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

Yesterday Environmental Defense Fund (EDF) filed more than 100 pages of comments on a 40-page draft risk evaluation the Trump Administration’s Environmental Protection Agency (EPA) has prepared for Pigment Violet 29 (PV29).  PV29 is the first of 10 chemicals undergoing risk evaluations under the Toxic Substances Control Act (TSCA).  Our comments were so much longer than the EPA document we were commenting on because there was far more to say about what information EPA failed to obtain, make available or consider than what EPA included in its draft.

The essence of our lengthy comments can be boiled down to a single sentence, however:  EPA has utterly failed to demonstrate that PV29 does not present unreasonable risk of injury to health or the environment.

For folks who want somewhat more detail than this, our comments start with a 4-page Executive Summary that capsulizes the many serious deficiencies we identified in EPA’s draft.  I’ll provide some highlights in this post.   Read More »

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

I’ve been blogging about the deep problems surrounding the first draft risk evaluation the Trump Administration’s Environmental Protection Agency (EPA) has released under the recently amended Toxic Substances Control Act (TSCA).  This risk evaluation, which is now out for public comment, is on a chemical commonly called Pigment Violet 29, or PV29.  Among the many problems that immediately jumped out as we began our review of this draft evaluation are EPA’s reliance on clearly inadequate health and environmental hazard data to conclude the chemical is safe, as well as EPA’s illegal withholding from the public of the little hazard information it does have.[pullquote]I suppose if you start with almost no reliable data on a chemical, are dead set against using your enhanced authorities to get any more data, and are hell-bent on finding the chemical is safe, this is how you might choose to conduct a risk evaluation.[/pullquote]

This post will look at the other half of the risk equation, exposure.  EPA has even less information on exposures to PV29 than it does on hazard.  EPA has no actual data on the levels of PV29 released to or present in air, soil, sediment, surface water, people, other organisms, workplaces or products containing or made from the chemical.  It lacks any data from, and hasn’t used its authorities to require, monitoring in workplaces or any environmental media.

So what does EPA have?   Read More »