EDF Health

EPA can incorporate cumulative impacts in its chemical assessments right now

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

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 »

Also posted in Health Science, PFAS / Tagged , | Comments are closed

In latest act of leadership, Cincinnati votes to cover the cost of replacing lead pipes for all residents

Tom Neltner, Chemicals Policy Director

The Cincinnati City Council has voted unanimously to authorize Greater Cincinnati Water Works (GCWW) to pay 100% of the cost of replacing private lead service lines (LSLs) that bring drinking water to customers’ homes and other buildings. The Council’s December vote supports its larger strategy to “provide quality healthy housing for all income levels.” More broadly, the action is the latest act of leadership from the city as it works to address the environmental justice issues in its communities.

The ordinance gives GCWW the authority to help more customers pay to fully replace LSLs as the utility conducts infrastructure work on drinking water mains that connect to the lead pipes. Since 2017, the utility has subsidized up to 40% of a customer’s replacement cost through grants, and allowed customers to take a 10-year, interest-free loan.

Despite these incentives, the utility recognized that the cost of replacement was an obstacle for many customers, especially for low-income residents. About 60% of customers declined to participate, leaving them with partial LSL replacements that left lead pipes on private property in place. These partial replacements create higher short-term spikes in lead levels in drinking water and do not reliably reduce the risk of lead exposure over the long-term, as full replacement does. This is an important step for Cincinnati, as it ends LSL replacement practices that force customers to share in the costs that can lead to environmental justice and civil rights issues. Read More »

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Civil rights complaint draws attention to the discriminatory impacts of common lead pipe replacement practice

Jennifer Ortega, Research Analyst, Environmental Health

This past Wednesday, Rhode Island’s Childhood Lead Action Project (CLAP) led a coalition of groups in submitting a civil rights complaint to the Environmental Protection Agency (EPA) against the Providence Water Supply Board (Providence Water), pursuant to the Civil Rights Act of 1964.

The administrative complaint highlights the discriminatory effects that can result when utilities require customers to share the cost of replacing the lead pipes that feed into their homes. The complaint was submitted as part of CLAP’s larger Lead-Free Water RI campaign, which calls “for an equitable, statewide plan for full, free lead pipe replacements for all Rhode Islanders.”

In the complaint, CLAP, South Providence Neighborhood Association, Direct Action for Rights and Equality, National Center for Healthy Housing, and EDF allege that the water utility’s process of replacing lead service lines (LSLs) — the lead pipes that run from the water main to the water meter in homes — has a disparate impact on Black, Latinx, and Native American residents in violation of Title VI of the Civil Rights Act of 1964 and EPA’s implementing regulations. Read More »

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EPA’s Significant New Use Rules under TSCA must reflect its policy goals

Lauren Ellis, Research Analyst, Environmental Health 

We recently submitted comments to the Environmental Protection Agency (EPA) on a subset of proposed Significant New Use Rules (SNURs) published by the New Chemicals program under the Toxic Substances Control Act (TSCA). We commend EPA for issuing these proposed SNURs. Our review of some of the SNURs, however, raised concerns about chemical releases to the environment, risks to consumers, and the absence of worker protections. We believe EPA can address many of these concerns by following through on its stated policy goals. 

For all the chemicals in this batch, EPA had previously issued “consent orders” – which impose restrictions on a new chemical – because the agency found at the time of their initial review for market entry that the chemical substances may present an unreasonable risk to health or the environment. We strongly support EPA’s use of SNURs to follow up on consent orders it issues, as a consent order only applies to the original company that submitted a premanufacture notice (PMN) to EPA to domestically manufacture or import a new chemical. 

A SNUR is a separate action that requires any company seeking to engage in a “significant new use” identified in the SNUR to notify EPA at least 90 days before beginning that use, triggering EPA’s review of the potential new use. For new chemicals that received orders, a SNUR can conform to the order – meaning it mirrors the conditions in the consent order for the chemical – or it can apply more broadly to activities or uses that are beyond the scope of the consent order. Either way, SNURs enable the agency to review potentially risky uses prior to their commencement. 

In our comments, we call for four major changes to a subset of the proposed SNURs: 

Read More »

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Flint area residents raise the bar on raising environmental justice concerns

Ugbaad Ali, Community Environmental Health Tom Graff Fellow

We all deserve to live in a healthy and vibrant community, yet many residents of Flint, Michigan, are overburdened by a lifetime of toxic exposures and environmental injustice. Recently, a coalition of environmental justice groups and community organizers in Flint used their combined power to organize against the siting of a new hot mix asphalt facility.

The Stop Ajax Asphalt Coalition was formed to protect neighboring communities from further environmental harm. The Coalition, which includes residents from Flint and Genesee Township, St. Francis Prayer Center, C.A.U.T.I.O.N, Environmental Transformation Movement of Flint, Flint Rising, Greater Holy Temple Church, Michigan United, R. L. Jones Community Outreach Center Campus, and Mi JustUs, submitted extensive comments and generated hundreds of public comments to contest the state’s permitting of a hot mixed asphalt facility by Ajax Materials Corp. near homes, schools, and parks.

Historically air permit decisions have been made in isolation, ignoring the cumulative impact from surrounding exposure sources. After hearing from the Coalition, the regional office of the Environmental Protection Agency (EPA) – which serves Michigan and five other states – weighed in with a letter that recommended Michigan’s Department of Environment, Great Lakes and Energy (EGLE) “conduct a cumulative analysis of the projected emissions from all emission units at the proposed facility, fugitive emissions from the proposed facility, and emissions from nearby industrial facilities, to provide a more complete assessment of the ambient air impacts of the proposed facility on this community.” It concluded that “because of the environmental conditions already facing this community, and the potential for disproportionate impacts, the siting of this facility may raise civil rights concerns.”

The U.S Department of Housing and Urban Development’s (HUD) regional office also  raised serious civil rights concerns in a letter to EGLE, highlighting that the proposed location is near two HUD-assisted communities housing low-income families of color – and expressing concern that EGLE failed to engage HUD on a decision that could impact HUD-assisted residents.

“This isn’t a defeat for the citizens of Flint. We’re just getting started.” – Anthony Paciorek, Michigan United (ABC News)

Despite the public comments and federal agency letters, EGLE approved the air permit, but with tightened requirements. The Coalition remains concerned about the siting of the facility and is committed to challenging the state to require additional measures to protect their community. Read More »

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