SAICM needs a new mechanism for action

SAICM needs a new mechanism for action


A group of NGOs*, including HEJSupport, submitted a proposal to the SAICM Secretariat for the next IP meeting, taking place in October 2019 Bangkok. The NGOs present in their paper a new mechanism of action and criteria for elevation of obligations to progress SAICM Issues of Concerns (IoCs) in the post 2020 multilateral regime for chemicals and waste.

*Health and Environment Justice Support (HEJSupport), Swedish Society for Nature Conservation (SSNC), Pesticide Action Network (PAN International), European Environmental Bureau (EEB), German NGO Forum on Environment and Development, Health and Environment Alliance (HEAL), Canadian Environment Law Association, Centre for Environmental Justice and Development (CEJAD), Confederación de Ecologistas en Acción, groundWork – Friends of the Earth South Africa, Društvo Ekologi brez meja, Gallifrey Foundation, ZERO – Associação Sistema Terrestre Sustentável,, Citizens’ Network on Waste Management, Women Engage for a Common Future (WECF), Public Eye, Women’s Healthy Environments Network, Friends of the Earth Germany

Toxic chemical exposure is a burden that disproportionally harms low and middle-income countries and has a negative impact on sustainable economic growth. Today, children are born ‘pre-polluted’ with dozens, if not hundreds, of hazardous chemicals in their bodies. Many of these chemicals harm the developing brains and bodies of children and have devastating lifelong and multi-generational consequences.(1) SAICM stakeholders have a duty to prevent children and other vulnerable groups from being exposed to toxic chemicals and pollution, including those substances the risks of which are not well understood. As the summary report to GCO II states, “solutions exist, but more ambitious worldwide action by all stakeholders is urgently required”. Stakeholders should continue working together to ensure that chemical safety issues are part of global and national targets, development agendas and poverty eradication strategies.

For these reasons, a number of stakeholders have agreed that the successor to SAICM (2) should contain a new mechanism of action, a process whereby IoCs for which inadequate progress has been made should be progressed to mechanisms with increased levels of obligations on stakeholders. (3) Our paper addresses the criteria that could be used in such a process. They were developed with the existing IoCs in mind but would apply also to new IoCs acknowledged under ‘SAICM 2’.

In addition, ‘SAICM 2’ should provide for the development of indicators that match these criteria, include time-bound goals, (4) a process of critical evaluations against these goals and the associated indicators, and the process for progressing an IoC to an issue with increased obligations.

Criteria for moving Issues of Concern (IoC) to the level with increased obligations

Failure to comply with, or fulfilment of, any criterion in the list below warrants consideration of moving the IoC to an increased level of obligation.

1  Failure to reduce acute poisoning and/or chronic effects by chemicals that are IoCs

2  Failure to reduce the levels of chemicals that are IoCs in human and environmental samples

3  Failure to reduce the volume of the production, use and disposal of substances of very high concern relevant to an IoC

4  Insufficient monitoring of human and environmental impacts by an IoC

5  Significant costs for society in the absence of action to address an IoC, including healthcare costs for individuals and the state; loss of IQ and productivity; loss of pollinators, natural biological control of pests, and other ecosystem services; loss of biodiversity; and costs of chemical contamination of natural resources, such as air, soil and water including but not limited to large-scale environmental clean-up and remediation costs

6  National regulations have failed to achieve sufficient improvement in the IoC (5)

7  Regional regulations for addressing an IoC are in place, or under development (6)

8  Failure to establish an effective, transparent multi-stakeholder working platform on an IoC

9  Failure to make available the information necessary for addressing an IoC (7)

(1) Bennett et al. 2016. Project TENDR: Targeting Environmental Neurodevelopmental Risks. The TENDR Consensus Statement. Environmental Health Perspectives 124(7):A118-!122
(2) Here referred to as ‘SAICM 2’ until a new name is agreed.
(3) For example, a legally binding protocol, a treaty, mandatory action plans and reporting, or other such agreement that places requirements on stakeholders.
(4) Time-bound goals should not be used to delay action for existing IoCs that have not progressed sufficiently under the present SAICM.
(5) IoC is not part of the national implementation plans; IoC is not included in national budgets; no national regulations developed to address particular IoC; no control measures are applied to monitor results on addressing IoC; the IoC has global dimensions and cannot be addressed efficiently by regulative measures in a single country, e.g. due to globalized trade.
(6) Regulations in one or two regions advance the IoC beyond SAICM and move it to the next level with increased obligation at the regional level, for example, the EDCs regulation in the EU. Such regional regulation is an acknowledgement of the necessity of an obligatory approach. These criteria are necessary to create a level playing field for all countries, so that those that are proactive in protecting human health and the environment from chemical threats are not disadvantaged on the global market. It reflects the Rotterdam Convention where regulatory action in two UN regions stimulates the listing of a chemical or pesticide under the Convention.
(7) Confidential business information currently takes precedence over transparency, despite the clear message in SAICM that information on chemicals relating to the health and safety of humans and the environment should not be regarded as confidential.

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Written by Alexandra Caterbow

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