Trump: A Disaster for Health,Safety,and Environment

Abstract

^*Editor's note: The opinions expressed herein are entirely my own and not those of any entity or organization to which I may be affiliated

On November 5, 2024, Donald J. Trump was elected President of the United States for the second time. He has been described in NEW SOLUTIONS as a “demagogue, authoritarian president” whose ideology is neofascism.¹ The threat to democracy from President-elect Trump is real and serious, as evidenced by the events of January 6, 2021, and the statements of many who worked for him during his first term; it has been discussed in many other places and will continue to be. This editorial will focus on Trump's threat to health, safety, and the environment. The threat is very well summarized in James Goodwin's review² of “Demolition Agenda” by Thomas McGarity³:

[A]ttacking the regulatory system was an all-consuming, all-hands-on-deck obsession of the Trump administration. The dazzling array of strategies, the comprehensive scope, the unmitigated shamelessness—all of it is still breathtaking to reflect upon, especially for those who were in the trenches trying to fight back…

In February 2017, shortly after Trump was inaugurated, Levenstein and Siqueira⁴ offered NEW SOLUTIONS’ first discussion of the threat he posed to health safety and the environment. At that time, they noted that Trump had proposed handing leadership of the Environmental Protection Agency (EPA) to Scott Pruitt, who had consistently sided with the fossil fuel industry as attorney general of Oklahoma and who was on record as a climate change denier. The Occupational Safety and Health Administration (OSHA) had been barred from proceeding with worker protection activity and the National Institute for Occupational Safety and Health had been prohibited from publishing anything relevant to workplace regulation. The words “climate change” had been struck from the Federal Government lexicon and the Trump Administration had withdrawn federal support and participation from a long-anticipated conference on the public health effects of climate change.

In a June 2017 NEW SOLUTIONS editorial, Levenstein et al.¹ observed that Trump's Department of Labor announced a delay in the Beryllium Rule and blocked the Fair Pay and Safe Workplaces Rule, which would have required prospective federal contractors to disclose labor law violations, including health and safety violations, so that the most egregious violations could be taken into account in making contracting decisions. The rule was designed to ensure that the worst actors, who repeatedly violated the rights of their workers and put them in danger, didn’t get federal contracts. In addition, Trump's Labor Department announced that it would delay implementation of the crystalline silica standard for the construction industry and of a rule for workplace examination of mines.

At the same time, Trump proposed to cut the budget of an EPA program aimed at providing clean, lead-free tap water in Flint, Michigan, where corruption and systemic racism had resulted in regulatory neglect, leading to contamination of the city's water supply. Trump further proposed to cut funding for programs related to criminal and civil enforcement of environmental laws and regulations, Superfund and Brownfields, endocrine disruptors, climate protection, vehicle and fuels standards, radiation preparedness, and grants related to nonpoint pollution sources.¹

In a September 2018 NEW SOLUTIONS editorial,⁵ Slatin commented on the Trump Administration's proposal to eliminate the requirement, issued by the Obama Administration, for electronic submission to OSHA of injury and illness records already collected by employers. The Obama OSHA Electronic Recordkeeping Rule had been established to help OSHA and the workplace safety and health community better determine why workers get hurt on the job and how to protect them more effectively. The Trump Administration, however, claimed that the information, if maintained electronically by OSHA, would potentially place employee privacy at risk. This claim was simply false because the Obama Administration had been careful not to require the electronic submission of information that would potentially place employee privacy at risk.⁶ What the Trump Administration really sought to protect was the safety reputation of employers. Eventually, the Trump Administration did repeal the rule, but it was later restored by the Biden Administration. It will likely come under threat again in the coming Trump Administration.

While insisting that the only way to protect workers’ privacy was to prevent OSHA from making injury and illness data public, the Trump Administration simultaneously proposed a “Transparency in Science” rule to require that data used to support EPA standards be made public as a condition of their use in the administrative record, even if this placed the privacy of research subjects at risk. Since scientists and the institutions that employ them are required to protect privacy as a condition of receiving Federal funding, this proposed rule was clearly intended to make it nearly impossible to use any human subjects research in support of EPA regulations. Hence, the Trump Administration was speaking out of both sides of its mouth. It asserted that privacy was of paramount value when it sought to protect employers’ reputations. Then when seeking to restrict the use of scientific studies to support EPA regulations, it asserted that transparency was of paramount importance, even at the expense of privacy. The “Science Transparency” rule would be put into effect by the first Trump Administration in January 2021 and repealed by the Biden Administration the next month.

The rule was again discussed in NEW SOLUTIONS, in August 2022, when James Goodwin reviewed² “Demolition Agenda” by Thomas McGarity.³ Goodwin observed that what made this rule so pernicious is that it sounds reasonable and desirable on its face, when in reality, it would have prevented the EPA from considering studies that have long provided the scientific underpinning for many of its most important public health safeguards. Without such studies, the Agency would likely have to abandon many of its rules aimed at limiting emissions associated with fossil fuel combustion or settle for much weaker versions of those rules. For example, the EPA particulate matter (PM) rule, which has saved thousands of lives, is heavily dependent on human subjects research such as the Harvard “Six Cities” study.⁷

Goodwin reports that, according to McGarity, the “Science Transparency” Rule was just one example of “sophisticated sabotage.” Another example was a drastic reduction in the “social cost of carbon,” which represents an attempt to monetize the climate harm caused by each additional ton of carbon dioxide emitted. The benefits of climate change regulations are measured by adding up the value of each ton of carbon prevented. A higher social cost of carbon would justify stronger and more expensive climate action. In an effort to block climate regulations by his own Administration and to limit climate regulations by future administrations, Trump saw to it that the social cost of carbon was dramatically reduced from the $36 per ton value set during the Obama Administration to just $1.

Goodwin describes McGarity's discussion of the Department of Agriculture's proposal to eliminate line speed limits for industrial hog processing plants, which had long been capped at 1,106 hogs per hour. The rollback would have exacerbated existing safety concerns at these plants. In addition to high rates of musculoskeletal disorders, McGarity notes that “[o]n average, a worker on a meat preparation line somewhere in the United States suffers a lost limb or serious injury every two days.” In addition, most hog plant workers were “generally poorly paid, non-unionized immigrants….”³ who supported their families in rural communities. The hog-processing rule rollback was challenged in court as part of a coordinated advocacy campaign launched by a “coalition of food safety, work safety, and public interest groups… [A} federal district court in Minnesota reinstated the limitation on line speeds.” McGarity notes, however, that the federal judiciary now “includes 230 Trump-appointed judges.” Since the publication of McGarity's book, the courts have struck down the OSHA vaccine or test rule⁸ and Chevron deference.⁹ A future with a judiciary containing even more Trump appointments looks particularly bleak.

Goodwin describes McGarity's discussion of the Trump Administration's response to the COVID-19 pandemic, stating that OSHA “shirked its statutory responsibility to provide safe workplaces for the millions of employees who did not have the option of sheltering in place and telecommuting.” The Occupational Safety & Health Act of 1970 required OSHA to use “emergency temporary standards” (ETS) and/or the “general duty clause” to protect workers from COVID-19. Instead, OSHA rejected a petition for an ETS from labor unions, resorting to nonbinding, nonenforceable “guidance documents.” Moreover, the Agency refused to deploy routine enforcement to safeguard workers during the pandemic. During the last 11 months of the Trump administration, “OSHA received 57,000 complaints related to COVID-19 but inspected less than six percent.”

In a June 2022 opinion piece,¹⁰ Rabinowitz offered a similar opinion on the Trump Administration's refusal to issue an ETS for severe acute respiratory syndrome coronavirus-2 in the workplace. She states that the refusal allowed workplace outbreaks of COVID-19 to become commonplace, especially where people worked indoors and physically close to others. She further observed that we don't know how many workers got COVID-19, because Trump's OSHA told employers they were not required to record COVID-19 cases and refused to put in place any requirement for employers to report workplace COVID-19 outbreaks.

More on the Occupational Health and Safety Record of the First Trump Administration

All of the above is just what was observed and commented on in the pages of NEW SOLUTIONS. Regrettably, there is much more. To begin with, Trump never confirmed an Assistant Secretary of Labor to direct OSHA. The position was vacant from January through August 2017, December 2017 through January 2018, and June 2019 through the end of the Trump Administration. When it was not vacant, it was occupied by Acting Assistant Secretary Loren Sweatt, who was never confirmed by the Senate.¹¹

In his Blog Confined Space, Jordan Barab¹² summarized Trump's record on Occupational Health and Safety:

The Trump administration did not issue a single major workplace safety or health standard or regulation in its entire 4 years. Standards that were underway were set aside and ignored. Under Trump, OSHA canceled rules on styrene, combustible dust, and construction noise.

During the Trump administration, the number of OSHA inspectors fell to a historic low, despite adequate funding to hire more inspectors.

Faced with massive illness and death from COVID-19 in meatpacking plants, Trump declared meatpacking workers “essential” and forced them to remain at work, instead of requiring meatpackers to protect their employees. In addition, Trump colluded with the companies to whitewash health and safety investigations and recommendations and to issue penalties that were so vanishingly small, that they did not prevent employers from continuing to put their workers in harm's way.

During the first Trump Administration, the Republican Congress repealed an Obama Administration rule that had allowed OSHA to issue penalties for record-keeping violations that occurred more than 6 months before the citation. The Obama rule had restored the Agency's practice from its inception until 2012, when conservative judicial activists imposed their own policy preferences instead of adhering to the rule of law. One beneficiary of this action was Tesla Inc., which was caught leaving injuries off its OSHA logs more than 6 months prior.¹³

Trump's OSHA removed reports of workplace fatalities from its website.

The Trump Department of Agriculture helped increase hazards to workers by allowing poultry processing facilities to increase line speeds.

More on the Environmental Record of the First Trump Administration

The first Trump Administration was a disaster on the environmental side in more ways than documented in NEW SOLUTIONS and discussed above. The New York Times identified more than 100 environmental rules that Trump reversed, revoked, or otherwise rolled back in his first administration.¹⁴ These rollbacks weakened Obama Administration limits on planet-warming carbon dioxide emissions, removed protections from more than half the nation's wetlands; and withdrew the legal justification for restricting mercury emissions from power plants. The first Trump Administration's deregulatory actions were estimated to increase greenhouse gas emissions substantially over the next decade and lead to thousands of extra deaths from poor air quality each year. Some of the first Trump Administration's most important environmental actions were:

Withdrawing the United States from the Paris Climate Agreement and weakening regulations of greenhouse gasses by—

prohibiting the regulation of greenhouse gas emissions from sources representing <3% of total U.S. greenhouse gas emissions, which effectively exempted oil and gas production facilities;

weakening Obama-era fuel economy and greenhouse gas standards for passenger cars and light trucks;

repealing rules meant to reduce the leaking and venting of powerful greenhouse gasses known as hydrofluorocarbons from large refrigeration and air conditioning systems; and

revoking an Obama executive order that set a goal of cutting the federal government's greenhouse gas emissions by 40% over 10 years.

Rejecting a proposed ban on chlorpyrifos, which is linked to developmental disabilities in children.

Reducing or eliminating regulation of—

sites that store and use hazardous toxic inhalable, flammable, or explosive chemicals;

toxic emissions from major industrial polluters;

releases of volatile organic compounds;

pollution from power plants;

pollution from sewage treatment plants;

pesticide application buffer zones to protect farmworkers and bystanders;

copper filter cake, an electronics manufacturing byproduct containing heavy metals;

burning waste coal for electricity; and

ozone pollution from upwind states to downwind states.

Reversing Obama rail safety rules to—

Eliminate a requirement for braking system upgrades to “high hazard” trains. (Note: The train that crashed in East Palestine, OH did not have an upgraded braking system as would have been required if the rule had remained in place).

Allow previously prohibited rail transport of highly flammable liquefied natural gas.

Reducing regulation of tailpipe emissions by—

revoking California's authority to set stricter tailpipe emissions standards than the federal government;

repealing a requirement that state and regional authorities track tailpipe emissions from vehicles on federal highways; and

lifting a summertime ban on the use of high-ethanol gasoline, which contributes to smog.

Changing the conduct of cost–benefit analyses under the Clean Air Act to make it harder to issue new public health and climate protections.

Limiting funding of environmental and community development projects through corporate settlements of federal lawsuits.

What We Might Expect in the Second Trump Administration

The second Trump Administration promises to be even worse than the first. On November 12, 2024, Trump issued the following statement on Truth Social:

I am pleased to announce that the Great Elon Musk, working in conjunction with American Patriot Vivek Ramaswamy, will lead the Department of Government Efficiency (“DOGE”). Together, these two wonderful Americans will pave the way for my Administration to dismantle Government Bureaucracy, slash excess regulations, cut wasteful expenditures, and restructure Federal Agencies… “This will send shockwaves through the system, and anyone involved in Government waste, which is a lot of people!” stated Mr. Musk.

… To drive this kind of drastic change, the Department of Government Efficiency will… create an entrepreneurial approach to Government never seen before…¹⁵

The post announced Trump's plans to go ahead with the stated intent to deconstruct (or take a wrecking ball) to the regulatory state. As noted above, Elon Musk who, as CEO of Tesla has been caught falsifying his OSHA injury and illness logs, will be put in a position to determine what kind of authority OSHA has to enforce its recordkeeping requirements.

In addition, Project 2025, a transition document prepared by the Heritage Foundation, offers a detailed description of Trump's plans to take a wrecking ball to EPA as part of his larger plan to “deconstruct the regulatory state.”¹⁶ The Center for American Progress (CAP) examined Project 2025 and found that its deregulation agenda would cripple the nation's ability to understand, monitor, and mitigate Americans’ exposure to environmental toxicants. CAP found that Americans’ health and lives would become collateral damage to corporate profits.¹⁷ CAP says that reversing regulations would rob Americans of their fundamental rights to breathe clean air and drink safe water. Specifically, Project 2025 would:

Hinder the EPA's enforcement of laws that protect human health and the environment and improve U.S. climate resilience, such as the Clean Air Act, Clean Water Act, and the Safe Drinking Water Act. It will do so by eliminating the Office of Enforcement and Compliance Assurance.

“Pause and review” major rules and guidance that protect the environment and public health. Here are some examples of protections that might be weakened or eliminated:

EPA's new rule on PM, a product of fossil fuel combustion. If allowed to stand, the new limit would prevent up to 4,500 premature deaths, 5,700 new cases of asthma, 2,000 emergency room visits, and 290,000 lost workdays.

Regulation of per- and polyfluoroalkyl substances contaminants in drinking water to reduce exposure for up to 105 million people, preventing at least 9,600 deaths and 29,900 cases of illness including developmental and cardiovascular issues, kidney cancer, and bladder cancer.

A proposal to replace lead service lines (LSLs) in water systems serving 9.2 million homes within 10 years. LSLs are found disproportionately in low-income communities and communities of color.

Perpetuate environmental and health disparities by dissolving the Office of Environmental Justice and External Civil Rights. This would threaten $2.7 billion in Inflation Reduction Act funding intended to tackle environmental injustices, as well as more than $50 million in grant funding for community-based organizations and organizing efforts to clean up pollution in front-line communities.

Ban cumulative impact analysis under the National Environmental Policy Act. Cumulative impact analyses address the combined effects of exposure to stressors such as pollution, extreme weather, and economic inequality.

Reject all research and science activities under the Office of Research and Development, which are not explicitly authorized by Congress, such as the IRIS Program which conducts hazard and dose-response assessments that inform EPA regulations.¹⁸

In sum, the first Trump Administration launched a major assault on the health and safety of American workers, communities, and the environment. This was well documented in the pages of NEW SOLUTIONS and elsewhere. Both Project 2025 and the statements made by Trump since the election indicate that the second Trump Administration promises to be even worse. Worker and Environmental Justice advocates have no choice but to fight back vehemently. To do so, invested stakeholders should continue to use time-tested organizing strategies. In addition, it is necessary to identify trusted messengers among workers and within communities to develop and deliver communications that will increase people's understanding as to how they are harmed by these policies. We must identify new allies and build a broad coalition to protect worker health and environmental justice from the coming onslaught.

Footnotes

Declaration of Conflicting Interests

The author declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author received no financial support for the research, authorship, and/or publication of this article.

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