The IPPC regulations introduced a requirement for the Environment Agency and local authorities to consult local healthcare trusts on permit applications. Primary care trusts (PCTs) are now expected to advise on impacts on human health.
However, the new regime exposed a lack of expertise on pollution and health in both PCTs and the Agency. In 2001, unofficial guidance aimed at plugging the gap was published by the University of Birmingham's Chemical Hazard Management and Research Centre (ENDS Report 320, p 9 ) - now part of the new Health Protection Agency.
The HPA's Andrew Kibble says that the draft guidance aims to introduce greater consistency in PCTs' work. It emphasises that most PCTs do not have the necessary expertise to advise the regulator - and urges them to seek support from specialists within the HPA.
The guidance stresses that PCTs should not replicate the regulators' work by getting involved in, for instance, technical arguments over the best available techniques (BAT) to control pollution. The Agency is still smarting from Rugby PCT's criticisms of its handling of Rugby Cement's plans to burn tyres (ENDS Report 345, pp 9-10 ).
The guidance explains that PCTs' role is to advise on the potential health impact of releases, based on an assessment of the information in a permit application. They are not to undertake any health assessment work themselves. Where applications do not contain sufficient information, PCTs should alert the regulator, who is then responsible for seeking further information from the operator.
According to the guidance, PCTs should expect operators to complete an initial screening of releases using the Agency's H1 assessment methodology, or a similar source-pathway-receptor framework. Where a release is of concern, the operator should be expected to do further work to quantify the effect. However, the HPA says there is "no clear guidance" from the Agency on how to carry out this more detailed work.
Mr Kibble said that the HPA and the Agency are considering whether to produce further guidance on the issue. The Agency itself is concerned that current assessment levels for the H1 methodology may not provide a sufficiently rigorous test of health impacts, and are in need of revision (ENDS Report 349, p 51 ).
Nevertheless, Mr Kibble says, H1 has flagged up significant releases which required further risk assessment in many applications across all sectors. In a number of cases, PCTs have advised the Agency to seek further information.
Mr Kibble reports an improvement since the early days of IPPC implementation, but says there is still "great variability" in the quality of operators' health impact assessments. Some were "very good", but others contained "very little" information. In general, he advises that "operators should give more thought on how emissions could impact on health."
The guidance also makes clear that the HPA regards the 28-day statutory consultation period for PCTs to respond as "extremely tight". However, the Agency is unlikely to be supportive given its current drive to speed up the process of determining applications (see pp 5-6 ).