Hands off the Report on Carcinogens

Sarah Vogel, Ph.D., is Managing Director of EDF’s Health Program.

Information, and importantly, access to reliable and objective information, is the cornerstone of a democratic society.  That is why recent efforts by the chemical industry and its allies to block Congressionally-mandated, scientific information on carcinogenic hazards by defunding the Report on Carcinogens (ROC) have many researchers and public health officials alarmed. 

Today, in a letter sent to House and Senate appropriations committee leaders, 75 occupational and environmental health scientists and professionals from around the country called on Congress to maintain funding for the ROC.  Their letter is in response to a legislative proposal that, if passed into law, would withhold funding for any work on the ROC until the National Academy of Sciences (NAS) completes its review of the listings of formaldehyde and styrene in the 12th ROC—a process the NAS has only just begun.  If such a proposal were successful, it would effectively delay public access to critical information on chemical carcinogens for years.    

The ROC is a scientific report (see this factsheet) that identifies substances, including industrial chemicals and pesticides, either known or reasonably anticipated to be human carcinogens.  The development and the public release of the Report are mandated by Congress according to an amendment to the 1978 Public Health Act, which was written by EDF’s Andy Maguire who served in Congress at the time.  Since 1980, the National Toxicology Program, the interagency program charged with developing the ROC, has issued 12 reports, the latest of which was released last year and included the listings for formaldehyde and styrene.

Why in the world would some in Congress consider withhold funding for a Congressionally-mandated scientific report just because the NAS is conducting a review of two listed chemicals?  The simple answer is that the producers of those chemicals are profoundly unhappy that the 12th ROC identified formaldehyde as a known human carcinogen and styrene as reasonably anticipated to be a human carcinogen.

Defunding the ROC is just one part of an industry-coordinated challenge that is playing out on several fronts, including in Congress and the courts.  The larger strategic objective is to call into question the scientific rigor of the listing of formaldehyde and styrene, and challenge the legal authority and scientific soundness of the ROC.

Last year, a rider to the Consolidated Appropriations Act of 2012 mandated the NAS review of the formaldehyde and styrene listings in the 12th ROC.  For more background, see previous blog posts by EDF’s Richard Denison and NRDC’s Jennifer Sass.  The clear motivation for mandating the review was the unsupported assertion made by styrene and formaldehyde producers like Dow Chemical and the American Chemistry Council that the formaldehyde and styrene assessments were flawed because in part the entire ROC process is unsound.  Questioning the rigor of a scientific review or study is an oft-used tool by industry to seed doubt about scientific findings that call into question the safety of a chemical and threaten profitable markets for its producers.  It’s worth noting that the ROC’s scientific evaluation of formaldehyde and styrene are consistent with those conducted by the World Health Organization’s International Agency for Research on Carcinogens (IARC).  

In a letter to Ruth Lunn, Director of the Office of the Report on Carcinogens, back in February of this year, the ACC urged delaying the development of any future Reports until the NAS completed its review. In an effort to legally enforce such a delay, Representative Denny Rehberg (R-MT), chair of the House Appropriations Subcommittee on Labor, Health and Human Services, Education and Related Agencies, drafted a rider that would bar the NTP from using any funds in the FY13 budget for the ROC until the NAS completed its reviews of formaldehyde and styrene.  It is this last move that led environmental and occupational health scientists and professionals to mobilize in support of the ROC. 

On another front, the Styrene Information and Research Center and the Dart Container Corporation filed a lawsuit against Secretary of the Department of Health and Human Services, Kathleen Sebelius, that seeks to overturn the styrene listing and, more broadly and brashly, to challenge the legal status of the ROC.  EDF, United Steelworkers and occupational scientists, represented by Earthjustice, have intervened in the case to support HHS and ensure a vigorous legal defense is mounted. 

The common theme underlying all of these efforts by industry is an attempt to control scientific information and its dissemination to the public.  The threat posed to producers of styrene and formaldehyde by the listings in the 12th ROC—which are not regulatory decisions—is they might encourage businesses to look for safer alternatives, or spur calls for new protections for workers and vulnerable populations.  The aim is simple:  to keep markets open as long as possible for hazardous substances by questioning the science used in government’s risk assessments and effectively delaying risk management decisions. 

Promoting efficiencies in market decisions and appropriate regulations are necessary if we are to move toward safer products that protect the public’s health.  This is the point of ensuring access to independent and objective science in a democratic society.  Without such information, we—workers, medical officers, concerned consumers, retailers, product manufacturers, industrial hygienists, public health professionals, and the general public—are left in the dark unable to act to improve the quality of our lives, the products we make and use, and the places in which we live and work. 

Defunding the ROC would yank out a cornerstone of independent scientific assessment of chemical hazards upon which a healthy society depends.


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  1. Frank Mirer
    Posted September 5, 2012 at 6:40 am | Permalink

    I support the ROC. Defunding would be a travesty. The IARC monographs would be the next target if the ACC succeeds. Neither EPA, CDC, NIOSH or OSHA attempt a comprehensive list of agents and exposures with carcinogenic potential. The appearance of the ROC, when it appears, concentrates attention of such exposures.

    That said, the criteria for listing an agent as “reasonably anticipated” to be carcinogenic in the ROC are substantially less inclusive than the criteria for listing in the IARC monographs. This applies to several important agents listed by IARC as Group B, “possibly carcinogenic.” For example, diethanolamine and coconut diethanolamide – ingredients in metalworking fluids and contaminants in cosmetics – are classified as “possibly carcinogenic” by IARC but not listed in the ROC.

    • Sarah Vogel
      Posted September 5, 2012 at 11:40 am | Permalink

      Thank you for your very thoughtful comment. The greater variability in the IARC categories does allow for different levels of certainty to be captured.

  2. Roberta Era
    Posted September 6, 2012 at 12:07 pm | Permalink

    Thank you for sticking your necks out for the individuals right to KNOW . Science has become somehow (I know how – “corporate free speech” ) suspect in the rapid “dumbing down” of the American public. I do not need to be a scientist to see the short term goals of corporate America, and under the bus we will go without people standing up and joining you in your fight – your fight FOR US – Some of us are looking and seeing what is happening, and we are standing up behind you. I will finish up by sending emails to those who wish to bury this information, and with other emails from my friends, perhaps we can make a difference – YOU ARE BEING HEARD – thanks – Berta