EDF Health

$10 in benefits for every $1 invested – Minnesota estimates benefits of lead service line replacement

Tom Neltner, J.D.Chemicals Policy Director

Last week, the Minnesota Department of Health (MDH) released a report estimating that investing $4 billion in virtually eliminating lead in drinking water over 20 years would provide societal benefits of more than $8 billion. The state agency only counted the societal benefits from avoiding the loss of IQ points due to children’s exposure to lead.

Replacing lead service lines (LSLs) – the lead pipes that connect a building’s plumbing to the water main under the street – yielded the greatest benefit with an investment of $0.228 to $0.365 billion yielding $2.118 to $4.235 billion in benefits. Replacing lead fixtures and solder had a lower, but still significant, return on the investment.

Based on this analysis, MDH recommended as high priority that the state conduct an inventory of LSLs and that LSLs be removed “at a measured pace” of 20 years. It also recommended undertaking as a medium priority an awareness campaign focused on the danger of lead in drinking water to formula-fed infants younger than nine months old and as a low priority a general public information campaign to prompt homeowners and renters to take action if they have an LSL.

The agency, which includes both the state’s drinking water protection program and its lead poisoning prevention program, prepared the report in response to a provision in a state appropriations law passed in 2017. The report is important because it is the first state assessment we know of, and it reports an impressive return on the investment of more than $10 for every $1 invested in LSL replacement. For these reasons, we took a close look at the analysis and the underlying assumptions.

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Also posted in Drinking Water, Health Policy, lead, States / Tagged , , , | Comments are closed

The elephant in the room: potential biopersistence of short-chain PFAS

Maricel Maffini, Ph.D., Consultant and Tom Neltner, J.D., Chemicals Policy Director

In January 2018, US Food and Drug Administration (FDA) scientists published a peer-reviewed journal article stating a commonly used raw material to make greaseproof paper is likely to persist in the human body. FDA scientists’ sophisticated analysis and remarkable conclusion raises questions about the broad assumption that short-chain perfluorinated alkyl substances (PFAS), as a class, did not accumulate.

Strangely, two recent reviews funded by the FluoroCouncil, ignored FDA scientists’ study even though it was published ten months before the industry group submitted their analysis for peer-review. The peer reviewers appear to have missed the omission as well. As a result, the industry evaluations continue to perpetuate the flawed assumptions, concluding that perfluorohexanoic acid (PFHxA) and related short-chain PFAS “present negligible human health risk” and that this substance alone is a suitable marker for the “safety of fluorotelomer replacement chemistry.”

In this blog, we discuss the differences between the studies and the implications of the discordance between FDA’s and industry’s conclusions for the safety assessment of short-chain PFAS.

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Also posted in Drinking Water, FDA, Health Policy, PFAS, Public Health, Regulation / Tagged , , | Comments are closed

The Trump EPA’s actions on formaldehyde can be summed up in one word: Corrupt

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

Today, Heidi Vogt at the Wall Street Journal reported on the systematic efforts by the Trump Administration to derail chemical assessments under the Environmental Protection Agency’s (EPA) Integrated Risk Information System (IRIS).   

Decisions are being made as I write by conflicted EPA political appointees, not only to derail the beleaguered IRIS assessment for the carcinogen formaldehyde, but to transfer any further assessment of the chemical to be under the control of those same political appointees.

The WSJ article cites an upcoming report by Congress’ Government Accountability Office (GAO) that notes “EPA leadership in October directed the heads of the agency’s various programs to limit the number of chemicals they wanted IRIS to study or continue researching.  Nine of 16 assessments were then dropped, including one that looked at whether exposure to formaldehyde increases the risk of leukemia that ‘has been drafted and is ready to be released for public comment.’ ”  The chemical industry has long sought to undermine the findings of numerous governmental authorities that have identified the dangers posed by formaldehyde, one of the industry’s biggest cash cows.

IRIS itself has also long been a target of the chemical and allied industries, including those well represented by EPA political appointees who are now able to drive the assault on IRIS from inside the agency.

This post will provide more of the backstory to the WSJ’s excellent reporting.  It reveals additional decisions being made as I write by conflicted political appointees, not only to derail the beleaguered IRIS assessment for formaldehyde, a known human carcinogen, but to transfer any further assessment of the chemical to be under the control of those same political appointees.  What is happening here we believe is ripe for further investigation.   Read More »

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

Data visualization to drive clean air innovation and improve health

Aileen Nowlan, Senior Manager, EDF+Business

The first time I spoke at a conference about air pollution, the venue was right beside a daycare—a well-regarded chain, no doubt with significant waiting lists. But on the outside, the facility was steps from onramps to a bridge and a major highway, where horns blared and buses and trucks idled at the lights.

The pollution around this daycare was invisible, but because there is still so much we don’t know about air pollution, so were many of the risks.

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Also posted in Air Pollution, Hyperlocal mapping, Innovation / Tagged , , | Read 1 Response

How and when will FDA rule on ortho-phthalates in food? It’s anyone’s guess.

Tom Neltner, J.D.is Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant

The Food and Drug Administration (FDA) has yet to decide three overlapping petitions requesting the agency take action on uses of ortho-phthalates in contact with food. Two of the petitions—a food additive petition and a citizen petition—were submitted by EDF, Earthjustice and nine other public health allies. In those petitions, we requested the revocation of all uses of this class of chemicals in food because the agency can no longer conclude that such use is safe. The law required FDA to make a decision by no later than September 2018; that deadline has long since come and gone, and the agency hasn’t acted.

The third petition was submitted by the Flexible Vinyl Alliance, an industry group. It requested that the agency revoke the food additive uses of 26 ortho-phthalates because, according to FDA’s notice, they had been abandoned. The agency agreed to review the petition in July 2018 and invited public comment on it in November 2018.  Public comments were due on January 14, 2019.

In a press release about its petition, the industry group announced that only four ortho-phthalates “remain relevant in food contact applications”:  di(2-ethylhexyl) phthalate (DEHP), diisononyl phthalate (DINP), dicyclohexyl phthalate (DCHP) and diisodecyl phthalate (DIDP).  It also stated that it confidentially provided the agency with exposure and safety data on these four substances. The agency has made neither the industry’s petition nor the safety data on the four ortho-phthalates publicly available. We submitted a Freedom of Information Act (FOIA) request seeking industry’s “confidential” report and more information on the petition.  We await a response.

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Also posted in FDA, Food, Public Health / Tagged , , , , | Comments are closed

The Trump EPA’s first TSCA risk evaluation is an epic fail

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

Yesterday Environmental Defense Fund (EDF) filed more than 100 pages of comments on a 40-page draft risk evaluation the Trump Administration’s Environmental Protection Agency (EPA) has prepared for Pigment Violet 29 (PV29).  PV29 is the first of 10 chemicals undergoing risk evaluations under the Toxic Substances Control Act (TSCA).  Our comments were so much longer than the EPA document we were commenting on because there was far more to say about what information EPA failed to obtain, make available or consider than what EPA included in its draft.

The essence of our lengthy comments can be boiled down to a single sentence, however:  EPA has utterly failed to demonstrate that PV29 does not present unreasonable risk of injury to health or the environment.

For folks who want somewhat more detail than this, our comments start with a 4-page Executive Summary that capsulizes the many serious deficiencies we identified in EPA’s draft.  I’ll provide some highlights in this post.   Read More »

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