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Cumulative Impacts and Mandatory Emissions Reductions Team

There is a fundamental problem with the way the US regulates chemical pollution.



Federal agencies have the power to determine whether chemicals are safe, and whether the facilities that produce them are safe. But right now, regulators aren’t seeing the big picture. When we regulate chemical pollution, we can’t just think about the safety of one chemical or one facility at a time. Instead, we have to think about the health of a community holistically. Is a community being exposed to lots of different toxic chemicals from a cluster of facilities? What happens when people breathe, drink, or are exposed to these chemicals in combination? Is public health already stressed in this community, and why? For example, are cancer and asthma rates higher than average in this community? Has this community faced systematic racial discrimination, by being targeted for highway construction and industrial development, or being shut out of home loans via redlining policies? Are there accessible and quality hospitals, grocery stores and green spaces in this community? 

By looking at cumulative impacts, we are able to see which communities have been harmed the most, and must be restored, strengthened and repaired. One way to do this is through mandatory emissions reductions that will require chemical facilities to decrease, and ultimately eliminate the toxic chemicals they are releasing into communities. Right now, companies are given permission to pollute into communities, via permits. We believe that no amount of toxic emissions into communities should be considered “safe” or acceptable, especially given that emissions from multiple sources add up and take a heavy toll on residents’ health. 

About us


We are a collaborative working group of the Coming Clean network. We support and mobilize environmental organizations and directly impacted community members to speak and submit comments to the EPA and other governmental agencies tasked with regulating pollution, to ensure that these bodies hear from people most affected by new methods and policies, listen to their concerns and implement their recommendations. Our long-term goals are to reduce harm from cumulative impacts and to require mandatory emissions reductions, in alignment with the Louisville Charter for Safer Chemicals.

Get involved

If you are a member, send an email to Kathy Curtis (see directory) to ask about current action opportunities, how to join our bi-weekly meetings, and learn more about our work! If you are not yet a member, email Jim Irby to inquire.

Recent federal advocacy



  • In March 2023, we commented on the EPA's Draft Proposed Principles of Cumulative Risk Assessment under the Toxic Substances Control Act (TSCA), arguing that TSCA already requires EPA to consider the real-world, cumulative risks that toxic chemicals pose to communities.


  • In November 2022, EPA revised its definition and framework for cumulative impacts analysis, in response to community feedback.


  • In March 2022 we provided critical input on the EPA’s draft Fenceline Assessment Approach, i.e. the way it plans to measure exposures and risks to fenceline communities when it evaluates chemicals under the Toxic Substances Control Act (TSCA). Problematically, EPA proposed only considering risk from a single facility and a single chemical at a time, ignoring cumulative harm that communities face from multiple facilities and chemicals, and additional health stressors. Read our public comment submitted by 25 organizations. And watch video of our testimonies to the Science Advisory Committee on Chemicals. 


Research from the Coming Clean network


Addressing Environmental Injustice Through the Adoption of Cumulative Impacts Policies: A 2021 Louisville Charter Policy Brief by Drs. Nicky Sheats and Ana Baptista defines cumulative impacts and highlights model policies to address them, with a focus on New Jersey state legislation.





Environmental Justice for Delaware Mitigating Toxic Pollution in New Castle County Communities: A 2017 report by the Union of Concerned Scientists, EJHA, Delaware Concerned Residents for Environmental Justice, Coming Clean and partners, shows that EJ communities in Delaware face substantial cumulative health risks from exposure to toxic air pollution that are much greater than those faced by wealthy white neighborhoods.




Life at the Fenceline: Understanding Cumulative Health Hazards in Environmental Justice Communities A 2015 report by Coming Clean and EJHA shows that people on the fenceline live under the threat of chemical disasters, have limited access to healthy food, and experience higher rates of cancer and respiratory illness.






Read more Coming Clean reports and resources

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