Proposed risk assessment
methodology for hazardous substances
Submission Reference no: 3
Dr Charles Baycroft,
End 2 Pain (Charles Baycroft)
402
Marine Parade
South New Brighton
New Zealand
Ph: 021443081
[email address]
Submitter Type: Not specified
Source:
Web Form
Overall Notes:
Clause
1. Is the level of detail appropriate? (please reference page numbers as appropriate)
Position
Yes
Notes
People are becoming more concerned about our impact on the environment and are starting to prefer a more sustainable and
interactive approach in preference to invasive and manipulative initiatives. It would be a very good idea to survey public opinion
more widely to determine whether or not the ongoing and increasing use of poisons and "inorganic " methods and products
are favoured or disapproved of.
Clause
2. Are there any areas that you would like more information on? (please reference page numbers as appropriate)
Position
Yes
Notes
There is a growing awareness that ongoing exposure to subclinical doses of hazardous substances can have adverse long
term effects on health. Are wel constructed and administered Epidemiological studies a part of the proposal?
Clause
3. Is the level of detail appropriate? (please reference page numbers as appropriate)
Position
No
Notes
I would suggest that the wel known and wel respected PRECAUTIONARY PRINCIPLE should be the preeminent consideration
and that economic cost benefit analyses should be the least influential factors influencing decisions.
Clause
5. Are there any areas that need more guidance? (please reference page numbers as appropriate)
Position
Yes
Notes
There are already many concerns that the exploitation of our environment for financial gain is excessive and that the regulations
that are meant to protect the environment and the people are not properly enforced. Making rules that are not rigidly enforced
is a form of deception and false reassurance that hazardous substances are not being used irresponsibly.
Clause
6. Are there any other matters that should be addressed as part of this methodology? (please reference page numbers as
appropriate)
Position
Yes
Notes
The methodology should be based on the precautionary principle and the clear understanding that we are here to preserve our
environment for the benefit of future generations and not for the short term benefits of those with vested financial interests
who wish to irresponsibly exploit and pol ute it for their personal benefit.
Clause
10. Are the requirements practical and achievable? (please reference page numbers as appropriate)
Position
No
Notes
There are probably already too many potential y harmful and hazardous substances in our environment and more effort should
be made to reduce rather increase the numbers. Given the vast numbers of poisonous substances in use and the difficulties in
enforcing al the regulations there are bound to be regrettable consequences in the future.
Clause
11. When used in conjunction with the external guidelines for each model, is any further clarification required to be able to
perform a risk assessment? (please reference page numbers as appropriate)
Position
No
Notes
Risk assessment is a way to predict future events and human beings are notoriously bad at doing that. If one does not expect
the unexpected then there wil be cause for regrets.
Clause
12. Are the parameter values used by the EPA relevant and correct? (please reference page numbers as appropriate)
Position
No
Notes
Too much emphasis on economics and not enough on sustainability and preservation of the balance of natural species and
processes. we are meddling with systems that are so complex and interactive that we cannot hope to predict the
consequences. Better to reduce our human interference before the environment and nature decided to dispose of our
species.
Clause
13. Are the models used by the EPA relevant and correct? (please reference page numbers as appropriate)
Position
No
Notes
I tend to think that there is too much reliance placed on information provided by people with vested financial interests (from
within and outside of our government). Decisions should only be based on evidence and opinions obtained from total y
independent and unbiased scientists. Since this is very difficult to achieve al evidence and opinions should be regarded as
potential y biased and invalid. If there is any doubt at al then the decision should be NO.
Clause
14. Are there any alternate models that the EPA could consider? (please reference page numbers as appropriate)
Position
Yes
Notes
A model that is based on reducing the reliance on and proliferation of invasive measures and promotes a shift to organic
agriculture and less interventions.
Clause
7. Are there alternative groundwater models that the EPA could consider as part of a revised groundwater risk assessment
framework?
Notes
The effects of current activities on future quality of groundwater are very difficult to predict. Changes in the quality and
quantities of groundwater seem to be very unpredictable and evolve of longer time periods. Adverse effects are also difficult to
predict or accurately monitor and are most likely to be exceedingly difficult and costly to remedy once they have been identified.
Please err total y on the side of caution.
Clause
I would like my personal information (other than my name) to be withheld from any publicly available response documents.
Position
No
Notes
