Prof. Hedley comments on the Govt’s pending Air Quality Objectives (AQO) review
We encourage you to take the time to read this (believe it or not) abbreviated version of Professor Anthony Hedley’s submission to the Government’s official AQO questionnaire. You can also download the full version here. If you want to read the official Government AQO document and questionnaire, you can find it here.
Professor Anthony Hedley is one of the world’s leading experts on the health impacts of air pollution and chairs the Department of Community Medicine at Hong Kong University.
The kernel of Hedley’s submission is summed up neatly by the following statements (taken from his submission):
- The government [AQO] document is misleading, disingenuous and lacks transparency and does not provide the public with an unbiased assessment of the choices which it is being asked to make.
- The term “with reference to the [WHO] guidelines & etc” is a mechanism for pretending that our new AQOs are based on the collective global scientific evidence which underpin the AQGs, without actually having to adopt them and then deal with the vested interests that would have to clean up transportation, power generation and manufacturing.
- The most salient fact is that there is probably no other country or region with a comparable level of social, economic and technical development which has allowed a comparable level of poor air quality to develop without taking effective counter measures.
- [The] proposals for emission controls are vague, lack fail-safe implementation methods and timescales.
As if those statements were not damning enough, read on. Those were just the tip of the iceberg –
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The government [AQO] document is misleading, disingenuous and lacks transparency and does not provide the public with an unbiased assessment of the choices which it is being asked to make.
Revision of the AQOs is necessary but not sufficient: the need for a professional Environmental Protection Department
Why has this professional arm of government lost its most senior professional posts?… Legco and the public need and deserve an intellectually valid and professional analysis of our environmental status and management choices.
CAN: “CAN WE ENVISAGE A SITUATION WHERE THE DIRECTOR OF HEALTH IS AN ADMINISTRATIVE OFFICER WITH NO MEDICAL OR HEALTH QUALIFICATIONS? I WOULD HOPE NOT, BUT THAT IS EFFECTIVELY WHAT WE HAVE NOW IN ENVIRONMENTAL PROTECTION,” PROFESSOR HEDLEY RECENTLY POINTED OUT IN A SPEECH ABOUT CHILD HEALTH TO THE EARLY CHILDHOOD DEVELOPMENT RESEARCH FOUNDATION.
There is no public health report in either of the annual departmental statements by the Director of Environmental Protection or the Director of Health, which explicitly documents the attributable harm to health and the burden on health services resulting from air pollution in each year.
CAN: SINCE THE 1990s THE GOVERNMENT HAS NOT FUNDED EPIDEMIOLOGICAL STUDIES OF THE HEALTH IMPACTS OF AIR POLLUTION, RELYING HEAVILY ON PRIVATELY FUNDED RESEARCH AND SCIENCE BY HONG KONG’S PUBLIC HEALTH ACADEMICS.
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The bad health outcomes of air pollution which include impaired lung function in young children, an epidemic of respiratory symptoms in both children and adults, increased doctor visits, hospital admissions and deaths from heart and lung disease and strokes should be presented in a way which emphasises that they are avoidable through competent management of the environment. This should be the explicit and plainly worded starting point of the consultation rather than bureaucratic statements from administrative officers.
CAN: A SQUARE ADMISSION OF THE MAGNITUDE OF THE PROBLEM WOULD HAVE ENABLED THE GOVERNMENT TO MORE EASILY SELL ITS CLEAN-UP MEASURES. IT WAS PRECISELY THIS POSITIONING WHICH ENABLED PREVIOUS MAYOR OF LONDON, KEN LIVINGSTONE, TO GET ON WITH HIS AIR CLEAN-UP PROGRAM.
In addition to any revision of our air quality standards a detailed annual accountability report should from now on be produced jointly by the EPD and DH to demonstrate the extent to which the government is effectively addressing this regional environmental disaster. These reports should be subject to independent external audit.
Did we need an outside consultant to modify the AQOs?
The consultants have no track record in this field of environmental and public health and the consultancy has contributed nothing new to our knowledge and other insights as to the solution of this serious hazard to the well being of the Hong Kong population. We have not yet seen from the consultant or government any comprehensive assessment of the health impacts of the proposed new AQOs…I am concerned that the consultancy and the proposed AQOs will apparently be used as a new instrument for procrastination without proper regard for the continuing medical and health impacts on our community.
Q2. Do you agree that the AQOs should be set with reference to the guidelines and interim targets (ITs) published by the World Health Organisation and that a staged approach be adopted to update the AQOs with a view to achieving the WHO Air Quality Guidelines (AQGs) as a long term goal?
The term “with reference to the guidelines & etc” is a mechanism for pretending that our new AQOs are based on the collective global scientific evidence which underpin the AQGs, without actually having to adopt them and then deal with the vested interests that would have to clean up transportation, power generation and manufacturing.
The term “a staged approach” almost certainly means that once the new but unsatisfactory AQOs are enshrined in the Air Pollution Control Ordinance the government will have total control over compliance and timescales and any leverage for accountably by the public will be reduced or lost.
The government’s phrase “long term goal” is particularly threatening to public health. This is a euphemistic way of the government saying that population health, including the future life-time health of children can and will be traded off in favour of other interests over an indeterminate period.
It must be remembered that although the full WHO AQGs are single limit values there is no suggestion that they demarcate the boundary between safe and unsafe air. Adverse health effects have already been demonstrated at levels well below the AQGs. These values can only be regarded as a maximum acceptable level of pollutants and even lower levels should be regarded as desirable targets.
The government should cease to emphasise, as one of its justifications for procrastination and as a distraction to the public, that “no country in the world (has adopted) the WHO AQGs in their entirety as legal standards”. We need to recognise that we are not dealing with other jurisdictions; we are, or should be, trying to address an environmental disaster here in Hong Kong. The most salient fact is that there is probably no other country or region with a comparable level of social, economic and technical development which has allowed a comparable level of poor air quality to develop without taking effective counter measures.
[The WHO’s] relatively permissive statements on levels and timescales of pollution abatement are designed to accommodate poor marginalised territories which would not have a hope of implementing the full AQGs in the near term. However for the HKSAR government to use this particular terminology … amounts to a shameful solecism. In particular it is not a public health approach.
In its approach to defining the new proposed AQOs the consultant and the government have not adequately addressed the issue of exposure reduction. A major obstacle to this is the very high level of roadside pollution across urban Hong Kong…Pollution abatement at the roadside is well within government control on a short timescale, given the necessary political will. The implementation of transport emission controls has taken far too long, is based on volunteerism and fails to take a comprehensive approach to identified problems. Until the government takes charge of this situation and ensures that effective mandatory measures are fully complied with we will continue to have dangerously high roadside pollution in Hong Kong. We have shown that this affects at least half the population on a daily basis and the exposure prevalence is probably very much higher.
Q4. Do you agree to the proposed new AQOs which have been set with reference to a combination of WHO AQGs and ITs?
The problem is that the government proposes that a variable number of “exceedances” should be permitted. These violations of the AQO (or supposed WHO criteria) have been informally argued by government officials as “unimportant”. This in turn raises the question as to why they are considered by government to be necessary.
In this respect the government’s report must be regarded as a major deception in terms of its misrepresentation of the WHO IT and AQG. Table 5 of the government consultation report makes no mention whatever of the introduction of exceedances. This arbitrary modification of the WHO Guidelines may (and probably will) have a profound effect on the degradation of air quality and the health effects which result from it. The proposed AQOs cannot in any sense be legitimately described as “benchmarked” to the WHO recommendations.
The process by which the consultants and government came to contrive this modification of the WHO guidelines should be fully externalised and examined in detail because it appears to indicate that government is seeking to establish Objectives which can accommodate the present highly polluted environment rather than remove it.
Q5. Do you agree that a mechanism should be put in place to regularly review the AQOs no less than every five years?
The regional health hazard of pollution should be the subject of continuous and detailed monitoring and appraisal. An annual report (jointly between the EPD and DH and other expert groups) … is necessary to maintain the required high profile of this problem and the priority which it demands. No argument is presented by government to support the suggestion of a five year interval. Government reviews can be notoriously prolonged and the post review period of assessment adds to the timescale. A five year review could easily lead to seven year intervals between any possible action on failing strategies.
Q6. To what extent do you agree that the proposed emission control measures should be implemented for achieving the new AQOs and improving air quality in general? What other measures do you think the government should consider?
We need urgent mandatory action on all of these.
We need a radical change of outlook here. For example the previously mentioned problem of volunteerism must be addressed. Polluters are harming others and rigorous control is part of the government’s duty of care. The costs of subsidies should be set against the ongoing community costs of pollution induced health problems and lost productivity, now and in the future… [The] proposals for emission controls are vague, lack fail-safe implementation methods and timescales.
Q7. How soon do you think these proposed emission control measures should be implemented?
There is no justification for any continuing delay on this matter and it stands as a litmus test of the government’s commitment to protect public health. In particular the government’s failure to sell the idea of conversion to higher Euro specifications for commercial vehicles must be fully resolved within the next 12 months. If we cannot achieve a cleanup of the commercial trucking industry, given the funds and the technology, then air quality strategies in general are doomed to fail. The Chief Executive promised a 4 year programme in 1999. Why is the government still asking the public how soon they want the damage to heart and lungs to cease?
Q8. Are you willing to bear the costs arising from the implementation of the proposed emission control measures, such as higher electricity tariff and bus fares, as well as adjustments in your way of living?
This question should have been put clearly in the context of the community burden arising from our current direct, indirect and intangible costs associated with illness, health care, lost time at school and work, loss of quality adjusted life years and premature deaths. At present that amounts very conservatively to about $20 billion a year. In that sense we are living well beyond our means to the detriment of mainly the most vulnerable and deprived members of the community who experience the worst effects of pollution including higher mortality. Given the enormous social inequity created by pollution there are good arguments for funding the investment and ongoing costs from existing government revenue.
There are many unanswered questions about the methods used to discount the costs and benefits in the consultant’s report. In particular, have they discounted future health benefits for children?
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