Richard Denison, Ph.D., is a Lead Senior Scientist.
Nary a day goes by without a complaint being lodged by someone in the chemical industry, or in one of the myriad law firms that represent its interests in Washington, D.C., about the delays in EPA’s approval of new chemicals under the Toxic Substances Control Act (TSCA).
Here’s the irony: Those delays and the general chaos in the TSCA new chemicals program are entirely of the industry’s own making. Read More
Richard Denison, Ph.D., is a Lead Senior Scientist.
News reports today indicate that the President is nominating Alexandra Dapolito Dunn for Assistant Administrator of EPA’s Office of Chemical Safety and Pollution Prevention, which implements the Toxic Substances Control Act (TSCA).
Here is our first take on what she will be facing and need to do, if confirmed:
The major reforms Congress made to TSCA in 2016 passed with strong bipartisan support because they struck a careful balance among competing interests. Since that time, however, every aspect of the law’s implementation by the Trump Administration has gone badly off the rails, skewed heavily in the chemical industry’s favor at the expense of the public’s health.
In EDF’s view, any credible nominee for the OCSPP Assistant Administrator needs to understand and acknowledge this stark imbalance and take steps to address it. The AA should be able and willing to facilitate a fundamental shift in TSCA implementation back to a course that comports with the law, reflects strong science, and is protective of public and worker health, including that of vulnerable subpopulations.
If she is confirmed, Ms. Dunn will have her work cut out for her, given the forces arrayed within and outside the agency that have led to the current imbalance. That is a challenge that will need to be faced head-on.
Ryan O’Connell is a High Meadows Fellow; Jennifer McPartland, Ph.D., is a Senior Scientist.
Last night, Environmental Defense Fund (EDF) submitted critical comments on EPA’s Office of Pollution Prevention and Toxics’ (OPPT) “systematic review” document that OPPT is using to evaluate chemicals’ risks under the Toxic Substances Control Act (TSCA).
Systematic review, a hallmark of the clinical sciences, employs structured approaches to identifying, evaluating, and integrating evidence in a manner that promotes scientific rigor, consistency, transparency, objectivity, and reduction of bias.
Unfortunately, OPPT’s systematic review document deviates dramatically from the best practices in systematic review—practices developed over decades based on empirical evidence and experience in application. OPPT’s approach also significantly diverges from recent recommendations of the National Academy of Sciences (see here and here).
Richard Denison, Ph.D., is a Lead Senior Scientist.
Last night, Environmental Defense Fund (EDF) submitted more than 200 pages of comments providing a detailed critique of each of the “problem formulations” EPA issued in June for the first 10 chemicals in commerce undergoing risk evaluations under the Toxic Substances Control Act (TSCA). EDF also delivered 45,000 comments to EPA from members of the public across the country echoing our concerns.
The EPA documents lay out the scope of each of the risk evaluations EPA will conduct. They are highly flawed and deviate in numerous ways both from what TSCA requires and from use of the best available science. Read More
Richard Denison, Ph.D., is a Lead Senior Scientist.
I’ve been blogging over the last week about how political appointees at EPA are starting to clear new chemicals to enter commerce based on a new – apparently unwritten and certainly not public – review process that ignores the law and will put the health of the public, workers and the environment at greater risk than even under the weak reviews conducted before Congress’ 2016 overhaul of the Toxic Substances Control Act (TSCA).
The first green light was given to a fragrance chemical intended for use in a wide array of everyday consumer products. Here is its formal name, a simpler synonym used by its manufacturer, and an identifier called a CAS number:[pullquote]Late in the review process EPA switched to analogue chemicals to estimate toxicity that are 500-fold less toxic than the analogue identified by the company and EPA’s own models.[/pullquote]
In this post I want to look more at what is known – and not known – about the chemical’s hazards. While the chemical is a polymer, it includes “low molecular weight (LMW) components” that are the primary hazard concern. Read More
Richard Denison, Ph.D., is a Lead Senior Scientist.
I blogged last week about how political appointees at EPA are starting to clear new chemicals to enter commerce based on a new – apparently unwritten and certainly not public – review process that ignores the law and will put the health of the public, workers and the environment at greater risk than even under the weak reviews conducted before Congress’ 2016 overhaul of the Toxic Substances Control Act (TSCA).
In this post I’ll start to take a deeper look at the specific fragrance chemical that is the subject of EPA’s first decision under the new scheme:
Oxirane, 2-methyl-, polymer with oxirane, bis[2-[(1-oxo-2-propen-1-yl)amino]propyl] ether
CAS 1792208-65-1
Recall that, even as it declared the chemical safe, EPA noted its “potential for the following human health hazards: irritation, mutagenicity, developmental/ reproductive toxicity, neurotoxicity, and carcinogenicity.” I’ll explore those hazard concerns more in a subsequent blog post. Here, let’s consider use of and exposure to the chemical.[pullquote]Here’s the thing: None of the parameters of the intended use is binding. They can be deviated from at any time without consequence.[/pullquote]
With its decision, EPA has allowed this chemical to enter the market without any conditions whatsoever placed on how or how much of it can be produced or used or by whom. This is in fact the aim of the new scheme and, barring another change in course, we can now expect this outcome for the great majority of new chemicals EPA reviews. It will be achieved by EPA routinely making determinations that the chemicals are “not likely to present an unreasonable risk.” Read More