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HRB Submission from Irish Doctors' Environmental Association

This study is limited by a number of factors and indirect influences, which when made public will leave it open to be used by the political lobby and corporate companies that seek to reduce Ireland’s ability to manage its waste appropriately, sustainable and in a safe way.


The study of the effects on public health and the environment of landfill and thermal treatment of waste in Ireland are funded by the minister of the environment and local government, commissioned by the Health Research Board and carried out by the Department of Public Health Medicine and Epidemiology. All interested parties about are linked to one another and depend on the good will of the government to operate successfully.


The level of funding allocated which is reported to be 50,000 old punts is not an adequate sum to deal with the large remit of investigating even one of the two issues outlined as the study’s main concern. A single academic Masters or PhD carried out by one single person would require a similar amount so a major study that is suppose to be looking at a nation issue is under-funded. If the government expect a full analysis from this funding then it would be apparent the associated links are been used to push this research group for a report that would have a bias and a bias that would suit the government’s interest

The fact that the government provides the initial funding and is the ultimate taskmaster of health research board and third level institutions, as well as having an already bias view of the waste industry means there is direct and indirect influence cal pressure on this work to report in a way to suit the government.

The Title

The assumption which under minds anything that this study may say is that there is no choice in this matter, landfill or thermal treatment take it or leave it. Where a title highlight this choice it shows a clear indication that while there may be a number of objectives in the study to look at other alternatives to landfill and thermal treatment, there is no real intention or aim of the study to take serious or report on the influential factors that alternatives may have. The title is explicated in that it seeks to under mind aspects of the study that may not be help the country’s current bias waste strategy.

Where the context of the whole study is in Ireland according to the title this allows the researchers to ignore or exclude aspects and issues outside of Ireland that may be of great and relevant importance and signifience to the whole debate.

The idea of this study is inappropriate and gives false assumptions that something new is to be found in the research. This is a review not a study where no new phenomena will be explored. The study proposed will indicate or explore what may happen in Ireland if thermal treatment is allowed to be used to deal with our waste. Currently as the number of illegal dumps are found throughout Ireland, there is no chance for this review to know, analysis or discuss the effect of landfill within the Irish context and the study will be outdated before it is produced.


This study should be reliable in that it will have findings that are similar to the review of a recent study in Great Britain and its results should mirror the view found in that study. The current view from that study is that landfill and thermal treatment are dangerous; a risk to human health while the principle of recycling is the safe to human health and has the lowest risk value in dealing with waste.


The validity of this review is nil as there are no real measurement used within the review to measure the effects of landfill within Ireland where the numbers and the extent of landfills in Ireland is at present and at the time of this review uncertain. There are no thermal treatment facilities for municipal waste in Ireland so this cannot be measured.

Objectives of the study

Objective a) a literature review of the effects of landfill and thermal treatment of waste

The objective of a literature review of the effects of landfill and thermal treatment of waste fail to take any other alternative into account and fail to specific about the kind of effect that will be looked at. A loop to allow the researcher to review what they want and to fulfill a narrow focus in that they only view two ways to treat waste

Objective b) a study of the knowledge and attitudes of service providers and members of the public to waste management options

A study of the knowledge and attitudes of service providers given the current illegal landfills been recorded daily highlight a covert way Ireland has been managing waste up to now and the review in this area may be of great importance. A study of the knowledge and attitudes of members of the public to waste management options is a subjective aspect that may undo any credibility of this study. In many studies of knowledge and attitudes of people it is necessary to involve a long-term study of a number of years. The aspect of this objective leaves one with the assumption that this will be used for political advantage to support the bias view of the government

Objective c) a comprehensive description of current policy and practice of waste management in Ireland and in selected other countries.

A comprehensive description of current policy and practice of waste management in Ireland is a hard task in light of the large number of illegal dumps and the current record of waste, which is unaccounted for in Ireland. With many waste accountable issues requiring criminal investigation it is difficult to see how academic personnel will uncover the facts.

“In selected other countries,” means that many examples of other countries waste management practices and policies can be viewed but many can also be ignored. An important aspect of this review is what is ignored as well as what is reported on.

Objective d) Review of national and international literature on environmental risk assessment.

Clearly this objective will provide us with the answer that the government wants. A comparative risk assessment between landfill and thermal treatment will provide the safer option between the two processes and exclude the risk in relation to waste management in its totality

Objective e) this study will also examine risks posed by similar hazards from other sources and compare risks posed by each, to the environment and public health

Where waste is a dynamic unscientific mixture of chemical and biological substances and compounds one has to ask the question of the sources of similar hazards and compares ion in risk. This objective will meet the need to allow landfill and thermal treatment to be carried out in light of other practices of a completely different nature but with similar hazards and risks. It will sanities the view of waste practice and takes away from analysis of waste practice, their hazards and risk to public health. So because we all drive a car, it gives the government the right to landfill or thermal treat our waste.

Main General Comment

1. The used of qualitative study of service providers, special interest groups and the general public is a study of feelings and emotions, similar to love and marriage.

“The purpose of this aspect of the study is to collect information on perceived risk, actual experience, source of information and attitudes to various aspects of waste management waste management”

In this one sentence the researcher are stating what they want to say and not what is the truth. They want to say that people have only perceived risks, have an unreliable source of information and have a bad attitude towards a proper waste management system so much so that they say waste management twice. This is an unscientific and a fraud in any academic sense given the subjective nature of the review mix of objective material and subjective material. The objective material of landfill and thermal treatment will be covered in the smoke screen of subjective material of perception and attitudes, like love and marriage

Given that the Minister of the environment has already stated that this study will be objective, it is difficult to accept this in light of the submission already made to the researcher

“In addition, the submissions that have already been received by the Department of the environment will be examined”


This study has many flaws but may be the only real Irish study that is to be produced. In this way it may be used as the corner stone for the argument for both thermal treatment and landfill. The flaws of the study could be sum up as

Limited to small funding 50,000
Short time period 4-5 months
Narrow focus of either landfill or thermal treatment
No focus on the safer forms of waste management recycling
No reference to mortality or morbidity similar to English study on thermal treatment
Main focus on perception and attitudes of general public used negatively
Qualitative study not feasible over short period
A literature review not a study
A study open to manipulation
Nothing new is been studied

The Irish Doctors' Environmental Association welcome the interest shown by the researchers into the possible adverse health effects of waste management practices. The matter has been of concern to the organization since it's inception in 1997, and has been the subject of correspondence by the organization, both to the Minister for Health and the Minister for the Environment. We have also raised the issue in the lay and medical press.

With regard to incineration, we will leave aside the illogicality of burning the earth's resources, instead of conserving them for future generations, and the demand that incinerators create for waste.

We would like to make the following 4 points to the researchers.

1)Only a limited number of studies have been carried out to determine whether individuals living near incinerators have been exposed to pollutants, and these have been limited to heavy metals and dioxins. Furthermore, as some of the emissions from incinerators are persistent and bioaccumulative, there may be a long latency period before any adverse health effects are found. We would have concerns that our present health surveillance systems are not sensitive or developed adequately to detect such events.

2)Although it is stated that there will be low levels of dioxins in the emissions to air, this will reflect only what is inhaled. However, these compounds will also be absorbed from the skin, and from foods, often grown elsewhere, thus increasing overall exposure.

3)With reference to dioxins again, current regulations only consider chlorinated dioxins. Mixed chloro and bromo varieties are also released from incinerators in appreciable quantities and appear to have equal toxicological significance. However, there is no obligation to monitor these chemicals. Our association has already been in correspondence with Indaver about this issue.

4) Recently, much concern has been expressed concerning the effects of particulate matter in the size range 2.5 microns on both the respiratory and cardiovascular systems. To our knowledge, only 5-30% of matter of this type is collected by current collecting mechanisms.

Finally, we have five reservations regarding the use of existing regulations:

(a) It is not acceptable to use the concept of 'safe' when discussing carcinogenic substances.
(b) Most environmental standards are based on BATNEEC (Best available technology, not exceeding excessive cost), and not health grounds.
(c) There is no 'standard person, people vary genetically, and by time, from the fetus to old age.
(d) For many substances, no 'safe' guideline exists, and there is huge uncertainty with regard to the effects of many chemical compounds on health.
(e) The accepted method of dispersal of pollutants is dilute and disperse. This does not work with compounds which are lipid soluble; because the body cannot cope with chlorinated hydrocarbons, they therefore accumulate.

Although requested by the European Environmental Bureau, there is no requirement for health related surveillance of incinerators. The Irish Doctors' Environmental Association submits that in the absence of a properly implemented waste management plan, it is wrong to proceed with either plans for an incinerator or landfill. Our association would hope that, in the near future, producing waste that is unrecyclable will be as frowned upon as smoking is today. We would be happy to discuss any aspect of this submission, or any other aspect waste management.

We wish you well with your work.
Best wishes
Elizabeth Cullen
Irish Doctors' Environmental Association

Cork Harbour Alliance for a Safe Environment
Bishop's Road, Cobh, Co. Cork
Tel - 021 481 5564      Email -
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