111
be argued that society responded comparatively slower on PBDEs than on PCBs.
When measures were agreed though, the regulatory strength of the EU was much
greater than in the 1960s, even though the complex science-policy interface in EU
legislation, placing a very strong burden of proof for measures, led to signifi cant
policy delays.
13
When it comes to the policy approach, the PBDE group has been regulated
mainly on the basis of the chemicals and polluter-oriented policy, not based on an
environmental approach, and even less so on a precautionary approach. The latter is
particularly true for decaBDE , where action was stalled during lengthy and politicised decision-making and legal processes (Eriksson et al. 2010a , 2010b ). The
environment- oriented approaches in the case of MSFD , for example, have so far not
led to signifi cant phase-out measures in themselves, and there are obvious implementation problems. In the case of WFD, in its third implementation report, the
European Commission was unable to even establish a baseline for the chemical
status of surface waters due to data gaps and insuffi cient monitoring (more than 40
% of surface water bodies in the EU were reported as having ‘unknown chemical
status’) making it very diffi cult to estimate the EU-wide or Baltic Sea situation
(European Commission 2012 ). Similarly, while BSAP is based on EAM (in theory
linking hazardous substances, negatively, to biodiversity objectives on the one hand
and to eutrophication on the other, where goal achievement may lead to higher concentrations of pollutants in biota), the practical responses to these insights still have
to be implemented broadly. Nevertheless, BSAP sets out to link the work of
HELCOM-identifi ed substances to the national implementation plans under WFD,
thereby helping policy effi ciency in practice. More generally, the implementation of
BSAP may help to broaden the implementation of WFD in EU Member States , and
conversely, some environment-oriented EU policies may then be implemented in
the HELCOM context. As for PCBs , there is thus a positive interplay between EU
and HELCOM policies, when it comes to BFRs.
5.5 The Third Generation, Perfl uorinated Organic
Substances: PFOS and PFOA
Man-made fl uorinated organic chemicals are since long widely used in industrial
processes and commercial products and are commonly detected in organisms and
various environmental compartments, the most well-known case being the infamous chlorofl uorocarbons that have depleted the ozone layer (e.g. EEA 2001 ). One
complex group of fl uorinated organohalogens consists of perfl uorinated substances ,
which, due to not least their stability and surface-active properties, are commonly
used since the 1950s in, for instance, fi refi ghting foam, non-stick coatings, food
packaging and electronics, as well as for water and stain proofi ng in textiles and
13 Comprehensive policies for destruction and decontamination of products containing PBDEs, as
exist for PCBs, are still largely missing for PBDEs (see, e.g. Bergman 2012 ).
5 Governance of Chemicals in the Baltic Sea Region: A Study of Three Generations…
be argued that society responded comparatively slower on PBDEs than on PCBs.
When measures were agreed though, the regulatory strength of the EU was much
greater than in the 1960s, even though the complex science-policy interface in EU
legislation, placing a very strong burden of proof for measures, led to signifi cant
policy delays.
13
When it comes to the policy approach, the PBDE group has been regulated
mainly on the basis of the chemicals and polluter-oriented policy, not based on an
environmental approach, and even less so on a precautionary approach. The latter is
particularly true for decaBDE , where action was stalled during lengthy and politicised decision-making and legal processes (Eriksson et al. 2010a , 2010b ). The
environment- oriented approaches in the case of MSFD , for example, have so far not
led to signifi cant phase-out measures in themselves, and there are obvious implementation problems. In the case of WFD, in its third implementation report, the
European Commission was unable to even establish a baseline for the chemical
status of surface waters due to data gaps and insuffi cient monitoring (more than 40
% of surface water bodies in the EU were reported as having ‘unknown chemical
status’) making it very diffi cult to estimate the EU-wide or Baltic Sea situation
(European Commission 2012 ). Similarly, while BSAP is based on EAM (in theory
linking hazardous substances, negatively, to biodiversity objectives on the one hand
and to eutrophication on the other, where goal achievement may lead to higher concentrations of pollutants in biota), the practical responses to these insights still have
to be implemented broadly. Nevertheless, BSAP sets out to link the work of
HELCOM-identifi ed substances to the national implementation plans under WFD,
thereby helping policy effi ciency in practice. More generally, the implementation of
BSAP may help to broaden the implementation of WFD in EU Member States , and
conversely, some environment-oriented EU policies may then be implemented in
the HELCOM context. As for PCBs , there is thus a positive interplay between EU
and HELCOM policies, when it comes to BFRs.
5.5 The Third Generation, Perfl uorinated Organic
Substances: PFOS and PFOA
Man-made fl uorinated organic chemicals are since long widely used in industrial
processes and commercial products and are commonly detected in organisms and
various environmental compartments, the most well-known case being the infamous chlorofl uorocarbons that have depleted the ozone layer (e.g. EEA 2001 ). One
complex group of fl uorinated organohalogens consists of perfl uorinated substances ,
which, due to not least their stability and surface-active properties, are commonly
used since the 1950s in, for instance, fi refi ghting foam, non-stick coatings, food
packaging and electronics, as well as for water and stain proofi ng in textiles and
13 Comprehensive policies for destruction and decontamination of products containing PBDEs, as
exist for PCBs, are still largely missing for PBDEs (see, e.g. Bergman 2012 ).
5 Governance of Chemicals in the Baltic Sea Region: A Study of Three Generations…