Moodie and Evans Respond

Abstract

Despite the charges by Stifelman et al., nowhere do we claim that blood lead levels (BLLs) were used as the sole criterion for cleanup actions at Bunker Hill. Rather, we argue that insofar as BLLs were one of the Remedial Action Objectives (RAOs) specified in the Record of Decision (ROD), this criterion was neither protective nor proactive in reducing risk. The threshold of concern (10 μg/dL) is far too high in light of a mounting body of evidence showing the adverse effect of lead at much lower levels.1–6 In addition, the other RAOs for environmental criteria (e.g., soil, dust, and water contaminant levels) were set at levels much higher than the Environmental Protection Agency’s (EPA’s) own standards.7 Although Stifelman et al. remain confident about the “protectiveness of the remedy,” this confidence does not equal valid and reliable data. The continued low participation in blood lead screening remains troublesome. In 2010, only 13 of 475 Medicaid children residing in the original Bunker Hill site (otherwise known as the “Box”) were screened; one had a BLL greater than 10 micrograms per deciliter. With less than three percent of Medicaid eligible children screened, let alone the broader population, safe lead exposure levels cannot be claimed. Although Stifelman et al. claim that “[a]chievement of BLLs below the RAO did not—and will not—stop remediation,” in February 2012 the EPA announced a massive scale back of the cleanup efforts at Bunker Hill.8,9 The EPA Region 10 director of environmental cleanup admitted that the work planned under this plan may not be sufficient. Finally, the social justice concerns raised by the use of BLLs (as well as other environmental criteria) as RAOs are not based on the distribution of exposure along socioeconomic lines. To the extent that the residents of Bunker Hill can be considered a vulnerable population (poverty, low educational achievement, and a background of poor health outcomes), exposure to lead increases the risk of adverse health outcomes compared with nondisadvantaged populations. The result is an exacerbation of the existing inequalities that threaten the health and well-being of Bunker Hill residents.