EDF Health

TSCA And The East Palestine Ohio Train Derailment Are Related–Here’s How

Derailed train, leaking toxic chemicalsBy Maria Doa, PhD, Senior Director, Chemicals Policy, and Lauren Ellis, MPH, Research Analyst

What Happened:  We recently expressed concern to EPA about its conclusion that “distribution in commerce” (including the transportation of chemicals) does not contribute to the unreasonable risk for any of the first 10 chemicals evaluated under the Toxic Substances Control Act (TSCA). 

In response, EPA stated that exposures from the distribution of chemicals in commerce would be minimal “given the fact that these chemicals are transported according to existing hazardous materials transportation rules.” 

Why It Matters: EPA does not currently quantify exposures and risks from spills, leaks, and other releases from transportation incidents. But people can be—and are—exposed to toxic chemicals at all stages of the chemical lifecycle, from these incidents to chemical facility releases.

For example, last month, a Norfolk Southern freight train hauling several railcars carrying toxic chemicals derailed in East Palestine, Ohio. This is just the latest example of how accidents involving highly toxic chemicals can have harmful impacts—both short- and long-term—on communities’ health and welfare.

The Ohio train derailment not only put several surrounding communities at risk of chemical pollution and negative health outcomes, but also highlighted the connection between TSCA and the risks of toxic chemicals from transportation accidents.

 

What’s Next: To accurately assess chemical risk under TSCA, EPA should consider data on spills, leaks, and releases from derailments, collisions, and other transportation incidents in its risk evaluations. These releases and exposures simply cannot be ignored.

By expanding evaluations to include the risks of chemicals at all stages of the chemical lifecycle, EPA can better protect communities.

Go Deeper: Visit our Deep Dives blog for a more in-depth analysis of this issue. 

Posted in Deep Dives, Public health, TSCA / Read 2 Responses

Unleading Baby Food: FDA’s proposed limits are a positive step, but…

Tom Neltner, Senior Director, Safer Chemicals

What Happened: FDA recently released draft action levels for lead in foods intended for babies and young toddlers.1 Action levels represent the point above which FDA is likely to regard food as adulterated – essentially unsafe – and seek a recall. This is a key step in implementing FDA’s Closer to Zero Action Plan.

  • Lead limits would be 10 parts per billion (ppb) for most foods.
  • Limits would be 20 ppb for dry infant cereals and single-ingredient root vegetable products, because these products may have greater lead contamination levels. (Root vegetables are primarily carrots and sweet potatoes.)

The new action levels do not apply to juices; FDA proposed limits on those in April 2022.

Why It Matters: There is no safe level of lead in the diet.

For young children living in homes without lead pipes or lead paint, diet is the primary source of their lead exposure. FDA makes clear in the proposal that:

“Even low lead exposure can harm children’s health and development, specifically the brain and nervous system. Neurological effects of lead exposure during early childhood include learning disabilities, behavior difficulties, and lowered IQ. Lead exposures also may be associated with immunological, cardiovascular, renal, and reproductive and/or developmental effects. Because lead can accumulate in the body, even low-level chronic exposure can be hazardous over time.”

Lead can enter the food chain through multiple sources, including crops grown in contaminated soil and/or irrigated with contaminated water, atmospheric deposition from industrial activities, and old food-processing equipment that contains lead. The objective is to get exposure closer to zero.

Our Take: We applaud FDA’s proposed limits, which are more protective than the European Union’s 2021 standards. BUT…on the flip side:

  • FDA failed to set action levels for popular grain-based snacks, like teething biscuits and snack puffs. The agency needs to rectify this failure with all deliberate speed.
  • More protective action levels are achievable, especially for non-rice cereals and for foods that don’t contain rice or root vegetables.
  • Proposed action levels do not apply to multiple categories of foods, including:
  • FDA’s justification for the draft action levels lacks transparency—undermining both credibility of the levels and the likelihood industry will comply with them.

In addition, USDA and industry need to expand their support for research on the methods for growing, harvesting, and processing root vegetables, rice, and quinoa to further reduce lead contamination in these important foods. Research should include both store-bought and homemade baby foods.

Go Deeper: Visit our new Deep Dives blog to see our 3-part series, which provides a more detailed analysis of FDA’s proposal—including our recommendations for setting more protective limits and improving the transparency and credibility of the agency’s process of setting action levels.

NOTES
1 FDA’s guidance refers to babies and young children. Younger than two is a very narrow definition of young children, especially since children up to age six are particularly vulnerable to the harm that lead causes to their brains. Other federal agencies set standards for this broader age range. Toddlers are generally considered to be between 1 and 3 years of age. Therefore, we use the term “young toddlers” to avoid confusion.

Revised on March 21 to correct quote.

Posted in Deep Dives, FDA, Health policy, Health science, Public health, Unleaded Juice / Read 1 Response

Introducing Deep Dives—EDF’s New Platform for In-Depth Scientific & Policy Analyses on Environmental Health

What’s New? Today we’re launching a new digital channel for the die-hard science and policy wonks in our midst! Deep Dives is a new, long-form blog site that will offer readers in-depth scientific analyses, hard data, and practical policy prescriptions from our top environmental health experts. The authors are Environmental Defense Fund experts in air quality, chemistry, epidemiology, law, public health, and more.Illustration of a pink brain wearing glasses on a bright yellow background

Why It Matters: We have multiple audiences for our content—and data tell us they have very different information needs and preferences about format.

We are committed to giving everyone the information they want in the format they prefer—and that led us to create Deep Dives.

Here’s the Deal: On average, only about 5% of web visitors read to the bottom of any particular piece of internet content. That’s why we have moved this blog to short-form content that tells you what’s happening and why it’s important from the jump. We give you the gist, and we try to keep it under 500 words.

But we also have a specialized audience of scientists, policymakers and implementers, academics, and advocates who value the policy nuances and scientific details. The people in this group want the meaty content and all the details—and, if they are interested in the subject, they will read to the end of the post, no matter how long it is.

If that describes you, Deep Dives was conceived and created for you!

What’s Next? We may be creating a new space for the self-described geeks and wonks, but we’ll continue to give you the skinny here—and all visitors are welcome in both spaces! Be sure to subscribe to this blog to receive email notifications of new Deep Dives blogs.

Last one in is a rotten egg!


Illustration of two French bulldogs under water, wearing swimming goggles, surrounded by a colorful coral reef.

Welcome to our new Deep Divers!

Posted in Deep Dives, Health policy, Health science, Public health / Comments are closed

EPA Should Address Cumulative Risks from New Chemicals

Names of blog authors: Maria Doa, PhD, Sr. Director, Chemicals Policy, and Lariah Edwards, PhD, Associate Research Scientist, Columbia University

What’s Happening? EPA’s current safety assessments of new chemicals proposed for market entry often fall short of effectively protecting all members of the public from risk because they don’t consider that we may be exposed to closely related chemicals that cause similar harms.

Recent Example: EPA proposed rules requiring notification of significant new uses for a group of new chemicals. Two of these chemicals, known as trimellitate esters, are very closely related, and would be expected to cause very similar harms and have very similar uses—so that people exposed to one chemical would likely be exposed to the other. Despite this, EPA did not consider the chemicals together or even use the information it had on one to inform its understanding of the safety of the other.

This doesn’t make sense.

Even though EPA said that one chemical was intended to be used as a lubricant and the other as a plasticizer (a chemical that makes plastics more flexible), it is likely that both could be used as a plasticizer or a lubricant. They may be used together or turn up in similar consumer products, such as a car’s dashboard. Further, both chemicals are very closely related to yet another plasticizer used in the auto industry, but it appears that EPA considered these nearly interchangeable chemicals in isolation from one another.

Items that require plasticizers for production. They include seats in cars, rain boots, a garden hose, medical gloves, an exercise ball, and rolls of wallpaper.

In fact, under the Toxic Substances Control Act (TSCA), EPA is required to identify such “reasonably foreseen uses,” such as ending up in the same product.

Why It Matters: Evaluating chemicals in isolation likely underestimates the exposures and risks workers, consumers, and frontline communities face. Doing so also fails to make use of all the best available science, since information on each of these two chemicals (as well as the one already being used) could inform the safety determination for the other.

Considering the combined risks from similar chemicals is not new. EPA is already doing this for another group of closely related chemicals—phthalates. Phthalates have long been widely used in a range of consumer products and are detected in almost all our bodies. Phthalates are known to impact male reproductive health. EPA is joining the ranks of other federal agencies that have considered the cumulative risks they pose.

Our Take: EPA should not stop at phthalates. They can and should be incorporating cumulative approaches from the very beginning of a chemical’s regulatory life. Considering the impact of combined exposures does not need to be complicated and EPA could make such a consideration without much extra effort.

EPA can take a first step toward doing this by considering the potential for cumulative risks when finalizing its regulation on the significant new uses for these two new closely related chemicals.

Go Deeper: Read EDF’s response to EPA’s proposed new SNURs. And check out our Cumulative Risk Assessment Framework.

Posted in Environment, Health science, Industry influence, Public health, TSCA / Comments are closed

Denver Water proves its Lead Reduction Program is a national model

Tom Neltner, Senior Director, Safer Chemicals and Lindsay McCormick, Senior Manager, Safer Chemicals

What’s New: After an extensive review process, EPA approved Denver Water’s request to extend the variance to allow the utility to administer their Lead Reduction Program for the full 15-year term. EPA touts Denver Water’s Lead Reduction Program as an “innovative and aggressive approach” to lead service line replacement (LSL) in a letter approving the variance.

Denver Water will continue to:

  • replace all lead service lines at no cost to homeowners,
  • provide residents with filters to help reduce their exposure in the short-term, and
  • use an alternative approach to water treatment that still ensures effective corrosion control.

We applaud their emphasis on environmental justice and commitment to ensure that the program continues to prioritize disproportionately impacted neighborhoods – and EPA’s new requirement to track this progress.

This fall, we visited Denver Water’s field operations to see for ourselves how it is successfully replacing more than 4,500 lines per year. We were impressed by what we saw, and sent a letter to EPA’s Regional Administrator expressing our full support for Denver Water’s March 2022 request to continue their program. Read More »

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

Mapping Lead: Powerful tool helps communities find underground hazards

Roya Alkafaji, Manager, Healthy Communities and Tom Neltner, Senior Director, Safer Chemicals Initiative

We have all come to expect access to information at our fingertips. To meet this demand, water utilities are increasingly posting interactive maps online to help residents identify whether their homes are connected to lead service lines (LSLs).[1] These are the pipes that deliver water from the main under the street to homes and buildings. In homes built before 1986, this pipe could be made of lead.

With this information, people can:

  • Better assess their risk of lead exposure from drinking water and take steps to reduce possible exposure (e.g., water filters);
  • Make decisions when renting or purchasing a new home, and/or;
  • Demand that their water utility and community invest in effective LSL replacement programs to reduce harmful exposure to lead, particularly for children who are most vulnerable.

Given the importance and growing popularity of LSL maps, we are launching a new blog series, Mapping Lead, that will explore how utilities are approaching maps, evaluate which map features are most and least effective, and share best practices to help guide future efforts.

EPA recognized the value of interactive maps in its August 2022 guidance on developing service line inventories. The agency recommended utilities of all sizes consider making information available through interactive maps using commonly available tools, like GIS software. The guidance references EDF’s 2019 study for evidence of the power of these interactive maps and spotlights LSL replacement programs in Cincinnati and Denver as examples of best practices.[2]

We wholeheartedly agree with EPA’s recommendations. As a result of the agency’s guidance, we anticipate that the number of online maps is likely to grow dramatically as utilities meet an October 2024 deadline to make their inventory of service line materials publicly accessible to comply with EPA’s revised Lead and Copper Rule (LCR).

Top 100 Cities: Who Has Maps – And Who Doesn’t

We identified over 50 interactive LSL maps that utilities have made publicly available to residents across the United States. Looking at the utilities that serve the 100 largest cities in the country, we found that 15 have LSL maps—a positive step that leverages existing asset-management tools such as GIS, while increasing public transparency. Together, these 15 utilities provide drinking water to more than 16 million people.

Throughout this blog series we’ll take a closer look at maps; in some cases, we’ll be critical of those that don’t meet the criteria for an effective map. Nonetheless, we recognize these utilities have taken a step in the right direction and should be applauded for their efforts.

We discovered that 12 large utilities were notably absent from the list of those with online maps. Given their size and location, these utilities presumably have LSLs in their distribution areas and the in-house resources to develop effective maps. We hope that by shining a light on the cities that are leading the way and addressing the contrast with those cities without maps, we can help spur action so residents of large cities served by these utilities will have access to this crucial information. For a list of the 12 utilities without maps and 15 with maps, see the tables below. We’ll continue to revise these lists as more large cities publish interactive maps online.

By the Numbers

It’s important to understand the broader landscape as we track cities that are choosing interactive maps as a key tool for communicating about LSLs to the public. Using estimates from EPA’s Regulatory Impact Analysis for the revised LCR, the figure below shows the number of community water systems that fall under the purview of the LCR and subsequent requirements based on presence of LSLs and population served.

By October 2024, more than 50,000 utilities[3] will either submit an initial service line inventory or demonstrate the absence of LSLs in their distribution area.[4] EPA estimates that more than 12,000 utilities will find LSLs and thus will be required to make their inventory publicly accessible; those that serve over 50,000 people will also be required to post the inventory online.

More to Come

Follow along as we explore interactive maps and the role they play in LSL replacement.

Utilities Serving Top 100 Largest Cities With Online Interactive Maps

UtilityPopulation Served†Estimated # of LSLs‡
New York City, New York (Map)8.3 million360,000
Boston, Massachusetts (Map)2.6 million3,900**
Denver, Colorado (Map)1.4 million64,000**
Columbus, Ohio (Map)1.3 million28,000*
Seattle, Washington (Map)956,0002,000*
San Francisco, California (Map)884,0001,600*
Cincinnati, Ohio (Map)750,00040,000
Memphis, Tennessee (Map)700,00014,000*
Tucson, Arizona (Map)675,000600
Washington, D.C. (Map)632,00042,000**
Pittsburgh, Pennsylvania (Map)520,00016,000**
Toledo, Ohio (Map)480,00030,000**
St. Paul, Minnesota (Map)400,00027,000
Newark, New Jersey (Map)295,00024,000**
Jersey City, New Jersey (Map)262,00016,000
*Map and/or estimated number of LSLs reflects public side only.
**Active or completed LSL replacement program. The number listed reflects the estimated number of LSLs prior to the start of the program.
†Source is SDWIS, 2022.
‡Source available upon request.

 

Select Utilities Serving Top 100 Largest Cities That Lacked Online Interactive Maps

UtilityPopulation Served†Estimated # of LSLs‡
Chicago, Illinois2.7 million380,000
Baltimore, Maryland1.6 millionNot reported
Philadelphia, Pennsylvania1.6 million20,000
Cleveland, Ohio1.3 million200,000
Charlotte, North Carolina1.1 millionNot reported
Indianapolis, Indiana (Citizens Energy – Water)837,00055,000-75,000
Nashville, Tennessee722,000Unknown
Detroit, Michigan714,00080,000
Milwaukee, Wisconsin590,00066,000
Omaha, Nebraska554,00016,000-17,000
Minneapolis, Minnesota424,00049,000
New Orleans, Louisiana291,000Unknown
†Source is SDWIS, 2022.
‡Source available upon request.

 

[1] For this blog series, LSLs includes service lines that are “galvanized requiring replacement” per 40 CFR § 141.2.

[2] See Section 7.2 of EPA’s service line inventory guidance.

[3] For purposes of this blog series, community water suppliers as defined by EPA are referred to as utilities.

[4] Per 40 CFR 141.84(4), CWSs must categorize each service line, or portion of the service line where ownership is split, as lead, galvanized requiring replacement, non-lead, or lead status unknown. In order to declare that the system only contains non-lead service lines, this must be “determined through an evidence-based record, method, or technique.”

 

Revised May 2, 2023 to update blog series title and link.

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