27th April 2002

 The Managing Director
Castle Cement, Park Square,
3160 Solihull Parkway,
Birmingham Business Park,
Birmingham B37 7YN
 
 

Dear Sir

I would be grateful if you could arrange that no further unsolicited copies of your company literature be delivered to my address. Due to the complete lack of unbiased evidence available as to the merits or otherwise of incinerating toxic waste I have no particular strong views on the subject, although I suspect that it can hardly be benign. I also have little interest in the cement industry and I find it an insult to my intelligence to have it implied that the proposed development at your Padeswood works will somehow benefit the local environment. Indeed, I suspect that if this were the case you would hardly be wasting good money to convince the local population that our lives are about to be transformed. British Aerospace have not sent us any literature about their new development at Broughton which is less than two miles away.

Being the parent of two young children I am concerned about the health affects that the new kiln will have. However, we are in the fortunate position of being able to move away from the immediate area which is what we will do once the kiln is completed.

Name and Address supplied
 
 

The Irish Times, 2nd April 2002.

The Irish Doctors' Environmental Association (IDEA) has entered the debate on incineration with a warning that no national database exists on the effects of dioxins, furans and other toxic compounds in the Irish population.

Thermal treatment should not be considered as a viable waste management option, the association says.

The intervention of the IDEA comes as the anti-incineration campaign in Cork, where the Belgian company, Indaver, is proposing to build the first hazardous waste incinerator in the State, is gaining momentum, and as plans are proceeding for the construction of a local authority "superdump" in the county as well as two privately-run materials recovery facilities (MRFs).

Indaver is at present conducting a widespread consultative exercise in Cork and says incineration should be viewed as one element only of the waste management process.

The IDEA held its annual meeting recently in Cork, at which opposition to incineration was one of the main items on the agenda.

According to its joint secretary, Dr Elizabeth Cullen, the private meeting expressed serious concerns about the siting of incinerators anywhere in the Republic.
"We have a waste problem in Ireland at the moment, but by burning our waste, and thereby reducing the volume, we simply have a different problem," she said. "Incineration is not a solution to anything. We are opposed to incineration for two reasons. First of all, it does not make sense to burn the Earth's resources; resources that we should recycle and reuse and share with future generations.

"Incineration does not remove or destroy rubbish; it just transforms it into emissions to the environment. The very presence of incinerators creates their own demand, and allows us to continue with our throwaway habits," Dr Cullen said.

"Secondly, we have concerns regarding adverse health effects. There are many types of compounds in our domestic waste, which contain numerous chemicals. It does not make sense to burn these chemicals which will combine in the furnace, releasing unknown compounds, whose composition and effects we know little about, into the environment.

"The decrease in waste volume arises from the dispersal of gases and particulate aerosols. It is therefore impossible to predict adverse health effects of incinerators, new or updated. As a consequence, our association is concerned about adverse health effects due to emissions from incinerators, and we are totally opposed to the process," Dr Cullen said.

Although the Indaver proposal for the Cork hazardous waste incinerator at Ringaskiddy has been vetted and passed by the Health and Safety Authority (HSA), and the company has pledged total transparency for its monitoring systems, the IDEA says that emissions either to the air or in the residual ash will include dioxins, polychlorinated bi-phenyls (PCBs), volatile organic compounds (VOCs) and other injurious chemicals.

Indaver's plans will be thoroughly scrutinised at the expected public hearing once Cork County Council has decided on the planning application, but from first principles the association is unhappy with incineration.

Dioxins, it says, have recently been classified as carcinogenic, yet only a limited number of studies of their effect in humans have been conducted.

"Many of the chemicals produced by incinerations are persistent, bioaccumulative (they accumulate in the body simply because the body is not designed to excrete them) and toxic.

"Furthermore, there could therefore be a long latency period before adverse health effects become visible. They may well be the most problematic chemicals to which natural systems could be exposed.

"Emissions of dioxins from incinerators may be said to be low, but the emissions to air only account for what is inhaled; these chemicals will also be
found on vegetation and soil, and intake will be increased in this way as well as by absorption from the skin. They will return to us when we consume contaminated food," Dr Cullen said, adding that for the general population of industrialised countries research had indicated that dioxins were exerting
effects on people at current background levels found in the environment. Such effects included altering the levels of certain hormones, enzymes and
immune system cells. Also, exposure to PCBs in the womb was associated with decreased intelligence, suppression of the immune system and
interference with the hormonal system of the body.

The IDEA's overriding concern, Dr Cullen added, was that the Irish health service was not geared at present to monitor the potentially harmful side-effects on humans from the chemical cocktail emitted by incinerators.

"Even if there was a database available on dioxins and other dangerous compounds, we would be against incineration. The problem is that no one is measuring the long-term impact on humans of these side-effects. No one is looking," she said.

The IDEA is concerned that ultra-fine particles, of less than 2.5 microns, are produced in the combustion process, but the majority of them, according to the association, are not trapped by the technology now in use. The particles are capable of reaching the oxygen exchange site in the lungs and of causing serious respiratory damage.

There is concern, too, that most environmental safety standards are based on the BATNEEC concept. BATNEEC stands for the Best Available
Technology Not Exceeding Excessive Cost, but Dr Cullen insists it has no direct health significance or benefits, and that the term "safe" cannot be
applied to anything that could potentially cause cancer.

The association says there is no requirement for health-related surveillance of incinerators in the licensing arrangements and that, while continuous
monitoring is required for many substances, only twice-yearly monitoring is called for in relation to dioxins.

Finally, the IDEA is concerned that while the number of chemicals on the European market is approaching 100,000, there is insufficient toxicity
information available for 75 per cent of them.
 

From Sunday Express

 EXCLUSIVE

 By Lucy Johnston

 Air pollution could be behind the growing epidemic of autism in Britain's children, new research has revealed.

 Scientists have discovered that toxic airborne particles  are over-loading children's immune systems making them susceptible to the devastating  brain disorder.

 Now the Government is to investigate the suspected link - which has risen tenfold in the past 10 years to one in 85 children.

 Dr.Robert Maynard, the Department of Health's senior medical officer, has enlisted the help of  toxicologist  Dr.Dick Van Steenis who recently compiled a dossier of
 evidence pointing to a connection.

 This research shows the areas of  highest pollution have four times the levels of autism than the least polluted  areas.

 Dr. Van Steenis also highlighted a recently published 20-year Belgian  study which shows that in one particularly heavily polluted area, 90 percent of boys aged two to nine
 and 55 percent of girls aged between 10-15 develop illnesses linked with faulty immune systems including autism and asthma.

 A third British-based  study, still under way, is comparing levels of toxins in 2,000 autistic children with those found in healthy youngsters.

 Early findings reveal children with developmental brain disorders- all of whom live around incinerator sites - have extraordinarily high levels of chemicals in their blood. Dr.
 Karta Badsha, the Southport- based toxicologist heading research, will also carry out extensive toxin tests in the children's lungs, liver, fat and kidneys and a psychiatrist will
 analyse evidence of brain damage and symptoms of autism.

 Dr. Badsha said, "the levels of toxins we have found in these children's blood is frightening."

 "I believe there is a very strong link between residues of chemicals and autism. The overload means some children who are more prone to autistic-type syndromes can never
 recover."

 Hereford based Dr. Van Steenis, who is to help the Department of Health with its inquiry into the possible link, explained," The increase in incineration and the use of waste
 as fuel across the UK has caused an explosion in tiny particles in the air which the body has difficulty in coping with."

 "Some children's immune systems are hit so badly they can no longer cope with whatever else comes along."

 "The  overload  can cause many problems including inflammation of the brain, behavioural problems and later autism."

According to an official, unpublished study
 
 

Paris, January 21st, 2003. CNIID reveals today the existence of an official epidemiological study showing that waste incinerators provoke the birth of deformed babies.
It was done in one of the biggest regions of the country and takes into account 70 incinerators. The authors conclude that "globally, significant risks for the exposed populations
are observed for two types of deformities:  chromosomal anomalies and other major deformities" (1).

Furthermore, they found "high and significant risk (...) for facial clefts, renal dysplasia, and megacolon". These are, among other things, deformities of the face, kidney and sex.
Waste incineration is thus responsible for the birth of an important number of deformed babies.

For Pierre-Emmanuel Neurohr, Director of the National Center for Independent Information on Waste (CNIID), "Starting from today, Roselyne Bachelot, environment minister, takes judicial
responsibility for every incinerator that is built in France. Waste incineration will be the asbestos of the 21st century, and she has the choice: either to declare a moratorium on the building of new
incinerators, effective immediately, or face in a few years' time a judgement for poisoning". This study adds to the case on the danger posed by waste incineration as such, including the higher levels of
cancer around the Besancon incinerator.

Furthermore, CNIID has asked the minister to clarify her policies on freedom of information. How is it possible that her ministry has known for months that incinerators provoke the birth of deformed
babies without informing at once the public?

An incinerator emits hundreds of toxic substances. According to the environment ministry, when it comes to dioxin, the dirtiest incinerators in France include St-Ouen (at the entrance of Paris)
which emits 4,9 g per year, Strasbourg, which emits 8,7 g per year and Lyon, which emits 4,4 g per year. Dioxin's toxicity is counted in millionths of millionths of gram. CNIID is currently doing a
postcards campaign in favor of the reduction of waste at the source aimed. Such a policy is the only viable alternative to incineration.

For more information, please contact Pierre-Emmanuel Neurohr at + 33 1 55 78 28 60.

(1) Risk of congenital anomalies in the vicinity of municipal solid
waste incinerators, Inserm, Afssaps, Institut européen des
génomutations, not published yet.
------------------------
 

Note: Although the study itself has not been published yet, the following abstract was presented during a conference of  "French-speaking epidemiologists".
 

Background
Although it appears indisputable that municipal solid waste incineration (MSWI) increases the overall environmental load of particulate matter containing dioxins and metals, the evidence of health consequences to populations is very limited. We used the birth defects registry for southeast France to attempt to assess at the regional level the impact of these emissions on birth defect rates.

Methods
We studied communities surrounding the 70  incinerators having operated at least one year in the region during the study period (1988-1997). Each exposed municipality (N=196) was assigned
an exposure index estimated from a Gaussian plume model. With Poisson models and a reference population of the 2683 unexposed communities in the region, relative risks for congenital
malformations were adjusted for year of birth, maternal age, population density, average family income and local road traffic for exposed communities.

Results
Both chromosomal and other major anomalies (mainly facial clefts, renal dysplasia, and megacolon) were  more frequent in the exposed than the non-exposed communities.
Within exposed communities, a dose-response trend of risk with increasing exposure was observed for obstructive uropathies.
Risks of cardiac anomalies, renal dysplasia, obstructive uropathies and skin anomalies increased linearly with road traffic density.

Conclusions
Although both incinerator emissions and road traffic are plausible candidates for explaining the excess risks found, we cannot exclude several alternative explanations,
including exposure misclassification, ascertainment bias and residual confounding. It should be stressed also that parts of the effects observed, if real, might be attributed to old
technology MSWI and the long lasting pollution around them.
 

The closest we have to this is probably the work on childhood cancer by Professor Knox published in June 2000 (Childhood cancers, birthplaces, incinerators and landfill sites.
Knox E Int J Epidemiol 2000 Jun;29(3):391-397).

Knox examined 70 municipal incinerators, 307 hospital incinerators and 460 toxic-waste landfill sites in Great Britain for evidence of emissions causing childhood cancers.
Knox was aware that municipal incinerators had previously shown significant excesses of adult cancers within 7.5 and 3.0 km (Cancer incidence near municipal solid waste incinerators in Great Britain.
Elliott P, Shaddick G, Kleinschmidt I, Jolley D, Walls P, Beresford J, Grundy C Small Area Health Statistics Unit, Department of Public Health and Policy, London School of Hygiene
and Tropical Medicine, UK. Br J Cancer 1996 Mar;73(5):702-10) but that the relative risks for adults had been marginal and that an analysis of childhood cancers seemed to offer a more sensitive
approach.

The child-cancer/leukaemia data showed no systematic migration-asymmetries around toxic-waste landfill sites; but showed highly significant excesses of migrations away from birthplaces close
to municipal incinerators. Relative risks within 5.0 km of these sites were about 2:1. Hospital incinerators gave analogous results. The ratios greatly exceed findings around 'non-combustion' urban sites.

Knox concluded that because of their locations, the specific effects of the municipal incinerators could not be separated clearly from those of adjacent industrial sources of combustion-effluents.
Both were probably carcinogenic. Landfill waste sites showed no such effect.

This study follows on from earlier work by Knox (Migration patterns of children with cancer in Britain.  Knox EG, Gilman EA Department of Public Health and Epidemiology, Medical School,
University of Birmingham. J Epidemiol Community Health 1998 Nov;52(11):716-26)  in which he was not specifically studying incineration but he confirmed the main findings of
that work, based upon a different and independent method.  Specifically that proximities to several types of industrial source, around the time of birth, were followed by a raised risk of
childhood cancer. Combustion products and volatile organic compounds were especially implicated. Within the 16 year limit of the study, the increased risk did not decay with advancing age.
Low atmospheric concentrations of many carcinogenic substances suggest that the mother acts as a cumulative filter and passes them to the fetus across the placenta or in breast milk.

Knox suggested that:
  "As with previous studies of proximities of childhood cancers to industrial sites, and of exposures to pre-natal medical radiation, the excesses were similar for leukaemia and solid tumours of all types.
This is as we might expect for agents with systemic access to the DNA/RNA of all types of fetal cells."

The work by Staessen also touches upon this area but not so specifically (Renal function, cytogenetic measurements, and sexual development in adolescents in relation to environmental pollutants:
a feasibility study of biomarkers Jan A Staessen, Tim Nawrot, Elly Den Hond, Lutgarde Thijs, Robert Fagard, Karel Hoppenbrouwers, Gudrun Koppen, Vera Nelen, Greet Schoeters,
Dirk Vanderschueren, Etienne Van Hecke, Luc Verschaeve, Robert Vlietinck, Harry A Roels, for the Environment and Health Study Group* Lancet 2001; 357:
--

CNIID
Centre national d'information indépendante sur les déchets
51 rue du fbg St-Antoine
75011 Paris
Tél. 01 55 78 28 60
Fax: 01 55 78 28 61

Site internet : http://www.cniid.org

Signed by 52 MPs
Including Flintshire's Mark Tami MP

That this House expresses strong concerns about the Environment Agency's proposals to relax the rules on the burning of a broader range of highly hazardous substances in cement plants; notes that such plants, being designed and built to manufacture cement rather than burn highly hazardous materials, will be able to operate at lower environmental standards than the exisiting specially designed and highly regulated facilities, particularly as the acceptable limit on emissions to the environment will be lowered; notes the lack of requirement to formally take into account the public's view at a national or local level; further notes the need to retain the precautionary principle especially as there is insufficient evidence to prove that the burning of such wastes in cement plants is safe; and calls on the Government to undertake a fundamental review of the Environment Agency's proposals taking into account the recommendations of the 1994-95 and 1996-97 Environmental slect committees.

Full image of the copy received by CANK-includes the names of the 52 signatories

Note: CANK has asked our MP - Mark Tami for an update of what happened to this Motion. we hope for an answer after the Summer recess