NATIONAL ENVIRONMENT JUSTICE
ADVISORY COUNCIL (NEJAC)
JUNE 2022 MEETING SUMMARY
VIRTUAL PUBLIC MEETING
JUNE 22 - 23,2022
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TABLE OF CONTENTS
PREFACE 3
AGENDA 5
1.0 NEJAC Meeting 7
1.1 Welcome, Introductions, & Opening Remarks 7
1.2 Welcome & EPA Updates 7
1.3 OEJ Consultation with NEJAC on EPA's Thriving Communities Technical
Assistance Centers 8
1.3.1 Jacob Burney, EJ Grants Program Manager, Office of Environmental Justice - U.S.
EPA 8
1.4 EPA PFAS Council Updates 11
1.4.1 Zach Schafer, Senior Advisor, Office of Water, U.S. EPA 12
1.5 Special Community Voices Panel Session: Air Quality and Community
Monitoring 15
1.5.1 Christina Rosan, PhD, Faculty Fellow, Temple University's Center for Sustainable
Communities 15
1.5.2 Naida Montes, PhD Candidate, Temple University and Community Organizer 16
1.5.3 Megan Heckert, PhD, Associate Professor, West Chester University 15
1.5.4 Russell Zerbo, Advocate, Clean Air Council 16
1.6 Public Comment Period 188
1.7 Closing Remarks & Adjourn 34
2.0 Welcome, Introductions, & Day 1 Recap & Opening Remarks 34
2.1 Welcome, EPA Updates, & Dialogue 34
2.1.1 Michael Regan, Administrator - U.S EPA 34
2.2 NEJAC Business Meeting 38
2.3 NEJAC Workgroup Updates 47
2.4 Announcements and Appreciations 48
2.5 Closing Remarks & Adjourn 48
Online Submitted Written Public Comments Error! Bookmark not defined.
Additional Submitted Written Public Comments - APPENDIX 1 50
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PREFACE
The National Environmental Justice Advisory Council (NEJAC) is a federal advisory committee
that was established by charter on September 30, 1993, to provide independent advice,
consultation, and recommendations to the Administrator of the U.S. Environmental Protection
Agency (EPA) on matters related to environmental justice.
As a federal advisory committee, NEJAC is governed by the Federal Advisory Committee Act
(FACA) enacted on October 6, 1972. FACA provisions include the following requirements:
Members must be selected and appointed by EPA.
Members must attend and participate fully in meetings.
Meetings must be open to the public, except as specified by the EPA Administrator.
All meetings must be announced in the Federal Register.
Public participation must be allowed at all public meetings.
The public must be provided access to materials distributed during the meeting.
Meeting minutes must be kept and made available to the public.
A designated federal official (DFO) must be present at all meetings.
The advisory committee must provide independent judgment that is not influenced by
special interest groups.
EPA's Office of Environmental Justice (OEJ) maintains summary reports of all NEJAC
meetings, which are available on the NEJAC website at
https.VAvww.epa.gov/environmentaljustice/national-environmental-justice-advisory- council-
meetings. All meeting materials are posted in the public docket for this meeting. The public
docket number for this meeting is EPA-HQ-OA-2022-0053. The public docket is accessible via
www.regulations.gov under its docket number, EPA-HQ-OA-2022-0053.
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Committee Members in Attendance
1. Sylvia Orduno, Chair, Michigan Welfare Rights Organization
2. Na'Taki Osborne Jelks, PhD, Vice-Chair, West Atlanta Watershed Alliance/Proctor
Creek
3. Michael Tilchin, Vice-Chair, Jacobs Engineering
4. Jan Marie Fritz, PhD, C.C.S, University of Cincinnati
5. Jill Lindsey Harrison, PhD, University of Colorado Boulder
6. Benjamin J. Pauli, PhD, Kettering University
7. Sandra Whitehead, PhD, MP A, George Washington University
8. Rev. Dr. Ambrose Carroll, Sr., Green the Church
9. Leticia Colon de Mejias, Green ECO Warriors
10. Cemelli de Aztlan, La Mujer Obrera
11. Sofia Owen, JD, Environmental Justice Legal Services (EJLS)/Alternatives for
Community & Environment (ACE)
12. Jerome Shabazz, JASTECH Development Services Inc. and Overbrook Environmental
Education Center
13. Brenda Torres Barreto, San Juan Bay Estuary Program
14. Andy Kricun, U.S. Water Alliance
15. Ayako Nagano, JD, Common Vision
16. Jacqueline D. Shirley, MPH, Rural Community Assistance Corporation
17. Millie Piazza, PhD., Washington State Department of Ecology
18. Scott Clow, Ute Mountain Ute Tribe
19. John Doyle, Little Big Horn College
20. Jonathan Perry, Becenti Chapter, Navajo Nation
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AGENDA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
NATIONAL ENVIRONMENTAL JUSTICE ADVISORY COUNCIL (NEJAC)
FULLY VIRTUAL PUBLIC MEETING
JUNE 22-23, 2022
1:00 P.M.-6:00 P.M. EDT DAILY
PUBLIC DOCKET NO.
EPA-HQ-OA-2022-0053 at www.requlations.gov
NEJAC MEETING WEBSITE:
https://www.epa.qov/environmentaliustice/national-environmental-iustice-
advisorv-council-meetinqs
DAY 1. WEDNESDAY June 22, 2022
1:00 pm- 1:10 pm
Welcome, Introductions, 8. Opening Remarks
o Fred Jenkins Jr., PhD, Designated Federal Officer - U.S. EPA
o Matthew Tejada, PhD, Director, Office of Environmental Justice (OEJ) - U.S. EPA
o Sylvia Orduno, National Environmental Justice Advisory Council Chair - Michigan Welfare
Rights Organization
o Na'Taki Osborne Jelks, PhD, National Environmental Justice Advisory Council Vice Chair -
West Atlanta Watershed Alliance and Proctor Creek Stewardship Council
o Michael Tilchin, National Environmental Justice Advisory Council Vice Chair - Jacobs
Engineering
1:10 pm - 1:20 pm
Welcome 8. EPA Updates
Matthew Tejada, PhD, Director, Office of Environmental Justice - U.S. EPA
DAY 1: WEDNESDAY June 22, 2022
1:20 pm - 2:05 pm
OEJ Consultation with NEJAC on EPA's Proposed Thriving Communities Technical Assistance
Centers
o Jacob Burney, EJ Grants Program Manager - U.S. EPA
2:05 pm - 3:00 pm
EPA PFAS Council Updates
o Zach Schafer, Senior Advisor to the Office of Water and EPA PFAS Council Representative -
U.S. EPA
3:00 pm - 3:15 pm
BREAK
3:15 pm - 4:15 pm
Special Community Voices Panel Session: Air Quality and Community Monitoring
o Panel: Preparing for Resilience and Equity with Accessible Community Technology (PREACT)
Project in Philadelphia, PA.
Christina Rosan, PhD, Faculty Fellow at Temple University's Center for Sustainable
Communities and Associate Professor of Geography and Urban Studies
Megan Heckert, PhD, Associate Professor, West Chester University
Naida Montes, PhD Candidate at Temple University and Community Organizer
Russell Zerbo, Advocate at Clean Air Council
4:15 pm -5:55 pm
PUBLIC COMMENT PERIOD
Members of the public will be given three (3) minutes to present comments on their issue or
concern to the NEJAC.
5:55 pm - 6:00 pm
CLOSING REMARKS & ADJOURN
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DAY 2: THURSDAY JUNE 23, 2022
1:00 pm - 1:05 pm
WELCOME, INTRODUCTIONS, & DAY 1 RECAP & OPENING REMARKS
o Fred Jenkins Jr., PhD, Designated Federal Officer - U.S. EPA
o Matthew Tejada, PhD, Director, Office of Environmental Justice - U.S. EPA
o Sylvia Orduno, National Environmental Justice Advisory Council Chair - Michigan Welfare
Rights Organization
o Na'Taki Osborne Jelks, PhD, National Environmental Justice Advisory Council Vice Chair -
West Atlanta Watershed Alliance and Proctor Creek Stewardship Council
o Michael Tilchin, National Environmental Justice Advisory Council Vice Chair - Jacobs
Engineering
1:05 pm - 1:30 pm
WELCOME, EPA UPDATES, 8. DIALOGUE
o Michael Regan, Administrator-U.S EPA
1:30 pm - 3:30 pm
NEJAC Business Meeting
o Discussion and Feedback on Proposed Thriving Communities Technical Assistance Centers
Proposal
o Finance and Investment Workgroup present and discuss proposed recommendations for
consideration by NEJAC
o PFAS Workgroup Discussion and Feedback
3:30 pm - 3:40 pm
BREAK
DAY THURSDAY JUNE 2022
3:40 pm-4:30 pm
NEJAC BUSINESS MEETING (Cont'd)
NEJAC Workgroup Updates
o Air Quality and Community Monitoring Workgroup
o Water Infrastructure Workgroup
o Farmworkers and Pesticide Workgroup
o NEPA Workgroup
4:30 pm - 4:50 pm
Announcements and Appreciations
o Matthew Tejada, PhD, Director, Office of Environmental Justice - U.S. EPA
o Sylvia Orduno, National Environmental Justice Advisory Council Chair - Michigan Welfare
Rights Organization
4:50 PM - 5:00 pm
CLOSING REMARKS & ADJOURN
Note: Please be advised that agenda times are approximate; when the discussion for one topic is completed,
discussions for the next topic will begin. For further information, please contact the Designated Federal Officer for
this meeting, Fred Jenkins Jr., PhD, atjenkins.fred@epa.gov.
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NATIONAL ENVIRONMENTAL JUSTICE ADVISORY COUNCIL
Virtual Public Meeting
June 22 - 23, 2022
MEETING SUMMARY
The National Environmental Justice Advisory Council convened via Zoom meeting on
Wednesday, June 22 and Thursday, June 23, 2022. This summary covers NEJAC members'
deliberations during the meeting and the discussions during the public comment period.
1.0 NEJAC Meeting
This section summarizes NEJAC members' deliberations during the two-day meeting, including
action items, requests, and recommendations.
1.1 Welcome, Introductions, & Opening Remarks
Fred Jenkins, Designated Federal Officer (DFO), U.S. EPA, welcomed attendees and made
announcements. He stated that everyone is in listen and view mode only, and public commenters
are invited to speak later that afternoon. He stated that anyone who didn't get a chance to speak
during the allotted time can submit their comment in writing to the NEJAC website by July 6,
2022. He noted that Spanish translation and closed captioning were available. He turned the
meeting over to Matthew Tejada, the director of the Office of Environmental Justice, for opening
remarks.
Dr. Matthew Tejada, Director, Office of Environmental Justice, U.S. EPA, informed everyone
that this is Dr. Jenkins final meeting as the DFO. He thanked Dr. Jenkins for all the work he has
done. He stated this will be a full meeting with discussions and decisions that will need to be
made. He thanked the members for their time and dedication.
Sylvia Orduno welcomed everyone and thanked Dr. Jenkins for his hard work. Michael Tilchin
informed her that quorum has been met. She thanked the Council for their dedication. She
introduced herself and informed the Council of a new aspect of the meeting - a community
voices panel.
Dr. Na'Taki Osborne Jelks introduced herself and thanked Dr. Jenkins and the members for
their hard work. She also thanked the public for sharing their stories. Vice-Chair Tilchin also
thanked Dr. Jenkins.
Chair Orduno invited the members to introduce themselves.
1.2 Welcome & EPA Updates
Dr. Tejada stated that the environmental justice (EJ) budget within EPA received a substantial
increase in FY'22. This was following the $50 million that was received earlier with the
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American Rescue Plan. That was for all EJ programs across the EPA. He stated that normally
they receive $15 million every year. He stated that this increase will go directly to the EJ Grants
program and the staff processing the grants. Their goal is to effectively spend that money. This
allocation must be spent by the end of the FY'22, or it will be lost. Jacob Burney will speak to
that program next. Dr. Tejada reminded everyone that the grant money goes toward EJ
communities that have been chosen as a priority.
1.3 OEJ Consultation with NEJAC on EPA's Thriving Communities Technical Assistance
Centers
1.3.1 Jacob Burney, EJ Grants Program Manager Office of Environmental Justice - U.S.
EPA
Jacob Burney thanked everyone for sending feedback in terms of the tentative plans for the
overall plan they have for the Thriving Communities Technical Assistance Centers as well as the
traditional EJ grants programs.
Mr. Burney stated, again, that EPA received over $50 million going to EJ grants and technical
assistance and must be spent by the end of FY'22. Some of the funds are allocated to EJ staff
both regionally and within the EJ Grants program who will provide oversight and substantial
involvement with the technical assistance providers, and direct oversight over the larger EJ
capacity and implementation grants. There may be changes in how the connections and
relationships are structured compared to what everyone's used to. He stated that there will be a
dedicated EPA project officer for each individual EJ grant just because there are so many
additional funds.
Mr. Burney explained the name change to the Thriving Communities Technical Assistance
Centers. The network will work with many federal agencies, including United States Department
of Housing and Urban Development (HUD), U.S. Department of Transportation (DOT), United
States Department of Energy (DOE), United States Department of Agriculture (USD A), and
others. Those agencies are already involved in the centers. He explained the overview of the
centers. The centers will establish hubs to provide support for EJ equity issues, capacity building,
grant writing training, and other kinds of training. These centers will be spread out across the
U.S. The grants applications to establish those centers are due this summer. The centers may be
grouped by region. Those centers would be financially supported even after FY'22. The regional
EPA EJ staff will be lead liaisons working with centers, receiving cooperative agreements which
would necessitate substantial involvement and oversight by EPA. EJ staff officer teams would
meet with each center at least monthly, reviewing their structure, technical assistance to EJ
communities, and outreach to remote areas.
Mr. Burney explained the reasons for the centers. Many stakeholders and members have shared
this idea for years. The appropriation of funding from the Bipartisan Infrastructure Law finally
came through. The current administration made this a priority to advance equity and
environmental justice. Multiple agencies are interested in leveraging resources and coordinating
efforts to maximize the value of the technical assistance programs.
Mr. Burney explained the goals of the centers. One is to meaningfully engage and collaborate
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which focuses on those community-driven goals and needs and the ability to inform the decision-
making process. Centers will proactively reach out to stakeholders and underserved communities
about the services they provide and how to access them; provide a broad range of technical
assistance; use of online tools and resources technology to facilitate access to information; and
deploy community-based engagement activities to assess project progress and community needs,
training, tools, and resources.
Mr. Burney explained the second goal which is interagency collaboration and coordination to
provide federal, place-based commitments and pooling of resources; coordinate and leverage
interagency technical assistance funding and resources to maximize the effectiveness of the
program; and provide federal, place-based and regional commitments to include ground floor,
low-capacity assistance opportunities and training, and interagency funding opportunities.
Mr. Burney explained the last goal which is community-centric collaborations. They provide TA
to local communities and stakeholders, especially underserved communities, free of charge. They
include counseling services for underserved communities on EJ, "how to" assistance in writing
competitive grant proposals, financial resource grant management assistance, community
engagement with other EJ partners, tracking and analyzing results, environmental justice analysis
of communities (EJSCREEN analysis, on-the-ground problem site identification, and/or
interviews of community residents detailing their EJ concerns), coordination and/or facilitation
services for meetings between local stakeholders (community residents, local elected officials,
port authority, industry, et cetera), translation and interpreting services for meaningful
engagement with limited English speaking participants.
Mr. Burney explained the short-term outlook for the program. They are looking to release the
Request for Applications (RFAs) by this summer. The eligible entities to serve as centers include
public/private universities, larger nonprofits, and Intertribal Consortia. Eligible stakeholders to
receive the services include underserved communities interested in EPA grant programs
(nonprofits, grassroots organizations, and local and state government entities that are looking to
engage in racial equity).
Mr. Burney explained the breakdown of the FY'22 budget. There was a slide showing the
breakdown. He then explained the new implementation authority. Traditionally, the EJ grant
activities were limited to research, demonstrations, and training and/or education activities. Now,
EJ grant activities have been expanded to include implementation activities such as small-scale
construction, refurbishment, mitigation of hazardous waste disposal, general clean-ups, and
installations. OEJ will work with EPA media programs and the Office of General Counsel
(OGC) to develop implementation project examples.
Mr. Burney explained the restructuring of EJ small grants and the sub-award model. Prior to this
restructuring, it would take about nine months of back-and-forth paperwork for applicants to get
approval for a grant. So now EPA would give the larger one or two entities $10 million each via
cooperative agreements. They would then sub-award the funds to the grassroots organizations
that need them the most. Communities will technically be subgrantees and will receive the funds
through the Funder(s) instead of directly through EPA. Communities will submit reports and
project updates to the funder(s). That change would alleviate a lot of the application burden on
communities. Awards are capped at $100,000 for each one-year project.
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Mr. Burney explained some of the concerns raised including the lack of an EPA project officer
or EPA staff involvement to provide oversight and possibly perpetuating existing inequality and
bias, lack of local connections, and a high percentage of funds going to the funder's overhead.
He then explained how to address some of those concerns, including expediting the process,
learning from the pilot program, evaluating historical grant recipients, setting a cap for overhead
costs, and scoring applications by EPA staff.
Mr. Burney then explained the cooperative agreement programs. They will continue to be
managed directly by EPA. Funds will at least double from FY'21 levels. Project periods will
likely be increased to three to five years. Nonprofits, U.S. territories, states, local governments,
and tribes will be eligible for them. They will be released by October or November 2022.
Mr. Burney stated that EPA is seeking feedback on the TA concept and the EJ Grants plan before
releasing the TA Request for Applications in summer 2022. All suggestions and written feedback
are tracked. He stated specific questions to shape the feedback.
Chair Orduno thanked Mr. Burney for the great presentation. It outlined what NEJAC has been
wanting to see, but she felt overwhelmed by the new program. She asked if there is a difference
between "centers" or "hubs" and if these are physical aspects or just online. Mr. Burney
answered that they are synonymous, and they are more of a virtual presence, but there will also
be physical locations. Chair Orduno invited members to ask questions or offer impressions. She
reminded the members that during the business meeting is where more specific recommendations
for additions or changes can be offered.
Jerome Shabazz thanked Mr. Burney for his presentation and applauded the idea of having
physical places for applicants to go for their EJ needs. He asked whether or not there is an
emphasis on where these centers need to be located respective to the clientele. Mr. Burney
replied that EPA has strongly recommended MSIs or HBCUs to apply to be a center. They have
a historic connection to underserved populations and communities. Mr. Shabazz rephrased his
question. Is there anything written into this RFA that would require that larger entities partner
with an actual community and affected neighborhood where those services might be overlooked?
Mr. Burney replied that they would encourage those connections to be articulated explicitly in
the RFA.
Vice-Chair Jelks asked, is there a particular definition around what a large non-profit is? In
terms of the EJ Small Grants Program, if these various entities are TA providers, they're going to
get about $100,000. She asked, does that mean that the EJ Small Grant award amounts will go
back down to the $20 to $30,000 range? Does that mean that the TA providers will split that
money into smaller grants beyond what their overhead might be? What's the difference in terms
of money that goes to the TA facilities versus money directly to communities through the grant
process? Mr. Burney replied that the funds for the TA centers, which are in the missions of
dollars, are separate from the funds for small grants. TA centers aren't receiving just $100,000.
Each hub will receive multiple millions of dollars to provide TA to certain EPA regions and
localities. The small grants will be provided about ten million dollars overall to be subaward to
grassroots organizations and small non-profits. There will be no other EPA small grants
opportunity this year other than that larger subaward model. Vice-Chair Jelks asked what the
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range is of funds for just the small grants. Mr. Burney answered that the cap is $100,000 for
each sub-award grant.
Sofia Owen asked, how is "underserved community" being defined? She added she shared many
of the concerns already mentioned and will address the rest of her concerns from his presentation
tomorrow. Mr. Burney replied that the definition of underserved communities is the same
definition that EJ Grants Program uses and is in the Racial Equity Order as well.
Ayako Nagano echoed what everyone said about the subgrants regarding concerns with non-
profits still trying to hold anti-racist, equity work. She highly recommended looking at the
historical record of those non-profits and if they are doing work with EJ organizations. She asked
what the hook was to get the other federal agencies to work with the TA centers and who they
are. Mr. Burney replied that the Thriving Communities network in the DOT appropriations is
mandated to be involved serving underserved and overburdened populations. The agencies
include DOT, DOE, USD A, HUD, and others.
Leticia Colon de Mejias asked how the two entities will be able to track in relation to ensuring
the subgrantees are diverse? She recommended looking at the overhead costs of the entities to
administer the grants and the application burden to subgrantees. She reminded everyone to be
careful with acronyms during the meeting because there may be people listening who don't know
what they are. She also recommended that all underserved communities are reached equitably.
She stated that, with this new program, she wants to make sure to avoid repeating the historic,
systemic, and racial exclusion of people. Mr. Burney agreed with her and explained the
acronyms he used in his presentation. He will explain tomorrow how those large, managing
entities can prevent having biases built into their selection process and ensure that the grant-
writing burden is alleviated.
Chair Orduno stated her concern with so much crammed into such a short timeframe for this
program and what that's going to mean for impacted communities who have to figure it all out to
participate effectively. Being a competitive process just adds to the burden and anxiety to apply
successfully. She asked if there was a way to be less competitive in spreading the wealth or
lengthening the timeline to build in more opportunity for more groups, especially first-time
applicants, and with more equity.
Andy Kricun stated that the program is terrific to get the resources where they are needed. He
asked how they can make it more sustainable and embedded. He also asked about interfacing
with compliance issues from industries and communities that need the help.
Chair Orduno stated that she looked forward to more of this conversation tomorrow. Mr.
Burney stated that this year is a very unique situation because we have such a short timeframe.
Don't take this timeframe as the standard. The EPA is looking to build more sustainability,
flexibility, and time in terms of the grant programs.
1.4 EPA PFAS Council Updates
DFO Jenkins announced that the Assistant Administrator for the Office of Water was
unable to attend and that, instead, the NEJAC would hear from Zachary Schafer, Senior
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Advisor, Office of Water.
1.4.1 Zach Schafer, Senior Advisor, Office of Water, U.S. EPA
Zach Schafer introduced other members of his office staff who are attending the meeting:
Jennifer McClain, Office of Groundwater and Drinking Water; Susan Burden, Office of
Research and Development; Ava Azad, Federal Facilities Enforcement Office; Jeff Dawson,
Office of Chemical Safety and Pollution Prevention; Matt Klasen, PFAS Council Manager. He
gave an overview of his presentation which would include EPA's approach to the roadmap and
recent progress for action in program areas. Mr. Schafer highlighted an important announcement
last week of new drinking water health advisories for four PFAS and new grant funding from the
Bipartisan Infrastructure Law. He added appreciation to the NEJAC PFAS workgroup for its
help to guide ongoing PFAS work.
He stated that, in April 2021, Administrator Regan established the EPA Council on PFAS and
charged it to develop a bold, strategic, and whole-of-EPA strategy to protect public health and
the environment from the impacts of PFAS. The council is comprised of senior technical and
policy leaders from across EPA's program offices and regions. He stated that the roadmap does
several things: lays out EPA's whole-of-agency approach to tackling PFAS, sets clear timelines
for concrete actions from 2021 to 2024, fills a critical gap in federal leadership, supports states'
ongoing efforts to tackle PFAS, and builds on the administration's commitment to restore
scientific integrity by making science the foundation of the work.
Mr. Schafer explained the background of PFAS and why there is such a concern about it. They
are a large class of synthetic chemicals and have been used since the 1940s in homes, businesses,
and industry in many consumer products. PFAS have been detected in soil, water, and air
samples around the world and CDC surveys show most people in the U.S. have been exposed to
it. Known or suspected toxins cause potential developmental, liver, immune, and thyroid effects.
They don't break down in the environment or in the human body and have been designed to be
durable, hence, their colloquial name as "forever chemicals." He explained the PFAS lifecycle
and EPA's approach to the challenges in industrial and consumer applications. They include: (1)
considering the lifecycle of PFAS and their many pathways for exposure, (2) getting upstream of
the problem, (3) holding polluters accountable, (4) ensuring science-based decision-making, and
(5) prioritizing the protection of disadvantaged communities with equitable access to solutions.
Mr. Schafer explained the three goals of the strategic roadmap include attacking the problem on
multiple fronts at the same time. The first is research in understanding the exposures and
toxicities, ecological effects, and effective interventions that incorporate the best-available
science. The second is to restrict the polluters from releasing it into the air, land, and water.
Lastly is to remediate or clean up the contamination to protect human health and ecological
systems.
Mr. Schafer stated that the roadmap includes actions and timelines across all of EPA's major
program offices. Those include the Office of Chemical Safety and Pollution Prevention with
TSCA and the Toxics Release Inventory, the Office of Water with the Safe Drinking Water Act
and the Clean Water Act, the Office of Land and Emergency Management with superfund,
CERCLA and RCRA, the Office of Air and Radiation with the Clean Air Act, and the Office of
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Research and Development.
Mr. Schafer explained the updates since last October. That includes EPA's actions to restrict
PFAS, reduce PFAS in products purchased by the federal government, evaluate and develop
technologies and methods for measuring and reducing PFAS in the environment, announce four
PFAS health advisories and $1 billion in Bipartisan Infrastructure Law funding, and develop
regulations to designate PFOS and PFOA as CERCLA hazardous substances.
Mr. Schafer stated that EPA has released four drinking water health advisories over a lifetime,
particularly for the most sensitive populations, that can be used by states and water utilities to
inform decisions on water quality monitoring and controls. He explained the context of the
advisories. These advisories provide information on contaminants, are not enforceable and non-
regulatory, and include treatment solutions. The interim advisories are based on epidemiological
studies in populations exposed to the chemicals. EPA has information on its website regarding
these advisories. The advisories are a step in the process to propose regulations later this year. In
December 2021, EPA announced upcoming monitoring for 29 PFAS in drinking water. This set
in motion EPA's gathering of data on PFAS and a new round of testing will include five times as
many PFAS at many more water systems with methods that can detect at much lower levels. In
December 2022, EPA plans to propose a national drinking water regulation. And in December
2023, EPA plans to finalize the regulation.
Mr. Schafer stated that EPA announced last week that, through the Bipartisan Infrastructure Law,
the first $1 billion (of $5 billion) was released to be dedicated in grants to small or disadvantaged
communities to address emerging contaminants in drinking water. He highlighted some of the
cross-program actions including engagement and PFAS' impact on people's lives and livelihood,
per a previous NEJAC recommendation. He reiterated their commitment to engaging directly
with affected communities through a regional approach with EJ and disadvantaged communities,
and a focus on tribal perspectives.
Chair Orduno thanked Mr. Schafer for the presentation and turned over the NEJAC discussion
to the chairs of the PFAS Work Group, Dr. Pauli and Dr. Whitehead.
Benjamin Pauli stated that he appreciated the presentation and noted that the health advisories
announcement was met with strong concerns by the water industry. The American Water Works
Association statement said that the PFOS and PFOA advisory levels are extremely low and did
not reflect the recommendations of the Science Advisory Board review. The amounts are
basically undetectable by modern laboratory methods. He added that there are suggestions that
the EPA is not following the science and that water utilities are concerned with feasibility, costs,
and how the health advisories can become regulatory standards. Dr. Pauli asked how the PFAS
Council can speak to potential gaps between what public health scientists and what water
treatment and distributors say is possible. Mr. Schafer replied that the statement of concern
didn't reflect what EPA is doing with these health advisories, which are the best available
assessments. EPA believes the information they have was significant and that it was important to
be transparent and inform the public and utilities about the significantly lower levels at which
adverse health effects may occur. He stated that they are lower than the advisories that came out
in 2016. He stated that EPA will change and set the final maximum contaminant level goal
which is the purely health-based component of the regulation, but it will be below the level of
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detection and the lowest possible for safe drinking water. Mr. Pauli realized that EPA would
receive pressure from both sides in making the regulatory standard.
Sandra Whitehead thought this was a good way to set the stage for this discussion and invited
NEJAC members to ask questions,
Ayako Nagano asked if there was any such thing as an end-user responsibility or extended
producer responsibility. What are the barriers to holding the manufacturers responsible for their
pollutants? Mr. Schafer replied that they are held under the superfund program and the rule that
would allow OLEM to regulate PFOS and PFOA under the CERCLA, and which would allow
impacted communities to recuperate costs of remediation from polluters. Matthew Klason,
Office of Water, U.S. EPA, added that holding polluters accountable is a key principle of the
roadmap and the administration is trying to get upstream of the problem and identify sources and
take action there.
Chair Orduno stated that the presentation and discussion haven't mentioned what is being done
specifically for EJ communities. She knows that there's a lot of testing going on, but what's
happening to remediate the problem areas now in this roadmap by the Office of Water where
there are multiple types of exposure and cumulative health impacts? People are drinking known
contaminated water now, so how can they get safe drinking water now and how is the roadmap
including emergency potable water needs. Mr. Schafer answered that due to time, current
actions weren't included in the presentation. Sampling is a major component of identifying the
worst polluted areas so they can build strategies and policy tools. There is no comprehensive,
national sampling database yet to determine specific dynamics across EJ communities when
levels and histories of exposure are unknown. EPA has already started working with companies
to significantly reduce the amount of PFAS in their products and farmers on protecting their
livestock and crops by reducing exposure, and FDA is working to phase out PFAS in food
packaging. Jennifer McLain, Office of Water, U.S. EPA, added that the Emerging
Contaminants Small and Disadvantaged Communities Grant is dedicated to small and
disadvantaged communities under the law, and 25% of SRF funds are available to address the
contamination and monitor more small systems.
Mr. Kricun asked if, similar to PCBs, there will be an effort for trackbacks, including the
industrial pretreatment information, for sampling at pumping stations to identify high sources.
Would they be working with brownfields when orphan sites are found? He stated that he's glad
to see the funding for the wastewater treatment plant and drinking water upgrades, but is there a
way to get win-wins with biosolids captured at the wastewater plants? Those biosolids capture a
lot of the PFAS and PCBs, so to capture those may eliminate the contamination before it gets to
wastewater and drinking water. He also asked if there was a way to incentivize utilities to do the
upgrades and remove those solids or modify their operations. Susan Burden, Executive Lead,
Office of Research and Development, U.S. EPA, stated that they are looking at existing
treatment and destruction technologies and thinking about and evaluating how well they perform
for PFAS contaminants, but the programmatic side of those questions are outside of the ORD.
Mr. Schafer added EPA is using permits to identify companies that are using these chemicals to
stop discharges where they are occurring. He invited everyone to ask follow-up questions
directly to them due to time constraints in the meeting. Sandra Whitehead stated that the
workgroup is excited about working on Roadmap 2.0.
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DFO Jenkins thanked the presenters for their time and stated that he had received a link to an
FDA article written about PFAS and will share it with the members and will include it in the
public docket. Chair Orduno stated that this issue is very important to the Council. She then
announced it was time for a break.
1.5 Special Community Voices Panel Session: Air Quality and Community Monitoring
Proposed Panel: Preparing for Resilience and Equity with Accessible Community
Technology (PREACT) Project in Philadelphia, PA.
Chair Orduno welcomed everyone back from the break. Mr. Shabazz introduced the next
panelists. He explained the background behind having the community panel speak. His work
group, Air Quality and Community Monitoring, invited this panel to speak to gather community
perspectives about data management and interpretation, access to air quality monitoring, data
anticipation with ARP grants, new techniques of how to monitor it, and having greater access for
community relationships with technology. They have an app that promises to ensure three major
outcomes: to enable and specify geographical interests for communities who need the
information the most, to identify ways to systematically address vulnerabilities within those
communities, and to ensure that data and data assumptions include the representation of the
communities and the needs of the people by their lived experience.
1.5.1 Christina Rosan, PhD, Faculty Fellow, Temple University's Center for Sustainable
Communities
Christina Rosan thanked the Council for the opportunity to speak. She informed the Council
that this is an NSF Smart and Connected Cities planning grant. It's a year-long project built on
many years of different projects that get to the fact that much of the data collected about
environmental justice tend to live at a scale that doesn't reflect the lived experience. She stated
that the app also brings together smaller projects into a larger, more strategic project data
application.
Dr. Rosan said the app uses air quality monitors from different parts of Philadelphia, especially
in areas that are the most affected by pollution to give a more real-time aspect of what's really
happening in the air. She said when talking to communities about air quality, the people bring up
other aspects of pollution that they feel need to be addressed, such as illegal dumping, health
concerns, gentrification, and other issues.
Dr. Rosan gave an example of the app in action. There was a huge tire/junkyard fire near her
neighborhood. She received an alert notification of the unsafe air conditions caused by the fire;
however, the app didn't give recommendations for emergency or safety measures the people
needed to take. She stated that the network is not robust enough, and more monitors are needed.
She gave other examples of other opportunities for accessible community technology. Planning
for environmental justice needs to consider the community's past, present, and how they see their
future.
1.5.2 Naida Montes, PhD Candidate, Temple University and Community Organizer
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Naida Montes stated that part of the work that her group has been doing has engaged
communities on several levels. A community's perspective of the environment goes beyond just
the land or greenspace; it includes issues such as violence, pollution, segregation, aging or vacant
housing, and lack of resources.
Dr. Montes explained the comparison of extremes within Philadelphia. Her mostly minority
community in North Philadelphia is only about five miles away from the Center City District.
There is a 20-year difference in life expectancy between the two areas. She explained asthma
rates also differ between communities. Urban heat islands exist in some areas and not others, but
then there's pushback from residents about the trees that can lead to home or sidewalk damage
despite a need for increasing tree canopies. Some parts of the city are over 20 degrees hotter than
other parts. She showed the overlay of urban heat and gun violence, and where there's more
urban heat, there's more gun violence.
1.5.3 Megan Heckert, PhD, Associate Professor, West Chester University
Megan Heckert stated that environmental justice demands an approach that is local, cumulative,
and intersectional. She explained that Philadelphia has taken a "green" approach to deal with
stormwater runoff and sewer overflows. It is called the Green City, Clean Waters program, and it
was started about ten years ago. The program has found that there isn't enough public land within
the city for this program to succeed if they "greened" everything. The water department has tried
to incentivize and support green infrastructure from private/corporate entities. She explained that
some green areas were well-received and were taken care of, and other areas became more
dumping grounds. Some areas have little to no yards in order to put green space.
Dr. Heckert explained that the group put together a Green Infrastructure Equity Index, which
tried to identify areas with the greatest need for green infrastructure based on 14 different
indicators. There are three different categories of those indicators: environmental need, lack of
amenities, and socio-economic vulnerability. She added you must also think about what's
physically possible to put in a place for green infrastructure and how it will be received
differently by a community. A lot of the indicators came from EJSCREEN in 2015.
1.5.4 Russell Zerbo, Advocate, Clean Air Council
Russell Zerbo explained that the city has tried adding amenities for tackling the hot weather
health crisis such as opening pools, libraries, and rec centers with federal pollution policy. Mr.
Zerbo explained that he and his co-presenters have published their findings, continued reviewing
data, met with community groups, and worked with EPA every step of the way. He stated that
his group set up air monitors around the city, focusing on specific areas around industrial areas.
This monitoring led to a two-year grant to continue monitoring the areas. The EPA subsequently
offered blood lead testing and soil led testing. He shared an example of monitoring around a
huge scrapyard fire. The federal PM2.5 standard is 12 micrograms per meter cubed, and the
readings showed over 2000.
Mr. Zerbo shared an example of a redevelopment of affordable housing with an underground
parking area in an area called the Triangle lot. That lot used to be an old industrial factory that
used to make watch casings and leather shoes, meaning the ground is most likely contaminated.
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Monitors will be set up to watch for airborne and soil pollution as construction begins, including
monitoring at an adjacent recreational center for kids.
Mr. Zerbo stated that he works with the city's air management services to help people make air
pollution complaints. He tracks all the different complaints that come in from people in the city,
mostly illegal dumping.
Dr. Rosan explained that, with the program, there are a lot of community impacts. They're also
trying to build a tool that allows community members to make these complaints and to identify
opportunities in their communities for climate investments that help them be more resilient,
including advocacy, education around solutions, and conversations. She shared some questions
that guided the project.
Chair Orduno offered her appreciation for the presentation and invited Mr. Shabazz and other
members to ask questions and/or make comments. Mr. Shabazz thanked the presenters for their
presentation. He asked them to speak about some of their challenges with the program. Dr.
Rosan answered that the city-level offices didn't trust the technology and data of the monitors,
and they had to figure out how to connect the local monitor data to the city's data. Dr. Jelks
asked about the community's role in co-creating this project and the various tools they are using.
Mr. Zerbo answered that his group had gotten a grant to work with a local EJ group to host three
workshops to address concerns and then install a few monitors. They had one workshop, and
then COVID hit. Suddenly, this large coalition came and met with his group, and they had many
virtual meetings. Now, many of the people in that coalition are part of his program and help with
the deployment and monitoring of the sensors. Dr. Montes added that it really helped to have the
community involved so the academics and policy people get a true picture of real life in these
neighborhoods.
Mr. Shabazz said there was a follow-up question about whether or not these community groups
were able to get funding to remediate some of their concerns. Dr. Heckert replied that there was
a grant whose goal is to develop a grant proposal. Most of the money is going to groups, some of
the money is funding students, and the rest is going to community participants. Dr. Rosan added
that was very difficult just to get community people to come to the meetings. They had to build
trust with the community by writing articles and being face-forward. The key challenge is the
lack of trust where there's illegal dumping, and people don't trust the government.
Ms. Owen stated that she will correspond with their group to get more ideas offline. She asked
about the extent of the discussions at the state level with the need for stronger air quality
standards to get to those improvements that are needed. Mr. Zerbo replied that Philadelphia has
its own air management services.
Ms. Colon de Mejias commended the passion and vision of their program. She delineated the
fact that all things are connected which she feels is the crux of environmental work. She liked the
idea of long-term maintenance of projects and the idea of demystifying the fact that people in
communities should have options and choices on impacts, and those projects should lead to
additional opportunities for those at-risk environmental justice communities. She asked if there
was a workforce component involved in those areas. Were they local workers, got paid decent
rates, and was it a diverse workforce? She added that involving the community made a bigger
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impactful result with their programs instead of the government running it. Dr. Rosan clarified
that they are really still in the thinking and tool development stage in making these ideas come to
fruition and how to help people see the benefits of these investments and how they can help the
neighborhood in various ways.
Chair Orduno asked how they are promoting green spaces while also having other competing
interests, such as developers who want to build something on any available land. She stated that,
in Detroit, there were many home foreclosures and now they are vacant or demolished with a
lack of funding for people to repair their houses, so now they have lots of green space and
developers on overdrive who want to build everywhere. She asked how they can just keep the
green space and stop developers from overbuilding while at the same time there's a need for
more low income affordable housing. Dr. Rosan stated that the pace of gentrification in
Philadelphia is staggering, so they need to have longer-term conversations about green
gentrification and how to protect those neighborhoods and keep the green spaces and have
affordable housing. Mr. Zerbo stated that he recently wrote an article about that subject.
Mr. Kricun suggested that adding a higher stormwater fee may discourage developers. Adding
green infrastructure and not impervious surfaces helps the community. Have you met with
PowerCorps? Dr. Rosan stated that her group just had a meeting with PowerCorps about this
issue. Mr. Shabazz appreciated the panelists and closed the discussion.
Chair Orduno thanked the panel again and moved to the Public Comment period.
1.6 Public Comment Period
On June 22, 2022, the NEJAC held a public comment period to allow members of the public to
discuss environmental justice concerns in their communities. A total of 13 individuals submitted
verbal public comments to the NEJAC and an additional 31 individuals had signed up to speak
but were not in attendance. Each speaker was allotted three minutes.
DFO Jenkins stated that the presentation slides and other material will be posted on the public
docket. He reminded everyone of the procedures for the Public Comment Period. Vice-Chair
Tilchin reminded members that, in the interest of time, no more than two comments are allowed
per public speaker. If needed, the members can contact the speaker after the meeting.
Nathan Park - Earthjustice, Washington, D.C.
Nathan Park: Good evening, everyone. My name is Nathan Park. I'm speaking on behalf of
Earthjustice, a public interest environmental law organization working to protect people's health
and the environment through the strength of our partnerships and the law. I appreciate the
opportunity today to speak with you.
I'll be focusing my comments on the Justice40 Initiative. Earthjustice continues to work with our
partners on ensuring that the historic IIJA funding levels for lead service line replacements are
distributed equitably in line with the administration's Justice40 Initiative. And to ensure this
happens and for the Biden administration to hold true on Justice40, EPA should do the
following. First, ensure that funded programs will fully pay for lead service line replacements
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without charging individual property owners. Second, EPA should clarify that drinking water
state revolving fund dollars cannot be used to fund any partial lead service line replacements,
which we know causes an increase of lead in drinking water. And finally, EPA should see
through a strong science-based and health-protective Lead and Copper Rule provision.
In December 2021, the Biden EPA allowed the Trump Lead and Copper Rule revisions to go
into effect, which significantly weakens the rule by setting up weak voluntary testing programs
at schools and childcare centers narrowing the definition of lead service lines and permitting over
90 percent of all water systems to avoid lead service line replacement. A new LCR must require
all lead service lines to be removed in ten years and strengthening the LCR will allow the Biden
administration and state and local water agencies to identify and ensure service line replacement.
I'm additionally glad to see the administration's update last week announcing that HUD has made
available $500 million for states and local governments to address lead-based paint hazards.
Earthjustice supports the administration's commitment to targeting these dollars towards
disadvantaged communities in line with Justice40. However, under HUD's Section 8 public
housing protocols, there's no requirement for tenant-based, Section 8 housing units to be
inspected for lead hazards at any time, not even upon turnover.
Additionally, although there are disclosure requirements, they are not effective and inspection
requirements will ensure that tenants have needed information about lead in housing. This means
that in public housing built before 1978, when lead paint was banned, many lead hazards are
going unidentified. And with no hazards being identified, these units will not receive any of the
$500 million that HUD has made available to remediate actively leaving people and children in
public housing at risk if they are not already suffering from lead poisoning. And we know folks
that live in Section 8 housing are disproportionately affected by a wide range of environmental
and health hazards, so ensuring these federal dollars reach them should be central to the
administration's Justice40 work.
So, EPA should join HUD in its repeated calls to Congress for a mandate to inspect Section 8
public housing for lead hazards. And I see that I'm out of time, so I'll stop there and can follow
up with the rest of my comments online.
Dr. Tejada invited other members to ask questions and/or make comments to Mr. Park. Chair
Orduno stated that the Water Infrastructure Workgroup is very much interested in these issues
and is working to promote remediation. She asked where the partial replacement lines are taking
place. Mr. Park replied that he can connect her to the folks in Earthjustice who are focusing on
lead service line replacement.
Adriane Busby - Friends of the Earth (Washington, D.C.)
Adriane Busby: Good afternoon and thank you all for your hard work and this opportunity to
speak with you today. I am Adriane Busby, the senior Food and Climate Policy analyst with
Friends of the Earth. Today, I'd like to recommend meaningful investment in research and
monitoring in communities located near concentrated animal feeding operations, also known as
CAFOs or factory farms.
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Each year today's industrial-scale farms generate as much as one billion tons of manure. Up to 20
times more waste than humans, but at least human waste is treated. This waste, which is not
treated, can contain pathogens and antibiotic-resistant bacteria, and groundwater can be
contaminated by CAFOs through runoff from land applications, leaching from manure that has
been improperly spread on land and through leaks or breaks in storage and containment units.
Factory farm pollution can contribute not only to respiratory ailments in nearby residents but also
decrease quality of life, mental stress, and serious health effects. These communities, which are
disproportionately communities of color or low-wealth communities, often have compounded
exposure to risk due to historic but lingering contamination while also being targeted for new
industrial development. These same communities often see little in pollution reduction
investment despite EPA's full-on knowledge of the dangers they face.
Friends of the Earth ask that NEJAC recommends that EPA fund direct long-term water and air
quality monitoring for communities located near CAFOs, including sample collection, access to
laboratories, lab costs, and experts for data analysis, so that the burden to collect this information
is not put on the communities that are already overburdened with life's existing demands.
Next, we think that EPA should support timely notice to communities when CAFOs are planned
for their communities and have a meaningful opportunity to object as well as education on the
pollutants these operations release and potential risk associated with public health. We also
recommend supporting research for sustainable alternatives to waste lagoons that are not
vulnerable to breaches and that protect local communities and resources from contamination. We
think that EPA needs to create an engagement plan to deeply solicit EJ community input to guide
the development and implementation of additional policy solutions to factory farm pollution,
including but not limited to hosting a series of region EJ listening sessions, prioritizing Regions
3, 4, 7, and 9 on environmental and public health impacts of CAFOs culminating in a national
listening session on the issue. In the interest of time, I will stop there, but I thank you all for your
time and consideration. Thank you very much.
Vice-Chair Tilchin thanked her for her testimony. He stated that he is glad that she included
potential solutions. He invited other members to ask questions and/or make comments directed
toward Ms. Busby. Dr. Jill Harrison asked if Ms. Busby could be more specific on the types of
air quality monitoring data that would be useful to her and her community partners. Ms. Busby
replied that Friends of the Earth is not specifically an EJ organization, but they do work with EJ
frontline communities to get an idea of what they feel is the best policy solution and ways to
support them going forward. What she has heard, depending on the time of day or when
operations are running, is that they release these emissions, such as ammonia. It really does
require constant monitoring, long-term monitoring because certain levels during the day do
fluctuate over time.
So, when we're talking about air monitoring, we're wanting to make sure that we're getting
consistent information from several points that are around these facilities, most likely within a
three-mile radius, because these are the locations that are most impacted in terms of continuous
emissions and sustained exposure. So, what she's hearing from some of the community members
is that, while impacted communities and front-line organizations really do have the drive to
dedicate to monitoring and collecting this information, over time, they simply just don't have the
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capacity to both live their lives and combat a lot of the challenges that they are already dealing
with on a daily basis. Then they have to continue to gather the sort of data that EPA says is
needed to either complete emission estimating methodologies or to get a real sense of the harm
that these communities are exposed to.
And so, what she would recommend and what she's been recommending to EPA's Office of
Environmental Justice and others is to talk to the communities themselves. She's been setting up
meetings with whoever at EPA would like to talk to frontline communities. She's done this with
the Office of Environmental Justice. They've had a meeting with a senior advisor, Robin Morris
Collin, on this issue as well. And so, she really believes that it's not up to her or Friends of the
Earth or other organizations that do not necessarily specialize in environmental justice to say
what these organizations or what these communities need. And so, she would put forth that
NEJAC continues to make meaningful connections and take opportunities to connect frontline
organizations so that they can tell you exactly their experiences as well as what they need on a
regular basis. Thank you.
Dr. Victor Perez - University of Delaware
Dr. Victor Perez: I wanted to thank everyone at NEJAC for giving me the opportunity to talk
today. My name is Dr. Victor Perez. I'm an associate professor of sociology at the University of
Delaware and an environmental justice researcher, and I'm speaking on behalf of the residents of
a community called Southbridge in South Wilmington, Delaware; the Southbridge Civic
Association; and I'm also speaking as the interim chair of the Southbridge Neighborhood Action
Plan's Environmental Committee.
The core of Southbridge is a small community of about 1,400 people, working class, with a
significant number of folks who fall below the poverty threshold. A little bit over 80 percent are
African American, and they've been involved in community-based efforts in trying to address a
variety of environmental justice issues for a long time that has always been sort of intertwined
with development in the area. So, this evening, I'm going to be providing some feedback that I
got from some community members at a recent civic association meeting regarding
environmental justice issues that are important to them, including flooding.
To quote one of the community members, "Everyone has a flooding story," and the flooding has
to do with a lack of adequate maintenance of the infrastructure but also because of just a long-
standing sort of problem with the ability to handle the water that happens in South Wilmington
due to the Christina River and the Delaware Bay itself. The brownfields in the community, there
are over 36 of them. Mosquitos and standing water in the community are problematic.
It is understood as an asthma cluster as well as a cancer cluster by community members. It is a
food desert. Recently, a South Wilmington wetland park, which is being developed by the City
of Wilmington, will only address about half of the flooding that the community currently deals
with. There has to be help for environmental justice problems before new negative
environmental justice issues come about caused by a development called Riverfront East, which
is in a lot of ways really providing the potential for green and resilient gentrification with a lack
of affordable housing. The community wishes to own its future and not be displaced.
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Folks also talked about basic needs like laundromats; as well as a mulch company and playing
children by the mulch company which has health and physical safety concerns; as well as a lack
of a variety of encapsulated soils all over including construction sites that has mounds of dirt
with glass and hazardous materials; as well as brownfields, particularly near where children play
in parks. Thank you very much for the opportunity to speak today.
Vice-Chair Tilchin invited other members to ask questions and/or make comments. Mr. Kricun
asked if there is anything that can be done? Are they working with DNREC or EPA Region 3 to
try to mitigate these other EJ burdens? Dr. Perez replied that one of the primary ways to do that
is to address some of the existing brownfields in the area. There's development that's happening
and is serving to try and mitigate a lot of the environmental justice issues in the area, but it's
development driven. So, when those mitigation mechanisms are put into place, they're generally
done in line with what it means for the future of development in the area. So, cleaning up our
brownfields, for example, to the west of the community of Southbridge in Riverfront East means
cleaning up a brownfield and then developing it for people who do not live in that community.
So, I would suggest that there need to be mechanisms that can help address the environmental
issues that are in addition to or alternative to development-driven, mitigation efforts, so cleaning
up brownfields for the sake of cleaning up brownfields or fixing flooding issues for the sake of
fixing the flooding issues. So, for EPA, I think, there are a variety of issues that could be
addressed including air pollution, soil pollution, groundwater, and contaminated groundwater.
The problem is that the solutions are a long time coming and generally speaking and I'm
speaking partly based on my observations as a community advocate for about ten years but also
based on antidotes and research from community members. The changes tend to happen when
the development happens, so the EPA can be very beneficial in providing alternative
opportunities to clean up the area that don't involve necessarily the potential for displacement.
Mr. Kricun suggested that NEJAC reach out to Dr. Perez and try to connect him with EPA
Region 3, and they can look at how Wilmington is being treated.
John Mueller - Private citizen (Tulsa, Oklahoma)
John Mueller: Good afternoon. Greetings ahead from Tulsa, Oklahoma. I am John Mueller, a
retired engineer, mainly in water resources engineering with a degree in geophysical engineering
from the Colorado School of Mines. I am again presenting concerns about water fluoridation, but
before going any further, I want to acknowledge and thank the NEJAC members for responding
to these concerns presented during previous NEJAC public meetings by myself and others. Also
thank you, Matt Tejada, for answering my questions in your NEJAC community engagement
calls.
My comment today is largely spontaneous in response to Mr. Schafer's presentation on the PFAS
and PFOA contamination chemicals. We all know, or we should know, that the F in those
organic chemicals is the fluoride atoms covalently bonded to the carbon atoms in those
compounds. What makes them the "forever chemicals" that they are is the strong bond which
Wikipedia tells us is one of the strongest single bonds in chemistry and is "the strong inorganic
chemistry". One reason is that fluorine has the strongest electro negativity and attractive force of
any element in the periodic table of the elements. It's the same fluorine atom that helps give
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prescription drugs like Prozac and Lipitor their efficacies. In its ionic form, it is deliberately
added to public water supplies and is increasingly recognized by emerging scientific studies as
being harmful to human health, affecting some of the same organs in our bodies as the PFAS and
the PFOA compounds not only in environmental justice communities but harm to the developing
brains of the unborn fetus in pregnant mothers of infants from formula reconstituted with
fluoridated water and young children swallowing fluoridated toothpaste.
Fluoride is a developmental neurotoxicant, like lead, and it's added as a medical treatment to help
prevent tooth decay with no control of human exposure other than what is added to the tap water
miles upstream. It is unethical with no informed consent from those who have no choice but to
drink that water. Tooth decay can be prevented with better diet and oral hygiene. Early brain
damage is, as we have heard, a horse of a different color. Accordingly, a specific NEJAC
recommendation should be banning the deliberate addition of any fluoride chemical compound
to public water supplies.
I will be submitting additional materials prepared by experts, including highly respected dentists.
Thank you again for these unprecedented opportunities to contribute to improving public health
in this still greatest of nations. Thank you again.
Vice-Chair Tilchin invited other members to ask questions and/or make comments. Chair
Orduno thanked him for testifying again and helping her understand this issue. As she grew up,
she was told to have all the fluoride they could get. She stated that people need to pay attention
to this issue. She would like to follow up with him regarding the science around fluoride. Mr.
Shabazz thanked him for keeping the issue on the radar.
Odette Wilkens - Wired Broadband, Inc. - (New York)
Odette Wilkens: Hello, everyone. I'm Odette Wilkens, president and general counsel of Wired
Broadband, a non-profit whose mission is to educate the public about the need for fiberoptics
deployment for broadband.
Radio frequency radiation, or RF radiation, from wireless infrastructure is a pollutant. That
includes cell towers, base stations, 4G, 5G, rooftop antennas, and so-called smart meters. It's
even documented by the telecom industry in their consumer product protection plans. For
example, a brochure states that a "pollutant" means any contaminant including artificially
produced electromagnetic fields, sound waves, microwaves, and all artificially produced non-
ionizing radiation." That is radio frequency radiation, and it is also called electro-smog.
The telecom industry uses that definition to disclaim liability for personal injury claims. Major
insurance companies will not cover personal injury from RF radiation. In fact, the EPA had
recognized RF radiation as an environmental hazard back in the 1990s. As soon as it did, the
EPA was defunded in that area, and its jurisdiction over that area was taken away. My question
is when will the EPA reclaim jurisdiction over this area?
Those who have born with the burdens of electro-smog are those who are electromagnetically
sensitive and EMS disabled. They have been the unrelenting subject of discrimination including
digital discrimination and algorithmic bias to belittle and deny the debilitating physical injuries
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of RF radiation exposure. The condition can include headaches, balance disorder, heart
palpitations, tremors, tinnitus, hair loss, depression, skin problems including lesions, nausea,
vomiting, and reproductive problems.
Their debilitation from such exposure has led to an inability to participate in normal activities or
even work. Many of the EMS disabled were unaware of the dangers or gave them no credence
until they became injured. In a survey, it was found that many lost their jobs as a result,
including engineers, doctors, lawyers, and children. Children living close to a cell tower were
vomiting in their beds. That community had a cell tower placed at the end of their block.
Seventeen people got sick, and many who could afford to live elsewhere evacuated their homes,
and it's still continuing in Pittsfield, Massachusetts.
RF radiation is invisible. It cannot be perceived with the naked eye or by smell, much like gas
leaking from a stove. And therefore, it goes unnoticed until one develops symptoms or is injured
by it. the EMS disabled have been unsuspecting victims of their injuries that have now become
their disabilities. There is talk of reducing fuel combustion and greenhouse gases or
decarbonization of our air and economy, but decarbonization cannot occur without the
decarbonization of electro-smog. Any perceived benefits from reduced fuel combustion are
likely to be offset by greenhouse gases from wireless infrastructure. Presenting these comments
is an effort to make visible what has otherwise been invisible until now, the EMS disabled. It's
important for the EPA to reclaim jurisdiction in evaluating the safety of RF radiation. Thank you.
Vice-Chair Tilchin invited other members to ask questions and/or make comments. Chair
Orduno stated that she is glad Ms. Wilkens came back to speak. She asked if wireless monitors
and meters have an impact on RF radiation. Ms. Wilkens responded that yes, absolutely. There
is definitely the same consideration for smart meters. She personally knows people who have
been very badly injured and permanently so neurologically because of where these smart meters
are placed. Sometimes they're placed right on the other side of your bedroom or on the other side
of your bed, and you don't even realize it until you are already damaged neurologically. People
then have to evacuate and go to a place that has no electromagnetic radiation whatsoever, not wi-
fi or anything.
Once you become severely injured, it's pretty much permanent. It's the same thing with cell
phones, cell towers, all of that. It's using the same form of RF radiation, and many people have
already been injured. There's a case right now in New York, and there's been a case in
Pennsylvania, especially regarding smart meters. People are not being given the opportunity to
opt out of smart meters without having to pay excessive fees and sometimes they're not given an
opportunity to opt out at all. They would just prefer to keep their analog meters. Chair Orduno
asked for a reference article to help the Council better understand how those health impacts are
determined. Ms. Wilkens said she lives in New York, and she's receiving statements from
people in New York who have been injured and continue to be injured by smart meters. There is
a court paper relating to the Pennsylvania case that has a tremendous number of references
including engineering and engineering reports and reports from scientists, which she can include
in her written submissions, and that will give them a lot of information. Chair Orduno stated
that those would be very helpful.
Mayra Reiter - Farmworker Justice (Washington, D.C.)
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Mayra Reiter: Good afternoon. My name is Mayra Reiter. I'm project director for Occupational
Safety and Health with Farmworker Justice. I would like to thank NEJAC for the opportunity to
speak today on Agency investments as they relate to environmental justice.
Agricultural workers comprise one of the most disadvantaged communities in the U.S. Studies
have shown that up to 80 percent of farmworker households experience food insecurity. The
average income of a farmworker family is in the range of $25 to $30,000, and at least 20 percent
of farmworker families find themselves below the federal poverty level.
2.4 million farm workers in the U.S. face significant health risks due to pesticide exposure which
can result in both acute and chronic health effects that may include neurological damage, birth
defects, learning disabilities, and other conditions.
Pesticide use is predicted to increase as climate change intensifies and agricultural pests expand
their range and their numbers. For there are a number of investments EPA can make to help
achieve greater environmental justice for the agricultural workers who produce the nation's food.
The first of them is to dedicate resources to prioritizing the registration review of
organophosphate pesticides, followed by the immediate cancelation of all uses that pose a
concern. EPA was supposed to complete the registration reviews of these highly toxic pesticides
via the statutory deadline of October 1st, 2022. But EPA has indicated that only 3 of the 15
organophosphate reviews will be completed by the deadline. And that research constraints are
directly responsible for this delay. This means that farmworkers have to wait years for EPA to
take action to fully address the risks posed by these pesticides unless they dedicate more
resources to complete the registration periods.
EPA must also put resources toward developing a systematic review framework by which it can
incorporate more scientifically sound, epidemiological, and long-term data to include pesticide
human health risk assessments to ensure that these assessments are informed by real-world data.
This framework should be peer reviewed by the National Academy of Sciences before its
adoption.
In addition, more resources are needed to improve pesticide illness surveillance. Currently, the
sensor pesticides program administered by NIOSH in partnership with EPA collects pesticide
poisoning data but covers only ten states. This program needs to be expanded to more states
prioritizing those with the greatest numbers of reports from workers. Without additional
investments, it will be hard to access the full extent of the field poisonings caused by agricultural
pesticides. This information is important for EPA to be able to properly perform its regulatory
function.
Finally, reducing pesticide exposures among farmworkers is an environmental justice goal for
EPA. Farmworker Justice asks EPA to direct more resources toward addressing pesticide
exposures among these essential workers. Thank you.
Vice-Chair Tilchin thanked Ms. Reiter for the testimony of what farmworkers are facing, not
just poverty and food insecurity, but with the poisons they touch every day. She described the
problem and gave clear and succinct recommendations. It has been an issue for a very long time.
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He invited other members to ask questions and/or make comments directed toward Ms. Reiter.
Jan Fritz asked what EPA's response was to the delay. Ms. Reiter responded that at the
moment, we have not had a satisfactory response, but EPA has agreed to meet with some of the
farmworker advocacy groups to discuss the stage of the organophosphate pesticide reviews.
Mr. Kricun stated that he was disappointed that only 3 of the 15 reports will be finished by the
October deadline. He wondered if NEJAC can write to EPA through the OEJ to try to encourage
an acceleration of that. He also wondered if there was any mitigative type of measures that could
be taken in the meantime to reduce the impact on farmworkers. Are there some things that could
be at least somewhat partially mitigative to reduce the vulnerability that they currently have in
parallel with the long-term full solution? Ms. Reiter answered that anything the NEJAC can do
before EPA would be welcomed by the farmworker groups. To answer the second part of the
question, there are things EPA can do. EPA doesn't need to wait until all of the reviews are
completed to take interim mitigation measures. They have already identified some risks and
concerns for these pesticides with respect to farmworkers. EPA has the authority to take action to
ban those uses that they know pose risks of concern that cannot be otherwise mitigated, but so
far, the Agency has not done so.
Mr. Kricun asked if she can let NEJAC know what those interim mitigative measures are so
they can include them in the request to the EPA to try to accelerate action in order to protect
vulnerable farmworkers. Ms. Reiter answered that yes, they will be happy to share that
information with the committee. Dr. Harrison stated that NEJAC has a Farmworkers and
Pesticides workgroup, and members of that workgroup are members of the farm working
community. Those members are working with those communities to establish priorities for
building a set of recommendations to be sent to the EPA. Any additional written comments will
help inform those recommendations. She stated that organophosphates are absolutely their major
concern.
Rashmi Joglekar - Earthjustice (Washington, D.C.)
Rashmi Joglekar: Hi, everyone. My name is Dr. Rashmi Joglekar. I am a staff scientist at
Earthjustice and would like to thank you for providing the opportunity to speak today. I will also
be focusing my comments on the upcoming registration reviews for organophosphate pesticides
very closely aligned with the excellent comments that Mayra just delivered.
EPA is delaying the statutorily mandated review of the dangerous class of pesticides called
organophosphate pesticides, or OPs, which is putting farmworkers, children, and families living
near fields where OPs are used at serious risk and posing environmental justice concerns. EPA is
statutorily required to complete the registration review for 18 OPs by October 1st of this year, as
Mayra mentioned, to ensure that they are safe for use. However, EPA is illegally delaying this
process to obtain unnecessary new scientific information from non-animal tests that EPA's own
scientific experts have warned against using to evaluate the safety of OPs.
EPA's already aware of the decades of scientific research that shows that OPs are dangerous to
human health. OPs are acutely neurotoxic meaning that people who are exposed over a short
period of time can experience poisoning symptoms, like headaches, dizziness, vomiting,
convulsions, and even respiratory failure. OPs are also linked to neurodevelopmental harm in
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children. Dozens of published scientific studies over more than two decades have shown that
exposure to extremely low levels of OPs during life can lead to irreversible harm to the
developing brain, which can result in long-term effects like attention disorders, autism, and
reduced IQ.
EPA's own draft risk assessments show that people face unacceptable risks from OPs including
children and farmworkers which again raises serious environmental justice concerns. EPA's own
risk assessments found that nearly all OPs pose risk to the general population from exposure to
the diet, which includes food and drinking water. Infants and toddlers experience dangerous
levels of dietary exposure from most OPs, and, for some, dietary exposures in children are over a
hundred times higher than EPA's levels of concern.
Farmworkers who directly handle the pesticides face severe risks meaning that at least one-use
scenario exceeds EPA's risk levels of concern by at least an order of magnitude. In some cases,
that's even after factoring in maximum protective clothing or equipment and engineering
controls. They also pose risk to bystanders or people who live near fields where pesticides are
used and sprayed. Nationwide, OP use data indicates that many of the communities and areas
with the highest aggregate OP usage are low-income communities of color.
Under EPA's proposed delay, the Agency will only meet the deadline for three of these
dangerous pesticides, as Mayra has highlighted, and each year of delay puts children at risk of
life-long developmental harm and puts farmworkers at risk of life-threatening OP exposures to
the other 15. In addition to the recommendations that Mayra outlined, I'd like to specifically ask
this Council today to issue a statement urging EPA to no longer delay the registration review of
this dangerous class of pesticides and to cancel registration for uses of OPs that cause
unreasonable harm to communities, farmworkers, and children. Thank you.
Vice-Chair Tilchin asked if she could clarify when she said, there are established levels of
concern for either all of the 18 pesticides or some of them. Can she shed some light on what he
called the regulatory status of what it means to have a level of concern? Dr. Joglekar explained
that the risk levels of concern that she is referring to are levels that were established in the risk
assessment process that EPA has conducted for 17 OPs. In the risk assessment process, they have
scientifically determined the levels below which there are supposedly no risks to human health
and above which there are acceptable risks to human health. So, in these risk evaluations, they
essentially gauge how much OP exposure is occurring in people, and they compare that to the
level of exposure that's associated with health harm. If they're above the risk level of concern,
that means that people are exposed to OPs at levels that will pose risk to their health. What they
found in these risk assessments is that for many of the uses of OPs for farmworkers, the
exposures that they were experiencing were at least ten to a hundred times higher than that risk
level of concern, which is the level at which you start to experience adverse health effects. So
these are extremely dangerous levels of exposure that farmworkers are experiencing, and they
have gone largely ignored by the Agency. These are literally their own findings from their own
staff scientists, so it's very problematic.
Vice-Chair Tilchin invited other members to ask questions and/or make comments to Dr.
Joglekar. Dr. Harrison asked Dr. Joglekar, in her written feedback, to include as much of that
detail as possible, including the detail about EPA's own scientists' statements about what they
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feel is sufficient and necessary for moving forward. Dr. Joglekar stated that she will submit
them.
Kurd Ali announced that was the last of the public speakers. Chair Orduno suggested, since
there was extra time, that they can hear from unregistered speakers. Mr. Ali answered yes.
Jane Williams - California Communities Against Toxics (California)
Jane Williams: Good afternoon, NEJAC members. Thank you so much for the opportunity to
speak with you today. I have registered to talk. I am the executive director of California
Communities Against Toxics. I want to talk to you today about municipal solid waste
combustion.
EPA had a duty to promulgate rules on municipal solid waste combustion units, also known as
garbage incinerators, in the early '90s. It was one of the first rules that the Agency issued under
the Clean Air Act Amendments of 1990. The communities surrounding these incinerators, of
which there are 57 facilities with 157 incinerators across the United States, have never actually
been afforded the protection of the act because the rule was challenged in the federal court and
then remanded by U.S. EPA. The rule is now 16 years overdue, and we are trying to get EPA to
issue this rule as rapidly as possible to grant protections to the communities that host these
municipal waste combustion units.
Many of these facilities, as I'm sure you must be aware, are in environmental justice
communities. They're in highly industrialized areas of the United States, and many are very old;
most of them are over 30 years old. So, I can really use all of the help that I can get from NEJAC
and its members to encourage U.S. EPA to as quickly as possible promulgate new, more
protective standards.
Many of these incinerators are actually concentrated in just a few states. Over half of the
inventory are in six states that are Massachusetts, Connecticut, New York, New Jersey,
Pennsylvania, and Florida. It can't be that difficult of a problem when there's over half the
inventory in just six states.
Since we promulgated the rules, we have learned so much more about the impacts of particular
emissions, especially during this pandemic. We see the correlation between high levels of
particulate matter and the COVID epidemiology on the ground. I can't emphasize enough how
important it would be for EPA to take this time and hurry up and promulgate new standards that
would not only reduce air toxics emissions in highly impacted communities but also particulate
matter. So, thank you so much for listening to me today, and I hope that NEJAC can help us do
something on this.
Vice-Chair Dr. Jelks asked Ms. Williams to clarify the timeframe for when the most recent
rules have been promulgated around these municipal waste combustion units. Ms. Williams
stated that the rules were promulgated in 2006, but the court ruled that they were not protective
enough. So, the Agency took a remand, and it's just been sitting on them since that time. To
actually answer the question, it has never been the case that the communities that host garbage
burners have been protected by a rule that meets the Clean Air Act protective standards.
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Vice-Chair Dr. Jelks invited other members to ask questions and/or make comments. Ms.
Owen stated that Massachusetts is home to the oldest incinerator in the country, and six of the
seven incinerators in her state are in or border on EJ populations, so she's very familiar with the
issues that were testified. She asked that Ms. Williams submit her written comments so the
Council can have further discussion and move the issue forward. Ms. Colon de Mejias
commended Ms. Williams for bringing this issue forward because it is often overlooked. She
encouraged Ms. Williams to submit her written comments because she lives in Connecticut and
knows the concerns firsthand. It will be forwarded to the Air Quality workgroup.
Mr. Clow asked if these facilities are large enough to require a Title V permit or a minor source
permit as far as the tonnage of emissions and the tonnage of toxic emissions that are on the
NESHAP list of hazardous air pollutants? Ms. Williams responded, yes, actually Section 129 is
a little bit different than Section 112 of the act, so all Section 129 facilities are required to get a
Title V permit. The statistics I gave you are for the large municipal waste combustors. There's
also a small municipal waste combustor, and then there's other solid waste incinerators that have
municipal waste combustion units in them. The statistics I gave you are just for the large sources
that are required to get Title V permits.
Mr. Kricun agreed with trying to impact the impact on EJ communities. He stated that he
worked for many years in Camden where there's a trash incinerator for the whole county, which
meets New Jersey's air permit emission requirements, but those requirements are just
significantly less than the best available technology. The community has been asking the state
for years to acquire this incinerator operator to put in a bag house to reduce particulates. But
because they're not required to, they won't do it. So, if incinerators can't be eliminated altogether,
they at least need to be required to do the best available technology, especially if they're within
the range of a residential community. He stated thatNEJAC should definitely support discussion
with the Office of Air with regard to better regulation or even elimination of incinerators. Vice-
Chair Dr. Jelks encouraged Ms. Williams to submit her written comments so that NEJAC can
appropriately follow up within EPA and with the relevant workgroup. Ms. Williams stated that
she will be happy to do that.
Mr. Ali reminded all speakers to speak slowly for the interpreters and the closed captioning.
Shaina Oliver - Private citizen (Colorado)
Shaina Oliver: I did register to comment, but I didn't hear my name called. I am a state
coordinator with Moms Clean Air Force, Colorado chapter as well as working with EcoMadres
engaging with communities organizing within the Latino community here in Colorado, focusing
on environmental justice, bringing justice to all communities for all children to have access to
clean air as well as to have a safe environment to live in. Moms Clean Air Force is a national
organization of one million moms and dads united in fighting for our children's right to breathe
clean air and have a safe environment to live in. Most importantly, I'm an indigenous mother of
four, and we're tribal affiliates of the Navajo Nation. We are the descendants of the survivors of
the genocide known as the Indian Removal Act, known to the Dine' as the Long Walk of the
Navajo.
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So, historic environmental racism has always been a historic mark on our first nation's tribes and
communities, and it still continues that genocide today by these environmental laws and policies
and regulations that have formed our communities and have formed our environmental injustice
communities, such as here in Commerce City, Colorado where we have the Suncor refinery who
are continuing to operate and harm community members where children are dying before their
parents that have grown up in this community. This community cannot use their water for
drinking or cooking, but they still bathe in this water.
The state public health and environment have tested the water for PFAS levels, and it's above the
limits. I don't think there's any safe limits of PFAS in our water, which, in the state of Colorado,
we just passed our House Bill 22-1345 pertaining to concerning measures to increase protection
from PFAS chemicals. I would like to see the EPA take on these stronger initiatives to tackle
PFAS nationally for all communities so that our children are not being victims to PFAS
chemicals as well as the oil and gas that releases these PFAS wastes into our waterways through
the Sand Creek River as well as the South Platte River. There is a community that uses dam
water from these waterways for their community's drinking water.
There's just no safe limits of PFAS, and we shouldn't have lower limits. High limits of PFAS
should not be even considered as safe limits. There is no safe limits of PFAS in our blood or in
our house. We need to go by science-based research and as well as climate research by scientists
to understand that we can no longer live with these contaminants in our air or our water. These
facilities like the Suncor Refinery continue to violate our right to public health and the
environment to be sustainable in a way that's safe for our children. These communities are
impacted directly by Suncore and surrounding industries that contaminate our air and our water
and our lands and continue the genocide through these environmental harms created through
these loopholes we call policies, regulations, and laws that stem from the Indian Removal Act.
That's why we need to address the past, present, and future in this way that we address the racism
underlined in these industries as well as our structured government. So, thank you for letting me
speak.
Vice-Chair Dr. Jelks stated that there's a lot that Ms. Oliver shared that will be discussed the
next day. She invited other members to ask questions and/or make comments to Ms. Oliver. Mr.
Clow stated that Ms. Oliver reached out to the staff at the Ute Mountain Ute Tribe also. He
appreciated that she has reached out to the national level. Ms. Oliver stated that she forgot to
mention that her community has been utilizing Boulder Air, which has been conducting the
community's air research in the Commerce City area, particularly around the Suncor refinery, so
they are online under Boulder Air.
Michelle Rutledge - Private citizen (Florida)
Michelle Rutledge: Good afternoon, everyone. Thank you so much for this opportunity, and I
did register as well, but I'm not sure if my call dropping may have impacted that. I am a
community member, and I would like to bring consideration towards rural, agricultural, and
residential communities. My home is in north central Florida. My neighborhood is a historically
African American neighborhood intact since the end of slavery. We have a very rich cultural
history. For example, we have survivors of the Rosewood Massacre who relocated after that
event in our area.
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I wanted to, if possible, ask if there have been considerations in environmental justice in
obtaining equity of siting land use and zoning. The panelist made a wonderful comment, I felt, as
a community member about considerations of how cumulative impacts, such as what's nearby,
like, are there good schools, and is there access to healthy foods? That resonated with me
because I do feel that planning may be a way to begin addressing and attempting to achieve
equity.
My community has been advocating for environmental justice and energy justice, but also as far
as what developments are potentially proposed, how communities are engaged if communities
are given an opportunity to be listened to. Being in a rural community, well water is something
that many of my neighbors and I and our families use.
So, I just want to thank you for this opportunity to just kind of share some of the experiences of
community members. Also, I'm not sure if this is the right forum, but if we're talking about J40
and funding, if there can be considerations on how that money can get directly to community
groups who are on the ground, grassroots organizations trying to better their community, that
would be awesome as well as that could be considered. So, thank you so much for your time.
Vice-Chair Jelks stated that zoning is a real challenge. Place matters and the challenge is that it
is very contextual and local and subject to local policies and politics. Some places have no
policies around zoning, especially restricting certain types of land uses in close proximity to
where people live and recreate. She stated that it's important to remember that zoning is not just
an issue in urban areas. She invited other members to ask questions and/or make comments to
Ms. Rutledge. Dr. Whitehead stated that she worked for many years as a land use planner in
Florida and worked directly with communities in the Gainesville area and in other parts of
Florida working with the health department. She asked what county Ms. Rutledge lives in. Ms.
Rutledge replied that she lives in Alachua County. Dr. Whitehead said she will get her some
connections with advocacy groups and the environmental planner for Alachua County. Ms.
Rutledge added that, as the panelist mentioned, are there parks and green spaces? That just
resonated with her because, in rural areas, there's no sidewalks there, but we still have the need to
protect these significant cultural areas from overplanning. The need to add places where children
can play, and adults can even exercise safely.
Mr. Kricun stated that it's important to be aware of zoning and to protect against cumulative
impact because, in some cases, federal and state regulatory actions don't sufficiently protect
those because the regulations aren't able to be as protective as we like. One of the things that
occurs to him is that perhaps it might be helpful for the EPA and the NEJAC to work together on
some sort of template ordinance to ensure that certain communities aren't overburdened or
underserved.
Akisha Eaton - CARE
Akisha Eaton: Thank you so much and thank you to NEJAC for welcoming me into this forum.
This is my first meeting, but I do anticipate coming to other public meetings. I did attempt to
register, but I was under the impression that I might not be able to speak. I realize that we're kind
of getting close to time, so I will keep my remarks very brief and follow up with further written
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comments.
I work as the chief of policy in the Environmental Justice Division of CARE, which stands for
Companions and Animals for Reform and Equity. We are a human and human well-being
organization, and, to my knowledge, we're the first animal welfare-related non-profit with a
division specifically dedicated toward environmental justice issues.
I just wanted to highlight and emphasize the importance of the human/animal relationship in the
environmental justice context. I personally live in a disaster-impacted area. Following Hurricane
Katrina, there were so many stories of people who did not evacuate because they had companion
animals at home, and they didn't take advantage of those critical services that they would have
needed to preserve their own lives and well-being. So, I just wanted to emphasize the importance
of that relationship and interweaving that wherever it can be interweaved in terms of
programming and applications for funding.
Just this past weekend, we happened to distribute free pools for companion animals of folks in
the community who had been impacted by the heat wave. There are currently no cooling centers
for folks to go to and certainly really many places that people can go to with their companion
animals. The result of that is that a lot of people might just stay home and face heat stroke and
other health-related impacts because that relationship hasn't been considered.
So those are just two examples. I do hope to follow up in more depth in writing, and I appreciate
the opportunity to speak today and look forward to joining the forum in the future.
Vice-Chair Dr. Jelks stated that she hadn't really thought about this issue, but certainly, folks
won't leave because of their pets. She looks forward to receiving the written comments for
follow-up.
Kate Welty - Earthjustice
Kate Welty: I am a law clerk in the Toxic Health and Exposure Program at Earthjustice. I am
here today to bring my concerns to the NEJAC about EPA's assessment of fenceline community
risks under the Toxic Substances Control Act. I wanted to begin by thanking the NEJAC for its
ongoing efforts and highlighting the harms to the fenceline communities surrounding facilities
where toxic chemicals are manufactured, used, released, or disposed of or who otherwise
experience greater exposures to harmful chemicals.
We urge the NEJAC to encourage EPA to follow this guidance and build out a more robust
framework for the evaluation of future chemicals while also taking immediate steps to improve
the fenceline assessments for chemicals that have already been evaluated. The TSCA risk
evaluation process requires EPA to comprehensively evaluate a chemical's exposures and risk
and determine whether the chemical substance presents or will present an unreasonable risk of
injury. EPA must separately consider risks to potentially exposed or susceptible subpopulations,
which are groups that due to either greater susceptibility or greater exposure may face greater
risks of harm than the general population. These communities often face severe health risks as
they are more likely to be dealing with stressors such as underlying health conditions, limited
access to health care, and psychological stress related to poverty and structural racism that can
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worsen the effects of chemical exposures.
Unfortunately, EPA's current fenceline assessment approach leads to an underestimation of
chemical exposure and a corresponding underestimation of risk. The current methodology uses a
chemical-by-chemical, facility-by-facility approach, ignoring the reality that fenceline
community residents are exposed to multiple chemicals from multiple sources, many of which
have cumulative effects.
EPA claims that it does not want to change its fenceline assessment approach to delay the
regulation of the ten chemicals that have already been assessed and found to present an
unreasonable risk. However, the choice between doing things quickly and doing things correctly
is a false dichotomy. There are steps that the EPA can take now that will allow for the swift
regulation of chemicals while also ensuring that fenceline assessments for those chemicals are
more reflective of the community's actual exposures and risks.
We are asking the NEJAC to advise EPA to, first, incorporate immediate modifications for
already assessed chemicals, including the use of existing air monitoring software to match the
chemical load, the inclusion of at least five years of chemical release data to better understand
estimated chemical exposures, the consideration of both pre-existing levels of contamination in
fenceline communities, as well as peak emissions from nearby facilities, and the inclusion of an
uncertainty factor to better represent unstudied cumulative impacts.
Secondly, we ask that you urge them to adopt broader changes to the fenceline assessment
approach that can strengthen the risk evaluation process going forward, including the addition of
cumulative risk analyses as outlined by the NEJAC in its own 2004 report addressing
communities facing multiple stressors. Thank you all so much for your time and consideration.
Vice-Chair Jelks stated that the issue of underestimation of exposures is really important.
Cumulative impacts don't necessarily just mean additive. There could be synergistic effects, such
as making exposures worsened or exacerbated when people are exposed to multiple chemicals at
the same time. She looks forward to receiving her written comments for follow-up. Chair
Orduno stated that they have received multiple testimonies from fenceline communities, and the
Council really needs to follow up on them in a prioritized way.
Marie Franklin (phonetic)
Marie Franklin: Thank you so much for getting me in. I'll make this brief. I'm a community
organizer in East St. Louis (inaudible). We are an impoverished area that needs all the help that
the EPA can give us. We have repeatedly ignored and looked over and cast aside. My question
is, who do we talk to get these services that the EPA is offering? Is it NEJAC? Is that who we
will start with? Who do we talk to get one of those technical assistance hubs here in East St.
Louis where it would be most beneficial? Unfortunately, sometimes our cities' fathers are not
aggressive enough of making sure that we get we need the assistance, so I'll just take it upon
myself to do that.
I've been a life-long resident of East St. Louis, and our city, our citizens deserve to thrive just
like the other citizens and (inaudible). How do we do that? We are working and learning. We
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have people who can work. We have people who are smart. We have everything we would need
gets if someone would just offer us the resources. Unfortunately, there are people talking about
low-income communities. They talk about leveraging the poor instead of redistributing the
wealth. We need the resources. We've got the brains. We've got the brawn.
Chair Orduno stated that they hear what she's saying, but there's terrible static noise, and the
interpreters can't understand her. She clarified that Ms. Franklin wants her city to get one of
these hubs. She hopes Ms. Franklin will listen to tomorrow's meeting to get information on the
hubs program. Ms. Orduno encouraged Ms. Franklin to submit written comments because they
need the comments to incorporate them into the work that they do. Ms. Franklin said she would.
1.7 Closing Remarks & Adjourn
DFO Jenkins thanked everyone for a very productive day. He adjourned the meeting for the
day.
2.0 Welcome, Introductions, & Day 1 Recap & Opening Remarks
DFO Jenkins welcomed everyone back for Day 2 of the meeting and made the same
announcements as the prior day. He invited the chairs and vice-chairs to introduce themselves.
Chair Orduno explained the agenda for the day. Vice-Chair Tilchin announced that the
quorum is met.
2.1 Welcome, EPA Updates, & Dialogue
Chair Orduno thanked Administrator Regan for speaking to the Council. She thanked him for
his leadership and commitment he has made to the Council and environmental justice overall.
She is excited to hear and understand more about how he is driving this EPA administration.
2.1.1 Michael Regan, Administrator - U.S. EPA
Michael Regan thanked the NEJAC for having him. He acknowledged that this will be a very
promising year for EPA. 2022 marks the 30th year since EPA first formed the Office of
Environmental Justice. He quoted the saying, "We've come a long way, but we have a long way
yet to go." He's proud to say that the NEJAC has been alongside OEJ holding EPA accountable,
lifting up the truth of the realities of communities on the ground and keeping them focused on
the horizon where equity and justice are finally achieved.
Administrator Regan stated that the NEJAC has been busy with an assortment of priority actions,
workgroups, engagements, and significant opportunities for providing him and this team with
real-time feedback. EPA is still wrapping up the actions. Their strategic plans are now in the full
throws of implementation. The infrastructure funding is starting to flow out of the Agency. The
2022 budget resources are getting ready to hit the streets. He knows the Council shares his
commitment and the commitment of his entire leadership team for all of us to accomplish their
goals. He appreciates the hard work of the entire staff.
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Administrator Regan understands that the Council will finalize the recommendations and looks
forward to receiving all of them. He believes they have such a historic opportunity to have the
resources of the Infrastructure Bill at the same time that they're prioritizing Justice40 across so
much of what they do. He acknowledged the enormous importance of the NEJAC as a federal
advisory committee. EPA relies on their advice. The advice they give EPA today is needed now
more than ever.
Administrator Regan stated that EPA's journey began when citizens demanded a clean
environment and basic public health protections. They have been incredibly successful at
delivering on those demands but not for all people and certainly not for all communities. That is
why he is committed to delivering on the Agency's original promise for the communities most
overburdened and vulnerable through our country's historic environmental injustices. That's part
of why this time is so important. He stated that the Justice40 Initiative is a clear mandate to be
laser-focused on delivering for communities who have suffered from generations of
disinvestments because of structural and systemic racism and classism.
Administrator Regan stated that they're advancing equity across everything they do to close that
disinvestment gap. They're doing the hard work of correcting from this time forward the
structural and systemic injustices that still pose such a significant challenge to communities
suffering disproportionately from levels of pollution. He said that's why he re-emphasized to his
leadership team the need to stay ambitious on delivering right now for equity, justice, and civil
rights.
Administrator Regan stated that this includes taking every opportunity to provide benefits
directly to underserved communities and revising guidance documents that lie at the heart of
their day-to-day work to ensure that EJ and civil rights compliance are included in that work.
Baking environmental justice and civil rights compliance into the rules they write from the very
first step and ensuring that all the engagement opportunities are fully accessible to persons with
limited English proficiency and disabilities.
Administrator Regan announced that he's also glad and relieved to have some help to do that.
He's glad to have Robin Collin as his senior EJ advisor, and he is relying very heavily on her to
work across the leadership team to help ensure that they're meeting the mark of their shared
ambition. They're so delighted to have Robin on board.
Administrator Regan stated that it was announced in April that the Agency had published the
Equity Action Plan. The purpose of the plan was to fulfill President Biden's executive order
directing the Agency, along with other federal agencies, to assess whether underserved
communities and their members face systemic barriers and accessing benefits and opportunities
through the federal government. He stated that this plan is a critical part of EPA's effort to break
through those barriers and advance equity and justice across their efforts to ensure clean water,
clean air, and clean land for all communities in this country.
Administrator Regan confirmed that they're clear in acknowledging the task. Some of EPA's past
actions not only have failed to alleviate the challenges faced by many communities, but they at
times exacerbated those challenges by increasing the disproportionate burdens born by so many
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of our communities. He stated that to do a better job, now and in the future, he believes that they
must recognize by lifting up this truth and confront it as they commit to doing things differently
moving forward.
Administrator Regan stated that one critical element in that Equity Action Plan, as well as in
their Agency's priority goal in the Strategic Plan, is to lay out a framework for considering
cumulative impacts across the programs and their decisions. He said that Ms. Collin has
personally taken leadership of this promise and is already working hard to make progress on this
critical commitment. He said that he knows this will be another issue that the NEJAC will want
to engage on, and he does not just welcome the input and advice, but they are all collectively
seeking the Committee's advice.
Administrator Regan stated that when they look at correcting systemic injustices, the
incorporation of cumulative impacts in their work will not solve all the issues, but it's absolutely
critical to unlocking so much of their ability to make progress on the tough environmental and
public health challenges facing communities with environmental justice concerns.
Administrator Regan spoke about the recent efforts, including EPA allocating historic amounts
of grant funding to EJ and overburdened communities thanks to the American Rescue Plan, the
Bipartisan Infrastructure Law, and their commitment to Justice40. Their grant-making will
empower communities in ways that ensure their ability to protect themselves with the knowledge
and the capacity that they deserve. This may be the most durable contribution to environmental
justice in communities because, for the first time, they are funding community implementation of
community projects. He stated that these grants are supported by President Biden's Bipartisan
Infrastructure Law which invests more than $1.5 billion through EPA's brownfields program to
advance EJ, spur economic revitalization, and create jobs by cleaning up contaminated, polluted,
and brownfield properties.
Administrator Regan declared that he's proud to say that approximately 86 percent of the
communities selected to receive funding for proposed projects are in historically underserved
areas. That meets and exceeds Justice40. EPA's brownfields grants and other technical assistance
programs are also helping to build the clean energy economy in the communities that need it the
most. These are the actions that they're taking and will continue to take with the historic funds
made available by the Infrastructure Law. He emphasized that they will make sure that these
investments are durable, lasting contributions to the health of communities and the environment.
They're driving those benefits to communities that need and deserve them the most.
Administrator Regan announced that they've set some ambitious goals for advancing equity, EJ,
and civil rights, but they're also already delivering on many of those promises. They've already
moved out in significant ways to start making their commitments a reality. It's more than lip
service but letting their actions speak louder than words. He stated that they will continue to do
this work at this pace during his tenure as administrator because he recognized it as their
collective responsibility as EPA employees to ensure that they correct these injustices.
Administrator Regan stated that the injustice stories that he heard on the Journey to Justice Tour
were born by communities for generations. They are unjust, unfair, and absolutely unbearable.
This work is not academic to him or anyone; it's personal. He reiterated that it's about alleviating
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those injustices for the people facing them today and about ensuring that their children and
grandchildren can grow up thriving in communities that are safe, protected, healthy, and that
provide them access to clean environments and green spaces, places that everyone will want to
raise their own children in.
Administrator Regan acknowledged that none of that progress is meaningful if you can't see it. If
it's not transparent to anyone, then it's abstract. He's committed to making sure that the progress
is shown, felt, and real for the communities on the front lines who are facing these challenges.
He said that he looks forward to their continued partnership to ensure that NEJAC's advice and
recommendations and engagement with him and his team are consistent, utilized, and continue to
aggressively push forward to advance equity, justice, and civil rights for the communities most
overburdened and vulnerable to the country's historic environmental injustices. He invited
members to ask questions and/or make comments.
Chair Orduno thanked the administrator for his remarks that touch on the issues they are
concerned about. She appreciated him actually going into directly impacted communities to hear
concerns from them. Dr. Harrison asked if he could explain more about the status of the
cumulative impact assessment work that Robin Collin is leading. She also asked if he could
explain how they plan on holding states accountable for their responsibilities for meeting their
obligations in environmental justice and civil rights. Administrator Regan replied that he has
given the regional administrators specific direction around how to incorporate EJ in community
work. He and the regional administrators are in contact with the governors and environmental
secretaries about the disproportionate impact on disadvantaged communities. His office is trying
to home in on common themes that unite the definition of disadvantaged communities and being
specific with the states on SRF and historical programs.
Administrator Regan stated that they are tying federal dollars with environmental justice and
equity criteria. EPA is not afraid of putting pressure from the bottom up (press and community
leaders) and top-down to support and empower these communities with resources. He also stated
that he informed Congress that if states don't step in and act, EPA will use their authority to lean
in and hold polluters accountable. We have demonstrated partnerships that if states can't take
action we will. But more importantly we've encouraged states to take action that they would not
have otherwise. He noted that he's proud of the national program managers at EPA who are
really tying criteria to the resources that are given to states.
Robin Collin, Senior Advisor, U.S. EPA, stated that they are working on a multipronged
strategy beginning with robust science, and they have pushed science as far as they can to make
sure that they are including the important aspects of the lived experience of the community. They
are overlooking nothing. This is important to their approach to their partners, co-regulators, and
other stakeholders in terms of an action agenda. It shows their willingness to be in the room to be
able to deliver immediate relief to communities. She added that they are looking at all of the
available law not pigeonholed or siloed that promises every community in this country clean
air, water, and land. Those things don't require some new statute. They are pushing with every
legal authority they have. They have a new legal tools document soon to be followed by the
cumulative impacts document. She stated that she looks forward to their next meeting together.
Administrator Regan ended by saying everyone knows that cumulative impact and the legal
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premise governing cumulative impact look different in all of their programs. It looks different in
the superfund program versus the air program. They are looking at where there may be gaps. He
emphasized that they could do more and will continue to do more to fill those gaps and make the
necessary changes.
Cemelli de Aztlan stated that she lives in a border town in El Paso, Texas, and, because of that,
data doesn't matter. The initiatives to collect data from air monitoring and the lack of the
cumulative impact of the sources don't really matter. The border is basically a dumping ground.
They are a frontline community but in a different sense because of Mexico. So far, the America
Rescue Plan has included the expansion of the international bridges, but the investment needs to
account for the construction, traffic, and air pollution from that but doesn't protect schools and
children. They see a constant blaming of Mexico for all the border pollution but almost 70% of
the industries in Ciudad Juarez are U.S. corporations. Administrator Regan replied that he has
been working with DOT and Dept. of Education on those issues. He knows of American
companies that go across the border and pollute Mexico because their regulations aren't as
stringent as ours. Part of the Infrastructure Bill goes to those border towns. He hopes to meet
with international counterparts on those issues with solutions and not just academic information.
He added that the EPA has to take into consideration some of the areas and regions that they may
not have given as much attention to in the past. He hoped the NEJAC will provide some
constructive solutions to the EPA as he has solutions from the ground.
Mr. Shabazz asked if Mr. Regan has established some kind of report card or rubric by which
they can measure how well the regions are functioning relative to administrating and carrying out
the initiatives that Administrator Regan supports. What safeguards are enabling administratively
that the regions will be in lock-step with the mandates and priorities of the administration?
Administrator Regan stated that he is very proud of the initiatives and actions taken by regional
administrators thus far as the implementors. There are national metrics that they are governed by,
but he added that their metrics and NEJAC's metrics need to be matched in order for both sides
to see the regions' successes. He added the EPA staff will walk the NEJAC through the metrics
they have in place nationally and regionally to determine if that's the kind of measurement of
progress that the Council is looking for and the administration may have to think about
differently. The will power and the resources are there now we need to make sure we're all
measuring and looking at this thing the same way as we're making progress.
Ms. Colon de Mejias asked about intentional steps to empower communities that have long
been long under-resourced and not meaningfully engaged, such as educational-based approaches
in planning, career opportunities, and closing the informational gap that exists in many frontline
communities. Administrator Regan replied that the billions of dollars will go to grants in those
areas. Examples are the no or low-cost loans and grants, instead of matching funds, for lead pipe
replacement and the technology hubs that will be built. He added that this money will go to
communities that have never seen federal resources before, and that will be a success. Chair
Orduno thanked Administrator Regan for speaking today. Administrator Regan added that
EPA is operating head and shoulders above the other federal counterparts because of the NEJAC.
2.2 NEJAC Business Meeting
Chair Orduno stated that they aren't going to provide any formal recommendations by way of a
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letter at this time. They realized that the scope of the work that's taking place in the Finance and
Investment Workgroup is still in progress as shown in the letter provided to the Council. They
are joined today by Dr. Sacoby Wilson, co-chair of the Workgroup and former NEJ AC member.
Dr. Baptiste was not able to attend today. She reminded the Council that they received an email
of the draft document with details and that the slides show the main points. The purpose of the
letter is to ask the EPA what it is doing across the board and within programs areas to better
define how it's providing investments and benefits to communities with EJ concerns. She started
with Section 1 DEFINING Investments and Benefits in EJ Communities. She stated that the
Council wants a clear understanding of how the EPA is defining investments and benefits, both
direct and indirect. One of the initial recommendations is drafting "model" definitions that are
co-created with communities and measure, both direct and indirect benefits within the Justice40
framework. She noted that they should include a co-creation of metrics with communities that
face environmental injustices to determine the prioritization of benefits - both direct and indirect.
Chair Orduno also mentioned that another recommendation regarding definitions is on the matter
of PFAS exposure; the EPA should develop key building blocks of the definition of PFAS
exposure to include race for disadvantaged or underserved communities which can be a model
for states, regions, and other federal agencies. She invited other members to ask questions and/or
make comments. No hands were raised.
Ayako Nagano added that if they don't have clear, consistent definitions, then they won't have a
clear, consistent application of the funding going to disadvantaged communities. She moved on
to Section 2 PRIORITIZING Investments and Benefits in EJ communities. The NEJ AC seeks to
understand how the EPA prioritizes and centers the concerns and needs of communities
experiencing EJ problems through financial investments and benefits. She stated that the NEJ AC
wants to know what the barriers and challenges experienced by some agency offices, and if
programs are implementing and prioritizing environmental justice.
Ayako Nagano emphasized two main issues. One, how is equity utilized as a determinant in the
EPA's prioritization of when, how, where, and why funding and investments are placed for
environmental justice concerns? Secondly, among the EPA's six Justice40 pilot programs for
implementation by the EPA in 2021, how were priorities established to determine where, when,
and why finances and investments were placed to correct environmental problems in affected
communities and to ensure equity? Chair Orduno invited other members to ask questions
and/or make comments. No hands were raised.
Mr. Shabazz introduced Section 3 ASSESSING/DETERMINING and DISTRIBUTING
Investments and Benefits in EJ communities. One of the primary concerns was to be certain that
there is a very specific tool or model in place to identify the funding, how it's invested, what the
technical supports look like, and to see that the funding is getting to the communities that need it
the most. He stated that NEJAC recommends funding and investing in technical support to
NGOs and CBOs, improving the depth of communication with frontline communities to provide
adequate resources to address community concerns, increasing EPA environmental justice
staffing capacity through direct funding and investments to assist with addressing EJ concerns,
establishing and funding Regional Environmental Justice Advisory Councils (REJACs) for each
EPA region, and funding an assessment of the utilization of the NEJAC's Model Plan for Public
Participation (2000) in the EPA's determination and distribution of investments.
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Chair Orduno added that NEJAC wants to ask EPA for a better understanding of the work that
they've done so far in those six pilot areas to understand how it is that the assessment and the
determination of the distribution of those funds were carried out through the program areas of
EPA, specifically, for each region, how many communities were recipients, which groups were
included, what changes occurred, and were those changes successful? She invited other members
to ask questions and/or make comments.
Mr. Kricun stated that he sees three main categories of barriers to why underserved
communities don't get funding. One is they may lack technical resources. The second is that
some community groups may be at their debt limit or just lack funding. The third is some
communities need basic services, and the local policymakers don't apply so the EPA needs to
proactively go after them.
Dr. Sacoby Wilson, co-chair of the Finance and Investments Workgroup, added that NEJAC has
requested REJACs for years. He also added that regional administrators need to use the EPA
EJSCREEN and be able to click on their regional tool to get regional data. These tools track the
indicators and snapshot programs and benefits. There needs to be a feedback in the regional tool
so community members can give feedback on the indicators and the definition of benefits.
Dr. Wilson moved on to Section 4 MEASURING and TRACKING Direct Investments and
Benefits in EJ communities. This is to understand the scope and flow of EPA direct and indirect
funding, financing, and investments that communes with EJ issues. All programs should provide
written documentation on the metrics that address direct and indirect investments and benefits.
What measures were utilized to ensure intended targets receive direct benefits? He continued
with the benefits should include social, economic, environmental, and health indicators.
Dr. Wilson spoke about how performance targets are measured, modified, and improved based
on data and experience. He stated that some questions include, in which way does EPA include
indirect benefits in its measurement of benefits? What are the metrics used to measure multiple
or cumulative benefits with a variety of stakeholders? How are accountability and oversight for
performance goals built into the EPA programs? What corrective actions will be undertaken if
they are not achieved to ensure investments measurably lower burdens on EJ communities? How
will the new OEJ tracking tool to measure investments and benefits allow for public engagement
from EJ communities? What are the primary barriers and challenges to creating this tracking
tool? What are the barriers and challenges to creating a system to track investments and benefits?
Chair Orduno acknowledged that this draft letter is very comprehensive, and the workgroup
needs help on where the focus needs to be.
Ms. Colon de Mejias stated that she has noticed, nationally, that there is a lack of focus on the
critical impacts of energy emissions, production, and distribution, and climate change which is
directly related to that. Related to talking about benefits and impacts, she noted that specific
information on the equity lens needs to be included. She and others developed a descriptive,
distributed equity lens. Benefits include cumulative impacts, jobs, health, housing, resilience
building, distribution of funding, and avoided harms like heat islands, flooding. She explained
the distributive equity lens, and she put a link in the chat to access it. She noted that there aren't
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many energy experts on the Council. She thinks that it is critical to discuss energy to ensure that
whatever document measures energy benefits is inclusive of energy infrastructure. Chair
Orduno asked Ms. Colon de Mejias to send those comments to the workgroup so they can be
incorporated. Ms. Colon de Mejias noted that energy is connected to everything humans do,
such as housing, playing, working, and just living.
Ms. Owen suggested that, whenever they're talking about funding, they should also include
enforcement and compliance and about Title VI and civil rights overall in addition to
environmental justice, especially with states. Chair Orduno suggested sending those thoughts to
the workgroup. Dr. Wilson explained the long-term struggle with states getting money, not
spending it correctly, and then it being sent back. He agreed with Ms. Colon de Mejias that most
environmental justice issues stem from energy. He suggested looking at pastNEJAC reports for
ideas.
Ayako Nagano informed the Council that the Office of Water is coming out with a memo that
says that they will be enforcing Title VI on the states. She added that the city of Oakland shared
a tool they use that reviews every line item on the budget for equity in the EJ work. She
recommended that NEJAC looks into a tool like that.
Mr. Shabazz added the EJSCREEN tool should include the energy part of measurement. Chair
Orduno asked members on the Water Infrastructure Workgroup to give suggestions on the
definitions. She also wants to hear more from territories and tribal lands to make sure their issues
are also being addressed.
Vice-Chair Jelks added that the Water Infrastructure Workgroup discussed the definitions and
metrics related to water. She emphasized benefits being codeveloped and marrying metrics with
expectations recognized by the community. She also recommended that EJSCREEN be the floor
for data sets and metrics and bringing in local data.
Mr. Clow mentioned that everything discussed so far has applied to tribal communities. He
mentioned that the DOE funds a lot of energy projects for tribes, and the magnitude of the
resources in Indian country to power this nation and the world is significant. He gave a few
examples of win-win situations mentioned by Administrator Regan. He also mentioned that he
hears a lot of negative feedback towards projects that could help due to concerns with capacity or
ability that could also help with climate change innovation and intergenerationality; just try the
idea and see if it works. Chair Orduno added her appreciation for Mr. Clow's hope, vision,
inspiration, and out-of-the-box creativity that can be a positive contribution to the letter and that
the NEJAC can champion.
Dr. Millicent Piazza wanted to underscore the importance of the terminology piece of the plan
as someone who tries to operationalize this work from a state bureaucracy. For instance, the term
historically underserved areas leads her to think about how that fits with mapping and how she
justifies that among other terms. She echoed comments on who defines the benefits and how to
connect investments and metrics to what the community benefits are and create accountability to
those benefits. She echoed the comment that they shouldn't focus on guardrails, i.e., what they
can't do but on what they can do. She recommended putting some language in the letter about
participatory budgeting and what that looks like, particularly what it can look like with
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accountability to community vision. She offered assistance in adding Title VI components to the
letter.
Mr. Shabazz stated that accountability and co-production need to be defined as to what they
look like and what social benefits looks like when community members participate in social
projects. He suggested a prosperity index as well or a community benefits index, so people aren't
focusing on what the problem but what it looks like when we do it right. For example, green
infrastructure and water are managed by the local municipality and we treat it as ancillary but it's
the primary aspect of the citizens involvement in what it looks like as a community benefit for
everything from the aesthetics of a community to how people feel and more. A prosperity or co-
benefits index should represent this. Jobs production programs should recognize this relationship
such as Hopeworks, PowerCorps, Green Ambassadors. He suggested that EPA work on creating
uniform guidance and training for citizen scientists and citizen participation, so the work and the
monitoring are legitimate and official and their monitored work can end up on a portal like
EJScreen. Dr. Wilson agreed with and praised the comments on the prosperity index.
Dr. Wilson moved on to Section 5 MAPPING and REPORTING Investments and Benefits in EJ
communities. He added when we map things out we should be able to map healthy cities, healthy
community systems, benefits that are tangible, the food-energy nexus and green infrastructure
which get back to mitigation, adaptation, and resilience and getting equity in that. He explained
the recommendations that all EPA programs should develop a clear and public method (similar
to the EJ Screening tool) that provides data on where EPA funding is provided, distributed, used,
and assessed; develop a visualization tool for funding to include mapping indicators in the
ongoing development of this tool with provisions for longitudinal data; and, for capacity building
centers, deepen the work on developing capacity building centers within marginalized
communities to enable them to have local technical resources available for applications,
including "ground floor" assistance.
Mr. Shabazz added an example regarding CEJST with the success of hiring local workers and
using local contractors, local resources, and local contacts. Chair Orduno added that many local
EJ groups had negative experiences with academic institutions and researchers that don't know
the people and the community.
Jacqueline Shirley agreed with Mr. Clow's comment on the win-win and about deepening
capacity development. She explained that the youth of today (in summer internship programs,
AmeriCorps, and VISTA) will become the organizers of tomorrow. Ms. Colon de Mejias stated
that yesterday's presentation proposed the funding will be distributed down seemed to take the
same trickle down approach as it has been in the past, and she found it to be ineffective or else
we wouldn't continue to have the same historic disparities in EJ communities that persist and
expand. She recommended that there needs to be an indication that there's a critical need to stop
the trickle-down approach from EPA to a large entity and switch to a "soaker hose" approach.
The funding needs to go to the "root" of the problem which is in the communities. Governments
tends to partner with known partners which are comfortable to make the investments because the
people look like them, talk like them and willing to do surface work and research without
directly engaging communities most at risk and harm. Those closest to the problem are closest to
the solution when they are listened to and empowered. She noted that the EPA funding solution,
as proposed by the new EJ Grants program, sounds extremely familiar and does not work. She
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does not want to repeat the past funding issues.
Chair Orduno transitioned the discussion to the Thriving Communities hubs. She reviewed the
presentation from the day before. DFO Jenkins reminded the Council that this program is not up
for a vote; it was just a proposal consultation, and OEJ members are listening for feedback.
Chair Orduno invited other members to ask questions and/or make comments.
Mr. Kricun stated that the proposal is a very positive thing to do. He stated that he is concerned
with sustainability across administrations, ensuring that communities know about them and that
these centers (not the government) give the assistance the communities deserve. Chair Orduno
asked for clarification on exactly who the centers are for. Mr. Kricun replied that he hopes they
are for everyone large groups and small groups. Mr. Burney answered that the hubs are for a
wide range of stakeholders in a community from community groups to state governments. Dr.
Tejada clarified that community groups are the primary goal users. EPA doesn't want to assist
larger groups and entities who can get help TA assistance elsewhere such as brownfields and
other philanthropic efforts set up for cities. Chair Orduno expressed concern that there may not
be enough time to get this up and running especially with pandemic experiences and infusions of
funding that required local assistance organizations and state agencies to ramp up their staffing
and programs and led to frustration among residents.
Ms. Owen echoed concerns already raised, such as the timeline and hubs being mostly online
because of connectivity issues within communities, large entities overseeing handling the
distribution of funds, pilot programs becoming the default, spending the money so quickly, EPA
relinquishing control of the funds to the large entities, setting the cap for cost rates, preferences
for non-profits versus universities, and providing federal place-based commitments and pulling
of resources. EPA lack of direct involvement with communities disadvantages communities
without access to EPA and they won't have the critical relationships to hear about issues and
concerns, and less of a direct audience with EPA.
Chair Orduno announced it was time for a break.
Chair Orduno encouraged members who haven't spoken yet to add to the discussion.
Vice-Chair Dr. Jelks echoed what others have said, such as the time constraints, the definition
of large non-profit, track records of organizations, and the measurement tool used to understand
if the organization can do the work. She stated her concern over the preparation of staff for the
hubs with cultural competencies, community contexts of past challenges and current realities,
and just relating to the community members. Technical know-how is one thing, but cultural
readiness is another. She asked for clarification about the duration of the small $100,000 grants.
Ms. Shirley echoed Dr. Jelks' comment about the devil is in the detail. She also asked for
clarification on what a "large" organization is. She asked what the end goal of the TA is. She
asked if the EPA could invite NEJAC members to be on the proposal application committee.
Chair Orduno added that it would seem that the folks that are managing the centers could be
potential arbiters of information. Who would they be answering to and how will the information
be used for other kinds of analytics.
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Mr. Shabazz shared that the process should be an inverted pyramid in that the non-profit
becomes the leader of the grant or the center, and other entities are there to support them. He
explained that it changes the balance of power by making the larger partnership to provide the
capacity and support but allow the local organization to drive the priorities for that particular TA
hub. It's more authentic, and there's better engagement. He asked if there was a particular suite of
services that these hubs provide. If you pick the type of services that you provide (water, air,
etc.) will you make certain people more eligible than others? By default you make certain people
eligible if you can't provide everything. He also asked, since the hubs are more of a virtual
experience, can there be an emphasis on them being a place-based experience? A lot of people
don't trust calling government entities. Chair Orduno added that tangible investments are more
worthwhile.
Dr. Whitehead asked if there are providers in mind for the pilot program. Most universities
won't bid on something that's less than 50 percent in overhead. She agrees that most of the
money should go to the non-profits in the communities. She would be wary of a national
organization coming in and working in a community they're not familiar with. When looking at
success, she asked whose success are you measuring? The TA number of classes or an increase
in capacity for a small organization or something else?
Rev. Ambrose Carroll stated that, since he's new, he likes to listen first. He stated that he's
looking for the political will to get this done. It is the impetus and the funding to get the capacity
for getting things started. The reality for redlined, subjugated communities is that they have
something to offer and this is an opportunity to breaking previous ways of working and building
capacity where it hasn't been trusted and where people and organizations haven't been resourced
and have been etched out. He stated that there are non-profits in the community who don't want
to help because they are not engaged. Chair Orduno agreed with him on those points.
Ms. Colon de Mejias echoed the question of, what are the end goals of the hubs? She also
echoed the comment of engaging the non-profits in the community as the fore-step to solving the
problems rather than as a last choice which also removes power from the community. Don't
incentivize the problem entities, but empower the solution, for example, carbon credits versus
lower emissions. She stated that she's concerned about EPA working with only a few entities
versus ensuring that there are entities in all of the regions to socialize EPAs work and EJ issues
and build trust and capacity and to be told to go here or there to search for resources.
Regarding the TAs, Brenda Barreto applauded the steps EPA is taking to make sure the grant
funding is more available to those communities that may not otherwise reach or get access to this
funding. They've had to establish resilient hubs through the transformation of community centers
or churches that people trust and then move forward with providing citizen science certification
and more. She stated her concern about the bureaucracy. EPA isn't always timely with guidance
such as estuaries and BIL funding for FY22. She noted that she likes the idea of incorporating
translation services. It is a huge barrier for communities to access funding and deal with the
paperwork. Chair Orduno asked for her comments on the EJ Grants program regarding island
communities. Ms. Barreto stated that her main concern is with any island or territories or any
other jurisdiction that lacks the EJ state-wide or island-wide platform to obtain the funding or be
able to translate this national policy into local actions. It's imperative that EPA requires these
places to really have that in place to be effective at the local level.
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Ayako Nagano echoed concerns about the large non-profits and academia holding the purse
strings. She suggested that the hubs also become resiliency centers for various activities or
workforce development.
Dr. Fritz agreed with many points. She highlighted the concern about overhead for universities.
It is true that they like national grants because there's a higher percentage involved, but they also
have a set percentage set aside to work on community issues as well. So, negotiations would
have to occur to make that happen. She suggested reviewing the model at a certain period, such
as at the three- to four-month mark, to make sure it's working the way it's intended and with
deadlines. She suggested that advisory groups monitor the program.
Mr. Clow suggested that the TA centers can be a place to connect people with entities that can
help and not tell people that they can't be helped and get referred elsewhere. Chair Orduno
asked for an example. Mr. Clow replied that he would have to think about it to give one.
Chair Orduno stated her concern about the competitive nature of the grants in relation to the
time constraint. She asked the OEJ Grants Program to consider this to be a less competitive
process and instead find ways to have better distribution to more communities, especially for
first-time applicants, recipients, or community-based issues.
Dr. Wilson stated that if all the questions on the letter are answered, this could be a great
program. He recommended having a regional focus instead of just two entities controlling the
money. He agreed with the flipping-it model, suggesting the community/university model where
the community is the lead. He strongly agreed with the overhead cap on indirect cost (IDC)
agreements and that equity is embedded in how the funding is disbursed.
Chair Orduno asked if anyone objected to extending the meeting by 30 minutes, so everything
gets covered. No one objected. She moved on to the PFAS Workgroup discussion.
Dr. Whitehead reviewed the priority points from the last meeting. She explained that those
points were condensed into the three priority points from the presentation yesterday: research,
restrict, and remediate. The workgroup will take the comments and feedback from the meeting
and roll them into Roadmap 2.0. That deadline is September. John Doyle stated that he is most
concerned with the land and soil and has learned that the Bureau of Indian Affairs was the
recipient of a lot military surplus items over the years that affected the soils and should be
investigated. He has a call next week on the testing. Ms. Shirley stated her concern that recently,
EPA requested volunteers to test the water, and the local water utility manager refused (which
was not true) because he said that, if PFAS was found in the water, EPA would regulate it and it
would cost money they don't have. She understands both sides: the cost of keeping it safe and
hiding it because it costs money if found and they are already burdened financially. While
military sites and industries hide, the small utilities struggle to keep running and their burdens
need to be appreciated by EPA.
Mr. Krichen agreed with the general roadmap and offered specific examples to optimize
restriction and remediation elements, such as enlisting allies in drinking water and wastewater
area to track back in the system and find sources like orphan sites where there could be runoff
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from PFAS coming into the system in need of a trackback. There are low-hanging opportunities
at low-cost to get PFAS out of the system. Dr. Whitehead added Mr. Krichen points about
biosolids to the PFAS Workgroups agenda items for its next meeting. Chair Orduno noted a
Michigan news story where biosolids used as fertilizer where cows graze had PFAS detected in
the beef served to children at a school. She didn't recall if it came from a wastewater treatment
plant but concerns were raised about creating problems in new areas and getting a better
understanding of potential impacts in using biosolids in other places. She added her concern with
the roadmap plan and concerns still not including emergency responses to communities with
high levels of contaminants. Remediate can be an extended process and oftentimes can mean it's
being dealt with in institutions or organizations that can be resistant as we've heard from the
Department of Defense that has not wanted to acknowledge its burden of responsibility in
contamination on military bases and that affects the drinking water of adjacent communities.
There's a need to ensure drinking water at the household level for communities that have been
polluted or contaminated in their ground or drinking water sources. She added the roadmap
needs to include immediate actions as appropriate responses in man-made disasters as we've
talked about with lead in drinking water when systems don't adequately protect against changes
in the source of their drinking water levels or not using adequate phosphates to line water mains
or in climate-related disasters. EPA has to be an active participant in addressing emergency
water needs. As Ms. Shirley has noted, small and rural systems are vulnerable. Benton Harbor is
a community to keep watching. Office of Water is looking at the process to review how systems
that haven't been meeting SDWA requirements should be under consideration for consolidation
or regionalization. She noted that when we look at historical reasons why communities are in
jeopardy to begin with or have not had the resources to upgrade their drinking water or water
treatment plants, there's very much racialized and class-based reasons behind them such as when
communities are left behind or private disinvestment leaves and the community is left holding
the bag. More affluent communities also build their systems off the vulnerable community and
leave them behind.
Ms. Barreto stated that she's concerned with the research part of PFAS. Sometimes their
protocols aren't accurate or timely. She stated that she's also concerned about the internal
capacity in the EPA to manage this new program. If the EPA is pushing an active agenda to
reduce the exposure of communities to PFAS contaminated water they have to do somethings
with their protocols to prevent and put forward the actions to save people's health. Dr.
Whitehead noted that comment for the workgroup's next meeting agenda. She invited more
members to join the workgroup.
Ms. Colon de Mejias noted the excellent work of the workgroups and reminded that PFAS can
be found in food packaging and cooking products, not just in water, air, or land. People are
reusing older packaging that may contaminate current food supplies, so education is an important
component of the restriction goal, along with stopping the distribution of those products now.
She also stated her concern with the timeliness of PFAS reports. She suggested that those reports
go out on TV, social media, radio, and computer outlets. She also suggested that companies stop
making packaging that contains PFAS now. Ms. Shirley stated that she's thankful that EPA is
spending money to help communities, but they also need to remove people, systems, companies,
and entities causing these problems, and remediate contaminants that are harming people now.
Ayako Nagano questioned, if EPA knew about these contaminants in packaging, et cetera, why
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haven't they done anything sooner to prevent this from being created in the first place? Are they
really protecting the people? The same thing happened in creating plastics.
Mr. Doyle informed the Council that this journey to ban PFAS began with burning garbage. The
PFAS was in the smoke that people breathed, and that smoke settled in the water they drank and
the land. The people were the impetus for EPA to start testing for PFAS. Indigenous people have
many unknown influences on their health issues and they don't know where to start or how to
address it, especially if they don't have the resources to do it. But if they don't do it, who will.
Their well water and surface water is contaminated with PFAS and puts a burden on their
community that they can't afford. Chair Orduno replied that EPA needs an immediate response
plan when a community's drinking water is contaminated, such as bottled water, piping it in,
reverse osmosis, and cleaning it up immediately with new technology that uses plasma. Ms.
Shirley shared a story that the chair of that workgroup apologized for bringing in a PFAS-most-
likely-containing water bottle that contains clean drinking clean water because she couldn't drink
her own tap water. Mr. Doyle stated that he uses bottled water every day because he knows
what's in the tap water and the river. His town doesn't have the resources to buy it, so they have
to go ten miles to get water and 60 miles to get cheap water.
Dr. Carroll recalled, when he was a child, drinking from a family home's well in northern
Louisiana, but now they have water pumped in from the city because the wells are polluted from
runoff and fracking. Food grown in that area is now questionable. That area is called Cancer
Alley for a reason. Chair Orduno thanked him for sharing the story. She moved the meeting to
the next agenda item.
2.3 NEJAC Workgroup Updates
Ayako Nagano gave the updates for the NEPA Workgroup. They met with the Office of Federal
Activities. The workgroup was given a three-pronged charge. The first is to look into internal
NEPA trainings that the OFA is putting on and, then secondly external OFA trainings to other
agencies regarding environmental justice issues, and then the third is to help the EPA provide
project-specific technical assistance on EJ considerations to lead agencies in community with EJ
concerns. Dr. Piazza added that it's the specific content of that training that needs to be looked
at. They will work on that charge until the end of the year and then transition to another aspect of
NEJAC.
Chair Orduno asked for clarification on the charges themselves. Ayako Nagano explained it
again. Chair Orduno asked for clarification that all charges need to come to the Council first,
and then it goes to the specific workgroup. DFO Jenkins replied that normally, yes, official
charges would come to the NEJAC first, but this is not an official charge yet. Dr. Piazza added
that maybe "charge" was not the correct word. Karen Martin, U.S. EPA, clarified that EPA has
agreed to sit in with the workgroup as they are discussing this issue. She stated that, right now,
the workgroup is in a consultation phase, and then she explained the process of a charge. Chair
Orduno thanked her for the clarification.
Vice-Chair Dr. Jelks gave the updates for the Water Quality Infrastructure Workgroup. They
are meeting with the Office of Water often. They are working on giving major input to the
Finance and Infrastructure Workgroup letter, developing their own letter by October regarding
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potential gaps in the 100 Day Letter, consolidating feedback and recommendations for the Office
of Water, and lastly possibly hosting a public meeting centered on water infrastructure issues.
She also explained that last week, they received a letter from the National Association of Clean
Water Agencies requesting help for their newly formed EJ committee. They're looking for help
with principles and recommended actions. Mr. Kricun added thatNACLA is looking to
potentially become an EJ resource for their communities. Chair Orduno added that there's also
conversations around the implementation of State Revolving Fund dollars. She also added that
the infrastructure dollars are decisions made by state legislatures. She stated that it's difficult to
bring forward recommendations between workgroup and public NEJAC meetings, so they've
been having stakeholder meetings instead.
Vice-Chair Tilchin gave the updates for the Air Quality and Community Monitoring
Workgroup. He stated that they are working on a recommendations letter to present to the
NEJAC. OAR has been working with them on that letter. The discussions from this meeting will
help also. Dr. Fritz asked what the difference is between receiving questions and a charge. Ms.
Martin explained that, when EPA is asking for recommendations from an advisory committee, it
comes in two forms. One is with an official charge to the whole NEJAC, and that's when NEJAC
formed the workgroups to address them. The whole Council sends the official response back.
The second is with consultation with individual members of the workgroup. Individuals can
write letters as well.
Chair Orduno gave the updates for the Farmworkers and Pesticides Workgroup. They are
working on the development of a charge with the Office of Pesticides regarding worker
protection standard non-compliance because the work from them so far has not been enough,
especially with women. The workgroup is hoping to have a draft at the next public meeting.
2.4 Announcements and Appreciations
Karen Martin reminded everyone that this was DFO Jenkins' last meeting. She announced that
Ms. Paula Flores-Gregg will be the incoming DFO. Many thanks were given to DFO Jenkins
by various members. DFO Jenkins also gave his thanks and appreciation.
2.5 Closing Remarks & Adjourn
DFO Jenkins adjourned the meeting.
[MEETING ADJOURNED]
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I, Sylvia Orduno, Chair of the National Environmental Justice Advisory Council, certify that
this is the final meeting summary for the public meeting held on June 22-23, 2022, and it
accurately reflects the discussions and decisions of the meeting.
Sylvia Orduno
Date: September 6, 2022
49
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Additional Submitted Written Public Comments -
APPENDIX 1
Appendix 1. Written Public Comments
2022-06-22 NEJAC Cover tette' re EPA lnc'nerat«r Staidards.pdf ................ 2
2022,07,05 NBAC Feicellne Monitoring Conmenti.Ddf ............................................................................ 4
AnrotatedB:blicGeT.pdf.,.. .......................................................................... 8
CARE NEJAC Pjalic Corr rrer.t.paf 27
Comments for 6-22-2022 NEJAC.pdf............ 30
EPA-oillne-a'cblve-lette-.Ddf ...................................................................................................... 31
fluorosis JJ5_2Q2I,pdf ......................................................................................................... 35
Granojean-Bercmiark Dose-Vate'nsl F and IQ "n kids-Ris
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Hearthjustice
July 5, 2022
Submitted electronically to nejac(a>,epa.gov
Chairperson Sylvia Orduno
National Environmental Justice Advisory Council
Office of Environmental Justice
U.S. Environmental Protection Agency [Mail Code 2201A]
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Dear Chair Orduno and Members of the National Environmental Justice Advisory Council:
This letter requests that the National Environmental Justice Advisory Council ("NEJAC")
help protect fenceline communities by urging EPA to expand and strengthen its assessment of
fenceline community risks without delaying the regulation of chemicals that were previously
evaluated under the Toxic Substance Control Act ("TSCA"). In 2016, Congress amended TSCA,
directing EPA to evaluate and eliminate chemicals' unreasonable risks not only to the general
public, but also to groups that that face higher levels of chemical exposure or are more
susceptible to chemical exposure ("potentially exposed or susceptible populations")1. Those
groups include communities surrounding the sites where toxic chemicals are manufactured, used,
released, and disposed, as well as communities that face increased chemical exposures from their
food and drinking water. These communities often face outsized harm, as they are more likely to
be dealing with intrinsic factors, such as underlying health concerns, as well as extrinsic factors,
such as psychological stress related to factors such as poverty and structural racism. These
factors can make people more susceptible to harm from chemical exposures, so communities
experiencing these stressors will face greater risks following an exposure than communities
without them. Despite these concerns, EPA's approach to assessing community risks (the "Draft
Fenceline Assessment Approach") leads to an underestimation of chemical exposure and
susceptibility, and a corresponding underestimation of risk. For this reason, we ask the NEJAC
to urge EPA to 1) implement near-term changes to its Fenceline Assessment Approach for
chemicals that have already been evaluated under TSCA and 2) to implement broader
changes, including the calculation of cumulative risks, for future TSCA risk evaluations.
1. EPA's current Fenceline Assessment Approach fails to adequately assess risks to
fenceline communities
EPA's mandate to evaluate risks to communities facing high levels of chemical exposure is
only satisfied if EPA considers the full range of intended, known, and reasonably foreseen ways
that fenceline communities will be exposed to toxic substances. EPA's current Fenceline
Assessment Approach fails to meet that standard. In particular, the approach narrowly defines
fenceline communities, does not adequately consider available data on pre-existing levels of
chemical exposure or peak facility releases, and does not reflect input from exposed communities
1 15 U.S.C. § 2605(b)(4)(A).
TOXIC EXPOSURE & HEALTH 48 WALL STREET, 19 FLOOR NEW YORK, NY 10005
T: 2 12.845.73 76 F: 2 1 2.9 18.155 6 TEH@EARTHJUSTICE.ORG WWW.EARTHJUSTICE.ORG
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themselves. Further, the approach fails to incorporate the cumulative impacts of multiple
chemicals and multiple polluting facilities, as EPA is only looking at exposure from one
chemical and one facility at a time. However, many chemicals cause the same kind of negative
health and safety effects, compounding the harm that communities face when exposed to
multiple toxins in one area, something not uncommon in manufacturing areas, particularly those
with a long industrial past.
2. Immediate modifications will allow for increased protections for fenceline
communities without delaying regulation.
EPA has expressed concern that modification of its Fenceline Assessment Approach may
result in a delay of regulation for chemicals that have already been evaluated and found to
present unreasonable risk. However, the choice between doing things quickly and doing things
correctly is a false dichotomy; there are steps that EPA can take now that will allow for the swift
regulation of chemicals while also ensuring that fenceline assessments for those chemicals are
more reflective of communities' actual exposures and risks. Many of these available steps have
been outlined by the Science Advisory Committee on Chemicals ("SACC") and by community
organizations working within this space.2
Firstly, EPA should consider the risks to people who are exposed to the same chemical from
multiple facilities and sources, as is often the case in the fenceline communities where polluting
facilities are concentrated. This could be done quickly and with little additional cost by utilizing
existing EPA air modeling software. Secondly, EPA should consider data on preexisting levels
of contamination in fenceline communities, as well as peak emissions from polluting facilities to
both incorporate existing exposure pathways and better understand the volume of toxins
fenceline communities are faced with. Third, EPA should account for cumulative impacts that
have not yet been fully quantified; in the short term, this could be done by including an
additional database deficiency uncertainty factor. Lastly, EPA should incorporate at least five
years of TRI data, as well as data available through federal or state sources and fenceline
monitoring, to better estimate chemical releases into communities. These modifications, if
implemented for the ten chemicals that have already been assessed under TSCA, will allow for
increased community protection without delaying the needed regulation of those chemicals.
3. Broader changes to the Fenceline Assessment Approach can be implemented to
strengthen the risk evaluation process going forward.
NEJAC should also urge EPA to make larger changes to the Fenceline Assessment Approach
for the risk evaluations that EPA is currently undertaking, including consultation with
community experts representing impacted communities. As identified by the SACC, EPA should
"reach out to Unique Communities ... the [National Tribal Toxics Council] and other tribal,
indigenous groups" about improvements to the Fenceline Assessment Approach, and
2 EPA, Final SACC Report and Meeting Minutes: Draft TSCA Screening Level Approach for Assessing Ambient
Air and Water Exposures to Fenceline Communities Version 1.0 ("SACC Report") at 15 (May 16, 2022);
Earthjustice, et. al., Comments on Draft Scopes of the Risk Evaluations for the First Twenty High-Priority
Substances under TSCA (May 26, 2020).
2
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"incorporate their recommendations in the Version 2.0 of that document."3. Additionally, as
acknowledged by both the SACC and NEJAC, EPA should incorporate analysis of cumulative
impacts of multiple chemicals within their risk assessment methodology.
This is particularly necessary for areas like Port Arthur, Texas, and in communities in Cancer
Alley, Louisiana. Residents of Port Arthur are more exposed than the general population to at
least five of chemicals that are currently being evaluated under TSCA, including 1,1,2-TCE,
phthalic anhydride, formaldehyde, 1,3-butadiene, and 1,2-dichloroethane From 2012 to 2018,
facilities in the Port Arthur area released, transferred off-site, and/or received just over 16 million
pounds of these five chemicals.4 The communities within Cancer Alley, which describes the 85-
mile industrial corridor stretching from New Orleans to Baton Rouge, have greater exposure than
the general population to nine of the TSCA high-priority chemicals, including 1,1,2-TCE, 1,2-
DCP, EDB, 1,1-DCA, DBP, phthalic anhydride, formaldehyde, 1,2-butadiene, and 1,2-
dichloroethane.5 When assessing the risk of additional chemicals under TSCA, EPA's current
methodology would fail to consider the already high chemical burden on communities like these,
ignoring the cumulative impacts that co-existing which such high toxicity levels can have on
community health.
The recommendations both for short-term modifications and longer term changes all echo
concerns that NEJAC have expressed in the past. In 2004, in the Ensuring Risk Reduction in
Communities with Multiple Stressors: Environmental Justice and Cumulative Risks/Impacts
Report6, NEJAC identified the need for EPA to incorporate vulnerability into assessment tools,
noting that "disadvantaged, underserved, and environmentally overburdened communities reflect
a complex web of combined exposures." In the almost two decades since the release of that
report, EPA has failed to develop an adequate strategy to evaluate the risks completely and
accurately for overburdened communities. In the meantime, millions of people have been living,
working, attending school, playing, and worshiping in close proximity to clusters of facilities that
release large volumes of toxins to the air, water, and land. We ask that NEJAC write to EPA and
urge EPA: (1) to assess the full range of chemical exposures and risks to fenceline communities
in all upcoming TSCA risk evaluations, including cumulative risks to people who are exposed to
multiple chemicals and non-chemical stressors and (2) to adopt near-term, readily available
changes to its fenceline assessments for the chemicals that EPA has previously evaluated under
TSCA, and to use those improved assessments to inform EPA's regulation of those chemicals.
We also offer our team as a resource to the NEJAC related to any fenceline monitoring or risk
evaluation issues.
3 SACC Report at 66.
4 Earthjustice, et. al., Comments on Draft Scopes of the Risk Evaluations for the First Twenty High-Priority
Substances under TSCA (May 26, 2020).
5 Id.
6 NEJAC, Ensuring Risk Reduction in Communities with Multiple Stressors: Environmental Justice and Cumulative
Risks/Impacts, (Dec. 2004), https://www.epa.gov/sites/production/files/2015-02/documents/neiac-cum-risk-
rptl22104.pdf.
3
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Respectfully submitted,
Katherine M. Welty7
Earthjustice
48 Wall Street, 19th Floor
New York, New York
(212)284-8025
kwelty @earthj ustice. org
7 Law Clerk, Earthjustice Toxic Exposure and Health Program, not currently admitted to practice.
4
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National Environmental Justice Advisory Council
Submitted electronically to neiac@epa.gov
June 23, 2022
Re: EPA's Delay in Updating Municipal Solid Waste Incinerator Standards
Dear NEJAC Members,
Thank you so much for your insightful comments to my testimony on municipal waste
combustion units at your June 22 meeting. The rules governing emissions from these facilities
are now decades overdue and many of the facilities are over three decades old. The USEPA
continues to grant a regulatory subsidy to these facilities by failing to issue regulations which
protect the health of the communities hosting the facilities. Modern air pollution control
technologies are required on just a handful of these incinerators; it is long past time for USEPA
to issue rules which comply with the Clean Air Act and protect environmental justice
communities from the harmful impacts of emissions from these incinerators.
There are 157 incinerator units at 57 sites across the country, but these sites are concentrated in a
handful of states. Over 90 of the 157 incinerator units in the country are in just these six states:
Connecticut 12 incinerator units at 5 sites
Florida 24 incinerator units at 12 sites
Massachusetts 11 incinerator units at 7 sites
New Jersey 13 incinerator units at 4 sites
New York 13 incinerator units at 10 sites
Pennsylvania 19 incinerator units at 6 sites
We are requesting that the NEJAC urge USEPA to finally issue rules for Municipal Waste
Combustors that protect public health and comply with the law as soon as possible.
We are attaching a letter on this topic submitted to the White House Environmental Justice
Advisory Committee from Breathe Free Detroit, California Communities Against Toxics, Center
for Environmental Transformation, Earthjustice, East Yard Communities for Environmental
Justice, Florida Rising, Global Alliance for Incinerator Alternatives, Ironbound Community
Corporation, New Jersey Environmental Justice Alliance, Oregon Physicians for Social
Responsibility, South Baltimore Community Land Trust, and Valley Improvement Project.
Thank you so very much for your kind attention to this critical public health issue. Communities
hosting these facilities need your help to protect their health and well-being.
Cordially,
Jane Williams
Executive Director, California Communities Against Toxics
Rosamond, California
661-256-2101
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Attachment:
Letter to White House Environmental Justice Advisory Committee from Breathe Free Detroit,
California Communities Against Toxics, Center for Environmental Transformation, Earthjustice,
East Yard Communities for Environmental Justice, Florida Rising, Global Alliance for
Incinerator Alternatives, Ironbound Community Corporation, New Jersey Environmental Justice
Alliance, Oregon Physicians for Social Responsibility, South Baltimore Community Land Trust,
and Valley Improvement Project
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Fluoridation Policy:
An Annotated Bibliography of Published Science
A sampling of the scientific studies and reports relevant to water fluoridation published
since the HHS 2015 recommendation to lower the fluoridation target to 0.7 ppm is listed below.
I suggest these items provide compelling evidence that 0.7 ppm is neither optimal nor safe
and that any claims to the contrary are ill-founded. Moreover, protests that more study is
required before banning fluoridation is a tacit endorsement of human experimentation
without individual consent which is medical assault - Karen F. Spencer
2022
RIGHT QUESTION: Given the robust and consistent evidence regarding the developmental
neurotoxic impact of fluoridation policy, the question that needs to be evaluated by communities
should be: is this intervention worth the risk of lowering the IQ of at least certain individuals
when we have a viable substitute, i.e. fluoridated toothpastes?
https://www.karaer.com/Article/Abstract/520789
Vieira AR The Overlooked Individual: Susceptibility to Dental Caries, Erosive Tooth Wear
and Amelogenesis. Monogr Oral Sci. Basel, Karger, 2022, vol 30, pp 140-148.
PAROTID GLANDS: Animal study finds fluoride exposure results in oxidative stress and
changes in oxidative biochemistry of the largest salivary gland which stimulates compensatory
mechanisms and increases risk to the complex cell cytoskeleton.
https://www.ncbi.nlm.nih.aov/labs/pmc/articles/PMC8794182/
Miranda GHN, et al. Effects of long-term fluoride exposure are associated with oxidative
biochemistry impairment and global proteomic modulation, but not genotoxicity, in parotid
glands of mice. PLoS One. 2022 Jan 27:17(1 ):e0261252.
LOWER PERFORMANCE IQ: Examined children's IQ at three separate time points (age 4, 5,
and 6-12 years) to determine longitudinal and domain specific effects of prenatal fluoride
exposure on IQ in mother-child dyads from the Early Life Exposures in Mexico to Environmental
Toxicants (ELEMENT) cohort. Found prenatal exposure to fluoride, which is primarily from
fluoridated salt programs, is associated with sustained impacts on IQ. Non-verbal abilities may
be more susceptible to impairment from prenatal fluoride exposure as compared to verbal
abilities.
https://www.sciencedirect.com/science/article/abs/pii/S00139351220032Q67via%3Dihub
Goodman C, et al. Domain-specific effects of prenatal fluoride exposure on child IQ at 4, 5,
and 6-12 years in the ELEMENT cohort. Environmental Research. 2022
GENOTOXIC: According to public health authorities, fluoride has a narrow range between the
concentration which is beneficial and that which has adverse effects. The primary exposure to
the fluoride-ion is through drinking water supplemented with fluorosilicic acid (FA). FA in 'safe'
doses causes DNA damage in human osteoblast cells, reduces the telomere length and induces
oxidative stress. Although combinations of fluoride with other toxins could have a synergistic
effect, this study found that FA alone affects the genomic integrity of human bone cells.
https://pubmed.ncbi.nlm.nih.gov/35483789/
Garcia ALH, Matzenbacher CA, Scares S, Rohr P, da Silva J. Fluorosilicic acid and cotinine,
separately and in combination, induce genotoxicity and telomeric reduction in human
osteoblast cell line MG63. Mutat Res Genet Toxicol Environ Mutagen. 2022 Apr-
May:876-877:503474.
compiled by KSpencer
2 July 2022
page 1
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Fluoridation Policy:
An Annotated Bibliography of Published Science
BODY & BRAIN: "Fluoride in higher concentrations or continuous exposure to lower doses are
both found to induce mental imbalance in animals apart from the genotoxic, immunotoxic, and
cytotoxic effects commonly observed. The behavioral profile of fluoride-treated animals has
corroborated the clinical symptoms seen in fluoride-poisoned humans."
https://pubmed.ncbi.nlm.nih.gov/35488996/
Ottappilakkil H, Babu S, Balasubramanian S, Manoharan S, Perumal E. Fluoride Induced
Neurobehavioral Impairments in Experimental Animals: a Brief Review. Biol Trace Elem Res.
2022 Apr 30.
PROBIOTICS: Adding probiotics to school milk is more effective and less costly than fluoride
varnish in preventing cavities in children, https://pubmed.ncbi.nlm.nih.gov/35567374/
Rodriguez GA, Cabello RA, Borroni CP, Palacio RA. Cost-effectiveness of probiotics and
fluoride varnish in caries prevention in preschool children. J Public Health Dent. 2022 May
14.
OVARIAN & TESTICULAR: Animal study from in utero through puberty showing adverse
impact on reproductive function. "Approximately 80-90% of fluoride absorbed by infants and
children accumulates in the body. It can enter into the umbilical cord blood of the child from the
mother through the placenta. In addition, significantly high fluoride content in breast milk is
indicative of fluoride exposure to infants. Young children show less resistance to the toxic effects
of fluoride than adults because of under-developed defense mechanisms and highly permeable
blood-brain barrier." https://link.springer.com/article/10.1007/s12011-022-0322Q-8
Li, W., Sun, Z., Li, M. et al. Exposure to Fluoride From in Utero to Puberty Alters Gonadal
Structure and Steroid Hormone Expression in Offspring Rats. Biol Trace Elem Res (2022).
BIRTH ANTHROPOMETRY: Using ELEMENT cohort, authors determined maternal exposure to
fluoride affects length and weight of newborns with different susceptibility windows. Advises
women avoid fluoride during pregnancy, https://pubmed.ncbi.nlm.nih.gov/35660617/
Ortiz-Garcia SG, Torres-Sanchez LE, Munoz-Rocha TV, Mercado-Garcia A, Peterson KE,
Hu H, Osorio-Yanez C, Tellez-Rojo MM. Maternal urinary fluoride during pregnancy and
birth weight and length: Results from ELEMENT cohort study. Sci Total Environ. 2022 Jun
2:156459. PMID: 35660617.
KIDNEY KILLER: Using U.S. NHANES data, finds water fluoridation results in significantly
higher plasma fluoride levels in healthy teens with lower renal function, suggesting a vicious
feedback loop for those with CKD.
https://www.sciencedirect.com/science/article/abs/pii/S00139351220093Q6
John Danziger, Laura E.Dodge, Howard Hu. Role of renal function in the association of
drinking water fluoride and plasma fluoride among adolescents in the United States:
NHANES, 2013-2016. Environmental Research. 7 June 2022.
2021
BENCHMARK DOSE ANALYSIS: Using fluoride studies from MIREC and ELEMENT projects
as input, the results of which are consistent with other studies, authors identify 0.2 mg/L as
having an adverse impact on neurodevelopment. "The prospective studies offer strong evidence
of prenatal neurotoxicity, and the benchmark results should inspire a revision of water-fluoride
recommendations aimed at protecting pregnant women and young children."
https://pubmed.ncbi.nlm.nih.gov/34101876/
Grandjean P, Hu H, Till C, Green R, Bashash M, Flora D, Tellez-Rojo MM, Song P, Lanphear
B, Budtz-Jorgensen E. A Benchmark Dose Analysis for Maternal Pregnancy Urine-Fluoride
and IQ in Children. Risk Analysis. 8 June 2021.
compiled by KSpencer
2 July 2022
page 2
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Fluoridation Policy:
An Annotated Bibliography of Published Science
LIFETIME EXPOSURE: Fluoridation is the primary source of fluoride exposure for 1,629
Canadians between 3 and 79 that finds substantially higher lifetime fluoride exposure in
fluoridated communities using CHMS data, increasing with age. Vulnerable subpopulations to
adverse effects of fluoride noted as the young, those who are iodine deficient, and post-
menopausal women, https://www.mdpi.com/1660-4601/18/12/6203/htm
Julia K. Riddell, Ashley J. Malin, Hugh McCague, David B. Flora, and Christine Till.
Urinary Fluoride Levels among Canadians with and without Community Water Fluoridation.
Int. J. Environ. Res. Public Health 2021, 18(12), 6203.
KIDNEYS: This study of 1,070 adults found every 1 mg/L increment in the urinary fluoride
concentrations was associated with significant increases of 22.8% in the risk of kidney function
injury after adjusting for potential confounding factors. Authors conclude that long-term fluoride
exposure is associated with compromised kidney function in adults, and that urinary NAG is a
sensitive and robust marker of kidney dysfunction caused by fluoride exposure.
https://pubmed.ncbi.nlm.nih.aov/34478979/
Wu L, Fan C, Zhang Z, Zhang X, et al. Association between fluoride exposure and kidney
function in adults: A cross-sectional study based on endemic fluorosis area in China.
Ecotoxicol Environ Saf. 2021 Aug 31:225:112735.
BEHAVIORAL CHANGES: Children in Cincinnati Childhood Allergy and Air Pollution Study
(CCAAPS) assessed at age 12. Boys in particular did not experience significant anxiety or
depression, yet had somatic behaviors based on their childhood urinary fluoride (CUF)
concentrations, "seven times more likely to exhibit 'at-risk' internalizing symptomology."
https://pubmed.ncbi.nlm.nih.aov/34755609/
Adkins EA, Yolton K, Strawn JR, Lippert F, Ryan PH, Brunst KJ. Fluoride exposure during
early adolescence and its association with internalizing symptoms. Environ Res. 2021 Oct
29:112296.
CRITICAL WINDOWS: Using urine samples and test scores from 596 mother-child Canadian
pairs in the MIREC prospective cohort, researchers found evidence that developmental
neurological damage was based on timing of fluoride exposure and gender, "Associations
between fluoride exposure and PIQ (performance IQ) differed based on timing of exposure. The
prenatal window may be critical for boys, whereas infancy may be a critical window for girls."
https://pubmed.ncbi.nlm.nih.aov/34051202/
Farmus L, Till C, Green R, Hornung R, Martinez-Mier EA, Ayotte P, Muckle G, Lanphear B,
Flora D. Critical Windows of Fluoride Neurotoxicity in Canadian Children. Environ Res. 2021
May 26:111315.
GENES: Several genes make individuals more vulnerable to the neurotoxic impact with gender
differences, also affecting mitochondria and suggesting vulnerability to dementia. Chinese study
of 952 school children between 7 and 13 using water, urinary, hair and nail fluoride identified
multiple neurodevelopmental metabolic pathways that result in adverse effects from low fluoride
exposures. https://www.sciencedirect.com/science/article/pii/S0160412021003Q68
Yu X, Xia L, Zhang S, et al. Fluoride exposure and children's intelligence: Gene-environment
interaction based on SNP-set, gene and pathway analysis, using a case-control design
based on a cross-sectional study. Environ Int. 2021 Jun 4:155:106681.
GENETIC VULNERABILITY: Dopamine relative genes affect the susceptibility of individuals to
fluoride toxicity even in safe water concentrations which result in lowered IQ so that low-
moderate fluoride exposure is inversely related to children's IQ."
https://pubmed.ncbi.nlm.nih.aov/33360592/
Zhao L, Yu C, Lv J, et al. Fluoride exposure, dopamine relative gene polymorphism and
intelligence: A cross-sectional study in China. Ecotoxicology and Environmental Safety. 2021
Feb:209:111826.
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BRITTLE BONES: "In this cohort of postmenopausal women, the risk of fractures was
increased in association with two separate indicators of fluoride exposure. Our findings are
consistent with RCTs and suggest that high consumption of drinking water with a fluoride
concentration of -1 mg/L may increase both BMD (bone mineral density) and skeletal fragility in
older women." https://Dubmed.ncbi.nlm.nih.gov/33822648/
Helte E, Donat Vargas C, Kippler M, Wolk A, Michaelsson K, Akesson A. Fluoride in Drinking
Water, Diet, and Urine in Relation to Bone Mineral Density and Fracture Incidence in
Postmenopausal Women. Environ Health Perspect. 2021 Apr;129(4):47005.
OSTEOARTHRITIS: Identifies fluoride as an environmental chemical that has adverse effects
on articular cartilage and osteoarthritis (OA) risk. "In full sample analysis, a 1 mg/L increase in
UF (urinary fluoride) level was associated with a 27% higher risk of OA."
https://link.sprinaer.com/article/10.1007/s12011-021-Q2937-2
Sowanou, A., Meng, X., Zhong, N. et al. Association Between Osteoarthritis and Water
Fluoride Among Tongyu Residents, China, 2019: a Case-Control of Population-Based
Study. Biol Trace Elem Res (2021).
NO BENEFIT FOR PRESCHOOLERS: Polish study finds 'optimal' fluoride concentrations in
water provide no dental benefit. Dental caries experience depended on oral hygiene and diet.
https://www.sciencedirect.com/science/article/abs/pii/S0946672X2100Q16X
Opydo-Szymaczek J, et al. Fluoride exposure and factors affecting dental caries in
preschool children living in two areas with different natural levels of fluorides. Journal of
Trace Elements in Medicine and Biology. Volume 65. 2021.
ALTERNATIVE: This systematic review and meta-analysis concludes that biomimetic
hydroxyapatite-containing, fluoride-free oral care products are effective in reducing dental
decay, especially in children without the risk of dental fluorosis and neurotoxicity inherent in
topical use of fluoridated products, https://files.cdha.ca/profession/iournal/2752.pdf
Hardy Limeback, BSc, PhD, DDS; Joachim Enax, Dr; Frederic Meyer, Dr. Biomimetic
hydroxyapatite and caries prevention: a systematic review and meta-analysis. | Can J Dent
Hyg 2021:55(3): 148-159.
AMERICAN KIDNEYS: Using U.S. NHANES data from two recent cycles, finds 'optimal'
amounts of fluoridated water results in high incidence of uric acid in adolescents suggesting
higher risk of kidney disease and other illnesses. Identifies dose-response trend in plasma
fluoride of teens.
https://www.sciencedirect.com/science/article/pii/S0147651320315074
Yudan Wei, Jianmin Zhu, Sara Ann Wetzstein. Plasma and water fluoride levels and
hyperuricemia among adolescents: A cross-sectional study of a nationally representative
sample of the United States for 2013-2016. Ecotoxicology and Environmental Safety.
Volume 208. 15 January 2021.
TODDLERS: The Programming Research in Obesity, Growth, Environment and Social
Stressors (PROGRESS) cohort included 948 mother-child pairs from Mexico City. Blinded
testing of children between one and 24 months to examine associations between maternal
fluoride intake from food and beverages during pregnancy and offspring neurodevelopment in
this prospective and longitudinal study found, "higher exposure to fluoride from food and
beverage consumption in pregnancy was associated with reduced cognitive outcome, but not
with language and motor outcome in male offspring over the first two years of life."
https://fluoridealert.org/wp-content/uploads/cantoral-2021.final .pdf
Alejandra Cantoral, Martha M. Tellez-Rojo, Ashley J. Malin, Lourdes Schnaas d,
ErikaOsorio-Valencia, Adriana Mercadob, E. Angeles Martinez-Mier, Robert O. Wright,
Christine Till. Dietary fluoride intake during pregnancy and neurodevelopment in toddlers: A
prospective study in the progress cohort. Neurotoxicology 87 (2021) 86-93.
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NO SAFE DOSE: Study of Mexican children and their mothers using measurements of urinary
fluoride and water concentrations associated dental fluorosis and lowered IQ with fluoride dose
consistent with findings of larger studies in other countries. Authors declare WHO fluoride
guidelines are unsafe and hypothesize that 0.045 F- mg/day is a protective exposure
https://www. mdpi. com/1660-4601/18/21/11490/htm
Farias P, Estevez-Garcia JA, Onofre-Pardo EN, Perez-Humara ML, Rojas-Lima E, Alamo-
Hernandez U, Rocha-Amador DO. Fluoride Exposure through Different Drinking Water
Sources in a Contaminated Basin in Guanajuato, Mexico: A Deterministic Human Health
Risk Assessment. International Journal of Environmental Research and Public Health. 2021;
18(21): 11490.
BABY BRAIN POISON: Exposure to fluoridated water (10 mg/L & 50 mg/L) beginning on the
first day of pregnancy and continuing through the last day of breastfeeding shows chemical
imbalances, cellular damage and changes in the hippocampus of Wstar rat offspring that would
affect neurological development.
https://pubmed.ncbi.nlm.nih.gov/33096359/
Ferreira MKM, Aragao WAB, Bittencourt LO, Puty B, Dionizio A, Souza MPC, Buzalaf MAR,
de Oliveira EH, Crespo-Lopez ME, Lima RR. Fluoride exposure during pregnancy and
lactation triggers oxidative stress and molecular changes in hippocampus of offspring rats.
Ecotoxicology and Environmental Safety. 2021 Jan 15:208:111437.
BAD TEETH - BAD BRAIN: Chinese study confirm 1.6 ppm v. 0.1 ppm results in children with
both damaged teeth and lower IQ. Authors validate that fluoride affects thyroid function,
neurotransmitters and mitochondrial energy enzymes. There were no students with low IQ
found in the area with low F level. There was high IQ among the 96.6% of the students who did
not experience fluorosis.
https://www.sciencedirect.com/science/article/pii/S0213911121001965
Yani SI, Seweng A, Mallongi A, et al. The influence of fluoride in drinking water on the
incidence of fluorosis and intelligence of elementary school students in Palu City. Gac Sanit.
2021:35 Suppl 2:S159-S163.
GUTS & BRAINS: Memory function was reduced and gut microbiota structure was significantly
altered in fluoride-exposed mice.
https://www.sciencedirect.com/science/article/pii/S014765132100219Q
Xin J, Wang H, Sun N, Bughio S, Zeng D, Li L, Wang Y, Khalique A, Zeng Y, Pan K, Jing B,
Ma H, Bai Y, Ni X. Probiotic alleviate fluoride-induced memory impairment by reconstructing
gut microbiota in mice. Ecotoxicol Environ Saf. 2021 Jun 1:215:112108
INFLAMED GUTS: Exposure to fluoridated water at both doses (10 mg/L & 50 mg/L) inflame
guts in rats and alters the gut microbiome as compared to control (0 mg/L).
https://pubmed.ncbi.nlm.nih.gov/33508686/
Dionizio A, Uyghurturk DA, Melo CGS, Sabino-Arias IT, Araujo TT, Ventura TMS, Perles
JVCM, Zanoni JN, Den Besten P, Buzalaf MAR. Intestinal changes associated with fluoride
exposure in rats: Integrative morphological, proteomic and microbiome analyses.
Chemosphere. 2021 Jan 11:273:129607.
PUBERTY: Black girls consuming optimally fluoridated water have earlier menarche.
httPs://doi.org/10.1007/s 12403-021 -00448-v
Malin, A.J., Busgang, S.A., Garcia, J.C. et al. Fluoride Exposure and Age of Menarche:
Potential Differences Among Adolescent Girls and Women in the United States. Expo
Health (2021).
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HARMFUL ADEQUATE INTAKE (AI): Study found "the levels of dietary F- intake were below
the current AI, were greater towards the end of gestation and in women who were moderately
and highly compliant with Mexican dietary recommendation" in ELEMENT cohort and
recommended changing future dietary recommendations due to evidence of developmental
neurotoxicity at even low dose exposure, https://pubmed.ncbi.nlm.nih.gov/33602354/
Castiblanco-Rubio, G., Munoz-Rocha, T., Cantoral, A., Tellez-Rojo, M., Ettinger, A.,
Mercado-Garcia, A., Peterson, K.E., Hu, H., Martinez-Mier, E. (2021). Dietary Fluoride
Intake Over the Course of Pregnancy in Mexican Women. Public Health Nutrition, 1-25.
CALCIUM & FLUORIDE IN PREGNANCY: Calcium intake during pregnancy lowers urinary
fluoride (UF) concentrations by some unknown mechanism in ELEMENT cohort.
https://pubmed.ncbi.nlm.nih.gov/34176079/
Castiblanco-Rubio GA, Munoz-Rocha TV, Tellez-Rojo MM, Ettinger AS, Mercado-Garcia A,
Peterson KE, Hu H, Cantoral A, Martinez-Mier EA. Dietary Influences on Urinary Fluoride
over the Course of Pregnancy and at One-Year Postpartum. Biol Trace Elem Res. 2021 Jun
26.
SAFETY: Evidence of dental fluorosis and other adverse effects to bodies and brains from
supposed safe concentrations is alarming. "The safety of public health approach of drinking
water fluoridation for global dental caries reduction are urgently needed further research."
https://www.sciencedirect.com/science/article/pii/S014765132100551Q7via%3Dihub
Dong H, Yang X, Zhang S, Wang X, Guo C, Zhang X, Ma J, Niu P, Chen T. Associations of
low level of fluoride exposure with dental fluorosis among U.S. children and adolescents,
NHANES 2015-2016. Ecotoxicol Environ Saf. 2021 Jun 22:221:112439.
SKELETAL FLUOROSIS: This Chinese study of the pathogenetic progression of skeletal
fluorosis, details how local signaling pathways, hormones, promoter DNA hypermethylation,
RNA expression etc. are affected by fluoride exposure leading to pain and disability.
https://www.mdpi.com/1422-0067/22/21/11932/htm
Qiao L, Liu X, He Y, Zhang J, Huang H, Bian W, Chilufya MM, Zhao Y, Han J. Progress of
Signaling Pathways, Stress Pathways and Epigenetics in the Pathogenesis of Skeletal
Fluorosis. International Journal of Molecular Sciences. 2021: 22(21): 11932.
DEPRESSION: Animal study finds negative changes in brain structure and behavior with
exposure to sodium fluoride (NAF). https://pubmed.ncbi.nlm.nih.gov/34735150/
Zhou G, Hu Y, Wang A, Guo M, Du Y, Gong Y, Ding L, Feng Z, Hou X, Xu K, Yu F, Li Z, Ba Y.
Fluoride Stimulates Anxiety- and Depression-like Behaviors Associated with SIK2-CRTC1
Signaling Dysfunction. J Agric Food Chem. 2021 Nov 4. PMID: 34735150.
DECEPTION: This historical analysis documents how the ADA suppressed the established
science that vitamin D was necessary for healthy teeth and bones in order to promote falsely
fluoride which was and is more profitable for their membership. "Public health may well depend
on looking at professional societies no different than the way we look at the pharmaceutical
industryconflicted organizations with a power to shape conventional wisdom based on fragile
evidence." https://www.mdpi.eom/2072-6643/13/12/4361/htm#
Hujoel PE. How a Nutritional Deficiency Became Treated with Fluoride. Nutrients. 2021.
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2020
AMERICAN FETAL EXPOSURE: Study on pregnant women in California and Montana find,
"Fluoride concentrations in urine, serum, and amniotic fluid from women were positively
correlated to public records of community water fluoridation" and that concentration is consistent
with findings of Canadian studies that find these concentrations are associated with increased
learning disabilities and lower IQ in offspring.
https://www.ncbi.nlm.nih.aov/pmc/articles/PMC7132865/
Abduweli Uyghurturk D, Goin DE, Martinez-Mier EA, Woodruff TJ, DenBesten PK. Maternal
and fetal exposures to fluoride during mid-gestation among pregnant women in northern
California. Environ Health. 2020 Apr 6; 19(1 ):38.
BLOOD: Canadian Health Measures Survey (CHMS) collects extensive biomonitoring data
used to assess the exposure of Canadians to environmental chemicals finds higher fluoride in
urine associated with significantly higher blood lead, urinary lead, etc. Also finds urinary
selenium is significantly lower in fluoridated Canadian communities, "this is the first study where
biomonitoring data from multiple cycles of CHMS were combined in order to generate robust
estimates for subsets of the Canadian population. Such assessments can contribute to a
regional-level prioritization of control measures to reduce the exposure of Canadians to
chemicals in their environment."
htt£s://wyvw,ncbj^
Valcke M, Karthikeyan S, Walker M, Gagne M, Copes R, St-Amand A. Regional variations
in human chemical exposures in Canada: A case study using biomonitoring data from the
Canadian Health Measures Survey for the provinces of Quebec and Ontario. Int J Hyg
Environ Health. 2020 Jan 20:225:113451.
THYROID & IQ: Concentrations of fluoride in drinking water considered optimal and safe in the
US result in altered thyroid function and lowered IQ in Chinese children.
htt£s://wyvw,science^
Wang M, Liu L, Li H, et al.Thyroid function, intelligence, and low-moderate fluoride exposure
among Chinese school-age children. Environment International. Volume 134, January 2020.
OVERDOSED CANADIAN BABIES: MIREC study documents Canadian bottle-fed babies have
lower IQ in optimally fluoridated communities while breast fed babies have extremely low F and
significantly higher IQ. Mfi.s://www,Me.nc.e..d|.^
Till C, Green R, Flora D, Hornung R, Martinez-Miller EA, Blazer M, Farmus L, Ayotte P,
Muckle G, Lanphear B. Fluoride exposure from infant formula and child IQ in a Canadian
birth cohort. Environment International. 2020.
BIASED NARRATIVES: Canadian researchers comment on "expert" attacks on the high quality
studies that contradict the dental CWF narrative, i.e. political suppression of scientific facts.
htt£s://wyvw,n.aM
Till, C., Green, R. Controversy: The evolving science of fluoride: when new evidence doesn't
conform with existing beliefs. Pediatr Res (2020).
BONE HEALTH: Low to moderate fluoride exposure weakens and damages bones in women.
htt£s://wyvw,scienge^
Minghui Gao et al, Association between low-to-moderate fluoride exposure and bone
mineral density in Chinese adults: Non-negligible role of RUNX2 promoter methylation.
Ecotoxicology and Environmental Safety. Volume 203, 15 October 2020.
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BONES: Found an age-specific association between fluoride exposure and altered CALCA
methylation in adult women, affecting bone health, https://pubmed.ncbi.nlm.nih.gov/32283421/
Sun R, Zhou G, Liu L, Ren L, Xi Y, Zhu J, Huang H, Li Z, Li Y, Cheng X, Ba Y. Fluoride
exposure and CALCA methylation is associated with the bone mineral density of Chinese
women. Chemosphere. 2020 Aug:253:126616.
SEX HORMONES IN FLUORIDATED US: "The data indicated gender- and age-specific inverse
associations of fluoride in plasma and water with sex steroid hormones of total testosterone,
estradiol and SHBG in U.S. children and adolescents."
https://www.sciencedirect.com/science/article/pii/S0269749119357963
Bai, R., Huang, Y., Wang, F., & Guo, J. (2020). Associations of fluoride exposure with sex
steroid hormones among U.S. children and adolescents, NHANES 2013-2016.
Environmental Pollution, 114003
NERVOUS SYSTEM: The enteric nervous system (ENS) is called the second brain and governs
the gastrointestinal track. Includes dopamine & serotonin function. Study finds "fluoride
exposure during pregnancy and lactation might induce ENS developmental defects."
https://link.sprinaer.com/article/10.1007/s12011-020-Q2249-x
Sarwar, S., Quadri, J.A., Kumar, M. et al. Apoptotic and Degenerative Changes in the
Enteric Nervous System Following Exposure to Fluoride During Pre- and Post-natal Periods.
Biol Trace Elem Res (2020).
ENDOCRINE SYSTEM REVIEW: The endocrine system includes the pineal gland,
hypothalamus, pituitary gland, thyroid with parathyroid glands, thymus, pancreas (partial
endocrine function), adrenal glands, as well as male and female gonads (testes and ovaries)
which are adversely effected by exposure to fluoride.
https://www.sciencedirect.com/science/article/abs/pii/S00456535203176Q4
Marta Skorka-Majewicz et al, Effect of fluoride on endocrine tissues and their secretory
functions - review. Chemosphere, Volume 260, December 2020, 127565.
PINEAL GLAND & MELATONIN: Fluoride calcifies the pineal gland and interferes with enzyme
function, hormones and sleep patterns, https://www.mdpi.eom/2076-3417/10/8/2885
Dariusz Chlubek, Maciej Sikora. Fluoride and Pineal Glad. Applied Sciences. 22 April 2020.
WHO IGNORES KIDNEYS: WHO guidelines of safety below 1.5 ppm fluoride concentration is
wrong. "The available guidelines for drinking water are solely based on healthy populations with
normal renal function. But, it is evident that once the kidney function is impaired, patients enter a
vicious cycle as fluoride gradually accumulates in the body, further damaging the kidney tissue."
https://www.sciencedirect.com/science/article/abs/pii/S0045653520313795
Shanika Nanayakkara, et al. The Influence of fluoride on chronic kidney disease of uncertain
aetiology (CKDu) in Sri Lanka. Chemosphere. Volume 257, October 2020, 127186
PEDIATRIC BONE DISEASE: Identifies fluoride concentrations in water above 1.2 ppm as
"dangerously high" that can cause pediatric bone disease. Urine measurements of fluoride in
those afflicted are below the fluoride concentrations in women living in optimally fluoridated
communities per 2017 Canadian study by Green et al.
https://pubmed.ncbi.nlm.nih.gov/32692054/
Nipith Charoenngam, Muhammet B Cevik, Michael F Holick. Diagnosis and management of
pediatric metabolic bone diseases associated with skeletal fragility. Curr Opin Pediatr. 2020
Aug:32(4):560-573.
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EPA ON ENVIRONMENTAL STRESS: EPA authors find that exposure to fluoride has the
greatest adverse impact on cognitive ability in children, even more than lead.
https://www. mdpi. com/1660-4601/17/15/5451 /htm
Frances M. Nilsen, Jazmin D.C. Ruiz and Nicolle S. Tulve. A Meta-Analysis of Stressors
from the Total Environment Associated with Children's General Cognitive Ability. Int. J.
Environ. Res. Public Health 2020, 17(15), 5451.
SOURCE: Compared MIREC, ELEMENT & PROGRESS data. MIREC & ELEMENT differed
from PROGRESS in that "daily food and beverage fluoride intake was not associated with CUF
in PROGRESS" but study "found that CUF (child urinary fluoride) levels are comparable among
children in Mexico City and fluoridated Canadian communities, despite distinct sources of
exposure." https://pubmed.ncbi.nlm.nih.gov/33233802/
Green, R., Till, C., Cantoral Preciado, A. D. J., Lanphear, B., Angeles Martinez-Mier, E.,
Ayotte, P., Wright, R. O., Tellez-Rojo, M. M., & Malin, A. J. (2020). Associations between
urinary, dietary, and water fluoride concentrations among children in Mexico and Canada.
Toxics, 8(4), 1-11. [110].
SPERM MOTILITY: Animal study determines mechanisms how fluoride exposure lowers sperm
quality and male reproductive function, https://pubmed.ncbi.nlm.nih.gov/31901658/
Liang C, He Y, Liu Y, Gao Y, Han Y, Li X, Zhao Y, Wang J, Zhang J. Fluoride exposure alters
the ultra-structure of sperm flagellum via reducing key protein expressions in testis.
Chemosphere. 2020 May:246:125772.
DENTAL FLUOROSIS & CWF CESSATION: Dental literature review by dentists finds "a
significant decrease in the prevalence of fluorosis post cessation or reduction in the
concentration of fluoride added to the water supply."
https://pubmed.ncbi.nlm.nih.gov/32598322/
Nor Azlida Mohd Nor, Kuala Lumpur, Barbara L. Chadwick, Damian JJ. Farnell, Ivor G.
Chestnutt. The impact of stopping or reducing the level of fluoride in public water supplies on
dental fluorosis: a systematic review. Reviews on Environmental Health. 2020.
2019
SLEEP & PINEAL GLAND: "Chronic low-level fluoride exposure may contribute to changes in
sleep cycle regulation and sleep behaviors among older adolescents in the US."
httD.s://e.higu..rn.al^
Malin, A.J., Bose, S., Busgang, S.A. et al. Fluoride exposure and sleep patterns among
older adolescents in the United States: a cross-sectional study of NHANES 2015-2016.
Environ Health 18, 106 (2019)
ADHD: Youth in optimally fluoridated Canadian communities are almost 3 times more likely to
be diagnosed with ADHD and have significantly higher rates of other learning disabilities as
compared to their counterparts in non-fluoridated communities on a dose-response trend line.
htt£s://wyvw,scien.ce.^
Riddell JK, et al. Association of water fluoride and urinary fluoride concentrations with
attention deficit hyperactivity disorder in Canadian youth. Environment International. Volume
133, Part B, December 2019.
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ASD: Increased exposure to fluoride is associated with higher incidence of ASD in regions with
fluoridated water or endemic fluorosis. Based on biological plausibility and incidence, authors
hypothesize that increased fluoride exposure is an environmental risk factor for autism.
https://www. mdpi. com/1660-4601/16/18/3431 /htm
Strunecka A, Strunecky O. Chronic Fluoride Exposure and the Risk of Autism Spectrum
Disorder. Int. J. Environ. Res. Public Health 2019, 16(18), 3431.
PRENATAL: Three measurements in high quality NIH sponsored prospective cohort study
(MIREC) found significantly lowered IQ in offspring of mostly white, well-educated Canadian
women living in 'optimally' fluoridated communities.
https://iamanetwork.com/iournals/iamapediatrics/fullarticle/2748634
Green R, Lanphear B, Hornung R, etal. (2019) Association Between Maternal Fluoride
Exposure During Pregnancy and IQ Scores in Offspring in Canada. JAMA Pediatrics. 2019.
KIDNEY & LIVER: Researchers at Mt. Sinai Medical School find American teens in optimally
fluoridated American towns have markers for altered kidney & liver parameters that puts them at
higher risk for kidney & liver disease as adults. Notes the primary source of fluoride is water.
https://www.sciencedirect.com/science/article/pii/S01604120193Q9274
Malin AJ, Lesseur C, Busgang SA, Curtin P, Wright RO, Sanders AP. Fluoride exposure and
kidney and liver function among adolescents in the United States: NHANES, 2013-2016.
Environment International. August 8, 2019.
GUTS: Animal study on microbiome health and immunity documents fluoride causes serious
damage to rectal structure and significantly inhibits proliferation of rectal epithelial cells.
https://www.ncbi.nlm.nih.gov/pubmed/31885060/
Wang H., Miao C., Liu J. et al. Fluoride-induced rectal barrier damage and microflora
disorder in mice. Environ Sci Pollut Res (2019).
TEETH: An analysis of the dental fluorosis data in three U.S. NHANES reports noted that more
than half of American teens have fluoride damaged teeth as the result of too much fluoride
consumption during childhood. This results in costly cosmetic dentistry in young adulthood for
millions as well as increased decay in the more severely affected.
(20% very mild + 15% mild + 28% moderate + 3% severe = 65% afflicted per 2011-12 data)
http://fluoridealert.org/wp-content/uploads/neurath.2019-1.pdf
Neurath C, Limeback H, Osmunson Bm et al. (2019) Dental Fluorosis Trends in US Oral
Health Surveys: 1986 to 2012. JDR Clinical & Translational Research.
ALZHEIMER'S: Even low concentrations of fluoride in drinking water at or below concentrations
deemed optimal or safe by the WHO result in a pattern of increased dementia.
https://www.ncbi.nlm.nih.gov/pubmed/30868981
Russ TC, Killin LOJ, Hannah J, Batty GD. Aluminium and fluoride in drinking water in
relation to later dementia risk. The British Journal of Psychology. March 2019.
DNA DAMAGE: Mitochondrial dysfunction associated with dental fluorosis observed in Chinese
children with fluoride concentrations in water identified as optimal or safe per U.S. authorities.
Gender differences to the fluoride induced oxidative stress also noted.
https://www.sciencedirect.com/science/article/pii/S01604120183262917via%3Dihub
Zhou G, Yang L, Luo C, et al. Low-to-moderate fluoride exposure, relative mitochondrial
DNA levels, and dental fluorosis in Chinese children. Environment International. Volume
127, June 2019, Pages 70-77.
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DEMENTIA: Describes mechanism by which the effectiveness of the two most popular drugs
used to treat Alzheimer's & other neurodegenerative dementia disease is reduced or blocked by
fluoride, https://www.mdpi.eom/1660-4601/16/1/10/htm
Marta Goschorska, Izabela Gutowska, Irena Baranowska-Bosiacka, Katarzyna Piotrowska,
Emilia Metryka, Krzysztof Safranow, Dariusz Chublek. Influence of Acetylcholinesterase
Inhibitors Used in Alzheimer's Disease Treatment on the Activity of Antioxidant Enzymes
and the Concentration of Glutathione in THP-1 Macrophages under Fluoride-Induced
Oxidative Stress. Int. J. Environ. Res. Public Health, 2019, 16(1), 10.
ADULT BRAINS: First long term NaF animal study (10 weeks) using moderate levels of fluoride
finds a number of histological changes including in parts of the brain associated with memory
and learning. https://www.sciencedirect.com/science/article/pii/S0045653518317508
Pei Jiang, Gongying Li, Xueyuan Zhou, Changshui Wang, Yi Qiao, Dehua Liao, Dongmei
Shi. Chronic fluoride exposure induces neuronal apoptosis and impairs neurogenesis and
synaptic plasticity: Role of GSK-3b/b-catenin pathway.Chemosphere. Volume 214, January
2019, Pages 430-435.
DELAYED MALE PUBERTY: This 4th study from the NIH sponsored ELEMENT investigation of
the prenatal impact of low-dose prenatal exposure found a significant pattern of delayed puberty
for boys associated with maternal fluoride as measured in urine samples. Female data showed
non-significant trend towards earlier menarche. More study needed to determine the impact on
sexual development, https://www.ncbi.nlm.nih.gov/pubmed/30922319
Liu Y, Tellez-Rojo M, Hu H, et al. Fluoride exposure and pubertal development in children
living in Mexico City. Environ Health. 2019 Mar 29;18(1):26.
ANXIETY & DEPRESSION: Both rats and children experience changes in brain chemistry from
extended exposure to fluoride which affects mood. Serotonin and the prefrontal cortex are
impacted. Studies that only examine short-term exposure are inadequate to detect these
changes which are more pronounced in females.
https://www.sciencedirect.com/science/article/abs/pii/S0031938418309375
Lu F, Zhang Y, Trevedi A, et al. (2019) Fluoride related changes in behavioral outcomes may
relate to increased serotonin. Physiology & Behavior.
EYE DISEASE: Fluoride is a poison that has biological impact on consumers in any dose,
contributing to the development of cataracts, glaucoma and macular degeneration.
https://www. mdpi. com/1660-4601/16/5/856
Waugh DT. The Contribution of Fluoride to the Pathogenesis of Eye Diseases: Molecular
Mechanisms and Implications for Public Health. Int. J. Environ. Res. Public Health. 2019,
16(5), 856.
BONES & GENES: This 30 day animal study at 8 mg/L fluoride documents DNA & RNA
damage that inhibits gene expression which can be passed on through generations affecting
bone development and contributing to weak bones, blood & bone cancers and skeletal fluorosis.
https://www.sciencedirect.com/science/article/pii/S01476513183117347via%3Dihub
Atule P. Daiwile, Prashant Tarale, Saravanadevi Sivanesan, et al. Role of fluoride induced
epigenetic alterations in the development of skeletal fluorosis. Ecotoxicology and
Environmental Safety. Volume 169, March 2019, Pages 410-417.
BRAIN INJURY: Fluoride interferes with calcium metabolism which impacts brain chemistry and
poisons the hippocampus. "The imbalance of calcium metabolism caused by fluorosis may be a
pathogenesis of brain injury induced by fluoride."
https://www.sciencedirect.com/science/article/pii/S00456535183240Q7
Qiuli Yu, Dandan Shao. Rui Zhang, Wei Ouyang, Zigui Zhang. Effects of drinking water
fluorosis on L-type calcium channel of hippocampal neurons in mice. Chemosphere. Volume
220, April 2019, Pages 169-175. [Online Ahead of Print]
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BRAIN DAMAGE: Prenatal & postnatal animal experiment using 10, 50 and 100 mg/Lto
simulate human experience documents mitochondrial damage and neuronal death as
mechanism that result in learning and memory impairments.
https://www.ncbi.nlm.nih.gov/pubmed/30659323
Zhao, Q., Niu, Q., Chen, J. et al. Roles of mitochondrial fission inhibition in developmental
fluoride neurotoxicity: mechanisms of action in vitro and associations with cognition in rats
and children. Arch Toxicol (2019).
IODINE: Identifies and discusses the biochemical and hormonal impact of fluoride and
fluoridation policy on iodine metabolism with consideration of related neurodevelopmental and
pathological disorders, https://www.mdpi.eom/1660-4601/16/6/1086
Waugh DT. Fluoride Exposure Induces Inhibition of Sodium/Iodide Symporter (NIS)
Contributing to Impaired Iodine Absorption and Iodine Deficiency: Molecular Mechanisms of
Inhibition and Implications for Public Health. Int. J. Environ. Res. Public Health 2019, 16,
1086.
BIOLOGY OF POISON: Deep dive into the biological impact of fluoride that affects metabolism,
hormones, immune function, etc. "Moreover, the findings of this study further suggest that there
are windows of susceptibility over the life course where chronic F exposure in pregnancy and
early infancy may impair Na+ , K+ -ATPase activity with both short- and long-term implications
for disease and inequalities in health." https://www.mdpi.com/1660-4601/16/8/1427
Waugh DT. Fluoride Exposure Induces Inhibition of Sodium-and Potassium-Activated
Adenosine Triphosphatase (Na+, K+-ATPase) Enzyme Activity: Molecular Mechanisms and
Implications for Public Health. Int. J. Environ. Res. Public Health 2019, 16(8), 1427
DOSE RESPONSE: Three month study on adult rats found "fluoride can impair the learning
ability of rats, which may be related to the induction of autophagy in rat hippocampal neurons."
https://www.ncbi.nlm.nih.gov/pubmed/31111310
Zhang C, Huo S, Fan Y, Gao Y, Yang Y, Sun D. Autophagy May Be Involved in Fluoride-
Induced Learning Impairment in Rats. Biol Trace Elem Res. 2019 May 20.
GENETIC SUSCEPTIBILITY: Review of recent scientific literature on biological impact. Same
exposure in same population affect individuals differently, suggesting genetic vulnerability.
https://onlinelibrarv.wilev.com/doi/full/10.1111/icmm.14185
Wei, W, Pang, S, Sun, D. The pathogenesis of endemic fluorosis: Research progress in the
last 5 years. J Cell Mol Med. 2019: 23: 2333- 2342.
MITOCHONDRIA: Prenatal and postnatal exposure to fluoride results in mitochondrial
abnormalities, autophagy and apotheosis contributing to neuronal death.
https://www.NCBI.nlm.nih.gov/pubmed/30659323
Zhao, Q., Niu, Q., Chen, J. et al. Roles of mitochondrial fission inhibition in developmental
fluoride neurotoxicity: mechanisms of action in vitro and associations with cognition in rats
and children. Arch Toxicol (2019).
NUTRITION: The f-ion is a poison but the bioavailability of CaF is different than NaF as calcium
is the antidote to fluoride poisoning. In addition to being in water and dental products, 20% of
pharma and 40% of agrichemicals have a fluoride base. Consequently, people are exposed to
excessive amounts of fluoride which contributes to chronic disease.
https://iournals.matheo.si/index.php/ACSi/article/view/4932/2095
Stepec D, Ponikvar-Svet M. Fluoride in Human Health & Nutrition. Acta Chim Slov. 2019, 66.
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SYNERGY, SUSCEPTIBILITY & TSCA: Accurately identifying highly exposed groups and the
intrinsic and extrinsic factors that affect susceptibility require adequately assessing the
aggregate exposure among vulnerable groups. The 2016 Lautenberg update to the 1976 Toxic
Substance Control Act (TSCA) requires performing a challenging and scientifically disciplined
risk assessment that mitigates risk, such as calculating the impact of combined fluoride
exposure from fluoridated pesticides in food and fluoridated water on young children.
https://www.ncbi.nlm.nih.aov/labs/pmc/articles/PMC6715167/
Koman PD, Singla V, Lam J, Woodruff TJ. Population susceptibility: A vital consideration in
chemical risk evaluation under the Lautenberg Toxic Substances Control Act. PLoS Biol.
2019 Aug 29:17(8):e3000372.
2018
THYROID: 18% of people drinking 'optimally' fluoridated water in Canadian communities have a
heightened risk of low thyroid function because fluoride interferes with iodine metabolism. Many
of them will be sub-clinical and not know they are mildly hypothyroid, which nevertheless
increases their risk for diabetes, high cholesterol, and other problems. Study excluded those
already diagnosed with thyroid disease. (CHMS)
h.ttns:.//wvvw,science.d.i.^
Ashley J. Malin, Julia Riddell, Hugh McCague, Christine Till. Fluoride exposure and thyroid
function among adults living in Canada: Effect modification by iodine status. Environment
International. Volume 121, Part 1, December 2018, Pages 667-674.
THYROID: Even 0.5 ppm fluoride in water has an adverse impact on thyroid hormones. Water is
currently fluoridated to 0.7 ppm, a reduction from up to 1.2 ppm in 2015.
htt£s://wyvw,MG.B^
Z. Kheradpisheh et al. (2018) Impact of Drinking Water Fluoride on Human Thyroid Hormones: A
Case-Control Study. Scientific Reports, volume 8.
OVERDOSED BABIES: Over one third of babies (37%) in fluoridated American communities
consume amounts of fluoride in excess of the upper limits of fluoride considered safe per
government regulations. Even 4% of babies in non-fluoridated communities are overdosed on
fluoride due to consumption of products made with fluoridated water. At the very least, this puts
these children at high risk for developing dental fluorosis. Dental fluorosis is associated with
increased incidence of learning disabilities, broken bones and kidney disease.
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Claudia X Harriehausen, Fehmida Z Dosani, Brett T Chiquet, Michelle S Barratt, and Ryan L
Quock. Fluoride Intake of Infants from Formula. Journal of Clinical Pediatric Dentistry. 2018.
GOVERNMENT BIAS: A National Toxicology Program animal experiment studying the impact of
fluoride consumption used the wrong rats, the wrong dose, and the wrong study design in order
to manufacture a finding of no prenatal or postnatal effect.
h.ttfi.s://w\^j^
Karen Favazza Spencer, Hardy Limeback. Blood is Thicker Than Water: Flaws in a National
Toxicology Program Study. Medical Hypotheses. Volume 121. December 2018. Pages
160-163.
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PREGNANT WOMEN: Pregnant Canadian women drinking 'optimally' fluoridated water had
twice the fluoride exposure per individual testing as compared to pregnant women in non-
fluoridated Canadian communities - and consistent with the range in the Mexican women in the
ELEMENT cohort whose children had up to 6 points lowered IQ based on prenatal exposure to
fluoride (from salt). The Canadian study excluded those with health conditions such as kidney
disease as well as considered confounding factors such as tea consumption.
https://ehp.niehs.nih.qov/doi/pdf/10.1289/EHP3546
Christine Till, Rivka Green, John G. Grundy, Richard Hornung, Raichel Neufeld, E. Angeles
Martinez-Mier, Pierre Ayotte, Gina Muckle, and Bruce Lanphear. Community Water
Fluoridation and Urinary Fluoride Concentrations in a National Sample of Pregnant Women
in Canada. Environmental Health Perspectives. October 2018.
LEARNING DISABILITIES: Over 200 children were individually tested. Study found attention
deficit disorder apparently caused by their prenatal exposure to fluoride specific to dose. This is
the 3rd report out of the NIH sponsored 12 year ELEMENT project that has confirmed low dose
prenatal exposure to fluoride consistent with exposure in 'optimally' fluoridated communities
causes subtle but permanent brain damage for many consumers. Excluded those with history
of mental illness or conditions such as diabetes and renal disease.
https://www.sciencedirect.com/science/article/pii/S0160412018311814
Morteza Bashash, Maelle Marchand, Howard Hu, ChristineTill, Angeles Martinez-Mier, Brisa
N. Sanchez, Niladri Basu, Karen Peterson, Rivka Green, Lourdes Schnaas, Adriana
Mercado-Garcia, Mauricio Hernandez-Avila, Martha Maria Tellez-Rojo. Prenatal fluoride
exposure and attention deficit hyperactivity disorder (ADHD) symptoms in children at 6-
12 years of age in Mexico City. Environment International. Volume 121, Part 1, December
2018, Pages 658-666.
ALZHEIMER'S DISEASE: Describes impact of fluoride-induced stress and inflammation in the
development of Alzheimer's disease and demonstrates the mechanism for cell death in its
worsening over time. https://www.mdpi.com/1422-0067/19/12/3965
Goschorska M, et al. Potential Role of Fluoride in the Etiopathogenesis of Alzheimer's
Disease. Int. J. Mol. Sci. 2018, 19 (12), 3965.
CANCER: Researchers who include an IARC scientist find esophageal cancer is 9.4 times more
prevalent among those with dental fluorosis in the endemic fluorosis regions of Kenya. Provides
biological plausibility that inflammatory fluoride affects microbiome and other biological
mechanisms. Recommends more study, https://www.ncbi.nlm.nih.gov/pubmed/30582155/
Menya D, Maina SK, Kibosia C, Kigen N, Oduor M, Some F, Chumba D3, Ayuo P, Middleton
DR, Osano O, Abedi-Ardekani B, Schuz J, McCormack V. Dental fluorosis and oral health in
the African Esophageal Cancer Corridor: Findings from the Kenya ESCCAPE case-control
study and a pan-African perspective. Int J Cancer. 2018 Dec 23.
KIDNEYS: Fluoride is a common exposure that is selectively toxic to the kidneys.
https://www.sciencedirect.com/science/article/pii/S0270929518301827
Lash LH. Environmental and Genetic Factors Influencing Kidney Toxicity. Seminars in
Nephrology. Volume 39, Issue 2, March 2019, Pages 132-140.
IQ & DF: Between 0.5 and 3.9 mg/L, found every 0.1 mg/L increased dental fluorosis by 2.24%
and every 0.5 mg/L decreases IQ by 2.67 points. Also found half as many kids with high IQ
children with higher F- dose. https://www.NCBI.nlm.nih.gov/pubmed/29870912
Yu X et al. Threshold effects of moderately excessive fluoride exposure on children's health:
A potential association between dental fluorosis and loss of excellent intelligence. Environ
Int. 2018 Jun 2:118:116-124.
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WORSE THAN ARSENIC: "In conclusion, F exposure was related to the urinary excretion of
early kidney injury biomarkers, supporting the hypothesis of the nephrotoxic role of F exposure."
https://vwvw.sciencedirect.com/science/article/pii/S0041008X183Q2382
Monica I. Jimenez-Cordova, Mariana Cardenas-Gonzaleza, Guadalupe Aguilar-Madrid, Luz
C. Sanchez-Pena, Angel Barrera-Hernandez, Ivan A. Dominguez-Guerrero, Carmen
Gonzalez-Horta, Olivier C. Barbier, Luz M. Del Razo. Evaluation of kidney injury biomarkers
in an adult Mexican population environmentally exposed to fluoride and low arsenic levels.
Toxicology and Applied Pharmacology. May 2018.
KIDNEY CASCADE: "Taken together, these findings indicate that there can be some
alterations in liver enzyme activities at early stages of fluoride intoxication followed by renal
damage." https://pubmed.ncbi.nlm.nih.gov/29769014/
Perera T. et al. Effect of fluoride on major organs with the different time of exposure in rats.
Environmental Health and Preventive Medicine (2018) 23:17
2017
REVIEW: Concludes that fluoridation schemes whether from water, food or salt programs "pose
risks of various diseases in the asthmatic-skeletal, neurological, endocrine and skin systems.
Dental and skeletal fluorosis are signs of chronic and excessive ingestion of fluoride."
https://www.NCBI.nlm.nih.aov/pubmed/28453591
Verena Romero, Frances J. Norris, Juvenal A. Rfos, Isel Cortes, Andrea Gonzalez,
Leonardo Gaete, Andrei N. Tchernitchin. The impact of tap water fluoridation on human
health. Rev. med. Chile vol.145 no.2 Santiago Feb. 2017.
DOSE-RESPONSE: Validated that IQs of children are lowered on a dose-response trend line
correlated with the amount of fluoride exposure as measured via urine tests of their mothers
during pregnancy and individualized IQ tests of offspring. In the range consistent with doses in
optimally fluoridated communities, there was up to a 6 point difference in IQ. This NIH
sponsored 12 year longitudinal study conducted by researchers at world class American &
Canadian universities excluded diabetics as well as those with kidney disease or pregnancy
complications and allowed for many confounders.
httD.s://nu.te
Morteza Bashash, Deena Thomas, Howard Hu, et al. Prenatal Fluoride Exposure and
Cognitive Outcomes in Children at 4 and 6-12 Years of Age in Mexico. Environ Health
Perspect. Sept 2017. Vol 125, Issue 9.
GENES & BONES: "This study provides evidence that chronic oxidative and inflammatory
stress may be associated with the fluoride-induced impediment in osteoblast differentiation and
bone development." Mfi.:.//.!.i..nk,^
Gandhi, D., Naoghare, P.K., Bafana, A. et al. Fluoride-Induced Oxidative and Inflammatory
Stress in Osteosarcoma Cells: Does It Affect Bone Development Pathway? Biol Trace Elem
Res (2017) 175: 103.
PRESCHOOL DIET: Diet of two year olds contain unsafe levels of fluoride.
h.ttn://.o.n.l.ineJjba
Martinez-Mier EA, Spencer KL, Sanders BJ, Jones JE, Soto-Rojas AE, Tomlin AM, Vinson
LA, Weddell JA, and Eckert GJ. Fluoride in the diet of 2-years-old children. Community Dent
Oral Epidemiol. 2017:00:1-7.
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APOPTOSIS: "Enamel fluorosis is a developmental disturbance caused by intake of
supraoptimal levels of fluoride during early childhood.The enamel defects consist of horizontal
thin white lines, opacities (subsurface porosities), discolorations, and pits of various sizes. The
molecular mechanism underlying enamel fluorosis is still unknown We can hypothesize that
fluorosis is due to a combination of direct cytotoxic effects causing cell death, the delayed
development of tight junctions, which are necessary to form a sealed barrier between apical and
basolateral surfaces, and a direct inhibitory effect of fluoride on vectorial calcium and/or
bicarbonate transport." https://www.NCBI.nlm.nih.aov/Dmc/articles/PMC5770627/
Racz, Robert et al. "No Change in Bicarbonate Transport but Tight-Junction Formation Is
Delayed by Fluoride in a Novel Ameloblast Model." Frontiers in Physiology. 2017: 8: 940.
DNA: Finds that "prolonged fluoride intake at chosen concentrations caused imbalance of the
cellular oxidative state, affected DNA and disrupted cellular homeostasis... It is recommended
that fluoride supplementation requires a fresh consideration in light of the current study."
https://www.NCBI.nlm.nih.gov/Dubmed/28089781
F.D. Campos-Pereira, L. Lopes-Aguiar, F.L. Renosto, et al. Genotoxic effect and rat
hepatocyte death occurred after oxidative stress induction and antioxidant gene
downregulation caused by long term fluoride exposure. Chem Biol Interact. 2017 Feb
25:264:25-33.
PRENATAL POISON: "F can pass through the cord blood and breast milk and may have
deleterious impact on learning and memory of the mouse pups."
http://iournals.saaepub.eom/doi/abs/10.1177/0960327117693067
Y Zhang, X Xue, R Niu, J Wang. Maternal fluoride exposure during gestation and lactation
decreased learning and memory ability, and glutamate receptor mRNA expressions of
mouse pups. Z Sun, Human & Experimental Toxicology. February 13, 2017.
IMMUNITY: Prenatal and early postnatal exposure to fluoride impairs spleen function and
development which damages spleen and lifelong immunity.
https://www.NCBI.nlm.nih.gov/pubmed/28846973/
Yanqin Ma, Kankan Zhang, Fengjun Ren, Jundong Wang, Developmental fluoride exposure
influenced rat's splenic development and cell cycle via disruption of the ERK signal pathway,
In Chemosphere, Volume 187, 2017, Pages 173-180
NEUROINFLAMMATION: Toxic effects of fluoride on the central nervous system and immunity.
https://link.sprinaer.com/article/10.1007/s10753-017-Q556-v
Chen R, Zhao LD, Liu H. et al. Fluoride Induces Neuroinflammation and Alters Wnt
Signaling Pathway in BV2 Microglial Cells. Inflammation. 2017;40: 1123.
2016
CRITIQUE HHS RECOMMENDATION: Pro-fluoridation team of dental researchers determined
that the Department of Health and Human Services reduction of the optimal fluoride
concentration to a single 0.7 ppm target is lacking in sound science, i.e. that "policy need to be
cognizant of the balancing of risk and protective exposures across the entire population and
potentially all ages and to be based on recent data that are purposefully collected, critically
analyzed and carefully interpreted... (the recommendation seems) premature in terms of its
rationale and its use and interpretation of sometimes dated data." These authors' bias is to
maintain 1 ppm: nevertheless, their rationale against the HHS document is appropriate. The
HHS document is political, not scientific.
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Spencer AJ, Do LG. Caution needed in altering the 'optimum' fluoride concentration in
drinking water. Community Dent Oral Epidemiol. 2016 Apr;44(2):101-8.
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OSTEOPOROSIS: "Consequently, although the World Health Organization continues to support
F schemes for caries prevention despite a lack of scientific proof, the F schemes are not able to
improve the crystal quality but rather contribute adversely to affect tooth development and
increases the risk of developing postmenopausal osteoporosis."
http://dx.doi.ora/10.4172/2379-1764.1000170
Mitsuo Kakei, Masayoshi Yoshikawa and Hiroyuki Mishima. Fluoride Exposure May
Accelerate the Osteoporotic Change in Postmenopausal Women: Animal Model of Fluoride-
induced Osteoporosis. Adv Tech Biol Med 2016, 4:1
DIABETES: Fluoridation policy significantly increases incidence of age related type 2 diabetes.
https://www.NCBI.nlm.nih.gov/pubmed/27740551
K. Fluegge. Community water fluoridation predicts increase in age-adjusted incidence and
prevalence of diabetes in 22 states from 2005 and 2010. Journal of Water and Health, 2016.
IBD: Crohn's disease and ulcerative colitis increases after fluoridation begins in multiple
countries. http://www.NCBI.nlm.nih.gov/pubmed/27199224
Follin-Arbelet B, Mourn B. Fluoride: a risk factor for inflammatory bowel disease? Scand J
Gastroenterol. 2016 May 19:1-6.
PROPAGANDA: Assisted by the media, fluoridationists misrepresent historical and scientific
fact in order to achieve a political end. https://www.researchgate.net/publication/305985332
Anat Gesser-Edelsburg and Yaffa Shir-Raz. Communicating risk for issues that involve
'uncertainty bias': what can the Israeli case of water fluoridation teach us? Journal of Risk
Research. August 2016.
2015
COCHRANE CWF REVIEW: Estimates that 12% of the children living in fluoridated
communities with 0.7 ppm fluoridation have aesthetically objectionable dental fluorosis with a
total dental fluorosis effect of 40%. The effects were 47% & 15% for 1 ppm, only a minor impact
on incidence of dental fluorosis and consistent with the findings of the 2000 York Review.
http://www.cochrane.org/CD010856/QRAL water-fluoridation-to-prevent-tooth-decav
Iheozor-Ejiofor Z, Worthington HV, Walsh T, O'Malley L, Clarkson JE, Macey R, Alam R,
Tugwell P, Welch V, Glenny A. Water fluoridation for the prevention of dental caries.
Cochrane Database of Systematic Reviews 2015, Issue 6.
THYROID: Diagnoses of low thyroid significantly higher in 'optimally' fluoridated regions.
https://www.NCBI.nlm.nih.gov/pubmed/25714098
S Peckham, D Lowery, S Spencer. Are fluoride levels in drinking water associated with
hypothyroidism prevalence in England? A large observational study of GP practice data and
fluoride levels in drinking water. J Epidemiol Community Health. 24 February 2015.
ADHD: Researchers found between 67k and 131k more 11 year olds with ADHD in fluoridated
regions of the U.S.
http://www.ehiournal.net/content/pdf/s12940-015-0003-1.pdf
A Malin and C Till. Exposure to fluoridated water and attention deficit hyperactivity disorder
prevalence. Environmental Health 2015, 14:17
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CWF INFLAMMATIONS: Found that "even in small concentrations fluoride changes the
amounts and activity of COX-1 and COX-2 enzymes taking part in the initiating and
development of inflammatory process."
http://www.sciencedirect.com/science/article/Dii/S08872333150016Q5
I. Gutowskaa, et al. Fluoride as a factor initiating and potentiating inflammation in THP1
differentiated monocytes/macrophages. Toxicology in Vitro. Volume 29, Issue 7, October
2015, Pages 1661-1668.
NEUROTOXICANT: EPA scientists classify fluoride as a 'gold standard' developmental
neurotoxicant with substantial evidence of harm.
http://www.sciencedirect.com/science/article/pii/S089203621530Q362
William R. Mundy, Stephanie Padilla, Joseph M. Breier, at al. Expanding the test set:
Chemicals with potential to disrupt mammalian brain development. Neurotoxicology and
Teratology. Volume 52, Part A, November-December 2015, Pages 25-35.
PROPAGANDIZING: The proponents of fluoridation ignored concerning evidence and did not
deliver on their promise of dental benefit then, and now. Neither did they do the expected due
diligence re harms. https://doi.ora/10.2105/AJPH.2015.302660
Carstairs C. (2015). Debating Water Fluoridation Before Dr. Strangelove. American journal
of public health, 105(8), 1559-1569.
NOT COST EFFECTIVE: Reveals errors in cost-benefit analysis (CBA) used by CDC. Best
case scenario after corrections is a $3 benefit which is more than wiped out by any
consideration of dental fluorosis. Fluoridated drinking water results in an economic loss to
communities. http://www.NCBI.nlm.nih.gov/pubmed/25471729
Lee Ko & Kathleen M. Thiessen (2015) A critique of recent economic evaluations of
community water fluoridation, International Journal of Occupational and Environmental
Health, 21:2, 91-120
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Additional items of note:
2017 IAOMT Position Paper: https://iaomt.ora/iaomt-fluoride-position-oaper-2/
2018 Open Letter: http://www.multibriefs.com/briefs/icim/nutrition.pdf
2019 Children's Health Defense Statement: https://childrenshealthdefense.org/news/u-s-
water-fluoridation-a-forced-experiment-that-needs-to-end/
2020 Expert Opinion: httm://www,.ehn,o.^^^
"...fluoride is presumed to be a cognitive neurodevelopmental hazard to humans..."
- Draft Monograph from National Toxicology Program, "Systematic Review of Fluoride Exposure
and Neurodevelopmental and Cognitive Health Effects" (Sept 6, 2019)
"The cessation of all compulsory water fluoridation schemes should be the goal of all
public health agencies, ethical lawmakers, and informed citizens."
- Prof. Rita F. Barnett-Rose, J.D. in "Compulsory Water Fluoridation" (2014)
**************************
DEFINITIONS:
Endorsement: An endorsement is an authoritative statement reflecting a point of view
for the purpose of exerting influence. An endorsement is not an expert opinion.
Authoritative statement: An opinion that interprets a rule, law or policy for the
purpose of guiding, influencing, or mandating action. Authoritative statements are not
inherently trustworthy or reliable, but they are inherently manipulative. "Testimonial
propaganda" utilizes authoritative statements in marketing and in politics. The slogan
question authority" was intended to encourage critical thinking in order to combat
the blind acceptance of biased authoritative statements that endorse policy and/or
sanctioned narratives. (Logical Fallacies: Appeal to Authority)
Expert Opinion: An expert opinion is dependent on evidence and the due diligence of
someone with substantial study in a field. The Daubert Standard is a legal process that
validates the trustworthiness of experts offering opinion in a court of law.
EXAMPLES:
ENDORSEMENT: The April 2015 HHS statement recommending 0.7 ppm fluoride
concentration in drinking water for 'safe & effective' prevention of tooth decay promoted the
long standing fluoridation policy of the agency,
vs.
EXPERT OPINION: The June 2015 Cochrane report finds no reliable evidence of dental
benefit to adults or low income children, but documents substantially higher rates of
dental fluorosis, some of which will likely result in costly cosmetic dentistry.
The 2019 National Toxicology Program systematic review offered an expert opinion
based on the evidence that fluoride is a presumed hazard to human health
specific to neurotoxic impact when exposure is pre- or post-natal.
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July 6, 2022
Sent via email to:
Dr. Fred Jenkins
nejac@epa.gov
Re: Public Comment Regarding EPA Investments (EPA-HQ-OA-2022-0053)
Dear Dr. Jenkins:
I am pleased to provide this public comment on behalf of Companions and Animals for
Reform and Equity (CARE), a nonprofit organization committed to the interest of human
and animal well-being. At CARE, we prioritize and amplify BIPOC and other
marginalized voices using narratives, research, and community-centered investments.
As the nation's only known organization with a division dedicated to environmental
justice in the context of the human-animal relationship, we would like to thank the
National Environmental Justice Advisory Commission for the opportunity to provide
comments on the topic of EPA investments for addressing Environmental Justice.
Since Hurricane Katrina especially, an increased amount of attention has been
dedicated to understanding how addressing the needs of companion animals facilitates
greater access to critical services to those most likely to be impacted by environmental
harms and devastation. According to one poll, as many as 44 percent of people who
declined to evacuate during Katrina did so due to fear of abandoning their pets.1 In the
wake of this national disaster, the federal PETS Act was enacted, requiring that state
and local emergency preparedness operational plans address, at least minimally, the
needs of individuals with household pets and service animals following a major disaster
or emergency.2 Additionally, organizations such as the NAACP included animal
1 https://www.washingtonpost.com/news/animalia/wp/2017/08/31/how-the-chaos-of-hurricane-katrina-help
ed-save-pets-from-flooding-in-texas/.
2 Pub. L. 109-295, 120 Stat. 1355 (2006),
https://www.congress.gov/109/plaws/publ295/PLAW-109publ295.pdf.
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sheltering and services among the key factors to be considered when building equity in
emergency management.3
The importance of accounting for the presence of companion animals to facilitate
environmental justice extends beyond natural disasters. As highlighted in a recent Iowa
incident, an unhoused person was subjected to a lengthy prison sentence stemming
from his dog's heat related death last summer, after walking for approximately a mile to
find the animal food and water. Cooling shelters were reportedly not accepting
companion animals, causing both lives to be placed at risk.4 It has been noted that as
many as 24 percent of the 3.5 million people experiencing homelessness have pets.5
Many would rather refuse shelter and risk their lives in order to not be separated from
their beloved companions. As recently as last year, more than 60 percent of people
experiencing homelessness in San Francisco alone reported having a lack of access to
drinking water. Moreover, a Coalition on Homelessness report listed "water for pets" as
ranking among the top uses for water.6 Additionally, the COVID-19 emergency laid bare
many pre-existing inequities that are inherently connected to environmental justice.
According to one NIH-published study, study participants' most cited reason for delaying
healthcare was the lack of a concrete plan for pet care.7 Presumably, similar concerns
would be played out in the context of human health as it is impacted by everyday
circumstances that are exacerbated by climate change and other environmental harm.
The above examples illustrate only a small number of scenarios in which the difference
between receiving or being denied an environmentally just outcome depends upon the
shared well-being of an animal. As noted in the above referenced NAACP toolkit,
current "cost-benefit" analyses for disaster mitigation and prevention have been
inefficient and costly, with Congress spending "almost 500 times more on disaster
recovery than on actions to reduce or prevent disaster risks altogether."8 Fortunately,
evidence of more efficient and cost-effective policy efforts that adopt a holistic approach
are beginning to emerge. The California Pet Assistance and Support Program, which
provides up to $600,000 for homeless shelters seeking to reduce barriers to those
3 See In the Eye of the Storm Disaster Equity Toolkit,
https://naacp.ora/resoyrces/eve-storm-peoples-auide-transformina-crisis-advancina-eauitv-disaster-contin
uum. pp. 56, 66.
4https://www.desmoinesregister.com/restricted/?return=https%3A%2F%2Fwww.desmoinesregister.com%
2Fstory%2Fnews%2Fcrime-and-courts%2F2022%2F03%2F26%2Fhomeless-iowa-man-michael-beaver-
could nt-afford-vet-care-ill-dog-charged-animal-neglect%2F7026461001 %2F.
5https://todaysveterinarynurse.com/ethics-welfare/can-the-veterinary-community-help-homeless-people-ta
ke-care-of-their-pets/#:~:text=According%20to%20the%20National%20Coalition,a%20pig%2C%20ferrets
%20and%20reptiles.
6 https://www.cohsf.org/water-report-2021/.
7 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7543786/
ahttPs://naacp.ora/resources/eve-storm-peoples-auide-transformina-crisis-advancina-eauitv-disaster-conti
nuum, p. 93.
-------
experiencing homelessness with their pets, and the recently introduced federal
Providing for Unhoused People with Pets (PUPP) Act of 20229 are two such examples.
In light of the increasing threats to environmental justice, we urge NEJAC to seek every
opportunity to prioritize environmental justice investments into initiatives that make a
deliberate effort to consider the needs of people living with animals. Doing so may
mean the difference between life and death of those facing our most serious
environmental challenges. We thank you again for this opportunity to comment and
look forward to engaging in future forums.
Sincerely,
Akisha Townsend Eaton
Chief of Policy, Environmental Justice Division
akisha@careawo.ora
9 H.R. 8074, 117th Congress (2022),
https://www.govinfo.gov/content/pkg/BILLS-117hr8074ih/pdf/BILLS-117hr8074ih.pdf.
-------
Prepared Comments for NEJAC public meeting on June 22, 2022
Good afternoon, and greetings again from Tulsa, Oklahoma. I'm John Mueller, retired
engineer, mainly in water resources engineering, and with a degree in geophysical
engineering from the Colorado School of Mines. I am again presenting concerns
about water fluoridation. But before going any further, I want to acknowledge and
thank the NEJAC members for responding to these concerns presented during
previous NEJAC public meetings, by myself and others, and thank you, Matt Tejada,
for answering my questions in your NEJAC Community Engagement calls.
My comment today is largely spontaneous in response to Mr. Schafer's presentation
on PFAS and PFOA contamination. We all know, or should know, that the "F" in those
organic chemicals, is the fluoride atoms covalently bonded to the carbon atoms in
those compounds. What makes them the "forever chemicals" that they are, is the
strong bond which Wikipedia tells us is ".. one of the strongest single bonds in
chemistry .." and is "... the strongest in organic chemistry." One reason is that
fluorine has the strongest electronegativity, an attractive force, of any element in the
Periodic Table of the Elements. It's the same fluorine atom that helps give
prescription drugs like Prozac and Lipitor their efficacies. In its ionic form, it is
deliberately added to public water supplies, and is increasingly recognized by
emerging scientific studies as being harmful to human health, affecting some of the
same organs in our bodies as the PFAS and PFOA compounds, not only in
Environmental Justice communities, but harm to the developing brains of the unborn
fetus in pregnant mothers, of infants from formula reconstituted with fluoridated
water, and young children swallowing fluoridated toothpaste. Fluoride is a
developmental neurotoxicant, like lead, and is added as a medical treatment to help
prevent tooth decay, with no control of human exposure other than what is added to
the tap water miles upstream. It is unethical with no informed consent from those
who have no choice but to drink that water. Tooth decay can be prevented with
better diet and oral hygiene. Early brain damage is "a horse of a different color."
Accordingly, a specific NEJAC recommendation should include banning the deliberate
addition of any fluoride chemical compound to public water supplies.
I will be submitting additional materials prepared by experts, including highly
respected dentists. Thank you again for these unprecedented opportunities to
contribute to improving public health in this still greatest of nations.
-------
Environmental Data
& Governance Initiative
June 13, 2022
The Honorable Michael Regan
Administrator
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460
regan.michael@epa.gov
Re: Urgent Call on the Environmental Protection Agency to Not Sunset its Online
Archive
Dear Administrator Regan,
We write on behalf of the Environmental Data & Governance Initiative (EDGI) and the other
undersigned organizations to oppose EPA's apparent plan to sunset its online archive in
July 2022. While we understand that providing a public archive of many of the historical
resources currently in EPA's online archive is voluntary, the removal of this information
constitutes a backwards step in the agency's commitment to public trust, scientific integrity,
and environmental justice. It reduces the public's ability to access important information
about critical environmental issues, as well as past and present agency activities, policies,
and priorities.
In a healthy democracy, the public needs to be able to trust information disseminated by
its government. In the 21 st century, websites are a primary way that federal agencies
communicate with the public, and so the accuracy, accessibility, and transparency of
information on federal agency websites matters. It is alarming, then, that the EPA plans to
remove its online archive as this archive constitutes an important, albeit incomplete, public
record of the agency's positions and activities over the last 20+ years.
The EPA Archive is a Critical Public Resource
The online EPA archive is a critical public resource. It hosts digital resources dating back to
the 1990s, and these records allow for activities ranging from historical research to
-------
democratic oversight. There are documents discoverable through the archive that are not
available anywhere else, such as records of the authorization of various chemicals,
monitoring data from natural disasters, and resources regarding past or proposed policies.
Only through the EPA archive is it possible to trace public-facing EPA climate change
information over the course of the escalating crisis, from the Clinton-era "Global Warming"
website to the Obama-era "Climate Change" website.
Some resources in the archive are hosted in other repositories such as regulations.gov, but
are more easily discoverable through keyword searches in the EPA archive. For example,
the EPA archive is the most accessible source of information regarding the evolution of
regulations for key toxins, such as the Clean Air Mercury Rule and the Mercury and Air
Toxics Standards, as well as EPA's evolving approach to protecting wetlands.
The EPA archive also served as a critical source of information and lifeline for civic
engagement when informational resources were suppressed on the main EPA website
during the Trump administration and transferred to the archive, such as the Clean Power
Plan (CPP) resources in the months before the proposal to repeal the CPP. EDGI recently
used the archived CCP webpages that were suppressed in an educational workshop to
teach undergraduate students about the importance of federal website governance in a
participatory democracy.
While the EPA archive is far from perfect, it has facilitated public engagement and oversight
and could be updated to be a model of more transparent and effective website
governance. Moreover, maintaining and improving the archive would support the agency's
outspoken commitments to scientific integrity and environmental justice, both of which
pivot upon the agency's commitments to transparency, accessibility, and democratic
oversight.
The Decision Lacks Transparency
The decision to sunset the EPA archive is itself evidence of the need for more transparent
and effective governance of federal web resources. There were no public explanations or
commenting period regarding this decision, and the links to further information on the
"Web Standard: Archive" webpage are to URLs that deny access to the public (403 error).
Information requests by our organization remain unanswered.
In an article Verse, the EPA provides reasons supporting its decision to sunset its
archive. One is that the infrastructure on which the archive is built is outdated. We
-------
appreciate the diligence and the care provided in updating the main EPA website to a more
modern content management system, but it is unclear why the archive could not also be
updated. We recognize that the EPA is substantially underfunded at the moment, but it
would, at a minimum, be better to retain an archive based on outdated infrastructure than
to remove public access to these resources entirely. Additionally, in the Verge article the
EPA stated that official records removed from the archive would continue to be available
through the Freedom of Information Act process. While we appreciate the degree of
transparency the FOIA can provide, this process is by no means an open and accessible
one. FOIAs require a level of pre-existing knowledge that much of the public doesn't have (it
is challenging to file a FOIA for something you don't know exists), the arduous process of
filing and then processing materials received through FOIA requests is itself a barrier to
access, and the FOIA process has shortcomings when it comes to scientific materials in
particular, which are beyond the scope of this letter.
Overall, the lack of transparency in the decision to sunset the EPA's archive is at odds with
EPA's commitment to openness. This decision runs counter to the ethics and values
embraced by entities such as the Socie lean Archivists. Further, it leaves the
public and the federal government dependent upon third-party non-governmental
organizations that are not operating pursuant to federal data integrity and provenance
policies to provide public archives of federally published information. Sunsetting the EPA
archive does not appear to be in the best interest of the public nor the agency.
Improvements to the Archive
We understand that maintenance of a comprehensive archive of EPA's digital materials is
voluntary and entails some costs. Yet this needs to be considered alongside the agency's
commitment to public trust, scientific transparency, and environmental justice. Instead of
doing away with the EPA archive, the Biden administration should promote it as a model
for other parts of the Executive Branch.
In our digital age, agencies must make their documents and records quickly, thoroughly,
and durably accessible to the public. We need the EPA's archive to be improved, not retired.
It should link to archived historical content from the main website and to archived pages
from defunct URLs. The search function should be improved to retrieve relevant results
first and search within date ranges. Archiving material should be required, not
discretionary. Agencies' Title 44 obligations must be modernized for the 21st century, with
digital materials included alongside paper records, and EPA should coordinate its online
archive with the Government Publishing Office, Library of Congress, and the National
-------
Archives and Records Administration. Implementing these upgrades could facilitate
democratic oversight and the rebuilding of public trust in the agency, while removing the
archive undermines both. Thank you for considering our views.
Respectfully signed by the following organizations,
Council on Library and Information Resources
Environmental Data and Governance Initiative
FracTracker Alliance
Free Government Information
Government Accountability Project
Government Information Watch
Government Records Section Steering Committee, Society of American Archivists
Internet Archive
Lakehead University Archives
Metadata and Digital Objects Section, Society of American Archivists
Northwest Progressive Institute
Open The Government
Pratt Institute
Public Employees for Environmental Responsibility
Sierra Club
Southern Environmental Law Center
Southern Oregon University's Hannon Library
Texas State University Albert B. Alkek Library
The Digital Democracy Project
Union of Concerned Scientists
University of Southern California Libraries
Also please see this growing list of individuals and organizations who express their
agreement with the requests made in this letter: https://tinyurl.com/htzz5su5.
-------
IT
APT ION At- rofiM NO
UNITED STATES GOVKRNMKNT
Memorandum ^
Chief, Disease Control Branch H
to : Division of Dental date: January 10, 1962
Public Health and Resources
Refer to: DFR-DC
from : Sanitary Engineer Director
Division of Dental Public Health and Resources
subject: Optimum Fluoride Levels
Dr. Russell told me today that negroes in Grand Rapids had twice as
much fluorosis as others - (indio«we of 0.15 vs 0.35) In a coi
with a larger number of negroes (say in Del^b County Georgia) would
this tend to change our optimum fluoride levels? Would this obeervatin
indicate more studies in case opponents use this finding?
JJ%Y ' f
Yp%. Maier
-------
Ecotoxicology and Environmental Safety 221 (2021) 112439
ELSEVIER
Contents lists available at cienceDirect
Ecotoxicology and Environmental Safety
journal homepage: www.elsevier.com/locate/ecoenv
Associations of low level of fluoride exposure with dental fluorosis among
U.S. children and adolescents, NHANES 2015-2016
Haitao Dong3, Xin Yang , Shixuan Zhang , Xueting Wang , Chunlan Guo3, Xinyuan Zhang3,
Junxiang Ma , Piye Niu ' , Tian Chen1''
3 Department of Stomatology, Peking Union Medical College Hospital, Chinese Academy of Medical Sciences and Peking Union Medical College, Beijing 100730, China
b School of Public Health and Beijing Key Laboratory of Environmental Toxicology, Capital Medical University, Beijing 100069, China
%
Check for
updates
ARTICLE INFO
ABSTRACT
Edited by Dr. Caterina Faggio
Keywords:
Fluoride
Dental fluorosis
Tap water
Plasma
Drinking water fluoridation
Drinking water fluoridation was a mid-twentieth century innovation based on the medical hypothesis that
consuming low doses of fluoride at the teeth forming years provided protection against dental decays. Numerous
studies showed that high level exposure to fluoride could cause dental and skeleton fluorosis. However, there was
limited study focusing on the fluorosis effect of low levels of exposure to fluoride. Therefore, our study aimed to
examine whether the low level of fluoride exposure (measured in blood plasma and household tap water) was
associated with the risk of dental fluorosis based on data of the National Health and Nutrition Examination
Survey (NHANES) 2015-2016. We analyzed data in 2098 children and adolescents who had Dean's Index scores,
and water and plasma fluoride measures. The Dean's Index score was measured by calibrated dental examiners
using the modified Dean's fluorosis classification system. Fluoride was measured in plasma and household tap
water. In this study, we found that the rate of fluoride concentration in water above the recommended level of
0.7 mg/L was 25%, but the prevalence of dental fluorosis was 70%. Binary logistic regression adjusted for
covariates showed that higher water fluoride concentrations (0.31-0.50, 0.51-0.70, > 0.70 compared 0.00-0.30)
were associated with higher odds of dental fluorosis (OR = 1.48, 95% CI: 1.13-1.96, p = 0.005; OR = 1.92, 95%
CI: 1.44-2.58, p < 0.001, and OR = 2.30, 95% CI: 1.75-3.07, p < 0.001, respectively). The pattern of regression
between plasma fluoride and dental fluorosis was similar. Inclusion, our study showed that even low level of
water or plasma fluoride exposure was associated with increased the risk of dental fluorosis. The safety of public
health approach of drinking water fluoridation for global dental caries reduction are urgently needed further
research.
1. Introduction
Fluoride is the ionic form of the naturally occurring fluorine element.
People can consume adequate amounts of fluoride from fluoridated
water, foods and beverages, and toothpaste and other dental products
containing fluoride (Buzalaf, 2018; Levy et al., 2001). The anion in-
creases the structural stability of teeth and bones through interactions
with calcium phosphates (Bronckers et al., 2009). Oral exposure to
fluoride primarily via consumption of fluoridated water has been shown
to be associated with decreased prevalence of dental caries in children
Featherstone, 1999). In response to these findings, community water
fluoridation programs were developed to add fluoride to drinking water
for preventing tooth decay. In 1962, the U.S. Public Health Service
recommended fluoride concentrations in water of 0.7-1.2 mg/L to
prevent dental decay (U.S. Department of Health and Human Services
Federal Panel on Community Water Fluoridation, 2015).
Exposure to excessive fluoride levels can result in dental fluorosis,
characterized by increased porosity of the subsurface enamel and well
mineralized surface layer of the enamel. The water fluoride level of 2.0
mg/L is reported to be the threshold that can cause severe dental fluo-
rosis in U.S. children (Selwitz et al., 1998), whereas Rango et al. (2014)
found that the children barely had severe dental fluorosis with water
fluoride concentrations < 4.0 mg/L in Ethiopian. Although with
different thresholds of fluoride level for dental fluorosis, all these studies
have confirmed high fluoride exposure can cause dental fluorosis
(Ayoob and Gupta, 2006). However, the evidence on the potentially
harmful effects of chronic exposure to low level of fluoride on children's
dental development is relatively insufficient.
* Correspondence to: School of Public Health, Capital Medical University, Beijing 100069, China.
E-mail addresses: niupiye@ccmu.edu.cn (P. Niu), chentian@ccmu.edu.cn (T. Chen).
https://doi.Org/10.1016/j.ecoenv.2021.112439
Received 7 February 2021; Received in revised form 16 June 2021; Accepted 17 June 2021
Available online 22 June 2021
0147-6513/© 2021 The Authors. Published by Elsevier Inc. This is an open access article under the CC BY-NC-ND license
(http://creativecommons. ofg/licenses/by-nc-nd/4.0/).
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H. Dong et ol.
In many countries, small amounts of fluoride were added to drinking
water, salt, or milk to reduce incidence of tooth decay. In the U.S.,
fluoridation of public water supplies was started in 1945 (U.S. Depart-
ment of Health and Human Services Federal Panel on Community Water
Fluoridation, 2015). Recent years, studies showed that the prevalence of
dental fluorosis was increasing after water fluoridation programs
(Neurath et al., 2019; Wiener et al., 2018). A more recent analysis of
NHANES data in 200-2002 and 2011-2012 found that prevalence of
dental fluorosis increased from 29.7% to 61.3% (Wiener et al., 2018).
So, water fluoridation has become a controversial public health inter-
vention these years (Peckham and Awofeso, 2014; Spencer and Lime-
back, 2018). In order to minimize the unwanted effect caused by water
fluoridation, more research might be needed to reevaluate the current
policy on water fluoridation programs.
In the U.S., fluoridation is not required by the U.S. Environmental
Protection Agency (EPA), which is prohibited by the Safe Drinking
Water Act from requiring the addition of any substance to drinking
water for preventive health care purposes. The Centers for Disease
Control and Prevention (CDC), which is one of the major operating
components of HHS, provides recommendations about the optimal
levels of fluoride in drinking water. A large number of studies have re-
ported that adequate fluoride intakes can reduce the risk of dental de-
cays (Iheozor-Ejiofor et al., 2015; Slade et al., 2018), but more and more
studies showed that low level of fluoride exposure was also related with
some adverse effects, such as neurotoxic to children (Agalakova and
Nadei, 2020; Bai et al., 2020; Bashash et al., 2017; Malin et al., 2019a,b).
They showed that low level of fluoride exposure was related with
decreased IQ scores in children (Agalakova and Nadei, 2020). Another
study also reported fluoride from chronic systemic exposure accumu-
lates highly in the pineal gland, which might contribute to changes in
sleep cycle regulation and sleep behaviors (Malin et al., 2019a). Dental
fluorosis was the most common adverse effect caused by excessive
fluoride exposure, but the dose-effect relationship between low level of
fluoride and dental fluorosis were still unclear. Therefore, our study
aimed to examine whether the recommend fluoride exposure (measured
in blood plasma and household tap water) was still associated with
dental fluorosis. This study is helpful to understanding the adverse ef-
fects of fluoride exposure and balancing the benefits with any potential
risks.
2. Materials and methods
2.1. Participants
This study utilized data from the National Health and Nutrition Ex-
amination Survey (NHANES) collected from 2015 to 2016, which
included both dental fluorosis clinical assessment and fluoride bio-
monitoring data. The NHANES is conducted biennially to collect the
nationally representative sample by the Centers for Disease Control and
Prevention and designed to assess health and nutrition status of people
of all ages living in the U.S. Details of the NHANES research procedures
are available on the NHANES website (Centers for Disease Control and
Prevention, 2020). In the use of the data, we have completely followed
the "data use restrictions" (Centers for Disease Control and Prevention,
2021) and ensured the data only used for statistical analysis or reporting
purposes.
Dental fluorosis clinical assessment was assessed among 3478 par-
ticipants aged 6-29 years. Plasma fluoride concentrations were
measured among 2547 participants aged 6-19 years and tap water
fluoride concentrations were measured among 4070 participants aged
0-19 years. Our analysis included children and adolescents aged 6-19
years because these participants had both fluoride measurements and
dental fluorosis assessments. Our sample included participants who had
fluoride measurements, dental fluorosis assessment and complete data
for all covariates and outcomes. There were 2098 participants who met
inclusion criteria for analyses. Of those, 1808 participants had plasma
Ecotoxicology and Environmental Safety 221 (2021) 112439
fluoride levels and 2071 participants had water fluoride levels. Partici-
pant selection was depicted in Fig. SI. Supplemental Table SI compared
demographic characteristics of the current overall study sample (n =
2098) and all participants ages 6-19 over the same years (NHANES
2015-2016).
2.2. Dental fluorosis assessment
The dental fluorosis clinical assessment was conducted at the
NHANES mobile examination center (MEC) by dental examiners, who
were dentists (D.D.S. or D.M.D.) licensed in at least one U.S. state. Each
tooth was scored according to the Dean's Fluorosis Index (DFI) and
assigned one of the DFI disease severity categories, based on the area of
the tooth surface with visible fluorosis and presence of pitting (NHANES
Dental Examiners Procedures Manual, 2016). Six categories were used
for tooth assessment: normal (translucent, smooth, glossy, pale creamy
white, DFI = 0), questionable (slight aberrations, a few white spots, DFI
= 0.5), very mild fluorosis (less than 25% of tooth has small, white areas,
DFI = 1), mild fluorosis (between 25% and 50% of the tooth has white
areas, DFI = 2), moderate fluorosis (50% or more of the tooth with all
surfaces involved, with or without brown stains, DFI = 3), or severe
fluorosis (all enamel is involved and has discrete or confluent pitting,
DFI = 4) (NHANES Dental Examiners Procedures Manual, 2016).
Missing teeth, deciduous (primary) teeth, permanent teeth not fully
erupted, and teeth in which more than one-half of the visible surface
area was obscured by a restoration, caries, or orthodontic appliance
were not assessed. A tooth having a non-fluoride opacity was assessed as
non-fluoride opacity. The basis for classifying a person's fluorosis status
was the categorization of the two most affected teeth. The lesser affected
tooth was to be used to identify the person's status if the two most
affected teeth were not equally affected (NHANES Dental Examiners
Procedures Manual, 2016).
2.3. Plasma fluoride measures
Plasma fluoride levels were influenced by many factors, including
total fluoride intake, type of intake, renal function, rate of metabolism,
etc. Fluoride concentrations were measured in blood plasma samples
(Centers for Disease Control and Prevention, 2017b). Plasma samples
were processed, stored, and shipped to the College of Dental Medicine,
Georgia Regents University, Augusta, GA for analysis. The ion-specific
electrode and hexamethyldisiloxane (HMDS) method was used to mea-
sure the plasma fluoride concentrations. Plasma fluoride was measured
in duplicate using the same sample and the average of two results was
employed. The lower limit of detection (LLOD) for plasma fluoride was
0.25 nmol. Approximately 68.76% (1475/2145) of detected participants
in NHNES 2015-2016, had values at or above the LLOD for plasma
fluoride. For analytes with analytic results below LLOD, an imputed fill
value (0.18), which was the LLOD divided by the square root of 2, was
assigned in the analyte results field.
2.4. Water fluoride measures
Fluoride concentrations in water samples were measured electro-
metrically using the ion-specific electrode (Centers for Disease Control
and Prevention, 2017a). Water samples are processed, stored, and
shipped to the College of Dental Medicine, Georgia Regents University,
Augusta, GA for analysis. Water fluoride was measured in duplicate
using the same sample and the average of two results was employed. The
lower limit of detection (LLOD) for water fluoride was 0.1 mg/L.
Approximately 87.66% (3495/3987) of detected participants in NHNES
2015-2016, had values at or above the LLOD for water fluoride. For
analytes with analytic results below LLOD, an imputed fill value (0.07),
which was the LLOD divided by the square root of 2, was assigned in the
analyte results field.
2
-------
H. Dong et al.
2.5. Covariates
Covariates were determined according to the prior empirical evi-
dence associated with fluoride exposure and dental fluorosis. They
included: age, gender, body mass index, race/ethnicity, the ratio of
family income to poverty, and season of sample collection. Question-
naires were used to collect demographic of age (yrs.), sex (male, female),
race/ethnicity (Mexican American, other Hispanic, non-Hispanic White,
non-Hispanic Black, non-Hispanic Asian, other race), six-month time
period when surveyed (November 1 through April 30, May 1 through
October 31) and the ratio of family income to poverty. BMI and BMI
categories (underweight, normal weight, overweight, and obese) were
collected from body measure data.
2.6. Statistical analyses
Means and proportions were calculated for descriptive analyses of
demographic variables as well as fluoride exposure and dental fluorosis
measures. A Pearson correlation examined the relationship between
logarithm (base 10)-transformed plasma and water fluoride concentra-
tions. Dental fluorosis was identified according to DFI score, which was
defined no fluorosis (DFI < 0.5) and fluorosis (DFI > 1). To examine the
relationship between water fluoride exposure and dental fluorosis,
water fluoride (mg/L) levels was transformed into a 4-category variable,
which was: 0.00-0.30 (0 = reference level), 0.31-0.50 (1 = level 1),
0.51-0.70 (2 = level 2), and > 0.70 (3 = level 3). To examine the
relationship between plasma fluoride exposure and dental fluorosis,
plasma fluoride (|imol/L) levels was transformed into a 4-category
variable, which was: 0.00-0.30 (0 = reference level), 0.31-0.40 (1 =
level 1), 0.41-0.50 (2 = level 2), and > 0.50 (3 = level 3). Binary logistic
regression analyses were used to determine the association between
fluoride exposure and the occurrence of dental fluorosis, controlling for
age, sex, race/ethnicity, BMI categories, the ratio of family income to
poverty and six-month time period when surveyed. Data analysis was
conducted with r software (R version 4.0.2). The two-sided p values <
0.05 were statistically significant.
3. Results
3.1. Demographic characteristics
Demographic characteristics were presented in Table 1. Table SI
compared demographics between current study participants and all
participants aged 6-19 years in NHANES 2015-2016. The number of
overall group was 2098 with an average age of 12.19 years, including
1054 boys and 1044 girls. Among the 2098 participants, 1808 subjects
had plasma fluoride concentrations and 2071 had water fluoride con-
centrations. The proportions of subjects in variables including age cat-
egories, sex, BMI categories, race, six-month time period when surveyed,
were similar across overall group, plasma fluoride sample group, and
water fluoride sample group.
3.2. Fluoride levels
Descriptive statistics for water fluoride levels and plasma fluoride
levels were presented in Table 2. Geometric mean of household tap
water fluoride concentration was 0.33 mg/L, which was below the U.S.
Public Health Service recommended concentration of 0.7 mg/L (U.S.
Wafer Fluoridation, 2015). However, values between the 75th and 95th
percentiles were above this level ranging from 0.71 to 1.02 mg/L. The
water fluoride concentrations in males were comparable with those in
females, but fluoride levels in plasma in males were higher than those in
females (Table 2, Fig, S2). Both the water and plasma fluoride levels in
children were higher than those in adolescents (Table 2, Fig, S3).
Fluoride concentrations in plasma and tap water were light positively
Ecotoxicology and Environmental Safety 221 (2021) 112439
Table 1
Demographic characteristics of selected samples in NHANES 2015-2016.
Demographic
Overall
Plasma fluoride
Water fluoride
characteristic
sample n =
2098
sample n = 1808
sample n = 2071
Age (yrs.); mean (SD)
12.19(3.77)
12.37 (3.78)
12.18 (3.77)
Age categories; N (%)
Children (6-11 yrs.)
995 (47.43%)
819 (45.30%)
985 (47.56%)
Adolescents (12-19
1103
989 (54.70%)
1086 (52.44%)
yrs.)
(52.57%)
Sex; N (%)
Male
1054
(50.24%)
917 (50.72%)
1038 (50.12%)
Female
1044
(49.76%)
891 (49.28%)
1033 (49.88%)
BMI; mean (SD)
21.88 (6.02)
22.12 (6.13)
21.88 (6.02)
BMI Categories; N (%):
Underweight
57 (2.72%)
44 (2.43%)
56 (2.70%)
Normal Weight
1203
(57.34%)
1029 (56.91%)
1186 (57.27%)
Overweight
374 (17.83%)
328 (18.14%)
369 (17.82%)
Obese
464 (22.12%)
407 (22.51%)
460 (22.21%)
Race/ethnicity
Mexican American; N
456 (21.73%)
417 (23.1%)
451 (21.78%)
(%)
Other Hispanic
254 (12.11%)
232 (12.8%)
250 (12.07%)
Non-Hispanic White
612 (29.17%)
519 (28.7%)
601 (29.02%)
Non-Hispanic Black
461 (21.97%)
376 (20.8%)
457 (22.07%)
Non-Hispanic Asian
181 (8.63%)
158 (8.7%)
179 (8.64%)
Other Race-Including
134 (6.39%)
106 (5.9%)
133 (6.42%)
Multi-Racial
Ratio of family income to
2.06 (1.49)
2.03 (1.48)
2.05 (1.49)
poverty; mean (SD)
Six month time period
when surveyed
November 1 through
984 (46.90%)
851 (47.1%)
972 (46.93%)
April 30
May 1 through
1114
957 (52.9%)
1099 (53.07%)
October 31
(53.10%)
correlated (r = 0.41, p < 0.001), which presented in Fig, 1. The corre-
lation patterns in subgroups males and females were similar (Fig, S4).
3.3. Dental fluorosis
The proportion of dental fluorosis severity by different fluoride levels
in drinking water and plasma was presented in Tables 3 and 4. Gener-
ally, the proportion of participants had normal teeth was relatively low,
which was just 13%. Compared with the lowest fluoride level group,
severity of fluorosis increased with higher exposure to fluoride, although
there were a few exceptions. For example, those exposed to > 0.70 mg/L
of water fluoride had less severe fluorosis than those exposed to
0.00-0.30 mg/L (Table 4), which might just because the number of
participants with severe fluorosis was too less.
3.4. Regression analysis between fluoride levels and dental fluorosis
Regression results for fluoride levels and fluorosis were presented in
Table 5 and adjusted variables in the regression were presented in
Tables 84 and S5. Binary logistic regression adjusted for covariates
showed that higher water fluoride concentrations (0.31-0.50,
0.51-0.70, > 0.70 compared 0.00-0.30) were associated with higher
odds of dental fluorosis (OR = 1.48, 95% CI: 1.13-1.96, p = 0.005; OR =
1.92, 95% CI: 1.44-2.58, p < 0.001, and OR = 2.30, 95% CI: 1.75-3.07,
p < 0.001, respectively). The pattern of regression between plasma
fluoride and dental fluorosis was similar, which showed the higher
plasma fluoride concentrations (0.31-0.40, 0.41-0.50, > 0.50 compared
0.00-0.30) were associated with higher odds of dental fluorosis (OR =
1.49, 95% CI: 1.14-1.96, p = 0.004; OR = 1.61, 95% CI: 1.15-2.29,
p = 0.007, and OR = 1.64, 95% CI: 1.18-2.28, p = 0.003, respectively).
We also further explored regression analysis for fluoride levels and
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K Dong et al.
Ecotoxicology and Environmental Safety 221 (2021) 112439
Table 2
Descriptive statistics of fluoride exposure levels.
Measure Number Arithmetic mean (standard deviation) Geometric mean Median 5th percentile 25th percentile 75th percentile 95th percentile
Water fluoride (mg/L)
All
2071
0.46 (0.40)
0.33
0.44
0.07
0.16
0.70
1.02
Male
1038
0.48 (0.41)
0.33
0.44
0.07
0.16
0.70
1.04
Female
1033
0.47 (0.38)
0.33
0.44
0.07
0.17
0.69
1.00
Children
985
0.52(0.44)
0.36
0.47
0.07
0.18
0.72
1.12
Adolescents
1086
0.43(0.35)
0.31
0.37
0.07
0.15
0.68
0.86
asma fluoride
(nmol/L)
All
1808
0.35 (0.22)
0.31
0.30
0.18
0.18
0.41
0.71
Male
917
0.36 (0.19)
0.32
0.32
0.18
0.18
0.43
0.70
Female
891
0.34 (0.25)
0.29
0.29
0.18
0.18
0.39
0.71
Children
819
0.38 (0.24)
0.33
0.33
0.18
0.25
0.45
0.73
Adolescents
989
0.32 (0.20)
0.29
0.28
0.18
0.28
0.38
0.66
-2 -1 0 1
Log(water fluoride (mg/L))
Fig. 1. Pearson's correlations between log 10-transformed water fluoride and plasma fluoride (n = 2107).
R= 0.41 ,p< 2.2e-16
Table 3
Number and frequency (percent) of Dean's Index score for children aged 6-19 years in the 3 sample groups.
Fluorosis severity level
Normal (DFI = 0) Questionable (DFI = 0.5) Very mild (DEI = 1) Mild (DFI = 2) Moderate (DFI = ,3) Severe (DFI = 4)
©verall sample n = 2098 288(13,73) 348(16,59) 1223 (58,29) 202(9,63) J4 (1,62) 3(0.14)
Water fluoride sample n = 2071 285(13.76) 346(16.71) 1206(58.23) 197(9.51) 34(1.64) 3(0.14)
Plasma fluoride sample n = 1808 243(13,44) 297(16,43) 1054(58,30) 181 (10.01) -30(1.66) 3(0.17)
fluorosis by age (Table S2) and gender (Table S3). The patterns of
regression results in children (aged 6-11 years) and adolescents (aged
12-19 years) were similar, but the patterns in different gender were
changed. Higher plasma fluoride concentrations were associated with
higher odds of dental fluorosis in females, but the associations in male
groups were almost disappeared (Table S3).
4. Discussion
No fluoride deficiency disease had ever been documented for
humans. However, municipal fluoridation was a mid-twentieth century
innovation based on the medical hypothesis that consuming low doses of
fluoride at the teeth forming years provided protection against dental
decays. In this study, we found that the rate of fluoride concentration in
water above the recommended level of 0.7 mg/L was 25%, but the
prevalence of dental fluorosis was 70% in the NHANES 2015-2016
survey, which was higher than that in the previous 2010-2012 survey of
65% (Neurath et al., 2019). The rate of combined moderate and severe
degrees was relatively low with 1.8%. To accurately assess the impact of
low levels of fluoride exposure on children and adolescents, we selected
4
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H. Dong et al.
Ecotoxicology and Environmental Safety 221 (2021) 112439
Table 4
Number and distribution (percent) of fluorosis severity level by different fluoride levels in drinking water and plasma.
Fluorosis severity level
Normal (DFI = 0) Questionable (DFI = 0.5) Very Mild (DFI = 1) Mild (DFI = 2) Moderate (DFI = 3) Severe (DFI = 4) Total
Water fluoride (mg/L)
0.00-0.30
0.31-0.50
0.51-0.70
> 0.70
Total
Plasma fluoride (|imol/L)
0.00-0.30
0.31-0.40
0.41-0.50
> 0.50
Total
134 (15.46)
68 (19.21)
29 (7.83)
54 (11.25)
285 (13.76)
136 (14.66)
50 (12.38)
28 (12.73)
29 (11.33)
243 (13.44)
198 (22.84)
42 (11.86)
61 (16.49)
45 (9.38)
346 (16.71)
179 (19.29)
57 (14.11)
28 (12.73)
33 (12.89)
297 (16.43)
483 (55.71)
186 (52.54)
241 (65.14)
296 (61.67)
1206 (58.23)
533 (57.44)
247 (61.14)
131 (59.55)
143 (55.86)
1054 (58.30)
39 (4.50)
51 (14.41)
31(8.38)
76 (15.83)
197 (9.51)
65 (7.00)
45 (11.14)
27 (12.27)
44 (17.19)
181 (10.01)
11 (1.27)
7 (1.98)
7 (1.89)
9 (1.88)
34 (1.64)
14 (1.51)
4 (1.00)
5 (2.27)
7 (2.73)
30 (1.66)
2 (0.23)
0 (0.00)
1 (0.27)
0 (0.00)
3 (0.14)
1 (0.11)
1 (0.25)
1 (0.45)
0 (0.00)
3 (0.17)
867 (41.86)
354 (17.09)
370 (17.87)
480 (23.18)
928 (51.33)
404 (22.35)
220 (12.17)
256 (14.16)
Table 5
Associations between water fluoride, plasma fluoride and occurrence of dental
fluorosis/ ?
Fluoride levels n Fluorosis *
Odds ratio (95%CI) p-value
Water fluoride (mg/L)
0.00-0.30
867
Reference
0.31-0.50
354
1.48 (1.13-1.96)
0.005
0.51-0.70
370
1.92 (1.44-2.58)
< 0.001
> 0.70
480
2.30 (1.75-3.07)
< 0.001
Plasma fluoride (|imol/L)
0.00-0.30
928
Reference
0.31-0.40
404
1.49 (1.14-1.96)
0.004
0.41-0.50
220
1.61 (1.15-2.29)
0.007 !
> 0.50
256
1.64 (1.18-2.28)
0.003 '
p < 0.01.
a Fluorosis: 0 = No fluorosis (DFI < 0.5); 1 = Fluorosis (DFI > 1).
b Regression analyses were adjusted for age, sex, race/ethnicity, body mass
index categories, ratio of family income to poverty, and six month time period
when surveyed. The regression analysis was carried out separately for water
fluoride and plasma fluoride.
both water fluoride and plasma fluoride as external and internal expo-
sure indicators, respectively, and observed that the levels of both were
positively associated with the increased risk of dental fluorosis.
People of different ages have different excretion rates of fluoride. For
adults, about 50% of absorbed fluoride is retained, and stored in bones
and teeth. The other 50% is excreted in urine (VkkiZolioori and Mai
siand Duckworth, 2017). However, in young children, up to 80% of
absorbed fluoride is retained because of the more need for the devel-
opment of the body (Whitford, 1999). In our study, we found that the
concentration of plasma fluoride in children was higher than that in
adolescents, which could be contributed by the less excretion fluoride in
children. But there was a strange result that the water fluoride con-
centration in children was also higher than that in adolescents, which
also contributed the higher level of plasma fluoride in children. As more
and more researches had indicated that even low-to-moderate exposure
to fluoride was related to a number of adverse health effects in children,
such as neurotoxicity ( and Nadei, 2020; Gre 2019;
Spencer and Lii ), changes in sleep cycle ( et al,.,
2019a), alteration of kidney and liver function (Malin 319b),
et al. All these studies implicated that younger children were the sus-
pected population to fluoride. However, all people with different ages
were exposed to the same level of fluoride (0.7 mg/L) in drinking water
with the water fluoridation system. So, in order to against the adverse
effect by fluoride exposure in youngers, children should be provided
with alternative sources of drinking water.
In our study, the level of plasma fluoride in males was higher than
that in females, when the level of water fluoride was similar with each
other. The reasons for this were complex. One possible reason for this
might be that males might intake more fluoride from drinking water
than females, because males had more weight than females (p = 0.009,
showed in Fig, S5) and needed more water. Once absorbed, a portion of
fluoride was deposited in the skeleton and most of the remainder was
excreted in urine, and to a smaller degree in feces and sweat. Another
reason might be a differential excretion rate of fluoride between gen-
ders, which might cause different effects. In Green et al. study, they
reported that maternal exposure to higher levels of fluoride was asso-
ciated with lower IQ scores in boys but not significant in girls (Green
et al,., 2019). Zhou et al. (2019) also reported that gender potentially
modified the associations of dental prevalence with relative mitochon-
drial DNA levels, which showed a stronger inverse relationship between
dental fluorosis prevalence and relative mitochondrial DNA levels in
boys than in girls.
The main type of drinking water sources in U.S. was being mainly
from tap water. Previous analysis of NHANES 2005-2014 showed that
85% of the U.S. children and adolescents on average drunk tap water
(Sanders and Slade, 2018). In order to reduce the risk and severity of
dental caries of children, the U.S. Public Health Service had recom-
mended the addition of fluoride to drinking tap water since 1945, and
63.4% of the U.S. population had accessed to a fluoridated community
water system in 2018 (Centers for Disease Control and Prevention,
2018). So, there was easy to understand that fluoride concentrations in
plasma was correlated with that in tap water. But the correlation coef-
ficient was not high. One reason for this might be that only about 60% of
fluoride intake was from fluoridated drinking water (
)
In order to minimize the unwanted effect caused by water fluorida-
tion, we might need to reevaluate the current policy on national water
fluoridation program, which is overseed by the Department of Health
and Human Services (HHS). Water fluoridation had become a contro-
versial public health intervention these years (Peckiiam and Awoieso,
2014; Spencer and Linieback, 2018). Fluoridation was not required by
EPA, which was prohibited by the Safe Drinking Water Act from
requiring the addition of any substance to drinking water for preventive
health care purposes. As some areas of the country had high levels of
naturally occurring fluoride which could dissolve easily into ground
water as it moved through bedrock, EPA had a non-enforceable standard
for fluoride of 2.0 mg/L in drinking water to protect children against
dental fluorosis (https://www.ei *va/drinking-water
-regulations-and-contaniiiiants). As there were numerous studies sup-
ported that low level of fluoride consumption had been shown to be
associated with decreased prevalence of dental caries (Featherstone,
1999; iheozor-Ejiofor et al.,., 2015). In many countries, including the U.
S., small amounts of fluoride were added to drinking water, salt, or milk
to reduce the incidence of tooth decay. In the U.S., fluoridation of public
water supplies was started in 1945. The Centers for Disease Control and
Prevention (CDC), which is one of the major operating components of
5
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H. Dong et al.
HHS, provides recommendations about the optimal levels of fluoride in
drinking water. However, a large increase in prevalence of dental fluo-
rosis occurred among recent 30 years, which might relate with the
widespread use of fluoride toothpastes and dental treatments (Neurath
et al., 2019).
In our study, we observed that even low level of water or plasma
fluoride exposure was associated with increased the risk of dental
fluorosis. This result was consistent with a European review, which
concluded that water fluoridation was a crude and rather ineffective
policy to prevent dental caries without a detectable threshold for dental
damage (European Commission, 2011). Previous studies reported there
was a linear dose-response relationship between the serious of dental
fluorosis and fluoride intake, and indicated that dental fluorosis could
occur even at very low fluoride intake from water (Butler et al., 1985;
Fejerskov et al., 1996). In Peckham's review, the authors concluded that
available evidences suggested that fluoride had a potential to cause
major adverse human health problems, while having only a modest
dental caries prevention effect (Peckham and Awofeso, 2014). There-
fore, the intervention of drinking water fluoridation is really needed
further research.
Our study also had some limitations. Due to the cross-sectional
design, this study had less power in terms of the causal inference of
the associations between fluoride exposure and dental fluorosis. Sec-
ondly, the assessment of drinking water fluoride and plasma fluoride
might not be satisfactory in reflecting exposure level in the years when
the permanent teeth of the participants forming (birth to 8 years). As
fluoridated water policy have implemented since 1960s, to a certain
extent, we hypothesized that a single measurement of blood fluoride and
water fluoride reflected the level of long-term exposure. However, since
participants were enrolled during or after 2015, the year that the HHS
recommended lowering water fluoride concentrations from 0.7 to
I.2 mg/L to 0.7 mg/L to minimize the risk of dental fluorosis (Fluori-
dation 2015), the water fluoride concentrations during the years when
the permanent teeth of the participants forming might be higher than
those observed in this study. We also collected the water fluoride data in
the year of 2013-2014 from NHANES (Centers for Disease Control and
Prevention, 2020), and found that water fluoride concentrations were
reduced significantly after lowering the recommended water fluoride
concentration (Fig. S6). Thirdly, NHANES did not provide data on par-
ticipants' length of time at their current residence, thus we could not get
their duration of exposure to the water fluoride concentrations
measured in this study.
5. Conclusions
Low level of water or plasma fluoride exposure was associated with
increased risk of dental fluorosis. The safety of public health approach of
drinking water fluoridation for global dental caries reduction are ur-
gently needed further research.
CRediT authorship contribution statement
Haitao Dong: Conceptualization, Writing - original draft. Xin Yang:
Investigation, Software. Shixuan Zhang: Data curation, Resources.
Xueting Wang: Investigation. Chunlan Guo: Software. Xinyuan
Zhang: Methodology. Junxiang Ma: Data curation. Piye Niu: Project
administration. Tian Chen: Software, Writing - review & editing.
Declaration of Competing Interest
The authors declare that they have no known competing financial
interests or personal relationships that could have appeared to influence
the work reported in this paper.
Ecotoxicology and Environmental Safety 221 (2021) 112439
Acknowledgments
The study was supported by the Fundamental Research Funds for the
Central Universities (No. 3332019030), and Youth Program of Peking
Union Medical College Hospital Foundation (No. PUMCH 201910847),
the National Natural Science Foundation of China (81703198).
Appendix A. Supplementary material
Supplementary data associated with this article can be found in the
online version at doi:10.1016/j.ecoenv.2021.112439.
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Risk Analysis, Vol. 00, No. 0, 2021
DOI: 10.1111/risa.l3767
A Benchmark Dose Analysis for Maternal Pregnancy
Urine-Fluoride ami IQ in Children
Philippe (irandjean ,1,2'* Howard Hu,3 Christine Till' ^ »4 Rivka Green,4 Morteza Bashash,3
David Flora ' ' »4 Martha Maria Tellez-Rojo' ,5 Peter X.K. Song,6 Bruce Lanphear,7
and Esben Bndtz-Jargensen8
As a guide to establishing a safe exposure level for fluoride exposure in pregnancy, we applied
benchmark dose modeling to data from two prospective birth cohort studies. We included
mother-child pairs from the Early Life Exposures in Mexico to Environmental Toxicants
(ELEMENT) cohort in Mexico and the Maternal-Infant Research on Environmental Chem-
icals (MIREC) cohort in Canada. Maternal urinary fluoride concentrations (IJ-F, in mg/L,
creatinine-adjusted) were measured in urine samples obtained during pregnancy. Children
were assessed for intelligence quotient (IQ) at age 4 (n = 211) and between six and 12 years
(n = 287) in the ELEMENT cohort, and three to four years (n = 407) in the MIREC co-
hort. We calculated covariate-adjusted regression coefficients and their standard errors to
assess the association of maternal IJ-F concentrations with children's IQ measures. Assum-
ing a benchmark response of 1 IQ point, we derived benchmark concentrations (BMCs) and
benchmark concentration levels (BMCLs). No deviation from linearity was detected in the
dose-response relationships, but boys showed lower BMC values than girls. Using a linear
slope for the joint cohort data, the BMC for maternal IJ-F associated with a 1-point decrease
in IQ scores was 0.31 mg/L (BMCL, 0.19 mg/L) for the youngest boys and girls in the two
cohorts, and 0.33 mg/L (BMCL, 0.20 mg/L) for the MIREC cohort and the older ELEMENT
children. Thus, the joint data show a BMCL in terms of the adjusted IJ-F concentrations in
the pregnant women of approximately 0.2 mg/L. These results can be used to guide decisions
on preventing excess fluoride exposure in pregnant women.
KEY WORDS: Benchmark dose; cognitive deficits; fluoride; neurotoxicity; pregnancy; prenatal expo-
sure
1. INTRODUCTION
Department of Environmental Health, Harvard T.H. Chan
School of Public Health, Boston, MA, USA.
2Department of Public Health, University of Southern Denmark,
Odense, Denmark.
3Department of Preventive Medicine, Keck School of Medicine,
University of Southern California, Los Angeles, CA, USA.
4Faculty of Health, York University, Ontario, Canada.
5Centro de Investigacion en Salud Poblacional, Institute Nacional
de Salud Publica, Cuernavaca, Morelos, Mexico.
6Department of Biostatistics, School of Public Health, University
of Michigan, Ann Arbor, MI, USA.
'Faculty of Health Sciences, Simon Fraser University, British
Columbia, Canada.
The Environmental Protection Agency's maxi-
mum contaminant level goal (MCLG) of 4.0 mg/L
for fluoride in drinking water was first set in 1985
to protect against chronic fluoride toxicity in the
8Department of Biostatistics, University of Copenhagen, Den-
mark.
'Address correspondence to Philippe Grandjean, Environmental
Medicine, University of Southern Denmark, J.B. Winslows vej
17A, 5000 Odense C, Denmark; tel: +45 6550 3769; fax: +45 6591
1458; pgrandjean@health.sdu.dk
1
0272-4332/21/0100-0001$22.00/1 © 2021 Society for Risk Analysis
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2
Grandjean et al.
form of crippling skeletal fluorosis (U.S. Environ-
mental Protection Agency, 1985). In 2006, the U.S.
National Research Council (NRC) concluded that
fluoride may adversely affect the brain (National Re-
search Council, 2006). Since then, a substantial num-
ber of cross-sectional studies, mostly in communities
with chronic fluoride exposure, have shown lower
cognitive performance in children growing up in ar-
eas with higher fluoride concentrations in drinking
water, as summarized in meta-analyses (Choi et al.,
2015; Duan, Jiao, Chen, & Wang, 2018; Tang, Du,
Ma, Jiang, & Zhou, 2008). Support for fluoride neu-
rotoxicity has also emerged from experimental stud-
ies (Bartos et al., 2018; Mullenix, Denbesten, Schu-
nior, & Kernan, 1995; National Toxicology Program,
2020). Despite the existence of recent prospective
birth cohort studies (Bashash et al., 2017; Green
et al., 2019; Valdez Jimenez et al., 2017), no meta-
analysis has so far focused on prenatal fluoride
exposure.
Fluoride is found in many minerals, in soil and
thus also in groundwater (National Research Coun-
cil, 2006). Since the mid 1940s, fluoride has been
added to many drinking water supplies in order
to prevent tooth decay (U.S. Environmental Pro-
tection Agency, 1985). Community water fluorida-
tion is practiced in the United States, Canada, and
several other countries, whereas some, like Mex-
ico, add fluoride to table salt. Fluoridated water ac-
counts for about 40-70% of daily fluoride intake
in adolescents and adults living in these communi-
ties (U.S. Environmental Protection Agency, 2010).
The fluoride concentration in drinking water roughly
equals the fluoride concentration in urine (National
Research Council, 2006), as also recently shown
in the Canadian cohort of pregnant women (Till
et al., 2018). In addition to fluoridation, some types
of tea, such as black tea, constitute an additional
source of exposure (Krishnankutty et al., 2021; Ro-
driguez et al., 2020; Waugh, Godfrey, Limeback, &
Potter, 2017).
Fluoride is readily distributed throughout the
body, with bones and teeth as storage depots. During
pregnancy, fluoride crosses the placenta and reaches
the fetus (National Research Council, 2006; World
Health Organization, 2006). As fluoride is rapidly
eliminated via urine, the adjusted urine-fluoride (U-
F) concentration mainly represents recent absorp-
tion (Ekstrand & Ehrnebo, 1983; World Health
Organization, 2006). Pregnant women may show
lower U-F concentrations than nonpregnant controls,
perhaps due to fetal uptake and storage in hard
tissues (Opydo-Symaczek & Borysewicz-Lewicka,
2005).
For the purpose of identifying safe exposure
levels, regulatory agencies routinely use bench-
mark dose (BMD) calculations (European Food
Safety Authority, 2009; U.S. Environmental Protec-
tion Agency, 2012). As long recognized (National
Research Council, 1989), fluoride is not an essen-
tial nutrient, and dose-dependent toxicity can there-
fore be considered monotonic. As with lead (Budtz-
J0rgensen, Bellinger, Lanphear, & Grandjean, 2013),
BMD results can be generated from regression co-
efficients and their standard errors for the associa-
tion between maternal U-F concentrations and the
child's intelligence quotient IQ score (Grandjean,
2019). The BMD is the dose leading to a specific
change (denoted BMR) in the response (in this case,
an IQ loss), compared with unexposed children. A
decrease of 1 IQ point is an appropriate BMR, as
specified by the European Food Safety Authority and
also recognized by the U.S. EPA (Budtz-J0rgensen
et al., 2013; European Food Safety Authority, 2010;
Gould, 2009; Reuben et al., 2017). The present study
uses data from two prospective birth cohort studies
(Bashash et al., 2017; Green et al., 2019) to calcu-
late the benchmark concentration (BMCs) of U-F as-
sociated with a 1-point decrement in Full Scale IQ
(FSIQ).
2. METHODOLOGY
2.1. Study Cohorts
In the Early Life Exposures in Mexico to Envi-
ronmental Toxicants (ELEMENT) project, mother-
child pairs were successively enrolled in longitudinal
birth cohort studies from the same three hospitals
in Mexico City which serve low to moderate income
populations. A full description of the cohorts and
associated methods is provided in a recent "Cohort
Profile" article (Perng et al., 2019). Urinary samples
were collected from pregnant women between 1997
and 1999 (Cohort 2A, n = 327) and between 2001
and 2003 (Cohort 3 with calcium intervention and
placebo arms, n = 670). Cohort 2A was designed as
an observational birth cohort of lead toxicodynamics
during pregnancy, while Cohort 3 was designed as a
randomized double-blind placebo-controlled trial of
calcium supplements. Women were included in the
current study if they had at least one biobanked urine
sample for fluoride analysis, a urinary creatinine
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Benchmark Dose for Maternal Fluoride and IQ Loss
3
concentration, complete data of adjusted covariates,
and their child underwent cognitive testing at age
four years (n = 287) and/or between ages 6 and 12
years (n = 211). Of the 287 participants with data on
general cognitive index (GCI) outcomes and other
variables, 110 were from Cohort 2A, 93 were from
the Cohort 3 calcium intervention arm, and 84 were
from the Cohort 3 placebo arm. Among participant
in the GCI outcome, U-F data were available for all
three trimesters (n = 25), two trimesters (n = 121), or
one trimester (n = 141). Of the 211 participants with
data on IQ outcomes, 78 were recruited from Cohort
2A, 75 from the Cohort 3 calcium intervention arm,
and 58 from the placebo arm; U-F data for IQ out-
come were available for all three trimesters (n = 10),
two trimesters (n = 82), or one trimester (n = 119).
In the Maternal-Infant Research on Environ-
mental Chemicals (MIREC) program, 2,001 preg-
nant women were recruited between 2008 and 2011
from 10 cities across Canada. Women were recruited
from prenatal clinics if they were at least 18 years old,
less than 14 weeks of gestation, and spoke English or
French. Exclusion criteria included fetal abnormali-
ties, medical complications, and illicit drug use dur-
ing pregnancy; further details have been previously
described (Arbuckle et al., 2013). A subset of chil-
dren (n = 601) in the MIREC Study was evaluated
for the developmental phase of the study (MIREC-
Child Development Plus) at three-four years of age
from six of the 10 cities included in the original co-
hort, half of which were fluoridated. Of the 601 chil-
dren who completed the neurodevelopmental testing
in entirety, 526 (87.5%) mother-child pairs had all
three U-F samples; of these, 512 (85.2%) had specific
gravity measures, while 407 (67.7%) had creatinine
data, as well as complete covariate data; 75 (12.5%)
women were missing one or more trimester U-F sam-
ples, and 14 women (2.3%) were missing one or more
covariates.
2.2. Exposure Assessment
All urine samples from the two studies were an-
alyzed by the same laboratory at the Indiana Univer-
sity School of Dentistry using a modification of the
hexamethyldisiloxane (Sigma Chemical Co., USA)
microdiffusion method with the ion-selective elec-
trode (Martinez-Mier et al., 2011).
In the ELEMENT study, spot (second morning
void) urine samples were collected during the first
trimester (M ± SD: 13.7 ± 3.5 weeks for Cohort 2A
and 13.6 ± 2.1 weeks for Cohort 3), second trimester
(24.4 ± 2.9 weeks for Cohort 2A and 25.1 ± 2.3 weeks
for Cohort 3), and third trimester (35.0 ±1.8 weeks
for Cohort 2A and 33.9 ± 2.2 weeks for Cohort 3).
The samples were collected into fluoride-free con-
tainers and immediately frozen at the field site and
shipped and stored at -20 °C at the Harvard School
of Public Health, and then at -80 °C at the Univer-
sity of Michigan School of Public Health. To account
for variations in urinary dilution at time of mea-
surement, the maternal U-F concentration was ad-
justed for urinary creatinine, as previously described
(Thomas et al., 2016). An average of all available
creatinine-adjusted U-F concentrations during preg-
nancy (up to a maximum of three samples) was com-
puted and used as the exposure parameter.
In the MIREC study, urine spot samples were
collected at each trimester, that is, first trimester at
11.6 ± 1.6 (M ± SD) weeks of gestation, second
trimester at 19.1 ± 2.4 weeks, and third trimester at
33.1 ± 1.5 weeks. Maternal U-F concentrations at
each trimester were adjusted for both creatinine and
specific gravity, as described previously (Till et al.,
2020). For this joint analysis, however, we elected
to use the U-F concentrations adjusted for creati-
nine to keep the urine dilution factor consistent with
the adjustment procedure in ELEMENT. For each
woman, the average maternal U-F concentration was
derived only if a valid U-F value was available for
each trimester.
2.3. Assessment of Intelligence
The ELEMENT study (Bashash et al., 2017)
used the McCarthy Scales of Children's Abilities
(MSCA) Spanish version to measure cognitive abil-
ities at age four years and derive a GCI as a stan-
dardized composite score. The MSCA was adminis-
tered by trained psychometrists or psychologists who
were supervised by an experienced clinical child psy-
chologist. For children aged six-12 years, a Spanish-
version of the Wechsler Abbreviated Scale of Intel-
ligence (WASI) was administered to derive FSIQ as
a measure of global intellectual functioning. In the
MIREC study, children's intellectual abilities (Green
et al., 2019) were assessed at age three-four years us-
ing the FSIQ from the Wechsler Preschool and Pri-
mary Scale of Intelligence, Third Edition (WPPSI-
III). A trained research assistant who was supervised
by a psychologist administered the WPPSI-III in ei-
ther English or French. In both studies, examiners
were blinded to the children's fluoride exposure. All
raw scores were standardized for age.
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4
Grandjean et al.
The GCI shows concurrent validity with in-
telligence tests, including the Stanford-Binet IQ
(r = 0.81) and FSIQ (r = 0.71) from the Wechsler
Preschool and Primary Scale of Intelligence (WPPSI)
(Kaplan & Sacuzzo, 2010). Similarly, the FSIQ of the
WASI (ELEMENT cohort) and WISC-III (MIREC
cohort) is strong (r = 0.81) (Wechsler, 1991). The
high covariance between the various measures of in-
tellectual ability provides justification for pooling IQ
scores across the two cohorts.
2.4. Covariate Adjustment
For the ELEMENT study, data were collected
from each subject by questionnaire on relevant pa-
rameters, gestational age was estimated by registered
nurses, and maternal IQ was estimated using sub-
tests of the Wechsler scale standardized for Mexican
adults. Covariates included gestational age (weeks),
birth weight, sex, age at outcome measurement, and
the following maternal characteristics: parity (being
first child), smoking history (ever smoked vs. non-
smoker), marital status (married vs. other), age at de-
livery, IQ, education (years of education), and subco-
hort (Cohort 2A, Cohort 3 calcium intervention or
placebo).
The MIREC study selected similar covariates
from a set of established predictors of fluoride
metabolism and cognitive development, including
sex, city of residence, HOME score, maternal edu-
cation (dichotomized as bachelor's degree or higher:
yes/no), and maternal race/ethnicity (dichotomized
as white: yes/no). Covariates included in the original
studies (Bashash et al., 2017; Green et al., 2019) were
retained in the statistical calculations in the present
study. Due to a growing body of epidemiologic stud-
ies showing sex-specific effects associated with neu-
rotoxic exposures (Levin, Dow-Edwards, & Patisaul,
2021), including fluoride (Green et al., 2019; Green,
Rubenstein, Popoli, Capulong, & Till, 2020), interac-
tions between sex and U-F exposure were examined.
2.5. Benchmark Concentration Calculations
The BMC is the U-F concentration that re-
duces the outcome by a prespecified level (known
as the benchmark response, BMR) compared to
an unexposed control with the same covariate pro-
file (Budtz-J0rgensen, Keiding, & Grandjean, 2001;
Crump, 1995). We based the benchmark calculations
on regression models with p covariates in the follow-
ing form:
IQ = "o + "l x covariatei H |-ap x covariatep
+ /(c) + e
where c is the urine-fluoride concentration and /
is the concentration-response function, and e is a
normally distributed error term with a mean of
0 (and a variance of a2). To assess the linearity
of the concentration-response relationship, several
models were considered. In addition to the stan-
dard linear model, where /(c) = /3c, we estimated a
squared effect, where/(c) = /3c2, and two piecewise-
linear models (or broken-stick) with breakpoints
at 0.5 and 0.75 mg/L. Piecewise-linear models are
useful in benchmark calculations because the slope
of the concentration-response function is allowed
to change linearity at the breakpoint, and in such
models, benchmark calculations are less sensitive to
exposure-associated effects occurring only at high
concentration levels. Furthermore, to allow for the
possibility of different exposure effects in boys and
girls, each concentration-response model was also fit-
ted with the inclusion of an interaction with sex.
Models were fitted separately in the two co-
horts yielding analyses that were similar to those pre-
sented in the original publications (Bashash et al.,
2017; Green et al., 2019) based on the original raw
data and with the covariate adjustments as originally
justified. Sensitivity analyses were carried out using
the MIREC specific gravity-adjusted U-F values joint
with the ELEMENT creatinine-adjusted U-F values
as well. The Mexico study controlled for maternal
bone lead stores (the primary source of prenatal lead
exposure in this cohort) and blood-mercury during
pregnancy, although the sample size was reduced by
about one-third; the effect estimates for fluoride on
child IQ increased and remained statistically signifi-
cant (p < 0.01) (Bashash et al., 2017). Similarly, con-
trolling for lead, mercury, perfluorinated compound,
arsenic, and manganese in the MIREC study did not
result in any appreciable change of the U-F estimates
(Green et al., 2019). Thus, these other neurotoxicants
were not included as covariates in the present cal-
culations. Using the regression coefficients, we first
calculated BMC results for each cohort and then
derived joint BMCs by combining regression coeffi-
cients from the two cohorts.
Given that the BMC reduces the outcome by the
BMR, a smaller BMR will result in lower BMC and
benchmark concentration level (BMCL) results. For
the child IQ as the outcome variable, the BMR is
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Benchmark Dose for Maternal Fluoride and IQ Loss
5
1 IQ point. In our regression model, the IQ differ-
ence between unexposed subjects and subjects at the
BMC is given by /(0) - /(BMC), and therefore the
BMC satisfies the equation /(0) - /(BMC) = BMR.
We use concentration-response functions with /(0) =
0, and therefore the BMC is given by
BMC = f-1 (-BMR)
In a regression model with a linear
concentration-response function [/(c) = /3c], we get
BMC = -BMR//S. If the estimated concentration-
response is increasing (indicating a beneficial effect),
the BMC is not defined, and the BMC is then
indicated by oo.
The main result of the BMC analysis is the
BMCL, which is defined as a lower one-sided 95%
confidence limit of the BMC (Crump, 1995). In the
linear model,
BMCL = -BMR/Aower
where /Siower is the one-sided lower 95% confidence
limit for (Budtz-J0rgensen et al., 2013). In the other
models considered, we calculated the BMCL by first
identifying a lower confidence limit for/(c) and then
finding the concentration (c) where confidence limit
is equal to -BMR.
Finally, we derived two sets of joint benchmark
concentrations: The MIREC results (FSIQ score)
were combined with ELEMENT outcomes using ei-
ther GCI or FSIQ scores for all subjects where the
creatinine-adjusted U-F was available. Joint bench-
mark concentration results were obtained under the
hypothesis that the concentration-response functions
were identical in the two studies. Under this hy-
pothesis, the concentration-response function [/(c)]
was estimated by combining the regression coeffi-
cients describing/(c). Again, using the linear model
as an example, we estimated the joint regression
coefficient by weighing together cohort-specific co-
efficients. Here we used optimal weights propor-
tional to the inverse of the squared standard error.
In a Wald test, we tested whether the exposure ef-
fects in the two cohorts were equal. We calculated
sex-dependent BMC results from regression mod-
els that included interaction terms between sex and
f(c). The fit of the regression models was compared
by twice the negative log-likelihood [-2 logL] as
supplemented by the Akaike Information Criterion
(AIC); the latter is provided in the tables. For both
measures, a lower value indicates a better fit, but
AlC-based differences below four are not consid-
ered important. For sex-dependent results, the AIC
value for both boys and girls represents the fit of
a model that includes an interaction between sex
and exposure. As the linear model is nested in the
piecewise linear model, the fit of these two models
can be directly compared. Thus, we calculated the
p-value for the hypothesis that the concentration-
response is linear in a test where the alternative was
the piecewise linear model. Here a low p-value in-
dicates that the linear model has a poorer fit. As
specific-gravity adjusted U-F values were available
for an additional 105 MIREC subjects, we carried out
sensitivity analyses using these data jointly with EL-
EMENT'S creatinine-adjusted data.
3. RESULTS
Table 1 shows the regression coefficients ob-
tained from the two outcomes (GCI and IQ score)
in the ELEMENT study and the IQ score in the
MIREC study. As previously reported (Bashash
et al., 2017; Green et al., 2019), maternal U-F ex-
posure predicts significantly lower IQ scores in boys
and girls in the ELEMENT cohort, while it does not
show a statistically significant association for boys
and girls combined in the MIREC cohort. However,
for the linear association, the difference between the
two studies is not statistically significant and the com-
bined data show highly significant U-F regression co-
efficients (Table 1). A sensitivity analysis using the
larger number of observations with specific-gravity
adjusted U-F did not show significant differences be-
tween the two cohort studies and yielded joint U-F
effects that were significant.
Table 2 shows the BMC results obtained from
the regression coefficients for each sex and for both
sexes. The BMC and BMCL are presented for the
MIREC study, the ELEMENT (GCI and IQ) study,
and combined across the two cohorts. The AIC re-
sults did not reveal any important differences be-
tween the model fits, except that the linear slope
appeared superior to the squared for the joint re-
sults that included the Mexican GCI data. For the
linear models, the joint BMCL in terms of U-
F (creatinine-adjusted) is approximately equal for
the MIREC-ELEMENT IQ model (0.20 mg/L) and
MIREC-ELEMENT GCI model (0.19 mg/L). Sim-
ilarly, for the squared models, the joint BMCL in
terms of U-F is approximately equal for the MIREC-
ELEMENT IQ model (0.77 mg/L) and MIREC-
ELEMENT GCI model (0.81 mg/L). When using the
larger number of specific gravity-adjusted U-F results
from the MIREC cohort, the joint analysis with the
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6
Grandjean et al.
Table 1. Regression Coefficients Adjusted for Confounders for the Change in the Outcome, for Boys and Girls Combined, at an Increase
by 1 mg/L in Creatinine-Adjusted Maternal Urine Fluoride Concentration for IQ in the MIREC Study, GCI (Upper Rows) and IQ (Lower
Rows) in the ELEMENT study, and a Joint Calculation. The Column to the Right (pdiff) Shows thep-Value for a Hypothesis of Identical
Regressions in the two studies. Two Concentration-Response Models are Used, a Linear and one with the Squared Exposure Variable
MIREC ELEMENT Joint MIREC-ELEMENT
model beta p beta p beta p
Linear
Squared
Linear
Squared
FSIQ (n = 407)
-2.01
-0.419
FSIQ (n = 407)
-2.01
-0.419
0.16
0.40
0.16
0.40
GCI (n = 287)
-6.29
-2.68
IQ (n = 211)
-5.00
-2.65
0.007
0.02
0.01
0.002
-3.20
-0.780
-3.07
-0.998
0.008
0.09
0.01
0.023
0.12
0.07
0.22
0.025
Fig 1. Association between creatinine-
adjusted maternal urinary-fluoride (U-
F) concentration in pregnancy and
child IQ loss for the larger num-
ber of children (joint for GCI in
ELEMENT and MIREC). Covariate-
adjusted models are shown for the lin-
ear (solid), squared (dotted), and piece-
wise (dashed) linear curve with break-
point 0.75 mg/L. The BMC is the U-
F concentration that corresponds to an
IQ loss of 1 (numbers shown in Tables 2
and 3).
ELEMENT data yielded results that were very close
to those shown in Table 2, that is, with BMC values of
about 0.19 mg/L for the linear model and about 0.63
mg/L for the squared model (data not shown).
Linear models allowing for sex-dependent ef-
fects showed a slightly better fit in the AIC mainly
due to the significant interaction terms in the MIREC
cohort. Although the BMCL in the MIREC co-
hort is clearly higher in girls than boys (0.61 vs.
0.13 mg/L), the overall BMCL for both sexes in the
MIREC cohort (0.23 mg/L) is closer to the one for
boys than the one for girls (Table 2). Sex-linked
differences were not significant in the ELEMENT
study.
Table 3 shows results using piecewise linear func-
tions, with one breakpoint at 0.75 mg/L and one at 0.5
mg/L. A piecewise linear model is more flexible than
a linear model, but AIC results showed that the joint
piecewise linear models in Table 3 did not fit bet-
ter than the standard linear models in Table 2. Thus,
the hypothesis of a linear concentration-response re-
lation could not be rejected: for the joint MIREC-
ELEMENT IQ model, /7-values for likelihood test-
ing were p = 0.18 and p = 0.15 when the linear
model was tested against models using breakpoints of
0.5 and 0.75 mg/L, respectively. For the joint MIREC-
ELEMENT GCI model, the corresponding /7-values
were p = 0.83 and p = 0.48.
The shapes of the linear, the squared, and one
piecewise concentration-response curves are shown
in Fig. 1. In accordance with the BMC values, the
Fig. shows that the squared model has a weaker slope
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Table 2. Benchmark Concentration Results (mg/L Urinary Fluoride, Creatinine-Adjusted) for a BMR of 1IQ Point Obtained from the MIREC Study and the Two Cognitive
Assessments from the ELEMENT Study as Well as the Joint Results. Two Concentration-Response Models are used, a Linear and One with the Squared Exposure Variable. For
both Models, Sex-Specific and joint benchmark Results are Provided. The fit of the Regression models was Compared by the AIC (Where Lower Values Indicate a Better Fit)
Study
Model
Sex
MIREC (n
= 407)
ELEMENT IQ
(n = 211)
ELEMENT GCI
(n = 287)
MIREC and
ELEMENT IQ
(n = 618)
MIREC and
ELEMENT GCI
(n = 694)
BMC
BMCL
BMC
BMCL
BMC
BMCL
BMC
BMCL
AIC
BMC
BMCL
AIC
Linear
Both
0.497
0.228
0.200
0.122
0.159
0.099
0.326
0.201
4770.1
0.312
0.192
5491.3
Linear
Boys
0.201
0.125
0.275
0.130
0.148
0.084
0.222
0.144
4766.7
0.184
0.125
5488.4
Linear
Girls
oo
0.609
0.160
0.091
0.169
0.087
1.098
0.275
4766.7
2.972
0.315
5488.4
Squared
Both
1.545
0.896
0.614
0.496
0.611
0.467
1.008
0.768
4768.8
1.133
0.807
5493.9
Squared
Boys
0.840
0.622
0.684
0.496
0.581
0.435
0.787
0.619
4769.4
0.761
0.601
5493.7
Squared
Girls
oo
1.262
0.576
0.449
0.642
0.434
1.637
0.866
4769.4
oo
1.040
5493.7
ea
s
n
a-
3
as
**
7?
o
o
rD
o5
as
rD
=
as
=
o
S-*
c
as
=
a.
r
o
Abbreviations: AIC, Akaike Information Criterion; BMC, benchmark concentration; BMCL, benchmark concentration level; BMR, benchmark response; GCI, Global Cognitive
Index; IQ, Intelligence Quotient.
Table 3. Benchmark Concentration (BMC) Results (mg/L Urinary Fluoride, Creatinine-Adjusted) for a BMR of 1 IQ Point Obtained from the MIREC Study and the Two
Cognitive Assessments from the ELEMENT study as well as the Joint Results. Two Piecewise Linear Concentration-Response Models (with Urinary Fluoride Breakpoints at 0.5
and 0.75 mg/L) are used. For both Models, Sex-Dependent and Joint Benchmark results are Provided. The fit of the Regression Models was Compared by the AIC (Where Lower
Values Indicate a Better Fit)
Study
Sex
MIREC (n
= 407)
ELEMENT IQ
(n = 211)
ELEMENT GCI
(n = 287)
MIREC and
ELEMENT IQ
(n = 618)
MIREC and
ELEMENT GCI
(n = 694)
BMC
BMCL
BMC
BMCL
BMC
BMCL
BMC
BMCL
AIC
BMC
BMCL
AIC
Breakpoint 0.5
Both
1.751
0.092
2.688
0.431
1.004
0.042
1.073
0.139
4770.6
0.788
0.104
5495.0
Breakpoint 0.5
Boys
0.086
0.040
2.953
0.135
0.725
0.011
0.156
0.053
4766.7
0.087
0.040
5493.9
Breakpoint 0.5
Girls
oo
0.309
2.363
0.024
1.144
0.046
2.913
0.428
4766.7
3.817
0.385
5493.9
Breakpoint 0.75
Both
0.166
0.081
1.283
0.149
0.115
0.050
0.284
0.112
4769.8
0.150
0.083
5493.8
Breakpoint 0.75
Boys
0.082
0.049
1.379
0.121
0.127
0.035
0.136
0.070
4769.4
0.086
0.052
5493.6
Breakpoint 0.75
Girls
oo
0.125
1.155
0.052
0.109
0.044
1.365
0.140
4769.4
0.413
0.106
5493.6
Abbreviations: AIC, Akaike Information Criterion; BMC, benchmark concentration; BMCL, benchmark concentration level; BMR, benchmark response; GCI, Global Cognitive
Index; IQ, Intelligence Quotient.
<1
-------
8
Grandjean et al.
at low concentrations, while the low-concentration
slope for the piece-wise association is steeper.
4. DISCUSSION
Experimental and cross-sectional epidemiology
studies have provided evidence of fluoride neuro-
toxicity, especially when the exposure occurs during
early brain development (Grandjean, 2019). As early
as 2006, sufficient evidence was available to warrant
further consideration of the possible brain toxicity
of fluoride exposure with an emphasis on vulnera-
ble populations (National Research Council, 2006).
We now have thorough prospective epidemiology ev-
idence on populations exposed to fluoridated water
(about 0.7 mg/L) or comparable exposure from flu-
oridated salt and other sources. The present study
is based on data from two prospective birth cohort
studies (Bashash et al., 2017; Green et al., 2019) that
include detailed assessment of child IQ and urinary
fluoride concentrations during pregnancy. In these
two studies, the mean U-F concentration (creatinine-
adjusted) was similar among pregnant women living
in Mexico City (0.89 mg/L) and the pregnant women
living in fluoridated cities in Canada (0.84 mg/L).
Due to the brain's continued vulnerability across
early development (Grandjean, 2013), early infancy
may also be a vulnerable period of exposure for ad-
verse effects from fluoride, especially among bottle-
fed infants who receive formula reconstituted with
fluoridated water (Till et al., 2019). Still, the effects
of fetal exposure (i.e., U-F in pregnancy) in the
MIREC Study remained significant when adjusting
for exposure occurring in infancy. Similarly, in the
ELEMENT study, the effect of maternal U-F was
only marginally reduced after controlling for child U-
F; fluoride exposure in school-age children showed
a weaker and nonstatistically significant association
with child IQ (Bashash et al., 2017). Taken together,
these findings suggest that fetal brain development is
highly vulnerable to fluoride exposure.
The magnitude of the fluoride-associated IQ
losses is in accordance with findings in cross-sectional
studies carried out in communities where the chil-
dren examined had likely been exposed to chronic
water-fluoride concentrations throughout develop-
ment (Choi, Sun, Zhang, & Grandjean, 2012). More
recent studies have shown similar results (Wang
et al., 2020; Yu et al., 2018), and benchmark dose cal-
culations (Hirzy, Connett, Xiang, Spittle, & Kennedy,
2016) relying on a large cross-sectional study (Xiang
et al., 2003) showed results on the linear association
similar to the ones obtained in the current analysis.
These findings provide additional evidence that flu-
oride is a developmental neurotoxicant (i.e., causing
adverse effects on brain development in early life).
Given the ubiquity of fluoride exposure, the popula-
tion impact of adverse effects from fluoride may be
even greater than for other toxic elements like lead,
mercury, and arsenic (Nilsen et al. 2020). Adverse
effects of the latter trace elements are associated
with blood concentrations that are about 100-fold
lower than the serum-fluoride concentration that cor-
responds to the benchmark concentration (Grand-
jean, 2019).
A few retrospective studies have been carried
out in communities with elevated fluoride expo-
sure, though with imprecise exposure assessment
that mostly relied on proxy variables, and with-
out prenatal fluoride measurements (Aggeborn &
Ohman, 2017; Broadbent et al., 2015). In addition
to IQ outcome studies, the ELEMENT cohort found
that elevated maternal U-F concentrations were as-
sociated with higher scores on inattention on the
Conners' Rating Scale, an indication of Attention-
Deficit/Hyperactivity Disorder (ADHD) behaviors
(Bashash et al., 2018). Other studies on attention out-
comes found an association between water fluorida-
tion and diagnosis of ADHD in Canada, although
data on child U-F did not replicate this association
(Riddell, Malin, Flora, McCague, & Till, 2019), which
is consistent with the ELEMENT study of child U-
F and IQ (Bashash et al., 2017). Similarly, increased
risk of ADHD was reported to be associated with wa-
ter fluoridation at the state level in the United States
(Malin & Till, 2015), although inclusion of mean ele-
vation at the residence as a covariate made the asso-
ciation nonsignificant (Perrott, 2018).
Individual vulnerability may play a role in fluo-
ride neurotoxicity. In the original MIREC study, boys
were more vulnerable to prenatal fluoride neurotox-
icity than girls (Green et al., 2019) suggesting that
sex-dependent endocrine disruption may play a role
(Bergman et al., 2013), among other sex-differential
possibilities. Genetic predisposition to fluoride neu-
rotoxicity may also exist (Cui et al., 2018; Zhang
et al., 2015), but has so far not been verified. Other
predisposing factors, such as iodine deficiency (Ma-
lin, Riddell, McCague, & Till, 2018) may contribute.
For such reasons, regulatory agencies routinely use
an uncertainty factor to derive safe exposure levels
that are lower than the BMCL.
Both prospective studies adjusted for a sub-
stantial number of cofactors. Prenatal and early
-------
Benchmark Dose for Maternal Fluoride and IQ Loss
9
postnatal lead exposure did not influence the EL-
EMENT fluoride-associated IQ deficits (Bashash
et al., 2017). Adjustment for other neurotoxicants or
risk factors, such as arsenic and lead exposure, did
not appreciably change the estimates in the MIREC
study (Green et al., 2019). While BMC results were
calculated for the creatinine-adjusted U-F available
from both studies, U-F results adjusted for specific-
gravity were available for an additional 105 MIREC
women; if using the latter U-F data, slightly lower
BMC results were obtained, as compared to those
based on creatinine-adjusted data only. Higher re-
sults were obtained for the squared, and lower for the
broken linear slopes, but neither showed a superior
fit to the data when compared to the linear relation-
ship between maternal U-F and child IQ.
The increased precision using the average ma-
ternal U-F concentration as an indicator of prenatal
fluoride exposure results in stronger statistical evi-
dence of fluoride-associated deficits, compared with
using cross-sectional or retrospective studies. Still,
the amount of fluoride that reaches the brain during
early brain development is unknown, and even the
maternal U-F concentration measurements may be
considered somewhat imprecise as dose indicators.
Such imprecision, likely occurring at random, will
tend to underestimate fluoride neurotoxicity (Grand-
jean & Budtz-J0rgensen, 2010).
The prospective studies offer strong evidence
of prenatal neurotoxicity, and the benchmark re-
sults should inspire a revision of water-fluoride rec-
ommendations aimed at protecting pregnant women
and young children. While systemic fluoride expo-
sure has been linked to dental health benefits in
early studies (Iheozor-Ejiofor et al., 2015), these ben-
efits occur in the oral cavity after teeth have erupted
(Featherstone, 2000), thus suggesting that use of
fluoridated toothpaste and other topical treatment
should be considered for alternative caries preven-
tion.
5. CONCLUSIONS
Two prospective studies examined
concentration-dependent cognitive deficits asso-
ciated with the maternal U-F during pregnancy; one
of the studies (Bashash et al., 2017 measured child
IQ at two ages and found similar results, whereas the
other study (Green et al., 2019) found a fluoride-IQ
effect only in boys. We explored the shape of the
concentration-response curve by using a standard
linear shape and compared with a squared expo-
sure and a piecewise linear function that allowed a
change in steepness at two points within the range of
exposures. Comparisons between the models suggest
that the standard linear function is a reasonable
approximation. All of these estimates have a certain
degree of uncertainty, and emphasis should therefore
be placed on the joint BMC results from the two
studies and involving both sexes. These findings,
using a linear concentration dependence, suggest
an overall BMCL for fluoride concentrations in
urine of approximately 0.2 mg/L. The results of this
benchmark analysis should be incorporated when
developing strategies to facilitate lowering fluoride
exposure among pregnant women.
CONFLICT OF INTEREST
PG has served as an expert on the hazards of
environmental chemicals on behalf of the plaintiffs
in Food & Water Watch v. US EPA. HH and BL
served as nonretained expert witnesses (uncompen-
sated) for the same trial, in which they offered tes-
timony regarding the studies their respective teams
on fluoride exposure and neurobehavioral outcomes.
All other authors have no interest to declare.
FUNDING
The ELEMENT study was supported by
U.S. NIH R01ES021446, NIH R01-ES007821,
NIEHS/EPA P01ES022844, NIEHS P42-ES05947,
NIEHS Center Grant P30ES017885 and the Na-
tional Institute of Public Health/Ministry of Health
of Mexico. The MIREC study was supported by
the Chemicals Management Plan at Health Canada,
the Ontario Ministry of the Environment, and the
Canadian Institutes for Health Research (grant #
MOP-81285). PG is supported by the NIEHS Su-
perfund Research Program (P42ES027706). CT is
supported by the NIEHS (grants R21ES027044;
R01ES030365-01).
ACKNOWLEDGMENTS
The authors gratefully acknowledge: Nicole
Lupien, Stephanie Bastien, and Romy-Leigh Mc-
Master and the MIREC Study Coordinating Staff
for their administrative support, Dr. Jillian Ashley-
Martin for providing feedback on the manuscript,
as well as the MIREC study group of investigators
and site investigators; Alain Leblanc from the IN-
SPQ for measuring the urinary creatinine; Dr. An-
-------
10
Grandjean et al.
geles Martinez-Mier, Christine Buckley, Dr. Frank
Lippert and Prithvi Chandrappa for their analysis
of urinary fluoride at the Indiana University School
of Dentistry; Linda Farmus for her assistance with
statistical modeling. This MIREC Biobank study
was funded by a grant from the National Insti-
tute of Environmental Health Science (NIEHS)
(grant #R21ES027044). The MIREC Study was sup-
ported by the Chemicals Management Plan at Health
Canada, the Ontario Ministry of the Environment,
and the Canadian Institutes for Health Research
(grant # MOP-81285).
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0 american society for
j|j ENVIRONMENTAL HISTORY
The Honorable Michael Regan
Administrator
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460
mi chael. regan@epa. gov
Re: Retiring the EPA Online Archive
Dear Administrator Regan,
We the undersigned write to express our opposition to EPA's plan announced in February to sunset
its online archive in July 2022. The vast majority of our government's interaction with the public
comes through digital channels; public digital archives such as the EPA's are of enormous value to
historians as well as to the public.
This EPA archive has already proven immensely useful to environmental historians.1 Not only are
citations to it regularly featured in traditional scholarly venues, it has greatly facilitated projects such
as "A People's EPA", a website and Twitter feed through which historians help explain the work of
the EPA to a broader public.
Not just historians but those from a variety of academic disciplines as well as the public rely on the
EPA digital archive for information, insight, and analysis. The site has provided resources for others
working in ecology, biology, toxicology, and other environmental sciences as well as geography,
law, sociology, political science, and public health. Professors and teachers at various levels, from K-
12 schools to the graduate level utilize the archive as a pedagogical resource, directing students to
1 Works that cite include: Bahng, Aimee. "The Pacific Proving Grounds and the Proliferation of
Settler Environmentalism." Journal of Transnational. AmericanStudies 11, no. 2 (2020); Cronin, John. "The Cuyahoga fire at
fifty; a false history obscures the real water crisis that never ceased." journalofBiimmnmentalStudies and Sciences 9, no. 3
(2019): 340-351; Elmore, Bartow J. "Roundup from the ground up: A supply-side story of the world's most widely used
herbicide." Agricultural Histoiy 93, no. 1 (2019): 102-138; Fredrickson, Leif, Christopher Sellers, Lindsey Dillon, Jennifer
Liss Ohayon,-Nicholas Shapiro, Marianne Sullivan, Stephen Bockinget al. "History of US presidential assaults on
modern environmental health protection." Americanjournalofpublic health 108, no. S2 (2018): S95-S103; Gillam, Carey.
"An Award-Winning Discovery." In Whitewash, pp. 23-41. Island Press, Washington, DC, 2017; Gutkowski, Andrew.
"The Evolution of Environmental (In) Justice in Spartanburg, South Carolina, 19002000." Journal of American History
106, no. 4 (2020): 923-948; Hepler-Smith, Evan. "Molecular bureaucracy: Toxico logical information and environmental
protection."' WLtmmmentalHistory 24, no. 3 (2019): 534-560; Rankin, William. "The Accuracy Trap: The Values and
Meaning of Algorithmic Mapping, from Mneral Extraction to Climate Change. " Btmmfimefit and History (2022); and
Spears, Ellen Griffith. Baptised in PCBs: Race, Pollution, and Justice in an AIlAmerican Town. University of North Carolina
Press, 2014, and Rethinking the American MnvironmentalESovemeni' Post-1945. Routledge, 2019.
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pages that offer authoritative records of the geographies they are exploring. Not least among those
who have relied on the EPA's online archive are those working with and living in more marginalized
or environmental justice communities, a stated priority of current EPA leadership.
Having easily accessible documentation of the extensive EPA's investigations and records of
decision for Camp Lejeune, North Carolina, for instance, has helped overcome local doubts about the
agency's effectiveness, yielded greater understanding of chemical exposures, and otherwise
significantly supported the agency's efforts at clean-up. Here and elsewhere, residents faced with a
potential environmental hazard can more easily access the agency's past work in their locale as an
aid to understanding prior investigations at the site.
The importance of EPA's online archive is perhaps best illuminated by considering what will be lost
when this archive is taken down. The many mentioned uses of EPA documents will become much
more difficult for those who cannot travel to EPA's print collections, and with any pandemic
recurrence, well-nigh impossible. A tremendous gap will also open up in what more recent historical
records are accessible, as it takes many years for any preserved documents to be transferred to and
made available through the National Archives. It will become much more difficult for historians to
assess and interpret this agency's recent past, much less to situate it within longer histories and larger
contexts.
We understand that the EPA's provision of a public archive of its own documents and deliberations
is voluntary and that online maintenance entails some costs. But those need to be factored against the
better and broader understanding it has nourished of the vital work done by this federal agency,
whose own future hinges on greater public awareness of and support for what it does. Instead of
doing away with the EPA archive, the Biden administration should promote it as a model for other
parts of the Executive Branch. In our digital age, agencies should make their own publications and
other public interactions more quickly, thoroughly, and durably accessible, both to historians and to
the larger publics our government serves.
Sincerely,
Sarah S. Elkind
President
American Society for Environmental History
The following organizations have cosigned this statement:
American Historical Association
College Art Association of America
Environmental Historians Action Collaborative
National Council on Public History
Society of Architectural Historians
World History Association
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
Region 1: Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island,
Vermont
Thank you, again, for all the work that went into the National Engagement Call. I know there was much
appreciation for the substantive conversation, as well as reports from staff that responded directly to
many of our suggested topics below. I am following up on a couple of items to maintain the momentum.
In general, I know many folks are wondering about the timing of the different guidance documents. And
more specifically, we wanted to check in about opportunities for public input and engagement on those
various documents. When we talked as a small group, Vernice had some great suggestions about
community engagement by combining opportunities for in-person, remote, and written input. We had
also discussed a NEJAC Title VI working group as one mechanism for input. Is there any way to get an
update about timing and/or plans for engagement? Do you have a sense of whether there will be formal
comment periods? I do know that this group and others would welcome the opportunity to strategize
about engagement in order to maximize input. Many thanks! Amy Laura
Region 2: New Jersey, New York, Puerto Rico, US Virgin Islands
Public Healthy sports Generation, and Academy, Should be Established and published in Region 2 If
possible all other Regions can also be mandated to do same, Web site should be Created between now
and November, And by Award AGE GROUP FOR FOOTBALL the age group for football should be for
Teenager 14 years to 16 years only to be Approved. THANKS - Oluwaleye John
Full Name (First and Last): Katherine Welty
Name of Organization or Community: Earthjustice
City and State: New York, New York
Brief description about the concern: In 2016, Congress amended TSCA, directing EPA to evaluate and
eliminate chemicals' unreasonable risks not only to the general public, but also to groups that that face
higher levels of chemical exposure or are more susceptible to chemical exposure. EPA's mandate to
evaluate risks to communities facing high levels of chemical exposure is only satisfied if EPA considers
the full range of intended, known, and reasonably foreseen ways that fenceline communities will be
exposed to toxic substances. However, EPA's current Fenceline Assessment Approach fails to meet that
standard. In particular, the approach narrowly defines fenceline communities, does not adequately
consider available data on pre-existing levels of chemical exposure or peak facility releases, and does
not reflect input from exposed communities themselves. Further, the approach fails to incorporate the
cumulative impacts of multiple chemicals and multiple polluting facilities, as EPA is only looking at
exposure from one chemical and one facility at a time. However, many chemicals cause the same kind of
negative health and safety effects, compounding the harm that communities face when exposed to
multiple toxins in one area, something not uncommon in manufacturing areas, particularly those with a
long industrial past.
What do you want the NEJAC to advise EPA to do? : We request that the NEJAC help protect fenceline
communities by urging EPA to expand and strengthen its assessment of fenceline community risks
without delaying the regulation of chemicals that were previously evaluated under TSCA. In particular,
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
we ask the NEJAC to advise EPA to: 1) Incorporate immediate modifications for already assessed
chemicals, including the use of existing air modeling software to map total chemical load; the inclusion
of at least five years of chemical release data to better understand estimated chemical exposures; the
consideration of both preexisting levels of contamination in fenceline communities as well as peak
emissions from nearby facilities; and the inclusion of an uncertainty factor to better represent unstudied
cumulative impacts; and 2) adopt broader changes to the fenceline assessment approach that can
strengthen the risk evaluation process going forward, including the addition of cumulative risk analyses,
as outlined by the NEJAC in its own 2004 report addressing communities facing multiple stressors.
Region 3: Pennsylvania, District of Columbia, Maryland, West Virginia, Virginia,
Delaware,
Full Name (First and Last): Akisha Townsend Eaton
Name of Organization or Community: Companions and Animals for Reform and Equity
City and State: Baltimore, MD
Brief description about the concern: Human and animal well-being as part of environmental justice.
What do you want the NEJAC to advise EPA to do? : Develop best practices and consider existing best
practices from other federal agencies and experts to consider the intersections of human and animal
well-being in environmental justice.
Region 4: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina,
South Carolina, Tennessee,
Full Name (First and Last): Demarious Nathaniel Baker
Name of Organization or Community: Tampa Bay Area
City and State: Land O Lakes Florida
Brief description about the concern: Good morning, My Name is Demarious Nathaniel Baker Born in
Arcadia Florida. I currently live in the Tampa Bay Area, Pasco County. I have reason to believe that a
secret agency is illegally taking DNA from my body to operate a simulation organization. I have videos in
my phone and I'm now hearing a force team talking thru their monitors from my 2018 Chevy Equinox.
To my knowledge they have been using this method to create laws that throughout the state by using
civilian frequency brain waves. My grandmother just recently asked me if I was hearing voices in my
head and she is nearly deaf. Therefore I feel that they used a undercover vehicle and put it on the
market through CarMax to text whatever methods that have already been altered. This is a big concern
to me and the safety of my family. I have been having thoughts from other people's DNA of people I
don't know including voices in my head of major threats on my life from the president and Vice
president and former presidents. Please help in this urgent time of need. I feel helpless in this moment
because whatever they're doing is running through my body I a high rate of radiation from my brain,
heart, testicles, lungs, groin all the way to my toes. Furthermore, MacDill AfB and all counties
throughout the state of Florida have been signalling waves from Atlanta Georgia stating that they have
been tracking my DNA since I was born through some type of intelligence operation that I have no
knowledge of. I have one last but not least piece of information. A friend of mine by the name of
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
Michael Lamar who's also a Facebook friend of mine who happens to live in downtown Tampa made a
video of me after I passed out face first on the elevator due to some type of aircraft and drone system
extraction from a PlayStation controller. I also feel this wave of signal coming from their aircrafts and
the videos below are there drones I believe. Thank you for your time
Dr. Ellen Griffith Spears, Environmental Historians Action Collaborative, July 1, 2022. Thank you for the
opportunity to submit comments to the NEJAC. I am writing today to urge the NEJAC to invest in helping
to preserve an important section of the EPA Web Archive, which the agency has announced will sunset
in July 2022. Although it is not the responsibility of the Office of Environmental Justice alone, but a
priority for the whole agency to preserve the archived material, I believe it would be significant if the
NEJAC went on record in favor of maintaining and upgrading the archive. The announced closure applies
to a specific segment of the archive, the EPA Web Archive. Excluded from the sunset provision are the
official publications posted in the NEPIS database at the National Service Center for Environmental
Publications (NSCEP). EPA has also noted that the press releases now on the EPA Web Archive will be
migrated and preserved. However, my understanding is that as many as 420,000 unique pages on the
EPA Web Archive will ultimately be affected by the change, including valuable documents from the
Clinton and Obama administrations about climate change. More than likely, all the documents will not
go away overnight, but, over time, the archive, already in need of an upgrade, will gradually become less
easy to use, less comprehensive, and of diminishing value as a resource for historians and the public. My
concern is that environmental justice communities will be especially affected by the loss of this historical
data. My own experience, working in depth in communities such as Gainesville, Georgia, with the
Newtown Florist Club and in Anniston, Alabama, with the Sweet Valley/Cobb Town Environmental
Justice Task Force and Community Against Pollution, suggests that the Web Archive is quite useful for
residents of affected communities. Recently, I found the archive invaluable in doing research in Holt,
Alabama, in Tuscaloosa County, where we found information about the history of the agency's
investigations there. Local people are often first to recognize cases of environmental injustice. An
archival search is often useful as residents work to uncover prior EPA involvement and to bring pollution
concerns to the EPA's current attention. Traveling to a regional print repository is expensive, often
impossible, and digital access provides the ability to search far more efficiently. The agency argues that
the cost of maintaining the archive makes retaining it prohibitive. I would argue that there is a much
larger cost to losing this record of EPA actions. Sunsetting the archive would not only be a loss for
historians and the public, but for the agency itself. In the words of the historians' letter sent to EPA
Administrator Michael Regan on June 14, the archive preserves "the vital work done by this federal
agency, whose own future hinges on greater public awareness of and support for what it does." I hope
that the NEJAC can invest in retaining these resources, mainly by allocating time and human capital in
the immediate term to convince the agency as a whole to commit the resources necessary to preserve
this valuable material as part of the commendable priority being placed on environmental justice by this
administration. The EPA may be unique among federal bureaucracies in the extent to whichfollowing
various laws starting with NEPA, reinforced by William Ruckelshaus's 1983 commitment to operate "in a
fishbowl," certainly with EPCRA and Community Right-to-Knowto prioritizing public access and
transparency. Maintaining that commitment is a sacred trust with the American people. Thank you.
Region 5: Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin,
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
Thank you and your panel for allowing me speak at the final moments of the webinar today. I am a
lifelong resident of East St. Louis, Illinois. Our community is full of capable and meaningful people, who
unfortunately have not been treated as such by agencies and people in positions of power. My
comments for those who could not hear are as follows, who do we address in order to bring the
resources of the EPA to East St.Louis? We have the brains and the brawn to implement any program,
any hub, any clean up effort that you can bring our way. We just need the resources. I read a quote once
that said "When the elite address the issue of poverty, they focus on managing the poor instead of
redistributing the wealth." Lets not follow that model. You have millions of dollars that need to be sent
out by September of 2023. That money could change our community for centuries. That could help to
right the wrongs that have been done to us environmentally and economically. We are ready with boots
on the ground. Sincerely, Marie Franklin
National Environmental Justice Advisory Council Meetings (NEJAC) comment. July 6, 2022 - My name is
Brenda Staudenmaier. I work in the water industry in Madison, Wisconsin protecting human health and
the environment. I have a degree in environmental engineering with a focus on drinking water and
wastewater. In 2017, myself, my children and others filed a Federal lawsuit against the US EPA using the
Toxic Substances Control Act, because fluoride added to the public drinking water supply is an
unreasonable risk to the developing brain. Fluoride is equally as toxic to the brain as lead. Our case is
ongoing and back in Federal Court with Judge Edward Chen, Tuesday, September 20, 2022. You should
know that fluorides in US drinking water is recognized as a water pollutant by the EPA, and fluoridation
policy has been recognized as an environmental justice issue by Civil Rights leadership for over a decade.
Yet, political power to address this issue is lacking. None of the three EPA approved, lead- and arsenic-
laced fluoridation chemicals ,that originate in the pollution control systems of industry, have ever been
safety-tested. The EPA has a Maximum Contaminant Level Goal of Zero for lead and arsenic. Fluoride
should have the same goal for the same reason. It poisons consumers. Please see my Product Data
Sheet for the fluoride chemicals used by my utility in Wisconsin below that shows the levels of lead and
arsenic allowed. Water fluoridation began in the early 1940's when we were also singing the praises of
asbestos. Fluoridation began despite dentists knowing fluoride could stain and pit children's teeth with
dental fluorosis. Today, 70% of US children and adolescents are afflicted with dental fluorosis on at least
two teeth from ingesting too much fluoride. This effect is disproportionate by race. Yet, the oral health
report in December 2021, shows despite increases in public water fluoridation, dental visits, sealants,
fluoride varnish applications, and significant financial, training, and program investments, tooth decay
persists - especially in minority populations who are most harmed by fluoride ingestion in more ways
than stained teeth. Fluoride is not a nutrient, it is a poison used as a drug. Like all drugs, fluoride has
adverse side effects affecting kidneys, thyroids, bones, and immunity - but the most appalling effect is
fluoride's damage to the developing brain. Backed by 100's of animal studies and 74 human studies link
fluoride to lower IQ and increased rates of learning disabilities like ADHD. It seems like almost every kid
in America is diagnosed with some form of learning disability. The National Institutes of Health have
funded some of the most robust neurotoxicity studies on fluoride. Every study funded by NIH has found
fluoride harms the developing brain. If a pregnant mother exposes their fetus to fluoride during
pregnancy or through bottle feeding their baby using tap water, they can expect to see a reduction in IQ
and an increase in ADHD in their children - similar to what we see with lead exposure. Fluoride is just as
neurotoxic to the brain as lead, especially when exposure occurs during fetal development and
infancy. We are spending over 15 billion dollars removing lead from drinking water pipes because it
harms the brain, while purposefully paying to add something just as toxic to the brain. This is the most
simple environmental justice problem to fix and requires no money. All we have to do is stop paying to
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
add neurotoxic fluoride to the public drinking water supply. I have also attached an annotated
bibliography that lists many studies published between 2015-2022 finding harm to the brain, bones,
thyroid, and kidneys. Sincerely, Brenda Staudenmaier
Region 6: Arkansas, Louisiana, New Mexico, Oklahoma, Texas,
Full Name (First and Last): Teresa Seamster
Name of Organization or Community: Retired - Former Principal & Teacher
City and State: Santa Fe, NM
Brief description about the concern: Health impacts on children and adults (especially pregnant women
and elderly) from excessive exposure to oil well emissions from wells located too near homes, schools
and businesses. As a researcher and author of several presentations and reports to the Navajo Nation on
behalf of the Tri-Chapter Health Impact Assessment Committee of Counselor, Torreon-Starlake and Ojo
Encino Chapters, I urge NEJAC to direct the well permitting agencies to establish better public safety
protection guidelines outlined below.
What do you want the NEJAC to advise EPA to do? : Establish greater well setbacks from inhabited
structures at 6600' for optimal health protection (MacKenzie, etal 2018 report on Boulder, CO) 2.
Provide gas-blood analyzers at "frontline" community clinics to determine exposure levels so health
providers can accurately diagnose and treat illnesses caused by air pollutants 3. Provide installation of
air filters in homes, schools, etc. within 1/2 mile of active wells 4. Secure routes for fire, EMT and school
buses that are off-limits to oil company traffic and construction projects 5. Require oil companies to
conduct continuous "fenceline" air quality monitoring and make readings available to the community
through an easily accessible "dashboard" on-line and in the daily media (newspaper, radio).
Full Name (First and Last): L. Watchempino
Name of Organization or Community: Multicultural Alliance for a Safe Environment
City and State: Pueblo of Acoma, NM
Brief description about the concern: EPA needs to end all exemptions from the laws that protect our
health and environment, like the Clean Water Act, the Safe Drinking Water Act, the Clean Air Act, and
NEPA, especially in overburdened environmental justice communities where these environmental
protections are most needed. Nor should EPA exempt industrial polluters or the mining industry from
returning a site to background standards through technical impracticability waivers.
What do you want the NEJAC to advise EPA to do? : Advise EPA to promote, rather than impede, the
right to clean, sustainable water sources and clean air in all overburdened populations within its
jurisdiction as a key element of Justice 40. If EPA permittees are unable to demonstrate the ability to
meet regulatory standards during operations or lack the technology to achieve background standards at
the close of operations, a permit should not be approved. In addition, more stringent conditions should
be adopted to protect sensitive ecological or cultural areas as well as overburdened environmental
justice communities.
Region 7: Iowa, Kansas, Missouri, Nebraska,
None
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
Region 8: Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming,
None
Region 9: Arizona, California, Hawaii, Nevada, the Pacific Islands,
All: The letter and accompanying exhibits previously sent to all of you document in detail numerous
egregious inaccuracies, unlawful excuses, and indefensible environmental justice abuses in EPA Region
9's January 28, 2022 and May 22, 2019 letters that coverup a gross lack of CERCLA remedial compliance
and enforcement action by Region 9 at the federal Motorola 52nd Street (M52) National Priorities List
(NPL) Superfund Site in Phoenix, Arizona. This lack of CERCLA remedial compliance and enforcement
action by EPA Region 9 has resulted in serious, decades-long unlawful groundwater contamination being
allowed to unlawfully migrate uncontrolled from the federal M52 NPL Site and contaminate additional
downgradient groundwater resources. More importantly, the unlawful migration of significant unlawful
groundwater contamination for multiple decades beyond the boundary of the M52 NPL Site significantly
contributes to ongoing and widespread public exposure of the local low income, dominantly minority
community in this area to uncontrolled emissions of hazardous volatile organic compounds and other
toxic chemicals from over 20 contaminated groundwater production wells that continue to operate in
the area. This unlawful groundwater contamination, unwarranted and unsafe human exposures to
known carcinogenic and other toxic chemicals and the resulting environmental justice abuses are all
caused, in significant part, by violations by EPA Region 9 of federal minimum environmental remedial
action cleanup and human health exposure standards applicable under CERCLA to the federal M52 NPL
Site. EPA Region 9's failure to act has allowed unlawful offsite migration of uncontrolled unlawful
groundwater contamination from the M52 NPL Site to continue for decades despite express CERCLA
legal remediation requirements to the contrary and express assurances by EPA Region 9 in a 1994 M52
NPL Site Record of Decision document to "fully address the threats posed by conditions at the [M52
NPL] site." Due to EPA Region 9's failure and continued refusal to comply with and/or enforce applicable
minimum CERCLA remedial action cleanup and human exposure standards at the federal M52 NPL Site,
as clearly expressed in Region 9's January 28, 2022 and May 22, 2019 letters, we hereby request EPA
Headquarters to independently review the documented information and data presented in the attached
letter and my September 9, 2021 letter and accompanying exhibits. EPA Headquarters, especially with
the Biden Administration's priority focus on remedial compliance and environmental justice, should not
allow Region 9 to continue to neglect and coverup its decades-long history of insufficient remedial
compliance and enforcement and failure to ensure equal protection of public health and the
environment under CERCLA from the unlawful groundwater contamination and unsafe human
exposures directly attributable to releases of hazardous and toxic substances within and from the
federal M52 NPL Site in Phoenix, Arizona. If EPA Headquarters and the Biden Administration are
genuinely serious on focusing on CERCLA remedial compliance and environmental justice as top
Administration priorities, there is no reason EPA Region 9 should be allowed to continue to ignore
ongoing violations of CERCLA's applicable human exposure and groundwater remedial action cleanup
standards at the federal M52 NPL Site, especially when those violations are directly responsible for
decades-long unsafe exposure of a local minority community to numerous carcinogenic and other toxic
chemicals at one of the largest groundwater contamination sites in the country. We are ready to meet
and discuss how this long-standing and inexcusable public tragedy can be readily addressed by simply
requiring compliance and enforcement of the applicable CERCLA remedial action cleanup and human
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
exposure standards and the Biden Administration's follow through on its numerous public commitments
to environmental justice. We look forward to hearing from you. Sincerely, David P. Kimball
Dear NEJAC Members, Thank you so much for your insightful comments to my testimony on municipal
waste combustion units at your June 22 meeting. The rules governing emissions from these facilities are
now decades overdue and many of the facilities are over three decades old. The USEPA continues to
grant a regulatory subsidy to these facilities by failing to issue regulations which protect the health of
the communities hosting the facilities. Modern air pollution control technologies are required on just a
handful of these incinerators; it is long past time for USEPA to issue rules which comply with the Clean
Air Act and protect environmental justice communities from the harmful impacts of emissions from
these incinerators. There are 157 incinerator units at 57 sites across the country, but these sites are
concentrated in a handful of states. Over 90 of the 157 incinerator units in the country are in just these
six states: Connecticut 12 incinerator units at 5 sites, Florida 24 incinerator units at 12 sites,
Massachusetts 11 incinerator units at 7 sites, New Jersey 13 incinerator units at 4 sites, New York
13 incinerator units at 10 sites, Pennsylvania 19 incinerator units at 6 sites. We are requesting that
the NEJAC urge USEPA to finally issue rules for Municipal Waste Combustors that protect public health
and comply with the law as soon as possible. We are attaching a letter on this topic submitted to the
White House Environmental Justice Advisory Committee from Breathe Free Detroit, California
Communities Against Toxics, Center for Environmental Transformation, Earthjustice, East Yard
Communities for Environmental Justice, Florida Rising, Global Alliance for Incinerator Alternatives,
Ironbound Community Corporation, New Jersey Environmental Justice Alliance, Oregon Physicians for
Social Responsibility, South Baltimore Community Land Trust, and Valley Improvement Project. Thank
you so very much for your kind attention to this critical public health issue. Communities hosting these
facilities need your help to protect their health and well-being. Cordially, Jane Williams, Executive
Director, California Communities Against Toxics, Rosamond, California
Region 10: Alaska, Idaho, Oregon, Washington,
None
Oral Comments (Raw) Provided at the Meeting:
(Note: Some of the Material might contain spelling and grammar errors. These comments are in a raw format and some of the
continuity maybe missing.)
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
Nathan Park Good evening, everyone. I'm speaking on behalf the earth justice, public interest
environmental law organization working to protect people's health and environment through the
strength of our partnerships and the law. And i appreciate the opportunity today to speak with you all
today I will be focusing on the justice40 initiative. Earthjustice continue to work with partners on
ensuring that the historic funding levels for lead service line replacements are distributed equitably in
line with the administration's justice40 initiative and to ensure this happens and for the Biden
administration to hold through on justice40, EPA should do the following: First, ensure that funded
programs will fully pay for lead service line replacements without charging individual property owners.
Second: EPA should clarify that drinking water state revolving fund dollars cannot be used to fund any
partial lead as much as line replacements which we know causes increase in lead in in drinking water
and finally EPA should see through a strong science based and health protective lead and copper rule
revision. In December 2021 the Biden EPA allowed the trump lead and copper rule revision to go into
effect which significantly weakens the rules rule by setting up weak voluntary test testing programs
narrowing the definition of lead service lines and permitting over 90% of all water systems to avoid lead
service line replacement altogether the ... A new LCR must require all lead service lines to be removed in
at the years and strengthening the LCR will allow Biden administration to identify and ensure service line
replacements, additionally glad to see administration's update last week announcing That HUD made
available 500 million for states and local governments to address lead-based payment hazards.
Targeting these dollars towards disadvantaged communities in line with justice40, however under HUD
housing protocols, there's no requirement for tenant-based section eight housing units to be inspected
for lead has regards at any time not even upon turn over. Additionally, there are disclosure
requirements, they are not effective and inspections requirements will ensure that tenants have needed
information about lead and housing. This means that in public housing built before 1978, when lead
paint was banned many hazards going unidentified. And that HUD made available to remade yet,
leaving people and children in public housing at risk if they are not already serving from lead poisoning.
And we know folks that live in-house rack or racks disproportionately affected by wide range of
environmental and health hazards to ensuring these federal dollars reaching them should be central to
the justice40 work. To that end EPA should join HUD in repeated calls to congress to inspect public
housing and lead has regards. I see I'm out of time I will stop there and follow-up the rest of my
comments online.
Adriane Busby. - Good afternoon and thank you all for your hard work and this opportunity to speak
with you today. I am A.B. the Senior Food and Climate Policy Analyst with Friends of the Earth and today
I'd like to recommend meaningful investment and monitoring communities located near concentrated
animal feeding operations also known as factory farms. Each year today's industrial scale farms
generate as much as 1 billion tons of manure. Up to 20 times more waste than humans, but at least
human waste is treated. This waste, which is not treated can contain pathogens and antibiotic resistant
hack back tear and call groundwater can be contaminated through ground applications leeching from
manure improperly spread on lapped and through leaks or breaks in storage and containment units.
Factory farm pollution contributes not only to respiratory elements but also decrease quality of life,
mental stress and serious health affects these communities are communities of color or low wealth
communities often have compounded exposure to risk due to historic but lingering contamination while
also being targeted for new industrial development. These same communities often see low pollution
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
reduction investment despite EPA's knowledge. Friends of the other asks that NEJAC recommends that
EPA fund direct long-term water and air quality monitoring for many including sample collection, access
to laboratories, lab costs and experts for data analysis. So that the burden to collect this information is
not put on the communities that are already overburdened with life's existing demands. Next, we think
that EPA should support timely noticed to communities and k pose and meaningful tunes to object and
as well as pollutants the operations release and potential risk associated to public health. We also
recommend supporting research for sustainable alternatives to waste look ons not vulnerable to
breaches and protect local communities from contamination. We think that need to create engagement
plan to solicit input in additional policy solutions to factory farm pollution including hosting a series of
regional EJ listening sessions, prioritizing regions, three, four, seven and nine on environmental and
public health impacts of KFOS culmination in national listening session on the I. In the interest of time, I
will stop there, but I thank you all for your time and consideration. Thank you very much.
Victor Perez, - My name is Doctor Victor Perez Associate Professor of Sociology at the University of
Delaware and Environmental Justice Researcher. And I'm speaking on behalf of the residents of a
community called Southbridge in Wilmington, Delaware, the civic association and also speaking as the
interim chair of the Southbridge neighborhood action plans environmental committee. Southbridge is
the core of south bridge is a small community of about 1400 people, working class with a significant
number of folks who fall below the property threshold. A little over 80% are African American and
they've been involved in community-based efforts in trying to address a variety of Environmental Justice
issues for a long time. That have always been sort of intertwined with development in the area. And so,
this evening I'm going to be providing feedback that I got from some community members as a recent
civic association neat meeting regarding issues important to them including flooding. To quote one
community member everyone has a flooding story and it has to do with lack of adequate maintenance
of the infrastructure, but also because of just the long-standing sort of problem with the ability to
handle the water that happens in here with the river and the Delaware Bay, itself. The brown fields in
the community, there are over 36 brown fields. Ms. Keith owes and standing water in the community
are problematic. It's understood as asthma cluster and cancer cluster by community members wet land
park being developed, will only address about half of the flooding that the community currently deals
with. And there has to be help for Environmental Justice problem before new negative Environmental
Justice issues come about caused by development called river front east which is in a lot of ways, really
providing the potential for green and resilient gentrification with lack of affordable housing the
community wishes to own its future and not be displaced folks talked about basic needs like
laundromats as well as a mill much company and children playing by the mill much company which has
health and physical safety concerns. As well as a lack of variety of encapsulated soils all over including
construction sites that has pounds of dirt with glass and hazardous materials as well as brown fields
particularly near where children play in parks. Thank you very much for the opportunity to speak today.
John Mueller- Good afternoon. And greetings again from Tulsa, Oklahoma. I'm Jon Mueller retired
engineer mainly water resource engineering and degree in gee physical engineering. I am again
presenting concerns about water floriation. But before going any further, I want to acknowledge and
thank the NEJAC members for responding to these concerns presented during previous NEJAC public
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
meetings by myself and others and also thank you, matt day by answering questions in your NEJAC
community engagement calls. My comment today is largely spontaneous in response to the
presentation on the PFAS and PFOA contamination chemicals. We all know or should know that the f in
those organic chemicals is the fluoride, atoms bonded to the carbon atoms in those compounds. What
makes them the "forever chemicals" that they are, is the strong bond which Wikipedia tells us is one of
the strongest single bonds in chemistry and is "the strongest in organic chemistry". One reason is that it
has the strongest electro negative of any element in the periodic table of the elements. It's the same
atom that helps give prescription drugs like president act and lip I tour their efficacies. It's it deliberately
added to public water supplies and increasingly recognized by emerging scientific studies as being
harmful to human health effecting some of the same organs in our bodies as the PFAS and PFOA
compounds, not only in Environmental Justice communities, but harm to the developing brains of the
unborn fetus in pregnant mothers, of infants from formula reconstituted with fluoridated water and
young children swallowing fluoridated foot paste. It's added as a medical treatment to help prevent to
the decay with no control of human exposure other than what's added to the tap water miles upstream.
It is unethical with no informed consent from those who have no choice but to drink that water. To the
decay can be prevent requested better diet and/oral hygiene early brain damage is, as we have heard, a
horse of a different color. Accordingly, a specific NEJAC recommendation should be banning the
deliberate addition of any fluoride chemical compound to public water supplies. I will be submitting
additional materials prepared by experts including highly respected thank you again for the unpresented
precedented opportunities in this still greatest of nations. Thank you again.
Odette Wilkins - Hello everyone, impress and general council of wired broad band a non-profit whose
mission to educate the public about the need for fiber on particulars deployment for broad band. Radio
frequency radiation from wireless infrastructure is a pollutant. That includes sell towers, base stations,
4g, 5g roof top a 10 that is so called smart meters, even documented by the telecom industry in
consumer product protection plans for example a brochure states: "Pollutants means any contaminant
including artificially produced electromagnetic fields, sound waves, microwaves and all ... radiation. Is
radio frequency radiation and also called electro smog. Personal injury claims. Major insurance
companies will not cover or for personal injury from RF radiation. In fact, the EPA had recognized RF
radiation as an environmental hazard back in the 1990s. As on as it did the EPA was defunded in that
area and jurisdiction over those areas with a taken away. My question is when will EPA reclaim
jurisdiction over this area. ... EMS disabled. They have been the unrelenting subject of discrimination,
including digital discrimination and bias to be little and deny the debilitating physical injuries of rf
radiation exposure. Condition can include headaches ... (too fast) hair loss, depression, skin inability to
participate in normal activities or even work many of the EMS disabled are unaware of the dangers, or
gave them no creed Ontario until they became injured. They also include children. Children living close
to a sell tower were vomiting in beds that community had sell tower placed at the end of the block 17
people got sick and many who could afford to live elsewhere, evacuated their homes. That and still
continuing in pits field Massachusetts. RF radiation is invisible cannot be perceived with naked high gas
leaking from a stove. And therefore, goes unnoticed until one develops symptoms or is injured by it.
The EMS disabled have been unsuspecting victims of injuries that now become their disabilities. There is
talk greenhouse cause gasses or air and economy. But decarbonization cannot occur without electro
smog. Any perceived benefit from reduced fuel con bulges is likely offset by greenhouse gasses from
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
wireless infrastructure. Presenting these comments is an effort to make visible what has otherwise been
invisible until now the EMS disabled. It's important for the EPA to reclaim jurisdiction on evaluating the
safety of RF radiation. Thank you.
Mayra Reiter - Project Director for Occupational Safety and Health with Farmworker Justice. I would
like to thank NEJAC for the opportunity to speak today on agency investments as they relate to
environmental justice. Agriculture workers comprise one of the most disadvantaged communities in the
U.S. studies shown that up to 80% of farmworker households experience food insecurity, the average
income of a farmworker family is in the range of 25 to $30,000. And at least 20% of farmworker families
find themselves below the federal poverty level. 2.4 million farmworkers in the U.S. face significant
health risks due to pesticide exposure which can result in both acute and chronic health effects that may
include neurological damage, birth defects, learning disabilities and other conditions pesticide use is
predicted to increase as climate change intense ties company number of investments EPA can make to
help us achieve greater Environmental Justice for the agriculture workers to produce. The first of them
is to dedicate resources to prioritizing the review for PFOS faith pesticide. Followed by the immediate
cancellation of all uses that pose risks of concerns. EPA was supposed to complete the registration
reviews of highly toxic pesticides, statutory deadline of October first, 2022. But EPA has inked indicated
that only three of the 15 reviews will be completed by the deadline. And that research constraints are
partly responsible for this delay. This means that farmworkers that have to wait years for EPA to take
stance to fully address the risks bows posed by this pesticide unless dedicated more resources to
complete the registration reviews. EPA must put resources toward developing a systematic review
framework by which it can incorporate more scientifically sound ... pesticide human health risk
assessments to ensure than the assessments are informed by real world data. The framework should be
peer reviewed by national academy of sciences reports adoption. In addition, more resources need
today improve pesticide illness surveillance. Currently the program administered by my on in
partnership with EPA collects pesticide poisoning data but covers only 10 states, this program needs to
be expanded to more states, prioritizing those with the greatest numbers of reports from workers,
without additional investment it will be hard to assess the full affects ... this information is important for
EPA to be able to properly perform its regulatory function. Finally, reducing pesticide exposures among
farmworkers is an environmental goal for EPA. Farmworker justice for EPA to direct more resources
towards as addressing pesticide exposures among these essential workers. Thank you.
(Rashmi Joglekar). - I'm staff scientist at earth justice and would like to thank you for providing the
opportunity to speak today I will also be flowing comments on the up-coming registration reviews for
pesticides, very closely aligned with the excellent comments that were just delivered. So, EPA delaying
the statutory mandated of a dangerous class of pesticide called (op's putting farm worsers, children and
families living near fields where ops are used at serious risk and posing Environmental Justice concerns.
EPA statutorily required to complete the registration review for 18 by October of this year to ensure
they're safe for use. However, EPA's illegally delaying in the process to on tape unnecessary new
scientific information from non-animal tests that EPA owes even scientific experts have warned against
August. EPA is already aware of the decades of scientific research that shows that ops are dangerous to
human health. Op are acutely neurotoxic meaning people exposed over a short period of time can
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
experience poisoning symptoms like headaches, dizzy next fast fast ops also linked to harm in
children, dozens of publishing scientific studies over more than two decades have shown that exposure
to extremely low levels of op during early life can lead to I see visible harm to the brain result go in long-
term effects. EPA's own draft risk assessment show people face unacceptable risks including children
and farmworkers and again race serious concerns. Ease EPA nearly all op's pose risk to the general
population from exposure to the diet including food and drinking water, infants and today letters
experience dangerous levels to most op's and for some, dietary exposures in children over 100 times
higher than EPA's level of concern. Farmworkers directly handle the pesticides face severe risks
meaning at least one-use scenario exceeds risk levels of person by at least an order of magnitude and
some cases that's even after factoring maximum protective clothing or equipment in engineering
controls also pose risk to bystanders or people living near fields where they're used and spread. Nation-
wide OP use data indicates that many of the communities in areas with the highest ago going at op
usage are low-income communities of color. Under EPA's proposed delay, the agency will only
immediately meet deadline for three as was highlighted and each year of delay puts children at risk of
lifelong development harm and farm workers at risk of to the other 15 In addition to the
recommendations that were outlined I'd like to specifically ask this council led, today, to issue statement
urging EPA to longer delay the registration review of this dangerous class of pesticide and cancel reg us
trace for uses of op that cause unreasonable harm to community's farmworkers and children. Thank
you.
Jane Williams. Jane I'm going to unmute your line and ailing how you to speak. Good afternoon NEJAC
members. Thank you so much for the opportunity to speak with you today. I had registered to talk. I
am the Executive Director of California Communities Against Toxics and I want to talk to you today
about municipal solid waste come bulges. EPA had a duty torn promulgate rules on municipal solid
waste also known as garbage incinerators in the early nineties. It was one of the first rules that the
agency issued under the clean air act amendments of 1990. The communities surrounding these
incinerators of which there are 57 facilities with 157 incinerators across United States have never
actually been afforded the protections of the act, because the rule was challenged in the federal court
and then remanded by U.S. EPA. The rule is now 16 years overdue. And we are trying to get EPA to
issue this rule as rapidly as possible to grant protections to the communities that host these municipal
waste combustion units. Many of these facilities, as I'm sure you must be aware, are in Environmental
Justice communities. They're in highly industrialized areas of the United States. And many are very old.
Most of them are over 30 years old. And so, I could really use all of the help that I can go from NEJAC
and its members to encourage U.S. EPA to as quickly as possible, promulgate new more protective
standards. Many of these incinerators are actually concentrated in just a few states. Over half the
inventory are in states that are Massachusetts, Connecticut, New York, New Jersey, Pennsylvania and
Florida. So it can't be that difficult of a problem when there's over half the inventory in just six states.
Since we promulgated the rules, we've learned to much more about the impacts of particulate emissions
especially during this pandemic. We see the correlations between high levels and the covid
epidemiologist on the ground. It is important for EPA to take this time and hurry up and promulgate
new standards not open reduce air toxic in high and so thank you so much for listening to me today.
And I hope that NEJAC can help us do something on this
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
Last three digits ending with 320. - I'm State Coordinator with Mom's Clean Air Force Colorado
Chapter also work withing engaging with community organizing within the lateen owe community here
in Colorado focusing on environmental justice, bringing justice to all communities for all children to have
access to clean air and have safe environment to live in. Mom's Clean Air Force is national organization
of 1 million mom and dads united in fighting for our children's rights to breathe clean air and have safe
environment to live in. Most importantly I'm an indigenous mother of four. We're tribal affiliates of
Navajo nations and survivor general side known as the Indian removal act known as the long walk of the
and a half a how. So historic (Navajo. Racism has always been a historic mark on our first nations tribes
and communities and still continues today by these environmental laws and policies and regular laces
that have formed our communities and have formed our environmental injustice communities such as
here in Colorado where we have refinery who are continuing to operate and harm community members
where children are dying before their parents that have drew up in this community. And in community
cannot use their water for drinking or cooking, but they stylobate in this water, and people the state)
still, bit (the state of environment have tested the water for PFAS levels and it's above the limits, I don't
think there's any safe limits of PFAS in our water which is the state of Colorado Wassed House Bill
221345 pertaining to concerns measures to increase proa texts from PFAS chemicals and I would like to
see the EPA take on these stronger initiatives to tackle PFAS nationally for all communities so that our
children are not being victims to PFAS chemicals as well as oil and gas that releases these PFAS waste
into our water ways through the sand creek river as well as the south matt river and there is a
community that uses damn water from these water ways for their community drinking water. And
there's just no safe limits of PFAS and we shouldn't have lower limits or high limits of PFAS to should not
be even considered as safe limits. There are no safe limits of PFAS in our blood or in our health. We
need to go by science based research and as well as climate research by scientists that understand that
we can no locker live with these contaminants in our error our with the and he that these facilities like
sup core refinery continuing to violate our right to public health sun core in a way that's safe for our
children and communities who are over 50 family housing that are impacted directly by sun core and
including surrounding industries that contaminate our air and our water and our lands and continue the
genocide through these environmental harm created through loopholes we call policies, regulation and
laws that sill. And the removal act and that's why we need to address the past, present and future in
this way that we address the racism underlying in these industries is as well as our structure of
government thank you for letting me speak.
(Unclear), - I'm a community member and I would like to bring consideration towards rural agriculture
and residential communities. My home is in North Central Florida. My neighborhood is historically
African American neighborhood intact since the end of slavery. We have a very rich history of cultural
history and also for example, we have survivors of the rose woods massacrer who relocated after that
event in our area. I wanted to, if possible, ask if there have been considerations in Environmental
Justice in obtaining equity of citing land use in zoning. The panelist made a wonderful comment I felt as
a community member about considerations of how cumulative impacts, such as what's nearby? Are
there good schools? Is there access to healthy foods? And i really, there's on ated with me because I do
feel that planning may be a way to begin addressing and attempting to achieve equity. My community
has been advocating for Environmental Justice and Energy Justice. But also, as far as what
developments are potentially proposed, how communities are engaged. If communities are given an
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
opportunity to be listened to, and being in a rural community, well water is something that many of my
neighbors and me and my families use. I want to thank you for this opportunity to just kind of share
some of the experience of community members and also, I'm not sure if this is the right forum but if
we're talking about justice40 and funding, if there can be considerations on how that money can get
directly to community groups would are on the ground, grass roots organizations trying to better their
community, that would be awesome as well if it that could be considered. So, thank you so much for
your time.
Akisha Townsend- This is my first meeting, but I do anticipate coming to other public meetings and I did
attempt to register but I was under the impression that I might not be able to speak and I realize that
we're getting close to time, so I will just keep my remarks very brief. And follow-up with further written
comments. But I work as the chief of policy in the Environmental Justice division of care which stabs for
companions and animals for reform and equity. We're human and animal wellbeing supports to my
knowledge we're the first animal welfare related new profit with a division specifically deaditied toward
Environmental Justice issues. And I just wanted to highlight and you know, emphasize the importance
of the human animal relationship and the Environmental Justice context. I personally live in a disaster
impacted area and also following Hurricane Katrina, so many stories of people who did not oaf ac wait
because they had animals, companion animals at home and they didn't take advantage of those critical
services that they would have need today preserve their own lives and wellbeing. So, I just wanted to
emphasize the importance of that relationship and weaving that wherever it can be in terms of
programming and applications for funding, just this past weekend we happened to distribute free pools
for companion animals of folks in the community who had been impacted by the heat wave. There are
currently no cooling centers for folks to go to and certainly not really many places that people can go to
with their companion animals and the result of that is that people might just stay home and face heat
stroke and other health related impacts because that relationship hasn't been considered. So those are
two examples. I do hope to follow up in more depth in writing and I appreciate the opportunity to speak
today. And look forward to joining the forum in the future.
Katherine Welty -1 am here today to bring my concerns to the NEJAC about EPA's assessment offence
lie community risks under the toxic's substances control act. I wanted to begin by thanking the NEJAC
for ongoing efforts and highlighting the harm to the fence line communities surrounding facilities where
toxic chemicals are manufactured, used, released or disposed or otherwise experience greater
exposures to harmful chemicals. Build out a more robust framework for the evaluation of future
chemicals while also taking immediate steps to improve the fence line assessment for chemicals already
been evaluated. The risk evaluation process requires EPA to ... exposures and risk and determine
whether the chemicals substance presents or will present an unreasonable risk of injury. EPA must
separately consider risks to susceptible subpopulations which are groups that either greater... planned
because I didn't somebody talking over. May face greater risks of harm these communities face severe
health risks more like I to be dealing with stress or underlying health conditions, limited access to health
care and psychological stress related to poverty and structural racism that can worsen the affects much
chemical exposures. Unfortunately, EPA's current fence line assessment approach to threads leads to
under estimation of chemical exposure and under estimation of risk of the methodology uses chemical
14
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NEJAC Public Comments for June 2022 Public Meeting/ By Region
by chemical facility by facility approach ignoring the reality that fence like community residence are
expose today multiple chemicals from multiple sources many of which have cumulative effects. EPA
claims it does not want to change its fence line approach to delay regulation of the 10 chemicals that
have already been assess and found to present unreasonable risk. However, the choice between doing
things quickly and doing things directly is a false dichotomy steps EPA can take now to allow for swift
regulation of chemicals while also ensuring fence line assessments are more reflective of community's
actual exposures and risks. We're asking NEJAC advise EPA to firstly, incorporate immediate
modifications for already assessed chemicals. Inleading the use of existing air modeling software to map
total chemical load, the inclusion of at least five years of chemical release data to better understand
estimated chemical exposures. The consideration of both pre-existing in fence line communities as well
as speak emissions from nearby facilities and the inclusion of uncertainty factor to better representative
cumulative impacts. Secondly, we ask you urge them to adopt broader changes to the fence lie
assessment approach that can strengthening the risk evaluation process going forward including
cumulative resoak analysis at outlined by NEJAC ... (fast) thank you all so much for your time and
consideration.
15
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G|K
Gallagher&Kennedy
David P. Kimball III
Shareholder
Direct: (602) 530-8221
Email: DPK@gknet.com
June 9, 2022
VIA U.S. MAIL & EMAIL
Michael S. Regan (regan.michael@epa. gov-)
Administrator
ENVIRONMENTAL PROTECTION AGENCY
Janet McCabe (mccabe.ianet@epa. gov)
Deputy Administrator
ENVIRONMENTAL PROTECTION AGENCY
David Uhlmann (uhlmann.david@epa.gov')
Assistant Administrator
OFFICE OF ENFORCEMENT AND COMPLIANCE
ASSURANCE ENVIRONMENTAL PROTECTION
AGENCY
Lawrence Starfield (starfield.lawrence@epa.gov)
A cting Assistant A dministrator
OFFICE OF ENFORCEMENT AND COMPLIANCE
ASSURANCE
ENVIRONMENTAL PROTECTION AGENCY
Matthew Teieda (teiada.matthewfa epa.gov)
Director
OFFICE OF ENVIRONMENTAL JUSTICE
ENVIRONMENTAL PROTECTION AGENCY
Cynthia Mackev (mackev.cvndv@epa.gov)
Director
OFFICE OF SITE REMEDIATION ENFORCEMENT
ENVIRONMENTAL PROTECTION AGENCY
Barry Breen (breen.barrv@epa. gov)
Acting Assistant Administrator
OFFICE OF LAND & EMERGENCY MANAGEMENT
ENVIRONMENTAL PROTECTION AGENCY
Carlton Waterhouse (waterhouse.carlton@epa.gov) Deputy
Assistant Administrator
OFFICE OF LAND & EMERGENCY MANAGEMENT
ENVIRONMENTAL PROTECTION AGENCY
Radhika Fox (fox.radhika@epa. gov)
Principal Deputy Assistant Administrator
OFFICE OF WATER
ENVIRONMENTAL PROTECTION AGENCY
Pam Mazakas (mazakas.pam@epa.gov)
Deputy Director
OFFICE OF CRIMINAL ENFORCEMENT,
FORENSICS & TRAINING
ENVIRONMENTAL PROTECTION AGENCY
Joseph Goffman (goffman. ioseph@epa. gov)
Acting Assistant Administrator
OFFICE OF AIR & RADIATION
ENVIRONMENTAL PROTECTION AGENCY
Alan Babcock (babcock.alan@epa. gov)
EJ Coordinator
ENVIRONMENTAL PROTECTION AGENCY
Brenda Mallorv (bmallorv@ceQ.eop.gov)
Chair
COUNCIL ON ENVIRONMENTALQUALITY
WHITE HOUSE
Jalonne White-Newsome (ialonne.white.newsoine@ceQ.eop.gov)
Senior Director
ENVIRONMENTAL JUSTICE
COUNCIL ON ENVIRONMENTAL QUALITY
WHITE HOUSE
Corey F. Solow (corev.f.solow@ceq.eop.gov)
Director
ENVIRONMENTAL JUSTICE
COUNCIL ON ENVIRONMENTAL QUALITY
WHITE HOUSE
Amanda Aguirre (amanda.aguirre@ceq.eop. gov)
Senior Advisor
ENVIRONMENTAL JUSTICE
COUNCIL ON ENVIRONMENTAL QUALITY
WHTE HOUSE
Karen L. Martin (martin.karenl@ena. gov)
Designated Federal Officer
OFFICE OF ENVIRONMENTAL JUSTICE ENVIRONMENTAL
PROTECTION AGENCY
Paula Flores-Gregg (flores.paula@,epa.gov)
Program Analyst
OFFICE OF ENVIRONMENTAL JUSTICE
ENVIRONMENTAL PROTECTION AGENCY
George OE Ward (ward. george@,epa. gov)
Program Analyst
OFFICE OF ENVIRONMENTAL JUSTICE
ENVIRONMENTAL PROTECTION AGENCY
2575 East Camelback Road I Phoenix. Arizona 85016-9225 ! P. 602-530-8000 I F: 602-530-8500 I www.gknet.com
8828556vl/21982-0001
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June 9, 2022
Page 2
Peggy Sheppard (pcggy@wcact.org)
Chair
INTERAGENCY COUNCIL ON ENVIRONMENTAL
JUSTICE
WHITE HOUSE
Dana Neal (daria,ncal@
Deputy Chief
FEDERAL COORDINATION & COMPLIANCE
SECTION
DEPARTMENT OF JUSTICE
Martha Guzman (Guznu
Regional Administrator
REGION 9 OFFICE OF THE REGIONAL
ADMINISTRATOR
Elizabeth Adams (A
Division Director
REGION 9 SUPERFUND & EMERGENCY
MANAGEMENT DIVISION
Will Duncan (DBWcan.Will@epa.gov)
Assistant Director
REGION 9 SUPERFUND & EMERGENCY
MANAGEMENT DIVISION
Emily Griffith gi~iffitli.ein.ilY@epa.gov
REGION 9 OFFICE OF REGIONAL COUNSEL
Cynthia M. Ferguson fcvnthia.foguson@usdoi .gov't
Senior Litigation Counsel
ENVIRONMENTAL JUSTICE, ENVIRONMENT &
NATURAL RESOURCES DIVISION
DEPARTMENT OF JUSTICE
Patrick Brevs.se fiijW@ccfci.gov)
Director
NATIONAL CENTER FOR ENVIRONMENTAL
HEALTH/AGENCY FOR TOXIC SUBSTANCES AND
L.SEASE REGISTRY
Re: Motorola 52nd Street National Priorities List Site. Phoenix. Arizona
Dear Federal Officials:
I am in receipt of EPA Region 9's January 28, 2022 letter in response to my September 9,
2021 letter and accompanying exhibits and January 13, 2022 follow-up correspondence that was
sent to all of you after more than four (4) months without any EPA response to my September 9,
2021 letter. A fter more than four (4) months of no response, Ms. Adams (as the Region 9 Director
of the Superfund & Emergency Management Division) simply attached EPA Region 9's previous
May 22, 2019 letter to her January 28, 2022 response under the false pretext that the May 22, 2019
EPA Region 9 letter "addresses the concerns raised again in [my] most recent correspondence."
Ms. Adams' premise that EPA Region 9's May 22, 2019 correspondence is responsive to the
serious environmental remedial action cleanup and human health exposure violations by EPA
Region 9, as detailed in my September 9, 2021 letter and accompanying exhibits, is grossly
misplaced and incorrect.
Contrary to EPA Region 9's self-serving and inaccurate statements in its May 22, 2019
letter, this letter and my September 9, 2021 letter and accompanying exhibits document serious,
on-going unlawful groundwater contamination, unsafe human exposures and social injustice
abuses directly caused by violations of applicable federal minimum remedial action cleanup and
human health exposure standards under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) bv EPA Region 9 at and relating to the federal
Motorola 52nd Street (M52) National Priorities List (NPL) Site in Phoenix, Arizona. These
violations within the federal M52 NPL Site directly and adversely impact the Arizona West Van
Buren Area (VVVBA) Water Quality Assurance Revolving Fund (WQARF) Site, which is a large
Arizona groundwater contamination site directly adjacent to and hydrologically downgradient
from the federal M52 NPL Site. The WQARP program is Arizona's equivalent to the federal
CERCLA program,
8828556vl/21982-0001
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June 9, 2022
Page 3
My earlier letters and EPA Region 9's prior responses related to my requests for EPA
assistance to continue, at that time, an active private voluntary groundwater pump and treat
remediation approved by the Arizona Department of Environmental Quality (ADEQ) within the
Arizona WVBA WQARF Site. That ADEQ-approved private wellhead groundwater remediation
was voluntarily initiated to protect public health and the private groundwater supply wells that
were impacted by unlawful groundwater contamination from releases of toxic chemicals by
unrelated third parties. That ADEQ-approved private wellhead groundwater pump and treat
remediation system cleaned up hazardous volatile organic compounds (VOCs) (as well as PFAS
chemicals) in the contaminated groundwater to "at least ... Maximum Contaminant Level Goals
established under the Safe Drinking Water Act" and "preclude!d] human exposure" to those
hazardous substances beyond the operating wellhead treatment systems, as expressly required
under the applicable Arizona aquifer water quality and WQARF groundwater remedial action
standards.1 The Arizona remedial action standards are consistent with the CERCLA minimum
groundwater remedial action cleanup and human exposure standards in Section 121(d)(2)(A) and
(B).2 That private, voluntarily funded and operated wellhead groundwater pump and treat
remediation system has since ceased operating after 8 years, due to EPA Region 9's failure under
the Tramp Administration to provide any requested assistance to continue that ADEQ-approved
groundwater remediation within the Arizona WVBA WQARF Site.
As a result, and as thoroughly discussed in my September 9, 2021 letter and accompanying
exhibits, groundwater contamination in violation of Arizona's applicable aquifer water quality
standards and directly attributable to releases of hazardous substances within the geographical
boundary of the hydrologically upgradient federal M52 NPL Site continues to be allowed by EPA
Region 9 to unlawfully migrate uncontrolled downgradient into the WVBA WQARF Site and
contaminant additional groundwater resources and be a continuing source of direct human
exposure to numerous hazardous and toxic substances present in the contaminated groundwater.
That unlawful groundwater contamination has been allowed by EPA Region 9 to unlawfully
migrate uncontrolled for decades and continues to unlawfully migrate from the federal M52 NPL
Site and, with the termination of the private voluntary downgradient wellhead groundwater pump
and treat remediation system in the WVBA WQARF Site, is now continually being pumped
without treatment by operating groundwater supply wells and released into the ambient air and
open-air canals in the WVBA WQARF Site, directly exposing the local low income, dominantly
minority community to hazardous VOCs, PFAS, 1, 4-Dioxane and other toxic chemicals. Such
continuing unlawful migration of unlawful groundwater contamination and the unsafe human
exposure to hazardous and toxic substances originating from releases within the federal M52 NPL
Site are in direct violation of the minimum remedial action cleanup and human health exposure
1 See, A.R.S. § 49-223.A ["Primary drinking water maximum contaminant levels [MCLsl established by the [EPA] administrator.. .are adopted
as drinking water aquifer water quality standards."!: See also, A.R.S. §§ 49-224.B; 49-282.06.A.2 and 49-282.06.B.4.b; A.A.C. R18-16-406.1;
A.A.C. R18-16-407.E. 1. ADEQ also restricts the relocation or transfer of contaminants from one environmental media (groundwater) to another
(air). See, letter from ADEQ Waste Programs Director to EPA Region 9 Superfund Director, dated November 14, 2007. These are all legally
"applicable or relevant and appropriate" (ARAR) cleanup standards under CERCLA Section 121(d) for the federal M52 NPL Site.
2 See, A.R.S. § 49-104.A. 16 ["The department TAPEO! shall, unless specifically authorized by the [Arizona] legislature, ensure state laws, rules,
standards, permits, variances and orders are adopted and construed to be consistent with and no more stringent than the corresponding federal law
that addresses the same subject matter."]
8828556vl/21982-0001
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June 9, 2022
Page 4
standards required under CERCLA Section 121(d)(2)(A) and (B) that legally apply to the federal
M52 NPL Site.
The Biden Administration EPA should not, and cannot, hide behind the May 22, 2019
response and analysis prepared by EPA Region 9 of the Tramp Administration that violate the
CERCLA minimum remedial action cleanup and human health exposure standards applicable to
the unlawful groundwater contamination originating within the federal M52 NPL Site. This is
especially true now that EPA in April 2022 has issued its Equity Action Plan under EPA Executive
Order (EO) 13985 that commits the Biden Administration EPA to make "equity, environmental
justice and civil rights a centerpiece of the agency's mission."3 "In practice, this means everyone
enjoys the same degree of protection from environmental and health hazards."4 In fact, EPA's
current top enforcement official in the Biden Administration recently pledged stepped-up
enforcement actions to fully address such CERCLA non-compliance.5 Accordingly, EPA should
pursue immediate active remedial cleanup and/or enforcement actions to prevent the historical and
on-going violations of the applicable CERCLA groundwater remedial action and human health
standards at the federal M52 NPL Site that are causing unsafe human exposure and disparate public
health protection of the local minority community to numerous toxic chemicals.
In EPA Region 9's May 22, 2019 letter, the Tramp Administration made excuses that are
in direct conflict with EPA's April 2022 Equity Action Plan (EO 13985). More importantly, those
EPA Region 9 excuses are all irrelevant to the minimum environmental remedial action cleanup
and human health exposure standards required as a matter of federal law under CERCLA. These
CERCLA standards legally apply to the unlawful groundwater contamination and toxic releases
originating within the federal M52 NPL Site that have been and continue to be allowed by EPA
Region 9 to unlawfully migrate uncontrolled downgradient and contaminate additional
groundwater resources and be released and directly exposed to the local minority community in
the WVBA WQARF Site.
My September 9, 2021 letter and accompanying exhibits didn't ask for EPA assistance to
continue the terminated private voluntary groundwater remediation system in the WVBA WQARF
Site. Instead, my September 9, 2021 letter seeks active EPA remedial action and/or enforcement
to address the unlawful groundwater contamination directly attributable to the federal M52 NPL
Site as required under federal law. Section 121 (d)(2)(A) of CERCLA expressly requires:
"Such [CERCLA] remedial action shall require a level or standard of control which
at least attains Maximum Contaminant Level Goals [MCLsl established under the
Safe Drinking Water Act."
Also, contrary to EPA Region 9's May 22, 2019 letter, CERCLA's minimum remedial
action cleanup standards expressly preclude application of the Clean Water Act surface water
quality criteria to the unlawful groundwater contamination that is being allowed to unlawfully
3 Executive Order 13985 Equity Action Plan; U.S. Environmental Protection Agency, April 2022, p.l.
4 Id. p.3.
5 Presentation by Larry Starfield, EPA Acting Enforcement Chief, American Bar Association, Washington D.C., May 24, 2022.
8828556vl/21tW2-O0ni
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June 9, 2022
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migrate uncontrolled from the federal M52 NPL Site and be directly exposed to the local minority
community in the WVBA WQARF Site:
"[Surface] [wjater quality criteria under the Clean Water Act ... may not be used
to establish applicable standards under this paragraph if the process assumes a point
of human exposure beyond the boundary of the facility ..."
The "no human exposure beyond the boundary of the facility" standard under CERCLA applies to
the wellhead of a groundwater supply "well" that has been impacted by unlawful groundwater
contamination that has been allowed by EPA Region 9 to unlawfully migrate from the federal M52
NPL Site. CERCLA defines the term "facility" to expressly include a "well" and expressly clarifies
that the boundary of a site or facility placed on the CERCLA National Priority List (NPL),
including the federal M52 NPL Site, "consists of all contaminated areas within the Fgeographic!
area used to identify the site, as well as any other location where that contamination has [migrated
and! come to be located."6
In short, as a matter of federal law, CERCLA requires the unlawful groundwater
contamination originating within and unlawfully migrating uncontrolled from the federal M52
NPL Site to be controlled and remediated "at least" to drinking water MCLs. Likewise, CERCLA
expressly prohibits human exposure to the hazardous substances in the contaminated groundwater
originating from the federal M52 NPL Site at any point beyond the boundary of any operating
groundwater supply well impacted by the unlawful groundwater contamination from the federal
M52 NPL Site if the hazardous substances in the groundwater have not been controlled and
remediated "at least" to drinking water MCLs. Additionally, and as expressly committed to by
EPA in its April 2022 Equity Action Plan (EO 13985), "equity, environmental justice and civil
rights," at a minimum, require compliance with these CERCLA minimum remedial action cleanup
and human health exposure standards, especially for hazardous substances from sites like the
federal M52 NPL Site that is considered one of the most contaminated sites in the country.
There is no excuse why EPA Region 9 for decades has not taken the minimum remedial
actions expressly required under CERCLA to adequately control and treat the unlawful
groundwater contamination and preclude any human exposure to the hazardous substances in the
contaminated groundwater directly attributable to releases of hazardous substances within the
federal M52 NPL Site that have been allowed to unlawfully migrate uncontrolled into the WBVA
WQARF Site. This is the environmental injustice to the local minority community that is fully
documented in my September 9, 2021 letter and accompanying exhibits. This is the environmental
injustice that EPA Region 9 during the Trump Administration in its May 22, 2019 letter ignores,
offering instead totally irrelevant and unlawful excuses to try and coverup decades of EPA Region
9 failure to comply with the CERCLA minimum remedial action cleanup and human health
exposure standards applicable to the federal M52 NPL Site. This is the environmental injustice
6 CERCLA Section 101(9); 42 (JSC § 9601 (9) (The term 'facility means (A) any building, structure, installation, equipment, pipe or pipeline
well, pit, pond, lagoon, impoundment, ditch, landfill, storage container, motor vehicle, rolling stock, or aircraft, or (B) any site or area where a
hazardous substance has been deposited, stored, disposed of, or placed, or otherwise come to be located...including contaminated groundwater
extraction wells). See also, 83 Fed Reg 2549, 2551 (2018); 85 Fed.Reg. 54931, 54932 (2020).
8828 556v 1121982-0001
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June 9, 2022
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that the Bid en Administration's EPA has pledged to address in its April 2022 Equity Action Plan
(EO 13985), and the environmental'-injustice violations that EPA's current chief enforcement
official has recently committed to take enforcement action against.
By continuing not to comply with or enforce the CHRCLA minimum remedial action
cleanup and human health exposure standards applicable to the unlawful groundwater
contamination originating within the federal M52 NPL Site, we can only presume that EPA Region
9 in its January 28, 2022 and May 22, 2019 letters is acting knowingly and intentionally, EPA
Region 9 is knowingly and intentionally refusing to apply the same and equally applicable
CEROLA minimum remedial action cleanup and human health exposure standards to the unlawful
groundwater contamination and released hazardous substances that EPA Region 9 has allowed to
unlawfully migrate uncontrolled beyond the current geographical boundary of the federal M52
NPL Site and are now being released and directly exposed to the local minority community in the
WVBA WQARF Site. Such continued unlawful inaction by EPA Region 9 clearly fails to provide
"the same degree of protection from environmental and health hazards" to the minority community
in the WVBA WQARF Site that the Biden Administration's EPA pledges in its April 2022 Equity
Action Plan (EO 13985) to make "a centerpiece of the agency's mission" and to take aggressive
actions to enforce,
EPA Region 9 tries to justify its disparate application and enforcement of the CERCLA
remedial action cleanup and human health exposure standards applicable to the unlawful
groundwater contamination and released hazardous substances that have been allowed by EPA
Region 9 to unlawfully migrate uncontrolled from the federal M52 NPL Site into the WVBA
WQARF Site by minimizing and downplaying the presumed human health exposure risk to the
downgradient local minority community in the WVBA WQARF Site. First, note EPA Region 9
doesn't dispute that the local minority community is being continually and directly exposed to
releases of known carcinogenic and other toxic substances despite the applicable "no human
exposure" CERCLA remedial action cleanup standard if the hazardous substances in the unlawful
groundwater contamination have not been controlled and treated to "at least" drinking water
MCLs. EPA Region 9 also tries to deflect attention away from EPA Region 9's decades-long
failure to fully comply with the CERCLA minimum, "drinking water MCL" and "no human
exposure beyond the boundary of the facility" remedial action cleanup standards applicable to the
federal M52 NPL Site, EPA Region 9 does this by arguing "no one is drinking groundwater" in
the WVBA WQARF Site and the ongoing releases of hazardous and toxic substances originating
from the federal M52 NPL Site to the ambient air and open-air canals from numerous operating
groundwater supply wells in the WVBA WQARF Site are "not impacting human health at levels
of concern" or "do not pose an acute risk to public health."
First and importantly, these so-called, risk-based arguments by EPA Region 9 are irrelevant
to the CERCLA minimum groundwater remedial action cleanup and human health exposure
standards applicable to the unlawful groundwater contamination and releases of hazardous
substances within the federal M52 NPL Site. The minimum CERCLA remedial action cleanup
standards specifically require "a level or standard of control which at least attains Maximum
Contaminant Level Goals established under the Safe Drinking Water Act" and no "point of human
8828 556v1/21982-0001
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June 9, 2022
Page 7
exposure beyond the boundary of the facility." More importantly, the local minority community
in the WVBA WQARF Site that is being subjected to unlawful and unsafe exposures to hazardous
and toxic substances originating from the federal M52 NPL Site has never agreed that the level of
unlawful groundwater contamination and toxic exposure to which it has been and continues to be
exposed is of "no concern" or that the 40-plus years of "chronic" exposure to known carcinogenic
and other toxic chemicals is acceptable as long as the exposure is not "acute." The WVBA
WQARF Site is not like any other VOC-contaminated site in Arizona (or Region 9 in all
likelihood) in that the local minority community has been exposed to uncontrolled hazardous VOC
emissions from more than 20 contaminated Roosevelt Irrigation District (RID) groundwater supply
wells for at least the past 40 years. Over 3,000 pounds of hazardous VOCs discharge into the
ambient air and open-air canals of this minority neighborhood every year.
Under CERCLA's applicable minimum remedial action cleanup standards, EPA Region 9
should have controlled migration from the federal M52 NPL Site of the hazardous VOCs, PFAS
and other toxic substances in the unlawful groundwater contamination, treated the unlawful
groundwater contamination from the federal M52 NPL Site to at least the applicable drinking water
MCLs, and precluded any human exposure to the hazardous substances in the unlawful
groundwater contamination that has migrated from the federal M52 NPL Site. The environmental
injustice suffered by the local minority community in Phoenix, Arizona as a result of EPA Region
9's failure to act, control and treat the unlawful groundwater contamination originating within and
unlawfully migrating uncontrolled from the federal M52 NPL Site as required under CERCLA is
demonstrably manifest by EPA Region 9's disparate treatment under CERCLA of the same
unlawful groundwater contamination within the geographical boundaries of Operating Units (OU)
1 and 2 of the federal M52 NPL Site.
Despite the undisputed facts that "no one [has or] is drinking the [contaminated]
groundwater" and there has never been any point of human exposure to the hazardous and toxic
substances in the contaminated groundwater within the geographical boundaries of the federal
M52 NPL Site, both EPA and ADEQ determined that "actual or threatened releases of hazardous
substances from this [federal M52 NPL] site, if not addressed by implementing the [pump and
treat] response action selected in the ROD, may present an imminent and substantial endangerment
to public health, welfare or the environment."7 Based on this determination by EPA and ADEQ
regarding the unlawful groundwater contamination solely within the boundaries of the federal M52
NPL Site, EPA Region 9, for more than 2 decades now, has required groundwater pump and
treatment to restore the aquifer to its applicable MCL drinking water aquifer water quality
standards and air-emission controls to preclude any human exposure to the hazardous substances
present in the contaminated groundwater at OU1 and OU2 of the federal M52 NPL Site since 1992
and 2001, respectively, as expressly required under the applicable CERCLA minimum remedial
action cleanup standards.
Yet, EPA Region 9 now wants us to accept in its May 22, 2019 letter that no CERCLA
remediation is necessary for the WVBA WQARF Site, where for multiple decades there is
8828556vl,21982-000
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June 9, 2022
Page 8
documented unlawful groundwater contamination above applicable Arizona aquifer water quality
standards and unsafe direct human exposure above EPA established not-to-be-exceeded air
exposure levels to the very same hazardous and toxic substances originating from releases to
groundwater within the federal M52 NPL Site that have been allowed by EPA Region 9 to
unlawfully migrate uncontrolled into the WVBA WQARJF Site. These are the same hazardous and
toxic substances whose mere presence within the federal M52 NPL Site, without any human
exposure, EPA and ADEQ determined more than 25 years ago present "an imminent and
substantial endangerment to public health, welfare or the environment" requiring active CERCLA
pump and treat remedial action at OU1 and OU2 of the M52 NPL Site.
Equally disturbing and unjustified is that, after extending the geographical boundary of the
federal M52 NPL Site in 1997 to include the large OU3 area downgradient of OU2 to address the
"co-mingling of regional VOC [groundwater] plumes"8 containing the same VOC and other toxic
chemicals found in OU1 and OU2 in concentrations that violate Arizona's applicable aquifer water
quality standards, EPA Region 9 for more than 25 years now has failed to initiate any active
remedial actions to comply with CERCLA's minimum remedial action cleanup standards at OU3.
Such EPA Region 9 inaction effectively has allowed the unlawful and unsafe hazardous and toxic
substances in the contaminated groundwater within the identified boundary of the federal M52
NPL Site, specifically from OU3, to continue to unlawfully migrate uncontrolled and contaminate
additional downgradient groundwater resources and be released and directly exposed to the local
minority community in the WVBA WQARF Site.
Furthermore, the health assessments referenced by EPA Region 9 are flawed and inaccurate
because they don't take into account the legally applicable drinking water MCL aquifer water
quality standards in Arizona, the increased toxicity established by EPA and adopted by the U.S.
Department of Health and Human Services for trichloroethene (TCE) (a known carcinogen and
only one of the many hazardous VOCs migrating from the federal M52 NPL Site) or acknowledge
that the air samples taken back in 2011 in the breathing zone where the public may be exposed
near the operating RID groundwater supply wells consistently exceeded the not-to-be-exceeded
air exposure level established by EPA in Region 10 for TCE of 2.0 micrograms per cubic meter
(ug/m3). Importantly, a TCE concentration of 29.0 ug/m3 was measured in ambient air near
neighborhood homes at one of the RID wells during the 2011 sampling activity. In addition to
excessive and unsafe concentrations of carcinogenic VOCs, other toxic chemicals in the
contaminated groundwater migrating from the federal M52 NPL Site, including PFAS and 1-4,
Dioxaee, are being released into the minority community.
We sincerely request that EPA Headquarters independently review the documented
information and data presented here and in the September 9,2021 letter and accompanying exhibits
and not allow Region 9 to continue to neglect and coverup its multi-decades history of remedial
non-compliance and failure to ensure equal protection of human health and the environment under
CERCLA from the unlawful groundwater contamination directly attributable and traceable to the
federal M52 NPL Site in Phoenix, Arizona.
8 201 1 CFRCl A Sitcvide Five-Year Review Report Motorola 5?"J Street Superfurid Site. Arizona Department of Environmental Quality, p. 17
SSISWni 21C»S2-0001
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June 9, 2022
Page 9
If EPA Headquarters refuses to investigate the violations of CERCLA's minimum remedial
action cleanup and human health exposure standards and resultant environmental injustices
directly attributable to those CFRCLA violations at the federal M52 NPL site, we will seek
appropriate investigations by EPA's External Civil Rights Compliance Office and the Justice
Department for violations by EPA Region 9 of the legally applicable CERCLA cleanup standards,
the Civil Rights Acts and President Biden's Environmental Justice Executive Order with respect
to the federal M52 NPL Site.
We are anxious to meet at your earliest convenience to discuss how this long-standing
public tragedy can be resolved.
Very truly yours,
GALLAGHER & KENNEDY, P.A.
cc: Misael Cabrera, ADEQ Director
Laura Malone, ADEQ Division Director
Mark Brnovich, Arizona Attorney General
Senator Stephanie Stahl Hamilton, LD10
Senator Rosanna Gabaldon, LD2
Senator Majority Leader Rick Gray, LD21
Senator Assistant Minority Leader Lupe Contreras, LD19
Senator Lisa Otondo, LD4
Senator Martin Quezada, LD29
Senator Rebecca Rios, LD27
House Rep. Assistant Minority Leader Jennifer L. Longdon, LD24
House Rep. Minority Whip Domingo DeGrazia, LD10
House Rep. Richard Andrade, LD29
House Minority Leader Reginald Bolding, LD27
House Rep. Cesar Chavez, LD29
House Rep. Diego Espinoza, LD19
House Rep. Diego Rodriguez, LD27
House Rep. Athena Salman, LD26
House Rep. Lorenzo Sierra, LD19
House Rep. Raquel Teran, LD30
House Staff Attorney & Policy Advisor, Ben Bryce
Steve Brittle, Don't Waste Arizona
Scott Meyer, Don't Waste Arizona
8828556vl/21982-0001
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June 9, 2022
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Richard Moore, WHEJAC
Carletta Tilousi, WHEJAC
Catherine Coleman Flowers, WHEJAC
Angelo Logan, WHEJAC
Rachel Morello-Frosch, PhD, WHEJAC
Viola Waghiyi, WHEJAC
Miya Yoshitani, WHEJAC
Jade Begay, WHEJAC
Kim Havey, WHEJAC
Kyle Whyte, PhD, WHEJAC
Hli Xyooj, WHEJAC
Tom Cormons, WHEJAC
LaTricea Adams, WHEJAC
Harold Mitchell, WHEJAC
Beverly Wright, PhD, WHEJAC
Susana Almanza, WHEJAC
Robert Bui lard, PhD, WHEJAC
Juan Parras, WHEJAC
Maria Belen Power, WHEJAC
Jerome Foster, WHEJAC
Andrea Delgado, WHEJAC
Maria Lopez-Nunez, WHEJAC
Michele Roberts, WHEJAC
Nicky Sheats, PhD, WHEJAC
Ruth Santiago, WHEJAC
Bryn K. DeFusco, Arizona Center for Law in the Public Interest
Abigail Dillen, Earthjustice
Fred Krupp, Environmental Defense Fund
Sandy Bahr, Sierra Club Grand Canyon Chapter
Dulce Juarez, CHISPA Arizona
Vianey Olivarria, CHISPA Arizona
8828556 vl/21982-000!
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Submitted via Email
July 6, 2022
National Environmental Justice Advisory Council
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Re: Earthjustice Written Comments on Disproportionate Harms to Farmworkers
from Organophosphate Pesticides Submitted as part of June 22, 2022 NEJAC
Meeting
Members of the National Environmental Justice Advisory Council ("NEJAC"),
Please accept these written comments as a supplement to the oral comments Earthjustice
provided at the June 22, 2022, meeting of the NEJAC. These comments highlight the
environmental injustices in the Environmental Protection Agency's review and regulation of
organophosphate pesticides that cause serious harm to farmworkers, their families, and
communities. EPA can take steps to address these injustices by ending its delays in completing
registration review of this dangerous class of pesticides and taking expeditious action to protect
workers and families from acute pesticide poisonings and neurodevelopmental harm to children.
I. EPA is delaying the statutorily mandated review of a dangerous class of pesticides
called organophosphate pesticides, or "OPs".
The Federal Fungicide, Insecticide, and Rodenticide Act ("FIFRA") requires EPA to complete
the registration review for 18 OPs by October 1st of this year to ensure they are safe for use. However,
under EPA's updated registration review schedule, released December 2, 2021, the agency will meet
this deadline for only three OPs (chlorpyrifos, chlorpyrifos-methyl, TCVP), and will miss the
deadline by as long as 3 years for the other 15. This delay is putting farmworkers, children, and
families living near fields where OPs are used at serious risk and posing environmental justice
concerns. Nationwide OP use data indicates that certain communities in areas with the highest
aggregate OP usage are low-income communities of color.1
II. EPA is aware of the decades of scientific research that shows that OPs are dangerous
to human health.
OPs are a class of neurotoxic pesticides, derived from chemicals originally developed by the
Nazis as nerve agents for war. OPs are chemically related to sarin gas. All OPs are acutely
neurotoxic, meaning that people who are exposed over a short period of time can experience
poisoning symptoms, including headaches, dizziness, vomiting, convulsions, and, in extreme cases,
1 Rashmi Joglekar & Hetty Chin, Earthjustice, Poisoned Food, Poisoned Brains: Mapping Dangerous Pesticides in the
Foods We Eat (2021), https://earthiustice.org/sites/default/files/files/20211118 comms op pesticide report.pdf
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Earthjustice Pesticide Injustice Comments, July 6, 2022
Page 2
respiratory failure leading to death. OPs are also linked to neurodevelopmental harm in children.
Dozens of published scientific studies over more than two decades show that exposure to extremely
low levels of OPs during early life can lead to irreversible harm to the developing brain, which can
result in long-term effects like attention disorders, autism, and reduced IQ.
In 2015, EPA reviewed the evidence and confirmed the link between OPs and
neurodevelopmental harm in a scientific literature review. This led the agency to retain the additional
tenfold margin of safety established by the 1996 Food Quality Protection Act (the "FQPA 10X safety
factor"), which is designed to account for the heightened susceptibility of children to pesticides when
establishing pesticide tolerances and assessing risk.
III. EPA's own draft risk assessments show that people face unacceptable risks from OPs,
including children and farmworkers, which raises serious environmental justice
concerns.
People are exposed to OPs through residues on food, contaminated water, and when pesticides
drift from where they are applied to where people live, work, go to school, and play. Children often
have greater exposure than adults to OPs due to their increased hand-to-mouth activity, and, for their
body weight, eat more fruits and vegetables, drink more water, and breathe more air. Farmworkers
face the highest exposures and risks from OPs when they apply these pesticides or enter fields where
OPs have been sprayed. And farmworkers and their families are more likely to live and go to school
near where OPs are sprayed.
EPA released preliminary human health risk assessments for all but one of the OPs
over the past six years, which document serious risks that exceed EPA's levels of concern,
which are the levels EPA associates with too much risk (see Table 1). Detailed findings from EPA's
preliminary human health risk assessments are summarized below:
a. Nearly all OPs pose risk to the general population from exposures through the diet,
which includes food and drinking water.
b. Children face the greatest risk of harm from exposure to OPs from food and/or
drinking water. As shown in Table 2 below, infants and toddlers experience
dangerous levels of dietary exposures to most OPs. For some OPs, including
bensulide, diazinon, ethoprop, and terbufos, dietary exposures in these young age
groups are over 100 times higher than EPA's levels of concern.
c. Farmworkers who directly handle the pesticides face alarming risks; all OPs
evaluated by EPA pose risks of concern to occupational handlers, some from all
tasks the workers perform, and some even with maximum protective clothing or
equipment and engineering controls. Most of the OPs pose severe risk to
occupational handlers, meaning that at least one use scenario exceeds EPA's risk
levels of concern by at least one order of magnitude, in some cases even after
considering maximum protective clothing or equipment and engineering controls.
d. OPs also pose risks of concern to field workers who enter fields following pesticide
application.
e. Two OPs (phosmet and malathion) pose risks of concern to children and adults from
exposures at pick-your-own farms.
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Earthjustice Pesticide Injustice Comments, July 6, 2022
Page 3
f. OPs also pose risks to bystanders, or people living near fields where pesticides are
used and sprayed.
EPA's risk assessment findings have languished in the agency without any measures being
put in place to protect children, workers, and bystanders.
IV. EPA continues to illegally delay protecting people from OPs to obtain unnecessary new
studies.
Despite the overwhelming scientific evidence, including epidemiologic data, linking OPs to
neurodevelopmental harm, during the Trump Administration, EPA considered removing the child-
protective FQPA 10X safety factor. It proposed this based on data derived from 'New Approach
Methodologies', or NAMs, which broadly includes toxicity tests that are rapid and inexpensive
compared to laboratory animal studies. While NAMs can provide useful information to support
or strengthen chemical hazard evaluations, scientists and policy experts have repeatedly
warned that they are limited in scope and cannot reliably predict risks for complex adverse
health outcomes, like cancer, diabetes, and neurodevelopmental disorders, including the
learning and behavioral problems associated with early-life exposure to OPs.
In December 2020, EPA's Scientific Advisory Panel ("SAP") issued a highly critical report
finding serious data gaps and substantive problems with EPA's proposed use of the NAMs tests for
its risk assessments of OPs.2 The SAP warned that due to the complex nature of neurodevelopment,
NAMs tests could not be used to accurately examine neurodevelopmental harm because they ".. .may
not be representative of many processes and mechanisms that could cause [such harm.]" Thus, the
SAP cautioned that NAMs could not be relied upon to set a safe exposure level or to eliminate
default safety factors, like the FQPA 10X safety factor, that provide measures of protection for
pregnant women and children.
EPA's Children's Health Protection Advisory Committee ("CHPAC") also warned in a recent
report against relying on NAMs to downgrade or weaken hazard evaluations.3
In defiance of the CHPAC and the SAP, EPA's Pesticide Office is requiring NAMs tests for
several OPs before moving forward with the registration reviews, introducing further unnecessary
delays. EPA already has the scientific evidence it needs to protect farmworkers and families from
this dangerous war-era class of pesticides. Waiting for data from NAMs tests that EPA's own
scientific experts have warned against using to evaluate the OPs is a scientifically unsupported
delay tactic that would leave families and farmworkers at risk.
2 Transmittal of Meeting Minutes and Final Report of the Federal Insecticide, Fungicide and Rodenticide Act, Scientific
Advisory Panel (FIFRA SAP) Virtual Meeting held on September 15-18, 2020 (Dec. 14, 2020) ("2020 NAM Report"),
https://www.re gulations.gov/document?D=EPA-HO-OPP-2020-0263-0Q54.
3 Children's Health Protection Advisory Committee. Letter to EPA acting administrator on protecting children's health
under amended TSCA: chemical prioritization. 2021. https://www.epa.gov/sites/default/files/2021 -
02/documents/2021.01.26 chpac tsca charge response letter.pdf
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Earthjustice Pesticide Injustice Comments, July 6, 2022
Page 4
V. EPA should act immediately to revoke food tolerances and cancel registrations for all
OP food uses EPA cannot prove to be safe.
EPA's OP risk assessments already document unsafe exposures to OPs from our food,
drinking water, and pesticide drift. These food-related uses are illegal and must end. Each year of
delay in ending OP uses exposes children to impairments in learning, social skills, motor function,
and other developmental harms. By October 1,2022, EPA should revoke all tolerances for unsafe
food uses and thereafter cancel registrations for all uses that cause unreasonable adverse effects
to workers, considering all of the routes of exposure, the full range of harms, and environmental
justice concerns. EPA's OP risk assessments document risks of concern from many activities workers
perform, including aerial spraying and broadcast ground spraying, yet EPA has delayed taking action
to protect workers from these risks.
VI. Given the role of this body as an Advisory Council to the EPA, we specifically ask this
Council to issue a statement urging EPA to:
a. Stop delaying the registration review of this dangerous class of pesticides;
b. Revoke food tolerances of admittedly unsafe used of all OPs expeditiously to
accelerate protecting people as fast as possible from harmful uses, and
c. Cancel registration for uses of OPs that cause unreasonable harm to
communities, farmworkers, and children.
If you have any questions about these comments, please contact Dr. Rashmi Joglekar,
Earthjustice, at rioglekar@earthiustice.org or Patti Goldman, Earthjustice, at
pgoldman@earthiustice.org. Thank you for your consideration.
Respectfully submitted,
Rashmi Joglekar, Ph.D.
Staff Scientist, Earthjustice
1001 G Street NW, Ste. 1000
Washington, DC 20001
(202) 667-4500
rioglekar@earthiustice.org
Patti Goldman
Senior Attorney, Earthjustice
810 Third Ave., Ste. 610
Seattle, WA 98104
(206)343-7340
pgoldman@earthiustice.org
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Earthjustice Pesticide Injustice Comments, July 6, 2022
Page 5
Table 1: OP Exposure Pathways of Concern, Worker Risks, and Health Effects
Acephate
~
¦
Bensulide
~
¦
Chlorethoxyfos
N/A
N/A
¦
C hlorpyrifos-methyl
N/A
~
N/A
¦
Diazinon
~
¦
Dichlorvos
N/A
~
N/A
¦
Dicrotophos
~
¦
Dimethoate
~
¦
Ethoprop
~
N/A
¦
Malathion
~
¦
Naled
~
¦
Phorate*
~
¦
Phosmet
~
¦
Terbufos
N/A
~
N/A
¦
Tribufos
¦
= an exposure pathway that is associated with risk levels of concern, according to EPA's human health risk assessments
~ = occupational handler exposure from one or more application methods (mixing/loading/applying) is associated with
severe risk, which we define as having a dermal and/or inhalation exposure that is one or more order(s) of
magnitude greater than EPA's risk level of concern.
= OP that is linked to neurodevelopmental harm based on human animal, and/or in vitro scientific studies.
N/A = an exposure pathway that is not expected for this pesticide because the OP is not sprayed in the air or it is not used
with field workers.
* = this table does not reflect any exposure pathways for phorate other than occupational handler exposures because EPA
has not conducted a human health risk assessment for phorate since 1999.
Note: Occupational handlers are workers involved in the pesticide application process. Occupational handlers can
experience varying exposures to pesticides due to the distinct job functions or tasks related to pesticide application,
which include mixing pesticide formulations, loading pesticide application apparatuses, and applying liquid or granular
pesticides to fields. EPA typically evaluates exposures to occupational handlers from dermal absorption of pesticide
residues and/or inhalation of pesticides during the application process. For all pesticides indicated above, one or more
use scenarios still pose risks of concern to handlers even if additional PPE or engineering controls are applied. EPA
provided insufficient information in the human health risk assessment to identity the severity of occupational handler
risk associated with Tribufos.
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Earthjustice Pesticide Injustice Comments, July 6, 2022
Page 6
Table 2: Dietary Risks of OPs in Infants and Children
MIJaUUUMW
ABE GROUP*
EPA'S RISK
THRESHOLD
Acephate
Infants
18
Bensullde
infants
>100
chlorethoxyros
Infants
240
ChlorpyrlTos- methyl
children
1.4
Dlazlnon
Infants, Children
>100
Olchlonras
Infants
5.9
Dlcrotophos
Infants
3.2
Dlmethoate
infants
12
Ethoprop
Infants
>100
Malathlon
Infants
4.8
Naled
Infants
5.5
Phosmet
infants. Children
19
"ferbufos
Infants
>100
Tributos
Infants
2.26
= an exposure pathway tliat is associated with risk levels of concern, according to EPA's human health risk assessments
* = Infants are defined as <1 year old. Children are defined as 1-2 years old.
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National Environmental Justice Advisory Council Public Meeting Comments
Oral comment provided June 22, 2022
Written comment provide July 6, 2022
Nathan Park
Associate Legislative Representative, Lead Exposure
Earthjustice
Dear NEJAC members,
My name is Nathan Park, and I am writing on behalf of Earthjustice, a public interest environmental law
organization working to protect people's health and the environment through the strength of our
partnerships and the law. I provided part of these comments at the June NEJAC meeting, and appreciate
the opportunity to follow up in writing about the Justice 40 Initiative.
Earthjustice continues to work with our partners on ensuring that the historic IIJA funding levels for lead
service line replacements are distributed equitably, in line with the administration's Justice 40 initiative.
To ensure that this happens and for the Biden administration to hold true on Justice 40, the EPA should
do the following:
> First, EPA should ensure that funded programs will fully pay for lead service line replacements
without charging individual property owners, and thereby avoiding exacerbating existing
inequities and civil rights concerns. Ensuring that federally-funded replacement does not
depend on the wealth of the property owner is paramount to avoid inequitable outcomes.
> Second, EPA should clarify that partial lead service line replacements cannot be funded using
any DWSRF funds, including for example DWSRF-funded water main replacement programs. If a
lead service line (including a lead connector like a gooseneck or pigtail) is touched using SRF
funds, the full lead service line must be replaced at utility expense.1
> Third, EPA must overhaul the Lead & Copper Rule (LCR) by late 2023, making the upcoming
Lead and Copper Rule Improvements (LCRI) transformative and truly protective of public health
rather than merely "tweaking" the existing fundamentally flawed regulation. For decades,
advocates across the country have conveyed the urgency of this crisis at every turn, and another
round of "tweaking" the LCR will not only undercut the historic investments in lead service line
1 In Response to the question posed by Sylvia Orduno during the public meeting on June 22, 2022, regarding
examples of communities where partial lead service line replacements are a concern, I wanted to share the
following, informed by my colleagues at Earthjustice and the Natural Resources Defense Council: any water utility
with lead service lines that has done water main repairs or replacements and requires residents to pay for the
portion under private property will have partial lead service lines. The exception is the state of Michigan, which
requires under the state's 2018 LCR for water utilities to remove and rate base full lead service line replacements
and bans partials (however, this does not address the partial lead service line replacements that happened over
previous decades. For example, this letter from DC Water in Washington, DC indicates that there are over 11,000
partial lead service line replacements across the District.
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removal Congress recently authorized but, more importantly, it will condemn another
generation of families to exposure to dangerous levels of lead in drinking water.
EPA promised in December 2021 to overhaul and strengthen the health protections in its Lead and
Copper Rule (LCR) for drinking water, while letting the Trump administration LCR Revisions go into
effect. Notably, those reforms leave much to be desired. Among other issues, they:
Set up a weak and voluntary testing program at schools and childcare centers after the first
year, missing an opportunity to use strong incentives to protect children in the places they go
for numerous hours each day to learn and play;
include a narrowed definition of "lead service line" excluding lead joints and connectors that
can be up to several feet long, and that contribute to lead contamination in water;
Slowed down the rate at which water systems must replace lead service lines once they are
required to under the rule; and
Permitted over 90 percent of all water systems to avoid lead service line replacement
altogether, regardless of how high lead levels are, due to the rule's treatment of small systems.
A new LCR must require all lead service lines to be removed in 10 years. Strengthening the LCR will allow
the Biden administration and state and local water agencies to identify and ensure that communities
disproportionately burdened by leaded drinking water will be prioritized for lead service line
replacement.
I am additionally glad to see the administration's June update, announcing that HUD has made available
$500 million for states and local governments to address lead-based paint hazards. Earthjustice supports
the administration's commitment to targeting these dollars towards disadvantaged communities in line
with Justice40. However, under HUD's Section 8 and Housing Choice Voucher (HCV) inspection
protocols, there is no requirement for tenant-based Section 8 housing and HCV units to be inspect for
lead hazards at anytime, not even upon turnover. Additionally, although there are disclosure
requirements, they are not effective. Inspections requirements will ensure that tenants have needed
information about lead in housing. This means that in units built before 1978 with Section 8 tenants,
when lead was banned in paint, many lead hazards are going unidentified.
With no hazards identified, these federally assisted housing units will not receive any of the $500 million
that HUD has made available to remediate, actively leaving people and children living in Section 8
housing at risk, if they are not already suffering from lead poisoning. We know that folks living in
federally assisted housing units are disproportionately affected by environmental and health hazards2,
so ensuring that federal dollars reach them should be central to the administration's Justice 40 work. To
that end, the EPA should join HUD in its repeated calls to Congress for a mandate to inspect public
housing for lead hazards. The Biden administration should also work with Congress to pass the Lead Safe
Housing for Kids Act, spearheaded by Rep. McEachin in the House and Sen. Durbin in the Senate. This
bill creates for HUD the needed mandate to require inspection of federally assisted housing where
children under the age of 6 will reside, in addition to strengthening the way that lead hazard inspections
are conducted in federally assisted housing units.
2 See the "Poisonous Homes" report, published by the Shriver Center on Poverty Law, Earthjustice, the Abrams
Environmental Law Clinic at the University of Chicago, and the Columbia Law School in June, 2020.
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Finally, funding and work to address lead-based paint hazards will not protect children and other
residents if the hazard standards are not health-based and protective. It is critically important that EPA
revise its lead hazard standards as soon as possible, in light of a federal appellate court finding that they
are woefully outdated and under-protective. It is also critical for EPA to work with HUD to revise the
definition of lead based paint for purposes of identifying lead paint in older residences, since the current
definition is more than 50 times less protective than the standard for how much lead can be present in
paint sold today.
Lead poisoning continues to plague communities across the country, causing irreversible harm to
children and people of all ages. There is no safe level of lead in the body, and it is imperative that EPA,
HUD, and other federal and state agencies work together to eliminate all lead hazards and end lead
poisoning. Thank you for your work and your consideration of these comments.
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Dear Chairman Kern and Fellow Board Members.
I'm a general and cosmetic dentist and am opposed to water
fluoridation in part because I treat patients harmed by
fluoridation. That's right. I make a living in part by treating both
functional (chips, broken, and fractured teeth) and cosmetic dental
fluorosis. Dental fluorosis is a bio-marker the child was exposed to
too much fluoride before the age of about six.
For many years, I supported fluoridation. Like virtually all dentists, I
heard mostly good things about it in dental school and the American
Dental Association (ADA) has promoted it from the beginning.
But I also have a degree in public health, and when I started
researching fluoridation, I found that it's minimally effective at
preventing cavities, if at all, and far more concerning, raises all
kinds of health risks when ingested. After 25 years of promotion, I
changed my mind. It was the rational, science-based bioethical
thing to do.
There's already a consensus that fluoride's effectiveness is mainly
topical, not swallowed. World Health Organization data show cavity
rates in children have dropped as much in developed nations that
don't fluoridate as in those that do. Clearly, fluoridation is not
essential for health. And the Cochrane Collaboration, considered the
gold standard of evaluating effectiveness, found no good evidence
of cavity reduction in adults nor diminishing of the gap in cavity
rates between low-income and higher-income families. I worked on
two Native American reservations and two low-income communities
and now with the very wealthy. The wealthy have better health and
teeth than the poor. My experience is consistent with quality
research that fluoridation does not benefit the poor nor reduce the
disparity. In fact, fluoridation actually harms the poor the most.
But even supposing fluoridation was effective, how could it possibly
justify the health risks it poses?
One of the most serious is neurotoxicity - permanent brain damage
- the focus of the ongoing lawsuit against the EPA for allowing
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fluoridation. It's based on massive, ever-increasing scientific
evidence showing fluoride is lowering IQs and increasing ADHD
rates in children. Please consider the science - and the scientists. I
can fix teeth damage but not brain damage.
The Fluoride Action Network has documented that out of 83 human
neurotoxicity studies, 74 linked higher fluoride levels to lower IQs.
The National Toxicology Program's most recent systematic review
draft found that of the highest quality studies, 25 out of 27 linked
higher fluoride levels to lower IQ's, 13 studies at levels in
fluoridated water. Even the EPA acknowledged in court what it
considered the four strongest studies ever done, three funded by
the National Institutes of Health. Three showed significantly lowered
IQs in children and one showed substantially increased ADHD rates
- all at levels in fluoridated water.
A recent study led by world-renowned scientists Philippe Grandjean
and Bruce Lanphear determined that fluoride levels in water at 0.2
parts per million (ppm) could lower IQs in children through ingestion
from their mothers while pregnant. The supposedly "safe"
fluoridation level of 0.7 ppm added to water and is rejected by most
of the world. The authors concluded the results should inspire a
revision of water-fluoride recommendations aimed at protecting
pregnant women and young childrenPlease warn pregnant mom's
to not ingest fluoridated water and do not swallow fluoridated
toothpaste.
It's no wonder that the editor of the Journal of the American Medical
Association Pediatrics, a Seattle physician, said I would not have
my wife drink fluoridated water" if she was pregnant.
How can anyone look at all these studies - and the prestigious
scientists that back them up - and still say fluoridation is proven
safe for everyone? Yet the ADA, CDC's oral health department and
organizations that follow them still support it. Either they're
unaware of the science or refuse to acknowledge it and we, the
public, suffer the consequences.
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Neurotoxicity is just the tip of the iceberg. The National Research
Council found that ingested fluoride can increase fluorosis, diabetes
and kidney malfunction and lower thyroid levels, among other
conditions. Hypothyroidism, for instance, can cause a variety of
harmful effects, including fatigue, weight gain, impaired memory,
joint pain and depression. According to the American Thyroid
Association, about 4% of Americans suffer hypothyroidism, many of
them unaware of it.
We've seen this before - wrongfully defending substances for
decades like lead paint, leaded gas, asbestos, DDT, Agent Orange
and cigarettes before finally banning, restricting or advising against
them. Meanwhile, millions of people were unknowingly - and
unnecessarily - suffering serious harm to their health. We're now
witnessing the same scenario with fluoridation.
However, fluoridation is ethically far worse. Governments give it to
us without consent, regardless of whether we are getting too much
from other sources. And in spite of the fact that the Food and Drug
Administration has approved topical fluoridated toothpaste with the
warning, "Do Not Swallow." The FDA's concern is the same amount
of fluoride as put in each glass of fluoridated water. Why can't
people see the disconnect. One government agency, the one
authorized to evaluate fluoride when intended to prevent dental
caries, warns "Do Not Swallow" the same amount of fluoride as
another government agency (city/water purveyor) requires in each
glass of water. Makes no sense.
Dentistry is my chosen profession and we dentists gain significant
profit from fluoridation. You may think conspiracy, but that is not
true. Remember, I recommended fluoridation for 25 years because
I did not recognize some of the chipped broken teeth were from the
excess fluoride from fluoridation. I was too busy to read the
science. People chip and break teeth. I simply did not consider
fluoridation contributed to the breaking.
As a cosmetic dentist patients come to me to fix dental fluorosis
cosmetic damage. Research indicates about 70% of children now
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have some degree of dental fluorosis damage. Damage is cost, not
the repairs. For example, suppose a very wealthy person scratched
your car. Would you consider the scratch cosmetic damage? Most
would. Knowing it was a very wealthy person who caused the
damage would you accept compensation? Probably. Cosmetic
damage is damage and the true cost of damage must be included in
costs.
You probably have heard the phrase, "every dollar spent on
fluoridation saves $38." That phrase is just part of the
equation. The true costs of buildings, labor, installation, repairs, etc
. . . are not included. Real world estimates report closer to $3 to $6
savings for every dollar spent on fluoridation. And none of those
estimates include any harm to patients, such as the known dental
fluorosis damage we dentists treat, Nor do the estimates include
the presumed loss of IQ, 60% increase in low IQ. Lower IQ
subpopulations have increased percentages of special education,
incarceration, divorce, lower wages, less happiness and quality of
life. Costs to society for those with lower IQ are in the many
billions/trillions of dollars. We must not harm the brain. We find
the same decrease in the percentage of very gifted, and all of us are
harmed.
When a patient comes to me for cosmetic dental treatment from
dental fluorosis it can require many teeth to be repaired, on average
about 10 teeth. At about $1,200 per tooth, re treated about every
12 years on average, the costs just for tooth damage is estimated
at over $150 for every dollar spent on fluoridation.
Your job for your vote is judgment and avoid blind trust. The
Nuffeld Council reviewed the ethics of fluoridation and requires
judgment on risk of fluoridation to be at the "potential" of
risk. Many serious health harms from fluoride have "potential"
risk. Stronger evidence is "presumed" risk and lower IQ is
"presumed" to result from fluoride exposure. The next higher level
of evidence is "known" risk. Dentists treat "known" harm of dental
fluorosis contributed by fluoridation.
-------
I know many dentists who feel the same as I do, but they are
reluctant to speak out for fear of criticism and controversy and
being shunned or disciplined by their peers. Silence and following
the majority is safer for respect from colleagues and makes more
money.
Fluoridation was a well-intended effort to reduce cavities and the
vast majority of people who support it are similarly well-intended.
But serious health risks have proven it a tragic mistake. This is
such a truncated brief overview. Please contact me if you have
questions.
Sincerely yours,
Bill Osmunson, DDS, MPH
Bellevue, Washington
I have been a practicing general and cosmetic dentist for 44 years
and clinical instructor for cosmetic and functional dentistry.
bill@teachinasmiles.com
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Dr. Ellen Griffith Spears
Environmental Historians Action Collaborative
July 1, 2022
Thank you for the opportunity to submit comments to the NEJAC. I am writing today to urge the
NEJAC to invest in helping to preserve an important section of the EPA Web Archive, which the
agency has announced will sunset in July 2022. Although it is not the responsibility of the Office
of Environmental Justice alone, but a priority for the whole agency to preserve the archived
material, I believe it would be significant if the NEJAC went on record in favor of maintaining
and upgrading the archive.
The announced closure applies to a specific segment of the archive, the EPA Web Archive.
Excluded from the sunset provision are the official publications posted in the NEPIS database at
the National Service Center for Environmental Publications (NSCEP). EPA has also noted that
the press releases now on the EPA Web Archive will be migrated and preserved. However, my
understanding is that as many as 420,000 unique pages on the EPA Web Archive will ultimately
be affected by the change, including valuable documents from the Clinton and Obama
administrations about climate change. More than likely, all the documents will not go away
overnight, but, over time, the archive, already in need of an upgrade, will gradually become less
easy to use, less comprehensive, and of diminishing value as a resource for historians and the
public.
My concern is that environmental justice communities will be especially affected by the loss of
this historical data. My own experience, working in depth in communities such as Gainesville,
Georgia, with the Newtown Florist Club and in Anniston, Alabama, with the Sweet Valley/Cobb
Town Environmental Justice Task Force and Community Against Pollution, suggests that the
Web Archive is quite useful for residents of affected communities. Recently, I found the archive
invaluable in doing research in Holt, Alabama, in Tuscaloosa County, where we found
information about the history of the agency's investigations there.
Local people are often first to recognize cases of environmental injustice. An archival search is
often useful as residents work to uncover prior EPA involvement and to bring pollution concerns
to the EPA's current attention. Traveling to a regional print repository is expensive, often
impossible, and digital access provides the ability to search far more efficiently.
The agency argues that the cost of maintaining the archive makes retaining it prohibitive. I would
argue that there is a much larger cost to losing this record of EPA actions. Sunsetting the archive
would not only be a loss for historians and the public, but for the agency itself. In the words of
the historians' letter sent to EPA Administrator Michael Regan on June 14, the archive preserves
"the vital work done by this federal agency, whose own future hinges on greater public
awareness of and support for what it does."
I am enclosing with my comments two letters that were sent on June 14,2022, to Administrator
Regan, so NEJAC members and OEJ staff will have this material at hand. I hope that the NEJAC
can invest in retaining these resources, mainly by allocating time and human capital in the
immediate term to convince the agency as a whole to commit the resources necessary to preserve
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this valuable material as part of the commendable priority being placed on environmental justice
by this administration.
The EPA may be unique among federal bureaucracies in the extent to whichfollowing various
laws starting with NEPA, reinforced by William Ruckelshaus's 1983 commitment to operate "in
a fishbowl," certainly with EPCRA and Community Right-to-Knowto prioritizing public
access and transparency. Maintaining that commitment is a sacred trust with the American
people. Thank you.
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I'm writing in response to Dr. Rachel Brennan's May 19 presentation on water fluoridation and her
committee's recommendation to have State College discontinue it. I totally agree.
My background is in management of non-profit health organizations. I worked for the American Cancer
Society for 21 years, the last five as executive vice president (CEO) of the Oregon chapter. I also worked
seven years as the founder and project director of the Oregon Physicians for Social Responsibility's safe
food program. I'm now retired.
I'm not a physician or scientist but throughout my life I've worked with them and I currently volunteer with
a large group of scientific, medical and dental professionals throughout North America opposing water
fluoridation.
For many years, I favored fluoridation. I only looked at who had endorsed it. I had heard many times from
authorities, and repeated by most media, that it was "safe and effective" for everyone. The main promoters
were the Centers for Disease Control (CDC) and the American Dental Association. Many other organizations
followed their lead.
Then, about 11 years ago, I was asked by a friend to research the issue. When I did, two things stood out.
First, high-quality scientific studies showed that there were numerous harmful health conditions linked to
ingested fluoride, many at levels in fluoridated water. They included permanent brain damage, especially IQ
loss, hypersensitivity, lowered thyroid function and kidney disease, to name a few. Second, the vast
majority of nations and cities in the world had rejected fluoridation, many of them explicitly disallowing it.
Based on this new information, I changed my mind. I felt so strongly that I volunteered to oppose
fluoridation wherever and whenever I could. I've put in thousands of hours studying and working on this
issue and have been amazed - and chagrined - at the amount of misinformation supporting it. To cite just
one example, out of many: "Fluoridation is one of the top 10 health achievements of the 20th century." At
one time, I believed this myself. When I took a closer look, I found out differently:
1. Out of 196 nations, only 24 have any fluoridation and only 10 for more than half their population.
The U.S. fluoridates as many people as the rest of the world combined. How can fluoridation be
such a great achievement when it's so widely rejected? It can't.
2. All of the other "top 10" health achievements have been adopted world-wide, such as recognition
of tobacco as a health hazard, decline in deaths from heart disease and family planning.
Fluoridation is the only one out of the 10 not widely accepted.
I believe that the vast majority of people and organizations who favor fluoridation are well-intended.
However, I'm quite sure they're unaware of the science, especially the most recent, demonstrating
fluoridation's harmful health effects.
Dr. Brennan's presentation touched on just one of those harmful health effects, loss of IQ. She highlighted
one major peer-reviewed study (Green et al), published in the Journal of the American Medical Association
Pediatrics. After this study was published, the editor, a Seattle physician, was quoted in the Washington
Post saying that if his wife were pregnant, he wouldn't want her drinking fluoridated water. Many other
leading scientists, including the former director of the National Toxicology Program, Dr. Linda Birnbaum,
have publicly voiced similar warnings (https://www.ehn.org/fluoride-and-childrens-health-
2648120286.html).
Out of 83 published studies, 74 have found that higher fluoride levels are linked to lower IQs in children
(https://fluoridealert.org/studies/brain01/). The National Toxicology Program's draft report, soon to be
-------
finalized, found that out of the 27 highest-quality studies, 25 linked higher fluoride with lower IQs, nearly a
dozen at levels in fluoridated water.
The scientific evidence couldn't be more abundantly clear that fluoridation can't be declared safe.
I was especially glad to hear that you are going by the tenets of the Precautionary Principle. Indeed, when
your responsibility is protecting the health of your citizens, you're doing your due diligence that, if you err,
you err on the side of caution.
Thank you for your consideration.
Sincerely,
Rick North
503-706-0352
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I'irsl Name
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Rachel
A Meidl
Baker Institute for Public Policy
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Luke
Jones
EPA-OITA
Bandana
Kar
Oak Ridge National Laboratory
Adrienne
Katner
LSUHSC
LaDonn
Kay lor
Idaho Dept of Environmental Quality
Chandler
Keenan
FDEP
Melvin
Keener
CRWI
Samuel
Kefauver
University of Maryland College Park CEEJH
Sharon
Kenny
U.S. EPA
Jenny
Keroack
HHS
Ferdous
Khan
Shanghai World Fashion
Lee
Killinger
Florida Crystals
Toshia
King
OLEM/ORCR/PIID/F STPB
John
Kinsman
Edison Electric Institute
Sarah
Kirkle
Texas Water Conservation Association
Suzanne
Kline
CA SWRCB - DDW - SAFER
Elizabeth
Kloeckner
academic
Trish
Koman
USEPA
Renee
Kramer
North Carolina Depart of Environ Quality
Fran
Kremer
USEPA
Rachel
Krogman
Slipstream
Emma
Kurnat-Thoma
Georgetown University NHS
Johanna
Kuspert
Maricopa County Air Quality Department
Jessica
Kutz
The 19th news org.
Krista
Kyle
TCEQ
Kim
Lambert
U.S. Fish and Wildlife Service
Katie
Lambeth
EGLE
Charles
Lee
EPA
Kristin
Lehman
FEMA
Cassidy
Leight
EPA
Leo
Lentsch
Civil and Environmental Consultants
Mel
Lewis
American Rivers
55
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Candace
Lewis
EPA
Kristine
Li even
KindAx
Marisa
Liles
Environmental Protection Agency
Osmond
Lindo
EPA
C
Liv
HHS
Stacey
Lobatos
EPA
Olivia
Lopez
Ocean Conservancy
Paulina
Lopez-Santos
ECOS
Michelle
Lovejoy
Environmental Defense Fund
Laurel
Lynn Rowse
Mississippi State Department of Health
Gabriella
Mabayyed
Environmental Policy Innovation Center
Richard
Mabion
Building A Sustainable Earth C
Arianna
Mackey
EDF
Ariel
MacMillan-Sanchez
U.S. EPA-Region 5
David
Magdangal
US EPA
Gretchen
Mallari
Pierce County Planning & Public Works
Krista
Mantsch
GAO
Larissa
Mark
EPA
Chris
Marks
Arizona Department of Environmental Quality
Janette
Marsh
US EPA Region 5
Carolyn
Marsh
Save Whiting and Neighbors
Brittney
Martinez
FERC
Arsenio
Mataka
HHS
Shifali
Mathews
AECOM
Hollis
Maye-Key
Environmental Protection Agency
Eileen
Mayer
US EPA
Terri
McCartney
Hopland Band of Pomo Indians
Colby
McClain
EPA GMD
Caitlin
McHale
National Mining Association
Rosemary
Mena-Werth
GreenLatinos
Erin
Middleton
Carbon Solutions LLC
Kathryn
Millard
US EPA
Mike
Miller
TCEQ
Ty
Mills
Miller-Wenhold Capitol Strategies
Ayanna
Miranda
Maryland Department of the Environment
Ronald
Moore
Cincinnati Children's Hospital Medical Center
Richard
Moore
Los Jardines Institute
Brie
Morris
Green Thumbs for Black Power
Brandon
Morton
Dallas College
Christina
Motilall
US EPA
John
Mueller
Private citizen
Bailey
Mullen
Illinois Farm Bureau
Robert
Murphy
Unitarian Universalists
56
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Knowledge
Murphy
Multnomah County/Office of Sustainability
Dana
Neely
Afton Chemical Corporation
Paulette
Nellems
Crown Colony Housing Addition
Lin
Nelson
Evergreen State College
Khai
Nguyen
Song CDC
Loan
Nguyen
USEPA
William
Nichols
US EPA
Sari
Nichols
Nevada Indian Commission
Jeffrey
Norcross
EPA Region 1
Avriel
Null
TVA
Leanne
Nurse
The Nature Conservancy
Onyemaechi
Nweke
USEPA
Ngozi
Nwosu
City of Dallas
Tim
O'Connell
USD A Rural Development
Li am
O'Fallon
NIEHS
Shaina
Oliver
Independent
Sarah
01 sen
Missouri Department of Natural Resources
John
Oluwaleye
Public Health and Human Rights Issues
Alana
Paccione
FERC
Ramon
Palencia-Calvo
Maryland LCV-Chispa Maryland
Monica
Palmeira
Greenlining Institute
Joel
Pannell
American Forests
Nathan
Park
Earthjustice
Juan
Parras
T.E.J.AS.
Ana
Parras
Texas Environmental Justice Advocacy
Services
Regan
Patterson
UCLA
Drue
Pearce
Holland & Hart LLP
Alexandrea
Perez
EPA
Victor
Perez (SOCI/CJ)
University of Delaware
Brett
Perlman
Center for Houston's Future
Kandyce
Perry
NJ Dept. of Environmental Protection
Maricel
Perryman
San Juan Bay Estuary Program
Cynthia
Peurifoy
Retired
Mary
Peveto
Neighbors for Clean Air
Eleanor
Phillips
Private Citizen
Laura
Phillips-Alvarez
Center for Environ Health and Environ Justice
Issamar
Pichardo - CEO
Colorado Energy Office
Randy
Pitre
EPA Region 6
Betty
Pittard
BP Consultation
Brian
Pontious
DANR
Kristel
Porter
MN Renewable Now
Sharron
Porter
Environmental Protection Agency
57
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Tasheena
Powers
EPA
Chris
Pressnall
Illinois EPA
Andrea
Price
EPA
Micah
Prior
Macedonia Development Corporation (MDC)
Karl a
R
VT ANR
Carlos
Ramirez-Gomez
Nevada Office of Minority Health and Equity
Emily
Ranson
Clean Water Action / Clean Water Fund
Holly
Ravesloot
HHS
Veda
Reed
EPA
Dawn
Reeves
Inside EPA
Amani
Reid
POWER Interfaith
Sean
Reilly
E&E News
Mayra
Reiter
Farmworker Justice
Zachariah
Richardson
State of Michigan
Leslie
Ritts
NED A/CAP
Rey
Rivera - EPA
US EPA
LaKeshia
Robertson
EPA
Lori
Rock
BigldeaZoo, LLC
Olivia
Rodriguez
Federal Govt
Sarah
Rowlands
Colorado AGs Office
Michelle
Rutledge
Self
Elyse
Salinas
US EPA
Virginia
Sanders
Sierra Club
Denise
Sarchiapone
B&D Environmental Consulting
Francisco
Sayu
RENEW
Grant
Scarboro
CEEJH
Robert
Schmidt
Greenville Water
Rachel
Schneider
DHS/CBP
Dean
Scott
Bloomberg
Hilary
Scott
NexGen Ind.
Isabel
Segarra Trevino
Harris County Attorney
Mario
Sengco
U.S. EPA
Danielle
Shannon
US EPA
Gina
Shirey
Alaska Department of Environ Conservation
Sarah
Sieloff
MFA
Vanessa
Simms
EPA
Brianna
Skinner
US Food and Drug Administration
Robert
Skoglund
Covestro LLC
Matthew
Small
U.S. EPA
Bernice
Smith
EPA
Dan
Solitz
Privat citizen
Steven
Sondheim
Sierra
Marisa
Sotolongo
Northeastern University
58
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Ellen
Spears
University of Alabama
Gianna
St.Julien
Tulane University Law School
Joanna
Stancil
USDA-FS
Dimitri
Stanich
Water Resources Control Board
Symone
Stephens
CEEJH
Tracy
Stephens
NA
Andrew
Stoeckle
ERG
Michael
Strieker
MD Dept of the Environment
Alice
Sung
Greenbank Associates
Feleena
Sutton
Aera Energy
Frank
Sylvester
US Environmental Protection Agency
Ean
Tafoya
GreenLatinos
Silvia
Tanner
Multnomah County Office of Sustainability
Debra
Tellez
U.S. EPA
Murielle
Tembunde
CEEJH EJ summer scholar
Abby
Tennant
NA
Hillary
Thomas
EJCC-MN
Tami
Thomas-Burton
EPA-R4
Joe
Tiago
EPA
Akisha
Townsend Eaton
Companions & Animals for Reform & Equity
Kathy
Triantafillou
EPA
James
Trice
Environ Justice Coordinating Council (EJCC)
Johnathon
Truong
LASAN
Venus
Uttchin
govt
Kat
Vakhromeeva
CEEJH
Jennifer
Valiulis
St. Croix Environmental Association
Sonita
Van der Leeuw
Iowa Environmental Council
Alicia
Vasto
Iowa Environmental Council
hector
Velez
USEPA
Carmen
Velez Vega
University of Puerto Rico
Esperanza
Vielma
EJCW
Marline
Vignier
HHS/OASH
Cynthia
Vital e
Colorado Attorney General's Office
Ashley
Voskuhl
ASDWA
Mary
Walker
Gulf Coast Ecosystem Restoration Council
Walt
Walker
Greeley and Hansen
Jess
Wallace
EPA
Jocelyn
Walters-Brannon
South Carolina depart of health and environ
Alan
Walts
EPA Region 5
Phillip
Washington
USD A
Cheryl
Watson
Blacks In Green
Lawrence
Weinstock
EPA
Angus
Welch
U.S. EPA
59
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Katherine
Welty
Earthjustice
Zaria
Wetzel
University of Maryland
Chad
Whiteman
U.S. Chamber of Commerce
Odette
Wilkens
Wired Broadband, Inc.
Daniel
Wilkus
Evergy, Inc.
Stephanie
Williams
Maryland Department of the Environment
Jane
Williams
California Communities Against Toxics
Rebecca
Williams
Vermont DEC
Tracy
Williams
Advocate
Daphne
Wilson
EPA Region 4
Samuel
Winans
UMD CEEJH
Ginger
Wireman
WA Dept. of Ecology, Nuclear Waste Program
Leah
Wood
Washington State Department of Health
Zach
Yamada
WPRFMC
Carolyn
Yee
California Environ Protection Agency
Suzanne
Yohannan
Inside EPA
Karen
Youngblood
Cinergi Group LLC
Dani
Zacky
Sierra Club
Rachel
Zander
Iowa DNR
Steven
Zuiss
Koch
60
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