On 8th April (not 1st April) Austria registered their intention to deal with the classification of peanut butter under the biocides regulation.
There are clearly some Member States with a lot of time on their hands to classify chemical substances.
If the Regulators are looking for more substances, I’d draw their attention to a helpful and very long list of substances linked to cancer and other harmful health effects produced by Edith Efron from 1985.
Here are some examples
Group 1: Essential Elements for Life
Here are the elements required for life for animals and animals (including humans).
Basic building blocks
Hydrogen
Carbon
Nitrogen
Oxygen
Macronutrients
Sodium
Magnesium
Phosphorus
Sulfur
Chlorine
Calcium
Potassium
Trace elements
Cobalt
Copper
Chromium
Oxygen
Fluorine
Iodine
Iron (for species requiring hemoglobin)
Manganese
Molybdenum
Chlorine
Nickel
Selenium
Silicon
Tin
Vanadium
Zinc
9 – in bold – were (in 1985) were reported to be carcinogenic.
Some more examples 2- Food and Drink
Efron lists a lot more.
The caffeine in my coffee has been reported to be mutagenic or to impair chromosomes.
The tea I like has tannin that’s been reported to be a carcinogen.
Some of the spices I like, ginger, cinnamon and black pepper contains safrole which is reported to be carcinogen
Some of the fruits I like, including dates, strawberries, blackberries and cherries contain coumarin. It is reported to be a carcinogen.
Peanut butter (after you open the jar and expose it to air) contains malondialdehyde has been reported to be carcinogen and a mutagenic.
Carrots, soybean, wheat, rice, oats, barley, potatoes, apples, cherries, plums, wheat bran, wheat germ, rice bran, olive oil, coconut oil, all contain compounds that produce estrongenic responses in experimental animals.
Cooked garlic and onions are mutagenic.
Some more examples 3 – Human Body
The human body produces a lot of nasty substances.
Cholesterol is reported to be carcinogenic.
Our blood contains acetaldeyde from the digestion of sugar. It is reported to be mutagenic. You’ll find nitrosamines are found in the blood after eating food.
Insulin is reported to be carcinogenic.
Sex hormones – estradiol, progesterone and testosterone – are reported to be carcinogenic.
Smega is reported to be carcinogenic.
Sperm may cause testicle and prostate cancer.
Mother’s milk contains lactose – milk sugar. It is reported to be carcinogenic.
How to Manage
As Efron observes “If these extraordinary data are valid, they tell us that in some ungraspable way the entire universe is implicated in the disease that is known as cancer” (p.177).
It would not matter if the classification of a substance – natural or man made – the hazard identification were compartmentalised. Then, and only then would a risk assessment be performed, and then, and only then, would risk management measures be performed.
If I were to get rid of everything that may have an intrinsic hazard my diet for one would be blander than it already is.
A Challenge for Commissioners
As the European legislator (and others) have chosen to apply – in a limited number of areas, a semi-automatic bans on the use of a substances after their classification, European Commissioners will continue to wake up and find out they have (often unknowingly) banned something, whatever the risk. Often, those same Commissioners will have no mechanism to mitigate or stop the ban, or be deterred from doing so.
The reputational harm that this may cause the European Union seems to matter not. That some of these measures will provide sustenance to those political interests who are against the EU is treated as a non-issue.
That legislators did not add in an emergency brake consistently across all downstream legislation, is something for a brave PhD student to work out the reasoning why. Why European officials don’t mix the system is another mystery that the could be answered.