US and EU Health Activities Are Focusing on Chemicals

Published: February 01, 2001, By Sheila A. Millar

Action on chemicals is at the forefront of activities on both sides of the Atlantic, with the potential to affect not only suppliers of chemicals and materials for use in packaging, but also converters and their customers.

In the US, the Environmental Protection Agency recently announced a children's health initiative that may affect producers and users of certain food-contact substances.

Sweden now has taken over its presidency of the European Union (EU). High on its agenda is a plan to extend the so-called "precautionary principle" to the chemical industry. Results of a study of mouthing behavior published in Pediatrics magazine, however, suggest that children mouth pacifiers and teething objects much less than previously thought, and they mouth other objects significantly less than pacifiers. This should prove useful as industry and governments strive to evaluate accurately exposure scenarios for products such as packaging.

EPA's Voluntary Children's Chemical Evaluation Program (VCCEP), as announced in the Federal Register Dec. 26, 2000, is one of three programs established under the Chemical Right-to-Know Initiative declared by VP Al Gore April 21, 1998. It is intended to provide data to help the public understand potential health risks when children are exposed to certain chemicals. EPA is asking companies that manufacture and/or import any of the 23 listed chemicals to voluntarily sponsor evaluation of the chemical(s).

Some of these chemicals, such as benzene, acetone, and vinylidene chloride, are used in the production of food-contact articles. There should be no immediate regulatory impact of this listing; rather, manufacturers and importers are asked to develop additional toxicity data relevant to children.

The precautionary principle has received attention in large part because it is the rallying cry of those who oppose the use of certain chemicals (for example, phthalates used as plasticizers in toys, packaging, and other products), and to genetically modified organisms (GMOs). Such opposition includes militant organizations like Greenpeace.

Those supporting the precautionary principle contend that no new technology should be permitted in the marketplace without a complete set of toxicology data and a complete assessment of all possible risks to humans and the environment. Risks to children and "sensitive" populations pose special concerns requiring adoption of the precautionary principle.

While groups like Greenpeace have professed to seek labeling and other "right-to-know" approaches to reflect precaution, make no mistake: They want to use the precautionary principle in support of total bans.

Sweden's promise to push for adoption of the precautionary principle is linked with the review of EU chemicals policies, a process that began two years ago. While legislative proposals have not been introduced yet, there are some indications that the regulatory landscape in this area may be overhauled significantly in the EU. The Council is scheduled to issue a "White Paper" early this year that should set forth a new Community policy on these chemicals; it should fully reflect the precautionary principle and the principle of sustainability and specify the obligations of the parties involved.

In a global environment where data - particularly scientific data - is shared broadly and is available instantly through the Internet, it is not unreasonable to think that any adverse toxicological data on a particular chemical that surfaces during EPA's VCCEP could be used by advocates of the precautionary principle to support bans or restrictions on products.

The risk, of course, is that there may never be enough positive data to silence the Luddites. Industry must assure that positive information is shared as widely as negative information. For this reason, the recent study on mouthing behavior should provide additional technical support for evaluating exposure to children via the ingestion route of chemicals commonly found in products accessible to them, in the long tradition of responsible industry action.