DRive for 10 to 15 MinutesNorth from Detroit, you may pass Hamtramck, Michigan. This small city of 2 miles is home to many communities of color including African Americans and Yemeni/Bangladesi immigrants. This is an area where Nearly 70 percentA majority of households speak a language other that English. This is an example of environmental injustice and a microcosm for national efforts to improve health equity for future generations.
More than 2,000 Hamtramcks’ 22,000 residents are within a half mile radius of the U.S. Ecology Detroit North Waste Management Facility. This facility stores and processes toxic heavy metals, as well as other wastes from governments and commercial entities. The facility has had a poor record in environmental safety compliance over the years. The Detroit Free Press received the 2016 Environmental Safety Compliance Award. Records The company had been found guilty of 150 wastewater violations in the past decade. These violations included water containing high levels of toxic mercury or arsenic and being discharged into the city’s sewer system. Independent testing of public lands around this facility was done in 2017. FoundSamples of soil containing arsenic are known carcinogen, at levels nearly 20 times the EPA safe limit. (The facility is exempted from soil and groundwater monitoring by long-standing waivers.
Residents began to notice a proposal for a neighborhood park several years back. ExpansionThis would allow the site to store nine times more chemical waste and allow it to process thirty new types of hazardous waste, including those that can cause cancer. aflatoxinsLocal activists protested. They filed petitions and staged protests to no avail. The Department of Environment, Great Lakes and Energy, a state agency responsible for hazardous waste management, delayed its final decision and extended the public comment period in 2020. ApprovedThe expansion of the facility.
The Great Lakes Environmental Law Center has filed a formal complaint to defend Hamtramck residents. GrievancesThe EGLEs Nondiscrimination compliance Coordinator. The coordinator reviews Title VI complaint in accordance to Environmental Protection Agency regulation. The law center also claims that the decision not to issue an expanded license to the U.S. Ecology facility violates that regulation. The grievance notes that 80 percentWithin a 3-mile radius of this site, a majority of residents are people of color.
Lawyers claim that although the EGLE gave public notice of the proposed expansion, it failed to make the notices in the appropriate languages for the many Bengali- and Arabic-speaking immigrants living near the facility. Further, the complaint claims that language-accessible public hearings were not made at the request of residents and grassroots groups. Since then, EGLE was closed. Released A Limited English Proficiency Plan, which outlines the steps the agency will take in order to comply with federal civil rights laws and public notice requirements in future.
Meaningful language access to legally mandated environmental information disclosures is a key component of many regulations and EPA discrimination-related complaints. Another, perhaps more serious criticism in the Hamtramck grievance is directed at a concept that has become a perennial issue in environmental regulation: cumulative risk.
There is a lot of research in disciplines like toxicology social epidemiologyStudies have shown that environmental pollutants can interact with each other, and that this can lead to adverse effects on a person’s health. impactedby the accumulation and maintenance of health risks throughout one’s life. These risks are not limited to toxic chemical and biologic exposures. Stress-inducing socioeconomic circumstances, often found in people of color, can also pose risks to human life. These factors can act. cumulativelyYou can even get it! SynergisticallyWith environmental toxicants to increase the risk for adverse health outcomes.
There are reasons to believe that these cumulative risks could be excessive in Hamtramck and the surrounding areas. The city is characterized by high poverty rates and high density, which are factors that are often associated with High incidenceof chronic disease. Metropolitan Detroit’s predominantly Black areas already have high levels of industrial pollution. highest asthma ratesThe country. Many Bangladeshi and Yemeni Immigrants have had to deal with both chemical and social toxicity in Hamtramck. Some Yemeni immigrants are still subject to xenophobic, Islamophobic discrimination. sufferThe psychological and biological effects that forced displacement from their home country can have devastating consequences for their health and well-being. These comorbidities, as well as social stressors, would likely be Amplifiedfurther exposure to pollution.
Additionally, Bangladeshi immigrants to America come from a country with the highest levels of groundwater. Arsenic contaminationMany have brought their farming traditions to Detroit where they rely upon urban farming. They might be concerned about the cumulative effects of arsenic in soil and groundwater on their health.
The most affected areas in metropolitan Detroit are predominantly Black and already suffer from high levels of industrial pollutants. They also have some of highest asthma rates in the nation.
The Great Lakes Environmental Law Center argues in its grievance against EGLE that the agency should have evaluated these cumulative risks before approving U.S. Ecology Detroit North expansion. The complainants argue that Michigan’s insistence on permitting polluters to continue to contribute to Hamtramcks disproportionate health-related risk is discriminatory.
There are few federal mechanisms that can force state and local agencies into considering cumulative risk when reviewing permit applications. The EPA spent the past year developing long-awaited regulations. UpdatesIts framework for planning and implementing cumulative risks assessments, with an aim to encourage more health-focused state permitting decisions. However, the guidance is not legally binding. The National Environmental Policy Act Requires Cumulative risk assessments can only be done for facilities that have received federal funding. Facilities such as U.S. Ecologys Detroit North site are not included in this category. (Even though facilities are subject to the policy law, the law doesn’t require that states base their decisions on cumulative risk assessments.
Cumulative risk assessments are not a standard part of most state environmental regulations because there is no federal mandate. This could be due to the fact that implementing and enforcing state level cumulative risk assessments requires significant investments of time, resources, and time. Terms and conditionsThese complex analyses cover every aspect, from the types and consequences of stressors that a risk analysis must consider to the method for estimating how a new activity might raise population-level risks.
These hurdles have not prevented some states from formalizing cumulative risk assessment in their environmental protection laws. Some states limit these laws only to certain types of emission. New York enforces cumulative risk assessments for pollution. Other states, like Minnesota and Massachusetts, have implemented more comprehensive cumulative risk measures that allow for community participation. The Hamtramck case is a good example of why it is so important for other states to follow their lead.
The outcome of the grievance on behalf of Hamtramcks residents still is pending. This much is clear: Science has proven that environmental pollution can have serious health consequences, especially in marginalized communities. Environmental justice will not be fully codified by lawmakers until marginalized communities like Hamtramck can apply this principle to their lives.
Farah Kader, a New York-based researcher analyst, is Farah Kader. She holds a B.A. A B.A. in public Health from the University of California-Berkeley. An MPH in Environmental Health Sciences from the University of Michigan.
