Risk Assessment Acknowledging Variability in Both Exposure and Effect

Risk assessment provides a scientific basis for evaluating potentially toxic chemicals. Central in the concept of risk is its dependence on both exposure and toxicity. Chemicals will only express their toxicity when these exceed a concentration at which a defined target becomes affected. While this is a trivial remark among environmental risk assessors, the new chemicals policy of the EU tends to divert into a different direction. The communication of the European Commission on its new Chemicals Policy places an emphasis on hazard-based chemical management. We urge the Commission to reconsider this view. We believe that for the majority of chemicals evaluated under REACH, a scientifically sound risk assessment evaluating both exposure and effect should remain the core of the EU strategy “towards a toxic-free environment”.