Royal Commission on Environmental Pollution

Greenpeace welcomes the Commission's proposal to look at the long-term effects of chemicals in the environment. Nowhere do current regulations adequately address this issue.

The Commission has already identified many of the areas that the study will need to investigate. We agree that any study must include the strands relating to scientific knowledge, the principles of regulation, and the assessment process.

Recognising that public values are important in the framing of a regulatory process, and the concern that people have about long-term uncertain impact of poorly understood hazards, we suggest that the Commission needs to look at the policy framework in terms of the effectiveness in producing drivers for change, as distinct from the slow and cumbersome assessment process that currently prevails in the EU Existing Substances regime. Such an approach would include:

- The need for an approach that puts the onus on policy makers to prioritise protection of human health and the environment over industrial/economic interests.

- The establishment of the substitution principle, including substitution of processes, materials and products where necessary, by those which display lower hazard characteristics, in order to eliminate hazardous raw materials and ingredients.

- The need for an alternative approach to regulation of new and existing chemicals that places the burden of responsibility on chemical manufactures to provide sufficient evidence, that can be independently validated, that a chemical presents no potential for harm to human health or the environment.

- The need to assign chemicals to groups according to chemical structure, in order to accelerate hazard identification and facilitate regulation.

- The establishment of producer responsibility and liability for long-term environmental and human health impacts of chemicals.

- The need for public availability of information regarding the use of chemicals in consumer products, necessitating an end to "commercial confidentiality" regarding chemical use.

- The need for assessment based on hazard rather than risk and in particular the need to prohibit the manufacture and use of persistent OR bioaccumulative substances irrespective of their toxicity.

- The need to achieve elimination, not merely reduction or management, of emissions, discharges and losses of hazardous substances to the environment.

Additionally Greenpeace believes that rather than restricting itself to a chemical by chemical approach, which is part of the failing of current EU and UK chemicals policy, the Commission should seek to devise an approach capable of looking at sectors, processes and materials. Examples would be the industrial use of chlorine, the incineration of waste or the manufacture of PVC. The policy prescriptions available to governments for reducing the environmental and health burden of chemical exposure might be quite different if 'the problem' is examined in this way. If particular processes or products which lead to a large and varied chemical burden on the environment could be substituted or replaced, it is more likely to meet public aspirations and values than a chemical-by-chemical approach.

I hope the above suggestions, which should not be taken as a comprehensive list of issues that need to be addressed, will be of use to the Commission in what promises to be valuable work. We look forward to the opportunity to submit evidence.

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