Miscellaneous REQ 1- white phosphorus

White phosphorus toxicity in the environment


The Advisory Committee on Hazardous Substances (ACHS) provided “expert advice on the science behind hazardous chemicals.” It was made up of eleven scientists, drawn from both private-sector industries and public-sector non-governmental organisations and a lay member.

It was established in 1991 under Section 140 of the Environmental Protection Act (EPA 90). Section 140(5) of the EPA 90 requires that the ACHS be consulted on any proposal to introduce regulations under Section 140 to control injurious substances or articles. Section 142(3) of the EPA 90 requires that the ACHS be consulted on any proposal to introduce an Order under that Section requiring information about potentially hazardous substances.

 In April 2001, the ACHS adopted the additional role of advising the UK Chemicals Stakeholder Forum. In 2005 the remit of the ACHS was widened to include nanomaterials

Terms of Reference

The ACHS was politically independent, and provided “objective, impartial advice from a purely scientific perspective.”

The Hazardous Substances Advisory Committee (HSAC) is the successor body to the Advisory Committee on Hazardous Substances (ACHS) which was abolished on 22 July 2012, with the coming into force of the Advisory Committee on Hazardous Substances (Abolition) Order 2012 (Statutory Instrument No 2012/1923).


We asked the following questions of the  ACHS and these were  responded to via DEFRA.

1. Could you please provide me with a breakdown of the committee members and a brief biography of which companies they may have worked for.

“A1. Information about the members of the ACHS is published on the ACHS website at http://www.defra.gov.uk/environment/quality/chemicals/achs/members.htm. For information about companies which the members have worked for, please see the sections relating to ‘declared interests’ in the Annual Reports, which are also available on the ACHS website.

As the information about members of the ACHS that you have requested is publicly available from the website mentioned above, we are exempt from providing a copy under section 21 of the FOIA.”

2. I would like to ask if the committee has looked at the impact of white phosphorus entering the environment and its toxicity to both animals and human exposure both acute and chronic?
Primarily the source of such exposure would be military use and chemical industry emmisions and waste tipping.

“A2. The ACHS secretary has checked the agendas of all ACHS meetings going back to 2001 and did not find any mention of papers on white phosphorus. Therefore, it is reasonable to conclude that the ACHS has not looked at the impact of white phosphorus entering the environment and its toxicity to animals or humans.”

Can the ACHS provide an opinion on the toxicity of exposure of white phosphorus in lagoon sediments from historic waste tipping operations or offer advice on how to deal with such a problem?

“A3. We would expect a request to the ACHS for such an opinion to come from the Environment Agency, if they felt it were necessary to raise the matter in order to meet their responsibilities in this area. The Environment Agency are aware of the Terms of Reference of the ACHS and will seek its advice if an issue at the Rattlechain Lagoon, which you mentioned in your request, were judged to fall within its remit.”



The membership and purpose of this committee give cause for concern. How can a committee advise government objectively when at least one of its members had links to the Chemical Industries Association- a powerful lobby organistaion for the chemical industry, as well as the European conglomeration CEFIC based in Brussels? Others have backgrounds to universities involved in ongoing research as well as big business chemical companies funded by Government. Ministers cannot possibly have “independent, expert and impartial advice, in this area” from such a committee membership.

Does Government need advice on regulation from those with a vested interest, or should advisory committees be formed of those with health only backgrounds which would be more in the public interest and not that serving the health of business?

We believe that these advisory committees should be free from lobbyist groups entirely- otherwise they have NO impartiality and NO integrity.  Codes of conduct offer little safeguards when “wrong doing” has to be proven but has little chance of being found. A tweak of wording here, a subtle  ammendment there- not “wrong doing” but not “independent” either. It is also concerning that outside consultancies can be set up by members of advisory committees offering “advice” of how to circumnavigate the legislation that its chief officers may have helped to “advise” on and have helped to massage.

The new line up of the HSAC can be found HERE