Communicating Health Risks at Contaminated Sites: U.S. Environmental Protection Agency Office of Land and Emergency Management Office of Inspector General Report

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued a September 9th report titled:

EPA’s Office of Land and Emergency Management Lacked a Nationally Consistent Strategy for Communicating Health Risks at Contaminated Sites (“Report”)

See Report No. 21-P-0223.

OIG states it initiated the audit to:

. . . determine whether the EPA is communicating sampling results or other indicators of human health risk at select sites in Office of Land and Emergency Management, or OLEM, programs in a manner that allows impacted communities to avoid exposure to harmful contaminants or substances.

In 2018 EPA defined risk communication as:

. . . the process of informing people about potential hazards to their person, property, or community… The purpose of risk communication is to help residents of affected communities understand the processes of risk assessment and management, to form scientifically valid perceptions of the likely hazards, and to participate in making decisions about how risk should be managed.

A March 2020 definition of risk communication EPA communicated stated:

Risk communication is communication intended to supply audience members with the information they need to make informed, independent judgements about risks to health, safety, and the environment.

OIG concludes that EPA did not consistently communicate human health risk at certain sites being addressed by OLEM in a manner that allowed impacted communities to decide how to manage their risk of exposure to harmful contaminants.

The Report cites EPA’s Seven Cardinal Rules of Risk Communication. OIG states that EPA did not consistently adhere to this guidance.

The OIG Report notes that it reviewed eight contaminated sites. It states that OLEM:

. . . struggled with risk communication because it lacked specific guidance to provide EPA personnel with best practices for addressing environmental justice concerns, timeliness, coordination, and clear communication.

Also cited as problems were inefficiencies in EPA risk communication and absence of a national strategy. A further cited concern was the lack of what is described as a “measurable definition of timely risk communication.”

Recommendations provided by OIG include:

  1. achieve OLEMwide, nationally consistent risk communication to improve public awareness and understanding of risks;
  2. monitor its risk communication efforts; and
  3. provide community members with information to manage their risks when exposed to actual or potential environmental health hazards. All recommendations are resolved with corrective actions pending. We also revised our report where appropriate based on technical comments provided by the Agency.

A copy of the Report can be downloaded here.

Written by:

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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