TL: ENVIRON. GROUPS DEMANDS, CHEMICAL INDUSTRY SO: Manfred Krautter (Greenpeace Germany) (GP) DT: June 6, 1994 Keywords: toxics chemicals production pollution greenpeace statements gp europe industry policy / ----------------------- POLICY ON CHEMICALS - ENVIRONMENTAL ORGANISATIONS' DEMANDS ON CHEMICAL INDUSTRY IN THE 1990s Text of paper presented at ACHEMA 1994, 6 June 1994 Manfred Krautter Greenpeace, Hamburg The average environmental expenditure by industry amounts to 0.7% of the value of its production (in 1989); in the chemicals sector the figure is 1.9%. Labour costs, however, come to as much as 39% (German Economic Research Institute, 1993). This cost structure is so designed that natural resources important for survival are wasted, and too great a burden is put upon the environment. Resources and environmental protection are too cheap! Environmental expenditure in Germany comes to just 1.6% of the Gross National Product. Military expenditure alone amounts to 2.4% of the GNP - one and a half times as much. The survival of our planet will be determined by ecological laws and not economic rules. Safeguarding the ability of our natural environment to survive must therefore become the primary guiding principle of all economic activity. Policy on chemicals to date Environmental legislation in the seventies and eighties was oriented towards the elements or media (the waste water law for water, the federal pollution control act in the case of air). A drawback to this approach is that pollution is shifted from one medium to another (e.g. effluent pollution becomes pollution of the soil by sewage sludge) without avoidance of pollutant being achieved. Furthermore the "end-of-pipe" philosophy considers almost only emissions in production; the impacts of the products themselves are ignored. Industry's main emissions, however, come through the factory gate in the form of products. But the few laws related to products, such as that on chemicals, have so far been largely ineffective. The staggering increase in the amounts, diversity, and releases of chemicals during the past few decades has led to a fatal "chemicalisation" of the environment. - The world's production of chemicals rose from about one million tonnes in 1940 to about 400 million tonnes in 1990. - The number of known chemical substances worldwide is today approximately twelve million, and is increasing by some 1,600 a day. Over 100,000 synthetic substances are marketed in commercial quantities in the EU. Only a few hundred of these have been analysed toxicologically, or have at least begun to be so analysed. Chemical industry itself does not know, or is quite inadequately aware of, the effects of most of the substances it uses and produces. This game of Russian roulette must be stopped. NEW POLICY ON CHEMICALS Today's policy on chemicals must concern itself with the flow of materials, and take account of environmental impacts over the product's whole life. Policy in the nineties must be about products and the phaseout of environmentally harmful product lines such as chlorine chemicals. Chemical industry has so far met the ecological, and increasingly economic, necessity for a new orientation with great resistance, though there is no lack of verbal acknowledgement of the need for this. - "If precaution (sic!) is called for on account of health and environment considerations, it should restrict the marketing of products or stop production regardless of economic interests" (Chemical industry federation's environmental guidelines). Contrary to its declared intentions, however, chemical industry has recently endeavoured to roll back environmental standards (e.g. reduce effluent charges and remove precautionary limits for pesticides in the drinking water directive). The economic opportunities for environmentally-sound, internationally competitive products with viability for the future have still received too little recognition. The central issue in the controversy over chemicals policy is the development and realisation of environmentally sound alternatives for development in the material-producing industry. Three models for policy on chemicals dominate discussion on it (Held, 1991): - Technical optimisation with orientation on ideal type of closed circuit; - The substitution of specific substances and groups of substances that are environmentally hazardous, especially chlorine chemicals; and - Starting with demand and consumer behaviour and questioning usefulness of function. Other models discussed are: - Orientation on nature and its basic principles: embedding in natural cycles and orientation on principles of natural material cycles; - Changing the raw material base: replacing petrochemicals with renewable raw materials; and - The developmental alternative of genetic engineering (on the part of chemical industry) "Clean Production" - a model for the material-producing industry The natural bases of life will in a foreseeable time be destroyed by today's form of economic activity. To prevent this the question of "what", "how much" and "how" goods are produced must be posed anew. Only through a far-reaching change in how we conduct our economic activities, in moving to "Clean Production", can future generations' right to the conservation of the natural bases of life be upheld and the ability of our planet to survive ecologically be secured. CENTRAL PRINCIPLES OF A NEW POLICY ON MATERIALS 1. Self-restriction and limitation of consumption of resources Per capita production and consumption, mainly in industrialised countries, must be drastically limited. 2. Sustainable use of energy and raw materials Renewable sources of raw materials should be preferred for production. All raw materials, especially renewable ones - but not only these, must be conducted in a cycle. 3. Create material cycles A raw material / product / raw material cycle with minimum losses must replace our open system of raw material / product / waste. 4. Make long-life goods The unnecessary consumption of additional resources will be obviated by long-life products which are easily maintained and repaired. 5. Minimise risks Risky techniques and products, the possible consequences of which are irreparable, irreversible, or may lead to disasters, have to be replaced. 6. Secure biological diversity and maintain ecological balance No man-made or natural substances may be allowed to be introduced by people into the ecosphere in burdensome amounts. Chemical products must be as ecologically sound as possible. Immediate company policy measures for implementing Clean Production criteria (with the aid of Hamburg Environment Institute's "criteria for environmentally sound production") 1. The company applies the same environmental standards of production and products worldwide, and makes it possible for these to be checked by independent bodies. Substances and facilities which are not licensed or allowed in Germany shall not be exported or operated or made in another place. 2. The company only produces in facilities in which an "event" cannot cause a disaster. The only facilities operated shall be those which a commercial assurer insures for unlimited liability for damages. Uninsured facilities shall be shut down. 3. The company reduces the number of chemicals produced; only single chemicals or defined mixtures of substances are brought onto the market. 4. The entry of chemicals into the environment - be they from production or products - shall be drastically reduced. 5. The company makes a comprehensive statement of what substances are contained in the products made by it. 6. Substances which have not been comprehensively analysed to establish their toxicity to people and the environment shall not be marketed. Toxic, persistent and biologically accumulating substances will not be introduced into the environment; the aim will be to replace these by more enviromentally sound substances as soon as possible. 7. The company restricts itself to producing chemicals for which there is an analytic procedure. 8. The company conducts product-line analyses on all the products made by it, with priority on the manufacture of persistent, biologically accumulating and highly toxic substances. The aim is the rapid substitution of especially environmentally harmful products. 9. Product-line analyses will also be conducted for the production of production plants and waste disposal facilities. The basic criteria here are concerned with the amounts of energy, raw materials and waste. 10. The risks from products and production are forcibly borne by the general public. This means that the appraisal of risks and decisions about taking them cannot be left to companies alone. An independent body shall conduct environmental audits for production plants and analyses of product-lines for products. This shall be the basis for decisions on production and products. 11. The company shall orient its research and development on the criteria of Clean Production, and draw up a timetable for developing alternatives to products with environmentally harmful materials. 12. The consumption of non-renewable energy and raw material resources will be drastically restricted, as will the spread of environmentally hazardous wastes. 13. The decomposition paths of all the products made by a company are known to it. No potentially environmentally hazardous interim products should be produced in their decomposition. 14. Closed cycles must be installed for water used in cooling and production. The quality of the resources of air, water and soil used shall basically not be worse after production than before it. 15. The use of (environmental) technologies which are unjustifiable on account of their use of energy or raw materials or production of waste, but are nonetheless used due to a lack of alternatives, shall be for a limited time only. 16. Groundwater shall not be polluted by the company's production or the products made by it. 17. The company acknowledges its obligation to provide information with regard to all data related to the environment, and to toxicological hazards emanating from its plants or products. 18. Critics of technical processes or construction plans must have the same access to information as users or experts working for the company. 19. In testing chemicals the company strives basically not to carry out experiments with animals; a timetable with dates should be set down for the cessation of experiments with animals. 20. The company shall not manufacture any chemical or biological weapons. 21. The company assumes responsibility for the impacts of chemical products made before the new policy. 22. The company remains in possession of its unmarketable products until they can be disposed of or reutilised in an environmentally sound way. Companies should achieve the maximum possible recycling or reutilisation quotas for their products. 23. The company actively supports international environmental organisations and bodies in creating unified environmental standards worldwide and effecting expert, independent controls. 24. The company has comprehensive liability for the products made by it. The precautionary principle applies without restrictions. 25. Long-term goals in environmental protection are of a standing equal to other company priorities, the company integrating them through management and staff training. 26. The company actively supports ecological tax reform to make energy and resources more expensive and reduce the price of the labour factor. If these criteria were to meet general agreement and be implemented by companies according to fixed-date timetables, long-term environmentally-sound production methods and products could emerge and take shape. BIBLIOGRAPHY Hamburg Environment Institute: "Kriterien fuer eine umweltgerechte Produktion" (criteria for environmentally sound production) Martin Held: Leitbilder der Chemiepolitik (models for policy on chemicals), Frankfurt, 1991 Deutsches Institut fuer Wirtschaftsforschung: Umweltschutz und Industriestandort (German economic research institute: environmental protection and industrial sites), Berlin 1993