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The following comments are submitted on behalf of the Competitive Enterprise Institute, a free market policy group located in Washington, D.C. Submitted along with these comments is a CEI paper on Organization for Economic Cooperation and Development’s (OECD) attempt to employ the EU chemicals policy.
We find that the proposed European Union (EU) chemicals policy is unlikely to generate benefits, and that it is likely to harm public health and well-being. It is it unlikely to produce benefits because it focuses on very low-level and questionable risks rather than substantial public health challenges. It is dangerous because it would divert resources from serious problems and will undercut the benefits of a free society by limiting economic growth. European consumers and others around the world will suffer higher prices and reduced access to consumer goods, many of which provide vital public health benefits. In particular, individuals suffering from poverty in the developing world will be hardest hit as the chemicals policy diverts resources and attention from the world’s most serious health problems.
Advocates of the chemicals policy suggest that they can improve public health via a chemical registration and research policy. They contend that additional study will enable policymakers to prevent the introduction of new “dangerous” chemicals and force the elimination of existing “dangerous” chemicals. Supporters of this approach assume incentives for companies to ensure the safety of their products are lacking, and hence the public currently faces grave risks.
Neither of these assumptions makes sense. Firms clearly have incentives to study chemicals to ensure safety for their customers. After all, they want repeat customers, and they don’t want lawsuits alleging harm. In addition, existing regulations mandate considerable research, and both public and private scientific groups add to that body of research. None of these groups have the incentive to over-invest in cases where the data indicate that risks are apparently quite low. Governments, on the other hand, can mandate such research based on shortsighted, politically driven views about the perception of risk. But policymakers should seriously consider whether any substantial benefits will flow from directing considerably more resources to such studies or whether limiting access to chemicals will improve—or worsen—public well being.
In a world of limited resources, public officials should take care not to divert those resources away from addressing serious risks toward tackling low-level risks. And they should take care not to devote those resources to policies that could prove harmful. Unfortunately, the EU chemicals policy represents a move in the wrong direction. While we may not know all the particulars of every chemical on earth, science shows that low-level environmental exposures to chemicals has not had a substantial impact on cancer rates nor proven to aversely impact the human endocrine system. As a result, expending resources in an attempt to discover minute, and largely theoretical, cancer risks will only divert resources away from more vital needs and adversely impact economic growth. In addition, the EU policy threatens to deprive consumer access to chemical products that produce important benefits. We already are seeing cases in which misguided allegedly “precautionary” approaches are proving deadly, particularly to people in the developing world. The EU chemicals policy simply promises to expand such failed approaches.