Introduction
In 2021, the United Nations Environment
Programme (UNEP) recognized
chemical pollution as a planetary crisis tantamount to climate change
and biodiversity decline.
1
In an important
next step, the international community agreed in March 2022 on establishing
an independent, intergovernmental science–policy panel on chemicals,
waste, and pollution prevention (hereafter termed “the Panel”).
2
This Panel will take its place among two other
intergovernmental bodies, the Intergovernmental Panel on Climate Change
(IPCC)
3
and the Intergovernmental Science-Policy
Platform on Biodiversity and Ecosystem Services (IPBES).
4
Now is a crucial time for establishing the Panel,
following a process facilitated by UNEP to negotiate the Panel’s
scope, functions, and institutional design, with the ambition to formally
establish the Panel in 2024.
As a group of international scientists
working on chemical pollution,
we applaud this milestone of progress to initiate the establishment
of a panel for chemicals, waste, and pollution prevention. At the
beginning of the negotiating process, we would like to highlight the
following 10 critical aspects for consideration in determining the
settings of the Panel.
1
Why a New Panel?
The new Panel is needed
to fill a critical gap pertaining to the mounting and accelerating
impacts on human and environmental health caused by chemical pollution
and waste globally. The highly multifaceted and heterogeneous impacts
of chemical pollution encompass a wide array of issues that often
show dynamic development and require international action.
5
Therefore, there is an urgent need for a big-picture
perspective resulting from a comprehensive and ongoing horizon scanning,
monitoring, interpretation of data, and synthesis of individual findings.
This goes beyond the remit of existing bodies at the national, regional,
and international levels because their scopes and mandates are limited
to certain chemicals, geographical areas, or jurisdictions (examples
here include the Basel, Stockholm, Rotterdam, and Minamata conventions).
For the development of effective action at the global level, comprehensive
and authoritative scientific assessments are crucial.
2
Avoid Paralysis by Analysis
Current
knowledge is sufficient for several chemicals or groups of chemicals
with hazardous properties (for example, lead, mercury, asbestos, and
several pesticides) to enable implementing evidence-based solutions.
As an integrator of scientific information, the Panel must avoid “paralysis
by analysis” by repeatedly re-assessing the same topics and
substances. The reports “Late lessons from early warnings I
& II”
6,7
provide a wide range of examples
(e.g., benzene, DDT, mercury, lead, asbestos, and PCBs) where continued
research expanded and deepened the understanding of the issue but
largely confirmed earlier insights and where, accordingly, action
could and should have been taken earlier. Also, knowledge of the proper
treatment of many types of waste is available, which helps to reduce
and ideally prevent the spread of many pollutants into the environment.
The Panel should therefore provide a comprehensive bigger picture
and forward-thinking reviews and assessments to enable horizon scanning
in order to identify new research gaps and needs, also for more recently
identified “emerging” issues.
3
Scope
The Panel’s work needs
to be broad and inclusive to properly respond to the breadth and complexity
of global chemical production, use, releases, and disposal, involving
up to several hundred thousand chemicals, of which a substantial fraction
is hazardous to humans and/or ecosystem health. This includes well-characterized
“legacy” chemicals, but also a much larger array of
“chemicals of emerging concern” and novel waste streams
such as non-agricultural biocides, per- and polyfluoroalkyl substances
(PFAS), pharmaceuticals; personal care products, toxic metal(loid)s,
rare-earth elements, and other chemicals being used in growing renewable
energy and digital technology industries.
8
In addition to understanding the impact of the use of single substances,
effects from mixtures also need to be considered.
9
Also to be addressed are the numerous (and often insufficiently
known) impurities in the produced chemicals and the even larger array
of (potential) chemical contaminants resulting from abiotic and biotic
environmental transformation processes.
10
4
Tasks and Outputs
As with other science–policy
bodies, the Panel should be policy-relevant but not policy-prescriptive
in providing integration and analyses that support sound, evidence-based
policy development. Early warning of new and emerging chemical contamination
issues, including the analysis of options for policy actions, should
be among the regular tasks for the Panel. The Panel should inform,
and provide feedback to, policymakers, especially in national and
multinational jurisdictions and regulatory bodies, about important
scientific gaps and findings and also inform the scientific community
about policy-relevant scientific questions. Chemical hazard and risk
assessments are performed by existing bodies, and while these processes
could be improved, assessments of individual chemicals should not
be the primary focus of the Panel. Rather, the Panel should address
strategically important and broader issues. These issues may include
the identification and assessment of chemical groups of concern (see
above), effective strategies for avoiding regrettable substitution,
etc.
5
Roles of Different Actors
The models
of IPCC and IPBES should inspire and inform the Panel in terms of
the roles and responsibilities of various societal actors and groups
contributing to its work. Governments should nominate independent
experts as the main “workforce” of the Panel. Independent
scientists will provide primary scientific results; independent scientists
can also facilitate the appropriate use of the assessments of the
Panel. Also, national and international government scientists should
be included as independent experts. However, while government scientists
are free to publish scientific findings in the peer-reviewed literature,
they may not be permitted to comment on or contradict existing government
policies on chemicals, specifically if there is divergence or conflict
of opinion. Other actors such as intergovernmental organizations,
environmental nongovernmental organizations, civil society groups,
community-based organizations, and the private sector should act as
observers and be invited to provide input.
6
Conflicts of Interest
The Panel needs
to establish and enforce a strict conflict-of-interest policy. In
particular, it must be recognized that, while the private sector might
be privy to important information, its representatives may also have
inherent conflicts of interest. Research shows that systematic strategies
for influencing, and in some cases discrediting, both the science
and the subsequent policy development have been used by industries
manufacturing tobacco, coal, sugar, oil, and chemicals.
11
This need for a clear conflict-of-interest statement
also applies to those who act through nongovernmental bodies such
as multisector associations. All experts contributing to the work
of the Panel must declare their conflicts of interest, financial and
otherwise.
7
Data
Following IPCC and IPBES, a range
of data from the peer-reviewed scientific literature, gray literature,
and existing biological and chemical monitoring programs will be foundational
for the outcomes of the Panel. This highlights the importance for
the Panel to make use of all available reliable and relevant data
and not to limit itself to prescribed data formats such as those defined
by specific test guidelines or good laboratory practice (GLP), as
such a limitation may exclude studies of significance, especially
from all geographic areas. Studies from the scientific literature
have proven to be valuable in the restriction of chemicals under the
EU chemicals regulation, REACH, meaning that these studies were considered
of sufficient reliability and relevance.
12
As a model, the new Transparency Regulation in the European Union’s
food laws is also expected to open up previously unavailable data
for use in other domains of chemical oversight in the EU and beyond.
Transparency of data and the Panel’s workflow is crucial. Furthermore,
the inclusion of under-resourced countries or regions in mobilizing
data (digitized and undigitized) should be fostered.
8
Establish Inclusive Knowledge Exchange
The production, use, and disposal of chemicals are important parts
of human activities across the globe. However, different countries
and regions approach the management of hazardous chemicals and waste
in different ways, driven by different government political climates,
economic systems, and state capacity, as well as different geographical
and ecological conditions. It will therefore be critical that the
Panel apply a transdisciplinary approach to the integration of knowledge,
across different temporal and spatial scales and different regions
of the world. The ability of the Panel to provide useful options for
improving the management of chemicals and waste will depend on an
integration of natural and biomedical sciences [e.g., chemistry, exposure
sciences, (eco)toxicology, ecology, epidemiology, and risk assessment],
social sciences (e.g., economics, political sciences, communication
sciences, and law), humanities, traditional and local indigenous knowledge,
and other knowledge sources. The adequate involvement of experts in
risk communication will be critical for the dissemination and contextualization
of the Panel’s work.
9
Work Program and Uptake of Results
The Panel has the potential to contribute objective, authoritative,
and current syntheses of information for countries to utilize as they
develop national and international policies. The work of the Panel
will provide a new and valuable resource from which information can
be drawn and from which suggestions for future actions can be developed.
Again, we emphasize that the outcomes of the Panel will be policy-relevant,
but not policy-prescriptive, and the actual way forward will be decided
by political processes at national, regional, and international levels
that feed into the intergovernmental process.
10
Global Representation and Participation
The Panel needs to ensure that all countries are adequately represented
in terms of experts and their backgrounds, data, and access to information.
The Panel should operate on a global scale to identify and address
critical needs in terms of both information and capacity. One key
task of the Panel is to address the limitation that currently available
data and expertise are centered on high-income countries, even though
the majority of pollution-related impacts and deaths occur in low-
and middle-income countries. The Panel should recognize that these
countries, broadly defined as the “Global South”, have
a critical but poorly recognized role in the production of chemicals
and handling of chemical waste and carry a substantial part of the
burden from chemical pollution, while at the same time being global
biodiversity hotspots.
Join the Process
Academic scientists around the world
will play a crucial role in
the work of the Panel. The time to prepare the ground for this important
task is now, by providing input to the political process defining
the setup of the Panel. We encourage scientists from all countries
to join the discussion, indicate their interest in the Panel’s
work, identify urgent chemical pollution and waste issues in their
regions, and share their insights with fellow scientists as well as
policymakers nationally and internationally.
An Open-Ended Working
Group (OEWG) has been established under UNEP
as the venue where the scope, function, and structure of the Panel
are being discussed and, eventually, will be decided.
13
Decisions will be made by governments; nongovernmental
stakeholders can be accredited as observers to contribute to the discussion.
Academic scientists can join this process through several avenues.
One is by being nominated as a member of their government’s
delegation. This will be an important role for scientists to play
but will be limited to a relatively small number of scientists per
country.
Another possibility is through accredited nongovernmental
organizations
(NGOs). However, many of these organizations may have specific mandates
that do not necessarily reflect, or are even in contradiction with,
the role of independent scientists. Therefore, there is a need for
organizations that fulfill the requirements for accreditation (most
importantly, nongovernmental, not-for-profit status, engagement in
the field of environment, and international scope) and that can offer
a platform for academic scientists to present their contributions
to the discussion. This function may be fulfilled by scientific societies
such as the Royal Society of Chemistry (RSC), the Society of Environmental
Toxicology and Chemistry (SETAC), the Endocrine Society, and others.
An example of an organization that specifically and exclusively represents
academic scientists is the International Panel on Chemical Pollution
(IPCP).
Finally, academic institutions may also be accredited
with UNEP,
which would facilitate participation of their faculty members. However,
very few universities have so far applied for accreditation, and it
is not yet fully clear under which circumstances universities fulfill
the status of “nongovernmental”. According to UNEP,
applications from academic institutions are welcome, also to further
clarify the accreditation process for universities.
14,15
The development of the Panel represents an important step
forward.
It recognizes the global nature and the complexity of chemicals and
waste issues. The Panel will provide the much-needed forum for comprehensively
addressing these challenges.