Health Impact Assessment

Downloads

The Chicago Department of Public Health’s complete Health Impact Assessment (HIA) Report on Reserve Management Group’s (RMG) application for a permit to operate a metal recycling plant is available below. 

Over the past two years, CDPH collected, analyzed, and interpreted data from a variety of sources to evaluate the current conditions and potential impacts – both positive and negative – of the proposed RMG/Southside Recycling facility. CDPH made numerous site inspections and collected thousands of public comments on the proposed facility. The work from the process is detailed in the report, its appendices, and related materials. 

Summary Report and Appendices

CDPH and its environmental consultant, Tetra Tech, with direction from EPA, prepared a comprehensive inventory of emission sources, calculated potential emissions, modeled air dispersion and deposition of contaminants, and conducted on-site soil sampling, then used this information as inputs for a risk model. These data allowed us to characterize existing site conditions and predict how the proposed Southside Recycling operations – together with current RMG business operations on the property – would affect community health risks. The resulting 509-page report can be viewed here: 

Chicago Department of Public Health Denies
RMG/Southside Recycling Permit Application to Operate a Recycling Plant on the Southeast Side

Cites concerns for health, environment and quality of life, as well as compliance issues uncovered during rigorous Health Impact Assessment process 

CHICAGO – The Chicago Department of Public Health (CDPH) announced today that it has denied RMG’s permit application to operate a scrap metal recycling facility on Chicago’s Southeast Side. CDPH found the potential adverse changes in air quality and quality of life that would be caused by operations, and health vulnerabilities in the surrounding communities - together with the company's track record in operating similar facilities within this campus - present an unacceptable risk. The announcement follows the third and final community engagement session held on Tuesday night as part of an eight-month Health Impact Assessment (HIA) that was recommended and guided by the U.S. Environmental Protection Agency (U.S. EPA).  

The HIA found that certain census block groups in the Southeast Side community rank among the highest in Chicago for vulnerability to air pollution, based on underlying health and social conditions. Further, the Southeast Side population has higher rates of chronic conditions such as coronary heart disease and COPD in adults than Chicago overall. The HIA also found that community conditions on the Southeast Side have been affected by the presence of past and current industry and that the proposed Southside Recycling facility would contribute additional negative impacts to the environment, health, and quality of life for area residents. 

CDPH regulations require that a company’s compliance history be considered as part of its review of any recycling permit application. Through the HIA process, CDPH officials discovered apparent instances of RMG’s non-compliance with City health and environmental regulations and existing requirements. This included failure to obtain necessary permits for foundry sand operations, as well as exceeding permitted capacity for other approved operations. In addition, the HIA assessment cited RMG’s lack of transparency and responsiveness, such as not reporting an April 2021 building collapse on the site and related failure to properly maintain asbestos-containing materials. 

“We are committed to protecting and enhancing the health, environment, and quality of life for all Chicagoans. In an already vulnerable community, the findings from the HIA combined with the inherent risks of recycling operations and concerns about the company’s past and potential noncompliance are too significant to ignore,” said CDPH Commissioner Allison Arwady, M.D.  

While RMG can continue to conduct the other appropriately permitted businesses on its site, the City’s permit denial means that RMG cannot operate the Southside Recycling facility. As with all permitted businesses, CDPH will continue to monitor RMG’s operations and ensure they are in compliance with existing permits.    

This HIA is the most rigorous and comprehensive study of a proposed industrial facility in Chicago to date. In this case, an HIA was necessary in part because of the size and nature of the proposed recycling facility, and the fact that public health considerations raised during the permitting process had not been fully addressed during zoning.  

Although this level of impact assessment would not be required for existing businesses, the City will continue to strengthen its regulations to protect the public from adverse impacts of industrial operations. Arwady emphasized the City’s recent transformational work to expand, enhance and enforce its regulations to promote health and racial equity alongside economic development. These include:   

  • A recent Air Quality Zoning ordinance that requires large industrial zoning applicants to submit an air quality impact study and get a written recommendation from CDPH and the City Department of Transportation as a condition for site plan approval. This has already addressed a gap in the zoning process that was highlighted through the RMG/Southside Recycling permit application review.  
  • Rules for large recyclers that impose extensive requirements for continuous air monitoring, dust and pollution controls, stormwater pollution prevention, and full enclosure of shredding and waste.   
  • Specific rules for control of emissions from handling and storing bulk materials and increased environmental fines to address violations of air pollution, fugitive dust and demolition ordinances.  

Later this year, CDPH plans to finalize new rules that require enhanced environmental controls for rock crushers. In addition to these important steps, the HIA includes recommendations to increase monitoring, enforcement and environmental protections for the Southeast Side; enhance the City's use of health and racial impact assessments, as well as ongoing community engagement; and embed cumulative impact principles in zoning, permitting and enforcement.   

“The larger picture here is making sure that our policies balance the City’s economic development interests with public health protections,” said Arwady. “Chicago has already taken important steps in this direction with the Air Quality Zoning ordinance. The HIA identifies other policy and process changes that we will work to advance with other public agencies, as well as industry and community partners.” 

The HIA summary report is available on the CDPH website. By the end of February, it will be updated to include appendices and final data. A Spanish version of this release is also available on that web page.  

February 15, 2022

CDPH Statement: Final RMG/Southside Recycling HIA Community Meeting

Tonight, the Chicago Department of Public Health (CDPH) hosted the third and final community engagement session as part of the Health Impact Assessment (HIA) related to the RMG/Southside Recycling application for a permit to operate a scrap metal recycling facility on Chicago’s Southeast Side. The HIA has been conducted collaboratively with the U.S. EPA.

During tonight’s session, CDPH officials and representatives from its environmental consultant Tetra Tech provided an overview of the potential environmental and health impacts associated with RMG’s current and proposed operation on the Southeast Side. Beyond the pending RMG permit decision, CDPH also discussed other policy and process changes it will implement to improve environmental protections for the Southeast Side and other vulnerable communities.

The findings from the completed HIA will guide our RMG/Southside Recycling permit decision. We expect to announce that decision by the end of this week.

Factors influencing this decision will include: 

  • Current community burden and vulnerability

  • Potential benefits to Southeast Side residents

  • Potential negative impact on environment, health and quality of life that cannot be adequately addressed through mitigations

  • Actions of the company to-date, including compliance history

Engaging the community has been a top priority of this process from the beginning. CDPH has been listening to community voices and concerns regarding this permit for well over a year. This has included convening multiple town hall meetings, ongoing meetings with local stakeholders, systematic review of thousands of public comments and daily social media monitoring.

CDPH will complete and publish the HIA summary report by the end of the week and in the coming weeks, it will be updated to include appendices, including the full data and documentation of the environmental and health risk assessment, community input analysis, and an additional analysis by the federal Agency for Toxic Substances and Disease Registry (ATSDR). Once completed, the HIA will be the most rigorous and comprehensive study of a proposed industrial facility in Chicago to date.

Our thanks go out to everyone who took part in these community meetings. 

CDPH has a longstanding history of promoting health and racial equity in the City of Chicago. CDPH is deeply committed to healthy communities, protecting vulnerable populations and pursuing equitable policies.

 

Downloads:

Final Community Engagement Session for RMG HIA to be Held Feb. 15

The third and final community engagement session as part of the Chicago Department of Public Health’s (CDPH) Health Impact Assessment (HIA) related to the RMG/Southside Recycling application for a permit to operate a recycling facility on Chicago’s Southeast Side will be held on Tuesday, February 15 from 5:30-7:00 p.m.

This session will be conducted via Zoom as a public health precaution given ongoing concerns about the COVID-19 pandemic. People interested in participating in this virtual session can register here. Spanish language translation will be provided.

This session was originally intended to be held in late January but was delayed by a COVID outbreak among the team assisting with on-site research and COVID-related lab slowdowns. The February 15 session was scheduled based on input from community members and stakeholders to avoid conflicts with other events occurring on the same date and to ensure more than two weeks’ advance notice to facilitate participation by all who wish to join.

In the February 15 session, CDPH officials and representatives from our environmental consultant (Tetra Tech) will review the HIA assessment methodology and present an analysis of the potential environmental and health risks associated with RMG’s current and proposed operation on the Southeast Side. The session will include a question-and-answer opportunity.

CDPH is working to complete a final report detailing the HIA process, findings and community input. We expect to make a decision about the RMG/Southside Recycling permit after this final HIA community engagement session.

HIA Sessions: Additional Background

The first HIA session, held on November 4, informed community members and stakeholders about the RMG/Southside Recycling proposal, HIA process, and existing conditions on the Southeast Side. The second session on December 9 solicited direct input from community members on the potential benefits and burdens of the proposal, which CDPH used to scope the assessment.

Engaging the community has been a priority for CDPH from the beginning of the RMG/Southside Recycling permitting process. To ensure that every community member who wants to share feedback or concerns has an opportunity to do so, CDPH has been listening to community voices around this scrap metal recycling permit for well over a year, including convening multiple town hall meetings, systematic review of thousands of public comments, daily mainstream and social media monitoring, and ongoing meetings with local stakeholders.

The HIA process has been a collaborative process with the U.S. EPA. It takes an intensive look at RMG’s existing operations, site conditions and activities associated with the proposed future operations, and employs a methodology that fully considers existing health factors specific to the surrounding community. Once completed, it will be the most rigorous and comprehensive study of a proposed industrial facility in Chicago to date.

The City of Chicago is committed to environmental justice and has been and will continue to be steadfast in our mission to protect public health, particularly among residents of vulnerable communities.

 Download the Spanish-language notice for the Final Community Engagement Session for RMG HIA

Health Impact Assessment Public Engagement Session #2 - 12/09/2021

On Thursday, Dec. 9, Southeast Side residents and other key stakeholders participated in a Health Impact Assessment (HIA) public engagement session with CDPH. The insights shared in this meeting are a direct input into the HIA and will inform our recommendations.
Meeting materials including slides, the session recording, and Jamboards created to capture points made in the breakout groups are posted here.
For anyone who was unable to attend the meeting and would like to answer the questions we discussed, we invite you to complete a brief survey: https://www.chicagohan.org/. The survey closes on Thursday, December 23rd, 2022.

Our final HIA meeting will be held in January.

Health Impact Assessment Public Engagement Session #1 - 11/04/2021

We held our first public engagement session on the Health Impact Assessment of RMG/Southside Recycling on November 4, 2021 from 5 to 7 p.m.. View materials shared before and during the meeting below.