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Professor Ragnar Lofstedt, Professor of Risk Management and the Director of the King's Institute for Risk Research, King's College London and Editor of the Journal of Risk Research, has published a paper suggesting that the substitution principle is not the "white knight" as described by a number of regulatory agencies and NGOs and proposes that chemical substitution can only work effectively on a case-by-case basis.
Lofstedt uses evidence discussed in the paper to make recommendations for the future use of the chemical substitution principle, including the abolition of numerical targets set by regulatory bodies such as the European Chemical Agency for listing chemical substances of very high concern (SVHCs), and that, if the substitution principle is to be properly implemented, there is a need to do 'comparative risk evaluations or risk-ranking exercises, to uncover how great the risk profile of the chemical in question actually is'.
The paper further suggests that greater support for evidence-based substitution and academic research into the scientific underpinnings of the chemical substitution principle is needed, along with a need for clear case studies and scientifically informed debates to help politicians become better informed about the pros and cons of the substitution principle.
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