Understanding Environmental Impacts on Housing: Regulating Pollution Exposure Pathways

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Explore the regulatory framework for managing pollutant exposure in homes, highlighting the complexity of exposure pathways and the importance of assessing risks based on toxicity and exposure levels. The discussion covers various exposure pathways such as drinking water, air quality, dermal contact, and vapor intrusion, emphasizing the significance of evaluating pollutants like VOCs, lead, asbestos, and household chemicals. Understand the role of environmental statutes and regulations in ensuring testing, record-keeping, and reporting of chemical risks.

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Environmental Impacts on Housing: Regulating Pollution Exposure Pathways in the Home Valerie Tachtiris Deputy General Counsel Indiana Department of Environmental Management

Exposure pathways

Presence of a pollutant does not always mean exposure to that pollutant Environmental regulators often speak in terms of complete and incomplete exposure pathways

Complete Exposure pathways-EPA guidance 1. Source how the substance enter the environment 2. Media air, soil, and/or water 3. Exposure where receptors contact the media 4. Exposure Route how the substance enter the receptor s body (ingestion, inhalation, dermal) 5. Receptor which plants and/or animals are exposed or potentially exposed Source: https://www.epa.gov/ecobox/epa-ecobox-tools-exposure-pathways-exposure-pathways- era#:~:text=For%20an%20exposure%20pathway%20to,one%20or%20more%20exposure%20routes

Exposure pathways in the home Drinking water Air in the home Dermal contact Incidental ingestion

Vapor Intrusion Infiltration of vapor- forming chemicals into a building from the subsurface. Common pollutants: VOCs, PCE/TCE, PCBs, and benzene Are volatized and enter homes through soil, groundwater, and/or sewer and drainlines

Pollutants of concern in the home Remember: presence of a chemical does not (necessarily)create an exposure pathway Environmental risks are evaluated based on toxicity and exposure

Pollutants of concern in the home Household chemicals Lead paint and products Contaminants in drinking water Asbestos VOC and other air pollutants

Environmental Statutes and Regulations

Requires testing, record-keeping and reporting by chemical manufacturers. Environmental Regs Toxic Substances Control Act Directly addresses the production, importation, use, and disposal of specific chemicals including polychlorinated biphenyls (PCBs), asbestos, radon and lead-based paint. Excludes food, drugs, cosmetics, and pesticides.

Regulates public drinking water systems that supply water to at least 15 service connections or 25 people. Environmental Regs Safe Drinking Water Act EPA has set legal limits on over 90 contaminants based on health effects and technological feasibility. Sets water-testing schedules and methods that water providers must follow.

U.S. EPA and delegated states conduct and pursue remedial actions under the Comprehensive Environmental Response, Compensation, and Liability Act. CERCLA gives EPA and states broad authority to require remedial actions and/or recover their costs from parties determined to be responsible for the contamination, regardless of whether the activity was permitted/legal at the time. Environmental Regs CERCLA Common applications of CERCLA to environmental exposure in the home would be soil remediation, groundwater assessment and remediation or use limitation, and VI mitigation. EPA guidance requires remedial actions conducted under CERCLA to be evaluated every five years. In December 2012, EPA provided additional guidance to project managers on assessing VI risk as part of five-year reviews. http://semspub.epa.gov/src/document/HQ/176385

EPAs attempt to ban manufacture of most asbestos-containing products was overturned by the Fifth Circuit Court in 1991. Asbestos exposure typically occurs through the lungs and is most likely when asbestos containing material (ACB) is disturbed in demolition/home renovations. Federal air regulations require building owners to notify the appropriate state agency before conducting demolitions/projects that could disturb ACB. Environmental Regs Asbestos Removal and Licensing Regulations Residential buildings with four or fewer dwellings are exempt; however, contractors are subject to worker safety practices and proper disposal requirements. Contractors and workers must be licensed to ensure an understanding of applicable safety requirements.