NEHA/CIEH sabbatical exchange program 1994.

Editor's note: This is part two of David Robbins' exceptional summary of his experiences overseas as a participant in our sabbatical exchange program. Part one appeared in the December 1995 issue. It included the abstract, introduction, and discussion about the 1994 Environmental Health Congress, water and water service companies, and wastewater practices in the United Kingdom. Part two addresses landfill practices, food hygiene inspections, and housing. It also includes Mr. Robbins' conclusions, a list of references, and a list of principal contacts.

LANDFILL PRACTICES IN THE UNITED KINGDOM

Solid waste disposal is a growing concern in the UK as it is elsewhere in the world. With increasing volumes and limited landfill space, the Department of the Environment has been working to develop appropriate techniques to handle this ever increasing environmental challenge. A key to the UK answer to solid waste is co-disposal. Co-disposal is the "calculated and monitored treatment of industrial and commercial, liquid and solid wastes by interaction with biodegradable wastes in a controlled landfill site" (23). In layman's terms, co-disposal mixes selected commercial wastes with municipal wastes for biodegradation and reduction of waste volume. Co-disposal has been successfully practiced in the UK as well as the US, Germany and Denmark, with each country developing their own practices and perceptions of the process.

The co-disposal process in the UK is used for two broad categories of solid wastes: difficult industrial wastes (with solid and liquid or pumpable fractions) and municipal wastes. Of these broad categories, certain wastes have been shown to be suitable for co-disposal. Examples of these are:

* brewery wastes

* animal and food industry wastes

* detergents, fats and greases in water

* aqueous solutions of organics from industrial processes

* interceptor wastes and sludges

* paint wastes and spray booth effluents

* industrial effluent sludges

* metal finishing wastes

Examples of those wastes not considered suitable for co-disposal include:

* acid tars

* flammable wastes

* immiscible organic solvents

* explosive wastes

* reactive wastes

* PCB or other toxic wastes 

While the concept of mixing municipal and industrial wastes for disposal is not new, it has in the past resulted in environmental contamination problems. The UK method of co-disposal seeks to reduce the potential for environmental degradation by carefully selecting and matching wastes that can be disposed together. The practice requires a broad knowledge of the chemistry of the wastes in question, as well as the aerobic and anaerobic bacterial processes that occur in the degradation process.

Throughout the UK, permitting of co-disposal facilities is performed by the Waste Regulation Authorities, while the National Rivers Authority acts as a consultant to the permitting process. Therefore, the concerns of surface pollution and groundwater protection are addressed by experts from both agencies. Permits set specific standards for engineering and design specifications, acceptable waste types and quantities, leachate and landfill gas control.

Two primary examples of co-disposal can be found at the Stewartby landfill in Bedfordshire, England, and the Packington landfill in Warwickshire, England (23). Both sites have shown success in the disposal of difficult industrial wastes including paint and resin wastes by mixing them with municipal wastes. Leachate from the Stewartby site is monitored and aerobically treated prior to disposal to the nearby watercourse.

FOOD HYGIENE INSPECTIONS

Food service and food manufacturing inspections are an important and routine function of local environmental health officers (EHOs) in the UK. The food industry is regulated through several bodies of legislation and guidance documents that provide specific information as to allowable food additives, frequency of inspection, temperature control, and risk assessment of specific operations.

The Food Safety Act of 1990 is the major governing legislation for food service and food manufacturing in the UK (24). The Code of Practice On Food Hygiene Inspections (Code of Practice #9) can be found under section 40 of the act. This is the general code that applies to all food activities unless more specific guidelines have been laid down under other food legislation. This code also gives the food authority guidance on interpretation of the new Food Safety Regulations to be released in 1995.

The European Community (EC) has a very strong influence on the legislation and enforcement procedures in regards to food hygiene inspections. The UK Industry Guides to Good Hygiene Practice (25) is an example of how the EC attempts to ensure that member states can have confidence in each other's food law enforcement activities. Another EC directive is the Official Control of Foodstuffs Directive (89/397/EEC) (26). The basic principle of this directive is that food should be inspected primarily at the point of production so that there is no need for regular border controls when food moves between member states.

Food hygiene inspection in the UK has its basis in risk assessment. The food authority ranks food service and preparation establishments based on the type of product produced and a determination of "likely future risk" under the Inspection Rating Scheme (27). Those establishments that are well run with comprehensive internal controls present a lesser risk and therefore will have a lower inspection frequency category. Inspection frequency categories range from "A" which would be a high risk enterprise requiring inspections at least every 6 months, to "F" which require inspections at least every 5 years. The EHO provides a score for each component in the formula and derives an overall score. The total score relates to one of the six overall levels of food safety which further relates inversely to the inspection frequency. Basically, the higher the score, the greater the inspection frequency (Table 2). This concept of risk ranking insures that funds for food hygiene inspection go to where they are needed most; for those operations which produce the most environmental health risk.

This risk assessment scheme was first reported to National Environmental Health Association (NEHA) in 1993 (28). The basic concepts of the scheme are represented below as it represents one of the most striking differences in the approach to resource allocation and prioritization that I encountered in my travels. The scheme is in contrast to procedures used in many US jurisdictions, where all food establishments are inspected at the same frequency regardless of risk.

In assessing risk, the EHO follows the Inspection Rating Scheme which focuses on three main questions:

Question 1: What is the potential hazard? The EHO will look at the type of food and method of handling, the method of processing, and the number of consumers at risk.

Question 2: What is the current level of compliance? Factors in this category include compliance with food hygiene safety and structural compliance of the facility.

Question 3: What is the level of confidence in the management and control systems?

Food service inspections in the UK are similar to those performed in the US. The inspector will don a clean laboratory coat and hair net if needed prior to entering the food preparation areas. The inspection includes a preliminary assessment of the food safety hazards associated with the business. The inspector will specifically determine if the business has satisfactory systems for hazard analysis. Contact with the proprietor at all stages of the inspection is considered most important. Follow up on the inspection is necessarily most important. Some jurisdictions leave informal reports with the proprietor at the time of inspection. Most often, the inspector will send out the inspection report that has been prepared in the office. Formal and informal written orders, or advice if needed, will be sent with the inspection report. The Food Safety Act allows food businesses issued with an improvement notice to take other steps to comply with regulations as long as these achieve the same effect. Due consideration must be given to any relevant UK or EC Industry Guides to Good Hygiene Practice when evaluating compliance with the Food Safety Regulations of 1995 (25).

Permitting of food service establishments and charging fees for services is typically a foreign concept in the UK. Establishments are monitored manually or electronically depending upon the size of the jurisdiction. Food handler training is a requirement in the 1995 Food Safety Regulations; however, up until this point, training requirements have been nebulous. The 1995 regulations require management of food operations to assess training requirements and provide the required level of training to its employees. Food handler training programs are generally not run by environmental health departments in the UK as in the US. However, many local colleges are providing food hygiene classes and local EHOs are typically recruited as teachers.

TABLE 2

Scores related to levels of food safety and inspection frequencies.

Category     Score Range     Minimum Inspection Frequency

A               91-175         At least every 6 months
B               71-90            At least every year
C               41-70          At least every 18 months
D               31-40          At least every 2 years
E               21-30          At least every 3 years
F           less than 21       At least every 5 years

The Chartered Institute of Environmental Health (CIEH) has developed a comprehensive food handlers training course and is established as a leading food hygiene examining body. Its Basic Food Hygiene Certificate is designed to give food handlers essential knowledge and understanding of good food hygiene practices. The course and certification program is available to food service and manufacturing operations. Additionally, the CIEH has two higher levels of food handling training, the Intermediate and Advanced Food Hygiene Certificates (29).

HOUSING

No discussion of the EHO's role in the UK would be complete without a discussion of housing. In the city of Birmingham, England, which has the largest housing authority in all of Europe, as many as one third of the residential dwelling units and commercial buildings are owned by the city council. Therefore the city is responsible for maintenance and upkeep, plan review and permitting, demolition, inspection, urban planning, and rent collection. The connection between environmental health and building regulation is nowhere clearer than in a large City Council Building Consultancy department where EHOs have made inroads throughout all levels of the bureaucracy.

Modern day building consultancy regulation is deeply rooted in history. The first building regulation can be traced back to the first Building Act of 1667, which required buildings to have some form of fire resistance. The Public Health Act of 1875 gave broad powers to newly created local boroughs to create and administer bylaws concerned with drainage, sanitation, open space, and building standards. The Building Act of 1984 provides for comprehensive legislation relating to building construction, inspection, and demolition. Additionally, provisions for the abatement of dangerous buildings were detailed. This act is the forerunner to the Building Act of 1991 which further expanded the scope of building regulation to include topics such as energy consumption requirements and toxic substances (30).

One area of building regulation that has a direct impact on public health is the abatement of dangerous buildings. Dangerous building complaints are taken very seriously in the UK, especially when the building is Council owned. As the landlord, the city has the responsibility and liability for unsafe conditions. In many instances, dangerous buildings are summarily abated with city funding to fix buildings with imminent health hazards (31). Field inspections and decisions regarding the abatement of dangerous building activities come under the jurisdiction of the Surveying Services Manager. Building surveyors in the UK are analogous to building inspectors in the US. The main functions of the building surveyor are building inspection, maintenance, demolition, and licensing of sports grounds. In some smaller jurisdictions, the environmental health department and office of the building surveyor are combined. While this tends to make for larger bureaucracies, services are seen as similar in the fact that both the building surveyors and the EHOs serve the public in ways that are designed to improve the health of the environment and the individual.

In the city of Birmingham, a major effort in the last two decades has been in the area of urban renewal. Birmingham has a comprehensive program that includes all aspects of the building consultancy. Planning teams are used to identify areas of greatest concern regarding inadequate or dilapidated housing. The idea is to take entire communities that are determined to be of greatest need and provide 100% housing improvement (31). The process of housing improvement is multi-disciplinary and requires years of planning and community organizing. A great effort is made to identify and understand the human needs of the population affected. This includes the age, socio-economic status, and health of the individuals impacted. Many times areas chosen for refurbishment are ethnic in nature, which requires additional expertise in communication and organization. Once a community is chosen for refurbishment, clearance areas are defined where demolition of existing buildings will occur. As the area is cleared, residents are moved to temporary housing where they remain until the new housing is constructed. Often the process is complicated by tenants not wishing to leave their homes despite a high degree of dilapidation. In some instances the housing has been occupied by the same lineage for one hundred years or more. These holdouts increase the difficulty, cost, and time it takes to complete the urban renewal cycle.

There are pros and cons of this type of subsidized urban renewal as seen from the perspective of EHOs working within the process. Often it is difficult to displace and relocate an entire community without loosing the fabric that held the community together. Additional concerns revolve around the nature of people receiving something for nothing. New communities that have gone through this process are sometimes plagued with graffiti and vandalism, as the residents tend to place a lesser value on something given as opposed to something they provide themselves. Additional problems occur because of the political process. Out of 2,000 proposals for urban renewal in the last 10 years, only eight projects have been funded. Politicians with the most authority and influence tend to have their projects approved, although in some instances, these are not most deserving. These detriments are oftentimes outweighed by the improved nature of the housing and associated improved environmental health of the community. The process of urban renewal is seen as having real benefits and a net positive impact on the individual communities as well as the city of Birmingham in general.

CONCLUSIONS

Environmental health officers in the UK, as in the US, have a huge responsibility to public welfare and take their jobs very seriously. As in the US, work conditions are often difficult and level of salary is often a concern. The political structure of the UK often impacts environmental health policy, perhaps at a greater level than in the US.

Environmental regulations in the UK tend to be reactive as opposed to proactive. Officials are more likely to perform sampling to insure a treatment plant or food processing technique is working properly and use enforcement (reactive) if the process violates standards. This is in contrast to US regulations which might require complex permitting (proactive) and "proof" that a process will work properly before construction is allowed to begin. The UK system may allow for more innovation to solve environmental challenges, but places a greater burden of performance on the developer of a particular system. The UK, at the local level, appears more likely to take stiff enforcement action towards violators of environmental standards.

Environmental regulation in the UK seems to be deeply rooted in risk assessment and risk management. Zero discharge and designing systems for overkill are looked at as undesirable concepts. Regulators are more inclined to determine the risk to environmental health and manage their systems accordingly. This concept is evidenced by a prevalent attitude to leaking underground petroleum storage tanks and contaminated soils. If the contamination is not likely to impact drinking water supplies, costly cleanup might not be required. Contrast this to the US, where billions of dollars are spent annually to clean up contamination regardless of risk to public health. Fortunately, risk assessment and management is finding its way into US environmental health policy, although at a much slower rate than I found in the UK.

Environmental regulators from both countries can learn a great deal from each other. Sabbatical exchanges such as that funded by NSF International provide a great forum for the exchange of ideas. The concept of professional exchange programs and travel scholarships should be encouraged and expanded through additional funding from agencies in the private and public sectors.

RELATED ARTICLE: 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 fifth 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, the 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. The sabbatical exchange presents the 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.

David Robbins, NEHA's 1994-95 NEHA/CIEH sabbatical exchange program recipient, shares in this two part report his experiences and his impressions of the United States' and United Kingdom's environmental health programs. The Journal hopes you will find in his story ideas you might use, as well as a deeper appreciation for the practice of environmental health at home and abroad.

REFERENCES

1. Her Majesty's Stationary Office (1994), Drinking Water 1993-A Report by the Chief Inspector, Drinking Water Inspectorate, London, England.

2. Her Majesty's Stationary Office (1991), The Water Industry Act of 1991, Statutory Instruments 1147 and 1384, London, England.

3. Department of the Environment (1993), How Good Is Our Drinking Water? P.O. Box 151, London, E15 2HF.

4. North West Water Group Plc. (1994), Annual Report 1994, Dawson House, Great Sankey, Warrington, WA5 3LW, United Kingdom.

5. Cryptosporidium Research Steering Committee, Drinking Water Inspectorate (1992), Cryptosporidium In Water Supplies-Progress with the National Research Programme, HMSO, London, United Kingdom.

6. Osborn, K. (1993), "Cryptosporidium: A significant public health issue?" Water and Health, (Nov):4-6.

7. National Rivers Authority (1994), Our Statement of Service Standards, Rivers House, Waterside Drive, Aztec West, Almondsbury, Bristol BS12 4UD.

8. Allen Williams Drainage (1994), verbal communication, Swansea, Wales.

9. Conder Pollution Control, A Division of Conder Products and Systems, Ltd. (1994), Product Information Description, Winchester, United Kingdom.

10. Her Majesty's Stationary Office (1983), Code of Practice BS 6297, London, United Kingdom.

11. Arizona Department of Environmental Quality (1989), Engineering Bulletin #12-Minimum Requirements for the Design and Installation of Septic Tank Systems and Alternative On-site Disposal Systems, Phoenix, Az.

12. Philip, H. (1993), Septic Tank Sludges: Accumulation Rate and Biochemical Characteristics, 2nd International Conference on Design and Operation of Small Wastewater Systems, Norway.

13. Brown, P.E., M.I.E.H., F.R.S.H. (1994), verbal communication, Environmental Health Department, Borough of Macclesfield.

14. Energy and Waste Systems, Ltd. (1994), EWS Clearwater Biospiral Product Literature, Brook Lane, Westbury, Wilts BA13 4ER.

15. Haddon, M. (1994), "Solid Progress - The small green friendly neighborhood sewage plant," Water Bulletin - The Weekly Journal of the Water Industry, 620:7-9.

16. Hydro-Action (1994), Dealer Instruction Manual Model G-500, Product Information, P.O. Box 426, Kountze, Tx 77625-0426.

17. Robinson, M. (1994), verbal communication, Wessex Water Services, Ltd., Poole, United Kingdom.

18. Robbins, D. M. (1994), "Constructed Wetlands For Wastewater Treatment-On-site Treatment Strategies For Difficult Flows," presented at National Environmental Health Association Annual Educational Conference, Fort Worth, Tx.

19. Green, M.B., J. Upton (1994), "Constructed Reed Beds - Appropriate Technology for Small Communities," Presented at 4th Int'l Conference on Wetlands Systems for Water Pollution Control, Quangzhou, China.

20. Johnson, I. (1994), verbal communication, Birmingham, England.

21. Her Majesty's Stationary Office (1937), Drainage and Trades Act, London, United Kingdom.

22. U.S. Environmental Protection Agency (1994), Industrial Pretreatment Program Requirements, 40 CFR Part 403, U.S. Government Printing Office.

23. The Department of the Environment (1993), UK Landfill Practice, Crown Copyright, 93 EP 137.

24. Her Majesty's Stationary Office (1991), Food Safety Act of 1990, London, United Kingdom.

25. Her Majesty's Stationary Office (1993), UK Industry Guides to Good Hygiene Practice, London, United Kingdom.

26. Her Majesty's Stationary Office (1989), Official Control of Food Stuffs Directive, (89/397/EEC), reprinted with permission, London, United Kingdom.

27. Her Majesty's Stationary Office (revised 1995), Code Of Practice on Food Hygiene Inspections, Code of practice #9, London, United Kingdom.

28. Coleman, G., R.E.H.S. (1993), "Further Observations of the English Environmental Health System," report submitted to National Environmental Health Association.

29. Institution of Environmental Health Officers (1992), Basic Food Hygiene Certificate Coursebook, London, United Kingdom.

30. Birmingham City Council Building Consultancy (1994), Building Control and Surveying Services, Department of Planning and Architecture Publication, Birmingham, United Kingdom.

31. Surveying Services Team (1994), verbal communication, Birmingham City Council.

David M. Robbins, R.S., R.H.S.P., 535 E. Comanche St., Flagstaff, Arizona 86001

Acknowledgments

I would like to acknowledge the many people and institutions that assisted me prior to and during my sabbatical exchange project. Thanks to Peggy Guichard-Watters, R.S., Marsha Robbins, R.S., and Judy Betterton, R.S., all past presidents of the Arizona Environmental Health Association, for supporting letters of recommendation to the selection committee. Thanks also to Eileen Collier of the Chartered Institute of Environmental Health (formerly the IEHO) and to Eric Foskett, President of the International Federation of Environmental Health, and Keith Osborn of North West Water, Ltd. for assisting me with logistics and contact names which led to a successful sabbatical exchange, Special thanks to Jane Forshaw of Birmingham City Council for the time and effort she provided to insure a worthwhile visit to Birmingham.

I would especially like to thank NSF International for funding the sabbatical exchange program in an effort to promote environmental health and the exchange of information and methodology between the United States and United Kingdom. I firmly believe that it is through these and similar efforts that true progress in our field can be made. Specifically, I would like to acknowledge Harry Grenawitzke and Nina

McClelland for their support and professionalism regarding this program and NSF International for their promotion of environmental health standards around the world.

Finally, I would like to express my sincerest thanks to the National Environmental Health Association and the NEHA staff and officers for their tireless efforts in support of the advancement of the environmental health professional and making this sabbatical possible. I would like to acknowledge the awards committee for their belief in me, and especially Nelson Fabian, who has given me unending support and encouragement.

It is to the NEHA members that continue to advance our profession in ways large and small that I dedicate my sabbatical and this report. I hope that my efforts help to bridge the gap between environmental health as practiced here and abroad.