All last week, USA Today published a series of articles detailing the findings of its investigation into the toxic air pollutants afflicting many of the schools throughout the United States. Using models developed by EPA for tracking toxic chemicals, USA Today investigators evaluated and ranked air quality for some 127,800 schools. In particular, these models were able—through the use of computer simulations—to predict the dispersal of toxic chemicals released by 20,000 industrial polluters during roughly the last decade. By combining these models with a map containing the locations of the various schools, investigators were able to predict the likely air quality outside the schools, and determine how air quality has changed over time.
The findings of this investigation were startling, to say the least. At roughly one-quarter of the schools studied, the toxic air pollution levels increased significantly over the course of 10 years. Thus, even as overall air quality has improved in the United States over the past few years, we have allowed many of the most vulnerable members of the population to slip through the cracks. Perhaps most disturbing, the models suggest a correlation between school locations and increased levels of toxic air pollutants. At roughly 13 percent of the schools studied, the air contained at least twice the amount of toxic pollutants as compared to the average for the school district in which the school is located. This statistic brings to mind the studies on environmental justice conducted in the 1980s, which found a statistically significant correlation between the siting of toxic waste dumps and communities of low-income and racial minorities. That was, with good reason, called environmental racism. What might we call the environmental consequences that result from the apparent second-class status that we have imposed on our nation’s youth?
While USA Today’s investigation has been helpful for calling attention to the issue of children and toxics, it may have actually underestimated how dangerous the impaired air quality outside of schools really is. The study uses for its yardstick risk assessments of particular chemicals that have been found outside of schools. The risk assessments attempt to summarize the risks posed by certain chemicals (e.g., exposure to a certain amount of a certain chemical poses a risk of cancer). The problem is that particular risk assessments may not always adequately account for children’s unique vulnerabilities to certain chemicals or adverse effects.
For example, huge gaps in knowledge regarding environmental dangers persist, gaps sufficient to undermine the accuracy of particular risk assessments. Invariably, the gaps lead to underestimation of environmental risks, thereby placing children in unreasonable and unacceptable risk. One such gap was noted in CPR’s recent report, Protecting Public Health and the Environment by the Stroke of a Presidential Pen:
The Integrated Risk Information System (IRIS), an EPA database of toxicological profiles used by regulators around the world, lacks “inhalation values” (the numbers that determine when exposure to air pollution could harm people) for most hazardous air pollutants. The absence of these inhalation values makes it difficult to set hazardous air pollutant standards that are protective of children’s health.
Setting proper air toxics standards is particularly important for children for a number of reasons. In comparison to adults, children breathe faster and spend more time outdoors (such as at recess), leaving them disproportionately vulnerable to air pollutants. To make maters worse, children are physiologically fragile because they are still developing important physiological systems, such as their neurological systems. As a result, pollutants that adversely affect these systems can impair development, causing damage that can never be undone.
Given that particular risk assessments do not always properly account for children’s unique vulnerabilities, we have to wonder whether the USA Today investigation actually managed to capture the full scope of the danger hanging in the air outside of schools. For instance, the study discusses one school in Ohio, in which the levels of toxic air pollutants created a cancer risk 50 times greater than what is deemed acceptable according to the particular risk assessments performed for those chemicals. If the risk assessments did not properly account for children’s unique vulnerabilities, then the risk of cancer for the school’s students may have actually been greater.
Obviously, much needs to be done to address the situation of toxic air pollutants afflicting U.S. schools. CPR’s recent Executive Order report, however, suggests a good starting point for the incoming Obama administration. One of its recommendations calls on President-elect Obama to amend the existing Executive Order on protecting children. Two of the provisions in the amended Order could have a profound impact for cleaning up the air around schools. First, the amended Order would require federal environmental and public health agencies to develop an affirmative agenda for identifying the threats to children posed by toxics and for taking steps to eliminate children’s exposure to these threats. Ideally, with an affirmative agenda, agencies can begin the difficult work of regulating these toxic risks, rather than having to react to reports of risks, such as the one presented in the USA Today investigation. Second, the amended Order would require these same federal agencies to reform their risk assessment policies, so that they properly account for the vulnerabilities of children. A properly reformed risk assessment process would provide a more complete picture of the adverse health effects that children suffer as a result of their exposure to environmental risks. If adopted, these two provisions of the amended Order—along with other important measures—can make schools a safe place for learning and growing again.
For information on the Bush Administration’s efforts to make federal risk assessments less protective of people and more tolerant of risk, go here.
