EDF Health

Workers are people too; EPA should treat them that way

EPA’s proposed TSCA rule to limit risks from chrysotile asbestos uses a higher “acceptable” cancer risk for workers than the rest of the population

Maria Doa, Ph.D., Senior Director, Chemicals Policy

When it comes to drawing the line on cancer risks, should workers be treated differently than the general population? Of course not. Unfortunately, EPA’s recently proposed rule to manage risks from chrysotile asbestos does just that, using one level of acceptable risk for workers and another – more protective threshold – for everyone else.

EPA says it uses a range for determining acceptable cancer risks under the Toxic Substances Control Act (TSCA), the country’s main chemical safety law. The range spans a risk (or the chance that a person will develop cancer) of less than one in 10,000 to a risk of less than one in one million. EPA says this is consistent with the cancer benchmark used by the National Institute for Occupational Safety and Health (NIOSH).

However, EPA’s proposed TSCA rule for asbestos does not actually use a range and it is not supported by TSCA. EPA instead applies a risk level to workers 100 times less protective than for everyone else! Read More »

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Changes for the better: EPA looks out for workers in revised risk finding for HBCD

By Samantha Liskow, Lead Counsel, Health

EPA has started to fulfill its promise to take another look at many of the chemical risk findings made during the Trump Administration. First up was “HBCD,” a collection of flame retardants present in many goods, including building insulation, furniture, and electronics. In its revised risk determination for the chemical EPA proposed important changes that are needed to protect health and the environment and are required under TSCA, our main federal law on chemical safety.

We highlighted these positive steps in our comments to the agency and urged EPA to formalize these changes when it releases its final revised risk determination for HBCD and other chemicals undergoing reevaluation.

Here is a look at the changes EPA made: Read More »

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“Illegal, unscientific, and un-health protective”: Summing up EPA’s final methylene chloride risk evaluation

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

Today, the Trump EPA released its first final risk evaluation and determination under the reformed Toxic Substances Control Act (TSCA), for the carcinogenic and acutely lethal chemical methylene chloride.

Sadly, despite EPA’s rush to issue this document as the 4th anniversary of TSCA reform on June 22 approaches, EPA 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 has grossly and systematically underestimated the exposures to and risks of methylene chloride.  Read More »

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An unwarranted assumption run amok: How the Trump EPA grossly understates the risks of 1-Bromopropane to workers

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

We have blogged repeatedly about the ways in which the Trump EPA is compromising workers’ health, either by failing to identify the significant risks they face, or wishing away the risks EPA does identify by erroneously assuming that existing industry practices and OSHA regulations are taking care of any possible problem.

If EPA uses PPE assumptions to erase unreasonable risks, then it won’t regulate the chemical and will forgo its only opportunity to ensure that PPE is actually used.  If EPA does find unreasonable risk even with its PPE assumptions, by understating the magnitude of that risk, any subsequent regulation EPA promulgates will be underprotective.

All of this is contrary to the mandate Congress gave EPA when it reformed the Toxic Substances Control Act (TSCA) in 2016.  The new TSCA strengthens EPA’s authority and mandate to protect workers, explicitly identifying them as a “potentially exposed or susceptible subpopulation.”  But under this administration, EPA has instituted many policies and practices that undercut the protections afforded workers under TSCA.

A key policy driver is EPA’s assertion – absent any empirical evidence to support it – that workers throughout chemical supply chains will always wear effective personal protective equipment (PPE).  There are many legal, scientific and policy problems with this assumption, and it is only one of many questionable aspects of the Trump EPA’s handling of risks to workers.

But just how big a difference does this assumption make?  Let’s look at the agency’s draft risk evaluation for the carcinogenic solvent 1-Bromopropane (1-BP), which is currently undergoing public comment and peer review.  Read More »

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