|
(05-08) Substitution and Precaution: Irreconsilable Principles in Risk Assessment and Management? Ahlers, Jan*,1, 1 Umweltbundesamt, Bismarckplatz 1, Berlin, Germany ABSTRACT- The principles of precaution and substitution are particularly critical when applied as elements of risk assessment and management of existing chemicals. In contrast to new chemicals they are already on the market and used in a wide range of applications. Usually, each application requires a different substitute. Due to a lack of data it is difficult to find a better alternative for a certain use or function of a chemical substance. Moreover, the uncertainty about the possible substitute might create even more problems. It would seem that the only way out of this dilemma is the obligation for industry to deliver a minimum data set for all relevant industrial chemicals. In addition, new concepts such as assessment on the basis of spatial range or risk management on the basis of persistence and bioaccumulation may be valuable tools to combine precaution and substitution. The registration and evaluation steps in the proposed REACH system of the EU White Paper on a strategy for a future chemicals policy will lead to more basic data, making it possible to compare different substitutes. The authorisation of very hazardous chemicals will lead to a large demand for less critical alternatives. Moreover, an assessment of chemical substances in clusters according to structural similarities or identical uses (use clusters) would facilitate the application of the substitution principle. Often sufficient risk communication (e.g. about the availability of less hazardous substances or of successful substitutions) is a prerequisite to enforce substitution. Non-chemical alternatives should also be included in substitution schemes. Examples for the advantages of these approaches are discussed: a comparative risk assessment of complexing agents (EDTA, NTA), risk assessment and risk management of short, medium and long chain chlorinated paraffins as well as priority setting and a combined assessment of fatty acid amines. Key words: Substitution, Precautionary Principle, Existing chemicals, Risk Assessment and Management |
