Select Committee on Science and Technology Written Evidence


Memorandum from the Environmental Industries Commission


  The Environmental Industries Commission (EIC) was launched in 1995 to give the environmental technology and services industry a strong and effective voice with government.

  With over 240 Member companies EIC has grown to be the largest trade association in Europe for the environmental technology and services industry. It enjoys the support of leading politicians from all three major parties, industrialists, trade union leaders, environmentalists and academics.


  EIC Members are supportive of the new legislation, as it will bring innumerable environmental and public health benefits. It would also put the EU in the forefront of research on the environmental impacts of chemicals and increase harmonisation of methods, standards, and priorities across the industry.

  Furthermore while there would be costs to the chemical industry, the economic benefits to other sectors, especially environmental laboratories, must be considered alongside these.

  EIC believes the UK Government should be welcoming the REACH proposals as a major opportunity for the UK as well as an important environmental measure and should not, therefore, be seeking any further weakening in the proposals.


  REACH will provide a single, risk-based approach to identifying and controlling threats to human health from the chemicals we use. As such, it will fill in huge gaps in our present knowledge base, provide an objective basis on which to base policies and actions, and bring presently fragmented chemical control legislation under a single overarching framework.

  EIC Members believe the REACH proposals are efficient and cost-effective and we would not, therefore, support any further weakening of the proposals.


  While much has been said about the costs of the legislation to the chemical industry and the threats to its competitiveness, little consideration has been given to the economic as well as environmental benefits.

  In particular the proposals will require considerable analysis work—some of it on the environmental impacts of chemicals. UK environmental laboratories are well placed to undertake this work both in the UK and abroad. The REACH proposals, therefore, will generate jobs and profits in a fast growing and highly skilled industry in which the UK has a strong market position.

  EIC therefore considers that the economic opportunities created by REACH for environmental laboratories should be included in the impact assessment of the proposals carried by out by the EU and UK Government.


  EIC Members view the proposed legislation as presenting an opportunity for undertaking much-needed work and research in many fields, including:

    —  properties of chemicals and formulations;

    —  environmental fate and behaviour of chemicals and formulations;

    —  establishment of environmental quality standards;

    —  monitoring of chemicals in the environment;

    —  developing test methods in environmental toxicology; and

    —  development, validation and application of (Q)SARS.

  While some of the work has already been done, REACH would bring it together in one place, in a standardised format, and make it equally accessible to all parties. It would also fill in the knowledge gaps concerning numerous chemicals and formulations that we use commonly, in ignorance of the risks they may pose.

  This information will have major benefits for environmental protection in many areas. For example assessment of the risks presented by contaminated land sites prior to redevelopment and regeneration would be greatly simplified.

  EIC considers these wider benefits to environmental protection should be considered by the EU and UK Government in the impact assessment of the REACH proposals.


  In order to implement the REACH proposals a great deal of research and analysis will be required. This, as indicated above, is a significant business opportunity for the UK.

  EIC therefore considers that the UK Government should review spending of research and development to ensure the UK is well placed to make the most of this business opportunity. For example a UK Centre for Chemicals Management, established as a centre of expertise, could be of great help in ensuring that the UK benefits from the business opportunities provided by REACH.

January 2004

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