Royal Commission on Environmental Pollution

WWF is one of Britain's leading environmental organisations, working on a wide range of environmental issues in the UK and around the world. WWF's philosophy is to conserve nature - wild species and wild places - by promoting the sustainable use of natural resources to meet the needs of current and future generations. This response relates to WWF-UK's concern about the long-term threats that toxic chemicals pose to the biodiversity of wildlife.

WWF-UK welcomes the opportunity to comment on the key issues that should be addressed by the Royal Commission's study on the long-term effects of chemicals in the environment. A number of important areas are outlined below, but WWF-UK also looks forward to further and more detailed input into this study at a later date.

·   It would be useful if the report covered both the identified long-term effects of chemicals, and whether the current regulatory system is adequate to prevent future long-term effects from chemicals, and where any particular weaknesses lie.

·   It would also be useful for the report to consider whether we are able to identify with confidence all the current long-term effects of chemicals. For example, are exposures to man-made chemicals causing behavioural effects in children? Are epidemiological studies likely to pick up subtle effects, or are these unlikely to be of much use due to the fact that there is no population which is not exposed to a range of pollutants, and hence there are too many confounding factors?

·   There is also a need to address the effects of concurrent exposure to many contaminants, which may have additive or synergistic effects.

·   The lack of toxicity tests to identify substances with endocrine disrupting properties, and the ability of these substances to cause long-term effects due to in utero or early life exposure should also be considered.

·   There is also a need to address and determine the low-dose effects of endocrine disrupting chemicals, particularly whether for some chemicals there is no threshold for effects. It has been suggested that low doses of certain chemicals may cause effects that are not seen at higher dose levels, and if verified this will require a new framework for establishing safety levels.

·   The long-term effects of chemicals on the immune system and on the neuro-developmental system, including behavioural effects, should be considered, and whether there is a need to develop and implement toxicity testing for such endpoints.

·   WWF considers that in risk assessment and risk management there is a need to require action to be taken on the basis of "early warning signs" even though the overall and long-term health consequences of some effects are unknown. For example, in draft risk assessments conducted by the UK under the EU regulation on existing substances 793/93, it has been argued that an increase in prostate weight should not be carried forward in the risk assessment because it is not an adverse functional effect. The Royal Commission study could therefore examine whether the need for regulation should be based on the identification of "adverse effects" in laboratory experiments, or whether any "abnormal" affect should be considered sufficient to trigger regulation.

·   Human variation and the difference in susceptibility to various pollutants should certainly be included in the study. This should include an examination of the difference in susceptibility during various developmental stages (ie during foetal development and puberty), and an examination of the potential increased exposure of early life forms.

·   The report should also look at the need to ensure that sentinel species are identified and tested in order to predict effects on biodiversity. For example, invertebrates represent more than 95% of the known species in the animal kingdom, but are the invertebrate phyla adequately represented in toxicity testing regimes, and would even the testing conducted on new EU chemicals reliably predict the effects across this taxa?

·   Similarly, given the biological diversity of the marine environment, there is a need to consider whether these species are adequately protected from the long-term effects of chemicals.

·   There is a need to consider the long-term effects of chemicals, not just on the organism directly affected, but also on other interdependent organisms, and ecosystems as a whole.

·   The difficulty of predicting all the possible effects from long-term exposure to chemicals from a few shorter-term tests on a few selected species should be examined. In addition, the consequences of not accurately predicting the effects of persistent and bioaccumulating substances should be considered, alongside the need for a precautionary approach to the regulation of persistent and bioaccumulating substances.

·   The potential that research into gene technology has to identify the harmful effects of substances and to identify susceptible people.

·   Alongside the report on the long-term effects of chemicals, in order that the report be of practical use, there should be a consideration of possible regulatory measures, that would reduce the likelihood of effects.

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