EDF Health

Paper mills as a significant source of PFAS contamination, but who’s watching?

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

Update: See June 21, 2018 Q&A blog on PFAS at textile mills and environmental permits

Across the country, communities are grappling with how to manage contamination of drinking water by perfluorinated alkyl substances (PFASs), a class of chemicals widely used in consumer products, industrial processes, and firefighting foams. Concern over the chemicals grew with the Environmental Protection Agency’s (EPA) 2016 release of a 70 parts per trillion (ppt) drinking water health advisory for PFOA and PFOS, two common and well-studied forms of PFASs.

One challenge to effectively evaluating the potential impacts of PFASs as well as cleaning up priority sites is that there is very little information on where these chemicals are being used. Through a Freedom of Information Act (FOIA) request to FDA, EDF obtained documents previously not made public that show that paper mills using PFASs may be a significant source of contamination to water and potentially to air and compost.

In the nearly 900 documents we received from FDA, we found environmental assessments in four Food Contact Substance Notifications (FCNs) submitted in 2009-2010 by two companies, Daikin America and Chemours.[1] FDA approved each notice, allowing the companies to sell their PFASs to make paper and paperboard repel oil and grease in food packaging such as pizza boxes, sandwich wrappers, and microwave popcorn bags. All four assessments based their estimates on what they called a “typical” paper mill that produces 825 tons of PFAS-coated paper per day and discharges 26 million gallons of water per day.[2]

  • Chemours FCN 885 estimated 95 pounds/day of its PFAS[3] in the wastewater discharge at 43,000 ppt.
  • Chemours FCN 1027 – a notification for the same PFAS – increased the amount in paper from 0.42% to 0.8% resulting in 183 pounds per day in the wastewater discharge at 83,000 ppt.
  • Daikin FCN 933 estimated 180 pounds/day of its PFAS[4] in the wastewater discharge at 83,000 ppt.
  • Daikin FCN 1044 estimated 225 pounds/day of a similar PFAS[5] in the wastewater discharge at 103,000 ppt.

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EPA reaffirms Lead-Safe Renovation, Repair, and Painting Rule, citing 150% to 500% payback

Tom Neltner, J.D.is Chemicals Policy Director

In April 2018, the Environmental Protection Agency (EPA) completed a thorough review of its Lead-Safe Renovation, Repair, and Painting Rule (RRP) promulgated a decade ago. This rule requires contractors and landlords to use lead-safe work practices when more than minor amounts of lead-based paint in homes built before 1978 are disturbed. It also applies to pre-1978 child-occupied facilities. This review was conducted pursuant to Section 610 of the Regulatory Flexibility Act because of RRP’s significant impact on more than 300,000 small businesses that perform more than 4 million affected projects each year.

EPA concluded that RRP, including several post-2008 amendments, “should remain unchanged without any actions to amend or rescind it.” As part of the review, the agency updated its economic analysis and found that the estimated annual societal benefits, primarily in improved children’s IQ, of $1.5 to $5 billion exceeds the $1 billion in estimated annual compliance costs. Those estimates translate into an impressive annual payback of 150% to 500%. Keep in mind that these benefits do not include the lower risk of premature cardiovascular deaths attributed to adult lead exposure in a March 2018 report in Lancet.

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New Study Says Lead – Even at Low Levels – is Associated with Risk of Premature Death

Dr. Ananya Roy is Health Scientist and Tom Neltner, J.D. is Chemicals Policy Director

This week, a team of researchers led by Dr. Bruce Lanphear published an important new study on the deadly impact of lead exposure for adults. The researchers examined data on more than 14,000 adults and found that an increase of 1 to 6.7 micrograms of lead per deciliter of blood (µg/dL) was significantly associated with an increase in mortality of 37% for all-causes, 70% for cardiovascular, and 108% for ischemic heart disease. The findings remained significant even after they considered and accounted for other factors that could have explained this effect.

This research fills a gap identified by the National Toxicology Program in 2011 in our understanding of the risk of lead exposure at low levels in adults. And it goes further by providing a quantitative relationship crucial to better evaluating the potential economic benefits of various policy options.

The study also had startling estimates about how many people are hurt by lead exposure. The authors estimated that over 400,000 Americans every year die from lead related illnesses – ten times higher than previous assessments. That’s on par with deaths from smoking cigarettes.

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Federal court of appeals gives EPA one year to update lead-based paint standards

Tom Neltner, J.D.is Chemicals Policy Director

Update: On July 2, 2018, EPA issued the proposed rule after the court gave it a 90-day extension. The agency has one year – until July 1, 2019 – to issue a final rule. Blog clarified on timing.

This week, the federal Ninth Circuit Court of Appeals directed the Environmental Protection Agency (EPA) to update its regulations defining lead-based paint and how much lead in dust represents a hazard. The court gave EPA 90 days to issue a proposed rule and one year later to publish a final rule with an option to convince the court that it needs additional time. The court said the agency had unreasonably delayed action on a citizen’s petition submitted in 2009. The science showing the need for action has only become more compelling in the eight years since EPA acknowledged the shortcoming of its rules. Rather than drag out this litigation, the agency should move quickly to revise its lead-based paint hazard standards to better protect children’s health.

EPA set the dust-lead hazard standard in 2001 after determining that a child living in a home with those levels had only a 1 to 5% chance of having an elevated blood lead level (EBLL) as defined by the Centers for Disease Control and Prevention (CDC). The scientific evidence now shows that the risk is greater than previously estimated. In addition, CDC has tightened its definition of an EBLL. As a result, according to the American Academy of Pediatrics, the risk to a child of having an EBLL in a home that meets EPA’s current dust-lead hazard standard is more than 50%.

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Children’s lead exposure: Relative contributions of various sources

Tom Neltner, J.D.is Chemicals Policy Director and Dr. Ananya Roy is Health Scientist

Last week, we noted in our blog that the Environmental Protection Agency (EPA) dropped the statement that paint, dust and soil are the most common sources of lead in its “Protect Your Family from Lead in Your Home” booklet. Property owners provide this booklet to prospective homebuyers and tenants in housing built before 1978. The change implicitly recognizes that there is no safe level of lead in the children’s blood, and we must reduce all sources of lead exposure. It also acknowledges that the relative contribution of air, water, food, soil, dust, and paint to children’s blood lead levels is complicated. Exposure varies significantly based on age of the home, the child’s race and age, the family’s income-level, and region of the country. Any simplification obscures these important differences.

EPA’s scientists made this clear in a model published earlier this year that pulled together the available data, divided children into three age categories, and assigned children in each category into ten groups based on their overall lead exposure. For each group, they estimated the relative contribution of air, water, food, and soil/dust (from paint). Not surprisingly, children living in older homes with lead-based paint hazards by far have the most exposure to lead. For 1 to 6 year olds in the top 90-100 percentile, more than 70% of the lead in their blood is from soil and dust. The contribution from food is 20% and drinking water is 10%. For infants, soil and dust contributes to 50% of the lead in blood, while 40% is from water and 10% from food.

Since there is no known safe level of lead in blood, we must do even more to reduce children’s exposure to lead-contaminated soil and dust.

However, to prioritize action at a national level, it is important to understand how different sources contribute to lead exposure in the average child as well as the most-exposed child. We used the underlying EPA data to calculate the average relative source contribution of different sources to blood lead levels for infants from birth to six months old, for toddlers 1 to 2 years old, and young children from 1 to 6 years old. The results indicate that infants have a much higher source contribution of lead from water in comparison to older children (Figure 1). For the average child 1 to 6 years old, food is the largest source of lead exposure, with 50%, followed by soil/dust then water.

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CBS News covers a chemical’s tragic impact; points to urgent need to ban high-risk uses of methylene chloride

Lindsay McCormick is a Project Manager.  

This morning, CBS News focused on the tragic story of Kevin Hartley—a young man who died at the age of 21 while working with a product that contains methylene chloride. Kevin’s story, powerfully relayed by his mother Wendy, illustrates the need to ban high-risk uses of this chemical.

As we have previously noted, in January, the Environmental Protection Agency (EPA) proposed to ban methylene chloride in paint and coating removal products. The agency based its proposal on an extensive assessment of the scientific literature, which demonstrated not only lethal risks from acute exposures to methylene chloride but also a host of other acute and chronic health impacts, like harm to the central nervous system, liver toxicity, and cancer.

Products containing this chemical can be readily found in most hardware stores in America and more tragedies are all but certain, if EPA does not promptly finalize its proposed ban.

The ongoing debates in Washington over the implementation of a new chemical safety law passed just last year are often dense and dry. In sharing her son Kevin’s story, Wendy Hartley reminds us that how these policies are applied has a very real human impact. That is why EDF continues to demand EPA better protect American families from toxic chemicals like the one highlighted by CBS News today.

Please watch the story: https://www.cbsnews.com/news/dangers-of-common-paint-stripper-chemical-methylene-chloride/

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