White Paper on a Clean Air (Wales) Bill - consultation response

In March 2021 we responded to the Welsh Government’s consultation to create a requirement to review and publish a Welsh Clean Air Plan Strategy every 5 years. We welcomed this proposal as this will ensure that essential action will be taken to reduce air pollution.

The purpose of this consultation was for Welsh Government to set out a number of potential legislative proposals for inclusion in a Clean Air (Wales) Bill. The document sets out the main reasons why there is a need to enhance air quality and how they propose to change it to enable an air quality management framework to be put into place which delivers the best outcomes for all.  

Poor outdoor air quality is a major issue in the UK. Our position statement recognises that air pollution is linked to a variety of health conditions and contributes to a large number of deaths every year. It is also linked to climate change, which itself poses wide-ranging threats to health and wellbeing.

Our response

We drew upon evidence from our Clean Air Position Statement as well as State of Child Health data and recommendations around asthma;  and insight from children and young people via our Voice Bank.

  • We are supportive of the introduction of an evidence-based framework to set new air quality targets as action can then be taken when needed to reduce harm and to deliver the most effective and sustained outcomes for children and young people.
  • We agree with the proposed quality target setting framework and welcome the establishment of an independent panel of experts to provide advice and recommendations on the target setting process and specific priority air pollutant targets which will assist in improving the long-term health of children and young people in Wales in the future.
  • In our response we agreed that there was a need to clarify and strengthen the legislation. We strongly support national policies, practices and legislation that aim to improve outdoor air quality and advocate for sharing information and supporting the public to act.
  • We are supportive of the efficient and effective roll-out of Clean Air Zones / Low Emission Zones in Wales, the expansion of clean air zones in towns and cities and expanding the infrastructure to support active travel, travel by public transport and electric vehicles.  
  • We welcome the proposal to introduce the concept of partners to improve collaboration and provide support to Local Authorities ‘partners’ to develop, implement and review actions to improve local air quality.
  • Our position statement recognises that whilst there are actions to be taken at an individual level, many of the identified ways to improve outdoor air quality rely on national and societal change, led by Government. The NHS and professionals working in the NHS can help and lead the change, both as role models and through their interactions with the public.

Our recommendations

  • We recognise that everyone has a responsibility for reducing air pollution, and strongly support action to improve air quality and inform the public of the issue. Paediatricians should be aware of the guidance and use it to inform patients and their families of the health impacts and encourage and support them to make positive changes to improve air quality and reduce their exposure to air pollution.
  • Better inform and support health professionals to take local action and provide advice to patients". Health professionals have a duty of care to inform their patients of the dangers of air pollution and how they can better protect themselves from it.
  • Working with relevant authorities and agencies across the UK to progress the recommendations listed in this position statement, with the aim of achieving steady improvement in UK outdoor air quality
  • We would also welcome the involvement of children and young people within the plans. Our RCPCH &Us engagement network have highlighted the importance of engagement with children and young people in all decision making.
  • Across the UK, the most deprived communities experience the worst air quality, further driving health inequalities. Air pollution is a clearly modifiable and avoidable cause of morbidity and mortality and as such, action can and should be taken to reduce or remove this harm. It is important to consider the impacts are pollution has on the health of children and young people specifically long-term conditions.
  • We recognise that this consultation is primarily in relation to outdoor air quality but feedback from our paediatricians highlighted that in terms of indoor air quality it was important to enforce the law on no smoking in cars with children.

The RCPCH also conducted a systematic review to find scientific studies about effects of indoor pollution on children’s health. The working group recommended that the Government and local authorities should:

  • Develop a national strategy, set indoor air quality standards, and have a national body to lead on indoor air quality.
  • Introduce emissions labelling of household products and building materials.
  • Give clear information for the public, local authorities, building professions and child health professions.
  • Establish a process for people in rented and social housing to report indoor air quality problems. Provide assistance for necessary improvements.

We respond to a wide range of consultations to ensure that the College’s position, and ultimately children’s health, is represented. Members in Wales can get involved in current consultations by contacting the Health Policy team: enquiries-wales@rcpch.ac.uk.