Follow on from FOI-2372-1617 & IRV-029-1718 Further to your internal review (Ref: IRV-029-1718), and your offer of a further internal review, I should be grateful if you would please proceed with a second internal review of the content of the response to FOI-2372-1617. In so doing please take into account the need to advise and assist me to facilitate the disclosure of information and to respond as soon as possible within the statutory time to respond. In light of your additional attempt to reach a satisfactory outcome for me in offering a second review I have re-considered the request I made and tried to focus it better to assist your response. I hope this will lead to full disclosure. My original request comprised of the following elements: a. the information you hold regarding the current air pollution experienced by commuters in the underground system (both on trains and in stations); b. the health risks that may occur for them in using your services; c. in particular […] I want to know about all significance health risks to me in using the underground; d. please also disclose to me all reports and internal briefings/memos or records of meetings you hold that cover the health risks to commuters on the underground over the last 3 years, the measures being deployed to mitigate this (and how effective those measures are); e. please identify the most dangerous/worst, and the best/least dangerous, underground lines to travel on and why; f. please provide this information in a table(s) organises in descending order with reference to each main pollutant. Your response did not address the majority of my request due to your assertion that it was ‘manifestly unreasonable’ as it would ‘take an excessive amount of staff time and resources’. The information I seek is of great interest to me and the general public who use your services. However, I recognise that part d) of my request might have been broad in scope. To assist you in narrowing your search I should be grateful if you would reconsider and respond to the following more specific requests, which are more limited in scope. Please would you: 1. identify, and provide copies of, any current or recent (in the last 3 years) internal policies or risk assessments (including in relation to Workplace Exposure Limits) regarding the levels of Nitrogen Dioxide in the London Underground network; 2. identify, and provide copies of, any current or recent (in the last 3 years) internal policies or risk assessments regarding the effect on the health of (1) drivers, (2) station staff, and (3) passengers of exposure to Nitrogen Dioxide in the London Underground network; 3. identify, and provide copies of, any current or recent (in the last 3 years) internal policies or risk assessments regarding air quality mitigation or filtration measures implemented, and their effectiveness, in relation to (1) drivers, (2) station staff, and (3) passengers in the London Underground network; 4. identify any ongoing methods of monitoring air quality within the London Underground network in relation to Nitrogen Dioxide and provide datasets and/or assessments of such datasets for the last 12 months; 5. identify in table form a list of (1) underground stations, and (2) underground lines, ranked from highest to lowest concentration for both particulate and non-particulate air pollution, specifying the relevant non-particulate pollutant. I believe these refined requests are not manifestly unreasonable because in each instance the information I am asking for ought to be in a form that is easily identifiable and readily available to you, such as current risk assessments and internal policy documents. There is clearly a strong and wide public interest in this information, which is highlighted by recent TfL press release (23 June 2017) which undertakes to improve air quality on the tube. The underlying issue to which this request relates; the extent to which responding to the request would illuminate that issue; and the wider value of the information being made publicly available is absolutely in the public interest. The information I have requested is of at least the same importance as the information that has recently been made available regarding particulate air pollution in the London Underground. I would like to emphasise the need for you to respond as soon as possible within the statutory timeframe, as this was not remotely adhered to with my earlier request. Please provide the information electronically to save time, cost and paper. However, I can supply a postal address if needs be. I understand that as this is another internal review that, failing disclosure in accordance with the Environmental Regulations 2004, I will be entitled to refer this matter directly to the Information Commissioner’s Office for determination.

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TfL Ref: FOI-1022-1718

Thank you for your request received by Transport for London (TfL) on 31 July 2017 asking for information about air quality.

Your request has been considered in accordance with the requirements of the Environmental Information Regulations and our information access policy. I can confirm we do hold the information you require. You asked:

•  

• Identify, and provide copies of, any current or recent (in the last 3 years) internal policies or risk assessments (including in relation to Workplace Exposure Limits) regarding the levels of Nitrogen Dioxide in the London Underground network

   

   

  London Underground does not generate significant quantities of Nitrogen Dioxide from its business activities however it is aware that it is an air pollutant of significance to London. As a business we do not routinely monitor staff exposures to Nitrogen Dioxide in station or vehicle settings. Nitrogen Dioxide levels in the city are monitored and reported by the London Air Organisation (see link below). Any staff exposure to Nitrogen Dioxide will be reflected in the figures published in this report by virtue of the locality they work in.

   

   

  http://www.londonair.org.uk/LondonAir/Default.aspx

   

   

  At present there is no workplace exposure limit for Nitrogen Dioxide in the UK however taking account of the Scientific Committee on Occupational Exposure Limit’s (SCOEL) recommendation for Nitrogen Dioxide exposures London Underground works to a precautionary limit of 0.5ppm (8 hour time weighted average) where exposure could be a potential health risk.

   

   

  http://ec.europa.eu/social/search.jsp?advSearchKey=nitrogen+dioxide&mode=advancedSubmit&langId=en&x=19&y=12

   

   

  During maintenance operations in tunnels there is often the need to use diesel generators. This occurs mostly in situations overnight and therefore outside of the normal operating times. It is during these activities that the greatest potential risk of exposure to both Nitrogen Dioxide and Carbon Monoxide is anticipated. For control measures see appendix 1.

   

   

• Identify, and provide copies of, any current or recent (in the last 3 years) internal policies or risk assessments regarding the effect on the health of (1) drivers, (2) station staff, and (3) passengers of exposure to Nitrogen Dioxide in the London Underground network

   

   

  London Underground does not possess any specific policies relating to Nitrogen Dioxide exposure to drivers, station staff or customers. This is covered by our procedures concerning control of diesel exhaust emissions (appendix 1).

   

   

  The rationale for this position is that exposures to Nitrogen Dioxide in the London Underground network will not be any higher than those monitored and recorded by London Air which are well below any proposed Workplace Exposure Limit (Proposed SCOEL exposure limit).

   

   

  Attached as Appendix 1 is Transport for London’s procedure – Control of Diesel Engine Exhaust Emissions which includes exposure to Nitrogen Dioxide and other exhaust gases (see section 8).

   

   

  London Underground commissioned the following report on methodologies to reduce Oxides of Nitrogen and Carbon Monoxide from diesel engines. This report is primarily aimed at protection of maintenance staff working in tunnels rather than drivers, station staff and passengers, who are not exposed outside of normal operating hours when maintenance operations will take place.

   

   

  Attached as Appendix 2 is a report commissioned by TFL on reducing emissions from diesel engines;

   

   

  Options for NOx and CO reductions for London underground diesel engines (draft)

   

  A consultancy project for 4 Rail Services Ltd

   

   

  Dr Hu Li and Andy Ross

   

  School of Process and Chemical Engineering

   

  The University of Leeds

   

  10th July 2015

   

   

• Identify, and provide copies of, any current or recent (in the last 3 years) internal policies or risk assessments regarding air quality mitigation or filtration measures implemented, and their effectiveness, in relation to (1) drivers, (2) station staff, and (3) passengers in the London Underground network;

   

  Attached as Appendix 3 is a copy of Transport of London’s Guidance on Occupational Exposure to Respirable Dust. This is primarily aimed at managing dusts from construction and maintenance activities.

   

  Filtration technologies are not applied to air in the underground network the exceptions being air drawn in the drivers cab and air conditioned trains on some of the lines (Circle / District line) which have filter units on the intakes. The filtration achieved will differentiate from line to line due to the use of different types of train used.

   

  The net effect of filtering passenger cabin air is limited by the fact that the train doors  open at each station.

   

•  

• Identify any ongoing methods of monitoring air quality within the London Underground network in relation to Nitrogen Dioxide and provide datasets and/or assessments of such datasets for the last 12 months;

   

   

  There are no ongoing methods to assess Nitrogen Dioxide exposures in the London Underground Network.

   

   

  The rationale for this is explained in items 1 & 2.

   

   

• Identify in table form a list of (1) underground stations, and (2) underground lines, ranked from highest to lowest concentration for both particulate and non-particulate air pollution, specifying the relevant non-particulate pollutant.

Attached are a number of air quality monitoring reports undertaken by both TFL and contractors. Pollutants measured are listed below. London Underground only monitor particulate pollutants because it is these pollutants that we partly generate and are of more interest from a health perspective.

Inhalable Dust

Respirable Dust

PM 10’s

PM 2.5’s

PM 1.0’s

Respirable Crystalline Silica

Iron

Nickel

Copper

Chromium

Zinc

Manganese

The levels measured are considered against the Health and Safety Executive’s Workplace Exposure Limits (EH40)

http://www.hse.gov.uk/pUbns/priced/eh40.pdf

Dust  Monitoring  Results Appendices:

Appendix 4    Respirable Airborne Dust Monitoring at Various London Underground Stations and Train Lines – 1^st May 2015*

Appendix 5    Respirable Airborne Dust Monitoring on the Victoria Line – September 2015*

Appendix 6    Respirable Airborne Dust Monitoring at Various London Underground Stations and Train Lines – 22nd September 2016*

Appendix 7    Pre Clean - Station and Tunnel Dust Monitoring Results. May-June 2017

Appendix 8    Post Clean - Station and Tunnel Dust Monitoring Results. July – August 2017

*Denotes that these documents have been provided to you previously under case ref FOI-2372-1617 and so are not included in this response

If this is not the information you are looking for, or if you are unable to access it for some reason, please do not hesitate to contact me.

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.

Yours sincerely

Lee Hill

Senior FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

Attachments

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