Toxic Chemicals in Everyday Life - House of Commons Environmental Audit Committee - Parliament (publications)

 
Toxic Chemicals in Everyday Life - House of Commons Environmental Audit Committee - Parliament (publications)
House of Commons
Environmental Audit Committee

Toxic Chemicals in
Everyday Life
Twentieth Report of Session 2017–19

Report, together with formal minutes relating
to the report

Ordered by the House of Commons
to be printed 10 July 2019

                                                        HC 1805
                                         Published on 16 July 2019
                           by authority of the House of Commons
Environmental Audit Committee
The Environmental Audit Committee is appointed by the House of Commons to
consider to what extent the policies and programmes of government departments
and non-departmental public bodies contribute to environmental protection and
sustainable development; to audit their performance against such targets as may be
set for them by Her Majesty’s Ministers; and to report thereon to the House.

Current membership
Mary Creagh MP (Labour, Wakefield) (Chair)
Dr Thérèse Coffey MP (Conservative, Suffolk Coastal)
Geraint Davies MP (Labour (Co-op), Swansea West)
Mr Philip Dunne MP (Conservative, Ludlow)
Zac Goldsmith MP (Conservative, Richmond Park)
Mr Robert Goodwill MP (Conservative, Scarborough and Whitby)
James Gray MP (Conservative, North Wiltshire)
Ruth Jones MP (Labour, Newport West)
Caroline Lucas MP (Green Party, Brighton, Pavilion)
Kerry McCarthy MP (Labour, Bristol East)
Anna McMorrin MP (Labour, Cardiff North)
John McNally MP (Scottish National Party, Falkirk)
Dr Matthew Offord MP (Conservative, Hendon)
Dr Dan Poulter MP (Conservative, Central Suffolk and North Ipswich)
Alex Sobel MP (Labour (Co-op), Leeds North West)
Derek Thomas MP (Conservative, St Ives)

Powers

The constitution and powers are set out in House of Commons Standing Orders,
principally in SO No 152A. These are available on the internet via www.parliament.uk.

Publications

© Parliamentary Copyright House of Commons 2019. This publication may be
reproduced under the terms of the Open Parliament Licence, which is published at
www.parliament.uk/copyright.
Committee reports are published on the Committee’s website at www.parliament.uk/
eacom and in print by Order of the House.
Evidence relating to this report is published on the inquiry publications page of the
Committee’s website.

Committee staff

The current staff of the Committee are Lloyd Owen (Clerk), Leoni Kurt (Second Clerk),
Ruth Cahir (Committee Specialist), Laura Grant (Committee Specialist), Laura Scott
(Committee Specialist), Helen Muller (Committee Researcher), Jonathan Wright (Senior
Committee Assistant), Baris Tufekci (Committee Assistant), Anne Peacock (Media
Officer) and Simon Horswell (Media Officer).

SContacts

All correspondence should be addressed to the Clerk of the Environmental Audit
Committee, House of Commons, London SW1A 0AA. The telephone number for general
enquiries is 020 7219 8890; the Committee’s email address is eacom@parliament.uk.
You can follow the Committee on Twitter using @CommonsEAC.
Toxic Chemicals in Everyday Life    1

Contents
Summary3

1   Introduction                                                                              5
    Chemicals in society                                                                      5
         Production of chemicals                                                              5
         Chemicals of concern                                                                 6
         Toxicity9
         Risk management                                                                      9
    Previous inquiries                                                                       10
    Our inquiry                                                                              10

2   Environment and human health impact of chemicals                                         11
    Environment11
         International chemicals management                                                  11
         Chemicals in the UK environment                                                     12
    Attitudes to chemicals                                                                   15
    Human health                                                                             16
         Body burden of chemicals                                                            17
         Biomonitoring18
         Plastic packaging                                                                   20

3   Furniture and Furnishings (Fire Safety) Regulations 1988                                 23
    Flame retardants                                                                         23
         Fire deaths                                                                         24
    1988 Furniture and Furnishings (Fire Safety) Regulations                                 27
         2014 BIS consultation                                                               31
         2016 BEIS consultation                                                              32
         Industry views                                                                      33
    Whistle-blower allegations                                                               36

4   Environmental contamination around the Grenfell Tower                                    40
    Environmental contamination testing                                                      40
         Response to findings of environmental contamination                                 42
         Public Health England response                                                      43
    Toxicity of smoke                                                                        45
         Exposure of firefighters                                                            46
5   Product safety                                                 48
    Product testing                                                48
         Products sold online                                      49
         Resources for chemical testing                            49
    Product labelling                                              52
         Innovations for consumers                                 54
    Product safety after the UK leaves the EU                      55
         RAPEX55

6   Future UK chemicals policy                                     57
    European Union                                                 57
         Strategy for a non-toxic environment                      58
         Framework on endocrine disruptors                         58
    Forthcoming Chemicals Strategy                                 59
    Chemicals regulation in the event of EU exit                   61
         Stakeholder engagement                                    63

Acknowledgments66

Conclusions and recommendations                                    67

Annex 1: Glossary                                                  74

Annex 2: Survey results                                            76

Formal minutes                                                     80

Witnesses81

Published written evidence                                         82

List of Reports from the Committee during the current Parliament   84
Toxic Chemicals in Everyday Life          3

Summary
Chemicals are pervasive in modern society and contribute to improved health and
quality of life globally. However, current regulation does not account for the cocktail
of chemicals we are exposed to. Hazardous chemicals and other pollutants are now
‘ubiquitous in humans and the environment.’1 Without a rapid transition to a more
circular economy for chemicals, it will not be possible to implement the ambitions set
out in the 25 Year Environment Plan or Resources and Waste Strategy. We call on the
Government to use the forthcoming Chemicals Strategy to form the basis of a non-toxic
environment in the UK. This should set out a clear, ambitious vision for the type of
chemical environment we hope to live in. We need to better understand which chemicals
we are exposed to in greatest measure and what the risk from that exposure is. To do
this, a long-term, UK wide, human and wildlife biomonitoring programme should be
established. The Chemicals Strategy should include objectives and priority areas for
monitoring. It should also consider the mixtures of chemicals we are exposed to and
lay out a plan for the remediation of harmful regulated substances in the environment.

The 1988 Furniture and Furnishings (Fire Safety) Regulations have been under review
for ten years with no reforms enacted. During this time, some of the most commonly
used flame retardants have been classed as persistent organic pollutants and substances
of very high concern. Inaction has allowed unnecessary and potentially toxic chemicals
to continue to enter the public’s homes. Our Regulations should be brought in line with
the rest of the world and the Government should develop a new flammability standard
without further delay. Children’s products should be immediately removed from scope
of the Regulations. Labels should clearly state if a furniture product has been treated
with chemical flame retardants. It is clear that the Regulations are contested and there
is no consensus; however, it is unacceptable a government department can take nearly
three years to respond to a public consultation. The Minister must publish the responses
before a new Prime Minister takes office on 24 July. Failure to do so will add to the view
that the process is being deliberately delayed.

We are troubled by the lack of urgency in response to findings of environmental
contamination from chemicals around the Grenfell Tower site. Residents should
be reassured that the presence of these chemicals is not harmful to their health and
homes. We support calls for full health biomonitoring for residents, including specific
monitoring for the effects of exposure to fire effluents. We also recommend that any
local residents who have concerns about dusts or residues within their homes be offered
the opportunity to have them tested for environmental contamination. Environmental
contamination testing for chemicals should be carried out as standard in the immediate
aftermath of major disasters.

Chemicals are routinely used in consumer products where their presence is not indicated
on the product label. Consumers have the right to know what chemicals are used in the
products they purchase. The current budget for product safety compliance does not
reflect the volume of products on the market and is failing to protect UK consumers.
The Government should increase resources for product safety compliance by 10 percent
a year in the upcoming spending review. Product labelling should be reformed to

1   UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p viii.
4       Toxic Chemicals in Everyday Life

    ensure consumers are aware of which groups of chemicals have been used. This should
    include domestic pictograms to indicate if a substance meets the criteria for a substance
    of very high concern. A full list of chemical ingredients should be made available on
    the product website and direction offered to independent, scientific advice. Public
    Health Bodies should be given responsibility for monitoring, researching the impact
    of chemicals on public health, and recommending restrictions and other controls on
    groups of problematic chemicals. They should be given adequate funding and staffing
    for research and policy development.
Toxic Chemicals in Everyday Life        5

1 Introduction
Chemicals in society
1. Chemicals are pervasive in modern society and have contributed to global
improvements in human health, food security, productivity and quality of life. Production
and consumption of chemicals are rising as the market for chemical-intensive products
such as computers, furniture and personal care products grows.2 There is growing
evidence that some chemicals cause products and wastes with hazardous properties which
harm human health and the environment.3 According to the UN’s Global Chemicals
Outlook, hazardous chemicals and other pollutants are now ‘ubiquitous in humans and
the environment.’4 CHEM Trust contends that ‘the unpleasant reality [is] that we are
constantly exposed to a cocktail of chemicals, something which is still largely ignored by
chemical safety laws.’5

Production of chemicals

2. Chemical production globally has increased fiftyfold since 1950 and is forecast to
treble in volume by 2050.6 The Lancet Commission estimates that over 140,000 new
chemicals and pesticides have been synthesised since 1950. 5,000 chemicals produced in
the greatest volume have become widely dispersed in the environment and account for
almost all human exposure.7 Per capita consumption of chemicals is driven by economic
growth in chemical intensive industries such as construction, agriculture, electronics,
cosmetics, mining and textiles.8 Emerging economies are experiencing rapid growth
in both production and consumption of chemicals.9 This increase in production means
more chemicals in products, which means increased human, animal and environmental
exposure.10

3. Global chemical sales were valued at €3.4 trillion in 2017 with China, the EU and
US the largest producers.11 The UK is the seventh largest chemicals producer in the EU
28. The industry contributes £18 billion to the UK economy each year.12 The European
Commission estimates there are over 100,000 chemicals on the EU market, only a
small proportion of which have been evaluated for their impact on human health and
the environment.13 Eurostat, the EU statistical office, estimates that the EU produced
81 million tonnes of chemicals hazardous to the environment and 219 million tonnes

2    UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 4.
3    UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 5.
4    UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p viii.
5    CHEM Trust, No Brainer – The impact of chemicals on children’s brain development: a cause for concern and a
     need for action (March 2017), p 2.
6    Q6
7    The Lancet, The Lancet Commission on pollution and health (2017), p 462.
8    Dr Olwenn Martin (TCS0030), pp 4–5.
9    UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p viii.
10   European Commission, Study for the strategy for a non-toxic environment of the 7th Environment Action
     Programme (2017), p 10.
11   CEFIC, Facts & Figures of the European chemical industry (2018), pp 6–7.
12   CEFIC, Facts & Figures of the European chemical industry (2018), p. 11; Chemical Industries Association (TCS0014),
     p 1.
13   European Commission, Study for the strategy for a non-toxic environment of the 7th Environment Action
     Programme (2017), p 10.
6       Toxic Chemicals in Everyday Life

of chemicals hazardous to human health in 2017.14 Only 70 unique substances, and
some related groups, are subject to restrictions under the EU’s Registration, Evaluation,
Authorisation and Restriction of Chemicals Regulation (REACH).15

Chemicals of concern

4. Our inquiry and this report are focused on chemicals most commonly found in
consumer products and due to limitations of time and space, we were not able to focus on
groups such as metals, pharmaceuticals, pesticides and nanomaterials in depth.

     Key terms

     Substance of very high concern (SVHC): A substance is classed as an SVHC under
     Article 57 of REACH if it meets the criteria for classification as carcinogenic,
     mutagenic or toxic for reproduction, is considered persistent, bio-accumulative and
     toxic or very persistent and very bio-accumulative, or causes an equivalent level of
     concern.16

     Combined exposure: Exposure to multiple chemicals via one or several sources and
     routes.17

     Regrettable substitution: The replacement of hazardous substances with structurally
     similar substances which exhibit similar hazardous properties.18

5. Substances of very high concern (SVHCs) are of particular interest to us. These are
chemicals which are defined as having hazardous properties under Article 57 of REACH.
To be considered a SVHC, a substance must meet the scientific criteria for classification as
carcinogenic (cancer causing), mutagenic (having the ability to change genetic material)
or toxic for reproduction, be considered persistent, bio-accumulative (accumulating in
the body of animals and humans) and toxic or very persistent and very bio-accumulative
or cause an equivalent level of concern.19 Once a substance is classified as of very high
concern, it is added to REACH’s Candidate List. This places additional obligations on
suppliers, including supplying safety information and informing the European Chemicals
Agency (ECHA), if the substance is produced in quantities above the threshold of one
tonne per producer/importer per year.20 Continued use of a substance of very high concern
may be permitted if applicants can demonstrate that the substance is used safely or if it
can be shown that there are no available alternatives.21

     REACH

     Under REACH any substance manufactured in or imported to the EU in quantities
     above one tonne per year must be registered with the European Chemicals Agency
     (ECHA). The information requirements to assess the potential hazard and risk of a

14     Eurostat, Chemicals production and consumption statistics (December 2018).
15     ECHA, Substances restricted under REACH [accessed 18 June 2019].
16     ECHA, Substances of very high concern identification [accessed 4 March 2019].
17     European Commission, Something from nothing? Ensuring the safety of chemical mixtures (May 2018), p 2.
18     European Commission, Study for the strategy for a non-toxic environment of the 7th Environment Action
       Programme (2017), p 42.
19     ECHA, Substances of very high concern identification [accessed 4 March 2019].
20     ECHA, Substances of very high concern identification [accessed 4 March 2019].
21     ChemSec, Lost at SEA* (March 2019), p 3.
Toxic Chemicals in Everyday Life       7

     substance are determined by the quantity of the substance. Registered substances can
     be added to the List of the Community Rolling Action Plan (CoRAP) for substance
     evaluation by ECHA or an EU member state. Substances are chosen based on a
     hazard and risk criteria defined by ECHA. Once listed, an individual substance is
     evaluated by member state(s) to determine if its use poses a risk to human health or the
     environment. If the evaluation concludes a substance is of concern, risk management
     measures are proposed including harmonised classification and labelling, identifying
     the substance as a substance of very high concern (SVHC), restricting the substance
     or proposing EU-wide occupational exposure limits, national measures or voluntary
     industry actions (outside of the scope of REACH).22

6. The EU has also identified endocrine disrupting chemicals as an area of concern.
They are ‘substances that alter function(s) of the endocrine system and consequently cause
adverse health effects in an intact organism or its progeny, or (sub)populations.’23 They
are structurally similar to hormones. This enables them to act like naturally occurring
hormones or alter the body’s ability to synthesise, release or eliminate hormones.24 They
are mostly synthetic and are found in pesticides, metals, additives or as contaminants
in food and cosmetics. Humans and wildlife are exposed to them through food, dust,
water, inhalation or through skin contact.25 Thresholds of exposure are likely to exist for
endocrine disrupting chemicals; however they may be very low for individual chemicals
and depend on when the exposure occurs.26 In addition to endocrine disrupting chemicals,
groups of chemicals which have been linked to ‘regrettable substitution’ in consumer
products will also be considered including flame retardants, per-fluorinated chemicals
and bisphenols. Regrettable substitution occurs when a hazardous substance is replaced
with a structurally similar substance which exhibits similar hazardous properties.27 We
heard evidence that the chemical bisphenol A (BPA) is an example of this.

             We identified that there were harmful health consequences of being exposed
             to bisphenol A sufficient to warrant a reduction in the tolerable daily limit
             that you are allowed to be exposed to. Lots of companies switched from
             bisphenol A to a highly related compound called bisphenol S to satisfy that
             this is a bisphenol A-free item, but bisphenol S has very similar toxicological
             properties to bisphenol A.28

CHEM Trust have argued that groups of chemicals should be regulated and controlled
together, rather than regulating individual substances on a case-by-case basis. It is the
regulation of single chemical substances that leads to regrettable substitution.29

22     UN Environment Programme, Overview Report III: Existing national, regional, and global regulatory frameworks
       addressing Endocrine Disrupting Chemicals (EDCs) (July 2017), p 15.
23     ECHA, Endocrine disruptor expert group [accessed 7 March 2019].
24     OECD, OECD work on endocrine disrupting chemicals (March 2018), p 7.
25     ECHA, Endocrine disruptors and our health [accessed 7 March 2019].
26     Munn, S. and Goumenou, M., Thresholds for endocrine disrupters and related uncertainties, Report of the
       Endocrine Disrupters Expert Advisory Group (2013), p 6.
27     European Commission, Study for the strategy for a non-toxic environment of the 7th Environment Action
       Programme (2017), p 42.
28     Q25
29     CHEM Trust (TCS0012), p 1.
report is set out below:
                                                                                                                                                      A table of some of the groups of chemicals and their properties to be considered in this

                                                                                                                                                                                                                                                 8
                  Sample of groups of chemicals of concern to human health and the environment
Chemical Group                 Uses                                   Possible health effects                     Products

                                                                                                                                                                                                                                                 Toxic Chemicals in Everyday Life
Bisphenols (BPA, BPF, BPS) A       main    component     in  the      Disrupts the reproductive and hormone Food can linings, plastic,
                             manufacture      of   polycarbonate      systems, increases the risk of cancer. electronic toys, paper receipts.
                             plastics, epoxies, epoxy resin.
Flame             retardants Fire retardant.                          Persistent, bio-accumulative, toxic; some Furniture, electronics, building
(brominated,                                                          kinds are also classified as carcinogenic, materials.
organophosphate,                                                      toxic, disrupting the reproductive system;
chlorinated)                                                          some disrupt the hormone system.
Formaldehydes                  Bind pigments to the cloth. Fire       Irritates mucous membranes and skin, can Toys, furniture, air fresheners.
                               retardant. Wrinkle resistance. Water   cause      hypersensitivity, carcinogenic
                               repellence. Adhesive in wood           (nasal pathway).
                               products.
Parabens                       Preservative.                          Estrogenic effects, disrupts the hormone Shampoos,    bath    additives,
                                                                      system, sensitizing agent.               lotions,    creams,        oils,
                                                                                                               sunscreens, toothpaste, baby
                                                                                                               wipes.
Perfluorinated     chemicals Water, grease and soil repellence.       Carcinogenic, disrupts fertility.        Waterproof clothing, non-stick
including                                                                                                      pans, toys.
perfluoroalkylated
substances     (PFAs)    (i.e.
perfluorooctanoic sulfonate
(PFOS)                   and
perfluorooctanoic        acid
(PFOA))
Persistent organic pollutants Flame retardants, surfactants.       Cancer risk, reproductive disorders, neuro-    Banned under the Stockholm
(PCBs, DDT, dioxins)                                               behavioural      impairment,      endocrine    Convention but still widely
                                                                   disruption, genotoxicity and increased birth   dispersed in the environment
                                                                   defects.                                       including in recycled products.
Phthalates (DEHP, DBP, Plasticiser, usually found in soft Disrupts development and the hormone                    Plasticisers in PVC, furnishings,
BBP)                          plastic, pellets for stuffing cuddly system, impairs fertility.                     clothing and food packaging.
                              toys. Can also be used as a
                              synthetic fragrance compound in
                              scented toys.
Source: Project NonHazCity [accessed 5 March 2019].
Toxic Chemicals in Everyday Life      9

Toxicity

7. We received several submissions highlighting that the level of toxicity of a chemical
is determined by the dose. Examples included oxygen which is harmful if normal
concentrations are increased fivefold30 and botulinum, a highly poisonous naturally
occurring substance, used in cosmetics (known as Botox) to treat muscle spasms.31 The
Paracelsus Principle states, ‘what is there that is not poison? All things are poison and
nothing is without poison. Solely the dose determines that a thing is not a poison.’32
Modern toxicity thresholds are determined by the No Observed Adverse Effect Level
(NOAEL) and Maximum Residue Levels (MRLs) for chemicals and pesticides in food.33
The Chemical Industries Association noted that developments in technology are enabling
the detection of chemicals in our bodies and the environment in ever smaller amounts.34
Approximately 2,000 new chemicals are placed on the market each year. Only a small
proportion of chemicals have ever been tested for toxicity and there is a lack of knowledge
about how they interact in mixtures. Evidence is emerging of a complex network of
problems which vary depending on the chemicals, mixes, species and environment.35

Risk management

8. The Royal Society of Chemistry outlined five principles to manage the risks from
chemicals in everyday life: the precautionary principle, risk and impact assessments,
mutual recognition, innovation and citizens’ ‘right to know.’36 The Chemical Industries
Association supports a risk-based approach for chemicals management. It said, ‘considering
both hazard and risk of chemicals alongside the potential benefits they bring to society is
the most effective means by which they should be regulated.’37 We heard evidence from
government bodies including the Food Standards Agency and Office for Product Safety
and Standards indicating they follow this approach.

9. Professor Michael Depledge of the University of Exeter told us that the regulatory
environment for chemicals is ‘firefighting’. He asked us to consider ‘what kind of chemical
environment are we willing to live in in the coming years’38 and suggested a ‘do no harm’
approach, mirroring the medical approach where ‘effort is put in to try to minimise that
harm.’39 Dr Michael Warhurst of CHEM Trust noted that there is a delay between the
use of a chemical and identifying problems. He called for a more proactive approach to
assessing the likely toxicity of chemicals with similar structures.40

30   Q475
31   Chemical Industries Association (TCS0014), p 2.
32   Grandjean, P., Paracelsus Revisited: The Dose Concept in a Complex World, Basic & Clinical Pharmacology &
     Toxicology, vol 119 (2016), p 1.
33   Grandjean, P., Paracelsus Revisited: The Dose Concept in a Complex World, Basic & Clinical Pharmacology &
     Toxicology, vol 119 (2016), p 1; Chemical Industries Association (TCS0014), p 2.
34   Chemical Industries Association (TCS0014), p 2.
35   Q6
36   Royal Society of Chemistry (TCS0034), pp 2–3.
37   Chemical Industries Association (TCS0014), p 2.
38   Q6
39   Q7
40   Qq131–133
10    Toxic Chemicals in Everyday Life

Previous inquiries
10. The Committee held an inquiry into the future of chemicals regulation after the EU
referendum in 2016–17. We heard from stakeholders including academics, environmental
groups, business representatives and government agencies. The inquiry concluded that
establishing a fully stand-alone system of chemicals regulation for the UK will be expensive
for taxpayers and for industry and the Government should seek to remain involved in the
ECHA’s registration process for chemicals as a minimum.41 The Government’s response
was published in September 2017. The Committee followed up this inquiry with a one-off
evidence session with stakeholders in December 2018 to consider further work required
to prepare the chemicals industry if we leave the EU.

Our inquiry
11. We launched a call for evidence on the impact of toxic chemicals in everyday life in
February 2019. The inquiry held four oral evidence sessions which heard from leading
academics in ecotoxicology, product safety experts, retailers and industry representatives.
In addition, the inquiry ran a survey about the public’s knowledge of chemicals in
consumer products. It received 589 responses and a summary of responses is provided in
Annex 2. The inquiry also held outreach events at IKEA Greenwich and Victoria Leeds to
gather consumer views about chemicals in consumer products.

12. As our inquiry considered the presence of chemicals in consumer products, two
specific issues emerged: the Government’s review of the 1988 Furniture and Furnishings
Regulations and environmental contamination around the Grenfell Tower site. This has
been reflected in the structure of this report. The environmental and human health effects
of chemicals in consumer products will be considered in Chapter Two. Chapter Three
and Four will be case studies of the use of flame-retardant chemicals in UK furniture and
environmental contamination from chemicals around the Grenfell Tower site. Product
safety and the future regulatory environment for chemicals in the UK is discussed in
Chapters Five and Six.

41   Environmental Audit Committee, Eleventh Report of Session 2016–17, Future of Chemicals Regulation after the
     EU Referendum, HC 912, p 4.
Toxic Chemicals in Everyday Life      11

2 Environment and human health
  impact of chemicals
Environment
13. There is a vast array of chemicals in the environment. These span historical
contaminants such as metals and persistent chemical pollutants to substances for modern
use such as pesticides, pharmaceuticals, nanomaterials and chemicals in consumer
products.42 They are released directly or as by-products of industrial and manufacturing
processes, energy generation, agriculture and pharmaceuticals.43 The persistence and fate
of chemicals in the environment is controlled by natural processes and ecosystems are
exposed to complex chemical mixtures.44 In 2013, the UN estimated that 27 percent of total
global ecosystem loss was due to chemical pollution.45 The Lancet Commission estimated
that 9 million premature deaths worldwide were attributable to pollution in 2015 and
it determined that ‘chemical pollution is a great and growing global problem’.46 It has a
cumulative effect where the whole food chain is impacted ‘because different chemicals will
have different effects on different parts of the ecosystem.’47 UK Research and Innovation
said it is not yet known what contribution chemicals make towards biodiversity loss and
environmental degradation.48

14. Professor John Sumpter of Brunel University told us that it is not possible to know
which chemicals we should be most concerned about. Using the example of Teflon, he said
that as one damaging chemical is restricted, over 1,000 similar chemicals are patented,
with many still in use.49 Chemicals in the environment are managed through international
conventions and by the EU’s REACH regulation.

International chemicals management

15. The management of chemicals is included in Goals 3 and 12 of the Sustainable
Development Goals. Target 3.9 aims to ‘substantially reduce the number of deaths and
illnesses from hazardous chemicals’ while target 12.4 aims to ‘achieve the environmentally
sound management of chemicals and all wastes throughout their life cycle.’50 International
oversight of chemicals is provided by the United Nations Environment Programme, the
OECD’s chemical safety and biosafety division and the World Health Organisation’s
International Programme on Chemical Safety. The UN administers the Strategic
Approach to International Chemicals Management, a policy framework to achieve the
safe management of chemicals throughout their life cycle51 and published its second global

42   Q5
43   Centre for Ecology & Hydrology (TCS0025), p 3.
44   UK Research and Innovation (UKRI) (TCS0022), p 2.
45   Wildlife & Countryside Link (TCS0024), p 3.
46   The Lancet, The Lancet Commission on pollution and health (2017), p 462.
47   Q2
48   UK Research and Innovation (UKRI) (TCS0022), p 2.
49   Q4
50   UN Sustainable Development Goals, Goal 3: Ensure healthy lives and promote well-being for all at all ages; UN
     Sustainable Development Goals, Goal 12: Ensure sustainable consumption and production patterns [accessed 28
     February 2019].
51   SAICM, SAICM Overview [accessed 11 March 2019].
12    Toxic Chemicals in Everyday Life

chemicals outlook in early 2019.52 It has also implemented global treaties to control the use
of hazardous chemicals including the Basel, Rotterdam and Stockholm Conventions (on
the trade in hazardous waste and ending the production of persistent organic pollutants).53

Persistent Organic Pollutants (POPs)

16. The 2004 Stockholm Convention [hereafter ‘the Convention’] aims to protect human
health and the environment from persistent organic pollutants (POPs). POPs are organic
chemical substances that remain intact for a long time, become widely distributed in the
environment through natural processes, accumulate in the fatty tissue of organisms and
are toxic to humans and wildlife.54 Food is the primary route of exposure for humans.
Professor Mumford explained that ‘probably 80% to 90% of our foodborne contact with
POPs is through animal products—through dairy, meat, fish and oils.’55 POPs can be toxic
to the liver, kidney and nervous, reproductive and immune systems and cancer-causing.56
The Convention requires signatories to prohibit or eliminate the production and use of
POPs. They must also take measures to ensure wastes containing POPs are managed in an
environmentally sound manner. 28 chemicals are restricted under the Convention with
a further three under review.57 The UK ratified the Convention in April 2005 and the
Government has a national implementation plan for its delivery. The 25 Year Environment
Plan commits the Government to fulfilling its obligations under the Convention including
the elimination of polychlorinated biphenyls (PCBs) by 2025 and increasing the amount
of material containing POPs being destroyed or irreversibly transformed by 2030.58

17. POPs continue to be found in the environment and organisms despite the Convention.
Reports suggest that levels of PCBs in Europe have stabilised rather than continuing to
decline.59 Dr Kimberley Bennett of Abertay University said that there has not been a
substantial reduction in the environmental risk from POPs to seals in the North Sea in
15 years. This indicated that ‘relying on a ban of production and use is not sufficient to
eliminate POPs from the environment and from the food chain in a timely way.’60 Professor
Tamara Galloway from the University of Exeter told us that regulation has contributed to
a fall in the concentration of PCBs in seafood and focused remediation can be effective in
reducing levels of PCBs below toxic levels.61

Chemicals in the UK environment

18. The Government’s approach to chemicals in the environment is set out in the 25 Year
Environment Plan and the 2018 Resources and Waste Strategy. The 25 Year Environment
Plan is focused on POPs and the UK’s obligations under the Stockholm Convention.62 It
does not consider chemical pollution or exposure from chemicals in consumer products.63
The Resources and Waste Strategy sets out how the Government will approach sustainable
52   UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019).
53   Basel Convention; Rotterdam Convention; Stockholm Convention [accessed 19 June 2019].
54   Stockholm Convention, What are POPs? [accessed 19 June 2019].
55   Q152
56   Persistent Chemical Pollutants, POSTnote 579, Parliamentary Office of Science and Technology, July 2018, p 2.
57   Persistent Chemical Pollutants, POSTnote 579, Parliamentary Office of Science and Technology, July 2018, p 1.
58   HM Government, 25 Year Environment Plan (2018), p 30.
59   Plastics leading to reproductive problems for wildlife’, The Guardian, 27 February 2019.
60   Dr Kimberley Bennett (TCS0026), p 3.
61   Q5
62   HM Government, 25 Year Environment Plan (2018), p 30.
63   CHEM Trust (TCS0012), p 6.
Toxic Chemicals in Everyday Life     13

chemicals use as it moves towards a circular economy. It notes that ‘there are significant
opportunities for resource efficiency savings in the chemicals sector.’64 Legacy chemicals
in products were identified as a problem as they contaminate waste streams and pose a
barrier to efficient recovery of resources. It cited Extended Producer Responsibility (EPR)
and Eco-design as methods to address these issues.65 Wildlife and Countryside Link and
CHEM Trust called on the Government to set targets for the reduction of chemicals in
the environment.

           The Government needs to set targets and strategies for the reduction into
           the environment from all sources of all substances of regulatory interest
           (e.g. all SVHC on ECHA’s candidate list, all substances in the REACH
           Restrictions process). They also need to address emerging chemicals of
           concern (persistent, mobile, endocrine disruptors etc) that are found in
           everyday products such as many “new” bisphenols.66

The Natural Environment Research Council (NERC) is supporting research into the
environmental risk from chemicals via its Emerging Risks of Chemicals in the Environment
programme. This is expected to lead to a transformation in how chemical risk assessment
is considered and moves towards an ecosystems approach.67

Extended Producer Responsibility

19. The Resources and Waste Strategy identified EPR as a method of reducing the
contamination of waste streams by chemicals. The waste management of products
containing harmful chemicals has a direct effect on the environment as toxic substances
can be released into the air, water and soil. These toxins can leach from landfill, enter soil
and water, travel long distances, accumulate in tissues of plants and animals, before entering
human bodies. The management of plastic waste through incineration, gasification and
pyrolysis can release toxic metals, dioxins, furans and acid gases. This can lead to direct
or indirect exposure to toxic substances for workers and communities.68

20. In the Resources and Waste Strategy, the Government committed to an EPR scheme
for bulky waste including mattresses, furniture and carpets by 2025.69 This is unlikely to
be consulted on before 2020.70 Defra is also developing a strategy with local authorities
and the waste industry to divert high risk items away from landfill.71 In evidence, Dr
Thérèse Coffey, Parliamentary Under-Secretary of State for the Environment, was unable
to give detail on the EPR scheme for bulky waste as it is still in early stages; however she
confirmed that the ‘polluter pays’ principle will form an element.72 She acknowledged
that chemicals used in bulky waste pose a technical challenge for identification and safe
removal. The Environment Agency is working with industry to find a solution to dispose
safely of brominated flame retardants.73 Cement kiln co-incineration was proposed as one
64   HM Government, Our waste, our resources: a strategy for England (2018), p 46.
65   HM Government, Our waste, our resources: a strategy for England (2018), p 46.
66   CHEM Trust (TCS0012), p 7; Wildlife & Countryside Link (TCS0024), p 3.
67   UK Research and Innovation (UKRI) (TCS0022), p 2.
68   CIEL et al., Plastic & Health: The hidden costs of a plastic planet (February 2019), p 2.
69   HM Government, Our waste, our resources: A strategy for England (2018), pp 38–9.
70   Environmental Audit Committee, Eighteenth Special Report of Session 2017–19, Fixing fashion: clothing
     consumption and sustainability: Government Response to the Committee’s Sixteenth Report, HC 2311, p 9.
71   Department for Environment, Food and Rural Affairs (TCS0040), p 9.
72   Qq518–519
73   Qq500–501
14    Toxic Chemicals in Everyday Life

solution.74 Minister Coffey agreed that mandating the use of environmentally friendly
alternatives to flame retardants would be a good approach ‘if it fulfils the principle of what
it is there to do, which is safety and also [reducing] the risk from chemicals.’75

21. The Furniture Industry Research Association (FIRA) confirmed that they, alongside
the British Furniture Confederation and National Bed Federation, have had discussions
with Defra regarding the disposal of products containing flame retardants.76 In evidence,
retailers were broadly supportive of an EPR scheme; however IKEA stressed the need for
a harmonised approach.77 Amazon added that it would like the administration of the
programme to involve the entire supply chain, including recyclers.78 Kingfisher noted the
need to ensure it is designed correctly so that the market responds and the Government
can help to facilitate information about approved recyclers.79

22. In May, the Mail on Sunday reported that Amazon destroys unsold stock in France.80
Following the reports, the French Prime Minister’s office reported that more than €650
million worth of consumer products are thrown away each year and the government
moved to ban the destruction of unsold or returned consumer products including clothes,
electrical items and cosmetics. The ban will be introduced within four years.81 Amazon
was questioned about the practice in the UK and denied it took place:

           No. When I was talking about this earlier, I was talking about my knowledge
           of the UK’s work here, because I work in the UK office, is that we have a zero
           to landfill policy. I know that they are looking to try to continually improve
           that story everywhere across Europe. One of the challenges that we have
           in France is that donations are subject to VAT so there are fewer overall
           donation pathways as a result of that.82

23. It will not be possible to implement the ambitions of the Government’s 25 Year
Environment Plan and the Resources and Waste Strategy without a rapid transition
to a more circular economy for chemicals. We call on the Government to set ambitious
targets for the reduction of chemicals in the environment. The forthcoming Chemicals
Strategy should form the basis for the UK to develop a non-toxic environment by setting
out a clear, ambitious vision for the type of chemical environment we hope to live in. It
should lay out a plan for remediation of regulated substances in the environment with
binding targets.

24. We recommend that the Government works with the EU environment plan and
REACH to mandate the phase out of chemicals harmful to the environment. This should
include a ban on the use of substances of very high concern, including those under the
threshold level, ‘regrettable substitutes’ and groups of chemicals whose properties mean

74   Q511
75   Q509
76   Q371
77   Q314
78   Q315
79   Qq318–319
80   How Amazon destroys millions of new items it can’t sell with everything from TVs to kitchen equipment, books
     and nappies dumped in landfill sites, Mail on Sunday, 12 May 2019.
81   France to ban destruction of unsold consumer products, The Guardian, 4 June 2019.
82   Q325
Toxic Chemicals in Everyday Life     15

they do not easily breakdown in the environment. The Government should introduce an
EPR to enable the furniture industry to invest in technology to ensure the safe disposal of
hazardous wastes containing harmful chemicals such as brominated flame retardants.

25. The landfill and incineration of consumer products containing chemicals causes
harm to the environment, workers and communities. Reports from France suggest this
is happening in huge volumes to unsold stock. We restate the recommendation in our
Fixing Fashion report and call on the Government to ban the landfill and incineration
of unused and unsold consumer goods.

Attitudes to chemicals
26. In 2017, a survey by the European Commission found that 90 percent of Europeans
were worried about the environmental impact and 84 percent were worried about the
health impacts of chemicals in everyday products. This indicated a higher level of public
concern for chemicals than plastics.83 During this inquiry, we ran a similar survey to
gauge the views of the UK public about chemicals in consumer products. The survey
received 589 responses online and through outreach events at IKEA Greenwich and
Victoria Leeds. There was a high level of awareness (79 percent) of potentially harmful
chemicals in consumer products. The results mirrored the European Commission’s
findings of overwhelming concern about the impact of chemicals in consumer products.
98 percent of respondents were somewhat or very concerned about the impact on the
environment while 95 percent were somewhat or very concerned about the impact of
their health. Beauty and laundry products, air fresheners, toys, clothing and shoes were of
particular concern.84

27. We received written evidence of exposure to chemicals. Georgina Downs described
the effects of her exposure to the organophosphate flame retardant, triaryl phosphate
ester, via a faulty laptop.

           It was deemed a relatively high level exposure considering that the
           breakdown product of the OP [organophosphate] was still found in my body
           fat almost 3 months later in blood and fat tests that were taken at a medical
           and scientific laboratory at the end of October 2009. The body fat tests
           also found raised levels of another flame retardant called polybrominated
           biphenyls (PBBs).

           The extensive and subsequently diagnosed impacts on my eyes as a result of
           the exposure causing pain in the eyes, light sensitivity, acute problems with
           glare, dry eyes, significant disturbances in the field of vision (which is like
           looking through debris with how many black lines etc. there are), have been
           permanent ever since. Also, at the time and for a few weeks after I also had
           pinpoint pupils (a common feature of OP poisoning).85

83   European Commission, Special Eurobarometer 468 Report: Attitudes of European citizens towards the
     environment (2017), p 34.
84   Environmental Audit Committee, Survey results: Toxic Chemicals in Everyday Life [accessed 28 June 2019].
85   UK Pesticides Campaign (TCS0050), pp 3–4.
16    Toxic Chemicals in Everyday Life

Tracy Logan detailed her exposure to formaldehyde:

           Our toxic furniture installation occurred in April 2017. It involved built-in
           cabinets and wardrobes in our bedroom, which made our eyes sting for
           10 days following installation. The furniture firm told us this was normal.
           Eleven days after installation, a BRE air quality investigator sampled the
           air in our bedroom. This showed our bedroom air to contain more than
           thirteen times the WHO’s safety limit for formaldehyde, over eighteen
           times the Building regulations for VOCs [volatile organic compounds] and
           four times over the WHO limit for styrene. Emissions were significantly
           higher inside a new wardrobe.86

Human health
28. The Lancet Commission concluded ‘the effects of chemical pollution on human
health are poorly defined and its contribution to the global burden of disease is almost
certainly underestimated.’87 It suggests that chemicals have the potential ‘to cause global
epidemics of disease, disability and death.’88 This is linked to a lack of testing of chemicals
for their safety and toxicity prior to be being placed on the market. Pre-market evaluation
of new chemicals is a recent development and at present, is limited to a small number of
high-income countries.89 The World Health Organisation (WHO) estimated the disease
burden from chemicals as 1.6 million deaths and 45 million disability-adjusted-life-years
in 2016.90 This was an increase on its 2012 estimates and it suggested it is likely to be an
underestimate overall as data is only available for a small proportion of the chemicals to
which people are regularly exposed.91 In the EU, the annual cost of exposure to endocrine
disrupting chemicals alone is estimated at between €109 billion and €157 billion.92

29. Concentrations of chemicals identified in humans vary depending on the location.
Higher levels of some flame retardants have been identified in developed countries while
some pesticides are present in greater concentration in developing countries.93 Professor
Depledge told us that research by the European Centre for Environment and Human
Health also identified different socio-economic groups as a factor in the burden of
chemicals.

           … [we looked at] people from different socioeconomic groups within the
           NHANES study, let us just say from wealthy people to very poor people. We
           looked at the body burden of chemicals that they had and they were very
           different. Wealthy people tended to have more mercury, probably from the
           consumption of shellfish, shrimps and things like that, and more pesticides
           from the golf course, whereas poorer people had more chemicals, say, from

86   Tracey Logan (TCS0045), p 2.
87   The Lancet, The Lancet Commission on pollution and health (2017), p 462.
88   The Lancet, The Lancet Commission on pollution and health (2017), p 480.
89   The Lancet, The Lancet Commission on pollution and health (2017), p 462.
90   WHO, The Public Health Impacts of Chemicals: Knowns and Unknowns - Data addendum for 2016 (2018), p 1.
91   WHO, Chemical Risk Assessment Network Newsletter (Spring 2019), p 2.
92   Trasande, L. et al., Estimating burden and disease costs of exposure to endocrine-disrupting chemicals in the
     European Union, The Journal of Clinical Endocrinology & Metabolism, vol 100 (2015), p 1245.
93   UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 27.
Toxic Chemicals in Everyday Life      17

            landfill sites and from air pollution. They end up with a different spectrum
            of diseases. We are only beginning to see how socioeconomic conditions
            interact with body burdens of environmental chemicals.94

30. Health conditions associated with exposure to harmful chemicals include
developmental disorders, endocrine disruption, breathing difficulties, reproductive
disorders, cancers and neurological disorders.95 Foetuses, children and pregnant women
are most at risk.96 Baskut Tuncak, the UN Special Rapporteur on human rights and toxics,
warned of children being born ‘pre-polluted.’97 Recent studies have discovered banned
flame retardants in the umbilical cord blood of new-borns.98 Dr Michael Warhurst of
CHEM Trust explained that ‘the most sensitive period is always development; it is always
the foetus and the development of the brain.’99 Men and some occupations are also at
risk in certain environments. Research by the University of Nottingham linked declining
male fertility with concentrations of chemicals in the home.100 Firefighters are at greater
risk from some carcinogenic per- and polyfluoroalkyl substances (PFAs) and flame
retardants; cashiers from bisphenols used in till receipts.101 Research for the Health and
Safety Executive (HSE) has shown higher instances of sinonasal cancer in furniture and
textile industry workers exposed to formaldehyde and wood dust.102

Body burden of chemicals

31. Humans and animals are exposed to complex mixtures of chemicals from a variety of
sources on a daily basis. This exposure can impact on human and environmental health,
even if individual chemicals in a mixture are below their individual safety threshold
levels. Moreover, chemicals do not act in a uniform way in mixtures and can have complex
additive, synergistic or cancelling effects.103 Professor Depledge explained that as people
are living longer, there is evidence that they are developing diseases earlier in old age.104

            As we are now living longer, we are accumulating levels in our bodies that
            are much higher than ever before, so there is a much larger number of
            people with higher levels of these chemical mixtures than ever before and
            we do not know what the implications are of it.105

Professor Sumpter outlined that under current testing regimes, it is not possible to
determine if there is a risk to human health from long-term, low-level chronic exposure.106

94    Q39
95    Changing Markets Foundation, Testing for Toxics: How chemicals in European carpets are harming health and
      hindering circular economy (October 2018), p 11.
96    UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 30.
97    Pure Earth, Pollution knows no borders (2019), p 34.
98    UN Environment Programme, Global Chemicals Outlook II: From legacies to innovative solutions (2019), p 27.
99    Q133
100   School of Veterinary Medicine, University of Nottingham (TCS0038), pp 2–3.
101   Fidra (TCS0019), p 4.
102   HSE, The burden of occupation cancer in Great Britain (2012), p iii.
103   Davies, S., Annual Report of the Chief Medical Officer 2017: Health impacts of all pollution - what do we know?
      (2017), p 52; Dr Kimberley Bennett (TCS0026), p 3.
104   Q19
105   Q19
106   Q41
18      Toxic Chemicals in Everyday Life

Biomonitoring

32. The Royal Society of Chemistry told us that with increasing data and awareness
of the burden of chemicals, ‘we will seek as a society to know whether the chemicals
observed in our biofluids (blood and urine) are presenting significant harm to the quality
and longevity of life.’107 The EU’s Joint Research Centre is coordinating five research
programmes: chemical mixtures in the environment (SOLUTIONS), human health
(EuroMix, HBM4EU), endocrine disruption (EDC-MixRisk) and alternatives to animal
testing (EUToxRisk). The purpose is to consider the links between mixtures and diseases
and the interaction effects of chemicals.108 The UK government funds the annual Health
Survey for England. This measures physical and mental health alongside wellbeing,
social care and lifestyle behaviours of 8,000 adults and 2,000 children.109 UK Biobank, a
registered charity and international health resource, has collected samples from 500,000
people aged between 40–69 including body scans and lifestyle questionnaires. These
samples are used by researchers around the world investigating prevention, diagnosis and
treatment of a range of serious illnesses. It receives funding from the Medical Research
Council, Department of Health, Scottish and Welsh governments and other UK charities.110

     HBM4EU (Human Biomonitoring for the EU)

     The HBM4EU programme is a five-year, EU member state initiative funded through
     Horizon 2020 to coordinate and advance human biomonitoring in the EU. It runs
     until 2021. The project is intended to harmonize procedures for biomonitoring
     enabling the collection of comparable data on human internal exposure to chemicals
     and mixtures of chemicals. To achieve this, the project is developing indicators to
     ‘describe the exposure and body burden of chemical mixtures, with an emphasis on
     defining priority mixtures and identifying the drivers of mixture toxicity.’111 To date
     it has listed 18 priority substances including chemical mixtures, bisphenols, flame
     retardants, per-/poly-fluorinated compounds and phthalates.112

     It has been suggested that the UK is only participating in this programme in a limited
     way and is not fully involved in collecting data.113

33. Biomarkers can provide ‘a biological measure of current or historic exposure to a
pollutant.’114 They provide a broader perspective than measuring concentrations of a
pollutant in an environment as lifestyle factors are also accounted for. Through blood
and urine sampling, information about individual exposure can be assessed which can
inform estimations of the population’s exposure. Countries such as the US and Germany
have used these surveys to monitor chemical exposure over time.115 To date, the Health
Survey for England has not been used to study the effects of pollution, including from

107    Royal Society of Chemistry (TCS0034), p 5.
108    European Commission, Something from nothing? Ensuring the safety of chemical mixtures (May 2018), p 2.
109    NHS Digital, Health Survey for England - Health, social care and lifestyles [accessed 20 June 2019].
110    UK Biobank, About UK Biobank [accessed 21 June 2019].
111    HBM4EU, Exposure and Health [accessed 15 March 2019].
112    Chemical mixtures pose ‘underestimated’ risk to human health say scientists, Horizon Magazine, 15 May 2019;
       HBM4EU, Substances [accessed 22 May 2019].
113    Public Health England, UK Chemicals Stakeholder Forum - HBM4EU Presentation (June 2019), pp 11–12.
114    Davies, S., Annual Report of the Chief Medical Officer 2017: Health impacts of all pollution - what do we know?
       (2017), p 145.
115    Davies, S., Annual Report of the Chief Medical Officer 2017: Health impacts of all pollution - what do we know?
       (2017), p 145.
Toxic Chemicals in Everyday Life      19

chemicals. The Chief Medical Officer’s 2017 annual report noted that ‘the collection and
storage of biological samples and health data mean that such studies using HSE data
could be undertaken were funding to become available.’116 In a parliamentary debate
on chemicals regulation after leaving the EU, Minister Coffey said the Government’s
forthcoming Chemicals Strategy was intended to ‘support collaborative work on human
biomonitoring.’117

34. We received evidence in favour of the UK establishing its own biomonitoring
programme within the Chemicals Strategy.118 Breast Cancer UK said its understanding
was that the UK could continue to participate in the HBM4EU project until its completion
but may be unable to continue as part of any follow-on programme should we leave the
EU without a deal. It suggested that the UK establish its own biomonitoring programme
in such a scenario.119 Professor Sumpter described the potential benefits:

            … It seems a rather dull and routine thing to be doing, and yet
            biomonitoring—and, I would also argue, wildlife monitoring—is really our
            eyes and ears. It gives us another angle to see to what degree our chemical
            exposure is changing, increasing or decreasing, and how that may or may
            not be associated with health. Without that monitoring exercise, for many
            of our aspirations such as those mentioned in the 25-year environment
            plan, we would have no idea whether we would be achieving them.120

Professor Sumpter outlined that it would not be possible to monitor every chemical, so
choices would have to be made on what to monitor. He suggested that the establishment
of a programme would incur significant costs and take time to produce information.121
Professor Tim Gant of Public Health England said similar national studies in other EU
countries cost in the region of €1 million annually.122 On its benefit for decision making,
Professor Andrew Johnson of the Centre for Ecology and Hydrology cautioned that ‘it will
not solve all the questions you wish to ask but it would be a vital part of the evidence you
would need to come to those sorts of decisions.’123

35. Public Health England also supported the need for biomonitoring and further resource
for the HBM4EU programme. Professor Gant said it would enable better understanding
of ‘what exposures are within the population. Only with that information can you then
start to calculate risk.’124 He proposed that this could be done via blood, hair, saliva and
urine sampling.125 When questioned about the inclusion of a biomonitoring programme
within the Chemicals Strategy, Minister Coffey said:

            I have tried to outline that we are still at very early stages. Some of this
            will depend on the scenario that we have for [EU] exit, but biomonitoring
            is important to follow the trends and identify problematic substances. We

116   Davies, S., Annual Report of the Chief Medical Officer 2017: Health impacts of all pollution - what do we know?
      (2017), p 145.
117   HC Deb, 1 February 2018,col 440WH [Westminster Hall].
118   Q43
119   Breast Cancer UK (TCS0018), p 6.
120   Q44
121   Q47
122   Letter from Public Health England to EAC, 26 June 2019.
123   Q45
124   Q590
125   Q593
You can also read