This really is starting to get rather tiresome. Every new piece of
supposed guidance seems to sow more and more confusion, and things are
not helped by the rider that we may "use our professional judgement".
Using what criteria, exactly? DEFRA's guidance on the legal definition
of contaminated land states baldly that you can, in effect, come to any
conclusion you want concerning the contamination of site, so long as you
have been "reasonable" in what you do. The uncertainties inherent in the
whole process render the concept of a "risk based regime" almost
meaningless.

I recall with much fondness a seminar down in Edinburgh where 5 groups
worked on the same set of data : a case study of a residential
development on land within which were elevated concentrations of
benzo-[a]-pyrene and lead. Methane data were also given for a former
landfill lying off-site. Following study of the data, all groups were
asked to come to a conclusion on what to do. I think you can all guess
what is coming.

Group 1 : declare as contaminated land for B[a]P only
Group 2 : declare as contaminated land for lead only
Group 3 : declare as contaminated land for both B[a]P and lead
Group 4 : declare as contaminated land for methane only
Group 5 : would not declare as contaminated land

There is a very pressing need indeed to sort this out so that we can get
on one way or the other.

Dr. Anthony Luke
Principal Officer (Contaminated Land)
TEC Services
The Highland Council
38 Harbour Road
Inverness IV1 1UF
01463-228703
07766-298104
 
The opinions expressed herein are my own and do not necessarily reflect
those of the council

-----Original Message-----
From: Contaminated Land Management Discussion List
[mailto:[log in to unmask]] On Behalf Of Adam
Czarnecki
Sent: 01 July 2010 17:35
To: [log in to unmask]
Subject: Re: Updated HPA PAH CLIS document (version 3, dated 2010)

It was stated as being guidance (we dont need to use..... it our
professional judgement) that of course may change in the future. It will
be interesting to see if the approach is adopted in the new pending
revised EA TOX2. 
 
Adam

________________________________

From: Contaminated Land Management Discussion List on behalf of
Fairwood, Duncan (UK)
Sent: Thu 01/07/2010 17:27
To: [log in to unmask]
Subject: Re: Updated HPA PAH CLIS document (version 3, dated 2010)


It would be interesting to establish the List view on whether this HPA
document constitutes 'Guidance' for the industry / regulators, or does
the 'old' TOX2 report (which as far as I know hasn't been withdrawn by
the Agency) still hold sway?
 
A quick run through CLEA 1.06 using the EFSA BMDL10 and a Margin of
Exposure of 10,000 gives a GAC of 0.36 mg/kg (sandy loam; 1% SOM)...are
others getting similar results?
 

DUNCAN FAIRWOOD
Principal Consultant
BAE Systems Environmental
Euxton Lane, Chorley, Lancashire, PR7 6AQ
Tel:       +44(0)1257 242008
Fax:      +44(0)1257 242018
Mobile:  +44(0)7793 421835
Environmental Consultancy / Remediation Consultancy & Contracting
Visit our website at - www.baesystems.com/environmental 

BAE Systems Properties Limited
Registered Office: Warwick House, PO Box 87, Farnborough Aerospace
Centre, Farnborough, Hants, GU14 6YU, UK
Registered in England & Wales No: 2863702



-----Original Message-----
From: Contaminated Land Management Discussion List
[mailto:[log in to unmask]] On Behalf Of Chris
Dainton
Sent: 01 July 2010 17:00
To: [log in to unmask]
Subject: Re: Updated HPA PAH CLIS document (version 3, dated 2010)


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I raised the issue twice in open group discussion and they wouldn't be
drawn into discussing the down-the-line implications.

I'm sure they are well aware of it, but that's not their remit or in
their gift:  their hands are tied in many respects.

In the afternoon session, the attendees were split in four groups.  One
group discussed the toxicology and you'll have to get some feedback from
someone in this group on the detailed conversations that went on (the ID
issue was raised with the HPA who 'lead' the group).

Each group reported back in general terms and made recommendations for
the way forward (sorry, shouldn't use that term). 

SoBRA will be taking the PAH issues forward.

Many thoughts were raised on  methods to derive the ID for BaP and ways
to make the CLEA conceptual model a 'better' model (one hopes these will
all eventually combine to make CLEA outputs more realistic).


Chris




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