{"id":9068,"date":"2019-09-03T13:30:19","date_gmt":"2019-09-03T18:30:19","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=9068"},"modified":"2024-02-12T11:02:20","modified_gmt":"2024-02-12T16:02:20","slug":"should-epa-grant-industrys-hypocritical-request-to-now-include-14-dioxanes-presence-as-a-byproduct-in-its-risk-evaluation-it-must-meet-a-number-of-conditions","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2019\/09\/03\/should-epa-grant-industrys-hypocritical-request-to-now-include-14-dioxanes-presence-as-a-byproduct-in-its-risk-evaluation-it-must-meet-a-number-of-conditions\/","title":{"rendered":"Should EPA grant industry\u2019s hypocritical request to now address 1,4-dioxane\u2019s risks as a byproduct, it must meet a number of conditions"},"content":{"rendered":"

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

Environmental Defense Fund (EDF) submitted extensive comments last week to the Environmental Protection Agency (EPA) that raise numerous serious concerns with EPA\u2019s draft risk evaluation for the likely human carcinogen 1,4-dioxane.\u00a0 EDF\u2019s comments are available here<\/a>.<\/p>\n

I want to use this post to highlight one of the many issues:\u00a0 For years, the industry has urged EPA not<\/em><\/strong> to include 1,4-dioxane\u2019s presence as a byproduct in various formulated products within the scope of its risk evaluation for the chemical; see comments specific to 1,4-dioxane from the American Cleaning Institute<\/a>, Procter & Gamble<\/a>, and the Household & Commercial Products Association<\/a>; and more general comments urging exclusions for byproducts and \u201ctrace levels\u201d from the American Chemistry Council<\/a> and the Consumer Specialty Products Association Comment<\/a>.<\/p>\n

Not surprisingly, the Trump EPA\u2019s draft risk evaluation for 1,4-dioxane did just that, a major problem EDF objected to on legal and scientific grounds<\/a>.<\/p>\n

Then in late July, the industry abruptly reversed itself. \u00a0A comment letter<\/a> submitted to EPA by the American Cleaning Institute and the Grocery Manufacturers Association says the industry has changed its mind and is now calling on EPA to include 1,4-dioxane\u2019s presence as a byproduct as a condition of use in its risk evaluation.<\/p>\n

Why the shift?\u00a0 At this late hour it has dawned on the industry groups that any final action by the agency on the chemical that excludes 1,4-dioxane\u2019s presence as a byproduct as a condition of use in its risk evaluation will not preempt states from acting to regulate this condition of use.<\/p>\n

The industry\u2019s hypocrisy aside, if EPA decides to grant this industry request, which has arrived long after EPA initiated the risk evaluation process, EPA should do so only subject to conditions that are critical to meet if its decision and risk evaluation are to maintain any semblance of credibility:<\/p>\n