Deep Dives: Environmental Health Policy

Health data needs to inform targeted environmental justice initiatives

Key Findings and Recommendations 

  • Air pollution results in a large burden of childhood asthma across the country, and this burden is disproportionately borne by people of color.
  • More than $100 million in grants from the Environmental Protection Agency is available for environmental justice initiatives, but targeting programs to alleviate the health impacts of air pollution to overburdened communities requires local-level health information that is often not readily available.  
  • We recommend health advocates and researchers work with local and state public health departments and impacted communities to access existing fine-scale data where available.

In the past, the lack of neighborhood-scale data on baseline disease rates, pollutant concentrations and children’s asthma has made it difficult to determine which U.S. communities bear the highest health burden from air pollution. Disparities in pollution exposures have been routinely underestimated. Generating more fine-scale data, together with advances in hyperlocal air monitoring, will make visible the disparities in exposure to air pollution across and within neighborhoods, allowing us to target mitigation and prevention efforts for maximum benefit. 

We now have an opportunity to make significant progress towards identifying, prioritizing and addressing the harms faced by the most burdened communities. EPA has made available over $100 million dollars for grants to advance environmental justice, including health impact assessments. Grant recipients can use the funds to obtain health information at the neighborhood level, data essential for identifying communities with the highest burden of air pollution health impacts. The application deadline is April 14, 2023. 

Pollution and racism 

Using new air monitoring techniques, advances in modeling, and community-based participatory research, studies confirm that neighborhoods which have experienced historical racism also experience higher levels of air pollution.

Decades of discriminatory and racist policies, practices and disenfranchisement have resulted in the disproportionate exposure to pollution sources in communities of color, along with disinvestment in housing and economic opportunities in these communities. Communities of color and areas of low wealth therefore face exposure to higher levels of air pollution and are more vulnerable to that air pollution, resulting in heavier health burdens borne by families.  

Air pollution data is only half of the story 

While air pollutant exposure is important in determining the effect of that pollutant on the health of a community, social factors and existing disease burden and risk play a large role in the impact that pollutant will have on the total health burden attributable to a pollutant in a community.  

Existing disease burdens and risks in populations are reflected in “baseline disease rates,” a key public health metric documented by public health agencies. Baseline disease rates vary within cities, but those rates are rarely made publicly available for use in risk assessment. 

Gaps in baseline disease data availability limit the ability of health impact assessments to determine which communities have existing vulnerabilities to the harmful effects of air pollution. For example, while studies of pediatric asthma attributable to nitrogen dioxide, a traffic-related air pollutant, have estimated there are 200,000 affected children living in American cities, these studies have relied on national-level estimates of asthma incidence. These national-level estimates hinder the ability of researchers to determine which areas within cities are experiencing the highest burden of asthma attributable to asthma. 

Local-level health data is needed to identify risks to overburdened communities  

The public health information available from city to city and within cities is a mix of fine-scale data (ZIP code level) and coarse-scale data (ZIP3 – aggregated data based on ZIP code information, roughly the size of counties.) The assessment of health risks, factors and outcomes can vary greatly depending on which level of data is used. 

Studies have repeatedly shown that using fine-scale baseline disease rates can make a profound difference when mapping the spatial distribution of health burdens attributable to air pollutants and on the ability to quantify disproportionate impacts in disadvantaged populations. For example, in an analysis of within-city air pollution risks in the San Francisco Bay Area of California, we found the highest census block group baseline mortality rate was 12 times higher than the rates in the census block group with the lowest rates, while the highest county rate was only four times greater than the lowest county mortality rate.

Lack of fine scale data leads to unreliable analysis 

Our work in New Jersey highlights the pitfalls of using only coarsely-resolved spatial data in identifying those communities that are at highest risk of the health burdens of air pollution. An analysis of the impact of pollution in that state found that 18,000 asthma emergency room visits by children could be attributed to fine particle pollution and 70% of those impacts were among communities of color (Asian, Black and Native American) and Hispanic populations.

Comparing the results using coarse-scale and fine-scale data, we found that:

  • Analysis using coarse-resolution emergency room visit information overestimated the burden to white populations. It underestimated the burden to people of color by as much as 90%
  • Using fine-scale data, we found emergency room visits for the ZIP code with the highest burden to be 1.5 times higher than the highest burden estimated using coarse-resolution data. 
  • We also found that using fine-scale data revealed double the variation between the ZIP code with the highest risk of PM-attributable visits and ZIP codes with the least risk of PM-attributable visits. Variation allows us to observe the relative disparities in risk within a community that are not otherwise observable with coarse-scale baseline disease data. 

The use of coarse-resolution (ZIP3) asthma emergency department visit data may underestimate PM-attributable asthma burdens (number of cases per 10,000) among non-white populations when compared to fine-scale (ZIP) data. Red shows communities where coarse-resolution health data underestimates risks.

Local-level health information can help EPA and other funders to identify and direct resources to the communities that need it most, which are too often communities of color facing legacy injustices. 

Our work in the Bay Area of California highlights the need for fine-resolution data on baseline disease rates, as pollutant concentrations alone were unable to capture the variation of air pollution health risks within Oakland.  

The maps shown in Figure 2 are of the neighborhoods of West Oakland. Looking only at the spatial distribution of the highest pollutant concentrations (A), the area of highest risk appears to be the truck traffic corridor of I-880. However, when we incorporated census block group baseline disease rates (B), provided by the Alameda County Public Health Department, we found that the area of highest risk, and therefore where the largest emission reductions could result in the largest reduction in health burden, was another area of West Oakland where both baseline mortality rates and pollution levels were elevated.  

Pollutant concentrations and county baseline disease rates alone would not have revealed this vulnerable neighborhood. A better understanding of pollution hotspots can help direct federal funds intended to address long legacies of pollution burdens to communities where they’re most needed. 

West and Downtown Oakland. The map on the left (A) shows the spatial distribution of pollutant concentrations, with high concentrations highlighted in the blue circle near major roadways. The map on the right (B) shows the spatial distribution of air pollutant attributable health burdens when the spatial distribution of underlying disease patterns are taken into consideration. The area of highest air pollutant attributable health burdens in map (B) is highlighted in the blue circle.

Ways to expand and improve local-level health data 

Past investment in satellite-derived estimates and local air pollution monitoring has resulted in making exposure disparities visible. Similar investment is required now for developing fine-scale data on baseline disease rates, which will enable identification of communities with the highest air pollution-attributable health burdens.  

Mechanisms currently exist for developing more fine-resolution data on baseline asthma emergency department visits. As part of the analysis in New Jersey described above, we purchased discharge-level emergency department visit data for New Jersey from 2016 to 2019 from the Healthcare Cost and Utilization Project’s State Emergency Department Database (HCUP SEDD). We urge the Agency for Healthcare Research and Quality, which manages the HCUP SEDD, to develop baseline asthma emergency department visit datasets and that the Agency update these datasets annually and make them publicly available. 

We recommend that health advocates and researchers work with local and state public health departments to access existing fine-scale data where available. We have found that local health departments often have the data needed but lack the resources to dedicate staff and expertise to process and analyze the information. As an example, EDF has had success working with the Alameda County Public Health Department to develop mortality rates at the census block group level. Other impediments to developing baseline disease rates include lack of funding and concerns about privacy. 

Deadlines approaching for funding opportunities to develop local-level health data 

EPA is accepting environmental justice grant applications through April 14, 2023 through two avenues: the EJ Collaborative Problem-Solving Cooperative Agreement Program (EJCPS) and the Environmental Justice Government-to-Government (EJG2G) program. 

While both grant programs are relevant to the use of local-level health data, the Government-to-Government grants allow community-based organizations to partner with their local health department on use of local-level data in health impact assessments. This can help alleviate the problem discussed above regarding inadequate staffing and expertise at local health departments.  

Of the five broad categories listed in the funding announcement, use of local-level health data fits under the category “community-led air and other pollution monitoring, prevention, and remediation, and investments in low- and zero-emission and resilient technologies and related infrastructure and workforce development that help reduce greenhouse gas emissions and other air pollutants.” 

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TSCA And The East Palestine Ohio Train Derailment Are Related–Here’s How

By Maria Doa, PhD, Senior Director, Chemicals Policy, and Lauren Ellis, MPH, Research Analyst

SUMMARY: We explore the connection between the Toxic Substances Control Act (TSCA), the risks of toxic chemicals from transportation accidents, and the pathway to better protect communities.

Last month, a Norfolk Southern freight train hauling several railcars carrying toxic chemicals derailed in East Palestine, Ohio. The crisis not only put several surrounding communities at risk of chemical pollution and negative health outcomes, but also highlighted the ongoing concerns faced by environmental justice communities that live with chemical pollution every day. There are significant gaps in the ways that the risks of chemical exposure are evaluated.

The Ohio train derailment is just the latest example of how accidents involving highly toxic chemicals can have harmful impacts—both short- and long-term—on communities’ health and welfare. By expanding evaluations to include the risks of chemicals at all stages of the chemical lifecycle, EPA can better protect communities.

Train hauling tanker cars full of chemicals

Immediate Impacts

The train derailment has put members of the community in East Palestine at significant risk for a range of health problems and is impacting their livelihoods and welfare. When the train derailed, it released vinyl chloride (known to cause cancer in humans) and other toxic chemicals into the surrounding air, water, and soil. Vinyl chloride is used to make plastic polyvinyl chloride (PVC), which is used in a wide range of products, including plumbing pipes and shower curtains.

Following the derailment, more than 115,000 gallons of vinyl chloride were burned. Burning vinyl chloride produces hydrogen chloride and phosgene, extremely toxic and corrosive chemicals.

In the aftermath of the derailment, residents have reported experiencing a variety of immediate health problems, including new reports of chemical-induced bronchitis. Because of the potential health risks, people are living in hotels miles away from their homes, families, and friends; in some cases, they have pulled their children out of school.

In addition, local waterways were blocked off, private wells were shut tight, and residents report that they still smell chemical residue in the air. Since the incident, more than 43,000 fish, crustaceans, and amphibians are known to have died.

And these are just the immediate effects. It may be years until we have a better understanding of the long-term impacts of exposure to these toxic chemicals.

Strengthening TSCA Reviews Could Better Protect Communities Like East Palestine

TSCA requires EPA to assess available information on the hazards and exposures of chemicals throughout their lifecycles; this includes a requirement that EPA specifically consider a chemical’s domestic production, import, processing, distribution in commerce, use, and disposal. “Distribution in commerce” includes transporting chemicals.

TSCA also requires EPA to consider the duration, intensity, frequency, and number of exposures when assessing the risk of a chemical. But so far, EPA has yet to fully embrace the tools in the reformed chemical safety law when it comes to assessing the risks toxic chemicals pose during transportation.

EPA does not assess the risks from the distribution in commerce of toxic chemicals in its risk evaluations because it considers current hazardous materials transportation regulations as sufficient to prevent chemical exposures. Thus, EPA did not quantify exposures and risks from spills, leaks, and other releases from transportation incidents but concluded there is “no unreasonable risk” from distribution in commerce of the first 10 chemicals assessed under reformed TSCA.

In our recent comments on the revised risk determinations for the first 10 chemical to undergo risk evaluation under reformed TSCA, we questioned EPA’s conclusion that distribution in commerce does not present an unreasonable risk. We suggested an approach that is more reflective of the risks that communities face.

In response, EPA stated that exposures from the distribution of chemicals in commerce would be minimal “given the fact that these chemicals are transported according to existing hazardous materials transportation rules.”  EPA did not share their reasoning of how transportation incidents involving the first 10 chemicals—including at least 28 incidents involving methylene chloride and six incidents involving TCE in 2022 alone—result in minimal risks to communities, nor how existing transportation regulations mitigate those risks.

We Can Do More to Protect Communities

People can be—and are—exposed to toxic chemicals at all stages of the chemical lifecycle, from spills, leaks, and other transportation incidents to chemical facility releases. The exclusion of these types of releases and exposures underestimates the risks faced by communities located near the site of these preventable accidental releases of toxic chemicals.

This needs to change.

To accurately assess chemical risk under TSCA, EPA should consider data on spills, leaks, and releases from derailments, collisions, and other transportation incidents in its risk evaluations. These releases and exposures simply cannot be ignored.

Also posted in Air pollution health effects, Chemical exposures, Environmental health, EPA, Policy, Safer chemicals, Science, TSCA / Authors: , / Leave a comment