Yes please, convener. CHEMTrust is a charity that focuses exclusively on chemicals policy, particularly at EU level but also in the UK, and tries to ensure that humans and wildlife are well protected. The key issue is that the database that will be created by the UK in the event of no deal and if we are outside REACH will be empty—it will just be sitting there without any information in it—whereas the REACH database, which is the best in the world, contains huge amounts of information. It took quite a few years to develop the database software, and then it took more than 10 years to get the data into it.
There is a big difference between an empty database and a full one, and the worry is that the UK will put in place a system that appears to be a copy of the EU’s system but without any of the information. There would be a very gradual phase-in of data and there is a lot of concern about how much data industry would have to supply and how much it would cost. You would still end up with a system that did not contain the same amount of information—it would be almost a shadow; a ghost or a virtual system. It might look like the EU system but, in reality, it would have something very different going on inside it.
Chemicals policy is very difficult. There are tens of thousands of chemicals in millions of different products; keeping a hold on all of that is very difficult and is why it has taken so long for any jurisdiction to make good progress on the matter. The EU might be the strongest in this area, but it is not in any way perfect. That is a challenge. The complex system that the EU has put in place is constantly developing, with new analyses being undertaken, new data coming in and new decisions coming out, but the UK has made no commitment to follow those decisions. The EU might look at this or that chemical and decide to restrict its use in, say, till receipts, but the UK has made no commitment to copy such a decision. The issue, therefore, is not just the lack of data in the UK database, but the fact that the UK has not said that it will copy the EU’s decisions.
Another point that is worth mentioning is that the EU system is quite open, in that there are many different meetings and management boards where there are people around the table from not only the member states, but industry, environmental and consumer groups, and unions. They can all input into the discussion and say, “Have you considered this research or this use?” Generally, all the stakeholders are pretty happy with that. In the European Union (Withdrawal) Act 2018, the UK has said that it will transfer everything from EU law into UK law and remove the bits that are not operable. It has said that all those committees are not operable, because we do not have member states in the UK, so everything will be put inside the HSE and the stakeholder functions will be got rid of. We are moving from quite an open system to a very closed system. CHEMTrust said to DEFRA that although there are not member states in the UK, there are devolved Administrations, and we suggested that committee structures could be created that would allow representation of devolved Administrations and stakeholders. DEFRA did not take that up, though, so all the functions are basically being subsumed into the HSE, with some role for the secretary of state in London. A very closed system is being created that pretends to be a copy of the EU system but is not.