EDF Health

ASDWA provides new recommendations to states and utilities for lead service line inventories

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: September 29, 2020

Tom Neltner, J.D., Chemicals Policy Director

The Association of State Drinking Water Administrators (ASDWA) released a new white paper to help states and utilities develop more useful inventories of lead service lines (LSLs). The paper builds on guidance the organization issued in August 2019. ASDWA partnered with BlueConduit to leverage that firm’s experience developing a statistical model for Flint, Michigan that accurately predicted which service lines were made of lead, galvanized steel, plastic or copper.

The guidance is timely as EPA prepares to finalize its Lead and Copper Rule revisions. We anticipate those revisions will require utilities to develop – and make public – inventories that identify the location of each service line made of lead or when the material is unknown and may be lead. Utilities would also be required to notify customers annually if they have a lead or unknown service line. Customers who buy a home and open a new water account would also be notified in the first bill.

The ASDWA/BlueConduit white paper encourages utilities to use five principles to best characterize the uncertainty in their inventories:

  1. Ensuring clean data management and organization;
  2. Not accepting all historical records as truth;
  3. Conducting a representative randomized sample of unverified service lines;
  4. Being transparent in public outreach and reproducibility; and
  5. Demonstrating accuracy on “hold-out sample.”

Read More »

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

New study: Lead reduction prevented up to 99,000 heart disease deaths in 2014 alone

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: September 28, 2020

Tom Neltner, J.D., Chemicals Policy Director

[pullquote]EPA needs to estimate reduced heart disease deaths when it evaluates the merits of four upcoming rules addressing lead in water, paint, and air.[/pullquote]

In 2018, we blogged on a study by Lanphear et al. that linked adult blood lead to a jaw-dropping 400,000 heart disease deaths annually. We called on federal regulatory agencies to give serious consideration to this and similar studies to develop a model they can use to quantify the socioeconomic benefits of potential regulatory changes designed to reduce adult exposure to lead. In June, 2019, the Environmental Protection Agency (EPA) successfully completed the necessary peer review of a model. The review was completed too late to be incorporated into the agency’s proposed revisions to its Lead and Copper Rule (released October 2019), but we applied the analysis to estimate that replacing all lead service lines in the nation over ten years would provide societal benefits of more than $205 billion – and called on EPA to consider the benefits when finalizing the rule.

Last week, Abt Associates, EPA’s contractor[1] who developed the initial peer-reviewed model, published a refined model in Environmental Health Perspectives and used it to estimate that between 34,000 and 99,000 cardiovascular disease (CVD)-related deaths were avoided in 2014 due to reduced adult blood lead levels from 1999 to 2014. The analysis reports that between 16% and 46% of the overall reduced CVD deaths during those 15 years was attributable to reduced lead in adult blood. Read More »

Posted in Emerging science, Lead / Tagged | Comments are closed

FDA’s Failure on Food Chemical Safety Leaves Consumers at Risk of Chronic Diseases

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: September 23, 2020

Tom Neltner, J.D., Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant

Update: FDA published the citizen petition upon receipt on 9/23, and is requesting public comment.

More than 60 years ago, Congress enacted legislation requiring the Food and Drug Administration (FDA) and the food industry to evaluate the cumulative effects of substances in the diet that have related health impacts when assessing the safety of chemical additives. In our decade of analyzing FDA and industry actions, we have been increasingly concerned that both have ignored this requirement. To figure it out, we investigated all safety determinations contained in Generally Recognized as Safe (GRAS) notifications voluntarily submitted by food manufacturers to FDA since the program began in 1997. We looked at GRAS notices because they are publicly available and because FDA rules explicitly require that food manufacturers include in the notice an explanation of how they considered the requirement. If there was an omission, it would be more easily noticeable.

We found that in only one of 877 GRAS notices did a food manufacturer consider the cumulative effect requirement in a meaningful way. And we found no evidence that the agency either recognized this single attempt to follow the law or had objected to the omissions in the 876 other notices. This failure has significant consequences for public health, particularly for communities who already face significant health and socio-economic disparities, and for children, who are uniquely susceptible to dietary exposures to multiple chemicals.

For this reason, EDF joined with other health, environmental, and consumer groups to file a formal petition to demand FDA and food manufacturers start following the law. The petition requests specific changes to rules designed to reinforce the existing requirement and make it easier to verify compliance. Still, given the lack of transparency in agency reviews, success still largely depends on FDA and the food industry taking seriously the mandate and the food safety implications.

Read More »

Posted in FDA, Food, Public health / Tagged , , , | Comments are closed

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

By / 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 »

Posted in Health policy, Regulation, TSCA reform / Tagged , , | Read 1 Response

Breathing wildfire smoke: A scientist mom’s concerns

By Maria Harris / Published: September 2, 2020

This post originally appeared on EDF Voices. 

Maria Harris is an Environmental Epidemiologist.

Downtown Oakland, CA skyline obscured by wildfire smoke. Aug. 22, 2020 Photo by Jose Carlos Fajardo, Getty Images.

If the risks, hardships and anxiety of life during a pandemic were not enough, my fellow northern Californians are now facing another health crisis.

As I write this, hundreds of wildfires are burning across the state, among them two of the largest ever in California. Together, the fires have burned more than 1.4 million acres, destroyed 2,800 homes and buildings, killed eight people and forced thousands to evacuate their homes.

On top of the acute risks to lives and homes, residents across the state are suffering from highly polluted air as massive plumes of smoke fill the skies above our homes.

Children, seniors and those with lung disease are especially vulnerable

As a mom of two young kids, it’s been a tough couple weeks of anxiously monitoring air quality data and maps to determine if and when it might be safe to go outside, while seeking information on how to keep my family healthy.

As an environmental health scientist, I know that wildfire smoke has been linked to a range of negative health impacts, including asthma exacerbation, which can lead to emergency room visits and hospitalizations, along with increased rates of heart attacks and even death. Children and pregnant women, as well as those with heart disease or respiratory conditions like asthma, are particularly vulnerable to the health impacts of wildfire smoke.

Read More »

Posted in Air pollution, Extreme weather / Tagged , , | Comments are closed

What the heck is going on with EPA’s risk evaluation fees under TSCA?

By / Published: August 31, 2020

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

What a mess.  That’s the best that can be said from the outside about the process EPA has followed to decide which companies are to pay fees to help defray the agency’s costs of conducting risk evaluations for the next 20 chemicals under the Toxic Substances Control Act (TSCA).[pullquote]EPA’s steps to endanger its ability to collect the fees under TSCA that Congress mandated border on self-sabotage.[/pullquote]

These fees were set forth in EPA’s final TSCA fees rule issued in October 2018.  The total fee assigned to each of the next 20 chemicals for which risk evaluations are now underway was set at $1.35 million.  That fee is to be paid by manufacturers (including importers) of a chemical.  TSCA provided EPA with authority to charge processors of these chemicals a fee as well, but the agency opted to exclude processors from such fees in its final rule (see p. 52,696).  EPA also opted not to charge fees to cover any of the costs it incurred for the first 10 risk evaluations (see p. 52,708 of the fees rule), although it had authority to do so.

Last week EPA issued what it calls its “interim final list” of companies obligated to pay fees to cover the costs of the next 20 risk evaluations.  The list is dramatically scaled-back from the agency’s earlier list, and it is impossible for the public to understand the basis for the changes.  That is in no small part due to the convoluted, opaque, and legally suspect process EPA has followed.  Read More »

Posted in Health policy, Industry influence, TSCA reform / Tagged , , | Comments are closed