Memorandum submitted by Barry & Vale Friends of the Earth (AQ 23)



Friends of the Earth in Wales have criticised the UK Air Quality Strategy since the first 1998 version, for seriously undercounting the harm to health from traffic-generated particulates and I write this from my involvement over more than a decade. I represented FoE on Defra's Air Quality Forum 1997-2002 and compiled responses to consultation on the UK's Air Quality Strategy Reviews. I participate in professional meetings on air pollution (NSCA, DMUG, IEH UK Annual Reviews) and in international environmental health science and assessment, including the European Airnet conferences and the PINCHE project on child environmental health.


This response is restricted to particulate pollution of the ambient air, whether or not covered by the Air Quality standards.


1. the Committee's first question

whether the Government is developing an effective strategy for meeting its obligations under the EU Air Quality Directives


We attach our objection (PM10 extension-resp toDefra March09.doc) to the Government's request to the Commission for extra time to meet the PM10 standard for 2005. This gives arguments why current plans are not effective for meeting the 2005 PM10 standard at Port Talbot and the infraction proceedings against the UK should continue. The Commission have rejected the request for time extension in respect of London, judging the action plan inadequate, and likewise very recently in respect of Port Talbot as we had pressed from FoE locally and centrally (attached FOE consultation response PM10 (10Mar09).pdf). Thus for these two areas, the Commission agrees with us that the answer to the Committee's question of 'effective strategy' is - no! For London and other areas requiring action on traffic emissions, we argued specific proposals for extra measures in response to the AQS in 2006 and in the latest objection:


Proposed Additional Measures for Abating Traffic-related PM10 and NO2


Speed limit of ~50 mph through and near to urban areas on all roads including motorways;

Taxation to improve the public transport to private car cost ratio;

Giving real force to 'smog' alerts, including incentives or legal measures to reduce vehicle use for the duration; and

Congestion charging that reduces traffic in congested areas could be helpful.


2. the Committee's second question:


whether the strategy is enough to ensure that air pollution is reduced to acceptable levels


We answer this from the standpoint that particulate pollution is a major public health hazard (worse than secondary cigarette smoking) and that the EU standards do not adequately address this hazard. The WHO guideline for PM2.5 of 10 mg/m3 (cf. 12 mg/m3 adopted in Scotland) shows the EU standard (25 mg/m3) is quite inadequate. Moreover, there is no standard for ultrafine particulates (nanoparticles, <0.1mg/m3) that are probably the most harmful pollution fraction.

1. The first AQS chose PM10 as index, when inhalation was better approximated by PM2.5 and the QUARG report [1] gave several other reasons for choosing PM2.5 (which we considered persuasive). While the UK persuaded the European bodies to choose PM10 (1998 AQS, the choice was driven - it is said - by the current head of Defra' AQ section, Martin Williams), the USA was then switching to PM2.5. It has taken till the latest review of air strategy in Europe to introduce PM2.5 monitoring and tentative standards. Thus the UK's choice of PM10 was not based on science and has led to misplaced effort on PM10.

2. The AQS has ignored ultrafine particles, despite their recognition as probably the major reason for adverse health impact and appreciation that they are hardly captured by the PM10 index. Our criticisms drew on the Royal Society conference of 1999 (Ultrafine particles in the atmosphere, Royal Society 2000) and contacts with specialists in fetal toxicology at Liverpool Univ. under V Howard (Microscopical Society seminar, now Professor at University of Ulster). Versions of the AQS repeatedly promised that ultrafine particles would be covered in the next review, and this promise was broken twice. The real reason given by Martin Williams was that Defra's AQ team did not know how to regulate ultrafine particles in the atmosphere (the AQ section's responsibility) and ignored the possibility of tackling them at source (combustion industry and vehicles, the latter by the DfT).

3. We have submitted criticisms of the EPAQS reports, including their ignoring of ultrafine particles. This fault was evidently prescribed by Defra's AQ section, for the chair Prof. Anthony Seaton is a pioneer on identifying ultrafine particles as having the major impact on health, and long-term member (current chair of COMEAP) stressed ultrafine particles are probably the main hazard to a European meeting in 2003 [2].

4. We have pointed out that COMEAP under the DoH has consistently underestimated the harm to health as shown in epidemiology studies ([3]; reports of 1998 and 2001), including in its latest report (dated June 2009; ANNEX 1). As this is over 2 years old and was to provide underpinning for the 2006-7 AQS review, it appears that it has been held up for political reasons, as it's at odds with the findings of the leading epidemiologists internationally and, effectively, failed its peer review.

Thus the figures the Committee call quotes from the AQ Strategy are too low by a factor two (maybe 3 times)

"estimated to reduce the life expectancy of every person in the UK by an average of 7-8 months with estimated equivalent health costs of up to 20 billion each year"

They should read 15-24 months and up to 60 bn/year.


For an up-to-date scientific review on the hazards to health from ultrafine particles, we attach as ANNEX 2 an extract of the evidence given by Prof. V Howard at a recent public inquiry (Ringaskiddy).


Whether the Strategy will suffice to reduce particle pollution to acceptable levels (as the Committee asks) must be answered with a resounding no! While no 'safe' levels of PM and ultrafines have been identified, it

a) doesn't suffice to meet the PM10 standards

b) doesn't seek to meet the WHO's PM2.5 guideline, and

c) ignores the ultrafine particle issue entirely, despite scientists believing it is the most serious fraction.





[1] Quality of Urban Air Review Group, 1996 report, chaired by Prof. Roy Harrison.

[2] Jon Ayres, Health Effects of Airborne Particles, to MVEG sub-group on Euro 5 and Euro 6, 4 Sept. 2003

[3] UK continues to undercount Air Pollution's Health-harm, British Medical Journal letters on-line, 23 September 2007


Attachments as e-files

PM10 extension-resp toDefra March09.doc

FOE consultation response PM10(10Mar09).pdf


15 December 2009




Particulates and long-term Mortality - COMEAP's report fails its peer review


The Committee on the Medical Effects of Air Pollutants (COMEAP) has published** its long-awaited report on the Long-Term Exposure to Air Pollution: Effect on Mortality and in so doing has confirmed the extent to which the UK Government considers there to be a strong link between the effect of air pollution, illness and life expectancy. The dose-effect coefficient settled upon by the Committee for fine particulate matter (PM2.5), a common pollutant in cities worldwide, is 6% (with a range 2-11%). This means that the Committee suggests that on average confirms its January 2006 figure of there will be a 6% increase in all-cause mortality for an increase of 10g/m3 of PM2.5. This figure was the basis for the 2007 Air Quality Strategy for England, Scotland, Wales and Northern Ireland.


Several responses to the consultation on COMEAP's draft report criticised the use of this low coefficient (Appendix 1), when more recent and intensive analyses of the large-scale evidence studies from the USA had concluded the appropriate values would be over 6% to 17% for long-term, all-cause mortality. The 6% figure is the basis for Defra's figure of 7-8 months reduction in lifespan, average in the UK, due to man-made particulate air pollution.


The report had four peer reviews, of which California EPA's Dr Ostro was the most detailed. He compared the results with five US assessments and pointed out that

their final estimates are robust to the technique used and

their central estimate is always greater than that developed for COMEAP.

Dr Ostro, the head of California EPA, has been involved in the extensive analysis in the USA, this shows that COMEAP's choice of lower coefficients is scientifically unsound.

COMEAP answers only weakly (their Appendix 2) that they:

"adopted a cut-off in early 2006 for published work... this, unfortunately, excludes an important and influential US review by Pope and Dockery (2006)".

Evidently, COMEAP's report failed its peer review.

COMEAP has a record of undercounting - in 1998 COMEAP discounted long term (chronic) effects as too uncertain, in 2001 they accepted that PM probably caused chronic mortality, but decided the coefficient value of 1% was "most likely". In January 1996, in an interim report they upped it to 6% after reviews in the EU fixed on the range 2 to 11 %. The latest Report quibbles about the endpoints, but essentially accepts the range 2-11% of 2005 as well as sticking to the 6%. Yet already in mid-2006, the range 6% to 17% was established by the US work.

COMEAP admit their report is out of date and make no case for departing from the findings from more thorough and up-to-date analysis in the USA, produced by an expert panel chosen specifically for its breadth of expertise and independence. How can government use this report that has failed its peer review as a basis for policy?



** on 18 June:

Committee on the Medical Effects of Air Pollutants, Advisory Committee under the Dept of Health




Particulate Emissions and Health Statement of Evidence to Inquiry June 2009

Professor C. Vyvyan Howard MB. ChB. PhD. FRCPath.


1.3 Particulates and Health:

Epidemiological studies worldwide have consistently demonstrated links between ambient

particulate matter exposure and adverse health outcomes, including increased rates of

respiratory and cardiovascular illness, hospitalizations, and pre-mature mortality [9, 10].

Particles are usually defined by their size, e.g., PM10 and PM2.5, as the mass of particles

with aerodynamic diameters less than 10 to 2.5 μm, respectively. Recently, however,

interest has also focused on the fraction of ultrafine particles (UFP) with a diameter less

than 0.1 μm, which are abundant in number but contribute little to the mass [11, 12]. The

UFPs are only usually measured for research purposes and are effectively outside

regulatory control. It is these emissions that are the main theme of this evidence.

Studies have shown that ultrafine particles are more toxic than larger particles [13-15].

Furthermore, individual particles have been shown to be capable of inducing inflammation

and oxidative stress [15], suggesting that particle number concentrations, which are

dominated by ultrafine particles, may be more indicative of some potential health impacts

than particle mass concentrations. UFP are also important because of their high alveolar

deposition fraction, large surface area, ability to induce inflammation, and potential to

translocate into the blood circulation system. At a given mass, ultrafine particles (diameter

< 0.1 μm) have 102 to 103 times more surface area than particles with diameters in the 0.1-

2.5 μm range and approximately 105 times more surface area than coarse particles (2.5 μm <

diameter < 10 μm) [16]. This surface area-to-mass effect may affect the relative toxicity of

particles to respiratory systems, in combination with a higher deposition efficiency of ultra

fines in the alveolar region (Hughes et al., 1998).

Estimates of the number of excess deaths on a global scale due to particle inhalation have

been made, and they amount to about 2 million/year of which c.370,000 per year are

within the EU. The health effects are not limited to lung injuries. The deaths also include

cardiovascular diseases and cancers [17].


1. Maynard, R. and C. Howard, Eds, Particulate Matter: Properties and Effects upon Health. 1999, Oxford: BIOS Sci. Pub.

8. Polichetti, G., et al., Effects of particulate matter (PM10, PM2.5 and PM1) on the cardiovascular system. Toxicology.

9. Pope, A.C., 3rd and D.W. Dockery, Health Effects of Fine Particulate Air Pollution: Lines that Connect. Journal of the Air & Waste Management Association, 2006. 56: p. 709-742.

10. Nawrot, T.S., et al., Stronger associations between daily mortality and fine particulate air pollution in summer than in winter: evidence from a heavily polluted region in western Europe. J Epidemiol Community Health, 2007. 61(2): p. 146-149.

11. Donaldson, K., X.Y. Li, and W. MacNee, Ultrafine (nanometre) particle mediated lung injury. Journal of Aerosol Science, 1998. 29(5-6): p. 553-560.

12. Penttinen, P., et al., Number concentration and size of particles in urban air: effects on spirometric lung function in adult asthmatic subjects. Environ Health Perspect, 2001. 109(4): p. 319-23.

13. Wahlin, P., et al., Pronounced decrease of ambient particle number emissions from diesel traffic in Denmark after reduction of the sulphur content in diesel fuel. Atmospheric Environment, 2001. 35(21): p. 3549-3552.

14. Donaldson, K., et al., Combustion-derived nanoparticles: A review of their toxicology following inhalation exposure. Particle and Fibre Toxicology, 2005. 2(1): p. 10.

15. Li, N., et al., Ultrafine particulate pollutants induce oxidative stress and mitochondrial damage. Environ Health Perspect, 2003. 111(4): p. 455-60.

16. Harrison, R., et al., Measurement of number, mass and size distribution of particles in the atmosphere. Philos Trans R Soc A, 2000. 358: p. 2567-2579.

17. Aboh, I.J.K., et al., EDXRF characterisation of elemental contents in PM2.5 in a mediumsized Swedish city dominated by a modern waste incineration plant. X-Ray Spectrometry, 2007. 36(2): p. 104-110.




Annex 1

Data from the Port Talbot (Margam Fire Stn) monitoring site for 2008

at <>


PM10 Particulate

Annual Mean (gravimetric)



PM10 Particulate

No. days 24hr mean >50g/m3 (gravimetric)




PM10 (no gravimetric conversion) 1-jan-08 to 1-jan-09

Annex 2

Proposed Additional Measures for Abating Traffic-related PM10 and NO2


Speed limit of ~50 mph through and near to urban areas on all roads including motorways

Reason - pollution per mile is minimised at ~50 mph; more nearly uniform speeds reduce the amount of congestion which itself gives higher pollution per vehicle-mile


Taxation to improve the public transport to private car cost ratio

Reason - private motoring has become cheaper in real terms since 1997, while public transport has increased. A reversal fits with declared objective of increased social inclusion and equity.


Giving real force to 'smog' alerts, including incentives or legal measures to reduce vehicle use for the duration

Reasons - restricting vehicles entering urban areas on high pollution days can reduce peak levels.

'Smog' actions also help in encouraging the public to reduce overall use of the car

To assist the public to understand the impact of air pollution on their health or the wider environment

To encourage the public to reduce emissions of pollutants within their control (for example by changing their driving habits)

Maynard, R.L. & Coster, S.M. 1999. Informing the Public about Air Pollution. In S. T. Holgate, J. M. Samet, H. S. Koren and R. L. Maynard. Air Pollution and Health. p. 1019-1033. Academic Press


Congestion charging that reduces traffic in congested areas could be helpful.

Reason - much of the pollution is emitted in urban starts and stops, as studies of London street canyons show (Imperial College, Kings College London)

However, authorities proposing such schemes outside London (Edinburgh and Manchester) have failed to win support. The other AQMA local authorities do not have the power to introduce congestion charging - even if one or two agreed to do it, it takes several years to decide and implement. Such schemes are experimental and only pilots might be feasible by 2011.

15 December 2009