Background
Some people suffer from adverse health effects when they are
exposed to pollutants at levels lower than thresholds determined
by expert bodies, such as the World
Health Organization. Many people may be exposed to pollutants
as a result of:
- a past preference for workers and factories to be located
close together, mainly for transport reasons
- a tendency for polluting industries to be located in lower
socio-economic areas
- land-use planning that did not take into account the health
impacts of industrial emissions—for example, insufficient
separation distances between what are now recognised as incompatible
land uses
- inadequate environmental impact assessment of industrial expansion
and urban growth or encroachment
- inadequate legislation and policies for land-use planning
and environmental impact assessments (EIA) to allow for cumulative
impact and strategic environmental assessment (SEA)
- unnecessarily hasty approval processes so as to achieve desired
outcomes.
The extent of health impacts from noise or other environmental
hazards is not yet completely understood, particularly at low
levels of exposure. Research on these issues involves major population
studies that are expensive. Budget limitations do not allow the
state government to play a major role in primary research. Instead
it relies on the work of the National
Health and Medical Research Council, overseas studies,
and other external sources.
There will, however, continue to be gaps between insufficient
and conflicting evidence of adverse health impacts of pollutant
exposure and the government's response. Engagement in national
approaches and responses to public health policy is one of the
most cost-effective means of addressing these gaps.
A health risk assessment or health impact assessment can be used
to set standards for pollution exposure that will, in general,
protect the community. These assessments consider likely impacts
from polluting or potentially polluting activities on MOST people,
but cannot do much for conditions that have no known cause—for
example, multiple chemical sensitivity.
Similarly, standards for air quality, noise, water quality, food,
etc. cannot protect ALL the people ALL the time; when unusual
sensitivities arise, they will need to be addressed on a case-by-case
basis. There is no such thing as zero risk, which can be difficult
for the community to understand.
Management approaches
A mixture of legislation (e.g.
Environment Protection Act 1993 and the Public
and Environment Health Act 1987), regulation, policy,
community and industry behavioural change programs, and cooperation
and collaboration are used to manage the adverse effects of human
activities on public health.
As legislation involves imposing restrictions or costs on citizens,
the definition of health impacts that trigger such an imposition
results from a public process that aims to balance the costs to,
and interests of, those affected by the outcome. Restrictions
need to be reasonable and practicable, as defined in legislation
such as the Environment Protection Act. Legislative impositions
cannot be easily varied to take into account the circumstances
of individual complainants, although the EPA can to some extent
take noise characteristics into account when determining acceptable
levels. However, this is only where noise impacts are not already
subject to an environment protection policy.
For new developments, land use planning, environmental impact
assessment and environmental regulation all play a role in protecting
the community from health risks. Health risk assessment and health
impact assessment are best done early in the decision-making process
so that health issues can be considered together with social,
economic and environmental objectives. Currently, the SA Department
of Health has little or no role in health risk and health impact
assessment for new developments. In other states, health departments
do consider the health impacts of new developments and this is
being considered for South Australia as part of proposed changes
to the planning legislation.
EPA approaches
Consultation & complaints service
The pollution complaints and response service is an essential
part of environmental protection and decides how, and which agency
is best able, to respond to the problem. The community of South
Australia plays an important role in assisting the EPA with its
environmental 'watchdog' responsibility.
Local government is well placed to manage pollution complaints
that result from local or domestic events such as air conditioner
noise or wood smoke. The police can also respond to domestic noise
complaints, usually those arising from loud music at parties,
etc. However, the community must accept some responsibility for
resolving problems resulting from domestic or neighbourhood issues
before involving the authorities.
This can be achieved by using free, government-operated community
mediation services for domestic pollution complaints. Many complaints
are a result of neighbour disputes and both parties must be willing
to negotiate for this service to be effective. Should community
mediation be unsuccessful, then compliance with the law may be
enforced, preferably by the local council with EPA support. Failing
that, the EPA will take action consistent with its Guidelines
for Compliance and Enforcement (133KB PDF).
For complex, sensitive or high public interest matters, the EPA
Board may invite both the community and industry to present to
the Board prior to making a decision, as in the case of the Hensley
and Castalloy foundries.
Cooperation and collaboration
As a result of the 'Sharing Responsibilities With Local Government'
pilot project, changes to the Environment Protection Act have
been proposed to enable some councils to voluntarily opt to enforce
the Environment
Protection Act 1993 (the Act) in their own right for non-licensed
activities. They will receive support from the EPA and be able
to recover some of the costs of dealing with contraventions of
the Act.
The EPA and the Department of Health have developed a coordinated
and integrated approach to identifying and dealing with high-priority
risks to health arising from industrial activity. The EPA works
with the Department of Health to deal with contaminated sites
and EPA staff regularly receive training in risk communication
in cooperation with the Department of Health. The Department of
Health will receive extra funding to assist with managing site
contamination following a government decision to fund a site contamination
package.
Community and industry behavioural change programs
Eco-efficiency projects, such as Greening
the Supply Chain and cleaner
production programs, identify opportunities for industry
to adopt cleaner production processes, resulting in cost savings,
less pollution and more efficient use of natural resources. Other
examples include the development of a campaign to inform the community
of the best way to use wood heaters so as to minimise wood smoke
pollution.
Monitoring
As a requirement of the National Environment Protection Measure
for Ambient Air Quality, the EPA has a network of ambient air
monitoring stations to assess community exposure to six priority
air pollutants, namely nitrogen oxides (NOx),
sulphur dioxide (SO2), ozone, lead, carbon
monoxide (CO), and particulate matter (PM10).
The EPA can also monitor hot spots or undertake campaigns to assess
local air quality and thus provide data for health risk assessments,
and guidance for industry environment improvement programs.
The EPA can also require licensees to identify what their emissions
are and to model how the pollutants will spread so as to be able
to predict ground level concentrations. These can be used to determine
the potential risk to the health of people living in the affected
area. When appropriate, the EPA monitors noise at licensed and,
under certain circumstances, non-licensed premises, and offers
support and training to local councils to measure and manage noise
in domestic situations.
Regulation and enforcement
Both prescriptive and performance-based licence conditions are
set by the EPA to manage emissions from industry, so as to meet
standards in the ambient environment. If appropriate, and particularly
in sensitive environments or when the carrying capacity has been,
or is close to being, exceeded, industry environment improvement
programs are implemented via licence conditions to reduce emissions,
and hence risk. In these circumstances, health risk assessment,
combined with best practice technology and environmental management,
is the minimum starting point.
The Department of Health provides advice on health risk assessments
conducted by industry to assist the EPA in deciding on environmental
authorisations and development assessments. Environment protection
policies, codes and guidelines are important tools for environmental
management—e.g. guidelines on separation distances for incompatible
land uses.
In making decisions about its major environment protection functions—for
example, assessment of development applications and environmental
authorisations—the EPA considers the objects of the Environment
Protection Act (including sustainability principles), the general
environmental duty that applies to everyone, and any environment
protection policy that covers the subject under consideration.
In essence, any measure taken to protect, restore or enhance
environmental quality must be reasonable and practicable. The
measures must have regard to the principles of ecologically sustainable
development and consider:
- the financial implications (as they relate to that industry
sector)
- the nature of the pollution or potential pollution and sensitivity
of the receiving environment
- current technical knowledge and likelihood of success of implementation.
The EPA undertakes enforcement action, consistent with its Compliance
and Enforcement guidelines, when there are breaches of the Environment
Protection Act, licence conditions or environment protection policies.
Enforcement can range from verbal warnings through to prosecution.
Proposed changes to legislation
Proposed changes to environmental legislation will require among
other things, industry to consult with the community on their
activities. In proposed changes to planning legislation, the Environment
and Conservation Portfolio¹ has recommended
that health impact assessment should play a much greater role
when assessing new developments.
National approaches
The Environment
Protection and Heritage Ministerial Council (EPHC) collaborates
with the health sector to set standards and criteria for air quality,
site contamination, water quality, etc. through legislative and
non-legislative approaches. The EPHC also has strong representation
on other national standard-setting bodies, including the enHealth
Council and the Land Transport and Environment Council.
A memorandum of understanding between the EPHC, the enHealth
Council and the National
Health and Medical Research Council (NHMRC) is being developed
to improve cooperation between the health and environment sectors
and provide a high level policy group to examine health-based
environment protection issues.
Further work
Work that needs to be done to further improve the management
of pollution impacts includes:
- development of EPA Position Statements and guidance for proponents
- development of policies for impact assessment of developments—for
example, strategic environmental assessments
- changes to the land-use planning and environmental impact
assessment processes and systems to streamline approvals without
compromising environmental quality and ecosystem integrity—for
example, strategic assessment of plan amendment reports
- expansion of industry and urban sustainability programs, e.g.
eco-efficiency
- expanded use of environment management systems (a necessary,
but not always sufficient tool for improving environmental performance)
- development of legislative and policy frameworks for the environmental
assessment of incremental industrial expansion
- full disclosure of company environmental performance, including
community relations
- review of national health-based criteria based on Australian
data—for example, the air quality NEPM.
Furthermore, it is becoming increasingly evident that while
the air NEPM provides useful information about the exposure
of the general Australian population to certain air pollutants,
alternative or complementary approaches need to be explored
in order to guide both health impact assessments and health
risk assessments of communities exposed to air pollutants, and
consequent management and regulatory responses.
- clarification of the roles and responsibilities of local and
state governments in environmental protection and response to
community complaints
- use of innovative policy tools to encourage continuous improvement
in industry's environmental performance—for example, the
use of the financial and insurance sectors and supply chains
as surrogate regulators.
While much of this work is under way, strong collaborative partnerships
will be required between governments, industry and communities
to fully implement these initiatives and identify further opportunities
for managing the health impacts of pollution.
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¹Department of Environment and Heritage,
Department for Water, Land and Biodiversity Conservation, Environment
Protection Authority
This page was last modified 29-01-2008
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