Dear All,

 

Having had the weekend to sleep and reflect on the excitement of Friday 7th, and the issues it raised; I think I am able to find (a little) comfort in “CLEA update BN3”, described below.

 

The SGV Task Force have been working within what was, at the time of derivation, “best practice”. Implementation of CLEA02 (and associated CLR series documents) will have facilitated the most significant and thorough assessment of its application, far greater than could ever been undertaken within the TF, prior to issue.

 

It is actually (whilst frustrating) quite impressive that the Task Force had the strength of character to raise it’s hand and acknowledge, that whilst it was best-practice then, it may not quite be the best way to do it now. At the end of the day, (I assume as part of the JISC forum) we are all scientists and are working towards what is most-likely, based on experiences and hypotheses to date. When things occur to test our hypotheses we are to adapt and modify, again to what is most-likely, and don’t ever proclaim to be unequivocally “right”. We will leave that to theologists and mathematicians.

 

We must take re-assurance in that the massive advances in understanding and application since CLEA02 has caused the Task Force to question its original hypotheses, identify and acknowledge its inadequacies and then attempt to change them accordingly.

 

HHRA will always have uncertainty. Until we can feed a “representative” range of human specimens soil until they die (as a result) and monitor/guarantee the behaviour of a “representative” target group (note intentional conflicting English), there will always be enormous FOS in the assessment. Is this acceptable? – In the (very well timed) words of Paul Nathanial at RESCUE-Cardiff last summer: “…you don’t design and build a bridge to only-just stand up…”

 

It is simply essential that we (and the TF) continue to learn, review and change where necessary. BN3 has acknowledged this process, and whilst it feels frustrating that it is only 4-yrs since we last had to “learn from scratch”, it is reassuring that progress and improvements are being implemented so rapidly. ICRCL was known to be inadequate and was kicking about for well-over a decade!!!

 

I am sure (hope?) that the suggestion to use foreign/historic guidance again, will receive a resounding “No” from regulators/guidance authors. Even within Europe the contrast of other country’s perception of “risk” is highlighted through different laws on speeding, drugs, welfare et al. It does bring a wry smile however, as (I understand that) most of the exposure algorithms and behavioural scenario’s are based on/adapted from work imported from overseas… Whilst it has been suggested (by BN3) that the control measures currently in-place in the UK “could be better”, they are still based on UK derived best practice methodologies and are therefore most appropriate until an alternative format is issued formally.

 

Given the (relatively) large volume of JISC-chat on this topic, I doubt if many of you will read this (and I don’t blame you). Better get back to doing some work…

 

Take Care all,

 

(again) Good Luck!!

 

 

 

giles

 

 

 

Giles Sommerwill

Earth Science Partnership (Wales)

T: 029 20 813 385

F: 029 20 813 386

W: www.espwales.co.uk

 

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