EDF Health

EDF requests extension of comment period on TSCA Alternative Testing Strategic Plan due to key document missing from docket

Jennifer McPartland, Ph.D., is a Senior Scientist.  Richard Denison, Ph.D.is a Lead Senior Scientist.

Last night EDF submitted a request to the Environmental Protection Agency (EPA) to extend the public comment period on its draft Alternative Testing Methods Strategic Plan under the Toxic Substances Control Act (TSCA).

EPA held a public meeting about the draft Strategic Plan on April 10, 2018.  At that meeting, Dr. Nancy Beck prominently highlighted an analysis that EPA had received from a stakeholder that she described as robust and extensive, and her description of the analysis suggested that it has or could significantly influence EPA’s consideration of the issues raised by the draft Strategic Plan.  When asked if EPA would make this analysis available to the public, an EPA official stated that it would be made available.  But the analysis has not yet been published to the docket.  The due date for comments on the draft Plan is a week from today, April 26, 2018.

Given the emphasis Dr. Beck placed on the analysis and the apparently extensive nature of it, EDF believes the public should be provided access to the document and ample time to review, and if desired, comment on it.  Hence we have requested that:

1)  EPA publish a copy of the relevant analysis to the docket for the draft Strategic Plan.

2)  EPA extend the public comment period by 30 days after it publishes the relevant analysis in the docket.

Because the deadline is impending, EDF requested that EPA respond to this request within three business days, i.e., by Monday, April 23.

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EDF joins Opening Brief in legal challenge to EPA’s Prioritization and Risk Evaluation Rules

Late yesterday, EDF joined fourteen other Petitioners in filing an Opening Brief in our case challenging EPA’s Prioritization Rule and Risk Evaluation Rule.  The Brief was filed with the U.S. Court of Appeals for the Ninth Circuit.

Our Brief argues that the Toxic Substances Control Act (TSCA), as amended by the Lautenberg Act, requires EPA to comprehensively evaluate a chemical’s hazards and exposures arising from all of its “conditions of use,” a term defined under TSCA as encompassing the chemical’s entire lifecycle from manufacturing and processing to use and disposal.  EPA is then to make a holistic determination of whether the chemical presents an unreasonable risk of injury to human health or the environment, including to potentially exposed or susceptible subpopulations.  EPA’s Rules violate this requirement because EPA asserts unfettered discretion to exclude known or reasonably foreseen exposures and conditions of use from consideration, thereby ignoring potentially important contributors to a chemical’s overall risk.  As a result, the Rules threaten to leave the public—especially vulnerable groups like children, pregnant women, and workers—as well as the environment inadequately protected from the potential risks posed by the thousands of chemicals to which we are exposed every day.

EPA’s response brief in the case is due to the Court on July 5, 2018.  As this litigation proceeds, you can find more information – including all significant legal documents – on EDF’s website.

 

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EDF comments fault EPA for deviating from the law in proposal for states and health professionals’ CBI access

Richard Denison, Ph.D.is a Lead Senior Scientist.

One of the key reforms to the Toxic Substances Control Act (TSCA) made by 2016’s Lautenberg Act was the expansion of who can access confidential business information (CBI) submitted by companies to EPA.  The old law largely limited access to federal government employees and contractors.  Congress recognized the enormous value such information could provide to officials at other levels of government and to health providers and environmental officials treating or responding to chemical releases and exposures.  It therefore mandated that EPA expand CBI access, subject to certain conditions specified in the law.

In March, a full 21 months after passage of the Lautenberg Act, EPA finally issued draft guidance documents setting forth how it intends to meet the law’s mandate to expand access to CBI.  Unfortunately, as has been the case with so many other aspects of TSCA implementation under the Trump administration, EPA got a lot of things wrong in its draft guidance documents.

Yesterday, EDF filed extensive comments raising our concerns over these serious deviations from the law and providing our recommendations for fixing them.   Read More »

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EPA IRIS program receives high marks from the National Academies

Jennifer McPartland, Ph.D., is a Senior Scientist and Ryan O’Connell is a High Meadows Fellow with the Health Program.

Last week the National Academy of Sciences (NAS) published its review of the Environmental Protection Agency’s (EPA) Integrated Risk Information System (IRIS) program, concluding that the program has made strong progress in implementing NAS’ earlier recommendations. As noted by the chair of the NAS committee that led the review, “The changes in the IRIS program over such a short period of time are impressive.”

As I’ve blogged about before, IRIS is a non-regulatory program that provides critical chemical reviews and scientific expertise that help ensure the water we drink, the air we breathe, and the land where we live, work, and play are safe. Offices across EPA and elsewhere in the federal government rely on IRIS, as do states, local governments, and affected communities (see here and here).

“The changes in the IRIS program over such a short period of time are impressive.”

The new NAS report comes four years after its 2014 review, which noted the substantial progress made by IRIS in addressing recommendations from a more critical 2011 review of a draft IRIS assessment of formaldehyde. It is worth noting that half of the committee members involved in the new IRIS review served on the committee that authored the 2011 review.   Read More »

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Monitoring our chemical exposures: Five lessons learned and what’s on the horizon

Lindsay McCormick, is a Project Manager.

Last October, a groundbreaking report concluded that diseases caused by pollution were responsible for 1 in 6 premature deaths in 2015 worldwide.  That’s 9 million deaths caused by environmental pollution – three times more than AIDS, tuberculosis, and malaria combined.

That may seem startling at first, but health outcomes are largely defined by a person’s genes and their environment.  In fact, environmental factors – like ambient and household air pollution, industrial chemicals, and common consumer products – are implicated in health impacts ranging from cancer and asthma to infertility.

Unfortunately, our ability to track an individual’s chemical exposures – also called the “chemical exposome” – lags way behind what we can measure genetically.  And without this information, it is virtually impossible to develop sound policies and evidence-based interventions to reduce harmful exposures and protect health.

But what if everyone could monitor hazardous chemical exposures? What if school children, soldiers, pregnant women, flight attendants, nail salon workers, gas attendants, and those living within just a few miles of industrial sites – or just about anyone – could understand chemical exposures in their personal environment?

This is where EDF comes in. EDF is exploring ways to catalyze development and scaling of breakthrough technologies capable of detecting an individual’s exposure to a broad spectrum of chemicals—making the invisible, visible.

Our efforts began three years ago, with a series of pilot projects in which people wore a simple silicone wristband capable of detecting over 1,400 chemicals in the environment. Today, we’re collaborating with diverse stakeholders to identify needs and opportunities for accelerating broad uptake of chemical exposure monitoring technologies. Below are five important lessons to jump-start this opportunity. Read More »

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Heavy metals in food: Carrageenan as an example of the need to improve ingredient quality

Tom Neltner, J.D., Chemicals Policy Director, and Maricel Maffini, Ph.D., Independent Consultant.

Arsenic, cadmium and lead levels in carrageenan varied widely but were within international standards. This is not reassuring since current specifications for the heavy metals are inadequate. Food manufacturers can and should set tighter limits to better protect their customers. Consumers, especially those buying from internet-only retailers, need to ask the ingredient supplier how much of the heavy metals is acceptable.

In the fall of 2013, the Food and Drug Administration (FDA) bought 10 samples of carrageenan from 5 companies sold through internet-only retailers to test for three heavy metals – lead, arsenic (total and inorganic), and cadmium. The agency published the results on its combination metals testing webpage in September 2016.

Each of these metals are carcinogens. In addition, lead and inorganic arsenic are widely acknowledged as harming children’s brain development even at low levels of exposure. EDF found that more than one million children consume lead in amounts that exceeds the maximum exposure level set by FDA in 1993, a level that subsequent research shows is of great risk to children’s health. Further, recent research has strengthened evidence of the relationship between low levels of lead exposure in adults and cardiovascular deaths. In 2011, the Joint FAO/WHO Expert Committee on Food Additives (JECFA) took the extraordinary step of withdrawing its previous tolerable intake level for lead because it could not determine a safe level of exposure for children.

In light of these risks, we must make every effort to reduce the levels of these heavy metals in food to the greatest extent possible – without undermining other food safety measures or compromising quality. A key step to success is examining the levels of heavy metals in all ingredients used to make a food since the risk is based on the cumulative exposure – even if the amounts in individual additives are small. With this in mind, we revisited FDA’s analysis of carrageenan.

Read More »

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