Written evidence submitted by the Royal College of Physicians (RCP) and the UKRI Clean Air Champions (AQU0014)

This evidence has been produced by the Royal College of Physicians (RCP) and the UKRI Clean Air Champions.

Did the UK Government’s 2019 Air Quality Strategy set out an effective and deliverable strategy to tackle the UK’s poor air quality and address the issues raised in our 2018 report? Has the UK Government put in place the necessary structures and resources to deliver its strategy?


Air pollution affects everyone, from the womb to old age, but is particularly dangerous for the most vulnerable individuals, including children, older people and those with existing health problems. They can also suffer the greatest exposure to air pollution, alongside outdoor and transport workers, people from deprived backgrounds and ethnic minorities.


An increase in evidence linking pollution to adverse health led to the publication of Every Breath We Take in 2016. This report, produced by the Royal College of Physicians (RCP) and the Royal College of Paediatrics and Child Health (RCPCH), revealed that 40,000 deaths in the UK each year are attributable to exposure to outdoor air pollution.


A government that is serious about protecting people’s health must make a legally binding commitment to meet World Health Organization (WHO) guideline levels for particulate matter pollution by 2030. This should be part of a long-term framework that also establishes new binding commitments to reduce people’s exposure to pollution, with a need to prioritise pollution reduction around schools, nurseries, playgrounds, extra care housing, locations with high levels of home care, care homes and hospitals. Binding targets should be set in a way that responds to the latest evidence on the health impacts of pollution and drives further reductions beyond 2030.


Central government is best placed to ensure that binding targets are met across the UK. However, to ensure effective and coordinated action, all levels and arms of government need to play their part. We need a new ‘clean air duty’ that requires all public bodies to factor air pollution into all their decision-making. Currently, there is no such explicit, broad statutory duty on local authorities or wider public bodies and corporations, such as the Coal Authority, BBC, Highways England, Homes England, NHS England, Network Rail and the UK Space Agency.


Will the Environment Bill provide England with a robust legal framework to define and enforce air quality limits?


The Environment Bill provides the government with an opportunity to set a course that could see the UK leading the way to clean up the air that we all breathe. As with most environmental issues, air pollution is also a health issue. The Bill, in its definition of “natural environment” excludes interaction between the natural and built environment. It could be fundamentally strengthened by being widened to incorporate this as referred to in the Clean Air Strategy 2019, particularly where there are impacts on human health.

In its current form, the Bill once reintroduced in parliament must be strengthened by:


  1. Introducing a legally binding commitment to meet World Health Organization (WHO) guideline levels for fine particulate matter (PM2.5) pollution by 2030 at the very latest.

The UK government has rightly recognised the need for a new binding target for PM2.5, one of the most harmful forms of air pollution. However, the Bill does not include specifics about what that new target will be, and delays setting the target for another two years. The Bill should increase ambition to protect people’s health, but currently, it risks allowing the weakening of existing legal limits for air pollution, meaning current protections could be eroded in the future.


  1. Ensuring that Robust plans are implemented to ensure binding targets are met. As they stand the Environmental Improvement Plans required by the Bill are insufficient to guarantee action to protect people’s health and meet the new air quality targets. The plans need to include timetabled, health-related impact-assessed measures that ensure the necessary improvements are made, alongside action to protect those most vulnerable to the effects of air pollution.


  1. Creating ‘clean air duty’ which would ensure all public bodies contribute to improving air quality. In its current form, the Bill risks pushing the burden of responsibility onto local authorities with no required action from central government. However, local authorities are unable to tackle this public health crisis alone and lack the money and resources to drive effective local action. All levels and arms of government should be required to play their part. Further efforts need to be made to highlight the co-benefits of meeting climate change objectives and cleaning up the air we breathe.


  1. While DEFRA and the DfT have taken increased interest in developing clean air strategies, there needs to be a greater level of engagement from the DHSC, especially since PHE does not have the necessary resources to disseminate information about the health benefits of cleaner air and what stakeholders need to do to reduce emissions. Another issue that requires urgent attention is the lack of engagement of health professionals (e.g. Hospital Specialists, GPs and public health physicians) not yet taking ownership of air pollution health problems as they did so successfully for active and passive tobacco smoking. For example, making changes to the GP contract with NHS to cover aspects to do with air quality and health would be a great help especially to patients with respiratory and cardiovascular diseases 



What does the early evidence from the COVID-19 pandemic say about the impact of poor air quality on health, and health inequalities for disadvantaged communities and other at-risk groups, and possible policy responses?


What are the current and emerging risks and opportunities for air quality posed by:



The changes we have seen to everyday life has led to people developing healthy habits that have cleaned our air, lowered our emissions and kept people safe. There is a new normal unfolding. Given the disproportionate impact of COVID-19 on disadvantaged communities, it is crucial that we avoid returning to the health-damaging levels of air pollution we had before lockdown. The current rapid increase in road traffic in response to COVID-19-related avoidance of public transport is not a sustainable situation and a new long-term plan for getting people back to using safe public transport is needed.


While recent announcements promoting ‘active travel’ is welcome, the government’s enthusiasm needs to be permanent and not just a short-term gap plugger. Further investment into a sustainable transport model that promotes cycling and walking and reduces pollution from modes of transport should be part of a fair and green post-coronavirus economic recovery plan aimed at creating a cleaner, fairer future.


With the introduction of affordable local air pollution monitoring such as Breathe London and similar activities elsewhere, there should be a move towards empowerment of people to know the levels of particulates and other pollutants in their neighbourhoods and workplace locality as occurs in some European cities such as Paris.


The imposition of national and regional lock-down has shone a light on the importance of the indoor environment as an important source of air pollution. The 2020 report, The inside story: Health effects of indoor air quality on children and young people, has highlighted some of the adverse effects of poor indoor air quality. It includes recommendations that require action from a number of same stakeholders but also a different set of stakeholders than those for outside air in the natural environment. Among these is a need for a government department to take responsibility for developing a national strategy and policy for cleaning up the air inside buildings where most people spend over 80% of their time, or more in the case of the more vulnerable. The strategy should designate a ministerial lead to report on the work to the Cabinet. The government should establish a cross-government committee to co-ordinate working in health, environment, education and homes for indoor air quality.  The interaction between the natural environment and buildings and structures is important and must have government oversight and coordinated action.