NEJAC RECOMMENDATIONS SUMMARY

The document outlines four core principles for the EPA to implement cumulative impact assessments: decreasing disproportionate burdens through distributive and restorative justice, expanding beyond traditional risk assessments to include social determinants of health, accounting for historical burdens, and adopting a precautionary approach that shifts the burden of proof to regulated actors.

• The NEJAC argues that regulators must use all available legal authority, including the Civil Rights Act and various Presidential Executive Orders, to address the disproportionate cumulative burdens faced by people of color, Indigenous people, and low-income households. It emphasizes that these assessments should be used for regulatory decision-making rather than just research and must not replace robust compliance and enforcement.
• Traditional risk assessments are criticized for being too narrow and biased toward protecting healthy adults because they rely on controlled exposures to healthy animals or working populations. The NEJAC recommends expanding these frameworks to include social determinants of health and the impacts of racism and colonialism, which were not addressed in the EPA's 2003 Framework for Cumulative Risk Assessment.
• To achieve justice, the EPA should evaluate the historical repercussions of past projects and programs rather than focusing solely on current or future exposures. This requires modifying uncertainty factors and incorporating qualitative data, such as lived experience and local community science, which are typically dismissed in traditional risk assessments.
• The NEJAC recommends a precaution-based approach to scientific uncertainty, shifting the burden of proof from the regulator to the regulated actor. Under this model, the entity proposing a project or chemical must prove it is safe before approval, rather than the regulator proving it is harmful.

APA

Gehred, N., & Ellickson, K. (2025). NEJAC RECOMMENDATIONS SUMMARY. Union of Concerned Scientists. https://www.ucsusa.org/sites/default/files/2025-02/NEJAC%20CI%20reccs_theme%201.pdf

Chicago

Gehred, Natalie, and Kristie Ellickson. NEJAC RECOMMENDATIONS SUMMARY. Union of Concerned Scientists, 2025. https://www.ucsusa.org/sites/default/files/2025-02/NEJAC%20CI%20reccs_theme%201.pdf.

Wikipedia

{{cite report |last1=Gehred |first1=Natalie |last2=Ellickson |first2=Kristie |title=NEJAC RECOMMENDATIONS SUMMARY |publisher=Union of Concerned Scientists |date=February 2025 |url=https://www.ucsusa.org/sites/default/files/2025-02/NEJAC%20CI%20reccs_theme%201.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{gehred2025nejac, author = {Gehred, Natalie and Ellickson, Kristie}, title = {{NEJAC RECOMMENDATIONS SUMMARY}}, institution = {Union of Concerned Scientists}, year = {2025}, month = feb, url = {https://www.ucsusa.org/sites/default/files/2025-02/NEJAC%20CI%20reccs_theme%201.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }