The government agencies that should be protecting a South Memphis neighborhood from cancer-causing air pollution have fallen down on the job, environmental justice advocates say, so they’re stepping up.
At Shady Grove Missionary Baptist Church church in Mallory Heights on Saturday, community organizers with Memphis Community Against Pollution and the Mallory Heights CDC alerted South Memphis residents to the colorless, odorless gas that’s poisoned the area for decades, letting them know what they could do to change that.
The gas comes from a facility two miles away. Sterilization Services of Tennessee at 2396 Florida Street uses ethylene oxide, also known as EtO, to remove bacteria from medical and dental equipment, which decreases the risks of infections in hospitals and clinics.
But breathing in the chemical over many years, the Environmental Protection Agency now says, can cause illnesses such as leukemia, non-Hodgkin’s lymphoma, and stomach and breast cancers.
Community Meetings
Where: Bloomfield Baptist Church, 123 S Parkway West and virtually. Register online here for virtual attendance.
When: Thursday, June 8 at 10 a.m. and 7 p.m.
Quick Facts
- Sterilization Services of Tennessee (SST) on 2396 Florida Street emits a carcinogen called Ethylene Oxide (EtO).
- EtO can cause illnesses like Leukemia, non-hodgkin Lymphoma, and stomach and breast cancers if inhaled over several years.
- The EPA is proposing new regulations to significantly reduce emissions, but it could take as long as three years for facilities to comply.
- Community organizers are asking community members to submit public comments and ask for a faster compliance period.
- People can submit their written public comments online through a form here or by email: https://www.epa.gov/hazardous-air-pollutants-ethylene-oxide
- People can mail public comment to the address: U.S. Environmental Protection Agency, EPA Docket Center, Docket ID No. EPA–HQ–OAR–2019–0178, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
- Find tips for effective public comments here. If you would like support on public comment, email: info@memphiscap.org.
And the SST facility operates 24 hours a day, seven days a week.
MCAP’s president, Keshaun Pearson, calls the inaction from local leadership inhumane and reflective of racist policies that have plagued his family and community for generations – dating back to the Reconstruction era.
“They continue to slow lynch this community. This is intentional. This is directed at a specific demographic,” said Pearson.
While the EPA has known EtO is a hazardous air pollutant for at least 30 years, scientists and analysts only recently started taking steps to address the carcinogen. The action comes after the agency discovered that EtO has a cancer-causing risk 60 times higher than previously known.
In response, the EPA proposed new regulations requiring facilities such as SST to reduce emissions by 80%. Before the regulations become the new standard, the public can submit comments by June 27. But the standards are in a dense, jargon-laden 68-page packet with 380 supporting documents.
So, MCAP and Mallory Heights CDC — with some of the same players who stopped the Byhalia Pipeline in 2021 — are organizing in-person and virtual meetings to help people in South Memphis understand the proposed new rules.
“We deserve clean air just like everybody else,” said Pearson.
A chance to submit concerns and questions
Eighty-six commercial sterilization facilities operate across the United States, many of which are in communities that were once redlined and now experience environmental injustice. The EPA determined that 23 of those facilities pose elevated lifetime cancer risks – including SST in South Memphis, an area riddled with various industrial facilities and their pollutants.
At the direction of the EPA, the Shelby County Health Department notified an undisclosed number of residents and held one informational meeting, but MCAP is doubling down on the health department’s work. In addition to holding multiple community meetings, the organization sent 11,000 mailers last week to people in the area, encouraging them to submit their concerns and questions.
MCAP is urging people to tell the EPA that it needs a shorter compliance period when new regulations go into place. It’s something the regional EPA air and radiation division director, Caroline Freeman, has emphasized herself because that kind of feedback from people in Memphis can directly influence the agency.
As the EPA’s timeline stands, once this round of public comment closes and the rules are finalized, it could take up to three years for facilities like SST to comply with the new standards. Those standards would update the Clean Air Act to require commercial sterilizers to use technologies and procedures proven to reduce EtO emissions. Concerns raised through public comment could require SST to act sooner to reduce their emissions under such rules.
“I need you to hear me on this,” Freeman said in October during the EPA’s first public meeting in Memphis. “EPA does plan to solicit comments on a shorter compliance time period. So that is why it’s critical you are aware that these rules are coming forward.”
So far, more than 25,000 comments have been submitted.
The EPA is especially concerned about SST’s emissions because a high concentration of the chemical has been released for a long duration. SST has been operating since 1976.
EtO contributes to nearly 82% of overall cancer risk in the census tract where the SST facility is located, according to the Union of Concerned Scientists. That level of EtO exposure could mean an increase of 20 cancer cases per 10,000 people exposed for 70 years.
Wind carries EtO, which can stay in the air for up to three months. In Memphis, it can loft over hundreds of homes in a ring of emissions that emanates from the facility. The chemical especially poses risks for children and babies. Their growing bodies make them more susceptible because EtO can mutate and damage DNA.
But because air filtration systems and N-95 masks do not prevent EtO inhalation, people can’t protect themselves or their families from this chemical.
Can the health department ‘do better’?
While zoned industrial in the corner of an I-55 interchange, SST is not an isolated facility. It sits within five miles of more than 130,000 people and about 180 schools and childcare centers, according to the Union of Concerned Scientists report. The community in that same area, it says, is 87% people of color and 57% low income, both percentages that are 20% greater than the county average.
“I’m here because you’re here, and you’re in danger. This is just unacceptable that our health department has failed us and that this company hasn’t jumped into action.”
U.S. Rep. Steve Cohen
About 86% of the EtO emissions coming from SST do not go through a device that breaks down the chemical before it is released into the environment, according to the EPA. In an SST sterilization chamber and aeration room, EtO is dispersed over the medical supplies where the control captures and cleans EtO from the air.
But rather than getting sucked into this cleansing technology, EtO escapes through what the EPA calls fugitive emissions. That means the emissions are possibly emanating through leaks, ventilation, gaps in windows and through open doors. As Freeman said, fugitive emissions are “unfortunately” not covered under current regulations.
But the Southern Environmental Law Center, which represents MCAP, claims the facility isn’t in compliance with current EtO federal regulations. The Tennessee Department of Environment and Conservation delegated authority to Shelby County Health Department to administer an air pollution control program.
SELC filed a petition with the Shelby County Health Department, asking it to issue an enforcement provision that allows the health department director to issue emergency air pollution orders, which would address EtO emissions faster than the EPA. In a written statement, the department denied the petition, citing that SST is meeting local standards.
However, under municipal code, an air pollution emergency episode can be declared “during adverse air dispersion conditions that may result in harm to public health or welfare.” Since the Memphis facility is among the most high-risk, and with an improved understanding on the chemical’s harmful impact, SELC and MCAP believe it is within reason for the director to exercise this power. They filed an appeal, asserting that leaders are refusing to act. A hearing is scheduled in August.
“This facility has known for many years that its pollution is harming people in the community. When you know better, you do better, and we’re not seeing that from the facility. We’re not seeing that from the health department,” said Amanda Garcia, Tennessee office director for SELC.
Sterilization Services has voluntarily reduced EtO at its facilities in other states, but not at its Memphis plant, according to Garcia’s office. SST did not respond to emails requesting comment.
The SCHD was noticeably absent at MCAP’s community meeting on Saturday. U.S Rep. Steve Cohen and staff from the office of city council member Edmund Ford, Sr., both of whom represent the district, attended.
“I’m here because you’re here, and you’re in danger,” said Cohen. “This is just unacceptable that our health department has failed us and that this company hasn’t jumped into action.”
Absent data, but some lived experiences
Over the weekend, community organizers convened residents who live near SST in preparation for two EPA meetings on Thursday. Pearson took issue with a March SCHD meeting, in which he and others felt SCHD leaders failed to hold SST accountable for polluting the neighborhood.
“They offered us cards for our comments, and to have our questions listened to, and if you were at that meeting, it didn’t quite go that way. They answered the questions that supported the talking points they already had, and that’s just not fair,” Pearson said.
At that meeting, the SCHD presented a study that did not find evidence of increased cancer rates near SST.
But because of other variables such as genetics and socioeconomics, proving environmental causes of cancer is challenging and establishing a link through statistical analysis is unlikely – facts that the health department stressed in its presentation. In fact, when SCHD director Michelle Taylor shared the results, she reminded audience members that the lack of evidence does not diminish the EPA’s EtO warning.
Researchers unaffiliated with government agencies or community organizations have been critical of methodologies used for other local EtO studies – such as an air pollution analysis commissioned by Memphis Mayor Jim Strickland in July 2022. Since there are no government-sanctioned air monitors in South Memphis, the researchers hired by the city set up a temporary sampling site.
The researchers said that over four days of monitoring, EtO, was not detected – a finding that comes with many shortcomings, according to researcher Richard Peltier at Institute for Global Health, an interdisciplinary program out of the University of Massachusetts. At the SELC’s request, he reviewed the measurement techniques and argued that it is difficult to draw conclusions through just 62 hours of sampling with variable wind directions. “The City of Memphis study,” he wrote, “does not provide useful information about ambient concentrations of ethylene oxide in the community.”
Over the last 10 years, study after study has shown that South Memphis disproportionally experiences air pollution with alarming health risks. But community members don’t need the data because they say they are watching it happen to their loved ones.
By combining their lived experiences with new science from the EPA, Pearson believes his communities can push government agencies to reduce EtO and cancer risks quicker than what is currently being proposed.
“…I am so glad my home is in South Memphis, where people continue to fight, and we’ve been fighting a long time,” said Pearson.
Ashli Blow is a freelance writer who covers environmental science and policy. Her stories range from the lives of people in urban watersheds to those who roam the wilderness. She was raised in Memphis and produced breaking news at WMC Action News 5. She has now been working in journalism and strategic communications for nearly 10 years. Ashli lives in Seattle and is a graduate student at the University of Washington, studying climate policy.
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