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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

Southern Community Groups Call for the Right to Say No to Natural Gas Facilities

Campaign to Safeguard America’s Resources Today community groups in Virginia, North Carolina and Georgia called for the establishment of local veto power over natural gas extraction, transport and use. At rallies, marches and other public events extending from Floyd, Virginia, across North Carolina to Valdosta, Georgia, people joined in a chorus of protests against pipelines, compressor stations, power plants, hydrofracking wells and waste dumps and for the restoration of property rights and local control over energy policy in the Southeast.

Lou Zeller, Executive Director of the Blue Ridge Environmental Defense League, said, “Today we launch the campaign to Safeguard America’s Resources because of our nation’s dangerous reliance on fossil fuel, including natural gas, which pollutes the air and water. But we also see a parallel danger to our communities, to our society and to our democracy from a dominant oil and gas industry.”

At press conferences in county courthouses, community buildings, a university and a small church, League chapters called for action to halt natural gas facilities in their communities. Following the speeches, they joined caravans and parades to focus public opposition at the local government level. Events across the region echoed the twin themes of danger and opportunity.

Kim McCall, Secretary of the Concerned Citizens of Richmond County, North Carolina, spoke against hydro-fracking and the expansion of Duke Energy’s natural gas power plant in Hamlet. She said, “We are petitioning local governments for the ability to veto projects that threaten our homes, our families and our neighbors.” The group has petitioned EPA to deny the air permit to increase toxic air pollution by 36% from the combustion turbine electric power plant in her backyard.

To launch their campaign in Lee County, North Carolina, members of EnvironmentaLEE held a prayer vigil and rally at Mount Calvary Baptist Church, which is located in front of the brickyard in Sanford where the dumping 8 million tons of Duke Energy’s toxic coal ash is proposed. Deb Hall, a member of EnvironmentaLEE, said, “We are already ground zero for fracking, and the North Carolina General Assembly stripped local governments of their ability to control fracking and coal ash dumping. This threatens our health, the environment, community self-determination, and property rights.”

Mark Laity-Snyder, a founding member of Preserve Franklin county, joined others carrying black coffins in a caravan to Floyd, Virginia. He said, “We chose a coffin to represent the loss of a basic American right, the right to be secure in our homes without private companies taking our land.” Jenny Chapman, from nearby Preserve Bent Mountain, said, “For a corporation like Mountain Valley Pipeline to override the rights of private citizens to their land, safety and quality of life is unacceptable.”

Pat Hill, co-founder of Person County PRIDE in Roxboro, North Carolina, said, “My husband and I live next to the Republic mega-dump. We want to have a voice in protecting our water and air quality because we live with it every day.” She continued, “The toxic wastes deposited here endanger our health and the health of our neighbors. Coal ash contains arsenic, lead and many other poisons. Because hydrofracking uses secret contaminants, it could have an unknown number of dangerous compounds.”

Michael G. Noll, President of Wiregrass Activists for Clean Energy in Valdosta, Georgia, sounded a note of hope, saying, “This is the beginning of a new era, where we see the unified efforts of communities across the nation to safeguard America’s resources, to wean ourselves of fossil fuels, and to protect the unalienable rights of citizens to clean water and air. I am convinced that safe and renewable sources of energy like solar and wind will be the lunar landing of our generation.”

Mara Robbins, Virginia Campaign Coordinator for the Blue Ridge Environmental Defense League and organizer of the Floyd March and Demonstration, said, “We chose to have this action here because we stand in solidarity with all the counties that are resisting the threat of the Mountain Valley Pipeline.” She pointed to many different communities in three states that are calling for community-level veto power over fossil fuel projects. Referring to her success in pushing the pipeline route out of her home county, she said, “Though Floyd is not in the line of fire at the moment, we claim the right to say NO to dangerous proposals that utilize eminent domain over the wishes of the people. And we think all communities deserve that right.”

The Blue Ridge Environmental Defense League was founded in 1984. The organization has a thirty-year track record of victories over polluting facilities.

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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

Guest Blog: Fracking Impacts Without Drilling

Guest blog by Ann M. Nau, Vice President, Myersville Citizens for a Rural Community

In talking about ‘fracking’, oftentimes the industry tries to limit the discussion to the actual process of injecting liquid at high pressure into rock formations to extract gas. However, there is a broad network of infrastructure that is required to support that process, including storage facilities, compressor stations, metering stations, processing facilities, gathering lines, and intrastate and interstate pipelines. And regulatory oversight of those components falls to various local and federal agencies, if it is regulated at all. Very generally speaking, activities related to drilling fall under state authority while the federal government has oversight of interstate pipelines and associated facilities.  And what that means for towns like Myersville is that while there is currently no fracking in Maryland, the natural gas boom has already negatively affected our community.

Myersville is a picturesque rural community of approximately 1,600, nestled in the Middletown Valley of Frederick County, MD about 40 miles north of Washington, DC. It is a place where families have lived for generations and where newcomers have settled, seeking the serenity and closeness a small town offers.

And it is here, approximately 1 mile from our only elementary school that Dominion Transmission (DTI), a subsidiary of Virginia-based power giant Dominion, sought to build and operate a 16 thousand horsepower natural gas compressor station to move gas along its interstate pipeline. This station would annually release 23.5 tons per year of Nitrogen Oxides in addition to particulate matter, volatile organic compounds, carbon monoxide, and green houses gases.

The citizens of Myersville were overwhelming opposed to this plan. We held rallies, wrote over 600 opposition letters, hired an attorney, and formed a community group.

In August of 2012, the Town Council unanimously voted against Dominion’s application to amend the Town Master Plan, finding among others things that the project posed a risk to the citizens.  And by doing so, the Town denied Dominion the necessary local zoning approval required by Maryland Department of the Environment to issue an air permit.  Despite all of this, in December of 2012, the Federal Energy Regulatory Commission or FERC authorized the project.  Armed with that certificate, DTI sued both the Town of Myersville and MDE, using the power of federal preemption granted in the Natural Gas Act to override local and state zoning.

FERC is an independent regulatory agency within the US Department of Energy with jurisdiction over interstate electricity sales, natural gas pricing, and oil pipeline rates.  It also reviews and authorizes liquefied natural gas (LNG) terminals, interstate natural gas pipelines and hydropower projects. The   Commission is composed of five embers, or Commissioners, who are appointed by the President and

In spite of our best efforts, as you enter Myersville, you are greeted by Dominion’s toxic-emission spewing gas compressor station. And while Myersville may be one of the first communities in Maryland impacted by build out from fracking, I can assure you it will not be the last. Already, our friends in Cove Point, MD are battling the LNG export plant and Williams Transco seeks approval to increase compression capabilities in Howard County. In fact, an industry group states that to support natural gas drilling nationally, they will need PER YEAR for the next 25 years1:

•           850 miles of new natural gas transmission mainlines,

•           Over 800 miles of new laterals to and from power plants, processing facilities and storage fields

•           14,000 miles of new gas gathering lines

•           More than 580,000 hp for pipelines and gathering compression

To put that into perspective, here is a 2008 map of natural gas pipelines and compressor stations.



So when we discuss fracking, we need to consider all the impacts associated with it– from drilling rigs, compressor stations, pipelines, processing plants, storage facilities and export plants.  We must not allow separate regulatory schemes to divide and conquer us.  Because what happens to our neighbors in West Virginia, in Pennsylvania, in Ohio, in Western MD, in Myersville, in Howard County, in Lusby, affects all us.

1http://www.ingaa.org/file.aspx?id=21498

Ann M. Nau is the Vice President of the Myersville Citizens for a Rural Community, http://mcrcmd.org/.

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Backyard Talk

New Health Studies Guide for Community Groups

The Boston University Superfund Research Program (BU SRP)recently made available the first four chapters of a new health studies guide targeted to community groups. The new guidebook, called Is a Health Study the Answer for Your Community? A guide for making informed decisions is available at www.busrp.org/hsg. For many years, environmental health scientists at BU included Dr. David Ozonoff and Dr. Richard Clapp worked with community groups to address health problems in communities. This experience together with input from many experts and organizations including CHEJ was used to develop this Health Studies Guide. The intent is to assist community groups and individuals who think that some form of environmental health investigation or health study may be useful or necessary in their community.


The guide begins by helping readers consider factors that might influence their decision about whether to do a health study. Readers are encouraged to thoughtfully define their goals, to consider whether a health study will be useful in meeting these goals, and, if so, to choose the appropriate kind of study. The guide includes a wide menu of health study types and helps you think through which one might be best to address the questions you are trying to answer. It takes you through the process of choosing and designing a study, but it is not a complete how-to guide. It does not, for example, explain how to do your own epidemiologic study or risk assessment, nor does it describe how to conduct a health survey, though helpful resources are included in the Appendix. One chapter explains how to evaluate the strength of a study’s results and how to think about what the results mean. The guide closes with a glossary to help sort through various technical terms and jargon.

The authors readily acknowledge that a health study may not be the answer to the fundamental questions that you are asking about the health problems in your family or in your community. Instead they offer alternatives to traditional health studies that may help achieve community goals. This guide should be a useful tool not only for those who are contemplating a study, but also for those who are involved in a study or are the subjects of one. It will help you think about your expectations for the study’s findings, costs, and time frame. We couldn’t agree more with this advice “Above all, if you decide on a health study you will want to organize and work with your entire community so that it is meaningful to you.”

Two additional chapters are still being developed and are expected to be completed in the near future. The authors welcome your comments and input.

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Backyard Talk

Celebrating 35 years of Success

What a night it was! Long-time and new friends joined Lois Gibbs in New York City to commemorate the 35th anniversary of Love Canal. The event also honored and celebrated Lois for her legacy and leadership as the founder of the Center for Health, Environment and Justice (CHEJ).
It was a truly celebratory evening. You could feel real energy in the room as everyone enjoyed the warm company and delicious food. It was a night to recognize how far we’ve come since the days of Love Canal and to reflect on the elements that have powered change in the past three decades.
In line with the celebratory theme, there were no lectures or speeches; a brief clip of the Love Canal segment in the documentary A Fierce Green Fire, The Battle for A Living Planet was shown. There was giggling at some scenes; boos at those that showed anti-environmental attacks, like when Ronald Reagan alleged that “the environmentalist won’t be happy until they turn the Whitehouse into a bird’s nest.” And of course, there was a lot of applause when Lois challenged President Carter and the U.S. government by taking the EPA representatives hostage. It was a fun fifteen minutes of viewing.
CHEJ and Lois certainly felt proud to be recognized and introduced by our special guests Chevy and Jayni Chase. The evening was also a successful fundraiser for CHEJ, bringing new critical resources to support the work of CHEJ’s Leadership Training Academy. The event is the first in a series that will be held this year across the country, commemorating the Love Canal anniversary and raising funds to train and mentor the next generation of grassroots leaders through the Academy.
A big thanks goes out to our host committee for their planning and support, especially to our co-chairs Sarah Stranahan and Cara McCaffrey. Their hard work has set a very high bar. Thank you to all who came and to our sponsors. Your support and involvement will have a lasting positive impact in the communities in which we serve.

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Backyard Talk

35 Years of Progress Since Love Canal

This year marks a very significant date – the 35th anniversary of the Love Canal crisis. It is hard to believe it has been that long and in recognizing this fact of life, I realize that entire generations have been born since who may know little or nothing about Love Canal and how the environmental health and justice movement began.

History is important and we need to find ways to tell the story so that we don’t repeat our mistakes and we can reap the benefits of lessons learned through oral histories. One key lesson from Love Canal is that a blue collar community with next to no resources was able to win its fight for justice and open the eyes of the nation and the world to the serious problems of environmental chemicals and their effects on public health.

Thanks to Mark Kitchell, an Oscar nominated and well known filmmaker (Berkeley in the Sixties), there’s now a compelling and thought provoking film that can be used as a tool in educating younger generations about Love Canal and the history of the environmental movement and engaging them and re-engaging the rest of us in the fight for a healthy planet. What is exciting about A Fierce Green Fire is that this film, which includes a prominent segment on Love Canal, demonstrates in real footage that change happens when people get involved.

“The main difference between my film and a lot of other environmental films is that instead of it being focused on the issues, ours is focused on the movement and activism,” said Mark Kitchell in an interview. “I feel that telling stories of activists, taking up the battle and fighting, is the best way to explicate the issues. And that was my main handle on the environmental subject, doing the movement story,” adds Kitchell. The film, narrated by such notables as Robert Redford, Meryl Streep and Ashley Judd among others, received great reviews at Sundance.

As CHEJ moves forward this coming year, we are partnering with groups across the country who would like to show the film in a theater setting, at small group gatherings or house events and have a conversation about how change happens and what they might do differently in their efforts to win on environmental and environmental health and justice issues. Partnering with groups, we hope to also bring media attention to their local issues and raise funds for their group and CHEJ. It’s a plan that’s hard to pass up.

If your group is interested in hosting a local viewing, please contact CHEJ. Together we can inspire people to take action to protect health and our planet.

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Backyard Talk

Information is Power: True or False?


I often ask this question when speaking publicly about what I do at CHEJ. I’m trained as a scientist and I provide technical assistance to grassroots community groups.  People send me testing data to review,  whether it’s the chemicals found in their drinking water, the air behind their child’s school, or the soil in the park where their children play. They ask me to do this primarily because they want to know what the test results mean. But they also believe that if they gather enough information – the right information, especially- and get it into the hands of the decision makers, that everything will fall into place.

So what do you think? True or false? Is information power?  Can you solve your environmental problem by gathering information and then getting it into the hands of the decision makers?  No, you cannot.  The answer is false, information is not power.  It’s not the information by itself but rather what you do with it that can make all the difference in the world. Just gathering data and sharing it no matter how important or impactful will not likely change a bureaucrat’s or a politician’s mind.  But if you use the information to educate your community and then go the bureaucrats and politicians with a set of demands that meet the needs of your community, you have a much greater chance to be successful.

At CHEJ, we work directly with community leaders to help them become knowledgeable and proficient in understanding the technical, health, statistical and scientific aspects of chemical exposures. We also work with community leaders to help them understand how to use technical information to achieve their goals and win what their community needs to resolve its environmental problem(s). What we do includes reviewing testing data; cleanup plans; technologies for treating/disposing of hazardous waste and household garbage; reviewing plans to build new facilities; defining a community-based testing plan that includes where to test, what to test (soil, air, water), what to look for; evaluating a health study completed by a government agency or other entity; and so much more.  CHEJ also has more than 60 guidebooks and fact-packs on a wide range of topics that you can use to focus your group on what it needs to be successful.

So don’t get trapped into believing you can win over the bureaucrats or your politicians by gathering information, or become frozen into inaction until you gather just a little bit more information.  What really matters is what you do with the information you have and how it fits strategically into your organizing plan. To learn more about CHEJ’s technical assistance services, see our website at http://chej.org/assistance/technical-assistance/

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Backyard Talk

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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Backyard Talk

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.