Sub-Committee D's Call for evidence
SubCommittee D (Environment, Agriculture, Public
Health and Consumer Protection) of the House of Lords European
Union Committee is conducting an inquiry into the European Commission's
White Paper "Strategy for a future Chemicals Policy"
(COM(2001)88 final). The inquiry will be chaired by the Rt Hon
Lord Crickhowell. (The Chairman of the SubCommittee, the
Earl of Selborne, has decided that it would be inappropriate for
him to chair the inquiry in view of his position as Chairman of
the UK Chemicals Stakeholder Forum). Mr Nigel Haigh has been appointed
Specialist Adviser to the inquiry.
The SubCommittee invites evidence on the White
Paper's proposals generally and with reference to the aspects
which give rise to particular concern to different interest groups.
The following questions may be helpful as an aide-mémoire,
but they are not exhaustive, nor are they intended to dictate
a framework for responses.
- What are the main differences between Commission's
proposals and the approach of the UK Government's Chemicals Strategy
- How strong is the case for having a single regime
for dealing with new and existing chemicals?
- Are the proposed procedures for testing of chemicals
justified and proportionate?
- Are the overall timescale and deadlines for registration
of chemicals realistic?
- What are the implications for animal testing?
- Should a requirement to conduct life-cycle risk
assessment of the use of chemicals form part of the strategy,
or should it be addressed separately?
- How effectively will the proposed authorisation
procedures meet the objectives of the strategy?
- What balance of effort and responsibilities should
be struck between the Commission and Member States under the proposed
Registration, Evaluation and Authorisation (REACH) regime?
- Where will the costs of implementation principally
fall? Has there been a realistic assessment of the likely costs
to industry and regulatory authorities in the Member States?
- Have the responsibilities of downstream users
been adequately addressed?
- Do the proposals meet the needs for transparency
and public access to information?
- How far should the strategy be concerned with
providing safeguards in relation to chemicals (especially imported
chemicals) as constituents of finished products, or are these
requirements dealt with adequately in other Community legislation?
- What are the implications for enforcement?
- What criteria, methodology and administrative
systems are appropriate for identifying chemicals, particularly
existing chemicals, of highest concern and for setting priorities
- What lessons can be learnt from overseas experience?
The inquiry will generally keep within the scope
of the White Paper and will not, for instance, be directly concerned
with controls on emissions of chemicals to the environment (including
disposal of chemical wastes) or with chemicals which are covered
by positive approval procedures (pesticides, biocides and human
and veterinary medicines), except to the extent that the proposals
of the White Paper may have implications for such separate regimes.
Evidence on animal testing should be consistent with
any submissions to the House of Lords Select Committee on Animals
in Scientific Procedures.
5 April 2001