UK Government consultation paper on sustainable production and use of chemicals1 Becky Allen reports on a paper which has been attacked by some sections of the chemical industry be needed to fund the basic research the RSC argues. ‘Industry is unlikely to do this [basic research] on its own. Latest figures for the UK chemicals industry show a declining spend on all research and development as a percentage of sales,’ the RSC points out. for not being radical enough In its submission to the Department of the Environment Transport and the Regions (DETR) the IChemE says ‘We are concerned that the focus [of the consultation paper] on extending current legislative regimes fails to encourage the radical approaches required to drive sustainability .. . Sustainability will only be achieved by a quantum change in approach by both industry and Government and this message is sadly lacking.’ According to the IChemE ‘Very urgent action is needed by the chemical industry to set in motion profound structural changes which can only flow from a reexamination of the chemistry fundamentals which underpin it and the development of the process technologies to bring about the changes.’ These sentiments are echoed in the Royal Society of Chemistry’s comments on the consultation paper. As well as needing ‘step changes that go well beyond good housekeeping’ the RSC says that the sustainable production and use of chemicals requires invention and development of new chemical science and technology.‘a step change is needed within academia and industry’ (IChemE and RSC) According to the RSC this ‘step change’ will depend on a new approach by many academic and industrial chemists as well as business managers ‘Sustainable performance can be a real commercial opportunity and worth the investment.’ But Government money will ‘Government money will be needed to fund basic sustainable production research’ The Government’s consultation paper says that a review of policy on chemicals in the environment is necessary because of factors like public attitudes towards chemicals and the slow progress of risk assessing existing chemicals. In its response to Government the Chemical Industries Association (CIA) says ‘A review is clearly needed.Despite industry's demonstrable improvements in performance there has been a change in the degree of risk acceptable to society from chemicals in the environment and this must be addressed.’ Many consultees support the Government’s suggestion of using a stakeholder forum to improve dialogue between industry and the public although` some doubt the impact it can have. According to the CIA:‘Transparency is essential in chemicals management [but] broadening public involvement will be difficult given the practical obstacles to genuine public dialogue.’ Room for agreement? As well as the IChemE CIA and RSC over 100 other organisations and individuals responded to the consultation paper C G F E AT U R E that posed several questions about the legal and policy framework (see box).The comments will form the basis of a White Paper due for publication in April. Comments came mainly from the chemical industry—including companies trade associations and professional societies but a significant number of environmental and health groups also responded. As a result there are divergent views among consultees on how to effect change although most agree that change is necessary. Differences of opinion are pronounced on several issues including risk assessment voluntarism and substitution. ‘There are large differences between consultees’ views on the proper scope of the review effective methods for speeding up assessments the correct rationale for controlling chemicals and information exchange with the public,’ says the DETR.Most environmental groups that responded to the consultation paper are signatories to the Friends of the Earth (FoE) Joint statement on chemicals and health. The statement calls for a phase- Key questions l How effective is current legislation and is framework legislation on chemicals needed at European or international level? l How might an eco-efficiency programme be advanced in the chemical industry? l How can the risk assessment process be accelerated? l How can the decision-making process be made more transparent? Green Chemistry April 1999 G47 F E AT U R E C G out of persistent or bioaccumulative chemicals and a move towards a positive licensing system for chemicals placing the onus to prove that a chemical is safe on industry.Consultees from the chemical industry reject such proposals. ‘We are specifically opposed to a regulatory approach based on the ‘reverse burden of proof’ comparative assessment and hazard substitution,’ says the CIA. Risk assessment substitution and the carrot or the stick? Despite widespread agreement among consultees that risk assessment under the Existing Substances Regulation must be speeded up there is no consensus about how to achieve this. Environmental groups also regard the risk assessment process as deeply flawed. But many consultees from industry agree that new schemes are not the way forward.‘We have severe doubts about a duplicative scheme being created in the UK and firmly believe that no new national schemes should be started for the testing and assessment of chemicals. Global resources for chemicals management are already scarce and those that do exist must be focused on the key issues,’ says CIA. Italian green chemistry recognition program ‘change must be based on the voluntary principle’ (CIA) ‘regulatory action is essential’ (Friends of the Earth) Although most responses from the chemical industry stress that any change must be based on voluntary principles environmental groups say that the stick must accompany the carrot. According to FoE ‘The crucial role of Government [is] in transforming industry and stimulating innovation through technology-forcing regulation rather than voluntary agreements which tend to reduce innovation .. . Friends of the Earth does not consider that a voluntary approach is adequate either to protect human health or to promote innovation. Regulatory action is essential.’ G48 Green Chemistry April 1999 Environmental organisations favour a positive licensing system for chemicals Greenpeace also thinks that innovation can be stimulated by a greater emphasis on substitution. The group’s submission argues that substitution will create new markets for the replacement of hazardous chemicals by less hazardous alternatives. According to Greenpeace ‘Substitution of hazardous chemicals is I TA LY C G Green chemistry in Italy On February 22nd Italy's National Interuniversity Consortium of Chemistry for the Environment (INCA) launched a annual recognition program of industrial contributions in ‘Green Chemistry’ / ‘Clean Chemical Production Processes.’ The formal recognition program was part of the annual INCA meeting in Venice Italy where representatives of some 30 Italian universities gathered to discuss their programs in chemistry for the environment and to map out research and education strategies for the Consortium over the next 5 years.INCA recognized three companies this year. The first award went to Lonza Intermediates and Additives S.A. for its ‘Process Optimization of the Oxidation of o-Xylene to Phthalic Anhydride by the Selective Transformation of Reaction Intermediates.’ The second company honored was Mapei S.p.A.for its development of ‘Very Low VOC Emitting Adhesives ‘and the third Solvay Italia for its process ‘Recovery of Residues from Fume Purification Plants and their Reutilization as Feedstocks.’ Each of the 1999 INCA recipients received a dish engraved citing their specific contribution. Participants in the recognition program included representatives from the Italian Ministry for Industry the Italian Institute for Health the Venetian Regional Program for the Modernization of Industry in Porto Marghera and the U. S. Environmental Protection Agency's Green Chemistry Program. The INCA recognition program is the first OECD country to formally implement an awards program as one of the recommendations contained in the OECD Working Party for Sustainable Chemistry report of October 1998. The OECD recommendation for member countries to implement industrial recognition programs was based on the highly successful Presidential Green Chemistry Challenge Awards program now in its fourth year in the United States. For further information contact Professor Pietro Tundo University of Venice tundop@unive.it or the INCA website hydra.unive.it/inca one feature of a new policy that has real potential to move the chemicals sector onto a more sustainable path.’ 1Sustainable Production and Use of Chemicals Consultation Paper on Chemicals in the Environment. Department of the Environment Transport and the Regions (1998). (http://www.environment.detr.gov.uk/sustainable/ chemicals/consult/index.htm).