Reply To: Oct 08 petition re air pollution


Just received from Professor Hedley – a letter he sent HK Standard, in response to enquiry re government and the apparently bogus public consultation:

In my opinion the Hong Kong Government’s Environmental Protection Department (EPD) response is purpose-designed as a serious deception which is about to be perpetrated on the Hong Kong public.  For example the Interim Target – 1 level for 24 hour particulates is 150 µg/m3.  However this level is so lax that it is already well above the maximum level observed on 99% of the days of the year.  So the government will be able to say that it has achieved the Interim Target -1 on all but 3 days in the year without having made any difference to daily pollutant levels.


Although I doubt we would agree to it they could have set the 24 hour IT-1 for Hong Kong at the 99th percentile for, say, 2006 which would be 135 µg/m3.  That at least would have been a notional tightening of the air quality regulations.  As things stand there is scope for developers to actually push pollution levels upwards so that the upper quantiles of the pollution profile approach 150 µg/m3 rather than 135 µg/m3.


The proposed IT-1 level of the targets actually stipulates a higher level of average annual particulates, at 70 µg/m3 than the present outdated Air Quality Objective of 55 µg.  It is not clear whether they will actually also adopt the IT-1 annual figure of 70 as well as the 24 hour figure of 150.  If they do then this will be a serious retrograde step.  The point is however that they should be selecting an effective 24 hour level together with an appropriate annual standard.  There is good evidence from analyses, considered by the WHO when they set the guidelines, that these are two indivisible measures and not separate issues when it comes to considering public health goals.


It is now very clear that from Minister Edward Yau’s latest pronouncements about the cost of pollution controls, repeated by his new undersecretary Kitty Poon on RTHK Backchat today, that it is government official policy to trade off the health of children (for example in terms of lung growth and development and future health related quality of life and their life expectancy) against the marginal costs incurred by manufacturers to clean up their business.


Our Air Quality Objectives Concern Group (AQOCG), coordinated by Civic Exchange, has repeatedly emphasized that the price being paid for goods manufactured in the Pearl River Delta does not reflect their true cost.  The real cost to the community includes the burden of ill health, health care costs and lost productivity due to illness and premature death.  One of the worst outcomes of course is damage to the health of growing children.


The low level IT-1 targets were intended for poor countries, with low capacity to tackle air quality problems, as an “entry level” approach to environmental management.  They are not there so that rich regions like Hong Kong can procrastinate over urgent environmental health matters.


The EPD claims that other socioeconomically advanced countries and regions have not yet adopted the WHO guidelines.  However none of these countries have anything like the levels of pollution being experienced by Hong Kong and the PRD.  In addition, as pointed out by Dr Alexis Lau on RTHK Radio 3 Backchat today, these countries are actively working on this, in an evidence-based approach, and will predictably adopt more stringent regulatory measures in the near future.  There is now serious doubt that Hong Kong will do this on any kind of appropriate time scale.  The fact that the government has made this announcement in advance of the report from the review they implemented, conducted by Ove Arup at a cost of $6 million, means that the whole process of a supposedly evidence based review has been corrupted.  How many of the independent overseas advisors to Arup would agree with the selection of IT-1 as the next step in environmental management?  Was the Advisory Panel to the Environment Bureau, for this project, consulted before this announcement was made?


The EPD has repeatedly and consistently rebutted or ignored our reports on the attributable (that is avoidable) illness and premature deaths from pollution and the on-going burden of costs to the whole community.  There is no mention of the word health in any of the recent pronouncements by Secretary Edward Yau or Undersecretary Kitty Poon.  Of course when challenged they readily concur that this is a health issue, but when making leading statements to the media they argue that this is a cost issue.  This direction in the government’s agenda is undoubtedly coming from the very top and as a result the Environment Bureau is not a credible independent evidence-based decision making body. 


There is no one in government with relevant background, qualifications and experience in environmental health who has the authority and opportunity to speak to these issues and counter the biased and misleading statements made on the current status of air quality and the potential solutions to it.  To my knowledge no Secretary for Health nor Director of Health has ever made any statement about air pollution and its health effects.  The Department of Health is not involved in any way in deliberations about air quality and safety or the prevention of cardiovascular and respiratory illness which results from it.  So, in this respect environmental health management and regulation is completely rudderless and will only be determined by the narrow and mistaken viewpoints of the senior management (CE, CS and FS) on the costs of a clean up, rather than the external costs to population health.


The environmental health lobby led by agencies such as Civic Exchange, other NGOs and the Universities have made a considerable impact on the evidence base, public awareness and advocacy in general.  However the government is digging in and will railroad through cosmetic measures despite the demonstrable need for urgent radical action.


We have debating all these issues for a great many years, but the people of Hong Kong will be breathing dirty air for many more years to come.



Professor AJ Hedley MD

Department of Community Medicine

School of Public Health

The University of Hong Kong