Improving the regulatory environmental risk assessment of human pharmaceuticals: Required changes in the new legislation

One of the flagship actions of the Pharmaceutical Strategy for Europe is to address environmental challenges associated with pharmaceutical use. This includes strengthening the Environmental Risk Assessment (ERA) at marketing authorisation (MA) of pharmaceuticals, and revision of the pharmaceutical legislation where needed. The overall aim of an ERA should be to enable comprehensive and effective identification and management of environmental risks of pharmaceuticals without affecting the availability of pharmaceuticals to patients. As experts in the evaluation of ERAs of human medicinal products submitted by pharmaceutical industries (Applicants), we have summarized the current status of the ERA and suggest legislative changes to improve environmental protection without affecting availability. Six regulatory goals were defined and discussed, including possible ways forward: 1) mandatory ERAs in accordance to the EMA guideline at the time of the MA, 2) enforcement of risk mitigation measures including re-evaluation of the ERA, 3) facilitated exchange of environmental data between pharmaceutical and environmental legislations, 4) substance-based assessments, 5) transparency of data, and 6) a catching-up procedure for active pharmaceutical ingredients that lack an ERA. These legislative proposals can be considered as prerequisites for a harmonised assessment and effective management of environmental risks and hazards of human pharmaceuticals.

Organic farming offers promising mitigation potential in dairy systems without compromising economic performances

There is a lack of clear empirical evidence towards the lower carbon footprint of organic food products, in particular in the dairy sector. Until now, small sample sizes, lack of properly defined counterfactual and the omission of land-use related emissions have hindered comparisons of organic and conventional products. Here we bridge these gaps by mobilizing a uniquely large dataset of 3074 French dairy farms. Using propensity score weighting, we find that the carbon footprint of organic milk is 19% (95%CI = [10%-28%]) lower than its conventional counterpart without indirect land-use change and 11% (95%CI = [5%-17%]) lower with indirect land use changes. In both production systems, farms' profitability is similar. We simulate the consequences of the Green deal target of 25% of agricultural land devoted to organic dairy farming and show that this policy would reduce the greenhouse gas emissions of the French dairy sector by 9.01-9.64%.

Is the EU chemicals strategy for sustainability a green deal?

A fully integrated Chemicals Strategy for Sustainability (CSS) in respect of chemicals is crucial and must include: • An objective evaluation of the present situation including impacts of 'chemicals of concern' throughout their life cycle, that incorporates sustainability issues. • A framework that facilitates innovation of chemistry-based approaches to tackle each of the key sustainability issues. The EU CSS only addresses adverse impacts and mainly focusses on one aspect of risk assessment, the hazard to humans from individual industrial chemicals. The proposal removes consideration of the nature and amount of exposure, which is a critical determinant of risk. It can be presumed that this is solely to simplify, and hence speed up, regulatory decisions thereby enabling more chemicals to be assessed. The linkage of this proposed approach to address any of the major sustainability issues, such as environmental pollutants is obscure. For example, the well-recognised environmental problems caused by polymers such as plastics are not considered. The proposed change in the assessment methodology lacks any scientific justification and fails to address the sustainability issues the EU and the rest of the world are facing. The authors critically discuss a comprehensive innovative evaluation methodology for the impact of chemicals.

Exploring transformative policy imaginaries for a sustainable Post-COVID society

The COVID-19 crisis and its underlying health, socio-economic and environmental challenges warrants a discussion about transformative policies for a more sustainable, post-pandemic world. At EU level, policy packages and initiatives such as the European Green Deal (EGD), the Bioeconomy Strategy (BES) or the Circular Economy Action Plan (CEAP) may have the prerequisites to support a sustainable socio-economic transformation. But can these initiatives live up to public imaginaries of a sustainable post-pandemic world? To answer this question, we conducted a qualitative media analysis in order to outline emerging public imaginaries, as well as different policy suggestions put forth by different media outlets. We then grouped these imaginaries into seven major themes ranging from finance to resource management and city planning. With the help of the Delphi approach, we discussed these themes with a panel of ten international experts in order to scope for different transformative policy options. The public imaginaries we identified represent a mix of imaginaries underpinned by different political ideologies, economic philosophies and sustainability rationales. The highest expectations were connected to the EGD, although none of the EU policy packages can singlehandedly tackle the urgent sustainability challenges posed by the pandemic. However, the current trajectory of the EGD is geared towards the business-as-usual. We discuss how EU policies can overcome this limitation and imagine more radical transformation pathways in order to jumpstart a sustainable post-COVID recovery that goes beyond pursuing green growth.

Towards 'one substance - one assessment': An analysis of EU chemical registration and aquatic risk assessment frameworks

With the Green Deal the EU aims to achieve a circular economy, restore biodiversity and reduce environmental pollution. As a part of the Green Deal a 'one-substance one-assessment' (OS-OA) approach for chemicals has been proposed. The registration and risk assessment of chemicals on the European market is currently fragmented across different legal frameworks, dependent on the chemical's use. In this review, we analysed the five main European chemical registration frameworks and their risk assessment procedures for the freshwater environment, covering 1) medicines for human use, 2) veterinary medicines, 3) pesticides, 4) biocides and 5) industrial chemicals. Overall, the function of the current frameworks is similar, but important differences exist between the frameworks' environmental protection goals and risk assessment strategies. These differences result in inconsistent assessment outcomes for similar chemicals. Chemicals are also registered under multiple frameworks due to their multiple uses, and chemicals which are not approved under one framework are in some instances allowed on the market under other frameworks. In contrast, an OS-OA will require a uniform hazard assessment between all different frameworks. In addition, we show that across frameworks the industrial chemicals are the least hazardous for the freshwater environment (median PNEC of 2.60E-2 mg/L), whilst biocides are the most toxic following current regulatory assessment schemes (median PNEC of 1.82E-4 mg/L). Finally, in order to facilitate a successful move towards a OS-OA approach we recommend a) harmonisation of environmental protection goals and risk assessment strategies, b) that emission, use and production data should be made publicly available and that data sharing becomes a priority, and c) an alignment of the criteria used to classify problematic substances.

Biodiplomacy, the new frontier for bioeconomy

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Biodiplomacy is a novel governance of natural resources addressing the global challenges.

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Biodiplomacy is rooted in the sustainable circular bioeconomies across the globe.

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Biodiplomacy needs to integrate bioeconomy objectives together with those of the SDG.

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Biodiplomacy must be global, inspired and acting in the interest of human population.

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Biodiplomacy has a holistic approach for the sustainable management of natural resources.

Most of the initiatives to adapt, reduce and mitigate the effects of global challenges of our planet are currently dominated by the consequences of climate change. These are unintentionally overshadowing others such as food security, increase of human population, preservation of natural ecosystems, water scarcity and reliability of energy supply, amongst others. This fact tends to obscure the reality that most, if not all the global challenges, are closely interdependent and need a holistic approach to deal with them in a coherent and effective way. Likewise, society at large must be made fully aware that there will not be an enduring solution unless there is a change in the level of consumption of goods and energy in affluent countries. There is an increasing perception, understanding and concern in academic circles as well as in other sectors of society that the unsustainable production and consumption of natural resources need to be tackled by novel approaches. These combined efforts should ensure that they will be enacted in policy initiatives and in the actions that pave the way to building a global biodiplomacy. This new biodiplomacy should have the courage to develop and act in the interests of the human population overall, and not be undone by the legitimate but narrower interests of any single national priority. This article concludes by highlighting some of the key elements needed to give a biodiplomacy a chance to address, effectively, responsibly and synergistically, the current global challenges that affect mankind.

Computational modelling for the sustainable management of chemicals

This commentary explores the contribution of computational toxicology to chemical safety assessment in the context of the broad policy challenges faced by the European Union. The state of the European Environment is considered from the perspective of chemical contributions to the burden of disease and ecosystem damage. This sets the scene for highlighting research and innovation opportunities to further develop computational approaches for assessing the human health and environmental effects of chemicals. Emphasis is placed on focus topics that are particularly relevant to the political priorities of the new European Commission. In particular, two of the six priorities are discussed - “The European Green Deal” and “A Europe fit for a Digital Age”. The former includes the zero pollution ambition for a toxic-free environment, including the need to develop safe and sustainable chemicals, while the latter includes the challenges and opportunities posed by Artificial Intelligence. This commentary is based on a presentation given at the 19th meeting of The Italian Society of Toxicology (SITOX), held in Bologna, Italy, in February 2020.