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Date Received Comment or Question Source
4/25/2025 I strongly oppose proposed 'updating' of the state's Hazardous Waste Management Plan to allow it to, 'identify and evaluate protective alternative management standards for soil identified as hazardous...to be disposed of in AUTHORIZED NON-HAZARDOUS WASTE LANDFILLS.' This would lead to contaminated soil ending up in everyday landfills near homes, schools, playgrounds, and other areas used by unsuspecting civilians. As a former Bay Area resident (now living on the Central Coast), where many residents have been exposed to toxic emissions from oil refineries, and landfills in Berkeley and Albany have recently been discovered to have toxic materials, and Hunters Point Shipyard, where new housing has been built, only to discover radioactive materials were not disposed of-- I am aghast at the possibility of expanding the areas in our state where people are exposed, often unknowingly, to toxic materials. The whole point of having hazardous waste disposal sites is to sequester these dangerous substances and to protect public health. Please don't allow this policy change, just because it's expensive and difficult to protect the public. It's more expensive and difficult, in the long run, to deal with the negative and enduring impacts on public and individual health. Sincerely, Joyce Ng Email
4/25/2025 Dear DTSC and BES Members, I am writing to express strong opposition to the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local landfills, represents a dangerous step backward for public health and environmental safety in California. We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because it's more convenient and cost-effective to manage them locally. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification. Communities near landfills, already face serious environmental and health burdens. Expanding the definition of acceptable waste will only add to these risks — through air pollution, groundwater contamination, and increased exposure to carcinogens and heavy metals. Instead of lowering our standards, California should be leading the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source. I urge you to reject this plan, extend the public comment period, and host more community hearings to ensure that the voices of frontline communities are heard and respected. Sincerely, Daniel Sternbaum Email
4/25/2025 Please see the attached letter. Public site
4/24/2025 My husband and I strenuous object to the dumping of poisons in our neighborhoods in California. Shame on California for backtracking on its so called values. Surely there are proven ways 9f dealing with toxic materials than dumping them in poor areas. We expect to hear alternatives from your organization. Public site
4/24/2025 Dear DTSC and BES Members: I am writing to express strong opposition to the proposed changes outlined in the 2025 Draft Hazardous Waste Management Plan. This plan, which would permit more hazardous materials — including contaminated soil and industrial byproducts — to be reclassified and disposed of in local landfills, represents a dangerous step backward for public health and environmental safety in California. We are deeply concerned that this proposal effectively lowers the bar on what is considered "toxic" — not because these materials have become less dangerous, but because it's more convenient and cost-effective to manage them locally. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification. Communities near landfills, already face serious environmental and health burdens. Expanding the definition of acceptable waste will only add to these risks — through air pollution, groundwater contamination, and increased exposure to carcinogens and heavy metals. Instead of lowering our standards, California should be leading the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source. My family and I urge you to reject this plan, extend the public comment period, and host more community hearings to ensure that the voices of frontline communities are heard and respected. Thank you, Aimee Doherty Email
4/23/2025 Please consider this article submitted by our coalition member Richmond Shoreline Alliance inanticipation of tomorrow's public meeting. I'm sending this in on behalf of the author. If you have any questions feel free to reach out to me directly. Look forward to seeing everyone tomorrow in Berkeley. -Matt ################# ICYMI: SF Chronicle: California is about to make it easier to dump toxic waste in your neighborhood. Here’s what to do about it In Richmond, where I live, we know what happens when hazardous waste is treated as an afterthought. Our shoreline is tainted with the legacy of more than a century of heavy industry — shuttered chemical plants, old oil tanks and hazardous waste sites that still bleed toxins into the soil and San Francisco Bay. California’s Department of Toxic Substances Control is updating the state’s Hazardous Waste Management Plan, a document that’s supposed to chart a safer, smarter future for dealing with our most dangerous industrial byproducts. But buried deep in the current version of the update is a proposal to allow more contaminated soil and toxic materials to be dumped in regular municipal landfills — sites never designed to safely contain hazardous waste. In the department’s own words, it would like to “identify and evaluate protective alternative management standards for soil identified as hazardous … to be disposed of in authorized non-hazardous waste landfills.” The bureaucratic language masks the dangerous implications: This policy shift could allow contaminated soil to land in everyday landfills near homes, schools and playgrounds, exposing Bay Area residents to heightened health and environmental risks. Richmond residents already breathe some of the dirtiest air in the state. Many of our children struggle with asthma, and our elders are burdened with pollution-related heart and respiratory disease and cancer. And for decades, Richmond activists have fought for stronger environmental protections — not just for ourselves, but for frontline communities across California. So, when the state quietly proposes to weaken rules that govern how and where toxic waste is dumped, we recognize it’s not just a bureaucratic policy change — it’s a threat. A threat to the health of our neighborhoods. A threat to the progress we’ve made. And a signal that California may be choosing pollution expansion over pollution reduction. Under this plan, the list of landfills eligible to receive toxic soil will grow, and many of them are in the Bay Area. Sites in San Jose, Vacaville, Half Moon Bay, Pittsburg and Petaluma. These are not theoretical locations. These are real communities with schools and homes and playgrounds, now being eyed as future dumping grounds for California’s toxic leftovers. The Department of Toxic Substances Control says the plan will reduce long-distance trucking and lower emissions. But that’s a false tradeoff. Instead of dealing with toxic waste at the source, this plan just spreads it farther and faster. This is not a pollution control strategy — it’s a pollution expansion strategy. It’s cheaper. It’s easier. And it puts the risks right back on communities ill-equipped to deal with them. What’s especially unacceptable is that this policy is moving forward with barely a whisper of public engagement. So far, there’s only been one public hearing with the department’s oversight body, the state Board of Environmental Safety — in Fresno, during the day, when most community members need to be at work. Despite these constraints, more than 40 speakers voiced opposition, including environmental justice advocates, public health experts, and impacted residents. Not a single person or industry group spoke in favor. And yet, the plan is now headed to the Bay Area unchanged. There will be a second public hearing on Thursday at the department’s offices in Berkeley. It’s the only opportunity for Bay Area residents to speak out. After a hearing in Los Angeles on May 15, the state Board of Environmental Safety will cast its final vote on July 15-16 at a meeting in Sacramento. The five-member Board of Environmental Safety, made up of appointees from the Legislature and the governor, was created in 2021 legislation to provide greater oversight and accountability to the Department of Toxic Substances Control, after years of criticism that the agency was nonresponsive to public input and lacked transparency in decision-making. The same law gave the board oversight authority over what gets included in the department’s Hazardous Waste Management Plan. The hearings and July vote will be the most significant tests yet of the new board’s ability to restore public confidence in the agency. After that, this policy becomes part of California’s roadmap for hazardous waste — one that could remain in place for years. We still have time to change course. So far, members of the oversight board have raised important questions: Why weren’t environmental justice groups consulted? Why hasn’t the department conducted site-specific environmental and health impact studies? Why not invest in contaminant removal and source reduction, instead of lowering the bar for disposal? Those are the right questions. But now the board needs to hear from the public — especially from those of us who would bear the brunt of these changes. Richmond isn’t alone in this fight. Communities all over the Bay Area are connected by this proposal. If the Department of Toxic Substances Control moves forward, it won’t be just one city that feels the consequences, it will be dozens. And the people who feel it most will be the same ones who’ve been left out of the conversation for too long. So I’m asking my neighbors across the Bay Area: Show up. Speak out. Help us tell the board: We’re not going to accept a plan that rolls back protections and treats our communities as dumping grounds. California should be leading the nation in environmental stewardship. This new hazardous waste plan risks sending us in the wrong direction. We deserve a plan that prioritizes health, safety and justice — not one that makes it easier to spread pollution to already overburdened communities. Janet Johnson is coordinator of the Richmond Shoreline Alliance, a project of San Francisco Bay Physicians for Social Responsibility, working to protect the Bay Area’s shoreline and Richmond residents from environmental harm. Email
4/18/2025 Good Afternoon, Please consider eliminating the fish bioassay test as a criteria for determining a non-RCRA hazardous waste for toxicity. Some businesses have policies not allowing animal testing, and out of speculation, consider wastes aquatic toxics, incurring costs (fish tests can cost ~$1000) associated with managing waste according to non-RCRA standards, where they might not otherwise. Additionally, the fish bioassay test fails some materials that are used to apply to the human body or other segments of the environment. Examples include: a. Sodium Hypochlorite-commonly used to sanitize wastewater (before it is sent to public waters), and drinking water. https://www.thecloroxcompany.com/wp-content/uploads/cloroxregular-bleach12015-06-12.pdf b. Some soaps and detergents, as stated by the DTSC. https://dtsc.ca.gov/faq/if-my-waste-is-a-detergent-or-soap-and-i-have-results-that-show-it-only-fails-the-aquatic-toxicity-test-can-i-ignore-those-results-and-handle-it-as-nonhazardous-waste/ It may be the case that some materials will kill limited types of fish (golden shiners, fathead minnows, rainbow trout) under certain concentrations (which also require environmental alignment of variables). However, it does not seem reasonable that products used to promote health and limit the spread of pathogens should be considered hazardous wastes, when only failing one test on a limited population of fish, when no other criteria for toxicity, or other hazardous characteristics exist. Has a study been conducted on how much of these products are being released into the environment and affecting aquatic populations? Knowing the facts based on such conclusions might provide better guidance on protecting aquatic life, rather than generators following burdensome regulations and incurring significant business costs. Thank you for your consideration. Public site
4/11/2025 Hello, My name is Madison. I am inquiring about the process to create a waste management plan. Is there any information that can help me with creating our plan as we just were notified this is a requirement. Email
4/8/2025 As society becomes increasingly aware of the pervasive dangers associated with per- and polyfluoroalkyl substances (PFAS), the need for comprehensive regulations becomes paramount. While various sectors are scrutinized and held accountable for PFAS contamination, artificial turf remains unregulated, creating an imbalance that ultimately jeopardizes public health and environmental integrity. In California, a state committed to environmental safety and public health, it is imperative to eradicate PFAS from artificial turf. The obligation that other industries face regarding PFAS should equally apply to artificial turf manufacturers, holding them to the same standards of accountability, especially given the compelling evidence indicating that artificial turf poses significant risks. Artificial turf contains unregulated PFAS compounds, which have been documented to contaminate soil and waterways, exposing children who utilize these artificial turf fields to potential endocrine system disruption (among other documented health issues). PFAS are notorious for their accumulation in the environment and potential toxicity to humans; research has linked these chemicals to decreased immune responses and heightened risks for infectious diseases in children (Dalsager et al. 2016; Granum et al. 2013). Children, due to their lower body height and higher rates of activity, are more susceptible to inhaling PFAS-laden dust. This critical factor raises ethical and health concerns regarding the continued use of artificial turf, particularly in recreational environments, where children play. The notion that artificial turf manufacturers can insist that their usage of PFAS is “safe” or that the quantities used are minimal is fundamentally flawed. Independent research has consistently underscored the necessity of transitioning away from artificial turf due to a lack of comprehensive studies on the transfer of PFAS from artificial turf surfaces to children. Furthermore, the presence of highly toxic PFAS compounds, including 6:2 FTOH and PFOS, in synthetic turf fields emphasizes the urgency for immediate action, particularly since the EPA revised its health advisory for PFOS in June 2022, determining that there are no safe levels of PFOS exposure in drinking water. Since it is widely documented that rain and watering of artificial turf fields creates PFAS and microplastic runoff into our waterways, it can easily be demonstrated that California cannot fully clean up its water supply without the full eradication of PFAS in artificial turf. Beyond health implications, artificial turf contributes significantly to environmental degradation. The manufacture and wear of synthetic fields emit methane, a potent greenhouse gas, and release microplastics into the environment. Microplastics not only contaminate soil and waterways, but they also pose threats to aquatic life and further disrupt beneficial ecosystems. Artificial turf also creates heat islands by elevating temperatures on fields to unsustainable levels, documented to reach up to 200 degrees fahrenheit. This condition exacerbates the urban heat crisis and poses additional risks to both human welfare and local ecology. In response to the growing awareness surrounding the dangers inherent in artificial turf, several municipalities, within and outside California, have taken proactive stances to limit its use through bans and moratoriums. This responsive legislative action reflects a growing societal consensus on regulating PFAS out of our environments. To effectively combat California's PFAS contamination problem, it is essential to adopt a holistic approach that addresses all PFAS-laden products, including artificial turf. The Environmental Working Group (EWG) has expressed that many homeowners remain unaware of the PFAS hidden within the turf they install, subsequently contaminating drinking water. One newly installed artificial field has the potential to leach PFAS into the environment for years, creating lingering health risks for both current and future generations. If California desires to fortify its public health initiatives against PFAS exposure in products, it cannot overlook the dangers posed by artificial turf. Creating restrictions exclusively on certain consumer products, while exempting artificial turf, creates an incongruity that undermines the state’s efforts to ensure safer water and food, as well as the overall ecological health of our environment. In conclusion, eradicating PFAS from artificial turf is not merely a health imperative but also a critical step towards achieving environmental equity in California. All manufacturers must be held accountable for the substances inherent in their products, aligning with the state’s broader goals for sustainability and public health, thus embodying its commitment to a safer, healthier future for all. By doing so, the state can safeguard both human health and the environment, creating a more equitable standard for product safety across all industries. Public site
3/20/2025 I have attached a comment letter. Public site
3/19/2025 ICYMI: Fresno risks worsening air pollution under state plan (Fresno Bee); & California regulators want to weaken hazardous waste disposal rules (Los Angeles Times); & California wants to send more hazardous waste to local landfills (San Francisco Chronicle) Join in to tell state officials Fresno must not be a dumping ground for waste | Opinion By Nayamín Martínez March 17, 2025 4:05 PM Fresno and the San Joaquin Valley are already home to some of the worst air pollution in the nation — yet state officials are quietly advancing a plan that could make it even worse. On March 20, the state Board of Environmental Safety will meet in Fresno to evaluate a proposal from the state Department of Toxic Substances Control that would allow more hazardous waste to be dumped in landfills across California, including here in the Valley. This means more exposure to toxic chemicals, more truck traffic bringing hazardous materials through our communities, and more risks to our health, water and air. The most disturbing part is that DTSC has not conducted any meaningful environmental review or public health studies to assess the consequences of this plan. The agency also failed to properly inform or engage the communities that will be most impacted. This is unacceptable. On Thursday, dozens of residents, farm workers, environmental advocates and community leaders will rally at Fresno City Hall before joining the Environmental Safety hearing. We are coming together to demand one simple thing: stop this reckless plan before it’s too late. For decades, the Central Valley has been treated like California’s pollution dumping ground — a sacrificial zone where low-income, rural, and farm worker communities are forced to live with the environmental consequences of industrial pollution, oil and gas operations, and unchecked pesticide use. Many of these communities, including those in Fresno County, already suffer from sky-high asthma rates, extreme exposure to diesel pollution, and widespread groundwater contamination. We know what happens when regulatory agencies fail to protect us — our health, our children and our future are put at risk. Now, DTSC wants to expand hazardous waste dumping in landfills that weren’t originally designed for it without fully evaluating how this will impact local air and water quality. This is not a pollution control strategy; it’s pollution expansion. Under California law, DTSC is required to conduct thorough environmental impact assessments, consult with impacted communities, and ensure full transparency before making major hazardous waste policy changes. But instead of following these basic legal protections, DTSC is rushing forward with this plan without providing a full environmental impact report that evaluates site-specific risks, a public health assessment on how this could increase respiratory illnesses and groundwater contamination, or a real community engagement process that includes accessible materials in Spanish and Indigenous languages and meetings in all impacted regions. This is a textbook case of environmental injustice. Sadly, Fresno is no stranger to this treatment, and we have fought back before. Through the Central California Environmental Justice Network, we join with farm workers, community leaders and public health experts to reduce pollution, protect drinking water and demand stronger safeguards for vulnerable communities. We are at a defining moment for Fresno’s leaders, policymakers and residents. If we don’t stop this plan now, more hazardous waste could be dumped in our communities for years to come — without proper oversight or accountability. That’s why we are calling on the Board of Environmental Safety to reject this hazardous waste expansion plan until proper studies are completed. DTSC must conduct a full environmental review and hold meaningful public hearings in all affected communities. Local and state leaders must stand with Central Valley residents and demand transparency, environmental protections, and real public engagement. Fresno residents are coming together to fight back. On March 20 at 10:15 a.m. we will rally at Fresno City Hall before heading inside to the BES hearing at 11 a.m. We call on other Valley residents sick of the status quo to join us. The Valley deserves clean air, safe water, and a government that listens to the people — not just polluters. It’s time for DTSC to listen. Nayamin Martinez, MPH, is the executive director of the Central California Environmental Justice Network. She has spent her career advocating for clean air, water, and public health protections in the Central Valley. Read more at: https://www.fresnobee.com/opinion/readers-opinion/article302247959.html#storylink=cpy Nayamin Martinez, MPH Executive Director Central California Environmental Justice Network Email
3/17/2025 Director Butler, BES members, and DTSC staff, The California Environmental Justice Coalition (CEJC) has written the attached letter to express our deep concerns about DTSC's proposed inclusion of alternative management standards for non-RCRA soil in the updated Hazardous Waste Management Plan. Many of us have been working on hazardous waste issues and engaging as DTSC stakeholders since the 1990s. Yet, we were not consulted about this significant policy shift. This lack of communication is disingenuous and suggests an attempt by DTSC to advance major changes without the input of long-standing stakeholders and impacted communities. We urge DTSC to honor its responsibility as a regulator by prioritizing community health and environmental safety over policies that weaken existing protections. As we have done in the past, CEJC is open to working with DTSC to find solutions that truly benefit all Californians, especially environmental justice communities. Please feel free to reach out to me to engage in further dialogue pertaining to this issue. Thank you for your time, Tom Helme Public site
3/16/2025 Science is revealing the growing body of scientific studies that show how dangerous microplastics are to living organisms. Microplastics should be considered a toxic substance and plans to deal with this growing threat should be formulated. Thank you. Public site