Date: April 25, 2022
To: The Council on Environmental Quality
RE: Submission for Request for Information (RFI) Climate and Economic Justice Screening Tool, Beta Version, Docket number: CEQ-2022-0002
Dear Madam, Sir,
Many thanks for the opportunity to contribute a submission during the development of this crucial tool.
- We are writing today to ask that you design and include a maternal and newborn health indicator in the screening tool, for example, percent of premature births and/or “small for gestational age” and/or low birth weight, perhaps in addition to other health indicators.
- This submission is in answer to Question 1(a) and 1(b) in the RFI.
We represent a diverse group of maternal and newborn health organizations, medical associations, climate advocates, and human rights and reproductive justice and rights organizations increasingly concerned about the impact of climate change and other mounting harms from environmental degradation on the health of all people, but especially on the health of pregnant people and newborn babies. These negative impacts, which reflect specific biological and socioeconomic vulnerabilities of pregnancy, are inequitably distributed, compound and interact with poverty, racism, and other forms of marginalization, and can have life-long impacts that in turn corrode future community resilience, including to the climate crisis.
Known impacts arising from air pollution, climate change and other environmental factors include preterm birth, low birth weight, still birth, and higher rates of some maternal diseases. Without action, environmental injustices will continue to worsen the US maternal health crisis, deepening unjust inequities in rates of maternal morbidity and mortality and adverse birth outcomes, with far worse rates for Black women and birthing people, Indigenous women and birthing people, and other women and birthing people of color.
The maternal health crisis is an important vulnerability to the climate crisis. We welcome increased attention on environmental justice from the current administration but are concerned that maternal health remains a marginalized dimension. Maternal health and newborn vulnerabilities should be urgently addressed, including through the Justice 40 mechanism.
We believe there are at least three compelling reasons why including preterm birth and small for gestational age as indicators would help the tool identify disadvantaged communities and communities disadvantaged by climate and other pollution. These are:
- In the US (and all over the world), maternal health indicators such as maternal morbidity and mortality and adverse birth outcomes, such as rates of preterm (also called premature, defined as births before 37 weeks of gestation) birth and low birth weight, are crucial indicators used to determine overall population health and wellbeing. They are important indicators of disadvantaged – marginalized or excluded – communities.See, for example, that low birth weight is a key indicator for the Centers for Disease Control and Prevention (CDC)’s Healthy People campaign: https://www.cdc.gov/nchs/healthy_people/hp2000/hp2000_indicators.htm
- Preterm birth and low birth weight are linked in a large and growing body of epidemiological evidence to climate and other environmental hazards and pollution. They are important indicators of communities disadvantaged by pollution. (Please see the annex below for some of the studies linking adverse birth outcomes with air pollution, climate change impacts, including exposure to extreme heat and wildfires, and other relevant environmental hazards.)
Scientific studies are also increasingly finding that poor maternal health outcomes (for example, higher rates of pregnancy diseases such as pre-eclampsia and gestational diabetes) are linked with environmental health.
- The US has a maternal health crisis that is also a reproductive justice crisis and an environmental justice crisis. Any tool to identify environmental injustice effectively and holistically in the US should have a maternal and newborn health component.
Here is some key information about the maternal health crisis in the US. Statistics are from the CDC.
Preterm birth: Reducing preterm/premature births is a CDC national health priority. Preterm birth is a leading cause of infant mortality and is often linked with poor lifelong mental and physical health. Preterm birth is also a significant financial burden on families, both in the immediate term and as a result of lifelong health consequences. Rates of preterm birth increased between 2013 and 2019 in the US. Recent increases in preterm birth rates in the US are not fully understood but have been linked to racism and environmental health factors. Rates of preterm birth are twice as bad for Black women than white women, and although overall rates decreased between 2019 and 2020, and by 2 percent for white women, and by 1 percent for Hispanic women, they did not decrease for Black women.
Low birthweight: Low birthweight (the percentage of infants born at less than 2,500 grams or 5 pounds, 8 ounces) is among the leading causes of infant death in the US, and low birth weight infants are also more likely to have health problems. Rates of low birthweight in 2020 (the latest reporting year) were lower than in 2019. However the general trend for the past years has been one of worsening rates of low birthweight. Between 2012 and 2019, rates increased by 4 percent.). However, while the overall rate reduced and the rates for white and Hispanic women examined separately, rates of low birthweight babies were essentially unchanged for Black women. In addition, when only singleton births were considered, the low birth weight rate remained essentially unchanged between 2019 and 2020.
Maternal mortality: Rates of maternal deaths are increasing in the US, even as they continue to decrease in other industrialized nations, with disproportionate impacts on Black women. In 2020, the maternal mortality rate for non-Hispanic Black women was 2.9 times the rate for non-Hispanic white women. The increases in maternal mortality rates from 2019 to 2020 for non-Hispanic Black and Hispanic women were significant yet the observed increase from 2019 to 2020 for non-Hispanic white women was not significant according to the CDC. Rates of severe maternal morbidity have also continued to increase over the past years, again in contrast to other industrialized nations, and again with far worse outcomes for women of color than white women.
Many thanks for considering including maternal and newborn health indicators in your screening tool. Please be in touch with me at wheeles@hrw.org or +1 (646) 203-2539 if we can be of further assistance.
Yours sincerely,
Katie Huffling, Alliance of Nurses for Healthy Environments
LaTricea Adams, Black Millennials for Flint
Skye Wheeler, Human Rights Watch
Hailey Duncan, Moms Clean Air Force
Zainab Jah, National Birth Equity Collaborative
ANNEX: Examples of Studies
[A] Studies describing important links between environmental and maternal and/or birth health outcomes.
Burris HH et al.
“Racial disparities in preterm birth in USA: a biosensor of physical and social environmental exposures”
DOI: 10.1136/archdischild-2018-316486
Robinson O, Vrijheid M.
“The Pregnancy Exposome.”
DOI: 10.1007/s40572-015-0043-2.
[B] Studies indicating links between air pollution and adverse birth outcomes
Koman PD et al.
“Examining Joint Effects of Air Pollution Exposure and Social Determinants of Health in Defining ‘At-Risk’ Populations Under the Clean Air Act: Susceptibility of Pregnant Women to Hypertensive Disorders of Pregnancy.”
DOI: 10.1002/wmh3.257.
Ha S, Hu H, Roussos-Ross D, Haidong K, Roth J, Xu X.
“The effects of air pollution on adverse birth outcomes.”
DOI: 10.1016/j.envres.2014.08.002
Lamichhane DK, Leem JH, Lee JY, Kim HC.
“A meta-analysis of exposure to particulate matter and adverse birth outcomes.”
DOI: 10.5620/eht.e2015011
Malley CS, Kuylenstierna JC, Vallack HW, et al.
“Preterm birth associated with maternal fine particulate matter exposure: A global, regional and national assessment.”
DOI: 10.1016/j.envint.2017.01.023
Basu R, Harris M, Sie L, Malig B, Broadwin R, Green R.
“Effects of fine particulate matter and its constituents on low birth weight among full-term infants in California.”
DOI: 10.1016/j.envres.2013.10.008
Vinikoor-Imler LC, Davis JA, Meyer RE, Messer LC, Luben TJ.
“Associations between prenatal exposure to air pollution, small for gestational age, and term low birthweight in a state-wide birth cohort.”
DOI: 10.1016/j.envres.2014.03.040
Ebisu K, Malig B, Hasheminassab S, Sioutas C, Basu R.
“Cause-specific stillbirth and exposure to chemical constituents and sources of fine particulate matter.”
DOI: 10.1016/j.envres.2017.10.015.
Varada Sarovar, Brian J. Malig, Rupa Basu.
“A case-crossover study of short-term air pollution exposure and the risk of stillbirth in California, 1999–2009.”
DOI: 10.1016/j.envres.2020.110103
Eric Lavigne et al.
“Ambient air pollution and adverse birth outcomes: Differences by maternal comorbidities.” DOI: 10.1016/j.envres.2016.04.026
Mendola P et al.
“Air Pollution and Preterm Birth: Do Air Pollution Changes over Time Influence Risk in Consecutive Pregnancies among Low-Risk Women?”
DOI: 10.3390/ijerph16183365
Trasande L, Malecha P, Attina TM.
“Particulate matter exposure and preterm birth: estimates of U.S. attributable burden and economic costs.”
DOI: 10.1289/ehp.1510810
Ghosh R et al.
“Correction: Ambient and household PM2.5 pollution and adverse perinatal outcomes: A meta-regression and analysis of attributable global burden for 204 countries and territories.”
DOI: 10.1371/journal.pmed.1003952
Hao H et al.
“Air pollution and preterm birth in the U.S. state of Georgia (2002-2006): associations with concentrations of 11 ambient air pollutants estimated by combining Community Multiscale Air Quality Model (CMAQ) simulations with stationary monitor measurements.”
DOI: 10.1289/ehp.1409651
Hansen C, Neller A, Williams G, Simpson R.
“Low levels of ambient air pollution during pregnancy and fetal growth among term neonates in Brisbane, Australia.”
DOI: 10.1016/j.envres.2006.06.010
Dugandzic R, Dodds L, Stieb D, Smith-Doiron M.
“The association between low level exposures to ambient air pollution and term low birth weight: a retrospective cohort study.”
DOI: 10.1186/1476-069X-5-3
Stieb DM, Chen L, Eshoul M, Judek S.
“Ambient air pollution, birth weight and preterm birth: a systematic review and meta-analysis.”
DOI: 10.1016/j.envres.2012.05.007
Chen G, Guo Y, Abramson MJ, Williams G, Li S.
“Exposure to low concentrations of air pollutants and adverse birth outcomes in Brisbane, Australia, 2003–2013.”
DOI: 10.1016/j.scitotenv.2017.12.050
Li X et al.
“Association between ambient fine particulate matter and preterm birth or term low birth weight: An updated systematic review and meta-analysis.”
DOI: 10.1016/j.envpol.2017.03.055
Bekkar B, Pacheco S, Basu R, DeNicola N.
“Association of Air Pollution and Heat Exposure With Preterm Birth, Low Birth Weight, and Stillbirth in the US: A Systematic Review.”
DOI: 10.1001/jamanetworkopen.2020.8243
DeFranco E et al.
“Exposure to airborne particulate matter during pregnancy is associated with preterm birth: a population-based cohort study.”
DOI: 10.1186/s12940-016-0094-3.
Melody SM, Ford J, Wills K, Venn A, Johnston FH.
“Maternal exposure to short-to medium-term outdoor air pollution and obstetric and neonatal outcomes: A systematic review.”
DOI: 10.1186/s12940-016-0094-3
[C] Studies indicating links between climate change and adverse birth outcomes
Ebi, K.L. et al.
In: Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment, Volume II
DOI: 10.7930/NCA4.2018.CH1
Cissé, G., et al.
In: Climate Change 2022: Impacts, Adaptation, and Vulnerability. Contribution of Working Group II to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change.
https://report.ipcc.ch/ar6wg2/pdf/IPCC_AR6_WGII_SummaryForPolicymakers.pdf
Watts N et al.
“The 2019 report of The Lancet Countdown on health and climate change: ensuring that the health of a child born today is not defined by a changing climate.”
DOI: 10.1016/S0140-6736(19)32596-6
Marya Zlatnik
“Climate Change and Pregnancy: Risks, Mitigation and Adaptation.”
Forthcoming.
Poursafa P, Keikha M, Kelishadi R.
“Systematic review on adverse birth outcomes of climate change.”
PMID: 26109998
Ha, S.
“The Changing Climate and Pregnancy Health.”
DOI: 10.1007/s40572-022-00345-9
Giudice, LC et al.
“Climate change, women’s health, and the role of obstetricians and gynecologists in leadership.”
DOI: 10.1002/ijgo.13958
Sorensen C, Murray V, Lemery J, Balbus J
“Climate change and women's health: Impacts and policy directions.”
DOI: 10.1371/journal.pmed.1002603
Roos, N. et al.
“Maternal and newborn health risks of climate change: A call for awareness and global action.”
DOI: 10.1111/aogs.14124
Various useful papers and commentary in special edition of Paediatric and Perinatal Epidemiology: Climate Change and Reproductive, Perinatal, and Paediatric Health: Paediatric and Perinatal Epidemiology: Vol 36, No 1 (wiley.com)
(a) Exposure to Extreme Heat
Bekkar B, Pacheco S, Basu R, DeNicola N.
“Association of Air Pollution and Heat Exposure With Preterm Birth, Low Birth Weight, and Stillbirth in the US: A Systematic Review.”
DOI:10.1001/jamanetworkopen.2020.8243
Kuehn L, McCormick S.
“Heat Exposure and Maternal Health in the Face of Climate Change.”
DOI: 10.3390/ijerph14080853. PMID: 28758917; PMCID: PMC5580557.
Chersich M F et al.
“Associations between high temperatures in pregnancy and risk of preterm birth, low birth weight, and stillbirths: systematic review and meta-analysis.”
DOI: 10.1136/bmj.m3811
Carolan, Mary & Frankowska, Dorota.
“High environmental temperature and preterm birth: A review of the evidence.”
DOI: 10.1016/j.midw.2013.01.011
Zhang Y, Yu C, Wang L.
“Temperature exposure during pregnancy and birth outcomes: An updated systematic review of epidemiological evidence.”
DOI: 10.1016/j.envpol.2017.02.066
Konkel L.
“Taking the Heat: Potential Fetal Health Effects of Hot Temperatures.
DOI:10.1289/EHP6221
(b) Exposure to wildfire
Holstius DM, Reid CE, Jesdale BM, Morello-Frosch R.
“Birth weight following pregnancy during the 2003 Southern California wildfires.”
DOI: 10.1289/ehp.1104515
Sam Heft-Neal et al.
“Associations between wildfire smoke exposure during pregnancy and risk of preterm birth in California.”
DOI: 10.1016/j.envres.2021.111872
Park, BY, Boles, I, Monavvari, S, et al.
“The association between wildfire exposure in pregnancy and foetal gastroschisis: A population-based cohort study.”
DOI: 10.1111/ppe.12823
Weeberb J. Requia et al.
“Increased preterm birth following maternal wildfire smoke exposure in Brazil.”
DOI: 10.1016/j.ijheh.2021.113901
Benjamin A. Jones & Shana McDermott
“Infant health outcomes in mega-fire affected communities.”
DOI: 10.1080/13504851.2021.1927959
Amjad S, Chojecki D, Osornio-Vargas A, Ospina MB.
“Wildfire exposure during pregnancy and the risk of adverse birth outcomes: A systematic review.”
DOI: 10.1016/j.envint.2021.106644.
Abdo M et al.
“Impact of Wildfire Smoke on Adverse Pregnancy Outcomes in Colorado, 2007-2015.”
DOI: 10.3390/ijerph16193720
[D] Studies indicating links between fossil fuel extraction and adverse birth outcomes
Lara J. Cushing et al.
“Flaring from Unconventional Oil and Gas Development and Birth Outcomes in the Eagle Ford Shale in South Texas.”
DOI:10.1289/EHP6394
Willis M et al.
"Associations between Residential Proximity to Oil and Gas Drilling and Term Birth Weight and Small-for-Gestational-Age Infants in Texas: A Difference-in-Differences Analysis.”
DOI: 10.1289/EHP7678
Gonzalez, David J. et al.
“Oil and gas production and spontaneous preterm birth in the San Joaquin Valley, CA: A case-control study.”
DOI: 10.1097/EE9.0000000000000099
Nicole W
“On Wells and Wellness: Oil and Gas Flaring as a Potential Risk Factor for Preterm Birth.”
DOI: 10.1289/EHP7952
A large number of studies on fracking and pregnancy outcomes are included in:
Concerned Health Professionals of New York, & Physicians for Social Responsibility. (2020, December). Compendium of scientific, medical, and media findings demonstrating risks and harms of fracking (unconventional gas and oil extraction) (7th ed.). http://concernedhealthny.org/compendium/
[E] Studies indicating links between environmental contaminants and adverse birth outcomes
Kelly K. Ferguson, Marie S. O'Neill & John D. Meeker
“Environmental Contaminant Exposures and Preterm Birth: A Comprehensive Review.”
DOI: 10.1080/10937404.2013.775048
Porpora, Maria G. et al.
"Environmental Contaminants Exposure and Preterm Birth: A Systematic Review."
DOI: 10.3390/toxics7010011
Ferguson KK, McElrath TF, Meeker JD.
“Environmental Phthalate Exposure and Preterm Birth.”
DOI:10.1001/jamapediatrics.2013.3699