Dear ‘Stop the Stink’ Campaign  

Sept 2021

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Dear “Stop The Stink” campaign,

On the 3rd of August, we attended the public meeting held between Newcastle-under-Lyme Borough Council, Public Health England, Staffordshire County Council, the Environment Agency, and the community where Walleys Quarry Landfill site is located.

This letter is a list of our thoughts and concerns based on our experience as neuroscientists working on public health issues. The intention is to support the “Stop The Stink” campaign, as you face different aspects of environmental injustice.

Despite strong evidence from lived experience and the logging of symptoms, your community is still being exposed to air pollution coming from the landfill site. We at Centric Lab have identified inaccuracies in the understanding and/or communication of the relationship between air pollution and health. We rebuttal quotes from the public engagement event of the 3rd of August and from answers to FAQs that can be found repeatedly on relevant websites (i.e., EA's Citizen Space, Newcastle-under-Lyme FAQs, and Staffordshire Newsroom). 

The aim of this letter is to be a scientific ally to your community and to provide a further scientific perspective. It is important to note that we are an independent lab and are not being paid to create this reporting. We do it because our lab is concerned with health justice and supporting communities. The “Stop the Stink” campaign can decide freely if and how to use this letter.

Commentary 

We are getting more and more concerned about the impact on health, both in the short term and in the long term because this situation has been going on for so long and because we do not yet have a clear timescale for when it might be resolved.
— Dr Richard Harling (Staffordshire County Council) at the public engagement event on 3rd August 2021

Point 1: Ignoring the Lived Experience as Data

There are now thousands of reports in which residents complain about the bad odour and report the experience of headaches; nausea; irritation of nose, eyes, and throat; poor sleep; and symptoms of anxiety and depression. The quotes below are Google reviews of Walleys Quarry Landfill:

Lara Jupp: ‘The landfill is responsible for noxious gases seeping for miles around and filling our homes and lungs. The landfill ultimately should never have been allowed so close to a residential area and must be capped for good. The company operating the site lacks morals and is focused entirely on profit over the mental and physical health of local residents.’

Lydia Ridge: ‘We live at least 2 miles away from the landfill site and still suffer the horrendous smell regularly. My 4yr old son has had a frequent cough in the last 2 months as have a number of his friends at school and I am certain it is due to the hydrogen sulphide coming from the site. It is despicable that this has been allowed to continue for so long, and we are still suffering despite apparently work being curtailed there.’

Claire Massey: ‘The smell is disgusting. I can smell it in Penkhull. I run through Silverdale sometimes but am avoiding it at the moment as it’s truly unbearable.’

Katie Powner: ‘I live near the landfill and [it] is absolutely horrendous. The stench invades our home despite windows and doors being closed. Their rubbish blows all across the cemetery opposite and it’s generally just a nuisance. The smell is sickening. I hope they are soon held accountable for inflicting hell on residents.’

Georgierio Welsh: ‘Absolutely disgusting. The landfill is causing illness and affecting local people’s basic human rights to breathe fresh air.’

Our commentary

These examples of people’s reviews of Walleys Quarry are evidence for the effect that the pollution from Walleys Quarry has on people’s quality of life and health. People’s lived experience and the collective community experience are evidence and should be valued as such. Related to the points we made above, you cannot simply measure air pollution concentrations, refer to annoyance and health guideline levels, and then ignore people’s lived experience. It is inaccurate to say that pollutants do not have a negative effect on people’s health only because they are (most of the times) below WHO health guideline levels. The evidence that this is simply not true is right there in the thousands of reports of people who have been affected negatively by the pollution for many months (or even years) now. It is time we understand that ‘objective’, ‘quantitative’ data are not sufficient to capture complex phenomena, such as the effect of air pollution on people’s health and well-being.

In brief, people’s lived experience of air pollution is not only valid but also invaluable for understanding the detrimental impact that air pollution has on people’s health. Once a community or a person identifies malaise in their body, whether it is a headache or a discomfort, it is imperative that organisations working in public health work to understand the root causes for the malaise. Even if it is only one person, the phenomenon is already in existence and therefore significant to community health. In our experience, people are very effective in understanding their relationship with the places they live and detecting changes in the environment that pose a threat.

We recommend that the public health organisations working with your community listen to your witness statements as expertise and valid points of data. You are experts as you have been in daily contact with the phenomenon for years. You are privy to the daily and nuanced changes this landfill site presents to your community.


Point 2: Ignoring Symptomatology as Data

Staffordshire County Council introduced an online survey where those affected can report on the intensity of the smell and on their symptoms. It is a structured and analytical organising of the initial lived experience complaints. The results of this survey, presented in the online public engagement event on the 3rd of August, show a correlation between symptom frequency and proximity to the landfill site.

Screenshot of a geospatial map showing that the location of symptoms is related to the location of the landfill site.

Our commentary

The geospatial map shows a clear correlation between proximity to the landfill and symptom frequency. In other words, the data visualisation clearly shows those living closest to the landfill site experience the most symptoms of poor health. This is valid and relevant evidence: it has a clear methodology of gathering and mapping data and a clear objective of study, and the relation being showcased with the data is within scientific plausibility.

We recommend public health organisations recognise these data and begin an investigation as to how the landfill is creating pathways of poor health (headaches, nausea, coughing, etc.). If it is established that the landfill site is not the root cause of the poor health outcomes, then an investigation still needs to be conducted to find out what is, as it is evident that people in your community are getting sick.

Point 3: An Incomplete Understanding of Health

The quotes below are taken from the Newcastle-under-Lyme FAQs:

Environmental Agency: ‘The human nose is very sensitive to smell, and there are many things that have a very strong smell, even at levels below which there is a direct harmful effect to health. However strong smells are unpleasant and can impact on wellbeing leading to stress and anxiety. Some people may also experience physical symptoms, such as nausea, headaches or dizziness, as a reaction to strong smells, even when the substances that cause those smells are themselves not harmful to health. Some residents’ symptoms may be as a result of their reaction to particular smells.’

Public Health England: ‘It should be noted that the human nose is very sensitive to odours, and substances that are perceived as odorous (i.e. that breach the odour annoyance guideline) are commonly present at levels below which there is a direct harmful physical effect. However, it is recognised that odours can cause nuisance amongst the population possibly leading to sleep disturbance, stress and anxiety. Some people may experience symptoms such as nausea, headaches or dizziness, as a response to odours even when the substances that cause those smells are themselves not harmful to health.’

Environmental Agency: ‘Based on the current data up to the end of March we would stress that any direct risk to health from pollutants in the area is likely to be small and temporary, but cannot be completely excluded. More important are the indirect risks to health from sleep disturbance, stress and anxiety as well as nausea, headaches or dizziness. These are longstanding and in some people profound.’


Our Commentary

These three exemplary quotes illustrate an incomplete understanding and communication of health. The main message of the quotes is supposed to be that pollution levels are below the WHO health guideline level and therefore not affecting health negatively. However, there are three problems with this statement. First of all, the Environmental Agency and Public Health England seem to limit health to physical health. Essentially, they say that the odour would not affect health; however, it could cause anxiety and depression. Such a statement is worrying because mental health is an important dimension of health. Poor mental health in itself means poor health. Further, it is linked to poor physical health. For example, depression is highly linked and is a predictor of obesity. Therefore, it is not accurate to create a division between poor physical and mental health.

Secondly, the Environmental Agency and Public Health England seem to distinguish between direct and indirect effects on health. This can be seen as an inaccurate understanding of health. Even if there were no ‘direct effects’ of the substance (hydrogen sulphide) on physical health, there are still ‘direct effects’ on mental health. One could argue that the effect of the substance on mental health is not ‘direct’ because it is ‘mediated’ by the smell of the substance and therefore ‘indirect’. However, ultimately, the substance causes the smell and therefore also causes annoyance and poor mental health. Saying that the substance does not have a ‘direct’ effect on health downplays the great value of people’s mental health. Third, even if we focused on physical health, the quotes above are contradictory in themselves. They state that there would be no effect on physical health but that the odours could cause nausea, headaches, and dizziness. The latter are, of course, physical health outcomes, so the statement that the pollution does not affect physical health is not accurate.

We recommend an updated understanding of health, which includes an understanding of the link between physical and mental health. We would also recommend that public health organisations adhere to the WHO definition of health, which is not just the absence of disease. It is important to establish a uniform understanding of health before any public health organisation can dismiss community lived experience. Finally, we recommend that health be looked at from a point of dignity (the state or quality of being worthy of honour or respect), which means that people should not be expected to live with a top-down factor interrupting and disrespecting their state of comfort and wellbeing. This includes forcing people to live with poor health outcomes such as headaches, nosebleeds, or nausea due to a preventable environmental pollutant.  


Point 4: Incomplete understanding of Air Pollution Effects 

The quote below is taken from the EA's Citizen Space:

Environmental Agency: ‘For the week 2nd to 8th August, hydrogen sulphide levels were below the WHO 24-hour average health guideline level to protect against short-term health effects but were above the World Health Organisation’s 30-minute average odour annoyance guideline level for between 1% and 10% of the week (although final information is still being collated).’

Our Commentary

Every week, the Environmental Agency reports hydrogen sulphide levels measured at four static monitoring sites around the landfill and compares them to the WHO’s annoyance guideline level (30-min average of 7 µg/m3) and health guideline level (24-h average: 150 µg/m3). While it is good practice to report these levels to the public, the Environmental Agency and Public Health England seem to equate pollution levels with health. In the previous quotes they state that air pollution levels are below levels that have an effect on health, which implies that, as long as pollution levels are below the WHO health guideline level, there is no effect on health. This, in turn, implies that concentrations of pollutants in the air can be used as an indicator of health. This is an inaccurate understanding of the relationship between air pollution and health. We cannot translate air pollution levels to health levels, and we cannot use measures of air pollution as measures of health. 

The same applies to annoyance. Annoyance is subjective and cannot be measured accurately with air pollution monitors, as the EA says themselves in a FAQ document. Therefore, measuring the concentration of pollutants in the air to measure annoyance is not accurate. In the same document, the Environmental Agency writes: ‘​​The human nose is still the best means we have for detecting the full range of gases that cause odour. The concentrations at which these odorous gases are present in outdoor (ambient) air is usually very low beyond site boundaries (even if the smell is intense), and few pieces of equipment are sensitive enough to pick up the full range of these gases, when compared to the nose.’ This suggests that people’s experiences of smell should outweigh the measurements of monitors around the landfill site. We shall see below that there is much evidence of people’s experiences of the smell suggesting a great impact on their well-being, health, and quality of life. In brief, it is wrong to say that air pollution concentrations below health guideline levels do not affect health.

Our commentary

It is time to move away from hiding behind and making decisions based on ‘healthy’ levels of air pollution as there are no healthy levels of air pollution, this is also supported by the WHO. It is time to move towards a zero tolerance for polluted air, and to finally take seriously, respect, and value the lived experience of people affected by air pollution. Additionally,  WHO presents guidelines to bring air pollution down (​​"WHO develops and produces air quality guidelines recommending exposure limits to key air pollutants"), not health risk metrics. 

Susceptibility also has to be considered as air pollution does not affect people equally, for example, those who experience higher levels of psychosocial stressors can be affected by air pollution even at very low levels.  

We recommend that public health organisations acknowledge that there are no safe levels of air pollution and that people are affected differently by air pollution so sweeping statements of low risk are not accurate. 

Point 5: A Need to Refer more to Historical Data

Our commentary

In this meeting the community has been asked to “prove” they are being affected by the landfill site, despite historical data and vast amounts of case studies supporting the deep link between landfill sites and poor health outcomes.

We recommend that these historical case studies be considered for this case. These types of studies are done, so other communities need not wait long periods of time before they are heard and listened to.

Point 6: The Effects of Acute and Chronic Exposure are the Same

The quote below is taken from the recording of the public engagement event of the 3rd of August:

Dr Ovnair Sepai (Public Health England):The effects from chronic exposure are likely to be the same as the effects from acute exposure.’


Our Commentary

In response to a question at the public engagement event of the 3rd of August, Dr Ovnair Sepai of Public Health England says that effects of chronic exposure to ‘lower levels’ of hydrogen sulphide would be the same as effects of acute exposure to these ‘lower levels’. These health effects include ‘irritation, respiratory discomfort, and possibly increased asthma events because of the irritation.’ Two things are wrong with this statement. First, even if the effects of acute and chronic exposures were the same, this would not be acceptable, as it would mean chronically impaired physical and mental health, and lower quality of life. Second, it is very unlikely that the effects of acute and chronic exposure are the same. Chronic exposure to air pollution can have detrimental effects on health, even at ‘lower levels’. The strain that exposure to pollutants puts on the human body and mind causes both poor physical health and poor mental health, and of course it makes a difference whether this strain is short-term or long-term. In brief, it is inaccurate to say that the health effects of acute and chronic exposure are the same.

We recommend that public health organisations are more transparent and specific about terms related to health and not use them to gaslight a community.


FURTHER CONSIDERATIONS

It is important for the landfill site to be contextualised within community life to really understand the burden it poses to your community’s health. In other words, the landfill site’s effect on health is in part due to what else is going on in Newcastle-under-Lyme. Given the statistics below, we would consider this community as highly susceptible to air pollution and therefore would recommend a reframing of risk to be assessed based on this information.

  1. 4,365 children in Newcastle-under-Lyme living below the breadline

  2. 18% of households are experiencing fuel poverty

  3. Wards Keele, Thistleberry, Westlands are all facing very high levels of deprivation (70-100%)

  4. One of the highest case rates of Covid-19

  5. Poor cardiovascular health is a key predictor to various more complex diseases, so a good marker for how disease pathology is evolving in a community. Below are current stats of Newcastle-under-Lyme.

We welcome your commentary and feedback should you wish to respond to the letter. 

With Kind Regards,

Araceli Camargo
on behalf of Centric Lab 

araceli@thecentriclab.com

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Right to Pollute Policies and their Epistemological Roots