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

Over the last few months, I was heartened to hear a number of industry stakeholders in the debate over TSCA reform embrace the idea of designating in TSCA reform legislation a "jump-start" or "quick-start" list of chemicals of high concern or priority.  The idea was to allow EPA to hit the ground running, by having an agreed-to list of chemicals on which it could immediately initiate action.  Well, it now appears many in industry actually have something far slower and far more cumbersome in mind. Read more »

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

When the chemical industry talks about prioritization – a central question in the debate over TSCA reform – more often than not it quickly reduces the question down to the argument that we should focus only on those chemicals, however hazardous or untested they may be, to which we know people are exposed.  In a perfect world, that might suffice.  But, as this post will explore, the world of exposure assessment is anything but perfect.  Read more »

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

A new entry showed up sometime in the last day on EPA's webpage for its ChAMP initiative.  It reads:  "The Chemical Assessment and Management Program (ChAMP) has been superseded by the comprehensive approach to enhancing the Agency’s current chemicals management program announced by Administrator Lisa Jackson on September 29, 2009." 

Don't miss this bit at the top of the page:

Yes, that image is a cobweb, which EPA uses to designate archived web content.  What's happening here? Read more »

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

It probably goes without saying that EDF welcomes EPA's decision to suspend the development and posting of risk-based prioritizations under its Chemical Assessment and Mangement Program (ChAMP).  EDF has been arguing (see our earlier posts) that ChAMP's "rush to risk" has taken EPA badly off-track.  But we have also identified many useful things that EPA's existing chemicals program can and should be doing with the data it obtained through the HPV Challenge (whether called ChAMP or not) .

We look forward to working with EPA to craft a new approach, grounded in a return to developing scientifically defensible hazard, not risk, characterizations and transparently identifying and addressing data gaps and data quality problems.

Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

Many of the screening-level hazard data being collected and analyzed under ChAMP that pertain to human health are derived from traditional laboratory animal studies.  The National Academy of Sciences (NAS) recently offered a "new paradigm for toxicity testing" in its 2008 report Toxicity Testing in the 21^st Century: a Vision and a Strategy.  Can ChAMP hazard data be used to facilitate the development of new testing strategies?  Read more »

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

This new post serves as a response to Charlie Auer's most recent comment responding to our critique of ChAMP.  (To see the whole exchange, start here, then go here, here and here.)  So far, this exchange has focused mainly on our disagreement over whether or not EPA is somehow required to do risk assessments under ChAMP.  At some point, I hope Charlie and others will engage on the substance of our critique – the serious concerns we've raised about the quality and validity of the ChAMP assessments.
  Read more »

Cal Baier-Anderson, Ph.D., is a Health Scientist.

In our critique of EPA's Chemical Assessment and Management Program (ChAMP), we have pointed out that, despite its limitations, there is value in the hazard data that EPA is collecting and analyzing.  How so? Read more »

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

As I noted in our first post on ChAMP, after getting off to a strong start in 2007, EPA's abrupt decision in 2008 to steer ChAMP in the direction of cranking out hasty risk decisions was entirely its own.  Can ChAMP be put back on track?  Read more »

Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

This example raises some new issues as well as some we discussed in the earlier examples:  EPA relies on a highly flawed "category approach" that ignores major differences in the properties and structures of the 13 members of this category.  It compounds this problem by unquestioningly accepting data from inadequate studies to assert low toxicity, rather than demanding that sufficient studies be provided.  As a result, it fails to identify, let alone require to be filled, the enormous gaps in the data available for many of the category members.  EPA ignores or dismisses without explanation its own earlier comments raising serious concerns about the quality and completeness of data provided by the sponsor of these chemicals under the HPV Challenge.  Finally, this example once again shows how EPA's heavy reliance on self-reported use information from manufacturers paints an incomplete and potentially very misleading picture of the actual uses of industrial chemicals.  Read more »

Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

Our analysis of EPA's risk decision under ChAMP for this category of toxic chemicals vividly illustrates how EPA has failed to adopt a health-protective approach to its screening of HPV chemicals.  Rather, it misclassifies or understates these chemicals' hazards, asserts that existing regulations are sufficient even when they are quite old or do not cover identified exposures, and naively assumes that children will not be as exposed as adults to consumer products used in the home unless they are intended for their use.  Finally, this case demonstrates that manufacturers are not reporting to EPA even readily available information on their chemicals' uses.  Read more »