EDF Health

A glimmer of good news flowing from the Gulf’s other recent disaster

By / Published: June 18, 2010

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

I’ve been blogging for some weeks now about how we may be compounding the problems of the BP oil disaster through our massive use of inadequately tested and ineffective dispersants.  There’s an eerie echo in these events to the compounding effects of decisions made in the wake of the Gulf region’s last major disaster, 2005’s Hurricane Katrina: specifically, the decision to house victims forced out of their homes in trailers made from imported plywood that exposed them to toxic levels of formaldehyde, a known human carcinogen.

In what I choose to regard as a silver lining arising from this earlier debacle, the U.S. Congress is finally – nearly five years later – inching toward passing legislation that seeks to prevent a repeat of that episode, by putting limits on how much formaldehyde can be emitted from imported and domestically manufactured pressed wood products.  Read More »

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Are you a guinea pig?

By / Published: June 15, 2010

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

The answer to that question — or at least what should be the answer — is the name of a new campaign launched today by Environmental Defense Fund, in cooperation with the Safer Chemicals, Healthy Families coalition and a number of its member organizations.

I Am Not a Guinea Pig is a new online campaign that provides tools and information Americans from all walks of life can use to press for fundamental reform of our nation’s toxic chemical law, the Toxic Substances Control Act (TSCA).

I Am Not a Guinea Pig is aimed at helping to ensure that the voices of millions of Americans who are concerned about and affected by exposures to untested and unsafe chemicals are heard as Congress begins the first serious effort to overhaul the 34-year-old TSCA.

The campaign will use a variety of social media, including a website, a Facebook page with daily updates, and a #NAGP Twitter hashtag.

Our thanks go out to our partners in Safer Chemicals, Healthy Families with whom we’ve worked in our initial effort: Autism Society, Health Care Without Harm, Learning Disabilities Association of America, Moms Rising, Reproductive Health Technologies Project and Teens Turning Green.

The campaign initially focuses on three groups at particular risk from toxic chemical exposures:  teens, children and health professionals.  We’ll be expanding the campaign over time to include others at risk, and we’ll continue until we’ve achieved the campaign’s fundamental aim:  a strong new chemicals policy in the United States that protects all Americans from toxic chemicals.

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Dispersants are a teachable moment for TSCA reform

By / Published: June 10, 2010

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

The Safer Chemicals, Healthy Families campaign just held a press call to draw direct links between the huge unknowns associated with the unprecedented use of chemical dispersants in the Gulf and the failures of TSCA.  The campaign called upon Congress to ensure that legislation to reform TSCA fully addresses dispersant safety so that, the next time a disaster of this sort unfolds, the country won’t be caught with its proverbial pants down.

While the reform bills would go a long way to improve the situation, the campaign also provided a detailed description of enhancements to the current reform bills needed to address:

  • the lack of public access to sufficient information about dispersants, their ingredients and their concentrations;
  • the lack of adequate safety testing for long- as well as short-term effects on both marine environments and people, including affected workers, volunteers and nearby residents;
  • the lack of a requirement that dispersants be shown to be safe as a condition for allowed use; and
  • the lack of adequate EPA authority to disallow unsafe dispersants and to halt or alter dispersant use based on on-the-ground developments.

As the legislation advances, we will be pressing Congress to include additional provisions to address these deficiencies.  There could be no better illustration of the limits to our current policies than that provided by government’s forced reliance on under-tested chemical dispersants the use of which is raising more questions than answers.

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EPA clarifies it wants more information on those dispersants made public

By / Published: June 9, 2010

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

EPA issued a statement today drawing attention to its posting on its website late last week of the ingredients in NALCO’s Corexit® dispersants, more than one million gallons of which have now been released into the Gulf of Mexico.  The statement appears to have been issued in response to queries from myself and others as to why the posting was not more prominently flagged by EPA.  It indicates that the most recent disclosure “was possible because NALCO waived their claim” that the ingredient identities are proprietary.  It also makes clear EPA doesn’t consider Nalco’s disclosure to be the end of the story, and that EPA will continue to seek to provide the public with more information about the dispersants than their producers have produced to date.

I’ve posted EPA’s statement just beyond this jump. Read More »

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Presto: Corexit® dispersant ingredients revealed

By / Published: June 8, 2010

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

With no fanfare whatsoever, a list of the ingredients in the Corexit® dispersants has been posted on EPA’s website.  I can’t say when the list appeared — I was pointed to it by Elana Schor, a reporter with E&E News, who discovered the list a little earlier today, buried well down on the agency’s dispersants page.

The components of COREXIT® 9500 and 9527 are:

CAS Registry Number Chemical Name
57-55-6 1,2-Propanediol
111-76-2 Ethanol, 2-butoxy-
577-11-7 Butanedioic acid, 2-sulfo-, 1,4-bis(2-ethylhexyl) ester, sodium salt (1:1)
1338-43-8 Sorbitan, mono-(9Z)-9-octadecenoate
9005-65-6 Sorbitan, mono-(9Z)-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivs.
9005-70-3 Sorbitan, tri-(9Z)-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivs
29911-28-2 2-Propanol, 1-(2-butoxy-1-methylethoxy)-
64742-47-8 Distillates (petroleum), hydrotreated light

More to come.

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Side-by-sides of TSCA, Senate bill and House discussion draft

By / Published: June 5, 2010

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

I have updated and made some minor corrections to the summary chart I posted earlier comparing current TSCA to the proposed TSCA reform legislation (Senate bill and House discussion draft) at the 10,000 foot level. It’s displayed below.

In addition, I have prepared a much more detailed side-by-side of the Senate bill and House discussion draft, which I’m posting here as a PDF.

Currently under TSCA Under the Senate and House proposals
DATA:  Few data call-ins are issued, even fewer chemicals are required to be tested and no minimum data set is required even for new chemicals. Up-front data call-ins for all chemicals would be required.  A minimum data set (MDS) on all new and existing chemicals sufficient to determine safety would be required to be developed and made public.
BURDEN OF PROOF:  EPA is required to prove harm before it can regulate a chemical. Industry would bear the legal burden of proving their chemicals are safe.
SAFETY ASSESSMENT:  No mandate exists to assess the safety of existing chemicals.  New chemicals undergo a severely time-limited and highly data-constrained review. All chemicals, new and existing, would be subject to safety determinations (in the case of certain new chemicals, at some point after entry into commerce).
SCOPE OF ASSESSMENT:  Where the rare chemical assessment is undertaken, there is no requirement to assess exposure to all sources of exposure to a chemical, or to assess risk to vulnerable populations. The safety standard would require the assessment of a chemical to account for aggregate and cumulative exposures to all uses and sources, and to ensure protection of vulnerable populations that may be especially susceptible to chemical effects (e.g., children, the developing fetus) or subject to disproportionately high exposure (e.g., low-income communities living near contaminated site or chemical production facilities).  “Hot spots” would be specifically identified and addressed.
REGULATORY ACTION:  Even chemicals of highest concern, such as asbestos, have not been able to be regulated under TSCA’s “unreasonable risk” cost-benefit standard.  Instead, assessments often drag on indefinitely without conclusion or decision. Chemicals would be assessed against a health-based standard, and deadlines for decisions would be specified.  Chemicals of highest concern would be subject to expedited safety determinations and/or actions to reduce use or exposure to them.
INFORMATION ACCESS:  Companies are free to claim, often without providing any justification, most information they submit to EPA to be confidential business information (CBI), denying access to the public and even to state and local government.  EPA is not required to review such claims, and the claims never expire. All CBI claims would have to be justified up front.  EPA would be required to review them, and only approved claims would stand.  Approved claims would expire after a period of time.  Other levels of government would have access to CBI.
RULEMAKING REQUIREMENTS: To require testing or take other actions, EPA must promulgate regulations that take many years and resources to develop. In addition to the MDS requirement, EPA would have authority to issue an order rather than a regulation to require reporting of existing data or additional testing.
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