In a letter sent to Atty. Juan Miguel Cuna, Director of the Environmental Management Bureau (EMB), the green groups led by the EcoWaste Coalition and the Global Alliance for Incinerator Alternatives (GAIA) sought for a policy that is in sync with the international consensus to phase out lead-added paints.
The groups were reacting to the EMB’s call for public comments regarding the final draft of the “Chemical Control Order (CCO) for Lead and Lead Compounds” as posted in the agency’s website.
Lead and lead compounds belong to the “Priority Chemicals List” of the Philippines that must be regulated, phased out or banned because of the serious risks these chemicals posed to public health, workplace, and in environment.
“The draft CCO must disallow the use of lead pigments in preparations and materials such as paint mixtures and children’s products and hasten industry shift to clean production via kid-safe alternatives to lead,” said Manny Calonzo of GAIA and the EcoWaste Coalition, stressing that “children are most susceptible to lead exposure and poisoning due to their hand-to-mouth and object-to-mouth activities and their smaller and still developing bodies.”
The draft CCO lists the use of lead in ‘paints, coatings and red lead primer” among the “allowable uses.” While there is a reference for “allowable limit,” the draft CCO contains no specification on what limit is to be allowed.
The draft CCO is not in step with the global consensus to prevent children’s exposure to lead via lead-added paints as well as minimize occupational exposure to leaded paints, the groups pointed out.
“If not improved, the CCO will run counter to chemical policy trends that are increasingly protective of children’s health. It would be very embarrassing for the Philippines to go against the global drive to protect children from being poisoned and harmed by lead-added paints and products,” the groups observed.
The groups cited paragraph 57 of the 2002 World Summit on Sustainable Development (WSSD) Plan of Implementation, which calls for the “phase out lead in lead-based paints and in other sources of human exposure, work to prevent, in particular, children’s exposure to lead and strengthen monitoring and surveillance efforts and the treatment of lead poisoning.”
They also cited a more recent decision in 2009 by the Second International Conference on Chemicals Management (ICCM2), which established the Global Alliance to Eliminate Lead Paints (GAELP) under the joint coordination of the World Health Organization (WHO) and the United Nations Environment Programme (UNEP).
According to GAELP, lead is a toxic metal affecting the multiple body systems, including the neurologic, hematologic, gastrointestinal, cardiovascular, and renal system.
For a stronger policy that will adequately protect children’s health and development from lead-added paints, the groups urged the DENR-EMB to revise the draft CCO as follows:
1. Set a mandatory standard that will explicitly and intentionally disallow the use of lead in paint in excess of 90 parts per million (ppm).
2. Expand the prohibition on the use of lead in “toys” to include “children’s articles” that will include children’s toys, jewelry, school supplies and other products intended for children.
3. Restrict “allowable uses” of lead to exclude such commercial and industrial uses where safer non-lead alternatives exist.
4. Emphasize essential information shall not be treated as confidential business information such as a) the total lead content of preparations or articles, b) commercial and industrial users of lead and lead compounds who have registered with the regulatory body, and c) information on health and safety issues pertaining to the use of these chemicals,
5. Require a health warning on lead-added preparations and articles.
6. Require an independent third party certification system that will confirm compliance with the “allowable limit” for lead in paint.
7. Strengthen provision for environmentally-sound management of lead-containing waste.
The 90 ppm lead in paint standard follows the recently revised US limit for lead-added paints applied for residential uses, and those applied for toys and consumer products designed for children age 12 and younger, the groups explained.
Laboratory tests abroad that were commissioned by the EcoWaste Coalition for 35 local paint samples in 2008 and for 25 samples in 2010 showed average lead concentration of over 300 times the US 90 ppm standard. The highest lead level found in the 2008 test conducted in India was 189,163.5 ppm, and 161,700 ppm for the 2010 test conducted in the USA.
Joining GAIA and the EcoWaste Coalition in pressing for kid-safe paints were the Angkan ng Mandirigma, Ang NARS, Arugaan, Ban Toxics, Buklod Tao, Cavite Green Coalition, Citizens Organization Concerned with Advocating for Philippine Environmental Sustainability, Green Convergence for Safe Food, Healthy Environment and Sustainable Economy, Greenpeace Southeast Asia, Interface Development Interventions Inc., Institute for the Development of Educational and Ecological Alternatives, Krusada sa Kalikasan, Miriam P.E.A.C.E., Mother Earth Foundation, November 17 Movement, Philippine Earth Justice Center, Philippine Network on Climate Change, Sanib Lakas ng mga Aktibong Lingkod ng Inang Kalikasan, Zero Waste Philippines, toxicologist Dr. Romy Quijano and beauty queen Cathy Untalan.
Final Draft CCO for Lead and Lead Compounds:
Global Alliance to Eliminate Lead in Paints: