EPA can incorporate cumulative impacts in its chemical assessments right now

By Maria Doa, Senior Director, Chemicals Policy, and Lariah Edwards, Ph.D., EDF-George Washington University Postdoctoral Fellow

EPA recently asked its Science Advisory Board to provide advice on how it can incorporate cumulative impact assessments into its decisions making and on research to support cumulative impact assessments. At a public meeting of the SAB on March 2, we highlighted several areas where EPA can incorporate cumulative impact assessments right now.

Cumulative impacts refer to the total burden from chemical and non-chemical stressors and their effect on health, well-being, and quality of life. EPA asked the SAB for advice in two areas: First, what research should the agency conduct to strengthen the methods used in cumulative impact assessments. Second, and somewhat more important, how can EPA start now to incorporate cumulative impact assessments into its decision-making using data that is currently available.

People living in communities are often exposed to multiple chemical and non-chemical stressors. When individuals are exposed to multiple chemicals that cause a particular type of harm, they do not experience the risks for each chemical separately from the other. Nor are these chemical burdens experienced in isolation from other non-chemical stressors a person may face, like nutritional deficiencies or psychosocial stress. Cumulative impact assessments consider the combination and impact of both types of stressors, and therefore are more reflective of real-life conditions.

EPA assessments and decision making should take into consideration this reality and move away as much as possible from the status quo of evaluating one source, one chemical, and one environmental medium.

These two questions were discussed at the SAB’s March 2nd meeting. In her public comments EDF post-doctoral fellow Lariah Edwards strongly encouraged the SAB to provide EPA with advice on where and how in the short term it can incorporate cumulative impact assessments. 

She encouraged the SAB to consider the full range of decisions EPA makes from supporting regulatory decisions for managing chemical risks to screening and prioritizing potentially harmful substances.

There are several areas ripe for this consideration. One area we highlighted for the SAB was TSCA risk evaluations of existing chemicals, particularly for ortho-phthalates (commonly referred to as phthalates). Phthalates are a group of chemicals that cause similar harm, and exposure to multiple phthalates should be considered together, not individually as EPA has historically done. This is simply better science that reflects real conditions.

We commend EPA for requesting advice from the SAB on both how to improve the methods for cumulative impact assessments and how and where to use cumulative impact assessment in its decision-making now. A final report from EPA is due to be published by the end of June this year.

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