EDF Health

EDF submits comments for peer reviewers on EPA’s exposure, use and hazard information on five PBT chemicals

By Lindsay McCormick / Published: July 24, 2018

Lindsay McCormick, is a Project Manager. Richard Denison, Ph.D., is a Lead Senior Scientist.

Yesterday, EDF filed comments on several draft EPA documents that are part of the basis for developing restrictions EPA is required to impose on five persistent, bioaccumulative and toxic (PBT) chemicals under the 2016 reforms made to the Toxic Substances Control Act (TSCA).  The draft documents are to undergo peer review, and EDF’s comments raise issues we believe peer reviewers need to pay particular attention to.

As required by TSCA section 6(h), EPA last year identified five PBT chemicals (DecaBDE, HCBD, PCTP, PIP (3:1), and 2,4,6 TTBP) that meet the statutory criteria for “expedited action”: By June 22, 2019, EPA must propose a rule to restrict these five chemicals.  Last month, EPA released draft documents for peer review and public comment that summarize available hazard information and assess exposure and use of each of the five PBTs.

Our main points for consideration for the peer review committee are summarized below: Read More »

Posted in TSCA reform / Tagged , | Authors: / Comments are closed

American Academy of Pediatrics calls for “urgently needed reforms” to fix broken food additive regulatory system

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: July 23, 2018

Tom Neltner, J.D. is Chemicals Policy Director

Today, the American Academy of Pediatrics (AAP) released a “Food Additives and Child Health” policy statement calling for “urgently needed reforms to the current regulatory process at the US Food and Drug Administration (FDA) for food additives.” The policy applies to chemicals deliberately added to food or to food packaging or food processing equipment that get into food. These substances are used to flavor, color, preserve, package, process and store our food, but many never appear among the list of ingredients. AAP’s statement calls specifically for the following:

  • “Greatly strengthening or replacing the GRAS [Generally Recognized as Safe] determination process;
  • Updating the scientific foundation of the FDA’s safety assessment program;
  • Retesting all previously approved chemicals; and
  • Labeling direct additives with limited or no toxicity data.”

EDF applauds AAP’s policy statement and its decision to add its influential voice to the rising call for reform of the process by which FDA and food manufacturers decide additives are safe. AAP, a professional society representing 67,000 pediatricians, develops policy statements regarding federal, state, and community policies that affect children through an extensive, deliberative process that draws on tremendous scientific expertise. As with past policies, such as those concerning lead toxicity and fruit juice consumption, this statement on chemicals in food presents a well-reasoned assessment of the problem and clear recommendations for reform.

Read More »

Posted in FDA, Food, GRAS, Health policy, Health science, Perchlorate, PFAS, Public health / Tagged , , , , , , , | Comments are closed

EPA undermines its own proposal for more protective dust-lead hazard standards

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: July 18, 2018

Tom Neltner, J.D., is Chemicals Policy Director

On July 2, 2018, in response to a court order, the Environmental Protection Agency (EPA) published a proposed rule[1] tightening its standards for lead in dust on floors and window sills for housing and child-occupied facilities built before 1978. The agency declined to lower the standard for lead in paint – citing insufficient information – and did not consider tightening the standards for lead in soil. While the proposed rule is a tentative step forward for lead poisoning prevention, as explained below, it will create unnecessary confusion and falls far short of what the science and the law demands. Comments are due by August 16, 2018. Pursuant to an order from the Ninth Circuit Court of Appeals, EPA must finalize the rule by July 1, 2019.

Read More »

Posted in Health policy, Lead, Public health / Tagged , , , , | Comments are closed

Trump’s EPA pivots yet again on reviews of new chemicals under TSCA, leaving public and worker health in the dust

By / Published: July 17, 2018

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

EDF has learned from multiple sources that political appointees at the Environmental Protection Agency (EPA) are on the verge of taking yet another huge lurch away from what the 2016 reforms to the Toxic Substances Control Act (TSCA) require when EPA reviews the safety of new chemicals prior to their market entry.  A reporter at Bloomberg Environment has heard the same thing, and published an article this morning on some of the changes.

The Trump EPA apparently intends to abandon its November 2017 “New Chemicals Decision-Making Framework,” which already strayed far from the law’s requirements.  That approach would have allowed EPA staff to limit their review of a new chemical only to the intended uses identified by its manufacturer, despite the law’s clear mandate that EPA consider known or reasonably foreseen, as well as intended, uses when conducting its review.  Under the framework, where EPA had concerns about reasonably foreseen but not intended uses – rather than issue an order as required by the law – EPA would take two other steps:  make a “not likely to present an unreasonable risk” determination for the chemical, clearing it to enter commerce; and issue a Significant New Use Rule (SNUR), which could trigger a separate, future review on any subsequently intended use, wholly divorced from the initial review.

Initially, EPA staff indicated the “not likely” finding would be made only once a final SNUR had been promulgated.  That then slipped to have issuance of the finding coincide with the proposal of the SNUR.  That then slipped further to allow the finding to be issued based on EPA’s mere intent to develop a SNUR.

Now, however, the Trump EPA plans to decouple completely its ability to issue a “not likely” finding from any dependency at all on promulgation of a SNUR.  How then, you might well ask, would EPA consider reasonably foreseen uses of a new chemical?  The short answer is, it won’t.   Read More »

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

Developing accurate lead service line inventories and making them public: Essential tasks

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: July 17, 2018

Tom Neltner, Lindsay McCormick, and Audrey McIntosh

This blog is the first in a series focused on how states are handling the essential task of developing inventories of lead service lines (LSLs) and making them public.

Most communities have a general sense of how many lead service lines (LSLs) they have and what neighborhoods have them. The utilities that manage these community water systems (CWSs) base their estimates on installation and maintenance records, size and age of the service line, and professional experience supplemented with field investigations. It is the 80:20 rule in action; most utilities know enough to scope out the problem, develop a strategy, and set broad priorities.

Utilities hesitate when they are expected to provide precise numbers or say with confidence whether a specific address has or does not have a LSL. It is especially difficult for older neighborhoods where records are particularly weak and there are long histories of repairs.

It takes leadership for utilities to share what they know – and don’t know – about LSLs with their customers and the public. They need to be prepared for questions, including why they don’t know more and what they plan to do to remove the lead pipes. Sharing the information with state regulators and the Environmental Protection Agency (EPA) brings additional scrutiny, especially if they claim they have zero LSLs.

For these reasons, EDF applauds leaders such as Boston, MA; Washington, DC; Cincinnati, OH; Columbus, OH; Evanston, IL; Providence, RI; and Pittsburgh, PA that have address-specific maps available online showing what is known and not known about each customer’s service line. We encourage you to check out their maps. In the coming months, we will share a study EDF recently conducted that evaluates consumer reactions to various approaches to online maps to help guide communities planning similar efforts.

An accurate, publicly-accessible inventory of LSLs was a key element of the National Drinking Water Advisory Council’s (NDWAC) recommendations to EPA in December 2015 for its overdue revisions to the Lead and Copper Rule (LCR).[1] Two months later, EPA sent letters to each governor and state environment/public health commissioner asking, as one of five near-term actions, that they:

Read More »

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

EDF Calls on EPA to Withdraw Censored Science Proposal

By EDF Blogs / Published: July 17, 2018

Experts for Environmental Defense Fund (EDF) called on the Environmental Protection Agency (EPA) today to withdraw the “censored science” proposal – a proposed rule that would bar the agency from considering some of our most important public health studies in making decisions about vital protections for human health and the environment.

EPA held an all-day public hearing on its proposal at its Washington, D.C. headquarters today. EDF Senior Health Scientist Jennifer McPartland was among the more than 100 Americans who were expected to testify.

“EPA’s proposed rule represents a total disregard for the agency’s core mission: protection of human health and the environment,” said McPartland in her testimony. “If finalized the rule will erode critical public health protections, and with them, the scientific integrity and public trust of the agency.”

Read More »

Posted in Health policy, Health science, Industry influence, Public health / Tagged , , | Comments are closed