Environment Bill

Written evidence submitted by the British Lung Foundation (EB18)

Written Evidence for Environment Bill Committee

1. Introduction

1.1. The British Lung Foundation (BLF) is campaigning so that one day everyone breathes clean air with healthy lungs. We offer hope, help and a voice. Our research finds new treatments and cures. We help people who struggle to breathe to take control of their lives. And together, we’re campaigning for better lung health.

1.2. Air pollution is bad for everyone, but for the 12 million people in the UK who live with a lung condition, such as asthma or chronic obstructive pulmonary disease (COPD) it poses a real and immediate threat to their health. A spike in air pollution levels can lead to symptoms getting worse, flare-ups and even the risk of hospitalisation.

1.3. With some small changes, the Environment Bill could provide an opportunity for the UK to become a world leader in the fight against air pollution. The Bill Committee is a crucial opportunity to make those changes.

2. PM2.5 Target

2.1. It is positive that the Bill commits the government to establishing a new binding target for PM2.5 pollution. Defra have publicly made clear they want to set the "most ambitious targets in the world" on fine particulate matter – so this Bill is a critical opportunity to do just that.

2.2. However, the Bill does not currently state what this target will be. The scale of the air quality health crisis requires faster and more ambitious action than the Bill currently promises.

2.3. The UK is currently meeting legal limits for PM2.5. However, this is only because our legal limit is much more lenient than the limit recommended by the international health community. The UK legal limit for PM2.5 is twice as high as the World Health Organisation (WHO) guideline.

2.4. To match the stated levels of ambition, we feel that the new target for PM2.5 should be in line with the guideline (10μg/m3) recommended by the WHO. [1]

2.5. This guideline was set via expert evaluation of scientific evidence by a WHO Working Group Meeting of a broad group of top scientists, representing all relevant research disciplines and engaged in research in various regions of the world. [2]

2.6. There is widespread support for adopting a binding target to meet WHO guideline levels from health and air pollution experts, as well as from across the political parties. Michael Gove, in his role as Environment Secretary, said in 2019 that the Bill should introduce ‘a legally binding commitment on particulate matter so that no part of the country exceeds the levels recommended by the WHO’. [3]

2.7. Defra has also published a technical analysis by two leading British universities that concluded that achieving WHO guidelines across the country is technically feasible. [4]

2.8. Following the guideline was also one of the key recommendations made in the 2018 Joint Select Committee report, "Improving Air Quality", published by the Efra, EAC, Health and Transport Select Committees. [5]

2.9. Committing to meeting this target by 2030 would be in line with what the WHO itself, as the global expert body on the health impacts of air pollution, is calling on governments across the world to do. This includes countries that have far higher levels of PM2.5 than the UK. Analysis by Kings’ College London has also shown that, with the right policies in place, this target could even be achieved in London, one of the most polluted cities in the UK, by 2030. [6]

2.10. Therefore, we are calling on the government to amend the bill and make a legally binding commitment to at least meet the WHO guideline level for fine particulate matter pollution by 2030 at the latest. Amendment 23 would achieve this, and already has significant support from across the house.

2.11. The Bill, as drafted, allows Defra to wait until 2022 to set the PM2.5 target – this is too slow for people with a lung condition, who are affected by the damaging effects of air pollution right now.

2.12. We have a much stronger knowledge of the impacts of air quality than the other areas outlined in the Bill, and experts at the World Health Organization have already set a recommended target for PM2.5.

2.13. We also have a strong understanding of the major sources of pollution such as road transport and the burning of solid fuel and how to reduce these sources.

2.14. Setting the PM2.5 target this year, rather than in 2022, will drive the urgency of action across government, and ensure that we avoid unnecessary delay in our action against PM2.5.

2.15. In the build up to COP26, this Bill represents an opportunity for the government to show that is can be a world leader on issues such as air pollution.

2.16. We should not wait until 2022 to set potentially life-saving new limits. The Bill should be amended to bring forward the deadline for setting the new PM2.5 target. Amendment 24 would achieve this.

3. Improving process

3.1. The Bill fails to set out what criteria or evidence government must consider when setting new air quality targets. The Bill provides no meaningful or transparent role for independent expert health advice in the government’s decision-making.

3.2. The government should amend the Bill to confirm the role of health experts, for example but not limited to the Committee on the Medical Effects of Air Pollutants, in the process.

4. Background on air pollution and health

4.1. Air pollution is linked to a wide range of health problems, including lung disease, stroke, and cancer. It can disproportionately affect certain groups including babies in the womb, children, people with existing lung or heart conditions and older people.

4.2. Air pollution is bad for everyone, but for the 12 million people in the UK who live with a lung condition, such as asthma or chronic obstructive pulmonary disease (COPD) it poses a real and immediate threat to their health.

4.3. A spike in air pollution levels can lead to symptoms getting worse, flare-ups and even the risk of going to hospital. Air pollution has a real effect on quality of life for some people, and nine out of ten patients we support tell us they struggle to breathe during high pollution episodes.

4.4. As Carole from Kent said to us: "Last year I collapsed and was hospitalised. Doctors told me air pollution had inflamed my lungs and put pressure on my heart. I was starved of air. Air pollution is now increasingly trapping me in my own home, and there’s nothing the best doctors in the world can do about it."

4.5. Around one in three children in the UK are currently growing up in areas with unsafe levels of air pollution. Breathing polluted air can cause irreversible damage to children’s growing lungs and hearts. [7]

4.6. Air pollution can worsen existing health inequalities. People living in the poorest areas are often the most exposed to pollution, so exposure to toxic air can reinforce unequal health outcomes for deprived communities. It can also contribute to health inequalities later in life, with children living in highly polluted areas are four times more likely to have reduced lung function in adulthood. This can leave children with lifelong health challenges. [8]

4.7. There is robust evidence of a clear link between high levels of air pollution and increased numbers of patients with breathing problems presenting at hospitals and GP surgeries.

4.8. A BLF funded study, carried out by the University of Dundee, found that on days when air pollution levels spiked there was a large increase in the number of people admitted to hospitals with breathing problems and also of visits to GPs with breathing problems, known as exacerbations. [9]

4.9. PM2.5 is one of the most harmful air pollutants for humans. PM2.5 refers to particles with a diameter smaller than 2.5μm – 30 times smaller than the average human hair - and these small particles can penetrate deep into the lungs, and potentially enter the bloodstream.

4.10. In October 2018, the BLF revealed that more than 2,000 health centres are in areas with levels of PM2.5 above that recommended by the WHO, putting at risk the health of millions of patients and staff. [10]

March 2020

[1] , Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulfur dioxide, Global update, (2005) https://apps.who.int/iris/bitstream/handle/10665/69477/WHO_SDE_PHE_OEH_06.02_eng.pdf;jsessionid=317C6E97E699E5F26D4A0089CF8E8392?sequence=1

[2] , Update of WHO air quality guidelines, (2008) Air Qual Atmos Health 1:7–13 http://www.euro.who.int/__data/assets/pdf_file/0003/78681/E91399.pdf

[3] and Michael Gove asks: If not now, when? (2019) https://www.wcl.org.uk/michael-gove-asks-if-not-now-when.asp

[4] , Assessing progress towards WHO guideline levels of PM2.5 in the UK (2019) https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/825472/air-quality-who-pm25-report.pdf

[5] , Improving air quality (2018) https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/433/433.pdf

[6] , PM2.5 in London: Roadmap to meeting WHO guidelines by 2030 (2019) https://www.london.gov.uk/WHAT-WE-DO/environment/environment-publications/pm25-london-roadmap-meeting-who-guidelines-2030

[7] , Healthy Air for Every Child: A Call for National Action, (2019) https://www.unicef.org.uk/clean-air-child-health-air-pollution/

[8] Fair society, healthy lives: strategic review of health inequalities in England post-2010, (2010) https://www.parliament.uk/documents/fair-society-healthy-lives-full-report.pdf

[9] , Air pollution levels linked to 'spikes' in hospital and GP visits, (2018) https://www.dundee.ac.uk/news/2018/air-pollution-levels-linked-to-spikes-in-hospital-and-gp-visits.php

[10] Toxic Air at the Door of the NHS report, (2018) https://www.blf.org.uk/take-action/campaign/nhs-toxic-air-report


Prepared 17th March 2020