Richard Denison, Ph.D., is a Lead Senior Scientist. Rachel Shaffer is a research assistant.
[UPDATE 6/24/14: Perhaps in response to this post of last week, an updated agenda for this week's IRIS meeting was posted by EPA today that reflects a somewhat more balanced set of speakers. Industry interests appear to have consolidated their number of slots, down from a high of 8 to a high of 6 per issue, and down from a high of 6 to a high of 4 individuals per issue from the same consulting firm. In addition, several additional slots are assigned to non-industry speakers. If you wish to see the changes, here is the agenda we linked to that was current as of last week, and here's the updated agenda posted today.]
In comments EDF made at a November 2012 stakeholder meeting held by EPA’s Integrated Risk Information System (IRIS) program, we warned that the tendency of the IRIS program to respond to criticism by expanding opportunities for “public” input would serve to increase rather than decrease the imbalance in stakeholder input.
We noted that providing more opportunities for participation not only lengthens the timeline for completing assessments; it also virtually ensures the input received by EPA is imbalanced and badly skewed toward the regulated community. That’s because companies that produce and use each chemical to be assessed – and the trade associations and myriad hired consultants that represent them – have a clear vested financial interest in the outcome of the assessment. They can and will take advantage of each and every opportunity for input, and they will be better represented than other stakeholders each and every time.
IRIS recently began holding bimonthly meetings focused on “key science issues” relating to upcoming assessments. And guess what? An army of industry representatives, including staff for trade associations and paid consultants, are overwhelming the agendas.
Exhibit A: Have a quick look at the list of speakers in the agenda for this month’s bimonthly meeting. A striking imbalance, no? As many as 8 industry representatives are set to speak on a given issue, including 6 from the same consulting firm! [UPDATE 6/24/14: See the top of this post for a description of the updated, slightly more balanced agenda; here is the agenda we had linked to that was current as of last week, and here's the updated agenda posted today.]
It isn’t only EDF that has raised this concern. In its just-issued review of the IRIS program, Review of EPA's Integrated Risk Information System (IRIS) Process (p. 5), the National Academy of Sciences’ National Research Council (NRC) recognized the same problem, warning that “not all stakeholders who have an interest in the IRIS process have the same scientific or financial resources to provide timely comments, and expanded opportunities for stakeholder involvement might lead to a further imbalance of public input.”
Achieving balance involves more than just improving accessibility; it also requires ensuring that actual participation is balanced, through placing speaking limits on overrepresented stakeholders and undertaking explicit outreach and providing support to underrepresented stakeholders. In its seminal 2009 report, Science and Decisions: Advancing Risk Assessment (p. 13), the NRC advised EPA to develop “incentives to allow for balanced participation of stakeholders, including impacted communities and less advantaged stakeholders.”
Similarly, in its 2014 review of the IRIS program, the NRC specifically suggested that the Agency look to efforts like the Superfund Program’s Technical Assistance Grants (TAGs) as models to support participation from a more diverse range of individuals.
EDF appreciates the IRIS program’s intent to streamline the assessment development process by providing an early, upfront opportunity for stakeholder input. However, without accompanying efforts to ensure more balanced participation, these opportunities can make matters worse rather than better.
We urge the EPA to immediately initiate steps to mitigate this growing and disconcerting imbalance. In conjunction with implementing these NRC recommendations regarding balancing input and resource assistance, Agency officials should also develop more effective approaches for soliciting input from relevant scientific experts and academic researchers to ensure better balance of participation.
Otherwise, a well-intended step becomes a further factor undermining confidence in EPA’s IRIS program.