Environmental health officers are concerned with those aspects of the physical environment which impact on the health or well-being of individuals or groups. Atmospheric pollution aptly illustrates the connection. The use of fossil fuels gives rise to a number of air borne effluents the most important of which are sulphur oxides, nitrogen oxides, carbon monoxide, particulates, organic compounds, trace metals, radionuclides and carbon dioxide. Most epidemiological studies show good correlation between particulates and health effects; the correlation between sulphur dioxide and health effects is less sharp, and it has been difficult to show correlation between impaired health and nitrogen oxides or oxidants. Particulates, especially fine ones that cannot be removed by present removal devices, are of particular concern because they can lodge easily deep in the lungs. Trace elements, polycyclic aromatic hydro carbons and other compounds absorbed on these particulates increase the damage through synergistic effects. The human health question is very much to the fore in this and other related areas such as industrial dust emissions and cigarette smoking.
Elsewhere in this issue you will read the story of convictions for breaches of environmental health law which were secured on foot of evidence given by two of our members. The Control of Atmospheric Pollution Regulations 1970 and the E.E.C (Waste) Regulations 1979 were relied on in these cases. The examples should once again highlight the importance of ensuring that local authority programmes of environmental protection and improvement are adopted with the full participation of our environmental health officers. “How could it be otherwise?” you may ask. In the correspondence on the refuse tip case we read:
“At no time prior to this were we informed of the existence of the EEC Regulations, nor were we asked to implement them, although they concern themselves amongst other things with disposal of waste so as not to endanger public health!”
While the matter of faulty and indeed non-communication between Departments of Government, Local Authorities, Health Boards and our members arises in the area of the adoption of the EEC directives and the enactment of national legislation in the environmental health area, and is a matter of grave concern to us, the intention here is to alert our members and management staff of health boards and local authorities to the significance of the environmental health officer as an expert witness in the environmental health area, and as an essential contributor to the environmental health planning, promotion and improvement activities of the local authorities.
Navan, Co. Meath
10th November 192
A recent court action in the Meath area may be of interest to readers. The case involved the operation of a refuse tip contrary to Section 3 of the E.E.C. (Waste) Regulations 1979. Initially following complaints of nuisance from smoke, litter, rat infestation we recommended the service of a Section 1 10 Notice ( 1878 Public Health Act) and subsequently on non-compliance we advised court action. We also advised action under the E. E.C. ( Waste) Regs. 1979 on the Planning Acts.
Because of the higher penalties the Council law agent decided to pursue the matter under the E.E.C. Regs. I was informed that I would not be required further as action under the 1878 Public Health Act was not proposed.
At the court hearing a member of the engineering staff gave evidence that the tip endangered public health and the environment for a number of reasons including rodents. When asked by the D.J. to explain why rats were a health hazard he stated that he was unable to answer and that his health col leagues would be better able to explain. The D.J.adjourned the case ordering that a health inspector appear to give evidence.
At this stage the Council asked us for a report on the public health aspects of the dump with regard to Section 3 of the E.E.C. (Waste) Regs. And requested that I appear as a witness.
On the witness stand I was asked by the Council Law Agent and defending solicitor to detail my qualifications and training. I was then asked to explain why rodents were considered a threat to public health. I was further asked as to what measures were necessary to operate the dump properly. I went Into some detail on controlled tipping etc. No other technical evidence was called. The defendant was convicted and fined.
I consider this case of some interest because: At no time prior to this were we informed of the existence of the E.E.C. Regs. nor were we asked to implement them. Although they concern them· selves amongst other things with ‘disposal of waste so as not to endanger pubic health’.
Comments on public health matters are still considered(by some people at least) to be the preserve of the health authorities.
Yours sincerely, Al Donnelly, Health Inspector.
P.S. An application for a waste disposal licence under the same Regs. has also been received and we have been asked to report on same.