EDF Health

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 »

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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 »

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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 »

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