Meaningful chemical policy reform for Environmental Justice communities begins with appropriate and comprehensive air monitoring in communities on the fenceline of industries. It also must include empowering fenceline communities to be involved in hands-on monitoring of the air they breathe. Incorporating the local knowledge of people who are directly affected complements other efforts underway to reform national chemical policies such as those on consumer products and new chemicals entering the marketplace.

Why is this so important? For many Environmental Justice communities, the biggest threat to their health is their home address. Whether it is a large oil refinery, chemical plant, pulp and paper mill, landfill, or fabric dye factory, many forgotten communities are living under a cloud of hazardous air pollution. For example, Port Arthur, Texas, is one of the nation’s most polluted communities. A cluster of refineries and petrochemical plants releases 7 million pounds of toxins yearly. Despite the air not being tested routinely, agencies and polluters reassure communities “the air is safe.”

These communities suffer high levels of asthma, respiratory problems, and illnesses related to toxic exposure. No health studies are done in these communities to determine the effects of pollution, yet health officials and polluters agree, “industry is not the cause of health complaints.”

Industry has targeted certain communities to expand their dirty operations, based on the lack of regulation and political power. Most often these are people of color and low income communities.

When communities complain that emissions from an industrial source are causing harm, the immediate response is a denial by the source and agencies that exposure is occurring. Traditionally, industry and government control monitoring and play the “data game” to downplay community concerns. The game is played by monitoring at the wrong locations, at the wrong times, for the wrong chemicals, with the wrong equipment. The predictable result is a finding of “no harmful chemicals” that misleads the exposed population.

A glaring problem is the lack of appropriate and comprehensive air monitoring used by regulators, including the USEPA, to identify toxic hotspots – such as those identified by the USA Today study, Smokestack Effect – in order to get agencies and companies to reduce emissions that cross the fenceline and thereby reduce/eliminate exposures.

There is an urgent need to empower – not just inform or involve or access information – impacted communities through hands-on participation to conduct the actual monitoring, program design and data interpretation to ensure local knowledge is respected and incorporated.

Community air monitoring has been a gamechanger in places like Norco, LA, where African American neighbors of Shell wanted their community relocated away from the fenceline.  Agencies weren’t doing toxics testing until the community initiated their own monitoring program. Armed with data to back up their experience of toxic exposure, residents won a fair and just relocation program.

Lack of appropriate and comprehensive air monitoring

Across the board, USEPA and their delegated agencies use and require regulated sources to use out-dated, limited technologies and methods to monitor air:

Only 6 criteria pollutants

Limited fixed locations versus along entire fencelines

Toxic tests once every 6 or 12 days on a published schedule

Equipment deployed for toxic releases is often either the human nose or hand held monitors with occupational capabilities – that is incapable of detecting offsite health impacts

We are way behind not only European colleagues, but also a growing number of developing nations like South Africa. There a very few examples of these types of systems in the nation. One exists in Rodeo California at the Conoco-Phillips refinery where real time monitors along thousands meters of the fenceline – both upwind and downwind – were required because the community blocked a permit, negotiated an agreement, and got the county to include the system as a requirement of the land use permit. The data is reported to a public website in real time – something we need in all industrial sites in the country, starting with the Environmental Justice “hot spots.”

What is the solution? We need comprehensive and real time monitoring around known hotspots, especially schools. We need this monitoring around homes near industrial/toxic sources and on the fencelines of those sources, for the specific pollutants known to be released to the air – in short, hot spot monitoring, not the old style ambient and stone age approaches that smooth over and average away real problems. Why? So problem toxic sources can be identified and cleaned up.

Urgent need to empower impacted communities in hands-on air monitoring

USEPA and their delegated agencies must empower and train impacted communities to conduct air testing where they live, work, and play in a hands-on manner.

This would accomplish:

Building a working relationship with communities

Respecting and incorporating local knowledge and experience in the design, monitoring, and interpretation of air tests

Creating a cost-effective way to carry out such a program by involving people who are already working on their air issues locally

In Detroit, neighbors of the Marathon refinery used a community based air sampling method known as the Bucket Brigade to identify high levels of benzene flowing through the sewers and burping up inside their homes.  Incidentally, they found that Marathon might be the only oil refinery in the nation that is allowed to dump in the sewer system. This shows the value of empowering people to be part of an agency monitoring program.

Policy reform should include all possible opportunities through state and federal regulations, permits, Title V, enforcement, and settlements – everything – to move USEPA and their delegated agencies into the new decade when it comes to monitoring and cleaning up our air, especially in over-burdened Environmental Justice areas.

Meaningful chemical policy reform must attack the problem with a life cycle approach that focuses on production and use of toxic chemicals in consumer products. We need to bring the fenceline Environmental Justice communities to the forefront of the whole debate on chemical policy reform.