Lead Limits Policy

Participants said that some assessment of the liabilities would be useful, and those assessments could lead to policies that may limit liabilities, which could have a positive impact on corporate investments. 

Heavy Metals Limits (Policy) The Committee on Food Chemicals Codex notes the importance of providing limits for individual heavy metals as required by the source and composition of individual food additives. Thus, it has decided to remove from most monographs the general heavy metals (as lead) limits and tests and, based on the current level and availability of scientific information and on the policy stated below, to replace them with limits and tests for specific heavy metals such as lead, cadmium, and mercury as may be relevant to each substance. 

Revision Lead and Heavy Metals Limits (Policy) revised to remove the heavy metals (as Pb) specifications and to replace them with individual tests for relevant heavy metals. 

NGOs remain(ed) critical of the list, however, because it represents a step back from the international consensus achieved with the WTO Decision. In the negotiations leading up to the Decision, several developed countries proposed to limit its scope to addressing specific diseases or just applying to specific pharmaceutical products. These efforts were roundly condemned by civil society activists as unethical and unsound health policy, and firmly rejected by developing countries. Ultimately, all WTO members agreed that there would be no such limitations. 

Although the decision associated with the application of a standard is a decision with a pass or fail value, the application of a standard implies recognition of uncertainty underlying its derivation and in the assessment of compliance. The exceedance of a speed limit by a few miles per hour does not usually lead to prosecution. This may be because the standard is precautionary or because the measuring device is not 100% accurate. The police might choose to act only when the limit is exceeded by, say, 10%, a policy that reflects issues of confidence and precision and the consequences of the violation in terms of the risk of accidents. At greater exceedances of the speed limit, more serious consequences for the offender are likely therefore, the absolute limit value of the speed limit is not necessarily implemented as an absolute limit that if exceeded will result in equivalent consequences. 

To implement such near optimal control algorithms would require considerable space and time on a process minicomputer because of the severe nonlinearities in the process, and therefore it is prdbaUy impractical in most situations. However, off-line simulations of this control policy shows some upper-limits as to what could possibly be accomplished and the nature and magnitudes of the feedrate manipulations that are necessary. This can then lead to the development of simpler heuristic-type control algorithms which capture the impextant aspects of the optimal control but are more easily implemented on-line. 

Three basic principles have emerged as common themes in these policies the Polluter Pays Principle clarifies who bears the costs for chemical contamination the Substitution Principle encourages the adoption of the safest chemicals and the Precautionary Principle promotes preventive action even in the face of the uncertainties of risks (see Section 3.3.2 for a more in depth discussion of the Precautionary Principle). Specifically, the new national chemicals policies of Northern European countries have relied on rapid screening tests for determining regulatory actions on chemicals, focused on products and product lifecycles for risk reduction, established lists of undesirable substances, and, in limited cases, employed government authority to phase out the use of the most hazardous substances such as lead, mercury, cadmium, brominated flame retardants and chlorinated paraffins (for a more extensive review, see Tickner and Geiser, 2003, www.chemicalspolicy.org). 

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