Last year's IPPC regulations introduced a new requirement for health authorities to be consulted on every permit application.
The Agency expects companies applying for a permit to assess their operation's potential impact on the health of the local population. The Agency has little expertise in health matters and is looking to health authorities to advise it on the adequacy of companies' assessments. However, health authorities have an undistinguished track record of engaging with environmental matters.
The authors of the new guidance, the University of Birmingham's Chemical Hazard Management and Research Centre (CHMRC), warn that many health authorities are unclear about their role in the IPPC process. Even so, they conclude, they are under a duty to protect public health and failing to respond to the consultation process is not acceptable.
CHMRC wrote the guidance for the West Midlands health authority which it advises on environmental health matters. It has now sent it to all authorities and their environmental health service providers in an attempt to draw attention to the issue.
The Agency is also concerned about health authorities' ability to respond. In a recent paper to its regional environment protection committees (REPACs), director of environmental protection Paul Leinster said "there are doubts whether all health authorities will have the necessary resources and experience to deal with the expected workload."
Professor Rod Griffiths, regional director of public health in the West Midlands NHS Executive, accepts that IPPC is going to be a "learning experience" for all health authorities. But he insists that it also "provided a good opportunity for authorities to engage in the wider environmental health debate."
However, the guidance is not formally endorsed by the DoH or the Agency, underlining the lack of clear responsibility for the health effects of industrial pollution. Professor Griffiths explained that "the brisk pace of IPPC's implementation was too quick for proper DoH guidance which would have taken time to produce."
The Agency's lack of competence on environmental health issues has become an increasingly prominent weakness. The regulator has shied away from debate on health impacts in contentious cases concerning incinerators and cement kilns. The REPAC paper admits that Agency personnel have "difficulty answering" public concerns about the health impacts of industrial releases.
CHMRC's guidance points to a vacuum in the Agency's sector-specific IPPC guidance to companies on how to prepare applications. It warns health authorities that "the lack of specific guidance for applicants on assessing the risk to health from their activities may result in many applications failing to contain sufficient relevant information."
The guidance says that authorities should assess whether an IPPC application identifies all releases to each environmental medium during both normal and abnormal operations. The application should quantify the likely human exposure using the source-pathway-receptor model, and consider health impacts on the exposed population. If an application does not cover these points, the authority should ask the Agency to seek further information from the company.