Royal Commission on Environmental Pollution

DICIDA-UK is the Development Initiative for Chemical Dependent Areas in the United Kingdom. The DICIDA-UK network provides a forum where all Local Authorities and public sector agencies in areas with a concentration of employment in the chemicals industry can join forces in the work to secure a safe future for their communities. Membership includes local authorities in Cheshire, Falkirk, Kingston-upon-Hull, North East Lincolnshire and the Tees Valley. Collectively, these areas represent a population of almost 3 million.

The aims of DICIDA-UK are to: (a) ensure that national government and European Union policies and programmes assist the continued growth of the chemicals industry in and across the Member States; and, (b) enable local regions to cope with the economic, social and environmental problems created by the restructuring of the chemicals industry. Further details are available from the DICIDA-UK website:
www.teesvalley-jsu.gov.uk/dicidauk

DICIDA members welcome the study into the long-term effects of chemicals on humans and the natural environment. Member organisations support the provision of public information on consumer products.

However, any study must maintain an important balance between the provision of adequate testing to determine likely impacts, and maintaining the competitiveness of the industry with the rest of the world. According to the EU White Paper published in February 2001, there are approximately 100,000 different chemical substances registered. Around 251,000 people in the UK are employed by the industry and it supports thousands of other jobs throughout the economy. Significant clusters of chemical industry are located within DICIDA areas. Although DICIDA generally welcome the study into the long-term effects of chemicals in the environment, and welcome improvements to health and safety, the study must not overlook potential social and economic impacts. The Enterprise Directorate should be included in future discussions to progress this Strategy.

International testing methods need to be agreed that prioritise the testing of the most hazardous chemicals. Whilst supporting globally harmonised testing methodology, this should not be overly prescriptive in comparison with the risk factor. It would also avoid putting the UK industry at a disadvantage to the rest of the world. Europe has 1000 substances on its 'banned' list, USA has 9 and Japan has 5. Whilst wanting high levels of protection for our local communities, DICIDA members want to retain the economical benefits the industry brings and would not want to see companies relocating to other countries.

Any testing measures agreed should not suppress innovation within the UK. Historically US companies are able to put products on the market much more quickly than EU companies. The introduction of new chemicals within Europe has declined from about 2000 a year in the 1970s to 200 per year now.

Distinction needs to be made between 'hazard and risk'. Hazard is the potential to cause harm, whereas risk is the likelihood of harm being caused by exposure to the hazard. The level of exposure is therefore an important factor in determining risk. A low exposure to a highly hazardous substance may result in a low risk. It is also possible for high levels of exposure to a low hazard substance to create a high risk of harm. Chemicals are an integral part of modern life. They are included in the cars we drive, domestic appliances, double-glazing, paint, computers, televisions, polythene bags and packaging etc. etc. The risk and exposure levels to chemicals in these types of products is fairly limited if they are used correctly. Most people will use some form of chemicals in their home every day - i.e. deodorants, perfumes, cleaning agents, plastic containers etc. Most domestic cleaning products are clearly marked as being hazardous. If these items are stored correctly in their proper containers and away from infants and children there is no risk to the family. If however they are stored in containers meant for other products (e.g. lemonade bottles) and left within easy reach, there is a risk that small children could drink the substance or get it into their eyes. Calls for regulation need to take these issues into account. Testing methods should reflect the levels of toxicity and potential hazard of the product and not be based solely on volume of production.

There is concern that downstream additional testing will involve a high proportion of SMEs in bureaucratic systems that could be beyond their capabilities and disproportionate to the level of risk. Simplification of testing criteria should be permitted for downstream SMEs in production that does not involve extremely hazardous chemicals.

Evaluation of the current regulatory process would assist in determining any inadequacies in testing, monitoring and verification and would assist in determining a more consistent approach. Investigation into international regulatory systems may also highlight approaches that reduce potential health & safety risks whilst maintaining global competitiveness.

Although DICIDA is concerned that people's values should be incorporated into assessment processes, there is concern that public perception of the benefits of the industry also require improvement. As stated previously, the production of many modern consumer items is reliant upon the provision of some element of their composition on the chemical industry. Industry has a very important role in providing information regarding risks associated with the industry and its products and appropriate guidelines for safe use of them and improving public perception of the industry. However the public has a role in determining what risk is acceptable. Some products will have high risk factors that make the product unacceptable, whilst others will have a negligible risk. Providing simple clear information to consumers allows them to determine if the benefits outweigh the potential risk. Perhaps it would inform the debate if the Royal Commission investigated the concerns lying behind the use of chemicals, and how these concerns are perpetuated.

The suggestion of adopting a 'ground up' approach to a regulatory framework is welcomed. This could contribute to public understanding of some of the issues facing the industry.

DICIDA-UK Network Membership, April 2000

Membership of the network currently includes:

Tees Valley Joint Strategy Unit ^* - (Secretariat and Chair)
Bradford City Council
Cheshire County Council
Ellesmere Port & Neston Borough Council
Falkirk Council
Halton Borough Council
Kingston upon Hull City Council
Manchester Investment Development & Agency Services
North East Lincolnshire Council
Vale Royal Borough Council


Chemical Industries Association
Engineering Construction Industry Training Board
Humber Chemical Focus
North West Chemical Initiative
Teesside Chemical Initiative

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