Health and environmental impact assessment: an integrated approach
May 1998
Recommendations
National policies for environmental and health impact assessment
1 The UK Town and Country Planning Regulations, and the guidance issued by the Department of the Environment, Transport and the Regions (DETR), and by the Highways Agency, should be amended to include an explicit and formal requirement for an assessment of the potential impacts on human health of all proposed developments requiring an environmental impact assessment (EIA) for planning purposes. No EIA should be deemed to be adequate unless it shows evidence that possible implications for occupational and public health have been properly addressed. March 1999 should be set as the target for the introduction of this requirement, in order to coincide with the deadline for implementation of EIA Directive 97/11/EC within the UK. There has been a failure explicitly to include human health as a component of all EIAs and this has created problems with the promotion of health impact assessment (HIA), which ought to play a more prominent role in safeguarding health in the development planning process both at a national, regional and local level. The present situation, whereby HIAs are treated separately, if at all, rather than as an integral part of EIAs is unsustainable. HIA should be considered as an integral component of the EIA process, rather than as a separate and parallel activity, because of the importance of developing an integrated approach to health and the environment.
2 The Department of the Environment, Transport and the Regions and the Department of Health must ensure that strategic environmental assessment (SEA) including specific provision for the assessment of impacts on human health is carried out for all public policies, programmes and plans which have implications for the environment and human health. For example, environmental policies such as those relating to transport or air quality, and social and economic policies, such as VAT on domestic fuel, will fall under this provision. A draft EC Directive on SEA is currently being considered which, if adopted, should enable the consideration of impacts on the environment, health and social well-being to be achieved in a more holistic way. The draft SEA Directive presently focuses on assessment of the cumulative impacts of numerous individual projects which are undertaken as part of a larger scale plan or programme. However, it also provides an opportunity to introduce mechanisms to assess the health and environmental impact of all future public policy.
3 The Government's new strategy for the nation's health, Our Healthier Nation, should address explicitly the influences of environmental conditions on human health, together with an overall comprehensive strategy for impact assessment. The document commits the Government to undertake health impact assessment of relevant key policies, but gives no criteria for deciding relevance, nor does it propose a strategy for implementation.
4 The Environment Agency must adopt a fully integrated approach in all its activities which acknowledges the relationship between the health of the environment and the health of the population. To do this, the Agency should appoint a medical officer at each regional level with specific responsibilities for the human health aspects of environmental quality. The majority of the Agency's functions with regard to the protection of the environment ultimately have an impact upon health and it is often the impact upon human health that determines the setting of standards and actions required with regard to the environment. The Agency should contribute to the development of an integrated environmental and health impact assessment methodology, and provide guidance on environmental health monitoring and assessment techniques. The Agency's work in assessing the impacts of pollution, and carrying out environmental assessments of new and existing chemicals, should provide valuable data for health and environmental impact assessments. The Chemical Release Inventory could also provide an effective monitoring, surveillance and analytical tool for those with an interest in environmental and public health.
5 The Department of the Environment, Transport and the Regions and the Department of Health must ensure that the development of an integrated environmental health impact assessment process is included as part of the UK's National Environmental Health Action Plan (NEHAP). NEHAP should be rewritten to include specific mechanisms by which environmental health issues can be addressed as part of the planning authorisation process and at the strategic level of policy appraisal.
6 Communication between professionals in the health care sector and those concerned with environmental protection and regulation needs to be improved. The Minister for Public Health, Chief Medical Officer and other senior officials, such as the Chief Scientific Officer, and the Environment Minister (as Chairman of the 'Green Ministers' Group') should participate in initiatives to ensure improved communication and consultation between all the agencies concerned with human health and the environment; this could include establishing a formal consultative committee. Such a committee must maintain close links with the Sustainable Development Unit which has been introduced to support all Departments in assessing the potential environmental impacts of new Government policy proposals. One important new initiative to strengthen communication in this area would be for the Annual Report from the Chief Medical Officer to include a specific section on the conduct and continuing methodological development of health impact assessments.
Research
7 A systematic and comprehensive programme of research is required to develop the methodologies with which HIA can be conducted. A consortium should be established to fund, commission and direct that research. The membership of that consortium should include the Department of the Environment, Transport and the Regions, the Department of Health, the Natural Environment Research Council, the Medical Research Council, the Biotechnology and Biological Sciences Research Council, the Economic and Social Research Council, the Environment Agency and the Royal Commission on Environmental Pollution.
8 The present situation whereby no groups of researchers in the UK are funded specifically to undertake research into health impact assessment must be urgently addressed. The programme of work should be conducted by research teams comprising a diverse range of specialists including health economists and those from the natural, medical and social sciences.
9 A structure for strategic and project-level health impact assessment methodologies should be developed. This should begin at the strategic policy level. The structured approach developed at this level should then be retained in developing project-level methodologies, taking account of the practical levels of information available at the different levels.
10 A systematic review of the health hazards associated with a series of programmes, policies and projects in each sector should be carried out to assess their health risks. A comprehensive checklist should then be produced to guide developers and planning authorities. Hazards both directly and indirectly associated with the development should be included in the checklist. The importance of each hazard should be determined according to its frequency and severity. The checklist should also include sociological factors and perceived hazards for which there is little or no evidence, but high public concern. Such a checklist if used as part of the EIA process would enhance the predictive power of further health impact assessments.
11 There should be an ongoing case study analysis of current and future HIAs in order to identify good practice. Information gained will assist the continuing development of HIA methodology, help to define concepts, and provide models for future health impact assessments to follow. Such studies could usefully include a systematic review of UK planning applications to determine the extent to which human health is being addressed within the planning process, but also to clarify the relationship between planning procedures, inquiries and the conduct of HIAs within the EIA process. This work would help to define the boundaries within which a health impact assessment should be carried out.
12 There is an urgent need for much more epidemiological surveillance both of occupationally exposed groups and of the general population. The case for more systematic epidemiology starting from, but extending beyond, occupational settings has repeatedly been emphasised by the BMA. Occupational settings have the methodological advantage that people are often exposed in the course of their employment to relatively high concentrations of potentially hazardous materials and activities, and for relatively long periods of time. Consequently, a thorough scrutiny of occupational settings can provide early warning signs of hazards to which the broader population may in due course also be exposed. Occupational and general epidemiology will therefore be important both for the conduct of HIAs and for research into ways of improving the methodologies of HIAs by providing baseline data sets against which the impact of proposed changes may be assessed. Laboratory and bench research is also required, with particular consideration given to:
- the development of new markers for monitoring and surveillance of health impact;
- improved estimates of exposure both for individuals and populations;
- better methods for extrapolating risk to populations, together with the ecological basis for risk assessment;
- exposure to, and effects of, mixtures of chemicals.
13 The screening criteria used for determining when a project requires an EIA, as set out in the UK Town and Country Planning Regulations, and contained within the guidance issued by the Department of the Environment, Transport and the Regions, and by the Highways Agency, should be revised so that potentially significant impacts on human health are included more explicitly. Only limited guidance is available on different project types and locations and, in practice, there has been considerable inconsistency in determining the eligibility of Schedule 2 projects for EIA. The lack of inclusion of health hazards and risks within the project screening process can contribute to failure of the planning authorities to require the assessment of health impacts for a proposal. Explicit reference to the need to screen projects for potential risks to human health would mean that the discretion currently exercised by local planning authorities will become more carefully circumscribed.
14 'Scoping' should become a legal, mandatory requirement for all UK EIAs and HIAs. Scoping procedures are used to determine the range of issues which should be addressed in the EIA and to identify those issues which are potentially adversely affected by the development and should therefore be studied in detail. Scoping also benefits developers, because careful scoping reduces unnecessary expenditures on research into issues which are not particularly relevant to decision-making, thus enabling resources to be allocated most effectively.
15 Health should always be one of the issues to be included within the scoping stage of an EIA. If health is to be adequately addressed, the potential health hazards of a project must be systematically and comprehensively identified at the scoping stage and a detailed list drawn up so that these may be adequately investigated. There is currently no comprehensive check list of the human health hazards that could be consulted during the scoping process. However, the BMA has proposed five working categories for health hazard identification: communicable disease; non-communicable disease; inappropriate nutrition; injury and mental disorder. Other categories may be added, such as special hazards to the developing foetus and children, or categories for indirect impacts on health such as those arising from social impacts. Information about health hazards is at present incomplete but current sources include reviews of similar projects elsewhere, opinions of specialists, the public and other stakeholders, published literature reviews identifying known health hazards within each sector, maps and local and national health data. In addition, lessons can be learned from bad scoping examples, such as EIAs of reservoir projects which have, for example, focused in a limited way on water-borne diseases without taking account of other potential health impacts that can be associated with such developments.
16 The draft terms of reference for the consultant who will carry out the environmental and health impact assessments should be made available for public comment as part of the early consultation process. This may also include review by the developer, relevant competent authority, other relevant agencies and authorities, affected parties and interest groups.
17 The terms of reference for conducting an EIA should always specifically indicate how the health risks which may be associated with the project are to be identified and how the consultant should assess these health risks. In addition, the terms of reference should require the consultant to include any other health hazards which may be discovered during the study. The provision of adequate terms of reference is important, since consultants will often only report what is required by their terms of reference. Statutory provision and guidelines on the terms of reference are required to ensure that the following components are addressed by the consultant in preparing the environmental impact statement:
- Identifying potential health hazards according to categories of communicable disease, non-communicable disease, inappropriate nutrition, injury and mental disorders;
- Identifying potentially vulnerable communities and describing why they are vulnerable;
- Identifying the environmental factors responsible for exposure of vulnerable communities to hazards;
- Describing the capacities and capabilities of the many agencies responsible for protecting health in relation to the project and identifying their limitations;
- Reaching a conclusion based on the above regarding the change in health risk reasonably attributable to the project ranked at least as a trend of increasing/decreasing or no change;
- Recommending health safeguards and mitigation measures in sufficient detail to be given serious consideration, including outline costs.
19 Local authorities should work jointly with health authorities to appoint statutory consultees with appropriate expertise in health-related issues to participate in environmental and health impact assessments. Within five years, all Health Authorities should appoint a consultant in public health medicine with expertise in environmental issues who would have a specific role as statutory consultee in the environmental and health impact assessment processes. Occupational health physicians and consultants in communicable disease control should also act as statutory consultees in relation to risks to occupational health and communicable disease transmission. Regular and effective consultation must also take place with environmental health officers and others eg, local directors of public health, to ensure effective integration of HIA. Greater resources may be needed to enable environmental health officers to contribute to the environment and health impact assessment process. Under the present system, local planning officials are expected to consult with the Health and Safety Executive in circumstances where a proposed development involves “manufacture, processing and storage of hazardous substances." The Environment Agency is a statutory consultee in circumstances where a proposal involves “works specified in Schedule 1 to the Health and Safety (Emissions to the Atmosphere) Regulations 1983”. However, such consultations may not always take place. In addition, there is no statutory consultee for developments involving other health-related issues, thus increasing the risk of their omission from the EIA process.
20 Health and social welfare specialists should be represented on specially convened panels which are set up to appraise environmental impact statements (EIS), once they have been prepared and submitted by the consultant to the competent authority. Currently, the local Directors of Public Health, public health physicians and environmental health officers may have a role to play in appraising the EIS. Consideration should be given to developing a specialty within public health related to environmental issues, which would strengthen links between toxicologists, epidemiologists and planning authorities with regard to the appraisal and subsequent management of health risks. Occupational health physicians may also be able to provide a valuable source of expertise on appraisal panels to address the health risks from industrial developments. This would facilitate the integration of environmental and health input at the appraisal stage.
21 Developers should make specific provision for mitigation measures to avoid, remedy or reduce any significant adverse impacts associated with the project, especially those with potentially significant impacts on environmental quality, occupational or public health. The subsequent performance of those measures should then be monitored by the developer, and this monitoring reviewed as part of a follow-on assessment, after an appropriate period, eg 5 years. This would determine the effectiveness of the mitigation measures, and provide information for future projects.
22 Local authorities should use planning conditions to ensure that adequate mitigation measures are undertaken by the developer, and should specify that developers earmark specific resources to ensure that concurrent and post-project environmental monitoring and epidemiological surveillance take place. The results of such monitoring and surveillance should be published. At present there is no formal requirement for monitoring of the impacts attributable to the project, or the subsequent effectiveness of mitigation measures, once development consent has been granted. Such monitoring and surveillance would enable the local authority to establish whether the proposed mitigation measures had been effective, and identify any previously unforeseen risks or benefits associated with the project.
23 The Department of the Environment, Transport and the Regions in collaboration with the Department of Health should review the practice and conduct of EIA and HIA, together with the outcome of any mitigation measures and 5-yearly follow-on assessments in order to establish and disseminate guidelines on best practice. The information gained from such a review should be used to improve the design, methodology and conduct of future environmental and health impact assessments and to circulate guidance on the effectiveness of mitigation measures based on past experience. In 1997 the DETR published the results of a study which showed that the treatment of mitigation within a sample of 100 EIAs was mostly only fair, with a third of the statements rating poor or worse.
Decision-making
24 Wherever possible, decisions regarding the environment and health should be evidence-based. However, given the lack of adequate empirical data, and the need to await further research results, the BMA believes that in conducting EIAs and HIAs, and in interpreting the results, a precautionary approach should always be taken. Local authority planning officials should exercise their discretion to request further studies and more data, but in conditions where ignorance and uncertainty prevail they should err on the side of caution and safety rather than expose the environment and public health to indeterminate risks and hazards.
25 When an EIA or HIA is completed, the subsequent report should always include a summary in non-technical language to enable members of the general public to gain an appreciation of the issues involved and the conclusions reached. This should improve the accessibility of information for the public.
Policies for the corporate sector
26 The Department of Trade and Industry, the Department of the Environment, Transport and the Regions, as well as trade organisations, should consider how national and international quality assurance standards such as ISO 9000, ISO 14000, and BS7750 can be applied more formally to the impact assessment process in the UK. Such standards provide methods for assessing the capability of project proponents to protect human health as part of their proposed development plans. Commercial organisations can contribute to the improvement of environmental conditions and public health, to some extent, by requiring that they, and their suppliers of both goods and services including environmental consultants, should act in accordance with national and international quality assurance standards such as ISO 9000, ISO 14000, and BS7750. All businesses, including small and medium size firms, can help protect the environment and human health through waste reduction and recycling, solvent management and the cost effective use of raw materials.
27 Businesses should be provided with continuing and extended support to enable them to minimise the environmental and health impacts of their activities. They may well benefit from the kind of help that is provided, for example, by the Environmental Technology Best Practice Programme which offers advice on environmental management tools, such as monitoring, and life-cycle assessment.
Education and training
28 Universities and training providers should ensure that the design and conduct of EIAs and HIAs are comprehensively addressed in the relevant educational courses. The results of the research which we are proposing should serve both to improve the design and conduct of EIAs and HIAs, but also contribute to improving the education and training of the relevant professionals in health care, environmental health officers and planning officials.
29 It is recommended that the syllabus for undergraduate medical education in the UK should include a significant element of education in toxicology and environmental health, and that the theme of public health medicine and occupational medicine should figure prominently in the undergraduate curriculum of medical students. These changes are already underway, but need to be developed, particularly to encompass health promotion and illness prevention, and the assessment and targeting of population needs as well as awareness of environmental and social factors in disease, in accordance with the recommendations of the General Medical Council report, Tomorrow's Doctors. This theme within the syllabus should also include an awareness of the methodology for, and interpretation of, health impact assessments.
30 Postgraduate education and training courses on environmental and health impact assessments should be provided for a broad range of professionals. Such courses should be available to all doctors, but especially public health physicians and local directors of public health who may be required to act as expert statutory consultees for health-related issues to be addressed by a health impact assessment. Public health physicians, in particular, should have a familiarity with the essential steps in the assessment of risk, and they should receive training, including continuing education in all specialties related to environmental toxicology and environmental health. Other relevant groups include local authority planning officers, those employed by the regulatory and enforcement agencies, such as the HSE, environmental health officers, occupational health physicians and public health officers who are likely to be required to give expert advice on health impact assessment to development consultants. Intensive short courses (eg for 1-2 weeks) should be available, which could be taken by a wide range of professionals and trainees as part of continuing professional development programmes. The results of the research into environmental and health impact assessment should contribute to improving such education and training programmes.