Subject matter for this objection
“The failure of this license and of the studies at its basis to consider the toxicity and potentially lethal effects of the nanoparticles, generated by the incineration process, on human health”
Arguments of this objection
This proposed license does not consider all of the hazards caused by incinerators to the general public health. In particular this license fails to mention and take into consideration the extremely serious effects that nanoparticles, which are undoubtedly generated by waste incineration, can have on human health.This license is also issued on the basis of a feasibility study completed in 2002, which also does not consider the risks to human health and to the environment represented by the aforementioned nanoparticles. The feasibility study was carried out before the completion of important studies on this matter and therefore could not consider the effects of nanoparticles on human health. These effects have been recently investigated by scientists and these studies now form the bedrock of a new branch of science called “Nanopathology”. This has also allowed the early prediction of the onset of diseases, similar to the so-called Gulf or Balkans syndrome, in the survivors of the World Trade Centre collapse in New York and their rescuers.In particular the toxicity of nanoparticles was the focus of the European project QLRT-2002-147.
This project, through the use of environmental scanning electronic microscopy, verified, in an innovative and original way, how pathological tissues affected by cryptogenic diseases of oncologic or inflammatory nature, contain inorganic particles of micro- and/or nano-metric size (10-8 – 10-5 m), which are not usually found in healthy tissues. The origin of these particles is predominantly environmental, due to either anthropogenic, or less significantly, natural pollution sources. These particles enter into the human and animal organism through inhalation and/or ingestion. The particles within the above mentioned dimension (10-8 m is the minimum limit the instrument can detect), once inhaled, are able to penetrate from the pulmonary alveoli into the blood stream in a very short time (one minute for those of nanometric size) and at this point may trigger the clotting of the blood in sensible subjects.
The blood stream then, carries them into internal organs (liver, kidneys, brain etc.) and they start to behave as foreign substances generating the formation of granulomas and inducing inflammation.It is known that a chronic phlogosis can be an alarm bell of a pre-cancer condition. Phagocytosis by macrophages appears ineffective in clearing these particles, since the particles are inorganic; therefore once the macrophage dies, they are released again into the body with very little ways out from it. In some cases, it has been possible to observe particles of up to 100 nanometres in size within the cell right inside the nucleus, without breaking its membranes. In around 500 pathological cases observed, the particles have also been classified as not biocompatible, and therefore, pathogenic.It is also widely known and accepted that the majority of the particles produced by waste incinerators, as other combustion processes, are of an aerodynamic diameter <0.1µ and hence fall into the aforementioned nano – or ultrafine – particles category.
It is also known that even the most advanced incinerators cannot efficiently filter these ultrafine particulate: collection efficiency of modern incinerators for respirable particles, less than 2.5µ aerodynamic diameter, ranges between 5% and 30% while particles smaller than 0.1µ diameter will most pass through the incinerators’ filtration systems undisturbed. If unsorted waste is incinerated then there will be emission of ultrafine particles of heavy metals and their detrimental effects on human and animal organism are undoubted.It is also know that to increase the efficiency of an incinerator, often the combustion temperatures are increased and this leads to the generation of finer particles. The higher the combustion temperatures the finer the particles that will be generated and, as previously mentioned, a finer particle will travel further and quicker into the human organism, reaching the blood and therefore the vital organs in a matter of minutes. It is worth remembering that once particles of heavy metals and other non bio-compatible substances enter the organism and, in the case of nanoparticles, the cells’ cores, they can’t be eliminated by the system and hence represent a pre-condition for the pathologies mentioned above.
We understand that the license issued to Dublin City Council for the Poolbeg Incinerator was drafted following the guidelines of the Directive EC 2000/76 on incineration of waste and other EU directives on waste management and disposal but we believe this is not a justification for ignoring the latest scientific discoveries made after the directive was published and after the feasibility study for this incinerator was completed. The fact that the European Directive EC 2000/76 does not consider the ultrafine particles does not mean that they do not exist, neither does it mean that they do not represent a serious threat to human health.This European Directive, with its limitations to pollutant emissions, is clearly based on what is technically achievable rather than on health end environmental data. It is already known, or is a widely accepted scientific opinion, that there are no “safe” levels of many environmental chemical pollutants such as dioxins, other persistent, bio-accumulative and toxic chemicals and endocrine disruptors. It is known and accepted that incinerators discharge into the environment extremely toxic substances, some of which are carcinogenic, and it is also scientifically known that there is no “safe threshold” below which this substances can be allowed in the atmosphere and human organismsThe well established and accepted facts that waste incineration produces, amongst many other pollutants, ultrafine particles of non bio-compatible substances – such as heavy metals – and the demonstrated link between the exposure to these particles and the occurrence of a wide range of serious diseases – such as cancer, sarcomas, neurological diseases, fetal malformations and many others – should deter from issuing a license for the Poolbeg Incinerator.
We have already mentioned the European Project QLRT-2002-147 and how its results now represent the bedrock of a new branch of science called “Nanopathology” and, in light of these results, we believe that the issued license has serious and fundamental flaws with regard to the possible consequences that this incinerator can have on the public health.This license also lacks any directive for a particulate matter (particles of an aerodynamic diameter equal or smaller than 10µ) control policy and system. Monitoring the particles concentration is not enough to protect the public health and an active control system to guarantee minimum level of emission of particulate matter should be in place. We also think that an independent body and not the plant operators should monitor the emissions and that the data should be made available, in real-time, to the general public via a dedicated website. We also believe that a license for such an incinerator should not be issued on the basis of a feasibility study that was completed before the aforementioned extremely important new discoveries on the effects of nanoparticles on human and animal organisms were made.A civil, democratic society should not proceed in building such an oversized incineration plant, as publicly stated by the Irish Prime Minister and other representatives of the government, ignoring the latest scientific discoveries and therefore the possible serious consequences for its population.It is evident how the Inspectors Report and the subsequent Addenda, published on the EPA website, also fail to consider and analyze the potentially lethal effects that the nanoparticles, which are universally accepted to be emitted by incinerators, are known to have on the health of both the personnel working in the plant and on the population living in an up to 20km radius area around it.
The failure to consider the possible consequences of these emissions on the massive amount of citizens that would be exposed to them (at least the whole population of Dublin and its suburbs) could result, in our opinion, in the liability of the license applicant – Dublin City Council – and the EPA for future onset of diseases amongst the population that could be directly linked to the matters subjects of this objection and ignored in all the studies and reports presently completed and published.The location decided for the plant is also unacceptable because, besides increasing the already unbearable traffic of HGVs on the country infrastructure, it guarantees the exposure of the maximum possible amount of citizens to the plant toxic emissions. If an incinerator should be built, in light of all the toxins it produces and of the arguments hereby discussed, one would expect that, by common sense, it would be placed where the exposure to citizens is minimized and therefore not in the centre of Dublin. This decision clearly states that the ease of access for vehicles is valued more than the health of the population.A number of less hazardous technologies, such as MBT, are available and have been used by other modern European countries and should be considered as an alternative to incineration.
It should be of example that the Philippines banned incineration of municipal, medical and hazardous waste, on a national scale, with its “Clean Air Act” of 1999.If a developing country like the Philippines decided to abandon incineration to promote a zero-waste target and re-use and recycle, then such a developed and wealthy country as Ireland cannot be less foreseeing, especially after having spent large amounts of taxpayers money to successfully promote a re-use and recycle culture amongst its citizens.In this document we have only mentioned the key facts at the basis of this objection.We have enclosed a list of some publications that explain in details the arguments hereby discussed but many more are available in literature. We have also included in this objection, some of the aforementioned publications and reports listed in the bibliography.
 4th Report of the British Society for Ecological Medicine, The Health Effects of Waste incinerators, Moderators jeremy Thompson and Honor Anthony.
* “NANOPATHOLOGY The Health Impact of Nanoparticles”, by Antonietta M Gatti (University of Modena & Reggio Emilia, Italy) & Stefano Montanari (Laboratory Nanodiagnostics, Italy). Pub. date: Nov 2007, ISBN 978-9812705549.
 “Incinerators and Human Health – State of Knowledge of the Impacts of Waste Incinerators on Human Health”, Allsopp M., Costner P., Johnston P., Greenpeace Research Laboratories, University of Exeter, UK.
 Aozasa O., Ohta S., Nakao T., Miyata H., Mochizuki A., Fujimine Y., Nomura T. Monthly variation in blood dioxin level, characteristics of isomer composition, and isomer changes in residents near an incineration facility. Bull. Environ. Contam. Toxicol., 70(4), 660-667.
 Agramunt M.C., Schuhmacher M., Hernandez J.M. and Domingo J.L., 2005. Levels of dioxins and furans in plasma of nonoccupationally exposed subjects living near a hazardous waste incinerator. J. Expo. Anal. Environ. Epidemiol., 15(1), 29-34.
 Agramunt M.C., Domingo A., Domingo J.L. and Corbella J., 2003. Monitoring internal exposure to metals and organic substances in workers at a hazardous waste incinerator after 3 years of operation. Toxicol. Lett., 146(1), 83-91.
 Bakoglu M., Karademir A. and Ayberk S., 2004. An evaluation of the occupational health risks to workers in a hazardous waste incinerator. J. Occup. Health, 46(2), 156-164.
 Biggeri A., Barbone F., Lagazio C., Bovenzi M. and Stanta G., 1996. Air pollution and Lung Cancer in Trieste, Italy: Spatial Anmalysis of Risk as a Function of Distance from Sources. Environ. Health Perspect., 104(7), 750-754.
 Cordier S., Chevrier C., Robert-Gnansia E., Lorente C., Brula P. and Hours M., 2004. Risk of congenital anomalies in the vicinity of municipal solid waste incinerators. Occup. Environ. Med., 61(1), 8-15.
 Comba P., Ascoli V., Belli S., Benedetti M., Gatti L., Ricci P. and Tieghi A., 2003. Risk of soft tissue sarcomas and residence in the neighbourhood of an incinerator of industrial wastes. Occup. Environ. Med., 60(9), 680-683.
 Dummer T.J., Dickinson H.O. and Parker L., 2003. Adverse pregnancy outcomes around incinerators and crematoriums in Cumbria, north west England, 1956-93. J. Epidemiol. Community Health, 57(6), 456-61.
 Hours M., Anzivino-Viricel L., Maitre A., Perdrix A., Perrodin Y., Charbotel B. and Bergeret A., 2003. Morbidity among municipal waste incinerator workers: a cross-sectional study. Int. Arch. Occup. Environ. Health, 76(6), 467-472.
 Hu S.W., Chang Chien G.P. and Chan C.C., 2004. PCDD/Fs levels in indoor environments and blood of workers of three municipal waste incinerators in Taiwan. Chemosphere, 55(4), 611-20.
 Karademir A., 2004. Health risk assessment of PCDD/F emissions from a hazardous and medical waste incinerator in Turkey. Environ. Int., 30(8), 1027-38.
 Kim M.K., Oh S., Lee J.H., Im H., Ryu Y.M., Oh E., Lee J., Lee E. and Sul D., 2004. Evaluation of biological monitoring markers using genomic and proteomic analysis for automobile emission inspectors and waste incinerating workers exposed to polycyclic aromatic hydrocarbons or 2,3,7,8,-tetracholrodedibenzo-p-dioxins. Exp. Mol. Med., 36(5), 396-410.
 Knox E.G., 2000. Childhood cancers, birthplaces, incinerators and landfill sites. Int. J. Epidemiology, 2000;29 (3), 391-397.
 Knox E.G., 2005. Childhood cancers and atmospheric carcinogens. Journal of Epidemiology and Community Health, 59, 101-105.
 Knox E.G., 2005. Oil combustion and childhood cancers. Journal of Epidemiology and Community Health, 59, 755-760.
 Knox E.G., 2006. Roads, railways, and childhood cancers, Journal of Epidemiology and Community Health, 60, 136-141.
 Kumagai S., Koda S. and Oda H., 2003. Exposure evaluation of dioxins in municipal waste incinerator workers. Ind. Health, 41(3), 167-174.
 Lee K.H., Cho S.H., Hong Y.C., Lee K.H., Kwan H.J., Choi I. and Kang D., 2003. Urinary PAH metabolites influenced by genetic polymorphisms of GSTM1 in male hospital incinerator workers. J. Occup. Health, 45(3), 168-171.
 Leem J.H., Hong Y.C., Lee K.H., Kwon H.J., Chang Y.S. and Jang J.Y., 2003. Health survey on workers and residents near the municipal waste and industrial waste incinerators in Korea. Ind. Health, 41(3), 181-188.
 Maitre A., Collot-Fertey D., Anzivino L., Marques M., Hours M., Stoklov M., 2003. Municipal waste incinerators: air and biological monitoring of workers for exposure to particles, metals, and organic compounds. Occup. Environ. Med., 60(8), 563-569.
 Oh E., Lee E., Im H., Kang H.S., Jung W.W., Won N.H., Kim E.M. and Sul D., 2005, Evaluation of immuno- and reproductive toxicities and association between immunotoxicological and genotoxicological parameters in waste incineration workers. Toxicology, 210(1), 65-80.
 Penttinen P., Timonen K.L., Tiittanen P., Mirme A., Ruuskanen J. And Pekkanen J., 2001. Ultrafine particles in urban air and respiratory health among adult asthmatics. Eur Respir. J., 17, 428-35.
 Rapiti E., Sperati A., Fano V., DSc, Dell’Orco V., Forastiere F., 1997. Mortality among workers at municipal waste incinerators in Rome: A retrospective cohort study, Epidemiology Unit Lazio Region, Rome, Italy.
 Rushton L., 2003. Health hazards and waste management. Br. Med. Bull., 68, 183-97.
 Sedman RM, Esparza JR. Evaluation of the public risks associated with semivolatile metal and dioxine emissions from hazardous waste incinerators. Environ Health Perspect, 1991;94:181-7
 Shy C.M., Degnan D., Fox D.L., Mukerjee S., Hazucha M.J., Boehlecke B.A., Rothenbacher D., Briggs P.M., Devlin R.B., Wallace D.D., Stevens R.K. and Bromberg P.A., 1995. Do waste incinerators induce adverse respiratory effects? An air quality and epidemiological study of six communities. Environ. Health Perspect, 103(7-8), 714-724.
 Srogi K., 2007. Levels and congener distributions of PCDDs, PCDFs and dioxin-like PCBs in environmental and human samples: a review, Environmental Chemistry Letters.
 Yoshida R., Ogawa Y., Mori I., Nakata A., Wang R., Ueno S., Shioji I. and Hisanaga N., 2003. Associations between oxidative stress levels and total duration of engagement in jobs with exposure to fly ash among workers at municipal solid waste incinerators. Mutagenesis, 18(6), 533-537.
 “Mispelstraat: living under the smoke of a waste incinerator”. Report on the health impact of the MIWA-waste incinerator in Sint-Miklaas, Belgium.
 Rowat S.C., 1999. Incinerator toxic emissions: a brief summary of human health effects with a note on regulatory control. Med. Hypotheses, 52(5), 389-396.