EDF Health

EPA’s draft risk evaluation of trichloroethylene contains major scientific flaws that understate the chemical’s risk and demand robust review

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

Yesterday Environmental Defense Fund (EDF) filed comments on the Environmental Protection Agency’s draft risk evaluation for the highly toxic chemical trichloroethylene, or TCE.

This draft, readers will recall, is the document that the Trump White House forced EPA to dramatically weaken just prior to public release, as reported in detail by Elizabeth Shogren of Reveal News.

It is also the document that EPA seems intent on subjecting to a rushed peer review next week in a 4-day virtual meeting of the Scientific Advisory Committee on Chemicals (SACC) – despite numerous reasons why, in the midst of the current COVID-19 public health crisis, such a meeting simply will not provide the robust scientific review that this draft warrants.  EDF has urged EPA to postpone the SACC review so that it can be done under circumstances that are conducive to a proper review and fair to SACC members and stakeholders who would like to participate.

EDF submitted comments yesterday in order to meet the very tight deadline EPA set for comments if they are to be considered by the SACC.  Our comments raise numerous scientific deficiencies in EPA’s draft.  These flaws arise from a host of unwarranted and unsupported assumptions and methodological approaches that systematically lead EPA to understate the risks posed by this chemical to pregnant women, infants and children; to workers; to consumers; to the public; and to the environment.

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 draft ignores or downplays each of these exposure sources and pathways.

It is vital that the current public health crisis caused by COVID-19 not be allowed to compromise the quality and integrity of scientific assessments of other critical public health risks we face.

Below I summarize some of the major concerns in EPA’s draft that we address in detail in our commentsRead More »

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Reveal News exposes Trump Administration’s disregard for protecting the public from a highly dangerous chemical: 5 key takeaways

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

This weekend, Elizabeth Shogren at Reveal News published an in-depth investigative report and hour-long radio segment delving into the Trump EPA’s latest abandonment of science and its serious consequences for public health.  The story focuses on the ubiquitous solvent trichloroethylene (TCE), a known human carcinogen and neurotoxicant that is also linked to birth defects at very low levels of exposure.

In reforming the Toxic Substances Control Act (TSCA) in 2016, Congress directed EPA to conduct comprehensive reviews of the risks posed by TCE and other widely used chemicals.  EPA was charged with identifying risks both to the general public and to “vulnerable subpopulations,” including pregnant women, infants, workers, and others.

EPA’s draft risk evaluation of TCE was released on February 21.  It suffers from many of the same gaping flaws as do EPA’s draft risk evaluations for other chemicals.  Once again, EPA has utterly failed to carry out the clear intent of the law, putting our health at greater risk.

  • EPA has ignored all exposures of the general population to TCE that arise from releases of the chemical to air, water and land – amounting to millions of pounds annually.
  • EPA has once again assumed, without any supporting data, that workers will wear personal protective equipment and that it will be effective in eliminating or reducing exposures.
  • EPA has inflated the acceptable level of risk of cancer that will allow workers to be exposed to as much as 100 times more of the chemical.

“This decision is grave. It not only underestimates the lifelong risks of the chemical, especially to the developing fetus, it also presents yet another example of this administration bowing to polluters’ interests over public health.”

Dr. Jennifer McPartland

But in this new draft EPA has gone even further in abandoning both science and the law.  Reveal’s exposé identifies key changes made at the 11th hour to the draft that were forced on career staff at the agency by the White House.

Here are five key takeaways from the Reveal story:  Read More »

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

EPA’s draft risk evaluation of carbon tetrachloride is riddled with unsupported exclusions and assumptions

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

Next week, the Scientific Advisory Committee on Chemicals (SACC), established under the Toxic Substances Control Act (TSCA) to peer-review EPA’s draft chemical risk evaluations, will meet to review the latest of those drafts, for the likely human carcinogen carbon tetrachloride.

As with other recent draft risk evaluations, EPA has been scheduling the SACC meetings in the middle of rather than following the public comment period.  This means the public has at best a few weeks to digest these huge documents and draft and submit comments in order to have them be part of the record that the SACC is allowed to take into consideration in its peer review.

However, we have learned that EPA is now further constraining the SACC’s schedule, requesting that the panel members come to the peer review meeting with their comments already drafted, and then delivering their final report within 60 days rather than the 90 days previously provided.  These developments further jam both the public and the SACC in their efforts to ensure EPAs work is subject to a robust peer review.

Whatever the reasons for EPA making these changes, EDF decided to expedite our initial comments to seek to ensure they could be considered.  We submitted comments last week, a full week before the February 19 deadline, to ensure the SACC received and had sufficient time to review them in advance of the peer review meeting.

We deemed this critical because of the glaring gaps and flaws in EPA’s draft that lead it yet again to drastically understate the risks of this chemical.  These include the same problems that have plagued the draft risk evaluations for other chemicals, as well as new ones.  Read More »

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The Trump EPA’s “Working Approach” to new chemical reviews is only working for the chemical industry

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

On Tuesday EDF filed detailed comments on the Environmental Protection Agency’s (EPA) “Working Approach to Making New Chemical Determinations under TSCA.”

The document is a major disappointment, to say the least.  The Trump EPA has worked very hard to render this long-awaited update of its approach to reviewing new chemicals under TSCA an empty exercise.  Despite Administrator Wheeler’s promises in January 2019 to the contrary:

  • EPA has still failed to provide any legal or scientific justification for its Working Approach.
  • EPA provided no actual response to the many detailed comments it received on its 2017 framework, instead issuing a 1.5-page document that dismisses many of the comments merely as having “stemmed from a misunderstanding of the Agency’s intent.”
  • EPA held a public meeting – but did so without first providing the Working Approach to stakeholders; EPA then limited their comments at the meeting to 2-3 minutes each and ended the meeting well ahead of schedule.
  • EPA’s new framework ignores the earlier comments it received, retaining all of the core flaws of the 2017 Framework and in fact doubling down on several of them.

Most remarkably, EPA seems to want to make clear that the Working Approach is hardly worth the paper on which it is written.  Read More »

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The Trump EPA reaches a shocking new low in failing to protect workers under TSCA

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

Just when I thought EPA putting workers’ health at risk by shirking its responsibilities under the Toxic Substances Control Act (TSCA) couldn’t get any worse, it has.

The notion that worker protection can or should be relegated to the equivalent of a shock avoidance experiment is deeply offensive if not outright immoral.

In its risk evaluations of existing chemicals (see our comments here and here) and its reviews of  new chemicals (see our comments here) entering the market, EPA has found ways bordering on the diabolical to avoid identifying or to understate the extent and nature of risks to workers making or using those chemicals.  The agency:

  • Simply assumes without evidence that workers will wear fully effective personal protective equipment (respirators and gloves).
  • Distorts OSHA regulations and claims they apply where they don’t.
  • Treats voluntary instruments that impose no binding requirements as if they were mandatory.
  • Assumes that if the average worker’s exposure does not exceed its acceptable risk level, then it doesn’t matter if there are exceedances for those workers most highly exposed.
  • Has unquestioningly accepted and used manufacturers’ undocumented data on workplace exposure levels even when data from more authoritative sources show far higher exposures.
  • And has adopted a cancer risk benchmark that is as much as two orders of magnitude more permissive of risk than warranted under TSCA.

All this despite TSCA’s express identification of workers as a “potentially exposed or susceptible subpopulation” that warrants special protection.

As appalling as all of this is, it just got worse. Read More »

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What connects cross country skiing and chemical safety?

Sam Lovell, Project Manager.

An idyllic afternoon gliding through fresh snow may seem as far removed as you can get from Washington, D.C. decision-making about toxic chemicals. However, as recently reported by Outside Magazine, there’s an intriguing connection here that ought to give skiers, and the rest of us, some pause.

Last year, the Environmental Protection Agency (EPA) approved a new chemical for use in ski wax. Just a few months before, the agency had planned to deny the chemical market entry based on the concern, among others, that exposure could “waterproof the lungs” – causing severe, acute harm. Due to the abrupt reversal in EPA’s decision, EDF began looking further into this case and made public records and Freedom of Information Act requests.

The intervening steps that resulted in this chemical getting the green light to market reveal serious problems in EPA’s new chemicals program regarding transparency and industry influence.

Read More »

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