This is a response to a public consultation document for the Environmental Protection Agency (EPA) proposals for hazardous waste management for the next 5 years. Further information and a copy of the consultation document can be found at www.epa.ie

Submission:

Introduction

The Institute of Public Health in Ireland (IPH)
IPH is an all-island body which aims to improve health in Ireland, by working to combat health inequalities and influence public policies in favour of health. IPH promotes co-operation in research, training, information and policy in order to contribute to policies which tackle inequalities in health.

Proposed National Hazardous Waste Management Plan 2008-2012
IPH welcome the opportunity to comment on the above Plan.  Waste management and public health are inextricably linked and as such there is inherent sense in assessing the potential impact on health of any proposed method of managing waste.

We wish to make the following general observations in relation to the Proposed Plan: 

• IPH calls for a greater emphasis on the impacts of hazardous waste on public health in the Proposed Plan. Hazardous waste presents a threat to public health and research studies have shown that although findings may be inconclusive there is cause for concern related to hazardous waste management facilities. 

• The Health Research Board in Ireland commissioned a literature review of the Health and Environmental Effects of Landfilling and Incineration of Waste (1).  This review found that with regard to incineration there is some evidence to suggest an association with respiratory morbidity.  Incinerator emissions have also been associated with acute and chronic respiratory symptoms. The EUROHAZCON study which was conducted across 23 sites in Europe identified that there was a higher risk of chromosomal anomalies in people who lived close to hazardous waste landfill sites (2). 

• Where no evidence can be found of a relationship between adverse health effects and proximity to incineration sites it is important to bear in mind this may mean there is no relationship or a relationship exists but may not be detectable using available methods and data sources.  The fact that ill-health may occur infrequently or take years to appear makes it difficult to establish cause and effect (3).  It is therefore imperative that the impact on public health is adequately addressed through the Proposed Plan.

• The Strategic Environmental Assessment (SEA) conducted on the Proposed Plan identifies that the inappropriate disposal of hazardous waste is the biggest impact on human health. IPH welcomes this statement and agrees that unreported hazardous waste needs to be better controlled and accounted for to minimise the risk to human health.

• The SEA considers the impact of the Proposed Plan on human and population health.  IPH strongly urges the EPA to adopt a more comprehensive view of health.  The World Health Organisation defines health as “…a state of complete physical, mental and social well-being and not merely the absence of disease and infirmity” (4). This more holistic interpretation of health includes psychological and social wellbeing.  It is particularly important to adopt this broad definition when referring to hazardous waste as this issue has the potential to impact on many aspects of human health.

• IPH recommends that the Proposed Plan includes requirements for Health Impact Assessment (HIA) and calls for a commitment to ensure all future hazardous waste management facilities are assessed for health impacts. HIA takes into consideration the wider determinants of health and is a methodology which assesses the potential and unintended health impacts of an identified proposal.  HIA uses both quantitative and qualitative methods to identify the health impacts on the population’s health and makes recommendations for decision-makers as to how negative health impacts can be mitigated and positive ones enhanced.  HIA can also make a contribution to tackling health inequalities in that it specifically explores the impact of the proposal on sub-groups within the population. This will help to ensure that the Proposed Plan does not exacerbate existing health inequalities and that were possible steps can be taken to reduce health inequalities thus making a significant contribution to a more equitable society.

In relation to the specific questions we wish to make the following points:

The Proposed Plan recommends a sectoral-based prevention programme for hazardous waste to be undertaken by the existing National Waste Prevention Programme.

IPH would welcome more collective ownership from all sectors for the impact of hazardous waste on public health.  The healthcare sector has been identified as a source of hazardous waste which can lead to public health concerns and IPH welcome the proposed actions in relation to this sector.  However, it should be acknowledged that the mismanagement of hazardous waste from all sectors can be a potential public health concern.  Therefore each sector should take responsibility for their actions which affect public health and appropriate guidance should be included in the Proposed Plan to help them in this regard.

The Proposed Plan recommends that Ireland should strive for greater self-sufficiency in the management of its own hazardous waste, where economically and technically feasible.

IPH supports the call in the plan to reduce the generation of hazardous waste across Ireland as a first step towards management of the issue.  In recognition that it is impossible to avoid all waste, it is essential that self-sufficiency programmes developed in Ireland are assessed for their potential health impacts prior to the establishment of any scheme or facility to deal with hazardous waste.

Finally, all-island co-operation is welcomed given the similarities in hazardous waste patterns produced by industry in Ireland, North and South.   IPH supports the collection of data, the conducting of research and development of guidance on an all-island basis to promote joint working and action in this area.  IPH as an all-island organisation has much experience in co-operation for improved health across the island and is willing to lend its expertise to further work in this area. 
 

References

1. Health Research Board (2003) Health and Environmental Effects of Landfilling and Incineration of Waste -  A Literature Review, p 194
2. Vrijheid, M PhD et al, 2002, The Lancet, Chromosomal congenital anomalies and residence near hazardous waste landfill sites, Volume 359, Issue 9303, 26 January 2002, p 320-322.
3. The Institute of Public Health in Ireland, 2005, Health Impact Assessment and Waste Management with particular reference to incineration
4. World Health Organisation, 1946

Contact details

For further information on this submission, please contact
Claire Higgins
Institute of Public Health in Ireland
Forestview
Purdy’s Lane
Belfast
BT8 7ZX
Northern Ireland
Tel: +44 28 90648494
Email: claire.higgins@publichealth.ie

Dr Jane Wilde
Chief Executive
Institute of Public Health in Ireland
Forestview
Purdy’s Lane
Belfast
BT8 7ZX
Tel: +44 28 9064 8494
Email: jane.wilde@publichealth.ie

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