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Richard Denison, Ph.D., is a Lead Senior Scientist.
Last week, the EPA Science Advisory Committee on Chemicals (SACC) conducted a virtual peer review meeting for the Agency’s draft risk evaluation of trichloroethylene (TCE). As expected, there was substantial discussion on the appropriateness of EPA’s decision to make risk determinations based on immune endpoints rather than fetal cardiac malformations (FCMs). Unfortunately, the review panel lacked anyone with specific expertise in cardiac development.
During the meeting, many of the peer review panelists signaled an initial inclination toward supporting EPA’s decision to use immune endpoints for risk determinations. However, panel members also noted with serious concern the recent investigations that have uncovered political influence exerted on EPA that led it to base the risk determinations in the draft risk evaluation on immune endpoints instead of FCMs.
Stepping back from the specifics of the discussions last week, it is important to understand the longstanding basis and support for EPA’s reliance on FCMs, the unprecedented nature of EPA’s decision to now move away from it, and the adverse implications of the decision for EPA’s ability to adequately manage the risks of TCE to all relevant subpopulations.
This decision is a major departure from thoroughly peer-reviewed science, fails to protect the most sensitive populations as mandated by TSCA, and deviates dramatically from existing Agency guidance. These concerns, discussed at length in EDF’s comments in the TCE Docket, are briefly summarized below: (more…)
Richard Denison, Ph.D., is a Lead Senior Scientist.
Yesterday Environmental Defense Fund (EDF) filed comments on the Environmental Protection Agency’s draft risk evaluation for the highly toxic chemical trichloroethylene, or TCE.
This draft, readers will recall, is the document that the Trump White House forced EPA to dramatically weaken just prior to public release, as reported in detail by Elizabeth Shogren of Reveal News.
It is also the document that EPA seems intent on subjecting to a rushed peer review next week in a 4-day virtual meeting of the Scientific Advisory Committee on Chemicals (SACC) – despite numerous reasons why, in the midst of the current COVID-19 public health crisis, such a meeting simply will not provide the robust scientific review that this draft warrants. EDF has urged EPA to postpone the SACC review so that it can be done under circumstances that are conducive to a proper review and fair to SACC members and stakeholders who would like to participate.
EDF submitted comments yesterday in order to meet the very tight deadline EPA set for comments if they are to be considered by the SACC. Our comments raise numerous scientific deficiencies in EPA’s draft. These flaws arise from a host of unwarranted and unsupported assumptions and methodological approaches that systematically lead EPA to understate the risks posed by this chemical to pregnant women, infants and children; to workers; to consumers; to the public; and to the environment.
Exposure to TCE is ubiquitous, coming from ambient and indoor air, vapor intrusion from contaminated sites, groundwater and drinking water wells, and food – yet EPA’s draft ignores or downplays each of these exposure sources and pathways.
It is vital that the current public health crisis caused by COVID-19 not be allowed to compromise the quality and integrity of scientific assessments of other critical public health risks we face.
Below I summarize some of the major concerns in EPA’s draft that we address in detail in our comments. (more…)
Richard Denison, Ph.D., is a Lead Senior Scientist.
As we all deal with an emerging major health crisis, it is critical that the quality of ongoing work on other issues vital to protecting public health is not sacrificed or compromised as a result. Given this, we strongly urge EPA to postpone next week’s peer review of its draft risk evaluation of trichloroethylene.
A few short weeks ago, EPA issued a draft risk evaluation for a highly toxic chemical, trichloroethylene or TCE. The draft is many hundreds of pages long (thousands of pages counting supplemental files). EPA also scheduled the peer review by the Scientific Advisory Committee on Chemicals (SACC) for next week, March 24-27.
Even before the COVID-19 crisis, the time frame EPA provided for getting meaningful expert review of this important document was already questionable. Now it is simply untenable.
As of now, EPA intends to proceed with the meeting as a virtual meeting. While traveling to a meeting next week should of course be off the table, proceeding with a virtual meeting at this point is asking far too much of SACC members and their families and will clearly lead to a severely compromised peer review. Consider, for example:
As we are learning in real time during this unfolding health crisis, ensuring there is sound expert input into public health decisions is absolutely essential. We cannot let the current crisis result in a weakening of the quality and credibility of scientific input on other important public health issues.
EPA needs to promptly postpone the SACC peer review of TCE and reschedule it at a time and in a manner that respects the critical role the SACC plays.
Richard Denison, Ph.D., is a Lead Senior Scientist.
This weekend, Elizabeth Shogren at Reveal News published an in-depth investigative report and hour-long radio segment delving into the Trump EPA’s latest abandonment of science and its serious consequences for public health. The story focuses on the ubiquitous solvent trichloroethylene (TCE), a known human carcinogen and neurotoxicant that is also linked to birth defects at very low levels of exposure.
In reforming the Toxic Substances Control Act (TSCA) in 2016, Congress directed EPA to conduct comprehensive reviews of the risks posed by TCE and other widely used chemicals. EPA was charged with identifying risks both to the general public and to “vulnerable subpopulations,” including pregnant women, infants, workers, and others.
EPA’s draft risk evaluation of TCE was released on February 21. It suffers from many of the same gaping flaws as do EPA’s draft risk evaluations for other chemicals. Once again, EPA has utterly failed to carry out the clear intent of the law, putting our health at greater risk.
[pullquote]“This decision is grave. It not only underestimates the lifelong risks of the chemical, especially to the developing fetus, it also presents yet another example of this administration bowing to polluters’ interests over public health.”
— Dr. Jennifer McPartland[/pullquote]But in this new draft EPA has gone even further in abandoning both science and the law. Reveal’s exposé identifies key changes made at the 11th hour to the draft that were forced on career staff at the agency by the White House.
Here are five key takeaways from the Reveal story: (more…)
Richard Denison, Ph.D., is a Lead Senior Scientist.
Next week, the Scientific Advisory Committee on Chemicals (SACC), established under the Toxic Substances Control Act (TSCA) to peer-review EPA’s draft chemical risk evaluations, will meet to review the latest of those drafts, for the likely human carcinogen carbon tetrachloride.
As with other recent draft risk evaluations, EPA has been scheduling the SACC meetings in the middle of rather than following the public comment period. This means the public has at best a few weeks to digest these huge documents and draft and submit comments in order to have them be part of the record that the SACC is allowed to take into consideration in its peer review.
However, we have learned that EPA is now further constraining the SACC’s schedule, requesting that the panel members come to the peer review meeting with their comments already drafted, and then delivering their final report within 60 days rather than the 90 days previously provided. These developments further jam both the public and the SACC in their efforts to ensure EPAs work is subject to a robust peer review.
Whatever the reasons for EPA making these changes, EDF decided to expedite our initial comments to seek to ensure they could be considered. We submitted comments last week, a full week before the February 19 deadline, to ensure the SACC received and had sufficient time to review them in advance of the peer review meeting.
We deemed this critical because of the glaring gaps and flaws in EPA’s draft that lead it yet again to drastically understate the risks of this chemical. These include the same problems that have plagued the draft risk evaluations for other chemicals, as well as new ones. (more…)
Tom Neltner, J.D. is the Chemicals Policy Director.
See all blogs in our LCR series.
Using publicly available information from the Environmental Protection Agency (EPA), EDF estimated that fully replacing the 9.3 million lead service lines (LSL) in 11,000 community water systems (CWS)[1] across the country would yield societal benefits of more than $205 billion, or about $22,000 per LSL removed. This estimate is based solely on reducing lead exposure in adults in order to have fewer cardiovascular disease (CVD) deaths over 35 years. It does not include the benefits to children’s brain development.
We submitted our analysis in comments to EPA on its proposed revisions to the Lead and Copper Rule (LCR), the federal regulation that limits lead in drinking water. Given the magnitude of the benefits, we called on the agency to incorporate CVD mortality into its economic analysis and consider strengthening its proposal by requiring full LSL replacement as an integral part of every CWS’s efforts, instead of as a last resort when lead levels get too high.
