House of Commons - Environment, Food and Rural Affairs

Select Committee on Environment, Food and Rural Affairs Written Evidence

Memorandum submitted by Dr C V Howard (X6)

Please note that the comments which follow are my personal opinion and should not be construed to be any policy of the University of Liverpool or any part thereof.

EXECUTIVE SUMMARY

As a medically qualified toxico-pathologist specialising in developmental toxicology, my research has made me very aware of the health impacts of the types of pollutants emitted during waste incineration and landfill. A number of these can affect the many ways in which hormones regulate development in the womb and early childhood, with effects which can last throughout life. I am of the opinion that there is no place for incineration in municipal waste management. It is a totally unsustainable use of resources and the inevitable emissions of particulates and toxic organic chemicals such as dioxin-like substances are likely to have harmful effects on health, especially the health of the most vulnerable members of society. These pollutants remain as a legacy for future generations. We should instead adopt two strategies. Firstly, the substitution of products which include potentially hazardous chemicals, by more harmless alternatives. Secondly, adopt a Zero Waste policy throughout the UK, thus avoiding the necessity for incineration or much landfill.

DETAILED COMMENTS

1. I am a medically qualified toxico-pathologist. I supervise the activities of the Developmental Toxico-Pathology Research Group at the University of Liverpool. For over 12 years, I have been studying human and mammalian fetal and neonatal development, ie the development of babies in the womb and young children. This has led to my becoming involved in investigating the effects of a number of global environmental pollutants which have their maximal impact upon the fetus. Many of these chemicals are persistent and bio-accumulative, ie they build up in our bodies over time. Mothers pass these chemicals to their babies in the womb and in breast milk, and many of them disrupt the action of the hormone systems, affecting babies' development in many different ways. All of these effects have been well documented, and many have been shown to be happening at current background levels of dioxins and PCBs, which are the most well studied of the hormone-disrupting chemicals.

2. The so-called "background" levels of dioxin-like compounds are almost totally caused by anthropogenic activities, mainly through combustion of organohalogenated products. Even the cleanest, most modern incinerators still emit an amount of dioxins and other products of incomplete combustion (PICs).

3. Even though the "background" levels of dioxins have been reducing in recent years, this does not mean that it is safe to add a little more into the environment, through new incinerators. Defra acknowledges in their recent dioxin consultation, that infants still receive many times the dose currently deemed "safe". Unfortunately, further evidence seems to indicate that there may be no safe dose below which health effects will not occur. As the effects on the fetus occur at extremely low levels, always in combination with many other anthropogenic chemicals, policy should be to reduce dioxin levels to as low as possible, not just to below the current TDI. Certainly, safety limits have steadily been revised downwards in the past few years, as more becomes known about these chemicals mode of action.

4. There is general agreement that the fetus is the stage of life which is the most vulnerable to damage from hormone disrupting chemicals. Dioxins and similar compounds affect the many ways in which hormones regulate development in the womb and early childhood, with effects which can last throughout life. These effects can range from an increased likelihood of respiratory problems or allergies, to reduced IQ, less efficient kidneys, reproductive problems or a higher probability of contracting cancer.

5. Effects on the intelligence, immune status and hormonal status of infants have been related quantitatively to the amount of dioxin-like substance in the mother's body, by Koppe et al.[3] Furthermore, the effects, including altered latency times in brain function and altered lung function, appear to persist past the age of seven.[4] Neurobehavioural and immune system deficits have been shown to be correlated with the level of PCBs and dioxins that infants receive from their mothers while in the womb. 22, 20, [5],[6] ,[7] ,[8] ,[9] The documented neurobehavioural effects include altered play behaviour as well as general mental and psychomotor development. Other papers also document a variety of reproductive dysfunctions.[10],[11] , [12]There is general acceptance that male reproductive health is under threat. 26,[13] , [14], [15] Exposure to dioxin-like substances has also been related to changes in the proportion of boys to girls being born[16],[17] , there being a decrease in the number of boys.

6. It is not feasible to do a realistic cost-benefit analysis of the health benefits arising from dioxin reduction, as the potential developmental health effects are so diverse, and can occur in synergy with other chemicals.[18],[19] It will never be possible to develop an accurate algorithm to quantify the cost to society of, for example, a reduction in IQ levels[20], or the reduction in quality of life due to fetal kidney growth impairment[21], immune system[22], [23], [24] or reproductive system[25], [26],[27] developing less than optimally, causing reduced potential, occasional illness throughout life or a higher risk of cancer.[28],[29] A precautionary approach would be to reduce human exposure to all chemicals which persist and bioaccumulate or are capable of hormonal disruption, down to the absolutely unavoidable level, especially as mixtures of chemicals may have synergistic effects.

7. However good the pollution abatement equipment is, large quantities of particles will still escape from an incinerator; they will simply be smaller, consisting of large numbers of tiny particles known as ultrafine or nano-particles. Unfortunately, these prove to have a size-related toxicity regardless of what material they comprise. As well as publishing a recent book on the health effects of particulates in 1999[30], I more recently reviewed the potential health effects of nano-particles and participated in an EU workshop which produced a risk analysis of nanoparticles.[31],[32] Many of the conclusions in these reports apply equally to the nanoparticles arising from the incineration of waste. There is strong human epidemiological evidence to show that chronic exposure to particulate aerosols through polluted air carries health consequences.[33] There is considerable evidence that inhaled nanoparticles can gain access to the blood stream and are then distributed to other organs in the body.[34],[35] ,[36] Once internalised, nanoparticles appear to be able to penetrate more rapidly into interstitial sites than larger particles can, and therefore to be trans-located to distant sites within the body. 31 There appears to be a natural "passageway" for them to travel around the body. This is through "caveolar" openings in natural cell membranes, which separate the body compartments. When environmental nanoparticles (such as from incineration or traffic pollution) gain unintentional entry to the body, it appears that there is a pre-existing mechanism which can deliver them to vital organs.[37] The body is then "wide open" to any toxic effects that they can exert. The probable reason that we have not built up any defences is that any such environmental toxic nanoparticles were not part of the prehistoric environment in which we evolved and therefore there was no requirement to develop defensive mechanisms.

8. There are two fundamental approaches to handling waste—either try to reduce the amount and the toxicity of inputs to the waste stream or to attempt to deal with wastes once they have been produced. Clearly there is scope to combine the two.

9. Substitution of hazardous substances: Instead of simply considering how to dispose of waste, much of which is hazardous, we need to start by considering pollution from the beginning of each product lifecycle. We can only control the health hazards from toxic pollutants throughout the product lifecycle, and minimise the production of hazardous waste, by substituting the production of goods which use potentially hazardous chemicals, with alternatives that use more benign chemicals. For most of the known hormone-disrupting chemicals, there are substitutes which are less obviously problematic. The only effective way to make the necessary effective permanent reductions to environmental levels of dioxin-like chemicals, is by substitution of all major uses of organochlorine and other halogenated chemicals (eg pesticides and chlorinated plastics) with safer alternatives. Clearly, this is a major step to take, but the costs to society of allowing the continuing health consequences, which are evident already in the general population, is likely to far outweigh the apparent costs to industry. While these chemicals are still produced in bulk, there will be inevitable release of dioxins during their manufacture, use, accidental fires and disposal, a significant amount of which will eventually find its way into our food chain and hence our bodies. A good use of the Precautionary Principle is to avoid the use of any persistent bioaccumulative chemicals, as these often tend to be linked to health problems. There need to be regulatory changes so that the necessity for a particular process is considered as part of the authorisation process, together with a comprehensive life-cycle analysis of the potential emission dangers throughout the product lifecycle. This should include a realistic assessment of the likely emissions caused by its eventual disposal, whether via controlled disposal or through accidental fires or uncontrolled home bonfires.

10. Another concern is the major issue of the unsustainable use of resources if waste is incinerated or landfilled. Incineration is rather worse than landfill in that respect, as future generations could at least recover certain materials such as metals from a landfill, if the shortage of resources made this necessary. The planetary resources of many raw materials are finite, and the energy consumed in retrieving raw materials often outweighs the energy recovered by incinerating products, which could have been reused or recycled.

11. In summary, my researches have led me to the firm conclusion that there is no place for incineration in municipal waste management. It is a totally unsustainable use of resources and the inevitable emissions of particulates and dioxin-like substances are likely to have harmful effects on health, especially the health of the most vulnerable members of society.

12. Strong emphasis should be focussed on waste minimisation rather than concentrating wholly on the debate over what method to use for the disposal of waste. Many local authorities worldwide are starting to adopt "Zero-Waste" policies. The concept of Zero Waste may sound impractical, but California, Toronto, Canberra, and New Zealand have already adopted a Zero Waste policy. The first two local authorities to adopt Zero Waste policies in England were Bath and North Somerset and Braintree.

13. We need to adopt a policy of maximal waste minimisation, reuse and recycling, by adoption of a Zero Waste policy throughout the UK and developing suitable financial and regulatory incentives. This would thus avoid the necessity for any incineration or much landfill.

Dr C V Howard MB. ChB. PhD. FRCPath

Head of Research, Developmental Toxico-Pathology Research Group

4 October 2004

3 Koppe, JG, ten Tusscher, G, and de Boer, P. (2000) "Background exposure to dioxins and PCBs in Europe and the resulting health effects" in P Nicolopoulou-Stamati, L Hens, and CV Howard (eds) Health Impacts of Waste Management Policies, Kluwer Academic Publishers, Dordrecht, the Netherlands, pp 135-154. Back

4 ten Tusscher, G (2002) "Later childhood effects of perinatal exposure to background levels of dioxins in The Netherlands", PhD Thesis, University of Amsterdam, ISBN: 90-9016271-2. Back

5 Vreugdenhil, HJ, Slijper, FM, Mulder, PG, Weisglas-Kuperus, N. (2002) "Effects of Perinatal Exposure to PCBs and Dioxins on Play Behavior in Dutch Children at School Age." Environ Health Perspect.; 110(10): A593-8. Back

6 Huisman, M, Koopman-Esseboom, C, Lanting, CI, van der Paauw, CG, Th Tuinstra, LGM, Fidler, V, Weisglas-Kuperus, N, Sauer, PJJ, Boersma, ER and Towen, BCL (1996). "Neurological condition in 18-month-old children perinatally exposed to polychlorinated biphenyls and dioxins." Early Human Development 43: 165-176. Back

7 Koopman-Esseboom, C, Weisglas-Kuperus, N, de Ridder, MAJ, van der Paauw, CG, Th Tuinstra LGM, and Sauer PJJ (1996). "Effects of Polychlorinated Biphenyl/Dioxin Exposure and Feeding Type on Infants' Mental and Psychomotor Development." Pediatrics 97(5): pgs 700-706. Back

8 Patandin, S, Lanting, CI, Mulder, PG, Boersma, ER, Sauer, PJ, Weisglas-Kuperus N (1999). "Effects of environmental exposure to polychlorinated biphenyls and dioxins on cognitive abilities in Dutch children at 42 months of age." J Pediatr. 134(1):33-41. Back

9 Weisglas-Kuperus, N, Patandin, S, Berbers, GA, Sas, TC, Mulder, PG, Sauer, PJ, Hooijkaas, H (2000) "Immunologic effects of background exposure to polychlorinated biphenyls and dioxins in Dutch preschool children." Environ Health Perspect. 108(12):1203-7. Back

10 Mably TA, Moore RW, and Peterson RE (1992) "In Utero and Lactational Exposure of Male Rats to 2,3,7,8-Tetrachlorodibenzo-p-dioxin", Toxicology and applied Pharmacology 114, 97-107. Back

11 Gray, LE Jr, Kelce, WR, Monosson, E, Ostby, JS and Birnbaum, L (1995) "Exposure to TCDD during development permanently alters reproductive function in male Long Evans rats and hamsters: reduced ejaculated and epididymal sperm numbers and sex accessory gland weights in offspring with normal androgenic status.", Toxicol Appl Pharmacol. 131(1):108-118. Back