Improving Living Conditions in the House of Beauty: Nail Technician Participation in Policy Change - Tiffany Skogstrom

DISCLAIMER: This is my personal opinion. The opinions expressed here represent my own and not that of my employer or any of the mentioned organizations.

The current regulations enforced by the Massachusetts Board of Registration of Cosmetologist’s (BORC) fails to protect public health from the emerging issues of infections, sanitation and safety in nail salons. Regulations must be reformed to involve and meet the needs of the stakeholders who can make real change – nail salon workers. The current method of regulation is designed to prevent stakeholder participation, marginalizes the largely immigrant workforce and lacks necessary reassessment to proactively deal with newly materializing public health issues.

Awareness of safety and sanitation problems in nail salons stems from a series of nail salon complaints regarding sanitation and infection reported to the Boston Public Health Commission (BPHC) in 2009. The heightened number of calls may be a consequence of raised awareness generated by the Safe Nail Salon Project – a program working with nail salons on environmental health and chemical safety issues (1). Attention to this public health problem culminated when on December 31, 2009 BPHC closed down a nail salon after a consumer was hospitalized and treated for a Methicillin-resistant Staphylococcus aureus (MRSA) infection believed to have been contracted via a manicure with unclean tools. Research reveals that outbreaks of a variety of foot-spa related skin infections have occurred in Georgia (2, 3), California (4), Ohio (5) and Kentucky (5). Many nail salon infections are likely to go unreported. Although the Safe Nail Salon Project educates nail technicians on protecting themselves from chemical exposure while at work, staff was blindsided by the emerging concern about sanitation and infection.

The Massachusetts BORC is the sole regulating agency with which the nail technicians have interaction. The agency guides hygiene, sanitation and general salon standard operating procedures and its stated mission is to protect “the health and safety of the public by maintaining high standards for the industry.”(6) The BORC’s expectation that nail technicians will follow Massachusetts regulations is built upon the Health Belief Model (7). For example, once a nail technician has passed her examination for licensure, she is aware of the Massachusetts regulations. A licensed nail technician knows that not following those regulations would make her ‘susceptible’ to disciplinary action and that the ‘severity’ of penalty could result in a loss of license or closure of her salon. Once she has become a legally trained nail technician, there are no ‘barriers’ to her following the regulations. The ‘benefits’ of following the regulations are employment and a safe work environment. All of the above circumstances are ‘cues’ that should bestow in her the ‘intention’ to abide by the law and then ‘act’ on that intention. When a nail salon worker does break the law, she is faced with penalties and left on her own to remedy the situation.

A more holistic and inclusive approach would be the better method for bringing nail salons into compliance. The problem with applying the Health Behavior Model to this program is that “there is no attempt to facilitate empowerment of those involved in the (research) process, nor is there opportunity for reflection.”(8) To put this into context, it is important to note that nail technicians in Boston and beyond consist of a young, female and mostly immigrant workforce. Working long hours for low wages and being exposed to an array of toxic chemicals, nail salon workers are so marginalized that Time Magazine identified their job as being one of the worst in America (9). The BORC online licensing database shows that more than a third of working Vietnamese immigrants in the Boston area work in nail salons (10). Furthermore, according to an article titled Results from a Community-based Occupational Health Survey of Vietnamese-American Nail Salon Workers by Roelofs and Azaroff, “Nail salons are the core of the Vietnamese immigrant and refugee community’s economic support. Low entry requirements, limited need for English language skills, ethnic business networks, and flexible work schedules draw many Vietnamese women and some men to the work.”(11) The BORC, on the other hand, does not have any Vietnamese representation (12).

While it is not surprising that the BORC would fail to mirror the demographics of the people working within the salons, several of its outdated policies impede participation and some are even detrimental to worker and public health. It would be to the benefit of the BORC and public health to have nail technicians participate in the revision of regulations, and to identify how to remove barriers to compliance.

The theory of frame alignment states that pitfalls in organizational participation include: failure to correctly interpret the communal grievance; treating constituent participation as a static means to an end; and over-generalization of participation-related processes (13). This paper will demonstrate these shortcomings as a road blocks for stakeholder involvement in the BORC and reinforce the idea that nail technicians need to be linked and mobilized within an alternative organization that is external from, and can put pressure on, a government agency.

The Three Frame Alignment Participation Pitfalls:

The BORC and Interpretation of Grievances (13)

The grievance most often heard from nail salon workers relates back to language barriers and takes the form of economical and job security concerns. The main complaint is that while in other states, such as California, “the nail salon industry draws so many Vietnamese workers that Vietnamese is one of the primary foreign-language option for the license examinations” (14), the Massachusetts BORC requires all examinations for licensure to be taken in English and refuses to allow translation. The BORC website declares that “EFFECTIVE OCTOBER 1, 1998, all examinations for licensure by the Board of Registration in Cosmetology will be administered in English only. Interpreters, dictionaries and other translation aids will not be permitted at any of the examination sites as of October 1, 1998. The decision of the Board to discontinue the use of interpreters and foreign language examinations is based on public health and safety concerns relating to the proper use of chemicals in the cosmetology profession and examination security issues in general.” (15)

The BORC ‘English-only’ policy for nail technician license exams forces people to work unlicensed and untrained in sanitation or any other trade skills. As a result, competing nail salons use cheap and unlicensed labor and undersell the businesses who are in compliance and abiding by the letter of the law. This also fosters potential for an underground economy for the buying and selling of nail technician licenses resulting in various forms of indentured servitude, and in extreme cases, human trafficking (16, 17, 18).

As outlined in Social Conditions as Fundamental Causes of Disease by Link and Phelan, “health policymakers should consider whether a proposed intervention will have an impact on just one disease or whether, because of its influence on a fundamental cause, it will affect many diseases.” (19) Failure to address the language grievance not only prevents the Vietnamese nail technicians from participating in mainstream government and society but also perpetuates the cycle of poverty, unsafe working conditions, unsanitary salons and general exploitation that has become ‘business as usual’ in nail salons.

The BORC and Dynamic Participation (13)

Nail technicians interactions with the BOC are a one-way relationship. Once nail technicians have passed their examination for licensure, the only expected interaction is through license renewals or a chance salon inspection. In 2003, there were 3 BORC inspectors and 1,206 salons in the state of Massachusetts (20). The BORC websites shows that a during a 2009 strike of 163 Boston beauty salon inspections, “56 were cited for violations ranging from unsanitary conditions to employment of unlicensed individuals and unlicensed shops.” (21) That one out of three of the businesses that were inspected had serious violations provides a telling snapshot of salon conditions. Salon employees tell tale of being issued citations without a clear understanding or direction on how to resolve the offenses. To draw an analogy from Siegel’s The Importance of Formative Research in Public Health Campaigns: An Example from The Area of HIV Prevention Among Gay Men, “public health efforts to change” a marginalized group’s “behavior must include efforts to change the way society treats” that group (22).

The BORC and Participation-Related Processes (13)

The BORC has put up many barriers for nail technician’s participation. For this reason, in June of 2009, a group known as the Massachusetts Healthy Cosmetology Committee met with the BORC with the goal of ‘nudging’ the agency to reconsider and revise some of cosmetology regulations for the sake of public health (23). This committee sought, among other things, to address:

·Allowing testing, training and hearings in languages other than English.

· The current requirement that nail technician licenses (as well as individual ‘health certificates') (24), which include home addresses, be prominently displayed in salons. The committee recommended that licensees’ home addresses not appear on licenses due to a story of a licensee being followed home and mugged for her tips.

· Clear and effective instructions for sanitation of nail salon tools (25).

· Eliminating the requirement for Steri-Dry (26) (dry sanitizer) and prohibit the use of any formaldehyde-based chemical in salons including Steri-Dry and formalin. Formaldehyde is a carcinogen, asthmagen, and strong irritant (27) and is unnecessary to assure salon hygiene and sanitation.

With the exception of the language request, the BORC was in agreement with the above mentioned items. However, rather than go through the process of rewriting and revising legislation, the BORC informed the committee that it was applying a ‘non-enforcement’ policy on those issues. The problem lies in the fact that if the laws are not formally changed, the nail technicians are unaware of which BORC rules are enforceable and which ones are not. In order to comply with regulations, nail technicians will continue to implement practices that put themselves and the public in harm’s way.

The BORC reluctance to make adjustments to outdated regulations demonstrates “collective conservatism” or ‘the tendency of groups to stick to established patterns even as new needs arise.” (23) The groups’ resistance to consider any outside suggestions, especially those with which they are in agreement, shows that the only way to participate in the BORC is if you are an appointed member of the Board or on the receiving end of a disciplinary action. Working conditions, sanitation, and environment cannot improve or get resolved with the current lack of opportunities to reevaluate situations. Even though the BORC agreed with most of the recommendations for improvements, the entity refused to be nudged. As stated in Klandermans’ Potentials, Networks, Motivations, and Barriers, “willingness is a necessary but insufficient condition of participation.” (28) The method of participation is ‘one-size-fits-all’, meaning that impermeability ensures that no one outside of the BORC gets to participate.

Analysis of the Three Participation Pitfalls and the BORC

The issues presented in the three pitfalls to participation reveal the BORC as an entity that works counter to its mission statement to “protect the health and safety of the public by maintaining high standards for the industry.” (6) The rigidity of the organization in terms of adapting to the training needs of the Vietnamese workforce results in consumers contracting infections. In any language, the BORC regulations continue to be outdated and unclear, and fail to address emerging infections or salon conditions.

Furthermore, during these turbulent economic times, low wage service workers are even more desperate for income and happy to do the work as unlicensed and exploited nail technicians. Unlicensed workers not only hurt the local economy by underselling their law abiding competitors, but create the perfect circumstances for indentured servitude where licenses can be bought and are worked off for exorbitant prices. The English-only examination policy further alienates an already marginalized community of people and makes young immigrant women even more vulnerable to exploitation through cheap labor and human trafficking.

Clearly there is no method to work within the BORC to make the necessary public health and worker safety changes. For this reason, Vietnamese nail technicians must link with an organization that shares their values, ideologies and beliefs in order to externally pressure the regulating agency to make important policy changes. Furthermore, the process of reviewing the pitfalls is valuable to make improvements because “efforts to reduce risk by changing behavior may be hopelessly ineffective if there is no clear understanding of the process that leads to exposure”.(19) Proactive public policy and interventions can be created by reflecting on the shortcomings of existing regulations.

The Intervention:

Frame alignment is a theory of collective action where un-mobilized individuals and an organization are linked together based upon shared ideology and a need to act (13). Social movements are comprised of people working together as ‘framing agents’ to define the world within which they live (29). According to Snow and Benford, the ongoing and necessary processes of a successful social movement are frame bridging, frame amplification, frame extension and frame transformation.

The four processes of frame alignment act as an organizational prophylactic against participation shortcomings and are necessary, flexible and fluid parts that aim to ensure momentum. Frame bridging (13) is the process of linking two or more ideologically congruent ‘frames’ (individuals and an organization) and building momentum through recruitment, leadership development and activities that are consistent with the shared ideology. Frame amplification (13) consists of value and belief amplification. Value amplification is the process where the group decides upon goals and mobilizes on them. Belief amplification is faith that the value amplification actions will have the desired impact. Frame extension (13) is the organization’s flexibility in what it can offer and incorporate to meet the needs of its constituents. Frame transformation (13) is the process of redefining or nurturing new values to find commonalities between the individual and organization that may not be immediately obvious. Frame transformation can be ‘domain specific’ where actions result in a change in status for a group of people, or ‘global interpretive’ which is a philosophical process of being “the change you want to see in this world.” (30) When linked together, the four frame alignment processes inoculate against the three pitfalls of participation and can create meaningful change.

1. Frame Alignment and the Interpretation of Grievances:

The first step of the process, known as frame bridging, involves identifying the organization best capable of properly interpreting the Vietnamese nail technician’s grievances and with which they would be best aligned. The Vietnamese – American Initiative for Development (Viet-AID) is a prominent organization within the Vietnamese community. Viet-AID’s mission to “provide comprehensive economic development programs and services to alleviate poverty and advance civic participation” (31) is complementary to the values and reflects the grievances of the nail technicians’ struggle for decent employment. Viet-AID has good relationships with the Vietnamese business leaders and plays a major role in the Safe Nail Salon Project and the Massachusetts Healthy Cosmetology Committee. This sets the stage for aligning the un-mobilized nail technicians with Viet-AID in a pact to force policy change.

Nail technicians working with Viet-AID for changes in the salons would vicariously be partnering with the BPHC Safe Nail Salons Project. BPHC is a governmental agency, and a population such as the Vietnamese community, who fled their country of origin to escape an oppressive government, may be gun-shy at the prospect of such a partnership (22). Through frame transformation, ‘regulatory’ values and activities would have to be made appealing to participants. Activity examples include creating model regulations that would be adopted by various municipalities across Massachusetts that would: require annual nail salon registration with the health department; make Safe Nail Salon training a condition of the annual registration; and create specific local requirements for sanitation.

To appeal to nail technicians, these regulatory methods must be framed to address nail technician’s grievances of an unsafe work environment, inequity amongst business’ underselling practices and low wages. The unlikely partnership between a government agency and the Vietnamese workers is made more attractive by revealing how BPHC’s public services might be beneficial. The BPHC Safe Nail Salon Project has a rich history of frame extension through helping people access health care and providing valuable public health services. Therefore, the closer relationship with a local government agency would be a partnership to bring nail technicians into the mainstream, rather than an additional regulatory burden.

While BPHC focuses on local regulations, Viet-AID may be the more appropriate vehicle to turn nail salon worker’s grievances into an active campaign to put external pressure on the BORC. These simultaneous efforts could lead to effective public health change.

2. Frame Alignment and Dynamic Participation

Frame bridging is needed to mobilize leaders and interpret grievances into movement activities. Viet-AID’s frequent visits to the salons helps recruit leaders who participate in activities, get the community talking about the problem and encourage others to take part. As stated by Klandermans, “informal recruitment networks are necessary conditions for the arousal of motivation to participation.” (28) This paves the way for frame value and belief amplification, where nail technicians “employ an ‘injustice framework’ that links personal and vicarious experiences of stigma and discrimination” (32) to Viet-AID’s mission of social and economic development.

Frame value and belief amplification involve articulating grievances in terms of ‘injustice’ and forming them into solution oriented actions. The conditions of belief amplification (13) are that people will mobilize when (a) they believe there is a serious problem; (b) there is an antagonist (the BORC) that is defined as the source of the problem and (c) with whom the constituents have stereotypical beliefs about power; (d) people believe that the identified actions will lead to change; and (e) there is importance in standing up together to overcome the injustice.

The frame transformation is domain specific, where actions result in the change in status of how a group of people are treated by the BORC. Potential actions, depending upon the will of the constituents, could include letters to the editor or public demonstrations demanding that the governor command the BORC to provide examination translation, or Vietnamese representation on the BORC. The dynamic participation feeds the recruitment aspect of frame bridging where “people show more of a tendency to participate in collective action if they expect that others will do so as well.” (28)

3. Frame Alignment and Participation-Related Processes

The theory of frame alignment requires that participants are active in all processes. Participation-related processes consist of recruitment and leadership development of frame bridging, identifying goals and strategic activities during frame amplification, recognizing innovative ways to meet the ongoing needs of the community through frame extension, and nurturing new values that serve the benefit of the community through frame transformation.

Where Vietnamese nail technicians have been alienated by the BORC, the frame alignment process of this proposed campaign welcomes participation in the ‘linked’ organization at all levels. If the frame alignment recipe is followed correctly, the result will be a functioning organization that serves the needs of its constituents. The processes could be the blueprint for a Nail Salon Business Leadership Council that might be housed within Viet-AID. The new leadership group would autonomously decide the best course of actions in the interest of nail technicians. It would drive its agenda through participation in other economic and social justice initiatives, and ideally, the BORC itself.

Ongoing success is only guaranteed if all of the frame alignment processes are participant driven. Furthermore, it is necessary to reevaluate and adapt all processes to meet emerging needs and realities in order to retain and accumulate constituents. An ideology that becomes set in stone will lose members and momentum (29), and becomes susceptible to mirroring the rigidity of the entity that it seeks to influence.

Conclusion:

In absence of the nail technician’s ability to participate in the BORC, the most sensible intervention involves collective action to improve public health policy. The most fundamental change would be to allow nail technicians to test for licensure in their own language. This single policy change will have astounding results such as giving people access to safe and well paying jobs and safer nail salons. While municipalities can put out fires by implementing city regulations, real change must happen within the BORC to tackle the root of these problems.

The frame alignment process has potential to bring a historically marginalized group of people into the mainstream. The multi-level methods address health inequities through strengthening individuals and communities, improving people’s access to services, and fostering economic and cultural change (33). This proposal builds meaningful, innovative and sustainable partnerships and a model that could be emulated in other parts of the country, further building momentum for social change.

References:

1. The Boston Public Health Commission’s Safe Nail Salon Project. Available at: www.bphc.org/safenails (accessed 2/27/10).

2. Gira AK, Reisenauer AH,, Hammock L, Nadiminti U, Macy JT, Reeves A, Burnett C, Yakrus MA, Toney S, Jensen BJ, Blumberg HM, Caughman SW, FS Nolte. Furunculosis Due to Mycobacterium mageritense Associated with Footbaths at a Nail Salon. Journal of Clinical Microbiology April 2004; Vol 42, No. 4: 1813 – 1817.

3. Cooksey RC, de Waard JH, Yakrus MA, Rivera I, Chopite M, Toney SR, Morlock GP, Butler WR. Mycobacterium cosmeticum sp. nov., a novel rapidly growing species isolated from a cosmetic infection and from a nail salon. International Journal of Systematic and Evolutionary Microbiology 2004: 2385–2391.

4. Winthrop KL, Albridge K, South D, Albrecht P, Abrams M, Samuel MC, Leonard W, Wagner J, Vugia DJ. The Clinical Management and Outcome of Nail Salon-Acquired Mycobacterium fortuitum Skin Infection. Clinical Infectious Diseases January 1, 2004: 38–44.

5. Redbord KP, MD; Shearer DA, MD; Gloster H, MD; Younger B, MD; Connelly BL, MD; Kindel SE, MD; Lucky AW, MD. Atypical Mycobacterium furunculosis occurring after pedicures. Journal of the American Academy of Dermatology March 2006; Vol. 54; No. 3: 520–524.

6. Massachusetts Board of Registration of Cosmetologists. About the Board of Registration of Cosmetologists. Available at: http://www.mass.gov/?pageID=ocaterminal&L=4&L0=Home&L1=Licensee&L2=Division+of+Professional+Licensure+Boards&L3=Board+of+Registration+of+Cosmetologists&sid=Eoca&b=terminalcontent&f=dpl_boards_hd_about&csid=Eoca (accessed 2/28/10)

7. Edburg, M. Individual Health Theories (p 35 - 49). In: Edburg, M. Essentials of Health Behavior. Social and Behavioral Theory in Public Health. Sudbury, MA: Jones and Bartlett Publishers. 2007

8. Thomas LW. A Critical Feminist Perspective of the Health Belief Model: Implications for Nursing Theory, Research, Practice and Education. Journal of Professional Nursing July – August 1995; Vol. 11; No. 4; 246 -252.

9. Kaplan J, Fitzpatrick L. The Worst Jobs in America. Time Magazine. 7/30/07. Available at: http://www.time.com/time/business/article/0,8599,1648055,00.html (accessed 2/27/10)

10. Doan, T. New Ecology Inc. (NEI). Toxicity, Safety and Performance Evaluation of Alternative Nail Products. Cambridge, MA. January 2006 (p 7) Available at: http://www.turi.org/content/download/3829/46553/file/New%20Ecology%20Report.pdf (accessed 2/27/10)

11. Roelofs, C, Azaroff, LS. Holcroft, C. Nguyen, H. Doan, Tam. Results from a Community-based Occupational Health Survey of Vietnamese-American Nail Salon Workers. Journal of Immigrant and Minority Health 2008; 353 - 361.

12. Massachusetts Board of Cosmetologists and Aestheticians: Board Members. Board of Registration of Cosmetologists. Available at: http://license.reg.state.ma.us/public/dpl_board_members/bm_view_list.asp?board_code_web=HD (accessed 2/27/10)

13. Snow DA., Rochford EB, Worden SK, Benford RD. Frame Alignment Processes, Micromobilization, and Movement Participation. American Sociological Review 1986; Vol. 51; No 4; 464 - 481.

14. Quach T, Nguyen KD, Doan-Billings PA, Okahara L, Fan C, Reynolds P. A Preliminary Survey of Vietnamese Nail Salon Workers in Alameda County, CA. Journal of Community Health May 2008; 336 – 343.

15. Massachusetts Board of Registration of Cosmetologists. Statutes and Regulations. Board Policies and Guidelines. State Board Examinations: English Language Requirement. Available at: http://www.mass.gov/?pageID=ocaterminal&L=6&L0=Home&L1=Licensee&L2=Division+of+Professional+Licensure+Boards&L3=Board+of+Registration+of+Cosmetologists&L4=Statutes+and+Regulations&L5=Board+Policies+and+Guidelines&sid=Eoca&b=terminalcontent&f=dpl_boards_hd_exams_english_only&csid=Eoca (accessed 2/28/10).

16. Logan TK, Walker R, Hunt G. Understanding Trafficking Victims in the United States: Where Are They? Trauma, Violence and Abuse January 2009; Vol. 10; No.1; 9.

17. Lee, R. Pair Sentenced for Modern-Day Slavery at Local Nail Salons; The Nail Salon Owner Received the Toughest Sentence of the Two – 90 Days in Jail – For Participating in Human Trafficking. York Daily News / York Sunday News. 2/11/10. Available at: http://www.ydr.com/crime/ci_14382799 (accessed 2/27/10)

18. Ramakrishnan, M. Human Trafficking Exists ‘Right Here, Right Now’. Allston / Brighton TAB. 1/15/10. Available at: http://www.wickedlocal.com/allston/news/lifestyle/x1409376265/Human-trafficking-exists-right-here-right-now (accessed 2/27/10)

19. Link BG, Phelan J. Social Conditions as Fundamental Causes of Disease. Journal of Health and Social Behavior 1995: p 80 - 94.

20. Roelofs C. Regulations for Manicurists / Nail Salon Operation: Massachusetts vs. Other New England States and New York. 11/19/03

21. State Inspectors Visit Boston to Ensure Safety and Compliance at Barber Shops and Beauty Salons. Board of Registration of Cosmetologists. Available at: http://www.mass.gov/?pageID=ocamodulechunk&L=4&L0=Home&L1=Licensee&L2=Division+of+Professional+Licensure+Boards&L3=Board+of+Registration+of+Cosmetologists&sid=Eoca&b=terminalcontent&f=dpl_consumer_press2009_dpl_2009_08_10&csid=Eoca (accessed 2/27/10)

22. Siegel M, Lotenberg LD. The Importance of Formative Research in Public Health Campaigns: An Example from The Area of HIV Prevention Among Gay Men (p. 73 - 78). In: Siegel M, Lotenberg LD. Marketing Public Health. Strategies to Promote Social Change. Sudbury, MA: Jones and Bartlett Publishers, 2007.

23. Thaler RH, Sunstein CR. Following the Herd (Chapter 3 p 53 - 71). In: Thaler RH, Sunstein CR. Nudge. Improving Decisions About Health Wealth and Happiness. Yale University Press, 2008.

24. 240 CMR 3.01(7) Licensure of Salons. Available at: http://www.mass.gov/?pageID=ocaterminal&L=6&L0=Home&L1=Licensee&L2=Division+of+Professional+Licensure+Boards&L3=Board+of+Registration+of+Cosmetologists&L4=Statutes+and+Regulations&L5=Rules+and+Regulations+Governing+Cosmetology+Profession&sid=Eoca&b=terminalcontent&f=dpl_boards_hd_cmr_240cmr300&csid=Eoca#3.01 (accessed 2/28/10)

25. 240 CMR 3.03 Equipment and Hygiene Procedures. Available at: http://www.mass.gov/?pageID=ocaterminal&L=6&L0=Home&L1=Licensee&L2=Division+of+Professional+Licensure+Boards&L3=Board+of+Registration+of+Cosmetologists&L4=Statutes+and+Regulations&L5=Rules+and+Regulations+Governing+Cosmetology+Profession&sid=Eoca&b=terminalcontent&f=dpl_boards_hd_cmr_240cmr300&csid=Eoca#3.03 (accessed 2/28/10)

26. 240 CMR 3.03 (17) b. 2. Equipment and Hygiene Procedures. Available at: http://www.mass.gov/?pageID=ocaterminal&L=6&L0=Home&L1=Licensee&L2=Division+of+Professional+Licensure+Boards&L3=Board+of+Registration+of+Cosmetologists&L4=Statutes+and+Regulations&L5=Rules+and+Regulations+Governing+Cosmetology+Profession&sid=Eoca&b=terminalcontent&f=dpl_boards_hd_cmr_240cmr300&csid=Eoca#3.03 (accessed 2/28/10)

27. Agency for Toxic Substances and Disease Registry. ToxFAQs for Formaldehyde. How can formaldehyde affect my health? June 1999. Available at: http://www.atsdr.cdc.gov/tfacts111.html#bookmark05 (accessed 3/3/10)

28. Klandermans B, Oegema D. Potentials, Networks, Motivations, and Barriers: Steps Toward Participation in Social Movements. American Sociological Review August 1997; Vol. 52; No. 4: 519 - 531.

29. Snow DA, Benford RD. Center for Advanced Studies in the Behavioral Sciences, Stanford. Clarifying the Relationship Between Framing and Ideology in the Study of Social Movements: A Comment on Oliver and Johnston.

30. Mohandas Karamchand Gandhi, 10/2/1869 – 1/30/1948.

31. Viet-AID’s Mission and History. Available at: http://www.vietaid.org/ (accessed 3/1/10)

32. Martin DD. From Appearance Tales to Oppression Tales: Frame Alignment and Organizational Identity. Journal of Contemporary Ethnography April 2002, Vol. 31, No. 2: 158 – 206.

33. Marks DF. Health Psychology in Context. Journal of Health Psychology 1996; Vol 1: 7 - 21.

Planetary Enemy Number 1: A Critique Of The Recycling Practices Of Boston, Massachusetts- Dorothy Marshall

Background

The concept of recycling is not a novel idea. People have been recycling for thousands and thousands of years. Recycling is simply reusing an item for a new purpose (5). Many people are unaware of how often they recycle on a daily basis. However, recycling has a greater impact when considered on the consumer scale (5). One of the main reasons to recycle is to reduce the amount of trash sent to landfills (5). Space is limited, so recycling creates a better use of the limited space for trash disposal. Additionally, recycling prevents the need to deplete limited resources by reusing ready-made products. This makes the creation of new products from recycled materials cost-efficient and energy conserving (5). Recycling also decreases the amount of greenhouse gases emitted into the atmosphere by avoiding incineration process. However, in spite of these benefits, Americans on average recycle 32% of solid waste. Even more shocking, Boston lags far behind the national average and recycles 15% of solid waste (8). Why do Bostonians fail to recycle? What are the barriers that prevent Bostonians from recycling? This paper takes a critical look at recycling programs and policies in Boston in an attempt to understand the disconnect between the public perception of the need to recycle and the public health problem of inappropriate waste disposal.

Critique 1: Amount/type of messages

Recycling in Boston began in 1987 with volunteers organizing newspaper and bottle drop- offs in several neighborhoods (2). Since then, there has been a lack of a coherent, cohesive, united effort from the city. “Environmentalists say that education isn’t enough” (8), but Boston provides little or no education to its residents about recycling. Residents are required to work to hard to receive any information about recycling. Not only must the resident go to the city’s website and find the link to request information about recycling, the information provided does not explain why recycling is important. Many environmentalists fallaciously believe that the message of recycling as a means to save the Earth is a relevant reason for the general population to engage in this activity and is common knowledge.
The Elaboration Likelihood Model postulated by Petty and Capuano in 1986 explains why this is an erroneous mindset (7). This theory states that people process information via a central processing route or a peripheral processing route. If a person is directly involved or has a personal attachment to an issue, they will use the central processing route when evaluating the message. They will be attentive to what is said analyze the information. On the other hand, when a person is not directly involved with the issue, they will use the peripheral route. They will evaluate the message and make a decision based on things such as: the attractiveness of the messenger, the attractiveness of the message, and the frequency of the message (7).
I argue that for the majority of Boston residents, recycling is not along the central process because none of the benefits of recycling that are touted by environmentalists directly affect the individual. The highlighted benefits are all for the greater good of mankind and the planet, which appeals to an altruistic individual. Lacking the direct, personal involvement in the issue, most Bostonians will look at the frequency and attractiveness of the recycling messages when making a conscious choice to recycle or not. The policies and advertisements for recycling do not account for the fact that many residents are not using the central processing route when making a choice. The media and policies are designed to reach those with personal, direct personal involvement in the act of recycling. People have to actively seek out newsletter and pamphlets in order to get information and residents have to call for recycling bins. For the vast majority of people, recycling is not a priority in their lives, so they are not listening to or processing any of the content in these messages. Additionally, recycling messages aimed at increasing awareness about the importance of and participation in recycling are few and far between. This is why “communities have spent a fortune on outreach, but the message hasn’t gotten through” (8). It may seem like recycling education is falling on deaf ears. It is.

Critique 2: Inappropriate framing

Although the concept of recycling has been around for thousands of years, the modern concept of recycling was born in the United States with the US Clean Air Act of 1970 (5). During this time, there became an awareness of the long-lasting effects of industrialization, the use of landfills, and the emission of greenhouse gases. In an attempt to stave off the effects of global warming and in order to be more efficient with the use of our limited natural resources, the modern age of recycling was born.
However, during this time, there were many critics of the concept of global warming and the need for recycling. Some people felt that global warming was nothing more than cyclical patterns in the climate known to happen on the Earth over the course of human history. These critics cited the fact that the climate change was not drastic. This leads to another fallacy of the environmental movements. To most people, global warming, the need to recycle, or to lessen the burden on landfills by using sustainable items was unnecessary. In the majority of attempts, to educate the public, environmentalists cite the need to recycle in order to decrease greenhouse gas emissions, save the ozone layer, and save endangered species and habitats. All of things are imaginary and mythical to the average American citizen. Most people do not see these issues. Since there is no tangible problem, there is no impetus to change the status quo. This is why recycling rates in Boston are abysmal. When people walk outside, they see a blue sky. When they turn on the faucet, they see clear water. When they put trash on the curb, it is taken away.
The framing of for the reasons to recycle is inappropriate (10). The habitats and animals that are currently most effected by climate change far from Boston (e.g. polar bears). Most people will never experience any of the issues (melted polar ice caps) that are supposed to be a motivator for behavior change. As a result, there is a large apathetic population that is resistant to change.
Additionally, landfills are located far from urban centers, so the majority of the population is unaware of where the trash goes. There is a disconnect between the idea that trash is not removed; only transported. People do not see the fact that space is limited because environmental engineers go to great length to maximize the space in landfills. However, this efficiency lulls the population into a false sense of comfort about trash disposal.
The goal of recycling as it is currently framed is to fix a problem that in the majority of people’s mind does not exist. It is hard to have a desire to or sustain changed behavior when you do not see the problem or the benefits of the changed behavior. Recycling is framed is such a manner that people do not see it as a necessity. It is something so distant with effect so far off that there is no need to worry about it in the present. As long as there is air to breathe, water to drink, and clean streets, there is no need to get involved. People also do not see or know the effect of generating large amounts of trash. Using future planetary consequences as an incentive and a frame for recycling in the present is an ineffectual approach.

Critique 3: Lack of Follow Through and Reinforcement

Proper waste management is important and is often cited as one of the most important contributions to ameliorating disease. The Age of Sanitation is considered to have begun in 1842 when British reports linked disease to filthy environmental conditions (6). The modern age of recycling began in the United States in the 1970s and in Boston, 1987. The first Boston citywide recycling effort began in 1993 with the weekly collection of newspapers (2). So for all intents and purposes, Boston wide recycling is 17 years old, where disposing of all trash to landfills is 168 years old.
Environmentalists fail to realize that for the majority of the population, recycling trash is a whole new process. A huge fallacy in recycling campaigns is that they fail to acknowledge that recycling is a two-step change process. The Social Learning Theory postulated by Bandura shows that actions are learned by observation (1). People are conditioned and used to throwing all unwanted items in a trashcan. In order to be effective, advocates need to acknowledge the fact that recycling involves breaking one habit and seeing the utility of taking up a new one. Unfortunately, Boston’s patchwork approach to recycling makes it impossible for recycling to become a habit. It makes it impossible for children and adults to observe and learn this behavior because recycling in Boston is not unified.
In an attempt to increase recycling in Boston and promoting the building of a new habit, the Waste Ban of 2000 was passed. This regulation prohibits the disposal of certain recyclable material in the trash (11). However, this regulation cannot be enforced. Recycling is not obligatory in Boston. Businesses and large apartment complexes can choose to enter into private recycling contracts (4). Curbside recycling is provided for some residents of homes, but recycling pick-ups are not consistent. “Many communities do not provide recycling at larger apartment complexes, and others pick up only every other week. Some do not offer curbside recycling at all, forcing trips to transfer stations” (8). So even for those that want to recycle, there is no consistency in the city. In order to pick up a new habit, according to the Social Learning Theory, it has to be consistent and people need to observe others participating (1). When residents see others throwing away aluminum cans, others will follow suit, especially if there is no other option readily accessible. This is why recycling rates in Boson peak and decline.
The most prominent issue with this is the STRIVE campaign. This campaign introduced recycling to all Boston Public Schools, but its efforts are negated because of the city’s recycling inconsistencies (2). For example, when a child goes home to a large apartment complex with no recycling option he cannot continue the recycling behavior he learned at school. The child will also see their parents throwing recyclables away, so the child will model what they see and not have the option to do the learn behavior from school. In order for any effort to be successful, consistency is vital.
As shown, recycling in Boston is riddled with problems. The Elaboration-Likelihood Model has shown that the persuasive messages are aimed at the wrong audience and that there are simply no enough of them. Framing has shown that the messages and benefits derived from recycling are not strong enough to persuade someone in understanding the need for recycling. Finally, the Social Learning Theory showed that recycling is a learned behavior that needs to be consistently modeled and observed in order to become a new habit, but the inconsistencies throughout the city thwart those efforts. Boston asks its residents to call for a recycling bin for a problem they can’t see, for a solution that’s yet future, to start a habit they cannot continue throughout the city.

Intervention: Aspects of the Matter Matters campaign

The “Matter Matters” campaign is an intervention that aims to address these three issues of inappropriate messages, poor framing, and lack of consistency. In this campaign, the messages will be tailored to the majority of Boston residents- an audience that has no personal involvement in recycling, is concerned with immediate benefits, and uses the most convenient option when disposing of trash. The three tenants of this intervention are based on the theory of framing, social norms/social learning theory, and operant conditioning theory.

Section 1: Framing

Because of the efficiency of our landfills and sanitation, trash is not something people actively think about. In this sense, the efficiency of trash disposal is hindering the progress of recycling. As stated before, the benefits and consequences of not recycling are intangible. When people put their trash on the curb it goes away. When people walk outside, they see green grass and a blue sky. When environmentalists speak of problems, they are often in the distant future. The benefits of recycling are usually framed as “it’s good for the Earth” or “it’s good for the environment”, but how is recycling good for the individual?
One way to reframe recycling so that the individual will see the direct benefits is to attach the monetary value ascribed to recycling. “When you’re paying $89.50 a ton for trash removal, recycling translated into big savings” (8). Instead of focusing on how much good recycling does for the environment and for posterity, create messages that focus on the fact that recycling saves money. Many of the messages do not highlight the fact that recycling common materials like paper, aluminum, and plastic are cost efficient. Many commercials show how using energy efficient light bulbs and energy star appliances can save money over the course of time and recycling these materials can do the same things. This addresses the personal involvement and immediate benefit to recycling.
At one point in time, recycling center would pay for cans and newspapers. This is a direct personal benefit that environmentalists can use to reframe recycling. Taking this frame a step further would involve tax breaks or incentives for those that recycle. By recycling you can save money the government money and receive tax breaks. If municipal governments are able to save money by paying less for trash removal, this could translate into large savings for the city. For example, there can be a slogan like “recycling is the answer to your tax hike”. At a city level, recycling should be reframed to emphasize it as a way for people to derive direct monetary benefits. Just like the Federal government used monetary incentives as a way to drive the market toward using fuel-efficient or hybrid cars, Boston’s city government can use the same method as a means to increase participation. We need to continue to reframe recycling until it becomes common practice.

Section 2: Social norms/ SLT/Mass Media

We can make recycling common by changing social norms by using the social learning theory through mass media. Once people begin to see the direct monetary benefit of recycling, more people will use the central processing route to make a decision whether or not to recycle (7). However, if there is spotty recycling throughout the city, the rates will not increase.
In the Matter Matters campaign, I would partner with the Boston sports teams in order to create a social norm of recycling (1). Bostonians are huge sports fans and just like beer is associated with sports, recycling can become associated with beer. If recycling efforts were pushed and advertised during sporting events, it would translate into daily practices. The attendees would see their peers recycling cans, bottles, etc. on a large scale (1). For example, the Matter Matters campaign would show commercials between innings at Red Sox games of how much money Boston Red Sox fans have saved by recycling their beverage containers. The Red Sox could have a “Recycle Night” with giveaways of Red Sox products made by recycled materials purchased by the money saved as a result of fan participation in recycling. This is a way of showing how the benefits of recycling are not only important and simple, but they directly and immediately translate back to the individual. This would create awareness of recycling cans and bottles, show how it is of personal relevance, and allow others to see recycling behavior modeled. This addresses the notion that the benefits of recycling are yet future.
With this aspect of the intervention, the population gets free, recycled Red Sox paraphernalia right away. The campaign could also be based on participation. The more that the fans recycle; the more the Red Sox can giveaway. This can be replicated for other Boston sports teams in other arenas as well. This will create a positive association between fun, recycling, and free gifts. It is also on a large scale, so many people will be able to receive the same mass media messages. There is also the added benefit of watching others participate and if Matter Matters could get players to participate that will help with the attractiveness of the message (1, 7).

Section 3: Operant Conditioning

Finally, to increase the perceived benefit of recycling, the Matter Matters campaign will employ the operant conditioning theory to negatively reinforce throwing things away in the trashcan. The theory of operant conditioning, postulated by Skinner, states that a behavior will increase if it is followed by positive reinforcement. A behavior will decrease if it is followed by negative reinforcement (9). This, unlike classical conditioning, is used for learned behavior. As mentioned before, the act of recycling for the vast majority of Americans is a learned behavior. The pay-as-you-throw campaign, modeled off of this theory, has shown to be an effective motivator for recycling. This program “gives residents a cash incentive to cull cans and cardboard from the trash and put them in recycling bins which are emptied for free” (8).
Not only will people know about the direct monetary benefits of recycling, but also they will be charged to use the trashcan. This will create the need for those people who never thought about the importance of recycling to reevaluate. The thought process shifts from, “it’s easier to throw everything in the trash because there’s a trash can readily available and it’s what I always do” to “is this recyclable? I want to avoid paying for trash pickup this week.” In order to avoid the negative consequence of paying of trash disposal, a resident can receive the benefit of having recycling removed for free. This will create a huge push for people to be more responsible consumers. This will deal with the issue of recycling as a means to compensate for overuse that some environmentalists are concerned about. “it’s crucial that people not only recycle more, but produce less trash to begin with” (8).
The juxtaposition of strongly promoting and providing incentives for recycling and disparaging trash disposal will create an awakening among Boston residents. To many people, recycling is not an issue. There are much bigger issues in daily life. The “Matter Matters” campaign takes all of the thinking and decision making process out of recycling.

Summary

The failure to recycle and use limited resources prudently will have long-lasting and far-reaching consequences. However, these consequences will not be visible to the general population for quite some time. It is important that public health practitioners never let those effects become visible to the lay audience. It is important that we address the failure to recycle now before recycling no longer has an effect on the environment.
As states, there are several issues with the approach that the City of Boston takes to recycling, which is evidenced by the fact that Boston recycles less than half of the average American citizen. The messages that are used are tailored for the wrong audience, they are inappropriately framed, and the city is inconsistent with its policies and enforcement of recycling practices. The Matter Matters campaign aimed to address these issues by looking at the problems with Boston’s approach to recycling and applying the theories of framing, social norms, and operant conditioning.
In taking a novel approach and acknowledging the fact that people need strong, consistent, tangible, and direct incentives to recycle, the Matter Matters campaign creates a whole new way for Bostonians to view and get involved with recycling. This campaign aims to create sustained change in the residents of Boston and beyond.

References

1. Bandura, A. Social Learning Theory. New York: General Learning Press, 1971.

2. City of Boston.gov. History of Recycling in Boston. Boston, MA: Official Website of the City of Boston. http://www.cityofboston.gov/publicworks/RecyclingandSanitation/history.asp

3. City of Boston.gov. Boston Recycling Information 2005. Boston, MA: Official Website of the City of Boston

4. City of Boston.gov. Recycling in Large Buildings. Boston, MA: Official Website of the City of Boston.
http://www.cityofboston.gov/publicworks/RecyclingandSanitation/recycling.asp

5. Grabianowski, Ed. How Recycling Works. http://science.howstuffworks.com/recycling.htm

6. Metzger, Thomas. Waste Watchmen. Waste Age. http://wasteage.com/Collections_And_Transfer/sanitation-recycling-through-history-200905/

7. Petty, R. E. and Cacioppo, J. T. Communication and persuasion: Central and peripheral routes to attitude change, New York: Springer-Verlag, 1986.

8. Schworm, Peter. Recycling efforts fail to change old habits: Apathy, confusion cited as obstacles. Boston.com. http://www.boston.com/lifestyle/green/articles/2010/03/14/despite_environmentalists_pleas_massachusetts_recycling_rate_stalls/

9. Skinner, B. F. Two types of conditioned reflex and a pseudo type. Journal of General Psychology 1935;12, 66-77.

10. Watzlawick, P., Weakland, J. and Fisch, R. Change: Principles of problem formation and problem resolution, New York: Norton, 1971.

Making The Safe Drinking Water Act More Effective – Brad Frithsen

In the 1970s public attention and support was behind a string of legislative initiatives aimed at cleaning up the environment. In 1974, one of these initiatives led to the passage of the Safe Drinking Water Act (SDWA). The SDWA was created to ensure the health of citizens was maintained by enforcing public water systems to comply with strict guidelines around the cleanliness of public water (24). Proponents of the bill realized the danger that was posed to the public health by the contaminants that could enter the public drinking water system through various sources including the improper disposal of chemicals, use of pesticides, and animal wastes among others (24).
On its surface, the mechanics of the SDWA appear to be fairly robust. Penalties for non-adherence to the SDWA are high; up to $25,000 per day for non-compliance (29) and the measures for meeting the SDWA are quite extensive (26). To ensure that the letter of the law is met, the Environmental Protection Agency (EPA) grants State governments the power to enforce the mandates of the SDWA and to make them even stronger (29). The SDWA also requires that municipalities inform the public of the safety of its drinking water by sending out water quality report cards on an annual basis (27).
Yet despite this law and the mechanisms in place to ensure enforcement, millions of illnesses occur each year that can be linked to water contaminants (4). Research conducted by the New York Times found that 40% of the nation’s water systems violated the SDWA at least one time in 2008. The effects of these infractions range from that of gastrointestinal illness to exposure to potentially deadly levels of toxins such as lead, arsenic, manganese, and barium that could contribute to cancer (5). Many of these violations occur with government knowledge and have no level of punishment enforced (4). There is also reason to believe that the SDWA doesn’t even come close to monitoring all of the potentially toxic substances in our drinking water. Currently only 91 contaminants are regulated by the SDWA even though according to the EPA, more than 60,000 chemicals are used within the United States (6). Hundreds of these chemicals have been linked with cancer and found in the public water supply (6) but because they do not fall within the law are considered legal.
Simply having legislation in place does not guarantee that it will be effective as a public health intervention. Public health legislation cannot remain static but rather has to change as new information becomes available that leaves the original bill lacking in its intentions. The SDWA was signed in 1974 and has only been amended twice (1986 and 1996) even though a large body of research has become available since then suggesting that the bill must be strengthened in order to secure clean water to the public. Public health advocates, in this case EPA officials, have to create public support so that the SDWA is strengthened in order to ensure that the law’s intentions are met. This paper will review why EPA officials have been unable to strengthen the SDWA and develop an intervention strategy to counter these critiques.

Critique 1: Reframe The Argument

The EPA has allowed opponents of efforts to strengthen the SDWA to frame the argument in their favor. Major opponents of amendments aimed at strengthening the SDWA have been from industry advocates. These groups have been able to frame the issue so that increased enforcement or amendment of the SDWA would equate to having an adverse impact on the core values of the public. There are several arguments from industry leaders against restructuring the law but this critique will focus on the argument of strengthening the SDWA by including the practice of hydraulic fracturing in its regulatory framework.
In 2005 the Energy Policy Act exempted hydraulic fracturing from the SDWA (12). Hydraulic fracturing, or fracking, is a method of reaching a reservoir of oil or gas by injecting liquid into a rock formation causing a crack to form. Oil or gas can then be extracted from the well created by the crack (20). Many of the fracturing fluids contain chemicals that can be toxic to humans (7) and advocates for clean drinking water oppose the use of fracking in gas and oil exploration because of the potential contamination of Underground Source of Drinking Water (USDW and regulated under the SDWA as of 1996). In June 2009 the Fracturing Responsibility and Awareness of Chemicals Act (FRAC) bill was introduced with the intention to eliminate the hydraulic fracturing exemption created by the 2005 law (11). This proposal was met with immediate consternation from the oil and natural gas industries. Their argument was that strengthening the SDWA would weaken American businesses, increase costs to consumers, and lower the disposable incomes of Americans (8,14, 19). Reframing the argument in this way sways public support towards the industry’s side and weakens the EPA’s ability to argue for strengthening the measure.
Reframing the argument has been deployed in the attempt to block various bills that had the intention of improving public health. The tobacco industry attempted to frame itself as an agent that was looking out for the public while painting anti-tobacco advocates as “zealots, health fascists, paternalists, and government interventionists” (22).
Legislation to lower the legal blood-alcohol limits has run into opposition groups that have framed the argument so that passing such legislation will have an adverse effect on the core values of ordinary citizens. When New Jersey tried to lower the legal blood-alcohol limit to 0.08% from 0.10% it was met with opposition from the New Jersey Restaurant Association. The association’s argued that such legislation will take away their consumer’s freedom to enjoy a couple of drinks with dinner (10). A 1997 Restaurants & Institutions publication argued that legislation to adopt a 0.08% Blood Alcohol Content level would effect the bottom line of businesses and essentially made someone who had a couple of social drinks into a common criminal (2).
This tactic was also successfully used to block the Clinton Administration’s Health Care Reform efforts in 1994. Opponents of the reform used formative research to identify the core values of the public and then using this knowledge framed their argument against the reform so that the public feared that proposal would “bankrupt the country, reduce the quality of care, and lead to jail terms for people who wanted to stick with their family doctor.” (22).
EPA officials must be able to reframe the enforcement and strengthening of SDWA in such a way that the public will recognize that continued failure endangers their core values. Core values that have been identified in previous public health policies initiatives include those of freedom, independence, economic opportunity, control, and fairness/equality (22).

Critique 2: Places Too Much Responsibility on Individuals to Ensure Compliance

According to the EPA’s 2009 Ground Water and Drinking Water Statistics report approximately 294 million people receive their water from a public water system that must comply with the SDWA. Ninety-six percent of a population is a large constituency to have to answer to. I find it surprising that the EPA hasn’t developed an easier method to notify the public of their water quality and more importantly developed a method that allows for the public to easily voice their concerns about unsatisfactory findings and lax enforcement.
The SDWA requires that the public be notified of the quality of its drinking water. The EPA provides consumers with a list of reports; consumer confidence reports, state compliance reports, and a public database called the Safe Drinking Water Information System (28). The EPA site that contains the links to these reports also lists ways in which consumers can become involved in discussions about the quality of their drinking water. The major flaw in this method of public notification is that it is an individual approach to involving the consumer in the discussion. The title of the EPA’s campaign implies the very individual nature of the intervention: “It’s Your Drinking Water: Get to Know it and Protect it!” (28). EPA officials make the assumption that the public will decide that the risks of being exposed to contaminants in their drinking water will outweigh the inconvenience of speaking up and demanding clean water. This approach however, is not a successful one. It assumes too much.
The EPA asks the public to “Be Informed, Be Observant, and Be Involved” in order to protect public drinking water (23) on their Protect Your Drinking Water For Life page of their website but it places too much responsibility on the individual to create a demand for clean drinking water. The EPA has to continue to provide the information but make it easier for the public to get involved in process of strengthening the public’s water system.

Critique 3: Lack of Imagery

Turn on the tap in most households and more often than naught, the water that pours from the tap is clear, odorless, and free of any bad taste. Toxic water does not have to look, smell, or taste toxic. Occasionally you might hear on the news that a city or town is on notice to boil its tap water because of a discovery that its drinking water is contaminated (it happened in my home in Gloucester last summer) but it appears that there isn’t ever any lingering affect of this information on the non-affected public. The fact that the issue is not clearly identifiable makes it difficult for clean drinking water advocates to gather public support.
Commercial brands often incorporate some form of visual or verbal cue that triggers a memory of their product when mentioned or viewed. Blitstein, Evans, and Driscoll wrote that because public health initiatives may require this type of cue even more than commercial products because unlike commercial brands, public health brands are selling an intangible product (1).
Currently the EPA uses the imagery that its water is free of contaminants and is completely safe to drink. Throughout the website there are pictures of crystal clear water being poured into glasses by children and elderly people as well as pictures of employees dutifully treating the public water at water systems. The fact that people’s drinking water is not safe however invalidates the promise that these images make. The EPA does not use imagery that invokes a memory in consumers of why there is a danger of toxic tap (i.e. industry leaders battling enforcement and strengthening of SDWA). The public needs more than a list of contaminants that are present in their water. Advocates for safe drinking water need to supply the public with some form of imagery that can assist them with remembering the dangers that may be present in their drinking water.

Intervention

Currently the EPA essentially relies on the belief that providing consumers of public drinking water with data on the quality of the water provided to them from public treatment systems is sufficient in gaining their support to improve enforcement. My intervention to assist strengthening the SDWA would focus its efforts on getting the public to believe that the law’s increased strength and enforcement was necessary in maintaining their core values. This is necessary because currently industry leaders are framing the argument in a way that any amendments strengthening the SDWA would adversely affect the public’s core values. The reframed argument could position the need to strengthen the SDWA by highlighting these values:
*Freedom: What is more basic than the thought that you should be able to turn on your tap water, fill a glass, and give it to your child? The intervention would reframe the argument so that a weakened SDWA threatens this freedom.
*Independence: A strong and effective SDWA will allow you to drink or use tap water when and however you want. A weakened SDWA limits that independence by forcing you to have to boil your water before using it or going to the store to buy bottled water. A strong and effective SDWA gives you the independence in that you do not have to depend on clean water to be brought to your home or community from other sources.
*Control: Strengthening the SDWA gives you and not the gas and oil industry control over your health and the health of your children.
*Fairness/Equality: Clean drinking water should be something that all Americans have access to but yet some have this access and other do not. The intervention can frame the issue so that a weakened SDWA threatens the equality that everyone should have access to clean drinking water.
(framework templates based on those used in Siegel-22)
Reframing the argument for strengthening the SDWA should increase public support for the issue. If successful, the next step of the intervention would be to increase public involvement in demanding that the bill is enforced at the very minimum but ultimately strengthened to actually achieve its goal of making drinking water clean. The EPA and/or the State do a very good job of providing the consumer with data about their drinking water but as my critique pointed out, more is needed than simply providing the data and assuming that the consumer will act on it. This portion of the intervention would include:
*A template letter that can be sent from the EPA website to the consumer’s Federal and State legislators. The template would be available when contaminant levels were in excess or when polluters were found to be unpunished. The template would include all of the necessary information (i.e. contaminants X, Y, Z were found at levels above the recommended levels or Company A was found to have violated the SDWA by contaminating the public drinking water and has yet to pay a fine).
*The EPA can provide the public with test kits that test for contaminants that are not currently regulated under the SDWA. The test kits can test for a handful of contaminants so that it is not overwhelming. Each kit can come with contact information of legislators. The thinking here is that if a consumer can see first hand what is in their water, then they might take more ownership over the process of strengthening the SDWA.
Finally, the intervention must create some form of imagery in order to make the issue resonate with consumers. The EPA needs to create the image that it is there to serve the people by protecting them from industries that seek profit over public safety. This intervention would use imagery similar to that used in the Mass Department of Public Health and American Cancer Society advertisements against smoking. By highlighting some of the illnesses and hardships brought about by contaminated drinking water, the intervention would attempt to trigger a visceral response in the public. The advertisements could use stories used in the New York Times articles on toxic waters that describe a child who develops painful rashes from the contaminants in his bathwater (5). These contaminants are from the local coal company. The intervention could also use similar techniques as those used in the Truth campaign such as placing oil and gas industry leaders in advertisements that highlights their disregard for public health.

Defense of Intervention Section 1: Frame-setting

Altering the frame of the argument is key to garnering the support of the public behind public health initiatives, which in turn can be an effective tool towards coaxing lawmakers to examine potential changes in the current legislation. The findings of Martino, et al revealed that humans tend to make decisions based on the frame in which those decisions are made. In their study, they found that people were more likely to gamble when they were in a “loss” frame and more likely not to gamble when placed in a “gain frame” (3). Successfully reframing an issue not only frames the argument but also suggests the solution (22).
The group Mothers Against Drunk Driving (MADD) is an excellent example of how public pressure can force reticent legislators to participate in a public health intervention (16). MADD was established in 1980 and has been involved in the creation of multiple pieces of legislation aimed at protecting public health by reducing fatalities related to drunk driving. Some of these include raising the minimum drinking age to 21, increasing health risk warnings on alcohol packaging, and reducing the legal blood-alcohol limit in several states (16).
Establishing anti-smoking legislation is another excellent example of how public pressure can influence legislation that affects public health. Public health advocates have been able to use the growing support of anti-smoking citizens to establish legislation that limit the negative effects of smoking. These initiatives include limiting smoking in restaurants and workplaces, reducing tobacco advertisements in magazines, and strengthening rules that make it difficult for underage kids to purchase tobacco products.
Both of these initiatives were able to reframe the way in which the public health question was being presented in legislation. The arguments were framed in such a way that the legislation was essential in maintaining the core values of the individuals. For example, every employee should have the freedom to work in an environment that will not adversely affect their health or everyone should have the freedom to not have their lives shortened by a drunk driver.

Defense of Intervention Section 2: Dependence on individual participation

Public health initiatives that are based on the belief that consumers will act rationally to protect their health and well being are seldom successful. Successful interventions strategies cannot assume that consumers will digest information and incorporate it into behavior changes in their life. The Health Lifestyle Habits study conducted on US adults between 1988-2006 is a perfect example of this. The study revealed that even though an abundance of evidence linking a healthy lifestyle with a decrease in cardiovascular disease was available, only a small number of Americans adhered to these measures (15). A study on the effects of the National Youth Anti-Drug Media Campaign found that an increased exposure to information about the consequences of drug use were for the most part ineffective, and in one sample actually increased pro marijuana use intentions (13). A similar effect can be witnessed in HIV prevention programs in the MSM community that have at the core of their intervention strategy the need to use condoms each and every time that intercourse takes place (21). The rising rate of HIV infection among the MSM community is evidence that such interventions are ineffective.

Defense of Intervention Section 3: Use of imagery

Opponents of smoking used vivid imagery to persuade the public to pay closer attention to the dangers of smoking. The American Cancer Society posted a posthumous video from Yul Brynner pleading with the public to avoid smoking because it killed him. The Massachusetts Department of Public Health took the story of one dying smoker to create moving anti-smoking commercials. The commercials depicted a young woman named Pam Laffin who despite being only 31 when she died looked much older. The commercials depicted the ultimate truth about smoking risk: smoking kills people in their 30s, addiction occurs rapidly and is severe, and smoking kills mothers (17, 18, 30). The Truth campaign used imagery in their anti-tobacco campaign. Truth used the image of a youth rebelling against the tobacco corporations to successfully meet aspired self-image of the public’s youth. In doing so the campaign was able to shift tobacco use behavior among young people (9).
Mothers Against Drunk Driving has posted numerous public service announcements focusing on the lives of children who have been ended because of a drunk driving incident. These PSAs do not consist of statistics that are easily forgotten about. They contain video montages of the laughing children or teenagers who became victims to drunk driving. MADD PSAs use a repetitive message to emphasize what is at stake if drunk driving is not considered a serious threat to public health.
Corporate products that have created successful marketing campaigns have usually used some method of imagery to enhance the ideal that their product is selling. The Marlboro Man sold the ideal of individuality and ruggedness. The silhouette of Michael Jordan that Nike uses sells the belief that wearing Nike products will give the consumer the feeling that they can fly through the air with grace and agility. According to Evans and Hastings, imagery can be a central component in creating associations with a product (9).

Conclusion

Access to clean drinking water should be something that nobody should worry about in the United States. Unfortunately this is not a reality. The Safe Drinking Water Act is a robust piece of legislation that is responsible for ensuring clean drinking water but it is not comprehensive enough nor is it enforced consistently. The EPA, as the public health officials for this issue need to reframe the argument so that consumers realize that their core values of freedom, control, and independence are threatened if the SDWA is not strengthened. The EPA also must develop a method involving more than just providing data about water to the public. This assumption that the public will act in a rational manner is flawed.

References

1. Blitstein JL, Evans WD, Driscoll DL. “What is a Public Health Brand?” Public Health Branding: Applying Marketing for Social Change (Chapter 2). Oxford: Oxford University Press, 2008, pp 25-41.

2. Deadline on the BAC Debate: Lobbyists Argue Effectiveness of the 0.08% BAC in Curtailing Drunk Driving. There’s No Question About Its Effect on Restaurant’s Bottom Lines. Restaurants and Institutions. 15 Aug 1997.

3. De Martino B, Kumaran D, Seymour B, and Dolan RJ. “Frames, Biases, and Rational Decision-Making in the Human Brain.” Science Vol. 313 (Aug 2006): 684-687.

4. Duhigg, C. “Millions in U.S. Drink Dirty Water, Records Show.” The New York Times. Web. 7 December 2009.

5. Duhigg, C. “Clean Water Laws Are Neglected, at a Cost in Suffering.” The New York Times. Web. 12 September 2009.

6. Duhigg, C. “That Tap Water is Legal but May be Unhealthy.” The New York Times. Web. 16 December 2009.

7. Earthworks. “Hydraulic Fracturing 101.” http://www.earthworksaction.org/FracingDetails.cfm

8. Energy Tomorrow. “Hydraulic Fracturing.” Copyright 2009.
http://www.energytomorrow.org/Hydraulic_Fracturing.aspx

9. Evans WD, Hastings G. “Public Health Branding: Recognition, Promise, and Delivery of Healthy Lifestyles.” Public Health Branding: Applying Marketing for Social Change. 3-24. Oxford University Press, Oxford. 2008.

10. “Frank Panico Opposes The Adoption Of A Tough New National Standard For Drunk Driving.” Business News New Jersey. Vol. 11. 16 March 1998. Pg. 13.

11. Govtrack.us. “H.R. 2766: Fracturing Responsibility and Awareness of Chemicals Act of 2009.” http://www.govtrack.us/congress/bill.xpd?bill=h111-2766

12. Heare, S. F. “Hydraulic Fracturing: Regulatory and Policy Considerations.” National Association of Regulatory Utility Commissioners. 15 February 2010.

13. Hornik, R., Jacobsohn, L., Orwin, R., Piesse, A., and Kalton, G. “Effects of the National Youth Anti-Drug Media Campaign on Youths.” American Journal of Public Health Vol. 98 No. 12 (Dec 2008): 2229-2236.

14. Industrial Minerals Association North America. “Hydraulic Fracturing Exclusion from the Safe Drinking Water Act.” Copyright 2009.
http://www.ima-na.org/Hydraulic-Fracturing-Exclusion-from-the-Safe-Drinking-Water-Act

15. King, D., Mainous III, A.G., Caremilla, M., and Everett, C. J. “Adherence to Healthy Lifestyle Habits in US Adults, 1988-2006.” The American Journal of Medicine Vol. 122 No. 6 (Jun 2009): 528-534.

16. Mothers Against Drunk Driving. http://www.madd.org/

17. Pam Laffin-Difference. Massachusetts Department of Public Health.
http://www.youtube.com/watch?v=F3D3NnLXYNg&feature=related

18. Pam Laffin-Kids. Massachusetts Department of Public Health.
http://www.youtube.com/watch?v=i3VVfTaHdcI

19. Policy Facts: U.S. Department of Energy National Energy Technology Laboratory. “More Restrictive Regulation (Hydraulic Fracturing) Could Impact Natural Gas Supply.” June 2001.

20. ProPublica. “What is Hydraulic Fracturing?” http://www.propublica.org/special/hydraulic-fracturing

21. Siegel, M. and Lotenberg, L. D. “The Importance of Formative Research in Public Health Campaigns: An Example from The Area of HIV Prevention Among Gay Men.” Marketing Public Health. 73-78. Jones and Bartlett Publishers, Boston. 2007.

22. Siegel, M. and Lotenberg, L. D. “Marketing Public Health-An Opportunity for the Public Health Practitioner.” Marketing Public Health. 127-152. Jones and Bartlett Publishers, Boston. 2007.

23. The United States Environmental Protection Agency. Protect Your Drinking Water for Life. http://www.epa.gov/safewater/publicoutreach/index.html

24. The United States Environmental Protection Agency. Understanding the Safe Drinking Water Act fact sheet. http://www.epa.gov/safewater/sdwa/pdfs/fs_30ann_sdwa_web.pdf

25. The United States Environmental Protection Agency. Safe Drinking Water Act Amendments of 1996: General Guide to Provisions. http://www.epa.gov/safewater/sdwa/summ.html#3G

26. The United States Environmental Protection Agency. Regulation & Guidance: Current Drinking Water Rules.
http://www.epa.gov/safewater/regs.html#current

27. The United States Environmental Protection Agency. Public Access to Information & Public Involvement fact sheet.
http://www.epa.gov/safewater/sdwa/pdfs/fs_30ann_publicinvolve_web.pdf

28. The United States Environmental Protection Agency. It’s Your Drinking Water.
http://www.epa.gov/safewater/consumer/itsyours.html

29. The United States Environmental Protection Agency. Drinking Water Monitoring, Compliance, and Enforcement fact sheet.
http://www.epa.gov/safewater/sdwa/pdfs/fs_30ann_monitoring_web.pdf

30. Yul Brynner-Anti Smoking Commercial. American Cancer Society.
http://www.youtube.com/watch?v=JNjunlWUJJI