The Institute of Public Health recently made a submission to the Department of Environment, Climate, and Communications in response to a public consultation on developing a Clean Air Strategy for Ireland.
Air pollution and health are inextricably linked and in this submission the Institute made a series of recommendations including the need to adopt World Health Organization global air quality guidelines.
Other key observations made include the following:
- A Strategic Environmental Assessment (SEA), which includes a broad interpretation of health, should be conducted to consider the public health impacts of the proposed policy and maximise alignment with complementary policies and legislation such as the Climate Action Bill 2021.
- A Health in All Policies approach should be incorporated into meetings of the Clean Air Strategic Implementation Group. Membership should include public health professionals and policy officials responsible for the health needs of those who are more vulnerable to the negative impacts of air pollution – such as children.
- Tobacco smoke is a key source of indoor air pollution, yet it is not included in the draft strategy. Protection against second-hand smoke (SHS) must be enshrined within any revised Clean Air Act and reducing exposure to SHS must be considered a fundamental aspect of indoor air pollution control.
- The Institute supports the proposed Solid Fuel Regulations and a population-wide transition to clean, carbon-neutral fuel to protect human health and suggests that any use of smokeless fuels is time-limited to allow for longer term work to take place, such as retrofitting, as these fuels still emit substantial levels of particulate matter (PM). A dedicated workstream to address fuel poverty and support to those who rely solely on solid fuels will be key throughout this transition.
- Collaboration with Northern Ireland is vital to address this transboundary public health challenge. IPH would welcome a formal reporting mechanism on air pollution into the North South Ministerial Council and would encourage the development of a Memorandum of Understanding to bolster cooperation.
- The Clean Air Strategy must make explicit reference to the specific actions that will be implemented to reduce greenhouse gas emissions as part of climate change mitigation and adaptation. The Institute would consider the Clean Air Strategy to have a leading role in efforts to reach net zero before 2050.
- Transformation is needed of infrastructure, transport and food systems in Ireland for health promotion and sustainability and this should be made explicit as a strategic priority and supported where possible by legislation.
- Pollutant emissions data is essential to understand the source-pathway-receptor model for air pollution and to effectively mitigate health harms. A comprehensive, accessible data system needs to be created to link emissions data with health outcomes to address the ‘environmental health gap’.
- The establishment of an independent advisory committee on the health impacts of air pollution would be welcomed to provide government departments with the necessary scientific evidence to inform policy decisions.
Access the full IPH consultation response here or read below.
