PCBs in school — follow up
2023-04-10
Dear friend,
I hope you had a great Easter.
My email to residents about the PCB test results in Twin Valley Elementary School led to correspondence with several residents. Here's a sampling:
"The fact is that TV parents KNOW that PCBs are in the school and that remediation has been recommended by State authorities. I am concerned that H.486 may downplay the health threat of PCBs and, concerningly, will result in discontinuation of state funding for remediation efforts at TV elementary school. It is critical that remediation of PCBs at TV Elementary be funded in large part by the state. One long-term solution to consider may be for the legislature to coordinate with the AG's office to file a lawsuit against Monsanto, the sole source of these harmful chemicals." - A Resident
"I totally agree with you [on H.486]. The State of Vermont’s current position on PCB testing - and level(s) of PCB identified as problematic - are reactionary." - A Resident
Today's email is a followup with more detail on the background of PCBs, why I support a pause in PCB testing in schools, and how that does not affect the deployment of mitigation measures in Twin Valley.
Although their commercial use ended in the U.S. in 1979, we will be reckoning with the legacy of polychlorinated biphenyls, or PCBs, for a long time. PCBs cause cancer in animals and are considered probable human carcinogens by the U.S. Environmental Protection Agency (EPA).
If that wasn’t bad enough, PCBs are oily substances that take a very long time to break down. They are present throughout our environment, and particularly in our waterways.
Avoiding consuming fish from polluted bodies of water has been shown to reduce exposure to PCBs. Another key intervention has been to protect workers handling electronic products like transformers.
The U.S. EPA has focused its efforts in these areas, and has not set an indoor air quality standard for PCBs.
Prior to being banned, PCBs were used in many products, including caulks, fluorescent lighting ballasts, and adhesives. Air-quality testing has revealed that they are present in buildings, including schools. However, PCBs have a low vapor pressure, and evaporate into the air at a low rate. This is in contrast with volatile organic compounds, or VOCs, that are common in products like oil-based paints and in carpeting that give off that “new carpet smell.”
Therefore, airborne levels of PCBs are low in most settings. Where they do appear, increased ventilation and filtering can help reduce those levels.
We do not have any evidence that there are health problems in Vermont’s school-age population or staff that can be attributed to PCB exposure in school buildings.
Out of an abundance of caution, a couple years ago Vermont began a PCB testing program in schools. The state budgeted $4.5 million for testing, $32 million for mitigation and remediation, and $2.5 million for urgent cleanup.
When Vermont started its testing program, we did not have an EPA standard. Vermont determined that harmful air quality levels for PCBs should be based on the following exposure scenario:
– being in a building over 200 days per year
– at 9.5 hours per day
– for 30 years.
If the exposure criteria are met, the data we have suggest that at most there might be 6 in 1 million deaths that are potentially attributed to PCBs.
We can now see that our standard is overly stringent and is leading to unintended consequences. These criteria simply don’t match the typical exposure of Vermont’s 83,000 school-age kids. The test method is similar to looking through the wrong end of a pair of binoculars. We’ll find things, but the proportion of the problems we’re finding is out of scale to the surroundings.
Following testing at the Burlington High School in 2020, the school was closed, and students have been moved into a Macy’s for the last two years. The school is being demolished, and Burlington voters approved a $165 million bond last November for the new school. With the cost of demolition, and fitting out the Macy’s, the overall cost is well over $200 million.
We are also seeing the consequences of this faulty method at the Department of Environmental Conservation (DEC).
The DEC has already asked the Legislature to extend its deadline for school testing by one year, to July 2026. Officials also say the $4.5 million dedicated to the program probably isn’t sufficient. They’re planning to ask the Legislature for more financing in 2024.
Considering the cost of the Burlington High School, that could become a drop in the bucket when looked at statewide.
Is every school district in Vermont prepared to go down this path? Closing and demolishing entire school buildings, is not proportionate to the public health issue, and could have severe unintended consequences for students.
Based on the work of the House Education Committee, the House has now passed H.486 to pause this testing plan, while giving the Department of Health, the Agency of Education, and others until January 2024 to review it.
I support H.486. We can use this brief pause to identify what PCB levels require immediate action and what levels could be addressed with strategic longer-term action.
This is also an opportunity to consider our statewide school facility needs. In 2007, the State of Vermont paused funding for any new school construction. There is now a generation of school buildings in Windham County and across Vermont that are aging and in need of major renovation and replacement. The longer this goes unaddressed, the more our kids will face system-wide and inequitable problems.
I would like to see rural schools like those in Halifax, Wilmington, Whitingham, Readsboro, and Stamford, at the table to be considered for new State funding for construction and renovation of schools.
Demolishing schools like Burlington High School without any statewide look at our facilities only complicates matters.
Those students in Burlington had a vacant downtown building that while not ideal, was available for them to turn to. I’m concerned that this testing program could proceed like a runaway train and take many Vermont schools offline, again without evidence of public health benefit.
The Legislature is working to create a comprehensive School Construction Task Force, at the same time we are now reviewing the initial PCB results.
It only makes sense to do these things together, and I believe that doing so will help all students and all schools across Vermont be able to come to the table equitably.
While the health risk of low levels of airborne PCBs are not well-established, we do know, from COVID, the negative educational and health outcomes of closing schools and limiting school offerings.
Students and teachers already have so much causing them anxiety and fear. H.486 facilitates a mid-course correction that will support the critical mitigation of PCB hot spots, without creating new issues out of proportion to the measurable public health risks.
The mitigation efforts already underway at Twin Valley will continue and will be funded by the existing program, even as we evolve our approach to be more comprehensive.
We need a comprehensive approach because we are living in a chemical world. Asbestos is another substance that has led to major public health concerns and multi-billion-dollar mitigation measures. PFAS, the “forever chemicals,” are another class of toxics that society is trying to mitigate.
PCBs are not unique. There are thousands, and by some measure tens of thousands of chemicals of concern that are common indoors.
Going after one chemical at a time, like the carnival game of “Whack-a-Mole,” is costly, and exhausting. It also doesn’t work.
For example, in consumer products, we’ve seen manufacturers remove Bisphenol-A from baby bottles and food can liners due to concerns about its health effects, only to replace it with Bisphenol-S. The problem with this approach is that the latter chemical isn’t necessarily any safer. It’s only less studied.
In this and other cases, we’ve seen chemicals of known concern replaced with chemicals of unknown concern. This kind of hasty action, dubbed “regrettable substitution,” does not benefit public health. It may only create worse problems and increased costs down the road.
I urge the Senate to support H.486 as a considered, comprehensive approach to keeping our schools open and healthy.
Attorney General Charity Clark has not stated whether she will sue Monsanto as a state, but I know it's on her radar.
To families and staff members currently affected by PCB test results – the pause for future PCB testing on schools does not affect the tests already completed, and does not affect the mitigation measures that are already going in place.
Questions? Comments? I appreciate hearing from you.
And if you support H.486, or don't, your Senators will also appreciate hearing from you as well, at 802-828-2228.