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Letter by Dr. Philip Michael to all thirty-three members of the Southern Health Board on behalf of IDEA - Irish Doctors Environmental Association

Dear Mr O'Keefe,

Incineration poses unacceptable risks to both the health of the people of Carrigaline, and the wider community, both now and in the future.

Specifically, there are concerns in relation to;

(i) the emission of particulate fine matter, in the size range 2.5 microns from incinerators.

These are very small particles, which travel far down the lungs, to the alveoli, where they interfere with oxygen/blood exchange. The United States Environmental Protection Agency has outlined the problems associated with these particles, namely, that when inhaled, they are closely associated with adverse health effects such as increased hospital admissions and emergency room visits, for heart and lung disease, increased respiratory disease, asthma, decreased lung function, and premature death. Sensitive groups that appear to be at greatest risk to these effects include the elderly, individuals with cardiopulmonary disease such as asthma, and children (1).

These small particles can also carry small particles heavy metals and other toxins down very deeply into the lungs. As far back as 1997, the US EPA added two new PM-2.5 standards, set at 15 micrograms per cubic meter and 65 g/m3, respectively, for the annual and 24-hour standards. Furthermore WHO recently adopted a recommendation to use fine particulate matter 2.5 as an indicator for pollution induced health effects(2).

We have no guidelines in Ireland for the regulation of these particles, and the issue was not addressed in the Health Research Board's report, and current technology permits only a small proportion of these incineration particles to be filtered from the stack emissions.

(ii)  the emission of varied chemicals, which will be emitted from the stack. Essential prerequisites for risk assessments of emissions from waste incineration are, actual, continual and comprehensive qualitative and quantitative analytical knowledge of the composition of emissions;  region-specific meteorological dispersion models of the emissions particulate; and evaluation of the complex mixtures in emissions for their kinetics in and toxicity for ecosystems and humans (3). None of these criteria has so far been fulfilled. In particular, incineration greatly enhances the mobility and bioavailability of toxic metals present in municipal waste incineration (4).

There are no formal air quality guidelines for many chemicals, of which we known little. The European Environment Agency has said that there is insufficient evidence for 75% of the 100,000 chemicals in widespread industrial use on the European Market. Many of these chemicals end up being incinerated in various consumer products or are otherwise released into the environment.  Heating unknown mixtures of different chemicals often produces novel or unwanted compounds many of which are known to be  persistent, bioaccumulative and toxic. There may well be a long latency period before any of these adverse effects are seen - years or even decades.

One of these chemical groups are dioxins. Children exposed to dioxins, during critical periods of development, while still in the womb, appear to be the most sensitive and vulnerable to these very persistant fat-soluble chemicals, which have  been classed as carcinogens. We know that these substances are already widely dispersed in the global environment due to industrial activity over the last one hundred and fifty years, in many areas at background levels known to cause human health effects.  It is also of significance that the protective blood brain barrier is not fully developed in babies until they are approximately six months old. This has serious implications for the health of unborn children and young babies, as many of these chemicals, including dioxins, are fat soluble, and the brain is largely composed of fatty compounds. A recent Belgian study found that continuous monitoring, as opposed to the usual intermittent method, underestimated dioxin releases by between 30 and 50 times.

The recent Health Research Board report states, 'incineration is associated with respiratory morbidity'.  ..... 'further research, using reliable estimates of exposure, over long periods of time, is required to determine whether living near landfill sites or incinerators increases the risk of developing cancer'.   The Health Research Board's report further states that 'Irish health information systems cannot support routine monitoring of the health of people living near waste sites'.

It is important to realise that 'controlling' emissions to air via the stack by various technologies does not eliminate these chemicals, they still end up environment, albeit in another form.

If we cannot say that incineration is safe and furthermore, that we have no way of monitoring any ill-effects, then surely, we should not use this method of waste management. Lack of evidence of adverse health effects from 'new' incinerators should not be taken to mean that there are no adverse health effects from them. Modern does not mean safe.

As medical practitioners we will be the first to witness the health impact of this proposal.  It is our responsibility both to our present and future patients to voice our very serious concerns and complete opposition to this proposal.  Furthermore, we believe that the Health Board will be failing in their statutory duty if they do not take a strong public stance on this issue.

Yours Sincerely,

Dr Philip Michael
PRO Irish Doctors Environmental Association (IDEA)
Millbrook Med Centre, Bandon, Co Cork  Tel 023 41132

(1) United States EPA website 9th April 2002

(2) WHO Regional Office for Europe website 17-1-2003

(3) Gesundheitswesen 1995 Jan;57(1):26-35 Public health risk caused by emissions from refuse incinerators] Wassermann O, Kruse H.

(4) Risk Anal 1988 Sep;8(3):343-55 Risks of municipal solid waste incineration: an environmental perspective. Denison RA, Silbergeld EK.


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