EDF Health

Now’s the Time—How EPA can use TSCA to turn off the PFAS tap

Faucet with the word PFAS flowing out of it

In the face of mounting evidence about the dangers posed by per- and polyfluoroalkyl substances (PFAS), one thing is clear: EPA needs to take urgent action to turn off the tap of these “forever chemicals” that have long-term consequences for our health and the environment.

As we discussed in a previous blog, it is imperative that the Environmental Protection Agency (EPA) use the Toxic Substances Control Act (TSCA) to regulate PFAS chemicals comprehensively—both those newly entering the market and those that have been in circulation for decades.

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Also posted in Chemical exposure, Chemical regulation, Cumulative impact, Cumulative risk assessment, Drinking water, Emerging science, Health policy, PFAS, Public health, Regulation, Risk assessment, Risk evaluation, TSCA, Vulnerable populations, Worker safety / Tagged , , | Authors: / Read 2 Responses

The Case of the Missing PFAS

By Lauren Ellis, MPH, Research Analyst, Environmental Health and Samantha Liskow, Lead Counsel, Health

NOTE: In a recent blog post, EDF called for EPA to revoke PFAS approved through the agency’s “low volume exemption” (an LVE is an exemption from a full safety review for new chemicals produced in quantities less than ~10 tons) and to instead require all PFAS to undergo a full safety review under the Toxic Substances Control Act (TSCA). Last month, EDF and other groups, represented by Earthjustice, formally petitioned EPA to do just that.

What Happened: We recently discovered that EPA is withholding the names of over 100 PFAS chemicals approved as LVEs—claiming that releasing that information would reveal “confidential business information” (CBI).

Why It Matters: PFAS causes harm to both the environment and to human health—including reproductive, developmental, and cancer-related effects. Given growing concerns about the risks of PFAS, the public has the right to know if they are being exposed to PFAS, especially those approved through exemptions to EPA’s new chemical safety review process.

Our Take:

  • EPA should reveal the identities of the missing PFAS LVEs. If doing so would reveal CBI, EPA should work with PFAS manufacturers to craft a name that clearly communicates PFAS class membership.
  • EPA should require full safety review for all PFAS, including those previously approved through exemptions.

GO DEEPER… Read More »

Also posted in Industry influence, PFAS, Public health, Regulation / Tagged | Read 1 Response

Workers are people too; EPA should treat them that way

EPA’s proposed TSCA rule to limit risks from chrysotile asbestos uses a higher “acceptable” cancer risk for workers than the rest of the population

Maria Doa, Ph.D., Senior Director, Chemicals Policy

When it comes to drawing the line on cancer risks, should workers be treated differently than the general population? Of course not. Unfortunately, EPA’s recently proposed rule to manage risks from chrysotile asbestos does just that, using one level of acceptable risk for workers and another – more protective threshold – for everyone else.

EPA says it uses a range for determining acceptable cancer risks under the Toxic Substances Control Act (TSCA), the country’s main chemical safety law. The range spans a risk (or the chance that a person will develop cancer) of less than one in 10,000 to a risk of less than one in one million. EPA says this is consistent with the cancer benchmark used by the National Institute for Occupational Safety and Health (NIOSH).

However, EPA’s proposed TSCA rule for asbestos does not actually use a range and it is not supported by TSCA. EPA instead applies a risk level to workers 100 times less protective than for everyone else! Read More »

Also posted in Public health, Worker safety / Tagged , , , , | Comments are closed

The many ways the American Chemistry Council wants to turn back time on TSCA implementation – Part 2

Part 2 of a 2-part series: Unrestricted approvals of new chemicals, with low fees 

Maria Doa, Ph.D., Senior Director, Chemicals Policy

In its recently issued ‘State of TSCA’ report, the American Chemistry Council (ACC) tries to turn back the clock on how EPA assesses and mitigates the risks of toxic chemicals under the Toxic Substances Control Act (TSCA) and in the process leave workers, frontline communities and other vulnerable individuals at risk.  

In my previous blog, I looked at how ACC’s proposals would restrict the EPA’s ability to assess chemical risks and the science behind it. In this second and final part of our blog series looking at the chemical industry trade group’s report, I discuss ACC’s plan to dictate how EPA should assess the safety of new chemicals industry hopes to bring to the marketplace, as well as its effort to let industry avoid paying its fair share of the cost for EPA to evaluate chemical risks.  Read More »

Also posted in Health policy, Industry influence, Public health / Tagged , , , | Read 3 Responses

The many ways the American Chemistry Council wants to turn back time on TSCA implementation – Part 1

Part 1 of a 2-part series: Minimizing or ignoring chemical risks

Maria Doa, Ph.D., Senior Director, Chemicals Policy 

In its recently issued ‘State of TSCA’ report, the American Chemistry Council (ACC) tries to turn back the clock on how EPA assesses and mitigates the risks of toxic chemicals. The chemical industry group looks to return to the policies of the Trump years – a time rife with scientific integrity issues and wholesale disregard of risks – particularly those risks to frontline communities, workers and other vulnerable groups: the very groups the Toxic Substances Control Act (TSCA) calls out for special consideration.

This 2-part blog series looks at the six ways ACC hopes to turn back time on chemical safety and looks at the harms that would result if trade group’s self-serving ideas were to be adopted. Part 1 looks at the types of risks ACC wants EPA to exclude from its chemical risk evaluations, the workers and other groups whose health would be affected, as well as the trade group’s goal to have itself appointed as the arbitrator of EPA science. Part 2 looks at ACC’s efforts to dictate the process for assessing new chemicals and industry’s clear goal to avoid paying its fair share of the cost to evaluate the risks posed by some of the most dangerous chemicals already in the marketplace.  Read More »

Also posted in Health policy, Health science, Industry influence, Worker safety / Tagged , , | Comments are closed

EPA’s new Collaborative Research Program – A step toward improving new chemical reviews under TSCA

Maria Doa, Ph.D., Senior Director, Chemicals Policy; Lauren Ellis, MPH, Research Analyst; and Lariah Edwards, Ph.D., Post-Doctoral Fellow 

The Environmental Defense Fund (EDF) recently filed comments on EPA’s Toxic Substances Control Act (TSCA) Collaborative Research Program to Support New Chemical Reviews (Collaborative Research Program). The Collaborative Research Program is a multi-year scientific partnership between the agency’s Office of Pollution Prevention and Toxics (OPPT) and Office of Research and Development (ORD) aimed at modernizing the methods, approaches, and tools used to evaluate new chemicals under TSCA.  

We strongly support OPPT’s collaboration with ORD, which has a breadth of scientific expertise across EPA’s different research programs. As such, ORD will help OPPT implement the best available science in its new chemical assessments, which should ultimately prevent risky chemicals from entering the marketplace. We urge OPPT to use this opportunity – and ORD’s expertise – to improve and expand its consideration of new chemical impacts to frontline communities, the risks new chemicals may pose throughout their entire life cycle, as well as cumulative risks from chemicals that may cause similar health effects. 

Below we outline the five proposed research areas for new chemicals under the Collaborative Research Program and our comments on each. All five can have an important impact on EPA’s new chemical assessments and consequently on EPA’s determination on whether a new chemical is expected to present an unreasonable risk.  Read More »

Also posted in New approach methods (NAMs) / Tagged , , | Authors: / Comments are closed