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Foreign Affairs, Defence and Trade References Committee
Contamination caused by firefighting foams at RAAF Base Williamtown and other sites

CONNOR, Mr Andrew Scott, Executive Director, Industry, Development and South Queensland Compliance, Department of Environment and Heritage Protection, Queensland

JEFFREYS, Mr John Adrian, Executive Director, Environment Policy, Department of Premier and Cabinet, Queensland

MILLER, Mr Elton, Executive Director, Department of Agriculture and Fisheries, Queensland

REEVES, Mr Jim, Director-General, Department of Environment and Heritage Protection, Queensland

SANDERS, Mr Paul, Regional Manager, Department of Natural Resources and Mines, Queensland

YOUNG, Dr Jeannette Rosita, Chief Health Officer and Deputy Director-General, Prevention Division, Department of Health, Queensland


CHAIR: We welcome officers of agencies of the Queensland government. I remind witnesses that the Senate has resolved and that an officer of a department of the Commonwealth or of a state shall not be asked to give opinions on matters of policy and should be given a reasonable opportunity to refer questions asked of the officer to superior officers or to a minister. This resolution prohibits only questions asking for opinions on matters of policy and does not preclude asking questions for explanations of policies or factual questions about when and how policies were adopted. Would someone like to make a brief opening statement before we go to questions?

Mr Reeves : I would like to thank the committee for the invitation extended to the Queensland government to give evidence about the Oakey contamination issue here in Oakey. The Queensland government is working to assist the Department of Defence in fulfilling its important obligations to the Oakey community. As advised in the written submission, the Queensland government has formed an interdepartmental committee chaired by the Department of Premier and Cabinet and comprising of representatives from Queensland Health, the Department of Agriculture and Fisheries, the Department of Environment and Heritage Protection and the Department of Natural Resources and Mines to facilitate this work.

The Queensland government was first informed of the potential contamination at the Oakey base by a phone call to the Department of Environment and Heritage Protection in December 2012. The advice from Defence was that they had identified some contaminated land and potentially contaminated groundwater at the Oakey base due to residues of firefighting foams. A meeting with neighbouring landholders had been held to inform them of the issue.

In December 2013 Defence advised that the contaminants from firefighting foam, used in training exercises between 1970 and 2005, had infiltrated groundwater below the base and it was likely that they had migrated outside the base boundaries. A meeting with potentially affected residents was arranged by Defence on 10 December 2013 and Queensland's Department of Environment and Heritage Protection and Department of Natural Resources and Mines attended. At the meeting the attendees were informed that further investigation was planned, however, human health risk assessments undertaken by a consultant on behalf Defence had concluded that adverse effects from exposure to PFOS and PFOA concentrations in groundwater for the off-site population and exposure pathways of concern were unlikely.

For constitutional reasons, the state government does not have a direct regulatory role over activities on Defence bases. Nonetheless, Queensland government officers proceeded to test the rigor of investigations undertaken and conclusions formed. Defence has continued to engage the Queensland government on its planned investigations and interpretation of investigation results.

In July 2014 Defence further advised the Queensland government that it had provided results of targeted water sampling to participating landowners. As a precaution, it had recommended that landholders within the investigation area do not drink any water sourced from underground water bores on their properties. This communication was followed by a community briefing session and agency briefings where Defence updated Queensland government departments and the Toowoomba Regional Council on test results. It was around this time that the Oakey ground water contamination became widely reported in the media.

Since being informed of the potential for off-site contamination in December 2013, the Queensland government representatives have attended all community meetings run by the Department of Defence, and continue to monitor advice given by the Department of Defence to the public. In addition, Queensland Health has prepared advice for community members who contact the department through the 13 HEALTH hotline, and it has provided advice to local general practitioners, should they be approached by members of the community. Defence has since provided the Queensland government with a number of reports indicating that the area of contamination is larger than previously thought. The Queensland government has encouraged Defence to move quickly to delineate the contamination, characterise the source, undertake biota testing, and ascertain risks to all potential exposure pathways.

Recently, Defence provided the Queensland government with its proposed investigation and monitoring plans for the next stage of investigation for review and comment. These plans include monitoring of crops consumed by humans and animals, stock, pasture, soil, stream biota, stream sediments, surface water and groundwater. To support this work, the Queensland government has provided data and advice to assist with the development of groundwater hydrogeological models, and hopes to continue a close involvement throughout the development of the models. The people of Oakey have a right to be kept informed throughout the Commonwealth-led investigation, and we expect Defence, as the responsible agency, to continue communicating closely with landholders in and around Oakey about appropriate use of contaminated water.

In the context of the broader matters of interest to the committee, the Queensland government has taken key steps to address concerns about the use of PFOS and PFOA. In 2003, Queensland Fire and Emergency Services ceased purchasing foams containing PFOS and PFOA. It has purchased only fluoride-free foam since that date, and taken action to remove older foams from service. PFOS and PFOA foams are also known to have been used at major ports, airports and industrial sites. Further work has been undertaken to determine the extent of this use. However, evidence to date indicates that use of the foams for training at state-regulated facilities has been limited compared to activities at Defence facilities. Consequently, the likelihood of infiltration outside these sites is lower.

While the Queensland government is undertaking work to develop its own guidelines, it considers that a nationally consistent approach should be developed for standards and screening guidelines, as well as assessment, management and remediation protocols for sites that are identified as being contaminated with PFOS and PFOA. This matter should not be left to individual states or territories.

The Queensland government has actively supported a consistent approach, including through the Queensland Department of Environment and Heritage Protection, being represented on the technical working group developing national guidelines for PFOS and PFOA. That is being managed by the Cooperative Research Centre for Contamination Assessment and Remediation of the Environment. Queensland Health has participated in discussion and workshops with the Australian Health Protection Principal Committee and its subcommittee to establish national guidelines for perfluorinated compounds.

In summary, the Queensland government is well engaged in both Oakey contamination investigation, work being undertaken by Defence, and the broader issues about management of existing stocks of PFOS/PFOA foams, and development of national standards. The Queensland government will continue to assist Defence to ensure the department meets its obligations. To date, this has been an appropriate collaborative approach between governments. However, I wish to make it clear that the onus is on Defence to keep the people of Queensland informed as it continues to investigate this matter.

I thank you for the opportunity to present to the committee, and would welcome any questions that members may have.

CHAIR: Thank you, Mr Reeves. You mentioned at the outset that you had no jurisdiction over Defence property. Is that what you said?

Mr Reeves : Yes.

CHAIR: Where does your responsibility start, then—at the boundary?

Mr Reeves : At the boundary.

CHAIR: And that is the contaminated area, in some respects.

Mr Reeves : Well, the contaminated area was the base. We have had some legal advice to have the base declared as a contaminated area. We are advised by our lawyers that registering on our inventory of contaminated sites is legitimate and will enable us to direct certain activities to occur on the base. But it is not a straightforward matter when you get the constitutional lawyers involved.

CHAIR: I think the residents of Oakey are well aware of that, if this has been going on since December 2012, and they, in their minds, are no further advanced to resolving some of their concerns. My question is: if the principle is 'polluter pays', I accept that Defence has authority over its base, but the pollution is occurring on land where you have authority. What have you been doing to make sure that the polluter makes good either the environmental degradation or the loss of property value?

Mr Reeves : There are two facets to that. One is that we are working with Defence—if you like, we are the regulator and they are the entity that we are trying to regulate—to get first-class intelligence on the extent of the pathways and the extent of pollution in groundwater. It is not a straightforward situation. There is not a clearly defined boundary around properties, and we are very reluctant to ask freehold landowners to register their property as being contaminated, because that may not be the case and it may not be the case next door but it would open a Pandora's box. Our view is that we have to work with Defence and we have to make sure that our approach is evidence based. There are people out there who might be adjacent to where there is some contamination, but unless we are 100 per cent sure we do not want to go down that path.

CHAIR: But you have taken the step of advising people not to use bore water?

Mr Reeves : Yes.

CHAIR: So you have made a decision?

Mr Reeves : Defence made that announcement, not us.

CHAIR: But those bores are not all on Defence property.

Mr Reeves : No.

CHAIR: So they would fall under your jurisdiction, wouldn't they?

Mr Reeves : They would, but Defence made the announcement. We have not got a robust enough process, we think, to go declaring the bores. We are asking Defence and advising Defence and assisting Defence to come up with a very rigorous investigation process.

CHAIR: Did you hear the evidence from the Toowoomba council this morning?

Mr Reeves : No.

CHAIR: Paraphrasing the witness—and you could probably check the Hansard—the issue of water into the future is a concern for them, and that would be potentially some cost if the population grows and they need to restart the reverse osmosis plan or increase the pipeline capacity. Surely, that is something that is within your jurisdiction?

Mr Reeves : I might ask my colleague from Natural Resources.

Mr Sanders : We have been staying pretty close to this process, and there are opportunities under the Water Act to restrict access to groundwater. I will answer your original question: the reason we did not is that, essentially, what you are aiming to do there is advise the community of what the issues are and whether they should be accessing that water. That was being achieved through the work that Defence was doing. There are limits on the length of time that you can put those restrictions on.

Regarding alternative supplies of water, we have been working with local industry and turning our mind to what would need to happen for alternative supplies. It is not easy because the availability of water in those areas is restricted; it is essentially all being used. It is not an easy answer, but there are some solutions and we certainly will be working with Toowoomba Regional Council, local industry and Defence to make sure that we explore all options that are available.

CHAIR: We did take some evidence from a landowner who said they bought a property with a bore—I think it was doing 950 gallons per hour; it was quite a commercial proposition—which is no longer useful. Would that not immediately present itself as a case for compensation, if somebody had contaminated that and we knew where it had come from?

Mr Sanders : It depends on the term 'being useful'. We are working and listening to what Defence is telling us about the appropriate use of contaminated water. At this stage the advice that they have given us is that you should not drink the water, but there is no evidence to say that other uses should be limited. It really does come down to the appropriate use of contaminated water.

CHAIR: I do not want to be rude, but you are the Queensland entities that are responsible for Queensland taxpayers and electors. Any question I seem to ask goes back to, 'We asked Defence and they said this.' What do you think about the situation? If this was a large commercial enterprise that was operating on a large piece of land that contaminated the surrounding area, would your attitude still be the same, or would you be jumping all over it?

Mr Reeves : We would be tending to jump all over them, I would imagine. It is very hard for us to have a well-measured approach to this. I understand the emotional toll that it is having on the residents of Oakey and surrounding districts, but again I emphasise that it is not a one-hat-fits-all situation. We cannot sterilise a whole district if we find an area that we think is contaminated. For example, with the Air Force base it has taken us some time to be able to work through the approach to get that put on the contaminated land register. We have got to be very close, because I do not want to be sitting here at some other juncture fronting a committee that says: 'You've been precipitant. You've sterilised a whole area, and half of them have now been found not to have water.' It is the same with food; there are no standards, in some cases, around PFOS or PFOA residuals in food. We cannot make up a standard. It is not our job.

CHAIR: Do we know how many people are living around or above the plume that has been identified and measured?

Mr Reeves : I could not tell you offhand; I am sorry.

CHAIR: So you have no idea whether it is 50 or 100 properties?

Mr Connor : There is still work underway to clarify the extent of the plume, but there are potentially hundreds of properties. It is very hard to put a single number on it. I would also like to clarify a comment around the Environmental Management and the Contaminated Land Registers on how state law can be applied to Commonwealth law. It is a very complex area. We have sought legal advice, we have formed a position that we can list the base on the environmental management register, but we are far less confident in our ability to actually compel Defence to do things in terms of heads of power. It has been a case of us providing scope of works to Defence, in terms of what needs to be done to identify exposure pathways and areas at risk. That information is critical for Defence to prepare management and remediation strategies at Oakey.

CHAIR: I accept that this is very complicated technically, legally and legislatively, but the guts of it is that people are suffering. It has been going on for a while and I do not get any sense that you are any closer to proposing some solutions. Are you close to proposing solutions? Can you fix this, or isn't it your job to do that?

Mr Reeves : I could stand back and say, 'It's not our job to do it.' We could have stood back to stage left. We have not. Since the day that we were notified we have been actively engaged with the Defence, helping them—as my colleague said—to develop programs and scopes of work that needed to be done. We need to look at the biota and all of those sorts of things, and we have been working assiduously at that. I understand that that has not translated into what, in a normal situation, might be a prosecution or some other sort of remedy. But it is complex and, I should say, it is not just Defence. For example, we have some recalcitrant miners in and around Queensland that we are having to deal with. It is a very complex area to work in, but you can rest assured we are very, very committed to working with Defence to bring about remedies as quickly as possible.

Senator BACK: Thank you, Mr Reeves. In your submission you have said the department has developed a draft policy on the management of firefighting foams, that that policy has been the subject of public consultation and that the third draft will be released this month. Can you tell us what the public consultation processes were and who you consulted with?

Mr Connor : I cannot list all of them. I can tell you there were over 100 organisations and associations who were sent drafts of the policy. The reason why we are saying early 2016 for the release of the third draft is that there has been a lot of feedback. So working through all of the comments received and putting that into a tabulated format so we can comment back to people who made submissions is taking some time. It has been a broad consultation process. I can provide the committee with a list if you would like to look through that.

Senator BACK: I would be interested if you could to that. Have you had any public meetings as part of the consultation process?

Mr Connor : There have been a series of meetings around the country.

Senator BACK: In the context of the draft policy—sorry, I do not know the Queensland situation well enough—are there any joint Defence and civilian airports in Queensland? Townsville?

Mr Connor : Yes.

Senator BACK: Is it Townsville?

Mr Connor : Townsville, yes. I am aware of that one.

Senator BACK: Are there others?

Mr Connor : I do not have that information to hand.

Senator BACK: Amberley is purely military.

Mr Connor : Defence, correct.

Senator BACK: I asked that question in the context of whether the policy relating to the management of firefighting foams will have an impact at all of your civilian airports and the Defence airports?

Mr Connor : Again, you do get into issues around jurisdiction, and there are federal regulations that apply to a number of airport sites—definitely in the case of the Defence sites but other airports as well. We have put the policy together and we have consulted across those groups so that they are aware of it. The underlying intention behind that policy is to phase out the use of these persistent chemicals. The signal is already there. We are already seeing shifts within industry, where they are removing the old stocks and replacing them with fluorine-free foams, which is ultimately the intent.

Senator BACK: Is there a firefighting training facility for the Queensland fire service?

Mr Connor : There is a shared facility. It is shared with a refinery in Brisbane.

Senator BACK: That would also be the subject of this policy, once it has been formalised?

Mr Connor : Correct.

Senator BACK: Excellent.

Mr Jeffreys : The preliminary advice that we can provide is that it does not appear that the extent of the use of these chemicals is anything like it has been at Oakey. So if there is contamination on that site, it will be considerably less.

Senator BACK: That is good news. Mr Miller, community members this morning indicated to us that they are unsure whether they are facing a liability for any stock or produce sold from properties that have contaminated bores. Can you give those livestock owners, horticulturalists and others satisfaction that they are not facing liability for possibly contaminated meat, milk, eggs or food—

Mr Miller : Is that in relation to the national vendor declarations as well?

Senator BACK: They did not specify the national vendor declarations, but I am sure that would be captured within it.

Mr Miller : Our view is that from a national vendor declaration perspective, because they are part of a national industry-operated quality assurance program where livestock producers are required to assess risks according to their individual circumstances, it would be inappropriate for DAF to issue blanket advice regarding the completion of national vendor declarations. One of the questions in those NVDs—question 5—is, 'In the past six months, have any of these animals been on a property listed on the Extended Residue Program database, or placed under any restrictions because of chemical residues?' The department's advice would be that a property owner should normally have no reason to believe that they should answer yes to that question 5 on the NVD unless the property or livestock on the property have a residue status assigned or a formal quarantine. In this case that is not the situation.

Senator BACK: So they can rest comfortably in that.

Mr Miller : But it is up to the individual to make their own risk assessment regarding that.

Senator BACK: From earlier evidence, a certain level of these PFCs in the blood of cattle, sheep, pigs, chooks or dairy cows might in fact not be information that is usable to the person in helping them to make that risk assessment.

Mr Miller : Not at this stage, but that is why the Queensland government is supporting and encouraging Defence to undertake the biota sampling. That will be sampling a range of plants and animals. We wait to see the results of that sampling. That can help inform the way forward.

CHAIR: Why is it Defence that has to do the testing? Why don't you do the testing?

Mr Miller : We are currently supporting Defence in doing the testing. We do not want to duplicate what they are doing. It is our understanding that they will be finalising that biota sampling plan shortly and will be undertaking that sampling.

CHAIR: That is all very nice, but why don't you just prosecute them, do the testing and send the bill? If it was a private company that is what you would do.

Mr Connor : It is very different when you are a state government trying to deal with a federal government entity. Questions that you have asked about damages previously are really a question for Defence. We work under a polluter pays principle.

CHAIR: My word you do.

Mr Connor : Defence is the polluter so Defence should be paying for the testing. They have not argued against that.

Mr Reeves : I must say that we are bound to follow due process and the law. According to the legal advice that we had, we took the position that we can lawfully list a Commonwealth place in Queensland on the Environmental Management Register, but the legal advice went on to say that they were less certain of our ability to direct Defence to undertake specific actions as a result. It is not a straightforward matter.

CHAIR: We obviously accept that, because we have heard evidence from Williamstown where Defence is over here and the New South Wales departments are over there. In the middle, exactly the same as here in Oakey, are a whole group of Australian taxpayers who are not getting a great deal of satisfaction out of the length of time or the complexity of the processes over what seems to be a quite simple issue. Someone has caused pollution; it has destroyed their property values and put a shadow over their health. There does not appear to be any success at the relevant Commonwealth and state entities getting together to fix that. Hence we have an inquiry. Do you have a comment on that?

Mr Reeves : I think it is a matter of policy.

Senator BACK: With regard to a program of blood testing of residents in affected areas on an annual basis, the Department of Health in New South Wales has a view on that proposal. Does the Queensland Department of Health have a view?

Dr Young : We do have a view on that. We believe that routine testing for PFC levels is not useful because we do not know what the association with that result actually means. We do know that it takes a long time for the levels to decrease—various studies have shown between two and nine years. So doing it yearly would not really be of great use.

What we would like to see, and we have been working with Defence, is to look at pooled samples. It would be very useful for us to know what is going on in the community overall, so we would hopefully see a gradual reduction in the levels once the source of the contamination has been removed.

Senator BACK: Could you just describe for the committee what a pooled sample is? Is it a sample of a population of people; is it one pool of young children; is it another pool of adolescents? When you say a 'pooled sample', are you suggesting literally just one piece of data.

Dr Young : No, I am suggesting that blood that has been taken for other purposes be tested, so that we find out what is going on—not necessarily test an individual person, because I think that can be quite anxiety-provoking for that person to know those results when there is nothing we can do about them—but it would be good to know what is going on across the community so we can track that forward.

Senator BACK: Would the Queensland health department have a blood bank going back 20 or 30 years that it could actually draw upon to get some understanding of what the PFOA or PFOS levels might have been back in the 1970s or 1980s? Does that exist, and have you done it?

Dr Young : We could do that, but that work has already been done, so we do not need to do that.

Senator BACK: In Queensland?

Dr Young : We do know what pooled results are, and we have a good understanding of what those average levels have been.

Senator BACK: Have you described a curve over time, then, of increased use of PFOA or PFOS with an increased pooled blood levels, and then dropping off after 2000 or whenever, when these aqueous firefighting foams ceased to be used?

Dr Young : It has not only been in firefighting foams. We know that it is ubiquitous. The point of removing it across the world, as has been recommended, is because it is so ubiquitous and it takes so long to degrade that it is persistent, so you do not want to accumulate it increasingly. The important thing is to remove it. But all of us have got levels of a certain degree.

Senator BACK: I think the highest levels that I have read recorded were actually of a domestic cleaner, a lady in the United States, who had no association with airports but was clearly associated with the chemicals used to protect furniture et cetera.

Dr Young : Exactly.

CHAIR: In relation to the data that you have, do you want to put on the record what that is? It is four to five nano—

Dr Young : Data that was collected in 2002-03 gave a pooled Australian mean value of 7.6 nanograms per millilitre for PFOA.

CHAIR: That is right across the population?

Dr Young : Yes, across Australia. For PFOS, the pooled Australian mean value was 21.3 nanograms per millilitre.

CHAIR: Everybody in Australia had that—

Dr Young : That was the testing that was done in 2002-03. That was reported in Environmental Science & Technology.

CHAIR: So that is all accepted? There is no contention about those figures?

Dr Young : Not that I am aware of.

CHAIR: Has there been a subsequent study since?

Dr Young : That is the one that I have information on at this point.

CHAIR: Were we still using it then, obviously?

Dr Young : It was around the early 2000s that there was a suggestion that people should decrease its use. It would still have been in the food chain and still available at that stage.

CHAIR: I read about Scotchgard, pots and pans, and all those sorts of things. Are they still a source, or have they been amended?

Dr Young : My understanding is, not in Australia. There has been an active process to reduce the amount that is in our environment.

CHAIR: If you have your lounge Scotchgarded in Australia now, you are not going to get a contaminant?

Dr Young : No, I believe not.

CHAIR: Those were the figures for 2002. Do you have any information about clusters or places like Oakey that may exhibit a higher level?

Dr Young : I do have the Defence results, but I understand Defence is giving evidence after us, so they will have that information as well. The average value of PFOA in 75 Oakey residents that they tested in 2015 was 3.05 nanograms per millilitre. It ranged—I think the range is very important here—from a minimum of 0.78 nanograms per millilitre up to 19.21 nanograms per millilitre, remembering that the Australian average was 7.6. That is PFOA, so suggesting that that is not a big concern.

The bigger concern is PFOS. The average value for those 75 Oakey residents in 2015 was 69.38 nanograms per mil. Again, I think it is the range that is important. It ranged from a minimum of 2.35 nanograms per mil up to a maximum of 381.29 nanograms per mil—again remembering that the average Australian pooled level was 21.3 nanograms per mil. Defence will have this data. They shared it with us.

CHAIR: Mr Reeves, do you communicate with your counterparts in New South Wales? There is a perception—perhaps from only me—that New South Wales departmental decisions are different to the ones that have been made in Queensland.

Mr Reeves : I could not comment on what is happening in the jurisdiction in New South Wales—

CHAIR: You could, but you won't.

Mr Reeves : I have only been in the position for about two months—

CHAIR: All they said was: 'Do not eat your eggs, do not eat your chooks, do not swim in the pool and do not drink the rainwater in the tanks unless it has been tested.' Have you said the same thing here?

Mr Reeves : No, we have not said the same thing here.

CHAIR: Is that because you have not tested those things or is that because you have a different view to New South Wales?

Mr Reeves : We have a different view to New South Wales.

Dr Young : Senator, may I comment?

CHAIR: Absolutely.

Dr Young : Thank you. At the moment we are working together at a national level through the Australian Health Protection Principal Committee to try to work out that we do need one source of advice. I think we were caught a little off balance in that New South Wales was told at one stage about Williamtown and we were told about Oakey and we did not have a chance to sit down and methodically work out what the risks genuinely are and what information we should be providing. That work has now started at the national level, so all states and territories have been engaged. We have developed a first draft of information that all states and territories have agreed to that will be made available. That is going through the process at the moment.

New South Wales, who I did talk with after they made their comments, decided that, because they were not quite sure what was happening, they would take a very precautionary approach, which is very understandable, and suggest that any exposure be limited. Whereas in Queensland we had had a little more time to think things through. They were told I think a bit later than we were and we were going through and felt that Defence had very appropriately responded to provide alternative drinking water supplies. All the evidence to date suggests that that is the major route of exposure. That was done very early by Defence. Work is now being done to look at what are the other sources of exposure.

I have one concern—and I know it is not possible to do this. They did an excellent piece of testing on those 75 Oakey residents. It would have been more useful if we had known what the exposure levels were for each person who was tested, because I am not quite sure in my own mind why some people have got levels that are way below the pooled level for Australia of 2.35 and others have levels of 381. Is that just because the person with the level of 381 was drinking contaminated bore water or did they have other sources of exposure? What is going on there? I would like to have a better understanding, given Defence did that tremendous piece of work, of what that really means. Also we are waiting for the results of the biota testing.

CHAIR: Would you say that the study has the answer to your questions? Was it just not given to you? Did they not ask?

Dr Young : I am not sure that they sought that information when the blood was taken, so it may need additional work by Defence to go back to those individuals and seek advice from them as to what their degree of exposure was.

CHAIR: Have you formally put that to Defence?

Dr Young : I have.

CHAIR: And their response?

Dr Young : That it would be difficult for them to do because they did not collect it at the time.

CHAIR: Go to 75 people and ask them some questions?

Senator BACK: It is a question now of which blood sample belongs to which person.

Dr Young : I am not sure.

CHAIR: You will get a response, though, as to why it is difficult?

Dr Young : At this stage Defence has said they are unable to progress that piece of work.

CHAIR: All right.

Dr Young : It is not an essential piece of work. It just would have been very useful to give us some information about whether there are potentially other routes of exposure.

CHAIR: Thank you very much for appearing here today.