EDF Health

Selected tag(s): pesticides

Too little, too fast: EDF comments raise numerous concerns with EPA’s proposal to expand use of a toxic chemical

By / Bio / Published: March 13, 2018

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

Last month EDF blogged about  our request to the Environmental Protection Agency (EPA) to extend the illegally and unreasonably short 15-day comment period it had provided on a modification EPA is proposing to make to expand the ways a toxic chemical could be used, subject to certain conditions, without triggering any requirement to first notify EPA.  Specifically, EPA is proposing to modify the Significant New Use Rule (SNUR) applicable to the chemical – which currently limits its use to metalworking fluid – to allow the chemical also to be used as an anti-corrosive agent in in oilfield operations and hydraulic fluids.

Our request  also noted that EPA had failed to provide the public with anything approaching a complete set of documents relevant to its proposal.  For example, the public docket for the proposed modified SNUR lacked even a redacted copy of the Significant New Use Notice (SNUN) that triggered EPA’s consideration of the expanded use.

EPA’s proposal to amend the SNUR noted that, while EPA was expanding the allowable uses of the chemical, it was also proposing to impose additional conditions on the use.  These conditions were necessary, EPA argued, because of “test data on the substance and on new data regarding the expected release of formaldehyde from the substance, for skin and eye irritation, neurotoxicity, mutagenicity, oncogenicity, allergic responses, and developmental toxicity.”

Yet the docket did not include copies of these health and safety studies or the test data, despite being referred to in the proposal and in other documents that are in the docket.  As a reminder, such health and safety studies and their underlying data must be made public under the Toxic Substances Control Act (TSCA).  And of course, access to them is crucial if the public is expected to comment on EPA’s proposal.

A few days before the end of the 15-day comment period, EPA did grant a 17-day extension.  It also added a copy of the SNUN to the docket.  But it failed to add any of the health and safety studies or associated data we had identified as missing.

The comment period ended yesterday, and despite the serious time constraint and information gaps, EDF filed these extensive comments last night.  In preparing our comments, however, we found that the amount of health and safety data EPA had failed to provide is even greater than we had originally thought.  And our concerns over the adequacy of EPA’s review of this new proposed use and of the conditions it proposes to include in the modified SNUR have only grown.   Read More »

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EPA proposes limits on hypochlorite bleach to reduce degradation to perchlorate

By / Published: November 17, 2017

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

Every 15 years, the Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) reviews the safety of registered pesticides. The current cycle ends in 2022. As part of that process, the agency is evaluating the safety of hypochlorite bleaches. In January 2017, EPA decided it would consider the risks posed by degradation of the hypochlorite into perchlorate.

This is important for two reasons: 1) degraded bleach is less effective as a pesticide, and 2) perchlorate is a chemical that interferes with the production of thyroid hormone, a critical hormone for fetal and infant brain development.

On September 22, EPA proposed changes to the pesticide label to minimize the degradation for hypochlorite bleach used to disinfect drinking water, and the agency is accepting comments until November 21, 2017. The label would advise users to:

  • Minimize storage time;
  • Maintain pH of the solution between 11 to 13;
  • Minimize exposure to sunlight;
  • Store at lower temperatures; and
  • If practical, dilute with cool softened water upon delivery.

EDF submitted comments to EPA supporting EPA’s proposal and requesting specific changes to the proposed language, including making the advice to users mandatory. We also asked the agency to extend the label requirements to hypochlorite bleach used to treat produce and to disinfect food handling equipment. Bleach appears to be one of several significant sources of perchlorate contamination of food. Improving management conditions will reduce degradation and preserve effectiveness regardless of the whether the bleach is used in drinking water or to treat vegetables.

EPA’s proposal is an interim decision. We also were pleased to see that OPP is committed to continue working with EPA’s Office of Water (OW) in its assessment of the risks of perchlorate to pregnant women and young children. We asked OPP to incorporate the OW’s findings in additional interim registration decisions for all uses of hypochlorite bleaches.

 

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Estimating chemical risk: Breadth (prevalence) may be just as important as depth (magnitude of effect)

By / Bio / Published: April 23, 2012

Jennifer McPartland, Ph.D., is a Health Scientist.

Earlier this month Dr. David Bellinger at Boston Children’s Hospital published a very interesting paper in Environmental Health Perspectives offering a new way to consider the importance of various risk factors for child neurodevelopment—such as pre-existing medical conditions, poor nutritional status or harmful chemical exposures—at the population level.  “A Strategy for Comparing the Contributions of Environmental Chemicals and Other Risk Factors to Neurodevelopment of Children” argues that, in evaluating the contribution of a risk factor to a health outcome, it is critical to consider not only the magnitude of its effect on the health outcome, but also the prevalence of that risk factor in the population.

Dr. Bellinger argues: “Although a factor associated with a large impact would be a significant burden to a patient, it might not be a major contributor to the population if it occurs rarely.  Conversely, a factor associated with a modest but frequently occurring impact could contribute significantly to population burden.”  The former “disease-oriented” approach has generally been used to estimate the burden of harmful chemical exposures to population health, rather than the latter “population-oriented” approach.  Relying solely on the former approach, he contends, may result in an underestimation of the impact of a chemical exposure or other risk factor on public health.  Read More »

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Exposing our ignorance: EPA study reveals barren exposure data landscape

By / Bio / Published: March 16, 2012

Jennifer McPartland, Ph.D., is a Health Scientist.

This past November, EPA scientists published a sobering paper, “The exposure data landscape for manufactured chemicals,” in the journal Science of the Total Environment.  The paper reveals how little systematic information we have about human and environmental exposures to the thousands of chemicals in use today.

The aim of the study was “to define important aspects of the [chemical] exposure space and to catalog the available exposure information for chemicals being considered for analysis as part of the U.S. EPA ToxCast screening and prioritization program.”  Its conclusion:  “The results suggest that currently available exposure data are insufficient to provide the evidence base required to inform risk assessment and public health decision making.”  Not good, but not surprising.  Read on for more detail. Read More »

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ECHA adds seven more Substances of Very High Concern to REACH Candidate List

By / Published: June 2, 2011

Allison Tracy is a Chemicals Policy Fellow. Richard Denison, Ph.D., is a Senior Scientist.

The European Chemicals Agency (ECHA) issued a press release on Tuesday announcing the addition of seven chemicals to the Candidate List of Substances of Very High Concern (SVHC) under the European Union’s REACH Regulation.  [Update 6/20/11:  The formal addition of these substances to the candidate list, the initial announcement of which this post addressed, happened today.  See ECHA’s press release, which also contains some additional information about the uses of these chemicals.  The full candidate list including these seven substances is available here.]

All of the chemicals are officially classified as Carcinogenic, Mutagenic or Reproductive toxicants (CMRs).  Their addition brings the total number of chemicals on the Candidate List to 53.  Adding a chemical to REACH’s Candidate List is the first step toward subjecting it to REACH’s Authorization process, whereby the chemical can be used only if specifically authorized by EU authorities.

In this brief post we present a bit more information on these latest seven SVHCs, including the extent of their presence in U.S. commerce and their main uses.  Read More »

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

By / Bio / 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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