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Selected tag(s): methylene chloride

While harder to discern, another EPA risk evaluation severely understates risk, this time for methylene chloride

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

When EPA released the draft of its risk evaluation for methylene chloride at the end of last month, some were surprised that EPA had identified numerous unreasonable risks presented under a variety of the chemical’s conditions of use.

In an earlier post, EDF provided some context, noting how dangerous the chemical is and raising initial concerns that EPA was once again excluding known uses and exposures, making unsupported assumptions, and applying inappropriate risk benchmarks that were once again leading it to significantly understate the actual risks posed by methylene chloride.

Four weeks later, EDF has confirmed these concerns in spades.  Last night we filed 84 pages of comments on the draft risk evaluation, for consideration by EPA’s Scientific Advisory Committee on Chemicals (SACC), which will meet next week to peer review the draft.

EDF’s deep dive into the draft demonstrates that EPA has employed a host of unwarranted and unsupported assumptions and methodological approaches that lead it to either avoid identifying unreasonable risk when it should have, or to understate the extent and magnitude of the unreasonable risks it did identify.  Below we summarize some of the major concerns, which are addressed in detail in our comments.  Read More »

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EPA’s just-released methylene chloride draft risk evaluation: Some important context

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

After more than a month’s delay, EPA today released its draft risk evaluation for methylene chloride.  Running to 725 pages (not counting more than a dozen supplemental files), it will take some time to digest.  But here are some initial observations that provide context for those of you who will be looking closer.

First, methylene chloride is a very nasty chemical.  It has killed a lot of people.  It causes cancer.  Short- and long-term exposure to it is tied to liver effects, immune system effects, nervous system effects, and reproductive/developmental effects.

So it shouldn’t be surprising that EPA’s draft – even coming from an administration not known to be overly worried about the risks of chemicals – has found that most industrial, commercial and consumer uses of methylene chloride present unreasonable risks.

For example, EPA found that workers using methylene chloride-based paint strippers face high risks.  Of course, we knew that already:  EPA identified those risks more than five years ago, and proposed to ban those uses.  This EPA decided it had to do it all over again – which means that thousands of workers have continued to be unnecessarily exposed to this deadly chemical.  And it will be even more years before we get back to where we were before EPA took its mulligan.

So the good news is that EPA seems to be acknowledging that methylene chloride presents high enough risks to warrant regulation under the Toxic Substances Control Act (TSCA).

The bad news is that EPA is dramatically underestimating the magnitude of methylene chloride’s risks – by pulling the same tricks it has for other chemicals among the first 10 it is evaluating under TSCA:

  • EPA once again ignores all exposures and risks to the general population by falsely assuming those exposures and risks are eliminated by actions it has taken or could take under other laws. That means ignoring over 4 million pounds of methylene chloride annually released to air, water and land.  See this backgrounder for the details and why this EPA assumption about methylene chloride is deeply flawed.
  • EPA once again grossly understates risks to workers:
    • EPA assumes that workers will always wear fully effective personal protective equipment (respirators and gloves) to make many of the risks it identifies go away – and to grossly understate the magnitude of the unreasonable risks it does find.
    • EPA once again finds a cancer risk to workers unreasonable only if it exceeds a level of 1 in 10,000 – which is 100 times higher a risk than warrants regulation under TSCA to protect workers and other vulnerable subpopulations.
    • For occupational non-users (ONUs), EPA has once again failed to identify unreasonable risks for the most highly exposed, and hence most vulnerable, workers unless it finds that the majority of workers also face unreasonable risks.

These are just a few initial observations based on our reading of EPA’s opus so far.

So while it’s somewhat encouraging that this new draft risk evaluation has found many more risks than previous drafts, we can already tell the draft falls far short of adequately describing the risks presented by methylene chloride.

Stay tuned.

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Next TSCA chemical peer reviews and draft risk evaluations to be delayed. You’ll never guess why.

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

We’re hearing that EPA has cancelled the next meeting of its Scientific Advisory Committee on Chemicals (SACC), which was scheduled for October 21-25.  The SACC is conducting peer reviews of EPA’s draft risk evaluations of the first 10 chemicals to undergo safety reviews under the Toxic Substances Control Act (TSCA).

Word is that the panel was to use its October meeting to peer-review the draft risk evaluations for methylene chloride and N-methylpyrrolidone (NMP).  But release of those drafts has been delayed, leaving insufficient time for the SACC to review them before the meeting.

We’re also hearing why release of the drafts has fallen behind.  The drafts were on track for release late last month, but apparently were blocked based on objections about at least the draft risk evaluation for methylene chloride.  The objections were lodged by Dr. Nancy Beck.  Read More »

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Long-Delayed Methylene Chloride Ban Finalized but Still Leaves Workers at Risk

Increasing pressure from families, lawmakers, and advocates forces EPA’s half-step on deadly chemical

Today, the Environmental Protection Agency (EPA) announced it has finalized a rule that bans methylene chloride in paint strippers for consumer uses but still allows use of the deadly products in workplaces. Instead of banning commercial uses, as it originally proposed to do more than two years ago, EPA is merely starting a process to gather input on what a possible future certification and training program might look like – delaying any action for years.   Read More »

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EDF statement in advance of House hearing on failure by the Trump EPA to protect workers from toxic chemicals

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

Tomorrow, the House Energy and Commerce Committee’s Subcommittee on the Environment and Climate Change will hold an oversight hearing on “Mismanaging Chemical Risks: EPA’s Failure to Protect Workers.” In advance of the hearing, Environmental Defense Fund lead senior scientist, Dr. Richard Denison, made the following statement:

“Under the Trump Administration, every aspect of EPA’s implementation of the Toxic Substances Control Act (TSCA) — our recently reformed chemical safety law — has gone off the rails. The Trump EPA has abdicated its authority and responsibility under the law to address risks to workers. Among the ways EPA has shirked these duties are the following:

  • Clearing new chemicals despite risks to workers. EPA has approved new chemicals for unfettered market access even where the agency has identified significant risks to workers or has indicated it has insufficient information to determine risks to workers. EPA has done so for many dozens of chemicals.
  • Abandoning worker protections from methylene chloride. EPA is poised to finalize a ban of methylene chloride-based paint strippers far narrower than the one it proposed over two years ago. While consumer uses will be banned, EPA will not limit commercial uses, leaving workers, who are most at risk from these products, unprotected.
  • Ignoring worker safety in chemical risk evaluations under TSCA. In the only draft risk evaluation of a chemical issued to date, EPA relied exclusively on a single undocumented workplace air concentration value, provided through a private personal communication by a conflicted industry source, as the basis to conclude that workers across the supply chain for this chemical face no significant exposure to the chemical.

“Oversight of this EPA’s reckless approach to worker protection under existing law is long overdue.  We applaud the subcommittee for holding this hearing. This EPA is putting the public’s health – especially worker’s health — at risk by systematically weakening and undermining chemical safety: the agency must be held accountable.”

 

 

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EDF to OMB: Ban on methylene chloride in paint strippers must protect workers in addition to consumers

Lindsay McCormick, Project Manager, and Joanna Slaney, Legislative Director

Over 11,000 concerned Americans have sent messages to Members of Congress over the last two weeks to urge EPA and OMB to protect workers – the population at most risk – from methylene chloride in paint strippers.

Today, EDF met with the White House Office of Management and Budget (OMB) about the Environmental Protection Agency’s (EPA) draft final rule on methylene chloride-based paint strippers. We urged the office to ensure the ban on methylene chloride-based paint and coating removers covers both consumer and most commercial uses – as the agency originally proposed.

Removing these deadly products from stores, workplaces, and homes is a critical step to protecting public health. Methylene chloride is acutely lethal. Exposure to the chemical has led to over 50 reported worker deaths since the mid-1980s, more than 40 of which are attributed to use of methylene chloride-based paint strippers. Many more deaths have likely gone unreported. The chemical is also associated with a host of other serious health effects, including neurotoxicity, cancer, and liver impairment.

Despite the facts that workers represent the vast majority of reported deaths and face the highest risks of other health effects, it appears that EPA is poised to finalize a rule that excludes a ban on commercial uses entirely – and will instead merely initiate a lengthy, uncertain process that may lead to certification and training approaches EPA had already considered and rejected as inadequate to protect workers.

Read More »

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