Survey: Settings Risk & Cumulative Risk Step 1 of 14 - Slide 1 7% Introduction Public health protection is at the heart of Cleaner Air Oregon. The Oregon Health Authority is engaged in this process to ensure that the process results in regulations that adequately protect health. The word "risk" is used a lot during these presentations—it refers to risks to health as opposed to any other kind of risk. Reducing health risk from breathing air toxics is the way we are protecting health. Breathing air that contains a lot of air toxics can increase risks of experiencing health problems. For example, many air toxics can increase the risk of developing various types of cancer, respiratory problems, and can even impair normal brain development in children. That is why the Oregon Health Authority and DEQ care so much about reducing health risks from air toxics. Air toxics are emitted by cars, trucks, wildfires, residential wood burning and, more. However, the sources of air toxics emissions Cleaner Air Oregon focuses on are those emissions from industrial facilities throughout the state of Oregon. Health Risk Levels Many government programs that regulate air toxics emissions from industrial facilities seek to protect public health by limiting air toxics emissions so that they don't exceed risk goals. Some examples of air toxics include hexavalent chromium, benzene, naphthalene and arsenic. DEQ's air monitoring equipment measures the concentration of air toxics in the air, and state agencies compare those measured air toxics concentrations against established risk levels or goals. So the established risk levels are really important to how air monitoring data are interpreted and how DEQ regulates facilities that emit those air toxics. Oregon in context (state rankings) Oregon's ranking on key economic, environmental and health measures for context. Sources: 25th Per capita income - Source: United States Census Bureau http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_14_1YR_DP03&prodType=table Manufacturing: Source: National Association of Manufacturers http://www.nam.org/Data-and-Reports/State-Manufacturing-Data/ Unemployment: http://www.bls.gov/web/laus/laumstrk.htm Pollution: http://scorecard.goodguide.com/ranking/rank-states.tcl Pollution: http://scorecard.goodguide.com/ranking/rank-states.tcl?type=mass&category=total_env&modifier=na&how_many=100 Everyday risks Risk in this context is about probability or the chance that something bad will happen. For example, a 10% chance means 10 chances out of 100. This graphic shows different kinds of everyday risks with high risk (or most likely to happen) on the left moving to low risk (or least likely to happen) on the right. The observed chance of getting some kind of cancer over the course of your lifetime is 1 in 3 (meaning that chances are 1 in 3 of us will get some kind of cancer over the course of our lifetime). That is unrelated to any particular environmental exposure or exposure to air toxics from any particular source. You can see where things like having a stroke, dying in a car or home accident or getting struck by lightning fall on the continuum of probability. Keep in mind that all of these things do happen. People do get struck by lightning, this is just showing that the average person is much less likely to get struck by lightning than they are to die in a car accident. Oregon has some non-enforceable air quality goals for air toxics that are set at a 1 in 1 million risk level. That means that the goals are set so that you could breathe that air for your lifetime and have no more than a 1 in 1 million chance of having a health effect that is related to the air you breathe. Again these benchmarks are non-enforceable air quality goals, not legal standards. Other state and federal agencies allow for flexible ranges of risk from air toxics that generally fall within this bracket of 1 in 1 million to 1 in 10,000. How Do Risks from Air Quality Compare with Other Risks to Public Health? This is a chart published in an article in the Journal of the American Medical Association in 2013. It isn't perfect because it isn't specific to Oregon and it isn't specific to the air toxics that Cleaner Air Oregon will address. But it is useful for some perspective in that it ranks the 17 leading risk factors for early death in the United States. Two of the leading 17 risk factors are directly related to air quality: ambient particulate matter pollution at #8 and ozone pollution at #15. These are criteria pollutants that do have federal regulatory requirements, but it may help give some broad and general perspective of air quality risks compared to other health risks. "Allowable" Risk It is important to understand what "allowable risk" or levels of risk that are "allowed," means. Everyone would like to prevent any additional risk beyond what people already have, but people in the United States live in a developed world with an economic and social infrastructure that produces pollutants. We want to reduce risk, but there will never be zero risk. When agencies use the term "allowable risk" they mean the relatively very low risk targets set out in regulations. In general, the lower the risk level you try to achieve, the higher the cost. There are innovative and exciting exceptions to this generalization, but generally this is the case. Choose the statement you agree with most:Regulations should...*A. Recognize the cost of compliance for the facility by allowing the most technically feasible emission controls to continue to operate, even if it does not meet 1 in a million risk protection standard.B. Set most protective risk levels, even if this puts jobs at risk and the health risk reduction benefit is small (e.g., 1 in a million risk standard or beyond).C. Provide flexibility in setting risk levels, based on facility size, proximity to neighboring residences and other factors while maintaining a minimum level.D. Set consistent and protective risk levels that are uniform for an industry, even if some facilities may not be able to operate because they cannot comply.E. Don’t know/Not sure Understanding Cumulative Risk The topic of cumulative risk relates to whether or not / how a new regulatory program for air toxics emissions from industrial facilities should address different kinds of cumulative risk. The Cleaner Air Oregon technical workgroup that was convened by OHA and DEQ over the summer addressed a broad array of considerations related to cumulative risk. The four types of cumulative risk addressed in this presentation are the ones that stood out in the work group's conversations. Cumulative Health Risk When OHA and DEQ refer to "cumulative risk" in developing a new air toxics permitting program, it means the combined health risk from multiple things. People are not exposed to one toxic air pollutant at a time or to pollutants from one source at a time. In reality, the air we breathe is a mixture that is influenced by all sources and inputs in the area. There are many ways of looking at cumulative risk. The examples considered in this presentation are: Combined risk from multiple air toxics emitted from a single facility Combined risk from air toxics from multiple industrial facilities in an area Combined risk from community sources – this means all kinds of sources beyond just industrial facilities. This would include traffic-related air toxics, residential wood burning, wildfires, etc. Combined risk from multiple routes of exposure – the most common example of this is mercury, which is emitted into air where it can be inhaled, but then settles on soils, with which people can come into contact . Mercury can also be concentrated through the food chain in fish that people eat. These different examples of cumulative risk are not mutually exclusive of one another, and could be occurring at the same time. A regulatory system could address more than one type of cumulative risk. Health Risks from Multiple Air Toxics from a Single Facility People aren't exposed to one air toxic at a time. The air around us is a mixture of gases and substances, some good (oxygen, nitrogen) and some harmful, like air toxics. Some states include health risks from multiple pollutants. Others don't. Accounting for the toxicity of the overall mixture in permitting decisions most accurately reflects the air that people actually breathe and therefore tends to be the most protective of health. States that look at one air toxic at a time tend to use very conservative/health protective allowable risk levels, so that even if there are multiple air toxics right at their limits, the cumulative risk is still low. One way to think about this is a bucket of risk, where potential disease could happen if the bucket overflows. Having very low allowable risk levels for individual air toxics, is like trying to leave a lot of room in that bucket to allow for additional risk from other air toxics without having the bucket overflow. Currently, Oregon is one of the states that takes this approach with existing non-regulatory benchmarks; Rhode Island is another. There are some regulatory challenges associated with addressing cumulative risk from multiple air toxics: Regulating cumulative risk is more costly than regulating one air toxic at a time, primarily due to complexity. However, in the case of air toxics, it is often the case that one emission control technology works on many air toxics, so it need not always cost more to reduce cumulative risk. It may be difficult to understand whether all of a facility's air toxics are present at the same time— they may be phased or occur as needed for production. There can also be uncertainty in estimating quantities of multiple air toxics. Some are harder to track or estimate than others, for example those that come out of a stack are better known, and those that may escape from a building's windows or doors are harder to quantify. Health Risks from Multiple Industrial Facilities in an Area Cumulative risk from multiple industrial facilities is very important for communities that are disproportionately impacted by air toxics from industry. Often times, the people with the least resilience to the effects of air toxics are also the people who end up breathing air with the highest concentrations of air toxics. For example, the cheapest properties are often located closest to sources of air toxics, such as multiple industrial facilities or highways. This compounds people's risks from air toxics and other stressors in their lives. One of the most powerful ways to ensure that the overall risk to all communities is low in a regulatory program is to make sure that cumulative risk from multiple industrial facilities is considered in permitting decisions. There are regulatory challenges in addressing cumulative risk from multiple sources of air toxics in an area : All of the same uncertainties involved with evaluating cumulative risk from multiple chemicals from one facility are multiplied when looking at cumulative effects from nearby facilities. There will be additional necessary assumptions and uncertainties from modeling concentrations from nearby facilities. Since the bulk of air toxics causing risk to the most people come from mobile and other community sources, evaluating cumulative risk only from nearby industrial facilities may place an unwarranted focus on the local impacts of industrial facilities. The exception would be emissions in an area that is dominated by industry. Health Risks from Community Sources There are other sources of air toxics in addition to industrial facilities. Examples of other sources are car and truck engines, residential wood burning, wildfires, agricultural burning, and even aircraft emissions. All of these sources generate air toxics. For the purpose of policy forum discussions, DEQ and OHA are calling air toxics from sources other than industrial facilities "community sources". Sometimes people also refer to these as background sources. Incorporating this type of cumulative risk in facility permitting is very protective of public health especially for those communities with disproportionate impacts. For example, a neighborhood surrounded by a railyard, a freeway and an industrial facility will likely have cheap housing but also multiple sources of air toxics. People who can't afford to live anywhere else often live in such locations. Communities like these also often have the least resources to advocate for improvements in their environment. Incorporating this type of cumulative risk into regulatory decision-making would be an effective way to protect the health of these vulnerable and disproportionately impacted communities. Some states require facilities to consider risks from community air toxics in applying for their permit, while others don't. States that don't attempt to address this using the previous bucket analogy - setting allowable risk from the permitted facility low enough to leave plenty of room in the risk bucket for other sources to contribute without having the risk bucket overflow. The same regulatory challenges from the last two types of cumulative risk apply for community sources, in addition to several more: It can be difficult to know what the risks from community sources are. With industrial facilities DEQ can find out directly from the facility what their emissions are. However, the same kind of emissions inventory doesn't exist for community sources. Airsheds are complex and there is limited monitoring data. Some communities will have some and others will not. NATA is a computer model run by the federal EPA that DEQ can use to estimate community air toxics emissions—statewide, however it has limitations: Any model makes assumptions that could be right most of the time but wrong in some cases. This introduces uncertainty. NATA is only as dependable or accurate as the emissions inventory that goes into it, and there can be gaps there Also, it is intended for screening purposes and not analysis or regulatory application. NATA may also focus on different health effects for toxic air pollutants than DEQ or OHA has found to be the most important one in a community Incorporating risk from community emissions into permits for industrial facilities could lead to competitive disadvantages for businesses when they are not the main source of air toxics in a community. Health Risks from Multiple Exposure Pathways Toxics emitted to air don't necessarily stay in the air. Mercury is the classic example of a chemical that can start out as an air toxic from coal or other organic combustion processes, and eventually settle out on soil or water. Mercury on soil eventually washes into surface water with rain run off. Once in the water, microorganisms convert that mercury into a form that bioaccumulates up the food chain until top predator fish, like bass, have levels of mercury in their tissues that can pose a risk to humans who catch and eat the fish. In most cases, the inhalation exposures do pose the greatest health risk because we absorb things into our blood streams so well through our lungs and because chemicals don't get a chance to be detoxified in our livers when absorbed through the lungs the way they do when swallowed. As a result, many states assume that if their regulatory programs protect against unsafe inhalation exposures, they will also be protecting against those other exposures. However, there are also several states (all of the ones researched by OHA and DEQ) that account for this kind of cross-media risk in their industrial air permits in some way. Usually they only apply it to air toxics that are known to bioaccumulate or persist for a long time in the environment, such as mercury. It may not make sense for air toxics that tend to break down into less toxic chemicals quickly, or light gases that tend not to settle out onto soil or water. Accounting for this type of multiple pathway cumulative risk is health protective, but makes the most difference for that subset of air toxics that are known to persist or bioaccumulate in the environment. As with any additional layer of complexity, there would be an increased cost of implementation and compliance in addressing this type of cumulative risk. Rank the following This question asks you to rank in priority order your top three choices among the different types of cumulative risk in order of importance for consideration in developing an air toxics permitting program. Please prioritize the three most important cumulative health risks you feel DEQ should consider when making air quality permit decisions relative to air toxics. (Select top 3 options.)A. A facility releasing multiple air toxicsB. Other facilities within an area that could also be releasing air toxicsC. Existing levels of air toxics from community sourcesD. Possibility of air toxics exposure from buildup in soils and fish or shellfishClick and drag the statements into the order of importance from top (most important) to bottom (least important). This iframe contains the logic required to handle AJAX powered Gravity Forms.