The International Council of Chemical Associations (ICCA) strongly supports the continuation of SAICM beyond 2020. Through our P
xpertise and S
olutions, the global chemical industry PAVES
the way for sustainable development and sound chemicals management under SAICM. We provide investment and in-kind resources to promote the safe manufacture, handling and use of chemicals worldwide – but we can’t pave this road alone, and there is more work to do.
SAICM’s multi-stakeholder approach has led to partnerships and collaboration between stakeholders that would not have been possible under a traditional, treaty-based approach.
While the perspectives of engaged stakeholders may differ, we share a common commitment to strengthening chemicals management around the world.
Government officials from developed and developing nations, NGOs and other elements of civil society, and experts from industry are each contributing their perspectives and knowledge to build a stronger foundation for sound chemicals management.
This collaborative approach has allowed for different regions to develop tools and approaches that are best suited to their individual needs and circumstances and that are complementary to their existing governmental requirements, as they vary greatly from region to region.
The trust and cooperation developed through the SAICM multi-stakeholder approach will continue to pay dividends as new issues emerge and work continues beyond 2020.
Moving forward to 2020 and beyond, SAICM activities should be prioritized to focus on those that can make the biggest contribution to sound chemicals management, particularly in countries that lack the capacity to do so.
SAICM has the opportunity to leverage progress in sound chemicals management to promote overall economic growth and improve the quality of life in countries that do not have robust chemical management frameworks today. Chemicals management is a necessary precursor to the growth of a sustainable manufacturing sector and international investment.
To achieve this, stakeholders should work with governments to support the creation of programs that will help responsibly manage the production, handling and use of chemicals throughout their lifecycle and that will accelerate and intensify the deployment of innovative products and technologies to address global challenges.
Success under SAICM depends on input and financing from all committed stakeholders, including industry.
ICCA is committed to ongoing support of SAICM through investment of monetary resources and in-kind contributions.
ICCA members have provided direct financial support to the SAICM Secretariat and significant in-kind contributions to help advance SAICM implementation including:
- Dedicating significant resources to develop, launch and promote ICCA’s Global Product Strategy (GPS) and expanding Responsible Care to over 60 countries, including China;
- Sponsoring and conducting 172 GPS and RC capacity building workshops;
- Preparing guidance related to best practices; and
- Participating in numerous public-private partnerships that promote the safe production, handling and disposal of chemicals.
To sustain financing in the future, ICCA supports the recommendation of UNEP’s Governing Council for an integrated approach to financing for sound chemicals management and its three components:
- Mainstreaming chemicals management into development planning, meaning that developing countries elevate chemicals management in their development plans, including economic and natural resource planning, and incorporate it into their international development assistance priorities. This approach is consistent with ICCA’s belief that sound chemicals management is essential to growing manufacturing sectors and international investment.
- Enhancing industry engagement, including the establishment of new partnerships, in kind contributions and incentives for industry to demonstrate further leadership.
- Increasing external funding by identifying new sources and broadening existing international financing mechanisms that will support relevant national institutions and national chemicals management activities.
It’s also important to recognize that industry provides substantial financial contributions to the sound management of chemicals through taxes, fees and other cost-recovery mechanisms applied by governments around the world.
ICCA believes governments should undertake actions that will intensify the deployment of products and technologies to address global climate change challenges. Addressing global climate issues, particularly through improved energy efficiency, is very important to the chemical industry, which enables greater carbon efficiency throughout the economy with the use of our products.
Chemical products have two effects on GHGs:
- GHGs are emitted in the manufacture of chemical products;
- Use of many of these products enables significant emission reductions in other sectors, often greater than the amount of GHGs emitted during their production.
ICCA believes successful implementation of the landmark Paris Agreement reached last December during the Conference of the Parties (COP-21) of the United Nations Framework Convention on Climate Change (UNFCCC) hinges in large part on the private sector transforming international policy directives on climate into action by investing, developing and deploying innovations to address global sustainability challenges, including reducing greenhouse gas (GHG) emissions.
The global chemical industry will be instrumental to the development, production, and delivery of these products and technologies.
ICCA strongly supports the objective of promoting sound chemicals management throughout the value chain.
Industry has brought its knowledge of global supply chains and existing mechanisms for sharing information to the table to help inform the development of the Chemicals in Products (CiP) initiative.
However, ICCA believes the CiP program proposal needs further improvement. Otherwise it will not attract the critical mass of industry participation that it needs to be successful.
Specifically, the proposal needs more work to meet three critical requirements:
- Refrain from duplicating existing information-sharing mechanisms;
- Incorporate consideration of risk and exposure in addition to hazard;
- Focus on sharing relevant health and safety information while protecting legitimate confidential business information, which is critical to supporting innovation and economic growth.
Transparency and access to chemical safety information is a centerpiece of our ongoing effort to drive best practices in chemicals management.
ICCA’s position is that all relevant health and safety information on chemicals should always be made available to the public. ICCA’s Global Products Strategy (GPS) web-based portal offers more than 4,600 product safety summaries on chemicals in commerce today.
The United Nations Globally Harmonized System (GHS) of Classification and Labelling plays a central role in harmonizing efforts to ensure that important information is available to determine whether certain chemicals in products can be used safely.
ICCA supports the expansion of the GHS, and we believe the CiP program can and should complement GHS by broadening its reach in developing economies where it’s less established.
ICCA fully supports the elimination of new decorative paints containing lead additives around the world by 2020.
The science is clear: lead doesn’t have a place in the paint we use to decorate our homes and offices.
The most industrialized countries in the world have successfully controlled the sale of lead-containing decorative paints for decades. We agree it’s time for the rest of the world follow suit. Government regulation and enforcement at the national level will be essential in achieving this objective.
Paints containing lead additives that are used in industrial settings or in applications that do not create consumer exposures do not pose risks of negative health effects. For example, paints containing lead are used to mark our roads for safety and to protect industrial parts from corrosion. These paints can still be used safely in such specific applications.
ICCA is ready to work with others to support the phase out of lead additives in decorative paints in developing countries.
Some small and medium sized enterprises (SME) and governments in developing countries face a variety of barriers to phase out the use of lead additives in decorative paints.
Industry, governments and SMEs should work together to overcome any barriers that may stand in the way of ensuring the health and safety of people living in these countries.
ICCA has joined forces with the Global Alliance to Eliminate Lead Paint (GAELP) and the International Paint and Printing Ink Council, Inc. (IPPIC) to help countries establish a regulatory framework to phase-out the manufacture and sale of decorating paints containing lead additives.
We believe NGOs can also support this effort through grassroots campaigns to raise awareness of the health and safety concerns in transitional areas.
ICCA supports evidence and risk-based approaches to identifying and managing chemicals that may affect the endocrine system.
ICCA’s Long-range Research Initiative (LRI) is developing cutting-edge screens and tests to identify substances that interact with the endocrine system (“endocrine-active”) and those that cause adverse effects through that interaction (“endocrine disruptors”).
The LRI has also substantially contributed to the development of High Throughput (HTP) tools that can be used to prioritize and conduct certain screens on dozens of chemicals at once, instead of the labor- and time-intensive manual techniques that have traditionally been used.
As part of current government programs like the U.S. EPA’s Endocrine Disruptor Screening Program (EDSP), industry has generated significant amounts of data on chemicals for use by regulators to determine whether their chemicals are endocrine active, and if so, whether they cause adverse effects due to that interaction.
We support efforts through SAICM to share information among stakeholders related to the existing work of governments, international organizations, civil society and industry on EDCs.
Any efforts related to endocrine activity of chemicals under SAICM should not duplicate or pre-judge ongoing efforts to broaden knowledge and understanding.
ICCA does not support any proposal to create an aggregated list of “known” or “suspected” EDCs. Many of the currently available lists are not based on conclusive evidence, and lists do not provide a full picture of a chemical’s use, benefits or safety profile, which are critical to determining a chemical’s use.
Efforts to prematurely label chemicals as endocrine disruptors or categorize chemicals as “suspected endocrine disruptors” create misperceptions about substances and cause unwarranted marketplace disruption.
ICCA sees the work plan on EDCs requested at ICCM-3, and developed by UNEP, WHO and the OECD, as the more appropriate basis for further work. Many of the issues raised in resolutions from SAICM regional meetings are covered by this work plan. Addressing them again would be costly and redundant and take away from resources better spent on making progress with other SAICM priorities.