EDF Health

Selected tag(s): risk evaluation

Haste makes waste: The Trump EPA’s 1,4-dioxane supplement may be its shoddiest TSCA work yet

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

Yesterday EDF submitted comments on a supplement to EPA’s 1,4-dioxane risk evaluation under the Toxic Substances Control Act (TSCA), which the agency issued a scant three weeks ago.

This solvent is a likely human carcinogen that contaminates drinking water nationwide and is present in millions of consumer products.

What EPA left out of its analysis swallows what it included.

The supplement expands the scope of EPA’s ongoing risk evaluation of 1,4-dioxane.  It now includes certain water exposures and certain exposures of consumers to products in which the chemical is present as a contaminant (more technically, a “byproduct”).

EPA rushed the public comment period, providing only 20 days and refusing requests from at least 14 organizations for an extension.  The agency also cut out another vital step in the process – peer review –in violation of its own rules for how risk evaluations are to be conducted.

But that wasn’t the only thing EPA rushed.  The Supplement itself was an 11th-hour affair, done mainly to appease a hypocritical demand from the formulated chemical products industry.

The haste with which it was assembled badly shows.  The additional exposures EPA examined are so narrowly constructed as to omit major, and potentially the largest, sources of exposure and risk people face from the presence of 1,4-dioxane in water and products.

And what EPA left out of its analysis swallows what it included.  Read More »

Posted in EPA, Health Policy, Health Science, Regulation, TSCA Reform, Worker Safety / Also tagged | Comments are closed

EPA’s final risk evaluation of trichloroethylene is scientifically flawed and understates risks to workers, the general public and those most susceptible

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

Today the Trump Environmental Protection Agency (EPA) issued its final risk evaluation for trichloroethylene (TCE).  It largely tracks the agency’s draft document, retaining numerous flaws that severely understate the highly toxic chemical’s risks to workers, the general public and those most susceptible to its health impacts.

Among the evaluation’s most serious deficiencies is the abandonment of a bedrock principle of chemical risk assessment: that risk estimates be based on the most sensitive health effect.  Sadly, the final document retains the unprotective approach the Trump White House forced EPA to adopt, as reported in detail by Elizabeth Shogren of Reveal News.

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

Below we summarize some of the major concerns in EPA’s evaluation that we addressed in detail in our comments.

One silver lining:  Despite its glaring deficiencies, the risk evaluation did find that the great majority of TCE’s conditions of use present unreasonable risks—even as it grossly understated the extent of those risks.  As a result, EPA must now proceed to regulate those activities, providing the new Administration an opportunity to rectify the serious problems created by the Trump EPA.  Read More »

Posted in EPA, Health Policy, Health Science, Industry Influence, TSCA Reform / Also tagged | Comments are closed

Passing the buck: The Trump EPA’s mind-boggling efforts to ignore the risks of 1,4-dioxane in drinking water

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

Readers of this blog will recall the major concerns EDF, EPA’s science advisors, and many others have raised about the Trump EPA’s systematic exclusion from its risk evaluations of all human exposures to chemicals released to air, water and land.  EPA has taken this illegal, unscientific and un-health protective approach across the board in the risk evaluations it has issued to date in draft or final form under the Toxic Substances Control Act (TSCA).

EDF first flagged the emergence of this fatally flawed approach over two years ago, and again when it was applied to the likely human carcinogen 1,4-dioxane, one of the first 10 chemicals undergoing TSCA risk evaluations.  Since then the Trump EPA has doubled down, repeatedly defying its own science advisors who have called out this deficiency in virtually all of their peer reviews of EPA’s draft risk evaluations.  EPA is clearly refusing to budge, issuing two final risk evaluations for methylene chloride and 1-bromopropane that seek to codify the approach.

EPA’s Office of Water is deferring any decision on whether to regulate 1,4-dioxane in drinking water, pending completion of a risk evaluation that expressly excludes that exposure.  That exclusion is in turn based on the TSCA office’s claim that the Office of Water already has it covered.

The asserted basis for ignoring tens of millions of pounds of these chemicals released annually is EPA’s claim that the releases are adequately managed under other laws the agency administers.  To bolster that claim, EPA also asserts that it has closely consulted with the EPA offices that administer those other laws to ensure this is the case.  Let’s take a closer look at the nature – and apparent effects – of that consultation in one setting:  1,4-dioxane in drinking water, which falls under the authority of the Safe Drinking Water Act (SDWA) administered by EPA’s Office of Water.  Read More »

Posted in EPA, Health Policy, Regulation, TSCA Reform / Also tagged | Read 1 Response

What the heck is going on with EPA’s risk evaluation fees under TSCA?

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

What a mess.  That’s the best that can be said from the outside about the process EPA has followed to decide which companies are to pay fees to help defray the agency’s costs of conducting risk evaluations for the next 20 chemicals under the Toxic Substances Control Act (TSCA).

EPA’s steps to endanger its ability to collect the fees under TSCA that Congress mandated border on self-sabotage.

These fees were set forth in EPA’s final TSCA fees rule issued in October 2018.  The total fee assigned to each of the next 20 chemicals for which risk evaluations are now underway was set at $1.35 million.  That fee is to be paid by manufacturers (including importers) of a chemical.  TSCA provided EPA with authority to charge processors of these chemicals a fee as well, but the agency opted to exclude processors from such fees in its final rule (see p. 52,696).  EPA also opted not to charge fees to cover any of the costs it incurred for the first 10 risk evaluations (see p. 52,708 of the fees rule), although it had authority to do so.

Last week EPA issued what it calls its “interim final list” of companies obligated to pay fees to cover the costs of the next 20 risk evaluations.  The list is dramatically scaled-back from the agency’s earlier list, and it is impossible for the public to understand the basis for the changes.  That is in no small part due to the convoluted, opaque, and legally suspect process EPA has followed.  Read More »

Posted in EPA, Health Policy, Industry Influence, TSCA Reform / Also tagged | Comments are closed

EPA flouts the law, science, and its obligation to protect public health yet again: The 1-bromopropane final risk evaluation

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

Today, the Trump EPA released its second final risk evaluation and determination under the reformed TSCA, for the carcinogenic solvent, 1-bromopropane (1-BP).

EPA has once again ignored expert scientific input it received from its own advisors.

As was the case with the final document for methylene chloride – which has already been challenged in court (see here and here) – EPA has doubled down on the illegal, unscientific, and un-health protective approach it has taken in all of its draft risk evaluations for the first 10 chemicals reviewed under TSCA.

EDF will be closely examining this final document, but it is already apparent that EPA continues to grossly and systematically underestimate the exposures to and risks of 1-BP to the general public, workers and the environment.

Below are four examples of the flaws; each was raised by EPA’s own Science Advisory Committee on Chemicals (SACC) in its peer review as serious deficiencies – expert scientific input that EPA has simply chosen to ignore in finalizing the document:  Read More »

Posted in EPA, Health Policy, Health Science, Industry Influence, Public Health, Regulation, TSCA Reform, Worker Safety / Also tagged | Read 1 Response

“Illegal, unscientific, and un-health protective”: Summing up EPA’s final methylene chloride risk evaluation

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

Today, the Trump EPA released its first final risk evaluation and determination under the reformed Toxic Substances Control Act (TSCA), for the carcinogenic and acutely lethal chemical methylene chloride.

Sadly, despite EPA’s rush to issue this document as the 4th anniversary of TSCA reform on June 22 approaches, EPA doubled down on the illegal, unscientific, and un-health protective approach it has taken in all of its draft risk evaluations for the first 10 chemicals reviewed under TSCA.

EDF will be closely examining this final document, but it is already apparent that EPA has grossly and systematically underestimated the exposures to and risks of methylene chloride.  Read More »

Posted in EPA, Health Policy, Health Science, Industry Influence, Public Health, Regulation, TSCA Reform, Worker Safety / Also tagged , | Comments are closed