OCTOBER 20249CHEMICAL INDUSTRY REVIEWWe need to be more fleet of foot in setting out controls at source to mitigate pollution and we need to have the courage to enact the polluter pays and producer responsibility principles to fund such activityby the WFD. However, the Commission also identified several needs that are relevant for both surface and groundwater that should be addressed to improve the level of protection of the European water environment, both on the surface and beneath.Looking at Surface water first. The addition of further new substances of concern to those we monitor, and control is warranted to ensure a coherent approach to such EU-wide risks is maintained. Similarly some existing Environmental Quality Standards (EQS) thresholds for specific substances need review in the light of better evidence, indeed some substances should be banned and controlled at source as they represent too significant a risk in pollution terms. For groundwater -­ several substances identified by the Groundwater Watchlist process need to be better controlled, including the PFAS group, pharmaceuticals and non-relevant metabolites of pesticides as groups of(emerging) pollutants of concern. Some of these also may need monitoring via the Drinking Water Directive(DWD). Again some of these chemicals are now ubiquitous in our environment and have been in use for more than a decade, before we have realised their harmful impacts on the environment or public health. The fact that after many years of use we register such chemicals indeed ban some after decades of use, simply recognises that man's ingenuity to produce and introduce for use ever more complex and societally useful chemicals consistently outstrips society's ability to regulate and control the entry of such substances in to the environment. This is where the key improvements are clearly needed ­ to stop the introduction of such chemicals, or at the very least short circuit the time taken to discover the harm they are causing. The good news then is the Commission is well on with its review, recognises many of the failings of the existing system, has good evidence collected, understand the costs and benefits of tightening regulatory standards and the need for real pace in our review processes ­ all to drive positive change.Critical will be whether the EU parliament has the political will to control the most polluting substances at source due to the economic impact on the pharmaceutical and chemical industries. This could be done with either mandatory product substitutions and or bans on production / sales, or suitably tight environmental quality controls which drive abatement solutions. Similarly politicians could choose to use the application of the producer responsibility principle enacted in EU (and now UK legislation through the Environment Act 2021) where the producers of pollution pay for the clear up, such as that urgently needed for single use plastics.On the subject of plastics, here in the UK we have our private members Bill going through the Westminster Parliament to ban the sale and production of wet wipes, which we know block our sewers and pollute our environment. This Bill as I see it will represent a water shed moment for Government, hopefully the first of a number of new controls at source measures adopted to protect the environment and public health. We should know later this year whether such efficient and effective controls are enabled.Governments also have economic instruments at their disposal such as the shortly to be introduced plastic packaging tax in the UK which is set at £200 per tonne charge for plastic packaging that doesn't contain at least 30 percent % recycled content.With all these tools and regulatory controls at Governments disposal many are now looking forward to the results of the EU review and the new controls and tighter standards expected for the better control of those chemicals most harmful to ecosystems and society. How we transpose these into UK legislation sadly remains opaque, but I am sure will become clearer as we are challenged on this matter by the eNGO community and our trading partners in the EU. One thing is for sure, we cannot continue to close the stable door after the horse has bolted. We need ever better evidence, and slicker regulatory processes to establish the harm (or not) caused by new and existing chemicals. We need to be more fleet of foot in setting out controls at source to mitigate pollution and we need to have the courage to enact the polluter pays and producer responsibility principles to fund such activity. If we lack the courage for such changes now, the next generation will wonder why we did not act and will not thank us.
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