Royal Commission on Environmental Pollution

1.   Introduction
The Royal Academy of Engineering welcomes the opportunity to contribute to the Commission's deliberations into the content and scope of its next inquiry: Long-term effects of chemicals in the environment. Views were sought from a number of Fellows and their replies collated to form this response. The views expressed are not necessarily representative of all Fellows of The Academy.

The list of broad topics for consideration is believed to be very comprehensive. However, the proposed scope is so broad that there is a fear of a lack of focus. In consequence, a first priority should be a definition of terms and refinement of the objectives to aid the attainment of some meaningful and useful conclusions. Great care will be needed to tease out the effects of chemicals from other factors that might be relevant to the protection of humans, ecosystems and bio-diversity.

2.   Broad topics and issues
Referring to the "Broad topics to be covered" and list of eighteen "issues", Fellows made the following comments (retaining the numbering of the original letter from the Commission):

c)    The Commission should seek to identify best practice from other industries. In particular, the current ICRP (International Commission on Radiological Protection) philosophy of "justification, optimisation, limitation" seems appropriate.

1)    Environmental pathways, although mentioned only in issue 1, are crucial : without a pathway the most toxic of substances will never have a receptor.

It is assumed that consideration of the dispersion and retention of materials in environmental media and the degradation of pollutants would be considered.

Human exposure from environmental routes needs to be considered alongside exposure from other routes e.g. domestic situations, since the resultant exposure is often greater than that received from food, air or water.

There is a need to distinguish between sensitive species, critical species, indicator species and reference species as the appropriate points of concern.

An adjunct to this issue is the identification of the appropriate point at which to evaluate the effect/implied protection. Is it individuals, populations, species or ecosystems?

2)   It is necessary to be explicit about the biological endpoint of concern e.g. morbidity vs mortality, the effects of fecundity, fertility etc. It should also be made clear that the effects of concern are "in the wild" not in the laboratory.

6)    The most urgent assessments should be conducted on chemicals apparently offering the greatest harm i.e. quantity of production x probable biotoxicity = harm potential, not simply production rate.

7)   Expand to include variability as well as uncertainty.

10)    The "Precautionary Principle" will require clear definition as applied to this study. Too often, today, the "Precautionary Principle" is used as a blunt instrument to argue against new developments. Whilst it is true that, in the past, the possible environmental effects of newly developed chemical species should have been more fully evaluated before they were made widely available, we should not use past errors as the reason to stop development of potentially beneficial chemicals and processes. Perhaps there is scope for the use of the "precautionary approach" that underpins radiological protection in the control of chemical species.

12)    The incorporation of people's values into the process is welcomed but concern has been expressed over the need to include those disenfranchised by current opinion surveying techniques.

It is thought important to broaden the impacts considered beyond health to aesthetics such as those caused by visible pollutants discolouring the environment or those causing odour problems. These can have a significant effect on people's appreciation of the environment and its economic value.

3.   Additional issues
Defining the threshold level or minimum concentration of a chemical creating a toxic effect. Too often this has been determined by the limit of detection, which has been progressively lowered with advancing analytical techniques. The "Precautionary Principle" has also been applied using the argument that if we do not know at what level a chemical becomes harmful, we should set the control limit as low as possible. The case for this needs to be examined vigorously : absolute zero concentration is unattainable; and it may well be that small sub-toxic traces of chemicals are actually beneficial to both the human body and to the wider environment in stimulating the developing nature's defence systems.

Comparability between assays. Ideally we should look for techniques which allow comparability of effects between chemical and radiological risks and certainly between different chemical types. Recommendations are needed on how best to compare between endocrine disrupters, cancer causing agents, eutrophication causing substances or other materials.

Analysis of the effects on local populations of "known natural concentrations" of minerals which are known to be deleterious to health on a laboratory scale. These studies might help to frame a more realistic level of the hazard posed by some contaminants than by extrapolation from laboratory studies.

The "Background" section gives the impression that man-made organic compounds are the dominant cause for concern but others would argue that metals, especially Cadmium, Mercury, Chromium, the metalloid Arsenic and the cyanide anion probably damage more ecosystems and human beings per annum. Other metals of concern include Platinum from ageing motor vehicles exhaust systems and Mercury from crematoria.

A study would achieve a lot by identifying which situations seem to be least controlled and monitored. Chemicals used in the home especially, cleaning materials and solvents, are a concern.

The current procedures for presenting the community with the pros and cons and necessary trade-offs are totally skewed by the populist media and if new routes to communicate can be established it would improve dialogue and understanding immensely.

4.  Other initiatives and studies
The University of Sheffield has a number of centres relevant to this study. In particular, the Sheffield University Waste Incineration Centre, with support from the Environment Agency, is initiating a quantitative study into the effects on health of combustion generated pollutants.

There is a new CIWEM book, "The diffuse pollution impact report", on diffuse pollution, which covers the full range of chemicals of interest in a comprehensive review of impacts.

There exists a large body of information on the effects of diesel particulates in the (underground) mine environment. The relevance of this data to the surface environment would be a useful study.

Data from mercury mines could be used to forecast the effects on properties and persons downwind of sites such as crematoria where mercury (from tooth fillings) would be discharged from the flues.

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