Letters

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Find HEAL’s latest letters from all of our activity areas here, we update this page regularly.

The letters are listed chronologically, but you can also search by subject area in the box on the right.

Date	Title
24/05/2018	Open Letter to President Juncker on behalf of 31 business associations, civil society, think tanks and other organisations on the Multi-Annual Financial Framework
03/05/2018	HEAL receives response from upcoming Austrian presidency to call for ambition for health and the environment On 17 April 2018, HEAL sent a letter to the Austrian Chancellor Sebastian Kurz ahead of Austria's upcoming presidency of the Council of the European Union from July 2018 on. We encouraged this member state to show leadership to advance on a safe environment that benefits people’s health and an adequate allocation of resources to climate and environment measures. On 2 May 2018, we received the response from the Director General for Coordination, responsible for EU matters and the Austrian Presidency of the Council of the European Union. The response can be found online here. The letter HEAL sent to Chancellor Kurz can be found here.
24/04/2018	HEAL highlights Western Balkans coal power plants’ lack of compliance with Energy Community rules ahead of Energy Community/European Parliament exchange The Health and Environment Alliance (HEAL) underlines the current unpreparedness of coal power plants in the Western Balkans to meet emission standards ahead of a European Parliament Industry, Research and Energy Committee meeting with the Energy Community. 24 April 2018 - The Health and Environment Alliance (HEAL) underlines the current unpreparedness of coal power plants in the Western Balkans to meet emission standards ahead of a European Parliament Industry, Research and Energy Committee meeting with the Energy Community. HEAL's briefing on the implementation of Large Combustion Plants Directive: 'Boosting Health By Improving Air Quality in the Balkans' shows that cutting down air pollution from Western Balkan coal power plants as of 2018 could result in 6,460 lives saved each year, if emission limits that need to be achieved by 2028 would be applied. Read the letter here.
24/04/2018	Seven NGOs ask for stricter standards on chemicals in textiles ahead of REACH committee meeting Ahead of this week's REACH committee meeting, seven NGOs call for stricter proposals on textiles, phthalates and nanomaterials. 23 April 2018 - Ahead of this week's REACH committee meeting, seven environment and health NGOs call for stricter proposals on textiles, phthalates and nanomaterials. The letter was sent to all members of the REACH Committee by the European Environmental Bureau (EEB), on behalf of the Center for International and Environmental Law (CIEL), ClientEarth, EcoCity, Ecologistas en Acción, the Health and Environment Alliance (HEAL), and Women Engage for a Common Future (WECF).
17/04/2018	HEAL encourages an ambitious Austrian presidency for health and the environment HEAL encourages Austria to show leadership to advance on a safe environment that benefits people’s health and an adequate allocation of resources to climate and environment measures. In a few months Austria will be taking over the presidency of the Council of the European Union. In an open letter sent to Chancellor Sebastian Kurz, HEAL encourages Austria to show leadership to advance on a safe environment that benefits people’s health and an adequate allocation of resources to climate and environment measures. The letter can be found online here. The response from the Austrian government can be found here.
16/04/2018	HEAL urges French President to act in favour of European transition towards a non-toxic environment Ahead of his visit to the European Parliament, HEAL sent a letter to French President Emmanuel Macron highlighting the decisive role France is playing in the European Union and asking him to act in favor of a European transition towards a non-toxic environment. 16 April 2018 - French President Emmanuel Macron will be addressing the European Parliament on Tuesday 17 April 2018 about the future of Europe. Ahead of this important debate, the Health and Environment Alliance (HEAL) sent a letter to President Macron highlighting the decisive role France is playing in the European Union and asking him to act in favour of a European transition towards a non-toxic environment, as outlined in the 7th Environment Action Program (EAP). The letter can be found online here.
11/04/2018	Open letter to MEPs of PEST committee - Glyphosate: an emblematic failure of the EU pesticides regime
04/04/2018	Letter to commissioner Vella and commissioner Andriukatis on human health and preventive action in BREFs
27/02/2018	Letter to commissioner Hahn on climate and air quality issues in the Balkans
20/02/2018	Letter to health ministers WHO European region outside EU 28 to take decisive action for clean air
14/02/2018	Letter to EU 28 health ministers to take decisive action for clean air in the EU by multiplying health sector engagement
24/01/2018	Letter on decision to challenge air pollution control measures to Bulgarian ministers
11/01/2018	Letter to Dutch Members of European Parliament: reject EC plans for BPA in food contact materials
09/01/2018	HEAL urges MEPs to reject European Commission plans for Bisphenol A in food contact materials Ahead of a discussion and vote in the European Parliament Environment Committee, HEAL urges MEPs to reject the European Commission proposed regulation on the use of bisphenol A (BPA) in food contact materials. Dear MEP, As a membership network of over 70 public interest organisations aiming to promote and protect people’s health through environmental action, the Health and Environment Alliance (HEAL) looks forward to the European Parliament’s environment committee using its right of scrutiny on the European Commission proposed regulation on the use of bisphenol A (BPA) in varnishes and coatings intended to come into contact with food and amending regulation 10/2011 [1]. On Thursday 11th January, we urge you to reject the European Commission regulation mentioned above, which fails to protect citizens from the adverse health consequences of BPA, and rather to support the motion for objection jointly put forward by several Members across political parties. There are well known human health and environment concerns in relation to exposure to Bisphenol A, including its endocrine disrupting properties and its toxicity for reproduction. These concerns justify a full ban of the substance at the European level in all consumer products, in particular sensitive products such as materials coming into contact with the food that European citizens eat [2]. However, the European Commission’s regulation proposes only to lower the migration limit of BPA in varnishes and coatings intended to come into contact with food, and consequently will fail to adequately protect European citizens because BPA can have adverse health effects at very low doses. This weak proposal is all the more puzzling and disappointing given safer alternatives are available and some member states and industry retailers are already on the path to substitution, showing that a full ban is possible. HEAL is asking you to oppose the European Commission regulation for three main reasons: 1. BPA’s recognised endocrine disrupting properties for human health and the environment and toxicity for reproduction The adverse health and environment effects of BPA are very well documented, with concerns about those effects due to its endocrine disrupting properties already flagged up in the 1990’s. The European Chemicals Agency (ECHA) validated those concerns when identifying BPA as a substance of very high concerns (SVHC) because of its endocrine disrupting properties for human health and the environment respectively in June and December 2017 [3]. Such identification adds to BPA classification as toxic for reproduction under the CLP regulation (which also got strengthened from category 2 to 1B in July 2016 [4]) and should open the way for a full phase out of this toxic substance in the near future. As you will be aware, endocrine disrupting chemicals are a significant challenge in terms of health protection because exposure at very low levels is associated to numerous adverse effects ranging from cancers to infertility problems, thyroid or behavioural disorders, which can sometimes manifest themselves years or decades after the actual exposure time. This is why exposure at key periods of human development (such as in utero exposure of the embryo or puberty) is so critical. From the perspective of regulators, this calls for particular caution when it comes to protecting individuals from exposure to chemicals through everyday consumer items such as the packaging wrapping the food we eat, because there are significant uncertainties about the establishment of said “safe levels”. 2. European Parliament 2016 resolution calling for full BPA ban in food contact materials In the case of the regulation of BPA in food contact materials, it is also important to recall that the European Parliament already took a unanimous decision in support of a full ban of the substance in all food contact materials, through its 2016 resolution [5]. Not only does the European Commission regulation not comply with this earlier demand, but it also fails to bring any meaningful argument to justify why this is the case, in a context where the scientific evidence and ECHA opinions on BPA are piling up to support a full ban of the substance. 3. Safer alternatives available and member states and industry retailers already taking action As pointed out by ECHA itself, safer alternatives are readily available to BPA on the European market and this should add further impetus for decision-makers to fully phase out the substance [6]. On the one hand, retailers are increasingly taking unilateral action to substitute BPA due to consumer demands and an understanding that there is a business case in the promotion of truly safer alternatives in the long run [7]. On the other hand, France’s experience with the introduction of a ban of BPA in all food contact materials since 2015 shows that substituting this toxic substance is possible and has given rise to inspiring industry exchanges about safer substitutes [8]. However, if agreed upon, the European Commission regulation would hinder this progressive example of health-protective and innovation-stimulating measures. For all the reasons mentioned above, HEAL is of the opinion that the proposed European Commission regulation that you will discuss on 11th January should be opposed, as a matter of health protection, consistency with earlier European identification and European Parliament decision, and from a business point of view. We count on you to put human health protection first and remain available for any question that you might have. Yours sincerely, Ms. Génon K. Jensen, Executive Director Health and Environment Alliance (HEAL) Contact: Natacha Cingotti – Policy Officer, Chemicals and Health, Health and Environment Alliance (HEAL), +32 (0)2 234 36 45, natacha@env-health.org Notes: 1. http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32011R0010&from=FR 2. http://www.env-health.org/resources/publications/article/food-contact-materials-and 3. https://echa.europa.eu/documents/10162/ac9efb97-c06b-d1a7-2823-5dc69208a238; https://echa.europa.eu/documents/10162/13638/svhc_msc_support_document_bisphenol_a_en.pdf/de4c668e-c1bf-d13c-b035-be8b624a69b1 4. http://eur-lex.europa.eu/legal-content/EN/TXT/uri=uriserv:OJ.L_.2016.195.01.0011.01.ENG&toc=OJ:L:2016:195:TOC 5. http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P8-TA-2016-0384 6. See https://echa.europa.eu/regulations/substituting-hazardous-chemicals/examples-from-real-life/safer-alternatives-for-bisphenol-a 7. See for instance https://chemicalwatch.com/59211/danish-retailer-urges-ban-on-bisphenols-and-fluorinated-substances-in-fcms 8. https://substitution-bp.ineris.fr/en/medias
08/12/2017	Lettre au gouvernement français relative à la seconde demande de l’ICE Stop Glyphosate
22/11/2017	HEAL letter on EBRD on its support for thermal and coking coal in its mining policy revision HEAL has sent a joint letter together with CEE Bankwatch and Re:Common to the on European Bank for Reconstruction and Development (EBRD) calling on it to abandon its support for thermal and coking coal in its mining policy revision. Read the full document here.
16/11/2017	Open letter to negotiators in German coalition talks – climate action means protection of health HEAL has sent an open letter to the parties involved in coalition talks for a next German government, the CDU and CSU, FDP and Greens. It reads: ‘we are noting with concern that to this point there is no agreement on climate action that will ensure that Germany sticks to its duties deriving from the Paris Agreement and its own goals for 2020 and beyond.’ The letter recommends 1. Phasing out coal by 2030 2. Ending subsidies for fossil fuels as well as setting a concrete date for this HEAL underlined these arguments with key data on the connection between energy choices, climate change and health and ended with the ‘hope that the potential coalition partners prioritise the protection of the health of the German and European citizens and agree the necessary steps on climate action in a coalition contract’. Read the original letter here.
16/11/2017	HEAL urges MEPs to support measures that promote health in EED vote [This letter was sent to all Members of European Parliament of the Industry, Research and Energy committee on 16 November 2017] Dear MEP, I am writing on behalf of HEAL, a leading European not-for-profit organisation working for better health through a healthier environment, regarding the Energy Efficiency directive, set to be voted by the EP’s Industry committee on November 28. In Europe, buildings use 40% of energy and produce nearly 36% of CO2 emissions. The EED legislation does not only have the potential to cut greenhouse gas emissions, it is first and foremost a key tool for healthier homes for millions of Europeans! As Europeans spend 90% of their time indoors, the quality of homes is a public health issue. The evidence linking buildings and building efficiency to physical and mental health is increasing: • 1 in 6 Europeans live in homes that make them sick: leaky, often damp homes, in urgent need of retrofits. Such buildings are defined as having “leaking roof or damp floor, walls or foundation, a lack of daylight, inadequate heating during the winter or overheating problems”; • Europeans are more than 1.5 times as likely to report poor health when living in an unhealthy building; • Europeans are 40% more likely to have asthma when living in a damp or moldy home; • Damp conditions are strongly linked to childhood illness (Gilbertson et al, 2006b, p12); • Up to 100 000 excess winter deaths in Europe are directly linked to cold homes, a situation directly linked to oftentimes inefficient buildings; • Cold homes are also shown to affect mental well-being: in the UK, programs addressing home insulation showed a significant impact in reducing anxiety and depression (Green and Gilbertson, 2008, pp14,18). Improving the health and comfort of people in buildings holds huge potential for economic and societal benefits such as better health, increased productivity, reduced sick leave and a decrease in associated medical costs. Progress on efficiency is also an opportunity to improve air quality, bringing massive healthcare cost savings. The 2017 Cambridge Econometrics study commissioned by the European Commission estimates a 40% energy efficiency target would save a whopping 77 billion Euros in healthcare costs.The Commission also estimates that approximately 200,000 premature deaths could be avoided. A 40% efficiency target for 2030, associated with a strong Article 7, is crucial to drive renovation efforts and provide a stable context for investments in efficiency improvements, which will bring huge health benefits and tackle social inequality. We hope we can count on your support for these proposals. Best regards, Anne Stauffer Director for Strategy and Campaigns
06/11/2017	Civil society and businesses demand health considerations to be given in Energy Performance of Buildings Directive (EPBD) In a letter to the European Parliament, HEAL was joined by civil society organisations and businesses to demand the Energy Performance of Buildings Directive (EPBD) prioritizes healthy indoor environments and binding measures to improve the energy performance of buildings in Europe. In a letter to the European Parliament, the Health and Environment Alliance (HEAL) was joined by civil society organisations and businesses to demand the Energy Performance of Buildings Directive (EPBD) prioritizes healthy indoor environments and binding measures to improve the energy performance of buildings in Europe. The letter, that was coordinated by Buildings 2030 and HEAL, was send to Members of the European Parliament involved in EPBD trialogue negotiations, and can be viewed online here.
24/10/2017	HEAL and the European Cancer Leagues urge EU ministers to reject European Commission proposal on glyphosate HEAL and the Association of European Cancer Leagues (ECL) urge EU ministers to reject the European Commission proposal for the 10-year re-approval of glyphosate, the world's most used herbicide. [This letter was sent to all Environment, Health, and Agriculture Ministers of the European Union member states on 23 October 2017] Dear Minister, The Health and Environment Alliance (HEAL) – a membership network of over 70 public interest organisations aiming to promote and protect people’s health through environmental action - and the Association of European Cancer Leagues – a pan-European umbrella organisation of national and regional cancer leagues including countries from Iceland to Turkey - welcome that representatives of EU Member States will discuss the European Commission proposal for re-authorisation of glyphosate on the EU market this week in the Standing Committee on Plants, Animals, Food and Feed. On Wednesday 25th October, we urge your representative to prioritise citizens’ health and cancer prevention by rejecting the European Commission proposal to re-authorise glyphosate in Europe for another ten years. Your rejection of this proposal is essential for the following reasons: • Glyphosate is the active substance in the world’s currently most used herbicide and human exposure to the substance has continuously increased over the last 30 years. Traces of glyphosate have not only been found in the bodies of all individuals tested for its presence (1), but also in numerous food items consumed by the majority of the European population on a daily basis (2). Numerous scientific studies assessed its potential harm (3). • In March 2015, the World Health Organisation (WHO) International Agency for Research on Cancer (IARC) has classified glyphosate as “probably carcinogenic to humans”. It is worth repeating that IARC is considered to be the gold standard when it comes to identifying carcinogens. Its research was carried out by a working group of 17 scientists free of conflicts of interests on the basis of the systematic assembly and review of all publicly available evidence relevant to the carcinogenicity of glyphosate (5). The European agencies EFSA and ECHA found that glyphosate is not carcinogenic, mostly based on studies provided by the industry and not available in the public domain. Meanwhile, serious questions about the influence of Monsanto – which has strong commercial interests in keeping glyphosate on the European market, because of its use in the mixture of his best seller herbicide Roundup – on the European carcinogenicity assessment of glyphosate have emerged and remain unanswered to date. These questions should be fully addressed before a sound discussion on the re-authorisation of the substance can take place (6). • The current proposal of the European Commission does not take into account the requirements set out in the resolution voted by the European Parliament in April 2016 (7). This resolution called for a renewed approval for a period of only seven years, and demanded that glyphosate would not be used for non-professional uses in or close to public parks, public playgrounds and public gardens. These demands are an absolute minimum in order to reduce citizens’ exposure to toxic chemicals and promote a transition towards a more sustainable agriculture. • Finally, the European Commission proposal ignores the significant legal and societal concerns about the current European evaluation process of pesticides. o On the one hand, the European Court of Justice was recently asked to assess whether the current risk assessment process respects the precautionary principle in order to properly protect human health and the environment (8). Such process calls for caution in the current re-authorisation discussions of glyphosate, as its outcome could have significant implications for the future approval process of pesticides. o On the other hand, 1.3 million citizens have signed the European Citizens Initiative demanding the ban of glyphosate and a reform of the European pesticides authorisation system (9) and cancer organisations – including in France, Belgium, Malta, Portugal and the UK – are increasingly calling for the promotion of health protection by reducing or eliminating glyphosate use (10). For all the reasons above and keeping in mind that regulating chemical use remains the best buy in cancer prevention, we urge you to reject the European Commission proposal on 25th October. In the meantime, we remain available for any question that you might have. Yours sincerely, Génon K. Jensen Executive Director, the Health and Environment Alliance (HEAL) Dr. Wendy Yared Director, Association of European Cancer Leagues (ECL) Contact: Natacha Cingotti, policy officer, health and chemicals, Health and Environment Alliance (HEAL); natacha@env-health.org; +32-2234-36-45 Anna Prokupkova, Policy & Project Officer, Association of European Cancer Leagues (ECL); Anna@europeancancerleagues.org; +32-2256-20-00 Notes: 1. http://www.env-health.org/resources/press-releases/article/to-what-extent-are-the-french 2. http://www.env-health.org/resources/press-releases/article/generations-futures-investigation 3. See consensus scientific statement: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4756530/ 4. http://www.iarc.fr/fr/media-centre/iarcnews/pdf/MonographVolume112.pdf 5. http://env-health.org/IMG/pdf/2017.05.09_heal-ecl-letter-to-mac.pdf 6. http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P8-TA-2016-0119+0+DOC+XML+V0//EN ; http://www.env-health.org/resources/letters/article/heal-s-opinion-on-glyphosate-vote 7. http://www.pan-europe.info/press-releases/2017/10/european-court-justice-has-chance-revolutionize-european-pesticide-policy 8. https://stopglyphosate.org/en/ 10. http://www.env-health.org/resources/press-releases/article/chemical-regulation-is-best-buy-in The Health and Environment Alliance (HEAL) is a leading European not-for-profit organisation addressing how the environment affects health in the European Union (EU). With the support of more than 70 member organisations, HEAL brings independent expertise and evidence from the health community to different decision-making processes. Our broad alliance represents health professionals, not-for-profit health insurers, doctors, nurses, cancer and asthma groups, citizens, women’s groups, youth groups, environmental NGOs, scientists and public health research institutes. Members include international and Europe-wide organisations as well as national and local groups. Website: www.env-health.org. Follow HEAL on Facebook and Twitter @HealthandEnv ECL is a pan-European umbrella organisation of 26 national and regional cancer leagues including countries from Iceland to Turkey. It provides the secretariat for the MEPs against Cancer group, which currently has 32 members.
18/10/2017	HEAL asks the European Parliament environment committee to support proposed objection to glyphosate proposal [This letter was sent to all members of the European Parliament Committee on Environment, Public Health and Food Safety on 18 October 2017] Dear Member of the European Parliament, As a membership network of over 70 public interest organisations aiming to promote and protect people’s health through environmental action, the Health and Environment Alliance (HEAL) welcomes the European Parliament (EP) opportunity to have a say on the European Commission proposal for renewal of the authorisation of glyphosate on the EU market. On Thursday 19th October, the Committee on Environment, Public Health and Food Safety of the European Parliament will discuss a motion for resolution to object the European Commission proposal to reauthorize glyphosate in Europe for another ten years. We are urging you to support this motion in order to honour previous commitments taken by the European Parliament and prioritise health and cancer prevention. As a member of the environment committee, your voice is absolutely critical for the following reasons: • Glyphosate is currently the world’s most used herbicide in the world and human exposure to the substance has continuously increased over the last 30 years. Traces of glyphosate have not only been found in the bodies of all individuals tested for its presence (1), but also in numerous food items consumed by the majority of the European population on a daily basis (2). There are numerous scientific studies on its potential harm (3). • European top soils are contaminated with glyphosate, (4) and evidence is mounting that demonstrates that this chemical persists longer in the environment than previously thought. This is particularly concerning because soil contamination also affects the food that farmers cultivate and that we eat. • In March 2015, the World Health Organisation (WHO) International Agency for Research on Cancer (IARC) has classified glyphosate as “probably carcinogenic to humans”. It is worth repeating that IARC is considered to be the gold standard when it comes to identifying carcinogens. Its research was carried out by a working group of 17 scientists free of conflicts of interests on the basis on the systematic assembly and review of all publicly available evidence relevant to the carcinogenicity of glyphosate (5). The European agencies EFSA and ECHA found that glyphosate is not carcinogenic, mostly based on studies provided by the industry and not available in the public domain. Meanwhile serious questions about the influence of Monsanto – which has strong commercial interests in keeping glyphosate on the European market, because of its use in the mixture of his best seller herbicide, Roundup – on the European carcinogenicity assessment of glyphosate have emerged and remain unanswered to date. The European Parliament should demand that these questions are answered and the European assessment of glyphosate is re-opened so that an informed discussion on the re-authorisation of the substance can take place (6). Against this background, the European Parliament should demand that the European Commission proposal at least respects the EP resolution from April 2016 (7). This resolution called for: a renewed approval for a period for only seven years, and that glyphosate should not be used for non-professional uses in or close to public parks, public playgrounds and public gardens. These demands are an absolute minimum in order to reduce citizens’ exposure to toxic chemicals and promote a transition towards a more sustainable agriculture. Finally, we urge you to take into account the ever-growing concerns of citizens and public health voices in relation to the continued use of glyphosate. This is illustrated by the 1.3 million signatures to the European Citizens Initiative to stop glyphosate and reform the European pesticides authorisation system (8) as well as increasing calls from cancer organisations – including in France, Belgium, Malta, Portugal and the UK – to promote health protection by reducing or eliminating glyphosate use (9). On 19th October, we trust that you will prioritize the health of citizens and future generations by supporting the objection to the European Commission proposal. We remain available for any question that you might have. Contact: Natacha Cingotti, Health and Environment Alliance (HEAL), natacha@env-health.org, +32 (0)2 234 36 45 Notes: 1. http://www.env-health.org/resources... 2. http://www.env-health.org/resources... 3. See consensus scientific statement: https://www.ncbi.nlm.nih.gov/pmc/ar... 4. http://www.pan-europe.info/press-re... 5. http://www.iarc.fr/fr/media-centre/... 6. http://env-health.org/IMG/pdf/2017.... 7. http://www.europarl.europa.eu/sides... ; http://www.env-health.org/resources... 8. https://stopglyphosate.org/en/ 9. http://www.env-health.org/resources...
17/10/2017	NGOs express concerns surrounding EU actions on the evaluation of PFOA HEAL joins the European Environmental Bureau (EEB) and other environment and health NGOs in expressing concerns to the European Commission over the involvement of an industry consultant in recommendations to create exemptions for the cancer linked chemical PFOA. HEAL joins the European Environmental Bureau (EEB) and other environment and health NGOs in expressing concerns to the European Commission over the involvement of an industry consultant in recommendations to create exemptions for the cancer linked chemical PFOA. The full letter can be read online here.
28/09/2017	Letter to Dutch Members of European Parliament: EU Criteria for endocrine disrupting chemicals will not protect health The European Commission's proposed criteria for identifying endocrine disrupting chemicals should be amended, as they will not protect the health of European citizens. In a letter to Dutch European Members of Parliament (MEPs), HEAL joined two other organisations - Wemos and Women Engage for a Common Future (WECF) - to call upon them to reject the current criteria. With the letter, HEAL, Wemos, and WECF express their concerns about the European Commission's criteria's flaws. The letter can be read online here (available in Dutch only).
26/09/2017	HEAL urges MEPs to reject European Commission’s unlawful and insufficient proposal on endocrine disruptors Ahead of a key vote on endocrine disrupting chemicals (EDCs) on 28 September, HEAL urges Members of European Parliament (MEPs) to reject the European Commission's unlawful and insufficient proposal. Dear MEP, As a membership network of over 70 public interest organisations aiming to promote and protect people’s health through environmental action, the Health and Environment Alliance (HEAL)would like to thank the Environment Committee for looking critically at the European Commission proposed identification criteria for endocrine disrupting pesticides. Today, we are urging you to reject these criteria, which we and millions across Europe believe will jeopardize our health, when you vote on September 28th. HEAL, alongside international scientific societies, major public health voices such as non-profit health insurers representing 200 million Europeans and the European cancer leagues, as well as hundreds of public interest groups, have been very critical of this proposal, which will leave people highly exposed to toxic chemicals and consequently at a higher risk of serious health problems such as hormonal cancers, infertility and developmental disorders. This is all the more disappointing as there is a significant public health and fiscal opportunity to reduce the economic burden arising from such diseases – which is estimated to be of at least 163 billion euros in the European Union every year. Our concerns are shared by almost half a million European citizens, who have signed a petition in rejection of the proposal on the table. The proposed European Commission identification criteria for endocrine disruptors are far from delivering the ambitious approach that we need to address this public health and economic challenge (1). We ask you to use your right to reject the European Commission proposal for the following reasons: 1. The burden of proof requested in the European Commission proposal is so high that it will make it nearly impossible to identify a pesticide as an endocrine disruptor, leaving hundreds of toxic chemicals off the hook. Failure to identify endocrine disruptors will delay regulatory actions in order to ban or phase out those chemicals, when people and workers are exposed to them every day and urgent action is needed. 2. The European Commission proposal introduces an unlawful exemption for substances designed to have an endocrine mode of action (Annex of the proposal, point 2, final paragraph – proposed exemption for non-target organisms). This exemption is equivalent to “de-identifying” substances that technically qualify as endocrine disruptors, and therefore constitutes an illegal derogation, whereby the European Commission is exceeding its mandate to establish science-based criteria for identification (2). In making up your mind, please consider the real-life impacts of the ill-designed identification of endocrine disruptors. These not only include the adverse health impacts detailed above and the associated burden of addressing these for public budgets, but they also mean a huge toll on the European current and future workforce at a time of severe economic and planetary crisis. We remain available for any question that you might have, including through a face-to-face meeting. Yours sincerely, Ms. Génon K. Jensen, Executive Director Health and Environment Alliance (HEAL) Notes: 1. HEAL editorial: https://www.euractiv.com/section/endocrine-disruptors/opinion/addressing-endocrine-disrupting-chemicals-requires-an-integrated-strategy/ 2. See ClientEarth and CIEL legal analyses of the proposed criteria: https://www.clientearth.org/analysis-reveals-unlawful-action-eu-commission-hormone-disrupting-chemicals/
11/09/2017	HEAL joins German NGOs to call for swift implementation of pollution control regulation In an open letter to the German ministry of economy as well as the ministry of environment, the Health and Environment Alliance (HEAL) joined six large German NGOs as well as the European Environmental Bureau (EEB) in calling for a speedy implementation of a new EU regulation which is set to curb air pollution from power plants, the so-called LCP BREF. The signatories condemn actions by four German states, led by the Prime Minister of Saxony Stanislaw Tillich, who asked the federal minister of economy Brigitte Zypries to file a legal complaint against the European Commission for publishing the LCP BREF in its current form. In their letter the NGOs stress the importance of Germany cutting its emissions as the second largest contributor to coal emissions and related health damage in the EU. They call on the government to respect the EU decision on the LCP BREF which was made under Comitology rules as a delegated act already in April 2017, when the German government had voted against it. Arguments of large costs for operators from required retrofits had then been voiced by representatives of the German government, mainly with regards to a new standard for lignite-fired power plants. The same arguments are now re-circulated by four German states that still depend on lignite mining: Saxony, Saxony-Anhalt, Brandenburg and North Rhine Westphalia. Most lignite plants in Germany do not yet comply with the upper range of the LCP BREF for nitrous oxides of 175 milligram per cubic metre. NGOs stress, however, that many of these plants will have reached the end of their lifetime and will have to be closed down for reasons of climate mitigation around 2021, the year by when the new standards will be effective for operators.
31/07/2017	Joint NGO letter to Commissioner Vella on air quality adjustment requests
27/06/2017	73 NGOs + World Alliance request workshop to end amalgam for children The Health and Environment Alliance (HEAL) has joined a coalition of 73 NGOs and The World Alliance for Mercury-Free Dentistry to urge the UN Environment Executive Director to co-sponsor a global workshop on ending amalgam use for children. L'Alliance Mondiale pour une Dentisterie Sans Mercure التحالف العالمي لطب أسنان خال من الزئبق Всемирный альянс за стоматологию без ртути Alianza Mundial por una Odontología Libre de Mercurio 世界无汞牙科联盟 World Alliance for Mercury-Free Dentistry The Honorable Erik Solheim, Executive Director UN Environment Nairobi Dear Executive Director Solheim: The World Alliance for Mercury-Free Dentistry deeply appreciates your 25 May meeting with Charlie Brown and Rachel Kamande, as well as with Desiree Narvaez and Hao Chen (and afterwards with Michiko Okumura) of UN Environment. At the end of that meeting you asked Charlie what you could do. After consulting with CSOs on every continent, here is our request for the single most effective step UN Environment can take to address Annex A-II of the Minamata Convention on Mercury. We ask that UN Environment join us to co-sponsor a global workshop on ending amalgam use for children. This recommendation comes from 73 CSOs (listed below), a majority of which are African and Asian. We CSOs come from 47 nations. Why focus on ending amalgam use in children? For five main reasons: 1. Children are particularly vulnerable to mercury: Children’s developing brains and neurological systems are especially susceptible to the neurotoxic effects of mercury. The Minamata Convention acknowledges that parties are “Aware of the health concerns, especially in developing countries, resulting from exposure to mercury of vulnerable populations, especially women, children, and, through them, future generations.” [i] Therefore, it is appropriate to focus on preventing both direct and indirect mercury exposures to this most vulnerable population. 2. Mercury-free alternatives are available for children’s teeth: It is widely accepted that mercury-free fillings are available for children’s teeth. The World Health Organization report Future Use of Materials for Dental Restoration explains, “Alternative restorative materials of sufficient quality are available for use in the deciduous [milk] dentition of children.”[ii] Between the irrelevancy of filling longevity in short-lived primary teeth[iii] and amalgam’s higher failure rates in such teeth,[iv] justification for amalgam for children no longer exists. In our experience, even many dentists who believe amalgam use may need to continue a little longer for adults agree that it should be stopped for children. 3. Ending amalgam use in children is a proven phase down step: Ending or restricting amalgam use in children has proven to be an important intermediate step in nations that have successfully phased down – or phased out – amalgam use. As described in the UN Environment brochure Lessons from Countries Phasing Down Dental Amalgam Use[v], Norway and Sweden “started with a recommendation against the use of amalgam for vulnerable populations such as children and pregnant women....Amalgam use in Danish children was restricted in 2003.... In the Netherlands, amalgam use has declined significantly in children and adults after it was discouraged in children....In Finland, national guidelines recommend that amalgam should not be used in pregnant women and children.”[vi] The entire European Union bans amalgam use for children under age 15 (effective 1 July 2018) and Mauritius has called on its dentists to stop amalgam use in children.[vii] 4. Many developing nations support this step and want guidance: Ending amalgam use for children is a phase down step that since 2012 has received strong support from people in developing nations – from the Africa Region’s landmark proposal during the INCs . . . to African CSOs’ Abuja Declaration for Mercury-Free Dentistry in Africa[viii] . . . to the NGO-led Dhaka Declaration for Mercury-Free Dentistry for Asia[ix] . . . to the Nigerian government’s new consumer brochure on amalgam. In the 21st century, many developing countries in Africa and Asia are leapfrogging past dead 20th century technologies such as landline telephones and branch banking – and they can do the same with amalgam. The workshop would provide guidance and experience-sharing that would help these nations protect their children, just as so many developing nations are protecting their own from this unnecessary source of mercury exposure. 5. This step will spur the private sector to transition to mercury-free fillings: Ending amalgam use in children will spur local manufacturers and suppliers in developing nations to shift to selling more mercury-free fillings to fulfill the new need. It will also discourage foreign manufacturers and suppliers from dumping their mercury products in developing nations – a contemptible environmental injustice. The major Indian business daily Financial Chronicle published an editorial by Satish Sinha of Toxics Link, “Let’s Get Rid of Mercury,” which calls for such a domestic industry to begin in India forthwith. Regarding logistics for such a workshop, we propose the following: • Location: Please consider Dhaka or Delhi as the location for this workshop. These Indian Subcontinent capital cities represent the largest consumer market in the world; both are home to grassroots movements advocating the transition to mercury-free dentistry and working to build local industry in mercury-free alternatives. An alternative is to have the conference at UN Environment’s headquarters in Nairobi. • Participants: We would invite governments, UN Environment and other international agencies, NGOs, dental school deans, practicing dentists, and dental material manufacturers. • Agenda: The workshop could feature speakers discussing, e.g., (a) mercury’s particularly devastating impact on children; (b) technical advantages of mercury-free alternatives for children; (c) case studies from countries that restricted amalgam in children; (d) case studies from government programs that ended amalgam use in children; (e) dental schools that promote mercury-free dentistry in children; (f) systems to provide mercury-free dentistry to low-income children; (g) steps to promote manufacturers selling mercury-free materials for use in children. We salute you for being the first minister to end amalgam use in a country. We look forward to continuing our long working relationship with our esteemed UN Environment colleagues to phase down amalgam use worldwide. 21 June 2017 Cordially yours, World Alliance for Mercury-Free Dentistry + 73 Civil Society Organizations with their leaders. cc—Chair of the Bureau, the Secretariat, Special Assistants to the Director, and UN Environment offices in Bangkok, Geneva, Nairobi, and Panama City; cc—Executive Committee of World Alliance Africa (26) Dominique Bally Kpokro, Centre Africain pour la Santé Environnementale (African-wide) Leslie Adogame, Sustainable Research and Action for Environmental Development (Nigeria) Dorah Swai, AGENDA for Environment and Responsible Development (Tanzania) Dr. Gilbert Kuepouo, Centre de Recherche et d'Education pour le Développement (Cameroun) Hemsing Hurrynag, Pesticide Action Network – Mauritius (Mauritius) Dr. Najoua Bouraoui, Association pour la Protection de l'Environnement et le Developpement Durable de Bizerte (Tunisia) Emmanuel Odjam-Akumatey, Ecological Restorations (Ghana) Griffins Ochieng, Centre for Environment Justice and Development (Kenya) Ndeye Maimouna Diene, Pesticide Action Network Africa (Senegal) Tom Aneni, Sustainable Environment Development Initiative (Nigeria) Adetonah Sounkoura, GAPROFFA (Benin) Semia Gharbi, Association de l'Education Environnementale pour les Futures Générations (Tunisia) Ibrahima Sory Sylla, Carbone Guinéé (Guinea) Nshimirima Jean Donatien , Propreté Environnement et Santé (Burundi) Moussa Hassan Ousseini, Jeunes Volontaires pour l'Environnement du Niger (Niger) Bernard Elia Kihiyo, Tanzania Consumer Advocacy Society (Tanzania) Amegadze Kokou Elorm, Les Amis de la Terre-Togo (Togo) Robert Tumwesigye Baganda, Pro-biodiversity Conservationists in Uganda (Uganda) Daniel Maina, Eco Ethics Kenya (Kenya) Solomon Kusi Ampofo, Friends of the Nation (Ghana) Dr. Tadesse Amera, Pesticide Action Network-Ethiopia (Ethiopia) Fatima Siddiki, Centre Optionnel pour la Promotion et la Régénération Economique et Sociale Secteur Afrique (Cameroun) Lucy Mulenkei, Indigenous Information Network (Kenya) Charles Baimey, Jeunes Volontaires pour l’Environnement-Côte d’Ivoire (Côte d’Ivoire) Dr Eugène Loubaki, Action sur l'Environnement et le Développement Congo (Congo-Brazzaville) Becha Hadley, Community Action for Nature Conservation (Kenya) Asia/Pacific (17) Siddika Sultana, Asian Center for Environmental Health (Asian-wide) Satish Sinha, Toxics Link (India) Gao Xiaoyi , All China Environment Federation (China) Dr. Eng. Naji Kodeih, IndyACT (Lebanon) Dr. Shahriar Hossain, Environment & Social Development Organisation (Bangladesh) Aileen Lucero, Ecowaste Coalition (Philippines) Dillip Pattanaik, National Alliance for Mercury Free Dentistry (India) Yuyun Ismawati, BaliFokus Foundation (Indonesia) Dr. Mahmood A. Khwaja , Sustainable Development Policy Institute (Pakistan) Ziyad Al-Alawneh, Land and Human to Advocate Progress (Jordan) Ram Charitra Sah, Center for Public Health and Environmental Development (Nepal) Dr Lillian Lasaten-Ebuen, IAOMT Philippines (Philippines) Lien To, Center for Community Health and Injury Prevention (Vietnam) Richard Gutierrez, BAN Toxics (Philippines) Eng. Marie Thérèse Merhej Seif, Human Environmental Association for Development (Lebanon) Sonia Mendoza, Mother Earth Foundation (Philippines) Juliet Pratt, Vice President Oceania-World Alliance for Mercury-free Dentistry (New Zealand) Europe (16) Genon Jensen, Health and Environment Alliance (European-wide) Johanna Hausmann, Women Engage for A Common Future (European-wide) Geoffrey Begon, Non au Mercure (France) Florian Schulze, Gesellschaft für Schwermetalltoxikologie (Germany) Francesca Romana Orlando, L’Associazione Malattie da Intossicazione Cronica e/o Ambientale (Italy) Hanna Schudy and Radosław Gawlik, EKO-UNIA (Poland) Graeme Munro-Hall, IAOMT-Europe (U.K.) Leticia Baselga, Ecologistas en Acción (Spain) Bruno van Peteghem, Association Toxicologie-Chimie de Paris (France) Dr. Bent Christiansen, Danish Society of Orthomolecular Medicine (Denmark) Dr. Elena Manvelyan, Armenian Women for Health and Healthy Environment (Armenia) Ann-Marie Lidmark, Tandvårdsskadeförbundet – The Swedish Association of Mercury Patients (Sweden) Susana Fonseca, ZERO - Associação Sistema Terrestre Sustentável (Portugal) Karolína Brabcová, Arnika - the Toxics and Waste Programme (Czech Republic) Cynthia Bagchi, Bedford Allergy Group (U.K.) Trine Jørgensen, Foreningen mod Skadeligt Dentalmateriale (Denmark) The Americas (11) María Isabel Cárcamo, Centro Latinoamericano de Salud Ambiental (Latin American-wide) Sylvia Dove, Consumers for Dental Choice (USA) Fernando Bejarano, Centro de Análisis y Acción en Tóxicos y sus Alternativas (México) Zuleica Nycz, TOXISPHERA-Environmental Health Association (Brazil) Michael Bender, Mercury Policy Project (USA) Mario Paredes, Alter Vida (Paraguay) Anna Tilman, Watershed Sentinel Educational Society (Canada) Hassan Sohn APROMAC-Environment Protection Association (Brazil) Sharon E. Lewis, Connecticut Coalition for Environmental Justice (USA) Darree Sicher, United Sludge Free Alliance (USA) Lidia Lucaski, AMAR-Environment Defense Association (Brazil) Indigenous Peoples Rochelle Diver, International Indian Treaty Council Worldwide Olga Speranskaya and Pamela Miller, Co-Chairs, IPEN Charlie Brown, World Alliance for Mercury-Free Dentistry References: [i] Minamata Convention on Mercury (2013), http://mercuryconvention.org/Portal... [ii] World Health Organization, FUT URE USE OF MATERIALS FOR DENTAL RESTORATION (2011),http://www.who.int/oral_health/publ..., p.35 [iii] BIO Intelligence Service (2012), Study on the potential for reducing mercury pollution from dental amalgam and batteries, Final report prepared for the European Commission-DG ENV, http://ec.europa.eu/environment/che..., p.69 (In 2012, the European Commission’s independent consultant elaborated that “With regard to young children, longevity of the restoration is not a relevant concern since baby teeth will fall out long before the restoration fails.”) [iv] Reinhard Hickel et al., Longevity of occlusally-stressed restorations in posterior primary teeth, AMERICAN JOURNAL OF DENTISTRY, Vol. 18, No. 3, June 2005, http://www.amjdent.com/Archive/2005... (Hickel et. al. found that amalgam has a mean annual failure rate of 7.6% in children’s primary teeth, meaning almost one amalgam filling in 12 fails in young children. This high 7.6% failure rates contrasts with 5.9% for composite and 3.3% for compomer, and with only 4.2% for resin-modified glass ionomer.) [v] http://www.zoinet.org/web/sites/def... [vi] UNEP, Lessons from Countries Phasing Down Dental Amalgam Use (2016), http://www.zoinet.org/web/sites/def..., p.21 [vii] Inventory of Mercury Releases in Mauritius (2014), http://health.govmu.org/English/Dep...).pdf, p. 19. [viii] https://mercuryfreedentistry.files.... [ix] http://cephed.org.np/pdf/31421052006.pdf
22/06/2017	Open letter to Nicolas Hulot, French Minister responsible for the environment The EDC-Free Europe coalition, which represents 70 civil society groups, write to the French Minister responsible for the environment to urge him to vote against weak EDC criteria. Dear Minister, We are writing to you on behalf of the EDC Free Europe coalition [1], which represents 70 civil society groups – trade unions, consumers, health professionals, cancer organisations, environmental groups and women’s groups – and promotes ambitious policy measures in order to reduce human and environmental exposure to endocrine disrupting chemicals. We are surprised and concerned to learn – through an article published in Le Monde [2] – that France could in the coming days vote in favour of the European Commission proposal for the elaboration of identification criteria for endocrine disruptors in the context of the EU regulation on pesticides. We call on you to reject this proposal in order to honour the electoral promises of Emmanuel Macron [3] and the ambitious approach that France has adopted so far in support of criteria that can be used in a practical and pragmatic way. We hereby acknowledge the remarkable work done by the French delegation at the European Chemicals Agency, which resulted in the long overdue recognition of Bisphenol A as a substance of very high concern for its endocrine disrupting properties for human health last week [4]. The difficulties to reach a consensus on the identification of this substance despite the significant level of scientific studies available about its negative effects is yet another illustration of the urgency to act towards swifter identification of endocrine disruptors. The proposal for the EU criteria currently on the table is insufficient, impracticable and most importantly not based on science [5]. Should it be adopted, it would require too high a burden of proof to be able to identify substances, while allowing an extremely worrying exemption for numerous pesticides that have an effect on the endocrine system. It would neither allow reducing citizens’ exposure, nor avoiding the resulting adverse health effects and their costs (which are estimated to amount to 163 billion euros a year [6]) – which would be in total contradiction to the commitments made at the European level through the 7th Environmental Action Plan in 2013 [7]. At a time when the European project is seriously being challenged, the elaboration of ambitious criteria represents a unique opportunity to demonstrate its added value and could create a worldwide precedent in order to really protect our health and that of future generations. 90% of French citizens are in favour of your government continuing and strengthening policies to fight against endocrine disruptors at the national and European levels [8]. This is why, in view of the meeting of the European pesticides committee scheduled for 4 July, we ask you to maintain the firm position that France has adopted so far and to reject the proposal currently on the table. It is still time to make a difference and France’s role on this issue is fundamental. Yours sincerely, Genon K. Jensen, Executive Director, Health and Environment Alliance (HEAL) François Veillerette, President, PAN Europe On behalf of the EDC-Free coalition Contact: François Veillerette, Director of Générations Futures and President of PAN Europe, francois@generations-futures.fr ; (+33)(0)6 81 64 65 58 This letter is also available in French. Notes: [1] http://www.edc-free-europe.org/about-us/ [2] Le Monde, Stéphane Foucart, Stéphane Horel, “Perturbateurs endocriniens: les scientifiques alertent sur le laxisme de Bruxelles”, 17 June 2017, http://mobile.lemonde.fr/planete/ar... [3] En Marche, presidential programme of Emmanuel Macron : « Nous fixons le cap de protéger les Français de leur exposition aux perturbateurs endocriniens, autres que les pesticides, nous interviendrons avec fermeté au niveau européen pour revoir totalement les méthodes d’évaluation des produits» ; https://en-marche.fr/emmanuel-macro... [4] https://www.anses.fr/fr/content/le-... ; http://env-health.org/resources/pre... [5] The Endocrine Society, The European Society of Endocrinology, The European Society for Paediatric Endocrinology, Lettre aux ministres européens de l’environnement, 15 juin 2017, http://bit.ly/2t914p5 [6] Léo Trasande and others, “Burden of Disease and Costs of Exposure to Endocrine-Disrupting Chemicals in the European Union: an updated analysis”, https://www.ncbi.nlm.nih.gov/pubmed... [7] Decision No 1386/2013/EU of the European Parliament and of the Council of 20 November 2013 on a General Union Environment Action Programme to 2020 ‘Living well, within the limits of our planet” [8] Opinion survey performed by IFOP, on behalf of Générations Futures, published on 21 June 2017. Available at www.generations-futures.fr
26/05/2017	Exclusion of coal investments through ETS funds and support establishment of Just Transition Fund Dear Environment Minister, Ahead of the upcoming trilogue meeting on the revision of EU’s Emission Trading System (ETS), the undersigned, representing 30 networks and organizations representing citizens from across Europe, would like to urge you to ensure that the funding mechanisms dedicated to help lower-income Member States transform their energy systems (article 10c and the Modernization Fund) are robust and well-designed to truly support the development of renewable energy and energy savings instead of subsidizing coal plants. If the EU wants its policies to be consistent with the long-term objectives of the Paris Agreement, it needs an ambitious ETS with a strong price signal. In addition, it cannot continue to subsidize coal power plants. We therefore call on you to support proposals that: 1. Exclude investments in coal power under Article 10c particularly through supporting a 450gCO2/kWh investment eligibility criterion. Article 10c is a transitional mechanism aimed at supporting the transformation and diversification of our energy systems. However, currently a vast majority of up to €12 billion investments through article 10c finance the expansion of fossil fuel capacity in Central and Eastern Europe (CEE), including hard coal and lignite. Allowing for these funds to continue subsidizing coal and lignite will have detrimental impacts on both the climate and public health. Furthermore, it will hinder the transition to an economy that is highly efficient and truly based on renewables. Article 10c should be used to shift more investments to energy efficiency and renewable energy sources. 2. Exclude investments in coal power and secure strong governance of the Modernisation Fund with a balanced role for all Member States (both beneficiary and non-beneficiary) as well as the European Investment Bank (EIB) in setting out investment guidelines for projects. Just as Article 10c, the Modernization Fund should not subsidize coal power in order to avoid dangerous lock in to coal for the coming decades. This can be accomplished by adopting either the 450 gCO2/KWh investment eligibility criterion proposed by the European Parliament or by maintaining the text included in the “general approach” agreed on February 28. Moreover, a the Modernisation Fund comes from a collective funding basis that represents European resources, it must be collectively managed. The European Investment Bank should have a decisive role in the selection of projects to benefit from the Fund. Day to day management must be in the hands of an independent management committee, with expertise on project development and finance. Strict monitoring tools should be put in place, and deterring penalties for countries manipulating the Fund should be foreseen. 3. Support establishing a Just Transition Fund Some low income communities and regions will need support to transition away from coal. It is therefore essential to establish a Just Transition Fund, in order to ensure that no one is left behind in the transition to a safe, clean and mutually prosperous Europe. We hope that you will show your support to the above ahead of the upcoming trilogue meeting. Yours Sincerely, Networks: 1. Climate Action Network Europe, representing 130 member organizations across Europe 2. Health and Environment Alliance (HEAL), representing 75 member organizations across Europe 3. European Environmental Bureau (EEB), representing 140 member organizations in European Union 4. CEE Bankwatch Network, representing 16 member organizations in Central and Eastern Europe 5. Bond Beter Leefmilieu, representing 160 member organizations, Belgium 6. Health Care Without Harm, representing 82 member organizations, Belgium 7. EKOenergy, representing 45 member organizations, Finland 8. Fundacja "Rozwoj TAK - Odkrywki NIE", representing 8 member organizations, Poland 9. Polish Green Network, representing 11 member organizations, Poland 10. Koalicja Klimatyczna, representing 22 member organizations, Poland Organizations: 11. CNCD-11.11.11, Belgium 12. Frank Bold, Czech Republic 13. E3G, European Union 14. Client Earth, European Union 15. Carbon Market Watch, Europe 16. WWF Greece 17. WWF Hungary 18. WWF Italy 19. Mouvement Ecologique (Friends of the Earth Luxembourg) , Luxembourg 20. NGO Green Home, Montenegro 21. Concerned Citizens against Climate Change, Netherlands 22. Stowarzyszenie Ekologiczne EKO-UNIA, Poland 23. Akcja Demokracja, Poland 24. WWF Poland 25. ZERO - Associação Sistema Terrestre Sustentável, Portugal 26. FUNDACIÓN RENOVABLES, Spain 27. WWF Spain 28. SEO/BirdLife, Spain 29. PUSH Sweden 30. Sandbag, UK
17/05/2017	Medical groups call for climate to be in G20 Health Ministers’ declaration
09/05/2017	Health and cancer groups want enquiry on Monsanto’s influence HEAL together with the Association of European Cancer Leagues (ECL) are asking members of the 'MEPs Against Cancer' group (MAC) to support the creation of an inquiry committee on Monsanto's actions in relation to the assessment of glyphosate. 9 May 2017, Brussels - The Health and Environment Alliance (HEAL) and the Association of European Cancer Leagues (ECL) has written to MEPs against Cancer to urge them to support the creation of an enquiry committee about the possible impact of Monsanto's action on EU scientific assessments. The letter can be read online here. For further information, please contact Natacha Cingotti, Policy Officer Health and Chemicals, Health and Environment Alliance (HEAL), email: natacha@env-health.org, phone: +32 (0)2 234 36 45
21/04/2017	HEAL and others seek positive stance on BREF for health
29/03/2017	Joint letter on the Type Approval Framework Regulation
24/03/2017	The Europe we want: Just, Sustainable, Democratic and Inclusive As we mark the 60th anniversary of the Treaty of Rome, we have a momentous opportunity to take stock of how far Europe has come. We call on European leaders to show leadership, vision and courage to set Europe on the path to a sustainable future. Common appeal to European leaders by European Civil Society Organisations and Trade Unions As we mark the 60th anniversary of the Treaty of Rome, we have a momentous opportunity to take stock of how far Europe has come – and how far we still have to go in order to offer a sustainable and prosperous future to everyone in Europe. It is an opportunity that we call on you, the leaders of Europe, to seize with both hands. We call on you to show leadership, vision and courage to set Europe on the path to a sustainable future which realises the rights of all people and respects planetary boundaries. We must not fail to appreciate how far Europe has come since 1957, when we were a handful of nations determined to emerge from the ashes of World War II and to move towards a peaceful and united common future. Today, the European Union is the largest and most successful peace initiative of our time, a place where Europeans find richness in cultural differences and strength in common values and aspirations, enjoying greater stability, safety and prosperity than in many other places in the world. But we cannot afford to be complacent: much still needs to be done to construct a sustainable world for current and future generations. While we have seen much progress, the promise of those early days has still not been fully achieved and we have entered an era in which the values at the very heart of Europe – democracy and participation, equality and social justice, solidarity and sustainability, respect for the rule of law and human rights – are being undermined. Citizens are questioning the raison d’être of the European Union, the legitimacy of governments and mainstream politics, and the ability of existing governance structures to respond to society’s most pressing challenges. As a result, trust in public institutions is in decline. In these uncertain times, European citizens seek a stronger focus on those core ‘European values’, not a reduced one. They seek economic, social and environmental well-being. Economic well-being in the form of prosperity for all and the redistribution of wealth. Social well-being in the provision of quality, affordable services for all and a reinforcing of the social fabric which binds us together. Environmental well-being residing in a healthy natural environment that sustains all life on Earth and protects our clean water and air. We therefore call on you, leaders of Europe, to move away from an economic model which has widened inequalities and rather to invest in a ‘social market economy’ that works for the benefit of all people. With poverty and social exclusion at unacceptably high levels, we must return to more inclusive economic policies which ensure that Europe’s prosperity is shared, without harming the planet. We call on you to uphold our core values and invest in employment and education based on critical thinking in order to defend our open, democratic societies and to address the sense of insecurity felt by many. We call on you, leaders of Europe, to ensure that gender equality, human rights, freedom of religion, democracy and the rule of law are fully implemented and upheld, both at EU and national level. We want to see a more hospitable Europe where everyone’s contribution is welcome and migration is recognised as a boon to society, not a drain. Europe also needs to play its part in tackling global challenges. Climate change in particular is an existential risk to our world and it must be tackled not only for environmental reasons, but also to prevent the escalation of conflict, hunger, and forced migration. Building on our call for ‘A New Europe for People, Planet and Prosperity for All’ (September 2016), we are seizing the opportunity of the 60th anniversary of the Treaty of Rome to reaffirm our belief in European integration and to offer concrete proposals for the EU Heads of State and Government as they consider the future of Europe. United, we call for: A Europe that promotes and protects the civil, political, social, economic and cultural rights of everyone and supports those beyond its borders to realise their rights; The delivery of the 2030 Agenda for Sustainable Development, by putting the Sustainable Development Goals and the principles that underpin it at the core of EU and national policy-making; The full implementation of the Paris Agreement by enhancing energy efficiency and accelerating the just and sustainable transition to clean and affordable renewable energy in order to keep global warming well below 2°C and pursuing efforts to keep it to 1.5°C; A strengthening of our representative and participatory democracy, with distinct space for people’s participation beyond elections, enabling a diverse civil society to flourish; A strengthening of education as a public responsibility that offers lifelong learning for all in order to develop active citizenship, critical thinking, social inclusion and an awareness of sustainable development and human rights; A just transition for workers and industrial regions from the current economic model to a modern, vibrant, green and socially just economy in which our human and natural capital is cherished; A European Social Model that provides full protection to all workers, all consumers and all people living in the EU; one that reverses the wealth gap and reduces poverty and social exclusion; A European Union with a strong social rights pillar, which ensures quality employment and fair pay, and addresses inequalities between women and men, discrimination against children and youth or based on race, sexual orientation, gender identity, socio-economic status, age, disability, minority or other status. In the face of a world that is changing faster than ever before, European unity and solidarity are just as important now as they were 60 years ago. Solidarity brought us together and solidarity is the only way forward. None of the current challenges can be solved by one nation or one group of people alone. However, there is an urgent need for the European Union and its institutions to reconnect with the realities, dreams and hopes of its citizens if the long-term relevance and survival of our Union are to be secured. Now is the time to rethink the direction in which we are travelling, build on our achievements and lay the foundations for the next 60 years of European integration. We expect you, as the leaders of Europe, to do just that: to have the courage and the vision to lead the transition to a just, sustainable, democratic and inclusive Europe. We expect you to listen to the people of Europe and to use the occasion of the Rome Summit to make a strong, joint commitment to a better, more sustainable future. Signatories: For all signatories, please click here. To read the letter in PDF format, please click here.
21/03/2017	16 Health and environment NGOs ask ECHA for a stricter implementation of REACH chemicals legislation
13/03/2017	Open letter on the independence and transparency of ECHA’s Risk Assessment Committee
14/02/2017	Call to implement Better Regulation principles in EU action on Endocrine Disrupting Chemicals Today, the EDC-Free Europe coalition and the Green 10 call on the First Vice-President of the European Commission to implement Better Regulation principles in EU action on Endocrine Disrupting Chemicals (EDCs). Brussels, 14 February 2017 To: Mr Frans Timmermans, European Commission First Vice-President Cc: Mr Vytenis Andriukaitis, European Commissioner for Health and Food Safety Subject: Call to implement Better Regulation principles in EU action on Endocrine Disrupting Chemicals We are contacting you about Better Regulation issues in the EU’s policy on Endocrine Disrupting Chemicals. First, we would like to express our appreciation to the European Commission for its stated commitment to “listen to the European Parliament, listen to all Member States, and listen to the people” (1). The harm caused by endocrine disrupting chemicals (“EDCs”) on EU citizens’ health and their environment is one of these “big problems” that the European Commission has been mandated to tackle as early as 1998 (2). However, although laws and policies adopted since then show the EU institutions have been trying to address EDCs, citizens continue to be concerned and scientists continue to sound the alarm (3) (4) (5) (6). The Commission’s proposals for criteria to identify EDCs, as required by the Pesticides and Biocides Regulations, are a necessary first step towards better protecting citizens and the environment from these harmful substances. However, because the proposals are currently at odds with the founding principles of Better Regulation, which aims at ensuring that the EU delivers high quality legislation, we bring the following concerns to your attention: (1) NOT EFFICIENT NOR COHERENT: The Commission is not adhering to existing EU political commitments for horizontal identification criteria enshrined in the Seventh Environment Action Programme (7), commitments which were recently reaffirmed by Council conclusions (8). Currently the proposed identification criteria are only designed to work specifically for and in the Pesticides and Biocides Regulations (see Annex). (2) NOT EFFECTIVE: The Commission proposal on derogation conditions changes the overall Risk Management balance between protection and competitiveness enshrined in the Pesticides Regulation for EDCs and thereby exceeds the Commission’s legal mandate: the Commission was required to adopt scientific criteria to identify EDCs, not to soften the conditions for approval of EDCs in pesticides (see Annex). (3) NOT BASED ON EVIDENCE: The Commission is using a misinterpretation of science to justify changing the overall Risk Management balance. The Commission’s justification to make a change to the derogation conditions for pesticides’ authorisation is actually based on a flawed selective reading of the EFSA Scientific Opinion (see Annex). (4) NOT COHERENT: The Commission’s criteria proposal is inconsistent with international practices in chemicals classification which jeopardises the adoption of harmonised criteria worldwide and thus creates further uncertainty for businesses and policy makers (see Annex). (5) NOT TRANSPARENT: There is insufficient transparency and openness in the recent amendments made to the initial proposed criteria text. Substantial changes in the identification criteria have been made that lack any publically available scientific reasoning or justification and make it a daunting task for stakeholders to follow the process and the impacts of such major changes (see Annex). As they stand now, the proposed criteria to identify EDCs are a perfect counter-example of Better Regulation. That is why, we call on you, as First Vice-President of the European Commission, in charge of coordinating the work on Better Regulation and the rule of law, and ensuring horizontal responsibility for sustainable development, to act to “break down silos” and adhere to existing EU political commitments (9). Your action within the Commission to ensure better EDC criteria can send a strong signal to European citizens about what Better Regulation can and ought to be on the big things that concern them, protecting people’s health and the environment from harmful chemicals. Yours sincerely, Genon K. Jensen, Health and Environment Alliance (HEAL) Executive Director on behalf of the EDC-Free Europe NGO coalition Jorgo Riss, Greenpeace European Unit Director on behalf of the Green 10 as current Chair EDC-Free Europe is a coalition of more than 70 environmental, health, women’s and consumer groups across Europe who share a concern about endocrine disrupting chemicals (EDCs) and their impact on our health and wildlife. The Green 10 are ten of the largest environmental organisations and networks active on the European level. They coordinate joint responses and recommendations to EU decision makers. Membership of the Green 10 alone is more than 20 million people. The complete letter, including the annex and footnotes, can be read online here.
13/02/2017	Open letter to Commission President: Improved EU decision-making in the area of health and consumer protection
08/02/2017	Open letter to Members of REACH Committee on D4D5, phthalates, and nanoforms
10/01/2017	Endocrine Disrupting Chemicals — One more way CETA endangers public health and the environment 35 Public interest organisations urge the European Parliament Environment Committee to vote in favour of their draft ENVI Committee opinion on the EU-Canada Comprehensive Economic and Trade Agreement (CETA) this Thursday. Endocrine Disrupting Chemicals — One more way CETA endangers public health and the environment Dear MEP La Via, Dear ENVI Committee Members, On behalf of 35 public interest organisations, we are writing to respectfully request that you vote in favour of the draft ENVI Committee opinion (1) on the EU-Canada Comprehensive Economic and Trade Agreement (CETA) on 12 January 2017 and to respectfully urge you to reject the draft Council decision on the conclusion of CETA in February 2017. The European Commission is already lowering EU standards of protection against dangerous endocrine disrupting chemicals (EDCs) (2), and has expressly acknowledged that its decision-making was influenced by ‘mounting’ pressure from EU trade partners (3). The entry into force of CETA will only make matters worse. There is a high likelihood that CETA would put the decision-making powers of the EU and its Member States in a straitjacket by prioritising trade interests over people’s health and the environment. Endocrine disruptors are harmful chemicals that have been linked to a wide range of diseases, including cancer, birth defects and other developmental disorders (4). They are conservatively estimated to cost Europeans more than € 160 billion each year in additional health expenses (5). Pursuant to its mandate, the European Commission is required to define criteria for the identification of EDCs. In this context, the European Commission has itself acknowledged an “aggressive and well orchestrated attack” by the U.S., Canada and other countries who consider this measure to be a trade barrier (6). How Canada is influencing EU EDC policy on trade grounds Through its regulations on pesticides and biocides, the European Parliament has mandated the EU to take a proactive and precautionary approach to protect European citizens from the harmful impacts of EDCs. For several years now, Canada has joined the US and other countries in trying to prevent the EU from taking that more protective approach. Since March 2015, Canada has argued against the EU approach to EDCs at every single meeting of the World Trade Organization’s Technical Barriers to Trade Committee (7). Moreover, the notes from a meeting (8) obtained through a freedom of information request reveal that in July 2016 a European Commission official acknowledged to Ambassadors from the US, Canada and other countries that the European Commission has no mandate to deviate from the ‘hazard approach’ enshrined in the pesticide and biocide regulations. Yet, contradicting this, the European Commission at the same meeting asserted that the revised proposal foresees the possibility to establish maximum residue levels, in an effort to “address the concerns” of the ambassadors. At the same time, the European Commission was asserting categorically to all other stakeholders that its proposals were in line with the high level of protection of human health and the environment mandated by the pesticide and biocide regulations. Indeed, the latest proposal on the EU pesticides legislation (9) (which has just been informally rejected for the third time in 6 months by the member state expert committees) lowers the level of protection applied to chemicals with endocrine disrupting properties (10). In particular, the European Commission is proposing an amendment to the annexes of the pesticide regulation that would allow the EU to set much higher maximum residue limits for endocrine disrupting pesticides. This change to the standard would be particularly welcome by transatlantic trading partners, which continue to disregard the large body of science showing that there is no safe level of exposure for these chemicals. As legal experts for the European Parliament confirmed last fall (11), however, the proposed amendment would exceed the European Commission’s powers and violate its mandate under the pesticides regulation. More fundamentally, yielding to US and Canadian pressures would result in the continued contamination of European food supplies with these dangerous substances, in violation of the European Commission’s duties to all EU citizens. How CETA would make this worse CETA chapters four (‘Technical Barriers to Trade’), five (‘Sanitary and Phytosanitary Measures’) and twenty-one (‘Regulatory Cooperation’) would extend the influence of Canada on the EU internal regulatory process and would directly affect areas such as EDCs, REACH and its implementation, pesticides and biocides rules. CETA would empower Canada and businesses based in Canada (such as Monsanto) to challenge such legislation in the EU and its Member States. Any provisional application of CETA would thus pose an immediate risk to health and environmental protection in Europe (12). This is in direct contradiction to point 2 (c) of the European Parliament’s Resolution on the EU-US trade and investment agreement (13), which called on the European Commission not to negotiate on issues “where the EU and the US have very different rules” and not to allow regulatory cooperation to affect future standards in such areas. In addition to disregarding this recommendation (14) by the European Parliament during the TTIP negotiations, the European Commission also failed to consider this recommendation in developing the parallel deal with Canada. As the European Parliament will soon vote on CETA, we strongly urge you to reject the draft Council decision on CETA, and to oppose any future EU agreement which fails to fully comply with the European Parliament’s recommendations or which endangers the high level of protection of human health and the environment afforded to and demanded by EU citizens. For additional information, please refer to: • James Crisp, EurActiv (December 2016) “New endocrine disruptor rules address your trade concerns, EU tells US, Canada” (English) (French) (German) • Stéphane Horel, Le Monde (November 2016) “Endocrine Disruptors: the interference of the United States” (English) (French) • EDC Free Europe (December 2016) “EU’s never-ending story on protective criteria to identify hormone disruptors continues” (English) Sincerely, Carroll Muffett, President and CEO, Center for International Environmental Law (CIEL) Génon K. Jensen, Executive Director, Health and Environment Alliance (HEAL) ON BEHALF OF: 1. Action for Breast Cancer Foundation (Malta) 2. Alliance for Cancer Prevention (UK) 3. Association on Environmental and Chronic Toxic Injury (Italy) 4. Breast Cancer UK 5. The Cancer Prevention and Education Society (UK) 6. CEE Bankwatch Network 7. Center for International Environmental Law 8. CHEM Trust 9. ClientEarth 10. The Danish Ecological Council (Det Økologiske Råd) 11. ECOCITY (Greece) 12. Ecologistas en Acción (Spain) 13. European Environmental Bureau 14. France Nature Environnement 15. Friends of the Earth Europe 16. Fundación Alborada (Spain) 17. GEmeinnützigen Netzwerks für UmweltKranke (Germany) 18. GMWatch 19. Green 10 20. Greenpeace 21. Health and Environment Alliance 22. Health and Environment Justice Support 23. Health Care Without Harm Europe 24. Institute for Sustainable Development - Inštitut za trajnostni razvoj (Slovenia) 25. International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations 26. Leefmilieu (Belgium) 27. Naturefriends International 28. Pesticide Action Network Europe 29. Pesticide Action Network – Italia 30. Pestizid Aktions-Netzwerk e.V. (PAN Germany) 31. Slow Food International 32. SumOfUs 33. Women Engage for a Common Future — WECF International 34. WWF European Policy Office 35. ZERO — Association for the Sustainability of the Earth System (Portugal) All references can be found in the PDF version of this letter.
15/12/2016	EDC-Free Europe urges Member States to reject Commission’s 3rd revised proposal on EDC criteria Brussels, 15 December 2016 – Today EDC-Free Europe sent a letter to EU Environment, Health and Agriculture ministers urging them to reject the 3rd revision which is to be discussed and possibly voted on in a meeting on December 21st. Update 16 December: the text of the pesticides proposals can now be found online here. To Health, Environment and Agricultural Ministers Dear Minister, The EDC-Free Europe NGO coalition urges your country to reject the European Commission’s 3rd revised proposal for identifying endocrine disrupting chemicals during the December 21st meeting of the Standing Committee of Food Animals Food and Feed. Although the revised version for pesticides has not been made public, we assume the identification criteria are the same as for biocides, whose texts have been released. We also understand that the proposal on the derogation remains the same – see point 1 below. We are very concerned that this 3rd proposal fails to protect citizen’s health or the environment for the following reasons: 1) Derogation change from `negligible exposure' to `negligible risk` The Commission claims legal authority to make the change from an article in the pesticides law that permits adjustments according to scientific advances. The scientific advance, which the Commission uses to justify the change to the risk-based approach is a key sentence in the 2013 scientific opinion from the European Food Safety Authority (EFSA). But recent newspaper investigations reveal that this key sentence was a pre-fabricated conclusion prior to the EFSA group even starting their work (For more details see the annex to this letter.) This news is deeply troubling and throws into serious doubt the scientific justification which underpins the Commission’s change to the derogation. 2) An excessively high burden of proof for identifying EDCs Under the identification criteria proposed, it will be extremely difficult to identify an endocrine disruptor for regulatory action before people or the environment have been harmed. This is also the conclusion of the world’s leading scientific society specializing in hormones, The Endocrine Society, when they evaluated the prior proposal. 3) A new exemption for certain endocrine-disrupting characteristics A new exemption has been introduced to excuse certain substances from identification (those with effects on moulting and/or growth), which could have wide ranging negative implications, in particular for wildlife. Firstly it contradicts the aim of the pesticides law to phase out use of endocrine disrupting pesticides and should therefore not be introduced as part of the identification criteria. Secondly, the identification criteria must be horizontally applicable, because they will have implications for the identification of EDCs under other laws. Exempting some Endocrine Disrupting characteristics from identification for purposes specific to the pesticides and biocides laws contradicts the commitment under the 7th Environmental Action Programme for horizontal criteria. In summary, we understand that this 3rd version continues to propose a risk-based derogation that is founded on a contrived scientific justification to introduce an illegal change in the previously democratically agreed legislative text; contains mostly cosmetic changes to the overly-stringent identification criteria; and introduces a new exemption which excuses a certain set of endocrine disrupting characteristics from identification. These proposals are unacceptable, and they do not respond to the growing public concern and mobilization for real action to reduce EDCs in our daily life. Over 220,000 EU citizens have signed an urgent petition to all European governments asking you to reject the EU Commission’s proposal. With kind regards on behalf of the EDC-Free Europe coalition, Genon K. Jensen Executive Director, Health & Environment Alliance (HEAL) In the view of the public interest in this matter we will make this letter available more widely. ANNEX New information on how DG Sante is using a pre-manufactured scientific conclusion for the risk based derogation, relies on industry funded studies and has been influenced by the US. In the first article of a three-part series published in Le Monde in French and in Environmental Health News in English, it is revealed that “the European Commission has developed its own evidence to avoid an overly stringent regulation” of EDCs. They have then used this to justify the change in the derogation from `negligible exposure` to `negligible risk` which illegally introduces new risk elements to the legislation. Part 1: Endocrine disruptors: The manufacture of a lie. The European Commission has developed its own evidence to avoid an overly stringent regulation of these hazardous substances. “a series of internal documents of the European administration obtained by Le Monde. They show, without ambiguity, that the key phrase on which the regulatory edifice proposed by the Commission is built had been drafted even before any scientific expertise had really begun.” Part 2: Endocrine disruptors: A denial of the state of the science. The European Commission relies on studies financed by industry. Part 3: Endocrine disruptors: The interference of the United States. Since 2013, the United States has been contesting by all means available the European regulation of these chemicals in the name of free trade. Euractiv reveals how Commissions’ proposal put private profit and trade concerns over public health Earlier this week, Euractiv’s article, “New endocrine disruptor rules address your trade concerns, EU tells US” illustrates how private profit and trade concerns are put above public health and democratically agreed laws. In July, the Health Commissioner met with EU trade partners about the Commission’s June draft proposal on the EDC criteria and assured them their proposals would use a different risk-evaluation method.
21/11/2016	HEAL supports open letter to European Parliament on EU ETS revision Open letter to Members of the Committee on Environment, Public Health and Food Safety of the European Parliament on the revision of the EU ETS Open letter to Members of the Committee on Environment, Public Health and Food Safety of the European Parliament on the revision of the EU ETS November 2016 Dear Members of the European Parliament’s Committee on Environment, Public Health and Food Safety, We, the undersigned, 31 organisations and networks working on a coal free Europe call on you to vote for a meaningful revision of the EU’s Emission Trading System (EU ETS) that supports the rapid decarbonisation of Europe’s energy systems and transition away from coal in line with the Paris agreement and the leadership role EU is aspiring to play in global climate policy. The EU ETS can accelerate this transition through a meaningful carbon price and its funding mechanisms. The ENVI vote is a key opportunity to support the ETS that builds a fair, inclusive and just transition from coal towards a low-carbon economy. We urge you to adopt amendments that: 1. Deliver a meaningful carbon price to phase out fossil fuels. The current carbon price of around EUR 6 is much too low to promote investments in clean, carbon-free technologies. On the contrary, proposed ETS rules will continue to support coal infrastructure. The ETS cap must therefore be tightened (e.g. by adopting a higher linear reduction factor, re-basing the starting point and cancelling surplus) to deliver a carbon price which would catalyse swift transition away from coal towards renewables. 2. Guarantee that EU ETS funding mechanisms for lower-income Member States to transform their energy systems are well-designed to support and not hinder the decarbonization in these countries. Accordingly, the EU ETS must: Reroute funding under Article 10c of the EU ETS Directive to the Modernisation Fund Article 10c has been largely misused to subsidise existing and new coal power plants in Central and Eastern Europe. Continuing free allocation could distort the internal energy market and endanger the climate friendly transition in the region. The Article 10c derogation should not be expanded beyond 2020. Instead, it should be folded into the Modernization Fund, which can deliver more investment in the region. By combining resources, Member States can avoid the administrative burden and complexity of implementing two programmes with overlapping objectives and benefit from less fragmentation and more effective use of public resources. Provide strong investment criteria that exclude coal New or existing coal generation (incl. coal-powered CHP) must be ineligible for funding under the Modernisation Fund. Strict Emission Performance Standard criteria for projects eligible for funding must be adopted, to shift investments to sustainable renewable energy, energy saving technologies and upgrade of electricity grid infrastructure. Investments under the Fund must be additional and more ambitious, e.g. to those needed to comply with Best Available Techniques (BAT) standards. Provide strong governance of the Modernisation Fund that includes non-beneficiary Member States. Resources for the Modernisation Fund come from a collective funding basis that represents European resources. Therefore, the investment board must include an equal number of non-beneficiary and beneficiary Member States, to ensure credibility of supported investments. 3. Support the establishment of the Just Transition Fund Some communities and regions will need support to transition away from coal. It is therefore essential to uphold the position of Committee on Industry, Research and Energy (ITRE) and support a Just Transition Fund, to ensure that no one is left behind in the transition to a safe, clean and mutually prosperous Europe and world. We hope that you will be able to support these points in the upcoming ENVI vote on the EU ETS revision on 8 December. Read letter online here. List of organisations: Networks: Bond Beter Leefmilieu, representing over 125 organisations in Flanders, Belgium European Environmental Bureau (EEB), representing over 150 member organisations in more than 30 countries Climate Action Network (CAN) Europe, representing 130 organizations in more than 30 European countries CNCD-11.11.11, representing 90 NGOs, trade unions and associations Polish Green Network, representing 10 Polish organizations Transport and Environment, representing 50 organisations across Europe Health and Environment Alliance (HEAL), representing 75 member organisations across Europe Organisations: Association 2Celsius, Romania Both ENDS, Netherlands Bund für Umwelt und Naturschutz (BUND) Landesverband Sachsen e.V., Germany Carbon Market Watch, Belgium Center for Environment, Bosnia and Herzegovina Concerned Citizens against Climate Change, Netherlands Eco Dobrogea, Romania Ekotim – Society for protection and advancement of nature environment and health, Bosnia and Herzegovina Frank Bold Society, EU Foundation “Development YES – Open-Pit Mines NO”, Poland Germanwatch, Germany Green Budget Germany – Forum Ökologisch-Soziale Marktwirtschaft, Germany Iceland Nature Conservation Association, Iceland MANS, Montenegro Mouvement Ecologique, Luxembourg NGO Green Home, Montenegro Polski Klub Ekologiczny Okręg Mazowiecki, Poland SEE Change Net, Western Balkans Society for the Earth, Poland Stowarzyszenie Ekologiczne EKO-UNIA, Poland Towarzystwo dla Natury i Człowieka, Poland ZERO – Association for the Sustainability of the Earth System, Portugal WWF European Policy Office, Belgium WWF Hungary, Hungary WWF Greece, Greece Za Zemiata, Bulgaria
14/11/2016	EDC-Free Europe letter to EU Ministers on revised EDC criteria Monday 14th of November 2016 To: Health, Environment and Agriculture Ministers Dear Minister, Ahead of the discussions on the criteria for endocrine disrupting chemicals in the Standing Committee of Food Animals Food and Feed on 18.11.2016 under the Pesticides 1107/2009 and Biocides 528/2012 Regulations, we would to like to share our concerns regarding the revised draft Commission proposal. The EDC-Free Europe coalition opposes this revised proposal because the text still demands too high a burden of proof, fails to address the requirements of the Pesticide and Biocide Laws and is hence also unfit to apply to other EU regulations. The criteria will still fail to protect EU citizens and the environment the way the law intends. Our two main concerns we would urge you to address: 1) The revised proposal continues to impose an unreasonably high burden of proof to identify EDCs. Although there have been some useful clarifications, the criteria are very difficult to fulfil because of the requirement to prove a consequential link between the adverse effect and the endocrine mode of action. In addition, the draft does not include categories in order to reflect the different levels of scientific evidence available, in spite of the fact that both EU Biocides and Pesticides Laws require the identification of EDCs that `may` cause adverse effects (i.e. suspected/potential EDCs). 2) The revised proposal still keeps the amendments to the Annex of the Plant Protection Product Regulation that alter in a fundamental way the risk management choice agreed by Council, Parliament and Commission in the co-decision procedure. The change in the derogation from `negligible exposure` to `negligible risk` introduces new risk elements to the legislation. By this change, the Commission widens an existing limited exemption into a major loophole that can easily be exploited to enable continued use of identified EDCs. This would allow endocrine disrupting pesticides to be authorised for widespread use. Europeans and the environment will remain unprotected for the harmful effects of EDCs. The EDC criteria are expected to have wide ranging implications for all EU chemicals laws and therefore the proposal needs to be changed to ensure coherence and to protect human health and the environment. We therefore call on you to oppose the revised Commission proposal and ensure the EDC criteria will provide a high level of protection, are in line with the European law and can be applied across all Regulations pertaining to chemicals. Your decision will be a critical contribution in the urgent efforts to prevent endocrine-related diseases for Europeans and averting damage from our ecosystems. With kind regards on behalf of EDC-Free Europe coalition, Francois Veillerette President of Pesticide Action Network (PAN) Europe Genon Jensen Executive Director, Health & Environment Alliance (HEAL) Letter available to download here
21/10/2016	It is now time to Phase Out Dental Amalgam Use in the European Union
08/09/2016	NGOs express support for restriction of chemical PFOA to REACH Committee
30/08/2016	Leading environmental NGOs urge top EU decision-makers to prioritize people’s health and the environment during Bratislava Informal Summit The Green10, a group of leading environmental NGOs active at the EU level, share their priorities for the EU’s future with EU-28 leaders ahead of an informal summit where the way forward following the UK’s vote to leave the EU will be discussed. Brussels, 30th August 2016 Dear President Tusk, President Juncker, President Schulz and Prime Minister Fico, In a few weeks EU-27 leaders will gather in Bratislava for an informal summit to discuss the way forward following the UK’s vote to leave the EU. With this letter we would like to share with you the Green 10 priorities for this debate and the direction we believe the EU should now take. In our previous letter reacting to the UK referendum vote, we had set out our view that the EU needs to now embark on an agenda of transformational change, one that puts the health and interests of people and planet first in everything that it does, guided by the global 2030 Agenda for Sustainable Development and the Paris climate deal. In order to achieve this, we now need an overarching EU implementation strategy for the 2030 Agenda, based on the 17 goals, targets and indicators, and developed in an open and participatory process. The EU is at a crossroads. It can either continue on the current path of deregulation and ‘less Europe’ – a path which has clearly failed to convince citizens both in the UK and across the Union – or it can embark on something new, answering to the needs and aspirations of European citizens. On this new path, instead of focussing on promoting globalisation, the EU would direct its efforts towards managing its impacts on our planet and ensuring that all its citizens can live a good life, well within the planetary boundaries. Successive opinion polls have shown that the environment consistently ranks high among the public’s concerns and that there is broad support for more action on the environment at EU level (1). The UK referendum result should thus give added impetus for the EU to increase its efforts to address environmental challenges. Moving in the direction of ‘less Europe’ and returning powers to national governments as some have advocated, if applied in the area of environmental policy, could actually undermine one of the EU’s recognised success stories. Tackling the global challenges of climate change, the depletion of natural resources, the collapse of ecosystems and disappearance of wildlife and the protection of people’s health is best done together, rather than in isolation. Policies to tackle these challenges must be guided by a long-term view of sustainability rather than serving short-term interests through the setting of cost- reduction targets or by making the elimination of trade barriers an overriding interest. Secondly, the EU needs to remember the fundamental rights and the rule of law it was founded on. Legislation to protect workers, citizens and the environment has drastically improved the standards of living in Europe, and this ‘safety net’ needs to be strengthened, not weakened. Moreover, if the EU fails to act collectively on issues such as the environment through the adoption and enforcement of legislation, Member States will act individually leading to a patchwork of national rules and regulations suited neither for common market nor pan-European environmental challenges. Thirdly, in a number of policy areas, important decisions are forthcoming which represent an opportunity to demonstrate the political will to take on board the lessons learned from the UK referendum: - As regards a pending decision on whether or not to ratify the CETA trade agreement with Canada and whether this should apply provisionally or not, EU leaders need to show that they are listening to the record number of EU citizens who expressed their opposition to this. Similarly, the EU needs to discontinue negotiations with the US on TTIP, unless an entirely different approach is taken. - The forthcoming review of the EU budget enables you to present a new budget that truly reflects a political re-orientation towards sustainable development. Central to such a new budget of results should be a deep and rigorous overhaul of one of the EU’s oldest and most controversial policies, the Common Agricultural Policy, starting by submitting it to a Fitness Check. - EU leaders further need to demonstrate a willingness to increase ambitions when it comes to solving climate change through a new more ambitious set of greenhouse gas, renewable energy and energy saving targets for 2030, underpinned by a solid, legally enforceable system of governance. Finally as regards the future relationship with the UK, the EU must insist on the full respect for and participation in the EU’s environmental acquis, both existing and future, as a condition for full access to the single market. Yours sincerely, Magda Stoczkiewicz Director, Friends of the Earth Europe On behalf of the Green 10 EU Directors: Angelo Caserta, Regional Director- BirdLife Europe Mark Fodor, Executive Director – CEE Bankwatch Network Wendel Trio, Director – Climate Action Network Europe Jeremy Wates, Secretary General – European Environmental Bureau Magda Stoczkiewicz, Director – Friends of the Earth Europe Jorgo Riss, Director – Greenpeace European Unit Genon K. Jensen, Executive Director – Health & Environment Alliance Andrea Lichtenecker, Executive Director- Naturefriends International Jos Dings, Director - European Federation for Transport and Environment (T&E) Geneviève Pons-Deladrière, Director - WWF European Policy Office Resources: (1) A Eurobarometer report published on 1 July 2016 showed that 67% of those canvassed want to see more action at EU level on the environment.
07/07/2016	European Commission crosses Parliament’s red lines on TTIP, say over 65 organisations in open letter
01/07/2016	Green10 Letter State of the European Union after Brexit: time for a new direction Dear President Juncker, President Schulz, President Tusk, Prime Minister Rutte, Like many committed to the vision of a strong well-integrated Europe, we have been shocked and saddened by the fact that 52% of UK voters who turned out to vote in the recent referendum expressed the wish for their country to leave the European Union. This is a significant blow not just for the EU but more importantly for the values that it represents: openness, inclusiveness, tolerance, respect and commitment to sustainability. In the coming days, weeks and months, a debate will take place on the most important question facing the EU: how do we live up to these values and ensure that the policies, structures and institutions that were created to uphold them can do so effectively in the face of fear, alienation and misinformation? As ten of the leading environmental networks active at European level, with a collective membership of over 20 million citizens, of whom a significant number live in the UK, we will certainly need to become better in making the case for the values and benefits EU policies have brought for its citizens’ health and wellbeing. This includes cleaner air, water and beaches, thriving wildlife, safer substances and green energy, to name but a few. These benefits should be communicated loud and clear and all the time, not only in the face of an imminent UK departure from the Union. At the same time, the EU needs to now embark on an agenda of transformational change, one that puts the interests of people and planet first in everything that it does, guided by the global 2030 Agenda for Sustainable Development and the Paris climate deal. Such an inspirational and transformational agenda should be given shape through a change in political emphasis and direction, supported by improved accountability of the EU institutions. That the EU’s current focus on less regulation has failed to turn “leavers” into “remainers” should not come as a surprise. It was never clear why there should be fewer rules, and for whom. The desire to deregulate originates from vested interests, exactly those entities that have gained most from the EU’s internal market and many of whom never wanted a Brexit in the first place. Now more than ever, it is crucial for the EU to show it is united, not paralysed, and remains willing and able to act for the benefit of its citizens and their natural environment. The EU remains uniquely placed to lead in tackling the global challenges of climate change, the depletion of natural resources, the collapse of ecosystems and disappearance of wildlife. It is capable of solving an environmental and health crisis by adopting and enforcing ambitious policies that can save and improve the lives of millions, within Europe and beyond. We welcome your willingness to engage in a new reflection on the future direction of Europe starting this week and stand ready to play our part in contributing to the discussion in the months ahead. Yours sincerely, Jeremy Wates EEB Secretary General and current Chair of the Green 10 On behalf of Green10 Directors: Angelo Caserta Regional Director – Birdlife Europe Wendel Trio Director – Climate Action Network (CAN) Europe Mark Fodor Executive Director – CEE Bankwatch Network Jeremy Wates Secretary General – European Environmental Bureau Magda Stoczkiewicz Director – Friends of the Earth Europe Jorgo Riss Director – Greenpeace European Unit Genon K. Jensen Executive Director - Health and Environment Alliance (HEAL) Andrea Lichtenecker Executive Director - Naturefriends International Jos Dings Director – European Federation for Transport and Environment (T&E) Geneviève Pons-Deladrière Director – WWF European Policy Office
20/06/2016	Need for increased engagement with the Western Balkans on their pathway to low-carbon transformation In the run up to the Energy Community Civil Society Day on June 21, HEAL and CAN Europe urge the EU Energy Union Commissioner to ensure that the European Commission sends strong messages about the urgent need to move towards low-carbon transformation. Brussels, 17 June 2016 Dear Vice-President Šefčovič, In the run up to the Energy Community Civil Society Day on June 21, the Permanent High Level Group meeting on June 22 as well as the Western Balkans 6 Summit in Paris on 4 July, Health and Environment Alliance (HEAL) and Climate Action Network (CAN) Europe are contacting you to ensure that the European Commission sends strong messages to the region about the urgent need to move towards low-carbon transformation, which will bring many benefits, including to people’s health not only in the region but the whole of Europe. Unfortunately, we see little being done by the Western Balkan countries to comply with the existing obligations under the Energy Community Treaty, such as meeting renewables and energy efficiency targets. Furthermore, it is worrisome that several governments have emphasised they have no alternative to coal for power generation during the last gathering in May of representatives of Western Balkan Governments and Ministries of Energy. In March 2016, HEAL published a new assessment that showed that existing coal power plants in the Western Balkans cause up to 8.5 billion EUR in health costs annually (due to air pollution), not only to the people in the region but also all across the EU Member States. It was disappointing to see that particularly the Serbian government questioned the evidence-base of the report, instead of initiating an open and comprehensive debate of the true costs of coal power and other fossil fuel generation. We consider this another example of the unwillingness of policy-makers in the region to prioritise low-carbon transformation. As the countries move forward with the implementation of the Energy Community legislation, the Paris Agreement and continue the EU accession talk, we consider your role and that of the EU Commission crucial to encourage and see through low-carbon transformation in the region. We therefore invite you to highlight, in your exchange with the Western Balkan countries, that health and climate benefits of the implementation of the EU Directives and low-carbon energy strategies surpass the costs of low-carbon transformation. As a first specific step, we hope that you, along with Commissioner Arias Cañete and colleagues from DG CLIMA, will ensure that the Energy Community gets it first climate acquis adopted this year, which will be essential to facilitate transition in the Western Balkans countries. In view of the public interest of this matter we intend to make the letter more widely known. We thank you for considering the issue and remain, Anne Stauffer, Deputy Director Health and Environment Alliance (HEAL) Wendel Trio, Director Climate Action Network (CAN) Europe
17/06/2016	EDC-Free Coalition asks Environment Ministers to say NO to hormone disruptors Ahead of the June Environment Council, the EDC-Free Europe Coalition to say NO to hormone disrupting chemicals. 17 June 2016, Brussels Dear Environment Minister, Ahead of the June Environment Council, we are writing to you on behalf of EDC-Free Europe, a coalition representing over 70 organisations who have come together because of our concern about endocrine disrupting chemicals (EDCs). The EDC-Free Europe coalition strongly condemns the Commission proposal for criteria to identify endocrine disrupting chemicals (EDCs) presented on June 15th. It will fail to protect wildlife and to address this urgent public health threat. We have reason for concern – over 1,300 studies have linked EDC exposure to serious health problems including infertility, diabetes, obesity, hormone-related cancers and neurological disorders. We see two major problems with the proposals which we ask you to rectify: 1) The Commission proposes to identify EDCs only if they have been proven to cause adverse effects in humans or non-target organisms. Requiring this unprecedentedly high level of proof means that humans and the environment will most likely have to be harmed before action is taken. This level of proof is incoherent with the usual approach taken in the EU for e.g. identifying carcinogens which uses both the wording `known` (CLP cat 1 A) and `presumed` (CLP cat 1B). The proposal will have wide ranging implications for all EU chemicals laws and therefore needs to be changed in order to ensure coherence, and to protect wildlife and people. 2) The Commission proposes amendments to the Plant Protection Product Regulation that alter the agreement taken between Council, European Parliament and Commission in the co-decision procedure. They propose changing the legal text from endocrine disruptors that “may cause adverse effect” to endocrine disruptors “known to cause an adverse effect”. Furthermore, the Commission goes beyond their task on identification criteria and actually reintroduces new specific risk assessments for all EDC pesticides, which changes the balance and approach agreed between Council and Parliament. They propose widening an existing exemption into a major loophole for those cases where chemicals have been identified as EDCs (changing `negligible exposure’ to ‘negligible risk´). This would allow continued uncontrolled exposure to these chemicals of high concern. We therefore call on you to use the opportunity at the Environment Council meeting on Monday, 20th of June, to insist on major changes. Thank you very much for ensuring a high level of protection for human health and the environment, preventing endocrine-related diseases for Europeans and averting damage from our ecosystems. In the view of the public interest in this matter we will make this letter available more widely. Translations of this letter are available in English, Spanish, and French.
16/06/2016	CAN Europe and HEAL urge EU Climate Commissioner on climate action in Western Balkans Dear Commissioner Arias Cañete, Climate Action Network (CAN) Europe and Health and Environment Alliance (HEAL) are contacting you regarding the need to ensure appropriate climate action and implementation of the Paris Agreement in the Western Balkans, which will bring many benefits, including to people’s health in the region and beyond. The countries of the Western Balkans are on the road towards joining the EU before 2030 while unfortunately their climate and energy policies are moving away from the necessary low-carbon transformation. This is evident from both their INDCs aand their energy strategies which include an increased use of coal and limited support for renewables and efficiency. We are concerned that the continued reliance on coal power would not only undercut the necessary climate mitigation efforts, but also cause significant health costs to the people in the region and the whole of the EU. A recent report by HEAL demonstrates that coal power plants in the Western Balkans region cause up to 8.5 billion EUR in health costs annually from air pollution. The INDCs of Western Balkans countries largely envisage an actual increase of emissions compared to today. Many of them are also limited in scope, as countries struggle with greenhouse gas accounting. GHG inventories are being made under UNFCCC reporting system, whereas emission data from land-use, land use change and forestry (LULUCF) are still largely missing. Given the state of play on GHG accounting, it will be increasingly difficult for these countries to implement the Paris Agreement but also to move forward with the EU accession talks on climate and energy. DG CLIMA has already recognised this need, and moved forward with an idea to have the Monitoring Mechanism Regulation (MMR) adopted and implemented through the Energy Community Treaty. This is an effective way to ensure that the whole region moves at the same pace. Without MMR in place, it will not be possible for these countries to improve their current INDCs. Moreover, without MMR, these countries will not be able to join the EU ETS nor have grounds for a level playing field in an integrated energy market with the EU. It is both in the EU's interest and responsibility to ensure that these potentially future member states start acting on climate immediately. Therefore we invite you to ensure that this file moves forward urgently, so that the MMR is adopted at the Energy Community Ministerial Council in Sarajevo on 14 October 2016. In view of the public interest of this matter we intend to make the letter more widely known.
10/06/2016	31 NGOs ask EU President Juncker to phase out glyphosate
08/06/2016	EDC-Free letter to President Juncker to act now on EDCs In a letter sent today, the EDC-Free Coalition asks the EU Commission President Juncker to protect our health from endocrine disrupting chemicals, also known as EDCs. 8 June 2016 Dear President Juncker, On 15 June, you and the EU College of Commissioners will be taking a major decision on the criteria to identify Endocrine Disrupting Chemicals (EDCs). We write to you about this decision as representatives of society, and members of 70 organisations from the EDC-Free Europe coalition across the EU and beyond. Our public interest groups include public health and cancer prevention advocates, health care professionals, consumers, farmers, and environment and health organisations. We are expecting from you and your colleagues that: 1. The EU Commission will uphold its obligations under specific EU laws and under the Treaty on the Functioning of the EU; 2. The EU Commission will take up the best available scientific evidence, and; 3. The EU Commission will think and act effectively to move the EU into a more dynamic, innovative, healthy and environmentally sustainable industrial and agricultural future. a) Will the EU Commission uphold its obligations under the TFEU and under 1107/2009 and 528/2012? The obligation of the EU Commission is to now decide on scientific criteria by which endocrine disrupting properties can be IDENTIFIED. This means any potential text changes beyond pure identification, such as potency or ‘hazard characterisation’ (see below), would change the balance which the law strikes between protection of human/animal health/environment and the internal market and would be unacceptable and illegal, as per the EU court of justice ruling in December 2015. b) Will the EU Commission acknowledge and incorporate the best science in its decision and in the criteria? The simplest and most robust reflection of the available scientific data is captured with the World Health Organization (WHO) definition and three categories (Option 3 of the Commission Criteria Roadmap). This importantly ensures coherence with other EU laws, such as the CLP Regulation, and allows the most effective decision making on how to convey the total weight of scientific evidence. In contrast, option 4 of the Roadmap or variations thereof use potency, or how much of a chemical is needed to create an effect, to identify EDCs. Potency will not work for EDCs which affect multiple systems within the body, and also can affect wildlife. Potency, which is addressed in ‘hazard characterisation’ is distinct from and not relevant to EDC identification. Consistent with the various scientific reports that the EU Commission has obtained since 2011 from contracted scientists (Kortenkamp et al), the JRC, and EFSA, the most recent papers are categorical that potency is not relevant to EDC identification: see the Consensus Statement from the April 2016 Berlin meeting hosted by the German government, which was hailed as a ‘breakthrough’, and a paper published by Slama et al in a leading Environmental Health journal (1). c) Will the EU Commission effectively move us to a dynamic industrial and agricultural future by enabling innovation in safer chemicals? The EU pesticides and biocides laws of 2009 and 2012 complement and build on the transition that the REACH chemicals management system is developing towards safer chemicals. The EDC identification criteria are therefore a coherent part of creating the conditions for innovation of safer chemicals, for synergising the potential of these laws, and for consolidating opportunities to expand advances into other product sectors. The pesticides and biocides laws set out strict controls for EDCs and chemicals that cause cancer, change DNA and harm reproduction. But these laws still allow continued use if needed when there are no safer alternatives, so claims of major agricultural and economic disruption must be treated with caution. At the same time, the societal impacts of health problems arising from EDCs are typically underestimated. Scientific studies show that these chemicals are very likely contributing to the increases in hormone-related diseases such as breast or testicular cancer, fertility problems, diabetes and obesity as well as learning and behavioural problems in children. In addition to the suffering of individuals and their families, these life threatening diseases come with a cost to Europe’s health systems and worker productivity, estimated in the billions annually for just a few of Endocrine Disrupting Chemicals assessed. A recent study on the “Health costs that may be associated with Endocrine Disrupting Chemicals” found that when looking at only five potentially EDC-health related effects “according to currently available literature, the socio-economic burden … for the EU may be substantial, ranging between 46 – 288 billion EUR per year” (2). We therefore look to you to instill confidence in European citizens by upholding the treaty and laws and to choose a path which triggers innovation and protects health at the same time. Moving us to an environmentally sustainable, healthy, and economically vigorous future requires taking effective steps: choosing the right EDC identification criteria is one of those, and will substantially contribute to the goal of the EU’s 7th Environmental Action Programme to minimise exposure to EDCs. In view of the public interest in this matter we will make this letter publicly available. Sincerely, Genon K. Jensen, Executive Director, Health and Environment Alliance (HEAL) On behalf of the EDC-Free Europe coalition
02/06/2016	Open letter to German health minister on health co-benefits of climate action HEAL recently sent an open letter to the German Health Minister Hermann Groehe highlighting the opportunity for disease prevention from Germany’s Climate Action Plan 2050 which is currently in consultation between ministries. With the support of two medical student organisations and 30 individuals from the health professionals and scientific communities, HEAL sent a letter of support on the German Climate Action Plan 2050. The plan, which has been drafted by the German ministry of the environment, involving a long consultation process with a large number of stakeholders, sets out targets, trajectories, strategies and measures to reach Germany’s climate target of 80 to 95 perecent reduction in greenhouse gas emissions until 2050. Public health can benefit from the proposed actions as several environmental and behavioural risk factors will be touched by these. The reduction of fossil fuel use will improve air quality and thus reduce cardiopulmonary disease and mortality. More active means of transport such as walking and cycling will increase the rates of physical activity, while noise emissions from traffic can be reduced. This therefore generates huge benefits for cardiovascular health and several other positive health impacts. Climate friendly diets can reduce the burden of chronic diseases while the lower rates of meat consumption mean fewer greenhouse gas emissions. Resources: The German version of this letter can be downloaded from here. Further information on the Climate Action Plan 2050 can be found here. HEAL’s briefing on climate mitigation as a strategy for disease prevention
26/05/2016	Call to European Parliament to phase out dental amalgam
13/05/2016	Non-REACH Chemicals REFIT process fails to comply with Better Regulation guidelines A coalition of ten health and environmental NGOs express their deep concern with the way the European Commission is carrying out a Fitness Check of non-REACH chemicals legislation in an open letter to various EU Commissioners. 12 May 2016, Brussels Dear Mr Timmermans, Ms Bieńkowska and Mr Vella, The undersigned organisations would like to express our deep concern with the way the European Commission is carrying out a Fitness Check of non-REACH chemicals legislation. The Commission’s Better Regulation Guidelines (1) establish that Roadmaps are a mandatory requirement for REFITs. The Guidelines state that these should summarise the design purpose and scope of the exercise to allow stakeholders to comment and that these documents require political validation from the lead Commissioner, Vice-President and First Vice President. In the case of the non-REACH chemicals REFIT, no such roadmap has been published. Yet the responsible Directorate General of the Commission, DG Growth, is nevertheless running a consultation exercise on the basis of a background document that is not approved by the Commission before this mandatory step is carried out. The aim of the Non-REACH Chemicals REFIT, as stated in a background document (2) from the Commission, is to ascertain whether the European Union chemicals acquis still meets its primary aims, namely to offer European citizens and the environment a high level of protection and to ensure that the EU internal market in chemicals functions well, thereby stimulating innovation and competitiveness. This may well be the widest REFIT exercise carried out until now, covering over a hundred pieces of law, and may have significant consequences. It is therefore even more important to ensure that the process follows the established requirements, is transparent and sound, and leads to reliable results. However, during the consultation workshop organised by consultants on behalf of DG Growth on 19 April 2016 to gather stakeholder input to a key study on the Regulation on classification, labelling and packaging of substances and mixtures (CLP Regulation) and related legislation commissioned under this REFIT exercise, Commission representatives stated that no stakeholder consultation was foreseen for the overall roadmap. They also stated that the scope and planned activities of the Chemicals REFIT were those already included in the background document, which were agreed after a consultation with only a limited number of unknown stakeholders. Equally worrying is the fact that no activity is foreseen as part of this exercise to seek to gather evidence on how European citizens and the environment are benefiting from the European Union chemicals acquis. The public consultation that has been launched is directed at only a limited number of stakeholders. It fails to include the scientific and healthcare community that could provide evidence on the environmental and health benefits of chemicals legislation. It addresses only the chemical industry, there seems to be no plan to send questionnaires to downstream users apart from a few sectors such as detergents, and there is no intention to gather any information on the benefits of chemicals legislation for industry. Such an approach suggests that rather than making a balanced assessment of whether the legislation in question still meets its primary aims, the intention is to focus only or primarily on regulatory burden on the industry. This is at clear variance with the stated aim of this REFIT exercise and casts further doubt on the rationale behind the Commission's 'better regulation' agenda. Furthermore, as each group of stakeholders has a different questionnaire, it will not be possible to compare opinions and information provided by different stakeholders during the public consultation by public debate and exchange. We therefore ask you to pause this process until a roadmap has been published and consulted on, as laid out in the Better Regulation guidelines. If such an important REFIT can proceed with such flagrant disregard for these guidelines, then one might question why these guidelines exist at all. Yours sincerely, Jeremy Wates (Secretary General of the European Environmental Bureau) On behalf of: Cancer Prevention and Education Society CHEM Trust ClientEarth Danish Ecological Council Ecologistas en Acción European Environmental Bureau (EEB) Health and Environment Alliance (HEAL) Health Care Without Harm Pesticide Action Network-Europe Women in Europe for a Common Future (WECF)
13/05/2016	NGOs warn European Regulators: Scientists expect increased cases of cancer if glyphosate would be re-authorised Open Letter from 39 European organisation raises questions about legal consequences of re-authorising glyphosate. Open Letter from 39 European organisation raises questions about legal consequences of re-authorising glyphosate 12 May 2016, Brussels - Today the Health and Environment Alliance sent an open letter together with 38 other European health and environmental organisations, to urge the decision-makers of the 28 EU Member States to vote against the reauthorisation of the active pesticide ingredient glyphosate. The vote will take place on the 18th or 19th of May 2016 during the meeting of the “Standing Committee on Plants, Animals, Food and Feed” of the European Commission. Despite the International Agency for Research on Cancer (IARC)’s recent classification of glyphosate as a probable human carcinogen the European Commission recommends re-authotisation of glyphosate for another 9 years. “This letter is directed to all government representatives of each EU Member State, who will vote in Brussels on the reauthorisation or ban of glyphosate in Europe and all the ministries involved", says Lisette van Vliet, Senior Policy Adviser at HEAL: "We aim to point out once again the expected health and legal consequences in case of a reauthorisation of glyphosate to the decision-makers before they vote." The view of the aforementioned environmental organisations is supported by notable scientists; German epidemiologist Prof. Eberhard Greiser of the University Bremen, presents a “meta analysis“ about the correlation between exposure to glyphosate and the abundance of cancer incidences of 'Non-Hodgkin Lymphoma' at a press conference in Vienna today. “A summary of all so far released epidemiological studies within the framework of a so called meta-analysis show an increased risk of desease by 45 percent for people working with glyphosate – in comparision to people without any contact with Glyphosate.”, Greiser states. “Therefore, in case of the reauthorisation of glyphosate, thousands of new diseases of this malignant lymphoma, which is mortal in 50 percent of the cases, are to be expected in the EU.”, he continued. “Pesticides, which cause cancer in animal studies shall not be authorised by European law”, says the lawyer Dr. Josef Unterweger. “But the German Federal Institute of Risk Assessment, which carried out the risk assessment of glyphosate on behalf of the EU, claims that there is no information on carcinogenic effects on a experimental nimals. In addition, the president of this authority compares the lethal dose of glyphosate with the one of table salt, even though the WHO classified glyphosate as 'probably carcinogenic to humans'. Since 1996 this comparison to table salt, originally made by Monsanto, has been shown to be misleading and in fact the US Ministry of Justice told Monsanto that if it continues using this comparison it will be breaking the law. By reauthorizing glyphosate, Europe would be putting its 500 million EU people at risk of cancer. In this case the EU could potentially face legal prosecutions from those that have been exposed to glyphosate through its use in agriculture and in other areas. Is it really worth the possibility of millions of lawsuits to reauthorise glyphosate because the pesticide industry is concerned about losing profits from its sale? Resources: Open letter to Ministers of Agriculture, Environment, Health and Food Safety of 28 EU Member States and Members of the Standing Committee on Plants, Animal, Food and Feed of the European Commission regarding how the renewal of the authorisation of glyphosate violates the European Regulation (EC) No. 1107/2009 on pesticides.
29/04/2016	Letter to European ministers to ensure that the EU’s largest climate instrument is fit for purpose The Health and Environment Alliance (HEAL) joined a coalition of 22 health and environmental NGOs in asking European ministers to ensure that the 2030 Effort Sharing Decision, the EU's largest climate instrument, is fit for purpose. Dear Minister, A global climate deal was adopted last December in Paris, in which all countries agreed to take action on climate change. The Paris agreement is unique as it represents a historically significant milestone that aims to pursue efforts to limit global temperature rises to 1.5°C above pre-industrial levels. Before the summer you will present a revised Effort Sharing Decision (ESD), to tackle 60% of the EU’s greenhouse gas emissions by setting out annual emission targets for each Member State. We urge you to maintain the momentum created in Paris by ensuring that the 2030 Effort Sharing Decision results in effective climate action in the transport, buildings, agriculture, small industry and waste sectors. Such a signal from the EU will demonstrate to the rest of the world the strong political determination to translate the Paris Agreement into dynamic and meaningful action at home. To be coherent with the agreement made in Paris, the revised Effort Sharing Decision for the post-2020 period should include the following elements: 1. Increased ambition that is consistent with long-term objectives. The 2030 ESD must set Europe on a cost-effective path to reach the goals of the Paris Agreement and contain a long-term trajectory to reach at least 95% emission reductions by 2050 compared to 1990 levels. The EU must be fully committed to implement the Paris Agreement’s long-term objective to limit temperature increase to well below 2°C, and pursue efforts for limiting it to 1.5°C. 2. Include 5-yearly review and ratchet up mechanisms. The 2030 ESD should be aligned with the 5-year commitment cycles stipulated in the Paris Agreement and also include a ratchet-up mechanism. These two elements will allow upward reviews of the targets every 5 years, in line with future scientific assessments and technological potential, to avoid dangerous global warming and ensure the implementation of the relevant EU climate and energy instruments. 3. Governance must be adequate. The 2030 ESD should include annual reduction targets, annual compliance cycles and more effective corrective actions to avoid non-compliance. These elements are necessary to keep progress towards achieving the targets transparent. 4. Start in 2021 at actual emission levels. Most Member States are expected to significantly overachieve their 2020 ESD targets. Therefore, the 2030 ESD should allocate Member State allowances at the level of real emissions in each Member State at the start of the implementation period. In those few Member States who fail to reach their 2020 ESD target, that target should be their starting point for the post-2020 period, so as not to ‘bail-out’ their underachievement. Doing this will prevent the over-allocation of emission permits into the next period. 5. Closing the loopholes. Member States should not be allowed to use surplus allowances from the EU ETS to comply with their climate targets in the non-ETS sectors. The oversupply of EU ETS allowances needs to be addressed in the context of the ongoing reform of the EU carbon market. Transfer of ETS credits into the ESD would result in overall higher emission levels in the EU up to 2030, compromising the delivery of the 30 per cent ESD emissions reduction target. 6. Address carbon removals separately to ESD emissions, as part of a separate LULUCF pillar. Carbon removals from forests and land use should be promoted in addition to (and not replacing) emission reductions in the existing ESD sectors. Such removals must not be used to offset fossil fuel emissions in the other sectors. The reformed ESD should contribute to correct carbon accounting of bioenergy emissions and secure strict compliance with bioenergy sustainability criteria in order to guarantee real emissions savings 7. Put efficiency first and reinforce the synergies between European climate, energy and sectoral legislation. Various EU measures, including in the area of energy, support Member States’ ability to meet their climate targets and are crucial to achieving necessary emission reductions in the ESD sectors. They include 2025 CO2-targets for road vehicles, Energy Performance of Buildings Directive, the Energy Efficiency Directive, and the Circular Economy Package. These instruments should be reinforced to help Member States achieve their ESD targets and ensure the delivery of emission reductions in all sectors. If implemented, these recommendations will help secure a real low-carbon transformation of our economy and will lead to more livable cities, cleaner air, reduced energy poverty and the creation of jobs. We call on you to take our recommendations into account when developing the proposal for the revised Effort Sharing Decision. To that effect, we would like to request a meeting in order to go into further detail on these issues. Yours sincerely,
25/04/2016	Call to exclude the ‘Good Regulatory Practices’ chapter from TTIP At the start of the 13th round of the Transatlantic Trade and Investment Partnership (TTIP) negotiations, a coalition of health and environment NGOs ask the EU Trade Commissioner to ensure that the problematic elements of the EU 'Better Regulation' agenda are not codified in this legally-binding trade agreement. 25 April 2016 Re: Call to exclude the ‘Good Regulatory Practices’ chapter from TTIP Dear Ms. Malmström: At the start of the 13th round of the Transatlantic Trade and Investment Partnership (TTIP) negotiations, we are writing to ask you to ensure that the problematic elements of the EU ‘Better Regulation’ agenda are not codified in this legally-binding trade agreement. The Commission’s approach to doing impact assessments and stakeholder consultations — as developed under its ‘Better Regulation’ agenda — is causing serious delays in the introduction of regulatory measures necessary to ensure the high level of protection of human health and the environment mandated by the Treaty on the Functioning of the European Union. In particular, the long delays in adopting identification criteria for endocrine disruptors and the failure to adapt the REACH registration requirements to the specificities of nanomaterials in time to be able to meet the 2018 registration deadline, were both caused by decisions to conduct impact assessments and public consultations. In the case of endocrine disrupting chemicals, the delay stemming from this decision led directly to the EU General Court’s ruling that the EU Commission was breaching its legal obligations. We believe it is therefore imperative that the way such instruments are used can and will be regularly reviewed. This would become impossible if domestic regulatory practices were codified in a legally binding international agreement that would give a prominent role to assessing trade impacts. Moreover, the aims of the “Good Regulatory Practices” chapter are to limit the impact of regulatory measures on transatlantic trade. The impact will, however, be the largest in areas where there are high levels of variation between EU and US legislation and standards such as the chemicals sector. As a result the EU’s ability to adopt and implement regulation will be affected most heavily in these areas. We remind you of the European Parliament’s July 2015 resolution on TTIP, which called on “negotiators on both sides […] to ensure similarly that it will not affect standards that have yet to be set in areas where the legislation or the standards are very different in the US as compared with the EU, such as, for example, the implementation of existing (framework) legislation (e.g. REACH) […] or future definitions affecting the level of protection (e.g. endocrine disrupting chemicals).” The codification of the ‘Better Regulation’ agenda under TTIP would run counter to the recommendation set by the European Parliament that would need to approve an eventual final transatlantic trade agreement. We therefore call on you to exclude the “Good Regulatory Practices” chapter from the European Commission’s TTIP proposals and to ensure that controversial elements of the EU’s ‘Better Regulation’ agenda are not embedded in a legally binding trade agreement. For further information on the implications of ‘Better Regulation’ and TTIP on the EU’s capacity to legislate in the area of public health and the environment, please find the attached January 2016 report by the Forum Umwelt und Entwicklung, Bread for the World and the European Environmental Bureau. Signed, David Azoulay, Program Director, Center for International Environmental Law (CIEL) Karla Hill, Director of Programmes (ClientEarth) Jeremy Wates, Secretary General, European Environmental Bureau (EEB) Génon K. Jensen, Executive Director, Health and Environment Alliance (HEAL)
21/04/2016	Statement from the Coalition for Higher Ambition for the Implementation Paris Climate Agreement An unprecedented grouping of businesses, trade unions, local authorities and civil society organisations urge EU Heads of State and Government to aim for higher ambition in the implementation of the Paris Climate Agreement. 20 April 2016 To: EU Heads of State and Government, Statement from the Coalition for Higher Ambition We represent businesses, trade unions, local authorities and civil society organisations supporting a wide range of social and environmental outcomes. We have come together in an unprecedented grouping, to recognise that the Agreement struck in Paris in December 2015 is a turning point that requires the world to step up and raise its ambition to keep global temperature rise well below 2 degrees, as well as to pursue efforts towards 1.5 degrees. European leadership helped deliver the Paris Agreement. As you set off to New York to sign this agreement, we ask you to continue to show leadership by delivering ratification of the Paris Agreement as soon as possible, and by working with other countries to support their delivery of the Agreement’s goals and obligations, thereby effecting enhanced climate diplomacy. However, showcasing European leadership abroad entails that we “walk the talk” at home. 2016 is a critical year for the implementation of the Paris Agreement and the Sustainable Development Goals, through the development of EU legislation that brings the EU’s 2030 climate and energy package to life. We believe that there is a real risk that the current level of ambition of legislation on the table will harm Europe’s chances of reaching the goals of the Paris Agreement, in a fair and equitable manner. Put simply, Europe’s 2030 legislative agenda risks locking-in insufficient ambition, and thereby undermining the integrity of Europe’s climate policies. We have demonstrated that we are ready to play our part in support of the objectives of the Paris Agreement. What we need to see now is the development of a robust European policy framework with strong, economy- wide targets, and clear timetables that will allow the EU to become a zero-carbon economy, driving increased deployment of renewable energy supply and energy efficiency measures. This also means guarantees, that 2030 and 2050 greenhouse gas reductions targets are in line with the long term goals of the Paris Agreement, building on the overachievement of the EU’s 2020 emissions reductions target. Together we must develop an innovative and sustainable European economy that will allow all of Europe to benefit in terms of good quality jobs, sustainable development, improved competitiveness and better public health, while ensuring a just transition for the workforce, and a healthy environment. Such a Europe will also be more credible and influential on the global stage, regaining its status as a committed leader on climate action, and strengthening Europe’s role as a fair partner, particularly to countries who are vulnerable to climate change impacts. Signatories ADP Acciona Act Alliance EU Anglian Water Bond Beter Leefmilieu Vlaanderen BT British Energy Efficiency Federation Bundersverband Erneuerbare Energie (BEE) Carbon Market Watch CARE International CDP Centre for Transport and Environment (CDE) Czech Republic Changepartnership Climate Action Network Europe Climate Alliance Deutsche Naturschutzring (DNR) Dong Energy Doosan Babcock DSM E.ON EKOenergy Entidad Nacional de Auditores y Certificadores Energéticos (ENACE) EuroACE Euroheat & Power European Alliance to Save Energy (EU-ASE) European Copper Institute European Council for an Energy Efficient Economy (ECEEE) European Environmental Bureau (EEB) European Geothermal Energy Council (EGEC) European Industrial Insulation Foundation (EIIF) European Insulation Manufacturers Association (EURIMA) European Solar Thermal Industry Federation (ESTIF) European Trade Union Confederation (ETUC) Ferrovial GEN Europe Gorenje Surovina d.o.o Greenpeace GSK Health Care Without Harm Europe Health And Environment Alliance (HEAL) Heathrow Iberdrola IEA DSM Task 24 Interface Inter-Environnement Wallonie (IEW) International Union for the Conservation of Nature (IUCN) Kingfisher Klima-Allianz Deutschland Koalicja Klimatyczna Poland Legambiente Italy Milieudefensie Nederland Mouvement Ecologique Luxembourg National Energy Conservation Agency (NAPE) Poland Nature Friends International Oxfam Philips Plan B za Slovenijo - network of non-governmental organisations for sustainable development Quercus Portugal Reseau Action Climat France Rockwool Sandbag SEO Birdlife Spain Sindikat vzgoje izobraževanja, znanosti in kulture Slovenije Sky SSE Sustainable Development Initiatives (DVI) Lithuania Terra Mileniul III Romania The B Team The Danish 92 Group Transport & Environment Unilever WWF Zero - Associacao Sistema Terrestre Sustentavel Portugal Zveza Svobodnih Sindikatov Slovenije 11.11.11 Vlaanderen 3M E3G
19/04/2016	Twelve Public Health and Environment NGOs Share Concerns On BPA and DEHP Ahead Of REACH Committee Twelve public health and environment NGOs share their views with regard to two endocrine disrupting chemicals, Bisphenol A and DEHP, in a joint letter. UPDATE: HEAL is disappointed at the EU REACH Committee’s decision to grant EDC phthalate DEHP the green light for use in recycled PVC goods like vinyl flooring. Prior to the vote, HEAL joined a multi-NGO open letter urging its rejection, stating that this authorisation undermines REACH’s aim to replace toxic substances with safer alternatives. The letter also covers BPA in thermal paper. Brussels, 15th April 2016 Dear Sir/Madam, We would like to share with you our views with regard to two decisions regarding the exposure of people and the environment to two endocrine disrupters, BPA and DEHP, that will be discussed during the next REACH Committee in Brussels on 20 April. These decisions will have particular implications for vulnerable populations such as babies in the womb, young babies and children. Restriction of the use of BPA in thermal paper The restriction proposal presented by France to ban the use of BPA in thermal paper will be on the agenda for discussion. It is important that member states make clear at this meeting their support for this restriction so that it can be brought to a vote as soon as possible. The intention is to reduce BPA exposure in the general population, but especially in workers, such as cashiers, who regularly handle thermal receipts. Since the greatest risk is to the developing foetus, the proposed restriction is also targeted at reducing BPA exposure for women who are or may be pregnant. ECHA’s Committee for Risk Assessment (RAC) broadly agreed with France’s conclusion that BPA may affect the liver, the kidney, and have other adverse effects on reproduction, on the mammary glands (breast cancer), the immune system, metabolism and neuro-behavioural development. However, it disagreed with the approach used by France to calculate the risks and carried out its own estimations, concluding that while the risks to consumers are adequately controlled, those to workers are not. We consider that RAC's assessment of the risk to consumers is not correct (see reasoning in attached briefing). SEAC re-evaluated the cost-benefit assessments submitted by France and concluded that the “restriction of BPA in thermal paper is considered unlikely to be proportionate”. In other words, the costs of the proposed restriction to industry may outweigh the monetised benefits to society. However, this conclusion depends strongly on the substitutes used after the restriction and on their costs. Furthermore, SEAC pointed out that it did not attempt to quantify all benefits to society, hence it underestimated the societal benefits of the restriction. We consider that SEAC has conducted a very poor estimate of the true costs and benefits of the proposed restriction (see reasoning in attached briefing). SEAC found the proposed restriction to be affordable, in the sense that industry can afford to pay the cost of changing to safer alternatives since it would involve an estimated price increase of no more than €0.05-0.18 to each roll of thermal paper, or €4–15 per year per cashier. SEAC also noted that “there may be favourable distributional and affordability considerations” since the proposed restriction is expected to reduce the risks for the disproportionately exposed group (pregnant cashiers), while sharing the costs broadly across the entire EU population. In short RAC and SEAC agreed that EU-wide action is justified, and that the proposed restriction is implementable, enforceable, manageable, and monitorable, even if they were more dismissive of the benefits than we believe is merited. Breast cancer accounts for the highest health-care costs (€6.73 billion or 13%) of all cancer-related healthcare costs in Europe. It is hard to imagine that any citizen of the EU would not pay €0.1–€0.2 per year to stop girls being exposed to BPA in their mothers’ wombs and thereby potentially avoiding them having to suffer breast cancer later in life. Indeed, there is already a strong preference among consumers for products labelled as “BPA-free. Authorisation of the use of DEHP in recycled consumer articles The Commission has presented a reviewed proposal to grant authorisation to Vinyloop Ferrara, Stena Recycling and Plastic Planet to use DEHP in recycled soft PVC-containing articles. The new proposal imposes stricter conditions on these companies in order for them to reapply for authorisation after the review period. It obliges downstream users to make monitoring and biomonitoring information available to ECHA before 31 December 2016. The proposed review period expires on 21 February 2019. However, granting authorisations for these applications would still not be in keeping with the provisions of Title VII of REACH, in particular Articles 60, 62 and 64 of REACH as: The risks related to the uses of DEHP are not adequately controlled. There are suitable alternative substances and technologies. The applicants did not demonstrate that the socio-economic benefits of continued use outweigh the risk to human health or the environment. Granting an authorisation that does not meet the requirements established by REACH would not only breach the Regulation but would also establish a very negative precedent that would compromise upcoming decisions and undermine the aims of the REACH Regulation. Therefore, we would ask you to support the restriction of the use of BPA in thermal paper and to reject the Commission’s proposal to grant authorisation for the use of DEHP in consumer articles made with recycled PVC. Yours faithfully, Jeremy Wates, Secretary General of the European Environmental Bureau On behalf of: Armenian Women for Health and Healthy Environment (AWHHE) Breast Cancer UK BUND CHEM Trust Danish Ecological Council ECOCITY Ecologistas en Acción European Environmental Bureau (EEB) Health and Environment Alliance (HEAL) Swedish Society for Nature Conservation (SSNC) Wemos Foundation Women in Europe for a Common Future (WECF) Other resources: A similar coalition of NGOs also voiced their concerns regarding these endocrine disrupting chemicals in a letter to Member State representatives earlier this month (http://env-health.org/resources/let...)
12/04/2016	HEAL’s view on the Parliament resolution on glyphosate On the 13th of April, Members of European Parliament (MEPs) will vote on the Environment Committee’s objection to the Commission’s draft measure to renew the EU market approval for glyphosate, the active ingredient in many widely used herbicides. HEAL joined other NGOs asking MEPs to support this objection because of serious health concerns. HEAL positive about parts of Parliament resolution on glyphosate The recent EP resolution on glyphosate re-approval clearly told the Commission that it has overstepped its powers with its recent proposal. The non legally-binding resolution recommends some important use limitations such as removing it from public areas, and from sale to private individuals. It also calls for strict limits on pre-harvest use, and no use where integrated pest management is adequate for weed control. The resolution recommends the Commission's 15 year proposal for re-authorisation for seven years. Brussels, 13 April 2016 – The Health and Environment Alliance (HEAL) says today’s vote on glyphosate re-approval shows that MEPs want the Commission and Member States to better protect the health of citizens, and that the Commission’s outrageous proposal exceeded its powers. Lisette van Vliet, Senior Policy Advisor for HEAL says: ''HEAL is pleased that the MEPs voted to stop use in public areas (playgrounds and parks), and to stop non professional uses. But its important to note that these limitations to the license will not be enough to fully address the risks of people’s exposure to a massively used probable carcinogen and possible endocrine disruptor''. She adds: ''The WHO’s International Agency for Research on Cancer (IARC) has shown that EFSA is not infallible, and if EFSA had done as good a job as IARC, glyphosate could not legally be renewed in the EU''. The Parliament vote is not legally binding, but conveys Parliament views to the Commission. The next official step in the legal decision-making procedure on glyphosate’s EU licence is that the representatives of EU Member States meet in the so-called Standing Committee on Pesticides (PAFF) on April 19-20, to discuss and decide on the Commission’s adjusted proposal. The Commission was unable to get PAFF agreement to its original proposal in early March. Ahead of the vote, HEAL joined other NGOs asking MEPs to support this objection because of serious health concerns. Pesticide Action Network Europe (PAN Europe), Health & Environment Alliance (HEAL), Slow Food and Greenpeace are asking MEPs to support this objection because of serious health and environmental concerns, which have been raised by the scientific community. Glyphosate-based herbicides are widely used in agriculture, forests, public areas and private gardens. The use of this substance is so extensive that it is now detected in food, drinks and in the human body (including babies and young children). Last year, the International Agency for Research on Cancer (IARC) of the World Health Organisation (WHO) classified glyphosate as a “probable human carcinogen”. However, the European Food Safety Agency (EFSA) said in November 2015 that there was no scientific evidence of any cancer link. Glyphosate may also disrupt the human hormone system – EFSA and leading scientists have called for further investigation. Both its cancer causing and hormone disrupting properties would disqualify glyphosate from EU market approval under EU pesticides law. In addition, there are “many environmental, plant health and soil-ecosystem problems associated with heavy and repeated uses of glyphosate-based herbicides” according to the scientists. Despite these serious concerns, the European Commission’s initial proposal is for the maximum period possible (15 years), bans only one of the nearly 500 possible co-formulants, polyethoxylated (POE)-tallowamine, already no longer used in Germany, one of Europe’s largest pesticides markets, allows a 66% increase in residues on food. allows glyphosate producers to prove the absence of hormone disruption after obtaining approval, a practice deemed inappropriate by the EU Ombudsman for this sort of case. The European Chemicals Agency (ECHA), which is formally responsible for the EU carcinogen classification, is about to review the possible carcinogenicity, germ cell mutagenicity and reproductive toxicity of glyphosate. That process will not be finalised before end of 2017. It is our strong view that the EU should not take any final decision before the potential health and environmental impacts of glyphosate have been fully established, including its potential to cause cancer and affect the endocrine system. In addition, the EU should immediately ban all uses of glyphosate that result in the greatest public and worker exposure, either directly or through residues in food. Therefore we call on MEPs to vote in favor of the objection to the Commission’s ill-considered proposal for glyphosate renewal and stand for the protection of human health, environment, and safer farming for all agricultural communities. ------------- Background In March 2015, the WHO’s International Agency for Research on Cancer (IARC) classified glyphosate as a ‘probable carcinogen’ based on ‘limited evidence’ in humans and ‘sufficient evidence’ in animals that glyphosate can cause cancer in humans. IARC has also found ‘strong evidence’ that glyphosate exhibits two characteristics associated with carcinogens, namely genotoxicity and the ability to induce oxidative stress. In November 2015, the European Food Safety Agency (EFSA) arrived at the opposite conclusion. It stated that evidence in humans is ‘very limited’ and that there is ‘no evidence’ of carcinogenicity in animals. EFSA also dismissed the evidence of genotoxicity and oxidative stress. EFSA had access to at least three additional industry studies that IARC had not seen, and that José Tarazona, head of EFSA’s Pesticides Unit, described as “key” and “pivotal”. However, 94 independent scientists – including 8 out of 17 members of the IARC Working Group – argue in a recent editorialthat: “Serious flaws in the scientific evaluation in the RAR incorrectly characterise the potential for a carcinogenic hazard from exposure to glyphosate.” The EU Ombudsman has recently slammed the European Commission’s practice of accepting proof of a pesticide’s safety after its formal approval. She said the practice should be applied “restrictively” and only “where there is no risk that the conclusion on the safety of the active substance could be flawed”. Nonetheless, the European Commission has proposed to “submit confirmatory information as regards the absence of endocrine disrupting properties that may cause adverse effect in humans” by 1 August 2016, whereas the current EU approval runs out on 30 June 2016. Glyphosate residues have been found in bread and beer, as well as human urine. EFSA has stated that existing monitoring efforts are insufficient to reliably measure glyphosate residue levels in food. Widespread use of glyphosate has led to the emergence and spread of glyphosate-resistant weeds, causing farmers to spray additional herbicides. It can also “significantly increase the severity of various plant diseases, impair plant defense to pathogens and diseases, and immobilize soil and plant nutrients rendering them unavailable for plant use,” according to Johal and Huber, 2009. The scientists warned that “ignoring potential non-target detrimental side effects of any chemical, especially used as heavily as glyphosate, may have dire consequences for agriculture such as rendering soils infertile, crops non-productive, and plants less nutritious”.
11/04/2016	Glyphosate – Your request for publication of confidential industry studies A joint letter to Dr Vytenis Andriukaitis, European Commissioner for Health and Food Safety, on his request for publication of confidential industry studies. 11 April 2016 Dr Vytenis Andriukaitis European Commissioner for Health and Food Safety Cc: Dr Bernhard Url, EFSA Executive Director Glyphosate – Your request for publication of confidential industry studies Dear Commissioner Andriukaitis, We refer to your letter of 4 April 2016 to Richard P. Garnett of Monsanto Europe, Chairman of the Glyphosate Task Force, an industry consortium pressing for continued approval of glyphosate. In this letter you requested the full publication of confidential industry studies on the potential carcinogenicity of glyphosate, an active ingredient in many widely used herbicides (1). The European Food Safety Authority (EFSA) examined 14 animal carcinogenicity studies, among other evidence, and concluded that glyphosate is not carcinogenic (2). The International Agency for Research on Cancer (IARC) evaluated eight of these studies, which were publicly available. It classified glyphosate in March 2015 as “probably carcinogenic to humans” (3). EFSA has underlined the fact that it “assessed more evidence including additional key studies that were not considered by IARC”.iv It stressed that “unpublished studies that were the core basis of the peer review evaluation were not available to the IARC experts” (5). This has raised expectations that the additional studies not seen by IARC must contain compelling evidence proving that glyphosate is not a carcinogen (6). We therefore appreciate your attempt to bring greater clarity to the glyphosate controversy by allowing independent scrutiny of these studies. However, your letter also raises some serious questions. Why are you asking for an exceptional release of the studies, instead of publication based on existing EU transparency rules? In December 2015, Corporate Europe Observatory requested that EFSA, under EU transparency rules, disclose five mouse carcinogenicity studies that were evaluated as part of the glyphosate risk assessment. The first response by EFSA was negative, arguing that disclosure of the studies would “put at risk the commercial interests and intellectual property rights of their owners” and that “no overriding public interest on disclosure applied to this request” (7). A final response is still pending despite the fact that legal deadlines have expired. It is our strong view that the public should have access to all scientific evidence submitted by pesticide producers, based on EU transparency rules, namely Regulation 1049/2001 on public access to European institution documents, and Regulation 1367/2006 on the application of the Aarhus Convention. This cannot be a one-off favour granted to an exceptional request by a single politician. When it comes to public health and environmental protection, transparency must be the rule. The recent opinion of Advocate General Juliane Kokott in case C-442/14 at the European Court of Justice confirms this (8). Laboratory studies on the impact of pesticides fall under the definition of ‘information on emissions into the environment’ of the Aarhus Convention. This means that there is an overriding public interest that requires disclosure, and the grounds for refusal must be interpreted in a restrictive way. Why are you only requesting the release of certain studies when it is clearly in the public interest that all evidence assessed by EFSA must be published? The animal carcinogenicity studies evaluated by EFSA are described in the Addendum to the Renewal Assessment Report issued by the German Federal Institute for Risk Assessment (BfR) (9). (This Addendum was published after IARC finalised its evaluation of glyphosate.) According to the information available, several of the studies not seen by IARC show a significant increase in different types of tumours due to glyphosate exposure, supporting IARC’s carcinogen classification (10). More detail would certainly be helpful to fully evaluate these results. EFSA dismissed the worrying findings of these studies partly because the incidence of tumours was, reportedly, within the range of control data from other animal studies (so-called “historical controls”). However, only one set of historical control data is referenced in the EFSA report, and the use of that data is inconsistent with established OECD and ECHA guidelines (9). It is essential that all the data on which EFSA based its conclusion are on the table for independent evaluation, including the historical control data used. As a matter of principle, EFSA scientific opinions, which form the basis of regulatory action, should be based on published scientific evidence. Restrictive access under the conditions of a “physical reading room” (11) fails to fulfil this requirement. It has no place in an open scientific process. The aim must be that all EFSA assessments, not only on glyphosate, can be reproduced by any expert who wishes to do so. Only in this way will EFSA be able to restore credibility in its work among the scientific community and the public. We look forward to your answers to these questions. Finally, we would like to reiterate our demands in relation to the renewal of the EU approval for glyphosate (12). We ask the European Commission to: Refrain from taking any final decision on the renewal of glyphosate’s EU approval as long as uncertainty remains over the risks it poses to human health and environment; Immediately ban the use of glyphosate where it results in the greatest public and worker exposure, including non-professional use in gardens and domestic environments, use by municipal authorities, railway and highway networks, and specialised agricultural uses, such as the desiccation of crops. This letter will be published on the websites of the signatory organisations. Yours sincerely, Jorgo Riss, Director, Greenpeace European Unit Also on behalf of: Corporate Europe Observatory Health & Environment Alliance (HEAL) Pesticide Action Network Europe Friends of the Earth Europe European Environmental Bureau Avaaz WeMove Notes: (1) http://ec.europa.eu/commission/2014... (2) http://www.efsa.europa.eu/en/press/... (3) http://monographs.iarc.fr/ENG/Monog... (4) http://goo.gl/tlVYBc (5) http://www.efsa.europa.eu/sites/def... (6) http://healthandenvironmentonline.c... (7) http://goo.gl/9QkssK (8) http://goo.gl/EiQGZd (9) http://corporateeurope.org/sites/de... (10) http://jech.bmj.com/content/early/2... (11) http://www.glyphosate.eu/gtf-statem... (12) http://www.greenpeace.org/eu-unit/e...
17/03/2016	Open Letter on Glyphosate to National Representatives on the Standing Committee on Plant Animal Food and Feed (PAFF) On Wednesday 16th of March, HEAL has asked national representatives of the Standing Committee on Plant Animal and Feed (PAFF) to submit amendments to their proposed renewal of the glyphosate marketing authorization in the EU, after postponing the vote last week due to lack of agreement. March 16, 2016, Brussels Dear National representative on the Standing Committee on Plant Animal Food and Feed (PAFF), The European Commission has asked you to submit amendments to their proposed renewal of the glyphosate marketing authorisation in the EU, after postponing the vote last week due to lack of agreement. As Health and Environment Alliance (HEAL) (1), a leading European non-profit organisations with over 70 member organisations working for better health through a healthier environment, we ask you to consider the following procedural issues and public health concerns, both for your own amendment(s) as well as for the position you take on any suggested amendments and the overall (amended) proposal for renewal of glyphosate’s authorisation. In brief, we urge you to oppose the renewal until the below conditions are met. You are no doubt aware that the German (BfR) draft assessment and EFSA’s peer review have been strongly criticized by nearly 100 scientists, who maintain that the EFSA conclusion is based on a flawed assessment. The current profound disagreements on the carcinogenicity of glyphosate between IARC and EFSA are a serious problem, given that regulation 1107/2009 prohibits active substances that are carcinogenic. Moreover, Glyphosate does not yet have an EU harmonised classification, and this process will probably be completed until 2017. It is scientifically questionable to completely disregard the IARC position and criticisms and assume that EFSA is entirely correct. Procedurally, it is pre-emptive to give a full renewal to glyphosate as if the EU harmonised classification will necessarily find glyphosate is not a carcinogen 1A or 1B. Equally, you will be familiar with the stipulation in 1107/2009 that prohibits active substances which have endocrine disrupting properties which may harm human health. EFSA stated in its peer-review that “an endocrine-mediated mode of action could not be ruled out”. Another recent scientific publication noted that the current models and data from the biological sciences predict that glyphosate disrupts endocrine signalling systems in ways that affect the hormones of vertebrate animals (2). Hence, although the criteria to identify endocrine disrupting properties have not yet been finalised, it seems premature to assume that glyphosate would not come under this prohibition. The European Commission has indicated that it will propose the criteria before the summer, meaning its approval procedure would be completed before the end of this year (earlier that the harmonised classification for carcinogenicity). Therefore, a renewal of the glyphosate authorisation should not be considered before the criteria are available. Finally, we must point to the increasing exposure of Europeans to glyphosate, which makes the above two unfinished procedures on glyphosate’s cancer causing and endocrine disrupting properties very disturbing. Last week a study showed traces of glyphosate detected in 99.6% urine samples of 2000 German consumers, and three-quarters of these samples tested above the existing maximum permissible limit. This trend could be similar across Europe. Regulation 1107/2009 states that particular attention be paid to the protection of vulnerable groups of the population, including pregnant women, infants and children (Recital 8). At the same time, more and more national cancer and medical groups, for example from Portugal, France, Belgium, UK and Malta, are calling for greater protection of our health. In conclusion, in the absence of certainty that glyphosate is not carcinogenic and not endocrine disrupting, and given the high level of exposure of vulnerable groups, a renewal of the glyphosate license does not respect the law. We therefore urge you to oppose renewal, until the EU classification process for glyphosate has been completed glyphosate has been formally assessed for its endocrine disrupting properties according to the forthcoming criteria Advise for an immediate ban on the uses that result in the greatest public and worker exposure, either directly or through residues in food, such as private individuals in the non-agriculture sector. We look to you to contribute actively towards the primary prevention of cancer and other diseases related to endocrine disruption, and to ensure that the existing law is upheld to the fullest. Sincerely, Ms. Génon K. Jensen Executive Director, Health & Environment Alliance (HEAL) Notes: (1) The Health and Environment Alliance (HEAL) is a leading European not-for-profit organisation addressing how the environment affects health in the European Union (EU). With the support of more than 70 member organisations, HEAL brings independent expertise and evidence from the health community to different decision-making processes. Our broad alliance represents health professionals, not-for-profit health insurers, doctors, nurses, cancer and asthma groups, citizens, women’s groups, youth groups, environmental NGOs, scientists and public health research institutes. Members include international and Europe-wide organisations as well as national and local groups. Website: www.env-health.org. Follow HEAL on Facebook and Twitter @HealthandEnv @EDCFree and @CHM_HEAL (2) http://ehjournal.biomedcentral.com/...
15/03/2016	Open Letter to Member States Ahead of ECHA’s REACH Committee Ahead of ECHA’s REACH committee vote this week, public health concerns feature in a joint letter to member state experts urging: 1) support for the identification of four phthalates as EDCs and 2) rejection of authorisation for the use of DEHP in recycled consumer articles. Read the open letter HEAL signed with 8 NGOs. Brussels, 11 March 2016 Dear Sir/Madam, We would like to draw your attention to two decisions regarding the exposure of people and the environment to four phthalates that will be voted on during the next REACH Committee on 16-17 March. These decisions will have particular implications for vulnerable populations such as babies in the womb and young babies and children. We would like to ask you to support the Commission’s proposal to identify four phthalates (DEHP, DBP, BBP and DIBP) as substances of very high concern (SVHCs) according to Article 57(f) of REACH due to their endocrine disrupting properties and consequent implications for human health, and to reject the Commission’s proposal to grant authorisation for the use of DEHP in consumer articles made with recycled PVC. Support the identification of four phthalates (DEHP, DBP, BBP and DIBP) as endocrine disrupting chemicals (EDCs) It has already been agreed that DEHP will be listed as an EDC for the environment (REACH 57f) in addition to its reprotoxic properties (REACH 57c). During this meeting, Member States will vote on whether these four phthalates shall be listed as EDCs due to their human health effects. Member States have already unanimously agreed in the Member State Committee (MSC) that these four substances have endocrine disrupting properties for environment and the majority of Member States agreed that as the level of concern over these effects on human health is equivalent, the four phthalates should be listed according to Art 57(f). However, four Member States had objections to their identification as SVHCs according to Art 57(f) as they are already included in the Candidate List (and authorisation list) as substances that are toxic for reproduction (category 1B). The Commission's proposal notes that Article 57 does not preclude identifying a substance as being of very high concern based on the same effect on human health several times, in order to specify the mode of action. In fact, other chemicals are listed as carcinogenic and mutagenic, and this is not considered double counting. We agree with the majority of Member States and the Commission on the importance of specifying the mode of action of these phthalates as endocrine disruptors by identifying them as SVHCs according to Art 57(f), as this would better reflect existing scientific knowledge on these substances. Listing DEHP, DBP, BBP and DIBP as EDCs for human health, as compared with only listing them as reprotoxicants, will lead to different risk management considerations in the REACH authorisation and restriction processes. For example, the REACH Review of how EDCs should be assessed noted that “it may be difficult (albeit not impossible) to determine a safe threshold with reasonable certainty for endocrine disruptors, taking into consideration all uncertainties related to EDs”. Although the deadline for submitting applications for authorisation for these substances has already expired, Denmark and ECHA will soon submit a restriction proposal for these four substances, in order to avoid the exposure of people and the environment through imported articles. The identification of the four phthalates as EDCs for human health is a crucial consideration in this upcoming restriction process because as EDCs for human health any level of exposure would constitute a risk to be addressed. Therefore, identifying whether a reproductive toxicant is also an EDC is very useful as it further informs how these chemicals should be dealt with. Reject authorisation for the use of DEHP in recycled consumer articles Vinyloop Ferrara, Stena Recycling and Plastic Planet have applied for authorisation of the use of DEHP in recycled soft PVC-containing articles. Granting authorisations for these applications would not be in keeping with the provisions of Title VII of REACH, in particular Articles 60, 62 and 64 of REACH and would undermine the main objective of REACH “to encourage and [...] to ensure that substances of high concern are eventually replaced by less hazardous substances or technologies where suitable economically and technically viable alternatives are available”. The risks related to the uses of DEHP are not adequately controlled as RAC has clearly stated in its opinion. There are suitable alternative substances and technologies. As highlighted in the SEAC's opinion, theapplicants, when providing their analysis of alternatives, ignored alternative materials, substances and techniques claiming that they cannot produce the alternatives, even though authorisation is sought for many downstream uses, not for manufacturing. Furthermore, DEHP has, to a large extent, already been replaced by other plasticisers and materials. During the public consultation, manufacturers of alternatives as well as downstream users applying these alternatives have provided overwhelming information which shows that readily available and technically and economically feasible alternatives do exist. The applicants could not demonstrate that the socio-economic benefits of continued use outweigh the risk to human health or the environment. SEAC’s opinion confirms that there were significant deficiencies in the socio-economic analysis presented by the applicant, including the lack of any health impact assessment identifying the remaining risk to workers’ health. Therefore, the legal requirements of Article 60(2) and 60(4) are not met and the authorisation must not be granted. We also would like to recall to your attention the EU Parliament’s Resolution (1) of 25 November 2015 calling on the Commission to reject the applications for authorisation for the formulation of recycled soft PVC containing DEHP. You can find further details regarding the procedural and substantive flaws of the ECHA Committees’ opinions on DEHP in a letter sent to the Commission by 55 civil society organisations (2) and in the EEB's report “A Roadmap to revitalise REACH” (3). As you can see, the decisions that you will take during next REACH Committee will have a substantial impact in reducing the exposure of people, including vulnerable populations such as babies in the womb and young babies and children, and the environment to these well known toxic substances. These decisions will also either reflect the spirit of the REACH law, or contradict its main purpose. We therefore call upon you to oppose the authorisation. Yours sincerely, Jeremy Wates, Secretary General of the European Environmental Bureau On behalf of: CHEM Trust ClientEarth The Danish Ecological Council The European Environmental Bureau (EEB) Friends of the Earth Germany-BUND Health and Environment Alliance (HEAL) Health Care Without Harm (HCWH) Europe Pesticides Action Network-Europe (PAN Europe) Women in Europe for a Common Future (WECF) Notes: (1) http://www.europarl.europa.eu/sides... 0409+0+DOC+PDF+V0//EN (2) http://www.eeb.org/EEB/?LinkServID=... (3) http://www.eeb.org/index.cfm/librar...
04/03/2016	Statement from the Coalition for Higher Ambition A major new coalition of businesses, cities, trade unions and non-profit organisations, including HEAL, are calling on EU leaders to live up to their Paris climate commitments. A major new coalition of businesses, cities, trade unions and non-profit organisations, including HEAL, are calling on EU leaders to live up to their Paris climate commitments. 1 March 2016 To: EU Heads of State and Government, Climate and Environment Ministers, the European Commission and the European Parliament The momentum and political good will that we witnessed at the Paris Climate Summit was truly remarkable. Thanks in large part to Europe's leadership the world has adopted the first ever global legally binding agreement, which will frame international climate action post 2020. In Paris, countries agreed to hold the increase in global average temperature “to well below 2 °C above pre-industrial levels and to pursue efforts to limit the temperature increase to 1.5 °C above pre-industrial levels”, as well as to bring greenhouse gas emissions down to net zero during the second part of this century. As businesses, cities, regions, investors, trade unions, civil society groups and other stakeholders we have demonstrated that we are ready to play our part in support of the objectives of the Paris Agreement. Over 1200 stakeholders have signed the ‘Paris Pledge for Action’, promising to act in order to ensure that the ambition set out in the Paris Agreement is met. However, our commitment to act will not be sufficient without an indication from Europe’s leaders that they will continue to show the leadership that was so critical in Paris and act to transform the Paris outcomes into reality. What we need to see now is the development of a robust European policy framework, which will allow the EU to become a zero carbon economy. We need Europe to stimulate long-term investments in low carbon technologies, in particular energy efficiency and renewable energy, as well as in sustainable agriculture and the protection and restoration of our ecosystems. We need Europe to develop an innovative European market that will allow all European leaders, citizens and workers to benefit in terms of good quality jobs, sustainable growth, improved competitiveness and better public health, while ensuring a just transition for the workforce. We also need Europe to continue to show international leadership by securing early ratification of Paris and working with other countries to support their delivery of the Paris Agreement. 2016 is a critical year for the implementation of the Paris Agreement as well as the Sustainable Development Goals through the development of EU legislation that will bring the EU’s 2030 climate and energy package to life. There is a real risk that the current level of ambition of legislation on the table is going to damage Europe’s chances of reaching the goals of the Paris Agreement. Put simply, Europe’s 2030 legislative agenda risks locking-in lower ambition. We therefore call on Europe’s leaders to: Ensure that Europe's ambition is consistent with the Paris Agreement and that we have a clear pathway set to 2050, which is at the upper end of the 80-95% range. Guarantee that 2030 and 2050 greenhouse gas reductions targets are in line with the science, the well below 2 degrees and 1.5 degree long term goals, building on the over achievement of the EU’s 2020 emissions reductions target. This will set the tone for the 2018 first global stocktake. Address the “at least’’ 40% domestic greenhouse gas emissions reduction target for 2030 (taking into consideration current progress). This will strengthen the EU’s strategy towards a low-carbon economy if underpinned by consistent and coherent binding targets and measures to support the deployment of low carbon technologies especially energy efficiency and renewable energy. Ensure that upcoming climate and energy legislation1 is aligned with delivering a growing, low-carbon, sustainable, socially fair and climate resilient Europe. This includes all relevant EU legislation on the EU Emissions Trading System, emissions from buildings, transport, agriculture and forests, renewable energy, energy efficiency and the EU's budget. This should include review clauses in all legislative proposals that allow for immediate implementation of any increase of the overall 2030 target in order to avoid locking in lower ambition. Work closely with businesses, cities, regions, investors, civil society groups and trade unions who have shown their commitment to transform the Paris Agreement into reality. As major organisations across Europe we call upon you to continue to show the leadership credentials that were so critical in driving the High Ambition Coalition at COP21. We look forward to working with you to ensure that the EU’s delivery of the Paris Agreement is set in motion in such a way that it will help us plan, invest properly and collectively set the EU on the right path in order to make the transition to a low emission and climate resilient economy inevitable, irreversible and irresistible. Note: [1] Including the ETS Directive, the Effort Sharing Decision, the Energy Efficiency Directive and Energy Performance in Buildings Directive; the Renewables Directive; the new Transport package; the Heating and Cooling Strategy, decisions around land-based emissions (LULUCF), the Multiannual Financial Framework and the Capital Markets Union. Signatories Acciona Águas de Portugal ACT Alliance EU Anglian Water Bond Beter Leefmilieu Vlaanderen British Energy Efficiency Federation BT Carbon Market Watch CARE International CDP Centre for Transport And Environment (CDE) Czech Republic Change Partnership Climate Action Network (CAN) Europe Climate Alliance of European Cities with Indigenous Rainforest Peoples Dong Energy Doosan Babcock DSM Entidad Nacional de Auditores y Certificadores Energéticos (ENACE) E.ON SE EuroACE Euroheat & Power European Alliance to Save Energy (EU-ASE) European Copper Institute European Council for an Energy Efficient Economy (ECEEE) European Environmental Bureau (EEB) European Geothermal Energy Council (EGEC) European Industrial Insulation Foundation (EIIF) European Insulation Manufacturers Association (Eurima) European Solar Thermal Industry Federation (ESTIF) European Trade Union Confederation (ETUC) E3G Ferrovial GEN Europe Gorenje Surovina d.o.o Greenpeace Health And Environment Alliance (HEAL) Health Care Without Harm Europe Heathrow Iberdrola IEA DSM Task 24 Inter-Environnement Wallonie (IEW) Interface International Union for the Conservation of Nature (IUCN) Kingfisher Klima-Allianz Deutschland Koalicja Klimatyczna Poland Legambiente Italy Milieudefensie Nederland Mouvement Ecologique Luxembourg National Energy Conservation Agency (NAPE) Poland Nature Friends International (NFI) Philips Plan B za Slovenijo - network of non-governmental organisations for sustainable development Quercus Portugal Reseau Action Climat (RAC) France Rockwool Sandbag SEO Birdlife Spain Skanska Sky Stora Enso Sustainable Development Initiatives (DVI) Lithuania Terra Mileniul III Romania The B Team The Danish 92 Group The Prince of Wales's Corporate Leaders Group Transport & Environment (T&E) Unilever WWF Zero - Associacao Sistema Terrestre Sustentavel Portugal 11.11.11 Vlaanderen 3M
02/03/2016	Conflict of Interest at the European Food Safety Authority: Enough is enough! An open letter from 7 EU organisations to the European Parliament's Budget Control Committee, urging to postpone EFSA's budget discharge because of its refusal to adopt meaningful measures to ban conflicts of interest among its experts and protect itself from undue influence. An Open Letter to the European Parliament's Budget Control Committee cc : Members of the Management Board of the European Food Safety Authority (EFSA), Commissionner V. Andriukaitis, DG SANTE, European Commission Brussels, 2 March 2016 Dear Members of the European Parliament's Budget Control Committee, On 26 January 2016, EFSA announced it was hiring a new director of communications, Ms Barbara Gallani, starting next May 1st. Ms Gallani has a long career in the food sector. There is a question, though: today, this person still is the Chief Scientist of the Food and Drink Federation, the food industry's trade federation in the UK. As a lobbyist, Ms Gallani was also applying to become a member of EFSA's Management Board, in one of the seats kept for “representatives of the food chain” there. She since withdrew her application. (1) With this appointment, EFSA once again indicates that, at best, it does not understand its political environment, or that, at worst, it does not care about its independence from the sector it is regulating. Whichever way, this decision was a disaster for what was left of EFSA's credibility. Enough is enough. We are writing to you to express our dismay. We have been discussing for many years with EFSA to try to convince this EU agency to reinforce its integrity, become more transparent and independent. We have been patient and constructive, participated in countless public and private consultations, open discussions and conferences. The European Parliament also, year after year since 2011, across political groups, made clear it wanted the agency to improve its reputation and in particular impose for two years a cooling off period on financial conflicts of interests. In its follow-up report to the Parliament's demands, the agency promised improvements but refused to close the loophole allowing conflicts of interest to happen (point 10). Experts with financial interests in companies regulated by EFSA can still be found in its scientific panels (and working groups), because the agency keeps evaluating these persons' interests only according to the specific topic of the group, not whether these interests are de facto regulated by EFSA. The more specific the topic, the bigger the loophole. With this system, a scientist's research on fries paid by a fast food company can be appointed to a scientific panel on hamburgers; different topic indeed, but is this really convincing as an independence policy? Some things did change at the agency. Small things. But too small. After a series of critical rulings on EFSA's independence policy, the European Ombudsman suggested she might launch a self-task investigation into EFSA's procedures on independence. Media reports keep accumulating (2) on the existence of conflicts of interest at the agency, which now is so afraid of media exposure that it regularly declines media requests. The agency keeps blaming bad journalism and says it needs to improve its communications. By hiring a lobbyist from the food industry? EFSA fears not being able to find enough qualified experts to fill its panels would it implement the Parliament's demand. But there are simple solutions to this, such as hearing any expert whose expertise would be considered interesting but not giving him/her a say on the panel's work. The agency has another, much better excuse: it cannot pay these experts and hardly has any budget to do research on its own. Free help is rare, and public help, from national agencies, research centers and universities, is being cut. That leaves lobbyists more space. Having to sacrifice independence to operational constraints is a rather desperate situation for a public risk assessment agency. But the blame falls essentially on the Commission for not giving EFSA a budget to at least pay 200 independent experts for the EU's 500 million citizens' food safety. EFSA's budget is even facing cuts. The European Commission has systematically dismissed MEPs' concerns on conflicts of interest at EFSA for the past years. We now ask you to do two things: postpone EFSA's budget discharge as long as they do not enact a serious independence policy on regulated commercial interests. They have the perfect opportunity to do it now since they have planned a revision of their independence policy for this year. postpone EFSA's budget discharge as long as the European Commission does not credibly commit to provide substantial additional budget to EFSA to pay independent experts and develop in-house research. With hope, Corporate Europe Observatory Fondation Sciences Citoyennes GMWatch Groupe international d’études transdisciplinaires (GIET) Health & Environment Alliance (HEAL) Pesticides Action Network Europe Testbiotech Notes: (1) Two members of the Management Board already come from the food industry. (2) See Appendix.
29/02/2016	Act on EDCs: EDC-Free Europe calls on Environment Ministers EDC-Free Europe, a coalition representing 68 organisations, calls upon European environment ministers to tell Commission to obey the law on endocrine disrupting chemicals (EDCs). 29 February 2016 Dear Environment Minister, We are writing to you on behalf of EDC-Free Europe, a coalition representing 68 organisations who have come together because of our concern about endocrine disrupting chemicals (EDCs). Scientists, health professionals and medical doctors have increasingly warned that EDCs can contribute to diseases and disorders like hormonal cancers (prostate, testicular, breast), reproductive health problems, impaired child development, and obesity and diabetes. We urge you, at the upcoming Environment Council, to make a strong statement calling on the European Commission to immediately comply with the ruling of the European Court of Justice on scientific criteria to identify Endocrine Disruptors (Case T-521/14 Sweden vs. Commission). The Court found that no impact assessment was legally required to produce the scientific criteria, and that any work on the impact assessment did not justify missing the legally binding deadline (Paragraph 74). Hence, any work on or from the impact assessment cannot be used to help decide or influence the final criteria, as the impact assessment is entirely irrelevant to the final completion and adoption of scientific criteria for identification of EDCs. The Court found that the criticisms of the proposed draft scientific criteria from June 2013 did not justify missing the deadline (Paragraphs 69, 70, 71). Hence, the draft criteria were appropriate for submission to Inter-Services Consultation, and still are. The Court also found that the criteria to determine endocrine disrupting properties can only be done in an objective manner, based on scientific data in relation to the endocrine system, independently of any other consideration (Paragraph 71). Therefore, the criteria must identify endocrine disrupting properties, based on interpretation of existing data, irrespective of any considerations about which endocrine disrupting chemicals might be of greater or lesser regulatory concern. Hence, the criteria should not include aspects related to ‘hazard characterisation’ (severity of effects, reversibility, and potency). In our view, the simplest and most robust reflection of the scientific data on endocrine disrupting properties is captured with three categories (Option 3 of the roadmap). It is also the approach that follows the existing categorisation scheme for Carcinogens, Mutagens and Reproductive Toxicants. We look to you to take a clear position after the release of the Court judgement in December 2015 and the Commission’s subsequent responses. Although we believe that having identification criteria with 3 categories enables pragmatic yet accurate reflection of the science, we acknowledge that for compliance with the Court judgement, the simplest way to proceed would be with an Inter-Services Consultation on the June 2013 draft criteria as soon as possible. Sincerely, Genon K. Jensen, Executive Director, HEAL on behalf of EDC-Free Europe ON BEHALF OF: Center for International Environmental Law (CIEL) ChemSec Client Earth Greenpeace Health and Environment Alliance (HEAL) Health Care Without Harm Europe (HCWH) Pesticide Action Network Europe (PAN Europe) Women in Europe for a Common Future (WECF) Action for Breast Cancer Action Cancer du Sein du Quebec Alliance for Cancer Prevention A.P.E.D.D.U.B Association pour la Protection de l’Environnement et le Développement Durable de Bizerte Baltic Environmental Forum Breast Cancer UK Breast Cancer Action BUND (Friends of the Earth Germany) The Cancer Prevention & Education Society (CPES) Centre Ecology and Health Chapaevsk Medical Association CHEM Trust Comité pour le Développement Durable en Santé C2DS Commonweal Corporate European Observatory Danish Consumer Council The Danish Ecological Council DES Daughter Eco Accord Ecobaby Foundation Ecocity Ecodes Ecologistas en Acción – Ecologists in Action European Academy of Environmental Medicine EUROPAEM Fodesam (Fondo para la Defensa de la Salud Ambiental) France Nature Environnement Fundación Alborada Fundación Vida Sostenible Fundacion Vivosano Générations Cobayes Générations Futures Gezinsbond Global 2000 Hipoalergiczni Indiana Toxics Action Project Initiativ Liewensufank Inter-Environnement Wallonie Irish Doctors Environmental Association IDEA Doctors for the Environment ISDE International Society of Doctors for the Environment ISTAS IVU e.V International Verein fur Umwelterkrankte Macedonian Association of Doctors for the Environment MADE Mediterranean Information Office for Environment, Culture and Sustainable Development (MIO-ECSDE) Naturskyddsföreningen / Swedish Society for Nature Conservation PAN Germany Physicians For Social Responsibility – Los Angeles Phyto Victimes Quercus – National Association for Nature Conservation Réseau Environnement Santé (RES) Scottish Hazards Campaign Stiching Huize Aarde TEDX The Endocrine Disruption Exchange The European Consumer Organisation (BEUC) TOXISPHERA Environmental Health Association Union of Construction, Allied Trades and Technicians UCATT WECF France WECF Germany WECF Netherlands Wemos Women Environment Network
23/02/2016	Joint Call For Clean Air More than 70 public health, environmental and civil society groups call on negotiatiors to aim high to cut emissions of harmful air pollutants across Europe, ahead of this week’s start of the trilogue on the National Emissions Ceilings Directive, a key piece of air quality law. To: Environment Ministers of EU Member States, EU Commissioner for Environment, Maritime Affairs and Fisheries, EU Commissioner for Health & Food Safety, Chair of the European Parliament Environment Committee and MEPs Julie Girling, Seb Dance, Jens Gieseke, Catherine Bearder, Kateřina Konečná, Bas Eickhout and Piernicola Pedicini Open letter by 76 public health, environmental, civil society, organic farming and animal welfare organisations on the opening of the trilogue negotiations on the National Emissions Ceilings Directive Brussels, 22 February 2016 Dear Ministers, Dear Commissioners, Dear Members of the European Parliament, This week you will be starting the trilogue negotiations for the new EU National Emissions Ceilings Directive (NEC). The NEC is a unique opportunity to set the EU on track for clean air and save literally thousands of European citizens’ lives each year. In the EU, air pollution continues to be an “invisible killer” causing 403,000 premature deaths in the year 2012 alone. Poor air quality also contributes to severe chronic disease across the lifespan including cardio-vascular and respiratory disease such as asthma, allergies, chronic obstructive pulmonary disease (COPD), lung cancer, impaired prenatal and early childhood development, and other chronic conditions such as diabetes, liver disease, mental health, obesity and childhood leukaemia. The health-related economic costs of air pollution are estimated at between €330 - €940 billion for the EU annually, which is equivalent to 3 - 9% of the EU’s GDP. Air pollution also impacts Europe’s nature and biodiversity, agricultural yields and natural vegetation. Crop losses due to air pollution are estimated at €3 billion per year. The European Commission has put forward proposals which would help tackle the severity and pervasiveness of air pollution as a public health emergency. We welcome this move and the improvements proposed by the European Parliament, in particular its call for earlier action. We are seriously concerned by the Council’s intention of weakening the overall ambition level, which will cause approximately 16,000 additional early deaths in the EU each year. (1) We are also alarmed by the high number of derogations and flexibilities introduced by the Council which undermine the whole purpose of the Directive to reduce air pollution and prevent premature deaths. (2) We, the undersigned public health, environmental, civil society organisations ask you to support the following five priorities for the trilogue negotiations: Support emission reduction commitments corresponding to at least 52% health improvement by 2030 EU-wide as proposed by the European Commission and the European Parliament - notably no weakening of ammonia and PM2.5 emission reduction commitments. Support legally binding targets for 2025 as requested by the European Parliament. Early action to tackle air pollution must be a priority. Reject unnecessary flexibilities, such as the adjustment of emission inventories, adjustment of emission factors and three-year averaging calculations, which are not justifiable and will dilute the ambition level of the Directive. Keep methane emission reduction commitments in the Directive as a way of tackling ground-level ozone. We also call upon the Commission to address harmful mercury emissions when reviewing the Directive. Support provisions granting the public the right to access to information, to participate in the formulation of national air pollution control programmes and to access the courts if their governments fail to comply with the Directive. Breathing clean air is one of our most fundamental human needs. Every EU citizen has the right to grow up, live and work in an environment which promotes their health rather than threatening it. Achieving good air quality requires strong action and commitment at EU level. The time to take this action is now. Each delay will result in additional unnecessary deaths, increased health impacts and suffering, and continued strain on healthcare budgets. Thank you in advance for your support. Yours sincerely, Jeremy Wates Secretary General, European Environmental Bureau (EEB) ON BEHALF OF: European Environmental Bureau - EEB Health and Environment Alliance - HEAL Air Pollution & Climate Secretariat – AirClim Client Earth Transport and Environment - T&E Greenpeace Friends of the Earth Europe - FoEE World Wild Fund for Nature Europe – WWF BirdLife Europe The European Public Health Alliance - EPHA The European Respiratory Society - ERS European Federation of Allergy and Airways Diseases Patients Associations - EFA Compassion in World Farming - CIWF European COPD Coalition – ECC European Academy of Allergy and Clinical Immunology - EAACI European Cyclists’ Federation - ECF EU Federation of Organic Agriculture Movements - IFOAM – EU Slow Food Change Partnership The Cancer Prevention and Education Society, UK Clean Air in London, UK Alliance for Cancer Prevention, UK Health Equalities Group – HEG, UK Royal College of Physicians, London, UK Naturschutzbund Deutschland - NABU, Germany Friends of the Earth Germany - BUND, Germany Deutsche Umwelthilfe - DUH, Germany Der Deutsche Naturschutzring - DNR, Germany Long fonds, Netherlands Milieu Defensie, the Netherlands Natuur en Milieu, Netherlands Leefmilieu, Netherlands MOBilisation for the Environment, Netherlands Vereniging Nederlands Cultuurlandschap, Netherlands Asthma and Allergies Association, France France Nature Environnement - FNE, France (1) In his speech at the Environment Council's debate on 16 December 2015, EU Environment Commissioner Vella estimated that every percentage change from the 52% health improvement target proposed by the Commission would result in around 4,000 additional premature deaths in the year 2030. The four percentage cut proposed by the Council is therefore estimated to cause around 16,000 additional premature deaths EU wide in the year 2030. (2) NGO comments about the different flexibilities proposed by the European Commission and the Council can be found here: http://www.eeb.org/index.cfm/librar...
04/02/2016	Open letter to national cancer organisations on World Cancer Day 2016 World Cancer Day 2016 An opportunity to prevent cancer by reducing environmental exposure to glyphosate I am writing to you today as President of the Health and Environment Alliance (HEAL) to ask for your leadership in a current opportunity to prevent cancer through more protective national and EU policies/laws. The Health and Environment Alliance (HEAL) is a leading European not-for-profit organisation addressing how the environment affects health in the European Union. With the support of more than 70 member organisations, HEAL brings independent expertise and evidence from the health community to different decision-making processes. To mark World Cancer Day 2016, we encourage you, as the president of an influential national cancer society, to call on your government for two actions on the chemical glyphosate. Glyphosate was recently classified as a probable carcinogen by the World Health’s Organization’s International Agency for Research on Cancer. (See overleaf for a summary of the scientific research.) Glyphosate is active ingredient in the most widely used herbicides in agriculture as well as public parks, school and hospital grounds, and private gardens, so people all over Europe are likely to be significantly exposed. (See overleaf for more details). We suggest that you write to your government and call for a national ban on glyphosate use in your country. In addition, we encourage you to call on your government to oppose the renewal of the authorisation for glyphosate in the EU and all EU member countries, which is to be decided before June 2016. On the following page, we summarise the state of the scientific research on glyphosate and the enormous usage of glyphosate. We would also like to draw your attention to the position of the French Cancer League on glyphosate, which called for a ban in April 2015, and various national control measures taken in response to the IARC finding (see overleaf). We believe that your leadership on this issue could significantly increase the chances of your national authorities banning this probable carcinogen, and of your government opposing the renewal of glyphosate’s authorisation at the EU level. Both of these concrete public health actions could contribute to reducing cancer risk. Public health and chemicals experts in the HEAL secretariat would be happy to provide you more information, answer any questions, and assist you in drafting the letter. For more information please contact the HEAL Secretariat, Ms. Génon K. Jensen, Executive Director (genon@env-health.org). We look forward to hearing you response. Yours sincerely, Dr Peter van den Hazel President, Health and Environment Alliance (HEAL) February 4th, 2016, Brussels BACKGROUND INFORMATION The scientific research Last year, IARC, the specialist cancer research body which advises the World Health Organization concluded that the herbicide glyphosate should be classified as "probably carcinogenic to humans". http://www.iarc.fr/fr/media-centre/... Reported in the leading international health journal, The Lancet, the Monograph assessing the carcinogenicity of the ingredients used in the herbicide was the work of a panel of 17 experts from 11 countries who met at the International Agency for Research and Cancer (IARC) in Lyon, France. They concluded that, “there was limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma”. The official document also said that: “One study in community residents reported increases in blood markers of chromosomal damage (micronuclei) after glyphosate formulations were sprayed nearby.” Widespread use The decision on glyphosate is a particular concern because it is very widely used. Glyphosate- containing herbicides are the most widely used herbicides in Europe and are applied in farming, forestry, parks, public spaces (including playgrounds and hospital grounds), and private gardens. The European Union does not publish data on the use of individual herbicides/pesticides in agriculture, making it difficult to find out how much glyphosate is being used by farmers. However, it is known to be the most commonly used herbicide in commercial fruit orchards in the UK for example. Glyphosate may be present in water; in food products such as milk and eggs, and meat cuts from animals – deriving from residues in their feed; and in grains, pulses (edible seeds, such as lentils), vegetables and fruits as residues from agricultural spraying. Many Europeans are likely to be significantly exposed to glyphosate. There are very few studies that actually examine glyphosate levels in humans, but a community biomonitoring study in 2013 showed that an average of 45% of urine samples from urban residents in 18 European countries contained glyphosate residues. The rates were highest in Malta, where 90% of urine samples were contaminated followed by Germany, UK and Poland where rates were 70%, Netherlands (63%), Czech Republic (60%), Belgium and Latvia (55%), Cyprus (50%), Spain and Croatia (40%), Hungary and France (30%). Real life conditions in which the spraying takes places may add to the hazards, particularly during hot weather. The label of the glyphosate-based weed killer recommends that the product is only used in good weather and in temperatures not exceeding 25 degrees Celsius. French control measures In April 2015, the French cancer league (la Ligue contre le cancer, 700,000 members) issued a statement calling on the French government to ban glyphosate and four other pesticides included in the IARC classification as soon as possible. In August 2015, la Ligue contre le cancer took a further step by launching a petition to prevent renewal of the licence for glyphosate by the European Union authorities. See https://www.ligue-cancer.net/articl... In June 2015, the French environment minister required French garden centres to stop sales of glyphosate to individuals unless a qualified vendor provides advice. Other national control measures The Netherlands banned private sales of herbicides containing glyphosate in 2014. German state consumer protection ministries have called for a ban, and some retailers in Germany have voluntarily taken glyphosate products off their shelves. The Danish Working Environment Authority (under the Danish Ministry of Employment) has followed the WHO/IARC decision and has now declared glyphosate a carcinogen. This will involve requiring changes in application practices, including recommendations to use alternative, less toxic chemicals. For public parks, school playgrounds and gardens HEAL advocates for the stop of spraying of any pesticides altogether. (see Roundup Listed Carcinogen by Danish Authority, SiS 67)
26/01/2016	Call on EP to reject real-world driving emissions proposal HEAL and other health and environmental groups urge MEPs to reject an implementing measure which would allow for greater NOx air pollution from cars, threatening efforts for cleaner air and better health in Europe. 18 January 2016 Dear MEP On behalf of the above organisations, we are writing to call on you to follow the recommendation of the Environment Committee and reject the implementing measure on the Real-world Driving Emissions (RDE) test in plenary vote on 19 January. This measure will de facto increase the existing Euro 6 limits for diesel NOx and thus undermine future efforts to clean up Europe’s air and improve public health. Air pollution is responsible for over 400,000 premature deaths in the European Union each year, causing health-related economic costs estimated between €330 and €940 billion annually (1). In October 2015 the Technical Committee of Motor Vehicles (TCMV) voted to allow Euro 6 diesel cars to emit over double the Euro 6 limit from 2017 to 2020, and 50% more after 2020. This would result in new diesel cars emitting up to 120 mg/km of NOx instead of the 80mg limit agreed back in 2007. This will lead to much slower improvements in air quality than required, having serious repercussions for public health, our environment and economy. The RDE proposal ignores the scientific advice of the Joint Research Centre of the maximum margin of error of ≤30% (2). It also ignores legislation agreed by MEPs in 2007 on Euro 6 NOx limits. The RDE proposal is a political decision to increase the agreed limits for diesel NOx emissions by half and through an implementing act ignoring primary legislation. Should MEPs allow the measure to go through, the only other possibility on the table to strengthen RDE is through annual reviews to bring the long-term conformity factor down to 1. However, the Commission has so far failed to provide any reliable commitment or outline plans to do so in the coming year. Air pollution has been proven to cause many cardio-vascular and respiratory diseases such as asthma, allergies, COPD and damaging effects on prenatal and early childhood development. Cities and regions rely heavily on Euro standards to reduce the shocking costs and health impacts of air pollution and to deliver improvements required by EU legislation, notably the Ambient Air Quality Directive (2008/50/EC). However, it is widely acknowledged that previous standards have failed to address NOx emissions in urban areas, which has prolonged NO2 exceedances in many cities across Europe. RDE is an essential tool to address this problem and we know it works when it is implemented effectively. The introduction of RDE into the approval of new Euro VI heavy duty diesel engines has led to substantial improvements in NOx emissions in urban conditions (3). Unfortunately, the current agreement sets out to undermine this tool and subsequently delay and weaken Euro 6 limits for light-duty vehicles. This is unacceptable given that many cities and regions across the EU are in breach of air quality standards and facing infringement procedures. We call on you to support the Environment Committee and reject the RDE implementing measure in your vote on 19 January 2016. This would send a clear message to the Commission and the Member States to come back with a better agreement by spring 2016 at the latest, so that diesel cars on EU roads can finally be as clean as intended in the Euro 6 legislation. Given that all the ground work for the new RDE test is already in place – on-road tests for monitoring purposes begin already this year – there is no reason why a more ambitious implementation of RDE cannot be agreed in a few months’ time. Yours Sincerely, Anna Lisa Boni, EUROCITIES Secretary General Assumpta Farran i Poca, Director-General for Environmental Quality, Ministry for Territory and Sustainability, Catalunya Prof. Bert Brunekreef, ERS Environment and Health Committee Chair Génon K. Jensen, HEAL Executive Director Jeremy Wates, EEB Secretary General Jos Dings, Transport & Environment Executive Director Karen Vancluysen, Polis Secretary General Mariëtte Pennarts-Pouw, Executive of the province of Utrecht on behalf of the Randstad Region Matthew Farrow, EIC Executive Director Matthew Pencharz, Deputy Mayor for Environment & Energy, Greater London Authority Sources: (1) European Commission Impact Assessment, Clean Air Package http://ec.europa.eu/environment/air... (2) https://circabc.europa.eu/d/a/works... 9410827c4f87/2015_10_01_Error_analysis_JRC.pdf (3) https://www.london.gov.uk/sites/def... _
08/01/2016	Joint Open letter on ECJ Ruling on EDC Criteria Four leading European health and environment organizations urge the European Commission to take action following European Court ruling on hormone disrupting chemicals. Addressed to: President Juncker First Vice President Timmermans, Commissioners Andriukaitis and Vella Concerns: Open letter on ECJ Ruling on EDC Criteria 8 January 2016, Brussels Dear President Juncker, On December 16, 2015 the General Court ruled in case T-521/14 Sweden vs. Commission that the European Commission has violated EU law by failing to adopt measures concerning the specification of scientific criteria for the determination of endocrine-disrupting properties according to Regulation No 528/2012 concerning the placing on the market and use of biocidal products. We have for several years now argued that the Commission’s decision to carry out an impact assessment in relation to the adoption of the scientific criteria is inappropriate and have urged the Commission to promptly publish the criteria. This view is also shared by EDC-Free Europe coalition which brings together over 60 health, environmental and consumer groups, campaigning to reduce exposure from endocrine-disrupting chemicals. Thus, we were astonished to hear the first reaction of the Commission’s spokesperson to the Court’s ruling which implies that the Commission has no intention of complying with the law. This apparent disregard for a court decision is even more disappointing given the Commission’s role as guardian of the Treaties. The political consequences for the EU of a European Commission that would effectively be placing itself above the rule of law, in particular at a time of growing Euroscepticism, is worrying. If the Commission were to continue with this approach, it would link its ‘Better Regulation’ agenda to not only a willful delay of urgently needed regulatory action to protect Europe’s citizens’ health from hormone disrupting chemicals but now also to a blatant violation of the law. Justifying such a course of action on the basis of Europe’s need for jobs and growth is also inappropriate, as the health costs of diseases related to EDC exposure in Europe are estimated to be over 150bn Euro annually – an estimate which is likely to be an underestimate and represent only a subset of the true costs – and most of these costs are derived from health impacts from pesticides. We therefore urge you to urgently proceed with the following two courses of action: The immediate adoption of the scientific criteria in accordance with the Commission draft recommendation of June 2013. A review of the Commission’s use of impact assessments and the extent to which this is causing unnecessary delays in regulatory action and feed this into a wider overhaul of the Commission’s ‘Better Regulation’ agenda. Given the public interest in the matter we will make this letter publicly available. Yours sincerely, Jeremy Wates, Secretary General EEB Genon Jensen, Executive Director HEAL Michael Warhurst, Executive Director CHEM Trust François Veillerette, President of the Board of Pesticide Action Network
15/12/2015	Joint letter to EU Commission: The EU and its Member States should rapidly ratify the Minamata Convention on mercury
14/12/2015	Joint letter: Public Health recommendations for strong National Emission Ceiling (NEC) Directive
11/12/2015	Joint letter: MEPs urged to reject new test on real-world driving emissions
13/11/2015	18 NGOs Co-Sign Letter to MEP regarding Upcoming Medical Device Regulation Negotiations
13/11/2015	30 NGOs call for partial glyphosate ban
09/11/2015	Joint letter: Dieselgate - EU action to protect citizens from air pollution and the manipulative and fraudulent behaviour of carmakers Health and Environmental organisations urge for EU action to protect citizens from air pollution and the manipulative and fraudulent behaviour of carmakers Addressed to: Donald Tusk, President of the European Council Jean-Claude Juncker, President of the European Commission Martin Schulz, President of the European Parliament Monday 9 November 2015 Concerns: Dieselgate - EU action to protect citizens from air pollution and the manipulative and fraudulent behaviour of carmakers Dear President, We write in connection with the revelations and wider implications of the dieselgate emissions scandal and to express our objections to recent decisions to more than double the emission limits for cars tested on the road. Volkswagen – and very likely other companies - have intentionally misrepresented and manipulated data for years to undercut standards which were put in place to protect our health and the environment. NGOs and other experts have repeatedly warned about major flaws in the way national and EU institutions test, monitor and enforce compliance with emission standards. National and European institutions have also been aware of the problem for years. The scandal is symptomatic of a ‘better regulation’ agenda in favour of cutting compliance costs and replacing the role of the public regulator with corporate co- and self-regulation. Over the past decade, this approach has favoured a climate in which rules that protect the public interest are considered as burdens rather than investments. Yet, the dieselgate scandal, caused by a will to cut compliance costs, shows that the human and economic consequences of weak rules and lenient enforcement of environmental laws are enormous. Over 400,000 people die prematurely each year in Europe because of polluted air. This requires a fundamental re-think of the way in which European and national institutions, including the European Commission, legislate and enforce environmental, consumer and health standards, and engage with vested interests. Specifically, the EU must urgently improve its capacity to protect European citizens from air pollution and the fraudulent behaviour of companies, and reorient the better regulation agenda. The European car industry has been successfully flexing its lobbying muscles for decades: in the mid-90s it lobbied against binding CO2 emissions targets, instead proposing a voluntary scheme. Unsurprisingly, the scheme failed. Binding emission limits were introduced a decade later, and yet again carmakers lobbied successfully to have the limits watered down. The same failures are now being repeated in relation to emission standards for lorries and in current negotiations on testing regimes and car type approval. As a major EU lobbyist, Volkswagen has for a long time benefited from privileged access and a significant influence on the policy process, also thanks to its membership of five Commission advisory groups, and industry lobby group ACEA (Association des Constructeurs Européens d'Automobiles). The impact of corporate lobbying on air quality is not limited to the automobile industry. For instance, in April, NGOs highlighted the systematic infiltration by the energy industry of EU regulatory processes to set emission standards for power plants. The consequence is that EU emission limits for coal plants are likely to fall behind existing standards in China and the United States. We therefore urge you, your institutions and national governments to take immediate action to respond to the dieselgate scandal. We call on you to: 1. Undertake an immediate, independent and transparent EU-level investigation into the dieselgate scandal, including a full review of the rules and regulatory mechanisms that failed to prevent Volkswagen’s manipulations, excessive emissions, and misuse of public funds. The investigation should also compile and interpret the findings of all national authorities and prosecutors on the fraudulent behaviour of Volkswagen and, if relevant, other car-makers. 2. Establish EU oversight in the process of type approval for motor vehicles. The existing procedure whereby national agencies oversee and undertake EU-wide type approval has failed. 3. Strengthen the enforcement of environmental legislation at EU and Member State level, including by equipping public environmental inspectorates with the mandate and powers to protect public health and the environment and improving market surveillance under the recently-unveiled internal market strategy. 4. Ensure that fraudulent companies are suspended from the EU lobby register until it has been demonstrated that they comply with EU law, and consequently decline meetings between the companies and the EU institutions unless the meeting directly concerns an investigation. Volkswagen’s membership in Commission expert groups and advisory bodies should also be suspended. We will closely monitor progress in all four areas and look forward to hearing from you about the actions you and your institution will take. For any further correspondence, please contact: Jorgo.Riss@greenpeace.org; +32 (0)2 274 19 07; Greenpeace, Rue Belliard 199, 1040 Brussels Yours sincerely, Birdlife Europe, CEE Bankwatch Network, CAN Europe, Corporate Accountability International, Corporate Europe Observatory (CEO), European Coalition for Corporate Justice, European Environmental Bureau, European Public Health Alliance, Food & Water Europe, Friends of the Earth Europe, Greenpeace European Unit, HEAL, Maison du Peuple d’Europe, Naturefriends International, Open Knowledge, Spinwatch, Governance Project Transnational Institute, European Federation for Transport and Environment, WECF International, WWF European Policy Office, Austrian Doctors for the Environment (AeGU, ISDE) & Institute for Environmental Health, Medical Uni. of Vienna, Berne Declaration, Center for Environment/FoE Bosnia and Herzegovina, University Hospital, Clean Air Action Group Hungary, Confederación de Ecologistas en Acción, Council for Sustainable Transportation, GLOBAL 2000 / Friends of the Earth Austria, GONG (Croatia), Longfonds (Lung Foundation, Netherlands), Milieudefensie/Friends of the Earth Netherlands, Mouvement Ecologique (Luxembourg), EAPN Romania / Reţeaua Naţională Antisărăcie - Includere Socială (Renasis), Pravno-informacijski center nevladnih organizacij – PIC, Pro Natura / Friends of the Earth Switzerland, Romanian Association of Human Resources Specialists (AUR), Werkstatt Ökonomie e.V., Young Friends of the Earth Ireland, Zelena akcija Friends of the Earth Croatia New signatories since 9 November: European Federation of Road Traffic Victims (FEVR), European Lung Foundation (ELF), European Respiratory Society (ERS), Fédération Française Union Touristique les Amis de la Nature (FFUTAN), Naturefriends Greece, Nivon Natuurvrienden.
23/10/2015	Open letter to MEPs - Call for clean air Next Wednesday MEPs have the unique opportunity to set the European Union on track for clean air and save literally tens of thousands of European lives each year. This is our call for clean air - everywhere - for European citizens. 23 October 2015 Dear Member of the European Parliament, Clean air – everywhere – for European citizens! Next Wednesday you have the unique opportunity to set the European Union on track for clean air and save literally tens of thousands of European lives each year. Air pollution continues to cause significant damage to health, harms our natural environment, makes it more difficult to protect our cultural heritage and buildings, hampers economic productivity, lessens the quality of life in Europe’s cities, and much more. It is estimated that the health costs from air pollution alone amount to 330 – 940 billion EUR a year. Over 400,000 people die prematurely each year because of polluted air. You can change this. Please follow the recommendations from your colleagues of the Committee on Environment, Public Health and Food Safety on the National Emissions Ceilings Directive (NEC), who supported strengthening the modest proposal from the EU Commission. Up to 42,865 additional European lives could be saved each year compared to the original EU Commission proposal if the ENVI position was followed, within the same cost range as calculated by the EU Commission. So greater health benefits at low cost. Given the severity and pervasiveness of the air pollution problem, all sectors of our economy need to take their fair share in cleaning up Europe’s air. The recent VW emissions scandal showed that greater regulatory action and scrutiny is needed, such as a swift entry into force of the new Real-World Driving Emissions (RDE) test and establishing an EU Type-Approval Authority to ensure car testing is robust and done independently. The VW scandal also showed the pitfalls of allowing industry groups to have too much influence over legislation. Don’t give in to calls from large scale industrial farms who want preferential treatment. Agriculture is responsible for over 90% of ammonia and 50% of methane emissions and only achieved slight reductions in the last years, even though cost-effective technical solutions are available. Why should the laggards be rewarded? Please hear the citizens’ call for cleaner air – everywhere. For more information see here: Via EEB website: NGO recommendations on the revision of the NEC directive following the publication of the rapporteur’s draft report Via HEAL website: Environment NGOs recommendations on the revision of the NEC directive following the publication of the rapporteur’s draft report and Health NGOs recommendations on the revision of the NEC directive following the publication of the rapporteur’s draft report Thanks you in advance for your support, Yours sincerely, Anne Stauffer Deputy Director, Health and Environment Alliance (HEAL) ON BEHALF OF: European Environmental Bureau (EEB) Transport and Environment (T&E) European Academy of Allergy and Clinical Immunology (EAACI) European Chronic Obstructive Pulmonary Disease Coalition (COPD) European Federation of Allergy and Airways Diseases Patients Associations (EFA) European Public Health Alliance (EPHA) Air Pollution & Climate Secretariat (AirClim) Client Earth
08/09/2015	Open letter to Commissioner Vella to ban the recycling of materials containing toxic flame retardants HEAL supports an open letter to the EU Commission, sent by the Centre for International Environmental Law, the European Environmental Bureau, Women in Europe for Common Future and IPEN, calling to ban the recycling of materials containing toxic flame retardants. HEAL supports an open letter to Karmenu Vella, EU Commissioner for Environment, sent by the Centre for International Environmental Law, the European Environmental Bureau, Women in Europe for Common Future and IPEN, calling on the EU Commission to ban the recycling of materials containing toxic flame retardants. The letter, supported by a host of NGOs and public interest groups worldwide, highlights the need to stop DecaBDE, reappearing in recycled products. DecaBDE is a toxic flame retardant mainly used in plastics for electronic and electrical equipment and in textiles. The substance is bioaccumulative, meaning it accumulates in living organisms and persistent, thereby staying in the environment for years. It also has potential adverse effects on human and animal hormone, reproductive, and nervous systems. The issue will be addressed by both the European Chemicals Agency (ECHA) in September and the Stockholm Convention POPs Review committee in October this year. The letter is available here
04/09/2015	Civil society organisations ask G20 Finance Ministers to phase-out fossil fuel subsidies In the lead-up to the G20 Summit in November, 66 civil society organizations, including HEAL, are calling on the G20 finance ministers and the Turkish G20 Presidency to advance commitments to phase out fossil fuel subsidies and support ambitious climate action toward a global climate deal at the COP21 climate negotiations in Paris this December. In the lead-up to the G20 Summit in November, 66 civil society organizations, including HEAL, are calling on the G20 finance ministers and the Turkish G20 Presidency to advance commitments to phase out fossil fuel subsidies and support ambitious climate action toward a global climate deal at the COP21 climate negotiations in Paris this December. Earlier this year, the G7 acknowledged the need to decarbonize the global economy over the course of this century. To meet this ambitious objective, it is clear that the vast majority of known fossil fuel reserves will have to stay in the ground. The G20 bears the capacity and responsibility to display strong global leadership, and follow suit of the G7 to incite clear action towards decarbonisation and climate ambition in advance of the global climate summit in Paris. The civil society organisations are calling on the G20 to deliver on the following issues: Implementation of the G20 commitment to end inefficient fossil fuel subsidies. Agreement to end public finance for coal. Progress on delivering climate finance needs. Read the full letter here. The Turkish government should particularly hear this call for a healthy energy future. Under their national energy strategy, about 80 new coal-fired power plants are in the pipeline, making Turkey the 3rd largest country of coal investments, after China and India. A recent report by the International Institute for Sustainable Development found that the Turkish government continues to subsidise coal investments. In 2013, the amount of public financing was 730 million US-$. The Turkish government also plans to turn the existing coal power complex of Afsin-Elbistan into the biggest plant of the world. A recent HEAL assessment showed that there is already a heavy health toll from existing coal power plants in Turkey, with health costs up to 3.6 billion EUR per year.
14/07/2015	MEPs put health first in key air vote HEAL welcomes today’s vote in the European Parliament’s Committee on Environment, Public Health and Food Safety on the new EU National Emissions Ceilings Directive (NEC). Press statement Brussels, 15 July 2015 – HEAL welcomes today’s vote in the European Parliament’s Committee on Environment, Public Health and Food Safety on the new EU National Emissions Ceilings Directive (NEC). The NEC is a key law to improve air quality in Europe, as it is the only instrument tackling cross-border air pollution, and implementing the EU’s international commitments under the UN Convention on Long-Range Transboundary Air Pollution. The new NEC will set limits for emissions of the major air pollutants including particulate matter, sulphur dioxide, nitrogen oxides, volatile organic compounds, ammonia and methane. “Air pollution continues to be a major health and environmental threat in Europe, with 430,000 early deaths each year and huge health economic costs” , says Anne Stauffer, Deputy Director of HEAL. She adds “Today’s vote is therefore welcome news for all those suffering from heart and lung disease and parents concerned about the health of their children. The emission cuts foreseen in the NEC will also help to bring down healthcare costs and boost workers productivity. With today’s vote, MEPs have put health first, in light of heavy lobbying from the agricultural sector and industry. We are particularly pleased that they insist on tackling emissions of mercury, a highly toxic heavy metal, which threatens the healthy development of our children. European Parliamentarians gave the clear signal that efforts for cleaner air need to be strengthened, and that this also includes bringing down ammonia and methane emissions.” HEAL calls on all Members of the European Parliament to follow the EP’s Environment Committee’s health-first position for the plenary vote in Autumn. In the text adopted today by the Environment Committee, the pollution targets are more stringent than in the Commission’s original proposal. The targets for 2025 have also become binding when they were only indicative originally, and mercury has been added as one of the pollutants covered by the directive. ENDS Joint NGO recommendations for clean air Ahead of the vote, over sixty health, environmental and animal welfare organisations including HEAL urged MEPs to stand for ambitious EU action that will benefit people’s health, environment and the economy - see recommendations below. 14 July 2015 Dear Members of the EP's Committee on Environment, Public Health and Food Safety, On 15 July 2015, you will vote on Julie Girling's report concerning the revised National Emission Ceilings (NEC) Directive. On behalf of a coalition of over sixty health, environmental and animal welfare organisations, we urge you to stand for ambitious EU action that will benefit people's health, environment and the economy. Every year, over 400,000 Europeans die prematurely because of air pollution. Bad air quality causes severe illnesses such as cardiovascular and respiratory disease, aggravation of asthma and chronic obstructive pulmonary disease (COPD), harms to children's healthy development and is a risk factor for diabetes. The health-related economic costs of air pollution are enormous, amounting to between 330 billion and 940 billion EUR for the EU in the year 2010 alone. This is equivalent to between 3 and 9 percent of the EU's GDP. Air pollution also impacts Europe's nature and biodiversity, agricultural yields and natural vegetation. Crop yield losses due to air pollution are estimated at 3 billion EUR per year in 2010. More ambition is necessary, possible and cost-effective. The Commission's proposal to revise the NEC Directive is very welcome but far from sufficient to solve Europe's air quality problems. The European Parliament's impact assessment shows that the new EU climate and energy policy agreed by the Council in October would lead to significant air quality improvements for costst that are lower than in the initial Commission proposal. We therefore call upon you to support: 1. Binding and ambitious emission reduction commitments for 2025 2. Ambitious emission reduction commitments for 2030 3. Ammonia emission reduction commitments 4. Methane emission reduction commitments 5. Mercury emission reduction commitments 6. Deletion of flexibilities 7. Effective national air pollution control programmes (NAPCPS) 8. Access to justice and public participation and information. The full list of NGO recommendations can be found in the letter here Useful resources 15 July 2015: EEB Press release - European Parliament votes for a breath of fresh air 11 June 2015: HEAL in Poland calls on Ministry of Environment for stronger support of NEC Directive 13 April 2015: Achieving better air quality with the NEC
10/06/2015	Letter to Commissioner Šefčovič: Health benefits of Serbia’s climate mitigation ambition
05/06/2015	HEAL signs joint NGO letter on glyphosate Several environmental and health NGOs have sent a letter to the European Commission, calling for a serious discussion on the use of glyphosate in the EU. In a joint letter to the European Commission, HEAL, Greenpeace, the Alliance for Cancer Prevention, Friends of the Earth Europe, and Pesticide Action Network Europe have asked for an informed debate on the use and glyphosate in Europe. The letter addresses their concern regarding the scope of the European Commission's request to the European Food Safety Agency (EFSA) to investigate the carcinogenic potential of glyphosate. Glyphosate is used in a large number of weedkillers. The International Agency for Research on Cancer (IARC) has classified the substance as "probably carcinogenic to humans". Read the letter here.
13/05/2015	Over 100 NGOs call for full lobby transparency Over 100 NGOs including HEAL, and trade unions from across Europe, call on the EU Commission to take strong and urgent action to create a high-quality and legally-binding EU lobby transparency register. To: Mr Frans Timmermans Vice President European Commission 11 May 2015 Over 100 NGOs including HEAL, and trade unions from across Europe, support the European Parliament Intergroup on Integrity and call on the EU Commission to take strong and urgent action to create a high-quality and legally-binding EU lobby transparency register. Lobby transparency is vital to reduce unethical lobbying and also to begin to ensure a better balance between corporate and public interest groups in the access to, and influence they have on, decision-making processes. The NGOs and Trade Unions welcome the steps the Juncker Commission has taken to increase lobby transparency at the European level, but the EU lobby register still has major weaknesses. Read the full letter here
20/04/2015	Achieving better air quality with the NEC The European Parliament’s Committee on Environment and Public Health (ENVI) has started to discuss their position on further air pollutant reductions under the National Emissions Ceilings (NEC) Directive. HEAL together with other groups urged MEPs to increase the ambition of the draft law. The European Parliament’s Committee on Environment and Public Health (ENVI) has started to discuss their position on further air pollutant reductions under the National Emissions Ceilings (NEC) Directive. HEAL together with other groups urged MEPs to increase the ambition of the draft law. Every year, over 400,000 Europeans die prematurely because of air pollution. Poor air quality also makes Europeans sick and significantly reduces their quality of life, in particular in cities. Increased illness, hospital admissions, extra medication and millions of lost working days are very costly for the European Union - the health-related costs of air pollution amounted to between €330 billion and €940 billion in 2010 alone, which is equivalent to between 3 and 9% of the EU’s GDP. This includes €15 billion in direct costs from lost workdays and €4 billion from treatment of chronic bronchitis. Air pollution also causes great harm to Europe’s nature, crop yields, buildings and monuments. On 13 April, the European Parliament's ENVI Committee discussed the draft report “Reduction of national emission of certain atmospheric pollutants and its amending directive” by MEP Julie Girling. On this occasion, many health, environmental and civil society groups across Europe voiced their recommendations on the proposed revised NEC directive. In one letter, health NGOs including HEAL, the European Federation of Allergy and Airways Diseases Patients Associations (EFA), the European Public Health Alliance (EPHA), and the European Respiratory Society (ERS) stated: "As healthcare professionals, patients, scientists, and public health advocates concerned with health and environmental protection, we write to you on behalf of the 400,000 Europeans whose premature deaths are caused each year by air pollution in Europe, and all those suffering from ill-health linked to air pollution to call on you to put public health considerations first in the political debate". In a second letter, a group of environmental NGOs including HEAL, AirClim, Client Earth, the European Environmental Bureau (EEB) and Transport & Environment (T&E) highlight the current lack of ambition of the proposed revised NEC Directive. In light of the essential health, environmental and economic benefits that could result from a more ambitious NEC directive, the NGOs call upon the Members of the ENVI Committee to support: 1. Significantly stricter emission reduction commitments for 2025 and 2030: the ambition level should ensure the achievement of WHO recommended levels by 2030, therefore helping the European Union to reach its long-standing aim of achieving “levels of air quality that do not give rise to significant negative impacts on, and risks to human health and environment”, an aim which is enshrined in the EU’s 7th Environmental Action Programme. A recent European Parliamentary Research Service’s impact assessment also demonstrates that more ambition is possible and can be achieved at the same or lower cost (1). The data provided by the European Parliament’s impact assessment study provide a good basis for improvement. 2. Stricter emission reduction commitments for 2020, based on the most recent baseline figures and establishing a linear pathway towards the achievement of the 2025 and 2030 commitments. 3. Legally binding emission reduction commitments for 2025 for all pollutants covered by the directive. 4. Legally binding emission reduction commitments for methane and mercury for all three targets years (2020, 2025 and 2030): currently, methane reductions targets are set only for 2030, despite the fact that methane contributes to toxic ground-level ozone, while mercury is left out of the Commission’s proposal despite being a toxic and highly trans-boundary pollutant causing great damage to health and ecosystems. 5. The rejection of flexibilities such as adjustment of emission inventories and offsetting of emissions between land and sea.
17/04/2015	Joint open letter: TTIP blocking urgently needed reforms in food safety, farm production, workers’ rights and animal welfare
08/04/2015	Joint letter to Commissioner Andriukaitis: EU response to WHO cancer determination of glyphosate
03/03/2015	Joint letter: For a TTIP resolution that puts people, the environment and democracy before short-term HEAL has joined other civil society organisations from across Europe to call on Members of the European Parliament to protect the environment and health of its citizens as it drafts its opinion on the TTIP (Transatlantic Trade and Investment Partnership) talks. In light of the European Parliament’s ongoing work on a resolution on the Transatlantic Trade and Investment Partnership (TTIP), today 375 civil society organisations including HEAL, wrote an open letter to MEPs warning that TTIP could constrain democratic decision-making by strengthening the influence of corparate interest and undermining public services, the protection of public health, the environment, and human rights. The civil society organisations welcome the fact that the European Parliament is forming its opinion on the TTIP and the role that the Parliament has already played in organising democratic public debates on the issue. But they are calling on all MEPs to agree on a strong resolution that makes clear that the European Parliament will reject any future trade or investment agreements that will not serve the public interest and threaten important rights acquired in long democratic struggles in the EU, US and the rest of the world. The open letter outlines the key demands from civil society on the TTIP negotiations, which were developed together with partners in the US and were first released in a joint civil society statement in May 2014 The letter is available in English with all the signatures and in French, German, Dutch, Spanish, Greek, Danish, Italian, Slovenian, Bulgarian and Portuguese):
29/01/2015	NGOs call on EU Commission to end public export credits for coal
13/01/2015	Call to MEPs to continue air quality negotiations Leading health, environmental, lawyers’ and civil society organisations from all over Europe urge EU-Parliamentarians to adopt a joint resolution asking for the ongoing negotiations on the draft Directive on National Emissions Ceilings (NEC) to continue. Leading health, environmental, lawyers’ and civil society organisations from all over Europe urge EU-Parliamentarians to adopt a joint resolution asking for the ongoing negotiations on the draft Directive on National Emissions Ceilings (NEC) to continue. HEAL, EEB, Transport&Environment, ClientEarth, European Public Health Alliance (EPHA), European Respiratory Society (ERS), European Association of Allergy and Airways Disease Patients Associations’ (EFA) and AirClim have written to all members of the European Parliament to urge them to adopt a joint resolution this Thursday asking for the ongoing negotiations on the revised Directive on National Emissions Ceilings (NEC) to continue and not be delayed. Read the letter here.
11/12/2014	Green 10 open letter on possible withdrawal of air and waste proposals and absence of sustainability The 10 leading environmental NGOs in Europe, the Green 10, have written an open letter to Vice President Timmermans expressing their grave concerns that environmental protection and sustainability is not only going to be absent in the Commission’s Workplan for 2015. The 10 leading environmental NGOs in Europe, the Green 10, have written an open letter to Vice President Timmermans expressing their grave concerns that environmental protection and sustainability is not only going to be absent in the Commission’s Workplan for 2015. Instead the EU Commission is are even planning to withdraw two recently proposed pieces of legislation that would bring major benefits for citizens’ health, the environment as well as for Europe’s economy – the air package and circular economy package. Read the open letter here The members of the Green 10 are: BirdLife Europe (current chair) Climate Action Network (CAN) Europe CEE Bankwatch Network European Environmental Bureau (EEB) Friends of the Earth Europe (FoEE) Greenpeace European Unit HEAL Naturefriends International Transport and Environment (T&E) WWF European Policy Office
04/12/2014	Civil Society view regarding pending EU legislation 2014 – response to BusinessEurope 20 organisations representing diverse public interest groups including HEAL, strongly oppose the worrying deregulatory tendency under the headline of ‘cutting red tape’. 20 organisations representing diverse public interest groups including HEAL, strongly oppose the worrying deregulatory tendency under the headline of ‘cutting red tape’. With an open letter to the EU Commission, these organisations specifically respond to the statement issued by BusinessEurope on 25th November under the heading ‘Business input to the screening exercise by EU Commission Vice-President Timmermans. Read the open letter here Read an Euractiv article here
27/11/2014	Joint open letter for the Canadian government to ban triclosan
25/11/2014	Letter to EC Vice President Katainen: Civil society organisations ask Commission to reject authorisation of hazardous DEHP in PVC plastic
20/11/2014	Open letter to EC President Juncker: Protecting public health from hormone disrupting chemicals 19 health and environment organisations, doctors, scientists, and concerned professionals of the EDC-Free Europe campaign, have sent a letter to EU Commission President Juncker urging him to ensure that the EU Commission takes clear action to minimise out multiple daily exposures to harmful hormone disrupting chemicals. Brussels, 20 November 2014, 19 health and environment organisations, doctors, scientists, and concerned professionals of the EDC-Free Europe campaign (of which HEAL acts as the campaign Secretariat), wrote to the President of the European Commission Juncker (right) urging him to ensure that the EU Commission takes clear action to minimise out multiple daily exposures to harmful hormone disrupting chemicals. This would ensure that the EU creates lasting benefits for productivity and health budgets by reversing chronic diseases related to endocrine disrupting chemicals (EDCs). You can download the letter here with the 19 signatories
18/11/2014	Health groups express dismay at potential withdrawal of EU Clean Air Policy Package Public health, patients', and medical organisations have sent a letter to EU Commission President Juncker expressing their dismay at any consideration to withdraw the EU Clean Air Policy Package, as presented by EU Environment and Health Commissioners Potocnik and Borg in December 2013. Brussels, 18 November 2014, Today, public health, patients', and medical organisations sent a letter to EU Commission President Juncker expressing their dismay at any consideration to withdraw the EU Clean Air Policy Package, as presented by EU Environment and Health Commissioners Potocnik and Borg in December 2013. The letter calls on President Juncker to keep the proposal and work with the European Parliament and Council to ensure a swift and ambitious adoption. You can download the letter here The letter was initated by the European Respiratory Society (ERS) and the European Federation of Allergy and Airways Diseases Patients' Associations (EFA) and HEAL. The following health groups signed on to the letter: European Public Health Alliance (EPHA) Standing Committee of European Doctors (CPME) European Lung Foundation (ELF) European COPD Coalition (ECC) European Academy of Allergy & Clinical Immunology (EAACI) European Kidney Health Alliance (EKHA) International Network on Children’s Health, Environment and Safety (INCHES) Royal College of Physicians North of England EU Health Partnership The Cancer Prevention & Education Society (CPES), UK Longfonds, Netherlands Leefmilieu (Human Environment), Netherlands Alborada Foundation, Spain Spanish Association of Environmental Education (Asociación Española de Educación Ambiental) Action for Breast Cancer Foundation, Malta WECF - Women in Europe for a Common Future, The Netherlands, France and Germany
17/11/2014	Joint letter to EU Commission on air package withdrawal
16/10/2014	Green 10 open letter to EC President Juncker
16/10/2014	Green 10 open letter to EP President Schulz
01/10/2014	Open letter to new Polish Prime Minister on air pollution In an open letter to the new Polish PM Ewa Kopacz (left), HEAL, together with leading health and medical experts in Poland, call to protect the health of citizens from harmful air pollution in Poland. On the day when Ewa Kopacz was sworn in as the new Polish Prime Minister, HEAL in Poland sent her an open letter about air pollution and its negative impact of human health in the country. The letter, co-signed by eight high-level medical and health experts, including the National Consultant of environmental health, and professors of allergology and epidemiology of non-communicable diseases, called to take decisive action to improve air quality in Poland and therefore the health of its citizens. Air pollution in Poland is responsible for 45,000 early deaths each year, and 97 percent of the Polish population breathe in air that is considered harmful to health by the WHO. Six out of ten of the most polluted cities in Europe are located in Poland. Co-signers of the letter show how air pollution in Poland not only brings huge individual suffering and high costs for the medical sector, but it is also an obstacle to economic growth, through productivity loss due to illness. According to a recent Eurobarometer survey, air pollution is currently the top environmental worry of European citizens. The letter expresses hope that the new Prime Minister (a previous Minister of Health in the Polish Government), will put the protection of children and families as a priority, supporting the necessary air quality policy changes at the European level and initiating further measures to curb air pollution from all sources in Poland. This would also answer to the recent local initiatives working to improve air quality, in light of missing national legislation. Download the letter in Polish here Media coverage in Poland: 97% Polaków oddycha szkodliwym powietrzem Ekolodzy: Ewa Kopacz powinna działać na rzecz czystszego środowiska List otwarty do premier Kopacz – czyste powietrze priorytetem dla Polski
29/09/2014	Green 10 open letter to Frans Timmermans, designated Vice-President for Better Regulation
16/09/2014	Joint open Letter to President-elect Juncker on the move of pharmaceuticals and medical devices
12/09/2014	Green 10 open letter: New Commission sidelining environment
19/08/2014	Joint letter on the position of Chief Scientific Advisor to the President of the EU Commission Today NGOs including HEAL sent a letter to the newly elected President of the EU Commission Mr Jean-Claude Junker urging that the position of Chief Scientific Adviser to the President of the EU Commission is not renewed in the new Commission. The group of NGOs including HEAL, HEAL members Réseau Environnement Santé (RES), The Cancer Prevention and Education Society, Pesticide Action Network Europe and other organisations including Greenpeace, Corporate Europe Observatory, Earth OpenSource and Sciences Citoyennes sent a letter to the new President of the EU Commission expressing their concern regarding the position of Chief Scientific Advisor to the President of the EU Commission. This post was created by Commission President Barroso whereby its mandate is “to provide independent expert advice on any aspect of science, technology and innovation as requested by the President”. In contrast to wishes for the position to be upheld, these organisations urge for the position to not be renewed. The post of Chief Scientific Adviser is problematic as it concentrates too much influence in one person, and undermines in-depth scientific research and assessments carried out by or for the Commission directorates in the course of policy elaboration. The full letter is available here
22/07/2014	NGO letter on ECHA consumers right to know video Environmental and health organisations including HEAL sent a letter to Geert Dancet, Executive Director of the European Chemicals Agency (ECHA) to express their appreciation of the ECHA video 'The price you pay' launched recently. On 17 July environmental and health organisations including HEAL sent a letter to Geert Dancet, Executive Director of the European Chemicals Agency (ECHA) to express their appreciation of the ECHA video 'The price you pay' launched recently. The video contributes to raising awareness of European citizens of substances of very high concern present in consumer articles and products and to enhance the consumers' right to know guaranteed by the REACH regulation. You can watch the video here The video enables citizens to be more aware of the risks linked to hazardous chemicals to which they are exposed and provides for informed purchasing decisions towards safer consumer articles. However, the NGOs do think the video could go further by making ECHA's 'chemicals in our life' page even more informative and helpful for consumers. ECHA could develop its own model letter in order to encourage European citizens to exercise their right to know according to REACH and they could even go beyond the video by giving concrete examples of controversial chemicals, where they are found and how they could be avoided by people who may not want to expose themselves to them. You can download the full letter here.
10/07/2014	Joint letter on regulating chemicals in TTIP
14/05/2014	Request for internal review of the Bulgarian Transitional National Plan
11/04/2014	Joint letter from NGOs to Chancellor Merkel on EU 2030 Climate and Energy package
01/04/2014	Request for internal review of the Polish Transitional National Plan
16/12/2013	Joint letter on opposition to include ISDS in Trans-Atlantic Trade and Investment Partnership (TTIP)
13/12/2013	Joint letter on proposed Non Road Mobile Machinery legislation
12/12/2013	Joint letter to EU Commissioners: Revision of Thematic Strategy on air pollution On 17 October HEAL signed a joint letter with environmental and citizens organisations to urge the EU Commission to adopt an ambitious package for cleaner air in the EU. In particular, we call upon the EU Commission to support: Ambitious emission reduction commitments for 2020 and 2025 in the revised Nation Emissions Ceilings (NEC) Directive. The level of ambition should go much beyond the 2020 Gothenburg Protocol and lead to the achievement of the 6th and 7th Environmental Action Programmes’ objectives for air quality by 2030 at the latest. Specific legislation to cut emissions from all major sources. Urgent action is needed to cut emissions from sectors such as small and medium scale combustion, agriculture, transport (road, non-road and shipping) and solvent use. Such sector-specific legislation is absolutely critical to actually decrease the levels of pollution and help Member States to comply with ambient air quality standards (Directive 2008/50/EC). Implementation, enforcement and strengthening of current EU air quality standards in light of the most recent WHO recommendations and health research results. Currently, the health standards for fine particles (PM2.5) are much too high to adequately protect Europeans’ health. Delaying action would be unacceptable given the costs of air pollution for Europe. We therefore ask for your support and help to ensure that the Commission will come forward urgently with ambitious proposals.
10/10/2013	Joint letter: NGO concerns over the Transitional National Plans pursuant to the Industrial Emissions Directive 2010/75/EU
14/05/2013	Health risks from climate change highlighted in joint letter to the WHO
08/05/2013	Joint NGO letter to President Barroso and Commissioners: Call to reduce our exposure to EDCs In a letter to the President of the EU Commission, environmental, occupational/workers and health organisations express their concerns about the global threat of EDCs and the need to reduce our exposure to them. Brussels, 7 May 2013 Dear President Barroso, Dear Commissioners Tajani, Potočnik, and Borg, We, the undersigned environmental, occupation/workers, and health organisations are writing to express our concerns about a matter of urgency for the health of EU citizens and wildlife. You will soon be taking key decisions on Endocrine Disrupting Chemicals (EDCs), which the World Health Organisation (WHO) and United Nations Environment Programme (UNEP) have called a global threat that needs to be resolved. Your decisions could set the path for significantly reducing exposure to these hazardous chemicals, reducing European national economies’ spending on endocrine related diseases, promoting green chemistry and safer products in the EU, and ensuring EU leadership in global chemicals management. With the Europe 2020 strategy, the EU has set itself the goal of becoming a smart, sustainable and inclusive economy. We believe that acting on EDCs will make a significant contribution to greater sustainability and lead to a more efficient use of resources through the development of better, safer, and greener chemicals, and ultimately strengthen the competitiveness of Europe’s chemical industry. In addition, economic recovery starts with a healthy population. Reducing exposure to EDCs will bring significant health benefits in the short and long term. The weight of scientific evidence, as outlined in the recent review by the WHO and UNEP, tells us that EDCs are linked to serious irreversible impacts on human health and wildlife. Recent EU co-funded human biomonitoring shows certain EDCs are found in both children and their mothers. It is therefore important that the EU ensures that European health and environmental protection is not undermined by policies which disproportionately address the interests of companies producing hazardous chemicals. Exposure reduction should form the key goal of EU EDC policy. In particular we call on the EU Commission to adopt in the coming weeks: 1) Comprehensive and workable criteria to identify EDCs Getting the criteria right for identifying EDCs is the first crucial step in achieving adequate regulation of chemicals with endocrine disrupting properties. 2) A robust and far-sighted EU EDCs Strategy Our organisations have already provided proposals for the revision of the EU EDC Strategy1. Today, we would like to highlight one point of particular importance: The EU must develop and implement a screening and testing strategy that addresses the complexity of the endocrine system, to correctly identify which chemicals are EDCs. The existing testing requirements in the legislation are not able to do this currently. 3) Review of EDCs in REACH authorisation, based on the latest science The upcoming review on how EDCs are regulated under the REACH authorization procedure provides an important opportunity to promote the replacement of EDCs with safer alternatives. The review should ensure that an authorization for an EDC - as for Persistent, Bioaccumulative and Toxic chemicals - can only be granted if no safer alternatives are available and the use is essential to society. Further details on these three issues are set out in the Annex. We call on you to recognise the overwhelming evidence of the dangers of EDCs and acknowledge the conclusion from the EU Commission’s EDC conference in June 2012 and echoed in the WHO/UNEP report: a tipping point has been reached. Now you must take the necessary steps to reflect this knowledge in EU Chemicals Policy. We also call on you to ensure European leadership in the global context as EDCs have become a priority issue in international negotiations on chemical management. Recent reports from the European Environmental Agency (EEA) and UNEP have demonstrated the costs of inaction associated with health and environmental effects of chemicals exposure and how much more expensive it is to take action later after there have been early warnings. In view of the public interest in this matter, we intend to make the contents of this letter more widely available. Sincerely, Genon K. Jensen, Executive Director, Health and Environment Alliance (HEAL) Supported by the following organisations: European Environmental Bureau (EEB) Greenpeace European Unit Pesticide Action Network Europe (PAN - E) Client Earth Health Care without Harm (HCWH) Women in Europe for a Common Future (WECF) Alliance for Cancer Prevention (ACP) Breast Cancer UK BUND Friends of the Earth Germany Cancer Prevention and Education Society (CPES) Center for International Environmental Law (CIEL) Chem Sec CHEMTrust Danish Ecological Council Ecologistas en Acción Fundación Vivosano Générations Futures Réseau Environnement Santé (RES) Swedish Society for Nature Conservation Annex 1) EDC Criteria Getting the criteria right for identifying EDCs is the first crucial step in achieving adequate regulation of chemicals with endocrine disrupting properties. Any criteria that the Commission proposes for identifying ‘chemicals with ED properties’ must not undermine the requirements of existing EU laws. Therefore EDCs must be controlled regardless of how strong they are – i.e. no “potency cut-offs”. The criteria should ensure transparency of existing data and provide incentives for more data generation. The currently deleted category 3 should be re-introduced into the final Commission’s proposal for the criteria. A category 3 is vital to provide transparency on what findings already exist, and to encourage manufacturers to provide further data. Not to include a category 3 in the criteria would be a step backward from the previous EU categorisation scheme for EDCs, which had a category based on in-vitro data. In addition, the criteria must not demand too high a burden of proof for showing how the chemicals exert their effects. Outstanding scientific questions should not lead to inaction. The criteria must be applied in individual pieces of EU legislation (e.g. pesticides, biocides) so that chemicals highly suspected to be EDCs are regulated. 2) EU EDC Strategy Our organisations have already provided proposals for the revision of the EU EDC Strategy2. Today, we would like to highlight one point of particular importance: The EU must develop and implement a screening and testing strategy that addresses the complexity of the endocrine system, to correctly identify which chemicals are EDCs. The existing testing requirements in the legislation are not able to do this currently. Furthermore, the structural barrier to identifying EDCs under the animal testing ban of the cosmetics law must be addressed. To date regulators use animal test data to categorise chemicals. Now, given the animal testing ban in the cosmetics law, the Commission must enable and support regulators to categorize chemicals based on information from non-animal test methods. Otherwise the important aim of minimising animal testing will leave the public unprotected, because no cosmetic ingredient will be identified as an EDC in the absence of animal data. 3) Review of EDCs in REACH authorisation The upcoming review on how EDCs are regulated under the REACH authorization procedure provides an important opportunity to promote the replacement of EDCs with safer alternatives. The REACH Candidate list is encouraging innovation and substitution of hazardous chemicals with safer chemicals, according to a recent EU Commission report. However, if authorizations are given for ‘adequate control’, it will undermine efforts in the transition to safer chemicals. The general population is exposed continuously to a cocktail of EDCs and there is no scientific evidence that “safe exposure levels” can be identified with sufficient certainty. Therefore, the review should ensure that an authorization for an EDC - as for Persistent, Bioaccumulative and toxic chemicals - can only be granted if no safer alternatives are available and the use is essential to society.
24/04/2013	HEAL response to EURACOAL statement
18/04/2013	Joint letter to EFSA on mercury in fish
12/04/2013	To: EU Environment Ministers Re: Informal Environment Council: your exchange on air quality and urban environment, 22 April HEAL urges EU Environment Ministers to consider the three priorities from over 60 environmental, health and citizens NGOs on the future of EU air policies. This topic will be discussed at the upcoming Informal Environment Council meeting on 22 April. Brussels, 12 April 2013 To: EU Environment Ministers Re: Informal Environment Council: your exchange on air quality and urban environment, 22 April Dear Environment Minister, The Health and Environment Alliance (HEAL), a leading European not-for-profit organisation addressing how the environment affects health in the European Union, urges you to consider the significant benefits for human health and well-being, and for the climate, that can be gained through ambitious EU measures to reduce air pollution. Despite a long history of legislation, air pollution continues to be a massive public health and environmental problem in Europe. (1) As the recent WHO REVIHAAP review of the science on air pollution demonstrates, there is no reason for local authorities, national governments and EU institutions to step back from efforts to improve air quality – on the contrary. (2) WHO concludes that damaging health effects can occur at lower levels than previously thought, and that a broader range of health effects has to be considered. Air pollution is not only a contributing factor to the burden of respiratory and cardiovascular disease – two of the major chronic diseases in Europe - but is increasingly linked to neurodevelopment and cognitive function impacts, and even diabetes. Most worrying is that children, even before birth, are being harmed from air pollutants. Recent studies show early life exposure to air pollution contributes to higher risks of developing chronic diseases later in life, including lung disease, diabetes and cancer. (3) Air pollution is also a factor for adverse pregnancy outcomes. Current pollution levels in Europe result in significant human health and economic costs. A recent report “The unpaid health bill: How coal power plants make us sick” provides the first-ever calculation of the effects of coal-fired power generation on chronic lung disease and some heart conditions. It estimates that air pollution from coal plants costs the EU up to 42.8 billion EUR a year. These findings have been widely covered in European and international media, including Forbes, Le Monde, La Repubblica and the Lancet. As you will be discussing the future of EU air policies, we urge you to consider the three priorities of the attached position paper from over 60 environmental, health and citizens NGOs from across Europe: 1. Ambitious emission reduction commitments in the revised National Emissions Ceilings (NEC) Directive 2. Sectoral legislation to cut emissions from all major sources 3. Enforcement and strengthening of ambient air quality limit values HEAL further hopes that you will show support for initiatives that will be beneficial for both air quality and the climate, such as phasing out coal power, ambitious reduction commitments for methane and black carbon, or incentives for active transportation and less meat consumption. Last but not least: outdoor air pollution is also a major determinant of the quality of the air indoors, and Europeans spend most of their time indoors. We call on you to show your support for improving indoor air quality with a dedicated strategy. Our extensive and broad alliance of public health, health professional and health-affected groups, as well as women’s, environmental and consumer groups from across Europe is keen to support your efforts to reduce air pollution. We count on your political commitment for tackling what one of our members, the European Respiratory Society calls the “invisible killer” at the Informal Council meeting and in the months to follow, so that substantial and immediate gains for health and the economy can be reaped. We look forward to future exchanges on this issue. Yours sincerely, Genon K. Jensen Executive Director (1) http://www.who.int/topics/global_burden_of_disease/en/ (2) http://www.euro.who.int/en/what-we-do/health-topics/environment-and-health/air-quality/activities/evidence-on-health-aspects-of-air-pollution-to-review-eu-policies-the-revihaap-project (3) Developmental origins of non-communicable disease: Implications for research and public health: http://www.ehjournal.net/content/pdf/1476-069X-11-42.pdf Attached documents: [European Respiratory Society: 10 principles for clean air->http://erj.ersjournals.com/content/39/3/525.full.pdf+html" class='spip_out' rel='external'>NGO priorities for the review of the Thematic Strategy on Air
13/03/2013	Open letter: Civil Society alarmed by the prospect of regressive Common Agricultural Policy reform
21/02/2013	Open letter on EU research funding for 2014-2020 21 February 2013 To: Members of the European Parliament, Member States of the European Union Dear Member of the European Parliament, dear Madam, dear Sir, You are now involved in the final negotiations around the EU's budget for 2014-2020. The position reached by the European Council's February 8th meeting concludes that a significant cut in research funding is being considered. According to European Commission estimates, this would translate into a €10 billion cut in Horizon 2020, out of an original €80 billion budget [1]. Civil society organisations have been denouncing Horizon 2020's excessive corporate bias since the very first Green paper published by the Commission in 2011 [2], but big business' lobbying prevailed. As it stands, the project is divided into three pillars, with the entire second pillar - more than €20 billion – allocated to a program called “Industrial leadership”, for activities with a “business-driven agenda” [3]. Past experience with similar business-driven EU Research programs shows that despite promises that the priority for these funds will be SMEs, for new research projects, they have mainly been captured by large multinational corporations, to finance research activities that were already planned [4]. This means that these much-needed research funds have been transformed into industry subsidies, with little added value in terms of research results and questionable legitimacy when these same companies slash their workforce while still paying out dividends and bonuses. One example is the Joint Technology Initiative “Clean Sky”, a public-private partnership between the European Commission and industry, in which €400 million of taxpayers' money is directly transferred to the largest companies participating (such as EADS, Thales, Dassault, Finmeccanica, Rolls-Royce...) [5]. Dedicating even more money to a failed policy is not an acceptable use of scarce public funds. We request that the “Industrial Leadership” program is the sole recipient of budget cuts, and that more money is made available for crucial research needs in areas such as food safety, preventative health policy, fundamental public research, ecology-focussed agriculture or renewable energies. Public research funding should go to public interest projects. Signatories ARC 2020 ASEED Europe BUKO Pharma-Kampagne Corporate Europe Observatory Committe for Independent Research and Information on Genetic Engineering (CRIIGEN) Earth Open Source European Coordination Via Campesina (ECVC) European Public Services Union (EPSU) European Network of Scientists for Social and Environmental Responsibility (ENSSER) Fondation Sciences Citoyennes Fondazione Italiana per la Ricerca in Agricoltura Biologica e Biodinamica (FIRAB) GMWatch Health and Environment Alliance (HEAL) International Federation of Organic Agriculture Movements (IFOAM) EU Group Living Knowledge Network Naturschutzbund Deutschland e.V. (NABU) Pesticides Action Europe (PAN) Testbiotech Wissenschaftsladen Wien - Science Shop Vienna Notes [1] In Downsized E.U. Budget, Mixed News for Research, Science Insider, 11 February 2013 [2] Public Research should benefit Society, not Big Business - An Open Letter on the Common Strategic Framework for EU Research and Innovation Funding – Fondation Sciences Citoyennes, 29 June 2011 [3] Proposal for a Regulation of the European Parliament and Council establishing Horizon 2020 - the Framework Programme for Research and Innovation (2014-2020), European Commission, 30 November 2011, Report on the proposal for a Council decision establishing the Specific Programme Implementing Horizon 2020 - The Framework Programme for Research and Innovation (2014 – 2020), (COM(2011)0811 – C7-0509/2011 – 2011/0402(CNS)), European Parliament, 8 January 2013 [4] EU research funding: for whose benefit? - S. Gardner and Corporate Europe Observatory, 5 December 2011 [5] Ibid.
20/12/2012	Joint letter: Last chance to develop strong treaty to reduce mercury exposure New scientific evidence on global mercury seafood contamination highlights adverse health effects occurring below the level which is considered “safe”. This and other scientific evidence clearly demonstrates that the mercury health threat has grown substantially over the last decade. HEAL, EEB and ZMWG urge EU environment ministers to support the adoption of a strong international agreement on mercury when governments meet in Geneva in January 2013. To: Environment Ministers of EU Member States Cc: Commissioner Potocnik Cc: Director General Falkenberg Dear Environment Minister, We, the undersigned, urge you to support the adoption of a strong international agreement on mercury when governments meet in Geneva in January for their fifth and final negotiation. Earlier this month, the Zero Mercury Working Group (ZMWG) presented the most extensive new findingsi to date on global mercury seafood contamination, with health effects occurring below the level considered “safe” just a few years ago – suggesting current health benchmarks should be revised. We highlighted new scientific evidence that for the first time correlates rising mercury levels in the oceans with the growth in pollution and also projects a 50% increase in mercury levels by 2050 in the Pacific Ocean if current pollution trends continue unabated. This and other new evidence clearly demonstrates that the mercury threat has grown substantially since the UN Environment Program (UNEP) global mercury assessment report was completed just after the turn of the century. Since 2001, countries around the world have been discussing options to control mercury pollution and in 2003 the UNEP Governing Council agreed that enough was known to “…warrant immediate action to reduce global mercury pollution.” Now over a decade has passed and the time for bold and corrective action has come. The solution is not for people to stop eating fish since the nutritional benefits are substantial and many small island countries, indigenous people and others depend on fish. While informing consumers about low mercury fish is essential to reduce exposure, this should not be a substitute for the ultimate goal: to reduce mercury contamination and all sources of exposure to the lowest possible levels in the shortest amount of time. Fortunately, the world community can come to grips with the global mercury crisis. Since 2009 governments have been negotiating an internationally binding agreement to control mercury pollution. The treaty is expected to include actions to reduce, amongst others, mercury supply, trade, its use in products and processes, and atmospheric mercury emissions, which will ultimately reduce human exposure to mercury globally. Yet so far the negotiations have been going slowly. This is not because alternatives or solutions are absent; the technology is available to manage mercury pollution — we know how to control mercury emissions, and there are mercury-free alternatives for nearly all mercury-containing products and industrial processes. What is missing is the political will to make the necessary commitments to phase out mercury use, and put the needed controls and alternatives in place. Therefore, as detailed in our comments on the final draft treaty text, we call on you, as representative of your country to work toward a successful outcome next month in Geneva; an ambitious treaty leading to serious emissions reductions and mercury use phase outs for the sake of our children and for future generations. The final treaty negotiation session in Geneva is the world’s last chance to create a strong program for international action and cooperation. Yours Sincerely, Jeremy Wates, Secretary General European Environmental Bureau (EEB) Genon Jensen, Executive Director Health and Environment Alliance (HEAL) Michael Bender and Elena Lymberidi-Settimo, International coordinators Zero Mercury Working Group (ZMWG) Links to the new reports http://www.zeromercury.org/phocadownload/Developments_at_UNEP_level/INC5/FINAL_BRI_Patterns_of_Global_Seafood_120312.pdf http://www.zeromercury.org/phocadow... http://www.zeromercury.org/phocadownload/Developments_at_UNEP_level/INC5/zmwg_summary_recommendations_final.pdf http://toxics.usgs.gov/highlights/p... Link to the ZMWG paper commenting on the final draft treaty text (“Chair’s text): http://www.zeromercury.org/phocadownload/Developments_at_UNEP_level/INC5/zmwg%20preliminary%20views%20on%20inc%205%20draft%20chairs%20treaty%20text-%20november%202012.pdf Link to the Chair’s text: http://www.unep.org/hazardoussubstances/Mercury/Negotiations/INC5/INC5MeetingDocuments/tabid/3495/language/en-US/Default.aspx
14/11/2012	Key issues to increase the chances of the next MFF delivering on Europe 2020 priorities The Green 10 has written an open letter to the President of the European Parliament, Mr Martin Schulz ahead of the 22-23rd November European Summit on the Multiannual Financial Framework (MFF) 2014 – 2020. In the letter the Green10 sets out some key issues that could substantially increase the chances of the next MFF delivering on Europe 2020 priorities on: Climate action: Ensure that 20% of the next MFF supports climate acti Common Agricultural Policy (CAP): Ensure the delivery of public benefits Cohesion policy: Put sustainability at the heart of regional development investments Ensure that LIFE (Environment and Climate fund) receives 1% of the next MFF External dimension: Maintain the Commission’s proposed allocation
09/11/2012	Open letter to Polish Prime Minister Tusk The Green 10 has written an open letter to Polish Prime Minister Tusk. The letter addresses recent statements made by the Polish Minister of Treasury, Mr Mikołaj Budzanowski regarding a civil society organisation. Dear Prime Minister Tusk, We are writing to you to express our concern about the statement made by your Minister of Treasury, Mr Mikołaj Budzanowski on 4th October to the Polish Press Agency and repeated later in an interview with the daily newspaper Rzeczpospolita on the 8th October. In reaction to the appeal made by a non-governmental organisation ClientEarth against the expansion by the Polish Energy Group (PGE) of a coal-fired power plant in Opole, Minister Budzanowski publicly challenged the activities of ClientEarth claiming that "[it] acts against the interest of the State (...)." The Minister also added that "This kind of organisation should accept that there are limits to its activities. In my opinion they have passed their limit. If I were ClientEarth (…) I would reconsider doing any further work against PGE.” These statements represent an unprecedented attack on a civil society organization from a high-level government representative. By equating the interests of private companies with those of the Polish State, Minister Budzanowski’s comments display a disturbing disrespect for the role of civil society in Poland. The Constitution states that the Republic of Poland shall protect the right to create and operate citizens' movements, voluntary associations and foundations, and that public authorities shall support citizens’ efforts in protecting and improving the quality of the environment. In addition, the Aarhus Convention, ratified by Poland, introduces the right of NGOs to challenge decisions affecting the environment before administrative bodies and courts. We therefore believe that you as Prime Minister, as a regular defender of the principles and the importance of democracy, should also defend a transparent dialogue with representatives of non-governmental organizations. We urge you to respond publicly and unambiguously to the Minister's statement.
10/10/2012	Joint NGO letter: Support phase-out of mercury use in dentistry in the EU and globally High quality and cost-effective alternatives to dental amalgam are readily available. HEAL and other organisations believe that dental amalgam use should be phased out and time-tables for such action should be supported at both the EU and global levels. To: EU Member States’ representatives and dental experts potentially attending the European Commission meeting on dental amalgam on October 11th, 2012 9 October 2012, Brussels Dear Member State environment/health expert, We are writing to you in view of the European Commission meeting with Member States’ experts on the 11th October, in Brussels, to address dental amalgam. As you are well aware, the recent European Commission commissioned BIOIS report, ‘Study on potential for reducing mercury pollution from dental amalgam and batteries’ concluded that the most effective way to reduce environmental impacts of dental amalgam use in the EU, would be a combination of banning the use of mercury in dentistry and improving enforcement of EU waste legislation regarding dental mercury [i]. Since indeed high quality and cost-effective alternatives to dental amalgam are readily available, we believe that such policy conclusions should now become legislative measures; dental amalgam use should be phased out and time-tables for such action should be supported at both the EU and global levels. [ii] Although the BIOIS report does not consider the health impacts from direct exposure from amalgams that are still being debated, it does recognize that dental mercury “remains a significant contributor to overall environmental mercury releases in the EU.” [iii] “In 2007, dental amalgam was the second largest mercury use in the EU after chlor-alkali production and it is expected to become the largest mercury use once mercury cell-based chlor-alkali production is phased out in the EU (target date 2020).” [iv] The report estimates that consumption of dental amalgam represented between 55 and 95 t Hg per year in 2010, and estimated to be an average of 75 tonnes/year. Furthermore, it is estimated that dental amalgam contributes 21-32% of overall EU mercury emissions to air and up to 9-13% of overall mercury emissions to surface water. [v] Once dental mercury has been used, there are a number of “end-of-pipe” techniques to prevent it from entering the environment, but each comes at a (sometimes very high) cost, and may not be as effective as intended. Further, the broad application of “end-of-pipe” techniques throughout the EU is severely limited, particularly in regard to mercury abatement from cremation (which is increasing).[vi] BIOIS concludes that waste management alone is not sufficient because “While […]it tackles environmental impacts from both historical and current dental amalgam use, it focuses on releases from dental practices and is not sufficient in itself to address the whole range of mercury releases from the dental amalgam life cycle (it does not address mercury releases from the natural deterioration of amalgam fillings in people’s mouths, from cremation and burial, and residual emissions to urban WWTPs).” [vii] While most dental professionals continue to charge somewhat lower prices for amalgams, it is increasingly clear that the full ‘external’ costs borne by the rest of society are high, when the full range of environmental and potential health ramifications are taken into account.[viii] Ultimately, society pays for the uncontrolled releases of mercury from dental amalgam through additional pollution control costs, the loss of common resources, and the health effects associated with mercury contamination.[ix] For those reasons, phasing out dental mercury use is necessary and cost-effective: “since the associated costs are considered to be reasonable for the various stakeholders, especially as they are considered to be outweighed by the associated environmental and health benefits.” [x] Furthermore and most importantly there are a range of safe and affordable mercury-free alternatives. The Swedish experience, among others, has proven that there are very few cases where a compelling argument can be made that amalgam fillings are ‘necessary.’ This is also backed up by the EU Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR 2008), which concluded in their study “that dental health can be adequately ensured by both types of materials” (i.e. mercury-free alternatives and amalgam), noting that alternatives have been in clinical use for over 30 years, and revealed little evidence of clinical significant adverse effects to date [xi]. In addition BIOIS finds, among other advantages, that, due to technological progress, composite can last just as long as amalgam, and in some cases even longer.[xii] Therefore in view of advancing discussions at EU level, a route to transitioning out of dental mercury could be, phasing it out as fast as possible, with some exceptions. Exemptions however, should be set in a restricted framework, otherwise they risk becoming a loophole and potentially undermining the policy proposals and the objectives of the regulators. Nevertheless, amalgam should not be allowed into children’s mouth, that is to say in milk teeth. Clearly, the environmental pollution from dental amalgam and health consequences from indirect exposures are significant [xiii], and the precautionary principle further obliges us to take a pro-active stand with regard to potential health risks from direct amalgam exposures. The BIOIS report shows that the transition to mercury-free dentistry can occur in all of Europe. To that end, we call on you to send a clear message to the EC that you support phase-outs of mercury from dentistry at the EU level and globally. Thank you in advance for your attention to this important environmental and health issue and for considering our concerns. Yours sincerely, Elena Lymberidi-Settimo Project Coordinator ‘Zero Mercury Campaign’ European Environmental Bureau This letter is also supported by: World Alliance for Mercury-Free Dentistry, www.toxicteeth.org Zero Mercury Working Group, www.zeromercury.org Health and Environment Alliance, www.env-health.org The International Academy of Oral Medicine and Toxicology – Europe Health Care Without Harm www.noharm.org- Europe, www.noharm.org European Academy for Environmental Medicine e.V, www.europaem.org Deutscher Berufsverband der Umweltmediziner, www.dbu-online.de Deutsche Gesellschaft für Umweltzahnmedizin, www.deguz.de Non au mercure dentaire, www.non-au-mercure-dentaire.org Réseau Environnement & Santé, http://reseau-environnement-sante.fr/ Association Toxicologie Chimie, http://atctoxicologie.free.fr/ References: [i] EC- BIOIS Study on potential for reducing mercury pollution from dental amalgam and batteries, http://ec.europa.eu/environment/che... [ii] With possible limited exemptions for specific medical conditions [iii] BIO Intelligence Service (2012), Study on the potential for reducing mercury pollution from dental amalgam and batteries, Final report prepared for the European Commission-DG ENV, http://ec.europa.eu/environment/chemicals/mercury/pdf/Final_report_11.07.12.pdf, p. 10 [iv] BIO Intelligence Service (2012), Study on the potential for reducing mercury pollution from dental amalgam and batteries, Final report prepared for the European Commission-DG ENV, http://ec.europa.eu/environment/chemicals/mercury/pdf/Final_report_11.07.12.pdf, p.10 [v] BIO Intelligence Service (2012), Study on the potential for reducing mercury pollution from dental amalgam and batteries, Final report prepared for the European Commission-DG ENV, http://ec.europa.eu/environment/chemicals/mercury/pdf/Final_report_11.07.12.pdf, p.176 [vi] Ibid. [vii] BIO Intelligence Service (2012), Study on the potential for reducing mercury pollution from dental amalgam and batteries, Final report prepared for the European Commission-DG ENV, http://ec.europa.eu/environment/chemicals/mercury/pdf/Final_report_11.07.12.pdf, p.108 viii Hylander & Goodsite 2006, Maxson 2006 Environmental costs of mercury pollution, Science of the Total Environment 368 (2006) 352–370 [ix] http://mpp.cclearn.org/wp-content/uploads/2008/08/finalreportfrommpptestimony0707081.pdf [x] BIO Intelligence Service (2012), Study on the potential for reducing mercury pollution from dental amalgam and batteries, Final report prepared for the European Commission-DG ENV, http://ec.europa.eu/environment/chemicals/mercury/pdf/Final_report_11.07.12.pdf, pp.108-09 [xi] http://ec.europa.eu/health/ph_risk/committees/04_scenihr/docs/scenihr_o_016.pdf [xii BIO Intelligence Service (2012), Study on the potential for reducing mercury pollution from dental amalgam and batteries, Final report prepared for the European Commission-DG ENV, http://ec.europa.eu/environment/chemicals/mercury/pdf/Final_report_11.07.12.pdf, p.68 [xiii] Studies have demonstrated that a certain portion of this dental mercury becomes bioavailable, and may constitute a significant source of risk to human health and the environment, Stone et al. (2005) – ME Stone, ME Cohen, L Liang and P Pang, Determination of methylmercury in dental-unit wastewater, Dental Materials 19 (2003) 675–679, Elsevier Ltd.
03/10/2012	Joint NGO letter to Commissioners on EDCs
19/09/2012	Green 10 letter: EU deliberations on Common Agricultural Policy (CAP) and Multiannual Financial Framework (MFF) With negotiations on the EU’s next MFF high on the political agenda, and in advance of next week’s discussion at the General Affairs Council, HEAL on behalf of the Green 10 urges EU ministers of Finance, European Affairs and Agriculture to ensure that no decision on the overall allocations to the CAP, under the MFF, is taken before a decision has been taken on what the CAP budget will deliver and to safeguard only those parts of the CAP budget that clearly demonstrate benefits to society and European taxpayers. TO: Ministers of Finance, Minsters of European Affairs CC: Ministers of Agriculture RE: EU deliberations on Common Agricultural Policy (CAP) and Multiannual Financial Framework (MFF) Brussels, 19 September 2012 Dear Minister, With negotiations on the EU’s next MFF high on the political agenda, and in advance of next week’s discussion at the General Affairs Council, we are writing to you on behalf of the Green 10, ten of the largest European environmental organizations, with a membership of over 20 million citizens, to urge you to ensure that no decision on the overall allocations to the CAP, under the MFF, is taken before a decision has been taken on what the CAP budget will deliver and to safeguard only those parts of the CAP budget that clearly demonstrate benefits to society and European taxpayers. As environmental organizations we have long argued that the CAP has the potential to become an instrument that will reward farmers for the delivery of public goods, and for this reason we have supported a significant part of the EU budget to be spent on the CAP. Despite previous reforms resulting in, for example, the creation of ‘the second pillar’, a large amount of funding, especially in ‘the first pillar’, is still going to Europe’s environmentally most damaging farming practices. These farming practices not only harm our environments and the climate, they also profoundly compromise reaching Europe’s goals for better public health, equity and tackling poverty and social exclusion. For the CAP to fulfill its potential, and to regain its legitimacy, it would need profound change. Over the last year we have been closely following the proposals being discussed in the Agriculture Council and in the European Parliament’s Agriculture Committee and we are observing that at the very best lip service is paid to such a profound change. Worse, both within the European Parliament and within the Council, agriculture negotiators are planning to wait for a decision to be taken on the MFF before providing any clarity on the fundamental question of how this new CAP budget will actually be used. Some MEPs have even gone on record arguing that any cut in the CAP budget would translate into cuts in the one part of the CAP budget that actually brings benefits to society. It is becoming ever clearer that the CAP is more likely to be green-washed, than “greened”. We believe this is an unacceptable way of taking decisions on the EU’s MFF, especially at a time of economic crisis and severe budget constraints across Europe. We also believe that this fatally undermines the possibly last chance for the CAP to regain its legitimacy and to develop into a policy that will be both politically and environmentally sustainable, by providing European citizens with public goods such as clean water and air, and thriving wildlife. We therefore call on you to help ensure the following key elements of sound decision making. First of all, that agricultural negotiators will actually provide clarity on the question of what the money will be spent on, and secondly, that only those parts of the CAP budget that are providing substantial and demonstrable benefits to society and European taxpayers are safeguarded within the final budget decisions. Yours sincerely, Genon K. Jensen, Executive Director, Health and Environment Alliance (HEAL) On behalf of the Green 10 EU Directors Green 10 EU Directors: Angelo Caserta, Regional Director of the European Division – BirdLife International Wendel Trio, Director – Climate Action Network (CAN) Europe Anelia Stefanova, Director – CEE Bankwatch Network Jeremy Wates, Secretary-General – European Environmental Bureau Magda Stoczkiewicz, Director - Friends of the Earth Europe Jorgo Riss, Director – Greenpeace European Unit Genon K. Jensen, Executive Director – Health & Environment Alliance Christian Baumgartner, Director, Naturefriends International Jos Dings, Director – The European Federation for Transport and Environment (T&E) Tony Long, Director – WWF European Policy Office
17/09/2012	To: Attachés of the Competitivness Council working group Re: Benefits to public health and national budgets of stringent noise standards HEAL, T&E, EEB and Eurocities call on EU Member States to reject attempts to further weaken the proposal on new EU vehicle noise limits. Ahead of a Competitiveness Council working group meeting, the joint letter highlights the benefits to public health and national budgets of stringent noise standards. Dear Attaché, Transport & Environment (T&E), the Health and Environment Alliance (HEAL), the European Environmental Bureau (EEB), and EUROCITIES, would like to draw your attention to the Competitiveness council working group meeting on Tuesday 18th 2012 to discuss the European Commission regulation proposal (2011/0409 COD) on the sound level of motor vehicles. Over the last forty years vehicle noise has increasingly impacted on the health and well-being of Europeans, while traffic noise standards have not been updated since the mid 1990s. Noise pollution is associated with around 50,000 fatal heart attacks every year and 250,000 cases of cardiovascular disease every year. It is the second biggest environmental health problem in Europe after air pollution, according to the World Health Organisation. Recent research proves that cutting traffic noise from vehicles would enable national governments, local authorities and society at large to enjoy benefits which would outweigh costs by a factor of more than thirty to one, saving around 89 billion Euros a year. This includes cutting health-related costs caused by noise, but also enabling local and national governments to avoid expensive measures such as installing noise barriers or insulating individual homes. We understands that the co-decision procedure is focused on how much and how quickly noise levels for different types of vehicles should be tightened. However, we are concerned that the process may lead to a significant weaken of the proposal – to the detriment of over 200 million Europeans who are currently at risk from high levels of road traffic noise. For these reasons, we ask you to reject proposals to further weaken the proposal: No delay to entry into force. The proposal from the European Commission would only apply to new types of vehicle from 20XX, and the vast majority of vehicles would not need any changes at all as they are already compliant with phase 1 limit values. Phase 2 would only enter into force after 7 years – the leadtime requested by the industry during the consultations on the regulation, which is more than sufficient. Proposals to delay this further, wait for agreement on UNECE Regulation 51, or add a further ‘transition period’ are not necessary and come at a high cost to public health and the budgets of local authorities. The proposed limits would only affect sales of new vehicles from 2019/20, so giving more than the 5-7 years lead time the industry claims is necessary for new models. Take care with ‘moving the goalposts’ on vehicle classification. In some cases, changing the classification is technically well-justified, but please be aware of proposals reclassifications intended to allow higher noise limits (and/or additional allowances) that were originally only intended for very specific vehicle types. Certain small-volume types of vehicles are responsible for a significant number of noise peaks; Reject rounding down of measured results. Proposing to round down measured results and allow vehicles in production to have more relaxed limits than tested vehicles; T&E, HEAL, EEB, suggest a five point plan that would improve the original text and bring about savings worth 51 billion Euros costing only 3 billion. Please click here to view the position paper. T&E, HEAL, EEB held an event in the European Parliament to launch A Sound Investment Joint Declaration in early June 2012, where cities, noise experts, politicians and civil society organisations came together in calling on the EU to increase the ambition level of European noise limits for new vehicles We would welcome an opportunity to discuss these issues with you in person at your convenience. Yours sincerely, Greg Archer, Transport & Environment (T&E) Anne Stauffer, Health and Environment Alliance (HEAL) Louise Duprez, European Environmental Bureau (EEB) Henk Wolfert, EUROCITIES
31/08/2012	To: Commissioner Janez Potočnik and Commissioner John Dalli Re: NGO comments on the RAC and SEAC opinion on the Danish phthalate dossier HEAL and 8 other European NGOs criticise the opinion of two committees of the European Chemicals Agency (ECHA) that the restriction of 4 phthalates (DEHP, DBP, BBP, and DIBP) in consumer goods, proposed by Denmark, is unjustified. We urge the Commission to restrict the 4 phthalates in consumer goods based on toxicological, epidemiological, and human biomonitoring evidence, and the precautionary principle as mandated by the REACH chemicals law. Also, the Commission should amend existing EU legislation to deal with the combination effects of chemicals, particularly related to REACH, to protect the health of EU citizens and environment. OPEN LETTER 29 August, 2012 Dear Commissioners, Our nine organisations are writing to you jointly as a response to the conclusions drawn by the two scientific committees of the Chemicals Agency (ECHA), the Committee for Risk Assessment (RAC) and the Committee for Socio-economic Analysis (SEAC), that the Danish proposal of restriction of four classified phthalates (DEHP, DBP, BBP, and DIBP) in articles is not justified. We welcome that the RAC, based on the Danish proposal, now recognizes in principle the potential for "combination effects", and thus has enabled the future banning of substances based on their combined effects due to the same mechanism of action. This conclusion is extremely important as it acknowledges reality where chemicals don’t act in isolation but people and wildlife are exposed to multiple substances at the same time. This recognition also emphasizes that epidemiology needs to abandon its outdated focus on single endocrine disrupters and has to embrace the reality of endocrine disrupter mixture effects by developing biomarkers that capture cumulative exposure to endocrine disrupters. Moreover it shows that in the absence of epidemiological and toxicological data that deals with mixtures, it is questionable to assume that chemicals are not exerting combination effects, and do not pose a risk. Therefore we strongly disagree with the conclusion from RAC and SEAC that the available data in the Danish dossier does not indicate that currently (2012) there is a risk from combined exposure to the four phthalates. Given that the RAC accepts that the Danish dossier may have over-estimated or indeed under-estimated some current exposure routes we do not consider that the RAC’s conclusion is robust. The RAC should decide on whether there is a need for restriction based on the best available data at this time, and the available biomonitoring data shows that there could be a risk from the combined exposure to the four phthalates both for children and for adults. An ongoing EU research project on human biomonitoring, Democophes, in preliminary results is showing combined exposures. In Germany for example researchers taking samples over this last year found slightly higher exceedance of (German) reference values for the phthalate DEHP compared to a prior biomonitoring project (GerES, which in 2003-06 already found exceedance), and for some phthalates higher maximum levels. One of the committee’s arguments to not support the Danish proposal is that the risk characterization ratios (RCRs) are only slightly above 1, and that a reduction of phthalates used in the last couple of years might have further lowered this value. In light of this our organisations want to draw attention to the data available on low-dose effects and the scientifically proven effects due to concurrent exposure to several chemicals with combination effects [1,2,3,4]. Even though the amount of the four phthalates in use might be decreasing, there will still be an exposure – a low dose exposure that could result in adverse combination effects. Here, it should be also borne in mind that there will be other anti-androgenic substances to which the human population is exposed, in addition to these 4 phthalates. For example, a recent report (sampling performed between April and June 2011) done by the Swedish Society for Nature Conservation (“Home sweet home? – dusty surprises under the bed” [5]) shows that we are exposed to a wide range of substances from the dust in our homes. Just considering dust from homes, the findings showed that the total level of phthalates (BBP, DBP, DEHP* and DINP), were in some countries found to be higher than what public authorities today consider to be safe, if the combination effects were considered. And since Europeans spend as much as 90 percent of their time indoors, it is very important to find a way to deal with the problem of combination effects – most effectively done through legislation by restrictions. This Swedish report is based on samples that were collected between April and June 2011 and thus originate after the restrictions on three of the four phthalates in toys and childcare articles. Another study [6], just published (2012) by the Danish Ministry of the Environment, shows that pregnant rats’ exposure to a combination of five different endocrine disrupting chemicals, at very low doses, can have adverse effects on the rat pups. The rats were given drugs at doses which individually do not cause an effect. The study showed that the combination of drugs prolonged gestation in dams, had serious effects on male offspring genitals, and led to a higher level of pesticides in the pups’ blood than when they were exposed to one chemical at a time. The study did not specifically include phthalates but other endocrine disrupters that are likely to have similar mechanism of action as phthalates. Besides the real concern about low-dose effects and combination effects, it is a fact that the products used as examples in the Danish Annex XV dossier are still on the market. In general it cannot be assumed that the authorisation process will reject the use of phthalates in all relevant consumer products in the EU. Moreover, the authorization process will evaluate the phthalates as separate substances and does not take into account that they act as a chemical cocktail. Furthermore, products that are imported from non-EU countries are not subject to the authorisation process. The fact that in 2010, 60 % of all products that were included in the EU RAPEX list for products posing a serious risk to the health and safety of consumers were made in China makes clear that there is a significant loophole in the authorization process. Very worryingly, the RAC argumentation that the RCRs calculated in the Danish dossier are not sufficiently above 1 is in direct conflict with the EU chemical legislation. Risk assessment officially is based on the precautionary principle [7]. The Committees should follow the REACH legal text, which says; “To ensure a sufficiently high level of protection for human health, including having regard to relevant human population groups and possibly to certain vulnerable sub-populations, and the environment, substances of very high concern should, in accordance with the precautionary principle, be subject to careful attention”. So even a RCR at or slightly above 1 should be taken very seriously and acted upon! In their rejection of the Danish proposal, RAC also uses the “very worst case” scenarios that are used in the dossier as an argument. These scenarios show that the total RCR for each age-group is above 1. It might be an overestimated exposure scenario, but taking into account that the articles used as examples in the dossier are just a limited selection of all the sources of exposure that we are exposed to, the scenario presented in the Danish dossier could as well be underestimated [8]. Given these uncertainties, the application of the precautionary principle is all the more warranted. NGOs are urging the European Commission to take a decision on the restriction of the four phthalates that is based on the precautionary principle. Furthermore, it should prepare concrete amendments to deal with the combination effects of chemicals in existing EU legislation, in particular REACH, in order to protect the health of Europe’s citizens and environment. We also call on companies and EU Member States to enhance the substitution of hazardous chemicals with safer alternatives and adopt reduction measures to reduce exposures to hormone disrupting chemicals. Yours sincerely, Lone Mikkelsen Policy officer –chemicals, Danish Ecological Council On behalf of the following organisations: CONTACTS: Lone Mikkelsen – Policy officer -chemicals, Danish Ecological Council: lone@ecocouncil.dk, +45 3318 1934 Clare Dimmer – Chair of Breast Cancer UK: clare.dimmer@breastcanceruk.org.uk, 0845 680 1322 Yannick Vicaire – Policy officer, Réseau Environnement Santé: res.yvicaire@gmail.com + 33 608 755 015 Anja Leetz – Executive Director, Health Care Without Harm Europe: anja.leetz@hcwh.org, +49 152 5397 8103 Sarah Häuser – Chemicals Policy and Nanotechnology, Bund für Umwelt und Naturschutz Deutschland e.V. (BUND): sarah.haeuser@bund.net, +49/30/27586-463 Alexandra Caterbow – Coordinator Chemicals and Health, WECF: alexandra.caterbow@wecf.eu, +49 (89) 23 23 93 8-16 Markus Johansson – Policy officer –chemicals, Swedish Society for Nature Conservation: markus.johansson@naturskyddsforeningen.se Lisette van Vliet – Senior Policy Advisor, Health & Environment Alliance (HEAL): lisette@env-health.org, +32 2 234 3645 Gwynne Lyons – Director, CHEM Trust: gwynne.lyons@chemtrust.org.uk, +44 1603 507 363 References [1] Silva E, Rajapakse N, Kortenkamp A 2002 Something from “nothing”: eight weak estrogenic chemicals combined at concentrations below NOECs produce significant mixture effects. Environ Sci Technol 36:1751–1756 [2] Benachour N, Moslemi S, Sipahutar H, Seralini GE 2007 Cytotoxic effects and aromatase inhibition by xenobiotic endocrine disrupters alone and in combination. Toxicol Appl Pharmacol 222:129–140 [3] Rajapakse N, Silva E, Kortenkamp A 2002 Combining xenoestrogens at levels below individual no-observed-effect concentrations dramatically enhances steroid hormone activity. Environ Health Perspect 110:917–921 [4] Laura N. Vandenberg, Theo Colborn, Tyrone B. Hayes et al., Hormones and Endocrine-Disrupting Chemicals: Low-Dose Effects and Nonmonotonic Dose Responses. Endocrine Reviews, June 2012, 33(3): 0000-0000. Edrv.endojournals.org [5] The report was presented as supportive data during the public consultation process. Reference number: 07d62328-e727-437f-ae58-d23e72f76324 http://www.naturskyddsforeningen.se... * The same phthalates as in the Danish proposal [6] http://www.food.dtu.dk/upload/føde... [7] “The precautionary principle provides justification for public policy actions in situations of scientific complexity, uncertainty and ignorance, where there may be a need to act in order to avoid, or reduce, potentially serious or irreversible threats to health or the environment, using an appropriate level of scientific evidence, and taking into account the likely pros and cons of action and inaction”. Gee D 2006 Late Lessons from Early Warnings: Towards Realism and Precaution with Endocrine Disrupting Substances. Environmental Health Perspectives, Vol 114, Supplement 1 [8] see for example list of article notifications for Dibutyl phthalate (DBP), the phthalate driving the combined risk assessment in the restriction proposal, http://echa.europa.eu/documents/101...
27/06/2012	Green 10 letter: Green Stimulus Measures needed to Exit Crisis, warn leading environmental groups Ahead of this week’s EU Summit, the Green 10 network of leading environmental organizations encourages EU heads of government to break the link between the banking and the sovereign debt crises. Governments must regain the ability to implement policies that will transform the EU economy to make it more resource efficient and resilient to worsening environmental conditions. The green groups also welcome that the debate is moving beyond austerity and consider that an EU stimulus agenda, if devised correctly, would help solve the interlinked environmental and economic crises. Measures which the Green 10 proposes for an EU stimulus package include: A green tax shift to address the problem of high unemployment and pollution. Conditionality for any financial support to banks to ensure investment in green sectors of the real economy. Priority support to energy savings and renewable technology, sustainable transport and renewable energy infrastructure for electric vehicles. No public subsidies for fossil fuels and unsustainable activities. Green public procurement as a fundamental principle to boost the economy. A continental tax or levy on financial transactions to provide additional financing for green stimulus measures and to fight climate change. Supporting sustainable activity in rural and maritime regions. At a time of critical economic challenges, including rising unemployment and dwindling natural resources, the Green 10 considers that Europe needs to transform its economy to become more resilient, to operate more efficiently and within planetary limits. Degradation of nature will cost the EU €1 trillion every year by 2050 [1]. Any EU stimulus plan must halt this destruction of natural wealth and its harmful impacts on human health [2], while creating millions of new jobs in green sectors such as renewable energy and energy savings, nature conservation and restoration, as well as sustainable transport. It should also make the European economy less dependent on energy imports, saving hundreds of billions of euro annually [3]. However, environmental groups warn that EU governments have a poor track record in finding long term solutions that benefit the environment and the economy [4]. Badly devised financial and regulatory support in the energy sector could lead to a technological ‘lock-in’, keeping the EU saddled with high energy costs for decades, preventing the rapid expansion of renewable technologies and related jobs. This is a Green 10 statement where the organisations that make up the coalition are: Birdlife International, CEE Bankwatch Network, Climate Action Network Europe (CAN-E), European Environment Bureau (EEB), Transport and Environment (T&E), Health and Environment Alliance, Friends of the Earth Europe (FoEE), Greenpeace, Naturefriends International (NFI) and WWF European Policy Office (WWF-EPO) Notes to editors: [1] Cost of policy inaction (COPI): The case of not meeting the 2010 biodiversity target. L. Braat & P. ten Brink (eds.) http://ec.europa.eu/environment/nature/biodiversity/economics/teeb_en.htm (chapter 6, p. 140) [2] Almost half a million European citizens die every year solely due to air pollution. See European Topic Centre on Air Pollution and Climate Change (2009): http://acm.eionet.europa.eu/docs/ETCACC_TP_2009_1_European_PM2.5_HIA.pdf (p. 20) [3] The International Energy Agency estimates oil imports into the EU to cost more than 500 billion dollars in 2012. http://www.iea.org/Speech%5C2012%5CBirol_2nd_set_oil_slides.pdf [4] For example, the costly car scrappage schemes introduced in 2008/9 were environmentally and economically ineffective. See OECD Interim Report of the Green Growth Strategy, p.30.
29/05/2012	To: Members of the EP’s Environment Committee Re: ENVI discussion on vehicle noise – comments from health, transport and environment groups HEAL, T&E and EEB call on the ENVI Committee to reach a position on the vehicle noise file currently being reviewed that will confirm the European Parliament’s commitment to tackling traffic noise and to use this unprecedented opportunity to prevent ill-health and disease. This afternoon during the ENVI committee session, you will be exchanging views on the draft report on the sound level of motor vehicles, by rapporteur Miroslav Ouzky (COM(2011)0856). The vehicle noise proposal is a key opportunity for health prevention that should not be missed, and would bring about huge benefits for national governments, local authorities and society at large. The Health and Environment Alliance (HEAL), Transport & Environment (T&E) and European Environmental Bureau (EEB) call on you as an ENVI Committee member to reach a position on the vehicle noise file that will confirm the European Parliament’s commitment to tackling traffic noise and to use this unprecedented opportunity to prevent ill-health and disease. In order to do so, we call on you to strengthen the Commission proposal by: Approving a long-term framework to reduce vehicle noise, with a further tightening of standards to come into force in 2020 Providing a maximum noise limit to reduce highly intrusive peak noise levels Adopting provisions for transparency as regards all vehicles’ noise emissions Closing loopholes in the existing legislation Accelerating progress by setting standards that come into force faster As MEPs, you have recently shown your commitment to tackling health effects from noise in the resolution on chronic diseases and also on the 7th EU Environment Action Programme. Consequently, we very much hope that you will support an ambitious proposal to reduce vehicle noise, echoing the concerns of many citizens in Europe. For further information on the health evidence and the vehicle noise proposal please see below. Yours sincerely, Anne Stauffer, Health and Environment Alliance (HEAL) Greg Archer, Transport & Environment (T&E) Louise Duprez, European Environmental Bureau (EEB) T&E, HEAL and EEB publications New EU vehicle noise limits Reduction of vehicle noise emissions - Technological potential and impacts Quiet Please - Better Health through Strong EU Regulation of Road and Rail Traffic Noise Health evidence and EP resolutions As an assessment by the World Health Organisation on the burden of disease from environmental noise has shown, road traffic noise contributes substantially to the burden of disease in the EU. In terms of the burden on health, environmental noise is second only to air pollution. It is therefore a major public health challenge that urgently deserves greater political attention. There are many other results of scientific research, which include EU funded projects, that highlight the links between noise exposure and health impacts. Studies have revealed that 50, 000 deaths and nearly a quarter of a million cases of cardiovascular disease every year in Europe are linked to traffic noise. Also for the first time, noise has been linked to an increased stroke risk: in Denmark 5% of all stroke cases are caused by traffic noise. The health concerns were raised in a letter to the rapporteur and shadows on the vehicle noise file signed by leading experts on noise from the field of health and vehicle technologies. We are especially concerned about the body of science showing the impact of environmental noise on cardiovascular health. Cardiovascular disease is the largest cause of death in the EU, accounting for 40% of deaths and approximately 10% of healthcare expenditure. Reducing noise emissions at source by tightening vehicle noise standards is therefore a key component for chronic disease prevention, a priority on the EU’s public health agenda. MEPs expressed specific concerns about noise and health in the resolution on the 7th EU Environment Action Programme (EAP), stressing that the 7th EAP should include measures to address health impacts from noise. In the European Parliament resolution on chronic diseases from Sept. 2011 (“EU position and commitment in advance of UN high-level meeting on the prevention and control of non-communicable diseases”), MEPs stressed the environmental dimension of chronic diseases and highlighted that an effective environmental policy offers major prevention opportunities. The vehicle noise proposal with the approach to reduce noise at source is such an opportunity.
24/05/2012	Energy efficiency targets for a healthy climate, clean air and healthy housing At present rates of progress, the EU will miss its target to reduce energy consumption by 20% by 2020 by at least half. This would mean missing out on a great many direct and indirect health-related co-benefits, linked to improved air quality and reduced fuel poverty. The EED provides a vital opportunity to close the gap to the 20% target, but must be made considerably more ambitious than the Council currently foresees. To: EU Energy Ministers Brussels, 24/05/2012 Dear Minister of Energy, On 25 April the Danish EU Presidency hosted a scientific conference on health, environment and climate change in Copenhagen. The event reflected the synergies between climate action and disease prevention and gave an important signal to ongoing negotiations on the Energy Efficiency Directive (EED). At present rates of progress, the EU will miss its target to reduce energy consumption by 20% by 2020 by at least half. This would mean missing out on a great many direct and indirect health-related co-benefits, linked to improved air quality and reduced fuel poverty. The EED provides a vital opportunity to close the gap to the 20% target, but must be made considerably more ambitious than the Council currently foresees. In particular, it must include binding national targets and clear requirements for deep renovation of buildings, as well as appropriate mechanisms to help deliver and finance these. Cold homes are an important cause of respiratory and cardiovascular diseases, affecting children and senior citizens the most. [1] The EU must greatly improve the energy efficiency of its houses – but existing EU legislation is insufficient to ensure this happens. A 3% annual renovation target for all public buildings, as proposed by the European Commission in the EED, would help to stimulate the market for building renovation. So too would clear national roadmaps for deep renovation of a country’s building stock by 2050, with interim targets and financing proposals. At the same time, health considerations must be paramount when improving the energy efficiency of buildings. From a healthy buildings perspective, the EED should therefore include requirements on the ventilation of buildings, as well as encourage the use of low-emission insulation, construction and other material. Indoor air quality can become worse if ventilation in insulated houses is insufficient, leading for example to an increase in mould. If made in the right way, energy efficiency improvements can be a win-win for both consumers’ bank accounts, and their health. Many households all over Europe still spend more than 10% of their income on heating, which makes them prone to insufficient heating and the health implications of cold homes. The World Health Organization report on Housing [2] published as part of the series Health in the green economy gives a detailed analysis of the health co-benefits that could be made and how to close the health equity gap in the building sector. The total savings foreseen by the Energy Efficiency Directive across different sectors will also lower fossil fuel consumption. Less combustion of fossil fuels through energy efficiency improvements will in the end improve air quality. According to a report by Health and Environment Alliance together with Health Care Without Harm Europe [3], the simultaneous air quality improvements from reducing greenhouse gas emissions through measures such as energy efficiency are worth billions in terms of avoided health costs. If the EU were to move from a 20% target in 2020 to a 30% target, up to Euro 7.9 billion could be saved annually. The 20% energy efficiency target is key for substantial reductions in European greenhouse gas emissions. The analysis of the European Commission in the draft communication on the 2050 Low Carbon Roadmap clearly states that 25% of greenhouse gas reductions could be achieved by 2020 if the 20% energy efficiency target was fulfilled. We urge you to take these health considerations into account in your negotiations with the European Parliament in order to reach an agreement which will benefit both people’s health and the planet. Best regards, Genon K. Jensen Executive Director References: [1] Marmot Review Team (2011): The Health Impacts of Cold Homes and Fuel Poverty. http://www.instituteofhealthequity.... [2] World Health Organization (2011): Health co-benefits of climate change mitigation – Housing sector. http://www.who.int/hia/green_econom... [3] Health and Environment Alliance & Health Care Without Harm Europe (2010): Acting NOW for better health. A 30% reduction target for Eu climate policy. http://www.env-health.org/IMG/pdf/H...
24/04/2012	NGOs call for EU air quality limit values to be enforced by the European Commission HEAL and over 25 other NGO's urge commissioner Potočnik to take immediate action against those Member States who are breaching their obligations to comply with the EU’s ambient air quality legislation. Every day, in many places across the EU, the limits for particulate matter (PM10) continue to be breached although EU legislation entered into force more than seven years ago. To: Mr. Janez Potočnik, EU Commissioner for Environment; Catherine Day, Secretary-General of the European Commission; Karl Falkenberg, Director General for Environment Brussels, 23 April 2012 Dear Commissioner Potočnik, We are writing to you on behalf of over 200 European citizens’ organisations from across the EU to ask you to take immediate action against those Member States who are breaching their obligations to comply with the EU’s ambient air quality legislation. Why the enforcement of EU limit values matters Although emissions of air pollutants have fallen over the past twenty years, the quality of the air we breathe has not significantly improved. Concentrations of ozone and particulate matter (PM), both very dangerous to human health, remain very high, having a significant impact on health and well-being and leading to nearly half a million premature deaths each year in the EU 27 Member States(1). In comparison with the WHO recommendations for ambient air quality, current EU limits are insufficient to protect people’s health, in particular when it comes to the concentrations of the smallest particles. The implementation of the WHO recommended limits for PM2.5 in 25 large European cities alone could provide savings of €31.5 billion annually, including savings on health expenditures, absenteeism and intangible costs such as well-being, life expectancy and quality of life(2). Still, EU legislation on ambient air continues to be breached, every day, in many places across the EU. More than seven years after the entry into force of PM10 limits, such breaches are simply unacceptable. Member states’ notifications for a postponement of the NO2 limit value The Ambient Air Quality Directive 2008/50/EC allows Member States to ask for a time extension to comply with the limits for some pollutants, under certain conditions. We are very pleased with the decisions adopted so far by the European Commission, which reflect a thorough technical assessment of Member States’ notifications and a strict application of the conditions required for obtaining an extension. We would like to encourage you to continue working in this direction, in particular with regards to NO2 notifications which are currently being assessed by your Directorate General. High concentrations of NO2 have been shown to have adverse impacts on human health, including damages to the lungs and increased risks of respiratory problems(3). We ask you to ensure that the derogations are limited to exceptional situations and only to those Member States who can demonstrate that they have taken all possible measures to comply with the limits. In particular, this should include evidence that a set of ambitious actions aimed at reducing traffic-related emissions in cities have been adopted(4). Infringement actions against non-compliant countries Every day that limit values are exceeded results in more costs for society. It diminishes the quality of the life and health of EU citizens. We therefore see no excuse for Member States to fail to comply with EU standards, especially as the health of EU citizens is at stake, and as those limits were negotiated and endorsed by Member States themselves more than ten years ago. One of the most effective ways to put an end to this is by enforcing the EU air quality laws as soon as possible. As Commissioner for Environment, you have a vital role to play in making sure that those Member States who are in breach of the Directive are sent to the European Court of Justice without delay. By doing this, you will stand firm for every European citizen’s right to clean air, regardless of where they live in Europe; be it Lisbon, London, or Ljubljana. We count on your support. Yours Sincerely, Jeremy Wates Secretary General, European Environmental Bureau On behalf of: European Environmental Bureau (EEB) Health and Environment Alliance (HEAL) Transport and Environment (T&E) Client Earth European Respiratory Society (ERS) European Federation of Allergy and Airways Diseases Patients Associations (EFA) Air Pollution & Climate Secretariat (AirClim), Sweden Bond Beter Leefmilieu Vlaanderen (BBL), Belgium Campaign for Clean Air in London, UK Center for Environment and Health, Czech Republic Clean Air Action Group, Hungary Danish Ecocouncil, Denmark Deutsche Umwelthilfe, Germany Ecologistas en Acción, Spain EU Umwelt Büro, Austria Fédération Inter-Environnement Wallonie, Belgium Finnish Association for Nature Conservation, Finland France Nature Environnement, France Friends of the Earth Germany (BUND), Germany Genitori Antismog, Italy Ile de France Environnment, France Institute for Sustainable Development, Slovenia Legambiente, Italy Milieu Defensie, the Netherlands Natuur en Milieu, the Netherlands Naturschutzbund Deutschland (NABU), Germany Society for Sustainable Living (SSL), Czech Republic Verkehrsclub Deutschland (VCD), Germany Zielone Mazowsze, Poland (1) According to a recent study by the European Topic Centre on Air and Climate Change (ETC/ACC) on behalf of the European Environment Agency (EEA), pollution of fine particles is associated with more than 455,000 premature deaths every year in the EU’s 27 member states. (2) See results of EU research project the project APHEKOM: http://www.aphekom.org/web/aphekom.org/home;jsessionid=196F85AD90D285D4755D72CAE82EE61 (3) WHO Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulfur dioxide - Global update 2005 - Summary of risk assessment, Available at: http://whqlibdoc.who.int/hq/2006/WHO_SDE_PHE_OEH_06.02_eng.pdf (4) For examples of successful measures which can contribute to reducing emissions from traffic, see EEB, T&E and AirClim publication “What can be done in our cities to decrease air pollution”, 2011: http://www.eeb.org/index.cfm/library/index.cfm?firstpublications=2&month=0&year=0&Publications=1
14/04/2012	Joint NGO letter: Turning promises into action: achieving the 20% by 2020 energy savings target
10/04/2012	Joint NGO letter on the 7th EAP to EU environment ministers EU Environment Ministers will soon hold a discussion on the content of the 7th EU Environment Action Programme. HEAL and eleven other organizations have written a letter to the EU Environment Ministers asking them raise the concerns of endocrine disrupting chemicals (EDCs), chemical mixtures and nanomaterials, as well as a better protection from substances of very high concern, in order to promote a healthy environment and healthy communities. To: EU Environment Ministers 5 April 2012, Brussels Dear Minister of Environment, Our thirteen organizations are writing to you ahead of the informal meeting of EU Environment Ministers on 17-19 April, to ask you to include measures to address endocrine disruptors (EDCs), chemical mixtures and nanomaterials, as well as a better protection from substances of very high concern (SVHC) in the 7th Environment Action Programme (7th EAP). Recent studies have brought to light alarming evidence showing that urgent action is needed to protect human health and the environment, and public concern continues to be high across the EU. As Environment Minister we ask you to raise these concerns at the April meeting, in order to promote a healthy environment and healthy communities. We are highly concerned about the lack of protection for wildlife and human health due to exposure to EDCs, chemical mixtures, SVHCs, and nanomaterials. Such exposures particularly threaten development in early life and exposure to mixtures of EDCs, in particular, are considered to contribute to the alarming trends in many diseases. It is critical that the future 7th EAP contains concrete and time specific targets, clear objectives, and solution oriented policy recommendations. The 7th EAP should close existing loopholes and provide for better enforcement of existing regulation. In the Annex you may find further information on these four crucial issues. In asking you to ensure that these issues are addressed within the 7th EAP, we do not wish to imply that all action on these topics should await the adoption of the 7th EAP. On the contrary, we consider that certain steps should be taken more urgently, such as the prevention of exposures to hazardous chemicals trough national and EU measures. However the 7th EAP should establish a longer term framework for ensuring that the new scientific findings are fully taken up through the development of specific measures relating to emerging health threats, such as combination effects of chemicals, EDC, SVHC, and nanomaterials. These issues are far from being sufficiently addressed under current EU legislation. We ask you to strongly support these issues and raise them at the informal ministers meeting to ensure that the 7th EAP will protect public health and the environment by swiftly preventing and reducing exposures to hazardous chemicals and making sure the EU will be the front-runner in delivering substitution with better alternatives for both human health and for the environment. In view of the public interest in this matter, we intend to make the contents of this letter more widely available. Thank you for your attention to the matters raised in this letter. Yours sincerely, WECF – Women in Europe for a Common Future, Sascha Gabizon, International Director HEAL – Health and Environment Alliance, Genon Jensen, Executive Director EEB – European Environmental Bureau, Jeremy Wates, Secretary General PAN-Europe (Pesticide Action Network), Hans Muilerman, Chemicals Officer, Pesticides & Alternatives ClientEarth, James Thornton, Chief Executive Officer Health Care Without Harm Europe, Anja Leetz, Executive Director ChemSec – International Chemical Secretariat, Anne-Sofie Andersson, Director CHEM Trust (Chemicals, Health and Environment Monitoring Trust), Gwynne Lyons, Director RES – Réseau Environnement Santé, André Cicolella, Président et porte-parole Swedish Society for Nature Conservation, Mikael Karlsson, President The Danish Ecological Council, Eline Aggerholm Kristensen, Policy officer – chemicals CCOO, Comisiones Obreras, Carlos Martínez Camarero, Confederal Environment Secretariat Bund für Umwelt und Naturschutz Deutschland (BUND), Patricia Cameron, Head of Substances and Technologies Endocrine Disrupting Chemicals (EDCs) Endocrine disruptors are a major environmental health threat. There is a growing body of science which links many harmful human health effects with EDC exposure, such as hormone-related cancers (breast, testicular, prostate), obesity, diabetes, cardiovascular diseases, reproductive health problems and disrupted human brain development. The recent report on the State of the Science on EDCs [1], published by the EU Commission provides alarming evidence that the negative impacts of EDCs are currently being underestimated and that EU legislation is currently not properly addressing this problem. The report highlights the shortfalls in existing test methods but also outlines a way forward. Chemicals Mixtures Every day we are exposed to a mixture of synthetic chemicals, via the air we breathe, the food we eat and the water we drink. And even when the exposure to individual chemicals is below the level where they cause an effect by themselves, new science is now showing that together they can ‘add up’ and cause a potentially dangerous “cocktail effect”. The State of the Art report on mixtures toxicity (Kortenkamp et al, Dec. 2009), commissioned by the European Commission’s DG Environment, states that “there is a consensus in the field of mixture toxicology that the customary chemical-by-chemical approach to risk assessment might be too simplistic. It is in danger of underestimating the risk of chemicals to human health and to the environment”. Current Risk Assessment approaches need urgent revising. Nanomaterials Nanomaterials can be found in a wide range of everyday products such as cosmetics, clothes, sports equipment, paints, food packaging and additives. Because of their novel properties, nanoparticles may present unique risks for human health and the environment. Potential toxicity and ecotoxicity of certain nanoparticles includes damage to DNA, damage to foetal development due to transfer via the human placenta, asbestosis-like diseases and damage to aquatic and terrestrial organisms. The safety tests performed on ‘bulk’ materials are not appropriate for extrapolating to the ‘nano’ level, leaving safety levels unpredictable. The current EU legislative framework is failing to address the risks posed by nanomaterials. REACH does not contain any nano-specific provisions regarding threshold, data requirement, safety assessment or the traceability of nanomaterials [2]. Despite strong pressure from civil society groups, from the European Parliament and a few Member States, the European Commission still refrains from proposing new, adequate tools that would ensure the safe production, use, and end-of-life treatment of nanomaterials. Now that a definition of the term “nanomaterial“ has finally been proposed, the Council must ask the European Commission to take action without further delay. Substances of very high concern (SVHC) in REACH REACH is a great achievement in chemicals management in the EU. However it has some gaps that urgently need to be addressed, in particular the slow pace of implementing the provisions on Substances of Very High Concern (SVHC). We therefore call on you to include in the 7th EAP an affirmation of the policy goal to have by 2020 all “known and suspected” SVHC substituted. It should ensure that sustainable chemistry (and its use) be promoted, in line with the resource efficiency agenda, and that economic instruments be introduced, e.g., a SVHC self-financing mechanism at no cost to government to support achieving objectives in line with the polluter pays principle. Additionally it is necessary to address the gaps in product legislation regarding SVHC. These concerns follow the current 6 EAP goal that “by 2020 chemicals are only produced and used in ways that do not lead to a significant negative impact on health and the environment”. 1 See: http://ec.europa.eu/environment/endocrine/documents/4_SOTA%20EDC%20Final%20Report%20V3%206%20Feb%2012.pdf 2 See CIEL report “Just out of REACH – How REACH is failing to regulate nanomaterials and how it can be fixed”, available at: http://www.ciel.org/Publications/Nano_Reach_Study_Feb2012.pdf 3 Policy makers agreed at the 2002 Johannesburg World Summit on sustainable development that the European Union shall achieve by 2020 that chemicals are produced and used in ways that lead to the minimisation of significant adverse effects on human health and the environment. This political commitment to implement substitution of SVHC by 2020 at the latest is re-affirmed in recitals 4 and 6 of the REACH Regulation. 4 Sustainable use of "sustainable" chemicals aims at providing necessary functions for society as a whole whilst preventing, or where not feasible, minimise negative environmental and health impacts throughout its lifecycle, such as linked to resource consumption and avoidance of hazardous substances. Constant improvements through research and innovation will not only bring advantages to the "knowledge based" EU industry to be leader in sustainable market models, but also protect our workers, consumers and the environment. For more information please consult the EEB/BEUC discussion paper "The path to sustainable use of chemicals in products: the European Ecolabel as a signpost" 5 The concept is a self-financing mechanism with no cost to the government, that operationalises the polluter pays principle by incorporating external costs, drives the solution of substitution while providing solution resources, and saves the government public tax revenue. The result would be a significant financial gain for the government due to no governmental costs, and massive savings through reduced human health costs, and environmental measures/costs. SVHC manufacturers would be subject to a minimal fee, increasing over time, to provide incentives and resources for research, development and implementation for substitute alternative substances that are non- or less-hazardous. The proceeds would go to a “SVHC solutions” fund administered by a government agency.
27/02/2012	EU leaders asked to ensure a high ambition level in the revised Gothenburg Protocol on air pollution HEAL and other organisations urge European leaders to take all necessary steps towards an ambitious revision of the Gothenburg Protocol on air pollution. Every year, air pollution causes nearly half a million premature deaths in the EU 27. Fighting air pollution does not only improve and extend people’s lives. It can also bring huge socioeconomic benefits. To: Mr. Janez Potocnik, European Commissioner for Environment and Mrs. Ida Auken, Minister for the Environment of Denmark Cc: Ministers for Environment of EU Member States and Mr. Karl Falkenberg, Director General, DG Environment G10 EU directors letter: Call for EU leaders to ensure a high ambition level in the revised Gothenburg Protocol on air pollution Brussels, 27th February 2012 Dear Commissioner Potocnik, Dear Minister Auken, From 30 April to 4 May 2012, the parties to the Convention on Long-range Transboundary Air Pollution (CLRTAP), including the EU, will meet and decide on the amendments to the Gothenburg Protocol on air pollution. We are writing as the Green 10 to urge you to take all necessary steps towards an ambitious agreement. Background: the cost of air pollution in Europe Every year, air pollution causes nearly half a million premature deaths in the EU 27. This corresponds to almost 4.5 million years of life lost. In addition to premature deaths, increased hospital admissions, extra medication and millions of lost working days, air pollution causes significant damage to ecosystems, agricultural crops, modern materials, and our cultural heritage. More than 70 % of the EU’s sensitive ecosystem areas are still subject to nitrogen deposition in excess of their critical loads. Fighting air pollution does not only improve and extend people’s lives. It can also bring huge socioeconomic benefits. In the year 2000 only, the health damage from air pollution was estimated to amount to between €277 and €790 billion. By aiming for a level of ambition in line with the so-called High* scenario, the implementation of a revised Gothenburg Protocol could bring monetary benefits that amount to up to €110-290 billion per year in Europe (of which €50-150 billion in the EU27). Those benefits would be up to 55 times higher than the costs involved. In all cases, it is financially worthwhile to fight air pollution. Impacts on the EU’s air pollution policy and 2013 “Year of Air” The revision of the Gothenburg Protocol presents a major opportunity for the EU to significantly improve the air quality in Europe, in line with the ambitions and objectives of the 6th Environment Action Programme (EAP). This could be done by the EU agreeing to strict emission reduction obligations by 2020 for the EU member states, and thereby also pushing non-EU countries in the same direction, which is of great importance since air pollutant emissions in non-EU countries markedly impact ambient air quality and depositions in EU member states. The Protocol’s revision is likely to have major consequences for the EU’s air policy strategy for the years to come, in particular for the long delayed revision of the National Emission Ceilings Directive (NECD) and the ongoing review of the Thematic Strategy on Air Pollution (TSAP). It therefore needs to be as ambitious as possible to provide a strong basis for the proposals expected in EU’s “year of air” in 2013. A high level of ambition under the Gothenburg Protocol will also help fight climate change more efficiently and cheaply. Air pollutants such as nitrogen oxides and volatile organic compounds (VOCs, precursors to ground-level ozone) or black carbon contribute also to global climate change. Cutting their emissions will therefore help both climate mitigation and air quality policies. Recommendations Negotiations under the CLRTAP have so far been a great disappointment as most EU member states and non-EU countries appear to aim for a very low level of ambition, with some member states even hesitating to accept emission reduction obligations in line with the baseline scenario (i.e. assuming solely the implementation of already existing legislation). We therefore urge you to make sure that the EU and other parties to the CLRTAP aim towards: Agreeing a level of ambition for national emission reduction obligations for 2020 that is at least in line with the High* scenario; Adopting ambitious binding emission limit values (ELVs) for specific sources of pollution, preferably at least in line with Option 1 in the draft technical annexes. Currently, the ELVs considered for adoption are either in line with or more lenient than existing EU legislation. Overall, the EU should ensure that levels of air quality are achieved that do not give rise to significant negative impacts on or risks to human health and the environment, as stated in the 6th EAP. Thank you for your support. Yours sincerely, Jeremy Wates, Secretary General, European Environmental Bureau On behalf of the Green 10 Directors Green 10 EU Directors: Angelo Caserta, Regional Director of the European Division, BirdLife International Wendel Trio, Director, Climate Action Network Europe Tony Long, Director, WWF -European Policy Office Anelia Stefanova, Director, CEE Bankwatch Network Jeremy Wates, Secretary General, European Environmental Bureau Genon K. Jensen, Executive Director, Health & Environment Alliance Agnieszka Komoch, Acting Director, Friends of the Earth Europe Christian Baumgartner, Generalsekretär, Friends of Nature International Jorgo Riss, Director, Greenpeace European Unit Jos Dings, Director, European Federation for Transport & Environment
27/02/2012	Letter: ENVI vote on draft report Leinen on 7 EAP – strengthen health and environment concerns to members of the ENVI committee LETTER Brussels, 27 February 2012 Dear Member of the ENVI Committee, This Wednesday, you will be voting on the draft report “Review of the 6th Environment Action Programme and the setting of priorities for the 7th Environment Action Programme – a better environment for a better life” (2011/2194(INI)), rapporteur Jo Leinen. We at the Health and Environment Alliance have several amendments to this report to which we’d like to draw your attention and support. The Health and Environment Alliance HEAL is a leading public interest alliance addressing how the environment affects human health. We welcome that the draft report addresses the public health dimension of environmental protection and the ongoing policy challenges. We also welcome a number of amendments which significantly strengthen the focus, which we recommend to you in detail below. Given that health and environment was a priority for the first time under the current 6th EAP, and many important initiatives were thereby launched in the air quality, chemicals or pesticides areas, it is key to keep this focus in the 7EAP. As the European Environment Agency State of the Environment Report 2010 has highlighted, major differences remain in environmental quality and public health between EU Member States and future EU environmental policies must address this gap. HEAL is especially concerned about the role that environmental degradation plays in the rise of chronic diseases such as cancer, cardio-vascular and respiratory diseases or diabetes. We therefore commend the recent resolution from the European Parliament on chronic diseases in which you called for the environment be considered as a fifth factor in chronic disease prevention. Your vote this week is an opportunity to show how the 7EAP can tackle environmental factors in ill health and provide significant health benefits to Europe, and can help prevent ill health and reduce health care costs. Informed by the science on environmental health, we urge you to take the following concerns into account for your vote this Wednesday Give health & environment challenges more recognition The challenges and emerging health threats outlined above are not yet adequately reflected in the draft report. The following amendments provide greater focus on health consequences from environmental degradation such as air quality, low environmental quality in urban environments and the burden of disease associated with this pollution. Support the following amendments: 2, 3, 6, 12, 13, 17, 18, 19, 29, 63, 66, 122, 125, 175 It is also key that the 7 EAP including the health & environment concerns is sufficiently integrated into other EU strategies and programmes such as the Multiannual Financial Framework and CAP to ensure adequate financial resources for future health and environment activities and research. Support the following amendments: 15, 23 Support reduction of people’s exposure to endocrine disrupting and other harmful chemicals Endocrine disruptors are a major environmental health threat and there is a growing body of science showing the many harmful human health effects that are linked to EDC exposure, such as hormone-related cancers (breast, testicular, prostate), obesity, diabetes, cardiovascular diseases, reproductive health problems and disrupted human brain development. Just last week, the European Commission published a major report on the science on endocrine disrupting chemicals EDCs by a leading scientists on the issue, Professor Andreas Kortenkamp and his team. (see: http://ec.europa.eu/environment/endocrine/documents/4_SOTA%20EDC%20Final%20Report%20V3%206%20Feb%2012.pdf) This report shows the increasing trends of many endocrine-related disorders in humans, and the current potential underestimation of EDC impacts. It also shows the inability of current EU legislation to properly cope with identifying and controlling EDCs, due to limits in the testing and information requirements. With your vote, you can underline the urgency of addressing population-wide exposures to EDCs and other harmful chemicals on a daily basis. Support the following amendments: 112, 113, 116, 117, 119, 128 Help ensure the tracking of pollutants in Europeans Human Biomonitoring is an indispensable tool to trace peoples’ exposure to pollutants, especially for vulnerable groups such as children. Two EU funded projects, COPHES and DEMOCOPHES, are currently developing a framework of EU level biomonitoring and harmonising a biomonitoring exercise among many EU Member States. But to ensure that the lessons learned and skills gained are kept and built upon, the 7 EAP should take over from the EU Action Plan on Environment and Health, which closed in 2010, and become the main policy framework for anchoring future European-level human biomonitoring. Support the following amendment: 121 Protect children as a vulnerable group In March 2010, all EU Environment and Health Ministers pledged their support for the WHO European Region Parma Declaration and Commitment to Act (See: http://www.euro.who.int/en/what-we-...) With this process, the 53 member countries of the WHO region have set time-bound targets to prevent effects on children’s health from environmental degradation. Scientific evidence is mounting on the effects of exposure to pollutants being most critical when they take place in the womb or in early life. This exposure not only negatively impacts children’s growth and development during the pregnancy or shortly after birth, but it can also have effects later in life, for example increasing the risk for cancer or diabetes. With a view to preventing chronic diseases and ensuring the health and well-being of future generations, and to save on healthcare budgets, the 7 EAP should include a specific strategy to protect children’s health. Support the following amendments: 120, 124, 127 Put health concerns at the heart of EU climate change policy Climate change is one of the biggest challenges for public health for the 21st century, and the health community is increasingly involved in climate change discussions and decisions. Public health concerns from a changing climate include health effects from temperature changes, extreme weather events, prolonged allergy seasons etc. But many studies also show the benefits to public health from the move to a low-carbon economy, for example as a result of cleaner air or increased walking+cycling. Within the EU’s climate and energy policy, health concerns do not yet play the role they deserve. The 7 EAP should strengthen and expand the cost benefit assessments to include health costs such as those related to ill health (morbidity) and the health co-benefits of various policy measures in EU climate discussions to reduce GHGs and improve energy choices. Support the following amendments: 46, 48 In conclusion, the 7 EAP will be the framework and strategic outline for EU environmental policy for the next years, and we hope that you will strengthen environment and health considerations within it. Best regards, Genon K. Jensen Executive Director Health and Environment Alliance Health and Environment Alliance (HEAL) 28 Boulevard Charlemagne, B1000 Brussels, Belgium phone:+32 2 234 3640 \| fax: +32 2 234 3649 \| e-mail: info@env-health.org \| www.env-health.org
23/02/2012	Joint letter: Support for phase-outs of mercury use in dentistry in the EU and globally to EU Environment Ministers 23 February 2012 - Since high quality and cost-effective alternatives to dental amalgam are readily available, we believe that dental amalgam use should be phased out and time-tables for such action should be supported at both the EU and global levels. The national governments of the world are now negotiating a legally binding treaty to address the global mercury crisis that is endangering our environment and health. To: EU Environment Ministers, Cc: Commissioner Potocnik and Director General Falkenberg Re: Joint Letter: Support for phase-outs of mercury use in dentistry in the EU and globally 23 February 2012 Support for phase-outs of mercury use in dentistry in the EU and globally Dear Environment Minister, As you know, the national governments of the world are now negotiating a legally binding treaty to address the global mercury crisis that is endangering our environment and health. According to United Nations Environment Program, the use of dental amalgam fillings constituted a global mercury consumption of about 313-411 tons annually, thus being among the largest consumer uses of mercury in the world.1 Since high quality and cost-effective alternatives to dental amalgam are readily available, we believe that dental amalgam use should be phased out and time-tables for such action should be supported at both the EU and global levels.2 As you may be aware, the European Commission (EC), under the Review of the Community Strategy Concerning Mercury3 has decided to undertake a full lifecycle assessment of the mercury use in dentistry. BIO Intelligence Service is now carrying out a Study on potential for reducing mercury pollution from dental amalgam and batteries for the EC, the results of which are expected in Spring 2012. Member states have been asked to answer a questionnaire and provide all relevant national data, and if your country has not yet done so, we respectfully request that your administration do its utmost to respond to this request in the most thorough and timely way. Although the relative health impacts from direct exposure from amalgams are still being debated, the significant contribution of dental mercury waste and its persistence in the environment are certain4. In the EU, mercury in dental tooth fillings is the second largest use of mercury, comprising 23.5% of the annual consumption, equal to 90-110 tonnes of mercury in 2007.3 In reviewing mercury releases to the environment from dental amalgam use, it has been estimated that: 35-50 tonnes end up in various environmental media, of which 45-60% to the soil (via wastewater sludge to land disposal, burial of deceased persons with fillings, atmospheric deposition following cremation or wastewater sludge incineration, etc.), 5-15% into the atmosphere (via cremation, etc)5, 10-20% to surface waters and eventually 5-15% to groundwater6. Once dental mercury has been used, there are a number of “end-of-pipe” techniques to prevent it from entering the environment, but each comes at a (sometimes very high) cost, and may not be as effective as intended. Further, the broad application of “end-of-pipe” techniques throughout the EU is severely limited, particularly in regard to mercury abatement from cremation (which is increasing).7 While most dental professionals continue to charge somewhat lower prices for amalgams, it’s increasingly clear that the full ‘external’ costs borne by the rest of society are high, when the full range of environmental and potential health ramifications are taken into account.8 Ultimately, society pays for the uncontrolled releases of mercury from dental amalgam through additional pollution control costs, the loss of common resources, and the health effects associated with mercury contamination.9 The most cost-effective and environmentally responsible solution to the dental mercury problem is its rapid phase out, since there are a range of affordable mercury-free alternatives. Regarding the availability of alternatives, the Swedish experience, among others, has proven that there are very few cases where a compelling argument can be made that amalgam fillings are ‘necessary.’ This is also backed up by the EU Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR 2008), which concluded in their study “that dental health can be adequately ensured by both types of materials” (i.e. mercury-free alternatives and amalgam), noting that alternatives have been in clinical use for over 30 years, and revealed little evidence of clinical significant adverse effects to date10 . Further, a 2011 World Health Organization (WHO) report, Future Use of Materials for Dental Restoration, acknowledges concerns about environmental releases of dental mercury. It also recognizes the need “to prepare for a treaty on mercury use,” stating that “the Geneva meeting encourages a global ‘phasing down’ of dental amalgam,” including support for use of dental material alternatives to amalgam.11 Leading up to and during the 3rd Intergovernmental Negotiating Committee meeting in November 2011, the Nordic Council12, Switzerland, and the African Region, expressed support for a dental amalgam phase out. In addition, the Council of Europe recently passed a resolution calling on nations to start “restricting or prohibiting the use of amalgams as dental fillings.”13 Clearly, the environmental pollution from dental amalgam and health consequences from indirect exposures14 are significant, and the precautionary principle further obliges us to take a pro-active stand with regard to potential health risks from direct amalgam exposures. To that end and considering all of the above, we call on you to swiftly submit any additional relevant information to the EC per the earlier BIOS request, and at the same time send a clear message that you support phase-outs of mercury from dentistry at the EU level and globally. Thank you in advance for your attention to this important environmental and health issue. Yours sincerely, European Environmental Bureau (EEB): Jeremy Wates, Secretary General Health and Environment Alliance (HEAL): Genon Jensen, Executive Director Zero Mercury Working Group (ZMWG): Michael Bender and Elena Lymberidi-Settimo, International coordinators Health Care Without Harm Europe (HCWHE): Anja Leetz, Executive Director 1http://www.chem.unep.ch/mercury/Atmospheric_Emissions/Technical_background_report.pdf. p.20 2 With possible limited exemptions for specific medical conditions 3 COM(2010) 723 final, COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the review of the Community Strategy Concerning Mercury 4 http://ec.europa.eu/environment/che... 5 The Cremation Society of Great Britain provides rather comprehensive statistics on cremations in the EU-27 (CSGB 2004), amounting to nearly one-third of all EU deaths, and based on previous assumptions, releasing about 4.5 tonnes of mercury annually. Since then, the rate of cremation has increased significantly. There are two simultaneous trends contributing to this: a rise in the average number of fillings per person cremated (due to increasing numbers of original teeth), and a rise in the number of cremations. It has estimated that the amount of mercury from cremations will increase in the UK by two-thirds between 2000 and 2020, accounting for between 11% and 35% of all mercury emissions to the air in 2020. The upper figure is consistent with UK emissions as reported to UN/ECE and EU. These conclusions reinforced those of Tauw Milieu (Coenen 1997, as cited by Defra 2003) that predicted for the Netherlands a doubling of mercury emissions from crematoria between 1995 and 2020, and a 68% increase for the period 2000 to 2020. For more information, see EEB/Concorde sprl ‘Mercury in Dental Use: Environmental Implications for the European Union’, May 2007 6 COWI/Concorde for DG Env ‘Options for reducing mercury use in products and applications, and the fate of mercury already circulating in society’, September 2008 and EEB/Concorde sprl ‘Mercury in Dental Use: Environmental Implications for the European Union’, May 2007 7 Ibid. 8 Hylander & Goodsite 2006, Maxson 2006 Environmental costs of mercury pollution, Science of the Total Environment 368 (2006) 352–370 9 http://mpp.cclearn.org/wp-content/uploads/2008/08/finalreportfrommpptestimony0707081.pdf 10 http://ec.europa.eu/health/ph_risk/... 11 http://www.who.int/oral_health/publ... 12 http://www.norden.org/en/publications/publikationer/2010-738 13 Parliamentary Assembly of the Council of Europe, Resolution 1816 (2011), available at http://assembly.coe.int/Mainf.asp?link=/Documents/AdoptedText/ta11/ERES1816.htm 14 Studies have demonstrated that a certain portion of this dental mercury becomes bioavailable, and may constitute a significant source of risk to human health and the environment, Stone et al. (2005) – ME Stone, ME Cohen, L Liang and P Pang, Determination of methyl mercury in dental-unit wastewater, Dental Materials 19 (2003) 675–679, Elsevier Ltd.
03/02/2012	Joint NGO letter: Comments to DG ENV on the analysis underpinning the review of EU air quality policy
29/11/2011	Joint letter to MEPs on air pollution from ships HEAL joined many environment and trade organizations in a call to MEPs for stricter standards for the sulphur content of marine fuels. The health and environment impacts of air pollution from ships are a major worry in Europe. Berlin, 29 November 2011 To: Members of European Parliament; Committee for Environment, Health & Public Safety; Committee for Transport & Tourism Re: Amendment of Directive 1999/32/EC: The EU should fully transpose IMO Marpol Annex VI and support the implementation of stricter standards on the sulphur content of marine fuels. Dear members of the Committee for Environment, Health and Public Safety Dear members of the Committee for Transport and Tourism, The signatories of this letter, representing various European environmental, health and labor associations, would like to express their deep concern at recent calls from certain (shipping) industry groups to weaken stricter rules on the sulphur content of marine fuels due to enter into effect in 2015 in European Emission Control Areas (ECAs). These calls amount to an open attack on existing regulations that are essential for our health and environment. Conversion to low sulphur marine fuels is environmentally necessary and long overdue. Bunker fuel currently used in shipping is essentially toxic waste. The stricter IMO (International Maritime Organization) standards have been known since 2008. They were strongly and publicly supported by the EU when adopted unanimously at the IMO into international law. They are therefore binding on all 23 EU Member States that ratified the relevant (MARPOL) IMO Convention1. The European Union must clearly stand behind the new sulphur requirements, which set a 0.1% sulphur limit in designated ECAs in 2015 as well as a global 0.5% limit in 2020. More and more ship builders and owners have already reacted and invested in cleaner and more efficient ship technologies in anticipation of the new regulations. Why should the early movers be penalized by governments bowing to sections of industry by delaying implementation of the new limit values or reverting to old standards? The use of low sulphur distillate fuel also provides good incentives for reducing fuel consumption and is a prerequisite for the use of particle filters, which can reduce particulate matter (PM) by up to 99%. The new limits are therefore an important step to reduce overall ship emissions. Ideally we should have ECAs all around Europe; the Mediterranean alone accounts for half of all EU ship emissions. Designation needs to be done via the IMO. To achieve this, the European Commission needs to provide the leadership and technical advice to support those Member States proposing to designate additional ECAs. The successful joint proposal of the United States and Canada for the designation of a distance-to-shore ECA covering the sea area out to 200 nautical miles (370 kilometers) from their coast (entering into force next year) and the consideration of Japan and Hong-Kong to implement ECAs shows that the EU should also take a comprehensive approach to create the same environmental and economic conditions in all European sea areas. Conversely if the EU as a whole or a single Member State were to step back from global regulations already adopted at the IMO this would send a disastrous signal to the IMO and every other nation heading for clean shipping. The proposed amendments to the directive2 will also underpin port state authority to police the new regulations. The health and environmental benefits of coastal ECAs in Europe would be outstanding. Tightened emission and fuel standards will help the shipping industry to develop more fuel and energy efficient ships and become a lead market for cleaner shipping. In view of the public interest in this matter we are making a copy available to certain media. Thank you for your attention to this important and urgent matter. On behalf of the supporters and the signatories of this letter, Yours sincerely, Olaf Tschimpke, President NABU e.V. on behalf of the Soot free for the Climate Campaign Meinhard Geiken, Regional head IG Metall Bezirk Küste (Industrial Metal Workers’ Union Coastal Region) Supporting organizations: Soot free for the Climate Campaign Friends of the Earth, Germany German Environmental Aid, Germany Verkehrsclub Germany Nature and Biodiversity Conversion Union, Germany World Wide Fund For Nature, European Policy Office, Brussels European Environmental Bureau, Europe, Brussels Health and Environmental Alliance, Europe, Brussels Transport and Environment,Europe, Brussels Air Pollution and Climate Secretariat, Sweden Fédération France Nature Environnement, France Stichting Natuur en Milieu, Netherlands Verkehrsclub Austria Det Økologiske Råd, Danmark IG Metall Bezirk Küste/ Industrial Metal Workers’ Union Coastal Region, Germany Fédération Générale des Mines et de la Métallurgie (FGMM-CFDT), France Federacion de industria, Spain Federatie Nederlandse Vakverenigingen (FNV) Bondgenoten, Netherlands 1 Annex VI to the MARPOL Convention, adopted in 1997, entry into force in 2005 2 set out in COM(2011)0439 View signed letter here.
21/11/2011	HEAL letter on ENVI discussion on Energy Efficiency – Indoor air quality and health concerns
13/09/2011	To: EU Health Commissioner, John Dalli; and President of the European Commission, José Manuel Barroso; European Commissioner for the Environment, Janez Potocnik; Members of the European Parliament; WHO focal points for environment and health Re: United Nations High-level Summit on Non-Communicable Diseases (NCDs), 19-20 September 2011 Brussels, 13 September 2011 OPEN LETTER Dear Commissioner Dalli, Show EU leadership by putting environmental prevention on the agenda The Health and Environment Alliance (HEAL) is writing to you today to urge you to put "Environment and Health" onto your policy agenda for the United Nations Summit on non-communicable diseases (NCDs) later this month. HEAL is the leading European not-for-profit organisation addressing how the environment affects health in the European Union. We demonstrate how policy changes can help protect health and enhance people’s quality of life. HEAL’s more than 65 member organisations, representing health professionals, patients, citizens, women, youth and environmental experts, help to bring independent expertise and evidence from the health community to different decision-making processes. Members include international and Europe-wide organisations, as well as national and local groups. HEAL is both astounded and very disappointed to note that the draft documents for the UN High-Level Summit ignore the role of environmental factors in causing chronic illness, such as lung conditions, cancer, heart disease, obesity, diabetes and other non-communicable conditions. Given the body of scientific evidence linking air pollution, hazardous chemicals, and radiation to chronic disease, how can the policy measures to tackle these threats be left off this important agenda? Why add the "environment" as a fifth factor? HEAL agrees with fellow leading non-governmental organisations represented in the European Chronic Diseases Alliance (ECDA) that prevention must be the number one priority and that four key lifestyle factors must be addressed, namely tobacco, poor diets, alcohol and lack of physical activity. But environmental causes must be added as a fifth factor. A huge opportunity for primary prevention of chronic disease will be missed if equal focus is not given to reducing peoples' everyday exposure to threats from environmental degradation, including from exposure to harmful chemicals. Exposure to air pollutants alone is responsible for an estimated 450,000 premature deaths each year in Europe. The EU's has long played a visionary role in bringing environmental factors to disease prevention. This commitment was already evident in 2003 when the environment and health strategy was launched, followed by an action plan in 2004. In 2010, the European Parliament underlined this focus on environmental health prevention by calling for the European Partnership for Action against Cancer to "include a component on environmental factors, these being defined as not only environmental tobacco smoke, radiation, and excessive UV exposure, but also hazardous chemicals in the indoor and outdoor environment to which people are exposed, including endocrine disruptors". A wealth of EU research now links environmental factors to disease. Research also demonstrates how reducing environmental exposures through effective policy and legislation prevents ill-health. The effect of air pollution on chronic disease has been scientifically recognised and widely known for 20 years and the EU has adopted a wide range of policy measures. Today, attention is turning to the potential of environmental policy change in cancer prevention. Immediately prior to a World Health Organization meeting in Asturias, Spain on Environmental and Occupational Determinants of Cancer: Interventions for Primary Prevention earlier this year, the New England Journal of Medicine, March 2011, wrote: "The most valuable approaches to reducing cancer morbidity and mortality lie in avoiding the introduction of carcinogenic agents into the environment and eliminating exposure to carcinogenic agents that are already there." A second reason why environmental factors must be brought to the agenda is the risk of further chronic disease as a result of climate change. Like many other regions of the world, Europe is seeing a growing number of extreme weather events. Climate change in Europe will affect air quality producing increased incidence of heart and respiratory conditions, especially during heat waves. The European Respiratory Society has shown that deaths and hospital admissions rise substantially as temperatures in cities rise above certain levels. A third and equally important reason why the environmental factor must become a focus at the UN Summit is the threat of chronic non-communicable disease to children. At the WHO Fifth Ministerial Conference on Environment and Health in Parma in March 2010, you showed your commitment to tackling children's environment and health by supporting time-lined targets in action plan agreed there. At that meeting, you mentioned the growing incidence of asthma and allergy, with one in every five children in Europe suffering from a chronic respiratory condition or allergy. Other childhood conditions of growing concern, including cancer, obesity and diabetes, are also linked to environmental exposure. Childhood cancers are increasing at a rate of more than 1% per year in Europe, and rates of obesity and diabetes are reaching epidemic proportions. The growing burden from environment-related ill-health in children is reflected in health care costs. A recent review in the US estimated health costs of children's environmental illness at 3.5% of the nation's total budget, up from 2.8% in a similar study in 1997. Such a toll is a problem not only for health finances but more importantly, it represents a threat to Europe's future. Yet, despite the likely contribution to increasing rates of chronic disease, the important role that environmental policy change can play in primary environmental prevention may hardly be mentioned at the talks. Environmental prevention pays for itself As EU Health Commissioner, you are ideally suited to present the case for a greater emphasis to be given to environment and health at the UN Summit. The European Union has a strong track record and recognised leadership role in environmental health and can present examples of environmental policy changes that, by reducing chronic disease, more than pay for themselves. The number one example is the EU's strong backing for tobacco control. Smoke-free public places legislation is already saving lives and improving health across the European region, according to WHO. Studies from countries that enforce bans on smoking in public places are finding reductions in heart attacks, with scientific literature indicating that hospitalisation rates for myocardial infarctions are decreasing by 20–40%. Further improvements in air quality could reduce many of the estimated 450,000 deaths that occur each year due to exposure to air pollutants. Recent EU-funded (DG SANCO) research project Aphekom showed that improving air quality in European cities would be especially beneficial for children. Both EU and US studies show that the costs of changes to improve air quality more than pay for themselves. Most recently, the US Environment Protection Agency (EPA) concluded that the health benefits achieved from policies aimed at cleaner air "far exceed" the costs of implementing clean air protection. Another example of cost-effective legislation is the EU's pioneering chemical policy. Although it is too early to assess the impact of this legislation, a European Commission assessment of REACH prior to its introduction stated that if this legislation succeeds in reducing chemical-related diseases by only 10%, the health benefits are estimated at 50 billion Euros over 30 years. This corresponds with 2,200 to 4,300 fewer cancer cases in the workplace annually. Finally, the extremely good news: a proportion of chronic disease can be prevented as a "by product" or "co-benefit" of certain climate change policy. For example, HEAL has shown that if the EU were to move promptly from the current 20% target on greenhouse gas emissions reduction to a 30% target for climate change, the public health benefits in terms of reduced respiratory and heart disease could reach 30.5 billion Euro per year in 2020. The leading medical journal, the Lancet, has also looked at the co-benefits for health of climate change policy. One example shows that transport policy aimed at reducing carbon emissions (encourage more walking and cycling, restriction of car travel, lower-carbon-emission motor vehicles) could prevent a substantial proportion of the following chronic diseases: cardio-vascular, diabetes, breast and colon cancer, dementia and depression. The synergies of climate and health policy in relation to air quality, clean energy and "active transport" are highlighted in the EU's "Low-Carbon Roadmap 2050”. Meeting the democratic challenge The European Chronic Disease Alliance represents the views of several million health experts and citizens. HEAL and its large membership joins them in the call for putting prevention first and setting targets and well-resourced commitments. We also support their recommendation to address the four key factors. In addition, HEAL would like to ensure that conflicts of interests are avoided in expert consultations in order to protect environmental health. However, we are writing primarily to urge you to add the environmental factor as an important agenda area in the prevention of chronic disease. European citizens are clearly worried about exposure to chemicals and other environmental pollutants. A recent Eurobarometer shows that pesticide residues in food are a number one worry for 72% of EU consumers, a higher percentage than in 2005. European governments also want renewed investment and action in "Environment and Health". In December 2010, EU environment ministers gave clear backing for a second Environment and Health Action Plan (EHAP). In particular, they asked that one of the priorities would be to address children's environment and health as "identified in the Parma Declaration on Environment and Health". HEAL hopes very much that you will decide to bring the huge potential of environmental prevention of chronic disease to the agenda in the UN High-level Meeting on chronic, non-communicable diseases in New York later this month. We believe that this addition will create inspiration and visionary impact to the global discussions. We would welcome a meeting with you to discuss this further. Yours sincerely, Genon Jensen Executive Director Health and Environment Alliance (HEAL) Attachment: HEAL fact sheet - Chronic disease: How do environmental factors play a role?
05/09/2011	To: Ban Ki-moon, United Nations Secretary General; Dr Margaret Chan, World Health Organization Director General Re: Call for diseases and risk factors to be considered September 5th, 2011 Dear United Nations Secretary General, Dear World Health Organization Director General, We welcome the joint initiative by the United Nations and the World Health Organization to host a high-level expert committee meeting on the prevention and control of non-communicable diseases, with a specific focus on the poorest countries of the world, during the UN General Assembly Session to be held in New York on the 19th and 20th September, 2011. We welcome the recognition by Heads of States of the seriousness of this global threat for all populations worldwide, assessed in the following terms: Non-communicable diseases account for over 63% of deaths in the world and further increases are expected, in particular in the African region; 29% of these deaths concern people under 60 years of age, living in low-and-middle income countries; We deem it legitimate to qualify, as you did, this global trend of “epidemics” and “imminent catastrophe, a catastrophe for health, society and all the more for national economies”. We share the analysis that non-communicable diseases can no more be considered only as a medical or public health issue but are closely connected to development policies and raise political concerns. We know that the prevention of these diseases can be done at two levels: individual and collective. Therefore, Governments of countries of the world have an ethical responsibility to act to prevent part of these diseases. We support the recommendations of limiting tobacco use and of a healthy diet, low in refined sugars, saturated fats and salt and we cannot accept that economic interests undermine the efforts of the international health community to help populations change behaviors in a responsible way. We consider it necessary for global health of the world population to also consider some other noncommunicable diseases as well as other exposures, beyond the ones which are amenable to behavioral interventions. Namely, we call for the inclusion in the UN resolution of neurologic and psychiatric disorders as well as reproductive problems, in addition to cancers, diabetes, cardiocerebro- vascular and respiratory diseases, as they do represent a significant share of the morbidity and are influenced by environmental risk factors. We also urge for a serious consideration when dealing with occupational factors of disease, of the issues of child labor as well as the specificity of women in the work force, in terms of sensitivity to potential toxics during reproductive years while also keeping in mind the issue of equal men treatment and pay at a comparable position and with similar education, training and experience. Among the risk factors to be considered, the physico-chemical pollution of air, water, food, soil and objects of daily living is of major concern. This corresponds to the presence in our general, occupational and domestic living environment of carcinogens, teratogens, endocrine disruptors and other toxic agents, ranging from indoor and outdoor air pollution, poor quality drinking water, food supply contaminated by pesticide and medicinal drug residues to exposures at the workplace, in particular in countries with no occupational medicine, industrial hygiene or any other form of worker protection, and with frequent legal or illegal child labor. We are concerned about the effects of these chemical and physical (ionizing and non-ionizing radiations, such as EMF emitted by cell phones) agents in the population as a whole, but even more so among susceptible groups, such as women of reproductive age, children and disadvantaged individuals. The only effective way to protect the world population is to act at a global level, in particular through legislation at the national level and a framework convention at the international one. The text of the UN Resolution needs to make clear statements and propositions such as the ones unanimously adopted during one of the preparatory meetings in Asturias which listed, among others the following key recommendations: “1. Prevention of the environmental and occupational exposures that cause cancer must be an integral component of cancer control worldwide. Such prevention will require strong collaboration across sectors … and among countries, and also with civil society and the media.” …. “4. All countries to adopt and enforce legislation for protection of populations, especially the most vulnerable populations, against environmental and occupational cancers.” ……. “6. Corporations to comply with all rules and regulations for prevention of environmental and occupational cancers and to use the same protective measures in all countries, developed and developing, in which they operate.” … These measures if they are implemented will have a much larger impact than the one on cancer. In fact, many carcinogens are also reproductive hazards or just simply toxic for several organs in humans (brain, kidney, liver, etc.). By removing them from our environment or at a minimum limiting exposure to them, we can significantly contribute to making the children of today and future generations healthier. We kindly request you to consequently complete the list of diseases and priority risk factors to reflect up to date scientific evidence and demonstrate the care Governments take of the health of their populations, being audacious enough to put the health of all ahead of the wealth of the few. Yours sincerely, This letter is signed by individual scientists and health professionals from many institutions around the globe. Their work affiliation is given for information of the readers and for identification purposes, but this should not be considered as any form of endorsement of the universities, research centers and other organizations which names appear on the following list. For members of non governmental organisations involved in the health and/or environment fields, name of an individual was most often a reflection of an official endorsement by the NGO, but this was not systematic. Europe France : Dr Annie J. Sasco, MD, MPH, MS, DrPH, HDR, Directrice de Recherche à l’Institut National de la Santé et de la Recherche Médicale (INSERM), Epidemiology for Cancer Prevention, Team on HIV, Cancer and Global Health, Inserm U 897, Bordeaux Segalen University, Bordeaux André Cicolella, Président du Réseau Environnement Santé, Conseiller scientifique à l’Institut National de Recherche et de Sécurité (INERIS), Paris Elisabeth Ruffinengo, Advocacy Officer, Women in Europe for a Common Future, Annemasse Sarah Anaïs Andrieu, Anthropologist, Ecole des Hautes Etudes en sciences sociales (EHESS), Paris Dr Xavier Anglaret, MD, PhD, Directeur de Recherche Inserm, Team on HIV, Cancer and Global Health, Inserm U 897, Bordeaux Segalen University, Bordeaux Dr Geneviève Barbier, International Society of Doctors for the Environment-France, Paris Anne Barre, Présidente du Women in Europe for a Common Future (WECF) France, Annemasse Geoffrey Begon, Lyon Pr Dominique Belpomme, MD, PhD, President International Society of Doctors for the Environment (ISDE)-France, Paris Dorothée Benoit-Browaeys, Déléguée Générale de VivAgora, Paris Bernadette Bensaude Vincent, Directrice du CETCOPRA, Paris 1-Sorbonne University, Présidente of VivAgora, Paris Nadège Bourvis, MPH, Psychiatric Intern, Paris Dr Nita Chaudhuri, PhD, Health Promotion and Environment Expert, Paris Jacqueline Collard, Présidente Association Santé Environnement Rhône-Alpes (SERA), Grenoble Nadia Collot, Founder CaméraSanté, Paris Madeleine Decoin, RN, GECSA, Inserm U 897, Bordeaux Segalen University, Bordeaux Natalia Dejean, Directrice WECF France, Annemasse Pr Michel Delcroix, Président d’Apri-Maternités sans Tabac, Bailleu Duccia Farnetani, Environmental engineer, Paris Jean-François Gonnet, toxicologue, Lyon Catherine Gouhier, Centre de Recherche et d’Information Indépendantes sur les Rayonnements Electromagnétiques (CRIIREM), Le Mans Marie Grosman, Non au Mercure dentaire, Lyon Dr Philippe Irigaray, PhD, International Society of Doctors for the Environment (ISDE)-France, Paris Laure Lachetallier, Vice-Présidente, Action Sociale, Handicap et Santé, Conseil Régional Île-de-France Nadine Lauverjat, Générations Futures, Paris Alain Lefranc, éco-electricien, Paris Madeleine Madoré, Docteur en pharmacie, Paris Pr Denis Malvy, MD, PhD, University Professor and Hospital Practitioner, Directeur Centre René Labusquière, Bordeaux Segalen University, and Services de Médecine Interne et Maladies Tropicales, Santé des voyageurs, Hôpital Saint-André, Bordeaux Dominique Martin-Ferrari, Journaliste, Gaïa Network, Paris Dr Marisa Mena, PhD, MS, Epidemiology for Cancer Prevention, Team on HIV, Cancer and Global Health, Inserm U 897, Bordeaux Segalen University, Bordeaux Dr Gérard Ostermann, Médecine interne, Bordeaux Dominique Ounadjela, Membre du Conseil d’Europe Ecologie Les Verts Ruth Peron, Vénissieux Catherine Ramm, Paris Dr Philippe Renaudier, MD, MS, Président du Conseil Scientifique de la Société Française d’Hémovigilance, Lyon Eva Fleur Riboli-Sasco, MS, Student in Anthropology and International Development, Paris Michèle Rivasi, Députée au Parlement Européen, Groupe Verts/ALE Dr Clément Rossignol, PhD, Junior Researcher Physicist, Centre National de la Recherche Scientifique, Deputy Chairman Bordeaux Community, Bordeaux Pr Gilles-Eric Séralini, President of CRIIGEN Scientific Council, Co-Director of Risk Pole, Quality and Sustainable Environment - MRSH- CNRS, University of Caen - Institute of Biology IBFA Laboratory Estrogens and Reproduction, Caen Diana Smith, Health and Environment Communications and Media Consultant, Paris Olivier Toma, Président du Comité pour le Développement Durable en Santé (C2DS), Paris Bellancille Uwamaliya, GECSA, Inserm U 897, Bordeaux Segalen University, Bordeaux François Veillerette, Spokesman of NGO Générations Futures, Expert on pesticide/chemicals issues, Paris Belgium: Corinne Lepage, Députée au Parlement européen, Brussels Henriette Christensen, Senior policy adviser, Pesticide Action Network Europe, Brussels Marie-Christine Dewolf, Project manager, Hygiène Publique en Hainaut asbl, Mons Pr Luc Hens, PhD, Vlaamese Instelling voor Technologisch OnderZoek (VITO), Mol Genon Jensen, Health and Environment Alliance (HEAL), Brussels Dr Jean Pauluis, Président de la cellule environnement-santé, Société Scientifique de Médecine Générale (SSMG) Tony Tweedale, MS, Rebutting Industry Science with Knowledge (R.I.S.K.) Consultancy, Brussels Bulgaria: Valentina Lukova, Executive director, My Right to Know Foundation, Sofia Czech Republic: Daniela Pelclova¡, MD, PhD, Professor of Occupational Medicine, Charles University and Department of Occupational Medicine of 1st Faculty of Medicine and General Teaching Hospital, Prague Germany: Alexandra Caterbow, Coordinator Chemicals and Health Women in Europe for a Common Future, Munich Greece: Adamantia F. Fragopoulou, MSc, PhD Candidate, Department of Cell Biology and Biophysics, Athens University, Athens Pr Lukas H. Margaritis, PhD, Professor Emeritus, Department of Cell Biology and Biophysics, Athens University, Athens Pr Polyxeni Nicolopoulou-Stamati, MD, PhD, Environmental Pathology, Medical School National and Kapodistrian University, Athens Tatiana Styloglou, entrepreneur, Athens Hungary: Zsolt Horváth, Director Clean Air Action Group, Attila Szuhi, On Crossroads Foundation Italy: Dr Fiorella Belpoggi, MD PhD, Director, Cesare Maltoni Cancer Research Centre, Ramazzini Institute, Bentivoglio Dr Franco Berrino, MD, Department of Epidemiology, National Cancer Institute, Milan Dr Ernesto Burgio, MD, Scientific Office President, International Society of Doctors for the Environment (ISDE) Pr Massimo Crespi, MD PhD, Fellow Collegium Ramazzini, Roma Antonietta Gatti, Engineer, Visiting Professor of the Institute for Advanced Sciences Convergence (DoD, USA), Coordinator of the Italian Institute of Technology's Project of Nanoecotoxicology called INESE, Modena Dr Livio Giuliani, MD, Dirigente di Ricerca, Direttore di Dipartimento ISPEESL, Roma Pr Roberto Lucchini, MD, Professor of Occupational and Environmental Health, Department of Experimental and Applied Medicine, University of Brescia, Brescia Republic of Ireland: The Hon. Desmond Guinness, Leixlip Castle, Leixlip, Co. Kildare John Weigel, Dublin Luxembourg: Maryse Arend, Director Initiativ Liewensufank asbl Republic of Macedonia: Dr Tomica Ancevski, Association of Doctors for the Environment (MADE), Kumanovo Natasha Dokovska, Journalist, Journalists for Human Rights Malta: Sarah Cardona, Action for Breast Cancer The Netherlands: Peter van Hazel, INCHES Sascha Gabizon, International Director, Women in Europe for a Common Future (WECF), Utrecht Dr Livio Riboli-Sasco, PhD, Utrecht Spain: Francisca Gutiérrez Claverho, Presidenta Asquifyde (Asociacion estatal de afectados por los sindromes de sensibilidad quimica, fatiga cronica, fibromialgia y para la defensa de la salud ambiental) María López Matallana, Presidenta de SFCMadrid. Asociacion de Afectados por SFC y por SQM de la Comunidad de Madrid Clara Valverde, President, Liga SFC/EM (Chronic Fatigue Syndrome/ME League) Marga Santamaria, ANDAFED Asociacion Nacional de Afectados por Dimetilfumarato Sweden: Pr Olle Johansson, Associate Professor, Experimental Dermatology Unit, Department of Neuroscience, Karolinska Institute and Professor, The Royal Institute of Technology, Stockholm United Kingdom: Pr Martin Bobak, Professor of epidemiology, Department of Epidemiology and Public Health, University College London, London Hope Daley, UNISON, Public Sector Trade Union Clare Dimmer, Chair Breast Cancer UK Diana Dowling, Breast Cancer Pr Vyvyan C. Howard, MB, ChB, PhD, FSB, FRCPath, Nano Systems Biology, Centre for Molecular Bioscience, University of Ulster Laurie Kazan-Allen, Coordinator, International Ban Asbestos Secretariat, London David Kidney, Head of Policy, Chartered Institute of Environmental Health, London Helen Lynn, Alliance for Cancer Prevention, Gwynne Lyons, CHEM Trust John McClean, National Health and Safety Officer, GMB Trade Union Pr Rory O'Neil, Occupational and Environmental Health Policy Research Group, Stirling University, Scotland: Dr Erhabor Osaro, Royal Bolton Hospital, National Hhealth Service (NHS) Trust Bolton Jamie Page, Chief Executive, the Cancer Prevention and Education Society, England and Wales Hilda Palmer, Hazards Campaign, Manchester Morag Parnell, Women’s Environmental Network Pr Andrew Watterson, PhD, CFIOSH, Professor of Health, Director of the Centre for Public Health and Population Health, Head of the Occupational and Environmental Health Research, University of Stirling, Stirling Africa and Middle-East Benin: Wilfried Affodegon, Directeur Exécutif, Centre Africain de Recherche et d’Action pour le Développement (CARAD), Cotonou Ghana: Emmanuel Odjam-Akumatey, Executive Director Ecological Restorations Dr Beatrice Wiafe, MD, PhD, President Breast Care International, CEO Peace and Love Hospital, Kumasi Jordan: Pr Dr. M. S. Al Salameh, Author and Academic, Jordan University of Science & Technology Lebanon: Elias R. Chedid, Attorney at Law South Africa: Professor Mohamed Jeebhay, Centre for Occupational and Environmental Health Research, University of Capetown Pr Leslie London, Director School of Public Health and Family Medicine, University of Capetown, Capetown Americas Argentina: Carolyn Stephens, PhD, FFPH, IFRSM, Profesora Titular Visitante en Ecologa y Salud Indegena, Facultad de Medicina, Universidad Nacional de Tucuma¡n and Reader in Ecology and Global Health, London School of Hygiene and Tropical Medicine Brazil: Zuleica Nycz, Director of Toxisphera Environmental Health Association Pr Paolo Saldiva, MD, PhD, Coordinator of the National Institute of Risk Analysis National Research Center, Chairman of the Department of Pathology, Faculty of Medicine, University of Sao Paulo Canada: Marie-Hélène Bacon, MA, Groupe de recherche interdisciplinaire sur la gouvernance, les risques, l’environnement, les technosciences, la santé et la société (Gretess), Université du Québec à Montréal, Montreal Dr Yv Bonnier Viger, MD, MSc, MM, FRCPC, CMSQ, Médecin spécialiste en santé publique et médecine préventive, Médecin conseil à la Direction de santé publique de Chaudière-Appalaches, Directeur du Département de médecine sociale et préventive de l'Université Laval Dr Dorothy Goldin Rosenberg, MES, PhD, Lecturer, University of Toronto Dr Magda Havas, BSc, PhD, Associate Professor, Trent University Dr Pascale Krzywkowski, PhD Neurosciences, MSc Sciences de l'environnement de l'Université du Québec à Montreal, Montreal Dr Louise Lajoie, MD, MSc, Médecin spécialiste en santé communautaire, professeur de clinique en médecine préventive, Université de Sherbrooke Françoise Maniet, Chargée de cours et agente de recherche, Département des sciences juridiques et GRETESS, Université du Québec à Montréal, Montreal Dr Donna Mergler, PhD, Professor Emerita, Centre de recherches interdisciplinaires en biologie, santé, environnement et société (CINBIOSE), Université du Québec à Montréal Pr Lise Parent, Professeure, Télé-Université, Montreal Pr François Reeves, MD, FRCPc, Cardiologue d'intervention, Professeur agrégé de médecine, Département de santé environnementale et du travail, Université de Montréal, Montreal Kathleen Ruff, Senior Human Rights Adviser, Rideau Institute, Ottawa Rev Dominic J. Sasco, Holy Spirit Parish, Archdiocese of Toronto Donald and Clare Sasco, Sidney Colin L. Soskolne, PhD, Professor, School of Public Health, University of Alberta, Edmonton François Therrien, Collectif Sauvons nos Enfants des Ondes, Terrebonne Pr Fernand Turcotte, MD, MPH, FRCPC, Professeur émérite de santé publique et médecine préventive, Université Laval, Quebec Cathy Vaillancourt, PhD, Professeur agrégé/Associate Professor, INRS-Institut Armand-Frappier, Université du Québec, Laval Pr Louise Vandelac, PhD, Professeure titulaire, Départment de Sociologie, Directrice de l’Institut des Sciences et de l’Environnement, Université du Québec à Montréal Haiti: Joan Lysias Cassotti, MD, MS, Regional Advisor Reproductive Health, United Nations Population Fund (UNFPA), Port-au-Prince Mexico: Fernando Bejarano, Center for Analyses on Toxics and Alternatives (CAATA), Mexico Peru: Dr Ernesto F Ráez-Luna, Director de Ciencia y Desarrollo Centro para la Sostenibilidad Ambiental, Environmental Sustainability Center, Universidad Peruana, Lima USA: Pr Nicholas A. Ashford, Professor of Technology and Policy, Massachusetts Institute of Technology (MIT), Cambridge, MA Pr John Bailar, PhD, Member of the US National Academy of Sciences, Chicago, IL Pr Michael S Bloom, PhD, MS, Assistant Professor, Departments of Environmental Health Sciences and Epidemiology and Biostatistics, University at Albany School of Public Health, State University of New York, NY Dr Barry Castleman, ScD, Environmental Consultant, Washington DC Pr David O Carpenter, MD, Director, Institute for Health and the Environment, University at Albany, NY Pr Richard Clapp, DSc, MPH, Professor Emeritus, Boston University School of Public Health, Boston, MA Pr Arthur L Frank, MD, PhD, Professor of Public health, Drexel University School of Public Health, Philadelphia, PA Pr Antonio Giordano, MD PhD , Director Sbarro Institute for Cancer Research and Molecular Medicine and Center of Biotechnology, College of Science and Technology, Temple University BioLife Science , Philadelphia, PA Nancy Hepp, Research and Communications Specialist, Collaborative on Health and the Environment, Dr James Huff, Phd, Staff scientist, Chemical Carcinogenesis, National Institute of Environmental Health Sciences (NIEHS), Research Triangle Park, NC Pr Patricia Hunt, Meyer Distinguished Professor, School of Molecular Biosciences, Washington State University, WA Pr Joseph LaDou, MD, Division of Occupational and Environmental Medicine University of California, San Francisco, CA Pr Lisa Lavine Nagy, MD President of The Preventive and Environmental Health Alliance Inc. Dr James Melius, MD, DrPH, New York State Laborers' Health and Safety Fund Dr Lloyd Morgan, PhD, Senior Scientist, Environmental Health Trust (EHT), CA Cindy Sage, MA, Sages Associates, Santa Barbara, CA Pr Ana Soto, MD, PhD, Professor, Department of Anatomy and Cell Biology, Tufts University School of Medicine, Boston, MA Pr Leslie Thomas Stayner, PhD, Professor of Epidemiology, Division of Epidemiology and Biostatistics, University of Illinois at Chicago, Chicago, IL, USA Pr Shanna H. Swan, PhD, Professor and Vice-Chair, Department of Preventive Medicine, Mount Sinai School of Medicine, New York, NY Dr Daniel Thau Teitelbaum MD, Colorado School of Public Health, Denver, CO Venezuela: Dr Janice Fernández de D´Pool, MD, MPH, Dr in Medical Sciences, Instituto de Salud, Ocupacional y Ambiental Facultad de Medicina, Universidad del Zulia Asia Cambodia: Dr Pascal Millet, Medical Officer, French Embassy, Advisor for the Rector, Université des Sciences de la Santé, Phnom Penh China: Dr Jung-Der Wang MD, ScD, Chair Professor, Department of Public Health, National Cheng Kung University College of Medicine, Taiwan Indonesia: Dr Sudjoko Kuswadji, MSc(OM), PKK SpOk, Yayasan Sudjoko Kuswadji Bersaudara (YSKB), Banten Dicky Jatnika, Musician, Bandung South Korea: Hae-Kwan Cheong, Department of Social and Preventive Medicine, Sungjyunkwan University School of Medicine, Suwon Oceania Australia: Peter Evans, RN (formerly) Grad Dip Health Counselling Convenor, South Australian Task Force on, Multiple Chemical Sensitivity, Port Adelaide Dr James Leigh MD PhD MSc MA C Eng BLegS FAFOEM FAFPHM, Centre for Occupational and Environmental Health, Sydney School of Public Health, University of Sydney, NSW, Australia Rwth Stuckey, PhD., Department of Epidemiology and Preventive Medicine Monash University, Melbourne New-Ze aland: Mary Redmayne, PhD candidate, School of Geography, Environment and Earth Sciences, Victoria University of Wellington Dr Meriel Watts, Coordinator, Pesticide Action Network, Aotearoa Contact : Dr Annie J. Sasco, MD, DrPH Epidemiology for Cancer Prevention Team of HIV, Cancer and Global health Inserm U 897 Bordeaux Segalen University 146 rue Leo Saignat 33176 Bordeaux cedex - France Cell : ++33 6 74 25 43 93 mail: annie.sasco@inserm.fr ajsasco@gmail.com
29/06/2011	To: Jose Manuel D. Barroso, President of the European Commission, Commissioners and services of the European Commission, Members of the European Parliament, Representatives of Member States Re: Groups call for public research to benefit society, not big business 29 June 2011 Public Research should benefit Society, not Big Business An Open Letter on the Common Strategic Framework for EU Research and Innovation Funding The research that is prioritized and funded today will have a decisive impact on the future of our societies and our planet. It is imperative that the EU research framework is geared towards the needs of society and the environment rather than those of big business. Our societies face immense ecological, social and economic challenges. It is certainly no time for "business as usual", and radical change is needed for society to address these challenges. Research and technology have a crucial role to play, but must - especially when publicly funded - benefit all sections of society. In these rapidly changing times, research and innovation play a double role: they enable the broadening of knowledge and informed decision-making, but they also contribute to the emergence of problems. Research into nuclear energy, pharmaceuticals, agricultural genetic engineering, synthetic biology, nanotechnologies, space and military research – for example – has seen big business secure generous public subsidies despite widespread concern about their environmental and social impacts. This has marginalized and limited the funding available for research in important domains such as environmental protection, preventative health policy, organic and low-input agriculture, energy-saving and renewable energies, toxicology, water supply issues, and environmentally sustainable fisheries as well as for research in social sciences which contributes to social change and problem solving that are not focused on technological fixes. Research agendas that prioritize profit and market share are incapable of meeting the social and environmental challenges Europe is facing precisely because these challenges require alternatives to the high-growth, high-profit models of economic development that have been pursued to such devastating excess. European research should promote and focus on innovation that provides solutions rather than investing in end of pipe technologies, which do not tackle the root causes of the problems that society faces. We are extremely concerned therefore that the Europe 2020 Strategy and the Innovation Union Flagship Initiative address Research and Innovation almost exclusively from the perspective of competitiveness. It envisages a society driven by technological ‘fixes’ instead of social-policy based solutions and threatens to impose an unacceptable corporate bias in the upcoming next EU framework research programme (2014-2020). Many of the undersigned organizations, who work on a broad range of social, environmental and economic justice issues, have expressed their concern about the corporate bias in the EU’s current ‘FP7’ research programme. We have highlighted problems such as industrydomination of European Technology Platforms (ETPs) and ‘informal’ agenda-setting bodies like the European Security Research and Innovation Forum. These channels create a structural conflict of interest by allowing industry lobbying to set the EU research agenda and then secure the public funds on offer. The more systematic use of public-private research partnerships envisaged by the European Commission will exacerbate these problems and undermine socially-driven innovation. While the EU has funded research that seeks to explore and promote alternatives at the margins of its current programme (particularly in its Science and Society programme), we are concerned that these already limited opportunities will be further restricted in the coming programme. Ethical concerns about many of the controversial technologies the EU is already funding have also been sidelined. The EU’s ethical guidance and compliance mechanisms must be urgently overhauled to ensure that much needed debates about the impact of new technologies can be considered and addressed as part of the overall research agenda. The role of social sciences, particularly, should not be narrowed to facilitating the “acceptability” of technologies. Research that will make Europe (and the world) an environmentally sustainable, healthy and peaceful place to live must now be prioritised over and above research that delivers marketable technologies. We, the undersigned civil society and scientific organisations, think that another research and innovation policy is not only possible but urgently necessary in order to respond to the challenges our societies are facing. We call on the EU Institutions to take steps to: Overcome the myth that only highly complex and cost intensive technologies can create sustainability, employment and well-being, and focus on tangible solutions to environmental, economic and societal challenges instead. Ensure that the concept of innovation includes locally adapted and social forms of innovation as well as technological development, and facilitate cooperation and knowledge exchange between civil society organisations and academia in order to realise the innovative potential of the non-profit sector; Establish a democratic, participatory and accountable decisionmaking process for research funding allocation, free from conflicts of interest and industry dominance, and enable civil society to play a full part in both setting the EU research agenda and participating in all EU research programmes; Ensure that all experts advising EU research policy-makers are appointed in a transparent manner to provide impartial and independent expertise, free from conflicts of interests; replace industry-dominated advisory groups and technology platforms with bodies that provide a balanced representation of views and stakeholders; Ensure that publicly funded research benefits wider society by systematically requiring equitable access licensing and encouraging open source access policies in the next Common Strategic Framework. Signatories (in alphabetical order): Action for Solidarity Environment Equality and Diversity (Netherlands) ANEC the European consumer voice in standardisation (Belgium) Arbeitsgemeinschaft Bäuerliche Landwirtschaft / Family Farmer Association (Germany) Arial (Germany) Associação Nacional de Conservação da Natureza (Portugal) Association of Doctors for the Environment (Macedonia) Associazione Culturale Pediatri (Italy) Baby Milk Action (United Kingdom) Belgische Shiatsu Federatie (Belgium) Bioforsk Organic Food and Farming Division (Norway) Biofuelwatch United Kingdom/US (United Kingdom) Bund Ökologische Lebensmittelwirtschaft e.V. (Germany) Bundeskoordination Internationalismus Pharma-Kampagne (Germany) Campagne tegen Wapenhandel / Dutch Campaign Against Arms Trade (Netherlands) Centre de Recherche et d’Informations pour le Développement (France) Chemicals Health and Environment Monitoring Trust (United Kingdom) Consumer Association for the Quality of Life (Greece) Corporate Europe Observatory (Belgium) Ecobaby Foundation (Netherlands) Estonian Organic Farming Foundation (Estonia) Estonian University of Life Sciences (Estonia) European Academy for Environmental Medicine e.V. (Germany) European Association of Consumer Cooperatives (Belgium) European Central Council of Homeopaths (United Kingdom) European Child Safety Alliance (United Kingdom) European Committee for Homeopathy (Belgium) European Environmental Citizens' Organisation for Standardisation (Belgium) European Federation of Homeopathic Patients' Associations (Belgium) European Federation of Patients' Associations for Anthroposophic Medicine (France) European Network of Scientists for Social and Environmental Responsibility European Shiatsu Federation (Belgium) Farmaceuticos Mundi (Spain) Fédération européenne du cheval de trait pour la promotion de son utilisation (Belgium) Fédération Inter-Environnement Wallonie (Belgium) Flanders Physicians for the environment (EPHE affiliate) (Belgium) Fondation Sciences Citoyennes (France) Food and Water Europe (Belgium) Food Ethics Council (United Kingdom) Formindep (France) Foundation on Future Farming (Germany) Friends of The Earth Europe (Belgium) GEKKO Foundation (Germany) Gen-ethisches Netzwerk (Germany) GeneWatch UK (United Kingdom) Gesellschaft für Ökologische Forschung (Germany) Gezinsbond VZW (Belgium) Global 2000/Friends of the Earth Austria (Austria) GMWatch (United Kingdom) Greenpeace Europe Health Action International Europe Health Care Without Harm Europe (Belgium) Health projects for Latvia (Latvia) Hungarian Haemophilia Society (Hungaria) Institute for Independent Impact Assessment in Biotechnology (Germany) Institute for Sustainable Development / Institut za trajnostni razvoj (Slovenia) Insulin Dependent Diabetes Trust (United Kingdom) Interessengemeinschaft für gentechnikfreie Saatgutarbeit (Germany) International Chemical Secretariat (Sweden) International Federation of Anthroposophic Medical Associations (Belgium) International Federation of Organic Agriculture Movements (Belgium) International Network of Engineers and Scientists for Global Responsibility International Society of Doctors for the Environment (Ireland) Italian Association for Organic Agriculture (Italy) Italian Foundation for Research in Organic and Biodynamic Agriculture (Italy) Moscow State University of Medicine and Dentistry, Dept of Internal Medicine n°2 (Russia) Mutual Aid Association (Latvia) My Right to Know Foundation (Bulgaria) National Women's Health Alliance (USA) Naturefriends International (Belgium) Naturschutzbund (Germany) No Patents on Life / Kein Patent auf Leben (Germany) Pesticide Action Network Europe (Belgium) Pestizid Aktions-Netzwerk e.V. (Germany) PharmAware-UK (United Kingdom) Physicians for Social Responsibility Finland (Finland) Quaker Council for European Affairs (Belgium) Redaktion UmweltRundschau (Germany) Réseau Environnement Santé (France) Ritimo (France) Save our seeds (Germany) Scientists for Global Responsibility (United Kingdom) Sociedad Española de Agricultura Ecológica (Spain) Spanish National Shiatsu Association (APSE, Spain) Statewatch (United Kingdom) Testbiotech (Germany) The Berne Declaration (Switzerland) The Corner House (United Kingdom) The European Consumers’ Organisation (Belgium) The Health and Environment Alliance (Belgium) The Independent Salzburg Platform Against Nuclear Dangers (Austria) The Irish Doctors' Environmental Association (Ireland) Transnational Institute (Netherlands) Verein Demokratischer Pharmazeutinnen und Pharmazeuten (Germany) Verein zur Hilfe Umweltbedingt Erkrankter (Germany) War on Want (United Kingdom) Wemos Foundation (Netherlands) Women in Europe for a Common Future (Germany) Women's Environmental Network Scotland (United Kingdom) View related press release here
21/06/2011	To: EU Environment Ministers Re: Input to Environment Council meeting 24 June Brussels, 15 June 2011 To: EU Environment Ministers Concerning: Input to Environment Council meeting 24 June Call for Council conclusions on “A Roadmap for moving to a competitive low carbon economy in 2050” to support a 30% reduction for better health Dear Minister, Europe’s leading environmental health organisations, the Health and Environment Alliance and Health Care Without Harm Europe, welcome the current discussions on a Roadmap for moving to a low carbon economy by 2050. Above all, we see that the move could bring substantial health benefits and healthcare savings, literally saving lives and improving the health of people across all of Europe. As two major European networks representing diverse health groups including patients, doctors, nurses, hospitals and public health institutes, we call on Europe’s environment ministers to support the 30% Greenhouse Gas reduction (GHG) target and to provide a platform for a legislative debate about the urgent need to decarbonise the European economy. Such a move would greatly benefit public health in Europe, e.g. reducing the risks of respiratory diseases such as asthma due to air pollution. This target will also lead to reduced car use and focus on healthier lifestyles such as walking and cycling whichwould reduce cardiovascular disease, diabetes, cancer and depression[i]. Research by both HEAL and HCWH Europe concludes that meeting the 30% GHG target would bring health benefits of up to €30.5bn every year by 2020[ii]. Failure to decarbonise will be much more costly. Reaching the 30% GHG target by 2020 will save up to 140,385 life-years that would otherwise be lost due to premature death each year caused by for example respiratory and cardiovascular disease[iii]. Ensuring a healthy society and reducing risks of unnecessary and serious illness will enable Europe to build a healthier workforce for sustainable economic growth. Action now is imperative. We therefore request that you: support an EU 30% emissions reduction target by 2020 bring forward proposals for the set-aside of allowances in the EU Emissions Trading Scheme provide guidance to the European Commission and the Polish EU Presidency to prepare a decision on a new EU climate target by the end of 2011. We look forward to working with you to ensure that health becomes a cornerstone of EU and international climate change policy. Sincerely, Genon Jensen Executive Director Health and Environment Alliance (HEAL) Anja Leetz Executive Director Health Care Without Harm Europe (HCWH Europe) [i] Health Care Without Harm and Health & Environment Alliance, ‘Acting now for a better health. A 30% reduction target for EU climate policy.’ (2010); page 12 [ii] Health Care Without Harm and Health & Environment Alliance, ‘Acting now for a better health. A 30% reduction target for EU climate policy.’ (2010). [iii] Health Care Without Harm and Health & Environment Alliance, ‘Acting now for a better health. A 30% reduction target for EU climate policy.’ (2010); page 25.
15/06/2011	To: Members of the European Parliament Re: Plenary Vote on the “Analysis of options to move beyond 20% greenhouse gas emission reductions and assessing the risk of carbon leakage” June 15th 2011 To: Members of the European Parliament Concerning: Plenary Vote on the “Analysis of options to move beyond 20% greenhouse gas emission reductions and assessing the risk of carbon leakage” Vote for better health: a 30% greenhouse gas reduction target for the EU Dear Member of the European Parliament, During the forthcoming plenary vote on 23 June you will vote on the report “Analysis of options to move beyond 20% greenhouse gas emission reductions and assessing the risk of carbon leakage.” Health Care Without Harm (HCWH) Europe and Health and Environment Alliance (HEAL) urge you to vote in favour of an overall EU target of 30% emission reductions by 2020, for the benefits of public health in the EU. We very much welcome the recent vote in the European Parliament’s ENVI Committee in favour of a 30% EU emissions reduction target by 2020, which is in line with Europe’s anticipated long term outlook towards a low-carbon economy by 2050. Such a move would bring substantial health benefits and healthcare savings for Europe, as well as other positive impacts related to sustainable development and green jobs creation. We therefore call on you to strengthen and continue your support of the overall 30% target, as has been Parliament’s position in the past. Research by both Health & Environment Alliance (HEAL) and Health Care Without Harm (HCWH) Europe concludes that meeting the 30% GHG target would bring health benefits of up to €30.5 billion every year by 2020 and also save up to 140,385 life-years that would otherwise be lost due to premature death each year . We look forward to working with you to ensure that health becomes a cornerstone of EU and international climate change policy. Sincerely, Genon Jensen _Executive Director _Health and Environment Alliance (HEAL) Anja Leetz _Executive Director _Health Care Without Harm Europe (HCWH Europe)
14/06/2011	To: Ministre de l’Ecologie du Développement durable, du Transport et du Logement Re: Contribution des médecins et ONGs en amont du Conseil européen des Ministres de l’environnement du 21 juin 2011 A l’attention de, Madame Nathalie Kosciusko-Morizet Ministre de l’Ecologie du Développement durable, du Transport et du Logement Copie à, Madame Norra Berra, Secrétaire d’Etat a la Santé Bruxelles et Paris le 14 juin 2011 Objet : Contribution des médecins et ONGs en amont du Conseil européen des Ministres de l’environnement du 21 juin 2011 Santé et climat : vers une réduction des émissions d’au minimum 30% d’ici à 2020 pour améliorer la santé publique Madame la Ministre, Les ONG de santé et d’environnement européennes représentées par la Health and Environment Alliance (HEAL), Health Care Without Harm Europe (HCWH-Europe) soutenues par le Réseau Action Climat – France (RAC-F) et 5 réseaux majeurs de médecins et experts de santé-environnementale, accueillent favorablement les discussions actuelles concernant la “Feuille de route 2050 pour une Europe compétitive et à faibles émissions carbone”. Un mouvement ambitieux de l’Union européenne vers une société décarbonée offrirait ainsi, au delà d’importants co-bénéfices environnementaux et socio-économiques, la possibilité d’améliorer substantiellement la santé des européens. Cela permettrait littéralement de sauver de nombreuses vies et d’améliorer les conditions de vie de nos concitoyens. C’est pourquoi, nous appelons la France à supporter un objectif de réduction des émissions de gaz à effet de serre d’au minimum 30% d’ici à 2020. Le changement climatique est devenu aujourd’hui un enjeu majeur de santé et de dépenses publiques. Ses impacts sur la santé sont multiples, les polluants atmosphériques associés aux émissions de dioxyde de carbone (CO2) tels que les particules fines, le dioxyde de soufre, l’ozone et les oxydes d’azote étant à l’origine d’une part importante des cas de maladies respiratoires, bronchites chroniques, asthme, pneumonies et tuberculose. Pire, nos émissions de gaz à effet de serre et autres gaz toxiques pourraient entrainer chaque année quelques 207 millions de jours d’activité restreinte et la mort prématurée de plus de 230.000 personnes dans les prochaines années en Europe. Question de santé publique chaque jour plus préoccupante, le changement climatique s’avère aussi un défi économique sans précédent pour notre service public de santé. Les dépenses afférentes aux maladies respiratoires coûtent à l’heure actuelle 6% du budget de santé annuel de l’Europe, soit environ 47,3 milliards d’euros selon un récent rapport des associations HEAL et HCWH-E . Cette même étude livre des résultants probants quant aux impacts d’une politique climatique renforcée sur les maladies respiratoires et les dépenses de santé publique. Elle démontre que, pour ces 10% supplémentaires (passage de -20% à -30%), les économies de dépenses de santé publique pourraient atteindre 3,5 milliards d’euros par an uniquement pour la France. Plus de 15% du déficit de la Sécurité Sociale pourraient être ainsi comblés. Ainsi, nous vous demandons, lors du prochain Conseil européen des Ministres de l’environnement de : soutenir un objectif de réduction des émissions de 30% d’ici 2020 (par rapport à 1990) en Europe ; inciter la Commission européenne et la Présidence Polonaise de l’Union européenne à préparer la décision pour l’adoption d’un nouvel objectif européen d’ici la fin de l’année 2011 au plus tard. Nous vous remercions par avance pour la prise en compte de nos demandes et nous restons à votre disposition pour faire de la santé publique l’un des pilier de la lutte contre le changement climatique au niveau européen et international. Veuillez agréer, Madame la Ministre, l’expression de notre plus haute considération. Genon Jensen, Executive Director, Health and Environment Alliance (HEAL) Anja Leetz, Executive Director, Health Care Without Harm Europe (HCWH Europe) Sandrine Mathy, Présidente, Réseau Action Climat – France, (RAC-F) Pr. Dominique Belpomme : Président de l'Association pour la Recherche Thérapeutique Anti-Cancéreuse (ARTAC), Médecin spécialiste en Oncologie médicale, Professeur de Cancérologie à l'Université Paris-Descartes (Paris V) Mr. André Cicolella : Porte-parole du Réseau Environnement Santé (RES) , Conseiller Scientifique auprès de l’Institut National de l’Environnement Industriel et des Risques (INERIS) Dr. Paul Cordonnier: Président de l’Association pour la Promotion de la Recherche en Environnement et Santé publique (APRES). Dr. Dominique Le Houézec: Vice-Président de la Confédération Nationale Médicale Santé-Environnement (CNMSE), Pédiatre, Ancien Chef de Clinique infantile du CHU de Caen Dr. Pierre Souvet : Président de l’Association Santé Environnement de France (ASEF), Cardiologue, élu « médecin de l’année 2008 » pour son combat sur la santé et l’environnement Mr. Olivier Toma : Président fondateur du Comité pour le Développement Durable en Santé (C2DS), Directeur de l'agence Primum Non Nocere.
27/04/2011	To: IMCO Committee Re: NGO vote recommendations in view of the vote in the IMCO-Committee on the amendments to the Commission’s proposal for a biocide regulation (COM 0267) To Members of the EP Committee on Internal Market and Consumer Protection (IMCO) NGO vote recommendations in view of the vote in the IMCO-Committee on the amendments to the Commission’s proposal for a biocide regulation (COM 0267), Brussels 28 April 2010 Brussels, 27 April 2010 Dear members of the EP- Committee for Internal Market and Consumer Protection, On the 28th April 2010 you will vote on the amendments to the Commission’s draft for a regulation concerning the placing on the market and use of biocidal products (COM (2009) 0267). These amendments are suggested by the IMCO rapporteur Amalia Sartori and further members of the Committee.1 PAN Germany and EEB, Federation Inter-Environnement Wallonie, Grüne Liga, Health and Environment Alliance, Levego Munkacsoport, PAN Europe and PAN UK welcome the review of the current biocide legislation (Directive 98/8/EC) as many shortcomings have occurred in the context of the registration, authorisation and marketing of biocidal products. Biocides like insecticides, rodenticides or household disinfectants can be widely sold, although they can contain highly hazardous substances with carcinogenic, immunotoxic or endocrine disruptive effects. Nano-biocides are commonly used in a wide range of consumer products, including textiles, despite scientific evidence of risks for human health2 and the environment3. Nanosilver particles used in anti-odor socks tend to end up in waste water, hampering the growth of bacteria in waste water treatment plants. Biocidal silver may also disrupt the functioning of key soil microbial communities and prevents use of sewage sludge for agricultural fields. In France only, it is estimated that 17 tonnes of nano silver are released every year in water due to the machine washing of anti-odorant socks containing nano silver.4 Currently, we have to face serious intransparencies on the market which hinder product safety and consumer protection. German authorities demonstrated for example infringements against provisions on safety instructions and accurate advertisement in up to 50% of the controls. So long, sufficient standards for the sustainable use of biocides have not been established, although they are necessary in order to ensure an efficient handling of biocides in Europe. As a consequence the authorities already recorded more than 15.000 cases of poisoning whereas the real extent of the impact of biocide use remains unclear due to data gaps in the majority of the member states. Particularly vulnerable groups like small children have been affected in up to 56% of biocides-related incidents which were documented.5 These figures underline that the internal market is not functioning in accordance with EU-standards for health and environmental protection. A consistent and incentive framework for the promotion of sound products and other sustainable alternatives for pest management is still outstanding. Furthermore, we believe that the Commission’s proposal is not balanced enough in order to cope with the identified shortcomings. Several suggested modifications would weaken current standards for the protection of human health and environment from the risks of biocides while the procedure for product authorisation is problematically simplified and accelerated. This approach not only overrides the positive suggestions in the Commission’s draft (e.g. labelling of treated articles and promotion of non-chemical alternatives) but it can also result in serious risks for European consumers as well as for responsible and innovative enterprises which invest in sustainable solutions. The Industry Committee already demonstrated with its vote on the biocide regulation that MEPs are concerned about insufficient standards for transparency (e.g. no labelling of nano biocides). Your decisions can also contribute to set a clear signal for a better system for the handling of biocides. We urge you to support the following amendments: guarantee a high level of protection of human health and the environment and embed the precautionary principle as main purposes of the regulation in order to ensure a consistent cut-off regime and the protection of vulnerable groups like children, pregnant women or elderly people (amendments 5, 16, 108) confirm a regular review of biocides (amendments 114, 121) support coordinated measures for the sustainable use of biocides (amendments 1, 28) encourage transparency and efforts for removing current gaps for decision making (amendments 91, 119, 143-146) promote and strengthen provisions for labelling treated articles (amendment 98) consider a clear framework for product authorisation that guarantees responsibility and healthy products (amendments 6, 113, 123) Furthermore, we believe that it is necessary to confirm those standards of the biocide legislation or suggestions of the Commission’s approach which can contribute to ensure consumer and environmental protection on the common market. For this reason we recommend to reject the following amendments as they will weaken current achievements: introduction and extension of vague exemptions that allow a regular and EU-wide approval of highly hazardous substances which can be applied in drinking water plants and against birds and fishes (amendment 15) weakening of existing criteria for the authorisation of biocidal products (amendments 12, 19-20, 27, 31, 37-38, 45-47, 50, 52, 55, 60, 68-72, 99, 116-117, 132- 134) confirmation of loopholes that prevent a clear and timely substitution regime (amendments 24, 39-44) entire centralisation of the product authorisation system that may result in antimicrobiological resistancies or other serious impacts for health and environment (amendment 124, 125) weakening of provisions for treated articles (amendments 73-75, 110, 136-142) destruction of transparency standards and the permission of harmless advertisement of harmful biocides (amendments 33 79-80, 85-89, 93, 120) exemptions for the authorisation of altered biocidal products without applying clear criteria and standards for the protection of human health and environment (amendments 9, 10, 63, 129) We should be most grateful if you consider our recommendations. Please do not hesitate to contact us for further information. Yours sincerely Pesticide Action Network Germany, Christian Schweer (Biocide Coordinator EU) European Environmental Bureau (EEB), Louise Duprez Health and Environment Alliance (HEAL), Anne Stauffer Pesticide Action Network Europe/ Clean Air Action Group, Gergely Simon (Board member) Pesticide Action Network UK, Nick Mole (Policy Officer) Health Care Without Harm Europe, Anja Leetz (Executive Director) Fédération Inter-Environnement Wallonie, 150 associations au service de l'environnement, Valérie Xhonneux Grüne Liga e.V., Bundeskontaktstelle Wasser, Michael Bender 1 Cf. http://www.europarl.europa.eu/meetd...; http://www.europarl.europa.eu/meetd... 2 There is evidence that nanosilver can be detrimental to human health when ingested or used in medical devices, see for instance: Carlson, C., et al., Unique Cellular Interaction of Silver Nanoparticles: Size- Dependent Generation of Reactive Oxygen Species. The Journal of Physical Chemistry B, 2008. 112(43): p. 13608-13619. 3 See for instance: Luoma, S., Silver nanotechonologies and the Environment: old problems or new challenges? Project on Emerging nanotechnologies, 2008. 4 See recent recommendations from the French « Agence française de sécurité sanitaire de l'environnement et du travail » (Afsset), 24 March 2010, http://www.afsset.fr/index.php?page... 5 Cf. European Commission, Directorate-General Environment (no year): Composite Report in Accordance with Article 24 of Directive 98/8/EC Concerning the Placing of Biocidal Products on the Market. Covering the Period from December 2003 to November 2006. Brussels. PDF-Download: http://ec.europa.eu/environment/bio...
14/03/2011	To: ENVI Committee Re: Exchange of views on the draft report on the “Analysis of options to move beyond 20% greenhouse gas emission reductions and assessing the risk of carbon leakage” 14th March 2011 To: Members of the European Parliament Committee on Environment, Public Health and Food Safety (ENVI Committee) Concerning: Exchange of views on the draft report on the “Analysis of options to move beyond 20% greenhouse gas emission reductions and assessing the risk of carbon leakage (2011/2012(INI))” ENVI Exchange of views on 15 March: Including health economic benefits in the climate change debate and outcomes Dear Member of the European Parliament, During the forthcoming ENVI Committee meeting on 15 March you will discuss the draft report on the “Analysis of options to move beyond 20% greenhouse gas emission reductions and assessing the risk of carbon leakage (2011/2012(INI))”. As the leading representatives of European-wide health and healthcare networks, Health and Environment Alliance and Health Care Without Harm Europe welcome the draft report from the European Parliament and would like to ask you to strengthen it to adequately recognise the health benefits and cost savings arguments it brings to the current climate change debate. We echo calls of both the World Health Organization (WHO) and the Standing Committee of European Doctors who advocate for greater consideration of the health co-benefits in setting climate targets and strong emission reductions in Europe.i We welcome discussions that have been taking place in the ENVI Committee on the possibilities of a European move beyond 20% to 30% domestic emissions reduction target by 2020, in line with Europe’s anticipated long term outlook towards a low-carbon economy by 2050. Such a move would bring substantial health benefits and healthcare savings for Europe, as well as other positive impacts related to sustainable development and green jobs creation. Research by both Health & Environment Alliance (HEAL) and Health Care Without Harm (HCWH) Europe concludes that meeting the 30% GHG target would bring health benefits of up to €30.5 billion every year by 2020ii. The failure to decarbonise is much more costly. Reaching the 30% GHG target by 2020 will also save up to 140,385 life-years that would otherwise be lost due to premature death each yeariii. Respiratory disease alone costs Europe an estimated €102 billion or €118 per person per yeariv. Action now is imperative. We therefore call on you to support the draft report and come forth with a strong position in support of a European domestic move to 30% emissions reduction target by 2020. We look forward to working with you to ensure that health becomes a cornerstone of EU and international climate change policy. Sincerely, Genon Jensen - Executive Director, Health and Environment Alliance (HEAL) Anja Leetz - Executive Director. Health Care Without Harm Europe (HCWH Europe) i World Health Organization, Health in the Green Economy (2010) http://www.who.int/hia/green_economy/en/ ii Health Care Without Harm and Health & Environment Alliance, ‘Acting now for a better health. A 30% reduction target for EU climate policy.’ (2010). iii Health Care Without Harm and Health & Environment Alliance, ‘Acting now for a better health. A 30% reduction target for EU climate policy.’ (2010); page 25. iv European Lung Foundation. Lung diseases: Economic impact. http://www.european-lungfoundation.... (accessed 13.08.2010)
28/02/2011	To: President Barroso Re: The Roadmap for a low carbon economy must include the 30% GHG target and stress health benefits and healthcare savings European Commission Rue de la Loi 200 1049 Brussels Monday 28 February 2011 To: President Barroso and the EU Commissioners The Roadmap for a low carbon economy must include the 30% GHG target and stress health benefits and healthcare savings Dear President Barroso, We welcome discussions on a Roadmap for moving to a low carbon economy by 2050, which could bring substantial health benefits and healthcare savings for Europe. However, we are concerned that the current draft document does not refer explicitly to the 30% greenhouse gas (GHG) target. And more importantly, it does not provide a platform for a legislative debate about the urgent need to decarbonise the European economy nor the very many qualitative benefits that would arise from such a move, such as improved public health. Research by both Health & Environment Alliance (HEAL) and Health Care Without Harm (HCWH) Europe concludes that meeting the 30% GHG target would bring health benefits of up to €30.5bn every year by 2020i. The failure to decarbonise is much more costly. Reaching the 30% GHG target by 2020 will also save up to 140,385 life-years that would otherwise be lost due to premature death each yearii. Respiratory disease alone costs Europe an estimated €102bn or €118 per person per yeariii. Action now is imperative. We therefore request that you bring forward proposals for the set-aside of allowances in the EU Emissions Trading Scheme and measures to implement the upcoming Energy Efficiency Plan to enable an informed and comprehensive debate about the future direction, health and prosperity of European citizens. Yours sincerely, Genon Jensen - Executive Director, Health and Environment Alliance (HEAL) Anja Leetz - Executive Director, Health Care Without Harm Europe (HCWH Europe) List of signatories: Climate and Health Council (CHC) European Federation of Allergy and Airway Diseases Patients Association (EFA) European Public Health Alliance (EPHA) European Respiratory Society (ERS) Health and Environment Alliance (HEAL) Health Care Without Harm Europe (HCWH) International Society of Doctors for the Environment (ISDE) Standing Committee of European Doctors (CPME) In CC: Commissioner Ashton, Commissioner Reding, Commissioner Alumina, Commissioner Kallas, Commissioner Kroesm, Commissioner Tajani, Commissioner Sefcovic, Commissioner Potocnik, Commissioner Rehn, Commissioner Piebalgs, Commissioner Bariner, Commissioner Vassiliou, Commissioner Semeta, Commissioner De Gucht, Commissioner Dali, Commissioner Geoghegan-Quinn, Commissioner Lewandowski, Commissioner Damanaki, Commissioner Georgieva, Commissioner Oettinger, Commissioner Hahn, Commissioner Hedegaard, Commissioner Fule, Commissioner Andor, Commissioner Malmstrom, Commissioner Ciolos i Health Care Without Harm and Health & Environment Alliance, ‘Acting now for a better health. A 30% reduction target for EU climate policy.’ (2010); page 11. ii Health Care Without Harm and Health & Environment Alliance, ‘Acting now for a better health. A 30% reduction target for EU climate policy.’ (2010); page 25. iii European Lung Foundation. Lung diseases: Economic impact. http://www.european-lungfoundation.... (accessed 13.08.2010)
19/01/2011	To: MEPs Re: MEPs called upon to protect EU transparency January 2011 OPEN LETTER: MEPs called upon to protect EU transparency To all Members of the European Parliament In the coming months MEPs will be called upon to vote on amendments in the recast of Regulation (EC) 1049/2001 regarding access to European Parliament, Council and Commission documents. The legislation sets out the conditions under which the public may have access to documents held by EU institutions. Access to information is fundamental to transparency, openness, and the democratic rights of European citizens. According to its founding treaties, the European Union (EU) aspires to create an ever closer union among the peoples of Europe, in which decisions are taken as openly as possible and as closely as possible to the citizen. However, the EU Ombudsman and others have warned that a proposal put forward by the Commission would mean access to fewer, not more, documents. The proposal would restrict access most notably by creating a narrower definition of what constitutes a document for the purpose of the regulation; by adding new exceptions to the right of access to documents, in particular in relation to documents drawn up within dispute settlement proceedings initiated by the Commission against Member States; and by granting more discretion to Member States to refuse access to documents they transmit to the EU institutions. We call on MEPs to amend the Commission fs proposal so as to prevent the access to documents regulation from becoming more restrictive than before and to expand the right of the public to have access to EU institutions, bodies, offices and agencies f documents. To this end we call on the Members of the European Parliament to: Support measures to align the regulation with the Lisbon Treaty to extend the scope of the regulation to all EU bodies, offices and agencies in addition to the institutions. Maintain the current definition of a document to cover all documents and not only ones that have been formally transmitted to some recipients or registered. The definition should also include all information recorded in all formats, including databases. Bring the regulation in line with the relevant pro.transparency decisions of the Court of Justice of the EU which has ruled that legal advice from legal services of EU institutions in legislative proceedings should be publicly accessible and that Member States do not have an unconditional right of veto regarding disclosure of documents they have transmitted to EU institutions. Maintain the deadline of 15 days for EU institutions to reply to confirmatory applications and reject the Commission fs proposal to extend this to 30 days. We call on MEPs to protect the rights of European citizens to access information and ensure transparency of EU institutions. Signed: European Region Abenhedstinget, Denmark . Editor, Nils Mulvad Access Info Europe, Spain . Executive Director, Helen Darbishire Access to Information Programme, Bulgaria . Executive Director, Gergana Jouleva, Ph.D ActiveWatch, Romania . President, Mircea Toma Agentia pentru Informarea si Dezvoltarea Organizatiilor Neguvernamentale, Romania . Mihai Lisetchi Aliancia Fair.play, Slovakia . Zuzana Wienk Amigos de la Tierra, Spain . Environmental Director, Liliane Spendeler Article 19, UK . Senior Legal Officer, Sejal Parmar Associacao para a Cooperacao Entre os Povos, Portugal . Director, Fatima Proenca Asociacion de la Prensa de Madrid, Spain . President, Fernando Gonzalez Urbaneja BilgiEdinmeHakki.Org, Turkey . Director, Yaman Akdeniz Birdlife International, European Division . Director, Angelo Caserta Bureau of Investigative Journalism, UK . Managing Editor, Iain Overton Campaign for Freedom of Information, UK . Director, Maurice Frankel Campaign for Freedom of Information in Scotland, UK . Carole Ewart Centre for Advanced Legal Studies, Serbia . Vladimir Vodineli. PhD Centre for Democracy and Law "Miko Tripalo", Croatia . Professor Josip Kregar Centre for Development and Democratization of Institutions, Albania . Executive Director, Ilir Aliaj Centre for Environmental Information and Education, Bulgaria . Daniel Popov Center for Independent Journalism in Bucharest, Romania . Ioana Avadani Centre for Legal Resources, Romania . Executive Director, Georgiana Iorgulescu Citizen Control . Animal Defence, Bulgaria . Board Chairman, Georgi Serbezov Civil Rights Project Sisak, Croatia . Milana Kreca ClientEarth, UK . CEO, James Thornton Climate Action Network Europe . Director, Matthias Duwe Community Media Forum Europe, Belgium . President, Pieter de Wit Confederacion de Consumidores y Usuarios, Spain . Vice President, Ana Etchenique Corporate Europe Observatory, Belgium . Research and Campaigns Coordinator, Olivier Hoedeman Cyprus EU Association, Cyprus . Dervi. Musann.f Danish Association for Investigative Journalism (FUJ) . Brigitte Alfter, Jacob Mollerup, Denmark Dutch.Flemish Association of Investigative Journalists VVOJ, Belgium/Netherlands . Director, Margo Smit eGovernance Academy, Estonia . Member of the Executive Board, Ivar Tallo Eotvos Karoly Public Policy Institute, Hungary . Laszlo Majtenyi and Mate Daniel Szabo Estonian Newspaper Association, Estonia . Managing Director, Mart Raudsaar European Environmental Bureau . Secretary General, John Hontelez European Federation of Journalists (EFJ/IFJ), Belgium . Co.Director, Renate Schroeder European Public Health Alliance, Belgium . Director of Policy and Strategy, Luiza Bara EU Transparency . Executive Director, Jack Thurston Farmsubsidy.org and Fishsubsidy.org . Co.founder, Jack Thurston Fonds Pascal Decroos voor Bijzondere Journalistiek, Belgium . Director, Ides Debruyne Forest Peoples Programme, UK . Responsible Finance Programme Coordinator Tom Griffiths Foundation Open Society Institute, Macedonia . Dance Danilovska . Bajdevska Friends of the Earth Europe . Director, Magda Stoczkiewicz Fund for an Open Society, Serbia . Transparency, Accountability and Public Integrity Program Coordinator, Miodrag Milosavljevic Fundacja Reporterow . Centrum Wspierania Dziennikarstwa w Europie Wschodniej, Poland . Director, Wojciech Ciesla German Civil Liberties Union (Humanistische Union e.V.), Germany . Sven Lueders Global Witness, UK . Co.Founder and Co.Director, Charmian Gooch GONG, Croatia . Executive Director, Sandra Pernar Greenpeace European Unit, Belgium . Deputy Director, Mahi Sideridou Greenpeace International, Netherlands . General Counsel, Jasper Teulings Health & Environment Alliance, Belgium . Director, Genon K. Jensen Hungarian Civil Liberties Union, Hungary . Tivadar Huttl IKME: Sociopolitical Studies Institute, Cyprus . Director, Alecos Tringides Iuridicum Remedium, o.s., Czech Republic . Helena Svato.ova K.Monitor Association, Hungary . Julia Keser. MANS: Mreza za afirmaciju NVO Sektora, Montenegro . Director for Citizens Initiatives, Zorica .erani. Naturefriends International, Brussels Office . EU Policy Officer, Sandra Roling Netzwerk Recherche, Germany . Dr. Manfred Redelfs N.ost: Network for Reporting on Eastern Europe, Germany . Christian Mihr Observatorio de Responsabilidad Social Corporativa, Spain . Lea Brumter Open Data Espana, Spain . Jacobo Elosua Open Data Network, Germany . Daniel Dietrich Open Society Archives at Central European University, Hungary . Counsellor, Ivan Szekely Partnership for Social Development, Croatia . President, Munir Podumljak Peace Institute in Ljubljana, Slovenia . Brankica Petkovic PRO MEDIA, Macedonia . Klime Babunski Providus, Latvia . Linda Austere PublicMedia Association, Romania . Cosmin Pacuraru Publish What You Fund, UK . Director, Karin Christiansen Rainbow Warriors Core Foundation, Aruba, Kingdom of the Netherlands . President, Milton Ponson Romanian Center for Investigative Journalism, Romania . Co.Founder, Stefan Candea SOMA Foundation for Investigative Journalism, Hungary . Chairma, Andras L.ke Statewatch, UK . Tony Bunyon Sustentia, Spain . Carlos Cordero Svenska Journalistforbundet, Sweden . Senior Adviser, Anita Vahlberg Tax Justice Network, UK . John Christensen The Access Initiative European Partner Organizations . Dr. Csaba Kiss Transparency International, Hungary . Executive Director, Adam Foldes Transparency International, Latvia (Delna) . Inese Voika Transparency International Liaison Office to the EU, Belgium . Ronny Patz Transparency International Secretariat, Germany . Andrea Figari Transparency International, Spain . President, Jesus Lizcano Transparency Zero Corruption, Macedonia . President, Slagjana Taseva Ph.D Transport & Environment, Belgium . Director, Jos Dings Tutkiva, Association for Investigative Journalism, Finland . Chairperson, Minna Knus.Galan WhatDoTheyKnow.com . Alex Skene Wobbing.eu . Editor, Brigitte Alfter World Press Freedom Committee . European Representative, Ronald Koven WWF European Policy Office . Advisor, Sandra Jen Global 5th Pillar, India . President, Vijay Anand Africa Freedom of Information Centre, Uganda . Gilbert Sendugwa African Network of Constitutional Lawyers . Access to Information Working Group, Fatima Diallo Alianza Regional por la Libertad de Expresion e Informacion, Latin America . Executive Secretariat, Karina Banfi Arab Freedom of Information Network . President, Said Essoulami Association Green Alternative, Georgia . Executive Director, Nino Gujaraidze Asociacion por los Derechos Civiles, Argentina . Executive Director, Alvaro Herrero Bahrain Transparency, Bahrain . President, Abdulnabi Alekry Bank Information Center, USA . Middle East and North Africa Program Manager, Amy Ekdawi Canadian Association of Professional Access and Privacy Administrators, Canada . National Chair, Sharon Polsky Centro de Archivos y Acceso a la Informacion, Uruguay . Edison Lanza Centre for Independent Journalism, Malaysia . Masjaliza Hamzah Centre for Law and Democracy, Canada . President, Toby Mendel Center for Promotion of Freedom of Expression and Access to Information, Moldova . President, Vasile Spinei Citizens' Campaign for Right to Information, Nepal . General Secretary, Tanka Aryal Commonwealth Human Rights Initiative, India . Maja Daruwala's Egyptians Against Corruption, Egypt . Engi M. El Haddad Electronic Privacy Information Center, USA . Marc Rotenberg Freedom Forum, Nepal . Chairperson, Taranath Dahal Freedom of Information Center, Armenia . Shushan Doydoyan Freedom of Information Programme at the South African History Archive, South Africa . Support Officer, Gabriella Razzano Freshwater Action Network, Mexico . M.Sc. Nathalie Seguin Fundacion Directorio Legislativo, Argentina . Executive Director, Maria Baron Fundacion Pro Acceso, Chile . Presidente, Federico Allendes S. Fundar, Centro de Analisis e Investigacion, Mexico . Miguel Pulido Georgian Young Lawyers f Association, Georgia . Tamar Kordzaia Institute for the Development of Freedom of Information, Georgia . Director, Giorgi Kldiashvili Institute for Information Freedom Development, Russia . Board Chair, Ivan Pavlov Instituto de Derecho y Economia Ambiental: IDEA, Paraguay . Executive Director, Ezequiel Santagada Jamaicans For Justice, Jamaica . Executive Director, Carolyn Gomes National Security Archive, George Washington University, USA . Director, Tom Blanton Open Society Georgia Foundation, Georgia . Deputy Executive Director, Tamuna Kaldani Open Society Institute . Assistance Foundation, Azerbaijan . Fidan Bagirova Poder Ciudadano (TI.Argentina), Argentina . Hernan Charosky Right to Know Coalition of Nova Scotia, Canada . President, Darce Fardy Socio.Economic Rights & Accountability Project, Nigeria . Executive Director, Adetokunbo Mumuni Suma Ciudadana, Peru . Coordinator, Javier Casas Transparency International, Israel . CEO, Galia Sagi Transparency Maroc, Morocco . Access to Information Project Coordinator, Saad Filali Meknassi Transparency International, Russia . Marina Savintseva Water Governance Institute (WGI), Uganda . Executive Director, Henry Bazira Zero Corruption Coalition, Nigeria . National Secretary, Babatunde Oluajo 89 European Organisations, 42 Global Organisations Total : 131 À titre personnel: Alexander Kashumov, Attorney at law, Bulgaria Andres Mejia, Colombia/USA Andrew Ecclestone, Honorary Senior Research Fellow, Constitution Unit, University College London, UK Angie Zelter, Wales, UK Annette Schiøler, Journalist, Denmark Anni Løndal de Lichtenberg, Denmark Bent Øberg, Denmark Blanka Hancilova, Austria Bryan Charles, Belgium Christian Bartels, Journalism Student, Denmark Ciarán Toland, Barrister–at–Law, The Law Library, Republic of Ireland Codru Vrabie, Civil society representative on the National Integrity Council, Romania David Goldberg, Law lecturer/FOI expert, Scotland, UK Ermal Nazifi, Lawyer, Albania E. Plebani, Reporter, Italy Eduardo Bertoni, Director, Center for Studies on Freedom of Expression and Access to Information, Palermo University School of Law, Argentina Eduardo Esclapés, Spain Felipe Vicente, Spain Francesca Fanucci, Lawyer and Freelance consultant on freedom of expression, transparency and freedom of information, UK Giner Rico, Spain Greg Michener, Brazil Heather Brooke, writer, journalist and activist, UK Heidi Birgitte Nielsen, Journalist, Denmark Heike Mayer, Germany Ian Davis (Dr.), Human Security and Arms Control Consultant, Scotland, UK Jaume Cot del Valle, Spain Jesus Cabrera, Photographer, Spain John McCarthy, USA José Cavani Ríos, Journalist, Peru Katrine Birkedal Christensen, Journalist, Denmark Kenneth Konrad Knudsen, Journalist, Denmark Laura Robinson, Journalist, Canada Leo Sisti, investigative reporter, contributing reporter for "L'Espresso" and "Il Fatto Quotidiano", Italy Manuel Sánchez de Diego Frdez. de la Riva, Law Professor, Spain Mariana Berbec Rostas, LL.M., human rights lawyer, Romania/Hungary Mario Gutiérrez Sanchez, Student, Spain Marion Brians, France Marjan Kroflič, Slovenia Markus Knigge, Belgium Michael Ewing, Coordinator of the Environmental Pillar of Social Partnership, Republic of Ireland Mónica Caballo, Librarian, Spain Nadejda Hriptievschi, Legal Consultant, Public Defender Office, Republic of Moldova Päivi Leino–Sandberg (Dr.), Finland Patrice McDermott, Director, OpenTheGovernment.org, USA Prashant Sharma, Doctoral Researcher, India Raül Romeva i Rueda, Member of the European Parliament, Greens/EFA, Spain Sarah Elizabeth Holsen, Research Assistant, Institut de hautes études en administration publique, Switzerland Silvana Fumega, Access to Information Independent Consultant, Argentina Sorin Schiopu, editor, Radio Targu Mures, Romania Stephen J Avalyan Newton (Prof.), International Governance and Change Management Specialist, Armenia Tarmo Vahter, member of the advisory board of Journalismfund.eu, Estonia Thorkild Knudsen (DJ), Journalist, Denmark Tom Devine, USA Ulf Öberg, Lawyer, Advokatfirman Öberg & Associés AB, Sweden W Mecklenburg (Dr.), Lawyer and Physicist, Germany Walter Keim, Norway 56 individuals + 131 organisations: Total: 187 signatures
12/01/2011	To: President Barroso and the EU Commissioners Re: Your upcoming College discussion on further measures to reduce air pollution in the EU European Commission Rue de la Loi 200 1049 Brussels Brussels, 12 January 2011 To: President Barroso and the EU Commissioners Re: Your upcoming College discussion on further measures to reduce air pollution in the EU Dear President Barroso, Dear Commissioner, In view of the upcoming meeting of the College of Commissioners later this month we would like to call on you to support the immediate revision of the National Emission Ceilings (NEC) Directive. An immediate revision should not be seen as a burden on Europe’s economy – it is an opportunity to put the EU’s economy on a recovery path that will improve the health of its citizens and their environment as quickly and as cheaply as possible. 1. The effects of air pollution on health and environment Air pollution creates serious health problems for European citizens and exacts an enormous human and financial toll. Every year, air pollution by fine particles is estimated to cause 455,000 premature deaths in the 27 EU member states, corresponding to almost 4.5 million years of life lost. Ground-level ozone is responsible for some 20,000 premature deaths each year. Europe’s ecosystems are heavily impacted by air pollution through acidification and eutrophication. Overload of nutrients is still a major factor pushing ecosystems towards tipping points and a major obstacle to achieving the newly adopted EU biodiversity targets for 2020. 2. Huge economic losses for society The cost-benefit analyses prepared by the Directorate General for Environment show that strict air policies also make very good economic sense. They value the benefits for the economy of a revised NEC Directive at between €22 and €70 billion per year, which means that the benefits of action exceed the costs by up to 50 times1, as the costs for achieving the environmental objectives of the Thematic Strategy on Air Pollution are estimated at €1.4-1.5 billion in 2020. Additionally we would like to stress that short term concerns of specific sectors of the economy that are expected to bear a large share of the costs can not be a reason not to set new and stricter targets for 2020. The European economy can be expected to pick up well before 2020 and industry will need to take decisions on where and how they invest. By setting stricter ceilings for 2020 the Commission will give a crystal clear signal where these investments should be made and set the EU economy on a green recovery path, and contribute to the EU 2020 objectives of sustainable growth and creating over 1 million green jobs. 3. The achievability of new ceilings for 2020 The current ceilings for 2010 have proven to be an effective tool, and their overall implementation at national level can be seen as relatively encouraging. Indeed, according to the EEA’s latest findings and recent declarations by national governments, 91 out of the 108 ceilings were expected to be met in 20102. What’s more, this reduction in emissions occurred in a period of sustained economic growth. Several of the 17 expected breaches are minor (few percentage points). With the majority of current ceilings being achieved, there is no excuse to wait any longer before revising the Directive and postpone action against the unacceptable human suffering due to remaining air pollution. 4. Provide ceilings for finest particles without further delay Fine particles (PM2,5) have the highest estimated impact on human health yet no ceilings for these pollutants exist. Revising the NEC Directive now would ensure that overall emissions of finest particles are addressed without further delay. 5. Help member states comply with ambient air quality limit values Most member states are struggling to meet binding limit values for PM10 and NO2 provided in EU ambient air quality legislation, and the Commission is currently launching infringement actions against 20 of them. Reducing overall emissions of air pollution will help address the effects of transboundary air pollution and therefore help competent authorities to comply with the requirements of the Air Quality Directive. It would also strengthen the European Commission’s position when reviewing the Air Quality Directive, in particular when looking into stricter standards for PM2.5, in accordance with the WHO recommendations. 6. Help mitigate climate change Revised ceilings should also be seen as a way to mitigate climate change more efficiently and cheaply since climate change and air pollution share the same sources. Reductions in emissions of non-CO2 greenhouse gases can contribute to the achievement of climate objectives. This is the case for pollutants such as methane, nitrogen oxides and VOCs that are responsible for ground-level ozone and also black carbon, a constituent of PM10 which has significant warming impacts, particularly in the Arctic region. Reducing levels of these pollutants would benefit climate and air quality targets simultaneously with significant health and environment benefits. 7. Aim higher for 2013 We fully support Commissioner Potoènik’s initiative to create a “year of air” and raise the political profile of air related policy measures in 2013. However, we do not accept this as an argument to yet again postpone urgent action which was been on hold since 2007. We believe the EU should raise its level of ambition in 2013, as compared to the commitments made in the now five year old Thematic Strategy on Air Pollution. Civil society from across Europe has called on the Commission repeatedly to cut air pollution as quickly as possible through an immediate revision of the NEC Directive. It is clear action must be taken sooner rather than later. Any further delay would be unacceptable given the costs to human health and the environment. Yours sincerely, John Hontelez - Secretary General EEB - European Environmental Bureau Jos Dings - Director T&E - Transport and Environment Genon Jensen - Executive Director HEAL - Health and Environment Alliance 1 See DG Environment’s website, e.g. 2008 AEA "NEC CBA report #3" available at http://ec.europa.eu/environment/air... 2 See latest EEA report of 24 September 2010 on the implementation of the NEC Directive : http://www.eea.europa.eu/highlights... exceed&utm_medium=email&utm_source=EEASubscriptions
29/12/2010	To: UNFCCC National focal points Re: Input to international climate talks in Cancun To: UNFCCC National focal points Concerning: Input to international climate talks in Cancun, 29 November - 10 December 2010 Dear Sir/Madam, What's good for climate change is good for health and the economy Strengthen the health dimension in current UNFCCC negotiating text A side event organised by the WHO and the Mexican government (Wednesday) stressed the devastating impacts which climate change will bring to human health and wellbeing. It also emphasised the massive benefits to health (and healthcare costs) which mitigating measures bring. This was reiterated yesterday at Recent evidence backs-up these views (e.g. IPPC, The Lancet report, HCWH/HEAL Report, WHO). Leading health organizations Health Care Without Harm (HCWH), Health and Environment Alliance (HEAL) and Climate and Health Council (CHC), together with some of the world’s largest medical, nursing and health organizations are calling on world leaders to take bold action to address climate change. They stress that failure to do so will result in widespread suffering and death. However, leaders should be encouraged. Bold action to reduce GHG emissions saves lives, and also money as healthcare costs plummet. The Lancet reports demonstrated that such benefits applied worldwide- to India, China and the UK for example. Meanwhile, HEAL/ HCWH demonstrate the benefits of moving the EU greenhouse gas emissions reduction target from 20% to 30% domestically by 2020 (compared to 1990 levels). This would cost €46 billion per year in 2020 (1, 2) but save We therefore call on negotiators to: - Ensure that health is in the Shared Vision paper Justification: Article 1, paragraph 1 of the UNFCCC Convention (1992), says that health should be alongside environment and socioeconomic development - Health has effective interventions for adaptation, so it should be mentioned in the Adaptation section of the official text The positive and negative impacts of mitigation actions should be recalled as criteria for mitigation measures Justification: Article 4.1 (8) of the UNFCCC Convection (1992) says that mitigation measures should assess health implications. We look forward to working with you to ensure that health becomes a cornerstone of international and EU climate change policy. Sincerely, Genon Jensen - Executive Director, Health and Environment Alliance (HEAL) Anja Leetz - Executive Director, Health Care Without Harm Europe (HCWHE) Mike Gill - Co-chair, Climate and Health Council (CHC)
14/12/2010	To: Commissioner Dalli. Re: EU Commission priority for pesticide reduction and better guidance for EU Member States implementation of National Action Plans 14th December 2010 Commissioner John Dalli European Commission DG Health and Consumers B-1049 Brussels Re: EU Commission priority for pesticide reduction and better guidance for EU Member States implementation of National Action Plans Dear Commissioner Dalli, Today, 14th December, marks the date for crucial deadlines in the implementation of the Directive 2009/128/EC establishing a framework for Community action to achieve the sustainable use of pesticides. By one year from now, on 14 December 2011, Member States have to bring the directive into accordance with their national law (article 23), and by 14 December 2012 have to communicate their National Action Plan to the Commission and to other EU Member States (article 4.2). With the new Barroso Commission, the responsibility for the Directive on the sustainable use now lies with yourself and your services. The Directive represents a major opportunity to achieve significant public health gains by encouraging pesticide dependency reduction in agriculture as well as urban spaces. Health and Environment Alliance HEAL and Pesticides Action Network PAN Europe would like to encourage you to make pesticides dependency reductions one of your priorities in 2011. Minimising our dependency on pesticides and working with non-chemical alternatives are major public health issues. There is a growing body of science which shows the link between pesticides exposure and ill-health, particularly for pregnant women and farmers. Health care costs continue to be dominated by chronic disease, which are at least partly linked to pesticides and chemicals exposure. Therefore, an effective implementation of the new pesticides law will bring major public health benefits. A discussion on health gains due to pesticide dependency reduction is not yet taking place in the public realm, and greater awareness could also be helpful in EU member states administrations. Yet, the issue of potential health impacts of pesticides is of continuous concern to European citizens. As a recent Eurobarometer showed, pesticide residues in food are the top concern of all food scares, and this has held true in both the 2006 and the 2010 surveys (72% of respondents are concerned). Europeans are also concerned about hazards from pesticide use in their home. A 2009 Eurobarometer on chemicals in consumer products revealed that pesticides and herbicides for home use (in gardens and greenhouses) are the top concern for Europeans (70% of respondents are concerned). Europe’s citizens expect their political leaders to act on these health threats, and they support ambitious measures. As we continue to consistently monitor EU Member States activities on the National Action Plans, we have become increasingly concerned with the slow and uneven implementation of the Directive in the EU, and the inadequate lack of any EU initiative which would facilitate and stimulate member states and regions to take action. Our feedback from many member states includes suggestions to receive guidance or even more important inspiration on “how” to go about reducing pesticides, and to develop national action plans with civil society, particularly with an increased participation of health and medical groups in this process. This involvement of all stakeholders can greatly enrich the public health debate (See for example the recent testimonies from cancer patients about their concerns of environmental causes of cancer: http://www.env-health.org/IMG/pdf/L...) PAN Europe recently developed a best practice NAP with examples of what is already being done in many member states (http://www.pan-europe.info/Resource...) and we follow this up regularly with adding more details. We also arrange meetings allowing stakeholders to exchange experience at practical level, identify problems and solutions, and together discuss ways forward. As part of its Sick of Pesticides campaign in 5 countries, HEAL is currently collecting examples of which cities and regions in Europe have already gone pesticide-free (www.pesticidescancer.eu) and working to raise public awareness about countries implementation commitments in this directive and their link to health. Given the public concern about health impacts of pesticides and your mandate in this area, we would like to encourage you to show leadership and prioritise this dossier in 2011. As a first step, DG SANCO could increase public awareness through a specific section on its Health Portal dedicated to Pesticides, Health and NAPs. As the EU Commissioner for both public health and consumers, your role could be visionary in showing how a NAP targeted both at the environment and human health protection is an opportunity to showcase “health in all policies”, as highlighted in the DGSANCO video launched earlier this year during the EU Health Forum. A serious NAP, with quantitative targets and timetables, is essential for swift and effective implementation of the directive. Ambitious NAPs are needed in order to guarantee for all Europeans the same level of health protection, especially for vulnerable groups. Underscoring the importance of pesticide reduction for public health can also increase awareness for public health issues in other EU policy fields, for example with the discussion on the 2020 Strategy and resource efficiency, as well as the Common Agricultural Policy reform and putting public health at the centre of sustainable food production. We would appreciate the opportunity to have a meeting with you and your cabinet and services to discuss further how our organisations and European citizens concerns for better public information, and greater EU guidance could be translated to stimulate and encourage front running member states and regions with the sustainable use of pesticides in order to achieve better health protection for all. Best regards, Genon K. Jensen - Health and Environment Alliance Henriette Christensen - Pesticide Action Network Europe
12/10/2010	To: Members of the Council Working Group for Environment. Re. Joint NGO recommendations for the forthcoming considerations of Council Working Group for Environment concerning the biocide regulation (COM (2009) 267) Joint NGO recommendations for the forthcoming considerations of Council Working Group for Environment concerning the biocide regulation (COM (2009) 267) Brussels, 12 October 2010 Dear Members of the Council Working Group for Environment, You are currently discussing the Commission's proposal for a biocide regulation (COM (2009) 0267), which was recently voted on by the European Parliament in first reading. This act proposal will revise the current Biocidal Products Directive 98/8/EC and establish new provisions for the authorisation and use of, for example, disinfectants, preservatives, products for pest control and other biocidal products. Pesticide Action Network (PAN) Germany, BUND/ Friends of the Earth Germany, Fédération Inter- Environnement Wallonie, Health and Environment Alliance (HEAL), Health Care Without Harm Europe (HCWH), National Movement Friends of the Earth Bulgaria, PAN Europe, PAN UK and Women in Europe for a Common Future (WECF) welcome the revision of the biocides legislation, but see an urgent need to improve the current European Commission draft, the European Parliament resolution as well as the relevant suggestions of the former Council Presidency in order to ensure the protection of the environment and human health against hazards and risks stemming from the use of biocidal products. While taking into account our key NGO demands and recommendations on the biocide regulation, we suggest highlighting the following issues in view of the coming Council Environment Working Group considerations on this dossier: Ensure a consistent and enforceable cut-off regime without unnecessary loopholes on EU and on national level. Guarantee a sufficient substitution regime and consider non-chemical measures and preventive measures within the comparative assessment. Ensure the protection of vulnerable groups from hazardous biocides and the substitution of developmental neurotoxic and immunotoxic biocides. Confirm appropriate labelling provisions for all treated articles. Support consistent measures for the sustainable use of biocides. Demand for consistent data requirements for evaluation and authorization. Confirm a sufficient low-risk approach to promote less hazardous alternatives. Facilitate consistent measures concerning nano-biocides. We provide more details in our comments and recommendations attached. Please do not hesitate to contact us in case of any question. We should be most grateful if you consider our recommendations. Kind regards Pesticide Action Network Germany Christian Schweer (Biocide Coordinator EU) Health and Environment Alliance Anne Stauffer Health Care Without Harm Europe Anja Leetz Fédération Inter-Environnement Wallonie Valérie Xhonneux Women in Europe for a Common Future Elisabeth Ruffinengo (Advocacy Officer) Bund für Umwelt und Naturschutz Deutschland e.V. (BUND) Friends of the Earth Germany National Movement Friends of the Earth Bulgaria Valentina Lukova Pesticide Action Network UK Nick Mole (Policy Officer) Tony Tweedale, M.S. Uppsala University hospital Clinical Microbiology, Eva Haxton PAN Europe Gergely Simon (board member)
12/10/2010	To: Commissioner Potocnik Re: Upcoming Commission decision on the revision of the National Emissions Ceilings Directive (NEC) Commissioner Janez Poto.nik DG Environment European Commission, 1049 Brussels 12 October 2010 Re: Upcoming Commission decision on the revision of the National Emissions Ceilings Directive (NEC) Dear Commissioner Potocnik, We understand that the College of European Commissioners will meet in the coming weeks to decide upon the timing for a revision of the National Emissions Ceilings (NEC) Directive and that the long awaited proposition might be postponed until 2013. With this letter, the Health and Environment Allliance HEAL, the European Federation of Allergy and Airways Diseases Patients Associations EFA and the European Respiratory Society ERS would like to highlight our great concerns about such a delay and call upon you to ensure that the NEC Directive will be immediately revised, as provided for by the Thematic Strategy on Air Pollution and in order to ensure a high level of health protection and wellbeing of Europeans citizens. With Thematic Strategy on Air Pollution (2005), the European Union has set ambitious goals for reducing air pollution by 2020. The revision of the NEC Directive was set to be the key instrument to achieve these objectives. However, adoption and publication by the EU Commission of the revision proposal have repeatedly been postponed since 2007. As late as June 2008 the Commission had a draft proposal ready, but decided again to postpone. Every year, millions of European citizens fall ill because of bad air quality. There is also ample evidence that air pollution aggravates the symptoms and suffering of whose health is already affected . the asthma and allergy patients and people with chronic obstructive pulmonary disease (COPD). Recent scientific evidence has also demonstrated the links between air quality and other diseases such as breast cancer and diabetes. Air pollution is estimated to cause half a million premature deaths in Europe per year. Air Pollution therefore plays a major role in the environmental burden of disease and the rise in chronic diseases in Europe. This has significant implications for public health, and puts yet another strain on EU Member States budgets, which are already under pressure because of the economic crisis. Respiratory diseases are estimated to cause a yearly financial burden of 102 billion EUR in Europe due to healthcare costs and lost working days. An immediate revision of the NEC directive is therefore a crucial contribution to preventing further rises in diseases and deaths. In order to better protect European citizens health and Europe's biodiversity, current ceilings need to be revised with increased ambition as soon as possible. The current ceilings are far from sufficient to meet the 2010 interim health and environmental targets laid down in article 5 of the NEC Directive. Also, a revised NEC will finally introduce ceilings for fine particles (PM2.5) the air pollutant estimated to cause the most harm to human health. We see no excuse for further delays, as these ceilings should have already been proposed in 2007. We would like to highlight that further delays imply huge economic losses for society. The cost benefit analyses available on the European Commission's website show that the monetised benefits of a revised NEC Directive will outweigh the costs involved by up to 47 times1. A revised NEC directive with ambitious targets can also help to reach the EU climate change policy goals. The NEC Directive is the key instrument which will allow Europe to reduce the effects of air pollution in Europe. We therefore call upon you to ensure the EU Commission will publish its proposal without any further delay, making clear, positive changes which would benefit every citizen of Europe for the years to come. In a recent Eurobarometer, EU citizens expressed great concern about the impacts of bad air on their health and expect the EU decisionmakers to act. We hope that you will listen to the voice of EU citizens and the ample public health evidence and tackle a NEC revision as soon as possible. Yours sincerely, Genon Jensen - Executive Director Health and Environment Alliance Susanna Palkonen - Executive Officer European Federation of Allergy and Airways Diseases Patients' Associations Jon Ayres - Chairman European Respiratory Society Environment and Health Committee 1 See cost-benefit analyses published on DG Environment's website such as the 2008 AEA "NEC CBA report #3"
21/09/2010	To: MEPs Re: NGO recommendations for the EP vote on ENVI report (Biocide Regulation) To Members of the European Parliament NGO recommendations for the EP vote on ENVI report (Biocide Regulation (COM (2009) 0267)), Strasbourg 22 September 2010 Brussels, 21 September 2010 Dear Member of the European Parliament, On 22 September 2010 you will decide in the first reading about the position of the European Parliament concerning the Commission's proposal of a biocide regulation which shall replace the current Biocidal Products Directive (Directive 1998/8/EC). The regulation will fundamen-tally change the authorisation system of biocidal products. Among other things biocides, also in nano-form, are used in the area of hygiene, pest control and material protection, in order to control unwanted organisms. Although products like insecticides, disinfectants or textile pre-servatives can be linked to significant risks for humans and the environment they are often applied. Despite the fact that many biocides belong to the group of hazardous chemicals, the current drafts focuses on allowing easy approval of them all over the EU. The signed envi-ronmental and health NGOs believe that the report of the leading Environment Committee does not ensure the protection of consumers and the environment from biocide risks even though it includes some improvements. For this reason and in support of the recommenda-tions of the international scientific network Collegium Ramazzini1 and of the joint position of 20 European NGOs2 we urge you to consider the following amendments: Clarify the purpose of the regulation: Protect human and the environment from biocide risks. Article 1 shall be in line with the precautionary principle of the current EU chemical laws (like REACH, Regulation (EC) 1107/2009) and with the general aim of the EU to ensure a high level of protection of human health. Please support amendment 341. Encourage comparative assessment and substitution for the development of safer products for children: Problematic products such as developmental neurotoxic and immunotoxic biocides can severely harm the nervous system and brain development of children and cause irreversible, long term damages. Please support the substitution of these products where safer alternatives are available. Consider also non-chemical options and reject attempts to weaken the comparative assessment. Please support amendments 61, 62, 94, 106, 127, 353 and reject amendments 68, 122, 123, 126, 336, 337 D, 339, 340. Strengthen the cut-off regime and Member States flexibility: All efforts should be consistent enough in order to phase out highly hazardous biocides in the EU. It is necessary to restrict active substances like with PBT, endocrine disruptive or carcinogenic properties to real cases of emergency and to ensure their proper use. Member States should also have the flexibility to adjust authorizations to their national circumstances. Please support amendments 146, 342, 343, 351, 352 Establish sufficient data requirements and evaluation criteria for the authorisation scheme in order to ensure that potential hazards and risks of biocides and nano-biocides can be identified as well as combination effects of biocide mixtures. For instance, establish requirement of specific methods to assess the safety of nanomaterials. Please support amendments 88, 89, 97, 200, 203, 204, 272, 323, 324, 329, 346, 347, 348, 354 and reject amendments 245, 251, 260-265, 268, 270-271, 273, 275, 277, 289, 294, 301, 307, 313-315, 356 . Guarantee transparency for consumers: All biocidal products and biocide-treated articles should have a sufficient labeling which shall inform about all active ingredients and risks. This is particularly needed for parents to make informed choices about protecting their children. It is all the more necessary since biocide-treated products are numerous and consumers often use them on an everyday basis. We fear that some of the amendments tabled create unnecessary administrative burden and do not lead to clear and transparent labeling rules. Please support amendment 344 and reject amendments 183, 184, 185, 186. Initiate EU-provisions and strategies for the sustainable use of biocides: A Community framework for measures and objectives could contribute to minimise risks like of antimicrobial resistances due to overuse, improper use, environmental impacts or accidents. Please support amendments 84 and 221. Please do not hesitate to contact us in case of any questions. We should be most grateful if you consider our recommendations. Kind regards, Pesticide Action Network Germany, Christian Schweer (Biocide Coordinator EU) BBU - Federal Association of Environmental Ac-tion Groups, Harald Gülzow Det Økologiske Råd, Christian Ege BirdLife International, Tatiana Nemcova, Boris Barov Health and Environment Alliance, Anne Stauffer Health Care Without Harm Europe, Anja Leetz Fédération Inter-Environnement Wallonie, Valérie Xhonneux Women in Europe for a Common Future, Elisabeth Ruffinengo (Advocacy Officer) Bund für Umwelt und Naturschutz Deutschland e.V. (BUND), Jurek Vengels National Movement Friends of the Earth Bulgaria, Valentina Lukova Pesticide Action Network UK, Nick Mole (Policy Officer) PAN Europe, Gergely Simon (board member) MDRGF, François Veillerette & Angelo San Filippo Grüne Liga e.V., Bundeskontaktstelle Wasser, Michael Bender 1 Cf. Collegium Ramazzini (2010, 17 September): Control of Biocides in the European Union. The Co legium Ramazzini Calls for Action to Protect Human Health. Hyperlink: http://www.collegiumramazzini.org/d... 2 Cf. NGO recommendations for the ENVI vote on Klaß report (Biocide Regulation (COM (2009) 0267)), Brussels 22 June 2010. Hyperlink: http://www.pan-germany.org/download...
01/09/2010	To: President Barroso Re: EU should support the stricter IMO regulation of the sulphur content in marine fuels in European ECAs Berlin, 1 September 2010 EU should support the stricter IMO regulation of the sulphur content in marine fuels in European ECAs Dear President Barroso, The signatories of this letter, representing various European environmental, health and labor associations, would like to express their deep concern at recent calls from certain (shipping) industry groups to weaken crucial marine sulphur limit regulations applying to European Emission Control Areas (ECAs). In their letter, the industry groups raise concerns about “negative consequences” with regard to the IMO emission standards for ECAs applying from 2015 which require the use of marine fuels with a maximum of 0.1 percent sulphur content. The environmental groups and labor associations are deeply concerned about this open attack on existing regulations that are essential for our health and environment. In particular, the argument raised by sections of the shipping industry of so-called “negative impacts on the competitiveness of industries in the affected EU countries” lacks any evidence and proof. Moreover, the argument should be reversed: If all sea areas around Europe (e.g. the Mediterranean Sea, the Black Sea and the North-East Atlantic in addition to existing SECAs in the Baltic and North Sea) would be designated as Emission Control Areas (ECAs) –covering emissions of sulphur, NOx and PM – a situation of balanced competitiveness would be created, protecting the health of thousands of people, preserving the environment and safeguarding jobs. In terms of preventing “negative consequences” for the shipping industry, it is from our viewpoint absolutely crucial to press for an eco-innovative ship industry in Europe. The IMO standards have been known for over two years now. They were strongly and publicly endorsed by the EU and were adopted unanimously by the IMO. More and more ship builders and owners have already reacted and invested in clean and efficient ship technologies they would be punished by reverting to lower standards again. In economic terms, remodeling, retrofitting and optimizing existing ships will create not just a market niche but a growing sector within the ship construction field considering the large size and long lifetime of the current ship fleet and the need for more efficient ships and engines. In economic terms, that means securing existing jobs and creating new ones around the technical modernization and reconstruction of older ships to increase energy efficiency and reduce emissions. The recent demand from some self-interested sections of the maritime industry to amend the IMO decision is unacceptable. The European Union has to clearly stand behind the new 2015 sulphur limits. Bunker fuels used in shipping are essentially toxic waste products of the refinery industry. Conversion to the use of low sulphur fuels is environmentally necessary and long overdue. Their use also provides good incentives for fuel reduction and therefore is also an important step to reduce overall ship emissions. We strongly urge the European Union to uphold and further support the IMO MARPOL decisions setting sulphur caps for designated ECAs as well as a global 0.5% limit in 2020. Even after the global regulation on sulphur comes into effect in 2020, shipping fuel will still contain around 500 times more sulphur than is allowed in road fuels in the EU today. For decades, the shipping industry has benefited from weak pollution regulations allowing them to pollute without paying. The European Commission needs to provide the leadership and technical advice for EU member states to support the additional designation of all European sea areas as ECAs within the framework of the IMO. The successful joint proposal of the U.S. and Canada for the designation of a distance-to-shore ECA covering their West and East coasts (which was approved by the IMO in March this year) shows that the EU should follow such a comprehensive approach to create the same economic condition all around European sea areas. As it is however, the European Commission has not even started the necessary technical work to investigate the feasibility of distance to shore ECAs in Europe. Nor has a firm decision been announced on the delayed revision of the Sulphur in Marine Fuels Directive (2005/33/EC). The EU’s support for the new IMO standards needs to be backed by action to incorporate them into EU legislation. This will also underpin port state authority to police the new regulations. The health and environmental benefits of coastal ECAs in Europe would be outstanding. Adjusted emission and fuel standards will help the shipping industry to develop more fuel and energy efficient ships and become a lead market for clean shipping. Because of the cross cutting character of this issue we are also sending these letters to Commissioners Sim Kallas (Transport), Janez Potočnik (Environment), Connie Hedegaard (Climate), Antonio Tajani (Industry & Entrepreneurship), and Maria Damanaki (Maritime Affairs and Fisheries). In view of the public interest in this matter we are making a copy available to certain media. Thank you for your attention to this important and urgent matter. On behalf of the signatories of this letter, Yours sincerely, Olaf Tschimpke, President NABU e.V. on behalf of the Soot free for the Climate Campaign Jutta Blankau, Regional head IG Metall Bezirk Küste (Industrial Metal Workers’ Union Coastal Region) Supporting organizations Environmental and health organizations: Soot free for the Climate Campaign Friends of the Earth, Germany German Environmental Aid, Germany Verkehrsclub Germany Nature and Biodiversity Conversion Union, Germany World Wide Fund For Nature Europe European Environmental Bureau, Europe/Brussels Health and Environmental Alliance, Europe/Brussels Transport and Environment, Europe/Brussels Verkehrsclub Austria The Clean Air Action Group (CAAG), Hungary Air Pollution and Climate Secretariat, Sweden Stichting Natuur en Milieu, Netherlands Clean Shipping Coalition, Europe Labor union organizations: IG Metall Bezirk Küste/ Industrial Metal Workers’ Union Coastal Region, Germany European Metalworkers‘ Federation, Europe/ Brussels International Transport Workers’ Federation Ver.di, Germany Fédération Générale des Mines et de la Métallurgie (FGMM-CFDT), France Confédération générale du travail (CGT), France Confédération française de l'encadrement - Confédération générale des cadres (CFE-CGC), France Central Organisation of Industrial Employees in Denmark (CO-industri), Denmark Metalliliitto / The Finnish Metalworkers' Union, Finland Metal, Construction and Allied Workers’ Federation/ Union General de Trabajadore (MCA-UGT), Spain General Workers Union, Malta
23/06/2010	To: EFSA Re: Potential adverse health effects associated with BPA exposures Prof. Klaus-Dieter Jany Chair of the CEF Panel European Food Safety Authority Largo N. Palli 5/A 43121 Parma, Italy 23rd June 2010 Dear Prof. Jany, We are writing to welcome the announcement on the European Food Safety Authority (EFSA) website that the CEF panel will be considering ‘hundreds of studies in its review and analysis of the most recent scientific literature’ in its review of the TDI of bisphenol-A in food contact products. Over the last decade and a half, a substantive body amounting to several hundred peer reviewed scientific papers, have been published that have highlighted potential adverse health effects associated with BPA exposures, at internal doses relevant to levels of biologically active BPA found in humans. As a March 2010 Review (Vandenberg et al) of 80 bio-monitoring studies of BPA in Environmental Health Perspectives makes clear; ‘The two toxicokinetic studies performed to date, which suggest that human exposure is negligible, have significant flaws and are therefore not reliable for risk assessment purposes.’ However, in its prior risk assessments of BPA, EFSA only relied on a small number of studies rather than the much larger number that the United States Food and Drug Administration recently recognised as valid and of high utility in its risk assessment of BPA, and which led the FDA to express concern about the health hazards posed by BPA. Only a tiny minority of studies have articulated that BPA exposure is completely safe, and many of these research papers have been criticised in academic commentaries and responses as having serious flaws, but it is these few flawed studies that EFSA previously relied on to declare BPA safe. For example, a letter co-authored by 24 scientists published in the February 2010 edition of Toxicological Sciences states; ‘Publishing studies that conclude no harm in response to low doses of endocrine disrupting chemicals, when the studies did not include a positive control (Tyl et al., 2002), included inappropriate doses of positive controls (Ryan et al., 2009; Tyl et al., 2008), or included positive controls that showed no effect (Cagen et al., 1999), is inappropriate in peer-reviewed journals (Myers et al., 2009a,b; vom Saal and Welshons, 2006). Such studies violate basic principles of study design.’ Many scientific studies are now calling into question the safety of BPA. For example, a recent study has highlighted that BPA may contribute to metabolic disorders relevant to glucose homeostasis, and suggests that BPA may be a risk factor for diabetes (Alonso-Magdalena et al., 2010). Moreover, experiments at Yale university report that BPA may induce altered developmental programming (Bromer et al.,2010), and Doherty et al (2010) of Yale university have published a study which raises the concern about epigenetic effects of BPA on the regulation of the mammary gland, with potential implications for breast cancer risk. Endometriosis is also a concern as work by Signorile et al (2010) highlights that pre-natal exposure of mice to bisphenol-A causes an endometriosis-like response in female offspring. It is therefore our opinion that any objective and comprehensive review of the scientific literature will lead to the conclusion that action is necessary to reduce the levels of BPA exposure, particularly in groups at highest risk, namely young infants and pregnant mothers. There are an increasing number of countries that are either already committed to this course of action, or have signalled that they will soon be undertaking similar measures. We share the concerns of these Governments and regulators and believe that reducing BPA exposure to these groups is both scientifically sound and in the best interest of public health. As such, we call on you as the Chair of the CEF panel and the CEF Committee Members in their ongoing review to include all relevant studies, including bio-monitoring studies, and based on that evidence we conclude that there is a strong scientific mandate for action. Yours sincerely, _Benson Akingbemi, Associate Professor, Department of Anatomy, Physiology and Pharmacology, Auburn University, Auburn, USA. _Prof. Dr. Ibrahim Chahoud, Institute of Clinical Pharmacology and Toxicology, Dept. of Toxicology, Charité - Universitätsmedizin Berlin _André Cicolella, Dipl Eng chemist-toxicologist. _Prof. Patricia Hunt, Meyer Distinguished Professor, School of Molecular Biosciences, Washington State University _Prof. Maricel V. Maffini. Ph.D. Research Assistant Professor. Department of Anatomy and Cellular Biology, Tufts University School of Medicine _Jane Muncke, Ph.D, Environmental Toxicologist, Emhart Glass SA, Switzerland. _John Peterson Myers, Ph.D., Chief Scientist, Environmental Health Sciences, Charlottesville VA. _Angel Nadal, PhD, Professor of Physiology, Instituto de Bioingeniería and CIBERDEM, Universidad Miguel Hernández de Elche, Spain. _Dr John Newby, Medical Information Scientist for the Cancer Prevention Society and Former Member of the Developmental Toxico-Pathology Research Group, Department of Human Anatomy & Cell Biology, Faculty of Medicine, University of Liverpool. _Prof. Jörg Oehlmann, Goethe University Frankfurt am Main, Institute for Ecology, Evolution and Diversity. _Prof. Nicolas Olea, MD, University of Granada, University hospital. _Prof. Gail S. Prins, PhD, Professor of Physiology, Department of Urology, University of Illinois at Chicago. _Prof. Fredrick vom Saal, Curators Professor of Biological Sciences, University of Missouri-Columbia. _Prof. Pietro Giulio Signorile, President of the Italian Endometriosis Foundation. _Prof. Carlos Sonnenschein, MD, Department of Anatomy and Cellular Biology, Tufts University, School of Medicine. _Prof. Ana M Soto, MD, Department of Anatomy and Cell Biology, Tufts University, School of Medicine. _Prof. Hugh S. Taylor, M.D., Professor of Molecular, Cellular and Developmental Biology, Department of Obstetrics, Gynecology and Reproductive Sciences, Yale University. _Laura N. Vandenberg, PhD, Postdoctoral Fellow, Center for Regenerative and Developmental Biology, Tufts University. _Prof. Cheryl S. Watson, PhD, Professor, Biochemistry & Molecular Biology Dept. University of Texas, Medical Branch, Galveston. _Prof. Andrew Watterson, Occupational and Environmental Health Research Group, University of Stirling. _Prof. R. Thomas Zoeller, Biology Department, Morrill Science Center, University of Massachusetts. _Action for Breast Cancer, Malta _Alliance for Cancer Prevention, UK _Arnika, Czech Republic _Association for Environmental and Chronic Toxic Injury, Italy _Austrian section of ISDE (International Society of Doctors for the Environment), Austria _Breast Cancer Fund, USA _Breast Cancer UK, UK _BUND / Friends of the Earth Germany, Germany _Cancer Prevention and Education Society, UK _ChemSec –International Chemical Secretariat, International _CHEM Trust, UK _Chemical Sensitivity Network, Germany _Clean Air Action Group, Hungary _Comité pour le Développement Durable en Santé, France _Danish Consumer Council, Denmark _The Danish Ecological Council, Denmark _Eco-Accord Program on Chemical Safety, Eastern Europe, Caucasus and Central Asia _EcoAid, Germany _Ecologistas en Acción, Spain _Environmental Health Fund, USA _Environment Illinois, USA _European Environmental Bureau, EU _Finnish Association for Nature Conservation, Finland _Friends of the Earth Spain, Spain _Global 2000 / Friends of the Earth Austria, Austria _Health and Environmental Network, Europe _Health Care Without Harm, International _Indiana Toxics Action, USA _Instituto Sindical de Trabajo Ambiente y Salud, Spain _The Irish Doctors' Environmental Association, Ireland _Italian Endometriosis Foundation, Italy _Plastic Planet, Austria _Rachel's Friends Breast Cancer Coalition, USA _Réseau Environnement Santé, France _Society for Sustainable Living, Czech Republic _Unison, UK _VHUE e.V., Germany _Women in Europe for a Common Future, Europe _Women’s Environmental Network, Scotland _Women's Voices for the Earth, USA _WWF European Policy Office, Europe References _Vandenberg LN, Chauhoud I, Heindel JJ, Padmanabhan V, Paumgartten FJ, Schoenfelder G 2010. Urinary, Circulating and Tissue Biomonitoring Studies Indicate Widespread Exposure to Bisphenol A. Environ Health Perspect :-. doi:10.1289/ehp.0901716 http://ehp03.niehs.nih.gov/article/... _vom Saal FS, Akingbemi BT, Belcher SM, Crain DA, Crews D, Guidice LC, Hunt PA, Leranth C, Myers JP, Nadal A, Olea N, Padmanabhana V, Rosenfeld CS, Schneyer A, Schoenfelder G, Sonnenschein C, Soto AM, Stahlhut RW, Swan SH, Vandenberg LN, Wang H, Watson CS, Welshons WV and Zoeller RT. 2010. Flawed Experimental Design Reveals the Need for Guidelines Requiring Appropriate Positive Controls in Endocrine Disruption Research. Toxicological Sciences 2010 115(2):612-613; doi:10.1093/toxsci/kfq048 http://toxsci.oxfordjournals.org/cg... _Alonso-Magdalena P, Vieira E, Soriano S, Menes L, Burks D, Quesada I, et al. 2010. Bisphenol-A Exposure during Pregnancy Disrupts Glucose Homeostasis in Mothers and Adult Male Offspring. Environ Health Perspect :-. doi:10.1289/ehp.1001993 http://ehp03.niehs.nih.gov/article/... _Bromer JG, Zhou Y, Taylor MB, Doherty L, Taylor HS. Bisphenol-A exposure in utero leads to epigenetic alterations in the developmental programming of uterine estrogen response. FASEB J. 2010 Feb 24. [Epub ahead of print] PubMed PMID: 20181937. _Doherty L, Bromer JG, Zhou Y, Aldad TS and Taylor HS. In Utero Exposure to Diethylstilbestrol (DES) or Bisphenol-A (BPA) Increases EZH2 Expression in the Mammary Gland: An Epigenetic Mechanism Linking Endocrine Disruptors to Breast Cancer. Hormones and Cancer. DOI: 10.1007/s12672-010-0015-9. http://www.springerlink.com/content... _Signorile PG, Spugnini EP, Mita L, Mellone P, D’Avino A, Bianco M, Diano N, Caputo L, Rea F, Viceconte R, Portaccio M, Viggiano E, Citro G, Pierantoni R, Sica V, Vincenzi B, Damiano G. Mita DG, Baldi F and Baldi A. Pre-natal exposure of mice to bisphenol A elicits an endometriosis-like phenotype in female offspring. General and Comparative Endocrinology. doi:10.1016/j.ygcen.2010.03.030.
15/06/2010	To: President van Rompuy Re: Stepping up the EU’s climate ambition could be a green way out of Europe’s economic blues 15 June 2010 Dear President van Rompuy, Europe’s financial woes are likely to get top billing at this week’s EU summit. Over the past few weeks, governments have announced cuts of billions of euros that will affect millions of Europeans. Hard times indeed. But stepping up the EU’s climate ambition could be a green way out of Europe’s economic blues. With stronger climate targets, European governments could create hundreds of thousands of new green jobs, according to a recent European Commission report. Instead of wasting cash on foreign oil and gas, EU countries could save up to €40 billion by boosting renewables. Savings in pollution control and health costs would be worth between €6.5 billion and €11.5 billion. A solid commitment for the climate could also help generate billions that could help governments consolidate their budgets. Upgrading the EU’s 2020 climate target from 20% to 30% would raise additional income of nearly €70 billion from emissions trading alone – a more than tidy sum to help EU countries reduce mounting budget deficits. (Based on new research, the table attached shows how much each country could gain.) A 40% cut in emissions, which scientists say could help head off the most catastrophic effects of climate change, would help raise even more income. But so far, you and other European politicians seem unwilling to harness these benefits. Since the Copenhagen climate conference, many European leaders have taken a back seat, claiming there was no way forward until the rest of the world caught up with the EU’s climate commitments. But while the EU waits for a diplomatic breakthrough, China and the United States speed ahead in the race for green technologies and energy independence. China has in fact already overtaken Europe in the production of solar panels and the installation of wind turbines. Representing Europe’s leading environmental organisations with over 20 million supporters, we ask you and other European leaders to act in the interest of competitiveness, of the people of Europe and of the environment we live in. We urge you to seriously consider the benefits of increasing Europe’s climate ambition at the EU summit this week and to follow up on your promise to hold a special summit on climate change in September. Slashing spending may help get European economies out of this recession, but investing in the transformation of the real economy will deliver technological innovation, greater resilience to fuel price fluctuations, increased revenues and greater energy security. We hope you recognise these facts and will lead your colleagues forward on Europe’s climate ambition. Yours sincerely, Angelo Caserta, Regional Director of the European Division – BirdLife International Matthias Duwe, Director – Climate Action Network (CAN) Europe asbl Anelia Stefanova, EU affairs coordinator – CEE Bankwatch Network John Hontelez, Secretary-General – European Environmental Bureau Magda Stoczkiewicz, Director – Friends of the Earth Europe Jorgo Riss, Director – Greenpeace European Unit Genon K. Jensen, Executive Director – Health & Environment Alliance Christian Baumgartner, Generalsekretär, Naturfreunde Internationale Jos Dings, Director – The European Federation for Transport and Environment (T&E) Tony Long, Director – WWF European Policy Office
09/06/2010	To: Commissioner Potocnik Re: NGO call for a prioritisation of air quality action (revision of the National Emission Ceilings and the Sulphur Content of Marine Fuels Directives) Brussels, 9 June 2010 To: Mr. Janez Potocnik, European Commissioner for the Environment Cc.: Mr. Karl Falkenberg, Director-General, DG Environment, European Commission Re: NGO call for a prioritisation of air quality action (revision of the National Emission Ceilings and the Sulphur Content of Marine Fuels Directives) Dear Commissioner Potocnik, As environment and health NGOs working on the improvement of air quality, we are writing to express our serious concerns about the Commission’s continued postponement of essential legislation in the field of air pollution. We previously wrote to you about air pollution from ships shortly after you took office but regrettably we feel the need to express our concerns more strongly and more specifically with this letter. Air pollutants are estimated to cause close to half a million premature deaths each year as well as severe damage to the environment through eutrophication, acidification and ground-level ozone throughout Europe. The revision of key legislation on emissions is therefore needed and would help Member States comply with limit values on ambient air quality which are currently exceeded in most parts of Europe. Given the importance of improving Europe’s air quality, and the synergistic effects of Commission work in other areas such as sustainable transport, climate change, health, biodiversity, and industrial policy (notably the Industrial Emissions Directive recast) we see no excuse for such delays and call upon you to raise the political profile of such an important issue affecting human and environmental health. In particular, we call upon you to activate without further delay the revision of the following legislation: Directive 2001/81/EC on national emission ceilings (NEC) The NEC Directive is the cornerstone of EU legislation to control overall levels of air pollution in Europe. The proposal for a revision of the NEC Directive was to be published in 2005, together with the Thematic Strategy on air pollution. However, the proposed revision has been repeatedly postponed by the European Commission. We would like to highlight that: Current national emission ceilings are not sufficient to meet even the interim health and environmental targets for 2010 laid down in the Directive, so new stricter ceilings are urgently needed. Moreover, without a revised NEC Directive, the overall emission of fine particulate matter (PM2.5), which is the pollutant with the highest estimated impact on human health, will remain unregulated. Sector legislation (such as IED, vehicle emission standards, etc.) is necessary, but does not guarantee the attainment of environmental and health quality targets. Current EU efforts addressing climate change will benefit from new national emission ceilings as greenhouse gases and air pollutants generally come from the same sources. Recently agreed biodiversity targets for 2020 will not be met without a reduction of air pollution which is responsible for widespread acidification of soil and water and eutrophication of terrestrial and coastal ecosystems in Europe. Further postponement of the NEC revision may result in increased costs for Member States and industry which need enough lead-in time to implement new ceilings. The cost-benefit analysis done in preparation of the NEC revision shows that the benefits for health, the environment and the economy will significantly outweigh the costs involved. Further postponement of the NEC will have wider international implications, such as slowing down progress under the Convention on Long-Range Transboundary Air Pollution (LRTAP) in revising the Gothenburg Protocol and risking undermining the EU’s credibility in these negotiations. One important consequence of the Gothenburg Protocol is that measures to reduce emissions are also implemented in non-EU countries influencing health and ecosystems within the EU. With a revised NEC Directive to refer to, the EU would strengthen its position in these negotiations and likely also improve the overall outcome of these negotiations. Directive 2005/33: Sulphur Content of Marine Fuels Directive Emissions of air pollution from sea-going ships are continuously increasing and are becoming one of the most pressing air pollution problems in Europe. This is happening despite existing cost-effective means to reduce shipping air pollution by as much as 80-90 per cent. A simple and efficient way of reducing emissions of SO2 and PM is to reduce the sulphur content of marine fuels. The International Maritime Organisation (IMO) took a major step forward in 2008 through amendments to Marpol Annex VI which set stricter marine sulphur limits worldwide in 2020 and enabled the establishing of emission control areas where more stringent limits would apply earlier. The US and Canada have already established such an emission control area around their coasts and the US recently enshrined the IMO provisions in its legislation. EU legislation needs similarly to reflect the IMO decisions and the 2008 review of Directive 2005/33 was specifically delayed until 2010 to do just that. We see no justification for a further delay or a piecemeal approach to revising this Directive. The Commission should adopt IMO standards as soon as possible in 2010 to signal its commitment to these breakthrough standards and to provide industry with a clear basis for developing sulphur abatement measures and the long term investments to meet the 2015 and 2020 limits. The Commission also needs to take an active role in assessments and consultations to expand emission control areas around Europe as they will play a critical part in Europe being able to meet environment objectives and air quality standards. As this new Commission continues to settle in, we call upon you to fight for the importance of improved air quality in Europe, to build upon work being done in other policy areas but which need the support of air quality legislation. The immediate revision of these two Directives is key in achieving clean air for Europe. Yours sincerely, John Hontelez, Secretary General, European Environmental Bureau Jos Dings, Director, Transport and Environment Christer Ågren, Director, Air Pollution and Climate Secretariat Genon Jensen, Executive Director, Health and Environment Alliance
20/05/2010	To: MEPs Re: Call for restriction of BFRs and PVC in electrical and electronic equipment in the RoHS revision The RoHS Directive must, in accordance with its stated objectives, consider the impact of chemical substances and their transformation products in the production, use and waste phase. It should therefore promote the substitution of hazardous substances in Electrical and Electronic Equipment (EEE) to protect the environment and human health and enhance the possibilities for recycling, based on swift uptake of new scientific evidence, and the precautionary principle. We, the undersigned public interest organisations, accordingly urge the European Parliament to strengthen the European Commission proposal for a revised RoHS Directive, and in particular: Restrict by 2015 at the latest halogenated organic substances in EEE, to a maximum of 0,1% (w/w) such as Brominated Flame Retardants (BFRs) and Polyvinyl Chloride (PVC) that cause serious concern throughout their lifecycle (production, use, disposal) and hamper recyclability Background The objective of the RoHS Directive is to protect human health and the environment and, more specifically, to contribute to environmentally sound recovery and disposal of electrical and electronic equipment1. Many substances with undesirable properties such as being Persistent, Bio-accumulative and Toxic (PBTs) or Carcinogenic, Mutagenic or Toxic for Reproduction (CMRs), endocrine disrupting or otherwise hazardous because of their nanoscale, are used in many Electrical and Electronic Equipment (EEE). In order to eliminate the adverse effects of hazardous substances and highly toxic transformation products in the life cycle of EEE, a number of prominent actors, equipment manufacturers and component suppliers have invested in substitution of hazardous substances in EEE including a general phase-out of halogenated organic substances. Their efforts have led to the transformation of the electronics supply-chain globally. This is not only due to the global nature of the supply chains in the EEE industry but also due to the fact that the EU RoHS legislation has been taken over by many other political entities outside the EU. In the case of RoHS, and contrary to what is commonly assumed, globalization has not led to a race to the bottom in environment and health protection policy. RoHS has triggered the introduction of similar regulations in California, China, Japan and South Korea. Australia, New Zealand, Malaysia, Taiwan and Thailand are currently considering the introduction of a similar policy. Setting a new high environment and health protection standard through the current RoHS revision in the EU will improve the environment and health both inside and beyond the EU. EU regulators now have a unique possibility support and uphold the momentum gained in parts of the industry by strengthening the RoHS Directive. We, the undersigned public interest organisations, consequently urge you to strengthen the European Commission proposal for a revised RoHS Directive. Some supporting arguments: Some phthalates which are used as plasticizers in PVC are classified in the EU as toxic to reproduction, recognised as Substances of Very High Concern under REACH2, and are also Endocrine Disrupting Chemicals (EDCs)3. The endocrine disrupting effects of halogenated flame retardants like TBBP-A are also demonstrated in the scientific literature4,5. TBBP-A is widely used in EEE - about 40.000 tonnes per year in the EU alone - and has been found in human blood-samples and human breast milk as well as in remote regions including the Arctic and in all kinds of animals (in wide variety of marine organisms, predatory birds, etc). Although there remain scientific gaps in order to determine the official classification of TBBP-A, existing evidence indicates that TBBP-A is very toxic to aquatic organisms; is persistent and potentially very persistent, and there are potential endocrine disruption effects. Another reason for banning halogenated organic substances and materials in EEE is because they have the potential to form dioxins and furans when incinerated under suboptimal conditions or otherwise subjected to thermal stress like extrusion, moulding, shredding or sunlight exposure. Dioxins are classified as very toxic and very persistent substances, and are recognized as priority contaminants in the Stockholm Convention for the elimination of Persistent Organic Pollutants (POPs). Thus their formation is both a local and global problem and damages health and environment at a global scale, irrespective of where they are formed. The restriction of halogenated organic substances will: increase the reusability and recyclability of EEE and, at the same time, protect humans and especially vulnerable groups like babies and children and highly exposed populations such as workers in the electronics recycling industry from cumulative exposure to chemicals that are demonstrated to pose severe health hazards confirm progress and support the momentum gained in parts of the industry by strengthening their voluntary substitution commitments improve the environment and public health both inside and beyond the EU For more information on alternatives to BFRs please consult “Alternatives to Brominated Flame retardants “ presented on 23rd March 2010 by the Phosphorus, Inorganic, Nitrogen Flame Retardants Association http://www.chemsec.org/images/stori... European_Parliament_RoHS_20100323_Final.pdf Please also see Industry Position Papers supporting the proposals for PVC and BFR substance bans in the RoHS revision by: ACER http://www.chemsec.org/images/stori... Cl_Br-free_of_RoHS_Revision.pdf), Hewlett Packard http://www.chemsec.org/images/stori... and Dell http://i.dell.com/sites/content/cor.... pdf 1 Article 1, 2002/95/EC, RoHS Directive. 2 REACH Regulation No 1907/2006, OJEU 29.05.2007. Substances of Very High Concern list: http://echa.europa.eu/chem_data/aut... 3 See the ‘Priority List’ and studies commissioned for European Commission’s DG Environment, where ‘Category 1’ EDCs are listed: http://ec.europa.eu/environment/end... 4 Lilienthal, H., Verwer, C.M., Van der Ven, L.T.M., Piersma, A.H., Vos, J.G., 2008. Neurobehavioral effects of tetrabromobisphenol A (TBBPA) in rats after pre- and postnatal exposure. Toxicology 5 Van der Ven LT, Van de Kuil T, Verhoef A, Verwer CM, Lilienthal H, Leonards PE, Schauer UM, Cantón RF, Litens S, De Jong FH, Visser TJ, Dekant W, Stern N, Håkansson H, Slob W, Van den Berg M, Vos JG, Piersma AH., 2008. Endocrine effects of tetrabromobisphenol-A (TBBPA) in Wistar rats as tested in a one-generation reproduction study and a subacute toxicity study. Toxicology
14/04/2010	To: MEPs Re: Strengthen health protection and include health co-benefits in adaptation policy Brussels, 14 April 2010 To: Members of the European Parliament Concerning: Plenary vote on the European Parliament Report on the European Commission White Paper: “Adapting to climate change: Towards a European framework for action’ (COM (2009)0147 - 2009/2152 (INI)).” Plenary vote on 21 April 2010 Strengthen health protection and include health co-benefits in adaptation policy Dear Member of the European Parliament, We, the undersigned leading European health and medical organisations are writing about the forthcoming Plenary Vote on the European Parliament Report (A7- 0057/2010) on the Commission White Paper: “Adapting to climate change: Towards a European framework for action (COM (2009)0147 - 2009/2152 (INI)”. We welcome that the Parliament’s Report contains its own chapter on ‘Health and social policies’, and contains recitals and articles that seek to take into consideration the range of climaterelated health impacts, promote protection of public health, take into account health cobenefits, and recognise the important role of the health sector in adaptation. We urge you to vote in favour of those recitals and articles (Annex I) in the Report (A7- 0057/2010) that would strengthen health protection and include health co-benefits in adaptation policy. Please vote in favour of recitals D and H; and articles 47, 48, 50, 110. As you are aware, climate change will affect people, their economies and ecosystem in disproportionate ways. For example, those already ill, the poor and disadvantaged populations, children and the elderly would be most at risk. The health sector will need to be at the forefront responding to the effects of climate change, and developing adaptation measures which do not add further to the climate problem. Increased awareness and resources are needed to ensure this happens and provide support for the sector’s efforts in reducing its climate footprint as recently highlighted in the WHO/HCWH discussion paper: ‘Healthy Hospitals, Healthy Planet, Healthy People: Addressing climate change in healthcare settings1’. We are pleased to see that Parliament’s Report (A7-0057/2010) acknowledges the need to halt global warming at 2°C, and that current pledges do not go far enough in order to prevent even more drastic health impacts from climate change, such as increased deaths from respiratory and vector borne disease, for example. Science suggests that a reduction in greenhouse gases by at least 40% below 1990 levels by 2020 is the minimum required to keep global warming well below the dangerous 2°C level. Action at this level would significantly improve people’s health, reduce Member States' rising healthcare costs, and protect our fragile ecosystems. Finally, we would ask you to support article 48 on ensuring that adaptation measures that are promoted are also those that provide “health co-benefits”. The benefits to health of tackling climate change can offset much of the costs of global action, as is outlined in the IPCC’s 4th Assessment report, chapter 8 on human health2. European studies have also clearly shown that stronger greenhouse gas emission reduction targets can protect health. For example, research commissioned by HEAL, CAN and WWF in 2008 has shown that a 30% target would result in estimated health benefits measured in monetary terms of up to 76 billion Euros per year from 2020 onwards.3 We look forward to working with you to ensure that health becomes a cornerstone of international and EU climate change mitigation and adaptation policy. Sincerely, Genon K. Jensen, Health and Environment Alliance (HEAL) On behalf of: Health Care Without Harm Europe (HCWH Europe) European Respiratory Society (ERS) Climate and Health Council (CHC) International Society of Doctors for the Environment (ISDE) AerztInnen fuer eine gesunde Umwelt, AeGU (ISDE) Austria The Standing Committee of European Doctors (CPME) Association for Environmental Health(EGYESÜLET A KÖRNYEZET-SZSÉGÜGYÉRT – E.K.E.) Partners voor Gezond Leefmilieu (PGL) Platform Gezondheid en Milieu (PGM) Bewonersgroep Waterland Fédération Inter-Environnement Wallonie Communities Against Toxics Action for Breast Cancer Foundation 1. World Health Organization and Health Care Without Harm, April 2009. Healthy Hospitals, Healthy Planet, Healthy People: Addressing climate change in health care settings. Available at: http://www.who.int/globalchange/pub.... 2. IPCC Fourth Assessment Report – Chapter 8 – Human Health; http://www.ipcc.ch/pdf/assessment-r... chapter8.pdf 3. The co-benefits to health of a strong EU climate change policy, 2008, CAN Europe, Health and Environment Alliance, WWF http://www.env-health.org/IMG/pdf/C... See also: recent study on health co-benefits: Lancet Series report on Health and Climate Change, 25 November 2009 http://www.thelancet.com/series/hea... Annex I Please support the following in the Plenary Vote on 21 April 2010 Recitals D and H: D. whereas the target of halting global warming at +2°C would still mean a warming scenario for Europe, marked by extreme regional climate changes, and whereas the current pledges notified to the UNFCCC would add up to warming of +3.5-4°C if implemented, H. whereas, according to the European Respiratory Society, for every Celsius degree increase in temperature over a given city-specific threshold, mortality amongst those with respiratory problems increases by 6%, Articles 47, 48, 50 and 110: 47. Welcomes the proposals of the Commission to develop guidelines and surveillance mechanisms on the health impact of climate change by 2011; underlines the increasing risk of propagation of vectorborne diseases, the serious impacts on respiratory health and the need to educate European citizens about effective preventive measures recommended by the European Centre for Disease Prevention and Control; 48. Notes that the health impacts of climate change are likely to impact the hardest on the most deprived communities, the poorest populations and the most vulnerable groups, such as children, the elderly and those who are already ill; regards it as essential for adaptation measures to be considered in the context of health inequalities, and for such measures to encourage action that promotes health cobenefits; 50. Recognises the role the health sector plays in adaptation; calls on the EU to support action to reduce the sector’s carbon footprint, and to ensure adequate financing for adaptation measures in the health sector; 110. Supports the proposal of the Commission to set up an impact and adaptation steering group; stresses that it is important for this group to involve regional and local actors in addition to state representatives; asks the Commission to ensure that this group includes representatives of Parliament as observers , as well as private stakeholders in an expert capacity; calls on the Commission to ensure that the steering group pays particular attention to the most severe health impacts of climate change, such as increases in weather-related deaths and vector-borne disease;
07/04/2010	To: ITRE Committee Re: NGO vote recommendations in view of the vote in the ITRE-Committee on the amendments to the Commission’s proposal for a biocidal regulation (COM 0267) To Members of the EP Committee for Industry, Transport and Research (ITRE) NGO vote recommendations in view of the vote in the ITRE-Committee on the amendments to the Commission’s proposal for a biocidal regulation (COM 0267), Brussels 7 April 2010 Dear Member of the Committee, On the 7th April 2010 you will vote on the amendments to the Commission’s draft for a biocide regulation. These amendments are tabled by the ITRE rapporteur Sajjad Karim and further members of the Committee. Your decision can contribute to better regulate the authorisation of products like insecticides, disinfectants, nano-biocides and rodenticides. We urge you to ensure the highest level of protection for human health and the environment, since biocide products are typically used by consumers with limited awareness of the product and their impact. This can lead to misuse of the product and uncontrolled disposal of intrinsically hazardous substances which can have adverse effects, in particular to vulnerable groups and the environment. We believe that a revised and strengthened biocide regulation can also ensure a clear incentive framework for research and innovation in sustainable alternatives of pest management. With regard to these aspects, Fédération Inter-Environnement Wallonie, Health and Environment Alliance (HEAL), Health Care Without Harm Europe, Pesticide Action Network (PAN) Europe, PAN Germany, PAN UK and Women in Europe for a Common Future (WECF) welcome and support the following amendments as they address significant challenges of the Commission’s draft. Please vote for the following amendments: ensure a clear framework to ban highly hazardous biocides (amendments 31, 72, 75) establish coordinated actions for the use phase of biocides (amendments 91 and 92) support products with substances of no concern (amendment 99) promote transparency (amendments 43, 174, 192-194) introduce efforts to identify and tackle impacts of nano-biocides (amendments 185, 186) Furthermore, we believe that it is necessary to continue with the current standards for the functioning of a sustainable common market. Therefore, please vote against the following amendments: introduction of vague exemptions that risk an EU-wide approval of highly toxic substances applied in drinking water plants (amendments 6 and 74) loopholes that prevent a clear and timely substitution regime (amendments 83-84, 109-116, 199) problematic simplification of the EU-wide distribution of products that may result in anti-microbiological resistancies or other serious impacts for human health and the environment (amendments 12, 30, 138-140) weakening of provisions for treated articles (amendments 36, 162-164, 167-169, 172- 173) We should be most grateful if you consider our recommendations. Please do not hesitate to contact us for further information. Yours sincerely, Pesticide Action Network Germany Christian Schweer (Biocide Coordinator EU) Pesticide Action Network UK Nick Mole (Policy Officer) Health and Environment Alliance (HEAL) Anne Stauffer Pesticide Action Network Europe/ Clean Air Action Group Gergely Simon (Board member) Women in Europe for a Common Future Demi Theodori Health Care Without Harm Europe Anja Leetz (Executive Director) Fédération Inter-Environnement Wallonie 150 associations au service de l'environnement Valérie Xhonneux
29/03/2010	To: ENVI Committee Re: Please ensure the recognition of the role of environmental and occupational factors in cancer and the primary prevention of cancer ENVI Vote on Commission communication on Action against Cancer: European Partnership (7 April, 2010) Please ensure the recognition of the role of environmental and occupational factors in cancer and the primary prevention of cancer Dear Member of the ENVI Committee, One in ten women in Europe are getting breast cancer. Male reproductive health problems which heighten men’s risk for testicular and prostate cancer later in life also seem to be rising across Europe. Cancers in children are increasing by a shocking 1% every year. Altogether it is estimated that one in three people in the EU will develop some form of cancer during their lifetime. The European Parliament has a unique opportunity to guide future EU action to reduce cancer and respond to increasing environmental health science which shows that chemical pollution in our environment and occupational settings plays a role, as recognised in previous European Parliament resolutions. The environmental contamination factors for cancer include exposure to the following in water, air, soil, food and physical items: Cancer causing chemicals (carcinogens) DNA altering chemicals (mutagens) Hormone disrupting chemicals (endocrine disruptors) as well as the more well known factors such as tobacco smoke, radiation, and UV rays. In order to prevent further rising of cancer rates, it is therefore crucial to not only consider individual lifestyle changes and screening, but to clearly include environmental and occupational, and specifically chemical pollution and non-voluntary exposures, especially those of fetuses and young children, in cancer prevention programmes and actions. At the next ENVI meeting on 7 April, you can help to ensure that action on environmental contamination factors in cancer is given the importance it deserves. The undersigned organisations call on you to support the amendments listed below to the Draft Report by Alojz Peterle on Action Against Cancer. We urge you to vote for wording that clearly expresses the need to address the environmental and occupational dimension in preventing cancer. This concerns particularly involuntary exposures to harmful chemicals linked to cancer so that primary prevention is distinct from early detection (screening), and individual lifestyle measures. Please vote for amendments (see attached Voting Recommendation sheet): 3, 6-9, 12, 13, 20, 21, 24, 36, 44, 45, 54, 55, 57, 59, 62-64, 66, 73, 80, 81. These amendments listed above Define ‘environmental factors’; and distinguishes primary and secondary prevention Ensure prevention includes work on environmental contamination factors Call for research on environmental factors, and resources on environmental prevention Call for swifter action on the Community Strategy on Endocrine Disruptors We hope you will agree that every effort is needed to reduce the breast cancer epidemic, combat testicular cancer and reduce childhood cancer rates, and this includes addressing environmental and chemical contamination as part of the wider effort. Sincerely, Genon Jensen, Health and Environment Alliance (HEAL) On behalf of: The European Respiratory Society (ERS) Women in Europe for a Common Future (WECF) Health Care Without Harm Europe (HCWH) International Society of Doctors for the Environment (ISDE) USA Cancer Prevention Coalition Pesticide Action Network Europe UK Alliance for Cancer Prevention Action for Breast Cancer Foundation, Malta Stichting Ecobaby, the Netherlands Initiativ Liewensunfank, Luxembourg AKUT Environmental Health and Indoor Air Quality, Luxembourg Association for Research and Treatments Against Cancer (ARTAC), France CHEMTrust, UK Cancer Prevention and Education Society, UK Pesticide Action Network, UK Breast Cancer UK Doctors for a Healthy Environment, Austria (ISDE Austria) Foundation Against Cancer, Belgium Federation Inter-Environment Wallonie (IEW), Belgium Flanders Physicians for the Environment (VLAMM), Belgium National Center of Public Health Protection (NCPHP), Sofia, Bulgaria Clean Air Action Group, Hungary
08/03/2010	To: ENVI Committee Re: Proposals to amend the European Parliament draft report on the “Commission White Paper: ‘Adapting to climate change: Towards a European framework for action’ (2009/2152 (INI)) Brussels, 8 March 2010 To: Members of the European Parliament Committee on Environment, Public Health and Food Safety (ENVI Committee) Concerning: Proposals to amend the European Parliament draft report on the “Commission White Paper: ‘Adapting to climate change: Towards a European framework for action’ (2009/2152 (INI)).” Upcoming ENVI Vote on 16 March on Adapting to Climate Change: Strengthen health protection and include health co-benefits in adaptation policy Dear Member of the ENVI Committee, We, the undersigned leading European health and medical organisations are writing about the upcoming ENVI Vote on the “Commission White Paper: ‘Adapting to climate change: Towards a European framework for action’ (2009/2152 (INI). We welcome that the ENVI draft report has its own chapter on ‘Health and social policies’, but would urge you to strengthen your draft report by voting for the amendments (Annex I below) that would take into consideration the range of climate-related health impacts, promote protection of public health, take into account health co-benefits, and recognise the important role of the health sector in adaptation. Please support amendments: 9, 14, 76, 78, 81 and 171. As you are aware, climate change will affect people, their economies and ecosystem in disproportionate ways. For example, those already ill, the poor and disadvantaged populations, children and the elderly would be most at risk. The health sector will need to be at the forefront responding to the effects of climate change, and developing adaptation measures which do not add further to the climate problem. Increased awareness and resources are needed to ensure this happens and provide support for the sector’s efforts in reducing its climate footprint as recently highlighted in the WHO/HCWH discussion paper: ‘Healthy Hospitals, Healthy Planet, Healthy People: Addressing climate change in healthcare settings1’. We are pleased to see amendments about the need to halt global warming at 2°C, and that current pledges do not go far enough in order to prevent even more drastic health impacts from climate change, such as increased deaths from respiratory and vector borne disease, for example. Science suggests that a reduction in greenhouse gases by at least 40% below 1990 levels by 2020 is the minimum required to keep global warming well below the dangerous 2°C level. Action at this level would significantly improve people’s health, reduce Member States' rising healthcare costs, and protect our fragile ecosystems. Finally, we would ask you to support amendment 78 on ensuring that adaptation measures that are promoted are also those that provide “health co-benefits”. The benefits to health of tackling climate change can offset much of the costs of global action, as is outlined in the IPCC’s 4th Assessment report, chapter 8 on human health2. European studies have also clearly shown that stronger greenhouse gas emission reduction targets can protect health. For example, research commissioned by HEAL, CAN and WWF in 2008 has shown that a 30% target would result in estimated health benefits measured in monetary terms of up to 76 billion Euros per year from 2020 onwards.3 We look forward to working with you to ensure that health becomes a cornerstone of international and EU climate change mitigation and adaptation policy. Sincerely, Genon K. Jensen, Health and Environment Alliance (HEAL) On behalf of: Health Care Without Harm Europe (HCWH Europe) European Respiratory Society (ERS) Climate and Health Council (CHC) International Society of Doctors for the Environment (ISDE) AerztInnen fuer eine gesunde Umwelt, AeGU (ISDE) Austria The Standing Committee of European Doctors (CPME) Vlaamse Artsen voor Milieu & Maatschappij (VLAMM). 1 World Health Organization and Health Care Without Harm, April 2009. Healthy Hospitals, Healthy Planet, Healthy People: Addressing climate change in health care settings. Available at: http://www.who.int/globalchange/pub.... 2 IPCC Fourth Assessment Report – Chapter 8 – Human Health; http://www.ipcc.ch/pdf/assessment-r... chapter8.pdf 3. The co-benefits to health of a strong EU climate change policy, 2008, CAN Europe, Health and Environment Alliance, WWF http://www.env-health.org/IMG/pdf/C... See also: recent study on health co-benefits: Lancet Series report on Health and Climate Change, 25 November 2009 http://www.thelancet.com/series/hea...
23/02/2010	To: ENVI Committee Re: NGO position on the draft Klaß report concerning the biocide regulation To Members of the EP Committee for Environment NGO position on the draft Klaß report concerning the biocide regulation (EP Envi Committee Meeting, 23 February 2010) Dear Member of the ENVI Committee, on 23 February 2010 you will consider the draft report of MEP Christa Klass (EPP) on the Commission’s proposed biocide regulation (COM (2009) 267 final). CEPTA, Grüne Liga, Health and Environment Alliance (HEAL), Fédération Inter- Environnement Wallonie, Women in Europe for a Common Future (WECF), Mouvement pour le Droit et le Respect des Générations Futures (MDRGF), Clean Air Action Group Hungary, NABU, National Movement Friends of the Earth Bulgaria, Pesticide Action Network (PAN) Germany, PAN UK and PAN Europe welcome several amendments of the draft report as they will improve the Commission’s proposal at crucial passages: requirements for water protection, new provisions regarding hazardous substances and information. Despite these positive amendments, we believe that the report is not balanced enough. It devotes too much focus on individual technical or industry-related issues rather than to significantly tackling the big challenges and open questions of the Commission’s proposal associated with the marketing and use of problematic biocides in Europe. The report’s suggestions neither effectively protect the environment and human health, nor initiate a consistent change towards the phasing-out of hazardous substances and an innovative framework for the development and application of low-risk products and other sound pest management alternatives (please see our key demands on the biocide regulation). In particular, we urge you to promote changes in the report which will ensure: A better protection of human health and the environment from adverse effects of biocides, particularly for vulnerable groups and biodiversity a strict cut-off system a real low-risk approach a clear framework for the promotion of sound alternatives sufficient data-requirements a systematic approach for the use phase a guarantee of public access to information In detail, we urge you to improve the report to: 1. Better protect human health and the environment from adverse effects of biocides, particularly the health of vulnerable groups and biodiversity – amend Articles 1 and 3 On the one hand, we understand the rapporteur’s amendment 10 as an initiative to protect human and animal health and the environment in principle and at a high level. We welcome this modification as a step forward. However, the regulation should also include the goal of ensuring that human health and the environment are protected from adverse effects of biocides. This would bring the Biocides regulation in line with the chemicals legislation REACH and the recently adopted Regulation on Plant Protection Products (Regulation no. 1107/2009). Increasing scientific evidence is emerging that shows certain groups of the population such as pregnant women or children are especially vulnerable to harmful effects of chemical substances, including biocides. The Regulation on Plant Protection Products recognizes their vulnerability and ensures that their specific sensitivity is taken into account in risk assessment and authorisation. The rapporteur’s draft report on Biocides should be brought in line with these provisions. It is also important to ensure that biocides and their use do not adversely affect biodiversity and Europe’s endangered species. 2. A strict cut-off system – amend Articles 5 and 45 Although the rapporteur’s draft will include in the cut-off criteria environment-related obligations and will introduce criteria for endocrine-disrupting substances (see amendment 27), the whole approach remains insufficient. Her approach, just like the Commission proposal, would still allow cancerogenic, mutagenic and reprotoxic (CMR) substances and other highly hazardous substances on the market. We think there should not be derogations from the exclusion criteria in art. 5. Article 45 offers a sufficient framework in cases of emergency but should be also strengthened for the protection of human health and the environment. 3. A real low-risk approach – amend Articles 3, 16 and 17 Nothing has been done to close the loopholes in the concept for low-risk products in the Commission proposal. Although such products will be eligible for an EU-wide authorisation (= one-zone approach of authorisation), the new approach will significantly weaken the current provisions of the Biocidal Products Directive for low-risk products (e.g. no sufficient assessment of the relevant active ingredients as they don’t have to be approved for inclusion into Annex I, no ban on substances of concern). All substances for low-risk products should be included in Annex I (undergo risk assessment) and should be of low hazard. The absence of exposure is not enough grounds for classifying a biocide as low-risk. 4. A clear framework for the promotion of sound alternatives – amend Articles 3, 9, 21, 33, 44, 70 Instead of strengthening the substitution principle (e.g. by means of introducing mandatory substitution/phasing-out plans) and supporting efforts for the development and marketing of real low-risk products, the rapporteur’s approach is to guarantee a centralised authorisation for every kind of biocidal product even though such products can include ingredients of concern (cf. amendment 57ff). We are particularly concerned that the EU standards for risk assessment and authorisation of insecticides will be replaced with the WHO Pesticides Evaluation Scheme (WHOPES, amendment 12). WHOPES functions through the participation of representatives of governments, manufacturers of pesticides and pesticide application equipment etc. It does not meet European standards of transparency and participation. As well, insecticides can be very harmful and WHOPES does not necessarily consider environment- related issues, sound alternatives or how to protect vulnerable citizens and endangered ecosystems at regional or local level from the adverse effects of insecticides. 5. Sufficient data requirements – amend Articles 16, 19, Annex II & IV Necessary amendments in order to strengthen the data requirements are still absent. This is problematic as the Commission’s proposed authorisation system does not sufficiently assess new active substances or products, especially on impact of their metabolites and combination effects on vulnerable groups or sustainable uses of natural resources, effects on natural drinking water sources or impacts on the biodiversity of the marine environment and groundwater dependent ecosystems. The rapporteur’s proposal can even contribute to more complicated situations as it introduces possibilities for the non-assessment of substances (amendment 46) and for further derogatory simplifications of the evaluation and authorisation procedure (e.g. amendment 67: reducing the time line for evaluating assessments). 6. A systematic approach for the use phase – amend Article 15 The already documented high number on poisoning incidents in Europe should instigate ambitious and binding efforts for the use phase (e.g. training measures, certification schemes, definition of good practice and sensitive areas). We welcome the rapporteur’s initiative to introduce measures for elucidation in order to minimise the use of biocides (amendment 94). But this should only be a part of a more systematic approach within a strategy for an integrated pest management and within national action plans. For this reason, it is necessary to initiate a framework directive for the use phase which should be established in a clear time line. Such a framework is already introduced in order to regulate the use phase of pesticides. 7. Guarantee public access to information – amend Articles 54, 55, 56, 57 and 58 All information on substances, their health and environmental impacts as well as statistics should be publicly available and regularly updated. The Commission’s proposal weakens current standards of the biocide legislation by repealing obligations for publishing implementation reports. We are also concerned that the rapporteur’s draft will establish new possibilities for data protection (amendments 83 & 85) instead of opposing the weaker implementation standards. Consequently, there is still a severe gap on transparency and a lack of requirements for sufficient reporting on the biocide market, citizen’s exposure to biocides and relevant effects on humans, animals and the environment. As well, obligations for a specific labelling of products which contain nano-biocides or which have been manufactured by means of nano-technology are still missing. Hence, consumers will be faced with an intransparent situation. We should be most grateful if you considered our comments and recommendations. Please do not hesitate to ask for further information. Yours sincerely, Pesticide Action Network Germany, Christian Schweer Pesticide Action Network UK, Nick Mole (Policy Officer) CEPTA - Centre for Sustainable Alternatives, Daniel Lesinsky Women in Europe for a Common Future, Demi Theodori Health and Environment Alliance (HEAL), Anne Stauffer Pesticide Action Network Europe/ Clean Air Action Group, Gergely Simon (Board member)
26/01/2010	To: ENVI Committee Re: Report on the proposed regulation on food information to consumers Brussels, 26 January 2010 Environment and Health NGOs’ comments on labelling of foodstuffs: Environment Committee’s report on the proposed regulation on food information to consumers [Discussion of amendments in ENVI, 27 January 2010 – Sommer report] The Health and Environment NGOs welcome the Commission’s proposal on an EU regulation on the provision of food information to consumers. Our interest in this report concerns the information consumers will receive about the presence of the toxic mercury. We therefore especially welcome the submission of amendment 541 concerning labelling of the mercury content of meat from large predatory fish or foodstuffs containing meat from these fish species. The amendment would add: 'contains methylmercury- not recommended for pregnant or breastfeeding women, women who might become pregnant, and children' to be added immediately after the list of ingredients. In absence of a list of ingredients, the statement should accompany the name of the food. Mercury is highly toxic, causing damage to the human nervous system at even relatively low levels of exposure.ii Mercury travels globally throughout the atmosphere and becomes deposited in soils and water. Microbial metabolism then creates the most toxic form of mercury, methylmercury, whose damage to the human brain and nervous system is well documented. In particular, it can damage the brain of babies before birth, and children while their brains are still developing. It readily passes both the placental and the blood-brain barrier, therefore, exposures during pregnancy are of highest concern. Exposure to mercury is also linked to kidney and liver damage, and the impairment of cardiovascular, immune and reproductive systems. Methylmercury has the capacity to collect in human and animal bodies (bioaccumulate) and to concentrate up food chains (biomagnify), especially in the largest, oldest predatory fish which are at the top of the fish food chain. This is why the Commission’s Directorate-General for Health and Consumer Protection has recommended that women who are breastfeeding or who are or might become pregnant should limit their consumption of large predatory fish, such as swordfish, shark, marlin, pike and tunaiii. We therefore urge you to support amendment 541: Multiple studies demonstrate the need for better information to consumers: The Zero Mercury Working Group released in February 2009 a study “Mercury in fish, a global health hazard”, where fish were tested for their mercury content in six countries in Europe, among others,. For the EU, two clear concerns emerge – adults and children who eat greater-thanaverage amounts of fish may get excessive methymercury exposure even if the average mercury level in their fish is relatively modest, and people who prefer to eat predatory, mercuryaccumulating species can easily be exposed to excessive methylmercury doses if they eat those fish often.iv (the executive summary of the report is also available in ES, FR, PT) The EU Commission Extended Impact Assessment on Mercury noted that there is evidence of continuing exposures at or above the recommended ‘safe’ levels among some of the European population, and especially in coastal areas of Mediterranean countries and the Arctic1. Initial indications from various studies are that European exposure could be equivalent to that in the USA, where it is estimated that one in six women could bear a mercury-damaged child. A US studyv estimates that between 300,000-600,000 babies born each year suffer from intelligence loss due to methylmercury exposure, which costs an estimated 8.7 billion dollars a year in lost earnings to the economy..vi Several Member States and other countries, such as U.S., Australia and New Zealand, have already issued specific advice to vulnerable groups to limit their intake or abstain from the intake of certain species of fish with regard to methylmercury intake. This proposed amendment is in line to the EU Strategy on mercury (January 2005), which the European Parliament supported in March 2006vii. The Mercury Strategy’s key aim is to reduce mercury levels in the environment and human exposure, especially from methylmercury in fish.viii To conclude – providing health/safety information to fish consumers regarding methylmercury intake should be a priority for to help vulnerable groups make informed decisions. Targeted consumer safety labelling is an appropriate approach in this case. We would also like to note that, we support the adoption of an EU harmonised front-of-pack colour coding scheme to help people in choosing a healthy diet. This scheme would use red, amber and green coding to show high, medium or low levels of nutrients important for public health (i.e. fat, saturated fat, sugar and salt). Therefore, we welcome amendment 431 and urge you to support it. Colour coding should at a minimum be applied to processed foods whose nutritional content is the most difficult for consumers to understand (e.g. ready to eat meals, pre-packaged snacks, prepared products from animal origin). We would therefore support amendments 470 and 575. Thank you in advance for considering our recommendations (Amendments 541, 431, 470, 575) during your discussion on the amendments at the Environment Committee meeting on the 27th January 2010. For more information please contact: Elena Lymberidi-Settimo, Project coordinator ‘Zero Mercury Campaign’, European Environmental Bureau , Elena.lymberidi@eeb.org, T: +32 2 289 13 01 Lisette van Vliet, Toxics Policy Advisor, Health and Environment Alliance, Lisette@env-health.org, T: +32 2 234 3645 1 Extended Impact Assessment – Communication from the Commission to the Council and the European Parliament on Community Strategy Concerning Mercury, SEC(2005) 101, p.5 i Environmental and Health NGOS include The European Environmental Bureau, (EEB), www.eeb.org, is a federation of more than 145 environmental citizens’ organisations based in all EU Member States and most Accession Countries, as well as in a few neighbouring countries. These organisations range from local and national, to European and international. The aim of the EEB is to protect and improve the environment of Europe and to enable the citizens of Europe to play their part in achieving that goal. The Zero Mercury Working Group (ZMWG), (www.zeromercury.org) is an international coalition of more than 80 public interest environmental and health non-governmental organizations from 42 countries from around the world formed in 2005 by the European Environmental Bureau and the Mercury Policy Project. ZMWG strives for zero supply, demand, and emissions of mercury from all anthropogenic sources, with the goal of reducing mercury in the global environment to a minimum. Our mission is to advocate and support the adoption and implementation of a legally binding instrument which contains mandatory obligations to eliminate where feasible, and otherwise minimize, the global supply and trade of mercury, the global demand for mercury, anthropogenic releases of mercury to the environment, and human and wildlife exposure to mercury. The Health and Environment Alliance (HEAL) (www.env-health.org) raises awareness of how environmental protection improves people’s health, and works to strengthen European policies. We do this by creating better representation of expertise and evidence from the health community in decision making processes. HEAL a diverse network of over 60 citizens’, patients’, health professionals’, women’s and environmental groups. Our members include international and Europe-wide organisations, as well as national and local groups. ii World Health Organization (WHO), 1991, Environmental Health Criteria 118, Inorganic Mercury, WHO, Geneva. iii EFSA communication on methylmercury in fish, 2004, http://www.efsa.europa.eu/cs/BlobSe... iv http://www.zeromercury.org/Internat... v Mount Sinai study: Public health and economic consequences of Methyl Mercury Toxicity to the Developing Brain, February 28, 2005 http://ehp.niehs.nih.gov/members/20... vi US EPA http://www.epa.gov/waterscience/fis... vii http://www.europarl.europa.eu/sides... viii EU Strategy on mercury, http://eur-lex.europa.eu/LexUriServ...
22/01/2010	To: Spanish Presidency of the EU Re: Europe’s emissions reduction target to the UNFCCC Secretariat Brussels, 22 January 2010 To: Spanish Presidency of the EU Concerning: Europe’s emissions reduction target to the UNFCCC Secretariat, 31 January 2010 Protect health through ambitious EU climate change commitments Dear Mr. Zapatero As you are aware, the Copenhagen Accord requires industrialised countries to register their formal emissions reduction pledges for 2020 with the UNFCCC Secretariat by 31 January 2010. The two-leading European health organisations, Health and Environment Alliance (HEAL) and Health Care Without Harm Europe (HCWHE) are calling on you to ensure that the EU: pledges a 40% unconditional emissions reduction target by 2020 compared to 1990 levels, through domestic action commits to least 35 billion euro per year in new and additional public financing by 2020 as Europe’s fair share of total international climate financing. This funding should be used to reduce emissions and to support mitigation, adaptation, capacity building and technology co-operation in developing countries and also to strengthen and prepare the healthcare sector to cope with the effects of climate change. We are concerned that climate change is already causing hundreds of additional deaths each day around the world, and higher temperatures and more frequent extreme weather events are exacerbating some of the major causes of child mortality particularly in developing countries. Above all, the latest science suggests that a reduction in greenhouse gases by at least 40% below 1990 levels by 2020 is the minimum required to keep global warming well below the dangerous 2°C level. Studies have clearly shown how stronger targets on climate change could protect health. One European review has estimated that a 30% target on greenhouse gas emission reductions from 1990 levels by 2020 would result in health benefits of up to 76 billion Euros per year from 2020 onwards.1 Moving to a 40% domestic emissions reduction target would significantly improve people’s health in Europe, reduce rising healthcare costs and protect our fragile ecosystems. Additionally, by putting at least 40% reduction target on the table, the EU could significantly increase the chances of a breakthrough at the COP 16 in Mexico and hold true to its track record as a global leader on environmental protection and sustainable development. The health sector is committed to a fair, ambitious and binding international climate change treaty that provides for public health, drastically reduces greenhouse gas emissions, promotes alternative, renewable energy and provides significant funding for developing countries to adapt and mitigate.2 We look forward to working with you to ensure that health becomes a cornerstone of EU and international climate change policies and actions. Sincerely, Genon Jensen - Executive Director, Health and Environment Alliance (HEAL) Anja Leetz - Executive Director, Healthcare Without Harm Europe (HCWHE) 1. The co-benefits to health of a strong EU climate change policy, 2008, CAN Europe, Health and Environment Alliance, WWF http://www.env-health.org/IMG/pdf/C... september_2008.pdf See also: recent study on health co-benefits: Lancet Series report on Health and Climate Change, 25 November 2009 http://www.thelancet.com/series/hea... 2. HCHW and HEAL post-Copenhagen Position Statement: http://www.env-health.org/IMG/pdf/2... 05_Position_statement_after_Copenhagen_final.pdf
22/01/2010	To: President Barroso Re: Europe’s emissions reduction target to the UNFCCC Secretariat, 31 January 2010 Brussels, 22 January 2010 To: The President of the European Commission Concerning: Europe’s emissions reduction target to the UNFCCC Secretariat, 31 January 2010 Protect health through ambitious EU climate change commitments Dear Mr. Jose Manuel Barroso As you are aware, the Copenhagen Accord requires industrialised countries to register their formal emissions reduction pledges for 2020 with the UNFCCC Secretariat by 31 January 2010. The two-leading European health organisations, Health and Environment Alliance (HEAL) and Health Care Without Harm Europe (HCWHE) are calling on you to ensure that the EU: pledges a 40% unconditional emissions reduction target by 2020 compared to 1990 levels, through domestic action commits to least 35 billion euro per year in new and additional public financing by 2020 as Europe’s fair share of total international climate financing. This funding should be used to reduce emissions and to support mitigation, adaptation, capacity building and technology co-operation in developing countries and also to strengthen and prepare the healthcare sector to cope with the effects of climate change. We are concerned that climate change is already causing hundreds of additional deaths each day around the world, and higher temperatures and more frequent extreme weather events are exacerbating some of the major causes of child mortality particularly in developing countries. Above all, the latest science suggests that a reduction in greenhouse gases by at least 40% below 1990 levels by 2020 is the minimum required to keep global warming well below the dangerous 2°C level. Studies have clearly shown how stronger targets on climate change could protect health. One European review has estimated that a 30% target on greenhouse gas emission reductions from 1990 levels by 2020 would result in health benefits of up to 76 billion Euros per year from 2020 onwards.1 Moving to a 40% domestic emissions reduction target would significantly improve people’s health in Europe, reduce rising healthcare costs and protect our fragile ecosystems. Additionally, by putting at least 40% reduction target on the table, the EU could significantly increase the chances of a breakthrough at the COP 16 in Mexico and hold true to its track record as a global leader on environmental protection and sustainable development. The health sector is committed to a fair, ambitious and binding international climate change treaty that provides for public health, drastically reduces greenhouse gas emissions, promotes alternative, renewable energy and provides significant funding for developing countries to adapt and mitigate.2 We look forward to working with you to ensure that health becomes a cornerstone of EU and international climate change policies and actions. Sincerely, Genon Jensen - Executive Director, Health and Environment Alliance (HEAL) Anja Leetz - Executive Director, Healthcare Without Harm Europe (HCWHE) 1. The co-benefits to health of a strong EU climate change policy, 2008, CAN Europe, Health and Environment Alliance, WWF http://www.env-health.org/IMG/pdf/C... september_2008.pdf See also: recent study on health co-benefits: Lancet Series report on Health and Climate Change, 25 November 2009 http://www.thelancet.com/series/hea... 2. HCHW and HEAL post-Copenhagen Position Statement: http://www.env-health.org/IMG/pdf/2... 05_Position_statement_after_Copenhagen_final.pdf
20/01/2010	To: The European Commission Re: The Commission consultation on the Green Paper on a European Citizens’ Initiative
22/12/2009	To: ENVI Committee Re: Issue for Commission Designate Hearings - Weakening of DG Environment To: ENVI Committee Re: Issue for Commission Designate Hearings - Weakening of DG Environment Brussels, 22nd December 2009
23/11/2009	To: MEPs Re: Plenary vote on the “Motion for a Resolution on the EU strategy for the Copenhagen Conference on Climate Change (COP 15)”, 25 November Brussels, 23 November 2009 To: Members of the European Parliament Concerning: Plenary vote on the “Motion for a Resolution on the EU strategy for the Copenhagen Conference on Climate Change (COP 15)”, 25 November Bring health to the centre of climate change towards Copenhagen and beyond: What’s good for climate is good for health Dear Member of the European Parliament, While we welcome the European Parliament‟s resolution on climate change and its call for binding reduction emission targets, we would like to highlight one striking omission; a reference to tremendous impact climate change has on people‟s health, and how actions to reduce emissions will have large, immediate benefits to people‟s health in Europe. The urgent call to include health more centrally in climate negotiations is being voiced not only by the World Health Organisation, but also also by our new campaign, The Prescription for a Healthy Planet, signed by over 70 organisations globally, represents millions of health professionals in more than 120 countries following endorsements from groups such as World Federation of Public Health Associations, International Council of Nurses, and Standing Committee of European Doctors. During the international climate talks in Barcelona earlier this month, the UNFCCC negotiating draft also now explicitly recognises the need to include health protection, and amendments were considered to highlight the health benefits of strict emission targets.1 As Parliamentarians, you also can ensure that your Resolution does not lag behind what is currently being discussed at UN level on health. On Wednesday, November 25, you will have an opportunity to support the “health” amendments tabled by Greens/EFA and ALDE that will help bring health back into the climate discussions in your plenary vote on the Resolution on the EU Strategy for the Copenhagen Conference on Climate Change. We, the undersigned leading health organizations, together with some of the world‟s largest medical, nursing and health organizations are calling on world leaders and you as EU decision-makers to take bold action to address climate change. This is crucial to avoid what could become a global public health crisis. The World Health Organization (WHO) estimates that climate change is already contributing to 150,000 deaths per year.2 . Recent science3 from European respiratory doctors has shown that for every one degree Celsius increase in temperature over a city-specific heat threshold, the death rate among respiratory patients increases six-fold4. As climate change advances, a "multiplier effect" will be seen on these and other conditions. Those already the most vulnerable will suffer earliest and most. Please support amendments tabled by Greens/EFA and ALDE (see below) which bring health into climate change discussions and policy outcomes. The latest science suggests that a reduction in greenhouse gases by at least 40% below 1990 levels by 2020 is the minimum required to keep global warming well below the dangerous 2°C level. This would significantly improve people‟s health, reduce Member States' rising healthcare costs and protect our fragile ecosystems. Moreover, the co-benefits of tackling climate change will offset much of the costs according to the IPCC 4th Assessment report5. Our four, clear recommendations for the Copenhagen treaty are set out in the "Prescription for a Healthy Planet6“(see attachment). They are: the protection of public health, strong targets on emission reductions, the promotion of clean energy, and a mandate for major funding for developing countries to address the climate crisis. The “Prescription” is signed and supported by major health organizations and networks, including the International Council of Nurses (a global federation of national nursing organizations representing nurses in 128 countries), the International Society of Doctors for the Environment, the Standing Committee of European Doctors (CPME), which represents 27 medical associations in Europe, the European Respiratory Society (ERS), Climate and Health Council (CHC), Health Care Without Harm (HCWH), Health and Environment Alliance (HEAL) and many more. In the United States a parallel initiative from healthcare leaders representing hundreds of hospitals and nearly three million health professionals is calling on President Obama to support the points made in the “Prescription”. We strongly encourage you to vote in favour of the proposed amendments tabled by Greens/EFA and ALDE which would help strengthen the health aspect in your “Resolution” by ensuring better protection of public health from climate change. Sincerely, Genon K. Jensen, Health and Environment Alliance (HEAL) On behalf of: Health Care Without Harm Europe (HCWH Europe) European Respiratory Society (ERS) Climate and Health Council (CHC) International Society of Doctors for the Environment (ISDE) ÄrztInnen für eine gesunde Umwelt, AeGU (ISDE Austria) The Standing Committee of European Doctors (CPME) European Public Health Alliance (EPHA). 1. See HEAL/HCWH/Climateand Health Council Letter on Barcelona negotiations: http://www.env-health.org/IMG/pdf/H... 2. http://www.who.int/heli/risks/clima... 3. ERS Position Statement, Climate change and respiratory disease: European Respiratory Society position statement, J G Ayres et al, European Respiratory Journal 2009; 34: 295-302. http://erj.ersjournals.com/cgi/cont... (HTML), http://erj.ersjournals.com/cgi/repr... (PDF) 4. The European Respiratory Journal (ERJ), „Climate Change and Respiratory Disease: European Respiratory Society position statement‟; available at: http://erj.ersjournals.com/cgi/cont.... 5. IPCC Fourth Assessment Report – Chapter 8 – Human Health; http://www.ipcc.ch/pdf/assessment-r... 6. www.climateandhealthcare.org
04/11/2009	To: ENVI Re: ENVI Exchange of Views on Biocides Regulation To: ENVI Committee Re: ENVI Exchange of Views on Biocides Regulation Brussels, 4 November 2009 Dear Members of the ENVI Committee, In preparation of your exchange of views this afternoon on the Commission’s Proposal for the “Placing on the market and use of biocidal products”, the Health and Environment Alliance would like to present some remarks for your consideration. As an environment and health network bringing together over sixty different organisations across Europe, the Health and Environment Alliance (HEAL) welcomes the legislative initiative to improve the existing framework for the approval and use of biocides. However, we are very concerned that the current Commission proposal compromises the goal of ensuring a high level of protection for human health and the environment. We therefore urge you to strengthen the Commission’s proposal towards better protection of human health and the environment by considering our recommendations below. There is increasing scientific evidence pointing to the detrimental health effects of chemicals, including biocides. Because biocides are intended to kill living organisms, many biocidal products pose significant risk to human health. The use of biocides can also have significant adverse effects on the natural environment. The European Union has just passed the so-called pesticide package, with crucial new rules to phase out the most problematic pesticides, including those which play a role in the cancer pandemic and growing fertility problems. The proposal for the Biocides regulation must ensure coherence with the Pesticide legislation, and must not fall behind the important provisions for the protection of human health which have been agreed on. Better policy coherence is also needed with other EU environmental legislation (for example Water Policy) and the EU Action Plan on Environment and Health to ensure that the new biocides legislation also contributes to the overarching goal of reducing the environmental burden of disease. HEAL calls on you to ensure the following: -* Better health protection, precautionary principle Many biocides are substances which can have harmful effects on human health and the environment. All decisions on the approval of such hazardous substances should therefore be based on the precautionary principle, in order to ensure there are no adverse effects on health and environment. Furthermore, the regulation should state as leading principle better health and environment protection. Both precautionary principle and better protection should explicitly be included in the subject matter of the regulation (article 1). -* Protect vulnerable groups Pregnant women or children are especially vulnerable to harmful effects of biocides. Their needs and specific situation have to be considered when assessing and authorizing biocides. Therefore, the regulation should make explicit reference to vulnerable groups (for example in risk assessment). -* Comprehensive cut-off criteria, no derogations We welcome the cut-off approach for certain hazardous substances, which mirrors the approach of the pesticide regulation and is in line with the precautionary principle. These proposed exclusion criteria should be further strengthened to reflect the advances made in the pesticides regulation. We fear that the suggested derogations compromise the goal of better health protection, creating loopholes for leaving hazardous substances on the market. We therefore urge you to support strict and stringent cut-off criteria. -* Clear provisions for nanomaterials in biocides In a growing number of biocidal products and applications, nano silver is being used because of its disinfectant qualities. Nano silver can now be found in washing machines, wound dressings and many other consumer and hospital products. These products are on the European market, despite scientific uncertainties about their risks for human health and the environment. The biocides regulation should specifically address nanomaterials, as being called for in a recent European Parliament resolution (P6_TA(2009)0328). Thus, specific provisions for nanomaterials should be included to ensure adequate safety evaluation, but also clear labeling rules. Please do not hesitate to contact me should you have any questions, Yours faithfully, Anne, Anne Stauffer, Policy Manager Health & Environment Alliance (HEAL), 28 Boulevard Charlemagne, B-1000 Brussels
20/10/2009	To: EU Environment Ministers Re: Input to Environment Council meeting 21 October Council conclusions on the Preparation of the EU Position for COP 15 Brussels, 20 October 2009 To: EU Environment Ministers Concerning: Input to Environment Council meeting 21 October Council conclusions on the Preparation of the EU Position for COP 15 Dear Minister, The two leading health organisations, Health and Environment Alliance (HEAL) and Health Care Without Harm (HCWH) Europe, would like to stress the critical nature of your Environment Council meeting on 21 October as an occasion in which we would like you to strengthen the EU’s position in the negotiations towards a global climate agreement in Copenhagen. Climate change will affect our individual health, public health and health care systems in the EU and globally. The latest science suggests that a reduction in greenhouse gases by at least 40% below 1990 levels by 2020 is the minimum required to keep global warming well below the dangerous 2°C level. In light of recent evidence showing that the earth is warming at an even faster pace than previously predicted, we find the current EU emissions reduction targets to be inadequate. Therefore, HEAL and HCWH Europe joins European NGOs1 in asking the EU to: Commit to an emissions reduction target of more than 40% below 1990 levels by 2020, in line with the most recent science. Major public health benefits and health care savings, such as reduced respiratory illnesses, can be achieved if the EU maintains its commitment to at least 30% or more greenhouse gas reductions domestically by 2020 from 1990 emission levels. Moreover, with a 30% target the EU could reap health savings of up to 25 billion euros every year from the domestic emissions reductions. Commit to at least 35 billion euro per year in new and additional public financing by 2020 as Europe’s fair share of total international financing. This funding should be used to reduce emissions and to support mitigation, adaptation, capacity building and technology co- operation in developing countries and also to strengthen and prepare the healthcare sector to cope with the effects of climate change. This financing should be predictable, timely and ensured through appropriate legally binding mechanisms agreed under the UNFCCC. We call on you to make sure that the EU maintains its leadership role in international climate discussions and establish emissions reduction targets that are in line with its climate objective of keeping global warming well below the dangerous 2°C level. We look forward to working with you to ensure that health becomes a cornerstone of international and EU climate change policy. Sincerely, Genon Jensen - Executive Director, Health and Environment Alliance (HEAL) Anja Leetz - Executive Director, Healthcare Without Harm Europe (HCWHE) 1. This letter was prepared with contribution from Climate Action Network Europe.
14/10/2009	To: ENVI Committee Re: Proposals for amendment of the “European Parliament Resolution on the EU strategy for the Copenhagen Conference on Climate Change (COP 15) Brussels, 14 October 2009 To: Members of the European Parliament Committee on Environment, Public Health and Food Safety (ENVI Committee) Concerning: Proposals for amendment of the “European Parliament Resolution on the EU strategy for the Copenhagen Conference on Climate Change (COP 15)” ENVI Vote on 19 October on Copenhagen Climate Conference: Bring health to the centre of climate change towards Copenhagen and beyond Dear Member of the European Parliament, During the forthcoming ENVI Committee meeting on 19 October you will vote on the Draft Resolution and amendments to the “European Resolution on the EU strategy for the Copenhagen Conference on Climate Change (COP 15)”. As the leading representatives of European-wide health, medical and healthcare networks, we welcome the Draft Resolution from the European Parliament and would like to ask you to strengthen it to adequately recognize the health dimensions of climate change1. Please support amendments 19, 40, 67 and 100, which bring health into climate change discussions and policy development. Climate change will affect our individual health, public health and health care systems in the EU and globally. Health represents the point of convergence of all the disruptions and damages caused by climate change, both the direct ones, for example respiratory disease, and indirect ones, for example from water shortage and population movement. For instance, for every one degree Celsius rise in temperature, the risk of premature death among respiratory patients is up to six times higher than in the rest of the population2. Yet in the current policy developments on climate change, there is not enough awareness of the negative impacts on health or of the potential benefits to health of strong measures of tackling climate change. Estimated savings on health costs in the EU from an increase to 30% domestic greenhouse gas reductions compared to 1990 emission levels by 2020, could be as high as 25 billion Euros per year from 2020 onwards3. Moreover, the health sector will need to be at the forefront in responding to the effects of climate change, and developing adaptation measures which do not add further to the climate problem. Increased awareness and resources are needed to ensure this happens as recently highlighted in the WHO/HCWH discussion paper: ‘Healthy Hospitals, Healthy Planet, Healthy People: Addressing climate change in healthcare settings4’. Therefore, the health and medical community urge you to vote in favour of the proposed amendments 19, 40, 67 and 100 (see Annex I, below) which would help strengthen the health aspect in your Draft Resolution by ensuring better protection of public health from climate change and support the healthcare sector fin adaption and mitigation actions. We look forward to working with you to ensure that health becomes a cornerstone of international and EU climate change policy. Sincerely, Genon K. Jensen, Health and Environment Alliance (HEAL) On behalf of: Health Care Without Harm Europe (HCWH Europe) European Respiratory Society (ERS) Climate and Health Council (CHC) AerztInnen fuer eine gesunde Umwelt, AeGU (ISDE) Austria The Standing Committee of European Doctors (CPME).
06/07/2009	To: President Barroso Re: Unacceptable move on Euro VI air pollution standards heavy goods vehicles July 2009 To: President Barroso Re: Unacceptable move on Euro VI air pollution standards heavy goods vehicles Dear President Barroso, At a meeting of the Commission’s Motor Vehicle Working Group on 6 July, an official document* was circulated stating that Vice President Verheugen has asked the services of DG Enterprise to prepare a proposal to delay introduction of the above standards that were legally adopted by the EU as recently as the Council meeting of 8-9 June. That would be an unprecedented and deeply damaging move. To our knowledge, no European Commission has ever proposed to postpone an environmental law that has been already agreed under the co-decision process. Such a move would severely damage the standing and credibility of the European Commission. Specifically, such a proposal would be damaging for the following reasons: Air pollution from lorries causes some 40,000 deaths a year. A further delay to this legislation would result in significant numbers of unnecessary deaths and illnesses; Euro standards are one of the few ways the EU can directly regulate air pollution, a delay would make it harder for national and local authorities to reach urban air pollution targets set at EU level. Recently the Commission rejected the majority of requests from Member States for derogations from air quality limits. A delay to Euro VI standards would obviously provoke an outcry from the Member States affected; The health impacts would be felt worldwide, as most other regions follow Euro standards within a few years; It would punish the forerunners, those manufacturers and suppliers who have already invested in the technology needed to meet these standards by the current deadline; if the proposal moves forward it would also create a huge amount of uncertainty in the industry; Europe is already several years behind the United States on introduction of tighter air pollution standards for lorries, this step would lead to Europe further lagging the US in a key area of environmental policy. For these reasons we urge you to prevent this unprecedented and damaging move from DG Enterprise from ever becoming an official Commission proposal. Yours sincerely, Jos Dings, Director, European Federation for Transport and Environment (T&E) Also on behalf of: European Environmental Bureau (EEB) Health and Environment Alliance (HEAL) * Work Programme on car legislation 2009 (2nd semester), Proposals under the responsibility of DG Enterprise & Industry
02/07/2009	To: UNFCCC National focal points Re: Input to Intersessional informal consultations on climate change, 10 – 14 August Brussels, 2 July 2009 To: European Region National Focal Points for the United Nations Framework Convention on Climate Change (UNFCCC) Concerning: Input to Intersessional informal consultations on climate change, 10 – 14 August Put health in the centre of climate change work towards Copenhagen and beyond Dear Madam/Sir, Climate change is affecting our individual and public health and healthcare systems in EU and globally. Already stretched healthcare resources are going to become even further extended as more people are made ill by climate change. If society is already struggling to finance current healthcare needs, we will certainly have serious difficulties when we start needing more healthcare - especially as the vulnerable, aging proportion of the population increases in size. Healthcare systems will have to deal with the consequences. Yet in the current discussions on climate change, there is not enough representation from those with expertise or a vital stake in the health impacts of strong measures tackling climate change. You have the opportunity to change this and bring health to the centre of international and national climate change discussions and outcomes for and beyond Copenhagen. We therefore urge you to: 1. Advocate for strong reductions in greenhouse gas emissions Strive for an ambitious, fair and effective international agreement at the United Nations Framework Convention on Climate Change (UNFCCC) meeting in Copenhagen in December 2009. Major public health benefits and healthcare savings, such as reduced respiratory illnesses, can be achieved if the EU maintains its leadership the negotiations and its commitment to at least 30% or more greenhouse gas reductions by 2020 from 1990 emission levels. Please see Annex I for more information. 2. Promote equitable funding mechanisms and support for climate change mitigation and adaptation Ensure that the Europe is committed to fighting climate change in the EU and externally by securing accessible, predictable, binding funding mechanisms, in addition to Overseas Development Assistance. These funding mechanisms should include i) reducing the health sector’s greenhouse gas emissions ii) supporting programmes that protect public health from climate change-related threats iii) assisting the most affected and vulnerable communities around the world fight and cope with climate change. The health sector is already working to reduce its carbon footprint. Our recently released joint-WHO discussion report provides case studies of what some hospitals are already doing. Please see Annex II for more information. We look forward to working with you to ensure that health becomes a cornerstone of international and EU climate change policy. Sincerely, Genon Jensen - Executive Director, Health and Environment Alliance (HEAL) Anja Leetz - Executive Director, Healthcare Without Harm Europe (HCWH E) Contact: Pendo Maro PhD, Joint Senior Climate Change and Energy Advisor, Health and Environment Alliance (HEAL) and Health Care Without Harm Europe (HCWHE), 28 Boulevard Charlemagne, 1000-Brussels, Belgium. Tel: +32 2 234 4647. E-mail: pendo@env-health.org Health Care Without Harm is a global network of more than 480 organisations in more than 50 countries, working to transform the health care sector so it is no longer a source of harm to people and the environment. Website: www.noharm.org The Health and Environment Alliance aims to raise awareness of how environmental protection improves health. It brings together more than 60 organisations working at the European level. Website: www.envhealth. org Annexes -* Annex I If the European Union increased its target greenhouse gas emission reductions from the present 20% to 30%, the total savings from death and ill-health due to respiratory conditions alone could reach an additional 25 billion Euros per year by 2020. Fewer emissions result in cleaner air, fewer premature deaths among people with existing respiratory problems, 5,300 fewer cases of bronchitis, and 2,800 fewer hospital admissions each year. See report from HEAL, CAN Europe and WWF entitled “The co-benefits to health of a strong EU climate change policy". Please find enclosed a short summary of this report. The full report is available here: http://www.env-health.org/IMG/pdf/Co- benefits_to_health_report_- september_2008.pdf. -* Annex II Funding for health projects is very low. In April 2009, Dr Roberto Bertollini, Senior Advisor and Coordinator, Public Health and Environment Department, World Health Organization told a meeting of health and environment ministers from 53 European countries that although 32 of the world's 38 poorest countries identified health in their national action plans on climate change, funding for health has received only less than 1% of allocations under the climate change framework. "Climate Change and Health: The Global Perspective" presentation by Dr Roberto Bertollini, Senior Advisor and Coordinator, Public Health and Environment Department, World Health Organization, Geneva (copy available on request from Diana Smith, Diana@gsmith.com.fr or +33 6 33 04 2943). The health sector is already working to reduce its carbon footprint. A recently released WHO-HCWH-HEAL report provides case studies of what hospitals are doing. The report: "Healthy Hospitals, Healthy Planet, Healthy People: Addressing climate change in health care settings", Discussion Draft is available at www.noharm.org or http://env-health.org/a/3351. Please find copy attached. -* Annex III Please find attached: European Lung Foundation’s Climate and Lung health fact sheet
06/06/2009	To: President Barroso Re: Improving health representation in climate change discussions and outcomes To: Commission President, Mr. Jose Manuel Barroso Commissioner for Environment, Mr. Stavros Dimas Commissioner for Health, Ms. Androulla Vassiliou cc: Ministers of Health of Member States of the European Union RE: Improving health representation in climate change discussions and outcomes Call for EU Health delegation at climate change talks Dear Commissioners, The coming days are crucial to the preparations for the United Nations Framework Convention on Climate Change (UNFCCC) meeting in Copenhagen in December 2009. We call on you to ensure a high-level delegation of EU Health Ministers and officials take part in the preparatory meetings and in Copenhagen. Human health is already being seriously affected by climate change. Global warming causes 300,000 deaths per year and increasingly severe heatwaves, floods, storms and forest fires could increase the annual death toll to 500,000 by 2030, according to a report published by the Global Humanitarian Forum, the think tank of former UN secretary general Kofi Annan in May 2009.1 Yet, the health benefits of tackling climate change are numerous. For example, our recently co-published report2 shows that if the European Union increased its target on greenhouse gas emission reductions from the present 20% to 30% then the total savings from health ‘co-benefits’ could reach an additional 25 billion Euros per year by 2020. These savings are due to cleaner air that would mean fewer premature deaths among people with existing respiratory problems, 5,300 fewer cases of bronchitis, and 2,800 fewer hospital admissions each year. It is essential that the health sector has a fair chance to bring attention to serious human health concerns and to focus policy solutions on measures that would bring the most benefits to human health and society at large. The health sector is already taking measures to address its climate footprint while simultaneously promoting health. In a recent document3 co-produced by the World Health Organisation (WHO), we also call on the United Nations Climate Change Conference in Copenhagen in December 2009 to specifically promote and facilitate climate change mitigation by the health sector. Prioritising primary health care and pursuing disease prevention strategies, in order to lower dependence on resource-intensive therapies, can simultaneously reduce the burden of disease and the health sector's fossil fuel consumption. We look forward to working with you to ensure that health becomes a cornerstone of international and EU climate change policy. Sincerely, Genon Jensen - Executive Director, Health and Environment Alliance (HEAL) Anja Leetz - Executive Director, Healthcare Without Harm Europe (HCWH E) Contact: Pendo Maro PhD, Joint Senior Climate Change and Energy Advisor, Health and Environment Alliance (HEAL) and Health Care Without Harm (HCWH), 28 Boulevard Charlemayne, 1000-Brussels, Belgium. Tel: +32 2 234 4647. E-mail: pendo@env-health.org Health Care Without Harm is a global network of more than 440 organizations in 52 countries working to transform the health care sector so it is no longer a source of harm to people and the environment. The Health and Environment Alliance aims to raise awareness of how environmental protection improves health. It brings together more than 60 organizations working at the European level. Website: www.env-health.org
02/04/2009	To: Minister of Health for France Re: Response to statement about BPA Bruxelles, Annemasse, le 2 Avril 2009 Lettre ouverte à Madame Roselyne Bachelot Madame la Ministre de la Santé, C’est au nom d’organisations de protection des consommateurs, de l’environnement et de la santé que nous souhaitons réagir à votre déclaration du 31 mars 2009 devant les députés français au sujet du Bisphénol A (BPA). Vous avez affirmé que « les autorités canadiennes ont décidé l’interdiction du BPA sous la pression de l’opinion publique et sur la base d’aucune étude scientifique sérieuse ». Permettez-nous d’attirer votre attention sur le fait que la procédure d’évaluation de cette substance par les autorités canadiennes a été conduite selon les règles de la Loi canadienne sur la protection de l’environnement (Canadian Environmental Protection Act, 1999) qui prévoit que les substances classées sur la liste des « substances prioritaires » fassent l’objet d’une évaluation des risques basée sur des analyses scientifiques. Le Bisphénol A faisait partie de cette liste car il a été classé comme « toxique pour la reproduction » par toutes les agences internationales, Union Européenne comprise (catégorie 3), et d’autre part parce que l’ensemble de la population y est exposé. Cette évaluation conduite sous l’égide de votre homologue canadien, Santé Canada, et du Ministère de l’Environnement a duré plusieurs années et a passé en revue l’ensemble des données scientifiques internationales disponibles sur le Bisphénol A. Les conclusions qui ont conduit à classer le BPA le 18 octobre 2008, parmi la liste des « substances toxiques » et à en interdire la présence dans les biberons, dans un premier temps, sont les suivantes : « Le bisphénol A pénètre ou peut pénétrer dans l’environnement dans des quantités ou des concentrations telles qu’il peut avoir des effets dommageables immédiats ou à long terme sur l’environnement et la biodiversité » et enfin que « le Bisphénol A constitue et peut constituer un danger pour la vie ou la santé humaine ». Selon tous les scénarios des autorités sanitaires internationales - dont l’Autorité européenne de sécurité des aliments (AESA) que vous évoquez, mais aussi le National Program of Toxicology, Etats-Unis, les populations les plus exposées au BPA sont les jeunes enfants, de la conception au 18ème mois. Chacun s’accorde sur ce point. Le rapport de Santé Canada, comme celui du National Program of Toxicology (Etats-Unis) ont tous deux classé au rang des préoccupations majeures les altérations du développement, en particulier ceux du développement neurologique et du comportement chez les plus jeunes, à des niveaux d’exposition courants. C’est en effet à cette période clé que les effets dommageables sont les plus graves. C’est pourquoi Santé Canada a jugé dans une approche de précaution fondée sur des études sérieuses, que les doses journalières autorisées (DJA) -pourtant de moitié inférieures à celles de l’Union européenne- « ne permettent pas d’assurer la protection des populations les plus à risque : femmes enceintes, foetus, nourrissons et jeunes enfants ». En Norvège, le Bisphénol A a été interdit dans les produits cosmétiques le 10 juillet 2008, et une recommandation d’interdiction dans les produits de consommations courante a été publiée par le « Norwegian State Pollution Control Authority (SFT). Nous rappelons enfin que les députés européens Hanne Dahl, Christel Schaldemose, Hélène Goudin et Carl Schlyter ont déposé le 15 décembre 2008 devant le Parlement Européen une déclaration écrite visant à faire interdire le BPA dans la fabrication des biberons en Europe. Le principe de précaution est un principe scientifique et rationnel, basé sur la science des systèmes complexes, selon lequel « en cas de risque de dommages graves ou irréversibles, l’absence de certitude scientifique absolue ne doit pas servir de prétexte pour remettre à plus tard l’adoption de mesures effectives visant à prévenir la dégradation de l’environnement » (définition de l’Agence Européenne de l’Environnement). La jurisprudence a étendu ce principe au domaine de la santé. Considérant les enjeux de la contamination des populations par le BPA, et son effet potentiel sur la santé publique, attesté par de nombreuses études concordantes, nous pensons être dans un cas où le principe de précaution doit s’appliquer. A la lumière de ces éléments nous vous demandons instamment que la France reconsidère sa position vis-à-vis du Bisphénol A afin de protéger la santé des générations présentes et à venir. Signataires : WECF- Women in Europe for a Common Future HEAL - Health and Environment Alliance EEB - European Environment Bureau Lettre soutenue par l’Association française SERA: Santé Environnement Rhône Alpes Contacts: Anne Barre Présidente WECF France anne.barre@wecf.eu téléphone: 04 50 49 97 38 portable: 06 12 90 37 21 Lisette van Vliet, Ph.D. Toxics Policy Advisor Health & Environment Alliance lisette@ env-health.org téléphone: +32 (0)2 234 3645 portable: +32 (0)484 614 528
23/09/2008	To: European Commission Re: Commission review of the availability of safer alternatives to Measuring Devices containing mercury
03/07/2008	To: Energy & Environment Ministers Re: Turning EU Effort Sharing Proposal into EU Benefit Sharing Agreement “Climate Action and Renewable Energy Package” Turning EU Effort Sharing Proposal into EU Benefit Sharing Agreement “Climate Action and Renewable Energy Package” 3rd July 2008, Council Meeting, Paris Dear EU Energy and Environment Minister, As you meet tomorrow, we would like you to consider reframing the current debate on Effort Sharing into one on Benefit Sharing. This will help create political acceptance for greater ambition levels and ensure that the EU abides by the principles of better regulation in considering both costs and benefits to it decisions. The Health and Environment Alliance (HEAL), a broad coalition of health professionals, environmental health and patient groups throughout Europe, urges you to ensure the highest possible level of health protection for EU citizen’s by supporting an ambitious Climate Action and Renewable Energy Package that exploits the important co-benefits to health of domestic climate change mitigation policies. The proposed Effort Sharing emission reduction target of the EU’s Climate Action and Renewable Energy Package is in violation of the COP13 Bali agreement for developed countries to reduce emissions by 25 - 40 per cent by 2020, a yardstick for staying below 2 degree global warming. To keep mean temperature rise below 2 degree and avoid a public health crisis, HEAL and its members call for: 1. A minimum domestic EU 30% cut in collective emissions from developed countries by 2020 to stop global warming before it reaches dangerous levels. The current proposal from the Commission equates to about a 10% domestic reduction target below 2005 (20% overall reduction target below 1990). 2. External credits from schemes such as the Kyoto Protocol’s Clean Development Mechanism (CDM) need to meet strict additional environment and health criteria, and should be in addition to an EU-wide 30% emission reduction. The EU must recognize the important co-benefits to health of domestic cuts and must therefore not "outsource" its emission reductions and associated co-benefits. 3. Co-benefits to health of reducing CO2, NOx, Particulate Matter and SOx need to be considered more prominently throughout the climate and energy package. Such co-benefits include improved local air quality, reduced noise, traffic pollution and accidents. The current 20, 20, 2020 EU’s Climate Action and Renewable Energy Package assessment estimates that the health benefits just for Particulate Matter (10ug/m3) alone would amount to a substantial €550Billion to €1350Billion per year. However, the modeling of energy scenarios or associated health benefits has NOT been considered in relation to different levels of ambition. This one-dimensional “coherent scenario” does not allow a flexible analysis of degrees of ambition as highlighted by an amendment voted in the European Parliament Committee on Environment and Public Health and Food Safety: “13a. Regrets that the current cost benefit impact assessment of the '20 20 by 2020 Europe’s Climate Change Opportunity'1 only considers the health benefits of reduced air pollution at a 20% reduction of greenhouse gas emissions by 2020; calls on the Commission to ensure that the (ancillary) co-benefits to health of various levels of ambition, in line with the International Panel on Climate Change recommendations of domestic 25% to 40% as well as possibly 50% or more of greenhouse gas emission reduction by 2020, are urgently investigated and modelled into an impact assessment by the Commission;” 1 COM(2008)0030. [Frédérique Ries (PE404.442v01-00) Mid-term review of the European Environment and Health Action Plan 2004-2010 (2007/2252(INI)] In this regard we recommend to Ministers and other decision makers, in addition to a 30% level of ambition, a flexible solution to allow no-regrets actions and policies up and above agreed targets, which is being promoted by Member of European Parliament Mr John Bowis (EPP-ED, UK). Proposed Amendment: Recital (8a)new “Member States may justify unrestricted levels of domestic greenhouse gas emissions reduction up and above their greenhouse gas emission limits, based on no-regrets actions and policies that have co-benefits. In this regard primacy should be given to the co-benefits to public health (partcicularly related to air quality) and improved safety, ecosystem preservation and biodiversity, poverty reduction and employment, and energy security.” Amendment justification: “The IPCC working group III on mitigation clearly indicates that the co-benefits of action in the form of reduced air pollution, more energy security or more rural employment offset mitigation costs. There is a general consensus for all world regions analyzed that near-term health and other benefits from GHG reductions can be substantial, both in industrialised and developing countries. Such near-term co-benefits of GHG control provide the opportunity for a true no-regrets GHG reduction policy in which substantial advantages accrue even if the impact of human-induced climate change itself turns out to be less than that indicated by current projections.” We attach a summary of the current macroeconomic understanding by Dr. Terry Barker, University of Cambridge and Cambridge Econometrics and IPCC author which shows that climate change mitigation efforts don’t necessarily reduce GDP. Indeed Dr. Barker indicates that: “There seems to be an impression that mitigation automatically incurs macroeconomic costs. This is not the case from the literature. e.g. see attached quote from IPCC AR4 SPM agreed by ALL governments in Bangkok, 2007.” Of course, as public health advocates we must highlight that many of these studies do not include health and other societal co-benefits. To fight climate change the international community will require not flexibility but global leadership from the EU. As it currently stands, the current EU’s Climate Action and Renewable Energy Package and underlying economic modeling and scenarios display pessimism on the outcome of international climate negotiations. It demonstrates to the world a lack of ambition in the EU’s level of commitment to the global effort to combat change and the unfounded assumption that EU citizens do not value healthy environments, a healthy society and indeed the health of their children, particularly in light of the significance of climate change endangering human health and well-being. Yours sincerely, Genon Jensen, Executive Director, Health and Environment Alliance (HEAL)
05/06/2008	To: EU Environment Ministers Re: Effort Sharing Proposal of the “Climate Action and Renewable Energy Package” 5th June 2008 Council Meeting Dear EU
31/03/2008	To: EU Environment Ministers Re: Supporting a broad export ban and safe storage of mercury
18/12/2007	To: EU Environment & Health Ministers Re: Council Conclusions on the Mid Term Review of the EU Environment and Health Action Plan 2004-2010
25/05/2007	To: Commissioners Dimas & Verheugen Re: Ensure REACH is not vulnerable to weakening in future
22/05/2007	To: European Commission Re: Consultation regarding the Review of RoHS Directive 2002/95/EC
24/04/2007	To: EU Members States’ experts Re: Calling for a wide mercury export ban and safe temporary storage of surplus mercury
05/04/2007	To: ITRE Committee Re: Better protection of vulnerable groups, in particular children, is needed against the hazardous health effects of pesticides
05/04/2007	To: IMCO Committee Re: Better protection of vulnerable groups, in particular children, is needed against the hazardous health effects of pesticides
05/04/2007	To: AGRI Committee Re: Better protection of vulnerable groups, in particular children, is needed against the hazardous health effects of pesticides
26/03/2007	To: MEPs RE: Ulmer Report on the Medical Devices Directive (93/42/EEC)
16/02/2007	To: EU Environment Ministers Re: Thematic Strategy on the Sustainable Use of Pesticides (COM(2006)372)
31/01/2007	To: MEPs Re: Calling for a robust mercury export ban and safe surplus storage regulation
12/12/2006	To: MEPs Re: Ensure the strength of REACH in the EP plenary vote
13/11/2006	To: MEPs Re: Support the compromise amendments, eliminate mercury from consumer mersuring devices
31/10/2006	To: Lidl Supermarket Re: Pesticides reduction standards in all Lidl countries
11/10/2006	To: EU Environment & Health Ministers Re: EU air quality standards
09/10/2006	To: ENVI Committee Re: Protect children’s health with REACH
19/09/2006	To: Ministers of Agriculture, Environment & Health Re: Call to reject EU authorisation of 6 unacceptable pesticides
21/06/2006	To: ENVI Committee Re: Call for defending existing health standards on airpollution (Krahmer report)
19/06/2006	To: Commissioner Dimas Re: Concerns about the current status and future challenges in implementing the EU Action Plan on Environment and Health
23/05/2006	To: Jose Barroso, President of the European Commission Re: Midterm review of the 2001 Common Transport Policy white paper
24/04/2006	To: ECOFIN Re: Council debate on the EU’s Sustainable Development Strategy, 5 May
16/03/2006	To: MEPs Corbey and Krahmer EU thematic stategy on air quality and ambient air quality legislation
13/03/2006	To: ENVI Committee Re: Better protection of vulnerable groups, in particular children, is needed against the health effects of pesticides
16/02/2006	To: Ministers of Environment, Agriculture & Consumers Re: Rejection of authorisation of 8 unacceptable pesticides under Council Directive 91/414/EEC
07/02/2006	To: ENVI Committee Re: Matsakis Mercury Report
02/01/2006	To: MEPs Re: Plenary Vote, Second Reading on Report-KORHOLA on Aarhus Convention and EU Institutions, EP January session
16/11/2005	To: ENVI Committee Re: Vote on Report-KORHOLA on Aarhus Convention and EU Institutions, next week.
22/09/2005	To: EU Commissioners Re: Commission communication ‘Reducing the climate change impact of aviation’
14/07/2005	To: EU Health Ministers Re: Brominated Flame Retardants: Rising Levels of Concern
12/07/2005	To: EU Commissioners Re: Thematic Environmental Strategies
30/06/2005	To: Jose Barroso, President of the European Commission Re: Thematic strategy on air quality
24/06/2005	To: EU Environment Ministers Re: Council discussion on DECA-BDE exemption
06/06/2005	To: Environment & Health Ministers Re: WHO Budapest conference - Our future and our children’s future needs you
26/05/2005	To: EU Environment Ministers Re: Council conclusions for action towards phasing out releases and uses of mercury

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