Royal Commission on Environmental Pollution

The London School of Hygiene and Tropical Medicine welcomes the timely review proposed by the Commission.

We note from our experience of participation in Risk Assessment activities, that the procedure of the case by case assessment and regulation of toxic chemicals in the environment has limitations in being able to adequately address the potential scale of the problem. While such a process has the advantage of being able to address the complexity of the environmental, toxicological, epidemiological and other evidence which needs to be assessed, it is very slow and set in too narrow a policy framework.

This is well illustrated by recent experience in the review of chemicals under the Existing Substances Regulations (ESR). This has been a very slow, and severely limited by the fact that comparative risk assessment of substitute materials is outside the scope of a single substances risk assessment, thus the most important information for assessing and if necessary encouraging the substitution of a material by one less harmful to the environment and exposed persons, falls outside the scope of the review.

Two problems thus need some creative reflection to address them: the need to incorporate comparative risk assessment in the process and the need to speed up the process, perhaps by a more generic approach risk assessment. We would encourage the Commission to include these topics, as well as a wider review of the adequacy of he ESR framework, in its review.

Another, related, topic is that (in spite of existing guidance) risk assessment decisions seem, in some circumstances, to be inconsistent and/or arbitrary. How to deal with the (inevitable) missing information, the role of "uncertainty" factors in estimating no effect levels, the place of quantitative risk assessment, the extent to which estimates of costs of implementation are integrated and the extent of stakeholder consultation/participation are all areas where a greater degree of consistency would surely be welcome. The potential for using the tools of decision analysis to improve the consistency of the decision-making in this kind of situation is an area on which we are currently working.

The complexity of assessments and in particular the comparative assessments relative to alternative materials and processes is perhaps best addressed by the industrial manufacturers of potential toxic substances. The UK certainly has encouraged industry to assume responsibility for this within the overall regulatory framework. The Commissions may like to include an assessment of the effectiveness of this self-regulatory approach in addressing the prevention of environmental impacts of chemicals.

While much of the focus of impacts of chemicals on the environment is related to industrial chemicals directly discharged to the environment, as health professionals we want to be careful not to forget the health sector: for example the remit should include pharmaceuticals, such as the potential environmental impact (on aquatic organisms) of estrogens ingested as contraceptive pills and re-excreted.

We anticipate that we will want be contribute evidence on some of the above issues during the Commission's work and very much look forward to the resulting report.

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