EDF Health

Selected tag(s): Oil dispersant

Does dispersant toxicity count? No toxicity standard limits EPA’s listing of oil spill dispersants

By Richard Denison / Published: June 24, 2010

Richard Denison, Ph.D., is a Senior Scientist.  EDF’s Health Program Intern Shannon O’Shea provided valuable assistance in the research for this post.

The more I have looked into the question of how dispersants get listed and selected under the country’s National Oil and Hazardous Substances Pollution Contingency Plan (NCP), the more disturbing it gets.

It turns out EPA regulations impose no maximum toxicity limits on dispersants allowed to be listed on the NCP Product Schedule.  Nor is such a listing deemed by EPA to be an approval or authorization for use of a dispersant on a spill – it merely signifies (with one exception) that required data have been submitted to EPA.  Yet, once listed, a dispersant is effectively “pre-authorized” for use, and the guidance provided to officials charged with deciding whether to allow use of a dispersant, and if so which one and in what quantities and settings, makes scant mention of toxicity as a factor to be considered in the selection decision.

No wonder there’s little incentive to do the research needed to understand the full scope of impacts associated with dispersant use, let alone to develop and shift to safer and more effective dispersants.

This post examines the following questions:

  • How does a dispersant get listed on the NCP Product Schedule?
  • Is listing of a dispersant considered approval for use on a spill?
  • How is a dispersant approved for use in a spill?
  • How are decisions made about dispersant use?
  • How is toxicity information considered in making decisions about dispersant use?

Read More »

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Correction to my last post: Clarification from EPA

By Richard Denison / Published: June 22, 2010

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

I have learned from EPA (see EPA’s statement at the end of this post) that, in my last post, I misinterpreted a key part of the May 26 Directive that EPA and the Coast Guard issued to BP calling for reductions in overall dispersant use.   Specifically, it stated “BP shall establish an overall goal of reducing dispersant application by 75% from the maximum daily amount” (emphasis added).  My calculation indicating only a 9% reduction was based on the average rather than maximum daily amount applied prior to the Directive.

According to EPA, the Directive was issued in direct response to concern over BP’s escalating use of dispersants in the days immediately prior: 45,000 gallons on May 22 and 70,000 gallons on May 23.

Using the maximum daily amount of 70,000 gallons as the baseline, BP’s subsequent use of dispersant post-Directive averaging 22,600 gallons per day represents a 68% reduction, much closer to the 75% goal.

My apologies for the confusion and my misreading of the Directive.

EPA also indicates that the continuing surface application of dispersant by BP has been approved by the Coast Guard, as provided for in the Directive.  I am seeking confirmation of that from the Coast Guard directly.

EPA statement added at 4:15 EDT today:

Statement from EPA Press Secretary Adora Andy:

When Administrator Jackson saw two straight days (May 22, 23) of skyrocketing dispersant volumes applied in the Gulf of Mexico she acted immediately to do something about it.  On the evening of May 23 Administrator Jackson and Coast Guard Rear Admiral Landry sat down with BP and ordered them to ramp down dispersant use – with an overall goal of 75% from its peak usage of 70,000 gallons on May 23.  The next day May 24, dispersant use dropped more than 50%.  Since Administrator Jackson and Admiral Landry met with BP on May 23 to demand a reduction, dispersant use is down 68% from its peak.  The Federal On-Scene Coordinator, in this case it’s Coast Guard Admiral Watson, has the authority to grant waivers for the use of more dispersant based on changing conditions at sea.

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Is BP complying with the Directive to reduce dispersant use in the Gulf?

By Richard Denison / Published: June 21, 2010

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

[Note added 6/22:  I have corrected one of the figures below, which was based on a misunderstanding of the EPA/Coast Guard Directive.  Please see this correction for the updated information and a statement from EPA.]

As of yesterday, BP’s use of dispersants to address the ongoing Deepwater Horizon spill has topped 1.4 million gallons.

On May 26, 2010, EPA and the Coast Guard issued a Directive to BP calling for significant reductions in BP’s use of dispersants.  That directive set out three requirements:

  • Eliminate surface application of dispersant except in rare cases where exemptions are requested in writing and granted by the Coast Guard’s Federal On-Scene Coordinator (FOSC).
  • Limit subsurface application of dispersant to a maximum of 15,000 gallons per day.
  • Overall goal of reducing dispersant use by 75%.

Has BP complied?  The short answer is not even close.  The details follow.  Read More »

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A glimmer of good news flowing from the Gulf’s other recent disaster

By Richard Denison / Published: June 18, 2010

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

I’ve been blogging for some weeks now about how we may be compounding the problems of the BP oil disaster through our massive use of inadequately tested and ineffective dispersants.  There’s an eerie echo in these events to the compounding effects of decisions made in the wake of the Gulf region’s last major disaster, 2005’s Hurricane Katrina: specifically, the decision to house victims forced out of their homes in trailers made from imported plywood that exposed them to toxic levels of formaldehyde, a known human carcinogen.

In what I choose to regard as a silver lining arising from this earlier debacle, the U.S. Congress is finally – nearly five years later – inching toward passing legislation that seeks to prevent a repeat of that episode, by putting limits on how much formaldehyde can be emitted from imported and domestically manufactured pressed wood products.  Read More »

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EPA data show dispersants plus oil are more toxic than either alone

By Richard Denison / Published: June 14, 2010

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

In an earlier post, I noted in haste some apparent discrepancies between EPA and BP acute toxicity data on the Corexit® dispersants.  Little did I realize that the data mixup was actually telling me something much more significant:  that the dispersant maker’s own test data demonstrate that the combination of oil plus dispersant is quite a bit more toxic than the dispersant alone and – even more significant – the combination is more acutely toxic than the oil by itself.

Let me repeat that:  The data indicate that dispersed oil is more toxic than undispersed oil.  Read More »

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Dispersants are a teachable moment for TSCA reform

By Richard Denison / Published: June 10, 2010

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

The Safer Chemicals, Healthy Families campaign just held a press call to draw direct links between the huge unknowns associated with the unprecedented use of chemical dispersants in the Gulf and the failures of TSCA.  The campaign called upon Congress to ensure that legislation to reform TSCA fully addresses dispersant safety so that, the next time a disaster of this sort unfolds, the country won’t be caught with its proverbial pants down.

While the reform bills would go a long way to improve the situation, the campaign also provided a detailed description of enhancements to the current reform bills needed to address:

  • the lack of public access to sufficient information about dispersants, their ingredients and their concentrations;
  • the lack of adequate safety testing for long- as well as short-term effects on both marine environments and people, including affected workers, volunteers and nearby residents;
  • the lack of a requirement that dispersants be shown to be safe as a condition for allowed use; and
  • the lack of adequate EPA authority to disallow unsafe dispersants and to halt or alter dispersant use based on on-the-ground developments.

As the legislation advances, we will be pressing Congress to include additional provisions to address these deficiencies.  There could be no better illustration of the limits to our current policies than that provided by government’s forced reliance on under-tested chemical dispersants the use of which is raising more questions than answers.

Posted in Health policy, TSCA reform / Also tagged , , | Read 2 Responses