\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\nRisk\nassessment involves categorizing and one of the side-effects of categorizing is\ncreating clusters or communities — those affected and those not, for instance.\nRisk assessment, though, goes further and arranges communities within a hierarchical\norder.
\nThis sort of thinking makes sense in a triage situation or an emergency where\nresponse has to be quick and effective. We believe that since there is no\npublic discussion about these categories or the way they are constructed, that\nthe process is open to a bias, no matter how “scientific” or\n“objective” it may be. One of the biases built into the EPA’s (and\nthe state’s) process of risk assessment is the desire not to create a\nremediation procedure that is too costly to industry or business. Permitting\nand other functions, either on a national or on a state level, also have to be\nconcerned with the economic cost to industry.
\nWe believe a bias can be shown to be present if the process is not working —\nif people are getting sick or if the environment is showing degradation. That’s\nalready happening, isn’t it? Witness global warming. Witness the eradication of\naquatic life in 30-some miles of Dunkard Creek that wanders through West\nVirginia and Pennsylvania. Witness the concerns of residents in the coal fields\nof West Virginia about underground coal slurry injection and their poisoned\ndrinking water.
\nThe communities we’ll be discussing in this post related to risk assessment are\nthe chemicals, their effects, people and the environment.
\nThe choice of whether a chemical is to be categorized as a COPC (Chemical of\nPossible Concern) is somewhat arbitrary. Again, this works great in a triage\nsituation. But there are chemicals that aren’t directly toxic to people, that\nwe believe should be members of the COPC category — chloride is one. The state\nincludes chloride in its water quality standards but chloride doesn’t appear on\nthe de minimis list of COPC for 60CSR3. Chloride also doesn’t appear in\nstandard EPA risk assessment tables or those produced by NOAA.
\nChemicals that do appear on risk assessment tables are divided into those that\ncause cancer and those that do not. Generally, those that cause cancer have\nmuch stricter screening levels. The problem is that there are chemicals such as\nendocrine disrupters that have effects on humans and wildlife that could\njeopardize a species’ survival. In addition, the presence of a chemical on a\nrisk assessment table generally means that there have been accepted scientific\nstudies about the effects of that chemical. A chemical not on the list should\nnot be considered safe.
\nIn risk assessment concern is about a site’s effects on populations, not\nindividuals. If the community isn’t large enough, then concern lessens. We also\nhave the feeling that if the community isn’t important enough, then concern\nlessens. This means an urban population tends to have a higher importance than\na rural population. Class and race also enter the equation.
\nOne way that states lessen the economic effects of remediation is by having a\nprocess where a contaminated site can be, either through deed restriction or\ncovenant, used only for industrial purposes. The risk assessment for industrial\nsoils is many times less protective than residential, and that makes sense in\nsome instances. The process, though, makes it easy to rubber stamp a site as\nindustrial and not do anything about it. In many places industrial and\nresidential sites are not carefully delineated — industrial sites have close\nneighbors who live in houses.
\nThe site we’re looking at is not located where its effects will be felt by a\nlarge enough community to make it very important from an official, risk\nassessment, standpoint. Only a few nearby residents could possibly directly\nexperience the results of soil or groundwater contamination. Again, in a triage\nsituation, such thinking might be appropriate (though racial and class bias\nwould not), but here we believe that the possible effects on individuals\nwarrants closer examination.
\nThe bias that is shown for communities of people in risk assessment is\nheightened when it comes to environmental screening. Ecological communities are\ncarefully delineated and extremely narrow and include endangered species,\nold-growth forests, and federal and state parks. Our belief is that if the contamination\nat a site can be assessed to cause a risk to wildlife or vegetation, then that\nis a problem, even if the wildlife or vegetation doesn’t have the luxury of\nbeing rare or located in a park. We’re especially concerned about the numerous\ninstances we’ve seen at well sites where deer have been attracted to areas that\nhave been contaminated in one way or another. Deer are attracted to salts and\nminerals present but it’s possible they are also ingesting chemicals that could\ndo them harm, or harm those further up the food chain.
\nRisk assessment is a tool but the way the tool works is often wanting.\n\n\n\n<\/p>\n","protected":false},"excerpt":{"rendered":"
Risk assessment involves categorizing and one of the side-effects of categorizing is creating clusters or communities — those affected and those not, for instance. Risk assessment, though, goes further and arranges communities within a hierarchical order. This sort of thinking makes sense in a triage situation or an emergency where response has to be quick…<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_kad_post_transparent":"","_kad_post_title":"","_kad_post_layout":"","_kad_post_sidebar_id":"","_kad_post_content_style":"","_kad_post_vertical_padding":"","_kad_post_feature":"","_kad_post_feature_position":"","_kad_post_header":false,"_kad_post_footer":false,"_kad_post_classname":"","footnotes":""},"categories":[8],"tags":[],"class_list":["post-388","post","type-post","status-publish","format-standard","hentry","category-gaswellstudy"],"_links":{"self":[{"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/posts\/388","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/comments?post=388"}],"version-history":[{"count":1,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/posts\/388\/revisions"}],"predecessor-version":[{"id":389,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/posts\/388\/revisions\/389"}],"wp:attachment":[{"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/media?parent=388"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/categories?post=388"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/tags?post=388"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}