The health risk assessment in connection with the third-stage expansion of the Central Taiwan Science Park is the main reason why the environmental impact assessment (EIA) for the park has resulted in opposition between the public, industry and government. The misunderstanding and misuse of the risk assessment principles and methodology have led to flawed conclusions regarding the health risks to Houli residents and misjudgments as to the size and significance of their impact on Houli Township (后里).
The risk assessment methodology used in international academic risk analysis circles entails using the most accurate scientific information and the most effective methods available. This means the resulting risk value will be as close as possible to the actual risk to the things being assessed and an accurate reflection of the risk to which local residents would be exposed.
The results of the health risk assessment for the Central Taiwan Science Park fall short of international standards. This is because the assessment process did not allow for a comprehensive appraisal to be made of the high background risk created by existing pollutants, heavy metals and dioxins. Health risk is calculated by multiplying the observed adverse effect level by hazard probability. In other words, if a chemical substance has been determined to be harmless, its observed adverse effect level would be zero, as would the health risk.
However, the actual risk was underestimated, for two reasons. First, the list of hazardous substances used for the risk assessment was incomplete. Second, since it was not possible to determine how many hazardous substances were on the list, their observed adverse effect level was assumed to be zero.
Taiwanese health statistics show that Houli ranks among the top 10 percent of places in Taiwan in terms of cancer incidence and cancer mortality rates. The fact that the risk of getting cancer in Houli is much higher than the Taiwanese average is not reflected in the risk assessment for the science park.
The view that it is acceptable to rationalize the risks of the science park development because the excess relative risk (ERR) is low, is flawed. This is because such a comparison is based on national averages for individuals and townships, and therefore is not applicable to Houli township and its residents, where background environmental health risks are clearly much higher than the national average.
Houli needs to reduce risk, not to increase ERR. The members of the EIA committee should not spuriously pass the amendment to the impact assessment for the third development stage of the science park simply because they do not have access to complete and comprehensive risk information. If they do, they will create a moral crisis because the people making the health risk assessment and the members of the EIA committee themselves will be seen as indifferent to the risk of harm to Houli residents.
For a risk management decision to be more in line with public healthcare ethics, we would first need to have a risk improvement plan in the Houli region to reduce the health risk to local residents. Since the factory buildings for the science park expansion have already been completed and manufacturing equipment has already been installed, a reasonable risk management approach would be to require that complimentary measures aimed at reducing existing risk be put in place before ERR can be allowed to increase.
Existing risks are mutually reinforcing, and this has contributed to the present high-risk environment. To determine how far relative risk would have to be reduced to make sure Houli residents no longer live in a high risk environment, a more complete risk assessment is required.
A second stage EIA is one possible way to resolve the dispute over the park’s current EIA. The Environmental Impact Assessment Act (環境影響評估法) says that once a development project has been determined to have entered the second EIA stage, a request can be made that the developer collect more in-depth data of a wider scope and over a longer period. This would reduce the uncertainty inherent in the environmental impact and the health risk assessments.
It would also ensure a higher degree of accuracy based on the EIA and stop the Environmental Protection Administration from violating the law and the Constitution. Investors would also have a more stable environment to operate in, and innocent and vulnerable Houli residents would no longer have to live in a high risk environment.
Chan Chang-chuan is a professor at National Taiwan University’s Institute of Occupational Medicine and Industrial Hygiene.
Translated by Perry Svensson
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