INTERNATIONAL
COUNCIL OF
CHEMICAL
ASSOCIATIONS
01-2001
INTERNATIONAL MANAGEMENT OF CHEMICALS
THE CONTRIBUTION OF THE
INTERNATIONAL COUNCIL OF CHEMICALS ASSOCIATIONS (ICCA)
BACKGROUND
The countries of the world took a significant step forward towards a better global future
when they came together in Rio de Janeiro 1992 and adopted Agenda 21. This global
endorsement of Sustainable Development and the protection of the environment formally
recognised that societies have a vital role in protecting their environmental relationships,
just as they do their social and economic relationships; and that all three of these
fundamental dimensions are interrelated. The chemical industry supports the goal of
Sustainable Development and has a vital part to play in attaining that goal.
The chemical industry is a key industry. Its products and services are instrumental in
meeting the needs of mankind. A major contribution of the chemical industry to
advancing sustainable development and to further improving the health, safety and
environmental performance of its operations and products is the global extension of its
improvement in the management of health, safety and environmental (HSE) risks whilst
also meeting customer and public demands for economically viable new products that can
be handled safely. Striving for such improvement is not only good business practice but
represents a practical contribution towards sustainable development, and drives chemical
manufacturers and suppliers to establish integrated Product Stewardship programmes.
Product Stewardship is the responsible and ethical management of the health, safety and
environmental aspects of a product throughout its entire life cycle. It is Responsible Care
applied to products.
Chapter 19 of Agenda 21, "Environmentally Sound Management of Toxic Chemicals"
recognises the need for co-operative government, industry and public actions to ensure
that the countries of the world make further progress in their efforts in each of the six
programme areas.
ICCA takes the view that the Intergovernmental Forum on Chemical Safety (IFCS)
should play a leadership role as a deliberative body through which the stakeholders can
better understand and identify possible international problems associated with chemicals,
prioritise those problems, and then recommend the most reasonable strategy approach to
deal
with
high
priority
international
chemical
issues.
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The independence of the IFCS is a fundamental prerequisite of this approach, as is its role
as an open forum rather than an implementing or decision-making organisation.
The chemical industry also supports the Inter-Organisation Programme on the Sound
Management of Chemicals (IOMC), an international mechanism to promote and to
improve co-ordination of policies and activities of the participating organisations.
Moreover, ICCA recognises and is further supporting the role of the United Nations
Environment Programme (UNEP) in chemicals management. The recently adopted
Rotterdam Convention on Prior Informed Consent (PIC), and the finalisation of the
Convention on Persistent Organic Pollutants (POPs) are remarkable milestones in the cooperation between UNEP, Governments, Industry and NGOs.
It is clear that various organisations and fora are involved in and dealing with chemical
safety issues at the global level. In this respect, it is vitally important to clarify which
issues are really of global concern and which fora are responsible for leading such issues
globally.
It is also critical to recognise that the ultimate goal of chemical safety related activities is
to ensure that chemicals can be handled safely from production, processing and use to
disposal at global level. This is why the chemical industry is committed to providing the
necessary information for the safe intended and foreseeable use of its products. The
ICCA High Production Volume (HPV) Chemicals Initiative is aimed at producing an
internationally agreed and harmonised data and information package, which will be made
publicly available.
It is ICCA's clear view that risk management measures have to be based on a sound
scientific risk assessment, as the key principle. Any risk reduction measures only based
on intrinsic properties are not justifiable, and therefore not acceptable to industry. A
science based, precautionary approach to risk management is fundamental to our health,
safety and environmental protection efforts and should guide application of Principle # 15
of the Rio Declaration. ICCA, through Responsible Care , encourages companies to work
towards characterising products with respect to their hazards and their risks and, in
concert with their customers, taking appropriate risk management actions.
Via ICCA, the chemical industry has launched its Long Range Research Initiative (LRI)
to contribute to the improvement of scientific knowledge in environmental and human
health and also to the further improvement of risk assessment. In this context, 18 LRI
projects were initiated in 2000. It is ICCA's belief that LRI will also contribute to an
enhancement of the reputation of the industry in line with Responsible Care .
The Round-Table Meeting of Ministers and industry leaders in Stockholm in January
1996, (so-called "Stockholm statement") acknowledged the need for a co-operative
approach to international management of chemicals that focuses on identifying,
understanding and systematically reducing risks associated with chemicals based on the
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application of sound scientific principles, common rules and harmonised methods and
criteria.
The member associations of the ICCA and the companies that they represent are
committed to improving and extending the quality of their communication with the public
and other concerned parties. The chemical industry sees this communication process as a
cornerstone between risk assessment and risk acceptance and is committed to continuous
improvement of sound product stewardship and chemicals management to ensure the safe
use of chemicals.
The following brief summary reflects ICCA’s view of the priority items in Chapter 19,
Agenda 21, and the industry’s contribution to achieving the goals of Chapter 19.
Detailed information is presented in the papers attached to this document.
Programme Area A
Expanding and Accelerating International Assessment of Chemical Risks
Programme Area A plays a crucial role in and is a fundamental element of Chapter 19
according to its close linkages to other Programme Areas like Area B, C and D.
It is through this that countries will elaborate data and information necessary for
assessing chemicals and to set up the basis for the exchange of information. Furthermore,
countries will establish the processes and standards by which they will judge chemicals
warrant global attention and the risk posed by those chemicals.
The involvement of industry in existing national and international programmes in
providing data for an internationally acceptable risk assessment is key to the fulfilment of
Programme Area A.
In ICCA’s view, there are three main areas which need to be developed further under
Programme Area A:
1. strengthening co-ordination and co-operation between governments and regional
and
international organisations and fora;
2. improving the current data base of existing chemicals and making the information
publicly available;
3. developing principles for mutual recognition of assessments on chemicals worldwide.
Co-ordination and mutual recognition should be focused on an internationally acceptable
risk assessment of chemicals in order to achieve a sound scientific basis for selection of
risk management options at the national, regional or international level, including
developing countries. This would also lead to recognition of the broad range of chemical
assessments being undertaken at an international level.
Co-ordination and co-operation between all committed stakeholders is also necessary for
developing commonly agreed criteria and procedures for:
 internationally acceptable risk assessment;
 selection of the most efficient risk management options;
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
mechanism for implementing risk management measures at a regional or
international level.
At its Board of Directors Meeting in Prague in early October 1998, ICCA established a
framework for a series of major actions and a programme to develop further its cooperation with international authorities. Part of this framework is the ICCA global
initiative on High Production Volume (HPV) Chemicals.
The goal of this initiative is to prepare harmonised, internationally agreed data sets and
initial hazard assessments under the Screening Information Data Set (SIDS) Programme
of the OECD (Organisation for Economic Co-operation and Development). The
improvement of the current data base of approximately 1,000 HPV chemicals based on
information gathering and validation, and where necessary by additional testing until the
end of 2004 is the key element of this programme and has to be considered as the first
step under this initiative.
In regard to the mutual recognition of assessments on new chemicals, industry proposed a
vision to the February 1998 OECD Chemicals Committee Joint Meeting, namely that
OECD member countries mutually accept new chemicals notification decisions from all
other member states by the year 2005 as a first step. This procedure would be
implemented and controlled through trade agreements.
Moving towards mutual recognition of notification decisions could be done in a step-wise
procedure:
In conclusion, it is industry’s strong belief that there are means to strengthen and
accelerate assessment of chemical risks in a manner consistent with both the spirit and
direction of Chapter 19.
Programme Area B
Harmonisation of Classification and Labelling
ICCA strongly supports and actively contributes to Governmental, Inter-Governmental
and NGO work in the field of the Harmonisation of Classification and Hazard
Communication of chemical substances and preparations.
The harmonisation of classification systems should reflect and be based on the most upto-date scientific knowledge and principles, in order to gain world-wide acceptance of
harmonised classification criteria. Existing data collected in accordance with such
harmonised criteria and methods should be accepted. To provide demonstrable benefit to
all concerned parties, harmonisation should involve a balanced approach which would
minimise the reclassification of existing substances and preparations and take into
account the significant downstream effects of hazard classification on existing regulatory
requirements.
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A harmonised system for the classification of chemicals is necessary to ensure
consistency of hazard information and the provision of safe handling and use advice on
chemical products. Any initiative resulting in the removal of existing ambiguities and
inconsistencies in hazard communication has the full support of ICCA.
A uniform global system will also assist developing countries to obtain relevant and
compatible information on chemicals, which will aid the fulfilment of the objectives of
Programme Area C.
If the goals of Chapter 19 of Agenda 21 are to be achieved, there should also be a
commitment from countries with existing systems to adopt the Globally Harmonised
System (GHS) within an agreed timeframe. It is equally important to ensure that there is
consistency of application of the agreed methods and criteria to substances and
preparations in existing expertly classified systems and databases.
Industry has endeavoured to play an active and constructive role in the development of
Programme Area B. It is important that industry is allowed to continue with this proactive role. Therefore, in the implementation of the GHS, provision must be made for
industry to be able to participate fully and effectively. This needs to recognise that
industry has a global dimension with differing views and opinions in the same way as
governments have. For industry to be able to participate effectively, its representation in
the implementing body must reflect its geographical spread.
Programme Area C
Information Exchange on Toxic Chemicals and Chemical Risks
ICCA supports programmes to ensure that governments have the information necessary
to provide for protection of health and the environment against risks associated with
chemicals. Much information is already developed and provided by industry, such as
Material Safety Data Sheets (MSDS), and labelling of products. Industry has also
elaborated a wealth of data and information under existing chemicals assessment
programmes. Substantial work has already been done and remains necessary under the
OECD HPV chemicals programme (which will be accelerated by the ICCA High
Production Volume Chemicals Initiative). All this information is or will be made
available globally via the International Programme on Chemical Safety (IPCS), the
United Nations Environment Programme (UNEP), the Food and Agriculture Organisation
(FAO) or by industry itself.
Pollutant Release and Transfer Register (PRTR) programmes provide information on
releases of substances to the environment and on offsite transfers of the substances for
final disposal. These emission inventory programmes - which can be either government
or industry initiatives - collect a range of information on substances on a regular basis to
allow tracking progress over time.
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ICCA supports emission reporting, believing that these programmes can provide valuable
information that can help document and stimulate reduction in emissions from production
and processing sites and communicate information to key audiences. All ICCA members
support the reporting provisions of Responsible Care
worked closely with governments to develop national emission reporting programmes.
These programmes vary considerably and there are ways to improve them, but the basic
concept and guiding principles of the programmes are sound.
The value of a well-designed emission-reporting programme is that it provides useful
information that increases awareness about emissions. Industry gains knowledge needed
to document and stimulate emissions reduction. Governments gain awareness and
understanding about national, regional and local emissions. The public gains awareness
about emissions in their communities. Emission reporting programmes should be
effective, manageable and concentrate on reporting requirements that provide real
benefits without imposing unnecessary costs on government, industry and society as a
whole.
The global chemical industry, through ICCA, welcomes the Rotterdam Convention on
the Trade in Hazardous Chemicals also known as "PIC Convention" .
The Rotterdam Convention is a legally binding instrument replacing the present
voluntary PIC scheme in which some 145 countries participate. It is a means for formally
obtaining and disseminating the decisions of importing countries as to whether they wish
to receive future shipments of chemicals banned or severely restricted by governments of
countries participating in the scheme.
The chemical industry is particularly pleased with the clear definitions, the maintenance
of the existing scope, the risk-based approach and the transparent procedure that have
been agreed upon. Since the Convention corresponds to a large degree with the scope and
obligations of the voluntary PIC procedure, ICCA hopes that this will ensure a broad
participation in the scheme.
ICCA considers that the PIC Convention constitutes a very useful element in the safe
management of chemicals, especially in developing countries, but has all along stressed
that it cannot substitute for an effective national chemical regulatory programme.
In ICCA’s view, there is also a need to develop more effective means to communicate in
an open and transparent process with stakeholders and the public. The communication
process should be used to provide information not just on chemicals and risks, but also on
any industry initiative or action related to the sound management of chemicals.
Programme Area D
Establishment of Risk Reduction Programmes
The "Stockholm" statement has acknowledged that risk management includes a range of
risk reduction measures, from product information to legally binding use restrictions.
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Risk reduction measures can be implemented on the basis of non-regulatory and/or
regulatory instruments. It is ICCA’s view that non-regulatory, voluntary mechanisms such as Responsible Care - have a proven role in reducing risks, without the high costs
of a strict government regulatory regime.
The chemical industry’s commitment to Responsible Care requires a continuous
improvement in the reduction of health, safety and environmental risk that may be posed
by its products. This is achieved by establishing Product Stewardship programmes. The
fundamental feature of Product Stewardship is its emphasis on managing the entire risk
of products throughout their life-cycle, rather than on manufacturing and specific siterelated issues.
Based on Product Stewardship, which is Responsible Care applied to products, ICCA
associations and their member companies are involved with a number of voluntary risk
reduction initiatives, including global dissemination of the chemical industry’s
developing and applying leading-edge technology to increase efficient use of resources
and reduce environmental impact, as they invest in new chemicals facilities in developing
as well as developed nations.
The global chemical industry has supported the development of a Convention on
Persistent Organic Pollutants (POPs) throughout the process of its negotiation. This has
included participation in the development of UNEP Governing Council Decision 19/13c
and the subsequent negotiating process until the Convention’s finalisation on 10
December 2000. ICCA's support for the development of a POPs Treaty is consistent with
the chemical industry's commitments to Responsible Care.
The POPs Treaty needs to be workable and based on science. It needs to promote actions
that are feasible, and that will lead to realistic and meaningful levels of environmental
improvement. Much progress has been made by Governments of the world in developing
a Convention consistent with these objectives, all of which are supported by the chemical
industry.
To ensure that this instrument contributes to the reduction and/or elimination of risk
without imposing unnecessary social or economic consequences, harmonised criteria and
procedure should be used to identify POPs pollutants. The POPs criteria should be based
on risk-and risk reduction measures, and be the least restrictive necessary to reduce the
specific risk.
In its position paper "Principles for Risk-Based Decision-Making" ICCA has laid down
key elements and principles for sound scientific risk-based management of chemical
products. This also includes the application of the Precautionary Principle embodied in
Principle 15 of the Rio Declaration, which provides for cost-effective measures to
prevent health and environmental degradation, where the weight of plausible scientific
evidence establishes that serious or irreversible damage to health or the environment is
likely to be caused by the activity or chemical in question. ICCA also supports paragraph
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44 of Chapter 19 of Agenda 21, which calls for a wide range of risk management options
for sound chemicals management, including consideration of bans or phase-outs of a
particular application of a particular chemical, when risks are unreasonable and otherwise
unmanageable. This applies not only to POPs, but to all chemicals.
Programme Area E
Strengthening of National Capabilities and Capacities for Management of
Chemicals
ICCA associations and their member companies are aiding countries by advancing
industry safety, health and environmental practices through global implementation of
Responsible Care
around the globe, providing manpower and financial resources for education, training,
etc. ICCA has also provided manpower and financial resources to allow the UNEP
Actions Programme for Emergencies at the Local Level (APELL) to mobilise country
resources to prevent accidents which may result from chemical manufacturing operations.
This programme has significantly enhanced national accident prevention efforts.
The American Chemistry Council (ACC), in consultation with other ICCA associations,
has also developed a Guidance Package for the Sound Management of Chemicals to
promote greater understanding regarding the assessment and use of chemicals, and to
encourage sound regulations where needed.
Industry also supports the United Nations Institute for Training and Research (UNITAR)
activities in developing National Profiles as the main basis for capacity building in
developing countries, and the UNEP awareness - raising activities on POPs in the regions
of the world.
A number of member companies of ICCA associations are providing resources to
national or regional projects in capacity building of various OECD member countries or
countries with economies in transition.
In principle, the global chemical industry, working through the ICCA, is prepared to
further promote and to support capacity building activities in developing countries and
countries with economies in transition such as:
 training programmes for regulatory authorities and local chemical industry with
focus on chemical safety;
 developing chemical safety information instruction tools and producing guidance
tools for the safe handling of chemicals;
 making available experienced advisors to help countries to develop National
Chemical Safety Programmes;
 developing programmes in line with Product Stewardship principles in
collaboration with national chemical federations and public authorities.
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Programme Area F
Prevention of Illegal International Traffic in Toxic and Dangerous Products
Industry, as represented by ICCA, the Global Crop Protection Federation (GCPF), and
the International Council on Metals and the Environment (ICME), is concerned about
illegal international traffic in toxic and dangerous products.
Industry supports the starting point for discussions as being the definition of illegal traffic
as contained in Programme Area F of Chapter 19, viz. "Illegal traffic refers to traffic that
is carried out in contravention of a country's laws or relevant international legal
instruments." This part of the definition is very clear, in that it refers to existing national
legislation and relevant international conventions, such as the Rotterdam Convention.
The industry supports this as the basis for consideration of activities related to "illegal
international traffic".
However, industry believes that there is a need for further discussion and clarification
related to the definition of terms like "compliance" and "enforcement".
The participants in the UNEP Workshop on Enforcement and Compliance with
Multilateral Environment Agreements (MEAs) in July 1999 agreed broadly that the
concept of compliance dealt with states' obligations under MEAs and whether they were
fulfilling them, whereas enforcement referred to the actions that states undertook within
their national territories. Industry recommends that these definitions be adopted as the
framework for discussions on illegal international traffic.
Finally, industry supports the recommendations given in I.2 of IFCS/Forum III/10w to
obtain further information regarding the nature and scope of the problem. We believe that
these recommendations are the first step towards achieving the desired results from
recommendations 19.69 - 19.74 of Chapter 19, regarding activities to be undertaken by
governments, regional commissions and international organisations related to the issue of
illegal international traffic. However, the focus should remain on assessment, as is
described in the subject paper, and an ad hoc working group, if created, should be
disbanded ("sunset") at the conclusion of the assessment.
The industry is willing to co-operate with the IOMC, as appropriate, to facilitate the
assessment process outlined.
Global Benefits of Chemicals
The chemical industry is one of the basic industries, consisting of diverse companies that
transform raw materials and intermediate chemicals through chemical reactions to make
products for consumers and other industries. From medicines to textiles to high-tech
electronics, chemicals are used to make the goods that improve everyday life.
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Most chemicals are useful and beneficial to mankind. From the basic "building block"
chemicals to the highly refined "speciality" chemicals, they advance the standard of
living and serve critical roles in the production of goods and the provision of services.
Most prescription and non-prescription pharmaceutical products are made by chemical
synthesis; even products derived from natural sources and fossil and renewable energies
require chemicals in their isolation, purification and preparation.
Chemicals play an indispensable role in modern health care products: surgical sutures,
equipment, and sterile gowns; X-ray and mammography films; cleaning and sterilising
preparations; sterile packaging, gauze and dressings; and electronic instruments.
Chemicals also play a critical role in boosting crop yields through the use of fertilisers,
herbicides, and pesticides. Beyond the farm, chemicals reduce food spoilage and extend
shelf life through sterilising agents, preservatives and packaging.
Products of the chemical industry make modern homes safer and more comfortable,
durable and energy efficient - from paints and varnishes to insulating materials, sealants
and caulk, casings for windows and doors, carpets, countertops, plumbing pipes and
equipment, roofs and electrical insulation and fixtures.
Chemistry makes possible the synthetic fibres that are fulfilling more of the world’s
clothing needs. In addition, dyes and fabric treatments are the products of chemistry.
Computers, calculators and other electronic equipment could not be made without the use
of chemicals in making microprocessors, circuit boards, and compact discs.
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