EDF Health

“Advanced recycling” is a toxic scam — now the EPA is turning a blind eye to some of the most toxic chemicals it produces

By Maria Doa, PhD, Senior Director, Chemicals Policy and Sara Hull, MPH, Project Manger, Safer Chemicals / Published: August 4, 2025

Advanced recycling is a false solution to the plastic waste crisis

What’s new: Last month, the Environmental Protection Agency (EPA) withdrew a proposed rule covering 18 new chemicals, which would have paused industry efforts to turn toxic oils from plastic waste into fuel until the agency could review their health risks. Companies make these oils through pyrolysis, a controversial process that essentially burns plastic waste—often full of toxic additives like lead, phthalates and PFAS—at high temperatures. Industry has sought for years to re-brand this inefficient and dirty process as “advanced recycling”—a false solution to the plastic waste crisis.

Why it matters: In 2022, the EPA approved the production and use of the 18 chemicals despite significant health risks documented in the agency’s own analysis. These risks include an up-to 1-in-4 lifetime cancer risk—250,000 times greater than what the EPA typically considers acceptable. It was only after residents near the facility in Pascagoula, Mississippi that received the approval learned of these risks and filed a lawsuit that the EPA finally pulled it back.

As damning as the EPA’s 2022 analysis was, it almost certainly underestimated the true risks of the 18 chemicals by failing to consider the known health risks of toxic additives such as lead, PFAS and dioxins commonly found in waste-plastic pyrolysis oils. In response to mounting pressure, the EPA issued the proposed rule in 2023 to address these additional risks. Because it is nearly impossible to make fuels from these oils that are free from toxicants, the rule had an immediate chilling effect on industry investment in “advanced recycling” that’s thawing now that it has been withdrawn.

Our Take: The proposed rule was effective because it would have required companies to notify the EPA before producing and using the new chemicals when they contain toxic plastic additives by designating it as a significant new use. This designation also would have given the agency time to evaluate potential risks to human health and the environment—and mitigate them if necessary.

The proposed rule was also significant because it represents the first time the EPA officially acknowledged that waste plastic-derived pyrolysis oils contain toxic additives “known to cause cancer and harm the reproductive system, among other health effects.” While we believe this rule (and the list of toxic chemicals requiring review) did not go far enough—and submitted comments to the EPA in 2023 explaining why—it was a big step in the right direction.

What’s the problem with so-called “advanced recycling?” Although industry touts “advanced recycling” as a solution to the plastic waste crisis, the process has major flaws. Not only does it fail to recycle anything, but it also rarely results in new plastic products. To make matters worse, the oils it produces are so toxic that their use is highly limited. Continued investments in “advanced recycling” will lock us into burning more polluting fossil fuels that contribute to climate change. Instead of spending its resources propping up this toxic scam, industry could devote them to developing truly innovative and safe solutions.

What’s next? With the rule now out of the way, the EPA is likely to reissue its approval of the 18 chemicals and propose a new set of “rules” that would ignore both the known cancer risks and the additional risks from the highly toxic additives. This would be an unacceptable outcome for public health. The agency must consider the full picture of risk—not just part of it.

With industry actively pushing to develop new facilities across the country—and simultaneously seeking exemptions from other pollution limits for facilities like the one in Pascagoula—the EPA’s reversal opens the door to more pollution and greater harm to both people and the environment. We must hold both the EPA and industry accountable to ensure these plastic waste-derived new chemicals filled with dangerous toxins are not approved—and that any future rules protect people and the environment from unreasonable risk.

To learn more about the health risks of “advanced recycling,” check out this recent Instagram reel by Sarah Vogel, Senior Vice President of Healthy Communities.

Posted in Adverse health effects, BPA, Chemical exposure, Chemical regulation, Contamination, Environmental justice, Frontline communities, Health policy, Industry influence, Phthalates, Risk assessment, TSCA, Vulnerable populations / Authors: , / Leave a comment

New report finds endocrine disrupting chemical in more than one-third of tested Indian clothing products

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: July 8, 2025

What’s new: A new report has found the cancer-linked endocrine disruptor, nonylphenol (NP), in one-third of tested Indian clothing products at levels exceeding European Union (EU) safety standards.

Scientists also detected NP in major Indian rivers downstream from textile hubs at levels that significantly exceeded international water quality standards. The report, Toxic Threads, was published by the Indian environmental research and advocacy organization Toxics Link in partnership with Environmental Defense Fund.

Common industrial applications of nonylphenol chemical

Common industrial applications of nonylphenol chemical (Toxics Link)

What is NP and where does it come from? NP is a chemical byproduct of degrading nonylphenol ethoxylates (NPEs), which manufacturers across several sectors use as a base ingredient in detergents, wetting agents, dispersants, defoamers, de-inkers and antistatic agents. Textile producers use NPEs most commonly in cleaning agents.

The Toxic Threads report’s key findings include:

  • NP was detected in 15 of the 40 products examined (about 35%).
  • NP levels in 13 out of the 40 products exceeded the current EU limit (<100 mg/kg).
  • 60% (9 out of 15) of baby and children’s products contained NP.
  • Female innerwear made with hosiery had the highest NP concentration of all garment types.
  • Significant NP contamination was found in several rivers near key Indian textile hubs.
  • NP’s presence in downstream locations and absence upstream strongly suggests point-source pollution from industrial activities, particularly textile manufacturing.

Why it matters: NP is an endocrine disruptor and has been linked to cancer. People, particularly children, can be exposed to it through everyday products they touch or might put in their mouths. NP’s persistence (how long it lasts), toxicity and ability to build up in the body over time makes it a significant threat to human health, the environment, marine ecosystems and the food chain. Because many textiles produced in India are exported, the associated health risks could extend to consumers in importing countries that don’t regulate NP in clothing, such as the United States.

Nonylphenol's path to waterways, marine ecosystems and the human body

Nonylphenol’s path to waterways, marine ecosystems and the human body (Toxics Link)

How can India protect its people and aquatic life from the dangers of NP? While several countries have taken proactive measures, India has yet to fully regulate against the harms of NP and NPE contamination.

The report recommends Indian leaders take decisive action to align with global efforts in restricting NP and NPE use. Strengthening regulations and promoting safer alternatives in textile manufacturing and consumer products are key to safeguarding human and environmental health and ensuring sustainable market practices.

Go deeper: Read the full Toxic Threads report here.

Posted in Adverse health effects, Carcinogenic, Chemical regulation, Cumulative impact, Endocrine disruptors, Environmental justice, General interest, Health policy, Health science, Public health, Worker safety / Authors: / Comments are closed

Six ways FDA can do better on food safety

By Maria Doa, PhD, Senior Director, Chemicals Policy, Liora Fiksel, Project Manager, Healthy Communities and Maricel Maffini, PhD, Consultant / Published: February 6, 2025

Refrigerated groceriesWhat Happened: 
Bipartisan support is growing for food safety reform as U.S. Food and Drug Administration (FDA) is considering comments on a new process for reassessing chemicals already on the market . On January 21, EDF submitted comments to FDA on how the agency should strengthen its proposal for a process to ensure the safety of existing ingredients in the market. While EDF supports modernizing FDA’s Human Food Program processes and methods, the current proposal falls short on transparency, efficiency, and scientific rigor.  

Why it Matters:
The public deserves a systematic, science-based approach to food chemical safety. FDA’s current process is outdated, opaque, and reactive rather than proactive. Delays in addressing chemical safety are common, with FDA often taking years to act on food additive petitions and chemical reassessments. Many food chemicals were approved decades ago using little or no data and have not been reevaluated since.    

FDA often relies only on its own studies, while ignoring or disregarding findings from other authoritative institutions such as the National Institutes of Health (NIH) and the European Food Safety Authority (EFSA), seemingly unable to acknowledge modernizing science. This failure to consider the full picture and the best available science undermines public health.  

Additionally, the agency fails to consider the cumulative effects of multiple related substances. People aren’t exposed to single chemicals in isolation, yet the FDA continues to evaluate them as if they are.  

While FDA leadership has emphasized that food chemical safety is a top priority for the Human Foods Program, historical lack of action has driven states like California to implement its own food additive regulations. This state-by-state approach creates a patchwork of rules that highlights the urgency for stronger federal leadership to protect all Americans from toxic chemicals. 

Our Take: 
FDA’s proposed process is a step forward but needs significant improvements.  

  1. FDA should set up a true prioritization process

    • FDA’s proposed process doesn’t identify which of the 10,000+ chemicals authorized to be used in food will be reassessed or why. FDA needs to outline specific criteria for prioritizing chemicals (e.g., risks to children’s health, endocrine disruption, biomonitoring data); start with high-priority chemicals identified by authoritative bodies like U.S. Environmental Protection Agency (EPA), International Agency for Research on Cancer (IARC) and the National Toxicology (NTP) Program; and make the process transparent by publishing rankings and methodology. Other agencies such as EPA have done this; FDA could build on their successful approaches.  
  2. Commit to comprehensive assessments 
    • FDA proposes using “focused assessments” based on limited data, skipping peer review and public transparency. FDA should commit to comprehensive assessments that use all available evidence and limit focused assessments to when immediate action is needed. 
  3. Enforce the Delaney Clause 
    • FDA must prioritize removing carcinogens, as mandated by law, without redundant reassessments. 
  4. Embed peer review and public input 
    • FDA should establish a scientific advisory committee, hold public comment periods, and ensure robust, external peer review for influential decisions.
  5. Separate risk assessment from risk management 
    • FDA should create an independent office to ensure unbiased chemical risk reassessments to avoid bias from teams that approve chemicals for market use. 
  6. Consider cumulative effects 
    • FDA often assesses chemicals in isolation, ignoring how we are exposed to multiple chemicals at the same time in real life. FDA should evaluate combined chemicals exposures, as required by law.

While developing this process, FDA can take immediate action on priority chemicals. EDF and others have already petitioned the agency to act on harmful phthalates, per- and poly-fluoroalkyl substances (PFAS), cancer-causing solvents (including methylene chloride), and titanium dioxide, BPA and lead. These toxic chemicals do not belong in our food. With growing bipartisan support for stronger food safety regulations, FDA has an obligation to be a leader in this space.  About two-thirds of American adults across political ideologies “strongly or somewhat favor” restricting or reformulating processed foods to remove added sugars and dyes signifying wide support for greater regulation on food additives.  

Next Steps: 
It is critical that FDA reevaluates its processes for determining the safety of chemicals in our food. EDF will continue to pressure FDA to act now on high-priority food chemicals, using the best available science and enforcing laws that effectively protect people’s health.  

Go Deeper:
Read the full version of the comments EDF submitted to FDA here. 

Posted in FDA, Food / Authors: , , / Comments are closed

Bipartisan Infrastructure Law helps Milwaukee replace harmful lead pipes

By Lindsay McCormick and Roya Alkafaji / Published: September 23, 2024

What’s New? 

With more than 70,000 lead service lines, Milwaukee holds the #5 spot in our top 10 cities with the most lead pipes. But the city is taking action to get the lead out. Officials are implementing a robust replacement program that leverages federal funding to focus on neighborhoods that need it the most. 

The Bipartisan Infrastructure Law, signed by President Biden in 2021, has enabled Milwaukee to triple its lead pipe replacement goals – from about 1,000 lines per year to 2,200 in 2024 and 3,500 in 2025.  

Critically, their program covers replacement of the entire line, including the portion on private property, at no cost to property owners. This practice avoids harmful “partial replacements,” which can increase the release of lead into the water and thus exposure to those that live in the home. Additionally, contractors must allocate 25% of project dollars to small business enterprises and ensure that 40% of work hours are performed by workers from local disadvantaged areas. 

Our partners at Waterloop took a deep dive into this issue:


Video courtesy: Waterloop 

 

Why it Matters 

Milwaukee’s program demonstrates exactly the type of progress to get the lead out that Congress and President Biden envisioned when they passed the Bipartisan Infrastructure Law – committing $15 billion in federal funds to tackling the issue of lead pipes across the nation.

This episode is just the first in a three-part series that spotlights communities at the forefront of these efforts to replace harmful lead pipes. Lead has been linked to permanent neurological damage and heart disease. Children, particularly in low-income communities and communities of color, experience the greatest burden from lead exposure. This is due to many factors, including discriminatory practices in housing that have left communities of color with greater poverty and substandard housing. 

Next Steps  

Stay tuned for upcoming Waterloop episodes on lead service line replacement, which are supported by EDF, the Environmental Policy Innovation Center, and BlueConduit. Explore our map to see if there are ongoing efforts to replace lead pipes in your community. If not, let us know – your input helps us keep the map up-to-date and showcase water utilities’ commitment to transparency across the country. 

Posted in Lead / Authors: , / Comments are closed

Cumulative assessment better estimates the real-world risks chemicals pose on our health

By Paige Varner, PhD, Scientist, Healthy Communities / Published: August 13, 2024
NOTE: This is the second of a series about EPA’s prioritization of existing chemicals. 

What Happened? 

EPA just proposed to designate five chemicals, including the widely-known toxic chemical vinyl chloride, as high-priority chemicals – meaning they are toxic to human and/or environmental health.  If finalized, these chemicals will immediately undergo the risk evaluation process under the Toxic Substances Control Act (TSCA).  

When designating these chemicals as high priority and moving forward in assessing their health risks, EPA can – and should – consider exposures to multiple chemicals that can cause the same health harms. To demonstrate the importance of these cumulative exposures, we conducted analysis on co-exposures to these five chemicals and submitted this analysis to EPA for greater consideration of real-world risks faced by individuals exposed to these toxic chemicals.  

Why It Matters 

Communities near industrial facilities are often exposed to multiple chemicals that cause the same health effects. Evaluating the health risk of these chemicals individually, as currently done by EPA’s TSCA program, often underestimates the true risks communities face. Additionally, many of these fenceline communities experience a variety of non-chemical stressors that exacerbate health effects from chemical exposure, such as physiological stress from poverty and racial discrimination, limited access to healthcare, or health effects from climate stressors like flooding and heat. Failing to consider these cumulative stressors on health in chemical risk evaluations often underestimates the actual risks these chemicals can pose to human health.  

Our Take 

Our analysis of Toxics Release Inventory (TRI) data from 2016-2021 shows that many chemicals that cause the same health effects – such as cancer, central nervous system (neurological), cardiorespiratory, liver, kidney, and thyroid, and reproductive and developmental effects – are often released together from the same facilities. For example, chemicals that cause cardiorespiratory effects are released with at least one other chemical that causes these same effects 74% of the time.  

For the five chemicals that have just been proposed as high priority under TSCA, all are known or probable carcinogens with some causing other adverse health effects. Based on our analysis, there are a few notable co-releases that EPA should consider when assessing cumulative risk with other chemicals causing the same harms. For example, creosotes, which are also probable carcinogens that can cause liver, kidney, and thyroid effects, are released 11% of the time with acrylonitrile, 18% with aniline, 11% with vinyl chloride, and 11% with 4,4-methylene bis(2-chloroaniline). 

Screenshot - Heatmap of co-releases of carcinogenic chemicals that are part of the TSCA Workplan.

Heatmap of co-releases of carcinogenic chemicals that are part of the TSCA Workplan. Legend represents the percentage of facilities releasing both chemicals out of the facilities releasing at least one of the pair of chemicals. Stars represent the 15 chemicals that were considered as part of TSCA’s pre-prioritization.

To demonstrate that EPA should also consider non-chemical stressors such as climate and environmental justice in its TSCA prioritization and risk evaluations, we looked at the vulnerability of communities to climate and environmental justice factors in areas where certain chemicals are released using EDF’s Climate Vulnerability Index. On average, vinyl chloride is released into communities with higher vulnerability than other chemicals analyzed – up to 12% higher than the average for other carcinogenic chemicals.  

What’s Next? 

EPA is now accepting comments on their proposal to designate these five chemicals as high priority, and we plan to submit comments to support the high priority designation. If finalized, EPA will begin risk evaluations for these chemicals. We hope EPA will consider cumulative risk and environmental justice as it moves through this process.   

In our next post in this series, we will recommend ways EPA can improve its prioritization process by considering risks from transportation and distribution of chemicals. 

Posted in Adverse health effects, Chemical exposure, Chemical regulation, Cumulative impact, Cumulative risk assessment, Environmental justice, Health policy, Public health, Regulation, Risk assessment, Risk evaluation, Rules/Regulations, TSCA, TSCA reform, Vulnerable populations / Authors: / Comments are closed

First things first: vinyl chloride data updates and our case for stronger evaluations

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: June 25, 2024
NOTE: This is the first of a series about EPA’s prioritization of existing chemicals. 

 What Happened? 

EPA recently announced it had initiated the prioritization process for five chemicals for upcoming risk evaluation.  One of the chemicals, vinyl chloride, is a highly toxic chemical known to cause liver toxicity and liver cancer in humans. The other four chemicals are also carcinogens and cause other toxic effects such as harms to pregnant women and infants.  

We have added these five chemicals to our Chemical Exposure Action Map. Our map shows releases of TSCA high priority chemicals, focusing on three major categories of health harms from cumulative exposure to these chemicals: cancer, developmental harm, and asthma.  U.S. map showing chemical facilities across the nationWhy It Matters 

Prioritizing a chemical as high priority is a key step in the process of evaluating and managing its unreasonable risks under TSCA.  The factors and data that EPA considers when prioritizing chemicals affects whether EPA designates a chemical as a high priority and how effectively the Agency will be able to assess its risks, especially to more highly exposed individuals and those more susceptible to the chemicals, like fenceline communities. 

We support the designation of these five chemicals, particularly vinyl chloride, as high-priority chemicals for evaluation.  However, as we explain in our recent comments, EPA can improve its prioritization process to consider the more real-world risks faced by people who are more highly impacted by these toxic chemicals.   

 Our Take 

EPA can improve its prioritization in two important ways.  

First, EPA should systematically prioritize chemicals released or used together that cause the same toxic harms.  Considering the cumulative risk posed by chemicals that cause the same harm provides a more complete and real-world picture of the risks fenceline communities face because exposure to multiple chemicals causing the same or similar health harms increases the risk of serious health problems.  

 Second, in prioritizing chemicals and evaluating the risks from these chemicals, EPA should consider exposures from accidental releases, including transportation accidents such as from the East Palestine, Ohio train derailment.  In the past, EPA has generally not considered these exposures despite the significant contributions they can have to the chemical’s risk. 

EPA has a major opportunity to improve its prioritization and evaluation processes so that it can develop a fuller picture of the risks posed by toxic chemicals. This would provide the Agency with the basis to develop regulations that will more fully protect human health and the environment, including for those people at greatest potential risk, like fenceline communities.  

What’s Next? 

EPA is now in the process of determining whether vinyl chloride and the other four chemicals the Agency is assessing should be designated as high priority chemicals.  If they are designated as high priority, EPA will begin risk evaluations for these chemicals.   

In our next post, we will recommend ways EPA can improve its prioritization process by incorporating cumulative risk analyses and considerations. 

Posted in Chemical exposure, Cumulative risk assessment, Risk evaluation / Authors: / Comments are closed