Washington, D.C. —

On Friday, June 28, 2013, Earthjustice and 28 other local and national environmental health and justice advocacy organizations filed comments to compel the U.S. Environmental Protection Agency to update the science the agency uses to address the cumulative impact of toxic pollution on communities.

Cement plant in Midlothian, TX.
Too many overburdened, vulnerable communities are surrounded by toxic pollution from factories.  (Samantha Bornhorst)

The EPA has established a panel of scientists who are evaluating the current science on ways to assess health impacts and risks to human populations and the environment. The panel is expected to consider what new guidelines are needed for agency decision-makers who are writing regulations and making other critical decisions, such as those about permits, site clean-ups, enforcement actions, and environmental policies.

These groups are calling on the agency to address all of the pollution that local communities are exposed to in daily life, protect children’s health, and provide environmental justice. Too many overburdened and vulnerable communities are surrounded by toxic pollution from factories like coal plants, refineries, cement kilns, chemical plants, and incinerators, plus highways, truck routes, and hazardous waste sites. Often the communities most exposed to hazardous pollution also are communities of color and lower-income communities whom research shows are especially vulnerable to the health effects pollution can cause, such as cancer, asthma, and cardiovascular problems.

In 2009, the National Research Council, National Academy of Sciences published Science and Decisions: Advancing Risk Assessment, but for years since then, the EPA has failed to follow its recommendations.

“All of our communities need strong, scientifically-sound protection from air, water, pesticides, hazardous waste, and other kinds of pollution,” said Earthjustice attorney Emma Cheuse. “Too many communities are getting dumped on from all sides, and it’s both the fair and the right scientific thing for the EPA to do to finally account for the real-world impacts of pollution so that communities can finally get real relief.”

Specifically the groups are calling on the EPA to:

• Account for real-world risks and impacts of pollution that communities face daily.
• Follow the best available science—including National Research Council, National Academy of Sciences (NAS) recommendations, research of independent scientists, and California EPA models—to address the full cumulative impact of pollution from multiple sources, multiple pollutants, and multiple pathways; and use default factors to protect people from all risk and impacts EPA knows exist, instead of just ignoring them.
• Recognize that early-life and in-utero exposure to pollution increases lifelong health risks and impacts and use additional age-based factors to protect children’s health.
• Account for the greater exposure and vulnerability of communities of color and lower income communities to provide meaningful public health protections and environmental justice.

“The science is clear.  The EPA is currently relying on outdated assessment methods that jeopardize communities and result in disparities,” said Miriam Rotkin-Ellman, Senior Scientist for the Natural Resources Defense Council. “Many pollution limits do not protect public health because they fail to account for the reality that people are exposed to more than one contaminant from more than one polluting facility at a time. The EPA must update existing guidelines and utilize new tools to account for these multiple exposures and the increased health threats to vulnerable populations.”

“Communities around the country should not have to keep waiting for the EPA to follow current science on the combined harm that all different kinds of pollution cause to our children. We need protection now, and that’s why it is so important that the EPA is looking at this issue,” said Jane Williams, Executive Director, California Communities Against Toxics. “The EPA must follow the current science in setting toxic air pollution limits and addressing all kinds of pollution and take action to issue strong new guidelines without delay.”

Organizations Joining Comments Filed By Earthjustice:

Air Alliance Houston, Alaska Community Action on Toxics, American Bottom Conservancy, California Communities Against Toxics, California Safe Schools, The City Project, Community In-Power and Development Association, Deep South Center for Environmental Justice, Del Amo Action Committee, Downwinders At Risk, Ironbound Community Corporation, Louisiana Bucket Brigade, Louisiana Environmental Action Network, Los Jardines Institute, Lower Mississippi Riverkeeper, Missouri Coalition for the Environment, Natural Resources Defense Council, Neighbors for Clean Air, New Mexico Environmental Law Center, North Carolina Environmental Justice Network, Oak Grove Neighborhood Association, Poverty & Race Research Action Council, Public Interest Law Center of Philadelphia, Royal Oak Concerned Citizens Association, Rural Empowerment Association for Community Help, Sierra Club, Southern Environmental Law Center, and West End Revitalization Association.

Additional Information:

• Comments Filed by Groups
• Federal Register notice, from Office of the Science Advisor, EPA
• More information on EPA’s Risk Assessment Forum CRA Technical Panel