APPENDIX 9
Memorandum from the Co-operative Bank
The Co-operative Bank is campaigning for Safer
Chemicals, with campaign partners and leading environmental organisation
WWF-UK. We share WWF's concerns regarding the current draft legislation
and fully support its submission and recommendations (attached).
We believe that UK Government should do all
it can to ensure a robust new Chemical Regulation is put in place,
one which prioritises "environmental, health and consumer
protection" to safeguard future generations.
In summary, we believe that particular attention
should be made to developing EU Chemical Regulation which:
— encourages the phase out, and eventual
elimination, of exposure to chemicals of very high concern (including
persistent and very bioaccumulative chemicals);
— incorporates the substitution principle:
chemicals of very high concern should only be authorised when
there is no safer alternative, and an overwhelming societal need,
and measures to minimise exposure are in place;
— employs the "precautionary principle",
rather than resorting to demands for necessary proof of the serious
and irreversible effects of these chemicals or recourse to animal
testing to prove toxicity;
— holds industry responsible for the
provision of sufficient toxicity data, in order that proper risk
management can be undertaken;
— insists on compulsory data sharing
to ensure duplicate animal testing is avoided; and
— ensures public access to all toxicity,
fate, exposure, use categories and risk assessment data.
The Co-operative Bank maintains that the UK
Government is well placed to lead the way in supporting a robust
Chemical Regulation, one that protects future generations of humans
and wildlife, and we await the results of your inquiry with interest.
January 2004
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