APPENDIX 14
Memorandum from the Environmental Industries
Commission
INTRODUCTION
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.
SUMMARY
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.
SAFEGUARDING HUMAN
HEALTH AND
THE ENVIRONMENT
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.
BENEFITS TO
ENVIRONMENTAL LABORATORIES
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.
WIDER BENEFITS
TO ENVIRONMENTAL
PROTECTION
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.
MAKING THE
MOST OF
REACH FOR THE
UK
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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