VEGA responds to a Defra consultation on the enforcement of REACH in the UK
VEGA's response to the Defra consultation on the enforcement of REACH in the UK follows:
1. We have these further comments to make as the REACH consultation advances after our last comments. We have been judging our experiences on the basis of the lifestyles of all individual citizens, some of which may translate to industrial and commercial relevance and to the purchase, importation, and procurement of “chemicals” to which workers and the public may be expected to be exposed to risk.
2. In our view an exhaustive study, based on a review of epidemiological and specialist surveys, especially of commodities associated with medical connexions and applications) and of results from A and E case (and even from tests set up for competitions of First Aiders’ competence). This requires attention to all commodities on general sale for foods and household goods on which retailers apply labeling and additional information easily reached by modern IT, we must be stimulated by education in citizenship and warnings on usage and hazards that are clearly presented. Such aids are still inadequate and improvements are compromised by occasional taunts by smart alecs on obviousness and nannyism (although ridiculousness and exaggeration must be avoided, it is important for nannies and carers in retirement homes to understand that risks and hazards change according to the individual’s age, gender, and circumstances, as well as accidental combinations of otherwise apparently innocuous products and substances).
3. We recommend therefore extension of your existing list of substances already tested in other contexts and for other purposes that may be authorized as ‘safe’ (on a GRAS basis), that would satisfy the demands of commonsense, the precautionary principle, and biochemical appraisal and experience and the responsibility of carers. It could be effectively amended if, after long, cautious usage, unexpected side effects begin to emerge. Clear labeling should be assisted by avoidance of confusing and misunderstood definitions of risks and definitions, eg for antibiotics, antiseptics, disinfectants, biocides; and development of resistant pathogens has to be assessed. This list would include risks arising from substances intended to enhance hygiene, health and safety, such as paints, varnishes, air fresheners, and furniture treatments and fire retardants. The noise and efficiency of vacuum cleaners are common sources of environmental nuisance.
4. Differentiation of risks into acute and chronic causes of harm must be appraised: for example established concrete surfaces may prevent little risk but a newly-laid area is likely to present considerable risks and burning to a person falling or working on the area.
5. We applaud DEFRA’s intention to adhere to the 3Rs principle in its evaluations of risks and testing, and we hope that vigorous application of a GRAS-type principle would indicate this earnest; moreover, it would reduce testing that only yields results from irrelevant procedures by the rote. We recommend also that building and design regulations include modifications to lower risks of accidents and obsessive practices, for instance, all hot surfaces should be fitted with guards and covers, spillages of risky liquids should be contained in bunds, and electrical leads should be kept as short as possible with built-in wall brackets for kettles, toasters, etc. It follows that water supplies should be overhauled to ensure that suck-backs don’t contaminate and endanger the quality of water for drinking and washing. Such changes should include lockable cupboards or cabinets for risky substances and articles in uses in households, hotels farms etc (as is practiced for pesticides and weapons) and with due allowance for inhabitants susceptible to allergies or epilepsy, and for young children and depressives.
6. Many retailers boast claims that their products are cruelty-free and natural, in their entirety or taking the ingredients one-by-one (ignoring possible interactions of components and the presence of ‘natural’ toxins). Operation of the REACH program will require modifications and reassessment of claims or alterations of formulae. A GRAS-type category could reduce resort to testing and control of doubtful benefit to the customer or manufacturer that would undermine rigorous application of the intent to reduce the cruelty of the tests.
7. The REACH product will have to take account of increasing disquiet over atmospheric and other environmental hazards from perceived nuclear and GM dangers and from particulates. Electromagnetic waves are ‘substances’ suspected by some people to upset the functions of the brain and memory; light pollution and “noise” may also be counted as acute and chronic sources of harm; and water supplies (some of which will be ‘imported’ in beers, wines, and other drinks and juices) need constant monitoring for hazards due to mains-supplies contaminated by pathogenic organisms and residues of substances used domestically, in farming, and in the purification and ‘improvements’ of ‘natural’ supplies.