The substitution principle

Hansson, Oskar; Molander, Linda; Rudén, Christina

doi:10.1016/j.yrtph.2011.01.011

Cited by 35 publications

(27 citation statements)

References 11 publications

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“…Substitution of dangerous substances by less hazardous substances is not always easy, but should be the first priority [52,77]. CMR substances, for example, should not be present in any PCPs and the exceptions allowed in the Cosmetic Regulation should be deleted.…”

Section: Reduction Of Dangerous Chemicals In Consumer Productsmentioning

confidence: 99%

‘Read this and be safe!’ Comparison of regulatory processes for communicating risks of personal care products to European and South African consumers

Klaschka

Rother

2013

Environ Sci Eur

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Background: Most personal care products (PCPs) contain hazardous ingredients, but current legislation in the European Union (EU) and South Africa (SA) does not require these to be labelled as hazardous products. Instead, ingredients must only be listed on containers to inform consumers of potential hazards. We assessed whether current legal strategies provide the means for effective risk communication (RC) mechanisms for PCPs in order to protect consumers' health and the environment. Results and conclusions: RC strategies used in developed countries are not necessarily better compared to developing countries despite the existence of extensive legislation in the former. Socio-cultural factors, scientific literacy and language differences are key reasons why the current ingredient lists on PCP labels are not an effective RC strategy. The assumption is that consumers will interpret the risks of these ingredients by conducting a risk assessment for their personal context. Realistically, the following risk mitigation measures should be implemented in developed and developing countries to reduce the public's potential exposures to hazardous substances: substitute hazardous ingredients with less hazardous; provide accessible mechanisms for consumers to comprehend RC measures; delete the exception clause in the EU Regulation on Classification, Labelling and Packaging (CLP); apply clear mandatory labels where PCPs health risks are clearly illustrated; and increase enforcement of legislation. The high incidence of fragrance allergies caused by PCPs is one example illustrating how current legal measures in the EU and SA fail to protect consumers and the environment from hazardous exposures. Therefore, efforts must be made to improve legally required RC measures.

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Section: Reduction Of Dangerous Chemicals In Consumer Productsmentioning

confidence: 99%

‘Read this and be safe!’ Comparison of regulatory processes for communicating risks of personal care products to European and South African consumers

Klaschka

Rother

2013

Environ Sci Eur

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“…Hansson et al 2011). Since chemical regulation, and thus also the substitution principle, is bound to be controversial given the size of the interests at stake, it will draw media attention, and most likely be subject to political opportunism and lobbying both from industry and from the health and environmental NGOs.…”

Section: Resultsmentioning

confidence: 99%

“…Under such circumstances it would be far better if substitution were based on risk assessments. Generally speaking, much emphasis is put on the distinction between a hazard and a risk in chemicals regulation (Hansson et al 2011;Molander and Rudén 2012), and I would agree with Löfstedt: risk assessment is important, not least to avoid risk-risk trade-offs. However, risk assessment is sometimes just as problematic as hazard categorization.…”

Section: Hazard-based or Risk-based Substitutiona Matter Of Controvementioning

confidence: 96%

“…In other words, the question of whether chemical regulation should be based on hazard categorization or risk assessment is not only a matter of definition and practical procedures; it is also a matter of conflicting interests. This is also the case when it comes to the supposed target of the categorization or assessment, as Hansson et al (2011) point out: environmental NGOs and policy-makers are inclined to focus on the existing substance or product; industry representatives on the process of substitution and the substance or product to be substituted. Hence, the substitution principle is influenced by underlying conflicts between the different interests and points of view, which, if they fit with the media logic of the day, will also make the news.…”

Section: Hazard-based or Risk-based Substitutiona Matter Of Controvementioning

confidence: 99%

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The substitution principle in chemical regulation: a constructive critique

Olofsson¹

2013

Journal of Risk Research

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“…2 Therefore, despite growing initiatives to substitute safer alternatives for toxic components, gaps persist in the knowledge on how to proceed. 3 In response to this dearth of information, the U.S. Environmental Protection Agency (EPA) established the High Production Volume (HPV) Challenge Program, a voluntary initiative that asks manufacturers to publicize information on health and environmental effects of chemicals that are either manufactured or imported in the United States in annual quantities exceeding 453 t (1 million pounds). In contrast, the Organization for Economic Cooperation and Development (OECD) and Japan set the annual threshold for reporting on HPV chemicals at production or import of 1000 t. Approximately 2200 chemicals are included in EPA's HPV Information System, and the data represent international consensus on which chemicals to include based on 18 Screening Information Data Sets.…”

Section: Introductionmentioning

confidence: 99%