6. Some policy initiative for reducing risk
There are over a dozen European Union Directives on chemicals control (Fig. 7) concerning classification and labelling, marketing and use, risk assessment, and protection of workers, consumers and the environment. Compliance with, and enforcement of these Directives is uneven, in part because it can be difficult for industry to know how best to achieve compliance with several sets of regulations. For example, in the dyestuffs industry, a highly competitive business involving many innovative and potentially hazardous chemicals, a study of the Notification of New Substances Directive (the NONS project, VROM 1996) in the 15 Member States of the EU found that many new substances being used had not been reported to the regulatory authorities, or even identified. Their use was not properly recorded, and in some cases they were inadequately labelled. About 45% of the 96 companies visited in most countries of the EU did not conform to this Directive. However, a follow-up project revealed some improvements, with just 32% of the 100 companies inspected in this sector not conforming to the Directive (the SENSE project; VROM, 1998).
All European countries have extensive national legislation in the field of chemicals. For example, a review of UK legislation on the control of chemicals (excluding pharmaceuticals and poisons) listed 25 relevant Acts of Parliament which were overseen by seven government departments and augmented by over 50 sets of regulations (Haigh, 1995). A similar pat-tern of multi-departmental policy response exists in many EU countries, which is prompting efforts to streamline such legislation and to shift the focus of policy measures from "downstream" impacts of control on workplaces, consumers and ecosystems to "upstream" reduction of exposure potential and prevention (Gottlieb, 1995; Steingraber, 1997) (Fig. 6). The Integrated Pollution Prevention and Control Directive of the EU obliges large plants to adopt such a comprehensive approach to pollution prevention.
In addition to EU Directives and regional initiatives, European countries are guided by a number of regional and international treaties. The Convention on Long-Range Transboundary Air Pollution (LRTAP), adopted in 1979 under the auspices of the United Nations Economic Commission for Europe (UNECE), covers Europe and North America. This Convention includes measures for eliminating or restricting use, reducing consumption and unintentional emissions or contamination, eliminating waste and improving the management of chemicals. It features two new protocols signed at the pan-European Ministerial meeting at Aarhus in June 1998. One protocol covers Persistent Organic Pollutants (POPs), including 16 pollutants: aldrin, chlordane, chlordecone, DDT, dieldrin, dioxins, endrin, furans, heptachlor, hexa-bromobiphenyl, hexachlorobenzene, hexa-chlorocyclohexane (including the isomer Lindane), mirex, polycyclic aromatic hy-drocarbons, PCBs and toxaphene. The other protocol covers certain heavy metals (cadmium, lead and mercury).
The Chemical Industry Sustainable Economic and Ecological Development programme (CHEMISEED), managed by the United Nations Economic Commission for Europe (UNECE), focuses mainly on harmonising legislation, cleaning contaminated sites, and promoting the eco-efficient use of chemicals in Central and Eastern Europe. The UNECE Working Group on Abatement Technology is helping countries to comply with the 1991 Volatile Organic Compounds (VOC) Protocol, under the LRTAP Convention, which came into force in 1997.
The voluntary Prior Informed Consent (PIC) procedure has been developed by UNEP and the Food and Agriculture Organization (FAO) of the United Nations. In March 1998, governments completed negotiations to transform PIC into a legally binding convention for strengthening the management of certain hazardous chemicals in international trade. Under PIC, governments will be required to stop the export of listed chemicals to other countries that have indicated that they do not want them imported, provided the importer does not manufacture or import the substance from another source for domestic use. Thus, chemicals can be pre-vented from entering countries where the risks they pose are deemed unacceptable by the recipient country. Soon after completing PIC, governments began negotiations (June 1998) on a global convention dealing with persistent organic pollutants (POPs). Its purpose will be to reduce and/or eliminate the release into the environment of those POPs which pose significant threats to human health and wildlife. Although the convention negotiations are to focus initially on a list of 12 POPs, they will include the development of criteria and a process for identifying additional POPs for international action. These negotiations under the auspices of UNEP are to be completed by the year 2000.
Co-ordination of international work on chemicals has been facilitated by the IFCS which was established in 1994 as called for in Chapter 19 of Agenda 21 of the 1992 UN Conference on Environment and Development. The IFCS provides policy guidance and strategies for implementation of the major programme areas contained in this chapter, including harmonisation of risk assessments and chemical classification, information exchange, risk reduction and chemicals management capacity building.