Baylor 

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Statement by William Brett Perkison, MD, MPH and Rebecca Jensen Bruhl, DrPH, MPH, MEM 

Proposed Petroleum Refinery Sector Risk and Technology Review 

and New Source 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 air taxies exposure are not only devastating to individuals 

and their families but are a huge economic burden to the Houston community as a whole, in terms of lost 

productivity and 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 only two examples of literally thousands of chemicals that would 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 of these studies examine health effects associated with air pollution mixtures at outdoor concentrations 

that were previously thought of as "safe." 

Good afternoon. My name is Dr. Rebecca Jensen Bruhl. I am assistant professor of Medicine at Baylor College of 

Medicine and associate director of Baylor's Environmental Health Service. 

Because our time is limited, I would like to speak directly to EPA's request for comments 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 that 
the environmental health or safety risks addressed by this action present a disproportionate risk to children. 

However, numerous recent studies suggest that the levels of air taxies we experience in our everyday 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 our children. 

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 trimester to benzene, polycylic aromatic hydrocarbons, arsenic, and several other 

taxies. Risk of acute 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 of disproportionate 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 with the highest levels of benzene during their pregnancy were significantly more 

likely to have children with spina bifida, a devastating birth defect (Lupo, Symanski et al. 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 of autism in children (von Ehrenstein 

OS, Aralis H et al. 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 of ambient 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 multipollutant effects, the proposed rule remains particularly weak 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 that children are at especially high risk. 

We must do a better job of accounting for and minimizing the impact of toxic 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 of refinery emissions. 
Bibliography 

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Environ Health Perspect 119(4): 566-572. 

Crosignani, P., A. Tittarelli, et al. (2004). "Childhood leukemia and road traffic: A population-based case-control 

study." lnt J Cancer 108(4): 596-599. 

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