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HIA and pollution prevention control: What they can learn from each other
Environmental Impact Assessment Review 25 (2005) 714 – 722 www.elsevier.com/locate/eiar
HIA and pollution prevention control: What they can learn from each other Balsam Ahmad *, Tanja Pless-Mulloli, Catherine Vizard School of Population and Health Sciences, William Leech Building, The Medical School, University of Newcastle upon Tyne, Framlington Place, Newcastle Upon Tyne, NE2 4HH, UK Available online 11 August 2005
Abstract Following the implementation of the Pollution Prevention and Control (England and Wales) Regulations on 1st August 2000, health authorities (now Primary Care Trusts) became statutory consultees for permits issued to industry by the environmental regulators (the Environmental Agency, Local Authorities). The aims of this paper are to review the process of providing public health input in the light of its similarities to and differences from HIA and to identify the opportunities for both HIA and PPC to learn from each other’s practice. We emphasise the challenges that are encountered by public health professionals who provide the public health input in the PPC. We use both our own experience of providing this input on behalf of health authorities and our expertise in HIA, environmental epidemiology and contaminated land. D 2005 Elsevier Inc. All rights reserved. Keywords: Pollution Prevention and Control (PPC); Health Impact Assessment (HIA)
1. Introduction The Pollution Prevention and Control PPC (England and Wales) Regulations 2000 are considered an important milestone for the protection of public health. This is because they incorporate a statutory function to consult on public health impact, thus bringing the protection of public health into the heart of permitting industrial activities (Health * Corresponding author. E-mail address: [email protected] (B. Ahmad). 0195-9255/$ - see front matter D 2005 Elsevier Inc. All rights reserved. doi:10.1016/j.eiar.2005.07.004
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Protection Agency, 2004). Examples of the types of industry regulated under the PPC regime include mineral and chemical industries, waste management (including landfill and incineration) and food and drink industries (DEFRA, 2004a,b). Since 2002 local health authorities (called Primary Care Trusts (PCTs) in England) have been the statutory consultees for permits issued to industry by the environmental regulator (the Environmental Agency or the Local Authority) in England and Wales. The PPC statutory role went to District Health Authorities in 2000 but subsequently was delegated to PCTs following the English National Health Service reform in 2002. Approximately 300 PCTs cover the population of England, each serving an average population of 170,000 people. Lanser and Pless-Mulloli (2003) reviewed the experience of health authorities in the PPC process and highlighted the inadequacy of early public health input. Ahmad (2004) has suggested that HIA could learn from the practice of integrating health in the PPC process in England and Wales. In this paper the feasibility of this recommendation is explored by reviewing the public health input to PPC practice in England, the evidence base used to inform such input, and the challenges facing it. It is argued that the current practice of providing public health input in the PPC can also learn from the evidence and practice of HIA. A wealth of published literature on HIA development, methods, evidence base and examples from practice now exists (Kemm et al., 2004; NICE, 2005). There are many examples of the involvement of PCTs in HIA practice in England. A number of these are published online (NICE, 2005). However we have found only one paper, which describes and analyses the PCT experience of undertaking an HIA to inform its response in the PPC process (Cook and Kemm, 2004). The authors have concluded that in this case the short time allocated to complete the HIA limited its value in resolving conflict and arranging adequate public participation. This paper draws on the experience of the Yorkshire IPPC Support Unit (YORIS), at the School of Population and Health Sciences in the University of Newcastle Upon Tyne, England. This unit provides public health input for the IPPC process on behalf of 23 PCTs in England. We have so far responded to more than one hundred PPC applications.
2. The role of the PCTs in the PPC process The Guidance to PCTs from the Health Protection Agency (Health Protection Agency, 2004) summarises their role in the PPC process as including the following: ! Determine whether the application contains adequate data to identify potential health risks to the local community from the installation emissions (both during normal and abnormal operations). ! Identify any local health issues that may be of relevance to the installation in question or to its location; for example, respiratory diseases that could be exacerbated by releases from the installation. In particular, it is important to identify any particularly vulnerable groups that can be more sensitive to the potential health effects from the installation. ! Identify whether or not the operator has demonstrated a high level of protection for human health and point out priority emissions for control from both normal and potential accidental releases.
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! Provide reassurance to the local community especially when a PPC application for an installation attracts wide public concern. During the four-month period available to the regulator to determine the PPC permit, the PCT and other statutory consultees are given 28 days to provide their comments on the application. It is generally the case that Part A1 installations (regulated by the Environmental Agency) have a greater potential to pollute the environment than Part A2 and Part B installations (regulated by the Local Authority) due to the nature and size of their operations. However, this assumption does not always hold true from a public health point of view. Small installations could face severe local opposition on health grounds, which may in turn require intense PCT involvement. The limited capacity for PCTs to respond to PPC applications in house has been an incentive to develop partnerships with specialist bodies to provide them with technical assistance for the fulfilment of their statutory role in the PPC process. In England, this technical support has been provided by the Local and Regional Services (LARS), the Division of Chemical Hazards and Poisons of the Health Protection Agency (HPA), or the environmental public health departments at regional universities.
3. Nature of the evidence used to inform public health input in the PPC process Both HIA and the public health input in the PPC need access to reliable and adequate evidence on potential health impacts of environmental exposures. Both use routine demographic data, epidemiological and toxicological evidence. The public health input in the PPC could therefore be said to resemble a dminiT HIA (i.e. one that is being based on already available information and limited quantification of impacts) (Parry and Stevens, 2001). The types of evidence used for the PPC process are: ! ! ! ! !
Data provided in the PPC application Sector guidance Epidemiological and toxicological evidence Routine demographic data Consultation with the regulator or other statutory consultees.
The applicants have to provide appropriate evidence on the pollutants released into air, water and land (as well as odour, noise and accidents), their sources (point or fugitive) and their likely concentrations. They often provide data from emissions and/or ambient monitoring or dispersion modelling. The operator is required to assess the effects of significant releases on sensitive receptors using the source-pathway-receptor model. The Environment Agency and the Department for Environment, Food and Rural Affairs (DEFRA) have issued sector and process guidelines to identify the main pollutants and processes involved in industrial activities. Epidemiological and toxicological evidence comes from peer reviewed journal articles and web-based data of national and international agencies such as the World Health
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Organisation (http://www.who.int/en/) and the US Agency for Toxic Substances and Disease Registry (ATSDR) (http://www.atsdr.cdc.gov/atsdrhome.html). Epidemiological evidence has the advantage of being transferable to other human populations. However, these exist only for a few of the types of installations being brought into the PPC system. Landfill sites are one such example (Vrijheid, 2000). The level of certainty of epidemiological evidence also varies greatly between the media: air, water, and soil. For the health effects of air pollution, a very large body of evidence linking short term variations of ambient pollution levels with population morbidity and mortality exists. The impacts of pollutant levels have been quantified and have led to evidence based air quality standards being set. The standards are not dno effectT levels but are set to be protective of public health to the extent that is acceptable to society at a given point in time (DEFRA, 2001). The evidence used to derive air quality standards is more robust that that used in developing soil guideline values using the Contaminated Land Exposure Assessment (CLEA) model. Vulnerability to environmental pollution differs between various population groups. For example, children and the elderly are considered more vulnerable to certain types of pollution. It is also well established that deprived communities are not only more likely to be located near polluting industries, but they may also be more susceptible due to compromised body systems (Pless-Mulloli and Phillimore, 2002). Therefore, demographic data can be used to identify the age and gender profile of the population and the level of socio-economic deprivation. In the UK, the latter is determined by using the Townsend Deprivation Score, which incorporates four variables from the National Census: percentage of private households with more than one person per room; the percentage of private households with no car; the percentage of private households which are not owner occupied, and the percentage of residents eligible for employment who are unemployed. These are combined into a single overall deprivation index (Donaldson and Donaldson, 2000). Consultation with the regulator or other statutory consultees or the public can sometimes yield important information; Local Authorities hold information on air quality, land contamination and nuisance complaints for noise or odour.
4. Challenges to the public health input in the PPC process A number of challenges face practitioners preparing public health responses in the PPC. These can be grouped as follows: ! Limitations in the evidence base ! Time and resource limitations ! Lack of consideration of cumulative environmental health impacts. There are considerable variations in the scope and detail in the applications, the quality of the data included, and the degree of quantification of emissions and environmental risk assessments. Epidemiological and toxicological evidence, which is used to inform either the public health input in the PPC or HIA has its limitations. These have been widely
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documented in the HIA literature and elsewhere (WHO, 2000; Petticrew et al., 2004; Wright et al., 1997). The disadvantage of epidemiological evidence is that human subjects are studied within their own environments. In such studies many factors cannot be controlled in the study design but can only be observed and accounted for in analysis. As for toxicological evidence, the main problem in using it is that assumptions have to be made about its transferability from animal or cell-based systems to human populations (Wright et al., 1997). Many PPC applications are highly technical, bulky documents often comprising several large lever-arch folders. Most applications lack a specific chapter on health impact and often the information required to assess the potential for public health impact is either scattered in different parts of the application or completely missing (YORIS, 2004; Ahmad et al., 2004). The nature of the technical content of PPC applications and the need to interpret complex environmental modelling data within a 28-day period require a considerable investment of time and expertise (Lanser and Pless-Mulloli, 2005). Similar restrictions of time and resources have also been recognised as limitations to the effectiveness of HIA and the ability to conduct full systematic literature reviews (Cook and Kemm, 2004). It is common for different parts of single installations to be run by different operators. They consequently submit separate applications for each component part, often at different times. (DEFRA, 2004a,b). Examples of this are heat boilers in a food manufacturing facility and waste treatment facilities on manufacturing sites. In many cases, therefore, the total load of pollutants and consequently the risk to public health may not be assessed. This is contrary to the spirit of integrated pollution prevention and control. A related but different example is applications for large landfill sites on a cell-by-cell basis. Due to the nature of landfill operations currently active landfill sites are often located adjacent to previously used sites. The older cells often use outdated ddilute and disperse’ methods. Consequently, pollutants emanating from a site may well be dominated by those originating from old cells rather than the newer ones operated with modern techniques.
5. Opportunities for public health input in PPC and HIA to learn from each other The cross-cutting nature of environmental health protection means that both the HIA and PPC can provide frameworks to stimulate cross-disciplinary cooperation and collaboration between the agencies involved in environmental and health protection. They can also support improved linkages between academia and industry in environmental and health protection practice, and encourage the production of evidence on the interactions between environmental determinants and health outcomes. Health authorities have been involved in the PPC and HIA processes for some time. This paper will now reflect on the opportunities that these processes offer to strengthen public health input into the environmental decision-making process and highlight some of the lessons learnt from this involvement. The PPC has so far proved to be a useful ongoing process for developing partnerships between the regulator and bodies involved in public health protection on national, regional and local levels. National PPC meetings have provided important and regular venues for representatives from public health bodies advising PCTs in the PPC process to meet
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representatives from the Environmental Agency and discuss problems that face public health comment for certain sectors. The PPC framework has also promoted more formal constructive cooperation between bodies responsible for environmental and health protection. For example, the Environmental Agency and the Health Protection Agency have recently signed an Interim Operational Agreement to ensure coordinated consideration of environmental related health protection issues arising from activities regulated by the Environmental Agency. HIA has also been quoted to contribute to the development and strengthening of cross-agency collaboration (Ardern, 2004; Milner, 2004). However, the ad hoc practice of HIA means that the framework for inter-agency collaboration created by the HIA may stop with the end of project or policy. Both PPC and HIA provide useful frameworks to sensitise the environmental regulators to the variety of health issues caused by industrial activities or by other non-health sector projects or policies. The lack of a dcommonT language between public health professionals and those working in environmental regulatory agencies has been mentioned as a possible reason for the lack of integration of health into established impact assessment procedures (Ahmad, 2004). Moreover, the Northern and Yorkshire Public Health Observatory scoping study has identified the lack of clarity of roles and lack of trust between stakeholders as obstacles perceived to hinder the effectiveness of environmental health protection from environmental hazards (Crowley et al., 2002). Thus the increased interaction and collaboration between public health and environmental professionals is an important step forward for the effectiveness of HIA and public health input in the PPC. In the words of Milner (2004: 248): Introducing HIA into local authorities is more about engaging people with the broad concepts of health, facilitating the process of it becoming a dmind setT, an automatic way of thinking within the authority. It is about raising the health consciousness of the organisation. Moreover, the effectiveness of both the HIA and the public health input in the PPC cannot be realised without the necessary expertise in environmental public health protection and the existence of an adequate and robust body of evidence on the linkages between health outcomes and specific environmental hazards. The development of environmental public health indicators to facilitate monitoring and coordinated environmental public health surveillance effort nationwide (with input from local and regional sources) is an important step forward for the development of the basic evidence base in environmental public health that both HIA and PPC processes can draw upon. In the future, it is anticipated that health agencies (PCTs or HPA) be involved in routine surveillance of sentinel environmental related conditions such as certain cancers, congenital abnormalities, (HPA, 2004: 22) or hospital admissions which can be linked later to environmental exposure data. Generation, analysis and systematic review of such data should be promoted as part the PPC framework which encourages links between academic departments and health and environmental protection bodies. Additionally, the PPC framework may also provide an incentive for the regulators to develop further and encourage the use of suitable quantitative approaches and models to assess health impacts of environmental exposures resulting from industrial activities (for example those developed by Fehr, 1999; Utley et al., 2003).
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The last decade has seen an increased public concern over the effects of environmental hazards coupled by an enhanced public expectation of being both informed about and involved in the decision making processes (Crowley et al., 2002). Whilst the structure for public participation and involvement is available in the PPC, it only provides a reactive rather than proactive format for engaging the public (only interested members of the public will seek to view the applications). Public participation, however, is considered integral part of the HIA process. Some HIAs are even considered a tool for community development (referred to as HIA-CD; Mittelmark et al., 2004). Thus the HIA can provide a useful tool for understanding the perception of health risks attributed to industrial installations in certain localities. This can feed into the development of risk communication strategies which are crucial for the development of trust. The PPC process offers an opportunity for the development of joint risk communication strategies by both the regulator and local health authorities. As discussed above, one of the main challenges facing the public health input in the PPC is the lack of consideration of cumulative environmental impacts in PPC applications. An HIA carried out as part of the EIA during the planning stage provides a reasonable framework within which the cumulative impacts may be considered. According to the guidelines published by DEFRA in 2004, new industries must obtain planning permission from the local authority as well as a PPC permit from the Environment Agency. These could be applied for simultaneously or sequentially, with the planning permission preceding the PPC, although the former is currently encouraged to take into account health considerations. Taking into account health issues in EIA conducted during the planning stage for a new installation can be helpful especially in covering issues not usually addressed in PPC applications such as environmental impacts from local transport and social impacts. Cumulative impacts are better addressed in strategic environmental assessments. It is not yet clear whether the implementation of the SEA Directive 2001/42/EC of the European Parliament and the Council of the European Union (EU) in UK regulations will make HIA of national, regional or local policies, plans and strategies mandatory by law. This Directive requires consideration of the likely significant effects on the population and human health when assessing the environmental impacts of policies.
6. Conclusion By providing a review of the public health input in the PPC process and the challenges involved, together with highlighting similarities with the HIA process, this paper has identified key opportunities for the integration of knowledge gathered from both HIA and PPC processes. This will serve to develop both practises and in turn serve to strengthen public health input in environmental decision making. It is recommended that these opportunities are seized by public health agencies, PCTs, in particular, in order to strengthen their roles and develop their expertise in relation to environmental hazards and health. This is important if PCTs have to fulfil their statutory responsibilities that include improving the health of the population within their boundaries and protecting public health.
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Acknowledgements We wish to thank Shelley Lanser for her comments on an earlier version of this paper and Janice Armstrong for administrative support. The views expressed are, however, strictly those of the authors and do not necessarily represent any organisation.
References Ahmad B. Editorial: integrating health into impact assessment: challenges and opportunities. Impact Assess Proj Apprais 2004;22:2 – 4. Ahmad B, Lanser S, Pless-Mulloli T, Vizard K. Integrated Pollution Prevention and Control (IPPC): an insight into the experience of health authorities in the Northern and Yorkshire area of the North East of England. Paper presented at the 24th Annual Conference of the International Association for Impact Assessment, impact assessment for industrial development. Whose business is it? April 24–30, 2004, Vancouver, Canada; 2004. Ardern K. HIA: a practitioner’s view. In: Kemm J, Parry J, Palmer S, editors. Health impact assessment Concepts, theory, techniques and applications. Oxford7 Oxford University Press; 2004. p. 103 – 14. Cook A, Kemm J. Health impact assessment of proposal to burn tyres in a cement plant. Environ Impact Asses Rev 2004;24:207 – 16. Crowley P, Cummings G, Pless-Mulloli T, Dunn CE, et al. Environmental Hazards and Health. A Scoping Study. London7 Northern & Yorkshire Public Health Observatory. Department for Environment, Food and Rural Affairs (DEFRA). The air quality strategy for England, Scotland, Wales and Northern Ireland. A consultation document on proposals for air quality objectives for particles, benzene, carbon monoxide and polycyclic aromatic hydrocarbons; 2001. Department for Environment, Food and Rural Affairs (DEFRA). Integrated Pollution Prevention and Control (IPPC): a practical guide. London7 DEFRA publications; http://www.defra.gov.uk/environment/ppc/ppc.htm; 2004a. Department for Environment, Food and Rural Affairs (DEFRA). Process guidance. available at: http:// www.defra.gov.uk/environment/ppc/laippc/laippc.htmnotes; http://www.defra.gov.uk/environment/airquality/ lapc/pgnotes/default.htm; 2004b. Donaldson LJ, Donaldson RJ. Essential public health. 2nd ed. Oxford7 Petroc Press 2000. Fehr R. Environmental health impact assessment: evaluation of a ten-step model. Epidemiology 1999;10:618 – 25. Health Protection Agency HPA. Integrated Pollution Prevention and Control (IPPC): a guide for Primary Care Trusts and Local Health Boards. Volume 2: Responding to IPPC applications. Chemical Hazards and Poisons Division. Version 1. September 2004. http://www.hpa.org.uk/hpa/chemicals/IPPC.htm; 2004. Kemm J, Parry J, Palmer S, editors. Health impact assessment. Concepts, theory, techniques and applications. Oxford7 Oxford University Press; 2004. Lanser S, Pless-Mulloli T. Integrated pollution prevention and control: a review of health authorities’ experience. J Public Health Med 2003;25:234 – 6. Milner SJ. Using HIA in local government. In: Kemm J, Parry J, Palmer S, editors. Health impact assessment. Concepts, theory, techniques and applications. Oxford7 Oxford University Press; 2004. p. 243 – 51. Mittelmark MB, Gillis DE, Hsu-Hage B. Community development: the role of HIA. In: Kemm J, Parry J, Palmer S, editors. Health impact assessment. Concepts, theory, techniques and applications. Oxford7 Oxford University Press; 2004. p. 143 – 52. National Institute for Health and Clinical Excellence (NICE). Public Health Practice Centre. Health Impact Assessment Gateway. http://www.publichealth.nice.org.uk/page.aspx?o=HIAGateway, accessed 12 July 2005. Parry J, Stevens A. Prospective health impact assessment: pitfalls, problems, and possible ways forward. BMJ 2001;323:1177 – 82. Petticrew M, Macintyre S, Thomson H. Evidence and HIA. In: Kemm J, Parry J, Palmer S, editors. Health impact assessment. Concepts, theory, techniques and applications. Oxford7 Oxford University Press; 2004. p. 71 – 80.
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Pless-Mulloli, T, Phillimore, P. Pollution, social exclusion, equity and health. In: Eames M, Adebowale M, editors. Sustainable development and social inclusion. Towards an integrated approach to research. York, UK: York Publishing Services Ltd, Policy Studies Institute; 2002. Utley M, Gallivan S, McCarthy M, Biddulph J, Ferguson J. ARMADA: a computer model for evaluating the effect of environmental factors on health. Health Care Manage Sci 2003;6:137 – 46. Vrijheid M. Health effects of residence near hazardous waste landfill sites: a review of epidemiologic literature. Environ Health Perspect 2000;108:101 – 12. World Health Organisation. Evaluation and use of epidemiological evidence for environmental health risk assessment Guideline document. Copenhagen7 World Health Organisation Regional Office for Europe; 2000. Wright C, Lopipero P, Smith A. Meta-analysis and risk assessment. In: Steenland K, Savitz D, editors. Topics in environmental epidemiology. New York7 Oxford University Press; 1997. p. 28 – 63. Yorkshire IPPC Support Unit (YORIS). (2004) Yorkshire IPPC support unit annual report. 1st September 2003 to 31 March 2004. 2004; School of Population and Health Sciences, University of Newcastle Upon Tyne.
HIA and pollution prevention control: What they can learn from each other Balsam Ahmad *, Tanja Pless-Mulloli, Catherine Vizard School of Population and Health Sciences, William Leech Building, The Medical School, University of Newcastle upon Tyne, Framlington Place, Newcastle Upon Tyne, NE2 4HH, UK Available online 11 August 2005
Abstract Following the implementation of the Pollution Prevention and Control (England and Wales) Regulations on 1st August 2000, health authorities (now Primary Care Trusts) became statutory consultees for permits issued to industry by the environmental regulators (the Environmental Agency, Local Authorities). The aims of this paper are to review the process of providing public health input in the light of its similarities to and differences from HIA and to identify the opportunities for both HIA and PPC to learn from each other’s practice. We emphasise the challenges that are encountered by public health professionals who provide the public health input in the PPC. We use both our own experience of providing this input on behalf of health authorities and our expertise in HIA, environmental epidemiology and contaminated land. D 2005 Elsevier Inc. All rights reserved. Keywords: Pollution Prevention and Control (PPC); Health Impact Assessment (HIA)
1. Introduction The Pollution Prevention and Control PPC (England and Wales) Regulations 2000 are considered an important milestone for the protection of public health. This is because they incorporate a statutory function to consult on public health impact, thus bringing the protection of public health into the heart of permitting industrial activities (Health * Corresponding author. E-mail address: [email protected] (B. Ahmad). 0195-9255/$ - see front matter D 2005 Elsevier Inc. All rights reserved. doi:10.1016/j.eiar.2005.07.004
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Protection Agency, 2004). Examples of the types of industry regulated under the PPC regime include mineral and chemical industries, waste management (including landfill and incineration) and food and drink industries (DEFRA, 2004a,b). Since 2002 local health authorities (called Primary Care Trusts (PCTs) in England) have been the statutory consultees for permits issued to industry by the environmental regulator (the Environmental Agency or the Local Authority) in England and Wales. The PPC statutory role went to District Health Authorities in 2000 but subsequently was delegated to PCTs following the English National Health Service reform in 2002. Approximately 300 PCTs cover the population of England, each serving an average population of 170,000 people. Lanser and Pless-Mulloli (2003) reviewed the experience of health authorities in the PPC process and highlighted the inadequacy of early public health input. Ahmad (2004) has suggested that HIA could learn from the practice of integrating health in the PPC process in England and Wales. In this paper the feasibility of this recommendation is explored by reviewing the public health input to PPC practice in England, the evidence base used to inform such input, and the challenges facing it. It is argued that the current practice of providing public health input in the PPC can also learn from the evidence and practice of HIA. A wealth of published literature on HIA development, methods, evidence base and examples from practice now exists (Kemm et al., 2004; NICE, 2005). There are many examples of the involvement of PCTs in HIA practice in England. A number of these are published online (NICE, 2005). However we have found only one paper, which describes and analyses the PCT experience of undertaking an HIA to inform its response in the PPC process (Cook and Kemm, 2004). The authors have concluded that in this case the short time allocated to complete the HIA limited its value in resolving conflict and arranging adequate public participation. This paper draws on the experience of the Yorkshire IPPC Support Unit (YORIS), at the School of Population and Health Sciences in the University of Newcastle Upon Tyne, England. This unit provides public health input for the IPPC process on behalf of 23 PCTs in England. We have so far responded to more than one hundred PPC applications.
2. The role of the PCTs in the PPC process The Guidance to PCTs from the Health Protection Agency (Health Protection Agency, 2004) summarises their role in the PPC process as including the following: ! Determine whether the application contains adequate data to identify potential health risks to the local community from the installation emissions (both during normal and abnormal operations). ! Identify any local health issues that may be of relevance to the installation in question or to its location; for example, respiratory diseases that could be exacerbated by releases from the installation. In particular, it is important to identify any particularly vulnerable groups that can be more sensitive to the potential health effects from the installation. ! Identify whether or not the operator has demonstrated a high level of protection for human health and point out priority emissions for control from both normal and potential accidental releases.
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! Provide reassurance to the local community especially when a PPC application for an installation attracts wide public concern. During the four-month period available to the regulator to determine the PPC permit, the PCT and other statutory consultees are given 28 days to provide their comments on the application. It is generally the case that Part A1 installations (regulated by the Environmental Agency) have a greater potential to pollute the environment than Part A2 and Part B installations (regulated by the Local Authority) due to the nature and size of their operations. However, this assumption does not always hold true from a public health point of view. Small installations could face severe local opposition on health grounds, which may in turn require intense PCT involvement. The limited capacity for PCTs to respond to PPC applications in house has been an incentive to develop partnerships with specialist bodies to provide them with technical assistance for the fulfilment of their statutory role in the PPC process. In England, this technical support has been provided by the Local and Regional Services (LARS), the Division of Chemical Hazards and Poisons of the Health Protection Agency (HPA), or the environmental public health departments at regional universities.
3. Nature of the evidence used to inform public health input in the PPC process Both HIA and the public health input in the PPC need access to reliable and adequate evidence on potential health impacts of environmental exposures. Both use routine demographic data, epidemiological and toxicological evidence. The public health input in the PPC could therefore be said to resemble a dminiT HIA (i.e. one that is being based on already available information and limited quantification of impacts) (Parry and Stevens, 2001). The types of evidence used for the PPC process are: ! ! ! ! !
Data provided in the PPC application Sector guidance Epidemiological and toxicological evidence Routine demographic data Consultation with the regulator or other statutory consultees.
The applicants have to provide appropriate evidence on the pollutants released into air, water and land (as well as odour, noise and accidents), their sources (point or fugitive) and their likely concentrations. They often provide data from emissions and/or ambient monitoring or dispersion modelling. The operator is required to assess the effects of significant releases on sensitive receptors using the source-pathway-receptor model. The Environment Agency and the Department for Environment, Food and Rural Affairs (DEFRA) have issued sector and process guidelines to identify the main pollutants and processes involved in industrial activities. Epidemiological and toxicological evidence comes from peer reviewed journal articles and web-based data of national and international agencies such as the World Health
B. Ahmad et al. / Environmental Impact Assessment Review 25 (2005) 714–722
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Organisation (http://www.who.int/en/) and the US Agency for Toxic Substances and Disease Registry (ATSDR) (http://www.atsdr.cdc.gov/atsdrhome.html). Epidemiological evidence has the advantage of being transferable to other human populations. However, these exist only for a few of the types of installations being brought into the PPC system. Landfill sites are one such example (Vrijheid, 2000). The level of certainty of epidemiological evidence also varies greatly between the media: air, water, and soil. For the health effects of air pollution, a very large body of evidence linking short term variations of ambient pollution levels with population morbidity and mortality exists. The impacts of pollutant levels have been quantified and have led to evidence based air quality standards being set. The standards are not dno effectT levels but are set to be protective of public health to the extent that is acceptable to society at a given point in time (DEFRA, 2001). The evidence used to derive air quality standards is more robust that that used in developing soil guideline values using the Contaminated Land Exposure Assessment (CLEA) model. Vulnerability to environmental pollution differs between various population groups. For example, children and the elderly are considered more vulnerable to certain types of pollution. It is also well established that deprived communities are not only more likely to be located near polluting industries, but they may also be more susceptible due to compromised body systems (Pless-Mulloli and Phillimore, 2002). Therefore, demographic data can be used to identify the age and gender profile of the population and the level of socio-economic deprivation. In the UK, the latter is determined by using the Townsend Deprivation Score, which incorporates four variables from the National Census: percentage of private households with more than one person per room; the percentage of private households with no car; the percentage of private households which are not owner occupied, and the percentage of residents eligible for employment who are unemployed. These are combined into a single overall deprivation index (Donaldson and Donaldson, 2000). Consultation with the regulator or other statutory consultees or the public can sometimes yield important information; Local Authorities hold information on air quality, land contamination and nuisance complaints for noise or odour.
4. Challenges to the public health input in the PPC process A number of challenges face practitioners preparing public health responses in the PPC. These can be grouped as follows: ! Limitations in the evidence base ! Time and resource limitations ! Lack of consideration of cumulative environmental health impacts. There are considerable variations in the scope and detail in the applications, the quality of the data included, and the degree of quantification of emissions and environmental risk assessments. Epidemiological and toxicological evidence, which is used to inform either the public health input in the PPC or HIA has its limitations. These have been widely
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documented in the HIA literature and elsewhere (WHO, 2000; Petticrew et al., 2004; Wright et al., 1997). The disadvantage of epidemiological evidence is that human subjects are studied within their own environments. In such studies many factors cannot be controlled in the study design but can only be observed and accounted for in analysis. As for toxicological evidence, the main problem in using it is that assumptions have to be made about its transferability from animal or cell-based systems to human populations (Wright et al., 1997). Many PPC applications are highly technical, bulky documents often comprising several large lever-arch folders. Most applications lack a specific chapter on health impact and often the information required to assess the potential for public health impact is either scattered in different parts of the application or completely missing (YORIS, 2004; Ahmad et al., 2004). The nature of the technical content of PPC applications and the need to interpret complex environmental modelling data within a 28-day period require a considerable investment of time and expertise (Lanser and Pless-Mulloli, 2005). Similar restrictions of time and resources have also been recognised as limitations to the effectiveness of HIA and the ability to conduct full systematic literature reviews (Cook and Kemm, 2004). It is common for different parts of single installations to be run by different operators. They consequently submit separate applications for each component part, often at different times. (DEFRA, 2004a,b). Examples of this are heat boilers in a food manufacturing facility and waste treatment facilities on manufacturing sites. In many cases, therefore, the total load of pollutants and consequently the risk to public health may not be assessed. This is contrary to the spirit of integrated pollution prevention and control. A related but different example is applications for large landfill sites on a cell-by-cell basis. Due to the nature of landfill operations currently active landfill sites are often located adjacent to previously used sites. The older cells often use outdated ddilute and disperse’ methods. Consequently, pollutants emanating from a site may well be dominated by those originating from old cells rather than the newer ones operated with modern techniques.
5. Opportunities for public health input in PPC and HIA to learn from each other The cross-cutting nature of environmental health protection means that both the HIA and PPC can provide frameworks to stimulate cross-disciplinary cooperation and collaboration between the agencies involved in environmental and health protection. They can also support improved linkages between academia and industry in environmental and health protection practice, and encourage the production of evidence on the interactions between environmental determinants and health outcomes. Health authorities have been involved in the PPC and HIA processes for some time. This paper will now reflect on the opportunities that these processes offer to strengthen public health input into the environmental decision-making process and highlight some of the lessons learnt from this involvement. The PPC has so far proved to be a useful ongoing process for developing partnerships between the regulator and bodies involved in public health protection on national, regional and local levels. National PPC meetings have provided important and regular venues for representatives from public health bodies advising PCTs in the PPC process to meet
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representatives from the Environmental Agency and discuss problems that face public health comment for certain sectors. The PPC framework has also promoted more formal constructive cooperation between bodies responsible for environmental and health protection. For example, the Environmental Agency and the Health Protection Agency have recently signed an Interim Operational Agreement to ensure coordinated consideration of environmental related health protection issues arising from activities regulated by the Environmental Agency. HIA has also been quoted to contribute to the development and strengthening of cross-agency collaboration (Ardern, 2004; Milner, 2004). However, the ad hoc practice of HIA means that the framework for inter-agency collaboration created by the HIA may stop with the end of project or policy. Both PPC and HIA provide useful frameworks to sensitise the environmental regulators to the variety of health issues caused by industrial activities or by other non-health sector projects or policies. The lack of a dcommonT language between public health professionals and those working in environmental regulatory agencies has been mentioned as a possible reason for the lack of integration of health into established impact assessment procedures (Ahmad, 2004). Moreover, the Northern and Yorkshire Public Health Observatory scoping study has identified the lack of clarity of roles and lack of trust between stakeholders as obstacles perceived to hinder the effectiveness of environmental health protection from environmental hazards (Crowley et al., 2002). Thus the increased interaction and collaboration between public health and environmental professionals is an important step forward for the effectiveness of HIA and public health input in the PPC. In the words of Milner (2004: 248): Introducing HIA into local authorities is more about engaging people with the broad concepts of health, facilitating the process of it becoming a dmind setT, an automatic way of thinking within the authority. It is about raising the health consciousness of the organisation. Moreover, the effectiveness of both the HIA and the public health input in the PPC cannot be realised without the necessary expertise in environmental public health protection and the existence of an adequate and robust body of evidence on the linkages between health outcomes and specific environmental hazards. The development of environmental public health indicators to facilitate monitoring and coordinated environmental public health surveillance effort nationwide (with input from local and regional sources) is an important step forward for the development of the basic evidence base in environmental public health that both HIA and PPC processes can draw upon. In the future, it is anticipated that health agencies (PCTs or HPA) be involved in routine surveillance of sentinel environmental related conditions such as certain cancers, congenital abnormalities, (HPA, 2004: 22) or hospital admissions which can be linked later to environmental exposure data. Generation, analysis and systematic review of such data should be promoted as part the PPC framework which encourages links between academic departments and health and environmental protection bodies. Additionally, the PPC framework may also provide an incentive for the regulators to develop further and encourage the use of suitable quantitative approaches and models to assess health impacts of environmental exposures resulting from industrial activities (for example those developed by Fehr, 1999; Utley et al., 2003).
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The last decade has seen an increased public concern over the effects of environmental hazards coupled by an enhanced public expectation of being both informed about and involved in the decision making processes (Crowley et al., 2002). Whilst the structure for public participation and involvement is available in the PPC, it only provides a reactive rather than proactive format for engaging the public (only interested members of the public will seek to view the applications). Public participation, however, is considered integral part of the HIA process. Some HIAs are even considered a tool for community development (referred to as HIA-CD; Mittelmark et al., 2004). Thus the HIA can provide a useful tool for understanding the perception of health risks attributed to industrial installations in certain localities. This can feed into the development of risk communication strategies which are crucial for the development of trust. The PPC process offers an opportunity for the development of joint risk communication strategies by both the regulator and local health authorities. As discussed above, one of the main challenges facing the public health input in the PPC is the lack of consideration of cumulative environmental impacts in PPC applications. An HIA carried out as part of the EIA during the planning stage provides a reasonable framework within which the cumulative impacts may be considered. According to the guidelines published by DEFRA in 2004, new industries must obtain planning permission from the local authority as well as a PPC permit from the Environment Agency. These could be applied for simultaneously or sequentially, with the planning permission preceding the PPC, although the former is currently encouraged to take into account health considerations. Taking into account health issues in EIA conducted during the planning stage for a new installation can be helpful especially in covering issues not usually addressed in PPC applications such as environmental impacts from local transport and social impacts. Cumulative impacts are better addressed in strategic environmental assessments. It is not yet clear whether the implementation of the SEA Directive 2001/42/EC of the European Parliament and the Council of the European Union (EU) in UK regulations will make HIA of national, regional or local policies, plans and strategies mandatory by law. This Directive requires consideration of the likely significant effects on the population and human health when assessing the environmental impacts of policies.
6. Conclusion By providing a review of the public health input in the PPC process and the challenges involved, together with highlighting similarities with the HIA process, this paper has identified key opportunities for the integration of knowledge gathered from both HIA and PPC processes. This will serve to develop both practises and in turn serve to strengthen public health input in environmental decision making. It is recommended that these opportunities are seized by public health agencies, PCTs, in particular, in order to strengthen their roles and develop their expertise in relation to environmental hazards and health. This is important if PCTs have to fulfil their statutory responsibilities that include improving the health of the population within their boundaries and protecting public health.
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Acknowledgements We wish to thank Shelley Lanser for her comments on an earlier version of this paper and Janice Armstrong for administrative support. The views expressed are, however, strictly those of the authors and do not necessarily represent any organisation.
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