Take a deap breath before reading..

ACCOUNT OF RUGBY CEMENT COMMUNITY FORUM 24 JANUARY 2007. VESTING HEALTH EXPERTS ON HEALTH PROTECTION, LOCAL DATA, AND CEMENT PLANT REGULATION.

1. PLUME MODELLING DIFFICULTIES AND EXPOSURE (LP: NOTE THIS IS NOT A CEMENT PLANT EXAMPLE: NO MENTION OF ALL THE DIFFERENT PLUMES/STACKS ON SITE ONLY A MAIN STACK IN THIS EXAMPLE)

TIM DAVIES WARWICKS NHS: I mentioned we have not tried to model a plume, modelling plumes is not my area of expertise but I do know enough to know that it is full of difficulty, like what sort of weather conditions you will have and where it will come down, and it will change, and all sorts of things so we went for the simplistic way. The cement factory is here and we went for - not quite circled around it. If you wanted to do something about the plume now what would you do - you would draw it, and...... It is quite difficult to do.....given that it changes and therefore the exposure in different areas will be different from day to day, its then quite difficult to put that in.

ROY MCCARTHY: Well the wind blows in this area for something like 280 days a year in the same direction....
TD: well it is something you could do if people wanted to see that sort of analysis. It would raise questions about the population exposed... Type of population and age and what is coming out of the stack and the concentrations and it would only give you an estimate of impact but what it does not give you is any objective data on exposure. It gives you a general things about the direction the plume is in, but it does not give you the exposure. The key thing is not what is coming out of the stack, but what people are exposed to....

CAROLYN ROBBINS: Thank you for presentation and questions.

DR PAT SAUNDERS HPA: (giving an example of a MAIN STACK ONLY plume model and health effects - NOT A CEMENT PLANT) We have here Plume dispersion model in another plant - see south westerly wind and the grey areas are where the concentration is highest so you would say the people who live in the shaded areas are more likely to be exposed than these areas, so you get a curious protective effect from living closer to a stack. But this is still only a statistic. And these models have not been validated using personal exposure data. They have been validated using environmental data, but that isn't necessarily the same as the exposure data. A personal bugbear of mine is that these models take no notice of personal behaviour - they presume that anyone living hear is going to be breathing that stuff in 24 hours a day - it takes no account of people working, nor how long they have lived there, not how much time they spend indoors, and the types of processes. I think that is grossly misleading.


2. HPA SUGGESTS LOOKING ON NATIONAL BASIS AT SIMILAR SITES (LP: WHEREVER THEY MIGHT BE SIMILAR TO RUGBY?)

PAT WYATT: statistics only as good as you want them to be.. Why have we wasted all this time when we could have done other things. We could have
done a study - cement is hazardous and dioxins are not measured - if Dr Saunders would live in Rugby in this dusty area?
PS: Yes.
CR: What exactly is your question Pat - are you just asking Dr Saunders if he would live here?
PW: No I am asking him about the HPA and that the statistics in this area can't really tell us anything?
PS: "It is a very fair point. In terms of single site studies the considerable scepticisms of expending resources on those sorts of studies. If science suggests any sort of relationship WE SHOULD BE LOOKING ON A NATIONAL BASIS AND LOOKING AT DOZENS OF SIMILAR SITES"
(LP: Where would they find EVEN one similar site like RUGBY to compare with?)
You could then expand the numbers. If the evidence of the science tells us that there is a plausible link between exposure to chemical X and health effect and the source of those chemicals is A SPECIFIC plant certainly we would be prepared to look at a large scale study. But in order to justify the costs it would have to be compelling as it is hugely expensive.


3. NUISANCE AND STATUTORY NUISANCE AND TOXIC POLLUTANTS:
WHAT EXPOSURE IS "RECOMMENDED" TO TOXIC POLLUTANTS?
DOES EXPOSURE TO CEMENT PLANT EMISSIONS EQUATE TO NUISANCE?

LILIAN P: What sort of daily exposure/dose of chemicals such as thallium;cadmium; Arsenic; mercury do you recommend? We know the plant gives these out and falls down in the vicinity .. The people have constant exposure to this.. 350,000 people die in Europe every year from air pollution - we know that even the EA and Cemex say that children should not live near the cement works, so is there a recommended daily dose of pollutants?
PS: It is offensive to suggest that people should be exposed...
LP: No no.. I....
PS: the clear indication from your question is that I would recommend the public to be exposed to toxic chemicals and for the record I am a public health professional of 30 years experience, and have spent entire 30 year career studying effects of pollution.

The question about exposure to "nuisance" is a matter for the LA and the LA would need to assess it if there is a "nuisance", that would be statutory nuisance and they are under an obligation to investigate it. You also made a statement that people are being exposed to that cocktail of chemicals and I cannot comment on that I am not involved personally in this particular issue, but I am sure if you could show us data I am sure my colleagues in the HPA would look at it. If you supply them with data that demonstrates exposure then we would be perfectly prepared to assess that. I am not aware of that. I don't know if the Environment Agency are aware??? (THERE WAS A LONG PAUSE AND NO ANSWER)

CR: I have got Martin. MARTIN EVERSFIELD: .. About asbestosis..... Then the nuisance is not the responsibility of the Local Authority but of the Environment Agency.
SEAN LAWSON: This is not a question for Dr Saunders to answer.. We have been through this before. We have been going over this ground on a number of occasions at different forums. The emissions from the cement plant are principally covered by the PERMIT issued by the EA, and they are the regulatory force upon it. STATUTORY NUISANCE IS EXCLUDED. We have exhausted that. There are perhaps other things we can move on to.
CR: Do you have a specific question?

Martin: You alluded to prevailing wind and weather conditions damping down - so I ask you..? And the other question is what factors you would recommend we investigate in Rugby? Are we on the right track or the wrong one?
PS: There are three issues there. I may have mislead the group in my answers about statutory nuisance. It was not specifically about Rugby Cement - I was talking in general terms. So the next question was.. Once you have made the decision there is something plausible then clearly you would want to take
into account weather conditions and you would want to consider some very heavy duty environmental monitoring. But that would follow a decision as to whether there was justification for a single site study. And that would mean data by emissions; environmental monitoring data ; health assessment data - all to be provided provided. I would certainly be prepared to be involved in making those sort of judgements and and I understand colleagues in the HPA have provided that sort of support.


4. INDUSTRY HAS TO COMPLY WITH PERMIT TO BE SAFE: INDUSTRY HAS TO COMPLY AND ADHERE TO CONDITIONS AND STANDARDS: SHORT TERM EXPOSURE VERSUS LONG TERM EXPOSURE:

CR: In view of time limits I have 5 more people:
NEIL SANDIS0N: What would be interesting is how you measure short term exposure against cumulative exposure. We would be on seventh heaven here at this site - we have a cement plant, a landfill nearby, 3 big primary schools in close proximity. It was very interesting what you said about expectant mothers, how it may be passed on. How would you measure? We have had several pollution incidents over a number of years; how would you measure that short term exposure - problems with eyes and skin - with cumulative exposure are the sort of concerns we have with respiratory and bronchial problems? I accept that what was said about it being difficult to measure but Clearly they are the concerns aren't they?
PS: It is very difficult to do. We would work on the basis that ALL the regulated industries would HAVE to COMPLY with the CONDITIONS set by the Regulators. We have confidence in those standards - IF THEY ARE APPLIED - and IF IF THEY ARE ADHERED TO THEY ARE PROTECTIVE OF PUBLIC HEALTH.

5. HOW TO DECIDE IF LOCAL STUDY IS NECESSARY AND TO ENGAGE WITH COMMUNITY:
CONFOUNDING FACTORS:

NS: How do you intend in engaging with the local community for working out parameters for your study?
PS: Firstly there is the process to go through to determine whether the study should be conducted or not. Then once that decision has been made and at some stage that would involve liaison with the local community. Then various options open to the local Health Agencies: there are existing bodies; Community forum like this could be appropriate. BUT before you get to that stage once you have made the decision then it is imperative to involve the community. That does not necessarily mean that the community would get everything it thought it should do, but at least it should be part of the design of the study itself. But the step before that is when the Agencies have to make a decision on whether it is justified to make a study at all. I do not know at this stage whether that decision has been made in this circumstance? If you are asking me about Rugby Cement then I cannot comment on data, but in terms of principles the community involvement would have to be in the design plan. But a decision would have to be made by professionals with support from academics as to whether was study was necessary.

CHRIS HOLMAN: One of the factors we have not taken into account in New Bilton is half a mile to east was a foundry that lit up every morning and threw out an enormous amount of emissions and no controls. People worked there and with no masks and lived locally in New Bilton so environmentally there are a number of issues that PREDATE anything to do with the cement plant.
(LP: a cement plant has been here since about 1860 - the new one since February 2000.)
PS: That is an important statement and a very important potential confounder.
CH: As Lilian alluded to earlier there is still a pile of foundry sand right besides the houses and is also being built on.

6. DUST AND LOCAL POLLUTION - WORRIES FOR NEW BILTON AND LONG LAWFORD. CEMENT PLANT WORKERS WEAR MASKS - ISSUES FOR LOCAL COMMUNITY. DIFFERENT ASPECTS:

ROY SANDISON: There are studies about workers in cement plants. One of the worries I had was the bagging plant - they had masks - I think there are
issues. Clearly the perception in new Bilton is extreme worry about the health consequences. When you look in your window and there is all dust - that does worry you. We all worry because we know that a few years ago they said that smoking was not bad for you - now we know passive smoking is bad for you. A few years ago asbestos was not bad for you as well. Now clearly, clearly, the problem is, and I don't want to be unkind, but there are different positions on different studies in terms of small area studies, and clearly we would if we had had the PRESENTATION before tonight we might have been able to put in different positions. That is the problem. If you will not agree, that there are different positions? This is Rugby and clearly there is a high level of worry that the EA has picked up on. We cannot just take one position. Next week we should discuss this again as there may be an alternative position to what has been discussed today.
PS: I agree there will be other opinions but I have not seen any official guidance from any Agency in the world that would contradict what I have said here today. All the guidance differs in emphasis, but it is all based on the same hierarchical approach and you need to tick certain boxes before you go on to study and those boxes are as I described: environment data; environmental exposure; plausibility; and spatial, temporal, biological. I don't think you will find any technical scientific data that will be different at all.

GARETH PREWETT: Not much difference between near and far - statistically. We have discussed so many times the exceedences, and the shut downs, and cement mills and for my case I have seen hundreds and hundreds of belching trucks going through our town. I have white dust all over my car and then I have to walk my children to school all in that. Regardless of what the statistics say I think in a few years time we will reap the benefit of that. The people in New Bilton suffer from deprivation, but they cannot do anything else. It seems to me if the cement works were not there then they would not have to live in that environment. I just wonder what is in the air - I have this cement plant in front of my lounge window. I find it odd that you come here and say it makes no effect.
PS: I do take your point, but I am talking about the difficulties of doing studies. For the circumstances you describe I have tremendous sympathy. In terms of you doing a small area study to substantiate your concerns... The difficulty is..
GP: You come out with these statements and then you seem to retract them. You say there is no problem. You seem to be disagreeing - one moment you say there is no risk to the people of Rugby, and we are all breathing good air, and have good health, and then you seem to say it is very difficult to get the data.
PS: Dr Davies was describing "large areas", which is routine, and I am talking about those "small areas" and focussing on an area round a particular plant, or several conditions, but the circumstances you describe regarding the dust it seems self evident that I cannot comment on the specific fact, but

it seems to me IF THE PLANT IS NOT OPERATING TO ITS REGULATED CONDITIONS THEN SOMETHING SHOULD BE DONE ABOUT IT. And you don't need to be looking for some kind of health assessment to validate that - EITHER THE PLANT IS COMPLIANT OR IT IS NOT! And that has always been our view and we advise health authorities and Local Authorities all over the country. And the first priority is make sure the plant is COMPLYING with the STANDARDS. Everything else is subsidiary to that.
GP: Lilian mentioned chemicals off the top of her head, and we know they are being emitted from the chimney. It is the nature of the process. Does zinc come out of the chimney?
CR: I understand what you are saying Gareth but what you are asking of Dr Saunders is not relevant. They are technical questions for the right people.
GP: I understand, but I am trying to make a point that it is difficult for us to take on board the figures that we have had the figures of Dr Davies when there seems to be a view by yourself - if I understand what you are saying - that it is too difficult to measure the impact?
PS: On a single site basis yes. It is very challenging to do - not impossible - but very challenging and you really have to meet the criteria I have laid out today. We are talking about two different things.
GP: Are we talking about the environment of the cement works?
PS: NO.


7. PRECAUTIONARY PRINCIPLE TO BE APPLIED : PARTICULATE AND PEOPLE TO STOP DRIVING CARS

CR: We must move on. Very quickly then.
NOREEN NEW: I am confused that unless we have facts that people are suffering illnesses we cannot actually say there is a problem? I am confused - because you are in health protection, and we have to get ill first and then?
PS: No I did not say that.
NN: My point of view is that surely if we have precautionary principle should we not say that prevention is better than cure.
PS: Yes but Precautionary Principle does not mean we will not do "anything" just in case.
NN: But we KNOW there is a problem.
PS: NO! we do NOT KNOW there is a problem. I do not know about this particular case, but over the years I know you cannot say that until you have investigated the exposure and health effects. I did not say that you have to wait until you have health effects, but that in order to justify, you should. If there is an exceedence of a health-based standard you just address the issue. You don't need a health based study. If there is a statutory nuisance, and I am not referring to Agency regulated processes, you abate it. If there is an excess of disease then you investigate it - an excess of disease from the health agency. They need to investigate it. But unless you have got the data we cannot ..
NN: But we know that particulate causes problems and ..
PS: Then in that case everyone would stop driving cars.
NN: That is a separate issue. We are discussing an industrial process not cars.
PS: All right then, if this plant, is this plant then the source of exceedence of..
NN: particulates yes
SEAN LAWSON: (barely audible) matter of public record
CR: I think we are getting bogged down in an area that is not relevant to this area of discussion.

8. INCONCLUSIVE ON FACTS AND EVIDENCE ABOUT THE AREA - IS CEMENT PLANT AND TYRE BURNING SAFE? ONUS OF PROOF TO BE ON THEM TO PROVE IT - NOT ON US.

ROY MCARTHY: I think you have convinced us that what we are looking at is inconclusive facts and evidence, but you are shaking your head. We are the people who may suffer if this is not right, but surely if someone is asking to do something that causes even the slightest risk of health to our children and community then surely the onus is on them to prove to us that this thing will be safe, and at their expense, rather than the way we are going around. We are all fluffing around, but we want to know is IS THIS THING SAFE? AND CAN IT BURN TYRES? From the information we have that is NOT THE CASE so why this INDECENT HASTE to let the people do this dreadful thing and to burn tyres in the community?
PS: I cannot comment on the specifics but what you describe is a matter for the regulators and the regulators WILL enforce health based standards - so that SHOULD happen. And my experience is that the regulator enforces health based standards and if these standards are breached there is an OBLIGATION to do something about it. I think that system already exists. The HPA certainly has confidence in the regulatory process - that is presuming that the Law is enforced and is adhered to. If a process, an unspecified process, does not operate to the standards that apply for it, then that is another issue. But the health based standards are based on a wealth of evidence and research and are the best available standards to us at the current time.
RM: The question is who is the onus of proof on? But we have stuff being pumped out of the chimney and who has the onus to say if they can burn tyres?
CR: That is the Environment Agency.
RM: They should be able to tell us that it is definitely safe, sufficient assurance, but based on what Dr Saunders says it is definitely not.
CR: That is not what he said at all.
RM: He said it is inconclusive. Can you answer that Dr Saunders?
PS: No I am sorry. I don't agree with that statement. I CANNOT COMMENT ON
THE SPECIFICS OF THIS PLANT.
RM: I am not asking you to do that. The current information as presented tonight is inconclusive.
CR: You are misrepresenting what Dr Saunders said - I am moving on.


9. REASONS WHY HPA IS HERE TONIGHT - AND COMMUNITY FRUSTRATION. NEW BILTON AND AREAS NEAR CEMENT PLANT ARE DEPRIVED AND POLLUTED. GET DOUBLE WHAMMY.

DIANE PASK: Can I just say I would like to reiterate why Dr Saunders is here tonight - out of constant questions about small studies, and to explain that the PCT stance was always, and still is, that they have a lot of difficulties in proving anything, and that is why Dr Saunders is here. But having said that I have sat here this evening quite disappointed and frustrated because we are saying that small studies are not that much help and we are also seeing statistics that on the face of it don't appear to be telling us what we think they should be. I think therefore there is frustration in the community, so where do we go? There are problems, we see the problems, we experience the problems, we hear the problems. We cannot have a small study, and the statistics on the surface seem to show no problem, and are not that much help. So where can we go? And I would also like to say in relation to that there is a huge research that toxicity can affect the human cells in a very bad way, and that people who eat well can withstand that much more than people who don't. Therefore I say the people who we are hearing are deprived are facing a double whammy, as they do not have the money to buy the right kind of nutrition to fend of the toxins that they are being exposed to. The frustration is high.
CR: I don't think Dr Saunders can answer that it is nothing to do with the discussion.