Royal Commission on Environmental Pollution

The Marine Conservation Society warmly welcomes this most recent study and believes that it will be one of the most important that the Royal Commission has undertaken. Pollution of the environment, via air, water and soil by chemicals is one of the least well understood and insidious of threats to biodiversity and human health.

I apologise for the late submission of this letter, with which I had hoped to enclose a draft report on 'Chemicals in the Marine Environment'. Unfortunately, other pressures and recent illness have prevented me achieving this and so this response is much briefer than intended. MCS would however, hope to make more detailed submissions to the study in due course. The report on chemicals in the marine environment draws together information and research on the sources and impacts of chemicals on marine organisms and may provide a useful reference document for the Royal Commissions study. Although it does not involve any new primary research the report reflects the range of chemicals and species that are affected as well as reviewing information on transfer of chemicals up the food chain to humans.

The most important issue that MCS wishes to raise at this point is to urge the Commission to include the marine environment as an major consideration within the scope of the study. Recent articles on the threats to human health of PCBs and dioxins in fish and of flame retardants in Polar Bears highlight the marine environment as an important pathway and sink for chemicals produced on land. The number of marine animals found with large burdens of toxic chemicals steadily increases as more research is undertaken and has been linked with mass strandings and outbreaks of disease which can leave local populations decimated.

The Marine Conservation Society would also like to draw the Commission's attention to a recent study which identified raw plastic pellets as a medium for the accumulation and transfer of toxic chemicals such as PCBs and DDE. MCS has been undertaking surveys of coastal litter for eight years and there are literally millions of these pellets on our shores in addition to the millions of pieces of plastic debris which arise from the breakdown of larger plastic items, making up 50% of the litter recorded. These small plastic pellets are mistaken for food such as larvae and fish eggs by a range of fish and bird species who consume them but are then often unable to pass them through their digestive system, thus accumulating the associated toxins.

Furthermore, MCS would stress the importance of the study addressing the gaps in the UK Governments Chemicals Strategy which does not include the addition of chemicals to food during processing, nor the measures relating to controls on emissions to the environment.

I apologise again for the late response from MCS and will ensure that a copy of the final report on Chemicals in the Marine Environment is forwarded to you in due course.

MCS received the initial letter regarding this study indirectly from Scottish Wildlife and Countryside Link and I would be grateful if you could add the Marine Conservation Society as an individual organisation to the consultee list for the study.

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