Virginia Department of Health (VDH)

Role

The Virginia Department of Health (VDH) is the state agency responsible for protecting and promoting the health of Virginians. VDH tracks disease outbreaks, assesses environmental exposures, and communicates health risks to the public. In this capacity, the agency serves as an institutional authority on how industrial activities, pollution, and environmental conditions affect community health—particularly in regions experiencing sustained environmental burdens.

The VDH operates through a Central Office in Richmond and a statewide network of 35 local health districts and 119 local health departments. The agency employs approximately 3,300 staff statewide, who play a central role in disease surveillance, public health education, emergency preparedness, and the monitoring of environmental health. VDH is led by the State Health Commissioner, who is appointed by the governor and operates within the Department of Health and Human Resources. This leadership structure positions VDH at the intersection of public health, state governance, and regulatory decision-making. VDH works with the Virginia Department of Environmental Quality (VA DEQ) on health issues related to environmental pollution and other hazards.

How does the VDH pick its focus issues? Decisions are based on government mandates, official requests, or pressure from residents and grassroots organizations. The agency's scale, authority, and accreditation give its findings significant weight making its role especially consequential for communities living near industrial infrastructure. However, VDH has faced criticism for not doing enough to advocate for stronger public health protections in the face of mounting evidence of health risks, including on coal dust pollution in Southeast Newport News and Lambert's Point, Norfolk.

Public Health Surveillance and Risk Assessment

VDH is responsible for assessing and monitoring public health outcomes associated with exposures to environmental pollution in Virginia, including those related to coal dust. As part of this mandate, VDH conducts health risk assessments, evaluates environmental monitoring data, and tracks population-level indicators of disease potentially linked to particulate matter exposure. This includes respiratory conditions such as asthma and bronchitis, chronic obstructive pulmonary disease (COPD), and other illnesses.

In the context of coal dust, VDH's role has primarily been to review air monitoring data generated by other entities, most notably the VA DEQ and, in some cases, the coal terminals—and determining whether measured concentrations pose a public health risk, specifically as defined by the National Ambient Air Quality Standards (NAAQS).

Institutional Authority and Public Risk Communication

As Virginia's primary public health authority, VDH's findings carry substantial weight in policy discussions, regulatory decision-making, and public perception. Statements concluding that exposures are "not expected to harm health" often function as de facto endorsements of the status quo, influencing whether additional monitoring, mitigation, or enforcement actions are pursued.

The agency's scale and its national accreditation by the Public Health Accreditation Board (PHAB) further reinforce the authority of its determinations. Accreditation signals institutional capacity and adherence to national public health performance standards, lending credibility to VDH assessments even when they are constrained by limited data, narrow exposure metrics, and contradict residents' lived experience and embodied knowledge.

Data as Potential Evidence for Community Advocacy

VDH's analyses and health data have the potential to serve as powerful tools for community organizations seeking to establish links between coal dust pollution and adverse health outcomes. When interpreted alongside community testimony, independent monitoring, and environmental justice research, VDH data could strengthen arguments for regulatory reform, expanded regulatory air monitoring, and public health interventions in affected neighborhoods. However, this potential is often unrealized. Health assessments have tended to rely on averages in space and time that minimize localized impacts of episodic pollutants, short-term sampling, and compliance-focused thresholds like the NAAQS, rather than on cumulative exposures, hotspots and hot moments, or community-specific vulnerabilities. As a result, data that could be mobilized in support of environmental justice are frequently framed in ways that limit their usefulness for advocacy and accountability.

Environmental Justice

While VDH has acknowledged health impacts associated with particulate matter, critics argue the agency has not sufficiently foregrounded disproportionate impacts, structural inequalities, and the compounding effects of exposure to multiple pollutants by community members.

Environmental justice advocates have criticized VDH for not more forcefully advocating for precautionary protections, expanded health surveillance, or stronger regulatory responses in the face of persistent community concerns and mounting scientific evidence regarding air quality. In this way, VDH exemplifies a broader institutional tension within public health—balancing regulatory compliance and administrative caution against the need to proactively protect communities experiencing chronic environmental harm.

Relevance

Peninsula Health Department Asthma Study, 2005

The Peninsula Health Department is part of the Hampton-Peninsula Health District and serves residents of Newport News and Poquoson. In 2005, the Peninsula Health Department reportedly published a study showing that Southeast Newport News residents visited the emergency room for asthma at a rate double that of both Newport News and Virginia on average. This study continues to be referenced in the news media and by community organizers; however, the document cannot be found online or by Peninsula Health Department, and appears to be lost.

VDH Letter Health Consultation, 2017

Map from the VDH Letter Health Concern. Neither the HRSD or ADMIN monitoring stations are downwind of the Norfolk Southern Pier 6 Terminal when winds blow from the facility into Lambert's Point.

In July 2017, the VDH Division of Environmental Epidemiology, in cooperation with the federal Agency for Toxic Substances and Disease Registry (ATSDR), issued a Letter Health Consultation examining the public health implications of particulate matter measuring 10 micrometers in diameter or less (PM₁₀), also known as dust, collected in Lambert's Point near the Norfolk Southern Pier 6 Terminal.

According to the report, VDH did the consultation because of ongoing community concerns about coal dust originating from Norfolk Southern's coal operations. Under a VA DEQ-approved monitoring plan, Norfolk Southern voluntarily operated three PM₁₀ regulatory monitors at two locations near the Norfolk Southern Pier 6 Terminal between August 2015 and July 2016. The Letter Health Consultation does not indicate the exact location of the PM₁₀ monitors. However, from the map provided by the VDH shown here, the monitors are not positioned to be downwind of most of the Norfolk Southern Pier 6 Terminal on days when winds blow over the facility and into the Lambert's Point neighborhood. The HSRD monitor could be considered a background measurement, as when winds are from the southwest, airflow to this monitor nearly entirely misses the Norfolk Southern Pier 6 Terminal.

The VDH report concluded that PM₁₀ concentrations measured at the monitoring sites were below the NAAQS and therefore "not expected to harm people’s health." The report is illustrative, showing how public health determinations are made within narrow regulatory and technological boundaries, even in the presence of visible environmental harm such as black residues on buildings and persistent community concern. The report framed health risk through NAAQS compliance rather than lived exposure or cumulative burden.

Notably, VDH applied a pervasive misconception about PM₁₀, which is that it is composed of material that is not harmful. It is generally true that as particles get smaller, they penetrate more deeply into our bodies and cause more harm. In fact, there is no known safe level of expose to fine particles (PM_2.5). But PM_2.5 composed of toxic metals is known to be especially harmful, and, for people living near a major source of metals, concentrations of toxic metals in PM₁₀ have been found to correlate with metals concentrations in residents' blood. In the Letter Health Consultation, the VDH relied on conclusions about the health impacts of PM₁₀ derived from research on PM₁₀ composition measurements across six U.S. cities. This research found that typical urban dust was composed of material that was not associated with increased mortality. However, it is a false assertion that coal dust has the same composition as urban dust on average. Such logic would not stand up to scientific peer review.

Finally, community concerns are acknowledged procedurally, but not centered analytically.

Documents

Public Health Implications of PM₁₀ Concentrations Collected near Lambert's Point Coal Terminal, Letter Health Consultation, Division of Environmental Epidemiology, Virginia Department of Health, July 19, 2017

Annual PM₁₀ Monitoring Data Report for Norfolk Southern’s Coal Pier – Lambert's Point, Norfolk, Virginia, Simpson Weather Associates, Inc., October 11, 2016