As residents of West Warwick, East Greenwich and nearby towns, we are writing to oppose any permits for MedRecycler to build a medical waste pyrolysis facility in West Warwick. Pyrolysis, which has been called a “high risk, low yield processes for waste management,” (GAIA 2017) is a potentially hazardous technology that is inappropriate for a residential neighborhood. The nearby residents of West Warwick and East Greenwich -– who bear all of the risks of this dangerous technology, both for human health and the environment – would have no control nor even knowledge of the hazardous waste imported to our towns every day.
Medical waste is known to contain persistent, bioaccumulative toxins like mercury, harmful plastics and other toxins that cannot be eliminated by pyrolysis. We are concerned about potentially harmful air and water pollution from MedRecycler damaging our health and environment, including substances known to result from pyrolysis: carbon dioxide, lead, mercury, dioxins, furans, sulphur dioxide, nitrogen oxides, ash, and char. Given the two daycare centers and a college in close proximity to the proposed site, it is shocking that a facility emitting lead alone would be allowed to operate nearby. Additionally, with residential neighborhoods surrounding the site, we are especially concerned about the health effects of dioxins – known to cause cancer, liver and endocrine damage, infertility, birth defects, and environmental harm – and the potential for radioactive waste to come to the facility (www.epa.gov/dioxin). During DEM’s January 25, 2021, Public Informational Workshop on Facility’s License Application, project developer Nicholas Campanella admitted that he intends to expand the facility to accept medical waste from throughout the northeast; he said that he chose this site partly due to its proximity to I-95. West Warwick and East Greenwich are not a highway off-ramp for hazardous waste. We are communities of kids, parents, and elders – including childcare centers, higher education, local businesses and residential neighborhoods in close proximity to the MedRecycler proposed site.
As residents who are deeply rooted in our hometowns – personally, professionally, financially, and historically – our voices of opposition should be heard in contrast to the developer, who wants to come to Rhode Island from New Jersey to bring technology from South Africa that is previously untested on medical waste. Those of us who live in East Greenwich, including several neighborhoods that would be directly impacted by emissions from this facility, feel particularly disenfranchised by this ostensibly democratic process. Given that the facility’s driveway and access roads are actually in East Greenwich, as Rep. Justine Caldwell has stated, East Greenwich “will have the emissions … and the questionable material being brought into the area without anyone on the receiving end ensuring that it is safe and that its contents are what it purports to be. It is unconscionable that our town leaders would have no standing in this matter when the abutting properties are in East Greenwich.”
We encourage DEM to apply the Precautionary Principle, an established tenet of environmental law, to this decision. Since pyrolysis has never been used to treat medical waste, the true risks are currently unknown. The residents of West Warwick and East Greenwich do not consent to our children, our families, and our neighborhoods being used as guinea pigs for an untested technology, which could cause unknown harm. What happens if there is a malfunction, an accident, a fire, or unpredictably harmful emissions from this plant? How do you reverse that damage? Once the children at the two nearby daycares are exposed to lead from the MedRecycler facility, how do you undo that harm? The answer is: it is impossible. Therefore, DEM should err on the side of caution to protect human health and the environment. “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public, should bear the burden of proof. The process of applying the precautionary principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action.” – Wingspread Statement on the Precautionary Principle, 1998
The fact is, there is nothing “green” or “recycled” about MedRecycler. Pyrolysis is barely distinguishable from a medical waste incinerator with a green-washed name, and medical waste incinerators are notoriously toxic, polluting facilities that are inconsistent with residential communities. This is the definition of regulated medical waste:
- Pathological waste. Tissues, organs, body parts, and body fluids removed during surgery and autopsy.
- Human blood and blood products. Waste blood, serum, plasma and blood products.
- Cultures and stocks of infectious agents (microbiological waste). Specimens from medical and pathology laboratories. Includes culture dishes and devices used to transfer, inoculate, and mix. Also includes discarded live and attenuated vaccines.
- Contaminated sharps. Contaminated hypodermic needles, syringes, scalpel blades, Pasteur pipettes, and broken glass.
- Isolation waste. Generated by hospitalized patients isolated to protect others from communicable disease.
- Contaminated animal carcasses, body parts and bedding. From animals intentionally exposed to pathogens in research, biologicals production, or in vivo pharmaceuticals testing.
Especially now, in the age of super-infectious COVID-19, these are not appropriate materials to import to this site. On the same January 25 call, Mr. Campanella admitted that he plans to start by processing 70 tons of medical waste/ day, but he chose this site partly because he can expand in the same building to accept up to 140 tons/ day. Industrial facilities are as imperfect and fallible as the humans who manage them. They malfunction, have accidents and do not always perform as planned. With the predicted volumes of hazardous waste, even small accidents can have a big impact on the surrounding community. We are concerned about machine malfunctions, accidents, spills, fires, toxic emissions, worker safety, first responder safety, environmental harm (air, water, wildlife and ecosystems), and the health of all of the people who live and work near or downwind of this site.
Rhode Island’s medical waste regulations germane to pyrolysis (specifically sections 250-RICR-140-15-1.F.5.a(3) and (4) concerning the approval of “Alternative Technologies”) require that for DEM to approve any alternative technology to treat medical waste, the technology must be “proven, on the basis of thorough tests to: . . . (3) Be protective with respect to total impact on the environment; and, (4) Ensure the health, safety and welfare of both facility employees and the general public.” MedRecycler — with so many unknowns about the technology itself, combined with the unquestionably hazardous nature of the materials being treated — clearly does not come close to reaching that bar.
Furthermore, we want to stress that our opposition to this facility does not rest on the “Not In My
Back Yard” theory of local protectionism. Rather, this facility does not belong in anyone’s
backyard. Zooming out from the local perspective to a statewide, national, and even global view,
the facts are clear that our state, nation and world are experiencing a climate crisis. It is long past time to reject the polluting technologies of the past, such as burning plastics and other wastes that contribute to climate change, and look to a truly greener future. In fact, Rhode Island is in the midst of debating whether to strengthen our greenhouse gas emission limits with the new Act on Climate bill, currently pending in the legislature. In her recent State of the State address, Governor Raimondo said, “Rhode Islanders can be proud that we are the state leading the nation in the fight against climate change.”
Rhode Islanders are justifiably proud of our beautiful coastal environment, and in this small state, we care deeply about the well being of our neighbors. Therefore, we ask DEM to prioritize the health and environment of Rhode Island families over the profits of this speculative developer, and deny any permits for MedRecycler.
Katie Silberman lives in East Greenwich and is working with a coalition of EG and West Warwick residents — more than 1300 of whom have signed onto this letter — to oppose MedRecycler. To learn more or sign the letter, please contact: [email protected]