Royal Commission on Environmental Pollution

Thank you for your letter of 19th October to Chris Kelly, which has been passed to me for reply.

I have discussed this with colleagues involved with chemicals in the Environmental Health Branch of the Public Health Group in DH. We note the breadth of the areas that the Commission intend to cover. These relate to existing knowledge of long term effects of chemicals in the environment and further research work needed, how potential hazards and risks are identified, and principles that should be followed in their regulations. For pragmatic reasons it will be essential to focus work on a limited number of key topics within the broad subject areas.

This is recognised and you ask our views on what specific questions should be investigated, referring to the list of 18 topics in your letter.

In our view effort should be concentrated on those areas which have been relatively little studied, rather than the more 'well-trodden' ground. There would be little merit in our view, in producing another compendium of current methods of chemical hazard and risk assessment, or data relating to specific, well studied chemicals. Consideration of the following areas (taken in the order listed in your letter rather than any priority order) will in our view be of particular value.

The balance between the desires for toxicity testing and animal welfare concerns. As you will be aware there is a major dichotomy between the perception that the public is being exposed to large numbers of environmental chemicals for which there is inadequate data to enable an appropriate risk assessment to be carried out and hence the need for considerably more testing, and the need to reduce the number of animals used in toxicity studies for animal welfare reasons. There has been no detailed consideration of this issue by any authoritative body.

The adequacy of chemical and/or biological monitoring to help evaluate predicted behaviour and discover unforeseen effects. In the context of health effects we believe that further consideration of recent advances in monitoring techniques and linking epidemiology studies would be helpful as a possible approach to identifying effects on humans, but bearing in mind the limitations of any such studies (regarding power to determine low incidence effects, latency etc).

The incorporation of peoples values in the process; this is clearly important but is not part of the conventional risk assessment and little studied.

Gaps or deficiencies in the present coverage of regulation and how these may be filled. It is apparent that there are large differences in the extent to which different groups of chemicals or types of exposure are regulated. The rationale for this, and the need for a more consistent approach has been little addressed.

Regarding the question of which chemicals should be assessed most urgently (ie the prioritisation) we would question your comment that are those produced over 1000 tonnes pa of greatest concern - in that it is now widely recognised that it is not only production tonnage (a crude surrogate of exposure) that matters, but also that the material has wide dispersive use (eg HPV intermediate are no longer considered a priority in the OECD scheme). Anyway the DETR Stakeholder Forum is developing criteria for prioritisation for environmental chemicals.

The above are the areas that we believe are particularly important. Clearly some of the other areas should also be included, but it is important that the work is focused and not allowed to become too diffuse.

We will be happy to provide a submission covering the relevant areas of our work in the Environmental Health Branch in due course, and when you have defined the key areas on which you wish to concentrate.

I hope that this contribution is helpful.

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