EDF Health

EDF to OMB: Ban on methylene chloride in paint strippers must protect workers in addition to consumers

By Lindsay McCormick / Published: February 7, 2019

Lindsay McCormick, Project Manager, and Joanna Slaney, Legislative Director

[pullquote]

Over 11,000 concerned Americans have sent messages to Members of Congress over the last two weeks to urge EPA and OMB to protect workers – the population at most risk – from methylene chloride in paint strippers.

[/pullquote]Today, EDF met with the White House Office of Management and Budget (OMB) about the Environmental Protection Agency’s (EPA) draft final rule on methylene chloride-based paint strippers. We urged the office to ensure the ban on methylene chloride-based paint and coating removers covers both consumer and most commercial uses – as the agency originally proposed.

Removing these deadly products from stores, workplaces, and homes is a critical step to protecting public health. Methylene chloride is acutely lethal. Exposure to the chemical has led to over 50 reported worker deaths since the mid-1980s, more than 40 of which are attributed to use of methylene chloride-based paint strippers. Many more deaths have likely gone unreported. The chemical is also associated with a host of other serious health effects, including neurotoxicity, cancer, and liver impairment.

Despite the facts that workers represent the vast majority of reported deaths and face the highest risks of other health effects, it appears that EPA is poised to finalize a rule that excludes a ban on commercial uses entirely – and will instead merely initiate a lengthy, uncertain process that may lead to certification and training approaches EPA had already considered and rejected as inadequate to protect workers.

Read More »

Also posted in Health policy, Public health, Regulation, TSCA reform / Tagged , , , , | Authors: / Comments are closed

Lead from a new “lead-free” brass faucet? More common than you’d hope

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 6, 2018

Tom Neltner, J.D. is the Chemicals Policy Director and Lindsay McCormick is a Project Manager.

[pullquote]Until NSF/ANSI 61 standard is updated to reduce or eliminate lead leaching, users must extensively clean and flush new brass fixtures before use and make a short flush standard practice for older fixtures.[/pullquote]

During this past year, we undertook a pilot project to tackle the problem of lead in drinking water at child care facilities. As part of the effort, we collected 250 mL samples (about 8 ounces of water) from every drinking water fixture, as recommended in the Environmental Protection Agency’s (EPA) 3Ts guidance for schools and child care facilities. We replaced 26 faucets that exceeded our action level with new brass faucets that were labeled “lead-free” and complied with NSF/ANSI 61 standard for drinking water system components.[1] To our surprise, when we sampled the faucets a few days after replacement, the lead levels were higher– between 9 and 10 ppb – on three of the new faucets.

The increase left us scratching our heads. Federal law allows a drinking water fixture to be labeled “lead-free” if the amount of lead in wetted surfaces[2] averages less than 0.25% (down from the 8% limit between 1986 and 2014). However, it isn’t clear how much this amount might contribute to levels of lead in water. To explore this issue, we contacted the supplier who said its product was certified under NSF/ANSI 61 and, therefore, not likely the source. The supplier suggested the source could be from existing upstream valves or from disturbing the plumbing. We could not rule these other possibilities out.

A study by Virginia Tech’s Jeff Parks on three models of new NSF/ANSI 61 certified brass faucets found similar results and concluded that even newly manufactured “lead-free” faucets may not meet the 1 ppb limit that the American Academy of Pediatrics (AAP) recommends for schools.

Read More »

Also posted in Drinking water, Lead / Tagged , , , , , , , , , | Authors: / Comments are closed

EPA Updates its 3Ts Guidance for Reducing Lead in Drinking Water

By Lindsay McCormick / Published: October 16, 2018

Lindsay McCormick, is a Project Manager. Tom Neltner, J.D., is the Chemicals Policy Director.

Earlier this month, EPA released its updated 3Ts for Reducing Lead in Drinking Water Toolkit, which provides guidance for schools and child care facilities seeking to ensure children are safe from lead in water.  The new 3Ts – an update to the agency’s 2006 guidance – is now a web-based toolkit that includes modules, customizable templates, and factsheets.

Overall, the new toolkit is an improvement.  While the protocol itself is largely the same, the new toolkit is more user friendly and written for the non-technical audience, making it more likely that school and child care staff will use it.  EPA has also reframed the toolkit from “Training, Testing, and Telling” to “Training, Testing, and Taking Action” – placing more emphasis on the critical step of addressing lead sources than the previous version.  “Telling” is now integrated throughout the entire toolkit to highlight the importance of communication at every step. The agency has also developed a helpful flushing best practices factsheet, which is a topic that often causes considerable confusion.

In EDF’s June 2018 report on our pilot of 11 child care facilities, “Tackling lead in water at child care facilities,” we recommended EPA update its 2006 guidance to address four key gaps.  The agency has made progress on the two most important of those but leaves the other two unresolved. The most important change to the guidance is that the agency has removed the 20 parts per billion (ppb) action level and instead recommends action whenever there are “elevated lead levels.” While EPA does not define an elevated lead level, a deep dive into the appendix suggests that levels over 5 ppb warrant follow-up. The updated guidance also puts a greater emphasis on the identification of lead service lines (LSLs) and includes LSL replacement as a permanent control measure, though not as an explicit recommendation. Further, the agency did not update the protocol to deal with challenges posed by aerator cleaning and hot water heaters.  Below we explore each of these issues in further detail. Read More »

Also posted in Drinking water, Health policy, Lead, Public health, Regulation / Tagged , , , , , | Comments are closed

Paint-lead hazard standard – A reconsideration

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: August 5, 2018

Tom Neltner, J.D., is Chemicals Policy Director

After 20 years working on lead poisoning prevention, it has become almost second nature for me to object when someone suggests that children eating paint chips is a significant route of exposure. All too often, the claim implies that the blame rests with parents who are not conscientious enough to clean or maintain their home or to properly care for their children. The implication is demeaning to the parents and distracts from the often – invisible lead dust hazards on floors that pose the greatest risk to children. So when I hear that idea, I quickly respond that dust is the key route of exposure.

However, a discussion with Hannah Chang at Earthjustice over my blog on the Environmental Protection Agency’s (EPA) July 2, 2018 proposed rule helped me realize that I was misguided with regards to defining the hazards of lead-based paints. She is the main attorney for the organizations that convinced a panel of judges in the Ninth Circuit Court of Appeals to order the EPA to update its lead-based paint hazard standard.

Hannah Chang told me I missed the most compelling point when I pointed out in my previous blog that “EPA did not appear to have considered HUD’s 2007 American Healthy Housing Survey, which should provide a solid basis for identifying the relationship between lead in paint and lead in dust.”  She was right; my logic was too focused on dust as the primary source of exposure. Here is my reasoning; it may be helpful to those planning to submit comments to EPA by the August 16 deadline on the proposed rule.

Read More »

Also posted in Health policy, Lead, Public health, Regulation / Tagged , , | Read 2 Responses

EPA undermines its own proposal for more protective dust-lead hazard standards

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: July 18, 2018

Tom Neltner, J.D., is Chemicals Policy Director

On July 2, 2018, in response to a court order, the Environmental Protection Agency (EPA) published a proposed rule[1] tightening its standards for lead in dust on floors and window sills for housing and child-occupied facilities built before 1978. The agency declined to lower the standard for lead in paint – citing insufficient information – and did not consider tightening the standards for lead in soil. While the proposed rule is a tentative step forward for lead poisoning prevention, as explained below, it will create unnecessary confusion and falls far short of what the science and the law demands. Comments are due by August 16, 2018. Pursuant to an order from the Ninth Circuit Court of Appeals, EPA must finalize the rule by July 1, 2019.

Read More »

Also posted in Health policy, Lead, Public health / Tagged , , , , | Comments are closed

FDA-approved PFAS and drinking water – Q&A on textile mills and environmental permits

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: June 21, 2018

Tom Neltner, J.D., Chemicals Policy Director, and Maricel Maffini, Ph.D., Independent Consultant

In May 2018, we released a blog highlighting paper mills as a potentially significant source of drinking water contamination from 14 Food and Drug Administration (FDA)-approved poly- and per-fluorinated alkyl substances (PFAS) used to greaseproof paper. We showed that wastewater discharge could result in PFAS concentrations in rivers in excess of the Environmental Protection Agency (EPA)’s 70 parts per trillion (ppt) health advisory level for drinking water contamination for PFOA and PFOS, the most studied of the PFASs. We identified 269 paper mills with discharge permits that warrant investigation. Readers of the blog have asked some important questions highlighted below. As with most issues involving PFAS, there are many gaps in what we know. Based on the information provided in response to EDF’s Freedom of Information Act (FOIA) request to FDA, we hope to fill in some of the gaps and highlight key information needed to better understand the risks of PFASs.  

Question 1: Could textile mills also be a source of PFASs in drinking water?

The answer is “probably.” The FDA-approved PFASs can be used in coating paper that contacts food to repel oil, grease, and water. The same or similar FDA-approved PFASs may be used for non-food uses such as coating textiles to resist stains and repel water.

The processes used to coat paper and textiles differ in some aspects that could affect a mill’s environmental releases. For paper, the PFASs are typically added to the wet wood fibers to be made into paper. In contrast, we understand that PFASs are applied to textiles after the water is removed. Therefore, we would suspect that the amount of PFASs, whether as polymers or impurities, released with the wastewater of a textile mill would be lower compared to that of a typical paper mill. However, there is very little data available to assess the potential environmental release of PFASs from textile mills. Unlike with FDA approvals, there is no environmental review of a chemical’s use in non-food consumer products.[1] So, it would be worthwhile to investigate textile mills for use of PFASs in addition to looking at paper mills.

Using an EPA database[2], we identified 66 textile mills (PDF and EXCEL) in the US, two thirds of which are located in North and South Carolina. Based on wastewater flow, the two largest mills are both operated by Milliken. Its largest facility is in Greenville, South Carolina with a water discharge of 72 million gallons per day (MGD). The second largest is in Bacon, Georgia with a water discharge of 15 MGD. DuPont’s Old Hickory facility, near Nashville, Tennessee, had the third greatest flow at 10 MGD. We do not know whether any of the facilities use and discharge FDA-approved PFASs.

Read More »

Also posted in Drinking water, FDA, Food, Health policy, Health science, Public health, Regulation / Tagged , , , , , , , , | Authors: / Comments are closed