Tamara Al-Obaidi, health impact assessor for Jacobs, outlines potential pitfalls for health impact assessments under the revised EIA Directive 2014/52/EU.
Health Impact Assessment (HIA) is a process undertaken to predict and evaluate the potential health implications of plans, policies or projects on people. The revised EIA Directive 2014/52/EU aims to achieve high levels of protection of human health and the environment.
One of the key changes in the revised directive is that direct and indirect significant effects of a project on population and human health should be identified, described and assessed in a manner appropriate to each individual case. Consideration is needed of the potential interactions between human health and other aspects cited in the directive such as biodiversity, land, soil, water, air, climate, material assets, cultural heritage and landscape when identifying and evaluating potential effects.
The directive specifies that risks to human health, for example, those arising from air pollution, now form a key criterion when screening for whether an EIA is needed. The likely significant effects of projects on human health must be considered using factors including their location; magnitude; geographical area; size of population; nature of impact; transboundary nature of impact; probability of impact; expected onset, duration, frequency and reversibility of impact; the cumulative effects; and the possibility of effectively reducing the impact.
The directive requires a description of alternative projects and the main reasons for selecting the chosen option, along with the likely significant effects on human health risk, for example, the vulnerability of the project to major disasters and/or accidents. Mitigation measures must also be reported, as well as compensation measures and monitoring arrangements where risks are identified.
Reading into the directive, a clear attempt has been made to give human health more prominence in EIA in terms of the consideration and assessment of effects on populations and human health risks. However, there are gaps between the aims and aspirations of the directive, guidance presented in the directive, and the tools which are available to identify, assess and report health-related effects.
A key gap in the directive is the lack of clarity regarding what is considered to be the appropriate manner of identification, description and assessment of significant health effects, including those which may arise from interactions with other environmental aspects.
The directive does not expand on a definition of a major accident and/or disaster and how such examples ought to be considered and assessed in the context of a project. Similarly, the directive states that such assessments need to be conducted by a competent expert but does not define the level of experience or qualification needed to be ‘competent’.
There are also gaps in which criteria and methods should be used when deciding whether a project qualifies for EIA on human health risk. This absence of definition is likely to present a challenge to HIA practitioners once the directive is transposed into secondary legislation in the UK. For example, would consultations with relevant authorities and health professionals, and health-related surveys, become a key requirement in order to establish whether a project should be subject to an EIA based on human health risks?
Further challenges are likely to emerge in relation to defining the spatial scope and extent of potential effects, such as establishing geographical area limits and/or the size of population to be considered in the assessment of human health risk.
As in earlier versions of the directive, limited guidance is offered on the format of reporting that should be used, except for the minimum requirements that must be considered and recorded as part of the EIA process. This could present additional challenges for assessors when compiling their findings and presenting them in the EIA report, as the HIA process and outcomes are unlikely to align with the common structure of reporting generally adopted in many other environmental assessments. Furthermore, should potential health impacts now form a more prominent factor in the consideration of project alternatives?
The strengthening of EIA screening and scoping procedures is likely to give rise to pressures on competent authorities when presented with more detailed, comprehensive requests. A key question is whether authorities will have the capability and experience to review such requests and provide informed opinions on health matters, notwithstanding those associated with assessment outcomes?
In summary, guidance is likely to be needed on the consideration of health impacts and risks in EIA following transposition of the directive in 2017. Clarity will need to be established on the following to aid both HIA and EIA practitioners:
- the definition and use of appropriate criteria when screening projects for risks to human health, to assist the process of screening and the subsequent reporting of the process;
- how to appropriately identify, describe and assess the direct and indirect significant effects of a project in terms of human health risks, as well as what constitutes disasters and accidents;
- the level of competency required by practitioners to ensure they are appropriately qualified and experienced to conduct and report human health risk assessments in EIA.
