Ms Joyce Whytock,
Air Quality Team,
Edinburgh EH6 6QQ
Dear Ms Whytock,
re: Comments on The Air Quality Strategy for England, Scotland, Wales and Northern Ireland. - A Consultation Document.
Thank you very much for the opportunity to comment on this important document.
The following are my comments. In response to your covering letter, please note that I do not mind at all if you publicise my comments by placing them in the libraries of the parliaments, in government or executive departments, or in other ways. I have no plans at present to publish my comments in the scientific literature or in the media. However of late when responding to Government Consultation Documents, I have adopted the practice of making them available on the World Wide Web. The URL for my comments on this consultation document is:
In general, this consultation document addresses most of the important issues in a detailed, highly satisfactory and well written manner.
While welcoming the strength of the consultation document, I should note what I believe to be the singular most glaring omission: This Air Quality Strategy does not explicitly set a strategic health target (as distinct from air quality targets). By way of comparison, if one looks at Government policy relating to "Our Healthier Nation" it sets out explicit targets for reductions in mortality or morbidity in such important areas as cancer, cardiovascular disease, mental health and accidents. The Government's Air Quality Strategy rightly appears to endorse the work of the Committee on the Medical Effects of Air Pollution (COMEAP), regarding the 'Quantification of the Effects of Air Pollution on Health in the United Kingdom'. Therefore why does the Air Quality Strategy not show true vision and transparency in setting out an explicit target for a reduction in this pollution related morbidity and mortality? What proportion of the current deaths and ill-health attributable to pollution does this strategy propose to eliminate?
What the strategy goes on to do, having omitted this vital step of setting
a health target, is to then lay the tactical ground work for air
quality standards for local air quality management. These are useful and
essential. However in my opinion, for the man in the street, such standards
are as remote as setting standards for low density lipoprotein cholestreol
would have been for the reduction of cardiovascular ill health. The public
needs to know how much illness and death the Government aims to prevent.
There is already a wealth of
evidence in the UK, and indeed even in Scotland [1,2] to permit further improvement on the quantification made by COMEAP and to be able to determine an appropriate target for reduction in morbidity and mortality related to air pollution.
Although the recommendations of the Expert Panel on Air Quality Standards publications such as the one on sulphur dioxide, have addressed the issue of susceptibility, the Air Quality Strategy does not address this issue at a strategic level as well. In other words I believe that the Air Quality Strategy should clearly set out what categories of susceptibile people the Government intends to protect and what level of risk to their health is deemed to be acceptable and/or achievable. Work to address these issues of susceptibility has already begun in Scotland . It is to be welcomed that the important issue of susceptible subgroups of the population is mentioned, albeit very briefly, in the need for further work on health effects.
A lesser omission, but one which I believe needs to be addressed nevertheless, relates to the lack of mention of Black Smoke as a standard in relation to pollution. While many believe that this is now "outdated" and replaced by other metrics such as PM10 and PM2.5, there are a number of studies, including ours [1,2,3] which suggest that in some respects, it may be a better predictor of certain adverse health outcomes than PM10. Therefore we should not be too hasty in discounting 'Black Smoke', especially since we have a wealth of data for exposure to it and which therefore permits us to draw long term comparisons on trends in pollution reduction and in the associated health effects.
Addressing the issue of an Air Quality Strategy from a Scottish perspective,
it would be useful for a specific reappraisal of COMEAP's assessment on
the quantification of health effects, to be conducted in relation to Scotland.
If the authorities in the rest of the UK are reluctant to set targets
for reductions in pollution related morbidity and mortality, perhaps the
new Scottish Parliament can 'grasp the nettle' (or thistle !) and determine
to set such strategic and visionary health targets (and not simply air
quality targets) in relation to air pollution in Scotland.
 Prescott GJ, Cohen GR, Elton RA, Lee AJ, Fowkes FGR and Agius RM. Urban air pollution and cardiopulmonary ill health - a 14.5 year time series study. Occup Environ Med, 1998; 55: 697-704.
 Prescott GJ, Cohen GR, Elton RA, Fowkes FGR and Agius RM. Urban air-pollution and cardio-pulmonary morbidity and mortality. Final report on research submitted to the Department of Health, London 1998.
 Prescott GJ, Lee RJ, Cohen GR, Elton RA, Lee AJ, Fowkes FGR and Agius RM. Investigation of factors which might indicate susceptibility to particulate air pollution. Occup Environ Med, 2000; 57: In press.
Raymond Agius 22nd October 1999