EDF Health

Estimating chemical risk: Breadth (prevalence) may be just as important as depth (magnitude of effect)

By Jennifer McPartland / Published: April 23, 2012

Jennifer McPartland, Ph.D., is a Health Scientist.

Earlier this month Dr. David Bellinger at Boston Children’s Hospital published a very interesting paper in Environmental Health Perspectives offering a new way to consider the importance of various risk factors for child neurodevelopment—such as pre-existing medical conditions, poor nutritional status or harmful chemical exposures—at the population level.  “A Strategy for Comparing the Contributions of Environmental Chemicals and Other Risk Factors to Neurodevelopment of Children” argues that, in evaluating the contribution of a risk factor to a health outcome, it is critical to consider not only the magnitude of its effect on the health outcome, but also the prevalence of that risk factor in the population.

Dr. Bellinger argues: “Although a factor associated with a large impact would be a significant burden to a patient, it might not be a major contributor to the population if it occurs rarely.  Conversely, a factor associated with a modest but frequently occurring impact could contribute significantly to population burden.”  The former “disease-oriented” approach has generally been used to estimate the burden of harmful chemical exposures to population health, rather than the latter “population-oriented” approach.  Relying solely on the former approach, he contends, may result in an underestimation of the impact of a chemical exposure or other risk factor on public health.  Read More »

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Striking the right balance between right to know and right to intellectual property protection

By / Published: April 13, 2012

Richard Denison, Ph.D., is a Senior Scientist.

There is clearly a need to balance the legitimate claims of companies to protect certain confidential business information (CBI) from public disclosure with the legitimate need for the market, consumers and the public to have access to information they need to make sound decisions about chemicals that are in commerce.  Unfortunately, most of TSCA’s provisions and their implementation by EPA have skewed this balance radically in the direction of denying the public’s right to know and creating an ill-informed chemicals marketplace.

The core problem is two-fold, constituting a vicious circle:  Too many CBI claims are made, and each of the infrequent examinations of such claims done by EPA has found a large fraction to be illegitimate, i.e., not meeting the well-established criteria for what constitutes a legitimate trade secret.  And because of the large number of claims made, EPA has lost the ability to review claims to ensure they are in fact legitimate and remain so over time; this lack of review has led directly to more claims being made, thereby completing the vicious circle.  Read More »

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Restoring the credibility of risk assessment: A vital need under TSCA reform

By / Published: April 6, 2012

Richard Denison, Ph.D., is a Senior Scientist.

The primary means by which chemical risks are to be judged under current legislative proposals for reform of the Toxic Substances Control Act (TSCA), including the Safe Chemicals Act of 2011 (S. 847), is through risk assessment – a key demand of industry.  Yet traditional risk assessments have often fallen short of protecting public health and have sometimes taken decades to identify a “safe” level of exposure to certain chemicals.  As a result, public and health and environmental community confidence in risk assessment is very low.  There are also major technical deficiencies in current risk assessment methodologies that must be addressed if it is to serve as a credible basis for determining chemical risks.  For example, we now know that there are many chemicals for which any level of exposure poses some risk, yet traditional risk assessment assumes a safe level exists for nearly all chemicals.

The Safe Chemicals Act includes provisions to ensure that EPA’s use of risk assessment incorporates the best available science, initially by requiring EPA to rely on the recent recommendations of the nation’s foremost scientific body, the National Academy of Sciences, as to how EPA can improve its practice of risk assessment. Implementing the recommendations is critical to restoring the credibility of and public confidence in risk assessment. Read More »

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Exposing our ignorance: EPA study reveals barren exposure data landscape

By Jennifer McPartland / Published: March 16, 2012

Jennifer McPartland, Ph.D., is a Health Scientist.

This past November, EPA scientists published a sobering paper, “The exposure data landscape for manufactured chemicals,” in the journal Science of the Total Environment.  The paper reveals how little systematic information we have about human and environmental exposures to the thousands of chemicals in use today.

The aim of the study was “to define important aspects of the [chemical] exposure space and to catalog the available exposure information for chemicals being considered for analysis as part of the U.S. EPA ToxCast screening and prioritization program.”  Its conclusion:  “The results suggest that currently available exposure data are insufficient to provide the evidence base required to inform risk assessment and public health decision making.”  Not good, but not surprising.  Read on for more detail. Read More »

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Smoke and Mirrors: ACC lawyers are working hard to rein in your right to know

By / Published: March 1, 2012

Richard Denison, Ph.D., is a Senior Scientist.

I’ve blogged here frequently about EPA’s efforts over the past couple of years to make more chemical information available to the public, especially health and safety information.  A key part of this, believe it or not, is simply making sure that when EPA shares a health study with the public – as required by law – you get to know the identity of the chemical that is the subject of that study.

EPA’s initial steps (see below) were met with a little grumbling on the part of the chemical industry, but not a whole lot.  After all, the industry says it wants the public to have more information about chemicals.  At #7 on the American Chemistry Council’s (ACC) top 10 principles for TSCA reform is:  “Companies and EPA should work together to enhance public access to chemical health and safety information.”

Times, apparently, have changed.  In recent weeks, ACC has launched a broadside attack on the EPA’s efforts to compel its member companies ever to name a chemical when submitting health and safety information to EPA.  My evidence?  A 36-page White Paper delivered by ACC to the office of the regulatory czar at the Office of Management and Budget, at a meeting held there on January 20.  The ACC document is a wonder of tortured logic, obfuscation and selective renditions of the history of TSCA.

Today, a response was mounted.  EDF and Earthjustice staff, as well as representatives of health-affected individuals, environmental justice communities and workers, held their own meeting with OMB officials.  And we delivered our own letter to OMB that thoroughly rebuts ACC’s White Paper.  It also points out that, way back in 1976, the drafters of TSCA actually wanted you to have access to health and safety information on chemicals – and they darn well didn’t expect you to have to guess at the identity of those chemicals.  Read More »

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No orphan left behind: Health and environmental NGOs support EPA’s proposed paired rules to address high production volume “orphan” chemicals

By / Published: January 18, 2012

Richard Denison, Ph.D., is a Senior Scientist.  Allison Tracy is a Chemicals Policy Fellow.

Environmental Defense Fund today submitted comments along with 15 other health, environmental justice and state and national environmental organizations, in support of EPA’s proposed rule to address the final batch of 45 “orphan” chemicals that were never sponsored under the agency’s earlier High Production Volume (HPV) Challenge Program.

An earlier post to this blog highlighted and applauded the novel, innovative and efficient approach EPA has proposed, which actually entails the coupling of two rules:

(1) a test rule for 23 of these HPV chemicals for which EPA can make the requisite exposure findings to require testing, combined with:

(2) a Significant New Use Rule (SNUR) for the other 22 HPV chemicals for which EPA cannot presently make such findings, which requires companies to notify EPA if their production or use of those chemicals changes so as to increase the potential for exposure and then warrant testing.

The comments we filed today reiterate our strong support for this approach – and propose that the same approach be extended to several additional batches of HPV chemicals that still lack a basic set of hazard data.

Read More »

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