Protecting Children from Toxic Waste: Data-Usability Evaluation Can Deter Flawed Cleanup

Abstract

Nearly 25 percent of US children live within 2 km of toxic-waste sites, most of which are in urban areas. They face higher rates of cancer than adults, partly because the dominant contaminants at most US hazardous-waste sites include genotoxic carcinogens, like trichloroethylene, that are much more harmful to children. The purpose of this article is to help protect the public, especially children, from these threats and to improve toxics-remediation by beginning to test our hypothesis: If site-remediation assessments fail data-usability evaluation (DUE), they likely compromise later cleanups and public health, especially children’s health. To begin hypothesis-testing, we perform a focused DUE for an unremediated, Pasadena, California toxic site. Our DUE methods are (a) comparing project-specific, remediation-assessment data with the remediation-assessment conceptual site model (CSM), in order to identify data gaps, and (b) using data-gap directionality to assess possible determinate bias (whether reported toxics risks are lower/higher than true values). Our results reveal (1) major CSM data gaps, particularly regarding Pasadena-toxic-site risks to children; (2) determinate bias, namely, risk underestimation; thus (3) likely inadequate remediation. Our discussion shows that if these results are generalizable, requiring routine, independent, DUEs might deter flawed toxic-site assessment/cleanup and resulting health threats, especially to children.

Health Misinformation about Toxic-Site Harm: The Case for Independent-Party Testing to Confirm Safety

“…As already noted in Section 1.2 , the literature shows that CBRE/TCC appears to have claimed site safety, yet conducted studies on least four of its current hazardous facilities that failed preliminary data-quality analysis [ 10 ]. The scientific literature also shows that, besides the problems outlined in this analysis, NOTSPA toxic-site testing failed a scientific data audit [ 11 ], as well as a data usability evaluation [ 12 ]. This article adds to that existing literature and supports it.…”

“…Third , these results are significant, both because the main victims of toxic sites include disproportionate numbers of children, minorities, and poor people [ 12 ], and because of the great potential for harm. At least one quarter of the known US inventory of hazardous facilities (nearly 400,000) has caused or could cause public exposure to carcinogenic vapor intrusion to thousands of people [ 52 ].…”

“…At three of these sites, CBRE/TCC violates 9 of 10 data-representativeness standards promulgated by the United States government; at the fourth site, the company violates all 10 data-representativeness standards [ 10 ]. In addition, earlier research shows that CBRE/TCC’s published conclusions about NOTSPA contamination contradict its own source data [ 11 ]; moreover, CBRE/TCC’s testing data for NOTSPA fail to include all the required data specified in CBRE/TCC’s own project description [ 12 ].…”

“…Likewise, our hypothesis is significant because some data indicate that CBRE/TCC may have misrepresented the health and safety of its toxic-facility testing and remediation in official government reports, presented through both traditional and social media. That is, the literature shows that the corporation appears to have claimed site safety for at least four of its current hazardous facilities; however, independent, university testing shows that all of the CBRE/TCC facilities fail preliminary data-quality analyses [ 10 ], and at least some of them also fail scientific data audits [ 11 ] and data usability evaluations [ 12 ]. This article adds to that literature by presenting the first known independent testing of a CBRE/TCC hazardous-site redevelopment, before any cancers have been reported, in order to determine whether empirical data, independent sampling, tend to corroborate or to falsify the corporation’s safety claims.…”

“…Sixth , the former NOTSPA is dangerous because, despite the 2004 ISE Order by the DTSC and the lack of most required testing, in 2019 the state regulator (under a new site-project director), approved both CBRE/TCC’s limited 2007 NOTSPA testing, as well as its mitigation and redevelopment plans, including plans to leave most VOCs “in place” onsite and instead to use land-use controls [ 19 , 20 ]. Seventh , despite CBRE/TCC’s leaving most contaminants in place (see Table 1 and Table 2 ), CBRE/TCC has approval to build 550 small apartment units onsite [ 20 , 21 ] that will house disproportionate numbers of poor people, minorities, children, and families [ 12 ].…”