EDF Health

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

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 exposure, Chemical regulation, Cumulative impact, Cumulative risk assessment, Environmental justice, Public health, Regulation, Risk assessment, Risk evaluation, Rules/Regulations, TSCA, TSCA reform, Vulnerable populations / Authors: / Comments are closed

Unveiling EDF’s Chemical Exposure Action Map

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 exposure, Chemical regulation, Cumulative impact, Cumulative risk assessment, Developmental toxicity, Health hazards, Public health, Regulation, Risk assessment, Risk evaluation, TSCA, Vulnerable populations / Tagged , , , , , , | Authors: , / Comments are closed

ICYMI: Secret GRAS determinations may outnumber those FDA reviews

Quote from FDA Commissioner Robert Califf, MD. "I want to throw in chemical safety as another really, really important area for the future—for humankind, really—and where science is evolving rapidly."

NOTE: This blog was originally published on our Deep Dives blog on April 13, 2023. It predates the recent reorganization efforts at FDA.

What Happened?

FDA estimates that, each year, food companies designate 82 new food chemicals as “GRAS” (Generally Recognized as Safe) for use in food. On average, FDA reviews only 64 of those new chemicals for safety. For the remaining 18 chemicals in FDA’s estimate, the companies making and marketing them for use in food or in the food-production process choose not to seek a voluntary review by FDA.

In comments to the agency, we said we think FDA’s estimate may be too low – and the number of new chemicals added to food that bypass FDA review may be as high as 130 new food chemicals a year (significantly higher than 18). This is based on searches of company marketing claims. In an 8-week period, we identified 10 chemicals claimed as GRAS without a submitted notice to FDA seeking voluntary review. (Please see our comments for a full explanation of our estimate.) Read More »

Also posted in Broken GRAS, Chemical regulation, FDA, Food, GRAS, Industry influence, Public health, Regulation / Tagged , , | Authors: , / Comments are closed

EPA’s new chemical regulations: Backtracking on PBTs

NOTE: This is the fifth in a series about EPA’s regulation of new chemicals. See below under Go Deeper for links to the other blogs in the series.

What Happened?

The Environmental Protection Agency (EPA) recently proposed new regulations for its safety reviews of new chemicals under our nation’s primary chemicals law, the Toxic Substances Control Act (TSCA). One of the proposed provisions would govern which persistent, bioaccumulative,1 toxic chemicals (PBTs) should undergo a full safety review.

Why It Matters

This proposed approach would exclude certain PBTs from a full new chemical safety review. This is a concerning step backward in addressing the risks from these chemicals.

PBT chemicals do not break down readily from natural processes and raise special concern because of their ability to build up in both the environment and in people and other organisms. Even small releases of these long-lived and bioaccumulative toxic chemicals can pose long-term risks to human health and the environment. Notable PBTs—such as DDT, which affects reproduction, and methyl mercury, which is a powerful neurotoxin—impacted whole ecosystems across the United States, including the Great Lakes.

View of Lake Michigan

View of Lake Michigan Photo credit: Maria Doa

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Also posted in Adverse health effects, Chemical exposure, Chemical regulation, Health hazards, Neurotoxicity, PBTs, Regulation, Risk assessment, Rules/Regulations, TSCA / Tagged , , , , , | Authors: / Comments are closed

California mandates toxics testing/disclosure for baby food

Tom Neltner, Senior Director, Safer Chemicals and Katelyn Roedner Sutter, State Director, California

Three jars of baby food surrounded by cut-up vegetables and fruit

What Happened?

On October 10, 2023, California Assembly Bill 899, authored by Assembly Member Al Muratsuchi, became law. It requires manufacturers of baby food (other than infant formula) who wish to sell their products in California to:

  • Test a representative sample of each baby food product for four toxic elements (arsenic, cadmium, lead, and mercury) at least monthly starting in 2024.
  • Provide the test results to the California Department of Health upon request.
  • Make the results of the testing publicly available on the manufacturer’s website for the shelf life of the product plus one month. That provision goes into effect in 2025.

In addition, as FDA establishes action levels for the four toxic elements, manufacturers must also include a quick response (QR) code on the label that links to the manufacturer’s website, where consumers can find the test results for that toxic element.

Why It Matters

By requiring testing and reporting on these foods, California will provide parents and guardians with important information they need to compare products and make purchasing decisions. The law also:

  • Sets a precedent for greater testing and disclosure of food contaminants; and,
  • Is noteworthy, in that baby food companies did not oppose the bill.

The law will strengthen FDA’s efforts to reduce children’s dietary exposure to those toxic elements to the lowest possible levels, while maintaining access to nutritious foods by filling two critical gaps in FDA’s Closer to Zero program. FDA current approach sets action levels on final products that food companies must meet and requires they use preventive controls to manage toxic elements in their ingredients. It does not require final product testing or disclosure of any testing results.

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Also posted in FDA, Food, Markets and Retail / Tagged , , , , , | Authors: / Comments are closed

Now’s the Time—How EPA can use TSCA to turn off the PFAS tap

Faucet with the word PFAS flowing out of it

In the face of mounting evidence about the dangers posed by per- and polyfluoroalkyl substances (PFAS), one thing is clear: EPA needs to take urgent action to turn off the tap of these “forever chemicals” that have long-term consequences for our health and the environment.

As we discussed in a previous blog, it is imperative that the Environmental Protection Agency (EPA) use the Toxic Substances Control Act (TSCA) to regulate PFAS chemicals comprehensively—both those newly entering the market and those that have been in circulation for decades.

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Also posted in Chemical exposure, Chemical regulation, Cumulative impact, Cumulative risk assessment, Drinking water, Emerging science, PFAS, Public health, Regulation, Risk assessment, Risk evaluation, TSCA, TSCA reform, Vulnerable populations, Worker safety / Tagged , , | Authors: / Read 2 Responses