Your right about the driving development away (could happen)? but surly
the slightly extra cost of contracting someone who can carry out a risk
assessment properly and therefore comply with the developers obligation
should out weigh any resistance. I have found developers are responsive
to our requests once their responsibility has been clearly pointed out.
The stance on the Dutch values is aimed at the smaller consultancies who
seem to rely heavily on the Dutch values and occasionally quote ICRCL
59/83. in my opinion this can not be accepted as acceptable.
Christiaan
-----Original Message-----
From: Contaminated Land Management Discussion List
[mailto:[log in to unmask]] On Behalf Of
Jonathan Parr
Sent: 21 January 2005 13:11
To: [log in to unmask]
Subject: Re: Rejection of Dutch Intervention Values
Hi All!
The paragraphs Chris mentions in the two new SGV reports quite clearly
indicate that there is an order of magnitude difference between DEFRA's
SGV's for toluene and ethylbenzene when comapred to the equivalent Dutch
figures, even when soil organic matter is adjusted to UK generic
guidance levels. Utilising the levels of the Dutch isnt authoritative
and in line with UK policy, and it also comes way down the hierarchy of
sources within CLR9 (UK, European (meaning EU, not other countries
within Europe), International (i.e. WHO), and finally other countries
(all the Dutch list and USEPA screening levels and everything else) and
those bu authoritative bodies but used for different purposes) With this
in mind it would seem impossible to defend the use of Dutch levels
within the UK. The only safe way around this is for the consultant to
undertake a DQRA and deriving SSAC's using SNIFFER.
This may well be asking a lot but at then end of the day, as regulators,
it is partly our responsibility to drive up the standards of SI's within
the land contamination industry and to protect the public health.
Also made public for the first time is that the EA have now adopted the
Johnson and Ettinger model for modelling inhalation of indoor vapour,
and dropped the Krylov and Ferguson model. The implications for this
with regard to Organic compounds are important; you can't use CLEA 2002
anymore as the Governments Policy has changed and CLEA 2002 is out of
date. Also to be brought to attention is the changing of building
parameters, also meaning CLEA 2002 is out of date. In light of this we
should all really be using SNIFFER to do DQRA's where an SGV does not
exist for a site. CLEA-UK cant come along too soon!!!!!!!!
Controversial I know but there you go!!!!!!!!!!!!!!!!!
Jon
Jonathon Parr
Public Protection Officer (Contaminated Land)
Blackpool Borough Council
[log in to unmask]
(01253) 478318
-----Original Message-----
From: Allison, John DCCS [mailto:[log in to unmask]]
Sent: 21 January 2005 12:38
To: [log in to unmask]
Subject: Re: Rejection of Dutch Intervention Values
Hello Christiaan,
The Dutch values are perfect for use in The Netherlands given their
particular policies on risk assessments and as you spotted different
soil types. Even if you correct for soil, the last time I looked at them
the human health side was based on average human receptors and not the
most sensitive receptor as current UK policy requires. The Dutch do tend
to revise their values much more frequently than we do which personally
I believe is no bad thing. Strictly speaking I would say that the use
of the Dutch values is inappropriate in this country for risk assessment
as they don't comply with UK policy on risk assessment. Having said this
the toxicology and modelling behind the values may be useful and there
may be times when it is appropriate to have a look through the values
and their calculation for guidance as they do cover a wide range of
contaminants. As ever though an "eyes open" approach is necessary when
doing this.
regards
John Allison BSc(Hons) MRSC SiLC
Scientific Officer (Contaminated Land)
Environmental Health & Consumer Protection
Knowsley Metropolitan Borough Council
Municipal Buildings
Cherryfield Drive
Kirkby
Merseyside
L32 1TX
Tel: 0151 443 2796
Fax: 0151 289 7488
-----Original Message-----
From: Contaminated Land Management Discussion List
[mailto:[log in to unmask]] On Behalf Of
Christiaan Wilkinson
Sent: 21 January 2005 11:18
To: [log in to unmask]
Subject: Rejection of Dutch Intervention Values
Hello All,
Before I take a new stance on the use of the Dutch Intervention Values
in GQRA could you give me some feedback on my thoughts.
Thanks,
Christiaan
Lancaster CC
Recent publication of the first organic SGV's (Toluene & Ethylbenzene)
show that the Dutch values contain large variations in their values. For
example, the current DVI for Toluene in soil is 339 mg kg-1. If this
were adjusted from 10% soil organic matter to 2.5% the intervention
value would be 84.8 mg kg-1. The Dutch have recently proposed to replace
the human health IV with new Serious Risk Concentrations (SRC)
guidelines. The proposed SRC for Toluene is 32 mg kg-1. The proposed SRC
is a ten-fold decrease from the current DVI. (SGV 15, 2004)
A further example of DVI variance is also in evidence in SGV16
(Ethylbenzene). Current DVI for Ethylbenzene in soil is 50mg kg-1. The
corrected soil organic matter from 10% to 2.5% would be 12.5 mg kg-1
which is a factor of two lower. However, the proposed SRC is 111mg kg-1
which shows a two-fold increase.(SGV 16, 2004)
UK policy requires the assessor to adopt the most conservative approach
when carrying out a Tier 1-risk assessment. The guidelines used must be
"appropriate, authoritative and scientifically based" (DETR Circular
02/2000). Based on this policy and the above evidence the LA does not
view the Dutch Intervention Values as being appropriate or
authoritative.
This e-mail and any attachments are confidential and may also be
privileged.
If you are not the intended recipient you should not copy or use any
part of it or disclose its contents to any person. If you have received
it in error please notify the sender immediately.
This e-mail and any attachments are believed to be virus free but it is
the recipient's responsibility to ensure that they are.
Email Disclaimer is:
http://www.blackpool.gov.uk/democracy/corpdocs/EmailDisclaimer.htm
This message has been scanned by F-Secure Anti-Virus for Microsoft
Exchange as part of the Council's e-mail and internet policy.
UK businesses use up 2 million tonnes of paper each year.Think before you print this email - do you really need to? Thank you.
-----------------------------------------------------------------
The information in this e-mail is confidential and may be legally privileged. It is intended solely for the addressee. Access to this e-mail by anyone else is unauthorised. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful. Although this e-mail and any attachments are believed to be free of any virus, or any other defect which might affect any computer or IT system into which they are received and opened, it is the responsibility of the recipient to ensure that they are virus free and no responsibility is accepted by Lancaster City Council for any loss or damage arising in any way from receipt or use thereof.
Furthermore the views contained in this e-mail are those of the originator. Unless they state otherwise they are not the views or opinions of the Council.
-----------------------------------------------------------------
Scanned by Information Services for all known Viruses.
|
