EDF Health

Selected tag(s): cumulative exposure

EDF outlines steps for EPA to strengthen its plan to assess risks to frontline communities

By / Published: March 24, 2022

Maria Doa, Senior Director, Chemicals Policy

This week Environmental Defense Fund (EDF) filed comments on EPA’s plan to assess the risks to frontline communities from nearby releases of chemicals to the air and water. The EPA’s proposal is an improvement from the previous administration, which failed to follow the requirements of the Toxic Substances Control Act (TSCA) and consider air and water releases and other significant exposure pathways for residents in “fenceline” communities near manufacturing or disposal facilities.

As we made clear in our comments, however, the agency’s planned screening approach is too narrow in scope and would underestimate the real-world risks faced by many communities.

Residents of these frontline communities often face exposure from multiple sources or higher levels of exposure than the general population, or both combined. Failing to consider the full scope of these risks could hamper EPA’s ability to craft protective rules that reduce the risks those living near industrial facilities.

We outline several areas where EPA can strengthen its screening approach Read More »

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EPA can incorporate cumulative impacts in its chemical assessments right now

By / Published: March 8, 2022

By Maria Doa, Senior Director, Chemicals Policy, and Lariah Edwards, Ph.D., EDF-George Washington University Postdoctoral Fellow

EPA recently asked its Science Advisory Board to provide advice on how it can incorporate cumulative impact assessments into its decisions making and on research to support cumulative impact assessments. At a public meeting of the SAB on March 2, we highlighted several areas where EPA can incorporate cumulative impact assessments right now.

Cumulative impacts refer to the total burden from chemical and non-chemical stressors and their effect on health, well-being, and quality of life. EPA asked the SAB for advice in two areas: First, what research should the agency conduct to strengthen the methods used in cumulative impact assessments. Second, and somewhat more important, how can EPA start now to incorporate cumulative impact assessments into its decision-making using data that is currently available.

People living in communities are often exposed to multiple chemical and non-chemical stressors. When individuals are exposed to multiple chemicals that cause a particular type of harm, they do not experience the risks for each chemical separately from the other. Nor are these chemical burdens experienced in isolation from other non-chemical stressors a person may face, like nutritional deficiencies or psychosocial stress. Cumulative impact assessments consider the combination and impact of both types of stressors, and therefore are more reflective of real-life conditions.

EPA assessments and decision making should take into consideration this reality and move away as much as possible from the status quo of evaluating one source, one chemical, and one environmental medium. Read More »

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Restoring the credibility of risk assessment: A vital need under TSCA reform

By / Published: April 6, 2012

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

The primary means by which chemical risks are to be judged under current legislative proposals for reform of the Toxic Substances Control Act (TSCA), including the Safe Chemicals Act of 2011 (S. 847), is through risk assessment – a key demand of industry.  Yet traditional risk assessments have often fallen short of protecting public health and have sometimes taken decades to identify a “safe” level of exposure to certain chemicals.  As a result, public and health and environmental community confidence in risk assessment is very low.  There are also major technical deficiencies in current risk assessment methodologies that must be addressed if it is to serve as a credible basis for determining chemical risks.  For example, we now know that there are many chemicals for which any level of exposure poses some risk, yet traditional risk assessment assumes a safe level exists for nearly all chemicals.

The Safe Chemicals Act includes provisions to ensure that EPA’s use of risk assessment incorporates the best available science, initially by requiring EPA to rely on the recent recommendations of the nation’s foremost scientific body, the National Academy of Sciences, as to how EPA can improve its practice of risk assessment. Implementing the recommendations is critical to restoring the credibility of and public confidence in risk assessment. Read More »

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Pediatricians: Reform TSCA to protect kids. ACC responds (a la W.C. Fields): We love kids, too

By / Published: April 26, 2011

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

A long-awaited and full-throated endorsement of comprehensive reform of the Toxic Substances Control Act (TSCA) from the venerable American Academy of Pediatricians (AAP) was published online yesterday in the journal Pediatrics.

Right down the line, the AAP’s 8-page policy statement calling for a wholesale overhaul of TSCA mirrors the recommendations of health and environmental advocates, academic researchers and just about anyone else who has paid attention to the mounting body of evidence documenting the linkages between rising chemical exposures and adverse effects on the health of our population, especially the most vulnerable among us:  the developing fetus, infants and young children.

The AAP’s recommendations also closely track key provisions in TSCA reform bills introduced last year in both Houses of Congress as well as the Safe Chemicals Act of 2011 just re-introduced in the U.S. Senate this month.

This latest statement from the Academy adds it to the list of other major medical and health associations that have previously called on Congress to  revamp TSCA, including the American Medical Association, the American Public Health Association and the American Nurses Association.

Given this growing chorus, it is perhaps not surprising that the American Chemistry Council (ACC) would seek to worm its way in to claim that it, too, loves kids and supports TSCA reform.

But dig a bit deeper, and what is most striking is that ACC stridently opposes essentially every element of TSCA reform called for by the American Academy of Pediatrics.  Read More »

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ACC endorses cumulative impact assessment for all TSCA regulations!

By / Published: March 14, 2011

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

In what seemed a startling move, the American Chemistry Council (ACC) last week gave testimony at a Congressional hearing that included a full-throated endorsement of mandating that EPA be required to assess cumulative impacts when developing regulations addressing chemicals under the Toxic Substances Control Act (TSCA).

The call for cumulative impact assessment was a contentious element in last year’s debate over the safety standard that would apply to chemicals under a reformed TSCA.  Reform advocates supported assessing such impacts where the science allows, while ACC had staunchly opposed the concept.  The need to account for cumulative impacts is also a key recommendation of the National Academy of Sciences, in its recent reports Science and Decisions:  Advancing Risk Assessment (2009) and Phthalates and Cumulative Risk Assessment:  The Tasks Ahead (2008).

Ah, but the devil is indeed in the details:  ACC’s apparent change of heart is no such thing.  Rather, ACC is endorsing a step that would make it even harder for EPA to act to control dangerous chemicals under TSCA, namely that the agency would have to consider the cumulative impact of all prior regulations affecting a given industry before it could propose a  new one.  Read More »

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New study demands far more than a pregnant pause: Expectant women carry dozens of toxic chemicals in their bodies

By / Published: January 14, 2011

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

A long-awaited study documenting the presence of multiple toxic chemicals in the bodies of pregnant women was published today in Environmental Health Perspectives.  The study, conducted by researchers at Program on Reproductive Health and the Environment at the University of California, San Francisco, analyzed the most recent comprehensive biomonitoring data collected by the Centers for Disease Control (CDC) as part of its national human biomonitoring program.

The new study found widespread exposure of pregnant women to a large fraction of the chemicals for which biomonitoring is conducted, including chemicals that are currently in widespread use, such as brominated flame retardants (known as PBDEs) used in furniture foam and plastics, perfluorinated chemicals (PFCs) used in everything from packaging to textiles, and a pervasive environmental contaminant used in rocket fuel (perchlorate).

In particular the study noted:  “Certain PCBs, organochlorine pesticides, PFCs, phenols, PBDEs, phthalates, polycyclic aromatic hydrocarbons (PAHs) and perchlorate were detected in 99 to 100% of pregnant women.” (emphasis added)  Read More »

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