This could all degenerate into silliness e.g. the knights that say Kd!, plant uptake factor of a leafy vegetable.....African or European! J

 

 

 

Dave Fountain
Contaminated Land Officer

*   email: [log in to unmask]
(  Office: 01283 508848 (direct dial)
2   Fax: 01283 508890
+  Post: Environmental Health Division, East Staffordshire Borough Council, Midland Grain     
Warehouse, Derby Street, Burton upon Trent, Staffordshire, DE14 2JJ.
:   Web Site: www.eaststaffsbc.gov.uk

P Help save paper - do you really need to print this email?

-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]]On Behalf Of Pearce, Steven (SKM)
Sent: 24 September 2008 14:49
To: [log in to unmask]
Subject: Re: GAC's- something like this perhaps???? (formerly Re: LQM/GACs)

Get that man on the bbc making a sketch show

 

here is a bit more python for you

 

they were thought I was mad to make this model, but I did it anyway just to show them

So I built the model....it crashed

so I built it again, that crashed

From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Ivens, Rob
Sent: 24 September 2008 14:37
To: [log in to unmask]
Subject: GAC's- something like this perhaps???? (formerly Re: LQM/GACs)

 

     Mr. Praline: 'Ello, I wish to register a complaint.

     Mr. Praline: 'Ello, Miss?

     DEFRA: What do you mean "miss"?

     Mr. Praline: I'm sorry, I have a cold. I wish to make a complaint!

     DEFRA: Its 11.30, We're closin' for lunch, come back at 4.

     Mr. Praline: Never mind that, my lad. I wish to complain about this software what I downloaded not half an hour ago from this very website.

     DEFRA: Oh yes, the, uh, the CLEA model...What's,uh...What's wrong with it?

     Mr. Praline: I'll tell you what's wrong with it, my lad. 'E's dead, that's what's wrong with it!

     Owner: No, no, 'e's uh,...he's just out for evaluation.

     Mr. Praline: Look, matey, I know a dead QRA Model when I see one, and I'm looking at one right now.

     Owner: No no he's not dead, he's, he's just at Beta testing'! Remarkable model, the CLEA model, idn'it, ay? Beautiful algorithms!

     Mr. Praline: The algorithms don't enter into it. It's stone dead.

     Owner: Nononono, no, no! 'E's testing!

     Mr. Praline: All right then, if he's testin', I'll use it! (shouting at the computer) 'Ello, Mister CLEA! I've got a lovely fresh risk assessment for you if you
     show...

     (DEFRA hits the computer)

     DEFRA: There, he moved!

     Mr. Praline: No, he didn't, that was you hitting the computer!

     DEFRA: I never!!

     Mr. Praline: Yes, you did!

     DEFRA: I never, never did anything...

     Mr. Praline: (yelling and hitting the computer repeatedly) 'ELLO CLEA!!!!! Testing! Testing! Testing! Testing! Where’s your SGV’s?, Where’s your phys. Chem. data..?

     (Takes hard disc out of the computer and thumps it on the counter. Throws it up in the air and watches it plummet to the floor.)

     Mr. Praline: Now that's what I call a dead model.

     Owner: No, no.....No, 'e's stunned!

     Mr. Praline: STUNNED?!?

    

YOU GET THE IDEA..........................

 

 

 

And I think there is a comedy sketch here

 

 

Remind me again which methodology has a legal basis under Part IIA and will stand up in a court of law?  Ah yes none of them

 

I wouldn't worry about PI cover, if it cant be argued in court that smoking causes cancer then I find it very unlikely that you will be seeing many successful prosecutions for BaP contamination

 

Risk aversion is the problem here, I would suggest that waiting for the magic answer from DEFRA/EA/HPA/daily mail is not a good idea as this is a political problem not a technical one.  The route of the problem is that the HPA and DEFRA are so risk adverse that they dont want to publish anything that may look like concrete advise.  Look at the disclaimer for the CLEA model, show that to a lawyer and see how concrete the numbers are that come out of it.

 

"The CLEA guidance describes the soil concentrations above which, in the opinion of the Environment Agency, there may be concern that warrants further investigation and risk evaluation for both threshold and non-threshold substances.  These levels area a guide to help assessors estimate risk.  It does not provide a definitive test for telling when risks are significant" 

 

So what exactly is CLEA useful for other then indicating that un specified further assessment is required?  Also what further risk evaluation can be done, I thought the point of DQRA was to do the risk evaluation.  I can only assume that by putting in the further evaluation statement the EA are eluding to a qualitative assessment of the results, which goes something like

 

"a value of 0.85mg/kg for BaP has been generated by CLEA, however because of the conservatism expressed in the model then it is unlikely that this represents the level at which significant risk of significant harm, therefore if BaP is detected at levels above this value on a site then remediation is not necessarily required"     

 

If this is what is being eluded to then this makes doing DQRA a bit irrelevant.  And who is accountable at the end of the day?  The consultant will have a disclaimer that says risk assessment is carried out in accordance with guidance from the EA/DEFRA, the LA will say they assessed the consultants report in accordance with the same guidance, the guidance meanwhile has a disclaimer saying that its up to the LA and consultant to determine if the level of risk is significant.  So who in this loop is actually accountable?   

 

To get some context, recently there has been a lot of press about acrylamide in fried food, I have looked this up on IRIS and the USEPA slope factor converted at 1 in 100,000 (i.e 10E-5) gives an oral ID of 2.2E-6 mg/kg/Bw.  This value is lower than that given for BaP, and the compound is found in any fried food you eat so the exposure is likely to be greater.  So are fried foods banned?  Does the HPA advise that eating Pringles is an unacceptable risk to human health?  No the food standards agency says that people have been eating fried foods for a long time, and more research needs to be done.

 

Perhaps you are eating some crisps right now...If you are interested in accessing the potential unacceptable risk to human health from eating Pringles on a saturday night then here is the link

http://www.food.gov.uk/news/newsarchive/2002/may/65268

http://toxnet.nlm.nih.gov/cgi-bin/sis/search/f?./temp/~yKyHUR:1

From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Albert.prince1
Sent: 16 September 2008 09:40
To: [log in to unmask]
Subject: LQM/GACs

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This email and any files transmitted with it are intended solely for the use of the individual or entity to which they are addressed. If you are not the intended recipient, the E-mail and any files have been transmitted to you in error and any copying, distribution or other use of the information contained in them is strictly prohibited.

The Council computer systems may be monitored and communications carried on them recorded, to secure the effective operation of the system and for other lawful purposes.

Notice - This message contains privileged and confidential information intended only for the exclusive use of the addressee named above. If you are not the intended recipient of this message you are hereby notified that you must not disseminate, copy or take any action in reliance on it. If you have received this message in error please notify us immediately. Opinions, conclusions and other information in this e-mail and any attachments that do not relate to the official business of the firm are neither given nor endorsed by it. Any documentation produced using this data is uncontrolled and not subject to update. The recipient is responsible for reviewing the status of the transferred information and should advise us immediately upon receipt of any discrepancy. Any design details are applicable to the intended project only. Subject to contract, we retain copyright of all the transmitted material and it must not be reproduced wholly or in part, or supplied to any third party without our written permission. The sender makes no warranty regarding the accuracy or completeness of the data transmittal or to the presence of computer viruses or data errors

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