Para 3 is encouraging!
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Neil Parry
Sent: 12 April 2006 10:08
To: [log in to unmask]
Subject: Re: CLEA update Bulletin No.3 - CLAN 4/06
Please see below CLAN 4/06 which explains the situation quite well.
Happy reading.
Neil Parry
CLAN 4/06
DEFRA UPDATE ON SGVs
1. Neil Thornton's letter of 10 February (reference CLAN 3/06) to Jane Forshaw, Chair of the SGV Task Force, indicated that work was in hand within Defra to build on the work of the Task Force. This work was envisaged in the previous CLAN on this subject (CLAN 2/05), concerning the need for and content of further guidance on human health risk assessment to support decisions under Part 2A of the Environmental Protection Act 1990 ("contaminated land").
2. The Chair of the SGVTF had concluded that a number of practical and policy issues for Government had been identified by the Task Force work, including the development team's presentations and papers and the scientific debate.
Since January, Defra have been working with Jane Forshaw and Judith Lowe, the Environment Agency, the Health Protection Agency and ODPM. From this, a package of ideas, on which decisions can be made, is being drawn together, which aims to provide a way forward on SGVs, as envisaged in the earlier CLAN notes. This package is intended to fit within and support the existing legal framework. There are over 30 specific ideas under consideration. The approach is one of evidence-based policy making, and the valuable Task Force work forms part of the evidence. A technical workshop was held recently at which some issues were explored. Defra have now asked CL:AIRE (through Jane Forshaw) and Judith Lowe, on a consultancy basis, to assist in taking forward this work.
3. In this highly technical area, it is recognised by Defra that as much as possible of the foundation for decision-making has to be established centrally in guidance, rather individual decision-makers having to handle case-by-case, which leads to both inefficiency and inconsistency. That is a key policy objective.
4. Our aim is to:
- refine a suitable package of policy and practical options
- pursue such a package more widely within Government, including the devolved administrations and internally
- help explain and explore support for proposals with key stakeholders and contributors, and
- carry forward the envisaged improvements in a timely manner.
5. In the interim, Defra and the Environment Agency do not intend to publish further Soil Guideline Value or Toxicological reports, while this work continues. This is because the work is likely to lead to some changes, and it now makes sense to take account of this before publication of further guidance in the series, rather than doing so afterwards. The existing publications in the series, and other technical guidance, continue to be applicable and Defra continues to support their use in site-specific decision-making in accordance with the advice in CLAN 2/05. (see http://www.defra.gov.uk/environment/land/contaminated/index.htm )
6. While it is not possible to offer a timetable for expected outputs at present, one should be available as soon as work and agreement is further advanced. Further updates will be provided as soon as possible, and the need for progress is fully recognised.
Contaminated Land Branch
LEQ/Defra
10 April 2006 e-mail enquiries: [log in to unmask]
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Jonathan Parr
Sent: 07 April 2006 15:23
To: [log in to unmask]
Subject: Re: CLEA update Bulletin No.3
I agree with Kevin, it is an uncessarily knee jerk reaction.
SGVs were only ever meant to show there was no significant possibility of significant harm, or there was a possibility of significant harm; thats why the HCVs were based on NOAELs where available, or route-to-route extrapolations where not.
to put it into modern usage, they show that a site is safe for use under planning, or that there could be issues from contamination so further work was necessary, and show that a site IS NOT Part IIA contaminate land
This was made evident in all the CLRs and the SGV reports published. if people misconstrued this then they hadn't read the guidance about them properly.
To stop producing them is a wholly unsatisfactory reaction, and seems to suggest that the EA/DEFRA dont really understand them either.
The issue seems to tbe the definition of unacceptable intake in Table B of the Circular. Unacceptable intake i am assuming means that if you ingest contaminants from the ground and an effect is seen, then this is unacceptable. So to extrapolate; unacceptable intake = LOAEL as acceptable intake = NOAEL.
The only probelm i can forsee is with Index Dose contaminats, which theroetically have an effect with one molecule.
Giles email suggests a way around this, the only issue is if we have to have a complete overhaul of the methodology we use how long will it take? i seem to remember CLEA being talked about in 1999 way before the model was published.
if it wasnt so important i would laugh!!!
Jon
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]On Behalf Of Kevin Privett
Sent: 07 April 2006 15:12
To: [log in to unmask]
Subject: Re: CLEA update Bulletin No.3
If it is inappropriate to issue new SGVs, this is because it would be inappropriate to use them if they were to be issued.
If it is inappropriate to use a new SGV, it must be inappropriate to use an old SGV, since both are calculated on the same basis.
Inappropriate for what? That is the question. The answer is inappropriate to determine under Part IIA.
As we have all worked out some time ago. They have a value in that soil concentrations below the SGV give no cause for concern. However, it is not possible to tell from an SGV alone if a soil concentration exceeding the SGV is safe or not safe.
This second point appears to be the reason for putting them on hold. In which case, it seems a bit of a knee-jerk reaction given that the first point is still valid and more SGVs would help in that respect.
Unless there is an even worse skeleton lurking in the cupboard.............
Regards,
Kevin Privett.
Dr Kevin Privett
Geo-Environmental Associate
Hydrock Consultants Ltd
Over Court Barns
Over Lane
Almondsbury
Bristol
BS32 4DF
Tel: (01454) 619533
Fax: (01454) 614125
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-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Guppy, Steve
Sent: 07 April 2006 13:52
To: [log in to unmask]
Subject: Re: CLEA update Bulletin No.3
I see no change in the current situation other than its unlikely to be resolved soon.
My only concern is that some developers and the like misinterpret this latest news and suggest that it is no longer appropriate to use existing SGVs. They clearly still have a role and it would have been useful if the bulletin had indicated this. Perhaps its not too late for revised version of Bulletin No.3 to make such a statement?
Regards
Stephen Guppy
Team Leader - Scientific Services
Pollution & Safety
Environmental Health & Consumer Protection
Southampton City Council
* 023 8083 4166 * 023 8083 3075
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Protect the environment - only print if absolutely necessary - avoid wasting paper
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]On Behalf Of Ivens, Rob
Sent: 07 April 2006 13:17
To: [log in to unmask]
Subject: Re: CLEA update Bulletin No.3
Andrew/etal
the task force already had a meeting of about 45 interested parties- consultants landowners, and industry representatives. 7 local authorities were there. I got a belated invite because of some stats work we were doing with ESI. The task force were looking at>
1. Sampling- how much data do you need to collect/how do you ensure your data is satisfactory to make a decision that an action level is exceeded.
2. the CLEA model.
3. resources-
I went to 1 and two.
1. Sampling- The results from the sampling was that people needed a linked piece of guidance that could help make decisions about the uncertainty in their data and how to improve it. so some improved stats tests but more importantly something that pulls the user through a process of testing and improving the data set.
2. The CLEA model- the thing I found most interesting here was the idea that their ought to be consideration given to pulling the tox uncertainties through the model so that decisions on iffy tox data would be more transparent. Other people may have picked up other issues
So much to read.
So Little Time
Rob Ivens MVDC- 01306 879232
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]On Behalf Of Andrew Bent-Marshall
Sent: 07 April 2006 13:05
To: [log in to unmask]
Subject: Re: CLEA update Bulletin No.3
I agree this is frustrating.... But will we really notice much difference, at least in the short term? We weren't exactly being overwhelmed with new Tox and SGV reports anyway.
My main concern is that, whilst all parties accept that better guidance is required, there is never any indication of timescales. If previous experience is anything to go by the review process could take a number of years....and this all coincides with the BVPI's, which are aimed at improving progress on Part IIA!
On a positive note, does this present an opportunity for Contam Land Officers across the country to influence future guidance? I don't want to step on anyone's toes in the task force, but should we be consider some kind of national response to this, perhaps coordinated across the Cluster Groups? Maybe the task force has this in hand already (please advise)?
Any comments on this are welcome.
Andy Bent-Marshall
Principal Land Quality Officer - London Borough of Hounslow
Tel: 020 8583 5062
Fax: 020 8583 5134
www.hounslow.gov.uk
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-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]On Behalf Of Jonathan Parr
Sent: 07 April 2006 11:32
To: [log in to unmask]
Subject: Re: CLEA update Bulletin No.3
Tears hair out in frustration!
Let unnaceptable intake = LOAEL and then they can get on with it!
This is a ridiculous situation to be in; why should they stop publishing them because of a Part IIA problem, SGVs as they are are fine for Planning!
Jon
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]On Behalf Of David Fountain
Sent: 07 April 2006 11:25
To: [log in to unmask]
Subject: Re: CLEA update Bulletin No.3
leaves us waiting, waiting, waiting
not the best news.
Dave Fountain
Contaminated Land Officer
East Staffordshire Borough Council
Tel: 01283 508848
Fax: 01283 508890
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]On Behalf Of Jo McMillan
Sent: 07 April 2006 11:23
To: [log in to unmask]
Subject: CLEA update Bulletin No.3
Any comments on this mornings news from the Agency?
http://www.environment- agency.gov.uk/commondata/acrobat/bulletin_3_1343154.pdf
Where does this leave us now?
Regards
Jo
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