Discussion and conclusions
IMPACT OF THE HAZELWOOD MINE FIRE on health
The impact of the Hazelwood mine fire on the population of the Latrobe Valley and Morwell in particular, was significant on many levels. Chapter 4.5 Health effects demonstrates that the population of the Latrobe Valley already has significant health challenges and does not enjoy the levels of health and social wellbeing of most other Victorians. Latrobe Valley is also socially and economically disadvantaged relative to the rest of Victoria, which further exacerbates health conditions.
Throughout this report examples have been given of the significant health and social impacts of the Hazelwood mine fire. The Board considers these impacts have further compromised the poorer health and wellbeing of communities such that some residents feel more distrustful of government agencies and services than they previously did. Special attention and targeted action is required to change this and provide hope for current and future generations.
PROVISION OF HEALTH INFORMATION
The Board considers that the advice provided by the Department of Health in the low level and high level smoke advisories was generic and in the case of the Hazelwood mine fire, repetitive. Whilst it is commendable that the Department and the EPA had the foresight to develop a protocol in response to the known adverse health effects of bushfire smoke, the Protocol’s effectiveness in response to the Hazelwood mine fire was questionable. The advisories to the community provided little practical advice about how to minimise the harmful effects of the smoke.
When a community is covered in smoke, residents need advice about how to protect themselves. Schools and businesses need advice about whether to close and if outdoor events should be cancelled. The Bushfire Smoke Protocol should contain a table of triggers detailing how and when people should respond to levels of smoke. The news media need to be informed about the level of danger. This advice should be included in a smoke management guide that comprises a suite of documents, including a revised Bushfire Smoke Protocol. Such a guide should be used to minimise the harmful effects of smoke on the community.
The Bushfire Smoke Protocol should be reviewed and amended to provide practical, clear and user -friendly guidelines. The Board recognises that the Victorian Government intends to review the existing Bushfire Smoke Protocol in its development of the State Smoke Plan by the end of September 2014, in preparation for the 2014/2015 summer bushfire season. This review will include integration of PM2.5 equivalent values into the PM10 approach.214 The Board affirms the proposal of the Victorian Government, however highlights that timeliness of the review is essential to ensure that the community has adequate protection and information prior to the next fire season.
ENGAGEMENT WITH GENERAL PRACTITIONERS AND HEALTH SERVICES
The Board is concerned with the lack of engagement by the Department of Health with general practitioners during the Hazelwood mine fire. Whilst the Department did seek input from general practitioners to understand the health demand, there is no evidence that they actively engaged with local general practitioners to ensure a consistent, effective health response in the community.
Local clinicians (general practitioners and specialists) may be more highly regarded and trusted by the community due to their existing relationships and knowledge of the local people, than officials from the Melbourne–based Department of Health. Engagement with local general practitioners would have assisted those practitioners to provide current and actionable information to patients, consistent with messages from the Chief Health Officer. It may have also assisted the Department of Health to engage with the local community more effectively.
Clear procedures, contact details and communication channels should be developed so that existing networks can be immediately contacted in the event of an adverse event. Regular two-way communication should be initiated and maintained with local practitioners by the Department of Health.
RESPONSE TO ELEVATED LEVELS OF CARBON MONOXIDE
The EPA reported very high levels of carbon monoxide to the Department of Health on 16 February 2014. If these readings were taken over a four hour period they were high enough to warrant at least a ‘Watch and Act’ alert, under the Carbon Monoxide Response Protocol. The Board was informed, however, that the Department of Health did not consider the measurements adequate for decision-making since the carbon monoxide data were ‘spot readings’. On the basis of the information available to the Board, this course of action is of concern, and more so given the relatively high exposure levels that were applied in the Carbon Monoxide Response Protocol.215
Although the evidence does not provide a basis for detailed findings, it does appear that there was no attempt to derive one or four-hour average carbon monoxide levels from the indicative data that was available. Further, the Department of Health did not provide any evidence that prevailing or forecast weather conditions were taken into account in assessing the significance of that data, as required by both the Carbon Monoxide Response Protocol and the Protective Action Decision Guide.
The Board was informed that no adverse health effects from community exposure to carbon monoxide were detected on and after 16 February 2014.
The Board considers it unfortunate that the Department of Health did not have in place a pre-existing carbon monoxide protocol to provide advice to the community about elevated levels of carbon monoxide. However in light of this, it was appropriate for the EPA and the Department of Health to develop a protocol to assist in decision-making.
The Board commends the Department of Health and the EPA for obtaining peer reviews of the Carbon Monoxide Response Protocol. The utility of the peer reviews would have been increased substantially if they were obtained more promptly and the results provided to the community. The expert peer reviews raised a number of concerns about the Protocol that are shared by the Board, in particular the use of the AEGL-2 guidelines for a protocol that was designed for a non-acute period.
Dr Lester was unable to confirm whether or not the Department of Health was provided with the peer reviews obtained by the EPA.216 The Department of Health and the EPA should make certain that they share all information obtained about environmental health protocols to ensure that the decision-making process is fully informed, and to provide optimal advice and protection to the community.
To ensure that the Department of Health and the EPA are prepared in the event that increased levels of carbon monoxide are experienced in the future, the Carbon Monoxide Response Protocol should be revised and finalised. In particular, the use of the AEGL-2 as the guide should be carefully reviewed for application to situations where there may be increased levels of exposure for greater than 24 hours. An independent panel appointed by the Emergency Management Commissioner should conduct the review.
The revised carbon monoxide protocol should specify who will monitor carbon monoxide in the community and by what means, the types of locations suitable for monitoring, how the results will be assessed to provide information for decision-making, trigger levels for action for specific risk categories (eg age groups, health conditions, other risk factors), and response actions according to each trigger level. Once agreed, the carbon monoxide protocol should be distributed to police, health services, local government, emergency services and any other relevant organisations to ensure a consistent response to future events.
The Board is concerned about the inconsistency between the Carbon Monoxide Response Protocol developed by the Department of Health to protect the community and the Health Management and Decontamination Plan developed by the CFA to protect firefighters from exposure to elevated levels of carbon monoxide (discussed in Chapter 4.4 Firefighter health). The Health Management and Decontamination Plan for firefighters at the mine provided that if the level of carbon monoxide exceeded 50 ppm they were required to wear breathing apparatus and if the level exceeded 75 ppm, they were required to put on breathing apparatus and immediately leave the area. By contrast, the Carbon Monoxide Response Protocol for the community required that if levels exceeded 70 ppm for more than one hour then the Department of Health would convene an internal assessment team and review the available information in light of the response matrix. That is, levels that were not considered safe for firefighters and required evacuation did not require the same response if the level was measured in the community. This inconsistency in the protocols was not satisfactorily explained to the Board and remains of concern.
The only explanation proffered for the different levels adopted in the Carbon Monoxide Response Protocol (community) and the Health Management and Decontamination Plan (firefighters) was that carbon monoxide levels are usually higher close to a coal fire and usually dissipate rapidly in the open air. However, the following concerns have not been addressed:
- Firefighters are generally fit adults. The same generalisation cannot be made about the community, which includes people in a range of vulnerable groups.
- Firefighters are screened. Pursuant to the Health Management and Decontamination Plan and those with pre-existing vulnerabilities and carboxyhaemoglobin levels over five per cent are excluded. Community members are not screened in the same way – everyone is exposed, including the vulnerable and those who already have high carboxyhaemoglobin levels.
- The AEGLs are only appropriate for short-term or acute exposures, ie up to eight hours. It follows that they may not be appropriate exposure standards for a longer incident.
The Board recommends that the firefighter carbon monoxide protocol (detailed in the Health Management and Decontamination Plan) be reviewed before the next fire season. The firefighter carbon monoxide protocol should be consistent with the community carbon monoxide protocol. As with the community protocol, the Emergency Management Commissioner should appoint an independent panel to conduct the review. The revised firefighter carbon monoxide protocol should also specify the types of locations suitable for monitoring, how the results will be assessed to provide information for decision-making, trigger levels for action for specific risk categories (eg age groups, health conditions, other risk factors), and response actions according to each trigger level. Once agreed, the firefighter carbon monoxide protocol should be distributed to the emergency services, the Victorian coal mining industry and other industries where carbon monoxide poisoning during firefighting may occur.
GDF Suez should adopt and apply the revised firefighter carbon monoxide protocol. The Board affirms that GDF Suez have committed to doing this in consultation with VWA and the CFA.217
HEALTH ASSESSMENT CENTRE
The Board commends the Department of Health for establishing the health assessment centre. The centre provided the community with an additional resource to provide health information, guidance and reassurance. The effectiveness of the centre would have been enhanced if local general practitioners had been asked to visit the centre to demonstrate their support and to reassure the community that appropriate measures were in hand.
PM2.5 HEALTH PROTECTION PROTOCOL
The Board considers that the development of the PM2.5 Health Protection Protocol, whilst appropriate as a guideline for decision-making, was developed too late by the Department of Health. By the time the protocol was in place, the local community had already been subjected to elevated levels of PM2.5 for over two weeks. The PM2.5 Health Protection Protocol should be reviewed and finalised to ensure that there is a protocol in place before another emergency of this nature occurs. The Emergency Management Commissioner should appoint an independent panel to conduct the review. The revised protocol should specify who will monitor fine particles in the air across the Latrobe Valley and by what means, the suitability of locations for monitoring, how the results will be assessed to provide information for decision-making, trigger levels for action for specific risk categories (eg age groups, health conditions, other risk factors) and response actions according to each trigger level. Once agreed, the protocol should be distributed to the police, health services, local government, emergency services and any other relevant organisations to ensure a consistency of response to future events.
TEMPORARY RELOCATION ADVICE
On 12 February 2014, the Chief Health Officer was aware that the Fire Services Commissioner considered that the mine fire would burn for at least one month.218 In light of this information and given the indicative pollution figures provided by the EPA, the Board considers that the Chief Health Officer had sufficient information to issue the temporary relocation advice shortly after the weekend of 15 and 16 February 2014.
On the basis of the information provided, the Board considers that the Chief Health Officer’s advice on 28 February 2014, that those in vulnerable groups living south of Commercial Road, Morwell should consider temporary relocation, was provided too late. While air quality did fluctuate during the fire, this does not justify taking a ‘day-to-day’219 approach to public health advice in connection with smoke from the fire that was predicted to burn for at least one month and was going to give rise to cumulative exposure to smoke over that month.
The basis for limiting temporary relocation advice to those in vulnerable groups living south of Commercial Road was poorly explained and was perceived by the community as arbitrary and divisive. The Board considers that the maps depicting PM2.5 data collected by the EPA using the TravelBLANkET could easily have been published to explain this aspect of the advice to the community.
The Board accepts that there are risks associated with relocation, however it considers that people are best placed to make their own decisions about those risks. On the information provided, the Board does not consider that compulsory evacuation of the affected area was necessary.
The temporary relocation advice was announced on Friday 28 February 2014. Many residents did not receive the advice until the late afternoon or evening. The timing of the temporary relocation advice was not ideal and caused additional distress to some residents.
STATE SMOKE GUIDE
The Board supports the intention of the Victorian Government to undertake further development on the incorporation of the Carbon Monoxide Response Protocol and the PM2.5 Health Protection Protocol documents into a single operational document.220 The Victorian Government submitted to the Board that it also intends to develop a State Smoke Plan covering the management of potential public health impacts from large scale, extended smoke events such as bushfires, planned burns, brown coal mine fires or industrial (such as hazardous material) fires. The Victorian Government further submitted that the purpose of the State Smoke Plan should be to provide a framework for ensuring that the most accurate and relevant information available about air quality assessments and forecasts is provided to the Department of Health in the most efficient manner.
As part of the State Smoke Plan, the Victorian Government intends to review the existing Bushfire Smoke Protocol in preparation for the 2014/2015 summer bushfire season. The Victorian Government also intends to improve its ability to understand and predict the movement and impacts of smoke from planned burning and bushfires.221 This will assist the Victorian Government to provide more accurate advice to the community.
The Board affirms this proposal, and recommends that the State Smoke Plan be incorporated into a State Smoke Guide, which would consist of a suite of documents and support materials that could be used to minimise the harmful effects of smoke in the community. The Guide should include the revised Bushfire Smoke Protocol, Carbon Monoxide Response Protocol and the PM2.5 Health Protection Protocol. It should also include practical advice and support materials for employers, communities and individuals on how to minimise the harmful effects of smoke. The public information materials in the State Smoke Guide should be presented in plain language and answer the key questions likely to be posed by the community.
USE OF INDICATIVE AIR QUALITY DATA
The Public Health and Wellbeing Act provides that ‘(i)f a public health risk poses a serious threat, lack of full scientific certainty should not be used as a reason for postponing measures to prevent or control the public health risk.’222
A key concern for the Board was the reluctance of the Department of Health to utilise indicative data from the EPA to inform and guide the community response. In an emergency, it is expected that the Department would make all endeavours to obtain all information available and then utilise this to assess risks to the community.
The modelling provided by the EPA indicates that the highest readings of PM2.5 and carbon monoxide were on the weekend of 15 February 2014 and 16 February 2014. As such, the Board considers that the Department of Health should have placed a greater reliance on the initial indicative data provided by the EPA.
The Board was also concerned by the lack of evidence provided to it about communication between the EPA and the Department of Health, specifically what air quality data was available and what data was required to inform public health advice. The evidence before the Board suggests that there was limited communication between the EPA and the Department about the utility and timeliness of air quality data, which may have inhibited the promptness of public health advice.
RELOCATION OF SCHOOLS AND CHILDREN’S SERVICES
The Board observed that there were two contrasting approaches to the relocation of schools and children’s services in Morwell during the Hazelwood mine fire. The Latrobe City Council assessed the conditions and promptly relocated all children’s services. The DEECD looked to the Chief Health Officer to provide direction about whether relocation was required.
Although the Commercial Road Primary School and the Sacred Heart Primary School were relocated relatively quickly, the Board is of the view that it would have been preferable to have the schools closed during the first week of the fire. The Board does not consider that it was necessary for DEECD to obtain direction from the Chief Health Officer before making a decision to relocate. The Board commends the Latrobe City Council for assessing the conditions in the southern part of Morwell, and independently and swiftly determining that the conditions were untenable for children and staff and not conducive to a quality education.223
ADVICE TO EMPLOYERS
The evidence before the Board demonstrated that there was a lack of clear and actionable information for employers to make sound judgments concerning air quality. The advice from VWA provided little assistance to the affected employers and business owners.
The Board considers that VWA, EPA and Department of Health should develop practical advice for employers, which reflects standards and trigger points for PM2.5 and carbon monoxide. The advice should then be widely communicated and included in the State Smoke Guide.
LONG-TERM HEALTH STUDY
The toxic nature of smoke from the Hazelwood mine fire has raised community and epidemiological concerns that there will be ongoing physical and mental health implications. The Department of Health has agreed to fund a long-term and wide ranging health study. This is not a decision that would have been taken lightly–there are few examples in Australia of long-term studies linked to an environmental disaster.
The Board affirms the Department of Health’s proposed long-term health study. The Board agrees a long-term study would be an extremely useful predictive tool to assist with understanding future risks, and to prevent or reduce the chances of adverse health effects arising from similar situations in the future. However, the Board recommends that all efforts be made to extend the duration of the study to at least 20 years given the long legacy of some potential pollutants and the fact that young children were susceptible to the impacts.
The Board agrees with the additional features of the study as suggested by Professor Campbell. In particular, in addition to the physical health effects from the exposure to the smoke and ash, the study should focus on the mental health impact of the Hazelwood mine fire; specifically the impact of the fire on levels of family violence and drug and alcohol abuse. The Board also agrees that the Department of Health should liaise closely with the EPA to ensure that air quality aspects are considered. An independent board, including community representatives, should govern the study, and regular reports should be made available to the public. The Health Advocate (see ‘Matters for further consideration’) should be a member of the independent board, monitor progress of the study, and be given access to the results as they become available.
Finally, the Board considers that it is important that as the study progresses, participants in the study and the local community are not only advised of the progress, but are provided with prompt, appropriate medical treatment as required.
The Board notes that studies are all very well, but they must be linked to sustained efforts to improve health outcomes for the region. To achieve this, a broader view must be taken of the scope and manner of the interventions needed to address health and social wellbeing. Action protocols should be developed to ensure that any findings from the study are quickly implemented to minimise the health consequences for both individuals and communities. In addition, action is required now to mitigate any future problems that may be found by the study. This is justified on the precautionary principle, which is well articulated in the Public Health and Wellbeing Act.
|The State review and revise the community carbon monoxide response protocol and the firefighter carbon monoxide response protocol, to:
|The State review and revise the Bushfire Smoke Protocol and the PM2.5 Health Protection Protocol, to:
|The State develop and widely disseminate an integrated State Smoke Guide, to:
|The State should continue the long-term health study, and:
|Gdf suez adopt and apply the firefighter carbon monoxide response protocol.|