The ESG says that the foul smells which have been troubling the citizens of Gibraltar are not in question. The group reiterates the content of its open letter to the Minister to be well researched and well founded.

The recent incident at the school highlighted a problem affecting Gibraltarians for many months now. The identity of those affected is not relevant to the serious issues raised. While the Minister is legally accurate in stating that “there are no surrogate statistics that can be used to compare hourly readings to annual averages” – the reality is that humans do not breathe in “annual averages”, but are affected by every breath they take.

The group puts forward an example whereby if a person takes no aspirins for 364 days and on the 365th day takes 730, would the death certificate claim that the person had died from a perfectly legal and non lethal dose of two pills a day averaged out over a year? This question of averaging results of exposure to dangerous chemicals needs to be addressed in a logical and scientific way.
Furthermore, while the EU law dictates an annual average of target limit 5 µg/m3 for Benzene, this is higher than the States where, possibly due to higher environmental standards, the EPA have forced down these limits to 0.25 µg/m3; the State of Texas to 12.00 µg/m3 for one hour maximum and 3.00 µg/m3 for a 24 hour period.

The Minister’s statement suggests that there is only weak evidence to support harmful effects of benzene below 32,000 µg/m3. How is this figure compatible with that set by EU directive 2000/69 of a target limit of 5 µg/m3?

The ESG reiterates that the same directive states “Benzene is a human genotoxic carcinogen and there is no identifiable threshold below which there is no risk to human health”. This fact was acknowledged by the Minister in his letter. Another report supporting this is a paper produced by DEFRA (Department of Env, Food, Rural affairs) called “Justification of an air quality standard for benzene”, written in October 1998. This paper recommends for present regulated levels of benzene under EU law to be further reduced to a value several times lower.

With regards to the stated “so-called” unscientific approach used by the ESG, the group says that the complaint it lodged before the European Commission which recently included bucket sample data, while identified as not being “traditional science” was upheld as being of significance. The data was enough to prompt the Commission to thoroughly check out the standards being applied in terms of EU legislation by Spain as the figures produced were of enough concern to by-pass the annual averages of the data they usually handle.

It is unfortunate that while the ESG’s scientific approach is accepted in Brussels, it should be questioned by the Ministry.

Fortunately we now have modern air monitoring stations which are picking up peak pollution incidences in Gibraltar. This data has to be used to identify and target pollution sources to improve air quality and safeguard the health of the environment.

The ESG, as always, does not advocate the elimination of industry but the adoption of the best available technology and practices which would allow industry to operate while minimising the effects on people and our environment. This would be in keeping with the aims and objectives of the Environmental Charter currently being drawn up by the Ministry. Our common aim should be in solving this environmental problem and determining the source of this pollution.

In summary, the ESG reiterates that high levels of benzene exist; are a problem and sources need to be addressed now as a matter of urgency.