Summary

Sometimes the environment becomes dark and murky. During such times friends also fall sick.

— A migrant worker in Dubai, September 2023

Even as the United Arab Emirates (UAE) government works to burnish its image as a global climate leader as host of COP28, the United Nations climate conference underway in Dubai, the country’s vast fossil fuel production and use spew toxic pollutants into the air and contribute to climate change.

The UAE has dangerously high air pollution levels, creating major health risks for its citizens and residents. According to the latest World Bank data, the mean annual exposure to PM2.5 in the UAE is more than eight times higher than what the World Health Organization (WHO) considers safe for human health. Based on WHO estimates, approximately 1,872 people die every year from outdoor air pollution in the UAE.

The UAE government says that the country has poor air quality but mainly ascribes this to natural dust from sandstorms. However, academic studies have shown that natural causes are not the single, or in some cases even the major, factor in air pollution. A 2022 academic study found that, in addition to the dust, emissions including from fossil fuels contribute significantly to the problem in the UAE. Air pollution and climate change are directly linked, as the extraction and use of fossil fuels are the sources of air pollution and greenhouse gas emissions

This report is based on Human Rights Watch review and analysis of government air pollution data and satellite imagery from 2018 to 2023, government reports, as well as interviews with 12 migrant workers, including low-wage workers engaged in outdoor work. Migrant workers form over 88 percent of the UAE population. Human Rights Watch also spoke with exiled Emiratis, academic experts, and international and domestic environmental groups and reviewed relevant government policies and media reports.

Current air pollution levels remain alarmingly high. Human Rights Watch analysis of PM2.5 levels provided by 30 government ground monitoring stations in September 2023 found that they were on average almost three times the daily recommended levels of the 2021 WHO air quality guidelines. Human Rights Watch analysis of the air quality monitoring data provided by the United States Embassy in Abu Dhabi and the US consulate in Dubai since 2021 also shows that the PM2.5 concentrations have been consistently above WHO recommended levels. Human Rights Watch also analyzed the annual PM10 concentrations from 2018 to 2022 published by the UAE Federal Competitiveness and Statistics Centre for 50 ground monitoring stations throughout the country, finding that the average of all the stations in 2022 was more than eight times the yearly WHO recommendation.

Migrant workers Human Rights Watch interviewed described breathing air that burned their lungs, feeling out of breath at work, having their skin itch, and other health problems that they believe could be related to breathing toxic air. Yet, migrant workers told Human Rights Watch that they had no information about the risks of air pollution, its sources, who is most impacted, and how they can protect themselves.

The UAE is one of the world’s largest oil producers and home to seven so-called “carbon bombs,” the world’s largest fossil fuel production projects. Nonetheless, the UAE is expanding its fossil fuel operations—including oil, gas, coal, and petrochemical—despite a consensus that there cannot be new fossil fuel development if governments are to meet global climate targets. 

The UAE government has submitted a revised nationally determined contribution (its “NDC”, a domestic climate action plan required by the Paris Agreement on Climate Change) to the United Nations Framework Convention on Climate Change (UNFCCC) in 2023. This plan, while making some ambitious commitments, also indicates the government’s intention to increase fossil fuel production—a goal that is inconsistent with limiting global warming to 1.5 degrees Celsius to avoid the worst impacts of the climate crisis globally.

The planned expansion of fossil fuel operations also undermines the UAE government’s objectives to reduce high air pollution levels. While the government recognizes the problem of air pollution, its current air-quality standards are much weaker than what the WHO recommends. The government is failing to adequately monitor and address high pollution levels and protect populations most at risk of its harmful health effects, including people with chronic health conditions, migrant workers—especially those working outdoors, older people, people with disabilities, children, pregnant people, and others facing economic and social marginalization.

The UAE government has ensured a complete closure of civic space which has led to a lack of independent information on environmental issues impacting the UAE, including air pollution. One climate activist Human Rights Watch interviewed said: “Nobody will ever hold the government to account publicly. We do not have the privilege of speaking out against the government.”

Those in the UAE wanting to report on, or speak out about, the risks of fossil fuel expansion and its links to air pollution face risks of unlawful surveillance, arrest, detention, and ill-treatment. Over the last decade, authorities in the UAE have embarked on a sustained assault on human rights and freedoms, including targeting human rights activists, enacting repressive laws, and using the criminal justice system as a tool to eliminate the human rights movement. These policies have led to the complete closure of civic space, severe restrictions on freedom of expression, both online and offline, and the criminalization of peaceful dissent.

The UAE government has obligations under international human rights law to address air pollution and confront the climate crisis as part of its obligations to realize the rights to life, health, and a healthy environment. It should take concrete steps to reduce pollution and protect people from its impacts.

This includes better monitoring of air quality and making air quality information easy to access and understand by everyone, applying more rigorous air quality standards in line with WHO recommendations, and assessing, clearly communicating, and mitigating risks to human health, including for at-risk groups. The government should also tackle the root causes of air pollution by drastically reducing the release of pollutants that are harmful to human health, including by developing plans for a full phase out of fossil fuels.

The UAE government should also ease its grip on civic space and uphold the rights to free expression, association, and protest, enabling meaningful participation of civil society pushing for a strong outcome of COP28. In its COP28 presidency role, it should work with all UNFCCC parties to pledge a full, fast, and fair phase out of all fossil fuels as part of the COP28 outcome.

Recommendations

To the Government of the United Arab Emirates

• Implement a moratorium on new or expanded fossil fuel operations.
• Develop a plan for phasing out existing fossil fuel operations, while supporting a just transition of workers, communities, and industry toward a renewable economy.
• In its COP28 presidency role, work toward a commitment to a full, fast, and fair phase out of all fossil fuels as part of the COP28 outcome document.
• Uphold the rights to free expression, association, and protest before, during, and after COP28.

To the Ministry of Climate Change and Environment

• Develop and implement more stringent regulations to limit air pollution in the UAE, including introducing legally binding limits for PM2.5 levels, in line with the WHO’s recommended guidelines.
• Monitor impacts of air pollution, including by collecting disaggregated data, across residential areas, in fenceline communities, and on at-risk groups including people with chronic health conditions, migrant workers especially those working outdoors, older people, people with disabilities, children, and pregnant people, and put in place effective measures to protect them. Ensure groups at risk are consulted and included in the development of protection measures. Ensure that everyone living and working in the UAE has access to information about air pollution and how to protect themselves, including through the development of improved air pollution warnings systems available in different languages and in formats accessible to at-risk populations.
• Make localized, real-time, and historic air pollution measurements of PM2.5 concentrations publicly available.

To the Ministry of Health and Prevention

• Educate healthcare providers to treat patients and sensitize them about the health risks associated with exposure to air pollution, treatment approaches, and prevention strategies.
• Take steps to ensure the availability, accessibility, affordability, acceptability, and quality of healthcare goods and services for all UAE residents. In particular, ensure that those without citizenship status can utilize healthcare services free from access barriers based on discrimination, affordability, lack of information, and physical proximity.
• Implement occupational health and safety programs for outdoor workers and ensure access to prevention including work stoppage linked to high air pollution.

To the World Health Organization

• Provide technical assistance to the UAE government to develop more stringent and legally binding domestic standards on air pollution, including limits for PM2.5 levels, in line with the WHO guidelines.

 

Methodology

Between June and October 2023, Human Rights Watch conducted telephone interviews with 12 migrant workers between ages 23 and 42 from Nepal and India about their experiences with air pollution in the UAE. International organizations like Human Rights Watch have no access to the UAE to undertake independent research. Two of the workers are female, ten are male. All interviewees provided verbal or written informed consent to participate and no compensation was provided for any interviews. Human Rights Watch also interviewed one exiled Emirati, one Emirati climate activist, four academics including medical researchers and environmental scientists, and four climate groups outside of the country.

Human Rights Watch reached out to environmental groups and academic researchers based in the UAE, but none agreed to be interviewed. The UAE government has a zero-tolerance policy for dissent and individuals who speak out against government policies are routinely arrested, targeted, banned from travel and subject to other forms of harassment.

Human Rights Watch also reviewed official government documents on air quality, analyzed air pollution levels collected from UAE government websites and from satellite remote sensing data.

Data source	Type of data	Location	Time period	Known limitations
National Air Quality Platform	Daily averages of PM2.5 and NO₂ concentrations, expressed in µg/m³ based upon hourly data.	33 sensor stations (see map below)	September 2023	Lack of values for the stations in Dubai and Fujairah Emirates. Data analyzed only for September 2023, no access to historical data
Copernicus’ Sentinel-5 dataset	Tropospheric NO₂ concentrations	Global	September 2023	Limited ability to assess air quality at ground level
Federal Competitiveness and Statistics Centre	Yearly PM10 concentrations	50 ground monitoring stations	2018-2022	No data for PM2.5 values
AirNow platform data for the US Embassy and Consulate	PM2.5 concentrations	Two ground monitoring stations in Dubai and Abu Dhabi	January 2021 to October 2023	Only two stations, no global coverage

Human Rights Watch exported hourly air quality data of 33 sensor stations available on the National Air Quality Platform throughout September 2023. A limitation of this dataset is the lack of values for the stations in Dubai and Fujairah Emirates, some of which are available through other platforms but were not included in this analysis for technical reasons. The air quality data includes hourly data on PM2.5 and NO₂ concentrations, expressed in µg/m³. Daily averages have been compiled following the platform’s methodology.

Human Rights Watch also reviewed satellite remote sensing data of tropospheric NO₂ concentrations from Copernicus’ Sentinel-5 dataset for September 2023. Though tropospheric values cannot be used to assess the air quality at the ground level, they provide insights at a global scale and useful information on areas not covered by ground sensor stations.

Human Rights Watch reviewed air quality monitoring data provided by the AirNow Platform which contains historical data on PM2.5 concentration collected by sensor stations located respectively in the US Embassy in Abu Dhabi and the US Consulate in Dubai.

Human Rights Watch analyzed PM10 concentrations between 2018 and 2022 published by the UAE Federal Competitiveness and Statistics Centre for 50 ground monitoring stations throughout the country.

In early November 2023, Human Rights Watch wrote letters to the Ministry of Climate Change and Environment, the Ministry of Health and Prevention, and local environment agencies, informing them about our preliminary findings and asking them to respond to questions in relation to their air pollution policies and practices. At time of writing, Human Rights Watch had not received any responses.

 

Background

Health Risks of Air Pollution in the UAE

The World Health Organization (WHO) has identified air pollution as the “single biggest environmental threat to human health” globally, with estimates of 6.7 million people dying from it prematurely every year. Based on concentrations of harmful PM2.5, a measurement of fine particulate matter in the air, the UAE was the 11th most polluted country in the world, according to IQair, a website that compares air quality measurements across countries.[1]

Among the major pollutants of concern globally are particulate matter (PM) and nitrous oxides (NOx)—both strongly linked to the burning of fossil fuels. The negative impact of PM2.5 on human health is well-documented. These particles, which are less than 2.5 microns in diameter or about 30 times narrower than a single human hair, can penetrate deep into the lungs and easily enter into the bloodstream, increasing the risk of respiratory and cardiovascular illness. Research has also shown the impact of NO2 on the human respiratory, cardiovascular, and nervous systems, causing type 2 diabetes and even death.[2]

The WHO’s air quality guidelines (AQG), last updated in 2021, guide governments globally to work toward improving health by reducing air pollution. However, the UAE government has yet to integrate these standards into domestic legislation.

Comparison of WHO Air Quality Guidelines with UAE Standards for PM2.5, PM10 and NO2

Pollutants	Averaging Time	WHO Air Quality Guidelines	UAE Standards
PM2.5, µg/m³	Annual	5	No regulated limit
	24ha	15	No regulated limit
PM10, µg/m³	Annual	15	No regulated limit
	24ha	45	150
NO2, µg/m³	Annual	10	No regulated limit
	24h	25	150
	1 hour	200	400

μg = microgram 
^a 99th percentile (i.e., 3–4 exceedance days per year). 

According to 2019 World Bank data, the mean annual exposure to PM2.5 in the UAE exceeds 40µg/m³, more than 8 times the annual WHO-recommended level of 5 µg/m³. According to the State of Global Air 2020 research, the UAE’s levels of PM2.5 exceeded the WHO annual recommended levels 98 percent of the time. Government reports also indicate that air pollution levels usually exceed WHO guidelines.[3]

Air pollution is a serious threat to public health in the UAE. Based on WHO estimates of the death rate attributable to outdoor air pollution, 1,872 people died from air pollution in 2019. Studies have also linked air pollution to the prevalence of specific diseases in the region. A 2015 review of scientific research conducted in the early 2000s identified air pollution, and particularly PM2.5, as a major risk factor for cardiovascular disease in Gulf countries, including the UAE.[4] A 2023 review of research documenting the relationship between particulate matter exposure and cardiovascular diseases found that the health harms of air pollution, including pollution-related mortality, continue to worsen in the region, with the UAE being one of the countries most impacted.[5]

People with certain health conditions such as asthma, pregnant women and other people, children, older people, people with disabilities, migrant workers especially those working outdoors, people living in poverty and other socially and economically marginalized populations are more likely to be exposed to or adversely impacted by harmful air pollution. One study investigated the impact of air pollution on young people between the ages of 13 and 20 in the UAE, linking their proximity to industrial areas as a predictor of asthma. Asthma impacts at least 13 percent of children aged 6-13 in the UAE.

Fossil Fuels Feeding Toxic Air

Air pollution comes from a number of sources, including burning fossil fuels for transportation, heating fuel, waste burning, electricity generation, and other industrial activities. The 2019 UAE Air Emissions Inventory Project, a report commissioned by the UAE government that attributed anthropogenic sources of pollution emissions to specific sectors of the economy, indicated that industry is responsible for just over two-thirds of anthropogenic PM2.5 emissions and attributed 79 percent of anthropogenic sulfur dioxide emissions specifically to oil and gas production.

There is a commonly cited position, supported by government and media reporting in the UAE, that air quality in the Gulf is primarily affected by the vast amounts of natural dust. According to the government, high levels of air pollution, including PM10, are mainly due to “natural sources due to the geographic location and weather patterns of the UAE,” making it “difficult evaluate the improvement from other mitigation measures implemented.” In a government-funded podcast about air pollution, an official of the Environment Agency of Abu Dhabi emphasized the natural sources of pollution including dust that “we can do nothing about,” and blamed individual consumption patterns such as the use of electricity for toxic air.[6]

Similarly, media reporting on air pollution over the past two years focused on dust storms as being the primary reason for high pollution levels in the UAE. The closure of civic space makes it difficult, if not impossible, for media and environmental groups working in the country to publicly address the contribution of fossil fuel operations to air pollution.

However, a 2022 peer-reviewed study, done by researchers from the Max Planck Institute for Chemistry in Germany and using ship-borne measurements and modeling, has shown that, in addition to the dust, anthropogenic emissions are contributing significantly to the problem.[7] The study revealed based on ship measurements and modeling that more than 90 percent of the—very small—particulate matter that is most detrimental to health originates from anthropogenic sources in the region. The study estimates that more than 3,000 people die due to PM2.5 exposure alone in UAE every year, with 27 percent of PM2.5 concentrations in the UAE being the result of anthropogenic sources including fossil fuel operations.

A medical researcher who studies air pollution risks in the Gulf region told Human Rights Watch that “policymakers love to say that [air pollution] is linked to dust.”

The UAE is one of the world’s largest oil producers and home to seven so-called “carbon bombs,” some of the world’s largest fossil fuel production projects, with reserves so large that were they to be completely extracted and burnt they could emit more than one gigaton of CO2 each. The UAE is expanding its fossil fuel operations including oil, gas, coal, and petrochemical, with plans for new oil and gas production by 2050 that exceed all but six nations worldwide—despite a consensus that there cannot be new oil, gas, or coal development if governments are to meet global climate targets and protect human rights. 

While the UAE submitted a revised nationally determined contribution with a stronger emissions reduction target to the UNFCCC in 2023, Climate Action Tracker, an organization providing independent scientific analysis of domestic climate policies, found that there has been “little action in the real economy” and gave the country a rating of “insufficient,” particularly as the UAE still plans to increase fossil fuel production. These policies to further grow fossil fuel extraction are inconsistent with limiting warming to 1.5 degrees Celsius.

Findings

Stifled Dissent and Lack of Information

Media in the UAE is tightly controlled by the government, limiting the dissemination of information [about air pollution].

– A 39-year-old worker who lives in Abu Dhabi, September 2023

Over the last decade, authorities in the UAE have embarked on a sustained assault on human rights and freedoms, including targeting human rights activists, enacting repressive laws, and using the criminal justice system as a tool to eliminate the human rights movement. Trade unions are banned, which inhibits migrant workers’ ability to demand better occupational safety policies. These policies have led to the complete closure of civic space, severe restrictions on freedom of expression, both online and offline, and the criminalization of peaceful dissent.

International groups, including Human Rights Watch, have no access to the country to undertake independent research. In researching this report, Human Rights Watch contacted several environmental groups and individuals, some based inside the UAE and others working on the UAE but based elsewhere in the region, to ask about their views on government policies related to air pollution and fossil fuels.

Environmental groups and most academics contacted either did not respond or otherwise indicated that they were not in a position to substantively discuss these topics with Human Rights Watch. While some individual climate activists and academics agreed to speak with or exchange information over email with Human Rights Watch, all did so on condition of anonymity.

Rampant surveillance and the risk of arrest, detention, and prosecution for expressing what the government may deem to be criticism of the UAE, its leaders, and its policies has led academics to tell Human Rights Watch during prior research that they restrict what they think they can say about the UAE. Academics have told Human Rights Watch that their organizations may exercise self-censorship for fear of denial of entry or deportation.

One climate activist said that nongovernmental organizations (NGOs) and activists were not able to speak freely in the UAE, adding: “We do not have the privilege of speaking out against the government, but we still find ways to advocate internally, in line with the existing rules.”

This experience suggests that it is extremely difficult, if not impossible, in the UAE to freely scrutinize and openly speak about the weakness of its air pollution policies.

When contacted by Human Rights Watch in October 2023, regional WHO officials shared via email that “Gulf countries are very sensitive to sharing data and information on health impacts of air pollution in their countries” because of “high levels of natural air pollutants” such as dust. 

WHO officials indicated in a second email in November 2023 that countries in the region had “insufficient source apportionment studies/reports and national inventories” alongside “[w]eak political commitments and resistance of stakeholders to identify emission sources.”

“Everything in the UAE is linked to fossil fuels and the rulers of the country own the fossil fuel operations,” one climate activist said. “This makes it difficult to discuss the contribution of fossil fuels to air pollution.”

The availability and consistency of data on air pollution varies widely across the country and the Emirates. While data from air monitoring stations across the country for certain pollutants is shared, important pollutants such as PM2.5 are sometimes missing from the data set. The available data is also scattered on different platforms and applications that display inconsistent total numbers of sensors stations.

In addition to the data gaps, there is a dearth of public information about the impacts of air pollution, its sources, and how at-risk populations can protect themselves. The UAE government acknowledged that “[t]here is currently no system to warn the public about inevitable high-level pollution episodes (for example, dust storms) and to provide guidance on how to reduce personal exposure to pollution,” yet it has done little to address these gaps.[8]

While existing air quality websites provide measurements from air quality ground level monitoring stations, some do not measure all relevant pollutants and the standards displayed are less stringent than WHO recommendations. The websites do not provide practical advice on protection measures and lack detailed information for at-risk groups. They only exist in Arabic and English and are not accessible to migrant workers who may not speak either of these languages. The information is not available in accessible formats, such as sign language or easy-to-read.

Migrant workers told Human Rights Watch that they do not know what is causing air pollution and are left in the dark on when and how to protect themselves. A chef who has been working in Dubai for three years said he is worried about the health risks of living in the UAE. “Sometimes, the environment becomes dark and murky. We discuss among friends why it is that way… The conversation ends there. During such times friends also fall sick.”

Migrant workers Human Rights Watch interviewed were not aware of the government websites or other sources to access current air pollution levels. Several reported not receiving advance warnings for bad air quality, with the exception of extreme sandstorms. One worker said: “We often have to deal with dusty air without prior warning. Sometimes we find out about the thick dust in the wind only after swallowing it.”

Another worker added: “They don’t say anything about the levels of air pollution. Such news don’t come… I am more alert about pollution in [my home country]—I hear news about the levels of air pollutions in [my home country] even from here. But I don’t know about UAE pollution.”

Some workers suspected that the lack of information was a result of the repression of free speech in the UAE. One worker said: “Every media here is under the control of the state. There is no freedom of the press. It is the government agency that decides what information to give and what not to give.” Another worker told Human Rights Watch: “Employers, doctors, and local authorities have never told me that there is air pollution in the UAE. Most of the people come here from outside. Maybe that is why they don’t want to spread the news on air pollution as it will affect it. Who wants to see their business collapse?... Here there is a lot of secrecy.”

Most of the migrant workers Human Rights Watch interviewed were told that the main source of air pollution was dust and reported only receiving warnings about extreme sandstorms on their mobile phones, typically in English and Arabic.

An exiled Emirati told Human Rights Watch that Emirati medical staff and researchers are unlikely to talk about the sources of air pollution because environmental information is censored. “[Health workers and researchers] don’t speak to the media; it could be a trap.” A medical researcher who studies air pollution risks in the Gulf region told Human Rights Watch that in their experience medical doctors were not well-educated on the risks of air pollution. Human Rights Watch reached out to several medical staff and environmental researchers based in the country via email but has not received a response.

Toxic Air and Its Health Impacts

“[The] UAE is a factory that produces patients. The workers return with disease. There are very few people who leave here with a healthy body.”

– A migrant worker who has lived in the UAE since 2007, September 2023

Research on air pollution in the UAE has repeatedly shown high pollution levels, creating major health risks for its citizens, residents, and migrant workers.[9] Human Rights Watch analysis of air quality data on PM2.5, PM10, and NO2 confirms that pollution levels remain high in recent years and months.

Analysis of 33 sensor stations available on the National Air Quality Platform throughout September 2023 found that the average daily PM2.5 concentration of all the stations was 42.7 µg/m³, almost 3 times the daily WHO recommended levels. During the month of September 2023, only three out of 30 stations recorded an average daily concentration of PM2.5 compliant with the WHO recommendations, and only for one or a few days each in the whole month. 

The UAE government does not provide historical data of PM2.5, but Human Rights Watch analysis of the air quality monitoring data provided by the AirNow Platform for the US Embassy in Abu Dhabi and US Consulate in Dubai shows that PM2.5 concentrations have been consistently above WHO recommendations since at least 2021.

Human Rights Watch analysis of air quality data of the 33 sensor stations throughout September 2023 found that the average daily PM10 concentration of all the stations was 125µg/m³, almost 3 times the daily WHO recommendation. During the month of September 2023, seven out of 30 stations recorded an average daily concentration of PM10 compliant with the WHO recommendation, but only for one or a few days each in the whole month. 

Human Rights Watch analysis of annual PM10 concentrations from 2018 to 2022 published by the Federal Competitiveness and Statistics Centre for 50 ground monitoring stations throughout the country found that the average of all the stations in 2022 was 126 µg/m³, more than 8 times the yearly WHO recommendation. Between 2018 and 2022, none of the 50 stations recorded a yearly average compliant with WHO guidelines.

With regards to NO2 concentration levels, Human Rights Watch analysis of ground level data found that exactly half of the monitoring stations assessed (15 out of 30) were consistently exceeding the WHO recommendation in September 2023.

Human Rights Watch also analyzed tropospheric data retrieved from satellite imagery for September 2023. While the values measured at the tropospheric level, meaning in the lowest kilometers of the atmosphere, cannot replace ground level measurements, the findings largely correspond with ground level data, with some of the most extreme pollution levels documented around Dubai and Sharjah.

Migrant workers described to Human Rights Watch a myriad of health problems that they believe could be related to the toxic air they are breathing: respiratory ailments, skin problems, eye problems, dizziness, cardiovascular diseases, and allergies. Migrant workers form over 88 percent of the UAE's population, including low-wage workers from countries in South Asia, Africa, and elsewhere in the Middle East.  

When asked about health issues potentially related to air pollution, a 39-year-old migrant worker who came to the UAE in 2007 told Human Rights Watch about his respiratory problems for which he cannot afford to get proper treatment in the UAE. “If my cough doesn’t get better, I have no option but to return... This is the reality for many people.” He previously worked and lived near oil fields in the Ruwais area where he started experiencing respiratory problems. “I felt out of breath even when I walked…so I wondered if there is something wrong with my health.” Colleagues and friends told him it could be the result of toxic emissions, but he has never been able to confirm it.

Some workers also reported worsening of existing health conditions that they believe is linked to air pollution in the UAE. For example, a 34-year-old worker who is currently employed as a technician in the oil and gas sector near Abu Dhabi and who has had asthma for several years told Human Rights Watch: “After returning from rig work, my asthma symptoms worsen for at least a week.”

 

Government Legal Obligations and Response

Under international human rights law, countries have a responsibility to tackle air pollution and its impacts on a range of human rights, including the rights to life, a healthy environment, and health. The Arab Charter on Human Rights of 2004, which has been ratified by the UAE, includes the right to a healthy environment as part of the right to an adequate standard of living that ensures well-being and a decent life (art. 38).[10]

The United Nations Committee on the Rights of the Child—which interprets and monitors compliance with the Convention on the Rights of the Child (CRC) that the UAE ratified— has stated that States should immediately take action to “equitably phase out the use of coal, oil, and natural gas” as well as to “improve air quality…to prevent child mortality.”[11]

Governments are required to take steps to limit air pollution by addressing its causes, as well as monitor its impacts and protect people during the worst air pollution events. This includes adequately assessing and reducing sources of air pollution, monitoring air quality, enforcing rigorous air quality standards, and assessing, communicating, and mitigating risks to human health, including for at-risk groups. 

Information is a prerequisite for the exercise of various other rights, including the rights to health and the right to a healthy environment. Under the CRC and the Convention on the Rights of Persons with Disabilities, to which the UAE is a signatory, the right to information obliges states to provide information necessary for the protection and promotion of rights, including the right to health, and to ensure access is easy, prompt, effective, and practical.

While the UAE recognizes the problem of air pollution and has introduced some policies and plans to address it, the government is largely failing to adequately monitor and address high pollution levels and protect populations most at risk. The UAE continues to expand fossil fuel operations, undermining its own objectives to reduce pollution and risking retrogression of the realization of the right to health.

The government has acknowledged the health impacts of air pollution and expects the implementation of the National Air Quality Agenda 2031, approved by the cabinet in 2022, to reduce health harms associated with air pollution. However, regulation of air quality remains grossly insufficient, both in terms of the quality of the standards and their coverage.[12] While the federal outdoor air quality regulation sets out limits for six major air quality pollutants in the country, they are not nearly as stringent as corresponding WHO guidelines, threatening the health of at-risk populations.[13] In particular, the Emirati PM10 limits over a 24-hour period exceed WHO recommendations by more than three times; NO2 limits exceed them by more than six times. Importantly, the federal regulation fails to set standards for PM2.5, one of the most harmful pollutants.[14]

The UAE has a human rights obligation to address air pollution and confront the climate crisis as part of its obligation to realize the rights to life, health, and a healthy environment. It should take concrete steps to monitor the impacts of air pollution and protect people during the worst air pollution events. This includes adequately assessing and better monitoring air quality, making air quality information easy to access and to understand by everyone, enforcing more rigorous air quality standards in line with WHO recommendations, and assessing, communicating, and mitigating risks to human health, including for at-risk groups, when pollutant levels are high. It should also tackle the root causes of air pollution, including by implementing the full phase out of fossil fuels. 

 

Acknowledgments

This report was researched and written by Katharina Rall, senior researcher in the Environment and Human Rights division at Human Rights Watch. Satellite imagery and air pollution data analysis was conducted by Léo Martine, senior geospatial analyst, Digital Investigations Lab. Two consultants interviewed migrant workers in the UAE.

The report was edited by Richard Pearshouse, director of the Environment and Human Rights division; it was reviewed by Joey Shea, UAE researcher in the Middle East and North Africa division; Matt McConnell, researcher in the Economic Justice and Rights division; Sam Dubberley, managing director and Brian Root, senior quantitative analyst, Digital Investigations Lab; Antonia Juhasz and Felix Horne, senior researchers in the Environment and Human Rights division; Juliane Kippenberg, associate director in the Children’s Rights Division; Skye Wheeler, senior researcher in the Women’s Rights Division, Emina Ćerimović, senior researcher in the Disability Rights Division; Bridget Sleap, senior researcher on the rights of older people, and Joe Amon, director of global health and clinical professor of Community Health and Prevention at the Dornsife School of Public Health, Drexel University. Clive Baldwin, senior legal adviser, and Babatunde Olugboji, deputy Program director, provided legal and program review.