{"id":1586,"date":"2011-09-20T05:30:30","date_gmt":"2011-09-20T10:30:30","guid":{"rendered":"http:\/\/blogs.edf.org\/nanotechnology\/?p=1586"},"modified":"2024-02-12T11:01:17","modified_gmt":"2024-02-12T16:01:17","slug":"accs-chemical-prioritization-tool-helpful-but-flawed-and-off-the-mark-for-epa-to-use-without-tsca-reform","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2011\/09\/20\/accs-chemical-prioritization-tool-helpful-but-flawed-and-off-the-mark-for-epa-to-use-without-tsca-reform\/","title":{"rendered":"ACC\u2019s chemical prioritization tool: Helpful, but flawed and off the mark for EPA to use without TSCA reform"},"content":{"rendered":"<p><em>Richard Denison, Ph.D.<\/em><em>, is a Senior Scientist.<\/em><\/p>\n<p><span style=\"font-size: small\">As I noted in <\/span><a href=\"http:\/\/blogs.edf.org\/nanotechnology\/2011\/09\/13\/avoiding-paralysis-by-analysis-epa-proposes-a-sensible-approach-to-identifying-chemicals-of-concern\/\"><span style=\"color: #59595b;font-size: small\">my last post<\/span><\/a><span style=\"font-size: small\">, the <\/span><a href=\"http:\/\/www.americanchemistry.com\/Media\/PressReleasesTranscripts\/ACC-news-releases\/ACC-Proposes-New-System-to-Prioritize-Chemicals-for-Review.html\"><span style=\"color: #00338d;font-size: small\">American Chemistry Council (ACC) issued<\/span><\/a><span style=\"font-size: small\"> its own <\/span><a href=\"http:\/\/www.americanchemistry.com\/Prioritization-Document\"><span style=\"color: #00338d;font-size: small\">\u201cprioritization tool\u201d<\/span><\/a><span style=\"font-size: small\"> in anticipation of the Environmental Protection Agency\u2019s (EPA) public meetings\u00a0 to get input on the approach it will use to identify additional chemicals of concern under its <\/span><a href=\"http:\/\/www.epa.gov\/oppt\/existingchemicals\/pubs\/enhanchems.html\"><span style=\"color: #59595b;font-size: small\">Enhanced Chemicals Management Program<\/span><\/a><span style=\"font-size: small\">.<\/span><\/p>\n<p><span style=\"font-size: small\">In the context of TSCA reform, various actors in the industry have long called for prioritization, often saying they support EPA\u2019s ability to get off to a quick start on identifying chemicals for further work \u2013 <\/span><a href=\"http:\/\/blogs.edf.org\/nanotechnology\/2009\/11\/18\/how-turn-a-quick-start-into-a-choke-point\/\"><span style=\"color: #59595b;font-size: small\">only to propose schemes that are more likely to do the opposite<\/span><\/a><span style=\"font-size: small\">.<\/span><\/p>\n<p><span style=\"font-size: small\">ACC itself has over time come off as a bit schizophrenic on prioritization, apparently being <\/span><a href=\"http:\/\/democrats.energycommerce.house.gov\/Press_111\/20090226\/testimony_acc.pdf\"><span style=\"color: #59595b;font-size: small\">for it<\/span><\/a><span style=\"font-size: small\"> before they were <\/span><a href=\"http:\/\/blogs.edf.org\/nanotechnology\/2010\/07\/30\/not-playing-nice-the-american-chemistry-council-solidifies-its-claim-to-being-the-industry-of-no\/\"><span style=\"color: #59595b;font-size: small\">against it<\/span><\/a><span style=\"font-size: small\">.\u00a0 ACC\u2019s release of its tool puts it squarely back in the pro-prioritization camp, but just what is it proposing?\u00a0 My sense is it\u2019s after something quite different from what EPA proposes, and frankly, different from what EPA is currently capable of deploying, given its limited authority and resources under TSCA.\u00a0 In this sense, ACC\u2019s proposal is more relevant in the context of TSCA reform, where we presumably would have an EPA with a mandate to review all chemicals in commerce, the authority to readily get the data it needs, and the resources required to execute the kind of comprehensive prioritization scheme ACC proposes.<\/span><\/p>\n<p><span style=\"font-size: small\">But setting that disconnect aside for the moment, let\u2019s delve a bit deeper into the ACC proposal on its own merits.\u00a0 <!--more--><\/span><\/p>\n<p><span style=\"font-size: small\">ACC\u2019s proposal is welcome in several ways:\u00a0 First, it\u2019s substantive and specific (which I haven\u2019t always been able to say about what ACC has offered in the past).\u00a0 It\u2019s so much easier to start working toward common ground when you know where the other guy is coming from.<\/span><\/p>\n<p><span style=\"font-size: small\">Second, there are some refreshing elements and acknowledgments:<\/span><\/p>\n<ul>\n<li><span style=\"font-size: small\">ACC at least implicitly notes (p. 2) that there are gaps in available hazard data for many chemicals \u2013 and that a chemical with such gaps should be elevated in priority to a high ranking.\u00a0 (Unfortunately, ACC makes no such provision for what is arguably an even larger knowledge gap for chemicals:\u00a0 data on use and exposure.\u00a0 This is one of several ways in which ACC\u2019s tool over-relies on limited exposure information.)<\/span><\/li>\n<li><span style=\"font-size: small\">Chemicals with multiple uses would be assigned the overall exposure ranking corresponding to the use with the greatest potential exposure (p. 5) \u2013 an appropriately conservative approach. \u00a0(Unfortunately, this is not the approach ACC uses in other cases; more below).<\/span><\/li>\n<li><span style=\"font-size: small\">ACC rightly criticizes at some length (p. 9) EPA\u2019s reliance on presence in children\u2019s products as insufficiently indicative of kids\u2019 exposure \u2013 noting, for example, that products used in the home but not by children may well lead to higher exposures.\u00a0 (Unfortunately, it relegates children\u2019s exposure potential to a second-tier consideration in prioritization.)<\/span><\/li>\n<li><span style=\"font-size: small\">ACC appropriately proposes using production volume (p. 6) as one of several surrogate measures of exposure \u2013 a bit ironic, given how much the industry railed against the European Union\u2019s REACH Regulation for doing the same.\u00a0 (Unfortunately, ACC reserves its \u201chigh\u201d ranking for those few chemicals annually produced at the staggeringly high level of 100 million pounds per year \u2013 <em>that\u2019s 100 times higher than the level EPA has designated as a high production volume (HPV) chemical<\/em>.)<\/span><\/li>\n<li><span style=\"font-size: small\">ACC proposes that EPA be able to use its professional judgment (p. 1) in certain aspects of prioritization \u2013 though it then appears to limit that allowance to hazard ranking (<em>not<\/em> exposure ranking!) and second-tier considerations.\u00a0 (And as we\u2019ll see below, little evidence of such flexibility is evident in the details of ACC\u2019s proposal.)<\/span><\/li>\n<\/ul>\n<p><span style=\"font-size: small\">There are also a number of quite problematic aspects of ACC\u2019s proposal:<\/span><\/p>\n<p><strong><span style=\"font-size: small\">Overly rigid rules applied in lockstep<\/span><\/strong><\/p>\n<p><span style=\"font-size: small\">For an organization that has frequently <\/span><a href=\"http:\/\/epw.senate.gov\/109th\/Walls_Testimony.pdf\"><span style=\"color: #59595b\"><span style=\"font-size: small\">asserted that the greatest strength of TSCA has been its <em>flexibility<\/em><\/span><\/span><\/a><span style=\"font-size: small\">, ACC has produced a remarkably rigid tool for prioritization.\u00a0 With calculator-like precision, neatly-assigned little numbers get tallied up in the ACC tool:\u00a0 Each element gets a numeric score, which are then added up and banded to yield crisp overall scores, which are finally assigned to high-, medium- and low- priority status.\u00a0 But the real world is not quite so reducible to simple arithmetic.<\/span><\/p>\n<p><span style=\"font-size: small\">ACC\u2019s tool demands EPA use certain \u201crules\u201d in the name of sound science and consistency: <\/span><\/p>\n<p><span style=\"font-size: small\"><em>The \u201cequal basis\u201d rule<\/em>:\u00a0 Most prominent among these rules is that \u201cthe hazard and exposure elements should be applicable across all substances being evaluated\u201d (p. 10), \u201crather than just those information elements available only for subsets of chemicals\u201d (p. 1).<\/span><\/p>\n<p><span style=\"font-size: small\">By this sleight of hand, ACC manages to rule out any types of information that may indicate a hazard or exposure of high concern unless it has been measured across basically all chemicals subject to prioritization.\u00a0 This rule may well help to explain ACC\u2019s relegation to a second-tier consideration any direct evidence of human or environmental exposure \u2013 e.g., biomonitoring and environmental release and media monitoring data \u2013 because such data aren\u2019t collected for all chemicals.\u00a0 ACC instead would have EPA resort to extremely narrow and rigid definitions and measurements of persistence and bioaccumulation potential even where direct real-world exposure data exist (more on this below).<\/span><\/p>\n<p><span style=\"font-size: small\">The lockstep application of this rule would have EPA ignore a chemical like perfluorooctanoic acid (PFOA) because it accumulates in blood rather than in fat tissue \u2013 the latter being the only kind of data that are available for many if not most chemicals and to which ACC restricts its bioaccumulation criterion.<\/span><\/p>\n<p><span style=\"font-size: small\">ACC\u2019s rule would also have EPA ignore other chemicals with unique or uncommon properties simply because either most chemicals haven\u2019t been examined for those properties or because those properties actually distinguish certain chemicals from most others.\u00a0 An example of the former might be a chemical deemed of concern because it is known to disrupt expression of a particular gene, while an example of the latter would be virtually all nanomaterials with unique size-dependent behavior that only shows up at the nanoscale.<\/span><\/p>\n<p><span style=\"font-size: small\"><em>High hazard <span style=\"text-decoration: underline\">and<\/span> high exposure<\/em>:\u00a0 A second such rigid rule in ACC\u2019s tool is that only chemicals for which high hazard <em>and<\/em> high exposure can be demonstrated warrant high priority.\u00a0 While such chemicals certainly merit prioritization, applying this as a hard-and-fast rule is overly limiting of professional judgment. <\/span><\/p>\n<p><span style=\"font-size: small\">I noted in my last post that <\/span><a href=\"http:\/\/www.americanchemistry.com\/Policy\/Chemical-Safety\/TSCA\/ACC-Proposes-New-Prioritization-Tool-to-Increase-Effectiveness-of-EPAs-Chemical-Review-Process.pdf\"><span style=\"color: #00338d;font-size: small\">ACC invokes the Canadian approach to categorization<\/span><\/a><span style=\"font-size: small\"> to support its tool.\u00a0 But ACC fails to point out that <\/span><a href=\"http:\/\/www.chemicalsubstanceschimiques.gc.ca\/about-apropos\/categor\/what-quoi-eng.php\"><span style=\"color: #59595b;font-size: small\">the criteria Canada used<\/span><\/a><span style=\"font-size: small\"> to screen its inventory included <em>separate<\/em> criteria for hazard and exposure, and any chemical meeting either advanced to the next stage.<\/span><\/p>\n<p><span style=\"font-size: small\">Given the large gaps in hazard and exposure data for many chemicals, it\u2019s simply shortsighted to automatically set aside as low priority any chemical for which evidence of both high hazard and high exposure is lacking \u2013 without any regard for how high the hazard <em>or<\/em> exposure might be.\u00a0 A potent developmental toxicant for which there is uncertainty about the extent to which pregnant women or infants are exposed may well warrant prioritization; likewise for a chemical released to the environment that is highly bioaccumulative and where there is suggestive but not definitive evidence of serious hazard. <\/span><\/p>\n<p><span style=\"font-size: small\">This need is especially acute given that one of the key actions to be taken on chemicals that are prioritized is to get more information on their hazards, uses and exposures \u2013 a step that would be forgone if a high-hazard or high-exposure chemical were set aside indefinitely.<\/span><\/p>\n<p><span style=\"font-size: small\">Over-relying on exposure information \u2013 appropriately called the <\/span><a href=\"http:\/\/www.jstor.org\/pss\/3434088\"><span style=\"color: #59595b;font-size: small\">\u201cweakest link\u201d in risk assessment<\/span><\/a><span style=\"font-size: small\"> \u2013 to relegate high-hazard chemicals to low priority is especially problematic \u2013 <\/span><a href=\"http:\/\/blogs.edf.org\/nanotechnology\/2009\/11\/11\/over-exposed-why-relying-on-exposure-to-prioritize-chemicals-is-dangerous\/\"><span style=\"color: #59595b;font-size: small\">a topic on which I have blogged at some length earlier<\/span><\/a><span style=\"font-size: small\">.<\/span><\/p>\n<p><span style=\"font-size: small\"><em>Persistent <span style=\"text-decoration: underline\">and<\/span> bioaccumulative<\/em>:\u00a0 A third rigid rule relates both to how ACC defines these P and B properties, and how ACC would only assign high priority to chemicals that are both P and B.\u00a0 Here again, ACC\u2019s invoking of Canada as the ideal approach fails to acknowledge that <\/span><a href=\"http:\/\/www.chemicalsubstanceschimiques.gc.ca\/about-apropos\/categor\/what-quoi-eng.php\"><span style=\"color: #59595b;font-size: small\">that country\u2019s criteria<\/span><\/a><span style=\"font-size: small\"> included chemicals that, in addition to being toxic, were found to be persistent <em>or<\/em> bioaccumulative.<\/span><\/p>\n<p><span style=\"font-size: small\">ACC\u2019s tool uses extremely narrow definitions of P and B, presumably due in part to the \u201cequal basis\u201d rationale that more data exist from tests based on the narrow definitions.\u00a0 The B definition, for example, assumes that the only means by which chemicals bioaccumulate is by being taken up from water into the fat tissue of aquatic organisms.\u00a0 Yet bioaccumulation can occur in other tissues (e.g., blood, bone) and by other routes, for example, through <\/span><a href=\"http:\/\/www.sciencemag.org\/content\/317\/5835\/236\"><span style=\"color: #59595b;font-size: small\">food-web uptake and accumulation by air-breathing animals<\/span><\/a><span style=\"font-size: small\">.<\/span><\/p>\n<p><span style=\"font-size: small\">Many chemicals that may not qualify as P or B using ACC\u2019s narrow definitions are for all intents and purposes persistent or bioaccumulative.\u00a0 This is often the case for chemicals that are frequently or even continuously released into the environment or to which people are routinely exposed.\u00a0 Bisphenol A is not P or B, yet shows up in the bodies of more than 90% of the American population.\u00a0 Why?\u00a0 Because exposure to it is ubiquitous and ongoing, it\u2019s being replaced as fast as it\u2019s being eliminated.\u00a0 It makes no sense for EPA to be required to ignore that fact.<\/span><\/p>\n<p><span style=\"font-size: small\">There\u2019s every reason to consider the data on P and B that ACC proposes be used \u2013 but there\u2019s also every reason not to stop there.\u00a0 Especially if data from biomonitoring and monitoring of environmental releases and media reveal direct evidence of persistence, EPA can and should consider this information in making prioritization decisions.\u00a0 Yet ACC\u2019s tool would relegate such data to at best second-class status.<\/span><\/p>\n<p><strong><span style=\"font-size: small\">Consistent use of the least conservative classification values<\/span><\/strong><\/p>\n<p><span style=\"font-size: small\">For toxicity, ACC proposes that EPA rely on classification criteria developed under the Globally Harmonized System (GHS) for Classification and Labeling (p. 1).\u00a0 <\/span><\/p>\n<p><span style=\"font-size: small\">(Now, I simply must stop here for a moment to flag a statement in ACC\u2019s document (p. 2) that I can only hope is an inadvertent \u2013 if gross \u2013misstatement.\u00a0 ACC claims that \u201cGHS classification information is <em>readily available for all substances<\/em>, as U.S. manufacturers have developed GHS classifications for their products to meet international requirements.\u201d\u00a0 But GHS does not require any company to generate any data where it doesn\u2019t already exist; it simply provides a means of classifying already available data.\u00a0 Because GHS provides criteria for dozens of different endpoints, I can imagine that most chemicals will have <em>some<\/em> data for <em>some<\/em> endpoints for which GHS provides classification criteria.\u00a0 But it is simply untrue that companies have data for all such endpoints.\u00a0 A very small number of chemicals have been tested for carcinogenicity, for example, yet GHS provides criteria for this endpoint.)<\/span><\/p>\n<p><span style=\"font-size: small\">But back to ACC\u2019s tool:\u00a0 I generally support ACC\u2019s proposal that EPA rely on GHS criteria, but with two caveats:\u00a0 First, GHS does not include every endpoint of concern, and its use should not limit EPA\u2019s ability to consider other health or environmental endpoints.<\/span><\/p>\n<p><span style=\"font-size: small\">Second, GHS\u2019 cutoff values must be used faithfully \u2013 and here, ACC fails badly.<\/span><\/p>\n<p><span style=\"font-size: small\">ACC\u2019s Table 2 (p. 3) lists what it says are cutoff values for repeat dose toxicity test data.\u00a0 But the table neglects to specify the corresponding test duration or to note that the cutoff values depend on the duration of the repeat dose test.\u00a0 Instead, ACC uses the least conservative values \u2013 those corresponding to the less commonly used 90-day test duration.\u00a0 Applying ACC\u2019s cutoff values to data from the much more commonly used 28-day repeat dose test would relegate what GHS would classify as a high-toxicity chemical to a lower ranking.\u00a0 See Table 6, p. 17, in <\/span><a href=\"http:\/\/www.epa.gov\/dfe\/alternatives_assessment_criteria_for_hazard_eval.pdf\"><span style=\"color: #59595b;font-size: small\">this EPA document<\/span><\/a><span style=\"font-size: small\"> summarizing the GHS repeat dose criteria.<\/span><\/p>\n<p><span style=\"font-size: small\">This is not the only case in which ACC has selected the least conservative cutoff values:<\/span><\/p>\n<ul>\n<li><span style=\"font-size: small\"><em>Persistence<\/em>:\u00a0 ACC\u2019s tool would designate any chemical with a degradation half-life in water, soil or sediment of less than 180 days as \u201cnon-persistent\u201d (p. 7).\u00a0 Yet EPA\u2019s own PBT criteria, also used in the New Chemicals Program, would classify chemicals with half-lives all the way down to 16 days as at least moderately persistent!\u00a0 Here are EPA\u2019s criteria (from Table 12, p. 23 in <\/span><a href=\"http:\/\/www.epa.gov\/dfe\/alternatives_assessment_criteria_for_hazard_eval.pdf\"><span style=\"color: #59595b;font-size: small\">this EPA document<\/span><\/a><span style=\"font-size: small\">):<\/span>\n<ul>\n<li><span style=\"font-size: small\">&gt; 180 days half-life = Very highly persistent<\/span><\/li>\n<li><span style=\"font-size: small\">60-180 days half-life = Highly persistent<\/span><\/li>\n<li><span style=\"font-size: small\">16-59 days half-life = Moderately persistent<\/span><\/li>\n<\/ul>\n<\/li>\n<li><span style=\"font-size: small\"><em>Bioaccumulation<\/em>:\u00a0 ACC\u2019s tool would only designate a chemical as bioaccumulative if its fish bioaccumulation factor (BAF) or bioconcentration factor (BCF) exceeded 5,000 (p. 7).\u00a0 Yet here again, EPA\u2019s own PBT criteria, also used in the New Chemicals Program, would classify chemicals with BAF or BCF values all the way down to 100 to be at least moderately bioaccumulative!\u00a0 Here are EPA\u2019s criteria (from Table 13, p. 24 in <\/span><a href=\"http:\/\/www.epa.gov\/dfe\/alternatives_assessment_criteria_for_hazard_eval.pdf\"><span style=\"color: #59595b;font-size: small\">this EPA document<\/span><\/a><span style=\"font-size: small\">):<\/span>\n<ul>\n<li><span style=\"font-size: small\">&gt;5000 BAF\/BCF = Very highly bioaccumulative<\/span><\/li>\n<li><span style=\"font-size: small\">1,000-5,000 BAF\/BCF = Highly bioaccumulative<\/span><\/li>\n<li><span style=\"font-size: small\">100-1,000 BAF\/BCF = Moderately bioaccumulative<\/span><\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<p><span style=\"font-size: small\">ACC\u2019s tool fails on two counts:\u00a0 Not only does it use the least conservative values, which would relegate many P and B chemicals to low priority.\u00a0 It also takes two critical chemical properties that manifest themselves along a broad continuum, and assigns a <em>single<\/em> bright line \u2013 when all authoritative bodies have explicitly acknowledged the continuous nature of such properties by designating multiple classification categories, ranging from very high to low or very low.<\/span><\/p>\n<p><strong><span style=\"font-size: small\">Over-relying on limited exposure information and discounting evidence of hazard<\/span><\/strong><\/p>\n<p><span style=\"font-size: small\">In several subtle ways, ACC\u2019s tool reflects its longstanding tendencies to over-rely on limited exposure information and discount evidence of hazard:<\/span><\/p>\n<ul>\n<li><span style=\"font-size: small\">The tool collapses its health hazard and environmental hazard rankings into a single score (albeit the higher of the two), whereas it combines scores for its three exposure elements.\u00a0 This means that a chemical that harms both people and other organisms only gets counted once, while a chemical that is low-volume and used only as an intermediate and is not P or B gets credit for being of low concern for all three attributes.<\/span><\/li>\n<li><span style=\"font-size: small\">The tool\u2019s scale for hazard runs from only 1-4, whereas its exposure scale runs from 1-5.\u00a0 Because these scores ultimately get combined, it\u2019s that much harder for a high-hazard chemical to get a high overall ranking than it is for a low-exposure ranking to get a low overall ranking. <\/span><\/li>\n<li><span style=\"font-size: small\">High-exposure scenarios that occur in industrial and commercial settings get discounted (Table 3, p. 5).\u00a0 Only chemicals with consumer exposure get a high ranking; this means that even if large numbers of workers are exposed to a very high-hazard chemical, that chemical automatically gets assigned a lower exposure priority.\u00a0 Again, this approach is too rigid:\u00a0 EPA needs to be able to elevate in priority a chemical where the risk to a subset of the population is disproportionately high.<\/span><\/li>\n<\/ul>\n<p><strong><span style=\"font-size: small\">Conclusion<\/span><\/strong><\/p>\n<p><span style=\"font-size: small\">While ACC\u2019s tool has some serious flaws and is not something that EPA has the authority or resources to utilize under current TSCA, ACC has put forth a serious proposal for prioritization that should help to raise the level of debate over this critical issue in TSCA reform.\u00a0 <\/span><\/p>\n","protected":false},"excerpt":{"rendered":"<p>Richard Denison, Ph.D., is a Senior Scientist. As I noted in my last post, the American Chemistry Council (ACC) issued its own \u201cprioritization tool\u201d in anticipation of the Environmental Protection Agency\u2019s (EPA) public meetings\u00a0 to get input on the approach it will use to identify additional chemicals of concern under its Enhanced Chemicals Management Program. &#8230;<\/p>\n","protected":false},"author":100,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[44,56096,114108],"tags":[39150,39168,641,5019,39153,39171,39192,39193],"coauthors":[],"class_list":["post-1586","post","type-post","status-publish","format-standard","hentry","category-policy","category-omboira","category-tsca","tag-american-chemistry-council","tag-biomonitoring","tag-canada","tag-consumer-products","tag-data-requirements","tag-exposure-vs-hazard","tag-globally-harmonized-system-ghs","tag-prioritization"],"acf":[],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/1586","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/users\/100"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/comments?post=1586"}],"version-history":[{"count":1,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/1586\/revisions"}],"predecessor-version":[{"id":12642,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/1586\/revisions\/12642"}],"wp:attachment":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media?parent=1586"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/categories?post=1586"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/tags?post=1586"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/coauthors?post=1586"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}