Nonprofit sign-on letter to EPA administrator Lisa Jackson
Published: March 30, 2009

Intro/Letter excerpt:  (from http://www.earthworksaction.org/library/detail/hydrogen_sulfide_needs_hazardous_air_pollutant_listing_under_caa_title_iii)

The community, environmental, and public health organizations named below request that you formally list Hydrogen Sulfide (H2S) as a hazardous air pollutant (HAP), as defined in Title III, section 112(b) of the 1990 Clean Air Act Amendments (CAA). We assert that EPA must act to address adverse H2S impacts based on evidence of harmful exposures in numerous communities and its toxicological effects at low concentrations such as non-cancer effects and emerging evidence that H2S is a genotoxic agent, meaning it damages DNA. EPA has assessed the need to list H2S as a HAP, but no formal listing action has been taken. H2S is clearly an unlisted hazardous air pollutant.

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(Full letter can be viewed at: http://www.earthworksaction.org/files/publications/H2SLetterToEPA.pdf)
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Conclusion  

Public health scientists have recognized for over a decade that hydrogen sulfide is a potent neurotoxin, and chronic
exposure to low ambient levels causes irreversible damage to the brain and central nervous system. Ultra-low levels
of H2S down to 25 ppb have been associated with acute exposure causing eye irritation in community settings in the
United States, Europe and New Zealand. Now emerging scientific evidence supports H2S causes neuron death,
confirming findings by Kilburn of irreversible brain damage. The latest scientific findings suggest H2S causes DNA
damage as a genotoxic agent, which EPA can no longer ignore. The potential carcinogenic implications of H2S
demand that EPA act to protect public health.

Children are among the most susceptible to this poison gas, and EPA needs to do a more effective job of protecting
schoolchildren from H2S impacts. Today, it is unacceptable for communities to have to continue suffering the ill
effects of H2S when the technology to monitor and control H2S emissions exists. As EPA has learned in the last four
decades, environmental injustice is a significant fact of life for thousands of communities in this nation and these
residents all have a right to clean, safe air.

It’s time for the EPA to take action to formally acknowledge hydrogen sulfide’s clear toxicity at low concentrations.
As Administrator, you have CAA authority under section 112(b)(2) to act based on a pollutant that poses or may
pose “…a threat of adverse human health effects…” Health studies confirm the need for EPA to list H2S under
section 112(b) of the CAA and Title III, since routine daily exposure effects are not addressed under the accidental
release provisions in section 112(r) of the CAA, where H2S is currently regulated. However, section 112(r) is not
designed or intended to address daily exposures at sublethal concentrations, but section 112(b) can bridge this gap.

EPA, in addition, needs to require annual reporting of H2S as a toxic substance under the Toxic Release Inventory
(TRI) reporting program, since H2S is not reported due to an administrative stay issued August 22, 1994 evidently
under a legal threat by the American Petroleum Institute. It’s extraordinary that industry has delayed reporting of
H2S for twenty years. EPA needs a TRI reporting threshold of 1.0 pound for H2S and not 10,000 pounds as was
originally the requirement. We request that EPA immediately lift the administrative stay on H2S and require TRI
reporting in the next TRI submission cycle. The TRI data would also help EPA compile more accurate H2S data.

Please respond to this request for EPA to take action to list H2S under section 112(b) of the CAA. Address the
EPA’s response to Neil Carman at the contact information listed below.

Respectfully yours,

Neil J. Carman, Ph.D.
Sierra Club’s Clean Air Team and the
Lone Start Chapter of the Sierra Club
1202 San Antonio St, Austin, TX 78701
Tel 512-472-1767; Fax 512-477-8526

(This letter was also sent/signed by the following organizations:   National Environmental Justice and Community Partnerships Director; Citizens for Environmental Justice; Community In-Powerment and Development Association; Earthjustice Legal Defense Fund; Environmental Integrity Project; Galveston Houston Association for Smog Prevention & Mothers for Clean Air; Global Community Monitor, National Refinery Reform Campaign & National Bucket Brigade Coalition; Downwinders At Risk; Groups Allied to Stop Pollution; The People’s Advocate; Lower Mississippi Riverkeeper; Louisiana Environmental Action Network; EARTHWORKS’, and Oil & Gas Accountability Project; San Juan Citizens Alliance; Sustainable Energy & Economic Development Coalition; Citizens Against Environmental Destruction; Northeast Ohio Gas Accountability Project; Huron Environmental Activist League; Don’t Waste Arizona; Cook Inletkeeper; Protect All Children’s Environment.)