Royal Commission on Environmental Pollution

Thank you for requesting the views of the RCGP on the key issues to inform this study.

The College welcomes this new study especially given the plethora of chemicals that are being released into the environment over the last fifty years or so and the lack of knowledge about their long-term effects.

It is our view that a better system of balancing the benefits to society of a new chemical against the potential adverse effects is required. Primary Care professionals have a role in monitoring the health of individuals exposed to differing levels of chemicals in the environment. Practice networks could be used to undertake epidemiological studies, although there would be substantial practical difficulties to be overcome. We also feel that there is a need to include the effects of pharmaceutical agents and chemicals in waste from the health system, e.g. diagnostic agents etc.

Finally, we are glad to see that the Commission proposals to look at the operation of the precautionary principle in chemical assessment and control. We feel that it is important to clarify just how far the burden of proof of safety can put the chemical manufacturer; what constitutes sufficient evidence of safety; and the degree to which emphasising corporate self-regulation on chemical safety is likely to be effective.

We hope you find these comment helpful.

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