We are concerned that Quemetco contested the Department of Toxic Substances Control’s October 30, 2015 directive to begin soil sampling and investigation immediately, following the Modified Quemetco Investigation Work Plan. We find Quemetco’s refusal to comply with the scope and thoroughness of DTSC’s plan very troubling and, frankly, irresponsible, given that there has never been any investigation of the extent and nature of the contamination in the neighborhoods that have grown up around this facility since it began operations in 1959.
It’s important to note that our current understanding of lead and arsenic exposure in children is much different than what it was when past health risk assessments of Quemetco’s emissions were conducted. Knowing about the problems Quemetco had with lead emissions in 1998 and arsenic emissions in 2013 and not yet having seen the latest HRA, we must be concerned with the exposure of our children, who are the most vulnerable. With this new understanding just last year the California Office of Environmental Health Hazard Assessment (OEHHA) updated the HRA guidelines to account better for early childhood exposures.
"Over the past 10 years, advances in science have shown that early-life exposures to air toxics contribute to an increased lifetime risk of developing cancer or other adverse health effects, compared to exposures that occur in adulthood. Children are typically more sensitive than adults to chemicals and this is true of air toxics; children’s defenses are not as developed, they breathe faster, and they are far more active than adults. In addition, they have a longer lifetime ahead of them, during which delayed health effects may become apparent." [1]
This new understanding absolutely compels us to insist that Quemetco’s application to process up to 25 percent more batteries be denied.
[1] “Frequently Asked Questions March 6, 2015 Release of OEHHA Risk Assessment Guidance Manual and ARB Hotspots Analysis and Reporting Program (HARP) Software” (http://www.sdapcd.org/homepage/FAQ-OEHHA.pdf). See also: http://www.oehha.ca.gov/air/hot_spots/hotspots2015.html
It’s important to note that our current understanding of lead and arsenic exposure in children is much different than what it was when past health risk assessments of Quemetco’s emissions were conducted. Knowing about the problems Quemetco had with lead emissions in 1998 and arsenic emissions in 2013 and not yet having seen the latest HRA, we must be concerned with the exposure of our children, who are the most vulnerable. With this new understanding just last year the California Office of Environmental Health Hazard Assessment (OEHHA) updated the HRA guidelines to account better for early childhood exposures.
"Over the past 10 years, advances in science have shown that early-life exposures to air toxics contribute to an increased lifetime risk of developing cancer or other adverse health effects, compared to exposures that occur in adulthood. Children are typically more sensitive than adults to chemicals and this is true of air toxics; children’s defenses are not as developed, they breathe faster, and they are far more active than adults. In addition, they have a longer lifetime ahead of them, during which delayed health effects may become apparent." [1]
This new understanding absolutely compels us to insist that Quemetco’s application to process up to 25 percent more batteries be denied.
[1] “Frequently Asked Questions March 6, 2015 Release of OEHHA Risk Assessment Guidance Manual and ARB Hotspots Analysis and Reporting Program (HARP) Software” (http://www.sdapcd.org/homepage/FAQ-OEHHA.pdf). See also: http://www.oehha.ca.gov/air/hot_spots/hotspots2015.html