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Drill Deeper on Fracking NY

“Drill deeper,
New York” said the Albany Times-Union in a recent 1/15/13 editorial, saying, “with our health and environment on the line, New York still has many issues to address before moving forward on fracking.”

“Perhaps more than any other place in New York, the Capital Region knows that science matters. An unswimmable Hudson and a half-billion dollar PCB dredging project just up the river from Albany are costly proof of what happens when we make decisions on incomplete knowledge. It’s a good time to remember this as New York winds down its review of high volume horizontal hydraulic fracturing — popularly known as fracking. There are disturbing signs that, even after more than four years, we don’t have the knowledge to make a fully-informed decision….

The question is simply this: What’s the risk to human health and the environment? We’re not convinced the state Department of Environmental Conservation knows — especially when some scientists and physicians are saying they aren’t sure… Scientists warn that there are many things they don’t yet know about the fracking process. They’re still learning about the effect on human health of constant noise and light from activities like gas drilling. Geologists are looking at a marked rise in earthquakes in some parts of the country where there has been an increase in fracking or deep well drilling for fracking fluid disposal. And some wonder if, when the entire production process is considered, natural gas is as clean as its proponents say.

And then there’s a potentially key document — a health study on fracking that’s being done by the state Department of Health — that has yet to be finished or made public. The state has engaged a group of scientists to review the Health Department study, but that review is secret, too. The DEC says it will consider whether the findings of the Health Department raise any significant issues.

In other words, the public, after getting less than all the information it needed to comment on fracking, could well be shut out of further comment even when that information is revealed. Under the latest timetable, the entire review could wrap up by late February. That timetable is quite simply unfair and inappropriate, given what we now know, and what we don’t.

…Any fair current analysis must return, time and again, to fracking’s still uncertain cost, not just in dollars and cents, but in terms of human health, safe drinking water, and a clean environment. When the stakes are that high, everything we don’t know should be a red flag.

http://blog.timesunion.com/opinion/drill-deeper-%e2%80%a8new-york/23705/

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The Irish—My Heritage—Said “No” To Fracking

Friday Ireland’s government said, “Until the EPA study has concluded and there has been time to consider its findings, the use of hydraulic fracturing in exploration drilling will not be authorized in Ireland.” Mr. O’Dowd, the Ireland Natural Resources Minister, is acting in a precautionary manner unlike the United States.

Taking a precautionary action, Mr. O’Dowd commissioned and funded three part study that will determine of fracking is harmful to the environment. He is concerned about widespread pollution especially of water sources where fracking will take place.

The studies include a geological study which will determine the impacts that fracking may have on groundwater and bedrock, seismic impacts, whether tremors, earthquakes or subsidence, and the third will be defining regulations around the fracking process. All of these studies are to be completed within 20 months.

Additionally the commission has asked for the public to suggest the terms of reference to be given to researchers. Wow, the Irish get a say in the study design and methodology.

Friday, Irish Eyes Were Smiling.

Other countries have banned the process as well, while the U.S. continues to move forward in ways the mimic the wild, wild, west. The cost of fracking in the U.S. has shown us that this extraction process is too expensive. We’ve seen environmental damages, poisoned water and water that ignites, health care costs increasing from victims as well as the migrant workers who are uninsured and use county facilities, lost land values and property values and the list goes on.

Not only is fracking moving forward at light speed compared to other industries’ ability to get permits and begin to set up their facility, the fracking industry has historically played dirty with communities by threatening, suing and attempting to undercutting local leaders credibility. However, the U.S. Frackers just recently said they’ll stop being bullies (my words not theirs) and try a new approach—civil communications.

In a strategy paper on combating the anti-fracking movement, analyst Jonathan Wood of Control Risks, a global consulting company, advised drillers to acknowledge that communities have legitimate grievances, in order to begin to repair a “crippling trust deficit.” Wood advised, among other things, openness, voluntary disclosure and “meaningful consultations” with communities, rather than “didactic information sessions to market the presumed benefits of drilling.”

Jim Cannon, whose job at Range focuses on local government relations has changed his ways. He recently said, “We’re probably more active listeners now, so we’re probably better able to hone in on what local governments need from us. A couple years ago, maybe we weren’t as sensitive to it. … Now we recognize how vital it really is.”

We’ll see if that happens. It is difficult to overcome “crippling trust deficit but maybe the companies can begin by taking down the bill boards along the PA highways that claim if you think fracking is dangerous “You’ve been Slimed.” I believe, and it has been my personal experience, that it will be difficult to come back from being a bully in the community to having people sit around the table and have a trusting meaningful conversation. It’s not easy after you have been beaten, robbed and violated to come back and trust those who did the nasty deeds.

The answer is for the industry to stop what they’re doing, not just be more open in communications, and follow the lead of the Irish and other countries. Step back, take a breath, take time to understand what you are actually going to do to communities, the environment, water sources and decide what to do based upon real studies, real science to determine how and if we should move forward.

Today I’m proud to be an Irish woman.

For more information see:

http://www.independent.ie/national-news/state-bans-fracking-until-environmental-tests-are-carried-out-3349818.html

http://fuelfix.com/blog/2012/12/31/gas-drilling-companies-work-on-community-relations/

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Today’s Rachel Carson

Today’s Rachel Carson is a woman I know, admire and love, Dr. Beverly Paigen. I was reminded of how important Dr. Paigen is when asked to present her with an award from the Maine Environmental Health Strategies Center.

When I began to think about what I would say about Dr. Paigen I realized how groundbreaking her research was back in 1978 at Love Canal. How when she presented her theories and her research findings around the Love Canal chemicals and adverse health problems she was dismissed, ridiculed, and harassed by those who wanted to silence her, just like Rachel Carson.

Beverly conducted health studies and showed that 56% of the children were born with birth defects. She suggested that this rate may occur in the next generation as well. She found there were more girls than boys born at Love Canal. All of these finding and others were what we are calling today endocrine disrupting chemical effects. In 1978 endocrine disrupting chemicals were not on the radar screen of most environmental health scientists other than in wildlife, as Rachel’s work pointed out.

Beverly demonstrated how the chemicals had likely moved out of the dumpsite the Love Canal and into the homes that surrounded the site. Again she was dismissed. Today, there is a name for this movement of chemicals called vapor intrusion and there is even an EPA approved technology to remove the chemicals from homes called vapor intrusion mitigation technologies.

Beverly like Rachel Carson suffered for her commitment to speak truth to power. She worked for the State of New York Department of Health as a researcher at Roswell Cancer Institute. Her boss was the Health Commissioner who opposed acknowledging anything was wrong at Love Canal. The result of her speaking up . . . of her speaking out . . . was her staff at her research laboratory was cut, as was her budget, space and she was asked to keep a written record of everything she did.

Later she was called in for a personal IRS audit. As the auditor began to open his file a news article about Dr. Paigen fell out. Beverly called foul play and asked the state of New York for an apology for harassing her. The State did publicly apologize.

When the NYS Health Commissioner refused to sign the agreement for millions of dollars in research funds that would come to Roswell and the state from the federal government, she took her research money and left the state. But she didn’t stop her work with the Love Canal families. Beverly continued her research with Lynn Goldman at Oakland’s Children’s Hospital and published the first study on growth and maturation of Love Canal children exposed to environmental chemicals. This study like the others link slow growth of long bones in children with environmental chemical exposures.

All of the studies that Dr. Paigen did at Love Canal were vindicated. NYS Department of health confirmed the birth defect rate of 56% and found that Love Canal children were giving birth to children with the same rate of birth defects. Her studies on abnormal sex ratio were also confirmed as was so many of her other findings.

The State of New York has never apologized for their harassment and unfair treatment of Dr. Paigen. But, Beverly isn’t really looking for an apology she just wants the public health scientists to conduct scientific studies that are not politically manipulated, that answers as best as science can, the questions of environmental exposures and health. People, American families need honest answers in order to make decisions on their lives. Government health scientists need to be left alone to conduct scientific research regardless of the outcome, not be told what to do and say.

I wanted to take this opportunity to publicly say thank you Beverly for your courage, passion and most importantly for providing the groundbreaking scientific findings to the world regardless of the consequences. You are today’s Rachel Carson.

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Train Derailment in NJ: More of the Same – No Cause for Alarm



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Paulsboro train derailment.



How many times have we heard the same refrain from government leaders and scientists involved in community wide exposures such as the recent train derailment in Paulsboro, NJ that released 23,000 gallons of vinyl chloride into the air? “There’s no cause for alarm, we have everything under control.”

If only this were true. Instead, many of the hundreds of people in the 27 block area that was evacuated remain frustrated by the lack of answers to their questions about health effects and accountability. This frustration is driven by how government leaders and scientists evaluate health risks and by the many uncertainties about what is known about the short and long term health effects of being exposed to vinyl chloride or other chemicals. Scientists can estimate risks and give their opinions, but we simply don’t know what’s going to happen to the health of the people who were exposed to vinyl chloride in the aftermath of this accident. Yet this is exactly what people want to know – what’s going to happen to their health or to the health of their children as a result of this accident?

Here’s what we do know. We know that vinyl chloride is a human carcinogen and that it damages the liver and central nervous system; that more than 200 families within a half mile of the accident site were evacuated; that the Coast Guard and other authorities acted swiftly in evacuating the homes immediately surrounding the site of the accident; that the train pulling 84 cars derailed on a bridge over Mantua Creek; that seven rail cars derailed; 4 contained vinyl chloride; one ethanol; three fell into the creek; and one ruptured releasing vinyl chloride into the air (see photo).  We also know that 10 days later most people are back in their homes with assurances from the local authorities that everything is fine.

This is not surprising because it’s the practical thing to do. But what was the scientific basis for this decision? Air samples taken by EPA on December 8th and 9th from throughout the surrounding neighborhood found vinyl chloride in every sample taken. Eight of the nine samples exceeded the EPA’s one-in-a million cancer risk value (EPA’s trigger level for action). Yet people are back in their homes. EPA’s interpretation of this data is that is that the results are within the agency’s “acceptable” risk range, which varies by a factor of 1,000. This is a ridiculously large risk range that has no meaning in protecting public health.

So the stalemate is set up between government leaders and scientists telling people that everything is fine and a frustrated community that has no answers. Given this dynamic, it’s not surprising that 54 residents filed suit this week against Conrail and CSX for damages. What they want is medical screening for early detection of life threatening medical conditions linked to vinyl chloride. This is actually a reasonable response to the many uncertainties that exist in the scientific understanding of what will happen to the health of the people exposed to toxic chemicals such as vinyl chloride.

Had the government leaders and scientists in Paulsboro recognized the scientific uncertainties and more honestly acknowledged how little is known about chemical exposures and health outcomes, there may have been a more satisfying resolution. A resolution that might have included practical steps forward such as medical screening for early detection of medical conditions linked to vinyl chloride. Testing that should be paid for by the companies responsible for the accident and who own the chemicals.

As long as decision makers continue to protect the companies responsible for area-wide chemical exposures such as what occurred in Paulsboro, this scenario will continue to play out as it has since the days of Love Canal more than 30 years ago. Isn’t it time we publicly acknowledge what we don’t know about exposures to toxic chemicals and stop deluding ourselves that using risk estimates that define “acceptable” exposures is the best way to manage toxic chemicals? There is no acceptable exposure if you‘re the one being exposed.

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NY PTA Passes Resolution to Phase-out PVC in Schools

The New York State Parents Teachers Association (PTA) voted last week at their annual meeting in Saratoga Springs, NY to pass a resolution calling for a phase out of the plastic PVC in schools. The resolution, called “Reducing & Phasing Out the Purchase of Polyvinyl Chloride (PVC) Plastic in New York Schools,” acknowledged the serious harm posed by PVC throughout its lifecycle, releasing toxic chemicals such as phthalates during use in products such as school supplies and building materials; releasing toxic chemicals such as vinyl chloride and ethylene dichloride during manufacture; and generating toxic chemicals such as dioxins during disposal when burned.

The PTA’s resolution recognized that chronic health problems and conditions in children linked to environmental exposures are on the rise, including learning and developmental disorders; that children are uniquely vulnerable to harm from toxic chemicals such as those released by PVC; that PVC materials and products contain toxic additives, including volatile organic compounds (VOCs) and phthalates, that may be released into the indoor environment, posing hazards to human health including asthma and developmental problems and that children are at greatest risk of exposure; that PVC is commonly found in office supplies and building materials used in schools; that safer, cost-effective alternatives to PVC products are readily available for schools; and that the U.S. Green Building Council provides incentives for schools to avoid PVC and phthalates in “green schools.”

The NYS PTA resolution calls for the following actions:

  • Resolved that the New York State Congress of Parents and Teachers, Inc. seek and support legislation that would reduce and phase out the use of PVC products at all New York State school facilities; and be it further
  • Resolved that the New York State PTA urge school districts and the New York State Education Department (NYSED) to develop green procurement policies to reduce and phase out the use and purchase of PVC building materials and office and education supplies in school facilities where safer cost effective alternatives are available; and be it further
  • Resolved that the New York State PTA and its constituent units educate parents and community members about the potential health effects of PVC and work to eliminate PVC products at all PTA-sponsored events; and be it further
  • Resolved that the New York State PTA forward this resolution to the National PTA for its consideration.

This resolution adds to the growing movement for PVC-free schools and follows similar resolutions enacted by the American Public Health Association (APHA), the “oldest and most diverse organization of public health professionals in the world,” last year and by the New York State United Teachers (NYSUT) union that represents more than 600,000 employees and retirees from New York State schools, colleges, and healthcare facilities, this past summer. The full PTA resolution can be read at the following link: http://chej.org/wp-content/uploads/NYS-PTA-PVC-Resolution.pdf.

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Great Lakes Are Improving from Legacy Chemicals but Fracking May Change That

Environmental Health News recently reported that,

“The Great Lakes hold 20 percent of the world’s fresh surface water. The good news is that legacy contaminants are decreasing more quickly than previously reported in three of the Great Lakes, but have stayed virtually the same in two other lakes, according to new research… Polychlorinated biphenyls (PCBs), the pesticide DDT and other banned compounds dropped about 50 percent in fish in Lakes Michigan, Ontario and Huron from 1999 through 2009, although there were no significant changes in Lakes Superior and Erie fish, according to the study to be published this month in the journal Science of the Total Environment.

“These are very positive results. The lakes are improving and slowly cleaning themselves up,” said Thomas Holsen, co-director of Clarkston University’s Center for the Environment and co-author of the study . “Even with the decreases, it will be 20 to 30 years until the decades-old contaminants in Great Lakes fish decline to the point that consumption advisories can be eliminated,” Holsen said.”

All good news, except as we clean up the old chemicals like Polychlorinated biphenyls (PCBs), the pesticide DDT and other banned compounds they are being replaced by newer ones, such as flame retardants that are building up in fish and wildlife and chemicals we are not yet even looking for from oil and gas development.

Today corporations are beginning hydro-fracturing (fracking) all around the Great Lakes to extract gas. It is against the law to frack under the lakes but there are no laws about fracking near streams, creeks, rivers that empty into the lakes. This is insane. Hundreds of very toxic chemicals are injected under pressure into the ground to fracture the shale formation. Not all of these chemicals are retrieved after the fracking is done. In fact the common gas well leaves behind about 30% of the chemicals, radioactive materials and brine. It’s unbelievable, hundreds of chemicals injected all around our fresh water lakes that both the U.S. and Canada have worked for decades to clean up.

This destructive activity is a prime example of governments’ tunnel vision. Oil and Gas development moves forward, cleanup of the lakes moves forward, air deposited of chemicals from many sources continues – – – it’s like shoveling the sidewalk in a blizzard, it won’t be cleaned until the snow stops falling. There is no sign of the chemical blizzards retreat.

I grew up near the lakes in Buffalo and understand their beauty and value. My sister and brother-in-law were active in advocating the cleanup of the lakes in the 1970’s. Our family vacationed on the lakes. It was exciting back then to hear that a serious effort from both sides of the boarder would advance to make the lakes swimmable, the fish safe enough to eat and so many other promises. Now over 35 years later reports are praising the cleanup of historical chemical deposits while at the same time new chemicals are allowed to enter the lakes without protest.

Fracking is not yet widespread around the great lakes. Yes there are some wells in PA, OH, MI but we can stop widespread fracking that would further contribute chemicals to our beautiful lakes by taking a stand and insisting that regulations are put in place and bans where necessary to protect this amazing gift of nature. It is up you and me to make it happen. For more information about the recent study of the Great Lakes, click here.

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Using Blood Lead Levels to Set Cleanup Goals

Lead smelter in Kellogg, ID.The creativity of our government regulators never ceases to amaze me. I’ve seen a lot of incredibly stupid and callous decisions in my time, but this one is right up at the top. The US environmental Protection Agency (EPA) Region 10 and the Idaho Department of Environmental Quality somehow thought it was a good idea to use Blood Lead Levels in children to establish a remedial action objective (RAO) at the Bunker Hill Superfund site in Kellogg, ID. According to a recent peer reviewed paper published in the American Journal of Public Health, this decision is codified in EPA’s 1991 Record of Decision for the Bunker Hill site (1).

According to the authors, “the 1991 ROD for the Bunker Hill mine defined the EPA RAOs for child blood lead levels and stipulated the following criteria measures: (1) less than 5% of tested children should have blood lead levels greater than 10 micrograms per deciliter and (2) less than 1% of tested children should have blood lead levels greater than 15 micrograms per deciliter.” You got that. As long as no more than 5% of the children in Kellogg have blood lead levels greater than 10 micrograms per deciliter (ug/dl) and no more than 1% had levels great than 15 ug/dl, then the site cleanup efforts could be considered “successful” (1).

What was EPA thinking when they decided to use lead levels in children to define the effectiveness of a cleanup? And then, to accept that some children will have blood lead levels that exceed the recommended criteria is unconscionable. Even if this factor was not the sole criterion used to make decisions about the effectiveness of the cleanup, it is still unethical to use the children of Kellogg in this way.

The adverse health outcomes of exposure to lead are well understood. Earlier this year the Centers for Disease Control (CDC) revised its guidelines for lead lowering the blood lead level for protecting children’s health from 10 to 5 ug/dl. At the time CDC’s Advisory Committee for Childhood Lead Poisoning Prevention whose recommendations led to this change made it clear that no safe blood lead level in children has been identified.

Lead was mined at the Bunker Hill site for more than 100 years and at one time this was the home of the largest lead smelter in the United States. When the mine shut down in 1981, it left behind a toxic legacy of huge waste piles and residual contamination everywhere. Blood lead testing in children as earlier as 1976 found that 99% of Kellogg children living within 1 mile of the smelter who were tested had blood lead levels greater than 40 ug/dl (2). Today it is much less clear what the blood lead levels are because so few children are tested.

It is an injustice for EPA to treat the residents of Kellogg in this way. The residents In Kellogg have suffered disproportionately not only from lead exposure which continues to this day, but also from social disparities that include unemployment, poverty, and limited educational opportunity. Although there has been substantial cleanup at the site, it remains unclear whether there has been a corresponding improvement in community health and wellbeing. So much more needs to be done. This of course will never be achieved in communities like Kellogg, so long as decision makers think there’s nothing wrong with using the children as canaries in the mine fields.

1. Moodie, SM and Evans, EL. Ethical Issues in Using Children’s Blood Lead levels as a Remedial Action Objective. American J Public Health 2011 101(S1): S156-S160.

2. Landrigan PJ, Baker EL Jr, Feldman RG, et al. Increased lead absorption with anemia and slowed nerve conduction in children near a lead smelter. J Pediatrics 1976 89(6):904-910.

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Our Children's Schools Matter – When We Fail-They Fail

It is sad that across the country as new youngsters are entering school they are placed in harm’s way. Their emotions are mixed worried about leaving their home, daily environment and routine, while at the same time excited about their new experiences.  But toxic dangers in the air or nearby are not part of their mantra.

Yet in schools across the country parents are concerned that the location of the school building will threaten the health of their children and possible their children’s ability to lean. For example, in Richmond, Virginia there is a petition, asking the Richmond School Board to ensure the preschoolers of Norrell Elementary, near a landfill are being educated in a safe environment.  Although the petition has gained some national attention to an issue, there hasn’t been any resolution to longstanding concerns to Richmond, Virginia residents.  It hasn’t provided the pressure yet to force authorities to answer parents questions.

It has with 27,370 signatures created awareness about schools on landfills across the country and beyond. And, signatures on this petition has provided energy to beleaguered city residents who feel like they’ve been disregarded and disrespected by authorities.  A new round of testing has been committed of the school building grounds near the landfill but there is no evidence of safety.

“Local resident Kim Allen said, these developments have empowered us as we’ve come to know ourselves as people who make a difference in our community.  I, and other private citizens like me, are lending a voice to concern for the safety of children, children like my four-year-old nephew Malachi. We speak on behalf of ourselves and our families. Being a private citizen is a privilege and a powerful place to stand when addressing the safety of the children who attend Norrell Elementary school.

The question I asked myself was, Would I be okay with Malachi being in the Norrell School building for 6 hours a day, 5 days a week?  My answer . . . I don’t know. Given that concern and the urgent nature of the matter, I helped to initiate the petition.”

Despite working for over thirty years at CHEJ I’m still shocked by the blatant disregard for children’s health year after year.  Schools continue to be built on or near dumpsites like Ms. Allen speaks about or the school built in Detroit literally on top of a Superfund site. Most of these schools, not surprisingly, serve low wealth and communities of color.

Further harming everyone in the school family, when the children fail at the standardized testing it is the parents or the teachers fault — not the fault of the chemicals that inhabit their ability to learn or cause them to be sick and absent too often from school to keep up.

In Houston, Texas their recently built high school, which houses 3,500 students, is encircled by a dozen chemical facilities.  So close that if there is an accident or release at any of them, the children are trapped, left only to put wet paper towels along the window sills.  Yet, the releases from these facilities are constant and as children enter, leave or go outdoors for recess or sports they are exposed to air pollution daily.  Like the other schools when these young people fail at meeting the goals of standardized testing their parents and teachers are blamed.

It is time for all Americans to stand up and speak out about putting our children in harm’s way.  It is our tax dollars that are building these schools and we should have laws that compel schools authorities to build places of learning in safe environments.  Enough is enough.  Our children matter and are the future of our country.

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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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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.