Will the HIA wiki replace existing HIA websites?

There's an interesting debate taking place over at the HIA Wiki at the moment about the future of HIA websites around the world. Take a look at the discussion and take a few moments to add your point of view.

New Zealand inlcudes commitment to HIA in childhood obesity prevention strategy

New Zealand Prime Minister Helen Clark yesterday announced that policy HIA will be included as part of a portfolio of initiatives aimed at childhood obesity prevention

We are here today to launch Mission-On, a new $67 million government-wide package of initiatives to help New Zealand's children and young people become healthier, so they can lead active and successful lives.

...Finally, policy makers will be required to carry out health impact assessments when developing new policy and legislation.

Read speech in full

It will be interesting to see how this commitment to HIA develops in practice. The New Zealand Public Health Advisory Committee has developed guidelines on policy HIA which will be readily applicable.

Media Coverage of the Mission-On launch
Helen Clarks' Speech (Scoop)
Opposition Response (Stuff)
Unhealthy Foods Get Chop from Tuck Shops (NZ Herald)
Launch of $67 Million Campaign to Fight Obesity (Radio New Zealand
Campaign Pressures Schools Over Junk Food (Bay of Plenty Times)

Health in All Policies: New publication from the Finnish Ministry of Social Affairs and Health

The mark the Finnish presidency of the European Union (as we've mentioned before) the Finnish Ministry of Social Affairs and Health has published a book entitled Health in All Policies: Prospects and potentials [PDF 1.9 Mb]. The publication presents a number of examples of "health in All policies" in sectors such as education, the environment, water and sanitation, planning, labour, housing, traffic, agriculture and nutrition.

The book has five sections:

• Health in All Policies: The wider context
• Sectoral Experiences
• Governance
• Health Impact Assessment
• Conclusions and the Way Forward

HIA: What's new on the web?

The London Health Observatory has released a Guide to Reviewing Published Evidence for Use in Health Impact Assessment. The guide has been through quite a rigorous testing and peer-review process and a revised edition, incorporating user-feedback, is planned for 2008. I haven't had a chance to use if yet and I'd be interested to hear about your experiences using it.

The European Public Health Alliance has an interesting page comparing the health impact assessments that have been done on US and European food and agricultural policies.

Mary Mahoney, from the Deakin University HIA Unit, recently spoke about a retrospective HIA that she has undertaken on drought relief in rural Victoria in Australia. The ABC has a page with details on the conference and Mary's HIA, along with an MP3 file of their interview with Mary (MP3, 1.6 Mb).

Is HIA a Science?

About six months ago, I re-read the Merseyside Guidelines, the leading guidance on HIA in the UK. It's the guidance that every practioner in the UK, and I'm one of them, has read or says they've read. Okay, so first time round I read them quite quickly and I liked what I read. What I hadn't done three years ago, when I was a novice HIA practitioner still learning the ropes, was to read them critically. That's what I did second time around. Imagine my shock, as a signed up champion of science, when on re-reading them I found, at the back, this definition of HIA:

"Is health impact assessment a science?
It is important to emphasise that HIA is not strictly a science.
Having said this, it most certainly draws on a scientific knowledge base.
Scientific evidence on health impacts of specific determinants forms the backbone of this creative, interdisciplinary form of enquiry.
But each HIA is uniquely located in time, space and local conditions though its evidence base can be evaluated, and the rigour with which procedures and methods were implemented can (and should) be assessed.
Uncertainties encountered during the undertaking of HIAs will frequently dictate the need to make assumptions, which may result in challenges to the HIA’s validity: such assumptions are acceptable as long as they are stated explicitly, so that the reader is free to agree or disagree. ”

I agree with every part of this quote except the phrase "HIA is not strictly a science" because for me it describes perfectly what it means to apply scientific knowledge to the real world outside the lab.

For me, both HIA and science in all its myriad forms are "interdisciplinary forms of enquiry"; to misquote John Donne 'No science is an island entire unto itself every science is a piece of the continent, a part of the main'.

HIA for me is:

1. a systematic endeavour;
2. it uses knowledge and methods from other scientific disciplines e.g. epidemiology, sociology, toxicology and biology;
3. it aims for rigour,
4. it actively avoids bias and confounding;
5. the findings of one HIA have some applicability to communities of a similar social and cultural mix as that studied by the HIA; and
6. its results are subject to revision when new evidence or information comes to light that contradicts and refutes previous knowledge.

For me, this quote illustrates a misreading of science as about numbers and quantitative findings and about universal laws that transcend time and space. That works for the physical world (most of the time) but doesn't work so well for our social and cultural worlds where general laws and theories need to take account of local context. In fact even the universal laws of physics have to take account of local context. Science is about systematic enquiry where the resulting knowledge is always provional and subject to revision.

What's even more interesting is that environmental impact assessment practitioners don't have any qualms about calling EIA a science. Neither do economists or sociologists.

But public health professionals and HIA practitioners, in my experience, seem to have a problem with saying that HIA is a public health science? Or maybe I've got it wrong?

Health Impacts of the Built Environment

The Institute for Public Health in Ireland has released a review on the health impacts of the built environment, complementing their earlier reviews of the health impacts of employment and transport. The review provides a useful basis for understanding the range of health impacts that may arise in relation to the built environment, though the lack of contextually-specific detail may make it more useful as a document that guides scoping.

The review includes the version of the determinants of health diagram developed by Goran Dahlgren and Margaret Whitehead that has been adapted by Barton and Grant to include a planning perspective. What I think is missing from the model is the important role health services still play in determining health outcomes, though their absence may be understandable given the audience for whom the diagram was adapted (land use planners, social planners, local government, etc).

I'm reminded of McKee's (2002) observation that McKeown's influence on public health was to popularise the view that improvements in mortality were mostly due to improvements in living conditions (McKeown 1979). Mackenbach and his colleagues refuted this, at least in part, by demonstrating the decline in deaths from conditions that could be altered through health care represented a major part of overall improvement in life expectancy in The Netherlands between 1950 and 1984 (Mackenbach et al 1988).

I think there's still an important role for health services in contributing to a reduction in health inequalities and ensuring population health gains. What do you think?

References
Mackenbach J, Looman C, Kunst A, Habbema D, van der Maas (1988) Post-1950 mortality trends and medical care: gains in life expectancy due to declines in mortality from conditions amenable to medical interven-tion in The Netherlands. Social Science and Medicine 27:889-894.

McKee M (2002) What can Health Services Contribute to the Reduction of Inequalities in Health?, Scandanavian Journal of Public Health, 30(Supplement 59) p 54-58.

McKeown T (1979) The role of medicine: dream, mirage or nemesis? Oxford: Blackwell.

Monitoring and Evaluation

An excellent introduction to monitoring and evaluation has been released by the World Bank:

Monitoring and Evaluation Report

This is a useful resource for anyone considering monitoring and evaluation approaches, tools and strategies as part of their HIA (or broader work). The booklet covers performance indicators, the logical framework approach, theory surveys, rapid appraisal methods, participatory methods, public expenditure tracking surveys, cost-benefit and cost-effectiveness analysis, and impact evaluation. Each has a section to itself that covers what each is, what each is used for, advantages, disadvantages, costs, skills and time required, and links to other websites and resources. Using the booklet would certainly help people to quickly and concisely scope the most appropriate approach to the monitoring and evaluation stage of their HIA (the least well covered stage in the HIA guidance literature).

7th International HIA Conference Proceedings are Now Online

Information from the 7th International Health Impact Assessment Conference held in Cardiff in April is now available on the Welsh Health Impact Assessment Support Unit website, including conference reports and presentations. (Thanks Salim!)

Health Impact Assessment Wikis

Wikis are website that allow any user to update and edit the information they contain. The biggest and best known wiki is Wikipedia, an ambitious free web-based encyclopedia project with over 1.2 billion articles in English.

Of interest to HIA practtioners are the HIA Wiki, which was started by Salim Vohra, and the HIA page on Wikipedia. You can use these not only as a source information but also as a vehicle for updating others on HIA-related developments.

A number of people have expressed concerns about wikis' unmoderated nature. I think that when using a wiki it's important to view the page history to assess if what you're reading is the result of informed and constructive contributions. The other thing to keep in mind is that even with traditional mediums such as books and journals the editorial and peer-review processes aren't rock-solid guarantees of quality. Critical appraisal has always been important.

Please take a look at both wikis. I'd be interested in your impressions of them.

Should population health studies be called HIAs?

I was reading through a report in today's Courier Mail (Brisbane, Australia) about an industrial estate in Queensland that's causing a bit of controversy. The local community has been concerned about the health impacts of a chemical fire that occurred in one of the estate's factories nine months ago, and the ongoing risks the industrial estate poses for their health.

In the article the Premier is reported as saying that a HIA will be undertaken as part of his plan for the site. The article isn't entirely clear about what the HIA will be done on - the impact of the fire nine months ago or the possible health impacts of relocating the four businesses identified by the government as being unsuitable for the industrial area. I get the impression that it's the former because it's described as "a full health impact assessment and full scientific study conducted with independent consultants".

This made me wonder, should this sort of activity be called HIA?

My gut response is that it shouldn't. It doesn't follow the steps of HIA and it doesn't necessarily involve looking at the determinants of health (instead often focusing on measuring health outcomes). This issue has come up in the past, with people calling a variety of population health-related research activities health impact assessment (see Kemm 2003, PDF 38Kb - particularly the discussion of retrospective and concurrent HIA).

What do you think about these sort of studies being called HIAs?

References
Kemm J. Perspectives on Health Impact Assessment, Bulletin of the World Health Organization 81(6):387. Available from http://www.who.int/entity/bulletin/volumes/81/6/kemm.pdf

New HIA Guidance from Ireland

The Institute for Public Health in Ireland has produced an interesting set of guidance on HIA. I like the way there are a number of case studies included in the appendices, helping to ground the guidance in the real-world experience of HIA.

What's your take on the publication?

Advancing HIA during the Finnish EU Presidency

I came across an interesting interview with Pekka Puska, head of the Finnish National Public Health Unit about the "health in all policies" goal they're working towards during the Finnish EU Presidency.

Tapani Kauppinen and Kirsi Nelimarkka (pictured with their poster on human impact assessment) mentioned at the IAIA Conference that STAKES is also going to be undertaking work to progress HIA at the policy level during the presidency.

It will be interesting to see how things progress.

The 7th International Health Impact Assessment Conference

By Patrick Harris

I grew up in the U.K. during the 1980’s and 90’s, Cardiff, the capital of Wales, had a reputation for being a rough, dead-end place, decimated by high unemployment caused by the closing of coal and other industries. While the rest of Wales was renowned for its natural beauty, Cardiff was to be avoided at all costs, glimpsed from the motorway if seen at all. So when I heard that the 7th International HIA conference was to be held in Cardiff, and that I was going, I was more than a little nervous. As it turned out however, these dark thoughts were entirely misplaced. As soon as we arrived, the taxi driver taking us to the hotel, past gleaming new buildings, told us with pride how Cardiff had put its rough past behind it, reinventing itself as one of the UK’s premier cities to live in and visit.

He wasn’t wrong, and while there I recognised that Cardiff was in fact the perfect place to have the latest HIA conference. The capital city embodies Wales’ regeneration as a healthy place to live, based on the legacy on health left by an industrial past. As the 2nd Minister for Health said at the conference dinner, re-iterated by speakers at the conference, the Welsh government is taking a ‘twin-track’ approach to health. One track refers to clinical services, the other to an agenda to improve health and reduce health inequalities. HIA is recognised as an important tool within this broader agenda.

The conference itself brought up some very interesting areas for those interested in HIA in Australia and NSW to consider. One was evaluating the effectiveness of HIA. The first keynote speaker, Professor Sally Macintyre from the Medical Research Council in Glasgow, threw down the evaluation and effectiveness gauntlet from the word go. While some delegates were concerned over Professor Macintyre’s familiarity with HIA, her presentation did reasonably suggest that for HIA to become better recognised as an effective tool, there needs to be a stronger loop between the assessment step and the monitoring and evaluation step. Interestingly this was reflected in the ‘capacity building’ session I presented in. Out of the four speakers only Professor Andrew Danenberg, reporting on developments in the U.S. via HIA case studies, referred to the impact of those HIAs on proposal development and decision making. Evaluation of HIA effectiveness is an area we can improve on in Australia (and are working on). However this is reflective of where HIA needs to improve internationally.

In recognition of this shortfall, the U.K. department of health has commissioned a cost benefit analysis of HIA. While the final report is yet to be released, Jacqueline O’Reilly of the York Health Economics Consortium, who are undertaking the analysis, presented on its methodology. The project builds on the process-impact-outcome framework, covering rapid and comprehensive HIAs across a broad range of subject areas as they are being conducted. Cost is based on time-sheets and wage rates of those involved and the stages in HIA. Benefits are threefold. Process benefits include community engagement and increased partnership working, the impact benefit (the primary benefit) is the impact benefit on informing and influencing the decision-making process, and the outcome benefit is the impact on public health. While the proof of the pudding will be in the final report, the project is a good example of how HIA can be evaluated. The report hopefully should help HIA move forward from the paralysing debate on the problems of conclusive causation. Let’s follow this example and just get on with it!

Another regular that reared its head during the conference was where HIA sits in relation to other assessment processes, with Environmental Impact Assessment (EIA) the most talked about example. From the ensuing debates it became clear that a number of people see the future of HIA as part of EIA, although I noted many of these people worked for EIA consultancies. Others see HIA as a stand alone process, noticeably health professionals. I myself came away thinking that both are important, HIA as separate on some proposals, and on others within EIA as long as the HIA component is done effectively. The debate also raises other questions: Is this is a golden opportunity for health to work intersectorally? Would this require further legislation that incorporates both a health protection and health promotion focus? Further discussion on this is warranted in NSW, particularly on planning and urban development issues.

What is occurring in Europe provides some useful insights. The recent Strategic Environmental Assessment (SEA) directive related to land-use planning from the European Union requires the consideration of the likely significant effects of a range of topics including population and human health into strategic spatial (which is replacing land-use) planning. In a plenary address on ‘Integration, Planning and HIA’, Ben Cave of Ben Cave Associates argued that SEA provides a golden opportunity for health to re-unite with planning, and for HIA to be a vehicle for this. Mr. Cave argued that HIA assists this intersectoral work while putting health on the planning agenda by encouraging action around shared definitions, concepts and language on health and health impacts. Later in the plenary, Hugh Barton from the University of the West of England added another bow to this debate. He argued that HIA should be part and parcel of an integrated approach to assessment, based on the concept of sustainability, the planning tool for which is a health map. Of interest was that this health map is based in the original determinants of health ‘Rainbow’ by Whitehead and Dahlgren. From a health professional’s perspective, it is encouraging that planning appears to want to engage with health around a broad concept of health, although the required driver may be broad directive such as SEA.

There were also excellent presentations on actual HIAs and the lessons learnt from these. Of relevance to all HIA practitioners was the experience of a local HIA undertaken on a proposal to erect 367 wind turbines on the island of Lewis in the Outer Hebrides. Apart from the findings of the HIA - for example that much of the island’s roads float on marshland, with implications for trucks carrying turbines reaching over120m in height! – was the process of the HIA itself. This apparently took place without any level of capacity building or support for those who conducted the HIA. Problems beset the HIA from the outset. The lesson is that without some level of expertise and support, such HIAs have the potential to be fraught with difficulties.

One other notable presentation was Mary Mahoney’s plenary on Healthy Public Policy in Victoria. Mary talked candidly about the challenges and achievements of her work on HIA in Victoria, and produced the ‘piece de resistance’ of the whole conference, a short film of cowboys ‘herding cats’. The ensuing mirth reflected how well this resonated with the work of many, including us in NSW, in the audience.

To conclude, a comparison of HIA in Australia and NSW to other countries is useful. Pleasingly our work appears to be in sync with HIA as it has been developed and is developing in other countries. However, we are also in a strong position to strengthen HIA internationally based on our current work. For example our work in NSW with planning will provide useful lessons for all. We also may be in a useful position to strengthen the evaluative component of HIA while we are embedding HIA in the system rather retrospectively or as an afterthought.

Oh and one last thought. Anyone planning on going to Wales or the UK on holiday, I recommend you spend a few days in Cardiff!

This piece first appeared in issue 15 of the HIA eNews.

HIA eNews: Issue 15 now online

• Be a Developmental Site!
• 7th International HIA Conference Report
• Health Impact Assessment in San Francisco
• Healthy PLACES Act
• HIA Connect Blog
• New Resources
• Download

Stay Up to Date: IAIA Conference Abstracts

The abstracts for the upcoming IAIA conference are now searchable online:

Abstract Listing
Even if you're not attending the conference the 28 HIA abstracts are well worth a look. Contact details are included as well if you'd like to contact people about their work.

US Healthy Places Act of 2006

More information on the Healthy Places Act of 2006 that we posted on previously is now available. The bill has been referred to the Committee on Health, Education, Labor, and Pensions. You can track its progress on GovTrack. It's probably important that we, as HIA practitioners, don't get our hopes up - most bills never make it out of committee.

You can download a copy of the bill [PDF 87Kb] if you'd like to read it int full, but the HIA related sections are:

SEC. 2. DEFINITIONS. ...
(5) HEALTH IMPACT ASSESSMENT- The term `health impact assessment' means any combination of procedures, methods, tools, and means used under section 4 to analyze the actual or potential effects of a policy, program, or project on the health of a population (including the distribution of those effects within the population).

... (Read More)

SEC. 4. HEALTH IMPACT ASSESSMENTS.

a) Definition of Eligible Entity- In this section, the term `eligible entity' means any unit of State or local government the jurisdiction of which includes individuals or populations the health of which are or will be affected by an activity or a proposed activity.

(b) Establishment- The Secretary, acting through the Director and in collaboration with the Administrator, shall--

(1) establish a program at the National Center of Environmental Health at the Centers for Disease Control and Prevention focused on advancing the field of health impact assessment, including--

(A) collecting and disseminating best practices;
(B) administering capacity building grants, in accordance with subsection (d);
(C) providing technical assistance;
(D) providing training;
(E) conducting evaluations; and
(F) awarding competitive extramural research grants;

(2) in accordance with subsection (f), develop guidance to conduct health impact assessments; and

(3) establish a grant program to allow eligible entities to conduct health impact assessments.

(c) Guidance- The Director, in collaboration with the IWG, shall--

(1) develop guidance for the assessment of the potential health effects of land use, housing, and transportation policy and plans, including--

(A) background on international efforts to bridge urban planning and public health institutions and disciplines, including a review of health impact assessment best practices internationally;
(B) evidence-based causal pathways that link urban planning, transportation, and housing policy and objectives to human health objectives;
(C) data resources and quantitative and qualitative forecasting methods to evaluate both the status of health determinants and health effects; and
(D) best practices for inclusive public involvement in planning decision-making;

(2) not later than 1 year after the date of enactment of this Act, promulgate the guidance; and

(3) present the guidance to the public at the annual conference described in section 3(e)(2).

(d) Grant Program- The Secretary, acting through the Director and in collaboration with the Administrator, shall establish a program under which the Secretary shall provide funding and technical assistance to eligible entities to prepare health impact assessments--

(1) to ensure that appropriate health factors are taken into consideration as early as practicable during any planning, review, or decision-making process; and

(2) to evaluate the effect on the health of individuals and populations, and on social and economic development, of decisions made outside of the health sector that result in modifications of a physical or social environment.

(e) Applications-

(1) IN GENERAL- To receive a grant under this section, an eligible entity shall submit to the Secretary an application in accordance with this subsection, in such time, in such manner, and containing such additional information as the Secretary may require.

(2) INCLUSION-

(A) IN GENERAL- An application under this subsection shall include an assessment by the eligible entity of the probability that an applicable activity or proposed activity will have at least 1 significant, adverse health effect on an individual or population in the jurisdiction of the eligible entity, based on the criteria described in subparagraph (B).
(B) CRITERIA- The criteria referred to in subparagraph (A) include, with respect to the applicable activity or proposed activity--

(i) any substantial adverse effect on--

(I) existing air quality, ground or surface water quality or quantity, or traffic or noise levels;
(II) a significant habitat area;
(III) physical activity;
(IV) injury;
(V) mental health;
(VI) social capital;
(VII) accessibility;
(VIII) the character or quality of an important historical, archeological, architectural, or aesthetic resource (including neighborhood character) of the community of the eligible entity; or
(IX) any other natural resource;

(ii) any increase in--

(I) solid waste production; or
(II) problems relating to erosion, flooding, leaching, or drainage;

(iii) any requirement that a large quantity of vegetation or fauna be removed or destroyed;
(iv) any conflict with the plans or goals of the community of the eligible entity;
(v) any major change in the quantity or type of energy used by the community of the eligible entity;
(vi) any hazard presented to human health;
(vii) any substantial change in the use, or intensity of use, of land in the jurisdiction of the eligible entity, including agricultural, open space, and recreational uses;
(viii) the probability that the activity or proposed activity will result in an increase in tourism in the jurisdiction of the eligible entity;
(ix) any substantial, adverse aggregate impact on environmental health resulting from--

(I) changes caused by the activity or proposed activity to 2 or more elements of the environment; or
(II) 2 or more related actions carried out under the activity or proposed activity; and

(x) any other significant change of concern, as determined by the eligible entity.

(C) FACTORS FOR CONSIDERATION- In making an assessment under subparagraph (A), an eligible entity may take into consideration any reasonable, direct, indirect, or cumulative effect relating to the applicable activity or proposed activity, including the effect of any action that is--

(i) included in the long-range plan relating to the activity or proposed activity;
(ii) likely to be carried out in coordination with the activity or proposed activity;
(iii) dependent on the occurrence of the activity or proposed activity; or
(iv) likely to have a disproportionate impact on disadvantaged populations.

(f) Use of Funds-

(1) IN GENERAL- An eligible entity shall use assistance received under this section to prepare and submit to the Secretary a health impact assessment in accordance with this subsection.

(2) PURPOSES- The purposes of a health impact assessment are--

(A) to facilitate the involvement of State and local health officials in community planning and land use decisions to identify any potential health concern relating to an activity or proposed activity;

(B) to provide for an investigation of any health-related issue addressed in an environmental impact statement or policy appraisal relating to an activity or a proposed activity;

(C) to describe and compare alternatives (including no-action alternatives) to an activity or a proposed activity to provide clarification with respect to the costs and benefits of the activity or proposed activity; and

(D) to contribute to the findings of an environmental impact statement with respect to the terms and conditions of implementing an activity or a proposed activity, as necessary.

(3) REQUIREMENTS- A health impact assessment prepared under this subsection shall--

(A) describe the relevance of the applicable activity or proposed activity (including the policy of the activity) with respect to health issues;

(B) assess each health impact of the applicable activity or proposed activity;

(C) provide recommendations of the eligible entity with respect to--

(i) the mitigation of any adverse impact on health of the applicable activity or proposed activity; or
(ii) the encouragement of any positive impact of the applicable activity or proposed activity;

(D) provide for monitoring of the impacts on health of the applicable activity or proposed activity, as the eligible entity determines to be appropriate; and

(E) include a list of each comment received with respect to the health impact assessment under subsection (g).

(4) METHODOLOGY- In preparing a health impact assessment under this subsection, an eligible entity--

(A) shall follow guidelines developed by the Director, in collaboration with the IWG, that--

(i) are consistent with subsection (c);
(ii) will be established not later than 1 year after the date of enactment of this Act; and
(iii) will be made publicly available at the annual conference described in section 3(e)(2); and

(B) may establish a balance, as the eligible entity determines to be appropriate, between the use of--

(i) rigorous methods requiring special skills or increased use of resources; and
(ii) expedient, cost-effective measures.

(g) Public Participation-

(1) IN GENERAL- Before preparing and submitting to the Secretary a final health impact assessment, an eligible entity shall request and take into consideration public and agency comments, in accordance with this subsection.

(2) REQUIREMENT- Not later than 30 days after the date on which a draft health impact assessment is completed, an eligible entity shall submit the draft health impact assessment to each Federal agency, and each State and local organization, that--

(A) has jurisdiction with respect to the activity or proposed activity to which the health impact assessment applies;

(B) has special knowledge with respect to an environmental or health impact of the activity or proposed activity; or
(C) is authorized to develop or enforce any environmental standard relating to the activity or proposed activity.

(3) COMMENTS REQUESTED-

(A) REQUEST BY ELIGIBLE ENTITY- An eligible entity may request comments with respect to a health impact assessment from--

(i) affected Indian tribes;
(ii) interested or affected individuals or organizations; and
(iii) any other State or local agency, as the eligible entity determines to be appropriate.

(B) REQUEST BY OTHERS- Any interested or affected agency, organization, or individual may--

(i) request an opportunity to comment on a health impact assessment; and
(ii) submit to the appropriate eligible entity comments with respect to the health impact assessment by not later than--

(I) for a Federal, State, or local government agency or organization, the date on which a final health impact assessment is prepared; and
(II) for any other individual or organization, the date described in subclause (I) or another date, as the eligible entity may determine.

(4) RESPONSE TO COMMENTS- A final health impact assessment shall describe the response of the eligible entity to comments received within a 90-day period under this subsection, including--

(A) a description of any means by which the eligible entity, as a result of such a comment--

(i) modified an alternative recommended with respect to the applicable activity or proposed activity;
(ii) developed and evaluated any alternative not previously considered by the eligible entity;
(iii) supplemented, improved, or modified an analysis of the eligible entity; or
(iv) made any factual correction to the health impact assessment; and

(B) for any comment with respect to which the eligible entity took no action, an explanation of the reasons why no action was taken and, if appropriate, a description of the circumstances under which the eligible entity would take such an action.

(h) Health Impact Assessment Database- The Secretary, acting through the Director and in collaboration with the Administrator, shall establish and maintain a health impact assessment database, including--

(1) a catalog of health impact assessments received under this section;
(2) an inventory of tools used by eligible entities to prepare draft and final health impact assessments; and
(3) guidance for eligible entities with respect to the selection of appropriate tools described in paragraph (2).

(i) Authorization of Appropriations- There are authorized to be appropriated to carry out this section such sums as are necessary.