The Right to Know – Modernising the Rotterdam Convention | Road to 2025 BRS COPs

About this Event

This event will focus on making visible the invisible occupational health and safety (OHS) victims of chemicals in general and in particular of those chemicals the Chemical Review Committee (CRC) has recommended for listing onto Annex III of the Rotterdam Convention, but which have yet to be listed by the COP.

In June 2022, the International Labour Conference decided to amend the ILO Declaration on Fundamental Principles and Rights at Work (1998) to include “a safe and healthy working environment” as a fundamental principle and right at work. In line with this decision the ILC then also decided to designate the Occupational Safety and Health Convention (no. 155, 1981) and the Promotional Framework for Occupational Safety and Health Convention (no. 187, 2006) as fundamental conventions. This now means that every ILO member state is required to respect and promote the right to a safe and healthy working environment.

Panelists will present and discuss how this fundamental change in the Human Rights landscape is contributing to increasing the visibility of OHS victims of hazardous chemicals and what steps need to be taken to make Governments in general, and Parties to the Rotterdam Convention in particular, yet more aware of the urgent need to increase the effectiveness of this Convention so as to align its implementation with these fundamental human rights. The objective is to highlight a stronger human rights perspective and discuss the important role the Rotterdam Convention, in particular the PIC mechanism, plays in helping to protect workers from exposures to these hazardous chemicals. Panelists will also present case studies highlighting the harms caused by exposures to non-listed chemicals and reveal how the Convention is being misrepresented by industry. The objective is to make delegates and participants more aware of the human and economic costs of OHS exposure to hazardous chemicals, in particular those recommended by the CRC for listing.

Road to 2025 BRS COPs

In the lead up to the 2025 Meetings of the Conferences of the Parties to the Basel, Rotterdam and Stockholm Conventions, taking place from 28 April to 9 May 2025 in Geneva, the Geneva Environment Network is collaborating with various partners, including the BRS Secretariat, for a series of events providing information on preparations and facilitating dialogues on key issues to be discussed at the meetings.

Speakers

By order of intervention. 

Halshka GRACZYK

Technical Specialist, Technical Specialist, Occupational Safety and Health and Working Environment Branch (OSHE), International Labour Organization (ILO)

Marcos ORELLANA

UN Special Rapporteur on toxics and human rights

Phillip HAZELTON

Campaign Coordinator, Union Aid Abroad APHEDA

Leo YOGA PRANATA

Director for Public Policy and Advocacy, LION Indonesia

Sheila WILLIS

Head of International Programmes, Pesticide Action Network UK

Vera NGOWI

Senior Lecturer, Muhimbili University of Health and Allied sciences, Tanzania

Kay WILLIAMS

Head, Global Framework on Chemicals

Bernhard HEROLD

Senior Advisor for Decent Work and OSH, Solidar Suisse | Moderator

Highlights

Video

Summary

Welcome

Bernhard HEROLD | Senior Advisor for Decent Work and OSH, Solidar Suisse | Moderator

• Workers are the first and last users of chemicals, with more than 1 billion workers worldwide exposed to hazardous substances. Tragically, each year, as a result of these exposures, more than 1 million workers usually die.
• In June 2022, the International Labor Conference decided to amend the ILO Declaration on Fundamental Principles and Rights at Work to include a safe and healthy working environment as a fundamental principle and right at work. This landmark decision, elevating the right to a safe and healthy working environment, means that all 187 member states of the ILO now have an obligation to respect, promote, and realize this new fundamental right.
• The event shows how this important decision is created in greater awareness of occupational victims of hazardous chemicals and is encouraging stronger action to prevent exposures. It highlights not only the importance of a rights-based approach to occupational safety and health and chemicals management but also the valuable role of the Rotterdam Convention and particularly its Prior Informed Consent (PIC) procedure in enabling these rights and specifically the right to know.
• This highlights not only the important role that the convention can play in preventing hazardous exposures but also the challenges that it is currently facing in failing to list chemicals that meet all the criteria for listing.

Panel Discussion

Halshka GRACZYK | Technical Specialist, Occupational Safety and Health and Working Environment Branch (OSHE), International Labour Organization (ILO)

The right to know is crucial for protecting workers from chemical hazards in the workplace, where exposure levels are significantly higher and longer-lasting than in the general population.

• Every year, approximately one million workers die due to chemical hazards, though this is likely an underestimate, with many more suffering lifelong disabilities and chronic illnesses. Around 80% of these deaths are caused by long-term diseases such as cancer, neurodegenerative disorders, and respiratory issues. No sector or region is spared, with chemical exposures present in industries like mining, agriculture, manufacturing, and textiles, necessitating urgent action.
• The ILO, a specialized UN agency, operates through a tripartite structure involving 187 member states, workers’ unions, and employer organizations to create and implement labor standards. In 2022, the ILO recognized a safe and healthy working environment as a fundamental right, which includes the right to know, alongside other rights such as access to training and education on workplace hazards, participation in occupational safety and health (OSH) decision-making, and the ability to remove oneself from dangerous conditions without fear of retaliation.
• The right to know is essential because many chemical exposures in the workplace are invisible, such as fibers, dust, and vapors, making it difficult for workers to recognize the dangers they face. Access to information enables workers to take necessary safety precautions, including selecting the appropriate personal protective equipment (PPE), which varies based on the specific chemical hazards present—ranging from basic face masks to full-face respirators. The right to know ensures that workers can make informed decisions regarding their health and safety.
• A key component of the right to know is access to critical hazard identification information, such as the toxicity, flammability, and reactivity of chemicals, as well as their acute and chronic health effects. This information is often provided through safety data sheets and adherence to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Clear hazard communication is essential to ensuring that workers understand the risks they are exposed to and can take appropriate protective measures.

The right to know extends beyond individual protection to fostering a culture of workplace safety. Workers must be engaged in safety management and have a role in improving workplace safety related to chemical exposure. This goes beyond protecting individual workers—it ensures that entire workplaces are safe and helps prevent large-scale industrial accidents that could affect surrounding communities and public health. Chemical safety is not just a workplace issue but an environmental and societal one.

The legal basis for the right to know is firmly established in international labor standards.

• ILO Convention 155, a fundamental convention recognized in 2022, mandates that employers provide workers with adequate information and training on OSH and facilitate consultation and negotiation on safety matters. Convention 187 reinforces this at the national level by requiring governments to develop a preventative safety and health culture that includes the exchange of information between employers and workers, as well as consultation and training.
• In addition to workplace-specific chemical hazard information, the right to know includes access to records of occupational diseases, injuries, and deaths related to chemical hazards. The protocol to the Safety and Health Convention requires that workers be informed about incidents of occupational accidents, dangerous occurrences, and suspected cases of occupational diseases linked to chemical exposure. This ensures transparency and accountability in workplace safety.
• ILO Convention 170 specifically addresses chemical risks in the workplace and enshrines the principle that workers have a right to information about the chemicals they use. Various articles within the convention establish concrete obligations, such as the requirement for clear and easily understandable chemical labeling (Article 7), the provision of safety data sheets and maintenance of chemical records by employers (Article 10), and proper labeling of chemicals during transportation between workplaces (Article 11).
• Monitoring and record-keeping of worker exposure is critical, particularly for substances like silica and asbestos, where health effects may not manifest until decades later. Article 12 of Convention 170 requires that records of chemical exposure be maintained and made accessible to workers. This is essential for diagnosing occupational diseases and ensuring long-term accountability for workplace safety.
• Beyond access to information, training is also a fundamental aspect of the right to know. Article 15 of Convention 170 mandates that employers not only provide hazard information but also ensure that workers are trained on how to read and interpret chemical labels and safety data sheets, as well as how to use protective equipment and implement preventive measures. Simply knowing about hazards is not enough—workers must be empowered with the skills to protect themselves effectively.
• Article 18 of Convention 170 further reinforces the right to information, requiring that workers have access to details on the identity of chemicals, their hazardous properties, necessary precautionary measures, and appropriate training. The convention establishes a legally binding framework to protect workers from chemical risks, with additional recommendations and codes of practice providing further guidance.
• Countries are encouraged to ratify these conventions and integrate their provisions into national legislation. Even in cases where conventions have not been formally ratified, many national legal frameworks have incorporated these principles, especially following the 2022 recognition of occupational safety and health as a fundamental right. Workers’ protection from chemical hazards is a global issue that requires both national and international commitment.

Marcos ORELLANA | UN Special Rapporteur on toxics and human rights

The right to know and the right to information are known in international human rights law and relevant to the Rotterdam Convention. There are 3 main reasons why a strong Rotterdam Convention is needed:

1. Implementation of the right to a clean, healthy, and sustainable environment. The ILO has recognized the right to a clean, healthy, and sustainable environment as a fundamental principle and right at work. In 2022, the UN General Assembly has for the first time at the global level, affirmed and recognized the existence of the right to a clean, healthy, and sustainable environment, which stresses the importance of Multilateral Environmental Agreements (MEAs) and the principles they include. The implementation of MEAs is key to the realization of a healthy environment.
2. Lack of capacity in many countries. There is a lack of capacity for the implementation of the right to a clean, healthy, and sustainable environment and, more broadly, for the safe and sound management of chemicals and waste. This is not exclusively an issue in developing countries but also in industrialized countries. The lack of capacity often opens the door to undue corporate influence or even potential corporate capture. Where regulators and institutions do not have capacities, industries that have information, tools and resources in this area can exercise their influence, hence the need for a strong Rotterdam Convention.
3. Duty of prevention of exposure to hazardous substances and wastes. The international human rights law established a duty of prevention of exposure to hazardous substances and wastes. The tools are available under the Rotterdam Convention, hence the need to polish and strengthen these tools.

To strengthen the Rotterdam Convention, adopting a human rights-based approach is needed. For instance, a rights-based approach would consider how individuals and communities may be in vulnerable situations and should be given priority. In the frame of a report on gender and toxics, the human rights-based approach sheds light on the disproportionate impacts of chemical exposure on women and girls.

Another element is to infuse the interpretations and application of the Rotterdam Convention in light of internationally protected human rights. Below are four key human rights relevant to the strengthening of the Rotterdam Convention:

1. The right to science. There needs to be alignment between scientific knowledge and policy, although we often see a misalignment. There are powerful forces in society that are trying to obscure knowledge and distribute disinformation to foster paralysis and maintain the status quo as it is profitable to certain economic interests. The human rights law requires alignment between scientific knowledge and policy so that everybody can benefit from scientific advances. In the context of the Convention, there is a breakdown of the science-policy interface, as the Conference Of the Parties has been unable to hear the advice of the scientific committee.
2. The right to know or right to information as a component of other internationally protected rights. The right to know is an element of several internationally protected human rights. Cases that have been heard by the UN Human Rights Committee, the European Court of Human Rights, the Interamerican Court of Human Rights and the African Court of Human Rights all stress how information is key to the realization of internationally protected human rights and the normative content, the duties that flow from rights such as the right to private and family life, the right to life. The Interamerican Court of Human Rights has pioneered the justiciability of this right in a recent case involving the community of La Oroya in Peru, where the right to information stands prominent in regard to the content of the right to a healthy environment. The right to information is also key in the realization of the right to Free, Prior and Informed Consent of Indigenous Peoples (FPIC) that has been affirmed in international jurisprudence.
3. The right to information as an autonomous human right. The right to information is not only an element of other human rights but is important as an autonomous human right. It has been described as an enabling right because it enables action.
   1. For instance, it enables civil society organizations and others to defend human rights, especially in connection with environmental protection. This raises the importance of Civic Space, the so-called environmental democracy. It highlights the role of organizations in connection with human rights.  
   2. It also enables communities to confront risks. There is mobilization in communities to demand action from governments to make visible what is otherwise invisible and to bring attention to these issues. That is how change usually takes place. The right to information also allows individuals to take action at their own level to confront risks. However, it often happens that communities don’t have the resources or means to take action because they are in vulnerable situations. 
   3. The right to information as an autonomous right also enables governments to confront risks. The adoption of measures to prevent exposure to hazardous substances and waste is an obligation under the international human rights law, which involves positive duties to face environmental risk. In the face of environmental risk, the state is not an observer, nor a witness, but needs to be a protagonist and has positive duties to act, to confront the risks and provide adequate protection to the population. However, in order to carry out this duty, governments need the tools to do so. This brings in, for instance, pollution information portals (the report published on this issue is available here). Another very important tool is the FPIC mechanism established in the Rotterdam Convention that provides governments with the information needed in order to be able to assess whether a given chemical or hazardous pesticide can be allowed for international trade. 
4. The right to an effective remedy. Closely related to the right to access to Justice, this right has clear implications.

These four rights show how an effective Rotterdam Convention is crucial for the realization of human rights and how a rights-based approach can strengthen it. 

The Rotterdam Convention needs to overcome its paralysis. While most of its listed chemicals are in disuse, the Rotterdam Convention needs to become relevant again to present realities and not be relegated to the museum of International Environmental Law. To achieve this, it must provide developing countries with access to information, particularly on hazardous chemicals, and give effect to the shared responsibilities of exporting and importing countries involved in the international trade of hazardous chemicals and pesticides. More broadly, the Rotterdam Convention needs to be able to serve as a tool for international cooperation and implementation of the right to a clean, healthy, and sustainable environment.

Phillip HAZELTON | Campaign Coordinator, Union Aid Abroad APHEDA

• Union Aid Abroad – APHEDA, representing the Australian trade union movement, works with partners across Southeast Asia, the Pacific, the Middle East, and Africa to address global justice issues, including occupational health and safety. Australia faces a severe legacy from past asbestos use, particularly chrysotile asbestos, with 4,000 deaths annually despite banning the material over 20 years ago.
• The Australian union movement, supported by the Australian government and international partners, has actively warned countries still using asbestos, especially in Asia, about its dangers. Indonesia remains one of the largest importers of asbestos, and local initiatives like OSH Network (Lion Indonesia) are working to raise awareness, protect workers and consumers from asbestos exposure, and seek justice for victims.
• Governments in the Asia region frequently emphasize the importance of the Rotterdam Convention in shaping hazardous chemical legislation. The Prior Informed Consent (PIC) mechanism for listed chemicals plays a critical role in guiding regulatory decisions. However, the case of chrysotile asbestos highlights the weaknesses in the convention’s implementation.
• Chrysotile asbestos, classified as a Group 1 carcinogen, is responsible for 70% of workplace-related cancers worldwide. It has been banned in 73 countries and is linked to over 200,000 deaths annually. Despite WHO and expert recommendations, efforts to list chrysotile asbestos under the Rotterdam Convention have been blocked at every COP meeting since 2006 by a small group of parties with conflicts of interest. The convention’s requirement for full consensus among parties before listing a chemical has enabled this obstruction, creating a clear disconnect between scientific evidence and policy decisions.
• Recently, in Indonesia, asbestos industry groups have begun misusing the Rotterdam Convention to justify legal action against consumer protection organizations and NGOs. These civil lawsuits are aimed at intimidating activists and blocking health warning labels on asbestos-containing products. This tactic aligns with broader trends of Strategic Lawsuits Against Public Participation (SLAPP), designed to suppress advocacy efforts. The Indonesian case illustrates the unintended consequences of failing to list hazardous chemicals under the Rotterdam Convention, leaving workers and consumers unprotected.

Leo YOGA PRANATA | Director for Public Policy and Advocacy, LION Indonesia

Asbestos has been used in Indonesia since the 1950s, with over one million tons of chrysotile asbestos imported over the past decade. Roughly 95% of this imported asbestos is used in the construction sector, primarily in roofing materials. There are currently at least 27 factories in the country that produce asbestos-containing materials. According to data from the Indonesia Central Bureau of Statistics, over 13% of households used roofing made from asbestos-containing products in 2024, showing the material’s widespread domestic use.

• In 2024, ten provinces in Indonesia were identified as having the highest use of asbestos roofing, with Jakarta leading at 54.68% of buildings using such materials. Other provinces include Bangka Belitung Islands, Riau Islands, Banten, West Java, Lampung, South Sumatra, East Java, West Nusa Tenggara, and South Kalimantan. The widespread use of asbestos across various provinces highlights the significant reach of the material in residential construction throughout the country.
• Although chrysotile asbestos remains the only legally permitted type in Indonesia, it is officially classified as a toxic and hazardous substance by the government. However, there is a major regulatory gap: products containing chrysotile, such as cement roofing, are sold without hazard labels due to a lack of requirements in Ministry of Trade regulations. Other forms of asbestos are banned, but poor oversight allows chrysotile to be widely used without appropriate warnings to consumers.

Civil society organizations, including LION Indonesia and LPKSM Yayasan Yasa Nata Budi, have pushed for greater transparency and consumer protection. They filed a judicial review with the Supreme Court to challenge Ministry of Trade Regulation No. 25/2021, which fails to mandate hazard labeling on asbestos cement roofing products. This legal effort aims to secure the right of consumers to be informed about the health risks associated with chrysotile asbestos.

• The legal struggle for asbestos labelling began with advocacy efforts dating back to 2010, led by organizations such as LION Indonesia and INABAN (Indonesia Ban Asbestos Network). On December 20, 2022, a formal judicial review was submitted to the Supreme Court. On March 19, 2024, the Court ruled in favor of the plaintiffs, mandating that asbestos roofing products must include clear health hazard labels—a landmark decision for public health and consumer rights.
• On July 18, 2024, the Indonesian Fiber Cement Association (FICMA), a coalition of companies producing asbestos roofing, filed a retaliatory civil lawsuit against the organizations that had won the labeling case. This lawsuit, characterized as a Strategic Lawsuit Against Public Participation (SLAPP), was an attempt to intimidate and silence critics by overwhelming them with legal costs and discouraging further advocacy.
• The lawsuit filed by FICMA argued that chrysotile asbestos is not classified as a hazardous chemical under international law, specifically referencing Indonesia’s ratification of the Rotterdam Convention through Act No. 10 of 2013. FICMA claimed that since chrysotile was not added to Annex III during the most recent Conference of the Parties to the Rotterdam Convention in May 2023, it should not be considered a hazardous substance and thus did not warrant labeling.
• FICMA’s petition claimed that because chrysotile was not listed in Annex III of the Rotterdam Convention, it is legally protected and should be treated as safe. They argued that the Supreme Court’s decision contradicted the international consensus, asserting that 170 countries had “agreed” not to list chrysotile as dangerous. They further accused the advocacy organizations of misleading the judges and requested the court to rule that chrysotile is harmless.
• The industry’s lawsuit went beyond legal argumentation by demanding extensive remedies: they sought a declaration that chrysotile is not hazardous, requested the removal of all references to white asbestos on INABAN’s website, demanded public apologies in national print and television media, and claimed financial damages based on a supposed 1% monthly loss from IDR 7.986 trillion in “opportunity cost.” Their overall objective was to stop labelling and expand investment in the asbestos industry under the guise of legality.
• FICMA’s position distorted the reality of the Rotterdam Convention’s process. While chrysotile was not listed in Annex III due to lack of consensus, this is not equivalent to international agreement on its safety. The industry’s claim that countries “agreed” not to list it is misleading; rather, the lack of listing reflects the blocking efforts of a few countries, despite the majority recognizing the danger.

The court battle reflects a broader struggle to protect workers and consumers from the dangers of asbestos. The Supreme Court’s decision to require health warning labels on asbestos products was not only a legal breakthrough but also a moral affirmation of the public’s right to know. However, the backlash from the industry and its misuse of legal tools and international agreements shows the lengths corporations will go to in order to maintain harmful practices.

Ultimately, the district court rejected FICMA’s lawsuit, upholding the Supreme Court ruling and reinforcing the right of consumers to be informed about health risks. This victory is part of a global pattern of resistance against asbestos industry tactics—such as denial, misinformation, and delay—especially efforts to block the listing of chrysotile in the Rotterdam Convention. The precedent set in Indonesia adds momentum to international campaigns demanding transparency, accountability, and the phasing out of hazardous materials.

Sheila WILLIS | Head of International Programmes, Pesticide Action Network UK

The case study is about information gaps and lack of information flowing to people who need it in the context of agricultural workers and farmers using hazardous pesticides.

• Pesticide poisoning is widely accepted as a major public health problem, particularly in low- and middle-income countries; however, the scale of the problem is not well known. Estimates of the number of cases of acute pesticide poisoning that happen each year vary quite widely. The most recent and comprehensive study suggested that 385 million cases of acute pesticide poisoning occur each year, which is equivalent to about 44% of farmers and farm workers.
• Only a small minority of instances are reported. National authorities tend to be blind to this problem because they don’t have access to the data. In 2016, a study by Dr. Ngowi revealed that, of those reporting unintentional acute pesticide poisoning in Tanzania, only 6% sought medical treatment in a formal healthcare setting. Even those that do reach medical services are often poorly recorded or poorly understood, highlighting a huge lack of information in this area.
• Studies in Nepal and Jamaica showed a similar picture, with 22% of farmers that said they had been poisoned in the previous 12 months having sought help from official medical services in Nepal, and only 7% in Jamaica.

It is to address this huge information and data gap that the Pesticide Action Network (PAN) UK works with partners in various countries and to share the data with the decision makers. The Network developed a phone app to help support this process, and collected data in several countries. The results from the most recent surveys show that the average proportion of farmers and farm workers reporting incidents of unintentional acute pesticide poisoning over a 12-month period is 40%, with a huge variation within this average.

• Most countries suffer from inadequate post-registration surveillance and have significant data gaps.
• The lack of information is one reason why it is so important that the Rotterdam Convention is able to fulfil its role as an information-sharing mechanism. Countries that have similar conditions of use should be able to share information with each other.

Vera NGOWI | Senior Lecturer, Muhimbili University of Health and Allied sciences, Tanzania

Cotton in Tanzania is a strategic crop: the government puts a lot of effort into ensuring a high and good production. Cotton production directly sustains over 500,000 households who are predominantly small holder farmers. The Simyu region of Tanzania is the largest cotton producer in Tanzania and is where the study takes place.

• Pesticides are still perceived as a key component to increase productivity, but there is no legislation controlling pesticide use in Tanzania, and the magnitude of poisoning is severely underreported.
• The cotton-growing communities identified the pesticides involved, along with main exposure routes and practices that lead to poisoning. Using the app developed by PAN UK, the cross sectional survey of 1,074 cotton farmers and farm workers in the Simyu region had a structured questionnaire and helped collect self-reported health effects within 24 hours of pesticide use. The data was analyzed by classifying the symptoms according to severity (moderate or severe), and then used a binary logistic regression to identify the risk factors of the poisoning. The criteria used to evaluate the condition of pesticide use causing exposure and poisoning was pesticide application.
• Almost 86% of cotton farmers reported they use manual backpack sprayers as a method of application. 48% reported unintentional acute pesticide poisoning (UAPP) symptoms.
• Although the industry encourages the use of protective equipment, it is not common for farmers to use it. Only 28% of farmers say they received training on the use of personal protective equipment (PPE), meaning the majority don’t know how to use PPE. Almost ⅔ wear ordinary, non protective clothing for spraying pesticides.
• Still, 14% of the farmers are not able to identify pesticides used in relation to the incident.
• A very small number of pesticides is associated with the majority of unintentional incidents reported. Chlorpyrifos is implicated in more than a quarter of the acute poisonings that were reported by the farmers.
• Chlorpyrifos has been banned in more than 39 countries due to its high toxicity to humans and the environment. It is currently under consideration for listing under the Stockholm and Rotterdam Conventions.
• 184 farmers and farm workers reported cases of poisoning, and 11% of these incidents were categorized as severe. The nervous system is predominantly affected with symptoms such as severe headaches, abnormal skin tingling or numbness, muscle weakness, tremors etc. The respiratory system is also affected.
• Health care providers are not trained in the management of poisoning. Even with the recorded cases, it is still very hard for policymakers to use them to make decisions that will address the problem of poisoning in the country.
• Underreporting is severe, with only 6% of people seeking formal medical treatment, which highlights important gaps in information.
• Apart from the health costs of the UAPP (48% of farmers reporting UAPP symptoms, linked to a few pesticides), there are also high economic costs which are mostly invisible; however, household income and agricultural productivity are impacted.

Suitable alternatives are certainly available to chlorpyrifos. The Simyu region of Tanzania – the same region as where pesticide use has been studied – has an organic cotton sector that has been thoroughly tested under the local conditions. No chemical pesticides are applied. There is also a strong expertise in other countries in West Africa and Ethiopia for example.

The Tanzanian law changed in 2020 and removed the pesticide research mandate from the regulatory activity. Tanzania lacks a post-registration surveillance system, and regulators lack the data they need, which seriously impedes their ability to take informed decisions and necessary actions to protect farmers and rural communities.

• The Rotterdam Convention is an important mechanism for sharing information between countries, and it is particularly important that chemicals such as chlorpyrifos are added to Annex III to support information sharing and to give national authorities greater control over hazardous chemicals entering the country.

Sheila WILLIS

The speaker highlights that chlorpyrifos has been highly implicated in many incidents, some of them very severe. The Pesticide Action Network (PAN) has been collecting this kind of data in many countries for over a decade: the problem of unintentional occupational pesticide exposure is very widespread.

• A very large proportion of incidents among cotton farmers has been associated with chlorpyrifos across many countries, in different regions, and in many surveys. Therefore, PAN UK would really urge parties to consider listing chlorpyrifos under Annex III of the Rotterdam Convention.
• National regulatory authorities need information to make informed decisions, and this also explains the importance of the Rotterdam Convention, as regulatory authorities need access to information in order to make good decisions on these pesticides.
• Developing post-registration surveillance systems would also be necessary.

Kay WILLIAMS | Head, Global Framework on Chemicals

The Global Framework on Chemicals (GFC) was negotiated in 2023 in Bonn and sets targets to be met. The Framework has 5 strategic objectives and 28 targets. It is truly multisectoral and multistakeholder: governments, civil society, industry, and academics all have an equal voice under the framework.

1. Because of the high level of political commitment to take urgent action in the area of chemicals and waste that resulted in the Bonn Declaration, the Framework has a solid ground to go to governments with and claim for immediate action.
2. There was an agreement for a Global Framework on Chemicals Fund, which currently stands at around USD 28 million. The GFC is currently having an executive board meeting, looking at the first round of projects that can be funded under this framework.
3. The next open-ended working group is coming up between 24-27 June 2025, aiming to progress some of the implementation. The GFC will be enhancing its national focal point structure within countries. Its vision is to have not only focal points that are sitting in the environment but also in the ministries of labor, of health and of the environment.

The strategic objectives are framed around the following five areas:

1. Great emphasis is put on implementation with the strategic objective of looking at the legal frameworks, institutional mechanisms, and capacities and making sure they are in place.
2. The second objective is about data and knowledge, this is where the right to know truly comes in.
3. The third objective is about the issues of concern that have been worked on under the strategic approach to international chemicals management.
4. The fourth is to ensure that safer alternatives are in place, looking at innovative and sustainable solutions in the product value chain, addressing questions such as: how do we work within this industry to create sustainable solutions but also work not only with industry themselves but down the product value chain – because 95% of all products do contain chemicals, many of which are harmful.
5. The fifth objective concerns the enhanced implementation through effective resource mobilization and partnerships. This requires close work not only with the chemicals and waste multilateral environmental agreements but also with other branches such as biodiversity, climate change, the ILO, the health sector, and all the other agreements that are doing activity in this area and can have an impact.

The transparency of the Framework, the open exchange of information it provides space for, and the shared responsibility are central to support the Rotterdam Convention. The amplification of forward-moving activities and information sharing through international meetings and conferences is another key contribution.

• The Framework also contributes to understanding the chemical risks through identifying how to gain information. Working with industries, the GFC looks at how to take information in the data transparency commitment made by industries and how to work with them to ensure that meeting that commitment will not only allow transparency but also ensure access to the data that they are willing to share but is often too complicated to be understandable.
• The targets bolstering the right to know are mostly relating to data and require any stakeholder generating the data to try making it publicly accessible and comprehensive.
• To make this happen, the Inter-Organization Programme for the Sound Management of Chemicals (IOMC) participating organizations have been running a webinar series looking at how to implement the global framework on chemicals more effectively. One of the approaches of the framework is the construction of globally identified implementation programs. Some could support the Rotterdam Convention and bolster the legally binding elements to ensure that countries can take action and have access to the information even though not all of it is yet contained in the listing under the Rotterdam Convention.
• The Framework looks at the legislation for consumer products and legislation in other areas that can also help change the approach taken towards chemicals to make sure that there is an environment that gets rid of those harmful chemicals and encourages innovation in the sectors.
• The second implementation program topic is about looking at the economic and financial sectors.
• It has been put forward that governments are very interested in the economy and want production to keep going up, but this also affects the development of a country and has many health impacts. The global burden of disease is a high-level indicator under the framework and should be used as a communication tool to governments to inform them that there are significant costs in not dealing with some of these chemicals appropriately. It doesn’t only make health sense, but it also makes good business sense to take action.
• Implying investors and the financial sector are also required to shift the needle. Investors want to know which companies to put their money behind and don’t want to invest in companies that are producing hazardous and harmful chemicals, causing health issues, morbidity and having an adverse impact on populations. Therefore, requiring a degree of financial disclosure and reporting could be a new element that will have an impact on companies, encouraging them to invest in sustainable alternatives and to make sure that their productions and approaches to product manufacturers are sustainable in the chemical sense.

Making Rotterdam work effectively, including the right to know, is essential. The GFC can help in terms of building capacity because it’s important to regulate industrial chemicals and consumer goods and try to fill that gap that has been identified.

Q&A

Q: The report, according to the Rotterdam Convention, especially about the industrial chemicals, is not up to the mark by many state parties. How can reporting on industrial chemicals be enhanced? How can the Global Framework on Chemicals possibly contribute to that?

• Kay WILLIAMS – Regarding transparency and traceability of chemicals, there is a long supply chain and making sure that the information is shared. The GFC is working through international standards bodies to make sure that there are mechanisms and that companies know from a financial perspective what needs to be reported so that investors are able to invest there. Reporting must be easy such that it is known across the whole supply chain which chemicals have been used.

Q: Who is best placed to pay for health insurance? And what if workers who work in high-risk environments cannot afford the premiums? Although many of these health costs are very long term, is there any thought given to internalizing health costs caused by working in highly toxic environments and making a sort of polluter-pays health costs principle?

• Halshka GRACZYK — It is important to recognize the role of health insurance and the role of other entities like social protection. It is not purely with the employer but is a bigger picture.
  • Even if there is a manufacturer that is producing very toxic goods, it would be complicated to implement an idea like the polluter pays principle. If we look at the national law and practice of what is happening, even the most developed economies have trouble having their health insurance recognize occupation diseases and establishing the causality between the exposure and the health outcome. This is due to long latency periods, chemical cocktails, various exposures, and exposures outside of the workplace.
  • Finally, having health insurance means working in a formalized workplace. In certain countries, up to 80% of exposures are happening in the informal sector: how to deal with the informal sector, with the platform economy and with different types of contractual arrangements is still a big challenge.

Q: How long will it take for versatile asbestos to be listed, as it has not been listed to the Annex despite meeting all the requirements?

• Phillip HAZELTON — Under the current structure of the Convention, a complete consensus of the 167 parties is required for any chemical to be listed. This means any country can block the listing of a chemical, and it is likely that countries selling it would try to keep blocking it. Therefore, it is so important that the Convention is not manipulated by the very small number of parties that are having economic benefit from their activities despite all the recommendations of the panel.

Q: How can countries exporting chemicals to factories in developing countries be required to provide full, transparent, and clear information on all chemical hazard exposure, reduction measures, and safe waste disposal practices? In what way does the Rotterdam Convention support the goal of having safe waste disposal practices, and how can its implementation strengthen the right to know and ensure safer chemical management in developing nations?

• Sheila WILLIS — The Prior Informed Consent Procedure is a central provision under the Rotterdam Convention. It was designed to support low-middle income countries, in particular to have greater transparency in the movement of hazardous chemicals from producer nations to recipient ones.
  • That is contingent on Annex III working well, but this is sadly being blocked by parties with conflicts of interest. This central problem should hence be addressed.
  • Getting some chemicals, such as chlorpyrifos, that are still widely used and are poisoning people into Annex III would really give much more transparency to the movement of that chemical and control by recipient countries.
  • The disposal of hazardous pesticides is a huge and global problem. There are tons of obsolete pesticides accumulating in various parts of the world, which is hideously expensive and difficult to address. It would be much better to have a transparent system that controls these chemicals before they’re used rather than wait until there is a massive problem of disposal to deal with.

Documents

• Presentations made during the event

Links

• BRS MEAs 2025 COPs
• Road to 2025 BRS COPs
• ILO Declaration on Fundamental Principles and Rights at Work