This map is a fascinating and important image as it does NOT show the many sites of (ongoing) nuclear radiation contamination in communities impacted by uranium extraction and processing. For example, the Navajo Nation has around 270 unreclaimed open pit tailings piles. This is not official "waste" but is quotidian waste that creates longstanding environmental harm.
This image hides many things, including:
1. the slow but steady dispossession of smallholder (often African-American) farms that have been overtaken/bought out by Smithfield Foods to enlarge the industrial footprint of CAFOs;
2. the hogs themselves, whose hooves never touch the ground as they stand on "hog slats" inside the hangers as they move through the Fordist stages of transformation from individual animals into packaged pork;
3. the human operators, themselves, who are rarely wealthy, and are contracted for decades (or life) to purchase all "inputs" (feed, semen, etc) from Smithfield; in 2010, I took my EJ class from UNC-Chapel Hill to visit one of these operators at his CAFO, outside Raleigh, NC, and he was battling Smithfield and Duke Energy to be allowed to erect and operate a small-scale, experimental wind turbine that ran on methane captured from his pigs; years later, individual efforts at small-scale biogas would be overtaken by entities like Align LNG which now, in Sampson County, proposes the "Grady Road Project" to scale-up factory-farmed methane gas capture from much larger operations;
4. the legacy of resistance to this form of agricultural production, led by community-based intellectuals like Gary Grant, who as early as the 1980s was speaking out, traveling to state and federal lawmakers, publishing, and organizing against the growing harms of CAFOs in his home territory of Halifax County, NC. [See the suggested readings by Gary Grant and Steve Wing, Naeema Muhammed and others, that tracks this organized resistance and the formation of several community-based EJ groups in response].
The Sampson County landfill can be smelled before seen. This olfactory indicator points toward the sensory scale of these pungent emissions but also toward the geographic scope: this landfill receives waste from as far away as Orange County (the state's most expensive property/tax base), among dozens of other distant counties, making this "hazardous site" a lesson in realizing impact beyond the immediate locale. So when we answer the question, "What is this hazard?" we must think not only about the landfill as a thing in itself but as a set of economic and political relations of capital and the transit of other peoples' trash, into this lower-income, rural, predominantly African-American neighborhood. In this way, 'thinking with a landfill' (like this one in Sampson County) enables us to analyze wider sets of relationships, NIMBY-ist policymaking, consumerism, waste management, and the racialized spatial politics that enable Sampson County to be the recipient of trash from all over the state. At the same time we think spatially and in transit, we can think historically to (a) inquire about the DEQ policies that enable this kind of waste management system; and (b) the emergent "solutions" in the green energy sector that propose to capture the landfill's methane in order to render the stench productive for the future -- that is, to enable more consumption, by turning garbage into gas. As such, the idea of "hazard" can expand beyond the site itself - impactful and affective as that site might be - to examine the uneven relations of exchange and capitalist-driven values of productivity that further entrench infrastructures such as these. [This offers a conceptual corrollary to thinking, as well, about the entrenchment of CAFOs for "green" biogas development, as we address elsewhere in the platform].
Most recent news (As of September 2022) focuses on the EPAs naming of 23 EtO sterilization plants as high risk. This announcement enables local leadership, environmental organizations and legal partners to assess human health risks while focusing on reducing EtO emissions, as outlined by the EPA. Most recent news (As of September 2022) focuses on the EPAs naming of 23 EtO sterilization plants as high risk. This announcement has enabled local leadership, environmental organizations and legal partners to assess human health risks while focusing on reducing EtO emissions, as outlined by the EPA. This release by the EPA has prompted activism in the communities affected by EtO sterilization facilities. As noted by EarthJustice on the news, “Raul Garcia, legislative director for Healthy Communities at Earthjustice: ‘This is an important and welcome step to increasing transparency on the toxic air pollution and health threats that sterilizer facilities pose to the health of millions of Americans. Now that EPA has new information on precisely where the worst health threats are, the agency must use its full authority to ensure public health so no one gets cancer from this pollution and require fenceline monitoring at these facilities. Now, EPA must issue a strong new rule that phases out the use of ethylene oxide at commercial sterilizers. No one should get cancer from facilities that are used to sterilize equipment in the treatment of cancer.’ “. In addition, one major article edited and published by ProPublica sparked both outrage but in addition, change. The article The Most Detailed Map of Cancer-Causing Industrial Air Pollution in the U.S. details
Activism has prompted more indepth research, increased acquisition and availability of EtO industry data, and increased focus on EtO as a carcinogen and toxin. This hazard was recognized fully by the EPA between 2016-2018 which led to increased assessment and acknowledgement of EtO as a toxin.
The main concern with EtO exposure includes inhalation. Laws that regulate air emissions have invariably affected and regulated this hazard. But specifically, below is a rough outline of laws that directly impacted the air emissions of facilities processing EtO:
Clean Air Act Section 112, Hazardous Air Pollutants. The CAA regulates Ethylene Oxide under section 112 of the CAA. The CAA labels EtO as a hazardous air pollutant. Under the CAA, EtO emissions can be regulated in conjunction with promoting the best emission controls.
Regulations on Sterilization Facilities (From Federal Register : National Emission Standards for Hazardous Air Pollutants: Ethylene Oxide Commercial Sterilization and Fumigation Operations)
Note, fugitive emissions have not been standardized by the EPA, including back vents, emergency ventilation etc.
Mainly stark contrast can be found between the EPA and various state and chemical manufacturing companies in terms of data divergence. The main concern surrounding EtO is the elevated cancer risk that occurs with long exposure both direct and indirect. The ways in which the EPA and other companies and agencies assess risk have been different in terms of unit quantity. The EPA utilized in 2016 the Integrated Risk Information System to model cancer risk. According to the American Chemical Council the, “ACC believes the value is significantly flawed.” Also, the Texas Commision on Environmental Quality has stated, “ ‘the US EPA unit risk factor (URF) for ethylene oxide is not scientifically justified.’ ”. This has led the TCEQ to raise its exposure limit from 1 ppb to 2.4 ppb.
Results of the Risk Assessment of Ethylene Oxide Emitting Facilities in Texas and Louisiana
Provides a list of 8 high risk EtO facilities both in LA and TX. Provides a breakdown of race in terms of proximity to facility and risk level. *One point to mention, is that data from the 2018 National Emissions Inventory (NEI), which was used, is provided to the EPA by the LDEQ and TCEQ.*
Ethylene Oxide Risk Map - Air Alliance Houston
Mapped by the Environmental Advocacy group Air Alliance Houston are EtO facilities across America. The top 25 EtO emitting facilities are labeled and census tracts with a cancer risk greater than 100 in 1 million are also highlighted.
The major organization involved in assessment of EtO is the EPA. The EPA and its branch leaders have spearheaded the response guidelines, have outlined cancer risks, and have conducted research in partnership with other national partners such as the NIH, federal departments of health, and state departments of health.
In the period between 1982 to 1984 multiple studies on lab rats concluded that inhalation concentrations of ethylene oxide could be correlated to cancer development. An analysis of the results found that increased exposure showed higher incidences of tumor development in both male and female lab rats. According to the EPA EtO is carcinogenic and, “Scientific evidence in humans indicates that exposure to EtO for many years increases the risk of cancers of the white blood cells, including non-Hodgkin lymphoma, myeloma, and lymphocytic leukemia. Studies also show that long-term exposure to EtO increases the risk of breast cancer in women.”