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Ethylene Oxide (EtO)

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1. Does this cause respiratory problems and shortness of breath, along with fatigue?

Based on available data, EPA does not expect EtO levels in the outdoor air around facilities like Sterilization Services of Tennessee to be high enough to cause immediate health effects (these are known as "acute” effects).  Short-term inhalation exposure to high amounts of EtO can cause headache, dizziness, nausea, fatigue, respiratory irritation (such as coughing, shortness of breath, wheezing) and, in some cases, vomiting and other types of gastrointestinal distress. Those effects do not usually occur with exposure to “fugitive emissions,” the amounts that typically escape facilities like Sterilization Services of Tennessee. 

2. Is it possible that there were residents who had moved away from the area who might have cancer, but were not included in the study?

Yes, it is possible. Tennessee Cancer Registry data is linked to the address where a cancer patient resided at the time of diagnosis. If the patient moved away from the risk area before diagnosis, they would not be geographically linked to the area surrounding Sterilization Services of Tennessee.

3. Are people with lead exposure more vulnerable? Many homes have lead water lines. Over 90% of children tested for lead in this area.

There is no evidence that exposure to lead or other chemicals makes individuals more vulnerable to ethylene oxide. EtO is carcinogenic to humans by inhalation (when breathed in air). EtO is not believed to be absorbed readily by water and soil. However, lead does linger in water and soil. Children whose brains and nervous systems are still developing are most vulnerable to lead exposure. Shelby County Health Department’s Childhood Lead Poisoning Prevention Program provides services to the community to increase awareness of the hazards of lead exposure, reduce lead exposure, and increase the number of children screened and tested for lead poisoning. If you have concerns about lead exposure in your home or environment, contact the Childhood Lead Poisoning Prevention Program at 901-222-9582. 

4. Is there a reason that throat cancer, aneurysms and other cancers are not included in this study?

Scientific evidence in humans indicates that regular exposure to EtO over many years increases the risk of cancers of the white blood cells, including non-Hodgkin lymphoma, myeloma, and lymphocytic leukemia. Studies also show that long-term exposure to EtO increases the risk of breast cancer in women. There is not strong evidence to link EtO exposure to other types of cancer.

5. The former Trump Administration rolled back many EPA regulations. Can we ever be safe again?

The Biden Administration recently signed an executive order to further embed environmental justice into the work of all federal environmental agencies, bring clean energy and healthy environments to all, and recognize, undo, and mitigate harm to those who have suffered from toxic pollution and other environmental burdens like climate change. The Biden Administration has also established a White House Environmental Justice Advisory Council to ensure that environmental injustices and inequities in communities like South Memphis are addressed. 

 

6. When did these gas emission results cause the EPA to become involved at this late date? The owners should have done their extensive study prior to establishing this hazardous source in our community.

When the Sterilization Services of Tennessee facility began using EtO decades ago, the health risks posed by EtO exposure were not well understood. As more studies were done and data became available, EPA began the process of updating regulations regarding EtO. This process began in 2022 and the proposed revised regulations were released by EPA on April 11, 2023. 

7. Will the Health Department do any testing on individuals for potential cancer of any kind?

SCHD refers residents to cancer screening programs such as the Tennessee Breast and Cervical Screening Program and federally qualified health centers that provide care on a sliding fee scale. 

8. Has Sterilization Services said they would lower their Ethylene Oxide emissions?

No, the company has not committed to taking any action before the revised EPA standards go into effect in 18 months.

9. Why hasn’t our Health Department used their authority to force Sterilization Services to reduce Ethylene Oide emissions? Our Health Department has the authority by law to do this.

Sterilization Services of Tennessee complies with all current federal, state, and local regulations. The Clean Air Act does not currently allow Sterilization Services of Tennessee to be held to legal standards higher than existing ones. The EPA is now in the process of updating Clean Air Act regulations to reduce allowable EtO emissions to better protect communities like South Memphis. As required by law, SCHD will ensure that the revised federal regulations regarding EtO are enforced as quickly as possible in Shelby County. 

10. What actions are being taken against the Sterilization company? These types of companies should be in remote areas.

As required by law, SCHD will ensure that the revised federal regulations regarding EtO are enforced as quickly as possible in Shelby County. 

11. Why are these meetings held so far away from the communities affected? This church is 3.3 miles away from the facility. What about folks without transportation?

Shelby County Health Department was unable to find a location within the risk area that provided the necessary space and the audio/visual capabilities required to hold a hybrid live/virtual meeting. 

12. Is there a lawsuit in the making for this matter because I hurt every day?

Shelby County Health Department has no information about any pending lawsuits regarding EtO.

13. When should the resident of 38109 expect any of these pending cancer-causing studies to be completed? What other actions in our regard should be taken?

The cancer cluster study requested by Shelby County Health Department has been completed. SCHD has also requested a Public Health Assessment (PHA) and a Health Consultation (HC) from the federal Agency for Toxic Substances and Disease Registry (ATSDR) to identify health risks related the usage of Ethylene Oxide (EtO) and other chemicals in the area surrounding the Sterilization Services facility. Those studies have not yet begun. 

14. What should you do if you have been diagnosed with cancer?

Those diagnosed with cancer should comply with all their physician’s recommended treatment guidelines. 

15. What should you do if you have cancer and do not have insurance for treatment?

A federally funded program called the Tennessee Breast and Cervical Screening Program provides screenings, diagnostic and other procedures for under-insured and uninsured Tennessee residents specifically for breast and cervical cancers. Federally qualified health centers provide recommended screenings and treatment options for other cancers. 

16. What can the Health Department do to provide access to care to those in the affected area?

The Health Department does not provide primary health care, however, we strongly encourage that everyone have a primary care provider who manages their health care. A primary care provider can recommend appropriate cancer screenings for persons exposed to EtO. Un- and under-insured persons can receive affordable health care at Federally Qualified Health Centers (FQHCs). To find an FQHC near you, go to https://findahealthcenter.hrsa.gov/ and enter your address. There are 23 FQHCs in and near Memphis, TN. 

17. How long does it take for EPA’s proposed rule to become final and how long will facility have to comply? Will Sterilization Services consider making voluntary changes after the rule is published?

Under the proposal, facilities would be required to comply with these new requirements within 18 months. This represents an expedited timeline under EPA authority. The Sterilization Services of Tennessee management has not indicated it will make any voluntary changes in emissions before the new requirements go into effect 18 months from now. 
 

18. Why does the Health Department not shut the facility down as a

Sterilization Services of Tennessee complies with all current federal, state, and local regulations. The Clean Air Act does not currently allow Sterilization Services of Tennessee to be held to legal standards higher than existing ones. The EPA is now in the process of updating Clean Air Act regulations to reduce allowable EtO emissions to better protect communities like South Memphis. As required by law, SCHD will ensure that the revised federal regulations regarding EtO are enforced as quickly as possible in Shelby County. 

19. What are the individual services at the Shelby County Health Department?

Shelby County Health Department offers cancer screening programs  for uninsured and underinsured individuals.

We work in conjunction with hospital systems, health care providers, and community organizations to make health screenings and preventive care available throughout the community.

 

20. What are ways that the Shelby County Health Department can be more trustworthy to the community?

The Shelby County Health Department is a division of Shelby County Government. We work for the people and answer to the representatives of the people, the elected Mayor and Commissioners of Shelby County. We strive to be responsive and accountable to the community at all times. 

21. When did EPA last review this and change emission standards?

The standard for EtO has not been changed since it was established in the 1970s.

22. What makes people more vulnerable to cancer from EtO?

EtO is a human carcinogen. It causes cancer in humans. Scientific evidence in humans indicates that regular exposure to EtO over many years increases the risk of cancers of the white blood cells, including non-Hodgkin lymphoma, myeloma, and lymphocytic leukemia. Studies also show that long-term exposure to EtO increases the risk of breast cancer in women.

Workers who use EtO as a part of their jobs and people who work, live, or go to school or daycare near facilities that use EtO may breathe in EtO at levels that can increase cancer risk. This risk is not the same for everyone and depends on how long a person is exposed over the course of their lifetime or career, as well as how much EtO is actually in the air. The distance from a facility or other EtO source plays a big role in how much EtO might be in the air.

Because children’s bodies are growing, they are expected to be more susceptible to the toxic effects caused by EtO. This is because EtO is mutagenic, meaning it can damage DNA. As children grow, they tend to be more susceptible to the harmful effects caused by chemicals, including chemicals that are mutagenic. For anyone, including children, risks would decrease with decreased exposure.

23. Does the lack of evidence of cancer clusters mean there is no elevated risk of cancer?

No.  Cluster studies are done to combine the science of what is known about cancer with geographic analysis – proximity to the facility within constraints.

24. Instead of conducting a cancer incidence study, why not test Ethylene Oxide levels in the air?

Shelby County Health Department cannot place an air monitoring station on our own without the permission of the EPA.

Ethylene oxide is hard to measure; very heavy gas emitted; immediately falls to the ground and is difficult to test for.

25. What has Sterilization Services said they would do?

The Sterilization Services has not issued any statements about their plans for the Memphis facility.

26. Would it not be better to move the sterilization plant to another area as a preventative measure for the safety of the neighborhood?

The Shelby County Health Department's authority is limited, but specific. SCHD cannot ask this industry to move somewhere else. The industry is not only regulated by the Shelby County Health Department, but also Codes Enforcement, Zoning, etc. The facility meets the current EPA standard, meaning that the operation meets the local, state, and federal compliance regulations. Local, state, and federal authorities cannot hold the facility to a higher standard than the current law allows.