Military Toxics Project
Information Sheet – June 2003 (first version)

Risky Business - Public Health Assessments by ATSDR

An incomplete or inadequate Public Health Assessment has the potential to actually increase risk to human health by reducing public vigilance, misdirecting public and environmental policy, and undermining pollution prevention objectives. Consequently, communities threatened by hazardous waste and other pollution sources should think twice before inviting the federal government to conduct such a study.

Created by Superfund legislation in 1980, ATSDR (Agency for Toxic Substances and Disease Registry) conducts a Public Health Assessment for every site on or proposed for the National Priorities List, or the NPL. For other sites, a “petitioned” Public Health Assessment is conducted at the request of a member of the public. When a petition is received, it is referred to a committee which decides whether the agency will perform a Public Health Assessment or if some other action would better meet the community's needs, or if no action is needed.

A Public Health Assessment should provide a thorough review of available information about hazardous substances at a site, evaluate whether exposure to those substances might cause any harm to people, and ultimately recommend action to protect public health. The methods utilized by ATSDR, however, routinely fail to meet these objectives. Inadequate contact with the populations being studied, reliance on inappropriate testing techniques, reliance on statistical methods unsuitable for small or mobile populations, contracting with biased researchers, and studying the wrong types of illnesses are common flaws in ATSDR’s health assessments.

Several years ago, Whidbey Islanders for a Sound Environment petitioned ATSDR to consider the effect of extreme jet aircraft noise from low level training over residential areas in a risk assessment for Whidbey Island Naval Air Station. ATSDR relied exclusively on information provided by the Navy and county to assess noise impacts to the community.

Bill Skubi, a spokesperson for the local group, said, “There was no reference to any scientific data or studies; only a statement crediting the county government with taking active measures to mitigate aircraft noise.” The only subsequent measure taken by the county was the passing of a "Noise Level Reduction Ordinance" in 1992 that puts the sole responsibility for noise mitigation on individual property owners residing in the impacted area. There is no actual mitigation required in this ordinance.

“Therefore our experience, too, was that the ATSDR risk assessment, as it treated a problem we know to cause health problems, was to give the false impression in their report that it was being actively addressed by local officials and the Navy,” Skubi added.

In Boulder, Colorado, local resident Adrienne Anderson reports ATSDR has refused to review adverse health outcomes in areas which received contaminated water from the Martin/USAF rocket plant, part of the Lockheed Martin complex.

“Furthermore,” she said, “the Colorado Department of Health has refused the same health outcome data to independent researchers interested in studying certain epidemiological connections.”

Anderson reports pressure from Lockheed Martin effectively blocked an investigation of the stalled study that was to address risks associated with hydrazine rocket wastes and other poisons found at the base. Ten years after the Martin and USAF sites were named to the NPL, there was still no finalized Public Health Assessment released for public comment describing impacts to public health in the Denver metropolitan area.

In 1995, The Wisconsin Division of Health (WDOH), acting as an agent for ATSDR, published a health assessment of residents near the Sauk County’s ‘Superfund’ Landfill. The WDOH study, approved by ATSDR, was based exclusively on information provided by the County (the owner/operator of the landfill and the responsible party) and contractors hired by the County. “Absolutely none of the data or concerns presented by the community were included in the report,” said Laura Olah, director of Citizens for Safe Water Around Badger. “The conclusions of the report predictably echoed, almost verbatim, the claims of the polluter that no health problems or risks were associated with their site.”

Since the release of the WDOH report, affected homeowners have discontinued actively monitoring the site, including associated air and groundwater contamination, and have resumed daily activities and patterns that may be placing them and their children at increased risk for cancer and other deadly diseases, Olah said.

The people in Memphis, Tennessee have been having a very difficult time with ATSDR too. Doris Bradshaw’s local Environmental Justice Group has lobbied the agency to revisit the Public Health Assessment previously done on the Defense Depot, a Defense Logistics Agency (DLA).

Community concerns have been expressed about public health effects from contamination in drainage ditches and from food grown in areas near these ditches; from contaminated groundwater; and from mustard gas destroyed and disposed at DDMT in 1946, as well as other chemical agents disposed at Dunn Field.

On May 4, 1999 Southwest Public Workers Union (SPWU) and the Committee for Environmental Justice Action (CEJA) announced the filing of a civil rights complaint alleging discrimination by Kelly Air Force Base (KAFB), the Greater Kelly Development Corporation, the City of San Antonio, the Texas Natural Resource Conservation Commission, the Agency for Toxic Substances and Disease Registry (ATSDR) and Region VI of the Environmental Protection Agency.

SPWU and CEJA allege that these agencies discriminated against Latino residents that live near Kelly AFB in San Antonio, Texas by ignoring their environmental protection and public health needs.

The complaint against the ATSDR was based on the agency’s failure to finalize the Public Health Assessment for KAFB; CEJA and SPWU alleged discrimination by the ATSDR and KAFB for withholding information and for manipulating the process.

In Vieques, Puerto Rico, ATSDR has recently initiated a Public Health Assessment, and again, serious concerns about ATSDR’s ability to adequately protect public health have been raised. In a February 18, 2000 letter to President Clinton, the Military Toxics Project (MTP), warned: “While ATSDR has already initiated a health assessment, we have little confidence it will address the health problems of Vieques residents resulting from military activities.”

“For small populations, such as that of Vieques, the kinds of epidemiological studies that ATSDR typically uses are inappropriate and inconclusive. Often, ATSDR studies have been used inappropriately as a tool to allay community concerns without disclosing the limitations of the studies. Instead of protecting the public, ATSDR studies have been used as public reassurances,” MTP concluded.

Military Toxics Project - "Networking for Environmental Justice"
P.O. Box 558, Lewiston, ME, 04243
Phone: (207) 783-5091 - Fax: (207) 783-5096 - Web: www.miltoxproj.org