Framework for combining REACH and national regulations to obtain equal protection levels of human health and the environment in different countries – Comparative study of Denmark and Korea

Abstract

The aim of this paper is to present a conceptual framework for a systems approach to protect the environment and human health by taking into account differences in the cumulative risks of total human exposure in a territorial context. To this end the measures that are available and that can be included in REACH exposure scenarios in order to obtain territorially relevant chemical safety assessments (CSAs) were explored. The advantage of linking the REACH exposure scenarios with background environmental quality data reported under other national regulations is discussed. The main question is how REACH may be improved to protect the environment and human health inside and outside the EU. This question is exemplified in a comparative case study of two countries, Denmark and Korea, each with its own set of different environmental qualities and national regulations. As a member of the EU Denmark is obliged to adopt REACH, while Korea implemented REACH to improve the competitiveness of Korean industry within the EU market. It is presented how differences in national regulations and environmental qualities in these two countries affect background human exposure concentrations. Choosing lead as a model compound, the territorial differences in background exposure to endocrine and neurological interfering stressors were modelled. It is concluded that the different territorial soil and air lead pollution levels contribute differently to the total childhood lead exposure in the two countries. As such, the probability of the total exposure from air and soil exceeding 10% of the provisional Total Daily Intake (PTDI) is estimated to be 55.3% in Denmark and 8.2% in Korea. The relative contribution from air inhalation and soil ingestion to childhood lead exposure is estimated to be 1–99% in Denmark while it is 83–17% in Korea.