Shifting Science: The Alternatives

11-2 Shifting Science: The Alternatives Section Divider
Models of science, research and technology that put the protection of communities first, plus principles for future research. Models of science, research and technology that put the protection of communities first, plus principles for future research.
 

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Holistic Risk Assessment

A new paradigm for environmental risk management

Native American Nations have become increasingly concerned about the adverse effects that toxic substances have on human health and the health of the environments on which these communities depend (1-3). In the case of the Mohawk territory of Akwesasne, (a Native American community located along the St. Lawrence River between northern New York and western Quebec / eastern Ontario), local residents, environmental organizations and leaders have mounted a strong response to the environmental degradation of their lands and waters.

Beginning in the 1950s, cheap hydroelectric power provided by the St. Lawrence-FDR Power Project attracted several industries to the area that have since polluted Mohawk waters, land, sediment and air. The community is located immediately adjacent to the General Motors Powertrain Division, and is downwind, downstream and down-gradient from Reynolds Metals and the Aluminum Company of America, all federal or state Superfund sites. Toxicants such as polychlorinated biphenyls (PCBs), dibenzofurans, dioxins, polyaromatic hydrocarbons, fluorides, cyanide, aluminum, arsenic, chromium and styrene have been released into the air and water, and have contaminated the St. Lawrence River, its tributaries, and Mohawk lands, air and water, endangering traditional land usage, subsistence lifestyles and cultural practices.

For over 25 years, the people of Akwesasne have waged a difficult battle to ensure that PCBs and other toxic substances released from neighboring industries are adequately remediated and ecosystems restored to their former health. Despite years of research at Akwesasne, risk assessment methods used by outside investigators remain inadequate. Such methods fail to account for, or include, a holistic approach for assessing the social, cultural, and spiritual values, beliefs and practices that link the Mohawks to their environment.

Need for Change
Risk assessment has traditionally focused on the analysis of biologic, chemical and physical data regarding the effects of hazards, primarily to human physical health (4,5). In 1998, the U.S. Environmental Protection Agency (EPA) released its Final Guidelines for Ecological Risk Assessment, which focus on the evaluation of impacts to ecosystems (6). Risk assessments are performed on a routine basis by government agencies or their contractors, and are used as a foundation for decision-making and management of risk. The basic process entailed in conducting risk assessments of toxic substances involves estimating toxicity (and lack of toxicity), estimating real-world exposure, and comparing potency of toxicity with expected exposure.

However, because the scientific community can never know all the ways that a substance can affect individuals, it’s impossible to state with certainty that exposure will cause no or minimal harm. Scientists and activists alike have questioned the purpose of risk assessment, suggesting that it appears to justify harm inflicted on certain people by using the vocabulary of science to draw attention away from the need for action (7-9). Through its communitybased research, the Akwesasne Task Force on the Environment has found that traditional risk assessment and management models have not been effective in defining environmental risk, promoting remediation, decreasing exposure, or restoring community health at Akwesasne (10, 11). Further experiences reflect the use of scientific studies and debates as tools by responsible parties to manipulate situations and impede remediation and restoration, all to the benefit of the polluter (10, 12, 13).

Exposure is only one part of susceptibility to disease, and many toxicologic studies upon which risk assessments are based have been conducted using healthy groups of adult animals. Variations in susceptibility exist within Native communities and are based on a wide variety of factors including age, sex, genetic susceptibility, state of health and many other variables (3, 14, 15). Cultural value systems followed by Native people often mandate special protections and considerations be given for groups of individuals, including elders, unborn generations of children, and sensitive species of wildlife (3, 16, 17, 18). The concern for all people, especially the most vulnerable, may run counter to the processes followed by scientists conducting epidemiologic studies and risk assessments, who tend to focus on identifying average exposures in a given population and providing protection based on the average exposed individual. However, it is those persons in the 95th percentile in exposure scenarios who are the very people that First Nations’ decision makers are mandated to protect.

Sociocultural Implications
Impacts and risks to the social, cultural, and spiritual practices of Native peoples must be included in identifying and addressing risks to health (3,10,14,17,19- 21,22-24). In the case of the Akwesasne, it has been found that the traditional cultural practices that express and reaffirm identity and culture (i.e. gardening, hunting, fishing, trapping and gathering of plants) may increase exposure (or perception of exposure) of community members to toxic substances. At the same time, however, healthcare providers, community members, researchers, and environmental staff have been quick to note that adverse health effects have resulted when Mohawk people were forced to abandon traditional cultural practices in order to protect their health and the health of future generations (10,16,25,11,26,27).

In Akwesasne, potentially serious adverse health effects can result when people stop traditional cultural practices. When traditional foods such as fish are no longer eaten, alternative diets are consumed that are often high in fat and calories and low in vitamins and nutrients. This type of dietary change has been linked to health problems such as type 2 diabetes, heart disease, stroke, high blood pressure, cancer and obesity (26-28). Consequently, serious health problems can result when traditional foods are no longer consumed, even if there is little or no exposure to toxic substances.

Although most affected communities would agree that sociocultural impacts should be included in any discussion of risk assessment, current models have no way to incorporate or deal with these effects except to call them value judgments (29). Even recent attempts to develop frameworks that incorporate broader real world contexts and stakeholder participation into risk assessment continue to be flawed because “alternative” types of information (social, cultural, economic, environmental justice) are viewed as merely providing a context for risk assessment. No methodologies exist to allow valuable information about all effects to be integrated into the risk assessment itself.

A new paradigm of risk-based decision-making—distinct from the one in which Native people often find themselves in a reactive mode, committing valuable resources to attempt to improve poorly conducted risk assessments—is clearly needed.

Holistic Decision Making
Holistic risk assessment is a way to integrate human health and ecological risk, and make better decisions that are more protective of people and the earth as a whole (30-34). Such a framework integrates both a consideration of the effects of contaminants on the physical health of human beings, and holistically examines impacts on the natural world, and on cultural, social, subsistence, economic and spiritual practices. To incorporate these many different effects, a holistic model would need to examine and include aspects from many fields of study, integrating qualitative research findings with the sciences of toxicology, epidemiology and ecology.

This expanded definition of health would be more inclusive than just the absence of disease or injury. Many community members at Akwesasne, for example, believe that concepts of health should include and reflect traditional Native American values, attitudes, beliefs and practices. As with many Native communities, however, traditional views of health are integrated such that it becomes impossible to consider physical, mental, spiritual, and social well-being in isolation (16,27).

In addition to the physical, social and cultural determinants of human health, the health of the natural world is central. This is especially true for Native peoples, where relationships among and between human beings and the natural and spiritual worlds are built on concepts of respect, caring, appreciation, duty, purpose, and responsibility (3,10,14,34, 35-37). Health, then, has many definitions for the Mohawk people. Health is based on peaceful, sustainable relationships with other peoples including family, community, Nation, the natural world and spiritual beings.

To be successful in developing a holistic, integrated approach to addressing environmental contamination problems, it is essential that affected communities be involved directly in both meaningful decisionmaking and in researching impacts and alternatives. Support for community capacity building, training, community-level action, communication, and leadership building are integral to any successful research. Furthermore, as part of any risk management strategy, the affected community needs to play a key role in identifying ways to remediate, restore, or replace resources that have been affected.

It is clear that if a holistic approach is to be used to solve human health and environmental problems, it must integrate the best information that can be found from many different sources, especially those that are most knowledgeable and intimately con-nected to the problems at hand. The First Environ-ment Program at Akwesasne has worked to follow a community environmental health research paradigm that is based on principles of environmental justice. This paradigm states that knowledge must be generated and disseminated in a shared process within the community in a way that allows people to reclaim their power to protect their families and the natural world.

Finally, because it is essential to minimize the time in which individuals, communities, and ecosystems are negatively impacted, an effective means for evaluating decision-making processes needs to be developed to ensure that actions have focused on the right issues, have served to prevent problems, and have produced sound results in a timely fashion. In developing an integrated framework for risk-based environmental decision-making, there is much to be learned from Native people, who have experience in developing equitable partnerships and using holistic, integrated thinking to solve problems.

This article is adapted from an article published in the April 2002 issue of Environmental Health Perspectives. Mary Arquette, Maxine Cole, Brenda LaFrance, Margaret Peters, Elvera Sargent and Vivian Smoke are members of the Akwesasne Task Force on the Environment. Additional authors include Katsi Cook of Iewirokwas Program; James Ransom of Haudenosaunee Task Force on the Environment; and Arlene Stairs of Queens University.


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The Science of Precaution

Barrio Logan residents use research and land use planning to prevent harm

Environmental justice activists commonly complain about incompatible land uses that put community residents and polluting industries close to one another. Environmental Health Coalition (EHC) and residents of Barrio Logan in San Diego have advocated for more than 15 years to remedy land use dilemmas through such strategies as re-zoning; moving or shutting down small industrial facilities; and implementing maximum pollution prevention for large industries that cannot move such as shipyards.


11-2 The Science of Precaution_1
The community achieved a victory in March 2002 when a chrome plating shop, Master Plating, was closed by court order after an air toxics monitor found high levels of hexavalent chromium at residences nearby. Related outcomes include a new land use planning effort for the community, and action at the California state level to include environmental justice and land use considerations in air regulations and in new environmental justice policies focusing on precaution. EHC and the community applaud these successes but emphasize that precaution, not proof of harm, should be the guiding principle for scientific research, land use planning, and future environmental justice organizing.

Land Use in Logan
The Logan area is an historic neighborhood southeast of downtown San Diego. Since early in the last century, Logan has been a low-income Latino community. Median household income in Logan in 1990 was less than half the median in San Diego County as a whole.

During the 1960's the community was bisected by the I-5 freeway. The small portion of Logan that lies west of the freeway is Barrio Logan. Like many older, inner city neighborhoods, Barrio Logan has an incompatible mix of land uses that includes large and small industries, homes, freeways, railroad tracks, schools, Navy facilities and parks. It’s located adjacent to San Diego Bay, exposing the community to tons of diesel exhaust from ships and trucks going to and from the Port of San Diego. Some 129 industries with regulated hazardous materials coexist with its 5,440 residents in an area of less than 1.2 square miles.

EHC recognized that proximity to major roads and freeways that cut through the community was a major concern. A majority of Barrio Logan residents live within 500 feet of a freeway or major road. Since the mid-1980s, EHC has worked in the Barrio Logan community to gather information about air quality. As EHC documented the results of the mixed use zoning that prevails in Barrio Logan, it became aware of probable health hazards to residents from toxic air emissions from a wide variety of businesses located nearby, often next door to homes. Residents told EHC that their children seemed to suffer more asthma, upper respiratory infections, and skin and eye disorders than they had in other communities.

Research and Results
EHC recognized that an air toxics monitor was critical to determining the severity of air quality in the Barrio. EHC appealed directly to the State agency that oversees the local air pollution districts, the California Air Resources Board (ARB). ARB was already engaged in neighborhood level air toxics monitoring in Los Angeles, was familiar with environmental justice concerns, and had a monitor available. In the months that followed, the decision was made by EHC and ARB to place a monitor at a middle school, Memorial Academy, situated about a half-mile from the largest shipyard and two blocks from a major freeway.


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Chrome platers and their hexavalent chromium emissions had been identified by EHC and community residents as a cause for concern for more than a decade. Standard computer models of dispersion of air emissions cannot accurately predict the concentration of pollutants very close to the source, yet there are residents living within 10 feet of the plating shops in Barrio Logan. Monitoring at Memorial Academy did not resolve the question of whether hexavalent chromium was present at high levels near the emission sources. Accordingly, ARB agreed to place six monitors at residences located within 200 feet of two chromium platers on Newton Street in Barrio Logan.

Monitoring was conducted from December 2001 through May 2002. High levels of hexavalent chromium were measured at the monitors near the plating shops on Newton Street. The highest levels were found in the front and back yards of one home situated immediately between the two platers. The ARB was so alarmed by the results that it issued a press release and sent a notice to the San Diego County Public Health Officer. Then the agency conducted extensive follow-up monitoring of indoor and outdoor chromium levels at both plating shops, Master Plating and Carlson & Beauloye. The average level at the backyard monitor over the entire monitoring period corresponded to a lifetime cancer risk of 114 per million, which is several times higher than federal standards for an acceptable cancer risk.

ARB and APCD also tracked the measured levels of chromium in relation to the levels of electroplating (measured by amp-hour readings), maintenance and cleaning procedures, and other activities at the shops. Analysis of the data persuaded ARB that Master Plating was the more likely source of the high outdoor levels of chromium. Subsequently, the County of San Diego filed a lawsuit against the owner of Master Plating on March 15, 2002. A temporary restraining order stopping the chrome plating operations was issued ten days later.

Shift in Strategy
The final impetus to shut down Master Plating followed an intensive air monitoring effort that cost the State government more than a million dollars. Unprecedented media coverage of the chromium findings, and election year politics, also figured into the outcome. However, because of the expense and effort, this is clearly not feasible as a routine method for addressing the thousands of other communities plagued by incompatible land uses. Dozens of facilities like Master Plating exist in Barrio Logan’s residential neighborhoods. Because local residents can’t wait for problems to be addressed one by one, incompatible land uses and environmental harm must be addressed from a broader perspective.

Historically, cities and counties have allowed industrial activities to occur in communities of color without regard to health and safety of residents. This echoes the pattern seen throughout the country, where less desirable land uses are placed in neighborhoods with the least political clout to challenge them. The challenge today is to reverse these discriminatory land use patterns.

EHC is committed to making sure that the closure of Master Plating is the kickoff to the elimination of toxic pollution from this community and other disproportionately affected communities. The shift to land use planning as an approach to protect community residents from toxic hazards is a precautionary model, one that aims to identify and prevent probable toxic hazards. In our precautionary land use planning process, we are using available scientific data on air emissions and presence of toxic substances to develop priorities—not to “prove” with absolute certainty that people are being harmed. The presence of facilities that emit chromium or diesel exhaust close to homes and schools in the Logan community almost certainly exposes residents to harmful compounds. Development of a community plan to phase out facilities that are close to residences or schools conforms with key aspects of the Precautionary Principle—i.e., to err on the side of safety and to include in decision-making the voices of those exposed to hazards.

Outcomes and Future Organizing
EHC and Barrio Logan residents’ efforts are having a direct impact on the community’s health and quality of life. Their work helps form the basis for the following state and federal policy changes:

  • The California ARB is re-evaluating and amending the Air Toxics Control Measure (ATCM) for chrome plating. Continuing efforts are needed to identify and address all sources of chromium emissions by land use planning, pollution prevention and tighter regulation.
  • ARB has also adopted Policies and Actions for Environmental Justice, the first by any agency of the California EPA, which include provisions that require development of a land-use guidance handbook (www.arb.ca.gov/ch/ej_meetings/may_10_2004_draft _land_use_handbook.pdf) to assist local officials in making informed land use decisions by considering the impacts to public health when sources of air pollution are located near residential or other sensitive land uses.
  • The City of San Diego has committed to revising the zoning and community plan for the area to address incompatible land uses. This spring, EHC and allied community organizations hosted a series of training and visioning sessions to empower community residents to be at the forefront of the community planning process.
  • The California Environmental Protection Agency adopted Environmental Justice Guidelines which require incorporation of a precautionary approach, including addressing community planning and undesirable land uses.

Joy Williams, Diane Takvorian, Paula Forbis, Melanie McCutchan and Sonya Holmquist of the Environmental Health Coalition (EHC) contributed to this article. EHC is a nonprofit environmental justice organization that works in the San Diego/Tijuana region.


 

  1. California Air Resources Board. Technical Support Document (Preliminary Draft), Air Quality at Memorial Academy Charter School in Barrio Logan, a Neighborhood Community in San Diego (October 1999 - February 2001), March 15, 2002 draft.

Body Burden Research

Communities can use biomonitoring to pinpoint poisons, and fight back.

What if you found out that the toxic chemicals and heavy metals found in hazardous landfills were also in your body? Then, what if you learned that the companies and industries responsible for producing those poisons were not held accountable?

To answer those questions, in July 2002, eight volunteers and I agreed to have our blood and urine tested as part of a unique scientific research project initiated by the Environmental Working Group (EWG) in coordination with Mount Sinai School of Medicine and Commonweal. The Body Burden project was designed to identify more than 200 industrial chemicals and heavy metals in the human body. The volunteers, hailing from California, Louisiana, New York, and Virginia, had a special interest in participating in this research based on diverse experiences dealing with environmental and health issues. Their backgrounds included broadcast journalism, cancer patient counseling, breast cancer advocacy, community organizing, environmental research, litigation, and advocacy. We all wanted to know our “body burden”—that is, the type and concentration of toxins in our bodies, and the sources of these toxins.

As an attorney dedicated to environmental justice, I was more than a little curious about the impacts of industrial manufacturing on my health. I wanted to use the results of my body burden testing to make people aware of the fact that industrialization has contaminated our bodies with toxic pollution— pollution that can harm our health and the health of our children whose development from conception is threatened by the body burden of their parents.

My initial reaction upon receiving the three-ring binder filled with laboratory data and explanations was one of grief followed by anger. Although I have never lived near a landfill or a major polluting facility, I carry 77 different industrial poisons in my body. Through the simple acts of breathing, eating, and using ordinary products, I have absorbed these poisons, including polychlorinated byphenols (PCBs) and dioxins, which were banned in the United States but still remain in the environment. My body burden includes toxins that can cause cancer, reproductive damage, lung and liver disease, among other ill health effects.

11-2 Body Burden Research
Through this experience, I gained a deeper understanding of the profound sadness that community activists, who live atop landfills in Louisiana or in the shadows of the 130 petrochemical facilities in the state, must have felt when they first learned that their health and the health of their family members were jeopardized by the pollution around them. In the living rooms and kitchens of community activists, I’ve heard the stories of sons and daughters dying from cancers or being rushed to emergency rooms because of asthma attacks. Much of my work focuses on providing legal and advocacy services to African-American community leaders, who struggle for a clean and healthy environment in neighborhoods that are the dumping grounds for oil refineries, petrochemical facilities and power plants. We work together to find ways of defending families and communities from proposed hazardous industrial developments; reducing pollution at massive oil, chemical, and waste facilities; cleaning up contaminated areas; or relocating residents.

Community leaders have long used air monitoring devices to effectively compel the U.S. Environmental Protection Agency (EPA) and industrial companies to reduce pollution. They believe that body burden research, or biomonitoring, is the next step in achieving greater pollution reduction and elimination of industrial toxins. However, they’ve learned that in order to benefit from any research method, they’ve got to be in control of not only understanding the data, but also how it is collected and interpreted. To strengthen their capacity, they’ve discussed strategies that involve developing community experts on biomonitoring; conducting community-wide biomonitoring training workshops; counseling community volunteers; creating effective and respectful partnerships with laboratories and health researchers; planning the design of scientific research protocols and methodologies; and targeting local industrial sources of toxic pollution through biomonitoring research and advocacy.

Holding polluting industries accountable for the chemicals they manufacture and sell is long overdue. Many companies would be forced to develop safer alternative materials or undertake other activities to avoid the threats of their toxic chemicals on human health. In the United States, an inconsequential number of industrial chemicals have been thoroughly tested by U.S. environmental and health agencies for their impacts on human health. Some 75,000 chemicals remain untested despite the fact that they are manufactured in processes involving dangerous operations, transported on barges and trains with a record of hazardous spills requiring emergency response, and, ultimately, placed on the shelves of stores for our consumption. The European Union is considering legislation titled Registration, Evaluation, and Authorization of Chemicals, abbreviated as “REACH,” which would require testing chemicals for safety and, depending on the results, restricting existing and proposed industrial chemicals before they could be sold. However, news reports have uncovered that the U.S. EPA, in concert with the chemical industry, is aggressively opposing the passage of REACH into European law.

While our society demands safety in a variety of products and services, we have unwittingly allowed our government to sacrifice communities of color and our individual bodies as landfills for a host of healthdamaging industrial chemicals and heavy metals. An important lesson that I learned as a result of the Body Burden study is that I have 77 more reasons for advocating that companies stop their toxic poisoning of our health and future.

Monique Harden is an attorney and co-director of Advocates for Environmental Human Rights, a public interest law firm in New Orleans, Louisiana. Information about the Body Burden research project can be found at http://www.ewg.org/reports/bodyburden/.

Biomonitoring

What communities must know

Biomonitoring, the study of chemical burdens in our bodies through the testing of bodily tissues and fluids (blood, urine, breast milk), can be an important community health research tool. It creates a new form of community right-to-know and can bolster organizing campaigns by providing objective evidence of exposure. However, many environmental health researchers and advocates are concerned about potential pitfalls for low-income communities of color. Some of the potential limitations to the promise of biomonitoring may include:

  • Biomonitoring alone may not provide the answers community members are seeking. Because there are few established relationships between levels of chemicals and health effects, and because health harm may result from cumulative exposures to multiple chemicals, biomonitoring of any particular chemical alone may not give sufficient information to establish links between the environment and a particular illness.
  • Biomonitoring identifies exposures that have already occurred. For example, many childhood lead poisoning prevention programs rely on testing children’s blood to identify children at risk. The problem with this approach is that it is an “after the fact” approach—by the time lead has reached levels of concern in the blood of children, damage may have already been done, and may be irreversible. This approach also essentially casts children as human lead detectors. More “upstream” approaches to lead poisoning prevention are now requiring mitigation of lead hazards in the home environment without relying on blood lead levels.
  • Biomonitoring may ignore the problem of short-term chemical effects. Certain toxins act as “drive by” chemicals; they enter the body, do extensive damage, and then leave. These chemicals represent a whole class of acute, non-bioaccumulative toxins (such as methyl isocyanate the chemical released in the 1984 Bhopal disaster) that may not be addressed through biomonitoring efforts.
  • Biomonitoring may mislead. Unclear communication of results may lead to alarm and decision-making that is adverse to health. For example, someone who may benefit from fish in his or her diet may stop eating fish after hearing about the pesticides contaminating fish. Similarly, many biomonitoring efforts focus on breast milk monitoring, because toxins accumulate in breast milk. But despite efforts to reinforce the desirability and superiority of breast milk for infants, concerns raised by perceptions of contamination may discourage breastfeeding.
  • Biomonitoring is expensive. The costs of biomonitoring can be prohibitively high for many community-based organizations. Furthermore, community groups need significant resources to interpret and apply biomonitoring results.
  • Biomonitoring may focus community attention on a single problem, diverting it from other related social and environment factors that affect health. Ill health is a product of environments where exposure to toxins occurs alongside other social and economic hazards. The relationships among a range of adverse conditions and human health is best considered comprehensively.
  • Biomonitoring can be used by industry, too. Industry has long relied on science as a tool to promote their agenda. Some industries, such as the American Chemistry Council (ACC), actually support biomonitoring. As one ACC representative has noted, “We as an industry have totally embraced biomonitoring because it takes all the guessing out of what people are exposed to.” In other words, biomonitoring may justify industry claims if little or no exposure, or link to illness, is confirmed through testing.

As with all research, communities should insist on meaningful participation in the process; coordinated documentation of information; legal access to data; training on data interpretation; and public accountability to ensure research leads to meaningful social change. Absent these elements, biomonitoring is subject to serious limitations that result from ignoring the moral and political context in which the research is done.

Compiled by Rajiv Bhatia, MD, MPH, director of the San Francisco Department of Public Health Section for Occupational and Environmental Health; Barbara Brenner, executive director, Breast Cancer Action; Brenda Salgado, program manager, Breast Cancer Action; Bhavna Shamasunder, environmental health and justice program associate, Urban Habitat; and Swati Prakash, environmental health director, WE ACT for Environmental Justice.

Principles for Research

Four ways to make environmental decision-making more just

1) Make the decision process more democratic. Decisions affecting public health and the environment are often made without input from impacted communities. For example, government agency approval of a proposed project is often based on the results of a risk assessment, which is normally conducted by expert consultants hired by polluting companies or by government agency professionals. Communities rarely have the resources to participate in these technical studies, and therefore have limited participation —if any—in the decision-making process.

One way of making environmental decisions more democratic is for agencies to provide funds to affected communities so they can hire their own experts to independently analyze a proposed project and develop community-based alternatives. Some governmental programs provide examples of what a more democratic approach to environmental decision-making might look like (e.g., EPA’s Technical Assistance Grants for communities affected by Superfund sites). However, such programs are limited and don’t address pollution prevention. Opportunities for meaningful and enhanced public participation must be provided before agency decisions are made. Communities have a right to know about the potential effects of a proposed activity before approval. Agencies should conduct extensive public outreach to facilitate community participation early in the process. Technical assistance should be provided for independent community review of proposed projects and alternatives. Finally, this process must ensure that public input can actually affect the outcome.

2) Use a more holistic approach. Instead of looking only at the risks of a proposed activity, officials should be urged to explore and analyze a full range of alternatives, including not taking any action. Decision makers should consider both the risks and benefits of the full range of options, allowing serious consideration of the alternatives developed by affected communities. This method of environmental analysis has been called “alternatives assessment,” and is used in a more limited way to analyze governmentsponsored projects under the National Environmental Protection Act (NEPA). Environmentalists have advocated that a more comprehensive and democratic form of alternatives assessment should become a fundamental part of all types of environmental decisionmaking, including permitting of industrial facilities, building of new freeways, and development of new consumer and industrial products. As in the NEPA context, environmental justice advocates can insist on being a part of the process throughout, and communities could develop and submit their own alternatives to a proposed activity.

Unfortunately, environmental decisions made under other laws do not normally allow for this form of community input. Even the NEPA process is not a panacea, since there is no requirement that the chosen alternative be based upon the needs and desires of affected communities. Therefore, to replace the current risk assessment and environmental decisionmaking paradigms with a process that is more just, community groups will need to pursue a long-range strategy of obtaining broad changes to most of our national and state environmental laws.

3) Use the principle of precaution. The Precautionary Principle says that where there is a threat of harm to human health or the environment, we should act to prevent it, even if causation is not conclusively established. The Precautionary Principle seeks to minimize harm by exploring a full range of alternatives for a well-informed decision.


11-2 Principles for Research

Important qualitative and semi-quantitative information about the potential adverse impacts of an activity is often available and could be used to make environmental decisions more comprehensive, more democratic and more health-protective. This is especially the case if one considers risk assessment not as a stand-alone decision-making process, but as one component of a comprehensive alternatives assessment. The use of the Precautionary Principle in this context would ensure that environmental decisions are made using the widest range of information available, while still allowing for a consideration of quantitative risk information. In this way, communities can advocate for the lowest level risk option.

4) Incorporate cumulative impacts. Project approval is often based on a narrowly conceived approach to risk management, with a singular focus on incremental risk. In reality, however, individuals are exposed to risks from a wide variety of substances from multiple sources of pollution, the cumulative impacts of which are ignored in decision-making. Under the risk assessment paradigm, individual health risks are determined to be within an “acceptable” range. Yet risks from multiple substances or clusters of sources together may easily exceed the range of “acceptability.” When added to existing risks, the incremental risk from a new source may create an unacceptable health burden in a community. Environmental justice advocates have long argued that agencies shift from traditional risk assessment towards a more comprehensive evaluation of cumulative impacts.

Some form of cumulative impacts evaluation is conducted in a number of environmental settings. For example, NEPA and other similar laws require cumulative impacts analysis of proposed federal actions, including past, present and likely future impacts, recognizing that actions may seem to have relatively minor impacts that become collectively significant over time. Under the Clean Air Act, area-wide assessments for specific pollutants are commonly prepared for planning purposes. In the Clean Water Act context, for example, when a waterway is over-polluted, the area must identify a “control strategy” sufficient to achieve reductions to meet water standards.

In the permitting context, agencies should identify “hot spots” where health risks can be limited with the goal of risk reduction. Agencies should evaluate the total health risk in an affected area before allowing additional pollution. This can be done through an area-wide grid or parcel study, on a caseby- case basis, or by conducting modeling and estimating risk for common source scenarios using existing data. Emissions from all types of sources should be used to estimate risk. When an agency lacks regulatory authority over a pollution source in the area, it should collaborate with the appropriate agency to collect data and explore options to reduce risks. To begin incorporating cumulative impacts into risk assessment, agencies should consider the additive effects from all pollutants at a facility and consider effects of other pollutants in the affected area. Risk reductions and/or local “offsets” should be required.

Agencies respond that they have limited resources and lack guidance in this regard. Tools and data exist to conduct these studies. Until a full budget for a comprehensive program is available, fees should be charged to project proponents for a full impact evaluation. However, lowering “acceptable” levels of risk may require grassroots political power as much as scientific evidence of harm.

Adapted in part from recommendations prepared for the Environmental Justice Air Quality Coalition by the Environmental Law and Justice Clinic at Golden Gate University School of Law in San Francisco.