November 16, 2001
Amy Ryder, Ohio Citizen Action
Ohio Citizen Action thanks the Agency for Toxic Substance and Disease Registry for this investigation into the health and safety of the individuals living, working and going to school near the Brush Wellman beryllium plant in Elmore, Ohio.
We believe the draft consultation is thorough and the recommendations appropriate. Our comments on the health consultation are -—
- On page 9, please change 'Ohio Public Citizen' to 'Ohio Citizen Action.'
On page 15, the ATSDR recommends to itself that it 'conduct an exposure investigation to determine whether community members have been exposed to beryllium from possible off-site transport of dust on Brush Wellman workers’s clothing.' We strongly support this recommendation and urge the agency to turn this investigation into a pilot project by creating a community panel to oversee the investigation. The panel would decide on the process and the timeline of the investigation, monitor the testing, choose the lab which will do the analysis, and review the analysis results. The panel should be made up of members of the community, ATSDR staff, Ohio Citizen Action, and technical experts, appointed by the community and paid for by the ATSDR. A process of public involvement is critical to the success of the exposure investigation for two reasons:
- The community is skeptical because this is the first time in over four decades that any government agency has looked into the health and safety of the community, because Brush Wellman has been permitted to police their own emissions for so long, and because the Ohio EPA is under strict scrutiny by the US EPA for lack of environmental enforcement. This skepticism was clearly displayed at the agency’s public meeting held on October 24. In order for this investigation to be thorough and credible to those who will benefit from it, members of the community need to not only be made aware of the process, they need to be involved in the decisions of what the process is, how long it will take, and who will conduct and analyze the testing. The community will most likely trust the results of the investigation if they create and are a part of the process 100%.
- Since the Brush Wellman plant has been operating, members of the community have been forced to rely on Brush Wellman and the Ohio EPA for information. Unfortunately, neither Brush nor the Ohio EPA have done much to establish a level of trust or lines of open communication to lead the public to believe that the information they put forth is trustworthy. Clearly one of the biggest problems in this community is poor communication between these two institutions and members of the community. The ATSDR addresses this problem in its recommendations to Brush Wellman and the Ohio EPA. This problem must also be addressed in the exposure investigation. The most effective way to do this is for the Agency to provide the financial resources to the community to hire its own technical expert(s) whose sole responsibility is to answer to members of the community. These experts will act in an advisory capacity to assure that the investigation process agreed upon and carried out is thorough and will achieve the intended results.
- We ask that the agency include in its exposure investigation soil sampling on the properties neighboring the Elmore plant. Because the facility has been operating for over four decades, it is reasonable to believe that beryllium could be accumulating in the soil, posing severe health risks for children. Since the ATSDR recognizes that, 'the unique vulnerabilities of infants and children demand special emphasis in communities faces with contamination of environmental media,' and that 'this site is a particular concern for children because there are residences close to the site,' it is critical to know if this highly toxic metal is accumulating in the ground where children spend a great deal of their time.
- On page 15, the ATSDR recommends that Brush Wellman, 'notify the community of the CAP meetings in advance, summarize CAP findings and actions in a newsletter or a fact sheet or other effective methods, and allow OEPA to participate in the CAP.' We ask that this recommendation be amended to actually opening the CAP to all members of the community. A CAP which operates behind closed doors is not an effective way to open lines of communication or establish a level of trust between the company and it's neighbors. Members of the community should not only know in advance when the meetings are taking place, but should also feel welcome to attend and participate in the meetings.
Thank you for your hard work and careful consideration. Please feel free to contact me if you have questions or need additional information.
Amy K. Ryder, Cleveland Director
Ohio Citizen Action
614 W. Superior Ave, #1200
Cleveland, OH 44113
(216) 694-6904 FAX
Copies to Peter Kowalski, MPH, CIH;
Robert Johnson, MD;
Lynn Wilder, Ms Hyg, CIH;