By: Rachel Meyer, Ohio River Valley Field Organizer, Moms Clean Air Force
Date: February 20, 2024
About: EPA TSCA Prioritization Webinar
To: Environmental Protection Agency
My name is Rachel Meyer and I am the Ohio River Valley Organizer for Moms Clean Air Force, an organization with over 1.5 million members working to protect children from air pollution and climate change. I am from Independence Township, Beaver County in Pennsylvania, northwest of Pittsburgh. Thank you for the opportunity to give comments today.
Moms Clean Air Force is urging EPA to designate vinyl chloride a High Priority Substance under the Toxic Substances Control Act and ultimately ban this harmful chemical.
It is well established that vinyl chloride is a toxic chemical harmful to health. People exposed to vinyl chloride have an elevated risk of numerous types of cancer, adverse birth outcomes, asthma and respiratory illness, and kidney disease. Frontline communities along with workers are exposed to the cumulative impact of vinyl chloride and other cancer-causing chemicals that are released during its production, transportation, use, and disposal. The EPA must evaluate the combined exposures to all chemicals that are produced, used, or released together.
Vinyl chloride is dangerous. It’s toxic, extremely flammable, and potentially explosive. I live about twenty miles from the site of the East Palestine train derailment. The vinyl chloride that burned as a result of this incident has made people sick and may result in increased cancer diagnoses in the future. Vinyl chloride is a well-established known human carcinogen, linked to liver, brain, lung, breast and blood cancers. Transportation is an exposure route that must be considered by EPA as incidents have happened before (Paulsboro, NJ) and, if nothing is done, will likely happen again.
Up to 36 million pounds of vinyl chloride is traveling in trains across the U.S. at any given moment. It’s estimated that 3 million people, including half a million children and over a thousand schools, are within a mile of the train tracks that vinyl chloride travels on from Texas to New Jersey, including cities like Pittsburgh with dense populations. (Toxic Free Future)
The rapid expansion of the petrochemical industry in the Ohio River Valley region, Texas, and Louisiana means that more trains carrying toxic chemicals could be traveling through communities, putting children and families at risk.
After the derailment in East Palestine, it was announced that the vinyl chloride in five railcars would be burned to prevent an explosion. The burning of vinyl chloride poses additional hazards, as it can generate highly toxic byproducts such as dioxins, phosgene and hydrogen chloride, resulting in severe chemical burns and long-term respiratory damage. People had to be evacuated. I looked at the wind direction and knew I did not want to stay at my home with my three year old daughter. Children are especially vulnerable to harm from vinyl chloride. Children breathe more air per unit of body weight than adults and therefore can receive higher doses of pollution. Children’s lungs and brains are still developing until early adulthood so toxic air pollution exposures can have harmful effects that can shorten life and last a lifetime.
I left my home concerned for the safety of our animals, worried that our chickens could be the canaries in the coal mine. The wind direction changed, and, when we returned, the chickens were fine. We were fortunate, but those closer to the burning vinyl chloride did and may continue to experience serious negative health impacts.
A chemical with the capability of causing so much harm certainly needs to be designated a “high priority substance” and the EPA should evaluate all possible exposures and risks, including from incidents, spills, and leaks during production, use, disposal, and transportation.