As the new home of WISPIRG's environmental work, Wisconsin Environment can be contacted with any questions regarding this testimony.
There are about 80,000 chemicals
in use by industry today. Chemicals are used in the creation and processing
of thousands of products. They are used to create plastic products, from toys
to toilet sets. They are used in creating electronics, paper products, machinery,
pharmaceutical and personal care products, and household cleaners. Chemicals
are also used in the process of food production, like packing meat and vegetables,
and even during electricity generation.
When factories across the
U.S. and Wisconsin use chemicals to create products they also release many of
these chemicals, polluting the air we breathe.
Many of the chemicals in
use today are toxic and are threatening the health of Wisconsinites. Chemical
air emissions can lead to cancer, birth defects, neurological damage, impaired
fetal brain development, respiratory problems, reproductive problems, suppressed
immune systems and developmental delays.
Despite the many health
effects we are aware of from chemical air emissions, there is an even larger
problem: we know almost nothing about the effect most chemicals are having on
human health. That is because very few chemicals are tested for health effects
before they reach the market. Of the 80,000 chemicals in use today, 2,800 are
considered high production volume chemicals - meaning industry uses over 1 million
pounds per year. We only have health information for about 7% of the 2,800 high
production volume chemicals, and for less than 1% of the total chemicals used.
And, to make matters worse,
we do not know the cumulative effect to health when humans are exposed to multiple
types of chemicals from multiple sources over long or short periods of time.
Why are the effects of man-made
chemicals such a mystery? Most people probably assume that any chemical on the
market today underwent safety testing before being approved for use. Unfortunately,
that is not the case. The federal government does not require chemicals to be
tested before they are used, and industry pressure has prevented much-needed
chemical safety laws from becoming a reality in the United States.
Because of scientific research
by groups like the National Toxicology Program and the World Health Organization's
International Agency for Research on Cancer, we are slowly learning the effects
of different chemicals on human health. This research is also often finding
that chemicals are toxic to humans in much smaller quantities than was previously
realized. As more scientific research becomes available, it is imperative that
state and federal government take action to limit air emissions of chemicals
that have been found to be toxic.
WISPIRG supports the Wisconsin
Department of Natural Resources' decision to update the state's list of hazardous
air contaminants based on scientific research. We fully support the addition
of chemicals that have been found to harm human health to the list of regulated
air toxins. We support the reductions in allowable emission levels for many
of the chemicals on the existing list based on scientific research. WISPIRG
also supports the change to risk-based thresholds as the standard for setting
emissions levels.
While the additional listing
and the decreased emission levels are a good step forward and could result in
less dangerous chemicals in Wisconsin's communities, industry pressure has resulted
in gaping loopholes in the ability of the DNR to ensure that industries are
complying with the law. The rules also ignore some important health concerns
such as the cumulative effect of exposure to multiple chemicals and the need
to list all chemicals that have been found to adversely impact human health.
We call on the Wisconsin
DNR to protect human health by making the following changes to the proposed
hazardous air pollution rule:
- The DNR must
protect the public from all sources of airborne pollution. All chemicals that
have been listed as hazardous by either the National Toxicology Program or the
World Health Organization must be regulated. The DNR must also create a process
to quickly regulate additional chemicals as scientific research becomes available.
- DNR must assess
health threats from a person's total exposure to air pollution. Through either
monitoring or approved models, DNR and industry must show that citizens living
in communities around polluting facilities will not be exposed to levels of
air emissions that can lead to cancer, birth defects, respiratory disease, cardiopulmonary
disease, suppressed immune system or other related illnesses from toxic air
pollution. The DNR must consider the cumulative effect of emissions from multiple
factories on human health, rather than simply considering each facility separately.
- The DNR must
set risk-based thresholds that better protect public health. The risk-based
thresholds should be changed from 1 in 100,000-risk to 1 in 1 million-risk.
- The DNR must hold
industry accountable to unsafe emissions and enforce the law consistently. Industries
who illegally emit toxic chemicals must not be protected from fines or other
legal action through the proposed "safe harbor" or "incidental
emitters" policies. Both of these programs will protect illegal polluters
from being held responsible for negatively impacting human health.
