Chemical Lifecycle and Exposure in Environmental Justice Communities

By Mark Mitchell, MD MPH

This essay is in response to: Explain how environmental justice concerns play out in your community, and how policy change could address exposure disparities.

Environmental justice (EJ) communities are low-income communities and communities of color that are disproportionately burdened with environmental hazards and suffer disproportionately from environmentally related diseases. Environmental justice strives to correct this imbalance while reducing hazards for everyone by changing environmental policies and practices.

Environmental justice communities are deeply impacted by national chemical policies. The failure of federal law to properly regulate chemicals based on health and safety has resulted in higher rates of environmentally related diseases, such as asthma, diabetes, learning disabilities, cardiovascular disease, and premature death, as well as many other health conditions in communities of color and low-income communities. Residents experience disproportionate exposure to chemicals over the entire lifecycle of chemicals: during their production, distribution, use, and disposal and including legacy exposure to chemicals that are no longer in use.

Environmental justice communities are exposed during chemical production because manufacturing facilities are often located in environmental justice communities without a sufficient buffer zone between the facilities and people’s homes to protect them when there are mishaps and accidental releases of toxics to the air, water, or on the land. From my experience, chemical facilities located in environmental justice communities, like the 11 facilities located in the Rubbertown section of Louisville, Kentucky, tend to have more pollution releases (fires, explosions, leaks, and spills) than similar facilities in other communities—possibly due to poorer maintenance and fewer upgrades. In Louisville, officials measured industrial air toxics on a schoolyard located a mile away from the facility; usually concentrations of air toxics dissipate enough to prevent them from being measured so far away. This community appears to have high rates of diabetes, cancer, lupus, endometriosis, depression, heart disease, and premature death—diseases that are correlated with the toxics that are emitted in the air in Rubbertown. It has the world’s highest rate of angiosarcoma of the liver, a disease known to be caused by vinyl chloride, which is used by its two PVC plastic production plants.

Chemical policy reform should allow EPA to take a geographic focus to identify chemical “hotspot” communities and allow reduction of identified high risk chemicals from all sources rather than regulating chemicals industry by industry or in the air separately from those same chemicals in the water and in the ground.

During chemical distribution, more people are likely to be injured from spills, fires, and leaks from truck accidents in urban areas. It is not unusual for train cars, presumably full of chemicals, to remain for days in residential areas of Louisville and other EJ communities. Nationally, the most common cause of chlorine release is from truck accidents in urban areas on their way to water and sewage treatment facilities. Chemical policy reform should allow for control of chemical storage and distribution if needed.

Low income people are also more likely to be exposed to certain chemicals during use of those chemicals.  Bisphenol A, an endocrine disrupter associated with diabetes, obesity, breast and prostate cancer and a host of other health conditions, is used in metal can linings.  In low income urban areas, fresh foods are more difficult to find and are often more expensive, therefore people are more reliant on BPA containing canned goods.  Lead tire weights are more likely to fall off the tires in urban areas when cars turn corners or hit potholes. The tire weights are then crushed by other cars and the lead dust can be tracked inside where toddlers can ingest it. Removing toxics from consumer products could reduce disparities in chemical exposure in environmental justice communities as well as reduce resultant health disparities.

Disposal of toxic products and chemicals is another area along the chemical life cycle where environmental justice communities are disproportionately exposed. Toxic Waste and Race at Twenty, released in 2007, demonstrates that hazardous waste sites are still more likely to be located in communities of color and low-income communities. In Connecticut before the 1980s, almost all of the 169 towns had their own town dumps. As the consumer products, and therefore the trash that people threw away, contained more toxic substances, the incidence of contamination of well water from leaching of these dumps increased. In the 1980s the state moved to close down these town dumps and consolidate trash into regional trash-to-energy facilities. These facilities, which are some of the largest point sources of toxics in the state, are mostly located in environmental justice communities. Reducing the toxicity of consumer products will reduce the toxicity of these landfills and incinerators.

In addition to production, distribution, use, and disposal of chemicals, the chemical lifecycle also includes legacy exposures. Legacy exposure is exposure to a chemical after it has gone out of use but has not been properly disposed of or detoxified. Examples of this exposure would be lead poisoning from paint, even though lead has been banned from use in paint since 1978, or Trichloroethylene (TCE) left in leaking underground storage tanks from abandoned industrial facilities located in residential communities, or polychlorinated biphenyls (PCBs) that leaked from old transformers. People are often exposed to legacy toxics from Brownfields and other contaminated properties in environmental justice communities. Chemical policy reform should allow EPA to address legacy toxics, along with all other sources of specified toxics, in overburdened chemical “hotspot” communities.

The environmental justice community supports reform of chemical policy that would eliminate disproportionate exposure throughout the life cycle of chemicals. We believe legislation that updates TSCA should embody three key policy elements:

1. Ensure Environmental Justice
   Effective reform should contribute substantially to eliminating the disproportionate burden of toxic chemical exposure placed on low-income people, people of color, and indigenous communities, as described above. These communities are not only overburdened, but also more susceptible to health effects from toxic exposures from other factors, such as malnutrition and psychosocial stress.
2. Immediately Act on the Worst Chemicals First and Promote Safer Alternatives
   Persistent, bioaccumulative, and toxic chemicals (PBTs) are uniquely dangerous. PBTs should be phased out of commerce except for critical uses that lack viable alternatives.  Exposure to other toxic chemicals, like formaldehyde and chromium 6, that have already been extensively studied should be reduced to the maximum extent feasible. Our communities cannot wait on yet another study on these proven poisons. Green chemistry research should be expanded, and safer chemicals favored over those with known health hazards.
3. Protect All People, and Vulnerable Groups, Using the Best Science
   All chemicals should be assessed against a health standard that protects all people and the environment, especially the most vulnerable subpopulations, including children, workers, pregnant women, and other vulnerable populations. EPA should adopt the recommendations of the National Academy of Sciences for reforming risk assessment. Biomonitoring by the Centers for Disease Control and Prevention should be significantly expanded and used by EPA to assess pollution in people.

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