Royal Commission on Environmental Pollution

Thank you for the opportunity for SDIA to contribute to the Royal Commission's Study on long-term effects of chemicals in the environment. We are pleased to be able to provide initial comments on the proposal.

The SDIA has around 50 members who produce the vast majority of soap, detergent and cleaning products sold in the UK for domestic and industrial use. For the most part these products are termed "down the drain" products because they end up in the sewage system after use. As such our interests in this area lie mainly in the potential impact on the aquatic environment.

The industry works with Government departments, environmental scientists and environmental bodies to assess research results, compare findings and keep a check on environmental studies. There has been regular official contact between the detergent industry and the relevant Government Departments, including the DETR, for over 40 years.

Thus detergents is a well-documented sector of chemicals usage, as the "Royal Commission on Environmental Pollution 16th Report: Freshwater Quality" illustrates. Various possible detergent ingredients were studied in a 1991 report commissioned by the Department of the Environment and entitled "Pollutants in Cleaning Agents". Overall, we believe the vast majority of the chemicals used in cleaning products will be removed by adequate sewerage treatment as will be required by law under the EC Urban Waste Water Treatment Directive (91/27/EEC).

Current legislation, such as the Detergents Biodegradability Directive already cover issues such as the biodegradability of surfactants used in cleaning products. The Dangerous Preparations Directive ensures that all products are assessed for their inherent safety aspects and from 2002 this will include an environmental assessment according to specified criteria. This European Directive requires appropriate labelling of products according to their resulting classification.

Our Industry's experience suggests that conclusions regarding environmental impact cannot be drawn solely on the basis of the inherent properties of the ingredients. Such assessment must extend to determining the actual exposure levels reached in the environment of those ingredients and any degradation products.

We hope that you will find our comments useful.

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