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Date Received Comment or Question Source
5/19/2025 The Draft 2025 Plan outlines ten goals around hazardous waste reduction, permitting, and circular economy reforms. However, its voluntary nature, lack of enforceability, and failure to address systemic environmental injustices render it deeply inadequate for overburdened communities. Key Problems: No Binding Protections: The plan relies on pilot programs and unfunded initiatives, with no enforceable mandates for pollution reduction or health safeguards in SB 535 communities. No Accountability for Past Failures: It ignores DTSC’s documented failures at toxic sites like Exide and Quemetco, offering no plan for legacy cleanup or institutional reform. No Community Oversight: Impacted communities are given no veto power, oversight boards, or role in permitting decisions—undermining core environmental justice principles. Ignores Cumulative Risk: There’s no strategy to address cumulative impacts or halt facility expansion in already overburdened areas like Kettleman City, Buttonwillow, or the San Gabriel Valley. No Industry Accountability: Fails to name top polluting sectors or require producer responsibility. Circular economy goals remain abstract and unenforceable. No Land Use Coordination: Fails to prevent the sale or redevelopment of toxic sites near schools, homes, or freeways without full cleanup or community approval. Recommendations: Codify EJ-Based Permit Denials and sector-specific pollution reduction targets Create community veto boards and independent regulatory oversight Impose moratoriums in high-risk zones and align land use decisions with public health Fund cleanup and reparations through polluter-pay mechanisms Enforce real-time data monitoring, penalties for violations, and restorative justice strategies The 2025 Plan falls short of delivering justice. Without enforceable rules, community oversight, or structural reform, it preserves the status quo. Policymakers in SB 535 communities must demand a stronger, justice-centered plan that puts health before hazardous waste profiteering. Public site
5/17/2025 As a resident of Martinez, living close to a major pollution source, an oil refinery, I appreciate your attention to the subject of hazardous waste & soils. We have contaminated soil from a November 2023 incident at that refinery. We can no longer plant vegetables in this soil and want to dispose of the soil as do many others who reside in Martinez. Public site
5/16/2025 If this plan goes through there will be so many citizens blasting this whole entire plan and all the info on their social media pages. DTSC you’re living in the age of social media and its domination over corrupt government agencies such as yourselves. There will be consequences for these corrupt actions environmentally and on citizens health. You should all be ashamed of yourselves. Public site
5/15/2025 Because of the arsenic from burnt materials containing glues and lead in old paint and nylon, and chromium plated objects, the fire debris need to be sorted through and those contaminated with toxins need to be sent to hazardous waste dumps where they could be recycled carefully. If mixed with regular trash, it would become unsafe to recycle regular trash in the future. Toxins could contaminate organic matter in the trash that might later become fertilizer for farms. We cannot keep piling up trash until it blows onto neighbors' heads. A new toxic waste dump or recycling facility with best available control technology is needed where nobody lives and there are no endangered species. Public site
5/15/2025 Hello, Thank you for the opportunity to comment. I live in Pittsburg, California and do not want to see more pollutants or toxic waste dumped in our community. If you look on CalEnviroScreen, you will see that our community alrhas some of the highest scores for being designated a SB 535 Disadvantaged Community. Please DO NOT weaken the regulations on toxic soil dumping. Thank you Public site
5/15/2025 Because of the arsenic from burnt materials containing glues and lead in old paint and nylon, and chromium plated objects, the fire debris need to be sorted through and those contaminated with toxins need to be sent to hazardous waste dumps where they could be recycled carefully. If mixed with regular trash, it would become unsafe to recycle regular trash in the future. Toxins could contaminate organic matter in the trash that might later become fertilizer for farms. We cannot keep piling up trash until it blows onto neighbors' heads. A new toxic waste dump or recycling facility with best available control technology is needed where nobody lives and there are no endangered species. Email
5/14/2025 DTSC Board, The Hazardous Waste Management plan would be sending toxic soil to landfills not built to handle hazardous waste. You were created to provide oversight. Now is the time to use your power X DO NOT approve the Hazardous Waste Plan before it's updated with changes demanded by communities. SEND THE PLAN BACK! Public site
5/14/2025 It's DTSC's responsibility to ensure that Californians health and environment are protected from hazardous waste, but this plan is a horribly risky. It appears that the plan's purpose is to enable polluters to avoid the full cost of the hazardous waste they create by allowing them to dump it in regular municipal landfills instead of specially designated hazardous waste disposal facilities. The ill conceived plan, instead of protecting Californians, puts frontline communities at even greater risk. It's like the emperor's new clothes: the waste is still what it always was, dangerously toxic, but DTSC is attempting to window dress it as something benign. Reclassifying it for convenience and cost advantages for polluters doesn't change its toxicity. These reclassifications of waste, such as contaminated soil and industrial residues, which have no basis in science or risk assessments, don't change the nature of the toxins. It merely allows an overly risky method of disposal that benefits polluters, not citizens. You know, citizens, the very people the DTSC is charge with protecting. Currently, people living near landfill sites already are exposed to disproportionate health and environmental risks. Expanding the definition of waste to include more types of toxic waste doesn't change the nature of the waste. The expansion of criteria of toxic waste that will be allowed in municipal landfills will only increase the danger of air and water contamination, and add to existing exposure to harmful substances like carcinogens and heavy metals. Many of the landfills that will be affected are located near neighborhoods, schools, and recreational areas. The residents of these areas deserve to have confidence that they are not being exposed to toxins and carcinogens in the very communities in which they live, work, and recreate. Using rebranding to allow more types of hazardous waste doesn't decrease the toxicity of that waste. It's reckless and highly irresponsible to even propose to subject communities located near landfills to more types of toxic waste. If anything, a proposal is needed that would lessen the types of waste allowed in municipal landfills. Instead of expanding the definition of what can go into these landfills, California should be promoting policies that reduce the generation of hazardous waste, advance sustainable alternatives, and strengthen protections for affected communities. Please reject the plan as drafted, extend the timeline for public comment, and provide additional public hearings so that those most impacted have a significant say in the process of managing said waste. DTSC, do the job that the taxpayers are funding you to do: protecting people and California's amazing environment from exposure to toxic waste. Public site
5/14/2025 The STLC Limit for chromium is 5 milligrams per liter. That results in any chromium result greater than 50 milligrams per kilogram requiring a Waste Extraction Test (WET) followed by an analysis for chromium in the extract. This is wasteful as the median background chromium concentration in California soils is well over 50 milligrams per kilogram (see https://ucanr.edu/sites/default/files/2019-01/297094.pdf ). Please change the rule so that soil samples with less than 100 milligrams per kilogram of chromium do not require WET extraction and chromium testing of the extract. Also, it's crazy to ship California Hazardous Waste (not RCRA Hazardous) out-of-state. Public site
5/14/2025 I am writing to firmly oppose the proposed revisions in the 2025 Draft Hazardous Waste Management Plan. The plan’s intent to allow more hazardous materials — such as contaminated soil and industrial residues — to be reclassified and disposed of in municipal landfills poses serious risks to public health and environmental integrity across California. This approach appears to redefine toxicity not based on science or risk, but on convenience and cost. Simply put, diluting or treating hazardous substances does not eliminate their harmful properties. Rebranding toxic waste does not make it any less dangerous, especially when it is disposed of near neighborhoods, schools, and recreational areas. Communities located near existing landfill sites already face disproportionate health and environmental challenges. Broadening the criteria for what can be discarded in these areas will only heighten the danger of air and water contamination, and increase exposure to harmful substances like carcinogens and heavy metals. California should be raising the bar — not lowering it. We should be advancing policies that reduce hazardous waste generation, promote sustainable alternatives, and strengthen protections for impacted communities. I urge you to reject the current draft, extend the public comment timeline, and facilitate additional public hearings to ensure those most affected have a meaningful voice in this process. Public site
5/14/2025 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. Please do not allow this to happen our health depends on it! Public site
5/14/2025 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. 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. As I live in the shadows of Sunshine Canyon landfill, I am reminded every day of Republic's inability to control and contain odor and run-off. Adding toxic materials to the mix makes an already unhealthful situation far worse. Public site
5/14/2025 I am writing to object to the proposed Hazardous Waste Management Plan. In Chapter 7, toxic soil is to be sent to landfills that were not built to handle hazardous waste. This is clearly not protecting the nearby communities, which is what you are supposed to do. I urge you to include actions that will reduce the creation of hazardous waste and to revise the plan so it also includes the updates of changes demanded by communities. Email
5/13/2025 No. Let’s not endanger families, wildlife, and the environment any further than we already have. I do not support this for Pittsburg. Public site
5/13/2025 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. Thank you, Carol Kentis Public site
5/13/2025 Thank you for the opportunity to submit the attached comments to the 2025 Draft Hazardous Waste Management Plan. Email
5/13/2025 Please so not allow hazardous waste to be deposited at our local landfills. This includes contaminated soils from the Los Angeles fires of earlier this year. Thank you. All best wishes, Bruce '0le' Ohlson Email
5/13/2025 Dear DTSC and BES Members, I strongly oppose 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 managing them locally is more convenient and cost-effective. This is an unacceptable tradeoff. Just because a chemical has been "treated" or diluted does not mean it is safe to place it in landfills near homes, schools, and parks. Toxicity does not disappear with reclassification. Communities near landfills already face severe 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 lead the nation by tightening regulations, investing in cleaner alternatives, and preventing hazardous waste generation at the source. I would like you to reject this plan, extend the public comment period, and host more community hearings to make sure that the voices of frontline communities are heard and respected. Sincerely, Elizabeth Mitev Email
5/13/2025 Dear DTSC and BES Members, The North Valley Coalition of Concerned Citizens Inc. is 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 Class III 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. For instance, the Sunshine Canyon Landfill, the largest landfill in the County of Los Angeles is already accepting 2.2 million tons of trash per year. In just a few short months they have already received over 189.000 tons of fire-related debris that was also reclassified thanks to the Water Board... material that should have been sent to a Class I Hazardous Waste Landfill.... and more tonnage expected. While this landfill does have a double liner and leachate collection system, we all know that a liner will only last 25 years at best, and a double liner 50 years. As the leachate collection system ages it silts up, becomes clogged, and collapses. All this, in one of the most seismically active area in all of California, right next to water treatment plants and the LA Reservoir and right next to the communities of Granada Hills and Sylmar. Why because the local authorities and politicians have allowed this in order to have cheap disposal of trash, and the fact that they won't be around to be held accountable for the inevitable contamination and suffering that it will eventually cause. Also, our landfill is located in a pass and the prevailing winds bring odors and dust (over 18,000 odor reports and over 400 NOVs since 2009). Residents have complained for years about the health impacts. The dust is everywhere; residents are having their insurance cancelled because of the accumulation of it on their roofs. If Class III landfills are allowed to take the reclassified hazardous waste soils without any consideration as to the prevailing conditions that exist at those landfills including their proximity to our water supplies, and not just whether or not it has a liner and leachate collection system, it is an environmental disaster waiting to happen, and you will be complicit if you reclassify any currently hazardous waste to non-hazardous or allow said material to be deposited in a Class III landfill. 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. The North Valley Coalition of Concerned Citizens Inc., urges 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, Wayde Hunter Email
5/12/2025 Attached are comments from the Motorcycle Industry Council (MIC), Specialty Vehicle Institute of America (SVIA), and Recreational Off-Highway Vehicle Association (ROHVA). Public site
5/12/2025 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, Miriam Koenig Email
5/12/2025 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 Email
5/10/2025 Dear DTSC, as a Public Health professional I am concerned about the proposed disposal of toxic soil in municipal landfills. Despite assurances about the low health risk of this proposal, it does in the face of the long-standing inequities that fence line communities are already living with. This seems like a step backwards when we are trying to undo historical environmental injustice burdens. Please reconsider this proposal. Thank you. Public site
5/10/2025 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, Gita Belinsky Email
5/7/2025 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, Bethany Sternbaum Email
5/7/2025 California has always set an example for other states of environmental issues. We have raised the bar on environmental issues, not lowered it. This is not the time to deregulate toxic waste. We should be getting more strict as our population becomes more unhealthy from toxic waste. We ask that you revise this motion to not re-classify the hazardous waste as non-hazardous. Our communities deserve better. Many municipal landfills are close to schools, homes, hospitals — vulnerable populations. 50% of landfill liners fail within the first 30 years. In fact, the landfill that’s a stone throw from my own home is 30 years old now. Will this new toxic waste be seeping into our ground water? Please reconsider this proposal for our population and our environment! Public site
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