Over the course of several decades, government policy successfully reduced the occurrence of hazardous substances in the physical environment, but of late this development is stagnating. The number of hazardous substances is increasing, as is the number of products that contain them. As a result, these substances are accumulating in the physical environment, giving rise to new risks and incidents. Examples of such risks and incidents include PFAS, plant protection products, microplastics and pharmaceutical residues.
Transparent information and more knowledge needed
To prevent further increase in the risks related to hazardous substances, first more knowledge is needed about the extent to which they end up in the physical environment. This applies to the various phases of production, use, reuse and waste processing. The Rli, therefore, advises the Dutch Government to compel companies to keep track of the routes travelled by these hazardous substances throughout their lifecycle, using a track & trace system. In addition, government policy capacity and knowledge must be enhanced to improve policy implementation, enforcement and supervision. This calls for additional budget being allocated to this purpose.
Limit the risks of cumulative exposure, for both people and the environment
As increasing numbers of hazardous substances are used more often and in larger quantities, this also increases the risk of simultaneous exposure to multiple substances. Previously, risks to humans and the environment mainly were caused by exposure to individual substances. Today, however, there are many more diffuse mixtures of substances, each in low concentrations, but together they may have an equally harmful effect. The Rli recommends that the effect of this simultaneous exposure is taken into account when setting national environmental standards. This may also be necessary in specific areas, for which government will need to support municipalities and provinces.
Safe product reuse and recycling calls for new European regulation
The transition towards a circular economy poses new challenges. A circular economy has closed-loop cycles, which also means that hazardous substances can accumulate within those cycles. Prior to the production and reuse of such substances, specific attention should be paid to ensuring their safe reuse. The Rli, therefore, calls on the government to promote rules and regulations, on a European level, which incorporate such reuse into the risk assessments of substances. In addition, information should be readily available on the substances contained in all products. In this context, the possibilities for introducing a material passport for the chemical composition of each product should be investigated. Such passports would offer insight into the possibilities of reuse for the producers and users of those products.
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