Monthly Archives: June 2010

Hurry up and wait: Not much new revealed by EPA's initial round of dispersant toxicity testing

By | Bio | Published: June 30, 2010

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

EPA held a press call today to discuss the initial results of its own testing of oil spill dispersants.  The testing by EPA was initiated after BP resisted complying with an EPA-Coast Guard Directive issued May 20 that directed the company to identify and switch to dispersants that are less toxic and more effective than the two Corexit® dispersants on which BP has exclusively relied to mitigate the effects of the oil disaster unfolding at Deepwater Horizon.  In expressing disappointment with BP’s response to the Directive, EPA indicated it would initiate its own toxicity and effectiveness testing of Corexit and other dispersants.  Today’s call reported on round 1 of that testing.

First let me say I applaud EPA for taking on the unglamorous task of conducting further testing and seeking to answer questions that would have been nice to have had answers to well before this mess developed.  Second, I understand that testing takes time, that this is only round one and EPA says more is coming, so that at least partially compensates for the distinctly anticlimactic feeling I had listening in on today’s call.

So, what did we learn today?  Not too much new. Read More »

Posted in Data requirements, Environment, EPA, Hazard, Oil dispersants, Testing | Tagged | Comments closed

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

By | Bio | 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 »

Posted in Data requirements, Environment, EPA, Hazard, Industry, Oil dispersants, Policy, Testing, U.S. Government | Tagged | Comments closed

Correction to my last post: Clarification from EPA

By | Bio | 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.

Posted in EPA, Health, Industry, Oil dispersants, U.S. Government | Tagged | Comments closed

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

By | Bio | 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 »

Posted in Environment, EPA, Health, Industry, Oil dispersants, U.S. Government | Tagged | Comments closed

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

By | Bio | 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 »

Posted in Environment, EPA, Health, Oil dispersants, TSCA | Tagged | Comments closed

Are you a guinea pig?

By | Bio | Published: June 15, 2010

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

The answer to that question — or at least what should be the answer — is the name of a new campaign launched today by Environmental Defense Fund, in cooperation with the Safer Chemicals, Healthy Families coalition and a number of its member organizations.

I Am Not a Guinea Pig is a new online campaign that provides tools and information Americans from all walks of life can use to press for fundamental reform of our nation’s toxic chemical law, the Toxic Substances Control Act (TSCA).

I Am Not a Guinea Pig is aimed at helping to ensure that the voices of millions of Americans who are concerned about and affected by exposures to untested and unsafe chemicals are heard as Congress begins the first serious effort to overhaul the 34-year-old TSCA.

The campaign will use a variety of social media, including a website, a Facebook page with daily updates, and a #NAGP Twitter hashtag.

Our thanks go out to our partners in Safer Chemicals, Healthy Families with whom we've worked in our initial effort: Autism Society, Health Care Without Harm, Learning Disabilities Association of America, Moms Rising, Reproductive Health Technologies Project and Teens Turning Green.

The campaign initially focuses on three groups at particular risk from toxic chemical exposures:  teens, children and health professionals.  We'll be expanding the campaign over time to include others at risk, and we'll continue until we've achieved the campaign's fundamental aim:  a strong new chemicals policy in the United States that protects all Americans from toxic chemicals.

Posted in Exposure, Hazard, Health, Policy, TSCA | Comments closed

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

By | Bio | 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 »

Posted in Environment, EPA, Hazard, Industry, Oil dispersants | Tagged | Comments closed

Dispersants are a teachable moment for TSCA reform

By | Bio | 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 Confidential business information (CBI), Environment, EPA, Health, Oil dispersants, Policy, Testing, TSCA | Tagged | Comments closed

EPA clarifies it wants more information on those dispersants made public

By | Bio | Published: June 9, 2010

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

EPA issued a statement today drawing attention to its posting on its website late last week of the ingredients in NALCO’s Corexit® dispersants, more than one million gallons of which have now been released into the Gulf of Mexico.  The statement appears to have been issued in response to queries from myself and others as to why the posting was not more prominently flagged by EPA.  It indicates that the most recent disclosure “was possible because NALCO waived their claim” that the ingredient identities are proprietary.  It also makes clear EPA doesn’t consider Nalco’s disclosure to be the end of the story, and that EPA will continue to seek to provide the public with more information about the dispersants than their producers have produced to date.

I’ve posted EPA’s statement just beyond this jump. Read More »

Posted in Confidential business information (CBI), EPA, Industry, Oil dispersants, Policy, TSCA | Tagged | Comments closed

Presto: Corexit® dispersant ingredients revealed

By | Bio | Published: June 8, 2010

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

With no fanfare whatsoever, a list of the ingredients in the Corexit® dispersants has been posted on EPA’s website.  I can’t say when the list appeared — I was pointed to it by Elana Schor, a reporter with E&E News, who discovered the list a little earlier today, buried well down on the agency’s dispersants page. 

The components of COREXIT® 9500 and 9527 are:

CAS Registry Number Chemical Name
57-55-6 1,2-Propanediol
111-76-2 Ethanol, 2-butoxy-
577-11-7 Butanedioic acid, 2-sulfo-, 1,4-bis(2-ethylhexyl) ester, sodium salt (1:1)
1338-43-8 Sorbitan, mono-(9Z)-9-octadecenoate
9005-65-6 Sorbitan, mono-(9Z)-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivs.
9005-70-3 Sorbitan, tri-(9Z)-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivs
29911-28-2 2-Propanol, 1-(2-butoxy-1-methylethoxy)-
64742-47-8 Distillates (petroleum), hydrotreated light

More to come.

Posted in Confidential business information (CBI), Environment, EPA, Hazard, Oil dispersants, TSCA | Tagged | Comments closed