Risk-based regulation of discharges whose risk is it anyway?

The Environmental Agency in the UK, is considering to revise its method of regulating discharges to the water environment, using risk-based principles known as the Hampton Principles. The agency is to adopt Operator and Pollution Risk Appraisal system (OPRA), which has already been applied to other regulatory regimes such as Pollution Prevention and Control and Waste Management, for the water quality regime. The Environmental Industries Commission's (ETC's) Water Pollution Control Working Group, which represents over 80 companies supplying water pollution control technologies and services, is supporting the EA's proposal but raising several issues of concern. Thess issues include the use of prescriptive conditions to trigger risk assessment, continued use of upper bound limits on flow rate and concentration within discharge consents and the impact of this on water efficiency, and the impact of the new water quality regime on efforts to clean up existing water contamination.