Clean Air’s Response to the University at Buffalo’s Tonawanda Health Study

The following statement was written collaboratively by Tonawanda members, Clean Air board members and Clean Air staff. Members of the Clean Air Board of Directors are elected through an annual membership vote. Members of Clean Air live in neighborhoods in Western New York that are disproportionately impacted by pollution, and pay annual organizational dues, lead campaigns and organize for public health and environmental justice in their communities.

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Clean Air was founded by residents living in the most industrialized neighborhood of New York State who suspected that their health problems were linked to the facilities in their neighborhood. They collected air samples that revealed high levels of carcinogenic chemicals in the ambient air. Through smart, strategic organizing, we were awarded a $1 million air study from New York State in 2007, which confirmed benzene levels were well over federal guideline concentrations, and that Tonawanda Coke Corporation was responsible for these high emissions.

Our members ran a direct action campaign against the company that resulted in a federal investigation. The verdict found Tonawanda Coke Corp. guilty in criminal court of breaking 14 federal laws under the Clean Air Act and the Resource Conservation and Recovery Act. Mark Kamholz, the environmental control manager, was found guilty on the same counts and an additional count of obstruction of justice. He was sentenced to a year in prison. The facility, which is still in operation, was forced to change its process and comply with federal law. Today, total emissions of benzene, a known human carcinogen, have decreased in the surrounding community by 92%, while New York State’s air monitors continue to operate in the neighborhood.

One outcome of the court process was that the University at Buffalo’s School of Public Health and Health Professions was awarded $11 million from fines levied against the company to perform a health study entitled “The Tonawanda Health Study: An Epidemiologic Study of Health Effects and Coke Oven Emissions from Tonawanda Coke.” The stated aim is to explore the health impacts of benzene in Tonawanda, health impacts of residents’ lifestyle choices, health effects of Tonawanda Coke emissions, and potential health impacts on Tonawanda Coke employees.

The study will be conducted over a ten year time frame by taking blood samples of Tonawanda residents and conducting surveys. Over the last few years Clean Air staff, board and members have been approached by faculty members working on this study requesting participation and endorsement of the University at Buffalo’s study. We have chosen not to participate in or endorse the study for the following reasons:

• Clean Air is committed to building real power in communities that have been cut out of decisions that impact their lives. Our organizing improves public health, quality of life, and builds equity. In determining our position on participation and endorsement of academic studies the Clean Air Coalition follows an academic research policy. The Clean Air Coalition academic research policy was created to set a standard by which we choose to engage in academic research. Our academic research policy was put in place to prevent us from engaging in academic studies that exploit residents and run contrary to our values. We will only engage in research that will enhance the capacity of residents to participate in the political process, bridge the gap between regulatory frameworks and community issues, impact policies, regulations and budgets, and transform decision makers. This study meets none of our required criteria for our participation.

• The Clean Air Coalition is dedicated to bringing residents to the center of the political process. We operate under the conviction that the persons most entitled to decision making are those who are affected by their outcomes. As already stated, the design and intent of the study relegates residents to subjects for experimentation. Given the role of residents in the study, the study’s intent, design and expected findings will not and cannot enhance their capacity to participate in the broader political process affecting their lives. It simply subjugates them and relegates them to a role of blind subjects for errant experimentation. It is clear to us that this study will be conducted with neither the design or intent to improve the lives of residents in Tonawanda.

• The study design proposes taking blood and urine samples on Tonawanda residents. These samples are to be analyzed for benzene metabolites. This is performed as a means of estimating ambient benzene air levels. The researchers will also collect population survey data. The study then proposes to compare benzene metabolite measurements against the population survey data. Following the comparison, the study then proposes to use these measurements to draw unspecified conclusions about the population.

• The study presents glaring failures of adherence to scientific rigor and ethical practices. To begin, the sampling of blood and urine to assess ambient air benzene exposure in a population is inappropriate. Measurement of blood and urinary benzene metabolites fluctuate as high as a factor of 10 over an 8 hour period. This fluctuation is due to the high rate at which benzene metabolites break down in the human body. As a result, blood and urine samples to assess ambient air benzene exposure is not only inaccurate; The existing body of scientific knowledge casts this method as inappropriate.  We already know the ambient air levels of Benzene. Based on NYSDEC air monitoring data we know that Tonawanda has had elevated levels of benzene and other volatile organic compounds (VOCs) in the ambient air. We know not only the type of VOC, but also their concentration.

• Vast research has been done on the negative health impacts of these chemicals, and is publicly available through the Department of Health, Environmental Protection Agency, and many other sources. We know, based on the New York Department of Health Outcomes Review (2009), which reviewed the occurrence of 18 different types of cancer in Tonawanda, that lung cancer, bladder cancer and total cancers were elevated among both males and females; esophageal cancer and oral cavity/pharynx was elevated among males; and uterine cancer and leukemia was elevated among females.

• In the case of benzene, exposure from point sources such as Tonawanda Coke, the research is already clear on the impacts to resident health. There is no shortage of knowledge linking chronic and acute exposures of benzene to harmful impacts on human health. The intent of the University at Buffalo’s study is to use dubious methods to conclude that which is already known to regulators and communities.

• The effects of benzene and the levels of benzene are known and have been known for a decade. Researchers are not needed to reconfirm again what the scientific community and the Tonawanda community already knows. What we need are enforceable policies that are based on equity and health. What we need is democratic decision making in how public money and resources are spent.  What we need are agencies, elected officials and corporations that are accountable to people who are impacted by their decisions. This study does not even begin or attempt to address these issues.

Based upon the documents provided to us, written and verbal conversations with representatives from the University at Buffalo (Dept of Epidemiology and Environmental Health, School of Public Health and Health Professions), we find the study insufficient to allow our participation. The study is not simply insufficient, but also damaging to our vision and values as an organization. After a thorough review of the health study, consultation with members active in the Tonawanda Coke campaign, within Tonawanda, our staff, and based on the values and process of Clean Air’s academic research policy–Clean Air’s Board of Directors has determined our organization will not participate in this study.

– Clean Air Board of Directors –