EDF Health

This week, EPA held its Science Advisory Committee on Chemicals (SACC) meeting to peer review its draft risk assessment on 1-bromopropane – one of the first 10 chemicals being evaluated under the reformed Toxic Substances Control Act (TSCA).

EDF provided both oral comments and written comments to the SACC, raising the following issues:

1. EPA inappropriately and illegally excludes all exposures to the general population from releases to air, water and land based on the unsupported assumption that other statutes adequately address the exposures;
2. EPA has failed to evaluate the risk to consumers of developing cancer from acute 1-BP exposure;
3. EPA errs in deeming a 1 in 10,000 cancer risk level reasonable for workers;
4. EPA lacks access to full studies and relies only on summaries, prepared by industry, of limited aquatic toxicity testing to conclude 1-BP presents no unreasonable risks to the entire environment; and
5. EPA overstates OSHA requirements and erroneously assumes that workers always use appropriate personal protective equipment. Yet in 2018 alone, OSHA cited 2,892 violations of the respiratory protection standard identified in 1,281 separate inspections, and such violations were the fourth most common type of violation.

Recently EPA has publicly stated that a number of the topics above are policy decisions outside the SACC’s charge (particularly, 1, 3 and 5). In our comments, EDF strongly disagreed, noting that all three decisions have major direct scientific consequences, and clearly lead EPA to underestimate the chemical’s risk – to the environment, the general population, workers, and vulnerable subpopulations.

For our full set of oral and written comments, see here.