What is the Industrial Facility Risk Gap?
More than 40 years of regulating Oregon air pollution has made a real difference, but there are still air toxics emissions that must be better understood and controlled to ensure protection of public health. The current situation at several art glass facilities where metals emissions have been at levels of concern has highlighted what DEQ and others have called a gap or a risk gap in the state’s regulations for air toxics.
The graphic roughly illustrates that gap. Assuming all air toxics in Oregon are within the whole shape, the ovals show levels of coverage.
The inner oval shows the body of federal regulations for air toxics. This includes several steps including technology based requirements and a review at remaining risk for each regulated sector.
While federal air toxics regulations have been very effective at reducing emissions and health risk nationally, they have limitations based on their generic nature. They are not tailored to each facility, and do not require site specific risk assessment or risk reduction. Federal regulations at times do not cover all of a facility’s emissions or apply to smaller facilities within a category. So in some cases they may adequately reduce potential health impacts, and in others they may not.
The middle ring shows DEQ’s geographically based air toxics program. This approach, used in the Portland Air Toxics Solutions Project, evaluates industrial emissions as part of the whole airshed, but has not been exact enough to understand or control risk to people in neighborhoods close to facilities. The geographic approach works well to identify problems and form partnerships to make needed changes.
The geographic approach may be best suited to understanding and reducing pollution from multiple wide-spread sources such as wood burning and engines.
The outer ring represents the gap: industrial air toxics emissions that are not adequately addressed by either federal regulations or Oregon’s current geographic approach.