What exactly is a health-based standard?

Cleaner Air Oregon

What exactly is a health-based standard? State toxicologist Dave Farrer breaks down what it means to create air quality laws focused on public health

Dave Farrer is the kind of guy that you want to have over for family dinner, or as your kid’s soccer coach. In a room full of people, his presence is gentle and thoughtful, like a professor standing in a lecture hall.

But his calm demeanor becomes spirited when asked about air toxics and what’s happening with the Cleaner Air Oregon Advisory Committee. Knowing that there might be confusion about what, exactly, a “health-based standard” is, we sat down with Dave to learn more about what it means and what the CAO Advisory Committee is doing.

Thanks for chatting, Dave. The air toxics regulatory process is a complex one, full of scientific jargon and complicated laws. So in relation to air regulation, what exactly is a health-based standard? How is it different than what we have in place now?

DF: Happy to chat, this is a very important issue. The air permitting rules currently in place for air toxics coming from industrial sources require that the appropriate control technologies be applied to different types of industrial equipment––but they do not set emissions limits or account for impacts to the next-door neighbors of regulated industrial facilities. Under Cleaner Air Oregon rules, the health of nearby and next-door neighbors to industrial facilities will be explicitly addressed in the permitting process. Hence “health-based” standard.
What is the Cleaner Air Oregon Advisory Committee looking at when planning for health-based standards then? 

DF: The committee is considering whether or not, and how, combined risk to multiple sources and types of air toxics should be addressed when granting permits to industrial facilities. The committee is also discussing levels of health risk from air toxics that could be considered allowable. The answers to these questions will guide how health-based standards and emissions limits will be set.

How do we assess health (versus risk) based standards, and what would the permitting process look like for this moving forward?

DF: When we talk about risks, we are talking about risks to public health. We protect public health by reducing health risks posed by air toxics. Under the new program, industrial facilities seeking a permit would have to demonstrate that the health risks they are posing to their neighbors do not exceed allowable levels.

Environmental justice is a major piece of this work. The Cleaner Air Oregon Advisory Committee co-chairs have characterized it as a driver for all of the committee’s work. How do environmental justice principles fit into this, and how does a health-based (versus risk-based) approach protect our neighbors and vulnerable communities?

DF: Environmental justice is essentially defined as the disproportionate and cumulative impact of multiple harmful environmental exposures to a specific community. Lower cost properties are often located in areas with the most exposure to air toxics from roads and industrial air emissions. So people who can’t afford to live anywhere else, and often with multiple other stressors in their lives, also end up breathing air with the highest concentration and greatest variety of air toxics. Cleaner Air Oregon is seeking to address this reality in a few ways––namely how to ensure that cumulative risk from multiple air toxics and multiple sources are incorporated into the process for granting operating permits to industrial facilities and industrial businesses.

Thanks again for the time, Dave. Anything to add as we wrap up?

DF: A lot is already happening, but there’s still work to do as the committee dives in and works on the complex details at play, so I urge everyone to tune in as this process moves forward with draft rules scheduled for spring 2017. I’d also add that ongoing public engagement and input is critical to this work, so I urge everyone to weigh in and share feedback throughout.


The next Cleaner Air Oregon Advisory Committee meeting is December 8, from 9 a.m. to 5 p.m. at the Ambridge Event Center, 1333 NE MLK Jr. Blvd, in Portland. Online and call-in options will be available.

For more information and a full recap of the meeting and rulemaking process: