EDF Health

EPA Takes Important Step to Ban Chrysotile Asbestos

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

EPA has made the important and long-awaited decision to propose banning nearly all remaining uses of chrysotile asbestos in the United States. EDF submitted comments supporting this proposed ban (with some caveats) because of the high risk of cancer and fatal respiratory diseases for individuals who import, process, distribute, and use chrysotile asbestos. The rule could be significantly improved by requiring a more immediate ban. If EPA chooses a more extended phase-in of the ban, we recommend that the Agency require companies to reduce workplace exposures in the interim to better protect workers.

Summary of Key EDF Concerns and Comments

Although asbestos is a known carcinogen, it is still used in automobile brake linings, gaskets, and brake blocks, as well as in permeable separators (diaphragms) at chlor-alkali facilities to produce chlorine and caustic soda. Currently, nearly 40,000 Americans die each year from asbestos-related illnesses. These deaths are preventable and must be stopped, and we applaud EPA for taking this step toward doing so.

  • EDF supports rapid implementation of EPA’s proposed chrysotile asbestos ban. Given the unreasonable risk posed by asbestos, we call on EPA to start the ban for all uses within 6 months after publishing the finalized rule.
  • In the event EPA chooses an extended phase-in (>6 months) of the ban on using chrysotile asbestos in chlor-alkali diaphragms and sheet gaskets, it should require companies to reduce workplace exposures during the interim in a way that poses the least risk to potentially exposed populations—particularly workers. In this case, we call on EPA to require hazard communication and the hierarchy of controls—first by reducing exposure through process, engineering, or administrative changes. Personal protective equipment (PPE) as a risk-reduction measure should be used only after applying these other controls to reduce chemical exposures. However, this approach would be less effective and more burdensome on workers than eliminating exposure completely and should be used only as a short-term, interim measure until the ban goes into effect.
  • EPA should explain how its proposed disposal requirements address the unreasonable risk presented by chrysotile asbestos. EDF is concerned that EPA has not demonstrated how compliance with OSHA’s Asbestos General Industry Standard and EPA’s National Emission Standards for Hazardous Air Pollutants would eliminate unreasonable risk, as TSCA requires.
  • EPA underestimates the benefits of preventing health impacts by banning chrysotile asbestos. In baseline exposure calculations, the Agency inappropriately assumes that workers will consistently and correctly use PPE while handling chrysotile asbestos and dramatically underestimates how many individuals will benefit from the rule. EPA should bolster its Economic Analysis in the final rule to more accurately reflect the benefits of the ban.

In addition, the proposed rule indicates EPA is continuing to include troubling policy decisions in its risk evaluations. Moving forward:

  • EPA should not consider costs or other non-risk factors in risk evaluations. EPA states it will consider use of PPE and other risk-management activities in its risk evaluations to help in making risk-management decisions—an approach that is not scientifically supportable and inappropriately conflates risk assessment with risk management.
  • EPA should not inappropriately treat workers differently from the general population by applying a less-protective cancer benchmark for workers. TSCA does not support this approach. Given that workers are particularly identified in TSCA for consideration and often face higher risks than the general population, making a less-protective standard is especially unjustified. (See our June 21, 2022 blog post on this issue.)

EDF also found many areas of agreement with EPA in the proposed risk-management rule. You can read the full set of comments here.

 

 

Also posted in Regulation / Tagged , | Comments are closed

Companies are not withdrawing PFAS exemptions on their own; EPA should

Samantha Liskow, Lead Counsel, Healthy Communities; and Lauren Ellis, Research Analyst, Environmental Health

EPA has committed to address the urgent issues presented by PFAS, a harmful class of human-made chemicals that are used widely in everyday products. Last July, as part of this effort, EPA called on companies to voluntarily withdraw some 600 PFAS that were previously allowed onto the market through a fast-track exemption process known as a “low volume exemption” (LVE).

Nearly a year later, however, less than 3% of these low volume per- and polyfluoroalkyl substances (PFAS) have been pulled from the market. That means manufacturers in the U.S. could still be making PFAS that never went through a full safety review – possibly millions of pounds each year. Read More »

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The many ways the American Chemistry Council wants to turn back time on TSCA implementation – Part 2

Part 2 of a 2-part series: Unrestricted approvals of new chemicals, with low fees 

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 under the Toxic Substances Control Act (TSCA) and in the process leave workers, frontline communities and other vulnerable individuals at risk.  

In my previous blog, I looked at how ACC’s proposals would restrict the EPA’s ability to assess chemical risks and the science behind it. In this second and final part of our blog series looking at the chemical industry trade group’s report, I discuss ACC’s plan to dictate how EPA should assess the safety of new chemicals industry hopes to bring to the marketplace, as well as its effort to let industry avoid paying its fair share of the cost for EPA to evaluate chemical risks.  Read More »

Also posted in Health Policy, Industry Influence, Public Health, TSCA Reform / Tagged , , , | Read 3 Responses

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

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 »

Also 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

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 »

Also posted in TSCA Reform / Tagged | Comments are closed

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

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 »

Also posted in Health Policy, Health Science, Industry Influence, Public Health / Tagged , , | Comments are closed