EDF Health

Selected tag(s): Risk assessment

EDF comments at EPA’s public stakeholder meeting on its IRIS Program

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

I provide in this post the comments I delivered as a panelist at the Environmental Protection Agency’s (EPA’s) November 13, 2012 Public Stakeholder Meeting on its Integrated Risk Information System (IRIS) program.  EPA describes IRIS as “a human health assessment program that evaluates information on health effects that may result from exposure to environmental contaminants.”

 

The theme of my comments today is the critical need to restore balance to the IRIS program.  In my view, the program’s structure and practice have over time tilted badly toward allowing one set of interests and desirable attributes of chemical assessments to wholly dominate over another, equally critical set.  Let me explain.  Read More »

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Despite TSCA-like law, there is movement down under on chemical safety

Alissa Sasso is a Chemicals Policy Fellow.

Australia’s chemical law, dating back to 1989, in many ways resembles the U.S. Toxic Substances Control Act of 1976 (TSCA).   Australia, however, has begun taking steps to address tens of thousands of existing chemicals at a scale that has not been taken in the U.S.  These steps come in the wake of government and stakeholder recognition that Australia’s TSCA-like approach to chemicals management is inadequate and in need of revision.  Read More »

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Repost: The new Safe Chemicals Act fulfills every detail of ACC’s 10 “Principles for Modernizing TSCA”

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

[NOTE:  I am reposting this piece, given that it was first posted during the dog days of August and I don’t want those interested to have missed it in digging out from time away from the office.  If you have an interest in understanding just how much the Safe Chemicals Act has changed to account for earlier industry concerns, please take the time to look at the analysis I’ve done comparing the bill to ACC’s TSCA Principles.]

You wouldn’t know it from listening to the American Chemistry Council (ACC) talk about the Safe Chemicals Act, but the new and improved version of the bill that was passed out of the Senate Environment & Public Works Committee on July 25 closely mirrors every detail of ACC’s 10 “Principles for Modernizing TSCA.”.

Those principles, issued in August of 2009, represent a key reference point given that they are virtually the only somewhat detailed public articulation by ACC of its substantive position on TSCA reform, one to which ACC continues to refer today.  In describing its principles, ACC says they “create a roadmap to a modern chemical regulatory system that will protect public health and the environment, while preserving the ability of American chemical companies to drive innovation, grow jobs, and compete in the global marketplace.”

ACC indicated in its statement on the revised bill that it only conducted a “cursory review” of the bill language, which perhaps explains why it got even some basics wrong.  One example:  ACC claims “[t]he bill would also dramatically increase the time it would take for the Environmental Protection Agency (EPA) to review new chemicals.”  In fact, the revised bill retains the 90-day review period for new chemicals operable under current TSCA.

So how does the bill stack up against ACC’s 10 Principles for TSCA Modernization?  Read More »

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The new Safe Chemicals Act fulfills every detail of ACC’s 10 “Principles for Modernizing TSCA”

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

You wouldn’t know it from listening to the American Chemistry Council (ACC) talk about the Safe Chemicals Act, but the new and improved version of the bill that was passed out of the Senate Environment & Public Works Committee on July 25 closely mirrors every detail of ACC’s 10 “Principles for Modernizing TSCA.”.

Those principles, issued in August of 2009, represent a key reference point given that they are virtually the only somewhat detailed public articulation by ACC of its substantive position on TSCA reform, one to which ACC continues to refer today.  In describing its principles, ACC says they “create a roadmap to a modern chemical regulatory system that will protect public health and the environment, while preserving the ability of American chemical companies to drive innovation, grow jobs, and compete in the global marketplace.”

ACC indicated in its statement on the revised bill that it only conducted a “cursory review” of the bill language, which perhaps explains why it got even some basics wrong.  One example:  ACC claims “[t]he bill would also dramatically increase the time it would take for the Environmental Protection Agency (EPA) to review new chemicals.”  In fact, the revised bill retains the 90-day review period for new chemicals operable under current TSCA.

So how does the bill stack up against ACC’s 10 Principles for TSCA Modernization?  Read More »

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The beat goes on with 13 new additions to the Candidate List under REACH

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

The number of chemicals identified as “substances of very high concern” (SVHCs) in the European Union continues to grow.  With today’s addition of 13 new chemicals, there are now 84 entries (representing 92 Chemical Abstract Service (CAS) registration numbers) on REACH’s Candidate List for Substances of Very High Concern for Authorisation.

The European Chemicals Agency (ECHA) added the 13 chemicals based on each chemical’s classification as Carcinogenic, Mutagenic, or Toxic for Reproduction (CMR).  [UPDATE:  Of the new batch, two are among the 83 TSCA workplan chemicals recently identified by EPA as priorities for risk assessment, and five were reported as being in U.S. commerce in 2006.  With the new addition, a total of 48 of the 92 CAS numbers on the Candidate List were reported as in commerce in the U.S. in 2006.  Additionally, 20 of the 92 CAS numbers on the Candidate List are included among the TSCA workplan chemicals.] Read More »

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

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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