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 »

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

In a previous post, I argued that the European Union's REACH Regulation for chemicals goes a long way to address the regulatory needs for nanomaterials – despite the fact that REACH never mentions nano and was not developed with nano in mind.  I also noted, however, that REACH will clearly need more than fine-tuning to ensure adequate nano oversight.  Apparently at least some in the European Parliament agree.  Read more »

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

Some months ago, my colleague John Balbus posted here about studies finding that when multi-walled carbon nanotubes (MWCNTs) are injected into the abdominal cavities of mice, they induce inflammation and mesothelioma-like reactions similar to those caused by asbestos.  He appropriately cautioned that – among other critical questions – these studies had not demonstrated that inhaled MWCNTs could actually move out of the lung and into the tissues where asbestos gives rise to its effects.  Well, that particular dot now appears to have been connected. Read more »

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

As one who has closely followed the emergence of nanotechnology, I am sure I was not alone several years ago in welcoming what appeared to be a refreshingly new attitude among a broad range of stakeholders toward the introduction of this new set of technologies and materials.  Calls from my organization to "get nanotech right the first time" were echoed widely.  Perhaps the most frequently used metaphor, though, was that a "window of opportunity" had opened to do things differently this time.  But I increasingly fear that the window is closing. Read more »

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

In May 2008, the International Center for Technology Assessment (ICTA) submitted a petition to EPA requesting that it regulate nano-silver used in products as a pesticide under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  The petition calls on EPA to take the following specific actions:

1. Classify nano-silver as a pesticide.
2. Determine that nano-silver is a new pesticide and require its registration as such.
3. Analyze the potential risks of nano-silver to human health and the environment.
4. Take enforcement actions against nano-silver-containing products being sold illegally without EPA approval under FIFRA. Read more »