EDF Health

Haste makes waste: The Trump EPA’s 1,4-dioxane supplement may be its shoddiest TSCA work yet

By Richard Denison / Published: December 11, 2020

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

Yesterday EDF submitted comments on a supplement to EPA’s 1,4-dioxane risk evaluation under the Toxic Substances Control Act (TSCA), which the agency issued a scant three weeks ago.

This solvent is a likely human carcinogen that contaminates drinking water nationwide and is present in millions of consumer products.[pullquote]What EPA left out of its analysis swallows what it included.[/pullquote]

The supplement expands the scope of EPA’s ongoing risk evaluation of 1,4-dioxane.  It now includes certain water exposures and certain exposures of consumers to products in which the chemical is present as a contaminant (more technically, a “byproduct”).

EPA rushed the public comment period, providing only 20 days and refusing requests from at least 14 organizations for an extension.  The agency also cut out another vital step in the process – peer review –in violation of its own rules for how risk evaluations are to be conducted.

But that wasn’t the only thing EPA rushed.  The Supplement itself was an 11th-hour affair, done mainly to appease a hypocritical demand from the formulated chemical products industry.

The haste with which it was assembled badly shows.  The additional exposures EPA examined are so narrowly constructed as to omit major, and potentially the largest, sources of exposure and risk people face from the presence of 1,4-dioxane in water and products.

And what EPA left out of its analysis swallows what it included.  Read More »

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A tale of two public comment extension requests: How they fared under the Trump EPA

By Richard Denison / Published: December 10, 2020

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

In recent weeks EPA has issued for public comment significant modifications to its draft risk evaluations under the Toxic Substances Control Act for two chemicals:  Pigment Violet 29 (PV29) and 1,4-dioxane.  Because EPA initially provided relatively brief comment periods on the modifications, both were subject to requests for extensions of the comment period.

The table below tells the story of how these two requests fared under the Trump EPA.  Read More »

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EPA’s final risk evaluation of trichloroethylene is scientifically flawed and understates risks to workers, the general public and those most susceptible

By Richard Denison / Published: November 23, 2020

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

Today the Trump Environmental Protection Agency (EPA) issued its final risk evaluation for trichloroethylene (TCE).  It largely tracks the agency’s draft document, retaining numerous flaws that severely understate the highly toxic chemical’s risks to workers, the general public and those most susceptible to its health impacts.

Among the evaluation’s most serious deficiencies is the abandonment of a bedrock principle of chemical risk assessment: that risk estimates be based on the most sensitive health effect.  Sadly, the final document retains the unprotective approach the Trump White House forced EPA to adopt, as reported in detail by Elizabeth Shogren of Reveal News.

Exposure to TCE is ubiquitous, coming from ambient and indoor air, vapor intrusion from contaminated sites, groundwater and drinking water wells, and food – yet EPA’s evaluation ignores or downplays each of these exposure sources and pathways.

Below we summarize some of the major concerns in EPA’s evaluation that we addressed in detail in our comments.

One silver lining:  Despite its glaring deficiencies, the risk evaluation did find that the great majority of TCE’s conditions of use present unreasonable risks—even as it grossly understated the extent of those risks.  As a result, EPA must now proceed to regulate those activities, providing the new Administration an opportunity to rectify the serious problems created by the Trump EPA.  Read More »

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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.

Read More »

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Industry’s influence over EPA could get even worse: Chemical advisory board nominees rife with conflicts of interest

By Richard Denison / Published: October 29, 2020

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

Today Environmental Defense Fund, Earthjustice, Natural Resources Defense Council, Physicians for Social Responsibility, and Union of Concerned Scientists filed comments on EPA’s list of nominees for appointment to its Science Advisory Committee on Chemicals (SACC).  The SACC conducts peer reviews of chemical risk evaluations EPA conducts under the Toxic Substances Control Act (TSCA). EPA can rectify this sad state of affairs by excluding these and any other conflicted individuals under consideration from membership on the SACC when EPA adds new members.

Our comments identified 19 nominees that have serious actual or potential conflicts of interest that should disqualify them from being appointed to the SACC.  Unfortunately, their inclusion in EPA’s list of nominees suggests either that EPA has not conducted even the most cursory of conflict-of-interest screenings of these nominees, or that the agency intends to flout conflict-of-interest concerns and skew the balance of its science advisors even further in its drive to prioritize the interests of industry over public health and environmental protection.  The most recent example of this is EPA’s appointments or elevation of members on the agency’s Science Advisory Board earlier this month.

Over the past several months, EPA received a slew of nominations for SACC membership of individuals that are employed either by companies with direct financial interest in specific chemicals or related science policy issues that fall within the remit of the SACC, or by consulting firms hired by those companies or their trade associations to represent their interests before EPA.

As extensively documented in the comments we submitted today, these individuals should not be appointed to the SACC because they trigger one or both of the federal requirements for excluding individuals from membership on federal advisory groups:  having potential or actual conflicts of interest, or creating an appearance of a lack of impartiality.  Read More »

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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 »

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