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Tom Neltner, J.D., is Chemicals Policy Director
On January 19, the Environmental Protection Agency (EPA) released a major new draft report proposing three different approaches to setting health-based benchmarks for lead in drinking water. We applauded EPA’s action and explored the implications for drinking water in a previous blog. One of the agency’s approaches provides useful, and surprising, insights into where the lead that undermines the health of our children comes from. Knowing the sources enables regulators and stakeholders to set science-based priorities to reduce exposures and the estimated $50 billion that lead costs society each year.
The EPA draft report is available for public comments until March 6, 2017, and it is undergoing external peer-review by experts in the field in support of the agency’s planned revisions to its Lead and Copper Rule (LCR) for drinking water. Following this public peer-review process, EPA expects to evaluate and determine what specific role or roles a health-based value may play in the revised LCR. With the understanding that some of the content may change, here are my takeaways from the draft:
For a visual look at the data, we extracted two charts from the draft EPA report (page 81) that show the relative contribution of the four sources of lead for infants (0-6 month-olds) and toddlers (1 to <2 year-olds) considered by the agency. The charts represent national exposure distributions and not specific geographical areas or age of housing.
[Edited on 17 February 2017. Click here to subscribe via iTunes or Google Play]
Today we are launching the second episode of our podcast, You Make Me Sick! On this episode, we talked with Dr. Brett Finlay, author of “Let Them Eat Dirt”, about the fascinating world of microbes.
Dr. Finlay’s research focuses on how bacteria and other tiny microorganisms living in and on us might not be all bad. We caught up with him in New York City to learn about fecal transplants and asthma, and to get some new evidence in the never-ending dogs vs. cats debate. Click below to listen.
[EPISODE 1 – Impact of lead on the developing brain]
Working at EDF’s Health Program, we learn new and fascinating things about the science of environmental health every day. We decided these stories of how chemicals can affect our health are too interesting and important to keep to ourselves. In order to bring you the latest and greatest in scientific research around environmental health, EDF Health is proud to present our new podcast, You Make Me Sick, hosted by yours truly and Dr. Jennifer McPartland.
Over the next few months, this podcast, which will be released every few weeks, will bring you the latest research from experts in the field of environmental health. We will be sitting down with them to discuss where the science has been, is, and will be.
Our first interview was with Dr. Bruce Lanphear, a professor at Simon Fraser University with expertise in children’s environmental health. His research ranges from childhood exposures to pesticides, mercury, tobacco smoke and other chemicals of concern. In this episode, we sat down with him in the EDF Washington office to learn specifically about how lead exposure affects children.
Click below to listen. While you’re at it, make sure to subscribe to us via iTunes or Google Play!
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Tom Neltner, J.D., is Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant
On January 9, we described a new Food and Drug Administration (FDA) report showing that perchlorate exposure to infants and toddlers increased 34% and 23% respectively between the years around 2005 and 2010. Young children were the most exposed age groups. FDA compared the exposure to a “safe dose” established in 2005 and saw no cause for concern. We respectfully disagree and find the levels alarming. First, we now know that the 2005 “safe dose” is no longer sufficient to protect children’s brains from the irreversible harm that can result from even transient exposures to perchlorate. Second, many young children may be over the “safe dose.” (more…)
Sarah Vogel, Ph.D., is Vice-President for Health.
Last week a new study was published showing promising results for a non-estrogenic alternative to polymers based on bisphenol A (BPA) used to line the inside of food cans. The paper, in Environmental Science & Technology (ES&T), evaluated the estrogenicity of an alternative to BPA— tetramethyl bisphenol F (TMBPF) — and its final polymer product developed by Valspar, a major paint and resin company. The authors found that, unlike BPA and some of its analogs that have been used as substitutes, TMBPF exhibited no signs of estrogenicity.
This was an unusual paper on a number of fronts—how the material was selected, how it was evaluated and by whom. In this post I’m going to explore who was involved, what testing was done and what this might mean for the BPA alternatives market.
Tom Neltner, J.D., is Chemicals Policy Director
In 2016, California became the first state in the country to make enforceable commitments to eliminating all lead service lines (LSLs) in the state. These lead pipes that connect the main under the street to homes are the primary source of lead in drinking water and unpredictably release lead particulate when disturbed. Under the leadership of Senator Connie Leyva, the state’s Senate voted unanimously, and the Assembly voted 72 to 7 to pass SB1398 to require drinking water utilities to inventory LSLs in use and then provide the State Water Resources Control Board (Water Board) a timeline for replacement of the lines.
Based on a national survey of utilities, the American Water Works Association reported that California has 65,000 LSLs out of 6.1 million nationally. Large utilities have the most with 46,000 LSLs, medium systems have 4,700 and small systems have 15,000. However, most utilities do not have an accurate inventory of LSLs, so the true number may be much greater.
California’s SB1398 recognized that an accurate inventory was critical and laid out a thoughtful two-step plan to accomplish the objective of full LSL replacement. By July 1, 2018, it requires public water systems (PWS) to submit an inventory of known LSLs and a timeline for their replacement. Two years later, PWSs must submit an updated inventory of LSLs and provide a timeline to replace any service line where it may be made of lead. The law does not set a deadline for replacement that PWSs must meet.
This two-step approach makes replacing known LSLs the highest priority and, by essentially presuming that a service line is lead unless known otherwise, also creates an incentive for PWSs to develop accurate inventories in the next three years.
Richard Denison, Ph.D., is a Lead Senior Scientist.
The Environmental Protection Agency (EPA) is publishing a notice in tomorrow’s Federal Register affirming that the Lautenberg Act requires upfront substantiation of all confidential business information (CBI) claims submitted under the Toxic Substances Control Act (TSCA), except for certain claims that the law exempts from substantiation requirements.
While EPA initially took a narrower approach on an interim basis in the flurry of activity following last June’s passage of the Lautenberg Act, today’s notice supersedes that earlier approach and clarifies the upfront substantiation requirement.
In today’s notice, EPA notes the strong support for its clarification in the statute itself as well as in the legislative history in both Houses of Congress leading up to its final passage.
This clarification hopefully won’t be controversial: A broad swath of stakeholders have voiced support for the upfront substantiation requirement and have noted that it is a key reform made by the new law.
In November the American Alliance for Innovation (AAI) sent a letter to EPA Administrator McCarthy signed by more than 60 trade associations – including the American Chemistry Council, the Society of Chemical Manufacturers and Affiliates, the American Cleaning Institute, the American Petroleum Institute and the Consumer Specialty Products Association – noting that under the Lautenberg Act “[c]laims for CBI protection must be accompanied by an upfront substantiation.”
And back in 2013, the American Chemistry Council provided responses to questions for the record posed by then-Congressman Henry Waxman that stated that “[i]mprovements to the CBI provisions in a modernized TSCA should include … [r]equiring upfront substantiation of the CBI claim.” The same response letter noted that: “The American Chemistry Council and its members support up-front substantiation of CBI claims.”
Importantly, EPA’s notice makes clear that the substantiation requirement applies to all non-exempt CBI claims made since passage of the law last June, although EPA is providing an exceedingly generous length of time for companies to comply.
Given the law’s 90-day deadline for EPA review of CBI claims, there are strong policy reasons for requiring upfront substantiation of CBI claims:
