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Testimony to the U.S. Environmental Protection Agency on the Miscellaneous Organic Chemical Manufacturing NESHAP Rule

EPA-HQ-OAR-2018-0746; FRL-6494.1-01-OAR

By Stephanie Thomas

The comments below were delivered orally by Dr. Thomas during the EPA’s public hearing on this rulemaking.

February 22, 2022 

Michael Regan, Administrator 

Re: Testimony of Stephanie Thomas, Ph.D., Houston area Researcher and Community Organizer, Public Citizen’s Texas Office to Environmental Protection Agency on the MON Rule. Docket No. EPA-HQ-OAR-2018-0746; FRL-6494.1-01-OAR. 

Good afternoon, my name is Dr. Stephanie Thomas, and I live in Texas. I work as a Houston-based organizer and researcher with Public Citizen, a national public interest organization with about 500,000 members and supporters. We advocate stronger health, safety, and consumer protections, and we appreciate the opportunity to provide testimony. We are also members of the Healthy Port Communities Coalition, a Houston-area coalition that advocates for the wellbeing of communities in and around the Houston Ship Channel, one of the largest industrial hubs in the nation. 

Today I’d like to speak in support of EPA’s proposed reaffirmation of its IRIS cancer risk value. Texas is among the top states in terms of facilities that produce ethylene oxide emissions, including several facilities that exceed the Level of Concern. 

For the last several years, I have worked as an advocate and have listened as community members have shared the pain of losing loved ones to cancer or enduring painful treatments. Furthermore, many of the communities most impacted by harmful pollution like ethylene oxide struggle to find adequate health care coverage. In a place like Texas where our politicians have failed to expand Medicaid, the most vulnerable community members suffer at the expense of corporate profit. 

Children are amongst those vulnerable to the health harms of ethylene oxide. Not far from an ethylene oxide producing facility, children attend school at Groves Middle School and Port Neches Elementary. Every day those children are exposed to pollution that can hurt their respiratory system – and increase their risk of cancer. 

We need EPA’s help to better understand the risks, especially in places like Houston, East Texas, and across the Gulf where there are cumulative impacts from the vast number of facilities exposing community members to pollution.  

Given the unique vulnerability of children to pollution exposure, we need more data to help better understand their risk. We need for the EPA to evaluate the risks to children learning in schools located near facilities. 

We need fence line monitoring. Communities need to know about what they are being exposed to, and in real time.  

We need to ensure that TCEQ is held to account to enforce protective standards.. 

I applaud EPA’s use of the best available science to determine risk. For too long, the state of Texas has sold out its people. We need the EPA’s support to protect Texas’ communities. I thank you for listening today. 


Stephanie Thomas, Ph.D. 

Houston-based Organizer & Researcher 

Public Citizen