top of page

Santa Clara Law Review


DON’T BREATHE IN: THE DANGERS OF SSM EVENTS AND WHY REPEALING AFFIRMATIVE DEFENSES FALLS SHORT
From the Louisiana and Texas Gulf coasts to Wilmington, California, communities face disproportionately high cancer risks linked to excess hazardous emissions. This article examines the longstanding regulatory gaps that allow industrial facilities to emit excess levels of hazardous air pollution during startup, shutdown, and malfunction (SSM) events. Despite the Clean Air Act’s enacted framework for controlling emissions, the EPA has created exemptions and affirmative defense
Gillian Spring
bottom of page