The Way Ahead


Future Protocols for HPPs

A recent “White Paper” from the European Commission has unveiled the shape of things to come in the area of toxicological testing and authorization of chemi­cals [13]. The Paper proposes that industry perform toxicological and ecotoxicolo­gical testing of all existing commercial substances and prepare risk assessments to demonstrate either that they are safe or should be authorized for future use only in restricted ways.

A tiered testing process will be phased in over a 20-year period, and is expected to cost industry approximately $2.5 billion, with an administrative staff of almost 200, to be paid for by a service fee levied on industry. Of major concern with HPPs is a “fast track” authorization provision for PBTs. As already noted in Sec­tion 25.3.4 above, HPP producers and importers must ensure accuracy of the defi­nition of PBTs as (P+B+T)s or face the specter of across-the-board regulatory restrictions on their products due to exercise ofthe Precautionary Principle.

The White Paper is now being submitted to the European Parliament. If signed into law, this strategy will ensure the largest volume of toxicological and ecotoxico­logical testing that has yet been seen.


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