A Cumulative Framework for Identifying Overburdened Populations under the Toxic Substances Control Act: Formaldehyde Case Study

Abstract

Extensive scholarship has demonstrated that communities of color, low-income communities, and Indigenous communities face greater environmental and health hazards compared to communities with more White or affluent people. Low-income, Indigenous, Black, and/or other populations of color are also more likely to lack access to health care facilities, healthy food, and adequate formal education opportunities. Despite the mountains of evidence that demonstrate the existence and significance of the elevated toxic social and environmental exposures experienced by these communities, the inclusion of these factors into chemical evaluations has been scarce. In this paper, we demonstrate a process built with publicly available data and simple geospatial techniques that could be utilized by the U.S. Environmental Protection Agency (USEPA) to incorporate cumulative approaches into risk assessments under the Toxic Substances Control Act. The use of these approaches, particularly as they relate to identifying potentially exposed and susceptible subpopulations, would help USEPA develop appropriate risk estimates and mitigation strategies to protect disproportionately burdened populations from the adverse effects of chemical exposures. By utilizing such approaches to inform risk evaluation and mitigation, USEPA can identify and protect those most burdened and impacted by toxic chemicals, and finally begin to close the gap of environmental health inequities.

Conducting evaluations of evidence that are transparent, timely and can lead to health-protective actions

“…The analysis identified 19 counties with a cumulative total of 10 or more respiratory carcinogens, including formaldehyde, according to industrial facilities air emissions reports. Demographic analyses revealed correlations between the number of facilities emitting formaldehyde and living in a single-parent household, speaking English “less than well,” living in multi-unit housing, being disabled, or living in a mobile home [ 5 ]. Thus, as these communities shoulder disproportionately high levels of exposure to hazardous agents from multiple pollution sources and through numerous exposure pathways, combined with exposure to non-chemical stressors including poverty and linguistic isolation that further exacerbate the health risk and effects posed by hazardous agents – methodological advances are needed to risk evaluations and regulatory policies that capture and address the combined impact of these stressors.…”

“…With so many examples of harm to people and the environment from delayed health and environmental protection policies and practices, why are early warnings from scientists still not sufficient to spur rapid action to ban production, replace hazardous materials with safer alternative products and processes, install pollution controls, and take other measures to avoid harm? The situation is made much more complex for myriad reasons, including but not limited to, the chemical industry’s influence in the regulatory process, the expense of conducting toxicity testing and environmental monitoring of chemicals, the complexities posed by chemical mixtures and how to determine the toxicity of an individual chemical, and ever-changing product formulations, the lack of public disclosure of both hazard and exposure information, the reality of multiple-chemical exposures (both aggregate exposure of an individual chemical from multiple sources, and cumulative risk from multiple chemicals) that is higher for workers and many communities, particularly low income and communities of color, and manufacturer’s claims of economic hardship due to the costs of installing pollution controls and other safety measures [ 5 , 12 ]. Solutions will need to find the appropriate balance between the health risks and social benefits of chemicals and encourage safe, sustainable business strategies that are informed by communities.…”

“…Overwhelmingly, when it comes to human suffering from chemical exposures, "Environmental Justice Communities, " or "EJ Communities, " whose residents are predominantly of color, and/or low income, are disproportionately impacted [4][5][6]. These communities are burdened by the cumulative effects of multiple hazardous industries sited closely together, in addition to other chemical stressors from the products they use in their homes and non-chemical stressors such as poverty, racial discrimination, and poor access to regular affordable medical care [7].…”

Toxic Substances Control Act (TSCA) Implementation: How the Amended Law Has Failed to Protect Vulnerable Populations from Toxic Chemicals in the United States

“…Nineteen counties were identified with a total of 10 or more respiratory carcinogens being reported (including formaldehyde) and an analysis of the demographic characteristics of these counties found correlations between the number of facilities releasing formaldehyde air emissions and speaking English “less than well”, living in a single-parent household, living in a mobile home, living in multiunit housing, or identifying as having a disability. 61 By only examining the risk of an adverse outcome from exposure to a single chemical, EPA overlooked how multiple exposures (chemical and nonchemical) may combine to produce a common adverse health outcome. ( Figure 1 ).…”

“…Not considering cumulative risk also underestimates risk. , For example, using publicly available data from the U.S. EPA Toxics Release Inventory (TRI), researchers were able to establish counties throughout the U.S. reporting air emissions of various chemicals linked to respiratory cancer, including formaldehyde, a leukemogen. Nineteen counties were identified with a total of 10 or more respiratory carcinogens being reported (including formaldehyde) and an analysis of the demographic characteristics of these counties found correlations between the number of facilities releasing formaldehyde air emissions and speaking English “less than well”, living in a single-parent household, living in a mobile home, living in multiunit housing, or identifying as having a disability . By only examining the risk of an adverse outcome from exposure to a single chemical, EPA overlooked how multiple exposures (chemical and nonchemical) may combine to produce a common adverse health outcome.…”