Selected tag(s): risk assessment

Advancing the ball while minding the gaps: EDF’s comments on EPA’s risk scoping documents for flame retardant chemicals

Lindsay McCormick is a Research Analyst.

Until June 2014, EPA had not completed a chemical risk assessment under its Toxic Substances Control Act (TSCA) authority in 28 years.  Since then, EPA seems to have been somewhat picking up the pace: Over the past year and a half EPA has completed four additional risk assessments through the TSCA Work Plan Chemical Program, which is designed to assess the risks of priority chemicals currently on the market.

Recently, EPA initiated its assessment process for the next set of Work Plan chemicals, including three “clusters” of flame retardant chemicals.  We fully support EPA’s current efforts to assess the risks of these flame retardants – with the end goal of managing identified risks – and have provided quite extensive comments on EPA’s initial scoping documents.  In this post, I’ll highlight some of our comments and recommendations; see the links at the end to access the comments themselves.   Read More »

Posted in EPA, Food, Health Policy, Health Science| Also tagged , , | Comments are closed

TSCA reform legislation: How chemicals are selected for safety evaluations

Richard Denison, a Lead Senior Scientist.

Part 1              Part 2              Part 3              Part 4              Part 5

[UPDATE 4-29-15:  On April 28, 2015, the Senate Environment and Public Works (EPW) Committee passed a revised version of the Lautenberg Act out of the committee on a bipartisan 15-5 vote.  The new bill made a few revisions to provisions discussed in this post; see updates below.]

[UPDATE 5-17-15:  On May 14, 2015, the House Subcommittee on Environment and the Economy passed a revised version of the TSCA Modernization Act of 2015 out of the subcommittee on a bipartisan 21-0 vote.  The new draft made several revisions to provisions discussed in this post; see updates dated 5-17-15 below.  UPDATE 5-28-15:  The legislation was formally introduced as H.R. 2576 on May 26, 2015.  ]

This is the third in a series of blog posts looking at less talked-about, but critically important, elements of bipartisan legislative proposals to reform the Toxic Substances Control Act (TSCA).  This post deals with how EPA would select which chemicals would undergo safety evaluations.

Under current TSCA, EPA has no mandate to review the safety of existing chemicals. There are no pacing requirements, such as specifying minimum numbers of chemicals to be examined.  The law provides no criteria for EPA to use in identifying chemicals that may pose risks.  There are no requirements for EPA to establish goals for reviews or schedules for any reviews it does undertake.

Safety reviews are rarely undertaken, and often consume many years (or even decades) – in large part because there are no mandates or deadlines.  As a result of these aspects of the current law, only about 2% of the chemicals that were on the market at the time TSCA was enacted have undergone any sort of safety review.

In 2012, EPA on its own initiative undertook a prioritization process that has led to identification of about 90 so-called “work plan” chemicals, for which EPA is conducting or intends to conduct risk assessments; five have been completed to date.

How would TSCA reform legislation identify chemicals to be subjected to safety reviews?   Read More »

Posted in Health Policy, TSCA Reform| Also tagged | Comments are closed

Only a 2-month wait, down from 28 years: New EPA risk assessments find paint stripper chemicals pose significant health risks

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

In June, I blogged about the first final risk assessment EPA had issued in 28 years using its authority under the Toxic Substances Control Act (TSCA), for the solvent trichloroethylene (TCE).  Happily, we only had to wait two months for EPA’s TSCA office to issue final risk assessments for three more chemicals.

One of the three is dichloromethane (DCM), also known as methylene chloride.  DCM is a common ingredient of paint strippers, the use on which EPA’s risk assessment focused.  As with TCE, EPA found DCM-laden paint strippers pose significant health risks to workers, consumers and the general public.  Here’s what EPA said in its press release:

The risk assessment for Dichloromethane (DCM), which is widely used in paint stripping products, indicates health risks to both workers and consumers who use these products, and to bystanders in workplaces and residences where DCM is used.  EPA estimates that more than 230,000 workers nationwide are directly exposed to DCM from DCM-containing paint strippers.

Read More »

Posted in Health Policy, Health Science, TSCA Reform| Tagged | Comments are closed

EPA releases final risk assessment for TCE: One down, 84,999 to go*

Richard Denison, Ph.D., is a Lead Senior Scientist.  Jennifer McPartland, Ph.D., is a Health Scientist.

EPA achieved a rather significant milestone today in releasing a final risk assessment for the solvent trichloroethylene (TCE).  This document is for the first of a group of 83 “work plan chemicals” EPA identified in 2012 as needing risk assessments and, where warranted, risk management.

Why do we call it a milestone?  It is the first final risk assessment issued by EPA using its authority under the Toxic Substances Control Act (TSCA) in – wait for it – 28 years.

The last time EPA issued a final risk assessment for a chemical under TSCA was in 1986, for asbestos.  (EPA has developed a few draft assessments under TSCA over the years, but today marks the first time since 1986 that one of them has been finalized.)

So, kudos to EPA for finally getting this risk assessment to the finish line.  Now what’s next?  Read More »

Posted in Health Policy, TSCA Reform| Tagged | Comments are closed

Imbalanced act: An EPA IRIS agenda that speaks 1000 words

Richard Denison, Ph.D., is a Lead Senior Scientist.  Rachel Shaffer is a research assistant.

[UPDATE 6/24/14:  Perhaps in response to this post of last week, an updated agenda for this week's IRIS meeting was posted by EPA today that reflects a somewhat more balanced set of speakers.  Industry interests appear to have consolidated their number of slots, down from a high of 8 to a high of 6 per issue, and down from a high of 6 to a high of 4 individuals per issue from the same consulting firm.  In addition, several additional slots are assigned to non-industry speakers.  If you wish to see the changes, here is the agenda we linked to that was current as of last week, and here's the updated agenda posted today.]

In comments EDF made at a November 2012 stakeholder meeting held by EPA’s Integrated Risk Information System (IRIS) program, we warned that the tendency of the IRIS program to respond to criticism by expanding opportunities for “public” input would serve to increase rather than decrease the imbalance in stakeholder input.

We noted that providing more opportunities for participation not only lengthens the timeline for completing assessments; it also virtually ensures the input received by EPA is imbalanced and badly skewed toward the regulated community. That’s because companies that produce and use each chemical to be assessed – and the trade associations and myriad hired consultants that represent them – have a clear vested financial interest in the outcome of the assessment.  They can and will take advantage of each and every opportunity for input, and they will be better represented than other stakeholders each and every time.

IRIS recently began holding bimonthly meetings focused on “key science issues” relating to upcoming assessments.  And guess what?  An army of industry representatives, including staff for trade associations and paid consultants, are overwhelming the agendas.

Exhibit A:  Have a quick look at the list of speakers in the agenda for this month’s bimonthly meeting.  A striking imbalance, no?  As many as 8 industry representatives are set to speak on a given issue, including 6 from the same consulting firm!  [UPDATE 6/24/14:  See the top of this post for a description of the updated, slightly more balanced agenda; here is the agenda we had linked to that was current as of last week, and here's the updated agenda posted today.] Read More »

Posted in Health Policy, Health Science, Industry Influence| Also tagged , , | Read 2 Responses

New Draft of House Chemical Safety Bill Falls Short; EDF Calls on All Sides to Redouble Effort

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

Release in response to today's House Environment and Economy Subcommittee hearing on a revised discussion draft of the Chemicals in Commerce Act (CICA)

Today’s hearing makes clear that the discussion draft has made progress but still falls far short of legislation that will fix the fundamental flaws of the current law, according to Dr. Richard Denison, Lead Senior Scientist at Environmental Defense Fund. He urged all sides to keep the bipartisan process moving forward in both houses of Congress.

“While bipartisan discussions have yielded a number of substantial improvements to address serious concerns with the original draft, the most problematic provisions remain virtually untouched,” Denison said. “The goal now should be to keep the conversations going.”

Examples of progress include giving the Environmental Protection Agency (EPA) authority to require testing where data are insufficient for prioritization purposes; incorporation of deadlines for agency action to assess and address risks of high-priority chemicals; and less prescriptive and onerous information quality and evaluation requirements.

Sections of the draft pose major concerns and fail to strike a fair and reasonable balance. Examples include the sweeping preemption of state authority for chemicals never subject to a thorough EPA safety review; overly broad allowances for companies to mask the identity of chemicals even long after market entry; and a failure to ensure that conditions placed on new chemicals apply to all companies making or using them.

“We’re optimistic that solutions are at hand that address the needs of all stakeholders, but it is going to take a redoubling of effort by all sides to get there,” he said.


Posted in Health Policy, TSCA Reform| Also tagged , , , | Comments are closed
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