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Backyard Talk

Identifying Disease Clusters – What Comes Next?

It’s hard to say how many disease clusters have been identified. The website of the National Disease Cluster Alliance (NDCA) which held a national conference last week has a map that identifies 73 clusters. Several people attending the meeting pointed out that their cluster was not on the map and there are no doubt many others not on the map. While identifying clusters is an important step, knowing how to respond and what steps to take once a disease cluster (even a suspected disease cluster) has been identified is, perhaps, more important. This and other questions about disease clusters were discussed at a National Disease Cluster Conference held in Washington, DC last week by the NDCA.

It was clear from several presentations that no guidelines exist for what action steps a government agency should take once a disease cluster has been identified. This is a big problem, especially since most health agencies typically close their investigation once a cluster has been identified, concluding that they could not determine the cause of the cluster. This is not the time to walk away from a community that is struggling to determine not just whether a disease cluster exists, but what‘s causing it as well.

There are plenty of examples of communities where a disease cluster was identified. There is the cleft palate cluster in Dickson, TN, increase cancers in Clyde, OH, and childhood cancers in Toms River, NJ, Sierra Vista, AZ and Fallon, NV to name a few (see NDCA map). There are few examples, however, of agencies being able to identify the cause of the cluster. Woburn, MA is the exception as the state health department was able to identify contaminated drinking water wells as the cause of a childhood leukemia cluster.

No doubt determining the cause of a disease cluster is a difficult question to answer. It took the MA state health department over 10 years to conclude that the contaminated drinking water wells were the cause of the cluster in Woburn. But because it’s difficult is not reason enough for public health agencies to walk away. This is unconscionable and irresponsible. Public health agencies need to come up with an action plan for how to follow-up the finding of a cluster. Part of the response needs to include an environmental investigation into what may be causing the cluster. In addition, the community would likely benefit from the distribution of educational materials about the disease in question and the methods used to investigate clusters and their causes. Whatever follow-up occurs, the government needs to include from the very beginning of the process the affected community as part of the planning group directing the investigation.

One example highlighted at the conference was the work of Dr. Paul Sheppard from the University of Arizona who conducted an environmental investigation following the identification a childhood leukemia cluster in Fallon, NV. Between 1997 and 2004, 17 children living in Fallon were identified with leukemia, three of them died. For three years Sheppard studied heavy metals in air, especially tungsten which had been identified as increased in Fallon. Sheppard used tree leaves and tree rings to measure tungsten and found a high concentration of tungsten in the center of Fallon, the home to a tungsten refinery and a tungsten plant since the 1960s.

Although Sheppard was unable to prove that exposure to tungsten caused the increase in leukemia, his work has clearly related the two. His work provides a model for how to follow-up finding a disease cluster. Investigating environmental exposures in a community with a cluster makes perfect sense. Now we need to convince the public health agencies that they need to include this step in as part of their responsibilities. For more about the conference, see www.clusteralliance.org.

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Backyard Talk

Phthalates and Asthma: What's going on with NYC children?

I have asthma.   Just like millions of other Americans.

That’s why I was upset when only a week after we released our new report that found high levels of phthalates in children’s vinyl back-to-school supplies, researchers at Columbia University published a major new study linking phthalates to asthma in NYC children.

“While many factors contribute to childhood asthma, our study shows that exposure to phthalates may play a significant role,” says Allan Just, PhD, first author on the new Center study and current postdoctoral researcher at the Harvard School of Public Health.

Phthalates are chemicals used to soften vinyl plastic, chemicals manufactured by big corporations like Exxon Mobil.

Phthalates in Harlem and Bronx children.

In the study, researchers found phthalates in the bodies of every single one of the 244 school-aged children in the study, ages 5 to 9. Every single one!  Do you believe that?!

All of the children live in Northern Manhattan and the South Bronx, where the rates of asthma are high.

Higher levels of two different phthalates were associated with higher levels of nitric oxide in exhaled breath, which apparently is a biological marker of airway inflammation. They also found phthalate exposure and airway inflammation was especially strong among children who had recently reported wheeze, a common symptom of asthma.

One of the phthalates they investigated, butylbenzyl phthalate (BBzP), is commonly used to soften vinyl flooring in NYC schools and others across the country.

Not the first, and probably not the last.

In recent years, a number of other studies have found a correlation between phthalates emitted from vinyl products and asthma. A few highlights:

  • A study published in 2009 found a statistically significant link between PVC flooring and asthma.
  • A 2008 study found an association between concentrations of phthalates in indoor dust and wheezing among preschool children.  The presence of PVC flooring in the child’s bedroom was the strongest predictor of respiratory ailments.
  • A study of 10,851 children found the presence of floor moisture and PVC significantly increased the risk of asthma.
  • A study of adults working in rooms with plastic wall covering materials were more than twice as likely to develop asthma.

Asthma on the rise.

The new research comes at a time when asthma has been skyrocketing in our communities.

In the last decade, the proportion of people with asthma in the United States grew by nearly 15%. 

Today, one out of every 11 school-age children has asthma. In fact, asthma is a leading cause of school absenteeism: 10.5 million school days are missed each year due to asthma.  About 9 people die from asthma each day.

Additionally, asthma costs the United States $56 billion each year.  That’s right. 56  B-I-L-L-I-O-N.

What can we do?

We know phthalates have been linked to asthma, not to mention many other health problems.  We know there are safer alternatives. We don’t need to use vinyl school supplies, flooring and other products in our schools in the first place.  Why take an unnecessary risk with children’s health?

Chemicals that have been linked to asthma have no place in our children’s schools.

Getting these harmful chemicals out of our schools is a common sense precautionary solution.

Don’t you agree?

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Backyard Talk

The Answer to Climate Change-A Floating City

For years I’ve thought that those who advocate “clean coal” or hydro fracturing, oil drilling off shore or even nuclear power plants thought that once the earth has been totally contaminated, climate change has dried up our lakes and streams and deserts have replaced once lush farmland that they believed there was another planet where they could rebuild the new America. It is the only plan that made sense to me since they, their children and their children’s children have to live somewhere. All the money in the world can’t protect them when the air is no longer breathable or the water drinkable.

But I now know I was wrong. No, they can’t buy their way out of the nasty planet earth they have ruined. Nor is there another planet to move to. However, those with money could make a family reservation on the Seascraper. That’s right a self contained floating city. It was highlighted in National Geographic News.

Here’s the story.

The Seascraper—a self-sufficient community of homes, offices, and recreational space—was designed with the intention of slowing urban sprawl, according to its designers.

The vessel’s energy independence would come from underwater turbines powered by deep-sea currents as well as from a photovoltaic skin that could collect solar energy. The concave hull would collect rainwater and allow daylight to reach lower levels. Fresh water would come from treated and recycled rainwater via an on-board desalination plant.

This green machine would also help keep marine populations afloat, so to speak, with a buoyant base that serves as a reef and discharges fish food in the form of nutrients pumped from the deep sea, the U.S. design team says.

The idea that engineers and designers are even thinking about this floating city as an answer to climate change is ridiculous. Instead of getting our arms around and our policies focused on prevention or protection of our homeland and planet, we are designing and building a bigger mouse trap. Unbelievable.

Furthermore, everyone knows that decisions on what happens in this floating city will be the responsibility of the Captain not through a democratic process.

O.K. so I was wrong. The other planet to move earthlings to is out but the floating city, which looks like a Nike shoe by the way, is the alternative. Now all we need to do is figure out how to make a reservation for the next generation of our families.

Or we need to worker harder and smarter to save our planet and ourselves.

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Backyard Talk

Health Study at Huge Toxic Spill

After forty years, the NYS Department of Health is finally launching a health study of people who lived in an area affected by a huge toxic chemical spill south of Rochester, NY. About 35,000 gallons of trichloroethene, or TCE, was released during a 1970 train derailment in Le Roy, Genesee County, creating a 4 ½-square-mile plume of contaminated groundwater.

People in several dozen homes drank and bathed in private well water containing TCE for two decades until officials finally provided public water. Others inhaled indoor air containing trace amounts of the solvent until recent action to alleviate that problem.

Two state health surveys done years ago found nothing out of the ordinary. But public attention has re-focused on the derailment spill site in recent months, and some residents have asserted that people who lived above the plume did suffer a higher-than-normal rate of cancer. The study will examine the Le Roy-area site and eight other lightly populated locations around the state where TCE have been found. Data for the nine sites will aggregated, so the sample size being analyzed is larger and thus more statistically meaningful.

The other locations are in Cayuga, Cattaraugus, Dutchess, Greene, Rensselaer, Ulster and Washington counties. The study will look at cancer incidence and also at birth weight, birth defects and pre-term births among people living at those sites as far back as the early 1980s. (Source, Rochester Democrat & Chronicle, 9/8/12)

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Backyard Talk

EPA Proposes Short-term Limit on TCE Exposures

The U.S. EPA has made a remarkable decision recently to protect the health of people exposed to trichloroethylene (TCE) in indoor air, primarily as a result of vapor intrusion of TCE vapors from groundwater. The Region 9 EPA has proposed a Remedial Action Level (RAL) for acute (short term) exposure to TCE of 15 micrograms per cubic meter (ug/m3) or 2.8 parts per billion by volume (ppbv). RALs are developed to protect residents exposed to chemicals in indoor air. The regional EPA staff is awaiting approval from EPA headquarters. This exposure limit was proposed to prevent against possible cardiac birth defects when pregnant women are exposed to TCE vapors. TCE is one of the most common chemical contaminants found in the environment. It is used primarily as vapor degreasing solvent to clean metal parts.

This new RAL was proposed as part of the cleanup efforts for the Middlefield-Ellis-Whisman (MEW) Superfund site in Mountain View, CA. The proposed exposure limit is based on EPA’s recently completed health assessment of TCE that set a reference concentration (RfC) for chronic exposure to TCE of 2.0 ug/m3. This reference dose is a level that EPA estimates a person can inhale over the course of their lifetime without causing any adverse health effects.

What’s unique about this proposed exposure limit is that EPA chose to use the reference concentration, which is considered a continuous lifetime exposure, as a daily average exposure. The proposed RAL assumes that a single daily exposure during the first trimester of pregnancy could result in an adverse developmental effect. I believe this is the first time that EPA has proposed a short term exposure limit for any chemical. This is a remarkable event.

The chemical industry of course has cried foul, arguing that using the RfC to create a short term exposure limit is inappropriate and that there is too much uncertainty about short term exposures to TCE. A report prepared by consultants for the chemical industry went on to say that by creating the short term RAL, the agency is considering “an overly strict standard that will cause unnecessary precautions and alarm.” No surprises there.

What it actually does is provide genuine protection for people exposed to TCE (and likely other chemicals) in homes where vapor intrusion occurs from contaminated groundwater. This is a good thing that EPA should be applauded for and encouraged to do more of. Local residents in CA support the EPA’s proposal. The Center for Public Environmental Oversight who has been active at the MEW Superfund site and on vapor intrusion issues has written to EPA asking that headquarters adopt the Region 9 proposal nationwide. EPA has not yet made a decision.

In the meantime, several states including California and New Jersey are following the EPA Region 9‘s lead and have begun using or are considering developing short term exposure limits for TCE. If you are involved in a situation with vapor intrusion of volatile chemicals like TCE, use the short term exposure limit for TCE as a guide to evaluating the risks you face. It’s a lot better than what the chemical industry would have you use.

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Backyard Talk

Ohioans letter to NY Governor

Dear Governor Cuomo:

We, the undersigned Ohioans, are writing to request that you oppose shale gas extraction via ‘fracking’ in all areas of New York, to include the Southern tier. Such development would be irresponsible not only for the reasons outlined below, but also due to the lacking infrastructure for proper disposal of fracking waste products within your state.

Because neighboring New Jersey will not accept out of state fracking waste, Ohio becomes a likely target for the disposal of the fluid by-products of fracking. Ohio relies on class II injection wells for disposal of such fluids. In recent years we’ve experienced increasing numbers and magnitudes of earthquakes as a result of this process. A moratorium was issued by our state due to the severity of the issue. Thus, Ohio’s current injection well space is at or over capacity. Should we be expected to receive New York waste, our citizens will be forced to endure many more injection wells in their communities.

The undersigned Ohioans oppose more injection wells. As recently as this month the city of Cincinnati voted unanimously to ban waste injection wells and the NRDC and others submitted comments detailing the proposed regulations of Ohio injection wells do not meet minimum standards. See: http://ohiogasdrilling.files.wordpress.com/2012/04/nrdc_odnr_uic_comments_081512_final1.pdf

We also endorse the following:

1. Letter from eleven national environmental groups collectively representing millions of members nationwide. See: http://ecowatch.org/wp-content/uploads/2012/08/letter.pdf

2. Coalition letter with more than 22,000 signatories which requests that Governor Cuomo withdraw the Revised Draft SGEIS until 17 documented concerns have been fully resolved. See: http://www.toxicstargeting.com/MarcellusShale/cuomo/coalition_letter/2011

3. Coalition letter with more than 2,700 signatories that opposes any fracking “Demonstration Project” in the Southern Tier and requests strict enforcement of Executive Order No. 41. See: http://www.toxicstargeting.com/MarcellusShale/cuomo/coalition_letter/201…

Respectfully Submitted,

Kari Matsko, Director People’s Oil & Gas Collaborative- Ohio

Teresa Mills, Center for Health, Environment and Justice, Ohio field office

Cheryl Johncox, Executive Director Buckeye Forest Council

Sandy Buchanan, Executive Director Ohio Citizen Action

Heather Cantino,  Athens County Fracking Action Network, Athens OH

Laurie Eliot-Shea/Nathan Johnson, No Frack Ohio Coalition

Greg Pace, Guernsey County Citizens Support on Drilling Issues, Columbus, OH

Bill Baker, Frack Free Ohio, Mansfield, OH

Monica Beasley-Martin, Defenders of the Earth Outreach Mission, Liberty, OH

Susie Beiersdorfer, Frackfree Mahoning Valley Trumbull/Mahoning Counties, OH

Kathie Jones, Concerned Citizens of Medina County Medina, OH

Lori Babbey, Concerned Citizens of Portage County Portage County, OH

Gwen B. Fischer, Concerned Citizens Ohio Portage County, OH

Terry Grange, Marengo OH 43334

Barbara R. Wolf, Cincinnati, OH 45206

Robin Webb Butler, Ohio 44822

Joanne Gerson, Southwest Ohio No Frack Forum

Jack Shaner, Deputy Director Ohio Environmental Council

John Rumpler, Senior Attorney Environment Ohio

Kathryn Hanratty, Water Advocate Frack-Free Geauga Chardon, OH

Fr.. Neil Pezzulo, Glenmary Home Missioners Cincinnati, Ohio

Lea Harper, FreshWater Accountability Project Grand Rapids, OH

Tish O’Dell, Co-Founder MADION, Mothers Against Drilling In Our Neighborhoods BroadviewHeights,OH

Chris Borello, President Concerned Citizens of Lake Twp./Uniontown IEL Superfund SiteUniontown,OH

Diana Ludwig, Frackfree America National Coalition Youngstown, OH

Lynn Anderson/Tim Raridon, Guardians of Mill Creek Park Youngstown, OH

Margaret Fenton, Berryfield Farm Centerburg, OH

Mary Greer, Concerned Citizens Ohio/Shalersville Shalersville, OH

Dr. Deborah Fleming Professor of English and Chair of the Department Ashland University

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Backyard Talk

Love Canal Déjávu – Ground Hog Day?

I couldn’t believe what I was hearing and seeing when I clicked on a link that connected me with a news story about Love Canal by the local ABC TV station in Buffalo. There in front of a camera was a young woman who reminded me of myself 35 years ago. Christen Morris talked about chemicals that have become visible, about trees dying, pets with cancer and growths, and many people who are sick.

I can remember saying those same words, making that same case in 1978 to EPA and the NYS Department of Environmental Conservation. Wow. At the same time as Ms Morris and others were speaking out about problems in the neighborhood, classmates who attended the 93rd Street School were sharing notes. 93rd Street School was located in the northern part of the community, and also demolished due to contamination. Former students, at a class reunion, began exchanging notes about how sick they were finding common concerns and disease. They believe their health related problems might be linked to exposure to Love Canal chemicals during their elementary school years.

Former student Laura Racine said, “I went to the reunion and decided to seek out all the kids that went to the 93rd Street School with and see if they were having health issues as well. And nine out of ten of them were having health issues.”

It is so hard to watch these news stories. It has never made any sense to me or other former residents of the area, why the state and federal government insisted on repopulating the northern part of the evacuation area or why they refused to follow the young children from both 99th and 93rd Street Schools. These are innocent people who were children and whose parents were assured that no long term health problems were likely. The public was assured that Love Canal was cleaned up, when actually the 20,000 tons of chemicals are still there, still in the center of the dump. Only a clay cap and trench system to capture anything that might move out horizontally was put in place. There’s absolutely no science that supports the government’s theory that the chemicals will stay put. All landfills leak and Love Canal is no exception. In fact, the Love Canal dump has no bottom. So, it leaks chemicals out the bottom every time the Niagara River levels drops . . . like in August for example.

The families living around the dump are not to blame. So many people want to – blame the victims. People were assured by every imaginable government agency that everything is fine. The most frequently used phrase to people who inquired was, “Love Canal is the most tested neighborhood in the country.” Of course that doesn’t mean its safe but those words along with assurance of safety people became convinced.

It will be painful to watch the new effort unfold as families with sickness and questions struggle to get those answers. I plan on helping where I can. To see recent news story click here.

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Backyard Talk

Senator Chuck Schumer: Get Toxic Phthalates Out of Children’s School Supplies

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Senator Chuck Schumer speaking at news conference on phthalates in children's school supplies. CHEJ's Mike Schade standing to the left. Photo: Kacey Anisa Stamats

Yesterday was a proud day for me.

You see, I had the privilege and honor to stand shoulder to shoulder with U.S. Senator Chuck Schumer, one of the most powerful Senators in America, to shine the light on hidden toxic chemicals lurking in children’s vinyl back-to-school supplies.

CHEJ and Senator Schumer partnered together to release the new report I authored, Hidden Hazards: Toxic Chemicals Inside Children’s Vinyl Back-to-School Supplies.

Our new report, co-sponsored by the Empire State Consumer Project, found children’s vinyl school supplies are chock full of toxic phthalates, chemicals banned in toys that have been linked to birth defects and asthma, chemicals that have no place in our school supplies. Chemicals manufactured by corporations like Exxon Mobil and Eastman Chemical.

“School supplies are supposed to help our children with their education, they shouldn’t be harming their health.  We don’t allow high levels of these toxic chemicals in children’s toys and we certainly shouldn’t allow them in back-to-school products. When kids take their lunch to school this fall, they shouldn’t be carrying it in a lunchbox laden with toxic chemicals.” — US Senator Charles Schumer (D-NY)

You can read the Senator’s press release he issued here, and watch this great TV story on Channel 7 Eyewitness News.

Our new investigation shows for the first time that popular vinyl school supplies contain levels of toxic phthalates as high as 69 times over the federal ban on toys.  80% of children’s back to school supplies we sampled contained phthalates, and 75% of them contained levels so high, it would be illegal for companies to sell them if they were toys.

Why are these chemicals banned in toys, but allowed in our school supplies?

It’s enough to make any parent furious.

“As a mom, I am horrified to know that Spider-Man and Dora could be associated with highly toxic chemicals,” said Penelope Jagessar Chaffer, Director of the film Toxic Baby. “As a filmmaker who has worked on this issue for years, I know what the effects of these toxic chemicals are on the bodies of children.  As more and more American moms become aware of this issue, it’s clear that we are going to be using our considerable clout as consumers to buy products that are safe for kids.  These products are not.”

These phthalates were found in Spiderman, Dora, and Disney vinyl back-to-school products sold at Kmart, Duane Reade, Payless and other retailers.  All of the products were purchased during the 2012 “back to school” shopping season, and tested by Paradigm Environmental Services in Rochester, NY.

Check out this slideshow of the products we tested:

Coverage of our new Hidden Hazards report is spreading across the country like wildfire.

Check out just some of these stories from:

We coupled the release of this new report with our 2012 Back-to-School Guide to PVC-free School Supplies, to provide tips on how parents can find safer school supplies free of phthalate-laden vinyl.

The awareness we’ve raised so far has been tremendous, but is not enough.

You see, we need YOUR help.

Can you help get the word out about this issue?  Can you share this on Facebook and with parents and teachers you know?  Can you talk about it at your next PTA meeting?

Perhaps more importantly, we need Congress to ACT.  Senator Schumer has co-sponsored the Safe Chemicals Act, which will help protect American families from hidden toxic chemicals in our children’s products.

Can you write to your Senator today, and ask him or her to join Senator Schumer in co-sponsoring the Safe Chemicals Act?

We can’t do it without you!

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Nuclear Reactor Shut Down Because Sea Water Can't Cool?

Why isn’t this front page news! Are people really still questioning Climate Change’s impacts? I’m in shock! The sea water . . . the ocean is too warm to cool the reactors, it’s not even believable. I only believe it because the huge energy corporations would never shut a reactor down unless they had too. Waterford, CT is not alone, a number of reactors across the country have been temporarily shut down in the past few days for safety reasons.

In Waterford, Conn., a reactor at the Millstone Nuclear Power Plant was shut down because the water in Long Island Sound was too warm to cool it. According to the reactor’s safety rules, the cooling water can be no higher than 75 degrees Fahrenheit. The plant has three reactors. The first began operation in 1970 and is now retired. The third was still running yesterday, but engineers have been monitoring the temperature in case that one also needs to be shut down. Temperatures this summer are the warmest we’ve had since operations began here at Millstone,” Dominion spokesman Ken Holt said (Matthew Wald, New York Times, Aug. 13).

At the Calvert Cliffs Nuclear Power Plant in southern Maryland, operators shut down one of the site’s two reactors because a control rod unexpectedly dropped into the reactor core on Sunday.

The plant’s staff is fixing the malfunction, said Kory Raftery, spokesman for operator Constellation Energy Nuclear Group.

Control rods are used to limit the fission taking place among a reactor’s fuel rods. An unplanned insertion of a control rod into a reactor core can “create an imbalance in the fissioning and pose challenges for reactor operators,” Nuclear Regulatory Commission spokesman Neil Sheehan said. It happens infrequently at U.S. nuclear plants, he said (Timothy Wheeler, Baltimore Sun, Aug. 13).

The Palisades Nuclear Generating Station in Covert Township, Mich., was taken offline after officials discovered a “very small, very minor” cooling water leak. The leak, which has been monitored by officials for a month, is being repaired inside a containment building at the plant. No radioactive materials were released, spokesman Mark Savage said Sunday. “Palisades is taking this conservative measure at this time because of our unrelenting commitment and focus on nuclear safety,” he said in a release. “Palisades will be returned to service when repairs are completed.”

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The NEJAC Meeting – Important issues facing Environmental Justice Communities

The National Environmental Justice Advisory Council (NEJAC) had its bi-yearly face-to-face meeting in Arlington, VA this past July. Meeting at the EPA Potomac Yard Conference Center on July 24 & 25, the conference was a public forum where council members as well as other experts and community leaders brought up pressing environmental justice (EJ) issues for review by the council. In addition, workgroups within the council and even the EPA presented reports on their activities involving EJ issues.
NEJAC takes on issues that really matter to environmental justice communities. One of the issues discussed during the meeting was the use of computer softwares for EJ screening. This entails the use of computer programs to aid in the determination of what areas need help. However, it was made clear from the proponents of this technology that it would not present clear-cut distinctions between what was considered an “EJ community “ and what was not. The effectiveness of these softwares to analyze the EJ burden within a community is still questionable at best because EJ factors are examined individually and independently of each other. This means that the cumulative effect of multiple exposures is not acknowledged. For this reason, the picture they create is still not representative of the real EJ burden of a particular community.
Another pressing issue brought up to the NEJAC was the safety of nail salon workers. Many nail salon workers are immigrants who have limited English proficiency and earn small salaries. These workers are exposed to the chemicals in hair and nail products, 89% of which are have not been tested to assess their health effects. In addition to this, several products that claim to be formaldehyde-free or phthalate-free contain significant quantities of these chemicals. The NEJAC was asked to urge the EPA to address this issue in some way in the near future.
A major highlight of the Meeting was a report on EPA’s stance on fracking as an EJ issue. EPA emphasized their stance on exploiting the country’s natural gas reserves responsibly, which is rhetoric and not real action. The presentation explained that fracking wells that do not use diesel fuels as their injection fluids are exempt from regulation under the Safe Drinking Water Act (SDWA), but did little to justify this exclusion . Furthermore, the EPA representative in charge of giving the report seemed not knowledgeable on the subject and ill equipped to deal with questions because she answered most of them vaguely and by referring those who asked the questions to other people within the EPA.
All in all, that the NEJAC meeting handled topics of great importance to the EJ communities around the US is undisputed. Whether the EPA listens to what the council has t say is still up in the air.
Copies of the documents made available at the meeting can be obtained at http://www.epa.gov/environmentaljustice/nejac/