GALWAY for a SAFE ENVIRONMENT
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Tuesday, July 18th , 2000
Galway for a Safe Environment (GSE) Residents for a Responsible Waste Management Policy Tuesday, July 18th , 2000 Dr. Vyvyan Howard Replies to MC O'Sullivan Health Report GSE have received a reply from Dr. Vyvyan Howard, of the University of Liverpool, on the topic of the controversial Health Report on "Thermal Treatment", authored by MC O'Sullivan Consulting Engineers, and distributed to Galway City and County Councillors last week. In his reply, Dr. Howard, who is at the Department of Fetal and Infant Toxico-Pathology, at the University of Liverpool, severely criticises the MC O'Sullivan report on a number of grounds: 1. Dr. Howard challenges the assertion that incineration is a "tried and tested method", and notes that "in the UK in 1996, virtually every incinerator in the country was shut down as a consequence of the health fears associated with them". 2. He says that "any risk assessment is meaningless unless a thorough hazard identification, hazard assessment and exposure assessment has been performed. For example with dioxin it is necessary to know what the current body burdens of the local population are. Nothing like this has, to my knowledge, been proposed in Galway." 3. Dr. Howard says that "research in Holland shows quite clearly that, at current body burdens of dioxin, a proportion of mothers are passing onto their offspring too much dioxin". He points out that this has led to negative effects on the childrens intelligence and ability to fight infections. In his full report (3 pages, attached) Dr. Howard lists numerous other failings in the MC O'Sullivan report, including the fact that the report never mentioned that the recent USEPA report on dioxins attributed 11% of all cancer deaths in the US to dioxins. Galway for Safe Environment spokesperson, Áine Suttle has called on City Councillors to read this report carefully (a copy has been given to each councillor), and to reflect on the fact that no health expert has approved of the plan to build an incinerator in Galway. "On the contrary", she said, "each health expert that has been consulted, either by Galway Corporation, or by GSE, has clearly said that they are not happy with the level of risk assessment that has been carried out by the authors of this plan" GSE are organising another silent demonstration outside City Hall next Monday evening, July 24th, from 6.30 to 7.30 pm, as Galway City Councillors are expected to vote on the controversial incinerator proposal that evening. Confirmation: Conchúr Ó Brádaigh, 091-799223 / 087-283045 Áine Suttle, 091-581047 Dr. Howard may be contacted at 00-44-151-7943854 ************************************************** Comments on the Draft Waste management Plan for the Connaught Region, Report on Thermal Treatment and Public Health, dated June 2000. Dr C. V. Howard. MB. ChB. PhD. FRCPath. Fetal & Infant Toxico-Pathology University of Liverpool In this response I have concentrated solely on the health aspects. I believe that there are other questions raised about the technology of incineration, which should be addressed by others with an engineering background. This report does not identify an author. Is the author suitably qualified to comment on the health effects of incineration? Much of the report looks as if it has been copied piecemeal out of other reports and books. Page 2, Section 2 line 4. "tried and tested method" is used to describe the use of incineration for waste disposal. That implies that it has been successful over the years. Nothing could be further from the truth. In the UK in 1996, virtually every incinerator in the country had to shut down as a consequence of the health fears associated with them. They either had to be retrofitted or rebuilt at extremely high cost, because of the additional gas scrubbing devices that had to be put in place. This was part of a continuing process of adding extras in a piecemeal fashion and claiming that these were now 'new incinerators' and that the 'old technology' could be forgotten. However, it should be recognised that this technology has been an unmitigated disaster, from a health point of view. It is estimated that up to 82% of the dioxin contamination in Europe has been the result of the incineration of waste, much of which is rich in organo-halogen products such as PVC. The new 'new incinerators' continue to malfunction frequently (about 500 episodes in the UK since 1996). Although they are emitting less pollutants into the air (thank goodness) this means that more is having to be landfilled as ash, a health problem that will be left as a legacy for our successors. Page 3, line 6 - "This leads to public concern about the thermal treatment of waste....". Weasel words, which imply that all that is needed is some reassurance. However, many scientific bodies such as the WHO, Dutch Health Council, EU, USEPA are also concerned. That was why all the incinerators had to close down in 1996. That was why the tolerable daily intake (TDI) of dioxin was reduced by the WHO from 10 pg/kg body wt/ day to 1 to4 pg/kg body wt/ day, with a strong recommendation that it should be below 1 pg/kg body wt/day. Why should this have happened? The answer is that research from Holland shows quite clearly that, at current body burdens of dioxin, a proportion of mothers are passing onto their offspring too much dioxin. Negative effects on their children's intelligence (a 4 point loss on the IQ scale between the most and the least exposed) and ability to fight infections have been measured (a 6-fold increase in middle ear infections between the most and the least exposed). Most of the responsibility for this must be associated with the incineration of waste. There is clearly a pressing need, on health grounds, to further reduce outputs of dioxin to the environment. Incinerators achieve the opposite, primarily by maximising waste and allowing the manufacturers of the toxic elements of the waste stream to continue in production because there is a disposal route available. Page 3, Heavy Metals, line 9. "There is no evidence...". This is an age-old mantra of polluting industries. It is hardly surprising that there is little evidence, because base-line health studies are never performed before these plants are introduced. Therefore, unless the health effects were massive or highly unusual, it would be impossible to detect them anyway. Absence of evidence is not the same as evidence of absence of effect. If you consider the case of thalidomide, its effects were detected quite quickly because it caused such an unusual and obvious defect. If thalidomide had caused something much more common, like cleft palate, it would have been much more difficult to associate the drug with the effect. In the case of incinerators, if they cause changes in the background rates of common diseases in the local population, such as respiratory or circulatory conditions or lung cancer for example, it will be very difficult to detect any changes by epidemiology. Thus the phrase "There is no evidence" is rather unreassuring and usually means "We didn't look". However, with respect to heavy metals, the recent Byker ash scandal has highlighted the fact that these ashes are highly contaminated. This is hardly surprising, as we have all learned that matter can neither be created nor destroyed. If you put these elements into an incinerator, they have to come out, either in the gas, airborne particles or ash. And they do. It would be far more sensible to reduce the amounts of heavy metals entering the waste stream in the first place and separate out any that do get into the waste stream, to be put aside for special handling and/or recycling or return to the manufacturer. With respect to dust, the use of gravimetric control standards has long been recognised as inadequate. The particles which are causing most concern are the 'ultrafine' particles, those less than 0.2 µm. These pass through the filter systems on incinerators virtually unabated. The smaller the particles become, the more toxic they become, particularly if they consist of metals. I have just edited a book on the health effects of particles and I append a chapter of a book, which is to appear shortly on the implications of ultrafine particle toxicity for waste incinerators. In my opinion they will have a local health impact, which as yet is unquantified. Page 4, Dust, line 6. "However, these effects are more likely to predominate in susceptible populations". I am not sure if this is put forward as an argument in favour of incinerators, but if it is, it is the most appalling statement. We should take care to protect the health of the most vulnerable, such as children, the aged, those with chronic disease, rather than simply dismissing them as irrelevant. The position stated here seems to very clearly portray callous disinterest in the people who are receptors of pollution from incinerators. Page 5, Risk assessment, line 1. Any risk assessment is meaningless unless a thorough hazard identification, hazard assessment and exposure assessment has been performed. For example, with dioxin it is necessary to know what the current body burdens of the local population are. This would be part of a hazard assessment. Nothing like this has, to my knowledge, been proposed in Galway. Page 5, Risk assessment, line 5 "Experimental studies assess the effects of pollutants by studying human and animal exposure". This implies that humans are experimented upon, which is of course illegal. Humans can be investigated, however. This elementary mistake, in not being able to distinguish between an experiment and an investigation, signals that this report was not written by an experimental scientist. Page 5, Risk assessment, line 9. "There is a paucity of epidemiological studies concerning health ...". The comments above about rare and common diseases are relevant. However, there are a number of studies extant which indicate the human health consequences of dioxin exposure. The IARC has now classified 2,3,7,8 TCDD as a Class 1 human carcinogen. The USEPA reappraisal of dioxin indicates that up to 11% of cancers may be attributable to dioxin exposure. The Dutch breast-milk studies also show the effects of dioxin. In the Seveso cohort, there is a significant reduction of the proportion of males born into the population. Page 8 Dioxin levels in Ireland, para 2. "in Ireland appear to be low" (wrt dioxin levels). This appears to be being put forward as an argument for increasing pollution levels! If, by chance, Ireland appears to have avoided the mistakes that have been made in the rest of Europe, then that is something to be protected and maintained. As the health effects of dioxins become more evident month by month, there will be an increasing premium put on uncontaminated foods. As dioxin and heavy metal pollution seem to be one-way tickets, policy makers should consider whether they want to embrace such a technology as waste incineration which has such a bad track record, and is in my opinion inherently hazardous. Dr Vyvyan Howard <!-- HTML Markup endspan --> </td> </tr> </table> <a name=bottom></a> </body> </html>