EDF outlines steps for EPA to strengthen its plan to assess risks to frontline communities

Maria Doa, Senior Director, Chemicals Policy

This week Environmental Defense Fund (EDF) filed comments on EPA’s plan to assess the risks to frontline communities from nearby releases of chemicals to the air and water. The EPA’s proposal is an improvement from the previous administration, which failed to follow the requirements of the Toxic Substances Control Act (TSCA) and consider air and water releases and other significant exposure pathways for residents in “fenceline” communities near manufacturing or disposal facilities.

As we made clear in our comments, however, the agency’s planned screening approach is too narrow in scope and would underestimate the real-world risks faced by many communities.

Residents of these frontline communities often face exposure from multiple sources or higher levels of exposure than the general population, or both combined. Failing to consider the full scope of these risks could hamper EPA’s ability to craft protective rules that reduce the risks those living near industrial facilities.

We outline several areas where EPA can strengthen its screening approach, including:

  • Incorporate important environmental pathways of exposure. These pathways include exposures from land disposal, groundwater, plume deposits and vapor intrusion into homes and businesses, consumption of contaminated food, and accidental spills and other releases.
  • Aggregate multiple exposure sources to a chemical. This includes considering exposures to the same chemical from different industrial facilities, which tend to be clustered together; from multiple pathways, such as exposure to a chemical from air and groundwater sources; and from being a member of more than one relevant population, such as a person who both lives near and works in the same facility.
  • Aggregate exposures and risks across different chemical applications or uses. This would capture more realistic scenarios in which community residents may be subject to combined risks from two or more chemical uses, such as someone who lives near an industrial facility and is also next door to a dry cleaner that emits a given chemical.
  • Integrate real-world monitoring data. EPA has the authority under TSCA to require chemical companies to develop data or provide existing information. It should use its authority to acquire air, water, and soil monitoring data to better assess risks for frontline communities near industrial facilities.

Going forward, EPA also needs to improve its efforts to reach out to frontline communities for feedback. Due to historically discriminatory practices in facility siting, planning, and housing policies, these neighborhoods are disproportionately communities of color and low wealth. Community-based input is critical for meeting the Biden administration’s environmental justice goals and is an essential component for building local trust in EPA’s actions and intentions.

Finally, EPA should not wait to incorporate these needed changes. The agency has said the proposed screening approach is “version 1.0” and will be replaced by an updated version in the future. However, EPA has also indicated it plans to use the current version to make important risk management decisions and to determine fenceline exposures to at least six toxic chemicals that the agency is currently reviewing.

At a minimum, EPA should include in version 1.0 all important pathways of exposure, the aggregation of exposures, and robust data sources to reflect how individuals living in a frontline community are actually exposed to these chemicals.

The agency should also use this opportunity to move toward a more cumulative approach for assessing risk to better protect communities at greater risk.

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