{"id":6377,"date":"2017-04-10T12:35:53","date_gmt":"2017-04-10T17:35:53","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=6377"},"modified":"2024-02-12T11:01:56","modified_gmt":"2024-02-12T16:01:56","slug":"where-theres-smoke-there-are-mirrors-the-trump-administrations-claim-to-preserve-tsca-implementation-under-its-proposed-epa-budget-is-pure-illusion","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2017\/04\/10\/where-theres-smoke-there-are-mirrors-the-trump-administrations-claim-to-preserve-tsca-implementation-under-its-proposed-epa-budget-is-pure-illusion\/","title":{"rendered":"Where there\u2019s smoke, there are mirrors: The Trump Administration\u2019s claim to preserve TSCA implementation under its proposed EPA budget is pure illusion"},"content":{"rendered":"<p><em>Richard Denison, Ph.D.,\u00a0<\/em>is a Lead Senior Scientist.<\/p>\n<p>As more details emerge about the Trump Administration\u2019s proposed budget cuts, it\u2019s becoming clearer that <a href=\"https:\/\/www.theatlantic.com\/politics\/archive\/2017\/03\/trumps-epa-cuts-budget\/521223\/\">the public\u2019s health could well take one of the worst hits<\/a>.\u00a0 Trump has proposed a 31% cut to the budget of the Environmental Protection Agency (EPA), paired with similarly deep reductions in staff.\u00a0 The details are laid out in a <a href=\"https:\/\/assets.documentcloud.org\/documents\/3534381\/Combined.pdf\">March 21, 2017, internal memo from EPA\u2019s Acting Chief Financial Officer<\/a>.<\/p>\n<p>Among the biggest cuts are to the Agency\u2019s research, both research it conducts and that undertaken by labs and universities it helps fund.\u00a0 EPA Office of Research and Development (ORD) would see its funding cut nearly in half, from $483 million to $250 million in 2018. The axe would fall across the full spectrum of EPA\u2019s research:\u00a0 air, climate, and energy; human health risk assessment; safe and sustainable water; sustainable communities; homeland security; and chemical safety. \u00a0EPA\u2019s extramural STAR grant program would be entirely eliminated.<\/p>\n<p>Scroll through Attachment A of the memo and you\u2019ll see program after program proposed to be eliminated or slashed.\u00a0 But there is a notable exception, on p. 9 of the Attachment:\u00a0 an apparent increase for an item labeled \u201cOCSPP \/ EPM \/ Toxic Substances: Chemical Risk Review and Reduction,\u201d accompanied by this explanation:\u00a0 \u201cThis program change increases $13,834K in non-pay resources in support of the new work required under the updated TSCA law.\u201d<\/p>\n<p>On one level, this seems like a bright spot in an otherwise dismal document, though it appears that the increase is in anticipation of the fees that the new TSCA authorizes EPA to collect from industry to help offset up to 25% of program costs.\u00a0 Still, unlike most of the rest of the Agency, the program\u2019s base budget is proposed to remain essentially intact.<\/p>\n<p>No doubt this reflects the strong bipartisan support that led to last year\u2019s passage of the Lautenberg Act and the continuing need for the chemical industry to be able to point to a viable federal chemical safety program in order to restore public and market confidence and seek to temper state and market action to restrict dangerous chemicals.\u00a0 (I\u2019ve recently blogged, however, about the mixed signals being sent by the industry; see <a href=\"https:\/\/blogs.edf.org\/health\/2017\/02\/09\/no-chemical-industry-you-cant-have-your-cake-and-eat-it-too-part-1\/\">here<\/a> and <a href=\"https:\/\/blogs.edf.org\/health\/2017\/02\/10\/no-chemical-industry-you-cant-have-your-cake-and-eat-it-too-part-2\/\">here<\/a>.)<\/p>\n<p>While this may seem like good news, the notion that EPA could somehow neatly carve out one program area and keep it functioning well when the carving knives are rampantly slashing everything around it is, well, preposterous. \u00a0<!--more--><\/p>\n<p>A functioning TSCA office at EPA is highly dependent on many other functions within the Agency.\u00a0 I\u2019ll just name two here for starters, both of which are housed within ORD and are proposed for near or total elimination under Mr. Trump\u2019s proposed budget:<\/p>\n<ul>\n<li><strong>EPA\u2019s <\/strong><a href=\"https:\/\/www.epa.gov\/iris\"><strong>Integrated Risk Information System (IRIS)<\/strong><\/a><strong> would be zeroed out (see references to IRIS on pages 19 and 21 of Attachment A of the budget memo).<\/strong> Yet EPA\u2019s ability to conduct risk evaluations under the new TSCA would be severely curtailed by the loss of both expertise and capacity that resides in the IRIS program.\u00a0 IRIS conducts hazard characterizations of chemicals, providing hazard values that other EPA offices combine with exposure information to characterize risk.\u00a0 Of the risk evaluations underway for the <a href=\"https:\/\/www.epa.gov\/newsreleases\/epa-names-first-chemicals-review-under-new-tsca-legislation\">first 10<\/a> so-called TSCA Work Plan chemicals, more than half have completed IRIS hazard assessments on which the TSCA office plans to build (these include asbestos, trichloroethylene (TCE), 1,4-dioxane, carbon tetrachloride, dichloromethane, and tetrachloroethylene), and for another IRIS has initiated an assessment (hexabromocyclododecane).<br \/>\nWhile IRIS has had its share of criticism in the past, major improvements have been made, leading the <a href=\"https:\/\/www.nap.edu\/catalog\/18764\/review-of-epas-integrated-risk-information-system-iris-process\">National Academy of Sciences <\/a>to applaud the program for embracing and quickly acting on its earlier recommendations.<\/li>\n<li><strong>EPA\u2019s ToxCast and related initiatives. <\/strong>Major cuts are proposed to EPA\u2019s \u201c<a href=\"https:\/\/www.epa.gov\/aboutepa\/about-chemical-safety-sustainability-research-program\">Chemical Safety for Sustainability<\/a>\u201d research program: a 44% reduction in budget and 22% cut in staffing (see references to \u201cChemical Safety and Sustainability\u201d <em>[sic] <\/em>on page 20 of Attachment A of the budget memo).\u00a0 This program has been shepherding the development of high-throughput testing and other predictive toxicology methods and computational tools that hold enormous promise to provide far more information on chemicals than has been possible in the past, and to do so at far less expense and with the use of far fewer laboratory animals.\u00a0 The need to further develop these approaches has been embraced by the entire spectrum of TSCA stakeholders, from industry to health and environmental organizations to animal welfare groups.\u00a0\u00a0 Given the large number of chemicals regulated under TSCA for which major data gaps exist, the TSCA reform legislation enacted last year has numerous provisions that call on EPA to advance the development and use of these methods.<\/li>\n<\/ul>\n<p>In addition, cross-cutting functions that would suffer deep budget cuts are essential for a functioning TSCA office. \u00a0For example, effective and equitable enforcement is critical to ensure not only that requirements are met, but also that companies in compliance are not put at a competitive disadvantage relative to companies that aren\u2019t. \u00a0Yet the enforcement office is cut by 23 percent, rewarding the cheaters, rather than the large majority of businesses who work to comply with the law.<\/p>\n<p>I cite these examples to illustrate how utterly impossible \u2013 and how short-sighted and counterproductive \u2013 it is to cut to the bone the core functions of EPA and then pretend that a \u201cTSCA island\u201d can still somehow thrive or even survive.<\/p>\n<p>My EDF colleague Jack Pratt summed up in a single sentence just how crazy this approach is:\u00a0 \u201cYou can\u2019t burn down my house, and then expect me to cook you dinner because the kitchen is still standing.\u201d<\/p>\n<p>&nbsp;<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Richard Denison, Ph.D.,\u00a0is a Lead Senior Scientist. As more details emerge about the Trump Administration\u2019s proposed budget cuts, it\u2019s becoming clearer that the public\u2019s health could well take one of the worst hits.\u00a0 Trump has proposed a 31% cut to the budget of the Environmental Protection Agency (EPA), paired with similarly deep reductions in staff.\u00a0 &#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":[44,114108],"tags":[68,56107],"coauthors":[],"class_list":["post-6377","post","type-post","status-publish","format-standard","hentry","category-policy","category-tsca","tag-epa","tag-lautenberg-act"],"acf":[],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/6377","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=6377"}],"version-history":[{"count":1,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/6377\/revisions"}],"predecessor-version":[{"id":12791,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/6377\/revisions\/12791"}],"wp:attachment":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media?parent=6377"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/categories?post=6377"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/tags?post=6377"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/coauthors?post=6377"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}