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- GASP Applauds Finalization of Protections for Workers and Communities Like Erie & Zelienople from Cancer-Causing Ethylene Oxide Pollution
Good news alert for yinz: This week, the U.S. Environmental Protection Agency (EPA) released the interim decision for Ethylene Oxide (EtO) – a pesticide used on 50 percent of all sterilized medical devices in the United States and on about 30 percent of dried herbs and spices. For the uninitiated: EtO is known to cause cancer, including lymphocytic leukemia, breast cancer, non-Hodgkin lymphoma and myeloma in people. Workers who use EtO and people who work, live, or go to school or daycare near facilities that use EtO may breathe in emissions at levels that can increase cancer risk. The greatest risk is for people who work for their entire careers at facilities directly handling EtO with insufficient worker protections in place. \ Two such facilities are right here in southwestern Pennsylvania - American Contract Systems, Inc., in Zelienople, Butler County, and Cosmed Group LLC/Erie in the City of Erie. And GASP, which has followed this issue closely for years , lauds the EPA for taking the important action. "This updated risk assessment, a result of substantial effort and resources, is a victory for residents in Zelienople, Erie, and all other communities impacted by these sterilization facilities," GASP Executive Director Patrick Campbell said. "The new rule will play a crucial role in mitigating the very real cancer risks they face." Now about the decision…First, it includes mitigation measures that, in addition to those included in the 2024 EtO National Emissions Standards for Hazardous Air Pollutants (NESHAP), will reduce exposure to workers and nearby communities. Together, these two EPA actions provide a comprehensive approach to addressing EtO pollution concerns, including cancer risk, that will increase safety in communities and for workers while supporting ongoing supply chain needs for sterilized medical equipment. How We Got Here (Little Bit of Background) EPA regulates EtO’s use as a pesticide under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). EtO has both antimicrobial uses, such as sterilization of medical devices, and conventional uses, such as fumigation of dried herbs and spices. In some instances, such as with sterilization of medical devices like surgical kits, EtO is the only available option, making it essential for protecting human health. Every 15 years, EPA evaluates potential human health and environmental effects associated with the use of a pesticide through the registration review process. As part of EtO’s registration review, the agency assessed cancer risk from working in sterilization and health care facilities that use EtO, living in communities near EtO facilities, and consuming dried herbs and spices treated with EtO. After a 75-day public comment period, EPA identified a broad set of protections under FIFRA that aim to reduce exposure to all EtO sterilization facility workers and to others who work, live, or go to school near sterilization facilities. What Changed? What’s Gonna Change? Specifically, the decision includes: a reduced EtO concentration rate limit for new medical device sterilization cycles to reduce levels of exposure for workers a lowered worker exposure limit of 0.5 ppm after three years, 0.25 ppm after five years, and 0.1 ppm after 10 years (compared to the current Occupational Safety and Health Administration standard of 1 ppm) phased cancellation of the use of EtO on specific dried herbs and spices and cancellation of the use of EtO when safer and effective alternatives are available. When it Comes to Commercial Sterilizers… Lowered worker exposure limit of 0.5 ppm by 2028, 0.25 ppm by 2030, and 0.1 ppm by 2035, as compared to the 1984 OSHA limit of 1 ppm. Any workers who could be exposed to concentrations of EtO above these limits would need to wear additional respiratory protection. Finalizing the ban of use for museum, library and archival materials; cosmetics; musical instruments; and beekeeping equipment. Immediate cancellation of the use of EtO for specific dried herbs and spices for which its use is not considered critical for food safety, and phased cancellation for specific dried herbs and spices for which EtO use is considered critical for food safety but have potential alternatives to EtO. Establishing a concentration limit of 600 mg/L for new medical device sterilization cycles within 10 years. If a device requires a concentration of EtO greater than 600 mg/L due to the device design, the facility must maintain records to justify the increased application rate. Separation of HVAC systems for areas where EtO is used and areas where EtO is not used, to reduce EtO exposure in areas such as offices. Requiring respirators to protect workers involved in certain high EtO exposure tasks, such as connecting and disconnecting EtO containers from sterilization process equipment. Continuous EtO concentration monitoring throughout sterilization facilities, including on-site storage facilities. Data requirements to monitor breathing zone worker exposure to EtO within commercial sterilization facilities and warehouses that store sterilized materials, both on and off-site. When it Comes to Healthcare Facilities... Require abatement devices for healthcare facilities that use more than 10 lbs. of EtO/year by comparison – c commercial sterilizers typically release tons of EtO annually. Ventilation of EtO through exterior ventilation stacks to reduce exposure to healthcare facility workers. Exposure to communities from EtO used in healthcare facilities is expected to be minimal because the amount of EtO used at healthcare facilities is orders of magnitude lower than at commercial sterilization facilities. What Happens Next? EPA expects that registrants will submit label amendments that include the changes outlined in the decision within 60 days after publication. The agency plans to quickly review the label amendments so that products sold and distributed by registrants will include the changes outlined. The timing for implementation for individual mitigation measures ranges from two years to 10 years, taking into consideration the costs, technology availability, potential impacts to the medical device supply chain and other logistical elements. Additionally, EPA will issue a Data Call-In (DCI) to gather information on worker exposure. Specifically, the DCI will require submission of worker exposure data for commercial sterilizers and warehouses in order to understand the worker exposure impacts of complying with EPA’s Clean Air Act EtO commercial sterilization NESHAP and implementing the mitigation measures identified in this Interim Decision. EPA will reevaluate this Interim Decision within eight years, earlier than the typical 15-year cycle, based on the submitted worker exposure data, in order to identify further opportunities to reduce EtO exposures.
- GASP Joins EPA in Encouraging Residents to Prevent Lung Cancer by Testing Homes for Radon
Did yinz know that January is National Radon Action Month? Did you further know that the EPA recommends that folks test their abodes for the cancer-causing gas? Indeed. Here’s what you need to know: Radon is an odorless, colorless, naturally occurring radioactive gas that, when left unaddressed, can build up inside a home. Over time, exposure to radon can cause lung cancer. The only way to know if your home has high levels of radon is to test for it. During this year's National Radon Action Month, GASP joins the EPA in urging everyone to take the first but vital step of testing their home. This year's theme of 'Test Your Nest: Test, Fix, Save a Life,' emphasizes that identifying and reducing radon exposure can decrease lung cancer risk and save lives. Good news is, testing for radon is easy and inexpensive. Affordable do-it-yourself radon test kits are available for purchase online and at most home improvement and hardware stores. Some states and municipalities even provide at-home radon test kits for free. You can also hire a qualified radon professional to test your home. Millions of homes in the United States have elevated levels of radon. Radon is the number one cause of lung cancer among non-smokers and is responsible for about 21,000 lung cancer deaths every year , but many people don't know about radon or the risks it can pose to their health. The EPA recommends taking action to fix your home if you discover radon levels above 4 picocuries per liter. If your home does have elevated levels of radon, a qualified professional can install a system to lower your indoor radon levels. For more guidance on how to address radon risks, see EPA's radon website . Editor’s Note: Want to learn more about your indoor air quality? Check out this FREE air quality monitoring program offered by our friends at ROCIS.
- Time is Running Out to Tell ACHD to Make ATI Title V Permit Stronger
Dear Fellow Breathers, We wanted to give a last call for comments for those who want to weigh in on the Title V permit issued to Brackenridge-based ATI, which has been a major source of air pollution in Allegheny County for DECADES. Allegheny County Health Department is accepting comments on the permit through Oct. 22 and we wanted to make sure you had the info you need to make your voice heard. GASP submitted formal comments that you can read here . For those who would like to join us in calling for the permit to be stronger, we have sample comments below. Feel free to personalize them or use them as-is. Comments must be e-mailed to aqpermits@alleghenycounty.us by the end of the day on Tuesday, Oct. 22. For those who would like to testify in person, a public hearing will be held 6 p.m. at the Harrison Township Municipal Building, 1 Municipal Drive, Natrona Heights, PA 15065, in the conference room. Anyone who would like to speak at the hearing should register online at least 24 hours in advance of the hearing on the Department’s permits webpage at https://alleghenycounty.us/AQnotices Here are those sample comments: The ATI Title V permit must be strengthened to better protect ambient air quality and public health. ACHD must: Modify the permit so is assures compliance with the limits on particulate matter content and opacity of emissions from the HRPF Slab Grinder's stack. Modify the permit so that it assures compliance with the permit's limits on emissions from the active Hot Boxes. Modify the permit so that it assures compliance with limits on the PM content and opacity of emissions from the Revering Roughing Mill. Modify the permit so that it assures compliance with limits on the PM content and opacity of emissions from the 7-Stand Hot Finishing Mill. Modify the permit so it assures compliance with NOX and PM limits on emissions from the Plasma torch cutting operation. Modify the permit so it assures compliance with hourly and annual limits on the NOX emissions from the Plasma Torch Cutting Operation.
- Tell Your County Council Rep: Vote YES on Proposal to Fully Fund Air Quality Program & Buoy Staffing, Enforcement
Friends, we need your help. Here’s what’s going on: A plan to fully fund Allegheny County Health Department’s Air Quality Program by making polluters pay is in danger of being derailed by the very companies that foul our skies. As we told yinz last week, Allegheny County Council was expected to vote on the ACHD proposal, which would increase certain air quality permit fees imposed on polluters. Despite significant public comment (including GASP’s Patrick Campbell) calling for members to vote yes on the fee schedule changes, that didn’t happen. Instead, they punted the thing back to the Health and Human Services Committee for further discussion. Full disclosure: We are hearing through back channels that one of Allegheny County’s most prolific polluters - U.S. Steel - has enlisted its allies to try to tank the proposal, which has already been approved by the Board of Health and subject to a public comment period where it received robust support from residents, nonprofits and elected officials alike. “The permit fee schedule vote should honestly be a no-brainer,” Campbell said. “But industry operatives are cherry-picking percentages from the plan and conflating the permit fee schedule changes with Allegheny County Executive Sara Innamorato’s budget to alarm council members enough for them to make a knee-jerk reaction and vote no on the issue.” He added: “We want to be very clear here: This isn’t some new tax plan. This isn’t something that residents will pay for. These are existing fees that ACHD is trying to increase because they simply do not cover the costs associated with running the program.” And guess what? ACHD has been delegated the authority to enforce federal and state laws and regulations regarding air pollution controls in Allegheny County like the Clean Air Act. And the Clean Air Act requires that ACHD have adequate funding and personnel to carry out its duties. In fact, the law requires ACHD to charge Title V facilities fees that are sufficient to cover the cost of administering the program. Bottom line? We need to let county council know loud and clear that: Air quality remains one of Allegheny County’s leading public health issues. Residents like you are impacted by air quality issues and deserve a fully funded Air Quality Program - one with the staffing and resources to enforce all applicable laws that protect our public health. That council needs to vote YES on the permit fee increases that are necessary for ACHD to carry out its duties - it’s literally the law. How can you do that? Easy. Reach out to county council and let them know how you feel! It doesn’t need to be anything super technical. An email introducing yourself, how you have been impacted by our county’s poor air quality, and that you need them to vote YES on the proposal to fully fund the Air Quality Program. All you have to do is click here and let ‘er rip. Have questions? Need a little more info or help getting started? Please don’t hesitate to hit up our communications manager Amanda Gillooly at amanda@gasp-pgh.org . She can help you craft and submit your comments.
- ACHD Proposal to Fully Fund Air Quality Program Headed to Council for Final Vote Following Committee’s Affirmative Recommendation
Friends, we have excellent news to report: Last night, Allegheny County Council’s Committee on Health and Human Services voted to affirmatively recommend a proposal to fully fund our Air Quality Program through increasing certain permitting fees imposed on polluters. “We want to send a big thank you to the committee,” GASP Executive Director Patrick Campbell said. “We also want to thank everyone who took a few minutes out of their day to contact their council rep and explain how important - and personal - this issue is to them.” But we want to remind everyone that we don’t have this thing over the proverbial goal line yet. The final stop? The permit fee increases ensuring ACHD has the resources/staffing it needs to properly run its Air Quality Program will be up for a vote at Allegheny County Council’s Dec. 17 meeting. And it will take more than a simple majority to get this thing passed - 10 of 15 council members need to vote YES. That’s why we’re gearing up for one final call to action. And we’re hoping that you will once again help us send a message to council to let them know how much public support there is for a fully funded air quality program. Please Contact your Allegheny County Council representative and tell them: You're concerned about air quality in Allegheny County (and share a personal story about how air pollution impacts you personally if you have one!) Residents deserve a fully funded Air Quality Program to enforce clean air laws. That you are urging them to vote YES on the proposal to fully fund the ACHD Air Quality Program. Making your voice heard is super simple! You don't need to be an expert. For real. You just send a quick message introducing yourself, explain how air quality impacts you, and emphasize the importance of a fully funded program. Here’s the link to the form to reach all of council: Contact County Council - Allegheny County, PA Rather make a quick call? You can reach County Council at 412-350-6490. Need a little help or more info? No problem! Just email our communications manager Amanda Gillooly at amanda@gasp-pgh.org .
- UPDATED: County Council Committee to Discuss Crucial Air Quality Funding Proposal Coming Up; Join GASP in Urging Members to Vote YES
Editor's Note: According to the Allegheny County website, the Health and Human Services Committe meeting originally slated for Nov. 14 has been moved to Dec. 5 (updated at 6:43 p.m. Nov. 13). In Allegheny County, clean air is a right not a privilege. And today, we’re asking you to take a few minutes to fight for that right. We need your help to urge Allegheny County Council’s Committee on Health and Human Services to vote YES on a proposal to fully fund our Air Quality Program through increasing permit fees on polluters. The committee, which meets at 4:30p.m. Thursday, is expected to vote on whether or not to recommend the proposal be approved by the full council on Tuesday, Nov. 19. Thing is, this should be a simple vote - a total no-brainer. But we are hearing through back channels that one of Allegheny County’s most prolific polluters - U.S. Steel - has enlisted its allies to try to tank the proposal, which has already been approved by the Board of Health and subject to a public comment period where it received a crazy amount of support from residents, nonprofits and elected officials alike. Why is it a no-brainer? The Clean Air Act in fact requires ACHD to have adequate funding and personnel to enforce air pollution controls. Specifically, the law mandates that ACHD charge fees to certain facilities (Title V facilities like U.S. Steel’s Clairton Coke Works) to cover the program's costs. The bottom line is clear: Air quality is a major public health concern and residents deserve a fully funded Air Quality Program with the resources to adequately enforce clean air laws and protect our public health from dangerous industrial pollution. How can you help? Contact your Allegheny County Council representative and tell them: You're concerned about air quality in Allegheny County (and share a personal story about how air pollution impacts you personally if you have one!) Residents deserve a fully funded Air Quality Program to enforce clean air laws. That you are urging them to vote YES on the proposal to fully fund the ACHD Air Quality Program. Making your voice heard is easy-peasy! You don't need to be an expert. For real. Just send a quick email introducing yourself, explain how air quality impacts you, and emphasize the importance of a fully funded program. Members of the Health and Human Services Committee include: Chair Paul Klein Paul.Klein@alleghenycounty.us Bethany Hallam Bethany.Hallam@alleghenycounty.us Suzanne Filiaggi Suzanne.Filiaggi@alleghenycounty.us Anita Prizio Anita.Prizio@alleghenycounty.us Dan Grzybek Dan.Grzybek@alleghenycounty.us Michelle Naccarati-Chapkis Michelle Naccarati-Chapkis Robert Macey Bob.Macey@alleghenycounty.us Nick Futules Nicholas Futules Rather make a quick call? You can reach County Council at 412-350-6490. Need a little help or more info? No problem! Just email our communications manager Amanda Gillooly at amanda@gasp-pgh.org . Editor’s Note: Want to watch the committee meeting? Here’s the link.
- OPPORTUNITY ALERT: GASP Seeking Hosts for EPA-Funded Allegheny County Community Air Monitoring Project
Friends, we have an amazing opportunity for folks to be a crucial part of our EPA-funded Allegheny County Community Air Monitoring Project - one that will place a PurpleAir or SPod monitor at your home or business! “We hope that this effort to monitor and sample the air around industrial sources like Lindy will give some leverage to environmental advocacy efforts and offer an opportunity for communication with ACHD about local concerns,” GASP field technician Julie Stouffer explained. “We will be looking to place 12 PurpleAir PM2.5 monitors, and a VOC sampling and monitoring device called an SPod in the neighborhoods around Lindy Paving.” That means that if you live in the area indicated below, you are eligible to be part of our project, which you can get the skinny on right here. Need more info? No problem! Here are some documents for you to peruse: Host Agreement Project Fact Sheet You can also check out this page for further details. Also: Please free to reach out to us at julie@gasp-pgh.org with any other questions you may have!
- EPA Formalizes Designation of New PA Non-Attainment Area & Reduces Secondary NAAQS for Sulfur Dioxide to End 2024
We blogged earlier this year about two developments concerning the National Ambient Air Quality Standards (NAAQS) for sulfur dioxide (SO2). Either just in time for the holidays (or, as is more likely, just before a new administration takes over in Washington), those developments have resurfaced at the Environmental Protection Agency (EPA). Here’s an update on them: First, back in February, we blogged about EPA’s proposal to designate portions of both Cambria and Westmoreland Counties as being in nonattainment for the 2010 primary NAAQS for SO2 (a primary NAAQS is designed to protect human health) based on the results of a modelling analysis; these areas are directly downwind from three coal-burning power plants (as well as a fourth that has shut down since the modelling was performed) that emit a lot of SO2. On Dec. 17, EPA published the rule that finalized that designation in the Federal Register. As a result, the state Department of Environmental Protection (DEP) will be required to develop revisions to its State Implementation Plan (the SIP, which includes all of Pennsylvania’s EPA-approved air pollution regulations and facility-based emission limits) that demonstrate the area will attain the 2010 primary NAAQS for SO2 by no later than Dec. 17, 2029, and submit those revisions to EPA for its approval. “But don’t hold your breath waiting for big changes,” GASP Senior Attorney John Baillie said. “One of the coal burners that contributed to high levels of SO2 that were modelled in the nonattainment area has already shut down (the Homer City Generating Station), and another two (the Keystone and Conemaugh Generating Stations) are scheduled to shut down by no later than 2028.” He continued: “Further, as we blogged in June , EPA has proposed a rule that would impose new limits on emissions of sulfur dioxide from these plants. The emission reductions from the plant shutdowns and the proposed new limits may very well be sufficient to demonstrate attainment.” Second, back in April, we blogged about an EPA proposal to reduce the secondary NAAQ S for SO2 from 500 parts per billion (ppb) not to be exceeded during any three-hour period more than once a year, to an annual average of only 10-15 ppb, measured over a three year period; a secondary NAAQS is designed to protect public welfare, meaning, mainly, plants, animals, and other property. The 500 ppb standard had been on the books, unchanged, since 1971. On Dec. 10, EPA announced it had finalized a new secondary NAAQS for SO2, which will be an annual average of 10 ppb measured over three years. “There are areas in both Allegheny County and other parts of southwestern Pennsylvania that may not attain this standard,” Baillie explained. “DEP will have one year to submit designations of those areas to EPA, and (assuming EPA accepts those designations) up to three years to submit revisions to the SIP that include new regulations or limits on facility emissions that will reduce SO2 levels enough to bring all areas of the Commonwealth into attainment of the new standard.” We will keep you posted on new developments related to these as they occur.
- ACHD Announces $1.8 Million Air Quality Program Deficit, Floats Increasing Permit Fees to Buoy Budget
Allegheny County Health Department’s Air Quality Program is facing a $1.8 million budget deficit and unveiled Monday a plan to buoy its budget through increasing myriad permit fees. ACHD Deputy Director of Environmental Health Geoff Rabinowitz presented a lengthy report to the Air Pollution Control Advisory Committee detailing those fees - one of which would go from $8,000 to $55,000 - and acknowledged that the numbers are “a bit of an eye opener.” Here’s what permit fee increases are being floated for Allegheny County’s largest emitters, known as Title V facilities: Here is the fee structure recommended for smaller sources of air pollution: Had there been a quorum of Air Pollution Advisory Committee members, Rabinowitz said he would have asked for approval to take the plan to the Allegheny County Board of Health to ask that it be greenlighted for public comment. As an aside: This is the third straight meeting where the Air Pollution Control Advisory Committee lacked a quorum and could not take official action. But back to the suggested permit fee changes… Rabinowitz said the timeframe is “aggressive” and that the Air Quality Program hopes to have the fee changes in place by the end of the year. Committee members noted procedural concerns. At least one member noted that the proposal should have been vetted by ACHD’s regulation subcommittee, which was bypassed. Another called the justification for the increases “scant.” Rabinowitz retorted that he envisioned that the regulation subcommittee could take a formal stance on the plan by meeting during the public comment period and providing feedback as part of that process. There was significant back and forth over whether or not the advisory committee would hold a special meeting to formally recommend or oppose the plan - or whether a formal letter opposing the advancement of the plan would be submitted to county leaders. Rabinowitz said he intended to take the permit fee increase proposal to the July 17 Board of Health meeting to formally request approval to send it to public comment. By way of background: This would be the second time in less than two years that ACHD is seeking to increase permit fees. Allegheny County Council in September 2022 approved increases in line with those approved by the Pennsylvania Department of Environmental Protection (DEP). You can read all about that here . And it wouldn’t be the first time ACHD raised the alarm about a budget shortfall. Last year, the Air Quality Program tried - unsuccessfully - to get access to a greater portion of the Clean Air Fund to help beef up its bottom line. You can read all about that here. GASP continues to follow this issue closely and will keep you posted.
- Special Air Advisory Committee Meeting Slated to Mull Proposal to Increase Fees on Polluters & Shore Up ACHD Shortfall
A special meeting of the Air Pollution Control Advisory Committee has been announced. The meeting, which is open to the public, is slated for 5:30 p.m. July 8. This meeting will be focused on proposed air quality permit fee increases and associated Article XXI amendments. While it will be held in person at the CCAC Allegheny Campus, in the K. Leroy Irvis Building, Highmark Conference Room 302, a virtual option is also available through Microsoft Teams. Here's what's going on: Allegheny County Health Department’s Air Quality Program is facing a $1.8 million budget deficit and unveiled Monday a plan to buoy its budget through increasing myriad permit fees. ACHD Deputy Director of Environmental Health Geoff Rabinowitz earlier this month presented a lengthy report to the Air Pollution Control Advisory Committee detailing those fees - one of which would go from $8,000 to $55,000 - and acknowledged that the numbers are “a bit of an eye opener.” You can read the plan here. As a sidebar: The reason for the special meeting is because there was not quorum at the latest Air Pollution Advisory Committee. It was the third straight meeting where the Air Pollution Control Advisory Committee lacked a quorum and could not take official action. But back to the suggested permit fee changes… Rabinowitz said the timeframe is “aggressive” and that the Air Quality Program hopes to have the fee changes in place by the end of the year. Committee members noted procedural concerns. At least one member noted that the proposal should have been vetted by ACHD’s regulation subcommittee, which was bypassed. Another called the justification for the increases “scant.” Rabinowitz retorted that he envisioned that the regulation subcommittee could take a formal stance on the plan by meeting during the public comment period and providing feedback as part of that process. There was significant back and forth over whether or not the advisory committee would hold a special meeting to formally recommend or oppose the plan - or whether a formal letter opposing the advancement of the plan would be submitted to county leaders. Rabinowitz said he intended to take the permit fee increase proposal to the July 17 Board of Health meeting to formally request approval to send it to public comment. By way of background: This would be the second time in less than two years that ACHD is seeking to increase permit fees. Allegheny County Council in September 2022 approved increases in line with those approved by the Pennsylvania Department of Environmental Protection (DEP). You can read all about that here . And it wouldn’t be the first time ACHD raised the alarm about a budget shortfall. Last year, the Air Quality Program tried - unsuccessfully - to get access to a greater portion of the Clean Air Fund to help beef up its bottom line. You can read all about that here. GASP continues to follow this issue closely and will keep you posted.





