Dear All,
I have been following the C4SL discussions with interest.
Putting aside the morality of Govt’s decision to increase public health risk from “minimal" to “low” in favour of economic growth, or the further erosion of the Precautionary and Polluter Pays Principles fundamentally underpinning our work, or the absence of any helpful governmental policy in the use of C4SL in Part IIA or planning work... I would like to discuss the practical questions of C4SL implementation...
How may Part IIA officers are formally trained in toxicology or experienced in deriving Benchmark Levels from primary epidemiological data?
How may Part IIA officers are equipped to critically appraise and challenge (on Appeal) the toxicological decisions and justifications of others?
Do Part IIA officers have access to suitably qualified and experienced toxicological specialists to assist them in their Part IIA and planning workloads? What additional resources and training will be made available to Part IIA officers for this new work?
Who is a "competent person” in this field anyway? (Prof, PhD, SiLC, NVQ?)
How did DEFRA/DCLG envisage that LAs will implement the new C4SL methodology anyway?
Best wishes,
David E Jackson
sometime freelancer..
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