By: Molly Rauch, MPH, Public Health Policy Director, Moms Clean Air Force
Date: March 15, 2022
About: Draft Toxics Substances Control Act Screening Level Approach for Assessing Ambient Air and Water Exposures to Fenceline Communities
To: Science Advisory Committee on Chemicals (SACC)
Thank you for the opportunity to testify. My name is Molly Rauch, and I am Public Health Policy Director for Moms Clean Air Force. I have three children, and I live in Washington, DC.
We have more than a million members across the country, and organizers working on the ground in a dozen states. Our moms—and dad, grandmas, and aunties—join us because they are concerned about how toxic chemical pollution is affecting the health of their children and their families. Many of them live near refineries, power plants, pumpjacks, petrochemical plants, factories, and other industrial facilities. They are living on the fence line.
It matters deeply to these members what they and their families are exposed to. They don't care if the chemical is in the air or in their water, or coming up through the soil in their home. Or whether it comes from the playground, home, or school. They care about being protected. It matters to them that someone is paying attention. That’s why it’s so important that EPA not take a piecemeal approach to looking at what they are exposed to. They are whole people, and should be treated as such.
A way to do this is not only to look at all the ways—or, “pathways”—that can expose fenceline communities to hazardous chemicals—such as through contaminated food and groundwater, and from chemical spills – but also to face the reality that these communities often deal with exposures from more than one source.
For example, EPA’s own data shows that polluting facilities tend to be clustered together, so fenceline communities will often be dealing with multiple exposures. Also, members of the community may have a double whammy of exposure because, for example, they live close to those facilities and also work at one of them. EPA’s plan does not properly take such lives into account.
I want to talk about another troubling aspect of the fenceline screening approach as it’s currently written. EPA’s approach not only underestimates the risks fenceline communities face, but also appears to trivialize them. EPA says if risks from certain chemical uses are identified, then it will do a further analysis to confirm those findings – although EPA does not explain what that analysis is. But on the flipside, if EPA does not identify any unreasonable risks, it says it’ll stop there; no further investigation needed.
It doesn’t make any sense that EPA would second-guess a finding of risk to fenceline communities and require more analysis to confirm it, while doing the opposite when its initial screening finds no risk, just presuming in that case that everything is fine.
I urge EPA to strengthen its method of analyzing fenceline risks to capture the real lived experience of these communities. Thank you for the opportunity to testify.