EDF Health

EPA’s draft risk evaluation of carbon tetrachloride is riddled with unsupported exclusions and assumptions

By / Published: February 21, 2020

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.  Read More »

Also posted in Health policy, Health science, Regulation, TSCA reform, Worker safety / Tagged , , , | Comments are closed

The Trump EPA’s “Working Approach” to new chemical reviews is only working for the chemical industry

By / Published: February 20, 2020

Richard Denison, Ph.D., is a Lead Senior Scientist.

On Tuesday EDF filed detailed comments on the Environmental Protection Agency’s (EPA) “Working Approach to Making New Chemical Determinations under TSCA.”

The document is a major disappointment, to say the least.  The Trump EPA has worked very hard to render this long-awaited update of its approach to reviewing new chemicals under TSCA an empty exercise.  Despite Administrator Wheeler’s promises in January 2019 to the contrary:

  • EPA has still failed to provide any legal or scientific justification for its Working Approach.
  • EPA provided no actual response to the many detailed comments it received on its 2017 framework, instead issuing a 1.5-page document that dismisses many of the comments merely as having “stemmed from a misunderstanding of the Agency’s intent.”
  • EPA held a public meeting – but did so without first providing the Working Approach to stakeholders; EPA then limited their comments at the meeting to 2-3 minutes each and ended the meeting well ahead of schedule.
  • EPA’s new framework ignores the earlier comments it received, retaining all of the core flaws of the 2017 Framework and in fact doubling down on several of them.

Most remarkably, EPA seems to want to make clear that the Working Approach is hardly worth the paper on which it is written.  Read More »

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The Trump EPA reaches a shocking new low in failing to protect workers under TSCA

By / Published: January 30, 2020

Richard Denison, Ph.D., is a Lead Senior Scientist.

Just when I thought EPA putting workers’ health at risk by shirking its responsibilities under the Toxic Substances Control Act (TSCA) couldn’t get any worse, it has.[pullquote]The notion that worker protection can or should be relegated to the equivalent of a shock avoidance experiment is deeply offensive if not outright immoral.[/pullquote]

In its risk evaluations of existing chemicals (see our comments here and here) and its reviews of  new chemicals (see our comments here) entering the market, EPA has found ways bordering on the diabolical to avoid identifying or to understate the extent and nature of risks to workers making or using those chemicals.  The agency:

  • Simply assumes without evidence that workers will wear fully effective personal protective equipment (respirators and gloves).
  • Distorts OSHA regulations and claims they apply where they don’t.
  • Treats voluntary instruments that impose no binding requirements as if they were mandatory.
  • Assumes that if the average worker’s exposure does not exceed its acceptable risk level, then it doesn’t matter if there are exceedances for those workers most highly exposed.
  • Has unquestioningly accepted and used manufacturers’ undocumented data on workplace exposure levels even when data from more authoritative sources show far higher exposures.
  • And has adopted a cancer risk benchmark that is as much as two orders of magnitude more permissive of risk than warranted under TSCA.

All this despite TSCA’s express identification of workers as a “potentially exposed or susceptible subpopulation” that warrants special protection.

As appalling as all of this is, it just got worse. Read More »

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What connects cross country skiing and chemical safety?

By Sam Lovell / Published: January 27, 2020

Sam Lovell, Project Manager.

An idyllic afternoon gliding through fresh snow may seem as far removed as you can get from Washington, D.C. decision-making about toxic chemicals. However, as recently reported by Outside Magazine, there’s an intriguing connection here that ought to give skiers, and the rest of us, some pause.

Last year, the Environmental Protection Agency (EPA) approved a new chemical for use in ski wax. Just a few months before, the agency had planned to deny the chemical market entry based on the concern, among others, that exposure could “waterproof the lungs” – causing severe, acute harm. Due to the abrupt reversal in EPA’s decision, EDF began looking further into this case and made public records and Freedom of Information Act requests.

The intervening steps that resulted in this chemical getting the green light to market reveal serious problems in EPA’s new chemicals program regarding transparency and industry influence.

Read More »

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Finally something we can (mostly) commend EPA for doing under TSCA

By / Published: January 14, 2020

Richard Denison, Ph.D., is a Lead Senior Scientist.

Readers of this blog will know how concerned EDF is with ensuring the public’s right to know about chemicals to which they may be exposed.  We have repeatedly sounded the alarm when EPA has taken steps to deny public access to chemical information, whether for chemicals entering the market or those already in commerce.  Even in recent months, EPA has sided with chemical companies in denying access to health and safety information on chemicals EPA is assessing under the Toxic Substances Control Act (TSCA).

So we were pleasantly surprised by a letter to an industry group that EPA posted on Friday.  Read More »

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Top takeaways from The Intercept’s investigation into Trump’s toxic rollbacks

By EDF Blogs / Published: January 13, 2020

Regulatory decisions by federal agencies in Washington often feel distant – bureaucrats moving paper in ways that don’t matter to regular people. But a devastating new story by reporter Sharon Lerner of The Intercept makes clear just how awful the Trump administration’s actions on chemical safety have been for average Americans.

Lerner shows that the Trump EPA has repeatedly bowed to industry lobbyists to allow dangerous chemicals to stay on or enter the market with little or no restrictions.

EPA’s actions are not abstract bureaucratic events to Angela Ramirez, who was diagnosed with breast cancer after years of living and working “near two facilities that were emitting a cancer-causing chemical called ethylene oxide.” EPA scientists knew “that exposure to ethylene oxide caused elevated rates of tumors in the brain, lungs, uterus, and lymph systems” – but under the Trump administration, following pressure from an industry trade group, EPA decided not to follow its own science deciding whether to limit the chemical.

Lerner reports that the Trump administration, stacked with political appointees who have worked, lobbied or advocated for the chemical, tobacco, and coal industries, has been systematically undermining EPA’s ability to use the best science and get the best expert advice to protect families. They’ve been attacking programs like the Integrated Risk Information System, or IRIS, which provides evidenced-based analysis to the government to make public health decisions.

From Texas to Delaware and across the country, Lerner shows the impact of an administration that seems entirely focused on doing the bidding of industry, rather than pursing its legal mission to protect public health. They are doing so both broadly – weakening a new chemical safety law –and in a series of individual chemical assessment decisions. “Each time we see one of these assessments, there are ways in which the science has been played with,” EDF’s Lead Senior Scientist Richard Denison told Lerner.

To read more about what Lerner calls “Trump’s cancer gang” and their attacks on science and public health, check out her full article.

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