Health Risks from Supposedly Remediated US Hazardous-Waste Sites: An Early-Warning Signal

Abstract

Scientific data are almost nonexistent regarding the health-protectiveness of most hazardous-waste-site remediation. Given this data-gap, recently the World Health Organization (WHO) urged scientists to develop methods of “cost-efficient health surveillance” of toxics’ cleanups, including any “illegal operations”. Following WHO, this article’s importance is to develop one such cost-efficient method. Given the assumption that remediators’-redevelopers’ public misrepresentations of their cleanups’ safety may warrant independently assessing the health-adequacy of their remediation, the article asks the question: “For US hazardous-waste sites, deemed by the courts ‘Imminent and Substantial Endangerment’ (ISE) health threats, are remediators’ public representations of testing-cleanup quality consistent with what their more private technical documents say?” The working hypothesis is that for representative toxic sites, remediators’-redevelopers’ public representations of cleanup often contradict their private technical documents. Using the US Environmental Protection Agency (EPA) weight-of-evidence method, the article (1) develops 5 transparent, reproducible criteria for discovering representative, ISE-designated, US toxic-waste sites; (2) develops 3 transparent, reproducible criteria to discover remediators’-redevelopers’ public representations of their testing-cleanup; (3) uses these 3 criteria to discover what remediators’-redevelopers’ private or technical documents say about the health-adequacy of their testing/cleanup; (4) investigates whether any public representations in (2) contradict any of (3)’s private or technical documents; and (5) discusses the degree to which such contradictions, if any, suggest waste-site threats to health or environmental justice. Our results show that for the representative hazardous sites assessed, many remediator-redeveloper public guarantees of testing-cleanup quality contradict their private or technical documents. The discussion suggests that such contradictions likely violate EPA scientific-integrity regulations, threaten public health, jeopardize environmental justice, thus may require independent investigation of the adequacy of testing-cleanup. For representative, US toxic-waste sites, posing court-determined ISE, remediators’-developers’ public representations of testing-cleanup quality threaten health by often contradicting their private technical documents. The article closes by outlining two scientific strategies to promote health-protective, hazardous-waste testing/remediation.