WHAT DID WE ASK?
The request concerned a comment by an HPA representative on the Chemical Hazards and identification risk surveillance group (CHaIRS) Group, in minutes obtained from December 14th 2010. In item 22 Any Other Business-
“GU provided an update to members on the ongoing Rhodia incident involving alleged white phosphorous poisoning amongst wild birds at a Rhodia site. GU informed members that the HPA had been contacted by Rhodia in relation to concerned members of the public who had seen material released as part of an FOI request. Due to the public concerns Rhodia is looking to commission an independent study to consider human health risks.”
(I) I am requesting Rhodia’s contact letter or email to you concerning
this incident and confirm that you hold this information.
(II) We asked whether the HPA published account on white phosphorus incident management was accurate, well researched and based on sound science, given that it makes a number of statements concerning the harmful human effects of the substance.
including “Very toxic by inhalation and if swallowed”,
(III) We also questioned their use of the word “alleged” in the minutes, in connection to the bird deaths, given that this highly toxic chemical had at this stage been identified In 4 separate birds? Did they have any evidence that the bird deaths were not caused by p4 poisoning?
WHY DID WE ASK THIS?
Rhodia’s reaction to the publication of the CHaIRS minutes gave them problems. We wondered if the “public concern” was an excuse to show that they were reacting to this, or an attempt to try to dismiss the comments with an HPA sponsored study. A distraction relating to human health distracts attention away from the ongoing bird deaths at the site.
The HPA white phosphorus incident management document provides clear independent advice concerning the dangers of the chemical through ingestion. Their comment that the bird deaths were “alleged” is unjustified and misued in the CHaIRS minutes, given that it had been found in a number of birds who had ingested it. They can’t have it both ways.
WHAT DID THEY KNOW?
A response was received
(i) “The Health Protection Agency (HPA) does not have any involvement in the area of recording or monitoring poisoning incidents in the wild bird population. We have not been involved in any alleged poisoning of wild birds at the Rhodia site and as such do not hold
any information in relation to this issue. The HPA role is to provide independent advice and support to protect public health.
The contact between Rhodia and the HPA to which Dr Graham Urquhart referred to at the CHaIRS Meeting of December 14th 2010 relates only to their request for the Agency to undertake an independent study to consider whether there was any risk to human health.
Contract terms have recently been agreed between Rhodia and HPA for this study to be undertaken, however, the study has not yet commenced, so for the purposes of the Environmental Information Regulations (EIRs) we would consider that this information is
excepted from disclosure under Section 12 (4) (a).”
(ii) We are an independent organisation dedicated to protecting people’s health in the United Kingdom. We do this by providing impartial advice and authoritative information on health protection issues to inform government, health professionals and the public.The Agency’s advice, information and services are underpinned by evidence-based research, and are regularly up-dated as and when fresh evidence emerges.
(iii) As previously outlined above, the HPA has no jurisdiction or responsibility in the area of wild bird poisoning, and as such I can confirm that for the purposes of the EIRs, the information is not held by us. The responsibility for incidents in this area lies with Defra, who may be able to provide you with further information on this incident. Further information can be found on their website at http://ww2.defra.gov.uk/.
We were not clear on some points of the reply which we queried.
(i) The response did not provide the contact interface between the HPA and Rhodia referred to.
(iii) Does this study look at decommissioning scenarios involving sediment redistribution, before during and after decommissioning and how this could impact on public health?
We also explained our concerns regarding the financial implications concerning the potential disposal of the land by Rhodia for housing purposes, and whether this HPA study was really motivated by this, as we still believe it to be.
They responded
“In relation to the first part of your e-mail, I can confirm that the initial contact made by Rhodia regarding the commissioning of an impact assessment on human health at the
Rhodia site was made by telephone to our West Midlands West (HPU) Health
Protection Unit.”
“We can confirm that the Health Protection Agency have had no role in previous studies commissioned by Rhodia at this or any other site. The study being undertaken is a human health risk assessment based on available data including data held by Rhodia. The study is a human health risk assessment based on the current circumstances at this site, and will not be considering any decommissioning scenarios. We anticipate that the report will be a public document and will be available later this year.
The Health Protection Agency’s role is to provide authoritative advice based on sound evidence and research. In relation to the independence of the human health risk assessment being undertaken, a steering committee is being set up formed of local health partners to verify the independence of the human health risk assessment being undertaken.”
WHAT DOES THIS MEAN?
Rhodia and “concerned members of the public” had read our public freedom of information requests to the Food Standards Agency regarding the CHaIRS minutes. The previously unpublished contents of these prompted Rhodia to undertake a PR exercise. The reply mentions “the initial contact” being made by telephone to the HPA, but does not give subsequent contact between the two- No recorded information= Convenient.
The study was to consider current conditions, AND NOT DECOMMISIONING SCENARIOS, INCLUDING THE LAYING OF A GEOTEXTILE MEMBRANE.
The request confirmed the report was being overseen by “a steering commitee of local health partners.” As events transpired, the independence of this committee including its Chair, we will argue was anything but “independent” in our opinion.