Royal Commission on Environmental Pollution

Thank you for inviting CIA to discuss the Royal Commission's Study on long-term effects of chemicals in the environment. We are pleased to be able to provide you with our comments on the scope of the study and would be willing to provide formal written evidence at a later stage.

Timing of the study and interaction with others
The chemical industry has a unique and major interest in this study and a keen interest in the outcome since it is largely the products of our industry that will be under scrutiny. The direction of the paper is therefore very important and we are keen to work with you, providing information and assistance. We would be delighted to offer the Commission a pre-study briefing either here at CIA or at your Offices to help your members understand the work being done by the industry and the status of public perception. Should this be of interest we would of course be happy to discuss the format of the meeting with you.

As you will be aware there are many other parties who are addressing chemicals management, particularly relevant to us are the UK government, their chemicals strategy and on-going stakeholder forum, the EU Review of chemicals management being carried out by DG ENV and DG ENT, OECD who have an on-going programme and OSPAR; we would ask you to interact with these other bodies to ensure that the output of your work can be practically applied.

Purpose and scope of the study
The key question to be addressed is whether there are long-term effects from chemicals in the environment; if so what these are and how can they be prioritised. The OECD have recently written an authoritative overview of the chemical industry and this may provide useful background.

There is a contradiction between the proven benefits of chemicals in terms of quality of life as well as increased length of life and a heightened fear of long term effects for which there is little if any hard evidence. We believe it would be useful for the Royal Commission to investigate the concerns lying behind the use of chemicals and what interests are motivating and feeding the public's anxiety. (Point 12) We recommend the Royal Commission look at risk benefit analysis.

We would urge you to ensure the study looks at chemicals which are both man-made and "naturally" obtained - hazard and risk are not tempered by a chemicals origin although there appears to be a perception that they are.

We are pleased that you have proposed to look at current legislation (Point 16). The chemical industry already faces a complex web of Regulations both horizontally applied to products (eg. Council Regulation on existing substances) and vertically applied to applications (eg. Biocidal Products Directive). An authoritative review of current legislation can be found in the DETR paper "Sustainable production and use of chemicals". We would support any move to look at all of these Regulations in an integrated manner and consider what gaps or deficiencies there are, which Regulations are failing and why. If this is done well, we believe that many novel answers will appear, helping us all to reduce the risks posed by the use and release of chemicals to man and the environment.

It appears to us that much could be done to minimise animal testing (point 15) and we would be happy to discuss the possibilities.

The need for substitution is raised in your point 11. We would urge consideration of the need for widespread acceptance of substitution on the basis of risk rather than hazard alone. The relative risks to either man or the environment need to be minimised by consideration of risk and are not achieved when Regulation calls for restrictions on the basis of hazard alone.

Product Stewardship is important. You touch on this in your point 13 and indeed we would welcome your views on how all people involved in the manufacture and handling of chemicals might practically work better together to ensure that chemicals are appropriately used. Clearly the primary manufacturer of a chemical has a number of legal duties and responsibilities, we would welcome your views on our moral responsibilities in order that we might extend our Product Stewardship work. We are also interested in your view on the balance between personal responsibility and liability.

There are a number of areas noted above where we hope we have given you and your colleagues considerable food for thought as to where you can most usefully apply your depth and diversity of experience. There are a limited number of areas where we feel it would be less fruitful to focus; those chemicals that are already heavily legislated and issues which are already being tackled by other organisations.

We do hope that you will find our comments to be of use. We are of course happy to work with you providing whatever additional information or evidence that we can to ensure the Royal Commission can arrive at a useful and pragmatic report.

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