Royal Commission on Environmental Pollution

I would firstly like to welcome the study which can provide an authoritative and timely contribution to the debate on how future policy on chemicals management should develop. The Agency will play a full role in contributing views and information arising out of its responsibilities and I understand that dialogue has already been established with key contacts developing the Agency's policy in this area.

The scope of the study is potentially very ambitious and we think the Commission is right to try to identify key issues. We believe that consideration of effects on both the natural environment and on human's exposed via environmental routes is helpful and can be used to highlight differences in approach. It can often be difficult to communicate relative risks and the importance of exposure routes, and your study may be able to explore this in more detail.

In your letter, you referred to the complexity of the regulatory regimes which have developed to address different types of chemicals. For example, biologically active substances introduced into the environment, such as pesticides, go though positive approval systems whereas industrial chemicals do not. Many different organisations are involved in chemical management in the UK and effective co-operative action is crucial to our success in ensuring that the environment and human health are adequately protected. These different regimes address long-term effects in different ways and we think it is helpful for the study to look at the entire range of substances rather than restrict itself to one type (such as industrial chemicals) to highlight deficiencies and good practice. We would draw your attention to the Pesticides in the Environment Working Group as a useful source of information on pesticides.

Turning to your list of issues, whilst all of these are important, we think it may be most productive to focus effort on those issues which are crucial to deliver the necessary level of protection for the environment and human health, rather than those concerned with improving the efficiency of the process, as the latter are being debated in a number of other fora.

When considering 'long-term effects', persistent, bioaccumulative and toxic chemicals are obviously an issue you will consider further but chemicals which are continually present in the environment by virtue of continual release may also merit consideration. Prolonged exposure to low levels of chemicals in the environment, singly and in combination, is perhaps one of the key issues where our scientific understanding of modes of toxic action and ability to predict and observe long-term effects should be considered. In this regard, the terrestrial ecosystem has in the past received less attention than the aquatic ecosystem and should not be ignored. Carcinogens, mutagens & reproductive toxicants are one group of chemicals which cause particular public concern. These can be classified differently and it may be helpful to consider the relevance of environmental routes and duration of exposure for such substances to aid communication.

There are a range of issues associated with the ecotoxicity tests undertaken for substance approval and their relevance for predicting long-term environmental effects, these include the suitability of test organisms, test design and the applicability of new approaches such as quantitative structure activity relationships. As you say, many of these have been addressed by the Commission in its 21st report but it is essential new approaches are evaluated for their applicability in the context of long-term effects and may merit further consideration in this study.

Substitution of more hazardous persistent, bioaccumulative and toxic substances with substances more in tune with the natural degradation cycle of complex molecules has been suggested as a beneficial risk management measure. Further consideration of this principle in terms of hazard and risk reduction and how comparative assessments can be made may be helpful. Other chemicals, such as antibiotics, have a specific mode of toxic action but are widely used and issues regarding control over environmental exposure to avoid the potential for rapid development of resistance could be explored.

I hope this is constructive and look forward to continued dialogue on this interesting study. To facilitate communication I would suggest further approaches to the Agency should be through Steve Killeen who leads on Chemicals Policy for the Agency.

Back to Index of comments to the scoping of the Chemicals Study