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Report on the 34th OECD Joint Meeting
(Paris 5-8th November 2002)
While the OECD Joint Meeting addresses both industrial chemicals and pesticides, this report focuses primarily on the industrial chemicals of concern. These were the persistent and bioaccumulative substances where action to remove them from the global markets, would be appropriate.
Unfortunately, consideration of any such action was not forth coming and following the discussions on the PFOS and PBDEs perhaps the greeting to the delegates (apart from Denmark and Switzerland) should be "may the children of the future forgive you".
Many of the workshop outcomes reflected the balance in participation, a factor also noted in the Chairman's early comments that "workshops simply reflect their participants". While the majority of participants were government regulators from OECD countries where the bulk of the chemical industry is situated, many delegations included participants from industry and there were also a large number of industry representatives from the international chemical industry under the banner of BIAC, the Business and Industry Advisory Council.
When reviewing some of the working groups that emanated out of the 33rd OECDE Joint meeting, in some working groups, for example, those dealing with commercial business information, BIAC representatives clearly utnumbered
government representatives.
Fortunately, some environmental NGOs attended the 34th meeting. The Environmental Defence Fund provided a representative to fill the ECO seat which OECD has only recently created (for environmental NGOs) to balance
industry representation. However, few NGOs are aware of this opportunity and there is little consultation among public interest and environmental NGOs regarding the positions taken. The limitations of being a member of the
Australian delegations meant that our participation was restricted, as statements need to be approved by the delegation head. However, our concerns and positions were well reflected by the ECO representative.
Topics of Concern
# Perflourooctane sulfonate PFOS /PFOA (Agenda item 4c, 7c)
Of major concern to NGOs and one of the prime reasons for our attending was the current lack of action on PFOS (perflourooctane sulfonate). This toxic, persistent fluorinated chemical has been detected in adults, wildlife and in
the blood of a US sample of nearly 600 children aged from 2-12 years. The fact that PFOS has been used in products such as waterproofing of clothes and furnishings, as well as in the wrappers of fast food, has provided a
direct path to children. While the USA has recently moved on PFOS (at the bequest of one manufacturer, 3M) and is rumoured to be considering a similar move on a group of related chemicals, PFOAs or perflourooctanoic acids, the rest of the OECD countries remained silent.
While, much was made about the need to generate more data, one was left wondering just how much more must be generated before individual countries and/or the OECD will act to ban at least the PFOS chemicals. When a
chemical is toxic, persistent and is found in 600 children, it could be asked what other information is required ? However, Japan argued that despite this, PFOS did not fulfill the criteria for persistence under the Stockholm Convention on POPs and maintained their right to continue using and manufacturing this group of chemicals.
Fortunately, at the very last stages of the meeting, the Australian delegation took on the role of continued assessment, particularly in relation to any essential uses and alternatives.
# Brominated flame retardants (BFRs) - PBDEs (7b)
NGOs expressed similar concerns with BFRs and in particular, pentabrominated diphenyl ether or PBDEs. The levels of PBDEs are doubling in the US population every few years. While the EU has moved on PBDEs and industry has committed to voluntarily phase out some of brominated flame retardants, the majority of countries remained silent about the timeframes and the scope of any phaseouts. No action was taken on the range of other BFRs with the only decision being to revisit the issue in February 2004.
This is of real concern when some of the recommendations of Australia's own review of BFRs clearly depend on OECD outcomes; for example,
" Recommendation 1: Further assessment
A full (risk) assessment to assess occupational, public and environmental exposure and consequently risks to human health and environment will be considered when testing of PBFRs is completed under the OECD Program. Selection of PBFRs for a full assessment will depend on the outcomes of the testing and the chemicals in use in Australia. A full risk assessment would also need to balance consideration of any adverse effects of these chemicals against the need for fire retardancy for certain articles and use situations to protect human heath and property."
The primary health concerns are the potential of some PBFRs to act as carcinogens, endocrine disruptors and neurodevelopmental toxicants as well as the lack of adequate toxicological data for others to fully assess their
hazards.
BFRs are not manufactured in Australia, but are imported as pure chemicals or mixtures, or in polymer resins or polystyrene foam boards. They are also introduced into Australia in finished products or articles, but there are no reliable estimates of the quantities. They are used exclusively as flame
retardants, typically in concentrations ranging from 3 to 12% depending on the product. While the content of BFRs in imported articles may vary widely, they present a large source of introduced flame retardants. Brominated
polystyrene (CAS No. 88497-56-7) was used in the production of stadium seating at the Sydney 2000 Olympics.
In a process referred to as "blooming" PBFRs may diffuse or emit from treated articles. This is dependent on a number of factors, including molecular weight and structure, the chemical nature of the compound (reactive or additive) and the structure of the polymer matrix of the article. Such articles are likely to be used to a great extent in private an d/or commercial premises and have a potential for long term occupational exposure. Yet, little information is available on the emission and release of PBFRs into the Australian environment.
Another concern is the partial combustion of materials containing flame retardant which produce polybromodibenzo-dioxins and -furans. However, these were mainly heavily brominated and congeners with the substitution pattern of most concern - 2,3,7,8 - were minor components of the congener mixture.
Despite a Swedish study showing that the levels of PBDEs in breastmilk have increased dramatically over the last 25 years from approximately 72 nanograms per kilogram lipid (sum of BDE congeners) in 1972 to approximately
4010 ng/kg lipid in 1997, Australia has carried out no biological or environmental monitoring for these chemicals.
# Pollution Release & Transfer Registers (PRTRs)
The issue of PRTRs and their worth was somewhat more positive, with a number of countries supporting their use in exposure assessment. However, for a country such as Australia, where only a handful of chemicals are involved
(100 out of 6-7,000 listed in the Australian index of substances) excluding all transfers of substances meant that it is unlikely that the National Pollutant Inventory could provide any meaningful data for exposure assessment.
# Quantitative structure-activity relationships (QSARs)
A special session was provided on the use of quantitative structure-activity relationships (QSARs) in regulatory assessment. QSARs are used as models to assess a chemicals likely behaviour and therefore, the need for more
detailed registration data. Based on aspects like molecular weight, flash points etc it is proposed that regulators could use QSARs to prioritise chemicals for regulatory actions. However, early validation by Denmark of these methods has demonstrated that in certain circumstances, for example, in assessing carcinogenicity of particular chemicals, the accuracy of QSARs is quite dismal.
Despite these adverse findings, support from both industry and governments for ongoing development, validation and use of QSARs was very strong. Seen as an effective way to prioritise or assess the tens of thousands of
untested chemicals in use today, they argued that it also avoided the pain and suffering of the many laboratory animals currently used in the generation of registration data. So despite the obvious limitations in the overt simplification of complex biological processes (eg endocrine disruption), the lack of validation and apparent inapplicability in certain circumstances, the development of QSARs will continue.
# Risk Assessment and Commercial Business Information (CBI)
Throughout the agenda, the issues of commercial business information (CBI) and the application of risk assessment ruled supreme! These two factors represent major restrictions to the effective and meaningful participation of NGOs and civil society in chemical regulatory affairs, both domestically and internationally. In the OECD forum, there appears to be no acknowledgement of the many limitations to the application of risk
assessment, except for the need for more data on individual chemicals. Risk assessment was seen as the domain of the expert with no role for civil society other than being on the receiving end of the risk communication.
This view highlighted how proactive the requirement is for community involvement in Australia's national enHealth Guidelines for Environmental Health Risk Assessment. It also highlights just how far the NGO community has to go to change the well-entrenched attitude that risk assessment is a flawless expert science rather than an art form, capable of being professionally and politically influenced.
The issue of secrecy of industries' data was regularly raised and while some countries gave lip service to 'transparency' this was presented in the framework of industry's absolute right to confidentiality. There was no
discussion of the definitional issues of CBI and trade secrets, with confidentiality assumed for anything claimed as such. The impact of CBI was evident in the huge package of data now provided to OECD meeting on PFOS.
Perhaps if this information had been available prior to 3M's withdrawal of PFOS, the huge popularity of the previous formulations of products like Scotchguard would have been tempered. Similarly, regulators may have controlled the use of PFOS in food packaging thereby protecting our children from yet another persistent, bioaccumulative toxic substance.
# Relationships with Other Forums
While other international organisations such as the United Nations Environment Program and the Intergovernmental Forum on Chemical Safety were present, it was apparent that there was not a direct passage from the OECD forum to international action elsewhere, for example in the listing of new POPs under the Stockholm Convention on Persistent Organic Pollutants. It made it quite clear that while the OECD forum could assist in generating data, it was not a forum to instigate bans or even management actions. For that, it is may be more appropriate and effective to look at the Intergovernmental Forum on Chemical Safety, where NGO input is more readily accepted.
INFOCAP
The Intergovernmental Forum on Chemical Safety (IFCS) also provided a presentation on INFOCAP, a web based information repository and gateway for chemical issues. IFCS is encouraging all stakeholders input including NGOs. Currently, we are having discussion regarding protocols for NGO information input to ensure real community involvement.
We are happy to discuss any of the issues raised in this report.
Mariann Lloyd-Smith, Coordinator
National Toxics Network Inc.
47 Eugenia St., Rivett ACT 2611
AUSTRALIA
biomap@oztoxics.org
http://www.oztoxics.org
Ph: Int+(612)62885881
Fax:Int+(612)62885881
Mobile 0413 621557
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