Royal Commission on Environmental Pollution

Thank you for your 19 October letter inviting DTI views on the key issues for this study. The DTI's interest in this work arises from our role as the key Department for improving the competitiveness of the UK chemicals industry.

As you rightly point out in your letter, the chemicals industry has brought modern society many benefits from dyes to plastics; detergents to pharmaceuticals and coatings. The UK industry itself is a very important to our economy - its annual turnover is £40bn; it employs more than 419,000 people and is the third largest in the EU; the sixth largest in the world. However, chemicals are always potentially controversial especially as our ability to measure effects improves. It is probably the long-term effects which are the least well understood. The Commission's study is therefore timely and relevant.

On the study itself, we have an interest in all three of the topics you list. The third runs to the heart of our concerns - how to regulate efficiently chemicals whilst still capitalising on their benefits. We all recognise that regulation is necessary, but inefficient regulation risks stifling innovation, limiting investment and undermining the competitiveness of the UK industry. A stable regulatory framework to protect human health and the environment whilst maintaining competitiveness is the prize.

The UK chemicals strategy is the Government's response to many of these concerns. At the same time industry is taking forward its "Confidence in Chemicals" programme. The Commission's report will, I am sure, be extremely helpful in improving our understanding of the underlying issues. For example, of the issues you list, those numbered 2 and 4 about test methods and the use of predictive methods to fill data gaps will be useful, as industry and regulators turn their attention to gathering data and prioritising substances. Issues 7 and 9-11 on the use of comparative assessment, the precautionary principle and dealing with uncertainty will be of interest to this Department as use of these will grow in prominence in the future and if not implemented properly could have a direct effect on competitiveness. We also suggest that issue 12, about incorporating people's values into the process might include socio-economic analysis. In sum, the proposed study covers all the issues we see as worthy of study.

Finally in your 8 December letter about the launch of the Web Forum to aid the Royal Commission Study, I see that you regard this as a way of seeking informal comments on the Commission's issues and on contributions made to the website. We shall be watching with interest how the debate develops amongst the forum participants.

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