My search uncovered a standard array of petroleum spills from leaky underground storage tanks throughout the town, including a somewhat significant one at a gas station adjacent to my daughter’s school. Luckily, the flow of ground water appears to move away from the school’s building footprint; although the contamination appears to have migrated offsite through the utility corridor, and was bad enough at one point to have warranted concerns about vapor intrusion at neighboring properties. The state is still working on that.

I also learned about soil and ground water contamination beneath the former Standard Register facility, now occupied by Connor Homes, and how the Subway on Court Street used to be a dry cleaner. Yes, indeed a dry cleaner that had an historic release of chlorinated solvents. When the problem was discovered some 20 years ago, plumes of tetrachloroethylene (PCE) and its carcinogenic degradation products had already migrated offsite, spreading beneath the neighboring residential properties and heading toward the daycare center located immediately behind.

I remember feeling a jolt as I read through the site records, as one of the owners of the offending dry cleaner bore the same last name as mine, and perhaps even more jarring because I have friends whose young children are currently enrolled at that daycare.  But I also recall feeling grateful —as I often did when I worked in the regulatory field— for the foundation of regulations that enable problems such as these to be addressed. The investigation report I read indicated that contaminated soils had been removed, that indoor air monitoring had been conducted for the daycare and neighboring homes years ago, that exposure pathways for sensitive receptors had been evaluated — in short, that the problem hadn’t been ignored.

If you are a parent of school-aged children like I am, you have no doubt encountered the locked doors and sign-in sheets at the front office of your child’s school. You may have submitted to the required background check before serving as a classroom volunteer, and have most likely provided documentation for your child’s receipt of the required vaccinations to attend their public school. These are just a few of the many protective layers that have been put into place to guard the health and safety of our kids, and many of them —like the heightened security and locked entrances, for instance— probably a reactionary procedure born from some tragic, preventable event.

It’s easy to forget the origins of such protective measures, especially when the threat is no longer visible. Easy for parents to forgo vaccinations for their children without the shadow of an iron lung looming overhead, because the regulations that were put into place have successfully kept our exposures at bay. But the threat is still present, and cracks in the armor of those protective measures invite the risk to come back in, as reminded by the few cases of whooping cough that cropped up at our school this year.

Having worked in the public sector, I am fully aware of the inefficiencies that plague the regulatory sphere. Improvements can always be made, I agree, but regulations are often there for a reason, their very purpose a storied affair. What would have happened, I wonder, if there were no rules? If the dry cleaner hadn’t been required to investigate and remediate its mess, if nobody even knew? What would the kids of the Mary Johnson Child Center be breathing into their lungs while they napped on mats along the floor?

I guess that’s why I’m so disgusted by the efforts of Trump and his supporters to usher in Cabinet members who seem so committed to the unraveling of protective regulations — everything from economic and education policies to environmental protection. It’s as if they’ve conveniently forgotten the critical events that have shaped the policies of the agencies for which they’ve been tapped to represent. And though it’s been nearly 30 years since Love Canal and the resulting Superfund legislation, it’s been less than a year since the lead-contamination tragedy in Flint, Michigan, and only 5 months since the PFOA crisis for the citizens of Hoosick Falls, NY.

If providing safe drinking water to our children isn’t a fundamental American value, then I don’t know what is.

Or maybe that’s just it. Maybe this incoming administration is just a timeline marker for the seismic shift of American values from a commitment to the preservation of health and human rights to something a little more… green.

Look, American industries have been complaining about regulation since the first regulations were ever passed. Cut the red tape, they say now, so we can be competitive with China.

Like this?

Or this?

That used to be us. I thought we already decided that wasn’t acceptable for our future generations. And remember child labor?

 Even that had to be regulated away.

But now I’m beginning to wonder if it ever really went away. Because the truth is, the burden we’re currently placing on the backs of our future generations might be the most brazen form of child labor that there is.

Photo credits:

Flint boy: npr.org

China air pollution: journal-neo.org

China water pollution: demilked.com

Addie Card, anemic little spinner in North Pownal Cotton Mill: Lewis Hine

There is no Planet B: Inhabit.com

The post If There Were No Rules appeared first on Mary Heather Noble.

But no one’s had it as bad as the 1,200 residents of the West Calumet Housing Project in East Chicago, Indiana — whose homes are actually located within the boundaries of the USS Lead Superfund site — and who have been told to relocate their households on short notice, due to critically unsafe levels of lead in neighborhood soil.

It’s been reported that two-thirds of those residents are children. Many of them are now lead-poisoned children. Nearly all of them have brown skin. I scroll through article after article, photos of black kids sitting on front steps, next to big EPA yard signs warning, “DO NOT play in the dirt or around the mulch.” With an illustration of a brightly-colored ball on fresh green grass, just to make the message clear.

What is it, exactly, that I want to say about all this?

My first impulse, just an echo of what has already been said: This never should have happened. Of course it shouldn’t have happened. We (they) should have known better.

Except that the West Calumet neighborhood was developed in the 1960s and 1970s, when the EPA was in its infancy, and before Superfund even existed. And I can tell you from personal experience in environmental remediation that stupidity was a pervasive problem in historic land use decisions. (Who builds a residential neighborhood on a former lead smelting site? The same type of planners who build a school and residential neighborhood over a filled, toxic canal that has been purchased for a dollar.)

But there’s more to this case than just the 20-20 hindsight of spackling over industrial blight. What I’m trying to say, is that when I read about 29 children with blood lead concentrations significantly over the CDC’s level of concern, all because they are living and playing in yards with lead levels containing as much as 227 times the lead limit allowed by the EPA, and then I think about how long this hazard has resided in the soils of this community, and how long that soil has been kicked up into dust by Goodwill-purchased sneakers, and tracked into hallways and wiped onto hand-me-down shirts tossed onto the backs of kitchen chairs before those children rifle through the pantry for something good to eat — when I think about what has happened here, and how long it’s really been happening, it triggers the same visceral anger I felt when I first started learning about PFOA.

Here’s why: Because both public health catastrophes reveal the same dysfunctional premise upon which our environmental health practices seem to rely (especially in low-income areas). Which is to say: Action need not be taken until harm has already been caused.

The EPA is quick to mention that action has, in fact, been taken. And yes, approximately 90 of 1,200 properties in the neighborhood were sampled during a three-year investigation started in 2003. Roughly half of the sampled properties contained lead-contaminated soil above the EPA’s standards, and 15 of those were contaminated enough to require time-critical removal action by the agency in 2008. These data were used to justify the neighborhood’s designation as a Superfund site in 2009, and an additional time-critical removal action was taken in 2011 for 16 additional properties. So yes, action was taken for some properties… sporadically, over a long period of time. My oldest daughter was born in 2003. A lot of childhood development happens during a 12-year period.

So one wonders what action was taken for those whose properties weren’t tested, or whose soil was tested but didn’t meet the threshold for emergency removal. A flimsy pamphlet on how to reduce your lead exposure? A recommendation that you wash your children’s hands and toys when they come inside from play? And one wonders how much action was taken to educate new residents of the neighborhood and housing project over that 10+ year period. A public notice for a public meeting?

Widespread testing to determine which soils needed removal was not initiated until 2014. In response to the shock and outrage recently expressed by residents of the West Calumet Housing Project over the sudden urgency of lead contamination in their neighborhood, Robert Kaplan, acting administrator for the EPA’s Great Lakes Region, told The New York Times that EPA “had in fact warned West Calumet residents for at least a decade to avoid the soil with public notices and community meetings.” Clearly a statement in the agency’s defense, but one which also implies that not only should residents have known about the lead, but that their ignorance about the matter may have played a role in their family’s health effects.

I can think of no greater insult beyond the trespassing of an industrial contaminant across the boundaries of my own cells and those of my children, than the suggestion that its preventable harm was solely my responsibility.

Kaplan’s remarks stink of a patriarchal you-should-have-known-better mentality, a scorn typically reserved for a scantily-clad sexual assault victim found in her pitiful shredded clothes.  What did you expect, living in the projects? You knew that there was lead.

Let us be clear. They were warned for at least a decade to avoid the soil. Not “We regret that it has taken this long to take full action on this issue.” Or simply, “We’re sorry, we didn’t know it was this bad. We are working on fixing the problem.” The sad irony of Kaplan’s subtle judgment is this: Even if West Calumet residents had been scientifically knowledgable enough to deduce the hazards in which they lived, or civically savvy enough to be fully engaged in the Superfund public process, what could they have done? Where would they have gone? The state and federal government certainly wouldn’t have footed any bills on the possibility that they might be harmed. They would have certainly wanted some proof.

Proof which requires routine blood lead testing and consistent funding of such programs — an issue in Indiana, I suspect, considering its less-than-stellar commitment to public health funding. It’s quite the lesson in environmental injustice, on the interconnectedness of environmental degradation, public health, race, politics, and urban American culture. An ugly, despicable lesson, but one that must be dragged into the light.

Photo credit: nbcnews.com

Works consulted: Final Feasibility Study Report, U.S. Smelter and Lead Refinery (USS Lead) Superfund Site

The post Bloodletting/Blood-lead-ing appeared first on Mary Heather Noble.

I guess that’s what makes the recent drinking water catastrophes in Flint, Michigan, and Hoosick Falls, New York so upsetting — because technically, both of those systems appeared to be in compliance with the Safe Drinking Water Act. Technically, water sampled from the City of Flint’s water treatment plant met drinking water standards for lead, even though that same water was corrosive enough to erode lead-bearing private and municipal infrastructure and produce (in some homes) tap water samples high enough in lead to be qualified as hazardous waste. Technically, the Village of Hoosick Falls Water Department appeared to have a flawless performance record, producing water of such quality that the Hoosick Falls Water Treatment Plant was once honored by the New York Rural Water Association as Rural Water Treatment Plant of the Year. In fact, Hoosick Falls’ water was named the best-tasting water in Rensselaer County in 2013, and did well enough in regional competitions to make it to the finals at the New York State Fair. And yet, until recently, water distributed from that perfectly compliant, award-winning plant contained alarming concentrations of perfluorooctanoic acid (PFOA), exposing thousands of unsuspecting residents to a chemical whose toxic health effects are just beginning to be understood.

I’m neither a resident of Flint nor Hoosick Falls, but I can imagine that the betrayal cuts deep, the violation of trust like a swift punch to the gut. It’s as if you asked a trusted friend to babysit your children, but when you got home, you found a stranger with a history of violent criminal behavior watching them instead. How did this even happen? How long has this been going on? What does this mean for the future of my family’s health and well-being?

When water hurts, your understanding of the world gets turned upside-down. The very essence of your cells and those of your children have been violated, their walls trespassed against by chemicals that may or may not hold your bodies hostage, that may or may not, at some time in the coming years ahead, commit some type of unspeakable harm. The anxiety is both tangible and intangible, acute and everlasting. When water hurts, the harm is real — even if the physiologic manifestation of that harm is not diagnosed for many years.

As a former environmental regulator, I have had the unfortunate experience of informing someone that their water has become contaminated — that their private well intersected a petroleum or solvent plume and their water was no longer safe to drink. There is little to say to dull the blow, little that can be offered to calm the fears of what might happen later on. So we focused on the solution. Our course of action always included bottled water as a temporary fix, in-situ treatment systems and monitoring plans as an acceptable long-term solution, but the holy grail for solving a potable water problem in our line of work was to connect them to  public water. Public water was the life boat, the safety net, the thing that delivered you unscathed to the other side.  It was the solution to the problem, not the problem itself.

But it seems this is no longer the case. Or rather, perhaps it never was. The unsettling discovery from the past few months is that the systems designed to safeguard and monitor our public drinking water systems are un-protective, incomplete.  We are vulnerable to a national crisis of antiquated water infrastructure, and we are limited by the narrow scope of authority that our regulatory agencies have.

To that point: the most contaminated public well in the Village of Hoosick Falls is reportedly located a mere 500 yards from the Saint-Gobain facility — a facility that has handled PFOA in the manufacturing of Teflon products since at least the 1960s. Though a clear hazard to a public source of drinking water, plant operators were never required to report releases of PFOA to the EPA, because the chemical wasn’t regulated, and the Village was never required to look for it because it wasn’t on the list. Why? Under existing chemical policy, compounds are considered safe until proven otherwise, and the EPA is granted neither the time nor the resources to adequately study the toxicity of the 85,000 industrial chemicals currently in use. PFOA is just one of those compounds.

The municipal water systems of Flint and Hoosick Falls are not the first public drinking water systems to become contaminated in this country, nor will they be the last. But one would expect our public health and environmental agencies to at least be equipped with the authority to handle the emergencies that arise. As long as chemicals for which human health and environmental impacts are not yet known can be incorporated into consumer products and released into soil, air, and water — as long as these compounds can loiter in our drinking water resources, unmonitored and unaddressed, our current rules are not enough.

The post When Water Hurts appeared first on Mary Heather Noble.

But no matter how savvy I think I am about the science, or how much people like me tend to believe that science is what’s going to save us, there is but one essential discipline whose role is really the driver of this bus.

Remember that phrase coined by political strategist James Carville in the 1990s? “It’s the economy, stupid.” Well, I can’t seem to get that phrase out of my head… again. And while Carville’s point back then may have been to emphasize the importance of the struggling economy in the 1992 presidential election, my point in resurrecting the phrase is this: It doesn’t matter how the science explains the cause-and-effect relationships involved in an environmental health crisis. What really matters is the why it happened — which, unsurprisingly, is almost always a matter of economics.

Take Flint, MI, for instance. Sure, I understand the science behind what’s happened:  Water drawn from the Flint River and delivered to Flint’s municipal water customers from spring of 2014 on was more corrosive than the City of Detroit water they had been using prior to then, so the new water literally ate through their aging infrastructure, causing lead and other particulates to pour from their taps. Chemistry 101, right?

But the science doesn’t explain how Flint River water got into the pipes in the first place, nor does it explain why months passed without any corrective action, despite complaints from residents about the visible contamination of their drinking water. Science also fails to provide an acceptable explanation for why Flint pediatrician Mona Hanna-Attisha was belittled and attacked when she released her findings that the percentage of Flint children with abnormally high blood lead levels had doubled since the City switched its water supply. Or why it wasn’t until late December and early January that authorities declared the continued lead poisoning of Flint’s children as the emergency that it was.

More than a year of daily, chronic exposure to lead-contaminated water has occurred in hundreds of Flint households — in a predominately African American community where over 40% of the population lives below the poverty level. Science? No, I think another discipline might be at play. You can almost see the words in the thought bubbles hanging above the City and State officials’ heads: It’s just for a few more months. Really, what difference does it make?

There’s an important term that is often tossed around in civil discourse about economics: “moral hazard.”  Moral hazard refers to the elevated risks one party might take in an economic transaction because another party will bear the negative consequences of those risks. We heard a lot about moral hazard around the Wall Street bank bailouts in 2008, and we often hear conservative grumbling about the moral hazards of the Affordable Care Act —or any social service program, for that matter— and how it isn’t fair for the taxpayers to pay for someone else’s (potentially irresponsible) personal choices.

But the concept of moral hazard is seldom discussed around matters of environmental or personal harm, when the asymmetry of risk involves something other than cold hard cash. Which seems misguided, since the underlying presence of unfairness is the same. Think about it: What if the moral hazard threatens one party’s ability to breathe? The ability to drink clean water? The ability to go to school or play in a city park without getting shot? Where are the conservatives then?

I don’t present this idea as a theoretical argument, because unabated moral hazards are yielding environmental and human health tragedies as we speak. Consider for a moment the economic equation controlling gun regulation in this country.

Consider the matter of DuPont in Parkersburg, WV, where, for decades, the company dumped thousands of tons of perfluorooctanioc acid waste (PFOA, formerly known as C8, the main ingredient in Teflon) into the Ohio River, unlined ponds and beyond, causing widespread contamination of surface and drinking water resources in Parkersburg and surrounding communities. DuPont not only exposed thousands of people to a toxic chemical, they actively concealed the known health effects of PFOA (identified in their own internal toxicology studies) for decades, so they could continue to bring in over $1 billion per year in profit from their highly successful Teflon products (read the recent New York Times article about the case here, a Huffington Post article about it here, and a slightly older one from The Intercept here).

DuPont had even developed a different chemical to replace PFOA in the early 1990s—one that was reportedly less persistent in the environment and stayed in the body for a shorter duration of time— but the company ultimately decided against replacement because the economic risk was too great.  Of course, when the exposure imposed upon workers of DuPont and the 70,000 people served by PFOA-tainted drinking water systems is factored into the equation, along with the link between PFOA and birth defects, kidney cancer, testicular cancer, thyroid disease, and other serious ailments, one wonders where the asymmetry of risk really falls.

—Which brings me back to my point: This is an economic equation, a deeply unbalanced one that is designed to limit the loss of profits, the loss of dollars and cents. Until we start attaching appropriate value to the lives at stake in these institutional transactions, I’m afraid the science is never going to be able to catch up to our inevitable loss.

Photo credits:

npr.org

dispatch.com, Chris Russell, Dispatch file photo

The post Moral Hazard: It’s More than Economics, Stupid appeared first on Mary Heather Noble.