Good afternoon. I'm Marilyn Howarth. I'm from the Center of Excellence in Environmental Toxicology at the University of Pennsylvania's Perlman School of Medicine. This seat is a P30 Environmental Health Sciences Core Center whose mission is really to do research in environmental health. We also do community engagement and reach out to regulators and legislators to do policy development to improve environmental health in our region. I'm joined with me by my colleague, Adrian Wood, who you'll hear from in just a few moments. We have no financial disclosure or conflicts of interest to report. I wanted to start today with environmental justice. Environmental justice, according to Robert Bullard, someone who has been researching in this field for decades and probably is the foremost authority on this topic, Robert defines it as environmental justice demands that everyone is entitled to equal protection and equal enforcement of our environmental health, housing, land use, transportation, energy, and civil rights and regulations. It's very aspirational and I wish I could say that we were somewhere close, but as you all know, we really aren't. In the United States and through much of the world, we have a fair amount of environmental injustice. Communities of color have more environmental hazards, industry waste facilities, and fewer environmental amenities like parks and green space, and in fact, often have inadequate access to decision making. Although environmental justice communities themselves knew about the circumstances far before any academic researchers started to work on them, they took it upon themselves and created in 1987 the very first research project in this area called Toxic Waste and Race, and it was done by the United Church of Christ, not the University of Pennsylvania, not Stanford, not the University of Illinois, the United Church of Christ. Fortunately, the rest of us recognized that this was a topic that was important to similarly research, but their early studies found that race was the single most significant predictor of where hazardous waste facilities were located in the United States. Fast forward to more recently, and we still find that there is substantial evidence of environmental injustice, including this report showing 70% of Superfund sites are located within a mile of federally assisted housing. Our topic today is largely around air pollution, so I wanted to talk a little bit about air pollution as a burden and a greater burden for people of color. More globally, more than 125 million Americans are exposed to unhealthy air, and as you know, certain of us have some vulnerabilities, the young, the older populations, people with pre-existing conditions, and pregnant people. People of color experience the greatest burden of air pollution. It's important to recognize why. There are a number of sources of air pollution, and environmental justice communities are often burdened by all of them. The industry, energy sources, transportation, all of these sectors are often co-located in environmental justice communities. The cumulative effects of these exposure lead to disparities in environmental justice communities that we can and have documented over many years. Just thinking about asthma, heart disease, dementia, cancer, and low birth weight, we can put together the air pollutants that are both, for which there are standards like nitrogen oxides, sulfur oxides, ozone in particulates, as well as those for which there are no standards, the 187 recognized hazardous air pollutants, those recognized by the EPA. So how do we monitor air? First of all, the Clean Air Act specifies where EPA monitors are across the country, and they specify them with the goal of understanding what our regional air pollution is. So there are very few. I use this example of Philadelphia, and relatively Philadelphia has more than many other areas. There are large swaths, many counties in Pennsylvania with no air monitors at all. In fact, very few of these monitors are measuring hazardous air pollutants. Only the four circled ones in Philadelphia do. So very few of the air monitors actually measure hazardous air pollutants, and they're sparsely distributed. There are no specific standards for hazardous air pollutants, just as there are standards for particulates, standards for ozone. We do not have standards for these hazardous air pollutants. And in fact, the way they're regulated is through the permitting process that goes through the State Department of Environmental Protection. So those state departments actually write permits that allow a certain amount of hazardous air pollutants to enter the air and be emitted in those places. And the permitting process does not need to incorporate how many other permitted industries are in the region. And in fact, they don't incorporate that. So the regulators set these permits based on risk assessment, for sure, a risk assessment process. But the standards are set that focus on just one chemical, don't consider the multiple other chemicals that may have similar impacts on people, as well as the other sites for which they're permitting. And so there is no requirement for this regional or cumulative approach. And as you know, industry does tend to concentrate in environmental justice communities for often reasons of cheap land, among others. So let's think of that risk assessment approach as it allows for an acceptable risk of one ton of benzene to be emitted by this one industry in an area. So that permit is given. Well, what about when all of these other industries move into that very same place and each of them is given a permit to emit one ton of benzene? So now we have 12 times the acceptable risk of benzene in this one community. So I think you see where we're going with this. There are lots of reasons why we see our regulatory process as not being protective enough of all people. And we'd like to use ethylene oxide as a hazardous air pollutant example of how this plays out for communities. And really, even if your community is not mentioned, as we talk about ethylene oxide across the country, the exact same scenario is playing out for other chemicals that are relevant in your communities. So with that, I will turn the presentation over to Adrienne Wood, who honestly did the lion's share of this work, and ask her to take it from here. Adrienne? ADRIENNE WOOD Thank you. So we first started this project back in 2018, and we first got introduced to this topic when we came across data that showed that Lehigh County, which is located just 60 miles north of Philadelphia, where we are now, had the fourth highest estimated cancer risk in the country. And this was shocking to us, because we work in this area, and we had never heard of this. We didn't know anyone working on this. And so we wanted to see what was going on here. And so the data we saw was from the EPA's National Air Toxics Assessment. And they release this every few years, and they use emission data from all sources across the United States to estimate cancer risks, and also non-cancer health effects for every census tract in the United States. And so the last one was released in 2018, and it was based on data from 2014. And what it showed as a whole was that cancer risk due to air pollution had decreased across the United States. But some communities had seen very drastic increases in their estimated cancer risk due to toxic air pollution. One of them was Louisiana, in this region between Baton Rouge and New Orleans. One was in Chicago, just south of Chicago in a suburb. And then another one was Lehigh County, in Allentown, just north of Philadelphia. And so the reason for these hotspots was due to ethylene oxide. Ethylene oxide is a gas that has been used for many purposes in the United States since the early 1900s, including use as a sterilization agent for medical equipment. And back in 1990, the International Agency for Research on Cancer, which is part of the WHO, classified ethylene oxide as a known human carcinogen due to links to lymphomas, leukemia, and breast cancer. And this was through inhalation. But it wasn't until 2016 that the EPA updated their classification of ethylene oxide to a known human carcinogen. And so due to this update in classification, the risk factor that they used to calculate these cancer risks was updated. And so when the data came out in 2018, it showed all these elevated cancer risks due to ethylene oxide in these communities that are right around facilities that emit ethylene oxide. And this was, you know, this is not very good. It doesn't look good for the EPA. But what was even worse was that all these facilities were acting within their legally required limits because updates in regulations for ethylene oxide hadn't been updated since 2006, 10 years before it was classified as a carcinogen. And so the EPA, kind of knowing that there was going to be backlash due to this report, acknowledged the risk of ethylene oxide in the data report and even kind of sent out a notification to state agencies saying that they were planning to work with the state agencies moving forward to address these hazards due to ethylene oxide. And so our project focused on kind of what has been done at the federal, state, and community level since these actions were announced after the assessment was released in 2018. And then also, is there any patterns in how these actions were implemented, depending on the social and demographic factors of the affected communities? And so we hypothesized that federal and state action would not occur without strong community involvement and also that there would be discrepancies in federal and state actions that correlate with the characteristics of environmental injustice. And so to start this project, we first identified facilities that led to these elevated cancer risks. As the EPA notes, they gave the level of 100 in a million as being considered elevated. And that's shown as the red and the orange on the map there. And so this led us to identifying 31 facilities across the United States, which separated out into 11 commercial sterilizers and 20 chemical plants. You can see they're all as dots on the map here. You can see they're all kind of focused mostly in the eastern half of the United States, with a lot of them focused in the southern region of Texas and Louisiana. You can even see, I pull out the region of Louisiana again, and between Baton Rouge and New Orleans, you can see there's a clustering of facilities, seven facilities located in this region. And you might be aware this is considered Cancer Alley and is sometimes on the national news for its level of hazard in that area. And we then focused on, we separated them out into EPA regions. So you can see most of the regions are represented here with over half of the facilities located in EPA region six, which is Texas, Louisiana, Oklahoma, New Mexico, and Arkansas. And then we identified the communities that are most affected by the facility. And we did this by measuring a one mile radius around each facility and use that to do the demographic data that we'll show later. So then we analyze the community, state, and federal actions that have taken place since the assessment was released in 2018 through our study period, which was through the end of 2020. And we started with saying actions from the community, which could include formation of community groups, doing local protests that got on the local news, class action lawsuits. Some of them had class action lawsuits. And then also we analyzed actions from the EPA and the DEP. And so we considered action being at a minimum, holding a public meeting, which was designed to inform the community of the risk and inform them about the facility that was located in their community. And then other actions could include doing air monitoring at the facility or in the community or conducting a formal risk assessment. And then we also looked at actions from local politicians and state legislation. And then also from the facility, if they did install new controls or if they eventually closed the facility. And so now I'll take you through what happened with the sterilizers. So there was 11 sterilizers that we looked at. And so a majority of them did have community outcry from the beginning. Right when the assessment came out, there was a lot of outcry from sterigenics in Illinois and in Georgia, and a lot of local protests wondering what was going on and why would there was these elevated cancer risks in their community. And this led to EPA involvement at a majority of these sites and also state DEP involvement. And air monitoring was then conducted at a lot of these sites. And then two formal risk assessments was completed, one in Colorado and one in sterigenics in Illinois. And then I do want to mention, I do have Texas as the state DEP being involved, but they were actually involved because they considered the assessment of ethylene oxide to be incorrect as a human carcinogen and actually wanted to loosen the restraints and allow for more emissions from the facilities in their state. So they did their own risk assessment. And then state legislation was passed in two states, in Illinois and Georgia, which affected four facilities. And then by the end of our study period, seven facilities had either closed or cut emissions significantly. And now we're going to look at the demographic data based on facilities that did some action, closed or cut emissions, and ones that did not. So for the facilities and the communities that surrounding them, they had an average median household income of around 68,000 of the ones that closed or cut emissions during this time period. However, the communities that did not see any change had a median household income of only 45,000. And then also the population surrounding the ones that did see action had a population of about 61% white non-Hispanic, while the communities that saw no action had a 30% population white non-Hispanic, with three of these communities being largely Hispanic in Texas, New Mexico, and Puerto Rico. And then to talk about the chemical plants. So during our study period, there wasn't really any action at any of the chemical plants that we looked at. There was community outcry, especially from the communities that live in Cancer Alley. While they have been active for a very long time due to other hazardous air pollution, not just ethylene oxide, but still no involvement from really the EPA or the DEP in these areas. And again, the Texas being with their own risk assessment. And now we'll look at these separated out into EPA region. And so the green represent where the EPA was involved. So you can see the EPA region four, five, seven, and eight were involved with all the facilities in their region. And then this led to the closure of a lot of those facilities or the cutting of emissions. You can see just to point out region six again, which is Texas, Louisiana, and New Mexico, which has the majority of these facilities. There was no action or no emissions cut for these facilities during this time period. And then to bring it back to environmental justice. So to look at this region again in Louisiana, these represent the census tracts in that area. And the hashed areas are regions that are considered environmental justice regions. And this is using the EPA's definition of 20% or more living in poverty or 30% of more of the population is minority. So you can see the hashed regions overlay with the regions that have the elevated cancer risks in the orange and red areas, and also where the facilities are located. And none of these facilities saw action during our study period. As opposed to the facility in south of Chicago, where they saw a very aggressive response from federal and state agencies. And this is not located in an environmental justice community. It is located in a very high income white community. And then if we look at all of the facilities based on whether they were located in an environmental justice community or not, we can see that the facilities that were located in environmental justice community, only 17% of them saw action, whereas 38% of the facilities located, not located in environmental justice, saw action from their federal and state agencies. And so some of the key findings of our project was that seven out of the 11 commercial sterilizers closed or cut emissions from 2018 to 2020 immediately following the release of the report. And these facilities were located in higher income, wider communities. And also strong community activism preceded federal and state involvement in the majority of the facilities that closed or cut emissions, and that the wealthiest communities, specifically around the serogenics in Illinois and Georgia, were the first to organize and receive the quickest and most aggressive response from the state and federal agencies. And also no chemical plants decreased emissions during this time period, and community activism did not have the same effect and did not lead to involvement for the chemical plants. And then for environmental justice, we did see faster federal and state involvement in higher income, wider communities than in environmental justice communities. And this continues that the communities that are most vulnerable to hazardous air pollution were not being protected during this time period. And so the implications of this project show how there are differences in how state agencies and EPA regions respond to environmental threats to residents. And it also reflects on how environmental injustice is perpetuated in the United States through these regulatory processes. And then just to note climate change really quickly, as we continue on with this inadequate regulatory protection of hazardous air pollution, in addition to the increased air pollution we are expected to see due to climate change, it will only worsen the health effects for people that are most vulnerable, including increased risk for health effects, including asthma, heart disease, cancer, and other health outcomes for the residents of these regions. And so to end on a more high note, I'm gonna be so negative all the time, the recent Biden administration did their Justice 40 initiative, which I'm sure you might've been heard of. And the new executive order that was passed recently does require 40% of all the benefits from government funding of specific categories to flow to disadvantaged communities. So all the investment in climate change, clean transit, affordable, sustainable housing, and a few others will flow to disadvantaged communities. And hopefully this will fund resources and programs to help those communities overcome the burden that has been placed due to our regulatory system. And then we just added some super recent news. So just last week, the EPA did propose new requirements for commercial sterilizers and chemical plants to reduce their ethylene oxide emissions. So just last week, yeah, in April of this year, they proposed these emissions. So why did it take five years? Some of these facilities were able to do it in less than a year. And just to bring it back to the timeline that I had up earlier, it's five years since the data came out, but it's 33 years since it was classified as a carcinogen. So these communities that are most vulnerable have been affected this whole time. And the delay of our government is just proof in how these systems should be updated to protect the ones that are most vulnerable. Thank you. I put some of our contact information up there for the Center of Excellence in Environmental Toxicology. So feel free to reach out with any questions or any questions you have right now. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Hello. My name is Matt. I'm with the University of Texas Health Science Center in Houston. I'm the PGY3 resident. Great presentation. Thank you. It highlighted a lot of issues that I think were new to some of us, especially me. But, so I'm in Texas. You highlighted some shortcomings in our state. Do you have any ideas of recommendations you would give, let's say you can address Texas, and try to give us an idea of like what first steps should we take to remedy some of the disparities in our state? What would you recommend? You want me to take that? So, one of the things I think we're seeing is the influence of local, and by local I mean state, industrial sort of influences on EPA. And so, I think if you, if we had the EPA at a national level take a more structured, more consistent approach in their requirements, we might see then the state EPA officials who are really good people in most cases that want to do the right thing. But, they feel that their hands are tied often. And so, they would feel, oh, you know, we have to do it because they tell us we have to do it. And I feel that there would be a more consistent approach, and it would be easier for them to do the right thing if in fact things were coming from the federal level. I think if there is, if I'm right and the reason that EPA region is not very aggressive about reining in what is clearly a known human carcinogen, then it seems like they need, the current system is not working, so we need to ramp that up. I don't know that anything more locally can be done. Because it's not reasonable really to expect a company to install a multi-million dollar chemical protection system unless it's really required. There are some companies that are doing it as good neighbors and who have a mission statement that incorporates environmental stewardship, and I applaud those, but I don't think that we can actually expect that to be the way every company behaves. I see, thank you. Hi, David Weissman, I'm from Nash in Morgantown, and I think the metric of time to response, like what was shown on the last slide, is really important. So for example, in West Virginia, the plants in Institute and in South Charleston, EPA did eventually come and do public meetings, and DEP did eventually come and get involved, but it was outside of the timeframe that you looked at. So I think that issue of time to response is really important. I agree. I think we have, at least I have an expectation, maybe I'm alone in this, that when something is a known human carcinogen, that should push us to a short timeframe. There should be action taken in, in my mind, months, not years. And really what we see here is some EPA regions feeling that way and taking that quick action, but not the majority. The majority really didn't, and the majority, in fact, in some of our interviews, didn't you hear that people said that they really didn't feel that they could take action because, you wanna speak to that? Right, yeah, so as part of this, I did speak with a number of state representatives from the state DEPs, and I remember I spoke to someone from West Virginia, and it was like, yes, we're aware of this, but there's so many other priorities right now that are taking precedent over this. I think someone from Texas said the same thing. It's like, we're having fires at this chemical plant. We really can't focus on this right now. We'll get to it eventually, but it's just a priority shift in some of the states. Not that they don't wanna do anything, just that it's not being pushed to the front by their regional EPA office or someone like that, so. And also feeling as though they didn't have the authority to really act on it until the federal government told them they needed to. That was not an uncommon thread, and I think that if that is really the case, then we need to recognize that we need a federal direction that is very clear in order to expect action, because otherwise, we have five years. We have five years now, and in fact, these are just proposals. They're not passed. We don't know that they will actually get through. They've just been proposed this month. Yes? Thank you. Thank you for a very good presentation, and I live in California now, but I grew up here. My dad was a chemist in Bridesburg. Grandfather's a leather tanner. The whole perception about environmental issues was very, very different then. However, with a comment about the EPA, I work in the federal government, and one of our agencies that we serve is the EPA, and over the past seven years or so, there has been quite the exit of a number of people and a lot of memory, institutional memory loss, because people were actually being shown the door. The EPA's finally gotten their own medical department after so many years and their workers working with hazardous materials and whatnot, so that is improving, but similar to what happened in California when the governor blue-penciled Cal-OSHA and we lost the state OSHA for a couple of years, it was reinstated, but it took years for us to recover from that, so we all are in a very fragile situation, both from the local, state, and federal level, and it just emphasizes more and more that all of these areas require some attention, and I'm not an activist, but I think that's probably the way to go and raise that level of consciousness to everyone, both from a professional level, which I'm a part of, but also engage more with the communities, so thank you for just letting me air my stuff, but I really appreciated the talk. Thank you, thank you. Hi, Paul McGovern, occupational physician from the UK. It kind of follows on from your point, sir. I was really interested to hear about how communities with a higher income have better outcomes or there's more likelihood of action. Their outcry, their public outrage, their expression of that is more effective. Does that mean that occupational environmental physicians should be activists, should be encouraging, facilitating, educating people, not just in the facts, not just in the evidence, but in the actions that they need to take, how they mobilize their communities to get people to listen to them and hear them? So I think that we all can play a really important role in engaging with communities. You will never see me carrying a placard. I don't do protests, I don't do any of that, but yet I am involved with many community groups to bring them the science and give them sometimes the direction. This is the right timing to submit comments. These are the people who need to hear this message. This is, here's some science that would help support your message. And so my answer to your question is absolutely, but whenever we use the word activist, it scares many of us away. And so I would say that perhaps if people didn't automatically include in that activist idea, the things that might scare us away, the placard carrying and laying our bodies down in the streets, the things that have been very effective for communities to do, I might add, that's not where we have to find ourselves. We have something else to bring to the table, and that is science, that is medical expertise, that is encouragement, and sometimes a better understanding of timing and who needs to know what in order to make something actually happen. So I work with the activist sort of mindset every day, and I think it's probably been the most satisfying part of my occupational medicine career, to be perfectly honest. Yes. Hi. My name is Elton Dork, and I work for a mining company. I found it interesting that all of the companies emitting ethylene oxide were healthcare companies. Were what? Healthcare companies. Becton, Dixon, all of them. Well, I think I only saw one I didn't recognize the name of, just at a system level. So in order for us to make sterile syringes, needles, and whatnot, we make people sick. Just found it interesting. Yeah, sterilizing is a very large part of ethylene oxide use, and then there are a number of other chemical industries that use it. And then I'll say one thing that happened after our project was concluded was COVID, and so that actually reopened some of these facilities because they needed to increase the sterilization, and so they needed to up the production of some of these facilities that they had previously closed. Yeah. Other thoughts or questions? Yeah. Oh, this was great, thanks. I'm gonna make a comment that I thought about when you were doing this, talking about this, is that June Spector's group at University of Washington did a really nice study of wildfire smoke and the fact that there's not air monitoring in a lot of the areas where that's happening, where farm workers work, rural areas, they don't have the air monitors to pick it up. So it's like I thought, oh, it's like heat islands. These are wildfire smoke islands to really vulnerable populations. Absolutely. I think you're raising a really important point. People think that because we have these air monitors around the country, that we have an effective air monitoring system that actually can inform us when we have events. And yes, sometimes there is one that is immediately downwind of an event and it can inform us in that situation, but much more commonly, we don't. I can give you the example of in Philadelphia when the Philadelphia Energy Solutions refinery exploded in 2019, Philadelphia Air Management repeatedly said, oh, the air is great. The air is fine, no problem. All the time when people saw this massive plume of smoke over 24 hours passing over them, they were coughing, it smelled bad, but the air management was saying, oh, it's fine. And our center actually did an air plume analysis and found that in fact, the plume just didn't pass over any of those monitors that we have in Philadelphia. And so we have to be cautious and in some ways, rein in some of our public health folks who may not quite get that just because none of the monitors are showing it, the monitors actually have to be in the right place in order to effectively monitor for a particular situation. So I think that's a really good example. I don't know why those firefighters aren't wearing real-time monitors that are going into the cloud and getting pulled out of those situations when they're not adequately protected. Of course, making sure that they actually were respirators would probably be a start too, just saying. You can ask David Weissman, why not? I guess it's that, you know, there's no respirator companies that are actually, I don't know, creating the right, either doing the right respirators or providing them to NIOSH for certification for wildfire fighters, something like that. But there are NFPA. Since I brought it up, sorry. There are NFPA standards, but there aren't any commercial products. At least when I last looked, there weren't any commercial products that were manufactured to those standards. And then even if they did exist, as you say, they would have to be used. Right, just to add to that, I know that in standard firefighting, given the garb and given the environmental conditions, it's very time-limited how long you can actually be in a respirator in that situation. That is not probably a practical scenario for wildfire fighters, and so there needs to be some other considerations to that. So I was a little flippant, but I think it's an important point that they are not protected. Other thoughts? So I'm gonna ask you all to go and look up those proposals for ethylene oxide that have just been made, and write something short in response to recommend that they actually be passed. Because they are still proposals, and I don't know if there's a comment period that's open yet, but please look for those because populations around these sites, in particular the chemical sites, the chemical manufacturing companies, really have seen no improvement, or very limited improvement, whereas some of the sterilizers, we've seen some of that. And so without our voices there in this mix, there may only be voices from chemical companies who are bearing the cost of these interventions. They need to hear from us, us who really are understanding of the impacts to people. And you don't have to know about the whole issue. Three quarters of a page works really well, in particular when you have an MD after your name, and you come from a recognizable organization. Other thoughts? All right, well thank you all very much for attending, and we'd be happy to take any individual questions if you have them. Thanks. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you.

environmental justice

air pollution

communities of color

environmental hazards

Superfund sites

monitoring air pollution

hazardous air pollutants

regulatory actions