Irish Examiner - 19/05/05
ENVIRONMENTAL Protection Agency (EPA) director Dr Pádraig Larkin’s insistence (Irish Examiner, May 6) that the agency is responsible for protecting human health from the effects of emissions from licensed facilities is somewhat confusing...
... given that the role of the EPA in this matter was never in question.
This responsibility is laid at the door of his organisation quite unambivalently in all the relevant domestic and EU legislation.
What has been at issue is whether the EPA has ever faced up to this serious responsibility?
Unfortunately, there are many reasons why the answer to that question must be in the negative.
For instance, Dr Larkin implies that by adhering to WHO exposure limits the agency is facing up to its remit to protect public health.
WHO guidelines are arrived at following intense political and industrial lobbying and the present exposure limits for the thousands of emissions permitted by the agency relate to mature adults only.
The EPA must be aware by now, following the many submissions since the agency’s inception by scores of respected epidemiological experts, toxicologists, environmental groups and individuals, that the greatest risks posed by persistent organic pollutants, such as dioxins, furans, etc., are to the unborn and developing infant, not a mature adult.
Yet the agency continues to ignore this scientific fact and proceeds with their ‘one size fits all’ approach.
Even if such exposure limits did offer some protection to the public, can Dr Larkin cite one instance where a pollution licence-holder in this jurisdiction ever adhered fully to the limits set by the agency? What possible use do these emission limits have in protecting public health when most breaches are tolerated by the EPA without sanction.
Even when the EPA does take action all licence breaches are prosecuted in the district courts where fines are minimal.
As long as this policy persists, industry will continue to treat EPA permits as little more than a formality.
Dr Larkin’s dismissal of proper health studies in favour of computer dispersion modelling of emissions (a science once described by a former director of the agency as ‘intelligent guesstimates’) is bizarre in the extreme.
A dispersion model is only as good as the information inputted and EPA director general Dr Mary Kelly acknowledged the dearth of reliable environmental and public health information available in Ireland earlier this year in a letter to the secretary of the Department of Health.
John F Kennedy once said: “We enjoy the comfort of our opinions without the discomfort of thought.”
It would seem that as long as the EPA is allowed to remain comfortable with its opinion that WHO exposure limits are sacrosanct, proper baseline health studies are unnecessary and that industry will adhere to their licence limits without proper enforcement procedures, then the public has every right to be very concerned for their health, especially that of their unborn and very young.
Harbour Alliance for a Safe Environment