Why Health Impact Assessment Matters for Industrial Pollution Control

Prim. Dr Elizabet Paunović

The World Health Organization (WHO) defines health impact assessment (HIA) as “a practical approach used to judge the potential health effects of a policy, programme or project on a population, particularly on vulnerable or disadvantaged groups”. ^[1] Its purpose is to provide decision-makers and stakeholders with recommendations that maximise the positive health effects of a proposed project while minimising its adverse impacts.

Health impact assessment should be a mandatory part of integrated permitting procedures under the Integrated Pollution Prevention and Control (IPPC) framework. It is a key mechanism for ensuring that industrial pollution controls are explicitly designed to protect public health. It also enables stricter, more precisely targeted measures to limit emissions and strengthens the legitimacy of decisions on integrated permits.

Assessing industrial emissions in terms of quantified health risks - for example, morbidity and mortality associated with exposure to PM₂, SO₂ or NOₓ - makes it possible to move beyond compliance with technical standards alone towards integrated protection of the environment and human health, in line with the Sustainable Development Goals and WHO guidance. This is central to the rationale behind integrated pollution prevention and control.

The connection between IPPC and HIA is clear in principle: integrated permitting requires an assessment of significant environmental impacts. Yet, under both Serbia’s existing legislation and the proposed new Law on Integrated Pollution Prevention and Control, human health is still addressed only implicitly through environmental quality standards rather than assessed as a distinct concern.

Integrating HIA into the IPPC framework would translate the link between the environment and health into permitting practice. The permitting procedure would identify exposure pathways - including air pollution, noise and the transfer of contaminants from soil into the food chain - quantify the resulting health burden and, on that basis, make measures to mitigate adverse health impacts a condition of the permit.

Public health institutions must therefore be involved from the outset of the permitting procedure, with a mandatory role in conducting HIA as an integral part of the overall impact assessment. Public consultations must also involve the people whose health is at risk, as well as civil society organisations working on health promotion and environmental protection.

Core principles of health impact assessment

HIA combines quantitative, qualitative and participatory methods and can be applied across a wide range of economic sectors.

As Cole and Fielding note, health impact assessment is “an activity that helps policymakers understand health as a concept much broader than the healthcare system and medical treatment”. ^[2] This broader understanding of health is reflected in the WHO definition of health as “a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity” ^[3], as well as in the principle of “Health in All Policies”. ^[4] These principles also underpin Serbia’s public health legislation. They aim to ensure that decision-makers take health-risk assessments into account when developing policies across sectors.

HIA provides a structured, legally defined means of involving the public in assessing health risks, including people who may be affected by a proposal. Such participation is a mandatory part of conducting HIA. The process also helps decision-makers consider alternatives and improvements that can prevent illness or injury and actively promote health. It rests on four interconnected values:

•    Democracy: promoting the participation of stakeholders;
•    Equity: considering how impacts are distributed across the population, including among the most vulnerable groups;
•    Sustainable development; and
•    Ethical use of evidence.

The role of public health institutions in assessing the impacts of policies and legislation on health

Serbia’s Law on Public Health recognises the need to make specialist public health expertise a  vailable to other    sectors. ^[5] Article 8 (“Environment and Health”) assigns the following responsibilities to public health institutes:

•   Providing opinions on spatial and urban planning documents, including relevant technical documentation governed by planning and construction legislation, insofar as they concern public health;
•    Assessing risks to public health using data from the register (cadastre) of pollution sources; and
•   Monitoring and analysing health of the affected population, including the epidemiological situation, and assessing health risks associated with environmental factors.

The Public Health Strategy of the Republic of Serbia for 2018–2026 ^[6], in its chapter on environment and health, requires the competent public health institutions to undertake the following activities:

4.2.1.4. Create an enabling environment for the active implementation of international commitments undertaken in the field of environment and health (environmental impact assessment - declarations, protocols, action plans and related instruments).

4.2.1.5. Actively implement international commitments undertaken in the field of environment and health (environmental impact assessment - declarations, protocols, action plans and related instruments).

Unfortunately, environmental impact assessment (EIA) studies in Serbia performed under the provisions of Espoo Convention, Kyiv Protocol and EU Directives 2011/92/EU nad Directive 2014/52/EU and related national legislation, do not provide health impact assessments that are scientifically robust and methodologically sound. They fail to answer questions that, according to professional consensus and WHO recommendations, must be addressed: What are the health risks? Can those risks be reduced? And do the proposed technologies ensure that health risks are kept as low as possible?

Although both recently adopted laws - the Law on Strategic Environmental Assessment ^[7] and the Law on Environmental Impact Assessment ^[8] - explicitly prioritise health impacts, EIA studies still either omit health impact assessment altogether or fail to conduct it in a methodologically appropriate way because they do not answer these fundamental questions.

The Draft Law on Integrated Pollution Prevention and Control and health impact assessment

The situation is even more concerning in relation to the Draft Law on Integrated Pollution Prevention and Control. ^[9] Although the substantive reasons for including HIA remain the same, the draft does not recognise health-risk assessment or proposed measures to protect public health as integral components of impact assessment. During the public consultation, amendments were proposed to make health an essential element of the assessment.

However, the Ministry of Environmental Protection’s responses to consultation submissions show that the drafters do not regard public health protection as an integral part of the assessment study and, consequently, of the IPPC permit itself. Nor do they recognise people exposed to harmful industrial impacts, or civil society organisations working in public health and environmental protection, as mandatory participants in the consultation process.

According to the Ministry’s position, the health sector may participate in the public consultation on the impact assessment study and submit health-risk assessment data if it considers this appropriate. What remains entirely unclear, however, is why the polluter is relieved of the obligation to provide an information on health impacts. The public interest of people suffering adverse health effects must take precedence over the interests of polluters, and legislation must protect that public interest.

The public health sector therefore has a dual role. First, it is an expert stakeholder: it provides opinions and recommendations to the competent authority, in this case, the Ministry of Environmental Protection, not merely when it “feels the need”, but as a statutory responsibility under the Law on Public Health, with which the proposed legislation should be aligned. Second, it acts as a bridge to the public, interpreting health risks, explaining assessment findings and communicating the significance of proposed safeguards in clear, accessible language.

This material has been published with the financial assistance of the European Union. Its content is the sole responsibility of the Platform for Social Development and Innovation (CORE) and does not necessarily reflect the views of the European Union.

^{References
[1] World Health Organization, resource on health impact assessment. Source
[2] Cole and Fielding, publication indexed in PubMed. Source
[3] Constitution of the World Health Organization. Source
[4] Health in All Policies: Framework for Country Action. Source
[5] Law on Public Health (Republic of Serbia). Source
[6] Public Health Strategy of the Republic of Serbia, 2018–2026. Source
[7] Law on Strategic Environmental Assessment. Source
[8] Law on Environmental Impact Assessment. Source
[9] Draft Law on Integrated Pollution Prevention and Control. Source}