This morning, I found myself back at EPA headquarters in downtown Washington, DC, asking EPA a second time to do something that should be obvious: listen to its own scientists and use the best available science to protect communities from hazardous air pollution.
While it should be straightforward for EPA to turn to its own science to support its decisions, the chemical industry has been on the offensive, attempting to discredit the EPA’s 2016 Integrated Risk Information System (IRIS) risk value for ethylene oxide and pushing the agency to use alternative science. In the proposed rule issued in November, the EPA announced intentions to require a subset of chemical-producing facilities to reduce emissions, but also suggested using a significantly less protective risk value (3,500 weaker to be exact), developed by the notoriously industry-friendly Texas Commission on Environmental Quality. But, under the Clean Air Act, the EPA is required to set emissions standards to eliminate unacceptable risks and protect the public with an ample margin of safety, not to cater to industry demands to continue with business as usual.
During the hearing, a representative from the Society of Chemical Manufacturers and Affiliates (SOCMA) opposed the use of EPA’s IRIS value and asked that the EPA take action to address the “confusion” that exists within communities about the risks they face related to ethylene oxide. Actually, there’s nothing confusing about the very real risks associated with ethylene oxide exposure, including multiple types of cancer, that government science has confirmed time and time again. This idea that communities are just confused about the health risks associated with chemical exposure is unfounded and straight-up offensive. It’s also very clear that the chemical burden is not distributed equally or fairly, as Stephanie Herron from the Environmental Justice Health Alliance stated in her comment. Ethylene oxide and other hazardous air pollutants pose significant environmental justice concerns, as exposure disproportionately burdens communities of color and low-income communities.
At a hearing in Houston, TX earlier this week, executive director of the Texas Environmental Justice Advocacy Services (t.e.j.a.s.) Juan Parras stated, “We cannot applaud EPA for doing the bare minimum, because the agency is not even doing what it knows is needed to protect people’s health, based on the best available science…EPA also cannot avoid ensuring that facilities use up-to-date pollution controls, and practices, including real-time fenceline monitoring, to protect public health. People in Texas deserve the strongest protection available for our health.”
It’s time for EPA to listen to the voices of the communities who are calling for change. The agency must step in and use its powers under the Clean Air Act, informed by the best available science, to protect them from unacceptable cancer risks.
Here’s my full statement:
Good morning and thank you for the opportunity to comment on EPA’s proposed amendments to the NESHAP for the Miscellaneous Organic Chemical Manufacturing source category. My name is Genna Reed and I am the lead science and policy analyst at the Center for Science and Democracy at the Union of Concerned Scientists.
The EPA’s proposal to require a reduction of hazardous air pollutant emissions at MON sources is necessary but the EPA must take more steps to adequately protect the public from unacceptable health risks, especially from the cancer-causing ethylene oxide. Further, the agency should require fenceline monitoring and make that data publicly available in a reasonable timeframe, require stronger leak detection and repair, and ensure that facilities follow best practices to prevent releases in emergency scenarios that are all too common at many of these locations.
We urge EPA to follow the best available science to strengthen emission standards and continue to apply the 2016 value, respecting its own scientific experts at IRIS who conducted a systematic review of toxicological and epidemiological evidence that took ten years to complete and included interagency review, input from the EPA Science Advisory Board, and public comment. It concluded that ethylene oxide is carcinogenic to humans, causing an increased risk of cancer of leukemia, lymphoma and breast cancer in women. National Air Toxics Assessment (NATA) data released in 2018 incorporating the new IRIS risk value revealed that the probability of developing cancer from air pollutants was beyond the EPA’s acceptable level of risk, and 91 percent of the risk can be attributed to ethylene oxide, formaldehyde, or chloroprene.
EPA has no time to waste complying with the American Chemistry Council’s baseless requests to question its own science. It also must not replace the IRIS value with the recently produced Texas Commission on Environmental Quality risk value which is 3,500 times weaker than the IRIS value and greatly underestimates cancer risks, especially to vulnerable populations including women and children. Further, the TCEQ assessment relies on a key study that EPA chose not to include in its evaluation of the best available science because the data “were not of sufficient quality” and other recent studies considered in the TCEQ’s assessment were funded by the American Chemistry Council, which has a clear, vested interest in ethylene oxide production and regulation.
The threat of cancer from ethylene oxide is real and present in so many communities across the country, and despite the known risks, EPA is failing to protect many exposed communities of color and low-income communities. In places like St. Charles, Louisiana right in the backyard of the largest ethylene oxide emitter in United States, exposure to ethylene oxide is just one toxin in a chemical cocktail of industrial exposures that the community faces. In Lake County, Illinois, residents face contamination from two nearby plants and EPA has failed to conduct fenceline air monitoring to understand the exposure and risks to the community. Areas like St. Charles, LA and Lake County, IL rely on the EPA to use its own rigorous assessments of the science to set health-protective limits. The EPA should heed the call of communities asking to be heard in an accessible location and incorporate their concerns into actions taken on ethylene oxide.
In order for the EPA to meet its mission to protect human health and the environment, it must rely on IRIS for its evaluations of the best available science and issue standards that best protect communities exposed to the highest emissions and associated health risks. Thank you.
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