This is important information especially after Gustav.

Report to Congressional Committees
June 2007
Hurricane Katrina

EPA’s Current and Future Environmental Protection Efforts Could Be Enhanced by Addressing Issues and Challenges Faced on the Gulf Coast  PDF

This document shows where the EPA along with the state of Louisiana failed to accurately warn people of potential and certain health hazards including mold after Katrina and Rita.

I was a resident of Louisiana until recently and a victim along with my daughter and her baby of mold toxins thanks to the owners of Jefferson Lakes Apartments managed by Riverstone Residential (a few months before Katrina). After that, in pursuing litigation, we have become victims of the corrupt and unethical Louisiana court system and of the “mishandling” of our case by our attorney.

The following excerpt from this report shows how the state and the EPA did not sample indoor contamination as they did outside “because state and local governments did not request this assistance and because EPA determined that indoor testing was not necessary to characterize the environmental contamination resulting from the storm”.

Of course they would rather not have those test results because the government and state government are influenced by big money from the insurance industry and others.

Excerpts from the report –

Insufficient Disclosure about Its Decisions Regarding Sampling of Contaminants Limited Residents’ Understanding of the Potential Health Risks of Returning Home

Following disasters such as Hurricane Katrina, an immediate and primary concern of evacuees is whether and when it is safe to return to their homes. Accurate and timely information on many factors is important for residents to make this assessment–and to determine what they should bring with them when they do return, including items to mitigate potential health risks. One important factor residents need information on is the environmental contamination to which they may be exposed when they return home. Such contamination was a particular concern in New Orleans, a densely populated, older urban area in proximity to petroleum and chemical industry sites, as well as a number of Superfund sites, from which contaminants may have migrated into residential areas.

EPA worked with other federal and state agencies to support local officials evaluating home and neighborhood safety. In addition, as discussed earlier, EPA provided a substantial amount of information to the public on environmental health risks using reports (environmental assessment summaries), flyers, public service announcements made available to the media, and EPA’s Web page. However, EPA’s communications about the potential health risks from environmental contamination in New Orleans–three environmental assessment summaries prepared with, among others, the Louisiana Department of Environmental Quality[Footnote 47]–were released about 3, 6, and 11 months after Hurricane Katrina, limiting their usefulness to residents who would have benefited from more timely information about the environmental health risks they could face when returning home. These environmental assessment summaries convey some helpful information about the floodwaters, sediments, and air quality in the New Orleans area after the hurricanes–that is, about the potential health risks of being outdoors in the New Orleans area.

However, because some sampling decisions that EPA made were not sufficiently disclosed, residents could have been given the wrong impression about the potential health risks they could face in returning to their homes. For example, the first environmental assessment summary, released in December 2005, states that “the great majority of the data available show that adverse health effects would not be expected from exposure to the sediments from previously flooded areas provided people used common sense and good personal hygiene and safety practices.” However, 8 months later in its third and final assessment summary, released in August 2006, EPA said that the December 2005 summary indicated no immediate health risk to residents returning for a quick assessment of damage to their homes. The August 2006 summary said that the focus of the analyses of sediments reported on in December 2005 was to assess “(1) whether hazardous substances were present in the sediment in residential areas and (2) the potential health effects to emergency workers and residents from short-term exposure to any hazardous substances found in the sediment.” Because the December 2005 summary did not include this qualification, residents could have misinterpreted it and assumed it was generally safe to return to their homes.

EPA also insufficiently disclosed an important decision it had made about sampling in New Orleans. That is, all sediment samples analyzed were taken outdoors, from streets and other areas of public access in previously flooded residential areas, and samples were not collected from private property, such as residents’ yards or inside residences. Regarding disclosure of this sampling decision, EPA states in its first assessment summary that all of its sampling was conducted “outdoors.” While the subsequent assessment summaries issued in March 2006 and August 2006 provide overviews of the previous assessment summaries, they do not disclose that the assessments did not include sediment samples taken inside buildings or on private property. For example, the March 2006 summary states only that the December 2005 assessment summary was based on the results of “samples from floodwaters and sediments analyzed throughout the flood-impacted areas.”

However, according to EPA officials, in its assessments, the agency assumes that results from sediment samples collected from streets or other public access areas in residential neighborhoods can be used to characterize the degree and nature of contamination in New Orleans, including inside homes and in yards. We believe this assumption is important and warrants highlighting in the EPA environmental assessment summaries for two main reasons. First, environmental contamination levels inside buildings can potentially be significantly higher than and different from the contamination levels outside for a variety of reasons, potentially causing more adverse health effects. For example, contaminants that could have been washed into a building during the flooding–such as petroleum-based products and arsenic–are not dispersed into the atmosphere over time if confined indoors. Moreover, any toxic chemicals or other contaminants already in a building at the time of the flooding–such as pesticides, asbestos, and lead-based paint–may be released inside the building. Finally, after flooding, mold frequently forms and spreads. For example, in the case of the Gulf Coast 2005 hurricanes, the Centers for Disease Control and Prevention (CDC) concluded that the duration and extent of the flooding and the number of structures flooded made massive mold contamination a certainty.[Footnote 48] Along these lines, the Natural Resources Defense Council conducted tests in several mold-contaminated homes in New Orleans and found that mold in one home was at concentrations that would render the building “dangerously uninhabitable”; in three other homes, mold spore concentrations were “dangerously high.” In addition to causing respiratory discomfort, mold also can cause major allergic reactions, asthma attacks, and a pneumonia-like illness (pneumonitis) that causes breathing difficulty and fever. Second, to understand the level of assurance that EPA can provide about the extent to which localized areas of contamination may exist throughout the city, it is important to understand that limiting sediment and soil sampling to outdoor, public access areas can be problematic in that, for example, sediments in streets may be subject to more dispersion than those that settled in more protected areas, such as close to residences.

Further, regarding indoor sampling, in September 2005, EPA’s Science Advisory Board had suggested that EPA consider some indoor sampling in New Orleans, including sampling of surface films on walls and structures, because material deposited outdoors may have been different from material indoors, where the potential for human exposure is likely to be greater. At that time, EPA said that indoor testing of private homes could not be conducted in the initial sampling effort because of worker safety issues and difficult logistical issues–such as obtaining owners’ consent–that could not be quickly resolved. EPA stated the agency would revisit this recommendation as these issues were addressed. To date, while CDC has tested some New Orleans homes for mold contamination, EPA has not tested for contamination inside homes that were flooded as a result of the hurricanes. EPA officials told us the agency has not tested indoors because state and local governments did not request this assistance and because EPA determined that indoor testing was not necessary to characterize the environmental contamination resulting from the storm.

During the time EPA was conducting the sediment sampling program, theagency posted test results on its Web page as the results became available, identifying the general area of the sampling sites on a map of the New Orleans area. Thus, any residents with access to the Internet and with experience in searching and reviewing government Web sites could obtain some information about the environmental contamination in New Orleans prior to the release of the assessment summaries. However, the information about the individual samples on EPA’s Web page is highly technical and would be of limited value to individuals who are not experts in health risk assessment. For example, the Web page provides information on the micrograms per kilogram (µg/kg) of arsenic and benzo(a)pyrene in the sediment at one sampling site. Accompanying text indicates whether the detected levels were above or below the “LDEQ RECAP value” and states that in cases where they exceeded the RECAP value, “the levels fall within EPA’s risk range of 1 in 1,000,000 to 1 in 10,000 risk of an individual developing cancer over a lifetime from exposure to those concentrations in residential soils.” Although we believe that posting data on the individual samples on EPA’s Web site was not a particularly effective tool for communicating information to residents about potential health risks and mitigation strategies, we agree with EPA’s Inspector General that EPA’s posting of information on sediment contamination on its Web page provided timely information to the states and other federal decision makers for use in determining associated risk and impact assessment.[Footnote 49]

Some Information EPA Provided to Residents in Its Public Service Communications Was Unclear and Inconsistent

Although EPA did not perform environmental assessments of any flooded homes in New Orleans, it did provide information to residents based on general knowledge and assumptions about potential environmental health risks inside buildings following disasters. Specifically, EPA relied on flyers, public service announcements, and EPA’s Web site to provide information on the potential health risks in buildings stemming from exposure to, for example, asbestos, lead, and mold–three contaminants that were of concern to EPA and other officials immediately after the hurricanes. While the flyers, public service announcements, and documents on EPA’s hurricane Web page provide information on mitigating exposure to these contaminants, some information lacks clarity and consistency on certain key points.[Footnote 50] For example, EPA’s most widely distributed flyer on environmental health risks–EPA and Louisiana Department of Environmental Quality Warn of Potential Environmental Health Hazards When Returning to Homes and Businesses[Footnote 51]–states that buildings constructed before 1970 are likely to contain asbestos, including pipe and other insulation, ceiling tiles, exterior siding, and roof shingles. In contrast, another document available on EPA’s hurricane Web page, Dealing with Debris and Damaged Buildings, states that all structures built before 1975 may contain significant amounts of asbestos, and structures built after 1975 may also contain asbestos. Further, in developing estimates of the number of homes that may contain asbestos, the Louisiana Department of Environmental Quality included homes built before 1980 as those likely to contain asbestos.[Footnote 52] Accurate and consistent information about the age of buildings that are most likely to contain asbestos is important in helping residents understand what protections they may need when entering and working in their homes.

In addition, EPA’s flyer on potential environmental health hazards recommends seeking assistance from public health authorities and specially trained contractors, if possible, when a resident knows or suspects that asbestos or lead-based paint may be in the home and these materials have been damaged or will be disturbed during cleanup. However, the flyer does not contain the following more strongly worded guidance from the Frequent Questions document on EPA’s hurricane Web page: “Before you begin your cleanup, seek help from public health authorities and specially trained contractors. Although conditions following a hurricane may make it difficult to obtain such assistance, EPA strongly advises against individuals attempting to handle such materials themselves.”

Both the flyer and the Frequent Questions document then list a number of steps individuals should take when handling this debris. However, the information provided on the hurricane Web page regarding respiratory protection that individuals should wear is more clear and useful than the information in the widely distributed flyer on potential environmental health hazards and in the relevant EPA public service announcement. Specifically, the flyer states, “In handling materials that are believed to be contaminated with asbestos or lead, EPA recommends that, at a minimum, you wear gloves, goggles, and most importantly, OSHA-approved respiratory protection, if available.” The public service announcement recommends wearing “gloves, goggles, and a face mask.” The information on EPA’s hurricane Web page, however, is more specific about what respiratory protection is required, where it can be purchased, and the importance of wearing it: “Wear gloves, goggles, pants, shirts, socks, and most importantly, a tightly-fitted N-95 OSHA-approved respiratory mask. A regular ‘dust mask’ is not enough to protect against lead or asbestos. N-95 masks are available at minimal cost at the hardware store. Carefully follow instructions when using a respiratory mask to make sure it fits correctly. A tight fit is important, and despite the heat, it is the best way to protect yourself.”

However, a safety step EPA recommended on its hurricane Web page that many individuals were not likely to have been able to perform was to determine if asbestos-containing products–specifically, asbestos-cement corrugated sheet, asbestos-cement flat sheet, asbestos pipeline wrap, roofing felt, vinyl-asbestos floor tile, asbestos-cement shingle, millboard, asbestos-cement pipe, and vermiculate-attic insulation–were present in their damaged homes. How individuals would determine if these asbestos-containing products were present is not clear, as another EPA document (available on the general EPA Web site but not cited in either the flyer for residents or the Frequent Questions document) states that unless they are labeled, materials containing asbestos cannot be identified by visual inspection. This document further cautions readers to treat the material as if it contained asbestos when in doubt or have it sampled and analyzed by a qualified professional.

Some communications about exposures to mold also were not sufficiently clear or consistent to be helpful to residents whose homes had beenflooded. For example, a flyer distributed to many residents specifically addressing mold is more focused on urging people to clean up than on providing information on how to protect themselves while doing so. The flyer, Cleaning Up After a Flood: Addressing Mold Problems, gives this general safety advice: “Take precautions to limit your exposure to mold and mold spores when attempting to clean up mold. If you have health concerns, you may want to have someone else clean up the mold.” Yet this flyer does not explain what precautions to take. Moreover, the flyer urges residents to act quickly to remove materials contaminated with mold and bacteria, explaining that these contaminants can trigger allergic reactions and induce respiratory infections. For “more specific information on mold,” the flyer refers readers to EPA’s Indoor Air Quality Hotline, EPA and CDC Web sites, and two documents available on EPA’s Web page (one addressing mold in schools and commercial buildings and the other addressing mold in homes). The document that addresses mold in homes includes the following somewhat tentative guidance: “In order to limit your exposure to airborne mold, you may want to wear an N-95 respirator, available at many hardware stores and from companies that advertise on the Internet….” However, other information on EPA’s general Web site that is not specifically cited in the flyer less ambiguously recommends wearing an N-95 respirator. Specifically, Flood Cleanup and the Air in Your Home says to wear an “N-95 respirator” over the mouth and nose to avoid breathing in mold. This publication further explains that a dust mask or handkerchief does not provide protection from mold because it can pass through them. In contrast, EPA’s flyer on potential environmental health hazards advises readers to wear “an N-95 respirator, if available, or a dust mask” when, for example, cleaning significant areas of mold contamination.

Importantly, as of March 2007, none of EPA’s communications, includingits hurricane Web page, were updated to highlight comprehensive information on mold exposure released by CDC on June 9, 2006. Specifically, CDC’s report Mold Prevention Strategies and Possible Health Effects in the Aftermath of Hurricanes and Major Floods includes population-specific recommendations for protection from exposure to mold in buildings after hurricanes and major floods.[Footnote 53] For example, CDC states that healthy individuals do not need to take special precautions for exposure to mold in buildings after hurricanes when they are observing from outside or simply inspecting or assessing damage. However, if healthy individuals are recovering moldy personal belongings (thereby disturbing some dust or mold), CDC recommends that they wear respiratory protection (N-95 filtering face pieces), gloves, and dermal protection. This report also identifies individuals who should avoid specific activities (inspecting, recovering belongings, sweeping, etc.) and specifies the protection they should have to conduct the activities. For example, pregnant women and those over the age of 65 may recover personal belongings wearing respiratory protection, dermal protection, and eye protection but are to avoid any sweeping or cleaning activities. Individuals with “profound immunosuppression”– such as those with HIV infection–are to avoid all exposures, while those with “immunosuppression”–such as those in cancer treatment–or those with lung disease can conduct some specified activities with recommended protective gear.

In addition, some information in EPA’s December 2005 environmental assessment summary was inconsistent. For example, according to the summary, it does not address indoor environmental issues associated with re-entry into flooded homes and structures. However, the following excerpt from the conclusions section of the summary appears to contradict this statement –

Good personal hygiene should be practiced with frequent hand washing,laundering of clothing, and cleaning of the homes (i.e. vacuuming, dusting, etc.) Efforts should be made to avoid tracking sediments into homes from un-vegetated or uncovered areas as well as stirring up dustfrom those same areas. Obvious signs of hazardous material or oil spillage should be avoided and reported, as well.

This guidance does not acknowledge that sediments and contaminants may have been washed into or spilled inside structures as a result of flooding. Thus, the detailed guidance the summary provides for working outdoors, which may also be applicable for working inside homes, is not recommended for working indoors. Specifically, the December assessment summary provides the following “good personal hygiene” guidance for those working with or near exposed sediments outdoors:

* “Wear gloves, boots, and safety glasses.
* Wear a dust mask (an N-95 dust mask is recommended and can be
purchased at your local pharmacy or building supply stores).
* Keep arms and legs covered. Wear long sleeves and long pants.
* Wash hands frequently with soap and water.
* Wash work clothes separate from other laundry.”

In general, EPA’s communications recommend wearing some sort of respiratory protection as a key step in mitigating potential health effects of exposure to sediments and three contaminants–asbestos, lead, and mold–likely to be present in many homes damaged by the 2005 Gulf Coast hurricanes. However, EPA refers to this protection inconsistently and with varying levels of specificity –

* “a face mask”
* “N-95 masks”
* “OSHA-approved respiratory protection”
* “a dust mask (an N-95 dust mask is recommended…)”
* “an N-95 respirator, if available, or a dust mask”; and
* “a tightly fitted N-95 OSHA-approved respiratory mask–a regular ‘dust mask’ is not enough to protect against lead or asbestos.”

These varying terms are confusing and could result in an insufficiently protective choice. For example, “OHSA-approved respiratory protection” is not a common term or household item, and people might not understand what to look for and where to find it. Moreover, the federal agency that approves respirators to protect against a variety of hazards is the National Institute for Occupational Safety and Health (NIOSH). Thus, respirators approved by NIOSH that are available for purchase will be labeled as in compliance with specified NIOSH requirements.[Footnote 54] Further, it is not clear what a “face mask” is, and “dust masks” and “dust respirators” vary widely in terms of the respiratory protection they provide. That is, dust masks can provide some protection to the lungs from the irritating effects of nontoxic dust and airborne particles such as pollen, common household dust, and cut grass, but they are not protective against mold spores or toxic dusts. Given the number and variety of dust masks and respirators that are available and that provide varying levels of protection, EPA’s communications would be more useful if they clearly and consistently named and described the type of respiratory protection the agency is recommending for the specific exposures being addressed.

Conclusions

Working under extraordinary conditions, EPA undertook a broad range of activities to support state and local entities in Louisiana and Mississippi in assessing and minimizing the environmental risks resulting from Hurricane Katrina, including search and rescue efforts that brought 800 New Orleans residents to safety. Because of the breadth and scope of this disaster, cleanup and recovery efforts are still under way in the New Orleans area. For example, many homes have yet to be demolished or substantially renovated. A significant number of them will be demolished or renovated during the next year, and likely these activities will continue for a longer period of time. Given the age of many New Orleans residences, environmental hazards such as asbestos are likely to be present. For the demolitions covered by the no action assurances, in lieu of the requirement for prior identification and removal of regulated asbestos-containing materials, homes that are not inspected before demolition are required to be wetted during the demolition and disposition processes to reduce potential asbestos emissions. However, much of the demolition and renovation activities, including house gutting, will be undertaken by individual homeowners; these activities are not regulated and therefore none of the asbestos control requirements apply. While EPA has taken steps to monitor asbestos concentrations in the air in New Orleans, it is not clear how its approach can accomplish the agency’s stated goal of measuring the effects from both the regulated asbestos-containing material, to which the no action assurances might apply, and the unregulated activities, which would include demolitions and renovations by individual homeowners. To date, according to EPA, the asbestos air data it has collected have not identified potential problems regarding public exposure to asbestos fibers. However, these results may not be representative of asbestos releases to which residents, workers, and volunteers may be exposed in some neighborhoods because of monitoring gaps stemming from monitor locations and the scaling back of monitoring sites a few months after demolitions began. Specifically, without sufficient and targeted asbestos air monitoring data from neighborhoods where demolitions and renovations are concentrated, EPA has limited assurance that the public health is protected from risks associated with inhalation of asbestos fibers potentially stemming from the substantial levels of both regulated and unregulated demolition and renovation activities occurring in concentrated geographic areas.

In addition, EPA could improve the effectiveness of its communications about the potential health risks from exposure to environmental contamination when responding to future disasters. Following a disaster that has involved evacuation, residents are typically anxious to return to their homes, and public leaders are eager to take steps to return to normalcy, including having residents return as soon as it is safe for them to do so. Among the important nformation residents need in order to minimize their environmental health risks when they do return is timely, complete, clear, and consistent guidance about the environmental contamination they may be exposed to, both indoors and outdoors, and how to best protect themselves from it. Without such information, people may return too soon or without the proper protective gear and supplies, which might expose them to both short-term and long-term negative health effects. This could well have been the case in New Orleans since, for example, EPA did not state until August 2006 that its December 2005 assessment summary applied to short-term visits, such as to view the external damage to their homes. This situation was exacerbated by some confusing information EPA provided in public service communications–for example, about the respiratory protection residents should use to mitigate potential exposure to asbestos, lead, and mold in their homes.