Skip to content

MENU

Quick guide to air pollution
MENUMENU
  • Public
    • Understanding
      • Annual Pollution Maps
      • Breathe London Blueprint
      • Clean Air in Cities App
      • Defra modelling 2015
      • Defra annual reports
      • How polluted is my road?
      • LAEI 2013
      • London Air
      • 187 focus areas
      • Mayor's useful links
      • 50 polluted roads
      • NO2 diffusion tubes
      • Oxford Street NO2
      • Schools near roads
      • Roadside modelling
      • South East schools
      • What kills Londoners?
    • Action
      • 10 steps
      • Airgonomics podcast
      • Chief Airgonomics Officer
      • Cycle Streets routes
      • EN 13779 hospitals
      • EN 13779 London 2014
      • Face masks
      • Get our mobile app
      • LAQM
      • Legal guide
      • London Plan
      • Mayoral questions
      • Mode choice
      • Putney Society
      • Sunday Times Clean Air Campaign
      • TfL cycling routes
      • Under the Dome (Part 7 from 9.36 mins)
      • Using FOIA/EIR
      • Using social media
    • Smog
      • airTEXT
      • Breathe London - Sloane Street
      • Copernicus
      • Defra hourly bulletins
      • Defra UK-Air
      • EEA Air Quality Index
      • Episodes
      • Health advice
      • Hourly bulletins
      • Jetstream
      • London Air
      • Mayor's school report 2016
      • MetClim
      • Met Office guide
      • Modelling
      • Plume London
      • RBKC monitors
      • SAS selection deaths 2013
      • Smog list on Twitter
      • 24 hour forecast
      • 84 hour pressure
      • 5 day weather
      • 10 day weather
      • 2 week weather
      • World cities AQI
  • Media
    • Media
      • News alerts
      • News
      • Statements
    • Links
      • Davey Cartoons
      • Flickr
      • Facebook
      • LinkedIn
      • Twitter
      • Vimeo
      • You Tube
  • Policy
    • Policy
      • Our Manifesto 2016
      • Clean Air Act
      • Health
      • Indoor
      • Legal
      • Olympics
      • Solutions
      • Sources
  • Resources
    • Guides
      • Guides
      • Guide to the 'Clean Air in Cities' app
      • Pollution Check
      • Pollution Suppressor
      • Smog
    • Resources
      • Davey Cartoons
      • App
      • Ella's Law
      • Indoor air
      • One Atmosphere (Vimeo)
      • One Atmosphere (YouTube)
      • Photos
      • Presentations
      • Videos
    • Links - Ella's Law
      • Clean Air (Human Rights) Bill
      • Ella’s Law
      • ellaslaw.uk
      • Ella Roberta Family Foundation
      • Inquest
      • EU lessons
      • Library briefing
      • New WHO AQGs
      • Petition
      • Supporters
      • The CCC's advice
    • Links - Health
      • Aphekom
      • Cognitive effects on children
      • COMEAP
      • IARC: Diesel
      • IARC: Outdoor/PM
      • JAMA
      • NO2 health study
      • NO2 meta-analysis
      • Public Health Indicators
      • PHI COMEAP advice
      • PHI Defra data
      • PHI PHE advice
      • RCP report 2016
      • Wellcome Witness - Air Pollution Research in Britain 1955 - 2000
      • WHO guidelines 2005
      • WHO AQG 2008
      • WHO AQG update 2017
      • WHO air pollution
      • WHO indoor guidelines
      • WHO HRAPIE
      • WHO outcomes
      • WHO publications
      • WHO REVIHAAP
    • Links - Legal
      • Air Quality Directive
      • AQSR 2010
      • CJEU judgment 2021
      • ClientEarth case
      • DG Environment
      • EU infringement cases
      • ECJ Judgement
      • EU Clean Air
      • EU Clean Air | Twitter
      • EU DGR findings
      • EU Environment Impact Assessments
      • EU financial sanctions
      • EU Fitness Check
      • EU infraction
      • EU infringement UK
      • EU legal processes
      • EU lessons
      • EU media releases
      • EU NECD emissions
      • EU NECD 2016/2284/EU
      • EU NECD revision
      • EU new AQ Directive 2022
      • EU reporting
      • EU TTIP
      • M4 bus lane
      • Planning resources
      • UK National Emissions Ceilings Regulations 2018
    • Links - Policy
      • Breathe Life 2030
      • Chief Airgonomics Officer website
      • CityAir
      • Defra media releases
      • DPF removal
      • Diesel emission standards
      • Diesel exhaust 2007
      • Diesel exhaust 2011
      • Diesel - history
      • Emissions Analytics EQUA Index
      • Engineering Cleaner Air
      • European Environment Agency
      • Fumifugium
      • GEO6
      • GEO7
      • Gothenburg 2020
      • Healthy Air Campaign 'asks'
      • Late lessons 1
      • Late lessons 2
      • LEZs in Europe
      • PX 2015
      • PX 2016
      • SDG scorecards
      • Shipping
      • 10 climate measures
      • What will climate change look like in your area?
      • WHO SLCP measures
  • About
  • Contact
  • Register

Open letter to Mayor Khan seeking urgent action on tube dust

Posted by Simon Birkett on 9 July 2017
Health, Indoor, News
Download pdf

Air pollution in the London Underground (‘tube dust’): expert health advice; warnings; and action

Dear Sadiq

I am writing on behalf of Clean Air in London (CAL) about air pollution in the London Underground (‘tube dust’ and ‘Tube’) to urge you to do much more, much faster to: understand the health risks (adopting a precautionary approach); warn passengers and potential passengers (with immediate, preliminary warnings); and reduce people’s exposure to it.

CAL welcomes your fresh approach to dealing with air pollution in the Tube announced on 23 June 2017, to the limited extent it goes:

https://tfl.gov.uk/info-for/media/press-releases/2017/june/mayor-launches-plan-to-improve-air-quality-on-the-tube

However, CAL was troubled to find subsequently that the independent advice and support mentioned in TfL’s media release was initially sought from the Committee on the Medical Effects of Air Pollution (COMEAP) on 23 May 2016, not now, in the form that CAL explicitly rejected in an unsatisfying dialogue with Transport for London (TfL) over many months.  That dialogue came after many years of CAL trying to get TfL and the previous Mayor to take air pollution seriously in the Tube.  CAL understands that, with limited resources, COMEAP met finally on 7 June this year and discussed a ‘literature search’ being undertaken which is being taken forward with TfL.

Last Monday (3 July), Lord Borwick (copied) asked the Minister, Lord Gardiner of Kimble, at the start of a two hour debate in the House of Lords:

“Will he ask the Committee on the Medical Effects of Air Pollutants [COMEAP] about the potential dangers of air pollution in the London Underground, who should be warned and what else should be done about it? I know the mayor has started to look into this issue but more work needs to be done.”

Then today (9 July), an exclusive investigation by Jonathan Leake of the Sunday Times (copied), quoted Professor Stephen Holgate of the British Lung Foundation, an eminent scientist and former Chairman of COMEAP (1992-2001), as saying, in the context of the investigation:

“The particles in underground railways are rich in iron and other metals such as copper, chromium, manganese and zinc.  Metal particles increase our risk of asthma, lung and cardiovascular disease and possibly dementia.” 

This statement is the starkest indication yet from an eminent scientist of the likely dangers of air pollution in the Tube and the need for much more action, much sooner by you as Mayor.  It compounds recent warnings and research from Professor Prashant Kumar, another eminent scientist.

Worse, CAL considers that TfL’s response quoted in the Sunday Times article was misleading, disingenuous or worse.  For example:

  • ‘health and safety’ standards relevant for TfL staff should not be the benchmark for population wide exposures to ‘tube dust’;
  • the ‘health and safety’ standards mentioned were rejected many years ago by leading experts including IOM and the TUC as being insufficient;
  • judging dangers or exposures relative to other air pollution exposures (such as diesel vehicles which emit carcinogenic fumes) rather than as absolute risks to public health is ridiculous; and
  • what does TfL mean when it says: “We have a new air quality programme to ensure particles are kept to a minimum?” By what measure(s) does TfL judge ‘minimum’ e.g. cost, convenience or the lowest level technically achievable?

As CAL understands it, scientists have found no safe level for exposure to airborne particulate matter.  Indeed, CAL’s understanding is that exposure to ‘dust’ can adversely affect health and it is important to keep dust concentrations as low as possible.     

Further, TfL’s previous protestations that tube dust is fundamentally different to (all) other forms of particulate matter because it is ‘heavier’ are nothing short of laughable.  If anything, Professor Holgate’s statement today suggests we might be more concerned not less relative to other forms of particulate matter.

In CAL’s opinion, it is also wrong for TfL to say or imply, as it has in the past, that such pollution is ‘safe’ when it is around some guideline levels in some locations: it is a bit like saying it’s safe to drive at the speed limit (in some countries).

Please take the following steps immediately:

1. COMEAP advice

Ask COMEAP the three questions proposed by Lord Borwick (and offer it resources) namely:

  • What are the potential dangers of air pollution in the London Underground?;
  • Who should be warned [and how and when]?; and
  • What else should be done about it?

2. Warn passengers and potential passengers on a precautionary basis

  • Ask Professor Holgate or the British Lung Foundation for advice, on a preliminary, urgent and precautionary basis pending the above advice from COMEAP, about public health warnings that you would initiate immediately and proactively to warn some or all passengers and potential passengers about air pollution in the London Underground.

3. Take every technically feasible step in the short-term, medium-term and longer-term to reduce people’s longest exposure to the highest air pollution in the Tube. This should include:

  • Platform barriers, like those on the Jubilee line, wherever technically feasible;
  • Commercial air filters on platforms that would match or exceed BS EN 16798-3:2017 ‘Energy performance of buildings’ which replaces BS EN 13779 on 25 July 2017. BS EN 16798-3:2017 uses ISO 16890 ePM1 (for particulate matter) and ISO 10121 (for gases); and
  • Ensuring that Crossrail’s air-conditioned trains include air filtration not just heating, cooling and ventilation. CAL understands they will have full-height platform doors.

Please note that Camfil, a leader in air filter solutions, has been a sponsor of CAL’s campaign to build public understanding of indoor air quality since 2011.  CAL and Simon Birkett have no financial interest or incentive to promote the use of air filters.

Please ensure TfL’s Board and Safety, Sustainability and HR Panel are involved fully in addressing the above issues.

CAL considers that your predecessor covered up the scale and dangers of air pollution in the London Underground and urges you therefore to go much further, much faster than you are currently proposing to address these serious problems.

I look forward to hearing from you.

Yours sincerely

Simon Birkett

Founder and Director

Clean Air in London

Cc:

Lord Borwick

Jonathan Leake, Science and Environment Editor, Sunday Times

London Assembly Environment Committee

Notes

‘Tube dust’: broken promises, ‘blind eye turned’ and duty breached

Tube dust is not ‘safe’

High levels of ‘tube dust’

CAL 352 Sunday Times_FOI Response 1889-1617 Appendices 1-6_V2

All news articles

Share this post

Share this article on Facebook Share this article on Twitter Share this article on LinkedIn
Tweets by CleanAirLondon

Calendar

  1. Anniversary (1955): Coke Prices (Increase)

    January 31, 2023

  2. Anniversary (2013): Tragic death of Ella Roberta Adoo Kissi-Debrah

    February 15, 2023

  3. Anniversary (1956): Atmospheric Pollution – Medical Research

    March 5, 2023

View all events

Categories

  • Apps5
  • Clean Air Act8
  • COP261
  • Great Smog1
  • Guides17
  • Health96
  • Hot topics18
  • Indoor20
  • Legal125
  • News264
  • Olympics23
  • Presentations17
  • Solutions91
  • Sources49
Clean Air in London is a company limited by guarantee, registered in England and Wales, with company number 7413769 and registered office Thames House, Mere Park, Dedmere Road, Marlow, Buckinghamshire, SL7 1PB
Privacy policy Terms of use

Favourites

  • ClientEarth
  • Healthy Air Campaign
  • Keep the city out
  • London Air Quality Network
  • Take a Breath
© 2023 Clean Air in London Registered company number 7413769
Allow us to send you notifications about news posts?
× No Thanks
This site uses cookies: Find out more.