Request ID: FOI-0121-2324 Date published: 11 May 2023
Hi, do you have a list or a number of customer/worker complaints regarding air quality on the London Underground?
Clarification received 13/04/2023: . Can you use the dates from January 2015 until the present day please. So, 5 years normal conditions plus 2 years of covid 19 lockdowns etc.
TfL Ref: EIR-0121-2324
Thank you for your request received by Transport for London (TfL) on 10th April 2023 asking for information about London Underground dust and air quality complaints.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations (EIR) and our information access policy.
Specifically you asked:
“Air quality or dust complaints:Hi, do you have a list or a number of customer/worker complaints regarding air quality on the London Underground?”.
On 13th April 2023 this was clarified as follows:
“Can you use the dates from January 2015 until the present day please. So, 5 years normal conditions plus 2 years of covid 19 lockdowns etc.”
I can confirm that we hold the information you require. However, I am afraid that there is no particularly quick or efficient way of sourcing the data requested, and hence the request is being refused under regulation 12(4)(b) of the EIR on the basis that it is ‘manifstely unreasonable’. The rationale for this is explained below.
There is no single source of data within TfL for both “worker” and “customer” complaints. Hence, to find the information you are looking for we would have to interrogate separate systems. In terms of staff, TfL does not have a standalone system for reporting staff complaints related to air quality on the London Underground. However, we do have a safety incident reporting system which records all safety incidents, including those related to air quality. Since January 2015, our safety incident reporting system has recorded 34 safety incidents on the London underground related to air quality issues. Please note, this covers a wide range of issues such as the accumulation and/or disturbance of dust; dust generated from maintenance activities (e.g. grinding); or non-dust related incidents such as the presence of fumes (e.g. vehicles, paint, poor ventilation). Furthermore, please note that ‘safety incidents’ are not the same as ‘complaints’. In addition to this, there is a fault reporting centre whereby complaints of this nature could be logged. An advanced search has been undertaken for this period and 17 records are logged under the key words – “air quality” and then “dust”.
In terms of customer complaints, there is no automatic way of finding an answer to your question as we do not log cases using a keyword such as “dust”. Rather, colleagues in our Customer Services team can run an automated search using a term such as “air quality” but to determine exactly what such complaints were specifically about (such as in relation to dust, air temperature, fumes, or any other aspect of “air quality”) we would have to manually review each and every complaint. An automated seach was run for the years 2015-2019 and this alone returned over 780 potential complaints on the broad theme of “air quality”. To manually review each of these to see exactly what they were about would take an estimated 39 hours (at a rate of 3 minutes per case). Clearly, covering the remaining 4-year period covered by your request would take even longer still. We do not believe that this is a proportionate use of our resource, hence the application of the Regulation 12(4)(b) exception.
The use of this exception is subject to the ‘public interest test’, which requires us to consider whether the public interest in applying the exception outweighs the public interest in disclosure. We recognise the need for openness and transparency in the operation of our business, and the fact you have requested the information demonstrates that there is an interest in it. However, the time it would take to provide the information would divert a disproportionate amount of our resource, and on balance we consider that the public interest currently favours the use of the exception.
More generally speaking, note that dust levels on the London Underground are within the limits set by the Health and Safety Executive with respect to inhalable and respirable dust workplace exposure standards (COSHH Regulations and EH40/2005 Workplace Exposure Limits). The most recent monitoring data showed a respirable dust level of 0.57 mg/m3, which is well within the more stringent limits recommended by the Institute of Occupational Medicine (1 mg/m3 for respirable dust and 5 mg/m3 for inhalable dust). However, we want to reduce levels further through our programme of targeted cleaning on the Underground and regular monitoring levels of tube dust. We are looking for innovative new ways to further reduce dust levels.
TfL engaged fully with the COMEAP report "Particulate Pollution on the London Underground" (2017) which recommended further research into the characteristics and concentration of Tube dust particulates and potential health impacts. TfL therefore commissioned Imperial College London to independently examine the possible health impacts experienced by London Underground workers who are most regularly exposed to tunnel dust. This includes investigating sickness absence in relation to dust exposure and examining pensions data to see if historical exposure to tube dust is associated with deaths due to lung or heart disease, which is due to be published in 2024/25.
Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
COMEAP is the Committee on the Medical Effects of Air Pollutants