United States
Environmental Protection
Agency
Policy, Planning
And Evaluation
(PM-221)
230-DR-92-002
February 1992
v>EPA Environmental Equity Draft
Reducing Risk
For All Communities
Copyright Sam Ktoner
Report To The Administrator
From The EPA Environmental
Equity Workgroup
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TABLE OF CONTENTS
Members of the Environmental Equity Workgroup i
List of Tables and Figures iii
Chapter One: Introduction and Executive Summary 1
The Environmental Agenda 1
Environmental Equity 1
The EPA Environmental Equity Workgroup . 2
Summary of Findings 3
Summary of Recommendations 4
Structure of This Report 5
Chapter Two: Background and Context 6
Background 6
Environmental Equity Workgroup Mission . 7
Defining the Issues 7
Defining the Terms 10
Chapter Three: Findings 11
Finding One 11
Finding Two 13
Finding Three 20
Finding Four 21
Finding Five 23
Finding Six 28
Chapter Four: Recommendations 30
Recommendation One 30
Recommendation Two 31
Recommendation Three 32
Recommendation Four 33
Recommendation Five 34
Recommendation Six 34
Recommendation Seven 36
Recommendation Eight 37
Descriptions of Existing EPA Projects 38
References 46
Map of EPA Regional Offices 49
Appendix: Supporting Materials Separate
Document
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MEMBERS OF THE ENVIRONMENTAL EQUITY
WORKGROUP
Staff
Rob woicott
Office of Policy, Planning and Evaluation
Reina Milligan
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
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Lawrence Molloy
Office of Policy, Planning and
Evaluation
Joe Montgomery
Office of Federal Activities
Dave Rejeski
Office of Administration &
Resources Management
Ken Sexton
Office of Research and
Development
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
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
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
ii
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LIST OF TABLES AND FIGURES
Table 1.
Table 2.
Table 3.
Table 4.
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
Figure 1. Minority Percentage of the Population in
U.S. Communities with Operating Commercial
Hazardous Waste Facilities
17
iii
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CHAPTER ONE
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 are significantly
reduced, many surface water systems have shown dramatic recovery
and hazardous waste is better managed and contained. To achieve
this progress, the nation has 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 people in
all communities. But many environmental problems remain. In
many locations the air is still 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
The U.S. Environmental Protection Agency (EPA) is
continually attempting to refine its approach to environmental
protection. Traditionally, environmental programs at all levels
of government have set broadly applicable standards for
individual pollutants emitted 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 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
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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 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. 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. While there are
many types of equity, all of which are important to EPA, the term
in this report refers specifically to racial and socioeconomic
equity.
EPA has begun to consider 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 socioeconomic factors that affect where
people live and work.
Environmental equity is important to those who might bear
disproportionately 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 a more equitable
distribution of risks and an environmental policy-making process
that allows the concerns of all communities to be heard,
understood, and considered.
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. Reilly
formed the EPA Environmental Equity Workgroup with staff from
offices and regions across the Agency. The Workgroup was asked
to assess the evidence that racial minority and low-income
communities bear a higher environmental risk burden than the
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general population, and consider what EPA might do about any
identified disparities.
In exploring how to define environmental equity, the
Workgroup built on the Administrator's April, 1991 memo which
stated, "The consequences of environmental pollution should not
be borne disproportionately by any segment of the population.1*
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.
The report is intended to contribute to the national
dialogue on environmental equity and to suggest -further steps for
EPA. It is a first step in the Agency's response to
environmental equity concerns. There is also much that we still
need to learn, through both internal study and public debate.
SUMMARY OF FINDINGS
1. There is a general lack of data on environmental health
effects by race and income. Although there are clear
differences between racial groups in terms of disease and
death rates, there is an absence of data to document the
environmental contribution to these differences. 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.
2. While there are large gaps in data on actual health effects,
it is possible to document differences in observed and
potential exposure to some environmental pollutants by
socioeconomic factors and race. Exposure is not the same as
health effects, but this finding is nevertheless a clear
cause for concern.
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3. Environmental and health data simply 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, improvements can be made in data collection
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.
5. There is a great deal of variation among EPA's program and
regional offices 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 minority and low-income communities.
6. Native American Indians are a unique racial group with a
special relationship with the federal government and
distinct environmental problems. Indian Tribes often lack
the physical infrastructure, institutions, trained personnel
and resources necessary to protect their members.
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, commencing with developing a research and data
collection plan.
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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
population, communities or geographic areas. In some cases
it may be important to know whether there are any population
groups at disproportionately high risk.
4. EPA should identify and target opportunities to reduce high
concentrations of risk to different population groups,
employing approaches developed for geographic targeting.
5. EPA should, where appropriate, selectively assess and
consider the distribution of projected risk reduction in
major rulemakings and Agency initiatives.
6. EPA should review and selectively 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 form 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 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. Chapter Two 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 already existing
and planned EPA projects addressing various environmental equity
issues are provided at the end of this document. Finally, the
Appendix, which is a separate document, presents more detailed
information on some aspects of environmental equity and contains
extensive references and a bibliography. Sections in the
Appendix are referenced throughout the main body of the text.
For a copy of the Appendix, please contact the Office of Policy,
Planning and Evaluation at (202) 260-5484.
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CHAPTER TWO
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 1982
demonstration against the siting of a polychlorinated biphenyl
(PCB) landfill in Warren County, North Carolina, was a watershed
event (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,
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:
o Undertake research geared toward understanding
environmental risks faced by minority and low-income
communities;
o Initiate projects to enhance risk communication
targeted to minority and low-income population groups;
o Include a racial and socioeconomic dimension in
geographic studies of environmental risk; and
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o 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 the Coalition and
forming the EPA Environmental Equity Workgroup. The Workgroup
was composed of staff from all around 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.
Task 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 as many definitions of
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equity as there are people. 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,
residence near waste sites, 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,
generations and industry groups 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 degree of risk and EPA's ability to
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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.
Based on these facets of environmental equity, the Workgroup
attempted to develop a working definition of the term. The .
Workgroup was only partially successful, and after debate,
produced instead a set of goals and principles pertaining to
environmental equity. The basic principle has been stated by
Administrator Reilly as official EPA policy: "The consequences
of environmental pollution should not be borne disproportionately
by any segment of the population." (Administrator's Memo, April
1, 1991).
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:
o Striving to assure that the protection of public health
and the environment is available to all segments of the
population; and
o 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:
o "[T]arget its environmental protection efforts on the
basis of opportunities for the greatest risk
reduction"; and
o "[R]eflect 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.
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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. To avoid misreporting research, where studies are
discussed in this report, the original classifications are
retained. Furthermore, this report follows the common practice
used in demographics: "race" 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.e.,
Hispanic, Irish).
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
overgerieralizations regarding the risk burdens borne by different
communities. Any perceived misuse of these terms is
unintentional.
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CHAPTER THREE
FINDINGS
1. There is a general lack of data on environmental health effects by race
and income. Although there are clear differences between racial groups
in terms of disease and death rates, there is an absence of data to
document the environmental contribution to these differences. 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 unacceptablv 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 cancer of different types. 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
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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 ug/dl By Race and Income
Black
White
Less Than
$6,000
68%
36%
$6,000-$15,000
54%
23%
More Than
$15,000
38%
12%
SOURCE; ATSDR, 1988.
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, EPA'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.Oof the Appendix for more detailed information on this finding.
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2. While there are large gaps in data on actual health effects, it is possible
to document differences in observed and potential exposure to some
environmental pollutants bv socioeconomic factors and race. Exposure
is not the same as health effects, but this finding is nevertheless a clear
cause for concern.
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 minorities 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:
o Individuals who experience the highest exposures.
o 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.
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
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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
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%
SOURCE; DOC, 1990.
Information on other racial minorities for this chart or
any other charts was not provided because it was absent from the
original studies.
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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
Nieyes, 1991). Table 3 is a summary of their findings. Some of
the differences can be explained by regional variations in
population patterns, but unexplained differences among Whites,
Blacks, and Hispanics remain.
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%
52.5%
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%
* Totals by population groups are greater than 100% because counties may
be included in more than one non-attainment category.
** Hispanics may be of either race, since Hispanic is an ethnic, not a
racial, category.
Source; Hernette and Nieves, 1991.
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 GAO's findings are
15
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listed in Table 4.
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 (S)
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)
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 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.
16
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Figure 1. Minority Percentage of the Population in U.S.
Communities with Operating Commercial
Hazardous Waste Facilities
Percentages
4C
40
tt
90
CC
SO
IS
10
s
Growl
Group I
Group
Orat* IV
Groups
I: Residential 5-digit ZIP code areas without operating commercial
hazardous waste treatment, storage and disposal facilities.
II: Residential S-digit ZIP code areas with one operating commercial
hazardous waste treatment, storage and disposal facility that is
not a landfill.
Ill: 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.
Source; UCC (1987)
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
17
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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.
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,
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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
link between pesticides and health (Perfecto, 1990). However, it
is estimated that as many as 313,000 farmworkers experience
pesticide related illnesses each year (Wasserstrom and Wiles,
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 Florida (Griffith and Duncan, 1983). Data from the
National Adipose Tissue Survey for 1982 found 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 relatively high human
health risk due to the large numbers of workers directly exposed
to a range of highly toxic chemicals. "[Agricultural workers
are exposed to many toxic substances in the workplace. Such
exposures can cause cancer and a wide range of non-cancer health
efficts" (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
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final in 1992.
For more detailed information on health effects and exposures, see Sec. 2. Oof the Appendix.
3. Environmental and health data simply are not routinely collected and
analyzed by income and race. Nor are data routinely collected on
health risks posed bv multiple industrial facilities, cumulative and
svnerfistic 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, improvements
can be made in data collection procedures.
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 the 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 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
20
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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.
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.
The Appendix, 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-wav
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
21
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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.
.EPA has a Risk Communication Program which has generated
materials that contain general principles on risk communication
and.very 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 minorities and low-income people, 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 the Appendix, Sec. 6.4.)
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. Expanding
outreach to religious organizations will be breaking new ground
for the Agency, but is important nonetheless.
See the Appendix, Sec. 6.0, for a detailed discussion of risk communication and Sec. 7.0 for
more information on outreach.
22
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5. There is a great deal of variation among EPA *s program and regional
offices 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 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 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.
23
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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 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
24
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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 American Indian 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 {he Appendix, 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.
Material belongs tor
Office of Toxic Substances Library
25 U.S. Environmental Protection Agency
401 M Street, S.W. TS-793
Washington, D.C. 20460
(202) 382-3944
-------
Based on the limited data available, several population
groups identified as being sensitive to the health effects of air
pollution seen 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 impacts
on low-income people than on middle- or high-income groups. For
example, under the Act, EPA roust 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 the Appendix, Sec. 3.2.
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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 is 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 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 III
(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 VIII (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 the Appendix, Sec. 8.0.
27
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6. Native American Indians are a unique racial group with a special
relationship with the federal government and distinct environmental
problems. Indian 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 unique trust 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:
o Indian 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.
o While individual risks may be high on some
reservations, Indian Tribes potentially may be
overlooked in EPA's risk-based approach. Typically,
Indian reservations have low populations with
relatively large land areas, and population risk will
often be small relative to other, especially urban,
population groups.
o EPA's risk analysis methodologies may not include
factors (e.g., diet and other cultural practices) which
accurately assess risk in Indian country. '
o Many Indian 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 Indian
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
28
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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
the many Tribes have no effective way to manage environmental
problems on reservations. This point has significant
implications for environmental risks to Indian populations
generally and for EPA Indian programs 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 the Appendix, Sec. 4.0, for more information on Native American Indian Tribes.
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CHAPTER FOUR
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.
The Appendix, Sec. 10.0, contains funher examples and details on the recommendations,
including suggested time frames.
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
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the environment. Bather, 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:
o 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.
o Top Agency managers could signal to outside groups in the
public and private sectors that environmental equity should
be given higher priority.
o 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, commencing
with developing 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:
o 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.
o Analyses could be undertaken to identify critical
characteristics of racial, ethnic, and class groups which
would significantly alter the susceptibilities of that
population group.
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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 population, communities or geographic areas. In some cases it
mav be important to know 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.
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.
Some examples of specific ways in which EPA could implement
this recommendation include:
o 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.
o 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
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concept which includes: cumulative exposures; multiple
exposures; increased susceptibility; the effects of
multiple/different pathways of exposure.
o 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.
o EPA could, where feasible and appropriate, identify and
demographically characterize the population residing within
the high-end of exposures.
o EPA could study ways in which to assess environmental risks
to Indian populations.
o 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
RISK POPULA TIONS
4. EPA should identify and target opportunities to reduce high
concentrations of risk to different 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:
o EPA could further develop its enforcement prioritization
policy to target high risk populations. Under this scheme,
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.)
o 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
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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, selectively assess and consider the
distribution of projected risk reduction in maior rulemakings 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:
o 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.
o The Agency could establish risk management guidelines which
would require considerations and evaluations of
environmental equity when arriving at regulatory decisions.
INTEGRATING EQUITY AND EPA OPERATIONS
6. EPA should review and selectively 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
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are a variety of these procedures that should be refined to
address environmental equity issues. To determine exactly 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:
o EPA could incorporate language in selected permit, grant and
enforcement guidelines which places priority on high risk
populations.
o Each headquarters and regional office could engage in a
review of its activities and present to the Administrator a
detailed plan of how it will achieve the Agency's equity
goals. These plans could be included in the strategic
planning and budget process.
o 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.
o 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.
o 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.
o Recognizing legislation and budget authorization limits, EPA
could explore ways to increase funding, training, and other
support to Indian 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.
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EXPANDING OUTREACH AND COMMUNICATION
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
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:
o 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.
o EPA could improve targeted outreach and environmental
education literature for racial minority and low-income
.communities.
o Each EPA regional office could develop two-way communication
programs similar to Region I's Urban Environmental
Initiative and Region VIII's Outreach Program in Ethnic
Communities. (See the Description of EPA Projects and the
Appendix, Sec. 8.2, for more details.)
o 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.
o EPA could establish outreach representatives for minority
and low-income communities in each of its regional offices.
o EPA could translate more of its published materials into
languages other than English.
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ASSURING LONG-TERM SUCCESS
8. EPA should establish mechanisms 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 the Appendix, Sec. 9.0.)
Some examples of specific ways in which EPA could implement
this recommendation include:
o EPA could incorporate environmental equity in the strategic
planning and budgeting process.
o EPA could establish an external Environmental Equity
Advisory Committee.
o EPA could continue the EPA Environmental Equity Workgroup
and provide staff and resources for implementing the
recommendations of this report, including time tables.
o 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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FS OF EXISTING El
This section is provided to illustrate practical examples of
approaches to addressing and solving environmental equity
concerns. The Appendix, 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
Rogion: I (Boston) Contact: James Younger
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 problems 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: II (New York) Contact: Joseph Clore
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: III (Philadelphia) Contact: Dominique LuecXenhoff
Multi-media environmental risk profiles for socioeconomic
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subgroups within the study.area will be developed and displayed
on Geographic Information System (CIS) maps. CIS 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, 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: III (Philadelphia) Contact: Dominique Lueckenhoff
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: III Contact: Aquanetta Dickens
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 on their experiences and perceptions of the problems.
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Project Name: Lead Education and Abatement Program
(Project LEAP)
Region: V (Chicago) Contact: William H. Sanders III
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 will be
completed by March, 1992.
Project Name: Geographic Enforcement Initiative
Region: V (Chicago) Contact: Bert Prey
The Region 5 Geographic Enforcement Initiative (GEI) is a
major part of a risk-based, multi-media effort focused on
Southeast Chicago and Northwestern Indian. 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.
Project Name: Region VII Indian Strategy
Region: VII (Kansas City) Contact: Mike Bronoski
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 VII is implementing the strategy
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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 VII is distributing an
environmental curriculum to the reservation schools accompanied
by teacher training, distributing training videos to the Tribes,
and coordinating with the local Indian junior colleges.
Groundwater contamination is being addressed with additional
outreach and by including a groundwater component in all grants
awarded to Tribes.
Project Name: Environmental Education Initiative
Region: VII (Kansas City) Contact: Rovena Michaels
Region VII 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 VII. The Center will continue to assure that diversity
is a special focus in future educational efforts.
The Region VII 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: Equitable Enforcement Investigation
Region: VIII (Denver) Contact: Elmer Chenault
Region VIII has initiated an investigation of polluting
facilities and enforcement actions in the Denver-Boulder
metropolitan area using Geographic Information System (CIS)
technology. The concern is that one or more localities may
experience a significant degree of inequity with regard to the
level of enforcement.
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Project Name: Outreach Program in Ethnic Communities
Region: VZIZ (Denver) Contact: Elmer Chenault
Region VIII 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 VIII 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.
Project Name: California Migrant Labor Camp Drinking Water
Enforcement Program
Region: IX (San Francisco) 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: IX (San Francisco) Contact: Gerald Hiatt
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
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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.
M
Project Name: Pesticide Applicator Training
Region: X (Seattle) Contact: Allan Welch
Region X 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 X. 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.
Project Name: Wisconsin Tribes Comparative Risk Project
Region: Headquarters/v (Chicago) Contact: Catherine Tunis/
Steve Dodge
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 V.
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.
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Project Name: Mexico-U.S. Integrated Border Environmental Plan
Headquarters/Region VI/Region IX Contact: Richard Kiy
In response to a request by the Presidents of the Mexico and
the U.S. in November, 1990, EPA and its Mexican counterpart are
developing 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 will be
released in mid-winter of 1992. To begin making progress
immediately, the U.S. National Enforcement Training Institute
will hold training sessions for Mexican inspectors of maquiladora
industries on March 23-27, 1992.
Project Name: x A Methodology for Estimating Population Exposure from
the Consumption of Chemically Contaminated Fish
Headquarters/Region X (Seattle) 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 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 Indian tribes are
being surveyed about their fish consumption habits.
Project Name: Environmental Equity Analysis of RCRA Corrective
Action Final Rule
Headquarters contact: Barnes Johnson
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
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for cleaning up releases and spills at commercial hazardous waste
facilities. As part of the regulatory impact analysis for this
rules, 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
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
The Environmental Equity Workgroup Report targets lack of
data on the distribution of environmental risks as a serious
concern. The Office of Health Research (ORD) has begun
addressing the Workgroup's recommendations for research by
initiating a project to develop approaches and perform analyses
to collect information the Agency needs to address environmental
equity issues. Part of this study involves the evaluation of the
relationship between levels of pollutant emissions and the extent
of potential exposure to racial minorities and/or people of lower
socioeconomic status. This type of analysis will be performed on
a national, state, county and local level. As an initial phase
of the project, demographics data on race and income will be
linked with exposure information, from the Toxics Release
Inventory (TRI), on location and magnitude of emissions. This is
a long-term effort that will begin 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. Horn, T. Gibbs, and P. Greenwald, 1991.
"Socioeconomic Factors and Cancer Incidence Among Blacks and
Whites", Journal of the National Cancer Institute. 83: 551-557.
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, I.F. 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.
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McCallum, M., 1985. Recreational and Subsistence Catch and
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Wasserstrom, R.F. and R. Wiles, 1985. Field Duty, U.S.
Farmworkers and Pesticide Safety. World Resources Institute,
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A Preliminary Gee-Demographic Analysis", presented at the
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Proceedings of the Michigan Conference on Race and the Incidence
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An extensive bibliography can be found in the Appendix, 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
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
PUERTO
RICO
Regions
3 Pennsylvania
1 Rhode Island
4 South Carolina
8 South Dakota
4 Tennessee
6 Texas
8 Utah
1 Vermont
3 Virginia
10 Washington
3 West Virginia
5 Wisconsin
8 Wyoming
9 American Samoa
9 Guam
2 Puerto Rico
2 Virgin Islands
49
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