The Testing Gap That Endangers Communities

Current federal cleanup removes only surface debris without mandatory soil verification—a dramatic departure from protocols used in previous major California wildfires. CWRO advocates for evidence-based federal testing protocols that protect public health and ensure genuine community recovery.

What Comprehensive Testing Means

• Complete Contamination Analysis: Heavy metals, chemical compounds, depth testing beyond surface soil, and grid sampling to identify contamination hotspots.

• Post-Remediation Verification: Mandatory verification after cleanup completion with independent laboratory analysis and transparent public reporting.

• Health-Protective Standards: Child-safe thresholds, cumulative risk assessment, and long-term monitoring.

  
  

Federal Precedent for Comprehensive Testing

• Camp Fire (2018) - Paradise, CA: Full post-cleanup soil testing by Army Corps of Engineers with comprehensive remediation based on results.

• Tubbs Fire (2017) - Santa Rosa, CA: State-led comprehensive soil assessment with post-remediation verification required before rebuilding.

• 2023 Maui Fire Exception: FEMA conducted comprehensive soil testing due to "lack of historical soil data"—the same situation exists in LA fire zones.

  
  

Current Federal Policy Problems

FEMA's 2020 policy change eliminated post-cleanup testing, claiming contamination was "primarily pre-existing." This ignores how fire mobilizes existing contaminants, creates new contamination sources, and concentrates toxins unpredictably.

Without testing, communities cannot determine when properties are safe for return, what protective measures families need, or where additional cleanup is required.

Recommended Federal Testing Standards

• Mandatory Testing: All destroyed structure properties, areas within 1000 feet of fires, properties downwind of burn areas, and anywhere ash is visible.

• Comprehensive Analysis: Lead, arsenic, mercury, cadmium, VOCs, PAHs, dioxins, and asbestos testing.

• Child-Safe Standards: Protective thresholds for children under 6 with post-remediation verification and independent review.

  
  

Implementation Framework

EPA provides environmental expertise, Army Corps handles engineering execution, FEMA supplies disaster relief funding, and HHS offers public health oversight. State and local agencies coordinate technical expertise and community communication.