Learning about local environmental health authorities in the United Kingdom: a month-long sabbatical experience.

Introduction

September of 1996 was one of the most educational - as well as enjoyable - months of my life. Thanks to the Sabbatical Exchange Program sponsored by NEHA and funded by NSF International, I had the opportunity to visit the United Kingdom and spend four weeks talking with environmental health officials in that country.

The first week of my sabbatical was spent attending a congress on environmental health sponsored by the Chartered Institute of Environmental Health (CIEH), the U.K. equivalent of NEHA. CIEH has 8,600 members, the majority of whom work for local authorities in England, Wales, and Northern Ireland. Approximately 800 CIEH members attended the congress. Outstanding education sessions helped me to learn about environmental issues of concern in the United Kingdom and enabled me to meet environmental health officers from England, Scotland, Wales, and Ireland all in one location. Elected city council officials, who have responsibilities for environmental health, also attended the conference. I enjoyed talking with them and hearing their perspectives.

After the congress, I discussed environmental health issues with environmental health officials in the cities of Manchester, Stockport, Birmingham, Lemington Spa, Bristol, and London and at the University of Birmingham. The majority of my time was spent at local environmental health authorities learning how their programs are organized and managed, as well as what their priorities are.

This paper discusses some of what I learned during my visit to the United Kingdom.

Deregulation - A Major Concern at the Congress

CIEH's congress was held from September 2 to September 5, 1996, in the beautiful resort town of Harrogate, which is located about 200 miles north of London. Each day highlighted a different program. Highlighted programs were Occupational Health and Safety; Food Protection; Environmental Protection (Contaminated Land and Indoor and Outdoor Air Quality); and Housing.

A topic that was raised several times during congress meetings was the central government's deregulation initiative. According to Roger Freeman, the central government minister responsible for deregulation, the purpose is to reduce the burden of regulation on business, while balancing this reduction with the needs of consumers and the environment. In a paper presented at the congress, the Cabinet Office wrote: Regulations are, of course, needed to provide protection of various kinds, but the regulatory regime must enable business to flourish and consumers to have choice. The aims of the deregulation initiative can be summed up as Fewer, Better, Simpler.

Fewer: Ensuring that the aims of regulation are delivered through the minimum number of rules and procedures.

Better: Regulations that are unambiguous in their scope and requirements that are easier for business to comply with and that aid consistent enforcement.

Simpler: Regulations should be clearly expressed, in plain English (1).

The paper continues, "It remains a common complaint of business that heavy-handed enforcement still exists. In order to address this concern the (central) government took new powers in Section 5 of the Deregulation and Contracting Out Act of 1994 to introduce procedures for business-friendly enforcement to existing regulatory legislation" (2).

Among other things, Section 5 gives businesses the right to have what they are asked to do, as well as their rights of appeal, set out clearly in writing. Section 5 also says that businesses must have the opportunity to make representations to the authority (on the basis of a "minded to take action" notice) before any formal action is taken. It should be stressed that Section 5 powers do not prevent or delay immediate enforcement action when it is needed.

In the meetings with CIEH members and in my visits with local health authorities, it became clear to me that this deregulation initiative did not sit well. Environmental health professionals felt the only purpose served by the "minded to" notice was to waste the time of local authorities by allowing companies to say why they shouldn't be required to comply with the law. CIEH members and local authorities also felt that the allegations by business that local health authority inspectors are "overzealous" when it comes to enforcing the law were untrue and pointed to a study conducted by central government showing that the rate of complaints was only one for every 8,000 visits. The environmental health community sees the deregulation initiative as unnecessary and believes it creates more problems than it solves. As one paper read at the congress put it:

There is nothing wrong with getting rid of outdated laws and, where possible, simplifying and updating important regulations. But it is misguided to think that simply reducing the total number of regulations will make it easier for businesses to understand what is required of them and to comply with health and safety laws. Often, the law is complicated because the real world is complicated; there is a wide range of hazards and risks that need to be controlled. Instead of trying to whittle down the number of pages in the legal textbooks, more effort is needed to make sure that businesses understand what is required of them in their particular sphere of activity (3).

Both sides of this debate make important, points. I get the impression that deregulation philosophy has arrived in the United Kingdom to stay. A pamphlet published by CIEH, An Environmental Health Agenda for the Next Generation, states, "deregulation should continue where the effect is removal of outdated and unnecessary legislation but NOT where legislative change increases the risk to the public." If that balance can be reached, all parties will benefit.

Environmental Health Management

I was pleased that the congress included a presentation on environmental health management. The title of the paper was "Managing Environmental Health Services into the 21st Century: Quality Issues and the Charter Mark Initiative." It was written and presented by Mike Pilgrim, Assistant Director of Environmental Health and Trading Standards, London Borough of Croydon. I was particularly interested by his idea that we should seek the views of our environmental service users. The company I purchased my car from sends me questionnaires several times a year asking me how I enjoy the car. They want to know if the dealer gives me quality service when I take the car in for an oil change, and if the car is performing up to my expectations. As members, we receive questionnaires from NEHA because the organizers are interested in what we think about and what we want from our association, but I can't recall ever receiving similar questionnaires from a government agency asking me what I thought of its service. Pilgrim believes that to improve service, environmental health officials must ask customers what they think of the services provided and what suggestions they have, and that doing so could be an important tool in helping government agencies improve the quality of service. According to Pilgrim, this means "listening to users and acting on what they say - not an easy concept to introduce when, historically, our services have been based on the views of the professional officer who, of course, knows best!" As an example, he explains that whenever staff from his department "carry out a food safety or health and safety inspection, the business is given a form so that it can say what it thought of the service." Pilgrim feels that this approach has been very helpful as his department tries to build partnerships with the businesses they inspect (4).

Pilgrim also discussed setting service standards: "The question we must all ask is whether the local standards we have set (assuming we have them, of course), are sufficiently well based on the requirements of the customers." He gave an example of what his department discovered when it conducted a boroughwide survey in Croydon, a self-governing, incorporated town just outside central London. The department learned that "our all-embracing 24-hour response time standard was in fact more than our customers expected in some cases. For example, only a five-day response time was considered necessary for training inquiries, whereas a response time under two hours was requested for noisy parties. The added value from this type of survey is the information gained about those residents not using the department's services - in our case the Chinese and Bangladeshi communities and people with disabilities" (4).

Environmental health professionals will always hear from people who understand and use the services we provide, but we may never hear from those who are not aware of our services, have never had a need for them, or do not know how to access them. A survey that is representative of the entire community may provide information that could make us rethink our present approach to providing service. We may be operating on the assumption that everyone feels the way those few who have voiced their opinions do, when they may actually be in the minority.

Pollution Prevention

For the past three years, my staff and I have spent a lot of time and effort developing a pollution prevention (P2) program. We began by educating our board of health, county and city officials, local landfills, and the State Department of Environmental Quality about the need for a permanent household hazardous waste facility, a conditionally exempt small-quantity-generator auditing program, and an environmental crimes investigation program. Our ideas received enthusiastic support, and we were provided with the funding to implement them. The permanent household hazardous waste facility has been operating for over a year, and the conditionally exempt small-quantity-generator auditing and the environmental crimes investigation programs have been functional for over two years.

I am pleased with our accomplishments in these areas, but in the back of my mind I have wondered if we could do better. I saw my sabbatical to the United Kingdom as an excellent opportunity to answer that question.

CIEH's Environmental Health Congress addressed many areas of the environmental health field, and I learned many things, but it did not address the areas of pollution prevention and environmental crimes investigation, To learn about these areas, I talked with individuals at the congress and visited local health authorities. In Bristol, I visited a solid waste transfer station that had a fenced-off area for household hazardous waste (HHW) items brought in by the public. When the station has accumulated a small amount of waste, a contractor is paid to package the waste and dispose of it properly. The facility is not as extravagant as ours in Salt Lake County, but nonetheless meets present needs.

Our permanent facility is located at a municipal landfill, which is not conveniently located for the public. Salt Lake County is developing a transfer station that will be much more conveniently located, and we have discussed doing something similar to what Bristol City has done. HHW could be brought to our new transfer station and stored for a short time in a covered, fenced-off area. Our laboratory pack chemist could then routinely perform minimal packaging and transport the waste to our permanent facility to be completely packaged and stored until the drums are full. This approach would certainly be more cost-effective than building a second HHW facility.

Environmental Crimes Investigation

I use the term "environmental crime" to refer to economic crimes associated with improper handling and disposal of waste, pollutants, and regulated materials. These crimes shift the costs for properly handling and disposing of these materials from industry to the public. Costs include charges for properly cleaning up, treating, or disposing of wastes; the expense of restoring damaged natural resources; and lost productivity. Environmental crimes are committed for only one reason: cold, hard cash. Individuals and businesses who dump wastes in fields, lakes, or abandoned warehouses - and get away with it - gain a competitive advantage over businesses that comply with environmental laws.

I was hoping to find a U.K. local health authority that had considerable experience in running an environmental crimes program, but I did not. The Department of the Environment (DOE), the equivalent of the U.S. Environmental Protection Agency (U.S. EPA), is the agency taking the lead in this area. However, DOE's focus, like U.S. EPA's, seems to be limited to large, high-profile businesses. What I really wanted to find was a local health authority that had a program designed for conditionally exempt small-quantity generators like dry cleaners, automobile body and paint shops, and cement batch plants. These are the types of businesses our department has received complaints about and developed programs for.

The Priorities of Local Health Authorities

It was interesting to learn about the priority programs of the various local health authorities. These were the programs covered in CIEH's Environmental Health Congress meetings (food protection, housing, noise, and occupational health and safety).

Food protection is a basic and important environmental health program in the United Kingdom, just as it is in the United States. Unfortunately, highly publicized problems such as "mad cow disease" have lowered public confidence in food safety. The environmental health community is working hard to turn that situation around.

Housing conditions have been steadily improving since the start of the century. The English House Condition Survey lists the following changes in dwelling conditions and amenities from 1971 to 1991:

* In 1971, 16.4 percent of dwellings lacked basic amenities, as compared with five percent in 1981 and one percent in 1991.

* In 1971, 69 percent of dwellings lacked central heating, as compared with 43 percent in 1981 and 16 percent in 1991.

There has been a significant increase in the number of complaints about noise in a period of just one year. Also, U.K. environmental health officials feel that too many avoidable accidents occur in the workplace and in the home. Every day during the congress, The Environmental Health News, a newsletter that recapped the previous day's events, was published. The following are some interesting statistics taken from that publication.

Noise

According to vital statistics for 1994-1995,

* construction noise boomed, with a total of 10,936 complaints - an increase of 70 percent from the previous year;

* complaints about aircraft noise soared - up 60 percent from the previous year; and

* the number of domestic noise complaints made to local authorities was 144,943 - an increase of 10 percent from the previous year (5).

Ninety-five percent of the population in England and 89 percent of the population in other parts of the United Kingdom (Scotland, Wales, and Northern Ireland) live in urban areas.

Occupational Health

In the United Kingdom, local health authorities are responsible - in much the same way that the Occupational Safety and Health Administration (OSHA) is in the United States - for inspections and enforcement of occupational health and safety. Vital statistics for 1994-1995 show that

* 33 people died from work-related accidents in the local authority-enforced sector;

* 27,000 accidents were reported to local authorities, compared with only 14,000 in 1986;

* slips, trips, and falls were responsible for more than a third of accidents, and manual handling (tasks such as lifting or moving) for almost a third; and

* notices served fell by 44 percent compared with 1992-1993, reflecting the government's deregulation policies.

CIEH notes that the rate of increase in accidents was reduced when enforcement action was at its highest (6).

Conclusion

Without exception, the individuals I met were accommodating and helpful. The environmental health managers were always interested in learning what I was doing. As I explained our P2 and environmental crimes programs, I found myself feeling more confident about the approach we have taken and received many positive comments. Several environmental health officials told me that our educational approach was similar to theirs, but that our enforcement actions were more aggressive and would not go over well in the United Kingdom, given the present climate of deregulation.

I had imagined that somewhere in the United Kingdom I would find a department whose program addressed all of my interests in the areas of P2 and environmental crimes investigation, but I soon realized that I had been dreaming. Life is not that simple! I did, however, find many great professionals, from whom I learned, and with whom I shared ideas and experiences. Also, as I explained our P2 and environmental crimes program to colleagues in the various cities of the United Kingdom, I found myself addressing many of my own questions and concerns. The experience helped me to develop a strong conviction about what I believe in and want to accomplish.

For the record, the sabbatical experience was not all work. I also explored the beautiful countryside of the United Kingdom and visited some historic sites. I found that the people of the United Kingdom have a good sense of humor and are helpful and friendly. They take pride in their history and have deep respect for their customs and traditions. They have much to offer those who are fortunate enough to visit. It was certainly an honor for me to do so. I would recommend this Sabbatical Exchange Program to anyone who is interested in learning more about environmental health and how another society approaches it.

Corresponding Author: Brian W. Bennion, Environmental Health Division, 1954 E. Fort Union Blvd., No. 100, Salt Lake City, UT 84121.

Acknowledgements

I am grateful to NEHA and NSF International for the opportunity to learn how a different country approaches its environmental health challenges. The support and encouragement of the Salt Lake County Commission, my department and division directors, and my bureau staff are greatly appreciated. Without their help and support, it would have been impossible for me to leave my responsibilities at work. Special thanks are due to Eric Fosskett, who introduced me to others in the field and whose enthusiasm for environmental health - and life in general - is impressive. I also thank June Balfe of the Chartered Institute of Environmental Health for her efforts in making my experience at the congress educational and enjoyable, and Rosin Rooney for scheduling appointments and providing transportation in Bristol.

NEHA/CIEH Sabbatical Exchange Program Report

About the NEHA/CIEH Sabbatical Exchange Program

The sabbatical exchange program was initiated and funded by National Sanitation Foundation, International in 1990. The program involves the participation of both NEHA and its counterpart in England, the Chartered Institute of Environmental Health (CIEH). The program annually offers an enriching experience to a member of each organization. Now in its eighth year, the program has become a tradition that features the exchange of ideas, solutions, and methods between environmental health professionals from the U.S. and England. Through the participants, the scope of environmental health issues and practices worldwide is broadening.

Upon selection, sabbatical recipients set out on a four-week journey of enlightening experiences and come into contact with virtually every aspect of environmental health problems and solutions confronted by the other country. This sabbatical exchange presents an opportunity to look at one's own approaches and compare - sometimes for the better and sometimes not. NEHA is proud to publish these sabbatical experiences, as it is our hope that through the accounts of our ambassadors, every NEHA member will benefit.

References

1. Freeman, Roger (1996), "The Deregulation Initiative," Paper presented at CIEH Congress 96.

2. Freeman, Roger (1996), "The Deregulation Initiative," Paper Presented at CIEH Congress 96.

3. Russell, Doug (1996), "Health and Safety Enforcement Policy," Paper presented at CIEH Congress 96.

4. Pilgrim, Mike (1996), "Managing Environmental Health Services into the 21st Century: Quality Issues and the Charter Mark Initiative," Paper presented at CIEH Congress 96.

5. Environmental Health News (September 4, 1996), CIEH Congress 96, p. 3.

6. Environmental Health News (September 2, 1996), CIEH Congress 96, p. 1.