Richard Denison, Ph.D., is a Lead Senior Scientist.
A constant criticism of EPA’s draft risk evaluations for the first 10 chemicals has been the dearth of information on which EPA has relied to draw sweeping, unqualified risk conclusions. EDF and other stakeholders, as well as EPA’s own Science Advisory Committee on Chemicals (SACC), have repeatedly pointed to the lack of sufficient, reliable information on:[pullquote]The Trump EPA appears intent on continuing to conduct risk evaluations that are ill-informed by actual data.[/pullquote]
- the chemicals’ presence in and releases into various environmental media;
- their presence in and releases from industrial, commercial, and consumer products and materials;
- the extent and magnitude of workplace exposure levels;
- key human hazard endpoints; and
- ecological hazards to and exposures of sediment- and soil-dwelling and terrestrial, as well as aquatic, organisms.
Concerns have also been repeatedly raised about EPA’s over-reliance on models in the absence of measured data and on physical-chemical and environment fate data to rule out exposure pathways, especially in the absence of rigorous uncertainty analyses and incorporation of uncertainty into EPA’s risk conclusions.
It’s not as if there isn’t a solution to the dearth-of-data problem. Yet the Trump EPA has steadfastly refused to use it. Read More