EDF Health

EDF files comments on EPA’s approaches to the process under TSCA formerly known as pre-prioritization

Lindsay McCormick, is a Project Manager.

Last week, EDF filed detailed comments to the Environmental Protection Agency (EPA) on the approaches it has presented for identifying potential candidates for prioritization under TSCA.

EDF believes the purpose of prioritization is to provide an orderly, transparent process for EPA to use in working its way through the huge backlog of chemicals needing risk reviews and to provide an accountable means by which EPA decides which chemicals need full risk evaluations and which have ample information at the time of the prioritization decision indicating they can be set aside absent new information.  Our comments argue for a simple process for identifying potential candidates for prioritization that:

  • is not overly formalized or regimented;
  • ensures sufficient information is available or will be developed in a timely manner to inform prioritization, and subsequently risk evaluations, through robust and early use of EPA’s section 4, 8 and 11 information-generation and information-gathering authorities;
  • proceeds at an incremental pace to build trust and gain experience, and preserve balance between high- and low-priority designations; and
  • allows EPA to routinely meet deadlines for making priority designations and completing risk evaluations on high-priority substances.

In light of these objectives, EDF recommends using an augmented TSCA Work Plan approach to identify potential high-priority candidates. The earlier methodology would need to be updated to incorporate statutory requirements not previously included – or not sufficiently addressed (e.g., exposure to children) – and to integrate new information.

We also believe EPA could use the Safer Choice Ingredient List (SCIL) as a starting point for identifying a comparable number of low-priority candidates.  However, EDF does not believe that the presence of a chemical on the SCIL list alone is at all sufficient for designating it as low-priority.  Rather, the SCIL list may help EPA identify a select number of candidates, which would need to undergo a much more robust evaluation to determine whether they meet the strict statutory requirements for low-priority designations.

For additional detail, check out our full comments.

Posted in EPA, TSCA Reform / Tagged , | Comments are closed

EDF submits comments on Oregon’s proposed rules for lead testing in child care centers

Lindsay McCormick, Project Manager and Tom Neltner, J.D.Chemicals Policy Director

EDF recently submitted comments to the Oregon Department of Education’s Early Learning Division regarding the state’s proposed rules for lead testing for water in licensed and regulated child care centers.

Children are particularly vulnerable to lead exposure: even very low blood lead levels can impair normal brain development, contribute to learning and behavioral problems and lower IQs.

While national attention on lead in drinking water has spurred action to address lead in schools, fewer states have addressed lead in water in child care settings – even though these centers serve children at their most vulnerable ages.

Read More »

Posted in Drinking Water, Health Policy, lead, Public Health, States / Tagged , , , | Comments are closed

CBS News covers a chemical's tragic impact; points to urgent need to ban high-risk uses of methylene chloride

Lindsay McCormick is a Project Manager.  

This morning, CBS News focused on the tragic story of Kevin Hartley—a young man who died at the age of 21 while working with a product that contains methylene chloride. Kevin’s story, powerfully relayed by his mother Wendy, illustrates the need to ban high-risk uses of this chemical.

As we have previously noted, in January, the Environmental Protection Agency (EPA) proposed to ban methylene chloride in paint and coating removal products. The agency based its proposal on an extensive assessment of the scientific literature, which demonstrated not only lethal risks from acute exposures to methylene chloride but also a host of other acute and chronic health impacts, like harm to the central nervous system, liver toxicity, and cancer.

Products containing this chemical can be readily found in most hardware stores in America and more tragedies are all but certain, if EPA does not promptly finalize its proposed ban.

The ongoing debates in Washington over the implementation of a new chemical safety law passed just last year are often dense and dry. In sharing her son Kevin’s story, Wendy Hartley reminds us that how these policies are applied has a very real human impact. That is why EDF continues to demand EPA better protect American families from toxic chemicals like the one highlighted by CBS News today.

Please watch the story: https://www.cbsnews.com/news/dangers-of-common-paint-stripper-chemical-methylene-chloride/

Posted in EPA, Public Health, TSCA Reform / Tagged , , , | Read 1 Response

More questions for EPA on identifying chemicals for prioritization under TSCA

Lindsay McCormick is a Project Manager.  

When EPA finalized its framework prioritization rule under TSCA last June, the agency deleted its proposed approach to identifying potential candidate chemicals for prioritization.  EDF had supported EPA’s initial proposed rule, and EPA’s decision to delay this process to allow for additional stakeholder engagement tracks closely with the comments chemical industry groups submitted on that proposed rule.

EPA is now holding a public meeting on December 11th to discuss its proposed approaches and get input from stakeholders.  As with the upcoming meeting on new chemical reviews, EPA is accepting questions ahead of the meeting.

In response, EDF submitted a number of questions to the agency on Monday, relating to our concerns in the following areas:

  • EPA’s stated intention to significantly exceed its statutory minimum of designating 20 low-priority chemicals within the law’s specified timeframe.
  • EPA’s passive approach to utilizing its new authorities to fill data gaps on chemicals before they enter the prioritization and risk evaluation processes.
  • The need to ensure transparency with respect to health and safety studies and underlying data used by EPA to identify candidate chemicals for prioritization.
  • Specific concerns regarding EPA’s proposed approaches, including to utilize Canada’s Chemicals Management Plan as a model and to use EPA’s Safer Chemicals Ingredient List (SCIL) as a basis for identifying low-priority chemicals.

Read our full list of questions here for more details.

Posted in EPA, Health Policy, Regulation, TSCA Reform / Tagged , | Comments are closed

Another tragic death — time for EPA to ban high-risk chemical paint strippers

Lindsay McCormick is a Project Manager.  

A few weeks ago, a 21-year-old man tragically passed away after being overcome by chemical fumes while refinishing a bathtub.  The young man was working for a small painting business in Tennessee.  His death is currently being investigated by the Occupational Safety and Health Administration (OSHA), but is suspected to have been caused by methylene chloride exposure.  If confirmed, this would add to the dozens of reported deaths caused by the chemical’s use in paint stripping products over the past several decades.

The Environmental Protection Agency (EPA) has within its grasp the ability to prevent this type of tragedy from happening again. In January, EPA proposed to ban methylene chloride in paint and coating removal products – including those used for bathtub refinishing, and is considering a ban on such use of another highly toxic chemical called N-methylpyrrolidone.  The agency based its proposal on an extensive assessment of the scientific literature, which demonstrated not only lethal risks from acute methylene chloride exposure but also other health impacts from both short- and long-term exposure to both chemicals.

Products containing these chemicals are available at hardware and other retail stores across the country, and unless EPA acts promptly to finalize a ban, there will surely be more avoidable deaths and other health impacts due to use of high-risk chemical paint strippers.  In EDF’s recent comments to EPA, we strongly urged it to finalize these bans as soon as possible to protect public health.  EPA should not wait for another reason to take action.

Posted in EPA, Regulation / Tagged , | Read 1 Response

Toxic Exposures: 10 Americans expose the toxic chemicals in our environment

Every day we are exposed to potentially hazardous chemicals we can’t see —chemicals used in everything from the clothes we wear to the lotions we use and even the couch we sit on. Synthetic chemicals are used to make 96% of products in the United States. Yet scientific research continues to link chemicals in common use to health effects like cancer, infertility, and asthma.

EDF selected 10 individuals across the country to wear a novel wristband technology designed to detect chemicals in their environment for one week – including Gordon, Karen, and Averi.


Gordon is a lieutenant for the Memphis Fire Department. Gordon’s wristband detected 16 chemicals, including gamma-chlordane, a pesticide that has been banned in the U.S. since the 1980s, and 3,4-dichlorophenyl isocyanate, a “chemical intermediate,” which is reportedly used exclusively for chemical manufacturing processes. While there were no fires to fight the week he wore the wristband, Gordon wondered if he came into contact with these chemicals from a site visit to a location that formerly housed chemical stockpiles, his local auto repair shop, the nearby highway – or even his fire suit.

Read More »

Posted in Emerging Testing Methods, Environment / Tagged | Comments are closed