Comment submitted by Aditi Vig

$340 billion is the economic burden of cost for endocrine disrupting chemicals (EDC’s) solely in the United States. In Europe, the cost is $217 billion comparatively. This economic concern translates into an environmental health problem when polybrominated diphenyl ethers (PBDE’s) enter the human body which may lead to intellectual disability (Attina et al., 2016). One of the ways that PBDE’s are leached into the environment is through the improper disposal of e-waste. Allowing Alaska to adopt its own “authorized hazardous waste program” will help limit toxic exposure from PBDE’s to the Alaskan population. Currently, Alaska does not have a state-authorized hazardous waste disposal program. Hazardous waste in Alaska is overseen by federal regulations and the Environmental Protection Agency (EPA). I am asking the EPA to realize that the addition of a hazardous waste disposal program at the state level will still allow the agency’s oversight. The proposal submitted by Alaska includes policies that will be just as rigorous, if not stricter, as federal regulations. If the EPA approves Alaska’s application for authorization, it will be easier for rural communities in Alaska to recycle e-waste. In my opinion, e-waste should be considered in the hazardous waste category instead of solid waste because the potential negative health impacts are too detrimental to exposed populations. This issue is relevant to my field of study because as a Public Health major, I am interested in learning about how new regulations, like the one proposed, serve to address environmental health problems to improve health outcomes. From my understanding, the rule is set to determine whether hazardous waste management will primarily be managed on a state or federal level. Human exposure to PBDE's are known to cause negative health effects on the liver, thyroid, endocrine, immune and reproductive systems (Gao et al., 2024). Humans are exposed to this group of toxic substances when e-waste, like computers, are improperly disposed of into the environment. Over time, PBDE’s found in electrical appliances leach out into the surrounding environment, leaving populations exposed to these chemicals. Expanding the oversight of hazardous waste to rural populations in Alaska will go a long way to keep Alaskans healthy by keeping the negative health effects associated with toxic exposure from PBDE’s at a minimal level. I ask the EPA to consider: how can PBDE exposure lead to liver toxicity? This is by causing activated cell death, or apoptosis, which compromises the functioning of the organ and alters its structure. Some background information regarding the biological mechanism of action for apoptosis, or exactly how cell death occurs in the human body on a cellular level. Mitophagy stress inhibits the functioning of mitochondria when micro RNA cannot do their part. Mitophagy is when mitochondrial waste or damage is broken down by the cell itself (Um & Yun, 2017). Proteasome dysfunction affects the functioning of the mitochondria by way of mitophagy defects (Zhang et al., 2015). These defects result in oxidative stress as the free radicals and antioxidants are imbalanced in the body. This imbalance is what leads to apoptosis. I urge the EPA to consider this proposal given the detrimental effects of liver toxicity. This will protect rural populations in Alaska from exposure to toxins expelled from PBDE’s. Research provides yet another reason to consider proper management of e-waste disposal: “Inhabitants and workers living near e-waste recycling sites can be exposed through inhalation, ingestion, and dermal absorption when they come into physical contact with contaminated soil, dust, air, water, or food sources (Parvez et al., 2021).” This quote sheds light on the importance of effective hazardous waste management so that humans are not exposed to dangerous chemicals. Here many environmentalists would probably object that the disposal of “refrigerators, freezers, stoves, dishwashers, washers, or dryers” will not be included in the proposal. Especially given a whole new set of toxins that people can be exposed to including mercury. However, I would like to point out that under 40 CFR Parts 273, 279, and 761, hazardous toxins like mercury are required to be removed from the appliance before it is disposed of as per federal mandate. As a result, their disposal into the environment subdues the negative health consequences. As a result, PBDE exposure still remains a major concern for e-waste disposal. My strong recommendation to the EPA is that e-waste disposal should follow the procedure of hazardous waste rather than solid waste. The negative health outcomes of PBDE’s are too detrimental to ignore and implementing this recommendation will have economic benefit for the state of Alaska within the billions. Thank you for your time and consideration.