EDF Health

The many ways the American Chemistry Council wants to turn back time on TSCA implementation – Part 1

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: May 17, 2022

Part 1 of a 2-part series: Minimizing or ignoring chemical risks

Maria Doa, Ph.D., Senior Director, Chemicals Policy 

In its recently issued ‘State of TSCA’ report, the American Chemistry Council (ACC) tries to turn back the clock on how EPA assesses and mitigates the risks of toxic chemicals. The chemical industry group looks to return to the policies of the Trump years – a time rife with scientific integrity issues and wholesale disregard of risks – particularly those risks to frontline communities, workers and other vulnerable groups: the very groups the Toxic Substances Control Act (TSCA) calls out for special consideration.

This 2-part blog series looks at the six ways ACC hopes to turn back time on chemical safety and looks at the harms that would result if trade group’s self-serving ideas were to be adopted. Part 1 looks at the types of risks ACC wants EPA to exclude from its chemical risk evaluations, the workers and other groups whose health would be affected, as well as the trade group’s goal to have itself appointed as the arbitrator of EPA science. Part 2 looks at ACC’s efforts to dictate the process for assessing new chemicals and industry’s clear goal to avoid paying its fair share of the cost to evaluate the risks posed by some of the most dangerous chemicals already in the marketplace.  Read More »

Posted in Health policy, Health science, Industry influence, TSCA reform, Worker safety / Tagged , , | Comments are closed

EPA’s new Collaborative Research Program – A step toward improving new chemical reviews under TSCA

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: May 16, 2022

Maria Doa, Ph.D., Senior Director, Chemicals Policy; Lauren Ellis, MPH, Research Analyst; and Lariah Edwards, Ph.D., Post-Doctoral Fellow 

The Environmental Defense Fund (EDF) recently filed comments on EPA’s Toxic Substances Control Act (TSCA) Collaborative Research Program to Support New Chemical Reviews (Collaborative Research Program). The Collaborative Research Program is a multi-year scientific partnership between the agency’s Office of Pollution Prevention and Toxics (OPPT) and Office of Research and Development (ORD) aimed at modernizing the methods, approaches, and tools used to evaluate new chemicals under TSCA.  

We strongly support OPPT’s collaboration with ORD, which has a breadth of scientific expertise across EPA’s different research programs. As such, ORD will help OPPT implement the best available science in its new chemical assessments, which should ultimately prevent risky chemicals from entering the marketplace. We urge OPPT to use this opportunity – and ORD’s expertise – to improve and expand its consideration of new chemical impacts to frontline communities, the risks new chemicals may pose throughout their entire life cycle, as well as cumulative risks from chemicals that may cause similar health effects. 

Below we outline the five proposed research areas for new chemicals under the Collaborative Research Program and our comments on each. All five can have an important impact on EPA’s new chemical assessments and consequently on EPA’s determination on whether a new chemical is expected to present an unreasonable risk.  Read More »

Posted in New approach methods (NAMs), TSCA reform / Tagged , , | Authors: / Comments are closed

EPA to release assessment of toxic formaldehyde, rejects industry’s tired delay tactics

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: April 13, 2022

Maria Doa, Ph.D., Senior Director, Chemicals Policy 

The EPA will release a draft Integrated Risk Information System (IRIS) assessment of formaldehyde, a key scientific review that identifies and characterizes the hazards from chronic exposure to this known carcinogen. The draft assessment, due to be published tomorrow, will be reviewed by the National Academies of Science, Engineering and Medicine (National Academies).

We welcome the EPA’s decision to issue its formaldehyde assessment. Release of the assessment is a win for scientific integrity that follows years of pressure from industry groups and efforts during the previous administration to suppress the assessment. 

The EPA’s IRIS program is the gold standard for identifying and characterizing the hazards that result from exposure to chemicals. Its findings are essential to informing health-based standards that protect frontline communities, workers, children, consumers and more.   Read More »

Posted in Health policy, Health science, Industry influence, Public health / Tagged , , , | Comments are closed

EDF outlines steps for EPA to strengthen its plan to assess risks to frontline communities

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: March 24, 2022

Maria Doa, Senior Director, Chemicals Policy

This week Environmental Defense Fund (EDF) filed comments on EPA’s plan to assess the risks to frontline communities from nearby releases of chemicals to the air and water. The EPA’s proposal is an improvement from the previous administration, which failed to follow the requirements of the Toxic Substances Control Act (TSCA) and consider air and water releases and other significant exposure pathways for residents in “fenceline” communities near manufacturing or disposal facilities.

As we made clear in our comments, however, the agency’s planned screening approach is too narrow in scope and would underestimate the real-world risks faced by many communities.

Residents of these frontline communities often face exposure from multiple sources or higher levels of exposure than the general population, or both combined. Failing to consider the full scope of these risks could hamper EPA’s ability to craft protective rules that reduce the risks those living near industrial facilities.

We outline several areas where EPA can strengthen its screening approach Read More »

Posted in Air pollution, Public health / Tagged , , , , , | Comments are closed

EPA can incorporate cumulative impacts in its chemical assessments right now

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: March 8, 2022

By Maria Doa, Senior Director, Chemicals Policy, and Lariah Edwards, Ph.D., EDF-George Washington University Postdoctoral Fellow

EPA recently asked its Science Advisory Board to provide advice on how it can incorporate cumulative impact assessments into its decisions making and on research to support cumulative impact assessments. At a public meeting of the SAB on March 2, we highlighted several areas where EPA can incorporate cumulative impact assessments right now.

Cumulative impacts refer to the total burden from chemical and non-chemical stressors and their effect on health, well-being, and quality of life. EPA asked the SAB for advice in two areas: First, what research should the agency conduct to strengthen the methods used in cumulative impact assessments. Second, and somewhat more important, how can EPA start now to incorporate cumulative impact assessments into its decision-making using data that is currently available.

People living in communities are often exposed to multiple chemical and non-chemical stressors. When individuals are exposed to multiple chemicals that cause a particular type of harm, they do not experience the risks for each chemical separately from the other. Nor are these chemical burdens experienced in isolation from other non-chemical stressors a person may face, like nutritional deficiencies or psychosocial stress. Cumulative impact assessments consider the combination and impact of both types of stressors, and therefore are more reflective of real-life conditions.

EPA assessments and decision making should take into consideration this reality and move away as much as possible from the status quo of evaluating one source, one chemical, and one environmental medium. Read More »

Posted in Health science / Tagged , , , | Comments are closed

Understanding PFAS: Why a broad, transparent PFAS Testing Strategy is needed

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: March 2, 2022

Maria Doa, Senior Director, Chemicals Policy; Lauren Ellis, Research Analyst; and Lariah Edwards, Post-Doctoral Fellow

EDF this week sent EPA a letter identifying opportunities for the agency to improve the effectiveness and transparency of its strategy for testing per- and polyfluoroalkyl substances (PFAS).

EPA unveiled its National PFAS Testing Strategy (Testing Strategy) last fall, laying out its plan to better understand the class of chemicals and inform its future regulatory efforts. PFAS are a large group of synthetic chemicals used to impart water, oil, grease, and stain resistance to various materials, and they are used in hundreds of everyday products, from water-proof clothing to grease-proof food packaging. By its own count, EPA says there are more than 12,000 individual PFAS.

In their letter to EPA, EDF analyst Lauren Ellis and post-doctoral fellow Lariah Edwards commended the agency for developing a strategy to address some of the significant data gaps that exist around PFAS and committing to use its authority under the Toxic Substances Control Act (TSCA) ‒ the country’s main chemical safety law ‒ to require manufacturers to provide toxicity data on the chemicals.

As the letter points out, however, in its current state, the Testing Strategy lacks sufficient detail and is too narrow to fulfill the agency’s intended purpose to understand and regulate PFAS in a way that is protective of both human health and the environment. Read More »

Posted in Health science, PFAS / Tagged , | Comments are closed