EDF Health

Understanding PFAS: Why a broad, transparent PFAS Testing Strategy is needed

Maria Doa, Senior Director, Chemicals Policy; Lauren Ellis, Research Analyst; and Lariah Edwards, Post-Doctoral Fellow

EDF this week sent EPA a letter identifying opportunities for the agency to improve the effectiveness and transparency of its strategy for testing per- and polyfluoroalkyl substances (PFAS).

EPA unveiled its National PFAS Testing Strategy (Testing Strategy) last fall, laying out its plan to better understand the class of chemicals and inform its future regulatory efforts. PFAS are a large group of synthetic chemicals used to impart water, oil, grease, and stain resistance to various materials, and they are used in hundreds of everyday products, from water-proof clothing to grease-proof food packaging. By its own count, EPA says there are more than 12,000 individual PFAS.

In their letter to EPA, EDF analyst Lauren Ellis and post-doctoral fellow Lariah Edwards commended the agency for developing a strategy to address some of the significant data gaps that exist around PFAS and committing to use its authority under the Toxic Substances Control Act (TSCA) ‒ the country’s main chemical safety law ‒ to require manufacturers to provide toxicity data on the chemicals.

As the letter points out, however, in its current state, the Testing Strategy lacks sufficient detail and is too narrow to fulfill the agency’s intended purpose to understand and regulate PFAS in a way that is protective of both human health and the environment. Read More »

Posted in Health science, PFAS / Tagged , | Comments are closed

The new FDA Commissioner has a full plate; here are 3 steps he can take to keep focused on food safety

Tom Neltner, Senior Director, Safer Chemicals.

The U.S. Senate today voted to return Robert Califf to the role of FDA Commissioner, bringing needed leadership to an agency that plays a vital role in protecting public health. 

While Dr. Califf faces historic challenges in the form of the COVID-19 pandemic and the opioid epidemic, he also has a tremendous opportunity to elevate the agency’s important role in protecting the public from unsafe chemicals in food. 

We put together a list of three things Dr. Califf and the FDA have the authority to do right now to keep problematic chemicals out of our food:  Read More »

Posted in BPA, FDA, Food, GRAS, Lead, Public health / Tagged , , , , , | Authors: / Comments are closed

Did your kids have a hyper holiday? Why those vibrantly colored treats need a warning label

Terry Hyland, Communications Manager

Many parents have experienced that foreboding sense of what might come next as they watch their child indulge in a decadent treat at a holiday gathering or birthday party. All that sugar means things are about to get a little crazy, right?

While sugar has its own issues, perhaps the source of that burst of hyperactivity is another ingredient: the synthetic dyes that brighten many of our sweet treats, and many of the not-so-sweet ones too.

Last year, California government scientists at the Office of Environmental Health Hazard Assessment (OEHHA) released a report finding that commonly used synthetic food dyes can lead to hyperactivity and other neurobehavioral problems in children, with some reacting very strongly to relatively small amounts of colorants. Children’s exposure is also higher compared to adults.

That stands to reason. According to OEHHA, the most common food items associated with food dye exposures include icings, fruit-flavored and juice drinks, sodas, and breakfast cereals. And it is not only the more than 6 million children diagnosed with Attention Deficit Hyperactivity Disorder (ADHD) that may be particularly sensitive to synthetic dyes; kids without pre-existing behavioral disorders can also be affected. Read More »

Posted in FDA, Food, Health science / Tagged , | Comments are closed

In latest act of leadership, Cincinnati votes to cover the cost of replacing lead pipes for all residents

Tom Neltner, Chemicals Policy Director

The Cincinnati City Council has voted unanimously to authorize Greater Cincinnati Water Works (GCWW) to pay 100% of the cost of replacing private lead service lines (LSLs) that bring drinking water to customers’ homes and other buildings. The Council’s December vote supports its larger strategy to “provide quality healthy housing for all income levels.” More broadly, the action is the latest act of leadership from the city as it works to address the environmental justice issues in its communities.

The ordinance gives GCWW the authority to help more customers pay to fully replace LSLs as the utility conducts infrastructure work on drinking water mains that connect to the lead pipes. Since 2017, the utility has subsidized up to 40% of a customer’s replacement cost through grants, and allowed customers to take a 10-year, interest-free loan.

Despite these incentives, the utility recognized that the cost of replacement was an obstacle for many customers, especially for low-income residents. About 60% of customers declined to participate, leaving them with partial LSL replacements that left lead pipes on private property in place. These partial replacements create higher short-term spikes in lead levels in drinking water and do not reliably reduce the risk of lead exposure over the long-term, as full replacement does. This is an important step for Cincinnati, as it ends LSL replacement practices that force customers to share in the costs that can lead to environmental justice and civil rights issues. Read More »

Posted in Civil rights, Drinking water, Lead, Public health / Tagged , , , , | Comments are closed

Civil rights complaint draws attention to the discriminatory impacts of common lead pipe replacement practice

Jennifer Ortega, Research Analyst, Environmental Health

This past Wednesday, Rhode Island’s Childhood Lead Action Project (CLAP) led a coalition of groups in submitting a civil rights complaint to the Environmental Protection Agency (EPA) against the Providence Water Supply Board (Providence Water), pursuant to the Civil Rights Act of 1964.

The administrative complaint highlights the discriminatory effects that can result when utilities require customers to share the cost of replacing the lead pipes that feed into their homes. The complaint was submitted as part of CLAP’s larger Lead-Free Water RI campaign, which calls “for an equitable, statewide plan for full, free lead pipe replacements for all Rhode Islanders.”

In the complaint, CLAP, South Providence Neighborhood Association, Direct Action for Rights and Equality, National Center for Healthy Housing, and EDF allege that the water utility’s process of replacing lead service lines (LSLs) — the lead pipes that run from the water main to the water meter in homes — has a disparate impact on Black, Latinx, and Native American residents in violation of Title VI of the Civil Rights Act of 1964 and EPA’s implementing regulations. Read More »

Posted in Drinking water, Lead, Public health / Tagged , , , | Comments are closed

EPA’s Significant New Use Rules under TSCA must reflect its policy goals

Lauren Ellis, Research Analyst, Environmental Health 

We recently submitted comments to the Environmental Protection Agency (EPA) on a subset of proposed Significant New Use Rules (SNURs) published by the New Chemicals program under the Toxic Substances Control Act (TSCA). We commend EPA for issuing these proposed SNURs. Our review of some of the SNURs, however, raised concerns about chemical releases to the environment, risks to consumers, and the absence of worker protections. We believe EPA can address many of these concerns by following through on its stated policy goals. 

For all the chemicals in this batch, EPA had previously issued “consent orders” – which impose restrictions on a new chemical – because the agency found at the time of their initial review for market entry that the chemical substances may present an unreasonable risk to health or the environment. We strongly support EPA’s use of SNURs to follow up on consent orders it issues, as a consent order only applies to the original company that submitted a premanufacture notice (PMN) to EPA to domestically manufacture or import a new chemical. 

A SNUR is a separate action that requires any company seeking to engage in a “significant new use” identified in the SNUR to notify EPA at least 90 days before beginning that use, triggering EPA’s review of the potential new use. For new chemicals that received orders, a SNUR can conform to the order – meaning it mirrors the conditions in the consent order for the chemical – or it can apply more broadly to activities or uses that are beyond the scope of the consent order. Either way, SNURs enable the agency to review potentially risky uses prior to their commencement. 

In our comments, we call for four major changes to a subset of the proposed SNURs: 

Read More »

Posted in PFAS, TSCA reform / Tagged , , , | Comments are closed