At the beginning and throughout the COVID-19 pandemic, many buildings remained dormant as we attempted to slow the spread of the virus. At the same time, the water and water-sources feeding those buildings were also unused, resulting in old, stagnant water within those buildings. Sudden closures of occupied facilities as a result of pandemic response efforts meant that building systems that were once constantly occupied were now dormant and unused. The combination of building closure and water stagnation provided the perfect conditions for bacteria to survive and thrive. Allowing these human pathogens to survive and grow within water systems can have negative consequences for facilities and subsequently on the people occupying those buildings.

Because of the delicate balance within building drinking water systems, sudden interruptions of these systems can provide the opportunity for bacteria and other human pathogens to grow. Stagnant water can result in the depletion of disinfectants (e.g., chlorine), and the water sources within a building (e.g., sinks) are transformed into exposure points for waterborne pathogens that impact human health. One such organism that has been identified is Legionella bacteria, and cases of Legionnaires disease have been on the rise - even with disease incidence underreporting - since 2000.

Legionnaires Outbreaks and More Could Come

There have been recent reports of Legionnaires’ disease outbreaks from building impacts as well as the detection of Legionella bacteria in public facilities. A recent nursing home outbreak resulted in a resident death, a common occurrence when a building has legionella growing within facility water (i.e., plumbing) systems. The Legionella bacteria was identified at a New York housing complex. Legionnaires disease outbreaks can be widespread, like the recent one in New Jersey that infected individuals across two counties.

The issues with facility water systems and the attention these systems need are becoming more widely recognized, especially when highlighted by the complexities of closing buildings. This further exemplifies the issue that can present from waterborne pathogens in buildings.

GSA Water Testing In Leased Spaces

To that end, the recent effort by the United States General Services Administration (GSA) aims to address the safety of drinking water within facility water systems. In recent years, GSA has recognized the impacts of building vacancy on water quality. These impacts, coupled with increases in incidence of Legionnaires disease, have led GSA to take a more proactive approach to managing water quality within owned and leased facilities. These proactive approaches have already been successful in identifying one GSA facility that had elevated levels of Legionella bacteria within the plumbing system. Legionella impacts on facility occupants - especially those that are at high risk - could be tragic if not addressed in a timely manner.

As part of their initiative to maintain high quality water within GSA facilities, the agency has issued testing requirements to establish safe water conditions within GSA facilities (both owned and leased). Baseline water testing as required by GSA will have to be completed by the end of fiscal year 2024 and includes testing for Legionella, total coliforms (including e. coli), lead, and copper. A checklist for required testing, along with action limits, is available on the GSA website.

Following baseline assessment, annual compliance for the identified contaminants will be required. The baseline testing requirements are for owned facilities that are greater than 1,000 square feet and most leased facilities; there are a few notable exceptions within the requirements (e.g., child care centers). The agency includes examples of those types of professionals that have specific knowledge and experience in relevant fields for testing water of this type, including industrial hygienists with preference for certified industrial hygienists (CIH).

Noble Water Management Efforts with Room to Grow

While the effort by GSA is noble, there are some interesting quirks required by the agency. For example, testing requirements state that samples are to be collected from fixtures that are "primarily designed for human consumption". While this may be applicable to total coliforms, lead, and copper, applying the standard to Legionella bacteria may lead to a false sense of accomplishment when performing these tests. GSA supplies examples of these types of outlets, such as drinking fountains, bottle fillers, and kitchenettes. They also supply examples of common in tenant showers as potential sampling points. Interestingly, bathroom sinks and water lines to the tenant's own equipment (e.g., refrigerators) do not require testing per the requirement. Based on what is known about where Legionella can grow, these areas are locations that actually should be tested. Excluding some of these areas can bias the testing methodology because the focus is on human consumption rather than inhalation, the primary exposure route for Legionella bacteria. Another interesting aspect is that GSA requires testing of common areas where tenants and visitors would have reasonable access and expectation for use. Additionally, the requirements required only first draw samples, again potentially missing locations within water systems where Legionella can grow.

GSA Taking the Lead in Addressing Water Quality

GSA is taking a big leap forward by requiring the testing of water within their occupied facilities. It is an effort that needs to be taken by facility owners and/or operators because of the issues that were highlighted by the COVID-19 pandemic. Reducing the occupant load on the buildings subsequently resulted in water stagnation within those facilities, ultimately leading to the opportunity for human pathogenic organisms to thrive. This step by GSA is an attempt to understand current water conditions within the facilities and to identify when human health hazardous conditions exist. However, focusing on the human consumption aspect of water testing may overlook potential exposure points for Legionella and subsequent Legionnaires disease cases or outbreaks, based on the fact that we know where these organisms like to grow. Hopefully, after baseline assessments, there will be re-evaluation by GSA to move forward with an understanding that additional exposure source points within facilities exist and should be captured by the testing for a true representation of potential human exposures to legionella bacteria.

Water Testing Expertise

If you are a GSA-owned or leased facility, our experienced certified industrial hygienist and team has the relevant experience necessary to assess facility water quality. Please reach for a free consultation with our team to help satisfy the baseline GSA requirements.

According to the Bureau of Labor Statistics, private employers in the United States reported a staggering 2,804,200 non-fatal workplace injuries and illnesses in 2022 — an alarming 7.5% increase from the previous year. Fatal workplace injuries in 2022 also increased 5.7% totalled 5,486 in 2022, marking a 5.7% increase from 2021.

Amidst these workplace injury statistics, there is also public concern about the safety of their environment. Gallup's annual environmental polls reveal that a majority of Americans, 55%, express deep concern about polluted drinking water, ranking it as their top environmental safety worry from 2019 to 2023.

Human loss is tragic and immeasurable. When it comes to concerns about our water and environment, residents should have peace of mind that their community is in safe hands. Ensuring the safety of employees and the broader community is both a moral and legal responsibility of every company. It is the cornerstone of being a good neighbor and a responsible corporate citizen. Non-compliance may lead to injuries, fatalities, illnesses, and environmental disasters that leave lasting effects on the community. Non-compliance can also bring steep fines, litigation, and potential criminal charges.

Simply checking regulatory boxes or providing personal protection equipment isn't enough. Organizations must commit to mitigating risk while maximizing safety for employees and the public. Robust risk management strategies, including ongoing risk assessments, are vital. These strategies will proactively find potential hazards, and determine how to eliminate them or when elimination isn’t possible, define appropriate control measures to reduce the risk to an acceptable level.

And this isn’t a one-time activity or a siloed one. Organizations must commit their ongoing attention to identifying, correcting and controlling all hazards and risks, including a process of continuous improvement to evolve the strategy and adapt to new circumstances and challenges. Integrating workplace safety and environmental well-being into the daily fabric of operations, job skills, company culture, and employee mindset ensures that it becomes everyone's business.

In today's world, where keeping workplaces safe and caring for the environment is a priority, Exposure Assessment Consulting’s industrial hygiene services are key to a company’s resilience and sustainability. We believe that employees should be safe at work, that they should return home healthy, and that communities should have peace of mind about the environmental stewardship of nearby companies. We understand the critical role industrial hygienists play in safeguarding against potential hazards and disasters.

In this article, we will dive into the indispensable contributions of industrial hygienists and explore their crucial role in navigating the complexities of disaster prevention and risk management. We’ll start by examining three real-life examples of disasters where the expertise of an industrial hygienist could have made a positive difference. We’ll also explore the types of hazards and the economic benefits of hiring industrial hygienists.

Examples of Real-life Disasters Where Industrial Hygienists Could Have Made A Difference

Hinkley Water Contamination

Released on March 17, 2000, the film "Erin Brockovich" etched the term "hexavalent-chromium" into the minds of the general public, grossing $256.3 million worldwide. Almost overnight, the importance of environmental safety and the consequences of inadequate risk management became part of widespread public awareness.

The movie is based on a true story of the 1993 class action lawsuit brought against Pacific Gas and Electric Company alleging that the company contaminated the wastewater around the community of Hinkley, California. The case found that from 1952-1964, PG&E disposed of hexavalent chromium (Cr6), a carcinogenic chemical used in operating a natural gas compressor station, leading to unsafe levels of chromium in the local drinking water. The case was settled in 1996 for $333 million awarded to more than 600 people. Remediation efforts continue to this day, over 60 years later.

Lowe’s Home Improvement - Deaths Linked to Toxic Products

On April 25, 2018, retail giant Lowe’s Home Improvement found its place on "The Dirty Dozen" 2018 list compiled by the National Council for Occupational Safety and Health. This annual list spotlights employers whose practices jeopardize the safety of both employees and communities. The inclusion of Lowe’s on this list was not arbitrary – the list states “56 U.S. deaths linked to exposure to paint strippers containing methylene chloride, including 17 workers who died while refinishing bathtubs.” At the time the list was published, the company continued to sell products containing this deadly substance.

Ohio Train Derailment

On February 3, 2023, at approximately 8:55 p.m. local time, about 50 train cars derailed in a fiery crash on the outskirts of East Palestine, Ohio. Eleven of the derailed cars were transporting hazardous materials. The 149-car train was passing through on its way to Conway, Pennsylvania when the derailment occurred. Responding to the catastrophe, an immediate evacuation order was issued, displacing thousands of residents. The mayor declared a state of emergency the next day. The derailed train cars burned for several days causing concerns over toxic fumes, explosions, and potential long-term health effects.

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These three highly publicized cases are only a tiny sampling of the larger number of incidents that have occurred in the United States. Recall the 2022 injury and fatality statistics at the beginning of this article with millions of injuries and thousands of fatalities.

While these examples differ in their nature, details, and impact, they share a common theme: all of them were preventable. However, the reality is that many health and safety hazards and risks aren’t obvious. This emphasizes the need for proactive assessment, vigilance, and a focus on prevention.

In the next section, let’s explore what industrial hygienists do.

What Does an Industrial Hygienist Do?

Industrial hygienists are scientists and independent experts who are committed to supporting a company’s responsibility for workplace safety and the environmental well-being of their surrounding community. They play an essential role as a protector against potential disasters and harm to individuals in the workplace or the community.

Industrial hygiene is the science of identifying, evaluating, and controlling conditions that may cause injury or illness or may be a threat to public health. An industrial hygienist uses a blend of science and engineering with a comprehensive risk management approach to assess environmental and workplace hazards, evaluate the risk, and develop recommended strategies to reduce or eliminate the associated risks.

It’s important to note the difference between a hazard and a risk. A hazard is a potential source of harm or danger. A risk is the possibility that something bad or unpleasant (such as injury or a loss) will happen. An industrial hygienist deals with both, where they not only identify hazards but methodically assess the potential risks, ensuring a comprehensive and proactive approach to creating safer environments.

The types of hazards defined by industrial hygienists are:

• Environmental

• Chemical

• Waterborne

• Biological

• Physical

• Ergonomic

Here are a few examples of what an industrial hygienist can provide in the context of the types of hazards mentioned earlier:

• Biological Hazard Management: Assessing and implementing control measures for biological hazards, such as mold or bacteria, to maintain a healthy and safe working environment.

• Chemical Management: Assessing and recommending proper handling, storage, and disposal procedures for chemicals to minimize risks and ensure compliance with regulations.

• Indoor Air Quality Assessments: Monitoring and improving indoor air quality to safeguard the health and comfort of occupants and identifying and mitigating sources of pollutants.

• Water Quality Assessments: Assessing the quality of water sources within industrial settings and identifying potential sources of contamination.

As an organization’s vital ally, an industrial hygienist plays a multidimensional role that extends well beyond risk management. They provide an independent perspective that is critical for several key functions, such as:

• Risk Management: Anticipating, identifying, managing, measuring, monitoring and mitigating risk.

• Risk Exposure Assessment: Identifying and assessing a company’s risk exposure.

• Regulatory Compliance: Ensuring regulatory compliance by delivering recommendations for risk policy and governance.

• Cultivating a Risk-Aware Culture: Helping companies to foster an effective risk culture and accountability.

• Tailored Risk Mitigation Plans: Providing support for developing customized risk mitigation plans.

• Environmental Strategy and Standards: Providing expertise to establish an organization's environmental strategy and standards to protect the community.

• Occupational Health & Safety Programs: Providing expert advice to develop and implement comprehensive occupational health and safety programs, including training programs.

• Exposure Litigation and Expert Testimony: Top industrial hygienists, such as Exposure Consulting’s founder, Dr. Alex LeBeau, offer these services as well. Exposure litigation refers to health claims and complex legal proceedings following a purported exposure to an environmental contaminant. Dr. LeBeau provides confidential scientific guidance to organizations to assess and evaluate these types of claims.

How Industrial Hygiene Can Make a Difference

Turning back to the real-life examples above, let’s explore how industrial hygiene could have made a positive difference.

In the case of the Hinkley water contamination, there are several ways an industrial hygienist could have helped. They may have been able to identify the risk associated with the chemical used in the compressor, called out potential points of entry into the community groundwater, and made recommendations for chemical management procedures to minimize the risk. After the contamination was found, an industrial hygienist may have participated in identifying the root cause, consulted on recovery procedures and provided their knowledge and expertise to support the resulting legal proceedings.

In the case of the Lowe’s Home Improvement deaths, an industrial hygienist may have been able to identify the risk associated with the paint stripper product and how an employee or customer could be exposed to it. Based on their assessment, they may have recommended control measures to minimize the risk of exposure, provided input into training programs, and proper handling instructions.

In the Ohio train derailment scenario, the cause was said to be an overheated wheel bearing on one of the train cars. It overheated to a dangerous degree, causing the bearing to fail. Although the temperature finally triggered an alarm for operators to apply the brakes and for the emergency braking system to trigger, it was too late. An industrial hygienist’s risk assessment would have likely included equipment monitoring procedures to identify potential failure points that could lead to increased risk from subsequent chemical releases. After the derailment, industrial hygienists were likely called in to contribute their expertise to emergency response procedures, public communication and messaging, long-term health and environmental impact assessments, and remediation planning.

These examples provide just a glimpse into the multi-faceted expertise of an industrial hygienist. They use a comprehensive methodology and risk management approach. These are systematic and strategic methods that also recognize that each industry and setting is unique. From pinpointing dangers and evaluating exposures to suggesting tailored protective measures, industrial hygienists navigate the complexities of various types of industries and environments.

Below, we provide an overview of how an industrial hygienist conducts their work and applies their methodology.

Industrial Hygiene Methodology: How Do Industrial Hygienists Assess Hazards?

One of the primary responsibilities of industrial hygienists is to conduct systematic and comprehensive risk assessments to scrutinize various aspects of a workplace or setting. At a high level, there are four phases to the risk assessment.

Phase 1 - Hazard Anticipation and Identification

The first phase in an industrial hygiene risk assessment is to anticipate and identify potential hazards. Anticipation involves understanding the possibility of potential hazards in an environment before they happen. Identifying hazards involves recognizing and pinpointing specific elements, substances, or conditions that have the potential to cause harm. For example, the presence of harmful substances used in the operation of equipment such as the hexavalent chromium (Cr6) used in a compressor station, which was the source of the Hinkley water contamination.

Phase 2 - Exposure Assessment

Once potential hazards are identified, exposure assessment is a critical next step to evaluate the extent of people’s exposure to these hazards and understand the potential risks to human health.

An exposure assessment is the process of estimating or measuring the magnitude, frequency, and duration of exposure to a hazard (EPA) as well as determining how a person might be exposed, such as through inhalation, skin contact, or other means. The assessment will also examine practices and working conditions that may contribute to exposure. It defines who might be harmed and how.

The ultimate purpose of an exposure assessment is to help quantify exposures to potential health risks. This is essential for understanding how environmental factors may affect human health, guiding risk assessments, and shaping strategies to minimize or manage exposures in various settings or for specific activities. Industrial hygienists are highly qualified to implement testing methods to accurately quantify exposures in real-world scenarios.

For example, if a chemical hazard is identified, an industrial hygienist would review all of the ways someone might be exposed to the chemical, who is at risk of exposure, and how many times and how long they might be exposed.

Phase 3 - Risk Evaluation

Once potential hazards are identified and their exposure has been assessed, the next phase is risk evaluation. This involves determining the likelihood of the risk and the severity of the risk, and comparing it against given risk criteria to calculate its significance or risk level. This can make it easier to prioritize which risks need more attention and resources.

For example, for a chemical hazard, an industrial hygienist would determine the likelihood of someone being exposed and the severity of that exposure.

Phase 4 - Putting it All Together With Risk Mitigation and Management

After conducting a comprehensive risk assessment, the next step is risk mitigation and management. This involves reviewing the assessment data and findings and deciding what controls should be implemented to eliminate or reduce the risk as well as how these will be monitored for their effectiveness.

As mentioned at the beginning of this article, a risk assessment must also include a continuous improvement process. As new information becomes available or as conditions change, the risk assessment needs to be revisited and updated accordingly. Regular reassessment ensures that the workplace remains safe and that controls are effective in minimizing potential hazards.

Why Your Business Needs Industrial Hygienists

By proactively managing and mitigating occupational health risks, organizations create safer workplaces and surrounding communities. Beyond safety concerns, several benefits emphasize that investing in the services of an industrial hygienist is a strategic move for your business.

Reduced Illness and Injuries and Increased Well-being

Implementing industrial hygiene best practices can aid in reducing illnesses and injuries in a variety of settings. Industrial hygienists use their expertise to identify and mitigate potential hazards before they can become serious health issues. Reducing injuries and illnesses will have a positive impact on employee health and morale.

Regulatory Compliance

Industrial hygienists help organizations comply with regulatory requirements, such as those of the U.S. Occupational Safety and Health Administration (OSHA). Their expert guidance will help to minimize the risk of fines and penalties due to non-compliance.

Environmental Protection

An industrial hygienist can help to identify and mitigate environmental hazards and risks. Their expertise will also help companies develop sustainable and eco-friendly practices.

Improved Community Relations

Industrial hygiene will demonstrate your commitment to environmental and community health. This will have a positive impact on your company’s reputation in the community as a responsible corporate citizen.

Emergency Response Preparedness

Industrial hygienists will contribute to the development and implementation of effective emergency response plans. If an incident occurs, they will also have an active role in coordinating with emergency response teams to safeguard employees and the community.

Cost-Savings and Economic Benefits

Hiring an industrial hygienist is a strategic investment with long-term cost savings and significant economic benefits, such as:

Minimizing fines and penalties from enforcing bodies

Avoiding health claims and costly exposure litigation

Lowering insurance premiums

Decreasing employee healthcare costs

Reducing worker compensation claims

Lowering employee absenteeism and sick leave

Increasing productivity

Attracting top talent

Preserving company brand and reputation

Improved relationships with customers, suppliers, banks, and investors

Final Thoughts

Companies must prioritize the safety and well-being of their workforce, safeguard the community, and protect their reputation. Companies can’t afford to overlook their responsibility in preventing workplace and environmental hazards Industrial hygienists are your essential partners in this commitment and responsibility. Industrial hygiene will help minimize the financial impact of accidents and illnesses on both employees and the organization and will help organizations avoid the financial burdens associated with workers' compensation claims, medical expenses, and potential legal battles.

The best time to hire an industrial hygienist is before an incident happens. However, they are also key to an organization’s ongoing monitoring and continuous improvement procedures as well as emergency response planning and implementation. Proactively engaging industrial hygienists is a strategic investment which aligns with a company’s broader goals of responsible business practices and a resilient and sustainable future.

Contact us today for a confidential appointment and find out what Exposure Consulting can do to help your company stay on top of any risks, prevent incidents and unnecessary expenses, and most of all, keep your employees and the community safe.

Citations:

U.S. Bureau of Labor Statistics: https://www.bls.gov/iif/#:~:text=In%202022%2C%20employers%20reported%202.8,to%20460%2C700%20cases%20in%202022.

U.S. Bureau of Labor Statistics: https://www.bls.gov/news.release/cfoi.nr0.htm

Gallup News: A Seven-Year Stretch of Elevated Environmental Concern https://news.gallup.com/poll/391547/seven-year-stretch-elevated-environmental-concern.aspx

National Council for Occupational Safety and Health: The Dirty Dozen 2018: https://nationalcosh.org/sites/default/files/documents/dirty-dozen-2018.pdf

Did you know that something as innocuous as a glass of water could harbor potentially harmful substances? It's time to dive into the world of exposure science and uncover the truth about PFAS (per- and polyfluoroalkyl substances), commonly known as "forever chemicals." In this eye-opening article, we will explore the key takeaways from a thought-provoking podcast episode with Dr. Alex LeBeau, an esteemed exposure scientist. Brace yourself, as we unravel the complexities surrounding PFAS, from their environmental impact to their adverse health effects.

The 'Forever Chemicals' Controversy:

PFAS have recently gained attention as a significant environmental concern. Found in various everyday products like food packaging, clothing, and even firefighting foams, these heat-resistant and water-repellent substances have infiltrated our water sources. But what sets them apart and earns them the ominous nickname of "forever chemicals"?

Key Takeaway 1: Understanding PFAS Compounds

PFAS is a broad class of chemicals characterized by their different carbon chain lengths and functional groups. Although regulatory agencies have varied definitions, there is consensus that PFAS pose potential risks to human health. Dr. LeBeau sheds light on how the fate and transport of PFAS in the environment, as well as their absorption and elimination from the body, depend on their specific characteristics. However, this also means that the effects and implications of PFAS can vary significantly.

Key Takeaway 2: Analyzing PFAS in Surface Water

Detecting and quantifying PFAS in surface water is crucial for assessing their environmental impact. Dr. LeBeau highlights two methods commonly used: the 16/33 and 537.1 methods. The former is more suitable for high solids content but requires extra steps, while the latter has been widely adopted for assessing PFAS in surface waters. However, variations in how laboratories implement these methods can lead to discrepancies in outcomes, making it challenging to draw definitive conclusions.

Key Takeaway 3: Navigating the Complexity of Risk Assessment

Determining the health risks posed by PFAS is no easy feat. Assessing small changes in doses and cancer incidence while accounting for confounding factors requires meticulous research. Dr. LeBeau stresses the importance of considering both epidemiological and toxicological evidence to avoid contradictory findings. Additionally, the speaker elucidates the complexities of regulating carcinogens versus non-carcinogens, where extrapolation from high-dose data becomes necessary.

Key Takeaway 4: Epidemiological Antibody Evaluation and PFAS Levels

Cross-sectional studies examining antibodies and PFAS levels have presented challenges. Variability in antibody concentrations, confounding factors like environmental exposures and pathogens, and the difficulty of establishing temporal relationships all complicate the interpretation of results. Dr. LeBeau advises caution when drawing conclusions from small changes in antibody response linked to chemical differences.

Key Takeaway 5: Weighing Risks and Taking a Calm Approach

As exposure scientists, Dr. LeBeau emphasizes the importance of considering overall risks and adopting a calm approach to managing substances like PFAS. While it's crucial to address and regulate their presence in drinking water, it's equally essential to maintain disinfectant levels. Striking the right balance between these two priorities can be a challenging but necessary path to protect public health effectively.

Conclusion:

Forever chemicals in our drinking water represent an undeniable challenge, but a calm and informed approach is crucial. The exposure scientist's insights provided a clear understanding of the complexity surrounding PFAS. It's time for us to engage, educate ourselves, and advocate for responsible regulation and management of these hazardous substances. Together, we can make a difference in safeguarding our water sources and ensuring a healthier future.

Take Action

Are you concerned about the presence of PFAS in your drinking water? Stay informed and engage with local authorities, regulatory agencies, and community organizations to advocate for rigorous testing and reliable mitigation strategies. Spread awareness among family, friends, and colleagues to create a ripple effect of change. Our collective actions today can shape a safer tomorrow.

Legionnaires Disease: Understanding the Threat

Legionnaires' disease is typically caused by inhaling aerosolized water droplets containing Legionella bacteria. These bacteria thrive in warm water environments, such as cooling towers, hot tubs, showers, and decorative fountains. However, assessments of facilities show that there are other areas of a facility’s water system that could contribute to the presence and growth of Legionella bacteria.  Human risk factors exist (e.g., age, gender, immunocompetency) that increase the chances of Legionella impacting the body. 

What has been the Recent  Legionnaires Disease Incidence Trend?

In order to evaluate that question the overall trend during Legionnaire’s disease tracking should be examined.  Figure 1 shows the evolution of tracking Legionnaire’s disease over time since 1976.

Figure 1: With the exception of 2020 as an outlier during COVID-19, It is obvious to see that the number of annual cases has been steadily increasing since 2003, after years of remaining relatively stable.

While the annual numbers tell one story, can weekly CDC reportable totals compared with these tell another? A comparison of weekly reportable can provide insight on how many cases are being underreported when compared with the annual numbers.

How Can Weekly Legionellosis Reporting Illustrate Legionnaires Disease Underreporting?

The CDC’s National Notifiable Diseases Surveillance System (NNDSS) enables public health agencies to share information on infectious diseases (e.g., legionellosis) that the Council of State and Territorial Epidemiologists (CSTE), in consultation with CDC, has designated as nationally notifiable - i.e., Legionnaires' disease. 

Through the NNDSS, cases of Legionnaires' disease (as legionellosis) are reported weekly and displayed in tables for ease in tracking the number of cases for each US state and some territories. Weekly reportable disease case reporting began in 2006 and has continued since. Annual tables are released at the end of each year, which show the total number of cases of Legionnaires Disease for that particular year. These annual numbers are often revised and there is a lag in reporting of these values.  For example, 2020 is the most recent year that annual tables for reportable illnesses are available.

While CDC warns against using weekly legionellosis for understanding prevalent disease impact, the weekly data can be used in an underreporting analysis to illustrate how often the disease can be overlooked-this is especially important for facilities trying to understand the impacts of the Legionella bacteria on facility water quality and management. 

Below is a sample of data from CDC WONDER (Wide-ranging Online Data for Epidemiologic Research) Weekly Infectious Disease Tables (Legionellosis Week 37, 2023):

Figure 2: CDC Wonder Table. The Week 37 reports 56 cases of legionellosis with a cumulative 2023 year to date (YTD) of 4,398 cases. CDC provides a weekly update of this table as the year progresses.

Legionnaires Disease Underreporting Using Weekly Data

For underreporting analysis, the current week totals for each week during the year have been summed and compared to the yearly totals that CDC reports on an annual basis, when available. Weekly data can be used to illustrate the continued and increasing underreporting that is occurring for Legionnaires disease cases. In the figure below, weekly incidence of Legionnaires' disease cases for respective years were totaled and compared with the annual total as reported at the end of each year by CDC. The data in Table one reflect the weekly percentage of the annual total, and the underreporting based on the weekly percentage.

Table 1: Yellow is underreporting at 60% or greater.  Red is underreporting at 70% or greater. *= Based on cumulative weekly total because CDC has not finalized annual numbers for these years.

A visual representation of the underreporting using weekly data can be viewed in Figure 3. As illustrated and from Table 1, weekly totals are underreporting the total cases by at least 50% for most of the years data are available.  In the years since COVID-19, the underreporting has increased to an average of 75%.

Figure 2: Orange represents the CDC annual totals for legionellosis (i.e., Legionnaires' disease) since 2006 and the blue represents the sum of the weekly totals as reported by CDC- when weekly reporting numbers were first available. 

While the weekly summed totals have always lagged the annual numbers, there has been an increasing trend in recent years of annual disease underreporting e versus weekly reporting. Figure 3 below highlights the increasing trend in underreporting since weekly tracking started.

Figure 3: Legionnaires' disease underreporting trend since 2006.

It is clear through the weekly data that underreporting of disease incidence is an increasing issue, especially in recent years. Below the possible contributing causal factors to these increases will be explored.

Legionnaire's Disease Underreporting Causal Factor Analysis

Updated 2019 CSTE Case Definition

The Council of State and Territorial Epidemiologists (CSTE) is an organization consisting of epidemiologists serving public health from states and territories in the United States. CSTE provides technical advice on infectious diseases to the CDC, including CDC adopting the CSTE legionellosis case definitions.

In June 2019, CSTE updated the Legionellosis definition for identifying reportable illnesses. The last case definition update was in 2005 and had legionellosis associated with two clinically and epidemiologically distinct illnesses: Legionnaires’ disease and Pontiac fever. Additionally, CSTE identified only two case classifications in 2005: suspected and confirmed.

With the new 2019 definition, CSTE added a "probable" case classification which is identified as a "clinically compatible case with an epidemiologic link during the 14 days before onset of symptoms". A new "extrapulmonary legionellosis" case description was also added during this update. See Figure 4 for underreporting since CSTE case definition change.

Figure 4: Legionnaires' disease underreporting trend since 2019 CSTE case definition update.

The underreporting trend following the update is marginal, but the impact could be hampered by the short amount of time that has passed - and the impacts of COVID on disease identification- since the updated case definitions.

Implementation of ASHRAE Standard 188

In June 2015, the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) released Standard 188 titled " Legionellosis: Risk Management for building Water Systems". The standard outlines specific assessment and control areas that building designers, owners, and operators shall follow in regards to managing legionellosis risk within building water systems. It also details general requirements necessary for any building that may need to make use of the standard’s guidance in reducing the risk of legionellosis for building occupants. ASHRAE developed this standard specifically aimed at preventing the growth and spread of Legionella. It defines types of buildings and devices that need a water management program as well as devices (e.g., hot tubs, cooling towers) that need to be controlled in order to prevent the growth and spread of Legionella.

Figure 5: Legionnaires' disease underreporting trend since ASHRAE Standard 188 released.

The purpose of ASHRAE 188 was to establish minimum risk management requirements for legionellosis risks in building water systems. That is, implementation of risk management techniques to minimize the incidence of legionellosis within a facility that originated with the building water system. However, based on stratification of the CDC data in Figure 5, underreporting has continued to increase since the implementation of the standard.

Implementation of EPA Disinfectant Byproduct Rule

First proposed in 1994, the Stage 1 and stage 2 Environmental Protection Agency (EPA) disinfection byproduct (DBP) rules were intended to protect public exposure to constituents formed during the disinfection process when an antimicrobial (e.g., chlorine) interacted with organic material (e.g., bacteria or other carbon-containing water contaminants). Stage 1 implementation was required to begin in 2002 for systems servicing>10,000 people, and 2004 was the set implementation deadline for smaller water utilities.  Stage 2 implementation was also staggered, with 2012 as the implementation deadline for systems servicing >50,000 people and 2013 as the dead line for smaller water utilities.

While it is not possible to evaluate the underreporting data from 2002 (because the weekly reporting did not start until 2006), the data from the Stage 2 DBP rule can be stratified for an understanding of the impacts the rule had on incidence reporting.

Figure 6: Legionnaires' disease underreporting trend since EPA DBP Stage-2 implemented.

While there is an initial reduction in underreporting (e.g., 2014 and 2015), the overall trend is increasing. An interesting observation in the data following the 2012 DBP implementation for larger water systems is the first instance in the weekly reporting data of more than 100 legionellosis cases (2013: Week 26 - 105 cases).

Legionnaires' Disease Underreporting Discussion

There is no doubt that Legionnaires disease cases are underreported. The analysis above used weekly data to understand underreporting as it related to annual legionellosis incidence. These data can illustrate how delays or changes in external factors (e.g., identification of disease or confirmation via CSTE case definition) can impact our understanding of disease incidence in the moment.

While weekly data stratification can allow an evaluation of the impact that certain changes have had on underreporting, the main culprit may be the bureaucratic process that is imbedded in disease tracking. For example, CDC warns against using weekly data (they identify it as "provisional") and highlight the unreliability of using weekly values to compute a cumulative annual total. From CDC:

"Current Week: For a case to be published in the table under current week, it must have been reported to CDC during that week and assigned by the jurisdiction to that MMWR week. Cases assigned by the jurisdiction to that MMWR week but reported later or cases reported in that week but assigned to a different MMWR week are published in the CDC WONDER weekly tables in the cumulative total column for that year, but are not published in any current week column. As a result, the cumulative sum of cases does not equal the sum of the number of cases published each week."

AND

"...weekly totals should not be added to compute the cumulative count for a year. It is not uncommon that cases are reported after data has been published for the week, or that updates change whether the case meets the case definition or publication criteria. Less commonly, a case definition is modified or the criteria are clarified during the year, resulting in a reevaluation of previously reported cases." (emphasis added)

If so many revisions or delays in reporting are occurring, perhaps there is a process issue that should be addressed. CDC also states, the following, which is in contrast to their statements above:

"Public health surveillance of national notifiable infectious diseases and conditions helps public health authorities monitor the effect of these diseases and conditions, measure the disease and condition trends, assess the effectiveness of control and prevention measures, identify populations or geographic areas at high risk, allocate resources appropriately, formulate prevention strategies, and develop public health policies."

If data needs constant revisions, than these efforts are hindering more than they are helping understand disease prevalence. The analysis of the legionellosis case definition update in Figure 4 show a moderate impact, but there are other factors that cannot be account for in this analysis. For example, the detection of this disease by public health officials in recent years has been hampered by COVID-19 due to similar disease outcomes (e.g., pneumonia, fever, etc.). Because the case definition changed the latter half of 2019, there the impact of the change (and bureaucratic red tape for case confirmation) may be masked by COVID prevalence, surveillance, or recognition, among other factors. This is a plausible outcome because the average underreporting during the COVID years (i.e., 2020-2022) is 75%. (Table 1). This is further supported by the fact that no finalized annual legionellosis numbers have been released since 2020, even though CDC guidance states that final numbers should be published approximately 10 months following year end.

Beyond the layers of reviews and re-reviews that are taking place dur to the changing epidemiological definitions for disease surveillance, other factors are also influence reporting (and thus, underreporting). Ass Dr. David Krause points out in his blog the impact the DBP rules have had on the ability for control of pathogens like legionella in drinking water systems. The weekly data illustrate that impact because there were no weekly reporting of 100+ cases of Legionnaire's disease until the full implementation of the Stage 2 BDP rule:. See Figure 7.

Figure 7: Number of 100+ legionnaire's disease days in each year. Note that the one day reported in 2020 appears to be an outlier, because there were 129 cases reported the last week of the year (i.e., Week 52 in December 2020), which is an unrealistic number for the winter months.

If cases were increasing following the DBP State 2 implementation, why did weeks of 100+ cases cease after CSTE change the case definition? Perhaps the revisions that were necessary were creating such a lag that weekly underreporting was increasing more than before, as the data indicate with 75% underreporting during 2020-2022.

The implementation of ASHRAE 188 (and other efforts, like those taken by Centers for Medicare and Medicaid Services) was to increase understanding, identification, and management of legionellosis risk in facility water systems. Based on Figure 5 above, underreporting is an increasing problem, even since the release of the standard. However, if a side effect of the standard is to increase awareness of the risk, why is the underreporting trend increasing?

Based on the analysis above, there are a number of factors that can and are influencing Legionnaire's disease underreporting. There are also likely factors not analyzed above that are also contributing (e.g., CMS requirements for reducing Legionella risk in healthcare facilities). The data above are not to assign a causative reason in his article, but to illustrate that increasing bureaucratic layers of constant revisions and reevaluating based on case definitions and confirmatory tests is masking true incidence on a weekly basis and leading to revisions and underreporting on an increasing scale. Overall active Legionnaire's disease surveillance and and underreporting of the true prevalence appears to take a back seat to other diseases (e.g., COVID-19) and the trend appears to be increasing.Legio

One of the most critical changes a hurricane can instigate is the failure of utility services due to the overwhelming impact of the storm. These failures have a domino effect on both the utility system and the end-users, such as homeowners. A particularly vulnerable aspect is the local water utility, where the absence of power and flooding can lead to the stagnation of potable water, the clean water intended for consumption. This stagnant environment becomes a breeding ground for pathogenic bacteria like Legionella. The absence of disinfectants, such as chlorine, in the stagnant water allows Legionella to thrive, posing a significant risk to human health once the systems are reactivated. Evaluating water quality within utility water mains and buildings becomes imperative to detect the growth of Legionella or other waterborne pathogens.

In the aftermath of a hurricane, buildings inundated by floodwaters become a fertile ground for the rapid proliferation of hazardous microbes. The levels of mold and endotoxins surge to alarming heights following water intrusion events. The intense winds accompanying hurricanes have the ability to transport environmental particles into spaces where they do not belong. Mold spores, previously confined to the outdoors, find their way into homes and buildings, establishing a potential health threat. The convergence of water intrusion and favorable temperature conditions, arising from power outages and lack of air conditioning, creates an ideal setting for mold growth.

It is evident that hurricanes, beyond their immediate dangers, can leave a trail of latent health risks, both immediate and long-term. The interplay of profuse water intrusion, elevated temperatures, and power outages provide the perfect storm for the growth of Legionella and fungi. As communities start the arduous process of recovery, they must remain vigilant against these hidden health threats.

By recognizing the potential risks that lurk beneath the surface, we offer a comprehensive approach to minimizing the dangers posed by these unseen health threats. Our expertise can make a tangible difference in safeguarding the well-being of communities struggling to regain their footing.

The aftermath of a hurricane extends far beyond the immediate physical devastation, revealing a range of health risks that demand attention and action. When utility services collapse and water stagnates, dangerous pathogens can grow. Flooded buildings also become breeding grounds for mold and other microbial hazards. The combination of these factors creates a perfect storm for potential health crises, emphasizing the need for proactive measures in the aftermath of Hurricane Ian. Amid the wreckage and challenges, it is imperative to remain aware of these hidden threats and to seek guidance from specialized experts to ensure the health and safety of affected communities.

What are the health implications of Forever Chemicals?

Recent news articles on PFAS (Per- and Polyfluoroalkyl Substances) have been highlighting the exposures that many people in the United States may have been exposed to the compound. PFAS are often called “forever chemicals” due to how long they survive in the environment. Could you be harmed by a chemical that could survive “forever”? We can evaluate what PFAS exposure means in terms of how dangerous it may be for you.

When making the determination, it is important to understand how people can be exposed to PFAS in everyday life. We likely have had exposures without even realizing we used PFAS-containing products. Personal exposures can include use of products intended to prevent food sticking (e.g., food packaging or cooking surfaces), ingestion of products from areas where PFAS may exist in the environment (e.g., drinking water or fish), or indirect exposure to PFAS that is contained within soil or settled dust that may exist inside the indoor environment.

Drinking Water Focus

Drinking water appears to me a major exposure pathway for the general population. A recent article in the Los Angeles Times highlighted the concern for PFAS exposures in urban areas based on a newly released study. Additionally, a recent finding by the University of Florida identify PFAS in drinking water where residents of a Florida county are being exposed. Are these exposures that you should be concerned about? We will explore this question within this article.

So what is PFAS

PFAS (Per- and Polyfluoroalkyl Substances) are a category of chemicals with at least one active chemical group. These active groups break down very slowly under typical conditions, making this category of chemicals useful for everyday products. PFAS function in many different capacities like surfactants, friction reducers, firefighting foams, and repellents of water, dirt, and oil. Many people think that all PFAS chemicals are the same because they have similar properties. However, there are actually different groups and subclasses within the PFAS umbrella.

While it may sound daunting, it is important to understand that PFAS is not one chemical but a group of chemicals. PFAS are generally categorized into six main groups: perfluorooctanoic acid (PFOA), perfluorooctanesulfonic acid (PFOS), perfluorobutanesulfonic acid (PFBS), perfluoroheptanoic acid (PFHpA), perfluorohexanesulfonic acid (PFHxS), and perfluorononanoic acid (PFNA). Within these groups, there are over 50 classes of PFAS, comprised of several individual similarly structured compounds.

How dangerous is PFAS?

While there are a number of known exposure routes, there is a general lack of agreement regarding the exact danger these chemicals may present. This is largely due to the many varieties and types of PFAS. There is insufficient information about the potential effects of inhaling PFAS. Exposure pathways such as aerosolization of PFAS-containing products and PFAS entrained in settled dust have been theorized, but there is still much to be explored.

PFAS Exposure Dosages that cause illness

Important questions to consider are, “is PFAS a human health risk and, if so, at what dose?” Unfortunately, the answer is not so clear. Although several studies have examined PFAS exposure by directly measuring PFAS levels in human samples, there is a limited number of studies that assess general population exposure using passive dosimetry. Studies on metabolism have demonstrated that the chemical structure of PFAS can affect how it interacts with the human body. This makes it challenging to categorize all PFAS as a single entity. Based on the particular PFAS structure, there are differences in how to interact with the body. These differences can impact half-life, which affects how long the substance will stay in the body.

This brings up the next question, “what will PFAS do to me”? That is, what are the toxic endpoints for PFAS? Again, there is no straightforward answer. The varying structures of PFAS makes general evaluation difficult. Different endpoints have been evaluated in different categories of PFAS. There have been studies that associate liver toxicity with PFOA, PFNA, PFBA, and GenX exposure. Developmental effects have been associated with PFOA, PFOS, and PFNA. Thyroid effects have been evaluated in relation to PFHxS and PFBS. Immunotoxicity, reproductive effects, and kidney issues have been linked to PFOS, PFHxS, and PFBS exposure respectively. These varying effects illustrate the difficulty in evaluating these PFAS substances as a single category.

Regulatory

Beyond the toxic endpoints there is also a concern among some regulators and others that PFAS exposure will cause cancer. The International Agency for Research on Cancer (IARC) performed a hazard assessment and identified that PFOA is possibly carcinogenic to humans at some hypothetical dose (Group 2B). Furthermore, the Environmental Protection Agency (EPA) has conducted a recent evaluation of PFOA and PFOS under the Safe Water Drinking Act. The findings have led to the identification of these two PFAS categories as having clear indications of being potentially carcinogenic. In the assessment, the EPA affirms that PFOA and PFOS have a high probability of causing cancer, specifically kidney and liver cancer. They further stress that there is no minimum dose that is considered safe for exposure to these substances. chemical is considered safe” and that “there is suggestive evidence of carcinogenic potential of oral exposure to HFPO–DA in humans, but the available data are insufficient to derive a cancer risk concentration”. There has been criticism of the EPA risk assessment because of the low threshold established based on the limited available data, especially considering that the latest epidemiological studies have yielded inconsistent findings to link cancer outcomes to PFAS exposure.

Limited assessments have been done on other PFAS compounds, including the short-chain variety, which creates information gaps in the PFAS umbrella category. Additionally, studies in humans and animals have been variable and inconclusive. It is unclear if the differences in health effects are species specific or related to dose differences. Inconsistencies in the epidemiological evidence are primarily due to generally limited information regarding PFAS exposure. There are several consistent reports of several biological effects associated with PFAS exposure; however, a direct causal relationship between PFAS exposure and critical health outcomes has not been defined.

Evaluating the Causal Relationship Between PFAS and Health

In scientific circles, it is important to identify both the exposure and whether the exposure actually causes a health issue. In this scenario, are there enough data published to support a general causal relationship with PFAS and human disease?. That is a question that was likely evaluated in a recent settlement decision for PFAS in water supplies. Many scientists believe that the available data on causation are inconclusive, although the scientific evaluations done in these lawsuits currently remain unknown to this author.

Summary

There are approximately 500 PFAS substances registered with the Chemical Abstract Service (CAS). Because there are so many PFAS chemicals, it is important to understand: what risk does PFAS exposure mean for the general population? There is mixed information on how dangerous PFAS is as a category. If there is a concern about exposure, it is advisable to conduct a risk assessment to determine whether anyone may be at a higher risk for health issues. Who should be initiating these types of assessments? If someone under your care (e.g., building tenants, employees, etc.) is being exposed to PFAS then it is recommended that their exposure be understood and quantified to understand the health risk. It is better to be proactive in this scenario than attempt to play catch-up when reacting to a PFAS risk situation.

*This blog contains updated information from a previous version*

 Stay at home orders from government officials in response to the SARS-CoV-2 virus and the resulting COVID-19 disease has resulted in closure of numerous business and buildings. Closing buildings abruptly could have unintended consequences if building owners and operators did not take proactive steps before closure or staff reductions. 

In some scenarios, building owners and operators were able to close using appropriate methods that will make eventual re-opening more streamlined. However, because of the fast-moving nature of the mass closures, many buildings may have been left in an “as-is” condition. This means that minimal preparation may have occurred when closing. Changes in building use patterns for a facility that is designed to be used daily can impact the indoor environment. These changes can manifest as degradation in water quality or increased indoor humidity levels.

Buildings and supportive systems were designed to be used while occupied. Water, HVAC, and electrical systems are intended to maintain equilibrium with the people inside the building. Because of an unexpected closure, a building could be operating in a scenario that greatly changes the loads on the mechanical systems. These changes could have negative impacts on the building’s systems. For example, a building that was designed to have hundreds of gallons of water flowing through potable water pipes when occupied will now have stagnant water flow conditions. Low or no flow of water in premise plumbing and associated water heaters will consume disinfectant (e.g., chlorine) quickly and result in conditions where waterborne pathogens may grow, especially Legionella. Additionally, less water will likely be used in utility water mains, contributing to stagnant conditions throughout the system.

Opportunistic pathogens like Legionella do not discriminate and can benefit from conditions where their growth is allowed to occur unabated. Interruptions in water use, similar to what is occurring in response to COVID-19, have been previously associated with outbreaks of Legionnaires’ disease, but on a smaller scale. Because of larger system-wide changes in water quality conditions, there is potential for Legionella growth within the plumbing of buildings that have closed for extended periods of time. Individuals re-occupying a building after closure could be exposed to the Legionella bacteria and may be at an increased risk of developing Legionnaires’ disease, a reportable illness, unless procedures are established to ensure the safe re-start and operation of the facility. Identifying Legionnaires’ disease cases following re-occupancy may be complicated because individuals with the disease and COVID-19 may have similar health issues (e.g., fever and pneumonia). This may lead to misidentification of the real reason behind the cause of disease and could result in ongoing issues linked to the building.

The current standard of care has placed the management of waterborne pathogens on building owners and operators. It is up to the owner and operator, not the local water utility, to manage the safety of the water within a facility.

Cooling towers are also under the control of building owners and operators and are a potential exposure point for Legionella. Changes in heat loads from lack of typical building operations may negatively impact heat transfer mechanics at a facility. Health departments have identified cooling towers as sources of Legionnaire’s disease outbreaks. Changes in operational capacity and limited or absent maintenance staff during this time may result in cooling tower conditions that may be favorable for Legionella bacteria growth to occur.

Continuity of indoor environmental operations will also be essential when bringing a building back into service. Indoor humidity levels may be higher than are prescribed if HVAC systems were turned off or were adjusted beyond recommendations before vacating a building. Elevated relative humidity can lead to mold and moisture problems on building materials or equipment left in place at the time of closure.

Cleaning surfaces that people will contact will become an important step in ensure the safe re-start of a facility. Building owners will have to understand that cleaning may not be a one time event, but rather a continuous effort. A one time cleaning for the “Coronavirus” may give a false sense of security. Limited studies have suggested that different surfaces can harbor the virus longer than others, showing the importance of routine cleaning protocols once people are again routinely interacting with the building environment. Further, a building owner or operator receiving a “certification” from a company showing elimination the virus via testing will need to have the certification reviewed to understand how the contractor established cleanliness of the surface (e.g, surrogate testing or otherwise). Currently, the EPA lists disinfectants that meet the criteria for use against SARS-CoV-2. It is important to understand the safety of the disinfectant, ensure that it is being used in accordance with its registered uses, and that they are being handled by employees in a safe way.

As a quick summary to the main points covered above:

• Buildings closed as a result of COVID-19 can have water     stagnation in potable water pipes.

• Water stagnation can quickly deplete residual     disinfectants and can allow waterborne pathogens, like the Legionella bacteria,     to grow uncontrolled.

• The current standard of care focuses on building owners and operators for the  management of     waterborne pathogens in a facility.

• Cooling towers can also be negatively impacted by     changes in building conditions, like allowing Legionella to grow if     not maintained during non-occupancy.

• Changes in indoor humidity levels can result in mold     and moisture issues on building materials and internal fixtures.

• Ensuring the safe function and cleanliness of key     systems and areas, including internal surfaces, is vital to maintain the     safety of occupants entering a building after a closure.

• Guidance documents by governmental organizations and professional groups (some available below) have been issued on this topic and others are being developed due to the fast moving nature of COVID-19 response.

Exposure Assessment Consulting can aid in evaluating site conditions when reoccupying a building. We can help identify the steps owners and operators can take to address stagnant water conditions, how to deal with changes in the indoor building environment, and can assist owners and operators in evaluating the effectiveness of cleaning procedures. Dr. Alex LeBeau is a toxicologist, certified industrial hygienist (CIH), and a human health risk assessor that has over twelve years of experience evaluating exposures and identifying high risk exposure scenarios that require mitigation. He has performed Legionella risk assessments at facilities, for both proactive measures and following outbreaks of Legionnaires’ disease. He has also evaluated the effectiveness of cleaning procedures following contamination and remediation. Together with our other professionals, we can assist building owners and operators identify scenarios that could lead to unsafe conditions for occupants. Please feel free to reach out and let us know if we can be of assistance or if you have any questions. 

 Alex LeBeau, PhD, MPH, CIH

Email: alexlebeau@exposureconsulting.com

Phone: 321-263-1333

Useful links for on topics covered above:

 Guidance from the American Industrial Hygiene Association (AIHA)- Recovering from COVID-19 Building Closures:

CDC Guidance for Building Water Systems: https://www.cdc.gov/coronavirus/2019-ncov/php/building-water-system.html 

 EPA Disinfectants meeting the criteria for use against SARS-CoV-2:

Monday December 22, 2008, an environmental disaster struck in Kingston, Tennessee. Tennessee Valley Authority (TVA)’s Kingston Fossil Plant released 1.1 billion gallons of coal ash into the nearby Clinch and Emory Rivers and covered nearly 300 acres of surrounding land. The coal ash damaged numerous homes and building structures, rendering them uninhabitable, and polluted waterways. While the initial spill clean-up did not result in immediate deaths or injuries, years later, those hired by TVA to clean up the release started to develop illness such as leukemia, lung cancer, and brain cancer. Within ten years of the disaster, forty workers had died.

On April 17, 2015, the first national regulations on the disposal of coal combustion residuals (CCR) were finalized and signed into effect. The new rules under subtitle D of the Resource Conservation and Recovery Act (RCRA) address the risks from improper disposal of coal ash as they pertain to leaking into groundwater and the aerosolization of contaminants. These new regulations require coal burning facilities to establish recordkeeping and reporting habits as well as make specific information accessible to the public. Of particular interest to those affected in Tennessee were the regulations regarding groundwater monitoring. Regulations would now require owners and/or operators of a CCR unit to monitor well water. Owners or operators would need specific procedures for sampling and methods for analyzing the data collected from groundwater to detect the presence of hazardous materials, such as arsenic and other heavy metals, along with water parameters. If the levels of hazardous materials found exceeded a groundwater protection standard, or if the water parameters measured were not adequate, the owner or operator would have to implement corrective actions.

While the new RCRA rules were headed in a positive direction, a 2018 decision resulted in the roll back of these regulations. This decision could potentially lead to the leaching of coal ash containing heavy metals (e.g., arsenic, mercury, and selenium) into water supplies from coal-fired power plants. The US Environmental Protection Agency (EPA) weakened the previously listed RCRA regulations by allowing weaker standards for many hazardous contaminants and leaving the issue of groundwater monitoring, both sampling and remediation actions, up to the states. Many states have left such actions up to the coal plants themselves. While there are many of these facilities that will proactively develop these plans, the TVA disaster shows what could happen when coal plants are allowed to check their own homework. Allowing coal plants to decide whether or not their actions are harmful may lead to coal ash leaking into the surrounding groundwater and could potentially result in severe adverse health effects on those who rely on the water.

Coal ash is the waste that is left after coal is combusted, mostly in coal-fired electric power plants. Coal ash can contain particulates of volatile and semi volatile organic compounds and heavy metals. The main hazards of coal ash are the substances of which it is made. Coal ash is known to contain arsenic, lead, mercury, selenium, cobalt, cadmium, chromium, manganese, and other known hazardous substances. Elevated levels of these heavy metals can be detrimental to one’s health and well-being. The composition of coal ash is any ratio of the above-mentioned heavy metals and can vary depending on the ground source of the coal. The potential for severe harm due to coal ash exposure is endless, especially because EPA has not labeled coal ash as hazardous waste. This means there are no governmental regulations on the proper way to dispose of the substance. This has allowed for many coal powered plants to dispose of their waste product in coal ash ponds, many of which can be unregulated. A minority of these ponds found in the United States have a protective lining to impede the coal ash from seeping into the groundwater. This is a big problem because data from many coal ash ponds show that they are leeching unknown levels of coal-associated substances into groundwater, ending up in nearby rivers and lakes, potentially putting thousands of lives at risk.

A real danger comes from EPA by allowing these power plants to regulate themselves. Under the new regulations, power plants are to check the surrounding groundwater levels only if they believe their actions cause dangerous levels of hazardous materials in the water. The problem is you are asking these companies to self-determine what “dangerous levels” are. The EPA, ATSDR, and CDC have not established what dangerous or acceptable levels of coal ash are beyond identifying the ash as a hazard, so how will coal ash companies know what the appropriate thresholds are?

Ten years after the Tennessee Valley disaster, forty people who were involved in the cleanup died and over 400 residents in the neighboring communities experienced severe health effects. Residents near TVA are not the only communities affected by coal ash ponds. An investigation in August of 2013 revealed numerous inmates at the State Correctional Institution Fayette in Pennsylvania had developed thyroid disorders, respiratory illnesses, GI tract problems, and even cancers. The correctional institution is surrounded by two coal ash ponds and over 40 million tons of combustion waste.

With states no longer monitoring groundwater, there is no way to know the amount of hazardous material coal ash ponds are leeching into the ground, subsequently contaminating the water supply. There are uncertainties with coal ash and the level or risk for downstream receptors, like the inmates mentioned above.  Overall, power companies self-determining if their actions are safe will, almost undoubtably, cause exposure to coal ash at unsafe levels and more devastating headlines.

References

1. Sears, C. G., & Zierold, K. M. (2017). Health of Children Living Near Coal Ash. Global pediatric health, 4, 2333794X17720330.

2. Drinking water and public health impacts of coal combustion waste disposal [electronic resource] : hearing before the Subcommittee on Energy and Environment of the Committee on Energy and Commerce, House of Representatives, One Hundred Eleventh Congress, first session, December 10, 2009. (2012). Washington : U.S. G.P.O., 2012.

3. Messinger, M., & Silman, M. (2016). Unmanned aerial vehicles for the assessment and monitoring of environmental contamination: An example from coal ash spills. Environmental Pollution (Barking, Essex : 1987), 218, 889–894.

4. Deonarine, Amrika, Bartov, Gideon, Johnson, T.M., Ruhl, Laura, Vengosh, Avner, and Hsu-Kim, Heileen, 2013, Environmental impacts of the Tennessee Valley Authority Kingston coal ash spill; 2. Effect of coal ash on methylmercury in historically contaminated river sediments: Environmental Science & Technology, v. 47, no. 4

5. Carlson, C.L., and Adriano, D.C., 1993, Environmental impacts of coal combustion residues: Journal of Environmental Quality, v. 22, no. 2, p. 227‒247

6. U.S. Environmental Protection Agency, 2014a, Coal combustion residuals (CCR)―Surface impoundments with high hazard potential ratings: U.S. Environmental Protection Agency

7. Dennis Lemly, A. (2015). Damage cost of the Dan River coal ash spill. Environmental Pollution, 197, 55–61

8. American Coal Ash Association, 2013, 2013 coal combustion product (CCP) production & use survey report: American Coal Ash Association

The safety of these artificial sweeteners has been evaluated under regulatory guidance and scientific methodologies. For example, in the United States, both aspartame and Sucralose are approved food additives under the U.S. Food and Drug Administration (FDA) specific uses. This means that they have followed the regulations and scientific requirements set by the FDA to make sure these products are safe to use. In the European Union (EU), aspartame (E 951) and Sucralose (E 955) are authorized food additives used as sweeteners in food products that have been evaluated and approved by the European Food and Safety Authority (EFSA). However, there have been recent reports and publications calling the safety of these sweeteners into question.

Aspartame As A Carcinogen

The International Agency for Research on Cancer (IARC) has identified aspartame as a possible human carcinogen (Group 2B: Possibly Carcinogenic to Humans). However, it is important to evaluate the limitations of IARC monographs when it comes to real world scenarios, including the fact that IARC only identifies potential hazards and does not evaluate dose or exposure risk when reviewing information. There are other limitations to the IARC assessment process when it comes to evaluation of information and how it translates to a risk assessment. Understanding these limitations is important when evaluating the overall carcinogenic potential and safe use of aspartame.

A recent study being highlighted in news media identifies potential health implications for Sucralose via the sucralose-6-acetate analog. The study examined Sucralose and an analog (considered an impurity by the authors) using various testing guidelines from the Organisation for Economic Cooperation and Development (OECD) and other methods described in published literature. It is not clear if good laboratory practices (GLP) were followed for any of the evaluation methods of Sucralose and the analog. As stated previously and within the study, Sucralose is an approved food additive. These types of regulatory assessments involve scientific evaluations and data submissions for regulatory review before they are approved.

This new information should be evaluated in both the context and within the wide body of literature in the knowledge database. As history will show, artificial sweeteners have been down this road before. Previously, saccharin was labeled as ‘reasonably anticipated to be a human carcinogen’ and required a cancer warning on the label. However, after conducting a more thorough assessment of the sweetener, it was determined that the mechanism responsible for the development of bladder tumors in male rats receiving high doses was not applicable to humans. Consequently, in the year 2000, the warning was lifted.

The above sweeteners have been studied in previous regulatory submissions. The anticipated findings by IARC or other publications should be evaluated in context to identify the actual risk assessment from ingestion, not just a theoretical hazard that may hypothetically exist.

Please feel free to reach out to Exposure Assessment Consulting to discuss these exposure and risk scenarios. We have previous experience evaluating the safety of food ingredients and can assist with any questions your clients may have on these exposures and related risk assessment.

References:

https://www.tandfonline.com/doi/full/10.1080/10937404.2023.2213903

https://nypost.com/2023/06/06/chemical-found-in-splenda-damages-dna-genotoxic-discovery/

https://www.efsa.europa.eu/en/topics/topic/sweeteners

https://efsa.onlinelibrary.wiley.com/doi/full/10.2903/j.efsa.2017.4784

https://www.eurekalert.org/news-releases/773600

https://www.efsa.europa.eu/en/topics/topic/aspartame

https://www.reuters.com/business/healthcare-pharmaceuticals/whos-cancer-research-agency-say-aspartame-sweetener-possible-carcinogen-sources-2023-06-29/

https://www.statista.com/chart/24713/sweets-chocolate-consumption-by-country/

https://nypost.com/2023/06/06/chemical-found-in-splenda-damages-dna-genotoxic-discovery/

https://www.cancer.gov/about-cancer/causes-prevention/risk/diet/artificial-sweeteners-fact-sheet