Monthly Archives: August 2018

PART 3: EPA rams through its reckless review scheme for new chemicals under TSCA, your health be damned

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

Part 1               Part 2               Part 3

I’ve been blogging over the last week about how political appointees at EPA are starting to clear new chemicals to enter commerce based on a new – apparently unwritten and certainly not public – review process that ignores the law and will put the health of the public, workers and the environment at greater risk than even under the weak reviews conducted before Congress’ 2016 overhaul of the Toxic Substances Control Act (TSCA).

The first green light was given to a fragrance chemical intended for use in a wide array of everyday consumer products.  Here is its formal name, a simpler synonym used by its manufacturer, and an identifier called a CAS number:[pullquote]Late in the review process EPA switched to analogue chemicals to estimate toxicity that are 500-fold less toxic than the analogue identified by the company and EPA’s own models.[/pullquote]

  • Name: Oxirane, 2-methyl-, polymer with oxirane, bis[2-[(1-oxo-2-propen-1-yl)amino]propyl] ether
  • Synonym: Jeffamine diacrylamide
  • CAS: 1792208-65-1

In this post I want to look more at what is known – and not known – about the chemical’s hazards.  While the chemical is a polymer, it includes “low molecular weight (LMW) components” that are the primary hazard concern.   Read More »

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PART 2: EPA rams through its reckless review scheme for new chemicals under TSCA, your health be damned

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

Part 1               Part 2               Part 3

I blogged last week about how political appointees at EPA are starting to clear new chemicals to enter commerce based on a new – apparently unwritten and certainly not public – review process that ignores the law and will put the health of the public, workers and the environment at greater risk than even under the weak reviews conducted before Congress’ 2016 overhaul of the Toxic Substances Control Act (TSCA).

In this post I’ll start to take a deeper look at the specific fragrance chemical that is the subject of EPA’s first decision under the new scheme:

Oxirane, 2-methyl-, polymer with oxirane, bis[2-[(1-oxo-2-propen-1-yl)amino]propyl] ether
CAS 1792208-65-1

Recall that, even as it declared the chemical safe, EPA noted its “potential for the following human health hazards: irritation, mutagenicity, developmental/ reproductive toxicity, neurotoxicity, and carcinogenicity.”  I’ll explore those hazard concerns more in a subsequent blog post.  Here, let’s consider use of and exposure to the chemical.[pullquote]Here’s the thing:  None of the parameters of the intended use is binding.  They can be deviated from at any time without consequence.[/pullquote]

With its decision, EPA has allowed this chemical to enter the market without any conditions whatsoever placed on how or how much of it can be produced or used or by whom.  This is in fact the aim of the new scheme and, barring another change in course, we can now expect this outcome for the great majority of new chemicals EPA reviews.  It will be achieved by EPA routinely making determinations that the chemicals are “not likely to present an unreasonable risk.”   Read More »

Posted in Health policy, Industry influence, TSCA reform / Tagged , , , , | Read 2 Responses

Paint-lead hazard standard – A reconsideration

Tom Neltner, J.D.is Chemicals Policy Director

After 20 years working on lead poisoning prevention, it has become almost second nature for me to object when someone suggests that children eating paint chips is a significant route of exposure. All too often, the claim implies that the blame rests with parents who are not conscientious enough to clean or maintain their home or to properly care for their children. The implication is demeaning to the parents and distracts from the often – invisible lead dust hazards on floors that pose the greatest risk to children. So when I hear that idea, I quickly respond that dust is the key route of exposure.

However, a discussion with Hannah Chang at Earthjustice over my blog on the Environmental Protection Agency’s (EPA) July 2, 2018 proposed rule helped me realize that I was misguided with regards to defining the hazards of lead-based paints. She is the main attorney for the organizations that convinced a panel of judges in the Ninth Circuit Court of Appeals to order the EPA to update its lead-based paint hazard standard.

Hannah Chang told me I missed the most compelling point when I pointed out in my previous blog that “EPA did not appear to have considered HUD’s 2007 American Healthy Housing Survey, which should provide a solid basis for identifying the relationship between lead in paint and lead in dust.”  She was right; my logic was too focused on dust as the primary source of exposure. Here is my reasoning; it may be helpful to those planning to submit comments to EPA by the August 16 deadline on the proposed rule.

Read More »

Posted in Health policy, Lead, Public health, Regulation / Tagged , , | Read 2 Responses

Families speak out on trichloroethylene exposure: It’s time for EPA to act

Samantha Lovell is a Project Specialist. Lindsay McCormick, is a Project Manager.

Today, families from across the country came to Washington, DC to tell lawmakers how the toxic chemical trichloroethylene (TCE) has impacted their lives.

TCE is a known human carcinogen that is toxic to the immune system and kidneys, and can cause fetal heart damage – among other harmful health effects.  The Environmental Protection Agency (EPA) proposed bans on high-risk uses of TCE under the newly reformed Toxic Substances Control Act (TSCA) back in December 2016 and January 2017, but under this Administration, the agency has abandoned these bans.

TCE is also one of the first 10 chemicals slated for a broad risk review by EPA under TSCA.  Unfortunately, EPA plans to ignore the major exposures Americans face from TCE and other toxic chemicals released to our air, water and land – yet another sign that EPA is giving in to the chemical industry to the detriment of the public’s health.

In a moving press conference today led by Sen. Tom Udall, several families shared their stories in an effort to pressure EPA to finalize the bans and take other necessary steps to protect communities across the country from TCE. Read More »

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PART 1: EPA rams through its reckless review scheme for new chemicals under TSCA, your health be damned

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

Part 1               Part 2               Part 3

Overruling the recommendations of its own longtime professional staff, political appointees at EPA have begun green-lighting new chemicals to enter commerce using an approach that shows contempt for the letter and intent of the 2016 reforms to the Toxic Substances Control Act (TSCA).

EDF blogged recently about the new approach and how it drastically deviates from what the law requires.[pullquote]Now any company will be free to produce, import and use the chemical in any manner it chooses and without any obligation to inform EPA of its activities.[/pullquote]

Today EPA posted the first decision made under the new scheme:  It issued a “not likely to present an unreasonable risk” determination for a chemical that, according to its manufacturer International Flavors and Fragrances Inc., is to be imported for use “to reduce malodors.  It will be sold to industrial and commercial customers for their incorporation into industrial, commercial, and household consumer products such as floor cleaners, cat litters, fabric refresher sprays, Etc.”

The “not likely” finding means that International Flavors and Fragrances Inc. can commence manufacture and sale of the chemical, and will not be subject to any conditions or limits.  Once manufacture starts, the chemical will be placed on the TSCA Inventory, and that company or any other will be free to produce, import and use the chemical in any manner it chooses and without any obligation to inform EPA of its activities.   Read More »

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