EDF Health

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 »

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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 »

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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

Amid COVID-19, the Trump administration sets dangerous air pollution standards. What is at stake for Houstonians?

Ananya Roy, Senior Health Scientist; Rachel Fullmer, Senior Attorney; Jeremy Proville, Director; Grace Tee Lewis, Health Scientist

The Trump administration’s disregard for science has been clear in the response to the COVID-19 pandemic, but it’s not the only health threat they’re making worse by ignoring overwhelming scientific evidence. For three years the administration has systematically sought to weaken clean air safeguards, endangering all Americans.

We know air pollution causes heart disease, diabetes and lung disease—and that the people suffering from these conditions are at greater risk of severe illness from COVID-19. Independent of the ongoing pandemic, air pollution is responsible for tens of thousands of deaths across America year after year. This underscores the vital importance of pollution protections to protect human health both during and after the COVID-19 crisis.

Unfortunately, EPA Administrator Andrew Wheeler has proposed to retain an outdated and inadequate standard for fine particulate matter (PM2.5) pollution despite strong scientific evidence that it must be strengthened to adequately protect human health.

To understand what having this pollution standard means for families living in the Greater Houston area, Harvard University and EDF scientists undertook an analysis of the impacts of PM2.5 exposure across the city. We found that:

  • Exposure to fine particle air pollution in 2015 was responsible for 5,213 premature deaths and over $49 billion in associated economic damages.
  • More than 75% of the health burden was borne by communities exposed to PM2.5 levels below the current standard.
  • Meeting the current standard alone would have prevented 91 deaths of the more than 5,000 premature deaths due to fine particle pollution.

By ignoring the scientific evidence and retaining the current standard, Administrator Wheeler is ignoring the very real health impacts felt by Houstonians and communities across the country from exposure to fine particle pollution.

Read More »

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Peer reviewers of EPA’s TCE report must affirm that the key risk is fetal heart damage

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

Last week, the EPA Science Advisory Committee on Chemicals (SACC) conducted a virtual peer review meeting for the Agency’s draft risk evaluation of trichloroethylene (TCE). As expected, there was substantial discussion on the appropriateness of EPA’s decision to make risk determinations based on immune endpoints rather than fetal cardiac malformations (FCMs). Unfortunately, the review panel lacked anyone with specific expertise in cardiac development.

During the meeting, many of the peer review panelists signaled an initial inclination toward supporting EPA’s decision to use immune endpoints for risk determinations. However, panel members also noted with serious concern the recent investigations that have uncovered political influence exerted on EPA that led it to base the risk determinations in the draft risk evaluation on immune endpoints instead of FCMs.

Stepping back from the specifics of the discussions last week, it is important to understand the longstanding basis and support for EPA’s reliance on FCMs, the unprecedented nature of EPA’s decision to now move away from it, and the adverse implications of the decision for EPA’s ability to adequately manage the risks of TCE to all relevant subpopulations.

This decision is a major departure from thoroughly peer-reviewed science, fails to protect the most sensitive populations as mandated by TSCA, and deviates dramatically from existing Agency guidance. These concerns, discussed at length in EDF’s comments in the TCE Docket, are briefly summarized below:  Read More »

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