EDF Health

EPA’s final risk evaluation of trichloroethylene is scientifically flawed and understates risks to workers, the general public and those most susceptible

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

Today the Trump Environmental Protection Agency (EPA) issued its final risk evaluation for trichloroethylene (TCE).  It largely tracks the agency’s draft document, retaining numerous flaws that severely understate the highly toxic chemical’s risks to workers, the general public and those most susceptible to its health impacts.

Among the evaluation’s most serious deficiencies is the abandonment of a bedrock principle of chemical risk assessment: that risk estimates be based on the most sensitive health effect.  Sadly, the final document retains the unprotective approach the Trump White House forced EPA to adopt, as reported in detail by Elizabeth Shogren of Reveal News.

Exposure to TCE is ubiquitous, coming from ambient and indoor air, vapor intrusion from contaminated sites, groundwater and drinking water wells, and food – yet EPA’s evaluation ignores or downplays each of these exposure sources and pathways.

Below we summarize some of the major concerns in EPA’s evaluation that we addressed in detail in our comments.

One silver lining:  Despite its glaring deficiencies, the risk evaluation did find that the great majority of TCE’s conditions of use present unreasonable risks—even as it grossly understated the extent of those risks.  As a result, EPA must now proceed to regulate those activities, providing the new Administration an opportunity to rectify the serious problems created by the Trump EPA.  Read More »

Also posted in EPA, Health Policy, Industry Influence, TSCA Reform / Tagged , | Leave a comment

New study: Lead reduction prevented up to 99,000 heart disease deaths in 2014 alone

Tom Neltner, J.D., Chemicals Policy Director

EPA needs to estimate reduced heart disease deaths when it evaluates the merits of four upcoming rules addressing lead in water, paint, and air.

In 2018, we blogged on a study by Lanphear et al. that linked adult blood lead to a jaw-dropping 400,000 heart disease deaths annually. We called on federal regulatory agencies to give serious consideration to this and similar studies to develop a model they can use to quantify the socioeconomic benefits of potential regulatory changes designed to reduce adult exposure to lead. In June, 2019, the Environmental Protection Agency (EPA) successfully completed the necessary peer review of a model. The review was completed too late to be incorporated into the agency’s proposed revisions to its Lead and Copper Rule (released October 2019), but we applied the analysis to estimate that replacing all lead service lines in the nation over ten years would provide societal benefits of more than $205 billion – and called on EPA to consider the benefits when finalizing the rule.

Last week, Abt Associates, EPA’s contractor[1] who developed the initial peer-reviewed model, published a refined model in Environmental Health Perspectives and used it to estimate that between 34,000 and 99,000 cardiovascular disease (CVD)-related deaths were avoided in 2014 due to reduced adult blood lead levels from 1999 to 2014. The analysis reports that between 16% and 46% of the overall reduced CVD deaths during those 15 years was attributable to reduced lead in adult blood. Read More »

Also posted in Emerging Science, lead / Tagged | Comments are closed

EPA flouts the law, science, and its obligation to protect public health yet again: The 1-bromopropane final risk evaluation

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

Today, the Trump EPA released its second final risk evaluation and determination under the reformed TSCA, for the carcinogenic solvent, 1-bromopropane (1-BP).

EPA has once again ignored expert scientific input it received from its own advisors.

As was the case with the final document for methylene chloride – which has already been challenged in court (see here and here) – EPA has doubled down on the illegal, unscientific, and un-health protective approach it has taken in all of its draft risk evaluations for the first 10 chemicals reviewed under TSCA.

EDF will be closely examining this final document, but it is already apparent that EPA continues to grossly and systematically underestimate the exposures to and risks of 1-BP to the general public, workers and the environment.

Below are four examples of the flaws; each was raised by EPA’s own Science Advisory Committee on Chemicals (SACC) in its peer review as serious deficiencies – expert scientific input that EPA has simply chosen to ignore in finalizing the document:  Read More »

Also posted in EPA, Health Policy, Industry Influence, Public Health, Regulation, TSCA Reform, Worker Safety / Tagged , | Read 1 Response

Greasing the skids: The Trump EPA is green-lighting dozens of new PFAS under TSCA

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

Under an obscure and opaque – and increasingly used – exemption that EPA provides under the Toxic Substances Control Act (TSCA), EPA has been quietly approving companies’ requests to introduce new poly- and per-fluorinated substances (PFAS) onto the market.  And it seems to be ramping up.

Under this EPA the “low-volume exemption” (LVE) application process is proving to be very smooth sailing for getting new PFAS onto the market.

PFAS is a class of chemicals that are showing up as environmental contaminants all over the country.  They are linked to large and growing list of adverse effects on human health.  These concerns have led to increased scrutiny about EPA’s actions to allow new PFAS to enter commerce.  EDF and others have raised concerns about a number of premanufacture notices (PMNs) companies have filed seeking approval to introduce new PFAS into commerce (see here and here); the PMN process is the standard way in which companies are to notify EPA of their intent to start manufacturing a new chemical.

But EPA has created other pathways to quickly get a chemical on the market, whereby companies can apply for an exemption from the PMN process.  As documented in this post, we have identified a whole lot of PFAS coming into EPA’s new chemicals program through exemptions, and most of them are getting quickly approved.  Worse yet, this side process is highly insulated from public scrutiny.  Read More »

Also posted in EPA, Health Policy, Industry Influence, PFAS, Regulation, TSCA Reform / Tagged | Comments are closed

“Illegal, unscientific, and un-health protective”: Summing up EPA’s final methylene chloride risk evaluation

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

Today, the Trump EPA released its first final risk evaluation and determination under the reformed Toxic Substances Control Act (TSCA), for the carcinogenic and acutely lethal chemical methylene chloride.

Sadly, despite EPA’s rush to issue this document as the 4th anniversary of TSCA reform on June 22 approaches, EPA doubled down on the illegal, unscientific, and un-health protective approach it has taken in all of its draft risk evaluations for the first 10 chemicals reviewed under TSCA.

EDF will be closely examining this final document, but it is already apparent that EPA has grossly and systematically underestimated the exposures to and risks of methylene chloride.  Read More »

Also posted in EPA, Health Policy, Industry Influence, Public Health, Regulation, TSCA Reform, Worker Safety / Tagged , , | Comments are closed

The Trump Administration’s got a problem with testing (TSCA edition)

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

A constant criticism of EPA’s draft risk evaluations for the first 10 chemicals has been the dearth of information on which EPA has relied to draw sweeping, unqualified risk conclusions.  EDF and other stakeholders, as well as EPA’s own Science Advisory Committee on Chemicals (SACC), have repeatedly pointed to the lack of sufficient, reliable information on:

The Trump EPA appears intent on continuing to conduct risk evaluations that are ill-informed by actual data.

  • the chemicals’ presence in and releases into various environmental media;
  • their presence in and releases from industrial, commercial, and consumer products and materials;
  • the extent and magnitude of workplace exposure levels;
  • key human hazard endpoints; and
  • ecological hazards to and exposures of sediment- and soil-dwelling and terrestrial, as well as aquatic, organisms.

Concerns have also been repeatedly raised about EPA’s over-reliance on models in the absence of measured data and on physical-chemical and environment fate data to rule out exposure pathways, especially in the absence of rigorous uncertainty analyses and incorporation of uncertainty into EPA’s risk conclusions.

It’s not as if there isn’t a solution to the dearth-of-data problem.  Yet the Trump EPA has steadfastly refused to use it.  Read More »

Also posted in EPA, Health Policy, TSCA Reform / Comments are closed