Public Affairs in times of the Chemicals Strategy for Sustainability

RP Comments
Jun 20, 2022, 02:29 PM

Salvatore Ricci, Consultant at Rud Pedersen Public Affairs, gave us his review of Public Affairs in times of the Chemicals Strategy for Sustainability - and how there is more to it than meets the eye!

On what was one of those Brussels’ grey and rainy Sundays, I decided to sit down and take stock of these past amazing months in Public Affairs.

The peak was definitely reached this week when I attended a workshop in Amsterdam with professionals, among which also scientists and regulatory experts, from an international chemical company.

The passionate and intriguing discussions that we had there reminded me of why I love what I do. Although the discussions around the Chemicals Strategy for Sustainability (CSS) are (fortunately - as science plays a big role!) rather technical and complex, they hide wider political discussions that our society will be called to answer sooner than later. For political scientists like me, catching the broader political/social impact of technical discussions is our warm milk.

For those who are currently part of, are following or are just interested in the EU CSS, here there are three thoughts that I pulled down after months of working in this field.

1. Is "safety" enough to address a "political concern"?

After a few hours of discussions in Amsterdam, one of the chemists attending the workshop addressed a question to the overall group asking, along the line, “are we actually trying to address the safety of this substance or the overall concern that the politics has created?”. This got me thinking.
The CSS is aiming to create a new EU definition for “substances of concern”. As already unveiled by the proposal for ESPR and the Taxonomy Delegated Act, a substance of concern is a substance that, among others, presents a list of intrinsic hazard properties (e.g. CMR, EDs, PBT, PMT etc). According to the Strategy, the use of the substances with those properties will be “minimised and substituted as far as possible”. The CSS says that this should happen without considerations on the risk of these properties to actually cause harm - what we call an "hazard-based approach".

In this context, it is totally legitimate that scientists and experts introduce to the debate science-based studies to prove the safety of using a certain substance. However, this does not seem to suffice in the current discussions.
Playing back to what the scientist above asked, a political/societal concern could run much deeper than "demonstrating safety". A concern is something that makes someone worried, anxious. Worry and anxiety are two emotions that cannot always be dealt with at a “rational level”. Despite how much "facts" and "data" you bring to the table, someone could still be worried. And, worry could lead anyone to overreact.

And to even strengthen the existing intrinsic difference between safety and concern, someone else at the workshop asked: why nobody talks about this substance which is use is not safe at all? Again, safety and concern do not go hand by hand. Concern is about perception.

These questions raised by the participants seemed so pertinent. At this stage though, there is a real risk of “emptying” scientific knowledge in favour of overreaction which brings me to the second point.

2. Science/Expertise and Political concern in the CSS: where is the balance?

The question on how do you balance expertise, politics and democracy is as old as philosophy itself. In a much less complicated world, Plato already claimed that rulers should be philosopher-kings because of own knowledge.

When it comes to the CSS, there is an actual risk of “banalisation” of scientific expertise and knowledge in favour of a general approach raising from a political concern. During my months of working in this field, I have listened to the frustration of scientists for not being heard. I have also heard experts saying that some of the CSS goals are based on “narrative” rather than “science”. Couldn’t agree more with their frustration, I would too if my technical knowledge was ignored or even banalised.

This trend also matches something that we see in other complex fields. Thus, my question here is: how do we make sure that the society, which does not have the knowledge to understand such topics for obvious reasons, could express itself on such technical topics without oversimplifying them?

If I have learnt something from working in this field is that the risk of oversimplification is very high. Substances’ applications are difficult to track, and restrictions on some uses may have serious impacts on complex supply-chains that experts may not even be aware of. Yet, there is a need to address a concern.

In all of this, a balance will need to be struck between technical knowledge and political decisions. A first step should definitely be to equip the society with more knowledge to fill in the current level of “unknown” which leaves room for manipulation.

3. Concern goes hand-in-hand with “unknown”, the more someone doesn’t understand something, the more they will be concerned.

I myself grow with the understanding that “chemical” equals "bad". There is even an expression in my dialect (from my lovely hometown of 5.000 people in the south of Italy) saying something along the line of “that’s chemical!” to indicate that the thing we are talking about it’s bad for your health. This surely comes from the fact that there is a level of “unknown” among the population around what a chemical does and what it is used for.

This is a dangerous field as people who do not understand something tend to be an easy target for manipulation. Concern can raise worry, for some people even anxiety. The result is that you can tend to forget what the science says. This can go both ways, and we have experienced it recently with Covid.

From a public affairs point of view, these are exciting times and challenges to work on in my opinion! Surely, there is a need in the upcoming months to inform the society on what we are talking about when the CSS related reforms are out for discussions in the European Parliament.

A level of informal agreement among all different actors will be needed to avoid the manipulation of people’ emotions while remaining as close as possible to the science.

Let’s keep in mind that chemicals are not the “bad thing” I have been thought. They will be crucial to achieve many of the EU’s political goals. Decarbonisation? Technology? Digital? It’s all about chemicals!