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HERA Workshop TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday Products REACH and GHS – Clarity or Confusion? HERA has achieved real progress, both in anticipation of REACH and during the evolution of the REACH legislation.

TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

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Page 1: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA Workshop TALKING ABOUT CHEMICALS WITH

CONSUMERSFrom Chemicals to Everyday ProductsREACH and GHS – Clarity or Confusion?

HERA has achieved real progress, both in anticipation of REACH and during the evolution of

the REACH legislation.

Page 2: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

•worked out how to form consortia with due regard to commercial sensitivities;

•worked out risk assessment procedures feeding off the detailed knowledge on intrinsic properties of a chemical (typically the province of the Supplier) and detailed knowledge of human and environmental exposure (typically the province of the DownstreamUser of the chemical – the Formulator);

•delivered risk assessments on a wide variety of chemicals used in products found in every home in the EU;

• REALISED THE CRUCIAL IMPORTANCE OF PROPER COMMUNICATION WITH THE EUROPEAN CONSUMER AND PROMOTED DISCUSSION ON THIS VITAL ISSUE.

HERA has

Page 3: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Consumer ConfidenceInformation: physical barrier

LABEL SIZEWON’T CHANGE!

Time

Availableinformation

NOW

UNDER REACH

What to do with allthe new information?

-New info is:

-Cost or Investment?-Burden or Engine?-Database or Asset?

-How to make use of it?

-Rules on labelling-Information selection-Alternative tools

5cm

8cm

Edit Herczog, MEP

Page 4: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

TRANSPARENCY

CONFIDENTIALITY

Business Paradigme in Change

COMPETITIONamoung companies

COMSUMERCHOICE

Consumer right to knowConsumer right to accessConsumer confidence

Industry’s RONIIndustry’s competitiveness

Industry’s IPR

Edit Herczog, MEP

Page 5: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

TRANSPARENCY

CONFIDENTIALITY

Business Paradigme in Change

Strategic Partnership

Competition forCOMSUMER CHOICE

Consumer right to knowConsumer right to accessConsumer confidence

Industry’s RONIIndustry’s competitiveness

Industry’s IPR

Edit Herczog, MEP

Page 6: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

WorkabilityInfo generation and flow: Who does what?

IndustrySupply chain:

Consumers

NGOs

Authorities

UP

DOWN

Helsinki NationalAUTHORITY CHANNEL

BUSINESS-CONSUMER CHANNEL

REGISTRATION

EVALUATION

AUTHORISATION

Consumer confidenceBU

SIN

ESS

CH

AN

NEL

BUSINESS-A

UTHO-

RITY C

HANNEL CON

SUM

ER-AU

THO

-

RITY CH

ANN

EL

Marketing

CommunicationTARGET

Page 7: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Chemical Industry Titanic

ProductsEuropeanchemicals

market

Productioncosts

Legislativecosts

Globalcompetitive

pressure

What REACH implies

Page 8: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

BE CAUTIOUS: Be sure you are provided with lifeboats!(workable procedures, effective authorities)

Chemical Industry Titanic

ProductsEuropeanchemicals

market

Productioncosts

Legislativecosts

Globalcompetitive

pressure

What REACH implies

Page 9: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

LEARN: Be prepared and watch out!(get information from authorities, SIEFs, partners)ADAPT: Get rid of burdensome cargo to float higher!(elimination of risky and uncompetitive substances)

BE CAUTIOUS: Be sure you are provided with lifeboats!(workable procedures, effective authorities)

Chemical Industry Titanic

ProductsEuropeanchemicals

market

Productioncosts

Legislativecosts

Globalcompetitive

pressure

What REACH implies

Page 10: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

LEARN: Be prepared and watch out!(get information from authorities, SIEFs, partners)ADAPT: Get rid of burdensome cargo to float higher!(elimination of risky and uncompetitive substances)

BE CAUTIOUS: Be sure you are provided with lifeboats!(workable procedures, effective authorities)

Chemical Industry Titanic

ProductsEuropeanchemicals

market

Productioncosts

Legislativecosts

Globalcompetitive

pressure

What REACH implies

Page 11: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

•to build understanding of stakeholder views on REACH and GHS

•and the need to take this opportunity to maximise the value of the two interlinked systems.

•We look to the Workshop to identify areas for development of ideas,

•(items which need to be taken into account in the legislative development)

and to take all the material generated to draft some direction for the wider debate.

This Fifth HERA Workshop gives us the chance

Page 12: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

The Workshop needs

• to demonstrate the different systems, their advantages and disadvantages,

(Legislative users and other stakeholders need to be conscious of these matters, if confidence in chemicals is to become a reality and public health and environmental safety are to be objectively assured.)

•It should provide industry and consumers (with the interest groups of both)

• the opportunity to convince themselves of the value of the correct assessment of chemicals and the communication of safety in use.

Page 13: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

I wish you a most fruitful and successful conference.

Page 14: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

REACH and GHS implementation

Anna-Liisa SundquistPermanent Representation of Finland to

the [email protected]

Page 15: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA210606 / 2

GHS - international contextMain principles of development of GHS• developed on the basis of existing systems• no reduction of level of protection of any existing systems• covers all main sectors of uses• a hazard based system

– classification of substances and mixtures based on hazard data for different hazard end points

– communication of information based on hazard classification by labels (+SDS’s)

• optionality – building blocks (BB) - harmonized elements of the GHS system

available for implementation according to the needs - NO CHANGES ALLOWED IN THE CONTENTS OF HARMONIZED ELEMENTS

– CA - options - for countries/regions to decide which of the unharmonized options to choose for implementation

GHS resembles closely to the present EU C&L system -some differences in details

Page 16: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA210606 / 3

CA-option: GHS Document Annex 5 Consumer product labelling based on likelihood of injury (1)

• included in GHS to satisfy the USA providing them the opportunity to continue with the present practice - the EU fighted unanimously against

• refers to the basic principle of assessment of intrinsic properties (hazard), however

– some systems provide information on chronic hazards in consumer products only after considering exposure of consumers under normal use conditions or foreseeable misuse conditions - risk assessment (RA)

– if RA shows that potential for harm insignificant, chronic health hazards may not be included on the label for consumer use

• GHS has not addressed harmonization of this type of approach - harmonized rules of RA missing

Page 17: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA210606 / 4

CA-option: GHS Document Annex 5 Consumer product labelling based on likelihood of injury (2)

No harmonized approach in GHSCertain general principles• classification always based on GHS criteria• risk based labelling only by CA’s to chronic health

hazards in consumer products - acute health, environmental, physical hazards labelled on the basis of intrinsic hazards

• estimates of possible exposures and risks to consumers based on conservative/protective assumptions to minimise possibility of underestimating exposure or risk - may not be accurate when the same products are used in a workplace

Page 18: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA210606 / 5

Key timing issues for GHS implementation• Goal: GHS classification criteria to be

applicable at the time when C&L information required in REACH

• GHS classifications to be established first for substances, then for mixtures

• Transitional arrangements as regards REACH requirements

• Two types of labels for a transitional period – as short as possible ?

• Adoption of the GHS Regulation in one reading with the European Parliament ?

Page 19: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA210606 / 6

GHS implementation• Commission will decide on the proposal on the basis of UN

adopted GHS

Implementation will• be closely linked to REACH

– C&L information provided in the context of registration– C&L inventory– authorisation and restrictions using classification as a

basis (followed by risk assessment)– COM promised to come forward with a proposal – Council of Europe conclusions: to be implemented

respecting REACH timeschedule• follow the accepted GHS document - no deviations from the

international agreement• apply BB approach• follow the present EU practice as closely as possible (CA

options!)The Commission to provide guidance how to transform the

present C&L to the GHS C&L

Page 20: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA210606 / 7

REACH and GHS – transitional arrangements

11/06 12/06

Prop.for GHSReg.

Adoptionof

REACH

04/07

EIF of REACH

12 monthspreparationfor REACH

6 monthspre-reg.

• Reg. of > 1000 t;> 100 t/R50-53; > 1 t cmr

• C&L inventory

04/10

GHS available for application

06/07

First readingadoption in theEP and Council

EIF of GHS Reg.

04/08

Transitional periods for GHS: Substances: 3 y for C + L

Mixtures: X y

Page 21: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA210606 / 8

Conclusions

• GHS implementation – as closely as possible to the present EU system -

will not include GHS Annex 5/CA-option– applies BB approach

• To take into account REACH implementation time schedule– GHS-based classification and labelling criteria

available when the first obligations to provide C&L data applied in REACH

• Simple guidance to transform the present C&L information to the new GHS C&L information

Page 22: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

1

Fifth HERA Workshop with StakeholdersTalking about Chemicals with Consumers

Brussels, 21 June 2006

From chemicals to everyday productsREACH and GHS – Clarity or Confusion

Takis DaskalerosHealth and Consumer Protection Directorate-General European Commission

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2

Consumers are exposed to a large number of chemicals from products they use every day

Consumers are also ‘exposed’ to a lot of information about the chemicals and the products they use!

In talking to consumers about chemicals in consumer products we must also be clear on what we want to achieve

Talking to consumers about chemicals Talking to consumers about chemicals

Page 24: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

3

Talking to consumers about chemicalsTalking to consumers about chemicals

• Need to be clear about what we want to communicate

– Safe use of a chemical or of a product?

– Hazard data of a chemical or a product?

– Risk (hazard and exposure) of a chemical or a product?

– Other aspects of chemicals (technical performance, efficacy)?

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4

Talking to consumers about chemicals Talking to consumers about chemicals –– CommunicationCommunication•• Perception i. e. how do consumers perceive product, safety elemePerception i. e. how do consumers perceive product, safety elements, etcnts, etc

•• Consumer expectations Consumer expectations

•• The circumstances (e.g. crisis The circumstances (e.g. crisis vsvs ‘normal’ situations)‘normal’ situations)

•• The degree of uncertainty (unknowns)The degree of uncertainty (unknowns)

•• The roles of those contributing in risk communication (who says The roles of those contributing in risk communication (who says what)what)

•• Social trust and dialogue Social trust and dialogue

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5

Talking to consumers about chemicals Talking to consumers about chemicals ––CommunicationCommunication• Currently there are mainly three types of

approaches used

– Top down (e.g. authorities communicating scientific facts)

– Bottom up (e.g. initiatives by consumer groups)

– Dialogue (two way communication)

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6

In the consumer product context, more often than not…In the consumer product context, more often than not…

•• …‘top down’ is most common way of communicating with …‘top down’ is most common way of communicating with consumers consumers

•• …talk more about the …talk more about the productproduct and less (if at all) about and less (if at all) about specific chemicals that make up the productspecific chemicals that make up the product

•• …talk about …talk about productproduct safety, use, efficacy and benefitssafety, use, efficacy and benefits

•• …communicate via the …communicate via the productproduct labellabel

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7

Talking to consumers about chemicals Talking to consumers about chemicals –– Consumer Consumer attitudes and expectationsattitudes and expectations• There is a high expectation among consumers that safety is an ‘ingredient’ of consumer

products

• Established habits and practices play a big role in consumers’ attitudes with products (‘I know how to use it/buy always the same product’ and the ‘convenience over safety’ attitudes when it comes to buying and storing products

• There is a clear difference in the perception of the risks associated with some product categories

• Overall symbol recognition is good when the symbol is representative/figurative and not as good when the symbol is more abstract

• Challenge is not to offer too much or too little or too technical safety/composition information on the label but to offer the right information

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8

Talking to consumers about chemicals/products Talking to consumers about chemicals/products

• What is the right information on the product? – Determined by carefully examining consumer attitudes and

perceptions

– Extensive pre-work on execution, presentation aspects

– Consumer education

– Complimentary communication elements

Page 30: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

9

Talking to consumers about chemicals Talking to consumers about chemicals –– REACH and GHS REACH and GHS in relation to consumersin relation to consumers• REACH is about chemicals

• There are provisions in REACH for access to information on chemicals

• Current classification system and future GHS are about chemicals and chemical products

• In the consumer context, classification/labelling aims – to inform consumers of potential dangers, and – To advice them to use the product safely

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10

Talking to consumers about chemicals Talking to consumers about chemicals –– GHS and the GHS and the consumerconsumer

System agreed at international level

No changes possible

New elements (symbols, colours, phrases)

Page 32: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

11

GHS and the consumer GHS and the consumer –– Way forwardWay forward• For DG SANCO GHS is an opportunity to deliver the ‘right’ information to

consumers

• Need a stakeholder dialogue and strategy to

– Understand how consumers will perceive the new system

– Educate consumers on the new system to facilitate its implementation

– Wherever possible optimise the execution/presentation of the new system to consumers

– Conduct complementary communication activities

Page 33: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

A.I.S.E. Developing an Effective

Communication on Chemicals and

Products Safety? V. Scailteur

Procter & Gamble – Brussels

HERA Workshop – June 2006

Page 34: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

A ChallengeMulti-Channels Answers

Prerequisite :

Product performance (“fit for use” )

Product safety (for man and the environment when used as intended and under reasonably foreseeable use)

Page 35: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Product Safety

• For workers in laboratories and factories.

• For consumers and communities.

• For environment around factories and at large.

Page 36: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Product Safety

• Regulatory compliance

• Risk assessment and management / experts.

Page 37: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Communicate but how ?

• Proclaiming safety … even with scientific third party confirmation : not sufficient.

• Many have no idea about the safety data Companies have.

• Opinion leaders and consumers expect more information.

Page 38: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Drivers

• Consumer interest for ingredients in products they buy, their effects on health and their environmental impact.

• Communities interest around factories.

• Information technology (internet etc…).

• Chemical analysis techniques and competitive aspects changing.

• Relatively low trust in Governments and in Industry.

• Scary news stories travel fast … and well.

Page 39: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

“Endocrine disruptor found in a window cleaner …”

more appealing than

“Brand X laundry detergent is safe …”

Page 40: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

What is Meaningful Information on Product Performance and Safety ?

To :• Consumers

StudentsCommunitiesSpecial interest groups

• Trade/Distributors• Regulators• Consumer Organizations• Environmental Groups• Media

A journey of dialogue and learningsHERA Workshops

Page 41: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Communication ? Previous HERA Workshops

• Labeling on pack

• Web-based channels

• Telephone/mail (consumer and professional lines)

• Campaigns

Page 42: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

HERA Learnings

Communicating information on chemicals and products to the consumer is a major challenge.

• Consumers want to know the risks that they face.

• Consumers want to buy products in the confidence that they are safe in today‘s world.

• Risk based communication needs to be continuous. Mistrust is created if companies are perceived only to communicate or react to a crisis.

• Risk based communication cannot be “one size fits all”. It must fit the purpose and be understandable.

Page 43: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

GHS and the Future EU Classification and Labeling Legislation

A Globally Harmonized System for Classification and Labeling of Chemicals

1992 UNCED Agreement, endorsed by the UN General Assembly:

A globally harmonized hazard classification and compatible labeling system, including material safety data sheets and easily understandable symbols, should be available, if feasible, by the year 2000.

Program Area B, Chapter 19, Agenda 21

Page 44: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

What is the GHS ?

• A single harmonized system to define and classify hazards, and communicate information on labels and safety data sheets.

• Communication to :• Workers• Consumers• Emergency responders• Transport sector

Page 45: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday
Page 46: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

GHS

Based on hazard as is labeling today (EU) ,

With possibility for labeling based on “likelihood of injury”

for consumer products

Page 47: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Views on Communication on Potential Danger to Consumers

• “More benefit if labeling system more consumer risk oriented” (NL Cons. Inst., 1997).

• “Need for consumers to understand the seriousness of the risk involved” (COFACE, 1994).

• “Consumers want information that connects consequences to actions” (US EPA, 1999).

• “Consumers switch to another brand when information overload” (P&G Cons. Res., 1999).

Page 48: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

A.I.S.E. Views

Supporting the option of consumer product

labeling based on the likelihood of injury (“risk

based labeling”).

Page 49: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Based on hazard Based on hazardand likelihood of injury

Warning :Causes eye irritation

Liquid detergent product containing >0.1% ethanol & 10% surfactants

Danger :• May damage fertility or theunborn child

• Causes eye irritation

!!

Page 50: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Product Information via the Web

Page 51: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

View of Science in the Box Website Illustrating Levels of Information

Risk assessment information Product information

Level 1: Formula detail

Level 1: Layman language

Level 2: more technical

Level 3: very technical

Level 1: Product Human & Env safety assessment

Page 52: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Broad campaigns : A.I.S.E. Washright

Communication to Consumers

“Promote sustainable consumption”

Page 53: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

• Wash-right panel on pack.

• Regular updates of the www.washright.com web-site

• Communication via local industry associations and companies (leaflets, print advertising campaigns, etc…)

Page 54: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

The Pan-Euro Washright TV Campaign

Objective :

• Build awareness of the Washright advices with consumers

Page 55: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

• Above 50% awareness (2/3 spontaneous)

• Very well received by consumers (qualitatively as well as quantitatively)

• Welcomed by the Authorities and NGO’s (at European as well as national level)

• Quoted by key global organizations as best practice of communication on Sustainable consumption (UNEP, OECD, WBCSD)

Page 56: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Broad Campaigns ?

• HERA, and especially REACH, will generate massive amounts of information on chemicals. This will not make consumers more comfortable with using chemicals ...

• ... unless a serious effort is made to help consumers to understand what all these data mean.

Page 57: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

An interactive CD was also produced in 2005, allowing the public access to information on chemicals in a setting they would understand: “CLEAN HOUSE, SAFE HOME”

Choose from: ‘A walk through the house’, ‘Scientists’ section’, ‘Links’ or ‘Partners’

1. Enter the house

2. Choose a room:HallLaundry roomBathroomKitchen

Page 58: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

3. Choose a product or open a cupboard / the oven / refrigerator

4. Obtain tips on efficient use of the product / an explanation of the role of the product / a list of ingredients

In the Scientists’ section the full HERA risk assessment is provided on each ingredient.

Page 59: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

Our Conclusions ?

• Information sharing is important to us.

• We are learning how … and are committed to continue.

• Dialogue with stakeholders.

• Accurate and meaningful information on chemicals and products risks

• Can help building consumer trust in our products.• Can help putting in perspective scary alarms.• Is part of our corporate credibility.

An Ongoing Journey

Page 60: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

When Hazard is Taken for RiskAddressing Hazard-based Chemicals Restrictions

Daniel Verbist

HERA Workshop, June 21st 2006

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2

ContextCefic Concern: Chemicals are increasingly restricted on the basis of their

hazard potential - despite favourable risk assessments: What does this mean for business – especially under REACH ?

Strategy Group on Risk (SGR) mandated, Dec 2004Specialty Chemicals Programme

Reality Check

By Whom, When, Where, are decisions to restrict chemicals taken?

Case studies, Literature reviewConsultation: Members – Regulators - Trade Associations –

Cefic StaffRegular validation by Company Delegates

Situation Analysis

Why are substitutions/ bans pursued?

What is the course of a typical issue?

Action Plan (October 2005)

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3

Findings

1. Science is critical as validation of chemicals management. But over-reliance on the “sound science” argument traps industry into increasing ‘techno-babble’ that lacks stakeholder resonance.

2. An increasingly risk-adverse social and political environment has created a new relationship with Science: where it is used not for what it can prove, butfor the doubts and concerns it raises

3. As a result, stricter regulations are imposed (e.g. REACH). But regulations cannot deliver certainty. At best they help impose acceptable levels of risk.

4. What is an “acceptable risk” is open to interpretation and subject to social mood.

The Chemical industry is caught in a Process Gap, preventing it from meeting stakeholder expectations on chemical safety

Industry is in a difficult position! Can it ever meet expectations?

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4

FindingsSOCIETAL EXPECTATIONS

STAKEHOLDERS

INDUSTRY

Process Gap

Acceptable level of risk

PRECAUTION (effective bans)

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5

Situation Analysis - ScienceScience is the foundation of the chemical industry

Science is intrinsically uncertain and open to interpretation

Uncertainty leads to fear

Fear leads to outrage and “playing it safe” “PRECAUTION”

The chemical industry relies on science to address fears

But the uncertainty embedded in Science ignites more fear

Catch-22 : “The Science Trap”

Industry needs to re-think the way it uses science in the debate. The “sound science” and “risk vs Hazard” mantra does not resonate…

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6

Why the Science-Trap?

Industry is not good at risk communication

Argumentation is not always clear, relevant, meaningful

Interpreted as side-stepping concerns

Science is open to interpretation – why believe Industry?

Science must support political agendas – or be ignored

- Science will always be industry’s validation (Long Range Research Initiative)

- Science can show industry is the solution

- Science can highlight benefits vs Risks & Hazard

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7

Reality Check – Precaution

1. The Precautionary Principle is written into the EU Constitution and EU Treaty

2. In 2000 the Commission issued its communication on the PP –setting a welcome framework for its application – but:

There is NO definition of the PP (most cited text is Principle 15 of Rio Declaration, 1992)Implementation reflects societal, rather than scientific opinionAs such, the PP can over-ride science

3. Clarification of the PP implementation is urgent since its application is likely to increase in the future (e.g multi-causality of environmental-health)

4. At least Half of all restrictions happen down-stream: brand-holders have no tools to resist pressure.

Concern that “Precaution” is increasingly misused to restrict chemicals…

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8

Action Plan3 Key Actions

1. Build alliances with key groups in facing common issues:

Hazard Identification – what’s the real danger?Perceived vs. real risk – when to benefits outweigh risks? Risk vs safety evaluation – what level of risk is acceptable?

2. Stop “techno-babble” : find new ways to communicate

3. Use “good examples” to work with members across the Supply Chain to define methodology to understand needsand provide appropriate tools

Key groups facing similar issues:Value Chain (incl. Consumer organisations)International Organisations (eg World Health Organisation)Community Agencies (eg European Environment Agency)Non-governmental organisations

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9

Conclusions

There is much industry can do, internally, to help close the Process Gap and escape the Science Trap…

But Industry will not fully reach Stakeholder expectations on chemical safety until it is seen as part of the solution to the Big Questions:

Ongoing social debate around risk acceptance in generalCosts vs benefits of “Progress”

Therefore we really need to work along the whole value chain till the end-consumer and to define theappropriated approaches and methodologies

Page 70: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

21.06.2006 Henkel KGaA / Dr.Haller / HERAWorkshop1

European stakeholders‘ workshopTalking about chemicals with consumers;

from chemicals to every day products

REACH and GHS: confusion or clarity

HERA21st June 2006

Werner HallerProduct Safety-Regulatory Affairs

Consumer Adhesives

Page 71: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

21.06.2006 Henkel KGaA / Dr.Haller / HERAWorkshop2

HAZARD - RISK

• Differentiation essential, but often blurred

• There is no „No Risk“

• Balance the risks to minimum

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21.06.2006 Henkel KGaA / Dr.Haller / HERAWorkshop3

HAZARD - RISK

• Differentiation essential, but often blurred

Rosin resin

Hazard: dust causes sensitisation by inhalationAdhesive: less than 5 % in an emulsion based productRisk: no exposure - no risk, as the dust is not available

for the customer (but for production !)

Page 73: TALKING ABOUT CHEMICALS WITH CONSUMERS From Chemicals to Everyday

21.06.2006 Henkel KGaA / Dr.Haller / HERAWorkshop4

HAZARD - RISK

• There is no „No Risk“ • Balance the risks to minimumSome keywords: Solvents, VOC, Plasticizers, Biocides, FA

Hazards: Inflammability, neurotoxicity, endocrine disruptors,MCS-Syndrom, allergies, cancerogenity, environment

Measures: reduction/replacement of solvents with waterbornesystems - use of plasticizers and preservatives;reduction/replacement of preservative - qualitiy issues,mould and bacteria growth

Consider environmental sources! (wood - FA; smoke; traffic)

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21.06.2006 Henkel KGaA / Dr.Haller / HERAWorkshop5

Labelling - Warning ?

• Meaning of labels unclear to most customers- either ignored or to great care (no buy)

• Confusing for customers as well as for producers- to many warning and advice sentences;

- hardly manageable laws and regulations

• Implementation of GHS will not improve situation- to much emphasis on hazard instead on risk

- at least in the transition phase increase in confusion

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REACH and GHSClarity or Confusion

From Chemicals to PaintsCommunication to consumers

Leo Appelman

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From manufacturer to consumers : old days

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From Manufacturer to consumer; Nowadays

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Clarity or confusion?

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Clarity or confusion?

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Communication tool to consumers.

•Paint can is the only tool, therefore information on:•HSE •Use and disposal

must be clear and unequivocal

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Communication to consumers via the package

• In order to avoid any confusion:- The packages should preferable have hardly any hazard

symbols or no symbols at all, - If possible even no Risk phrases via:

• Selection of the raw materials.• Calculating the impact of the raw materials on the labeling of the

formulation• A pro-active Product Stewardship/ Coatings care program

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Product Stewardship/ Coatings Care program

• Adhere to the applicable legislation ( Marketing and Use Restrictions Directive)

• Going beyond the MUR by:

• Adherence to the AN Coatings Policy on raw materials• Stepwise phase out of Crystalline Silica• Phase out of Alkyl Phenoxy ethoxylates• Compliance ahead of legislation with VOC Directives

• No statements “what is not in the product”• Warning statement for exposure to dust from sanding

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Expectations of the consumer.

• High quality products• Safe product under normal use

• Way of application: roller, brush

• No adverse health effect when used indoor• No use of fungicide indoor• Offering solvent free products

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Actions to meet expectations from consumers

• Anticipate on GHS (impact analysis and reformulating)• Discussion with authorities about sense and non-sense of

new initiatives• Continuous improvement of the products by selecting the

right raw materials• Following closely global discussions on hazard

classifications

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Akzo Nobel Decorative Coatings is trying to avoid confusion at the consumers even with the GHS ahead.

Thanks for attention.

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Communicating to Consumers

Shannon Coombs - Executive DirectorCanadian Consumer Specialty Products Association (CCSPA)Presentation – HERA Workshop - June 21, 2006

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Canadian Example..Risk-based labelling for cleaning products, disinfectants, pest control productsLegislation governed by Health Canada

Hazardous Products Act (HPA) & Consumer, Chemical & Containers Regulations 2001Pest Control Products Act (PCPA)Food & Drugs Act (F&DA) & Regulations

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What is the basis for communication with consumers?

Warning StatementsFirst Aid Treatment

Symbols

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Will there be added benefit to consumers with GHS?

Timing of GHS implementation in Canada 2008.CCSPA Position – GHS will only benefit Canada if we have a timed implementation with our major trading partner in North America – the United States.Risk-based labelling is a building block in GHS –and one that Canadian industry is requesting that government include in the proposed regulations.

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CCSPA Talking to Canadian Consumers – Safety of Consumer Products

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What is CSDSL? What is this list of substances? What does it mean to me?

Categorization & Screening of the Domestic Substances List (CSDSL)Mandated program under the Canadian Environmental Protection Act (CEPA)Legislation governs all substances in Canada

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CCSPA ActivitiesCreated a member driven stakeholder working groupCreated a website www.healthycleaning101.orgfor consumers to provide balanced information:

Benefits of the productsHelpful tidbits, consumer informationHow the products/substances are regulated

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CCSPA ActivitiesMessages are focused on product categories:

pest control products, aerosols, soap & detergents, disinfectants, household cleaners

Key Themes: Read the label, use productsappropriately – stay safe, healthy and clean

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What does the list mean to Canadians?

Substances and Products are safe when used according to the label.Canadian government is doing a good job –using the best available science in a step wise process to ensure the health, safety and environment for all Canadians.

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What has CCSPA been doing?

Actively working with Government Officials to get a Working Group established to develop a communication strategy, key messages and a key government spokesperson for the initiative.Working with other industry associations to develop alliances.

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Preparing for public awareness of the list in September.Developing key messages for CCSPA.Working with elected officials to brief them on this important topic. Consumer Brochure available at:http://www.ec.gc.ca/substances/ese/eng/brochure.cfm

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What have we learned so far?Consumers want to know products are safeChemical language is a difficult sell in any country and in any languageGovernment officials are reactive – not proactiveENGOs are very sophisticated in approaches Media wants negative stories

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Globe & Mail – May 27, 2006

Toxic Shock: Part 1- Canada’s chemical reactionPart 2: Coming to terms with perils of non-stick productsPart 3: Ottawa plans to snuff out flame retardantsPart 4: Are plastic products coated in peril?Part 5: Want a full-time job? Live chemical-free

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Key Messages!Canadians can feel confident that the products they use are safe!CSDSL is a rigorous science-based program. Canadian government is doing the appropriate oversight for existing chemicals. Priority setting is step one, government and all stakeholders will plan a path forward.Canada has tough laws and regulations for human health, safety and the environment governing substances and products.Industry is working with all stakeholders – we are part of the solution.

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Who is our key audience?Elected and government officials – people who draft and influence legislation and regulationEducatorsConsumers via the website

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What else is going on?Mandated review of the Canadian Environmental Protection Act (CEPA) by 2 Houses within our Parliament (House of Commons & Senate)Release of “Toxic Nation” – a biomonitoring study by an ENGO group regarding contaminants in blood levels in Canadians.