”A DUTY TO PROTECT“
DPH’s Emergency Preparedness Is Dangerously Outdated
Public Health Emergency & Response Plan (PHEPR) threatens the Health Department’s Reaccreditation in 2025
• • • • • • • • January 2025 • • • • • • • •
The capability of the public health systems, communities, and individuals, to prevent, protect against, quickly respond to, and recover from health emergencies, particularly those whose scale, timing, or unpredictability threatens to overwhelm routine capabilities." — Public Health Emergency Preparedness Tomas Aragon, MD, DrPH | Health Officer & Director, Population Health & Prevention - SFDPH
The photo above was captured on December 14, 2024, on Folsom Street in San Francisco. A Fire Department spokesperson told a local news channel, “We are seeing it throughout San Francisco … in the Avenues, Mission District and downtown San Francisco … Nobody has been immune.”
It is one in an archive of videos of damaged property and devastated holiday hope experienced by city residents in the aftermath of fierce storms this month, titled “San Francisco residents assess damage after storm brings fierce winds, tornado warning.”
San Francisco is surrounded on three sides by coastline, and the writing is on the sea wall. The City must fortify San Francisco’s Public Health Emergency Preparedness and Response (PHEPR). Its founding policy and directives need to be updated to incorporate predictions of climate change, sea level rise, extreme weather events, and chemical and radiological exposures for the whole community.”
“A 25 foot sea rise or 25 foot flood could happen in our lifetimes, especially if we lose Greenland or West Antarctica ice sheets.”
—Urban Life Signs
The best time to prepare for an emergency is before it happens. San Francisco is surrounded on three sides by coastline, and the writing is on the sea wall. The City must fortify San Francisco’s Public Health Emergency Preparedness and Response (PHEPR). Its founding policy and directives need to be updated to incorporate predictions of climate change, sea level rise, extreme weather events, and chemical and radiological exposures for the whole community.
The 10 Essential Public Health Services required for public health department accreditation by the Public Health Accreditation Board include assessment and monitoring of population health, utilization of legal and regulatory actions, and the investigation of health hazards and root causes.
The Population Health Division website defines a duty to “provide expert core public health services for people in the City and County of San Francisco.
These services include epidemiology and surveillance, health promotion, disease and injury prevention, disaster preparedness and response, applied research, as well as policy development and implementation.”
It surprised me, as a former physician specialist, to discover that population health is not solely a division of DPH. Population Health is a network of divisions that includes the Emergency Medical Services Agency, the Center for Data Science, the Community Health Equity & Promotion Branch, Public Health Emergency Preparedness & Response (PHEPR) and the Public Health Lab.
The Equity & Community Engagement Branch supports efforts to build relationships and partnerships with community members and organizations to ensure that services and programs are tailored to meet and support community health needs.” The Population Health Division was proud to co-sponsorBaySpark 2024 Igniting Youth Action for Climate and Environmental Justice.
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The Environmental Health Branch enforces over 50 Health Codes and Regulations. The most controversial is Article 31 of the Health Code. Article 31 is an Ordinance that permits DPH to collect revenue via the Master Developer for earth-moving activities at a Federal Superfund site.
In 2010, Mayor Gavin Newsom bypassed the Health Department to approve an Article 31 Amendment by the Board of Supervisors, allowing the City to capture revenue from the remediation of the entire base. Despite the COVID pandemic and construction shut-down, SFDPH generated over $120,000 in Article 31 revenue, channeled by Master Developer Lennar through the Office of Community Investment & Infrastructure. DPH does not use Article 31 funds for population monitoring and surveillance — as required by both the Population Health Division and the Public Health Accreditation Board.
Public Health Emergency Preparedness 2025
The Public Health Emergency Preparedness and Response Plan (PHEPR) was created in 2011 by Tomas Aragojn, MD, DrP, and Erica Pan, MD.
The 2011 PHEPR defines “all hazards” to include earthquakes and other natural disasters, oil spills, chemical and radiological discharges and bioterrorism:
“PHEPR serves the public, DPH, and partners by coordinating public health emergency preparedness, response, and recovery efforts. PHEPR promotes a culture of preparedness to ensure that in an emergency, disease and injury are prevented and accessible, timely and equitable health and clinical services are available.”
Today I call on Director Phillips for immediate action to address the systemic neglect, environmental injustice, and health disparities that have been too long ignored in Bayview Hunters Point.—Ann Colchidas”
PHEPR’s Inadequate Mission
Functions of PHEPR include:
* Focus on all-hazards public health preparedness and response planning for San Francisco.
* Ensure all populations are equally served.
* Work collaboratively with partners
* Integrate a culture of preparedness into everyday operations.
The 2011 PHEPR does not address projections of sea-level rise and extreme weather events evident in San Francisco this month nor following the stormy winter of 2023.
The PHEPR has not been implemented to conduct biosurveillance in investigating and identifying health threats occurring in San Francisco’s southeast sector - home to 14 Superfund sites and 442 polluting facilities, according to the EPA ECHO Enforcement & Compliance tool.
San Francisco experienced major earthquakes in 1906 and 1989. The 1906 earthquake registered 7.9 on the Richter scale. It destroyed most of the City, killing over 3000 people. — San Francisco: A City Subject to Natural Hazards; Alloprof
Additionally, the 2011 PHEPR fails to address mental health impacts experienced by trauma and disaster survivors.
On Monday, December 22, 2024, about 70. Miles south of San Francisco, three Santa Cruz residents survived the collapse of a wharf. Two people were rescued, and another swam to safety after part of the pier structure fell into the ocean. Although none were physically injured, all will require mental health and emotional support.
The outdated PHEPR and failure of DPH to update, circulate and implement it, compromises the Health Department’s reaccreditation standards, set by the Public Health Accreditation Board, under review for 2025.
Superfund threatened
Superfund: In the Eye of the Storm identifies the emerging threat to the Superfund program as the “economic storm” of corporate bankruptcies that allow polluting companies to avoid clean-up costs, leaving American taxpayers with an enormous bill funded entirely by taxpayer dollars.
The Center for Health, Environment and Justice was founded in 1981 by Lois Gibbs. CHEJ “mentors a national movement to build healthier communities by empowering residents to prevent harm caused by toxic chemical threats.”
As the primary organizer of the Love Canal Homeowners Association in 1978, Gibbs brought nationwide attention to the environmental crisis at the Love Canal toxic waste dump in Niagara Falls, New York, resulting in the evacuation of 833 families. Awarded the Goldman Environmental Prize in 1999, Gibbs’ efforts led to the creation of the US Environmental Protection Agency’s Comprehensive Environmental Response Compensation and Liability Act, or Superfund used to clean up toxic waste sites throughout the United States.
Superfund In the Eye of the Storm is a report by the Center for Health, Environment and Justice (CHEJ) that critically examines the Superfund program, which is responsible for cleaning up highly contaminated sites in the US. Superfund is facing a growing crisis due to the large number of newly identified contamination sites, legal challenges, and restricted funding. The Report emphasizes the need to reinstate the polluter pays principle within the Superfund program to prevent natural disaster sites from exposing adjacent communities to their contamination.
Illegal Dumping
Photo taken on January 4, 2023, by Shirletha Holmes Boxx, Hunters Point resident and Greenaction community organizer. The photo captures the entry to the Federal Superfund site at the Hunters Point Naval Shipyard in the aftermath of the 2023 Atmospheric Rivers. The 2022-2023 atmospheric rivers caused record-breaking amounts of rain, leading to extreme flooding, landslides, power outages, 21 deaths and over $3 billion in losses.
Situated across the street from a children’s playground at Crisp Road & Griffith, and 50 feet east of private homes, churches, public housing and the Oakdale community center, the photo documents the illegal dumping that occurs chronically at the Crisp Road main gate and the crucial observation that mud and debris - at the entry to the Parcel E-2 landfill (characterized in 2012 to contain radionuclides, PCB’s and asbestos) and the UC-3 roadway - site of Tetra Tech soil fraud - are seen contaminating the sewer system connecting with the City & County of San Francisco …and San Francisco Bay.
Despite the announcement of a settlement agreement between Tetra Tech and the Department of Justice, expected to be reached by December 31, 2024, compensation for thousands of plaintiffs will be complicated by a legal dispute with its insurance company.
According to the San Francisco Chronicle, in September 2024, Tetra Tech sued to hold its insurer AIG, responsible for costs for its defense and for damages in lawsuits brought by the Justice Department and the class action complaint brought by Bayview Hunters Point residents.
Ann Colchidas Testimony
In public comment, submitted on December 3, 2024, to the Population Health Hearing, Ann Colchidas of the San Francisco Gray Panthers wrote:
“Today I call on Director Phillips for immediate action to address the systemic neglect, environmental injustice, and health disparities that have been too long ignored in Bayview Hunters Point.
The BVHP community lives every day with the toxic legacy of the Hunters Point Naval Shipyard and the burden of industrial and abandoned sites polluting their bodies, air, soil, and water.
Residents are tired of siloed responses which ignore the cumulative impacts. They need you to listen, to act decisively and to address the cycle of harm and neglect that has perpetuated this crisis.
Listen to the experts in our community - organizations like the Hunters Point Community Biomonitoring Program, Marie Harrison Community Foundation, All Things Bayview, Greenaction and the historic Hunters Point Mothers & Fathers Committee. Allow data emerging from the community to guide you.
Now is the time for DPH to make a firm commitment to this neglected community.”
National Preparedness Month 2024/Prepare Your Health/CDC
The CDC National Preparedness Month was observed in September 2024 to raise awareness about the importance of preparing for disasters and emergencies that could happen at any time. The theme of CDC’s 2024 is raising awareness about preparing the whole community by integrating disability inclusion and accessibility in all phases of emergency preparedness and response.
“Social Determinants of Health are non-medical factors that influence health outcomes. They include the conditions in which people are born, live, learn, work, play, worship, and age, and the wider set of forces and systems shaping the conditions of daily life.
In 2023 CDC’s Office of Readiness and Response launched a series of activities to help public health departments develop “whole community” plans that integrate social determinants of health on personal and community-wide emergency preparedness and response.
Dr. Ahimsa Porter Sumchai is a climate activist living on the Westside.
January 2025
