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• Are all the exposure pathways used for the derivation of GAC appropriate at the site For example,
the presence of hard-standing may prevent the generation of dusts and/or direct contact with
soil;
• Are the generic parameter values used for the derivation of GAC reasonable for the site For
example, the residential GAC may not be protective for a house with a large garden used almost
exclusively for the cultivation of homegrown fruit and vegetables.
Like the SGV, the EIC/AGS/CL:AIRE GAC represent minimal or tolerable risk. As such, they present useful screening
criteria for the assessment of risks. Care should be taken if adopting these values for other purposes, such as
acceptance criteria for imported topsoil. Although the GAC may prove convenient screening criteria for this purpose
it should always be recognised that they are based on generic assumptions and parameter values and that the
development of site-specific assessment criteria protective of human health may be more appropriate at some
sites.
2.2.3
Consultation
Definition and Use
One key difference between the EIC/AGS/CL:AIRE GAC and the SGV relates to the degree of consultation
undertaken in their derivation / publication. The SGV (and associated HCV) have been derived by the Environment
Agency of England and Wales in consultation with other Government departments and agencies, including the
Food Standards Agency and the Health Protection Agency. The EIC/AGS/CL:AIRE GAC have not been subject to
this level of consultation and unlike the SGV are not endorsed by DEFRA, the HPA or the Environment Agency of
England and Wales.
Nevertheless, the EIC/AGS/CL:AIRE GAC do carry a level of authority for the following reasons:
• They have been derived using the CLEA model (v 1.06) in general accordance with the CLEA
framework of guidance documents;
• They have been researched and agreed on by a group of experienced human health risk assessors
from 26 EIC and AGS member companies;
• They have been subject to a high degree of internal review (see Sections 3.1.2 and 3.1.3); and
• Various external authoritative bodies were invited to read and comment on a pre-publication
version of the EIC/AGS/CL:AIRE GAC report (see Section 3.1.3). Comments were received from the
Environment Agency of England and Wales, the Royal Environmental Health Institute of Scotland
(REHIS), Environmental Protection UK, the Northern Ireland Environment Agency, the Chartered
Institute of Environmental Health (CIEH) and the Scottish Environment Protection Agency (SEPA).
These comments mostly related to the overall approach and wording of the main text and included
recommendations for improving the clarity of the report. These comments have all been considered
and with few exceptions addressed in the final version of the report. All of the comments significant
to the derivation or application of the GAC have been addressed. Comments not addressed related
to style and/or presentation of report. It is noteworthy that the Environment Agency of England
and Wales commented that the approach described for derivation of the EIC/AGS/CL:AIRE GAC
appeared to be broadly consistent with the CLEA guidance with some exceptions (which are
highlighted in this report).
It should be noted that none of the external authoritative bodies have carried out a detailed technical review of
any of the recommended physico-chemico and toxicological properties or GAC values presented in this report.
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