impacting on health. 20 Within the region, a number of states report introducing health assessments into their environmental impact assessment processes. 21 Adequate Standard of Living Article 11(1) of ICESCR recognises ‘the right of everyone to an adequate standard of living’, which includes a right to food, housing and water. 22 Similar recognition is found in other international instruments. CESCR General Comment No. 12 affirms that the right, which is “indivisibly linked to the inherent dignity of the human person and is indispensable for the fulfilment of other human rights”, requires the adoption of appropriate environmental and social policies, at both the national and international levels. 23 Cultural (and Indigenous) Rights ICCPR, Article 27 protects the right of minority groups, including Indigenous groups, to enjoy their own culture, to profess and practise their own religion, and to use their own language. Environmental contamination or environmentally destructive activities may affect a minority groups’ traditional practices, such as hunting, fishing and land ownership and use, which are a manifestation of their culture. The UN Human Rights Committee has stated that the enjoyment of these rights may require positive legal measures of protection and means to ensure the effective participation of minority communities in decisions (including environmental decisions) which affect them. 24 Conversely, there is a tension between traditional subsistence activities that may threaten the environment, and the broader community aims to protect the environment. Recognising this tension, International Labour Organisation (ILO) Convention 169 on Indigenous and Tribal Peoples in Independent Countries provides that the subsistence and traditional activities of indigenous peoples shall be recognised as important factors in maintaining culture, economic self reliance and development. 25 The jurisprudence of the UN Human Rights Committee and Inter-American Commission of Human Rights provide strong support for the proposition that environmental harm may violate Indigenous rights to culture. 26 More recently, The UN Declaration on the Rights of Indigenous Peoples, adopted on 13 September 2007, contains specific protections against environmental harms that would threaten the traditional way of life of Indigenous people. The Right to Privacy Article 27 of ICCPR protects people from ‘arbitrary or unlawful interference with [their] privacy, family, home or correspondence’. Similar protections are found in regional instruments. In Europe, the relevant right in the ECHR has been used extensively to address environmental concerns impacting on privacy occasioned by air and noise pollution and contamination by hazardous substances.27 The Right to Work Article 7 of ICESCR requires States Parties recognise ‘the right of everyone to just and favourable conditions of work’, including ‘safe and healthy working conditions’. Working 20 See for example: Minors Oposa v. Secretary, Department of Environment and Natural Resources (DENR), 30/7/93, 33ILM 173 (1994). 21 See for example Thailand. Asia Pacific Forum, above n4, 172. 22 Committee on Economic, Social and Cultural Rights, General Comment No 15: The Right to Water (arts 11 and 12 of the International Covenant on Economic, Social and Cultural Rights), UN Doc E/C.12/2002/11 (2003). 23 CESCR General Comment No. 12, Para 4. E/C.12/1999/5, 12 May 1999 24 UN Human Rights Committee, General Comment 23. CCPR/C/21/Rev.1/Add.5. Available at: http://www.unhchr.ch/tbs/doc.nsf/0/fb7fb12c2fb8bb21c12563ed004df111?Opendocument 25 Article 23, Convention (No. 169) concerning Indigenous and Tribal Peoples in Independent Countries, International Labour Organisation. Adopted on 27 June 1989. Available at http://www.unhchr.ch/html/menu3/b/62.htm. Issues relating to traditional land ownership have been recognised by the UN in its report on Sustainable Development and Small Island Developing States, and in the Beijing Statement on Combating Desertification and Promoting Sustainable Development. 26 UNHRC General Comment No. 23. The Rights of Minorities. CCPR/c/21/Rev1/Add.5 @ para 7. See also Asia Pacific Forum, above n 4. pp. 42–4, 45–6. 27 Arrondelle v United Kingdom (1982) 26 DR 5; Powell and Rayner v United Kingdom (1990) 172 Eur Court HR (ser A); Baggs v United Kingdom (1987) 52 DR 29; Hatton v United Kingdom (2002) 34 EHRR 1. - 13 -