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A campaign for sustainable methods of waste management |
Correspondence with Tayside Health Board, 6 December 2009 onwards
Comment on this story || Shore Road campaign || Binn Farm campaign
Dear fellow campaigner,
On 6 December 2009, I emailed Sandy Watson, Chairman of Tayside Health Board, requesting the closure of the DERL incinerator because of its poor safety record, and suggesting that they should block proposals for a new waste incinerator at Binn Farm. On 22 February I received separate letters in response to each of these suggestions. Both letters were were written by Dr Finn Romanes on behalf of Tayside Health Board. I have since replied to both of these.
You can see my initial email and subsequent correspondence below. This page will be kept updated with any further correspondence.
Best wishes,
Michael.
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Sent: Sunday,
December 06, 2009 8:39 PM Subject: Waste
incineration health concerns Mr
Sandy Watson OBE, Chairman,
Board of NHS Tayside 6
December 2009 Dear
Mr Watson Waste
incineration health concerns In
2000 NHS Tayside was promised that the new DERL waste incinerator at
Baldovie would meet the highest standards with regard to control of
emissions. In fact it has consistently failed to meet those standards,
despite the addition of £1.2 million of pollution abatement equipment in
2004. Recently I asked SEPA for a breakdown of emission breaches at
DERL. They replied that they would have to charge me £350 to cover
eight hours work by one of their officers. As an
alternative they
offered (free) a short summary of emission breaches since 2006. You can
see this here. Even
this summary is shocking. Over a four day period in 2008 the plant was
found to be emitting 102 times the permitted level of dioxins, which are
generally regarded as some of the most toxic and carcinogenic compounds
known to man. The
plant was also found to be emitting excessive quantities of fine
particulates. Dr Vyvyan Howard's Statement of Evidence to the Ringaskiddy
incinerator inquiry in Ireland, dated June 2009, explains that the
ultrafine particulates from incinerators are particularly dangerous
because they carry a range of toxins including dioxins, PCBs and metals
deep into the lungs, from where they enter the bloodstream and all parts
of the body (see Dr Howard's report, 'Particulate
Emissions and Health'). In
essence, the problem lies in the difference between what is technically
possible, and what happens in reality. In real life the so-called high
tech pollution control devices consist of fabric bags, into which a man
must shovel lime. If the bag is torn, or there isn't the right amount of
lime, they don't work. Similarly a smudge on the optical device that
measures particulate emissions can stop the whole thing from working. Nor
is gasification the clean alternative to incineration that it is made out
to be. Here is an extract from a report by the Blue Ridge Environmental
Defense League (click here for
full report): Gasification
shares many characteristics with incineration. At high temperatures used
in incineration and gasification, toxic metals including cadmium and
mercury, acid gases including hydrochloric acid, and ozone-forming
nitrogen oxides are released. Also, dioxins and furans are created in the
cooling process following the burning of ordinary paper and plastic. These
poisons are dangerous at extremely low levels and modern pollution control
devices do a poor job of reducing these emissions into the atmosphere.
Some including mercury and dioxin are persistent and bioaccumulative; they
resist breakdown in the environment and are concentrated in the food
chain. For
further information about the dangers of gasification, Dr Jorge Emmanuel
Phd presents a very informative series of films on YouTube - click here. Claims
that local authorities have no choice but to burn waste in order to avoid
fines for excessive landfill are entirely bogus. The Landfill Allowance
Scheme only applies to the biodegradable portion of municipal waste,
mainly consisting of paper, card, textiles, kitchen and garden waste.
Almost all of this can be recycled or composted at a fraction of the cost
of incineration (see WRAP
Gate Fees Report 2009). As for non-biodegradable items, many more of
these are becoming recyclable, including batteries and tetrapak drink
cartons. Many more items could be recycled, such as plastic fruit punnets
and yoghurt cartons, but as long as there are incinerators needing fed,
that is where they will go. I
ask that you bring this evidence to the attention of the Board of NHS
Tayside for their consideration, with a view to closing the DERL facility
and submitting an objection to the current application by SITA for a license
to run a waste incinerator at Binn Farm. Yours
sincerely Michael
Gallagher
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Health
Protection Team |
Date
22 February 2010 |
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Dear Mr Gallagher
Yours sincerely Dr Finn Romanes, Consultant in Public Health Medicine (Health Protection) Return to top of page ____________________________________________________________________________
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Dear
Dr Romanes WASTE
INCINERATION HEALTH CONCERNS Thank
you for replying to my recent letters to Sandy Watson, Chairman of
Tayside NHS Board, in which I suggested that Tayside Health Board
should push for the closure of the Baldovie incinerator and the revocation
of planning consent for the Binn Farm incinerator proposals. You
commented: “…emission
standards are strict and by nature precautionary and temporary breaches of
standards are not necessarily likely to be associated with adverse health
effects.” In
reply, I would like to point out that while emission standards may be
high, monitoring is often very poor. Take dioxins and furans as an
example. As
you will recall, in summer 2008 the Baldovie plant was found to be
emitting 102 times the legal limit for dioxins and furans over a four day
period. The company dismissed the breach as a one-off problem. However it
must be noted that under Scottish law it is only necessary for dioxins and
furans, and other airborne toxins, to be measured once every 6 months –
see section 5.6 of Waste
Incineration (Scotland) Regulations 2003: Practical Guidance: Edition 2. Even
if SEPA uses its discretion to increase the number of times it samples
these toxins, say, to 4 times a year, there can still be months when
emission breaches are taking place without anyone knowing. In fact, far
from improving monitoring, moves are afoot to reduce the number of
inspections of polluting industries – see
today’s report in the Sunday Herald. There
is another area of uncertainty that must also be considered, namely
empirical evidence of detrimental effects on human health. Independent
researcher Michael Ryan has found that infant mortality is consistently
higher downwind of incinerators. Of course it is difficult to prove a
relationship, but nor have scientists been able to disprove such a link.
The attached map of Coventry provides an example.
However
it may not just be infants that are affected. ONS figures show that New
Cross ward, which is largely downwind of the Debtford incinerator, has the
highest Standardised Mortality Ratio out of all 625 council wards in
London with a figure of 161 for 1999-2003. This translates as 61% more
deaths than would be expected (See
ONS statistics). Finally,
I would like to direct your attention to the current consultation on
TAYplan, which sets out planning policy for the next 20 years. The TAYplan
Environmental Report (click here to
see TAYplan documents) states that one of its goals is "To
reduce levels of pollution to air in the TAYplan area". How can the
production of tens of thousands of tonnes of airborne pollutants from
Baldovie and the proposed incinerator at Binn Farm help achieve this? I
look forward to your further comments. Yours
sincerely Michael
Gallagher
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Response from Dr Finn Romanes regarding my request for the closure of the DERL incinerator because of regular emission breaches, 22 February 2010 |
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Health
Protection Team |
Date
22 February 2010 |
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Dear Mr Gallagher REQUEST FOR CLOSURE OF THE DERL WASTE INCINERATOR AT BALDOVIE I am writing in relation to your letter of 6th December 2009 to Mr Sandy Watson, Chairman of Tayside NHS Board (the Board), wherein you noted events related to the waste incinerator at Baldovie and requested the Board consider the evidence submitted with a view to requesting closure of the facility. A separate letter has been sent to you regarding your requests around the SITA application for an Energy from Waste facility at Binn Farm. This letter will address your request related to the Baldovie incinerator. As an organisation concerned to robustly assess any risk to the health of the public, can I thank you for your contact and the expression of your concerns regarding potential human health effects of the operations of the facility. Within the last year, extensive reviews of the scientific literature have been undertaken, by the Health Protection Agency (HPA), Health Protection Scotland (HPS) and the Scottish Environment Protection Agency (SEPA), into concerns about links between incineration of waste and reported human health effects. One of the most recent of these documents is entitled The Impact on Human Health of Emissions to Air from Municipal Waste Incinerators' published by the HPA in September 2009, and this makes a range of expert observations including that the contribution to national emissions of particulates from waste incineration in a modern facility using best available technology is low, and that incineration of municipal solid waste accounts for less than 1% of United Kingdom estimated emissions of dioxins. Additionally, the report notes that even when people consume a significant proportion of locally produced foodstuffs, the contribution of incinerator emissions to their intake of dioxins is probably small and well below the tolerable daily intake for dioxins recommended by expert national committees. I raise these points to make the observation that available evidence from the scientific literature does not currently appear to support the general closure of waste incinerators. I have sought detailed responses from SEPA in relation to the concerns you have raised and can report the following: • Dioxin breaches did occur however action is reported to have been taken that has returned these emissions to within the required standards, and on sampling, there was no evidence of dioxin levels in nearby soil exceeding those expected in urban environments • Total dust breaches did occur however action was taken to return these emissions to compliant levels • The lime injection technique in use is reported to represent the best available technique • Errors in optical monitoring equipment are reported to have been rectified • In general, compliance with emissions standards is now reported to be high When coming to an interpretation of the risk that may be posed to public health, I note that emissions standards are strict and by nature precautionary and temporary breaches of standards are not necessarily likely to be associated with adverse health effects. I note also that appropriate actions have been taken to correct problems that led to breaches of emissions standards and that in the expressed opinion of SEPA the facility does not currently pose a serious pollution risk nor have problems been detected that amount to a degree of risk that would justify revocation of the permit to operate. The view of Tayside NHS Board's Department of Public Health is thus that the risk to human health, if present, is likely to be very low and that on the available evidence there are no public health grounds to request closure of the facility. It remains however appropriate and necessary for SEPA - as the regulator - to continue to closely monitor the situation at Baldovie and to liaise with NHS Tayside where the need arises. I trust this letter is helpful and thank you for your concern and interest in this matter. On behalf of Tayside NHS Board Yours sincerely Dr Finn Romanes, Consultant in Public Health Medicine (Health Protection) Return to top of page
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To Dr Finn Romanes, Tayside Health Board, Monday 5 April 2010 Dear Dr Romanes REQUEST FOR CLOSURE OF DERL WASTE INCINERATOR AT BALDOVIE – Your ref: FR/ad/0239-fr Thank you for your response to my request for the closure of the DERL incinerator due to its poor record of emission control. In this letter I will cover some of the points you raise. I have already replied to your letter regarding proposals to build an incinerator at Binn Farm. In your letter you point to the recent report by the Health Protection Agency, which largely dismisses concerns over health risks associated with waste incineration. I would like to highlight some of the deficiencies in this report. First, as you say, the report points out that incinerators are responsible for less than 1% of emissions of dioxins in the UK, implying low risk to human health. However this displays total ignorance of the fundamental difference between ‘point source’ emissions and ‘diffuse source’ emissions. They represent two distinct environmental disciplines. The situation is analogous to house fires. For the occupants of a house that goes on fire, the toxic fumes can be lethal. And yet as a proportion of airborne pollutants in the UK, fumes from house fires are virtually negligible. Another example is provided by the Eastcroft incinerator in Nottingham. While it may only be responsible for a very small proportion of total UK air pollution, that is little comfort to local residents suffering from the infamous ‘Eastcroft Cough’. As if this basic schoolboy error weren’t enough, the HPA report goes on to use a variety of outdated and largely discredited reports – in particular a report by DEFRA from 2004 titled Review of the Environmental and Health Effects of Waste Management. The Royal Society criticised this report for failing to discuss cumulative effects, timelines for exposure, effects of mixtures and synergies of emissions and the additive effects, for example, when combined with other environmental and occupational exposures. DEFRA acknowledged these deficiencies in the final draft. However, the Royal Society subsequently stated:"Although the uncertainties have been acknowledged in this report, it is important that anyone using these data takes adequate consideration of its inherent uncertainty". Both the Defra report and the Royal Society’s peer review are available online - click here. The Health Protection Agency seems to have gone out of its way to find reports that exonerate incineration. By contrast, a recent report by Health Protection Scotland, Incineration of Waste and Reported Human Health Effects, seems to be more even handed, and professional, in its approach. For example it refers to a report by Tango et al (2004), which identified a significant “peak-decline” increase in risk of infant death and infant death ascribed to congenital malformation in Japan for children living near MSW incinerators, with a peak risk at one to two kilometres from an incinerator. The HPA report also dismisses concerns over emissions of ultrafine particles, stating that most of these come from vehicles. However Professor Vyvyan Howard’s Statement of Evidence to the Ringaskiddy incinerator inquiry in Ireland, dated June 2009, explains that the ultrafine particulates from incinerators are particularly dangerous because they carry a range of toxins including dioxins, PCBs and metals (see Dr Howard's report, 'Particulate Emissions and Health'). As I mentioned in my letter of 4 March, although emissions standards may be high, monitoring is often rather poor and infrequent. Furthermore it is often left to the operators themselves to carry out such monitoring. Overall I believe the evidence points to a significant degree of uncertainty over the safety of modern incinerators, suggesting that where possible, alternative methods of waste management should be sought. Such methods exist, as proved by the likes of Surrey County Council, which has disavowed incineration in favour of reducing, reusing and recycling – with no toxic emissions at all. Surely, where there is a choice between uncertain emissions and zero emissions, Tayside Health Board should demand the latter.I look forward to your further comments, pointing to a definite course of action. Yours sincerely, Michael Gallagher |
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