8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

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This year, Sasha Haldane and her husband, Will Hayward, took one of the biggestdecisions of their lives. They decided that, for the sake of their two children, theywould leave Hong Kong.

Haldane grew up in the city and, apart from a brief spell in Australia and NewZealand, had lived and worked here all her life. Max, 10, and Alyssa, six, were bothborn and raised in Hong Kong. Their parents had good jobs and the children weresettled happily in schools. One factor alone compelled them to leave.

"Will became very concerned about the air pollution as he is an ultra-marathoner,"

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Families packing up andleaving Hong Kong overpollution life expectancyfearsWith children the most at risk from Hong Kong's air pollution, some familieshave reluctantly packed up and left behind friends and comfortable lifestyles.Angharad Hampshire looks at the dangers and what is being done to addressthem WE RECOMMEND

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A BANNER SHOWING AN IDYLLIC HARBOUR VIEW BELIES THE TRUE PICTURE BEHIND. THE AIR-POLLUTION INDEXON THAT DAY, AUGUST 22 LAST YEAR, WAS AT "VERY HIGH", WITH THE CITY BLANKETED IN HAZE. PHOTOS; SAMTSANG; MAY TSE; K.Y. CHENG; DAVID WONG; AFP; WILL HAYWARD/COURTESY OF THE HAYWOOD FAMILY;COURTESY OF THE BRINNER FAMILY

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8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

Page 2 of 10http://www.scmp.com/magazines/post-magazine/article/1501490/bad-air-daze-air-pollution-and-our-children?page=all

Professor Anthony Hedley

says Haldane. "He was really noticing the air quality when he was running, and I wasnoticing that you could no longer see across the harbour most days in winter. Whatwas meant to be the best time of year, October/November, was now the worst."

Hayward worked as head of the psychology department at the University of HongKong. Concerned about the deteriorating air quality, he sought out ProfessorAnthony Hedley, an expert on air pollution at HKU's School of Public Health. Hediscussed the problem with Hedley and set about reading a long list of scientificpapers on the effects of pollution.

"As a result of those papers, we realised thatif we did not leave, we were going to reduceour children's life expectancy. What weunderstood was that, whilst it was bad foryounger children living in this air quality,the most impact was going to come whenthey were teenagers, when the greatestexpansion of their lung growth wasoccurring. The pollution could affect thatexpansion so that when they were mucholder, in later life, they would be less able torecover from respiratory illnesses and morelikely to die earlier."

So, with heavy hearts, the family looked forplaces with cleaner air in which to live.

"When a job came up in Auckland, NewZealand, Will was happy to move," Haldanesays, from her new home. "He is from New

Zealand and has family here. Auckland has very good air quality for the size of thepopulation. But there were no other factors. We both had very good jobs, greatfriends and a wonderful lifestyle. In January, we moved."

Hong Kong has long prided itself on its high life-expectancy figures. However, thoseliving to a ripe old age now grew up with much cleaner air.

Lai Hak-kan is a research assistant professor at HKU's School of Public Health. Hestudies the impact of pollution on health and has no doubt that children growing upin Hong Kong now should expect shortened lives.

"Our studies find that 10mg of particulate matter will cause two years of lifeexpectancy lost. In Hong Kong, we are looking at 45mg to 50mg of such matter.Theoretically, this means 10 years of life lost."

The World Health Organisation recently reported that one in eight deaths globally islinked to air pollution, making it "the world's single largest environmental healthrisk". Out of the seven million deaths attributed to pollution in 2012, six millionoccurred in Southeast Asia and the Western Pacific - the region containing GreaterChina.

One of the biggest predictors of life expectancy is lung function. Our lungs take inclean, oxygenated air and distribute it to our tissues to enable them to function.When we breathe in dirty air, our respiratory system - including its major organs, thelungs - becomes damaged and cannot operate properly.

"There are a number of negative health impacts for air pollutants but most of thefindings from medical literature indicate that the main impacts are on cardiovascularhealth and also on respiratory diseases," says Lai. "Some studies also indicate thatlonger-term exposure can be linked to cancer development."

The impact is worse in children than in adults.

"One of the basic principles we know when we are handling health problems inchildren is that they have small organs which are growing day by day. So, all thosecardiovascular, respiratory and lung functions need to be developed into maturity inhealth to prepare them for the demands of the future. If, however, they are exposedto things which are harmful, the effect is much more significant than if these systemsare already fully developed. The implications are much higher and have a lifelongconsequence. We have growing evidence that long-term respiratory andcardiovascular problems are strongly related to early exposure to environmentalpollutants. The lungs and heart are immature in particular before primary school."

Watch: How to deal with Hong Kong's smog

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8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

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Hong Kong's once fragrant harbour is thick with a fug of cargo-ship emissions, trafficfumes and output from coal-powered power stations and factories in Guangdongprovince. The city's topography of mountains and high-rise buildings causes acanyoning effect, which prevents toxic air from dispersing. All this contributes to thesmog that Haldane had noticed folding its way round the city, billowing through theharbour and hanging between buildings.

This smog consists of many substances. First is sulphur dioxide (SO2), an odourlessgas that is caused by the combustion of fossil fuels in power plants, industrial boilersand vehicles on land and at sea. SO2 damages the respiratory system and aggravatesrespiratory disease, for example bronchitis. It causes wheezing, shortness of breathand coughing. It can also cause cardiovascular disease in people with sensitiverespiratory systems, including asthmatics, the elderly and children.

Second, nitrogen oxides (NOX) and nitrogen dioxide, which are formed throughcombustion at a high temperature in power plants and vehicle engines, at land and atsea. Nitrogen dioxide is a smelly brown gas that irritates the lungs and lowers thebody's resistance to respiratory infections such as the flu. People with respiratoryproblems (for example, asthmatics) are more susceptible to the effects of NOX. Inyoung children, these gases impair lung development and chronic exposure leads tostructural changes in the lungs.

Third, ozone, which is formed by the reaction of nitrogen dioxide in ultraviolet lightand makes a photochemical smog. Ozone irritates mucous membranes in the nose,throat and airways. Because it's "consumed" by the gaseous pollutants found byroadsides, ozone is often more prevalent at higher levels in outlying areas, such asthe New Territories, where people may feel there is less pollution. It causes coughs,chest pain, throat pain and eye irritation, decreases lung function and inflames therespiratory system.

Those are the main gases. Then come some non-gaseous nasties - fine particlescalled respirable suspended particulates (RSPs). They are made of matter that issuspended in the air but is not a gas - so liquids, solids or a mixture of the two.Measured by their size, RSPs are divided into two categories: PM10 and PM2.5. ThePM10 particles measure 10 micrometres or less across and PM2.5 particles measure2.5 micrometres or less. These miniscule particles are produced by combustion -particularly in diesel vehicles and power plants - construction, incineration and, innature, the sea. Often, the particulate matter is small bits of unburnt or partiallyburnt carbon attached to elements such as silicon, aluminium, sodium, calcium,manganese, iron, barium, mercury and lead.

Lead is particularly dangerous to young children as it damages the nervous system,red blood cells and kidneys and can cause brain damage. Many RSPs arecarcinogenic.

The problem with RSPs is both their size and the chemicals they contain. PM2.5particles are so small that our noses can't filter them out. They get breathed straightinto the lungs, where they deposit on the lining and have no way out. RSPs cause awide range of problems, such as blocked airways, coughs, decreased lung function,aggravated asthma and the development of diseases such as bronchitis. In peoplewith existing heart and lung disease, they can cause premature death from the likesof lung cancer.

Dr Lee So-lun is honorary clinical associate professor at HKU's Department ofPaediatrics and Adolescent Medicine. She explains why children are so much morevulnerable to these pollutants.

"Firstly, it's biological, meaning that the build-up of their body is different. All theorgans are still growing and maturing during childhood. Any insult to growing

8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

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Stirling and Rebekah Brinner with theirchildren, Zoe (right) and Tabby, inPhiladelphia.

organs causes a long-term impact, unlike in adults, who have mature systems. Plus,their body system cannot remove toxins as well as adults. Then we have to look at thelungs because that is where the air pollutants are going. Lungs are maturing inchildhood and we know that toxins on growing lungs are harmful. Our immunesystem is also immature in childhood. So, if you have a toxin that interacts with agenetic predisposition, it can cause things like allergies and asthma.

"There are also physiological differences," Lee continues. "The lung wall in a baby isproportionally much larger than an adult's. This means far more pollution circulatesthrough the system. Babies and small children also have tiny airways, so anythingthat aggravates them will have a far greater impact. Also, children are much moreprone to mouth breathing, which stops their noses filtering dirty air. Children areusually much more active than adults, so they tend to run around breathing in muchmore polluted air."

Scientific studies show that mothers living in polluted areas are at greater risk ofhaving babies with low birth weights and congenital malformation. Animal studieshave linked attention deficit hyperactivity disorder (ADHD) and hyperactivity toearly exposure to air pollution.

Rebekah and Stirling Brinner, an ITmanager, lived in Hong Kong for five years.Both of their children, Zoe, now five, andTabby, two, were born in Hong Kong. Theystruggled with Zoe's reaction to thepollution.

"Zoe was born with eczema," says RebekahBrinner, a former nurse. "But conditions inHong Kong exacerbated it. As your skin isyour largest barrier to infection, she gotminor illnesses more often than her peers,and she had trouble sleeping due toconstant intractable itch. The worst came inthe form of repeated skin infections. Herwhole body was covered in painful, itchy,oozing sores. She was absolutely miserableand was hospitalised with a major infectionat one point, not to mention the frequenttrips to private and public doctors foroutpatient treatment."

The Brinners ruled out other possible causes such as soaps and allergies. Their curecame whenever they left Hong Kong on holiday. Almost immediately, Zoe'sinfections and skin flares subsided. As soon as they returned to the city, her skinflared up again.

"I know that it's hard to pinpoint the specific cause of eczema, as it's at least partiallygenetic and, if you have it, it never actually goes away, but it can be managed and youcan reduce triggers. Every doctor we've discussed it with has agreed that thepollution was a likely factor, especially considering that we ruled out the other likelytriggers.

"We had to leave because our daughter had a very low quality of life. She couldn't beallowed out of my sight otherwise she would scratch until she bled, which could andoften would lead to another infection, not to mention potential for scarring and needfor more strong medications. Stirling and I discussed it and decided we needed to gether out of the toxic environment as soon as possible, and he was lucky enough toquickly find a job."

They left Hong Kong in May last year.

"We now live in a suburb of Philadelphia, in the United States. We've been herenearly 11 months and she hasn't had a single infection or flare. We've significantlyreduced both the potency and frequency of topical steroids and she has gainedindependence because she can be allowed to do things on her own. She sleeps betterand has gone from the third percentile on the Child Development Centre growthchart up to the 25th percentile."

The Brinners miss Hong Kong culture and friends but are certain they made theright choice.

"Zoe asks frequently when we are moving back but she is thriving here. We've hadsome rough days, but then she'll say that her skin doesn't hurt anymore. So far, thefuture looks bright, our daughters are excelling. Ultimately, Hong Kong seemsunable to do much about the pollution as so much of it comes from the mainland.Sad, as we really grew to love the city."

Forty-seven per cent of Hong Kong's pollution comes from the Pearl River Delta. The

8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

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rest is made up of the city's own roadside, marine and power-station emissions.

Global studies show that the highest impact on children's health is from roadsidepollution. Living, walking or going to school next to a busy road is much more likelyto harm children than ambient air pollution from the mainland.

Arthur Lau Pui-sang is adjunct associate professor in the Division of Environment atthe Hong Kong University of Science and Technology. In collaboration with ChineseUniversity, he is running a citywide study of the health effects of pollution in primaryschools. The study looks at 3,000 students aged nine and 10 in 30 primary schools tofind out how the air quality is affecting them now and consider their long-termpulmonary development. The study will follow up with these children in two yearsand then, funding permitting, a further two years later.

Lau's initial findings show that the distance from a road is a major factor in childhealth. A safe distance is defined as 200 metres. The direction the windows face andgeneral wind direction also dictate how much pollution enters a school environment.As does the proximity of school buses, which often have polluting engines left idling.

The season is important, too. In summer, when the windows are shut and the air-conditioning is on, the air inside a classroom is much cleaner. In winter, whenwindows are more likely to be open, classroom air quality is dependent on outdoorair quality.

"The reality in Hong Kong is that there are lots of schools next to busy streets," saysLau.

The WHO has drawn up a gold standard of air-quality objectives (AQO) to provide aguideline about safe levels of pollution. As one would expect, Hong Kong falls farshort of the WHO's objectives. As a result, the government has set up some interimobjectives of its own. The city uses the WHO's guidelines for nitrogen dioxide andcarbon monoxide but has adopted the lowest interim target levels suggested by theorganisation for SO2, ozone and PM2.5 particles, with a slightly better target forPM10 particles.

Air is measured in 12 general stations and three roadside stations throughout HongKong. This information is compiled into the Air Quality Health Index (AQHI), whichis available online and via an app so the public can view levels of pollution anddecide how best to protect their families on bad days.

The system looks at levels of the four major pollutants and works out in real timewhat the percentage risk to health is. It then categorises the risk on a scale of one to10.

At times and in places when/where a reading is high (7+), the government's advice isthat children reduce the amount of time they spend - and especially exert themselves- outside. Once it hits very high (8+), children are advised to reduce outdoor time toa minimum, and when it's serious (10+), to stay inside. In effect, that is thegovernment's advice - go outside less or stay indoors.

Under the previous air-pollution index, which was replaced by AQHI at the end oflast year, 6 per cent of days were considered dangerous to health in Hong Kong.Under the new system, 30 per cent of days are considered dangerous. If the indexconformed to WHO standards, about 90 per cent of days would be deemeddangerous.

Wong Tze-wai is a research professor at Chinese University's School of Public Healthand Primary Care. He led the project to develop the AQHI system and is a specialistin community medicine who has conducted research on air pollution and health formore than 20 years.

"For a warning system to work," says Wong, "you need to avoid the phenomenoncalled 'information fatigue'. If we issue a warning to the public every time the air-pollutant concentration [for example, PM2.5] is above the WHO 24-hour guideline[25 micrograms per cubic metre], we end up overwarning, because on most days,Hong Kong's level of PM2.5 is around 30 or so. If we overwarn, the public will notrespond.

"Moreover, it would not be desirable to advise the schools to cancel the PE classevery time any one air pollutant exceeds the WHO guidelines, for that would meanno PE classes on 90 per cent of days in a year."

So, if the only available solution to bad air days is to stay indoors, how much cleaneris indoor air?

"In general, indoor air quality is better than outdoor air quality, provided there is noindoor source of air pollution, for example cigarette smoking, incense burning, gascooking, furniture - especially new - that emits harmful volatile organic chemicalssuch as formaldehyde," says Wong.

Lee warns parents not to become complacent just because a child doesn't show any

8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

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Undersecretary for the EnvironmentChristine Loh.

immediate symptoms.

"We are looking at this from a population level. Just because your own child doesn'tseem to be affected does not mean it's not a big issue. It is a serious medical concernand something we have to deal with because of the long-term effects.

"The weather, outdoor environment and indoor environment all affect us," says Lee."Outdoors there's humidity and pollen, for example. Indoors, house dust mites andpassive smoking. There are so many variables in the environment. While oneelement of the environment is high at any given time, others are low and that is whypeople can react differently."

Undersecretary for the EnvironmentChristine Loh Kung-wai, anenvironmentalist and herself a mother, iscommitted to reducing the city's pollutionand, since she began her tenure, Hong Konghas introduced measures to tackle theproblem. Loh recognises that both a localand a regional approach are needed and hasbeen working with the governments hereand in Guangdong to facilitate change.

By 2019, Hong Kong will have phased outits most polluting older diesel vehicles andbuses. A subsidy scheme is in place to assistowners of taxis and light buses to replaceworn-out catalytic converters by the end ofthis year. Funding is also available forfranchised bus companies to clean up theirexisting fleet. At sea, domestic and rivervessels refuelling in Hong Kong had toswitch to very low sulphur diesel by April 1and regulations are being drafted to compel ocean-going vessels to switch to lowsulphur fuel while berthing in the city's waters from next year. That would makeHong Kong the first port outside the US and European Union that legislates for afuel switch at berth.

By 2017, Guangdong is aiming to reduce PM2.5 levels by 15 per cent. Furthermore,Hong Kong and Guangdong have already successfully completed one round ofpollutant reductions.

"In 2012, we agreed on a second round of targets for 2015 and 2020," says Loh.

Her goal is to meet the city's current air-quality objectives by 2020. Sheacknowledges that these objectives don't meet the WHO's standards but explainsthat interim goals are necessary as there is no point setting standards that simplycannot be met. She promises the objectives will be reviewed - and tightened ifpossible - every five years.

"Probably more than anyone else, I know how much we are doing in Hong Kong andin Guangdong. We must implement our plans well and then we must do more still,"says Loh. "Five years ago, I was the CEO of a non-profit think tank where we didsurveys to assess the level of concern in Hong Kong about air quality. Today, there isno question in government that air pollution isn't a top priority. The chief executivehas already made this clear."

"The situation has actually improved a bit in the past decade," says Dr Alfred TamYat-cheung, a paediatrician in private practice and a member of the Advisory Councilon the Environment. "The general stations have recorded decreasing levels ofpollutants except for O3 while the roadside stations have recorded increasing levelsof NOX and RSP. So although the general situation has improved, the roadsidesituation has not.

"I think it is safe to bring up children here as long as you avoid the roads," he says."The general situation is better than many cities in the mainland and it [is getting]better slowly."

Too slowly for people such as Haldane, though. Unlike most parents in Hong Kongwho fear for the well-being of their children, she could leave the city without toomuch trouble, but she'd prefer to return. That will not happen, she says, until thegovernment adopts the WHO's AQO.

"I realise that Hong Kong is hampered in terms of the pollution from China but thegovernment could crack down more on the pollution from incoming ships and thetraffic, and should have done so years ago instead of listening to special interestsectors.

"I was not happy to leave. I am a Hong Kong girl. I have my entire life there. I love

8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

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Hong Kong. It is my home. Right now, I am really homesick. But I had to make thedecision for my children. I had to give them the best chance for a long life."

For an alternative look at what Hong Kong's monitoring stations are telling usabout air quality, take a look at HKU's Hedley Environmental Indexhedleyindex.sph.hku.hk/html/en (http://hedleyindex.sph.hku.hk/html/en) .

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dunndavidMay 5th 20146:55pm

Two antidotes from China: 1. A provincial Chinese Metrology Department contacts my friend who asks me to find a mobile device to checkindustrial pollutants. No spec, just verbal notification. We tell then to do it right you have to have a bulky samplecollection case, probe, signal line and then the customer has to say what gas species they want to test for (NOx.SOx, or PM 2.5) whatever. Than you need to give us a protocol for that gas and you need to assign a lab to run thetest. Total cost USD 30K+ than test cost. Chinese Metrology Department comes back and says no what they want isa hand-held device like a big scientific calculator that they can get instantaneous results with at a fraction of the cost.We say that is impossible and withdraw from the inquiry. The bottom line - Chinese aren't serious about sourcepollution measurement.2. We try to sell equipment that helps control NOx from new power plants. Devices used by most U.S. power plantsand no comparable device in China. Chinese power plants come back and say that with the 2014 anti-corruptioncampaign, power plants can't spend more on anything than they have spent for a similar product in the past. I.E. noimprovement possible in 2014 for new power plants.The bottom line - Chinese aren't serious about source pollutioncontrol.

HK-LoverMay 5th 20146:20am

One of the biggest polluters is the use of electricity and here the government itself is one of the biggest culprits.If you look around in the night you can see that in all government buildings (schools, public housing, administrationbuildings, legco etc. etc.) all backstairs are illuminated permanently throughout the night. The same applies to all residential and office buildings, car parks, universities, private schools etc. Why is that ? Why is there no legislation that makes it mandatory to use motion sensors to switch on the lights inbackstairs only temporarily for the rare occasion someone uses the backstairs ?This Mrs. Christine Loh could be introduced immediately to all future buildings and the ones currently underconstructions and within less then 5 years to all existing buildings.

AFTER READING THIS ARTICLE, PEOPLE ALSO READ

8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

Page 8 of 10http://www.scmp.com/magazines/post-magazine/article/1501490/bad-air-daze-air-pollution-and-our-children?page=all

skhkMay 5th 20143:51am

Awesome and informative article folks! Great work.

dcdMay 4th 20146:39pm

Probably the best piece of journalism I have ever read in the SCMP (including the 'magazine'). A whole different levelof quality from SCMP's standard fare of scandal-mongering headlines followed by thin and questionable content.This addresses a very serious problem, is highly factual, and draws balanced conclusions (as opposed to screaming'run for your lives' the way an article about the government or the financial industry might). Please keep this up. Theissue is important, and good information will be necessary for the good of everyone in Hong Kong.

milanaMay 4th 20145:52pm

I don't understand why it needs to take years before anything can be achieved. The biggest problem seems to beroadside and the government can do something about that TODAY, not tomorrow or in 10 years!

skywalkerMay 4th 20145:40pm

Good for those who can just leave Hong Kong. Many others are born here and cannot just re-locate (actually:moving back) to where they came from. But in Hong Kong it is more important to have motors of taxis idling, so that the old taxi drivers do not get a heatstroke.

dynamcoMay 4th 20145:16pm

www.industrytap.com/worlds-15-biggest-ships-create-more-pollution-than-all-the-cars-in-the-world/8182sadly, you are al missing the major point .............of where our major pollution source is on 3 sides of HKG 24 x 7

rawmMay 4th 20144:00pm

It's a step in the right direction to exempt fully Electric Vehicles from First Registration Tax until 2017.But by far it's not enough. Why not double the FRT for regular cars to make EVs more attractive.

dingrscnmnpMay 4th 201410:12pm

In addition, legalize electric assisted bicycles instead of persecuting users of such modes oftransport and create a more bicycle-friendly environment.

8/6/14 10:36 pmFamilies packing up and leaving Hong Kong over pollution life expectancy fears | South China Morning Post

Page 9 of 10http://www.scmp.com/magazines/post-magazine/article/1501490/bad-air-daze-air-pollution-and-our-children?page=all

CarparkleeMay 4th 201412:45pm

Whenever I see vehicle running with a tail of thick black smoke, I feel extremely angry and helpless. I can see veryclearly the registration no. plate on the vehicle and I can even take picture of it. But, all this still sounds useless. Ireally hope that EPD can fix the law so that general public can be entitled the right to report polluting vehicles on theroad by using pictures taken and sent to government agencies via medium like the 1823 smartphone app.

rpaseaMay 4th 20142:35pm

You can report smoky vehicles at tellme@1823.gov.hk. They will want date, time and location inaddition to plate number.

dynamcoMay 4th 20145:12pm

and sadly nothing will happen unless:www.epd.gov.hk/epd/english/how_help/report_pollution/spotter_training.html

dynamcoMay 4th 20148:42am

EDWARD YAU’S DO-NOTHING LEGACYSHIPPING OUR MAJOR POLLUTERFrom: tony_yt_lee@epd.gov.hk Sent:27 Jun 2011 05:54 PMTo: dynamcoSubject: E(11/1515) : Port Strategy - A new dawnthe sulphur content of any fuel oil used on board ships in Hkg is not to exceed 4.5% m/m. As mentioned,since China has not designated its waters (including that of Hkg) as an Emission Control Area, there isno vehicle for Hong Kong to "require" operators to use fuels of more stringent specifications. 6. HKG is supposed to be an independent territory for 50 years from 1997 is it not? We make our own laws do wenot? The EPD intends to designate Low Emission Zones for traffic on Nathan Road, Cwb & Central so that only Euro5 diesels / hybrids will be allowed to enter those areas. I see no difference with doing the same for HK waters –either meet the relevant standards or do not enter our waters or be fined if you do. Using "China did not do it" is a lame duck reply more worthy of Bowtie than a body supposed to be looking after theair quality here, in this 50 year independent SAR. EPD Ans. Under MARPOL Annex VI, there are general requirements on the sulphur content of any fuel oil used onboard ships.. the International Maritime Organization (IMO) can apply for designating its waters as an EmissionControl Area (ECA). Hong Kong is an associate member of IMO, not a full member (member state) & thus cannot filean application for ECA designation by Hong Kong itself. Tony YT Lee

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