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This article explores the challenges and strategies in managing risks at the state level, focusing on the development and implementation of toxicity factors. It discusses the impact of "perfect data", uncertainty and variability, default procedures, and conflicting information on toxicity values. The article also highlights the need for effective risk communication and allocation of regulatory authority and resources. Case studies on natural gas processing facility emissions and formaldehyde exposure are presented. The article concludes by emphasizing the importance of considering the ripple effects of decisions and improving risk communication to the public and policymakers.
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Managing Risks at the State Level Michael Honeycutt, Ph.D. Texas Commission on Environmental Quality
Different Perspectives • Developing a Toxicity Factor • “Perfect data” • Uncertainty/Variability • Default procedures/uncertainty factors • Drives toxicity values lower • “Implementing” a Toxicity Factor • Background levels • Screening levels become bright lines (10-6) • “Sound Bite” explanations don’t work well to counter media hype • Conflicting information/opinions • Regulatory authority and resources • Responding to public/legislative concerns
Natural Gas Processing Facility 390 TPY VOCs 1.2 ppb Benzene annual average
New Draft Arsenic SFo • Typical US dietary intake of inorganic arsenic >10-3 risk • Typical fish and seafood levels >10-4 risk (inorganic fraction; 2 meals/month) • Typical drinking water levels >10-3 risk • Typical levels in rice (average consumption of people who eat rice, inorganic fraction) >10-3 risk • Typical soil levels in Texas >10-4 risk
2005 NATA Preview • National Risk Driver – Formaldehyde • Based on Cal OEHHA – Rodent nasal carcinoma/LMS; Draft EPA value even more potent • I will get calls from media, concerned citizens, legislators, environmentalists for action • Annual average concentrations – 7 monitors; 1.9 – 4.5 ppb • Will push for more monitoring
Reported normal human breath levels of formaldehyde (median – 97.5th percentile) presumably from endogenous production (Moser et al. 2005). Indoor and outdoor average concentrations and concentration ranges were based on values in IARC (2006). Outdoor average concentration ranges for the US and Texas were based on monitoring data.
Acrolein • Ambient air monitoring program initiated at schools across the US • Acrolein will probably be a national issue
Where Do We Put Our Resources? • New required monitoring – ozone, lead, NO2, SOx; probably CO, PM2.5 • Benzene • Formaldehyde • Acrolein • Arsenic • Our budget is shrinking
Take Home • The ripple effects of decisions made during tox factor development can be staggering • We want to be health-protective, but we need to be real • We need to do a better job communicating risk and uncertainty to the public and to policy makers