Environmental Health Officers’ Association Summer School
The Clare Inn, County Clare Ireland, May 1982
Michael Woods, T.D., Minister of Health attending
During the past number of years, fuller recognition of our service has come from abroad through the placement of overseas students in environmental health services inIreland. In this regard I am pleased to again welcome two students from the State of Qatar, attached to theDublinCityenvironmental health office, who are attending this years Summer School. – Salim Al. Maleki and Jassim Ali.
I should like also to welcome Douglas Smith, Deputy Chairman, Institution of Environmental Health Officers, and, finally, extend a warm welcome to our Northern friends.
In keeping with the wishes of our membership, expressed by the passing unanimously of a motion on a change of name at our Annual General Meeting in October 1975, we are pleased to announce that our Association is now legally titled:
This change of name has been effected in anticipation of a change of title for the office of Health Inspector to that ofEnvironmental Health Officer. It is in accord with the thinking of the Department of Health, and, we should be grateful to you, Mr. Minister, if you would make the necessary arrangements to have the official title of our office changed toEnvironmental Health Officer.
The basic functions of an Environmental Health Officer have been proposed as including the following (EURO Reports and Studies 29):
These last three elements, together with a host of other related activities, have characterised, in large part, the work role of our membership, from the time when our Association was first incorporated some twenty eight years ago.
Unfortunately the title “Health Inspector” belies the role designated and is associated in the minds of the public, virtually exclusively, with activities directed at surveillance, enforcement and prosecution.
The title Environmental Health Officer” is an apt one and recognises the professional role already operating in the service. While enforcement and prosecution activities are legitimately pursued, functions carried out daily around the country bring a whole host of tasks to mind which characterise the office in a much more complete way. Planning, coordinating, promoting, liaising, instructing, guiding, educating, motivating, researching, pacifying, satisfying, assisting, resolving, averting and abating – are words used to describe tasks performed in environmental health by our membership. The great variety of environmental health problems and challenges encountered require responses of many kinds and demand a high level of knowledge, expertise and tact to ensure that optimal solutions are adopted.
It is important that the image of what our office is about is complete and accurate so that our efforts receive public support and commitment. Environmental health is everyone’s concern, and the promotion of healthful living conditions is very much our business.
As Environmental Health Officers we have enjoyed significant success in delivering environmental health messages. In recent times these efforts have included the organisation and delivery of national food hygiene courses, involving other professional organisations such as CERT, AnCO, the Health Education Bureau, the Irish Hotel and Catering Institute, the Vintners’ Federation of Ireland, the Licensed Vintners’ Organisation; and educational establishments, including the Regional Technical Colleges, Dublin Institute of Technology – Cathal Brugha Street, the College of Marketing and Design, the Army School and Shannon College of Catering. It has been encouraging also to experience the cooperation and good will which were extended by industry generally, and from the trade unions, principally the Irish Transport and General Workers’Union. Bord Fàilte has encouraged and promoted hygiene in a most practical way, including the publication of the booklet “Interview” which is used as a text book for these courses.
Activities are afoot in the area of school health education, and our Association is pursuing a programme of environmental health education in the adoption and promotion of guidelines and standards.
Public awareness of environmental health matters has increased in recent times. The ecological model of our environment, which recognises that elements in the model are interconnected, interrelated and interdependent, highlights for us the importance of ensuring that organisations such as An Taisce, the Irish Quality Control Association, and wildlife protection groups are encouraged and given active support and recognition in their efforts to promote environmental health and hygiene. In addition, key organisations and personnel having a recognised responsibility in shaping environmental attitudes, such as teachers organisations and the Environment Council, should recognise the significant human health question which underlies all environmental issues, and encourage input in their programmes from our Association. Government Departments having environmental protection responsibilities and that promote improved environmental conditions include the Departments of Education, Labour, Trade Commerce and Tourism, Environment, Agriculture and Fisheries. To these Departments I would like to put on record that our Association is ready, willing and able to cooperate fully with them in ensuring that their environmental programmes take full cognisance of the human health issues involved.
While many individuals and organisations are committed in word and action to protecting and improving our environment, there are, unfortunately, far too many who show a complete disregard for public safety and comfort. Such individuals are to be found in urban and rural areas, and have no hesitation in engaging in indiscriminate dumping of litter, organic and toxic wastes.
Public health has been endangered by the irresponsible discharge of human and farm animal wastes to some of our watercourses; and antisocial littering of our urban areas is a national disgrace. The orchestration of efforts to ensure that this kind of activity becomes socially unacceptable and that those who engage in it are brought to task is fully supported by this Association.
The Department of Health has shown courage and foresight in directing its efforts in the area of environmental health education. The McCaughey Report, the National Hygiene Campaign and the establishment of the Health Education Bureau has directed effort where it was very much needed, with the aim of promoting knowledge, attitudes and action for healthful living. The recent decision of the Minister for Health to make food poisoning a notifiable disease is welcomed as another mechanism to ensure that preventive measures are highlighted and public awareness improved.
Our Environmental Health Officers’ Association is very much behind these developments. We also acknowledge the establishment of an improved career structure, and look forward to the day when a Chief Environmental Health Officer heads up the environmental health team at each of the eight Regional Health Boards.
Footnote: In an interview the chairman highlighted the reality and extent of irresponsible discharges of human sewage and farm animal wastes into our water courses and called upon government departments, such as Environment, Education, Agriculture and Labour, to make a genuine effort to educate the public on matters affecting the environment. (See: ‘Woods lauds hygiene, inspector recalls slugs’, Arthur Quinlan, Irish Times, May 29th, 1982)
Annual General Meeting
Athlone, October 15th 1983
The exploits and achievements of great men and women spur us on to greater effort. Their contribution to the public good is like the proverbial “breath of fresh air”. John Graunt, the father of health statistics, was such a person. Analytical studies in 1662 and 1681 enabled him to demonstrate successfully four of the most important facts that vital statistics disclosed. First, he made clear that there was a certain regularity in the occurrence of phenomena, which, considered independently, may appear to be merely the play of chance. Secondly, he pointed out that there was always an excess of male births over female births, but that in the population alive at any time, the number of the two sexes was approximately equal. Thirdly, he showed that the mortality rate was relatively high in the earliest years of life. And, finally, he found that the death rate in cities was then higher than in rural areas. In his Observations Upon the Dublin Bills of Mortality, Graunt referred to the importance of accurate and complete data, recommended an exercise for improving data collection in Dublin, and claimed that “an eight or ten pound per annum surcharge would make the Bills of Dublin to exceed all others, and become an excellent Instrument of Government.”
Graunt categorized years as “healthful” and “sickly” and, on the basis of his [Error: William Petty did the Dublin work. Grant was already dead].analysis of the Dublin Bills, selected 1641 as the “Standard of Health”. He ventured to make a“standard of the healthfulness of the air” and the“wholesomeness of the food” from the data on disease.
The Bills of Mortality were introduced during the previous century and were weekly compilations of the burials, baptisms and marriages recorded in each parish. Graunt described the mechanism of collection of the data in the following words:
“When any one dies, then, either by tolling or ringing of a bell, or by bespeaking of a grave of the sexton, the same is known to the searchers, corresponding with the said sexton:
“The searchers hereupon (who are ancient matrons sworn to their office) repairto the place where the dead corpse lies, and by view of the same, and by other enquiries, they examine by what disease or casualty the corpse died. Hereupon they make their report to the parish clerk, and he, every Tuesday night carries in an accompt of all the burials and christenings happening that week to the Clerk of Hall. On Wednesday the general accompt is made up and printed, and on Thursday published and dispersed to several families who will pay four shillings per annum for it.”
John Graunt saw in the Bills a message for posterity and so began a process without which all public health must remain in the dark. William Farr, Compiler of Abstracts to the General Register Officer, remarked some two centuries later that “vague conjecture began to be replaced by numerical expression.” Graunt was obviously a man of broad vision and sound judgement and saw the potential in his new “statistics” of application in relation to the impact of environmental factors on the public health.
This ability to recognize the value of environmental health data and to gather and use data as a means to planning and evaluating environmental health services is very much needed today. In the recent Community Care Review Report the INBUCON Consultants noted that “Little epidemiological data has been acquired to date in community medicine” – and this over 300 years after Graunt!
The present arrangement, whereby health and environmental matters come under the jurisdiction of several government departments, militates against the likelihood of any comprehensive study being undertaken to identify environmental health needs. Indeed the failure of the interdepartmental committee to finalize its report on the role of our officers, coupled with the virtual exclusion of expert public health input from Department of the Environment Reports would seem to suggest that government environmental programmes are designed for the natural flora and fauna and not for our citizens.
Chemicals developed for agricultural and industrial use present threats to the public. The growth of synthetic chemicals in the last 30 years has been extraordinary: more than four million chemical compounds are now recognised; more than 60,000 are comercially produced; and 1,000 new ones are introduced each year. Some make their way into water and food supplies. While there are now substantially fewer dangers from contamination of drinking water by bacteria, the danger of contamination by oil, fuel and organic chemicals are very real.
With the growth in use of chemicals for industry and farming, our waterways have become vulnerable dumping grounds for wastes from these uses. Food supplies as well are subject to contamination or treatment with chemicals in the course of growth, fertilizing, harvesting, processing and storing.
Increased air pollution has been associated with debilitating respiratory diseases, such as acute and chronic bronchitis, pneumonia, and exacerbation of symptoms in people who already have pulmonary disease. Of concern also are poisoning from lead emitted to the air and the possibility of cancer from pollutants such as asbestos and synthetic chemicals with carcinogenic potential.
Hepatitis, certain forms of which have been established as a major causative factor in liver cancer, is on the increase in Ireland. There was a 50% increase in 1982 over the 1981 figures and, because many sufferers become carriers, and those incubating the disease will excrete the virus even before the symptoms appear, this dramatic increase raises challenges in the area of hygiene education and water and food control. However, it can be said that food hygiene is related directly to the external environment. The problems of salmonellosis in livestock illustrates the point. Watering cattle in slurry polluted watercourses can increase the incidence of both human and bovine salmonellosis. Schemes to eradicate zoonotic diseases should not be undertaken without ensuring that appropriate environmental health measures are catered for.
The health effects of many new compounds may not be known until the 21st century. The great variety of environmental health problems and challenges we face require responses of many kinds and demand a high level of knowledge, expertise and tact to ensure that optimal solutions are adopted. We cannot be experts in all scientific areas, yet our training has equipped us to take decisions, because we are familiar with the methods appropriate to the various sciences involved in environmental health.
The dilemma of the specialist and the generalist is not new. It was examined by Aristotle some 2,300 years ago, and his observations should encourage us in our efforts. In the first paragraph of his work “On the Parts of Animals” he observes:
“There are, as it seems, two ways in which a person may be competent in respect of any study or investigation, whether it be a noble one or a humble: he may have either what can rightly be called a scientific knowledge of the subject; or he may have what is roughly described as an educated person’s competence, and therefore be able to judge correctly which parts of an exposition are satisfactory and which are not. That, in fact, is the sort of person we take the ‘man of general education’ to be; his ‘education’ consists in the ability to do this. In this case, however, we expect to find in the one individual the ability to judge of almost all subjects, whereas in the other case the ability is confined to some special science; for of course it is possible to possess this ability for a limited field only. Hence it is clear that in the investigation of nature, or natural science, as in every other, there must first of all be certain fixed principles by which the acceptability of the method of exposition may be tested, apart from whether the statements made represent the truth or do not.”
As Environmental Health Officers our approach should be comprehensive and not fragmented. Our training and experience fit us for the role of ‘general practitioner’ in serving the community’s environmental health needs, particularly in the fields of technical advice, education and environmental health legislation and enforcement.
Over the past 100 years advances in science and technology have been enormous. Our predecessors, particularly in the late 19th and early 20th century, laboured without the benefit of the knowledge now at our disposal. In 1883 Charles Cameron (he later became Dublin City Medical Officer, was knighted and made an Honorary Freeman of Dublin) investigated a serious outbreak of food poisoning at Rosegarland, Taghmon, County Wexford. Commenting on the outbreak, in which 29 people became very ill and two died, after eating boiled beef up to four days after it was cooked during a “very warm” August, he noted:
“the putrescent properties of the meat were due to the presence of some poisonous principle developed in the meat itself” , that “the cooked meat had entered into a state of incipient decomposition before it was eaten” and finally that “the poisonous properties of the meat were perhaps partly the result of disease, partly of incipient decomposition”.
We can see from his report that it was to take some time before the science of microbiology revolutionized our concept of food hygiene.
At a meeting of the Dublin Sanitary Association reported in 1883, which was chaired by Dr. Cosgrove, attention was called to the Registrar General’s Returns, comparing fifty two large towns. The Irish towns had a mortality rate of 29 per 1,000 while the English towns had a death rate of 22 per 1,000. The following resolution was carried:
“in the interest of the health of the public, the executive committee direct attention to the dangerous practice which in bad weather prevails in Dublin of thawing the snow on the pavements by means of a free sprinkling of salt. By this mixture of snow and salt intense cold is produced, and the feet of the passers-by are chilled in such a way as seriously to imperil health; besides, a sheet of smooth ice is subsequently formed. The executive committee suggest that sprinkling the pavements with dry, clean sawdust, sand, or straw, will be found to neutralise the danger of slipping in time of frost and snow and to prevent injury to health through unnecessary chilling of the feet, and the possible occurrence of fractures and other accidents.”
There is no mention here of the causes of the high rates of communicable disease in Dublin at that time, nor of effective courses of action to improve the situation.
By 1908 evaluation of the causes of communicable disease had improved greatly, as we see from Professor McWeeney’s analysis of the outbreak of food poisoning at Limerick, where 73 persons were taken ill and 9 died. McWeeney identified the causative organism and gave an explanation of factors contributing to its growth and spread.
Analysis of disease trends show that the environment is the primary determinant of the state of general health of any population. Some 50 years ago there were 402 reported cases of typhoid in this country with 75 resulting deaths. The virtual eradication of typhoid from Ireland can be attributed to the improvement over the years of our drinking water supplies, the pasteurisation of milk, control of the food supply and improvements in hygiene generally.
Our Environmental Health Officers can claim credit for much of the improvement in the health status of our population. Dr. J.D. MacCormack, one of the best epidemiologists in Ireland at the time, in an article in the Irish Journal of Medical Science of February 1951, highlighted the contribution of a member of our profession. He had this to say:
“That typhus fever was eliminated from Kerry long before the days of D.D.T. and typhoid fever successfully controlled was due entirely to the help and cooperation I received from a most enlightened Board of Health, and from a man who was a veritable prince of Sanitary Officers. John Burke of Killorglin was a man the like of whom one meets only once in a lifetime.”
“If ever a man had a real vocation for his work, John Burke possessed one in excelsis. A call to action would bring a beatific smile to his face. Long hours of ardous toil meant nothing to him. His one concern was to do a completely good job. Add to this a personality that could charm the birds off the trees, and you will appreciate why I call him the Prince of Sanitary Inspectors. I well remember one occasion in the wilds of Ballydavid, away out beyond Dingle, when we were on a typhus extermination campaign. Approaching one house we were met by three enormous and enraged men armed with pitchforks and talking Irish. I often pause to think what would have been my fate had I been alone. I was not easily frightened in those days, but with no knowledge of Irish to help me, my own stubborn determination opposed by an equally stubborn and armed determination must surely have landed me in serious trouble. John Burke was quite unperturbed and started talking to the three menacing figures in fluent Irish. In two minutes he had them laughing, and in five minutes he had enlisted their active help. Not only that – one of these men was the local leader of the I.R.A., and he undertook, at Burke’s suggestion, to get us all the help we required, and guaranteed the active cooperation of every household in the district, a promise which he faithfully carried out. If ever they erect a statue to anyone in Kerry they should set up one to Burke, for to him must go the real credit of rooting out typhus fever from the endemic areas there.”
Great men and women spur us on to greater effort and the example of our predecessors is encouragement to us all.
Challenges for the Future
Our achievements of the past are known to us. The challenge for the future is great indeed. Toxic agents in the environment can present health hazards which may not be detected for years. Environmental health education must be directed to ensuring that the general public are made aware of those aspects of the physical environment which affect their health and of the procedures and practices in relation to the environment which promote healthful living.
The dramatic increase in hepatitis cases is symptomatic of poor environmental hygiene, a significant cause of which is the tendency to exclude health goals from environmental policies. Animal disease eradication schemes cannot succeed without efforts to tackle the environmental causes of such diseases. Control of zoonotic diseases requires the coordinated effort of a number of government departments. Government must have an environmental health policy which has as its principal object the satisfaction of human health needs.
Annual General Meeting
Salthill Hotel, Galway, 1984
In its Seventh General Programme of Work, covering the period 1984 to 1989, the World Health Organization emphasised the significance of environmental health as a prerequisite for health development in all countries. It concluded that the development of national programmes for the prevention and control of environmental hazards has not, in general, kept pace with the increase in environmental health problems brought about by rapid industrialization and urbanization, or by the introduction of new technology.
The World Health Organization notes that foodborne diseases continue to be an important cause of sickness, not only in developing areas, but also in industrialized countries. Foreign agents found in food, including food additives, pesticide residues and biological and chemical contaminants are posing serious health risks, while long term harmful consequences for health from chemical substances in giving rise to cancer, genetic mutations and changes in the human embryo are possible. The report notes potential risks relate not only to the thousands of chemicals already in existence but to the scores more being developed almost daily. The report indicates that international cooperation for the assessment of the health and environmental effects of new and existing chemicals will assume an increasingly important role in the future.
Mans’ activities during the last century have dramatically altered the natural order of substances on the face of the earth. In addition to the production of a multitude of synthetic chemicals, man has, in his quest for energy, compressed millenia of normal evolutionary changes into days. Rapid modifications of the natural environment are, almost without exception, made with the intention of producing improvements and advantages for people. Environmental health problems arise from the fact that byproducts and side effects occur that may result in increased sickness, and even death, in the general population. In some cases the undesirable side effects may be unknown or unpredictable; in other cases they are tolerated as a supposed ‘necessary price’ to pay for the benefits of the energy form. The nuclear power industry is a case in point. It has generated a great deal of interest recently and, subsequent to the showing of the programme – “Windscale – The Nuclear Laundry” by Yorkshire Television (YTV) in November 1983, the UK Minister for Health established an Advisory Group, chaired by Sir Douglas Black, to inquire into the possible increased incidence of cancer in the area adjacent to the Sellafield site.
The Advisory Groups’ Report “Investigation of the Possible Increased Incidence of Cancer in West Cumbria” was recently published and makes interesting reading. The evidence on which calculations into radiation exposure of young people in Sellafield are made is contained in three separate reports produced by the National Radiological Protection Board (NRPB).
The report does not attach great importance to “critical groups” such as laverbread eaters and persons with a strong dietary bias towards fish culled from the relevant areas of the Irish Sea. In making its calculations the report was interested in the majority of the population under consideration, and indicated that “It is these average doses to the population that are most relevant to any risk estimate, and these average doses were used in the NRPB report in calculating doses to red bone marrow.”
While the report refers to the six babies with Down’s Syndrome born to young mothers who had attended school together in Dundalk during the Windscale fire of 1957 and the suggestion by the researchers, Dr. Sheehan and Professor Hillary, that these several cases might be related to discharges from Sellafield, it indicated that the subject fell outside the terms of reference, and included a recommendation that a detailed study to explore the Down’s Syndrome aspect be undertaken “in the vicinity of Sellafield.”
A knowledge of the principles and basic methods of statistics is but one of the several skills involved in the critical evaluation of the health risks arising from ionizing radiation. Statistical understanding needs to be synthesized with environmental health expertise and logical skills to ensure a comprehensive and cogent exposition and analysis of the available information. A person’s mathematical calculations may be flawless, but if the model used to predict additional cancer cases resulting from the activities at a nuclear reprocessing plant is based on flimsy and uncertain information then lengthy calculations will not improve ones predictions. The report extrapolates from prediction models of high uncertainty and creates the impression of a scientific accuracy which is unwarranted.
The terms of reference in the Black Report are so narrow and their interpretations so limited that the report fails to address adequately the issues raised in the Yorkshire Television programme. What is more distressing are the fallacies in logic and the absence of a comprehensive environmental health perspective revealed in the document.
The report, noting the lack of health input, indicated surprise at, and I quote, “the lack of coordination in the assessment of the overall impact of the discharges on the population. Each organisation we spoke to had considerable expertise in their particular area of environmental monitoring, but we were unable to identify any organisation that had the responsibility for assessing all of the information available and deciding on the overall implication of the discharges with regard to the health of the community.”
What an incredible and frightening observation! No organisation could be identified as having the responsibility for assessing the data and deciding on the overall health implications of the activities at the nuclear reprocessing plant at Sellafield. I will be meeting the Chairman of the United Kingdom Institution of Environmental Health Officers on Tuesday, 16th October 1984 and propose to discuss with him the Black Report and the attitudes of the Institution to the health aspects of nuclear energy.
The observation prompts me to ask:- What Minister, what Department of Government, what organization is responsible for assessing all the information available on pesticides used on our food and deciding on the overall implications of such use with regard to the health of the community?
What organisation is responsible for assessing all of the information available on water pollution and deciding on the overall implications with regard to the health of the community? A selection of further questions should be asked and answered in relation to such activities as control of animal diseases, such as tuberculosis and brucellosis and the implications for human health; and the activities of planning authorities and the implications for the public health.
In addition, the organisation responsible for taking action to minimize or eliminate risk to the health of the community should be identified in each case. These questions would seem to be elementary and subject to an easy answer, particularly in view of the fact that we are dealing with matters that relate to serious hazards to human health.
My experience with our environmental health service might not allow me to do as the ghost in Hamlet claimed he could in the following words: “I could a tale unfold, whose lightest word would harrow up thy soul; freeze thy young blood; make thy two eyes, like stars, start from their spheres; thy knotted and combined locks to part, and each particular hair to stand on end, like quills upon the fretful porpentine.” I can, however, confirm that the public health is not only not being adequately protected, it is at present at serious risk because environmental policies in many areas are excluding health goals.
In a case involving the contamination of potatoes with poison at Dundalk, Environmental Health Officers could not seize the food under the Food Hygiene Regulations as potatoes were excluded from application by the relevant sections. When our officers requested Department of Agriculture officers to seize the food they found that their concern was for the “health of the potato” and they had no legal power to remove and destroy the vegetables. Fortunately, the importer cooperated with the Health Board in having the potatoes destroyed.
The 35 member Water Pollution Advisory Council has no Environmental Health Officer representation. Its recent report,“A Review of Water Pollution in Ireland”, carried out by An Foras Forbartha, notes in the Foreword that “Water pollution does constitute an environmental problem.” What should we understand by “environmental” in this context? It is of interest to note that the Environment Council’s report, “Toward an Environment Policy” that, and I quote: “The Council is concerned with the external physical environment, that is the natural and man-made surroundings of urban and rural life. Other aspects of environment – such as health and welfare, social and cultural matters, together with the living and working conditions of individual people – are not the direct concern of the Council.” – end of quote. Water pollution then is noted, not as a health problem, not as an environmental health problem, but as an “environmental problem”. The exclusion of “other aspects of environment – such as health” is a serious matter. We hear of several reports of fish kills around the country. Serious pollution of large public water supplies, in which human health was at risk, have occurred over the past year. There have been a number of episodes in which the Health Board was notified after the event, even though fisheries and local authority officers had early warning and large drinking water supplies have been polluted.
The Department of the Environment Memo “Development Control Advice and Guidelines” of October 1982 is another example where an attempt is made to exclude health consideration from environment decisions. Our colleague, Al Donnelly, has made some very useful comments on the Memo, and I have no hesitation in agreeing with his analysis and repeat his observation that “someone obviously has decided that public aspirations with regard to health standards are such that they can safely be ignored at the planning stage”.
Following our Annual General Meeting in October of last year a message was sent to AnTaoiseach, Dr. Garret Fitzgerald, T.D., seeking a national environmental health plan. In February 1984 we outlined to Dr. Fitzgerald the reasons for our proposal and suggested a strategy for securing a coordinated approach to environmental health. On March 12th we sought a meeting with Dr. Fitzgerald and indicated the seriousness with which we viewed the need for change. On March 29th we made a submission to the Department of the Public Service in connection with the proposed White Paper on the organization, management and operation of the Public Service. In our submission we referred to, among other things, the practice of Government establishing Commissions, Committees, Working Parties, etc. to examine and advise on a variety of significant areas of national concern. We indicated our view that in deciding the composition of advisory groups it is imperative that, where the terms of reference include environmental health elements, Environmental Health Officer representation be ensured.
The Taoiseach’s Private Secretary wrote to us on May 7th last and advised us that the Minister for Health has been concerned for some time at the absence of a general understanding between Departments of their precise responsibilities in the environmental health area. He indicated that the Minister welcomed the Association’s proposal for a national environmental health plan as “a timely and valuable contribution to present consideration of the matter”. The Minister for Health, we were advised, “intends to make proposals for resolving the present unsatisfactory situation”. We met with officials of the Department of Health on 17th May 1984 and made known to them our concerns and recommendations in relation to the National Environmental Health Plan including the coordination of environmental health services.
In the light of the information that the Minister for Health has, for some time, been concerned at the absence of understanding between Departments of their precise responsibilities and had welcomed our proposals as valuable and timely, it was with considerable surprise that we received a circular letter from the Department of Health, dated July 3rd1984 relating to a review of our Environmental Health Officer service. The document refers to imbalances in Environmental Health Officer working time on Health Board and Local Authority functions. No suggestion is made as to an appropriate time allocation, however, Environmental Health Officers are identified as “officers of health boards” and the observation is made that “the organization of their work schedules should reflect this”.
It has been the policy of this Association for some time that a segmented approach to environmental health does a disservice to the public, and can and does lead to serious shortcomings in health protection. Environmental Health Officers are fully conscious of the relationship between pollution on farms, animal health, water supplies, planning controls and food borne disease. The Food Hygiene Regulations cannot be applied effectively without ensuring an orchestrated effort in areas of environmental control, both inside and outside food premises. The appearance of antibiotic resistant microorganisms in food animals, in humans, in the general environment, and in our food supplies presents serious environmental health challenges in relation to the over reliance presently placed on chemicals and antibiotics in agriculture and industry. Good animal husbandry and horticultural practices, which concentrate on environmental approaches to disease control and utilize chemicals and antibiotics in a safe and discriminatory manner, is required. This calls for a major rethink in relation to the controls of antibiotics, pesticides and other chemicals in use.
The recent reports from the United States of deaths from food poisoning caused by an antibiotic resistant strain of Salmonella and of the 28 deaths from Salmonellosis at Wakefield highlights the ever present risk of serious food poisoning outbreaks in this country and the additional challenges arising in our Health Board hospitals. Credit is due to Environmental Health Officers for their achievements in delivering food hygiene courses countrywide and in motivating industry to support such courses. There is, however, evidence of a poor attitude to hygiene and lack of appreciation of basic hygiene practices in too many food premises around the country. Practices, such as the unnecessary handling of cooked meats, the display of such meats and cream cakes uncovered and unrefrigerated at warm temperatures, and poor personal hygiene habits can contribute to food poisoning incidents, are unlawful, and when observed by the general public should be reported to the local Environmental Health Officer. In addition, it would be a significant effort in the promotion of the public health if customers would indicate their objection to proprietors when breaches are encountered.
We are in an age when education is encouraged and the right to know is emphasised. I should like to take this opportunity to congratulate the Connaught Tribune in its very fine coverage in publicising aspects of our Environmental Health Officers’ work, thereby bringing very valuable information to the notice of the public. Environmental health education must increasingly be directed to ensuring that the public are more fully aware of those aspects of the physical environment which affect their health, and of the procedures and practices in relation to the environment which promote healthful living. The provincial and national press, and the media generally, have a major responsibility to ensure that environmental health issues are aired, that the public are aware of their rights in this area, and that deficiencies in our environmental health services are exposed.
Before I conclude I should like to pay a tribute to Martin Devine, our Secretary, to Ray Ellard, our Treasurer, and to Michael Nugent, our Public Relations Officer for their great work, involving considerable time, dedication and effort over the past number of years. When activities are in high gear, particularly during a Summer School year, the normal duties of dealing with correspondence, meeting with government officials, organizing meetings, collecting subs., paying bills, preparing press releases, etc., are significantly added to; and the stresses and strains to which they wholeheartedly submit themselves should be appreciated by all. Not to mention Martin’s courtship, trip to the altar and honeymoon in Rhodes. I am sure you will all join me in wishing Martin and Ita long life and happiness.
I should also like to thank Gerry Heraghty, our Vice Chairman, for his support, and particularly for his assistance during the Summer School. Praise should also be directed to John Shelley who is largely responsible for ensuring that the ‘Environmentalist’ gets to your desks, and I must beg his forgiveness for the odd delay I have caused him in submitting the editorial.
Many other thanks should be extended to contributors to the ‘Environmentalist’, the Year Book and the Summer School programme, and to all members who keep the branches alive and active and promote the Association.
As for the year ahead, a busy schedule awaits us, and some of the plans will emerge and be decided upon in the course of this, our Annual General Meeting. We are in an exciting and challenging time in the field of environmental health, and a prominent role for us in the future is guaranteed by the commitment and enthusiasm of our members and students, and by the significance of environmental control in the promotion of human health.
I intend not to go forward next year for the position of Chairman. After four years I am sure it will have come time for new blood, a new style and new ideas.
To conclude, I should like to refer back to the last century. Lyon Playfair, a Member of the Royal Commission on the State of Large Towns, which was established in 1843, having noted the deplorable conditions of the time, went on to say:
“Civic powers were split up into a number of discordant and often conflicting authorities constantly overlapping each other in their duties.”
Today there is an attempt to exclude a health responsibility from our Ministers for Environment and Agriculture, and an effort to exclude aspects of the physical environment which affect health from the concern of our Minister for Health. It is high time that government faced its serious responsibilities in this area and that protection of the public health was given first priority. Our call for an National Environmental Health Plan must be taken seriously, and we appeal to the public, to our politicians, and to the media to examine the issues and to support our call.
Annual General Meeting
Ardilaun Hotel, Galway, 1985
Ideas have consequences. If pollution comes to mean whatever you decide it to mean, then government departments, by adopting a shallow standard of measure, can claim that pollution levels are satisfactory, even where human health is under considerable threat. The standard of measure used to define pollution and to evaluate the state of the environment has become a sick joke. The words ‘pollution’ and ‘environment’ have been given a new meaning unbeknown to the public and, as Thucydides said of the Hellenic cities during the Peloponnesian War: “The ordinary acceptation of words in their relation to things was changed as men thought fit.”
The environment is increasingly being viewed as separate from people, and pollution is being interpreted in relation to its effects on plants and animals. The Environment Council sees itself as concerned with the external physical environment but not with the health and welfare of people. The Department of the Environment is actively seeking to exclude human health considerations from environmental decisions and, in seeking to justify this stand, claims that the physical planning system is primarily concerned with land use. An Foras Forbartha uses a ‘biotic index’ to ascribe arbitrary ratings to stretches of our rivers. These ratings are categorized as ‘unpolluted’, ‘slightly to moderately polluted’ and ‘seriously polluted’. However, the word ‘polluted’ as used by An Foras does not, by any stretch of the imagination, give any indication of human health risks arising, as significant human health related measures are purposely excluded from their grading scheme. Reports of An Foras Forbartha are confusing to the public, to say the least, and without doubt mislead the public into thinking that health risks are being assessed and attended to, when in fact they are not.
The tendency to ignore human health consequences in formulating environmental policies is growing. The Black Report into activities at Sellafield could not identify any organization as having the responsibility for evaluating the health risks resulting from the discharges at the nuclear reprocessing plant. The Irish Government has approved the construction of a 900 M.W. coal fired generating station at Moneypoint, the flues of which are not to be fitted with scrubbers. In recently recommending that all our oil-fired stations be converted to coal and that additional coal burning plant be planned, the Department of Energy has chosen to completely ignore the health costs of such a strategy. The epidemiological method, which examines the causes and mechanisms whereby disease occurs and is spread and which seeks to identify control measures, is systematically being attacked in the environmental health field. The Inbucon Consultants and the World Health Organization have highlighted this fact and I referred to it in the Foreword to our 1984 Yearbook. In a 1983 Report on a European Community Epidemiological Survey on the relationship of air pollution and respiratory health it was recommended that the epidemiological method be abandoned because of the confusing and arguable results it produces. The trend now is to opt for simplicity; for the certain and the general. What matter if the information is useless in relation to assessing human health risks. Such shallow evaluations must be challenged if we are not to experience the dire consequences of the decisions they spawn.
The use of narrow terms of reference, the concentration of attention on pollution effects on plants and fish life while excluding significant human health related measures, and the inappropriate use of mathematical prediction models and statistical averages, are examples of the techniques which are increasingly being used to assure the public that pollution is being tackled or is not serious.
In fostering the idea that health and environmental matters can be dealt with separately, the government has placed the public at significant risk. Our drinking water supplies are under considerable threat, there is a sizable traffic in casualty meat, and we are being invited to tolerate unacceptable levels of pollution. Land and the environment apart from people has no meaning, and until the standard of measure becomes the effect on the overall wellbeing of people, government department programmes will be beset by failure.
On a more positive note, I am pleased to welcome the publication of the White Paper, “Serving the Public Better” which was launched on September 11th last by John Boland, T.D., Minister for the Public Service. The Minister is to be congratulated for the scope and content of the document and for his promise that its publication heralds a comprehensive and substantive initiative to overhaul the machinery of public administration and the introduction of enabling legislation to see this through.
In March of last year we wrote to Mr. Boland and referred to anomalies that result from divisions of responsibilities for environmental health among several government departments. We indicated that the general system of resource allocation in relation to environmental health related programmes was grossly inadequate and inefficient; and that the public not only had to bear the high cost, but had also to suffer the consequences of poor environmental health protection. The overwhelming need to coordinate and control functions in relation to environment and/or health duties of different government departments was explained, and the need to ensure Environmental Health Officer representation on relevant study groups was outlined.
The White Paper echoes our concerns and proposes changes to remedy some serious defects. The Minister is to examine areas of overlap and duplication among government departments, and the Government is to draw up a programme of priority areas for detailed examination so as to ensure efficiency and effectiveness. These measures are proposed as part of a fundamental and coordinated reappraisal of the machinery of public administration. The Department of Health is referred to as having special priority needs and accordingly a departmental unit for the coordination of policy and the control and development of information technology services in the sector has been set up.
The report acknowledges the Government’s responsibility to protect life, property and community rights, and refers to the difficulty of no one Minister being responsible for managing the delivery of the services provided by some 220,000 public service members. “Better coordination of overall policy” is seen in the report as a prerequisite for the delivery of a better service.
The report accepts the need for an input of experience and expertise from sources outside the public service and, accordingly, proposes to forge a partnership of interest with outside bodies. The Public Service Advisory Council is to investigate and recommend on how such an arrangement can best be achieved. In the Association’s Submission on the proposed White Paper we highlighted the importance of such expertise, and referred to the unfortunate consequences of trying to implement recommendations, which, in the absence of such an input, can prove to be impractical or inappropriate in relation to the professional staff involved in the delivery of a service.
The Minister for the Public Service has expressed his appreciation to us for our Submission and it is with some satisfaction we report that our recommendations have been considered, and are, in some substantial part, dealt with in this White Paper. In launching the Report the Minister indicated that its impetus arises from the Government’s wish to have a public service in Ireland which is second to none. I welcome the White Paper and now look forward to the progress promised.
In addition to our input to the Department of the Public Service White Paper we have sought over the years a national Environmental Health Plan, have made submissions to the Taoiseach, and have communicated our views, either directly or through the Department of the Taoiseach, to the Ministers for Health, Environment, Agriculture and Labour. Our proposals were welcomed by the Minister for Health as timely and valuable, and he has indicated his concern at the absence of a general understanding between government departments of their precise responsibilities in the environmental health field. In addition, we have been advised that the Minister intends to make proposals for resolving the present unsatisfactory situation. We have had several meetings in the Department of Health and have a considerable file of correspondence with government departments on issues such as food hygiene, meat inspection, water pollution, health and safety, and environmental health matters generally.
In the area of meat inspection we were promised a circular letter some three years ago. We have written on a number of occasions asking that the position in relation to meat inspection be clarified by Ministerial Circular from the Department of Health, and have, throughout our period of contact with the department, highlighted the serious defects in our meat control arrangements. Our representations did result in the Minister for Agriculture taking an initiative in relation to slaughterhouses, and we have indicated to the Secretary of the Department of Health our grave disappointment at not being consulted on the proposals. It appears that the Department of Health want to wash their hands with regard to meat control responsibility, despite the fact that meat control is primarily a public health problem. The fact that a significant trade in unfit meat has come to light in recent times, that much of the meat sold to Irish consumers is not inspected, and that liberal attitudes are encouraged in relation to the use of hormones and antibiotics in our food supplies, must raise serious questions about the appropriateness of any arrangements to reserve responsibility in relation to slaughterhouses and meat control to the Minister for Agriculture.
In the area of shellfish control the Minister for Health has considered it inappropriate to meet with us in connection with the recent proposals on the export of untreated shellfish, despite the fact that serious public health questions are at issue. We have indicated our surprise and disappointment at not being consulted, in view of the active involvement of our members in implementing existing controls and in the light of assurances from officers of the Department of Health that our views would be sought in relation to matters of environmental health consequence. We also indicated our concern that a major incident could occur in which the public health could be seriously damaged, our control procedures brought into ridicule and the reputation of our country injured.
Representatives of the Institution of Environmental Health Officers, the Royal Environmental Health Institute of Scotland together with our own Association, represented by our incoming Chairman Gerry Heraghty and I, met at Bournemouth, England on September 24th last to launch the International Federation of Environmental Health. Its objects are to provide a focal point for national organizations of officers whose concern is the control of the environment in the interests of the public health. It will provide a means of exchanging information; publish an international journal and other literature; hold meetings; be involved at meetings at international level; represent environmental health interests to national governments, state agencies and international organizations; promote studies and exchange information on education and research; promote cooperation in particular where problems cross national frontiers; and promote the interchange of persons engaged in environmental health work. Our Association has been given a major responsibility in relation to the publication of a proposed international journal. I have every confidence that this Association will play a significant role in the development of the Federation and in determining its activities into the future.
Directive on Environmental Impact Assessment
On July 3rd 1985 the Council of the European Communities notified Member States of the adoption of an Environmental Impact Assessment Directive. Ireland must take the measures necessary to comply with the Directive within three years. A primary objective of the document is to protect human health and the quality of life, and some serious decisions must be taken by Government on how to organize legislation and procedures to comply with its provisions. I would ask the Government to ensure that full consultations are held with this Association so as to guarantee that environmental health implications are adequately explored and catered for.
In connection with our call for a National Environmental Health Plan, which was first conveyed to An Taoiseach, Dr. Garret Fitzgerald T.D. on 18th October 1983, I would ask the Government to establish a high level environmental health section in Central Government to ensure that national environmental health needs are provided for. Human health and wellbeing must become the standard by which environmental programmes are measured.
Before returning to the business of the Meeting, I should like to thank the members from Galway, especially Andy Halloran and his colleagues, for arranging so fine a venue for this A.G.M. and for their welcome. I also extend my thanks to the management and staff of the Ardilaun House Hotel for their hospitality.
I have been Chairman now for some four years and have been blessed during that time with a dedicated, hard working and talented team. Their commitment to the aims of this Association is very evident in the long hours they spend on yours and the general publics’ behalf; and in their achievements in bringing environmental health issues to the attention of our citizens. I should like to thank Martin Devine, Michael Nugent and Ray Ellard for their help and hard work over the years, and wish Martin and Ray additional success in their new roles.
I wish to thank Gerry Heraghty for his support and assistance as Deputy Chairman and later I will have an opportunity to wish him well at his Inauguration as Chairman of the Association. I have known Gerry for over twenty years now and have every confidence in his ability and talent to give strong leadership to our organization.
It has been a great pleasure to have been Chairman of so fine a group of people and I thank you all for bearing with me and supporting me. After all, the members are the backbone of the Association.