It has been a long time coming, but you will I hope now have heard that proposals to ban artists paints containing cadmium pigments from the EU have now been formally abandoned.
In an official communication from the European Commission dated 28 October 2015, almost two years after Sweden first made the proposal to the European Chemicals Agency (ECHA), the Commission has agreed that this process is terminated. As a result, countries in the EU are not permitted to restrict the sale or use of artists paints containing cadmium pigments, unless there is new evidence sufficient to initiate a new evaluation.
For artists, not just those in Europe, this is excellent news.
This article considers some of the background to the original proposal, how the proposal failed, and where we should go from here.
Environmental concerns are now important political issues throughout Western democracies, particularly those in Europe. Unfortunately, as with many issues which become politicised, it is common for campaigns and slogans to depart considerably from the underlying science.
Over the last couple of decades, concern has been growing over contamination of agricultural soils with metals known to be toxic to man. One metal which has a long history of industrial toxicity, and which finds its way into the soils from which much of our food is produced, is cadmium.
There are three obvious ways in which cadmium can get into agricultural soils:
- it can be present there from the start,
- it can be added by man in fertilisers and other dressings,
- it can enter the soil via water (from the atmosphere and flowing water).
Soils which are inherently high in cadmium, perhaps from underlying minerals or previous heavy contamination, would appear to be unsuitable for agricultural use until their cadmium levels have been reduced, although in some parts of the world crops are still commonly grown on them.
The focus of attention in Europe has therefore been on the addition – and accumulation – of cadmium contained in fertilisers and other dressings applied by farmers. Those may consist of the sludge resulting from the treatment of waste water, or may be commercial preparations derived from minerals and similar sources.
Application of sewage sludge varies considerably according to country and region. In many countries in the West, it is very unusual, whereas in others it is extremely common. Because of the risk of accumulation of toxic substances, including cadmium, there are limits to the levels of those substances contained in sewage sludge for it to be judged ‘safe’ to apply.
In many of the member states of the EU, the rural vote is politically important, and determines which parties form their government. Issues such as regulation of fertiliser content and use have thus become heavily politicised. Those parties which rely on strong support from country areas are particularly careful to avoid campaigns which could upset rural and farming populations, and unfortunately the issue of cadmium and agricultural soil has become one of these.
Even the most naive assessment of the situation led to the obvious conclusion that controlling cadmium levels in soils could only be achieved by controlling the levels of cadmium in non-sludge fertilisers, supplied by the large and powerful agro-chemicals industry to farmers in politically-sensitive areas. So little has been done to address the blindingly obvious.
Little has also been done to assess the impact of the largest man-made dumps of cadmium in the environment, landfill containing discarded cadmium batteries, the latter accounting for the majority of industrial cadmium production. Nothing has been done to consider the richest human dietary sources of cadmium, shellfish and chocolate, which may in many cases be of greater health impact than all other dietary sources combined.
Instead the politicians needed scapegoats which would make it look as if something was being done, but which would offend the fewest potential voters and least powerful commercial lobbies. Cadmium in artists paints was thus an ideal target.
As politicians and campaigners generally have a very weak grasp of science, and little real concern for facts, Swedish water authorities – responsible for producing sewage sludge for agricultural use – were provided with university students to undertake studies which would provide a ‘factual’ basis for the campaign being mounted by those water authorities against artists paints.
Whilst they may have been adequate for their educational purpose, in terms of scientific evidence the quality of those studies was dismal, and none would have been publishable in any reputable scientific journal.
Bolstered by this growing irrational demonisation of a disorganised and tiny minority, Swedish politicians decided to increase its profile by proposing that its strong support for a national ban (which would of course not be permissible under EU law) should extend to the whole of Europe. Thus a very parochial political issue suddenly became a much more serious matter, which could have resulted in major change, albeit for a small number of EU citizens.
How it failed
Although there are problems in many of the EU’s institutions, most of those involving professionals are very well-informed, thorough, and arrive at measured and just decisions. The very weak evidence presented as the case for banning cadmium in artists paints was thus recognised as such, and the recommendations from the ECHA to the European Commission were fair and clear.
However, the case was very nearly lost. Had we left it to those bodies which claim to represent artists, such as the national academies, or to academia such as the colleges of art, there would have been little or no argument presented against Sweden’s proposal, and ECHA may have been obliged to recommend that cadmium should have been banned from artists paints. I summarised my feelings about this in a previous article.
The European Commission statement makes clear that the following arguments were most persuasive in its considerations:
- the very small health impact of any ban, in terms of risk reduction,
- weakness of assumptions made of the amount of cadmium released from washing brushes,
- negligible contribution of cadmium from artists paints to the total amount added to agricultural land,
- thus the almost immeasurably low impact of any ban, even over a very long period.
Although the ECHA was impressed by the considerable number of individual artists who submitted comments – thanks to a vigorous campaign by Michael Craine, of Spectrum Paints, Artists and Illustrators magazine, the art material suppliers Jackson’s, and others – that was supportive rather than decisive.
The decisive submissions were those made by the International Cadmium Association, in conjunction with CEPE, the European Council of the Paint, Printing Ink and Artists’ Colours Industry, and one or two others (I hope including my own paper, which considered the arguments which proved persuasive). Without their submissions, we might well now have been stockpiling paint in anticipation of an EU-wide ban coming into force in 2017 or so.
Where we go
All those involved in defending this case are aware that this is not the last time that such a proposal will be made. Additional studies will be undertaken on cadmium, and in a couple of years, another dossier may be submitted to ECHA to restart the process of their restriction. We are also aware that other metals and substances used in painting and art more generally are likely to be targets of future proposals.
Thankfully the trade organisations are well-organised, and employ staff who keep tabs on such matters. They have been good friends to artists, and will continue to be. We should all thank Michael Craine, Jackson’s, Golden Artist Colors, and the others who rose to the occasion.
However, I think this only emphasises the importance of planning for the future. If we all sit back, breathe a sigh of relief, and get back to our painting, the next challenge will come as another shock. And its outcome may not be as favourable.
Please use this ‘success’ to question our clubs, academies and organisations, colleges and universities, as to what they are doing to be seen to be more environmentally responsible, and to safeguard the future of our pigments and materials.