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ToxStrategies at the Forefront: Environmental Justice and Cumulative Impact Assessment

EPA recognizes that there are environmentally related health inequities in certain communities, exacerbated by socioeconomic and psychological stressors, background health conditions, and ethnicity-specific susceptibilities. Environmental justice initiatives are intended to address the history of disproportionate exposure and proximity to environmental hazards in these communities. EPA and other federal and state agencies are in the process of developing and using various approaches, methods, and data to achieve a Cumulative Impact Assessment (CIA) for the environmental exposures that incorporates some measure of the additional stressors. These activities are happening at a rapid pace at various levels of government, and there is no uniform approach at this time.

In January 2023, the Office of General Counsel of U.S. EPA issued “EPA Legal Tools to Advance Environmental Justice: Cumulative Impacts Addendum” (1). In this document, EPA asserts its authority to “protect human health and the environment for all people, regardless of race, color, national origin, limited English proficiency, disability, sex, or income” by requiring that cumulative impacts affecting communities with environmental justice concerns be addressed explicitly in all federal and state programs that receive federal funding. EPA’s Office of Research and Development (ORD) defines “cumulative impacts” as “the totality of exposures to combinations of chemical and non-chemical stressors and their effects on health, well-being, and quality of life outcomes“ and lays out a strategy of research to develop methods and data to support cumulative impact assessments (2).

ToxStrategies is working actively on cumulative impact assessment for vulnerable populations. This includes comprehensive evaluations of the state of science on quantitative CIA methods for vulnerable and susceptible populations that are subject to EJ concerns, development of methods to account for allostatic load from non-chemical stressors, and epidemiological studies of health impacts to vulnerable communities. At the 2022 annual meeting of the Society of Environmental Toxicology and Chemistry (SETAC), Dr. Bill Rish, of ToxStrategies, and Dr. Chris Frey, of EPA’s ORD, co-chaired a session on “Data and Methods to Support Cumulative Risk and Impact Assessments.” This discussion built upon the session, “Environmental Justice: Methodologies to Incorporate Environmental Justice into Human Health Risk Assessment” from the 2021 SETAC annual meeting, also chaired by Dr. Rish. At the annual meeting of the Society for Risk Analysis (SRA) in December 2022, ToxStrategies presented a workshop on behalf of SRA’s Justice, Equity, and Risk Specialty Group on “Approaches to Assessing Environmental Justice: Perspectives from the Scientific, Regulatory and Regulated Communities.”

More information on ToxStrategies’ services related to cumulative impact assessment and environmental justice can be found at this link or by contacting Dr. Bill Rish at or (614) 204-6467.



(1) EPA Legal Tools to Advance Environmental Justice: Cumulative Impacts Addendum. Office of General Counsel, U.S. Environmental Protection Agency. Washington, D.C., January 2023.
(2) Cumulative Impacts: Recommendations for ORD Research. U.S. Environmental Protection Agency. U.S.EPA/600/R-22/014F. September 2022.