Royal Commission on Environmental Pollution

The Royal Commission on Environmental Pollution is inviting views for its new study on whether a more consistent and robust basis can be found for environmental standards.

The past twenty years have seen a considerable expansion of environmental legislation and policies. Increasing use has been made of numerical standards concerned with emissions, exposures, intakes, and concentrations of substances in the environment. Such standards have been set using various approaches by many different bodies - global, European and national - with the aim of protecting both human health and the natural environment.

It has recently been argued that some standards now being set are so stringent that the costs imposed on society will be out of proportion to the benefits obtained. Others argue that some forms of pollution (for example, prolonged exposure to very low concentrations of certain substances, especially in combination) are not being taken seriously enough.

The creation of new Environment Agencies responsible for regulating most forms of pollution makes it timely to try to establish a consistent and sustainable basis for standards. The recent transfer of responsibility for the Health and Safety Commission and Executive to the Department of the Environment has highlighted the relationship between pollution control and standards for occupational health.

The Royal Commission's study will compare the methods and procedures adopted in arriving at standards for all types of pollution and for all aspects of the environment. The term 'standards' means standards contained in law (for example, emission limits or environmental quality standards) and also non-statutory protocols, guidelines and targets, and criteria used in deciding individual cases. The study will examine what happens at European level, in other major countries, and in international organisations, as well as in the United Kingdom. It will also cover related issues about the approval of chemicals and the regulation of contaminants in food. The Royal Commission will focus in particular on different types of scientific evidence, the ways in which these are utilised, and the potential for resolving present uncertainties through further research.

As part of the study, views are now being sought on a number of issues. The Royal Commission wants to obtain input from all types of organisation and from the general public, based on the widest possible range of situations. Those submitting evidence are asked to describe the experience on which they are drawing. There may be legitimate differences in the approach to standard-setting according to the context.

The list of key issues identified by the Royal Commission (which is not necessarily exhaustive) is as follows:

The general approach to environmental standards

1. What should be the purpose of setting standards? How successfully do present standards achieve that purpose?

2. Is the level at which standards are set at present (global, European, national or local, or by individual regulators) appropriate?

3. What should be done to make the standard-setting process more explicit and transparent? What role should scientific experts have, and how should they be chosen? At national level, what role should Ministers and government Departments have? Ought there to be a greater role for the courts, or new forms of quasi-judicial regulatory hearing?

4. What role should quantification of costs and benefits play in setting and revising standards?

5. How adequate is present scientific understanding of toxicity, ecological tolerance and environmental processes as a basis for setting numerical standards?

6. Where scientific opinion and public perception are in conflict, what weight should each carry in setting standards and in determining the best practicable environmental option? Should attempts be made to modify public perceptions through education and information? Should the scientific community take more account of social preferences and sensitivities?

7. What is the best way of making allowance for uncertainties? When, and how, should the precautionary principle be applied?

8. What relationship should be sought between risks from pollution and levels of risk in other contexts? How should priorities be determined within pollution control?

Specific factors in standard-setting

9. How should standard-setting make allowance for natural variations in exposure to the same hazards?

10. In setting standards, what significance should be attached to particular vulnerability or susceptibility on the part of certain individuals, groups or species?

11. How valid is the concept of 'critical loads' and where can it be applied?

12. What should be the relationship between standards for exposure of the general public and standards for occupational exposure?

13. In what ways can standards best be set to encourage innovation, particularly investment in cleaner technologies?

Implementation and review of standards

14. What are the advantages and disadvantages of standards which are not legally binding?

15. In what circumstances could economic instruments (such as levies and tradeable permits) or voluntary measures provide a satisfactory replacement for government-defined standards?

16. How far do limitations on the detail or precision with which measurements can be made constrain the effectiveness of pollution control? What are the prospects for overcoming such constraints?

17. What should be the relationship between numerical standards for particular substances and what is overall the best practicable environmental option (as defined in the Royal Commission's Twelfth Report)?

18. What is the most effective way of linking standards for environmental quality, or critical loads, to standards for emissions or products?

19. What further provision is needed for keeping standards up to date?

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