Temporary relocation advice

ELEVATED LEVELS OF PM2.5

In addition to elevated carbon monoxide levels during periods of the mine fire, the community was also exposed to elevated levels of PM2.5. Dr Lester told the Board that the longer the duration of exposure to PM2.5, the greater the risk.119

Figure 4.55 Validated and indicative PM2.5 levels for Morwell and Traralgon from 9 February 2014 – 31 March 2014 (daily averages)120

4.27-Graph-Validated-_opt

Figure 4.55 adapted from an EPA graph shows indicative data and validated data for PM2.5 levels in February and March 2014, in the area around the Hazelwood mine fire. The dotted lines represent indicative data and the solid lines represent validated data. The Figure demonstrates that there were three key peaks of elevated PM2.5 readings, particularly at the monitoring station at the Morwell Bowling Club (South). The peak periods were from 15–18 February 2014, 21–25 February 2014 and 26–28 February 2014. As detailed in Chapter 4.3 Environmental effects and response, the peak hourly reading of PM2.5, recorded via the DustTrak, during the Hazelwood mine fire was just below 1200 µg/m3.

It is unclear from the evidence before the Board how much indicative data was provided to the Department of Health during the Hazelwood mine fire. However the EPA did provide some indicative data to the Department of Health before providing validated data. From 16 February 2014, the Department of Health received validated PM2.5 reports from the EPA for the eastern part of Morwell, and indicative data for the southern part of Morwell.121 Dr Torre advised the Department of Health via email on 16 February 2014, that the levels recorded in the southern area of Morwell were around two and a half to three times higher than in the eastern area of Morwell.122

From 22 February 2014, the Department of Health received validated PM2.5 reports from the EPA for the southern part of Morwell.123

Figure 4.56 Validated PM2.5 levels for Morwell from 15 February 2014 – 23 March 2014
(24 hour rolling average)124

4.56-Graph-Latrobe-V_opt

Figure 4.56 adapted from a Department of Health graph shows the validated levels of PM2.5 recorded in Morwell from 16 February 2014 until 22 March 2014, together with the corresponding Department of Health ranges for the levels of air quality. The orange line represents the levels recorded at the Morwell Bowling Club (South) monitoring station and the green line represents the levels recorded at the Hourigan Road, Morwell (East) monitoring station. The Figure demonstrates that there were two key peaks of validated PM2.5 recorded at the Morwell Bowling Club (South) air monitoring station, where the levels were considered by the Department of Health to be ‘high (extreme)’. The peak periods were between 21–25 February 2014 and 26–28 February 2014.

PM2.5 HEALTH PROTECTION PROTOCOL

On 25 February 2014, the Department of Health with the assistance of the EPA, developed a protocol to provide a decision-making tool to assess the risks and appropriate responses to high levels of PM2.5 in the Morwell community, in particular in the area south of Commercial Road close to the Hazelwood mine.125

The PM2.5 Health Protection Protocol outlines six levels of air quality based on the 24 hour rolling average of PM2.5 and the appropriate action for each level. The six air quality categories are: ‘good’, ‘unhealthy–sensitive’, ‘unhealthy–all’, ‘very unhealthy–all’, ‘hazardous’, and ‘extreme’. Each air category is accompanied by detailed cautionary health advice and actions (see Figure 4.57).126

Figure 4.57 Smoke advisory levels for PM2.5 (24 hour rolling average) and cautionary advice for increasing health impacts127

Smoke advisory level

Air Quality Categories

PM2.5 24 hr µg/m3

Potential health effects

Cautionary health advice/actions

Not applicable Good <25 Meets the relevant air quality standard None
LOW Unhealthy sensitive 26–
55
People with lung or heart conditions, elderly, children Sensitive groups: People with heart or lung conditions, children and older adults should reduce prolonged or heavy physical activityNo specific message for everyone else other than sensitive groups
HIGH – General Unhealthy –
all
56–
95
Increased likelihood of effects for people with lung or heart conditions, elderly, and childrenGeneral population respiratory symptoms Sensitive groups: People with heart or lung conditions, children and older adults should avoid prolonged or heavy physical activityEveryone else should reduce prolonged or heavy physical activity
HIGH – General Very
unhealthy –
all
96–
156
Increased likelihood of effects for people with lung or heart conditions, elderly, and childrenGeneral population respiratory symptoms Sensitive groups: People with heart or lung conditions, children and older adults should avoid all physical activity outdoorsEveryone else should avoid prolonged or heavy physical activity
HIGH – Hazardous Hazardous 157–
250
Significant likelihood of effects for people with lung or heart conditions, elderly, and childrenIncreased likelihood of respiratory symptoms in the general population Sensitive groups: People with heart or lung conditions, children 5 years and younger, pregnant women and people over 65 years should temporarily relocate to a friend or relative living outside the smoke-affected area. If this is not possible, remain indoors and keep activity levels as low as possibleConsider closing some or all schools until air quality improvesEveryone should avoid all physical activity outdoors.Healthy people with symptoms should seek medical advice and take a break away from the smoky conditions.Reschedule outdoor events eg. concerts and competitive sports schools until air quality improves
HIGH – Extreme Extreme >250 Serious likelihood of effects for people with lung of heart conditions, elderly, pregnant women and childrenRespiratory symptoms in the general population Cautionary health advice/actions the same as for HIGH–Hazardous above except for sensitive groupsSensitive groups: If the 24 hour rolling average PM2.5 values remain in this category for two days and are predicted to continue at this level or increase:People with heart or lung conditions, children
5 years and younger, pregnant women and people over 65 years are strongly recommended to temporarily relocate until there is sustained improvement in air quality

Dr Lester told the Board that the primary objective of the PM2.5 Health Protection Protocol was to prevent vulnerable groups from spending more than three days in an atmosphere of a level of more than 250 µg/m3 of PM2.5.128

The PM2.5 Health Protection Protocol includes a detailed procedure that should be followed if the PM2.5 levels exceed 250 µg/m3. This procedure describes:

  • when to notify the Department of Health
  • when the Department of Health’s Health Risk Assessment Team should be activated
  • the required continuous air monitoring and reporting to the Department of Health (including actual and predicted results) from the EPA
  • issuing the subsequent advice from the Chief Health Officer.129

Essentially, the PM2.5 Health Protection Protocol provides that if the PM2.5 levels reach the extreme level (greater than 250 µg/m3) for two days and are predicted to stay at this level or to increase, the Department of Health’s Health Risk Assessment Team is activated and determines whether ‘the Chief Health Officer should strongly recommend that sensitive groups temporarily relocate until the air quality improves for a sustained time (see Figure 4.58).’

Figure 4.58 Summary of PM2.5 response procedure between Department of Health and EPA130

Days of exposure to air

Action points T=24 hours T=36 hours T=48 hours
Notification and updates EPA notifies DH on-call Officer if PM2.5 (24 hour rolling average value)
is > 250 µg/m3
EPA updates DH
(see below)
EPA updates DH
(see below)
Monitoring and Assessment EPA provides DH with:

  • the last 12 hrs of PM2.5 rolling average values
  • qualitative prediction of change in smoke intensity over the next 12 hours
EPA provides DH with:

  • the last 12 hrs of PM2.5 rolling average values
  • qualitative prediction of change in smoke intensity over the next 12 hours
Decision No activation of DH Health Risk Assessment (HRA) Team if:

  • the 12th hour 24 rolling average value (which represents 36 hours of community exposure) for PM2.5 is < 250
    µg/m3 and
  • the smoke intensity is predicted to decrease

OR

Alert DH HRA Team and continue assessment of monitoring data for the next 12 hours if PM2.5 (rolling 24 hour average) is >250 µg/m3 and current smoke intensity is predicted to remain the same or increase

No activation of DH Health Risk Assesment (HRA) Team if:

  • the 12th hour 24 rolling average value (which represents 48 hours of community exposure) for PM2.5 is < 250
    µg/m3 and
  • the smoke intensity is predicted to decrease

OR

Activate DH HRA Team if PM2.5 (rolling 24 hour average) is >250 µg/m3 and the current smoke intensity is predicted to remain the same or increase over the next 12 hours

Chief Health Officer – subsequent advice/actions The issue of further advice by the Chief Health Officer involves factors in addition to an improvement in air quality: fire suppression status, plume predictions, weather outlook information etc.Any advice from the Chief Health Officer will therefore be made in consultation with the Fire Services Commissioner, EPA, CFA, DHS and VicPol.

DH = Department of Health

Peer review of the PM2.5 Health Protection Protocol

On 4 March 2014 the Department of Health had the PM2.5 Health Protection Protocol peer reviewed by Ms Denison.131 Ms Denison considered that the PM2.5 Health Protection Protocol was consistent with international approaches to public health warnings associated with bushfire (or wildfire) smoke. She also considered that the PM2.5 levels included in each range were consistent with international systems and ‘provides [sic] appropriate advice to minimise the adverse effects of the smoke on these [sensitive] groups.’132 She was also of the view that allowing three consecutive days of extreme levels before recommending temporary relocation was consistent with addressing the increasing risk arising from several days of constant exposure.133 Ms Denison made no suggestions for improvement to the PM2.5 Health Protection Protocol.

Independent expert Ms Claire Richardson, Managing Director and Principal Consultant, Air Noise Environment Pty Ltd, advised the Board that a key difference between the Bushfire Smoke Protocol and the PM2.5 Health Protection Protocol was that the latter did not have triggers for one hour levels. She also observed that the PM2.5 Health Protection Protocol did not outline a time period within which to determine when specific actions were to be taken, such as relocation.134

On 5 March 2014, Dr Lester also sought review of the PM2.5 Health Protection Protocol from the Australian Health Protection Principal Committee.135 Different members of the Committee had different views on the Protocol.

Dr Paul Kelly, Australian Capital Territory Chief Health Officer, considered that the PM2.5 Health Protection Protocol should allow for general advice to be triggered by different levels and associated health impacts, rather than making specific recommendations. He agreed that the level of high/extreme of 250 µg/m3 in the Protocol was appropriate in light of the available evidence.136

Mr Roscoe Taylor, Tasmania Chief Health Officer, was of the view that the PM2.5 Health Protection Protocol’s defined action levels and actions had the potential to work against a more precautionary approach to early warnings.137

The New South Wales Department of Health was concerned that a number of comments in the PM2.5 Health Protection Protocol did not have a sound scientific or evidentiary basis, namely the comment that the effects of exposure to PM2.5 are cumulative and that there is a link between exposure and harm to foetuses. The Department considered the individual risk from PM2.5 to be so small as to be unlikely to justify a government recommendation for relocation. The Department was concerned the PM2.5 Health Protection Protocol could set an ‘unjustified precedent’.138

Seventeen committee members of the Australian Health Protection Principal Committee (out of 22) were unable to respond within the required timeframe or did not provide substantive responses.139

There was no evidence before the Board that the EPA sought a peer review of the PM2.5 Health
Protection Protocol.140

ADVICE ON 28 FEBRUARY 2014

On 26 and 27 February 2014, Dr Lester became concerned about the significant decrease in air quality.141

On 27 February 2014, Dr Lester discussed her intention to issue temporary relocation advice at a meeting of the State Crisis and Resilience team.142 Dr Lester also discussed her intention to issue the temporary relocation advice with Associate Professor Louis Irving, respiratory physician, Dr Johnston, public health physician, and the Environmental Health Standing Committee.143 Comments from the Committee included that a tiered approach was an appropriate way to respond to the situation, however other Committee members were concerned that the proposed temporary relocation advice (to be announced the next day) may set an ‘inappropriate precedent’.144

On the morning of 28 February 2014, a meeting was held in Morwell and was attended by Dr Lester, Mr Lapsley, Mr Ken Lay, Chief Commissioner of Police, Mr Merritt, Cr Sharon Gibson, Latrobe City Council Mayor, Mr Mitchell, and various other departmental representatives. The purpose of the meeting was to discuss the proposed temporary relocation advice.145

Mr Mitchell told the Board that the map shown in Figure 4.59 was circulated at the meeting to demonstrate air quality in different areas of Morwell.146 He read the map as indicating a very strong concentration of air pollution in one area (which he indicated was in the area south of Commercial Road), and another ‘bubble’ at McDonald’s Road.147

Figure 4.59 Distribution of pollution as indicated by PM2.5 levels in Morwell on 22 February 2014148
4_59

In the early afternoon of 28 February 2014, Dr Lester advised vulnerable groups (preschool aged children, pregnant women, people with pre-existing heart and lung conditions and people over 65 years) to temporarily relocate from the area south of Commercial Road in Morwell.149

Dr Lester told the Board she issued the advice because she was concerned that the levels of PM2.5 had started to increase on 26 February 2014, and that on 27 February 2014 she had specific advice from Mr Lapsley that the fire was likely to burn for at least two more weeks.150 Dr Lester was concerned that if the PM2.5 levels continued to increase they would exceed 250 µg/m3 for three days, and that vulnerable groups had been in the smoke long enough.151 Dr Lester confirmed that the advice was not to evacuate but rather that residents should consider temporary relocation.152

When asked by the Board why she did not issue the temporary relocation advice earlier, Dr Lester responded:

The risk of adverse events happening increases – the longer people are exposed to the smoke, the risk of adverse events increases. The actual level of the smoke, as you’ve seen from the PM2.5 graph, varied quite considerably across that time. We needed to give advice, which was proportionate to the risk of what we were seeing.153

COMMUNITY RESPONSE TO RELOCATION ANNOUNCEMENT

Community members informed the Board that they considered Dr Lester’s temporary relocation advice on 28 February 2014 to be inconsistent with her earlier advice that it was safe to stay in the area. Ms Wilson stated:

I felt, when she did come out and say, “We recommend you relocate”, and it was only a matter of days before we’d heard everything is fine, no one needs to relocate, I just felt inadequate, I just felt like everything that I had portrayed to people about what we were doing was right and informed and considered, became something of, “You would have been better off just trusting yourself and your family rather than an expert”.154

Dr Lester did not consider that the advice to relocate was inconsistent with her earlier advice, but rather that it was an extension of ongoing advice to avoid exposure to the smoke if possible. She told the Board that she was continuing to emphasise the message to take regular breaks from the smoke as the fire progressed and that the temporary relocation advice was an escalation of this.155

Ms Julie Brown of Morwell, submitted to the Board that she felt let down by the Department of Health because ‘they did not have scientific certainty that this health risk did not pose a serious threat and allowed people of Morwell to be exposed to an obvious risk.’156

Ms Wheatland told the Board: ‘I think the advice that we got was late, I don’t think that it was considered in the context of the vulnerable people that are living in the community. It should have been earlier.’157 She also described the temporary relocation advice–so late after the commencement of the fire–as ‘quite unsettling’.158

Professor Campbell told the Board that from a clinician’s perspective, the spikes of PM2.5 were very concerning and that he would have erred on the side of being concerned. However, he did not specify what action should have been taken.159 He told the Board:

Well, look, we’re dealing with a complex issue, we have an information deficit, we don’t have the information that would give us a definitive answer but we have to make a decision, and to not make a decision is to make a decision; so you don’t have a choice, you’ve got to make a decision. It’s either, it is or it isn’t.160

The Board heard significant concern from the community about the use of Commercial Road as the dividing line for the temporary relocation advice, and in particular the use of the term ‘Morwell South’. The Board received a submission from Mr Fred Burns of Moe who stated that the continued use of ‘Morwell South’ by Dr Lester gave the impression that the other parts of Morwell (in particular north of the railway line) were less affected by smoke, ash and fine particles in the air.161