Implementing national environmental health action plans

Implementation of centrally planned National Environmental Health Action Plans (NEHAPs) must be done at the local level in order to address priority problems in a way which makes the most efficient use of limited resources while taking advantage of existing local information and capacity to deal with environmental hazards and risks, i.e. respecting Agenda 21 principles.

Effectiveness in implementation of NEHAP will depend on the ability of central governments to transfer responsibility to local authorities while encouraging participation of stakeholders at all levels.

Implementation of NEHAPs will require improvements to environmental health services in most countries. The harmonization of national legislation and enforcement systems with EU directives needs special efforts.

Currently, first or final drafts of NEHAPs have been developed by over 40 Member States of the WHO European Region whose combined experience can provide guidance for all countries. It is rapidly becoming clear that no implementation scheme can be successful without appropriate stakeholder participation at the local level.

Experience shows that: NEHAPs should be designed for step-by-step implementation; they should be based on a project approach that can be achieved and afforded and has measurable outcomes; implementation should have a target date for completion; and there should be a strategy for updating the plan if necessary to accommodate changed circumstances.

The implementation of NEHAPs should be based on the following principles: (a) a commitment to solidarity within and between countries – by participation in collaborative efforts to improve environmental health and by giving priority to the worst affected areas; (b) political commitment – by assigning the highest possible priority to NEHAPs and ensuring their continuity; (c) sustainable development – by development that meets the needs of the present without compromising the ability of future generations to meet their own needs; (d) the precautionary principle – where there are significant risks of serious or irreversible damage to the environment, taking precautionary action to limit the use of potentially dangerous materials or the spread of potentially dangerous pollutants, even where scientific knowledge is not conclusive, if the balance of likely costs and benefits justifies it; (e) the "polluter pays" principle – the cost of measures decided by authorities to ensure that the environment is in an acceptable state should be reflected in the cost of goods and services which cause pollution in production and/or consumption; (f) the European Health 21 targets – these constitute the long-term goals for all Member States; (g) cooperation and partnership – not only between the health and environment sectors, but also with other economic sectors and with all social partners; (h) subsidiarity – taking decisions at the lowest administrative level possible (this is closely linked to the practice of delegation of responsibility and accountability); (i) complementarity and compatibility – between NEHAPs and national environmental action plans (NEAPs), in particular, but also between other plans. Policy principles (a), (c)-(e) and (g)-(h) were endorsed at the Second European Conference on Environment and Health (Helsinki, 20-22 June 1994).

Implementation of a NEHAP should be based on a strategy which includes the following elements: (a) improvement of environmental health services, so that they respond effectively to the particular needs and activities of the principal actors; (b) actions by economic sectors (these are of crucial importance for mitigating environmental health problems in the key areas of industry, energy, transport, agriculture and tourism); (c) financing (a NEHAP is not an extra burden for the country but a means to reduce environmental health expenditure and costs by better planning and coordination of efforts); (d) public communication and participation in the decision-making process, based on the principles of the Ã…rhus Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters (1998) Convention giving the public access to information, the opportunity to register its concerns, ready access to procedures for participation, the right to participate in decision-making, and access to justice; (e) investment projects on key environmental health problems, to address actions identified in the NEHAP (project implementation may require significant investments, good coordination and partnership); (f) establishment of a system for monitoring, reporting on and evaluating implementation actions (this is a means of maintaining momentum, ensuring that money is spent on the right projects at the right time, and improving plans to take account of achievements and changes); and (g) development and implementation of environmental health action plans at the local level, based on the same holistic approach as NEHAPs but addressing problems at the local level.

The organization of a government itself and its agencies may affect the implementation of a NEHAP. Combining or redistributing the responsibilities of ministers and ministries may be helpful in resolving internal conflicts of interest within a ministry or between ministries. Cooperation between ministries provides a broader perspective on the interdependence of responsibilities and opens up the way to mutually beneficial solutions to problems. Effective cooperation may be achieved through the establishment of a NEHAP interministerial steering committee to supervise activities, provide a platform for coordinated efforts, and adjust actions to current needs and policies.

In many states, but particularly in the countries of central and eastern Europe (CCEE) and the newly independent states (NIS), effective implementation of a NEHAP requires improvement of environmental health services (EHS). This improvement should be driven and supervised by central government as a part of national administrative reforms. However, an existing system, even if it is unsatisfactory, should not be dismantled until a better system has been created. The series of environmental health pamphlets published by the WHO Regional Office for Europe (WHO/EURO) answers many of the needs of states in this regard.

At national level, parliamentarians, members of national committees and the national news media are important for the successful implementation of NEHAPs. At local level, implementation of NEHAPs can be facilitated if local opinion-formers can be identified and convinced of the merits of the plan, so that they can play an effective role in promoting it. Local opinion-formers include respected local figures and professionals, local councillors and parliamentarians, and the local news media.

Using economic arguments will be the key factor in advancing the implementation of national environmental health action plans (NEHAPs). To gain more attention and financing, many targets defined in a country's NEHAP need to be supplemented with: (a) clarification of the economic benefits of the proposed improvements; (b) identification of possible sources of finance in connection with these economic benefits; and (c) definition of the proper mix of economic instruments and regulatory measures that will make the improvements effective at the least cost and simplify their enforcement. In that respect, coordination with the national environmental action plans (NEAPs) could be particularly beneficial, as these points have usually been included in these plans.

The success of the NEHAP implementation programme in each country will therefore depend primarily on the extent to which regional and local authorities are mobilized to take the priority environment and health actions. The public should be seen as an important partner in implementing the national action plans, and they should enjoy every possible opportunity to become informed about the plan and to be involved in decision-making. Mobilizing the various sectors of the economy to take an active part in implementing a NEHAP is the most important task at both international and national levels. The role of international bodies and the leadership of some of the most active countries at the international and subregional levels will be decisive in building the NEHAP movement.

Before implementing the actions of a National Environmental Health Action Plan (NEHAP), the following questions should be asked: (1) Is responsibility clearly assigned? (2) Is it accompanied by adequate powers? (3) How will the proposal be financed or otherwise resourced? (4) Are actions set in a timescale with clear target dates? (5) For the longer term projects are there specific reporting milestones? (6) Is there a system for reporting the achievement of milestones and target dates?
 In terms of the the overall strategy for implementing a NEHAP, appropriate questions include: (1) Has the principle of subsidiarity been consistently applied? (2) Has the sum of the effects of separate proposals been considered in terms of the effect on national, local and private sector economies? (3) Is there adequate capacity? (4) How will the effectiveness of the NEHAP as a whole be measured? (5) Can health improvements be monitored? (6) Is there provision for review of the NEHAP?
 The process of drawing up and carrying out a NEHAP helps to integrate the WHO Health for All targets with the goals of sustainable development; it creates a wider constituency for them both than they would have separately; and it positively affects the cost-benefit analysis of projects, by taking account of the benefits to health.