United States
Environmental Protection
Agency
Policy, Planning
and Evaluation
(3103)
EPA-230-R-92-Q08
June 1992
v>EPA Environmental Equity
Reducing Risk for
All Communities
" >*»-
r/n?ed on Recycled Paper
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
May 29,1992
Mr. William K. Reilly
Administrator
U.S. Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Reilly:
In July of 1990, you established the Environmental Equity Workgroup. You
directed the Workgroup to review the evidence that racial minority and low-income
communities bear a disproportionate environmental risk burden. You asked the
Workgroup to make recommendations for Agency action on environmental equity
issues. The following report contains a summary of the information collected and
the Workgroup's recommendations.
The literature relating environmental risk to race and income is limited
although highly suggestive. It spans a wide spectrum of environmental problems
and population groups exposed. The evidence indicates that racial minority and
low-income populations are disproportionately exposed to lead, selected air
pollutants, hazardous waste facilities, contaminated fish tissue and agricultural
pesticides in the workplace. The extent and nature of the problem may not be
known in every case, but EPA can help lead the way in clearly defining the
problems.
The report is the final product of a collective effort by many individuals and
offices across the Agency. It is a first step. We welcome and encourage public
debate on the report and the issue. Any effort to address environmental equity
issues effectively must include all segments of society: the affected communities,
the public at large, industry, people in policy-making positions and all levels and
branches of government.
We have been delighted and inspired by the enthusiasm and attention that
environmental equity issues have received. Concern for the issues has come from a
diversity of people and institutions, both within and outside the Agency. Diversity
spawns the innovative and effective solutions needed to address this complex and
engrained problem.
Sincerely,
Robert M. Wolcott
Chair
Environmental Equity Workgroup
Warren A. Banks
Special Assistant
Office of the Administrator
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CONTENTS .'•••. : \
Members of the Environmental Equity Workgroup fi
List of Tables and Figures
Chapter One: Introduction and Executive Summary j
The Environmental Agenda -,
Environmental Equity 1
The EPA Environmental Equity Workgroup '.'.'.'.'. 2
Summary of Findings 3
Summary of Recommendations ][
Structure of This Report 4
Chapter Two: Background and Context 6
Background ,
Environmental Equity Workgroup Mission '.'.'.'.'.'.'.I'.'.'.'.'.'. 7
Defining the Issues g
Defining the Terms g
Chapter Three: Findings .............. .1. . u
Finding One
Finding Two ........... .' " ' 12
Finding Three .„
Finding Four ..... i»
Finding Five
Finding Six 23
Chapter Four: Recommendations 25
Recommendation One .,..
Recommendation Two 26
Recommendation Three ' ' 26
Recommendation Four | ' -7
Recommendation Five ' ' 2g
Recommendation Six 2g
Recommendation Seven 2o
Recommendation Eight -0
Descriptions of Existing EPA Projects 32
References
Map of EPA Regional Offices 43
Volume II: Supporting Document Separate
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MEMBERS OF THE ENVIRONMENTAL EQUITY
WORKGROUP
Chair: Robert M. Wolcott
Office of Policy, Planning and Evaluation
Staff Reina Milligan
Asst.: Office of Policy, Planning and Evaluation
Headquarters
Warren Banks
Office of the Administrator
Luctrician Booth
Office of Policy, Planning
and Evaluation
Rebecca Calderon
Office of Research and Development
Sharie Centilla
Office of Water
David Cleverly
Office of Research and Development
Rapheal De Leon
Office of General Counsel
Jan Gallagher
Office of Water
Clarice Gaylord
Office of Human Resources
Management
Roberta Gordon
Office of General Counsel
David Grim
Office of Civil Rights
Robin Grove
Office of Congressional and
Legislative Affairs
Yvonne Kinney
Office of Toxic Substances
Peggy Knight
Office of Communications and
Public Affairs
Bob Knox
Office of Solid Waste and
Emergency Response
Elaine Koerner
Office of Communications and
Public Affairs
Karen Levy
Office of Air & Radiation
Debora Martin
Office of Policy, Planning
and Evaluation
Craig McCormack
Office of Policy, Planning
and Evaluation
Sherry Milan
Office of Enforcement
Kitty Miller
Office of Water
Lawrence Molloy
Office of Policy, Planning
and Evaluation
Joe Montgomery
Office of Federal Activities
Dave Rejeski
Office of Administration and
Resources Management
Ken Sexton
Office of Research and Development
11
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Bob Smith
Office of Pesticide Programs
Sherry Sterling
Office of Pesticides and Toxic
Substances
Edgar Thornton
Office of Policy, Planning and
Evaluation
Alex Varela
Office of Enforcement
Will Wilson
Office of Air and Radiation
Regional Offices
James Younger
Region 1
Conrad Simon
. Region 2
Samara Swanston
Region 2
Dominique Lueckenhoff
Region 3
Jewell Harper
Region 4
Stallings Howell
Region 4
J. Milton Clark
Region 5
William (Bill) Sanders
Region 5
Art Turner
Region 5
Bill Hathaway
Region 6
Don Jones
Region 6
Delores Platt
Region 7
Elmer M. Chenault
Region 8
Alvin Chun
Region 9
Pat Cirone
Region 10
ui
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LIST OF TABLES AND FIGURES
Table 1.
Table 2.
Table 3.
Table 4.
Figure 1.
Estimated Percentage of Children (Living in Cities with
Populations over One Million) 0.5-5 Years Old with Blood
Lead Levels Greater Than 15 ug/dl by Race and Income .
Comparison of Urban Versus Rural
Distribution of Population by Ethnic Group
Percentages of Total U.S. Whites, Blacks
and Hispanics in EPA-Designated Air Quality
Non-Attainment Areas, By Air Pollutant
1980 Data for Census Areas Where EPA Region
IV Hazardous Waste Landfills Are Located
12
14
15
16
Minority Percentage of the Population in
U.S. Communities with Operating Commercial
Hazardous Waste Facilities
17
IV
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Chapter 1
INTRODUCTION AND EXECUTIVE SUMMARY
The Environmental Agenda
Over the past twenty years, the United States has made considerable progress in
protecting and cleaning up the environment. Many forms of air pollution have
been significantly reduced, many surface water systems have shown dramatic
recovery and hazardous wastes are better managed. To achieve this progress, the
nation enacted major laws at the federal, state and local levels, established agencies
to administer these laws and expended considerable sums to install and operate
control equipment. Today there is also a growing movement throughout our
society to prevent pollution before it is ever created, through changes in production
and consumption practices.
This progress has brought important benefits to many communities throughout
the U.S. But many environmental problems remain, and some are regrettably
growing. In many locations the air remains too polluted, the water is still too dirty
and the land still bears too much uncontrolled waste. There are numerous efforts
underway to identify, rank and clean up these problems. All communities have a
direct interest in identifying, prioritizing, and addressing environmental problems.
Environmental Equity
pie U.S. Environmental Protection Agency (EPA) is continually attempting to
improve its approach to environmental protection. Traditionally, environmental
programs at all levels of government have set broadly applicable standards for
individual pollutants released by specific types of sources with the goal of
protecting the environment and all people. Recognizing that not everyone is
affected in the same ways by pollution, these standards have often been set to
protect the most susceptible, such as asthmatics, children or pregnant women.
Environmental protection has progressed from this initial strategy to include
risk-based priority setting. The EPA Science Advisory Board, in its report Reducing
Risk: Setting Priorities and Strategies for Environmental Protection, urged EPA to target
its environmental protection efforts based on the opportunities for reducing the
most serious remaining risks (EPA, 1990). In response, EPA began to examine and
target its efforts on those environmental problems which pose the greatest risks
nationwide to human health and the environment, using comparative risk analyses
to rank environmental problems according to severity. One approach EPA now
employs to prioritize environmental efforts based on risk is geographic targeting,
where attention is focused on the problems faced by individual cities or regions,
such as the Chesapeake Bay, the Great Lakes and the Gulf of Mexico.
In the context of a risk-based approach to environmental management, the
relative risk burden borne by low-income and racial minority communities is a
special concern. A low-income community which is surrounded by multiple
sources of air pollution, waste treatment facilities and landfills and which has lead-
based paint in the residences is clearly a community that faces higher than average
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potential environmental risks. A racial or cultural group whose children commonly
have harmful levels of lead in their blood is also living with a greater
environmental risk. In addition, as a result of factors affecting health status, such
communities may be more likely than the general population to experience disease
or death due to a given level of exposure. Poor nutrition, smoking, inadequate
health care and stress can all contribute to an increased rate of health effects at a
given pollutant level. Hence, to the extent these communities are subject to these
factors. They are also more likely to actually experience harm due to these
exposures.
Issues such as these, and how government agencies respond, have come to be
known today as issues of environmental equity. Environmental equity refers to the
distribution of environmental risks across population groups and to our policy
responses to these distributions. While there are many types of equity, all of which
are important to EPA, the this report focuses on racial minority and low-income
populations.
EPA has begun to assess how patterns of environmental problems converge on
different places, how people who live in those places are affected and how
environmental programs should be further refined to address identified differences.
The causes of these differences are often complex and deeply rooted in historical
patterns of commerce, geography, state and local land use decisions and other
factors that affect where people live and work. With respect to some types of
pollutants, race and income, however, appear to be correlated with these
distributions. .
Clearly, environmental equity is important to those who might bear high risks.
But everyone has a stake in environmental equity because it results in better
environmental protection generally. Environmental equity is an important goal in a
democratic society. It involves ensuring that the benefits of environmental
protection are available to all communities and an environmental policy-making
process that allows the concerns of all communities to be heard, understood, and
addressed.
The EPA Environmental Equity Workgroup
In response to a variety of concerns raised by EPA staff and the public, in July
1990, EPA Administrator William K. Reffly formed the EPA Environmental Equity
Workgroup with staff from all EPA offices and regions across the Agency. The
Workgroup was directed to assess the evidence that racial minority and low-income
communities bear a higher environmental risk burden than the general population,
and consider what EPA might do about any identified disparities.
This report to the Administrator reviews existing data on the distribution of
environmental exposures and risks across population groups. It also summarizes
the Workgroup's review of EPA programs with respect to racial minority and low-
income populations. Based on the findings from these analyses, the Workgroup
makes initial recommendations. Because of the specific nature of the Workgroup's
assignment, the report does not deal with other important related subjects, such as
EPA's minority recruiting programs. It also does not repeat the work recently done
by EPA's Minority Academic Institutions Taskforce (Final Action Plan completed in
May, 1991) or the on-going work of EPA's Cultural Diversity Committee.
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f- .- - '..- >:
The report is intended to contribute to the national dialogue on environmental
equity and to suggest further steps for EPA. It is an initial step in the Agency's
response to environmental equity concerns. There is also much that we still need
to learn, through both research and public debate.
Summasy Of Findings
i.
2.
3.
5.
6.
There are clear differences between racial groups in terms of disease and death
rates. There are also limited data to explain the environmental contribution to
these differences. In fact, there is a general lack of data on environmental
health effects by race and income. For diseases that are known to have
environmental causes, data are not typically disaggregated by race and
socioeconomic group. The notable exception is lead poisoning: A significantly
higher percentage of Black children compared to White children have
unacceptably high blood lead levels.
Racial minority and low-income populations experience higher than average
exposures to selected air pollutants, hazardous waste facilities, contaminated
fish and agricultural pesticides in the workplace. Exposure does not always
result in an immediate or acute health effect. High exposures, and the
possibility of chronic effects, are nevertheless a clear cause for health concerns.
Environmental and health data are not routinely collected and analyzed by
income and race. Nor are data routinely collected on health risks posed by
multiple industrial facilities, cumulative and synergistic effects, or multiple and
different pathways of exposure. Risk assessment and risk management
procedures are not in themselves biased against certain income or racial groups.
However, risk assessment and risk management procedures can be improved to
better take into account equity considerations.
Great opportunities exist for EPA and other government agencies to improve
communication about environmental problems with members of low-income
and racial minority groups. The language, format and distribution of written
materials, media relations, and efforts in two-way communication all can be
improved. In addition, EPA can broaden the spectrum of groups with which it
interacts.
Since they have broad contact with affected communities, EPA's program and
regional offices are well suited to address equity concerns. The potential exists
for effective action by such offices to address disproportionate risks. These
offices currently vary considerably in terms of how they address environmental
equity issues. Case studies of EPA program and regional offices reveal that
opportunities exist for addressing environmental equity issues and that there is
a need for environmental equity awareness training. A number of EPA
regional offices have initiated projects to address high risks in racial minority
and low-income communities.
Native Americans are a unique racial group that has a special relationship with
the federal government and distinct environmental problems. Tribes often lack
the physical infrastructure, institutions, trained personnel and resources
necessary to protect their members.
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Summary Of Recommendations
Although large gaps in data exist, the Workgroup believes that enough is known
With sufficient certainty to make several recommendations to the Agency. These
recommendations are also applicable to other public and private groups engaged in
environmental protection activities. The job of achieving environmental equity is
shared by everyone.
1. EPA should increase the priority that it gives to issues of environmental equity.
2. EPA should establish and maintain information which provides an objective
basis for assessment of risks by income and race, beginning with the
development of a research and data collection plan.
3. EPA should incorporate considerations of environmental equity into the risk
assessment process. It should revise its risk assessment procedures to ensure,
where practical and relevant, better characterization of risk across populations,
communities or geographic areas. These revisions could be useful in
determining whether there are any population groups at disproportionately
high risk.
4. EPA should identify and target opportunities to reduce high concentrations of
risk to specific population groups, employing approaches developed for
geographic targeting.
5. EPA should, where appropriate, assess and consider the distribution of
projected risk reduction in major rulemakings and Agency initiatives.
6. EPA should selectively review and revise its permit, grant, monitoring and
enforcement procedures to address high concentrations of risk in racial
minority and low-income communities. Since state and local governments have
primary authority for many environmental programs, EPA should emphasize
its concerns about environmental equity to them.
7. EPA should expand and improve the level and forms with which it
communicates with racial minority and low-income communities and should
increase efforts to involve them in environmental policy-making.
8. EPA should establish mechanisms, including a center of staff support, to ensure
that environmental equity concerns are incorporated in its long-term planning
and operations.
Structure Of This Report
This report presents the information collected by the Workgroup and its
conclusions. It is an internal staff report from the Workgroup to the Administrator.
The report reflects a variety of expertise and views from individuals and offices
across the Agency. The Workgroup's central goals in producing this report were
to: present an initial perspective and assessment of environmental equity issues;
focus the attention of EPA officials and staff on environmental equity issues; and
inform other government officials and the general public about these issues.
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The report consists of two volumes: the main report and the supporting
document. Chapter Two of the report describes the background, context, and
assignment of the Workgroup and defines the issues examined in this report.
Chapter Three presents the findings of the Workgroup. The Workgroup's
recommendations are detailed in Chapter Four. Brief descriptions of existing and
planned EPA projects addressing various environmental equity issues are provided
at the end of this document.
Volume n presents more detailed information on some aspects of
environmental equity and contains extensive references and a bibliography.
Sections in Volume n are referenced throughout the main body of the text.
Finally, the main report was shared with a group of technical and policy
experts for peer review. Although their comments could not be fully incorporated,
we have included the reviewers' full comments and a summary in Volume II. For
a copy of Volume n, please contact the Office of Policy, Planning and Evaluation at
(202)260-5484.
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Chapter 2
BACKGROUND AND CONTEXT
Background
While low-income and racial minority communities have been involved in
environmental issues for many years, an environmental equity movement has
arisen in the past decade. The environmental equity movement formed primarily
at the grassroots level. During the 1980s, organizations formed around the country
to work on environmental issues in racial minority and low-income communities.
For instance, in Los Angeles, Mothers of East Los Angeles was formed to protest a
proposed incinerator. The Southwest Network for Environmental and Economic
Justice and the Southwest Organizing Project brought together many community-
based groups working on environmental concerns in the Southwestern United
States. Native Action began on the Northern Cheyenne Reservation to protest the
coal mining on surrounding federal land. In Southside Chicago, People for
Community Recovery formed to aggressively pursue clean up of industrial and
hazardous waste sites in their community. These examples are only several among
the hundreds of community-level environmental equity organizations.
National organizations have also been formed to integrate the civil rights and
environmental movements. In 1985, the Center for Environment, Commerce and
Energy was founded as the first national African American environmental
organization. It embraced the goal of carrying out environmental cleanup and
conservation activities in racial minority and low-income communities. Also in
1985, the National Council of Churches' Eco-Justice Working Group began focusing
on environmental equity issues. Finally, the American Baptist Churches developed
a program titled "Ecological and Racial Justice" and which encompasses training
workshops which bring together social justice activists, environmentalists and
church leaders. m^r,\
The 1982 demonstration against the siting of a polychlorinated biphenyl (PCS)
landfill in Warren County, North Carolina, was a watershed event in the
environmental equity movement (Lee, 1990). In response to the protests in this
predominantly Black county, Delegate Walter Fauntroy (D.C.) requested that the
General Accounting Office (GAO) investigate siting issues with respect to race and
income.
To expand on the scope of the GAO study, the United Church of Christ
Commission for Racial Justice examined the statistical relationship between
hazardous waste site location and the racial/socioeconomic composition of host
communities nationwide. While several studies were done in the 1970s, Toxic Waste
and Race in the United States was the first study to address issues of race, class and
the environment at the national level (UCC, 1987).
In January 1990, the University of Michigan School of Natural Resources held
the "Conference on Race and the Incidence of Environmental Hazards." A group of
social scientists and civil rights leaders formed at the meeting, informally calling
themselves the Michigan Coalition.
The Coalition wrote a letter to the Administrator of the U.S. Environmental
Protection Agency, William K. Reilly, in March 1990, requesting a meeting and
Agency action on a number of points relating to environmental risk in racial
minority and low-income communities. Specific proposals for EPA consideration
included:
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• Undertake research geared toward understanding environmental risks faced
by minority and low-income communities;
• Initiate projects to enhance risk communication targeted to minority and
low-income population groups;
• Require, on a demonstration basis, that racial and socioeconomic equity
considerations be included in Regulatory Impact Assessments;
• Include a racial and socioeconomic dimension in geographic studies of
environmental risk;
• Enhance the ability of minority academic institutions to participate in and
contribute to the development of environmental equity;
• Appoint special assistants for environmental equity at decision-making
levels; and
• Develop a policy statement on environmental equity.
Administrator Reilly responded to the Coalition's letter, as well as concerns of EPA
staff, by meeting with representatives of the Coalition and forming the EPA
Environmental Equity Workgroup. The Workgroup was composed of staff from
across the Agency and was convened in July 1990.
Environmental Equity Workgroup Mission
Administrator Reilly charged the Workgroup with four tasks:
Task One: Review and evaluate the evidence that racial minority and low-income
people bear a disproportionate risk burden,
Evidence on the distribution of environmental risk will allow EPA to identify
high risk populations that should be targeted for risk reduction efforts.
Task Two: Review current EPA programs to identify factors that might give rise
to differential risk reduction, and develop approaches to correct such
problems.
This task directly addresses institutional or programmatic barriers to
accomplishing the goal of equitable risk reduction.
Task Three:
Review EPA risk assessment and risk communication guidelines
with respect to race and income-related risks.
Task Three was broken into two parts. The first concerns the adequacy of EPA
risk assessment procedures. The second part addresses the manner in which EPA
communicates information on environmental problems.
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Tasfc Four: Review institutional relationships, including outreach to and.
consultation with racial minority and low-income organizations, to
assure that EPA is fulfilling its mission with respect to these
populations.
Task Four involves how the Agency relates to external groups and other federal
agencies in the decision-making process for routine business matters, major policy
debates and environmental priorities.
Defining The Issues
As the Workgroup set out, it found that one of its more difficult tasks was simply
defining the concept of equity in relation to the environment. There are many
definitions of equity. In fact, the complex subject of equity and how to achieve it
has been debated by philosophers advocating numerous ideas over the centuries.
For this reason, rather than adopting any single philosophy, the Workgroup
attempted to identify some of the major aspects of environmental equity.
Environmental equity is concerned with a variety of issues which fall into three
general categories: the distribution and effects of environmental problems, the
environmental policy making process, and the administration of environmental
protection programs. As to the first category, the Workgroup focused broadly on
a host of environmental problems and the distribution of those problems across
population groups. The environmental problems examined included lead, air
pollution, hazardous waste exposures, consumption of contaminated fish and
farmworker exposure to pesticides.
The distributional aspect of environmental equity has many facets. For
instance, while this Workgroup, focused on environmental equity as it relates to
racial minority and low-income populations, equity across age, gender, sensitive
populations (such as asthmatics), geographic location and generations is also very
important. Similarly, in the global context, environmental equity among nations
could also be examined. This Workgroup focused on socioeconomic status and
race, within the United States, because of concerns raised within and outside the
Agency that these populations bear high environmental risks. However, much of
the knowledge gained should be transferable to other equity issues.
The second category of issues falling under the general heading of
environmental equity relates to the access of racial minority and low-income
communities to the environmental policy making process. The Workgroup
examined EPA's outreach programs, the form and content of public hearings, the
development of environmental priorities, and who EPA consults in the course of
major policy debates. The Workgroup did not address hiring issues. However, for
many years the Office of Civil Rights has had programs to increase equal
employment opportunity and outreach to minority academic institutions. To
further these efforts, Administrator Reilly had previously established the EPA
Minority Academic Institutions Taskforce and the EPA Cultural Diversity
Committee.
The third aspect of environmental equity, as it relates to EPA, is concerned
primarily with the administration of Agency programs. Ensuring that EPA
programs and operations are equitable includes making sure that: grants are
available to communities of all races and socioeconomic status; enforcement actions
and compliance monitoring in minority and low-income communities reflect the
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degree of risk and EPA's ability to reduce risk in those communities; research
includes issues of concern to racial minority and low-income communities; and
access to decision-making is available to all communities.
Neither EPA nor any other organization has control over all factors that
contribute to environmental inequities. However, guided by the basic principle
stated above, EPA can help achieve environmental equity by pursuing the
following two goals:
• Assuring that the protection of public health and the environment is
available to all segments of the population; and
• Implementing environmental statutes in a manner that equitably confers
benefits and risk reductions on all segments of the population.
The concept of risk provides the theoretical basis and a mechanism for
achieving equitable environmental protection. In its report Reducing Risk: Setting
Priorities and Strategies for Environmental Protection, the Science Advisory Board
urged EPA to:
• "[T]arget its environmental protection efforts on the basis of opportunities
for the greatest risk reduction"; and
• "[RJeflect risk-based priorities in its budget process" by focusing "budget
resources at those environmental problems that pose the most serious risks"
(EPA, 1990).
By identifying and focusing on population groups which are more likely to
experience adverse effects of a given environmental problem, EPA can increase
both the efficiency and equity of its actions.
While EPA can ensure that its processes are open and fair, it cannot by itself
ensure that environmental inequities will be erased. However, EPA should strive
to reduce environmental threats to all communities and administer its programs in
pursuit of this goal.
The Workgroup believes that there should be further public debate about
values and measures of success pertaining to environmental equity. However,
there is enough agreement on the principles and goals of environmental equity that
the Workgroup is confident in making the findings and recommendations that
follow in this report.
Defining The Terms
The terms used to describe racial population groups are continually changing.
The United Church of Christ's Toxic Waste and Race Report defines "minority
populations" to include: Blacks, Hispanics, Asian/Pacific Islanders, American
Indians [and Alaskan Natives] and other "non-White" persons (UCC, 1987).
However, other terms are also in use today. In this report, Black and African
American are used interchangeably, as are Hispanic and Latino, and Indian and
Native American. To avoid misreporting research, where studies are discussed in
this report, the original classifications are retained. In charts where information is
not provided for all racial groups, it was absent from the original studies.
Furthermore, this report follows the common practice used in demographics: "race"
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differentiates among population groups based on physical characteristics of a
genetic origin (i.e., skin color), and "ethnicity" refers to differences associated with
cultural or geographic differences (i.ev Hispanic, Irish).
The term used in this report to describe the equitable distribution of
environmental protection benefits is also the subject of considerable debate.
Environmental equity, as described above, refers to the distribution and effects of
environmental problems and the policies and processes to reduce differences in
who bears environmental risks. An alternate term is environmental justice. Some
use the term environmental racism to refer to disproportionate environmental risks
in racial minority communities (Rees, 1992).
EPA chose the term environmental equity because it most readily lends itself to
scientific risk analysis. The distribution of environmental risks is often measurable
and quantifiable. The Agency can act on inequities based on scientific data.
Evaluating the existence of injustices and racism is more difficult because they take
into account socioeconomic factors in addition to the distribution of environmental
benefits that are beyond the scope of this report. Furthermore, environmental
equity, in contrast to environmental racism, includes the disproportionate risk
burden placed on any population group, as defined by gender, age, income, as well
3 c r3Cf*
The Workgroup recognizes the importance and sensitivity of these terms. The
Workgroup also recognizes that combining racial groups into one category, racial
minorities, can lead to overgeneralizations regarding the risk burdens borne by
different communities. Any perceived misuse of these terms is unintentional.
10
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Chapters
FINDINGS
1. There are clear differences between racial groups in terms of disease and
death rates. There are also limited data to explain the environmental
contribution to these differences. In fact, there is a general lack of data on
environmental health effects by race and income. For diseases that are
known to have environmental causes, data are not typically disaggregated
by race and socioeconomic group. The notable exception is lead
poisoning: A significantly higher percentage of Black children compared
to White children have unaccepted// high blood lead levels.
The Workgroup reviewed existing literature on the evidence that racial
minority and low-income communities bear a disproportionate environmental risk
burden. The survey revealed several important findings about background health
statistics. First, there is clear evidence that there are differences by race for disease
and death rates. For example, age-specific death rates are higher for Black males
and females than their White counterparts in all age groups from 0 to 84 years of
age. Furthermore, overall death rates from cancer are greater in Blacks than Whites
for both males (33% greater) and females (16% greater). The overall cancer
mortality rate for other racial minorities is lower than for Whites. There is,
however, great variation in rates of different types of cancer. For example,'White
females have the highest rate of mortality for breast cancer, ovarian cancer,
leukemia, and non-Hodgkin's lymphoma; Chinese females have the highest
mortality rate for lung cancer; Black females have the highest mortality rate for
cancer of the colon, pancreas, cervix, and uterus; and Japanese females have the
highest mortality rate for stomach cancer.
The second point about disease and death rates is the lack of data collected by
socioeconomic variables. The U.S. is the only western high-income country whose
government does not collect mortality statistics by class indicators such as income,
education, or occupation.
The population differences in disease and death rates undoubtedly are caused
by a number of confounding factors, including economic, social, cultural, biological,
and environmental variables. However, while the differences are dramatic, there is
a paucity of data on the environmental contribution to these diseases.
For diseases that are known to be environmentally induced, there is a lack of
data disaggregated by race and socioeconomic variables. The notable exception is
lead. Here the data are unambiguous: a higher percentage of Black children than
White children have high blood lead levels. The evidence on lead shows that all
socioeconomic and racial groups have children with lead in their blood high
enough to cause adverse health effects. However, as shown in Table 1, a
significantly higher percentage of Black children compared to White children have
unacceptably high blood lead levels (ATSDR, 1988).
Table 1: Estimated Percentage of Children (Living in Cities with Populations over One Million) 0.5-5
Years Old with Blood Lead Levels Greater Than 15 fig/dl By Race and Income
Black
White
Source: ATSDR. fllSR)
LESS THAN $6,000
68%
36%
$6,000-$1 5,000
54%
23%
MORE THAN $15,000
38%
12%
11
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For both Blacks and Whites, increasing family income is associated with lower
blood lead concentrations. The difference is smallest for the lowest income level,
yet there is still a large unexplained difference. Furthermore, while this table
concerns urban populations, the figures for the country as a whole are similar
(ATSDR, 1988).
Because a significant portion of these differences in blood lead levels have been
due to lead in gasoline, FJPA's actions in the 1980s to eliminate nearly all lead in
gasoline were a major step in the reduction of high blood lead levels among all
children. Current lead reduction strategies at EPA focus on lead in drinking water,
lead in urban soils, and lead in paint.
See Sec. 2.0 of Volume Ufor more detailed information on this finding.
2. Racial minority and low-income populations experience disproportionate
exposures to selected air pollutants, hazardous waste facilities,
contaminated fish and agricultural pesticides In the workplace. Exposure
does not always result in an immediate or acute health effect High
exposures, and the possibility of chronic effects, are nevertheless a clear
cause for health concerns.
Some low-income and racial minority communities appear to have greater than
average observed and potential exposure to certain pollutants because of historical
patterns affecting where they live and work and what they eat. Racial minority
and low-income communities may have a greater than average potential for
exposure to some pollutants because they tend to live in areas with high air
pollution levels or may be more likely to live near a waste site. Furthermore, some
groups rely on subsistence fishing and may be more exposed than the average
population to fish that have accumulated pollution. Farmworker exposures to
pesticides is another area where racial minority and low-income communities are at
greater than average risk. All of these differences in exposures are complex and
deeply rooted in many aspects of society, such as historical residence, politics,
commerce, geography, state and local land use decisions and other socioeconomic
factors that affect where people live and work.
1. Exposures and Susceptibilities
There are two groups that are generally considered to be at higher than average
public health/environmental risk:
• Individuals who experience the highest exposures. (These individuals are
in approximately the 90th percentile in the distribution of exposure across
the exposed population.)
• Individuals who are more biologically susceptible to the health effects of
environmental pollution. These people are more likely than the general
population to develop environmentally induced disease or injury, even at
equivalent exposures. (Such individuals may include the developing fetus,
young children, pregnant women, individuals with chronic diseases,
individuals with poor immune systems and the elderly.)
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The group at highest risk is composed of individuals who are both more
biologically susceptible and who encounter high exposures. Exposure is not the
same as actual health effects, but when data on actual health effects are lacking,
data on exposure are important to examine.
Although environmental measurements in air, water, soil, or food often are
used as surrogates for exposure, they in fact represent "potential" exposure rather
than "actual" exposure. Even though the potential for exposure may be the same,
not all potentially exposed persons will experience the same actual exposure. For
example, the level of outdoor air pollution in a particular community is a measure
of the potential exposure for the residents. Individuals residing in the community
are likely to have significantly different exposures to air pollution depending on
factors such as occupation, proximity to sources, indoor pollution sources, and
activity patterns. It is increasingly apparent that a person's activity pattern is the
single most important determinant of environmental exposures for most pollutants.
Social/cultural factors such as living near a pollutant source and access to
health care can increase an individual's or population's susceptibility. Several
recent studies have suggested that many, if not all, of the differences in cancer rates
between African Americans and Whites can be explained by the effects of poverty
(Navarro, 1990; Basquet, et. al, 1991). Indeed, some have interpreted the results to
suggest that if differences in socioeconomic characteristics could be eliminated,
Blacks would actually have a lower overall cancer rate than Whites (Okie, 1991;
Gibbons, 1991). Others suggest that while poverty and lifestyle can explain a
significant portion of the observed difference, there is still a substantial amount of
variation that seems to be explained only by race or ethnicity (Gladwell, 1990;
Gibbons, 1991).
2. Air Pollution
. Air pollution is primarily an urban phenomenon, where emission densities tend
to be the highest. A large proportion of racial minorities reside in metropolitan
areas (Table 2) and may be systematically exposed to higher levels of certain air
pollutants.
Table 2: Comparison of Urban Versus Rural Distribution of Population by Ethnic Group
ETHNIC GROUP
White
Black
Hispanic
Other
Source DOC. (1990)
LIVE IN URBAN AREAS
70.3%
86.1%
91.2%
86.5%
LIVE IN RURAL AREAS
FARM NON-FARM
2.3%
0.3%
0.7%
0.4%
27.0%
13.6%
8.1%
12.5%
Researchers at the Argonne National Laboratory studied the demographics of
areas designated by EPA as out of compliance with the Clean Air Act (called air
non-attainment areas.) They found that higher percentages of Blacks and
Hispanics, compared to Whites, live in air non-attainment areas for particulate
matter, carbon monoxide, ozone, sulfur dioxide, and lead (Wernette and Nieves,
1991). Table 3 is a summary of their findings.
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Figure 1: Minority Percentage of the Population in U.S. Communities with Operating Commercial
Hazardous Waste Facilities
45-
40-
35-
30-
25-
20-
15
10
37.6
23.7
22
5 " Group I Group II Group III Group IV
Source! UCC (1987)
Groups:
I. Residential 5-digit Zip code areas without
operating commercial hazardous waste
treatment, storage and disposal facilities.
II. Residential 5-digit ZIP code areas with one
operating commercial hazardous waste
treatment, storage and disposal facility that is not
a landfill.
III. Residential 5-digit ZIP code areas with one
operating commercial hazardous waste landfill
that is not one of the five largest in the U.S.
IV. Residential 5-digit ZIP code areas with one of
America's five largest commercial hazardous
waste landfills or more than one treatment,
storage and disposal facility.
A key implication of the above discussion is that EPA's extensive efforts to
improve air quality in non-attainment areas under the Clean Air Act of 1990 should
bring significant benefits to racial minority groups.
3. Residence Near Waste Sites
There is evidence (GAO, 1983; UCC, 1987) to indicate that racial and ethnic
minorities are more likely to live near a commercial waste treatment facility or an
uncontrolled hazardous waste site than the general population. In 1983, the U.S.
General Accounting Office conducted a study of hazardous waste landfills in eight
southeastern states (EPA Region IV). The GAO reported that in three of the four
communities where offsite hazardous waste landfills were located, Blacks formed
the majority of the population (GAO, 1983). The GACXs findings are
listed in Table 4.
Table 3: Percentages of Total U.S. Whites, Blacks and Hispanics in EPA-Designated Air Quality
Non-Attainment Areas, By Air Pollutant*
AIR POLLUTANTS
Particulate Matter
Carbon Monoxide
Ozone
Sulfur Dioxide
Lead
WHITES
14.7%
33.6%
525%
7.0%
6.0%
BLACKS
16.5%
46.0%
62.2%
12.1%
9.2%
HISPANICS"
34.0%
57.1%
71.2%
5.7%
18.5%
Total* by population group* are greater than 100% because counties may b.e included in more than one non-attainment category.
" Hilpanks may be of either race, since Hispanic is an ethnic, not a racial, category.
Source Wemette and Nieves, (1991)
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The United Church of Christ decided to study the GAO's findings at the
national level and produced the Toxic Waste and Race Report. They found that the
proportion of racial minorities in communities with the largest commercial landfills
in America or the greatest number of commercial waste facilities was three times
greater than in communities without such facilities (UCC, 1987). The results of
their study are summarized in Figure 1.
The UCC's analysis of "uncontrolled hazardous waste sites" (old industrial
landfills and waste sites that arose before EPA or its laws were created) concluded
that race was more strongly associated with residence near a waste site than
socioeconomic status. The study also concluded that the presence of uncontrolled
toxic waste sites is highly pervasive. According to the report, more than half of the
total population in. the U.S. resides in communities with uncontrolled toxic waste
sites. It is clear that more study of this issue is required to fully understand the
associations of race, income, and facility location.
Table 4:1980 Data for Census Areas Where EPA Region IV Hazardous Waste Landfills Are Located
LANDFILL
Chemical Waste
Man.(AL)
SCA Services (SC)
Industrial Chemical
Co. (SC)
Warren County
PCB Landfill (NC)
POPULATION
Total
626
849
728
804
% Black
90%
38%
52%
66%
MEDIAN FAMILY
INCOME ($)
All Races
11,198
16,371
18,996
10,367
Blacks
10,752
6,781
12,941
9,285
POPULATION BELOW
POVERTY LEVEL
Total
265
260
188
256
%
42%
31%
26%
32%
% Black
100%
100%
92%
90%
Source U.S. GAO, (1983)
4. Dietary Exposure Through Fish Consumption
Consumption of fish can be an important route of exposure for certain
pollutants. PCBs, dioxins, and furans can bioaccumulate in fish tissues to high
concentrations, even when water concentrations are below detection limits.
Variations in fish consumption can affect exposure to those pollutants and hence,
health risks. Some populations, such as subsistence fishers and some racial groups,
consume more fish than the average population.
A recent survey of licensed anglers in Michigan found that Native Americans
consumed 36% more fish and Blacks 13% more fish than the Caucasian population
(West, 1990). A California study of sport fishers indicates that Asians/Samoans eat
the most fish followed in order by Caucasians, Hispanics, and African Americans
(Puffer, 1981). A national survey of 25,000 individuals, the National Purchase Diary
(NPD) Survey, supported these findings and found Asians to have the highest fish
consumption rate (SRI, 1980). It is important to note that these studies found
different rates of fish consumption for the racial population groups studied.
Calculating fish consumption rates is complex and dependent on regional dietary
patterns.
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Other socioeconomic factors also may play a role in rates of fish consumption.
Several studies found that fish consumption generally increases with increasing age
(West, 1990; SRI, 1980; NYDEC, 1988). In addition, both the Michigan and NPD
surveys found a correlation between lower education level and higher fish
consumption. Studies have generally not found a correlation between income and
fish consumption (SRI, 1980; West, 1990), although one study did find that fish
consumption actually increased with increasing income (NYDEC, 1988). These
studies, however, most often surveyed licensed fishers and may not account for
lower-income anglers who do not purchase licenses.
In addition to the quantitative rate of fish consumption, fish preparation and
species of fish eaten also can affect exposure to contaminants and may vary by
socioeconomic factors. Lipophilic compounds that bioaccumulate tend to
accumulate in the fatty portions of the fish and accumulate to a higher degree in
bottom feeding species. Most risk assessments assume that the population
consumes skinless, trimmed fillets. Yet evidence suggests that racial minorities are
more likely to eat fish with the skin, may be less likely to trim the fat, and are
more likely to eat the whole fish (NOAA, 1985; West, 1990). In addition, preferred
fish species differ across populations. For example, the Michigan study found that
Great Lakes bottom dwellers were consumed exclusively by non-white, low-income
populations. A study of anglers in Puget Sound found that Asians
disproportionately consumed clams and the hepatopancreas of crabs (McCallum,
1985), both practices that might lead to higher relative exposures to pollutants.
This evidence points to the complexity of the subject, variation among
communities, and a greater potential for contaminant exposure to certain
populations through the fish ingestion route. However, these studies were not
designed specifically to address these concerns. Additional studies are needed
before these differences can be consistently and conclusively validated.
5. Pesticide Exposures to Farmworkers
Exposures to pesticides occur in a variety of ways,
including occupational settings; contact with garden, home, and ^
lawn care products; contaminated food or soil; and even mother's milk. It is
believed by many that racial and ethnic minorities, especially Latinos, are at
increased risk because of their high numbers in the agricultural workforce and the
fact that many of them live in places close to agricultural pesticide spraying
activities (EPA, 1990).
It has been estimated that 80-90% of the approximately two million hired
farmworkers (performing farm work not done by farm families) are racial
minorities (Martin et al, 1985). Hispanics make up the largest group, followed in
order by African Americans, Black Caribbeans, Puerto Ricans, Filipinos,
Vietnamese, Laotians, and Koreans (Martin et. al., 1985).
For a multitude of reasons, it is difficult to document the cause and effect
between pesticides and health (Perfecto, 1990). However, it is estimated that as
many as 300,000 farmworkers experience pesticide related illnesses each year (Coye,
1985). Furthermore, results from a nationwide study of selected organochlorine
pesticides in the milk of 1,436 mothers found that Hispanic women in the study
had higher levels of dieldrin and oxychlordane, while heptachlor epoxide levels
were similar for Whites and Hispanics (Savage, 1976). Another study failed to find
significant differences between Black and White field workers in Honda (Griffith
and Duncan, 1983). Data from the National Adipose Tissue Survey for 1982 found
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that Whites had significantly higher concentrations than Non-Whites for five
pesticides (Unger and Mak, 1989). No compounds measured in the study were
higher in Non-Whites.
EPA's Science Advisory Board (SAB) identified worker exposures to chemicals
in agriculture as a high human health risk due to the large numbers of workers
directly exposed to a range of highly toxic chemicals. "[A]gricultural workers are
exposed to many toxic substances in the workplace. Such exposures can cause
cancer and a wide range of non-cancer health effects" (SAB, 1990). While there is
very little published information on pesticide exposures in general and almost none
at all on differences by class, race, or ethnicity, it is clear that since racial and ethnic
minorities comprise the majority of the documented and undocumented farm
workforce, they may experience higher than average risk from agricultural
chemicals.
In recognition of inadequate federal farmworker protection standards, EPA
proposed more protective standards in 1988. The proposal included provisions for:
restricted entry times after application during which time workers are not
permitted to re-enter treated "fields; additional protective equipment; increased
training; and notifying workers of areas treated with pesticides through field
posting. The final rule is currently being reviewed within the Administration and
is expected to become final in 1992.
For more detailed information on health effects and exposures, see Sec. 2.0 of Volume II.
3. Environmental and health data are not routinely collected and analyzed by
income and race. Nor are data routinely collected on health risks posed
by multiple industrial facilities, cumulative and synergistic effects, or
multiple and different pathways of exposure. Risk assessment and risk
management procedures are not in themselves biased against certain
income or racial groups. However, risk assessment and risk management
procedures can be improved to better take into account equity
considerations.
The quantitative and qualitative steps incorporated in EPA's risk assessment
guidelines for carcinogenic and noncarcinogenic effects are not, in themselves,
biased against certain racial/ethnic groups. However, as most risk assessors
proceed through the stages of the risk assessment process where data are obtained
and analyzed (hazard identification, exposure assessment and risk characterization)
they do not routinely collect information on differences by race and income group.
In some cases this is due to the fact that information on the distribution of risks
across race and income groups may not always be relevant to a risk assessment. If
these factors are relevant, they should be considered in the risk assessment process
and presented to the risk managers in the decision-making process.
For the purposes of reviewing the accuracy of the risk assessment process with
respect to population group differences, the Workgroup evaluated several studies
on trie distribution of environmental risks in addition to the health and exposure
data presented above. Evidence suggests that exposures to and risk from
environmental contaminants may vary significantly depending on age, gender, race,
ethnicity, and economic factors. For example, in epidemiologic studies of those
U.S. steel workers most heavily exposed to mixtures of organic pollutants in coke-
oven emissions at by-product plants, it was found that 90% of these workers were
nonwhite. This population had an 8-fold higher rate of respiratory cancer than
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expected (EPA, 1984). Also, estimated lung cancer deaths in the U.S. attributable to
indoor radon exposure are about 2-fold higher in males than in females, and
remain higher even when adjusted for smoking (Nazaroff and Teichman, 1990).
With respect to identifying human health hazards associated with chemical
exposure, the preponderance of the epidemiologic studies has involved evaluations
of White males working in industry. Determinations of the carcinogenic potency of
known human chemical carcinogens is based on direct evidence from these
epidemiologic studies. In addition, the direct evidence of noncancer health effects
are derived from these studies. This information is also used routinely by EPA and
others in conducting risk assessments.
Currently, the Agency does not present exposure analyses as distributions
across population groups. The U.S. Census Bureau database is a potentially rich
source of data for presenting gradations of exposures across demographic groups,
including age, gender, ethnicity, race and income level. Likewise, quantitative
estimates of risk probabilities are not displayed as distributions across the exposed
population, broken down demographically.
Multiple sources of pollution can play a significant role in exposures to
environmental pollutants in certain low-income and racial minority communities.
However, for the most part, EPA programs do not calculate the aggregate human
health risks posed by all types of sources in a particular community. Nor do
programs address cumulative and synergistic effects or multiple pathways of
exposure. This can, in part, be attributed to the inherent difficulty of performing
such analyses and to the Agency's original structure and mission, which are
fragmented under many different pieces of legislation into problem-specific
program areas.
Risk assessment information is used by EPA staff and managers to make
regulatory decisions. The decision stage in the process is called risk management.
Recognizing the importance of risk management, the Workgroup reviewed the risk
management process as well. The Workgroup noted that while risk management,
like risk assessment, is not inherently biased, there are no published guidelines to
guide risk management decisions, nor are there any guidelines to promote the
consistent and systematic consideration of equity when selecting among regulatory
alternatives.
Volume H, Sec. 5.0, contains detailed information on risk assessment and risk management
procedures.
4. Great opportunities exist for EPA and other government agencies to
improve communication about environmental problems with members of
low-income and racial minority groups. The language, format and
distribution of written materials, media relations, and efforts in two-way
communication all can be improved. In addition, EPA can broaden the
spectrum of groups with which it interacts.
EPA's communication efforts generally have not had explicit equity goals.
Indeed, EPA risk communication guidance seldom mentions race, income, or other
characteristics that might influence the distribution of risks and benefits. Nor are
there explicit guidelines to ensure that the communication process itself is
equitable.
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EPA has a Risk Communication? Program which has generated materials that
contain general principles on risk communication and sound advice that can be
used in coming to grips with equity issues. However, more guidance is needed
that illustrates these general principles with explicit reference to the equity issues
affecting racial minority and low-income populations, and some concrete advice
about how to address these problems. Guidance would be particularly useful on
language, format and distribution of written materials, as well as on working with
the media. (In depth case studies of several EPA risk communication programs can be
found in Volume II, Sec. 63.)
On a related matter, organizations concerned with environmental equity
complain that traditional environmental groups do not address the concerns of
racial minority and low-income communities. Thus, EPA and other government
organizations should expand their outreach programs to ensure that racial minority
and low-income communities are included in setting environmental policies and in
regulatory negotiation wherever possible. EPA's aggressive hiring programs, work
with Minority Academic Institutions, and EPA's new Tribal Lands Scholarship
Program will assist these efforts.
To increase outreach, government agencies should work with local and regional
grassroots organizations, which play a key role among low-income and racial
minority communities. EPA traditionally has worked with large, national
organizations, especially at the Headquarters level. Given the local focus of most
grassroots groups, much of the interaction with racial minority and low-income
communities may occur through EPA Regional offices (a map of EPA Regions is
located on the back page), as well as state and local government offices.
Another element of the environmental equity movement is the role of religious
organizations. For example, a driving force in the movement has been the United
Church of Christ. The United Methodist Church, the Presbyterian Church, the
World Council of Churches and the National Council of Churches, as well as
others, are strongly involved in environmental equity issues. In May 1992,
scientists and religious leaders convened to produce the "Declaration of the
'Mission to Washington' Joint Appeal by Religion and Science for the
Environment." Expanding outreach to religious organizations will be breaking new
ground for the Agency, but is important nonetheless.
See Volume II, Sec. 6.0, for a detailed discussion of risk communication and Sec. 7.0 for
more information on outreach.
5. Since they have broad contact with affected communities, EPA's program
and regional offices are well suited to address equity concerns. The
potential exists for effective action by such offices to address
disproportionate risks. These offices currently vary considerably in terms
of how they address environmental equity issues. Case studies of EPA
program and regional offices reveal that opportunities exist for address/no
environmental equity issues and that there is a need for environmental
equity awareness training. A number of EPA regional offices have
initiated protects to address high risks in racial minority and low-income
communities.
EPA has four program offices based on specific environmental media and
pollutants - the Office of Water, the Office of Air and Radiation, the Office of
Prevention, Pesticides and Toxic Substances, and the Office of Solid Waste and
Emergency Response. The legislation authorizing these programs gives EPA, the
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States, and municipal governments different regulatory and enforcement powers
and responsibilities in each of these program areas. Identifying factors that might
give rise to a differential distribution of program benefits and developing solutions
to any identified problems is a complex process.
A general review of EPA programs reveals variation within and between the
program offices in terms of how they address the distribution of risks across
population groups. While some offices have explicitly considered the distribution
of risk and high risk populations in their rulemakings, there has never been a
consistent EPA policy to address equity issues with respect to racial and income
groups. Furthermore, equity issues are more prevalent in some environmental
problems than others, and this may be reflected in the EPA programs. Statutory
authority and state responsibilities also affect the degree to which EPA programs
address equity concerns.
For example, the Office of Pesticide Programs (OPP) identifies and addresses
risks to population groups, particularly agricultural workers, through the special
review, re-registration and registration programs. For dietary exposure, OPP has a
system in place which can examine consumption of various food commodities
based on gender-, ethnic- and age-specific patterns. OPP uses the system to
examine exposure of 22 population groups.
To explore these issues further, the Workgroup conducted case studies of two
EPA programs, the Office of Solid Waste and Emergency Response (OSWER) and
the Office of Air and Radiation (OAR). Two different approaches were used in
reviewing the two programs. The review of OSWER was carried out by conducting
awareness workshops for OSWER managers and staff. The OAR review was
conducted by OAR's Office of Policy Analysis and Review and then circulated to
OAR staff for their comments. The Workgroup also reviewed regional
environmental equity efforts.
1. Office of Solid Waste and Emergency Response
To familiarize program managers with equity issues, the Workgroup held four
Environmental Equity Awareness Workshops. As a pilot program, these
workshops were held for managers and staff in OSWER. Furthermore, so that
OSWER could better respond to citizen inquiries and complaints, a toll-free line
was recently installed in the Office of the Ombudsman. The number is 1-800-262-
7937.
Specific problems discussed by OSWER managers involved the siting and
permitting of solid and hazardous waste facilities, risk analysis, and risk
communication. OSWER managers also discussed awareness of equity issues and
the need for equity awareness training for Agency personnel. Furthermore,
workshop participants agreed that low-income and minority individuals would be
the primary beneficiaries of positive results arising from EPA's pollution prevention
initiative.
Siting and Permitting of Waste Facilities. OSWER managers and staff
recognize that the siting and permitting of hazardous and solid waste management
facilities involve socioeconomic forces that are not related to technical concerns
such as geohydrology and depth to groundwater. The siting issue is very complex.
On the one hand, a result of the "not in my backyard (NIMBY)" syndrome is that
such facilities will tend to be located in communities with the least ability to mount
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a protest On the other hand, there are examples of poor communities seeking a
waste site or industrial facility to increase the tax base and create jobs.
In this context, the division of authorities between federal and state
governments plays a crucial role. The siting of waste facilities is controlled
primarily by state and local governments. EPA's role in permitting comes after the
site has been chosen and involves technical considerations. However, OSWER is
developing further standards for localities to use in siting waste sites.
To help overcome the problem of actual and perceived disproportionate siting
in minority and low-income communities, EPA could assess the feasibility of
increasing its oversight in the siting and permitting of hazardous and solid waste
management facilities. Workshop participants discussed several options for
increasing EPA oversight.
Risk Analysis. Managers and staff identified the lack of information on the
cumulative effects of multiple sources of pollution as a serious concern. Workshop
participants pointed to the lack of information on cross-media pollution in heavily
industrialized areas. There are also untapped opportunities to address equity
issues in risk analysis under existing legislation. For example, in setting corrective
action priorities at Resource Conservation and Recovery Act facilities, the Agency
does not currently consider a facility's location and surroundings (in addition to the
risk-producing conditions at the facility itself).
Risk Communication/Outreach. The Agency devotes considerable resources to
risk communication and outreach efforts, especially in the Superfund program.
These efforts include community outreach projects, the use of Technical Assistance
Grants (TAGs) to help communities hire outside experts to describe the risks posed
by Superfund sites in their communities, and the translation of EPA bulletins and
notices into the languages of non-English speakers.
Pollution Prevention. Workshop participants pointed out that EPA's pollution
prevention initiatives should help to mitigate the adverse health impacts
experienced by minority and low-income individuals as a result of exposure to
pollution and polluting facilities. For example, fewer and less toxic emissions to air
should help to improve air quality in urban areas where racial minorities tend to
live.
While the pollution prevention program is innovative> there is no mention of
Native American tribes in the authorizing legislation, implementing regulations or
grant guidance. EPA technical assistance is needed for tribes to compete with
states for pollution prevention grants in the highly competitive process.
See Volume n. Sec. 3.1 for more information on OSWER.
2. Office of Air and Radiation
The literature available illustrates that exposure, siting, sensitivity, and the
distribution of air pollutants raise concerns about equity, with respect to air
pollution. Available studies do not demonstrate (or even raise the suggestion), that
OAR's policies have resulted in differential allocations of environmental benefits.
However, the literature examined suggests that racial minority and low-income
populations have experienced poorer air quality because they tend to live in urban
areas and have in some cases lived in closer proximity to air polluting facilities.
Also, in some cases, they may be more sensitive to certain air pollutants than the
general population.
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Based on the limited data available, several population groups identified as
being sensitive to the health effects of air pollution seem to be disproportionately
composed of low-income or racial minority individuals compared to the general
population (Mak, 1982; Goldstein, 1986; NCHS, 1990; Schwartz, 1990; HHS, 1991.)
These groups include asthmatics, people with certain cardiovascular diseases or
anemia, and women at risk of delivering low-birth-weight fetuses. Further work is
needed to discern the factors at the root of the differences in health statistics.
Whatever the causes, EPA can act to protect affected individuals through increased
education programs and regulatory action where heightened susceptibilities in
communities are demonstrated.
1990 Clean Air Act Amendments. The bulk of OAR's current resources are
focused on the implementation of the Clean Air Act of 1990. The Workgroup gave
the legislation special attention because of its opportunities to address differences in
exposure and susceptibilities.
The 1990 Clean Air Act Amendments provide powerful tools to ensure that the
national ambient air quality standards are attained nationwide. Most of the
nation's serious non-attainment problems occur in urban areas. To the extent urban
air quality is improved via the Act, minority populations will experience higher
relative benefits than the general population because of their high representation in
urban areas.
The Act also contains several provisions involving'health or risk assessments
and the setting of health-based standards. The Act provides for health-related
studies, clearinghouses, and health standards, which present opportunities for EPA
to analyze in detail the distribution of the health effects of air pollution and use
this information in setting health-based standards.
The reductions in exposure and the associated control costs will in general be
distributed widely. However, several of the changes enacted could potentially have
greater economic impacfs on low-income people than on middle- or high-income
groups. For example, under the Act, EPA must publish guidance for the states on
the development of transportation measures necessary to demonstrate and maintain
attainment of the national ambient air quality standards. Once again, opportunities
exist for EPA to include consideration of those racial minority and low-income
communities who are at greater risk than the population as a whole in the
development of this guidance.
For more information on OAR, see Volume IT, Sec. 3.2.
3. EPA Regional Offices
EPA's ten regional offices play a major role in program implementation. For
this reason, many environmental equity issues are best addressed by Regional
offices. Through many discussions with regional staff, the single most important
discovery with regard to the equity issue was lack of awareness, although
awareness is increasing dramatically. Awareness of equity issues also varies
considerably by region.
Another important finding is that there are a wide variety of on-going regional
activities that address environmental equity issues. Through the efforts of a
relatively small number of staff, several regional offices have managed to conduct
research, outreach, and risk communication efforts targeted to racial minority and
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low-income communities. Most of the Regional staff members interviewed
identified outreach as a key method for addressing issues of equity.
For example, in Region I (Boston), staff in the Office of Civil Rights are
engaged in the Urban Environmental Initiative, a two-way outreach project to
develop environmental priorities for the Boston area which includes the concerns of
racial minority communities. The Initiative focuses on community awareness,
empowerment and involvement in environmental issues. Region in (Philadelphia)
also has an outreach program called the Chesapeake Bay Multi-Cultural
Participation Program to broaden public participation and involvement in the
restoration of the Bay. The target groups for greater involvement are citizens of
African, Latino and Asian descent, as well as rural poor and others with a direct
economic link to the productivity of the Bay.
Staff in Region V (Chicago) are aggressively attacking the urban lead program
with the Lead Education and Abatement Program, a comprehensive strategy and
implementation plan to address and remediate lead contamination in the six state
region. The target population is African American and Latino children under seven
years of age, and women of child bearing age.
Region Vffl (Denver) is currently developing and testing a model risk
communication program designed to communicate environmental awareness to
racial minority communities and to foster two-way communication between EPA
and these communities. The Multi-media approach is being designed to
communicate, in simple common language: risk assessments, legal rights, the
Community-Right-To-Know program, Technical Assistance Grants (Superfund) and
federal versus state responsibilities.
For more information on these and other Regional projects, see the Descriptions of Existing
EPA Projects in this document and Volume II, Sec. 8.0.
6. Native Americans are a unique racial group that has a special relationship
with the federal government and distinct environmental problems. Tribes
often lack the physical infrastructure, institutions, trained personnel and
resources necessary to protect their members.
Native American people represent a unique sector of American society. The
federal government has a special relationship with tribal governments, based on
original Treaties and subsequent legislation passed by Congress. Because of their
unique political, historical, environmental and cultural status, the Workgroup
decided to treat tribal populations separately for the purposes of this report.
In its review of environmental equity concerns with respect to Native American
populations, the Workgroup raised the following issues:
• Native American tribes may be at a higher risk for certain pollutants than
the average population due to subsistence practices, including high wild
food and fish consumption rates.
• While individual risks may be high on spme reservations, tribes potentially
may be overlooked in EPA's risk-based approach. Typically, reservations
have small populations with relatively large land areas, and population risk
will often be small relative to other, especially urban, population groups.
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• EPA's risk analysis methodologies may not include factors (e.g., diet and
other cultural practices) which accurately assess risk in Indian country.
• Many tribes are substantially behind states in developing physical and
institutional environmental protection infrastructure and often lack the
technology that states posses to assess environmental problems.
1. Wisconsin Tribal Comparative Risk Project
To analyze these issues further on a case study basis, a comparative risk project
was initiated for the eleven tribes in Wisconsin. The results of the project have
important implication for equity concerns.
Comparative risk studies employ a methodology which has been used at EPA
and state and local agencies to identify environmental problems in a given
geographic area and to rank those problems based on analysis of their severity or
risk. Varying numbers of environmental problem areas are ranked, including
problems as diverse as pesticide exposures, indoor air quality, and drinking water
contamination.
Typically three types of risk analyses are. performed on each environmental
problem: human health, ecological, and economic welfare. The human health
analysis was modified to consider the very different pathways of exposure to
environmental risks that Native Americans may face. The economic welfare
analysis was modified to include damages to cultural and religious values and
subsistence lifestyles. The list of environmental problems studied was modified to
add food contamination as a separate problem. The analysis portion of the
Wisconsin project was completed in a very short time frame to accommodate the
schedule of the Environmental Equity Workgroup.
The results of this analysis show that the tribes in Wisconsin face different risks
than those faced by the population of the northern Mid-West as a whole. Food
contamination from environmental sources was found to be the highest health risk
facing the tribes. Ecological risks were found to be caused mostly by long-distance
transport of pollutants from outside the reservations. Finally, the influence of
religious and cultural values significantly affected the economic welfare ranking.
One of the most striking findings of the Wisconsin project was that many of the
current and future risks facing the tribes could be reduced significantly if the
Wisconsin tribes had the physical, legislative/regulatory and institutional
infrastructure and the environmental professionals to implement an environmental
protection program. Many tribes have limited staff, if any, who are knowledgeable
on the technical and legal aspects of environmental matters. This lack of
infrastructure means that many tribes have no effective way to manage
environmental problems on reservations. This point has significant implications for
environmental risks to Native American populations generally and for the EPA
Indian Program because, although the Wisconsin tribes may differ from other tribes
in wild food consumption, religious and cultural values, and pathways of exposure,
they differ little in infrastructure development.
See Volume U, Sec. 4.0, for more information on Native American tribes.
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Chapter 4
RECOMMENDATIONS
Although gaps in data exist, the Workgroup believes that enough is known to
make several recommendations to the EPA Administrator, management and staff.
These recommendations might also be applicable to other public and private
groups concerned with protecting the environment and public health.
Presented with each recommendation are several specific examples of ways
EPA could implement the recommendation. These examples are not the only
possible implementation strategies, but are meant to illustrate EPA's opportunities.
Making Environmental Equity A Priority
1. EPA should increase the priority that it gives to issues of environmental
equity.
EPA is already engaged in a number of activities which promote environmental
equity. However, an implication of the findings is that EPA should give more
explicit attention to environmental equity issues. As detailed in the findings and
other recommendations, there are many additional opportunities to improve the
manner in which EPA addresses these issues.
Increasing the priority that environmental equity issues receive will require an
educational process in which managers and staff are made aware of the issues and
the tools to identify and address inequities in risk. The first step in this direction
must be for Agency managers to give the overall issue of environmental equity
higher priority. This increased priority should be reflected in the resources
provided to program and regional offices. Not only would this signal to EPA staff
that they should take actions such as those recommended in this report, but it
would signal to people in other public and private organizations that they should
follow suit.
Environmental equity is one of the important next steps in environmental
protection, as the nation attempts to refine its environmental priorities.
Environmental equity is not in conflict with EPA's present efforts to protect public
health and the environment. Rather, it is fundamentally consistent with EPA's goal
of protecting all communities and its efforts to identify and remedy those
environmental problems posing the greatest risks. Indeed, environmental equity
reinforces the push for better environmental protection generally by emphasizing
that all communities share a common interest in improving the state of the
environment.
Some examples of specific ways in which EPA could implement this
recommendation include:
• Top Agency managers could make clear statements to EPA staff about EPA's
interest in environmental equity. They could give special attention to activities
which are already underway and emphasize where additional action is needed.
• Top Agency managers could signal to outside groups in the public and private
sectors that environmental equity should be given higher priority.
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EPA could include a section on the progress of environmental equity projects in
its "Administrator's Tracking System Report."
Strengthening The Database For Better
Decision Making
2. EPA should establish and maintain information which provides an
objective basis for assessment of risks by income and race, beginning
with the development of a research and data collection plan.
Questions about the distribution of environmental problems, exposure and risk
can only be answered if EPA develops more detailed data on specific pollutants
and risks.
Some examples of specific ways in which EPA could implement this
recommendation include:
• Research on environmental exposures and health effects could recognize and
consider race, ethnicity and socioeconomic status in study design
implementation. To the degree feasible, data could be collected and
disaggregated by age, gender, race, and ethnicity.
• Analyses could be undertaken to identify critical characteristics of racial, ethnic,
and class groups which would significantly alter the susceptibilities of that
population group.
• EPA could develop a comprehensive research plan for collecting data and
developing new risk assessment methodologies. Consultations with the
Department of Health and Human Services would greatly enhance this effort.
• The Agency could make demographic data and support services centrally
accessible to all Agency offices.
Quantifying Risks: Tools For Better Risk Assessment
3. EPA should incorporate considerations of environmental equity into the
risk assessment process. It should revise its risk assessment procedures
to ensure, where practical and relevant, better characterization of risk
across populations, communities or geographic areas. These revisions
could be useful in determining whether there are any population groups at
disproportionately high risk.
To determine which groups are especially susceptible to environmental
exposures, the Agency should revise and expand its procedures for assessing risk.
Guidelines should be amended to help EPA gain a clearer picture of which
populations, communities, and geographic areas bear high risk burdens.
Information on race and income will not be necessary or appropriate for all risk
assessments, and EPA should devote time to deciding in what cases demographic
information should be included in risk assessments.
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Some might observe that risk calculations are race and income neutral and that
risk assessments should only include information on pollutants. However, the
Workgroup has concluded that in studying aggregate risks, high risk populations
in some cases have been overlooked. By collecting information on race and
income, EPA can gain a more accurate picture of risks to all population groups.
EPA should initiate implementation of this recommendation by conducting a series
of pilot assessments to determine data requirements and cost.
Some examples of specific ways in which EPA could implement this
recommendation include: ' . -
• To the extent practical and appropriate, the Agency could require that
quantitative risk assessments include distributions of exposures and health risks
across broad sub-categories of the exposed population, incorporating census
data on age, gender, income level and race.
• EPA could focus on improving existing methods and developing new methods
for assessing risk from multiple chemicals and multiple sources within and
across environmental media. It could continue to develop the Maximally
Exposed Community concept which includes: cumulative exposures; multiple
exposures; increased susceptibility; the effects of multiple/different pathways of
exposure.
• EPA could continue to develop and refine exposure factors information,
particularly in the area of exposure factors for population groups, which are
used in developing risk assessments.
• EPA could, where feasible and appropriate, identify and demographically
characterize the population residing within the high-end of exposures.
• EPA could study ways in which to assess environmental risks to Native
American populations.
• Based on the availability of exposure data by population group, national,
regional and state comparative risk studies could be expanded to selectively
incorporate disaggregation of risk by population group.
Creative Measures To Address Equity: Targeting High
Ricks Populations e & &
4. EPA should identify and target opportunities to reduce high
concentrations of risk to specific population groups, employing
approaches developed for geographic targeting.
EPA currently is placing more emphasis on reducing the highest risks and
pollution prevention. The Agency should continue to prioritize its actions based on
risk, adjusting its priorities as our understanding of the highest risks changes. EPA
should identify and target high-risk populations.
Some examples of specific ways in which EPA could implement this
recommendation include:
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• EPA could further develop its enforcement prioritization schemes to target high
risk populations. Under this approach, the most exposed and highly
susceptible populations in each region would be targeted for enforcement
actions. Geographic Information System technology could be used to identify
high-risk populations. (For an example, see the description of the Region V
Geographic Enforcement Initiative in the Description of EPA Projects.)
• EPA could undertake a set of targeted geographic initiatives where high
population exposures to various pollutants exist. Possible targets include: 1)
the Mississippi River between Baton Rouge, LA and New Orleans, LA; 2) the
Mexico-U.S. border; 3) New York City, NY and 4) East Los Angeles, CA.
Consider using Total Exposure Assessment Monitoring (TEAM) methodology
which accounts for multiple sources of pollution.
• EPA could conduct one or a series of showcase urban projects focusing on
marshalling targeted prevention, remediation, education and outreach
instruments on minority and low-income communities.
Considering Risk Distribution In Decision Making
5. EPA should, where appropriate, assess and consider the distribution of
projected risk reduction in major mlemakings.and Agency initiatives.
Current regulatory impact statements assess the costs and benefits associated
with major rules. Where costs and benefits are analyzed, and where appropriate,
EPA should include a population distribution analysis. This will not be necessary
or appropriate in all cases, and EPA should test several cases to define when such
information should be collected.
Some examples of specific ways in which EPA could implement this
recommendation include:
• EPA could conduct 3 to 4 pilot environmental equity analyses based on a set of
prospective major rules for which such an analysis is feasible and will not
unduly delay the rule.
• The Agency could establish risk management guidelines which would require
considerations and evaluations of environmental equity when arriving at
regulatory decisions.
Intergrating Equity And EPA Operations
6. EPA should selectively review and revise its permit, grant, monitoring and
enforcement procedures to address high concentrations of risk In racial
minority and low-income communities. Since state and local governments
have primary authority for many environmental programs, EPA should
emphasize Its concerns about environmental equity to them.
Many actions affecting the environment are ultimately determined by permit,
grant and enforcement procedures. There are a variety of these procedures that
should be refined to address environmental equity issues. To determine exactly
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where changes are needed, program managers and staff need to examine their
operations carefully.
In addition, environmental regulatory actions often impose high costs. These
costs may be reflected in increased costs of goods and services, and sometimes in
job loss, plant relocation and plan closures. In certain cases, these economic effects
to selected communities may exceed the benefits of environmental controls, even
though the environmental control renders net benefits to the population as a whole.
In such circumstances, the Agency should attempt to minimize adverse effects by
the appropriate design and implementation of its regulations, taking into account
the special circumstances of the most severely impacted communities.
Some examples of specific ways in which EPA could implement this
recommendation include:
• EPA could incorporate language in selected permit, grant and enforcement
guidelines which places priority on high risk populations.
• Each headquarters and regional office could engage in a review of its activities
and present to the Administrator a plan of how it will achieve the Agency's
equity goals. Environmental equity goals could be included in the strategic
planning and budget process.
• EPA could assess the feasibility of requiring an assessment of the cumulative
impacts and risks associated with new or expanding Resource Conservation
and Recovery Act facilities.
• EPA could review its implementation of the Clean Air Act of 1990 to ensure
that the flexibilities in the Act do not result in consistent increased pollution
burdens on poor or racial minority communities.
• As part of the development of guidance for states on the development of
transportation measures under the Clean Air Act of 1990, EPA could analyze
the potential inequities resulting from increased transportation user fees and
look for solutions that would simultaneously reduce the possible inequities and
achieve the goal of traffic reduction.
• Recognizing legislation and budget authorization limits, EPA could explore
ways to increase funding, training, and other support to Native American tribes
for the purpose of establishing physical and institutional infrastructure for
environmental protection and staff training, similar to support provided to
states in the past decades.
Expanding Outreach And Communicatiion
7. EPA should expand and improve the level and forms with which it
communicates with racial minority and low-income communities and
should increase efforts to Involve them in environmental policy-making.
The Agency should take specific steps to strengthen its communications
program for racial minority and low-income populations. This outreach initiative
should be based on EPA's existing communications network but should also
include community groups that have close links to those who are affected by
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I
environmental equity issues. All communications efforts should reflect sensitivity
to issues such as language and value systems and should ensure that populations
affected are actively engaged in the risk communication process from the
beginning.
Some examples of specific ways in which EPA could implement this
recommendation include:
• EPA could explore additional ways to support and help racial minority and
low-income communities get technical assistance to understand and participate
in decisions about environmental issues at the local level. In doing so, the
Superfund Program's Technical Assistance Grants program is one example of
how this can be done.
• EPA could financially support university-based regional environmental equity
centers engaging in research and education activities and directed, in part, by
community concerns.
• EPA could improve targeted outreach and environmental education literature
for racial minority and low-income communities.
• Each EPA regional office could develop two-way communication programs
similar to Region I's Urban Environmental Initiative and Region VTfl's Outreach
Program in Ethnic Communities. (See the Description of EPA Projects and
Volume E(, Sec. 8.2, for more details.)
• EPA could develop general guidance for its staff on communication with racial
minority and low-income communities. The guidance could cover language,
format and distribution of written materials, working with the media and
collaborating with local agencies.
* EPA could establish outreach representatives for minority and low-income
communities in each of its regional offices.
• EPA could translate more of its published materials into languages other than
English.
Assuring Long-Term Success
8. EPA should establish mechanisms, including a center of staff support, to
ensure that environmental equity concerns are incorporated in its long
term planning and operations.
Specific measures must be instituted to ensure that EPA systematically
considers equity issues in its routine business and major policy debates. (For details
on an institutional model for addressing environmental equity, see Volume II, Sec. 9.0.)
Some examples of specific ways in which EPA could implement this
recommendation include:
• EPA could incorporate environmental equity in the strategic planning and
budgeting process.
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• EPA could develop a policy statement on environmental discrimination.
• EPA could establish an external Environmental Equity Advisory Committee.
• EPA could continue the EPA Environmental Equity Workgroup and provide
staff and resources for implementing the recommendations of this report,
including time tables.
• The EPA Environmental Equity Workgroup could conduct a comprehensive
analysis of each recommendation to assess its impact and to determine realistic
accomplishments and time frames for action.
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Descriptions Of Existing EPA Projects
This section is provided to illustrate practical examples of approaches to addressing
and solving environmental equity concerns. Volume II, Sec. 8.2, contains other
examples of existing EPA projects addressing environmental equity issues and further
details on the projects listed here.
Project Name: Urban Environmental Initiative
Region: I (Boston) Contact: James Younger
Office: Office of Civil Rights
The Urban Environmental Initiative is an attempt to develop a bi-directional
communication strategy. The ultimate goal of the Initiative is to develop
environmental priorities for the Boston area which includes the concerns of racial
minority communities. Currently underway in Boston, the project focuses on
community awareness, empowerment and involvement in environmental issues.
The program is exploring the impact of environmental pioblems on the ;urban
community with particular emphasis on those environmental problems other than
lead, such as air pollution, PCBs and radon.
Project Name: Superfund Enforcement Investigation
Region: H (New York). Contact: Dana Williams
Office: Equal Employment Office
The first part of the study will document if there are more
Superfund/CERCLis sites located in minority/poor communities in New York and
New Jersey. Using census data recently loaded into a Geographic Information
System (CIS), a map will be developed that includes the location of CERCLIS and
Superfund sites and pertinent demographic data. The second part of the study
asks the question: Are more affluent communities able to speed up the Superfund
process? This study will identify the key factors in determining the level of activity
of remediation at Superfund sites. Do minority/poor communities receive proper
attention in the earlier stages of the Superfund process?
Project Name: Baltimore/Washington, D.C. Urban Environmental Risk Initiative
Region: m (Philadelphia) Contact: Dominique Lueckenhoff
Office: Chesapeake Bay Program
Multi-media environmental risk profiles for socioeconomic subgroups within
the study area will be developed and displayed on Geographic Information
System (GIS) maps. GIS will serve not only to assist with the analytical work, but
also to present the results in a format understandable to the general public. These
risk profiles will also be compared to background or reference conditions in order
to determine whether environmental risks within the defined study areas are
disproportionately distributed by socioeconomic class. Community outreach to
organizations and individuals representing the affected populations in the study
areas will be conducted with the assistance of state and local officials and Morgan
State University. In addition to communicating EPA's risk assessment findings,
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these community outreach forums will also be used to reach consensus on the
environmental problems of greatest concern and how best to address them based
upon community needs and available resources.
Project Name: Multi-cultural Participation in the Chesapeake Bay Program
Region: m (Philadelphia) Contact: Dominique Lueckenhoff
Office: Chesapeake Bay Program
The Chesapeake Bay Program is developing a multi-cultural participation
program to broaden public participation and involvement in the restoration of the
Bay. The target groups for greater involvement are citizens of African, Latino and
Asian descent, as well as rural poor and others with a direct economic link to the
productivity of the Bay. The focus of the program is on structuring public
information materials and educational programs to have broad appeal and
encourage increased participation. This includes surveying multi-cultural interests
to evaluate the impact of the Chesapeake Bay Program on racial minority and low-
income communities.
Project Name: Radon and Asbestos Awareness Program (RAAP)
Region: HI Contact: Aquanetta Dickens
Office: Air Division
RAAP targets racial minority communities for effective communication of
health risks associated with radon and asbestos. The program is now being piloted
in the Philadelphia area, with the intention of being transferred to other major
metropolitan areas within the Region. The program involves regular radio forums
consisting of professionals from EPA, other federal agencies, universities/colleges
and private industry to communicate the health threats of radon and asbestos and
to obtain direct feedback from members of racial minority communities oh their
experiences and perceptions of the problems.
Project Name: Superfund Equity Analysis
Region: TV (Atlanta) Contact Rosalyn Hughes
Office: Office of Policy, Planning and Evaluation
Region 4 is conducting a study to determine to what degree environmental
inequity exists within the region. The analysis will deUniate community
characteristics, such as racial minority populations and socioeconomic class, within
areas of environmental hazards.
The analysis is underway using 1990 Census data to develop the population
profile with respect to racial origin. An income profile will also be developed
when data become available. The analysis will initially focus on the following
environmental hazards:
• Superfund sites;
• Permitted RCRA sites;
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• Toxic Release Inventory facilities;
• Wastewater treatment facilities; and
• Commercial waste treatment facilities.
Geographic Information System (CIS) technology is being used for the analysis.
Project Name: Lead Education and Abatement Program (Project LEAP)
Region: V (Chicago) Contact William H. Sanders HI
Office: Environmental Sciences Division
The Region 5 comparative risk study identified lead as one of the multi-
program pollutants of concern. Region 5 selected lead as a priority area, and
tasked the medium programs, and a project director, with development of a
comprehensive strategy/implementation plan to address and remediate lead
contamination in the six state region.
Because children are a elevated risk, a targeted population has been chosen to
be children under seven years of age, and women of child bearing age as a
surrogate for the fetus. Within this population group, African- and Hispanic-
Americans are particularly targeted in recognition of an increased body burden
susceptibility/vulnerability to the uptake and effects of lead exposure. Project
LEAP is a multi-media and multi-program approach having four basic
components -1) data analysis and targeting; 2) pollution prevention; 3) education
and intervention activities; and 4) abatement activities. The project will be
implemented over a three year period, and the first stage report, Spatial and
Numerical Dimensions of Young Minority Children Exposed to Low-Level Environmental
Sources of Lead, is now available.
Project Name: Geographic Enforcement Initiative
Region: V (Chicago) Contact: BertFrey
Office: Deputy Regional Counsel
The Region 5 Geographic Enforcement Initiative (GEI) is a major part of a risk-
based, multi-media effort focused on Southeast Chicago and Northwestern Native
American tribes. This heavily industrialized area is beset with a host of
environmental problems affecting air, water, soil and quality of life. Previous
evaluations of this area have highlighted a variety of unacceptable human health
and ecological risks. GEI is an enforcement initiative to reduce emissions and
ensure environmental compliance in an area where low-income and racial minority
populations dominate.
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Project Name: CIS/Comparative Risk Equity Analysis
Region: VI (Dallas) Contact Lynda Carroll
Office: Office of Planning and Analysis
Region 6 has developed Geographic Information System (GIS) and Comparative
Risk capabilities to evaluate environmental equity concerns in the five states in the
area. Region 6's comparative risk methodology identifies susceptibility factors as
part of risk evaluations for human health. Factors such as age, pregnancy, genetics
(race), personal income, pre-existing disease and lifestyle are susceptibility
measures. Considerations of racial minority status are included in the genetics and
lifestyle factors. The other factors indirectly assess the socioeconomic status of
identified population groups.
Susceptibility factors have been analyzed for site specific studies (i.e., areas
around hazardous waste sites) and large geographic locations such as cities, states
or the region. Combined with chemical release data (i.e., the Toxic Release
Inventory or monitoring information), geographic and demographic data and state
health department vital statistics data, regional equity assessments can be
performed routinely.
Project Name: Gulf Coast Toxics Initiative
Region: VI (Dallas) Contact: Lynda Carroll
Office: Office of Planning and Analysis
The Gulf Coast Toxics Initiative is a major 1992 enforcement effort in Region 6.
The program will target facilities in the sensitive Gulf Coast ecoregion where most
of the toxic releases in the region occur. The region's inspectors will allocate 38
percent of their time to this initiative. Owing to the high human populations and
quantity of wetlands in the Gulf Coast of Louisiana and Texas, it was selected as
the most likely area to benefit from an intensive multi-media enforcement effort
Project Name: Region VH Indian Strategy
Region: VH (Kansas City) Contact
Office: Office of Policy and Management
Dewane Knott
The focus of EPA's Indian Strategy is to develop the capability within tribes to
manage their own tribal environments. Since tribal environments and the
corresponding environmental problems vary nationally, Region 7 is implementing
the strategy by concentrating in the three areas identified as priorities by the tribes
in the region: solid waste, environmental education and groundwater protection.
A Native American Senior Employment Program person has been hired to work
exclusively with the tribes on solid waste issues by providing training
opportunities. In terms of environmental education, Region 7 is distributing an
environmental curriculum to the reservation schools accompanied by teacher
training, distributing training videos to the tribes, and coordinating with the local
Native American junior colleges. Groundwater contamination is being addressed
with additional outreach and by including a groundwater component in all grants
awarded to tribes.
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Project Name: Environmental Education Initiative
Region: VIE (Kansas City) Contact: Rowena Michaels
Office: Office of Public Affairs
Region 7 and the University of Kansas established a National Environmental
Education and Training Center to provide leadership in environmental education,
teacher training and professional development. The region funded a pilot teacher
training project to develop exemplary environmental education modules for use in
the four state area. The project focused on educating K-6 teachers at a two-week,
on-campus "Summer Institute" in July, 1991. Special emphasis was placed on
assuring that teachers selected for the "Summer Institute" represented diverse
school districts from urban and rural areas in Region 7. The Center will continue
to assure that diversity is a special focus in future educational efforts.
The Region 7 Strategic Plan covering fiscal years 1993 through 1996 includes
commitments to work extensively with educators throughout the region to assure
that young people receive adequate information about environmental matters to
make sound environmental choices throughout their lives. The Plan also
recognizes environmental equity as an important issue which will be reflected in
communication and outreach.
Project Name: Pollutant Exposure and Risk Patterns
Region: VHI (Denver) Contact Elmer Chenault
Office: Federal Facilities Compliance Branch
Region VIE has initiated an investigation of polluting facilities in the Denver-
Boulder, Colorado, metropolitan area using Geographic Information System (CIS)
technology. The purpose of the project is to determine potential and actual purpose
of the project is to determine potential and actual pollutant exposure and define
possible risk patterns to the minority residents of this area.
Project Name: Outreach Program in Ethnic Communities
Region: VEB (Denver) Contact: Elmer Chenault
Office: Federal Facilities Compliance Branch
Region 8 is currently developing and testing a model outreach program
designed to communicate environmental awareness to racial minority communities
and to foster two-way communication between EPA and these communities. The
Multi-media approach is being designed to communicate, in simple common
language: risk assessments, legal rights, the Community-Right-To-Know program,
Technical Assistance Grants (Superfund) and federal versus state responsibilities.
Once the program has been implemented and modified in Region 8 an information
packet will be distributed for national application. The kit will include: an EPA
outreach model for low income communities; actions plans for workshops; and
detailed workshop presentations.
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Project Name: California Migrant Labor Camp Drinking Water Enforcement
Program
Region: DC (San Francisco)
Office: Drinking Water Program
Contact: Mona Ellison
During the past year, Region 9 has gathered information on migrant labor
camp drinking water systems in California. The Region 9 Drinking Water Branch
was concerned that labor camps shared many, if not more, of the compliance
problems common to small systems throughout the state. In summary, Region 9
found 191 violating labor camp water systems serving over 8,500 people in 20
counties. Failure to monitor and report was the most common violation category.
More than one county contact warned that strict enforcement of the drinking
water regulations may result in the closure of many labor camps, creating
additional housing, welfare and social burdens for county administrators, taxpayers
and camp residents. Region 9 is now working with state and local officials to
devise and implement an enforcement plan.
Project Name: Hawaii Environmental Risk Ranking Project
Region: DC (San Francisco) Contact: Gerald Hiatt
Office: Office of the Regional Administrator
The state of Hawaii has undertaken a comparative risk project to identify and
rank environmental problems facing the state. Risk assessment information is
being used to rate Hawaii's environmental problems on the basis of threats to:
human health, environment, economic welfare and quality of life. One of the major
quality of life concerns is the effect of development and pollution on native
Hawaiians, including a number of subsistence-level communities. Native Hawaiian
culture and religion are closely tied to the environment and the sociological and
psychological impacts of environmental change extend beyond direct health and
ecosystem effects.
Two issues unique to native Hawaiians are being considered: 1) cultural and
religious impacts of loss or degradation of specific ecosystems or sites; and 2)
increased exposure to environmental pollution in subsistence-level Hawaiian
communities. Three professors at the University of Hawaii are assisting the project:
Drs. Luciano Minerbi, Davianna McGregor, and Jon Matsuoka.
Project Name: Pesticide Applicator Training
Region: X (Seattle) Contact: Allan Welch
Office: Air and Toxics Division
Region 10 has developed, in conjunction with the Washington Department of
Agriculture, a Pesticide Applicator Training course in Spanish. This training
module was developed for Latino farmworkers who find it much easier to learn in
Spanish. The total cost was $50,000, with support of staff from the State and
Region 10. During 1991 a total of 400 Latino farmworkers attended one of the six
session courses that were held at six different locations in the State. Many of the
participants took and passed the Washington private applicator exam.
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Project Name: Wisconsin Tribes Comparative Risk Project
Region: Headquarters/V (Chicago) Contact: Catherine Tunis/
Casey Ambutus
Office: Regional & State Planning Branch/Indian Coordinator
Comparative risk studies are used to prioritize environmental problems in a
given geographic area and have been done at the national, regional, state and city
levels. The Wisconsin project will help define the high risk areas for the eleven
Wisconsin tribes. Another major goal of the project is to adapt the current
comparative risk methodology to account for the different exposure and risk factors
for Native Americans as compared to the general U.S. population. The results of
the study will be compared to the results of the Region V analysis and the planned
Wisconsin state analysis. This project is a cooperative effort between the Office of
Water and the Office of Policy, Planning and Evaluation in Headquarters and
Region 5. Meetings will be held with the eleven Wisconsin tribes to present the
results of the analysis and gather their evaluations of the adapted methodologies.
A report will be prepared that can serve as guidance for future tribal comparative
risk projects.
Project Name: Mexico-U.S. Integrated Border Environmental Plan
Headquarters/Region VtyRegion DC Contact: Richard Kiy
Office: Office of International Activities
In response to a request by the Presidents of the Mexico and the U.S. in
November, 1990, EPA and its Mexican counterpart have developed a bilateral plan
to protect the environment in the border area. Of particular concern are the
inadequate waste water treatment and drinking water facilities for the colonias
(unincorporated towns along the border.) The plan was released in mid-winter of
1992. To begin making progress immediately, the U.S. National Enforcement
Training Institute held training sessions for Mexican inspectors of maquiladora
. industries on March 23-27,1992.
Region 6 awarded a $15 million grant to the Texas Water Development Board
to establish a revolving fund for plumbing loan programs to colonias in 12
counties. The program provides low-interest loans to individuals for connecting
homes to drinking water distribution systems and/or sewage collection systems
and for household plumbing improvements. People can take up to 10 years to
repay the loans. Ultimately, this program could provide benefits to some 200,000
people living in 950 colonias along the Texas-Mexico border. In March, loans were
provided to the City of Pharr in Hidalgo County where some 500 homes in the Los
Miltas and Lopezville colonias will receive indoor plumbing and clean water.
Project Name: A Methodology for Estimating Population Exposure from the
Consumption of Chemically Contaminated Fish
Headquarters/Region X (Seattle)
Office: Science Policy Branch
Contact: Craig McCormack
The purpose of the study is to develop a methodology to estimate populations
that may be at a greater than average risk from eating fish contaminated from
industrial point pollution. These populations eat fish at a greater than average rate
38
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and include Native Americans, Asians, Blacks, and recreational and subsistence
fishers. The methodology developed provides an estimate of a geographical area of
potential exposure and an estimate of exposure and risk in consideration of age, sex
and race/ethnicity. The methodology will assist EPA regional offices and states in
issuing fish advisories.
To collect more data on the fish consumption patterns of Native Americans,
EPA is sponsoring the Columbia River Inter-Tribal Fish Commission Survey of Fish
Consumption and Related Issues. In this survey, four Pacific Northwest Native
American tribes are being surveyed about their fish consumption habits.
Project Name: Environmental Equity Analysis of RCRA Corrective Action Final
Rule
Headquarters Contact: Barnes Johnson
Office: Office of Solid Waste
The Communications, Analysis, and Budget Division in the Office of Solid
Waste (OSW) conducts regulatory impact analyses for regulations relating to solid
waste. A major regulation being developed by OSW is the Resource Conservation
and Recovery Act (RCRA) corrective action final rule which will set guidelines for
cleaning up releases and spills at commercial hazardous waste facilities. As part of
the regulatory impact analysis for this rule, the Division is conducting an
investigation of the distribution of risk, based on income and race/ethnicity,
around RCRA facilities.
Project Name: EPA Lead Reduction Strategy
Headquarters Contact: Doreen Cantor
Office: Office of Toxic Substances
EPA's comprehensive lead strategy, released last February, has a goal of
reducing to as low as possible the number of children with blood lead levels
greater than 10 ppm. This goal has been and will continue to be a major factor in
setting new lead standards and revising existing standards. In 1992, EPA will
propose to ban the sale of lead solder and brass and bronze plumbing fixtures for
use in residential plumbing. Last June, EPA published a final rule reducing the
amount of lead in drinking water. It ensures that homes with the highest risks are
targeted for treatment. As a result, neurological risks to over 20 million children
will be reduced, and about 100,000 children are expected to avoid IQ losses. About
95% of these health benefits will be realized within the next 6 years.
Project Name: Environmental Health Equity Analysis: Evaluation of
Potential Human Exposure to Environmental Pollution
Headquarters Contact: Ken Sexton
Office: Office of Health Research
The Office of Health Research (OHR) has initiated a project to evaluate the
relationship between levels of pollutant emissions and the extent of exposure to
racial minorities and/or people of lower socioeconomic status. The first step
involves an analysis of the location and magnitude of emissions (as identified by
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the Toxics Release Inventory) and the demographic characteristics of the population
in the surrounding area. Demographic data will come from the U.S. Bureau of the
Census or the Donnelley Marketing data base. Additional data sets, such as the
attainment of the National Ambient Air Quality Standards, will be added as the
project develops. The analysis will be done by state, county and targeted
geographic areas. This is a long-term effort that began in February 1992.
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REFERENCES
Agency for Toxic Substances and Disease Registry (ATSDR), 1988. The Nature and
Extent of Lead Poisoning in Children in the United States: A Report to Congress, Centers
for Disease Control, Atlanta, GA.
Basquet, C.R., J.W. Horm, T. Gibbs, and P. Greenwald, 1991. "Socioeconomic
Factors and Cancer Incidence Among Blacks and Whites", Journal of the National
Cancer Institute, 83: 551-557.
Coye, M., 1985. "Health Effects of Agricultural Production: I - The Health of
Agricultural Workers", Journal of Public Health Policy, 6: 349-370.
Department of Commerce (DOC), 1990. Bureau of the Census. Statistical Abstract of
the United States. Washington, D.C.
Department of Health and Human Services (HHS), 1991. Health Status of Minorities
and Low-Income Groups: Third Edition.
Environmental Protection Agency (EPA), 1984. Carcinogen Assessment of Coke Oven
Emissions, Office of Health and Environmental Assessment, Washington, D.C, EPA-
600/6-82-003F.
Environmental Protection Agency (EPA), 1990. Reducing Risk: Setting Priorities and
Strategies for Environmental Protection, Science Advisory Board, Washington, D C,
SAB-EC-90-021.
General Accounting Office (GAO), 1983. Siting of Hazardous Waste Landfills and
Their Correlation with Racial and Economic Status of Surrounding Communities,
Washington, DC.
Gibbons, A, 1991. "Does War on Cancer Equal War on Poverty?" Science, 253: 260.
Gladwell, M, 1990. "Public Health Turns to Economic Ills", The Washington Post,
November 26.
Goldstein, IF. and A.L. Weinstein, 1986. "Air Pollution and Asthma: Effects of
Exposures to Short-Term Sulfur Dioxide Peaks", Environmental Research, p. 40.
Lee, C., 1990. "Toxic Waste and Race in the United States". In: Bryant, B. and P.
Mohai (Eds.), The Proceedings of the Michigan Conference on Race and the Incidence of
Environmental Hazards.
Mak, H., P. Johnston, H. Abbey and R.C. Talamo, 1982. "Prevalence of Asthma and
Health Service Utilization of Asthmatic Children in an Inner City", Journal of Allergy
and Clinical Immunology, 70:5.
McCallum, M., 1985. Recreational and Subsistence Catch and Consumption of Seafood
from Three Urban Industrial Bays ofPuget Sound: Port Gardner, Elliot Bay and Sinclair
Inlet, Washington State Division of Health.
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National Center for Health Statistics (NCHS), 1990. Health of Black and White
Americans, 1985-87, Series 10: Data from the National Health Interview Survey, No. 171,
U.S. Department of Health and Human Services, January.
National Oceanic and Atmospheric Administration (NOAA), 1985. Potential
Toxicant Exposure Among Consumers of Recreationally Caught Fish from Urban
Embayments ofPuget Sound, Washington, DC.
Navarro, V, 1990. "Race or Class Versus Race and Class: Mortality Differentials in
the United States", The Lancet 336:1238-1240.
Nazaroff, W. arid K, Teichman, 1990. "Indoor Radon", Environmental Science and
Technology, 24: 774-782.
New York Department of Environmental Conservation (NYDEC), 1988. New York
Statewide Angler Survey.
Okie, S., 1991. "Study Links Cancer, Poverty", The Washington Post, April 17,1991.
Perfecto, I., 1990. "Pesticide Exposure of Farm Workers and the International
Connection." In: Bryant, B. and P. Mohai (Eds.), The Proceedings of the Michigan
Conference on Race and the Incidence of Environmental Hazards.
Puffer, H, 1981. Consumption Rates of Potentially Hazardous Marine Fish Caught
in the Metropolitan Los Angeles Area, EPA Grant #R807 120010
Rees, M., 1992. "Blac and Green", The New Republic, March 2,1992.
SRI, 1980. Seafood Consumption Data Analysis, Prepared for the U.S. Environmental
Protection Agency, Office of Water Regulations and Standards, Washington, D.C.
Schwartz, J., D. Gold, D.W. Dockery, S.T. Weiss, and F.E. Speizer, 1990. "Predictors
of Asthma and Persistent Wheeze in a National Sample of Children in the. United
States", American Review of Respiratory Disease, 142.
United Church of Christ Commission for Racial Justice (UCC), 1987. Toxic Wastes
and Race in the United States: A National Report on the Racial and Sodo-Economic
Characteristics of Communities with Hazardous Waste Sites.
Wemette, D. and L. Nieves, 1991. "Minorities and Air Pollution: A Preliminary Geo-
Demographic Analysis", presented at the Socioeconomic Research Analysis Conference - II,
June 27-28.
West, P.C., JM. Fly, F. Larkin, and R. Maratis, 1989. "Minority Anglers and Toxic Fish
Consumption: Evidence from a State-Wide Survey of Michigan." In: Bryant, B. and P.
Mohai (Eds.), The Proceedings of the Michigan Conference on Race and the Incidence of
Environmental Hazards, pp. 108-122.
An extensive bibliography can be found in Volume II, Sec. 11.0.
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MAP OF EPA REGIONAL OFFICES
Regions
4 — Alabama 1 -
10 — Alaska 3 -
9 — Arizona 1 -
6 — Arkansas 5 -
9 — California 5 -
8 —. Colorado 4 -
1 — Connecticut 7 -
3 — Delaware 8 -
3 — D.C. 7 -
4 — Florida 9 -
4 — Georgia 1 -
9 — Hawaii 2 -
10 — Idaho 6 -
5 — Illinois 2 -
5 — Indiana 4 -
7 — Iowa 8 -
7 — Kansas 5 •-
4 — Kentucky 6 -
6 — Louisiana 10 -
Regions
Maine 3
Maryland 1
Massachusetts 4
Michigan 8
Minnesota 4
Mississippi 6
Missouri 8
Montana 1
Nebraska 3
Nevada 10
New Hampshire 3
New Jersey 5
New Mexico 8
New York 9
North Carolina 9
North Dakota 2
Ohio 2
Oklahoma
Oregon
Regions
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
American Samoa
Guam
Puerto Rico
Virgin Islands
43
•SU.S- Government Printing office : 1992 -312-014/40183
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