EDF Health

Righting the ship: A new chance for stronger protections against toxic chemicals

By Richard Denison / Published: November 17, 2020

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

In June 2016, Congress passed historic, bipartisan legislation overhauling the Toxic Substances Control Act, the country’s main chemical safety law, to better protect the public from harmful exposure to toxic chemicals. The Trump administration has spent the last four years working to undermine TCSA by driving its implementation dangerously off the rails.

Now, with President-elect Biden set to take the helm in January, there’s a tremendous opportunity not only to repair the damage done by the Trump administration, but also to use the law proactively to ensure that everyone in the country is better protected from hazardous chemicals — with attention to those whose health is most at risk and to communities where exposures are greatest.

Here are five ways to restore sound and legal implementation of the law and strengthen health protections for families across the country.

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Passing the buck: The Trump EPA’s mind-boggling efforts to ignore the risks of 1,4-dioxane in drinking water

By Richard Denison / Published: September 3, 2020

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

Readers of this blog will recall the major concerns EDF, EPA’s science advisors, and many others have raised about the Trump EPA’s systematic exclusion from its risk evaluations of all human exposures to chemicals released to air, water and land.  EPA has taken this illegal, unscientific and un-health protective approach across the board in the risk evaluations it has issued to date in draft or final form under the Toxic Substances Control Act (TSCA).

EDF first flagged the emergence of this fatally flawed approach over two years ago, and again when it was applied to the likely human carcinogen 1,4-dioxane, one of the first 10 chemicals undergoing TSCA risk evaluations.  Since then the Trump EPA has doubled down, repeatedly defying its own science advisors who have called out this deficiency in virtually all of their peer reviews of EPA’s draft risk evaluations.  EPA is clearly refusing to budge, issuing two final risk evaluations for methylene chloride and 1-bromopropane that seek to codify the approach.[pullquote]EPA’s Office of Water is deferring any decision on whether to regulate 1,4-dioxane in drinking water, pending completion of a risk evaluation that expressly excludes that exposure.  That exclusion is in turn based on the TSCA office’s claim that the Office of Water already has it covered.[/pullquote]

The asserted basis for ignoring tens of millions of pounds of these chemicals released annually is EPA’s claim that the releases are adequately managed under other laws the agency administers.  To bolster that claim, EPA also asserts that it has closely consulted with the EPA offices that administer those other laws to ensure this is the case.  Let’s take a closer look at the nature – and apparent effects – of that consultation in one setting:  1,4-dioxane in drinking water, which falls under the authority of the Safe Drinking Water Act (SDWA) administered by EPA’s Office of Water.  Read More »

Also posted in Health policy, TSCA reform / Tagged , , | Read 1 Response

Under the Trump EPA, no risk to workers is too high to impede a new chemical’s unfettered entry into the market

By Richard Denison / Published: August 27, 2020

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

The Trump EPA’s understating of the risks to workers posed by both existing and new chemicals under the Toxic Substances Control Act (TSCA) has been a frequent topic for this blog.  This disturbing, illegal policy continues unabated and, if anything, has accelerated and expanded to outright dismissal of worker health concerns.[pullquote]The Trump EPA’s blatant shirking of its clear responsibilities under TSCA to identify and mitigate the serious risks that chemicals present to workers – who are on the front lines of chemical exposures – surely constitutes one of its most egregious failings.[/pullquote]

In its reviews of new chemicals, EPA now frequently identifies serious risks to workers that exceed its own risk benchmarks, often many times over.  How great are the exceedances EPA finds and ignores?  Our examination of recent cases, described below, reveals exceedances as high as 25,000-fold.  In other words, EPA has found and then dismissed worker exposures to new chemicals at levels as much as 25,000 times higher than it deems acceptable. That is not a typo:  In a very recent case EPA found a dermal risk of reproductive effects to workers that exceeded its own benchmark by a factor of 25,000.

Any reasonable new chemical review that identified excess risk would then impose conditions blocking or conditioning the market entry of these chemicals in a manner sufficient to mitigate the identified risks.  Indeed, that is exactly what TSCA requires EPA to do.

Instead, the Trump EPA over and over again clears these chemicals entirely, ignoring its own risk findings to assert that the chemicals are “not likely to present unreasonable risk.”  This has now been done for hundreds of new chemicals EPA has reviewed in the past two years.

To illustrate what EPA is doing, we examined the 29 new chemicals EPA found “not likely to present unreasonable risk” (“not likely” determinations) since the beginning of June of this year.  Read More »

Also posted in Health policy, Industry influence, TSCA reform, Worker safety / Tagged , | Read 2 Responses

EPA flouts the law, science, and its obligation to protect public health yet again: The 1-bromopropane final risk evaluation

By Richard Denison / Published: August 11, 2020

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

Today, the Trump EPA released its second final risk evaluation and determination under the reformed TSCA, for the carcinogenic solvent, 1-bromopropane (1-BP). [pullquote]EPA has once again ignored expert scientific input it received from its own advisors.[/pullquote]

As was the case with the final document for methylene chloride – which has already been challenged in court (see here and here) – EPA has doubled down on the illegal, unscientific, and un-health protective approach it has taken in all of its draft risk evaluations for the first 10 chemicals reviewed under TSCA.

EDF will be closely examining this final document, but it is already apparent that EPA continues to grossly and systematically underestimate the exposures to and risks of 1-BP to the general public, workers and the environment.

Below are four examples of the flaws; each was raised by EPA’s own Science Advisory Committee on Chemicals (SACC) in its peer review as serious deficiencies – expert scientific input that EPA has simply chosen to ignore in finalizing the document:  Read More »

Also posted in Health policy, Health science, Industry influence, Public health, TSCA reform, Worker safety / Tagged , , | Read 1 Response

Greasing the skids: The Trump EPA is green-lighting dozens of new PFAS under TSCA

By Richard Denison / Published: July 28, 2020

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

Under an obscure and opaque – and increasingly used – exemption that EPA provides under the Toxic Substances Control Act (TSCA), EPA has been quietly approving companies’ requests to introduce new poly- and per-fluorinated substances (PFAS) onto the market.  And it seems to be ramping up. [pullquote]Under this EPA the “low-volume exemption” (LVE) application process is proving to be very smooth sailing for getting new PFAS onto the market.[/pullquote]

PFAS is a class of chemicals that are showing up as environmental contaminants all over the country.  They are linked to large and growing list of adverse effects on human health.  These concerns have led to increased scrutiny about EPA’s actions to allow new PFAS to enter commerce.  EDF and others have raised concerns about a number of premanufacture notices (PMNs) companies have filed seeking approval to introduce new PFAS into commerce (see here and here); the PMN process is the standard way in which companies are to notify EPA of their intent to start manufacturing a new chemical.

But EPA has created other pathways to quickly get a chemical on the market, whereby companies can apply for an exemption from the PMN process.  As documented in this post, we have identified a whole lot of PFAS coming into EPA’s new chemicals program through exemptions, and most of them are getting quickly approved.  Worse yet, this side process is highly insulated from public scrutiny.  Read More »

Also posted in Health policy, Health science, Industry influence, PFAS, TSCA reform / Tagged , | Comments are closed

Why now is the moment for cities around the world to act decisively on air pollution

By Sarah Vogel / Published: June 30, 2020

Sarah Vogel, Ph.D., is Vice President for Health.

This is the second in a series of Global Clean Air blogs on COVID-19 and air pollution. EDF scientists and program experts will share data about pollution levels during quarantine from a local and global perspective, and provide recommendations for governments and companies to Rebuild Better.

New COVID-19 air quality/ transportation measures in Bogotá, Colombia.

Around the world, we’ve seen dramatic improvement in air quality as a result of the response to COVID-19. While it’s come from an artificial and unwanted brake on the global economy, it’s drawn renewed attention to the devastating impacts of outdoor air pollution.

As many large cities around the world emerge from lockdown, city authorities need to act decisively to prevent air pollution rebounding and even exceeding pre-COVID-19 levels. That was the conclusion of participants in a “Clear Skies to Clean Air” webinar I moderated last week by the Organisation for Economic Co-operation and Development World Wildlife Fund and Environmental Defense Fund, in collaboration with the World Bank.

The improvements in air quality seen during the COVID-19 lockdown have shown individuals and policymakers what is possible and could open the door to reinvigorated efforts to address pollution.

London and Bogotá demonstrate clean recovery strategies

The webinar heard from policymakers on the front lines of addressing air pollution: Shirley Rodrigues, Deputy Mayor of London, with responsibility for environment and energy; and Claudia López, Mayor of Bogotá, Colombia.

New COVID-19 air quality/ transportation measures in London.

Cities need devolved powers if they are to address local air pollution, argued Rodrigues: “We can’t have a centralised approach … Citizens deal with their local authorities, mayors know what is needed in their cities. Devolving powers, alongside funding, is absolutely critical so we can push the electrification agenda and the reclamation of roads, so we can avoid a car-based recovery.”

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Also posted in Air pollution, Hyperlocal mapping, International, Public health / Tagged , , | Comments are closed