In 2020, the European Commission launched a consultative process to review the current EU Air Quality Directives. As an organisation representing allergy, asthma and chronic obstructive pulmonary disease (COPD) patients, the future of our health and wellbeing hugely depends on the laws that Europe will adopt to reduce air pollution.
While the EU air quality framework has improved the situation as compared to 15-20 years ago, there is clearly still a long way to go to eliminate the health burden of air pollution. For example, the recently updated WHO Air Quality Guidelines have demonstrated the many ways that air pollution damages our health at levels even lower than previously thought.
Air pollution is associated with more than 400.000 premature deaths in the EU each year and it is linked to the development and exacerbation of major non-communicable diseases, including respiratory diseases such as asthma and COPD, cardiovascular diseases, cancer and diabetes.
Towards a new EU air quality framework
In an acknowledgement of our solid knowledge and strong record on air quality issues, European Commission invited EFA to provide the perspective of allergy and airways disease patients to the revision of the EU Air Quality Directives (AQDs). The targeted survey was conducted in February and sought feedback on three main policy areas:
- Closer alignment with the latest recommendations of the WHO
- Improving current framework, including provisions on penalties and public information
- Strengthening of air quality monitoring, modelling and plans
The inputs received will also inform the parallel European Commission exercise to draft an impact assessment of the current EU Air Quality Directives.
EU standards vs WHO recommendations: Can the EU afford not to align?
EFA considers full alignment with WHO recommendations as the only option that truly protects health. We strongly believe that all efforts must be made to make it feasible as soon as possible, and certainly no later than 2030.
In practice, full EU alignment with WHO recommendations entails that the EU limit values for each pollutant, including fine particulate matter (PM2,5), ground ozone (O3), sulphur dioxide (SO2), nitrogen dioxide (NO2) and carbon monoxide (CO), should become equal to those recommended by WHO. Under the EU legislative framework, these aligned levels would be legally binding and not mere recommendations, so any short or long-term pollutant exceedance would oblige countries to take corrective measures (or face penalties, in case of no or insufficient action).
In addition, EFA urges the European Commission to also address and regulate ‘emerging pollutants’ such as ammonia, black carbon and ultra-fine particulates, all of which have been associated with adverse health effects, including reduced lung function and worsening of respiratory symptoms.
Crucially, EFA calls for strong action on other natural and chemical pollutants with well-documented effects on respiratory health, such as pollen and other aeroallergens, sand and dust storms, and volatile organic compounds (VOCs), detailed below.
Air quality directives should improve information to vulnerable groups
EFA believes that the future EU legislative framework can be reinforced through a combination of targeted interventions to increase its effectiveness and ensure better air quality for all. From EFA’s perspective, information is power and must be the basis for both evidence-based policymaking and an empowered population.
EFA supports the introduction of a mechanism to adjust the EU air quality standards based on new evidence from bodies such as the WHO, the European Environment Agency (EEA), and the Organisation for Economic Cooperation and Development (OECD). This would also entail a regular review of technical and scientific progress, in close collaboration with relevant stakeholders.
Crucially, EFA calls for legally binding information requirements to keep citizens informed of air pollution conditions in real-time, including on pollen, sand/dust storms and volcanic emissions. In fact, In the case of pollen and sand and dust storms, EFA calls for a systematic reinforcement of forecast services and public information, and encourages to set up an EU-wide real-time monitoring system, combined with a formal information threshold arising from the EU Air Quality Directives and messaging targeted to vulnerable groups of the population. To the same end, we call the Commission to harmonise the air quality index bands across all EU countries.
Technology can be an ally for better informed citizens, but conventional as well as the latest communication tools and channels must be free, transparent and user-friendly. The Commission must work to increase awareness of existing tools, such as the EU Air Quality Index and its application, across the society. Information can also be synchronised and channelled via eHealth and mHealth tools that facilitate self-management of diseases, such as the connected inhaler of MyAirCoach.
Sanctions are not the only mechanism to protect the population
In cases where air quality standards are not respected, EFA highlights the need for a clear and precise action plan. Actions must involve all relevant stakeholders, including competent authorities, sectoral representatives, civil society and citizens. An open approach is key to gain a full understanding of specific air pollution events and identify the most effective measures to address them.
Accordingly, in cases of infringements it is important to ensure penalties that make up for the damage done to human health and the environment. Individuals must obtain the right to compensation for damage to health related to air pollution, while access to justice must be open for both groups and individual citizens on these matters.
However, EFA stresses that there can be no full protection of health from air pollution without addressing Indoor Air Quality (IAQ) aspects. Indoor pollutants such as mould, dust, volatile organic compounds, tobacco smoke and emissions from heating and cooking can be extremely damaging to respiratory health. Addressing IAQ means to prioritise health and coordinate actions across sectors and policies, including, but not limited to, the legislation on buildings and renovations, chemicals, product labelling, and smoke-free environments. Taking IAQ considerations into account will help the EU move towards an Air Quality Framework Strategy that is exhaustive and integrated.
Expand air pollution monitoring
EFA reiterates its position that, without a well-functioning air quality monitoring mechanism, we lack the necessary information to support policymaking and individual decisions. Unfortunately, many monitoring stations across the EU today fail to provide data, which points to the need of clear provisions regarding repair and/or replacing of defunct stations.
In addition, EFA calls on the Commission to support citizen science in air quality monitoring, as a complementary tool to official monitoring. This can be achieved through the uptake of low-cost but scientifically proven monitors that are already available today in the market.
Furthermore, we believe that the Commission must expand the scope of EU air quality monitoring to include emerging pollutants such as ammonia, black carbon and ultra-fine particles, but also real-time estimates of natural pollutants such as pollen, sand/dust, and volcanic emissions.
Finally, it is of utmost importance that air quality plans include a health impact assessment at any stage of implementation, in order to ensure transparency and steer corrective action where necessary.
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EFA looks forward to continuing bringing the voice of respiratory patients in the critical discussions to come on the future of air quality in Europe. The upcoming 2nd stakeholder meeting on the revision of the AQDs (planned in April) will provide a first opportunity to reiterate our asks for a legislative revision that protects health and the environment.
Moreover, we are ready to engage with the institutions and other stakeholders on an ambitious EU air quality framework via our participation in the Zero Pollution Stakeholder Platform.
You can find the full EFA response to the targeted surveys Policy Area 1 and Policy Areas 2 and 3 as well as our response to the air quality directives consulation.