Addressing Environmental Justice to Achieve Health Equity

Abstract

Environmental justice (EJ) communities are composed of marginalized racial/ethnic, low-income/poor, rural, immigrant/refugee, and indigenous populations that live in areas disproportionately burdened by environmental hazards, unhealthy land uses, psychosocial stressors, and historical traumas, all of which drive environmental health disparities. EJ communities are underserved by public and private entities that create and enforce environmental hazards and are underrepresented in decision-making processes. In addition, they are inconsistently defined and often identified via spatial mapping tools or on the basis of other socioeconomic information. Race is the strongest indicator of health risks in these communities, and children are particularly vulnerable due to their physiology and interactions with the environment. Due to its disproportionate impact on health, environmental injustice is definitively a human rights issue as it impedes growth, stability, and the long-term well-being of families living in these underserved and marginalized neighborhoods in both rural and urban settings. Achieving health equity requires assessment of cumulative environmental health burdens within a social determinants of health framework to address EJ as a structural public health issue. A health in all policies approach must be coupled with thoughtful integration of social, economic, and political indicators in EJ research and solutions, and affected communities must be an integral part of the process. EJ seeks health and safety for those most impacted but often with the least power and resources. Health experts have a critical role to play as they shape institutions, research, application of health practices and policies, and interactions with communities.

Relationship to Existing APHA Policy Statements

The following APHA policy statements support the purpose of this statement by advocating on a range of environmental stressors arising from diverse workplace and community contexts, as well as on behalf of specific vulnerable populations. However, none of these policies holistically address the many facets of EJ as it relates to health equity.

• APHA Policy Statement 20189: Achieving Health Equity in the United States
• APHA Policy Statement 20137: Improving Health and Wellness through Access to Nature
• APHA Policy Statement 20179: Reducing Income Inequality to Advance Health
• APHA Policy Statement 201711: Public Health Opportunities to Address the Health Effects of Air Pollution
• APHA Policy Statement 20073: Environmental Injustices: Research and Action to Reduce Obesity Disparities
• APHA Policy Statement 20077: Calling on the US Congress to Restructure the Toxic Substances Control Act of 1976
• APHA Policy Statement 20005: Effective Interventions for Reducing Racial and Ethnic Disparities in Health
• APHA Policy Statement 20062: Reducing Racial/Ethnic and Socioeconomic Disparities in Preterm and Low Birthweight Births
• APHA Policy Statement 200011: The Precautionary Principle and Children’s Health
• APHA Policy Statement 201713: Establishing Environmental Public Health Systems for Children at Risk or with Environmental Exposures in Schools
• APHA Policy Statement 20177: Improving Working Conditions for U.S. Farmworkers and Food Production Workers
• APHA Policy Statement 20078: Addressing the Urgent Threat of Global Climate Change to Public Health and the Environment
• APHA Policy Statement 9912: Preventing Environmental and Occupational Health Effects of Diesel Exhaust
• APHA Policy Statement 7715: Informing Workers of Occupational Health Risks
• APHA Policy Statement 8911: Resource and Solid Waste Management
• APHA Policy Statement 20037: Precautionary Moratorium on New Concentrated Animal Feed Operations
• APHA Policy Statement 20026: Access to Safe Water, Sanitation, and Hygiene Promotion in Developing Countries
• APHA Policy Statement 20017: Research and Intervention on Racism as a Fundamental Cause of Ethnic Disparities in Health
• APHA Policy Statement 20044: Creating Policies on Land Use and Transportation Systems that Promote Public Health
• APHA Policy Statement 200017: Confirming Need for Protective National Health Based Air Quality Standards
• APHA Policy Statement 200012: Reducing the Rising Rates of Asthma
• APHA Policy Statement 8416(PP): Increasing Worker and Community Awareness of Toxic Hazards in the Workplace
• APHA Policy Statement 200412: Support for Community Based Participatory Research in Public Health
• APHA Policy Statement 20042: Reducing Health Disparities in People with Disabilities through Improved Environmental Programmatic and Service Access
• APHA Policy Statement 20079: Building a Public Health Infrastructure for Physical Activity Promotion
• APHA Policy Statement 20015: APHA Position Paper on the Health Status of American Indians and Alaska Natives
• APHA Policy Statement 9904: Federal Policies Impacting American Indians and Alaska Natives
• APHA Policy Statement 201210: Promoting Health Impact Assessment to Achieve Health in All Policies
• APHA Policy Statement 20099: Improving Health Through Transportation and Land-Use Policies
• APHA Policy Statement 20157: Public Health Opportunities to Address the Health Effects of Climate Change
• APHA Policy Statement 201712: Advancing a ‘One Health’ Approach to Promote Health at the Human-Animal-Environment Interface
• APHA Policy Statement 201710: Protecting Children's Environmental Health: A Comprehensive Framework
• APHA Policy Statement 201415: Support for Social Determinants of Behavioral Health and Pathways for Integrated and Better Public Health

Problem Statement

Environmental justice (EJ) is both a set of principles and policies and a social movement that seeks to eliminate the disproportionate impacts of environmental health hazards on communities of color, indigenous communities, and low-income communities, including foreign-born populations.[1,2] The EJ movement grew out of the civil rights movement, and EJ communities have organized and fought myriad environmental injustices. Landmark fights of the 1970s and 1980s include Native nations battling mineral mining; Houston, Texas, communities rising up against the Whispering Pines Landfill; and Warren County, North Carolina, residents demonstrating against a polychlorinated biphenyl landfill.[3,4] Solidarity among EJ communities across the urban-rural divide ensures that environmental injustices are eliminated and not merely displaced from one community to another.[1]

As the United States prioritized environmental health with the establishment of the Environmental Protection Agency (EPA) in 1970, communities of color raised concerns about then-undocumented disparate conditions; however, they were often ignored or sidelined.[5] The EPA would not explicitly address disparities in environmental health in earnest until 1990 with the creation of the Environmental Equity Work Group, which led to the establishment of the Office of Environmental Justice (originally the Office of Environmental Equity) and the National Environmental Justice Advisory Council (NEJAC) in 1992 and 1993, respectively.[3] In 1970, the U.S. Department of Health and Human Services (DHHS) released a report noting a higher prevalence of preventable lead poisoning in children of color predominantly caused by substandard housing.[6] It would be another 15 years before the DHHS created a task force on minority health in 1985. In 1994, Presidential Executive Order 12898 (Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations) directed federal agencies to address EJ.[3] However, addressing past traumas and deconstructing systems that continue to permit, or even encourage, environmental inequities require directed and widespread action by many, including the public health community.[7]

In addition to slow or little implementation at the federal regulatory level, structural racism and discrimination in planning have further contributed to environmental injustices and, thus, threats to public health in EJ communities. Suburbanization, discriminatory housing policies, segregation (residential, economic, occupational), massive highway construction, deindustrialization, and poor zoning have all contributed to inequitable development in and across U.S. landscapes.[8] Uneven planning and development have resulted from common exclusionary practices and policies over the years (i.e., Jim Crow, exclusionary zoning, racial covenants, redlining).[8] These same EJ communities, particularly urban ones, are then gentrified as an influx of wealthier, highly educated workers relocate to these historically disadvantaged areas as a result of “urban revival” efforts. Residents are subsequently displaced due to inflated costs of living within these communities, as seen in metropolitan areas across the country.[9] Gee and Payne-Sturges’s exposure-disease-stress model on individual- and community-level vulnerability highlights the need for resources to counterbalance disproportionate impacts that become more significant in areas of high segregation.[7] Alongside the compound effects of poverty, unemployment, and crime, communities are suffering from a lack of healthy, fresh, and culturally appropriate foods; quality infrastructure; access to transportation; and access to green space—all environmental variables considered to potentially impact mental health via increased stress and anxiety.[8,10]

It is therefore no surprise that exposure to deleterious land uses and infrastructure has been linked to increased cancer and respiratory illness and a decreased overall sense of well-being,[2,8] as well as exacerbation of comorbid conditions such as diabetes, obesity, cardiovascular disease, neurological and psychiatric disorders, and impaired maternal and child health.[7,8,11] Infants and children are especially vulnerable to adverse environmental health outcomes because of their unique biological vulnerabilities and age-related patterns of exposure.[12] Addressing these variables strategically can potentially combat environmental injustices and inequities if the process is inclusive and collaborative and includes community members, policymakers, and EJ organizations to ensure resource development and prevention of neo-segregation and displacement.[9] Research has further elucidated that race is a stronger indicator of disproportionate harm than poverty.[5,13–15]

Robust evidence of disproportionate environmental health risks affecting communities of color, indigenous communities, and low-income people has been documented across a wide variety of specific contaminants and multicontaminant sources, including lead,[6,16] air pollution,[13,14] hazardous waste,[4,5] chemical and petrochemical facilities,[2] uranium mine tailings,[17] and dumping.[17] Furthermore, growing research shows that climate change exacerbates disparities in exposures, both directly through increased exposures to air and water contaminants and indirectly due to limited adaptation and resilience planning.[18,19]

EJ communities are often alarmed by high disease rates and suspect that hazardous environmental exposures have caused a disease cluster.[20] However, existing protocols for disease cluster investigations and methods for linking disease clusters to environmental exposures are flawed and rarely provide satisfactory answers.

While extensive research has examined the health impacts of individual pollutants, growing evidence suggests that pollutants and other environmental stressors often have synergistic effects, indicating that a more holistic approach is needed.[19,21] “Cumulative impact” refers to the combined, incremental effects of human activity and their consequences for human health.[2] Cumulative impact analyses, integrating social determinants of health, have begun to elucidate the full scope of stressors in EJ communities and the impacts of policies.[11,19,22–26] “Health in all policies” is a concept that attempts to address cumulative impacts by incorporating considerations of health impacts into a wide range of policy-making and decision making. Federal-level policies have begun to tackle both social determinants of health and environmental justice, in part by incorporating the health in all policies concept.[27–29] By eliminating these environmental injustices, health burdens, and adverse exposures, we can promote health equity through physical and mental health promotion, communal resilience with respect to climate change, and improved health care access.

Evidence-Based Strategies to Address the Problem

The list of strategies described here began with a review of WE ACT for Environmental Justice of West Harlem’s “Eight Ways Environmental Organizations Can Support the Movement for Environmental Justice” and adaptation of these eight concepts to be relevant to a broad suite of public health professionals.[30] The strategies represent actions toward achieving environmental justice and not merely environmental equity—eliminating harms rather than attempting to redistribute them.[31] A fundamental principle underlying these strategies is respecting the experiences of communities most impacted by environmental inequality and promoting their ability to speak for themselves.[1]

Support EJ communities’ power with information, resources, scientific collaborations, and spaces for networking/sharing to document and address health inequities: EJ policy changes typically stem from pressure and activism of communities and organizations rather than from initiative within a government agency. The tools of the civil rights movement inform many successful strategies that have reduced environmental injustices and, thus, improved public health. These strategies include litigation, petitions, marches, and other nonviolent direct action.[32] Among the groups supporting EJ progress are the Deep South Center for Environmental Justice (which cultivates environmental leaders), the National Environmental Justice Conference and Training Program, and NEJAC. There are significant efforts at historically Black colleges and universities to promote leadership in environmental organizations that better reflects the diversity in our country, helping to ensure that the charge to address EJ is done through the lens of communities of color and their lived experiences.[3]

Providing EJ communities with accurate, timely information can support their approaches and solutions and foster meaningful participation.[32] Public health professionals must conduct the preparatory work (prework) necessary to understand which terms of engagement work for a particular community, including logistics that facilitate participation (e.g., convenient meeting times and locations) and translation needs (in terms of both language translation and communication of technical information). Prework also includes identifying existing activities and services (e.g., specific supports, structures, and competencies) and understanding the efforts needed at different operational levels and in different contexts of public health practice. Communities will have diverse needs; the main prerequisite is to ensure that they are resourced to participate, which may require a flexible, case-by-case approach and dedicated funding.

Promote cross-disciplinary research that investigates disproportionate impacts and methodologies to advance cumulative impact analyses: Academic research on cumulative impacts, vulnerability indicators, and multiple exposures over a lifetime is growing. Empirical studies have documented multiple stressors and cumulative impacts across all environmental media, and in some cases these investigations have integrated nonchemical stressors and socioeconomic and community factors.[22,24,33] (A number of studies in this area were published in the American Journal of Public Health’s special issue on environmental justice in December 2011.) This type of research is better able to capture the synergistic effects that multiple environmental and sociodemographic stressors can exert, offering greater insight into the realities faced by EJ communities. It is particularly important that research and tools for characterizing cumulative burden be developed with both rural and urban geographies in mind.

Cumulative impact analysis is typically more spatial and quantitative in nature and should be complemented by other mixed-method, community-driven, and collaborative research, including community-based participatory research (CBPR), community science, and community monitoring.[34,35] Community-centered research can fill gaps where agency data are lacking and call attention to emerging or understudied community issues. For example, certain EJ subpopulations may be especially difficult to reach, such as immigrants who are undocumented or linguistically isolated. As a result, there is a lack of research in current literature evaluating these subgroups’ overall environmental health. Studies have shown that community health workers can play a key role in CBPR and other types of community-engaged work, serving as a direct link for research and intervention among these and other vulnerable populations.[36]

Track environmental and public health metrics with a specific and targeted focus on EJ to better quantify who predominantly benefits and who is impacted by environmental programs and policies: Understanding how proposed solutions, decision making, and planning will affect impacted communities is essential to improving health outcomes and mitigating unintentionally perpetuated injustices.[18] Well-intentioned programs and policies may improve public health for some but perpetuate or miss opportunities to reduce inequities. For example, national average pollution emissions have decreased dramatically since the implementation of the Clean Air Act of 1963, and these reductions have significant and quantifiable health benefits.[37] However, reporting only national and regional averages disregards lower-income communities and communities of color where air pollution concentrations violate air quality standards and health guidelines.[13]

Relatedly, the dominant approach to reducing U.S. greenhouse gas emissions is through emissions trading based on “average” state emission rates targets.[24,25] This approach may lead to reductions in average emissions over larger geographic areas but does not address impacts from pollution on a smaller geographic scale. A recent study on the first 3 years of California’s cap-and-trade program showed that while total emissions were under the program cap, many neighborhoods experienced increases in annual average greenhouse gas and co-pollutant emissions from nearby facilities.[24] These neighborhoods tended to have characteristics of EJ communities. Researchers stressed that climate mitigation programs should incentivize emissions reductions in disadvantaged communities. Mitigation policies that fail to consider place-based disparities may not rectify inequities in environmental health and could even result in increases in disparities.[25]

Integrate findings from cumulative impact research into interagency and intergovernmental (tribal-U.S.) policy and planning: New geospatial software and analytical tools have greatly improved the process of identifying EJ communities at risk and offer a powerful analytical and advocacy strategy. In 2012, following a multiyear consultative process, the California Environmental Protection Agency released CalEnviroScreen, a spatial analysis tool integrating multiple environmental, sociodemographic, and health metrics to assess cumulative impacts, identify areas of concern, and prioritize resources. The federal EPA launched its own EJ screening tool, EJSCREEN, to identify and prioritize areas of concern in 2015. Both CalEnviroScreen and EJSCREEN have inspired efforts to create similar tools in other jurisdictions.

Analytic tools and results are insufficient if they are not connected to policy levers to promote environmental justice and public health, especially at the local and state levels.[9,23,38] Ways in which findings can and have been leveraged include the following: informing permitting and land-use decisions, prioritizing enforcement, ensuring better informed provision of technical expertise to communities, allocating grants for emissions-reduction projects, and providing funding for green infrastructure development.[39] With respect to permitting and land use, there should be mechanisms for community participation and for consultations between the U.S. government and tribal governments to reduce potential health impacts. Finally, Title VI prohibits discrimination on the basis of race in programs that receive federal funding. EJ research could inform U.S. Department of Justice enforcement of Title VI by investigating discriminatory and subsequent enforcement actions.[3]

Collaborate with and seek guidance from impacted communities and environmental justice organizations early in public health decision making: The principles of EJ were adopted on October 27, 1991, in Washington, D.C., at the National People of Color Environmental Leadership Summit; these principles emphasize the “self-determination of all peoples.” Inherent to self-determination is meaningful engagement, one of the key tenets of EJ and an instrumental factor in creating strong policy.[1] Meaningful engagement includes ensuring access to decision-making opportunities through thoughtful planning of meetings, including timing, location, and the language used to communicate information and solicit input. These tenets were reaffirmed in the 2019 Equitable and Just National Climate Platform, which seeks to cooperatively address the climate crisis while simultaneously advancing the goals of economic, racial, and environmental justice to improve the public health and well-being of all communities.[18] A myriad of grassroots groups joined with national nonprofits in working to achieve these goals.

In addition to providing technical assistance, public health organizations and agencies can provide space for sharing resources, networking, and soliciting guidance and input from communities impacted by environmental inequities. Preventing extractive engagement and instead offering collaboration that is mutually beneficial and supports building capacity is critical. The value of opportunities for collaborative problem solving cannot be understated, as multiple stakeholders can support community-driven solutions.[32] One example of how this can be successful is to have nontraditional partners participate in an environmental justice advisory group (e.g., migrant workers, Black Lives Matter, faith-based organizations). As policies and programs are developed to reduce pollution and improve environments, an inclusive and equitable process that promotes collaboration among local agencies and partners can prevent gentrification and displacement.[9]

Another way to ensure thoughtful and valuable engagement is to work toward greater diversity and inclusion in academic, environmental, public health, and governmental organizations.[40,41] Greater diversity implies increased representation from groups that are not a part of the dominant culture in the specific work and education environment. The National Institute of Environmental Health Sciences Environmental Career Worker Training Program awards grants in communities across the United States to recruit and train individuals in vulnerable communities at risk of contaminant exposure to work in environmental fields, while the Centers for Disease Control and Prevention’s Office of Minority Health and Health Equity also runs student programs. Ideally, these efforts, applicable across both governmental and nongovernmental sectors, work to increase capacity and promote better decision making through inclusive hiring and retention practices and effective consultation policies.

Opposing Arguments/Evidence

EJ requires changing unjust structural conditions deeply ingrained in our built environment and social and economic systems. Because EJ means dismantling systems of oppression and redistributing power and resources, opposing arguments generally tend to reframe the issue to shift responsibility, argue that current conditions are acceptable, or maintain that change is too difficult and costly. A shift away from systemic environmental racism and toward ethical decision making involves the realization and acknowledgment of an unjust system by those working and living within the system itself. This section includes an overview of some common arguments against EJ with evidence in response.

One category of opposing arguments questions the links between polluted environments and observed health problems, alleging responsibility on the part of impacted communities. Polluting industries or government agencies might acknowledge that EJ communities suffer from health disparities but will argue that health problems are the result of individual choices and behaviors (e.g., smoking or diet), not environmental conditions, and instead recommend interventions involving behavior change, educational information, or individual services. While individual interventions have health benefits, this approach distracts from and does not adequately address underlying socioeconomic and environmental determinants of health and the interwoven dynamics that shape health behaviors, including systemic and institutional inequities.[22,42] Neighborhood contexts and determinants of health influence and constrain personal decision making.[43] Even with health-supporting behaviors, chronic exposure to stressors will increase the risk of adverse outcomes.

Another argument is to acknowledge racial/ethnic health disparities in EJ communities but argue that they are instead due to genetic differences. It is well established across scientific fields that race is a social construct that was used to create systems of racial oppression in the context of European settler colonialism.[44] Through systems and institutions, these socially constructed racial hierarchies continue to be reproduced and remain evident in policies that shape the built environment and social landscape. Race has also been a primary factor, more influential than class/income, in the siting of polluting land uses in communities of color.[5,13–15] The field of epigenetics points to the dynamic nature of gene-environment interactions and provides a fuller understanding of how various forms of trauma and stress, including environmental exposures, can affect gene expression and induce disease.[45,46]

A final responsibility-shifting argument questions whether polluting industries are intentionally sited in low-income communities of color and suggests instead that people choose to move into more affordable areas with greater industrial activity. There is ongoing debate about this “chicken-and-egg” cycle, but evidence suggests that racial discrimination and sociopolitical forces do drive facility siting into communities of color and low-income communities.[15] Economic pressures determine what options people have, and the availability of affordable, healthy housing is limited in large part due to the legacy of redlining and racial segregation. The lack of affordable housing, the high cost of moving, and fear of eviction or landlord retaliation create pressure and vulnerability for low-income families, increasing their likelihood of living in substandard conditions.[47]

Still others argue that current conditions for EJ communities are acceptable and justifiable. Many explain that there is a societal need for critical industrial facilities to be located somewhere, and economic development brings benefits that outweigh harms, creating socially acceptable “sacrifice zones.”[48] This logic has been applied to the detriment of not only urban-based EJ neighborhoods but also rural EJ communities that endure the externalities supposedly necessary for achieving “green” cities (e.g., receiving waste from cities, losing their natural resource base due to extraction).[49] Advocates of this position also claim that environmental regulations are overly burdensome and that government imposition wastes resources and hampers development. Any additional regulations for EJ protections are then presented as too costly and as involving a risk of layoffs or factory shutdowns. In fact, however, the costs of environmental health risks are often externalized and not taken into account.[50] Cumulative impacts are disregarded in cost-benefit analyses, which assess one regulation at a time in a framework based on regulating individual pollutants or pathways of exposure.[37] Developing adequate and just responses would not be government overreach, as government action (e.g., redlining, pollution permits) and inaction (e.g., lack of enforcement of violations) created the undue burden.

Action Steps

To achieve the goals of the evidence-based strategies listed, APHA offers the following recommendations:

1. Institutions and organizations, including government, academia, nonprofits, and private companies, should work to increase diversity and inclusion in environmental and public health sectors in several ways, such as publicly backing and funding institutional diversity and inclusion and retention programs. In addition, organizations should identify and effectively address racism and implicit racial biases, seeking outside expertise where necessary and making this an integral part of work plans. This recommendation applies to all levels of organizational structure
2. Preparatory work should be done to develop goals to better serve EJ communities facing disparate impacts, and then specific strategies and approaches should be chosen on the basis of the unique characteristics of these communities. Furthermore, in addition to understanding existing support structures and competencies, work should be done to identify support structures and competencies that need to be created for this type of engagement based on community contexts.
3. Public health agencies should form partnerships with social justice actors and organizations. This may push agencies out of their comfort zones. However, forming these nontraditional partnerships to tackle the social determinants of health would be a major step in addressing environmental injustice.
4. Institutions and organizations, including government, academia, nonprofits, advocacy groups, and private companies, should meet with, listen to, and work with and for EJ communities to advance solutions to environmental health concerns at the local and state levels. Meaningful engagement of these communities should be prioritized by all entities developing programs, policies, and projects that can impact community health and well-being.
5. Institutions and organizations, including government, academia, nonprofits, and advocacy groups, should join EJ communities in their response to climate change mitigation and adaptation. Climate change mitigation and adaptation policies should include the components of energy justice and should incorporate the results of disparity impact analyses into specific projects to build green infrastructure, improve energy efficiency, and switch to clean, renewable energy.
6. Public health professionals should advocate for sustained health coverage for EJ communities as well as expanded health care and support in the face of environmental disasters, including but not limited to those resulting from climate change. These policies should ensure that resources are directed in ways that reduce disparities.
7. The EPA and state environmental and public health agencies should promote and further develop publicly available analyses and tools to study cumulative risks and impacts. These analyses and tools can be designed to integrate hazard, exposure, and health indicator data collected by the public. The results generated should inform regulations, permitting, settlements, and enforcement actions, leading to reductions in pollution in overburdened communities.
8. Federal, state, and local public health departments should integrate EJ criteria into funding requirements and prioritization. This includes both grant making and budgeting, with the goal of helping to address the causes and ramifications of disproportionately poor health burdens in EJ communities.
9. Federal, state, and local public health departments and public health advocates should work across sectors and jurisdictions to initiate, develop, and promote policies to translate cumulative impact analyses into concrete actions and decisions, including zoning policies, permitting (federal, state, and local), monitoring, compliance, enforcement, new rules and statutes, mitigation programs, and resource allocation.
10. Philanthropic organizations that fund environmental and public health research should fund research on EJ policies that need more evidence-based evaluation, pilot examples of successful policies and programs in other areas, and fund grassroots groups to lead or collaborate on research and programs.
11. Federal, state, and local public health departments and public health advocates should initiate, develop, and promote a strong National Environmental Policy Act program that uses advanced public health tools to evaluate cumulative impacts and provide recommendations to promote health, integrates media-specific findings into a comprehensive analysis including unique connections to the lands of certain cultural groups, and adequately characterizes human health impacts (e.g., through the use of health impact assessments).
12. Institutions and organizations, including government, academia, nonprofits, and advocacy groups, should join EJ communities to advance programs that provide affordable, healthy housing and promote equitable zoning and land-use planning policies.
13. Academic institutions should create EJ curricula, from coursework to department majors, and should engage EJ community members directly in that work by sharing institutional resources.
14. Federal, state, and local governments and academic institutions should address deficiencies in human health risk assessments that do not protect the most sensitive and vulnerable. This includes conducting research on vulnerable populations, characterizing the interactions between chemical and nonchemical stressors, and adequately testing historic default assumptions based on majority populations. The EPA should reinforce approaches—and the National Institutes of Health should fund studies—that account for the cumulative impacts and risks from early-in-life exposures, as well as vulnerability due to socioeconomic stressors and multiple pollutant and pathway exposures. Research agendas should also include the development of epidemiological methods with increased sensitivity to help identify causes of disparate health outcomes.
    In addition, APHA recommends that:
    
    
15. Federal, state, and local local public health agencies should not only enforce existing rules and statutes that include EJ components but also pass and implement specific EJ legislation. It is important to formally codify EJ-related executive orders, agency guidance, and frameworks to allow agency implementation and promulgation. Under its authority to implement Executive Order 12898 (Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations), the U.S. Department of Justice should enforce Title VI of the Civil Rights Act of 1964 in the context of environmental justice. Title VI prohibits recipients of federal financial assistance (e.g., states, local governments, businesses) from discriminating on the basis of race, color, or national origin in their programs or activities, including in permitting and enforcement. Community complaints should be expediently addressed and to the fullest extent of the law.

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