Opinion: Richard Card – A full inquest to look at Thanet ‘hazards to life’

Water supply

Thanet resident Richard Card is a retired electrical engineer and was the over 40s national Wales powerlifting champion 1992. 

The grandfather has Chronic obstructive pulmonary disease (COPD) from lung damage caused while in the Army Coldstream Guard Air Platoon in 1970.

Here he looks at his concerns related to Thanet’s water supply which he has been researching for many years:

People are saddened by this week’s news that judicial reviews, against the NHS decision making process denying QEQM its own specialist stroke unit, have failed. 

There is also sad news about maternity unit tragedies at QEQM.  HM Coroner has made a preliminary examination in one loss and is to decide whether to hold full inquest as an “Article 2” inquest and with jury.   I hope HM Coroner does this.  The wider ranging Article 2 Inquest looks more at a broader context of hazards to life. It examines whether the state failed in its duties to protect life and lessons to be learned.

NHS planning is governed by the Health and Social Care Act 2012.  It creates reporting duties for local authorities.  Of particular interest must be the duty to report environmental hazards to health.

To my mind there is a welcome development as protesters, against possible habitat destruction for housing development at Poorhole Lane, broadened their concerns to include the massive remediation project over 12 years that recovered 470 tonnes of leaked cyclohexanone from Poorhole Lane chalk strata.  The leak had lasted for a suspected 30 years from 1963 to 1993 and the total amount has never been calculated. 470 tonnes was the size of the residue.

Rumfields Drinking Water Abstraction Plant was switched off in 1993 upon discovery of the leak.  It is my belief, based on all the evidence I have seen, that for 30 years an undetermined amount of this solvent was contaminating drinking water.

Incredibly, it seems to me, the local authority wedded itself to the view that when (AND IF !) the contaminated site is remediated all the people who (presumably) drank the water for 30 years have been miraculously healed. The idea of legacy impact on public health seems to me to be alien to the echelons at Cecil Square.  And hence they don’t take the view it is their statutory duty to report it to NHS for expert examination and incorporation in NHS planning factors.

In 2007 the Department of Environment Food and Rural Affairs (DEFRA) issued warnings about the persistent residue of firefighting foam PFOA.  This is on the United Nations list of “Persistent Organic Pollutants” – The Stockholm Convention.  The warning light was there.  Manston aquifer was a source of Thanet drinking water but it can be seen from freedom of information answers that Southern Water has never tested the site for PFOA.

Last year I called in DEFRA Drinking Water Inspectorate who told me “Southern Water do have a treatment works which abstracts water from the aquifer below Manston. However, this treatment works has been out of supply for quite a few years due to having high level of nitrate in the source water and the company being able to maintain local supplies without using it.

“We (Defra)  will require an updated risk assessment (and sampling data to back it up) if the company put the site back into supply. This is a regulatory requirement (Regulation 15) and the company are aware of this.”

Among the many hazards to health of PFOA, as I understand them, are stroke risk and pre-eclampsia risk.

I have asked Kent County Council Health and Well Being Scrutiny Committee to put this on the agenda for discussion in March when they meet to discuss the maternity tragedies. The local authorities have powers under the Health and Social Care Act 2012 to raise their own expert inquiries for onward report to NHS planning.

I have also reported to HM Coroner.

*A Thanet council response, made in 2008, to questions about the Sericol leak can be found here


  1. Up to about 3 / 4 years ago a Laboratory company used to take regular water samples from the aquifer beneath the (East Kent Retail Park) now named Westwood Retail Park, [ Mataland/ pets at home / Iceland / B&M / Pound Stretcher Harvey .]
    There are small round inspections covers dotted over the site from where the water was taken from. This site backs onto Poorhole Lane. Not sure why the firm stopped analysing the samples.

  2. What about future threats to our health from a 24/7 freight terminal dropping particulates and other dangerous chemicals from their exhaust emissions now highlighted by qualified medical teams.

    • The question framed is about cumulative impact. The area has high rates of COPD. Airborne particulates from an airfield are lung irritants. No cumulative impact assessment, to take account of the pre existing aberrant disease rates in Thanet, has ever taken place.

      When May 2019 United Nations Stockholm Convention upgraded PFOA to max toxic hazard to health .. in my opinion the Riveroak construction phase plan was obsolete before its ink dried. I have seen no plan to prepare for DEFRA enforcement of PFOA containment that starts in about a years time. Not at Riveroak and not at TDC.

  3. Is there any evidence (as distinct from supposition) that there is anything wrong with our drinking water? Is there any proxy evidence (eg the people of Thanet losing their hair)?

    • You miss the point. The duty to test these things is with TDC and Southern Water. Have they fulfilled their statutory duties ?

      You indulge a fallacy belief that there is a default position of all being well unless someone proves it aint well!

      It is a duty upon the state to ensure that all is well.

      As for correlations between Thanet aberrant levels of disease and the chemical contaminations being cited … highest stroke rate in Kent, highest copd rate in country ? High rate of colorectal cancer … maternity tragedies.

      So yes there is abundant “Proxy” correlation.

      • So no evidence, then?
        I don’t actually “indulge” any “beliefs” whatsoever.
        I do like to see hard science, though. Reports devoid of comments such as :
        “The leak had lasted for a *suspected* 30 years from 1963 to 1993 and the total amount has *never been calculated*”
        ” It is *my belief*”
        “Incredibly, *it seems to me*”

        These are all emotive, conditional or subjective statements.

        Lets have some actual facts.
        For example, how is the Kent Police inquiry into the acquisition of Manston going?

        • A fact is Southern Water never tested the water supply for the chemical PFOA.

          I would like to see hard science. There is some on Southern Water response to FOI of their post 2001 Lord of the Manor testing results .. no mention of nitrates there.

          You clearly are a fallacy thinker. So I’ll try once more. Your fallacy is to believe all is well unless someone proves it aint well.

          The burden of proof on the protestor is to show that authorities failed to comply with statutory duties to safeguard us.

          The police inquiry arose from Chief constable response to reports which are subject of mandatory reporting law. The reports were made by the concerned investor who withdrew from draft contract to invest in Manston. . It was Chief constable decision to appoint economic crime unit to inquiry. So maybe if you direct your question to chief constable ?

          The reason it is a “suspected” 30 years is because no one knows for sure. It is important because it would inform what levels of cyclohexanone got in water supply. Another indicator might be epidemiology impact inquiry to look at rises in correlated conditions since 1963.

          To calculate the initial toxic loading would be calculable from Sericol audit records. Production costs would have reduced from moment loss was stopped.

          What value do you put on 470 tonnes of cyclohexanone residual in chalk layers ?

          • What is a fallacy thinker? It seems to me that Tony is just asking for plausible proof and references to support the allegations made in the article. He has not expressed his opinion as to whether “all is well” or not. How could he do
            so, when he is asking you for evidence because (I suppose)he doesn’t know much about the subject?

  4. The bore holes are no longer used to check the ground water as Sericol removed the residual in the chalk under watch of EA and further tests showed little trace of any contamination according to TDC at the time. Southern Water was not taking water at Rumfields at the time it was discovered, but if the leak had been over 30 years then there was a chance contaminated water was being taken during those years.
    Southern Water apparently do not draw water from the aquifier under Manston as that water is already contaminated with nitrates. If a fully functioning airport were to open then there would be further contamination to that aquifier. More attention by the authorities needs to be focused around this issue.

    • The Rumfields water abstraction was turned off 1993 as a result of the Sericol leak discovery. The Environment Agency best guess is that leak was 30 years undetected accessing drinking water.

      Why I tend to believe that was so, is that I have found out what happened on initial installation site 1963. And who was involved.

      Southern Water claimed to DEFRA DWI they suspended use of Lord of the Manor some years ago due to nitrates.

      (1) That does not feature in their answers to Freedom of Information requests dated before the DEFRA DWI were called in.

      (2) TDC submission to National Planning 2018 (Which is alarming reading) is in present tense about lord of manor drinking water source protection zone

      (3) Nitrates were not reported to TDC.

      (4) Southern Water have a history of massive fines for lying to regulators.

      The contamination at issue is residue of firefighting foam used in past.

      The Manston Development has avoided cumulative impact assessment, precautionary principle and site remediation planning.

      There is a Kent Police economic crime unit inquiry into acquisition of manston. Added to that as an intelligence report is crime complaint against a former TDC leader re concealing toxic environmental hazards to health, contrary to law, from NHS |CCG Planners.

  5. Sericol realised there was a loss of Cyclohexanone and inquiry ensued. Because the solvent is over a drinking water aquifer Rumfields Water abstraction was turned off.

    Hence at the time a leak source was discovered Rumfields was already switched off.

    TDC and others who wish to mislead about the contamination have used pedantry to imply Rumfields was switched off before the leak started. They are lying.

  6. An allegation has been raised which has been rebuffed by the relevant authorities. It is now down to the person making the allegations to provide substantial evidence that their case is strong.

    Just repeating that the relevant authorities are lying and there is some huge cover up just sounds like a ridiculous conspiracy theory. Where is the medical evidence proving that there has been health issues in the local area? Compared to which control group ?

    • The allegations raised are that authority has not complied with statutory duties in environmental protection, in planning and in NHS planning law.

      In Sept 2018 I opened pre action protocol to seek a mandatory Order of the High Court to compel TDC, and hence Clinical Commissioning Group, to comply with statutory duties.

      Far from “Relevant authority rebuffing” the facts are on the record and maybe you missed them ? TDC made the following statement to National Planning Process re Manston

      In fact ironically I had suffered a stroke and was in hospital having to drop the High Court action !

      TDC statement 2018

      “The site lies entirely within the catchment of the Source Protection Zone (SPZ) for the Lord of the Manor groundwater abstraction. This abstraction, which is a significant groundwater resource, relies substantially on an adit in the Chalk which runs below the existing runway, approximately 50m below the site. The runway and part of the site are in SPZ Zone 1, and the south-central and south-east part of the site is in SPZ Zone 2.
      4.5.7 The Chalk aquifer derives its permeability from secondary permeability (fracture flow) and is therefore highly susceptible to pollution due to rapid transport of dissolved and particulate contaminants through fracture networks. Groundwater from the chalk rock beneath Thanet is used to supply water for drinking water, agriculture, horticulture and industry. It also feeds the springs that emerge along the coast and near the marshes. The groundwater is extremely vulnerable to contamination as substances (natural substances and man-made chemicals) are able to pass rapidly through the thin soils and the natural fissures (cracks) in the chalk rock to the groundwater below the ground surface.
      4.5.8 It is considered that the former land use is likely to have resulted in potentially significant land quality impacts, particularly in the runway area where Fog Investigation and Dispersal Operation (FIDO) was carried out and runway foams were used. This method for clearing fog was used during the Second World War and was installed at Manston Airport. The FIDO system used the burning of fuel either side of the runway to disperse fog to enable aircraft to land safely.
      4.5.9 The previous use of chlorinated solvents and radiological materials are also potentially significant issues that may be present and complex to deal with as well as the potential for asbestos to be present in soils (possibly in deliberate disposal pits of significant volume). The adit under the runway which feeds the Lord of the Manor PWS is a highly sensitive receptor protecting this receptor may require rephrasing or redesign of the scheme once the distribution of contamination is better understood.
      4.5.10 The Lord of the Manor PWS is not identified as a separate receptor. This is an omission and should be included, due to the presence of an adit which feeds the PWS directly below the runway. Specific measures may be needed to protect this receptor that would not apply to the wider aquifer.
      4.5.11 A County-wide Contaminated Land Strategy is being prepared by the Kent & Medway Contaminated Land Forum and will form part of the evidence base for this Plan once it has been finalised. The Council has a Contaminated Land Strategy for the district – this is currently being reviewed”

      • “Where is the medical evidence” The fact is it is not a burden on the complainant it is a burden by statutory duty on the relevant authorities (who have rebuffed nothing !)

        Having said that the facts are after my FOI of 2008 revealed the Sericol facts from Environment Agency I copied the EA response to Health Protection Agency And their medical expert said long term health impact study should be made.

        I don’t know why no such inquiry took place. But I have asked the expert inquiry into QEQM maternity tragedies to contact the former HPA doctor and get his answer and recall.

        But I repeat It is a fallacy to base your positions upon an idea that there is a default situation in which all is well unless someone can prove all aint well. In the rational world the law places duties on authority to test and verify all is well. The burden of proof on a questioner or complainant is a matter of law. The allegation is authority did not comply with statutory duties.

        So far contrary to assumption above … authority has not “Rebuffed” “Allegations”

        Mostly authority says they have no record. No “Evidence” They cannot prove they did comply with statutory duty.

        • It is a well recognized principle that absence of evidence is not evidence of absence.
          Several times, several people have asked you to support the claims you’ve made. But all you do is embroiled yourself in complicated arguments about burden of proof.
          It seems to me that what you’re basically saying is that you don’t need to prove that anything bad is happening because the Authorities haven’t proved all is well.

          • Correct. I don’t have to prove the consequence of breaches of statutory duties I have to prove the duties were breached.

            Your fallacy position is that authority should only be questioned about breach of duty if the questioner can establish a consequence . Which is utter tosh. It is the tosh of saying “If they got away with it they should continue to get away with it”

            Another fallacy you embrace is an assumption all consequences would have manifested by now. A position for which you have no evidence.

        • Has Richard Card actually proved that the statutory duties were breached by the relevant companies and local authorities?

          A list each statutory duty followed by proof that this duty was breached would be clear and useful.

          I still don’t see where Tony says that he assumes everything is ok regarding this possible water- pollution situation. I also don’t see how one aquifer can be isolated from another uniess there is a layer of impermeable rock all round it- is the latter the case with Manston?

          • It is established that TDC never reported toxic environmental hazards to health to the Clinical Commissioning Group.

            For example if Southern Water told DEFRA the truth last year that abstraction was suspended due to a nitrates problem then why do TDC have no record ? This would have been reportable in NHS Planning law.

            If your question is “Has Richard Card any proof that statutory duties were breached” ? Then because the burden of duty is on TDC it was a simple matter to ask them by Freedom of Information Act. They have been warned a number of times by Information Commissioner re failures to answer They have had schedules set on them by Information Commissioner. Internal Reviews are long overdue (One is one year one day overdue today actually)

            I would suggest if it was TDC position that there are no toxic hazards to report then they have had ample time to take that position. Their statement to National Planning 2018 would hardly be helpful to their cause would it ?

            Lord knows what you think Tony’s position is ! According to you He hasn’t said or implied that everything is fine until someone proves the contrary then ? So according to you Tony accepts that toxic hazards to health exist in Thanet ? Orwellian Double Think Marva.

            I try to be courteous and to answer comments. But that is it now. Unless a comment is rational and fallacy free I will ignore it now.

      • I’m sorry, but I don’t understand the significance of your posting this extract from TDC’s submission to the ExA.
        Would you mind posting a link to your data for the incidence of COPD in Thanet. It would be useful if this data spanned a number of years. It would be useful, too, to include data over similar time scales for other areas of similar socio-economic backgrounds, for comparison.

        • The Thanet health stats are public record.

          Does it not occur to you to wonder for example about “Fido” of WW2 finally getting a TDC mention in 2018 ? Surely you must wonder what ever happened with the risk assessments for use of Manston aquifer 1945 to 2018 ???

          TDC are there finally mentioning fire fighting foam. DEFRA first issued warnings on this in 2007 the chemical “PFOA”

          In May 2019 the United Nations upgraded PFOA on its list of most toxic persistent organic pollutants. PFOA was already UN listed and TDC should have acted on that just as they should have acted on DEFRA Warning 2007 and Public Health England warning 2009.

          UN Stockholm Convention. DEFRA will be enforcing this starting in about a years time.

          So you misunderstand the issue.

          But your mention of socio economic circumstances is illuminating. What USA is finding is that in contaminated zones around US Forces air bases the PFOA blood serum levels are tending to be higher in the middle class who buy local grown veg and local caught fish.

          It being self evident that toxic contaminants do not discriminate on the basis of socio economics.

          Let me repeat. The issue is a matter of law of statutory duties.

          If TDC have complied with duties, to report environmental hazards to health to NHS Planners, if they had complied with controlled waters duties in environmental protection law then why have they got no compliance records.

          The question of what consequence breaches of statutory duty had/have ? Is a future issue

          The significance of TDC submission is that under threat of High Court action they changed position and admitted error and announced a review.

          First I seek to prove TDC broke statutory duties.

          If Baby Archie is granted an Article 2 inquest it is possible that HM Coroner will examine this and hopefully take expert evidence. The independent inquiry into QEQM maternity tragedies is already aware of the history in which toxic environmental hazards were not reported for NHS evaluation.

          I have asked KCC Health Scrutiny to discuss the statutory duty issue at their March meeting to discuss maternity tragedies.

          Under the 2012 Health and Social Care Act the local authority can commission its own research for onward report to NHS planners.

  7. “The Thanet health stats are public record. “.
    Sorry, Richard: to save me hunting, would you mind simply pasting the link here, to save me spending ages looking for stuff, and finding the wrong resource etc.

  8. I can’t believe that you have spent well over 12 years of your life pursuing this. Fair enough, if all the relevant authorities turn around one day and admit all their experts were wrong and Richard Card was in fact right then this was a crusade worth fighting.

    However, the chances of this happening are something like winning the lottery or being struck by lightning so I would helpfully suggest (for your own peace of mind and personal contentment) that you move on and find something else more positive to focus your energy and life on.

    That’s all intended to be helpful rather than insulting by the way.

  9. I should think that Tony would have no opinion one way or the other as to whether toxic hazards exist in Thanet, as he does not seem to have very many facts about this at present. Neither have I, of course.

  10. “All the relevant authorities” Name them and what their “experts” said ?

    “I should think Tony would have no opinion” (I couldn’t possibly comment)

    If there are no toxic hazards in Thanet I am at a los to explain TDC admission to National Planning and review of contaminated land “Strategy” Surely they could have consulted you lot and been reassured all is well.

    So your position is that because there are no toxic hazards to health TDC were right not to report them ??

    Which is a position different to that of Health Protection Agency expert 2009.

    I have provided that expert name to the current expert inquiry into QEQM.

    And I have also asked them to consider asking a former QEQM consultant who is now based in Cheshire who was raising questions about Thanet water supply 15 to 20 years ago.

    Now what part of toddle along don’t you understand. Southern Water have had no applications to be re connected to Manston aquifer so it rather looks as if you bozos take the benefit of someone else’s efforts criticise but don’t have the courage of your convictions to drink the water from that aquifer. Never mind hopefully Kathy will publish another piece for you to be anon armchair experts about. You haven’t eviscerated Steve Coombes lately.

    • I would rather expected that someone who had published an “Opinion Piece ” on Isle of Thanet News would be able to support their cause without resorting to calling people “bozos”.
      Simple facts will support your case, if there are any.
      Again I ask you: please post a link to the incidence of COPD in Thanet, the one to which you refer.

    • Well, Richard Card, as you see, I am not anonymous. So could you please tell me where Ramsgate’s drinking-water comes from? Thank you.

  11. I cannot see where anybody commenting here is saying that there are no toxic hazads in Kent.
    Richard Card could you please explain “Now what part of toddle along don’t you understand”? As you have written an opinion piece, you would surely expect some people to be sceptical of your argument.

    Could you also please tell me where my tapwater comes from? I live in Ramsgate. Thank you.

Comments are closed.