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Comments from the Institution of Environmental Sciences
on the scoping of the Chemicals Study


From: Dr R A Fuller, Honorary Secretary, Institution of Environmental Sciences, PO Box 16, Bourne, Lincolnshire PE10 9FB

19 January 2001

The Institution expects to contribute views and comments to the web-site forum in the near future. However, at this point we are pleased to provide a short response giving our opinion on key issues to be addressed in the main study.

The range of issues as listed in the consultation paper is wide ranging and every item is worthy of consideration. Priorities are desirable to establish those issues requiring the most urgent and/or most extensive study. In our view the completion of the review of the life cycle characteristics of the 10,500 listed chemicals is of utmost importance. (It is recognised that the Commission will not be directly carrying out such reviews but the means of implementation and its importance will form part of the study). New chemicals will need to be included in the exercise.

An initial aspect to be addressed is the establishment of those chemicals in most urgent need of assessment i.e. those with the - perceived - most harmful effects or potential effects.

Improvements in the communication of technical and scientific findings both to the public and governmental bodies are crucial. Active and effective measures to control the harmful effects of chemicals and to permit and develop the beneficial uses depend on properly informed opinion rather than ignorance and prejudice.

The development of cost-benefit techniques to establish criteria for use or non-use of chemical products is also of extreme importance in the establishment of proper controls.

We look forward to the web-site forum debate and to providing written views at a later date.

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