EDF Health

Cumulative assessment better estimates the real-world risks chemicals pose on our health

By Paige Varner, PhD, Scientist, Healthy Communities / Published: August 13, 2024
NOTE: This is the second of a series about EPA’s prioritization of existing chemicals. 

What Happened? 

EPA just proposed to designate five chemicals, including the widely-known toxic chemical vinyl chloride, as high-priority chemicals – meaning they are toxic to human and/or environmental health.  If finalized, these chemicals will immediately undergo the risk evaluation process under the Toxic Substances Control Act (TSCA).  

When designating these chemicals as high priority and moving forward in assessing their health risks, EPA can – and should – consider exposures to multiple chemicals that can cause the same health harms. To demonstrate the importance of these cumulative exposures, we conducted analysis on co-exposures to these five chemicals and submitted this analysis to EPA for greater consideration of real-world risks faced by individuals exposed to these toxic chemicals.  

Why It Matters 

Communities near industrial facilities are often exposed to multiple chemicals that cause the same health effects. Evaluating the health risk of these chemicals individually, as currently done by EPA’s TSCA program, often underestimates the true risks communities face. Additionally, many of these fenceline communities experience a variety of non-chemical stressors that exacerbate health effects from chemical exposure, such as physiological stress from poverty and racial discrimination, limited access to healthcare, or health effects from climate stressors like flooding and heat. Failing to consider these cumulative stressors on health in chemical risk evaluations often underestimates the actual risks these chemicals can pose to human health.  

Our Take 

Our analysis of Toxics Release Inventory (TRI) data from 2016-2021 shows that many chemicals that cause the same health effects – such as cancer, central nervous system (neurological), cardiorespiratory, liver, kidney, and thyroid, and reproductive and developmental effects – are often released together from the same facilities. For example, chemicals that cause cardiorespiratory effects are released with at least one other chemical that causes these same effects 74% of the time.  

For the five chemicals that have just been proposed as high priority under TSCA, all are known or probable carcinogens with some causing other adverse health effects. Based on our analysis, there are a few notable co-releases that EPA should consider when assessing cumulative risk with other chemicals causing the same harms. For example, creosotes, which are also probable carcinogens that can cause liver, kidney, and thyroid effects, are released 11% of the time with acrylonitrile, 18% with aniline, 11% with vinyl chloride, and 11% with 4,4-methylene bis(2-chloroaniline). 

Screenshot - Heatmap of co-releases of carcinogenic chemicals that are part of the TSCA Workplan.

Heatmap of co-releases of carcinogenic chemicals that are part of the TSCA Workplan. Legend represents the percentage of facilities releasing both chemicals out of the facilities releasing at least one of the pair of chemicals. Stars represent the 15 chemicals that were considered as part of TSCA’s pre-prioritization.

To demonstrate that EPA should also consider non-chemical stressors such as climate and environmental justice in its TSCA prioritization and risk evaluations, we looked at the vulnerability of communities to climate and environmental justice factors in areas where certain chemicals are released using EDF’s Climate Vulnerability Index. On average, vinyl chloride is released into communities with higher vulnerability than other chemicals analyzed – up to 12% higher than the average for other carcinogenic chemicals.  

What’s Next? 

EPA is now accepting comments on their proposal to designate these five chemicals as high priority, and we plan to submit comments to support the high priority designation. If finalized, EPA will begin risk evaluations for these chemicals. We hope EPA will consider cumulative risk and environmental justice as it moves through this process.   

In our next post in this series, we will recommend ways EPA can improve its prioritization process by considering risks from transportation and distribution of chemicals. 

Also posted in Adverse health effects, Chemical regulation, Cumulative impact, Cumulative risk assessment, Environmental justice, Health policy, Public health, Regulation, Risk assessment, Risk evaluation, Rules/Regulations, TSCA, TSCA reform, Vulnerable populations / Authors: / Comments are closed

First things first: vinyl chloride data updates and our case for stronger evaluations

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: June 25, 2024
NOTE: This is the first of a series about EPA’s prioritization of existing chemicals. 

 What Happened? 

EPA recently announced it had initiated the prioritization process for five chemicals for upcoming risk evaluation.  One of the chemicals, vinyl chloride, is a highly toxic chemical known to cause liver toxicity and liver cancer in humans. The other four chemicals are also carcinogens and cause other toxic effects such as harms to pregnant women and infants.  

We have added these five chemicals to our Chemical Exposure Action Map. Our map shows releases of TSCA high priority chemicals, focusing on three major categories of health harms from cumulative exposure to these chemicals: cancer, developmental harm, and asthma.  U.S. map showing chemical facilities across the nationWhy It Matters 

Prioritizing a chemical as high priority is a key step in the process of evaluating and managing its unreasonable risks under TSCA.  The factors and data that EPA considers when prioritizing chemicals affects whether EPA designates a chemical as a high priority and how effectively the Agency will be able to assess its risks, especially to more highly exposed individuals and those more susceptible to the chemicals, like fenceline communities. 

We support the designation of these five chemicals, particularly vinyl chloride, as high-priority chemicals for evaluation.  However, as we explain in our recent comments, EPA can improve its prioritization process to consider the more real-world risks faced by people who are more highly impacted by these toxic chemicals.   

 Our Take 

EPA can improve its prioritization in two important ways.  

First, EPA should systematically prioritize chemicals released or used together that cause the same toxic harms.  Considering the cumulative risk posed by chemicals that cause the same harm provides a more complete and real-world picture of the risks fenceline communities face because exposure to multiple chemicals causing the same or similar health harms increases the risk of serious health problems.  

 Second, in prioritizing chemicals and evaluating the risks from these chemicals, EPA should consider exposures from accidental releases, including transportation accidents such as from the East Palestine, Ohio train derailment.  In the past, EPA has generally not considered these exposures despite the significant contributions they can have to the chemical’s risk. 

EPA has a major opportunity to improve its prioritization and evaluation processes so that it can develop a fuller picture of the risks posed by toxic chemicals. This would provide the Agency with the basis to develop regulations that will more fully protect human health and the environment, including for those people at greatest potential risk, like fenceline communities.  

What’s Next? 

EPA is now in the process of determining whether vinyl chloride and the other four chemicals the Agency is assessing should be designated as high priority chemicals.  If they are designated as high priority, EPA will begin risk evaluations for these chemicals.   

In our next post, we will recommend ways EPA can improve its prioritization process by incorporating cumulative risk analyses and considerations. 

Also posted in Cumulative risk assessment, Risk evaluation / Authors: / Comments are closed

Unveiling EDF’s Chemical Exposure Action Map

By Maria Doa, PhD, Senior Director, Chemicals Policy and Paige Varner, PhD, Scientist, Healthy Communities / Published: February 22, 2024

U.S. map showing chemical facilities across the nationWhat’s New

Today, we are excited to introduce the Environmental Defense Fund’s (EDF) latest initiative—the Chemical Exposure Action Map. This tool is designed to spur the Environmental Protection Agency (EPA) to transform the assessment of risks posed by toxic chemicals in our communities.

Our map focuses on multiple high-priority chemicals—making visible the urgent and long-overdue need to assess the risks of chemicals together as they exist in the real-world. Unlike many current methods that look at risks one chemical at a time, our map offers a comprehensive view, highlighting the potential for cumulative risks from multiple high-priority chemicals.

Why It Matters

In a world where industrial facilities expose communities to multiple harmful chemicals daily, many have long called for a cumulative approach to assessing the risks from these chemicals. It is crucial that we wait no longer to reassess how we evaluate the health risks they pose.

Pregnant Latine woman gazing lovingly at young daughter who is hugging her belly.

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Also posted in Adverse health effects, Carcinogenic, Chemical regulation, Cumulative impact, Cumulative risk assessment, Developmental toxicity, Health hazards, Health policy, Public health, Regulation, Risk assessment, Risk evaluation, TSCA, Vulnerable populations / Tagged , , , , , , | Authors: , / Comments are closed

Why are four notorious carcinogens approved by FDA for food?

By EDF Blogs / Published: February 1, 2024

By Liora Fiksel, Project Manager, Healthy Communities, and Lisa Lefferts, Environmental Health Consultant

Pregnant woman rests a cup of coffee on her belly.

While exposure data are scant, people who are choosing decaf coffee during pregnancy or for other health reasons may not realize that some popular brands contain methylene chloride.

What’s Happening?

On December 21, 2023, FDA filed a food-additive petition and a color-additive petition submitted by EDF and partners that asks FDA to revoke its approval for four carcinogenic chemicals approved for use in food.

There is broad agreement that benzene, trichloroethylene (TCE), methylene chloride, and ethylene dichloride are carcinogenic,1 and federal law2 is clear: additives that cause cancer in humans or animals are not considered “safe.” All the chemicals have been identified as causing cancer in humans or animals since the 1970s and 1980s.3 Read More »

Also posted in Adverse health effects, Carcinogenic, Chemical regulation, FDA, Food, Health hazards, Public health, Vulnerable populations / Tagged , , , , , , | Authors: / Read 9 Responses

EPA’s TCE ban: A vital step for public health

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: November 17, 2023

We only have until December 15, 2023, to show EPA we support
a full and rapid ban of all uses of TCE.

Take Action: Tell EPA–Ban TCE Now

What Happened?

The Environmental Protection Agency (EPA) has recently taken a significant step in safeguarding public health by proposing new regulations under our nation’s primary chemicals law, the Toxic Substances Control Act (TSCA) that would protect people from exposure to trichloroethylene (TCE), a highly toxic chemical that causes serious health risks. The proposed rule would ban the production, import, processing, and distribution in commerce for all uses of TCE.

Yet, despite the known dangers of TCE and the undeniable scientific evidence supporting the need for this action, the chemical industry is trying to undermine this critical regulation by incorrectly claiming the proposed rule is “inconsistent with the science.” Read More »

Also posted in Adverse health effects, Chemical regulation, Developmental toxicity, Health hazards, Industry influence, Neurotoxicity, Public health, Reproductive toxicity, Rules/Regulations, TSCA / Tagged , , | Authors: / Read 1 Response

Unleaded Food: FDA acts quickly on contaminated applesauce

By Liora Fiksel, Project Manager, Healthy Communities and Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 17, 2023

What’s Happening?

The North Carolina Departments of Health & Human Services and Agriculture & Consumer Services identified WanaBana cinnamon applesauce pouches as a source for elevated blood lead levels in multiple children. They found extraordinarily high concentrations of lead (1,900- 5,100 ppb) in the products, leading to the identification of at least 34 cases of elevated blood lead levels across 22 states to date.

On October 28, 2023, FDA issued a safety alert advising that “parents and caregivers of toddlers and young children who may have consumed WanaBana apple cinnamon fruit puree pouches should contact their child’s healthcare provider about getting a blood test.” Three days later, the company issued a voluntary recall.

As the recall expanded, FDA transferred the investigation to its Coordinated Outbreak Response & Evaluation (CORE) Network to determine the source of lead contamination and whether additional products are linked to illnesses.

Brands under a voluntary recall. Photo credit: FDA

Brands under a voluntary recall. Photo credit: FDA

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Also posted in FDA, Food, Health hazards, Public health / Tagged , , , | Authors: , / Read 1 Response