EDF Health

Re-visioning TSCA: Address the cumulative impacts of chemical exposures

By / Published: April 1, 2021

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

Part 4 of a 4-part series – see Part 1, Part 2, and Part 3 here

This series of blog posts is looking ahead toward opportunities to advance a more robust and holistic vision for implementing the Toxic Substances Control Act (TSCA) as reformed in 2016.

We discussed in the preceding installments of this series the importance of ensuring that combined exposures to a chemical from multiple sources and the greater exposures and susceptibilities of certain groups are accounted for.  But it is critical to also recognize that many other factors influence the impacts chemical exposures have on our health.  This final installment in our series will discuss how TSCA can and should take into account all of these factors – that is, account for cumulative impacts.

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

FDA takes an important step by phasing out paper greaseproofing agents containing a specific PFAS

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: August 4, 2020

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

Last week, the Food and Drug Administration (FDA) announced the phase-out of per- and polyfluorinated alkyl substances (PFAS) used to greaseproof paper and paperboard food packaging made from a specific type of short-chain PFAS known as 6:2 fluorotelomer alcohol (6:2 FTOH).  The action, narrow as it is, is welcome news for efforts to protect public health and the environment from the risks posed by short chain PFAS, known as “forever chemicals” because they do not degrade.

FDA secured voluntary agreements with three companies, Archroma, Asahi Glass, and Daikin, to phase-out products based on 6:2 FTOH. A fourth company, Chemours, asked FDA to suspend the agency’s approvals on its products containing the PFAS one year ago. The action affects 15 food contact substance notifications (FCN) approved by the agency between 2006 and 2016. It does not address 13 FCNs for similar greaseproofing uses made from PFAS other than 6:2 FTOH. And, under the agreement, consumers may still find 6:2 FTOH-laden, carry-out containers until June 2025.

The process FDA took, and the time it took to get there, reveals the significant difficulties the agency has in reversing past actions in the face of mounting evidence of a chemical’s risk:

  • FDA must seek out information because companies have no obligation to affirmatively notify the agency of new studies showing potential problems;
  • When FDA finds the information and identifies potential safety concerns, it appears to act as if it has the burden of proving the use is no longer safe; and
  • FDA continued approving uses of 6:2 FTOH even after it identified problematic data gaps.

These difficulties reinforce the need for actions being taken by states such as Washington, Maine, New York, and California, by Congress, and by retailers to reduce uses of PFAS in their products. When it comes to food packaging, PFAS are dinosaurs and their time is running out.

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

Think PFAS in food packaging are safe simply because FDA accepted their use? Think again.

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 13, 2019

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

[pullquote]

PFAS manufacturers’ claims that the agency demands scientific data, including toxicity and exposure, and conducts a rigorous review before allowing the use of the chemicals in contact with food are not accurate.

[/pullquote]Per- and poly-fluorinated alkyl substances (PFAS)—recently dubbed “forever chemicals”—have received a large amount of national attention, mostly due to contamination of drinking water affecting millions of Americans. Since June 2019, when the U.S. Food and Drug Administration (FDA) released its testing results from three studies, questions have arisen about food as a source of PFAS exposure. The main routes by which PFAS enter the food supply are environmental contamination—such as from nearby chemical manufacturing facilities, airports or Department of Defense operations—and from food packaging and processing equipment.

With greater attention on PFAS in food, we’ve noticed several misleading PFAS manufacturers’ talking points asserting that FDA review and acceptance is required for any PFAS to be used in contact with food, and that, due to this review, PFAS that go through this process are safe. However, their claims that the agency demands scientific data, including toxicity and exposure, and conducts a rigorous review before allowing the use of the chemicals in contact with food are not accurate.

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Posted in FDA, Food, GRAS, PFAS / Tagged , , | Read 1 Response

The Trump EPA is setting back chemicals policies by decades

By / Published: June 13, 2019

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


Tacoma, WA 1972

As we approach the third anniversary of the historic passage of bipartisan legislation to overhaul our nation’s broken chemical safety system, we’re hearing that political appointees at the agency are gearing up to celebrate their “successes” in implementing the law.[pullquote]Even more disturbing than its individual actions are the methodical steps the Trump EPA is taking to dismantle decades of progress in our country’s chemicals policies.[/pullquote]

While the chemical industry may well have things to celebrate, it’s simply not the case for the rest of us:  Comments from former top EPA officials, members of Congress, state and local governments, labor groups, firefighters, water utilities, public health groups, and a broad range of environmental groups make crystal clear that there’s nothing warranting celebration.  EPA’s actions are threatening the health of American families.

But as I reflect on how implementation of the Toxic Substances Control Act (TSCA) has gone off the rails under the Trump EPA, even more disturbing than its individual actions are the methodical steps it is taking to dismantle decades of progress in our country’s chemicals policies.  In this post, I’ll briefly highlight five such policies and how this EPA is undermining them:

  • Pollution prevention
  • Inherent safety and hazard reduction
  • Protection of vulnerable subpopulations and environmental justice
  • Holistic, real-world risk assessment
  • Public right to know

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Posted in Health policy, Industry influence, Regulation, TSCA reform, Worker safety / Tagged , , , , | Read 2 Responses

Toxic chemicals can enter food through packaging. We made a list.

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: March 26, 2019

Boma Brown-West, Senior Manager, Tom Neltner, Chemicals Policy Director, and Michelle Harvey, Consultant.

This is the second in a series evaluating the challenges in single-use food packaging waste.

[pullquote]See our list of key chemicals of concern in food packaging.[/pullquote]In the late 1980s, the Council of Northeast Governors (CONEG) was concerned that heavy metals in packaging would accumulate in recycled materials to levels that presented serious health concerns. The organization drafted model legislation that prohibited the intentional addition of mercury, lead, cadmium, and hexavalent chromium to any component of packaging, including inks. It also set a 100 parts-per-million limit on the total amount of these four heavy metals. To ensure compliance, companies making packaging materials had to provide certificates of compliance to downstream purchasers and report compliance to the states.

CONEG also established the Toxics in Packaging Clearinghouse to maintain the model legislation, coordinate implementation of state legislation, and serve as a resource for companies seeking compliance information. The Council’s hypothesis: protecting virgin material from contamination will improve the recyclability of post-consumer materials and protect public health.

Over the years, 19 states have adopted a variation of the model legislation.  In 2018, the State of Washington took an unprecedented step of expanding its version of the legislation from heavy metals to include per- and poly-fluorinated alkyl substances (PFAS). PFAS are bioaccumulating, persistent chemicals and are associated with an array of health problems including endocrine disruption and children’s developmental harm. The State was concerned that paper and cardboard food packaging treated with these chemicals may be contaminating composting and paper recycling processes post-consumer.

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Posted in FDA, Food / Tagged , , | Authors: / Read 1 Response

A gap remains in the circular economy conversation: Toxic chemicals in packaging

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: February 27, 2019

Boma Brown-West, Senior Manager, Tom Neltner, Chemicals Policy Director, and Michelle Harvey, Consultant.

This is the first blog in a series evaluating the challenges associated with single-use food packaging waste.

This week Walmart joined a growing number of companies that are trying to advance the circular economy for packaging. Like previous commitments from Nestle, Coca-Cola and McDonald’s, Walmart is stepping up its efforts to use more recyclable packaging, incorporate more recycled content, and accelerate development of collection and recycling infrastructures. EDF has a long history fighting for greater and smarter plastics recycling, so we are pleased to see more companies working to eliminate plastic packaging waste from our environment. However, something is often missing from their statements: commitments for safer packaging free of toxic chemicals.

What defines safer packaging?

There are many facets to sustainable packaging: recyclability, reusability, lower material and energy inputs, and the avoidance of toxic chemicals.  A significant amount of virgin plastic used in packaging currently contains toxic chemical additives such as ortho-phthalates or contaminants such as heavy metals. These chemicals have been linked to diseases and health disorders, such as reproductive problems and impaired brain development. When tainted plastic packaging is reused or recycled, these toxic chemicals persist and may accumulate to worrisome levels until the packaging is retired, posing long-term threats to our health.

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