Risk Assessment

Public Health Implications of Hazardous Waste
Sites and the Superfund Program

PROBLEMS IN DETERMINING HEALTH RISKS

1. Risk Assessment
   A. Risk is an arbitrary designation of what is acceptable. The person making this value judgement is not the person who is being affected.
   
   B. Risk assessments, whether for carcinogens or non-carcinogens, do not consider synergistic effects of exposures to multiple chemicals.
   
   C. Risk Assessments do not take into account multiple exposures or chronic exposures over a long period of time, such as is the case at Superfund sites.
   
   D. Risk assessments on non-carcinogens are very poor, because they usually only involve studies of acute exposure, not chronic exposure.
   
   E. Risk assessments do not take in account the totality of the environment, ie. age, nutrition, physiological state, genetic background (makes some populations even more sensitive), likelihood of getting early diagnosis and treatment, ability to have regular medical and preventive care, etc.
   
   F. Risk assessments do not take in account the effects on people who have become hypersensitive as a result of long-term exposure.

2. Modeling
   
   A. Modeling studies can reveal some information, but one must be careful about relying too heavily on them. A model is only as good as the data input. It is difficult for the person doing the modeling to be fully aware of all of the variables.

3. Epidemiological Studies
   
   A. Population size is a big factor in studies of this type, and rarely do Superfund communities have the population size to reach a statistically significant conclusion. It would seem that several Superfund and other chemically exposed communities could be grouped together and compared. My experience has been that communities exposed to chemical (it does not matter too much what they are) share some common symptoms. They include an increase in asthma and other respiratory problems, immune system disorders, reproductive and developmental disorders, and neurological disorders.

4. Direct Measurements of Contaminants
   
   A. Interesting, and perhaps even useful information can be obtained by measurements of the environmental media, but again, it should not be relied on too heavily unless an effective Continuous Emission Monitor (CEM) is in place. The levels of chemicals in the environment from chemical plants and Superfund sites vary widely over a period of time.
   
   B. Biomarkers show a lot of promise as indicators of exposure, but still too little is known in this field to test their reliability.

5. Primary Care Providers
   
   A. Special training of primary care providers is certainly needed. However, in a given community, people may use many different doctors in different geographical areas. Therefore, it will be difficult for these different doctors to recognize an "epidemic" of environmental health problems.

6. Emergency Removals
   
   A. Emergency health removals are very controversial! EPA seems to drag its feet and make all kinds of excuses why emergency removal is not necessary. One of the biggest problems with the Superfund process is the excessive exposure of people during the remediation. A little common sense and sensitivity is badly needed! People in Carver Terrace had to sit on top of a Superfund site for years before EPA begrudgingly made some meager funds available to remove the citizens. Unfortunately, for some citizens, the relocation came too late. People at the Rheichold Brothers site in Columbia, MS are within 10-15 feet of the Superfund site as chemicals are being removed with the concomitant release of chemicals to the air. Families in Alsen still live across the street and are being exposed to chemicals from the Petro Processors Superfund site. All of these people have been exposed for years. They are still being exposed, and EPA and ATSDR argue that their exposure levels are acceptable, and not health threatening.
   
   B. Superfund Reauthorization needs to have a provision for mandatory, automatic relocation (either temporary or permanent) of people within a certain minimum distance of superfund sites. This distance can be calculated on the basis of the types of concentrations of the chemicals known to be at the site, the extent of offsite migration, the likelihood of volatilization, and other factors. The decision to relocate, if it errs, must be on the side of caution to protect human health.

7. ATSDR
   
   A. ATSDR needs to be totally dismantled and restructured from the ground up, or done away with altogether. Its record of performance is so poor and riddled with biased studies as to have totally lost the confidence of the citizens it seeks to serve.
   
   B. If ATSDR is preserved, it needs to be a separate entity. It should receive its funding by congressional appropriation, and should not come under the umbrella of CDC.
   
   C. Any studies conducted by ATSDR or other agency should undergo a thorough peer review, with unaddressed criticisms attached to the final report. A community representative and a technical advisor of the community should be a part of this peer committee.

In summary, science is too limited in its knowledge of the effects of toxic chemicals on the long term health of people, particular, long-term, low-level exposures or multiple acute exposures to use existing standards of risk. Decisions should be made based on exposure. Health effects need not be proven by community. An ultra-conservative, cautionary approach should be used that is protective of human health and environment.

Center for Community Action and Environmental Justice (CCAEJ)
PO Box 33124 * Riverside, CA 92519
Phone (951) 360-8451 * Fax (951) 360-5950
Website: http://www.ccaej.org
E-Mail: admin@ccaej.org