If the aim is to “achieve a better understanding of the environmental threats to human health, to identify the disease burden caused by environmental factors in the EU and to plan policy responses to the challenges that emerge” then there must first be a change in attitude by those who assess the effects on human health. Currently there are too many victims of environmental toxins who are officially labelled as suffering from symptoms induced by their state of mind as attempts to hide the true effects continue.

I seriously question the claim that “many environment and health related problems have been solved.”
In reality there has been a determined effort to “paper over the cracks” so that all appears sound when in fact human health is deteriorating as fast as the environment around us.
The lowering of sperm counts, increases in cancers and neurological diseases, rise in asthma and eczema cases, and rises in birth defects are all indicators of serious adverse effects at cellular level.
How the so-called scientists who have allowed this to continue have escaped censure is a mystery.
The EU Commission is correct when it says that much work still remains to be done but I suspect that those involved in the consultation here in the UK will continue to undermine their work.

Many people have warned for decades that the current policy underestimates health impacts but because they have not been part of the hallowed circle of “experts” their views have been ignored.
The world and its people depend on a stable environment and even slight imbalances in any vital system can have major debilitating effects, which can be catastrophic in the long term.
I believe that we are seeing that process in action and urgent action is needed if we are to avoid disaster.

Unfortunately vested interests have already harmed the five key elements: Science, Children, Awareness, Legal and Evaluation.
Science has been corrupted by commercial pressure.
Children have been harmed by toxins and will be for many years - even before they are born.
Those aware of the interdependence between health and our environment have been ridiculed for decades.
The Legal system has been proven to be corrupt and easy prey for those who profit by hiding the truth.
Evaluation of risks and of damage to humans has been corrupted because adverse data has been hidden.

We can only hope that the Health Strategy will be based on true Science, but if so it must draw together knowledge from a wider range of interested parties and not just the stakeholders who will benefit most if the adverse effects are hidden.

There should be a focus on children, because children are our future. It is true that children are particularly vulnerable to environmental hazards as their physiology, metabolism, diet, and behaviour are different to adults but it is also true that calls were made by scientists and others to protect children’s health from the highly toxic organophosphates as long ago as 1997 but little has been done - so far.
Talk is cheap and promises are empty - so far.
When Rachel Carson attempted to “raise Awareness about the interconnection between environment and health” in 1960 she was attacked and ridiculed - much as her supporters are today. The regulators pay lip-service to science but hide the science which indicates a dire need for action, as they have always done.

Some of us attempted to use the law to demonstrate the failure of the regulatory, evaluation, and enforcement policies, but the authorities stooped to unlawful activities in order to hide the major failings and the corrupt practices which are now embedded into the system. We can only hope that the Legal instruments provided by the Amsterdam Treaty and other EU legislation will expose the failures.

Evaluation of basic chemical safety has been shown to be seriously inadequate and to overlook important adverse effects so we can only hope that evaluation methods used “to verify the efficacy and cost-effectiveness of the actions in terms of the reduction of the environment-related health problems” will be more reliable. However since, no doubt, the same old hands will be involved in this work at national level it is likely that the same failings will be seen and the adverse effects will again be ignored.

Over 40 years ago Rachel Carson carefully listed the hazards to the environment and the reasons why those hazards were being ignored and yet those problems remain and are referred to as “new emerging problems” which might need to be addressed.
There is no “knowledge gap on the link between environment and health” since the knowledge has been documented for years but it has simply been ignored.
If as stated in “4.1. EU chemicals and environment policies. Health has always been a major driver for environmental policy development” why are things getting worse, as predicted all those years ago?
Even now the delaying tactics continue and we have the “first cycle” lasting from 2004 until 2010 during which time it is hoped to establish “a good understanding of the link between environmental factors and ill health”.
It is bit late in the day for that - but better late than never.
I recall first hearing about asthma when a school friend who lived on a farm in the early 1950s was said to suffer with the condition. At the time it was said that his symptoms were mentally induced, much as Multiple Sclerosis sufferers were treated for decades. Now we are told that children on farms are less likely to get asthma and yet asthma is a well know symptom following poisoning by agricultural pesticides.
Many agricultural workers poisoned by OPs end up suffering from multiple chemical sensitivity, referred to as “allergies” and that too is said to be caused by psychological factors despite official recognition as to the toxic causes.
Neurodevelopmental disorders are also known to be caused by pesticides and solvents now ubiquitous in the environment.
Cancers are also known to be caused by pesticides, solvents and radiation. This is not new information.
Endocrine disrupting effects have also been known for decades. Only a slight imbalance is enough to trigger serious hormonal disturbances in the long term.

So there are major health hazards, which have been known and documented since the 1950s and beyond, but the best that science can do in the 21st Century is to take another decade to find out about them?
What on earth has gone wrong with science in the last few decades?
If we have not been able to deal effectively with these known dangers in all that time what hope is there for any action being taken on any new health threats caused by environmental factors?

It is to be hoped that the European Integrated Environment & Health Monitoring and Response System will be a far more efficient system than the national system we currently have in the UK which fails dismally when it comes to environmental and health monitoring and hides the effects on human health with spurious claims about mentally-induced illness in order to conceal the poisoning of our people.

“Research” is often used as a means to delay official recognition of cause and effect.
Given the way the UK Government and its administrations have helped to hide the truth about the dangers of radiation, pesticides, GM crops, Tetra Masts, mobile phones and the MMR vaccine, to name but a few, I suggest that it is dangerous for Europe to allow these individuals to take an active role in the consultative process.
Perhaps the UK should be used as an example of how not to do the work.

Even when the Environment & Health Strategy is completed it will not be backed by legislation.
So much for protecting our children, the environment, and the future health of the people of Europe.
Is that really the priority as claimed?

In answer to the specific questions:

2. Draft Initial Regulatory Impact Assessment (RIA) As well as any general comments and views that you may have on the RIA, I would be grateful if you could consider the following questions:
I have not had the pleasure of seeing the draft impact assessment for this consultation but from papers released in other consultations it would seem that current risk assessments leave much to be desired, if they are ever done correctly at all. Even when the regulators are told that data is suspect they ignore the information and with suspect data the risk assessments are worse than useless. They are dangerous.
If the risk assessments are unreliable any impact assessment on the proposed changes will also be useless since the true situation as far as pollutants and their effects is unknown.

Risk Assessment - Paragraph 10
1. Do you think that the Commission is focussing on the most significant "health and environment" problems in the UK?
No. The most significant problem is the failure to enforce environmental and health protection regulations. Because these regulations are not enforced we effectively have no protection.
In most cases these laws can be freely breached and prosecutions are rare. Even when individuals attempt to correct these failures through the courts they are blocked by the system.
Risk assessments demand the use of accurate safety and adverse effect data and yet we still have chemicals on the market for which the safety data is known to be flawed. Since I have submitted detailed information on this matter to various government departments and consultations over the course of a decade, and still no action has been taken, I see no point in resubmitting the many pages of information again here.

2. Do you consider that the problems can be addressed in the ways proposed by the Commission? No because it is just yet another “talking shop” with no teeth and no back-up legislation.

3. Do you have evidence or examples of the effects of "combined exposure and cumulative effects".
Yes. In my own case and that of other officially recorded cases serious ill-health resulted from an exposure to a combination of pesticides and the cumulative effects of occupational exposure.

Options - Paragraph 11
Do you think that non-regulatory approaches (e.g. voluntary agreements) would be a more cost-effective way than regulations to address the problems identified? No. Unless there is legally enforceable regulation it is possible for polluters to continue polluting without fear of prosecution. History shows that no lasting improvements are ever made unless the regulations are backed up by effective legal sanctions.

Costs - Paragraph 17
What types of costs are likely to be incurred as a result of monitoring and reducing exposure to substances in the environment which impact on health? I suggest that the costs involved resulting from pollution already represent a major drain on the Community budget in respect to residue monitoring, adverse health effects and their treatment, loss of skilled workers due to illness, cancer etc, and cleaning up contaminated land and water.
It seems obvious that reducing the amount of pollution will inevitably reduce the costs to the community and there will, in time, be no additional costs at all.
If on the other hand the stakeholders refuse to limit the pollution of our planet then they must be prepared to pay the full cost of monitoring and reducing the exposure to, and the release of, damaging substances.
It is not for the taxpayers to subsidise those who would poison them for profit.
How many decision makers value their own lives and health so lightly?

Small Business - Paragraph 20
Do you consider that there will be a disproportionate impact on small firms from the monitoring of, and reduction in, substances in the environment that impact on health?
The major players will no doubt ensure that their smaller competitors will take the strain, and the pain, for it will be to their advantage and they hold the most power and influence. In fact before the advent of the all-powerful multinationals the world survived well and prospered in its reliance on smaller companies. There were other advantages too in that smaller units produced fewer concentrations of pollutants and they did not have the global effects seen today.
“Progress” has obviously come with a very high price.

Enforcement, Sanctions Monitoring and Review - Paragraph 21
Do you think that a formal, regular UK review of the actions taken, and their impact, will be required? If so, at what intervals should the review take place (eg every 2 years, every 5 years)?
Obviously given current and past failures regular reviews are necessary.
Had the regulators performed their task of protecting the people of the UK and Europe correctly then there would be no need for any review. There would also be no need for this strategy.
Sadly the evidence is growing and demonstrates that neither the people nor the environment have been given the protection they deserve and which is their right under the EU Treaties.

Please do not allow vested interests to hide the terrible toll on human life around the world, and in the EU, which the deadly toxins released into the environment and our food supply are causing.
This opportunity to bring a swift end to the suffering and torment must not be missed simply because a relatively small, but enormously powerful, group of companies fear losing profit.

The rules demand that the polluter pays.         Let it be so.

I would very much like to be kept informed in the development of this Strategy.

Yours sincerely,

Dated 14/01/2004    Updated 20/02/2016

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