{"id":8343,"date":"2018-12-19T09:32:33","date_gmt":"2018-12-19T14:32:33","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=8343"},"modified":"2024-02-12T11:02:14","modified_gmt":"2024-02-12T16:02:14","slug":"the-trump-epas-first-risk-evaluation-under-the-new-tsca-is-a-house-of-cards","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2018\/12\/19\/the-trump-epas-first-risk-evaluation-under-the-new-tsca-is-a-house-of-cards\/","title":{"rendered":"The Trump EPA\u2019s first risk evaluation under the new TSCA is a house of cards"},"content":{"rendered":"

Richard Denison, Ph.D.,\u00a0<\/em>is a Lead Senior Scientist.<\/p>\n

I\u2019ve been blogging about <\/a>the deep problems surrounding the first draft risk evaluation the Trump Administration\u2019s Environmental Protection Agency (EPA) has released under the recently amended Toxic Substances Control Act (TSCA).\u00a0 This risk evaluation, which is now out for public comment, is on a chemical commonly called Pigment Violet 29<\/a>, or PV29.\u00a0 Among the many problems that immediately jumped out as we began our review of this draft evaluation are EPA\u2019s reliance on clearly inadequate health and environmental hazard data to conclude the chemical is safe, as well as EPA\u2019s illegal withholding from the public of the little hazard information it does have.[pullquote]I suppose if you start with almost no reliable data on a chemical, are dead set against using your enhanced authorities to get any more data, and are hell-bent on finding the chemical is safe, this is how you might choose to conduct a risk evaluation.<\/em><\/strong>[\/pullquote]<\/p>\n

This post will look at the other half of the risk equation, exposure.\u00a0 EPA has even less<\/em> information on exposures to PV29 than it does on hazard.\u00a0 EPA has no actual data on the levels of PV29 released to or present in air, soil, sediment, surface water, people, other organisms, workplaces or products containing or made from the chemical.\u00a0 It lacks any data from, and hasn\u2019t used its authorities to require, monitoring in workplaces or any environmental media.<\/p>\n

So what does EPA have?\u00a0\u00a0<\/p>\n

It has a personal communication from a conflicted industry source who claims \u201can approximate maximum workplace air concentration of 0.5 mg\/m3<\/sup> [milligrams per cubic meter] would be expected over a 12 hour shift\u201d at a PV29 manufacturing facility (see page 22 of the draft risk evaluation<\/a>).\u00a0 That number was provided to EPA by an employee of Sun Chemical, the only identified manufacturer of PV29 in the U.S., and \u2013 to state the obvious \u2013 an entity with a strong interest in having EPA find its chemical safe.\u00a0 All the public has to go on is a statement and reference in the risk evaluation that indicate a fellow at Sun Chemical named Robert C. Mott personally communicated this value to EPA on September 25, 2017.\u00a0 EPA has not even made the content of the personal communication public, nor has it provided or alluded to any actual data provided by Mott to support his statement.<\/p>\n

EPA cites this value, but then acknowledges it does not know what this workplace air value actually represents, noting the personal communication was not even clear whether the claimed value was for Pigment Violet 29 itself or for total dust.<\/p>\n

(Ironically, it appears that, in order to rely on this information, EPA had to exempt it from being scrutinized using its own TSCA Systematic Review approach.\u00a0 On page 18 of the draft risk evaluation<\/a>, EPA states that its systematic review approach \u201cis not well suited for the review\u201d of such \u201ccorrespondences with industry … used to inform the likelihood of exposure,\u201d and \u201c[a]s a result, formal data quality evaluation of these references according to the Application of Systematic Review in TSCA Risk Evaluations <\/em>(U.S. EPA, 2018a) was not conducted.\u201d)<\/p>\n

But it\u2019s what EPA does next with this unverified, conflicted single data point that is truly remarkable:<\/p>\n