Future UK chemicals regulation - our role in an international endeavour
Camilla Alexander-White, our senior policy advisor for environment and regulation, outlines why chemicals regulation needs to be high on the list in Brexit negotiations and calls for a future of increased international scientific cooperation and collaboration.
Tens of thousands of chemicals are manufactured for use in our everyday life and are vital to UK and global economies. The chemicals sector can be said to be an industry for all others, in that chemicals are integral to so many areas of research, innovation, processes and products. As well as bringing great benefits, some hazardous chemicals can present risks to human health and the environment.
The UK needs a future regulatory system that achieves a balance between nurturing innovation, protecting the environment and human health, and enabling the UK to trade internationally. The latter includes our ability to work with, and continue to trade in chemicals and products with, the EU post-Brexit.
Clear decision making functions need to be established for UK chemicals management
Our analysis shows the UK currently complies with more than 300 EU regulations relating to chemicals; these will be transposed into UK law via the EU Withdrawal Bill.
As we highlighted in our response to the House of Commons Environmental Audit Committee on ‘The Future of Chemicals Regulation after the EU Referendum’, to make UK regulation work, it is critical that the UK establishes how regulatory decisions will be made. This includes addressing how expert scientific input feeds in and what legal relationship the UK will have with EU bodies, such as the European Chemicals Agency (ECHA), that are currently key to decision-making.
Chemical sciences data and expertise underpin regulation relating to chemicals
It is critical to establish how data generated by industry, underpinning regulation, will be accessed, reviewed and interpreted. Diverse types of chemical sciences data are used in chemical safety assessment frameworks and interpreted by scientific experts who inform policymakers. On exit day, it is not clear if, and how, the UK will be able to access ECHA’s extensive databases. The UK has a strong reputation in the science underpinning chemicals regulation. EU scientific advisory committees, such as those at the European Food Standards Authority (EFSA), are rich in UK talent and regularly call for international scientific expertise. I hope that such strong scientific collaborations will continue between UK, EU and international experts.
International scientific cooperation and collaboration are vital to foster globally harmonised regulations and international trade
If the UK wants to look beyond the EU, strengthening its role as a world leader in research, innovation and new products for global trade, we need to understand how other potential partners regulate their chemicals, and assess regulatory alignment. Where there are divergences, the UK has an opportunity to use its expertise to foster greater alignments and regulatory innovation. Harmonisation happens at the scientific level: discussions between specialist scientists are needed from a range of disciplines relevant to regulation. The UN development of the globally harmonised system (GHS) of classification of chemical hazards, is a good example of successful cooperation between international scientists and regulators.
Looking to the future, it is positive to note that the issue of regulation – which we had pointed out was absent in an earlier Green Paper – has been mentioned considerably more in the UK government’s Industrial Strategy White Paper. The government has clearly recognised the importance of regulation, and the need to achieve the balance we advocate.
Our engagement activities to establish ‘what good looks like’ for regulation
Throughout 2017, we actively engaged on the future of UK chemicals regulation with our members and key stakeholders, such as those we liaise with on the UK Chemicals Stakeholder Forum (UKCSF). To engage with our members, we held a workshop with our Environment and Regulation Collective (EnReC) on ‘Science and the development of chemical & environmental policy’. We brought together over 50 expert scientists and senior policymakers to discuss four hypothetical future regulatory scenarios for the UK post EU-exit. The four scenarios (see image across the page) span two dimensions:
1. Strongly regulated to completely un-regulated chemicals management frameworks.
2. Complete divergence from, or complete alignment with, EU or other global regulations.
Discussion of these scenarios suggests the following in terms of what best practice looks like for future chemicals regulation:
• Clear, efficient and simple processes.
• Systems of decision-making that are proportionate and coordinated.
• Pragmatism in regulatory decision-making.
• Regulation informed by scientific evidence.
• Consistency and harmonisation with global principles.
At the Royal Society of Chemistry, we will continue to engage key stakeholders, drawing upon the expertise and experience of our global community, to ensure the chemical sciences have a voice in Brexit negotiations, the UK industrial strategy, and the development of future regulation in the UK and internationally.
How can I get involved?
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In the UK, get in touch with your MP: if you feel strongly about this issue, have questions on what the UK government is doing in this area, or feel you have knowledge to share, please do speak to your local MP.
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Contribute to UK government consultations: anyone can input evidence into open consultations, including individuals, so if you think your experience or expertise can add value, please do respond to these. You can search for open consultations on the www.gov.uk website.
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Join our Environment and Regulation Collective to contribute your views and join our workshops. All Royal Society of Chemistry members interested in this area are welcome to join, and we are particularly aiming to strengthen our connections to our global community. You can express your interest by emailing science@rsc.org.
The Institute of Directors Navigating Brexit series
Camilla also recently took part in a panel discussion at the Institute of Directors (IoD), which brought together members of the institute along with policy experts, industry specialists and politicians, to discuss chemicals, lifes sciences and our future relationship with the EU. Read Camilla's contributions and the thoughts of the other guest speakers on the IoD website.
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