is why safety data sheets are written in such frightening categorical language. Worse, some downstream users may not be using chemicals in a sustainable way (I think of a case study during REACH when Nike used SF6 in their Air Jordan product line against industry advice). When I was at Cefic during the first reading of REACH in 2005, I welcomed how the regulation would guarantee the safe use of chemicals downstream.

Pity 579 MEPs don’t understand this.

Rainbows, butterflies and poppies please

4. Calls on the Commission to come up with a comprehensive Chemicals Strategy for Sustainability to bring about the necessary paradigm shift to implement the zero-pollution ambition for a toxic-free environment, ensuring a high level of protection of human health, animal health and the environment, minimising exposure to hazardous chemicals, with particular regard to the precautionary principle and the effective protection of workers, minimising the use of animal testing, preserving and restoring ecosystems and biodiversity, and fostering innovation in sustainable chemicals, as the basis for a European strategy for a resource-efficient, circular, safe and sustainable economy, while strengthening the competitiveness and innovation power of the Union’s economy and ensuring security of supply and boosting employment within the EU;

… and world peace.

I am not sure how to unpack the flower-child innocence of this emotion-laden sentence. Every seven-year-old wants butterflies and rainbows, but people grow up and realize that society needs technology, innovation and industry to innovate and create the societal goods we need to maintain a quality of life, provide jobs and protection from the ravages of nature. And this involves managing hazardous chemicals and using resources. When it is done responsibly, it is called risk management. The precautionary mindset this resolution proliferates assumes that all you need to do is eliminate any hazard and we can all enjoy the beauty of nature. Sweet.

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Do these 579 members of the European Parliament understand that the European Union is in a state of crisis, with industries and entire sectors going bankrupt, causing massive unemployment and poverty? Talk of a paradigm shift to “zero-pollution” and a “toxic-free environment” is not only naive, impossible and unscientific, it is also irresponsible to further impoverish Europe to chase the dogmatic dreams of the innocent, ignorant and affluent.

This quest for a world full of poppies would be considered cute if, following the disastrous consequences of the COVID-19 lockdowns, we were not perched on the greatest economic and societal collapse of the last century. Someone needs to seriously pop the bubble that Brussels inhabits and I can’t believe I’m the only prick out there.

Chemical Industry caused COVID-19

13. Stresses the need to reduce and prevent exposure to chemicals such as endocrine disruptors (EDCs), which have been shown to contribute to significant increases in chronic diseases and some of which can disrupt the immune system and its inflammatory responses, in the context of measures to improve public health and strengthen resistance to viruses such as SARS-CoV-2(39);

[Indian food activist] Vandana Shiva claims GMO feed caused COVID-19. Anti-vaxxers declare 5G to be the source. And 579 members of the European Parliament say this latest coronavirus pandemic was caused by chemicals. Maybe that explains the shortage of tin foil in the shops around Etterbeek.

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Vandana Shiva. Credit: Frank Schwichtenberg [CC BY-SA 4.0 (https://creativecommons.org/licenses/by-sa/4.0)], from Wikimedia Commons
And what evidence are the European lawmakers basing their claims that EDCs are responsible for the latest coronavirus pandemic that has decimated global populations? What peer-reviewed scientific study did they cite? Was it published in Nature? Science? Was this claim verified by the European Chemicals Agency? EFSA? The JRC? No … they used, as a basis for an EU government resolution published in the Official Journal of the European Union, an activist article that appeared in Environmental Health News – an anti-chemicals, endocrine disruption campaign site set up by Pete Myers, a rabid American activist zealot and the author of Our Stolen Future.

Worse, the authors of this campaign pamphlet, Frederick vom Saal and Aly Cohen, are well-known anti-chemical activist scientists. Vom Saal has been a one-man army in his attempt to ban BPA as an endocrine disruptor. The logic in this sole resource cited by European lawmakers is that there is an increase in chronic diseases in the US and at the same time (they assume) there has been an increase of chemicals in the environment. The authors were driven by ideology to conclude there must be a direct correlation (and that chronic diseases in the US have nothing to do with lifestyle). And as people with chronic diseases tend to have more inflammation, they tend to be more at risk to have complications from the SARS-CoV-2 virus.

Thus the answer is clear: we must ban all synthetic chemicals.

579 Members of the European Parliament (to 18 votes against) endorsed this chemophobic nonsense in a resolution now published as an official EU document. If you are reading this in a European Union country, I regret to inform you that there is a high likelihood that your political representative in Brussels is either too lazy to read or an overpaid idiot (probably both).

We should all be contacting our MEPs to ask them how they voted. Send them a link to this article. I’d love to hear what they have to say.

A Radical Shade of Precaution

14.  Stresses that the Strategy should fully reflect the precautionary principle and the principles that preventive action should be taken, that environmental damage should as a priority be rectified at source and that the polluter should pay, as well as cornerstone principles of the European chemicals legislation such as the placing of the burden of proof on manufacturers, importers and downstream users, and that it should effectively apply those principles;

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This parliamentary resolution is relying on the radical, EEA version of the precautionary principle (reversal of the burden of proof) meaning that innovative, sustainable technologies without any exposure data would not be allowed on the market (unless campaign groups support it as an alternative to a product they want banned). Our 579 MEPs also assume that the world is simple – that there are clearly-defined good products and evil ones. One substance, however, might use more resources but less energy to manufacture, while an alternative uses less waste in the recycling stage or has a more sustainable production process.

Yes, science, but also listen to our non-scientists who demand the hazard-based approach

18. Highlights that the new Chemicals Strategy for Sustainability should be based on robust and up-to-date scientific evidence, taking into account the risk posed by endocrine disruptors, hazardous chemicals in imported products, and combination effects of different chemicals and very persistent chemicals, and that subsequent regulatory action, other than on scientific matters (e.g. hazard identification and hazard classification)(40), should be accompanied by impact assessments and should take into account the input of relevant stakeholders so to increase clarity over priorities;

Endocrine activists argue for a hazard-based approach to chemical policy (meaning exposure and dose levels are not important since we really don’t know if there are combination effects or low-dose effects that might influence a system we really don’t know much about). Most chemists and toxicologists (working on the premise that exposures determine the risk) don’t have much patience for the hazard-based approach, which is why the resolution recommends we also take views of other (non-scientist) “relevant stakeholders”.

For the record, the hazard-based approach governs the Sustainable Use Directive on pesticides and it is estimated that up to 60% of the active plant protection substances will be removed from EU market in the next four years since (as they cannot be proven with certainty to not have endocrine disrupting properties). The hazard-based approach renders risk management obsolete (there are no exposures or dose levels to consider), leaving a “Yes-No” precautionary approach as the only means to govern chemicals. In other words, Point 18 of the European Parliament Resolution of 10 July 2020 proposes the systematic removal of a majority of chemical substances permanently handcuffing European competitiveness and innovation, hurting consumers and the environment.

And these “relevant stakeholders” will be the citizen panel members from EDC-Free Europe making those decisions. Pure madness.

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Isn’t REACH the European Chemicals Regulation?

21. Reiterates its concern that legislation preventing the presence of chemicals in products, including imports, is scattered, is neither systematic nor consistent and applies only to very few substances, products and uses, often with many exemptions; calls on the Commission to present as part of the Chemicals Strategy for Sustainability an action plan to close the gaps in the current legal framework, giving priority to the products that consumers come into close and frequent contact with, such as textiles, furniture, children’s products and absorbent hygiene products;

The European Union approved REACH in 2006 and set up the European Chemicals Agency to provide the legal framework to regulate the safe use of chemicals in the EU. The only thing scattered would be to introduce another layer of hazard-based legislation called the Chemicals Strategy for Sustainability to appease some loud, disgruntled anti-chemicals campaigners.

Related article:  Genetic Literacy Project’s Top 6 Stories for the Week - June 19, 2017

And by the way, why did 579 MEPs vote in favour of special attention to “absorbent hygiene products”? Could it be that the endocrine activist lobby wrote this resolution?

Ghost of Monsanto

23. Considers that the new Chemicals Strategy should ensure that no chemical substance that has potentially negative effects on human health or the environment is placed on the market before the hazards and risks related to such a substance have been thoroughly assessed;

24. Underlines the need for a clear commitment to securing medium and long-term funding for improved and independent research into green chemistry, based on safety-by-design to develop safe and sustainable alternatives, including non-chemical alternatives, and to promoting the substitution of harmful chemicals, where feasible, and safe and sustainable production, ensuring the adequate preconditions for safe and sustainable innovation and development of new and safer chemicals;

25. Stresses that the chemical industry should participate widely in such funding;

When anti-industry lobby groups like Corporate Europe Observatory manufactured a fear that Monsanto was controlling EU risk assessment processes, they sought to redefine how risk assessments should be done: not with industry involvement (but paid by industry), with internal scientists (even though there is no capacity) and controlled by citizen panels (ie, activist groups).

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If there were any doubt this Parliamentary resolution was written by activist NGOs, take a look at some of the embarrassingly naive chem-illiteracy in these passages.

  • To demand that regulators “ensure that no chemical substance that has potentially negative effects on human health or the environment is placed on the market” would be rather difficult. Every chemical (which is every substance) at some dose level has the potential for negative effects. This is basic Paracelsus.
  • As everything is made up of chemicals, what exactly is a “non-chemical alternative”? And are natural chemicals necessarily safer?
  • Using an emotion-laden term like “safe” (safe alternative, safe production, safe innovation) shows the naivety of the authors of this document. As I had recently discussed, there is no such thing as “safe”, and while risk managers continuously seek “safer” it is hard to impose precaution without a categorical “unsafe” label.

Generic Risk: The new precautionary Trojan horse?

34. Considers that the Strategy should extend the use of generic risk assessment across legislation;

10 years ago, few people understood what the hazard-based approach to policy truly meant when a majority of MEPs passed legislation on pesticides that handcuffed regulators, made European farming less sustainable and decimated European innovation on crop protection. The activists who manipulatively slid that approach into law relied on the ignorance of others. In 10 years, I fear we will be talking about how regulations demanding generic risk assessments undermined governance and destroyed European competitiveness.

What is a generic risk assessment? It is an assessment relying on data that could apply to a generic type of product, substance or process. For example, a regulation on bicycles could rely on generic data that extend across all classes of bicycles (children’s, racing, mountain or electric bikes). Rain, cars or surface obstacles are generic hazards that would apply to all bicycles (assuming no need to get into specific exposure situations). For any new products or innovations (eg, step scooters or folding bikes), they might just be subsumed under the existing risk assessment data.

Generic risk assessments assume that many hazards are the same, apply to any situations and any users. On chemicals, it entails a certain control banding (meaning hazards are grouped together in categories). It differs from qualitative risk assessments which can consider specific risk management options, exposure questions (dose, duration, age), how and when substances are used, end-user profiles…

For the endocrine disruption lobbyists, generic risk assessments are attractive given they would allow activists to keep the focus on a wide band of potential EDCs as hazards to the most vulnerable populations (fetuses), without regard for potency or thresholds, with similar regulatory demands blanketing a wide range of different chemical uses. It would entail less work for the expedient regulator as the removal of substances from the market would be almost automated. Wider use of hazard-based generic risk assessments over qualitative risk assessments would be bad news for consumers, downstream users, scientists and innovators.

Generic risk assessments is a regulatory Trojan horse for another hazard-based approach to make any new chemicals regulation ungovernable.

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If you are still confused why 579 MEPs voted for the wider use of generic risk assessments, perhaps you should read the anti-chemicals NGO, CHEMTrust’s position paper demanding the hazard-based generic risk assessment approach for endocrine disrupting chemicals. Now I don’t want to suggest that large parts of this Parliamentary resolution was ghostwritten by CHEMTrust and other members of EDC-Free Europe (… but it clearly was). We were stupid enough to allow them to slip the hazard-based approach into pesticide regulations more than a decade ago; how stupid are we today?

Chemophobic Cocktails

35. Calls on the Commission to take all the necessary action to ensure that combination effects of chemicals are fully and consistently addressed across all the relevant legislation, including by reducing exposure and, where necessary, revising data requirements and developing new testing methods, preferably in accordance with methodologies agreed by EU agencies;

36. Calls on the Commission to develop, in cooperation with ECHA, EFSA, the Member States and stakeholders, a methodology to take into account the combination effects of chemicals, including combined exposure to multiple chemicals as well as exposure from different sources, such as for example a mixture assessment factor, and to adapt legal requirements to address these effects in risk assessment and management across all relevant chemicals and emission legislation;

Chemists and toxicologists measure toxicity according to exposure – it is the dose that makes the poison (Paracelsus). Endocrine disruption activists have been arguing for decades that this is not enough, that we “just don’t know” how chemicals combine and the consequences of this uncertainty are far too great (the extinction of humanity, other species, biodiversity…). That certain chemicals may combine and have synergistic effects and that any new chemical can disrupt the balance of nature is a convenient fear-laden trump card, but that implies that any innovative chemical would never be approved under the precautionary, hazard-based framework that activists – and 579 MEPs – are advocating (because “we just don’t know”).

This demand for certainty on cocktail effects of a selected list of chemicals (under threat of invoking the precautionary principle) looks great as an activist campaign strategy document but from a practical point of view, it is completely useless. The lunch I have just consumed combined at least 10,000 chemicals (plus an extra 1000 in my black coffee). As that cocktail of chemicals works within my digestive system, it may make me sleepy, give me energy, improve my health or get me sick. To know for certain how each individual chemical reacts with the others and then understand how it affects each individual is not possible. For chemophobic precautionistas, that provides legitimate grounds to ban these chemicals; for normal people it is how nature works.

Paracelsus was a medieval alchemist

76. Reaffirms its call of 14 March 2013(44) for testing methods and guidance documents to be developed so as to take better account of EDCs, possible low-dose effects, combination effects and non-monotonic dose-response relationships, in particular with regard to critical windows of exposure during development; stresses that EDCs should be regarded as non-threshold substances unless an applicant can scientifically demonstrate a safe threshold;

For most endocrine activists, there is no accepted safe dose level for any synthetic chemical (go ahead, just ask them). So when scientists determine a safe dose level (and comply with potential exposure levels hundreds of times lower) the activists will simply argue that there are low-dose effects that “we just don’t know about” (thus the need to invoke the precautionary principle). If the exposure levels as so low as to be ridiculous, the activist wordsmithers then add: “long-term low-dose effects” that we “just don’t know about”. There is no safe threshold, especially when the chemophobes then add “combination effects and non-monotonic dose-response relationships”.

These relentless endocrine activists have got a nice little racket going on here; no one can prove them wrong so they will just wait out the legitimate scientists and take advantage of any opportunities to create fear and regulator exhaustion. It was so kind of the “authors” of this European Parliament resolution to give these anti-innovation campaigners the opportunity to further legitimise their little game and get their rhetoric into the Official Journal.

“EDC-Free cities”? Seriously!

112.  Calls on the Commission to support the establishment of a European network of EDC-free cities and local communities with a view to improving cooperation and exchanging best practices, in the same vein as the Covenant of Mayors for Climate and Energy;

Plastic Bottles

EDC-Free Cities is a campaign tool adopted by many EDC-Free Europe partner NGOs to try convince their local urban authorities to make loose declarations to get the environmentalist vote, including policy pronouncements towards restricting pesticides or plastics. It is merely a green gimmick (especially as most urban areas don’t have large farms). If cities seriously wanted to go endocrine-disruptor-free, they would have to close all hospitals, forbid the sale of contraceptives and HRT treatments and ban coffee, humus and soy products.

So why would this “demand” for EDC-free cities be included? It happens quite frequently that Green MEPs use environmental NGOs to write their legislation and amendments (and this document is clearly one case where many campaign programmes got past the gatekeepers unfiltered). Kudos to the NGOs at EDC-Free Europe who wrote much of this European Parliament resolution to get their cute little urban-elitist gimmick into the Official Journal of the European Union. Shame on the 579 MEPs who voted in favour of a ridiculous idea, promoting a tinpot band of zealots and discrediting their own reputation.

Wake up and Smell the Stupid

Why did no European media groups expose this chem-illiterate campaign document disguised as a European Parliament resolution? Why did no journalist interview any of the 579 MEPs who voted for this chemophobic nonsense? Shouldn’t the scandal of a group of endocrine-activist NGOs from EDC-Free Europe and CHEMtrust having ghost-written a European Parliament document be considered news?

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But NGO lobbyists are so sweet!

It is not uncommon for NGOs to draft European Parliament resolutions (see image of an earlier example on the activist Save-the-Bees campaign). In the EP’s Chemical Strategy for Sustainability document, it is clear that much of the text was drafted by the endocrine disruption NGO lobby. Doesn’t anybody see a conflict of interest in this? What would happen if Exxon-Mobil were charged with drafting legislation on climate and energy? Where is the outrage or are we all hypocrites? Where was the media to expose this, to scrutinise our leaders, to ensure the European public is well represented? Being on holiday in July is no excuse (NGOs do their worst damage to society and the environment when no one is watching them).

If this document were taken seriously, Europe would become a chemical-free industrial backwater unable to feed itself. This though would not be because of its ignorant leaders, but because of the failure of the European media to do its job and scrutinise our politicians. Many feral journalists (like the two Stéphanes at LeMonde) prefer to highlight the alarmist fear-mongering. Others have been silenced after being intimidated by a band of activist rottweilers. With a lazy media preferring to repackage sensational fear campaigns over research and facts, I fear we get what we deserve.

Anyone with a middle-school science education could see the chemophobic idiocy and activist opportunism of this official parliamentary resolution. Doesn’t the fact that it was passed in the European Parliament by a vote of 579 to 18 (with 84 abstentions) worry anyone? Doesn’t its intention to systematically ban most chemical substances and further deindustrialise Europe alarm anyone? The people making these Green Deal decisions are in a comfortable bubble in Brussels, oblivious to the impoverishment and lost opportunities Europeans are facing. With governance led by dogmatic activist idealists, this magic wand conjuring 1.8 trillion euros will only make things worse over the long run.

Europe will soon be “chemical-free” … and poor. Maybe I am alone on this one, but this sheer stupidity, willful ignorance, NGO infiltration and media indifference scares the hell out of me.

David Zaruk has been an EU risk and science communications specialist since 2000, active in EU policy events from REACH and SCALE to the Pesticides Directive, from Science in Society questions to the use of the Precautionary Principle. Follow him on Twitter @zaruk

This article was originally published at Risk-Monger and has been republished here with permission.

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