Good afternoon everyone and thank you for the invitation.
There’s been a lot of talk today, a lot of discussion,
about the need for co-operation and collaboration
between environment and health.
I have been asked to speak about one practical way
in which this can happen, and that’s for the health sector
to become better engaged in national environmental regulation
processes such as EIA and SEA.
I’m going to start by presenting some Irish and international research
on the evidence on how well health is currently considered in these processes,
and then I’m going to present some suggestions on how health can be better integrated.
I will start with SEA.
This was a review conducted for the WHO back in 2010,
and it looked at how well health was being considered
in SEAs conducted across EU member states.
There were eight SEAs reviewed in total from six member states.
Five of the eight came from spatial planning, 1 each from transport, waste and economic development
Five of them came from the local level
and one each from county, regional and national levels.
And the main findings are there on the slide.
And you can see that they centred around three main issues.
Firstly, only half of them really considered
social and behavioural issues in any meaningful way.
Although all of them did look at physical and natural aspects related to health.
And this was reflected then in the use of baseline data.
So those SEAs that understood health in quite a narrow way
used a more limited range of data.
And overall throughout all the SEAs
there was quite limited consideration of the data.
So it didn’t really follow through into considering options and different impacts.
And then the authors went on to look at what the barriers might be.
And they put these into three different areas.
The first one was around institutional factors.
These included things like institutional links with health authorities,
having a dedicated body or commission
and whether health professionals were involved or engaged
in the assessment process at all.
Then methodological factors included things like,
having that broader understanding of health among the assessors,
and really clearly identifying the issues in the plan
that were significant for health and broader determinants of health.
And then procedural factors were concerned with whether
SEA was used as an instrument for integration,
if there was co-ordination with other assessment tools,
and if there was specific guidance available on how to consider health in SEA.
Staying with SEA,
this is a review that we conducted in IPH about five years ago.
And we looked at 10 case studies from
across both Northern Ireland and the Republic of Ireland.
And again four came from spatial planning
and two each from water, energy and waste.
Two were at the national level,
six at the regional level and two at the local level.
And overall our findings reflected those of the WHO study.
In terms of the understanding of health,
we found some sectoral differences in that,
those concerned with spatial planning in general
had a broader consideration of health than those from other sectors.
However, none of the 10 SEAs explicitly mentioned
that health professionals were involved at any stage of the process.
Overall there was quite limited inclusion of health data.
Four out of the ten didn’t include any health data at all
and of the six that did four looked at
social and broader determinants of health
while two just looked at mortality data.
Finally we found quite a wide variation
in whether SEA recommendations referred to health,
and in particular if there was any reference
to monitoring of health or health-related impacts.
And just by way of example, there were two case studies,
as I mentioned, on waste.
One had health as a key area and had detailed indicators
and monitoring in place,
while the other had no explicit reference to health monitoring arrangements.
Looking then at the review of the effectiveness of SEA
conducted by the EPA in 2012,
this didn’t focus explicitly on health,
but I think it gives a good indication of some of the broader issues
in relation to how SEA is being carried out in Ireland.
The findings that I’m going to present here are
from just one aspect of the study,
which was looking at a review of 26 Irish case studies and interviews.
And these were some of the areas that they identified as requiring improvement.
They found that in most cases objectives
were well thought out and linked to targets and indicators,
but they weren’t always quantifiable or measurable.
And in many cases specific limits,
thresholds and timeframes weren’t being met.
There was also a variation across the case studies
to the degree in which alternatives were either selected
and then analysed, and there was a sectoral dimension to this.
Land use plans in particular showed a tendency
towards limited consideration of alternatives.
And with regard to monitoring there were examples of both good and bad practice.
The main issue was where responsibility for monitoring lay.
Again in terms of transparency, at the amendment stage
there were some sectoral differences seen there.
And overall there was a high standard of SEA statements,
but some were quite short and it was felt they could have benefited
from further details, especially around consultation
and how recommendations resulted in changes to the plan.
Moving on to EIA then.
This is a study, a project funded by the European Commission, (IMP)3,
improving the implementation of impact assessment across member states.
And it looked at a number of aspects including how health was considered in EIA.
So this data is quite old at this stage
because the research was conducted in 2004/2005,
but I think at least some of the issues are still as relevant today.
So again health was mostly being interpreted in a narrow way.
Health outcomes like mental illness, anxiety and worry
were less adequately considered than death and serious physical illness,
while health determinants such as educational opportunity,
social capital and cohesion, and the widening of health inequalities,
were seldom considered compared to things like
effects on the local economy, employment and recreational areas,
which were often or always considered.
And with regard to interest groups the biggest concern
amongst those interviewed
was a failure to routinely include health experts in EIA teams.
The overall study also looked at failure to include other interest groups.
And then I have also listed some of the barriers
that were presented as to why health wasn’t better considered.
And you can see a lot of parallels with the SEA findings.
So things like time and cost, health impact assessment capacity,
lack of baseline health data, lack of institutional and professional co-operation,
public involvement and inadequate EIA frameworks.
And then fast forward to the situation in Ireland.
This is the first of several slides that I’m going to present from a report
that was commissioned by the EPA a couple of years ago
and conducted by Golder Associates.
And this is on how health is considered
in national environmental regulation processes.
This slides presents some concerns raised by stakeholders
specifically with regard to EIA.
And it’s worth noting that the researchers commented
that many of the findings reflected that of the IMP study
that took place a number of years earlier.
So overall it was felt that the human beings section of the EIA was quite weak.
For example, a community profile might be loosely described,
but potential impacts weren’t really being addressed.
There was generally a lack of public consultation early on
in the development of the report.
Cumulative impacts weren’t being given due consideration.
There was a lack of transparency in how risks were calculated,
and there was rarely an attempt to link emissions with baseline health data.
Looking at the same report, the next two slides
look at the regulatory framework in Ireland,
compared with four other countries,
the UK, Sweden, Norway and the Netherlands, from a health perspective.
This table looks at EIA and the next one will look at SEA.
in the interests of being able to read the table
I have taken off three rows from the table.
So they had quite similar findings across the country.
So the ones that are missing are,
if a health agency was an authority in the EIA process
and the findings were that didn’t happen anywhere among the five countries.
Health as an advisor was voluntary everywhere,
except for Norway where a medical expert was mandatory for HIA.
And then how was health interpreted?
It was physical and social everywhere except in Sweden
where it was only physical.
So you can see there there’s quite a lot of variation between the countries.
Ireland not doing particularly well
in the comparison with some of the other countries.
And then as I said, this is SEA.
Most of the issues are the same except for the last one
- the review by the competent authority.
I will just give you a minute.
And then the authors looked at some international literature.
They looked at IMP3 and EIA and the WHO study on SEA
which I have already mentioned,
also a WHO report from 2007
on the effectiveness of health impact assessment.
And even though they were coming from three different assessment processes
they felt there were a number of points in relation
to health that were similar across all three.
So this was around early and effective engagement with health authorities,
clear objectives and methodologies for assessing health
and legislative support for the use of health determinants.
And finally the report made a number of recommendations
based around three areas which I have displayed in the left column.
And on the right are recommendations from a 2010 report
by Gary Garavan and others. It was conducted as part of the Strive programme.
And I have put it up there, because you will see there are some similarities
between the two.
So both talked about the need for a more strategic consideration
of how health can be incorporated into environmental assessments.
The suggested tasks of a working group that was proposed
in the Golder report include things like establishment of a centralised unit,
facilitating early engagement by health authorities,
producing guidance, and providing better access to health data.
In terms of capacity building the Golder report
made recommendations around different types of training
that could be put in place.
And finally, both talked about the need for legislative support
around health considerations, but also to ensure the
scope of health issues would take account of known determinants of health.
And then very briefly, moving back to the wider international context,
I just want to mention this report which was conducted by WHO,
the International Association for Impact Assessment
and the European Public Health Association.
And it looked at health in impact assessment.
So as well as EIA, SEA and HIA,
it looked at sustainability appraisal and social impact assessment.
And it suggested that in order for health to be better considered
across a range of impact assessment
there needed to be things again very similar
like consistent use of a clear conceptualisation of health,
access to reliable health data on both proximate
and distant health determinants, again early involvement
of health experts and awareness by all impact assessors
and decision-makers on the interconnections of policies and projects with health.
So that was a whistle-stop tour which actually took me a bit longer
- I usually talk really fast, so I better speed up a bit now
– through the evidence.
I’m just going to try and pull together some recommendations
that have come from the research and also some of my own thoughts
on how these barriers and concerns can be addressed.
I have grouped these under five headings
– legislation, structures, data & tools, guidance and training.
I am not going to dwell on this slide.
I actually thought that there would be much more discussion
about this today and there wasn’t.
But an acknowledgement
that recent legal and policy developments
are moving towards better consideration of
health in environmental processes.
So you would be aware of the EIA directive.
From a public health perspective
the main areas of interest are explicit mention of health
and increased acknowledgement of the importance of participation
and references to Aarhus which Ireland ratified in 2012.
There are many environmental regulations,
the two I have pulled out here are of particular relevance to health
in terms of access to information but also the second one there,
that establishes the health sector to have a legal basis,
a legal role for development planning.
And you have heard this morning about Healthy Ireland
and its actions, one of which is to further integrate
and improve consideration of human health
in environmental protection functions across EPA functions.
In terms of structures then, I think all of the research identified
how the presence or absence of institutional factors impacts
on the degree to which health is considered.
I think the core message is the need for stakeholders
to be involved routinely and at an early stage.
Legislation is an important factor,
a willingness to engage across sectors is critical.
But I think there needs to be structures in place as well,
so some of the suggestions given were things like
having a dedicated unit with involvement from all the parties,
together with or having working groups.
And obviously from a practical perspective
there needs to be access to support and resources
which might include time and expertise,
and these resources need to be fairly distributed.
With regard to data and tools
it’s clear there’s a need for access to reliable data and information.
And I think there was already quite a good discussion on the need for better data today.
So there are some excellent resources available,
but I think there are many gaps in the data,
particularly at the local level and amongst different population groups,
which makes it difficult to look at how a particular exposure
might have different impacts, for example,
due to an existing health or social condition amongst a particular group.
And I thought the example given by Professor Depledge earlier today
about access to blue space and how that differed
amongst socio-economic groups was particularly interesting.
And I think perhaps in the absence of having good disaggregated data,
you know, maybe we can use some of that information
and evidence really to bring to bear on these assessment processes.
I’m just going to touch very briefly on tools,
models that can integrate health and environment,
like HEIMTSA, INTARESE, mDPSEEA.
I think these can be very good tools for better mapping
of causal pathways between exposures and health,
but in the interest of time I’m not going to go into them,
and because I do want to talk a little bit about guidance.
There are again some very good resources available.
I want to talk a little bit about some others
that are available in the broader context,
but I think these could be adapted for use in the Irish context.
The first there was a draft guidance document on health in SEA
which was developed as a consultation document in 2007
by the English Department of Health.
Unfortunately it didn’t go any further.
But I think it could potentially be a very useful template
to follow if there was interest in developing such a resource here.
It lays out the issues in a really accessible way
both for health bodies and for responsible authorities.
And the second one which I have inadvertently referenced as SOPHIA,
it was actually by a Canadian group called Impact Partners.
There are a lot of HIA guidance manuals available,
but I flagged this one up because it focuses on environmental projects
and it provides some details for health authorities
as to how and why they can become involved.
And I think one of the reasons health professionals
don’t get involved with environmental regulation
is because they are uncomfortable with the idea of working
on a platform they are not familiar with.
And this can help them to become better informed
and actively seek opportunities to become involved.
Finally I think it’s useful to consider training needs of practitioners
charged with carrying out assessments.
Over the 10 years that we were involved
in delivering training in health impact assessment
we noticed that an increasing number of participants
were coming from an environmental background.
And they were really keen to learn about how to
incorporate broader dimensions of health in environmental assessments.
These suggestions are based on a WHO project
in capacity building in environment and health,
just things you might want to consider in terms of
putting together a training programme,
things like what’s the baseline availability at the moment,
what your aims and objectives might be,
if you want to have a one-off or continuous training,
who is going to do the training,
what institutions are capable of delivering it,
who is your target group,
what resources are available
and things like quality standards and accreditation processes.
I’m going to finish there.
I think a common thread running through all this
is really an overarching goal for better communication
and understanding between health, environmental and planning sectors,
and I think a real willingness to engage
outside our own area of expertise.
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Teresa Keating, Institute of Public Health in Ireland
Health Assessment in EIA & SEA Processes