EDF Health

EDF submits comments for peer reviewers on EPA’s exposure, use and hazard information on five PBT chemicals

Lindsay McCormick, is a Project Manager. Richard Denison, Ph.D.is a Lead Senior Scientist.

Yesterday, EDF filed comments on several draft EPA documents that are part of the basis for developing restrictions EPA is required to impose on five persistent, bioaccumulative and toxic (PBT) chemicals under the 2016 reforms made to the Toxic Substances Control Act (TSCA).  The draft documents are to undergo peer review, and EDF’s comments raise issues we believe peer reviewers need to pay particular attention to.

As required by TSCA section 6(h), EPA last year identified five PBT chemicals (DecaBDE, HCBD, PCTP, PIP (3:1), and 2,4,6 TTBP) that meet the statutory criteria for “expedited action”: By June 22, 2019, EPA must propose a rule to restrict these five chemicals.  Last month, EPA released draft documents for peer review and public comment that summarize available hazard information and assess exposure and use of each of the five PBTs.

Our main points for consideration for the peer review committee are summarized below: Read More »

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Illinois moves forward with critical rules to address lead in water at child care facilities

Lindsay McCormick, Project Manager.

Last week, EDF submitted comments to the Illinois Department of Children and Family Services (DCFS) on the state’s proposed rules for lead in water testing at licensed child care facilities. Our comments focused on what we learned from our pilot in 11 child care facilities, including 4 in the Chicago area.

Even at very low levels, lead can impair brain development, contributing to learning and behavioral problems as well as lower IQs. While national attention on lead in drinking water has spurred action in schools, few states have addressed lead in water in child care settings – even though these facilities serve children at younger, more vulnerable ages.

Illinois is one of seven states that EDF has highlighted in a previous blog for requiring lead in water testing in child care facilities. In January 2017, Illinois General Assembly enacted SB550, establishing a new set of requirements to address lead in drinking water in the state. Under the legislation, Illinois was required to adopt rules prescribing the procedures and standards to assess lead in water in licensed day care homes, day care centers, and group day care homes (herein after “child care facilities”). Read More »

Posted in Drinking Water, lead, Regulation / Tagged , , | Read 1 Response

New report: Tackling lead in drinking water at child care facilities

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

Recent crises around lead in drinking water have focused national attention on the harmful effects of children’s exposure to lead. While the particular vulnerability of children to lead is well understood by most – what might be surprising is that the majority of child care facilities are not required to test their water for lead.

Only 7 states and one city have such regulations on the books. And while the Environmental Protection Agency (EPA) has provided a voluntary guidance, the “3Ts for Reducing Lead in Drinking Water,” for schools and child care, the document has significant gaps in the child care setting – including an outdated action level of 20ppb and little emphasis on identifying and replacing lead service lines.

Given the critical need for more investigation in this area, we conducted a pilot project to evaluate new approaches to testing and remediating lead in water at child care facilities. EDF collaborated with local partners to conduct lead in water testing and remediation in 11 child care facilities in Illinois, Michigan, Mississippi, and Ohio. We have previously blogged about some early takeaways from testing hot water heaters and our preliminary findings from the project. Today, we released our final report, which provides the full results of the pilot and recommendations to better protect children moving forward.

Read More »

Posted in Drinking Water, Emerging Testing Methods, EPA, Health Policy, Health Science, lead, Public Health, Regulation, States / Tagged , , , | Comments are closed

Lead in water at child care facilities: Preliminary results from EDF’s pilot

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

When choosing a child care facility, parents weigh numerous factors – like cost, distance to their home, comfort with the staff – with the goal of providing safe care to their child. Unfortunately, it’s not always easy to know if the facility where the child care program is located itself may present health risks – like lead in the drinking water.

The vast majority of schools and child care facilities are not required to test their drinking water for lead under federal requirements. While much of the attention has been on schools, we find that childcare is relatively overlooked, even though water is the most significant source of lead for formula fed infants. In earlier blogs, we talked about state and local testing requirements and levels in hot water.

We tested at 11 child care facilities and found lead in drinking water in at least one sample at seven facilities above our 3.8 ppb action level, three facilities above 20 ppb, and two facilities above 80 ppb.

To explore lead in drinking water at child care facilities further, EDF conducted a pilot project to investigate new approaches for lead in water testing and remediation in childcare settings.  Our pilot utilized and expanded on EPA’s 3Ts for Reducing Lead in Drinking Water.

We will be releasing a report that will detail our full process, results, and recommendations for addressing lead in water in child care settings. In the meantime, we wanted to share our preliminary takeaways and recommendations below as well as a fact sheet on our project. Read More »

Posted in Drinking Water, lead / Tagged , | Comments are closed

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 »

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

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.

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