Author Archives: Elena Craft, PhD

Why Honeycutt is such an alarming choice for EPA's science advisory panel

Michael Honeycutt – the man set to lead the U.S. Environmental Protection Agency’s prestigious Science Advisory Board – has spent most of his career as a credentialed counterpoint against almost anything the EPA has proposed to protect human health.

Fortunately, his lone voice for the Texas Commission on Environmental Quality rarely carried beyond the Lone Star State. Until now.

The EPA science advisory panel Honeycutt will chair is supposed to provide the agency with independent scientific expertise on a wide range of issues. In a highly unusual move, EPA Administrator Scott Pruitt picked the Texan for the job even though he has never been a member of the board.

More than Honeycutt’s inexperience, however, what worries me most is his faulty logic and what this means for science at the EPA.

Honeycutt downplays ozone dangers

A toxicologist by training, Honeycutt has criticized the EPA’s health-based standards for ozone because “most people spend more than 90 percent of their time indoors,” reducing their exposure to the ubiquitous pollutant.

Houston residents know differently. The city’s worst day for lung-damaging ozone this year happened while many people were outside for long hours of cleanup after Hurricane Harvey.

Honeycutt doubled-down on his position that ozone is not harmful to human health in a 2014 interview with the Texas Tribune.

“I haven’t seen the data that says lowering ozone will produce a health benefit,” he said. “In fact, I’ve seen data that shows it might have a negative health benefit.”

Honeycutt’s statement suggests he believes that more air pollution might actually be good for you.

…even though ozone can cause premature death

I am a toxicologist in Texas, too, and here is the truth about ozone: The pollutant can exacerbate asthma, lung disease and heart disease – and even lead to premature death.

The current acceptable limit, recommended during the George W. Bush administration and set under Obama’s in 2015, is 70 parts per billion, a standard that the public health community still believes is too high. The EPA’s own science advisors had recommended a limit as stringent as 60 ppb to protect human health.

Honeycutt spent millions to refute science

In his Texas role, Honeycutt responded to the recommendation by paying more than $2.6 million for research that says tighter ozone rules would cost the state billions of dollars annually with little or no impact on public health.

“Every part per billion that they don’t lower it is millions of dollars,” Honeycutt told the Houston Chronicle. “So we think that the return on investment in this is just phenomenal. Just phenomenal.”

And it’s not just ozone that seems to be a target for Honeycutt. He also has issues with protections against mercury, particulate matter and air toxics.

The reality is, however, that by failing to improve air quality, we’re paying more in health and social costs. This is real money lost on hospital visits, and on missed work and school days.

…and now he’ll steer EPA science

All this matters because Honeycutt, as the board’s chair, will help prioritize which issues the EPA decides to investigate and pick the scientists who review studies and reports before they come to the full board.

My worry is that he will continue down a path that is destructive to public health protections, a well-known pattern within the Trump administration.

We know that clean air and a strong economy go hand in hand – and that claims by industry doomsayers claims are unsubstantiated.

But none of that matters to an administration that scrubs qualified scientists from serving on advisory committees, that eradicates scientific data from websites that do not support the its agenda, and that does not want to be challenged.

Honeycutt’s appointment is yet another attack against science. With American health at stake, we can not stay silent about this latest EPA development.

This post originally appeared on our EDF Voices blog.

Image source: Source: Flickr/Science Democrats.

Posted in Health, Policy, Science| Comments are closed

EPA Safeguards and the Arkema Chemical Plant Disaster – Information You Should Know

Hurricane Harvey over the Gulf of Mexico. Photo: U.S. Department of the Interior

(This post was co-authored by EDF’s Peter Zalzal)

Like many Americans, we’ve been closely following the story about the Arkema chemical plant that was flooded when Hurricane Harvey hit Texas. The resulting explosions there have added a horrifying new dimension to the tragic events in the greater Houston area.

Here’s more information that you might want to know.

The Arkema chemical facility in Crosby, Texas has had previous health and safety violations and has been the subject of enforcement actions.

The Arkema Crosby chemical facility has been the subject of at least two enforcement actions by the Texas Commission on Environmental Quality.

  • In 2006, the facility was subject to penalties because of a fire due to inappropriately stored organic peroxides. The fire led to discharge of 3,200 pounds of volatile organic compounds along with other harmful pollutants.
  • In 2011, the facility was subject to penalties for failure to maintain proper temperatures of the thermal oxidizer.

Gina McCarthy, EPA Administrator under President Obama, strengthened the standards governing preparedness for chemical releases during emergency situations.

In January of 2017, EPA Administrator Gina McCarthy strengthened key provisions of the Accident Release Prevention / Risk Management Program. Those provisions are designed to help prevent and mitigate chemical accidents. The changes included more protective accident prevention program requirements, emergency response enhancements, and enhanced public transparency and availability of information.

Some of these key improvements, which are jointly known as the “Chemical Disaster Rule,” are summarized below (the final rule is at 82 Fed. Reg. 4594.) These protections were slated to take legal effect on March 14, 2017, and the rule required phased-in compliance with its provisions over the next several years. The rule requirements differ depending on whether the facility is classified as Program 1, 2, or 3, with more rigorous and focused requirements applying to Program 3 facilities due to the types of processes at the facility. The Arkema Crosby plant is a Program 3 facility.

  • Accident Prevention Program Improvement
    • Root Cause analysis: The final rule requires Program 2 or 3 facilities to conduct a “root cause analysis” as part of an incident investigation of a “catastrophic release.” The analysis is meant to look beyond immediate causes to help prevent future disasters by uncovering underlying causes in an incident investigation.
    • Third Party Audit: The rule requires Program 2 or 3 facilities to conduct independent third party audits, or to assemble an audit team led by an independent third party auditor, to perform a compliance audit after a reportable accident. Previously, facilities were allowed to perform self-audits. The revision “is intended to reduce the risk of future accidents by requiring an objective auditing process to determine whether the owner or operator of the facility is effectively complying with the accident prevention procedures and practices.” (82 Fed. Reg. at 4,595)
    • Safer Technology Alternatives Analysis: For Program 3 facilities, the rule requires a Safer Technology Alternatives Analysis to identify the practicability of any inherently safer technology identified.
  • Emergency Response Enhancements
    • The final rule requires all covered facilities to coordinate with local emergency response agencies at least once per year to determine how the facility is addressed in the community emergency response plan, and to ensure that local response organizations are aware of the regulated substances at the facility, their quantities, the risks presented by covered processes, and the resources and capabilities at the facility to respond to an accidental release of a regulated substance. (82 Fed. Reg. at 4,595)
    • The rule also requires Program 2 or 3 facilities to conduct notification exercises to ensure that emergency contact information is accurate and complete, and that certain facilities conduct field or tabletop exercises. From the final rule: “Improved coordination with emergency response personnel will better prepare responders to respond effectively to an incident and take steps to notify the community of appropriate actions, such as shelter in place.” (82 Fed. Reg. at 4,595)
  • Enhanced Availability of Information
    • “The rule requires all facilities to provide certain basic information to the public, upon request. The owner or operator of the facility shall provide ongoing notification of availability of information elements on a company website, social media platforms, or through some other publicly accessible means.” (82 Fed. Reg. at 4,596)

Arkema and its industry trade organization, the American Chemistry Council, filed comments objecting to several of these key improvements.

Arkema filed adverse comments on the proposed improvements to the Chemical Disaster Rule, and also endorsed comments filed by the American Chemistry Council (Arkema is a member company of ACC).

Arkema objected to the third-party audit procedure, objected to the safer technology alternatives analysis as burdensome, and expressed concerns about the requirements to share certain information with emergency responders and the public.

Scott Pruitt immediately obliged and suspended the Chemical Disaster Rule improvements.

One of the immediate actions taken by Trump Administration EPA head Scott Pruitt was to suspend these key improvements to Chemical Risk Program.

On February 28, 2017, an industry coalition including the American Chemistry Council, the American Petroleum Institute, the U.S. Chamber of Commerce, and the Utility Air Regulatory Group asked EPA to reconsider the Chemical Disaster Rule.

Administrator Pruitt quickly obliged by convening a reconsideration proceeding on March 13, 2017 and suspending the Rule for 90-days on March 16, 2017. Both of these initial actions to halt the rule took place without any public process, a pattern continued in many of Pruitt’s actions as EPA Administrator.

Subsequently, on June 14, 2017, Pruitt issued a rule suspending the requirements until February of 2019. Pruitt’s decision to suspend these protections disrupted the implementation of the rule.

Administrator Pruitt’s suspension is now being challenged in the U.S. Court of Appeals for the D.C. Circuit, with a preliminary decision yesterday denying the petitioners’ motion for a stay but granting expedited briefing on the merits. Air Alliance Houston is one of the organizations challenging Pruitt’s damaging actions. 

A closer look at the Arkema facility in Crosby, Texas.

The Arkema facility in Crosby, Texas is a Program 3 facility and is required to submit a Risk Management Plan under the Chemical Disaster Rule.

The envirofacts webpage for the facility notes that the last plan was submitted in June 2014, pursuant to the less stringent requirements that were then in place.

EPA does not publicly post online Risk Management Plans for facilities but they are available for review in the federal reading rooms. On August 31, 2017, EDF examined the 2014 Risk Management Plan for the Arkema facility. According to Arkema’s documents on file:

  • The Arkema facility manufactures liquid organic peroxides, which are primarily used in the production of plastic resins, polystyrene, polyethylene, polypropylene, PVC, and fiberglass.
  • There are two substances on site that are present at or above the minimum threshold quantities for a Risk Management Plan – 85,256 pounds of 2 methylpropene (a flammable substance), and 66,260 pounds of sulfur dioxide (a toxic substance). Both are present in levels that make the facility subject to Program 3 requirements.
  • The site conducted a process hazard analysis on October 31, 2013 and indicated that any errors identified would be corrected by October 30, 2015. The 2013 hazard analysis identified concerns, including: equipment failure; loss of cooling, heating, electricity;  floods (flood plain); hurricane; other major failure identified: power failure or power surge

There have now been explosions reported at the Arkema facility and 15 police officers were taken to the hospital after inhaling fumes from the chemical plant. Because of limited air monitors operating in the region, we do not know the pollutants or their concentrations in the surrounding air.

EPA Administrator Scott Pruitt has led an unprecedented rollback of public health and environmental safeguards for our communities and families.

This is one of many damaging actions by EPA Administrator Pruitt to roll back fundamental safeguards under our health and environmental laws. Pruitt’s actions imperil our communities and families, and increase risks across our nation.

The explosion at the Crosby chemical facility is a terrible tragedy. It is incumbent on those who manufacture and use these dangerous chemicals — and it is the solemn duty of policymakers entrusted with protecting the public – to carry out their responsibilities under our nation’s public health and environmental laws to protect all Americans.

EDF is urging EPA Administrator Pruitt to immediately reinstate the critical Chemical Disaster Rule safeguards that he has suspended, and we are asking all Americans to join us. Please contact EPA and tell them you support these protections.

Posted in EPA litgation, News, Policy| Read 2 Responses

Study: Clean air makes children's lungs stronger, healthier

Source: Flickr/Alec Couros

We’ve known for a long time that breathing polluted air can make you sick. Now there's more evidence that breathing cleaner air can make you better.

The New England Journal of Medicine published new research this month detailing improved lung function in children that breathe cleaner air.

The Southern California study received major attention.

That’s not surprising – as it provides compelling evidence that efforts to improve air quality over the years have been successful in improving children’s health.

The study followed three populations of children, aged 11 to 15, for a period of four years. This age group was chosen because children’s lungs develop rapidly during this stage.

In all, the study examined more than 2,100 children in five distinct California communities.

The report found that the greatest improvements in lung function were seen with declining levels of particulate pollution, also known as soot; and of nitrogen dioxide, a fuel combustion byproduct.

And potentially the best benefit of all: Cleaner air doesn’t just lead to healthier lungs during childhood because the benefits last a lifetime. Children with healthier lungs grow up to be adults who have a lower risk of premature death and other serious health problems.

The bottom line?

We need and deserve policies to secure a wide range of protections for cleaner, healthier air. Fighting for stronger health protections against smog and defending the first-ever national standards to reduce mercury pollution and other air toxics from power plants are good places to start.

Please join us in giving future generations the best possible chance, today and tomorrow, for healthy lungs.

This post originally appeared on our EDF Voices blog.

Posted in Health, Policy| Comments are closed

Clearing the air: Why we need strong smog standards

Smog over Dallas Skyline. Source: WikiCommons

This week and next, the U.S. Environmental Protection Agency (EPA) is holding hearings across the country on the proposed updates to our national smog (ground-level ozone) standards from their current level of 75 parts per billion (ppb) to 65 to 70 ppb. Exacerbated by the combustion of fossil-fuel power plants and car exhaust, ground-level ozone is the single most widespread air pollutant in the United States and is linked to severe respiratory health outcomes. Ozone poses a great threat to public health across America.

What is the issue?

Smog is a dangerous air pollutant that is linked to premature deaths, asthma attacks, and other serious heart and lung diseases. It is estimated that more than 140 million people live in areas with unhealthy levels of smog pollution. The very air we breathe is putting us at risk for adverse health outcomes such as premature deaths, increased asthma attacks and other severe respiratory illnesses, as well as increased hospital visits.

Does the proposal go far enough?

While EDF supports EPA’s proposal to strengthen these critical health protections, we believe that going even further, to 60 ppb, would provide the strongest protections for Americans and would be in line with what leading medical associations like the American Lung Association recommend.

Can this be achieved?

America has decades of experience innovating and cost-effectively cleaning up the air – and we can do so again to reduce smog pollution. From the Tier 3 tailpipe standards to the proposed Clean Power Plan, which would set the first-ever national limits on carbon pollution from existing power plants, the air across the country is becoming cleaner, showing us that we can have healthy air and a strong economy.  In some American cities, we estimate that ozone is already declining each year thanks to important air regulations such as the Cross State Air Pollution Rule, but there is still work to do.

What can you do?

Voice your support for strong clean air standards! A strong smog standard will help ensure Americans know whether the air they are breathing is safe, and will drive much-needed pollution reductions. Our communities, our families, and our children are counting on EPA’s leadership in setting a strong ground-level ozone standard.

This post was adapted from an earlier post on EDF’s Texas Clean Air Matters blog

Posted in Cars and Pollution, Health, Policy| Read 1 Response

5 reasons EPA is right about tougher smog standards

(This post originally appeared on EDF Voices)

Robert S. Donovan

The Environmental Protection Agency last week released much-awaited, tighter standards for smog pollution, common-sense protections that will save lives and safeguard human health from one of the nation’s most ubiquitous air pollutants – ozone.

As expected, it took but a few hours before critics lashed out, while ignoring key facts behind EPA’s proposal. Here are five reasons EPA is on the right track:

1. The current standard doesn’t do enough to protect human health

About half our population, some 156 million Americans, areat risk from smog, or ground-level ozone, because of age, health conditions, or the work that they do. They include more than 25 million people with asthma, 74 million children, 40 million senior citizens, and nearly 17 million outdoor workers.

Our current standard of 75 parts per billion (ppb) doesn’t adequately protect human health.

EPA’s new proposal, issued under a court-ordered deadline, is a step in the right direction – even if it doesn’t, in our view, go far enough.

Consider this: The proposed 65 to 70 ppb limit would prevent between 320,000 and 960,000 asthma attacks in children and up to 1 million lost school days. It would also prevent up to 180,000 lost work days and an estimated 750 to 4,300 premature deaths.

2. Clean air is good for the economy

By law, the issue of cost cannot be factored in when setting a health-based standard. But even if costs were considered, the conclusion remains that clean air is good for the economy.

Since 1970, the benefits of the Clean Air Act have outweighed costs by 30 to 1, and a similar trend is expected to hold true also for the proposed smog standards.

In fact, in Texas, the state agency charged with protecting public health and natural resources, concluded that Houston’s gross domestic product increased as smog concentrations dropped.

3. EPA’s action is backed by science

The proposed standard, set to be finalized in October 2015, has been recommended repeatedly by EPA’s Clean Air Scientific Advisory Committee, an independent panel of leading scientists, as well as by medical and public health professionals nationwide.

There’s overwhelming evidence showing that smog affects millions at the existing standard of 75 ppb.

In fact, EPA is also seeking comments on a health standard that would limit exposure to 60 ppb – a standard that would provide the strongest protections for Americans and be in line with what groups such as the American Lung Association recommend.

4. Smog pollution measures are nothing new

The United States has already taken steps over the past few years that help to cost-effectively reduce smog pollution and help restore healthy air.

Those protections include the Tier 3 tailpipe standards, supported by the U.S. auto industry, which will slash smog-forming pollution from new cars beginning in model year 2017. Meanwhile, EPA’s proposed Clean Power Plan  will reduce smog-forming pollutants from power plant smokestacks nationwide.

These standards will work in tandem to cut pollution and spur new innovation. America has shown time and time again that we can innovate and come up with solutions for industry that make new regulations affordable.

5. It’s time we catch up with other developed nations

Once a leader in environmental protection, the U.S. now lags behind other developed and developing nations in the protectiveness of air quality standards for smog.

Numerous industrialized countries have adopted ozone standards that are far more protective than the current standard in the U.S. The European Union’s limit today is 60 ppb and Canada’s is 63 ppb, for example.

Some of these countries are doing as well, or better, economically than the U.S.

For this and all other reasons mentioned here, EPA’s new smog standards will help us breathe easier.

Posted in Clean Air Act, Health, Policy| Read 1 Response

Soot Pollution Limits Unanimously Upheld in Court, Continuing Clean Air Victory Streak

Last week, the U.S. Court of Appeals for the D.C. Circuit unanimously upheld the Environmental Protection Agency’s (EPA’s) particulate matter (soot) pollution standard, ruling that EPA’s decision to strengthen the standard in 2012 was firmly grounded in science and the law. The ruling also upheld EPA’s new requirement that states install air quality monitors near heavy traffic roads, where soot pollution levels can spike. The court’s decision is the latest in a string of legal victories for critical health protections on air pollution.

When fossil fuels are burned in an automobile or power plant, they release soot pollution, very fine, ashy particles less than one tenth the width of a human hair. These particles are so small that the air can carry them for long distances. When inhaled, soot particles penetrate deep into the lungs, where they can cross into the bloodstream via the path normally taken by inhaled oxygen. Exposure to soot pollution can inflame and alter our blood vessels, cutting off the oxygen supply to our heart and brain, leading to a heart attack, stroke, or other serious cardiac event.

The Clean Air Act mandates that EPA revisit its standards on criteria air pollutants – like soot – every five years, so that clean air standards can keep pace with the latest understanding of health science. Since EPA established its 2006 soot standard, hundreds of scientific studies have shown that particle pollution could cause adverse health effects—even in cities that met EPA’s established limits. Based on this information, in 2012, EPA strengthened its soot pollution standard to protect public health. Furthermore, EPA called for states to implement roadside air quality monitors to ensure the standards would likewise protect individuals exposed to significant near-road emissions.

The National Association of Manufacturers and the Utility Air Resources group, a coalition of large power companies and coal companies, filed legal challenges to EPA’s new soot standards, arguing that the 2006 standard was sufficient to protect public health. But the science doesn’t lie. In the D.C. Circuit Court’s unanimous decision, Judge Brett Kavanaugh wrote:

Here, we can be brief: Petitioners have not identified any way in which EPA jumped the rails of reasonableness in examining the science. EPA offered reasoned explanations for how it approached and weighed the evidence, and why the scientific evidence supported revision of the National Ambient Air Quality Standards.

EPA was reasonable in their interpretation of the science—the polluting companies, on the other hand, could not present a credible argument against the updated soot pollution standards, or the need for roadside air quality monitors.

This important victory is critical to protect our families and communities from harmful soot pollution, and it is clear that EPA’s implementation of the Clean Air Act stands up to both legal and scientific scrutiny.

This post was adapted from EDF’s Texas Clean Air Matters Blog

Posted in Cars and Pollution, Clean Air Act, Health| Read 3 Responses
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