PUBLIC HEALTH ASSESSMENT
NEW BEDFORD SITE APPENDICES
NEW BEDFORD, BRISTOL COUNTY, MASSACHUSETTS
APPENDIX 1
Figures
APPENDIX 2
Figure 1. Achusnet River Estuary and
Hot Spot Areas
Figure 2. New Bedford Harbor and
Surrounding Areas
Figure 3. New Bedford Harbor
Fishing Closure Areas
Figure 4. Schematic of Harbor Waters
The following tables were not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:
Agency for Toxic Substances and Disease Registry APPENDIX 3
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
New Bedford Liver, Leukemia, and Bladder Cancer Incidence
(1982-1986)
The following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:
Agency for Toxic Substances and Disease Registry APPENDIX 4
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
Evaluation of the Prevalence of Lead Poisoning in New Bedford, MA
1990-1992
With the exception of the figures below, the following section was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services
Branch, E-56
1600 Clifton Road NE, Atlanta, Georgia 30333
Figure 2. Distribution of Children by Lead Level
New Bedford, MA
Figure 3. New Bedford Census Tracts
Map 1. 1990-1992 Elevated Lead Levels
by Census Tract Among New Bedford Children
Ages 9 months - 4 years
Map 2. 1990-1992 Lead Levels 20+ ug/dl
by Census Tract Among New Bedford Children
Ages 9 months - 4 years
Map 3. 1990-1992 Lead Levels 15-19 ug/dl
by Census Tract Among New Bedford Children
Ages 9 months - 4 years
Map 4. 1990-1992 Lead Levels 10-14 ug/dl
by Census Tract Among New Bedford Children
Ages 9 months - 4 years
Map 5. 1990-1992 Lead Levels 5-9 ug/dl
by Census Tract Among New Bedford Children
Ages 9 months - 4 years
APPENDIX 5
Map 6. 1990-1992 Lead Levels 1-4 ug/dl
by Census Tract Among New Bedford Children
Ages 9 months - 4 years
Summary of Written Correspondence
Received during the Public Comment Period
New Bedford Harbor
Public Comment
| Name and Address |
Information |
Comment |
| Ms. Patricia Fowle Health Agent Fairhaven Board of Health Town Hall 40 Centre Street, Fairhaven , MA 02719 |
X | |
| Ms. Gayle Garman Remedial Project Manager Massachusetts II Superfund Section U.S. Environmental Protection Agency J.F. Kennedy Federal Building Boston, MA 02203-2211 |
X | |
| Ms. Helen Waldorf, Deputy Division Director Federal Sites Division Bureau of Waste Site Clean-Up Massachusetts Dept of Environmental Protection One Winter Street Boston, MA 02108 |
X | |
| Mr. Raymond Belanger Director, City of New Bedford Department of Public Health, 181 Hillman Street, New BedfXord, MA 02740-4347 |
X | |
| MaryBeth Smuts, Ph.D. Regional Toxicologist Toxics and Radiation Section, U.S. Environmental Protection Agency, J. F. Kennedy Federal Building Boston, MA 02203-2211 |
X | |
| Ms. Susan Smith Hazardous Waste Treatment Council 915 15th Street, 5th Floor, Washington, D.C. 20005 |
X X |
|
| Mr. Thomas Abdella Perland Environmental Inc. Burlington, MA |
X X |
|
| Mr. David Hammond Hands Across the River, Fairhaven, MA 02719 |
X X |
|
| Ms. Kate Hickman Southeastern Massachusetts Univ. Dartmouth, MA |
X X | |
| Allison Taylor, Ph.D. Research Professor Department of Environmental Health Harvard School of Public Health, 665 Huntington Avenue, Boston, MA 02115 |
X X | |
| Mr. Daniel Ring Reporter, Ottaway News Service |
X X | |
| Ms. Amanda Martinez United Way of Greater New Bedford, P.O. Box 7823, New Bedford, MA 02742 |
X X |
APPENDIX 6
Responsiveness Summary
SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
This responsiveness summary addresses comments that were received by MDPH or ATSDR during the public comment period for the New Bedford Harbor NPL site. This period was from October 9, 1993 to November 8, 1993. The Agency received written commentary from the United States Environmental Protection Agency (USEPA), the Massachusetts Department of Environmental Protection (MDEP), and the Health Officers for the city of New Bedford and the town of Fairhaven. Written commentary is addressed in the following section.
COMMENTS FROM MDEP:
MDEP was mainly concerned with the lack of current information in the document regarding incinerator lead removal efficiency from the emitted airstream and failure to consider exposure to PCBs volatilized during daily low tide conditions as well as PCBs made airborne during the dredging process. These concerns are reiterated throughout their letter of commentary to MDPH dated October 19, 1993.
COMMENT 1: MDEP believed that the statement in the sixth paragraph of the executive summary regarding the uncertainties of lead exposure based on emissions migration modelling should be removed. MDEP contends that since the model was based on conservative assumptions, the resultant lead emissions levels that the incinerator needed to achieve during the trial burn was protective of human health.
Response: MDPH/ATSDR retained the statement. Any estimation of lead exposure based on modelling results will have inherent uncertainties. While ambient air lead monitoring during the incineration process may also present some uncertainties with respect to the source of any observed transient elevation of ambient air lead level, MDPH believes that an air lead monitoring program would be of particular importance in relation to any remediation considered for the area where lead may be released. This is because results from an ongoing surveillance of statewide childhood lead poisoning prevalence rates indicates that the rate for the city of New Bedford far exceeds that observed in the Commonwealth as a whole. We have also investigated in greater detail where the areas of high childhood lead poisoning prevalence are in New Bedford. This report which appears in appendix 4 reports that the highest areas in New Bedford of childhood lead poisoning prevalence are in close proximity to the proposed incinerator site. We have amended our recommendation regarding ambient air lead monitoring to reflect its inherent uncertainties regarding interpretation of results while maintaining the need for such data in areas where sensitive receptor populations exist.
COMMENT 2: MDEP believes that exposures and risk associated with inhalation of PCBs in ambient air needs mentioning in the summary.
Response: MDPH has added information in the summary that addresses these issues.
COMMENT 3: MDEP believes that in the description of PCBs, it should be noted that the constituent two carbon rings are aromatic.
Response: MDPH believes that this language is too technical in nature and could be misconstrued to mean that the PCBs have a distinctive odor. As a result this term was not included in the description of PCBs.
COMMENTS 4-7: These comments suggest a more detailed description of the site layout.
Response: MDPH appreciates these suggestions and they were incorporated into the document.
COMMENT 8: Ambient air PCBs levels are indicated in the text of the Environmental Contamination section of the document. MDEP believes that the state standard for ambient air PCB levels should be included in the text as well.
Response: Comparison values are not routinely included in the text of the document but are indicated in the tables presenting the environmental contamination detected on or near the site.
COMMENT 9: MDEP concurs that the security at the Aerovox plant could be improved, however since there is a fence between the plant grounds and the bluff, the risks from falling from the bluff at the factory grounds are overstated.
Response: MDPH has changed the wording of the passage to indicate that the security at the site could be improved and has reassessed the specific risks at the harbor waters near the plant after considering the presence of the plant fence.
COMMENT 10: MDEP believes that the photolysis of PCBs in the harbor waters and sediment producing dioxins and furans under anaerobic conditions will not occur, therefore discussion of this process is not appropriate.
Response: This reaction does occur under some environmental conditions and it is possible that to a small extent these conditions may exist in the harbor and estuary; therefore for the sake of completeness this process is mentioned. MDPH does state in the sentence immediately after the description of the process that it is not expected that the process will have a significant impact on contamination levels in the harbor.
COMMENT 11: In reference to the MDPHs reporting of the percentage of the greater New Bedford population who consume locally caught fish, MDEP comments that the sum of the presented percentages do not equal 100.
Response: The remainder of the individuals surveyed for source of locally caught fish in the Greater New Bedford PCB Health Effects Study did not fall into the categories of consumed no locally caught fish or consume fish locally caught by themselves, friends or relatives. These individuals responded as follows: fish retailers (10.9%), supermarkets (2.5%), restaurants (2.4%), local fisherman (0.8%), and don't know (6.4%). For clarity of comparison, only the percentages of those individuals who definitely consumed fish caught from restricted waters and those who consumed no local fish were presented.
COMMENTS 12-15, 18-21, 24, 26: These comments provided by MDEP updated specifications of the remedial plan as it was designed when the Public Health Assessment was released for public comment.
Response: MDPH appreciates this information and has updated the document accordingly.
COMMENTS 16 and 17: MDEP suggest changes in the wording of the selected remediation.
Response: MDPH believes that the suggested wording is too technical in nature for the document, therefore the original wording will be retained.
COMMENTS 22: MDEP disagrees with the statement that the release of metals (especially lead) through the waste stream poses the greatest health concern from the hot-spot remediation.
They believe that the potential exposure to PCBs made airborne during the dredging process poses a greater health concern.
Response: While MDPH appreciates the concern of exposure to airborne PCBs, we have also identified a sensitive receptor population, specifically young children living in close proximity of the proposed incinerator site in whom an increased risk of lead poisoning was observed (Please see appendix 4.). Although the extent of lead exposure (if any) from the incinerator is not known, the possibility of such an exposure in an area where lead poisoning is already occurring warrants concern. The document has also been updated to reflect the possibility of exposure to airborne PCBs during the dredging process. We believe, however, that since the exposure during the remedial process is not expected to be chronic, we do not anticipate a measurable impact on the cancer rates in the areas near where the dredging and storage of contaminated sediments will occur. On the other hand, significant short term lead exposure to children can result in irreversible health effects.
COMMENT 23: MDEP believes that reporting of past investigations of incinerator lead removal efficiency is unnecessary when such data for the incinerator that will actually be used for the remediation are available. MDEP believes that these numbers should be included in the report.
Response: An investigation reporting the partitioning of lead in the waste stream of an
incinerator without an Air Pollution Control Devise (APCD) was incorporated into the document
in order to describe the flow of lead contamination in the incineration process and the percentage
of lead fed into the incinerator needed to be removed by the (APCD). The lead removal
efficiency data provided to MDPH are incorporated into this revision of the document.
COMMENT 25: MDEP questions the statement in the public release revision of the document pertaining to the ineffectiveness of concrete stabilization of incinerator ashes.
Response: The summary of an investigation reporting that over time the stabilization matrix breaks down was reviewed and incorporated into the document. The public health assessment accurately communicates the effects of such breakdown by reporting that migration of contamination bound to broken down stabilization material will not occur since the complex will be contained in the lined Confined Disposal Facility.
COMMENT 27: MDEP believes that the statement in the document that emissions will travel a significantly shorter distance on rainy days is inaccurate and that high wind speeds on such days may carry emissions a greater distance.
Response: MDPH agrees with MDEP in that the precipitation on those days will remove particulates from the atmosphere causing shorter emissions travel. Since the intent of the statement was to illustrate that modelling of emissions migration is dependent on some parameters that can not be predicted well beforehand such as the weather, MDPH believes the statement should be retained.
COMMENT 28: Since the contents of fly ash will be determined, MDEP believes that the statement that if fly ash contents are not known or are not considered, the modelling results will be compromised should be eliminated.
Response: MDPH believes the original statement to be factual and should be retained. We have, however, amended the language to indicate that the lead content in the fly ash will be determined and this result should be considered when developing models of emissions plume behavior.
COMMENT 29: MDEP believes that the statement that lead emissions from the incinerator may settle in nearby waters contaminating the food chain should be eliminated since any contamination of the food chain via this route will be minimal.
Response: MDPH agrees that if the APCD is operating according to specifications, the contamination of the food chain via lead emissions will be minimal and has added language to this effect.
COMMENT 30: MDEP questions the use of 1970 census data which was the source of the percentage of housing in the area that was constructed prior to 1950. MDEP also questions using the percentage housing constructed prior to 1950 as an indicator of the prevalence of a lead point source when lead paint was banned in 1972. Finally MDEP questions why lead paint is the only source of lead exposure considered and not atmospheric deposition from automobiles built prior to 1974 or industrial emissions.
Response: MDPH utilized data regarding the percentage of pre-1950s housing from the most recent needs assessment released by the MDPH Childhood Lead Poisoning Prevention Program (CLPPP). This information is not in the 1990 census data reviewed when completing this report. We have expanded on these findings (See appendix 4.) and have observed that the areas in New Bedford with the highest prevalence of childhood lead poisoning are those that are in close proximity to the area where the incinerator is proposed to be sited. The interiors of houses constructed prior to 1950 were predominantly painted with paints containing lead. This can not be said about the houses constructed after this time period. Finally, lead paint is considered as not the only source of exposure but is that which is most prominent in the population of concern; children under six years of age living in an urban environment.
COMMENT 31: MDEP believes the lead removal efficiencies demonstrated by the actual incinerating unit to be used at the site should be reported.
Response: The latest revision of this document includes these numbers.
COMMENT 32: MDEP questions the statement in the document that ambient air monitoring will provide a more accurate determination of the extent to which human populations are being exposed to incinerator emissions than would actual stack testing.
Response: MDPH believes that both ambient air monitoring and modelling of exposure based on the results of stack testing have both their merits and uncertainties. We also believe that ambient air monitoring is necessary in order to determine whether ambient air is a source for significant lead exposure before, during, or after the incineration process is completed. MDPH considered in detail those areas where the prevalence of childhood lead poisoning is high and noted these areas to be in close proximity of the area where the incinerator is proposed to be sited. We have however modified the language of the statement in question to indicate that uncertainties also exist regarding the source of any lead elevations that may appear during necessary ambient air monitoring.
COMMENT 33: MDEP questions the consideration of exposure to site contaminants via use of private ground water since the site is non-potable salt water and that any migration of PCBs via ground water would be minimal.
Response: As part of the Health Assessment process, all ground water use and contamination is considered, and if possible, its impact on human health characterized. If information regarding ground water contamination or use is not available, ATSDR considers the Public Health Assessment incomplete. There is no possibility that the municipal water supplies for New Bedford and the surrounding towns have been affected by the New Bedford Harbor site and it is believed that the drinking water needs for the entire city of New Bedford are served by distant water supplies. There may be, however, industrial use of private ground water, which may present a means of exposure to environmental contaminants since PCBs were detected in ground water at the Aerovox plant.
COMMENT 34: MDEP questions why risks associated with inhalation of PCBs that are elevated in the areas around the hot-spots especially during low tide were not reported in the Public health Implications section.
Response: MDPH reported in the Public Health Implication section that based on animal studies, chronic exposure to PCBs in ambient air detected at the hot spots and surrounding areas may be associated with elevated risk of cancer development. MDPH believes this statement is a sufficient description of the risk involved with such exposure. To address this concern, we have expanded the description of this exposure in the appropriate sections of the document.
COMMENT 35: MDEP believes that the language "at a 0.05 level of significance" is not easy to understand.
Response: The language in the document has been modified to more clearly present this concept.
COMMENT 36: MDEP reiterates their concern with the statement that exposure to lead emissions from the incinerator poses the largest health concern with respect to the selected remediation.
Response: Please see response to comment 22.
COMMENT 37: MDEP reiterates their concern with the stated significance of the recommended ambient air monitoring.
Response: Please see response to comment 32.
COMMENT 38: MDEP requests that the exposure routes associated with the dredging process and those associated with PCBs in ambient air be included in the conclusions section.
Response: MDPH has included these routes in the conclusion section in the revised document.
COMMENT 39: MDEP states that VOCs will not enhance the mobility of PCBS in air.
Response: Conclusion 7 (now Conclusion 8) has been changed to state that VOCs enhance PCB volatilization and mobility through sediment and water.
COMMENT 40: In response to Conclusion 9, MDEP reiterates their comment about the fence at the Aerovox plant.
Response: The wording of this conclusion has been changed considering the presence of a fence between the plant grounds and the bluff.
COMMENT 41: In response to recommendation 4, MDEP reiterates their concerns regarding the uncertainties inherent in the interpretation of ambient air monitoring.
Response: While MDPH is aware of these uncertainties, we also recognize the need to consider that the incinerator is in an area where an elevated prevalence of childhood lead poisoning has been identified. We believe that it would be helpful in the planning of remedial strategies if the exact locations of these areas of high risk were identified and have done so. (See appendix 4.) We also believe that ambient air monitoring will enable health officials to determine whether ambient air lead levels are exacerbating the existing childhood lead poisoning problem in New Bedford.
COMMENT 42: In response to the recommendation that sediment be monitored for PCB migration during the dredging process, MDEP states that such monitoring will occur.
Response: MDPH appreciates this information.
COMMENT 43: In response to recommendation 8, MDEP reiterates their concern that physical risk may be overstated in the public release of the document.
Response: See response to comment 40.
COMMENTS FROM USEPA:
COMMENT 1: USEPA suggests that the report implies that the proposed incineration of PCB contaminated sediments poses the greatest risk with respect to exposure to site-related contaminants.
Response: While the public release of the document originally stated that incineration of PCB and metal contaminated sediment poses the greatest health concern with respect to the proposed remediation (this wording has since been changed) it does not state or imply that the health risks associated with incineration of contaminated sediments outweigh those associated with the site in its present state. Rather, MDPH believes that the removal of the contaminated hot-spot sediments will reduce the risk associated with dermal contact. We also state that the two primary routes of exposure to site related contaminants are ingestion of contaminated fish and dermal contact with contaminated sediments. We have also expanded the discussion regarding the exposure to PCBs in ambient air via inhalation and the possible increased risk of exposure to PCBs via inhalation during the dredging process.
COMMENT 2: USEPA suggests that incorporation of the lead removal efficiency demonstrated by the incinerator that is actually proposed to be used at the site would be helpful to the community.
Response: In response to both USEPAs and MDEPs concerns, this data has been included in the latest revision of the document.
COMMENT 3: USEPA maintains that trial burn performance is sufficient to indicate whether health and safety requirements will be met and that permits to proceed with full scale incineration will not be issued until these performance standards have been met.
Response: See response to MDEP comment 1.
COMMENT 4: USEPA suggests that any risks resulting from short term exposure to site contaminants resulting from remedial efforts should be weighed against the effects of long term persistent exposure which may occur if the site remains unremediated.
Response: MDPH agrees that removal of the contaminated Hot-Spot sediment will mitigate exposure via dermal contact and inhalation of PCBs. The department, however, believes that exposure to lead by sensitive populations (eg. young children) residing near the area where treatment is proposed could present a hazard with persistent effects if short term exposure to high lead concentrations were to occur. It is important to note that if the incinerator were to operate at the high lead removal efficiencies observed in the past, health effects associated with lead exposure would, in all likelihood, not occur.
COMMENT 5: USEPA suggests that the ambient air pathway is not well discussed and that inhalation of indoor air while important is not discussed at all. USEPA also suggests that there is an imbalance between the amount of discussion devoted to known inhalation pathways and potential inhalation pathways posed by the operation of the site-specific incinerator which will have known controls, which in EPAs opinion are not mentioned in the document.
Response: MDPH has expanded the discussion of the ambient air exposure pathway in the current revision of the document. There was no discussion of exposure to site-related contaminants via inhalation of indoor air since there were, to the best of MDPHs knowledge, no indoor air samples taken in buildings near the site. The issues of exposure to incinerator emissions and contaminants in present ambient air conditions were discussed in the document. MDPH presented an extensive discussion of the potential exposure to incinerator emissions due to the citizen concern prompted by the issue of incineration. The issue of incinerator controls which will be used on the actual incinerator proposed to be used at the site was also sufficiently discussed.
COMMENT 6: USEPA commends the incorporation of Toxic Release Inventory (TRI) data into the Public Health Assessment but notes that this data only represents a small fraction of actual industrial release of contaminants to the environment.
Response: MDPH has considered this commentary in the current revision of the document.
COMMENT 7: USEPA suggests that MDPH should do a lead exposure assessment of children in the greater New Bedford area but believes that ambient air monitoring would not adequately enable officials to identify the source of elevations of ambient air lead levels should they occur.
Response: MDPH has identified those areas of greater New Bedford where elevated prevalence rates of childhood lead poisoning have been identified. Please see the response to MDEP comment 1 for MDPHs response to the need for ambient air lead monitoring.
COMMENT 8: USEPA suggests that observational epidemiologic evidence of adverse health effects that is consistent with those observed in controlled animal studies should be presented in the Public Health Assessment.
Response: MDPH believes that if an epidemiologic study does not adequately control for other potentially confounding variables, it is not a valid study and should not be presented as suggestive evidence of an association between PCB exposure and adverse human health effects.
COMMENT 9: EPA suggests that MDPH should determine the areas where the highest prevalence of childhood lead poisoning exists but believes that the recommendation for ambient air lead monitoring before, during and after the incineration process may not be necessary since the incinerator operation will not exceed the state's ambient air lead standard.
Response: MDPH feels that, in all likelihood, even with the most efficient removal of lead from the air stream, lead emissions may exceed the Massachusetts Allowable Air Levels (MAALs), especially at the point of emission. MDPHs questions whether these levels will remain elevated at points where sensitive receptor populations exist.
COMMENTS FROM THE CITY OF NEW BEDFORD BOARD OF HEALTH (NBBOH):
COMMENT 1: The NBBOH supports MDPHs recommendation for ambient air monitorin to be conducted in conjunction with the incineration of contaminated hot-spot sediment and believes that it is unconscionable for EPA to base their evaluation of incinerator emissions to air on two trial burns.
Response: MDPH appreciates the support of the New Bedford Board of Health on this issue.
COMMENT 2: NBBOH has asked MDPHs position regarding incineration if the recommended ambient air and stack testing is not conducted.
Response: Both USEPA and MDEP have assured MDPH that the incineration will not be permitted unless appropriate lead removal efficiencies have been demonstrated during the two stack tests. MDPH recommended ambient air lead monitoring as further assurance that areas with subpopulations sensitive to lead exposure were not being negatively impacted during the incineration process. The MDPH would need evidence that this would not occur before it could concur with any remedial plan for the area.
COMMENT 3: NBBOH asked about the available courses of action to either the City of New Bedford or the Commonwealth if MDPHs recommendation for ambient air lead monitoring is not followed.
Response: Since the MDPH is not a regulatory agency, EPA is not legally compelled to comply with the Department's recommendation.
COMMENT 4: NBBOH has asked about the lead removal efficiencies demonstrated for the actual incinerator planned to be used at the site.
Response: The MDPH has updated the document and has included this data which was made available as the public comment revision was nearing completion. Lead removal efficiencies of 99.96% have been calculated based on the results of previous stack tests conducted on the incinerator prior to other remedial projects.
COMMENT 5: The NBBOH inquires of health risks associated with elevated emissions of other contaminants besides lead.
Response: The MDPH anticipates no other adverse health effects associated with incinerator emissions provided it operates within the stated specifications.
COMMENTS FROM THE FAIRHAVEN BOARD OF HEALTH (FBOH):
COMMENT 1: The FBOH provides the correct spelling of Coggeshall Street.
Response: MDPH appreciates this information and has made the appropriate changes to the document.
COMMENT 2: The FBOH appreciates the detail of discussion of the pathways analyses of the document, but would like this information incorporated into recommendations for remediation.
Response: The MDPH has already made recommendations regarding the selected remedial plan and its impact on the health risks posed by the site. We state that removal of contaminated sediments is essential to prevent further exposure to PCBs via inhalation and dermal contact with contaminated sediment and that further monitoring of seafood is necessary in order to determine the impact of remedial efforts on food chain contamination. We also state that under proper operating conditions the incinerator poses no health risks to the surrounding communities but since a sensitive receptor population for lead exposure exists in New Bedford the Department believes that ambient air monitoring for lead is warranted.
COMMENT 3: The FBOH states that the information regarding the type of incinerator is dated and should be revised.
Response: The MDPH has made the appropriate revisions in the most current revision of the document.
COMMENT 4: The Board offers data on wind speed and direction that have been compiled over the past year to MDPH to assist with assessment of exposure to incinerator emissions.
Response: MDPH appreciates the offer and should the health impact of PCBs incineration on the citizens of Fairhaven become an issue, the MDPH will review the data that the FBOH has compiled and incorporate it into any exposure assessment that MDPH may conduct in response to such issues.
