|
Chemicals Management
The products of chemistry provide undeniable and significant benefits to society. However, some also possess inherent hazards that must be identified and responsibly managed. Over time, knowledge about the basic characteristics of the chemicals has grown, primarily as a result of continuous studies and the development of refined testing methodologies. Control measures have been introduced to reduce the most serious risks of chemical exposure. Dow has traditionally been keenly engaged in this area, which is now broadly defined as chemicals management.
In the period 2000 to 2004, we are actively participating in three voluntary international initiatives aimed at improving the quality and availability of health and environmental information on High-Production-Volume (HPV) chemicals. The initiatives were developed as a joint effort among governments, the chemical industry, and environmental groups. They focus on filling information gaps by completing appropriate testing, and making a summary of the test findings available to the public. Governments in Europe and North America are driving development of new policies for the introduction of new chemicals and the continued scrutiny of chemicals already established in commerce. The chemical industry has, as part of the Responsible Care® initiative, committed to improving the public availability of information about these chemicals.
Dow’s involvement in these efforts is primarily delivered through the chemical industry trade associations in Europe, Canada, and the United States. We have volunteered to provide information consistent with the HPV criteria for over 180 chemicals; Dow is the sole volunteer for 33 chemicals. We are on track to meet our testing commitments.
At the same time, we are trying to assess the impact of the evolving European Commission’s Chemicals Management Policy, including the "REACH" protocol, which was introduced in 2001 and is expected to be in place in 2006. REACH would require the registration, evaluation and authorization for some 30,000 chemicals currently on the market, as well as for those to be introduced in the future. The burden would fall principally on manufacturers, but downstream users also have obligations under the proposed system. Increased regulatory scrutiny of chemicals is also underway in Canada, the United States, and in some Asia Pacific nations.
We favor a scientifically justified, risk-based, and globally consistent system of regulating chemicals. We are, therefore, working through trade associations in each geographic region to deliver a unified, scientifically based, advocacy position to support our point of view. Dow has contributed to the development of the International Coalition of Chemical Associations’ Global Chemicals Management Policy, which includes an objective to:
"Provide the information and data (a knowledge base) for assessing health, safety, and environmental effects of chemicals and their intended uses. This would be sufficient to: consistently prioritize chemicals to determine which should be focused on first; promote and contribute to the understanding of health, safety, and environmentally related scientific issues on chemicals; and promote further minimization in the use of animals in testing."
This policy has been used to establish metrics that the American Chemistry Council (ACC) will use to measure company performance as part of its Responsible Care commitment. The ACC product-related metrics include demonstration that a company has a risk characterization process and provides a summary of that process to the public. Also, ACC requires that the company is applying its risk characterization process and sharing information in an easily accessible way with the public. Dow intends to provide access to our risk characterization process through www.dow.com, where we will be continuing to make product risk characterization documents available.
Dow is also participating in the U.S. Environmental Protection Agency’s (EPA) Voluntary Children’s Chemical Evaluation Program (VCCEP). VCCEP was initiated in 2001 as a pilot program to evaluate a tiered approach to assessing the risk that chemicals might pose to children’s health. Dow has committed either alone or as part of an industry consortia to assist the EPA in the evaluation of seven chemicals. During 2003, detailed risk assessments for two of those chemicals, vinylidene chloride and acetone, were submitted to the VCCEP peer-consultation process. Risk assessments on the remaining five chemicals will be prepared and submitted to fulfill Dow’s commitments.
Animal Testing
One of the more divisive aspects of chemicals management is the issue of animal testing. This government-required testing, primarily with mice, rats, and rabbits, has long played an important role in major scientific breakthroughs, ranging from nutrition improvements to new medicines. Nevertheless, we seek to develop alternative tests that don’t involve animals but are acceptable to regulatory agencies and we follow a self-imposed regimen of using a minimal, and decreasing, number of animals. We also provide humane handling, care, and treatment for all the animals used in our testing laboratories. This practice is audited and validated by the Association for Assessment and Accreditation of Laboratory Animal Care. When selecting a contract research organization, an evaluation of its animal welfare practices is also part of our decision-making process.
Responsible Care® is a registered service mark of the American Chemistry Council
|
