Memorandum submitted by Michael Ryan
THE FAILURE OF ENVIRONMENT AGENCY (EA) TO
REGULATE HARMFUL INDUSTRIAL PM2.5 EMISSIONS
1. EXECUTIVE
SUMMARY
1.1 The EA's failure to regulate harmful
PM2.5 (particles of 2.5 microns and below) emissions from power
stations, incinerators, cement works, brickworks and some other
industrial processes has caused a massive increase in sickness
and premature death, which is likely to continue unless your Parliamentary
Committee takes early and effective action. These PM2.5s have
increased exponentially due to switch in fuel from coal to hazardous
waste mixes.
1.2 The UK only monitor PM10s, ie particles
of between four and 11 microns (a micron being one millionth part
of a metre), despite proof that the critical upper size of particles
to enter the lungs is PM2.5 and particles doing most harm are
within the range PM1 to PM2.5.
1.3 There is no effective public health
system in the UK to examine the patterns of sickness and premature
deaths resulting from industrial PM2.5 pollution despite there
being considerable published research on the subject by Dr Dick
van Steenis and others.
1.4 If the UK adopted the US Clean Air Act
of 1997 we could easily reduce the annual NHS bill by £24
billion. The US saved $193 billion just from reduced hospital
visits and days off work according to the White House Office of
Management and Budget report which was featured in the Washington
Post, 27 September 2003. HM Treasury failed to reply to Paul
Marsden MP after he raised this issue on my behalf in October
2004. My letter to Paul Marsden MP is at www.ukhr.org/obesity.
1.5 The failure of the EA to regulate and
reduce toxic airborne emissions can be proved and this statement
will make use of a case study in Shropshire and also my birth
defect research at www.ukhr.org as only part of the proof.
1.6 The failure of public health professionals,
whether in Primary Care Trusts (PCTs) or Health Protection Agency
(HPA) or elsewhere to study locations and causes of sickness and
premature death patterns and take effective remedial action shows
a gross dereliction of duty.
1.7 There are two case studies with this
report, the first is based in Shropshire and focuses on a range
of health parameters and a major unregulated source of PM2.5 pollution,
which has caused and is continuing to cause great loss of life.
The second is based in Greater London and refers to variations
in rates of babies born with defects, a set of data that has been
gathered by the government since January 1964 with the aim of
"providing early information of causal factors of congenital
malformation" (The Times, 6 January 1964, "Scheme
to notify malformations"). The principles of each case study
apply elsewhere.
1.8 I've read and agree with Dr van Steenis'
e-mailed submission (25 November 2005), having discussed the matter
with him. We both agree that the best solution would to replace
the EA's failed role as a regulator with an Environmental Police
Force under the direction of HM Treasury, whose money is at stake
for the cost of failure of regulation and also because HM Treasury
is the controlling department of the Office of National Statistics
(ONS), whose extensive data proves that what is written here is
correct and can be used in future to demonstrate that regulation
is taking place, unlike today. Such a new department should also
be subject to external audit to prove effectiveness. Dr van Steenis
would be able to provide expert advice on setting up and auditing
such an establishment.
2. BACKGROUND
2.1 Dr Dick van Steenis carried out a childhood
asthma survey in West Wales [Lancet, 8 April 1995] and found 38%
of four-to-five-year-olds in Whitland to be chronic asthmatics
compared with just 1% in Aberaeron and other locations upwind
of the oil refinery/power station complex at Milford Haven waterway.
Dr van Steenis also obtained the cancer admission rates in high
and low asthma zones and found a 20-fold differential, ie the
high asthma zone had a cancer admission rate that was 2,000% higher
than the low asthma zone. Dr van Steenis also obtained the referral
rates to consultant psychiatrists for clinical depression in high
and low asthma zones and found a nine-fold differential, ie the
high asthma zone had a referral rate that was 900% greater than
the low asthma zone.
2.2 Dr van Steenis has shown that at least
20 illnesses/health parameters are caused by industrial PM2.5s
and the Shropshire Case Study, which started with childhood asthma,
is detailing the variation in rates of about half the list.
2.3 The devious role of the EA in public
health was clarified during Prime Minister's Questions on 16 November
2005, when Tony Blair MP failed to confirm that the EA "must
at all costs protect the people . . ." in response to the
question by Jim Dobbin MP. There is no protection from the EA,
just an illusion of protection to deceive the public.
3. CASE STUDY
1: SHROPSHIRE
3.1 I have replicated Dr van Steenis' asthma
survey in Shropshire and obtained the percentage of children in
years 3 to 6 who bring inhalers to school for asthma. The highest
was 100% in a school immediately downwind of a brickworks. The
lowest was 1.9% in a school that was upwind of both the brickworks
and also Ironbridge Power Station, the power station being a major
source of industrial PM2.5s in Shropshire. The asthma survey is
reported at www.ukhr.org/asthma and the variation in percentages
of asthma inhalers brought to school can be seen to be higher
downwind of the power station, prevailing winds being mainly west-south-westerly,
with north-westerly winds being the second most common.
3.2 The rates of infant mortality by electoral
ward were obtained and found to be higher downwind of Ironbridge
Power Station and the brickworks.
3.3 Telford & Wrekin PCT's 2004 report
included ward maps showing highest premature death rates due to
both cancer and also coronary. These high death rate wards coincided
with wards with high infant mortality and were also in locations
with high childhood asthma.
3.4 Dr Dick van Steenis and I met Michael
Gwynne (Coroner for East Shropshire) on 27 June 2005 and showed
him the above data and Dr van Steenis gave his opinion that suicides
would be mostly clustered in the same electoral wards with high
rates of infant mortality etc. Mr Gwynne was sceptical, but offered
access to his register and subsequent examination has proved Dr
van Steenis to be correct.
3.5 Dr van Steenis had earlier spoken to
Dr Catherine Woodward at Telford & Wrekin PCT regarding Ironbridge
Power Station and a meeting was due to be held, but was cancelled
by the PCT. The patterns of illness and premature deaths in Telford
& Wrekin must, or should, have been known to Dr Woodward whose
own 2004 report referred to high rates of suicide and infant mortality.
3.6 I have requested data from Telford &
Wrekin PCT under Freedom of Information; some has been refused
(suicide data by electoral ward) and some was false (infant death
data by electoral ward failed to match that obtained from the
ONS). I also received a threat of a libel action by the Chief
Executive of Telford & Wrekin PCT for suggesting in my letter
that Dr Woodward was responsible (through her negligence) for
more deaths than Dr Harold Shipman.
3.7 The health parameters in Telford &
Wrekin PCT that have been studied so far include: infant mortality,
stillbirth, childhood asthma, diabetes, COPD, suicide, sudden
unexplained deaths, age standardised mortality rates (ie life
expectancy), premature cancer deaths and premature death from
coronary disease. The correlation of high rates of the above (most
by electoral ward, two by GP practice and asthma by school catchment)
in the same locations should have been apparent to Telford &
Wrekin PCT and their forebears years ago.
3.8 I first raised the issue of excess deaths
downwind of Ironbridge Power Station with Michael Gwynne (Coroner)
on 2 December 2004. Beacon Radio interviewed me on 14 February
2004 and broadcast several news items about emissions on 15 February
2005 and included statements by Richard Pennells [manager of Ironbridge
Power Station], who stated the following in the 10.00 am broadcast:
"We monitor our emissions on a minute-by-minute asis, 24
hours a day, 365 days a year. We can categorically prove we are
not a danger to public health." I wrote to Richard Pennells
and also the EA after the Beacon Radio broadcast requesting copies
of any medical reports that backed up Richard Pennell's claims.
Both declined to send me any medical report and I later discovered
[through the asthma survey and other health research under Freedom
of Information] that no such report can possibly exist unless
it is fraudulent, because the PCT refuse to analyse their own
data.
3.9 I have raised concerns about the "Unlawful
killing of Shropshire citizens" with Shrewsbury & Atcham
Borough Council (SABC), Shropshire County Council, Bridgnorth
District Council and Telford & Wrekin Unitary Authority by
e-mail in October 2005 but all that has happened is that SABC
have referred the matter to public health professionals, having
earlier claimed on 13 October 2005 to "have been advised
that the (medical) evidence does not support (my) concerns".
SABC failed to send me a copy of the "evidence" that
must also be false, just like that which Richard Pennells referred
to on Beacon Radio in the broadcast of 15 February 2005.
3.10 There's a possibility that excess rates
of sickness and premature death downwind of Ironbridge Power Station,
and other industrial processes around the UK, are known about
but covered up. If that is so, it's reasonable to assume that
there might be bribery of certain officials responsible for monitoring
of airborne emissions or public health to do nothing. If there
have been financial inducements to public servants to turn a blind
eye to the effects of emissions from Ironbridge Power Stations,
such an action is little different to a police officer who, although
aware of a Dr Shipman-like character murdering patients, allowing
it to proceed in exchange for some financial reward from the murdering
doctor.
3.11 Simon Conolly, Chief Executive of Telford
& Wrekin PCT, wrote the following to me on 13 June 2005: "Whilst
the PCT retains an open mind on this subject (excess premature
deaths due to Ironbridge Power Station emissions), I should explain
that your views that there are adverse effects from the emissions
(from Ironbridge Power Station) is at odds with the professional
advice that the PCT has allegedly received from the EA and the
HPA. Accordingly, in order to use NHS resources to the best effect,
I am not prepared to ask my staff to become engaged in a detailed
investigation unless a clear and justified case is put to us that
there may be harmful effects associated with the power station
emissions."
Mr Conolly's letter had earlier invited me to
write to the PCT in order to "explain the scientific case
that you (ie Michael Ryan) are alleging in respect of the power
station emissions". The data now gathered is such that his
only course of action would be to sack Dr Catherine Woodward and
then resign in disgrace. The removal of Dr Woodward and Mr Conolly
is overdue because Mr Conolly has admitted reliance on "professional
advice from the EA and HPA" instead of looking at the facts,
many of which are published in Dr Woodward's public health report
of 2004. If Mr Conolly had been an effective manager, he'd have
studied my letter of 4 June 2005 very carefully—then asked
Dr Woodward to investigate the possibility that emissions from
Ironbridge Power Station might be causing excess premature deaths.
They should have intwerviewed Dr van Steenis and myself. If Dr
Woodward carried out such an investigation, she'd have reached
the same conclusion as me in much less time and thereby saved
many lives. It was both foolish and counterproductive of Mr Conolly
to show Dr Woodward my letter as my accusing her of negligence
must prejudice her against me.
3.12 Shropshire is a large, mainly rural
county. Out-of-hours GP services are provided by "Shropdoc",
which might result in a home visit from a GP 50 miles away. The
Director of Shropdoc (until his death, aged 46, earlier this month)
was Dr Steve Hugh. Dr Hugh's medical practice was at Stirchley
and he had lived mainly in Coalbrookdale before moving a short
distance to Little Wenlock. Coalbrookdale is in the electoral
ward of Ironbridge Gorge, which has the shortest life expectancy
by far of any of the 33 wards in Telford & Wrekin (according
to ONS) and is also the closest to Ironbridge Power Station. It
seems probable that Dr Hugh's sudden death, whilst on a walking
holiday in Spain, was due to a heart attack. His premature death
is like so many others who have lived and worked downwind of Ironbridge
Power Station and where lives will continue to be cut short until
effective action is taken to prevent hundreds of premature deaths
per annum.
4. CASE STUDY
2: GREATER LONDON
BIRTH DEFECT
RATES
4.1 Using unpublished ONS birth defect data
released on the instruction of Ruth Kelly MP, I've calculated
rates of babies born with defects in each of the 31 Greater London
PCTs for the years 1995 to 2002. Birth defects are known to be
caused by radioactivity, organophosphate pesticides/herbicides
and industrial emissions of PM2.5s as described in my report at
www.ukhr.org.
4.2 If birth defects were randomly distributed,
then any of the Greater London PCTs will have a one in 31 chance
of having the highest rate in any year. If the same PCT has the
highest rate for two consecutive years, the odds are multiplied
ie the odds are 1 in 961 of occurring by chance. Bexley PCT had
the highest rate of babies born with defects in Greater London
for each of the five years 1998 to 2002 and the odds against that
sequence being a chance event are one in 28,629,151, ie about
twice as unlikely as winning the National Lottery with a single
£1 ticket.
4.3 Bexley is the only London Borough with
an incinerator authorised to burn radioactive waste (White Rose,
Sidcup) according to information supplied to me by Barbara Young,
Chief Executive of the EA, in her letter of 23 December 2002.
Bexley is also home to the Crossness sewage sludge incinerator
which was used to dispose of sewage sludge after dumping sludge
in the North Sea was banned on environmental grounds in 1992.
This sludge contains heavy metals and other chemicals that are
damaging to health when inhaled. The numbers of babies recorded
as being born with defects in Bexley for the years 1995 to 2002
are as follows: 24, 33, 33, 56, 48, 66, 65, and 59. It should
be noted that scanning techniques for detecting defects have improved
considerably since 1995 and so the defect numbers in later years
are an understatement of the true scale of the problem.
4.4 Islington PCT, in the heart of the largest
urban area in the UK, was chosen as the "control" in
my analysis of birth defect data. Islington's birth rate is only
slightly less than Bexley's and yet the numbers of babies born
with defects during the years 1995 to 2002 were: <5, <5,
10, 5, <5, 12, <5, and <5. The ONS refused to divulge
actual numbers less than 5 (<5), hence my inability to state
whether the rate of babies born with defects in Mid Devon PCT
during 2002 was "merely" 39 times greater than the rate
in Islington (assuming four babies with defects in Islington)
or whether the Mid Devon rate was 2,526 times greater than in
Islington (assuming one baby with a defect).
4.4. Greater London PCTs with slightly lower
rates of babies born with defects than Bexley are mostly clustered
downwind of Grundon's radioactive waste-burning incinerator at
Colnbrook. The published ONS birth defect data showed Hillingdon
to be the worst London location for birth defects in 2000 and
2001 and John McDonnell MP asked a series of Parliamentary Questions
in 2004 after he met Dr van Steenis and I on 9 March 2004.
4.5 As Slough PCT will also be adversely
affected by PM2.5 emissions from Grundon's incinerator, I've examined
the rates of babies born with defects in Slough PCT as well as
the 31 Greater London PCTs to determine how many times each PCT
is featured in the worst 10 PCTs during the eight years 1995 to
2002 and found the following:
| Primary Care Trust
| Number of times in top 10 for birth defect rates (out of maximum of 8)
|
| Bexley | 7 | (highest 1998 to 2002)
|
| Croydon | 7 | (highest in 1996 and 1997)
|
| Hillingdon | 7 | (third highest in 2000 and 2001)
|
| Wandsworth | 7 | (second highest in 1996,1997 and 1998)
|
| Harrow | 6 | (second highest in 1999)
|
| Slough | 6 | (fourth highest 2000 and 2002; fifth in 2001)
|
| City and Hackney Teaching | 5
| (highest in 1995) |
| Kingston | 5 |
|
| Tower Hamlets | 5 |
|
| Hounslow | 4 | (second highest in 2001 and 2002)
|
| Hammersmith and Fulham | 4 |
|
| Ealing | |
|
| Sutton and Merton | 3 |
|
| Southwark | 3 |
|
| Lewisham | 2 |
|
| Enfield | 2 |
|
| Greenwich | 1 | (seventh highest in 1999)
|
| Haringey Teaching | 1 | (joint fourth highest in 2002)
|
| Richmond and Twickenham | 1
| (fifth highest in 2000) |
| Waltham Forest | 1 | (third highest in 1998)
|
| | |
A Greater London map showing point sources of industrial
PM2.5s would explain variations of birth defect rates and other
health parameters. Bexley is also affected by emissions from SELCHP
(Lewisham) and Littlebrook D Power Station. I raised these issues
in my statement to the recent public inquiry using unpublished
ONS birth defect data—yet my evidence was wrongly criticised
by pro-incinerator "expert" Professor Jim Bridges, whose
seven page report on my statement was erroneous as detailed in
the South London Mercury, 23 November 2005. Professor Bridges
stupidly quoted from non-existent published birth defect data
for Bexley and then, through Lovells (his solicitors), refused
to retract his erroneous report after I reminded Professor Bridges
that I had access to unpublished ONS data.
Michael Ryan
December 2005
| 
