Royal Commission on Environmental Pollution

Background to UKASTA
The United Kingdom Agricultural Supply Trade Association (UKASTA) represents more than 300 companies and cooperatives in the agricultural supply industry. Members comprise crop traders, animal feed manufacturers and agricultural merchants who supply products and advisory services to farmers for feed, seed, fertilisers, forage additives, and agrochemicals. Their combined annual turnover is approximately £5 billion.

UKASTA Interest in Royal Commission Study
It is generally agreed that the manufacture and use of chemicals has offered great benefits to mankind, as well as posing some risks, both to humans and the environment. The same is true for animals, particularly farmed species. But, it should be acknowledged that the benefits of chemical use far outweigh the risks, and this is especially true in the UK. The process of authorisation procedures that has been developed in the UK ensures that all chemicals that are in use offer benefits that far outweigh any potential risks.

It should also be noted that the procedures for evaluating chemicals that are in place today are much improved. An example of this could be thalidomide, the drug that resulted in birth defects. There is no chance of such an active ingredient being marketed today. Concerning agriculture, pesticides were not included in any statutory authorisation schemes until 1985, and there is no evidence of any serious harm being caused. Today, it is a very well regulated sector under COPR, a system that is probably one of the most robust in the World.

UKASTA feels that the reference to DDT is unfortunate. Although DDT has caused some problems, upon its introduction in World War Two, it was vital in combating serious infestations at a time when maximum levels of production were required.

Finally, UKASTA would consider that the ongoing reviews of chemical use in the EU are being driven by political considerations and therefore may not fully take into account scientific fact. Although it is impossible to ignore the political climate, it is important that science should always be respected.

Broad Topics to be covered
UKASTA would generally agree with the list of broad topics to be covered, but would make the following points, which bear consideration:

The suggested figure in Item 6 of chemicals produced in quantities of over 1000 t/yr is totally artificial. There are chemicals produced in minute quantities that have higher levels of toxicity than 1 million t of another chemical eg: fertilisers. The Royal Commission should not set any arbitrary figures, but look at potential risks to the environment caused by chemicals on a case by case basis.

Item 7 suggests that there is uncertainty and/or a lack of data in the assessment process. This may be true in some cases, upon which UKASTA is not competent to comment, but it is certainly not the case for pesticides and fertilisers.

Item 8. The speed of the current assessment process. Is the Royal Commission considering whether the assessment process is rapid or too slow? UKASTA would submit that the principal issue is the thoroughness of the process.

The "substitution principle" discussed in Item 11 is important, but is already an essential element of a COSHH assessment. It is also already extended to cover non-chemical solutions.

It is a matter of some concern to UKASTA that "people's values" should be considered to any extent by the Royal Commission. These values are more than likely to be purely subjective and not necessarily based upon factual knowledge.

Item 14 is to consider the openness and transparency of the assessment process. UKASTA would submit that the process for pesticides is already open and transparent subject to the limits of commercial confidentiality.

Finally, UKASTA would submit that the UK approvals process for pesticides and agro-chemicals in general is superior to most other systems in the World. While therefore it is always important to consider how those systems could be improved, the UK may well have little to gain from greater co-ordination with other countries other than unnecessary delays in the process.

Invitation to submit views on key issues
UKASTA is not aware of any other significant issues that would bear consideration by the Royal Commission. Indeed, the issues already proposed for the study should provide a definitive understanding of the situation in the UK regarding the long term effects of chemicals in the environment.

UKASTA has no recent initiatives or studies to bring to the attention of the Royal Commission.

Finally, UKASTA has no recent examples of practical difficulties or failings in good practice to report.

Back to Index of comments to the scoping of the Chemicals Study