Dr Thompson's response to the DEFRA report

A Review of Environmental and Health Effects of Waste Management

This report on waste management was published in May 2004. Many believe its purpose is to give a green light to the government’s plan to build large numbers of incinerators around the country. This work, particularly the extended summary, has more of the feel of a promotional document than a scientific work. It ignores most of the public’s concerns over the safety of incinerators. The quality of the science is poor and the report is already out of date. It does not consider important new, safer technologies such as plasma gasification. Here we look at the contents of the report.

An obvious criticism of this report is that it was written by a waste management company, Enviros, who have everything to gain from an increase in incineration. This is equivalent to asking Monsanto to write a report on genetically modified food or the mafia to write a report on crime prevention. There is no excuse for allowing a vested interest to write such a major report and as such it lacks credibility.

Much has been made, by the waste industry, of the endorsement of the report by the Royal Society. In fact the Royal Society stressed the inherent uncertainties in the report, particularly regarding health effects. They point out that a more cautious approach should have been used and that inadequate data had been used in a quantitative framework.
They state that the relevance to decision-making by Local Authorities is limited because of the need to take into account the local environment and health problems. This is highly relevant in Slough which has the highest mortality rate in the South-East and already has high levels of pollution.
They state that the report is potentially misleading both for national policy and for local authorities. It states that the report gives an apparently reassuring estimate of the impact of different waste management options, including incineration, when in fact it does not present a complete or sufficiently critical summary of the evidence.
As we shall see these criticisms are fully justified. The report contains glaring inaccuracies, omissions of highly relevant data and it’s at odds with other relevant reports on incineration.

OMISSIONS

1) The report fails to acknowledge that children will suffer disproportionately from the resultant pollution

It is now beyond dispute that the maximum impact of pollution is on children. Recent books such as Generations at Risk (1) and Silent Scourge (2), plus major scientific reviews such as “In Harms Way: Toxic threats to Child Development” by the Greater Boston Physicians for Social Responsibility (3) and the recent document Compromising Children: Chemical Impacts on Children’s Intelligence and Behaviour by the World Wildlife Fund (4) have all confirmed that children are at considerably higher risk from pollution. These reports have provided a vast amount of scientific evidence highlighting this danger. As science has advanced, it has become apparent that toxicity to a range of substances occurs at much lower levels than previously believed. These toxic exposures produce a wide variety of problems including impairments of attention, memory, learning intelligence and social behaviour (3).
Legislation such as the Food Quality Protection Act in the USA has already accepted that children and infants are far more vulnerable to toxins (5). The foetus is uniquely susceptible. The recent WHO report has found that between 1.8 and 6.4% of all deaths in children up to 4 are due to fine particulates and 1.4% disability adjusted life years in this age group are due to poisoning by lead (6). These are just two of the substances emitted by incinerators. To deliberately and knowingly expose this vulnerable group, who deserve and need our protection, to this unnecessary risk from incineration, when safe alternatives are available, is both unacceptable and immoral.

2) There is no realistic attempt to calculate the health costs

The cost of incineration to society is huge if you include the health costs. The European Commission estimated that the health and environmental costs of a 400,000 tonne a year incinerator would be between £9 and £57 million per year. To expect the local taxpayers to not only pay this bill but to be exposed additionally to the frightening health risks is a gross injustice.
This figure may well be an underestimate of the true costs. An expert committee convened by the US National Academy of Sciences in July 2000 estimated that 3% of all developmental disorders in children in the USA were a direct consequence of toxic environmental exposures and that another 25% are the result of an interaction between environmental factors and individual children’s susceptibility (6). When we consider that the lifetime cost of a single case of autism has been estimated at £12.4 million and the cost of mental retardation, autism and cerebral palsy due to toxic chemicals has been estimated at £1 billion pounds annually in the UK (4), it is easy to see how incredibly expensive it is to pollute the atmosphere. The human costs are even greater and truly tragic.
In addition the US Environmental Protection Agency has found that strict control of air pollution has saved between $120 and 192 billion dollars over the last 10 years (see below)
It is important to realise that this pollution is unnecessary. Plasma gasification produces zero pollution to air and in the long –term is no more expensive than incineration. The only justification for incineration appears to be that it is cheaper for the waste industry, and even then, only in the short-term.
The implication of this report is that the financial needs of the waste industry outweigh all considerations of public health. Again this is grossly unjust and could be financially ruinous for the NHS who will pick up the bill for an increase in incinerators. This runs completely counter to the principle of the polluter pays.

3) The most important study of incineration ever done never even gets a mention

The study of the incinerator at Sint Niklaas is the only long-term study of an incinerator. It was funded by the Belgian government and carried out under the supervision of a University Professor. It was of such high quality that a Belgian Court ordered the closure of this incinerator in December 2001 even though it was complying with all European waste regulations.
It is unique among studies of incinerators for several different reasons. Firstly it shows a causal link between incineration and cancer. The study revealed a massive five fold increase in cancer in adults and also showed how these cancers gradually increased over time, presumably as the bodies of the inhabitants became more toxic. The incinerator was the only possible cause for the huge increase in cancers as there were no other industrial processes in this town (7).
Secondly it showed the long latent interval before the increase in cancer appeared (13 years in adults) and this highlights the need for long-term safety studies of modern incinerators before any more are built. It also demonstrated that incinerators could cause a wide range of illnesses, probably by damaging the immune system. To this day no one knows what pollutants or what combination of pollutants, emitted from this incinerator, caused these large rises in cancer and other diseases. The omission of this study from the report is extraordinary and is not in keeping with a true scientific enquiry.

4) The dangers to health from combinations of chemicals has not been discussed

A number of major studies have shown that small amounts of chemical pollutants can have vastly greater effects in combination than when used alone. One study showed that animals exposed to mixtures of heavy metals and chemicals at “safe doses” developed impaired immune responses, altered brain development and altered thyroid function (8). A study published in Science magazine demonstrated that the combinations of chemicals could increase toxicity by 500 to 1000 times (9). This is often called the “cocktail effect”. This is highly relevant to incineration where hundreds of dangerous chemicals are emitted. Even more worrying is the fact that no one has any knowledge of the dangers to health of the type of combinations released from incinerators. The fact that this crucial issue hardly gets a mention shows up the poor quality and lack of balance in this report.

5) The report fails to acknowledge the appalling lack of regulation of modern incinerators

A recent study found that 10 incinerators committed over 500 pollution offences over a two year period (10). All of these were criminal offences and all could have led to loss of life or endangered health. Unbelievably there is to be further deregulation in this industry so it is likely that these offences will increase. The report incorrectly states that incinerators are inspected without prior warning. This is not the case and operators are given prior warning. That tells us everything about the cosy relationship between the Environment Agency and the waste industry.
The study looks at incineration operating under ideal conditions. This is unrealistic. It is known that incinerators frequently break down and that safety limits are often broken. The public can have no confidence at all in a system that so clearly fails to protect them. Again the omission of this essential data adds to the lack of credibility of this report.

6) The risk from brominated chemicals has been ignored

These substances which include PBDEs, a class of flame retardants which are widely used in televisions, computers and foams, have been doubling in breast milk every 5 years with a 57 fold increase between 1972 and 1997. Evidence suggests that levels in the breast milk of women in the UK are already higher than in other European countries (4). They have a similar toxicity to the banned PCBs. Their precursors have been increasing in incinerator waste are therefore likely to be increasing in incinerator emissions. However they are not monitored in incinerators and this is a major concern. Like many toxic substances there is evidence that harmful effects occur at levels which are close to the background levels already present in people’s bodies. Again the effect will be most marked on the foetus and on children and these pollutants are likely to act synergistically with other pollutants.

7) There are no studies on the safety of the new generation of incinerators in the UK

It has often been stated that modern incinerators are safer than the older type. There is no proof that this is true. In fact modern incinerators are far bigger (often ten-fold bigger) than the older incinerators and modern waste contains far more plastic. This produces more toxic by-products. So there is great potential for harm. It is clear from the Sint Niklaas study that it would take a 20 year study to establish the safety of these incinerators. In addition it would be necessary to investigate the body burden of toxic chemicals in the populations in the vicinity. These studies have not been conducted and therefore the safety of these incinerators is unproven and people living nearby are being treated as guinea pigs.

8) The study does not look at incinerators that burn hazardous and radioactive waste.

This is important omission. There are over 30 sites that incinerate radioactive waste in the UK and recent evidence suggests a high rate of birth defects around these sites (10). It is well established that there are higher rates of childhood cancers and leukaemias around other sites where radioactive matter is released. This includes Sellafield, Dounreay and Aldermaston. Scandalously there has been no research on the health effects of incinerating hazardous and radioactive waste.

INCORRECT DATA

1) DEFRA suggests that the best way of assessing pollution is from modelling data

Nothing could be further from the truth. Modelling is the most subjective and inaccurate way of assessing pollution. The R and D report of the Environment Agency “An intercomparison of the AERMOD, ADMS and ISC Dispersion Models for Regulatory Applications” shows huge discrepancies between the models. Modelling has a confidence ratio of 30%. This is less accurate than tossing a coin. Why did the DEFRA report throw its weight behind modelling? One can only assume that it is because it is the easiest method for industry to manipulate.
Objective methods of assessing pollution should have been given far more weight. This includes monitoring of pollutants and body burdens.
Monitoring of pollutants must include monitoring of PM2.5 particulates because these pollutants cause the greatest health damage and are produced primarily by combustion sources. In addition the smallest and most dangerous particulates are not removed by the filters in the incinerators and so will be inhaled by the local population. These are the particulates that are less than 1 micron in diameter (PM1s). Ideally PM1s should also be monitored. Even data from monitoring can be manipulated and many suspect this is already happening. It is crucial that this process should be transparent and capable of independent verification.
The most objective method of assessing pollution is to measure the body burdens of those living near incinerators over time. At the moment we simply have no data on the accumulation of toxic material in the bodies of people living near incinerators. Research from the USA has shown that people living near waste sites have higher body burdens of toxic chemicals (12). This is even more likely to occur near incinerators and the lack of data on this is incompatible with claims that incinerators are safe. The collection of data on body burdens from people living near incinerators should be a high priority and should be completed before any more are built.

2) DEFRA states that air pollution only shortens life by a few days

The work of Dr Joel Schwartz, an international authority on air pollution, has shown quite clearly that this is untrue. He has looked at this very question in his paper Air Pollution and Harvesting (13). He found that the maximum effect was on subjects in good health with underlying heart disease. He found that deaths were being brought forward by a non-trivial amount of time and not the few days or weeks as suggested in the report.

3) DEFRA states that there is little risk of cancer with incinerators

This is quite contrary to the evidence. Before discussing this issue it is necessary to look at epidemiological studies of cancer. It is quite difficult to show that toxic chemicals cause cancer. Even if nearly everyone in a particular street has cancer due to pollutants from a nearby chemical factory it may not be possible to show a statistically significant link. This is because large numbers of cases are needed for statistical proof. This problem is acknowledged in the report.
Let’s look at this a different way. Two important recent studies have shown very clear links between cancer and environmental pollution, namely the Upper Cape study and the Long Island study. In both these cases the initial studies were negative. Only active campaigning by local citizens followed by sophisticated studies by scientists from many different fields showed up the true situation. This illustrates the difficulty of proving that industrial pollution is the cause of cancer.
Now look at the DEFRA report. Nine different studies did indeed show higher rates of cancer around incinerators. As we have said it is easy to have a real increase in cancer and for no statistically significant increases to show. Here we see these increases occurring time and time again. How do the authors interpret the data? Incredibly they dismiss the connection in every case. This is absurd. The weight of evidence of nine different studies makes a connection highly likely. We must also add the crucial evidence from the Sint Niklaas incinerator which showed a progressive and large increase in cancer occurring in the years after the incinerator started operating. This study seems to have been conveniently forgotten.
Why did the report dismiss these studies? The cancer connection was dismissed for reasons such as the presence of deprivation or other industrial processes occurring in these areas. This should have led them immediately to another important conclusion. It is totally inappropriate to put incinerators in areas which are already polluted and it is totally inappropriate to put incinerators in areas with deprived populations.
However their data should also have led them to another obvious conclusion. Incinerators and increased rates of cancers go hand in hand and virtually every study shows this.
What is so tragic about this situation is that cancer is gradually increasing with the present population already having a 1 in 3 risk of developing cancer with treatment a poor gamble. Compare this with the 1 in 13 risk in 1900. Studies of body burdens have found that the average healthy person already has over 50 identifiable carcinogens in their body fluids (14). While their body is trying to cope with this toxic load they are being exposed to at least 65 carcinogens from their food, 40 carcinogens from the water they drink and over 60 carcinogens in the air they breathe (15). It should be clear to every intelligent person that this is unacceptable and there is an urgent need to reduce the number of carcinogens we are exposed to. It is therefore insane to deliberately pollute the air further with hundreds of carcinogenic substances from incinerators when the population is only just coping with the present level.

4) It ignores the crucial question of particulate pollution

Incinerators convert waste into gases and particulates. The filters in incinerators remove the larger particulates but cannot stop the smaller ones being released, especially those particulates less than 1 micron in size. Unfortunately for the people living in the vicinity, these are the very particulates that cause the most health damage. These particulates are also are highly chemically reactive and carry other toxic chemicals into people’s bodies. Recent research in the USA has demonstrated that PM2.5 particulates are highly carcinogenic and can trigger heart attacks. A 10mcg/m3 increase can cause an 8 to 14% increase in lung cancer and a 6 to 14% increase in heart deaths (16). There is now simply no excuse for deliberately emitting these highly dangerous particulates. The report ignores the huge volume of research on the dangers of particulates. This is incompatible with true science.

AT ODDS WITH OTHER REPORTS

1) The European Commission’s Report

This report found that an incinerator burning 400,000 tonnes a year, as previously stated, would cause between £9 and £57 million of health and environmental damage per year. Another report found that the health damage from an incinerator of this size would cost 48 million euros per year. The UK government’s own report suggests that for each tonne of waste burned would create £10 of environmental damage, in other words £4 million per year of environmental damage. It is important to remember these immense costs are unnecessary as plasma gasification caused virtually zero pollution to air.

2) The Parliamentary Report by Public Interest Consultants (DSW 56)

This report suggested the public were quite right to be concerned about incinerators and that the Minister for the Environment admitted that emissions from incinerators were extremely toxic and some were carcinogenic. He also admitted that there was no threshold for many of these dangerous substances. The report went on to say that allowing incinerators could be unlawful in respect of the Environmental protection Act and the Waste Directive Framework. They state it may infringe Article 2 of the European Convention on Human Rights, the Right to Life.

3) The Environmental Protection Agency’s assessment of the cost of air pollution

The Environmental Protection Agency is the USA assessed the success of their policy of tight control of air pollution in September 1993. They found that the saving in health costs on just three health indicators (reduction in premature deaths, reduction in hospital admissions and saved working days) was between $120 and $192 billion dollars over a 10 year period between 1992 and 2002. It is almost unbelievable that whilst the Americans have demonstrated that controlling air pollution has led to the savings of billions of dollars in health costs and thousands of lives that this report recommends polluting the atmosphere further with its inevitable enormous impact on NHS costs.

OTHER COMMENTS

The report seems more concerned with spin than substance. They use phrases like “dialogue and not monologue” and “stakeholders should ensure that people are trained in communication”. People would be a lot more reassured by a degree of honesty. If DEFRA admitted that there had been no adequate health studies on incinerators in the UK, if they admitted that regulation of incinerators was grossly inadequate and if they admitted that there has been no attempt to look at body burdens in those living near incinerators and started to address these issues, then people would start to believe them.
Much of the report uses a strange perversion of logic. It goes something like this. If there’s a few more murders in your town then don’t worry because that’s an insignificant number of deaths compared with the number of people that die from road traffic accidents. In this way they ignore their own data which shows that incinerators have a higher mortality than any other method of waste management. We might contrast this heartless approach with the words of President John F Kennedy who said “the loss of even one human life or the deformation of even one human baby should be a source of concern to us all. Our children and grandchildren are not mere statistics towards which we can be indifferent”. The simple inescapable fact is that whenever incinerators are built, innocent people are condemned to die.

SUMMARY

This report is fundamentally flawed and will be regarded in much the same way as many other government reports, that is with a high degree of suspicion. It appears to be a report written by the waste industry for the waste industry and does nothing to answer the many important questions being asked about the safety of incineration. It will reassure no one.

REFERENCES

1) Generations at Risk, T Schettler, G Solomin, M Valenti, A Huddle, 1999, MIT Press
2) Silent Scourge: Children, Pollution, and why Scientists Disagree, C Moore, Oxford University Press, 2003
3) In Harm’s Way: Toxic Threats to Child Development, J Stein, T Schettler, D Wallinga, M Valenti, Developmental and Behavioural Paediatrics, 2002: Vol 23:S13 -22
4) Compromising Children: Chemical Impacts on Children’s Intelligence and Behaviour www.wwf.org.uk/chemicals
5) Chronic Effects of Toxic Environmental Exposures on Children’s Health, Landrigan P, Garg A, Clinical Toxicology 2002;40(4):449-56
6) www.euro.who.int/eprise/main/progs/bud/home
7) www.milieugezundheid.be
8) Toxicol Sci 2002;67(2):207-18
9) Science 1996;272:1489-92
10) www.icwales.com
11) A Review of the Performance of Municipal Incinerators in thee UK, Greenpeace,2001
12) ATSDR Biennial Report to Congress (Atlanta,ATSDR 1992)
13) Air Pollution and Harvesting, J Schwartz,Epidemiology,2001;12(1):55-61).
14) Environmental Working Group: Body Burdens www.ewg.org/reports/bodyburden/findings.php
15) Env Health Perspectives 1996;104 (7):750-4
16) Lung Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine Particulate Air Pollution, Pope C, Burnett R, Thun M, Calle E, JAMA, 2002; 287:1132-41