What does the Environmental Improvement Plan mean for chemical pollution?


The recently published Environmental Improvement Plan 2023 outlines the UK’s updated plans for restoring and protecting our natural world. Here, we take a look at what this means for chemical pollution, what victories have been achieved and what work is still left to do.

What is the Environmental Improvement Plan?

In 2018, the UK Government published its 25 Year Environment Plan (25YEP) (1). The document set out the government’s plans to nurse our natural environment back to health over the next quarter of a century. One of the commitments made was for the plan to be refreshed every 5 years; the Environmental Improvement Plan (EIP) 2023 is the first of these refreshes. The EIP aims to build on the existing vision set out in the 25YEP, review progress towards targets and update an on-going action plan (2).

What is the UK Chemicals Strategy?

One of the biggest revelations announced within the EIP, was confirmation that the UK Chemicals Strategy will be published this year. Development of a UK Chemicals Strategy was set out within the 25YEP but has been subject to numerous delays following BREXIT and the Covid-19 pandemic. The strategy should set out the government’s approach to chemicals management post-BREXIT and work towards the 25YEP goal of managing environmental pressures by “managing exposure to chemicals”.

Concerns around chemical pollution and its impacts on human and environmental health have continued to intensify since publication of the 25YEP. In 2019, the United Nations recognised pollution as one of the 5 main drivers of biodiversity loss (3). In January 2022, scientists warned that we had already crossed the planetary boundary for chemical pollution, and in May 2022 the Lancet Commission’s latest report attributed 1 in 6 deaths worldwide to pollution (4; 5). With increasing international pressure to turn the tide on chemical pollution, the UK Chemicals Strategy offers a once in a generation opportunity to set new standards and make meaningful progress towards restoring our natural environment.

What does the EIP say about tackling Chemical Pollution?

In 2021, Fidra, alongside other health and environmental NGOs, produced 12 Key Asks for the UK Chemicals Strategy, outlining our priorities to achieve effective health and environmental protection. Although not all 12 are bound in commitments, we’re pleased to see a number of our asks reflected under the EIP’s updated plan for “Managing exposure to chemicals and pesticides”. To help summarise, we’ve compared our highlights from the EIP alongside our 12 Key Asks below.


Our Ask: 1. Apply the precautionary principle.

What the EIP says: The Environment Act 2021 required the government to develop an environmental principles policy statement which aims to ensure environmental protection is considered within policy making. The precautionary principle, a principle that allows decision-makers to adopt precautionary measures to protect human health and the environment in the absence of full evidence, forms part of this statement.

When referring to the development of the Chemicals Strategy, the EIP states that there will be an adherence “to the environmental principles policy statement enshrined in the Environment Act.” Whilst this is promising, it is also worth noting that the precautionary principle, and other principles set out in the policy statement, are caveated with “whilst supporting innovation and economic growth”.


Our Ask: 2. Phase out the most hazardous chemicals from consumer products for non-essential uses.

What the EIP says: An infographic used in the EIP refers to “banning or restricting the most harmful chemicals”. This is then mentioned again when referring to how the Chemicals Strategy plans to “continue to phase out the most harmful and persistent pollutants in favour of safer and more sustainable alternatives”.


Our Ask: 3. Plan to address endocrine disrupting chemicals including timelines to phase them out, 4. Phase out the use of PFAS and other very persistent chemicals & 6.
Address the combined exposure to chemicals – the ‘cocktail effect’.

What the EIP says: Under “Ensuring chemicals are safely used and managed”, Endocrine Disrupting Chemicals (EDCs), PFAS and chemical mixtures are addressed. The document states, “Through a Chemicals Strategy we will… set out our approach to managing priority and emerging chemicals of concern, such as Per- and Polyfluorinated Substances (PFAS),…Endocrine Disrupting Chemicals (EDCs),… and the combination effects that different chemicals can have on the environment.”


Our Ask: 8.
Ensure a clean circular economy with products that are safe by design.

What the EIP says: Chemicals and the circular economy were again introduced in an infographic, stating an intention to make sure “chemicals in waste are appropriately managed, to support the circular economy.”

Another action set under the Chemicals Strategy also refers to promoting “innovation to support the circular economy, drive the use of safer and sustainable chemicals and reduce the risks to human health and the environment caused by hazardous chemicals in waste.” Under “Monitoring and Evaluation”, preventing “harmful chemicals from being recycled” is listed as a key indicator for managing exposure to chemicals.


Our Ask: 9. Develop an effective monitoring and alert system.

What the EIP says:  Under ask 9 of the 12 Key Asks, we outline the need for wider screening methodologies to provide a more efficient alert system for emerging contaminants.

Again under action for the Chemicals Strategy, the EIP states ambitions to “develop monitoring methods to allow water bodies and other environments to be scanned for a broader range of chemicals beyond those already monitored.”


Our Ask: 10. Stop the continued accumulation of legacy chemicals in the environment

What the EIP says: Legacy pollution is mentioned at numerous points, largely in relation to managing residual Persistent Organic Pollutants (POPs) listed under the Stockholm Convention. In fact, the first subject tackled under the chemical management chapter aims to “reduce persistent organic pollutants (POPs) in the environment”. To meet this goal, the EIP lists a number of actions including, incineration of waste domestic seating expected to contain 1,200 tonnes of POPs in the form of flame retardants, preventing them from otherwise entering the environment through landfill; supporting management of “POPs contamination of carpet and automotives wastes”; and “initiating a programme of work to examine the levels of POPs occurring in construction and demolition waste”.


What’s Next?

There are lots of positives to be taken from the EIP, and a lot of potential for the upcoming Chemicals Strategy, but we are not out of the woods just yet. We now need to turn those promising words into action. We need the UK government to ensure ALL our asks are delivered. Our asks must translate into time-locked commitments, and for human and environmental health to be at the core of UK chemical policy.

We’ll be continuing to advocate our 12 Key Asks with decision-makers and watching progress closely. If you want to help protect against chemical pollution, why not share our 12 Asks with your local MP. To stay up-to-date, you can also follow us on Twitter and Facebook.

 

References

1. HM Government. A Green Future: Our 25 Year Plan to Improve the Environment. 2018.

2. HM Government. Environmental Improvement Plan 2023 – First revision of the 25 Year Environment Plan. 2023.

3. IPBES. The global assessment report on biodiversity and ecosystem services. 2019.

4. Outside the safe operating space of the planetary boundary for novel entities. Persson, L., Carney Almroth, B.M., Collins, C.D., Cornell, S., de Wit, C.A., Diamond, M.L., Fantke, P., Hassellöv, M., MacLeod, M., Ryberg, M.W. and Søgaard Jørgensen, P. s.l. : Environmental science & technology, 2022.

5. Pollution and health: a progress update. Fuller, R., Landrigan, P.J., Balakrishnan, K., Bathan, G., Bose-O’Reilly, S., Brauer, M., Caravanos, J., Chiles, T., Cohen, A., Corra, L. and Cropper, M. s.l. : The Lancet Planetary Health., 2022.