Introduction by Croakey: A recent test by Emissions Analytics found that car tyres produce more ultrafine particle pollution than exhaust emissions.
Given the health effects from ultrafine particles, including lung inflammation and links to cancer, this is concerning.
The test found differences in wear rates, toxicity and chemical composition in different tyres, which “potentially points to an effective way to drive reductions in wear and toxicity through economic incentives and regulation,” according to Emissions Analytics, but more research is required.
Another area requiring stronger regulations is in the use of agricultural, veterinary and industrial chemicals, due to their potentially adverse effects on human health and the environment, according to Dr Peter Tait, a GP, academic and environmental health advocate.
“A key principle of all regulation is the protection of human and environmental health. Failure of regulation increases exposures and hence increases the burden of preventable disease,” he writes below.
Tait discusses a review to assess Australia’s chemical regulators and includes recommendations for improvement.
Peter Tait writes:
In the past five years Australia’s agricultural, veterinary (agvet) and industrial chemical regulation has undergone a series of reviews and reforms.
The purpose of these has been to reduce the regulatory burden on manufacturers, importers and industry while retaining protection of the environment and human health.
Industrial chemical regulation falls under the purview of the Australian Industrial Chemicals Introduction Scheme (AICIS) and agvet chemicals are regulated by the Australian Pesticides and Veterinary Medicines Authority (APVMA). AICIS replaces the National Industrial Chemicals Notification and Assessment Scheme (NICNAS). The APVMA reform continues.
In 2021 the Public Health Association of Australia, with students from the Australian National University Medical School, undertook a comparison of Australia’s chemical regulatory system to regulation in comparable countries, specifically the USA, Canada and the European Union.
The aim of the review was to assess what Australia’s regulators were doing well and where improvements might be made.
Many agvet and industrial chemicals are known to have or potentially have adverse effects on human health and the environment (summarised in our review; here and also here).
Chemical impacts present a global problem and each country has to play its part in minimising harm. Thus, regulation to eliminate or seriously reduce this threat is an important public and planetary health objective in Australia.
Consequent to the review, we have made a series of recommendations for policy and regulatory improvements. While there is some overlap in recommendations for the agvet and industrial sectors, we grouped recommendations within each sector, as well as identifying common ones.
Agvet chemicals regulations
Australia should establish a National Domestic Produce Pesticide Residue Monitoring Program prioritising high risk agricultural zones and water catchments as a means of optimising cost in line with the EU, US and Canadian systems.
A program such as this would be an extension of resources and outputs of the National Residue Survey, the Australia Total Diet Study and other industry residue monitoring programs such as FreshTest.
A National Domestic Produce Pesticide Residue Monitoring Program would not only benefit assessments of effects on human health, but also that of ecosystem health and water safety.
Implementation of well-defined review triggers, such as de-registration by an international regulator, or reaching a threshold number of validated adverse event reports, as well as scheduled periodic reviews backed up by a re-registration scheme similar to the EU, US, and Canada could build upon existing mechanisms such as codes of practice, work health and safety risk management plans, pesticide spray records, and industry waste stewardship schemes.
There needs to be a National Licensing Framework to regulate occupational agvet chemical exposure activity backed up by a set of training standards, especially for restricted chemical products.
Machine-readable, smart chemical product labels to enable communication of key information such as chemical safety properties, safe use measures, first aid, and safe disposal requirements should be adopted.
As part of the current APVMA review, the current adverse events reporting system extending beyond animal health concerns, and integrating better with jurisdictional reporting of other agvet chemicals such as pesticides can be introduced. This would link with the residue monitoring program.
Industrial chemicals regulation
Similarly to the agvet sector, Australia needs to establish biomonitoring of industrial chemical residues and exposure with a continuous funding stream similar to the chemical body burden monitoring programs in Europe, USA, and Canada.
In parallel, we need a comprehensive national database to collect biomonitoring results to assist in identifying exposure trends over time and by geographical regions, and to enable detection of populations that may have increased exposure and risk of adverse effects.
Under the recently Introduced National Industrial Chemicals Environmental Management Standard (IChEMS), specify standards for states and territories to incorporate into their legislation to facilitate nationally harmonized risk management and develop a robust system of measurable indicators.
IChEMS should also include performance metrics to enable industry to show that the standards are being met.
AICIS needs improved resourcing (from government and industry) to enable the Inventory Multi-Tiered Assessment and Prioritisation (IMAP) Program to accelerate assessment of the large number of unassessed chemicals currently in use.
Recommendations
In parallel to the above measures, Australia should implement a National Adverse Chemical Events Reporting System with reports from chemical registrants, regulators, users and the general public being funneled to a single entity.
This should systematically report the potential indirect impacts of chemicals in the environment on human health. These reports need to be accessible by the public once validated, as a confidence building measure.
Additionally there needs to be a National Surveillance System to link together fragmented data sources in the current regulatory framework.
Such inputs would include data from sales, national residue monitoring programs, chemical use, industry quality assurance programs, compliance, adverse events reported, as well as associated reports, research and decisions from international regulators.
A further support and confidence measure necessary is a performance measurement structure to ensure that risk reduction strategies are effective in protecting human health and the environment.
This might include AICIS and APVMA conducting reviews involving comparison with other international regulatory bodies and exploring adoption of strategies proven to work overseas as well as regular external audits by experts to complement regular self-assessments.
These need to be backed up by clear reporting obligations with proportionate penalties for breaches.
Clearer distinction between risks from consumer products and risks to humans from environmental exposures to agvet and industrial chemicals is required.
Consultation and engagement of stakeholders with the ongoing monitoring of the effectiveness of the national data collection and regulatory effort is critical.
Information collected through these programs should then be readily available in real-time to all stakeholders, including the public, in an appropriate form as a means of instilling confidence in Australia’s chemical regulatory framework.
The process for monitoring to determine if recent reforms to agvet and industrial chemical regulation will be sufficient to facilitate ratification of international conventions in a timely manner needs to continue.
Adequate system funding for operation and evaluation is essential.
Conclusions
Chemical exposures currently affect human health adversely. This is particularly the case for vulnerable populations: the young, aged, pregnant women and their fetuses, and people in lower socioeconomic circumstances, particularly First Nations peoples.
A key principle of all regulation is the protection of human and environmental health. Failure of regulation increases exposures and hence increases the burden of preventable disease.
Combined with other major environmental changes (climate disruption, topsoil loss, and biodiversity loss among others), accumulating chemical toxins in the environment reduce the adaptive capacity of all species including our own.
Both the Australian agvet and industrial chemicals regulatory frameworks require further improvement to bring them in line with comparative international regulators.
The recent changes to AICIS and the proposed changes to the APVMA have been guided by government priorities to reduce the regulatory burden on the industry. This may increase the risk of chemical exposure to people and the environment, and this needs to be monitored.
Protection of animal and human populations from unnecessary and damaging chemical exposures is, therefore, a central public health action. Another opportunity for the new ALP Government to rise to, for improving the public good.
Dr Peter Tait is a GP, a Clinical Senior Lecturer in Population Health at ANU Medical School and active with many public health and democracy organisations. On Twitter, follow @aPeterWT.
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