Monthly Archives: January 2023

EPA Should Address Cumulative Risks from New Chemicals

Names of blog authors: Maria Doa, PhD, Sr. Director, Chemicals Policy, and Lariah Edwards, PhD, Associate Research Scientist, Columbia University

What’s Happening? EPA’s current safety assessments of new chemicals proposed for market entry often fall short of effectively protecting all members of the public from risk because they don’t consider that we may be exposed to closely related chemicals that cause similar harms.

Recent Example: EPA proposed rules requiring notification of significant new uses for a group of new chemicals. Two of these chemicals, known as trimellitate esters, are very closely related, and would be expected to cause very similar harms and have very similar uses—so that people exposed to one chemical would likely be exposed to the other. Despite this, EPA did not consider the chemicals together or even use the information it had on one to inform its understanding of the safety of the other.

This doesn’t make sense.

Even though EPA said that one chemical was intended to be used as a lubricant and the other as a plasticizer (a chemical that makes plastics more flexible), it is likely that both could be used as a plasticizer or a lubricant. They may be used together or turn up in similar consumer products, such as a car’s dashboard. Further, both chemicals are very closely related to yet another plasticizer used in the auto industry, but it appears that EPA considered these nearly interchangeable chemicals in isolation from one another.

Items that require plasticizers for production. They include seats in cars, rain boots, a garden hose, medical gloves, an exercise ball, and rolls of wallpaper.

In fact, under the Toxic Substances Control Act (TSCA), EPA is required to identify such “reasonably foreseen uses,” such as ending up in the same product.

Why It Matters: Evaluating chemicals in isolation likely underestimates the exposures and risks workers, consumers, and frontline communities face. Doing so also fails to make use of all the best available science, since information on each of these two chemicals (as well as the one already being used) could inform the safety determination for the other.

Considering the combined risks from similar chemicals is not new. EPA is already doing this for another group of closely related chemicals—phthalates. Phthalates have long been widely used in a range of consumer products and are detected in almost all our bodies. Phthalates are known to impact male reproductive health. EPA is joining the ranks of other federal agencies that have considered the cumulative risks they pose.

Our Take: EPA should not stop at phthalates. They can and should be incorporating cumulative approaches from the very beginning of a chemical’s regulatory life. Considering the impact of combined exposures does not need to be complicated and EPA could make such a consideration without much extra effort.

EPA can take a first step toward doing this by considering the potential for cumulative risks when finalizing its regulation on the significant new uses for these two new closely related chemicals.

Go Deeper: Read EDF’s response to EPA’s proposed new SNURs. And check out our Cumulative Risk Assessment Framework.

Posted in Environment, Health science, Industry influence, Public health, TSCA / Comments are closed

Denver Water proves its Lead Reduction Program is a national model

Tom Neltner, Senior Director, Safer Chemicals and Lindsay McCormick, Senior Manager, Safer Chemicals

What’s New: After an extensive review process, EPA approved Denver Water’s request to extend the variance to allow the utility to administer their Lead Reduction Program for the full 15-year term. EPA touts Denver Water’s Lead Reduction Program as an “innovative and aggressive approach” to lead service line replacement (LSL) in a letter approving the variance.

Denver Water will continue to:

  • replace all lead service lines at no cost to homeowners,
  • provide residents with filters to help reduce their exposure in the short-term, and
  • use an alternative approach to water treatment that still ensures effective corrosion control.

We applaud their emphasis on environmental justice and commitment to ensure that the program continues to prioritize disproportionately impacted neighborhoods – and EPA’s new requirement to track this progress.

This fall, we visited Denver Water’s field operations to see for ourselves how it is successfully replacing more than 4,500 lines per year. We were impressed by what we saw, and sent a letter to EPA’s Regional Administrator expressing our full support for Denver Water’s March 2022 request to continue their program. Read More »

Posted in Drinking water, Lead / Tagged , , , | Authors: / Comments are closed