Understanding the Health Risk Assessment
“Health Risk Assessment is a detailed comprehensive analysis prepared the Health Risk Assessment
“Health Risk Assessment is a detailed comprehensive analysis prepared pursuant to Section 44361 to evaluate and predict the dispersion of hazardous substances in the environment and the potential for exposure of human populations and to assess and quantify both the individual and population wide health risks associated with those levels of exposure.”
The Bay Area Air Quality Management District (BAAQMD) employs a Health Risk Assessment (“HRA”) protocol to evaluate health risks from exposure to industrial pollution. This is what they used to determine that Lehigh’s emissions were safe for nearby residents and why Lehigh claims to have safe emissions levels. For details about this topic download BAAQMD Air Toxics NSR Program Health Risk Screening Analysis (HRSA) Guidelines. You can also download the latest HRA submitted by Lehigh Cement to BAAQMD: Health Risk Assessment by AMEC – 9/10/2010 (136 pages).
This technique only evaluates the risk of each chemical independently and uses the cumulative risk factors of all the chemicals to determine overall health risk.
Using this tool and the mercury emissions supplied to them by Lehigh the BAAQMD has deemed the toxic emissions coming from Lehigh Cement company at low enough levels as to be considered safe. This is the gold standard used by all the other regulatory agencies.
HRA ignore any consideration to chemical interactions and their synergistic compounding effects. Scientist are currently studying these complex synergistic toxic interactions (Synergistic Toxicity) that health professionals have observed for decades. It is possible that an agent could be hundreds of times more toxic in combination with another/other agents than by itself. These other agents could be from the same source, from the environment, from ingested food, from inoculations, or due to genetic factors. Thus this method of HRA could be hundreds of time off. The current HRA method of evaluating health risk is seriously flawed and out of date!
In light of what we now know we are convinced that it is much more prudent to error on the safe side and assume that the synergistic effects are significant and that we are all at considerably higher health risk than BAAQMD has lead us to believe rather than take the HRA at face value.
It is far better to be prudently safe now than to be regrettably sorry later when it is too late to prevent thousands of assignable health crises. It might already be too late for some.
Latest Health Risk Assessment
Newest Health Risk Assessment indicates that Lehigh has Exceeded Notification Thresholds for the last few years!
What this means is that by the standards that Bay Area Air Quality Management District and other regulatory agencies use, Mercury levels in our air have been at high enough levels as to pose a Significant Health Risk to Residents for the last few years and likely much longer.
Mercury levels have been under-reported in the past due to the way it was estimated. The new method sanctioned by the EPA for estimating Mercury emissions elevates the actual mercury levels quite significantly. Regulatory agencies and Lehigh Cement can no longer make claims that Lehigh’s Mercury emission are at safe limits!