Saatja: Génon Jensen <
[email protected]>
Saadetud: 21.10.2022 13:35
Adressaat: Génon Jensen <
[email protected]>
Koopia: Natacha Cingotti <
[email protected]>
Teema: Guaranteeing the timely delivery of the EU Green Deal for health:
reforming the REACH and CLP regulations and agreeing on the Sustainable
Use of Pesticides Regulation are not optional
Dear Ministers,
Please find below and attached a letter and our recommendations from the
Health and Environment Alliance (HEAL) on behalf of HEAL and the 13
health civil society organisations for the REACH and CLP reform and the
ongoing discussion on the Sustainable Use of Pesticides Regulation.
Should you have any questions, please feel free to contact the Programme
Lead of HEALs Health and Chemicals team, Natacha Cingotti ()
To: EU national Ministers for Environment, Health, and Agriculture
Dear Ministers,
On behalf of public health groups working together across Europe, we are
writing to you to express our deep concerns at the current delays in the
delivery of several European Green Deal initiatives to address our
everyday exposure to harmful chemicals, which are crucial for improved
disease prevention and health protection today and in the coming
decades.
We need you to send a strong signal to the European Commission President
that the reforms of the REACH and CLP regulations as promised under the
Chemicals Strategy for Sustainability (CSS) are not optional, but crucial
for public health and a healthy economy. We also call on you to support
the Commissions proposal for the Regulation for the Sustainable Use of
Plants Protection Products (SUR), as promised under the Farm-to-Fork
Strategy, to help reduce Europes dependence on pesticides.
If well-crafted, these reforms for industrial chemicals and pesticides
can provide pivotal shifts in the way Europe manages the production and
release of synthetic chemicals, and support their reduction. This would
be an important gain as we are all exposed, mostly unwillingly, to
harmful substances through consumer products we use, the air we breathe,
the work we perform, the food we eat, and the water we drink. These
chemical cocktails build up in our bodies and increase the risk of
serious diseases and health conditions, including but not limited to
cancers and disorders of our reproductive, metabolic, or behavioural
functions. I npractice, the implementation of the promised reforms cna
significantly improve peoples lives by guaranteeing healthiera nd more
sustainable living and working environments and a fundamental shift in
the way our economy operates and provides for every individuals basic
needs.
Importantly, these reforms can also alleviate the current burden weighing
on member states authorities when they want to bring forward regulatory
measures to protect their citizens and their environment, or promote the
implementation of fundamental EU principles such as the polluter pays
principle.
Unfortunately, the EU Green Deal implementation is today being challenged
on unjustified grounds, including geopolitical considerations such as the
Ukraine war and the safeguarding of food security. It is important to
note that the latter in fact makes an urgent case in favour of an even
faster sustainable transition towards a healthy, just, and
environmentally-friendly food system, whereby Europe develops its
environmental, health and economic resilience, strategic autonomy, and
sobriety [1]. Such short-termism is not acceptable and fails to see the
untapped potential of a stronger chemical and pesticide legislative
framework for citizens and economic players alike.
Scientific knowledge about the state of (agri-)chemical pollution keeps
piling up and has reached unprecedented levels of concern that require
robust and swift political responses. Among the latest warning signals,
scientists have highlighted that the pollution created by PFAS chemicals
(short for per- and polyfluorinated-alkyl substances, that are also known
as forever chemicals as they can take up to 1,000 years to break down in
nature) has now exceeded the planetary boundaries [2]. This means PFAS
pollution is ubiquitous across the planet and almost irreversible, and
that we are all exposed. This is particularly worrying when put in
perspective of existing health costs assessment for our exposure to PFAS:
for Europe alone, the annual costs of healht impacts associated to PFAS
exposure are estimated to be between the 52 - 84 billion Euro range [3].
The example of PFAS pollution clearly illustrates that chemical pollution
knows no border and that urgently addressing it in a coherent way has
become a priority for the future of our health, our environment, our
economy and societies as a whole. Yet, the recent European Commissions
postponing of the publication of the REACH reform proposal to the fourth
quarter of 2023 raises serious doubts that the EU executive realises the
extent and urgency of the problem and questions its commitment to its own
objectives and workplan under the EU Green Deal [4].
The use of harmful pesticides in agriculture, green and urban public
spaces continues to put the health of farm workers and citizens at risk,
including that of young children. Occupational exposure to pesticides has
been linked to serious diseases, such as certain types of cancer and
respiratory diseases as well as cognitive disorders and Parkinsons
disease [5]. Communities living in agricultural areas are also affected,
as pesticides are typically detected at distances of 5 to 600 meters from
where they have been used [6].
This increasing pollution and our continuous exposure are having an
impact on our health, and our health systems and wider economy. This is
why we are urging you, as member states representatives, to play your
important part in supporting the delivery of the EU Green Deal. Priority
initiatives for health protection from chemicals include the following:
The swift reform of the REACH and CLP regulations
We ask you, member states representatives, to demand that the European
Commission urgently bring out:
- The reform of the CLP regulation:
* Support the recent European Commission proposal for the addition of
new hazard classes, including for endocrine disrupting chemicals;
* Encourage the European Commission to publish its proposal for the
reform of the main CLP legislative text by the end of 2022.
- The reform of the REACH regulation:
* Demand that the European Commission brings forward its proposal as
soon as possible and in any case before the end of 2023, despite the
concerning postponing of the publication date in the 2023 Commissions
work programme;
* Constructively contribute to the preparatory work of the above-
mentioned legislative proposal.
The adoption of the SUR regulation, now being discussed in Council and
European Parliament:
We ask you, member states representatives, with regard to the Commissions
proposal to:
* Support the proposals legally binding 50% reduction target by 2030 in
the use and risk of synthetic pesticides at EU and national levels;
* Modify the existing tool that calculates pesticide reduction to
objectively promote the use of safer alternatives and non-chemical
methods;
* Support the proposal for a total ban on the use of all pesticides in
areas used by the general public, particularly pregnant women and
children;
* Expand the 3-meter pesticide-free buffer zone in proximity to areas
used by the general public to at least 50 meters, or to at least 100
meters if these areas are used by children, babies and pregnant women.
We thank you for considering our significant concerns and we trust your
willingness to constructively support the successful delivery of the
European Green Deal in view of promoting a healthier, more resilient and
autonomous Europe for todays and future generations.
Yours faithfully,
Genon K. Jensen
Founder Executive Director, Health and Environment Alliance (HEAL)
On behalf of:
Alerte des Médecins sur les Pesticides (AMLP)
Association of European Cancer Leagues
C2DS
Cantine Sans Plastique France
Générations Futures
Health and Environment Justice Support (HEJSupport)
International Society of Doctors for the Environment (ISDE) Italy
Pesticide Action Network (PAN) Europe
Pesticide Action Network Netherlands
Portuguese Society of Environmental Health
Réseau Environnement Santé (RES)
Tegengif / Erase All Toxins
Women Engage for a Common Future (WECF) France
Notes:
[1] Pörtner, L. M. et al. (2022). We need a food system transformation
in the face of the Ukraine war, now more than ever. One Earth.
[2] Cousins, I., T. et al. (2022). Environmental Science &
Technology. DOI: 10.1021/acs.est.2c02765
[3] Nordic Co-operation (March 18, 2019). The cost of inaction: A
socioeconomic analysis of environmental and health impacts linked to
exposure to PFAS. doi: 10.6027/TN2019-516
[4] European Commission, 2023 Work Programme,
[5] Inserm, 2021 Collective Expert Review.
[6] Cech et al, 2022. Science of the Total Environment, DOI:
10.1016/j.scitotenv.2022.158814
Genon K. Jensen (She/her)
Executive Director
Health & Environment Alliance (HEAL)MUNDO MADOUVisitors and
deliveries: Avenue des Arts 7/8 Head office: Rue de la Charité 22Tel:
+32 2 329 00 80
| | | |
Brussels, 21 October 2022
To: EU national Ministers for Environment, Health, and Agriculture
Guaranteeing the timely delivery of the EU Green Deal for health: reforming the
REACH and CLP regulations and agreeing on the Sustainable Use of Pesticides
Regulation are not optional
Dear Ministers,
On behalf of public health groups working together across Europe, we are writing to you to express our
deep concerns at the current delays in the delivery of several European Green Deal initiatives to address
our everyday exposure to harmful chemicals, which are crucial for improved disease prevention and
health protection today and in the coming decades.
We need you to send a strong signal to the European Commission President that the reforms of the
REACH and CLP regulations as promised under the Chemicals Strategy for Sustainability (CSS) are not
optional, but crucial for public health and a healthy economy. We also call on you to support the
Commission’s proposal for the Regulation for the Sustainable Use of Plants Protection Products (SUR),
as promised under the Farm-to-Fork Strategy, to help reduce Europe’s dependence on pesticides.
If well-crafted, these reforms for industrial chemicals and pesticides can provide pivotal shifts in the way
Europe manages the production and release of synthetic chemicals, and support their reduction. This
would be an important gain as we are all exposed, mostly unwillingly, to harmful substances through
consumer products we use, the air we breathe, the work we perform, the food we eat, and the water we
drink. These chemical cocktails build up in our bodies and increase the risk of serious diseases and health
conditions, including but not limited to cancers and disorders of our reproductive, metabolic, or
behavioural functions. In practice, the implementation of the promised reforms can significantly improve
people’s lives by guaranteeing healthier and more sustainable living and working environments and a
fundamental shift in the way our economy operates and provides for every individual’s basic needs.
Importantly, these reforms can also alleviate the current burden weighing on member states’ authorities
when they want to bring forward regulatory measures to protect their citizens and their environment, or
promote the implementation of fundamental EU principles such as the polluter pays principle.
Unfortunately, the EU Green Deal implementation is today being challenged on unjustified grounds,
including geopolitical considerations such as the Ukraine war and the safeguarding of food security. It is
important to note that the latter in fact makes an urgent case in favour of an even faster sustainable
transition towards a healthy, just, and environmentally-friendly food system, whereby Europe develops
its environmental, health and economic resilience, strategic autonomy, and sobriety [1]. Such short-
termism is not acceptable and fails to see the untapped potential of a stronger chemical and pesticide
legislative framework for citizens and economic players alike.
Scientific knowledge about the state of (agri-)chemical pollution keeps piling up and has reached
unprecedented levels of concern that require robust and swift political responses. Among the latest
warning signals, scientists have highlighted that the pollution created by PFAS chemicals (short for per-
and polyfluorinated-alkyl substances, that are also known as ‘forever chemicals’ as they can take up to
1,000 years to break down in nature) has now exceeded the planetary boundaries [2]. This means PFAS
pollution is ubiquitous across the planet and almost irreversible, and that we are all exposed. This is
particularly worrying when put in perspective of existing health costs assessment for our exposure to
PFAS: for Europe alone, the annual costs of health impacts associated to PFAS exposure are estimated to
be between the 52 - 84 billion Euro range [3].
The example of PFAS pollution clearly illustrates that chemical pollution knows no border and that
urgently addressing it in a coherent way has become a priority for the future of our health, our
environment, our economy and societies as a whole. Yet, the recent European Commission’s
postponing of the publication of the REACH reform proposal to the fourth quarter of 2023 raises serious
doubts that the EU executive realises the extent and urgency of the problem and questions its
commitment to its own objectives and workplan under the EU Green Deal [4].
The use of harmful pesticides in agriculture, green and urban public spaces continues to put the health of
farm workers and citizens at risk, including that of young children. Occupational exposure to pesticides
has been linked to serious diseases, such as certain types of cancer and respiratory diseases as well as
cognitive disorders and Parkinson’s disease [5]. Communities living in agricultural areas are also affected,
as pesticides are typically detected at distances of 5 to 600 meters from where they have been used [6].
This increasing pollution and our continuous exposure are having an impact on our health, and our health
systems and wider economy. This is why we are urging you, as member states’ representatives, to play
your important part in supporting the delivery of the EU Green Deal. Priority initiatives for health
protection from chemicals include the following:
The swift reform of the REACH and CLP regulations
We ask you, member states representatives, to demand that the European Commission urgently bring
out:
- The reform of the CLP regulation:
● Support the recent European Commission proposal for the addition of new hazard classes,
including for endocrine disrupting chemicals;
● Encourage the European Commission to publish its proposal for the reform of the main
CLP legislative text by the end of 2022.
- The reform of the REACH regulation:
● Demand that the European Commission brings forward its proposal as soon as possible
and in any case before the end of 2023, despite the concerning postponing of the
publication date in the 2023 Commission’s work programme;
● Constructively contribute to the preparatory work of the above-mentioned legislative
proposal.
The adoption of the SUR regulation, now being discussed in Council and European Parliament:
We ask you, member states representatives, with regard to the Commission’s proposal to:
• Support the proposal’s legally binding 50% reduction target by 2030 in the use and risk of
synthetic pesticides at EU and national levels;
• Modify the existing tool that calculates pesticide reduction to objectively promote the use of safer
alternatives and non-chemical methods;
• Support the proposal for a total ban on the use of all pesticides in areas used by the general public,
particularly pregnant women and children;
• Expand the 3-meter pesticide-free buffer zone in proximity to areas used by the general public to
at least 50 meters, or to at least 100 meters if these areas are used by children, babies and
pregnant women.
We thank you for considering our significant concerns and we trust your willingness to constructively
support the successful delivery of the European Green Deal in view of promoting a healthier, more
resilient and autonomous Europe for today’s and future generations.
Yours faithfully,
Genon K. Jensen
Executive Director, Health and Environment Alliance (HEAL)
On behalf of:
Alerte des Médecins sur les Pesticides (AMLP)
Association of European Cancer Leagues
C2DS
Cantine Sans Plastique France
Générations Futures
Health and Environment Justice Support (HEJSupport)
International Society of Doctors for the Environment (ISDE) Italy
Pesticide Action Network (PAN) Europe
Pesticide Action Network Netherlands
Portuguese Society of Environmental Health
Réseau Environnement Santé (RES)
Tegengif / Erase All Toxins
Women Engage for a Common Future (WECF) France
The Health and Environment Alliance (HEAL) is the leading not-for-profit organisation addressing how the environment affects human health
in the European Union (EU) and beyond. HEAL works to shape laws and policies that promote planetary and human health and prot ect those
most affected by pollution, and raise awareness on the benefits of environmental action for health.
HEAL’s over 90 member organisations include international, European, national and local groups of health professionals, not-for-profit health
insurers, patients, citizens, women, youth, and environmental experts representing over 200 million people across the 53 countries of the WHO
European Region.
As an alliance, HEAL brings independent and expert evidence from the health community to EU and global decision -making processes to inspire
disease prevention and to promote a toxic-free, low-carbon, fair and healthy future.
HEAL’s EU Transparency Register Number: 00723343929-96
Notes:
[1] Pörtner, L. M. et al. (2022). “We need a food system transformation – in the face of the Ukraine war,
now more than ever.” One Earth. https://doi.org/10.1016/j.oneear.2022.04.004
[2] Cousins, I., T. et al. (2022). “Outside the Safe Operating Space of a New Planetary Boundary for Per-
and Polyfluoroalkyl Substances (PFAS).” Environmental Science & Technology. DOI:
10.1021/acs.est.2c02765
[3] Nordic Co-operation (March 18, 2019). “The cost of inaction: A socioeconomic analysis of
environmental and health impacts linked to exposure to PFAS.” doi: 10.6027/TN2019-516
[4] European Commission, 2023 Work Programme, https://ec.europa.eu/info/publications/2023-
commission-work-programme-key-documents_en
[5] Inserm, 2021 Collective Expert Review. https://presse.inserm.fr/en/inserm-publishes-its-latest-
collective-expert-review-on-the-health-effects-of-pesticides/43303/
[6] Cech et al, 2022. “Pesticide drift mitigation measures appear to reduce contamination of non-
agricultural areas, but hazards to humans and the environment remain” Science of the Total Environment,
DOI: 10.1016/j.scitotenv.2022.158814