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Backyard Talk

It’s Time to Move Beyond Risk Assessment

Risk assessment is the standard method for evaluating exposure to toxic chemicals, despite the fact that it’s nearly impossible to do a risk assessment that is objective and accurate. There are just too many hard-to-measure factors affecting the chance that any one chemical will harm us and if so, how and to what extent, and too many ways for personal bias to change the results. For example, there’s been a long argument about whether arsenic causes cancer. We do know that it’s poisonous. It probably does cause cancer, but many people seem to be immune. So we’re not sure how many cases might occur, and what amount of arsenic might cause cancer. Also, it doesn’t seem to cause cancer in animals, so there’s no way to put the information together. When there are information gaps, the only thing we can do is build-in an extra safely factor, by making the “allowable” level a certain amount less than what we think the “safe” level is. But is that really the answer?

The public wants greater protection from exposure to toxic chemicals than provided by the traditional quantitative risk assessment approach which has many limitations and uncertainties. Instead, support has grown for use of a precautionary approach that promotes (1) preventive action, (2) democratic and transparent decision-making with the broadest possible public participation, and (3) a shifting of the questions being asked (e.g., instead of asking what level of risk is acceptable, asking how much risk can be avoided; what is the need; why is it needed; who benefits and who is harmed; and what are the alternatives?) as well as the presumptions used in decision-making (e.g., shifting the burden of proof to the proponents of potentially harmful activities, and placing public health above other considerations).

In its 2009 report, Science and Decisions, the National Resource Council (NRC) of the National Academies acknowledged that risk assessment is “at a crossroads” facing “a number of substantial challenges”, that “its credibility is being challenged”, and that the “regulatory risk assessment process is bogged down”.  The report made a number of recommendations that focused on improving the methodology of risk assessments (e.g., thorough evaluation of uncertainties and variability, unified dose-response approach to cancer and non-cancer endpoints, broadening the assessment of cumulative and interacting health risks and stressors), and improving the relevance or utility of risk assessments for decision-making (e.g., involving all stakeholders at the earliest stage of the planning, design and scoping of the risk assessment, and increasing the transparency of the assessment methods and process).

The NRC recommended two major shifts: (1) “that risk assessment should be viewed as a method for evaluating the relative merits of various options for managing risk”, with the risk management questions being “clearly posed, through careful evaluation of the options available to manage environmental problems at hand,” casting light on “a wider range of decision options than has traditionally been the case”; and (2) aligning closely the technical analysis with the problem at hand so that the risk assessment will be relevant to the needs of the decision-makers and stakeholders who are addressing the problem (e.g., a “one size fits all” approach to risk assessment will not be appropriate for such very different problems as regulating a chemical and deciding on a site remediation approach).

These recommendations are now more than 5 years old, and there’s little evidence that government is adopting these recommendations. Doing so should improve the ability to interpret hazards, contamination levels and population exposures, dose-response relationships, and cumulative risks (exposures from multiple pathways, complex mixtures, multiple stressors, and factors affecting vulnerability), as well as the evaluation of a wide range of alternative options (e.g., inherently safer technologies, alternative ways to achieve the same goal, etc.). It could also provide a way to integrate the risk assessment tool within a broader precautionary approach that seeks to reduce or avoid exposures to toxic chemicals, which the public is actively calling for. It’s time to stop accepting risk assessment as the best we can do to evaluate risks and adopt more a holistic approach to protecting public health and the environment.


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Backyard Talk

St. Louis is Burning, and Moms are on the Move

“The truth is that nobody is really sure what is buried at the West Lake Landfill, or where — and that’s the problem.” – Ryan Schuessler, Al Jazeera News.

A burning landfill, in proximity to a radioactive waste dump, in a neighborhood with a host of unexplained health problems ranging from appendix cancer to alopecia – all the elements of an environmental crisis in the making, and a health crisis already well underway. This is what some citizens of St. Louis have been coping with, and what has brought a group of them to Washington, D.C. today in an effort to protect their children.



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Trevor, suffering from alopecia, is one child affected by the situation in St. Louis


A group of mothers from St. Louis will convene at the National Press Club today for a press conference on the nuclear waste polluting their town. After, they will deliver petitions to Bill Gates, who has the power to protect St. Louis families from further harms. While he is not responsible for the situation, Gates is the major shareholder of Republic Services, the company responsible for the waste. He can use both his shareholder vote and his financial influence to push for an evacuation of St. Louis families living near the landfill.


Post-Press Conference Updates:

On Thursday, three mothers from St. Louis, representing the group ‘Just Moms,’ spoke at the National Press Club in Washington and bore heartbreaking testimony to the devastating health problems their children have suffered from living adjacent to the West Lake Landfill Superfund Site. The mothers have been pressing EPA Administrator Gina McCarthy for a meeting, but she has thus far ignored their requests, leaving them with few places to turn in fighting for the health and safety of their children.



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Just Moms march to EPA headquarters on Thursday




Following the press conference, the Just Moms and a crowd of supporters marched to the EPA headquarters in Washington, D.C., chanting “The Moms Are Not Going Away, Gina McCarthy Meet Today!” They demonstrated and passed out fliers outside of EPA headquarters, before traveling to the headquarters of the Gates Foundation to deliver petitions to Bill Gates.

View more photos from the event at https://chej.org/gallery/stl_justmoms/.

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Backyard Talk

Gina McCarthy Where Are You?

In my 35 years of working in the field, beginning with Love Canal, I have never seen such irresponsible behavior by EPA headquarters. Yes, there has been many cases where EPA did not act responsibly but this is by far the worst.

In St. Louis, Missouri waste from the Manhattan Project has sat throughout the community for more than 20 years. The West Lake Superfund site contains tons of this highly radioactive wastes. Over 20 years not much has been done about cleaning up the wastes, except studies.

Today, the landfill adjoining the Manhattan waste site is burning and the fire is moving toward the radioactive wastes. What will happen when the fire and radioactive wastes meet? No one knows.

That however, if the background of the situation. In the fore ground is USEPA’s mismanagement of the sites. Everyone right up to the regional administrator has been “transferred.”  Transfers is what government does instead of firing people.

In a recent meeting with local community leaders, EPA staff from headquarters and the region EPA refused to talk about the fire moving toward the radioactive wastes. EPA staff also refused to even consider the relocation of families downwind of the smoke that often bellow’s from the site. EPA staff was like those silly dolls where you pull the string and they say the same things over and over again.

This mismanagement of the site and situation is a direct result of incompetency and has created an even larger problem. It will be two years before the new cleanup plan and barrier will be defined and then it must go through public comments. Not a shovel will be moving around the site for two plus years.

Why is this important? Because toxic smoke rises from the site and into the neighborhood especially Spanish Village on a regular basis. No one can put the uncontrolled fire out.  That is what the state and federal government is saying. The fire will burn for years to come.

EPA Administrator Gina McCarthy is only willing to transfer inept staff and won’t take a single step to assist the community. Today she is refusing to meet with local leaders who will travel to Washington, D.C. next week after raising travel costs from bake sales. They want to tell their story and plead for help. Their children are sick and their families are trapped.

Throughout my years of work in CHEJ I’ve been disappointed and frustrated by EPA but never have I been told that the community leaders will never get a meeting with the Administrator.  Never get this and never get that.  “We (staff below her level of authority) make the decisions not McCarthy.”  So according to these people who work under Gina they have the final say. I wonder if she knows that. So according to them there is nowhere to appeal the lower staff decisions.

Its past time for Gina McCarthy gets her Superfund program and staff in order.  If I as CHEJ’s Director received negative comments about my staff I would certainly talk to those who are unhappy about staff’s behavior and performance not just get rid of bad apples.

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News Archive

St. Louis burning: Atomic Legacy Haunts City

by Ryan Schuessler @RyanSchuessler1 April 29, 2015 5:00AM ET
Karen Nickel had never even heard of lupus before she was diagnosed with the autoimmune disease six years ago. Today she says she takes as many as 18 pills a day — “and that’s just to make me feel OK.”
Read part one of three part series.

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Backyard Talk

Linking Adverse Health Effects and Chemical Exposures

One of the most common questions I get asked is about the health effects of toxic chemicals. Will the chemicals in the landfill harm my children? Will the emissions from the plant cause my family to get cancer? Did the chemicals off-gassing from the PVC flooring cause my son’s asthma? The questions continue every day from people across the country.

Most of what we know about the toxicity of chemicals comes from animal studies and from studies of workers who manufacture the chemicals. From this experience, we’ve learned that dusty air causes lung cancer, benzene causes leukemia, radioactive paint causes bone cancer, vinyl chloride, liver cancer, and certain pesticides cause muscle weakness and paralysis. There’s also limited evidence from studies in communities, especially among children who are highly susceptible to toxic chemicals. At Love Canal, for example, there were high rates of miscarriages and children born with birth defects; in Tucson, AZ, children whose parents drank water contaminated with trichloroethylene (TCE) were born with 2-1/2 times more heart defects than normal; in Toms River, NJ, high rates of childhood cancer was linked to drinking water contaminated with TCE and other solvents; and in Woburn, MA, increased rates of childhood leukemia were associated with drinking contaminated water.

There is no question that exposure to toxic chemicals causes adverse health effects. But for nearly all chemicals there is not enough information on what happens when people are exposed. At best, there’s good information on the toxicity of only about 10% of over 80,000 chemicals in use today.

This makes it very difficult to say with certainty what health effects will occur following exposure to toxic chemicals. Among the uncertainties are how an individual body responds to exposure (this varies quite a lot from person to person), how long exposures occur, how many chemicals you’re exposed to and the actual toxicity of the substance. In most instances, these factors are unknown.

Another confounding factor is that many symptoms or diseases are not specific to a particular chemical. In most instances, there can be many causes of the symptoms that people are having. And since few physicians know much about toxic chemicals, they often tend to blame the victim for his or her situation rather than looking at chemicals as a possible explanation. For example, many physicians will diagnose a person who is fatigued, moody and without appetite as “depressed,” likely to have a problem at home or at work. Seldom is exposure to toxic chemicals considered, even when raised by the patient.

Still another problem is determining the “normal” rate of an illness or disease in a community or in a group of people. Scientists simply can’t decide amongst themselves what is normal, in large part because of the many uncertainties already mentioned.

As a result, evaluating chemical exposures is largely a matter of opinion, not fact. Scientists can give you estimates of risk, or tell you what adverse effects are typically associated with exposure to a chemical, but they cannot tell you with any certainty whether your child will develop cancer because of his/her exposure to TCE or other chemicals in your drinking water. They can give you their opinion, but it’s only an opinion.

This is very frustrating for people. How can we be smart enough to put a man on the moon and bring him back, yet we don’t know much about the toxicity of the sea of chemicals that we live in every day? This speaks volumes about the power of the chemical industry to control government regulations and research agendas.

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Backyard Talk

Environmental Justice – Learning from Ecuador

In a previous blog by CHEJ’s Science Director, Stephen Lester, we saw that Environmental Justice (EJ) communities are not at all confined to the US. In fact, they may be even more prevalent in developing countries, and their struggles can help us better learn how to fight for justice in our own communities.

One such example is in the South American country of Ecuador, where Texaco, later annexed by oil giants Chevron, polluted massive portions of the Amazon rain forest with their oil drilling operations for nearly 40 years during the later half of the past century. Between 1954 and 1990, the amount of contamination dumped in Ecuador’s Amazon portion is estimated to be over 30 times greater than the oil spilled during the Exxon Valdez disaster.

In 2003, over 30,000 affected Ecuadorians – many of them indigenous people – filed a class-action lawsuit against Chevron, accusing the oil company of being directly responsible for more than 1,000 cancer deaths. Years of legal battles and stalling tactics by Chevron ensued, but in a recent development the International Court of Justice (ICJ) ruled that a prior decision by an Ecuadorean court fining Chevron $9.5 billion in 2011 should be upheld.

Although it is still unclear what body would have the authority to enforce the ICJ’s ruling, this decision is a massive victory for the people of Ecuador. Their perseverance – over 10 years of struggle and activism – lead to this development. In addition, despite having severely limited monetary resources and little education as well as political influence, they found strength in numbers. More than 30,000 individuals came together and organized for the cause. They used the small connections they had to draw in NGOs and other organizations to help them in their cause.

In the end, the people from Ecuador may yet achieve retribution and justice from the multibillion company that polluted their homes and killed their loved ones. As for us, we should congratulate and learn from their hard work and determination.

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Backyard Talk

Health Studies: What you can expect and what you can do

Whether your group is new or has been organized for years, one of the most pressing questions you’ll face is about health problems in your community. Typically, if you raise enough public attention and pressure, the state will ask the Agency for Toxic Substances and Disease Registry (ATSDR) to do a health study. While you may initially be excited, be careful what you ask for. ATSDR has a poor track record at investigating health problems in communities. You are more likely to get a result that is “inconclusive by design” than you are to get an honest answer to your questions. At least that’s what history tells us.

You can expect at least two things from ATSDR: First, the agency is going to treat your community like every other community that they have gone into. Second, ATSDR is going to use the standard methods they use to evaluate and investigate the health problems in your community.  Unfortunately, these scientific methods cannot answer with any accuracy or assurance the questions that people have about health problems in their community. The best state-of-the-art scientific methods that ATSDR will use cannot determine what’s causing an increase in cancer, birth defects or any other adverse effect in a population of people.

In 99 out of 100 instances, health studies conducted by ATSDR or other government agencies are inconclusive or at best incapable of determining what might be causing an observed increase in a disease found in a community. Given this likely outcome, it’s critical to have a plan for how to get the most from a health study done in your community.

One important step is to define as a community what you want. Do you want a typical epidemiological study where a questionnaire is distributed throughout the community asking about health problems and the results are then compared to a matched unexposed community? Do you want a clinic set up in the community where people could be tested to evaluate their health? Maybe some portion of the community wants to be relocated or evacuated and you want ATSDR to recommend such action.

Once you’re clear on what you want, then you need to figure out how to achieve these goals. This will take some strategic planning and a strong organized community effort. Ask these three questions about the health study, the answers to which will give you a good sense of the intent of the investigators and the limits of the study:

  • What are the goals of the investigation?
  • How will the investigators get the information they need?
  • How are they going to release the results?

Based on what you find out, you may decide that you don’t want to participate in this study. Or you may decide you want to change the agency’s plan to something that will be useful to your group. Changing their plan will require a strong organized community effort and a plan to get your points across to the agency. CHEJ can help you develop a plan to address a health study. Contact us at chej@chej.org

Also, tune in tomorrow at 12 noon EST to participate in a training session on Health Studies: What can they tell you about health problems in your community?


(RSVP Online Now)

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Backyard Talk

The Circle of Poverty and Poison

This past month I’ve spent time with several grassroots organizations fighting to protect their families from environmental chemical threats. In each case I was reminded of how impossible it is for parents, with dreams of a bright successful future for their children, to achieve their goals while living in the circle of poison and poverty.

Many parents in low wealth communities, tell the story of how they work hard to support their children in school. Moms and dads make sure their homework is done, provide the healthiest breakfast and lunch they can afford and attend as many meeting and events that time allows. They want their children to succeed in school, to learn the skills needed to later secure a job that will bring them a better life.

Yet, no matter how hard parents try they often can’t stop the environmental poisons in the air, water or land. As the children leave for school the toxic air triggers an asthma attack. A parent must lose a day of work, daily earnings, and take the child to the hospital or care for the child at home. When a child is exposed to other environmental chemicals, or maybe even the same ones that cause the asthma, they can suffer from various forms of central nervous system irritants that cause hyperactive behaviors, loss of IQ point or a host of other problems that interfere with learning potential.

The end result is the child becomes frustrated because s/he can’t keep up with what is required at school because of being sick or unable to focus and often drops out of school. That child and the parent’s dreams disappear. A healthy baby, poisoned for years from environmental chemicals, life is forever altered. Often unable to earn enough money to ever leave the poisoned community, possibly even raising their own families in that same neighborhood, continues another generation within the circle of poverty and poison.

America’s environmental protection agencies are responsible for a healthy environment. As we all know the agencies fail often and even more frequently in low wealth communities. In my conversations with leaders in such areas I hear over and over again, parents saying we had so much hope for our child but the chemicals destroyed that hope. Our family can’t afford to move and our children can’t succeed if we stay and they are poisoned. What are families supposed to do?  I can’t answer that question, except to say keep speaking up and out. Can you answer parent’s cries for a solution?

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Backyard Talk

SAN Trimer: The hidden killer behind the Reich Farm Superfund Site

Styrene-acrylonitrile trimer. It sounds like some sort of noxious mega-rocket fuel that Wile E. Coyote used to power his Acme rockets as he tried to take the Roadrunner down. Turns out styrene-acrylonitrile trimer, or SAN trimer for short, is not so far from being just that as the residents of Toms River, NJ painfully and tragically found out.

SAN trimer is a compound set of similar semi-volatile chemicals that are formed during the production of acrylonitrile styrene plastics. This compound is relatively new to modern toxicology, having been studied in depth only within the past decade and a half. As a result, its toxicological properties remain poorly understood – and the residents of Toms River and its surrounding areas paid the price for our lack of understanding and, most importantly, our carelessness.

In 1971 a waste hauler working for Union Carbide improperly disposed of drums containing toxic solvents on a section of the three-acre Reich Farm property in Toms River leading to massive soil and groundwater contamination with volatile organic compounds such as trichloroethylene (TCE) and perchloroethylene (PCE). Consequently, the New Jersey Department of Environmental Protection and USEPA worked to address the site’s contamination, introducing it into the National Priorities List in 1983, developing a cleanup plan in 1988 and culminating the soil portion in 1995 (groundwater treatment was ongoing).

However, the SAN trimer lay hidden in the groundwater undisturbed by the treatment system – silently eating away at the health of the local residents. In 1996, significantly elevated rates of certain childhood cancers were found in the Toms River area. A staggering total of 90 cases of childhood cancer were reported from 1979-1995. New Jersey authorities were baffled by this and frantically looked for possible causes. Finally, with the help of the U.S. Agency for Toxic Substances and Disease Registry, they found a possible culprit as high concentrations of the SAN trimer in groundwater surrounding the Reich Farm Superfund Site were detected. Despite having practically zero understanding of the toxicity of SAN trimer, this find led to an update in the groundwater treatment system designed to remove the SAN trimer. Simultaneously, the National Toxicology Program was asked to conduct studies on the SAN Trimer to determine its health effects, and they completed their review in 2012.

The results concluded that the SAN trimer has potential to cause peripheral nerve degeneration, bone marrow hyperplasia and urinary bladder hyperplasia, while also concluding that it has no carcinogenic effects. However, the study consisted of 7 week, 18 week, and 2 year reviews of rats exposed to the SAN trimer as well as bacterial assays. These studies were quite limited and simply underscore our incomplete knowledge of SAN trimer toxicity. Furthermore, although not statistically significant, dose-related increases in DNA damage in brain and liver cells of test rats were observed pointing the way towards a possible association with cancer.

What is clear is that the SAN trimer is one of many new chemicals whose toxicity we simply do not understand. The reality is that it was present for nearly 20 years at the Reich Farm Superfund Site, and it ate up the lives of the children living there. Now, over 35 years since the site became contaminated, EPA held a public meeting in Toms River last Friday to explain how the SAN trimer is not responsible for the cancer cluster that devoured so many lives. And what are they basing this assessment on? On the lie they tell themselves and the rest of the public – that we understand how the SAN trimer works on our bodies, and that this hidden killer is not responsible for ruining 90 lives.

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Backyard Talk

Demand What You Want-Not What’s “Feasible”

Truer words have never been spoken. In CHEJ’s recent training on Lessons Learned from New York State, which recently banned fracking until it can be proven safe, Eric Weltman from Food and Water Watch told the group to demand what you want not what is feasible.

I find it frustrating and a bit troubling when I visit communities who are struggling to protect their health and environment from environmental threats and they ask for less than they deserve and need. When I ask leaders, “why short change themselves,” they often respond saying they don’t want to sound unreasonable or worse because their opponents said it’s too expensive. Leaders and community members are often bullied into believing that they must take less or they won’t get anything. This is just not true.

At Love Canal in 1978, our community was told that government does not evacuate families and purchase homes because of toxic pollution. If we didn’t stick to our goal we would never had been evacuated. When the environmental health and justice movement demanded that no more commercial landfills be built, we were all told it must go somewhere. Several years later up until today no new commercial hazardous wastes landfills have been built, although it is still legal to do so.

In one of CHEJ’s consumer campaigns around a multinational corporation, we were demanding they take certain products off their shelves. The corporations response was, we won’t be bullied by radical environmental group. Yet a short time later they did exactly what we and consumers across the country asked.

No one should ask or accept as the final decision, what is not right and fair. However, winning the big ask is more difficult and demands serious discipline. Everyone needs to be on the same page and demand the same goal. Yes, there are always those few who will say out loud and even in the media that they would be wiling to accept less. Yet if the loud vocal people, the base of the majority, the framers of the campaign stick with their larger goal for justice, they will dominate the campaign. Those with smaller goals will be essential drowned out by the voices and actions of this  larger group.

This was the case in New York State around fracking. There were good people who would have accepted better regulations or only drilling in certain parts of the state. In every issue those working from various groups often have different goals. Sometimes their efforts help build toward the larger goal and other times they may be an irritation. The key to win it all is to build larger stronger, more visible opposition and demand for the larger goals. In this way you can win your goals without publicly fighting with others.

As Eric told us, “we were relentless. With op-eds, press events, using the public participation/comment period to submit a hundred thousands of “comments” that said Ban Fracking Now –not detailed line by line comments about regulations that were proposed. Hundreds of groups participated in bird dogging the governor who couldn’t go anywhere without a group, small or large in his face demanding he ban fracking.”

Secondly, Eric was clear that you need a single target, in NYS it was the governor. “You need to find the person who has the power to give you what you are demanding,” he said. I would add that it always needs to be a person not an entity, like regulatory agency or corporation. You need a human face on your opponent and your messengers to make it all work.

This is a time tested strategy and if you follow it you are more likely to receive a higher level of justice not a compromising solution.