Response to the Passage of the Air Pollution Control (Amendment) Bill 2024

Clean Air Network (‘CAN’) welcomes the passage of the Air Pollution Control (Amendment) Bill 2024, which addresses a loophole in the Air Pollution Control Ordinance, Cap. 311, and will empower the Government to cease unlicensed operations of cement plants that cause public nuisance.

It also represents progress towards the Government’s commitment to achieving the ultimate goal of having Hong Kong’s air quality fully meet with the Air Quality Guidelines (‘AQGs’) of the World Health Organization (‘WHO’).

To further improve air quality to protect the health of the public, CAN calls for even more enhanced AQOs, in particular for nitrogen dioxide and ozone, due to their severe health implications. Also, CAN suggests that the Government provide a clear timeline and roadmap for aligning Hong Kong’s AQOs with the WHO’s ultimate targets.

Indoor Air Quality (‘IAQ’)

Human exposure to outdoor and indoor air pollution has equally significant health implications. While there has been progress made in reviewing AQOs for ambient air quality, IAQ has not received sufficient emphasis and attention.

Currently, the Government relies on a self-regulatory model to manage IAQ. Notably, the Government updated the Guidance Notes for the Management of Indoor Air Quality in Offices and Public Places in 2019, followed by the release of guidance notes for the management of IAQ in schools and elderly homes in 2022.

However, public education on IAQ remains insufficient, and there is limited awareness of the impact of IAQ on health. CAN suggests that the Government strengthen its public education programs to significantly enhance societal awareness of this issue.

From a policy perspective, CAN believes it is most pressing to protect children from prolonged exposure to indoor air pollution. The lungs of infants, children and adolescents are still developing and are more susceptible to damage from pollutants. Exposure to harmful substances can lead to respiratory issues, impair normal lung development, and have long-term consequences for respiratory and circulatory systems. Poor IAQ may also negatively affect children’s mental health and cognitive performance and hence their learning ability.

Based on our observations and discussions with operators who manage spaces frequented by children, and our assessment of current IAQ practices in Hong Kong, CAN believes the Government should develop a long-term policy roadmap to provide clarity on an IAQ regulatory framework for public spaces frequented by children.

CAN also recommend amending the Air Pollution Control Ordinance to introduce indoor AQOs with mandatory regular reviews, as is the case for ambient and roadside AQOs. Such indoor AQOs should apply to public spaces frequented by children, including schools, preschools, nurseries, hospitals, clinics, and libraries. The pollutants and parameters covered should include carbon dioxide, fine suspended particulates (PM 2.5 ), respirable suspended particulates (PM 10 ), volatile organic compounds (VOCs) such as formaldehyde, relative humidity, and temperature.

CAN’s submission to the Bills Committee on Air Pollution Control (Amendment) Bill 2024 of the Legislative Council in December 2024 can be found here.