The very presence of some chemicals presents a Risk, especially if they, or their containers, are not stable.
Furthermore the Hazard is not merely the chemical alone but the greater Risk is in how it is used.
The UK Health and Safety Executive makes much of the assessment of Risk as if simply assessing it reduces the Risk.
In truth the Risk is inherent in the presence of the chemical - and made worse by the way the chemical is used.
There is no control over the latter - or the fate of the chemical after it is released into the environment.
It is suggested that the Risk is reduced when the chemicals break down after release.
Unfortunately in order for chemicals to be effective they are produced in formulations with other chemicals.
Those chemicals may not only enhance the toxicity of the active ingredients but may also prevent their breakdown.
This effect greatly increases both the Hazard and the Risk - but is ignored in safety calculations.

There is a well known Risk when two or more chemicals act together.
This is a serious Risk but very little testing is done on the mixtures of chemicals - or their behaviour in the body.
This is especially so when chemicals from more than one manufacturer are involved.
In all too many cases no authority has any idea of either the Hazard or the Risk in such situations.

This is all the more evident when those who are medicated by doctors for existing illness are exposed.
Many drugs are dangerously contraindicated in cases where exposure to chemicals is involved.
Such situations would also include exposures in the womb where small exposures can have dramatic effects.
It is impossible for any Risk Assessment to consider these vital aspects when releasing chemicals into the environment.

Clearly there is a Hazard involved in the failure to assess these very real and unavoidable Risks.

Given the current situation is it good practice to promote the idea of Hazard versus Risk in the regulatory process?

The definition of "Hazard" (danger, risk etc.) is

A danger or risk; a potential source of danger; a safety hazard.
A factor or exposure that may adversely affect health; anything that has the potential to cause harm.

The definition of “Risk" (danger, peril, hazard etc.) is not so clear

It refers to 'the chance of danger, loss, injury or other adverse consequence' (Oxford English Dictionary)
– a risk to health - or it can be simply an indicator of threat or the probability of harm.
Probability calculations inevitably assume that it is acceptable for some individuals to be seriously harmed.
Probability calculations boldy claimed the Chernobyl and Fukushima disasters were unlikely to happen.

Then there is of course that catch-all phrase “Perception of Risk”

A judgement that people make about the potential adverse effects and severity of the Risk.
Those with previous experience of the adverse effects of a Hazard will have a differing perception to those who have not.
Regulatory authorities tend to think that merely a "Perception of Risk" induces the symptoms triggered by a Hazard.
They seem to want to educate away any "Perception of Risk" - as we see currently with pesticides and radiation exposure.
This does not reduce the Hazard or the Risk - in fact as with "familiarity breeds contempt” it increases the Risk.
A “Deadly Poison” does not suddenly become safe through a change in perception of its risk - or its container.

Then there is the definition of “Significant Risk” A risk of high probability that is likely to create an impact of some significance.
What may be a low Risk to some individuals could be much higher or even life-threatening to others.

Of course if there is no Hazard then there is no possibility of Risk and so the regulatory system knowingly puts us all at Risk.
Any suggestion that there is no Risk from a chemical ignores the failure to correctly assess the degree of Hazard involved.
As the Health and Safety Executive itself states in its Guidelines for the Control of Substances Hazardous to Health -
“Remember that hazards and risks are not limited to substances labelled ‘hazardous’”.

In the UK Control of Chemicals Hazardous to Health Regulations avoidance of Risk is a key factor.
In all situations the least hazardous methods should always be employed.
Only when all other possibilities have been eliminated should Personal Protective Equipment (PPE) be used.
With some chemicals, such as the ubiquitous organophosphates (OPs), there is no PPE that can completely prevent exposure.
Exposure to the skin and therefore via inhalation and ingestion, are equivalent to injecting the chemical into the blood stream.
OPs are found in our food and environment, even in the air that we breathe.
To susceptible individuals very small exposures can be extremely dangerous, even life-threatening..
Is this why the current propaganda proclaims safety for all pesticide uses, even in the enclosed spaces of aircraft?
“When used according to the instructions” is a catch-all phrase which overlooks the contradictory information in those instructions.

But the HSE and its subsidiaries approve dangerous chemicals as “safe” to use and suppress reports of any actual harm caused
- all the while playing the Hazard v Risk game to give the impression that the end users are to blame for any harm done.
Hazard v Risk was used by the British Government and others to weaken the EU REACH regulations controlling dangerous chemicals.

Confused? That is the obvious intention built into the promoted propaganda of Hazard and Risk.…..

Dated 26/08/2016.   

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