Data-Quality Assessment Signals Toxic-Site Safety Threats and Environmental Injustices

Abstract

Most hazardous-waste sites are located in urban areas populated by disproportionate numbers of children, minorities, and poor people who, as a result, face more severe pollution threats and environmental-health inequalities. Partly to address this harm, in 2017 the United Nations unanimously endorsed the New Urban Agenda, which includes redeveloping urban-infill-toxic-waste sites. However, no systematic, independent analyses assess the public-health adequacy of such hazardous-facility redevelopments. Our objective is to provide a preliminary data-quality assessment (PDQA) of urban-infill-toxic-site testing, conducted by private redevelopers, including whether it adequately addresses pollution threats. To this end, we used two qualitative, weight-of-evidence methods. Method 1 employs nine criteria to select assessments for PDQA and help control for confounders. To conduct PDQA, Method 2 uses three US Environmental Protection Agency standards—the temporal, geographical, and technological representativeness of sampling. Our Method 1 results reveal four current toxic-site assessments (by CBRE/Trammell Crow, the world’s largest commercial developer); at all of these sites the main risk drivers are solvents, volatile organic compounds, including trichloroethylene. Our Method 2 results indicate that all four assessments violate most PDQA standards and systematically underestimate health risk. These results reveal environmental injustice, disproportionate health threats to children/minorities/poor people at all four sites. Although preliminary, our conclusion is that alleviating harm and environmental-health inequalities posed by urban-infill-toxic-site pollution may require improving both the testing/cleanup/redevelopment requirements of the New Urban Agenda and the regulatory oversight of assessment and remediation performed by private redevelopers.

Does Hazardous-Waste Testing Follow Technical Guidance, Thus Help Protect Environmental Justice and Health?

“…Yet because random or accidental violations should have bidirectional effects, this testing (sites assessed here) appears biased. Such VOC undertesting/underreporting also is consistent with TC's risk under-calculation, which violates DTSC calculation requirements (see Supplementary Materials S2, Section S2.8) and is consistent with earlier analyses showing that TC testing has failed data-quality analysis [84], scientific-data audits [85], and data-usability analysis [86].…”

“…(2) All violations are unidirectional and uniformly underreport risks; (3) No site assessors explain/defend these testing-violations, as the regulator requires; none show reasons that their VOC testing was equivalent to required testing (see A1); (4) TC repeatedly misrepresents its privatized testing as reliable (see Question 1), instead of being transparent about its tests; (5) The results of this analysis, showing testingrequirement violations at representative waste sites, are consistent with other results, showing that testing at representative waste sites also fails data-quality analysis [84].…”

“…TC-testing violations also threaten health because, at least at the sites examined here, TC appears to misrepresent its flawed, privatized testing as reliable [84,85]. For example, Canoga-Park assessors ignored DTSC-approved TCFM SLs or health-protective levels [10] (Appendix D, Table 3); see Supplementary Materials S1, (Table S1).…”

“…As already mentioned, no refereed publications-except in 2021 by the author [84] -systematically assess whether hazardous-waste testing, most of which is privatized, violates testing requirements such as scientific standards. However, some literature generally supports the results of this analysis.…”

Correction: Shrader-Frechette, K.; Biondo, A.M. Data-Quality Assessment Signals Toxic-Site Safety Threats and Environmental Injustices. Int. J. Environ. Res. Public Health 2021, 18, 2012

“…The authors would like to make the following corrections (1 and 2) to this paper [1]. Regarding correction 1, in the earlier paper we inadvertently used the statistics for no sampling of currently occupied site buildings instead of current site buildings.…”