Assigning authority for national environmental health action plans

In order to establish the necessary authority to implement a National Environmental Health Action Plan (NEHAP), the institutional framework of a country at national, regional and local level (whether government, agency or private sector) must be considered with regard to its effectiveness: (a) in providing information for understanding the environmental health situation; (b) for control of emissions, dumping and; (c) for enforcement of laws and standards; (d) for issuing warnings of both imminent and emerging problems; (e) for reporting on progress made under the NEHAP and other plans; (f) for monitoring environmental health.

A NEHAP will be implemented within the institutional framework of the country so one test of the likely effectiveness of proposed actions is whether: (a) responsibility is assigned for carrying out any proposed action; (b) powers are adequate for discharging those responsibilities; (c) resources are made available for performing responsibilities. One part of a NEHAP could be the amendment of the national institutional framework where it has been found to be ineffective.

Because a NEHAP cuts across the interests of several government ministries, unless one body be given sole responsibility for its preparation there is the danger always associated with divided responsibility that it will be ineffective. Nevertheless, the body with responsibility should have the obligation to consult with all relevant ministries and organisations and take account of their views. Some countries have given the responsibility to the Ministry of Health, others to the Ministry of Environment, and others to a special commission. The choice depends on what is likely to be most effective. Under some constitutions, Home Affairs or Finance Ministries might be appropriate. Another approach was taken by Sweden: it established a Commission on Environmental Health which published a report. If a body is to perform its responsibilities effectively it will need commensurate authority and resources.

Depending on the constitutional and administrative arrangements, formal authority for a NEHAP may have to be obtained at Parliamentary, Ministerial, regional and official level. In the proposal for allocating responsibility for preparing a NEHAP, and in seeking the necessary authority and resources, the responsible official would refer to the country's commitment to the Helsinki Declaration. The ministry made responsible for a NEHAP needs authority to require cooperation and textual contributions from other ministries and agencies of government.

In the countries where NEHAPs have already been piloted, once it had been decided which Ministry was to be responsible, an individual official was nominated to have the responsibility and authority to oversee the preparation of the NEHAP. The pilot countries have found it is important for the responsibility and authority to be determined at the highest possible level. Bulgaria, for example, set up an Intersectoral Council chaired by the Minister of Health and the Minister of Environment and having as members Deputy Ministers from all the principal Ministries concerned with the NEHAP. This does not preclude the normal process of management delegation thereafter. Some countries have found it helpful to have a committee of officials senior enough to ensure steady progress of the work and that all parties live up to their duty to contribute in a timely manner.

While governments talk about public participation in environmental health management, the participatory approach, and empowering citizens to claim their environmental rights, at the end of the day the Helsinki Declaration places the power to develop NEHAPs solely in the hands of governments.