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.
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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 »

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

This post is the first of a number to come that will examine in some detail specific chemicals and chemical categories for which EPA has made questionable or flawed risk decisions under ChAMP. Many of these problems can be traced to EPA's near-exclusive reliance on incomplete or poor-quality data provided by manufacturers, or its need to resort to unsupported assumptions in the absence of sufficient data. For each posting, we'll summarize what is known about production and use of the chemical(s); describe EPA's hazard, exposure, risk and priority rankings; and then discuss why we question or disagree with EPA's decisions. First up: a category of three alkyl nitriles. Read more »

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

[Earlier posts in this series can be found here and here.]

Over the past decade, the Environmental Protection Agency (EPA) has pursued a voluntary program, the High Production Volume (HPV) Chemical Challenge, as a means to fill the enormous gaps in publicly available data on the hazards of the most widely used chemicals in the U.S. Using the Challenge data, EPA has recently begun assessing HPV chemicals under its Chemical Assessment and Management Program (ChAMP). But is ChAMP up to the job? Read more »

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

[The first post in this series can be found here.] 

Some in the chemical industry point to EPA's New Chemicals Program as a robust program, one that could serve as a model for reform of the Toxic Substances Control Act (TSCA).  Most recently, the National Petrochemical & Refiners Association (NPRA) did so in its testimony at a recent House of Representatives subcommittee's TSCA oversight hearing.  So just how robust is EPA's program on new chemicals?  Read more »

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

For the past several years, EDF has been in the thick of discussions about whether the Toxic Substances Control Act of 1976 (TSCA) needs reform and, if so, what form it should take.  Happily, the former question has largely been answered:  With only a few remaining holdouts, even the chemical industry acknowledges the time has come.  So now we can move on to what such reform should look like - and what it should not. Read more »

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

You may have noticed some subtle changes to the look of this page.  That's because EDF has decided to expand the focus of this blog to include the policy, legislative, regulatory and scientific issues surrounding the health and environmental impacts of chemicals, as well as nanomaterials. Read more »