talking about chemicals with consumers“talking about chemicals with consumers: confidence through...

TALKING ABOUT CHEMICALSWITH CONSUMERS

A European joint initiative between A.I.S.E. and Cefic

European Chemical Industry Council

Stakeholders Workshop

CONFIDENCE THROUGH COMMUNICATION?

9 November 2004Proceedings

HERA Workshop– page [2] HERA Workshop– page [3]

Five years later, the project continues to build on its original aims. These were to demonstrate to regulators and the public that targeted risk assessments provide relevant safety information on detergents in a fast and effective way, and to make a useful and practical contribution to a risk-based approach for EU chemicals regulation.

HERA will assess more than 250 chemicals representing more than 90% of the total volume of ingredients used in household cleaning products in Europe. From the beginning, HERA adopted a way

of working that is unique. In addition to the targeted risk assessment approach, with one common review per substance, and bringing together all relevant experts to optimise the process, HERA is breaking new ground in terms of open dialogue with stakeholders and providing transparent results.

An External Advisory Panel contributes to the development of HERA by critically reviewing its risk assessments, as published on the web (www.heraproject.com).

In October 2001, HERA held its first stakeholder workshop on the scientific validity of the approach, followed in October 2002 with a meeting on the political relevance of HERA in the context of the new EU Chemicals Policy – REACH.

Now we are trying to address the needs of consumers. In November 2003, we held a workshop entitled “Talking about Chemicals with Consumers – the Language of Risk Communication”. And very much following on and building on that theme, we now host our fourth European Stakeholders’ Workshop: “Talking about Chemicals with Consumers: Confidence through Communication?”.

At this point, we realize that HERA has pioneered several new approaches that have lasting value. HERA is probably the first example of the type of consortium that will be needed to obtain the best assessment of a chemical’s safety. In the context of REACH, the experience gathered from running risk assessments is likely to be highly valuable to many companies, particularly for small and medium enterprises.

It is also the first time that producers and users really got organized to pool all the relevant data thereby ensuring best safety knowledge about specific chemicals. We believe that this collaboration between producers and users could lead to a “HERA Code of Conduct”, providing a model of cooperation for other industries.

Finally, HERA has shown the value of open communication about chemical safety, and particularly how full cooperation between producers and users of chemicals can provide critical and complementary insights regarding communication.

Claude Mancel,Chairman of the HERA Sponsors Committee

In 1999, European household detergent manufacturers got together with their chemical suppliers to see if they could jointly develop a way of assessing risks to human health and the environment associated with the use of cleaning products. The Human and Environmental Risk Assessment (HERA) project, involving the European Chemical Industry Council (Cefic) and the International Association for Soaps, Detergents and Maintenance Products (A.I.S.E.), was born.

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INTRODUCTION


TALKING ABOUT CHEMICALS WITH CONSUMERS – CONFIDENCE THROUGH COMMUNICATION?

T HE FOUR T H HER A WOR K S HOPQUESTIONS FOR THE DAY ......................................................................5

THE MODERATOR’S VIEW ON THE WORKSHOP ......................................6

P L EN A RY PRE S EN TAT ION SRISK ASSESSMENT PARADIGM ................................................................9J.F.Solbé, Unilever Home & Personal Care Europe

PROBLEMS OF RISK COMMUNICATION ................................................. 10Adam Burgess, Professor of Sociology, University of Kent

RESULTS OF THE EUROBAROMETER SURVEY ON RISK PERCEPTION ........ 11Panagiotis Daskaleros, European Commission –DG Health & Consumer Protection

"10 REASONS NOT TO JOIN THE GARDEN CLUB" ................................. 12Franklin Apfel, World Health Communication Associates

THE ACTIVITIES OF THE JOINT RESEARCH CENTRE ................................. 13Demosthenes Papameletiou, Joint Research Centre

ENGAGING WITH THE TRADE ............................................................... 14Sheila Kirkwood, Head of Technical Services, McBride

TESTIMONIAL FROM THE COSMETICS INDUSTRY ................................... 15Walter Aulmann, Head of Human Safety Assessment Dept, Schwarzkopf-Henkel

TESTIMONIAL FROM THE AUTOMOTIVE INDUSTRY ................................. 17Urban Wass, Head of Environment and Chemistry Dept, Volvo

TESTIMONIAL FROM THE FOOD INDUSTRY ............................................ 19Yasmine Motarjemi, Corporate Food Safety Manager, Nestlé

PA NE L PRE S EN TAT ION S & DIS CU S SION SPANEL 1: PRODUCT INFORMATION AND LABELLING .................................. 20

PANEL 2: OTHER BRAND, COMPANY AND ORGANISATIONAL TOOLS ....... 22

PANEL 3: CAMPAIGNS AND JOINT COMMUNICATION PROGRAMMES .... 24

CONCL UDING RE M A R K SSAFETY, CONFIDENCE AND SOCIETY: FINAL REMARKS ......................... 26Phillip Whitehead, MEP, Chairman Committee on Internal Market & Consumer Protection TH

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CONTENT


E X HIBI T IONSUMMARY OF EXHIBITS ......................................................................... 27

CL E A N HOU S E , S A FE HOMEHERA’S APPROACH TO COMMUNICATE RISK TO CONSUMERS ..............30

CONCL U SION SCONCLUSIONS ..................................................................................... 31

A NNE X E STHE HERA PROJECT ............................................................................... 34

THE WORKSHOP AGENDA .................................................................... 37

WORKSHOP REGISTRATIONS ................................................................ 39

PRESENTATIONS AVAILABLE ON REQUEST ............................................ 43

LIST OF SPEAKERS AND EXHIBITS ...........................................................45

The content of this document has been prepared and reviewed on behalf of HERA with all possible care. It is provided for information only. HERA cannot accept any responsibility or liability and does not provide a warranty for any use or interpretation of the material contained in this publication.

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SETTING THE SCENE

The 2004 HERA Stakeholders Workshop – ”Talking about Chemicals with Consumers; Confidence through Communication?” – brought together over 100 representatives from the European Commission, European Parliament, Member States, NGOs and industry.

Continuing the theme of 2003’s successful workshop – “Talking about Chemicals with Consumers; the Language of Risk Communication” – the aim this year was to build further understanding, as how to talk about risks with the public based on the different testimonials and discussions.

The workshop addressed several key questions, such as:

- What more have we learned about communicating with consumers to achieve confidence in chemicals?

- What tools work and how should they be used?

- What role has HERA to play in this process?

Speakers came from a wide range of backgrounds…from university sociologists, to healthcare specialists, from the EU institutions, industry, and consumer and environmental organisations. In addition, speakers from other industries provided valuable insights into their experiences of human behaviour, risk perception and communicating risk management.

This booklet provides an overview of presentations, panel discussions and comments made during the meeting. A similar publication is available covering the 2003 workshop.

Thank you to Christine Drury, who moderated the workshop, to the speakers for their valuable contributions as well as to all rapporteurs and subgroup moderators who contributed to the success of this event.

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Christine Drury, Workshop Moderator

Valuable dialogue role for HERA on how to improve risk communicationThis was the fourth HERA workshop and the second on risk communication, particularly to the consumer, a subject which should be a central issue for the EU Policy on the management of chemicals, known as REACH. Industry, the European Parliament and Commission, consumer and environmental groups and academia shared knowledge on how current communication is received by the public and what is needed for the future. There was agreement on the common goal of increasing consumer confidence in products by helpful communication on the chemicals they contain. Risk assessment information from other parts of the HERA programme and other initiatives across the chemical and user industries provide a timely focus for this goal.

“PEC is what birds do - Just tell me: am I safe? Is my family safe?”The workshop had a lively reminder that communicators always need to have a clear understanding of the right language for each audience. The language of risk assessment (“PEC (Predicted Environmental Concentration), TGD, Margin of Safety, EUSES…”) is wholly appropriate for an audience of risk assessment experts but consumers expect to hear risk communication about household products expressed simply in everyday language, even though this may be difficult to do. The language of risk assessment must be tailored sensitively to the intended audience.

Beware of risk communication becoming an inward looking "industry" Risk regulations multiply and authorities and industry are coordinating established methodologies to assess and communicate risk. But is this process of communication becoming more important than the content? And how strong is the public demand for risk communication? Are institutions in danger of addressing a “phantom public” of consumers they perceive to be living in a “sea of troubles” and of seeing risks where none exist in the public realm? This challenging view is a useful reminder to listen well to how consumers actually perceive risk.

Risk communication should always attempt to address concerns in an adult mannerA more optimistic view of communication emphasises the empowerment and well being that comes from embracing and managing risk in daily life. This is literally a personally healthier outcome. It is better than feeling dependent on others to eliminate risk. Following this approach, any fears that consumers have are best answered with rational explanations, avoiding emotion, about WHAT risks are, WHEN they present a problem and HOW society can minimise risk.

Consumers ignore safety labelling: is this great confidence or poor labelling?Many consumers say they buy detergents, household cleaners, cosmetics and paints without paying attention to safety labelling. Labels on paints get slightly more attention; those on cosmetics rather less. Consumers explain they are confident that they know how to use their brand, and expect companies to make safe products. Warning symbols on packaging are not well understood, the diagonal cross for “Irritant” being the least comprehensible. Figurative symbols are better understood.

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Opportunity to focus on the communication effectiveness of labelling The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) that is now being implemented will introduce another set of pictogram symbols. This labelling needs to work well independently of language and culture. The GHS is an opportunity to take action to improve labels so that they communicate better to consumers.

Part of a portfolio of communication activities, giving many sources of information Empowering consumers to manage risk means being able to give answers to: “What do I do if…?” questions. Consumers need to know where to find information: calling a phone number, or asking at their supermarket, or searching a website. Information from TV, or the independent guidance implied by an eco-label will be helpful to some people. There are now TV advertising programmes showing how to consume with greater awareness of the natural environment. Websites can also help teachers and schools programmes to equip the next generation to understand and manage risks ie education for longer term results.

The challenge of communicating the difference between hazard and riskScientifically “hazard” refers to the intrinsic properties of a chemical, whereas “risk” is the chance that harm will actually occur. If there is no exposure to a hazard there will be no risk. In the public, discussion about chemicals, risk and hazard are often confused, and all hazards are also perceived as risks. One of the challenges for risk communication is to make this distinction understandable.

Silent CommunicationRisk reduction measures are normal in all sectors; they pre-empt potential problems by controlling exposure, hazard or both but it is enlightening to think of them as forms of “silent risk communication”. Some sectors, where risk is focussed elsewhere, such as automotive, will find this easier to do than others like food, where public perceptions take over very quickly. There will always be a need to act in times of occasional trouble, but the emphasis of risk communication is on continuous management by both risk reduction measures and effective risk communication.

Facing the reality of some Risk management based primarily on perception UK retailers, but not necessarily those in other Member States, feel a strong need to respond to consumer demand, which is strongly influenced by pressure groups and the media, and they have to react in a very fast competitive environment. This results in a tendency to drive risk management by consumer perception rather than by scientific risk assessment. This is reinforced by the high level of consumer contacts through call centres. Environment risk management can even become a part of strategies for competitive advantage, as when retailers reformulate their products to avoid hazard labelling.

Moving forward to a proportionate precautionary principle It is helpful to have political decisions on REACH less focussed on zero risk. The real world is not zero-risk, therefore treating consumers as adults able to manage risk is a better approach. It is also practical: consumer expectations are that products are safe, but not entirely risk-free. In this context proportionate application of the precautionary principle could lead to better dialogue between legislators and industry and more progress on reducing the burden of risk from chemicals for man and the environment.

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This section presents an overview of the various speeches of the plenary session.

The contents, which have been prepared by a copywriter and approved by speakers, are based on presentations and discussions made during the workshop. Complementary Powerpoint presentations are available for speeches containing the sign. (see Annex 4 for full presentations available on request from the HERA secretariat).

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RISK ASSESSMENT PARADIGMJ.F. Solbé, Unilever Home & Personal Care Europe

In the heart of Brussels, at the Renaissance Hotel, Professor John Solbé, an authority on risk assessment steps up to the podium, paradigm in hand. The room hushes…

PROFESSOR SOLBE: “It is a great pleasure for me to describe environmental risk assessment procedures to you at the start of this workshop.

We are all members of the public, all consumers, and we all need to understand the background to risk assessment for our different purposes – to answer questions such as “Am I safe?” “Is my family safe?” “Is my environment safe?”

Of course, we all make many assumptions in our everyday lives. We assume that we live in a predictable world ruled by the laws of thermodynamics, forgetting that ours is, and always has been, a world full of kinetics, far from a state of equilibrium. Let me illustrate this with one of the well-known paradigms of the development of PEC/PNEC scenarios.

My hope is that by looking at the basics of one aspect of risk assessment we can develop a transparent approach, which must surely lead to an increase in consumer confidence in chemicals. Here is our basic step-sequence paradigm. Of course I have simplified it. You all know that the development of knowledge along the abscissa is more typically a continuum: but what is this graph hiding from us? Let’s rotate it through 90 degrees and look at this area of overlap…. As you can see I have left the lines of central tendency on the graph, and they will still apply. We are interested in the tails of the distributions of PEC in red and of PNEC in green. But I don’t want to confuse the audience…”

MARLEEN, “a delegate”: “EXCUSE ME! I am part of this audience and I am totally confused already. What is this all about? Aren’t we trying to gain the consumer’s confidence by explaining things to them clearly?

I’ve never heard so much jargon in so few seconds. PEC for me is something birds do – and what’s all this talk of paradigms? I might have a chance if you talked in parables. Dear Professor: Please understand that my world is one of buying products, using them to clean myself, my children and my home. I want to know the answers to the questions you asked at the start: “Am I safe?” “Is my family safe?” “Is my environment safe?” But I haven’t the least idea what

you are talking about and I just don’t see what it’s got to do with me as a member of the public…the things I buy, how I use them, and whether they are safe for my family and for Planet Earth.”

CHRISTINE DRURY: “And that’s exactly what we shall try to do in the rest of this Workshop. Thank you Marleen for leading us in the right direction. Thank you John for play-acting – even if we’ve had to drag you away from your pet subject!”

“PEC IS SOMETHING BIRDS DO!”

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PROBLEMS OF RISK COMMUNICATIONAdam Burgess, Professor of Sociology, University of Kent

A visitor from the past might guess that all risk assessments in every walk of life meant that the world had become a more dangerous place. But of course it hasn’t.

Risk assessment has become:

- Routine in that we do it all the time. We search for risk rather than respond to it.

- Routine in that we do it without thinking or questioning. It is never considered that risk assessments might institutionalise mistrust.

- Routine in that it is not a response to any clear demand in any meaningful sense. We are talking to a “phantom public” about “phantom risks”.

This routinisation of risk assessment has profound consequences:

1. The greater number of problems being communicated leads to what we can call a “sea of troubles”. In a “sea of troubles” its very hard to convey anything in a clear, still less a measured way.

2. Routinisation of risk assessment means that it tends towards becoming little more than content-less formal exercises, like “10 Commitments to Communication”. These “one size fits all” communication exercises are unlikely to be of any relevance.

3. A third, related problem, is that risk assessments can create an environment for the avoidance of actual issues. There is a tendency to shy away from necessary confrontation, waving the “10 Commitments to Communication” and hide behind formality.

There is a need for a collective approach to risk communications. One company should not defend itself to the detriment of others. Industry should deal with the issues rather than individual companies defensively protecting their reputation.

A rule to remember is that people trust who they can see. Clear television messages by communicative scientists addressing people’s concern will do far better than all fashionable talk of “dialogue”, “stakeholders”, etc.

Overall, my message is to contest routine. Routines have their place in any organisation but the cosy formulas of risk assessment, management and communication leave us ill-equipped to deal with problems that require direct, immediate and creative confrontation.

Do not say you are committed to safety, tell what you are doing – communicate openness, talk about the issue.

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RESULTS OF THE EUROBAROMETER SURVEYON RISK PERCEPTION

Panagiotis Daskaleros, European Commission, DG Health & Consumer Protection

The European Commission’s DG Sanco (Health and Consumer Directorate) is seeking to understand how consumers perceive risks and safety in order to develop appropriate risk communication tools.

As part of the Risk Perception-Risk Communication project, DG Sanco’s Product and Safety Unit asked Eurobarometer to assess consumer behaviour relating to various products, including detergents. The behaviour included:

- Reading, understanding and recognising danger symbols- Reading, understanding and following use and safety instructions- Storage of products

The Eurobarometer survey questioned 16,000 people in the 15 existing EU Member States. The population sample was representative in terms of Eurostat criteria.

According to the results, more than 60% of consumers pay attention to key safety instructions and danger symbols when buying a detergent. More than 50% notice the type of closure and the composition. On the flip side, 35% rarely or never look at safety instructions and 36% pay no attention to danger symbols.

The main reasons given for not reading safety instructions were “I know how to use it”, or “I always buy the same product, with 65% and 41% of those surveyed giving these answers respectively. Some 11% said there was too much information, 9% said there was not enough, and 3% said the instructions were either too technical or incomprehensible.

While a third of consumers appear to ignore safety information on detergent packs, consumers do have high expectations regarding safety. Between 75-90% expect detergents to be safe, non-irritating and not to cause allergies. They also do not expect detergents to contain chemicals that harm health or the environment. And they do think products should incorporate appropriate safety features.

When it comes to detergent storage, convenience appears to take precedence over safety. Only a quarter of consumers store detergents out of the reach of children.

Danger symbols that are representative or figurative are best recognised, while abstract signs are not. The irritant hazard symbol is least understood with only 23% of consumers correctly identifying it. This compares with 89% identifying the symbol for flammable, 79% for toxic, 66% for dangerous for the environment and 40% for corrosive. Consumers tend to look for safety information when they need it rather than systematically, for example when they have an accidental spillage.

DG Sanco would welcome the views of other stakeholders on consumer understanding of safety features (symbols, instructions,etc). It also acknowledges the need to address the low recognition by consumers of the irritant symbol.

OVER 75% OF CONSUMERS EXPECT DETERGENTS TO BE SAFE

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irritant

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"10 REASONS NOT TO JOIN THE GARDEN CLUB" Franklin Apfel, World Health Communication Associates

I consider public confidence to be a determinant of health. Studies show that people are healthier if they are empowered, in control and confident. This meeting is about how we, as health and risk communicators, can contribute to well being.

My presentation stems from a talk I prepared for my children’s school when I was asked to set up a garden club. My children were dismayed! Not Cool! So I rewrote the talk under the title “Ten Reasons not to join the Garden Club”. My intention was to force students to reframe their views so that not joining the Club would be uncool.

Using that model… 1. Better dead than read – Some companies still do not see the value of communications. If

you are a communications dinosaur, don’t join the Garden Club!2. Profits before People – Many organisations only accept the need and value of risk

communication if it can be tied to overall marketing strategies. Only 5% of consumers trust industry-generated information. If you are into product-tied risk communication, don’t join the Garden Club!

3. Reactive not Proactive – Many people still believe risk communication is critical, but only in times of crisis. If you do not want to engage in proactive risk communication, don’t join the Garden Club!

4. Horses for Courses – How do we reach out proactively to build consumer confidence? By bringing groups together you can identify and agree ways to deliver trustworthy messages. We can help each other sing louder and in greater harmony. If you want to sing solo, don’t join the Garden Club!

5. Check your Values at the Door – What qualities should determine membership of our Club? If you are unwilling to be accountable to your peers for your communication activities, don’t join the Garden Club!

6. Swimming in a Goldfish Bowl – Engaging in risk communication opens companies up to more scrutiny. If you’re not into transparency and clarity, don’t join the Garden Club!

7. Walk the Talk – Risk communication is not just an external activity, it is also about sharing information with worker health and safety programmes and applying the same standards with your neighbours. If you’re not into applying your own standards at home, don’t join the Garden Club!

8. Reinventing the Wheel – We can help each other by sharing experiences. If you are not into documenting, evaluating and sharing your experience, don’t join the Garden Club!

9. OKIYB but NIMBY – Particular attention needs to be paid to even access of information. If you’re “OK In Your Backyard”, but “Not In My BackYard, don’t join the Garden Club!

10. The Antidote …Risk communication is not a one-off event. It requires ongoing investment in education, health promotion, crisis management and information campaigns. So if you are a knee-jerk, don’t join the Garden Club!

This is a rare opportunity. Applied strategically and sensitively, risk communication should help people better deal with uncertainty and in so doing improve peoples health.

PUBLIC CONFIDENCE – A DETERMINANT OF HEALTHP

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THE ACTIVITIES OF THE JOINT RESEARCH CENTRE Demosthenes Papameletiou, Joint Research Centre

There is a clear need to build knowledge and develop European infrastructure, methods and tools for understanding human exposure relating to chemical use.

Exposure data is highly complex and difficult to assess, and in many cases it is missing altogether. As a result, in Europe there is a major bottleneck in safety and risk assessments and communication processes. There are also implications for new legislation including REACH and the General Product Safety Directive.

To combat these problems, DG Sanco (Health and Consumer Directorate) and the Joint Research Centre (JRC) have launched the European Information System on risks from chemicals released from consumer products and articles (EIS-ChemRisks). The initiative aims to provide the nucleus for informed and transparent exposure assessment and communication in the EU by designing, prototyping and implementing the EU Exposure Assessment Toolbox. Details of the programme can be found on www.jrc.cec.eu.int/eis-chemrisks

The programme aims to apply transparent peer review and validation procedures and become a key reference system within the EU. It is looking to network all relevant institutions and stakeholders and harmonise the development of tools, guidance documents and communication.

Initially, the programme is setting up communication among stakeholders, but in the long-term it is seeking communication with the general public.

Between 2004 and 2005, sectorial taskforces will look at textiles, toys and non-woven personal care products. Workshops will be the main mechanism for engaging stakeholders. Expert taskforce groups will aim to ensure that all relevant knowledge and interests are represented. EIS-ChemRisks will provide tools and resources to manage the dialogue. The Exposure Assessment Toolbox will allow users to access information and make queries from specialised reference databases.

EIS-ChemRisks is exploring ways to assist the sectorial stakeholder dialogue process. These include:

- A state-of-the-art review including published and non-published information- An indexed database of all key available documents- The formation of a network of key experts in the field- The development of a toolbox on best practices- The specification of a Eurobarometer studies programme

Stakeholders are invited to develop strategies to provide missing exposure data. For pressing policy needs, the JRC is studying ways to deliver data quickly on an ad hoc basis.

TRIGGERING MULTI-STAKEHOLDER DIALOGUE

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ENGAGING WITH THE TRADE Sheila Kirkwood, Head of Technical Services, McBride

The retail trade sector in the UK feels that not enough is being done to respond to consumer pressure. NGOs are concerned about risky chemicals, and via the media are creating concern and doubt in the consumer. Information flow seems to be one way.

The Supply Chain:

If media stories are inaccurate, we must tell journalists that they have got it wrong.

The number of customers questioning risky chemicals is relatively low compared to other product issues. Most queries go directly to the retailer. In one week, a leading UK supermarket had 36,000 calls from the general public, only 4% related to chemicals – but that equates to 1,500 calls/week.

UK retailers want to do the right thing, but they don’t necessarily know what it is. They operate in a very competitive environment. It is all about cost and value for money, but fear of losing customers drives everything. If there is a question about a raw material, they tend to adopt the precautionary approach and just get rid of it.

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Retailers cannot be experts on all brands. They want their suppliers to be informative and active. The fear of what the customer might do has resulted in some retailers viewing the labelling requirements of the new detergents directive as “adverse labelling”. That is how they see hazard labelling.

There is a positive link between consumer brands and trust.

To be proactive, the British Retail Consortium has set up a Chemical Stewardship Committee to address chemical risks in the retail sector. They have compiled a list of 160 chemicals (from various sources) and are addressing the top 25. Most are pesticides; none are used in detergent products.

A supply chain leadership group has also been established between six retailers and five chemical companies. The group opens up a new channel of communication, albeit limited at the moment. The focus is on specific products and a best practice document will be published by Autumn 2005.

The whole supply chain should be looking at better ways of communicating and managing risk.

HERA is one possible route to engage the retail trade sector.

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THE EXPERIENCE FROM THE COSMETICS INDUSTRYWalter Aulmann, Head of Human Safety Assessment, Schwarzkopf-Henkel

If we strive for a product safety strategy which is accepted by the public, we must not ignore public concerns but have to take them seriously. Moreover, we need to be credible, transparent, reproducible and comprehensible. All these criteria can be taken into account, if we follow a process including risk assessment and risk management. Risk communication is a crucial part of risk management. It needs to have a sound rationale and therefore needs to be based on the previous step of risk assessment. This ensures reproducibility, transparency and is a prerequisite for long term acceptance. Hazard assessment is an important step in the process, but it is not the whole story. In the past, activities focussed on in-depth assessment of hazard. Inclusion of the exposure aspect is crucial, whatever its complexity may be. Whereas for hazard assessment generally accepted conventions are in place, this is not always the case for exposure.

For cosmetics the situation is different: standards for exposures have been established for many years and found access also into the EU technical guidance documents on risk assessment. They can be considered as tried and tested. A more recent trend is to set up exposure categories to reduce complexity. At Schwarzkopf-Henkel, for example, we established ten types of such exposure categories. Based on both, i.e. hazard and exposure data, the further risk assessment process is straightforward. With assessment factors also covering sensitive sub-groups a tolerable human dose or concentration is calculated. For cosmetics, special care is taken for sensitive subgroups, additionally. For example specific safety assessments are conducted for products intended for children below three years. Persons suffering from allergies are provided with proper information to enable them to avoid contact with critical substances. Besides the general INCI declaration of ingredients with their INCI names, specific labelling for 26 fragrances with a high sensitisation rate is standard. For special products such as hair dyes further specific information is given in the package to reduce the probability of allergic elicitations.

Taking all these steps TOGETHER, i.e. hazard assessment plus exposure assessment, combined in a risk assessment, a well established system is in place to provide a high level of safety for cosmetics. Most recent regulatory developments, however, indicate that the paradigma that risk management should be based on risk assessment is increasingly eroded. The general ban of CMR category 1 and 2 substances - also of those that have a threshold - and thus irrespective of the actual risk is one example for such an erosion. The provisions of the cosmetics directive on public access on dangerous ingredients is another one. In both cases, hazard assessment is used as the decision basis instead of risk assessment.In the long run, ignoring risk assessment as the sole basis for risk management may lead to contradictions1 compromising our goal to maintain and increase the trust of consumers.

1 A good example is Ethanol: a known, but so far not yet classified reprotoxicant may be banned in the future from hydroalcoholic formulations (perfumes), in spite of the fact that such exposure is minute compared to the exposure from alcoholic beverages.

SHOULD CMRs BE USED IN COSMETICS?P

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TESTIMONIAL FROM THE AUTOMOTIVE INDUSTRY Urban Wass, Head of Environment and Chemistry Dept, Volvo

The first question is: “Do we at Volvo like to communicate?” The answer, is “Yes, we do!” And not only about how good our cars are, but also about chemicals. Chemicals are used in the manufacture of cars (as well as trucks, buses and construction equipment) and also during the life of the car, where consumers can buy products like motor oil, antifreeze or paint. At Volvo, we have a group of ten people addressing chemical use – half cover chemicals used in production, half focus on the after-sales markets.

Flow of Chemicals:

Overall, the most important feature is risk reduction. We have put a lot of effort into the use of less risky chemicals. During the 1970s, safe handling of chemicals was the main area of concern for substances used in car production. In the ‘80s and ‘90s this turned to toxics and waste. Now the key focus is on resource issues. So we are looking for lighter materials, which may lead to an increased use of epoxy-based adhesives.

Volvo sells around 400 products in the after-sales market, more or less globally. We need to communicate the risks associated with these products. We have software that covers regulatory requirements.

We do a lot of communication with professional users. But it is more difficult to connect with people we never meet. At Volvo we try to use all the senses. For example:

- Taste and smell – the use of denaturing agents in windscreen washes.

- Touch – tactile warnings for blind or partially-sighted customers

- Hearing – a telephone service

- Sight – safety data sheets, in national languages and accessible via the intranet

IT TAKES AN EXPERT TO COMMUNICATE WITH A NON EXPERT

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What we call Silent Risk Communication is extremely important. We have effective risk reduction and management, which aims to phase out or replace risky chemicals. We have already replaced lead chromates in paints, and use of chlorinated solvents, nonylphneol ethoxylates and some phthalates. We are currently striving to move to high molecular weight epoxy resins and readily biodegradable surfactants.

When we do make these positive changes, we say so on the label.

From our experience, it takes an expert to communicate with a non-expert. We decide how a product should be handled, and communicate this in clear messages. We have also trained our sales people. They represent important links between the company and the public.

Symbols are important, and the Eurobarometer surveys are interesting.

We are also prepared for crisis communication – but I cannot think of a time when we have had to use it.


TESTIMONIAL FROM THE FOOD INDUSTRYYasmine Motarjemi, Corporate Food Safety Manager, Nestlé

Food is close to the consumer. From a nutritional viewpoint it is essential, and it also gives pleasure. Therefore for food industry, the trust of consumers is particularly important. In regard to this, a EU survey has shown that consumers in Europe have little trust in food manufacturing and processing industry.

There is a growing preference for organic chemical-free food despite the increased risk of microbiological reaction. It is interesting that consumers are particularly concerned about chemicals in food, when food-borne illnesses present the highest risk – in the US alone around 76 million people/year are affected and 5,000 people/year die from such illnesses.

The reason for this is Risk Perception. It is essential to understand risk perception before you attempt risk communication. The concept of risk perception is closely related to acceptability of risk. Understanding of factors influencing acceptability of risk is important for an effective risk communication. Examples of these factors are voluntary versus imposed nature of risk, natural or man made risk, outrage, benefits for the risk taker, etc.The key challenges for risk communicators include:

- Explaining the difference between a hazard and risk. For most people presence of a hazard in a food implies risk.

- Communicating uncertainty and science that changes- Overcoming consumer fear or outrage created by bad media reporting

Some companies marketing practices lead to misperception. For instance a food company which states “our food does not contain food additives” lead consumers to believe that food additives are bad. Comparative risks don’t work in the food industry, e.g. staying that the food item or the hazard in question present less risk than flying. Nestlé are among food companies that sponsor the European Food Information Council (EUFIC), which aims to provide factual information to the consumer.

Food industry behaved transparently when semicarbazide associated with the lids of a number of products was discovered – The food industry informed the appropriate authorities and worked with the packaging sector to identify and solve the problem. It was also important to adequately inform consumers on the issue so they could understand the problem and the dilemma in overcoming it, i.e. a chemical risk versus a biological risk.

Treat public fears seriously, admit uncertainties in science and communicate the risk minimisation steps you are taking, but do not use technical risk estimates alone as the basis of communication efforts. Be clear about WHAT the risks are and WHEN they present a health risk. Explain WHY substances are used and the implications of not using them. Provide information on HOW society can minimize risks.

Collaboration between different sectors is crucial.

UNDERSTANDING RISK PERCEPTION

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PANEL 1:PRODUCT INFORMATION AND LABELLING

Moderator: Karen Duff, UnileverRapporteur: Alan Barber, Unilever

The Global Harmonisation System* (GHS) and Consumer Communication Activities in the NetherlandsHenk Roelfzema, Ministry of Health, The Netherlands

Dutch companies are enthusiastic about taking part in voluntary projects as it helps them to prepare for new EU directives and improve chemical management.

The Dutch government stimulates companies, importers and retail trades to communicate more openly to relevant stakeholders about the safety of chemicals in consumer products. The Dutch government appreciates the initiatives of HERA and NVZ, the Dutch detergents association, to prioritise consumer dialogue.

Case Study: The New Detergents RegulationStephen Pickering DG Enterprise and Industry

From 8 October 2005, the new Detergents Regulation will require more detailed labelling of detergents. Perfumes, preservation agents and allergenic fragrance ingredients will have to be included on pack labelling, along with 18 classes of detergent ingredient. Dosages will be provided to try to avoid over use of detergents.

Manufacturers must publish a full list of the ingredients used in a detergent on a website for the general public. In addition, detergent makers must make a more detailed ingredients’ datasheet available for medical personnel.

The provision of detailed ingredient information on a common consumer product, such as detergents, is a new departure for EU chemicals legislation. It reflects the importance society attaches to protecting human health and the environment.

*GHS for the classification and labelling of chemicals is an initiative of the Inter-Organization Programme for the Sound Management of Chemicals (IOMC). See [email protected] for more information.

THE CONSUMER MUST VIEW THE LABEL AS EMPOWERING


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The Importance of LabellingAndrew Fasey, Consultant

Classification through the Global Harmonisation System* will be a vital part of REACH and the use of appropriate risk management measures. For most consumers, the only risk management they are aware of is the label. It is therefore essential that we get labelling right. GHS will increase the number of products with a danger label seen by consumers, but will this lead to safer behaviour and reduced risk?

We need to fundamentally look at labelling to ensure consumers act in the best way to reduce the risk burden.

Consumers should be able to differentiate between products so that substitution takes place at point-of-purchase. This should encourage producers to formulate safer products. Labels need to be appropriate, so that care is taken when needed – meaningless labels lead to inappropriate behaviour.

Conclusions

The Dutch project reinforces company responsibility regarding control and minimisation of risk which includes greater communication to consumers about the safety of chemicals in consumer products. This includes websites, brochures and incident management. The project is an opportunity for us all to learn. Some labelling has already been corrected.

The new Detergents Regulation aims to further protect the environment and human health. It is hoped that the new labelling requirements will aid purchasing decisions. They will alert consumers to certain allergens and provide information for those with specialist medical requirements. They will also allow consumers to make value comparisons for detergent products.

New symbols are being devised under the Global Harmonisation System – this is an opportunity for hazard and risk communication.

It should be noted that the EU has not fundamentally reviewed labelling requirements. However, GHS could mean 100% classification of products.

We need a risk approach that makes labelling meaningful to consumers. The label priorities should include:

- what the product is;- safety information; and- an environmental assurance label possibly

The consumer must understand the label messages for them to be empowering.


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PANEL 2:OTHER BRAND, COMPANY AND ORGANISATIONAL TOOLS (WEBSITES, LEAFLETS, PHONE LINES)

Moderator: Veronique Scailteur - P&GRapporteur: Goetz Lachmann - Sasol

The Dutch Pilot Site, "Is this product safe?" One year’s experienceBert Beij, Unilever for NVZ

In response to a growing interest from consumers and semi-professional users for substance and product information, the Dutch association for producers and importers of cleaning and maintenance products decided to develop a website (www.isditproductveilig.nl). The website aims to improve user confidence in cleaning agents.

The project began in August 2002; the website started in summer 2003 and launched in March 2004. Over 6,200 different visitors have logged on to the website, with around 230 pages/day being viewed. Label and hazard information is one of the most visited pages. In the future the current website will be expanded to include additional products and product groups.

Science In the BoxAndrew Fisk, P&G

Science in the Box is a scientific information website on laundry detergents and household cleaning products developed by Procter & Gamble. The site, www.scienceinthebox.com, delivers a wealth of product information to consumers, media, scientists and professionals. Subjects include product innovation, R&D, human and environmental safety, and sustainability. It also provides access to the company’s library of scientific publications and product safety datasheets.

The site is intended for audiences with different backgrounds and levels of education. It is structured in layers; the top two to three layers contain basic information and are tailored to a general audience. On the deeper levels, information becomes more detailed and more technical.

A STRONG FOCUS ON SCHOOLS AND UNIVERSITIES


GreenFactsDavid Zaruk

GreenFacts aims to summarise scientific documents in a language and structure accessible to non-specialists interested in health and the environment.

It has developed a three-tier structure to allow complex materials to be communicated more easily, while ensuring the reader has direct contact with original scientific source documents. Available reports, which are reviewed by GreenFacts’ Scientific Board, can be found on the Internet at: www.greenfacts.org

Conclusions

We are at the beginning of a new era of transparency. There is not a “global’ consumer – the answers are not black and white, for industry or NGOs, and we have to communicate this. Who is the real consumer?

We are really just starting to communicate. Work is in progress, and we should not expect immediate answers. To reach different audiences, we need different communication channels.

Do we make a business out of this? No, but we will gain the trust of consumers and of the people who work in our organisations. Trustworthy communication works through people who trust other people. It was said that people do not believe Nostradamus-type predictions...but they do believe doctors.

It was also stressed that there should be a strong focus on education, both on schools and universities. Teach people how to obtain information on the one hand and use it on the other, and, more importantly, how they can provide information for different audiences.

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PANEL 3:CAMPAIGNS AND JOINT COMMUNICATION PROGRAMMES

Moderator: Marc Devisscher - CEFICRapporteur: Kerstin Ochs - Henkel

BEUC ActivitiesCharlotte de Roo, Environment, Health & Safety Officer, BEUC

Because it sees a high level of scientific uncertainty surrounding chemicals used in the house, BEUC, the European consumers organisation, has decided to run a campaign at European

level. We have a website looking at hazards in the home, www.chemical-cocktail.org and recommend products carrying an eco-label.

Our campaign on what consumers should look for in a product has been well received. But how does BEUC restore confidence in chemicals? The only way is through honesty and safe products. But what is a safe product? Zero risk does not exist.

Often detergent adverts give simplistic messages, for example showing convenience, but not illustrating safe guards that should be taken. It is not enough to have informative websites, if the marketing does not follow.

WWF ActivitiesKarl Wagner, Director WWF Detox Campaign

WWF activities are based on scientific facts and trying to find common ground. We believe in promoting a strong industry and the benefits of chemicals. But it is imperative that chemicals are regulated. We know that some chemicals cause problems that appear worldwide. We try to see the impacts, and the long-term and cumulative effects. We have a clear and coordinated approach for stronger REACH regulation; see www.panda.org/detox and www.chemsec.org. The bio-monitoring programme, which tested the blood of key European figures for certain chemicals, was a successful campaign for us – it got good media coverage.

By not backing REACH, industry is running the risk of missing an opportunity. Supporting REACH is the best thing you could do for your image. Some 93% of Europeans feel that chemicals have

HONESTY AND SAFE PRODUCTS


a negative impact on their health. You cannot back positions that are not sustainable in the long term.

TV ActivitiesMartin Lichtl, Managing Director, Lichtl Sustainability Communications

In Germany there is increasing interest in sustainable development. A science programme called WELT DER WUNDER gets 3-4million viewers each week. This program contains more and more sustainability themes and it is planned to launch a pure sustainability program called «PROJECT BALANCE».

The idea in «WELT DER WUNDER» and later in «PROJECT BALANCE» is to appeal to new audiences. It is difficult to get heavily information-based concepts over to consumers. We try to appeal to the emotions linked with entertainment-ecotainment. For example, we used James Bond backing music and a fast car in an item about biofuels, or the Hitchcock genre in an item about correct dosing of washing machines.

We also focus on solutions, telling consumers how they can act in daily life positive and in a sustainable manner. We run a website containing a lot of background information with the chapter “BALANCE” on www. weltderwunder.de

Conclusions

Everyone wants safe products.

Consumers should be able to buy good products.

There are certain responsibilities for industry, including educating consumers on the safe use of products. Information should be honest and tailored for consumers. Companies should not just create a picture of safe chemicals, but this has to be supported by marketing.

There is a strong need for a workable REACH.

NGOs want to stimulate consumer interest in information. Sometimes NGO messages are frightening. From WWF’s viewpoint, this is not the intention. It wants solutions based on science.

TV is a powerful medium for communicating science and risks.

Television is a very powerful tool for risk communication. But it is a challenge to get people to listen. It is crucial to firstly catch people’s interest. In Germany’s weekly science show, this is achieved by tapping into emotions and presenting surprising facts.

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SAFETY, CONFIDENCE AND SOCIETY: FINAL REMARKSPhillip Whitehead, Chairman Committee on Internal Market & Consumer Protection

First, these are my own views – and not necessarily those of the Committee I chair:Consumers, as informed citizens, need to know about the chemicals that shape their world; not by obscuring the facts, not by scaremongering, but by objective assessment. I welcome this important conference because it will lead us to the priorities of risk communication, the language we use to express it, and that agreement about the precautionary principle proportionately applied which will be the common ground of consumers, industry and NGOs alike.

It is important for administrators, industry and consumers to tie their actions together: If we do not share our concerns, we will not solve them. Whenever I hear strident calls of alarm, or the opposite, deep complacency—I treat them with caution. We all know that hazards are a feature of life. Zero risk does not exist. We need more transparent information about chemicals…and we need to know the Law of Unintended Consequences.It is important to assess how risk studies are performed and find out where the realities lie.I applaud your attempt to understand the fears of citizens and meet those fears with rational explanation. It is important that public concerns are engaged.

REACH is a central area of EU legislation and a key test of how the Commission and Parliament can deal with the issues. Because of uncertainties in the marketplace and among interested parties, REACH will be discussed by three committees—Environment, Industry and Internal Market—on 19 January 2005 in the Parliament. All sides must make progress with REACH. We seek a process that identifies real risks.

We support the position of the UK Royal Commission on Pollution that calls for one registration per substance. There needs to be a hierarchy of risk, with isolation of the most dangerous substances and a focus on areas of real concern. A move towards sensible classification of chemicals should be swiftly followed by appropriate labellingIf there is a clear risk, you cannot continue substances for these applications, even if substitutes have not been found. In 5-7 years we do not want Europe left with unresolved anxieties. We have got to persuade industry that self-regulation has a role to play.When an industry feels threatened, there is a lot to be said about engaging industry as a whole. Brominated flame retardant emissions are hazardous but there were no replacements when the proposal was first made. Should you be left in a position when you either burn quickly or choke slowly on chemical effluvia? Thanks to the engagement of the fire protection bodies we have been able to find substitutes, e.g. in TV sets construction, ahead of regulation.

However, industry also needs to accept that legislation is necessary. If we as legislators accept that there is no such thing as zero risk, and agree proportional risk control, your responsibility is to engage in dialogue and improve it. We cannot do it without you and you cannot do it without us.

CONCL UDING RE M A R K S

IF WE DO NOT SHARE OUR CONCERNS, WE WILL NOT SOLVE THEM

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“TALKING ABOUT CHEMICALS WITH CONSUMERSCONFIDENCE THROUGH COMMUNICATION?”The exhibition hall was organised in order to invite organisations and companies to share their initiatives in the domain of risk communication towards consumers. Trust in brands, products and ingredients as well as acceptance of communicated risk and safety is a major driver for industry and essential for its success.

The exhibition can be visited during the coffee break and buffet lunch of the Workshop.The different exhibits are described herewith:

A.I.S.EContact: V. Séjourné / C. Cullen

“Consumer communication activities at EU and national levels”The stand introduced A.I.S.E, the International Association for Soaps, Detergents and Maintenance products (one of HERA’s sponsor organisations) and its network of 35 National Associations in 31 countries.

It also highlighted a major pan-European campaign that has been developed since 1998: “Washright”, aimed at providing tips to all consumers in Europe for the environmental friendly use of laundry detergents (see washright.com).

Complementary to that, several of its National Associations have been pioneering activities on consumer information namely:

- Assocasa (Italy), with brochures from the Istituto Superiore per la Prevenzione E la Sicurezza del Lavoro on Detergents and Biocides;

- IKW (Germany) which has developed material about hygiene tips for use by consumers in their home;

- NVZ (The Netherlands) with the project & website “Is dit product veilig?” regarding product information and safety;

- SKW (Switzerland), with brochures on laundry products and the environment, on product composition information

A.I.S.E. will build upon these initiatives to further develop relevant material on the topic.


CEFICContact: A. Ojanperrä

“Risk and Hazard, how they differ”A lot of jargon is used when talking about risk and some of this can be confusing. In the discussion about chemicals, the word “risk” and “hazard” are very often used as if interchangeable. In this brochure we offer our understanding of the difference between these expressions, appreciation of which is fundamental to informed debate on the safety of chemical products and processes.

GREENFACTSContact: D. Zaruk

“GreenFacts.org : Communicating credibility through science”GreenFacts summarizes authoritative scientific source documents in a language and structure accessible to non-specialists. They have developed a Three-Level Structure that allows complex materials to be communicated more easily, while ensuring the reader has a direct contact with credible scientific source documents. At the stand, you will be able to see what a HERA risk assessment would look like in a GreenFacts Three-Level Structure.

HENKELContact: K. Ochs

“Theoprax”Henkel Germany developed a specific website for laundry and home care brands: www.theoprax.de. It addresses different target groups – ranging from professional stakeholders to consumers.

“Theo”, represents the source of background – information for technical and scientific oriented questions and “Prax”, explains how to achieve best results in washing, dishwashing and cleaning, guides the user through the website.

HERAContact: N. Werkers

“Clean House, Safe Home”HERA’s first attempt to add value in the communication process resulted in the development of plain language (Q&A) translations on the outcome of its Risk Assessments. However, better communication to consumers starts from the consumers’ reference point: their home and products.

Consequently, HERA has developed the demo “CLEAN HOUSE, SAFE HOME”, aiming at continuously exploring new ways to deliver transparency and information about risk and safety. EX

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PROCTER AND GAMBLEContact: E. Saouter

“Science in the Box”P&G’s new website, www.scienceinthebox.com, is a valuable resource for a wide range of audiences. For example, sections specifically for consumers include how to care for fabrics, why dirt is important and tips for kitchen hygiene.

For scientists and environmentalists they have access to most of P&G scientific publications, to the methodology used to assess human and environmental safety, to products and chemicals safety data and much more.

UNILEVERContact: A. Barber – S. Smith

“Building consumer confidence”People trust our brands to use every day in their homes to safeguard their family’s health and we take very seriously our responsibility to meet their needs safely. As well as applying rigorous safety standards, we strongly believe in providing consumers with risk information in an honest and clear way. This will result in greater public confidence in the decision-making process and ultimately enable consumers to feel safe as well as be safe.

Whilst our product packs provide information covering a mixture of regulatory and voluntary information, the packs are not the best place to cover every piece of information. Consumers who prefer more personal contact can call our carelines to not only get product advice but also to request answers to questions about ingredients and any risks that are of genuine concern to them.

We have produced a brochure “Consumer Confidence in Chemicals’ which sets out our approach in more detail.

WWFContact: K. Wagner

“Detox Campaign”WWF supports new European Union (EU) law and welcomes the publication of the new draft law – called REACH – that would apply to all EU countries.

We live in a chemical world. They are in use all around us – from pesticides to cosmetics and baby bottles to computers. Some chemicals are known to be toxic and we know very little about many others.

Via the Detox site, “www.panda.org/campaign/detox/”. WWF gives simple tips for the consumer to reduce their exposure to harmful chemicals. And protect wildlife from the toxic threat.


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HERA’S APPROACH TO COMMUNICATE RISKTO CONSUMERSRecent HERA stakeholder consultations, involving consumer feedback, have highlighted that communicating the outcome of HERA risk assessments in an easy and accessible way is strongly appreciated.

Consequently HERA launched in 2003 a project on risk communication and developed plain language (Q&A) summaries of its risk assessments.

Having learned that consumers want clear guidance in product use and purchase, rather than evaluating loads of information or becoming an expert themselves (Qualitative Market Survey – October 2003), HERA imbedded its Q&A’s in the consumers’ environment to trigger interest in the topic.

It is therefore that HERA’s “CLEAN HOUSE, SAFE HOME” was developed as programmed software where consumer products are presented in the home.

HERA developed the “house’-interface for the:- kitchen- bathroom- laundry room

Animated hotspots in each of the rooms provide information on products and their ingredients. Next to that the “Scientists’ Section” guides the visitor to HERA’s plain language (Q&A) summaries.

The cleaning products and their ingredients described are: kitchen cleaners, window cleaners, oven cleaners, manual dishwashers, automatic dishwashers, all purpose cleaners, bath (shower) cleaners, toilet cleaners, laundry softeners, laundry bleaches, laundry detergent powders, laundry detergent liquids.

“CLEAN HOUSE, SAFE HOME” is a tool that could serve as an example for use by other industries and on other products.

For more information on this project, please contact the HERA Secretariat; e-mail: [email protected]


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“Talking about Chemicals with Consumers, Confidence through Communication?” was the theme of a one-day workshop in Brussels on 9 November 2004. The workshop was organised by HERA (Human and Environmental Risk Assessment on Ingredients of Household Cleaning Products), a joint initiative of A.I.S.E. and Cefic.

Speakers included a sociologist, a healthcare specialist, and representatives from several industries, the European Commission and Parliament, and consumer and environmental NGOs.

Why should we be communicating risks?The need for risk communication seems to be expanding. Consumers hear more about hazards and are becoming more inclined to protect themselves from potential liabilities.

We have to recognise that consumers want to buy products in the confidence that they are safe. The chemical ingredients are obviously important, but the link is indirect.

What direction should Risk Communication be taking?There is a very clear message: Risk communication cannot be “one-size-fits-all”. It must be fit for the purpose. Communication needs to be acceptable – it needs to take into account the world of risk that people inhabit in their everyday lives.

Communicators need to focus on the customer. The risk assessment and risk communication process is becoming an industry in itself. It is developing internally, but the objective is to communicate to others.

As part of going about our everyday business, we continuously take risk reduction measures and pre-emptive action. We need to draw attention to our actions through “silent risk communication”.

Risk communication needs to be continuous. Mistrust is created if companies are perceived to only communicate or react in a crisis.

Who should we be working with?Because consumers are primarily interested in finished products, the wider supply chain should be involved in the debate.

UK retailers make supply decisions based entirely on the consumer’s perception of risk, which is mostly influenced by pressure from NGOs and the media. The chemical industry cannot respond to such messages on its own. It needs to develop partnerships to bridge gaps and engage the wider supply chain in the debate. It is important to keep the process simple because of the large number of products involved. To what extent does this situation exist across Europe? It might be that retailers in other countries look more at legal requirements and are not under the same pressure as their UK counterparts.

It is important for industry to forge alliances elsewhere too – industry needs intermediaries to convey a more credible message.

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How should we be communicating?Risk communicators need to find creative ways of talking. Science does not speak for itself. The process should not be one of translation but of communication. It should deal with the issues, not the processes.

Regular calibration, such as the Eurobarometer surveys, is necessary to provide a measure of what people respond to.

Because of the nature of communication today, and the Internet revolution especially, scare stories regarding consumer risks will continue. How do risk communicators cope with that, without adding to the overall stress experienced by consumers? It is very difficult to keep emotions out of risk assessment debates.

Everyone at the workshop seemed to agree that zero risk does not exist. The question is how do you explain this and the implications of “acceptable” risk to the public? Precaution must be proportionate.

You cannot compare risks. Do not deny the risks of some chemicals or say that the risks are insignificant, by saying for instance, that “daily life is a bigger risk”. This does not help. Explain the risks and benefits of chemicals.

There are a great number of tools being developed. The work of the Joint Research Council measuring exposures to substances will be invaluable from a practical viewpoint.

There is a role for risk communicators to take in terms of education – here there are a lot of contexts.

Again, there is a need to keep the process simple otherwise it will become too big and muddled.

If we turn to the three questions posed at the beginning of the workshop:

• What more have we learned about communicating with consumers to achieve confidence in chemicals?

• What tools work and how should they be used?

• What role has HERA to play in this?

We can say that the process we started last year of “Talking about Chemicals with Consumers” is very much a continuing story.

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The theme of no “one-size-fits-all” was repeated. However, different risk communication channels, methods and messages must be based on common information. It is also clear that we should not just talk about risks – we need to be active in terms of doing risk management and talking about that too. Consumers want to understand the issues and their solutions, not the process. They do not want to become experts in the matter.

Regarding tools, we can learn from what the European Commission is doing in terms of surveying consumer actions and perceptions relating to risk, and the work of the Joint Research Centre on chemical exposure assessments.

From our viewpoint, our stakeholders and the authorities appear to appreciate the tools we, and our member companies, have developed so far. The language of risk and safety needs to have a common basis in order to help identification and consumer understanding. We have also heard that we need to work with others in the supply chain to enhance consumer confidence in chemicals and products.

In the context of REACH, the HERA experience will be highly valuable. HERA has also set out to open communication channels about chemical safety to a broad audience. The path to gaining consumer confidence in chemicals may be challenging, but with the HERA project, the journey very much continues.


ANNEX 1THE HERA PROJECTThe HERA (Human and Environmental Risk Assessment) project is a European voluntary initiative, which was launched in 1999 by the following organisations:

A.I.S.E. (International Association for Soaps, Detergents and Maintenance Products), representing the formulators and manufacturers of such products, and

Cefic (European Chemical Industry Council), representing the suppliers and manufacturers of the raw materials.

Until recently, the results of safety assessments carried out on ingredients remained confidential to the company that conducted them. In today’s world, both the regulators and the general public rightly demand greater transparency of information on the potential risks posed by the ingredients of products used in the home. There is now a call for data to be published so that the need for further information, if required, can be debated in public.

HERA brings together producers of chemicals and formulators of the finished product to provide such data and to place it in the public domain.

Objective of HERAHERA provides a common risk assessment framework for the household cleaning products industry, and shows that this process can deliver validated safety information on the ingredients used in these products in an effective and transparent way.

This process is intended to support a risk-based approach to chemicals legislation in the European Union, and may serve as a pilot for the application of the same process in similarly structured sectors and / or other geographical areas.

Risk assessment is the best tool to establish the need for risk management measures and to define them appropriately. So HERA risk assessments will naturally lead to risk management decisions being taken and implemented by companies; a guidance document to help this process is being elaborated.

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The HERA principlesHERA is committed to partnership between supplier and formulator companies and their representative groups.

HERA develops an open dialogue with stakeholders e.g. regulatory scientists and interested European organisations.

Transparency in all its activities is essential. This includes the risk assessment procedures, agreed data-sets, justification for data selection, reasons for overriding some standard elements of procedures such as those from the Technical Guidance Document for risk assessment of new and existing chemicals in Europe.

No preconceptions exist of the outcome of the risk assessments. The results speak for themselves.

Above all, HERA is a solid commitment to a science-based risk assessment and to the use of a tiered (“step-sequence”) approach to understanding the behaviour of chemicals during the use and disposal phase of household cleaning products.

The HERA approach ensures the use of robust, available data thus avoiding unnecessary animal testing.

Progress The first phase (1999 onwards) aimed at developing the methodology for the HERA risk assessments and began working on example substances.

During the second phase (2003 onwards), the HERA teams have been applying this methodology to a range of substances and subsequently, have produced a whole series of risk assessments.

A third phase (2004 onwards) was initiated in which HERA aims to finalise its work. By complementing the list of substances, it is expected that all important ranges of chemical ingredients and all exposure scenarios will be covered.

In total, HERA will assess approximately 250 CAS (*) numbers and cover over 30 chemical ingredient families. Those represent the great majority of ingredients used in household cleaning products in Europe.

External Advisory PanelIn 2001, an External Advisory Panel composed of scientific experts from different Universities in Europe and other organisations was appointed to carry out a progressive review of the HERA methodology and of the draft risk assessments posted on the website.


Under the leadership of Professor Jim Bridges, who also chairs the EU Task Force on Risk Assessment Procedures and the Scientific Committee of Toxicology and Ecotoxicology (CSTEE), the HERA External Advisory Panel has made steady progress in reviewing the risk assessments, supporting HERA’s objective to continuously fine-tune the quality level of its work. A current member-list of the Panel can be consulted on the HERA website.

Stakeholders consultation Transparency and stakeholder input are key features of the HERA project. In this context, regular consultations are being organised with representatives from academia, EU authorities, NGOs (consumers, environment) and industry.

Four workshops have taken place to date (October 2001, July 2002, November 2003 and November 2004) in which attendees welcomed the initiative and provided useful suggestions for HERA’s future development. Global coordination and information exchange are consistently encouraged.

Communicating to the publicHaving set the goal of providing useful and transparent information on risk assessments, HERA contributes to overcoming the communication challenge “more and better communication on chemicals to consumers” by developing plain language summaries of its risk assessments.

A “simplified” Question and Answer set will consistently be used for all HERA risk assessments.

For more information, including the latest news, methodology and risk assessments, visit the HERA website on: www.heraproject.com

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ANNEX 2THE WORKSHOP AGENDA

Moderator: Christine Drury

08.30 Registration of participants

09.00 Opening remarks Welcome and introduction to the day

Christine Drury,Moderator of the dayClaude Mancel, HERA Sponsors Committee Chairman

09.15 Risk Assessment paradigm John SolbéChair of the HERA Operations Team

09.20 Problems of Risk Communication Adam BurgessProfessor of Sociology, University of Kent

09.40 Results of the Eurobarometer surveyon risk perception

Panagiotis Daskaleros,European Commission DG Health & Consumer Protection

10.00 Questions & Answers All

10.10 “10 reasons not to join the Garden Club” Franklin Apfel, World Health Communication Associates

10.30 The activities of the Joint Research Centre Demosthenes Papameletiou, Joint Research Centre

10.50 Questions & Answers All

11.05 Coffee break / Visit of the exhibition hall

11.20 Engaging with the Trade Sheila Kirkwood,Head of Technical Services, McBride

11.40 Testimonials from other industries :11.40 – 11.55 : Cosmetics industry Walter Aulmann, Head of Human Safety

Assessment Dept, Schwarzkopf-Henkel11.55 – 12.10 : Automotive industry Urban Wass, Head of Environment and

Chemistry Dept, Volvo12.10 – 12.25 : Food Industry Yasmine Motarjemi, Corporate Food

Safety Manager, Nestlé 12.25 – 12.35 : Questions & Answers

cont’d


12.35 Closing the morning session /introduction afternoon session

Christine Drury

12.45 Lunch break / Visit of the exhibition hall

14.00 Panels (all running in parallel): The risk communication tools

Panel 1: Product information & labelling

Moderator: Karen Duff (Unilever)Rapporteur: Alan Barber

Panellists include:- The Global Harmonisation System and

consumer communication: activities in the NL

- Case study: the new Detergent Regulation

- The importance of labelling

Discussion

Henk Roelfzema, Ministry of Health, The Netherlands

Stephen Pickering, EC- DG Enterprise and IndustryAndrew Fasey, consultant

Panel 2: Other brand, company, organisation tools (websites, leaflets, phone lines etc)

Moderator: V.Scailteur (P&G)Rapporteur: Kerstin Ochs

Panellists include:- The Dutch pilot site “is this product

safe?”; one year of experience- Science in the Box- GreenFacts

Discussion

Bert Beij, Unilever for NVZ

Andrew Fisk, P&GDavid Zaruk, GreenFacts

Panel 3: Campaigns and joint communication programmes

Moderator: Marc Devisscher (Cefic)Rapporteur: Peter Wiedemann

Panellists include:- BEUC activities

- WWF activities- TV Activities: Project Balance

Discussion

Charlotte de Roo, Environment, Health & Safety Officer, BEUCKarl Wagner, Director WWF Detox CampaignMartin Lichtl, Managing Director, Lichtl Sustainability Communications, Germany

ANN

EXES

cont’d


ANN

EXES

cont’d

15.45 Debrief from sub-groups on discussions By rapporteurs

16.30 Safety, confidence and society: final remarks

Phillip Whitehead, MEP,Chairman Committee on Internal Market & Consumer Protection

16.50 Conclusions Claude Mancel, Christine Drury

ANNEX 3WORKSHOP REGISTRATIONS

NAME ORGANISATION

ABMA Hendrik FECC

ACCORSI Marcello Federchimica

APFEL Franklin World Health Communication Associates

AULMANN Walter Henkel-Schwarzkopf

BARBER Alan Unilever Home & Personal Care Europe

BEIJ Bert Unilever Home & Personal Care Europe

BERNA Jose Luis Petresa - Ecosol

BERNHEIM Michael Ciba Specialty Chemicals

BLEREAU Linda Procter and Gamble

BLOCK Christian HERA

BONCY Richard IFRA

BOSTJANCIC Darja Ministry of Health, Nat. Chemicals Bureau (Slo)

BROWN Tracey

BURGESS Adam University of Kent

CHADWICK Roger European Parliament

CHYNOWETH Emma

COX Patrick University of East Anglia

CULLEN Cheryl A.I.S.E.

DASKALEROS Panagiotis European Commission

DE ROO Charlotte BEUC

DESTASIO Raniero Procter and Gamble


DEVISSCHER Marc Cefic

DRURY Christine Workshop Moderator

DUFF Karen Unilever Home & Personal Care Europe

EKMETZOGLOU-NEWSON Thisvi

European Parliament

EMSLEY John University of Cambridge

FASEY Andrew Protection Through Knowledge

FISK Andrew Procter and Gamble

GRAEFE Sebastian European Parliament

GRYGLEWICZ Lucien A.I.S.E.

HAKKINEN Pertti Juhani Joint Research Center

HEGYI Gyula European Parliament

HERTEL Rolf Federal Institute for Risk Assessment (D)

HILGERS Genevieve Procter and Gamble

HILLERSBORG Aage Lego

HUM Julianna European Parliament

IACCINO Federica GreenFacts

ISLER BEGUIN European Parliament

KALLENBACH Gisela European Parliament

KALLENBERGS Kristian Stockholm School of Economics

KARATZAS Dorian European Commission

KASTENHOLZ Hans EMPA

KIRKWOOD Sheila McBride

KNAPHEIDE Timo European Parliament

KRAHMER Holger European Parliament

KUSKIS Aldis European Parliament

LABBERTON Maarten A.I.S.E.

LACHMANN Goetz Sasol

LAROCHE Charles Unilever Home & Personal Care Europe

LE BLANSCH Kees QA+

LICHTFUS Gerard Henkel Belgium

LICHTL Martin Lichtl Sustainable CommunicationsANN

EXES

cont’d


ANN

EXES

cont’d

LINDBERG Emma European Parliament

MADSEN Torben DHI Water & Environment

MAKELÄ Petteri A.I.S.E.

MANCEL Claude HERA

MARTIN Audrey IFRA

MARX Sebastian Colipa

MC IVOR Emily BUAV

MENTRE Barbara European Commission

MOTARJEMI Yasmine Nestlé

MUSSET Laurence OECD

NORIN Helena Swedish Society for Nature Conservation

OCHS Kerstin Henkel-Schwarzkopf

OJANPERÄ Anne-maria Cefic

OLAJOS Peter European Parliament

OLIVER Rebecca Unilever Home & Personal Care Europe

PAPAMELETIOU Demosthenes Joint Research Center

PAUWELS Marleen Vrije Universiteit Brussel, dept. Toxicology

PEETSO Terje European Commission

PETTA Georgia-Melina LST-E Institute

PICKERING Stephen European Commission

PIZZATO Luciano Reckitt Benkiser

PRESTON Catherine Unilever Home & Personal Care Europe

PRODI Vittorio European Parliament

PUGH George Colgate Palmolive

RAZENBERG Hans NVZ

RENAERTS Rob OIVO - CRIOC

RISS Jorgo Greenpeace

RODEYNS Anne-Marie A.I.S.E.

ROELFZEMA Henk Ministry of Health (Nl)

SAOUTER Erwan Procter and Gamble

SCAILTEUR Veronique Procter and Gamble


SCHERES Huub AMFEP - Genencor

SCHUMANN Regina European Commission

SCOLA Julian WWF

SEJOURNE Valerie A.I.S.E.

SINGHOFEN Axel European Parliament

SMITH Samantha Unilever Home & Personal Care Europe

SNARY Chris DEFRA

SOLBE John Unilever Home & Personal Care Europe

SOLTWEDEL-SCHÄFER Irene European Communication

STEENHOUT Anne Université Libre de Bruxelles (GEEPSIH)

TAYLOR Sally European Parliament

TUCCIMEI Laura A.I.S.E.

VADSTRUP Mette British Retail Consortium

VAKALIS Nikolaos European Parliament

VAN ENGELEN Jacqueline RIVM

WAGNER Karl WWF

WAGSTAFFE Peter European Commission

WASS Urban Volvo

WERKERS Nadia HERA

WHITEHEAD Phillip European Parliament

WIEDEMANN Peter Jülich Research Center

WILL Hamish Unilever Home & Personal Care Europe

WOLTERS Jürgen Dalli-Werke

ZARUK David GreenFacts

ZONNEKEIN Marleen

ANN

EXES

cont’d


ANN

EXES

ANNEX 4PRESENTATIONS AVAILABLE ON REQUESTThis section presents an overview of the various speeches of the plenary session.

This sign indicates whenever the text of the speech and/or a complementary powerpoint presentation is available on request from the HERA secretariat:

Square Marie-Louise 49; 1000 Brussels; Tel. + 32 2 230 83 71; Fax. +32 2 230 82 88; e-mail: [email protected]

P L EN A RY PRE S EN TAT ION SRISK ASSESSMENT PARADIGM J.F.Solbé

PROBLEMS OF RISK COMMUNICATION Adam Burgess

RESULTS OF THE EUROBAROMETER SURVEY ON RISK PERCEPTIONPanagiotis Daskaleros

“10 REASONS NOT TO JOIN THE GARDEN CLUB” Franklin Apfel

THE ACTIVITIES OF THE JOINT RESEARCH CENTRE Demosthenes Papameletiou

ENGAGING WITH THE TRADE Sheila Kirkwood

TESTIMONIALS FROM COSMETICS INDUSTRIES Walter Aulmann

TESTIMONIALS FROM AUTOMOTIVE INDUSTRIES Urban Wass

TESTIMONIALS FROM FOOD INDUSTRIES Yasmine Motarjemi

PA NE L PRE S EN TAT ION STHE GLOBAL HARMONISATION SYSTEM AND CONSUMER

COMMUNICATION: ACTIVITIES IN THE NL Henk Roelfzema


CASE STUDY: THE NEW DETERGENT REGULATION Stephen Pickering

THE IMPORTANCE OF LABELLINGAndrew Fasey

THE DUTCH PILOT SITE “IS THIS PRODUCT SAFE?” Bert Beij

SCIENCE IN THE BOXAndrew Fisk

GREENFACTSDavid Zaruk

BEUC ACTIVITIESCharlotte de Roo

WWF ACTIVITIES Karl Wagner

TV ACTIVITIES Martine Lichtl

CONCL UDING RE M A R K SSAFETY, CONFIDENCE AND SOCIETY: FINAL REMARKSPhillip Whitehead, MEP

ANN

EXES


ANN

EXES

ANNEX 5LIST OF SPEAKERS

P L EN A RY PRE S EN TAT ION SFranklin ApfelWorld Health Communication Network – Little Harborne, Compton BishopSomerset, United Kingdom

Walter AulmannHenkel KgaA – Henkelstrasse 67, D-40191 Düsseldorf, Germanywww.henkel.com

Adam BurgessUniversity of Kent at Canterbury – Kent CT2 7NZ, United Kingdom

Panagiotis DaskalerosEuropean Commission – DG Sanco – Rue Belliard 232 B4, B-1000 Brusselshttp://europa.eu.int/dgs/health_consumer/index_en.htm

Sheila KirkwoodMcBride – Middleton way, M24 4DP Manchester, United Kingdom www.mcbride.co.uk

Yasmine MotarjemiNestlé – 55 Avenue Nestlé, CH-1800 Vevey, Switzerland www.nestle.com

Demosthenes PapameletiouJoint Research Center – Institute for Health and Consumer Protection, TP460, Via E.Fermi 1, I-21100 Ispra, Italywww.jrc.cec.eu.int

J.F. SolbéUnilever Home & Personal Care Europe – Quarry Road East, Bebington, Wirral CH63 3JW, United Kingdom

Urban WassVolvo Technologies – Dept. 6700, M14 40508 Gothenberg, Swedenwww.volvo.com


PA NE L PRE S EN TAT ION S

Bert BeijUnilever Home & Personal Care Europe – Postbus 1, NL-2410 Bodegraven, The Netherlandswww.unilever.com

Charlotte de RooBEUC – Avenue de Tervuren 36 Bte 4, B-1040 Brusselswww.beuc.org

Andrew FaseyProtection Through Knowledge Ltd. – Ivy Cottage, The Street, Binsted, Hampshire GU 34 4PB, United Kingdom Andrew FiskProcter & Gamble – route St.Georges 47, CH-1213 Petit Lancy, Switzerlandwww.pg.com

Martine LichtlLichtl Sustainability Communications – Eschborner Landstrasse 41-51, D-60489 Frankfurt Am Main, Germany www.lichtl.com

Stephen PickeringDG Enterprise E3 – Rue d’Arlon 88, B-1040 Brusselshttp://europa.eu.int/comm/dgs/enterprise/index_en.htm

Henk Roelfzema Dutch Ministry of Health – PB 20350, 2500 EJ Den Haag, The Netherlands

Karl WagnerWWF Detox Campaign – Avenue de Tervuren 36, B-1040 Brusselswww.panda.org/campaign/detox/

David ZarukGreenFacts – Rue des Palais 44, B-1030 Brusselswww.Greenfacts.org

CONCL UDING RE M A R K S

Phillip Whitehead, MEPEuropean Parliament – Bat. Altiero Spinelli, 13G205, Rue Wiertz 60, B-1047 Brusselswww.labmeps-emids.fsnet.co.uk

ANN

EXES


ANN

EXES

LIST OF EXHIBITSA.I.S.E.Contact: V. Séjourné / C. CullenSquare Marie-Louise 49, B-1000 Brusselswww.aise-net.org

CEFICContact: Annemaria OjanperäAvenue E. Van Nieuwenhuyse 4, B-1160 Brusselswww.cefic.org

GREENFACTSContact: David ZarukRue des Palais 44, B-1030 Brusselswww.Greenfacts.org

HENKELContact: Kerstin OchsHenkel KgaA – Henkelstrasse 67, D-40191 Düsseldorf, Germanywww.henkel.com

HERAContact: N. WerkersSquare Marie-Louise 49, B-1000 Brusselswww.heraproject.com

SCIENCE IN THE BOXContact: Andrew FiskProcter & Gamble – route St.Georges 47, CH-1213 Petit Lancy, Switzerlandwww.pg.com

UNILEVERContact: Alan BarberQuarry Road East, Bebington, UK CH63 3JW Wirral, United KingdomContact: Samantha Smith3 St. James Road, Kingston-upon-Thames, Surrey KTI2 BA, United Kingdomwww.unilever.com

DETOX CAMPAIGNContact: Karl WagnerWWF Detox Campaign – Avenue de Tervuren 36, B-1040 Brusselswww.panda.org/campaign/detox/

Square Marie-Louise 49B-1000 Brussels

Tel. +32 2 230 83 71Fax. +32 2 230 82 88

e-mail : [email protected]

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