Environmental and Public Health Interventions around NOA:

A Community Case Study

Marci R. Culley, Ph.D.

Georgia State University

GSU/CDC Seed Grant Awards in theSocial and Behavioral Sciences

Purpose – enhance research relationships

How this study came about

2 years

Research Team - Who are we?

- Agency for Toxic Substances and Disease Registry

- Georgia State University Community Psychology

- skill sets

Why Collaborate on this Issue?

Previous ATSDR & GSU collaborations

Environmental health science and behavioral sciences- some conceptual integration- limited application

Federal environmental and public health agencies- environmental hazards intervention, public

involv.- series of successes and failures

Enhance understanding of env. health intervention

Potential widespread impact of NOA

Overview of Study

The Setting for Research

El Dorado Hills, California

Why We Chose El Dorado Hills

Significant regulatory and public health attention

Complexity of dealing w/ NOA in residential setting

Unique challenges associated w/ NOA

- regulatory “hot potato”

- not your typical “dirt job”

Potential widespread nature of NOA

- broader public health implications

- recent attention from USGS, others

Notable Environmental and Public Health Actions in El Dorado Hills

Oak Ridge High School- EPA’s cleanup under CERCLA / Superfund authority

- ATSDR’s Public Health Consultation

EPA’s October 2004 activity-based sampling- Rolling Hills Middle School- Jackson Elementary, garden - Silva Valley Elementary- NY Creek Nature Trail- CSD park

Media

Continuum of Coverage…

Series of articles

1998 – present

Sacramento Bee

Mountain Democrat

Science News

January 13, 2007

“U.S. EPA to revisit asbestos toxicity”

Mother Jones: May/June 2007

Specific Aims of the Study

1) Use social and behavioral sciences methods to conduct a qualitative community case study:

- describe the environmental and public health interventions / “actions” used to mitigate NOA effects

- document how these were perceived by key stakeholder groups

- determine feasibility of framework / tool for assessing these

2) Provide guidance to communities potentially effected

Panel convened to provide feedback in 2 areas:

- case study findings and recommendations- accuracy and utility of analytic framework / tool

Panel Participants’ experience - Program evaluation / logic models - environmental public health intervention- NOA science- community members

3) Disseminate results in various ways

- academic journals- academic conferences- environmental and public health officials- media- El Dorado Hills community

My focus tonight:

Qualitative Case Study Findings

Research Questions:

1. What is the nature of environmental and public health interventions / “actions” in this community?

2. How do key stakeholders experience these?

3. How might this case study inform future interventions?

Qualitative Community Case Study Method

Laying groundwork for recruitment, interviews- talked with ATSDR staff- met with LAWG, CAG- recruitment e-mails to key stakeholder groups- compiled and read background info

Sought Interviews with 4 key stakeholder groups: - County level officials (N=11)- State agency officials (N=9)- Federal agency officials (N=8)- Community activists (N=10)

Targeted sample to meet objectives of case study

Interview Participants

Federal and state govt. employees (11)- 7 federal (87.5%), EPA and ATSDR - 4 state (44.4%), CARB, OEHHA, DHS

Community activists (7) – 70% of those recruited

County employees - 0- some initial interest expressed- e-mail from EDC Superintendent of Schools- those who initially expressed interest then declined

DTSC employees – 0 - cited lack of time, scheduling conflicts- informally told otherwise, not confirmed

Interview Method

In person by GSU researcher and grad assistant

- August and September 2006

Location chosen by participants

Average length about 1 hour

Informed Consent, Confidentiality

Audio recorded, transcribed verbatim for analysis

Open-ended question asked of all participants

“Tell me what you think is important for me to know about how NOA had been addressed in El

Dorado Hills…”

Possible Interview Prompts

What “actions” / interventions occurred?

What worked well / was successful?

Challenges?

Lessons learned or recommendations?

Open-ended technique allows for rich description of participants’ experiences vs. researcher’s preconceived notions of such

Data Analysis – Interviews

Participants given opportunity to review transcripts- about ½ offered edits / clarifications- typically minor

About 400 single-spaced pages of transcripts- textually analyzed - to identify emerging themes and subthemes

Goal to characterize data – range of responses- NVIVO 7 qualitative data software

Document Data Sources

Hundreds of pages of background info reviewed- specific to NOA “actions” in EDH / EDC- env & public health agencies at local, state, fed levels- scholarly publications- information produced by stakeholder groups- media- several key docs

• 2005 Joint Senate Committee Hearing transcript• agency websites, fact sheets & reports

Chronology of Events / Timeline Development

- triangulation of data sources

Interview Findings

(Table pp. 20-21)

Actions

Challenges

Successes

Recommendations / Lessons Learned

Most and least salient…

Actions

(100%)

Communication

Asbestos ID / Sampling / Monitoring

Enhanced Regulation and Enforcement

Building Agency Collaboration

Remediation / Mitigation

Risk Assessment Work

Communication Subtheme

Series of public meetings most frequent (100%)

- May 2005 joint EPA / ATSDR meetings- GV, ORHS, BOS, EPA science seminar

E-mail, telephone btwn agencies and citizens (55%; 57%)

Inter-agency communications (73%; 14%)

General agency communication w/ public (55%; 29%)

- public release of reports, press, policymakers- fact sheets, websites, info repository

Attendance of ACAG, LAWG meetings (18%; 14%)

Asbestos ID / Monitoring / Sampling Subtheme

(91%; 100%)

“Historic” sampling / ID in mid 1980s (27%; 57%)

- GV, Cothrin Ranch Road, DMG mapping

ORHS and surrounding areas- CARB (45%; 57%)

- EPA (64%; 29%)

- County (18%; 57%)

- School district (18%; 43%)

- CSD (9%; 43%)

EPA’s Oct 2004 activity-based sampling (73%; 43%)

- most frequently noted by participants

Enhanced Regulation and Enforcement Subtheme

(82%; 100%)

County’s BEACON dust program (45%; 100%)

State’s updated ATCM and related rules (64%; 29%)

- paving materials, quarries, construction / dust

DTSC’s Interim Guidance for CA Schools (55%; 43%)

- new construction rules - O & M Guidance- hazardous materials removal / oversight for lot

County regulation of “buffer zones” (0%; 43%)

Building Agency Collaboration Subtheme

(91%; 43%)

EPA state and county (45%; 0%)

ATSDR state and county (55%; 0%)

EPA & ATSDR EPA Tech Working Group (36%; 0)

Method 435 Group (36%; 0%)

County Task Force / Steering Committee (18%; 29%)

BOS collaborations with State DMG (0%; 29%)

OEHHA’s technical support work (18%; 0%)

EPA’s USGS (18%; 0%)

Remediation / Mitigation Subtheme

(64%; 80%)

EPA’s removal action at ORHS (55%; 43%)

County level remediation efforts (27%; 57%)

- ORHS, CSD

Road paving in Garden Valley (36%; 29%)

DTSC hazardous materials removal (0%; 29%)

- tremolite on Woedee Drive residential lot

Risk Assessment Work Subtheme

(82%; 52%)

ATSDR’s Public Health Consult for ORHS (36%; 57%)

ATSDR’s 2nd Health Consult (45%; 0%)

EPA expert panel (9%; 29%)

ATSDR’s biomarkers expert panel (18%; 0%)

OEHHA’s risk assessment work (18%; 0%)

ATSDR’s “white paper” / NTP proposal (18%; 0%)

- EPA’s response to RJ Lee report (27%; 14%)

Challenges

(100%)

Regulatory Issues - The “hot potato” effect (100%; 86%)

- Regulatory “loopholes” (91%; 100%)

- The nature of bureaucracy (36%; 29%)

NOA Science- Risk assessment and communication (100%)

- Sampling methods and analyses (91%; 71%)

- Identification of “asbestos” (73%; 71%)

- The nature of asbestos and remediation (45%; 86%)

Challenges Cont…

Local and State Issues- Resistance to NOA issues (91%; 100%)

- Community conflict (100%; 86%)

- Resource issues (82%; 57%)

- Distrust of government (64%; 0%)

Political Context (73%; 100%)

- Political nature of local, state and federal agencies- Conflict of interest- Conflicting political values or ideology

Regulatory Issues…

The “Hot Potato” Effect

“It was kind of like, ‘well who’s in charge here?’ I mean, that’s really…a huge problem and will continue to be a

problem for issues like that everywhere.”

Govt. Employee

“You envision a bunch of people standing in a big circle and everybody pointing to the right claiming it’s this guy’s

responsibility.”

Citizen

Regulatory Loopholes

Lack of regulation specific to NOA

Enforcement of O & M procedures

Dust rules

Land use planning

“Part of the huge issue is that this kind of situation falls through the regulatory cracks.”

Govt. Employee

“What has happened is incomplete and…is focused on new construction, not addressing historic issues.”

Citizen

NOA Science

Risk assessment and communication- ill-fitting, underdeveloped risk models- related debates on toxicity of different fibers- disproportionate focus on chrysotile / occupational- lack of understanding

latency periods, disease mechanisms

dosage, duration, synergistic / cummulative

- modeling risk from soil / traditional air sampling

- challenges of risk communication given these

“You can’t answer the specific questions of ‘well my kid plays soccer five times a week, is he gonna get sick?...the problem is we don’t know…we don’t know if one serious

hit off that big cloud is gonna be enough to trigger disease.

Govt. Employee

“Sometimes the public may not realize that [it is] very frustrating for us to not be able to provide a clear answer

to them…we’ve got answers based on a lot of inexact science.”

Govt. Employee

“They don’t have all the answers, and as far as risk is concerned, they’re never gonna have black and white

answers, and I don’t think people understand that here…that’s not the nature of risk.”

Citizen

NOA Science Cont…

Sampling methods and analyses

- “Ambient” / “Background” air monitoring- flow rates, testing limits- location of monitors- whether done under “realistic” situations- capturing personal activity-based exposures

- Soil sampling- variability- capturing personal activity-based

exposures

NOA Science Cont…

ID of “asbestos”- cleavage fragment vs. fiber debate- ID beyond “serpentine” / “ultramafic”- fiber types (chrysotile v. amphiboles)- visual inspection v. electron microscopes

Nature of asbestos and remediation- once uncovered and spread around- not a “typical dirt job”- invisible nature of fibers

“You can’t undergo some kind of normal remediation process where you’d clean it up and bury it or seal it. What’s

our solution? So that’s a real challenge.”

Govt. Employee

“No matter how much you spray water on it…this is not a controllable situation…it dries…the wind blows and people run over it with bicycles or walk on it, or animal tracks or whatever, so…it’s never a controllable situation, which

humans feel they can control everything.”

Citizen

Local and State Issues

Resistance to acknowledging or addressing NOA- particularly county officials- state agencies- residents, parents, school staff

“A lot of what US EPA and ATSDR [did] was motivated by the perception that there had been a lack of willingness on

the part of some state agencies and perhaps local agencies…to even acknowledge there was a problem.”

Govt. Employee

“People don’t want to know.”

Citizen

Local and State Issues Cont…

Community conflict- polarization evident via media, public meetings- “fallout” feared if petitioners named- difficulty working together- impacted federal agencies’ work

“I heard it more than once that ‘oh this is just something these anti-development people are making up so that we

retain our green space and we don’t put up any more houses up here…’ So, they literally thought that [it was] totally

fabricated.”

Govt. Employee

“[The former School] Superintendent said this was a left wing conspiracy brought out by environmentalists…it

polarized the population.”

Citizen

Local and State Issues Cont…

Resources- financial constraints- lack of staff and training / expertise

Distrust of government- especially federal govt.- across continuum

“[The] Air Pollution Control District…they’re a tiny office of three people. How can they run around making sure it’s

enforced?”

Govt. Employee

“The schools have certainly had to spend a lot of money in mitigation for asbestos.”

Citizen

“The executive offices of different [state] departments are kinda like ‘well, wait a minute, we’re not getting any funding

to do this…we don’t want this becoming an enormous resource sink.”

Govt. Employee

“Successes” / What Worked Well

(100%; 57%)

Science

Public Communication

Collaboration

CSD Work

Political Savvy

Science Subtheme

(64%; 43%)

EPA’s activity-based sampling (45%; 29%)

State geologists’ work (0%; 29%)

Method 435 work (9%; 0%)

CARB air monitoring efforts (9%; 0%)

EPA’s Technical Working Group (9%; 0%)

Public Communication Subtheme

EPA and ATSDR efforts (73%; 14%)

- May 2005 large public meeting / availability session

- EPA website, work w/ press, science seminar

- ATSDR biomarkers meeting

“I had never seen such a huge community meeting…a thousand people [were] there and I thought that was really

important because…I think there were a lot of different community members, not just the people who’d been

interested in it for a long time or who were activists but…the soccer moms, kids, the dad…it was an opportunity to get some information across…I thought the folks who were sitting up there from EPA and ATSDR did a great job.”

Govt. Employee

Collaboration Subtheme

(64%; 14%)

EPA and ATSDR

EPA Technical Work Group

Method 435 Group

County and DMG

CSD Work Subtheme

(0%; 57%)

Particularly CSD Director

“[The CSD Director] spent money…he hasn’t bitched or complained or whined. He’s just done it. He’s finding ways

to get it done.”

Citizen

Political Savvy Subtheme

(18%; 14%)

Community activists

– building awareness; catalyst for actions

EPA and ATSDR management

– “laying the groundwork”

“Lessons Learned” / Recommendations

(100%)

Proactive / Preventive Approaches (55%; 100%)

Resource Dedication (55%; 71%)

NOA Science Development (55%; 71%)

Policy Change (64%; 43)

Collaboration (36%; 43%)

Communication (55%; 14%)

Political Understanding (27%; 14%)

Tailored Interventions (18%; 14%)

“I hope El Dorado is a lesson to fast growing communities, to look at their environment, their

geology, and really take a hard look at how they should build, where they should build [so that they are]

actually preventing additional public health problems…This is a prime example to show other communities that it is up to them to…prevent themselves the heartache…

down the line.”

Govt. Employee

Interpreting Findings and Recommendations

Actions

Interview and document data sources revealed a fairly comprehensive picture of NOA actions

- Chronology / Timeline, triangulation of sources

- confirmed participant accounts

- filled gaps due to lack of participation by some

Challenges

Documents helped to confirm interview findings- county officials perceived challenges that parallel- evidence of county / state resistance- only stakeholder group to suggest overestimation

Data reveal differences in opinion about what challenges mean

- who has authority, responsibility?- who will devote resources?

Successes

Very little here…

- more from govt. employees

- typically qualified

- ambivalent about science, communication

“Lessons Learned” / Recommendations

Many offered

Multi-layered understanding of complicated issue

Social Sciences Literature

EDH community response similar to other communities facing toxic exposure disputes

- natural and chronic technological disasters / disputes

- psychosocial impact of toxic materials

- individual and community response patterns

- community conflict / “corrosive community”

- combination of natural and human-made elements here

- Lack of cohesive institutional response only exacerbates

Recommendations

Findings specific to this case

Social sciences literature

Researcher’s experiences with similar case studies

Necessarily Interrelated…

Recommendation #1

Proactive and preventive approaches are consistent with prudent public health practice and the precautionary principle; therefore, whenever possible, such approaches should be utilized.

These approaches are reasonable given U.S. environmental and public health agencies consider all forms of asbestos to be hazardous to human health

- evidence that amphiboles may be more toxic

At the local level, these approaches could:

- mitigate adverse p.h. outcomes associated with NOA- avoid expensive and impractical “after the fact remediation- ease community conflict related to NOA exposure disputes

Best of all scenarios - ID before exposed - develop strategies to avoid exposures- e.g., informed land use planning

If NOA has already been disturbed…

Some version of these approaches may still be applied

- avoid further release of material- contain the material already uncovered- track over time material identified on parcels- provide land owners with accurate info about exposure av.- relocate people to uncontaminated areas

Decision-making about implementation or whether necessary- involvement of local, state, federal agencies and public- meaningful engagement of all stakeholders - open process

These processes informed by evaluation of existing policies…

Recommendation #2

Evaluation of how existing policies specific to NOA (at local, state and federal levels) could facilitate a cohesive, comprehensive approach to the problem should occur.

Some changes in local (EDC) and state (CA) policies- aim to further protect public- gaps exist that yield less than prudent p.h. practices

Majority of interview participants cited “loopholes” / gaps

- pose significant problems for sufficiently addressing NOA- pose problems for protecting public

Working at cross-purposes w/ fed & state officials- contributed to inability of stakeholders to come together

- resistance to implementing O & M procedures- authority to enforce O & M- all forms of soil disturbance not addressed- retro-fitting, day-to-day residential v. commercial

Suggests that not all avenues have been covered to protect public

Not difficult to imagine similar scenarios elsewhere

Suggest consideration of the following points:

Differences in opinion about authority, responsibility- only exacerbated by gaps in policy- combined, can interfere w/ prudent public health

practices- public’s health would be better protected if gaps

addressed

Conflict of interest / resistance at local level- may interfere with enforcement and regulation p. h.

State and/or federal agencies may be better suited to lead - eval. (state-wide task force w/ local and national players)- develop & enforce existing regulations (land use w/

toxics)

Inadequate institutional response to toxic exposure disputes- associated with increased psychological / social stress- may pose additional, although unintended health risks

Recommendation #3

Evaluation of strategies to enhance resource dedication and usage at local, regional, state and federal levels should occur.

Resources should be dedicated to the following:

Continued development of NOA-related science

Adequate regulation and enforcement efforts

Ensuring “best practice” public health ed / communication- in communities already dealing with NOA- others with existing but unexposed NOA- effective and accurate communication - about what is known, not known, will never be known- could ease some community conflict

The development of local and state capacity to deal with NOA - economically; staff training / expertise

Further research to enhance community response to NOA issues

Community “Tool Kit” - may facilitate proactive / preventive approaches to NOA- for areas suspected to contain NOA- mapping, historical info, experiences of NOA communities

Might include:- strategies to determine roles / responsibilities of agencies- strategies to determine regs / planning processes in place- “model” regs, policies, monitoring related to NOA- “model” regs for id of “new areas” and existing conditions

Would be good reference to avoid “reinventing the wheel”- should include explicit statements about gaps

Recommendation #4

Prudent public health practice requires responsible leadership by those who have the resources, the power and the authority to protect the public, and such leadership, particularly from federal agencies should occur.

This kind of leadership could - emphasize importance of proactive / preventive approaches - facilitate consistent and comprehensive approaches

- inform NOA resource dedication and usage- engage local, state and natl’ players to guide policy change

When considering how responsible leadership might occur, we suggest consideration of the following points:

The politics of asbestos appear to impact policies at all levels- may interfere with enforcement and regulation- yield less than prudent public health practices

Federal agencies should take proactive approach- provide guidance to state and local agencies to protect

p.h.- “neutral” position may actually represent a position

In the case of El Dorado Hills

- downplaying resistance / conflict at local level- may have helped to facilitate polarization in community- what is known, not known…

No “Easy” Fix…

Complex, Multi-layered Issue

“You gotta get all of the stakeholders together in a room and you gotta have that knock down, drag out

fight to make progress. It’s always uncomfortable but it’s inevitable under our present system.”

Citizen

Conclusions

EDH community experiences not uncommon

Data suggest multi-layered approach to intervene- also indicate gaps in intervention / “actions”

Interventions to mitigate and prevent NOA exposure- will require multi-strategy, multi-level response

NOA science is still being developed- prudent p.h. practice dictates protecting the public

Stakeholders often have conflicting views- economic interests and health / well-being- will have to work together

Limitations of Study

Sample size, representativeness

- may be viewed as limitation- lack of participation of key stakeholder group- portraying an accurate picture of various positions- document data sources, chronology

Did not conduct interviews with the general public

- info about public participation, perceptions of “actions”- purposeful focus on key informants

Focus on agency “actions” versus community activist “actions”- catalyst for agency actions

Generalizability - reflected pattern of experiences similar to other cases

- can only speculate about extent- may reflect a story unique to this group- alternative explanations (e.g., privileged community)- access to resources may have shaped events here

Emphasis of depth versus breadth was purposeful- allowed for rich and descriptive data- based on multiple sources- accommodates exploration of patterns across data sets- inter-rater reliability- texts came “full circle”- suggests fairly representative story being told here

Helps to illuminate a pattern of experiences related to dispute

Acknowledgements

Janet Heitgerd, Ph.D., ATSDR

Terrie D. Sterling, Ph.D., CDC

Jennifer Zorland, GSU graduate research assistant

Panel Participants

Study Participants