Does representative hazardous-waste-site testing tend to follow or to violate government technical guidance? This is an important question, because following such guidance promotes reliable risk analysis, adequate remediation, and environmental-justice and -health protection. Yet only government documents typically address this question, usually only when it is too late, when citizens have already exhibited health harm, allegedly from living or working near current/former hazardous-waste sites. Because no systematic, representative, scientific analyses have answered the preceding question, this article begins to investigate it by posing a narrower part of the question: Does representative US testing of volatile-organic-compound (VOC) waste sites tend to follow or to violate government technical requirements? The article (i) outlines US/state-government technical guidance for VOC testing; (ii) develops criteria for discovering representative US cases of VOC testing; (iii) uses the dominant US Environmental Protection Agency method to assess whether these representative cases follow such guidance; (iv) employs the results of (iii) to begin to answer the preceding question; then (v) discusses the degree to which, if any, these results suggest threats to environmental health or justice. Our initial, but representative, results show that almost all US VOC-waste-site testing (that we investigated) violates government technical requirements and systematically underestimates risks, and this may help justify less expensive, potentially health-threatening cleanups, mostly in environmental justice communities. We outline needed future research and suggest two strategies to promote following government technical guidance for hazardous-waste testing.
Keywords: Trammell Crow (TC); environmental justice (EJ); hazardous waste; soil-gas testing; trichloroethylene (TCE); vapor intrusion; volatile organic compound (VOC); weight of evidence method (WoE).