PO Box 1070, Frankfort, KY 40602 Phone 502.875.2428, Fax 502.875.2845
KRC Statement Responds To ATSDR Rubbertown Health Consultation Posted: August 24, 2006
KRC STATEMENT IN RESPONSE TO RELEASE OF RUBBERTOWN INDUSTRIAL AREA HEALTH CONSULTATION BY THE AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR) ON AUGUST 24, 2006
KRC appreciates the recommendation from the ATSDR that releases of cancer-causing chemicals in West Louisville's air should be reduced or eliminated whenever possible.
KRC is concerned that ATSDR's use of 100 in a million as the level of concern for cancer risk will be used as a foil by those who have for decades used Louisville's air for toxic waste disposal. The difference between how EPA and ATSDR define acceptable risk to public health is that EPA believes 1 additional cancer death in a million people is the goal and that 100 in a million deaths is the maximum risk that should ever be tolerated, but ATSDR considers chemical exposure causing 100 deaths in a million to be an appropriate endpoint.
EPA's ceiling for cancer risk is ATSDR's floor, and both Congress and this state have embraced the more protective approach. In choosing such a lax number for what is "acceptable" cancer risk, and in suggesting that there is a threshold below exposure which cancer-causing chemicals cause no harm, ATSDR is out-of-step with bedrock principles of public health.
It should be remembered that there is no right to use the public air for disposal of toxic air pollutants, and that exposing the public to elevated risks of cancer, respiratory or neurological injury is never reasonable where it is unconsenting and avoidable risk.
The STAR goals are consistent with Congress' goals for air toxics programs, and with EPA's residual risk program. ATSDR's health consultation adds little to the debate other than demonstrating the obvious - if you use a standard for risk measurement that tolerates more injury and death from air toxics exposure, less chemicals will appear to be of concern than if you use a more protective standard.