# Baylor College

# or**~kdirinc**



### Statement by William Brett Perkison, MD, MPH and Rebecca Jensen Bruhl, DrPH, MPH, MEM Proposed Petroleum Refinery Sector Risk and Technology Review and NewSource Performance Standards August 5, 2014 My name is Dr. Brett Perkison. I am assistant professor of Family and Community Medicine at Baylor College of Medicine. I am board certified in Family Medicine as well as in Occupational and Environmental Medicine, and am medical director of Baylor College of Medicine's soon-to-open adult environmental health clinic. I also have over 15 years of clinical experience treating patients in a primary care clinic in the Houston area, and have worked as an occupational and environmental medicine physician, both in an academic setting and in the oil and gas industry along the Houston Ship Channel. I appreciate the opportunity to speak to you today about EPA's proposed petroleum refinery rule. I applaud EPA's efforts to reduce air toxic emissions from refineries; this is vitally important to the health of our community. Air pollution is a serious concern here in Houston, where hundreds of chemical and refinery plants sit in close proximity to more than two million people. Despite the many controls that have already been put in place by industry, some neighborhoods still have outdoor concentrations of air pollution high enough to pose an unacceptable health risk. Medical problems related to airtaxies exposure are notonly devastating to individuals and their families but are a huge economic burden to the Houston community as a whole, in terms of lost productivityand increased health care costs. Two air taxies of particular concern, given the high levels repeatedly measured at outdoor air monitors in Houston, are benzene and 1,3-butadiene (Sexton, Linder et al. 2007; Linder, Marko et al. 2008). The link between occupational exposure to these chemicals and the development of pediatric and adult cancers (e.g., leukemia and non-Hodgkin's lymphoma) is well established (International Agency for Research on Cancer 2012). But, benzene and 1, 3-butadiene are onlytwo examples ofliterallythousands ofchemicals thatwould be further controlled if EPA fully implements this proposed rule. I urge you, as a physician and member of the Houston community to implement a rule with improved health as the clear and unambiguous goal of all of its components. Dr. Rebecca Bruhl will now discuss several important new studies of particular relevance to the proposed rule. Most ofthese studies examine health effects associated with air pollution mixtures at outdoor concentrations thatwere previouslythought ofas "safe."

Good afternoon. My name is Dr. Rebecca Jensen Bruhl. Iam assistant professor of Medicine at Baylor College of Medicine and associate directorofBaylor's Environmental Health Service. Because ourtime is limited, Iwould like to speak directlyto EPA's request forcomments regarding the effects of early life exposure to emissions from petroleum refineries. As you are all too aware, early exposures often result in life-long-and sometimes devastating-consequences. According to the draft rule, EPA does not believe thatthe environmental health or safety risks addressed by this action present a disproportionate risk to children. However, numerous recent studies suggest thatthe levels ofairtaxies we experience in oureveryday lives-and that are often even higher in neighborhoods near refineries-increase the risk for childhood cancers, birth defects, and other major health problems in ourchildren. For example, there is growing scientific evidence of a link between early childhood cancers such as acute lymphoblastic leukemia (ALL), acute myeloid leukemia (AML), and bilateral retinoblastoma with greater exposure to traffic-related pollution during the mother's pregnancy (Crosignani, Tittarelli et al. 2004; Amigou, Sermage-Faure et al. 2011; Vinceti, Rothman et al. 2012; Ghosh, Heck et al. 2013; Heck, Wu et al. 2013; Heck, Park et al. 2014). A newly published case-control study, based on records of children under age 6 from the California Cancer Registry, found that the risk of acute lymphoblastic leukemia was significantly elevated with increased exposure in the 3rd trimesterto benzene, polycylic aromatic hydrocarbons, arsenic, and several other taxies. Risk ofacute myeloid leukemia was also elevated with increased exposure to benzene, chloroform, and two other traffic-related taxies during the 3rd trimester. This study suggests that exposure during the 3rd trimester and early life may be especially critical to the development of cancer later in life (Heck, Park et al. 2014). Such "windows ofdisproportionate effect" are well established and should be addressed by EPA. Similarly, a study published in 2011 by Lupo and associates using the Texas Birth Defects Registry found that mothers living in census tracts withthe highest levels ofbenzene duringtheir pregnancy were significantly more likelyto have children with spina bifida, adevastating birth defect (Lupo, Symanski etal. 2010). An article soon to appear in the widely respected journal Epidemiology suggests that in utero exposure to ambient air taxies (including 1,3-butadiene, benzene, toluene, ethylbenzene, xylenes, formaldehyde, lead, and chlorinated solvents) from traffic and industry emissions increases the risk ofautism in children (von Ehrenstein OS, Aralis Hetal. 2014). Because there are high correlations among pollutants in ambient air, it is difficult to disentangle the effects of single substances. It could be that mixtures ofambient air pollutants, rather than single pollutants, are related to the specific health endpoints, possibly due to synergistic effects. Cumulative or concurrent exposure to mixtures of environmental agents-as well as to non-chemical stressors such as noise and stress-can modify the effects of single chemicals considerably (Sexton and Linder 2011). Although EPA has begun studying cumulative and multipollutanteffects, the proposed rule remains particularlyweak in this regard. Although there are still many uncertainties in the medical literature related to the impact of air taxies on reproductive and developmental outcomes, what we do know is that our community is burdened with high levels of pollution and multiple stressors that increase susceptibility to health-related disorders-and recent studies suggest thatchildren are at especially high risk. We must do a betterjob ofaccounting forand minimizing the impact oftoxic emissions on children's health and protect our already over-burdened communities. To do this, EPA needs to further strengthen the rule to address the real-world impacts ofrefinery emissions.

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