Royal Commission on Environmental Pollution

Thank you for the opportunity to comment on the key issues and areas it would be most appropriate for the new study to investigate.

The BMA welcomes the proposed study into the long-term effects of chemicals in the environment. In commenting on the four options for the Commission's next study in November 1999, the Association recommended that priority should be given to "the long-term effects of chemicals and biological agents" in view of the BMA's concerns regarding the effects of genetically modified organisms on the environment and human health. We note, however, that the Commission has decided that a study attempting to cover both chemicals and biological agents would be too broad, and are concerned that the subject of biological agents should also be addressed by the Commission in the near future.

The BMA has previously expressed concern about the incompleteness of existing knowledge concerning the effects of chemical exposure on human health and recommended an active research programme in this area.¹ The Commission's study should, therefore, examine the extent of current scientific knowledge and identify further research needs, both national and international. We believe that comprehensive data are needed on the quantities of compounds in use and where, when and how such chemicals are applied, so that an accurate picture of current levels of exposure can be established. Data from such work are necessary for adequate epidemiological and environmental studies.

Professional and public confidence in the regulation of pesticides and other chemicals depends largely on confidence in the quality of the scientific information upon which decisions are based. More information on new scientific technologies should be made publicly available and subject to peer scrutiny and review. This should include information about the costs and benefits in terms of health, the environment, the economy and other social considerations.²

In addition, general practitioners and hospital doctors have an important role to play in providing guidance to the public and patients about the hazards of toxic chemicals. They can, however, only fulfil their responsibilities if they receive sufficient training to enable them to recognise the symptoms of exposure when they encounter them. Training of medical students in the basics of toxicology should be given a higher priority and doctors who have completed their training should have access to education courses which would enable them to update and refresh their existing knowledge as more information about the health effects of chemicals becomes available.

In the BMA report entitled "Health and Environmental Impact Assessment"³ we expressed concerns regarding multiple exposure effects which can occur when a person is exposed to many different chemicals, each of which may have been released at a safe concentration. The consequence of exposure to a mixture of chemicals may be by summation of the action of each component, or sometimes the components may interact, causing a different and usually enhanced effect. We therefore believe that such multiple exposure effects should be addressed within the Royal Commission study.

One of the issues to be addressed by the Royal Commission study is the application of the Precautionary Principle. The BMA believes that, whenever possible, decisions regarding the environment and health should be evidence-based. However, given the lack of adequate empirical data, a precautionary approach should always be taken and decision-makers should err on the side of caution and safety rather than expose the environment and the public health to indeterminate risks and hazards.

I hope this information is of help. If you would like copies of any of the publications referred to, please let me know.

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