The Precautionary Principle and Chemicals Regulation: Past Achievements and Future Possibilities (8 pages)

Background, Aim and Scope

The paper investigates the development of the institutional basis of the present modes of chemicals regulation and management, with special attention to interrelations with the precautionary principle. Main Features: The paper elucidates on how the precautionary principle has been shaped in relation to chemicals regulation and management since Carson's Silent Spring (years before the principle was confirmed as a policy-principle in German and European legislation. Furthermore, it is examined how the precautionary principle interacted with the development of the present chemicals regulatory regime, in a complex interplay within the OECD and Member Countries. The present modes of precaution in the new EU chemical legislation – REACH – are investigated with respect to the precautionary principle, and tested against two contemporary problems; brominated flame retardants and endocrine disrupting substances. Results: The analysis demonstrates the changing character of the integration of the precautionary principle. The main tendencies are from implicit to more explicit precaution and from a closed expert-orientation towards a more deliberative approach to scientific knowledge and uncertainty. The results demonstrate that the precautionary principle is manifest in both the design of the testing strategy and in policy provisions. In particular, the substitution of hazardous substances with less hazardous is important. Discussion: Despite explicit attention to the precautionary principle, is the present reformulation of the European Chemicals policy in danger of falling into loop-holes that equal problems related to the present regulation of existing chemicals? 'Precaution' has been reduced virtually to an abstract concept that is more or less devoid of practical meaning in the regulatory process. Conclusions: It is concluded that the role of the precautionary principle in chemicals regulation will require continued scrutiny in the future shaping of the REACH strategy. Perspectives: Continued development of robust and precaution-based chemicals regulation will have to involve both new data-generation strategies and new forms of political decision-making, with special attention given to transparency and deliberative policymaking.     

Data ranges in aquatic toxicity of chemicals

A significant problem for effect assessment of aquatic ecosystems arises from the large ranges of toxicity data, which can be found in different databases and literature. Here, ranges are given for the aquatic toxicity of 27 high production volume chemicals. Based on these illustrative examples and on the current literature on uncertainty in aquatic effect assessment, toxicity ranges are discussed for their possible causes (variation in experimental condition, species, endpoint, time) and ways to handle them (safety factors). Implications and recommendations on the procedure of risk analysis of chemical substances are drawn. Two main requirements for a comprehensive risk assessment are identified, which often play a minor role in current practice (as they are often neglected) as well as in scientific discussion (as they are meant to be trivial). First, data quality must be checked critically before applying any result of a toxicity test. Secondly, experimental data should take into account different species and acute as well as chronic data. If these aspects are considered in risk analysis, which is common practice in ecotoxicology but not always in the context of practical applications in risk engineering, a more comprehensive picture of the environmental toxicity of a chemical substance can be obtained.     

Regulating BFRs--from science to policy

An adequate distribution of responsibilities between scientists and policy-makers requires that a distinction be made between theoretical rationality (what to believe) and practical rationality (what to do). In chemical risk management, it is often necessary to base decisions on indications of risk that do not amount to full scientific proof. Guidelines are offered for how this can be done without infringing upon the integrity of science. Furthermore, it is shown that the application of standard decision theory to chemical risks yields conclusions very much in agreement with the precautionary principle.     

Ecological risk assessment of pollutant chemicals: extinction risk based on population-level effects

The extinction probability is one of the most useful endpoints that are utilized in conservation biology. A parallel approach is advocated for the ecological risk assessment of chemical pollutants. The presented framework estimates extinction probability induced by pollutant chemicals in order to evaluate ecological hazards of pollution, and is applicable to any biological community (aquatic or terrestrial). The analytical framework, which is based on stochastic population dynamics theory, is briefly explained. The extinction risk estimation is feasible if ecotoxicological data concerning pollutant effects on population growth rate of organisms (the intrinsic rate of natural increase), and if environmental exposure concentration is provided. Tentative risk estimation was made for some agrochemicals and surfactants on zooplankton populations (Daphnia) as target organisms.     

Fragrances in the Environment: Pleasant odours for nature? (9 pp)

Goal, Scope and Background Fragrance preparations or perfumes are used in an increasing variety of applications, as for example washing, cleansing, personal care products, consumer goods or in applications to modify indoor air. However, up to now, little is known to the general or scientific public about their chemical identity and the use pattern of single substances, not even for high production volume chemicals. Some toxicological data are published for a comparatively small number of substances with a focus on sensitisation and dermal effects, while other effects are neglected. Information on ecotoxicity and environmental fate are rare, especially for long-term exposure. Data for a detailed hazard and risk analysis are available in exceptional cases only. According to the current legal situation, fragrance industry is self-regulated, which means that pre-market risk evaluation is not required for most fragrances. Odour and the ability to smell play a major role for wildlife for all taxonomic groups. Reproductive and social behaviour, defence, communication and orientation depend on volatile compounds which can be identical to those used in fragrance preparations. Our interdisciplinary approach leads to the question of whether and, if so, to what extent anthropogenic fragrances may influence life and reproduction of organisms in the environment. Main Features Information from literature on use, exposure and biological effects was combined to analyse the state of knowledge. Following an overview of the amounts of fragrances used in different consumer products and their release into the environment, the roles of odours in nature are shown for a selection of compounds. Existing regulation was analysed to describe the data basis for environmental risk evaluation. Finally, recommendations for further action are derived from these findings. Results Three main results were elaborated: First, fragrance substances are continuously discharged in large amounts into the environment, especially via the waste water. Second, there are some indications of negative effects on human health or the environment, although the data basis is very thin due to the self regulation of the fragrance industry and the regulatory situation of fragrance substances. Third, many odoriferous substances used by man are identical to those which are signal substances of environmental organisms at very low concentrations, thus giving rise to specific mode of actions in the ecosystem. Recommendations For the adequate risk assessments of fragrances, test results on their unspecific as well as their specific effects as signal substances are needed. This would imply prioritisation methods and development of useful test methods for specific endpoints for appropriate risk assessments. Before a comprehensive testing and evaluation of results has been finished, a minimization of exposure should be envisaged. Eco-labelling of products containing acceptable fragrance ingredients could be a first step and provide consumers with the respective information. Transparency concerning the fragrance ingredients used and their biological potency will help to build up confidence between producers and consumers. Conclusions and Perspectives The interdisciplinary approach, bringing together chemical, biological, toxicological and ecotoxicological data with information provided by manufacturers and with legal and consumer aspects, offers new insights into the field of fragrance substances used in consumer products. The amounts and application fields of fragrance substances increases while fate and effects in the environment are hardly known. The current legal situation is not suited to elucidate the effects of fragrances on human health and the environment sufficiently, especially as it was shown that fragrances may play a considerable role in the ecosystem on the behaviour of organisms. According to the precautionary principle, the lack of knowledge should best be tackled by reducing exposure, especially for compounds such as fragrance substances where no ethical reasons object a substitution by less hazardous chemicals. ESS-Submission Editor: Dr. Thomas Knacker (th-knacker@ect.de)     

Power analysis as a reflexive scientific tool for interpretation and implementation of the precautionary principle in the European Union

The diversity of interpretation, the subsequent lack of implementation, and the enforcement of the precautionary principle have been important issues in the European environmental discourse for the past five years. The European Commission published a communication on the Commission's interpretation of the precautionary principle on February 2nd, 2000. However, the distinction between precaution and prevention is absent in the EU Commission's interpretation, resulting in the communication's lacking relevance for the precautionary principle. The important consequence of the precautionary concept in policy and decision-making is that it should not be based on an assumed certainty of the certainty of environmental knowledge--but rather on a certainty of the uncertainty of environmental knowledge. In other words, the regulation should, to a greater extent, be based on the management of uncertainty, and risk assessments should explicitly present and discuss related uncertainty and lack of knowledge. The management of uncertainty should be based on setting the acceptable level of risk of accepting a failure to reject the null hypothesis of no adverse effects (beta). This is done by setting the required power (1-beta) according to a socioeconomic cost-benefit analysis. Moreover, the acceptable ecological effect size (A) could also be set a priori which would have implications for the power of a study. Reversal of the burden of proof could be considered in order to resolve possible legal implications for the risk managers.     

European union system for the evaluation of substances: the second version

This publication presents major changes in the assessment of the risks of chemicals to human health and the environment as implemented in the second version of the European Union System for the Evaluation of Substances, EUSES 2.0. EUSES is a harmonised quantitative risk assessment tool for chemicals. It is the PC-implementation of the technical guidelines developed within the framework of EU chemical legislation for industrial chemicals and biocides. As such, it is designed to support decision making by risk managers in government and industry and to assist scientific institutions in the risk assessment for these substances. The development of EUSES 2.0 is a co-ordinated project of the European Chemicals Bureau, EU Member States and the European chemical industry. Several model concepts, the technical background and the user interface of EUSES have been improved considerably. Major changes in the environmental assessment such as the implementation of emission scenario documents for industrial chemicals and biocides, the addition of the marine risk assessment, the enhancement of the regional model to include global scales, and improvements in the secondary poisoning and environmental effects modelling will be discussed. The update of the human risk assessment module in EUSES focuses on the risk characterisation for both threshold and non-threshold substances with, among others, the introduction of assessment factors. The performance of EUSES is illustrated in an example showing the human and environmental risk assessment of a sanitation disinfectant for private use.     

Opportunities for a probabilistic risk assessment of chemicals in the European Union

In risk assessment of new and existing substances, it is current practice to characterise risk using a deterministic quotient of the exposure concentration, or the dose, and a no-effect level. A sense of uncertainty is tackled by introducing worst-case assumptions in the methodology. Since this procedure leads to an assessment with an unknown degree of conservatism, it is advisable to deal quantitatively with uncertainties. This paper discusses the advantages and possibilities of a probabilistic risk assessment framework, illustrated with an example calculation. Furthermore, representatives of EU Member States and the chemical industry were interviewed to find out their views on applying uncertainty analysis to risk assessment of industrial chemicals.     

The U.S. Experience in Promoting Sustainable Chemistry (9 pp)

- Sustainable chemistry - Section editors: Klaus Günter Steinhäuser, Steffi Richter, Petra Greiner, Jutta Penning, Michael AngrickBackground, Aim and Scope Recent developments in European chemicals policy, including the Registration, Evaluation and Authorization of Chemicals (REACH) proposal, provide a unique opportunity to examine the U.S. experience in promoting sustainable chemistry as well as the strengths and weaknesses of existing policies. Indeed, the problems of industrial chemicals and limitations in current regulatory approaches to address chemical risks are strikingly similar on both sides of the Atlantic. We provide an overview of the U.S. regulatory system for chemicals management and its relationship to efforts promoting sustainable chemistry. We examine federal and state and examine lessons learned from this system that can be applied to developing more integrated, sustainable approaches to chemicals management.Main Features There is truly no one U.S. chemicals policy, but rather a series of different un-integrated policies at the federal, regional, state and local levels. While centerpiece U.S. Chemicals Policy, the Toxic Substances Control Act of 1976, has resulted in the development of a comprehensive, efficient rapid screening process for new chemicals, agency action to manage existing chemicals has been very limited. The agency, however, has engaged in a number of successful, though highly underfunded, voluntary data collection, pollution prevention, and sustainable design programs that have been important motivators for sustainable chemistry. Policy innovation in the establishment of numerous state level initiatives on persistent and bioaccumulative toxics, chemical restrictions and toxics use reduction have resulted in pressure on the federal government to augment its efforts.Results and Conclusions It is clear that data collection on chemical risks and phase-outs of the most egregious chemicals alone will not achieve the goals of sustainable chemistry. These alone will also not internalize the cultural and institutional changes needed to ensure that design and implementation of safer chemicals, processes, and products are the focus of the future. Thus, a more holistic approach of ‘carrots and sticks’ – that involves not just chemical producers but those who use and purchase chemicals is necessary. Some important lessons of the US experience in chemicals management include: (1) the need for good information on chemicals flows, toxic risks, and safer substances.; (2) the need for comprehensive planning processes for chemical substitution and reduction to avoid risk trade-offs and ensure product quality; (3) the need for technical and research support to firms for innovation in safer chemistry; and (4) the need for rapid screening processes and tools for comparison of alternative chemicals, materials, and products.     

Principles and perspectives

BACKGROUND, AIM AND SCOPE: With respect to the enormous increase of chemical production in the last decades and the tens of thousands of individual chemicals on the market, the permanent improvement of chemical management is a permanent target to achieve the goals of sustainable consumption and production set by the WSSD in Johannesburg 2002. MAIN FEATURES: Several approaches exist to describe sustainability of chemistry. However, commonly agreed criteria are still missing. There is no doubt that products of modern chemistry help to achieve important goals of sustainability and that significant improvements have occurred regarding direct releases from production sites, but several facts demonstrate that chemistry is far from being sustainable. Still too many chemicals exhibit hazardous characteristics and pose a risk to health and environment. Too many resources are needed to produce chemicals and finished products. RESULTS AND CONCLUSION: Therefore, a strategy for sustainability of chemistry should be developed which comprises the following main elements: 1. Sustainable chemicals: sustainable chemical management includes a regulatory framework which makes no difference between new and existing chemicals, contains efficient information flow through the supply chain which allows users to handle chemicals safely and offers an authorisation procedure and/or an efficient restriction procedure for substances of high concern. This regulatory scheme should promote the development of inherently safe chemicals. 2. Sustainable chemical production: Sustainable chemical production needs the development and implementation of emerging alternative techniques like selective catalysis, biotechnology in order to release less CO2 and less toxic by-products, to save energy and to achieve higher yields. Information exchange on best available techniques (BAT) and best environmental practices (BEP) may help to promote changes towards more sustainability. 3. Sustainable products: An integrated product policy which provides a framework for sustainable products promotes the development of products with a long-term use phase, low resource demand in production and use, low emission of hazardous substances and properties suitable for reuse and recycling. This may be promoted by eco-labelling, chemical leasing concepts and extended information measures to enhance the demand of consumers and various actors in the supply chain for sustainable products. RECOMMENDATION AND PERSPECTIVE: Important tools for the promotion of sustainable chemistry are the abolition of barriers for innovation in legislation and within the chemical industry, more transparency for all users of chemical products, a new focus on sustainability in education and research, and a new way of thinking in terms of sustainability.     

Integrated testing and intelligent assessment—new challenges under REACH

BACKGROUND, AIM AND SCOPE: Due to a number of drawbacks associated with the previous regime for the assessment of new and existing chemicals, the European Union established a new regulation concerning the registration, evaluation, authorisation and restriction of chemicals (REACH). All relevant industrial chemicals must now be assessed. Instead of the authorities, industry itself is responsible for the risk assessment. To achieve better and more efficient assessments while reducing animal testing, all information-standard, non-standard and non-testing-has to be used in an integrated manner. To meet these challenges, the current technical guidance documents for risk assessment of new and existing chemicals had to be updated and extended considerably. This was done by experts in a number of REACH Implementation Projects. This paper presents the most relevant results of the expert Endpoint Working Group on Aquatic Toxicity in order to illustrate the change of paradigm in the future assessment of hazards to the aquatic environment by chemical substances. MAIN FEATURES AND CHALLENGES: REACH sets certain minimum data requirements in order to achieve a high level of protection for human health and the environment. It encourages the assessor to use alternative information instead of or in addition to standard one. This information has to be equivalent to the standard information requirement and adequate to draw overall conclusions with respect to the regulatory endpoints classification and labelling, persistent, bioaccumulative and toxic (PBT) assessment and predicted no-effect concentrations (PNEC) derivation. The main task of the expert working group was to develop guidance on how to evaluate the toxicity of a substance based on integration of information from different sources and of various degrees of uncertainty in a weight of evidence approach. INTEGRATED TESTING AND INTELLIGENT ASSESSMENT: In order to verify the equivalence and adequacy of different types of information, a flexible sequence of steps was proposed, covering characterisation of the substance, analysis of modes of action, identification of possible analogues, evaluation of existing in vivo and in vitro testing data as well as of QSAR results. Finally, all available data from the different steps have to be integrated to come to an overall conclusion on the toxicity of the substance. This weight of evidence approach is the basis for the development of integrated testing strategies (ITS), in that the available evidence can help to determine subsequent testing steps and is essential for an optimal assessment. Its flexibility helps to meet the different requirements for drawing conclusions on the endpoints classification and labelling, PNEC derivation as well as PBT assessment. The integration of all kinds of additional information in a multi-criteria assessment reduces the uncertainties involved with extrapolation to the ecosystem level. The weight of evidence approach is illustrated by practical examples. CONCLUSIONS AND PERSPECTIVES: REACH leads to higher challenges in order to make sound decisions with fewer resources, i.e. to move away from extensive standard testing to an intelligent substance-tailored approach. Expert judgement and integrated thinking are key elements of the weight of evidence concept and ITS, potentially leading to better risk assessments. Important sub-lethal effects such as endocrine disruption, which are not covered by the current procedure, can be considered. Conclusions have to be fully substantiated: Risk communication will be an important aspect of future assessments.     

Development and implementation of surface water quality standards for protection of human health in Korea

Current water quality standards for the protection of human health in Korea include 17 substances found in rivers and streams. Due to increasing concern over the release of hazardous chemicals into the aquatic environment, there has been a demand for additional water quality standards. Therefore, the Korean Ministry of the Environment plans to gradually increase the number of water quality standards to 30 substances, including 22 substances for protection of human health and 8 substances for protection of aquatic ecosystems by 2015. In this study, new water quality standards for protection of human health were established for 1,4-dioxane, formaldehyde, and hexachlorobenzene. We selected candidate hazardous chemicals, conducted a human health risk assessment to determine priority chemicals, established water quality standards based on technical analyses and comparison with domestic and developed countries’ water quality standards, and conducted an expert review. Water quality standards for protection of aquatic ecosystems will be derived in the near future. This study describes how the water quality standards for protection of human health were developed and implemented. Current status, recent expansion, and future plans for water quality standards in Korea are also covered.     

A rule-based screening environmental risk assessment tool derived from EUSES

Within the context and scope of the forthcoming European Union chemical regulations (REACH), there is a need to be able to prioritise the chemicals for evaluation. Therefore, a simple, pragmatic and adequately conservative approach for the identification of substances of very low or no immediate concern at an early stage is presented. The fundamental principles and basic concepts are derived from the EU Technical Guidance Document and EUSES, and are translated into an easy-to-use rule-based system. For this development, the effect on risk characterisation ratios (RCRs) of the key environmental parameters in EUSES was quantified (taking into account several standardised chemical release scenarios). Using statistical analysis, ranges were identified for each key parameter, within which the end result of the assessment was not significantly affected. This information was then translated into a lookup table from which environmental risk characterisation ratios can be directly read as a function of a few parameters.     

环境应急信息管理平台

环境应急信息管理平台是以信息化技术手段作为支撑的、面向环境应急事件的综合性的信息管理、事态预测、应急决策系统。系统以GIS为基础,可以快速地了解突发环境事件的发展状况,同时通过对环境背景数据库、空间信息数据库、环境应急专项数据库中的相关知识与数据进行综合分析,建立污染物扩散模型以及辅助决策模型,为决策者快速提供一个直观、科学、合理、优化的应急处置方案和指挥调度方案,并能够为事件后期评估、科学制定善后处理措施提供必要保障。     

Decision-support software tools for integrated risk assessment of hazardous substances in complex terrain

This paper presents the ongoing research at the Swiss Federal Institute of Technology (ETH), Zurich, related to the design and implementation of an IDSS (integrated decision support system) dedicated to integrated risk assessment and safety management with application to the transportation of hazardous substances. One of the goals is to construct advanced models to estimate (a) the optimal routing for transportation of hazardous substances and (b) optimise plans for emergency preparedness and management in case of potential (severe) accidents. As an output of this activity one aims at designing tools to represent risk to the public by using a GIS calculation platform, generically applicable to Switzerland. Though a database of some 700 chemicals is available, epichlorohydrin is the hazardous substance targeted in the first phase.     

Effluent impact assessment using microarray-based analysis in common carp: a systems toxicology approach

Effluents are a main source of direct and continuous input of pollutants to the aquatic environment, and can cause ecotoxicological effects at different levels of biological organization. Since gene expression responses represent the primary interaction site between environmental contaminants and biota, they provide essential clues to understand how chemical exposure can affect organismal health. The aim of the present study was to investigate the applicability of a microarray approach for unraveling modes of action of whole effluent toxicity and impact assessment. A chronic toxicity test with common carp (Cyprinus carpio) was conducted where fish were exposed to a control and 100% effluent for 21 days under flow-through conditions. Microarray analysis revealed that effluent treatment mainly affected molecular pathways associated with the energy balance of the fish, including changes in carbohydrate and lipid metabolism, as well as digestive enzyme activity. These gene expression responses were in clear agreement with, and provided additional mechanistic information on various cellular and higher level effects observed for the same effluent. Our results demonstrate the benefit of toxicogenomic tools in a “systems toxicology” approach, involving the integration of adverse effects of chemicals and stressors across multiple levels of biological complexity.     

One-at-a-time sensitivity analysis of pollutant loadings to subsurface properties for the assessment of soil and groundwater pollution potential

Chemical leak was numerically simulated for four chemical substances: benzene (light non-aqueous phase liquid (NAPL)), tetrachloroethylene (dense NAPL), phenol (soluble in water), and pentachlorophenol (white crystalline solid) in a hypothetical subsurface leak situation using a multiphase compositional transport model. One metric ton of chemical substances was assumed to leak at a point 3.51 m above the water table in a homogeneous unconfined aquifer which had the depth to water table of 7.135 m, the hydraulic gradient of 0.00097, the recharge rate of 0.7 mm/day, and the permeability of 2.92?×?10^?10 m². For comparison, surface spill scenarios, which had a long pathway from source to the water table, were simulated. Using the model results, point-source pollutant loadings to soil and groundwater were calculated by multiplying mass, impact area, and duration above and below the water table respectively. Their sensitivity to subsurface properties (depth to water table, recharge rate, porosity, organic carbon content, decay rate, hydraulic gradient, capillary pressure, relative permeability, permeability) was analyzed, with changing each parameter within acceptable ranges. The study result showed that the pollutant loading to groundwater was more sensitive to the subsurface properties than the pollutant loading to soil. Decay rate, groundwater depth, hydraulic gradient and porosity were influential to pollutant loadings. The impact of influential parameters on pollutant loadings was nonlinear. The dominant subsurface properties of pollution loadings (e.g., decay rate, groundwater depth, hydraulic gradient, and porosity for groundwater) also affect the vulnerability, and the subsurface pollutant loadings defined in this study are dependent on chemical properties as well, which indicates that the influential hydrogeological and physicochemical parameters to pollutant loadings can be used for pollution potential assessment. The contribution of this work is the suggestion that the sensitivity of pollutant loadings can be used for pollution potential assessment. Soil and groundwater pollution potential of chemicals are discussed altogether for leak scenarios. A physics-based model is used to understand the impact of subsurface properties on the fate and transport of chemicals above and below the water table, and consequently their impact on the pollutant loading to soil and groundwater.

     

Using Multimedia Modeling to Expedite Site Characterization

GOAL, SCOPE AND BACKGROUND: This paper uses two case studies of U.S. Department of Energy nuclear weapons complex installations to illustrate the integration of expedited site characterization (ESC) and multimedia modeling in the remedial action decision making process. CONCEPTUAL SITE MODELS, MULTIMEDIA MODELS, AND EXPEDITED SITE CHARACTERIZATION: Conceptual site models outline assumptions about contaminates and the spatial/temporal distribution of potential receptors. Multimedia models simulate contaminant transport and fate through multiple environmental media, estimate potential human exposure via specific exposure pathways, and estimate the risk of cancer and non-cancer health outcomes. ESC relies on using monitoring data to quantify the key components of an initial conceptual site model that is modified iteratively using the multimedia model. CASE STUDIES: Two case studies are presented that used the ESC approach: Los Alamos National Laboratory (LANL) and Pantex. LANL released radionuclides, metals, and organic compounds, into canyons surrounding the facility. The Pantex Plant has past waste management operations which included burning chemical wastes in unlined pits, burying wastes in unlined landfills, and discharging plant wastewaters into on-site surface waters. CONCLUSIONS: The case studies indicate that using multimedia models with the ESC approach can inform assessors about what, where, and how much site characterization data needs to be collected to reduce the uncertainty associated with risk assessment. Lowering the degree of uncertainty reduces the time and cost associated with assessing potential risk and increases the confidence that decision makers have in the assessments performed.     

Environmental risks of chemicals and genetically modified organisms: a comparison. Part II: Sustainability and precaution in risk assessment and risk management

The principles of precaution and sustainability require more consideration in the assessment of environmental risks posed by chemicals and genetically modified organisms. Instead of applying risk reduction measures when there are serious indications for damage, full scientific certainty is often waited for before taking action. The precautionary principle particularly should be applied in those cases in which the extent and probability of damage are uncertain, e.g. in the case of persistent chemicals which are additionally bioaccumulative or highly mobile. Based on these principles, environmental action targets for risks associated with GMOs and chemicals can be developed. Risk management not only includes statutory measures but also instruments designed to influence behaviour indirectly are important to achieve the goals. Particularly for risks of GMOs which provoke fear, risk communication is important. Some rules to which attention should be paid in communication with the public are presented.