Environmental Epidemiology, Volume 1 Public Health and Hazardous Wastes (1991) / Chapter Skim
Currently Skimming:
2. State and Federal Context for Environmental Epidemiology of Hazardous Wastes
2. State and Federal Context for Environmental Epidemiology of Hazardous Wastes
Pages 60-100
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estimated that in 1981, 264 million metric tons of hazardous waste were produced (NRC, 19851. (One million metric tons equal approximately 1.1 million English [short]
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To answer it would require information on the scope of potential and actual human exposures to hazardous wastes and on the health effects that could be associated with these exposures. Yet during the past 10 years, of the estimated $4.2 billion spent each year on hazardous-waste sites in the U.S.
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From page 62... ...
These objectives are in fact the traditional elements of a public health strategy: The discovery and preliminary assessment of as many sites as possible, to describe the universe of potential exposures; the priority ranking of sites by a defined protocol, to identify and act on those most urgently requiring attention; the collection and use of data on current human exposures and health effects early in the triage and evaluation processes; and the development of remediation programs with direct and continuous attention to the public health effects of releases from the sites. As this review of the federal and state regulatory context for environmental epidemiology will reveal, however, the intent of Congress in creating Superfund has not been realized.
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Removal Action: This action starts any time after a site is identified because of emergency conditions that require fast action or to prevent deteriorating conditions that would make cleanup more difficult. Preremedial Process Preliminary Assessment (PA)
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is to develop a risk assessment for the site, representing the likely current and future risk associated with human exposures to releases from the site. The risk assessment includes hazard identification, a dose-response assessment, an exposure assessment, and risk characterization.
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EPA was directed to revise its site evaluation process, and Congress gave new prominence and responsibility to ATSDR, which was directed to produce public health assessments of all Superfund sites proposed for the NPL, and for other sites in response to public petition. In addition, ATSDR was required to establish a priority list of hazardous substances found at CERCLA sites, to produce toxicologic profiles for each substance on this list, and to conduct research on the health effects of hazardous substances and hazardous-waste sites (P.L.
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From page 66... ...
Significantly, this meant that ATSDR's health assessment would normally be completed well before each RI/FS began. Because the RI/FS is the stage at which the most extensive exposure and risk assessment information is produced, ATSDR has divided its health assessments into two stages: the preliminary health assessment (PHA)
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. In 1151 health assessments at NPL sites completed by mid-1990, ATSDR determined that 85 percent of the sites involved releases of hazardous substances and that about 15 percent of these merited further public health investigation (Johnson, 1990~.
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. In all, there were adequate data for only 39 sites that could be eliminated as sources of public health concern either because remedial action had already mitigated earlier concerns or because there was no feasible pathway for human exposure (ATSDR, 1989a)
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Although the Niagara County Health Department reportedly excavated some soil from the area in 1980 and EPA conducted an initial site inspection in 1987, no action had been taken to further assess the site, remediate the hazards, or relocate the residents until New York State and EPA invited ATSDR to conduct a public health assessment in 1989. ATSDR's assessment noted the potentially serious exposures for the families at the site and recommended the immediate reloca.
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Congress also directed ATSDR to undertake a further set of responsibilities, beyond the assessment of NPL sites, that were intended to build a science base for the health evaluation of hazardous-waste sites and exposures. With EPA, ATSDR has developed a priority list of 225 hazardous substances found at Superfund sites (see Table 3-2, and Appendixes 3-A and 3-B)
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Although routine monitoring of drinking water and air quality are state responsibilities, state direction of this monitoring to assess potential emissions from hazardous-waste sites is made even less likely by the fact that EPA's regional offices do not notify the relevant state agencies when off-site migration is suspected or confirmed. DISTRIBUTION OF EXPOSURE How well does this system characterize the distribution of human exposures to chemicals released from hazardous-waste sites?
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OTA reports that EPA itself holds thousands of hazardous-waste sites outside the CERCLIS inventory, to control the resource and management problems posed by congressional deadlines for preliminary assessments on CERCLIS sites. As a result, there is no single, common inventory of hazardous-waste sites in the U.S.
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The range and distribution of human exposure to releases from hazardous-waste sites is both unknown and unknowable. EPA now acknowledges that undiscovered sites could well represent significant health risks (OTA, 1989~.
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Preliminary Health Assessment 25 that most sites with serious potential for harm had been detected (OTA, 1989~. The assumption that potential health risks are missed in the current nonsystem of reporting to CERCLIS is supported by several state reviews of the subject.
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. NFRAP sites also include those that never received CERCLA hazardous substances, those that have no potential to release CERCLA hazardous substances into the environment, and those that do not fall under EPA jurisdiction (such as uranium mill tailings that fall under a Department of Energy program)
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A 1989 EPA report on the congressionally mandated revision of the hazard ranking system stated that the legislative intent in SARA "makes clear that this mandate does not require detailed risk assessments, but directs EPA to rank sites as accurately as feasible based simply on information available from preliminary assessments and site inspections consistent with the goal of 'expeditiously' identifying candidates for response actions" (EPA, 1990a, p.
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media. Off-site contamination and human exposure have been modeled rather than measured directly in off-site sampling of groundwater, drinking water, soil, and air.
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3-2, 3-3~. But EPA has no public health professionals or other staff members trained in the public health aspects of site evaluation to rely upon in this regard; it is ATSDR, in fact, that incorporates the EPA risk assessments generated in the RI/FS process into EPA's full health assessment (EPA, 1989b)
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From page 83... ...
As ATSDR has cleared the backlog of health assessments on preexisting NPL sites, moreover, an important role has emerged for ATSDR's health assessments in the selection of remediation strategies by EPA. The preliminary health assessment is initiated by ATSDR when EPA proposes a site for NPL listing in the Federal Register, that is, after the EPA preremedial evaluation has been completed but well before the RI/FS begins (the RI/FS frequently does not begin for another four to five years)
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On-site sampling of environmental contamination to estimate off-site human exposure is in some cases inadequate for the assessment of potential human exposure; these cases should be identified and off-site samples obtained. There is no routine review of early site assessments to determine the need for public health interventions or epidemiologic studies.
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The further development and application of this approach to environmental surveillance holds particular promise for the epidemiologic investigation of populations exposed to hazardous wastes. Although ATSDR is vigorously pursuing the development of an intramural research program in environmental epidemiology and has extended this to include a number of states through cooperative agreements, in FY90 ATSDR's total budget for programs that assess hazardous-waste sites was $15.8 million If.
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This integration helps to ensure that public health concerns (off-site exposures, drinking water) are appropriately evaluated and controlled
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The most recent survey of state expenditures estimates that about $500 million is spent on hazardous-waste-site cleanups each year; no similar information is available for the health assessment aspect of these activities alone (OTA, 1989~. Most environmental epidemiology studies of health effects associated with hazardous wastes are conducted by state health departments, even in states that have separate departments for environmental management.
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As our review of federal programs concludes, there is no comprehensive national inventory of hazardous-waste sites, no site discovery program, no minimum data set on potential human exposures, no adequate system for the early identification of sites for which immediate action to protect public health or continued surveillance of health effects could be necessary, and no validation or evaluation of the component parts of the site assessment process. EPA and ATSDR are instituting some improvements in each of these areas, but these improvements are largely limited to sites that are proposed for or already listed on the NPL.
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It is an active tool for identifying potentially hazardous exposures and directing interventions to prevent further exposures. Because the evaluation of human exposures and health effects associated with hazardous-waste sites is not integrated into early site evaluation and interim remediation decisions, the real contributions of public health and epidemiology are lost.
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Savings could be realized by reorganizing the assessment process to directly incorporate health assessments and staff with health expertise into the management and implementation of preliminary assessments. CONCLUSION We know enough about some exposures at some sites chiefly from ATSDR's assessments of those sites on the NPL- to suggest the potential benefit of further epidemiologic studies at these and other sites.
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Use the inventory to ensure that sites are not deferred or placed in closure status without a revised preliminary assessment as described above. · Rigorously evaluate the data and methodologies used in site assessment, including the characterization of potential and actual releases to groundwater, surface water, air, and soil that result in human exposure; methodologies for the estimation of populations exposed to hazardous-waste-site emissions; the use of this information in the preliminary assessment and in determining actions to protect the public health; and compliance with public health recommendations for the protection of exposed populations and site remediation.
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From page 97... ...
Provide increased funding for competitive grants in environmental epidemiology through ATSDR and NIEHS. A decade after implementation of Superfund, and despite congressional efforts to redirect the program, substantial public health concerns remain, and critical information on the distribution of exposures and health effects associated with hazardous-waste sites is still lacking.
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1989b. Preliminary Health Assessment for Forest Glen Mobile Home Park, Niagara Falls, Niagara County, New York.
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1986. The feasibility of conducting epidemiologic studies of populations residing near hazardous waste disposal sites.
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1987. Growth of children living near the hazardous waste site, Love Canal.
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